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UNITED STATES OF AMERICA

BEFORE THE FEDERAL TRADE COMMISSION

In the Matter of 

SHORE TO PLEASE VACATIONS LLC, a limited 

liability company, and 

ROBERT AARON STEPHENS, individually and as 

manager of SHORE TO PLEASE VACATIONS LLC. 

FILE NO. 182-3088 

AGREEMENT CONTAINING 

CONSENT ORDER

The Federal Trade Commission (“Commission”) has conducted an investigation of certain 

acts and practices of Shore to Please Vacations LLC and Robert Aaron Stephens (collectively, 

“Proposed Respondents”). The Commission’s Bureau of Consumer Protection (“BCP”) has 

prepared a draft of an administrative Complaint (“draft Complaint”). BCP and Proposed 

Respondents, individually or through their duly authorized managers, enter into this Agreement 

Containing Consent Order (“Consent Agreement”) to resolve the allegations in the attached draft 

Complaint through a proposed Decision and Order to present to the Commission, which is also 

attached and made a part of this Consent Agreement. 

IT IS HEREBY AGREED by and between Proposed Respondents and BCP, that:

1. The Proposed Respondents are:

a. Proposed Respondent Shore to Please Vacations LLC, a Nevada limited liability 

company, registered to do business in Florida, with its principal office or place of 

business at 8033 West Sunset Boulevard, #1079, West Hollywood, California 90046. 

b. Proposed Respondent Robert Aaron Stephens, the owner and manager of Shore to Please 

Vacations LLC. Individually or in concert with others, he formulates, directs, or controls 

the policies, acts, or practices of Shore to Please Vacations LLC. His principal office or 

place of business is the same as that of Shore to Please Vacations LLC. 

2. Proposed Respondents neither admit nor deny any of the allegations in the Complaint, except

as specifically stated in the Decision and Order. Only for purposes of this action, Proposed 

Respondents admit the facts necessary to establish jurisdiction. 

3. Proposed Respondents waive:

a. Any further procedural steps;
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b. The requirement that the Commission’s Decision contain a statement of findings of fact 

and conclusions of law; and 

c. All rights to seek judicial review or otherwise to challenge or contest the validity of the 

Decision and Order issued pursuant to this Consent Agreement. 

4. This Consent Agreement will not become part of the public record of the proceeding unless 

and until it is accepted by the Commission. If the Commission accepts this Consent Agreement, 

it, together with the draft Complaint, will be placed on the public record for 30 days and 

information about them publicly released. Acceptance does not constitute final approval, but it 

serves as the basis for further actions leading to final disposition of the matter. Thereafter, the

Commission may either withdraw its acceptance of this Consent Agreement and so notify each 

Proposed Respondent, in which event the Commission will take such action as it may consider 

appropriate, or issue and serve its Complaint (in such form as the circumstances may require) 

and decision in disposition of the proceeding, which may include an Order. See Section 2.34 of 

the Commission’s Rules, 16 C.F.R. § 2.34 (“Rule 2.34”). 

5. If this agreement is accepted by the Commission, and if such acceptance is not subsequently 

withdrawn by the Commission pursuant to Rule 2.34, the Commission may, without further 

notice to Proposed Respondents: (1) issue its Complaint corresponding in form and substance 

with the attached draft Complaint and its Decision and Order; and (2) make information about 

them public. Proposed Respondents agree that service of the Order may be effected by its 

publication on the Commission’s website (ftc.gov), at which time the Order will become final. 

See Rule 2.32(d). Proposed Respondents waive any rights they may have to any other manner of 

service. See Rule 4.4. 

6. When final, the Decision and Order will have the same force and effect and may be altered, 

modified, or set aside in the same manner and within the same time provided by statute for other 

Commission orders. 

7. The Complaint may be used in construing the terms of the Decision and Order. No 

agreement, understanding, representation, or interpretation not contained in the Decision and 

Order or in this Consent Agreement may be used to vary or contradict the terms of the Decision 

and Order. 

8. Each Proposed Respondent agrees to comply with the terms of the proposed Decision and 

Order from the date that Proposed Respondent signs this Consent Agreement. Proposed 

Respondents understand that they may be liable for civil penalties and other relief for each 

violation of the Decision and Order after it becomes final.
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SHORE TO PLEASE VACATIONS LLC

By: ______________________________ 

 Robert Aaron Stephens 

 Managing Member

 Date: ________________________ 

ROBERT AARON STEPHENS

By: ______________________________ 

 Robert Aaron Stephens, individually 

and as Managing Member of Shore to 

Please Vacations LLC

 Date: ________________________ 

______________________________ 

Daniel W. Uhlfelder, Esq.

Daniel W. Uhlfelder, P.A. 

124 East County Highway 30A 

Santa Rosa Beach, Florida 32459 

Attorney for Shore to Please Vacations 

LLC and Robert Aaron Stephens 

Date: ________________________ 

FEDERAL TRADE COMMISSION

By: ______________________________ 

Carl H. Settlemyer, III

 Attorney 

Division of Advertising Practices

APPROVED:

 ______________________________ 

Mary K. Engle

Associate Director

Division of Advertising Practices

 ______________________________ 

 Andrew M. Smith 

Director

 Bureau of Consumer Protection 

Date: ________________________