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Case 4:18-cv-00806-SBA Document 165 Filed 09/07/18 Page 1 of 3 

ALDEN F. ABBOT 

General Counsel 

SARAH SCHROEDER, Cal. Bar No. 221528 

ROBERTA TONELLI, Cal. Bar No. 278738 

EVAN ROSE, Cal. Bar No. 253478 

Federal Trade Commission 

901 Market Street, Suite 570 

San Francisco, CA 94103 

sschroeder@ftc.gov, rtonelli@ftc.gov, erose@ftc.gov 

Tel: (415) 848-5100; Fax: (415) 848-5184 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

OAKLAND DIVISION 

FEDERAL TRADE COMMISSION, 

Plaintiff, 

vs. 

AMERICAN FINANCIAL BENEFITS CENTER, 

a corporation, also d/b/a AFB and AF STUDENT 

SERVICES; 

AMERITECH FINANCIAL, a corporation; 

FINANCIAL EDUCATION BENEFITS CENTER, 

a corporation; and 

BRANDON DEMOND FRERE, individually and as 

an officer of AMERICAN FINANCIAL BENEFITS 

CENTER, AMERITECH FINANCIAL, and 

FINANCIAL EDUCATION BENEFITS CENTER,

 Defendants. 

Case No. 4:18-cv-00806-SBA 

DECLARATION OF KELLY ORTIZ 

IN SUPPORT OF FEDERAL TRADE 

COMMISSION’S ADMINISTRATIVE 

MOTION TO SCHEDULE A CASE 

MANAGEMENT CONFERENCE 
 

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Case 4:18-cv-00806-SBA Document 165 Filed 09/07/18 Page 2 of 3 

1. I am a Senior Federal Trade Investigator for the Federal Trade Commission (“FTC”), the 

plaintiff in this matter. I submit this declaration in support of the FTC’s Administrative 

Motion to Schedule a Case Management Conference. 

2. As a Senior Federal Trade Investigator, my duties include monitoring and investigating 

persons or companies suspected of engaging in unfair or deceptive acts or practices in 

violation of the Federal Trade Commission Act and any other laws or rules enforced by 

the FTC. 

3. In the course of my employment, I participated in an investigation of American Financial 

Benefits Center (“AFBC”), Ameritech Financial (“Ameritech”), Financial Education 

Benefits Center (“FEBC”), and Brandon Frere (collectively “Defendants”). 

4. The FTC maintains a database of consumer complaints for law enforcement partners 

called Consumer Sentinel (“Sentinel”). The database is a collection of complaints from 

various sources including local, state, federal, and international law enforcement 

agencies, as well Better Business Bureaus. 

5. Attached hereto as Ortiz Attachment A, with personally identifiable information 

redacted, are 2,030 Sentinel entries about the Defendants that the FTC has received since 

July 2, 2018. Blank rows indicate that the consumer did not include information in the 

“comments” section of his or her Sentinel report. Some lengthy consumer comments do 

not fit into the allocated space and are only partially visible. 

6. Ortiz Attachment B, which the FTC is filing separately under seal, is a call recording 

that Defendants produced to the FTC. The recording captures a conversation between 

Defendants’ employees and a consumer. 

7. Ortiz Attachment C, with personally identifiable information redacted, is a true and 

correct copy of the Ortiz Attachment B transcript as provided by For The Record on 

September 7, 2018. 

/// 

/// 

/// 

DECLARATION OF KELLY ORTIZ IN SUPPORT OF FEDERAL TRADE COMMISSION’S 

ADMINISTRATIVE MOTION TO SCHEDULE A CASE MANAGEMENT CONFERENCE

 4:18-CV-00806-SBA Page 2
 

 

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Case 4:18-cv-00806-SBA Document 165 Filed 09/07/18 Page 3 of 3 

I declare under penalty of perjury that the foregoing statements are true and correct. 

Executed in San Francisco on September 7, 2018. 

DECLARATION OF KELLY ORTIZ IN SUPPORT OF FEDERAL TRADE COMMISSION’S 

ADMINISTRATIVE MOTION TO SCHEDULE A CASE MANAGEMENT CONFERENCE 

4:18-CV-00806-SBA 3