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DocuSign Envelope ID: 5813994A-78FC-4D90-A3D7-32FFD1B8A6BF Case 2:18-cv-00442-JCM-PAL Case 2:18-cv-00442-JCM-PAL Document 78 Document 80 Filed 06/12/18 Filed 06/15/18 Page 1 of 30 Page 1 of 30 

Roberto Anguizola 

Illinois Bar # 6270874 (Admitted pursuant to LR IA 11-3) 

Tel. (202) 326-3284 

Email: ranguizola@ftc.gov 

Miry Kim 

Washington Bar # 31456 (Admitted pursuant to LR IA 11-3) 

Tel. (202) 326-3622 

Email: mkim@ftc.gov 

Gregory J. Evans 

DC Bar # 1033184 (Admitted pursuant to LR IA 11-3) 

Tel. (202) 326-3425 

Email: gevans2@ftc.gov 

Federal Trade Commission 

600 Pennsylvania Avenue, NW 

Mail Drop CC-8528 

Washington, DC 20580 

Attorneys for Plaintiff 

FEDERAL TRADE COMMISSION 

UNITED STATES DISTRICT COURT 

DISTRICT OF NEVADA 

FEDERAL TRADE COMMISSION, 

Plaintiff, 

v. 

AWS, LLC, a Nevada limited liability company; 

ADAMS CONSULTING, LLC, a California limited 

liability company; FBA DISTRIBUTORS, LLC, a 

Massachusetts limited liability company; FBA 

STORES, LLC, a Nevada limited liability company; 

GLOBAL MARKETING SERVICES L.L.C., a 

Nevada limited liability company; INFO PROS, 

LLC, a Nevada limited liability company; INFO 

SOLUTIONS, LLC, a Nevada limited liability 

company; ONLINE AUCTION LEARNING 

CENTER, INC., a Massachusetts corporation; 

ONLINE AUCTION LEARNING CENTER, INC., 

a Nevada corporation; CHRISTOPHER F. 

BOWSER; ADAM S. BOWSER; JODY L. 

MARSHALL; and JEFFREY A. GOMEZ, 

Defendants. 

1 

CASE NO. 2:18-cv-00442-JCM-PAL 

STIPULATED ORDER FOR 

PERMANENT INJUNCTION AND 

MONETARY JUDGMENT AS TO 

DEFENDANTS AWS, LLC, FBA 

DISTRIBUTORS, LLC, FBA 

STORES, LLC, INFO PROS, LLC, 

INFO SOLUTIONS, LLC, ONLINE 

AUCTION LEARNING CENTER, 

INC. (MASS. CORP.), ONLINE 

AUCTION LEARNING CENTER, 

INC. (NEV. CORP.), 

CHRISTOPHER F. BOWSER, 

ADAM S. BOWSER, AND JODY L. 

MARSHALL 
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DocuSign Envelope ID: 5813994A-78FC-4D90-A3D7-32FFD1B8A6BF Case 2:18-cv-00442-JCM-PAL Case 2:18-cv-00442-JCM-PAL Document 78 Document 80 Filed 06/12/18 Filed 06/15/18 Page 2 of 30 Page 2 of 30 

Plaintiff, the Federal Trade Commission (“Commission” or “FTC”), filed its Complaint 

for Permanent Injunction and Other Equitable Relief, as amended, (“Complaint”), in this matter, 

pursuant to Sections 13(b) and 19 of the Federal Trade Commission Act (“FTC Act”), 15 U.S.C. 

§§ 53(b) and 57b. The Commission and Defendants AWS, LLC, FBA Distributors, LLC, FBA 

Stores, LLC, Info Pros, LLC, Info Solutions, LLC, Online Auction Learning Center, Inc. (Mass. 

Corp.), Online Auction Learning Center, Inc. (Nev. Corp.), Christopher F. Bowser, Adam S. 

Bowser, and Jody Marshall (“Settling Defendants”) stipulate to the entry of this Stipulated Order 

for Permanent Injunction and Monetary Judgment (“Order”) to resolve all matters in dispute in 

this action between them. 

THEREFORE, IT IS ORDERED as follows: 

FINDINGS 

1. This Court has jurisdiction over this matter. 

2. The Complaint charges that Settling Defendants participated in deceptive and 

unfair acts or practices in violation of Section 5 of the FTC Act, 15 U.S.C. § 45, and in violation 

of the Business Opportunity Rule, 16 C.F.R. Part 437, in connection with the advertising, 

marketing, distribution, promotion and sale of business opportunities to consumers throughout 

the United States. 

3. Settling Defendants neither admit nor deny any of the allegations in the 

Complaint, except as specifically stated in this Order. Only for purposes of this action, Settling 

Defendants admit the facts necessary to establish jurisdiction. 

4. Settling Defendants waive and release any claims that they may have against the 

Commission and the Receiver, including against any agent of the Commission or the Receiver, 

that relate to this action. 

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DocuSign Envelope ID: 5813994A-78FC-4D90-A3D7-32FFD1B8A6BF Case 2:18-cv-00442-JCM-PAL Case 2:18-cv-00442-JCM-PAL Document 78 Document 80 Filed 06/12/18 Filed 06/15/18 Page 3 of 30 Page 3 of 30 

5. Settling Defendants waive all rights to appeal or otherwise challenge or contest 

the validity of this Order. 

6. Individual Defendant Jody Marshall filed a petition for relief under Chapter 13 of 

the Bankruptcy Code on January 5, 2016. In re Jody L. Marshall, No. BKS-16-10016-MKN 

(Bankr. D. Nev.) (“Marshall Bankruptcy Case”). The Commission’s prosecution of this action 

and the Order are actions to enforce the Commission’s policy or regulatory power. As a result, if 

the Marshall Bankruptcy Case is pending as of the date of entry of this Order, then these actions 

are excepted from the automatic stay pursuant to 11 U.S.C. § 362(b)(4). 

DEFINITIONS 

For the purpose of this Order, the following definitions apply: 

A. “Business Coaching Program” means any program, plan, good, or service, including 

those related to business opportunities, that is represented, expressly or by implication, to coach, 

train or teach a participant or Purchaser how to establish, operate, or improve the Purchaser’s 

business. 

B. “Business Opportunity” means a commercial arrangement in which: 

1. A Seller solicits a prospective Purchaser to enter into a new business; and 

2. The prospective Purchaser makes a required payment; and 

3. The Seller, expressly or by implication, orally or in writing, represents that the 

Seller or one or more Designated Persons will: 

(i) Provide locations for the use or operation of equipment, displays, vending 

machines, or similar devices, owned, leased, controlled, or paid for by the 

Purchaser; or 

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DocuSign Envelope ID: 5813994A-78FC-4D90-A3D7-32FFD1B8A6BF Case 2:18-cv-00442-JCM-PAL Case 2:18-cv-00442-JCM-PAL Document 78 Document 80 Filed 06/12/18 Filed 06/15/18 Page 4 of 30 Page 4 of 30 

(ii) Provide outlets, accounts, or customers, including Internet outlets, 

accounts, or customers, for the Purchaser’s goods or services; or 

(iii) Buy back any or all of the goods or services that the Purchaser makes, 

produces, fabricates, grows, breeds, modifies, or provides, including providing 

payment for such services as, for example, stuffing envelopes from the 

Purchaser’s home. 

C. “Designated Person” means any Person, other than the Seller, whose goods or services 

the Seller suggests, recommends, or requires that the Purchaser use in establishing or operating a 

new business. 

D. “Document” is synonymous in meaning and equal in scope to the usage of “document” 

and “electronically stored information” in Federal Rule of Civil Procedure 34(a), 

Fed. R. Civ. P. 34(a), and includes writings, drawings, graphs, charts, photographs, sound and 

video recordings, images, internet sites, web pages, websites, electronic correspondence, 

including e-mail and instant messages, contracts, accounting data, advertisements (including 

advertisements placed on the World Wide Web), FTP Logs, Server Access Logs, USENET 

Newsgroup postings, books, written or printed records, handwritten notes, telephone logs, 

telephone scripts, receipt books, ledgers, personal and business canceled checks and check 

registers, bank statements, appointment books, computer records, customer or sales databases, 

and any other electronically stored information, including Documents located on remote servers 

or cloud computing systems, and other data or data compilations from which information can be 

obtained directly or, if necessary, after translation into a reasonably usable form. A draft or nonidentical copy is a separate document within the meaning of the term. 

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DocuSign Envelope ID: 5813994A-78FC-4D90-A3D7-32FFD1B8A6BF Case 2:18-cv-00442-JCM-PAL Case 2:18-cv-00442-JCM-PAL Document 78 Document 80 Filed 06/12/18 Filed 06/15/18 Page 5 of 30 Page 5 of 30 

E. “Earnings Claim” means any oral, written, or visual representation to a consumer, 

prospective Purchaser or investor that conveys, expressly or by implication, a specific level or 

range of actual or potential sales, or gross or net income or profits. Earnings claims include, but 

are not limited to any: (1) chart, table, or mathematical calculation that demonstrates possible 

results based upon a combination of variables; and (2) statements from which a consumer, 

prospective Purchaser or investor can reasonably infer that he or she will earn a minimum level 

of income (e.g., “earn enough to buy a Porsche,” “earn a six-figure income,” or “earn your 

investment back within one year”). 

F. “Person” means a natural person, organization, or legal entity, including a corporation, 

partnership, proprietorship, association, cooperative, government or governmental subdivision or 

agency, or any other group or combination acting as an entity. 

G. “Providing locations, outlets, accounts, or customers” means furnishing the 

prospective Purchaser with existing or potential locations, outlets, accounts, or customers; 

requiring, recommending, or suggesting one or more locators or lead generating companies; 

providing a list of locator or lead generating companies; collecting a fee on behalf of one or more 

locators or lead generating companies; offering to furnish a list of locations; or otherwise 

assisting the prospective Purchaser in obtaining his or her own locations, outlets, accounts, or 

customers. 

H. “Purchaser” means a Person who buys a Business Opportunity or Business Coaching 

Program. 

I. “Receiver” means Robb Evans & Associates LLC, the receiver appointed in Section XI 

of the Temporary Restraining Order issued on March 14, 2018 [ECF No. 29], and whose 

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DocuSign Envelope ID: 5813994A-78FC-4D90-A3D7-32FFD1B8A6BF Case 2:18-cv-00442-JCM-PAL Case 2:18-cv-00442-JCM-PAL Document 78 Document 80 Filed 06/12/18 Filed 06/15/18 Page 6 of 30 Page 6 of 30 

appointment is continued in Section VI of this Order, and any deputy receivers that shall be 

named by Robb Evans & Associates LLC. 

J. “Receivership Estate” means the assets identified in Section III.C of this Order and all 

assets of the Settling Corporate Defendants, including: (a) any assets of the Settling Corporate 

Defendants currently in the possession of the Receiver; (b) all the funds, property, premises, 

accounts, documents, mail, and all other assets of, or in the possession or under the control of the 

Settling Corporate Defendants, wherever situated, the income and profits therefrom, all sums of 

money now or hereafter due or owing to the Settling Corporate Defendants, and any other assets 

or property belonging or owed to the Settling Corporate Defendants; (c) any assets of the Settling 

Corporate Defendants held in asset protection trusts; (d) any reserve funds or other accounts 

associated with any payments processed on behalf of any Settling Corporate Defendant, 

including such reserve funds held by a payment processor, credit card processor, or bank; and (e) 

all proceeds from the sale of such assets, except those assets the sale of which the Receiver 

determines will not add appreciably to the value of the estate. 

K. “Seller” means a person who offers for sale or sells a Business Opportunity or Business 

Coaching Program. 

L. “Settling Corporate Defendants” means AWS, LLC, FBA Distributors, LLC, FBA 

Stores, LLC, Info Pros, LLC, Info Solutions, LLC, Online Auction Learning Center, Inc. (Mass. 

Corp.), Online Auction Learning Center, Inc. (Nev. Corp.), and any of their subsidiaries, 

affiliates, successors, and assigns. 

M. “Settling Defendants” means all of the Settling Individual Defendants and the Settling 

Corporate Defendants, individually, collectively, or in any combination. 

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DocuSign Envelope ID: 5813994A-78FC-4D90-A3D7-32FFD1B8A6BF Case 2:18-cv-00442-JCM-PAL Case 2:18-cv-00442-JCM-PAL Document 78 Document 80 Filed 06/12/18 Filed 06/15/18 Page 7 of 30 Page 7 of 30 

N. “Settling Individual Defendants” means Christopher F. Bowser, Adam S. Bowser, and 

Jody L. Marshall, individually or collectively. 

ORDER 

I. BUSINESS OPPORTUNITY AND BUSINESS COACHING BAN 

IT IS ORDERED that Settling Defendants are permanently restrained and enjoined from 

advertising, marketing, distributing, promoting, or offering for sale, or assisting in the 

advertising, marketing, distributing, promoting, or offering for sale of, any Business Opportunity 

or Business Coaching Program. 

II. PROHIBITED BUSINESS ACTIVITIES 

IT IS FURTHER ORDERED that Settling Defendants, Settling Defendants’ officers, 

agents, employees, and attorneys, and all other Persons in active concert or participation with 

them, who receive actual notice of this Order, whether acting directly or indirectly, in connection 

with promoting or offering for sale any good or service, are permanently restrained and enjoined 

from: 

A. making any Earnings Claim, unless the Earnings Claim is non-misleading, and, at 

the time such claim is made, Settling Defendants: (1) have a reasonable basis for their claim; (2) 

have in their possession written materials that substantiate the claim; and (3) make the written 

substantiation available upon request to the consumer, potential Purchaser or investor, and to the 

Commission; or 

B. misrepresenting or assisting others in misrepresenting, expressly or by implication 

any other fact material to consumers concerning any product or service, such as the total costs; 

any material restrictions, limitations, or conditions; or any material aspect of its performance, 

efficacy, nature, or central characteristics. 

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DocuSign Envelope ID: 5813994A-78FC-4D90-A3D7-32FFD1B8A6BF Case 2:18-cv-00442-JCM-PAL Case 2:18-cv-00442-JCM-PAL Document 78 Document 80 Filed 06/12/18 Filed 06/15/18 Page 8 of 30 Page 8 of 30 

III. MONETARY JUDGMENT AND PARTIAL SUSPENSION 

IT IS FURTHER ORDERED that: 

A. Judgment in the amount of One Hundred Two Million, Four Hundred Eighty-One 

Thousand, Five Hundred Ninety-Six Dollars ($102,481,596.00) is entered in favor of the 

Commission against Settling Defendants, jointly and severally, as equitable monetary relief. 

B. Settling Individual Defendants are ordered to make the following payments to the 

Commission, which, as Settling Individual Defendants stipulate, their undersigned counsel holds 

in escrow for no purpose other than payment to the Commission: 

1. Individual Defendant Christopher F. Bowser is ordered to pay to the Commission 

Three Hundred, Twenty-Five Thousand Dollars ($325,000.00); 

325,000.00); and 

2. Individual Defendant Adam S. Bowser is ordered to pay to the Commission Three 

Hundred, Twenty-Five Thousand Dollars ($

3. Individual Defendant Jody Marshall is ordered to pay to the Commission 

Seventy-Five Thousand Dollars ($75,000.00). 

Such payments must be made within 7 days of entry of this Order by electronic fund transfer in 

accordance with instructions previously provided by a representative of the Commission. 

C. In addition to the payments to the Commission specified in Subsection B above, 

immediately upon entry of this Order, the Settling Defendants are ordered to surrender to the 

Commission all control, title, dominion, and interest each has to the following assets: 

1. All interest the Settling Defendants have in funds in any accounts in the name of 

the Settling Corporate Defendants, eLearn Service, LLC, E-Learn Services, Ltd., 

EMWW, LLC, Finn Rich Wireless, LLC, Plaza TowneHomes, LLC, Sell On 

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DocuSign Envelope ID: 5813994A-78FC-4D90-A3D7-32FFD1B8A6BF Case 2:18-cv-00442-JCM-PAL Case 2:18-cv-00442-JCM-PAL Document 78 Document 80 Filed 06/12/18 Filed 06/15/18 Page 9 of 30 Page 9 of 30 

AMZ Inc., Surf Cellular Express, LLC, Vmerica, Inc., Buy Box Wholesale Inc., 

Auction Profit Builders LLC, Insider Online Secrets LLC, or Sellers Hangout; 

2. All cash held by the Receiver; 

3. All assets owned by the Settling Corporate Defendants, eLearn Service, LLC, ELearn Services, Ltd., EMWW, LLC, Finn Rich Wireless, LLC, Plaza 

TowneHomes, LLC, Sell On AMZ Inc., Surf Cellular Express, LLC, Vmerica, 

Inc., Buy Box Wholesale Inc., Auction Profit Builders LLC, Insider Online 

Secrets LLC, or Sellers Hangout, including any real, personal, or intellectual 

property, chattel, goods, instruments, equipment, fixtures, general intangibles, 

effects, leaseholds, contracts, mail, or other deliveries, shares or stock, securities, 

inventory, checks, notes, accounts, credits, receivables, insurance policies, lines of 

credit, cash, trusts (including asset protection trusts), lists of consumer names and 

reserve funds or any other accounts associated with any payments processed by, 

or on behalf of, any Settling Corporate Defendants, eLearn Service, LLC, E-Learn 

Services, Ltd., EMWW, LLC, Finn Rich Wireless, LLC, Plaza TowneHomes, 

LLC, Sell On AMZ Inc., Surf Cellular Express, LLC, Vmerica, Inc., Buy Box 

Wholesale Inc., Auction Profit Builders LLC, Insider Online Secrets LLC, or 

Sellers Hangout; 

4. All funds held by Bank of America N.A., in the name of Info Pros LLC dba 

“Online Seller”, including the accounts ending in 1812 and 6059; 

5. All funds held by Bank of America N.A., in the name of FBA Stores LLC dba 

“AWS”, including the accounts ending in 6155 and 3425; 

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DocuSign Envelope ID: 5813994A-78FC-4D90-A3D7-32FFD1B8A6BF Case 2:18-cv-00442-JCM-PAL Case 2:18-cv-00442-JCM-PAL Document 78 Document 80 Filed 06/12/18 Filed 06/15/18 Page 10 of 30 Page 10 of 30 

6. All funds held by Bank of America N.A., in the name of FBA Stores LLC, 

including the account ending in 2607; 

7. All funds held by Bank of America N.A., in the name of FBA Distributors LLC, 

including the account ending in 5349; 

8. All funds held by Bank of America N.A., in the name of EMWW, LLC LLC, 

including the account ending in 8299; 

9. All funds held by Bank of America N.A., in the name of Elearn Services LLC dba 

“Edominance”, including the account ending in 1867; 

10. All funds held by Bank of America N.A., in the name of Finn Rich Wireless LLC, 

including the account ending in 2342; 

11. All funds held by Bank of America N.A., in the name of Vmerica Inc., including 

the account ending in 5607; 

12. All funds held by America First Credit Union, in the name of Info Solutions LLC, 

including the account ending in 7992; 

13. All funds held by Washington Federal Bank, in the name of Info Pros LLC, 

including the account ending in 9156; 

14. All funds held by Washington Federal Bank, in the name of EMWW, LLC, 

including the account ending in 8182; 

15. All funds held by Rockland Trust Company, in the name of Online Auction 

Learning Center, Inc., including the Demand Deposit accounts ending in 1323 and 

2412; 

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DocuSign Envelope ID: 5813994A-78FC-4D90-A3D7-32FFD1B8A6BF Case 2:18-cv-00442-JCM-PAL Case 2:18-cv-00442-JCM-PAL Document 78 Document 80 Filed 06/12/18 Filed 06/15/18 Page 11 of 30 Page 11 of 30 

16. All funds held by Rockland Trust Company, in the name of Auction Profit 

Builders LLC dba “Insider Online Secrets”, including the Demand Deposit 

account ending in 1538; 

17. All funds held by Rockland Trust Company, in the name of Finn Rich Wireless 

LLC, including the Demand Deposit account ending in 6468; 

18. All funds held by Rockland Trust Company, in the name of Surf Cellular Express 

LLC, including the Demand Deposit account ending in 7031; 

19. All funds held by JP Morgan Chase & Co., in the name of Info Pros LLC, 

including the account ending in 3922; 

20. All funds held by JP Morgan Chase & Co., in the name of Plaza TowneHomes, 

LLC, including the account ending in 3929; 

21. All reserve funds or any other accounts held, controlled, or serviced by Stripe, 

Inc. and associated with any payments processed by, or on behalf of FBA 

Distributors LLC, including the merchant account with the merchant 

identification number (“MID”) ending in uiJvd; 

22. All reserve funds or any other accounts held, controlled, or serviced by Stripe, 

Inc. and associated with any payments processed by, or on behalf of Adam 

Bowser dba “AWS”, including the merchant account with the MID ending in 

K9Yc2; 

23. All reserve funds or any other accounts held, controlled, or serviced by Electronic 

Merchant Systems and associated with any payments processed by, or on behalf 

of FBA Stores LLC, including the merchant account with the MID ending in 

0179; 

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DocuSign Envelope ID: 5813994A-78FC-4D90-A3D7-32FFD1B8A6BF Case 2:18-cv-00442-JCM-PAL Case 2:18-cv-00442-JCM-PAL Document 78 Document 80 Filed 06/12/18 Filed 06/15/18 Page 12 of 30 Page 12 of 30 

24. All reserve funds or any other accounts held, controlled, or serviced by Electronic 

Merchant Systems and associated with any payments processed by, or on behalf 

of Online Auction Learning Center, Inc., including the merchant accounts with 

the MID ending in 0908; 

25. All reserve funds or any other accounts held, controlled, or serviced by EVO 

Payments International, LLC and associated with any payments processed by, or 

on behalf of FBA Stores LLC, including the merchant account with the MID 

ending in 4353; 

26. All reserve funds or any other accounts held, controlled, or serviced by EVO 

Payments International, LLC and associated with any payments processed by, or 

on behalf of Online Auction Learning Center, Inc., including the merchant 

accounts with the MIDs ending in 2829 and 7498; 

27. All reserve funds or any other accounts held, controlled, or serviced by PayPal, 

Inc. and associated with any payments processed by, or on behalf of FBA Stores, 

LLC, including the merchant account with the MID ending in 3735; 

28. All reserve funds or any other accounts held, controlled, or serviced by PayPal, 

Inc. and associated with any payments processed by, or on behalf of Info Pros 

LLC, including the merchant account with the MID ending in 4079; 

29. All reserve funds or any other accounts held, controlled, or serviced by PayPal, 

Inc. and associated with any payments processed by, or on behalf of Info 

Solutions, LLC, including the merchant account with the MID ending in 0073; 

30. All reserve funds or any other accounts held, controlled, or serviced by PayPal, 

Inc. and associated with any payments processed by, or on behalf of Online 

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DocuSign Envelope ID: 5813994A-78FC-4D90-A3D7-32FFD1B8A6BF Case 2:18-cv-00442-JCM-PAL Case 2:18-cv-00442-JCM-PAL Document 78 Document 80 Filed 06/12/18 Filed 06/15/18 Page 13 of 30 Page 13 of 30 

Auction Learning Center, Inc., including the merchant accounts with the MIDs 

ending in 8564 and 1083; 

31. All reserve funds or any other accounts held, controlled, or serviced by Qualpay 

and associated with any payments processed by, or on behalf of FBA Stores LLC, 

including the merchant account with the MID ending in 0602; and 

32. All reserve funds or any other accounts held, controlled, or serviced by Global 

Payments, Inc. and associated with any payments processed by, or on behalf of 

Info Pros LLC dba “On Line Seller” or “Online Seller”, including the merchant 

account with the MID ending in 3060. 

D. To the extent they are not already in the possession of the Receiver, Settling 

Defendants shall deliver the assets identified in Subsection C above to the Receiver’s possession 

within 7 days of the entry of this Order. 

E. The Receiver shall, as soon as practicable, commence the sale of the unliquidated 

assets identified in Subsection C above and surrendered pursuant to this Order using a 

commercially reasonable procedure. The Receiver shall hold the surrendered assets, and the 

proceeds from the sale of the unliquidated assets, for future transfer in accordance with further 

instructions from the Court. 

F. Upon delivery of the payments specified in Subsection B above to the 

Commission, and of all the assets specified in Subsection C above to the Receiver, the remainder 

of the judgment is suspended, subject to Subsections G-O below. 

G. The Commission’s agreement to the suspension of part of the judgment is 

expressly premised upon the truthfulness, accuracy, and completeness of Settling Defendants’ 

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DocuSign Envelope ID: 5813994A-78FC-4D90-A3D7-32FFD1B8A6BF Case 2:18-cv-00442-JCM-PAL Case 2:18-cv-00442-JCM-PAL Document 78 Document 80 Filed 06/12/18 Filed 06/15/18 Page 14 of 30 Page 14 of 30 

sworn financial statements and related Documents (collectively, “financial representations”) 

submitted to the Commission, namely: 

1. the Financial Statement of Individual Defendant Christopher F. Bowser signed on 

March 21, 2018, including the attachments; 

2. the Financial Statement of Individual Defendant Adam S. Bowser signed on 

March 27, 2018, including the attachments; 

3. the Financial Statement of Individual Defendant Jody Marshall, signed on March 

28, 2018, including the attachments; 

4. the Financial Statement of Corporate Defendant FBA Stores, LLC signed by 

Alma Kelly, Internal Accountant, on March 21, 2018, including the attachments; 

and 

5. the Financial Statement of Corporate Defendant Online Auction Learning Center, 

Inc. (Mass. Corp.), signed by Christopher F. Bowser, Owner, on March 21, 2018, 

including the attachments. 

H. The suspension of the judgment will be lifted as to any Settling Defendant if, 

upon motion by the Commission, the Court finds that Settling Defendant failed to disclose any 

material asset, materially misstated the value of any asset, or made any other material 

misstatement or omission in the financial representations identified above. 

I. If the suspension of the judgment is lifted, the judgment becomes immediately 

due as to that Settling Defendant in the amount specified in Subsection A above (which the 

parties stipulate only for purposes of this Section represents the consumer injury and unjust 

enrichment alleged in the Complaint), less any payments previously made pursuant to this 

Section, plus interest computed from the date of entry of this Order. 

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DocuSign Envelope ID: 5813994A-78FC-4D90-A3D7-32FFD1B8A6BF Case 2:18-cv-00442-JCM-PAL Case 2:18-cv-00442-JCM-PAL Document 78 Document 80 Filed 06/12/18 Filed 06/15/18 Page 15 of 30 Page 15 of 30 

J. Settling Defendants relinquish dominion and all legal and equitable right, title, 

and interest in all assets transferred pursuant to this Order and may not seek the return of any 

assets. 

K. The facts alleged in the Complaint will be taken as true, without further proof, in 

any subsequent civil litigation by or on behalf of the Commission, including in a proceeding to 

enforce its rights to any payment or monetary judgment pursuant to this Order, such as a 

nondischargeability complaint in any bankruptcy case. 

L. The facts alleged in the Complaint establish all elements necessary to sustain an 

action by the Commission pursuant to Section 523(a)(2)(A) of the Bankruptcy Code, 11 U.S.C. 

§ 523(a)(2)(A), and this Order will have collateral estoppel effect for such purposes. 

M. Settling Defendants acknowledge that their Taxpayer Identification Numbers 

(Social Security Numbers or Employer Identification Numbers), which Settling Defendants 

previously submitted to the Commission, may be used for collecting and reporting on any 

delinquent amount arising out of this Order, in accordance with 31 U.S.C. §7701. 

N. All money paid to the Commission or assets ultimately surrendered to the 

Commission pursuant to this Order (or any subsequent Court order issued in this matter) and 

further instructions from the Court may be deposited into a fund administered by the 

Commission or its designee to be used for equitable relief, including consumer redress and any 

attendant expenses for the administration of any redress fund. If a representative of the 

Commission decides that direct redress to consumers is wholly or partially impracticable or 

money remains after redress is completed, the Commission may apply any remaining money for 

such other equitable relief (including consumer information remedies) as it determines to be 

reasonably related to Settling Defendants’ practices alleged in the Complaint. Any money not 

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DocuSign Envelope ID: 5813994A-78FC-4D90-A3D7-32FFD1B8A6BF Case 2:18-cv-00442-JCM-PAL Case 2:18-cv-00442-JCM-PAL Document 78 Document 80 Filed 06/12/18 Filed 06/15/18 Page 16 of 30 Page 16 of 30 

used for such equitable relief is to be deposited to the U.S. Treasury as disgorgement. Settling 

Defendants have no right to challenge any actions the Commission or its representatives may 

take pursuant to this Subsection. 

O. The asset freeze imposed by the March 14, 2018 Temporary Restraining Order 

[ECF No. 29], is modified to permit the payment and transfers identified in Subsections B and C 

above. Upon completion of those payment and transfers, the asset freeze as to Settling 

Defendants is dissolved. Any existing asset freeze as to the remaining non-settling Defendants 

shall remain in full force and effect. 

IV. CUSTOMER INFORMATION 

IT IS FURTHER ORDERED that Settling Defendants, and their representatives, agents, 

employees, and attorneys, and all other persons in active concert or participation with any of 

them, who receive actual notice of this Order, are permanently restrained and enjoined from 

directly or indirectly: 

A. failing to provide sufficient customer information to enable the Commission to 

efficiently administer consumer redress. Settling Defendants represent that they have provided 

this redress information to the Commission. If a representative of the Commission requests in 

writing any information related to redress, Settling Defendants must provide it, in the form 

prescribed by the Commission, within 14 days. 

B. disclosing, using, or benefitting from customer information, including the name, 

address, telephone number, email address, social security number, other identifying information, 

or any data that enables access to a customer’s account (including a credit card, bank account, or 

other financial account), that any Settling Defendant obtained prior to entry of this Order in 

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DocuSign Envelope ID: 5813994A-78FC-4D90-A3D7-32FFD1B8A6BF Case 2:18-cv-00442-JCM-PAL Case 2:18-cv-00442-JCM-PAL Document 78 Document 80 Filed 06/12/18 Filed 06/15/18 Page 17 of 30 Page 17 of 30 

connection with the advertising, marketing, distribution, promotion and sale of business 

opportunities to consumers throughout the United States; and 

C. failing to destroy such customer information in all forms in their possession, 

custody, or control within 30 days after receipt of written direction to do so from a representative 

of the Commission. 

Provided, however, that customer information need not be disposed of, and may be 

disclosed, to the extent requested by a government agency or required by law, regulation, or 

court order. 

V. COOPERATION 

IT IS FURTHER ORDERED that Settling Defendants must fully cooperate with 

representatives of the Commission in this case and in any investigation related to or associated 

with the transactions or the occurrences that are the subject of the Complaint. Settling 

Defendants must provide truthful and complete information, evidence, and testimony. Settling 

Individual Defendants must appear and Settling Corporate Defendants must cause Settling 

Corporate Defendants’ officers, employees, representatives, or agents to appear for interviews, 

discovery, hearings, trials, and any other proceedings that a Commission representative may 

reasonably request upon 5 days written notice, or other reasonable notice, at such places and 

times as a Commission representative may designate, without the service of a subpoena. 

VI. RECEIVERSHIP 

IT IS FURTHER ORDERED that Robb Evans & Associates LLC is hereby appointed 

equity Receiver for the Settling Corporate Defendants for the purpose of taking the necessary 

steps to wind down the businesses of the Settling Corporate Defendants, liquidate assets, and pay 

any net proceeds to the Commission to satisfy the monetary judgment in this Order. In carrying 

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DocuSign Envelope ID: 5813994A-78FC-4D90-A3D7-32FFD1B8A6BF Case 2:18-cv-00442-JCM-PAL Case 2:18-cv-00442-JCM-PAL Document 78 Document 80 Filed 06/12/18 Filed 06/15/18 Page 18 of 30 Page 18 of 30 

out these duties, the Receiver shall be the agent of this Court, shall be accountable directly to this 

Court, and is authorized and directed to: 

A. Take any and all steps that the Receiver concludes are appropriate to wind down 

the affairs of the Settling Corporate Defendants. 

B. Continue to exercise full control over the Settling Corporate Defendants and 

continue to collect, marshal, and take custody, control, and possession of all the funds, property, 

premises, accounts, documents, mail, and other assets of, or in the possession or under the 

control of the Settling Corporate Defendants, wherever situated, the income and profits 

therefrom, and all sums of money now or hereafter due or owing to the Settling Corporate 

Defendants. 

C. Continue to have full control over the management and personnel of the Settling 

Corporate Defendants. 

D. Take all steps necessary or advisable, including issuing subpoenas, to locate and 

liquidate all other assets of the Settling Corporate Defendants, cancel the Settling Corporate 

Defendants’ contracts, collect on amounts owed to the Settling Corporate Defendants, and take 

such other steps as may be necessary to wind-down the Settling Corporate Defendants 

efficiently. 

E. To the extent not already completed, the Receiver shall as soon as practicable 

after the entry of this Order, take exclusive custody, control, and possession of all assets 

identified in Section III.C of this Order. 

F. The Receiver shall give reasonable notice to the Commission of any settlements 

or compromises by the Receiver concerning the Receivership Estate, before the settlement or 

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DocuSign Envelope ID: 5813994A-78FC-4D90-A3D7-32FFD1B8A6BF Case 2:18-cv-00442-JCM-PAL Case 2:18-cv-00442-JCM-PAL Document 78 Document 80 Filed 06/12/18 Filed 06/15/18 Page 19 of 30 Page 19 of 30 

compromise is consummated. Within 20 days of this notice, the Commission shall have the 

opportunity to object to any such settlement, by filing a motion with the Court. 

G. Make payments and disbursements from the Receivership Estate that are 

necessary or advisable for carrying out the directions of, or exercising the authority granted by, 

this Order. The Receiver shall apply to the Court for prior approval of any payment of any debt 

or obligation incurred by the Settling Corporate Defendants prior to the date of entry of the 

temporary restraining order in this action, except payments that the Receiver deems necessary or 

advisable to ensure assets of the Settling Corporate Defendants are not lost, stolen, or dissipated. 

H. Institute actions or proceedings in state, federal, or foreign courts as the Receiver 

deems necessary and advisable to preserve or recover the assets of the Settling Corporate 

Defendants, or that the Receiver deems necessary and advisable to carry out the Receiver’s 

mandate under this Order, including actions challenging fraudulent or voidable transfers. 

I. Defend any or all actions or proceedings instituted against the Settling Corporate 

Defendants, as the Receiver deems necessary and advisable to preserve the assets of the Settling 

Corporate Defendants. 

J. Continue to maintain accurate records of all receipts and expenditures incurred as 

the Receiver. 

K. Perform all acts necessary or advisable to complete an accurate accounting of 

assets of the Receivership Estate, and prevent unauthorized transfer, withdrawal, or 

misapplication of said assets. 

L. Continue to be entitled to reasonable compensation for the performance of the 

Receiver’s duties pursuant to this Order, including duties performed by the Receiver’s agents, 

including accountants and lawyers, and for the cost of actual out-of-pocket expenses incurred by 

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DocuSign Envelope ID: 5813994A-78FC-4D90-A3D7-32FFD1B8A6BF Case 2:18-cv-00442-JCM-PAL Case 2:18-cv-00442-JCM-PAL Document 78 Document 80 Filed 06/12/18 Filed 06/15/18 Page 20 of 30 Page 20 of 30 

them, from the assets of the Receivership Estate, at the hourly rate previously agreed to by the 

Receiver and used as the bases for prior fee applications approved by the Court. 

VII. ORDER ACKNOWLEDGMENTS 

IT IS FURTHER ORDERED that Settling Defendants obtain acknowledgments of 

receipt of this Order: 

A. Each Settling Defendant, within 7 days of entry of this Order, must submit to the 

Commission an acknowledgment of receipt of this Order sworn under penalty of perjury. 

B. For 10 years after entry of this Order, each Settling Individual Defendant for any 

business that such Settling Defendant, individually or collectively with any other Settling 

Defendants, is the majority owner or controls directly or indirectly, and each Settling Corporate 

Defendant, must deliver a copy of this Order to: (1) all principals, partners, officers, directors, 

and LLC managers and members; (2) all employees, agents, and representatives who participate 

in conduct related to the subject matter of the Order; and (3) any business entity resulting from 

any change in structure as set forth in the Section titled Compliance Reporting. Delivery must 

occur within 7 days of entry of this Order for current personnel. For all others, delivery must 

occur before they assume their responsibilities. 

C. From each individual or entity to which a Settling Defendant delivered a copy of 

this Order, that Settling Defendant must obtain, within 30 days, a signed and dated 

acknowledgment of receipt of this Order. 

VIII. COMPLIANCE REPORTING 

IT IS FURTHER ORDERED that Settling Defendants make timely submissions to the 

Commission: 

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DocuSign Envelope ID: 5813994A-78FC-4D90-A3D7-32FFD1B8A6BF Case 2:18-cv-00442-JCM-PAL Case 2:18-cv-00442-JCM-PAL Document 78 Document 80 Filed 06/12/18 Filed 06/15/18 Page 21 of 30 Page 21 of 30 

A. One year after entry of this Order, each Settling Defendant must submit a 

compliance report, sworn under penalty of perjury: 

1. Each Settling Defendant must: (a) identify the primary physical, postal, and email 

address and telephone number, as designated points of contact, which 

representatives of the Commission may use to communicate with Settling 

Defendant; (b) identify all of that Settling Defendant’s businesses by all of their 

names, telephone numbers, and physical, postal, email, and Internet addresses; (c) 

describe the activities of each business, including the goods and services offered, 

the means of advertising, marketing, and sales, and the involvement of any other 

Settling Defendant (which Settling Individual Defendants must describe if they 

know or should know due to their own involvement); (d) describe in detail 

whether and how that Settling Defendant is in compliance with each Section of 

this Order; and (e) provide a copy of each Order Acknowledgment obtained 

pursuant to this Order, unless previously submitted to the Commission. 

2. Additionally, each Settling Individual Defendant must: (a) identify all telephone 

numbers and all physical, postal, email and Internet addresses, including all 

residences; (b) identify all business activities, including any business for which 

such Settling Defendant performs services whether as an employee or otherwise 

and any entity in which such Settling Defendant has any ownership interest; and 

(c) describe in detail such Settling Defendant’s involvement in each such 

business, including title, role, responsibilities, participation, authority, control, 

and any ownership. 

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DocuSign Envelope ID: 5813994A-78FC-4D90-A3D7-32FFD1B8A6BF Case 2:18-cv-00442-JCM-PAL Case 2:18-cv-00442-JCM-PAL Document 78 Document 80 Filed 06/12/18 Filed 06/15/18 Page 22 of 30 Page 22 of 30 

B. For 20 years after entry of this Order, each Settling Defendant must submit a 

compliance notice, sworn under penalty of perjury, within 14 days of any change in the 

following: 

1. Each Settling Defendant must report any change in: (a) any designated point of 

contact; or (b) the structure of any Settling Corporate Defendant or any entity that 

Settling Defendant has any ownership interest in or controls directly or indirectly 

that may affect compliance obligations arising under this Order, including: 

creation, merger, sale, or dissolution of the entity or any subsidiary, parent, or 

affiliate that engages in any acts or practices subject to this Order. 

2. Additionally, each Settling Individual Defendant must report any change in: (a) 

name, including aliases or fictitious name, or residence address; or (b) title or role 

in any business activity, including any business for which such Settling Defendant 

performs services whether as an employee or otherwise and any entity in which 

such Settling Defendant has any ownership interest, and identify the name, 

physical address, and any Internet address of the business or entity. 

C. Each Settling Defendant must submit to the Commission notice of the filing of 

any bankruptcy petition, insolvency proceeding, or similar proceeding by or against such Settling 

Defendant within 14 days of its filing. 

D. Any submission to the Commission required by this Order to be sworn under 

penalty of perjury must be true and accurate and comply with 28 U.S.C. § 1746, such as by 

concluding: “I declare under penalty of perjury under the laws of the United States of America 

that the foregoing is true and correct. Executed on: _____” and supplying the date, signatory’s 

full name, title (if applicable), and signature. 

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DocuSign Envelope ID: 5813994A-78FC-4D90-A3D7-32FFD1B8A6BF Case 2:18-cv-00442-JCM-PAL Case 2:18-cv-00442-JCM-PAL Document 78 Document 80 Filed 06/12/18 Filed 06/15/18 Page 23 of 30 Page 23 of 30 

E. Unless otherwise directed by a Commission representative in writing, all 

submissions to the Commission pursuant to this Order must be emailed to DEbrief@ftc.gov or 

sent by overnight courier (not the U.S. Postal Service) to: Associate Director for Enforcement, 

Bureau of Consumer Protection, Federal Trade Commission, 600 Pennsylvania Avenue NW, 

Washington, DC 20580. The subject line must begin: FTC v. AWS, LLC et al., X180026. 

IX. RECORDKEEPING 

IT IS FURTHER ORDERED that Settling Defendants must create certain records for 20 

years after entry of the Order, and retain each such record for 5 years. Specifically, Settling 

Corporate Defendants and each Settling Individual Defendant for any business that such Settling 

Defendant, individually or collectively with any other Settling Defendants, is a majority owner 

or controls directly or indirectly, must create and retain the following records: 

A. accounting records showing the revenues from all goods or services sold; 

B. personnel records showing, for each person providing services, whether as an 

employee or otherwise, that person’s: name; addresses; telephone numbers; job title or position; 

dates of service; and (if applicable) the reason for termination; 

C. records of all consumer complaints and refund requests, whether received directly 

or indirectly, such as through a third party, and any response; 

D. all records necessary to demonstrate full compliance with each provision of this 

Order, including all submissions to the Commission; and 

E. a copy of each unique advertisement or other marketing material. 

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DocuSign Envelope ID: 5813994A-78FC-4D90-A3D7-32FFD1B8A6BF Case 2:18-cv-00442-JCM-PAL Case 2:18-cv-00442-JCM-PAL Document 78 Document 80 Filed 06/12/18 Filed 06/15/18 Page 24 of 30 Page 24 of 30 

X. COMPLIANCE MONITORING 

IT IS FURTHER ORDERED that, for the purpose of monitoring Settling Defendants’ 

compliance with this Order, including the financial representations upon which part of the 

judgment was suspended and any failure to transfer any assets as required by this Order: 

A. Within 14 days of receipt of a written request from a representative of the 

Commission, each Settling Defendant must: submit additional compliance reports or other 

requested information, which must be sworn under penalty of perjury; appear for depositions; 

and produce Documents for inspection and copying. The Commission is also authorized to 

obtain discovery, without further leave of court, using any of the procedures prescribed by 

Federal Rules of Civil Procedure 29, 30 (including telephonic depositions), 31, 33, 34, 36, 45, 

and 69. 

B. For matters concerning this Order, the Commission is authorized to communicate 

directly with each Settling Defendant. Settling Defendant must permit representatives of the 

Commission to interview any employee or other person affiliated with any Settling Defendant 

who has agreed to such an interview. The person interviewed may have counsel present. 

C. The Commission may use all other lawful means, including posing, through its 

representatives, as consumers, suppliers, or other individuals or entities, to Settling Defendants 

or any individual or entity affiliated with Settling Defendants, without the necessity of 

identification or prior notice. Nothing in this Order limits the Commission’s lawful use of 

compulsory process, pursuant to Sections 9 and 20 of the FTC Act, 15 U.S.C. §§ 49, 57b-1. 

D. Upon written request from a representative of the Commission, any consumer 

reporting agency must furnish consumer reports concerning Settling Individual Defendants, 

pursuant to Section 604(1) of the Fair Credit Reporting Act, 15 U.S.C. §1681b(a)(1). 

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DocuSign Envelope ID: 5813994A-78FC-4D90-A3D7-32FFD1B8A6BF Case 2:18-cv-00442-JCM-PAL Case 2:18-cv-00442-JCM-PAL Document 78 Document 80 Filed 06/12/18 Filed 06/15/18 Page 25 of 30 Page 25 of 30 

XI. RETENTION OF JURISDICTION 

IT IS FURTHER ORDERED that this Court retains jurisdiction of this matter for 

purposes of construction, modification, and enforcement of this Order. 

SO ORDERED this day of , 2018.

June 15, 2018.

______________________________ 

United States District Judge 

_________________________________ 

STIPULATED AND AGREED TO BY: 

FOR SETTLING DEFENDANTS: 

 Date:_________________________ 

Suzette Michele M. Moore 

Shumaker 

Bank of America Plaza, Suite 2800 

101 East Kennedy Boulevard 

Tampa, FL 33602 

Tel. (813) 227-2272 

Email: smoore@slk-law.com 

Attorney for defendants AWS, LLC, FBA 

Distributors, LLC, FBA Stores, LLC, Info 

Pros, LLC, Info Solutions, LLC, Online 

Auction Learning Center, Inc. (Mass. 

Corp.), Online Auction Learning Center, 

Inc. (Nev. Corp.), Christopher F. Bowser, 

Adam S. Bowser, and Jody L. Marshall 

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DocuSign Envelope ID: 5813994A-78FC-4D90-A3D7-32FFD1B8A6BF Case 2:18-cv-00442-JCM-PAL Case 2:18-cv-00442-JCM-PAL Document 78 Document 80 Filed 06/12/18 Filed 06/15/18 Page 26 of 30 Page 26 of 30 

________________________________ Date:_____________________________ 

Christopher F. Bowser, Individually and as 

Vice President and Manager of FBA 

Distributors, LLC; Vice President of FBA 

Stores, LLC, Managing Member of Info 

Solutions, LLC; President of Online Auction 

Learning Center (Mass. Corp.) and Online 

Auction Learning Center (Nev. Corp.) 

DEFENDANTS: 



 ____________________________________ Date:______________________________ 

Adam S. Bowser, Individually and as Manager 

of AWS, LLC; Manager and President of FBA 

Distributors, LLC; Managing Member of Info 

Solutions, LLC; Officer of Online Auction 

Learning Center (Mass. Corp.) and Online 

Auction Learning Center (Nev. Corp.) 

Date: ______________________________ 04/23/2018

FOR FEDERAL TRADE COMMISSION: 

____________________________________ 

Jody L. Marshall, Individually and as Manager 

of Info Pros, LLC; Managing Member of Info 

Solutions, LLC; Owner of FBA Distributors, 

LLC 

Roberto Anguizola 

Illinois Bar # 6270874 

Date: ______________________________ 6/12/2018

(Admitted pursuant to LR IA 11-3) 

Tel. (202) 326-3284 

Email: ranguizola@ftc.gov 

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DocuSign Envelope ID: 5813994A-78FC-4D90-A3D7-32FFD1B8A6BF Case 2:18-cv-00442-JCM-PAL Case 2:18-cv-00442-JCM-PAL Document 78 Document 80 Filed 06/12/18 Filed 06/15/18 Page 27 of 30 Page 27 of 30 

Miry Kim 

Washington Bar # 31456 

(Admitted pursuant to LR IA 11-3) 

Tel. (202) 326-3622 

Email: mkim@ftc.gov 

Gregory J. Evans 

DC Bar # 1033184 

(Admitted pursuant to LR IA 11-3) 

Tel. (202) 326-3425 

Email: gevans2@ftc.gov 

Federal Trade Commission 

600 Pennsylvania Avenue, N.W. 

Mail Drop CC-8528 

Washington, D.C. 20580 

Attorneys for Plaintiff 

FEDERAL TRADE COMMISSION 

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Case 2:18-cv-00442-JCM-PAL Case 2:18-cv-00442-JCM-PAL Document 78 Document 80 Filed 06/12/18 Filed 06/15/18 Page 28 of 30 Page 28 of 30 

CERTIFICATE OF SERVICE 

I hereby certify that on June 12, 2018, I caused the foregoing document to be filed with 

the Clerk of the Court via the Court’s CM/ECF electronic filing system. Additionally, I served 

all of the counsel and parties listed on the attached Service List by the methods indicated therein. 

/s/ Roberto Anguizola 

Roberto Anguizola 

Attorney for Plaintiff 

FEDERAL TRADE COMMISSION 

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Case 2:18-cv-00442-JCM-PAL Case 2:18-cv-00442-JCM-PAL Document 78 Document 80 Filed 06/12/18 Filed 06/15/18 Page 29 of 30 Page 29 of 30 

SERVICE LIST 

Suzette Michele M. Moore 

S. Moore Law 

4720 Cleveland Heights Blvd. 

Suite 201 

Lakeland, FL 33813 

Tel. (863) 229-2140 

Email: s.moore@smoorelaw.com 

Attorney for defendants AWS, LLC, FBA 

Distributors, LLC, FBA Stores, LLC, 

Info Pros, LLC, Online Auction Learning 

Center, Inc. (Mass. Corp.), Online 

Auction Learning Center, Inc. (Nev. 

Corp.), Christopher F. Bowser, Adam S. 

Bowser, and Jody Marshall 

Seeking admission Pro Hac Vice 

Served via email 

Brick Kane 

President 

Robb Evans & Associates LLC 

11450 Sheldon Street 

Sun Valley, California 91352-1121 

Tel: (818) 768-8100 

Fax: (818) 768-8802 

Email: bkane@robbevans.com 

Court Appointed Receiver 

Served via email 

Ronald D. Green (NV Bar No. 7360) 

LaTeigra C. Cahill (NV Bar No. 14352) 

Randazza Legal Group, PLLC 

4035 S. El Capitan Way 

Las Vegas, NV 89147 

Tel. (702) 420 2001 

Email: lcc@randazza.com, 

rdg@randazza.com 

Attorney for defendants AWS, LLC, 

FBA Distributors, LLC, FBA Stores, 

LLC, Info Pros, LLC, Online Auction 

Learning Center, Inc. (Mass. Corp.), 

Online Auction Learning Center, Inc. 

(Nev. Corp.), Christopher F. Bowser, 

Adam S. Bowser, and Jody Marshall 

Served via email 

Gary Owen Caris 

Barnes & Thornburg LLP 

2029 Century Park E., Suite 300 

Los Angeles, California 90067-2904 

Tel. (424) 363-2920 

Email: gcaris@btlaw.com 

Attorney for the Court Appointed 

Receiver Robb Evans & Associates 

LLC 

Served via email 

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Case 2:18-cv-00442-JCM-PAL Case 2:18-cv-00442-JCM-PAL Document 78 Document 80 Filed 06/12/18 Filed 06/15/18 Page 30 of 30 Page 30 of 30 

James C. Bastian, Jr. 

Shulman Hodges & Bastian LLP 

100 Spectrum Center Drive, Suite 600 

Irvine, CA 92618 

Tel. (949) 340-3400 

Email: jbastian@shbllp.com 

Attorney for defendants Adams 

Consulting, LLC, Global Marketing 

Services L.L.C, and Jeffery A. Gomez 

Served via email 

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