UNITED STATES DISTRICT COURT 

DISTRICT OF MARYLAND 

FEDERAL TRADE COMMISSION 

Plaintiff, 

v. 

ECOLOGICAL FOX, LLC, a Maryland limited liability 

company,1 

LUKE CHADWICK, individually and as an officer or 

owner of Global Property Alliance, Inc. (also doing 

business as Sanctuary Bay, Sanctuary Belize, The 

Reserve, Kanantik, Laguna Palms, Bamboo Springs, Eco 

Futures, Eco Futures Development, Eco Futures Belize, 

Sittee River Wildlife Reserve, Buy Belize, Buy 

International, and Buy Paradise), Sittee River Wildlife 

Reserve (also doing business as Sanctuary Bay, Sanctuary 

Belize, and The Reserve), Buy Belize, LLC (also doing 

business as Sanctuary Bay, Sanctuary Belize, The 

Reserve, Kanantik, Laguna Palms, and Bamboo Springs), 

Buy International, Inc. (also doing business as Sanctuary 

Bay, Sanctuary Belize, The Reserve, Kanantik, Laguna 

Palms, and Bamboo Springs), Foundation Development 

Management Inc., Eco Futures-Development (also doing 

business as Sanctuary Bay, Sanctuary Belize, and The 

Reserve), Eco-Futures Belize Limited (also doing business 

as Sanctuary Bay, Sanctuary Belize, and The Reserve), 

Power Haus Marketing, Prodigy Management Group, 

LLC, Belize Real Estate Affiliates, LLC (also doing 

business as Coldwell Banker Belize and Coldwell Banker 

Southern Belize), Exotic Investor, LLC (also doing 

business as Coldwell Banker Belize and Coldwell Banker 

Southern Belize), and Southern Belize Realty LLC (also 

doing business as Coldwell Banker Belize and Coldwell 

Banker Southern Belize), 

ANDRIS PUKKE, also known as Marc Romeo and Andy 

Storm, individually and as an officer or owner of Global 

Property Alliance, Inc. (also doing business as Sanctuary 

Bay, Sanctuary Belize, The Reserve, Kanantik, Laguna 

Civil Action No: 

COMPLAINT FOR 

PERMANENT INJUNCTION 

AND OTHER EQUITABLE 

RELIEF 

See Ex. A for all parties’ addresses. 1 
Palms, Bamboo Springs, Eco Futures, Eco Futures 

Development, Eco Futures Belize, Sittee River Wildlife 

Reserve, Buy Belize, Buy International, and Buy 

Paradise), Sittee River Wildlife Reserve (also doing 

business as Sanctuary Bay, Sanctuary Belize, and The 

Reserve), Buy Belize, LLC (also doing business as 

Sanctuary Bay, Sanctuary Belize, The Reserve, Kanantik, 

Laguna Palms, and Bamboo Springs), Buy International, 

Inc. (also doing business as Sanctuary Bay, Sanctuary 

Belize, The Reserve, Kanantik, Laguna Palms, and 

Bamboo Springs), Foundation Development Management 

Inc., Eco Futures-Development (also doing business as 

Sanctuary Bay, Sanctuary Belize, and The Reserve), EcoFutures Belize Limited (also doing business as Sanctuary 

Bay, Sanctuary Belize, and The Reserve), Power Haus 

Marketing, Prodigy Management Group, LLC, Belize 

Real Estate Affiliates, LLC (also doing business as 

Coldwell Banker Belize and Coldwell Banker Southern 

Belize), Exotic Investor, LLC (also doing business as 

Coldwell Banker Belize and Coldwell Banker Southern 

Belize), and Southern Belize Realty LLC (also doing 

business as Coldwell Banker Belize and Coldwell Banker 

Southern Belize), 

PETER BAKER, individually and as an officer or owner 

of Global Property Alliance, Inc. (also doing business as 

Sanctuary Bay, Sanctuary Belize, The Reserve, Kanantik, 

Laguna Palms, Bamboo Springs, Eco Futures, Eco Futures 

Development, Eco Futures Belize, Sittee River Wildlife 

Reserve, Buy Belize, Buy International, and Buy 

Paradise), Sittee River Wildlife Reserve (also doing 

business as Sanctuary Bay, Sanctuary Belize, and The 

Reserve), Buy Belize, LLC (also doing business as 

Sanctuary Bay, Sanctuary Belize, The Reserve, Kanantik, 

Laguna Palms, and Bamboo Springs), Buy International, 

Inc. (also doing business as Sanctuary Bay, Sanctuary 

Belize, The Reserve, Kanantik, Laguna Palms, and 

Bamboo Springs), Foundation Development Management 

Inc., Eco Futures-Development (also doing business as 

Sanctuary Bay, Sanctuary Belize, and The Reserve), EcoFutures Belize Limited (also doing business as Sanctuary 

Bay, Sanctuary Belize, and The Reserve), and Power Haus 

Marketing, 

GLOBAL PROPERTY ALLIANCE, INC., a California 

corporation, also doing business as Sanctuary Bay, 

2 
Sanctuary Belize, The Reserve, Kanantik, Laguna Palms, 

Bamboo Springs, Eco Futures, Eco Futures Development, 

Eco Futures Belize, Sittee River Wildlife Reserve, Buy 

Belize, Buy International, and Buy Paradise, 

SITTEE RIVER WILDLIFE RESERVE, an entity 

organized under the laws of Belize, also doing business as 

Sanctuary Bay, Sanctuary Belize, and The Reserve, 

BUY BELIZE, LLC, a California limited liability 

company, also doing business as Sanctuary Bay, 

Sanctuary Belize, The Reserve, Kanantik, Laguna Palms, 

and Bamboo Springs, 

BUY INTERNATIONAL, INC., a California corporation, 

also doing business as Sanctuary Bay, Sanctuary Belize, 

The Reserve, Kanantik, Laguna Palms, and Bamboo 

Springs, 

FOUNDATION DEVELOPMENT MANAGEMENT 

INC., a California corporation, 

ECO-FUTURES DEVELOPMENT, a California 

corporation, also doing business as Sanctuary Bay, 

Sanctuary Belize, and The Reserve, 

ECO-FUTURES BELIZE LIMITED, a company 

organized under the laws of Belize, also doing business as 

Sanctuary Bay, Sanctuary Belize, and The Reserve, 

POWER HAUS MARKETING, a California corporation, 

BRANDI GREENFIELD, individually and as an officer 

or owner of Global Property Alliance, Inc. (also doing 

business as Sanctuary Bay, Sanctuary Belize, The 

Reserve, Kanantik, Laguna Palms, Bamboo Springs, Eco 

Futures, Eco Futures Development, Eco Futures Belize, 

Sittee River Wildlife Reserve, Buy Belize, Buy 

International, and Buy Paradise), Sittee River Wildlife 

Reserve (also doing business as Sanctuary Bay, Sanctuary 

Belize, and The Reserve), Buy Belize, LLC (also doing 

business as Sanctuary Bay, Sanctuary Belize, The 

Reserve, Kanantik, Laguna Palms, and Bamboo Springs), 

Buy International, Inc. (also doing business as Sanctuary 

Bay, Sanctuary Belize, The Reserve, Kanantik, Laguna 

Palms, and Bamboo Springs), Foundation Development 

3 
Management Inc., Eco Futures-Development (also doing 

business as Sanctuary Bay, Sanctuary Belize, and The 

Reserve), Eco-Futures Belize Limited (also doing business 

as Sanctuary Bay, Sanctuary Belize, and The Reserve), 

Power Haus Marketing, and BG Marketing, LLC, 

BG MARKETING, LLC, an Oklahoma limited liability 

company, 

PRODIGY MANAGEMENT GROUP, LLC, a Wyoming 

limited liability company, 

JOHN USHER, individually and as an officer or owner of 

Sittee River Wildlife Reserve (also doing business as 

Sanctuary Bay, Sanctuary Belize, and The Reserve) and 

Eco-Futures Belize Limited (also doing business as 

Sanctuary Bay, Sanctuary Belize, and The Reserve), 

ROD KAZAZI, individually and as an officer or owner of 

Global Global Property Alliance, Inc. (also doing business 

as Sanctuary Bay, Sanctuary Belize, The Reserve, 

Kanantik, Laguna Palms, Bamboo Springs, Eco Futures, 

Eco Futures Development, Eco Futures Belize, Sittee 

River Wildlife Reserve, Buy Belize, Buy International, 

and Buy Paradise), Buy Belize, LLC (also doing business 

as Sanctuary Bay, Sanctuary Belize, The Reserve, 

Kanantik, Laguna Palms, and Bamboo Springs), Buy 

International, Inc. (also doing business as Sanctuary Bay, 

Sanctuary Belize, The Reserve, Kanantik, Laguna Palms, 

and Bamboo Springs), Eco Futures-Development (also 

doing business as Sanctuary Bay, Sanctuary Belize, and 

The Reserve), and Foundation Partners (formerly known 

as Red Crane Advisors, Inc.), 

FOUNDATION PARTNERS, a California corporation 

formerly known as Red Crane Advisors, Inc., 

FRANK COSTANZO, also known as Frank Green, Frank 

Peerless Green, Frank Connelly, and Frank ConnellyCostanzo, individually and as officer or owner of 

Ecological Fox, LLC, Buy International, Inc. (also doing 

business as Sanctuary Bay, Sanctuary Belize, The 

Reserve, Kanantik, Laguna Palms, and Bamboo Springs), 

and Foundation Development Management, Inc., 

4 
BELIZE REAL ESTATE AFFILIATES, LLC, a limited 

liability company organized under the laws of St. Kitts 

and Nevis, also doing business as Coldwell Banker Belize 

and Coldwell Banker Southern Belize, 

EXOTIC INVESTOR, LLC, a limited liability company 

organized under the laws of St. Kitts and Nevis, also 

doing business as Coldwell Banker Belize and Coldwell 

Banker Southern Belize, 

SOUTHERN BELIZE REALTY, LLC, a limited liability 

company organized under the laws of Belize, also doing 

business as Coldwell Banker Belize and Coldwell Banker 

Southern Belize, 

SANCTUARY BELIZE PROPERTY OWNERS’ 

ASSOCIATION, a Texas non-profit corporation, also 

doing business as The Reserve Property Owners’ 

Association, and 

ATLANTIC INTERNATIONAL BANK, LTD., a 

company organized under the laws of Belize, 

Defendants, and 

ANGELA CHITTENDEN, 

BEACH BUNNY HOLDINGS, LLC, a California limited 

liability company, 

THE ESTATE OF JOHN PUKKE, also known as the 

Estate of Janis Pukke and the Estate of John Andris 

Pukke, 

JOHN VIPULIS, and 

DEBORAH CONNELLY, 

Relief Defendants. 

Plaintiff, the Federal Trade Commission (“FTC”), for its Complaint alleges: 

5 
1. The FTC brings this action under Section 13(b) of the Federal Trade Commission 

Act (“FTC Act”), 15 U.S.C. § 53(b), and the Telemarketing and Consumer Fraud and Abuse 

Prevention Act (“Telemarketing Act”), 15 U.S.C. §§ 6101-6108, to obtain temporary, 

preliminary, and permanent injunctive relief, rescission or reformation of contracts, restitution, 

the refund of monies paid, disgorgement of ill-gotten gains, and other equitable relief for 

Defendants’ acts or practices in violation of Section 5(a) of the FTC Act, 15 U.S.C. § 45(a), and 

the Telemarketing Sales Rule (“TSR”), 16 C.F.R. Part 310, in connection with the marketing and 

sale of real estate investments and related services. 

2. Since 2005, Andris Pukke and his co-defendants have sold lots in a Southern 

Belize real estate development. The development has had several names, including Sanctuary 

Bay, Sanctuary Belize, and The Reserve (for ease, “Sanctuary Belize”). The Defendants sell 

these lots primarily to Americans looking to retire abroad or seeking investment opportunities. 

They target small business owners and couples nearing retirement. Among other things, they 

claim the lots are low-risk investments that consumers can resell easily and enjoy 200%-300% 

appreciation. They further claim that every dollar from lot sales goes into the development, 

which will have all the amenities of an American luxury resort community, including a hospital, 

hotels, a golf course, a spa, a casino, high-end boutiques, cafes, restaurants, and an “Americanstyle” supermarket. At all times relevant to the Complaint, the Defendants have promised 

consumers that Sanctuary Belize would be finished quickly—often within two, and always 

within five, years. 

3. In fact, the lots are not low-risk investments. After twelve years of promises, the 

development is nowhere close to finished and it is unlikely it will ever be finished. Many 

consumers attempt to sell their lots on the open market and fail because there is no market for 

6 
them. Others sell their lots back to the Defendants years later at a loss, despite claims that the 

lots would rapidly appreciate. Still other owners simply stop making payments on their lots. 

Defendants then resell these lots to new victims without extinguishing or remunerating the prior 

owner’s interest—creating a situation in which two, three or even four victims may have an 

interest in the same lot. There are more than 1,000 victims. 

JURISDICTION AND VENUE 

4. This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331, 1337(a), 

and 1345, and 15 U.S.C. §§ 45(a), 53(b), 6102(c), and 6105(b). 

5. Venue is proper in this District under 28 U.S.C. § 1391(b)(2), (b)(3), (c)(2), 

(c)(3), and (d), and 15 U.S.C. § 53(b). 

PLAINTIFF 

6. The FTC is an independent agency of the United States Government created by 

statute. 15 U.S.C. §§ 41-58. The FTC enforces Section 5(a) of the FTC Act, 15 U.S.C. § 45(a), 

which prohibits unfair or deceptive acts or practices in or affecting commerce. The FTC also 

enforces the Telemarketing Act, 15 U.S.C. §§ 6101-6108, and TSR, 16 C.F.R. Part 310, which 

prohibits deceptive and abusive telemarketing acts or practices. 

7. The FTC is authorized to initiate federal district court proceedings, by its own 

attorneys, to enjoin violations of the FTC Act and TSR, and to secure such equitable relief as 

may be appropriate in each case, including rescission or reformation of contracts, restitution, the 

refund of monies paid, and the disgorgement of ill-gotten monies. 15 U.S.C. §§ 53(b), 6102(c), 

and 6105(b). 

7 
DEFENDANTS 

8. Andris Pukke, who uses the aliases Marc Romeo and Andy Storm, resides in 

Newport Beach, California. Although Pukke hides his role and does not legally own any of the 

corporate defendants, he controls and participates in the conduct of the Sanctuary Belize 

Enterprise (“SBE”), which is at the heart of the deceptive, unlawful real estate investment 

scheme alleged in this Complaint. SBE includes Defendants Global Property Alliance, Inc., 

Sittee River Wildlife Reserve, Buy Belize, LLC, Buy International, Inc., Foundation 

Development Management, Inc., Eco-Futures Development, Eco-Futures Belize Limited, Power 

Haus Marketing, and Sanctuary Belize Property Owners’ Association (“Core SBE Corporate 

Defendants”), as well as the following individuals and companies that they own or control: Luke 

Chadwick, John Usher, Rod Kazazi, Brandi Greenfield, Frank Costanzo (collectively, with 

Pukke, “SBE Individual Defendants”), Prodigy Management Group LLC, Foundation Partners, 

BG Marketing, LLC, Ecological Fox, LLC, Belize Real Estate Affiliates LLC, Exotic Investor 

LLC, Southern Belize Realty LLC (collectively with the Core SBE Corporate Defendants, “SBE 

Corporate Defendants”). Collectively, this Complaint refers to SBE Corporate Defendants and 

SBE Individual Defendants as “SBE Defendants.” 

9. In 2003, Pukke purchased the parcel of land that ultimately became Sanctuary 

Belize through defendant SRWR (BZ). He has since that time retained control over SBE. 

Currently, all of the Core SBE Corporate Defendants operate from 3333 Michelson Drive in 

Irvine California (“3333 Michelson”). From his corner office in 3333 Michelson, Pukke controls 

SBE and participates in its activities by deciding salaries for SBE employees, hiring and firing 

SBE employees, developing and designing SBE marketing and products, determining SBE 

marketing strategy, specifying contract terms for sales within Sanctuary Belize, authorizing 

8 
payments to third parties, using SBE funds for his personal matters, and transferring SBE funds 

to numerous family members. At all times material to this Complaint, acting alone or in concert 

with others, he has formulated, directed, controlled, had the authority to control, or participated 

in the acts and practices set forth in this Complaint. Defendant Pukke, in connection with the 

matters alleged herein, transacts or has transacted business in this District and throughout the 

United States. 

10. Peter Baker resides in Newport Beach, California. Baker legally owns certain 

Core SBE Corporate Defendants, including Global Property Alliance Inc., Eco-Futures 

Development, and Eco-Futures Belize Limited. Baker is a bank signatory for two Core SBE 

Corporate Defendants: Global Property Alliance, Inc. and Sittee River Wildlife Reserve. Baker 

holds two of three board positions for two Core SBE Corporate Defendants: Foundation 

Development Management, Inc. and Buy International Inc. As of the end of 2016, Baker was the 

Chairman of the Board for Sittee River Wildlife Reserve. Baker is also the CEO of Buy Belize, 

LLC. Additionally, he maintains the Fictitious Business Name (“FBN”) “Eco Futures.” Global 

Property Alliance (which Baker owns) has registered three additional FBNs: “Eco-Futures 

Belize,” “Eco-Futures Development,” and “Sittee River Wildlife Reserve HOA.” In these roles, 

Baker controls and participates in the conduct alleged in the Complaint. Baker was also an 

undisclosed party to the 2008 transaction approved by this Court through which Pukke was 

ordered to turn over interests in Sanctuary Belize to a Court-appointed receiver. The 

Commission used proceeds from those interests to repay Pukke’s debt-relief scam victims. 

Baker purchased Pukke’s shares of Sanctuary Belize from the Court-appointed receiver so that 

Pukke could maintain control over SBE, unbeknownst to the Court, the Receiver, and the FTC at 

that time. At all times material to this Complaint, acting alone or in concert with others, he has 

9 
formulated, directed, controlled, had the authority to control, or participated in the acts and 

practices set forth in this Complaint. Defendant Baker, in connection with the matters alleged 

herein, transacts or has transacted business in this District and throughout the United States. 

11. Global Property Alliance, Inc. (“GPA”) is a California corporation with its 

principal place of business at 3333 Michelson. GPA is a Core SBE Defendant whose owners 

and officers include Baker, Greenfield, and Kazazi. Pukke is the de facto head of GPA, with 

Greenfield as his “right hand.” Among other things, GPA controls the other SBE sales arms, 

including Buy Belize and Buy International. Furthermore, GPA has the following registered 

Fictitious Business Names (“FBN”): “Eco-Futures Development,” “Eco-Futures Belize,” and 

“Sittee River Wildlife Reserve HOA.” GPA also operates United States domestic bank accounts 

under the following DBAs: “Eco Futures Belize” and “Sittee River Wildlife Reserve.” 

Currently and at times material to this Complaint, acting alone or in concert with others, GPA 

has advertised, marketed, distributed, or sold SBE’s real estate investments and related services 

to consumers in this District and throughout the United States. 

12. Sittee River Wildlife Reserve (“SRWR (BZ)”) is a Belizean entity organized as a 

nonprofit under the laws of Belize. SRWR (BZ) operates for its own profit or that of its 

members or control people, including, at various times, Pukke, Baker, John Usher, and Luke 

Chadwick. SRWR (BZ)’s de facto principal place of business is 3333 Michelson. As noted 

above, SRWR (BZ) operates in the United States through fellow SBE member GPA, which 

controls a United States domestic bank account in its name. Pukke originally created SRWR 

(BZ) to hold the land for himself and SBE. Indeed, this Court has already recognized in the 

AmeriDebt proceeding that land held in the name of SRWR (BZ) was actually land held by and 

for the benefit of Pukke, rather than land held by a genuine nonprofit. Furthermore, SRWR (BZ) 

10 
markets Sanctuary Belize lots solely for the profit of those who control it. SBE represents that 

SRWR (BZ) holds title to the Sanctuary Belize land. It shares officers and owners with the forprofit SBE Corporate Defendants, is operated by the SBE Individual Defendants to further the 

deceptive scheme, and comingles funds with the rest of the SBE. At all times material to this 

Complaint, acting alone or in concert with others, SRWR (BZ) has advertised, marketed, 

distributed, or sold SBE’s real estate investments and related services to consumers in this 

District and throughout the United States. 

13. Buy Belize, LLC (“Buy Belize”) is a California limited liability company with its 

principal place of business at 3333 Michelson. Baker is the managing member. Buy Belize 

performs marketing functions for SBE, such as housing a telemarketing “boiler room,” operating 

a website, and running infomercials in its name. Currently and at times material to this 

Complaint, acting alone or in concert with others, Buy Belize has advertised, marketed, 

distributed, or sold SBE’s real estate investments and related services to consumers in this 

District and throughout the United States. 

14. Buy International, Inc. (“Buy International”) is a California entity with its 

principal place of business at 3333 Michelson. Buy International performs marketing functions 

for SBE, such as housing a telemarketing “boiler room,” operating a website, and running 

commercials in its name. Currently and at times material to this Complaint, acting alone or in 

concert with others, Buy International has advertised, marketed, distributed, or sold SBE’s real 

estate investments and related services to consumers in this District and throughout the United 

States. 

15. Foundation Development Management Inc. (“FDM”) is a California corporation 

with its principal place of business at 3333 Michelson. FDM pays SBE telemarketers and funds 

11 
and performs real estate development functions. Currently and at times material to this 

Complaint, acting alone or in concert with others, FDM has advertised, marketed, distributed, or 

sold SBE’s real estate investments and related services to consumers in this District and 

throughout the United States. 

16. Eco Futures Development (“Eco-Futures (US)”) is a California corporation with 

its principal place of business at 3333 Michelson. Defendant Rod Kazazi incorporated EcoFutures (US), which, among other things, receives consumers’ lot payments and Belizean taxes 

on behalf of SBE’s Belizean members. Currently and at times material to this Complaint, acting 

alone or in concert with others, Eco-Futures (US) has advertised, marketed, distributed, or sold 

SBE’s real estate investments and related services to consumers in this District and throughout 

the United States. 

17. Eco-Futures Belize Limited (“Eco-Futures (BZ)”) is a Belizean entity Baker owns 

and Usher manages. Eco-Futures (BZ) has a de facto principal place of business at 3333 

Michelson, where communications purportedly from “Eco-Futures” entities are sent and 

received. As noted above, Eco-Futures (BZ) operates in the United States through fellow SBE 

member GPA, which registered a FBN allowing it to do business as “Eco-Futures Belize,” and 

operates a United States domestic bank account in the name of “Eco Futures Belize.” SBE 

represents that Eco-Futures (BZ) is the “developer” for Sanctuary Belize. In this role, EcoFutures (BZ) is a party to the lot sale agreement. Nonetheless, Eco-Futures (BZ) directs 

American consumers to pay it at a California address, most recently 3333 Michelson. Currently 

and at times material to this Complaint, acting alone or in concert with others, Eco-Futures (BZ) 

has advertised, marketed, distributed, or sold SBE’s real estate investments and related services 

to consumers in this District and throughout the United States. 

12 
18. Power Haus Marketing (“Power Haus”) is a California corporation with its 

principal place of business at 3333 Michelson. SBE uses Power Haus to purchase advertising. 

Currently and at times material to this Complaint, acting alone or in concert with others, Power 

Haus has advertised, marketed, distributed, or sold SBE’s real estate investments and related 

services to consumers in this District and throughout the United States. 

19. Luke Chadwick resides in Costa Mesa, California. He is SBE’s public face in 

many marketing materials, including infomercials. Chadwick describes himself as a Sanctuary 

Belize “principal.” As a principal, he signs contracts on behalf of Eco-Futures (BZ). Chadwick 

physically interacts with consumers on SBE’s behalf, including taking part in sales tours of 

Sanctuary Belize and conducting webinars for consumers. Chadwick served as a SRWR (BZ) 

director and owns the entities that control Coldwell Banker Belize: Southern Belize Realty, 

LLC, Belize Realty Associates, LLC, and Exotic Investor LLC. Currently and at times material 

to this Complaint, acting alone or in concert with others, he has formulated, directed, controlled, 

had the authority to control, or participated in the acts and practices set forth in this Complaint. 

Defendant Chadwick, in connection with the matters alleged herein, transacts or has transacted 

business in this District and throughout the United States. 

20. Prodigy Management Group, LLC (“Prodigy”) is a Wyoming limited liability 

company with its principal place of business at 3333 Michelson. Nominally an “independent 

contractor,” internal SBE documents treat Prodigy as the means through which SBE 

compensates Chadwick. Currently and at times material to this Complaint, acting alone or in 

concert with others, Prodigy has advertised, marketed, distributed, or sold SBE’s real estate 

investments and related services to consumers in this District and throughout the United States. 

13 
21. Brandi Greenfield resides in Irvine, California. Greenfield began as SBE’s 

“Director of Sales” in 2007 and serves as Pukke’s “right hand.” Among other things, she is a 

GPA officer, signs contracts on behalf of Eco Futures (BZ), and directly participates in 

marketing to consumers, personally making misrepresentations directly to consumers. Currently 

and at times material to this Complaint, acting alone or in concert with others, she has 

formulated, directed, controlled, had the authority to control, or participated in the acts and 

practices set forth in this Complaint. Defendant Greenfield, in connection with the matters 

alleged herein, transacts or has transacted business in this District and throughout the United 

States. 

22. BG Marketing, LLC (“BG Marketing”) is an Oklahoma limited liability company 

with its principal place of business at 3333 Michelson. Nominally an “independent contractor,” 

BG Marketing is on SBE’s payroll. It has no known operations other than receiving part of 

Greenfield’s compensation for SBE activities. Currently and at times material to this Complaint, 

acting alone or in concert with others, BG Marketing has advertised, marketed, distributed, or 

sold SBE’s real estate investments and related services to consumers in this District and 

throughout the United States. 

23. John Usher resides in Belize. Usher became the Director of SRWR (BZ) in 2008 

before buying the Sanctuary Belize parcel of land from the Receiver appointed by this Court in 

FTC v. AmeriDebt Inc., No. PJM 03-3317 (D. Md.). Usher continued as a SRWR (BZ) board 

member until at least late 2013. He is a bank signatory on Eco Futures (BZ)’s U.S. bank account 

and is Sanctuary Belize Property Owners’ Association’s Director. Various SBE marketing 

materials identify Usher as the “Chairman,” “developer,” or “principal.” In his role as a SBE 

principal, Usher has visited Broward County, Florida, and Orange County, California, to meet 

14 
Pukke and transact SBE business. Additionally, Usher has met with numerous American 

consumers during the SBE sales process, repeating many of the misrepresentations detailed 

below. Currently and at times material to this Complaint, acting alone or in concert with others, 

he has formulated, directed, controlled, had the authority to control, or participated in the acts 

and practices set forth in this Complaint. Defendant Usher, in connection with the matters 

alleged herein, transacts or has transacted business in this District and throughout the United 

States. 

24. Rod Kazazi resides in Newport Beach, California. Kazazi is GPA’s CFO and, at 

times, he has identified himself as GPA’s COO (including in testimony to this Court). He has 

negotiated contracts with consumers and third parties (including Sanctuary Belize lot buyback 

agreements), responded to consumer complaints, directed financial transfers, incorporated SBE 

entities, and was a bank signatory for SBE entity accounts—including GPA, SRWR (BZ), Eco 

Futures (BZ), Eco Futures (US), and FDM. In November 2015, this Court held a hearing 

regarding Pukke’s supervised release from incarceration. At that hearing, this Court heard 

testimony from Kazazi regarding the SBE. At that time, Kazazi testified that he had the 

following roles: (i) as an SBE control person, he had authority over how funds are used to 

develop Sanctuary Belize; (ii) as COO of GPA, he worked with SRWR (BZ); (iii) as a control 

person for GPA, he did business as Eco Futures; and (iv) as a control person for GPA, he had 

hiring and firing authority within GPA. Separately, Kazazi also represented to SBE’s current 

payroll provider that he is the “owner” of Buy Belize and GPA. Currently and at times material 

to this Complaint, acting alone or in concert with others, he has formulated, directed, controlled, 

had the authority to control, or participated in the acts and practices set forth in this Complaint. 

15 
Defendant Kazazi, in connection with the matters alleged herein, transacts or has transacted 

business in this District and throughout the United States. 

25. Foundation Partners (“FP”) is a California business entity with its principal place 

of business at 3333 Michelson. Kazazi owns FP. Nominally an “independent contractor,” FP is 

on SBE’s payroll. FP has a website that lists various development projects including Sanctuary 

Belize and two others to which SBE has transferred millions. Currently and at times material to 

this Complaint, acting alone or in concert with others, FP has advertised, marketed, distributed, 

or sold SBE’s real estate investments and related services to consumers in this District and 

throughout the United States. 

26. Frank Costanzo, who uses aliases Frank Green, Frank Peerless Green, Frank 

Connelly, and Frank Connelly-Costanzo, resides in Los Angeles, California. Frank Costanzo is 

married to proposed relief defendant Deborah Connelly. Costanzo was an attorney until both the 

Maryland Court of Appeals and the Florida Supreme Court disbarred him for misappropriating 

client funds and related misconduct. Costanzo is an officer for two SBE entities: Buy 

International and FDM. In sales presentations, Costanzo presents himself as an environmental 

expert and makes misrepresentations directly to consumers, including leading deceptive 

presentations and accompanying potential buyers on property tours. As noted in SBE marketing 

materials, Costanzo is “deeply involved” with Sanctuary Belize. Currently and at times material 

to this Complaint, acting alone or in concert with others, he has formulated, directed, controlled, 

had the authority to control, or participated in the acts and practices set forth in this Complaint. 

Defendant Costanzo, in connection with the matters alleged herein, transacts or has transacted 

business in this District and throughout the United States. 

16 
27. Ecological Fox, LLC (“EF”) is a Maryland limited liability company with an 

address in Annapolis, Maryland, and with a de facto principal place of business at 3333 

Michelson. Costanzo’s wife legally owns this entity. EF has no known operations other than 

receiving part of Costanzo’s SBE compensation. Currently and at times material to this 

Complaint, acting alone or in concert with others, EF has advertised, marketed, distributed, or 

sold SBE’s real estate investments and related services to consumers in this District and 

throughout the United States. 

28. Belize Real Estate Affiliates LLC (“BREA (NV)”) is a limited liability company 

organized under the laws of St. Kitts and Nevis with places of business at 3333 Michelson and in 

Placencia, Belize. BREA (NV) was the Coldwell Banker franchisee that, in turn, owns Southern 

Belize Realty, LLC. Along with Exotic Investor, LLC and Southern Belize Realty, LLC, BREA 

(NV) operated a Coldwell Banker franchise used to market Sanctuary Belize and thwart 

consumers’ attempts to sell lots to third parties. Chadwick owns BREA (NV). BREA (NV) used 

3333 Michelson for elements of its operations, it used U.S. addresses in communications with 

Coldwell Banker, and it used a U.S. address for its domestic bank account. BREA (NV)’s 

franchise agreement with Coldwell Banker is governed by U.S. law and subjects BREA (NV) to 

U.S. jurisdiction for disputes arising out of its agreement. Coldwell Banker terminated the 

franchise in December 2017, but Coldwell Banker Belize nonetheless continued operating under 

the “Coldwell Banker” name for at least a period of time. At times material to this Complaint, 

acting alone or in concert with others, BREA (NV) has advertised, marketed, distributed, or sold 

SBE’s real estate investments and related services to consumers in this District and throughout 

the United States. 

17 
29. Exotic Investor, LLC (“Exotic (NV)”) is a limited liability company organized 

under the laws of St. Kitts and Nevis with places of business in both Placencia, Belize and at 

3333 Michelson. Exotic (NV) is the member of BREA (NV). Chadwick, in turn, owns Exotic 

(NV). In addition, as Exotic (NV), Chadwick produced and appeared in videos made to seem 

like a reality TV show marketing Sanctuary Belize. At times material to this Complaint, acting 

alone or in concert with others, Exotic (NV) has advertised, marketed, distributed, or sold SBE’s 

real estate investments and related services to consumers in this District and throughout the 

United States. 

30. Southern Belize Realty LLC (“SBR”) is a limited liability company organized 

under the laws of Belize that also does business as “Coldwell Banker Belize” and “Coldwell 

Banker Southern Belize” with places of business at 3333 Michelson and in Placencia, Belize. 

Chadwick owns SBR, which was a Coldwell Banker sub-franchisee until December 2017, 

although SBR continued to use the “Coldwell Banker” name for at least some period of time. 

Charmain Voss is a manager reporting to Chadwick. Chadwick and Voss use both 

“@ColdwellBankerBelize.com” and “@SanctuaryBelize.com” email addresses, employees at 

3333 Michelson coordinate travel arrangements for “Coldwell Banker Belize” employees, and 

Voss has referred to “Coldwell Banker Belize” and “Sanctuary Belize” as “ONE TEAM.” At 

times material to this Complaint, acting alone or in concert with others, SBR has advertised, 

marketed, distributed, or sold SBE’s real estate investments and related services to consumers in 

this District and throughout the United States. 

31. Sanctuary Belize Property Owners’ Association (“SBPOA”), also known as The 

Reserve Property Owners’ Association (“RPOA”), is a Texas non-profit corporation with its 

principal place of business at 3333 Michelson. Although registered as a nonprofit, it is in fact 

18 
operated for the profit of its owners. Usher is its Director, and when SBE changed the 

development’s name from “Sanctuary Belize” to “the Reserve,” SBPOA registered “The Reserve 

Property Owners Association” as a trade name. SBE uses SBPOA to collect monthly 

homeowners’ association dues. In theory, these dues should support only owners’ common 

amenities; in reality, SBE commingles SBPOA funds with other SBE money by depositing 

consumers’ HOA payments into general GPA bank accounts. Both SBPOA and RPOA invoices 

direct consumers to make checks payable to SRWR, and instruct consumers to mail checks to 

“SRWR c/o Eco-Futures” at 3333 Michelson. Therefore, it comingles funds with for-profit 

entities, and performs few services other than funneling money to these for-profit entities. 

Currently and at times material to this Complaint, acting alone or in concert with others, SBPOA 

has advertised, marketed, distributed, or sold SBE’s real estate investments and related services 

to consumers in this District and throughout the United States. 

32. Atlantic International Bank Ltd. (“Atlantic International”) is an entity organized 

under the laws of Belize and based in Belize City, Belize. No American financial authority 

regulates Atlantic International and it has no U.S. branches. Atlantic International is a so-called 

“international” bank within Belize, meaning it markets its services to foreign consumers, 

including Americans, instead of Belizeans or other individuals residing in Belize. Atlantic 

International jointly markets with SBE and shares its physical address in Belize City with 

Southern Belize Realty (d/b/a Coldwell Banker Southern Belize). Atlantic International visited 

SBE’s California offices and presented to SBE telemarketers regarding the services Atlantic 

International could provide consumers, including lower interest rates and relaxed underwriting 

for buyers wishing to finance Sanctuary Belize home construction. Atlantic International urged 

the telemarketers to sell its banking services to American consumers as part of the Sanctuary 

19 
Belize sales pitch. As Atlantic International’s CEO explained, the purpose of the marketing is to 

create ongoing banking relationships with consumers residing in the United States. SBE 

principal Chadwick filmed a marketing video endorsing Atlantic International at Atlantic 

International’s request, and Atlantic International provides financial services to SBE. Similarly, 

Atlantic International’s logo appears on SBE marketing materials provided to consumers in the 

United States. Atlantic International also presents to consumers directly during Sanctuary Belize 

tours, lending support and legitimacy to the sales process, while offering ongoing services to 

individuals it knows are and will be based in the United States. Atlantic International further 

assists SBE by providing Belizean banking facilities, both for the SBE itself and for the 

consumers targeted by SBE, all while knowing that its clients are and will be based in the United 

States. Furthermore, to provide its offshore banking services to Americans, such as SBE and 

SBE’s consumers, Atlantic International accepts wires from the SBE and American consumers 

through American correspondent banks, including, for at least a significant period, the Bank of 

New York Mellon. Currently and at times material to this Complaint, acting alone or in concert 

with others, Atlantic International has assisted and facilitated in the TSR violations this 

Complaint sets forth. Defendant Atlantic International, in connection with the matters alleged 

herein, transacts or has transacted business in this District and throughout the United States. At 

all times material to this Complaint, Atlantic International knew, or reasonably should have 

known, that its acts in furtherance of its unlawful coordination with SBE in violation of the TSR 

substantially affect the United States. 

20 
RELIEF DEFENDANTS 

33. Angela Chittenden is an individual who has received funds from the SBE 

Defendants’ deceptive and otherwise unlawful acts or practices alleged below to which she has 

no legitimate claim. Chittenden resides in Newport Beach, California. 

34. Beach Bunny Holdings, LLC (“Beach Bunny Holdings”) is an entity that has 

received funds from the SBE Defendants’ deceptive and otherwise unlawful acts or practices 

alleged below to which it has no legitimate claim. Beach Bunny Holdings is a California limited 

liability company with its principal place of business at 3333 Michelson. 

35. The Estate of John Pukke, also known as the Estate of Janis Pukke and the Estate 

of John Andris Pukke, is a New York entity that has received funds from the SBE Defendants’ 

deceptive and otherwise unlawful acts or practices alleged below to which it has no legitimate 

claim. This is the estate for Andris Pukke’s late father, who died in 2010. Andris Pukke is the 

co-executor of the estate and has signatory authority on Estate of John Pukke bank accounts 

receiving money from the SBE Defendants. 

36. John Vipulis is an individual who has received funds from the SBE Defendants’ 

deceptive and otherwise unlawful acts or practices alleged below to which he has no legitimate 

claim. After this Court civilly incarcerated Pukke in the AmeriDebt matter, Vipulis paid $4.5 

million to end Pukke’s civil incarceration. The order releasing Pukke prohibited Pukke from 

repaying this loan before fully satisfying his monetary debt to the FTC. Nonetheless, through 

payments from SBE to Vipulis, Pukke has repaid Vipulis more than $3 million before satisfying 

his monetary debt to the FTC. Vipulis resides in Las Vegas, Nevada. 

37. Deborah Connelly is an individual who has received funds from SBE Defendants’ 

deceptive and otherwise unlawful acts or practices alleged below to which she has no legitimate 

21 
claim. She is a Maryland attorney married to Defendant Frank Costanzo. Connelly resides in 

Los Angeles, California. 

COMMON ENTERPRISE 

38. The SBE Corporate Defendants have operated as a common enterprise while 

engaging in the deceptive acts and practices and other violations of law alleged below. The SBE 

Corporate Defendants have conducted the business practices described below through an 

interrelated network of companies that have common ownership, officers, managers, business 

functions, employees, and office locations, and with commingled funds. Because the SBE 

Corporate Defendants have operated as a common enterprise, each of them is jointly and 

severally liable for the acts and practices alleged below. The SBE Individual Defendants have 

formulated, directed, controlled, had the authority to control, or participated in the acts and 

practices of the SBE Corporate Defendants that constitute the common enterprise. 

ASSISTING & FACILITATING 

39. Defendant Atlantic International has assisted and facilitated the acts and practices 

alleged herein. Therefore, Atlantic International is jointly and severally liable for the acts and 

practices that violate the TSR. 

COMMERCE 

40. At all times material to this Complaint, Defendants have maintained a substantial 

course of trade in or affecting commerce, as “commerce” is defined in Section 4 of the FTC Act, 

14 U.S.C. § 44. 

22 
DEFENDANTS’ BUSINESS ACTIVITIES 

The Sanctuary Parcel and the AmeriDebt Litigation 

41. In 2003, the FTC sued Pukke and companies he controlled (AmeriDebt and 

Debtworks) under Section 5 of the FTC Act and the Gramm-Leach-Bliley Act. Specifically, the 

FTC alleged that Pukke lured financially-strapped consumers into expensive debt management 

plans (“DMPs”) meant to consolidate debt. The FTC alleged that AmeriDebt took consumers’ 

entire first payment as a “contribution” without their authorization (i.e., the entire first payment 

went to Pukke, and none to the consumer’s creditors). The FTC further alleged that Pukke took 

portions of subsequent payments as “contributions” without authorization. Pukke pleaded the 

Fifth Amendment rather than testify. The parties resolved the litigation through a stipulated 

2006 Final Order. 

42. The 2006 Final Order imposed monetary obligations on Pukke and appointed a 

Receiver to collect funds and assets from Pukke. Among other things, the 2006 Final Order 

required Pukke to turn over to the Receiver rights to an enormous parcel of land in Southern 

Belize (the “Sanctuary Parcel”). At that time, the Sanctuary Parcel covered more than 12,000 

acres (approximately nineteen square miles, or the size of a small city). SBE markets Sanctuary 

Belize, which includes the Sanctuary Parcel, as even larger—14,000 acres—(approximately 

twenty-two square miles, approximately the size of Manhattan). 

43. In 2007, on the Receiver’s motion, the Court found Pukke and his childhood 

friend, a co-defendant here, Baker, in contempt for refusing to turn over assets to the Receiver, 

including the Sanctuary Parcel. The Court ordered Pukke and Baker to comply, banned Pukke 

from leaving the United States, and threatened to incarcerate both if they failed to cooperate (the 

“Turnover Order”). 

23 
44. Specifically, the Turnover Order obligated Pukke and Baker “individually and 

collectively” to turn over Pukke’s interests in the Sanctuary Parcel, including whatever interests 

he had in 2005, “and/or that were acquired or arose thereafter . . . whether or not all or any 

portion of [the rights] have been transferred to and/or initially acquired by one or more persons 

or entities[.]” 

45. Both Pukke and Baker defied the Turnover Order. 

46. Following a contempt hearing, the Court characterized their conduct as 

“mendacious” and emphasized that both Pukke and Baker “lied on the record numerous times,” 

including some claims the Court found “ludicrous.” Accordingly, the Court ordered their 

coercive incarceration. 

47. The FTC and Receiver subsequently consented to Baker’s conditional release 

pursuant to an order requiring him to cooperate in collecting Pukke’s assets. The FTC and the 

Receiver later consented to Pukke’s conditional release pursuant to a similar Conditional Release 

Order and two payments totaling $4.5 million on Pukke’s behalf from relief defendant Vipulis. 

To secure Pukke’s release, Vipulis agreed to pay the Receiver $1.25 million for Latvian property 

and $3.25 million as a loan to Pukke. Notably, the Court’s Conditional Release Order required 

Vipulis “to subordinate repayment of [his] loan to satisfaction in full of the FTC judgment.” The 

Order also prohibited Pukke from “repay[ing] all or any portion of the Vipulis Loan” before 

satisfying the 2006 FTC judgment as “agreed to by the FTC” or found by the Court. 

48. In 2008, the Court approved the Receiver’s sale of the Sanctuary Parcel to SBE 

Corporate Defendant SRWR (BZ) for $2 million. The Receiver accepted only $2 million largely 

because SRWR (BZ) aggressively resisted the Receiver’s efforts to control the property 

notwithstanding the Turnover Order. 

24 
49. Significantly, five years earlier, Pukke helped create SRWR (BZ), although he 

purportedly ceded control to a Belizean shrimp farmer, SBE Individual Defendant Usher, prior to 

the 2008 sale. 

50. Unbeknownst to the FTC, the Receiver, and the Court, the sale was in fact the 

result of Baker having “surfaced [an] investor who agreed to invest $2 million,” which SRWR 

(BZ) used to purchase Pukke’s rights from the Receiver. SBE explained that, “[w]ith the 

settlement payment made [to the Receiver], Andris’ equity shares were conveyed to Peter Baker 

and the original core development investors.” 

51. As a result, Pukke maintained control over the Sanctuary Parcel through Baker 

despite the Receivership and the Turnover Order. 

The Current Deceptive Scheme: Using False Promises to Sell Sanctuary Belize Lots 

Phase One: Telemarketing 

52. SBE encourages consumers to contact it through commercials on Fox News and 

Bloomberg, infomercials, and other national advertising. 

53. These advertisements target American consumers on behalf of the Belizean 

entities Eco-Futures (BZ) and SRWR (BZ), the ultimate developer and vendor for the lot 

purchases. 

54. The national advertising drives consumers to websites, such as buybelize.com. 

The websites make few claims, instead encouraging consumers to submit their contact 

information to learn more. 

55. Typically, consumers who express interest then receive a call from Californiabased telemarketers. The telemarketers identify themselves as “property consultants” or 

“investment consultants.” 

25 
 

56. These calls, from United States-based telemarketers, are at least ostensibly on 

behalf of Belizean SBE entities Eco-Futures (BZ) and SRWR (BZ), who are listed as the 

developer and vendor on lot sale agreements. 

57. During these calls, the telemarketers screen anyone unable to make a substantial 

down payment. 

58. The telemarketers make various claims about the development including: 

a. SBE uses a “no debt” business model. The “no debt” model makes Sanctuary 

Belize a less risky investment than one in which the developer has to make 

payments to creditors. 

b. In part because of the “no debt” model, every dollar SBE collects from lot sales 

goes back into the development. 

c. This funding stream means SBE will finish the development quickly—within two 

to three years, or within five years. 

d. The finished development will feature numerous amenities including a hospital 

staffed with American physicians and nurses near the development, an emergency 

medical center near the downtown “Marina Village,” a championship-caliber golf 

course, an airstrip within the development, and a new international airport nearby 

with direct flights to and from the United States. The Marina Village, which is 

the heart of the community, will include high-end boutiques, restaurants, cafes, an 

American-style grocery store, an elegant casino, a hotel, and a 250-slip worldclass marina. 

e. These impressive amenities mean the lots will appreciate from 200% to 300% 

within two to three years. 

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f. Consumers can realize the rapid appreciation without difficulty because there is 

already a robust resale market, making it easy to resell the lots should they choose 

to do so. 

59. In addition to developing rapport, learning about the consumer, and making these 

six claims, typically, SBE encourages the consumer to participate in a longer webinar about the 

development. 

60. During the webinar, another telemarketer speaks to the consumer over the phone 

while showing photos and graphics regarding the development on the consumer’s computer. The 

telemarketer repeats the six claims above, makes additional claims, and answers questions. 

61. The telemarketer also sells the consumer on visiting Belize to tour the property. 

SBE offers an all-inclusive package, usually $999 per couple, that covers lodging at a nearby 

resort, local transportation, and meals. 

62. In numerous instances, SBE persuades consumers to sign a “non-binding lot 

reservation agreement.” Pursuant to this agreement, consumers pay $2,000 to $10,000 to obtain 

a right of first refusal on a particular lot. After they view the development, SBE will apply the 

payment to their purchase of the reserved lot, or another lot, or return it if they decide not to buy. 

63. Although most consumers place down payments on lots and then travel to 

Sanctuary Belize before purchasing, many consumers purchase lots without ever going to Belize 

to see the property or meeting with a sales person. 

64. The telemarketing also frequently includes marketing for Atlantic International’s 

banking services. Notably, Atlantic International visited SBE’s California offices and presented 

to SBE telemarketers regarding the services Atlantic International could provide consumers, 

including lower interest rates and relaxed underwriting for buyers wishing to finance Sanctuary 

27 
Belize home construction. Atlantic International urged the telemarketers to sell its banking 

services to American consumers as part of the Sanctuary Belize sales pitch. As Atlantic 

International’s CEO explained, the purpose of the marketing is to create ongoing banking 

relationships with consumers residing in the United States. 

Phase Two: Tour of the Development in Belize 

65. Most purchasers take part in a tour of Sanctuary Belize as part of the sales 

process. The tour is a multi-day trip to Belize during which consumers receive a steady stream 

of claims like those received during the initial telemarketing. 

66. Typically, consumers make their own arrangements to reach Belize City on a 

Thursday. From there, they fly to an airstrip in remote southern Belize, where SBE employees 

greet them. SBE then brings the consumers to a resort in Southern Belize, typically about twenty 

miles from Sanctuary Belize. 

67. On Friday and Saturday, consumers then tour Sanctuary Belize, visit lots, and 

attend sales presentations. The tour group sometimes includes SBE “plants,” purported 

consumers who are actually being paid by SBE to attend the tours, who express enthusiasm for 

the development. 

68. Although most consumers visit the lot they have reserved or are otherwise 

interested in purchasing, many do not visit their specific lot. These consumers are shown the 

development in general and perhaps shown a portion of part of the development where the lot 

they are interested in is located. 

69. SBE guides remove any consumers who ask skeptical questions. 

70. The sales presentations reiterate the representations made by the telemarketers, 

typically providing even more detail. For instance, some presentations provided additional 

28 
details on the promised hospital, including specific information about when it will open 

(typically within two years), what staff it will have (typically American doctors and nurses), and 

what procedures it will offer (usually advanced treatments ranging from organ transplants to 

chemotherapy). 

71. In numerous instances, Chadwick, Costanzo, and other SBE principals attend or 

present at these sales presentations. The sales presentations reiterate six core claims about 

Sanctuary Belize: (i) that SBE uses a “no debt” business model that reduces risk to consumers; 

(ii) that every dollar from lot sales goes back into the development; (iii) the funding stream 

means SBE will finish the development quickly—within two to three years, or within five years; 

(iv) the finished development will have specific amenities one would expect in an American 

luxury resort community; (v) the lots will appreciate from 200% to 300% within two to three 

years; and (vi) consumers can realize this appreciation through a robust resale market. 

72. Consumers often meet Usher when visiting Sanctuary Belize. 

73. Usher knows that these consumers reside in the United States and are touring 

Sanctuary Belize in response to U.S. telemarketing. Usher also knows that lot sales will create 

long-term financial relationships with American consumers who will make lot payments from 

the United States. 

74. In the early days of the scam, some consumers met Pukke, then using the alias 

“Marc Romeo.” Pukke used an alias because, as he has previously testified, he knew that at least 

some people were concerned that consumers would not buy lots from someone with two federal 

convictions related to consumer fraud. 

75. In fact, if consumers ask about Pukke, SBE, including other SBE principals like 

Chadwick and Costanzo, falsely assure them that Pukke is no longer involved with Sanctuary 

29 
Belize. If pressed, they sometimes assert that Pukke’s involvement is limited to marketing 

activities. 

76. In numerous instances, consumers attend presentations from Atlantic 

International, builders controlled by SBE insiders, and sometimes Coldwell Banker Belize. 

77. Atlantic International in fact created ongoing banking relationships with 

American consumers who reside in the United States as a result of the telemarketing and in 

person presentations. 

78. Atlantic International is frequently present during in-person sales presentations to 

consumers and, therefore, has heard over several years sales people promise consumers 

amenities and features that have not been completed within the promised time periods. 

Similarly, as a sophisticated lender, it should know that SBE’s claim that its “no debt” model 

reduces risks to consumers is false. 

79. Typically, on Saturday or Sunday, SBE takes consumers by boat to a small 

private island that is part of Sanctuary Belize. The ride takes approximately forty minutes, and 

the SBE boat is the only way to leave the island. SBE invites each couple to a private meeting. 

To get to the meeting, they wade offshore to a small thatch-roofed gazebo suspended over the 

water. Inside, consumers and SBE negotiate over the lots. 

80. The negotiations vary, but SBE seeks the maximum immediate cash down 

payment even to the detriment of other deal terms. Atlantic International representatives 

sometimes help facilitate cash payments, but only “developer financing” is available— 

consumers are strongly discouraged from involving traditional lenders. 

81. Consumers typically purchase the property outright, or make a down payment and 

then make additional payments over time to SBE directly. In most cases, SBE collects the 

30 
12.5% Belizean General Sales Tax (“GST”) on full purchases, down payments, and monthly 

payments. 

82. Additionally, consumers typically agree to make $100 monthly payments to the 

property owners’ association. SBE also collects 12.5% GST on homeowner’s association 

payments, meaning these payments are typically $112.50 per month per lot. 

83. The lots typically cost $150,000 to $500,000. The “Memorandum of Sale” for 

lots typically directs payments for the lot and Belizean taxes to Eco-Futures (BZ) at a California 

address, most recently at 3333 Michelson. 

84. Some consumers purchase multiple lots. In many instances, they do so because 

SBE claims that the lots’ value will so rapidly increase they will be able to sell one for a profit 

and use the proceeds to build a house on the other. 

85. Consumers report that nearly everybody who attends a tour purchases at least one 

lot. Typically, after SBE finishes the one-on-one meetings, it returns the consumers to the hotel 

where there is a celebration for the “new owners.” 

86. Throughout, the intrinsic characteristics of specific Sanctuary Belize lots do not 

substantially affect consumers’ decisions. SBE does not include information about soil 

composition, mineral rights, vegetation, or other features of the specific lots in the sales pitch. 

87. Internally, SBE discusses the idea of selling a “dream”—that is, the dream of 

becoming an owner in Sanctuary Belize in general. As a result, owners put substantial deposits 

on lots before visiting Sanctuary Belize, and many buy their lots during the tour without seeing 

the lot they are buying. 

31 
88. Internal SBE communications reveal instances in which SBE tour guides are told 

to “switch” a consumer from one lot to another during the tour, typically because SBE has taken 

two deposits on the same lot. 

89. SBE can switch consumers from lot to lot during the tour because the specific lot 

itself is not the primary motivation to buy; rather, consumers want the amenities and investment 

value that SBE promises. 

Phase Three: Continuing Payments 

90. After consumers return to the United States, they make any additional down 

payments or monthly payments. 

91. Typically, consumers make these payments to SBE entities at 3333 Michelson. 

For the property owners’ association payments, consumers typically send their checks to 3333 

Michelson or to a separate address maintained by the SBPOA in Texas. 

92. SBE continues to send marketing to consumers, referring to them as “new 

owners” and attempting to keep them happy so that they will keep making payments. 

Phase Four: Unwinding Transactions and Buybacks 

93. Although sales began thirteen years ago, in a development roughly the size of 

Manhattan, SBE has only completed portions of the electrical infrastructure, a two-pump gas 

station, a bodega or general store, a pool, an open-air restaurant and bar, and part of the promised 

marina. Approximately a dozen homes are complete, many occupied by persons associated with 

SBE. 

94. Many consumers become dissatisfied once they realize that SBE is not 

completing the development as promised and that their investments are not appreciating as SBE 

claimed. 

32 
95. Many of these consumers attempt to force SBE to buy back their lots or provide 

refunds. SBE initially tells consumers that they do not provide refunds or buy back lots. 

Nonetheless, some consumers convince SBE to repurchase the lots, but they typically receive 

less than they paid, and never receive the promised appreciation as part of the buy back 

agreement. 

96. The March 15, 2013 buy back agreement for Sapodilla Ridge Lot No. 156 is 

representative. The agreement recites that the lot was originally purchased on July 11, 2012 and 

that the purchaser had so far paid $56,414.60 towards the lot purchase, $50,276.60 to SBE and 

$6,138.00 collected by SBE for Belize’s General Sales Tax. The agreement then specifies that in 

return for giving up the lot, the buyer will receive $50,276.60 over six monthly payments. Thus, 

even if SBE made the promised payments, this consumer incurred a substantial loss. 

97. Some consumers attempt to resell their lots on the open market. These consumers 

discover there is no such market, that Coldwell Banker Southern Belize will not attempt in good 

faith to sell their lots, and that many local realtors will not list or show Sanctuary Belize lots. If 

they do, SBE limits their access to the development to one day a week, and removes the “for 

sale” sign, or otherwise obstructs the resale. 

98. Some consumers simply stop making payments. In these cases, SBE threatens 

and then proceeds with “foreclosure,” although the process it calls “foreclosure” consists solely 

of notices or letters from SBE or its Belizean counsel. After a period of time from sending the 

letter, which varies from owner to owner, SBE treats the owner’s rights to the lot as extinguished 

and resells the lot to a new consumer. SBE does not tell new consumers about the lot’s history, 

or that another consumer may have rights to the lot. 

33 
99. Consumers believe they own the lots, and SBE tells them—repeatedly—that they 

do. However, during the so-called “foreclosure” process, SBE no longer treats them as owners. 

SBE does not refund or credit consumers the amount they have paid (i.e., return the consumers’ 

payments and cancel the contract), nor does it credit consumers for the lots’ value (i.e., pay the 

consumers the difference between the lot’s value upon resale and the amounts the consumer 

owes SBE). Instead, SBE simply keeps the consumer’s money and resells the lot to a new 

victim. 

SBE’s Sales Claims Are False 

100. Although SBE claims its “no debt” model reduces risk for consumers, the 

opposite is true. Reasonable debt would have significant risk-reducing features that benefit 

consumers, including that: (i) creditors provide consistent cashflow to complete the 

development; (ii) creditors perform underwriting to ensure the developer is trustworthy and 

capable, and that the project is feasible; and (iii) creditors monitor the developer’s progress to 

ensure the development is completed. The absence of these features actually increases the risk to 

consumers. 

101. SBE’s claim that “every dollar” from the lot sales goes into Sanctuary Belize is 

false because significant funds are used for personal expenses or otherwise funneled to people, 

companies, and projects unrelated to Sanctuary Belize. 

102. SBE’s claim that it will finish the development within two, three, or five years is 

also false. SBE has made this claim for at least 12 years and the development is still largely 

unfinished. Furthermore, SBE will not be able to generate the income necessary to complete the 

project within the next five years. 

103. As a result, the development also will not contain the promised amenities. 

34 
104. Additionally, the Sanctuary Belize lots are not experiencing the promised “rapid 

appreciation,” nor will they. This is apparent from the fact that many consumers cannot sell their 

lots for any price or convince SBE to repurchase them other than at a loss. 

105. Similarly, the promised resale market does not exist. Consumers cannot resell 

their lots at all, let alone for amounts in excess of what they paid. 

106. Contrary to SBE’s sales representations, Pukke in fact is significantly involved 

with Sanctuary Belize. He is, and always has been, SBE’s primary control person. 

VIOLATIONS OF THE FTC ACT 

107. Section 5(a) of the FTC Act, 15 U.S.C. § 45(a), prohibits “unfair or deceptive acts 

or practices in or affecting commerce.” 

108. Misrepresentations or deceptive omissions of material fact constitute deceptive 

acts or practices prohibited by Section 5(a) of the FTC Act. 

Count I – Deception 

(SBE Defendants) 

109. In numerous instances in connection with the advertising, marketing, promotion, 

offering for sale, or sale of real estate investments and related services, SBE Defendants have 

represented, directly or indirectly, expressly or by implication that: 

a. the SBE Defendants use a “no debt” business model to develop Sanctuary 

Belize, which makes lots in Sanctuary Belize a less risky investment than 

one in which the developer makes payments to creditors; 

b. every dollar the SBE Defendants collect from Sanctuary Belize lot sales 

goes back into the development; 

c. the SBE Defendants will finish Sanctuary Belize quickly, including within 

two to three years, or within five years; 

35 
d. the finished Sanctuary Belize will have all of the amenities expected of an 

American luxury resort community, such as: (i) a hospital staffed with 

American physicians and nurses near the development; (ii) an emergency 

medical center near the downtown “Marina Village;” (iii) a championshipcaliber golf course; (iv) a local airport within the development; (v) a new 

international airport nearby with direct flights to and from the United 

States; (vi) a “Marina Village” containing high-end boutiques, restaurants, 

cafes, an American-style grocery store, an elegant casino, and a hotel; and 

(vii) a 250-slip world-class marina; 

e. Sanctuary Belize lots will appreciate rapidly, such as 200% to 300% 

within two to three years; 

f. consumers can realize the rapid appreciation of their lots within Sanctuary 

Belize because there is a robust resale market through which consumers 

could easily resell their lots should they choose to do so; and 

g. Andris Pukke has had no meaningful involvement with the SBE 

Defendants. 

110. In truth and in fact, in numerous instances in which the SBE Defendants have 

made the representations set forth in Paragraph 109 of this Complaint: 

a. the SBE Defendants’ use of a “no debt” model, if true, would make 

consumers’ investments more risky; 

b. the SBE Defendants do not put every dollar collected on Sanctuary Belize 

lot sales back into Sanctuary Belize; 

36 
c. the SBE Defendants have not yet completed Sanctuary Belize and will not 

complete Sanctuary Belize within the next five years; 

d. Sanctuary Belize does not contain, and will not contain within the next 

five years, all of the amenities expected of an American luxury resort 

community, such as: (i) a hospital staffed with American physicians and 

nurses near the development; (ii) an emergency medical center near the 

downtown “Marina Village;” (iii) a championship-caliber golf course; (iv) 

a local airport within the development; (v) a new international airport 

nearby with direct flights to and from the United States; (vi) a “Marina 

Village” containing high-end boutiques, restaurants, cafes, an Americanstyle grocery store, an elegant casino, and a hotel; and (vii) a 250-slip 

world-class marina; 

e. Sanctuary Belize lots are not rapidly appreciating, including not 

appreciating by 200% to 300% over the course of two or three years; 

f. consumers cannot realize any appreciation of their lots within Sanctuary 

Belize because there is not a robust resale market; 

g. Andris Pukke has, and continues to have, a meaningful role with the SBE 

Defendants. 

111. Therefore, the SBE Defendants’ representations as set forth in Paragraph 109 of 

this Complaint are false or misleading and constitute deceptive acts or practices in violation of 

Section 5(a) of the FTC Act, 15 U.S.C. § 45(a). 

37 
VIOLATIONS OF THE TSR 

112. Congress directed the FTC to prescribe rules prohibiting abusive and deceptive 

telemarketing acts or practices pursuant to the Telemarketing Act, 15 U.S.C. §§ 6101-6108, in 

1994. The FTC adopted the original Telemarketing Sales Rule (“TSR”) in 1995, extensively 

amended it in 2003, and amended certain sections thereafter. 16 C.F.R. Part 310. 

113. The SBE Defendants are “seller[s]” or “telemarketer[s]” engaged in 

“telemarketing” as defined by the TSR, 16 C.F.R. § 310.2(dd), (ff), and (gg). 

114. Atlantic International is a “person” within the meaning of the TSR, which defines 

“person” to mean “any individual, group, unincorporated association, limited or general 

partnership, corporation, or other business entity.” 16 C.F.R. § 310.2(y). 

115. The SBE Defendants are offering, offering for sale, or selling an “investment 

opportunity” within the meaning of the TSR when offering, offering for sale, or selling the 

Sanctuary Belize lots. The TSR defines “investment opportunity” to mean “anything tangible or 

intangible, that is offered, offered for sale, sold, or traded based wholly or in part on 

representations, either express or implied, about past, present, or future income, profit, or 

appreciation.” 16 C.F.R. § 310.2(s). 

116. The TSR prohibits sellers and telemarketers from misrepresenting directly or by 

implication, in the sale of goods or services, any of the following material information: 

a. Any material aspect of the performance, efficacy, nature, or central 

characteristics of goods or services that are the subject of a sales offer. 16 

C.F.R. § 310.3(a)(2)(iii). 

38 
b. Any material aspect of an investment opportunity including, but not 

limited to, risk, liquidity, earnings potential, or profitability. 16 C.F.R. § 

310.3(a)(2)(vi). 

117. The TSR prohibits any person from providing substantial assistance or support to 

any seller or telemarketer when that person knows or consciously avoids knowing that the seller 

or telemarketer is engaged in any act or practice that violates 16 C.F.R. §§ 310.3(a), 310.3(c), 

310.3(d), or 310.4. Id. § 310.3(b). 

118. Pursuant to Section 3(c) of the Telemarketing Act, 15 U.S.C. § 6102(c), and 

Section 18(d)(3) of the FTC Act, 15 U.S.C. § 57a(d)(3), a violation of the TSR constitutes an 

unfair or deceptive act or practice in or affecting commerce, in violation of Section 5(a) of the 

FTC Act, 15 U.S.C. § 45(a). 

Count II – TSR Misrepresentations 

(SBE Defendants) 

119. In numerous instances, in connection with the telemarketing of its goods and 

services, the SBE Defendants have misrepresented, directly or indirectly, expressly or by 

implication, material aspects of the performance, efficacy, nature, or central characteristics of 

such goods and services, including, but not limited to: 

a. the SBE Defendants use a “no debt” business model to develop Sanctuary 

Belize, which makes lots in Sanctuary Belize a less risky investment than 

one in which the developer makes payments to creditors; 

b. every dollar the SBE Defendants collect from Sanctuary Belize lot sales 

goes back into the development; 

c. the SBE Defendants will finish Sanctuary Belize quickly, including within 

two to three years, or within five years; 

39 
d. the finished Sanctuary Belize will have all of the amenities expected of an 

American luxury resort community, such as: (i) a hospital staffed with 

American physicians and nurses near the development; (ii) an emergency 

medical center near the downtown “Marina Village;” (iii) a championshipcaliber golf course; (iv) a local airport within the development; (v) a new 

international airport nearby with direct flights to and from the United 

States; (vi) a “Marina Village” containing high-end boutiques, restaurants, 

cafes, an American-style grocery store, an elegant casino, and a hotel; and 

(vii) a 250-slip world-class marina; 

e. Sanctuary Belize lots will appreciate rapidly, such as 200% to 300% 

within two to three years; 

f. consumers can realize the rapid appreciation of their lots within Sanctuary 

Belize because there is a robust resale market through which consumers 

could easily resell their lots should they choose to do so; and 

g. Andris Pukke has had no meaningful involvement with the SBE 

Defendants. 

120. In truth and in fact, in numerous instances in which the SBE Defendants have 

made the representations set forth in Paragraph 119 of this Complaint: 

a. the SBE Defendants’ use of a “no debt” model, if true, would make 

consumers’ investments more risky; 

b. the SBE Defendants do not put every dollar collected on Sanctuary Belize 

lot sales back into Sanctuary Belize; 

40 
c. the SBE Defendants have not yet completed Sanctuary Belize and will not 

complete Sanctuary Belize within the next five years; 

d. Sanctuary Belize does not contain, and will not contain within the next 

five years, all of the amenities expected of an American luxury resort 

community, such as: (i) a hospital staffed with American physicians and 

nurses near the development; (ii) an emergency medical center near the 

downtown “Marina Village;” (iii) a championship-caliber golf course; (iv) 

a local airport within the development; (v) a new international airport 

nearby with direct flights to and from the United States; (vi) a “Marina 

Village” containing high-end boutiques, restaurants, cafes, an Americanstyle grocery store, an elegant casino, and a hotel; and (vii) a 250-slip 

world-class marina; 

e. Sanctuary Belize lots are not rapidly appreciating, including not 

appreciating by 200% to 300% over the course of two or three years; 

f. consumers cannot realize any appreciation of their lots within Sanctuary 

Belize because there is not a robust resale market; 

g. Andris Pukke has, and continues to have, a meaningful role with the SBE 

Defendants. 

121. Therefore, the SBE Defendants’ acts or practices, as described in Paragraphs 119 

and 120, violate the TSR, 16 C.F.R. § 310.3(a)(2)(iii). 

Count III – Investment Opportunities 

(SBE Defendants) 

122. In numerous instances, in connection with the telemarketing of investment 

opportunities, the SBE Defendants have misrepresented, directly or indirectly, expressly or by 

41 
implication, the risk, liquidity, earnings potential, profitability, or any other material aspect of the 

investment opportunities, including, but not limited to: 

a. the SBE Defendants use a “no debt” business model to develop Sanctuary 

Belize, which makes lots in Sanctuary Belize a less risky investment than 

one in which the developer makes payments to creditors; 

b. every dollar the SBE Defendants collect from Sanctuary Belize lot sales 

goes back into the development; 

c. the SBE Defendants will finish Sanctuary Belize quickly, including within 

two to three years, or within five years; 

d. the finished Sanctuary Belize will have all of the amenities expected of an 

American luxury resort community, such as: (i) a hospital staffed with 

American physicians and nurses near the development; (ii) an emergency 

medical center near the downtown “Marina Village;” (iii) a championshipcaliber golf course; (iv) a local airport within the development; (v) a new 

international airport nearby with direct flights to and from the United 

States; (vi) a “Marina Village” containing high-end boutiques, restaurants, 

cafes, an American-style grocery store, an elegant casino, and a hotel; and 

(vii) a 250-slip world-class marina; 

e. Sanctuary Belize lots will appreciate rapidly, such as 200% to 300% 

within two to three years; 

f. consumers can realize the rapid appreciation of their lots within Sanctuary 

Belize because there is a robust resale market through which consumers 

could easily resell their lots should they choose to do so; and 

42 
g. Andris Pukke has had no meaningful involvement with the SBE 

Defendants. 

123. In truth and in fact, in numerous instances in which the SBE Defendants have 

made the representations set forth in Paragraph 122 of this Complaint: 

a. the SBE Defendants’ use of a “no debt” model, if true, would make 

consumers’ investments more risky; 

b. the SBE Defendants do not put every dollar collected on Sanctuary Belize 

lot sales back into Sanctuary Belize; 

c. the SBE Defendants have not yet completed Sanctuary Belize and will not 

complete Sanctuary Belize within the next five years; 

d. Sanctuary Belize does not contain, and will not contain within the next 

five years, all of the amenities expected of an American luxury resort 

community, such as: (i) a hospital staffed with American physicians and 

nurses near the development; (ii) an emergency medical center near the 

downtown “Marina Village;” (iii) a championship-caliber golf course; (iv) 

a local airport within the development; (v) a new international airport 

nearby with direct flights to and from the United States; (vi) a “Marina 

Village” containing high-end boutiques, restaurants, cafes, an Americanstyle grocery store, an elegant casino, and a hotel; and (vii) a 250-slip 

world-class marina; 

e. Sanctuary Belize lots are not rapidly appreciating, including not 

appreciating by 200% to 300% over the course of two or three years; 

43 
f. consumers cannot realize any appreciation of their lots within Sanctuary 

Belize because there is not a robust resale market; 

g. Andris Pukke has, and continues to have, a meaningful role with the SBE 

Defendants. 

124. Therefore, the SBE Defendants’ acts or practices, as described in Paragraphs 122 

and 123, violate the TSR, 16 C.F.R. § 310.3(a)(2)(vi). 

Count IV – Assisting and Facilitating 

(Atlantic International) 

125. In numerous instances in connection with the SBE Defendants’ violations of the 

TSR as set forth in Counts II and III above, Atlantic International provided substantial assistance 

or support to the SBE Defendants, who are sellers and telemarketers. 

126. Atlantic International knew or consciously avoided knowing that the SBE 

Defendants were engaged in acts or practices that violated the TSR as set forth in Counts II and 

III above. 

127. Atlantic International’s acts and practices, as described in Paragraphs 125 and 126 

of this Complaint, are deceptive telemarketing acts or practices that violate Section 310.3(b) of 

the TSR. 

Count V – Relief Defendants 

(Chittenden, Beach Bunny Holdings, The Estate of John Pukke, Vipulis, and Deborah 

Connelly) 

128. Relief Defendants Chittenden, Beach Bunny Holdings, The Estate of John Pukke, 

Vipulis, and Deborah Connelly have received, directly or indirectly, funds and other assets 

obtained from SBE Defendants’ customers through the deceptive and otherwise unlawful acts or 

practices described herein. 

44 
129. Relief Defendants Chittenden, Beach Bunny Holdings, The Estate of John Pukke, 

Vipulis, and Deborah Connelly are not bona fide purchasers with legal and equitable title to 

SBE Defendants’ customers’ funds or other assets, and will be unjustly enriched if they are not 

required to return the funds or the value of the benefits they received as a result of Defendants’ 

deceptive and otherwise unlawful acts or practices. 

130. By reason of the foregoing, Relief Defendants Chittenden, Beach Bunny 

Holdings, The Estate of John Pukke, Vipulis, and Deborah Connelly hold funds and assets in 

constructive trust for the benefit of the SBE Defendants’ customers. 

CONSUMER INJURY 

131. Consumers have suffered and will continue to suffer substantial injury as a result 

of Defendants’ violations of the FTC Act and TSR. In addition, Defendants have been unjustly 

enriched as a result of their unlawful acts or practices. Absent injunctive relief by this Court, 

Defendants are likely to continue to injure consumers, reap unjust enrichment, and harm the 

public interest. 

THIS COURT’S POWER TO GRANT RELIEF 

132. Section 13(b) of the FTC Act, 15 U.S.C. § 53(b), empowers this Court to grant 

injunctive and such other relief as the Court may deem appropriate to halt and redress violations 

of any provision of law enforced by the FTC. The Court, in the exercise of its equitable 

jurisdiction, may award ancillary relief, including rescission or reformation of contracts, 

restitution, the refund of monies paid, and the disgorgement of ill-gotten monies, to prevent and 

remedy any violation of any provision of law enforced by the FTC. 

45 
 

PRAYER FOR RELIEF 

Wherefore, Plaintiff FTC, pursuant to Section 13(b) of the FTC Act, 15 U.S.C. § 53(b), 

Section 6(b) of the Telemarketing Act, 15 U.S.C. § 6105(b), and the Court’s own equitable 

powers, requests that the Court: 

A. Award Plaintiff such preliminary injunctive and ancillary relief as may be 

necessary to avert the likelihood of consumer injury during the pendency of this action and to 

preserve the possibility of effective final relief, including but not limited to, temporary and 

preliminary injunctions, an order freezing assets, immediate access, appointment of a receiver, 

and an accounting; 

B. Enter a permanent injunction to prevent future violations of the FTC Act and TSR 

by Defendants; 

C. Award such relief as the Court finds necessary to redress injury to consumers 

resulting from Defendants’ violations of the FTC Act and TSR, including, but not limited to, 

rescission or reformation of contracts, restitution, the refund of monies paid, and the 

disgorgement of ill-gotten monies; 

D. Enter an order requiring the Relief Defendants to disgorge all funds and assets, or 

the value of the benefits they received from the funds and assets, which are traceable to 

Defendants’ deceptive and otherwise unlawful acts or practices; and 

E. Award Plaintiff the costs of bringing this action, as well as such other and 

additional relief as the Court may determine to be just and proper. 

46 
Dated: /a /3, II>< , 7 

Respectfully submitted, 

Alden F. Abbott 

N COHEN, D. Md. Bar No. 16776 

en2@ftc.gov 

BENJAMIN J. THEISMAN, pro hac vice 

btheisman@ftc.gov 

AMANDA B. KOSTNER, pro hac vice 

akostner@ftc.gov 

KHOURYANNA D1PRIMA,pro hac vice 

kdi prima@ftc.gov 

600 Pennsylvania Ave. NW, CC 9528 

Washington, DC 20580 

Phone: (202) 326-2551 (Cohen), -2223 (Theisman), 

-2029 (DiPrima) 

Facsimile: (202) 326-3197 

ATTORNEYS FOR PLAINTIFF 

FEDERAL TRADE COMMISSION 

47