Case 2:14-cv-03173-EL Document 3 Filed 06/06/14 Page 1 of 21

UNITED STATES DISTRICT COURT 

EASTERN DISTRICT OF PENNSYLVANIA 

UNITED STATES OF AMERICA, 

Plaintiff, 

v. 

HERITAGE HOMES GROUP, INC., 

a corporation; 

HERITAGE BUILDING GROUP, INC., 

a corporation; 

HERITAGE HIGI):GATE, INC., 

a corporation; 

HERITAGE PARTNERS, INC., 

a corporation; and 

CJL REALTY MANAGEMENT, LLC, 

a limited liability company. 

Defendants. 

FILED 

JUN -6 2014 

r;cHAEL E. KUNZ, Clerk - Jep. Clerk 

STIPULATED ORDER FOR 

PERMANENT INJUNCTION AND CIVIL PENALTY JUDGMENT 

Plaintiff, the United States of America, acting upon notification and authorization· to the · 

Attorney General by the Federal Trade Commission ("Commission"), filed its Complaint seeking 

a permanent injunction, civil penalties, and other equitable relief in this matter, pursuant to 

Sections 13(b) and 16(a)(l) of the Federal Trade Commission Act ("FTC Act"), 15 U.S.C. 

§§ 53(b) and 56(a)(l). Defendants have been served with the Summons and the Complaint. 

Plaintiff and Defendants stipulate to the entry of this Stipulated Order For Permanent Injunction 

And Civil Penalty Judgment ("Order") to resolve all matters in dispute in this action between 

them. 

THEREFORE, IT IS ORDERED as follows: 
Case 2:14-cv-03173-EL Document 3 Filed 06/06/14 Page 2 of 21

FINDINGS 

1. This Court has jurisdiction over this matter. 

2. The Complaint charges that Defendants disseminated deceptive commercial 

communications regarding mortgage credit products in violation of Section 5 of the FTC Act, 15 

U.S.C. § 45, the Mortgage Acts and Practices~ Advertising Rule ("MAP Rule"), 16 C.P.R. Part 

321, and the Mortgage Acts and Practices Advertising Rule (Regulation N) ("Regulation N"), 12 

C.F .R. Part 1 014. The Complaii1t further alleges that Defendants failed to include required 

disclosures and meet other requirements in its advertisements for mortgage loans,in violation of 

the Truth in Lending Act ("TILA") 15 U.S.C. 1601~1666j and its implementing Regulation Z, 12 

C.P.R. Part 1026. 

3. 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, Defendants admit the facts 

necessary to establish jurisdiction. 

4. . Defendants waive any claim that they may have under the Equal Access to Justice 

Act, 28 U.S.C. § 2412, concerning the prosecution of this action through the date of this Order, 

and agree to bear their own costs and attorney fees. 

5. Defendants and Plaintiff waive all rights to appeal or otherwise challenge or 

contest the validity of this Order. 

DEFINITIONS 

For purposes of this Order, the following definitions shall apply: 

1. "Commercial communication" means any written or oral statement, illustration, 

or depiction that is designed to effect a sale or create interest in purchasing goods or services, 

whether it appears .on or in a label, package, package insert, radio, television, cable television, 

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brochure, newspaper, magazine, pamphlet, leaflet, circular, mailer, book insert, free standing 

insert, letter, catalogue, poster, chart, billboard, public transit card, point of purchase display, 

film, slide, audio program transmitted over a telephone system, telemarketing script, on-hold 

script, upsell script, training materials provided to telemarketing firms, program-length 

commercial ("infomercial"), the intemet, cellular network, or any other medium. · 

2. "Commission" means the Federal Trade Commission. 

3. "Closed-end credit" means consumer credit other than open-end credit. 

4. "Credit" means the right to defer payment of debt or to incur debt and defer its 

payment. 

5. "Defendants" means Heritage Homes Group, Inc., Heritage Building Group, 

Inc., Heritage Highgate, Inc., Heritage Partners, Inc., and CJL Realty Management, LLC 

("Defendants" or "the Heritage Entities"), and their successors and assigns. 

6. "Defendant Heritage 

and its successors and assigns. 

7. "Defendant Heritage Building Group, Inc." means Heritage Building Group, 

Inc., and its successors and assigns. 

8. "Defend~nt Heritage Highgate, Inc." means Heritage Highgate, Inc. and its 

successors and assigns. 

9. "DefendantHeritage Partners, Inc." means Heritage Partners, Inc. and its 

successors and assigns. 

10.. "Defendant CJL Realty Management, LLC" means CJL Realty Management, 

LLC and its successors and assigns. 

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11. . "Mortgage credit product" means any form of credit that is secured by real 

property or a dwelling and that is offered or extended to a consumer primarily for personal, 

family, or household purposes. 

12. "Open~end credit" means consumer credit extended by a creditor under a plan in 

which: (i) the creditor reasonably contemplates repeated transactions; (ii) the creditor may 

impose a finance charge from time to time on an outstanding unpaid balance; and (iii) the 

amount ef credit that may be extended to the consumer during the term of the plan (up to any 

limit set by the creditor) is generally made available to the extent that any outstanding balance is 

repaid. 

13. "Person" means any natural person, organization, or other legal entity, including 

a corporation, partnership, proprietorship, association, or cooperative, limited or general ' ' 

partnership, corporation, or 'other business entity. 

ORDER 

I. MORTGAGE ACTS AND PRACTICES~ ADVERTISING 

IT IS HEREBY ORDERED that Defendants and Defendants' officers, agents, servants, 

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

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

with the advertising, marketing, promotion, offering for sale, or sale of any mortgage credit 

product, are hereby permanently restrained and enjoined from: 

A. Misrepresenting, expressly or by implication, any term of any mortgage credit 

product, including but not limited to: 

1. The interest charged for the mm1gage credit product, including but not 

limited to misrepresentations concerning: 

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(a) The amount of interest that the consumer owes each month that is 

included in the consumer's payments, loan amount, or total 

amount due, or 

(b) Whether the difference between the interest owed and the interest 

paid is added to the total amount due from the consumer; 

2. The annual percentage rate, simple annual rate, periodic rate, or any other 

rate; 

3. · The existencel nature, or amount of fees or costs to the consumer 

associated with the mortgage credit product, including but not limited to 

misrepresentations that no fees are charged; 

4. The existence, cost, payment terms, or other terms associated with any 

additional product or feature that is or may be sold in conjunction with the 

-------------- ----------:::::::-==-=::::-:::--.-== 

credit disability insurance; 

5. The terms, amounts, payments, or other requirements relating to taxes· or 

insurance associated with the mortgage credit product, including but not 

limited to misrepresentations about: 

(a) Whether separate payment of taxes or insurance is required; and 

(b) The extent to which payment for taxes or insurance is included in 

the loan payments, loan amount, or total amount due from the 

consumer; 

6. Any prepayment penalty associated with the mortgage credit product, 

including but not limited to misrepresentations concerning the existence, 

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nature, amount) or terms of such penalty; 

7. The variability of interest, payments, or other terms of the mortgage credit 

product, including but not limited misrepresentations using the word 

~'fixed"; 

8. Any comparison-between: 

(a) Any rate or payment that will be available for a period less than the 

full length of the mortgage credit product; and 

b) · Any actual or hypothetical rate or payment; 

9. The type of mortgage credit product, including but not limited to 

misrepresentations that the product is or involves a fully amortizing 

mortgage; 

10. The amount of the obligation, or the existence, nature, or amount of cash 

or credit available tb.im-e~sume-FirFcoimection with the mortgage credit 

product, including but not limited to misrepresentations that the consumer 

will receive a certain amount of cash or credit as part of a mortgage credit 

transaction; 

11. The existence, number, amount, or timing of any minimum or required 

payments, including but not limited to misrepresentations about any 

payments or that no payments are required in a reverse mortgage or other 

mortgage credit product; 

12. The potential for default under the mmigage credit product, including but 

not limited to misrepresentations concerning the circumstances under 

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which the consumer could default for nonpayment of taxes, insurance, or 

maintenance, or for failure to meet other obligations; 

13. The effectiveness of the mortgage credit product in helping the consumer 

resolve difficulties in paying debts, including but not lin~ited to 

misrepresentations that any mortgage credit product can reduce, eliminate, 

or restructure debt or result in a waiver or forgiveness, in whole or in part, 

of the consumer1s existing obligation with any person; 

14. l11e association of the mortgage credit product or any provider of such 

product with any other person or progran1, including but not limited to 

misrepresentations that: 

(a) The provider or the Defendant is, or is affiliated with, any 

govemmental entity or other organization; or 

(b) benefit, or is endorsed, 

sponsored by, or affiliated with any government or other program, 

including but not limited to through the use offonnats, symbols, or 

logos that resemble those of such entity, organization, or program; 

15. The source of any commercial communication, including but not limited 

to misrepresentations that a commercial communication is made by or on 

behalf of the consumer's current mortgage lender or servicer; 

16. The right of the consumer to reside in th~ dwelling that is the subject of 

the mortgage credit product, or the duration of such right, including but 

not limited to misrepresentations conceming how long or under what 

conditions a consmner with a reverse mortgage can stay in the dwelling; 

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17. The consumer's ability or likelihood to obtain any mortgage credit product 

or term, including but not limited to misrepresentations concerning 

whether the consumer has been preapproved or guaranteed for any such 

product or term; 

18. The consumer's ability or likelihood to. obtain a refinancing or 

modification of any mmigage credit product or term, including but not 

limited to misrepi·esentations concerning whether the consumer has been 

preapproved or guaranteed for any such refinancing or modification; 

19. The availability, nature, or substance of counseling services or any other 

expert advice offered to the consumer regarding any mortgage credit 

product or term, including but not limited to the qualifications of those 

offering the services or advice; and 

20. That any the product, service, plan, ..o.r ... program; 

B. Failing to maintain, for a period of twenty-four months from the last date a person 

made or disseminated the applicable commercial communication regarding any 

term of any mortgage credit product, the following evidence of compliance: 

1. Copies of all materially different commercial communications 

as well as sales scripts, training materials, and marketing materials, 

regarding any term of any mortgage credit product, that the person made 

or disseminated during the relevant time period; 

2. Docwnents describing or evidencing all mortgage credit products 

available to consumers during the time period in which the person made or 

disseminated each commercial communication regarding any terms of any 

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mortgage credit product available to consumers; and · 

3. Documents describing or evidencing all additional products or services 

(such as credit insurance or' credit disability insurance) that are or may be 

offered or provided with the mortgage credit products available to 

consumers during the time period in which the person made or 

. disseminated each commercial communication regarding any tenn of any 

mortgage credit product, including but not limited to the names and terms 

of each such additional product or service available to consumers; 

C. Misrepresenting, expressly or by implication any material fac~ concerning any 

mortgage credit product; and 

. D. Violating the Mortgage Acts and Practices Advertising Rule (Regulation N), 12 

C.F.R. Part 1014. 

II. PROHIBITED 

THE SALE OF HOMES AND RELATED PRODUCTS AND SERVICES 

IT IS FURTHER ORDERED that Defendants and Defendants' officers, agents, 

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

·any of them, who receive actual notice of this Order, whether acting directly or indirectly, are 

hereby permanently restrained and enjoined from misrepresenting, or assisting others in 

misrepresenting, expressly or by implication, any fact material to consumers conceq1ing the sale 

of homes and related products and services, such as: the total costs; any material restrictions, 

limitations, or conditions; or any material aspect of the performance, efficacy, nature, or central 

characteristics, including but not limited to the following: 

A. That consumers will pay $0 money down to purchase a home or for a mortgage 

loan; 

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B. TI1at consumers will reccilv~ 100% financing to purchase a home or through a 

mortgage loan; and 

C. That consumers will pay no closing costs to purchase a home or for a mortgage 

loan. 

III. INJUNCTION AGAINST FAILURE TO DISCLOSE MATEIUAL TERMS 

IT IS HEREBY ORDERED that Defendants and Defendants' officers, agents, servants, 

employees, and attorneys, and all other persons in active conce11 or participation with any of 

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

with the advertising, marketing, promotion, offering for sale, or sale of any mortgage credit 

product are permanently restrained and enjoined from representing a periodic payment amount, 

including a monthly payment amount such as for $1,198 per month, and failing to disclose, 

clearly, prormnently, and cOJlltemr:1onmeoi~ii~~~~-

A that the loan requires and financing through the United States 

Department of Agriculture's Rural Development Loan Program or other financing 

program, as applicable, in which credit and income limits apply, if true; . 

B. that a good faith deposit is required at contract signing, and the amount or 

percentage ofthat deposit, if true; 

C. that a guaranty fee and annual fee are required, and the amount or percentage of 

those fees, and that other fees are required, for the financing and are to be paid at 

settlement or during the loan, as applicable and if true; and 

D. the annual percentage rate ("APR") for the advertised fmancing. 

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IV. THE TRUTH IN LENDING ACT AND REGULATION Z 

IT IS FURTHER ORDERED that Defendants and Defendants' officers, agents, 

servants, employees, and attorneys, and all othei· persons in active concert or participation with 

any of them, who receive actual notice ofthis Order, whether acting directly or indirectly, in 

connection with advertising closed~end credit are hereby permanently restrained and enjoined 

from: 

A. Advertising credit terms other than those terms that actually are or will be 

an-anged or offered by the creditor; 

B. Advertising a payment amount, without disclosing or clearly and conspicuously 

disclosing: 

1. The terms of repayment, which reflect the repayment obligations over the 

full tenn of the loan, including any balloon payment; 

2. 

and, if the annual percentage rate may be increased after consummation, 

that fact; and 

C. Violating the Truth in Lending Act, 15 U.S.C. § 1601~1666j and Regulation Z, 

12 C.P.R. Part 1026. 

V. MONETARY JUDGMENT FOR CIVIL PENALTY AND 

SUSPENSION 

IT IS FURTHER ORDERED that: 

A. Judgment in the amount of Six Hundred and Fifty Thousand Dollars 

($650,000.00) is entered in favor of the Plaintiff against Defendants Heritage 

Homes Group, Inc., Heritage Building Group, Inc. and Heritage Partners, Inc., 

jointly and severally, as a civil penalty. 

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B. The monetary judgment is suspended, subject to the Subsections below. 

C. The Plaintiff's agreement to the suspension of the judgment is expressly premised 

upon the truthfulness, accuracy, and completeness of Defendants' sworn financial 

statements and related docuiUents (collectively, "financial attestations") submitted 

to the CoiUmission, namely: 

1. The Financial Statement of Defendant Heritage Homes Group, Inc., signed 

by Richard R. Carroll, Jr., Vice-President, including the attaclunents, 

.submitted by Defendant's counsel Walter Weir, Jr., to Commission 

counsel Carole Reynolds on NoveiUber 19, 2013; 

2. The Fhiancial Statement of Defendant Heritage Building Group, Inc., 

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signed by Richard R. Carroll, Jr., President, including the attaclunents, 

submitted by Defendants' counsel Walter Weir, Jr., to Commission 

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I 3. The Financial Statement of Defendant Heritage Highgate, Inc., signed by 

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Richard R. Carroll, Jr., Preside11t on November 19, 2013, including the 

attachments; 

4. The Financial Statement of Defendant Heritage Partners, Inc., signed by 

Richard R. Carroll, Jr., President, including the attaclunents, submitted by 

Defendants' counsel Walter Weir, Jr., to Commission counsel Carole 

Reynolds on November 19, 2013; 

5. The Financial Statement of Defendant CJL Realty Management, LLC, 

signed by Richard R. Carroll, Jr., Manager, including the attachments, 

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submitted by Defendants' counsel Walter Weir, Jr., to Commission 

counsel Carole Reynolds on November 19, 2013; and 

6. Additional documentation submitted by electronic mail messages from 

Defendants' counsel Walter Weir, Jr., to Conunission counsel Carole 

Reynolds on the following dates: December 21,2013, January 2, 2014, 

and January 8, 2014, attaching: 

(a) A lease application filed by Defendant CJL Realty Management, 

dated June 11, 2013; 

(b) A hardware/ software financing proposal for CJL Realty 

Management, dated July 17, 2013; 

(c) A narrative response and additional supporting documents by 

Defendant Heritage Highgate, Inc., discussing the company's 

- --~-~- -------~-------

--~----- ---- petition for ~f!:~ttptc)r-uhder Chapter 11 of the Banlauptcy Code 

in January 2009, dated December 30, 2013; and 

(d) A Judgment Schedule, and a list of Monetary Judgments and 

Settlements Owed by Heritage Building Group. 

D. The suspension of the judgment will be lifted as to Defendants Heritage Homes 

G-roup, Inc., Heritage Building Group, Inc., and Heritage Partners, Inc., if, upon 

motion by the Plaintiff, the Court finds that any of Sl1ch Defendants, or Defendant 

Heritage Highgate, Inc. or Defendant CJL Realty Management, LLC, 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. 

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

due as to Defendants Heritage Homes Group, Inc., Heritage Building Group, 

Inc. and Heritage Partners, Inc., in the amount specified in Subsection A. above 

(which the parties stipulate only for purposes ofthis Section represents the 

amount of the civil penalty for the violations alleged in the Complaint), less any 

payment previously made pursuant to this Section, plus interest computed from 

the date of entry of this Order. If the suspension of the judgment is lifted as to 

Defendants 'Heritage Homes Group, Inc., Heritage Building Group, Inc., 

and Heritage Partners, Inc., then Defendants Heritage Highgate, Inc. and CJL 

Realty Management, LLC, also are liable for immediate payment of the judgment, 

jointly and severally. 

F. 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. 

G. 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 m· monetary judgment pursuant to 

this Order, 

H. Defendants acknowledges that their Taxpayer Identification Numbers (Social 

Security Numbers or Employer Identification Numbers), which Defendants must 

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

delinquent amount arising out ofthis Order, in accor4ance with 31 U.S.C. § 7701. 

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VI. ORDER ACKNOWLEDGMENTS 

IT IS FURTHER ORDERED that Defendants obtain acknowledgments of receipt of 

this Order: 

A. Each 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 5 years after entry of this Order, each Defendant must deliver a copy of this 

Order to: (1) all principals, officers, directors. and .LLC managers and members; 

(2) all employees, agents, and representatives who participate in the conduct 

specified in Sections I, II, III, and IV of this 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 persotmel. must occm· before they assume their 

responsibilities. 

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

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

acknowledgment of receipt ofthis Order. 

VII. COMPLIANCE REPORTING 

IT IS FURTHER ORDERED that Defendants make timely submissions to the 

Commission: 

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

report, sworn under penalty of pe1jury: 

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

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

representatives ofthe Commission and Plaintiff may use to communicate 

with Defendant; (b) identify all of that Defendant's businesses by all of 

their names, telephone numbers, and physical, postal, email, and Intemet 

addresses; (c) describe the activities of each business, including the goods 

and services offered, the means of advertising, marketing, and sales; (d) 

describe in detail whether and how that 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. 

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

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

following: ~~~-~~_-· __ :::-;.:;__- __ -_ 

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

. contact; or (b) the structure of any entity that 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. 

C. Each Defendant must submit to the Conunission notice of the. filing of any 

bankruptcy petition, insolvency proceeding, or similar proceeding by or against 

such Defendant within 14 days of its filing. 

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

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penalty ofpe1jury 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. 

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. Heritage Homes Group, Inc., et al., 1223234. 

VIII. RECORDKEEPING 

IT IS FURTHER ORDERED create certain records for 20 years 

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

connection with the conduct specified in Sections I, II, III, and IV of this Order, 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 related to mortgage 

credit products, whether received directly or indirectly, such as through a third 

party, and any response; 

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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 0r other marketing material related to 

m01tgage credit products. 

IX. COMPLIANCE MONITORING 

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

compliance with this Order, including 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 

Plaintiff, each Defendant must: submit additional compliance reports or other 

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

depositions; and produce documents f<Dr inspection and copying. The 

Commission and Plaintiff are also authorized to obtain discovery", without further 

leave of court, using any o~f~~~tlre~~ ~"p~r~o~~e~ditrfesprescribed by Federal Rules ~f Civil 

Procedure 29, 30 (including telephoniq depositions), 31, 33, 34, 36, 45, and 69. 

B. For matters concerning this Order, the .Commission and Plaintiff are authorized to 

conmmnicate directly with each Defeqdant. Defendant must permit 

~epresentatives of the Commission and Plaintiff to interview any employee or 

other person affiliated with any Defenrlant who has agreed to such an interview. 

The person interviewed may have couJilsel present. 

C. The Commission and Plaintiff niay use all other lawful means, including posing, 

through its representatives as consumers, suppliers, or other individuals or 

entities, to Defendants or any individulitl or entity affiliated with Defen~ant"s, 

without the necessity of identification or prior notice. Nothing in this Order limits 

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FEDERAL TnADE COMMISSlON 

-~t:~_. CAROLE REVN~ 

MICHELLE GRAJALES 

YAA APORl 

Wl'~a:~G-~i"t\'1111ers LLP 

The Widener Building 

1339 Chestnut Street, Suite 500 

Philadelphia, Pennsylvania 19107 

Telephone: (215) 24 l -7721 

Facsimile: {215} 665-8!91 

Email: wweir@weit'pat1ners.com 

DEFgNDANTS 

HERITAGE HOMES GROUP, lNC. 

HERITAGE BUILDJNG GROUP, INC. 

HERITAGE I-BGHGATE, INC. 

HERITAGE PARTNERS, INC. 

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-=c::......;;_;_ __ _ 

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Case 2:14-cv-03173-EL Document 3 Filed 06/06/14 Page 20 of 21

CJL REALTY MANAGEMENT, LLC 

By· 

Ric ard R. Carroll, Jr., Pr ident of 

Heritage Homes Group I c.; Heritage 

Building Group, Inc., an Heritage Highgate 

Inc., and Manager of CJL Realty 

Management, LLC 

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Case 2:14-cv-03173-EL Document 3 Filed 06/06/14 Page 21 of 21

'' 

the Commission.' s lawful use of compu.lsory process, pursuant to Sections 9 and 

20 ofthe FTC Act, 15 U.S.C. §§ 49, 57b·l. 

X. RETENTION OF ~URISDICTION 

IT IS FURTHER ORDERED that this Court retainsjmisdiction of this matter for 

purposes of constl'UOtion, modification, and enforcement of this Order, 

'111 SO ORDERED this --\lo(o ___ day of 

UNITEJ) STATES DISTRICT 

SO STIPULATED AND AGREED: {...ut>W\G\.:J: 

FOR TilE PLAINTIFF~ 

THE UNITED STATES OF AMERICA 

STUART F. DELERY 

Assistant Attorney General, CiviLDivB· ~±' :c::3.. 

1LS. DEPARTMENT OF JUST 

MICHAEL S! BLUME 

· Director 

ANDREW E. CLARK 

AMES , HARLOW 

Tl'ial Attorney 

Consumer Protection Branch 

U.S. Department of Justice 

P.O. Box 386 

Washington, D.C. 20044 

PHONE: 202~514~6786 

FAX: 202"514~8742 

James.W.Harlow@usdoj .gov 

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