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UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

On July 12, 2019, the Federal Trade Commission (“FTC”), filed a complaint for 

permanent injunction and other equitable relief under Sections 13(b) and 19 of the Federal Trade 

Commission Act (“FTC Act”), 15 U.S.C. § 53(b), and an application for an ex parte temporary 

restraining order and ancillary relief under Fed. R. Civ. P. 65(b). Dkt. Nos. 4, 14. The Court 

granted the FTC’s ex parte application and issued an ex parte Temporary Restraining Order on 

July 18, 2019, and set a preliminary injunction hearing for August 1, 2019 at 2:00pm. Dkt. No. 

FEDERAL TRADE COMMISSION,

 Plaintiff,

 vs.

AH MEDIA GROUP, LLC, a Delaware Limited 

Liability Company,

HENRY BLOCK, individually, and as an officer 

of AH MEDIA GROUP, LLC,

ALAN SCHILL, individually, and as an owner of 

AH MEDIA GROUP, LLC,

 Defendants,

 and

ZANELO, LLC, a Puerto Rico Limited Liability 

Company,

 Relief Defendant.

Case No. 19-cv-04022-JD

[Proposed] STIPULATED

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26. Upon the joint request of the parties, the Court extended the Temporary Restraining Order 

and rescheduled the preliminary injunction hearing for August 29, 2019 at 10:00am. Dkt. No. 

31. The respondent defendants are AH Media Group, LLC, Henry Block, and Alan Schill

(collectively, “Defendants”), and respondent relief defendant is Zanelo, LLC (collectively with 

Defendants, “Stipulating Defendants”).

The FTC, defendants, and relief defendant, by and through their undersigned counsel, 

have stipulated and agreed to the entry of a preliminary injunction order (“Order”).

BACKGROUND AND FINDINGS

By stipulation of the parties, the Court finds:

A. The FTC and Stipulating Defendants have stipulated and agreed to the entry of 

this Order without any admission of wrongdoing or violation of law, and without a finding by the 

Court other than stated below.

B. Stipulating Defendants waive all rights to seek judicial review or otherwise 

challenge or contest the validity of the Order.

C. This Court has subject matter jurisdiction over the case, and there is good cause to 

believe that it will have jurisdiction over all parties hereto and that venue in this district is proper.

D. The FTC asserts there is good cause to believe that Defendants: 

(1) misrepresented the price associated with “trial offers” of their products; (2) misrepresented 

that clicking on a “complete checkout” button would complete just the purchase of the trial offer, 

when in fact it added upsell products and associated charges; (3) did not clearly and 

conspicuously disclose to consumers that they would be charged the full amount for the product 

and enrolled in continuity plans resulting in additional charges to their credit cards or 

withdrawals from their debit accounts; (4) did not obtain consumers’ express informed consent 

before imposing these charges, or provide a clear way to stop the recurring charges; (5) did not 

clearly and conspicuously disclose their return, cancellation, and refund policies; (6) used 

fraudulent documentation to contest consumer disputes over unauthorized charges; and 

(7) engaged in credit card laundering, through which they unlawfully used shell companies and 

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shell owners to obtain access to merchant accounts needed to accept consumers’ credit and debit 

card payments.

E. The FTC asserts there is good cause to believe that Defendants have engaged in,

and are likely to engage in, acts or practices that violate Section 5(a) of the FTC Act, 15 U.S.C. 

§ 45(a), Section 4 of the Restore Online Shoppers’ Confidence Act (ROSCA), 15 U.S.C. § 8403,

Section 907(a) of the Electronic Funds Transfer Act (EFTA), 15 U.S.C. § 1693e(a), and Section 

1005.10(b) of Regulation E, 12 C.F.R. § 1005.10(b), and that the FTC is likely to prevail on the 

merits of this action. 

F. The FTC asserts there is good cause to believe that immediate and irreparable 

harm is likely to result from Defendants’ ongoing violations of the FTC Act, ROSCA, EFTA and 

Regulation E, unless Defendants are restrained and enjoined by order of this Court.

G. The FTC asserts there is good cause to believe that relief defendant has received 

funds or other assets that are traceable to Defendants’ violations of law, and that relief defendant 

holds funds and assets in constructive trust for the benefit of Defendants’ customers.

H. The FTC asserts there is good cause exists for continuing the receivership over 

the Receivership Entities (defined infra), continuing to freeze Defendants’ assets, and freezing 

relief defendant’s assets.

I. This Order is in the public interest.

J. The Court has authority to issue this Order under Sections 13(b) and 19 of the 

FTC Act, 15 U.S.C. § 53(b); Federal Rule of Civil Procedure 65; and the All Writs Act, 28 

U.S.C. § 1651.

K. No security is required of any agency of the United States for issuance of a 

preliminary injunction. Fed. R. Civ. P. 65(c).

DEFINITIONS

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

A. “Asset” means any legal or equitable interest in, right to, or claim to, any 

property, wherever located and by whomever held.

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B. “Associated LLCs” means the companies identified in Attachment A to this 

Order and each of their subsidiaries, affiliates, successors, and assigns.

C. “Clear and Conspicuous” or “Clearly and Conspicuously” means that a required 

disclosure is difficult to miss (i.e., easily noticeable) and easily understandable by 

ordinary consumers, including in all of the following ways:

1. In any communication that is solely visual or solely audible, the disclosure 

must be made through the same means through which the communication is 

presented. In any communication made through both visual and audible means, 

such as a television advertisement, the disclosure must be presented simultaneously 

in both the visual and audible portions of the communication even if the 

representation requiring the disclosure is made in only one means;

2. A visual disclosure, by its size, contrast, location, the length of time it 

appears, and other characteristics, must stand out from any accompanying text or 

other visual elements so that it is easily noticed, read, and understood;

3. An audible disclosure, including by telephone or streaming video, must be 

delivered in a volume, speed, and cadence sufficient for ordinary consumers to 

easily hear and understand it;

4. In any communication using an interactive electronic medium, such as the 

Internet or software, the disclosure must be unavoidable;

5. On a product label, the disclosure must be presented on the principal 

display panel;

6. The disclosure must use diction and syntax understandable to ordinary 

consumers and must appear in each language in which the representation that 

requires the disclosure appears;

7. The disclosure must comply with these requirements in each medium 

through which it is received, including all electronic devices and face-to-face 

communications;

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8. The disclosure must not be contradicted or mitigated by, or inconsistent 

with, anything else in the communication; and

9. When the representation or sales practice targets a specific audience, such 

as children, the elderly, or the terminally ill, “ordinary consumers” includes 

reasonable members of that group.

D. “Corporate Defendant” means AH Media Group, LLC, and each of its 

subsidiaries, affiliates, successors, and assigns.

E. “Defendant(s)” means Corporate Defendant AH Media Group, LLC, Henry 

Block and Alan Schill, individually, collectively, or in any combination. 

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

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

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

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

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

Server Access Logs, books, written or printed records, handwritten notes, telephone logs, 

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

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

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

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

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

G. “Electronic Data Host” means any person or entity in the business of storing, 

hosting, or otherwise maintaining electronically stored information. This includes, but is not 

limited to, any entity hosting a website or server, and any entity providing “cloud based” 

electronic storage.

H. “Individual Defendant(s)” means Henry Block and Alan Schill, individually, 

collectively, or in any combination.

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I. “Negative Option Feature” means, in an offer or agreement to sell or provide 

any good or service, a provision under which the consumer’s silence or failure to take affirmative 

action to reject a good or service or to cancel the agreement is interpreted by the seller or 

provider as acceptance or continuing acceptance of the offer.

J. “Receiver” means the receiver appointed in Section XIV of this Order and any 

deputy receivers that are named by the receiver.

K. “Receivership Entities” means Corporate Defendant, Zanelo, LLC, the 

Associated LLCs, as well as any other entity that has conducted any business related to

Defendants’ online marketing of trial offers, including receipt of Assets derived from any 

activity that is the subject of the Complaint in this matter, and that the Receiver determines is 

controlled or owned by any Defendant.

L. “Stipulating Defendants” means Defendants and relief defendant Zanelo, LLC, 

individually, collectively, or in any combination.

ORDER

I. PROHIBITED BUSINESS ACTIVITIES

IT IS THEREFORE ORDERED that Defendants, Defendants’ officers, agents, 

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

receive actual notice of this Order, whether acting directly or indirectly, in connection with the 

advertising, marketing, promoting, or offering for sale of any goods or services, are restrained 

and enjoined from misrepresenting or assisting others in misrepresenting, expressly or by 

implication, any material fact, including, but not limited to: 

A. Any cost to the consumer to purchase, receive, use, or return the initial good or 

service;

B. That the consumer will not be charged for any good or service;

C. That a good or service is offered on a “free,” “trial,” “sample,” “bonus,” “gift,” 

“no commitment,” “discounted” basis, or words of similar import, denoting or implying the 

absence of an obligation on the part of the recipient of the offer to affirmatively act in order to 

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avoid charges, including where a charge will be assessed pursuant to the offer unless the 

consumer takes affirmative steps to prevent or stop such a charge;

D. That the consumer can obtain a good or service for a processing, service, 

shipping, handling, or administrative fee with no further obligation;

E. That a transaction has been authorized by the consumer; 

F. Any material aspect of the nature or terms of websites that are presented as part of 

the process of completing a purchase, including “complete checkout” buttons;

G. Any material aspect of the nature or terms of a refund, cancellation, exchange, or 

repurchase policy for the good or service; or

H. Any other fact material to consumers concerning any good or service, such as: 

the total costs; any material restrictions, limitations, or conditions; or any material aspect of its 

performance, efficacy, nature, or central characteristics.

II. PROHIBITION AGAINST UNFAIR AND DECEPTIVE 

NEGATIVE OPTION MARKETING PRACTICES

IT IS FURTHER ORDERED that Defendants, Defendants’ officers, agents, 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 restrained and 

enjoined from charging, causing to be charged, assisting others in charging, or attempting to 

charge any consumer in any sale of a good or service with a Negative Option Feature without:

A. Clearly and Conspicuously disclosing all material terms of the Negative Option 

Feature before obtaining the consumer’s billing information;

B. Obtaining a consumer’s express informed consent, written or similarly authorized, 

to the Negative Option Feature before making any charge; and

C. Providing a simple mechanism for a consumer to stop recurring charges from 

being placed on the consumer’s credit card, debit card, or other financial account.

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III. PROHIBITION AGAINST DEBITING CONSUMERS’ 

BANK ACCOUNTS WITHOUT AUTHORIZATION

IT IS FURTHER ORDERED that Defendants, Defendants’ officers, agents, 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, in connection with the 

sale of any good or service, are restrained and enjoined from:

A. Failing to timely obtain written authorization signed or similarly authenticated by 

the consumer for any Preauthorized Electronic Fund Transfer from a consumer’s account before 

initiating any Preauthorized Electronic Fund Transfer; and

B. Failing to provide the consumer a copy of a valid written authorization signed or 

similarly authenticated by the consumer for any Preauthorized Electronic Fund Transfer.

IV. PROHIBITION RELATED TO OBTAINING MERCHANT ACCOUNTS 

AND RESPONDING TO CHARGEBACKS

IT IS FURTHER ORDERED that Defendants, Defendants’ officers, agents, 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 restrained 

and enjoined from: 

A. Failing to disclose to any bank, payment processor, credit card processor, 

independent sales organization, third party processor, payment gateway, or other financial 

institution any material fact relating to obtaining a merchant account, including, but not limited 

to, the identity of the bona fide owner, manager, director, or officer of an entity applying for or 

holding a merchant account, and whether such owner, manager, director, or officer:

1. Has been or is placed in a merchant account monitoring program;

2. Has had a merchant account terminated by a bank, payment processor, or 

other financial institution; or

3. Has been fined or otherwise disciplined by a bank, payment processor, or 

other financial institution, in connection with a merchant account. 

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B. Making, or causing, or assisting others in making, directly or by implication, any 

false or misleading statements in order to obtain a merchant account or respond to a chargeback.

V. PROHIBITION ON RELEASE OF CUSTOMER INFORMATION

IT IS FURTHER ORDERED that Defendants, Defendants’ officers, agents, 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 restrained 

and enjoined from:

A. Selling, renting, leasing, transferring, or otherwise disclosing, the name, address, 

birth date, telephone number, email address, credit card number, bank account number, Social 

Security number, or other financial or identifying information of any person that any Defendant 

obtained in connection with any activity that pertains to the subject matter of this Order; and

B. Benefitting from or using the name, address, birth date, telephone number, email 

address, credit card number, bank account number, Social Security number, or other financial or 

identifying information of any person that any Defendant obtained in connection with any 

activity that pertains to the subject matter of this Order.

Provided, however, that Defendants may disclose such identifying information to a law 

enforcement agency, to their attorneys as required for their defense, as required by any law, 

regulation, or court order, or in any filings, pleadings or discovery in this action in the manner 

required by the Federal Rules of Civil Procedure and by any protective order in the case.

VI. ASSET FREEZE

IT IS FURTHER ORDERED that Stipulating Defendants and their officers, agents, 

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 

restrained and enjoined from:

A. Transferring, liquidating, converting, encumbering, pledging, loaning, selling, 

concealing, dissipating, disbursing, assigning, relinquishing, spending, withdrawing, granting a 

lien or security interest or other interest in, or otherwise disposing of any Assets that are:

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1. owned or controlled, directly or indirectly, by any Stipulating Defendant;

2. held, in part or in whole, for the benefit of any Stipulating Defendant;

3. in the actual or constructive possession of any Stipulating Defendant; or

4. owned or controlled by, in the actual or constructive possession of, or 

otherwise held for the benefit of, any corporation, partnership, asset 

protection trust, or other entity that is directly or indirectly owned, 

managed or controlled by any Stipulating Defendant.

B. Opening or causing to be opened any safe deposit boxes, commercial mail boxes, 

or storage facilities titled in the name of any Stipulating Defendant or subject to access by any 

Stipulating Defendant, except as necessary to comply with written requests from the Receiver 

acting pursuant to its authority under this Order;

C. Incurring charges or cash advances on any credit, debit, or ATM card issued in 

the name, individually or jointly, of Corporate Defendant or any corporation, partnership, or 

other entity directly or indirectly owned, managed, or controlled by any Stipulating Defendant or 

of which any Stipulating Defendant is an officer, director, member, or manager. This includes 

any corporate bankcard or corporate credit card account for which any Stipulating Defendant is, 

or was on the date that this Order was signed, an authorized signor; or

D. Cashing any checks or depositing any money orders or cash received from 

consumers, clients, or customers of any Defendant.

Except for the exceptions set forth below in this Section, the Assets affected by this Order 

include: (1) all Assets of Stipulating Defendants as of the time the Temporary Restraining Order 

(Dkt. No. 26) was entered; or (2) Assets obtained by Stipulating Defendants after the Temporary 

Restraining Order was entered if those Assets are derived from any activity that is the subject of 

the Complaint in this matter or that is prohibited by this Order. Provided that this Order will not 

apply to, or otherwise restrict, Assets obtained after the Temporary Restraining Order was issued 

that were derived from activity that is neither the subject of the Complaint nor prohibited by this 

Order. Provided further that this Section does not prohibit any transfers to the Receiver or 

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repatriation of foreign Assets specifically required by this order. Provided further that the 

following Assets are exempt from the Asset Freeze:

i) The bank account in the name of Dynamic Body Solutions 1 LLC, DBA Dynamix 

held at Bank of The West and ending in xxxx4491; and

ii) The bank account in the name of Zanelo Capital Management, LLC held at Banco 

Popular and ending in xxxx7584.

Provided further, however, that Defendants Block, Schill, and AH Media Group, may 

request from FTC counsel—and the Receiver, in the event the request concerns Receivership 

assets—in writing and with supporting documentation, a stipulation agreeing to the release of 

frozen funds for reasonable and necessary expenses. FTC counsel, and, if applicable, the 

Receiver, shall review any such request and communicate any objections to Defendants’ counsel. 

The parties shall meet and confer concerning any objections to a request for release of funds for 

expenses. To the extent the parties agree on a stipulation, Defendants shall file a stipulation and 

proposed order with the Court to modify the asset freeze to release the funds in the stipulation. In 

the event that the parties are unable to resolve objections to a request for release of funds for 

expenses, Defendants Block, Schill, and AH Media Group may move the Court for a release of 

funds for expenses. FTC counsel or the Receiver may raise an opposition with the Court to such 

a motion.

VII. DUTIES OF ASSET HOLDERS AND OTHER THIRD PARTIES

IT IS FURTHER ORDERED that any financial or brokerage institution, Electronic Data 

Host, credit card processor, payment processor, merchant bank, acquiring bank, independent 

sales organization, third party processor, payment gateway, insurance company, currency 

exchange or cryptocurrency exchange or service provider, business entity, or person who 

receives actual notice of this Order (by service or otherwise) that:

(a) has held, controlled, or maintained custody, through an account or 

otherwise, of any Document on behalf of any Stipulating Defendant or any Asset that has been: 

owned or controlled, directly or indirectly, by any Stipulating Defendant; held, in part or in 

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whole, for the benefit of any Stipulating Defendant; in the actual or constructive possession of 

any Stipulating Defendant; or owned or controlled by, in the actual or constructive possession of, 

or otherwise held for the benefit of, any corporation, partnership, asset protection trust, or other 

entity that is directly or indirectly owned, managed or controlled by any Stipulating Defendant; 

(b) regarding Electronic Data Hosts, has held, controlled, or maintained 

custody of any email account set forth in Attachment B to this Order;

(c) has held, controlled, or maintained custody, through an account or 

otherwise, of any Document or Asset associated with credits, debits, or charges made on behalf 

of any Stipulating Defendant, including reserve funds held by payment processors, credit card 

processors, merchant banks, acquiring banks, independent sales organizations, third party 

processors, payment gateways, insurance companies, or other entities; or

(d) has extended credit to any Stipulating Defendant, including through a 

credit card account, will:

A. Except for the explicit carve-outs in Section VI, hold, preserve, and retain within 

its control and prohibit the withdrawal, removal, alteration, assignment, transfer, pledge, 

encumbrance, disbursement, dissipation, relinquishment, conversion, sale, or other disposal of 

any such Document or Asset, as well as all Documents or other property related to such Assets, 

except by further order of this Court; provided, however, that this provision does not prohibit an 

Individual Defendant from incurring charges on a personal credit card established prior to entry 

of this Order;

B. Except for the explicit carve-outs in Section VI, deny any person, except the 

Receiver, access to any safe deposit box, commercial mail box, or storage facility that is titled in 

the name of any Stipulating Defendant, either individually or jointly, or otherwise subject to 

access by any Defendant;

C. To the extent applicable, provide the FTC’s counsel and the Receiver, within 

three (3) days of receiving a copy of this Order, a sworn statement setting forth, for each Asset or 

account covered by this Order, subject to the explicit carve-outs in Section VI:

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1. The identification number of each such account or Asset;

2. The balance of each such account, or a description of the nature and value 

of each such Asset as of the close of business on the day on which this 

Order is served, and, if the account or other Asset has been closed or 

removed, the date closed or removed, the total funds removed in order to 

close the account, and the name of the person or entity to whom such 

account or other Asset was remitted; 

3. The identification of any safe deposit box, commercial mail box, or 

storage facility that is either titled in the name, individually or jointly, of 

any Defendant, or is otherwise subject to access by any Stipulating 

Defendant; and

4. The cryptographic hash value, time stamp, transaction data, public 

addresses or other information sufficient to identify, locate, and track 

cryptocurrency in any blockchain or distributed ledger technology system 

that is belonging to, for the use or benefit of, under the control of, or 

subject to access by any Stipulating Defendant; and 

D. Upon the request of the FTC’s counsel or the Receiver, promptly provide the 

FTC’s counsel and the Receiver with copies of all records or other Documents pertaining to each 

Asset or account covered by this Order, including originals or copies of account applications, 

account statements, signature cards, checks, drafts, deposit tickets, transfers to and from the 

accounts, including wire transfers and wire transfer instructions, all other debit and credit 

instruments or slips, currency transaction reports, 1099 forms, and all logs and records pertaining 

to safe deposit boxes, commercial mail boxes, and storage facilities.

Provided, however, that this Section does not prohibit any transfers to the Receiver or 

repatriation of foreign Assets specifically required by this Order.

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VIII. FINANCIAL DISCLOSURES

IT IS FURTHER ORDERED that each Stipulating Defendant, within five (5) days of 

service of this Order upon them, who has not already done so, will prepare and deliver to the 

FTC’s counsel and the Receiver:

A. Completed financial statements on the forms attached to this Order as 

Attachment C (Financial Statement of Individual Defendant) for each Individual Defendant, and 

Attachment D (Financial Statement of Corporate Defendant) for Corporate Defendant AH 

Media Group, LLC and relief defendant Zanelo, LLC; 

B. Completed cryptocurrency financial statement on the form attached to this Order 

as Attachment E; and

C. Completed Attachment F (IRS Form 4506, Request for Copy of a Tax Return) 

for each Stipulating Defendant.

IX. FOREIGN ASSET REPATRIATION

IT IS FURTHER ORDERED that within five (5) days following the service of this 

Order, each Defendant who has not already done so, will:

A. Provide the FTC’s counsel and the Receiver with a full accounting, verified under 

oath and accurate as of the date of this Order, of all Assets, Documents, and accounts outside of 

the United States which are: (1) titled in the name, individually or jointly, of any Stipulating 

Defendant; (2) held by any person or entity for the benefit of any Stipulating Defendant or for 

the benefit of, any corporation, partnership, asset protection trust, or other entity that is directly 

or indirectly owned, managed or controlled by any Stipulating Defendant; or (3) under the direct 

or indirect control, whether jointly or singly, of any Stipulating Defendant; 

B. Take all steps necessary to provide the FTC’s counsel and Receiver access to all 

Documents and records that may be held by third parties located outside of the territorial United 

States of America, including signing the Consent to Release of Financial Records appended to 

this Order as Attachment G.

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C. Transfer to the territory of the United States all Documents and Assets located in 

foreign countries that are: (1) titled in the name, individually or jointly, of any Stipulating 

Defendant; (2) held by any person or entity for the benefit of any Stipulating Defendant or for 

the benefit of, any corporation, partnership, asset protection trust, or other entity that is directly 

or indirectly owned, managed or controlled by any Stipulating Defendant; or (3) under the direct 

or indirect control, whether jointly or singly, of any Stipulating Defendant; and

D. The same business day as any repatriation, (1) notify the Receiver and counsel for 

the FTC of the name and location of the financial institution or other entity that is the recipient of 

such Documents or Assets; and (2) serve this Order on any such financial institution or other 

entity.

X. NON-INTERFERENCE WITH REPATRIATION

IT IS FURTHER ORDERED that Stipulating Defendants, Stipulating Defendants’ 

officers, agents, 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 restrained and enjoined from taking any action, directly or indirectly, which may 

result in the encumbrance or dissipation of foreign Assets, or in the hindrance of the repatriation 

required by this Order, including, but not limited to:

A. Sending any communication or engaging in any other act, directly or indirectly, 

that results in a determination by a foreign trustee or other entity that a “duress” event has 

occurred under the terms of a foreign trust agreement until such time that all Stipulating 

Defendants’ Assets have been fully repatriated pursuant to this Order; or

B. Notifying any trustee, protector or other agent of any foreign trust or other related 

entities of either the existence of this Order, or of the fact that repatriation is required pursuant to 

a court order, until such time that all Stipulating Defendants’ Assets have been fully repatriated 

pursuant to this Order.

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XI. CONSUMER CREDIT REPORTS

IT IS FURTHER ORDERED that the FTC may obtain credit reports concerning any 

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

§ 1681b(a)(1), and that, upon written request, any credit reporting agency from which such 

reports are requested will provide them to the FTC.

XII. PRESERVATION OF RECORDS

IT IS FURTHER ORDERED that Stipulating Defendants, Stipulating Defendants’ 

officers, agents, 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 restrained and enjoined from:

A. Destroying, erasing, falsifying, writing over, mutilating, concealing, altering, 

transferring, or otherwise disposing of, in any manner, directly or indirectly, Documents that 

relate to: (1) the business, business practices, Assets, or business or personal finances of any 

Stipulating Defendant; (2) the business practices or finances of entities directly or indirectly 

under the control of any Stipulating Defendant; or (3) the business practices or finances of 

entities directly or indirectly under common control with any other Stipulating Defendant; and

B. Failing to create and maintain Documents that, in reasonable detail, accurately, 

fairly, and completely reflect Stipulating Defendants’ incomes, disbursements, transactions, and 

use of Stipulating Defendants’ Assets.

XIII. REPORT OF NEW BUSINESS ACTIVITY

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

employees, and in-house counsel, 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 

restrained and enjoined from creating, operating, or exercising any control over any business 

entity, whether newly formed or previously inactive, including any partnership, limited 

partnership, joint venture, sole proprietorship, or corporation, without first providing the FTC’s 

counsel and the Receiver with a written statement disclosing: (1) the name of the business 

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entity; (2) the address and telephone number of the business entity; (3) the names of the business 

entity’s officers, directors, principals, managers, and employees; and (4) a detailed description of 

the business entity’s intended activities.

XIV. RECEIVER

IT IS FURTHER ORDERED that the Court continues the appointment of a Receiver, 

with Robb Evans & Associates LLC appointed as Receiver of the Receivership Entities with full 

powers of an equity receiver. The Receiver will be solely the agent of this Court in acting as 

Receiver under this Order.

XV. DUTIES AND AUTHORITY OF RECEIVER

IT IS FURTHER ORDERED that the Receiver is directed and authorized to accomplish 

the following:

A. Assume full control of Receivership Entities by removing, as the Receiver deems 

necessary or advisable, any director, officer, independent contractor, employee, attorney, or 

agent of any Receivership Entity from control of, management of, or participation in the affairs 

of the Receivership Entity;

B. Take exclusive custody, control, and possession of all Assets and Documents of, 

or in the possession, custody, or under the control of, any Receivership Entity, wherever situated;

C. Take exclusive custody, control, and possession of all Documents or Assets 

associated with credits, debits, or charges made on behalf of any Receivership Entity, wherever 

situated, including reserve funds held by payment processors, credit card processors, merchant 

banks, acquiring banks, independent sales organizations, third party processors, payment 

gateways, insurance companies, or other entities; 

D. Conserve, hold, manage, and prevent the loss of all Assets of the Receivership 

Entities, and perform all acts necessary or advisable to preserve the value of those Assets. The 

Receiver will assume control over the income and profits therefrom and all sums of money now 

or hereafter due or owing to the Receivership Entities. The Receiver will have full power to sue 

for, collect, and receive, all Assets of the Receivership Entities and of other persons or entities 

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whose interests are now under the direction, possession, custody, or control of, the Receivership

Entities. Provided, however, that the Receiver will not attempt to collect any amount from a 

consumer if the Receiver believes the consumer’s debt to the Receivership Entities has resulted 

from the deceptive acts or practices or other violations of law alleged in the Complaint in this 

matter, without prior Court approval;

E. Obtain, conserve, hold, manage, and prevent the loss of all Documents of the 

Receivership Entities, and perform all acts necessary or advisable to preserve such Documents. 

The Receiver will: divert mail; preserve all Documents of the Receivership Entities that are 

accessible via electronic means (such as online access to financial accounts and access to 

electronic Documents held onsite or by Electronic Data Hosts, by changing usernames,

passwords or other log-in credentials; take possession of all electronic Documents of the 

Receivership Entities stored onsite or remotely; take whatever steps necessary to preserve all 

such Documents; and obtain the assistance of the FTC’s Digital Forensic Unit for the purpose of 

obtaining electronic Documents stored onsite or remotely.

F. Choose, engage, and employ attorneys, accountants, appraisers, and other 

independent contractors and technical specialists, as the Receiver deems advisable or necessary 

in the performance of duties and responsibilities under the authority granted by this Order;

G. Make payments and disbursements from the receivership estate that are necessary 

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

and to incur, or authorize the making of, such agreements as may be necessary and advisable in 

discharging his or her duties as Receiver. The Receiver will apply to the Court for prior approval 

of any payment of any debt or obligation incurred by the Receivership Entities prior to the date 

of entry of this Order, except payments that the Receiver deems necessary or advisable to secure 

Assets of the Receivership Entities, such as rental payments;

H. Take all steps necessary to secure and take exclusive custody of each location 

from which the Receivership Entities operate their businesses. Such steps may include, but are 

not limited to, any of the following, as the Receiver deems necessary or advisable: (1) securing 

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the location by changing the locks and alarm codes and disconnecting any Internet access or 

other means of access to the computers, servers, internal networks, or other records maintained at 

that location; and (2) requiring any persons present at the location to leave the premises, to

provide the Receiver with proof of identification, and/or to demonstrate to the satisfaction of the 

Receiver that such persons are not removing from the premises Documents or Assets of the 

Receivership Entities. Law enforcement personnel, including, but not limited to, police or 

sheriffs, may assist the Receiver in implementing these provisions in order to keep the peace and 

maintain security. If requested by the Receiver, the United States Marshal will provide 

appropriate and necessary assistance to the Receiver to implement this Order and is authorized to 

use any necessary and reasonable force to do so;

I. Take all steps necessary to prevent the modification, destruction, or erasure of any 

web page or website registered to and operated, in whole or in part, by any Defendants, and to 

provide access to all such web pages or websites to the FTC’s representatives, agents, and 

assistants, as well as Defendants and their representatives; 

J. Enter into and cancel contracts and purchase insurance as advisable or necessary;

K. Prevent the inequitable distribution of Assets and determine, adjust, and protect 

the interests of consumers who have transacted business with the Receivership Entities;

L. Make an accounting, as soon as practicable, of the Assets and financial condition 

of the receivership and file the accounting with the Court and deliver copies thereof to all parties;

M. Institute, compromise, adjust, appear in, intervene in, defend, dispose of, or 

otherwise become party to any legal action in state, federal or foreign courts or arbitration 

proceedings as the Receiver deems necessary and advisable to preserve or recover the Assets of 

the Receivership Entities, or to carry out the Receiver’s mandate under this Order, including but 

not limited to, actions challenging fraudulent or voidable transfers;

N. Issue subpoenas to obtain Documents and records pertaining to the Receivership, 

and conduct discovery in this action on behalf of the receivership estate, in addition to obtaining 

other discovery as set forth in this Order;

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O. Open one or more bank accounts at designated depositories for funds of the 

Receivership Entities. The Receiver will deposit all funds of the Receivership Entities in such 

designated accounts and will make all payments and disbursements from the receivership estate 

from such accounts. The Receiver will serve copies of monthly account statements on all 

parties;

P. Maintain accurate records of all receipts and expenditures incurred as Receiver;

Q. Allow the FTC’s representatives, agents, and assistants, as well as

Defendants’ representatives and Defendants themselves, reasonable access to the premises of the 

Receivership Entities, or any other premises where the Receivership Entities conduct business. 

The purpose of this access will be to inspect and copy any and all books, records, Documents, 

accounts, and other property owned by, or in the possession of, the Receivership Entities or their 

agents. The Receiver will have the discretion to determine the time, manner, and reasonable 

conditions of such access;

R. Allow the FTC’s representatives, agents, and assistants, as well as Defendants and 

their representatives reasonable access to all Documents in the possession, custody, or control of 

the Receivership Entities; 

S. Cooperate with reasonable requests for information or assistance from any state or 

federal civil or criminal law enforcement agency;

T. Suspend business operations of the Receivership Entities if in the judgment of the 

Receiver such operations cannot be continued legally and profitably; 

U. If the Receiver identifies a nonparty entity as a Receivership Entity, promptly 

notify the entity as well as the parties, and inform the entity that it can challenge the Receiver’s 

determination by filing a motion with the Court. Provided, however, that the Receiver may delay 

providing such notice until the Receiver has established control of the nonparty entity and its 

Assets and records, if the Receiver determines that notice to the entity or the parties before the 

Receiver establishes control over the entity may result in the destruction of records, dissipation 

of Assets, or any other obstruction of the Receiver’s control of the entity; and

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V. If in the Receiver’s judgment the business operations cannot be continued legally 

and profitably, take all steps necessary to ensure that any of the Receivership Entities’ web pages 

or websites relating to the activities alleged in the Complaint cannot be accessed by the public, or 

are modified for consumer education and/or informational purposes, and take all steps necessary 

to ensure that any telephone numbers associated with the Receivership Entities cannot be 

accessed by the public, or are answered solely to provide consumer education or information 

regarding the status of operations.

XVI. TRANSFER OF RECEIVERSHIP PROPERTY TO RECEIVER

IT IS FURTHER ORDERED that Stipulating Defendants and any other person with 

possession, custody or control of property of, or records relating to, the Receivership Entities 

will, upon notice of this Order by personal service or otherwise, fully cooperate with and assist 

the Receiver in taking and maintaining possession, custody, or control of the Assets and 

Documents of the Receivership Entities and immediately transfer or deliver to the Receiver 

possession, custody, and control of, the following:

A. All Assets held by or for the benefit of the Receivership Entities;

B. All Documents or Assets associated with credits, debits, or charges made on 

behalf of any Receivership Entity, wherever situated, including reserve funds held by payment 

processors, credit card processors, merchant banks, acquiring banks, independent sales 

organizations, third party processors, payment gateways, insurance companies, or other entities; 

C. All Documents of or pertaining to the Receivership Entities;

D. All computers, electronic devices, mobile devices and machines used to conduct 

the business of the Receivership Entities;

E. All Assets and Documents belonging to other persons or entities whose interests 

are under the direction, possession, custody, or control of the Receivership Entities; and

F. All keys, codes, user names and passwords necessary to gain or to secure access 

to any Assets or Documents of or pertaining to the Receivership Entities, including access to 

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their business premises, means of communication, accounts, computer systems (onsite and 

remote), Electronic Data Hosts, or other property.

In the event that any person or entity fails to deliver or transfer any Asset or Document, 

or otherwise fails to comply with any provision of this Section, the Receiver or any Stipulating 

Defendant may file an Affidavit of Non-Compliance regarding the failure and a motion seeking 

compliance or a contempt citation.

XVII. PROVISION OF INFORMATION TO RECEIVER

IT IS FURTHER ORDERED that Stipulating Defendants, if they have not already done 

so, will immediately provide to the Receiver:

A. A list of all Assets and accounts of the Receivership Entities that are held in any 

name other than the name of a Receivership Entity, or by any person or entity other than a 

Receivership Entity;

B. A list of all agents, employees, officers, attorneys, servants and those persons in 

active concert and participation with the Receivership Entities, or who have been associated or 

done business with the Receivership Entities; and

C. A description of any Documents covered by attorney-client privilege or attorney 

work product, including files where such Documents are likely to be located, authors or 

recipients of such Documents, and search terms likely to identify such electronic Documents.

XVIII. COOPERATION WITH THE RECEIVER

IT IS FURTHER ORDERED that Stipulating Defendants; Receivership Entities; 

Stipulating Defendants’ or Receivership Entities’ officers, agents, employees, and attorneys, all 

other persons in active concert or participation with any of them, and any other person with 

possession, custody, or control of property of or records relating to the Receivership Entities who 

receive actual notice of this Order will fully cooperate with and assist the Receiver. This 

cooperation and assistance will include, but is not limited to, providing information to the 

Receiver that the Receiver deems necessary to exercise the authority and discharge the 

responsibilities of the Receiver under this Order; providing any keys, codes, user names and 

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passwords required to access any computers, electronic devices, mobile devices, and machines 

(onsite or remotely) and any cloud account (including specific method to access account) or 

electronic file in any medium; advising all persons who owe money to any Receivership Entity 

that all debts should be paid directly to the Receiver; and transferring funds at the Receiver’s 

direction and producing records related to the Assets and sales of the Receivership Entities.

XIX. NON-INTERFERENCE WITH THE RECEIVER

IT IS FURTHER ORDERED that Stipulating Defendants; Receivership Entities; 

Stipulating Defendants’ or Receivership Entities’ officers, agents, employees, attorneys, and all 

other persons in active concert or participation with any of them, who receive actual notice of 

this Order, and any other person served with a copy of this Order, are hereby restrained and 

enjoined from directly or indirectly:

A. Interfering with the Receiver’s efforts to manage, or take custody, control, or 

possession of, the Assets or Documents subject to the receivership;

B. Transacting any of the business of the Receivership Entities;

C. Transferring, receiving, altering, selling, encumbering, pledging, assigning, 

liquidating, or otherwise disposing of any Assets owned, controlled, or in the possession or 

custody of, or in which an interest is held or claimed by, the Receivership Entities; or

D. Refusing to cooperate with the Receiver or the Receiver’s duly authorized agents 

in the exercise of their duties or authority under any order of this Court.

XX. STAY OF ACTIONS

IT IS FURTHER ORDERED that, except by leave of this Court, during the pendency of 

the receivership ordered herein, Stipulating Defendants, Stipulating Defendants’ officers, agents, 

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

who receive actual notice of this Order, and their corporations, subsidiaries, divisions, or 

affiliates, and all investors, creditors, stockholders, lessors, customers and other persons seeking 

to establish or enforce any claim, right, or interest against or on behalf of Stipulating Defendants, 

and all others acting for or on behalf of such persons, are hereby enjoined from taking action that 

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would interfere with the exclusive jurisdiction of this Court over the Assets or Documents of the 

Receivership Entities, including, but not limited to: 

A. Filing or assisting in the filing of a petition for relief under the Bankruptcy Code, 

11 U.S.C. § 101 et seq., or of any similar insolvency proceeding on behalf of the Receivership 

Entities;

B. Commencing, prosecuting, or continuing a judicial, administrative, or other action 

or proceeding against the Receivership Entities, including the issuance or employment of process 

against the Receivership Entities, except that such actions may be commenced if necessary to toll 

any applicable statute of limitations;

C. Filing or enforcing any lien on any Asset of the Receivership Entities, taking or 

attempting to take possession, custody, or control of any Asset of the Receivership Entities; or 

attempting to foreclose, forfeit, alter, or terminate any interest in any Asset of the Receivership 

Entities, whether such acts are part of a judicial proceeding, are acts of self-help, or otherwise.

Provided, however, that this Order does not stay: (1) the commencement or continuation 

of a criminal action or proceeding; (2) the commencement or continuation of an action or 

proceeding by a governmental unit to enforce such governmental unit’s police or regulatory 

power; or (3) the enforcement of a judgment, other than a money judgment, obtained in an action 

or proceeding by a governmental unit to enforce such governmental unit’s police or regulatory 

power.

XXI. COMPENSATION OF RECEIVER

IT IS FURTHER ORDERED that the Receiver and all personnel hired by the Receiver as 

herein authorized, including counsel to the Receiver and accountants, are entitled to reasonable 

compensation for the performance of duties pursuant to this Order and for the cost of actual outof-pocket expenses incurred by them, from the Assets now held by, in the possession or control 

of, or which may be received by, the Receivership Entities. The Receiver will file with the Court 

and serve on the parties periodic requests for the payment of such reasonable compensation, with 

the first such request filed no more than sixty (60) days after the date of entry of this Order. The 

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Receiver will not increase the hourly rates used as the bases for such fee applications without 

prior approval of the Court.

XXII. RECEIVER’S BOND

IT IS FURTHER ORDERED that the Receiver, if he has not already done so, will file 

with the Clerk of this Court a bond in the sum of ten thousand dollars ($10,000) with sureties to 

be approved by the Court, conditioned that the Receiver will well and truly perform the duties of 

the office and abide by and perform all acts the Court directs. 28 U.S.C. § 754.

XXIII. DISTRIBUTION OF ORDER BY DEFENDANTS

IT IS FURTHER ORDERED that Stipulating Defendants, if they have not already done 

so, will immediately provide a copy of this Order to each affiliate, telemarketer, marketer, sales 

entity, successor, assign, member, officer, director, employee, agent, independent contractor, 

client, attorney, spouse, subsidiary, division, and representative of any Stipulating Defendant, 

and will, within ten (10) days from the date of entry of this Order, provide the FTC and the 

Receiver with a sworn statement that this provision of the Order has been satisfied, which 

statement will include the names, physical addresses, phone number, and email addresses of each 

such person or entity who received a copy of the Order. Furthermore, Stipulating Defendants 

will not take any action that would encourage officers, agents, members, directors, employees, 

salespersons, independent contractors, attorneys, subsidiaries, affiliates, successors, assigns or 

other persons or entities in active concert or participation with them to disregard this Order or 

believe that they are not bound by its provisions.

XXIV. SERVICE OF THIS ORDER

IT IS FURTHER ORDERED that copies of this Order may be served by any means, 

including facsimile transmission, electronic mail or other electronic messaging, personal or 

overnight delivery, U.S. Mail or FedEx, by agents and employees of the FTC, by any law 

enforcement agency, or by private process server, upon any Stipulating Defendant or any person 

(including any financial institution) that may have possession, custody or control of any Asset or 

Document of any Stipulating Defendant, or that may be subject to any provision of this Order 

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pursuant to Rule 65(d)(2) of the Federal Rules of Civil Procedure. For purposes of this Section, 

service upon any branch, subsidiary, affiliate or office of any entity will effect service upon the 

entire entity.

XXV. CORRESPONDENCE AND SERVICE ON PLAINTIFF

IT IS FURTHER ORDERED that, for the purpose of this Order, all correspondence and 

service of pleadings on the FTC will be addressed to:

Roberta Tonelli

Emily Burton

Colin Hector

Federal Trade Commission

901 Market Street, Suite 570

San Francisco, CA 94103

Tel: (415) 848-5197, -5111, -5195

Fax: (415) 848-5184

Email: rtonelli@ftc.gov; eburton@ftc.gov; chector@ftc.gov

XXVI. DURATION OF THE ORDER

This Order, including the provisions of the Asset Freeze in Section VI of this Order, will 

expire upon entry of a final judgment in this case.

XXVII. RETENTION OF JURISDICTION

The Court retains jurisdiction of this matter for all purposes.

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SO STIPULATED:

/s/ Roberta Diane Tonelli

ROBERTA DIANE TONELLI

EMILY COPE BURTON

COLIN A. HECTOR

Federal Trade Commission

901 Market Street, Suite 570

San Francisco, CA 94103

Email: rtonelli@ftc.gov

eburton@ftc.gov, chector@ftc.gov 

Tel: (415) 848-5100

Fax: (415) 848-5184

Attorneys for Plaintiff

FEDERAL TRADE COMMISSION

/s/ Karl S. Kronenberger

KARL S. KRONENBERGER 

LIANA W. CHEN 

Kronenberger Rosenfeld, LLP 

150 Post Street, Suite 520 

San Francisco, CA 94108

Email: karl@krinternetlaw.com

Tel: (415) 955-1155

Attorneys for Defendants

AH MEDIA GROUP, LLC

HENRY BLOCK

ALAN SCHILL

and Relief Defendant

ZANELO, LLC

IT IS SO ORDERED.

DATED: August 28, 2019

_______________________________

JAMES DONATO

UNITED STATES DISTRICT JUDGE

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Attachment A 

Associated LLCs 

Case 3:19-cv-04022-JD Document 52 Filed 08/28/19 Page 28 of 73
1

ATTACHMENT A

ASSOCIATED LLCs

KA KETTERLIN, LLC

AE HART, LLC

UNDERSTATED INVESTMENTS, LLC

JBE INVESTMENTS, LLC

ANS INVESTMENTS, LLC

SAM INVESTMENTS, LLC

ESM INVESTMENTS, LLC

MOOD INVESTMENTS, LLC

EEG INVESTMENTS, LLC

AMES INVESTMENTS, LLC

LAB INVESTMENTS, LLC

ELANN INVESTMENTS, LLC

KDUR INVESTMENTS, LLC

BEAN INVESTMENTS, LLC

PIAZ INVESTMENTS, LLC

AMB INVESTMENTS, LLC

KMD INVESTMENTS, LLC

CCB INVESTMENT, LLC

LE LIMITED, LLC

GALB INVESTMENTS, LLC

PYPER INVESTMENTS, LLC

PEEPS INVESTMENTS, LLC

SES INVESTMENTS, LLC

MADDY INVESTMENTS, LLC

CHAZ INVESTMENTS, LLC

LWA INVESTMENTS, LLC

SCW INVESTMENTS, LLC

KJA INVESTMENTS, LLC

MCH INVESTMENTS, LLC

TWP INVESTMENTS, LLC

COLETTE LIMITED, LLC

MPM HEALTH, LLC

GRL HEALTH, LLC 

SW HEALTH, LLC

KGW HEALTH, LLC

Case 3:19-cv-04022-JD Document 52 Filed 08/28/19 Page 29 of 73
2

HSK HEALTH, LLC

AAM HEALTH, LLC

BJM HEALTH, LLC

KJL HEALTH, LLC

AAH HEALTH, LLC

RWM HEALTH, LLC

LJL HEALTH, LLC

SMW HEALTH, LLC

BAS HEALTH, LLC

NMG HEALTH, LLC

GWV HEALTH, LLC

SWC HEALTH, LLC

TCO HEALTH, LLC

MBR HEALTH, LLC

MAG HEALTH, LLC

EMB HEALTH, LLC

JMD HEALTH, LLC

CBC HEALTH, LLC

CLM HEALTH, LLC

LAZ HEALTH, LLC

JMO HEALTH, LLC

ZB HEALTH, LLC

BS HEALTH, LLC

IJG HEALTH, LLC

BSB HEALTH, LLC

RAZ HEALTH, LLC

TCM HEALTH, LLC

KJW HEALTH, LLC

CAG HEALTH, LLC

ACCOLADE INDUSTRIES LLC

ALEJA VITAL BALANCE LLC

ALPHA AMC HEALTH LLC

ALPHA BRUDZE LLC

ALPHA JF HEALTH LLC

ALPHA STOUT LLC

ANGEL EYES HEALTH LLC

ANTIDOTE INDUSTRIES LLC

ARTFUL MEDIA LLC

BIRDMAN HEALTH SOLUTIONS LLC

Case 3:19-cv-04022-JD Document 52 Filed 08/28/19 Page 30 of 73
3

BJB HEALTH LLC

BYZANTINE COMPANIES LLC

CACTUS ENTERPRISES LLC

CJC WELL BEING LLC

COGNIZANT LLC

DREAMY DAWN PRODUCTS LLC

IKAIKA WELLNESS LLC

INTRICATE ENTERPRISES LLC

JADED EXCELLENCE LLC

JR COMPREHENSIVE SOLUTIONS 

LLC

KALANI HEALTH SOLUTIONS LLC

KLG HEALTH LLC

LA PUISSANCE HEALTH LLC

PERK HEALTH LLC

PICCO POWER SOLUTIONS LLC

PONTS CAPITAL LLC

RMD HEALTH LLC

SARAH'S REMEDIES LLC

SLOAN SIMPLE SOLUTIONS LLC

SMG INVESTMENTS LLC

SMK SOLUTIONS LLC

STEBO HEALTH SOLUTIONS LLC

STREET SMART RESTORATIVES LLC

TREMENDOUS TOTTON LLC

WILD COSMO ENTERPRISES LLC

Case 3:19-cv-04022-JD Document 52 Filed 08/28/19 Page 31 of 73
Attachment B 

Email Accounts 

Case 3:19-cv-04022-JD Document 52 Filed 08/28/19 Page 32 of 73
ATTACHMENT B 

EMAIL ACCOUNTS 

1) All emails using the domain @ahmediagroup.net, including but not limited to the 

following:

ablock@ahmediagroup.net; 

alan@ahmediagroup.net; 

hblock@ahmediagroup.net; 

sara@ahmediagroup.net; 

vanessa@ahmediagroup.net 

2) All emails using the domain @zanelo.com, including but not limited to the 

following: 

alan@zanelo.com 

henry@zanelo.com 

shanya@zanelo.com 

3) hblock55@aol.com 

4) ahwildones@gmail.com 

5) ibownerco@gmail.com 

6) sarah.grauert@gmail.com 

Case 3:19-cv-04022-JD Document 52 Filed 08/28/19 Page 33 of 73
Attachment C 

Financial Statement of Individual Defendant 

Case 3:19-cv-04022-JD Document 52 Filed 08/28/19 Page 34 of 73
Federal Trade Commission Financial Statement of Individual Defendant 

FEDERAL TRADE COMMISSION 

FINANCIAL STATEMENT OF INDIVIDUAL DEFENDANT 

 

Definitions and Instructions: 

1. Complete all items. Enter “None” or “N/A” (“Not Applicable”) in the first field only of any item that does not apply 

to you. If you cannot fully answer a question, explain why. 

2. “Dependents” include your spouse, live-in companion, dependent children, or any other person, whom you or your 

spouse (or your children’s other parent) claimed or could have claimed as a dependent for tax purposes at any 

time during the past five years. 

3. “Assets” and “Liabilities” include ALL assets and liabilities, located within the United States or any foreign country 

or territory, whether held individually or jointly and whether held by you, your spouse, or your dependents, or held 

by others for the benefit of you, your spouse, or your dependents. 

4. Attach continuation pages as needed. On the financial statement, state next to the Item number that the Item is 

being continued. On the continuation page(s), identify the Item number(s) being continued. 

5. Type or print legibly. 

6. Initial each page in the space provided in the lower right corner. 

7. Sign and date the completed financial statement on the last page. 

Penalty for False Information: 

Federal law provides that any person may be imprisoned for not more than five years, fined, or both, if such person: 

 (1) “in any matter within the jurisdiction of the executive, legislative, or judicial branch of the Government of the 

United States, knowingly and willfully falsifies, conceals or covers up by any trick, scheme, or devise a material fact; 

makes any materially false, fictitious or fraudulent statement or representation; or makes or uses any false writing or 

document knowing the same to contain any materially false, fictitious or fraudulent statement or entry” (18 U.S.C. § 1001); 

 (2) “in any . . . statement under penalty of perjury as permitted under section 1746 of title 28, United States Code, 

willfully subscribes as true any material matter which he does not believe to be true” (18 U.S.C. § 1621); or 

 (3) “in any ( . . . statement under penalty of perjury as permitted under section 1746 of title 28, United States 

Code) in any proceeding before or ancillary to any court or grand jury of the United States knowingly makes any false 

material declaration or makes or uses any other information . . . knowing the same to contain any false material 

declaration” (18 U.S.C. § 1623). 

For a felony conviction under the provisions cited above, federal law provides that the fine may be not more than the 

greater of (i) $250,000 for an individual or $500,000 for a corporation, or (ii) if the felony results in pecuniary gain to any

person or pecuniary loss to any person other than the defendant, the greater of twice the gross gain or twice the gross 

loss. 18 U.S.C. § 3571.

Case 3:19-cv-04022-JD Document 52 Filed 08/28/19 Page 35 of 73
 

 1 of 10 Federal Trade Commission Financial Statement of Individual Defendant

BACKGROUND INFORMATION

Item 1. Information About You 

Full Name Social Security No.

 

Current Address of Primary Residence

 

Driver’s License No.

 

State Issued

 

Phone Numbers

Home: ( ) 

Fax: ( ) 

Date of Birth: / /

 (mm/dd/yyyy)

Place of Birth

Rent Own From (Date): / /

 (mm/dd/yyyy)

E-Mail Address

Internet Home Page

 

Previous Addresses for past five years (if required, use additional pages at end of form)

Address

 From: / / Until: / / 

 (mm/dd/yyyy) (mm/dd/yyyy)

Rent Own 

Address

 From: / / Until: / / 

Rent Own 

Address

 From: / / Until: / / 

Rent Own 

Identify any other name(s) and/or social security number(s) you have used, and the time period(s) during which they 

were used: 

Item 2. Information About Your Spouse or Live-In Companion

Spouse/Companion's Name

 

Social Security No.

 

Date of Birth

 / / 

(mm/dd/yyyy)

Address (if different from yours)

 

Phone Number

( )

Place of Birth

 

Rent Own From (Date): / /

 (mm/dd/yyyy)

Identify any other name(s) and/or social security number(s) you have used, and the time period(s) during which they were used:

 

Employer’s Name and Address 

 

Job Title 

Years in Present Job

 

Annual Gross Salary/Wages 

$ 

Item 3. Information About Your Previous Spouse

Name and Address

 

Social Security No.

 

Date of Birth

 / / 

(mm/dd/yyyy)

Item 4. Contact Information (name and address of closest living relative other than your spouse) 

Name and Address

 

Phone Number

( ) 

Initials: 

Case 3:19-cv-04022-JD Document 52 Filed 08/28/19 Page 36 of 73
 

 2 of 10 Federal Trade Commission Financial Statement of Individual Defendant

Item 5. Information About Dependents (whether or not they reside with you)

Name and Address

 

Social Security No.

 

Date of Birth

 / / 

(mm/dd/yyyy)

Relationship

Name and Address

 

Social Security No.

 

Date of Birth

 / / 

(mm/dd/yyyy)

Relationship

 

Name and Address

 Social Security No.

 

Date of Birth

 / / 

(mm/dd/yyyy)

Relationship

 

Name and Address

 Social Security No.

 

Date of Birth

 / / 

(mm/dd/yyyy)

Relationship

 

Item 6. Employment Information/Employment Income

Provide the following information for this year-to-date and for each of the previous five full years, for each business entity of which you were a director, 

officer, member, partner, employee (including self-employment), agent, owner, shareholder, contractor, participant or consultant at any time during that 

period. “Income” includes, but is not limited to, any salary, commissions, distributions, draws, consulting fees, loans, loan payments, dividends, 

royalties, and benefits for which you did not pay (e.g., health insurance premiums, automobile lease or loan payments) received by you or anyone else 

on your behalf.

Company Name and Address

 Dates Employed Income Received: Y-T-D & 5 Prior Yrs.

From (Month/Year)

 / 

To (Month/Year)

 / 

Year Income

20 $

Ownership Interest? Yes No $ 

Positions Held From (Month/Year) To (Month/Year) $ 

/ / $ 

/ / $ 

/ / $ 

Company Name and Address

 Dates Employed Income Received: Y-T-D & 5 Prior Yrs.

From (Month/Year)

 / 

To (Month/Year)

 / 

Year Income

20 $

Ownership Interest? Yes No $ 

Positions Held From (Month/Year) To (Month/Year) $ 

/ / $ 

/ / $ 

/ / $ 

Company Name and Address

 Dates Employed Income Received: Y-T-D & 5 Prior Yrs.

From (Month/Year)

 / 

To (Month/Year)

 / 

Year Income

20 $

Ownership Interest? Yes No $ 

Positions Held From (Month/Year) To (Month/Year) $ 

/ / $ 

/ / $ 

/ / $ 

Initials: 

Case 3:19-cv-04022-JD Document 52 Filed 08/28/19 Page 37 of 73
 

 3 of 10 Federal Trade Commission Financial Statement of Individual Defendant

Item 7. Pending Lawsuits Filed By or Against You or Your Spouse

List all pending lawsuits that have been filed by or against you or your spouse in any court or before an administrative agency in the United States or in 

any foreign country or territory. Note: At Item 12, list lawsuits that resulted in final judgments or settlements in your favor. At Item 21, list lawsuits that 

resulted in final judgments or settlements against you.

Caption of Proceeding Court or Agency and Location Case No. Nature of 

Proceeding Relief Requested Status or 

Disposition

Item 8. Safe Deposit Boxes

List all safe deposit boxes, located within the United States or in any foreign country or territory, whether held individually or jointly and whether held by 

you, your spouse, or any of your dependents, or held by others for the benefit of you, your spouse, or any of your dependents.

Name of Owner(s) Name & Address of Depository Institution Box No. Contents

Initials: 

Case 3:19-cv-04022-JD Document 52 Filed 08/28/19 Page 38 of 73
 

 4 of 10 Federal Trade Commission Financial Statement of Individual Defendant

FINANCIAL INFORMATION

REMINDER: When an item asks for information regarding your “assets” and “liabilities” include ALL assets and liabilities, located within 

the United States or in any foreign country or territory, or institution, whether held individually or jointly, and whether held by you, your 

spouse, or any of your dependents, or held by others for the benefit of you, your spouse, or any of your dependents. In addition, provide 

all documents requested in Item 24 with your completed Financial Statement. 

ASSETS

Item 9. Cash, Bank, and Money Market Accounts

List cash on hand (as opposed to cash in bank accounts or other financial accounts) and all bank accounts, money market accounts, or other financial 

accounts, including but not limited to checking accounts, savings accounts, and certificates of deposit. The term “cash on hand” includes but is not 

limited to cash in the form of currency, uncashed checks, and money orders.

a. Amount of Cash on Hand $ Form of Cash on Hand 

b. Name on Account Name & Address of Financial Institution Account No. Current Balance

$

$

$

$

$

Item 10. Publicly Traded Securities 

List all publicly traded securities, including but not limited to, stocks, stock options, corporate bonds, mutual funds, U.S. government securities (including 

but not limited to treasury bills and treasury notes), and state and municipal bonds. Also list any U.S. savings bonds.

Owner of Security

 

Issuer

 

Type of Security

 

No. of Units Owned

 

Broker House, Address

 

Broker Account No.

Current Fair Market Value

$ 

Loan(s) Against Security

$ 

Owner of Security

 

Issuer

 

Type of Security

 

No. of Units Owned

 

Broker House, Address

 

Broker Account No.

Current Fair Market Value

$ 

Loan(s) Against Security

$ 

Owner of Security

 

Issuer

 

Type of Security

 

No. of Units Owned

 

Broker House, Address

 

Broker Account No.

Current Fair Market Value

$ 

Loan(s) Against Security

$ 

Initials: 

Case 3:19-cv-04022-JD Document 52 Filed 08/28/19 Page 39 of 73
 

 5 of 10 Federal Trade Commission Financial Statement of Individual Defendant

Item 11. Non-Public Business and Financial Interests

List all non-public business and financial interests, including but not limited to any interest in a non-public corporation, subchapter-S corporation, limited 

liability corporation (“LLC”), general or limited partnership, joint venture, sole proprietorship, international business corporation or personal investment 

corporation, and oil or mineral lease.

Entity’s Name & Address Type of Business or Financial 

Interest (e.g., LLC, partnership)

Owner

(e.g., self, spouse)

Ownership 

% 

If Officer, Director, Member 

or Partner, Exact Title

Item 12. Amounts Owed to You, Your Spouse, or Your Dependents

Debtor’s Name & Address

 

Date Obligation 

Incurred (Month/Year)

/

Original Amount Owed

$ 

Nature of Obligation (if the result of a final court 

judgment or settlement, provide court name 

and docket number)

Current Amount Owed $ Payment Schedule

$ 

Debtor’s Telephone

 

Debtor’s Relationship to You

 

Debtor’s Name & Address

 

Date Obligation 

Incurred (Month/Year)

/

Original Amount Owed

$ 

Nature of Obligation (if the result of a final court 

judgment or settlement, provide court name 

and docket number)

Current Amount Owed $ Payment Schedule

$ 

Debtor’s Telephone

 

Debtor’s Relationship to You

 

Item 13. Life Insurance Policies 

List all life insurance policies (including endowment policies) with any cash surrender value.

Insurance Company’s Name, Address, & Telephone No.

 

Beneficiary Policy No. Face Value

$

Insured

 

Loans Against Policy

$ 

Surrender Value

$ 

Insurance Company’s Name, Address, & Telephone No.

 

Beneficiary

 

Policy No.

 

Face Value

$ 

Insured

 

Loans Against Policy

$ 

Surrender Value

$ 

Item 14. Deferred Income Arrangements

List all deferred income arrangements, including but not limited to, deferred annuities, pensions plans, profit-sharing plans, 401(k) plans, IRAs, Keoghs, 

other retirement accounts, and college savings plans (e.g., 529 Plans).

Trustee or Administrator’s Name, Address & Telephone No.

 

Name on Account

 

Account No.

 

Date Established

 / / 

(mm/dd/yyyy)

Type of Plan

 

Surrender Value before 

Taxes and Penalties 

$

Trustee or Administrator’s Name, Address & Telephone No.

 

Name on Account Account No.

Date Established

 / / 

Type of Plan

 

Surrender Value before 

Taxes and Penalties 

$

Initials: 

Case 3:19-cv-04022-JD Document 52 Filed 08/28/19 Page 40 of 73
 

 6 of 10 Federal Trade Commission Financial Statement of Individual Defendant

Item 15. Pending Insurance Payments or Inheritances

List any pending insurance payments or inheritances owed to you.

Type Amount Expected Date Expected (mm/dd/yyyy)

$ / /

$ / /

$ / /

Item 16. Vehicles

List all cars, trucks, motorcycles, boats, airplanes, and other vehicles.

Vehicle Type Year Registered Owner’s Name Purchase Price

$

Original Loan Amount

$

Current Balance

$

Make Registration State & No. Account/Loan No. Current Value

$

Monthly Payment

$

Model

 

Address of Vehicle’s Location

 

Lender’s Name and Address

 

Vehicle Type Year Registered Owner’s Name Purchase Price

$

Original Loan Amount

$

Current Balance

$

Make Registration State & No. Account/Loan No. Current Value

$

Monthly Payment

$

Model

 

Address of Vehicle’s Location

 

Lender’s Name and Address

 

Vehicle Type Year Registered Owner’s Name Purchase Price

$

Original Loan Amount

$

Current Balance

$

Make Registration State & No. Account/Loan No. Current Value

$

Monthly Payment

$

Model

 

Address of Vehicle’s Location

 

Lender’s Name and Address

 

Vehicle Type Year Registered Owner’s Name Purchase Price

$

Original Loan Amount

$

Current Balance

$

Make Registration State & No. Account/Loan No. Current Value

$

Monthly Payment

$

Model

 

Address of Vehicle’s Location

 

Lender’s Name and Address

 

Item 17. Other Personal Property

List all other personal property not listed in Items 9-16 by category, whether held for personal use, investment or any other reason, including but not 

limited to coins, stamps, artwork, gemstones, jewelry, bullion, other collectibles, copyrights, patents, and other intellectual property. 

Property Category

(e.g., artwork, jewelry) Name of Owner Property Location Acquisition Cost Current Value

$ $

$ $

$ $

Initials: 

Case 3:19-cv-04022-JD Document 52 Filed 08/28/19 Page 41 of 73
 

 7 of 10 Federal Trade Commission Financial Statement of Individual Defendant

Item 18. Real Property

List all real property interests (including any land contract) 

Property’s Location

 

Type of Property

 

Name(s) on Title or Contract and Ownership Percentages

 

Acquisition Date (mm/dd/yyyy)

/ /

Purchase Price

$

Current Value

$

Basis of Valuation

Lender’s Name and Address

 

Loan or Account No.

 

Current Balance On First Mortgage or 

Contract

$

Monthly Payment

$

Other Mortgage Loan(s) (describe)

 

Monthly Payment

$

Rental Unit

Monthly Rent Received

$

Current Balance

$

Property’s Location

 

Type of Property

 

Name(s) on Title or Contract and Ownership Percentages

 

Acquisition Date (mm/dd/yyyy)

 / / 

Purchase Price

$

Current Value

$

Basis of Valuation

Lender’s Name and Address

 

Loan or Account No.

 

Current Balance On First Mortgage or 

Contract

$

Monthly Payment

$

Other Mortgage Loan(s) (describe)

 

Monthly Payment

$

Rental Unit

Monthly Rent Received

$ Current Balance

$

LIABILITIES

Item 19. Credit Cards 

List each credit card account held by you, your spouse, or your dependents, and any other credit cards that you, your spouse, or your dependents use, 

whether issued by a United States or foreign financial institution.

Name of Credit Card (e.g., Visa, 

MasterCard, Department Store) Account No. Name(s) on Account Current Balance

$

$

$

$

$

Item 20. Taxes Payable

List all taxes, such as income taxes or real estate taxes, owed by you, your spouse, or your dependents. 

Type of Tax Amount Owed Year Incurred

$

$

$

Initials: 

Case 3:19-cv-04022-JD Document 52 Filed 08/28/19 Page 42 of 73
 

 8 of 10 Federal Trade Commission Financial Statement of Individual Defendant

Item 21. Other Amounts Owed by You, Your Spouse, or Your Dependents

List all other amounts, not listed elsewhere in this financial statement, owed by you, your spouse, or your dependents. 

Lender/Creditor’s Name, Address, and Telephone No.

 

Nature of Debt (if the result of a court judgment or settlement, provide court name and docket 

number)

 

Lender/Creditor’s Relationship to You

 

Date Liability Was Incurred

 / / 

(mm/dd/yyyy)

Original Amount Owed

$ 

Current Amount Owed

$ 

Payment Schedule

 

Lender/Creditor’s Name, Address, and Telephone No.

 

Nature of Debt (if the result of a court judgment or settlement, provide court name and docket 

number)

 

Lender/Creditor’s Relationship to You

 

Date Liability Was Incurred

 / / 

(mm/dd/yyyy)

Original Amount Owed

$ 

Current Amount Owed

$ 

Payment Schedule

 

OTHER FINANCIAL INFORMATION

Item 22. Trusts and Escrows

List all funds and other assets that are being held in trust or escrow by any person or entity for you, your spouse, or your dependents. Include any legal 

retainers being held on your behalf by legal counsel. Also list all funds or other assets that are being held in trust or escrow by you, your spouse, or your 

dependents, for any person or entity. 

Trustee or Escrow Agent’s Name & Address Date Established

(mm/dd/yyyy) Grantor Beneficiaries Present Market Value of Assets*

/ / $

/ / $

/ / $

*If the market value of any asset is unknown, describe the asset and state its cost, if you know it.

Item 23. Transfers of Assets 

List each person or entity to whom you have transferred, in the aggregate, more than $5,000 in funds or other assets during the previous five years by 

loan, gift, sale, or other transfer (exclude ordinary and necessary living and business expenses paid to unrelated third parties). For each such person or 

entity, state the total amount transferred during that period.

Transferee’s Name, Address, & Relationship Property Transferred Aggregate Value* Transfer Date

(mm/dd/yyyy)

Type of Transfer

(e.g., Loan, Gift)

$ / /

$ / /

$ / /

*If the market value of any asset is unknown, describe the asset and state its cost, if you know it.

Initials: 

Case 3:19-cv-04022-JD Document 52 Filed 08/28/19 Page 43 of 73
 

 9 of 10 Federal Trade Commission Financial Statement of Individual Defendant

Item 24. Document Requests 

Provide copies of the following documents with your completed Financial Statement.

Federal tax returns filed during the last three years by or on behalf of you, your spouse, or your dependents. 

All applications for bank loans or other extensions of credit (other than credit cards) that you, your spouse, or your 

dependents have submitted within the last two years, including by obtaining copies from lenders if necessary.

Item 9 For each bank account listed in Item 9, all account statements for the past 3 years.

Item 11

For each business entity listed in Item 11, provide (including by causing to be generated from accounting records) the 

most recent balance sheet, tax return, annual income statement, the most recent year-to-date income statement, and all 

general ledger files from account records.

Item 17

All appraisals that have been prepared for any property listed in Item 17, including appraisals done for insurance 

purposes. You may exclude any category of property where the total appraised value of all property in that category is 

less than $2,000.

Item 18 All appraisals that have been prepared for real property listed in Item 18.

Item 21 Documentation for all debts listed in Item 21.

Item 22 All executed documents for any trust or escrow listed in Item 22. Also provide any appraisals, including insurance 

appraisals that have been done for any assets held by any such trust or in any such escrow. 

SUMMARY FINANCIAL SCHEDULES

Item 25. Combined Balance Sheet for You, Your Spouse, and Your Dependents

Assets Liabilities

Cash on Hand (Item 9) $ Loans Against Publicly Traded Securities (Item 10) $

Funds Held in Financial Institutions (Item 9) $ Vehicles - Liens (Item 16) $

U.S. Government Securities (Item 10) $ Real Property – Encumbrances (Item 18) $

Publicly Traded Securities (Item 10) $ Credit Cards (Item 19) $

Non-Public Business and Financial Interests (Item 11) $ Taxes Payable (Item 20) $

Amounts Owed to You (Item 12) $ Amounts Owed by You (Item 21) $

Life Insurance Policies (Item 13) $ Other Liabilities (Itemize)

Deferred Income Arrangements (Item 14) $ $

Vehicles (Item 16) $ $

Other Personal Property (Item 17) $ $

Real Property (Item 18) $ $

Other Assets (Itemize) $

$ $

$ $

$ $

Total Assets $ Total Liabilities $

Item 26. Combined Current Monthly Income and Expenses for You, Your Spouse, and Your Dependents

Provide the current monthly income and expenses for you, your spouse, and your dependents. Do not include credit card payments separately; rather, 

include credit card expenditures in the appropriate categories.

Income (State source of each item) Expenses

Salary - After Taxes

Source: $ Mortgage or Rental Payments for Residence(s) $ 

Fees, Commissions, and Royalties

Source: $ Property Taxes for Residence(s) $ 

Interest

Source: $ Rental Property Expenses, Including Mortgage Payments, Taxes, 

and Insurance $ 

Dividends and Capital Gains

Source: $ Car or Other Vehicle Lease or Loan Payments $ 

Gross Rental Income

Source: $ Food Expenses $ 

Profits from Sole Proprietorships

Source: $ Clothing Expenses $ 

Distributions from Partnerships, S-Corporations, 

and LLCs

Source:

$ 

Utilities

$ 

Initials: 

Case 3:19-cv-04022-JD Document 52 Filed 08/28/19 Page 44 of 73
 

 10 of 10 Federal Trade Commission Financial Statement of Individual Defendant

Item 26. Combined Current Monthly Income and Expenses for You, Your Spouse, and Your Dependents (cont.)

Distributions from Trusts and Estates

Source: $ Medical Expenses, Including Insurance $ 

Distributions from Deferred Income Arrangements 

Source: $ Other Insurance Premiums

$ 

Social Security Payments $ Other Transportation Expenses $

Alimony/Child Support Received $ Other Expenses (Itemize)

Gambling Income $ $

Other Income (Itemize) $

$ $

$ $

$ $

Total Income $ Total Expenses $ 

ATTACHMENTS

Item 27. Documents Attached to this Financial Statement List all documents that are being submitted with this financial statement. For any Item 24 documents that are not attached, explain why.

Item No. Document Relates To Description of Document

I am submitting this financial statement with the understanding that it may affect action by the Federal Trade

Commission or a federal court. I have used my best efforts to obtain the information requested in this statement. The 

responses I have provided to the items above are true and contain all the requested facts and information of which I have 

notice or knowledge. I have provided all requested documents in my custody, possession, or control. I know of the 

penalties for false statements under 18 U.S.C. § 1001, 18 U.S.C. § 1621, and 18 U.S.C. § 1623 (five years imprisonment 

and/or fines). I certify under penalty of perjury under the laws of the United States that the foregoing is true and correct. 

Executed on:

_______________ ___________________________________

(Date) Signature

Case 3:19-cv-04022-JD Document 52 Filed 08/28/19 Page 45 of 73
Attachment D 

Financial Statement of Corporate Defendant 

Case 3:19-cv-04022-JD Document 52 Filed 08/28/19 Page 46 of 73
FEDERAL TRADE COMMISSION

FINANCIAL STATEMENT OF CORPORATE DEFENDANT

 

Instructions: 

1. Complete all items. Enter “None” or "N/A" (“Not Applicable”) where appropriate. If you cannot fully answer a

question, explain why.

2. The font size within each field will adjust automatically as you type to accommodate longer responses.

3. In completing this financial statement, “the corporation” refers not only to this corporation but also to each of its

predecessors that are not named defendants in this action.

4. When an Item asks for information about assets or liabilities “held by the corporation,” include ALL such assets

and liabilities, located within the United States or elsewhere, held by the corporation or held by others for the

benefit of the corporation.

5. Attach continuation pages as needed. On the financial statement, state next to the Item number that the Item is

being continued. On the continuation page(s), identify the Item number being continued. 

6. Type or print legibly. 

7. An officer of the corporation must sign and date the completed financial statement on the last page and initial

each page in the space provided in the lower right corner. 

Penalty for False Information: 

Federal law provides that any person may be imprisoned for not more than five years, fined, or both, if such person:

(1) “in any matter within the jurisdiction of any department or agency of the United States knowingly and

willfully falsifies, conceals or covers up by any trick, scheme, or device a material fact, or makes any false,

fictitious or fraudulent statements or representations, or makes or uses any false writing or document knowing the

same to contain any false, fictitious or fraudulent statement or entry” (18 U.S.C. § 1001);

(2) “in any . . . statement under penalty of perjury as permitted under section 1746 of title 28, United States Code,

willfully subscribes as true any material matter which he does not believe to be true” (18 U.S.C. § 1621); or

(3) “in any (. . . statement under penalty of perjury as permitted under section 1746 of title 28, United States

Code) in any proceeding before or ancillary to any court or grand jury of the United States knowingly makes any

false material declaration or makes or uses any other information . . . knowing the same to contain any false

material declaration.” (18 U.S.C. § 1623)

For a felony conviction under the provisions cited above, federal law provides that the fine may be not more than the

greater of (i) $250,000 for an individual or $500,000 for a corporation, or (ii) if the felony results in pecuniary gain to any

person or pecuniary loss to any person other than the defendant, the greater of twice the gross gain or twice the gross loss.

18 U.S.C. § 3571.

 

Case 3:19-cv-04022-JD Document 52 Filed 08/28/19 Page 47 of 73
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BACKGROUND INFORMATION

Item 1. General Information 

Corporation’s Full Name ___________________________________________________________________________

Primary Business Address ______________________________________________________ From (Date) _________

Telephone No. _____________________________ Fax No. _____________________________

 E-Mail Address________________________ Internet Home Page________________________

All other current addresses & previous addresses for past five years, including post office boxes and mail drops: 

Address____________________________________________________________ From/Until____________________

Address____________________________________________________________ From/Until____________________

Address____________________________________________________________ From/Until____________________

All predecessor companies for past five years:

Name & Address _________________________________________________________ From/Until ______________

Name & Address _________________________________________________________ From/Until ______________

Name & Address _________________________________________________________ From/Until ______________

Item 2. Legal Information 

Federal Taxpayer ID No. _________________________ State & Date of Incorporation _________________________

State Tax ID No. ____________________ State ________________ Profit or Not For Profit _____________________

Corporation’s Present Status: Active ________________ Inactive _______________ Dissolved __________________

If Dissolved: Date dissolved _________________________ By Whom ______________________________________

Reasons _________________________________________________________________________________________

Fiscal Year-End (Mo./Day) ________________ Corporation’s Business Activities _____________________________

Item 3. Registered Agent

Name of Registered Agent __________________________________________________________________________

Address __________________________________________________________ Telephone No. __________________

Case 3:19-cv-04022-JD Document 52 Filed 08/28/19 Page 48 of 73
Page 3 Initials __________

Item 4. Principal Stockholders

List all persons and entities that own at least 5% of the corporation’s stock.

Name & Address % Owned

_________________________________________________________________________________ ______________

_________________________________________________________________________________ ______________

_________________________________________________________________________________ ______________

_________________________________________________________________________________ ______________

Item 5. Board Members 

List all members of the corporation’s Board of Directors. 

Name & Address % Owned Term (From/Until)

____________________________________________________________________ __________ _________________

____________________________________________________________________ __________ _________________

____________________________________________________________________ __________ _________________

____________________________________________________________________ __________ _________________

____________________________________________________________________ __________ _________________

Item 6. Officers

List all of the corporation’s officers, including de facto officers (individuals with significant management responsibility

whose titles do not reflect the nature of their positions). 

Name & Address % Owned

_______________________________________________________________________________ ________________

_______________________________________________________________________________ ________________

_______________________________________________________________________________ ________________

_______________________________________________________________________________ ________________

_______________________________________________________________________________ ________________

Case 3:19-cv-04022-JD Document 52 Filed 08/28/19 Page 49 of 73
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Item 7. Businesses Related to the Corporation 

List all corporations, partnerships, and other business entities in which this corporation has an ownership interest.

Name & Address Business Activities % Owned 

___________________________________________________________________ ___________________ _________

___________________________________________________________________ ___________________ _________

___________________________________________________________________ ___________________ _________

State which of these businesses, if any, has ever transacted business with the corporation _______________________

________________________________________________________________________________________________

Item 8. Businesses Related to Individuals

List all corporations, partnerships, and other business entities in which the corporation’s principal stockholders, board

members, or officers (i.e., the individuals listed in Items 4 - 6 above) have an ownership interest. 

Individual’s Name Business Name & Address Business Activities % Owned

__________________ __________________________________________________ __________________ ________

__________________ __________________________________________________ __________________ ________

__________________ __________________________________________________ __________________ ________

State which of these businesses, if any, have ever transacted business with the corporation _______________________

________________________________________________________________________________________________

Item 9. Related Individuals

List all related individuals with whom the corporation has had any business transactions during the three previous fiscal

years and current fiscal year-to-date. A “related individual” is a spouse, sibling, parent, or child of the principal

stockholders, board members, and officers (i.e., the individuals listed in Items 4 - 6 above).

Name and Address Relationship Business Activities

_________________________________________________________ _________________ ______________________

_________________________________________________________ _________________ ______________________

_________________________________________________________ _________________ ______________________

Case 3:19-cv-04022-JD Document 52 Filed 08/28/19 Page 50 of 73
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Item 10. Outside Accountants

List all outside accountants retained by the corporation during the last three years.

Name Firm Name Address CPA/PA?

____________________ ______________________ ________________________________________ ____________

____________________ ______________________ ________________________________________ ____________

____________________ ______________________ ________________________________________ ____________

____________________ ______________________ ________________________________________ ____________

____________________ ______________________ ________________________________________ ____________

Item 11. Corporation’s Recordkeeping

List all individuals within the corporation with responsibility for keeping the corporation’s financial books and records for

the last three years. 

Name, Address, & Telephone Number Position(s) Held

____________________________________________________________________________ ___________________

____________________________________________________________________________ ___________________

____________________________________________________________________________ ___________________

____________________________________________________________________________ ___________________

Item 12. Attorneys

List all attorneys retained by the corporation during the last three years.

Name Firm Name Address

____________________ ___________________________ ________________________________________________

____________________ ___________________________ ________________________________________________

____________________ ___________________________ ________________________________________________

____________________ ___________________________ ________________________________________________

____________________ ___________________________ ________________________________________________

Case 3:19-cv-04022-JD Document 52 Filed 08/28/19 Page 51 of 73
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Item 13. Pending Lawsuits Filed by the Corporation 

List all pending lawsuits that have been filed by the corporation in court or before an administrative agency. (List

lawsuits that resulted in final judgments or settlements in favor of the corporation in Item 25). 

Opposing Party’s Name & Address___________________________________________________________________

Court’s Name & Address___________________________________________________________________________

Docket No._________________ Relief Requested____________________ Nature of Lawsuit____________________

____________________________________ Status______________________________________________________

Opposing Party’s Name & Address___________________________________________________________________

Court’s Name & Address___________________________________________________________________________

Docket No._________________ Relief Requested____________________ Nature of Lawsuit____________________

____________________________________ Status______________________________________________________

Opposing Party’s Name & Address___________________________________________________________________

Court’s Name & Address___________________________________________________________________________

Docket No._________________ Relief Requested____________________ Nature of Lawsuit____________________

____________________________________ Status______________________________________________________

Opposing Party’s Name & Address___________________________________________________________________

Court’s Name & Address___________________________________________________________________________

Docket No._________________ Relief Requested____________________ Nature of Lawsuit____________________

____________________________________ Status______________________________________________________

Opposing Party’s Name & Address___________________________________________________________________

Court’s Name & Address___________________________________________________________________________

Docket No._________________ Relief Requested____________________ Nature of Lawsuit____________________

____________________________________ Status______________________________________________________

Opposing Party’s Name & Address___________________________________________________________________

Court’s Name & Address___________________________________________________________________________

Docket No._________________ Relief Requested____________________ Nature of Lawsuit____________________

____________________________________ Status______________________________________________________

Case 3:19-cv-04022-JD Document 52 Filed 08/28/19 Page 52 of 73
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Item 14. Current Lawsuits Filed Against the Corporation 

List all pending lawsuits that have been filed against the corporation in court or before an administrative agency. (List

lawsuits that resulted in final judgments, settlements, or orders in Items 26 - 27).

Opposing Party’s Name & Address___________________________________________________________________

Court’s Name & Address___________________________________________________________________________

Docket No._________________ Relief Requested____________________ Nature of Lawsuit____________________

____________________________________ Status______________________________________________________

Opposing Party’s Name & Address___________________________________________________________________

Court’s Name & Address___________________________________________________________________________

Docket No._________________ Relief Requested____________________ Nature of Lawsuit____________________

____________________________________ Status______________________________________________________

Opposing Party’s Name & Address___________________________________________________________________

Court’s Name & Address___________________________________________________________________________

Docket No._________________ Relief Requested____________________ Nature of Lawsuit____________________

____________________________________ Status______________________________________________________

Opposing Party’s Name & Address___________________________________________________________________

Court’s Name & Address___________________________________________________________________________

Docket No._________________ Relief Requested____________________ Nature of Lawsuit____________________

____________________________________ Status______________________________________________________

Opposing Party’s Name & Address___________________________________________________________________

Court’s Name & Address___________________________________________________________________________

Docket No._________________ Relief Requested____________________ Nature of Lawsuit____________________

____________________________________ Status______________________________________________________

Opposing Party’s Name & Address___________________________________________________________________

Court’s Name & Address___________________________________________________________________________

Docket No._________________ Relief Requested____________________ Nature of Lawsuit____________________

____________________________________ Status______________________________________________________

Case 3:19-cv-04022-JD Document 52 Filed 08/28/19 Page 53 of 73
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Item 15. Bankruptcy Information

List all state insolvency and federal bankruptcy proceedings involving the corporation. 

Commencement Date _________________ Termination Date _________________ Docket No. __________________

If State Court: Court & County _______________________ If Federal Court: District __________________________

Disposition ______________________________________________________________________________________

Item 16. Safe Deposit Boxes

List all safe deposit boxes, located within the United States or elsewhere, held by the corporation, or held by others for the

benefit of the corporation. On a separate page, describe the contents of each box.

Owner’s Name Name & Address of Depository Institution Box No.

__________________ ___________________________________________________________________ __________

__________________ ___________________________________________________________________ __________

__________________ ___________________________________________________________________ __________

__________________ ___________________________________________________________________ __________

__________________ ___________________________________________________________________ __________

FINANCIAL INFORMATION

REMINDER: When an Item asks for information about assets or liabilities “held by the corporation,” include

ALL such assets and liabilities, located within the United States or elsewhere, held by the corporation or held by

others for the benefit of the corporation.

Item 17. Tax Returns

List all federal and state corporate tax returns filed for the last three complete fiscal years. Attach copies of all returns. 

Federal/

State/Both

Tax Year Tax Due

Federal

Tax Paid

Federal

Tax Due

State

Tax Paid

State

Preparer’s Name

___________ __________ $_________ $_________ $__________ $__________ ______________________________

___________ __________ $_________ $_________ $__________ $__________ ______________________________

___________ __________ $_________ $_________ $__________ $__________ ______________________________

Case 3:19-cv-04022-JD Document 52 Filed 08/28/19 Page 54 of 73
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Item 18. Financial Statements

List all financial statements that were prepared for the corporation’s last three complete fiscal years and for the current

fiscal year-to-date. Attach copies of all statements, providing audited statements if available. 

Year Balance Sheet Profit & Loss Statement Cash Flow Statement Changes in Owner’s Equity Audited?

_________ _____________ ______________________ __________________ _______________________ ________

_________ _____________ ______________________ __________________ _______________________ ________

_________ _____________ ______________________ __________________ _______________________ ________

_________ _____________ ______________________ __________________ _______________________ ________

Item 19. Financial Summary

For each of the last three complete fiscal years and for the current fiscal year-to-date for which the corporation has not

provided a profit and loss statement in accordance with Item 18 above, provide the following summary financial

information.

Current Year-to-Date 1 Year Ago 2 Years Ago 3 Years Ago

Gross Revenue $_________________ $_______________ $_______________ $_______________

Expenses $_________________ $_______________ $_______________ $_______________

Net Profit After Taxes $_________________ $_______________ $_______________ $_______________

Payables $_________________

Receivables $_________________

Item 20. Cash, Bank, and Money Market Accounts 

List cash and all bank and money market accounts, including but not limited to, checking accounts, savings accounts, and

certificates of deposit, held by the corporation. The term “cash” includes currency and uncashed checks. 

Cash on Hand $_________________________ Cash Held for the Corporation’s Benefit $_______________________

Name & Address of Financial Institution Signator(s) on Account Account No. Current

Balance

_____________________________________ _______________________________ ______________ $___________

_____________________________________ _______________________________ ______________ $___________

_____________________________________ _______________________________ ______________ $___________

_____________________________________ _______________________________ ______________ $___________

Case 3:19-cv-04022-JD Document 52 Filed 08/28/19 Page 55 of 73
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Item 21. Government Obligations and Publicly Traded Securities 

List all U.S. Government obligations, including but not limited to, savings bonds, treasury bills, or treasury notes, held by

the corporation. Also list all publicly traded securities, including but not limited to, stocks, stock options, registered and

bearer bonds, state and municipal bonds, and mutual funds, held by the corporation. 

Issuer _________________________________ Type of Security/Obligation __________________________________

No. of Units Owned __________ Current Fair Market Value $__________________ Maturity Date _______________

Issuer _________________________________ Type of Security/Obligation __________________________________

No. of Units Owned __________ Current Fair Market Value $__________________ Maturity Date _______________

Item 22. Real Estate 

List all real estate, including leaseholds in excess of five years, held by the corporation. 

Type of Property________________________________ Property’s Location__________________________________

Name(s) on Title and Ownership Percentages___________________________________________________________

Current Value $____________________ Loan or Account No. __________________________

Lender’s Name and Address_________________________________________________________________________

Current Balance On First Mortgage $_______________ Monthly Payment $______________

Other Loan(s) (describe)____________________________________________ Current Balance $_________________

Monthly Payment $__________________ Rental Unit?_________________ Monthly Rent Received $_____________

Type of Property________________________________ Property’s Location__________________________________

Name(s) on Title and Ownership Percentages___________________________________________________________

Current Value $____________________ Loan or Account No. __________________________

Lender’s Name and Address_________________________________________________________________________

Current Balance On First Mortgage $_______________ Monthly Payment $______________

Other Loan(s) (describe)____________________________________________ Current Balance $_________________

Monthly Payment $__________________ Rental Unit?_________________ Monthly Rent Received $_____________

Case 3:19-cv-04022-JD Document 52 Filed 08/28/19 Page 56 of 73
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Item 23. Other Assets 

List all other property, by category, with an estimated value of $2,500 or more, held by the corporation, including but not

limited to, inventory, machinery, equipment, furniture, vehicles, customer lists, computer software, patents, and other

intellectual property. 

Property Category Property Location Acquisition

Cost

Current

Value

____________________________ _____________________________________________ $__________ $_________

____________________________ _____________________________________________ $__________ $_________

____________________________ _____________________________________________ $__________ $_________

____________________________ _____________________________________________ $__________ $_________

____________________________ _____________________________________________ $__________ $_________

____________________________ _____________________________________________ $__________ $_________

____________________________ _____________________________________________ $__________ $_________

____________________________ _____________________________________________ $__________ $_________

____________________________ _____________________________________________ $__________ $_________

Item 24. Trusts and Escrows

List all persons and other entities holding funds or other assets that are in escrow or in trust for the corporation. 

Trustee or Escrow Agent’s 

Name & Address

Description and Location of Assets Present Market

Value of Assets

______________________________________ _______________________________________ $_________________

______________________________________ _______________________________________ $_________________

______________________________________ _______________________________________ $_________________

______________________________________ _______________________________________ $_________________

______________________________________ _______________________________________ $_________________

______________________________________ _______________________________________ $_________________

______________________________________ _______________________________________ $_________________

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Item 25. Monetary Judgments and Settlements Owed To the Corporation 

List all monetary judgments and settlements, recorded and unrecorded, owed to the corporation. 

Opposing Party’s Name & Address___________________________________________________________________

Court’s Name & Address____________________________________________________ Docket No._____________

Nature of Lawsuit______________________________ Date of Judgment________________ Amount $____________

Opposing Party’s Name & Address___________________________________________________________________

Court’s Name & Address____________________________________________________ Docket No._____________

Nature of Lawsuit______________________________ Date of Judgment________________ Amount $____________

Item 26. Monetary Judgments and Settlements Owed By the Corporation

List all monetary judgments and settlements, recorded and unrecorded, owed by the corporation. 

Opposing Party’s Name & Address___________________________________________________________________

Court’s Name & Address____________________________________________________ Docket No._____________

Nature of Lawsuit_______________________________________ Date______________ Amount $______________

Opposing Party’s Name & Address___________________________________________________________________

Court’s Name & Address____________________________________________________ Docket No._____________

Nature of Lawsuit______________________________ Date of Judgment________________ Amount $____________

Opposing Party’s Name & Address___________________________________________________________________

Court’s Name & Address____________________________________________________ Docket No._____________

Nature of Lawsuit______________________________ Date of Judgment________________ Amount $____________

Opposing Party’s Name & Address___________________________________________________________________

Court’s Name & Address____________________________________________________ Docket No._____________

Nature of Lawsuit______________________________ Date of Judgment________________ Amount $____________

Opposing Party’s Name & Address___________________________________________________________________

Court’s Name & Address____________________________________________________ Docket No._____________

Nature of Lawsuit______________________________ Date of Judgment________________ Amount $____________

Case 3:19-cv-04022-JD Document 52 Filed 08/28/19 Page 58 of 73
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Item 27. Government Orders and Settlements 

List all existing orders and settlements between the corporation and any federal or state government entities.

Name of Agency ___________________________________________ Contact Person __________________________

Address _____________________________________________________________ Telephone No. _______________ 

Agreement Date ______________ Nature of Agreement __________________________________________________

Item 28. Credit Cards

List all of the corporation’s credit cards and store charge accounts and the individuals authorized to use them. 

Name of Credit Card or Store Names of Authorized Users and Positions Held

__________________________________________ _____________________________________________________

__________________________________________ _____________________________________________________

__________________________________________ _____________________________________________________

__________________________________________ _____________________________________________________

__________________________________________ _____________________________________________________

Item 29. Compensation of Employees

List all compensation and other benefits received from the corporation by the five most highly compensated employees,

independent contractors, and consultants (other than those individuals listed in Items 5 and 6 above), for the two previous

fiscal years and current fiscal year-to-date. “Compensation” includes, but is not limited to, salaries, commissions,

consulting fees, bonuses, dividends, distributions, royalties, pensions, and profit sharing plans. “Other benefits” include,

but are not limited to, loans, loan payments, rent, car payments, and insurance premiums, whether paid directly to the

individuals, or paid to others on their behalf.

Name/Position Current Fiscal

Year-to-Date

1 Year Ago 2 Years Ago Compensation or 

Type of Benefits

_____________________________ $____________ $___________ $____________ ___________________________

_____________________________ $____________ $___________ $____________ ___________________________

_____________________________ $____________ $___________ $____________ ___________________________

_____________________________ $____________ $___________ $____________ ___________________________

_____________________________ $____________ $___________ $____________ ___________________________

Case 3:19-cv-04022-JD Document 52 Filed 08/28/19 Page 59 of 73
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Item 30. Compensation of Board Members and Officers 

List all compensation and other benefits received from the corporation by each person listed in Items 5 and 6, for the

current fiscal year-to-date and the two previous fiscal years. “Compensation” includes, but is not limited to, salaries,

commissions, consulting fees, dividends, distributions, royalties, pensions, and profit sharing plans. “Other benefits”

include, but are not limited to, loans, loan payments, rent, car payments, and insurance premiums, whether paid directly to

the individuals, or paid to others on their behalf.

Name/Position Current Fiscal

Year-to-Date

1 Year Ago 2 Years Ago Compensation or 

Type of Benefits

_____________________________ $____________ $___________ $____________ ___________________________

_____________________________ $____________ $___________ $____________ ___________________________

_____________________________ $____________ $___________ $____________ ___________________________

_____________________________ $____________ $___________ $____________ ___________________________

_____________________________ $____________ $___________ $____________ ___________________________

_____________________________ $____________ $___________ $____________ ___________________________

_____________________________ $____________ $___________ $____________ ___________________________

_____________________________ $____________ $___________ $____________ ___________________________

Item 31. Transfers of Assets Including Cash and Property

List all transfers of assets over $2,500 made by the corporation, other than in the ordinary course of business, during the

previous three years, by loan, gift, sale, or other transfer. 

Transferee’s Name, Address, & Relationship Property

Transferred

Aggregate

Value

Transfer

Date

Type of Transfer

(e.g., Loan, Gift)

______________________________________ ________________ $____________ __________ _________________

______________________________________ ________________ $____________ __________ _________________

______________________________________ ________________ $____________ __________ _________________

______________________________________ ________________ $____________ __________ _________________

______________________________________ ________________ $____________ __________ _________________

Case 3:19-cv-04022-JD Document 52 Filed 08/28/19 Page 60 of 73
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Item 32. Documents Attached to the Financial Statement

List all documents that are being submitted with the financial statement.

Item No. Document

Relates To

Description of Document

___________________ ____________________________________________________________________________

___________________ ____________________________________________________________________________

___________________ ____________________________________________________________________________

___________________ ____________________________________________________________________________

___________________ ____________________________________________________________________________

___________________ ____________________________________________________________________________

___________________ ____________________________________________________________________________

___________________ ____________________________________________________________________________

___________________ ____________________________________________________________________________

I am submitting this financial statement with the understanding that it may affect action by the Federal Trade

Commission or a federal court. I have used my best efforts to obtain the information requested in this statement. The

responses I have provided to the items above are true and contain all the requested facts and information of which I have

notice or knowledge. I have provided all requested documents in my custody, possession, or control. I know of the

penalties for false statements under 18 U.S.C. § 1001, 18 U.S.C. § 1621, and 18 U.S.C. § 1623 (five years imprisonment

and/or fines). I certify under penalty of perjury under the laws of the United States that the foregoing is true and correct.

Executed on:

______________________________ _____________________________________________________

(Date) Signature

_____________________________________________________

Corporate Position

Case 3:19-cv-04022-JD Document 52 Filed 08/28/19 Page 61 of 73
Attachment E 

Cryptocurrency Financial Statement 

Case 3:19-cv-04022-JD Document 52 Filed 08/28/19 Page 62 of 73
Page 1 of 6

Cryptocurrency Financial Statement

Full Name: _______________________________ Social Security Number: __________________

When an item asks for information regarding your cryptocurrency, include ALL cryptocurrency, whether 

held in the United States or in any foreign country or territory, or institution, whether held individually 

or jointly, and whether held by you, your spouse, or any of your dependents, or held by others for the 

benefit or you, your spouse, or any of your dependents. 

This Cryptocurrency Financial Statement does NOT request information necessary to transfer, dispose 

of, or otherwise exert control over the cryptocurrency.

Place your initial in the bottom right corner of each page. If you need additional space, attach a page to 

this form and note the item to which the information is responsive and place your initial in the bottom 

right corner of each page you add. 

Item 1.

For all your cryptocurrency, state the following:

a. The type of cryptocurrency;

b. The amount of cryptocurrency and its current value;

c. The location and method of storage of the private keys necessary to exert control over the

cryptocurrency (e.g. third party custodian, web wallet, hardware wallet, personal computer,

handwritten document, etc.), and if applicable, the name and manufacturer of any software

or hardware storage methods;

d. Any public addresses or public keys associated with the cryptocurrency; and

e. The owners of your cryptocurrency and the percentage of ownership of each owner.

Case 3:19-cv-04022-JD Document 52 Filed 08/28/19 Page 63 of 73
Page 2 of 6

Initial: _______

Item 2.

For all cryptocurrency for which you have possession or access to the private key, excluding your 

cryptocurrency disclosed in Item 1, state the following: 

a. The type of cryptocurrency;

b. The amount of cryptocurrency and its current value;

c. The location and method of storage of the private keys necessary to exert control over the

cryptocurrency (e.g. third party custodian, web wallet, hardware wallet, personal computer,

handwritten document, etc.), and if applicable, the name and manufacturer of any software

or hardware storage methods;

d. Any public addresses or public keys associated with the cryptocurrency; and

e. The owners of the cryptocurrency and the percentage of ownership of each owner.

Initial: _______

Case 3:19-cv-04022-JD Document 52 Filed 08/28/19 Page 64 of 73
Page 3 of 6

Item 3.

List each person or entity to whom you, your spouse, or any of your dependents have transferred, in the 

aggregate, more than $5,000 worth of cryptocurrency, the value of the cryptocurrency transferred, the 

reason for the transfer, and the transfer date.

Case 3:19-cv-04022-JD Document 52 Filed 08/28/19 Page 65 of 73
Page 4 of 6

Initial: _______

Item 4.

List each person or entity from whom you, your spouse, or any of your dependents have received, in the 

aggregate, more than $5,000 worth of cryptocurrency, the value of the cryptocurrency transferred, the 

reason for the transfer, and the transfer date.

Case 3:19-cv-04022-JD Document 52 Filed 08/28/19 Page 66 of 73
Page 5 of 6

 Initial: _______

Item 5.

List all security interests held in any of your cryptocurrency disclosed in response to Item 1, the name

and address of the holder of the security interest, and the amount of the security interest, and the date 

the security interest was placed upon the the cryptocurrency.

Case 3:19-cv-04022-JD Document 52 Filed 08/28/19 Page 67 of 73
Page 6 of 6

 Initial: _______

I am submitting this financial statement with the understanding that it may affect action by the 

Federal Trade Commission or a federal court. I have used my best efforts to obtain the information 

requested in this statement. The responses I have provided to the items above are true and contain all 

the requested facts and information of which I have notice or knowledge. I know of the penalties for 

false statements under 18 U.S.C. § 1001, 18 U.S.C. § 1621, and 18 U.S.C. § 1623 (five years imprisonment 

and/or fines). I certify under penalty of perjury under the laws of the United States that the foregoing is 

true and correct.

Executed on: _________________ Signature: ____________________________________

 (Date) 

 Printed name: _________________________________

Case 3:19-cv-04022-JD Document 52 Filed 08/28/19 Page 68 of 73
Attachment F 

Request for Copy of Tax Return 

Case 3:19-cv-04022-JD Document 52 Filed 08/28/19 Page 69 of 73
Form 4506

(March 2019)

Department of the Treasury 

Internal Revenue Service 

Request for Copy of Tax Return

a Do not sign this form unless all applicable lines have been completed.

a Request may be rejected if the form is incomplete or illegible. 

a For more information about Form 4506, visit www.irs.gov/form4506.

OMB No. 1545-0429

Tip. You may be able to get your tax return or return information from other sources. If you had your tax return completed by a paid preparer, they 

should be able to provide you a copy of the return. The IRS can provide a Tax Return Transcript for many returns free of charge. The transcript 

provides most of the line entries from the original tax return and usually contains the information that a third party (such as a mortgage company) 

requires. See Form 4506-T, Request for Transcript of Tax Return, or you can quickly request transcripts by using our automated self-help service 

tools. Please visit us at IRS.gov and click on “Get a Tax Transcript...” or call 1-800-908-9946.

1a Name shown on tax return. If a joint return, enter the name shown first. 1b First social security number on tax return, 

individual taxpayer identification number, or 

employer identification number (see instructions) 

2a If a joint return, enter spouse’s name shown on tax return. 2b Second social security number or individual 

taxpayer identification number if joint tax return 

3 Current name, address (including apt., room, or suite no.), city, state, and ZIP code (see instructions) 

4 Previous address shown on the last return filed if different from line 3 (see instructions) 

5 If the tax return is to be mailed to a third party (such as a mortgage company), enter the third party’s name, address, and telephone number. 

Caution: If the tax return is being mailed to a third party, ensure that you have filled in lines 6 and 7 before signing. Sign and date the form once you 

have filled in these lines. Completing these steps helps to protect your privacy. Once the IRS discloses your tax return to the third party listed on line 

5, the IRS has no control over what the third party does with the information. If you would like to limit the third party's authority to disclose your return 

information, you can specify this limitation in your written agreement with the third party.

6 Tax return requested. Form 1040, 1120, 941, etc. and all attachments as originally submitted to the IRS, including Form(s) W-2, 

schedules, or amended returns. Copies of Forms 1040, 1040A, and 1040EZ are generally available for 7 years from filing before they are 

destroyed by law. Other returns may be available for a longer period of time. Enter only one return number. If you need more than one 

type of return, you must complete another Form 4506. a

Note: If the copies must be certified for court or administrative proceedings, check here . . . . . . . . . . . . . . .

7 Year or period requested. Enter the ending date of the year or period, using the mm/dd/yyyy format. If you are requesting more than 

eight years or periods, you must attach another Form 4506. 

8 Fee. There is a $50 fee for each return requested. Full payment must be included with your request or it will 

be rejected. Make your check or money order payable to “United States Treasury.” Enter your SSN, ITIN, 

or EIN and “Form 4506 request” on your check or money order. 

a Cost for each return . . . . . . . . . . . . . . . . . . . . . . . . . . . $ 

b Number of returns requested on line 7 . . . . . . . . . . . . . . . . . . . . . .

c Total cost. Multiply line 8a by line 8b . . . . . . . . . . . . . . . . . . . . . . $ 

9 If we cannot find the tax return, we will refund the fee. If the refund should go to the third party listed on line 5, check here . . . . .

Caution: Do not sign this form unless all applicable lines have been completed. 

Signature of taxpayer(s). I declare that I am either the taxpayer whose name is shown on line 1a or 2a, or a person authorized to obtain the tax return 

requested. If the request applies to a joint return, at least one spouse must sign. If signed by a corporate officer, 1 percent or more shareholder, partner, 

managing member, guardian, tax matters partner, executor, receiver, administrator, trustee, or party other than the taxpayer, I certify that I have the authority to 

execute Form 4506 on behalf of the taxpayer. Note: This form must be received by IRS within 120 days of the signature date.

Signatory attests that he/she has read the attestation clause and upon so reading 

declares that he/she has the authority to sign the Form 4506. See instructions. 

Sign 

Here 

Phone number of taxpayer on line 

1a or 2a 

F

Signature (see instructions) Date 

F

Title (if line 1a above is a corporation, partnership, estate, or trust) 

F

Spouse’s signature Date 

For Privacy Act and Paperwork Reduction Act Notice, see page 2. Cat. No. 41721E Form 4506 (Rev. 3-2019) 

50.00

Case 3:19-cv-04022-JD Document 52 Filed 08/28/19 Page 70 of 73
Form 4506 (Rev. 3-2019) Page 2 

Section references are to the Internal Revenue Code 

unless otherwise noted. 

Future Developments

For the latest information about Form 4506 and its 

instructions, go to www.irs.gov/form4506. 

Information about any recent developments affecting 

Form 4506, Form 4506-T and Form 4506T-EZ will be 

posted on that page. 

General Instructions 

Caution: Do not sign this form unless all applicable 

lines have been completed.

Purpose of form. Use Form 4506 to request a copy 

of your tax return. You can also designate (on line 5) 

a third party to receive the tax return. 

How long will it take? It may take up to 75 

calendar days for us to process your request. 

Tip. Use Form 4506-T, Request for Transcript of Tax 

Return, to request tax return transcripts, tax account 

information, W-2 information, 1099 information, 

verification of nonfiling, and records of account. 

Automated transcript request. You can quickly 

request transcripts by using our automated self-help 

service tools. Please visit us at IRS.gov and click on 

“Get a Tax Transcript...” or call 1-800-908-9946. 

Where to file. Attach payment and mail Form 4506 

to the address below for the state you lived in, or the 

state your business was in, when that return was 

filed. There are two address charts: one for 

individual returns (Form 1040 series) and one for all 

other returns. 

If you are requesting a return for more than one 

year or period and the chart below shows two 

different addresses, send your request to the 

address based on the address of your most recent 

return. 

Chart for individual returns 

(Form 1040 series) 

If you filed an 

individual return 

and lived in: 

Mail to: 

Alabama, Kentucky, 

Louisiana, Mississippi, 

Tennessee, Texas, a 

foreign country, American 

Samoa, Puerto Rico, 

Guam, the 

Commonwealth of the 

Northern Mariana Islands, 

the U.S. Virgin Islands, or 

A.P.O. or F.P.O. address 

Internal Revenue Service 

RAIVS Team 

Stop 6716 AUSC 

Austin, TX 73301 

Alaska, Arizona, 

Arkansas, California, 

Colorado, Hawaii, Idaho, 

Illinois, Indiana, Iowa, 

Kansas, Michigan, 

Minnesota, Montana, 

Nebraska, Nevada, New 

Mexico, North Dakota, 

Oklahoma, Oregon, 

South Dakota, Utah, 

Washington, Wisconsin, 

Wyoming 

Internal Revenue Service 

RAIVS Team 

Stop 37106 

Fresno, CA 93888 

Connecticut, 

Delaware, District of 

Columbia, Florida, 

Georgia, Maine, 

Maryland, 

Massachusetts, 

Missouri, New 

Hampshire, New Jersey, 

New York, North 

Carolina, Ohio, 

Pennsylvania, Rhode 

Island, South Carolina, 

Vermont, Virginia, West 

Virginia 

Internal Revenue Service 

RAIVS Team 

Stop 6705 S-2 

Kansas City, MO 

64999

Chart for all other returns 

If you lived in 

or your business 

was in: 

Mail to: 

Alabama, Alaska, 

Arizona, Arkansas, 

California, Colorado, 

Connecticut, Delaware, 

District of Columbia, 

Florida, Georgia, Hawaii, 

Idaho, Illinois, Indiana, 

Iowa, Kansas, Kentucky, 

Louisiana, Maine, 

Maryland, 

Massachusetts, 

Michigan, Minnesota, 

Mississippi, 

Missouri, Montana, 

Nebraska, Nevada, New 

Hampshire, New Jersey, 

New Mexico, New York, 

North Carolina, 

North Dakota, Ohio, 

Oklahoma, Oregon, 

Pennsylvania, Rhode 

Island, South Carolina, 

South Dakota, 

Tennessee, Texas, Utah, 

Vermont, Virginia, 

Washington, West 

Virginia, Wisconsin, 

Wyoming, a foreign 

country, American 

Samoa, Puerto Rico, 

Guam, the 

Commonwealth of the 

Northern Mariana 

Islands, the U.S. Virgin 

Islands, or A.P.O. or 

F.P.O. address 

Internal Revenue Service 

RAIVS Team 

P.O. Box 9941 

Mail Stop 6734 

Ogden, UT 84409 

Specific Instructions 

Line 1b. Enter your employer identification number 

(EIN) if you are requesting a copy of a business 

return. Otherwise, enter the first social security 

number (SSN) or your individual taxpayer 

identification number (ITIN) shown on the return. For 

example, if you are requesting Form 1040 that 

includes Schedule C (Form 1040), enter your SSN. 

Line 3. Enter your current address. If you use a P.O. 

box, please include it on this line 3.

Line 4. Enter the address shown on the last return 

filed if different from the address entered on line 3. 

Note: If the addresses on lines 3 and 4 are different 

and you have not changed your address with the 

IRS, file Form 8822, Change of Address. For a 

business address, file Form 8822-B, Change of 

Address or Responsible Party — Business.

Signature and date. Form 4506 must be signed and 

dated by the taxpayer listed on line 1a or 2a. The 

IRS must receive Form 4506 within 120 days of the 

date signed by the taxpayer or it will be rejected. 

Ensure that all applicable lines are completed before 

signing. 

F!

CAUTION

You must check the box in the 

signature area to acknowledge you 

have the authority to sign and request 

the information. The form will not be 

processed and returned to you if the box is 

unchecked.

Individuals. Copies of jointly filed tax returns may 

be furnished to either spouse. Only one signature is 

required. Sign Form 4506 exactly as your name 

appeared on the original return. If you changed your 

name, also sign your current name. 

Corporations. Generally, Form 4506 can be 

signed by: (1) an officer having legal authority to bind 

the corporation, (2) any person designated by the 

board of directors or other governing body, or (3) 

any officer or employee on written request by any 

principal officer and attested to by the secretary or 

other officer. A bona fide shareholder of record 

owning 1 percent or more of the outstanding stock 

of the corporation may submit a Form 4506 but must 

provide documentation to support the requester's 

right to receive the information.

Partnerships. Generally, Form 4506 can be 

signed by any person who was a member of the 

partnership during any part of the tax period 

requested on line 7. 

All others. See section 6103(e) if the taxpayer has 

died, is insolvent, is a dissolved corporation, or if a 

trustee, guardian, executor, receiver, or 

administrator is acting for the taxpayer. 

Note: If you are Heir at law, Next of kin, or 

Beneficiary you must be able to establish a material 

interest in the estate or trust.

Documentation. For entities other than individuals, 

you must attach the authorization document. For 

example, this could be the letter from the principal 

officer authorizing an employee of the corporation or 

the letters testamentary authorizing an individual to 

act for an estate. 

Signature by a representative. A representative 

can sign Form 4506 for a taxpayer only if this 

authority has been specifically delegated to the 

representative on Form 2848, line 5a. Form 2848 

showing the delegation must be attached to Form 

4506. 

Privacy Act and Paperwork Reduction Act 

Notice. We ask for the information on this form to 

establish your right to gain access to the requested 

return(s) under the Internal Revenue Code. We need 

this information to properly identify the return(s) and 

respond to your request. If you request a copy of a 

tax return, sections 6103 and 6109 require you to 

provide this information, including your SSN or EIN, 

to process your request. If you do not provide this 

information, we may not be able to process your 

request. Providing false or fraudulent information 

may subject you to penalties. 

Routine uses of this information include giving it to 

the Department of Justice for civil and criminal 

litigation, and cities, states, the District of Columbia, 

and U.S. commonwealths and possessions for use 

in administering their tax laws. We may also 

disclose this information to other countries under a 

tax treaty, to federal and state agencies to enforce 

federal nontax criminal laws, or to federal law 

enforcement and intelligence agencies to combat 

terrorism. 

You are not required to provide the information 

requested on a form that is subject to the Paperwork 

Reduction Act unless the form displays a valid OMB 

control number. Books or records relating to a form 

or its instructions must be retained as long as their 

contents may become material in the administration 

of any Internal Revenue law. Generally, tax returns 

and return information are confidential, as required 

by section 6103. 

The time needed to complete and file Form 4506 

will vary depending on individual circumstances. The 

estimated average time is: Learning about the law 

or the form, 10 min.; Preparing the form, 16 min.; 

and Copying, assembling, and sending the form 

to the IRS, 20 min. 

If you have comments concerning the accuracy of 

these time estimates or suggestions for making 

Form 4506 simpler, we would be happy to hear from 

you. You can write to: 

Internal Revenue Service 

Tax Forms and Publications Division 

1111 Constitution Ave. NW, IR-6526 

Washington, DC 20224. 

Do not send the form to this address. Instead, see 

Where to file on this page. 

Case 3:19-cv-04022-JD Document 52 Filed 08/28/19 Page 71 of 73
Attachment G 

Consent to Release Financial Records 

Case 3:19-cv-04022-JD Document 52 Filed 08/28/19 Page 72 of 73
CONSENT TO RELEASE FINANCIAL RECORDS 

 I, __________________________of _______________________, (City, 

State), do hereby direct any bank, saving and loan association, credit union, 

depository institution, finance company, commercial lending company, credit card 

processor, credit card processing entity, automated clearing house, network 

transaction processor, bank debit processing entity, automated clearing house, 

network transaction processor, bank debit processing entity, brokerage house, 

escrow agent, money market or mutual fund, title company, commodity trading 

company, trustee, or person that holds, controls, or maintains custody of assets, 

wherever located, that are owned or controlled by me or at which there is an 

account of any kind upon which I am authorized to draw, and its officers, 

employees, and agents, to disclose all information and deliver copies of all 

documents of every nature in its possession or control which relate to the said 

accounts to any attorney of the Federal Trade Commission, and to give evidence 

relevant thereto, in the matter of Federal Trade Commission v. AH Media Group, 

LLC, et al., now pending in the United States District Court of the Northern 

District of California, and this shall be irrevocable authority for so doing. 

 This direction is intended to apply to the laws of countries other than the 

United States of America which restrict or prohibit disclosure of bank or other 

financial information without the consent of the holder of the account, and shall be 

construed as consent with respect hereto, and the same shall apply to any of the 

accounts for which I may be a relevant principal. 

Dated:_______________ Signature:_____________________________ 

 Printed Name:__________________________ 

Case 3:19-cv-04022-JD Document 52 Filed 08/28/19 Page 73 of 73