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DAVID C. SHONKA

Acting General Counsel

SARAH SCHROEDER, Cal. Bar No. 221528 

ROBERTA TONELLI, Cal. Bar No. 278738 

EVAN ROSE, Cal. Bar No. 253478 

Federal Trade Commission

901 Market Street, Suite 570 

San Francisco, CA 94103 

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

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

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

OAKLAND DIVISION

FEDERAL TRADE COMMISSION, 

 Plaintiff,

 vs. 

AMERICAN FINANCIAL BENEFITS 

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

STUDENT SERVICES; 

AMERITECH FINANCIAL, a corporation; 

 

FINANCIAL EDUCATION BENEFITS 

CENTER, a corporation; and

BRANDON DEMOND FRERE, individually 

and as an officer of AMERICAN FINANCIAL 

BENEFITS CENTER, AMERITECH 

FINANCIAL, and FINANCIAL EDUCATION 

BENEFITS CENTER,

 

 Defendants. 

 

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

DECLARATION OF MILTON 

MARSHALL IN SUPPORT OF 

FEDERAL TRADE COMMISSION’S 

MOTION FOR PRELIMINARY 

INJUNCTION

Case 4:18-cv-00806-SBA Document 37 Filed 03/02/18 Page 1 of 5

DECLARATION OF MILTON MARSHALL IN SUPPORT OF FEDERAL TRADE 

COMMISSION’S MOTION FOR PRELIMINARY INJUNCTION

 4:18-CV-00806-SBA
Marshall Declaration - Page 1 

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DECLARATION OF MILTON MARSHALL 

1. My name is Milton Marshall and I am an honorably discharged, disabled U.S. 

Navy veteran. I reside in Las Vegas, Nevada. The following statements are within my personal 

knowledge and if called as a witness I could and would competently testify thereto. 

2. In 2003, I graduated from California State University – Los Angeles with a 

Bachelor of Arts in Child Development. In 2010, I earned a Master’s degree in Education from 

Loyola Marymount University. I owe around $92,000 in student loans, mostly related to 

expenses from my Master’s degree. I currently work for Veterans Affairs. 

3. On or around March 10, 2015, I became concerned that I would be unable to 

make my student loan payments, which were approximately $960 per month. Around this time, I

think I received a solicitation from a company called American Financial Benefits Center 

(“AFBC”), but do not recall the details. I remember visiting AFBC’s website in spring 2015. 

4. On or around March 2015, I called AFBC and spoke with a company 

representative. The representative told me I qualified for an income-based repayment program 

(“IBR program”), which would reduce the amount of my student loan to $0. The AFBC 

representative told me that AFBC would enroll me in the IBR program if I paid AFBC a $95 

processing fee and a $1,200 program fee. I did not know that I could apply for the IBR program 

directly through my loan servicer. The AFBC representative also told me that the U.S. 

government would forgive my entire loan balance after 10 years if I continued to work for 

Veterans Affairs. However, the representative neglected to tell me that my loan would still 

accrue interest during those 10 years. 

5. I initially believed that AFBC was affiliated with the government, or at least 

sanctioned by the government, because the representative told me I qualified for a government 

program and seemed very knowledgeable. 

6. In March 2015, AFBC sent me numerous documents via email and instructed me 

to sign them electronically through a program called DocuSign. The material was 

overwhelming. A true and correct copy of the material AFBC sent me, with my personal 

information redacted, is attached as Marshall Attachment A. The documents in Marshall 

Case 4:18-cv-00806-SBA Document 37 Filed 03/02/18 Page 2 of 5
Marshall Declaration - Page 2 

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Attachment A are not necessarily in the order AFBC provided them to me. I signed, scanned, 

and emailed the documents back to AFBC. I found the forms overwhelming, especially the 

lengthy forms with small print, and did not read them all. On March 10, 2015, I signed 

additional documents that AFBC emailed me to consolidate my student loans. 

7. After I signed the material that AFBC sent me, I contacted AFBC to inquire when 

my payments to the company would begin. On April 8, 2015, an AFBC customer service 

representative named Nicole Williams sent me the following response: “We received your 

inquiry about your payment draft. The first payment does take a bit longer to process as the bank 

and merchant have to match up. Your payment was drafted on the 3rd of April and is currently 

pending. It should go through by the end of the week.” A true and correct copy of Ms. 

Williams’ April 8, 2015 email to me is attached as Marshall Attachment B. 

8. On April 3, 2015, AFBC debited funds directly from my checking account. After 

I began paying AFBC, I worked with several AFBC representatives to consolidate my student 

loans and submit an application for the IBR program. AFBC sent me forms that I signed, 

scanned, and emailed back to AFBC. Sometimes AFBC sent me forms to sign with information 

fields to be left blank. I did not know the particulars of the forms and trusted AFBC to take care 

of everything. AFBC consolidated my loans with a new lender, FedLoans, and told me my 

monthly loan payment was $0. AFBC also told me not to correspond with FedLoans. 

9. From May 3, 2015 to October 3, 2016, AFBC withdrew $147.70 per month 

directly from my checking account. From November 2016 to March 2017, AFBC withdrew 

$47.70 monthly from my checking account. I do not recall AFBC representatives telling me that 

my funds were being held in an escrow account or were refundable. I understood that these 

payments went to the program fee and I assumed that after I paid the $1,200 program fee, any 

funds that AFBC withdrew were going towards my loan balance. 

10. Around March 2016, AFBC asked me to submit documents showing my current 

income. I had to submit the material twice because AFBC lost the documents. A true and 

correct copy of my April 6, 2016 email to AFBC is attached as Marshall Attachment C. In the 

Case 4:18-cv-00806-SBA Document 37 Filed 03/02/18 Page 3 of 5
Marshall Declaration - Page 3 

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email, I told AFBC the following: “This is the second time I submitted these documents. Please 

don’t loose these.” 

11. In fall 2016, I became concerned about my loan and contacted my loan servicer, 

FedLoans. A FedLoans agent told me that I could have done the modification myself for free 

and recommended that I contact the Federal Trade Commission to report AFBC’s practices. The 

agent also told me that my loan amount was increasing instead of decreasing, which I found 

confusing because I believed AFBC was submitting loan payments to my lender. I did not know 

what to do and was confused about my payments to AFBC. I continued to let AFBC withdraw 

funds from my checking account because I did not want to my loan to go into default. 

12. On or around November 10, 2016, I called the Federal Trade Commission’s 

complaint hotline and shared my concerns about AFBC. Specifically, I complained that AFBC 

had taken $2,500 from my account and made no payments towards my student loan. 

13. In January 2017, I reviewed my contract with AFBC and noticed that AFBC 

charged me a $600 fee and a monthly $47.70 fee, in addition to the $1,200 program fee and $95 

processing fee. I was shocked to discover these separate fees, which AFBC slipped right past 

me. I have no idea why AFBC charged me $600 or $47.70 per month. I hired AFBC to lower 

my monthly loan payments and did not purchase any other service from the company. I do not 

recall receiving any DVDs, CDs, books, or other material from AFBC. 

14. From late 2016 until spring 2017, AFBC contacted me numerous times asking for 

access to my online account with my loan servicer. The AFBC representative asked for my login 

ID and password, but I was concerned about AFBC’s practices and did not provide the 

information. In March 2017, I tried to log into my account with my loan servicer, but my 

password did not work. 

15. AFBC deceived me about its fees. The company also led me to believe that the 

money I paid AFBC was going towards my student loan. I am also concerned about possibly 

fraudulent statements that AFBC make on my loan modification applications without my 

knowledge. Because of AFBC’s actions, my loan amount has increased and AFBC has taken 

over $2,800 from me. 

Case 4:18-cv-00806-SBA Document 37 Filed 03/02/18 Page 4 of 5
1 16. I declare under penalty of perjury that the foregoing is true and correct. Executed 

('\ c .. Jt. . on J.-,:, __ r-: j .....,(_, l 2017, m Nevada. 

' ';l vltJ,c 1, } 1[ AA"l~ l 

Milton Marshall 

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Marshall Declaration - Page 4 

Case 4:18-cv-00806-SBA Document 37 Filed 03/02/18 Page 5 of 5
Marshall Attachment A

Case 4:18-cv-00806-SBA Document 37-1 Filed 03/02/18 Page 1 of 24
AFB (~enter 

American Financial Benefits Center 

3 l l Professional Center Drive #-200 

Rohnert Park, CA 94928 

Na Client#: 

Address: Home Phone: 

City, State, Zip Las Vegas NV 89119 Other Phone: 

Date: 3/9/2015 

Thank you for contacting American Financial Benefits Center. Based on the information you have 

provided to our company, we believe that you may qualify for one or more student loan assistance 

programs offered by the U.S. Department of Education. American financial Benefits Center ("AfiBC") 

is a privately owned company that helps consumers like you identify programs that may be suitable fo r 

their situalion, ga:rher their relevant appli<.:ation documems, then assist them by preparing those documents 

for review and submission. AFBC also offers its own great programs to further assist with you with your 

:financial situation. To begin, we need the following information from you: 

I. Please carefully read the enclosed Agreement, and make sure that all pages arc signed and 

dated wb.ere ind icated. 

2. Please provide your National Student Loan Data System personal identification number 

(''PIN"), or yow· most cw-rent student loan servicer account statement(s). 

3. Please provide a copy of a voided check, along with the attached ACH Authorization Forms, 

signed by the account holder who is remitting the program payment. 

4. After you have faxed your documents, or provided your PIN, please contact AFBC at l-&00-

488-1490 ext. '0' and speak to a Client Services Representative to verify all documentation 

has been rece ived. You may also email your documentation to: income.doc@afbcenter.com 

5. Be sure to retain a copy of all documents for your records. 

Due to the importance of this material and so we may start working fo r you as soon as possible, return 

these documents and provide your PIN to American Financial Benefits Center via fax, email, or mail to 

311 Professional Center Drive #200, Rohnert Park, CA 94928, as soon as possible. 

1f you have any questions when reviewing the attached documents, please feel free to contact your 

American Financial Benefits Center Client Services Representative at 1-800-488-1490. 

Main Telephone: (800) 488- l 490 

Fax: (707) 222-5200 , (707) 222-5300 

Website: www .afbcenter.com 

Documents: income.doc@afbcenter.com 

E-mail: info@atbcenter.co m 

Client Signature Date: 3/9/2015 

Marshall Attachment A - 1 

Case 4:18-cv-00806-SBA Document 37-1 Filed 03/02/18 Page 2 of 24
American Financial Benefits Center 

Document Preparation and Service Agreement 

This Service Agreement is entered into on the date shown below between the American Financial 

Benefits Center, Inc. (AFBC) and the Client shown below (Client). 

AFBC provides processing and support services to assist consumers who are applying for Federal Student 

Loan Consolidation Services, and/or other repayment plan programs available through the Department of 

Education (DOE). AFBC is a private company, not affiliated with any government agency, and for a fee 

AFBC will assist in assembly and submission of student loan consolidation, and/or other repayment plan 

program documents. AFBC is not a lender or a debt consolidation company. 

Client requests AFBC to perform, in good faith, the following services, ("the Services"): (a) Performing a 

review of the Client's current Federal Student Loan debt situation, (b) Identify potential Student Loan 

Consolidation, and/or other repayment plan options that may be available to Client from the DOE, (c) 

Discuss potential options with the Client, and (d) After Client selects an option, prepare and process, on 

the Client's behalf, a Federal Student Loan Consolidation Application, and/or other repayment plan 

program application with the DOE. 

Now therefore in consideration of the foregoing and every term, covenant and condition hereafter set 

forth, AFBC and Client do hereby understand, covenant and agree to the following: 

l. Provide Complete and Truthful Information. AFBC will provide Client with an overview session 

limited to their Federal Student Loan debts to assist the Client in locating options that may be available to 

them. Client expressly represents and warrants that he/she/they will at all times provide AFBC with 

information that is complete, accurate and true to the best of their knowledge and belief. 

2. Performance of Services. Upon receipt of all information from Client, AFBC shall promptly analyze 

Client's Federal Student Loan debt situation, review the information provided by the Client, and complete 

the application forms required for the DOE program(s) that have been selected by the Client. Upon 

completion of AFBC's review and due diligence, AFBC shall prepare for filing with Client's lender an 

application to initiate a Federal Student Loan Consolidation, and/or other repayment plan available to 

Client through the DOE on behalfofClient. 

3. Fees for Services. The cost of the program for a client enrolling is $ GOO and is split into a 

monthly payment option as indicated in the attached form. The fee shall be debited from Client's bank 

account specified on the attached Electronic Funds (EFT) Authorization. AFBC will use a third party 

payment processor to debit Client for fee and Client shall pay all processing fees associated with such. 

AFBC's services shall be complete upon AFBC completing its review and providing an application 

packet to the Client. 

4. Documents Service Agreement and Monthly Cost Authorization. AFBC will use a third party payment 

processor to debit Client for fees/payments and Client shall pay all processing fees associated with such. 

Client herby authorizes AFBC to deduct all payments due per this contract from the financial institution 

listed in the Electronic Funds (EFT) Authorization or such other financial institution that may be used by 

Client from time to time. Further, Client authorizes .their financial institution to accept and to charge any 

debit entries initiated by American Financial Benefits Center to Client's account. This authorization for 

automatic withdrawal of fees/payments is to remain in full force and effect until AFBC has received 

written notice from Client of its termination in such time and such manner as to afford AFBC a 

reasonable opportunity to act. A fee/payment (whether paid by debit or other means) that is not honored 

Marshall Attachment A - 2 

Case 4:18-cv-00806-SBA Document 37-1 Filed 03/02/18 Page 3 of 24
by Client's financial institution for any reason may be subject to a $20.00 service fee imposed by AFBC 

(unless otherwise limited or prohibited by state law), the amount of which may be debited from Client's 

account. 

5. Limited Money Back Guarantee. AFBC guarantees that Client will receive a Federal Student Loan 

Consolidation, or other repayment plan program available to client through the Department of Education 

subject to the following conditions: ( 1) student loans that Client presents to AFBC are original debts, and 

have not been previously consolidated or had their te1ms or amow1ts previously adjusted; (2) Client full 

cooperates, is honest and timely in providing all infom1ation requested by AFBC and DOE; and/or (3) 

Client does not possess a characteristic that pursuant to DOE rules would disqualify Client from receiving 

a consolidation. If a Client is not approved for a Federal Student Loan Consolidation, or any other 

repayment plan program available to client through the DOE, after reasonable efforts by the parties, then 

AFBC will reimburse the Consolidation Fee Payment (payment made to AFBC in Section 3, above). All 

refund requests must be.made, in writing, to AFBC within 30 days of any denial by the DOE. 

6. Process. Once paperwork has been received, processing will begin. AFBC will always act promptly on 

Client's documents and program. Be advised that Federal Student Loan Consolidations, and other 

repayment plans completed by AFBC rely on the relevant lenders for prompt service and AFBC cannot be 

held liable for delayed completion. Average completion of a Federal Student Loan Consolidation through 

the DOE is usually ninety (90) days, but may take longer. AFBC solely prepares and provides documents 

for submission, and does not control the DOE application review process. 

7. Indemnification and Hold Harmless. Client hereby agrees to defend and hold harmless AFBC from and 

against any claims and liability of any nature whatsoever arising out of or in connection with Client's 

failure to timely provide requested information to AFBC, Client's lack of authority or ability.to complete 

terms of this Agreement, and all other claims arising out of this Agreement or relating to Client's Joans 

and other financial obligations. This Agreement constitutes the entire agreement between the parties. 

AFBC makes no warranty, express or implied, as to the fitness of any recommendation it may make to 

Client arising out of this Agreement. Except for cause, Client unconditionally waives any right of action 

against AFBC, its officers, directors, employees, agents, brokers and assignees, at law, equity or any other 

cause of action for any reason, directly, indirectly or proximately believed to arise out of this Agreement, 

for any damages of any nature whatsoever that Client may incur by reason of Client following any 

recommendation of AFBC or Client's failure to follow any recommendation of AFBC, whether any 

singular, concurrent or series of recommendations are acted upon or not acted upon in whole or in part by 

Client. This section shall survive any termination of this Agreement. 

8. Important Limitation on Consumer Rights - Mandatory Arbitration Requirement - Please read 

carefully: In the event of any controversy, claim or dispute between the parties arising out of or relating to 

this agreement or the breach, termination, enforcement, interpretation, consionability or validity thereof, 

including any determination of the scope or applicability of this agreement to arbitrate, shall be 

determined by arbitration in Sonoma County, California or in the county in which the consumer resides, 

in accordance with the Laws of the State of California for agreements to be made in and to be performed 

in California. The parties agree that the arbitration shall be administered by the American Arbitration 

Association ("AAA") pursuant to its rules and procedures and an arbitrator shall be selected by the AAA. 

The arbitrator shall be neutral and independent and shall comply with the AAA code of ethics. The award 

rendered by the arbitrator shall be final and shall not be subject to vacation or modification. Judgment on 

the award made by the arbitrator may be entered in any court having jurisdiction over the parties. If either 

party fails to comply with the arbitrator's award, the injured party may petition the circuit court for 

enforcement. The parties agree that either party may bring claims against the other only in his/her or its 

individual capacity and not as a plaintiff or class member in any purported class or representative 

proceeding. Further, the parties agree that the arbitrator may not consolidate proceedings of more than 

one person's claims, and may not otherwise preside over any fonn of representative or class proceeding. 

The parties shall share the cost (not attorneys' fees) of arbitration equally. In the event a party fails to 

proceed with arbitration, unsuccessfully challenges the arbitrator's award, or Jails to comply with the 

arbitrator's award, the other party is entitled to costs of suit, including a reasonable attorney's fee for 

Marshall Attachment A - 3 

Case 4:18-cv-00806-SBA Document 37-1 Filed 03/02/18 Page 4 of 24
having to compel arbitration or defend or enforce the award. Binding Arbitration means that both parties 

give up the right to a trial by a jury. It also means that both parties give up the right to appeal from the 

arbitrator's ruling except for a narrow range of issues that can or may be appealed. It also means that 

discovery may be severely limited by the arbitrator. This section and the arbitration requirement shall 

survive any tennination. OPT-OUT PROCESS: You may choose to opt-out of this Arbitration Provision 

but only by following the process set-forth below. If you do not wish to be subject to this Arbitrat ion 

Provision, then you must notify us in writing within thirty (30) calendar days of the date of this 

Agreement at the following address: AFBC, Attn: Customer Service, 311 Professional Center Drive #20'0 

Rohnert Park, CA 94928. Your written notice must include your name, address, the date of this 

Agreement, and a signed statement that you wish to opt out of the Arbitration Provision. If you choose to 

opt out, then your choice will apply only to this Agreement. 

9. Entire Agreement. By virtue of Client's signature below, Client acknowledges that he/she has read, 

understands and agrees to every term, covenant and condition of this Agreement and that he/she has 

received a true and complete copy hereof, effective on the date below. This agreement is the only 

agreement between the parties and there is no other collateral agreement (oral or written) between the 

parties in any manner relating to the subject matter of this agreement. If any portion of this agreement is 

held to be invalid or unenforceable, the remaining provisions will remain in effect. The parties mutually 

understand and agree that a facsimile copy signature or an electronic signature on this agreement shall be 

deemed an original for all lawfully enforceable purposes. 

10. Cancellation Policy - I, the Client, may cancel this contract at any time prior to being approved for a 

Federal Student Loan Consolidation, or any other Department of Education repayment pl<!,n option 

achieved on Client's behalf, and receive a full refund. 

11. Limitations on Damages: AFBC's liability tm.der this agreement and/or relating directly or indirectly 

to Client's participation in the Student Loan Consolidation Program, under any theory of liability 

regarding any claim by the Client is limited to the amount of fees paid by Client to AFBC. The Parties 

agree to be contractually bound to such limitation on any damages, and agree not to demand or attempt to 

recover any amount in excess of such. This section shall survive termination. 

12. Information Authorization: I hereby authorize AFBC to verify my past present employment earnings 

records, bank accounts, stock holdings, and any other asset balances that are needed to process my 

Federal Student Loan Consolidation, and/or other repayment plan program available to client. The 

information AFBC obtains is only to be used in the processing of my application for a Federal Student 

Loan Consolidation or any other repayment plan program through the DOE, and AFBC does not provide 

any form of credit repair, credit score enhancement, or debt relief. 

13. Legal Authorization Form: This form will serve to acknowledge that tbe below Student Loan 

borrower has authorized our company, American Financial Benefits Center (AFBC) to act on tbeir behalf 

to apply for consolidation of their Federal Student Loans, and/or other repayment plan programs available 

to client. Client has been advised that once approved for the Federal Student Loan Consolidation, and/or 

other repayment plan program, the Client will receive a sixty (60) day furlough before payments will 

start. If you have any questions regarding this Federal Student Loan Consolidation Program, please 

contact AFBC at l-800-488-1490. 

BY SIGNING BELOW(ELECTRONICALL Y OR PHYSICALLY), I HEREBY ACKNOWLEDGE 

THAT I HA VE NOT BEEN ADVISED BY AMERICAN FINANCIAL BENEFITS CENTER, ANY 

OF ITS AGENTS, AND/OR AFFILIATES TO FOREGO A STUDENT LOAN PAYMENT IN 

EXCHANGE FOR THE GOOD FAITH PAYMENT AND FEDERAL STUDENT LOAN 

CONSOLIDATION PROGRAM. DURING THIS PROCESS, CLIENT IS RESPONSIBLE FOR 

MAKING HIS OR HER PAYMENTS, AND FAILURE TO DO SO COULD DISQUALIFY THE 

CLIENT FROM OBTAINING THE SERVICE THAT WAS AGREED UPON. I FURTHER 

ACKNOWLEDGE THAT NO GUARANTEES CONCERNING THE SUCCESS OF THE LOAN 

Marshall Attachment A - 4 

Case 4:18-cv-00806-SBA Document 37-1 Filed 03/02/18 Page 5 of 24
CONSOLTDA TIO HA VE BEEN PROVIDED TO l'vffi/US BY AMERlCAN FINANCIAL BENEFITS 

CENTER, AND/OR ANY OF 1TS AGENTS, AND/OR AFFILIATES AND A POSITIVE OUTCOME 

IS NOT GUARANTEED. f, THE CONSUMER, HAVE BEEN EXPLAINED THE PROGRAM IN 

FULL AND TO MY SATISFACTION. 

3/9/2015 Date executed: _ ________ _________ _ 

For: Client 

SSN: 

Print Name~~~~~~~'._ ____________ _ 

DOB:-/ _________ / _______ _ 

For: American Financial Benefits Center ("AFBC") 

Title: Managing Director 

Marshall Attachment A - 5 

Case 4:18-cv-00806-SBA Document 37-1 Filed 03/02/18 Page 6 of 24
American Financial Benefits Center Document Preparation and Service Agreement Program Enrollment 

Electronic Funds Transfer (EFT) Authorization 

Authorized Company to Dehit Account: Company Name: American Finllncial Benefits Center 

Account Holder's Information: Accmmt Holder's 

Name: 

Billing Streef Address: --

-=---= - ----= - - --- -. 

Las vegas City, State, Zip: NV 89119 

Accollnt Holder's Bank Information: 

,:i 2nsr,7aq,: 12 l I Z3~5Gl' 000 I 

L I I l l L -C::..chack Num

Atoount Number 

Routing HI.Dllber 

Payment Information 

Bank Name: 

ber Routing Number 

(9 Digits): 

Account Number: -

-

x Checking Savings Checking or Savings: 

$ 600 

Total Amount: 

DMft #l Drttft #2 ' Draft #3 

Dra.ftl.Jate 2016-0S-03 2016- 06- 03 2016-07-03 

Draft Amount 100 100 100 

Draft #4 Draft #5 Drcdt #6 

DrajtDate 2016-08- 03 2016- 09- 03 2016-10-03 

Draft Amoun 100 100 t 100 

Authorization: 

I hereby authorize American Financial Benefits Center ("AFBC") to debit the Bank Account referenced herein, via an 

Automated Clearing House (ACH) system, according to the parameters specified herein for my American Financial 

Benefits Center Student Loan Document Preparation and Service Agreement. If you have questions about your 

payment, please contact AFBC at 1-800-488- 1490, or 311 Professional Center Drive 200, Rohnert Park, CA 94928. 

This authority will remain in effect until the payment is completed as specified herein. If a payment is returned for any 

reason I acknowledge that I am subject to a rejected item fee of$20 or the maximum amount allowed by law in addition 

to any charges made by my bank . 

-

.... 3/9/2015 

Account Holder's Authorized Signature Date 

***Please retain a copy of this doc11ment as your receipt of purchase*** 

Marshall Attachment A - 6 

Case 4:18-cv-00806-SBA Document 37-1 Filed 03/02/18 Page 7 of 24
Financial Education & Resource Center Program Enrollment & AFBC Student Financial Management Plan 

Congratulations! We are excited that you have taken the first step in improving your finances through our Financial 

Analysis & Evaluation, AFBC Student Financial Management Plan, and your enrollment into our Financial Education and 

Resourc_e Ce~ter :rogr~m becau~e getting the right tools and education will save you time and money. We believe that by 

purchasing this Fmanc1al Education and Resource Center Program and Student Financial Management Plan, that you have 

taken the first steps in making a change in your financial life. These financial tools were built on proven strategies, methods, 

and exercises that we've coupled with our Financial Education & Resource Center Program, to help you to begin achieving 

financial independence today and to give you the greatest opportunity for improving your financial position forever. 

Authorization & Refund Policy: I hereby authorize American Financi~l Benefits Center to debit the credit card(s), or bank 

account(s) listed below for the amounts stated on the draft dates herein. This authority shall remain in effect until American 

Financial Benefits Center has received the full purchase amount. If a payment is declined by your credit card company or 

bank, American Financial Benefits Center may attempt to again process this payment at a later date, typically within 72 hours. 

No products will be shipped or provided until payment is confirmed. I, the Buyer, fully understand I am purchasing an 

American Financial Benefits Center Student Financial Management Plan and enrolling into the Financial Education and 

Resource Center Program through American Financial Benefits Center. The company has the right to substitute the primary 

product(s) with an alternative product(s) of equal value. All transactions will appear on your credit card, or bank s1atement(s) 

as "AFBC." American Financial Benefits Center offers a 100% Satisfaction Guarantee or your money back for those 

customers who request in writing within 30 days from the date of purchase. Thereafter customers may also request a refund up 

to 90 days from the date of purchase however American Financial Benefits Center reserves the right to determine a reasonable 

refund amount If you have any questions about your payment, please contact us directly at 1-800-488-1490, or 311 

Professional Center Drive 200, Rohnert Park, CA 94928. 

Your Financial Education & Resource Center Program & AFBC Student Financial Management Plan Includes: 

• 

• 

l-on-1 P rogram Consultation: what to expec1 from our products and services. 

Access to The Student Loan Financial Education Resource Center: stay regularly informed of student loan 

• 

benefits that may be available to you through OLlr online educational resource portal. 

Access to Ongoing Document Preparation Seryices: at your request, we will prepare and submit documents to 

• your student loan service provider on your behalf to reflect any changes in your situation. 

• 

Access to Official Forms and Documents: a library of important document~ anrl forms at your fingertips! 

Access to Dozens of Printable Legal Documents and Templates: lease agreements, bills of sale, house titles-

• 

and much more! You'll receive access to our ever-growing document archive. 

Resume and Cover Letter Documentation: several professional resume and cover letter templates are a1 your 

• disposal, helping you to be even more competitive in the job market. 

• 

Tools for Keeping a Budget: You'll receive access to the budgetary tools that catt:r most to your lifestyle. 

Access to Dozens of Infonnatioual & Useful Web links: From legal document databitses to tax and mortgage 

• 

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Buyer's full Name : 

Spouse's full f'lame (if applicable) : 

Buyer's Best Contact Phone Number: 

AFBC Financial Education & R.csource Center Program Enrollment 

& AFBC Student Financial Management Plan Charge: 1295 

Marshall Attachment A - 7 

Case 4:18-cv-00806-SBA Document 37-1 Filed 03/02/18 Page 8 of 24
Financial Education & Resource Center Program Enrollment & AFBCStudent Financial Management Plan 

Authorized Company to Debit Account: 

Account Holder's lrzfomzatior,: 

C1 ·t y, s tate, Zi p: _Las __Vegas ___ NV _ _ __89119 __ _ 

Account Holder's Bank Information: En ro 11 ment r=ee Amount: $95 

Enrol l ment Fee Date: 2015-04-03 

BankName: 

•:l2

L

l~5i,76~•: H3 IB~SG•• 000 1 

I L 11 I 

---r=..chockNumber Routing Number {9 Digits):- Account NumbOr 

ftoutiig Number 

x Checking Savings Checking or Savings: 

$ 1295 Payment Infonnation Total Amount: 

Draft#J Draft#2 Drafi #3 Draftl/4. Draft#5 Draft#6 

Draft Date 2015- 05-03 2015-06- 03 2015-07-03 2015-08-03 2015-09-0 3 2015-10-03 

Draft Amou1tt $ 100 100 100 100 100 100 ---- . - '--. ------ ..._,_ - . --- Draft#7 Draft#8 Drafi #9 Draft#JO Draft#JJ Draft#l2 

2015-11-03 2015- 12-03 2016-01- 03 2016-02 - 03 2016-03-03 2016-04-,03 

100 100 100 100 100 100 

Authorization: 

I hereby authorize American Financial Benefits Center to Debit the Bank Account referenced herein, via an Automated 

Clearing House (ACH) system, according to the parameters specified herein for my Financial Education and Resource 

Center Program enrollment & American Financial Benefits Center Student Financial Management Plan. This authority 

will remain in effect until the payment is completed as specified herein. If a payment is returned for any reason 1 

acknowledge that I am subject to a rejected item fee of $20 or the maximum amount allowed by law in addition to any 

charges made by my bank. 

3/9/2015 

Date 

., .. i,+pzease retain a copy of this document as your receipt of purchase*** 

Marshall Attachment A - 8 

Case 4:18-cv-00806-SBA Document 37-1 Filed 03/02/18 Page 9 of 24
J?i11ancial Education & Resource Center Program Enrollment Recurring A CH Authorization Form 

B_y my signature be l~w, I authorize and permit American Financial Benefits Center to initiate electronic funds transfer 

via Automated Clearing House system (ACH) from my account listed below, for the Financial Education and Resource 

Center Program payment amount listed below. 

Account Holder's Full Name: 

Mailing Address: 

Mailing City, State, Zip Las Vegas NV 89119 

Monthly Payment Due Amount: $49.70 

Name of Bank: 

Bank Routing Number (9 digits): 

Bank Account Number: 

-

First Monthly Draft Date: 2015-11-03 

Monthly Draft Day: 

Terms of Agreement: 

American Financial Benefits Center, located at 311 Professional Center Drive 200, Rohnert Park, CA 94928, is 

authorized to deduct a scheduled payment from Client's checking or savings account from the bank listed above, if 

necessary American Financial Benefits Center may make adjustments if errors have occurred during transaction. In the 

event that Client's draft is returned unpaid for any reason, Client agrees to pay all past due balances immediately, in 

addition to a $5.00 administrative fee, and the current months payment amount. The date of the draft is listed above, 

however if the draft date falls on a weekend or bank holiday, the debit transaction will take place on the next business 

day. The company has the right to substitute the primary product(s) with an alternative product(s) of equal value. This 

authority will remain in effect until American Financial Benefits Center is notified by Client in writing by either email 

to; fercp@afbcenter.com or by fax to 707-222-5200 at least 10 business days prior to the next scheduled draft date See 

the attached notice of cancellation form for an explanation of this right. For questions regarding your payment, you may 

also contact us directly at 1-800-48 8-1 490. No other forms of cancellation by Client will be honored. This agreement 

may become void at the option of American financial Benefits Center at any-time. The reversal of funds from a Client's 

account that was drafted in error cannot be made until seven business days from the draft date. The Client agrees to 

waive all rights of reversal or refusal of any payment on any draft that American Financial Benefits Center may make 

against the Client's bank account during the time Client is actively enrolled. TI1e Client agrees with all of the provisions 

and conditions outlined herein. The Client further agrees to hold American Financial Benefits Center, its directors, 

employees, officers, and its agents harmless from any damages that may occur or arise from and within the entirely of 

this agreement. American Financial Benefits Center will not be responsible for any fees your financial institution may 

assess should a draft be returned for insufficient funds. 

By my signature below I acknowledge that I have read, understand and agree to the terms of this document titled 

Financial Education and Resource Center Program Recurring ACH Authorization Form. 

3/9/2015 

Date 

**" Please retain a copy of this MCU.ment as your receipt*** 

Marshall Attachment A - 9 

Case 4:18-cv-00806-SBA Document 37-1 Filed 03/02/18 Page 10 of 24
-'"'.,_,,..._,,:;I' ' '-l!VOIV J.10 JU. 

"Notice of Cancellation" 

Date: _ _ _ ___ ___ _ 

"You may cancel this transaction, without any penalty or obligation, within ten (10) business days from the 

above date. 

If you cancel, any property traded in, any payments made by you under the c~ntract or sale, and any 

negotiable instrument executed by you will be returned within ten (10) days following receipt by the seller of 

your cancellation notice, and any security interest arising out of the transaction will be canceled. 

If you cancel, you must make available to the seller at your residence, in substantially as good condition as 

when received, any goods delivered to you under this contract or sale, or you may, if you wish, comply with 

the instructions of the seller regarding the return shipment of the goods at the seller's expense and risk. 

If you do make the goods available to the seller and the seller does not pick them up within 20 days of the 

date of your notice of cancellation, you may retain or dispose of the goods without any further obligation. If 

you fail to make the goods available to the seller, or if you agree to return the goods to the seller and fail to do 

so, then you remain liable for performance of all obligations under the contract." 

To cancel this transaction, mail or deliver a signed and dated copy of this cancellation notice, or any other 

written notice, or send a telegram to American Financial Benefits Center, at 311 Professional Center Drive 

Suite 200, Rohnert Parle, CA, 94928 not later than ten (10) business days from the above date . 

I hereby cancel this transaction. 

(Client's signature) 

(Print Name) 

(Date) 

Marshall Attachment A - 10 

Case 4:18-cv-00806-SBA Document 37-1 Filed 03/02/18 Page 11 of 24
American Financial Benefits Center 

Complaint Policy 

Our goal at American Financial Benefits Center is to provide exceptional service to our Clients. While 

every effort is taken to ensure we treat our Clients in a fair, co~rteous, and honest manner, sometimes our 

Clients have special inquiries that require our immediate attention. 

We believe that our Clients have the right to raise a complaint, and the right to have their complaints 

addressed immediately. We also believe that a successful organization must be willing to evolve in an 

effort to meet the needs of its Clients. Therefore, we have established a complaint process for Clients who 

are unsatisfied with the service or treatment they have received. 

How to Initiate a Complaint 

In the event you are unsatisfied with our service, please initially direct your comment or complaint 

directly to the employee or team which is responsible for your dissatisfaction. If the individual employee 

cannot resolve the matter, we will quickly engage the relevant Manager or Director to resolve your 

matter. 

We always attempt to resolve your concerns at the first point of contact. However, if you are not satisfied 

with the resolution, you may then notify our Compliance Officer directly in writing at: 

I. compliance@afbcenter.com 

2. 1-800-488-1490 Extension: 2 

3. American Financial Benefits Center 

Attention: Compliance Officer 

311 Professional Center Drive Suite 200 

Rohnert Park, CA 94928 

Please include the following in your written correspondence 

l. A clear description of the complaint and any suggestions you may have that would resolve your 

grievance. 

2. Details of any relevant information relating to any contacts you may previously have had with 

American Financial Benefits Center on this subject. 

3. Whether it is an original complaint, or a follow-up to a reply you were not satisfied with. 

4. Your complete contact information (including full postal address, telephone number, and email 

address) and your date of birth (for verification purposes). • 

What to Expect 

We strive to resolve all complaint inquires as quickly and efficiently as possible. You can expect to 

receive a response from us within 2 business days after submitting your complaint. If your case is 

particularly complex and cannot be resolved within 2 business days, we will provide you with an 

estimated time in which you should expect:o receive such resolve. Thank You. 

Marshall Attachment A - 11 

Case 4:18-cv-00806-SBA Document 37-1 Filed 03/02/18 Page 12 of 24
Limited Power of Attorney 

To: Any and all of my Student Loan Creditors: 

I, hereby duly authorize, empower and appoint the American Financial Benefits Center of 3 J 1 

Professional Center Drive Suite #200, Rohneri Park, CA, 94928, its agents and representatives (AFBC) 

permission to perform any acts necessary or convenient, including but not limited to, the following on my 

behalf: 

1. Prepare, sign, and file any documents pertaining to my Student Loans with any governmental body or 

agency, represent me in all Student Loan matters including negotiating, compromise, or settling any 

matters with such government agencies, and communicate as fully I cou Id do if personally present and 

acting with any and/or all of my Federal Student Loan providers. To communicate with any/or all of my 

Federal Student Loan providers and their servicing agencies to consolidate or adjust my Student Loans. 

American Financial Benefits Center may discuss and coordinate financial adjustments on my behalf. 

2. To communicate with banks, creditors, financial institutions, licensed collection agencies, and all other 

related entities and individuals relating to my Federal Student Loans, including but not limited to the 

balance ofmy account, payment history verification of the account, financial adjustments, and any and all 

necessary communications, correspondence, and negotiations regarding my account(s). I assert that all of 

the information that I have provided and will provide AFBC is true and accurate. 

·3_ I hereby authorize third party communication from banks, creditors, financial institutions, licensed 

collection agencies, and all other related entities and individuals relating to my Federal Student Loans to 

communicate directly with AFBC concerning my account or the collection activities associated with it, in 

accordance with Section 805(b) of the Fair Debt Collection Practices Act. I further request that all of my 

lenders direct all further telephone calls to: 1-800-488-1490 and correspondence to: American F-inancial 

Benefits Center, 311 Professional Center Drive Suite #200, Rohnert Park, CA 94928 -Customer 

Service . Any and all communications directed to me will be referred to AFBC, and only AFBC will be 

authorized to deal with your company and or its representatives. 

I understand that AFBC is not a law firm, is not licensed to practice law or provide legal advice and that I 

w ill not request or accept, any legal advice from AFBC relating to my personal financial situation. I 

expressly agree to waive, forgo, indemnify and defend any claim against the AFBC relating to the 

practice of law. I understand that any creditor or collection activity, demands, or lawsuits are unrelated to 

my enrollment in the AFBC program. 

I agree that electronic or facsimile copy signature shall be deemed original and is an authorization by me 

for all lawfully enforceable purposes. 

This Limited Power of Attorney shall remain in forc.e until or unless modified or rescinded in writing, or 

upon resolution oft.he current matter. 

31912015 Executed On (Date): 

Applicant Signature~ --- ~ u=oc=us=,11J1,.,.;ei1;,.,o=y:.-------Applicant SSN: 

Applicant Name: Applicant DOB: ----'----

Marshall Attachment A - 12 

Case 4:18-cv-00806-SBA Document 37-1 Filed 03/02/18 Page 13 of 24
uv..:u;:,1yri cnve,ope ,u: 

National Student Loan Data System Access 

As part of the federal student loan consolidation application process, it will be necessary for American 

Financial Benefit Center to access your student loan information within the National Student Loan Data 

System located Online at http://www.nslds.ed.gov, or through your specific loan servicer's online portal. 

The National Student Loan Data .System contains a complete list of your federal education loans, along 

with current estimated balances and servicer detail information that is required to complete your 

consolidation, or other repayment plan application. 

By enrolling in the American Financial Benefits Center consolidation assistance program, you are 

agreeing to allow American Financial Benefits Center and its authorized agents to access your 

profile and all the data contained within that profile. 1n order to allow this access, you will need to 

provide American Financial Benefits Center with your Personal Identification Number (PIN). 

Please note that all infonnation that American Financial Benefits Center obtains from the National 

Student Loan Data System, or servicer online portal, will be used expressly for the purposes of 

confirming your eligibility for the American Financial Benefits Center consol:idation, or other repayment 

plan assistance program, and assisting you in the consolidation of your federal education loans. 

Acknowledgment 

l, Milton Marsha 17 , hereby acknowledge that I have read, understood, and agree to the 

above statements regarding access to my National Student Loan Data System profile. i understand that I 

will be asked to provide American Financial Benefits Center with my Personal Identification Number 

(PIN) and that American Financial Benefits Center and its authorized agents will use this PIN in order to 

access information regarding my federal education loans that is contained within the National Student 

Loan Data System. I understarid that this information will be used solely for the purposes of verifying my 

eligibility for the American Financial Benefits Center consolidation assistance program and completing 

my application for a Federal Department of Education consolidation loan. 

By signing this acknowledgment, I agree to allow American Financial Benefits Center to use my National 

Student Loan Data System PIN to access my personal profile as explained above. 

~DocuS!gn<d by: 

Client Signature~ Date: 3/9/2015 

Marshall Attachment A - 13 

Case 4:18-cv-00806-SBA Document 37-1 Filed 03/02/18 Page 14 of 24
American Financial Benefits Center 

Privacy Policy 

American Financial Benefits Center (hereinafter "Company") is dedicated to protecting your privacy and 

~roviding you with the h_ighest level of service. This Policy explains what Company does to keep 

informat10n about you pnvate and secure. This Policy covers only information that you provide to 

Company or that it obtains about you from companies that you have chosen to do business with. Please 

read this Policy carefully and contact us if you have any questions. 

Personal Information We Collect 

The personal information we collect about you comes from the following sources: 

0 Information we receive from you, such as your name, address, and telephone number, or 

other information that you provide to us over the phone or in documents or applications, 

• Information about your transactions, such as your account balances with your creditors, 

payment histories, account activity, and all other information that may be contained in your 

credit card statements or other reports relating to your debt, and 

• Information we receive from consumer reporting agencies and other sources, such as your 

credit bureau reports, collection agency reports or other communications, and other 

information relating to your payment histories, creditworthiness, annual income, or ability to 

satisfy your obligations. 

We reserve the right to, and will, sell or transfer your personal information to third parties for any purpose 

in our sole discretion. We prohibit the sale or transfer of personal information to non-affiliated entities for 

their use without giving you the opportunity to opt-out. We may disclose such information in order to 

effect or carry out any transaction that you nave requested of us or as necessary to complete our 

contractual obligations with you. We may also share your information with service providers that 

perform business operations for us, companies that act on our behalf to market our services, or others only 

as permitted or required by law, such as to protect against fraud or in response to a subpoena. We may 

also share or transfer our information in the event we transfer or sell your account or our business assets 

to another provider. 

By carrying out those services, we may disclose your information, as we see fit and as-permitted by law, 

to your creditors, credit card companies, collection agencies, banks, and other entities and individuals 

specifically necessary to effect, administer and perform our services. 

Your Choices / Opt-out 

We provide you the opportunity to 'opt-out' of having your personally identifiable information used for 

certain purposes. By providing information to Company you are consenting to the collection, use and 

disclosure of such perso~al information in the manner described in this privacy policy. We provide you 

the opportunity to withdraw your consent when such information is collected. 

Such consent may be withdrawn by calling -the telephone number provided below or may be done in 

writing/email and sent to our customer service department at the following physical address or email 

address: 

Marshall Attachment A - 14 

Case 4:18-cv-00806-SBA Document 37-1 Filed 03/02/18 Page 15 of 24
..,..,...,.,.-.J,::;•• ._, ,v .... ,vt-'v u .... , 

Marshall Attachment A - 15 

American Financial Benefits Center 

311 Professional Center Drive Suite #200 

Rohnert Park, CA 94928 

Jf by email: info@afbcenter.com 

If by phone: 1-800-488-1490 

How We Protect Your Information 

We train our employees to protect all customer information. We maintain physical, electronic and 

procedural controls that comply with government standards. We authorize our employees, agents and 

contractors to get information about you·only when they need it to do their work with us. You can help to 

maintain the security of your online transactions by not sharing your personal information or password 

with anyone. Remember, no method of transmission over the Internet, or method of electronic storage, is 

100% secure. 

This Policy applies to current and former customers. If you have any questions, please contact American 

Financial Benefits Center at 311 Professional Center Drive Suite 200, Rohnert Park, CA 94928 

Client Signature Date: 3/9/2015 

Case 4:18-cv-00806-SBA Document 37-1 Filed 03/02/18 Page 16 of 24
ln_co_ me-Based (IBR) / Pay As You Earn/ Income-Contingent (IGR) Repayment Plan Request 

W II o F d OM3 '-">. 1845-0102 1 •~m • or Federal Direct Loan (Direct Loan) Program/ Federal Family Education Loan (FFEL) Program Form Appsovod 

Use this fOfm to (1) request an ava1latle repayment plan based on·your income, (2) provida the required lnfonnation !or the annual reevaluation cxp. 11 2015 Oet• '3~

of your payment amo1.11t U11der one of these plans, or (3) request that your loan holder recatulate your monthly payment amount. 

IBRPAYE/ICR IV ARNING: Any person who knoNiigly rrol<28 a false stalemenl or misrep.<lsenlalion on Clis fufm oron any accompanying doCulll6nl is sutject to penallies fiat may lncllid -

I mp030nment, or bolh, undert~e U.S. Criminal Cooe and 20 U.S.C. 1097. e lines, SEcr10N 1.- BORROWER 10E,vr1F1cAnoN 

SECTION 2: REPAYMENT PLAN REQUEST 

B1;fore completing this form, carefully read the entire form, particularly Sections 7, 8, and 9. Type or print using dark ink. lf you need help completing 

this form, contact your loan holde_r(s). Re~u~~ the completed form and any r~quired documentation to the address shown in Sectlon 10. You may be 

able to complete your request onhne by v1s1bng studentloans.gov. Information about repayment plans and calculators are available at studentaid.gov. 

Other repayment plans, S<Jch as extended or graduated, may be available and may offer a lower monthly payment amoont. In addilion, payment under the IBR. 

Pay As You Earn, or ICR plans may result in your paying more inieresl over lime and may result in federal income tax liability on any loan amount that is forgiven 

under these plans. 

1. Rease select the reason that you are ccmpleting this request by checking box a, b, or c, below. 

a. ~ I am requesting a repayment plan based ()1 my income - Cheek the plan(s) you are requesting below and lhen continue to item 2. 

Direct Loan Program Loans· FFEL Program Loans' 

IBR 

Pav As You Earn • 

I I Not Availab • le 

ICR Not Available 

I request that my loan holder delermine which of the 

• 

above plans lam eligible ior, and place me on the Only IBR wlll Ile considered • for FFEL Program loans olan wilh the lowest monthlv oavment air.aunt. 

• Not all lo,m types under the FFEL and Direct Loan Programs are eligible for these plans (see Sa::tion 8). 

F()( Direct Looi borrowers, your requesl wil apply lo all of your loans that are eligible for the plan you choose. For FFEL borrowers, 

you can exclude eligible loans if you request IBR prior to July 1, 2013. If you are a FFEL borrower and request IBR on or after July 

1, 2013, you musl repay al loans eligible for !BR under that plan. For all borrONefs, you will need lo choose a different repayment 

plan for loans lhai are not eligible for a repayment plan based on income or they will be placed on the standard repayment plan. 

b. ~ I am submitting annual doa.rnnentation for lhe recalculation of my monthly payment amount under my current repayment plan - Continue to item 2. 

c O I am requesting that my loan holder recalculate rrtf current monthly payment anount because my circumstances have changed - Continue to item 2. 

2. 0 Check !his box If you crwe eligible loans to more than one loan holder. You must submit a separate request to each holder of the loans you want 

to repay under the IBR, Pay As You Earn, or lCR plan. 

You must promptly submit to your loan holder(s) this completed form and acceptable documentation of your Adjuste<l Gross Income (see Section 4), 

or, if applicable, alternative documentation of your current income (see Section 5). 

SECTION 3: SPOUSAL INFORMATION 

Complete this section if any of the folfowing apply to you: 

• You file a joint federal income tax return with your spouse and your spouse has eligible loans. Enter information about your spouse, beow. 

• You have a joint Direct or FFEL Consolidation Loan that ycu oblained with your spouse. Enter information about the co-borrower of the loan. 

• You and ycur spouse have Diroct Loans and both of you want to repay those loans under the ICR Plan. Enter information about your spouse, below. 

3. Spouse's SSN I I I I • I I I • I I I I I If yoo file a joint lederal irocme lax return wilh yo;r spouse, ycurloan 

4. Spouse's Name hoo!er(s) win base 7our elgi.lilty delermia.tion and m011lhly payment 

amount on ;our 311d your spouse's combined income regard!e,;s of 

-~1~1 - whether your spouse has elgi:ile federal st.,denl l0<1<1s. 1-b.rever, l your 

5. Spouse's Date of Birth S[)OUSS does not nave ellgitle slUdent loans. you do nolneed b 

completa lhit secUon. 

6. 0 My spouse and l wish to repay our Direct Loans jointly under the ICR Plan. 

If you complete this section. your spouse is also required to sign this form. By signing, your spouse is authorizing the loan holder(s) to access information 

about his or tier federal student loans in the National Student Loan Data Syslem (NSLDS). In addilion, if the Department is nct your loan holder and your FFa 

loan holder(s) dres not service at least one ol your spouse's loans, your loan holder(s) will need detai!ed information about all of your spouse's loans to accurately 

evaluate your eligibiity and payment amount. Your spouse should log into NSLDS at nslds.ed.gov to give yoor loan holder(s) access to his or her loan infomration. 

To obtain the organization code needed for authorizallon on NSLDS or for other options to provide the loan details needed on your spouse's loans, contact your 

loan holder(s). 

Pago 1 of·5 

Name 

Address 

City, State, Zip Code 

Telephone - Primary 

Telephone - Alternate 

E-mail Address [Optional) 

Marshall Attachment A - 16 

Case 4:18-cv-00806-SBA Document 37-1 Filed 03/02/18 Page 17 of 24
SECTION 4: FAMILY SIZE AND FEDERAL TAX INFORMATION 

7. I I Enter your family size (as defined in Section 8). 

N_ote: If you do not enter yo~r family_ size, your loan holder(s) will assume a family siz_e of one. For purposes of these repayment plans, your family size may be 

different from the number or exemptions you claim on your federal lax return. By signing this form, you are certifying that the family size you enter above is correct. 

8. Did you file a federal income tax return for either of the lwo most recently completed tax years? 

0 Yes - Continue to Item 9. 

D No - Skip to Section 5. 

~- Is your current inco~e or your ~pouse's current income (if you completed Section 3 or file a joint federal income lax return) significantly different than the 

income used to determine the Ad1usted Gross Income* (AGI) reported to the IRS on your most recently filed1ederal income tax return? 

D Yes - Continue to Section 5. · 

0 No - Provide your most recently filed federal income tax return or IRS tax return transcript Skip to Section 6. 

'You can find our Musted Gross Income on our most recentl filed IRS Form 1040, 1040A, or 1040EZ. 

SECTION 5: ALTERNATIVE DOCUMENT A T!ON OF INCOME 

To be completed if {1} you did not file a federal income tax return for the two most recently completed tax years, (2) your AG! from your most recently 

filed federal income tax return does not reasonably reflect your current income (due to circumstances such as the loss of or change in employment), 

or (3) your loan holder(s) informed you that alternative documentation of income is required. 

10. Do you have taxable income? Check ' No' if (1) you do not have any income, (2) receive only untaxed income (such as Supplemental Security Income, child 

support, or federal or state public assistance). or (3) are not required to file a federal income tax return based on the amount of your taxable income. 

D Yes - Provide documentatioo of this income, as described below. 

0 No - By signing this form, you are certifying that you have no taxable income or are not required to file a federal income tax return based on the amount of. 

your taxable income. 

11 . If you are married and completed Section 3 or file a joint federal income tax return with your spouse, does your spouse have taxable income? Check 'No" if (1) 

your spouse does not have any income, (2) receives only untaxed income (such as Supplemental Security Income, child support, or federal or state public 

assistance), or (3) is not required to file a federal Income tax return based on the amount of his/her taxable income. 

D Yes - Provide documentation of your spouse's income, as described below. 

D No - By signing this form. your spouse is certifying that he/she has no taxable income or is not required to file a federal tax return based on the amount of 

his/her taxable income. 

You must provide documentation of all taxable income thal you currently receive from all sources (for example, income from employment, unemployment 

income, dividend income, interest income, tips, alimony). II yoo are married and completed Section 3 or file a joint federal income tax return, you must also 

provide documentation of your spouse's taxable income. Do not report untaxed income such as Supplemental Security Income, child support, or 

federal or state public assistance. 

You must provide one piece of supporting documentation for each source of income (your and your spouse's). For example, documentation includes pay 

stubs, a letter(s) from your employer(s) listing income, interest or bank statements, or dividend statements. If these forms of documentation are 

unavailable, attach a signed statement from you or your spouse explaining the income source{s) and giving the name and the address of the source(s). 

Unless the frequency is clearly indicated on the documentation that you provide, write on your documentation how often you receive the income, for 

example, 'twice per month' or ' every other week'. The date on any supporting documentation you provide must be no older than 90 days from the date you 

si n this form. Co ies of ori inal documentation are acce table. 

SECnoN 6: BORROWER REQUEST, UNDERSTANDINGS, AGREEMENT, AUTHORIZATION, AND CERTIFICATION 

I request to use the plan I selected in Section 2 to repay my eligible Direct Loan or FFEL Program loans held by the holder(s) lo which I submit this form. If I 

selected the option to allow my loan ho!der(s) to choose my plan, I request my-loan holder(s) to place me in the plan with the lowest monthly payment amount. 

If more than one plan provides the same initial payment amount, I understand that my loan holder will choose the plan that is likely to keep my monthly 

payment amount lower in subsequent years. 

• I understand that: (1) If I am entering repayment on my loan(s) for the first time and do not provide my loan holde«s) with this completed form and any other 

documentation required by my loan holder(s), or if I do not qualify for the repayment plan that I requested, I will be placed on the standard repayment plan (see 

Section 8). {2) If I am currently repaying my loan(s} under a different repayment plan and want to change to the repayment plan I selected in Section 2, my 

loan holde«s) may grant me a forbearance fr.ir up to 60 days to collect and process documentation supporting my request for the selected plan. I am not 

required to make loan payments duling this period of forbearance, but interest will continue to accrue. Unpaid interest that accrues during this maximum 60-day 

forbearance period will not be capitalized (see Section 8). (3) If I am delinquent in making payments under my current repayment plan at the time I request one 

of the repayment plans listed in Section 2, my loan holder(s) may grant me a forbearance lo cover any payments that are overdue, or that would be due, at the 

time I enter the repayment plan I requested. Unpaid interest that accrues during this forbearance period may be capttalized. (4) If I am requesting the ICR plan, 

my initial payment amount will be the amount of interest that accrues each month on my loan(s) until my loan holder receives the income documentation 

needed to calculate my ICR payment amount. If I cannot afford the initial interest payments, I may request forbearance by contacting my loan holder. 

• I authorize the entity to which I submit this request (i.e., !he school, the lender, the guaranty agency, the U.S. Department of Education, and their respective 

agents and contractors) to contact me regarding my request or my loan(s), including repayment of my loan(s), at the number that I provide on this form or any 

future number that I provide for my cellular telephone or other wireless device using automated telephone dialing equipment or artificial or prerecorded voice or 

text messages. 

• I certify that all of the information I have provided on this form and in any accompanying documentation is true, complete, and correct to the best of my 

knowledge _and belief. ~-,it.;~u 

Borrower's Signature ~ _, C Date _3_/~~~/_2_0_1_5 __________ _ 

Spouse's Signature (if required) _ _________________ Date 

Note: Your spouse's signature is required if you completed Section 3 and/or completed Item 11. 

Page 2 of 5 

Marshall Attachment A - 1 7 

Case 4:18-cv-00806-SBA Document 37-1 Filed 03/02/18 Page 18 of 24
Records Code: HDFRB - XFRB 

GENERAL FORBEARANCE REQUEST 0MB No. 1845-0031 

William D. Ford Federal Direct Loan Program Form App,oved 

Exp. Dote 12/3112015 

WARN IN~: Any person who krowingty makes a false statement or misrepresentation on this fonn or on any acoompanyi~n-g -.-docu_m_en_t - - - --' 

win whim GFB be subjoct to penalties may include finas, inprisonment, er both, under the U.S. Crirrinal Code and 20 u.s.c. 1097. 

f SECTION 1: BORROWER JOENTIFJCATTON 

Please enter or correct the following lnformatioo. 

Oche · 

SECTION l: FORBEARANCE REQUEST 

Before completing this Form, carefully read the entire Form, inctuding the instructions and other information in Sections 3, 4, ands. 

11 I am willing but uneble lo make my current Direct Lean paymems due to a temporary hardship. I am requesting this folbearance because I am experiencing a t~rary hardship 

related to one of the fellowing situatjons {check one): 

~ Financial difficulties 

0 Change in employment 

0 Medical circumslances 

O Other (explain): 

• II this Forbearance request is approved, I want to (check ore): 

~ Temporarily stop making payments; o: 

O Temporarily make smaller payments of$ ____ per month. 

• If this forbearance request is approved, I am requesting that the U.S. Department of Education (ED) grant a folbearance on my loan(s) beginning (M.1,1.DO. YYYY) 

3 9 2015 9 9 2015 1-1 L-H-=- 1 1- H---J 1--11-1 L...I and ending {MM-0O-YYVY) 1---l 1-H .. :: .... J l---l-1-11-11-11- 1 for a period not to exceed 12 months. 

I SECTION J: BORROWER/£/VDORSER UNDERSTANDINGS AND CERTIACATJONS 

• I understand that the following tem,s e.id conditions apply lo this forbearance request: 

(1) ED v.ill not grant this forbearance request unless this form i5 comp'.etecl an:I any required supporting documenlalion is provided. 

(2) ED may grant a forbearance oo my !oans for up lo 60 days, if necessary, for the collection and processing of documentation related to my fortlearance reQUest. ED will not 

capitanze Interest fl1at aCC/ues durirg this forbearance. 

(3) If I am past <Jue on payments not covered by tl\is fcrooararce, ED may grant an additional folbearance on my loa" s) lo resolve all paymerits due when my request is 

processe::I, and all unpaid interest rr.ay be capitalized. 

(4) Al the end of the forbearance, I may ap~y to renew the forbearance ii I am stil experiencing a financial hardship. 

(5) I will connnue ro receive billing staerrents for my current payrrent amount, whieh I must pay until I am notified by my servicer tllal my forbearance request has been granted. 

(6) Durir;:i the Forbearance period. I am rot required to ma~e i;eyments of loan principal and inteiest bu1 interest win Ile charged on all of my loans. 

(7) If I requested to temporarily stop making payments, I vAII receive an interest notice, and I may pay the interest al any time. If I do not pay the intef€si that accrues on my 

1oan(s), it will be captalize:l at tlle end ot the roroearance pertod. 

{8) If I requested to tamporariiy make smaller payments, I will receive a monlhly ootice for the requested payment amount until the iorbearance ends, and any unpaid interesl 

that has accrued durirr,i lhe period v,iO be c:apilafited al the end or lhe fcrllearance period. 

• I certify that 

(1) The inFomiatj)n I have provided on this form is true i:Wld correct. 

(2) I will provide any additonal dccumentafion to ED, as required, to support my contilued Forbearance status. 

(3) I wffl notify ED immediately when the condition that qualified me for !he fortJearance ends. 

(4) I agree to repay rny loan(s) according lo the terms of my promissory note, regardless of whether the folbearance is granted. 

11 I authorize the entity to whk:h I submit this reques

::rt (i.e .. tile school. the lender. .._

the guaranly agency, ED, and Iller respective agents and contracrors) to contact me regardirg my 

request or my loan{s), including repayment of my ban(s), at lhe number that I provide on this Form or any Future number !hat I provide for my celh.iar telephone or other wireless 

device using automated di01ing equipment or Jj artificial or prerecorded voice or toxt messages. D0<uSlg ne<1 by: 

BORROWER'SORENOORSER'SSIGNATUREj 1 _____________ _ DATE: 3/9/2015 

Page 1 of 2 

SSN 

E-mail 

Marshall Attachment A - 18 

Case 4:18-cv-00806-SBA Document 37-1 Filed 03/02/18 Page 19 of 24
American Financial Benefits Center Document Preparation and Sen,ice Agreement 

Section J: Client Information Client ID: Agreement .0a1e: 3/9/2015 

Client La-;t Name: 

Former Last Name 

Street Address: City, Stace, Zip: Las veg as NV 89119 

Client Email: Client Phone: 

Section 2: Client's Estimated Summary oJ Currenl Federal Stud~ntLoans 

The basis or thls ~-ummary is det·ived from the input proYideiJ by the cli,mt. 

Estimated Total Federal Loan Balance: Loan Stahl~ (current, delinquent, default; consolidated): Current 

Approximate CurrenfMonthly Payment:$ 960, 00 Federal Loan Types (Single, Muhi): Multi 

Estimated New Loan Payment: $ , 00 New LQan Payment Validation Term: Annually 

Estimated Payment Adjusted After (Months): 20 Current Loan Servieer(s): Great Lakes/ Acs 

DOE PIN Code: 

Employer Name: Veterans Services Occupruioo: Veterans Services- Program 

t11floytN'Ci1?,9.$U9. Zip: Las Vegas NV 89119 

Employer Phone: Client Stated family Size: 8 

Client Marital Status: Sing l e Client Stated Tax: Filing Status: Singl e 

Current Annual Income: $ Form of Documented Income Submitted: Tax Return 

Spouse First Name: Spouse Last Name: 

Spouse SSN: Sl)()use DOB: 

Spouse Employer Nwne: Spouse Work Phone: 

Spouse Annual Income: $ PSLF Candidate (Yes/No): Yes 

Reference,· 2 Person.I Wllh dtfferem 2<1/i:esses PO 8())(es ru-e NOT ~~pl.Ible. not res1dtng m the 1ume bome{for e:wuple a spouse) m ,nyo11e h -ii1i; o,Jtl,ide tre U.S. 

Permanent Address: 

Reference l Phone: Relationship to Client: 

Reterence 2 Full Narn Pennanent Address: 

Reference 2 Phone: Relationship to Client 

Secfion 4: AFBC Doc1m1ent Preparation and Service Agreemen·t Program Payment 

AFBC Program Payment/Fee Amount:$ 600 A.FBC Program P•yment Amount: $ 100 

First Program Payment Date: 2015-11-03 Payment Term (months): 6 

Section 5: Client Payment Information 

B11nkName: 

Account Type {Checlong / Savings}: Checking Routing Number: 

1'lorts: C- 6 Min 

This Service Agreement is made and entered into, the date of signing, by and between American Financial Benefits 

Center ("AFBC"), and Client, as stated in Section I, hereinafter referred to as ("Client") residing at address as 

stated in Section l. Subject to, and conditioned upon, the following for the Client Student Loan Document 

Preparation and Service Agreement. All information above is provided by the Client 

Oieut Signature~---------- Date: 3/9/2015 

Marshall Attachment A - 19 

Case 4:18-cv-00806-SBA Document 37-1 Filed 03/02/18 Page 20 of 24
Date: 3/9/2015 

Name & Address: 

Las vegas NV 89119 

To whom this may concern, 

To the best of my knowledge, my current annual income for this year 

will b e $ -

Thank you, 

Signed:~ ~ 

Mi Hon Marsha 11 Print: _____________ _ 

SSN: 

Marshall Attachment A - 20 

Case 4:18-cv-00806-SBA Document 37-1 Filed 03/02/18 Page 21 of 24
Hand Signed Documents 

& 

Income Verification Request 

For processing purposes, please hand-sign and return to AFBC the documents requested below. This will 

ensure that we have all the necessary forms required to work directly with your current and/ or new 

student loan service provider on your behalf. 

Additionally, please provide your most recently filed complete federal tax return along with 30 days of 

your most recent paystubs. 

Please fonvard the requested information to one of the locations below: 

Ifby scan/ email: income.doc@afbcenter.com 

If by fax: (888) 334 - 6281 

Ifby mail: AFBC , Attn: Documents 

311 Professional Center Drive Suite 200 

Rohnert Park, CA 94928 · 

Marshall Attachment A - 21 

Case 4:18-cv-00806-SBA Document 37-1 Filed 03/02/18 Page 22 of 24
Date: 

RE: Cancellation Request for Automatic Withdrawal of Student Loan Payment 

To: Whom it may concern, 

At this time, I am requesting that your company cancel any and all automatic 

withdrawals (EFT or ACH) being debited from my account for the purposes of paying my 

student loan payment. Per our agreement, please consider this written notification to cancel 

this, and all future payment transactions. 

Sincerely, 

Signed: 

Prmt: . __

Mi lton ___Marshall ________ _ 

Marshall Attachment A - 22 

Case 4:18-cv-00806-SBA Document 37-1 Filed 03/02/18 Page 23 of 24
Limited Power of Attorney 

To: Any and all of my Student Loan Creditors: 

I, hereby duly authorize, empower and appoint the American Financial Benefits Center of 311 

Professional Center Drive Suite #200, Rohnert Park, CA, 94928, its agents and representatives (AFBC) 

permission to perform any acts necessary or convenient, including but not limited to, the following on my 

behalf: 

1. Prepare, sign, and file any documents pertaining to my Student Loans with any governmental body or 

agency, represent me in all Student Loan matters including negotiating, compromise, or settling any 

matters with such government agencies, and communicate as fully I could do if personally present and 

acting with any and/or all of my Federal Student Loan providers. To communicate with any/or all of my 

Federal Student Loan providers and their servicing agencies to consolidate or adjust my Student Loans. 

American Financial Benefits Center may discuss and coordinate financial adjustments on my bel1alf. 

2. To communicate with banks, creditors, financial institutions, licensed collection agencies, and all other 

related entities and in<;lividuals relating to my Federal Student Loans, including but not limited to the 

balance ofmy account, payment history verification of the account, financial adjustments, and any and all 

necessary communications, correspondence, and negotiations regarding my account(s). I assert that all of 

the information that I have provided and will provide AFBC is true and accurate. 

3. l hereby authorize third party communication from banks, creditors, financial institutions, licensed 

collection agencies, and all other related entities and individuals relating to my Federal Student Loans to 

communicate directly with AFBC concerning my account or the collection activities associated with it, in 

accordance with Section &OS(b) of the Fair Debt Collection Practices Act. I further request that all of my 

lenders direct all further telephone calls 10: 1-800-488-1490 and correspondence to: American Financial 

Benefits Center, 311 Professional Center Drive Suite #200, Rohnert Park, CA 94928 -Customer 

Service . Any and all communications directed to rne will be referred to AFBC, and only AFBC will be 

authorized to deal with your company and or its representatives. 

I understand that AFBC is not a law firm, is not licensed to practice law or provide legal advice and that J 

will not request or accept, any legal advice from AFBC relating to my personal financial situation. 1 

expressly agree to waive, forgo, indemnify and defend any claim against the AFBC relating to the 

practice of law. I understand that any creditor or collection activity, demands, or lawsuits are unrelated to 

my enrollment in the AFBC program. 

l agree that electronic or facsimile copy signature shall be deemed original and is an authorization by me 

for all lawfully enforceable purposes. 

This Limited Power of Attorney shall remain in force until or unless modified or rescinded in writing, or 

upon resolution of the current matter. 

Executed On (Date): 31912015 

.. 

Applicant Signature . . cant SSN: 

Applicant Name: Mi 1 ton Marsha 11 Applicant DOB: 

-

Marshall Attachment A - 23 

Case 4:18-cv-00806-SBA Document 37-1 Filed 03/02/18 Page 24 of 24
Marshall Attachment B

Case 4:18-cv-00806-SBA Document 37-2 Filed 03/02/18 Page 1 of 2
-----Original Message-----

From: Nicole Williams <nicole.williams@afbcenter.com>

To:

Sent: Wed, Apr 8, 2015 11:01 am 

Subject: In regards to your AFBC inquiry 

Good Morning, 

We received your inquiry about your payment draft. The first payment does take a bit longer to process as the bank and 

merchant have to match up. You payment was drafted on the 3rd of April and is currently pending. It should go through 

by the end of the week.

I hope you have a great day! 

Please confirm that I have met your expectations at this time regarding the above matters. Thank you! 

--

Warm Regards,

Nicole Williams

Customer Service 

American Financial Benefits Center

311 Professional Center Drive Suite 200

Rohnert Park, CA 94928

Phone: 800-488-1490 ext. 152

Fax: 888-334-6281

Email: nicole.williams@afbcenter.com

Website: www.afbcenter.com

Our Client Promise:

100% Client Satisfaction - 100% of The Time

NOTICE: The information contained in (and attached to) this e-mail is intended only for the personal and confidential use 

of the designated recipient(s) named above. If the reader of this message is not the intended recipient, you are hereby 

notified that you have received this document in error and that any review, dissemination, distribution or copying of this 

message is strictly prohibited. If you received this communication in error, please notify us immediately by reply e-mail, 

and delete the original message (including attachments 

Marshall Attachment B

Case 4:18-cv-00806-SBA Document 37-2 Filed 03/02/18 Page 2 of 2
Marshall Attachment C

Case 4:18-cv-00806-SBA Document 37-3 Filed 03/02/18 Page 1 of 12
need, as well as documents we have on file.

Marshall Attachment C-1

 dernts Requiecum

ents are needed to further process your file. Please see 

> .com

dditional Documents Required 

center oc@afb

:53 pm 

* AFBC - Additional Do

onal docum

e----- 

come.d

2

ginal Messag

ni

-----OriFrom:To: income.doc <Sent: Wed, Apr 6, 2016 1

IMPORTANT Subject: Re: *

Hello,This is the second time I submitted these documents. Please don't loose these. I haven't filed taxes for this year, however, I've enclosed my earning statements for the last two pay periods, along with a signed IBR paper work. Best,MiltonThe document s are attached here... Subject: *IMPORTANT* AFBC - ADear Milton, Our records indicate that additibelow for a complete list of documents that we 

nything marked "Needed" will need to be sent to us as soon as possible. You may reply to this email A

with the necessary documents attached.

Case 4:18-cv-00806-SBA Document 37-3 Filed 03/02/18 Page 2 of 12
You can also fax documents to 888-334-6281 or mail them to: 

American Financial Benefits Center 

c/o Document Collection Dept 

311 Professional Center Drive #200 

Rohnert Park, CA 94928 

Please see below for the complete list of documents we require. 

Most Recent 30 Days of Paystubs: Needed 

Most Recently Filed Tax Return: Needed 

Statement of Income: N/A 

PSLF Employment Certification Form: Received 

Stop Automatic Payment To Servicer Form: N/A 

Recent Loan Servicer Statement(s) or Documents: N/A (Pulled Fed Site Statement) 

IBR/ICR Application Form: Need Client Signature 

Forbearance Form: Need Client Signature 

Stop/Freeze Forbearance Form: Received 

Voided Check: Received 

Notes by our Document Collection Department:

Thank you! 

AFBC Team 

1-800-488-1490 ext. 0 

NOTICE: The information contained in (and linked to) this e-mail is intended only for the personal and 

confidential use of the designated recipient(s) named above. If the reader of this message is not the 

intended recipient, you are hereby notified that you have received this document in error and that any 

review, dissemination, distribution or copying of this message is strictly prohibited. If you received this 

communication in error, please notify us immediately by reply e-mail, and delete the original message 

(including attachments/links). 

Marshall Attachment C-2

Case 4:18-cv-00806-SBA Document 37-3 Filed 03/02/18 Page 3 of 12
Marshall Attachment C-3

Case 4:18-cv-00806-SBA Document 37-3 Filed 03/02/18 Page 4 of 12 INCOME-DRIVEN REPAYMENT PLAN REQUEST: 0MB No. 1845-0102 

Form Approved For the Revised Pay As You Earn (REPAVE), Pay As You Earn (PAYE), Income-Based Exp. Date 10/31/2018 (IBR), and Income-Contingent (ICR) repayment plans under the William D. Ford 

IDR Federal Direct Loan (Direct Loan) and Federal Family Education Loan (FFEL) Programs 

WARNING: Any person who knowingly makes a false statement or misrepresentation on this form or on any accompanying 

document is subject to penalties that may include fines, imprisonment, or both, under the U.S. Criminal Code and 20 u.s.c. 

1097. 

SECTION 1: BORROWER IDENTIFICATION 

Please enter or correct the following information. 

• 

Name Milton Marshall 

City, State, Zip 

Address 

Code ~:------

Telephone • Primary 

Telephone - Alternate (--- ( __ ) 

Email (Optional) 

SECTION 2: REPAYMENT PLAN OR RECERTIFICATION REQUEST 

READ BEFORE COMPLETING THIS FORM: 

• You can apply on line at Studentloans.gov. It is faster and easier to complete this form online. 

• Income-driven repayment plans offer many benefits, but may not be right for everyone. 

• You can learn more about these plans at StudentAid.gov/lDR and by reading Sections 9 and 10. 

• It's simple to explore all of your repayment options at StudentAid.gov/repayment-estimator. 

• You can find out which types of loans you have and who your loan holder or servicer is at nslds.ed.gov. 

• If you need help completing this request, contact your loan holder or servicer for free assistance. 

• You may have to pay income tax on any loan amount forgiven under an income-driven plan. 

1. Select the reason you are submitting this form (Check 2. Choose a plan and then continue to Item 3. 

only one): D (Recommended) I want my loan holder to place me on 

CJ the plan with the lowest monthly payment. I am not in an income-driven repayment plan, but 

= v-¢t to enter one - Continue to Item 2. D REPAYE 0 IBR 

iif[" am already in an income-driven repayment plan • PAYE OICR 

and am submitting documentation for the annual 

3. Do you have multiple loan holders or servicers? recalculation of my payment - Skip to Item 5. • Yes - Submit a separate request to each loan holder or 

DI am already in an income-driven repayment plan and servicer. Continue to Item 4. 

am submitting documentation early because I want D No· Continue to Item 4. 

my loan holder to recalculate my payment 

immediately- Skip to Item 5. 4. Are you currently in a deferment or forbearance? 

D I am already in an income-driven repayment plan, D No - Continue to Item 5. 

but want to change to a different income-driven D Yes, but I want to start making payments under my plan 

repayment plan - Continue to Item 2. 

• 

immediately - Continue to Item 5. 

Yes, but I do not want to start repaying my loans until 

the deferment or forbearance ends - Continue to Item S. 

If you have FFEL Program loans, they may only be repaid under IBR. If you request a different plan, your loan holder will 

consider you for IBR on your FFEL Program loans. You may be able to consolidate your FFEL Program loans into a Direct 

Consolidation Loan to take advantage of other income-driven plans by visiting Studentloans.gov. 

Pagel ol 12 
Marshall Attachment C-4

Borrower Name: Milton Marshall 

SECTION 3: FAMILY SIZE INFORMATION 

5. How many children, including unborn children, are in 6. How many people, excluding your spouse and children, 

y r family and receive more than half of their support live ith you, and receive more than half of their 

om you? por from you? 

. Continue to Item 6. . Continue to Item 7. 

A definition of "family size" is available in ·section 9. 

Do not enter a value for you or your spouse. Those ID Single - Continue to Item 8. values are automatically included, if appropriate. 

D Married - Skip to Item 11. 

SECTION 4A: INCOME INFORMATION FOR SINGLE BORROWERS 

8. Did you file a fe ef'alirlcome tax return for either of 10. Do you currently have taxable income? Check "No" if 

the past tw a>< years? you do not --;e any income or receive only untaxed 

es - Skip to Section 5. 

D No - Skip to Section 6. 

9. Has your income significantly changed since you filed 

your last federal income tax return? For example, have Remember, any person who makes a knowingly false 

you lost your jo , gotten divorced, or experienced a statement or misrepresentation on this form may be 

drop in inc subject to fines, imprisonment, or both. 

- Continue to Item 10. 

No - Provide your most recent federal income tax 

return or transcript. Skip to Section 6. 

SECTION 48: LOAN AND INCOME INFORMATION FOR MARRIED BORROWERS 

11. Does your spouse have federal student loans? 16. Has your income significantly changed since you 

D tiled your last federal income tax return? For Yes - Continue to Item 12. 

example, have you lost your job or experienced a 

D No - Skip to Item 14. drop in income? 

12. Provide the following information about your spouse D Yes - Skip to Item 18. 

and then continue to Item 13: D No - Continue to Item 17. 

a. Spouse's SSN: 

17. Has your spouse's income significantly changed since 

your spouse filed his or her last federal income tax 

b. Spouse's Name return? For example, has your spouse lost his or her 

job or experienced a drop in income? 

c. Spouse's Date of Birth D Yes - Continue to Item 18. 

El No - Provide your and your spouse's most recent 

13. If you are placed on the ICR plan, do you want to federal income tax return or transcript. Skip to 

repay your Direct Loans jointly with your spouse? Section 6. 

D Yes - Continue to Item 14. 18. Do you currently have taxable income? Check "No" if 

l2l No - Continue to Item 14. you do not have any income or receive only untaxed 

income. 14. When you filed your last federal income tax return, 

did you file jointly with your spouse? D Yes - Provide documentation of your income as 

D Yes - Continue to Item 15. instructed in Section 5. Continue to Item 19. 

D No - Skip to Item 20. D No - Continue to Item 19. 

15. Did you and your spouse file a federal income tax 

Remember, any person who makes a knowingly false return for either of the past two tax years? 

D statement or misrepresentation on this form may be Yes - Continue to Item 16. subject to fines, imprisonment, or both. 

D No - Skip to Item 18. 

Page 2 or 12 

Borrower SSN: Case 4:18-cv-00806-SBA Document 37-3 Filed 03/02/18 Page 5 of 12
Marshall Attachment C-5

Borrower Name: Case 4:18-cv-00806-SBA Document 37-3 Filed 03/02/18 Page 6 of 12 Milton Marshall Borrower SSN: 

SECTION 48: LOAN AND INCOME INFORMATION FOR MARRIED BORROWERS (CONTINUED) 

19. Does your spouse currently have taxable income? 24. Are you reasonably able to access information 

Check "No" if your spouse has no taxable income or about your spouse's income and able to have your 

receives only untaxed income. spouse sign this application? 

D Yes - Provide documentation of your spouse's D Yes - Continue to Item 25. 

• 

income as instructed in Section s. D No - Provide documentation of only your 

No - Skip to Section 6. income as instructed in Item 21 or 22 and then 

20. Did you file a federal income tax return for either skip to Section 6. 

of the past two years? 25. Did your spouse file a federal income tax return for D Yes - Continue to Item 21. either of the past two tax years? 

D No - Skip to Item 22. (J Yes - Continue to Item 26. 

21. Has your income significantly changed since you 

No - Skip to Item 27. filed your last federal income tax return? For D 

example, have you lost your job or experienced a 26. Has your spouse's income significantly changed 

drop in income? since your spouse filed his or her last federal 

D Yes - Continue to Item 22. income tax return? For example, has your spouse 

D lost a job or experienced a drop in income? No - Provide your most recent federal income 

ta>< return or transcript. Skip to Item 23. D Yes - Continue to Item 27. 

22. Do you currently have taxable income? Check "No" D No - Provide your spouse's most recent federal 

if you have no taxable income or receive only income tax return or transcript. This information 

• 

untaxed income. will only be used for the REPAVE Plan. Skip to 

Yes - Provide documentation of your income as Section 6. 

instructed in Section 5. Continue to Item 23. 27. Does your spouse currently have taxable income? 

D No Check "No" if your spouse has no taxable income or - Continue to Item 23. 

received only untaxed income. 23. Are you separated from your spouse? D Yes - Provide documentation of your spouse's D Yes - Provide documentation of only your income as instructed in Section 5. This 

income as instructed in Item 21 or 22 and then information will only be used for the REPAVE 

skip to Section 6. Plan. 

Cl No - Continue to Item 24. D No - Skip to Section 6. 

Remember, any person who makes a knowingly false statement or misrepresentation,on this form may be subject 

to fines, imprisonment, or botll. 

SECTION 5: INSTRUCTIONS FOR DOCUMENTING CURRENT INCOME 

You only need to follow these instructions if, based on your answers in Section 4, you and your spouse (if applicable) are 

required to provide documentation of your current income instead of a tax return or tax transcript. After gathering the 

appropriate documentation, continue to Section 6. 

• You must provide documentation of all taxable • If documentation is not available or you want to 

income you and your spouse currently receive. explain your income, attach a signed statement 

• Documentation w ill usually include a pay stub or letter explaining each source of income and giving the name 

from your employer listing your gross pay. and the address of each source of income. 

• You must provide at least one piece of documentation • Write on your documentation how often you receive 

for each source of taxable income. the income, for example, "twice per month" or "every 

• Taxable income includes, for example, income from other week." 

employment, unemployment income, dividend income, • The date on any supporting documentation you dividend income, interest income, tips, and alimony. provide must be no older than 90 days from the date 

• Do not provide documentation of untaxed income you sign this form. 

such as Supplemental Security Income, child support, • Copies of documentation are acceptable. 

or federa l or state public assistance. 

Page 3 of 12 
Marshall Attachment C-6

Borrower Name: Case 4:18-cv-00806-SBA Document 37-3 Filed 03/02/18 Page 7 of 12 Milton Marshall Borrower SSN: 

SECTION 6: BORROWER REQUESTS, UNDERSTANDINGS, AUTHORIZATION, ANO CERTIFICATION 

If I am requesting an income-driven repayment plan or seeking to change between income-driven repayment plans, 1 request: 

• That my loan holder place me on the plan I selected in Section 2 to repay my eligible Direct Loan or FFEL Program loans 

held by the holder to which I submit this form. 

• If I do not qualify for the plan or plans I requested, that my loan holder place me on the plan with the lowest monthly 

payment amount. 

• If I selected more than one plan, that my loan holder place me on the plan with the lowest monthly payment amount 

from the plans that I requested. 

• If more than one of the plans that I selected provides the same initial payment amount, or if my loan holder is 

determining which income-driven plans I qualify for and I qualify for more than one of those plans, my loan holder will 

use the following order in choosing my plan: REPAVE (if my repayment period is 20 years), PAYE, REPAVE (if my 

repayment period is 25 years}, IBR and then ICR. 

If I am currently repaying my Direct Loans under the IBR plan and am requesting to change to another income-driven plan, I 

must be placed on the Standard Repayment Plan, and cannot change to the plan that I requested until I make a payment under 

the Standard Repayment Plan or make a payment under a reduced-payment forbearance. 

If I check the box below, I request that my loan holder grant me a reduced-payment forbearance for one month so that I can 

move from the IBR plan to my new income-driven repayment plan. 

O I want a one-month reduced-payment forbearance in the amount of (must be at least $5). 

I understand that: 

• If I do not provide my loan holder with this completed form and any other required documentation, I will not be placed 

on the plan that I requested. 

• I may choose a different repayment plan for any student loans that are not eligible for income-driven repayment. 

• If I requested a reduced-payment forbearance of less than $5 above, my loan holder will grant my forbearance request 

in the amount of $5. 

• If I am requesting the ICR plan, my initial payment amount will be the amount of interest that accrues each month on 

my loan until my loan holder receives the income documentation needed to calculate my payment amount. If I cannot 

afford the initial payment amount, I may request a forbearance by contacting my loan holder. 

• If I have FFEL Program loans, my spouse may be required to give my loan holder access to his or her loan information in 

the National Student loan Data System (NSLDS). My loan holder will contact me with further instructions. 

• My loan holder may grant me a forbearance while processing my application or to cover any period of delinquency that 

exists when I submit my application. 

I authorize the loan holder to which I submit t his request (and its agents or contractors} to contact me regarding my request or 

my loan(s), including repayment of my loan(s), at any number that I provide on this form or any future number that I provide for 

my cellular telephone or other wireless device using automated telephone dialing equipment or artificial or prerecorded voice 

or text messages. 

I certify that all of the information I have provided on this for and in any accompanying documentation is true, complete, and 

correct to the best of my knowle g a,r'cfbelief. 

Date: Spouse's Signature 

If you are married, your spouse is required to sign this form unless you answered "yes" to Item 23 or "no" to Item 24. 

Page 4 or 12 
1. Pay Period End 

O'Z/06/ 1 6 

CIVILIAN LEAVE AND EARNINGS STATEMENT 2. Pay Dalo 

3 Name 

t~j,RSHJ\LL MII.TOU L .,_ Pr pwrwnn:er O:!/l:!/ 1 6 

s 

9. Localil % 

15. Financiol lnstilution - Allotment #1 16. Financial tnstitulion. Allotmonl #2 

Add'I 18. Tax Marital Exemptions Add'I Taxing Authority 20. Mi6tary Deposit Sl;,lus 

PJ\I D: 

01:Eo: 

21 . 22. 

GROSS PAY T S P Oi1.°;,·\ 

TAXABLE WAGES 

NONTAXABLE WAGES 

• 

TAX DEFERRED WAGES 

DEDUCTIONS 

AEIC 

NET PAY 

CURRENT EARNINGS 

TYPE YPE HOURS/DAYS AMOUNT TYPE HOURS/DAYS AMOUNT 

R~GUL,.\R i

1AY 

DEDUCTIONS 

TYPE CODE YEAR TO DATE TYPE CODE CURRENT YEAR TO DATE 

F!::Ol,l co MED!G\RE 

Ol ,SDI ORC/UllIO!l V li!J\ 

ili':TIRE . FERS T,\X Pl-IT, VOL 

':"A.!~. FEOER,\L TS P Si\VUfCS 

DF.1r.;,1, VI S iOII 

LEAVE 

TYPE PRIOR YR ACCRUED ACCRUED USED USED DONATED/ CURRENT USE-LOSE/ BALANCE PAY PO YTO PAY PO YTO RETURNED BALANCE TERM DATE 

i\JJ?:U,\L 

S I CK 

BENEFITS PAID BY GOVERNMENT FOR YOU 

TYPE CURRENT YEAR TO DATE TYPE 

FE<.il.l M~O l C,'\!lE 

0,\SDI R:'.TIRE. FERS 

TS P 9l,S I C TSP M/,7CH lllG 

REMARKS YOUR P,\'!ROLL OFF! CE IO l!UM3ER IS D:':PJ\RTM£117 Or V£7ERlJIS AF:'J\I as. 

YOU~ P,\SS1•:0 ;l0 Hl~ BEEU EST,\BLI5h~O/CM:UZCEO FOa ,· .. c c ~SS!l-JC t-t'IP,,Y . 

IF YOU DID !IOT 7,il:E -:'HIS 1iL'TION, CONTACT 1·888 · .B:? •7•11 1 OR ( 216) 5:?2-:i0 96 . 

TiiE: il,\!,I C OT ilA7E Ul ilOX G IS YOUR !JASE HOURLY R,\Tl:: Ill n o x 5 7!Mi,S 1. 5 ; HOW?;VER . YOUR 

;,c -:-l!i,L OT R,',!S FOR Nfl GIVStl DJ\Y c ;Jl 3 ::'. ,iFFECTSD 3 Y SHIFT O,! OTH2R PREMIUM PAY 

THIS REPORT CONTAINS INFORMATION SUBJECT TO THE PRIVACY ACT OF 1974 AS AMENDED 

Marshall Attachment C-7 

Case 4:18-cv-00806-SBA Document 37-3 Filed 03/02/18 Page 8 of 12
1. Pay Period End 

03/ 19/16 

CIVILIAN LEAVE AND EARNINGS STATEMENT 2. Pay Date 

03/25/ 16 

3. Name 

MJI.RSHALL MILTON L 

01 / 07/17 

Marital Exemplions Add'I Taxing Authority 19. Cumulative Retirement 20. Military Deposit Slatus 

FED FERS : - PAI D: 

OWED : 

21 . Current Year10 Date 22. 

GROSS PAY TSP DATA 

TAXABLE WAGES 

NONTAXABLE WAGES 

• 

TAX DEFERRED WAGES 

DEDUCTIONS 

AEIC 

NET PAY 

CURRENT EARNINGS 

TYPE TYPE HOURS/DAYS AMOUNT TYPE HOURS/DAYS AMOUNT 

REGULAR PAY HOURS/DAYS AMOUNT 

DEDUCTIONS 

TYPE CODE C ::li: .:.:••! TYPE CODE 

FEGLI co MEDICARE 

OASDt ORG/UHION VlHA 

RETIRE , FERS KF TAX PMT, VO L 

TAX, FEDERAL TSP SAVINGS 

DENTAL VISI ON 

LEAVE 

TYPE USE-LOSE/ 

TERM DATE 

ANNUAi.. 

SICK 

BENEFITS PAID BY GOVERNMENT FOR YOU 

TYPE CURRENT YEAR TO DATE TYPE CURRENT YEAR TO DATE 

FEGLJ MEDt CARE 

OASDI RETrRE, FERS 

TSP BASIC TSP MATCHING 

REMARKS 

YOUR PAYROLL OFFICE IO NUMBER TS - DF.PARTNFNT OF VFTFRANS AFFATRS . 

I'f IS YOUR DUTY TO COMPLY WITH FEDERAL TAX LAWS. CALL THE I RS F'OR ASSISTANCE AT 

1·800 · 829·1040 OR ACCESS THEIR WEBSITE AT l'IWW. l RS . GOV . 

THE BASIC OT RATE IN BOX 6 IS YOUR BASE HOURLY RATE IN BOX 5 TIMES 1.5; HOWEVER. YOUR 

ACTUAL OT RATE FOR ANY GlVEN DAY CAN BE AFFECTED B':' SH l!'T OR OTHER PREMIUM PAY 

THIS REPORT CONTAINS INFORMATION SUBJECT TO THE PRIVACY ACT OF 1974 AS AMENDED 

Marshall Attachment C-8 

Case 4:18-cv-00806-SBA Document 37-3 Filed 03/02/18 Page 9 of 12
1. Pay Period End 

03/05/lG 

CIVILIAN LEAVE AND EARNINGS STATEMENT 2. Pay Date 

0 3 / ll./ 16 

3. Name 

MARSHALi, MILTON L 

8. Soc Sec No 

14. Financial Institution • Net Pay 16. Financial lnstilution • Allotment #2 

17. Tax Marital Exemptions Add'I 18. Tax Marital Exemplions Add'I Taxing Authority 20. Mililary Deposit Status Status 

PAlD : 

OI-IED : 

21 . 22. 

GROSS PAY TSP DAT.>; 

TAXABLE WAGES 

NONTAXABLE WAGES 

TAX DEFERRED WAGES 

DEDUCTIONS 

AEtC 

-

NET PAY 

CURRENT EARNINGS 

TYPE PE HOURS/DAYS AMOUNT TYPE HOURS/DAYS AMOUNT 

REGULAR PAY 

DEDUCTIONS 

TYPE CODE YEAR TO DATE TYPE CODE CURRENT YEAR TO DATE 

FEGLI co MEDICARE 

OASl)T ORG/UNION VlHh 

RETIRE, F'ERS KF' TAX PHT, VOL 

TAX , FEDERAL TSP SAVINGS 

DENTAL 1/ISlOII 

LEAVE 

TYPE PRIOR YR ACCRUED ACCRUED USED USED DONATED/ CURRENT USE-LOSE/ 

BALANCE PAY PD YTD PAY PD YTD RETURNED BALANCE TERM DATE 

ANNUAi, 

SICK 

BENEFITS PAID BY GOVERNMENT FOR YOU 

TYPE CURRENT YEAR TO DATE TYPE C E TOD 

F'EGLl f!EDICARE 

OASDJ RETIRE, FERS 

TSP BASIC TSP MATCHING 

REMARKS 

YOUR PAYROLL OFFICE TD NUMB2R TS ---- DEPARTMENT OF' VETERANS AFFAIRS. 

YOUR PASSi,ORD HAS BEEN ESTABLISHED/CHANGED FOR ACCESSING MYPAY . 

H' YOU DlD NOT TAKE TH IS ACTION, CONTACT 1·88a•332 ·7-lll OR (2 1 6 ) 522-5 0 96. 

TllE BASIC OT RATE IN BOX 6 rs YOUR EASE HOURLY RATE IN BOX 5 TIMES 1.5; HOWEVER. YOUR 

ACTUAL OT P.P.TE !"OR ANY GlVEN DAY CAN BE AFFECTED BY SHI FT OR OTHER PREMIU~1 PAY 

THIS REPORT CONTAINS INFORMATION SUBJECT TO THE PRIVACY ACT OF 1974 AS AMENDED 

Marshall Attachment C-9 

Case 4:18-cv-00806-SBA Document 37-3 Filed 03/02/18 Page 10 of 12
flM Internal Revenue Service 

United States Department of the Treasury 

This Product Contains Sensitive Taxpayer Data 

Request Date: 02- 26- 2015 

Response Date: 02-26-2015 

Tracking Number: 

Wage and Income Transcript 

SSN Provided: 

Tax Period Requested : December, 

Form W-2 Wage and Tax Statement 

617 

Employer : .. .. ... . . . . - . . ~ mber CEIN) 

Employee: 

Employee's Social Security Number: 

Submission Type: .. . ............................. . ............ Original document 

Wages, Tips and Other Compensation: ...................... . ......... . Federal Income Tax Withheld: ............ . .......................... . Social Security Wages : .......... . . . . . . . .............•.•.. . .. .. .. . . . . Social Security Tax Withheld: ....................... . .. . .. . . .. ... .. . Medicare Wages and Tips: ............... . . . ......................... . Medicare Tax Withheld: ........... . ........................ . ... .. .. . . Social Security Tips: ... . .............. . ........... . ............... . Allocated Tips: ...... . . . ............ . . . . . .......................... . Dependent Care Benefits: ... . .............. . . . .... . . . ............... . Deferred Compensation : ....... . ... . ................................. . Code "Q" Nontaxable Combat Pay: . . .. ................... .. ..... . ..... . Code "W" Employer Contributions to a Health Savings Account: ....... . Code "Y" Deferrals under a section 409A nonqualified Deferred Compensa 10n 

plan: .... . ...... . .. . ...... . ... . ............... . . . .. . ............ . ....... ·- Code nzn Income under section 409A on a nonqualified Deferred Compensati 

p Ian: ........... . ... . ........ . . .. ................ • .....•.. . .. , . . ... , . . , . Code "R" Employer's Contribution to MSA: .•.•.•...•.•.•...•...•...••...•. 

Code "S" Employer's Contribution to Simple Account: .. . .. . .. . .......... . . Code 111 Expenses Incurred for Qualified Adoptions: ..... . .......... . ... . Code "V" 11 

Income from exercise of non-statutory stock options: .......... . Code "AA" Designated Roth Contributions under a Section 401Ck) Plan: ... . Code "BB" Designated Roth Contributions under a Section 403(b) Plan, ... . Code 11DD" Cost of Employer-Sponsored Health Coverage : . ... . ... . . ........ . Code "EE" Designated ROTH Contributions Under a Governmental Section 457 

Plan: ................. . . , ................ . ...... • . . ......... . .......... . Third Party Sick Pay Indicator : . . . . . . . . . . ..... . . . . . ..... . . . ........ . Retirement Plan Indicator: .. . ............... . ... . .. . .. . . Statutory Employee: ....•................ . . . ............. 

Form 1099-G 

Payer : • • • • .. a ,. a • I I { II a er (FIN): 

SACRAMENTO, CA 95814-4807 

017

Marshall Attachment C-1 O 

Case 4:18-cv-00806-SBA Document 37-3 Filed 03/02/18 Page 11 of 12
Marshall Attachment C-11

Tracking Number: 

Recipient: 

Recipient's Identification Number : 

Submission Type: ... . . . . . ........... . ......... . .•.•......... . . Origi Account Numb er C Op tional ) : ....... . ......... .. ..... .. ......... . ... . ATAA Payments: . . . . .......... .... ... ... ..... ......... ............. . Tax Withhe l d : . . . . . . . ............................................. . Tax ab le Grants: ...................... .. ..... . ..•.• . . . ... .... . . .... Unemployment Compensation: ................ . ..... . ................ . Agricultural Subsidies: .. .... .. ...... .. ................... .. . . . .. . Prior Vear Refund: . . . . ............. . ...................... . .. . .. . . Market gain on Commodity Credit Corporation loans repaid on or after January 

Vear 

1, 2007: ................... .... .. . . ... .... ... . . . ..... . . ................. - of Refund: .................................. . . ........ . .... .... . .. N~ 1099G Offset : .............. Not Refund, Credit, or Offset for Trade or Business 

Form 1099 - INT 

Payar: · ·cation Number (FIN) 

SAN ANTONIO, TX 78265-0000 

Recipient: 

Recipient's Identification Number 

MI TON L 

L 

Submission Type: ..... . . . .. ..... ........ . .. ... . . . ..... .. .... .. Origi Account Number C Optional): ..................•.......•.•......•.... Interest: ........................................................ . Tax Withhe l d: .................................................... . Savings Bonds: . .... . . ... .... ... ...... . . . .... . . . . ... . . . . ......... . . Investment Expense : ..... . . .. ... . ...... .. . . ... . . . ... . . . . . .. ... . ... . Interest Forfeiture: .......... ..... ... .... ... ... ..............•... Foreign Tax Paid: .•. . ................ . .... . . . ..... . . . . . . .. . . . . .... Tax- Exempt Interest: . ........ . ....... . ........ . ... ... ... .. .... . .. . Specif~ed Private Activity Bond Interest: ........... . ...... . .•.. .. Second Notice Indicator: . .... . . . .................. ... ........ . Foreign Country or US Possession: •.• ... .... . .. . •.... .. .. ... . . . . . . ............. CUSI P Number : ........ .. . . . .... . . .•.. . . . .... ... ... ..... . ... ............... . .. .. 

Form 1099-MISC 

IN):-

NORTH LAS VEGAS, NV 89033-0000 

Recipient: 

Recipient's Identification Number 

Submission Type: . ....................... ... .•...........•. .. . Origina Account Number C Optional): ....... . ............................... . . . Tax Wi thhald: . . ..... .. . . .......................................... . . 

Medical 

Non-Employee Compensation: ...... . ............ . ......... ...... .... .. . Payments: ... ..... , ....................... .... ... ... . . ...... . 

Case 4:18-cv-00806-SBA Document 37-3 Filed 03/02/18 Page 12 of 12