Case 1:11-cv-01258-RBW Document 13-1 Filed 07/20/12 Page 1 of 15

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UNITED STATES DISTRICtr COURT 

FOR THE DISTRICT OF C@LUMBIA 

UNITED STATES OF AMERICA, 

Plaintiff, 

v. 

B. K. H~NRY FUNERAL CHAPEL, INC., 

a District of Columbia corporation; 

BRIAN K. HENRY, individually and as an officer of 

the corporation; and 

LISA HENRY, individually and as an officer Cifthe , . corporation; 

Defendants, 

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). Civil Action No. 11-1258-RBW 

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CONSENT DECREE 

WHEREAS, Plaintiff, the United States of Al1leric~, has commenced this action by filing 

the Complaint herein; Defendants B.K. Henry Funeral Chapel, Inc., Brian K. Henry, and Lisa 

Henry have waived service of the Summons and Complain~; the'parties have been represented by ! . 

the attorneys whose names·appear hereafter; and the partie~ have agreed to settlement ofthis 

action upon the following terms and conditions, without'ad~udication 'of arty issue of fact or law 

1 . 

and without Defen~ants admitting liability for any of thel~atters charged 'in the Complaint other i . 

than jurisdictional facts; I 

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UNITED STATES DISTRICtr COURT 

FOR THE DISTRICT OF C@LUMBIA 

UNITED STATES OF AMERICA, 

Plaintiff, 

v. 

B. K. H~NRY FUNERAL CHAPEL, INC., 

a District of Columbia corporation; 

BRIAN K. HENRY, individually and as an officer of 

the corporation; and 

LISA HENRY, individually and as an officer Cifthe , . corporation; 

Defendants, 

) : 

) : 

. I 

) : 

) 

) : 

). Civil Action No. 11-1258-RBW 

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CONSENT DECREE 

WHEREAS, Plaintiff, the United States of Al1leric~, has commenced this action by filing 

the Complaint herein; Defendants B.K. Henry Funeral Chapel, Inc., Brian K. Henry, and Lisa 

Henry have waived service of the Summons and Complain~; the'parties have been represented by ! . 

the attorneys whose names·appear hereafter; and the partie~ have agreed to settlement ofthis 

action upon the following terms and conditions, without'ad~udication 'of arty issue of fact or law 

1 . 

and without Defen~ants admitting liability for any of thel~atters charged 'in the Complaint other i . 

than jurisdictional facts; I 

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Case 1:11-cv-01258-RBW Document 13-1 Filed 07/20/12 Page 2 of 15

ORDER 

THEREFORE, on the joint motion ofthePlaintiJT and Defendants, it is ORDERED, i 

ADJUDGED, and DECREED as follows: 

FINDINGS 

1. This Court has jurisdiction of the subject matter an;d of the parties. 

2. The Complaint states a claim upon which relief m1Y be granted against the Defendants ! 

under Sections 5(a)(l), 5(m)(1)(A), 13(b), and 16(a) ofth~ Federal Trade Commission Act, 15 

u.s.C. §§ 45(a)(1); 45(m)(I)(A), 53(b), and 56(a). 

3. Venue in this district is proper under 28 U.S.C. §§ j1391 (b-c) and 1395(a).and 15 U.S.C. § 

i 

53(b). I 

I 

4. The activiti.e.s of Defendants are in or affecting cOi~merce as "commerce." is·defined in 

I 

Section 4 of the FTC Act, 15 U.S.C. '§ 44. I 

i 

5. Entry of this Consent Decree is in the public ·intereft. 

6. Defendants stipulate to the entry of this Consent Decree freely and without coercion. 

Defendants further acknowh:~dge that they have read the pl"~)visions of this Consent Decree and 

are prepared to abide by them. 

~ 7. All parties waive all rights to appeal. or otherwise ella Henge or c.ontest the validity of this , 

Consent Decree. 

8. The parties sha..ll ea9h bear their own costs and 'att,9hlj:lYS' fees incurred in this .action. 

1 . 

Defendants waive any clai,m they may have under the Eqq*l Access to Justice Act, 28 U.S.C. § 

i 

2412. i' 

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ORDER 

THEREFORE, on the joint motion ofthePlaintiJT and Defendants, it is ORDERED, i 

ADJUDGED, and DECREED as follows: 

FINDINGS 

1. This Court has jurisdiction of the subject matter an;d of the parties. 

2. The Complaint states a claim upon which relief m1Y be granted against the Defendants ! 

under Sections 5(a)(l), 5(m)(1)(A), 13(b), and 16(a) ofth~ Federal Trade Commission Act, 15 

u.s.C. §§ 45(a)(1); 45(m)(I)(A), 53(b), and 56(a). 

3. Venue in this district is proper under 28 U.S.C. §§ j1391 (b-c) and 1395(a).and 15 U.S.C. § 

i 

53(b). I 

I 

4. The activiti.e.s of Defendants are in or affecting cOi~merce as "commerce." is·defined in 

I 

Section 4 of the FTC Act, 15 U.S.C. '§ 44. I 

i 

5. Entry of this Consent Decree is in the public ·intereft. 

6. Defendants stipulate to the entry of this Consent Decree freely and without coercion. 

Defendants further acknowh:~dge that they have read the pl"~)visions of this Consent Decree and 

are prepared to abide by them. 

~ 7. All parties waive all rights to appeal. or otherwise ella Henge or c.ontest the validity of this , 

Consent Decree. 

8. The parties sha..ll ea9h bear their own costs and 'att,9hlj:lYS' fees incurred in this .action. 

1 . 

Defendants waive any clai,m they may have under the Eqq*l Access to Justice Act, 28 U.S.C. § 

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2412. i' 

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Case 1:11-cv-01258-RBW Document 13-1 Filed 07/20/12 Page 3 of 15

DEFINITIONS 

1. "Individual Defendants" means Brian K. Henry an~ Lisa Henry. 

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2. I 

"Corporate Defendant" means B. K. Henry Funera~ Chapel, Inc., and its successors and 

assigns. 

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3. "Defendants" means all of the lndividual Def~nd~'l.~ts and the Corporate Defendant, 

individually, collectively, or in any combination. 

4. "Funeral Rule" or "Rule" means the Trade Reguhllfion Rule Concerning Funeral Industry , 

Practices issued by the Federal Trade Commission ("FTC'1 or "Commission"), 16 C.F.R. Part , , 

453. Copies of the Funeral Rule 

I. 

and the FTC publication,: "Complying with the Funeral Rule," 

(, 

are attached hereto as Exhibits A and B, respectively, and lincorporated in this Consent Decree as 

iffully set forth herein. 

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! 

I. INJUNCTION! 

. I 

IT IS THEREFORE O:RJ)ERED that Defendf.l1itf: and thejr officers, a,gents, servants, 

employees, successors, attorneys,and all other persons in!aotive concert or participation with'any 

! 

of them whO receive actual Mtke of this' Consent Decree~ypersonal serVice or otherwise, are 

i 

permanently enJoined from violating, directly or through ~ny corporation, subsidiary, division, or I 

I 

<?ther deyice, any provision of the Funeral Rule, including, but not limited to, the Rule's 

prohibitions against: I 

• i 

A. Failing to give consumers who inquire in p,BI'.50n a general price list they can keep 

upon beginning discussion of the overall type of funeral s~rvice or disposition, specific funeral , 

goods or services offered, or the prices of such goods or sierv ices, as required by 16 C.F .R. § 

453.2(b)(4); 

DEFINITIONS 

1. "Individual Defendants" means Brian K. Henry an~ Lisa Henry. 

I 

2. I 

"Corporate Defendant" means B. K. Henry Funera~ Chapel, Inc., and its successors and 

assigns. 

i 

3. "Defendants" means all of the lndividual Def~nd~'l.~ts and the Corporate Defendant, 

individually, collectively, or in any combination. 

4. "Funeral Rule" or "Rule" means the Trade Reguhllfion Rule Concerning Funeral Industry , 

Practices issued by the Federal Trade Commission ("FTC'1 or "Commission"), 16 C.F.R. Part , , 

453. Copies of the Funeral Rule 

I. 

and the FTC publication,: "Complying with the Funeral Rule," 

(, 

are attached hereto as Exhibits A and B, respectively, and lincorporated in this Consent Decree as 

iffully set forth herein. 

j 

! 

I. INJUNCTION! 

. I 

IT IS THEREFORE O:RJ)ERED that Defendf.l1itf: and thejr officers, a,gents, servants, 

employees, successors, attorneys,and all other persons in!aotive concert or participation with'any 

! 

of them whO receive actual Mtke of this' Consent Decree~ypersonal serVice or otherwise, are 

i 

permanently enJoined from violating, directly or through ~ny corporation, subsidiary, division, or I 

I 

<?ther deyice, any provision of the Funeral Rule, including, but not limited to, the Rule's 

prohibitions against: I 

• i 

A. Failing to give consumers who inquire in p,BI'.50n a general price list they can keep 

upon beginning discussion of the overall type of funeral s~rvice or disposition, specific funeral , 

goods or services offered, or the prices of such goods or sierv ices, as required by 16 C.F .R. § 

453.2(b)(4); 
Case 1:11-cv-01258-RBW Document 13-1 Filed 07/20/12 Page 4 of 15

B. F ailing to show conswners who inquire in lierson about the offerings or prices of 

caskets or alternative containers a casket price list upon beginnin:g discussion of caskets, but in 

I 

any event before showing any caskets, models, or pictures pf caskets, as required by 16 C.F.R § 

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453.2(b)(2); I 

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C. . Failing to show consumers who inquire in rlergQl1 about outer burial container 

I 

offerings or prices an outer burial container price list uponlbegiiming discussion of outer burial . , 

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containers, vaults or grave liners, but in any event before sflOWing any outer burial containers, 

i 

models, or pictures thereof, as required by 16 C.P.R. § 45~.2(b)(3); 1 

D. Failing to tell any person who asks'by telep110ne about defendants' offerings or . ! 

, 

prices any accurate information from defendants' price list~ and any other readily available . ! 

information that reasonably.answers the question, as requi1'ed by 16 C.F.R. § 453.2(b)(1); 

E. Fai1i~g to give e~ch person who arranges a Iruneral or othe~ disposition ofhuman 

.r 

remains an' itemized Written statement to keep at the ·conel hs \cHi ofthe discussiori of [. 

arrangements, as required by 16 C.F.R. § 453".2(b)(5); and! ! 

. i . . F. Conditioningtlie furnishing of any futi"era:1.gpod .or funeral"service to a person. 

r 

arranging a fi;meral upon the purchase of any other fuheralrgOOd or funeral service co.ptrary to 16 

j 

C.F.R. § 453.4(b)(i), charging any fee as a condition tofUJrnishing any funeral goods or·funeral . ! • I 

services except as permitted by 16 C.F .R. § 453 .4(b )(ii), olr failing to make the disclosures 

required by 16 C.F.R. § 453.4(b)(2). 

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B. F ailing to show conswners who inquire in lierson about the offerings or prices of 

caskets or alternative containers a casket price list upon beginnin:g discussion of caskets, but in 

I 

any event before showing any caskets, models, or pictures pf caskets, as required by 16 C.F.R § 

! 

453.2(b)(2); I 

I 

C. . Failing to show consumers who inquire in rlergQl1 about outer burial container 

I 

offerings or prices an outer burial container price list uponlbegiiming discussion of outer burial . , 

! 

containers, vaults or grave liners, but in any event before sflOWing any outer burial containers, 

i 

models, or pictures thereof, as required by 16 C.P.R. § 45~.2(b)(3); 1 

D. Failing to tell any person who asks'by telep110ne about defendants' offerings or . ! 

, 

prices any accurate information from defendants' price list~ and any other readily available . ! 

information that reasonably.answers the question, as requi1'ed by 16 C.F.R. § 453.2(b)(1); 

E. Fai1i~g to give e~ch person who arranges a Iruneral or othe~ disposition ofhuman 

.r 

remains an' itemized Written statement to keep at the ·conel hs \cHi ofthe discussiori of [. 

arrangements, as required by 16 C.F.R. § 453".2(b)(5); and! ! 

. i . . F. Conditioningtlie furnishing of any futi"era:1.gpod .or funeral"service to a person. 

r 

arranging a fi;meral upon the purchase of any other fuheralrgOOd or funeral service co.ptrary to 16 

j 

C.F.R. § 453.4(b)(i), charging any fee as a condition tofUJrnishing any funeral goods or·funeral . ! • I 

services except as permitted by 16 C.F .R. § 453 .4(b )(ii), olr failing to make the disclosures 

required by 16 C.F.R. § 453.4(b)(2). 

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Case 1:11-cv-01258-RBW Document 13-1 Filed 07/20/12 Page 5 of 15

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II. CIVIL PENAL T~ : 

IT IS FURTHER ORDERED that: 

A. Defendants shall pay to Plaintiff a civil pen~lty, pursuant to Section 5(JIi)(I)(A) of 

the Federal Trade Commission Act, 15 U.S.C. § 45(m)(I)(~), in the amount of Twenty-Five 

Thousand Dollars ($25,000). 

B. J)ef~ndants shall make the payment requi.rep by Section ILA. in ·installments. 

1 

Within five (5) days ofthe date of entry of this Consent D~cree, Defendants Shall pay an initial 

I 

sulllofFive Thousand Dollars ~$5,-0~O}, followed by twel~.e monthly payments of Six Hundred I '" "--- . . 

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Twenty-Five Dollars ($625)begirining 30 days thereafter. ~lat are due and payable no later than 

i 

the end of each month, with:a final payment of Twelve Thtl!:sand Five Hundred bollars 

($12,500) due 'and payable no later than 30 days after the ·dnaJ monthly payment is due. All ! I 

payments shall be made in the form of a wire transfer or c~rt'ified or cashier's check payable to I 

• J 

the Treasurer of the United States. The checks or written ~~ontinnations of the wire transfers • J 

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shall be delivered in accordance with procedures specified! by the Consumer Protection Branch, 

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'Civil Division, u.s. Department of Justice, Washington, qc 20530. ! 

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C. .i . . ' 

In the event of any default m payment requIred to be made under ·thIS Consent J 

. 1. 

Decree, the entire unpaid penalty; together with interest :f'r?lll.the date of default to the date of 

. I '. 

payment, as corriputed,pursuant to 28 U.S .. C. § 1961, shaUrimmediately become due.and payable. 

i 

D. Defendants· relinquish all dominion,contro~, and title to the funds paid to the 

! 

fullest extent pennitted by law. Defendants shall make nol claimto or demand return of the 

funds, directly or indirectly, through counselor otherwise.! 

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E. In accordance with 31 U.S.C. § 7701, Defehdants are hereby required, unless they ! 

have done so already, to furnish to Pl~intiff and the CQllT111 ission their taxpayer identifying . i . 

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i. 

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II. CIVIL PENAL T~ : 

IT IS FURTHER ORDERED that: 

A. Defendants shall pay to Plaintiff a civil pen~lty, pursuant to Section 5(JIi)(I)(A) of 

the Federal Trade Commission Act, 15 U.S.C. § 45(m)(I)(~), in the amount of Twenty-Five 

Thousand Dollars ($25,000). 

B. J)ef~ndants shall make the payment requi.rep by Section ILA. in ·installments. 

1 

Within five (5) days ofthe date of entry of this Consent D~cree, Defendants Shall pay an initial 

I 

sulllofFive Thousand Dollars ~$5,-0~O}, followed by twel~.e monthly payments of Six Hundred I '" "--- . . 

I 

Twenty-Five Dollars ($625)begirining 30 days thereafter. ~lat are due and payable no later than 

i 

the end of each month, with:a final payment of Twelve Thtl!:sand Five Hundred bollars 

($12,500) due 'and payable no later than 30 days after the ·dnaJ monthly payment is due. All ! I 

payments shall be made in the form of a wire transfer or c~rt'ified or cashier's check payable to I 

• J 

the Treasurer of the United States. The checks or written ~~ontinnations of the wire transfers • J 

. ! 

shall be delivered in accordance with procedures specified! by the Consumer Protection Branch, 

f 

'Civil Division, u.s. Department of Justice, Washington, qc 20530. ! 

! 

C. .i . . ' 

In the event of any default m payment requIred to be made under ·thIS Consent J 

. 1. 

Decree, the entire unpaid penalty; together with interest :f'r?lll.the date of default to the date of 

. I '. 

payment, as corriputed,pursuant to 28 U.S .. C. § 1961, shaUrimmediately become due.and payable. 

i 

D. Defendants· relinquish all dominion,contro~, and title to the funds paid to the 

! 

fullest extent pennitted by law. Defendants shall make nol claimto or demand return of the 

funds, directly or indirectly, through counselor otherwise.! 

! 

E. In accordance with 31 U.S.C. § 7701, Defehdants are hereby required, unless they ! 

have done so already, to furnish to Pl~intiff and the CQllT111 ission their taxpayer identifying . i . 

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i. 

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Case 1:11-cv-01258-RBW Document 13-1 Filed 07/20/12 Page 6 of 15

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1'1' 

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~umbers (sociai security number or employer identificatidn number). Such numbers may be , I 

I 

used for purposes of collecting and reporting on any delinguent amount arising out of 

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Defendants' relationship with the government. I 

I 

F. Defendants agree that the facts as alleged i'11 the Complaint filed in this action , 1 

shall be taken as true, without further proof, in any subseciuent civil litigation filed by or on , 

behalf of the Commission to enfor~e its rights to any paYl~el1t or money judgment pursuant to 

i 

this Consent Decree. 

, f 

G. The Individual Defendants agree that thej4dguiellt represents a civil penalty 1 

owed to the United States Government, is not CQmpensattfn for actual pec~niaiY loss, and" 

" therefore, as to the 1I;1divid~alDefendl:U'l,ts, itis not subjec~:todischarge'u:nderthe Bankruptcy 

Code pllrsuantto 11 lJ.S.C'. §, 523(a)(7). 

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III. COMPLIANCE MON.~TORING , 1 

IT IS FURTHER ORDERED that, for the purpo~e of (i) i:nonitoring and investigating 

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compliance with any provision ofth,is Consent Decree an~ (ii) investigating the accuracy of any 1 

i 

Defendants' financial statements upon which the Commi~sion's.agreem:eilt to thisCorisent 

! 

j 

Decree is expressly premised: I: 

i 

A. Within ten (lO}days of receipt of written ,i~<l'tice from a representative of the . 1.. 

i 

Commission, Defendants shall each submit additional wrl~ten reports, which are true and l' 

I 

accurate and sworn to under penalty ,?f perjury; produce ~pc,urrients for inspectionartd copying: 

i . ,. " 

appear for deposition; and provide entry dutingnOrri:J.al b~sitl:eSs ,hours to any business location in 

, ! 

such Defendant's possession or direct or indirect control ~o inspect the business operation; 

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B. In addition, the Commission is authorized to use all other lawful means, I 

including, but not limited to: 

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i 

i. I, 

1'1' 

I II 

" i 

J i. 

~umbers (sociai security number or employer identificatidn number). Such numbers may be , I 

I 

used for purposes of collecting and reporting on any delinguent amount arising out of 

, ! 

Defendants' relationship with the government. I 

I 

F. Defendants agree that the facts as alleged i'11 the Complaint filed in this action , 1 

shall be taken as true, without further proof, in any subseciuent civil litigation filed by or on , 

behalf of the Commission to enfor~e its rights to any paYl~el1t or money judgment pursuant to 

i 

this Consent Decree. 

, f 

G. The Individual Defendants agree that thej4dguiellt represents a civil penalty 1 

owed to the United States Government, is not CQmpensattfn for actual pec~niaiY loss, and" 

" therefore, as to the 1I;1divid~alDefendl:U'l,ts, itis not subjec~:todischarge'u:nderthe Bankruptcy 

Code pllrsuantto 11 lJ.S.C'. §, 523(a)(7). 

! 

f 

i 

III. COMPLIANCE MON.~TORING , 1 

IT IS FURTHER ORDERED that, for the purpo~e of (i) i:nonitoring and investigating 

! 

compliance with any provision ofth,is Consent Decree an~ (ii) investigating the accuracy of any 1 

i 

Defendants' financial statements upon which the Commi~sion's.agreem:eilt to thisCorisent 

! 

j 

Decree is expressly premised: I: 

i 

A. Within ten (lO}days of receipt of written ,i~<l'tice from a representative of the . 1.. 

i 

Commission, Defendants shall each submit additional wrl~ten reports, which are true and l' 

I 

accurate and sworn to under penalty ,?f perjury; produce ~pc,urrients for inspectionartd copying: 

i . ,. " 

appear for deposition; and provide entry dutingnOrri:J.al b~sitl:eSs ,hours to any business location in 

, ! 

such Defendant's possession or direct or indirect control ~o inspect the business operation; 

! 

B. In addition, the Commission is authorized to use all other lawful means, I 

including, but not limited to: 

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Case 1:11-cv-01258-RBW Document 13-1 Filed 07/20/12 Page 7 of 15

I. 

2. 

Obtaining discovery from any perso~1, without further leave of Court, 

j 

using the procedur~s prescribed by fed. R. Civ. P. 30, 31, 33, 34, 36, 45 

r 

and 69; ., 

Having its representatives pose as C~,nSLllT1erS and suppliers to Defendants, i 

I 

their employees, or any other entity!managed or controlled in whole or in 

! 

part by a Defendant, without the ne~essity of identification or prior notice. 

C. Defendants each shall peflT1it representativ~s of the Commission to interview any 

employer, consultant, independent contractor, representati~le, agent, or employee who has agreed I ' 

to such an interview, relating in any way to any conduct sq,bject to this Consent Decree. The I 

person interviewed may have counsel present. 

l 

!> i. . 

Provided, however, that nothing in this Consent I)~cl'ee shalt limit the Commission's 

lawful use of compulsory process, pursuant to Sections'9.l,ncl 20 ofthe'PTC Act, 15 n-s.C. §§ 

! . ! 

49, 57b-1, to obtain- any documentary material, tangible tl,'ings, testimony, or infonnation 

I 

relevant to unfair or deceptive acts or practices in or affeci:ing comme~ce (within the meaning of 

15 U.S.C. § 45(a)(1)). I 

IV. COMPLIANCE REPbRTING I 

! 

IT IS FURTHER ORDERED that. in order that ?ompliance with the provisions oftMs 

! . 

Consent Decree may be monitored: i 

i 

A. For a period of three (3) years from the dat~ of entry ofthis Consent Decree, I .1 

1. Each Individual Defendant shall no~ify the Commission of the following: I 

a. Any changes in such ,D~fellilant's residence, mailing addresses, , I 

and telephone numbers, within ten b 0) days,ofthe date of such change; 

i , 

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I. 

2. 

Obtaining discovery from any perso~1, without further leave of Court, 

j 

using the procedur~s prescribed by fed. R. Civ. P. 30, 31, 33, 34, 36, 45 

r 

and 69; ., 

Having its representatives pose as C~,nSLllT1erS and suppliers to Defendants, i 

I 

their employees, or any other entity!managed or controlled in whole or in 

! 

part by a Defendant, without the ne~essity of identification or prior notice. 

C. Defendants each shall peflT1it representativ~s of the Commission to interview any 

employer, consultant, independent contractor, representati~le, agent, or employee who has agreed I ' 

to such an interview, relating in any way to any conduct sq,bject to this Consent Decree. The I 

person interviewed may have counsel present. 

l 

!> i. . 

Provided, however, that nothing in this Consent I)~cl'ee shalt limit the Commission's 

lawful use of compulsory process, pursuant to Sections'9.l,ncl 20 ofthe'PTC Act, 15 n-s.C. §§ 

! . ! 

49, 57b-1, to obtain- any documentary material, tangible tl,'ings, testimony, or infonnation 

I 

relevant to unfair or deceptive acts or practices in or affeci:ing comme~ce (within the meaning of 

15 U.S.C. § 45(a)(1)). I 

IV. COMPLIANCE REPbRTING I 

! 

IT IS FURTHER ORDERED that. in order that ?ompliance with the provisions oftMs 

! . 

Consent Decree may be monitored: i 

i 

A. For a period of three (3) years from the dat~ of entry ofthis Consent Decree, I .1 

1. Each Individual Defendant shall no~ify the Commission of the following: I 

a. Any changes in such ,D~fellilant's residence, mailing addresses, , I 

and telephone numbers, within ten b 0) days,ofthe date of such change; 

i , 

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Case 1:11-cv-01258-RBW Document 13-1 Filed 07/20/12 Page 8 of 15

2. 

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b. Any changes in such Defen~~mt's employment status (including 

self-employment), and any change i'n such Defendant's ownership in any 

I 

business entity, within t(;!n (10) dayt of the date of such change. Such 

notice shaH includ(;! the name and a~dress of each business that such 

i 

Defendant is affiliated with, emplohd by, creates or fonns, or perfonns 

1 

services for; a detailed description ~f the nature Qfthe business; and a 

i 

detailed description of such DCfen1~1l1t's dutie~ and re~ponsibUitjes in 

connection with toe business or crn!/loyment; and 

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c. Any changes in such Defen~ant's name or use of any aliases or 

1 

fictitiolls names within ten (10) day,s of the 'date of such change; 

! 

Defendants shall notify the Commi.~sion of any changes in structure of any 

! 

Corporate Defendant or any business ent~t~ that a Defendant directly Or indirectly 

controls, or has an ownership interest in, tllat may affect-compliance qblig!ltion~ 

arising under this Consent Decree, incJudiJg, but not limited to: incorporation or 

. 1: . 

. other organization; a dissolution, assigntneht;.:s~i:le, merger, or other action; the' 

. t 

creation or dissolution ofa .subsidiary,.par111t, or affiliate that engages in an)iacts 

. I 

or practices subjectto this· Consent Decree.! or a change in the business name or 

address, at least thirty (30) days.prior to subh change, provided that, with respect ! 

to any such change in the business entity C1?Out ~hich a Defendant learns less than 

! 

thirty (30) days prior to the date such actioil is to take place, the Defendant shall ! 

notify the Commission as soon as is practiq.ab.le after obtaining such knowledge. 

B. One hundred eighty (180) days after the dtlfe. of entry of this Consent Decree and 

I . 

annually thereafter for a period of three (3) years, Defend~nts shall each provide a written report 

! . 

8 

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2. 

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b. Any changes in such Defen~~mt's employment status (including 

self-employment), and any change i'n such Defendant's ownership in any 

I 

business entity, within t(;!n (10) dayt of the date of such change. Such 

notice shaH includ(;! the name and a~dress of each business that such 

i 

Defendant is affiliated with, emplohd by, creates or fonns, or perfonns 

1 

services for; a detailed description ~f the nature Qfthe business; and a 

i 

detailed description of such DCfen1~1l1t's dutie~ and re~ponsibUitjes in 

connection with toe business or crn!/loyment; and 

i 

c. Any changes in such Defen~ant's name or use of any aliases or 

1 

fictitiolls names within ten (10) day,s of the 'date of such change; 

! 

Defendants shall notify the Commi.~sion of any changes in structure of any 

! 

Corporate Defendant or any business ent~t~ that a Defendant directly Or indirectly 

controls, or has an ownership interest in, tllat may affect-compliance qblig!ltion~ 

arising under this Consent Decree, incJudiJg, but not limited to: incorporation or 

. 1: . 

. other organization; a dissolution, assigntneht;.:s~i:le, merger, or other action; the' 

. t 

creation or dissolution ofa .subsidiary,.par111t, or affiliate that engages in an)iacts 

. I 

or practices subjectto this· Consent Decree.! or a change in the business name or 

address, at least thirty (30) days.prior to subh change, provided that, with respect ! 

to any such change in the business entity C1?Out ~hich a Defendant learns less than 

! 

thirty (30) days prior to the date such actioil is to take place, the Defendant shall ! 

notify the Commission as soon as is practiq.ab.le after obtaining such knowledge. 

B. One hundred eighty (180) days after the dtlfe. of entry of this Consent Decree and 

I . 

annually thereafter for a period of three (3) years, Defend~nts shall each provide a written report 

! . 

8 

! 

! 
Case 1:11-cv-01258-RBW Document 13-1 Filed 07/20/12 Page 9 of 15

~ ! 

i 

, 

iit 

I. 

I 

: 

! 

to the FTC, which is true and accurate and s~om to uriderlpenalty of peIjury, setting forth in 

. detail the manner and fonn in which they have complied 8:~ld are complying with this Consent 

Decree. This report shall include, but no~ be limited to: 

C. 

1. For each Individual Defendant: 

a. Such Defendant's then-curr¢nt residence address, mailing , 

addresses, ~nd telephone numbers; I 

b. Such Defendant's then-cudmt- employment status (including selfi' 

employment), including the name, ~dd.resses, and tel~phone numbers of , 

j. 

each business that such Defendant \s affiliated with, employed by, or , 

performs services for; a detailed de~cription ofthe.·Iiature of the business; 

r 

and a detailed description of such ~efendant' s duties a.li.d responsibilities 

! 

in connection with the business or~'mployment; and 

; 

Any other changes required!.to be reported under Subsection A of 

! 

this Section. 

2. For all Defendants: 

a A copy of each aCknov';led~11ent of receipt of this ConseJ::lt Decree 

i , obtained pursuant to the Section tit~ed "Distribution of Consent Decree;" 

and 

I 

I 

I 

i 

I· b. Any other changes requirec\ to 'be reported under Subsection A of 

! 

this Section. I 

Each Defendant shall notify the Commissi~n of the filing of a bankruptcy petition 

: 

by such Defendant within fifteen (15) days offiling. 

9 

~ ! 

i 

, 

iit 

I. 

I 

: 

! 

to the FTC, which is true and accurate and s~om to uriderlpenalty of peIjury, setting forth in 

. detail the manner and fonn in which they have complied 8:~ld are complying with this Consent 

Decree. This report shall include, but no~ be limited to: 

C. 

1. For each Individual Defendant: 

a. Such Defendant's then-curr¢nt residence address, mailing , 

addresses, ~nd telephone numbers; I 

b. Such Defendant's then-cudmt- employment status (including selfi' 

employment), including the name, ~dd.resses, and tel~phone numbers of , 

j. 

each business that such Defendant \s affiliated with, employed by, or , 

performs services for; a detailed de~cription ofthe.·Iiature of the business; 

r 

and a detailed description of such ~efendant' s duties a.li.d responsibilities 

! 

in connection with the business or~'mployment; and 

; 

Any other changes required!.to be reported under Subsection A of 

! 

this Section. 

2. For all Defendants: 

a A copy of each aCknov';led~11ent of receipt of this ConseJ::lt Decree 

i , obtained pursuant to the Section tit~ed "Distribution of Consent Decree;" 

and 

I 

I 

I 

i 

I· b. Any other changes requirec\ to 'be reported under Subsection A of 

! 

this Section. I 

Each Defendant shall notify the Commissi~n of the filing of a bankruptcy petition 

: 

by such Defendant within fifteen (15) days offiling. 

9 
Case 1:11-cv-01258-RBW Document 13-1 Filed 07/20/12 Page 10 of 15

; 

! 

! 

D. For the purpO$es ofthis Consent Decree, D~fendants shall, unless othenvise 

j 

directed by the Commission's authorized representatives, tend by overnight courier (not the U.s, 

Postal Service) all reports and notifications to the Commis~ion that are required by this Consent 

Decree to: 

Associate Director for Enforcementi 

Bureau of Consumer Protection i 

Federal Trade Commission : 

600 Pennsylvania Avenue, N.W. 

Washington, D.C. 20580 , 

Re: United States v. B.K Henry FUlreral Chapel, 

Inc:, Case No. ] 1-,1258 ": 

I 

Provided that, in lieu of ovemightcourier, Defendtl1ts may 'send stich reports or 

notifi,cation,s by first-class mail, but only if Defendants¢oirtemporaneously sei'id,an electronic 

i, 

version of stich report or notification to the'Coinrriissioii''8.tDEBrlef~ftc:g;oy~ 

E.I:Or:pufposes bfthe compliahce reporting ~'i~d monitoring required by this Consent I ' 

m~cree, the Commission is authorized to communicate 'dir~0t1y with each Defendant. 

! 

I 

V. RECORDKEEPING I 

IT IS FURTHER ORDERED that, for a peribd ok'three (3) years from the date of entry i 

j 

of this Consent Decree, Defendants create certain records,jand retain each such record for five , ! 

(5) years after their creation. Specifically, the, Corporate rbefendant, for any business that has I 

I 

, I 

sold or offered to sell funeral goods, or funeral services, 811d each Individual Defendant, for any ! ' 

such business in which that Defendant, individually or col)eclively with any other Defendant, is a, • i 

majority owner or directly or indirectly contto'ls'h111st maihtain the following records: - ! 

! 

A. Accounting records that reflect the cost of'~oods or services sold, revenues 

! 

generated, and the disbursement of such revenues; 

10 

; 

! 

! 

D. For the purpO$es ofthis Consent Decree, D~fendants shall, unless othenvise 

j 

directed by the Commission's authorized representatives, tend by overnight courier (not the U.s, 

Postal Service) all reports and notifications to the Commis~ion that are required by this Consent 

Decree to: 

Associate Director for Enforcementi 

Bureau of Consumer Protection i 

Federal Trade Commission : 

600 Pennsylvania Avenue, N.W. 

Washington, D.C. 20580 , 

Re: United States v. B.K Henry FUlreral Chapel, 

Inc:, Case No. ] 1-,1258 ": 

I 

Provided that, in lieu of ovemightcourier, Defendtl1ts may 'send stich reports or 

notifi,cation,s by first-class mail, but only if Defendants¢oirtemporaneously sei'id,an electronic 

i, 

version of stich report or notification to the'Coinrriissioii''8.tDEBrlef~ftc:g;oy~ 

E.I:Or:pufposes bfthe compliahce reporting ~'i~d monitoring required by this Consent I ' 

m~cree, the Commission is authorized to communicate 'dir~0t1y with each Defendant. 

! 

I 

V. RECORDKEEPING I 

IT IS FURTHER ORDERED that, for a peribd ok'three (3) years from the date of entry i 

j 

of this Consent Decree, Defendants create certain records,jand retain each such record for five , ! 

(5) years after their creation. Specifically, the, Corporate rbefendant, for any business that has I 

I 

, I 

sold or offered to sell funeral goods, or funeral services, 811d each Individual Defendant, for any ! ' 

such business in which that Defendant, individually or col)eclively with any other Defendant, is a, • i 

majority owner or directly or indirectly contto'ls'h111st maihtain the following records: - ! 

! 

A. Accounting records that reflect the cost of'~oods or services sold, revenues 

! 

generated, and the disbursement of such revenues; 

10 
Case 1:11-cv-01258-RBW Document 13-1 Filed 07/20/12 Page 11 of 15

B. personnel records accurately reflecting: th~name, address, and telephone number 

j 

, 

of each person employed in any capacity by such busines~~ including as an independent 

I 

contractor; that person's job title or position; the date tlPOll which the person commenced work; 

! 

I 

and the date and reason for the person's termination, ifapylicable; 

C. Customer files containing the names, addr~sses, phone numbers, dollar amounts ! 

paid, quantity of items or services purchased, and descript~bn of items or services purchased, to 

i 

the extent the information is obtained in the ordinary cOllr~e of business; 

i 

D. Complaints and refund requests (whether rfceived directly or indirectly, such as 

- i 

through a third party) and any responses to those complaiJ!Jts or requests; 

I 

E. Copies of all price lists, sales scripts, trainihg. materials, advertisements,' or other . ! 

marketJng materials; and I 

~-

F. All records and documents necessary to de~onstrate full compliance with each 

I 

provision of this Consent Decree, -including, but not iimi:ttd to, copies of acknowledgments of 

I 

receipt of this Consent Decree req~ire'd by the S'ectiOns ti~l~d:-"Distdbution of Consent Decree" 

and "Acknowledgment of Receipt of Consent Decree' 8l1'¥ -all reports-submitted to the:FTC 

[ 

pursuant to the Section-titled "Compliance:Reporting." i 

f 

i 

VI. DISTRIBUTION OF CONSENT DECREE' 

! 

IT IS FURTHER ORDERED that, for a period (~fthree (3) years from the date of entry , 

of this C<)TIsent Decree: 

A. Corporate Defendant: The Corporate D~f~ndanfmust deliver a copy of this 

Consent Decree to (1) all of its principals, officers, dkectfl"S, and managers; (2) all of its 

employees, agents, and representatives who engage in co~~duct related to ~he subject matter of the 

Consent Decree,including, but not limited to, all personnbl who h~ve contact with the public; 

f· i 

! 

! 

11 : 

B. personnel records accurately reflecting: th~name, address, and telephone number 

j 

, 

of each person employed in any capacity by such busines~~ including as an independent 

I 

contractor; that person's job title or position; the date tlPOll which the person commenced work; 

! 

I 

and the date and reason for the person's termination, ifapylicable; 

C. Customer files containing the names, addr~sses, phone numbers, dollar amounts ! 

paid, quantity of items or services purchased, and descript~bn of items or services purchased, to 

i 

the extent the information is obtained in the ordinary cOllr~e of business; 

i 

D. Complaints and refund requests (whether rfceived directly or indirectly, such as 

- i 

through a third party) and any responses to those complaiJ!Jts or requests; 

I 

E. Copies of all price lists, sales scripts, trainihg. materials, advertisements,' or other . ! 

marketJng materials; and I 

~-

F. All records and documents necessary to de~onstrate full compliance with each 

I 

provision of this Consent Decree, -including, but not iimi:ttd to, copies of acknowledgments of 

I 

receipt of this Consent Decree req~ire'd by the S'ectiOns ti~l~d:-"Distdbution of Consent Decree" 

and "Acknowledgment of Receipt of Consent Decree' 8l1'¥ -all reports-submitted to the:FTC 

[ 

pursuant to the Section-titled "Compliance:Reporting." i 

f 

i 

VI. DISTRIBUTION OF CONSENT DECREE' 

! 

IT IS FURTHER ORDERED that, for a period (~fthree (3) years from the date of entry , 

of this C<)TIsent Decree: 

A. Corporate Defendant: The Corporate D~f~ndanfmust deliver a copy of this 

Consent Decree to (1) all of its principals, officers, dkectfl"S, and managers; (2) all of its 

employees, agents, and representatives who engage in co~~duct related to ~he subject matter of the 

Consent Decree,including, but not limited to, all personnbl who h~ve contact with the public; 

f· i 

! 

! 

11 : 
Case 1:11-cv-01258-RBW Document 13-1 Filed 07/20/12 Page 12 of 15

and (3) any business entity resulting from any change in structure set forth in Subsection A.2 of 

the Section titled "Compliance Reporting." For current perSOllJH.H, delivery shall be within five 

(5) days of service of this Consent Decree upon such Defehdant. For new personnel, delivery . I 

I 

I 

shall occur prior to them assuming their responsibilities. ~or any business entity resulting from 

I 

any change in structure set forth in Subsection A.2 of the gection titled "Compliance Reporting," 

delivery shall be at least ten (l0) 'days prior to the change i~l: structure. i 

, B. IndiVidual Defendant as controiperson: Folr any business that an Individual 

Defendant controls, directly or indirectly, or in which sucli Defendant has a majority ownership 

. i 

interest, such Defendant must deliver a copy of this Consel1t" Decree to (1) all principals, officers, I 

directors, and managers of that business; (2) all employeeS" agents, and representatives of that I • 

business who engage in conduct related to the subject m8tler 'ofthe Consent Decree including, I 

i 

but not limited to, all personnel who have contact with thej public; and (3) any business entity 

I 1 

resulting from any change in structure set forth in SubsectjQI1 A.2 of the Section titled 

, ! ~~ . "Compliance Reporting." For current personnel, delivery ISh all be within five (5) days of serviCe. 

i , ! .. 

of this Consent Decree upon such Defendant. F ot new :p~t.son nel, delivery shall occur prior to 

. I 

. I . .. them assuming their responsibilities. For any 'pusiness en~itY"fesulting from::any change in I 

.1 

structure set forth in Subsection A.2 ofthe Section titled ~:Comp liance Reporting,'; deljyery sh~lI. i . 

be at least ten (10) days prior to the change in structure. 1 

! 

I . 

C. Individual Defendant as employee or non~4011trol'person: For any business where 

an Individual Defendant is not a controlling person of a business but otherwise engages in . I 

; 

conduct related to the subject matter of this Consent Decr~e, such Defendant must deliver a copy 

1 

of this Consent Decree to all principals and managers OfS~lCh business before engaging in such 

conduct. 

12 

and (3) any business entity resulting from any change in structure set forth in Subsection A.2 of 

the Section titled "Compliance Reporting." For current perSOllJH.H, delivery shall be within five 

(5) days of service of this Consent Decree upon such Defehdant. For new personnel, delivery . I 

I 

I 

shall occur prior to them assuming their responsibilities. ~or any business entity resulting from 

I 

any change in structure set forth in Subsection A.2 of the gection titled "Compliance Reporting," 

delivery shall be at least ten (l0) 'days prior to the change i~l: structure. i 

, B. IndiVidual Defendant as controiperson: Folr any business that an Individual 

Defendant controls, directly or indirectly, or in which sucli Defendant has a majority ownership 

. i 

interest, such Defendant must deliver a copy of this Consel1t" Decree to (1) all principals, officers, I 

directors, and managers of that business; (2) all employeeS" agents, and representatives of that I • 

business who engage in conduct related to the subject m8tler 'ofthe Consent Decree including, I 

i 

but not limited to, all personnel who have contact with thej public; and (3) any business entity 

I 1 

resulting from any change in structure set forth in SubsectjQI1 A.2 of the Section titled 

, ! ~~ . "Compliance Reporting." For current personnel, delivery ISh all be within five (5) days of serviCe. 

i , ! .. 

of this Consent Decree upon such Defendant. F ot new :p~t.son nel, delivery shall occur prior to 

. I 

. I . .. them assuming their responsibilities. For any 'pusiness en~itY"fesulting from::any change in I 

.1 

structure set forth in Subsection A.2 ofthe Section titled ~:Comp liance Reporting,'; deljyery sh~lI. i . 

be at least ten (10) days prior to the change in structure. 1 

! 

I . 

C. Individual Defendant as employee or non~4011trol'person: For any business where 

an Individual Defendant is not a controlling person of a business but otherwise engages in . I 

; 

conduct related to the subject matter of this Consent Decr~e, such Defendant must deliver a copy 

1 

of this Consent Decree to all principals and managers OfS~lCh business before engaging in such 

conduct. 

12 
Case 1:11-cv-01258-RBW Document 13-1 Filed 07/20/12 Page 13 of 15

i 

i 

D. Defendants mu,st secure a signed and date9 statement acknowledging receipt of 

i , , this Consent Decree within thirty (30) days of delivery, fi~om all persons receiving copies of the . ! 

Consent Decree, pursuant to this Section. 

, 

VII. ACKNOWLEDGMENT OF RECEIPT' OF CONSENT DECREE" 

I 

IT IS FURTHER ORDERED that each Defenddnt, within five (5) business days of i 

i 

receipt of this Consent Decree as entered by the Court"mtlst submit to the Commission a truthful 

j. 

sworn statement acknowledgi,ng receipt of this Consent d,ecte'e. 

i 

t 

VIII. RETENTION OF JURtlSDICTION , '" '" f '" , 

IT IS FURTHER ORDE;RED that this Court. $h~n retain jurisdiction of this matter for 

purposes of construction, ~odification, and enforcement ~fthiS Consent Decree. 

! 

! 

JUDGMENT IS THEREFORE ENTERED in t'avor of Plaintiff and against 

Defendants, pursuant to all the terms and conditions recitrd above. 

f 

i 

ENTERED; this '__ d ay 0 f __ --'--'-____ ~..:...',' '''''~', ~Oi'J~' . .<.0,:, 

UNITED STATES DISTRICT JUDGE 

13 

I 

;. 

i 

i 

D. Defendants mu,st secure a signed and date9 statement acknowledging receipt of 

i , , this Consent Decree within thirty (30) days of delivery, fi~om all persons receiving copies of the . ! 

Consent Decree, pursuant to this Section. 

, 

VII. ACKNOWLEDGMENT OF RECEIPT' OF CONSENT DECREE" 

I 

IT IS FURTHER ORDERED that each Defenddnt, within five (5) business days of i 

i 

receipt of this Consent Decree as entered by the Court"mtlst submit to the Commission a truthful 

j. 

sworn statement acknowledgi,ng receipt of this Consent d,ecte'e. 

i 

t 

VIII. RETENTION OF JURtlSDICTION , '" '" f '" , 

IT IS FURTHER ORDE;RED that this Court. $h~n retain jurisdiction of this matter for 

purposes of construction, ~odification, and enforcement ~fthiS Consent Decree. 

! 

! 

JUDGMENT IS THEREFORE ENTERED in t'avor of Plaintiff and against 

Defendants, pursuant to all the terms and conditions recitrd above. 

f 

i 

ENTERED; this '__ d ay 0 f __ --'--'-____ ~..:...',' '''''~', ~Oi'J~' . .<.0,:, 

UNITED STATES DISTRICT JUDGE 

13 

I 

;. 
Case 1:11-cv-01258-RBW Document 13-1 Filed 07/20/12 Page 14 of 15

i 

The parties, by their respective counsel, consent tol the tenns and conditions of the 

Consent Decree as set forth above and consent to the entd thereof. 

FOR THE FEDERAL TRADE 

COMMISSION: 

WILLARD K. TOM 

General Counsel 

LOIS C. GREISMAN 

nr::: II 

Attorney 

~~W· 

Federal Trade Commission 

600 Pennsylvania Ave. N.W. 

Washington, D~C. 20580 

(202) 326-:l970 (Office) 

(202) 326-3395 (Facsimile) 

14 

I 

FOR!TBE UNITED STATES 

OFAMERlCA: ! 

RONALD C. MACHEN, JR. 

Unit~d States Attorney 

Distr~ct of Columbia 

STuART F. DELERY 

Actil~ Assistant Attorney General , ~ 

MAAME EWUSI-MENSAH FRIMPONG 

Actirk Deputy Assistant Attorney General 

i 

! 

MIC*A.EL S. BLUME 

Director . I 

I(EN~ETH i.. JOST 

Depuj,?, Director ~ 

~ .. 

Trial (Attorney 

Consumet· Protection Branch 

Unit~ States Department of Justice 

P.O. BOX 386 

Was~ington, D.C. 20044 

(202); 532-4721 (Office) 

(2021514-8742 (Facsimile) 

, I 

1 

i 

) 

I 

i 

1· I 

i 

The parties, by their respective counsel, consent tol the tenns and conditions of the 

Consent Decree as set forth above and consent to the entd thereof. 

FOR THE FEDERAL TRADE 

COMMISSION: 

WILLARD K. TOM 

General Counsel 

LOIS C. GREISMAN 

Attorney 

r~~ ~~W· 

Federal Trade Commission 

600 Pennsylvania Ave. N.W. 

Washington, D~C. 20580 

(202) 326-:l970 (Office) 

(202) 326-3395 (Facsimile) 

14 

I 

FOR!TBE UNITED STATES 

OFAMERlCA: ! 

RONALD C. MACHEN, JR. 

Unit~d States Attorney 

Distr~ct of Columbia 

STuART F. DELERY 

Actil~ Assistant Attorney General , ~ 

MAAME EWUSI-MENSAH FRIMPONG 

Actirk Deputy Assistant Attorney General 

i 

! 

MIC*A.EL S. BLUME 

Director . I 

I(EN~ETH i.. JOST 

DePt: Director ~ 

c~ .. 

Trial (Attorney 

Consumet· Protection Branch 

Unit~ States Department of Justice 

P.O. BOX 386 

Was~ington, D.C. 20044 

(202); 532-4721 (Office) 

(2021514-8742 (Facsimile) 

, I 

1 

i 

) 

I 

i 

1· I 
Case 1:11-cv-01258-RBW Document 13-1 Filed 07/20/12 Page 15 of 15

FOR THE DEFENDANTS: 

,.' .""''''', /.'1 1 / i~"'/ ., ""'"·"'1.1 /(' /,·· ........ ·fj . ( A .J/dd ...f / La.4{~·)"4,, .. f •. 

'tr.SA H~~RY \. ' ". . ./ ... / . 

;P} / / /7/'/ Cj . #;' ,'" p;~r/ / ;y ~(47)~?-f(jl~_~ ... ,,",.-."--

KARL CHEN . 

Counsel for defendants 

CHEN Law, PLLC 

1629 K Street, N.W., Suite 3.00 

Washington, D.C. 2.0.0.06 

C202) 6.0.0-7682 (Office) 

.l~ 888-798-93.06 (Facsimile) 

15 

FOR THE DEFENDANTS: 

H.R17\"N K .. HEim Y 

,.' .""''''', /.'1 1 / i~"'/ ., ""'"·"'1.1 /(' /,·· ........ ·fj . ( A .J/dd ...f / .l,/24{~·)"4,, .. f •. 

'tr.SA H~~RY \. ' ". . ./ ... / . 

/P) / / /y /'/ Cj . #;' ,'" p;~r/ / ;y ~4t7)~?-f(jl~_~ ... ,,",.-."--

KARL CHEN . 

Counsel for defendants 

CHEN Law, PLLC 

1629 K Street, N.W., Suite 3.00 

Washington, D.C. 2.0.0.06 

C202) 6.0.0-7682 (Office) 

.l~ 888-798-93.06 (Facsimile) 

15