UNITED STATES DISTRICT COURT 

DISTRICT OF MARYLAND 

FEDERAL TRADE COMMISSION, 

Plaintiff,· 

v. 

PASSPORT AUTOMOTIVE GROUP, INC., a 

corporation, 

PASSPORT MOTORCARS, INC., a corporation, 

also d/b/a as PASSPORT NISSAN OF MARLOW 

HEIGHTS, also d/b/a as PASSPORT NISSAN OF 

VIRGINIA, also d/b/a as PASSPORT INFINITI 

. OF ALEXANDRIA, 

IMPORT MOTORCARS, INC., a corporation, 

also d/b/a PASSPORT MAZDA, 

AUTOS INTERNATIONAL, INC., a corporation, 

also d/b/a PASSPORT INFINITI OF SUITLAND, 

PASSPORT IMPORTS, INC., a corporation, also 

d/b/a PASSPORT TOYOTA, 

PASSPORT MOTORS HOLDING, INC., a 

corporation, also d/b/a PASSPORT MINI OF 

MONTGOMERY COUNTY, 

PASSPORT OF ALEXANDRIA, INC., a 

corporation, also d/b/a PASSPORT MINI OF 

ALEXANDRIA, 

INTERNATIONAL MOTORCARS, INC., a 

corporation, also d/b/a PASSPORT BMW, 

Page I of 18 

Case No. TDC-22-2670 

STIPULATED ORDER FOR . 

PERMANENT INJUNCTION, 

MONETARY JUDGMENT, AND 

OTHER RELIEF 

Case 8:22-cv-02670-TDC Document 10 Filed 10/21/22 Page 1 of 18 
EVERETT HELLMUTH, III, individually and as 

an owner of PASSPORT AUTOMOTIVE 

GROUP, INC., PASSPORT MOTORCARS, 

INC., IMPORT MOTORCARS, INC., AUTOS 

INTERNATIONAL, INC., PASSPORT 

IMPORTS, INC., PASSPORT MOTORS 

HOLDING, INC., PASSPORT OF 

ALEXANDRIA, INC., and INTERNATIONAL 

MOTORCARS, INC., and 

' JAY KLEIN, individually and as an officer of 

PASSPORT MOTORCARS, INC., IMPORT 

MOTORCARS, INC., AUTOS 

INTERNATIONAL, INC., PASSPORT 

IMPORTS, INC., PASSPORT MOTORS 

HOLDING, INC., PASSPORT OF 

ALEXANDRIA, INC., and INTERNATIONAL 

MOTORCARS, INC. 

Defendants. 

Plaintiff the Federal Trade Commission ("Commission" or "FTC"), filed its Complaint for 

Permanent Injunction, Monetary Relief, and Other Relief ("Complaint"), for a permanent 

injunction and other relief in this matter, pursuant to Sections 5(a), 13(b ), and 19 of the Federal 

Trade Commission Act ("FTC Act"), 15 U.S.C. §§ 45(a), 53(b), and 57b, and the Equal Credit 

Opportunity Act ("ECOA''), 15 U.S.C. §§ 1691-169!f. The Commission and Defendants 

stipulate to the entry of this Stipulated Order for Permanent Injunction, Monetary Judgment, and 

Other Relief ("Order") to resolve all matters in dispute in this action between them. 

THEREFORE, IT IS ORDERED as follows: 

FINDINGS 

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Case 8:22-cv-02670-TDC Document 10 Filed 10/21/22 Page 2 of 18 
I. . This Court has jurisdiction over this matter. 

2. The Complaint charges that Defendants participated in deceptive and unfair acts or 

practices in violation of Section 5(a) of the FTC Act, 15 U.S.C. § 45(a), and the Equal Credit 

Opportunity Act ("ECOA'') and its implementing Regulation B, 12 C.F.R. § 202, in the 

advertising, sales, and financing of motor vehicles. 

3. Defendants neither admit nor deny any of the allegations in the Complaint, except as 

specifically stated in this Order. Only for purposes of this action, Defendants admit the facts 

necessary to establish jurisc!iction. 

4. Defendants waive any claim that they may have under the Equal Access to Justice Act, 28 

U.S.C. § 2412, concerning the prosecution of this action through the date of this Order, and agree 0 

to bear their own costs and attorney fees. 

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

contest the validity of this Order. 

DEFINITIONS 

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

A. "Buy rate" means the lowest interest rate at which any assignee will purchase the 

contract. 

B. "Clearly and conspicuously" means that a required disclosure is difficult to miss (i.e., 

easily noticeable) and easily understandable by ordinary consuroers, including in an of the 

following ways: 

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Case 8:22-cv-02670-TDC Document 10 Filed 10/21/22 Page 3 of 18 
1. In any communication that is solely visual or solely audible, the disclosure must be 

made through the same means through which the communication is presented. In any 

communication made through both visual and audible means, such as a television 

advertisement, the disclosure must be presented simultaneously in both the visual and 

audible portions of the communication even if the representation requiring the disclosure 

is made in only one means. 

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

other characteristics, must stand out from any accompanying text or other visual elements 

so that it is easily noticed, read, and understood. 

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

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

and understand it. 

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

or software, the disclosure must be unavoidable. 

5. The disclosure must use diction and syntax understandable to ordinary consumers 

and must appear in each language in which the representation that requires the disclosure 

appears. 

6. The disclosure must comply with these requirements in each medium through 

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

7. The disclosure must not be contradicted or mitigated by, or inconsistent :-vith, 

anything else in the communication. 

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Case 8:22-cv-02670-TDC Document 10 Filed 10/21/22 Page 4 of 18 
8. When the representation or ·sales practice targets a specific audience, such as 

children, the elderly, or the terminally ill, "ordinary consumers" includes reasonable 

members of that group. 

C. "Defendants" means all of the Individual Defendants and the Corporate Defendants, 

individually, collectively, or in any combination. 

1. "Corporate Defendants" means Passport Automotive Group, Inc.; Passport 

Motorcars, Inc., also d/b/a Passport Nissan of Marlow Heights, also d/b/a Passport Nissan 

, 

of Virginia, also d/b/a Passport Infiniti of Alexandria; Import Motorcars, Inc., also d/b/a 

· Passport Mazda; Autos International, Inc., also d/b/a Passport Infiniti of Suitland; Passport 

Imports, Inc., also d/b/a Passport Toyota; International Motor Cars, Inc., also d/b/a 

Passport BMW; Passport Motors Holding, Inc., also d/b/a Passport MINI of Montgomery 

County; Passport of Alexandria, Inc., also d/b/a Passport MINI of Alexandria; and their 

successors and assigns. 

2. "Individual Defendants" means Everett A. Hellmuth, III and Jay Klein. 

D. "Express, Informed Consent" means an affirmative act communicating unambiguous 

assent to be charged, made after· receiving and jn close proximity to a Clear and Conspicuous 

disclosure, orally and in writing, of the following: 

1. what the charge is for; and 

2. the amount of the charge(s), including if the charge is for a product or service: all 

fees and costs to be charged to the consumer over the period of repayment with and without the 

product or service. 

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Case 8:22-cv-02670-TDC Document 10 Filed 10/21/22 Page 5 of 18 
ORDER 

I. PROffiBITION AGAINST MISREPRESENTATIONS 

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

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

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

advertising, marketing, promotion, offering for sale or financing, or sale and fmancing of vehicles 

are permanently restrained and enjoined from misrepresenting, expressly or by implication: 

A. the costs or terms of purchasing, fmancing, or leasing a vehicle; 

B. the availability of vehicles at an advertised price; 

C. whether charges, products, or services are optional or required; 

D. whether charges, products, or services are authorized by consumers; and 

E. any material fact, including all material restrictions, limitations, or conditions 

applicab_le to the purchase, receipt, or use of any product or service for which a charge is 

incurred. 

II. PROffiBITION AGAINST UNLAWFUL CREDIT DISCRIMINATION 

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

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

receive actual notice of this Order, whether acting directly or indirectly, are permanently 

restrained and enjoined from: 

A. discriminating against any credit applicant: 

1.. on the basis of race, color, religion, national origin, sex or marital status, or 

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Case 8:22-cv-02670-TDC Document 10 Filed 10/21/22 Page 6 of 18 
age (provided the applicant has the capacity to contract); 

2. because all or part of the applicant's income derives from any public 

assistance program; or 

3". because the applicant has in good faith exercised any right under the 

Consumer Credit Protection Act, §§ 1601-1693r, a copy of which is attached; or 

B. failing to comply with the Equal Credit Opportunity Act, 15 U.S.C. §§ 1691-

1691f, and Regulation B, 12 C.F.R. § 202 ("ECOA''), a copy of which is attached. 

III. FAiR LENDING PROGRAM 

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

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

receive actual notice of this Order, whether acting directly or indirectly, shall not participate in the 

extension, renewal, or continuation of credit unless they establish and implement, and thereafter 

maintain, a fair lending program ("Fair Lending Program") that safeguards against discrimination 

against credit applicants on a basis prohibited by this Order or by law. To satisfy this 

requirement, Defendants must, at a minimum: 

A. Designate a fmance director and/or senior finance manager qualified in fair lending 

compliance as the fair lending compliance officer responsible for the Fair Lending 

Program; 

B. Ensure all employees, before engaging in the extension, renewal, or continuation 

of credit, and at least once every twelve ( 12) months, receive training from an independent 

qualified person or organization on the Fair Lending Program, the requirements of the 

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Case 8:22-cv-02670-TDC Document 10 Filed 10/21/22 Page 7 of 18 
ECOA, and Defendants' obligations under the ECOA, and sign an acknowledgement that 

states that the employee: (1) completed the training, (2) had the opportunity to have 

questions about his or her legal responsibilities answered, and (3) understands his or her 

legal responsibilities not to discriminate under the federal fair lending laws; 

C. Implement and maintain written guidelines specifying the reasons for assessing or 

not assessing any fee or other charge and each factor Defendants may consider in 

calculating any such charge, each of which must be objective and none of which can be 

discriminatory; 

D. At each of Defendants' dealership locations: 

I. Offer a subvented retail installment sales contract to each consumer who is 

eligible; and 

2. On an annual basis, choose to and thereafter either: 

a. Charge an interest rate not greater than the Buy Rate on all retail 

installment sales contracts; or 

b. Charge the same number of basis points (not to exceed IOO) above 

the Buy Rate on all non-subvented retail installment sales contracts; 

E. · Promptly terminate employees engaged in discriminatory conduct or conduct that 

violates the Fair Lending Program or any term of Sections I through III and V of this 

Order; and 

F. For 20 years after entry of this Order, within 14 days ofreceiving, whether directly 

or indirectly, such as through a third party, a complaint of discrimination relating to a 

Page 8 ofl8 

Case 8:22-cv-02670-TDC Document 10 Filed 10/21/22 Page 8 of 18 
motor vehicle transaction against Defendants or any of Defendants' officers, agents, or 

employees, submit a copy, along with any response, to the Commission pursuant to the . . 

Section titled "Compliance Reporting." 

Provided, however, that nothing in this Order shall be construed as permitting any conduct 

that overtly, in treatment, or in effect discriminates against consumers on the basis of race, 

color, national origin, or any other protected characteristic or violates the ECOA or any ' . 

other law. 

IV. OBTAINING EXPRESS INFORMED CONSENT FOR ALL CHARGES 

IT IS FURTHER ORDERED THAT Defendants, Defendants' officers, agents, employees, 

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

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

sale or lease of motor vehicles, are permanently restrained and enjoined from charging a 

consumer without having obtained the consumer's Express, Informed Consent. 

V. MONETARY JUDGMENT 

IT IS FURTHER ORDERED that: 

A. Judgment in the amount of Three Million, Three Hundred Eighty Thousand 

Dollars ($3,380,000) is entered in favor of the Commission against Defendants,jointly 

and severally, as monetary relief. 

B. Defendants are ordered to pay to the Commission Three Million, Three Hundred 

Eighty Thousand Dollars ($3,380,000), which, as Defendants stipulate, their undersigned 

counsel holds in escrow for no purpose other than payment to the Commission. Such 

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Case 8:22-cv-02670-TDC Document 10 Filed 10/21/22 Page 9 of 18 
payment must be made within 7 days of entry of this Order by electronic fund transfer in 

accordance with instructions previously provided by a representative _of the Commission. 

D. Defendants relinquish dominion and all legal and equitable right, title, and interest 

in all assets transferred pursuant to this Order and may not seek the return of any assets. 

E. The facts alleged in the Complaint will be taken as true, without further proof, in 

any subsequent civil litigation by or on behalf of the Commission, including in a 

proceeding to enforce its rights to any payment or monetary judgment pursuant to this 

Order, such as a nondischargeability complaint in any bankruptcy case. 

F. The facts alleged in the Complaint establish all elements necessary to sustain an 

action by the Commission pursuant to Section 523(a)(2)(A) of the Bankruptcy Code, 11 

U.S.C. § 523(a)(2)(A), and this Order will have collateral estoppel effect for such 

purposes. 

H. Defendants acknowledge that their Taxpayer Identification Numbers (Social 

. Security Numbers or Employer Identification Numbers), which Defendants must submit to 

the Commission, may be used for collecting and reporting on any delinquent amount 

arising out of this Order, in accordance with 31 U.S.C. §7701. 

I. All money received by the Commission pursuant to this Order may be deposited 

into a fund administered by the Commission or its designee to be used for consumer relief, 

such as redress and any attendant expenses .for the administration of any redress fund. If 

a representative of the Commission decides that direct redress to consumers is wholly or 

partially impracticable or money remains after such redress is completed, the Commission 

Page IO of 18 

Case 8:22-cv-02670-TDC Document 10 Filed 10/21/22 Page 10 of 18 
may apply any remaining money for such related relief (including consumer information 

remedies) as it determines to be reasonably related to Defendants' practices alleged in the 

Complaint. · Any money not used for relief is to be deposited to the U.S. Treasury. 

Defendants have no right to challenge any actions the Commission or its representatives 

may take pursuant to this Subsection. 

VI. CUSTOMER INFORMATION 

IT IS FURTHER.ORDERED that Defendants, Defendants' officers, agents, employees 

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

of this Order, are permanently restrained and enjoined from directly or indirectly failing to 

provide sufficient customer information to enable the Commission to efficiently administer 

consumer redress. If a representative of the Commission requests in writing any information 

related to redress, Defendants must provide it, in the form prescribed by the Commission, within 

14 days. 

VII. ORDER ACKNOWLEDGMENTS 

IT IS FURTHER ORDERED that Defendants obtain acknowledgments ofreceipt of this 

Orqer: 

A. . Each Defendant, within 7 days of entry of this Order, must submit to the 

Commission an acknowledgment of receipt of this Order sworn under penalty of perjury. 

B. For 5 years after entry of this Order, each Individual Defendant for any business 

· that such Defendant, individually or collectively with any other Defendants, is the 

majority owner or controls directly or indirectly, and each Corporate Defendant, must. 

Page 11 of 18 

Case 8:22-cv-02670-TDC Document 10 Filed 10/21/22 Page 11 of 18 
deliver a copy of this Order to: (1) all principals, officers, directors, and LLC managers 

and members; (2) all employees having managerial responsibilities for conduct related to 

the subject matter of the Order and all agents and representatives who participate in the 

advertising, marketing, promotion, offering for sale or financing, or sale and financing of 

vehicles; and (3) any business entity resulting from any change in structure as set forth in 

the Section titled Compliance Reporting. Delivery must occur within 7 days of entry of 

this Order for current personnel. For all others, delivery must occur before they assume 

their responsibilities. 

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

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

receipt of this Order. · 

VIII. COMPLIANCE REPORTING 

IT IS FURTHER ORDERED that Defendants make timely submissions to the 

Commission: 

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

report, sworn under penalty of perjury: 

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

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

representatives of the Commission may use to commllllicate with Defendant; (b) 

identify all of that Defendant's businesses by all of their names, telephone 

. numbers, and physical, postal, email, and Internet addresses; ( c) describe the 

Page 12 of 18 

Case 8:22-cv-02670-TDC Document 10 Filed 10/21/22 Page 12 of 18 
activities of each business, including the goods and services offered, the means of 

advertising, marketing, and sales, and the involvement of any other Defendant 

(which Individual Defendants must describe if they know or should know due to 

their own involvement); (d) describe in detail whether and how that Defendant is 

in compliance with each Section of this Order; and ( e) provide a copy of each 

. ' 

Order Acknowledgment obtained pursuant to this Order, unless previously 

submitted to the Commission. 

2. Additionally, each Individual Defendant must: (a) identify all telephone 

numbers and all physical, postal, email and-Internet addresses, including all 

residences; (b) identify all business activities, including any business for which 

such Defendant performs services whether as an employee or otherwise and any 

entity in which such Defendant has any ownership interest; and ( c) describe in 

detail such Defendant's.involvement in each such business, including title, role, 

responsibilities, participation, authority, control, and any ownership . 

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

notice, sworn under penalty of perjury, within 14 days of any change in the following: 

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

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

Defendant has any ownership interest in or controls directly or indirectly that may 

affect compliance obligations arising under this Order, including: creation, 

merger, sale, or dissolution of the entity or any subsidiary, parent, or affiliate that 

Page 13 of 18 

Case 8:22-cv-02670-TDC Document 10 Filed 10/21/22 Page 13 of 18 
engages in any acts or practices subject to this Order. 

2. Additionally, each Individual Defendant must report any change in: (a) 

name, including aliases or fictitious name, or residence address; or (b) title or role 

in any business activity, including any business for which such Defendant 

performs services whether as an employee or otherwise and any entity in which 

such Defendant has any ownership interest, and identify the name, physical 

address, and any Internet address of the business or entity. 

C. Each Defendant must submit to the Commissionnotice of the filing of any 

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

Defendant within 14 days of its filing. 

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

penalty of perjury must be true and accurate and comply with 28 U.S.C. § 1746, such as 

by concluding: "I declare under penalty of perjury under the la~s of the United States of 

America that the foregoing is true and correct. Executed on: __ " and supplying the 

date, signatory's full name, title (if applicable), and signature. 

E. Unless otherwise directed by a Commission representative in writing, all 

_submissions to the Commission pursuant to this Order must be emailed to 

DEbrief@ftc.gov or sent by overnight courier (not the U.S. Postal Service) to: Associate 

Director for Enforcement, Bureau of Consumer Protection, Federal Trade Commission, 

600 Pennsylvania Avenue NW, Washington, DC 20580. The subject line must begin: 

FTC v. Passport Motorcars, Inc. 

Page 14 of 18 

Case 8:22-cv-02670-TDC Document 10 Filed 10/21/22 Page 14 of 18 
IX. RECORDKEEPING 

IT IS FURTHER ORDERED that Defendants must create certain records for 20 years 

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

Defendant and each Individual Defendant for any business that such Defendant, individually or 

collectively with any other Defendants, is a majority owner or controls directly or indirectly, must 

create and retain the following records: 

A. accounting records showing the revenues from all goods or services sold; 

B. personnel records showing, for each person providing services, whether as an 

employee or otherwise, that person's: name; addresses; telephone numbers; job title or 

position; dates of service; and (if applicable) the reason for termination; 

C. records of all consumer complaints and refund requests, whether received directly 

or indirectly, such as through a third party, and any response. For purposes of this 

provision, consumer complaint( s) shall mean any written, oral, or electronic allegation, 

charge, claim, demand, dispute, or lawsuit concerning the subject matter of the Order; 

D. a copy of each unique advertisem.ent or other marketing material; 

E. each employee's Fair Lending Training Acknowledgement Form; and 

F. all records necessary to demonstrate full compliance with each provision of this 

Order, including all submissions to the Commission. 

X. COMPLIANCE MONITORING 

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

with this Order and any failure to transfer any assets as required by this Order: 

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Case 8:22-cv-02670-TDC Document 10 Filed 10/21/22 Page 15 of 18 
A. Within 14 days of receipt of a written request from a representative of the 

Comm.ission, each Defendant must: submit additional compliance reports or other 

requested information, which must be sworn under pena\ty of perjury; appear for 

depositions; and produce documents for inspection and copying. The Commission is also 

authorized to obtain discovery, without further leave of court, using any of the procedures 

prescribed by Federal Rules of Civil Procedure 29, 30 (including telephonic depositions), 

31, 33, 34, 36, 45, and 69. 

B. For matters concerning this Order, the Commission is authorized to communicate· 

directly with each Defendant. Defendant must permit representatives of the Commission 

to interview any employee or other person affiliated with any Defendant who has agreed 

to such an interview. The person interviewed may have counsel present. 

C. The Commission may use all other lawful means, including posing, through its 

representatives as consumers, suppliers, or other individuals or entities, to Defendants or 

any individual or entity affiliated with Defendants, without the necessity of identification 

or prior notice. Nothing in this Order limits the Commission's lawful use of compulsory 

process, pursuant to Sections 9 and 20 of the FTC Act, 15 U.S.C. §§ 49, 57b-l. 

D. Upon written request from a representative of the Commission, any consumer 

reporting agency must furnish consumer reports concerning Individual Defendants, 

pursuant to Section 604(1) of the Fair Credit Reporting Act, 15 U.S.C. §168lb(a)(l). 

XI. RETENTION OF JURISDICTION 

IT IS FURTHER ORDERED that this Court retains jurisdiction of this matter for purposes 

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Case 8:22-cv-02670-TDC Document 10 Filed 10/21/22 Page 16 of 18 
of construction, modification, and enforcement of this Order. 

SO ORDERED this ~ day of _ _.6_r,...._.k .... l,.__.w' ....___ __ _,, 2022. 

SO STIPULATED AND AGREED: 

FOR PLAINTIFF: 

FEDERAL TRADE COMMISSION 

s~~644nsamue1 Jaco~ 

Larkin Turner 

Attorneys 

Federal Trade Commission 

600 Pennsylvania Ave. NW 

Washington, DC 20580 

Tel: 202-876-5590 (Jacobson) 

Fax: 202-326-3768 

Email: sjacobson@ftc.gov 

Page 17 of 18 

JUDGE 

Case 8:22-cv-02670-TDC Document 10 Filed 10/21/22 Page 17 of 18 
i."Tt::'~~c--¥-----f9£'--~Date: q/4 pt 1

/;}. d. Allen H. nson, Esq. 

Stephen J. Newman, Esq .. 

Stroock & Stroock & Lavan LLP 

1875 K Street NW, Suite 800 

Washington, DC 20006 

Tel: 202-739-2805 

Email: adenson@stroock.com 

DEFENDANTS: Passport Automotive Group, Inc., Passport Motorcars, Inc.,lmport 

Motorcars, Inc., Autos International, Inc.,Passport Imports, lnc., Passp11rt Motors 

Holding, Inc., Passport of.Alexandria, Inc., International Motorcars, Inc., Everett 

He~h,illaod/~ Date: 'f.i'_"'/,,, ?QJ-~ 

E~, Ill INDMDUALLY __:[/_/J/-~ 

AND AS AN OFFICER OF 

PASSPORT AUTOMOTIVE GROUP, INC., 

PASSPORT MOTORCARS, INC., 

IMPORT MOTORCARS, INC., 

AUTOS INTERNATIONAL, INC., 

PASSPORT IMPORTS, INC., 

PASSPORT MOTORS HOLDING, INC., 

PASSPORT OF ALEXANDRIA, INC., 

INTERNA · AL MOTORC:ARS, INC. 

JAY KLEIN IN IVIDUALL Y 

AND ASANO FICER OF 

PASSPORT A TOMOTIVE GROUP, INC:., 

PASSPORT · TORCARS, INC., 

IMPORT MO ORCARS, INC., 

AUTOS INTERNATIONAL, INC., 

PASSPORT iMPORTS, INC., 

PASSPORT MOTORS HOLDING, INC., 

PASSPORT OF ALEXANDRIA, INC,. 

INTERNATIONAL MOTORCARS, INC, 

Date: #'J'). 

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Case 8:22-cv-02670-TDC Document 10 Filed 10/21/22 Page 18 of 18