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ALDEN F. ABBOTT 

General Counsel 

JOSHUA S. MILLARD, pro hac vice

jmillard@ftc.gov 

BRIAN M. WELKE, pro hac vice

bwelke@ftc.gov 

FEDERAL TRADE COMMISSION 

600 Pennsylvania Ave., N.W., CC-9528 

Washington, D.C. 20580 

Tel: (202) 326-2454, -2897; Fax: (202) 326-3197 

BARBARA CHUN, Local Counsel, Cal. Bar. No. 186907 

bchun@ftc.gov 

FEDERAL TRADE COMMISSION 

10990 Wilshire Blvd., Suite 400 

Los Angeles, CA 90024 

Tel: (310) 824-4312; Fax: (310) 824-4380 

Attorneys for Plaintiff 

UNITED STATES DISTRICT COURT 

CENTRAL DISTRICT OF CALIFORNIA 

FEDERAL TRADE COMMISSION, 

 Plaintiff, 

 v. 

IMPETUS ENTERPRISE, INC., a 

California corporation, also d/b/a 

Aiding Student Relief, Aiding Students 

& Teachers, Aidnest, Avec Staffing, 

and National Education Student and 

Teacher; FIG TREE & CO., LLC, a 

California limited liability company, 

also d/b/a Aiding Student Relief, Aiding 

Students & Teacher, and Aiding 

Case No. ____________ 

COMPLAINT FOR 

PERMANENT INJUNCTION 

AND OTHER EQUITABLE 

RELIEF 

[Lodged Under Seal] 

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Students & Teachers; TUAN DINH 

DUONG, a/k/a Thomas Duong, a/k/a 

Thomas Dinh, individually and as an 

officer of IMPETUS ENTERPRISE, 

INC.; BRENDA AVITIA-PENA, 

individually and as an officer of 

IMPETUS ENTEPRISE, INC. and 

FIG TREE & CO., LLC; and BRIAN 

COLOMBANA d/b/a FUTERO, 

individually and as an officer of FIG 

TREE & CO., LLC, 

 Defendants, and 

NOEL SOLUTIONS, LLC, a Wyoming 

limited liability company, 

 Relief Defendant. 

 

 Plaintiff, the Federal Trade Commission (“FTC”), for its Complaint alleges: 

 1. The FTC brings this action under Section 13(b) of the Federal Trade 

Commission Act (“FTC Act”), 15 U.S.C. § 53(b), and the Telemarketing and 

Consumer Fraud and Abuse Prevention Act (“Telemarketing Act”), 15 U.S.C. §§ 

6101-6108, to obtain temporary, preliminary, and permanent injunctive relief, 

rescission or reformation of contracts, restitution, the refund of monies paid, 

disgorgement of ill-gotten monies, and other equitable relief for Defendants’ acts 

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

FTC’s Telemarketing Sales Rule (“TSR”), 16 C.F.R. Part 310, in connection with 

their deceptive marketing and sale of student loan debt relief services. 

JURISDICTION AND VENUE

 2. This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 

1331, 1337(a), and 1345, and 15 U.S.C. §§ 45(a), 53(b), 6102(c), and 6105(b). 

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 3. Venue is proper in this district under 28 U.S.C. § 1391(b)(1), (b)(2), 

(c)(1), (c)(2), (c)(3), and (d), and 15 U.S.C. § 53(b). 

PLAINTIFF

 4. The FTC is an independent agency of the United States Government 

created by statute. 15 U.S.C. §§ 41-58. The FTC enforces Section 5(a) of the FTC 

Act, 15 U.S.C. § 45(a), which prohibits unfair or deceptive acts or practices in or 

affecting commerce. The FTC also enforces the Telemarketing Act, 15 U.S.C. §§ 

6101-6108. Pursuant to the Telemarketing Act, the FTC promulgated and enforces 

the TSR, 16 C.F.R. Part 310, which prohibits deceptive and abusive telemarketing 

acts or practices in or affecting commerce. 

 5. The FTC is authorized to initiate federal district court proceedings, by 

its own attorneys, to enjoin violations of the FTC Act and the TSR, and to secure 

such equitable relief as may be appropriate in each case, including rescission or 

reformation of contracts, restitution, the refund of monies paid, and the 

disgorgement of ill-gotten monies. 15 U.S.C. §§ 53(b) and 6102(c). 

DEFENDANTS 

 6. Defendant Impetus Enterprise, Inc. (“Impetus”), also doing business 

as Aiding Student Relief, Aiding Students & Teachers, Aidnest, Avec Staffing, and 

National Education Student and Teacher, is a California corporation with its 

principal place of business at 18100 Von Karman Ave., Suite 850, Irvine, 

California 92612. Impetus transacts or has transacted business in this district and 

throughout the United States. At all times material to this Complaint, acting alone 

or in concert with others, or as part of the common enterprise described in 

paragraph 12, Impetus has advertised, marketed, offered to provide, provided, 

offered for sale, or sold student loan debt relief services to consumers throughout 

the United States. 

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 7. Defendant Fig Tree & Co., LLC (“Fig Tree LLC”), also doing 

business as Aiding Student Relief, Aiding Students & Teacher, and Aiding 

Students & Teachers, is a California limited liability company with its principal 

place of business at 18100 Von Karman Ave., Suite 850, Irvine, California 92612. 

Fig Tree LLC transacts or has transacted business in this district and throughout 

the United States. At all times material to this Complaint, acting alone or in 

concert with others, or as part of the common enterprise described in paragraph 12, 

Fig Tree LLC has advertised, marketed, offered to provide, provided, offered for 

sale, or sold student loan debt relief services to consumers throughout the United 

States. 

 8. Defendant Tuan Dinh Duong, also known as Thomas Duong and 

Thomas Dinh (“Duong”), has identified himself as or served as the President, 

director, general manager, sales manager, owner, co-owner, and principal 

shareholder of Impetus. At all times material to this Complaint, acting alone or in 

concert with others, he has formulated, directed, controlled, had the authority to 

control, or participated in the acts and practices set forth in this Complaint. 

Defendant Duong resides in this district and, in connection with the matters alleged 

herein, transacts or has transacted business in this district and throughout the 

United States. 

 9. Defendant Brenda Avitia-Pena (“Avitia-Pena”) has identified herself 

as or served as the President, CEO, Secretary, CFO, director, and owner of 

Impetus, and the manager of Fig Tree LLC. At all times material to this 

Complaint, acting alone or in concert with others, she has formulated, directed, 

controlled, had the authority to control, or participated in the acts and practices set 

forth in this Complaint. Defendant Avitia-Pena resides in this district and, in 

connection with the matters alleged herein, transacts or has transacted business in 

this district and throughout the United States. 

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 10. Defendant Brian Colombana (“Colombana”), who has also done 

business under the fictitious business name “Futero,” has identified himself as or 

served as co-owner of Impetus (and CIO of its d/b/a, Avec Staffing), and manager 

of Fig Tree LLC. At times material to this Complaint, through at least January 

2018, acting alone or in concert with others, Colombana formulated, directed, 

controlled, had the authority to control, or participated in the acts and practices set 

forth in this Complaint. Defendant Colombana resides in this district and, in 

connection with the matters alleged herein, transacts or has transacted business in 

this district and throughout the United States. 

RELIEF DEFENDANT 

 11. Relief Defendant Noel Solutions, LLC (“Noel”) has received funds 

that can be traced directly to Defendants’ deceptive acts or practices alleged below, 

for which it has no legitimate claim. Noel is a Wyoming limited liability company 

that reported in a public document that its principal place of business is 1623 

Central Ave., Suite 201, Cheyenne, Wyoming 82001. Noel also incorporated as a 

California limited liability company in January 2018, listing its address as 18997 

Barroso St., Rowland Heights, California 91748. Noel resides in this district and 

in the district of Wyoming. 

COMMON ENTERPRISE 

 12. Defendants Impetus and Fig Tree LLC (“Corporate Defendants”) have 

operated as a common enterprise while engaging in the unlawful acts and practices 

alleged below. Defendants have conducted the business practices described below 

through interrelated companies that have common ownership, officers, managers, 

business functions, employees, and office locations, and routinely transfer funds 

amongst themselves. Because the Corporate Defendants have operated as a 

common enterprise, each is jointly and severally liable for the acts and practices 

alleged below. Defendants Duong, Avitia-Pena, and Colombana have formulated, 

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directed, controlled, had the authority to control, or participated in the acts and 

practices of the Corporate Defendants that constitute the common enterprise. 

COMMERCE

 13. At all times material to this Complaint, Defendants have maintained a 

substantial course of trade in or affecting commerce, as “commerce” is defined in 

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

DEFENDANTS’ UNLAWFUL STUDENT LOAN DEBT RELIEF 

OPERATION 

 14. Since at least December 2014, Defendants have operated an unlawful 

debt relief scheme that preys on consumers with student loan debt. In telephone 

calls and on websites, Defendants promise to reduce consumers’ monthly student 

loan payments and eliminate all, or a portion of, their student loan debt through 

enrollment in student loan forgiveness or repayment programs. In many instances, 

however, Defendants failed to obtain debt forgiveness or monthly payment 

reductions. In fact, some consumers owed more on their student loans after 

enrolling in Defendants’ program. 

 15. In exchange for the promised student loan debt relief services, 

Defendants have charged illegal upfront fees of $499 or more. 

Background on Student Loan Forgiveness and Repayment Programs 

 16. Student loan debt is the second largest class of consumer debt; more 

than 42 million Americans collectively owe nearly $1.5 trillion in student loan 

debt. The student loan market shows elevated levels of distress relative to other 

types of consumer debt. 

 17. To address this mounting level of distressed debt, the U.S. 

Department of Education (“USDE”) and state government agencies administer a 

limited number of student loan forgiveness and discharge programs. Most 

consumers, however, do not qualify for these programs because of strict eligibility 

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requirements. For example, one program requires the consumer to demonstrate a 

total and permanent disability; another applies only to consumers whose school 

closed while the consumer was still enrolled. A third program, the Borrower 

Defense to Repayment (“BDR”), may provide a loan discharge if the school, 

through an act or omission, violated state law directly related to the borrower’s 

federal student loan or to the educational services for which the loan was provided. 

 18. Other forgiveness programs require borrowers to work in certain 

professions for a period of years. For example, Teacher Loan Forgiveness applies 

to teachers who have worked full-time for five years in a low-income elementary 

or secondary school or educational service agency. Public Service Loan 

Forgiveness (“PSLF”) applies to employees of governmental units or non-profit 

organizations who make timely monthly payments for a period of ten years while 

employed in the public sector. 

 19. The federal government also offers loan forgiveness through incomedriven repayment (“IDR”) programs that enable borrowers to reduce their monthly 

payments and have portions of their loans forgiven. IDR programs allow eligible 

borrowers to limit their monthly payments based on a percentage of their 

discretionary monthly income. To remain in an IDR program, borrowers must 

recertify their income and family size annually. Obtaining forgiveness through 

IDR programs requires a minimum of 20 or 25 years of qualifying payments, 

depending on whether borrowers received their first loans on July 1, 2014 or 

before that date. Because a borrower’s income is likely to fluctuate over the life of 

the loan, monthly payments under the IDR programs can vary considerably from 

year to year. If a borrower’s income were to increase over the repayment period, 

for example, the monthly payment amount could correspondingly increase to the 

point where those payments would pay off the loan before any amount could be 

forgiven at the end of the repayment term. No loans have been forgiven yet under 

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any of the IDR programs because the programs have not existed long enough for 

borrowers to make the minimum number of years of qualifying payments. 

 20. Consumers can apply for BDR, PSLF, IDR, and other loan repayment 

and forgiveness or discharge programs through USDE or their student loan 

servicers at no cost; these programs do not require the assistance of a third-party 

company or payment of application fees. 

 21. USDE will grant forbearance while processing applications for an 

alternative repayment plan, and in some cases of hardship. During forbearance, 

unpaid interest is added to the principal balance. 

Defendants’ Deceptive Marketing of Student Loan Debt Relief Services 

 22. To lure consumers into purchasing their purported student loan debt 

relief services, Defendants have made false promises to eliminate or reduce 

consumers’ student loan balances or monthly payments through loan forgiveness 

or other programs. 

 23. To induce consumers to purchase their purported student loan debt 

relief services, Defendants have disseminated websites such as aidingstudents.com 

and aidnest.com, including, but not necessarily limited to, the attached exhibits A 

through E. Defendants’ websites have contained the following statements, among 

others: 

Free Assessment Service Guarantee Success Rate 

Our experts will assess 

your current student loan 

program, and determine 

which programs are 

available in your 

situation. We will help 

you decide which 

program can help you 

We are committed to 

helping customers get 

lower rates and monthly 

payments, and we will 

make the process 

seamless and 

straightforward. You will 

be satisfied with our 

Our 96% success rate is 

one of the top ratings in 

the industry. Our process 

has been tested, and our 

success rate proves that it 

works. We can help you 

reduce and simplify your 

payments. Call us today! 

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achieve your goals. Call 

us today! 

service and our 

commitment to your 

success. That’s our 

guarantee. 

Ex. A at 1 (aidingstudents.com, 2015). 

“We can help you reduce and simplify your payments. Contact one of 

our specialists today for a free evaluation.” 

Ex. A at 2 (emphasis in original). 

 “‘Aiding Student Relief has helped countless people reduce their student 

debt. Their proven business plan has led to one of the highest success rates in the 

industry.’” 

Ex. A at 4. 

100% Customer Satisfaction 

We can help you reduce and simplify your payments. Call one of our specialists 

today. 

Ex. B at 1 (aidingstudents.com, 2016) (emphasis in original). 

Meet some of our members who have saved big on their student loan debt. 

Helping You Save Big 

---------- 

“Thanks to Aiding Student Relief, I am savings [sic] $250 per month.” 

Michael Martin 

Entrepreneur 

Ex. B at 2 (emphasis in original). 

“We can help you reduce and simplify your payments . . . .” 

Ex. C at 1 (aidingstudents.com, 2018) (emphasis in original). 

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Student Loan 

Forgiveness 

Loan Forgiveness Student Loan 

Forgiveness 

If you have Federal 

Student Loans, you’re in 

the right place to get those 

loans reduced, forgiven or 

completely discharged 

through our student loan 

forgiveness programs. 

Get your multiple Federal 

Student Loans 

consolidated into one, 

forget about increasing 

interests [sic] and pay 

month to month at the 

lowest possible cost. 

We understand if you’re 

going through some 

hardship, and that’s why 

with us you’ll be able to 

make monthly payments 

based on your 

affordability, for as low as 

$0.00, depending on your 

situation. 

Ex. D at 2 (aidnest.com, 2016). 

Lower your loan payments 

by getting in touch with 

one of our professionals 

We design a customized repayment plan that will allow you to make 

payments based on your monthly income, family size, and spending. 

Get rid of the hassle of extensive paperwork and get the help you 

deserve. 

What we can help you achieve [is] a lower payment or lower rate. 

Ex. E at 6 (aidnest.com, 2018) (emphasis in original). 

 24. In some instances, consumers view the Defendants’ online advertising 

and call Defendants’ telemarketers for more information. Defendants also make 

outbound telemarketing calls and send texts to consumers to offer their services 

and convince student loan borrowers to sign up for Defendants’ debt relief 

services. 

 25. In calls with consumers, Defendants’ telemarketers have told 

consumers that Defendants can cause consumers’ student loan balances to be 

reduced, or that consumers’ loan balances would be forgiven after making lower 

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monthly payments. Defendants’ telemarketers have told some consumers that over 

half their loan balance would be forgiven. Moreover, Defendants’ telemarketers 

have told some consumers that their loan payments could or would be rapidly 

reduced to $19 per month, or promptly forgiven. 

 26. Defendants have made other representations concerning loan 

reduction or forgiveness to consumers in telemarketing their debt relief services. 

For example, Defendants’ telemarketers have told one or more consumers that 

“family size,” a metric for determining the amount borrowers pay each month 

under IDR plans, includes “anyone you help out throughout the year[,] they don’t 

have to live with you,” even claiming that helping with “gas money, three times 

out of the year” is enough to include a person in “family size.” Further, 

Defendants’ telemarketers have offered one or more consumers “basically a 

guarantee to remain” in an IDR plan, and warned one or more consumers that 

signing up for an IDR plan with a lender instead would result in a higher loan 

payment. 

 27. Defendants have not been likely to achieve the lower monthly 

payments or student loan forgiveness they have advertised, marketed, and 

promoted to consumers. In many instances, Defendants have failed to obtain the 

promised lower monthly payments or student loan forgiveness. 

 28. Defendants have charged consumers fees for purported debt relief 

services before achieving lower monthly payments or student loan forgiveness, 

and, in many instances, have failed to achieve those results at all on behalf of 

consumers. 

 29. Defendants’ telemarketers have sought and obtained consumers’ 

payment information by phone or the Internet. 

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 30. Defendants’ total advance fees typically have been in the range of 

$300-500. Defendants also have charged consumers recurring monthly fees for 

purported debt relief services, typically charging $19 per month. 

THE FTC ACT

 31. Section 5(a) of the FTC Act, 15 U.S.C. § 45(a), prohibits “unfair or 

deceptive acts or practices in or affecting commerce.” 

 32. Misrepresentations or deceptive omissions of material fact constitute 

deceptive acts or practices prohibited by Section 5(a) of the FTC Act. 

VIOLATIONS OF THE FTC ACT 

Count One 

(Deceptive Student Loan Debt Relief Representations)

33. In numerous instances in connection with the advertising, marketing, 

promotion, offering for sale, or sale of student loan debt relief services, Defendants 

have represented, directly or indirectly, expressly or by implication, that consumers 

who purchase Defendants’ debt relief services will or likely will have their 

monthly payments reduced or their loan balances forgiven in whole or in part. 

34. In truth and in fact, in numerous instances in which Defendants have 

made the representations set forth in Paragraph 33 of this Complaint, such 

representations were false or not substantiated at the time Defendants made them. 

35. Therefore, Defendants’ representations as set forth in Paragraph 33 of 

this Complaint are false or misleading and constitute deceptive acts or practices in 

violation of Section 5(a) of the FTC Act, 15 U.S.C. § 45(a). 

THE TELEMARKETING SALES RULE

 36. Congress directed the FTC to prescribe rules prohibiting abusive and 

deceptive telemarketing acts or practices pursuant to the Telemarketing Act, 15 

U.S.C. §§ 6101-6108, in 1994. The FTC adopted the original TSR in 1995, 

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extensively amended it in 2003, and amended certain sections thereafter. 16 

C.F.R. Part 310. 

 37. Defendants are “seller[s]” or “telemarketer[s]” engaged in 

“telemarketing” as defined by the TSR, 16 C.F.R. § 310.2(dd), (ff), and (gg). A 

“seller” means any person who, in connection with a telemarketing transaction, 

provides, offers to provide, or arranges for others to provide goods or services to a 

customer in exchange for consideration. 16 C.F.R. § 310.2(dd). A “telemarketer” 

means any person who, in connection with telemarketing, initiates or receives 

telephone calls to or from a customer or donor. 16 C.F.R. § 310.2(ff). 

“Telemarketing” means a plan, program, or campaign which is conducted to 

induce the purchase of goods or services or a charitable contribution, by use of one 

or more telephones and which involves more than one interstate telephone call. 16 

C.F.R. § 310.2(gg). 

 38. Defendants are sellers or telemarketers of “debt relief services” as 

defined by the TSR, 16 C.F.R. § 310.2(o). Under the TSR, a “debt relief service” 

means any program or service represented, directly or by implication, to 

renegotiate, settle, or in any way alter the terms of payment or other terms of the 

debt between a person and one or more unsecured creditors or debt collectors, 

including, but not limited to, a reduction in the balance, interest rate, or fees owed 

by a person to an unsecured creditor or debt collector. 16 C.F.R. § 310.2(o). 

 39. The TSR prohibits sellers and telemarketers from requesting or 

receiving payment of any fees or consideration for any debt relief service until and 

unless: 

 a. The seller or telemarketer has renegotiated, settled, reduced, or 

otherwise altered the terms of at least one debt pursuant to a 

settlement agreement, debt management plan, or other such 

valid contractual agreement executed by the customer; and 

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 b. The customer has made at least one payment pursuant to that 

settlement agreement, debt management plan, or other valid 

contractual agreement between the customer and the creditor; 

and 

 c. To the extent that debts enrolled in a service are renegotiated, 

settled, reduced, or otherwise altered individually, the fee or 

consideration either: 

 i. Bears the same proportional relationship to the total fee 

for renegotiating, settling, reducing, or altering the terms 

of the entire debt balance as the individual debt amount 

bears to the entire debt amount. The individual debt 

amount and the entire debt amount are those owed at the 

time the debt was enrolled in the service; or 

 ii. Is a percentage of the amount saved as a result of the 

renegotiation, settlement, reduction, or alteration. The 

percentage charged cannot change from one individual 

debt to another. The amount saved is the difference 

between the amount owed at the time the debt was 

enrolled in the service and the amount actually paid to 

satisfy the debt. 16 C.F.R. § 310.4(a)(5)(i). 

 40. The TSR prohibits sellers and telemarketers from misrepresenting 

directly or by implication, any material aspect of any debt relief service, including, 

but not limited to, the amount of money or the percentage of the debt amount that a 

customer may save by using the service. 16 C.F.R. § 310.3(a)(2)(x). 

 41. Pursuant to Section 3(c) of the Telemarketing Act, 15 U.S.C 

§ 6102(c), and Section 18(d)(3) of the FTC Act, 15 U.S.C. § 57a(d)(3), a violation 

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of the TSR constitutes an unfair or deceptive act or practice in or affecting 

commerce, in violation of Section 5(a) of the FTC Act, 15 U.S.C. § 45(a). 

VIOLATIONS OF THE TELEMARKETING SALES RULE 

Count Two 

(Advance Fee for Debt Relief Services) 

 42. In numerous instances, in connection with the telemarketing of 

student loan debt relief services, Defendants have requested or received payment 

of a fee or consideration for debt relief services before: 

 a. Defendants have renegotiated, settled, reduced, or otherwise 

altered the terms of at least one debt pursuant to a settlement 

agreement, debt management plan, or other such valid contractual 

agreement executed by the customer; and 

 b. The customer has made at least one payment pursuant to that 

settlement agreement, debt management plan, or other valid 

contractual agreement between the customer and the creditor. 

 43. Defendants’ acts or practices, as described in Paragraph 40 of this 

Complaint, are abusive telemarketing acts or practices that violate Section 

310.4(a)(5)(i) of the TSR, 16 C.F.R. § 310.4(a)(5)(i). 

Count Three 

(Material Debt Relief Misrepresentations) 

 44. In numerous instances, in connection with the telemarketing of 

student loan debt relief services, Defendants have misrepresented, directly or 

indirectly, expressly or by implication, material aspects of their debt relief services, 

including, but not limited to that consumers who purchase Defendants’ debt relief 

services will or likely will have their monthly payments reduced or their loan 

balances forgiven in whole or in part. 

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 45. Defendants’ acts and practices, as described in Paragraph 42 of this 

Complaint, are deceptive telemarketing acts or practices that violate Section 

310.3(a)(2)(x) of the TSR, 16 C.F.R. § 310.3(a)(2)(x). 

Count Four

(Disgorgement of Ill-Gotten Gains of Relief Defendant)

 46. Relief Defendant Noel has received, directly or indirectly, funds or 

other assets from Defendants that are traceable to funds obtained from Defendants’ 

customers through the unlawful acts or practices described herein. 

 47. Relief Defendant Noel has no legitimate claim to Defendants’ 

customers’ funds or other assets and will be unjustly enriched if it is not required to 

disgorge the assets or the value of benefits received as a result of Defendants’ 

unlawful acts or practices. 

 48. By reason of the foregoing, Relief Defendant Noel holds funds and 

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

CONSUMER INJURY

 49. Consumers have suffered and will continue to suffer substantial injury 

as a result of Defendants’ violations of the FTC Act and the TSR. In addition, 

Defendants have been unjustly enriched as a result of their unlawful acts or 

practices. Absent injunctive relief by this Court, Defendants are likely to continue 

to injure consumers, reap unjust enrichment, and harm the public interest. 

THIS COURT’S POWER TO GRANT RELIEF

 50. Section 13(b) of the FTC Act, 15 U.S.C. § 53(b), empowers this Court 

to grant injunctive and such other relief as the Court may deem appropriate to halt 

and redress violations of any provision of law enforced by the FTC. The Court, in 

the exercise of its equitable jurisdiction, may award ancillary relief, including 

rescission or reformation of contracts, restitution, the refund of monies paid, and 

16
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the disgorgement of ill-gotten monies, to prevent and remedy any violation of any 

provision of law enforced by the FTC. 

 51. Section 6(b) of the Telemarketing Act, 15 U.S.C. § 6105(b), 

authorizes this Court to grant such relief as the Court finds necessary to redress 

injury to consumers resulting from Defendants’ violations of the TSR, including 

the rescission or reformation of contracts, and the refund of money. 

PRAYER FOR RELIEF

 Wherefore, Plaintiff FTC, pursuant to Section 13(b) of the FTC Act, 15 

U.S.C. § 53(b), Section 6(b) of the Telemarketing Act, 15 U.S.C. § 6105(b), and 

the Court’s own equitable powers, requests that the Court: 

A. Award Plaintiff such preliminary injunctive and ancillary relief as 

may be necessary to avert the likelihood of consumer injury during 

the pendency of this action and to preserve the possibility of effective 

final relief, including but not limited to, temporary and preliminary 

injunctions, orders freezing assets, immediate access to business 

premises, appointment of a receiver, and expedited discovery; 

B. Enter a permanent injunction to prevent future violations of the FTC 

Act and the TSR; 

C. Award such relief as the Court finds necessary to redress injury to 

consumers resulting from Defendants’ violations of the FTC Act and 

the TSR, including but not limited to, rescission or reformation of 

contracts, restitution, the refund of monies paid, and the disgorgement 

of ill-gotten monies; 

D. Enter an order requiring Relief Defendant to disgorge all funds and 

assets, or the value of the benefit it received from the funds and assets, 

which are traceable to funds obtained from Defendants’ customers 

through the unlawful acts or practices described herein; and 

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E. Award Plaintiff the costs of bringing this action, as well as such other 

and additional relief as the Court may determine to be just and proper. 

18
1 

2 Dated: November 6, 2018 

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19 

Respectfully submitted, 

ALDEN F. ABBOTT 

General Counsel 

Brian 

Barbara Chun 

Attorneys for Plaintiff 

FEDERAL TRADE COMMISSION 

19
EXHIBIT A 
Exhibit A

20
Exhibit A

21
Exhibit A

22
Exhibit A

23
Exhibit A

24
Exhibit A

25
Exhibit A

26
EXHIBIT B 
 	
	

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Exhibit B

29
EXHIBIT C 
Exhibit C

30
EXHIBIT D 
info@aidnest.com

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Exhibit D

31
If you have Federal Student

Loans, you’re in the right place to

get those loans reduced, forgiven

or completely discharged through

our student loan forgiveness

programs.

Get your multiple Federal Student

Loans consolidated into one,

forget about increasing interests

and pay month to month at the

lowest possible cost.

We understand if you’re going

through some hardship, and that’s

why with us you’ll be able to

make monthly payments based on

your affordability, for as low as

$0.00, depending on your

situation.

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Exhibit D

32
Our knowledge base is designed to provide information regarding some of the critical topics those with student

loans must be aware of to be able to make educated decisions regarding their future.

If you’re in default, you don’t

have to worry anymore – not only

can we enroll you into one of our

rehabilitation programs, but also

your credit score will show in

good standing within 6 to 9

months.

A wage garnishment is any legal

procedure in which some portion

of a person’s earnings is required

to be withheld by an employer for

the payment of a debt.

If you’re in default, you don’t

have to worry anymore – not only

can we enroll you into one of our

rehabilitation programs, but also

your credit score will show in

good standing within 6 to 9

months.

With this program your payments

change as your income changes

and will not be longer than 25

years. This is the ideal plan if you

are in partial financial hardship.

Your monthly payments will be

lower and you’ll pay more for

your loan over time than you

would under the 10-year standard

plan.

Temporarily allowing you to

postpone or reduce your federal

student loan payments. Postponing

or reducing your payments may

help you avoid default and future

garnishments.

Your monthly payments will be

lower and you’ll pay more for

your loan over time than you

would under the 10-year standard.

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Exhibit D

33
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Exhibit D

34
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Exhibit D

35
pay-grandchild-studen

Why 2016 Will Be a Big Year For Student Loans

December 30, 2015

12511110_1112367518

Top Student Loan Refinancing Questions of 2015

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36
EXHIBIT E 
AIDNEST Let us help you through this national crisis

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Call one of our specialists today.

Forbearance & Deferment

If you are still in school and struggling to make payments on your student loans. You may qualify

for Forbearance & Deferment.

Garnishment Prevention

Federal law requires that the Department of Education or guarantee agency notifies you before they

begin garnishing your wages.

Loan Forgiveness

If you are a teacher, public service worker, or an individual with total and permanent disability you

Exhibit E

37
AIDNEST Let us help you through this national crisis

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may qualify for this program.

Consolidating Your Loans

Consolidating your loans to one new loan under one lender may lower your payments and make

your life a bit more manageable.

Affordable Payments

If you are looking to lower your monthly payments, then Income Based Repayment Plans may be

the correct choice for you.

Learn more about our services

LEARN MORE

Exhibit E

38
AIDNEST Let us help you through this national crisis

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Loan Forgiveness Programs Income Based Payments Student Loan Rehabilitation

Student Loan Consolidation

You may be eligible for

Loan Forgiveness Programs

In some cases, individuals with Federal Student Loans may qualify to have a portion of the amount

owed to be forgiven.

Get in touch with our professional team to find out which loan forgiveness program you qualify for and

how you can get rid of your unpaid student loan.

LEARN MORE

Exhibit E

39
AIDNEST Let us help you through this national crisis

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There are no obligations or commitments.

YOUR ASSESSMENT IS ABSOLUTELY FREE

Meet your Budget

One of our advisers will help you meet your payment goals by using your budget and timeline to

determine the best plan available.

Exhibit E

40
AIDNEST Let us help you through this national crisis

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Simple Process

We understand that lowering your payments alone can be difficult. Our intuitive platform allows us

to keep the entire process simple.

Customer Satisfaction

We are committed to providing you with outstanding service only. We look forward to working

with you.

100% money back guarantee

No Hassle Money Back Policy

Exhibit E

41
AIDNEST Let us help you through this national crisis

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Lower your loan payments

by getting in touch with

one of our professionals

We design a customized repayment plan that will allow you to make payments based on your

monthly income, family size, and spending. Get rid of the hassle of extensive paperwork and get the

help you deserve.

What we can help you achieve a lower payment or lower rate.

Exhibit E

42
AIDNEST Let us help you through this national crisis

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How a Change of City can Change your Life

(and Loan)!

The Argument for Tuition-Free College

We stand by our consultation and quote. We

are so sure and confident about our services

and offers that they are all 100% money back

guarantee, risk free – if we don’t do what we

promise, you’ll get your money back.

CONTACT INFO

info@aidnest.com

855-580-NEST (6378)

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Irvine, CA 92612 

1651 E. Fourth St. 

Santa Ana, CA 92701

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© 2018 AIDNEST Let us help you through this national

crisis.

Exhibit E

43
Services | AIDNEST Let us help you through this national crisis

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INCOME BASED PAYMENTS

If you are suffering from a financial hardship, you may be eligible for an

Income Based Payment. In this repayment program, you would have a

payment based on your income and family size. The payment could be as

low as $0.00 per month, with forgiveness at the end of 20-25 years.

Exhibit E

44
Services | AIDNEST Let us help you through this national crisis

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LEARN MORE 

LEARN MORE 

LOAN FORGIVENESS

If you have Federal Student Loans you may qualify for any of the student

loan forgiveness programs that are available to borrowers. You may be

eligible for principal reduction, loan forgiveness, or a complete loan

discharge depending on your individual circumstance.

PRIVATE STUDENT LOAN CONSOLIDATION

Much like refinancing a mortgage, generally the biggest benefit of private

student loan consolidation/student loan refinancing is a lower interest rate

Exhibit E

45
Services | AIDNEST Let us help you through this national crisis

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LEARN MORE 

(something federal consolidations do not offer).

STUDENT LOAN REHABILITATION

You can renew eligibility for new loans and grants and eliminate the loan

default by “rehabilitating” a defaulted loan.

Exhibit E

46
Services | AIDNEST Let us help you through this national crisis

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With our fast, friendly and professional services we’ll be glad to help you get your student loans

reduced, forgiven or completely discharged. To this end, we’ll assist you in consolidating all your

student loans, so you’ll have only one lender and you’ll start making one monthly payment. Our

professionals will walk you through the best and most flexible repayment options, and if it’s also

necessary, varied deferment options and rehabilitation programs.

CHECK ELEGIBILITY 

LEARN MORE 

WAGE GARNISHMENT

A wage garnishment is any legal procedure in which some portion of a

person’s earnings is required to be withheld by an employer for the

payment of a debt.

Exhibit E

47
Services | AIDNEST Let us help you through this national crisis

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Our CRM System

Our CRM is one of the most advanced in the industry and most importantly, it’s linked directly to

the Department of Education (DOE). This keeps your personal and most confidential information

safe. Furthermore because our CRM system is linked to the DOE, our approval is 100%. Through

our CRM we will be doing continuous monitoring of our process without losing sight of your

immediate needs, ensuring that your case has the proper handling and most efficient process.

Exhibit E

48
Services | AIDNEST Let us help you through this national crisis

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We stand by our consultation and quote. We

are so sure and confident about our services

and offers that they are all 100% money back

guarantee, risk free – if we don’t do what we

promise, you’ll get your money back.

CONTACT INFO

info@aidnest.com

855-580-NEST (6378)

18100 Von Karman Ave Suite 850,

Irvine, CA 92612 

1651 E. Fourth St. 

Santa Ana, CA 92701

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© 2018 AIDNEST Let us help you through this national

crisis.

Exhibit E

49