1 

 2 

 3 

 4 

 5 

 6 

 7 

 8 

 9 

 10 

 11 

 12 

 13 

 14 

 15 

 16 

 17 

 18 

 19 

 20 

 21 

 22 

 23 

 24 

 25 

 26 

 27 

 28 

ALDEN F. ABBOTT

Acting General Counsel

SARAH SCHROEDER, Cal. Bar No. 221528 

ROBERTA TONELLI, Cal. Bar No. 278738 

EVAN ROSE, Cal. Bar No. 253478 

Federal Trade Commission

901 Market Street, Suite 570 

San Francisco, CA 94103 

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

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

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

OAKLAND DIVISION

FEDERAL TRADE COMMISSION, 

 Plaintiff,

 vs. 

AMERICAN FINANCIAL BENEFITS 

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

STUDENT SERVICES; 

AMERITECH FINANCIAL, a corporation; 

 

FINANCIAL EDUCATION BENEFITS 

CENTER, a corporation; and

BRANDON DEMOND FRERE, individually 

and as an officer of AMERICAN FINANCIAL 

BENEFITS CENTER, AMERITECH 

FINANCIAL, and FINANCIAL EDUCATION 

BENEFITS CENTER,

 

 Defendants. 

 

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

Related Case: 4:17-cv-04817-SBA 

DECLARATION OF MELISSA 

BUSSEWITZ IN SUPPORT OF 

 FEDERAL TRADE COMMISSION’S 

MOTION FOR PRELIMINARY 

INJUNCTION

Case 4:18-cv-00806-SBA Document 105 Filed 04/19/18 Page 1 of 3

DECLARATION OF MELISSA BUSSEWITZ IN SUPPORT OF FEDERAL TRADE 

COMMISSION’S MOTION FOR PRELIMINARY INJUNCTION

 4:18-CV-00806-SBA
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

DECLARATION OF MELISSA BUSSEWITZ 

1. My name is Melissa Bussewitz and I am a teacher in New York state. The 

following statements are within my personal knowledge and if called as a witness I could and 

would competently testify thereto. 

2. In mid-January 2018, I received a postcard offering student loan forgiveness. The 

postcard featured a photo of me and my daughter reflected in a creepy man’s glasses. I was 

upset that a company used my private photo without my permission. I was very alarmed by the 

postcard and took a photo of it. A true and correct copy of a photo that I took of the postcard is 

attached as Bussewitz Attachment A. 

3. I was upset when I saw my personal photo on the postcard and called the toll-free 

number at the bottom of the postcard. The woman who answered my call said she worked for a 

company called Ameritech Financial (“Ameritech” or the “company”). I told her that Ameritech 

was using my personal image without my permission. She dismissed my concerns and said the 

postcard from from the company’s marketing department. I asked to speak with a supervisor and 

she transferred me another person. I shared my concerns with the supervisor, but he also 

dismissed me and said Ameritech was getting a lot of positive reaction to the marketing 

campaign. The operation seemed like a scam and I did not discuss my student loan with either 

agent. 

4. Based on Ameritech’s reaction to my concerns, I filed a review about the 

company with the Better Business Bureau (“BBB”) on January 18, 2018. My review to the BBB 

stated: 

“I received a solicitation in the mail today from this company [Ameritech]. It was a 

postcard offering to have my student loans forgiven. The photo on the card was a man 

wearing mirrored glasses. In those mirrors reflecting back at me was a photo of myself 

and my daughter. I called the company to tell them this is not ok and to remove me from 

their mailing list. I feel this is a gross invasion of privacy and told them so. Any 

company taking photos of people off the internet to use in marketing is not a legitimate 

one.” 

Bussewitz Declaration - Page 1 

Case 4:18-cv-00806-SBA Document 105 Filed 04/19/18 Page 2 of 3
1 I declare under penalty of perjury that the foregoing is true and correct. Executed on 

pril_E 

A

. 2018, in New York. 

[;Th,J��Melissa�

2 II 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

Case 4:18-cv-00806-SBA Document 105 Filed 04/19/18 Page 3 of 3
n 

-

-

-

•• 

Bussewitz Att. A

Case 4:18-cv-00806-SBA Document 105-1 Filed 04/19/18 Page 1 of 1