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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 4:18-cv-00806-SBA Document 111 Filed 04/19/18 Page 1 of 3

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

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

DECLARATION OF GEORGIA 

MARTIN IN SUPPORT OF FEDERAL 

TRADE COMMISSION’S MOTION 

FOR PRELIMINARY INJUNCTION

DECLARATION OF GEORGIA MARTIN IN SUPPORT OF FEDERAL TRADE 

COMMISSION’S MOTION FOR PRELIMINARY INJUNCTION

 4:18-CV-00806-SBA
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DECLARATION OF GEORGIA MARTIN 

I. My name is Georgia Martin and I reside in California. The following statements 

arc within my personal knowledge and if called as a witness I could and would competently 

testify thereto. 

2. I worked at Ameritech Financial in February and March 20 17 in the El Dorado 

Hills call center. 

,., 

_,. Originally, the employment advc1tiscment on Indeed quoted an $80k pay scale. 

After I arrived, I found out it was a $ 12.00 per hour job with a $ 10.00 bonus for every person 

that I signed into the program. 

4. The company had a '·program" to assist people who had student loan debt. The 

script that was developed and used was quite lengthy and took about an hour to get through. I 

feel it was intended to make it so that people were paying less attention by the end of the call. 

5. The benefits that were included in the monthly fee were of little or no value to the 

general public, but were an offset for the $99 minimum payment. We were encouraged to hide 

in the jargon, the fact that none of the payment was actually going to the loan servicer. 

6. The company had a stri ct policy that telephone agents needed to "sign up" as 

many people as possible and threatened termination if that was not met. 

7. I left the company after a few weeks when I questioned the ethics of certain 

practices and was told that I will do whatever my supervisor fucking said to do or else. I resigned

that day. 

8. I later took a job with a different company and have a desk in the El Dorado court 

building. I saw one of the employees in the court and he told me that the company was doing so 

good that they have opened an orfice in the Dominican Republic and one other country, I believe 

either Mexico or Costa Rica. 

k&l 

9. 

/

I 

/ 

declare under 

, 

penalty of pe1jury that the foregoing is true and correct. Executed 

on 20 18, in California. 

Martin Declaration - Page I

Case 4:18-cv-00806-SBA Document 111 Filed 04/19/18 Page 2 of 3
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Martin Declaration - Page 2 

Case 4:18-cv-00806-SBA Document 111 Filed 04/19/18 Page 3 of 3