-~ 

s.... 

§ : - !!" .... 

~- . Cl-fA,:1Lf2D 

'-or--,-. -~- IN THE UNITED STATES DISTRICT COURT t;,.-... fro, ... "S", Ne 

FOR THE WESTERN DISTRICT OF NORTH CAROLINA c:i 6

1 

CHARLOTTE DIVISION ,A. us 2019 rvssh Dis-,..

'2f?,v F?1c.,. o,~F?,gou1y-,.

.,.0,: 

FEDERAL TRADE COMMISSION, ) 4'c 

) 

Plaintiff, ) 

) 

v. ) 

) 

GLOBAL ASSET FINANCIAL SERVICES ) 

GROUP, LLC, et al., ) 

) 

Defendants. ) 

) 

) 

) ________________ ) 

CASE NO. 3:19cv55 

TEMPORARY RESTRAINING 

ORDER WITH AN ASSET FREEZE, 

APPOINTMENT OF RECEIVER, 

AND OTHER EQUITABLE 

RELIEF, AND ORDER TO SHOW 

CAUSE WHY A PRELIMINARY 

INJUNCTION SHOULD NOT ISSUE 

Plaintiff Federal Trade Commission ("FTC") has filed its Complaint for Permanent 

Injunction and Other Equitable Relief pursuant to Section 13(b) ofthe Federal Trade 

Commission Act ("FTC Act"), 15 U.S.C. § 53(b), and Section 814(a) ofthe Fair Debt Collection 

Practices Act ("FDCPA"), 15 U.S.C. § 1692/(a), and has moved ex parte, pursuant to Rule 65(b) 

ofthe Federal Rules ofCivil Procedure, for a temporary restraining order, asset freeze, other 

equitable relief, and an order to show cause why a preliminary injunction should not issue 

against Defendants. 

FINDINGS OF FACT 

The Court, having considered the Complaint, the ex parte Motion for a Temporary 

Restraining Order, declarations, exhibits, and the memorandum ofpoints and authorities filed in 

support thereof, and being otherwise advised, finds that: 

Page 1 of34 
A. This Court has jurisdiction over the subject matter ofthis case, and there is good cause to 

believe that it will have jurisdiction over all parties hereto and that venue in this district is 

proper. 

B. There is good cause to believe that Defendants Global Asset Financial Services Group, LLC, 

Regional Asset Maintenance, LLC, 1OD Holdings, Inc., Trans America Consumer Solutions, 

LLC, Midwestern Alliance, LLC, LLI Business Innovations, LLC, TACS I, LLC, TACS II, 

LLC, TACS Ill, LLC, Cedar Rose Holdings & Development, Inc., Ankh Ali, Aziza Ali, 

Kenneth Moody, David Carr, Jeremy Scinta, and Omar Hussain have engaged in and are 

likely to engage in acts or practices that violate Section S(a) ofthe FTC Act, 15 U.S.C. 

§ 45(a), and multiple provisions ofthe FDCPA, 15 U.S.C. §§ 1692 - l 692p, and that the 

FTC is therefore likely to prevail on the merits ofthis action. 

C. There is good cause to believe that immediate and irreparable harm will result from 

Defendants' ongoing violations ofthe FTC Act and the FDCPA unless Defendants are 

restrained and enjoined by order ofthis Court. 

D. There is good cause to believe that Defendants have caused consumer harm of at least $4.3 

million. 

E. There is good cause to believe that immediate and irreparable damage to the Court's ability 

to grant effective final relieffor consumers - including monetary restitution, rescission, 

disgorgement or refunds -will occur from the sale, transfer, destruction or other disposition 

or concealment by Defendants oftheir assets or records, unless Defendants are immediately 

restrained and enjoined by order ofthis Court; and that, in accordance with Fed. R. Civ. P. 

65(b), the interests ofjustice require that this Order be granted without prior notice to 

Page 2 of34 
Defendants. Thus, there is good cause for relieving the FTC of the duty to provide 

Defendants with prior notice of its Motion for a Temporary Restraining Order. 

F. Good cause exists for appointing a temporary receiver over the Receivership Entities, 

freezing Defendants' assets, permitting the FTC and the Receiver immediate access to the 

Defendants' business premises, and permitting the FTC and the Receiver to take expedited 

discovery. 

G. Weighing the equities and considering the FTC's likelihood of ultimate success on the 

merits, a temporary restraining order with an asset freeze, the appointment of a temporary 

receiver, immediate access to business premises, expedited discovery, and other equitable 

relief is in the public interest. 

H. This Court has authority to issue this Order pursuant to Section 13(b) ofthe FTC Act, 15 

U.S.C. § 53(b); Federal Rule ofCivil Procedure 65; and the All Writs Act, 28 U.S.C. § 1651. 

I. No security is required of any agency ofthe United States for issuance ofa temporary 

restraining order. Fed. R. Civ. P. 65(c). 

DEFINITIONS 

For the purpose ofthis Order, the following definitions shall apply: 

A. "Asset" means any legal or equitable interest in, right to, or claim to, any property, wherever 

located and by whomever held. 

B. "Consumer" means any person. 

C. "Corporate Defendant(s)" means Defendants Global Asset Financial Services Group, LLC, 

Regional Asset Maintenance, LLC, 1 OD Holdings, Inc., Trans America Consumer Solutions, 

LLC, Midwestern Alliance, LLC, LLI Business Innovations, LLC, TACS I, LLC, TACS II, 

Page 3 of34 
LLC, TACS III, LLC, Cedar Rose Holdings & Development, Inc., and each oftheir 

subsidiaries, affiliates, successors, and assigns. 

D. "Debt" means any obligation or alleged obligation to pay money arising out of a transaction, 

whether or not such obligation has been reduced to judgment. 

E. "Debt Portfolio" means spreadsheets, databases, tables, lists, or any other compilation of 

information describing debts or purported debts. 

F. "Defendant(s)" means the Corporate Defendants and the Individual Defendants, 

individually, collectively, or in any combination. 

G. "Document" is synonymous in meaning and equal in scope to the usage of "document" and 

"electronically stored information" in Federal Rule ofCivil Procedure 34(a), Fed. R. Civ. P. 

34(a), and includes writings, drawings, graphs, charts, photographs, sound and video 

recordings, images, Internet sites, web pages, websites, electronic correspondence, including 

e-mail and instant messages, contracts, accounting data, advertisements, FTP Logs, Server 

Access Logs, books, written or printed records, handwritten notes, telephone logs, telephone 

scripts, receipt books, ledgers, personal and business canceled checks and check registers, 

bank statements, appointment books, computer records, customer or sales databases and any 

other electronically stored information, including Documents located on remote servers or 

cloud computing systems, and other data or data compilations from which information can be 

obtained directly or, ifnecessary, after translation into a reasonably usable form. A draft or 

non-identical copy is a separate document within the meaning of the term. 

H. "Electronic Data Host" means any person or entity in the business ofstoring, hosting, or 

otherwise maintaining electronically stored information. This includes, but is not limited to, 

Page 4 of 34 
any entity hosting a website or server, and any entity providing "cloud based" _electronic 

storage. 

I. "Individual Defendant(s)" means Ankh Ali, Aziza Ali, Kenneth Moody, David Carr, 

Jeremy Scinta, and Omar Hussain, individually, collectively, or in any combination. 

J. "Person" means a natural person, an organization or other legal entity, including a 

corporation, partnership, sole proprietorship, limited liability company, association, 

cooperative, or any other group or combination acting as an entity 

K. "Receiver" means the temporary receiver appointed in Section XI of this Order and any 

deputy receivers that shall be named by the temporary receiver. 

L. "Receivership Entities" means the Corporate Defendants as well as any other entity that has 

conducted any business related to Defendants' debt collection or debt brokering, including 

receipt of Assets derived from any activity that is the subject ofthe Complaint in this matter, 

and that the Receiver determines is controlled or owned by any Defendant. 

ORDER 

I. PROIDBITED REPRESENTATIONS 

IT IS THEREFORE ORDERED that Defendants, Defendants' officers, agents, 

employees, and attorneys, and all other persons in active concert or participation with them, 

who receive actual notice ofthis Order by personal service or otherwise, whether acting 

directly or indirectly, in connection with the advertising, marketing, promoting, or offering 

for sale of any goods or services, are temporarily restrained and enjoined from: 

A. Misrepresenting or assisting others in misrepresenting, expressly or by implication, 

any material fact, including, but not limited to: 

Page 5 of34 
1. that any consumer is delinquent on a payday loan or other debt that any 

Defendant or any other person has authority to collect; 

2. that any consumer has a legal obligation to pay any Defendant or any other 

person; 

3. that non-payment of a purported debt will result in a consumer's arrest, 

criminal prosecution, imprisonment, or in seizure, garnishment, or attachment 

ofa consumer's property or wages; 

4. that consumers have committed a fraud or a criminal act; 

5. that any Defendant or any other person has taken, intends to take, or has 

authority to take formal legal action against a consumer who fails to pay any 

debt; 

6. that any Defendant will serve, or arrange for a third party to serve, documents 

on a consumer; 

7. that any Defendant or any other person is an attorney or affiliated or 

associated with an attorney; 

8. that any Defendant or any other person is a law firm; or 

9. the character, amount, or legal status of a debt; 

B. Communicating with third parties for purposes other than acquiring location 

information about a consumer, without having obtained directly the prior consent of 

the consumer or the express permission of a court ofcompetent jurisdiction, and 

when not reasonably necessary to effectuate a postjudgment judicial remedy; 

C. Placing telephone calls without meaningfully disclosing the caller's identity; 

Page 6 of34 
D. Failing to disclose or disclose adequately (1) in the initial communication with a 

consumer that any Defendant or any other person is a debt collector attempting to 

collect a debt and that any information obtained will be used for that purpose, or (2) 

in subsequent communications with consumers that any Defendant or any other 

person is a debt collector; 

E. Tirreatening to take action that is not lawful or that any Defendant or any other person 

does not intend to take; 

F. Using any false representation or deceptive means to collect or attempt to collect a 

debt, or to obtain information concerning a consumer; 

G. Using a business, company, or organization name other than the true name of 

Defendants' business, company, or organization; 

H. Failing to provide consumers, within five days after the initial communication with a 

consumer, a written notice containing: (1) the amount ofthe debt; (2) the name ofthe 

creditor to whom the debt is owed; (3) a statement that unless the consumer, within 

thirty days after receipt ofthe notice, disputes the validity ofthe debt, or any portion 

thereof, the debt will be assumed to be valid by Defendants; (4) a statement that ifthe 

consumer notifies Defendants in writing within the thirty-day period that the debt, or 

any portion thereof, is disputed, Defendants will obtain verification of the debt or a 

copy ofa judgment against the consumer and a copy ofsuch verification or judgment 

will be mailed to the consumer by Defendants; and (5) a statement that, upon the 

consumer's written request within the thirty-day period, Defendants will provide the 

consumer with the name and address ofthe original creditor, if different from the 

current creditor; 

Page 7 of 34 
I. Marketing, distributing, or selling Debt Portfolios that list loans that the lenders have 

not, in fact, made to the consumers identified in such portfolios, or Debts that 

Defendants do not have the right to collect; 

J. Providing others with the means and instrumentalities to misrepresent, or assist others 

in misrepresenting, directly or indirectly, expressly or by implication, that consumers 

owe debts or that a debt collector has obtained the rights to collect from a consumer; 

and 

K. Engaging in any conduct that violates the FDCPA, 15 U.S.C. §§ 1692-1692p. 

Il. PROHIBITION ON RELEASE OF CUSTOMER INFORMATION 

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 ofthis Order, whether acting directly or indirectly, are hereby 

temporarily restrained and enjoined from: 

A. Selling, renting, leasing, transferring, or otherwise disclosing, the name, address, birth 

date, telephone number, email address, credit card number, bank account number, 

Social Security number, or other financial or identifying information of any person 

that any Defendant obtained in connection with any activity that pertains to the 

subject matter ofthis Order; and 

B. Benefitting from or using the name, address, birth date, telephone number, email 

address, credit card number, bank account number, Social Security number, or other 

financial or identifying information of any person that any Defendant obtained in 

connection with any activity that pertains to the subject matter of this Order. 

Page 8 of34 
C. Provided, however, that Defendants may disclose such identifying information to a 

law enforcement agency, to their attorneys as required for their defense, as required 

by any law, regulation, or court order, or in any filings, pleadings or discovery in this 

action in the manner required by the Federal Rules ofCivil Procedure and by any 

protective order in the case. 

III. ACCOUNTING FOR DEBT PORTFOLIOS AND CHAINS OF TITLE 

IT IS FURTHER ORDERED that Defendants, within five (5) business days ofservice 

of this Order, shall provide to FTC counsel: 

A. An accounting of all Debt Portfolios that have been distributed, placed, collected on, 

sold, or acquired (including acquisitions made for the purpose of collection) by 

Defendants, their subsidiaries, officers, agents, or employees since June 1, 2014, by 

providing a report to FTC counsel that sets forth the folJowing details: 

1. The current owner(s) ofeach Debt Portfolio; 

2. The filenames, titles, or other descriptions of each Debt Portfolio; 

3. The location(s) where each Debt Portfolio is stored and any username or 

password required to access any computer or electronic files, including but not 

limited to information stored, hosted or otherwise maintained by an Electronic 

Data Host; 

4. Any compensation related to the distribution, sale, acquisition, placement, or 

collection ofeach Debt Portfolio; 

5. The full names, addresses, and telephone numbers ofeach seller of each Debt 

Portfolio; 

Page 9 of34 
6. The full names, address and telephone numbers of each purchaser of each Debt 

Portfolio; 

7. The full names, addresses and telephone nwnbers ofthe Person(s) that provided 

all or part ofthe records in each Debt Portfolio; 

8. The full names, addresses and telephone numbers ofthe Person(s) that issued or 

originated the debts described in each Debt Portfolio; 

9. The full names, addresses and telephone numbers ofthe Person(s) that ever held 

or transferred title to the debts described in each Debt Portfolio; 

10. The full names, addresses and telephone numbers of any Electronic Data Host 

that was used to store, host, or otherwise maintain each Debt Portfolio; and 

11. The full names, addresses and telephone numbers ofany Financial Institution that 

processed payments related to the sale or acquisition of each Debt Portfolio. 

B. Along with this accounting, Defendants shall produce copies of all documents and 

records relating to the chain of title ofeach Debt Portfolio described in the 

accounting. 

IV. ASSET FREEZE 

IT IS FURTHER ORDERED that Defendants and their officers, agents, employees, 

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

receive actual notice ofthis Order, whether acting directly or indirectly, are hereby 

temporarily restrained and enjoined from: 

A. Transferring, liquidating, converting, encumbering, pledging, loaning, selling, 

concealing, dissipating, disbursing, assigning, relinquishing, spending, withdrawing, 

Page 10 of 34 
granting a lien or security interest or other interest in, or otherwise disposing of any 

Assets that are: 

1. owned or controlled, directly or indirectly, by any Defendant; 

2. held, in part or in whole, for the benefit ofany Defendant; 

3. in the actual or constructive possession of any Defendant; or 

4. owned or controlled by, in the actual or constructive possession of, or 

otherwise held for the benefit of, any corporation, partnership, asset 

protection trust, or other entity that is directly or indirectly owned, 

managed or controlled by any Defendant. 

B. Opening or causing to be opened any safe deposit boxes, commercial mail boxes, or 

storage facilities titled in the name ofany Defendant or subject to access by any 

Defendant, except as necessary to comply with written requests from the Receiver 

acting pursuant to its authority under this Order; 

C. Incurring charges or cash advances on any credit, debit, or ATM card issued in the 

name, individually or jointly, of any Corporate Defendant or any corporation, 

partnership, or other entity directly or indirectly owned, managed, or controlled by 

any Defendant or ofwhich any Defendant is an officer, director, member, or 

manager. This includes any corporate bankcard or corporate credit card account for 

which any Defendant is, or was on the date that this Order was signed, an authorized 

signor; or 

D. Cashing any checks or depositing any money orders or cash received from 

consumers, clients, or customers of any Defendant. 

Page 11 of 34 
E. The Assets affected by this Section shall include: (1) all Assets ofDefendants as of 

the time this Order is entered; and (2) Assets obtained by Defendants after this Order 

is entered if those Assets are derived from any activity that is the subject of the 

Complaint in this matter or that is prohibited by this Order. This Section does not 

prohibit any transfers to the Receiver or repatriation offoreign Assets specifically 

required by this order. 

V. DUTIES OF ASSET HOLDERS AND OTHER THIRD PARTIES 

IT IS FURTHER ORDERED that any financial or brokerage institution, Electronic 

Data Host, credit card processor, payment processor, merchant bank, acquiring bank, 

independent sales organization, third party processor, payment gateway, insurance company, 

business entity, or person who receives actual notice ofthis Order (by service or otherwise) 

that: (a) has held, controlled, or maintained custody, through an account or otherwise, of any 

Document on behalf ofany Defendant or any Asset that has been owned or controlled, 

directly or indirectly, by any Defendant; held, in part or in whole, for the benefit ofany 

Defendant; in the actual or constructive possession ofany Defendant; or owned or controlled 

by, in the actual or constructive possession of, or otherwise held for the benefit of, any 

corporation, partnership, asset protection trust, or other entity that is directly or indirectly 

owned, managed or controlled by any Defendant; (b) has held, controlled, or maintained 

custody, through an account or otherwise, of any Document or Asset associated vvith credits, 

debits, or charges made on behalf of any Defendant, including reserve funds held by payment 

processors, credit card processors, merchant banks, acquiring banks, independent sales 

organizations, third party processors, payment gateways, insurance companies, or other 

Page 12 of 34 
entities; or (c) has extended credit to any Defendant, including through a credit card account, 

shall: 

A. Hold, preserve, and retain within its control and prohibit the withdrawal, removal, 

alteration, assignment, transfer, pledge, encumbrance, disbursement, dissipation, 

relinquishment, conversion, sale, or other disposal of any such Document or Asset, as 

well as all Documents or other property related to such Assets, except by further 

order ofthis Court; provided, however, that this provision does not prohlbit an 

Individual Defendant from incurring charges on a personal credit card established 

prior to entry ofthis Order, up to the pre-existing credit limit; 

B. Deny any person, except the Receiver, access to any safe deposit box, commercial 

mail box, or storage facility that is titled in the name of any Defendant, either 

individually or jointly, or otherwise subject to access by any Defendant; 

C. Provide FTC counsel and the Receiver, within three (3) days ofreceiving a copy of 

this Order, a sworn statement setting forth, for each Asset or account covered by this 

Section: 

1. The identification number ofeach such account or Asset; 

2. The balance ofeach such account, or a description ofthe nature and value ofeach 

such Asset as ofthe close of business on the day on which this Order is served, 

and, ifthe account or other Asset has been closed or removed, the date closed or 

removed, the total funds removed in order to close the account, and the name of 

the person or entity to whom such account or other Asset was remitted; and 

Page 13 of 34 
3. The identification of any safe deposit box, commercial mail box, or storage 

facility that is either titled in the name, individually orjointly, of any Defendant, 

or is otherwise subject to access by any Defendant; and 

D. Upon the request ofFTC counsel or the Receiver, promptly provide FTC counsel and 

the Receiver with copies ofall records or other Documents pertaining to any account 

covered by this Section or Asset, including originals or copies ofaccount 

applications, account statements, signature cards, checks, drafts, deposit tickets, 

transfers to and from the accounts, including wire transfers and wire transfer 

instructions, all other debit and credit instruments or slips, currency transaction 

reports, l 099 forms, and all logs and records pertaining to safe deposit boxes, 

commercial mail boxes, and storage facilities. 

E. Provided, however, that this Section does not prohibit any transfers to the Receiver or 

repatriation offoreign Assets specifically required by this order. 

VI. FINANCIAL DISCLOSURES 

IT IS FURTHER ORDERED that each Defendant, within five (5) days ofservice of 

this Order upon them, shall prepare and deliver to FTC counsel and the Receiver: 

A. Completed financial statements on the forms attached to this Order as Attachment A 

(Financial Statement oflndividual Defendant) for each Individual Defendant, and 

Attachment B (Financial Statement ofCorporate Defendant) for each Corporate 

Defendant; and 

B. Completed Attachment C (IRS Form 4506, Request for Copy ofa Tax Return) for 

each Individual and Corporate Defendant. 

VII. FOREIGN ASSET REPATRIATION 

Page 14 of 34 
IT IS FURTHER ORDERED that within five (5) days following the service ofthis 

Order, each Defendant shall: 

A. Provide FTC counsel and the Receiver with a full accounting, verified under oath and 

accurate as ofthe date ofthis Order, of all Assets, Documents, and accounts outside 

ofthe United States which are: (1) titled in the name, individually or jointly, of any 

Defendant; (2) held by any person or entity for the benefit of any Defendant or for the 

benefit of, any corporation, partnership, asset protection trust, or other entity that is 

diJ;ectly or indirectly owned, managed or controlled by any Defendant; or (3) under 

the direct or indirect control, whether jointly or singly, of any Defendant; 

B. Take all steps necessary to provide FTC counsel and Receiver access to all 

Documents and records that may be held by third parties located outside ofthe 

territorial United States of America, including signing the Consent to Release of 

Financial Records appended to this Order as Attachment D. 

C. Transfer to the territory ofthe United States and all Documents and Assets located in 

foreign countries which are: (1) titled in the name, individually or jointly, of any 

Defendant; (2) held by any person or entity for the benefit of any Defendant or for the 

benefit of, any corporation, partnership, asset protection trust, or other entity that is 

directly or indirectly owned, managed or controlled by any Defendant; or (3) under 

the direct or indirect control, whether jointly or singly, ofany Defendant; and 

D. The same business day as any repatriation, (1) notify the Receiver and FTC counsel 

ofthe name and location ofthe financial institution or other entity that is the recipient 

ofsuch Documents or Assets; and (2) serve this Order on any such financial 

institution or other entity. 

Page 15 of 34 
VIII. NON~INTERFERENCE WITH REPATRIATION 

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

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

receive actual notice ofthis Order, whether acting directly or indirectly, are hereby 

temporarily restrained and enjoined from taking any action, directly or indirectly, which may 

result in the encumbrance or dissipation of foreign Assets, or in the hindrance ofthe 

repatriation required by this Order, including, but not limited to: 

A. Sending any communication or engaging in any other act, directly or indirectly, that 

results in a determination by a foreign trustee or other entity that a "duress" event has 

occurred under the terms of a foreign trust agreement until such time that all 

Defendants' Assets have been fully repatriated pursuant to this Order; or 

B. Notifying any trustee, protector or other agent of any foreign trust or other related 

entities of either the existence of this Order, or ofthe fact that repatriation is required 

pursuant to a court order, until such time that all Defendants' Assets have been fully 

repatriated pursuant to this Order. 

IX. CONSUMER CREDIT REPORTS 

IT IS FURTHER ORDERED that the FTC may obtain credit reports concerning any 

Defendants pursuant to Section 604(a)(l) ofthe Fair Credit Reporting Act, 15 U.S.C. 

1681b(a)(l ), and that, upon written request, any credit reporting agency from which such 

reports are requested shall provide them to the FTC. 

X. PRESERVATION OF RECORDS 

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 

Page 16 of 34 
receive actual notice ofthis Order, whether acting directly or indirectly, are hereby 

temporarily restrained and enjoined from: 

A. Destroying, erasing, falsifying, writing over, mutilating, concealing, altering, 

transferring, or otherwise disposing of, in any manner, directly or indirectly, 

Documents that relate to: (1) the business, business practi~es, Assets, or business or 

personal finances of any Defendant; (2) the business practices or finances ofentities 

directly or indirectly under the control ofany Defendant; or (3) the business practices 

or finances ofentities directly or indirectly under common control with any other 

Defendant; and 

B. Failing to create and maintain Documents that, in reasonable detail, accurately, fairly, 

and completely reflect Defendants' incomes, disbursements, transactions, and use of 

Defendants' Assets. 

XI. TEMPORARY RECEIVER 

IT IS FURTHER ORDERED that Cotton Wright is appointed as temporary receiver of 

the Receivership Entities with full powers of an equity receiver. The Receiver shall be solely 

the agent ofthis Court in acting as Receiver under this Order. 

XII. DUTIES AND AUTHORITY OF RECEIVER 

IT IS FURTHER ORDERED that the Receiver is directed and authorized to 

accomplish the following: 

A. Assume full control ofReceivership Entities by removing, as the Receiver deems 

necessary or advisable, any director, officer, independent contractor, employee, 

attorney, or agent of any Receivership Entity from control of, management of, or 

participation in, the affairs of the Receivership Entity; 

Page 17 of 34 
B. Take exclusive custody, control, and possession of all Assets and Documents of, or in 

the possession, custody, or under the control of, any Receivership Entity, wherever 

situated; 

C. Take exclusive custody, control, and possession of all Documents or Assets 

associated with credits, debits, or charges made on behalf ofany Receivership Entity, 

wherever situated, including reserve funds held by payment processors, credit card 

processors, merchant banks, acquiring banks, independent sales organu;ations, third 

party processors, payment gateways, insurance companies, or other entities; 

D. Conserve, hold, manage, and prevent the loss of all Assets ofthe Receivership 

Entities, and perform all acts necessary or advisable to preserve the value of those 

Assets. The Receiver shall assume control over the income and profits therefrom and 

all sums of money now or hereafter due or owing to the Receivership Entities. The 

Receiver shall have full power to sue for, coliect, and receive, all Assets ofthe 

Receivership Entities and of other persons or entities whose interests are now under 

the direction, possession, custody, or control of, the Receivership Entities. Provided, 

however, that the Receiver shall not attempt to collect any amount from a consumer if 

the Receiver believes the consumer's debt to the Receivership Entities has resulted 

from the deceptive acts or practices or other violations oflaw alleged in the 

Complaint in this matter, without prior Court approval; 

E. Obtain, conserve, hold, manage, and prevent the loss of all Documents ofthe 

Receivership Entities, and perform all acts necessary or advisable to preserve such 

Documents. The Receiver shall: divert mail; preserve all Documents of the 

Receivership Entities that are accessible via electronic means (such as online access 

Page 18 of 34 
to financial accounts and access to electronic documents held onsite or by Electronic 

Data Hosts, by changing usemames, ·passwords or other log-in credentials; take 

possession of all electronic Documents ofthe Receivership Entities stored onsite or 

remotely; take whatever steps necessary to preserve all such Documents; and obtain 

the assistance ofthe FTC's Digital Forensic Unit for the purpose of obtaining 

electronic documents stored onsite or remotely; 

F. Choose, engage, and employ attorneys, accountants, appraisers, and other 

independent contractors and technical specialists, as the Receiver deems advisable or 

necessary in the performance ofduties and responsibilities under the authority 

granted by this Order; 

G. Make payments and disbursements from the receivership estate that are necessary or 

advisable for carrying out the directions of, or exercising the authority granted by, 

this Order, and to incur, or authorize the making of, such agreements as may be 

necessary and advisable in discharging his or her duties as Receiver. The Receiver 

shall apply to the Court for prior approval of any payment of any debt or obligation 

incurred by the Receivership Entities prior to the date of entry of this Order, except 

payments that the Receiver deems necessary or advisable to secure Assets ofthe 

Receivership Entities, such as rental payments; 

H. Take all steps necessary to secure and take exclusive custody ofeach location from 

which the Receivership Entities operate their businesses. Such steps may include, but 

are not limited to, any ofthe following, as the Receiver deems necessary or advisable: 

(1) securing the location by changing the locks and alarm codes and disconnecting 

any internet access or other means of access to the computers, servers, internal 

Page 19 of 34 
networks, or other records maintained at that location; and (2) requiring any persons 

present at the location to leave the premises, to provide the Receiver with proof of 

identification, and/or to demonstrate to the satisfaction of the Receiver that such 

persons are not removing from the premises Documents or Assets ofthe Receivership 

Entities. Law enforcement personnel, including, but not limited to, police or sheriffs, 

may assist the Receiver in implementing these provisions in order to keep the peace 

and maintain security. If requested by the Receiver, the United States Marshal will 

provide appropriate and necessary assistance to the Receiver to implement this Order 

and is authorized to use any necessary and reasonable force to do so; 

I. Take all steps necessary to prevent the modification, destruction, or erasure of any 

web page or website registered to and operated, in whole or in part, by any 

Defendants, and to provide access to all such web page or websites to the FTC's 

representatives, agents, and assistants, as well as Defendants and their 

representatives; 

J. Enter into and cancel contracts and purchase insurance as advisable or necessary; 

K. Prevent the inequitable distribution of Assets and determine, adjust, and protect the 

interests ofconsumers who have transacted business with the Receivership Entities; 

L. Make an accounting, as soon as practicable, ofthe Assets and financial condition of 

the receivership and file the accounting with the Court and deliver copies thereof to 

all parties; 

M. Institute, compromise, adjust, appear in, intervene in, defend, dispose of, or otherwise 

become party to any legal action in state, federal or foreign courts or arbitration 

proceedings as the Receiver deems necessary and advisable to preserve or recover the 

Page 20 of 34 
Assets of the Receivership Entities, or to carry out the Receiver's mandate under this 

Order, including but not limited to, actions challenging fraudulent or voidable 

transfers; 

N. Issue subpoenas to obtain Documents and records pertaining to the Receivership, and 

conduct discovery in this action on behalf ofthe receivership estate, in addition to 

obtaining other discovery as set forth in this Order; 

0. Open one or more bank accounts at designated depositories for funds ofthe 

Receivership Entities. The Receiver shall deposit all funds ofthe Receivership 

Entities in such designated accounts and shall make all payments and disbursements 

from the receivership estate from such accounts. The Receiver shall serve copies of 

monthly account statements on all parties; 

P. Maintain accurate records ofall receipts and expenditures incurred as Receiver; 

Q. Allow the FTC's representatives, agents, and assistants, as well as Defendants' 

representatives and Defendants themselves, reasonable access to the premises ofthe 

Receivership Entities, or any other premises where the Receivership Entities conduct 

business. The purpose of this access shall be to inspect and copy any and all books, 

records, Documents, accounts, and other property owned by, or in the possession of, 

the Receivership Entities or their agents. The Receiver shall have the discretion to 

determine the time, manner, and reasonable conditions ofsuch access; 

R. Allow the FTC's representatives, agents, and assistants, as well as Defendants and 

their representatives reasonable access to all Documents in the possession, custody, or 

control ofthe Receivership Entities; 

Page 21 of34 
S. Cooperate with reasonable requests for information or assistance from any state or 

federal civil or criminal law enforcement agency; 

T. Suspend business operations ofthe Receivership Entities if in the judgment ofthe 

Receiver such operations cannot be continued legally and profitably; 

U. Ifthe Receiver identifies a nonparty entity as a Receivership Entity, promptly notify 

the entity as well as the parties, and inform the entity that it can challenge the 

Receiver's determination by filing a motion with the Court. Provided, however, that 

the Receiver may delay providing such notice until the Receiver has establish~d 

control ofthe nonparty entity and its assets and records, ifthe Receiver determines 

that notice to the entity or the parties before the Receiver establishes control over the 

entity may result in the destruction ofrecords, dissipation of assets, or any other 

obstruction ofthe Receiver's control ofthe entity; and 

V. Ifin the Receiver's judgment the business operations cannot be continued legally and 

profitably, take all steps necessary to ensure that any ofthe Receivership Entities' 

web pages or websites relating to the activities alleged in the Complaint cannot be 

accessed by the public, or are modified for consumer education and/or informational 

purposes, and take all steps necessary to ensure that any telephone numbers 

associated with the Receivership Entities cannot be accessed by the public, or are 

answered solely to provide consumer education or information regarding the status of 

operations. 

XIII. TRANSFER OF RECEIVERSHIP PROPERTY TO RECEIVER 

IT IS FURTHER ORDERED that Defendants and any other person, with possession, 

custody or control ofproperty of, or records relating to, the Receivership Entities shall, upon 

Page 22 of 34 
notice ofthis Order by personal service or otherwise, fully cooperate with and assist the 

Receiver in taking and maintaining possession, custody, or control ofthe Assets and 

Documents ofthe Receivership Entities and immediately transfer or deliver to the Receiver 

possession, custody, and control of, the following: 

A. All Assets held by or for the benefit of the Receivership Entities; 

B. All Documents or Assets associated with credits, debits, or charges made on behalf of 

any Receivership Entity, wherever situated, including reserve runds held by payment 

processors, credit card processors, merchant banks, acquiring banks, independent 

sales organizations, third party processors, payment gateways, insurance companies, 

or other entities; 

C. All Docwnents ofor pertaining to the Receivership Entities; 

D. All computers, electronic devices, mobile devices and machines used to conduct the 

business ofthe Receivership Entities; 

E. All Assets and Documents belonging to other persons or entities whose interests are 

under the direction, possession, custody, or control ofthe Receivership Entities; and 

F. All keys, codes, user names and passwords necessary to gain or to secure access to 

any Assets or Documents of or pertaining to the Receivership Entities, including 

access to their business premises, means of communication, accounts, computer 

systems (onsite and remote), Electronic Data Hosts, or other property. 

G. In the event that any person or entity fails to deliver or transfer any Asset or 

Document, or otherwise fails to comply with any provision ofthis Section, the 

Receiver may file an Affidavit ofNon-Compliance regarding the failure and a motion 

seeking compliance or a contempt citation. 

Page 23 of34 
XIV. PROVISION OF INFORMATION TO RECEIVER 

IT IS FURTHER ORDERED that Defendants shall immediately provide to the 

Receiver: 

A. A list of all Assets and accounts ofthe Receivership Entities that are held in any name 

other than the name of a Receivershlp Entity, or by any person or entity other than a 

Receivership Entity; 

B. A list ofall agents, employees, officers, attorneys, servants and those persons in 

active concert and participation with the Receivership Entities, or who have been 

associated or done business with the Receivership Entities; and 

C. A description of any documents covered by attorney-client privilege or attorney work 

product, including files where such documents are likely to be located, authors or 

recipients ofsuch documents, and search terms likely to identify such electronic 

documents. 

XV. COOPERATION WITH THE RECEIVER 

IT IS FURTHER ORDERED that Defendants; Receivership Entities; Defendants' or 

Receivership Entities' officers, agents, employees, and attorneys, all other persons in active 

concert or participation with any ofthem, and any other person with possession, custody, or 

control ofproperty of or records relating to the Receivership entities who receive actual 

notice of this Order shall fully cooperate with and assist the Receiver. This cooperation and 

assistance shall include, but is not limited to, providing information to the Receiver that the 

Receiver deems necessary to exercise the authority and discharge the responsibilities ofthe 

Receiver under this Order; providing any keys, codes, user names and passwords required to 

access any computers, electronic devices, mobile devices, and machines ( onsite or remotely) 

Page 24 of34 
and any cloud account (including specific method to access account) or electronic file in any 

medium; advising all persons who owe money to any Receivership Entity that all debts 

should be paid directly to the Receiver; and transferring funds at the Receiver's direction and 

producing records related to the Assets and sales of the Receivership Entities. 

XVI. NON-INTERFERENCE WITH THE RECEIVER 

IT IS FURTHER ORDERED that Defendants; Receivership Entities; Defendants' or 

Receivership Entities' officers, agents, employees, attorneys, and all other persons in active 

concert or participation with any ofthem, who receive actual notice of this Order, and any 

other person served with a copy ofthis Order, are hereby restrained and enjoined from 

directly or indirectly: 

A. Interfering with the Receiver's efforts to manage, or take custody, control, or 

possession of, the Assets or Documents subject to the receivership; 

B. Transacting any ofthe business ofthe Receivership Entities; 

C. Transferring, receiving, altering, selling, encumbering, pledging, assigning, 

liquidating, or otherwise disposing of any Assets owned, controlled, or in the 

possession or custody of, or in which an interest is held or claimed by, the 

Receivership Entities; or 

D. Refusing to cooperate with the Receiver or the Receiver's duly authorized agents in 

the exercise of their duties or authority under any order ofthis Court. 

XVII. STAY OF ACTIONS 

IT IS FURTHER ORDERED that, except by leave ofthis Court, during the pendency 

of the receivership ordered herein, Defendants, Defendants' officers, agents, employees, 

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

Page 25 of 34 
receive actual notice ofthis Order, and their corporations, subsidiaries, divisions, or 

affiliates, and all investors, creditors, stockholders, lessors, customers and other persons 

seeking to establish or enforce any claim, right, or interest against or on behalf of 

Defendants, and all others acting for or on behalf ofsuch persons, are hereby enjoined from 

taking action that would interfere with the exclusive jurisdiction ofthis Court over the Assets 

or Documents ofthe Receivership Entities, including, but not limited to: 

A. Filing or assisting in the filing of a petition for relief under the Bankruptcy Code, 11 

U.S.C. § 101 et seq., or of any similar insolvency proceeding on behalf ofthe 

Receivership Entities; 

B. Commencing, prosecuting, or continuing a judicial, administrative, or other action or 

proceeding against the Receivership Entities, including the issuance or employment 

of process against the Receivership Entities, except that such actions may be 

commenced ifnecessary to toll any applicable statute oflimitations; 

C. Filing or enforcing any lien on any asset of the Receivership Entities, taking or 

attempting to take possession, custody, or control of any Asset ofthe Receivership 

Entities; or attempting to foreclose, forfeit, alter, or terminate any interest in any 

Asset ofthe Receivership Entities, whether such acts are part of a judicial proceeding, 

are acts ofself-help, or otherwise. 

D. Provided, however, that this Order does not stay: (1) the commencement or 

continuation of a criminal action or proceeding; (2) the commencement or 

continuation ofan action or proceeding by a governmental unit to enforce such 

governmental unit's police or regulatory power; or (3) the enforcement of a judgment, 

Page 26 of34 
other than a money judgment, obtained in an action or proceeding by a governmental 

unit to enforce such governmental unit's police or regulatory power. 

XVIIl. COMPENSATION OF RECEIVER 

IT IS FURTHER ORDERED that the Receiver and all personnel hired by the Receiver 

as herein authorized, including counsel to the Receiver and accountants, are entitled to 

reasonable compensation for the performance ofduties pursuant to this Order and for the cost 

of actual out-of-pocket expenses incurred by them, from the Assets now held by, in the 

possession or control of, or which may be received by, the Receivership Entities. The 

Receiver shall file with the Court and serve on the parties periodic requests for the payment 

of such reasonable compensation, with the first such request filed no more than sixty (60) 

days after the date ofentry ofthis Order. The Receiver shall not. increase the hourly rates 

used as the bases for such fee applications without prior approval of the Court. 

XIX. RECEIVER'S BOND 

IT IS FURTHER ORDERED that the Receiver shall file with the Clerk ofthis Court a 

bond in the sum of$1000.00 with sureties to be approved by the Court, conditioned that the 

Receiver will well and truly perform the duties of the office and abide by and perform all acts 

the Court directs. 28 U.S.C. § 754. 

XX. RECEIVER'S REPORTS 

IT IS FURTHER ORDERED that the Receiver shall report to this Court on or before 

the date set for the hearing to show cause regarding the Preliminary Injunction, regarding: 

(1) the steps taken by the Receiver to implement the terms ofthis Order; (2) the value ofall 

liquidated and unliquidated assets ofthe Receivership Entities; (3) the sum of all liabilities of 

the Receivership Entities; (4) the steps the Receiver intends to take in the future to: (a) 

Page 27 of34 
prevent any diminution in the value of assets of the Receivership Entities, (b) pursue 

receivership assets from third parties, and ( c) adjust the liabilities of the Receivership 

Entities, if appropriate; (5) whether the business of the Receivership Entities can be operated 

lawfully and profitably; and (6) any other matters which the Receiver believes should be 

brought to the Court's attention. Provided, however, if any of the required information 

would hinder the Receiver's ability to pursue receivership assets, the portions of the 

Receiver's report containing such information may be filed under seal and not served on the 

parties. 

XXI. IMMEDIATE ACCESS TO BUSINESS PREMISES AND RECORDS 

IT IS FURTHER ORDERED that: 

A. In order to allow the FTC and the Receiver to preserve Assets and evidence relevant 

to this action and to expedite discovery, the FTC and the Receiver, and their 

representatives, agents, contractors, and assistants, shall have immediate access to the 

business premises and storage facilities, owned, controlled, or used by the 

Receivership Entities. Such locations include, but are not limited to, 5700 Executive 

Center Drive, Suite 102, Charlotte, North Carolina, and any offsite location or 

commercial mailbox used by the Receivership Entities. The Receiver may exclude 

Defendants, Receivership Entities, and their employees from the business premises 

during the immediate access; 

B. The FTC and the Receiver, and their representatives, agents, contractors, and 

assistants, are authorized to remove Documents from the Receivership Entities' 

premises in order that they may be inspected, inventoried, and copied. The FTC shall 

return any removed materials to the Receiver within five (5) business days of 

Page 28 of 34 
completing inventorying and copying, or such time as is agreed upon by the FTC and 

the Receiver; 

C. The FTC's access to the Receivership Entities' documents pursuant to this Section 

shall not provide grounds for any Defendant to object to any subsequent request for 

documents served by the FTC; 

D. The FTC and the Receiver, and their representatives, agents, contractors, and 

assistants, are authorized to obtain the assistance offederal, state and local law 

enforcement officers as they deem necessary to effect service and to implement 

peacefully the provisions of this Order; 

E. If any Documents, computers, or electronic storage devices containing information 

related to the business practices or :finances ofthe Receivership Entities are at a 

location other than those listed herein, including personal residence(s) of any 

Defendant, then, immediately upon receiving notice ofthis order, Defendants and 

Receivership Entities shall produce to the Receiver all such Documents, computers, 

and electronic storage devices, along with any codes or passwords needed for access. 

In order to prevent the destruction of computer data, upon service ofthis Order, any 

such computers or electronic storage devices shall be powered down in the normal 

course ofthe operating system used on such devices and shall not be powered up or 

used until produced for copying and inspection; and 

F. If any communications or records of any Receivership Entity are stored with an 

Electronic Data Host, such Entity shall, immediately upon receiving notice ofthis 

order, provide the Receiver with the username, passwords, and any other login 

Page 29 of 34 
credential needed to access the communications and records, and shall not attempt to 

access, or cause a third-party to attempt to access, the communications or records. 

XXII. DISTRIBUTION OF ORDER BY DEFENDANTS 

IT IS FURTHER ORDERED that Defendants shall immediately provide a copy of this 

Order to each affiliate, telemarketer, marketer, sales entity, successor, assign, member, 

officer, director, employee, agent, independent contractor, client, attorney, spouse, 

subsidiary, division, and representative ofany Defendant, and shall, within ten (10) days 

from the date of entry ofthis Order, and provide the FTC and the Receiver with a sworn 

statement that this provision ofthe Order has been satisfied, which statement shall include 

the names, physical addresses, phone number, and email addresses ofeach such person or 

entity who received a copy ofthe Order. Furthermore, Defendants shall not take any action 

that would encourage officers, agents, members, directors, employees, salespersons, 

independent contractors, attorneys, subsidiaries, affiliates, successors, assigns or other 

persons or entities in active concert or participation with them to disregard this Order or 

believe that they are not bound by its provisions. 

XXIII. EXPEDITED DISCOVERY 

IT IS FURTHER ORDERED that, notwithstanding the provisions ofthe Fed. R. Civ. P. 

26(d) and (f) and 30(a)(2)(A)(iii), and pursuant to Fed. R Civ. P. 30(a), 34, and 45, the FTC 

and the Receiver are granted leave, !J.t any time after service ofthis Order, to conduct limited 

expedited discovery for the purpose of discovering: (1) the nature, location, status, and 

extent ofDefendants' Assets; (2) the nature, location, and extent of Defendants' business 

transactions and operations; (3) Documents reflecting Defendants' business transactions and 

Page 30 of 34 
operations; or (4) compliance with this Order. The limited expedited discovery set forth in 

this Section shall proceed as follows: 

A. The FTC and the Receiver may take the deposition of parties and non-parties. Fortyeight (48) hours' notice shall be sufficient notice for such depositions. The 

limitations and conditions set forth in Rules 30(a)(2)(B) and 31(a)(2)(B) ofthe 

Federal Rules ofCivil Procedure regarding subsequent depositions of an individual 

shall not apply to depositions taken pursuant to this Section. Any such deposition 

taken pursuant to this Section shall not be counted towards the deposition limit set 

forth in Rules 30(a)(2)(A) and 3 l(a)(2)(A) and depositions may be taken by telephone 

or other remote electronic means; 

B. The FTC and the Receiver may serve upon parties requests for production of 

Documents or inspection that require production or inspection within five (5) days of 

service, provided, however, that three (3) days of notice shall be deemed sufficient for 

the production of any such Documents that are maintained or stored only in an 

electronic format; 

C. The FTC and the Receiver may serve upon parties interrogatories that require 

response within five (5) days after the FTC serves such interrogatories; 

D. The FTC and the Receiver may serve subpoenas upon non-parties that direct 

production or inspection within five (5) days ofservice; 

E. Service ofdiscovery upon a party to this action, taken pursuant to this Section, shall 

be sufficient if made by facsimile, email, or by overnight delivery; and 

F. Any expedited discovery taken pursuant to this Section is in addition to, and is not 

subject to, the limits on discovery set forth in the Federal Rules ofCivil Procedure 

Page 31 of34 
and the Local Rules ofthis Court. The expedited discovery permitted by this Section 

does not require a meeting or conference ofthe parties, pursuant to Rules 26(d) & (f) 

ofthe Federal Rules of Civil Procedure. 

XXIV. SERVICE OF TillS ORDER 

IT IS FURTHER ORDERED that copies ofthis Order as well as the Motion for 

Temporary Restraining Order and all other pleadings, Documents, and exhibits filed 

contemporaneously with that Motion (other than the complaint and summons), may be 

served by any means, including facsimile transmission, electronic mail or other electronic 

messaging, personal or overnight delivery, U.S. Mail or FedEx, by agents and employees of 

the FTC, by any law enforcement agency, or by private process server, upon any Defendant 

or any person (including any financial institution) that may have possession, custody or 

control of any Asset or Document of any Defendant, or that may be subject to any provision 

of this Order pursuant to Rule 65( d)(2) ofthe Federal Rules of Civil Procedure. For purposes 

ofthis Section, service upon any branch, subsidiary, affiliate or office of any entity shall 

effect service upon the entire entity. 

XXV. . CORRESPONDENCE AND SERVICE ON THE FTC 

IT IS FURTHER ORDERED that, for the purpose ofthis Order, all correspondence 

and service of pleadings on the FTC shall be addressed to: Quinn Martin, Federal Trade 

Commission, 600 Pennsylvania Avenue NW, Room CC-10232, Washington, DC 20580, 

email: qmartin@ftc.gov. 

XXVI. PRELIMINARY INJUNCTION HEARING 

IT IS FURTHER ORDERED that, pursuant to Fed. R. Civ. P. 65(b), Defendants shall 

appear before this Court on the 15th day of February, 2019, at 2:00 o'clock p.m., at the 

Page 32 of 34 
United States Courthouse, Courtroom 2-2, Charlotte, North Carolina, to show cause, if there 

is any, why this Court should not enter a preliminary injunction, pending final ruling on the 

Complaint against Defendants, enjoining the violations ofthe law alleged in the Complaint, 

continuing the freeze oftheir Assets, continuing the receivership, and imposing such 

additional relief as may be appropriate. 

XXVII. BRIEFS AND AFFIDAVITS CONCERNING PRELIMINARY INJUNCTION 

IT IS FURTHER ORDERED that: 

A. Defendants shall file with the Court and serve on FTC counsel any answering 

pleadings, affidavits, motions, expert reports or declarations, or legal memoranda no 

later than four ( 4) days prior to the order to show cause hearing scheduled pursuant to 

this Order. The FTC may file responsive or supplemental pleadings, materials, 

affidavits, or memoranda with the Court and serve the same on counsel for 

Defendants no later than one (1) day prior to the order to show Cause hearing. 

Provided that such affidavits, pleadings, motions, expert reports, declarations, legal 

memoranda or oppositions must be served by personal or overnight delivery, 

facsimile or email, and be received by the other party or parties no later than 5:00 

p.m. (EST) on the appropriate dates set forth in this Section. 

B. The question ofwhether this Court should enter a preliminary injunction shall be 

resolved on the pleadings, declarations, exhibits, and memoranda filed by, and oral 

argument of, the parties. Live testimony shall be heard only on further order ofthis 

Court. Any motion to permit such testimony shall be filed with the Court and served 

on counsel for the other parties at least five (5) days prior to the preliminary 

injunction hearing in this matter. Such motion shall set forth the name, address, and 

Page 33 of34 
telephone number of each proposed witness, a detailed summary or affidavit 

reyealing the substance of each proposed witness's expected testimony, and an 

explanation of why the taking of live testimony would be helpful to this Court. Any 

papers opposing a timely motion to present live testimony or to present live testimony 

in response to another party's timely motion to present live testimony shall be filed 

with this Court and served on the other parties at least three (3) days prior to the order 

to show cause hearing. Provided, however, that service shall be performed by 

personal or overnight delivery, facsimile or email, and Documents shall be deliv~red 

so that they shall be received by the other parties no later than 5:00 p.m. (EST) on the 

appropriate dates provided in this Section. 

XXVIII. DURATION OF THE ORDER 

IT IS FURTHER ORDERED that this Order shall expire fourteen (14) days from the 

date of entry noted below, unless within such time, the Order is extended for an additional 

period pursuant to Fed. R. Civ. P. 65(b)(2). 

XXIX. RETENTION OF JURISDICTION 

IT IS FURTHER ORDERED that this Court shall retain jurisdiction of this matter for 

all purposes. 

IT IS SO ORDERED, tlris--46--day of~ 2019, at 

'clock a.m6) 

UNITED STATES DISTRICT JUDGE 

~o

Page 34 of34