UNITED STATES DISTRICT COURT 

MIDDLE DISTRICT OF FLORIDA 2016 Jmi -8 PM 2: 11 

ORLANDO DIVISION 

FEDERAL TRADE COMMISSION, and 

OFFICE OF THE ATTORNEY 

GENERAL, STATE OF FLORIDA, 

DEPARTMENT OF LEGAL AFFAIRS, 

Plaintiffs, 

v. 

LIFE MANAGEMENT SERVICES OF 

ORANGE COUNTY, LLC, a Florida 

limited liability company, 

LOYAL FINANCIAL & CREDIT 

SERVICES, LLC, a Florida limited 

liability company, also d/b/a FOC Credit, 

and Reward Services, 

IVD RECOVERY, LLC, a Florida limited 

liability company, 

KWP SERVICES, LLC, a Florida limited 

liability company, 

KWP SERVICES OF FLORIDA, LLC, a 

Florida limited liability company, 

LPSOFFLA LLC, a Florida limited 

liability company, 

LPSOFFLORIDA L.L.C., a Florida 

limited liability company, 

PW&F CONSULTANTS OF FLORIDA 

LLC, a Florida limited liability company, 

UAD SECURE SERVICES LLC, a 

Florida limited liability company, 

Page 1 of34 

M' 'D''\ - I -.· I Uc ••.. · . 

Df\UdWU. 1· L 

Case No: 6:16-cv-982-0rl-41TBS 

[Filed Under Seal] 
UAD SECURE SERVICE OF FL LLC, a 

Florida limited liability company, 

URB MANAGEMENT, LLC, a Florida 

limited liability company, 

YCC SOLUTIONS LLC, a Florida limited 

liability company, 

YFP SOLUTIONS LLC, a Florida limited 

liability company, 

KEVIN W. GUICE, individually and as an 

officer of LOYAL FINANCIAL & CREDIT 

SERVICES, LLC, 

CHASE P. JACKOWSKI, individually 

and as an officer of LPSOFFLA LLC, 

LPSOFFLORIDA L.L.C., and YFP 

SOLUTIONS LLC, 

LINDA N. MCNEALY, individually and as 

an officer of LOY AL FINANCIAL & 

CREDIT SERVICES, LLC, 

CLARENCE H. WAHL, a/k/a Harry C. 

Wahl, individually and as an officer of KWP 

SERVICES OF FLORIDA, LLC and LIFE 

MANAGEMENT SERVICES OF 

ORANGE COUNTY, LLC, 

KAREN M. WAHL, individually and as an 

officer ofKWP SERVICES, LLC, 

Defendants, and 

ROBERT GUICE, individually, 

TIMOTHY WOODS, individually, 

Relief Defendants. 

TEMPORARY RESTRAINING ORDER 

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Plaintiffs, the Federal Trade Commission ("FTC"), and the Office of the Attorney General, 

State of Florida, Department of Legal Affairs ("State of Florida"), have filed their Complaint for 

Permanent Injunction and Other Equitable Relief pursuant to Section 13(b) of the Federal Trade 

Commission Act ("FTC Act"), 15 U.S.C. § 53(b), the Telemarketing and Consumer Fraud and 

Abuse Prevention Act ("Telemarketing Act"), 15 U.S.C. §§ 6101-6108, and the Florida Deceptive 

and Unfair Trade Practices Act, Chapter 501, Part II, Florida Statutes ("FDUTPA") (Doc. S-1), 

and have moved, pursuant to Federal Rule of Civil Procedure 65(b ), for an ex parte Temporary 

Restraining Order, Asset Freeze, Appointment of a Temporary Receiver, Immediate Access, Other 

Equitable Relief, and an Order to Show Cause Why a Preliminary Injunction Should Not Issue 

against Defendants Life Management Services of Orange County, LLC, Loyal Financial & Credit 

Services, LLC, IVD Recovery, LLC, KWP Services, LLC, KWP Services of Florida LLC, 

LPSofFLA LLC, LPSofFlorida L.L.C., PW&F Consultants of Florida LLC, UAD Secure Service 

of FL LLC, UAD Secure Services LLC, URB Management, LLC, YCC Solutions LLC, YFP 

Solutions LLC, Kevin W. Guice, Chase P. Jackowski, Linda N. McNealy, Clarence H. Wahl, and 

Karen M. Wahl, and Relief Defendants Robert Guice and Timothy Woods (Doc. S-11). 

The Court, having considered the Complaint, the ex parte motion for a temporary 

restraining order, and all declarations, exhibits, and the memorandum of points and authorities 

attached in support, and being otherwise advised, GRANTS Plaintiffs' motion for a temporary 

restraining order and FINDS and ORDERS as follows: 

I. FINDINGS 

A. This Court has jurisdiction over the subject matter of this 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. 

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B. There is good cause to believe that Defendants have engaged in and are likely to engage in 

acts or practices that violate Section 5(a) of the FTC Act, 15 U.S.C. § 45(a); the FTC's 

Trade Regulation Rule entitled the "Telemarketing Sales Rule" ("TSR"), 16 C.F.R. Part 

310; and Section 501.204 of the FDUTPA, Chapter 501, Part II, and that Plaintiffs are 

therefore likely to prevail on the merits of this action. 

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

Defendants' ongoing violations of the FTC Act, the TSR, and Section 501.204 of the 

FDUTPA unless Defendants are restrained and enjoined by Order of this Court. 

D. There is good cause to believe that Relief Defendants Robert Guice and Timothy Woods 

have received funds that can be traced directly to Defendants' deceptive acts or practices, 

and that they have no legitimate claim to those funds. 

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

to grant effective final relief for consumers (including monetary restitution, rescission, 

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

disposition or concealment by Defendants or Relief Defendants of assets, documents, 

records, or other evidence if Defendants are provided with advance notice of Plaintiffs' 

application, Defendants' and Relief Defendants' assets are not frozen, and Corporate 

Defendants are not placed into receivership. Therefore, there is good cause for the Court 

to (1) issue this Order without prior notice to Defendants or Relief Defendants pursuant to 

Federal Rule of Procedure 65(b); (2) appoint a Temporary Receiver over the Corporate 

Defendants; (3) freeze Defendants' and Relief Defendants' assets; (4) grant Plaintiffs' and 

the Temporary Receiver immediate access to Defendants' business premises; (5) authorize 

Plaintiffs to take expedited discovery; and (6) order the ancillary relief described below. 

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F. Weighing the equities and considering Plaintiffs' likelihood of ultimate success on the 

merits, it is in the public interest that the Court enter an ex parte Temporary Restraining 

Order that temporarily: (1) enjoins Defendants from making misrepresentations, failing to 

make disclosures of material facts, violating the TSR, and violating Section 501.204 of the 

FDUTPA; (2) appoints a Receiver over Corporate Defendants; (3) freezes Defendants' and 

Relief Defendants' assets; (4) orders Defendants and Relief Defendants to show cause why 

a preliminary injunction should not issue; and (5) provides other equitable relief. 

G. No security is required of any agency of the United States for issuance of a temporary 

restraining order. Fed. R. Civ. P. 65(c). For the reasons stated in the Florida Attorney 

General's motion (Doc. S-7) for a waiver of the security requirement, the State of Florida 

is not required as a co-plaintiff with the FTC to give security before the issuance of this 

temporary restraining order. 

II. DEFINITIONS 

For the purpose of this Temporary Restraining Order ("Order"), the following definitions 

shall apply: 

A. "Corporate Defendants" means Life Management Services of Orange County, LLC, 

Loyal Financial & Credit Services, LLC, IVD Recovery, LLC, KWP Services, LLC, KWP 

Services of Florida LLC, LPSo:tFLA LLC, LPSo:tFlorida L.L.C., PW &F Consultants of 

Florida LLC, UAD Secure Service of FL LLC, UAD Secure Services LLC, URB 

Management, LLC, YCC Solutions LLC, and YFP Solutions LLC, and their divisions, 

subsidiaries, affiliates, predecessors, successors, and assigns, and any fictitious business 

entities or business names created or used by these entities, or any of them. 

B. "Debt Relief Product or Service" means any product, service, plan, or program 

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represented, expressly or by implication, to renegotiate, settle, or in any way alter the terms 

of payment or other terms of the debt or obligation between a Person and one or more 

creditors or debt collectors, including a reduction in the balance, interest rate, or fees owed 

by a Person to a creditor or debt collector. 

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

individually, collectively, or in any combination, and each of them by whatever names each 

_ might be known. 

D. "Individual Defendants" means Kevin W. Guice, Chase P. Jackowski, Linda N. 

McNealy, Clarence H. Wahl, and Karen M. Wahl, and by whatever other names each may 

be known. 

E. "National Do Not Call Registry" means the registry of telephone numbers maintained by 

the FTC, pursuant to Section 310.4(b )(1 )(iii)(B) of the TSR, 16 C.F .R. 

§ 310.4(b)(l)(iii)(B), of Persons who do not wish to receive Outbound Telephone Calls to 

induce the purchase of goods or services. 

F. "Outbound Telephone Call" means a telephone call initiated by a Telemarketer to induce 

the purchase of goods or services or to solicit a charitable contribution. 

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

corporation, partnership, proprietorship, association, cooperative, government or 

governmental subdivision or agency, or any other group or combination acting as an entity. 

H. "Receiver" or "Temporary Receiver" means the individual appointed as receiver or 

temporary receiver appointed in Section Error! Reference source not found. of this Order 

and any deputy receivers that shall be named by the temporary receiver. 

I. "Relief Defendants" means Robert Guice and Timothy Woods. 

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J. "Representatives" means Defendants' officers, agents, employees, attorneys, or any other 

Person in active concert or participation with any of them who receive actual notice of this 

Order. 

K. "Telemarketer" means any Person who, in connection with Telemarketing, initiates or 

receives telephone calls to or from a customer or donor. 

L. "Telemarketing" means any plan, program, or campaign that is conducted to induce the 

purchase of goods or services or a charitable contribution by use of one or more telephones. 

Ill. PROHIBITED BUSINESS ACTIVITIES 

It is hereby ORDERED that Defendants and Defendants' Representatives, whether acting 

directly or indirectly, in connection with promoting or offering for sale any good or service, 

including any Debt Relief Product or Service, are temporarily restrained and enjoined from: 

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

the following: 

1. That consumers who use Defendants' services will have their credit-card interest 

rates reduced substantially and permanently; 

2. That consumers who use Defendants' services will save thousands of dollars in a 

short time; 

3. That consumers who use Defendants' services will be able to pay off their creditcard debts much faster, typically three to five times faster; 

4. That Defendants can obtain money from a government fund, paid for by credit-card 

companies, that Defendants will use to pay off consumers' credit-card debts within 

18 months; 

5. That Defendants are representatives of, or otherwise affiliated with, consumers' 

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banks or other credit-card issuers, or credit-card associations such as MasterCard 

and Visa; or 

6. Any other fact material to consumers concerning any good or service, such as: the 

total costs; any material restrictions, limitations or conditions; or any material 

aspect of its performance, efficacy, nature, or central characteristics; 

B. Representing, or assisting others in representing, expressly or by implication, the benefits, 

performance, or efficacy of any good or service, unless the representation is nonmisleading, and, at the time such representation is made, Defendants possess and rely upon 

competent and reliable evidence to substantiate that the representation is true; and 

C. Failing to disclose, or disclose adequately, the material terms and conditions of 

Defendants' offer, including that Defendants' services may result in a consumer having to 

pay a variety of fees to credit-card issuers including, among others, balance-transfer fees, 

which can total three to five percent of a consumer's credit-card debt. 

IV. PROHIBITIONS REGARDING TELEMARKETING 

It is FURTHER ORDERED that Defendants and Defendants' Representatives, whether 

acting directly or indirectly, in connection with Telemarketing of any product or service, including 

any Debt Relief Product or Service, are temporarily restrained and enjoined from: 

A. Initiating, or causing others to initiate, an Outbound Telephone Call: 

1. That misrepresents, directly or by implication, any material aspect of any Debt 

Relief Product or Service, including the amount of money or the percentage of the 

debt amount that a consumer may save by using such service and the amount of 

time necessary to achieve the represented results; 

2. That misrepresents, directly or by implication, an affiliation with consumers' banks 

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or other credit-card issuers, or credit-card associations such as MasterCard and 

Visa; 

3. That fails to disclose, in a clear and conspicuous manner, that any Debt Relief 

Product or Service might result in a consumer having to pay additional fees to a 

credit-card issuer; 

4. That fails to disclose that any Debt Relief Product or Service that relies upon a 

consumer's failure to make timely payments to creditors or debt collectors, will 

likely adversely affect the consumer's creditworthiness, may result in the consumer 

being subject to collections or sued by creditors or debt collectors, and may increase 

the amount of money the consumer owes due to the accrual of fees and interest; 

5. To a Person whose telephone number is on the National Do Not Call Registry; 

6. That delivers a prerecorded message; 

7. To a telephone number within a given area code when Defendants have not, either 

directly or through another Person, paid the required annual fee for access to the 

telephone numbers within that area code that are included on the National Do Not 

Call Registry; 

B. Requesting or receiving payment of any fee or consideration from a consumer for any Debt 

Relief Products or Services until and unless 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 consumer and 

the consumer has made at least one payment pursuant to that settlement agreement, debt 

management plan, or other valid contractual agreement between the consumer and the 

creditor or debt collector; or 

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C. Violating any provision of the Telemarketing Sales Rule, 16 C.F .R. Part 310, attached as 

Attachment A. 

V. ASSET FREEZE 

It is FURTHER ORDERED that Defendants, Relief Defendants, and their 

Representatives, whether acting directly or indirectly, are temporarily restrained and enjoined 

from: 

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

dissipating, disbursing, assigning, relinquishing, spending, withdrawing, granting a lien or 

security interest or other interest in, or otherwise disposing any funds, real or personal 

property, accounts, contracts, shares of stock, lists of consumer names, or other assets, or 

any interest therein, wherever located, including outside the United States, that are: 

1. owned, controlled, or held, in whole or in part, by any Defendant or Relief 

Defendant; 

2. held, in whole or in part, for the direct or indirect benefit of, any Defendant or Relief 

Defendant; 

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

4. held by an agent of any Defendant or Relief Defendant as a retainer for the agent's 

provision of services to Defendants or Relief Defendants; 

5. owned or controlled by, or 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 

or Relief Defendant, or of which any Defendant or Relief Defendant is an officer, 

director, manager, or member. This includes, but is not limited to, any assets held 

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by, for, or subject to access by, any Defendant or Relief Defendant at any bank, 

credit union, or savings and loan institution, or at/with any broker-dealer, retirement 

fund custodian, money market or mutual fund, trustee, escrow agent, title company, 

insurance company, commodity trading company, precious metal dealer, payment 

processor, credit card processor, acquiring bank, merchant bank, independent sales 

organization, third party processor, payment gateway, automated clearing house 

processor, network transaction processor, bank debit processing agent, or other 

financial institution or depository of any kind, either within or outside the United 

States; or 

6. held in any account for which any Defendant or ReliefDefendant is, or was on the 

date that this Order was signed, an authorized signer; 

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

facilities titled in the name of any Defendant or Relief Defendant, either individually or 

jointly, or subject to access by, or under the control of, any Defendant or Relief Defendant; 

C. Incurring liens or other encumbrances on real property, personal property, or other assets 

in the name, individually or jointly, of any Defendant or Relief Defendant or of any 

corporation, partnership, or other entity directly or indirectly owned, managed, or 

controlled by any Defendant or Relief Defendant; 

D. Incurring charges or cash advances on any credit or bank card issued in the name of any 

Corporate Defendant, or for which payment is guaranteed by any Corporate Defendant. 

This includes, but is not limited to, any corporate bank card or corporate credit card account 

held by any Corporate Defendant and for which any Defendant or Relief Defendant is, or 

was on the date that this Order was signed, an authorized signer; and 

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E. Cashing any checks or depositing or processing any payments from consumers, clients, or 

customers of any Defendant; 

PROVIDED that the funds, property, and assets affected by this Section shall include all 

assets of all Defendants and Relief Defendants: (1) existing as of the date this Order was entered; 

or (2) acquired after entry of this Order from any activity that is the subject of, or is prohibited by, 

this Order. 

VI. DUTIES OF HOLDERS OF DEFENDANTS' AND RELIEF DEFENDANTS' ASSETS 

It is FURTHER ORDERED that any Person that: (a) is served with a copy of this Order 

or has actual or constructive knowledge of this Order; and (b) holds, controls, or maintains custody 

of, or has held, controlled, or maintained custody of at any time since January 2011, any account 

or asset (including reserve funds held by payment processors, credit card processors, payment 

merchant banks, acquiring banks, independent sales organizations, third party processors, payment 

gateways, insurance companies, or other entities) of any Defendant, Relief Defendant, or any 

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

managed, or controlled by any Defendant or Relief Defendant, or of which any Defendant or Relief 

Defendant is an officer, director, manager, or member shall: 

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

transfer, pledge, encumbrance, disbursement, dissipation, relinquishment, conversion, sale, 

liquidation, or other disposal of any such accounts or assets, as well as all documents or 

other property related to such accounts or assets; 

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 or Relief Defendant, 

either individually or jointly, or otherwise subject to access by any Defendant or Relief 

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Defendant; 

C. Provide Plaintiffs' counsel and the Receiver, within five (5) days of receiving a copy of 

this Order, a sworn statement setting forth: 

1. the identification number of each such account or asset; 

2. the balance of each such account, or a description of the nature and value of each 

such asset as of the close of business on the day on which this Order is served and, 

if the account or 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 asset was remitted; and 

3. the identification of any safe deposit box, commercial mail box, or storage facility 

that is either titled in the name, individually or jointly, of any Defendant or Relief 

Defendant, or is otherwise subject to access by any Defendant or Relief Defendant; 

and 

D. Within five (5) days of a request from any Plaintiff or the Receiver, promptly provide 

Plaintiffs and the Receiver with copies of all records or other documents pertaining to such 

account or asset, including originals or copies of account 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, 1099 forms, and all logs and records pertaining to such safe 

deposit boxes, commercial mail boxes, and storage facilities. 

E. Plaintiffs may properly serve this Order by facsimile transmission, hand delivery, or 

overnight carrier. This Section shall apply to existing accounts and assets, assets deposited 

or accounts opened after the effective date of this Order, and any accounts or assets 

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maintained, held, or controlled since January 2011. This Section shall not prohibit transfers 

in accordance with any provision of this Order, any further order of the Court, or by written 

agreement of the parties. 

VII. FINANCIAL REPORTS 

It is FURTHER ORDERED that each Defendant and Relief Defendant, within five (5) 

days of service of this Order upon them, shall prepare and deliver to Counsel for Plaintiffs and the 

Receiver: 

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

(Financial Statement of Individual Defendant) for themselves individually, and 

Attachment C (Financial Statement of Corporate Defendant) for each business entity 

under which they conduct business or of which they are an officer, director, member, or 

manager and for each trust for which any Defendant or Relief Defendant is a trustee. The 

financial statements shall be accurate as of the date of entry of this Order and signed under 

penalty of perjury. Each Defendant and Relief Defendant shall include in the financial 

statements all information requested in the statements, including a full listing, verified 

under oath, of all accounts, funds, and assets, whether located inside or outside of the 

United States, that are: (a) titled in the name of such Defendant or Relief Defendant, jointly, 

severally, or individually; (b) held by any Person or entity for the benefit of such Defendant 

or Relief Defendant; or ( c) under the direct or indirect control of such Defendant or Relief 

Defendant. Defendants and Relief Defendants shall attach to these completed financial 

statements copies of all local, state, provincial, and federal income and property tax returns, 

with attachments and schedules, as called for by the instructions to the financial statements; 

and 

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B. A completed IRS Form 4506, appended to this Order as Attachment D, requesting tax 

returns for the past five years (2011-2015). 

VIII. CONSUMER CREDIT REPORTS 

It is FURTHER ORDERED that Plaintiffs may obtain credit reports concerning any 

Defendant or Relief Defendant pursuant to Section 604(a)(l) of the 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 Plaintiffs. 

IX. FOREIGN ASSET REPATRIATION 

It is FURTHER ORDERED that within five (5) days following the service of this Order, 

each Defendant and Relief Defendant shall: 

A. Provide Plaintiffs and the Receiver with a full accounting, verified under oath and accurate 

as of the date of this Order, of all documents and assets located outside of the United States. 

of America that are held by or for any Defendant or Relief Defendant or are under any 

Defendant's or Relief Defendant's direct or indirect control, jointly, severally, or 

individually, including the names and addresses of any foreign or domestic financial 

institution or other entity holding the documents and assets, along with the account 

numbers and balances; 

B. Provide Plaintiffs and the Receiver access to all records of accounts or assets of any 

Defendant or Relief Defendant held by Persons located outside the United States by signing 

and delivering to Plaintiffs' counsel and the Receiver the Consent to Release of Financial 

Records attached to this Order as Attachment E; and 

C. Transfer to the United States and deliver to the Receiver all funds, documents, and assets 

located outside of the United States of America that are held by or for any Defendant or 

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Relief Defendant or are under any Defendant's or Relief Defendant's direct or indirect 

control, jointly, severally, or individually. 

X. NON-INTERFERENCE WITH REPATRIATION 

It is FURTHER ORDERED that Defendants, Relief Defendants, and their 

Representatives, whether acting directly or indirectly, are temporarily restrained and enjoined from 

taking any action, directly or indirectly, that may result in the encumbrance or dissipation of 

foreign assets, or in the hindrance of the repatriation required by Section IX of this Order, 

including: 

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 assets have been fully 

repatriated pursuant to Section IX of this Order; or 

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

of either the existence ofthis Order, or of the fact that repatriation is required pursuant to 

a court order, until such time that all Defendants' assets have been fully repatriated 

pursuant to Section IX of this Order. 

XI. PRESERVATION OF RECORDS 

It is FURTHER ORDERED that Defendants, Relief Defendants, and their 

Representatives, whether acting directly or indirectly, are temporarily restrained and enjoined 

from: 

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

or otherwise disposing of, in any manner, documents, including electronically stored 

materials, that relate to: (1) the business, business practices, assets, or business or personal 

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finances of any Defendant, Relief Defendant, or any entity directly or indirectly under the 

control of any Defendant or Relief Defendant; (2) any webpage or website operated, in 

whole or in part, on any Defendants' behalf; and (3) any electronic communication sent or 

received by Defendants or Relief Defendants; and 

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

completely reflect Defendants' and Relief Defendants' incomes, disbursements, 

transactions, and use of Defendants' and Relief Defendants' assets. 

XII. REPORT OF NEW BUSINESS ACTIVITY 

It is FURTHER ORDERED that Defendants and their Representatives, whether acting 

directly or indirectly, are temporarily restrained and enjoined from creating, operating, or 

exercising any control over any new business entity, whether newly formed or previously inactive, 

including any partnership, limited partnership, joint venture, sole proprietorship, or corporation, 

without first providing counsel for Plaintiffs with a written statement disclosing: (1) the name of 

the business entity; (2) the address and telephone number of the business entity; (3) the names of 

the business entity's officers, directors, principals, managers, members, and employees; and (4) a 

detailed description of the business entity's intended activities. 

XIII. PROHIBITION ON RELEASE OF CONSUMER INFORMATION 

It is FURTHER ORDERED that Defendants and their Representatives, whether acting 

directly or indirectly, are temporarily restrained and enjoined from directly or indirectly disclosing, 

using, or benefitting from customer information, including the name, address, telephone number, 

credit card number, bank account number, email address, or other identifying information, or any 

data that enables access to a customer's account (including a credit card, bank account, or other 

financial account), that any Defendant obtained prior to entry of this Order in connection with any 

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activity that pertains to Debt Relief Services; provided, however, that Defendants may disclose 

such identifying information to a law enforcement agency or as required by any law, regulation, 

or court order. 

XIV. APPOINTMENT OF TEMPORARY RECEIVER 

It is FURTHER ORDERED that MARK J. BERNET, Esq. is appointed Temporary 

Receiver for Corporate Defendants and any of their affiliates, subsidiaries, divisions, or telephone 

sales or customer service operations, wherever located, with the full power of an equity receiver, 

including full power over all funds, assets, accounts, collateral, premises (whether owner, leased, 

occupied, or otherwise controlled), choses in action, documents, and other property belonging to, 

being managed by, or in the possession of or control of Corporate Defendants. The Receiver shall 

be solely the agent of this Court in acting as Receiver under this Order and is immediately 

authorized, empowered, and directed to: 

A. Assume full control and manage and administer the business of Corporate Defendants by 

performing all incidental acts that the Receiver deems to be advisable or necessary, 

including removing, as the Receiver deems necessary or advisable, any director, officer, 

manager, member, independent contractor, employee, or agent of any Corporate 

Defendant, including any Individual Defendant, from control of, management of, or 

participation in, the affairs of Corporate Defendants; 

B. Take exclusive custody, control, and possession of all assets and documents of, or in the 

possession, custody, or under the control of, Corporate Defendants, wherever situated; 

C. Conserve, hold, manage, and prevent the loss of all assets of Corporate Defendants, 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 

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hereafter due or owing to Corporate Defendants. The Receiver shall have full power to sue 

for, collect and receive, take in possession, hold, and manage all ·assets of Corporate 

Defendants and other Persons whose interests are now under the direction, possession, 

custody, or control of Corporate Defendants. Provided, however, that the Receiver shall 

not attempt to collect any amount from a consumer ifthe Receiver believes the consumer's 

debt to Corporate Defendants has resulted from the deceptive acts or practices or other 

violations oflaw alleged in the Complaint in this matter, without prior Court approval; 

D. Obtain, conserve, hold, manage, and prevent the loss of all documents of Corporate 

Defendants, and perform all acts necessary or advisable to preserve such documents. The 

Receiver shall: divert mail; preserve all documents of Corporate Defendants that are 

accessible via electronic means (such as online access to financial accounts and remote 

access to electronic documents held by cloud service providers, email service providers 

and web hosts), by changing usemames, passwords or other log-in credentials for any 

online account titled in the name of a Corporate Defendant or which in the Receiver's 

judgment has been used in furtherance of any Corporate Defendant's business practices; 

take possession of all electronic documents of Corporate Defendants stored remotely; copy 

all such documents; and obtain the assistance of the FTC's litigation support staff for the 

purpose of obtaining electronic documents stored remotely; 

E. Choose, engage, and employ attorneys, accountants, appraisers, and other independent 

contractors and technical specialists, as the Receiver deems advisable or necessary in the 

performance of duties and responsibilities under the authority granted by this Order; 

F. 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 

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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 Corporate 

Defendants prior to the date of entry of this Order, except payments that the Receiver deems 

necessary or advisable to secure assets of Corporate Defendants, such as rental payments; 

G. Suspend business operations of Corporate Defendants if in the judgment of the Receiver 

such operations cannot be continued legally or profitably; 

H. Take all steps necessary to secure and take exclusive custody of each location from which 

Corporate Defendants operate their businesses. Such steps may include, but are not limited 

to, any of the 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, internet 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 

of the Receivership Defendants. Plaintiffs and Receiver are authorized to employ the 

assistance of law enforcement personnel to effect service, to implement peacefully the 

provisions of this order, and to keep the peace and maintain security; 

I. Take all steps necessary to ensure that any of Corporate Defendants' web pages or websites 

relating to Debt Relief Services 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 Corporate Defendants cannot be accessed by 

the public, or are answered solely to provide consumer education or information regarding 

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the status of operations; 

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 

of consumers and creditors who have transacted business with Corporate Defendants; 

L. Make an accounting, as soon as practicable, of the assets and financial condition of the 

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

parties; 

M. Institute, compromise, adjust, appear m, intervene in, . defend, adjust, 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 

assets of Corporate Defendants, or to carry out the Receiver's mandate under this Order, 

including 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 of the receivership estate; 

0. Open one or more bank accounts as designated depositories for funds of Corporate 

Defendants. The Receiver shall deposit all funds of Corporate Defendants in such a 

designated account and shall make all payments and disbursements from the receivership 

estate from such an account. The Receiver shall serve copies of monthly account statements 

on all parties; 

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

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

representatives and Defendants themselves, reasonable access to the premises of Corporate 

Defendants, or any other premises where Corporate Defendants conduct operations. The 

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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, Corporate Defendants or 

their agents. The Receiver shall have the discretion to determine the time, manner, and 

reasonable conditions of such access; 

R. Allow Plaintiffs' representatives, agents, and assistants, as well as Defendants and their 

representatives reasonable access to all documents in the possession, custody, or control of 

Corporate Defendants, including electronic documents; 

S. Cooperate with reasonable requests for information or assistance from any state or federal 

civil or criminal law enforcement agency; and 

T. File timely reports with the Court at reasonable intervals, or as otherwise directed by the 

Court. 

XV. TRANSFER OF RECEIVERSHIP PROPERTY TO RECEIVER 

It is FURTHER ORDERED that Defendants and their Representatives, and any other 

Person with possession, custody, or control of property of, or records relating to, Corporate 

Defendants shall, upon notice of this Order by personal service or otherwise, fully cooperate with 

and assist the Receiver in taking and maintaining possession, custody, or control of the assets and 

documents of Corporate Defendants and immediately transfer or deliver to the Receiver 

possession, custody, or control of, the following: 

A. All assets of Corporate Defendants; 

B. All documents of Corporate Defendants, including books and records of accounts, all 

financial and accounting records, balance sheets, income statements, bank records 

(including monthly statements, canceled checks, records of wire transfers, and check 

registers), client lists, title documents, electronic documents, and other papers; 

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C. All computers, electronic devices, mobile devices, and machines and data in whatever form 

used to conduct the business of Corporate Defendants; 

D. All assets and documents belonging to other Persons whose interests are under the 

direction, possession, custody, or control of Corporate Defendants; and 

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

assets or documents of Corporate Defendants, including access to their business premises, 

means of communication, accounts, computer systems, or other property. 

In the event that any Person fails to deliver or transfer any asset or document, or otherwise 

fails to comply with any provision of this Section, the Receiver may file an Affidavit of Noncompliance regarding the failure and a motion seeking compliance or a contempt citation. 

XVI. PROVISION OF INFORMATION TO RECEIVER 

It is FURTHER ORDERED that Defendants shall provide to the Receiver, immediately 

upon request, the following: 

A. A list of all assets and property, including accounts, of Corporate Defendants that are held 

in any name other than the name of a Corporate Defendant, or by any Person other than a 

Corporate Defendant; and 

B. A list of all agents, employees, officers, directors, managers, members, or those Persons in 

active concert and participation with Defendants, who have been associated or done 

business with Corporate Defendants. Such list should include every entity that provides 

leads to Corporate Defendants. 

XVII. COOPERATION WITH THE RECEIVER 

It is FURTHER ORDERED that Defendants, Relief Defendants, their Representatives, 

and any other Person served with a copy of this Order shall fully cooperate with and assist the 

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Receiver in taking and maintaining possession, custody, or control of the assets and documents of 

Corporate Defendants. This cooperation and assistance shall include, but not be limited to: (A) 

providing information to the Receiver that the Receiver deems necessary to exercise the authority 

and discharge the responsibilities of the Receiver under this Order; (B) providing any password 

required to access any computer, electronic file, or telephonic data in any medium; (C) advising 

all Persons who owe money to Corporate Defendants that all debts should be paid directly to the 

Receiver; and (D) transferring funds at the Receiver's direction and producing records related to 

the assets of Corporate Defendants. The entities obligated to cooperate with the Receiver under 

this provision include, but are not limited to, banks, broker-dealers, savings and loans, escrow 

agents, title companies, commodity trading companies, precious ·metals dealers, credit card 

processors, payment processors, merchant banks, acquiring banks, independent sales 

organizations, third party processors, payment gateways, insurance companies, and other financial 

institutions and depositories of any kind, as well as all common carriers, telecommunications 

companies, and third-party billing agents. 

XVIII. NON-INTERFERENCE WITH THE RECEIVER 

It is FURTHER ORDERED that Defendants, Relief Defendants, and their 

Representatives, whether acting directly or indirectly, and all other Persons are temporarily 

restrained and enjoined from: 

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

of, the assets or documents subject to this receivership; 

B. Transacting any of the business of Corporate Defendants; 

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 

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in which an interest is held or claimed by, Corporate Defendants; and 

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 of this Court. 

XIX. STAYS OF ACTIONS AGAINST CORPORATE DEFENDANTS 

It is FURTHER ORDERED that, except by leave of this Court, during pendency of the 

receivership ordered herein, Defendants, Relief Defendants, their Representatives, whether acting 

directly or indirectly, and all other Persons are temporarily restrained and enjoined from: 

A. Seeking to establish or enforce any claim, right, or interest against or on behalf of any 

Corporate Defendant; 

B. Commencing, prosecuting, continuing, enforcing, or defending any suit or proceeding 

against or in the name of Corporate Defendants, except that such actions may be 

commenced if necessary to toll any applicable statute of limitations; 

C. Accelerating the due date of any obligation or claimed obligation, filing or enforcing any 

lien upon, or taking or attempting to take possession, custody, or control of any asset of 

any of Corporate Defendants, or attempting to foreclose, forfeit, alter, or terminate any 

interest in any asset of Corporate Defendants, including the establishment, granting, or 

perfection of any security interest, whether such acts are part of a judicial proceeding or 

otherwise; 

D. Using self-help or executing or issuing, or causing the execution or issuance of any court 

attachment, subpoena, replevin, execution or other process for the purpose of impounding 

or taking possession of or interfering with, or creating or enforcing a lien upon any asset, 

of any of Corporate Defendants, the Receiver, or any agent appointed by the Receiver; and 

E. Doing any act to interfere with the Receiver taking control, possession, or management of 

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assets subject to this receivership, or to interfere in any way with the Receiver, or to harass 

or interfere with the duties of the Receiver; or to interfere in any manner with the exclusive 

jurisdiction of this Court over the assets of Corporate Defendants, including the filing by 

the Defendants of a petition for relief under the United States Bankruptcy Code, 11 U.S.C. 

§ 101 et seq., as to any Corporate Defendant. 

PROVIDED THAT, nothing in this Section shall prohibit any federal or state law 

enforcement or regulatory authority from commencing or prosecuting an action against Corporate 

Defendants. 

XX. COMPENSATION OF RECEIVER 

It is FURTHER ORDERED that the Receiver, and all Persons hired by the Receiver as 

authorized under this Order, including counsel to the Receiver and accountants, are entitled to 

reasonable compensation for the performance of duties 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, Corporate Defendants. 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 of entry of this Order. 

The Receiver shall not ihcrease the hourly rates used as the bases for such fee applications without 

prior approval of the Court. 

XXI. RECEIVER'S BOND 

It is FURTHER ORDERED that the Receiver shall file with the Clerk of this Court a 

bond 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. The amount of the bond shall be set at the hearing on preliminary injunction. 

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xxn. IMMEDIATE ACCESS TO BUSINESS OFFICES AND RECORDS 

It is FURTHER ORDERED that, in order to allow Plaintiffs and the Receiver to preserve 

assets and evidence relevant to this action and to expedite discovery: 

A. Defendants and their Representatives must immediately identify to Plaintiffs' counsel and 

the Receiver: (1) all of Corporate Defendants' business premises; (2) any other premises 

where Corporate Defendants conduct business related to Debt Relief Products or Services; 

(3) any premises where documents related to the business operations of Corporate 

Defendants are maintained, including the name and location of any electronic data hosts; 

and ( 4) any premises where assets belonging to Defendants are stored and maintained; 

B. Plaintiffs and the Receiver and their counsel, agents, representatives, contractors, and 

assistants shall have immediate access to all business premises and storage facilities of 

Corporate Defendants, including the offices located at 12001 Science Drive, Suites 125 

and 180, Orlando, Florida 32826; 

C. Plaintiffs and the Receiver may exclude Defendants, Relief Defendants, and their 

Representatives from Corporate Defendants' business premises and storage facilities 

during the immediate access; 

D. Plaintiffs and the Receiver and their counsel, agents, representatives, contractors,· and 

assistants are authorized to obtain the assistance of the U.S. Marshal's office and other 

federal, state, and local law enforcement officers as they deem necessary to effect service 

and to implement peacefully the provisions of this Order; 

E. Plaintiffs and the Receiver and their counsel, agents, representatives, contractors, and 

assistants are authorized to remove documents from Corporate Defendants' business 

premises and storage facilities in order that they may be inspected, inventoried, and copied 

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for the purpose of preserving discoverable material in connection with this action; 

F. Defendants and their Representatives shall provide Plaintiffs and the Receiver with any 

necessary means of access to documents including, without limitation, the locations of 

Corporate Defendants' business premises and storage facilities, keys and combinations to 

Corporate Defendants' business premises or storage facility locks, access codes of all 

electronic devices used to conduct Corporate Defendants' business, and storage area access 

information; 

G. If any property, records, documents, or computer files relating to Corporate Defendants' 

finances or business practices are located in the residence of any Defendant or Relief 

Defendant or are otherwise in the custody or control of any Defendant or Relief Defendant, 

then such Defendant or Relief Defendant shall produce them to Plaintiffs and the Receiver 

within twenty-four (24) hours of service of this Order, along with any codes or passwords 

needed for access. In order to prevent the destruction of electronic data, upon service of 

this Order upon Defendants or Relief Defendants, any computing device (including 

computers, tablets, and smart-phones) shall be powered down (turned off) in the normal 

course for the operating systems used on such computers and shall not be powered up or 

used again until produced for copying and inspection, along with any codes needed for 

access; 

H. In the event that any Corporate Defendant's documents have been removed from Corporate 

Defendants' business premises or storage facilities by, and are in the possession of any 

other law enforcement ot investigative agency, Plaintiffs may have immediate access to 

such documents for purposes of inspection, indexing, and copying, subject to the agency 

consenting to access by Plaintiffs; 

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I. Plaintiffs' or the Receiver's access to Corporate Defendants' documents pursuant to this 

Section shall not provide grounds for any Defendant or Relief Defendant to object to any 

subsequent request for documents served by Plaintiffs; and 

J. The Receiver shall allow Defendants reasonable access to the business premises and 

business records of Corporate Defendants within his possession for the purpose of 

inspecting and copying materials relevant to this action, although the Receiver shall have 

the discretion to determine the time, manner, and reasonable conditions of such access. 

XXIII. DISTRIBUTION OF ORDER BY DEFENDANTS 

It is FURTHER ORDERED that: 

A. Within five (5) days following service of this Order, Defendants shall provide a copy of 

this Order to each of their affiliates, Telemarketers, customer service agents, sale agents, 

distributors, subsidiaries, successors, assigns, officers, directors, members, managers, 

employees, independent contractors, client companies, agents, spouses, and attorneys, as 

well as to any other Person who participates in Defendants' marketing, advertising, 

promotion, distribution, offer for sale, or sale of Debt Relief Products or Services; 

B. Within seven (7) days following service of this Order, Defendants shall provide Plaintiffs 

and the Receiver with a sworn statement that Section XXIII (A) has been satisfied, which 

statement shall include the names, titles, physical addresses, phone numbers, and e-mail 

addresses of each such Person who received a copy of the Order and the date which such 

Person received it; and 

C. Defendants shall not take any action that would encourage officers, agents, members, 

managers, directors, employees, salespersons, independent contractors, attorneys, 

subsidiaries, affiliates, successors, assigns, or other Persons or entities in active concert or 

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participation with Defendants to disregard this Order or believe that they are not bound by 

its provisions. 

XXIV. EXPEDITED DISCOVERY 

It is FURTHER ORDERED that, notwithstanding the time periods, notice provisions, 

and other requirements of Federal Rules of Civil Procedure 26(d), 26(f), 30(a)(2)(A), and 

3 l(a)(2)(A), and pursuant to Federal Rules of Civil Procedure 30(a), 34, and 45, Plaintiffs and the 

Receiver are granted leave, at any time after entry of this Order, to conduct limited expedited 

discovery as to parties and non-parties for the purpose of discovering: (1) the nature, location, 

status, and extent of Defendants' and Relief Defendants' assets; (2) the nature and location of 

documents reflecting Defendants' businesses, business transactions, and operations; (3) the 

telecommunications providers that Defendants utilize to conduct the practices alleged in Plaintiffs' 

complaint; ( 4) Defendants' affiliates and subsidiaries; ( 5) the nature and location of any premises 

where Defendants, directly or through any third party, conduct business operations; (6) 

Defendants' whereabouts; (7) the applicability of any evidentiary privileges to this action; or (8) 

compliance with this Order. The limited expedited discovery set forth in this Section shall proceed 

as follows: 

A. Plaintiffs may, on three (3) days' notice, take the deposition of any Person, whether or not 

a party, in any judicial district. Depositions may be conducted telephonically, by 

videoconferencing, or in person. Deposition transcripts that have not been signed by the 

witness may be used at the preliminary injunction hearing in this matter. 

B. Plaintiffs may serve interrogatories upon Defendants and Relief Defendants, and 

Defendants and Relief Defendants shall respond within five (5) days after Plaintiffs serve 

such interrogatories. 

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C. Plaintiffs may, upon five (5) days' notice, including through the use of a Rule 45 subpoena, 

demand the production of documents from any Person, whether or not a party, provided 

that three (3) days' notice shall be deemed sufficient for the production of any such 

documents that are maintained or stored only in an electronic format. 

D. For purposes of discovery pursuant to this Section, service shall be sufficient if made by 

facsimile, by email, or by overnight courier. 

E. 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 of Civil Procedure and Local Rules 

of this Court. 

F. The expedited discovery permitted by this Section does not require a meeting or conference 

of the parties, pursuant to Federal Rules of Civil Procedure 26( d) and (f). 

G. The Parties are exempted from making initial disclosures under Federal Rule of Civil 

Procedure 26(a)(l) until further order of this Court. 

XXV. SERVICE OF THIS ORDER 

It is FURTHER ORDERED that copies of this Order may be served by U.S. First Class 

Mail, overnight delivery, facsimile, email, or personal service, by agents or employees of 

Plaintiffs, by agents or employees of the Receiver, by any law enforcement agency, or by private 

process server, upon any Person that may have possession, custody, or control of any property, 

property right, document, or asset of any Defendant or Relief Defendant, or that may be subject to 

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

this Section, service upon any branch, subsidiary, affiliate, or office of any financial institution or 

entity shall effect service upon the entire financial institution or entity. This Order shall bind 

Persons that may be subject to any provision of this Order pursuant to Federal Rule of Civil 

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Procedure 65( d)(2) upon such Person's receipt of actual notice, by personal service or otherwise, 

of this Order. 

XXVI. CORRESPONDENCE AND SERVICE ON PLAINTIFFS 

It is FURTHER ORDERED that, for the purpose of this Order, because mail addressed 

to the FTC is subject to delay due to heightened security screening, all correspondence and service 

of pleadings on the FTC shall be sent either via electronic transmission or via Federal Express to: 

Tejasvi M. Srimushnam (tsrimushnam@ftc.gov) 

Joshua A. Doan Gdoan@ftc.gov) 

Federal Trade Commission 

600 Pennsylvania A venue NW 

Mail Stop CC-8563 

Washington, DC 20580 

(202) 326-2959 (Srimushnam phone) 

(202) 326-3187 (Doan phone) 

(202) 326-3395 (fax) 

Any correspondence, papers, and pleadings related to this order must be served upon the 

State of Florida by overnight mail, electronic mail, courier delivery, or facsimile to: 

Jennifer Knutton Gennifer.knutton@myfloridalegal.com) 

Denise Beamer (denise.beamer@myfloridalegal.com) 

Office of the Attorney General 

Consumer Protection Division 

135 West Central Boulevard, Suite 670 

Orlando, Florida 32801 

Telephone: ( 407) 316-4840 

Fax: ( 407) 245-0365 

xxvn. PRELIMINARY INJUNCTION HEARING 

It is FURTHER ORDERED that, pursuant to Federal Rule of Civil Procedure 65(b), 

Defendants and Relief Defendants shall appear before this Court on the June 22, 2106, at 2p.m. in 

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Courtroom 5B at the United States Courthouse located at 401 West Central Boulevard, Orlando, 

Florida to show cause, if there is any, why this Court should not enter a preliminary injunction 

enjoining Defendants from further violations of the FTC Act, the TSR, and Section 501.204 of the 

FDUTPA as alleged in the Complaint, continuing the freeze of their assets and Relief Defendants' 

assets, continuing the receivership, and imposing such additional relief as may be appropriate 

pending final adjudication of the Complaint filed in this matter. 

XXVIII. BRIEFS AND AFFIDAVITS CONCERNING PRELIMINARY INJUNCTION 

It is FURTHER ORDERED that: 

A. Defendants and Relief Defendants shall file with the Court and serve on Plaintiffs' counsel 

any answering pleadings, affidavits, motions, expert reports, declarations, and/or legal 

memoranda no later than seven (7) days prior to the hearing on the Plaintiffs' request for a 

preliminary injunction. See Local Rule 4.06(b )(3). 

B. Plaintiffs may file responsive or supplemental pleadings, materials, affidavits, expert 

reports, declarations, and/or memoranda with the Court and serve the same on counsel for 

Defendants and Relief Defendants no later than one ( 1) day prior to the preliminary 

injunction hearing in this matter, 

C. The hearing shall be limited to argument of counsel unless the Court grants express leave 

to the contrary in advance of the hearing. See Local Rule 4.06(b). 

D. All affidavits, pleadings, motions, expert reports, declarations, legal memoranda and/or 

oppositions must be served by personal or overnight delivery, facsimile, or email. 

XXIX. DURATION OF ORDER 

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It is FURTHER ORDERED that this Temporary Restraining Order shall expire on June 

22, 2016, at 11:59 p.m. Eastern Time, unless within such time, the Order is extended for an 

additional period pursuant to Federal Rule of Civil Procedure 65(b )(2). 

XXX. RETENTION OF JURISDICTION 

It is FURTHER ORDERED that this Court shall retain jurisdiction of this matter for all 

purposes. 

DONE and ORDERED in Orlando, Florida on June 8, 2016, at 1 :02 p.m. 

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CARLOSE.MENDOZA 

UNITED STATES DISTRICT JUD E