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US CIS l f<ICT L~=~:R T 

D, s l F,: c ·1 c. F r~~ -~· :~~ 't L :~J1 ~1 

IN THE UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF MARYLAND] J.'.'.·'. - 8 P ?: l W 

SOUTHERN DIVISION 

i . 

~ 

In re SANCTUARY BELIZE LITIGATION No.: 18-cv-3309-PJM 

STIPULATED ORDER FOR PERMANENT INJUNCTION AND MONET ARY 

JUDGMENT AGAINST DEFENDANTS BRANDI GREENFIELD AND BG 

MARKETING, LLC 

Plaintiff the Federal Trade Commission ("Commission" or "FTC"), filed its Complaint 

for Permanent Injunction and Other Equitable Relief ("Complaint"), pursuant to Section 13(b) of 

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

Consumer Fraud and Abuse Prevention Act ("Telemarketing Act"), 15 U.S.C. §§ 6101 -6108. 

On January 11 , 2018, the Court granted the FTC's motion to amend, substituting the Amended 

Complaint for Permanent Injunction and Other Equitable Relief ("Amended Complaint") for the 

Complaint. Defendants Brandi Greenfield and BG Marketing, LLC ("BG Marketing") were 

served with the Amended Complaint and summons. The Commission and Defendants Brandi 

Greenfield and BG Marketing stipulate to the entry of this Stipulated Order for Permanent 

Injunction and Monetary Judgment Against Defendants Brandi Greenfield and BG Marketing, 

LLC ("Order") to resolve all matters in dispute between them in this action and the related FTC 

v. AmeriDebt Inc., No. 03-cv-3317 (D. Md.) ("AmeriDebt"). 

IT IS THEREFORE ORDERED: 

FINDINGS 

1. This Court has jurisdiction over this matter. 

2. The Amended Complaint charges that Defendants Brandi Greenfield and BG 

Marketing along with the other named Defendants, participated in deceptive acts or practices in 

violation of Section 5 of the FTC Act, 15 U.S.C. § 45, as well as violations of the Telemarketing 
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Sales Rule, 16 C.F .R. Part 310, in connection with the sale of lots in a development in Belize 

known variously as Sanctuary Bay, Sanctuary Belize, and The Reserve (for ease, "Sanctuary 

Belize"). 

3. Defendants Brandi Greenfield and BG Marketing neither admit nor deny any of 

the allegations in the Complaint, except as specifically stated in this Order. Only for purposes 

of this action, Defendants Brandi Greenfield and BG Marketing admit the facts necessary to 

establish jurisdiction. 

4. Defendants Brandi Greenfield and BG Marketing waive any claims they may 

have under the Equal Access to Justice Act, 28 U.S.C. § 2412, concerning the prosecution of this 

action through the date of this Order, and agree to bear their own costs and attorney fees. 

5. Defendants Brandi Greenfield and BG Marketing waive all rights to appeal or 

otherwise challenge or contest the validity of this Order. 

DEFINITIONS 

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

property, wherever located and by whomever held, whether tangible, intangible, digital, or 

otherwise, including, but not limited to, digital currencies, virtual currencies, digital tokens, and 

cryptocurrencies. 

B. "Corporate Defendant(s)" means Global Property Alliance, Inc., Sittee River 

Wildlife Reserve, Buy Belize, LLC, Buy International, Inc., Foundation Development 

Management, Inc., Eco-Futures Development, Eco-Futures Belize Limited, Power Haus 

Marketing, and Sanctuary Belize Property Owners' Association, Prodigy Management Group 

LLC, Foundation Partners, BG Marketing, LLC, Ecological Fox, LLC, Belize Real Estate 

Affiliates LLC, Exotic Investor LLC, Southern Belize Realty LLC, Newport Land Group LLC, 

and Atlantic International Bank Ltd. and each of their subsidiaries, affiliates, successors, and 

assigns. 

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

individually, collectively, or in any combination. 

D. "Individual Defendant(s)" means Andris Pukke, Peter Baker, Luke Chadwick, 

John Usher, Rod Kazazi, Brandi Greenfield, Frank Costanzo, and Michael Santos, individually, 

collectively, or in any combination. 

E. "Receiver" means the Receiver appointed in Section V of this Order and any 

deputy receivers who shall be named by the Receiver. 

F. "Receivership Asset" means any and all Assets ordered to be turned over to the 

Receiver pursuant to this Order. 

G. "Receivership Entities" means the Corporate Defendants (except Atlantic 

International Bank, Ltd.), 2729 Bristol LLC, and 3905 Marcus LLC, as well as any other entity 

that: (1) is located at, registered to, or operated from 3333 Michelson Drive, Suite 500, Irvine, 

California, and assists, facilitates, or otherwise conducts business related to the sale of real estate 

in Belize; (2) assists, facilitates, or otherwise conducts business related to the acts identified in 

the Findings of Fact in this Order, and is owned or controlled by any Defendant; or (3) Assets 

that are otherwise in the Receivership and that are corporations or other legal entities. 

H. "Relief Defendant(s)" means Angela Chittenden, Beach Bunny Holdings LLC, 

the Estate of John Pukke, John Vipulis, and Deborah Connelly. 

I. "Settling Defendant(s)" means Brandi Greenfield and BG Marketing, LLC 

individually, collectively, or in any combination, and any subsidiaries, affiliates, successors, and 

assigns. 

J. "Telemarketing" means any plan, program, or campaign which is conducted to 

induce the purchase of goods or services by use of one or more telephones, and which involves a 

telephone call, whether or not covered by the Telemarketing Sales Rule. 

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ORDER 

I. BAN ON TELEMARKETING 

IT IS ORDERED that Settling Defendants are permanently restrained and enjoined from 

Telemarketing, whether directly or through an intermediary, including by consulting, brokering, 

planning, investing, or advising. 

II. PROHIBITION AGAINST MISREPRESENTATIONS IN THE SALE OF ANY 

GOOD OR SERVICE 

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

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

them, who receive actual notice of this Order, whether acting directly or indirectly, in connection 

with advertising, marketing, promoting, or offering for sale any good or service, are permanently 

restrained and enjoined from misrepresenting, or assisting others in misrepresenting, expressly or 

by implication: 

A. The use of a "no debt" business model makes an investment less risky than one in 

which an entity or individual must make payments to creditors; 

B. Every dollar, or the vast majority of dollars, collected from selling the good or 

service is used to further the good or service; 

C. The good or service will be completed or available within a specified period of 

time, such as a particular number of weeks, months, or years; 

D. The good or service will have specific features or amenities; 

E. The good or service will appreciate in value or appreciate in value rapidly, such 

as a particular rate within a particular period of time; 

F. Consumers can realize the appreciation of their good or service because there is a 

robust resale market through which consumers could easily resell their good or service should 

they choose to do so; 

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G. One or more Defendants have no meaningful involvement with the relevant 

business; and 

H. 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. 

III. MONETARY JUDGMENT 

IT IS FURTHER ORDERED that: 

A. Judgment in the amount of one hundred forty four million dollars ($144,000,000) 

is entered in favor of the Commission against Settling Defendants, jointly and severally, as 

equitable monetary relief. 

B. Settling Defendants are ordered to pay to the Commission twenty-four-thousand, 

three-hundred and thirty-two dollars and three cents ($24,332.03). Such payment shall be 

satisfied by the following transfers: 

1. Within fifteen (15) days of receiving notice of this Order, Voya Financial, 

its parent corporation, subsidiaries, principals, and agents must transfer to 

the Commission by electronic fund transfer or certified bank or cashier's 

check, in accordance with instructions to be provided by a representative 

of the Commission, all funds in the name of, or for the benefit of Settling 

Defendants, in addition to all funds in Account No. XXX8334 

(approximate surrender value of $6,284.03); 

2. Settling Defendant Greenfield is ordered to pay to the Commission 

eighteen-thousand and forty-eight dollars ($18,048), which as Settling 

Defendant Greenfield stipulates, her undersigned counsel holds in escrow 

for no purpose other than payment to the Commission. Such payment 

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must be made within fourteen (14) days of entry of this Order by 

electronic funds transfer in accordance with instructions previously 

provided by a representative of the Commission. 

C. Settling Defendant Greenfield is also ordered to liquidate all stock identified in 

Item IO of Financial Statement of Individual Defendant Brandi Greenfield executed on 

November 16, 2018, within fourteen (14) days of entry of this Order. She shall give notice to 

the FTC of each liquidation within one (1) day of completing it. Settling Defendant Greenfield 

is ordered to pay to the Commission the proceeds of these liquidations, if any, within 

twenty-eight (28) days of entry of this Order by electronic funds transfer in accordance with 

instructions previously provided by a representative of the Commission. 

D. Settling Defendant Greenfield is also ordered to liquidate and turn over all funds, 

if any, in the follow~ng accounts at Bank of America N.A.: Account No. XXXXXXXX2778, 

Account No. XXXXXXXX5377, Account No. XXXXXXXX8545, and Account No. 

XXXXXXXX6693 , all held in the name of Brandi Greenfield. 

E. Settling Defendants shall also permanently transfer, assign, or relinquish to the 

Receiver all rights they may have in lot in any development previously owned or operated by 

any Corporate Defendant, including Settling Defendant Brandi Greenfield's interest in a WWV 

lot at Sanctuary Belize, identified in Item 18 of the Financial Statement of Individual Defendant 

Brandi Greenfield executed on November 16, 2018. 

F. Upon completion of all asset transfers, as specified in this Section, the remainder 

of the judgment against Settling Defendants is suspended, subject to the Subsections below. 

G. The Commission's agreement to the suspension of part of the judgment is 

expressly premised upon the truthfulness, accuracy, and completeness of Settling Defendants' 

representations, sworn financial statements and related documents (collectively, "financial 

representations") submitted to the Commission, namely: 

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I. the Financial Statement of Individual Defendant Brandi Greenfield executed on 

November 16, 2018, including the attachments; 

2. the Financial Statement of Corporate Defendant BG Marketing, LLC, executed on 

October 31, 2019, including the attachments; 

3. bank statements provided by Settling Defendant Brandi Greenfield in December 

2018. These records included bank statements for accounts in the names of: 

Cortez Properties LLC (Bank of America accounts ending in 7554, 2823, 2836, 

2849, and 9504); BG Marketing, LLC (Bank of America account ending in 5526); 

Brandi Greenfield (Bank of America accounts ending in 3358, 5377, 8545, 6693, 

and 2778); and Newport Land Group (Bank of America accounts ending in 0794, 

8924, and 0804); 

4. Cori Ferrentino's email to Amanda Kostner dated December 5, 2018, listing the 

personal property of Settling Brandi Greenfield; 

5. Cori Ferrentino's email to Benjamin Theisman dated October l 0, 2019, including 

its attachment; 

6. the representation that the 529 deferred income arrangement accounts (Account 

Nos. XXXXXX3825 and XXXXXX3858) identified in Item 14 of the Financial 

Statement of Individual Defendant Brandi Greenfield executed on November 16, 

2018 (the "529 Accounts") will be used solely for the qualified educational 

expenses of the children of Settling Defendant Brandi Greenfield. A "qualified 

educational expenses" of the children of Settling Defendant Brandi Greenfield 

includes any qualified educational expense according to the law of the state in 

which the account was held on November 7, 2018; 

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7. the representation that Settling Defendant Brandi Greenfield will provide to the 

Commission notice of the withdrawal of any amount from the 529 Accounts 

within 14 days of the withdrawal, as specified in Section XIII of this Order; 

8. the representation by Michael King on November 6, 2019 that the $18,048.00 

cash payment in Section B.2, which represents the equity in the 2013 Ford F-150 

identified in the Financial Statement of Individual Defendant Brandi Greenfield 

executed on November 16, 2018, are the proceeds of a loan from the mother of 

Brandon Showalter; and 

9. the representation by Michael King on November 7, 2019 that Settling Defendant 

Greenfield, pursuant to the Court's Order Authoriz ing Limited Access to Assets, 

DE 102, withdrew all of the funds from the bank accounts identified in Section D 

and also used $1 ,000 in cash that was frozen. 

H. The suspension of the judgment will be lifted asto either Settling Defendant if, 

upon motion by the Commission, the Court finds that a Settling Defendant failed to disclose any 

material asset, used the frozen assets in either 529 Account for anything other than the qualified 

educational expenses of one of Settling Defendant Brandi Greenfield's children, failed to 

disclose one or more withdrawals from the 529 Accounts as specified above in Section G.7.; 

materially misstated the value of any asset, or made any other material misstatement or omission 

in the financial representations identified above. 

I. If the suspension of the judgment is lifted, the judgment becomes immediately 

due as to that Defendant in the amount specified in Subsection A. above, which the parties 

stipulate only for purposes of this Section represents the consumer injury, less any payment 

previously made pursuant to this Section, plus interest computed from the date of entry of this 

Order. 

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IV. ADDITIONAL MONETARY PROVISIONS 

A. Settling Defendants relinquish dominion and all legal and equitable right, title, 

and interest in all assets paid, transferred, assigned, or relinquished pursuant to this Order and 

may not seek the return of any assets. 

B. The facts alleged in the Complaint will be taken as true, without further proof, in 

any subsequent civil litigation by or on behalf of the Commission, including in a proceeding to 

enforce its rights to any payment or monetary judgment pursuant to this Order, such as a 

nondischargeability complaint in any bankruptcy case. 

C. The facts alleged in the Complaint establish all elements necessary to sustain an 

action by the Commission pursuant to Section 523(a)(2)(A) of the Bankruptcy Code, 11 U.S.C. § 

523(a)(2)(A), and this Order will have collateral estoppel effect for such purposes. 

D. Settling Defendants acknowledges that their Taxpayer Identification Numbers 

(Social Security Numbers or Employer Identification Numbers), which Settling Defendants 

previously submitted to the Commission, may be used for collecting and reporting on any 

delinquent amount arising out of this Order, in accordance with 31 U.S.C. §7701. 

E. All money paid to the Commission pursuant to this Order may be deposited into a 

fund administered by the Commission or its designee to be used for equitable relief, including 

consumer redress and any attendant expenses for the administration of any redress fund. If a 

representative of the Commission decides that direct redress to consumers is wholly or partially 

impracticable or money remains after redress is completed, the Commission may apply any 

remaining money for such other equitable relief (including consumer information remedies) as it 

determines to be reasonably related to Defendants' practices alleged in the Complaint. Any 

money not used for such equitable relief is to be deposited to the U.S. Treasury as disgorgement. 

Defendants have no right to challenge any actions the Commission or its representatives may 

take pursuant to this Subsection. 

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F. The asset freeze imposed on Settling Defendants in the previously issued 

Stipulated Preliminary Injunction as to Defendants Rod Kazazi, Foundation Partners, Brandi 

Greenfield, BG Marketing LLC, Frank Costanzo, Deborah Connelly, Ecological Fox LLC, 

Michael Santos, Angela Chittenden, and Beach Bunny Holdings LLC (DE 195) is modified to 

permit the transfers identified in the Monetary Judgment Section. Upon the payments, transfers, 

assignations, and relinquishments required under this Order, the asset freeze is dissolved as to 

Brandi Greenfield and BG Marketing LLC. 

V. RECEIVER 

IT JS FURTHER ORDERED that Robb Evans & Associates LLC is appointed as 

Receiver for all assets ordered to be turned over to the Receiver pursuant to this Order. He shall 

have full powers of an equity receiver. The Receiver shall be solely the agent of this Court in 

acting as Receiver under this Order. 

VI. DUTIES AND AUTHORITY OF RECEIVER 

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

the following: 

A. 

B. 

Take exclusive control, custody, and possession of all Receivership Assets; 

Conserve, hold, manage, and prevent the loss of all Receivership Assets, 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 Settling Defendant as a result of the Receivership Assets. The Receiver 

shall have full power to sue for, collect, and receive, all Receivership Assets. Provided, 

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

Receiver believes the consumer's debt has resulted from deceptive acts or practices or other 

violations of law, without prior Court approval; 
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C. Liquidate, through fair market sales or similar transactions, all Receivership 

Assets, following a motion and order from the Court approving the sale or liquidation. The 

Receiver shall take steps to ensure that the full fair market value of any Asset is obtained by the 

receivership estate in any sale or liquidation; 

D. The Receiver shall make periodic disbursements to the Commission of any 

liquidated Assets and, upon the liquidation of all Receivership Assets, disburse all proceeds to 

the Commission, less its Court-approved fees and expenses; 

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 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, except payments that the Receiver 

deems necessary or advisable to secure Receivership Assets, such as rental payments; 

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

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

the interests of consumers who have transacted business with Settling Defendants and the 

Receivership Entities; 

I. Make an accounting, as soon as practicable, of the Receivership Assets and 

financial condition of the receivership and file the accounting with the Court and deliver copies 

thereof to all parties; 

J. 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 

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

Receivership Assets, or to carry out the Receiver's mandate under this Order, including but not 

limited to, actions challenging fraudulent or voidable transfers; 

K. Demand from any person or entity documents and records pertaining to the 

Receivership Assets within three (3) days after delivery of the Order by mail, courier, email, or 

other method by which the recipient receives a copy of this Order, in addition to obtaining 

discovery pursuant to the Federal Rules of Civil Procedure, including subpoenas seeking 

documents and/or testimony under Rule 45; 

L. Open one or more bank accounts at designated depositories for funds of the 

receivership estate. The Receiver shall deposit all funds of the receivership estate 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; 

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

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

federal civil or criminal law enforcement agency; 

0. Suspend business operations of any entity that is a Receivership Asset if in the 

judgment of the Receiver such operations cannot be continued legally and profitably; and 

P. If in the Receiver's judgment the business operations of any Receivership Asset 

cannot be continued legally and profitably, take all steps necessary to ensure that any of the web 

pages or websites relating to the activities of the Receivership Asset 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 Asset cannot 

be accessed by the public, or are answered solely to provide consumer education or information 

regarding the status of operations. 

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VII. ST A Y OF ACTIONS 

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

the receivership ordered herein, Defendants and Relief Defendants and their officers, agents, 

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

who receive actual notice of this 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 of such persons, are hereby enjoined from taking any action that 

would interfere with the exclusive jurisdiction of this Court over the Assets within the 

receivership, 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 of any Receivership 

Entity; 

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

or proceeding against any of the Receivership Assets or otherwise seeking an interest in any of 

the Receivership Assets, including the issuance or employment of process, except that such 

actions may be commenced if necessary to toll any applicable statute of limitations; 

C. Filing or enforcing any lien on any Receivership Asset, taking or attempting to 

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

forfeit, alter, or terminate any interest in any Receivership Asset, whether such acts are part of a 

judicial proceeding, are acts of self-help, or otherwise. 

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

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

action or proceeding by a governmental unit to enforce such governmental unit's police or 

regulatory power; or (3) the enforcement of a judgment, other than a money judgment, obtained 

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in an action or proceeding by a governmental unit to enforce such governmental unit's police or 

regulatory power. 

VIII. 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 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, the receivership estate. 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 increase the hourly rates used as the bases for such 

fee applications without prior approval of the Court. 

IX. RECEIVERSHIP TERMINATION 

IT JS FURTHER ORDERED that the Receiver must complete all duties within 270 days 

after entry of this Order, but any party or the Receiver may request that the Court extend that 

Receiver's term for good cause. 

X. CUSTOMER INFORMATION 

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

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

them, who receive actual notice of this Order, are permanently restrained and enjoined from 

directly or indirectly: 

A. Failing to provide sufficient customer information to enable the Commission to 

efficiently administer consumer redress. If a representative of the Commission requests in 

writing any information related to redress, Settling Defendants must provide it, in the form 

prescribed by the Commission, within I 4 days; 

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B. Disclosing, using, or benefitting from customer information, including the name, 

address, telephone number, email address, social security number, 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 Settling Defendants obtained prior to entry of this Order; and 

C. Failing to destroy such customer information in all forms in their possession, 

custody, or control within 30 days after receipt of written direction to do so from a representative 

of the Commission. 

Provided, however, that customer information need not be disposed of, and may be 

disclosed, to the extent requested by a government agency or required by law, regulation, or 

court order. 

XI. COOPERATION 

IT IS FURTHER ORDERED that Settling Defendants must fully cooperate with 

representatives of the Commission in this case and in any investigation related to or associated 

with the transactions or the occurrences that are the subject of the Complaint. Settling 

Defendants must provide truthful and complete information, evidence, and testimony. Settling 

Defendants must appear for interviews, discovery, hearings, trials, and any other proceedings 

that a Commission representative may reasonably request upon 5 days written notice, or other 

reasonable notice, at such places and times as a Commission representative may designate, 

without the service of a subpoena. 

XII. ORDER ACKNOWLEDGMENT 

IT IS FURTHER ORDERED that Settling Defendants obtain acknowledgments of 

receipt of this Order: 

A. Each Settling Defendant, within seven (7) days of entry of this Order, must 

submit to the Commission an acknowledgment of receipt of this Order sworn under penalty of 

perJury. 

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B. For twenty (20) years after entry of this Order, each Settling Defendant must, for 

itself and any business that such Defendant, individually or collectively with any other 

Defendants, is the majority owner or controls directly or indirectly, deliver a copy of this Order 

to: (1) all principals, officers, directors, and LLC managers and members; (2) all employees 

having managerial responsibilities for marketing, sales, or operations, and all agents and 

representatives who participate in marketing or sales; (3) all payment processors as well as all 

consultants or contractors who perform services in connection with marketing or sales; and (4) 

any business entity resulting from any change in structure as set forth in the Section titled 

Compliance Reporting. Delivery must occur within seven (7) days of entry of this Order for 

current personnel. For all others, delivery must occur before they assume their responsibilities. 

C. From each individual or entity to which each Settling Defendant delivered a copy 

of this Order, that Defendant must obtain, within 30 days, a signed and dated acknowledgment of 

receipt of this Order. 

XIII. COMPLIANCE REPORTING 

IT IS FURTHER ORDERED that Settling Defendants make timely submissions to the 

Commission: 

A. One year after entry of this Order, each Settling Defendant must submit a 

compliance report, sworn under penalty of perjury: 

1. Each Settling Defendant must: (a) identify the primary physical, postal, 

and email address and telephone number, as designated points of contact, 

which representatives of the Commission may use to communicate with 

Defendant; (b) identify all of that Defendant's businesses, whether owned 

or controlled, directly or indirectly, by all of their names, telephone 

numbers, and physical, postal, email, and Internet addresses; (c) describe 

the activities of each business, including the goods and services offered, 

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the means of advertising, marketing, and sales, and the involvement of any 

other Defendant (which Settling Defendants must describe in detail, 

including title, position, compensation, and duties); (d) describe in detail 

whether and how that Defendant is in compliance with each Section of 

this Order; and ( e) provide a copy of each Order Acknowledgment 

obtained pursuant to this Order, unless previously submitted to the 

Commission. 

2. Additionally, each Settling Defendant must: (a) identify all telephone 

numbers and all physical, postal, email and Internet addresses, including 

all residences; (b) identify all business activities, including any business 

for which such Defendant performs services whether as an employee or 

otherwise and any entity in which such Defendant has any ownership 

interest, whether directly or indirectly; and ( c) describe in detail such 

Defendant's involvement in each such business, including title, role, 

responsibilities, participation, authority, control, and any ownership. 

B. For twenty (20) years after entry of this Order, each Settling Defendant must 

submit a compliance notice, sworn under penalty of perjury, within fourteen (14) days of any 

change in the following: 

1. Each Settling Defendant must report any change in: (a) any designated 

point of contact; or (b) the structure of any entity that Defendant has any 

ownership interest in or controls directly or indirectly that may affect 

compliance obligations arising under this Order, including: creation, 

merger, sale, or dissolution of the entity or any subsidiary, parent, or 

affiliate that engages in any acts or practices subject to this Order. 

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2. Additionally, each Settling Defendant must report any change in: (a) 

name, including aliases or fictitious name, or residence address; or (b) title 

or role in any business activity, including any business for which such 

Defendant performs services whether as an employee or otherwise and 

any entity in which such Defendant has any ownership interest, and 

identify the name, physical address, and any Internet address of the 

business or entity. 

C. Each Settling Defendant must submit to the Commission notice of the filing of 

any bankruptcy petition, insolvency proceeding, or similar proceeding by or against such 

Defendant within 14 days of its filing. 

D. Settling Defendants must submit to the Commission notice of the withdrawal of 

any amount from the 529 Accounts within 14 days of the withdrawal. Upon written notice from 

a representative of the Commission, Settling Defendants must provide within 7 days all 

documentation supporting the specified withdrawal as a qualified educational expense. 

E. Any submission to the Commission required by this Order to be sworn under 

penalty of perjury must be true and accurate and comply with 28 U.S.C. § 1746, such as by 

concluding: "I declare under penalty of perjury under the laws of the United States of America 

that the foregoing is true and correct. Executed on: __ " and supplying the date, signatory's 

full name, title (if applicable), and signature. 

F. Unless otherwise directed by a Commission representative in writing, all 

submissions to the Commission pursuant to this Order must be emailed to DEbrief@ftc.gov or 

sent by overnight courier (not the U.S. Postal Service) to: Associate Director for Enforcement, 

Bureau of Consumer Protection, Federal Trade Commission, 600 Pennsylvania Avenue NW, 

Washington, DC 20580. The subject line must begin: FTC v. Ecological Fox LLC, 

18-cv-3309 (D. Md.), FTC File No. X040009. 

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XIV. RECORDKEEPING 

IT IS FURTHER ORDERED that each Settling Defendant must create certain records for 

twenty (20) years after entry of the Order, and retain each such record for 5 years. Specifically, 

for any business that each Settling Defendant, individually or collectively with any other 

Defendants, is a majority owner or controls directly or indirectly, must create and retain the 

following records: 

A. accounting records showing the revenues from all goods or services sold; 

B. personnel records showing, for each person providing services, whether as an 

employee or otherwise, that person's: name; addresses; telephone numbers; job title or position; 

dates of service; and (if applicable) the reason for termination; 

C. records of all consumer complaints and refund requests, whether received directly 

or indirectly, such as through a third party, and any response; 

D. all records necessary to demonstrate full compliance with each provision of this 

Order, including all submissions to the Commission; and 

E. a copy of each unique advertisement or other marketing material. 

XV. COMPLIANCE MONITORING 

IT IS FURTHER ORDERED that, for the purpose of monitoring each Settling 

Defendant's compliance with this Order, including any failure to transfer any assets as required 

by this Order or otherwise to collect on the judgment entered in this Order: 

A. Within fourteen (14) days of receipt ofa written request from a representative of 

the Commission each Settling Defendant must: submit additional compliance reports or other 

requested information, which must be sworn under penalty of perjury; appear for depositions; 

and produce documents for inspection and copying. The Commission is also authorized to 

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obtain discovery, without further leave of court, using any of the procedures prescribed by 

Federal Rules of Civil Procedure 29, 30 (including telephonic depositions), 31 , 33, 34, 36, 45 , 

and 69. 

B. For matters concerning this Order, the Commission is authorized to communicate 

directly with each Settling Defendant. Each Settling Defendant must permit representatives of 

the Commission to interview any employee or other person affiliated with any entity either 

Settling Defendant owns or controls, directly or indirectly, who has agreed to such an interview. 

The person interviewed may have counsel present. 

C. The Commission may use all other lawful means, including posing, through its 

representatives as consumers, suppliers, or other individuals or entities, to communicate with 

Settling Defendants or any individual or entity affiliated with Settling Defendant~, without the 

necessity of identification or prior notice. Nothing in this Order limits the Commission 's lawful 

use of compulsory process, pursuant to Sections 9 and 20 of the FTC Act, 15 U.S.C. §§ 49, 

57b-l. 

D. Upon written request from a representative of the Commission, any consumer 

reporting agency must furnish consumer reports concerning Settling Defendant Brandi 

Greenfield, pursuant to Section 604(1) of the Fair Credit Reporting Act, 15 U.S.C. §168lb(a)(l) 

XVI. RETENTION OF JURISDICTION 

IT IS FURTHER ORDERED that this Court retains jurisdiction of this matter for 

purposes of construction, modification, and enforcement of this Order. 

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SO ORDERED, this g- day of '.TA N 

SO STIPULATED AND AGREED: 

FOR THE FEDERAL TRADE COMMISSION: 

/13/ZOZG 

Jonathan Cohen (jcoben2@ftc.gov) Date 

Benjamin Theisman (bthcisman@ftc.gov) 

Christopher Ericbon ( cericbon@ftc.gov) 

Federal Trade Commission 

600 Pennsylvania Ave., N.W., CC-9S28 

Washington, DC 20580 

202-326-2551 (Cohen); -2223 (Theisman); 

-3671 (Erickson); -3197 (facsimile) 

FOR DEFENDANTS BRANDI GREENFIELD AND BG MARKETING, LLC: 

d 

an Officer of 

C 

, Inc. 

ers, Suite 5900 

2448 East 81 st Street 

Tulsa, OK 74137 

Counsel for Brar,di Greenfield and 

BG Marketing. UC 

Not adld.tted in Maryland 

21