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ALDEN F. ABBOTT 

General Counsel 

ELIZABETH NACH 

VA Bar No. 75235 

ANNETTE SOBERATS 

FL Bar No. 0093934 

Federal Trade Commission 

600 Pennsylvania Avenue, NW 

Mail Stop: CC-10528 

Washington, DC 20580 

Tel: (202) 326-2611, -2921 

Fax: (202) 326-3259 

enach@ftc.gov; asoberats@ftc.gov 

ATTORNEYS FOR FEDERAL TRADE COMMISSION 

UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF NEVADA 

FEDERAL TRADE COMMISSION, Case No. ____________ 2:20-cv-547

 Plaintiff, COMPLAINT FOR PERMANENT 

INJUNCTION AND OTHER 

 v. EQUITABLE RELIEF

HEALTH CENTER, INC., a corporation, and 

PEGGY PEARCE, individually and as an owner 

and officer of HEALTH CENTER, INC., 

 Defendants. 

Plaintiff, the Federal Trade Commission (“FTC”), for its Complaint alleges: 

1. The FTC brings this action under Sections 13(b) and 19 of the Federal Trade

Commission Act (“FTC Act”), 15 U.S.C. §§ 53(b), 57b, and the Telemarketing and Consumer 

Fraud and Abuse Prevention Act (“Telemarketing Act”), 15 U.S.C. §§ 6101-6108, to obtain 

Case 2:20-cv-00547 Document 1 Filed 03/19/20 Page 1 of 23
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permanent injunctive relief, rescission or reformation of contracts, restitution, the refund of 

monies paid, disgorgement of ill-gotten monies, and other equitable relief for Defendants’ acts or 

practices in violation of Sections 5(a) and 12 of the FTC Act, 15 U.S.C. §§ 45(a), 52, and the 

FTC’s Telemarketing Sales Rule (“TSR”), 16 C.F.R. Part 310, in connection with the 

advertising, marketing, promotion, offering for sale, or sale of Rejuvi-Cell, Rejuvi-Sea, and 

Rejuvi-Stem. 

JURISDICTION AND VENUE 

2. This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331, 1337(a),

and 1345. 

3. Venue is proper in this District under 28 U.S.C. § 1391(b)(1), (b)(2), (c)(1), and

(c)(2), and 15 U.S.C. § 53(b). 

PLAINTIFF 

4. The FTC is an independent agency of the United States Government created by

statute. 15 U.S.C. §§ 41-58. The FTC enforces Section 5(a) of the FTC Act, 15 U.S.C. 

§ 45(a), which prohibits unfair or deceptive acts or practices in or affecting commerce. The

FTC also enforces Section 12 of the FTC Act, 15 U.S.C. § 52, which prohibits false

advertisements for food, drugs, devices, services, or cosmetics in or affecting commerce, and the

TSR, which prohibits deceptive and abusive telemarketing acts or practices.

5. The FTC is authorized to initiate federal district court proceedings, by its own

attorneys, to enjoin violations of the FTC Act and the TSR, and to secure such equitable relief as 

may be appropriate in each case, including rescission or reformation of contracts, restitution, the 

refund of monies paid, and the disgorgement of ill-gotten monies. 15 U.S.C. §§ 53(b), 57b, 15 

U.S.C. §§ 6102(c) and 6105(b). 

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DEFENDANTS 

6. Defendant Health Center, Inc. (“HCI”) is a Nevada corporation with its principal 

place of business at 2310 Paseo del Prado, Suite A-205, Las Vegas, Nevada 89102. HCI 

transacts or has transacted business in this District and throughout the United States. At all 

times material to this Complaint, acting alone or in concert with others, HCI has advertised, 

marketed, distributed, or sold Rejuvi-Cell, Rejuvi-Sea, and Rejuvi-Stem to consumers 

throughout the United States. 

7. Defendant Peggy Pearce is the owner, president, secretary, treasurer, and director 

of HCI. At all times material to this Complaint, acting alone or in concert with others, she has 

formulated, directed, controlled, had the authority to control, or participated in the acts and 

practices of HCI, including the acts and practices set forth in this Complaint. Defendant Pearce 

has had final approval over all aspects of the business, including advertising and billing, and has 

been heavily involved in HCI’s day-to-day operations. Defendant Pearce has drafted 

telemarketing scripts, product packaging information, and product labels for HCI’s products. 

Defendant Pearce is also the co-inventor of the Rejuvi-Stem formula. Defendant Pearce resides 

in this District and, in connection with the matters alleged herein, transacts or has transacted 

business in this District and throughout the United States. 

COMMERCE

8. At all times material to this Complaint, Defendants have maintained a substantial 

course of trade in or affecting commerce, as “commerce” is defined in Section 4 of the FTC Act, 

15 U.S.C. § 44. 

THE TELEMARKETING SALES RULE

9. In 1994, Congress directed the FTC to prescribe rules prohibiting abusive and 

deceptive telemarketing acts or practices pursuant to the Telemarketing Act, 15 U.S.C. §§ 

Case 2:20-cv-00547 Document 1 Filed 03/19/20 Page 3 of 23
6101-6108. The FTC adopted the original TSR in 1995, extensively amended it in 2003, and 

amended certain provisions thereafter. 16 C.F.R. Part 310. 

10. Under the TSR, a “telemarketer” means any person who, in connection with 

telemarketing, initiates or receives telephone calls to or from a customer. 16 C.F.R. § 310.2(ff). 

A “seller” means any person who, in connection with a telemarketing transaction, provides, 

offers to provide, or arranges for others to provide goods or services to the customer in exchange 

for consideration. Id. § 310.2(dd). 

11. The TSR prohibits sellers and telemarketers from misrepresenting, directly or by 

implication, in the sale of goods or services, any material aspect of the performance, efficacy, 

nature, or central characteristics of the goods or services that are the subject of a sales offer. 16 

C.F.R. § 310.3(a)(2)(iii). It also prohibits sellers and telemarketers from making a false or 

misleading statement to induce any person to pay for goods or services. 16 C.F.R. § 

310.3(a)(4). 

12. Pursuant to Section 3(c) of the Telemarketing Act, 15 U.S.C. § 6102(c), and 

Section 18(d)(3) of the FTC Act, 15 U.S.C. § 57a(d)(3), a violation of the TSR constitutes an 

unfair or deceptive act or practice in or affecting commerce, in violation of Section 5(a) of the 

FTC Act, 15 U.S.C. § 45(a). 

DEFENDANTS’ BUSINESS ACTIVITIES

13. Since at least January 1, 2015, Defendants have advertised, labeled, offered for 

sale, sold, or distributed health products, including, but not limited to, Rejuvi-Cell, Rejuvi-Sea, 

and Rejuvi-Stem to consumers throughout the United States through telemarketing sales calls, 

social media pages, and the following internet websites: rejuvi-cell.com, healthcenterinc.net, 

rejuvi-stem.com, and buyhci.com. Defendants have targeted the elderly in their advertising. 

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14. Rejuvi-Cell is a sublingual spray that purportedly contains homeopathic-level 

dilutions of the following active ingredients: somatotrophin, colostrum with IGF, pineal gland, 

pituitary gland, thyroid, kidney, adipose tissue, pancreas, adrenal gland, parathyroid, and 

hypothalamus. A product information sheet included with each Rejuvi-Cell shipment has 

directed consumers to apply fifteen sprays per day during the first week, twelve sprays per day 

during the second week, and nine sprays per day thereafter. 

15. Rejuvi-Sea, which is sold in sixty-caplet bottles, purportedly contains marine 

phytoplankton with spirulina blue-green algae. Defendants have advised consumers to take two 

caplets daily. 

16. Rejuvi-Stem is purportedly a “stem cell recruiter” tablet that enhances, releases, 

and recruits adult stem cells so that they can migrate to the parts of the body where they are 

needed the most. According to the product label, it contains Vitamin D-3 and “Plurinol,” a 

proprietary blend of beta-glucan, astragalus extract, resveratrol, pomegranate peel, green tea, goji 

berry, aphanizomenon flos-aquae, probiotics, beet juice, and liposomes. It has been sold in 

sixty-tablet bottles, and each serving size is two tablets. 

17. Defendants have sold each product in three- or twelve-bottle packs priced at 

$349.95 plus shipping and $799 plus shipping, respectively. Sales of the three products in the 

United States from January 2015 through July 2019, minus refunds, totaled approximately $8.28 

million. 

18. Defendants have represented, among other things, through express and implied 

claims and consumer testimonials, that their products treat, mitigate, or cure a myriad of diseases 

and health conditions. 

19. To induce consumers to purchase Rejuvi-Cell, Rejuvi-Sea, and Rejuvi-Stem, 

Defendants have disseminated or caused to be disseminated advertisements via internet websites, 

social media pages, and product packaging, including but not limited to, the attached Exhibits A 

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through J. Defendants have often contacted consumers initially through unsolicited 

telemarketing calls made by their employees or contractors, and thus are “telemarketers” and 

“sellers” engaged in “telemarketing” as defined by the TSR, 16 C.F.R. § 310.2(dd), (ff), and 

(gg). Defendants have placed the calls to consumers and have instructed their employees and 

contractors to follow word-for-word the telemarketing scripts attached as Exhibits C, G, and J. 

Defendants’ advertisements have contained the following statements and depictions, among 

others: 

A. Excerpt from the Rejuvi-Cell Website, www.rejuvi-cell.com (captured 

March 7, 2019): 

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B. Excerpt from the Rejuvi-Cell Website, www.rejuvi-cell.com (captured 

 April 18, 2018) 

C. Excerpts from the Rejuvi-Cell Telemarketing Script 

* * * 

[H]ave you had Cancer in the last five years? (If yes, sell Phytoplanton 

[sic]) Are you an insulin dependent Diabetic (type 1) or a Diabetic who 

uses INJECTIONS and PILLS? (type 2) (If customer is on insulin switch 

to Phytolankton [sic]. If customer is a Type 2 Diabetic using PILLS 

ONLY.... continue).... It’s a proven fact (customer’s name) that the lack 

of hGH in our bodies is responsible not only for the aging process, but 

also for a wide range of health challenges.... Our goal is to get your hGH 

levels back up like they were when you were a young adult. Now that 

sounds like a plan, doesn’t it (smile customer can see your tone) 

(customer’s name) until recently the only way to get HUMAN GROWTH 

HORMONE was by a prescription from the Doctor. The problem was 

that most people could not afford the $1,000.00 per month for the 

injections. What we have developed is a specially formulated 

Homeopathic Human Growth Hormone Oral Spray. You spray it under 

your tongue 3 times daily.... (customer’s name), you should feel results in 

just a few weeks, you cannot ask for much more than that, can you? 

Doctors have proven hGH comes with many of [sic] Health and Cosmetic 

benefits. hGH helps to smoothen [sic] and rehydrate skin, starts to 

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eliminate cellulite (women) and can return hair back to its natural color if 

your hair is salt and pepper. It Increases [sic] muscle mass in men and 

sexuality in both men and women. 

The New England Journal of Medicine called it the MOST Effective anti 

obesity agent ever discovered and they also said it’s the best immune 

system enhancer ever found. Hgh WILL INCREASE YOUR 

STRENGTH by 91 % and your ENERGY by 63%! We could all use a 

little more energy, couldn’t we? Doctors across the country are still using 

hGH today to treat a wide range of health disorders. Actually hGH has 

proven to be beneficial for people with fibromyalgia, hypertension (high 

blood pressure), high cholesterol, arthritis, emphysema, asthma and 

muscular dystrophy. Do you have any of those? In fact (customer’s 

name), hGH is the only thing that had positive results so far on 

Alzheimer’s Disease. Here is why it helps with so many things 

(customer’s name), hGH rebuilds, rejuvenates, and re-nourishes the tissues 

in the lungs, heart, liver and kidneys. We can never be too heatlhy [sic] 

in any of those areas, can we? 

D. Excerpt from the Rejuvi-Sea Website, www.healthcenterinc.net 

 (captured March 7, 2019): 

* * * 

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E. Excerpt from the Rejuvi-Sea Website, www.healthcenterinc.net 

 (captured April 18, 2018) 

F. Excerpts from the Rejuvi-Sea Product Information Sheet inside 

 Packaging: 

 

 * * *

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G. Excerpts from the Rejuvi-Sea Telemarketing Script 

Hi my name is __________, with Health Center Inc. Is this ___________? 

We are looking for people that are interested in improving their health, 

maybe someone with high blood pressure, diabetes, cancer, OR breathing 

problems and most importantly pain. Or those who may just need a little 

more energy or that want to lose a few pounds ....... does that describe 

you? 

Well, ___________ , have you ever heard of Marine Phytoplankton? 

.... Marine phytoplankton has changed the entire face of nutrition and

nutritional healing. This is unprecedented, extreme nutrition---- 750 time 

the calcium as in milk and better calcium than milk-------650 times the 

magnesium as in spinach-----180 times the 86 as in tuna ..... it alkalizes 

your body to keep you from getting sick or so you can’t grow cancer cells 

..... it oxygenates your deep tissues .... helps your strength and energy, 

your memory and your mood and libido ... even the aging process! 

That’s just the tip of the iceberg ... that’s not even talking about the 

diseases that good nutrition can alleviate ....... from depression to 

diabetes, to obesity or cancer, bone disease, Arthritis etc. People all 

over the world are talking about these things and how Marine 

phytoplankton has had profound positive effects on their diseases and their 

lives. You can use this and change your life and increase the quality of 

life ..... at any juncture! Nutrition like this is a good bet! Do you agree? 

H. Excerpts from the Rejuvi-Stem Website, www.rejuvi-stem.com 

 (captured March 7, 2019): 

* * * 

* * * 

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* * * 

 

* * * 

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I. Excerpts from the Rejuvi-Stem Product Information Sheet inside 

 Packaging: 

* * * 

J. Excerpts from the Rejuvi-Stem Telemarketing Script 

Hello, ____________, my name is ________________; I’m calling from 

the Health Center Inc in Southern Nevada. How ARE you today? Great! 

The reason for my call is to share some information with you about Adult 

Stem Cell Enhancement.... We are looking for three types of people 

who benefit the most from stem cell enhancers. 

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The first person we are looking for: A person who is concerned about 

aging (perhaps premature aging), the second, is a person suffering medical 

conditions (like pulmonary disease, heart disease, bone disease, arthritis, 

diabetes), or the last one is a person who experiences pain [on a] daily 

basis. Would any of that apply to you? (listen with empathy) I am sorry to 

hear that you have had to go thru that and I am glad that I called because 

our company has released a product that could help you, for a long time, if 

not forever. Have you ever heard of regenerative medicine? (listen) 

Well you’ve heard of stem cells right? Now there is something even 

better than that and it is you own stem cells, adult stem cells. 

To put it simply, stem cells are always in our body from conception until 

death. We can use the stem cells that we have in our body to slow down 

aging, reverse diseases and it is a proven fact that they work for pain as 

well. Did you know that? The problem is, stem cell replacement 

therapy and even adult stem cell therapy clinics charge $8000.00 every 

three months for this therapy. What we have developed is a special blend 

of natural ingredients that enhance, replenish, and release your very own 

stem cells. You know that adult stem cell therapy is called regenerative 

therapy for a reason. With good stem cells you can regenerate tissues in 

your body, whether it is lung tissue, heart tissue, stomach tissue, skin, 

brain, joints, bones, any tissue [sic] Nothing does that like Rejuvi-Stem 

formula. It is called “The magnificent little pill” because when you take 

two of these a day your stem cells improve and your body renews itself. 

This can help you, make you better. It has no side effects, it doesn’t 

interfere with any medications, and no allergies have ever been reported. 

The secret is, in the blend of the ingredients. The first thing people notice 

is their skin. It thickens thin skin, reduces the appearance of wrinkles and 

improves elasticity. There is less pain throughout the body, and the 

longer you use it the more effective it becomes. This is why it is called 

[a] modern miracle!

20. Defendants have not conducted any studies demonstrating that their products

cure, treat, or mitigate diseases or health conditions, improve memory, cause fat loss, or cause 

wrinkles to disappear. There are no human clinical studies in the scientific literature showing 

that these products or their ingredients cure, treat, or mitigate diseases or health conditions, 

improve memory, cause fat loss, or cause wrinkles to disappear. 

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21. In their advertising, Defendants have used testimonials from their employees that 

purported to be from ordinary consumers in various locations throughout the United States. 

These testimonials include: 

-- Exhibit B, excerpt from the Rejuvi-Cell Website, 

www.rejuvi-cell.com (captured April 18, 2018) 

* * * 

-- Exhibit E, excerpt from the Rejuvi-Sea Website, 

www.healthcenterinc.net (captured April 18, 2018) 

* * * 

* * * 

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-- Exhibit H, excerpts from the Rejuvi-Stem Website, 

www.rejuvi-stem.com (captured March 7, 2019) 

22. Defendants engaged in their unlawful acts and practices repeatedly and unabated 

over a period of at least four years and continued their unlawful conduct despite having 

knowledge of numerous complaints. Defendants’ unlawful acts and practices were the subject 

of a September 2016 law enforcement action by the Iowa Attorney General, yet Defendants 

continued to engage in such practices until August 31, 2019, more than a year after being 

notified of the FTC’s investigation. Based on the facts and violations of law alleged in this 

Complaint, the FTC has reason to believe that Defendants are violating or are about to violate 

laws enforced by the Commission. 

VIOLATIONS OF THE FTC ACT

23. Section 5(a) of the FTC Act, 15 U.S.C. § 45(a), prohibits “unfair or deceptive acts 

or practices in or affecting commerce.”

24. Misrepresentations or deceptive omissions of material fact constitute deceptive 

acts or practices prohibited by Section 5(a) of the FTC Act.

25. Section 12 of the FTC Act, 15 U.S.C. § 52, prohibits the dissemination of any 

false advertisement in or affecting commerce for the purpose of inducing, or which is likely to 

induce, the purchase of food, drugs, devices, services, or cosmetics. For the purposes of Section 

12 of the FTC Act, 15 U.S.C. § 52, Rejuvi-Cell, Rejuvi-Sea, and Rejuvi-Stem are either “foods” 

or “drugs” as defined in Section 15(b) and (c) of the FTC Act, 15 U.S.C. §§ 55(b), (c).

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COUNT ONE

False or Unsubstantiated Efficacy Claims

26. In numerous instances in connection with the advertising, marketing, promotion, 

offering for sale, or sale of Rejuvi-Cell, Rejuvi-Sea, and Rejuvi-Stem, including through the 

means described in Paragraph 19, Defendants have represented, directly or indirectly, expressly 

or by implication, that:

A. Rejuvi-Cell improves memory by 62%, causes weight and fat loss, 

including fat loss of 72%, and causes wrinkles to disappear by 51%;

B. Rejuvi-Cell treats, mitigates, or cures multiple diseases and health 

conditions, including cancer, diabetes, Alzheimer’s disease, fibromyalgia, arthritis, emphysema, 

asthma, muscular dystrophy, erectile dysfunction, obesity, high blood pressure, and high 

cholesterol;

C. Rejuvi-Sea treats, mitigates, or cures multiple diseases and health 

conditions, including cancer, diabetes, dementia, Alzheimer’s disease, Parkinson’s disease, 

kidney disorders, autoimmune disorders, heart attacks, heart disease, atherosclerosis, strokes, 

liver disease, hepatitis, thyroid disorders, asthma, respiratory disorders, arthritis, rheumatoid 

arthritis, osteoporosis, joint pain, depression, chronic fatigue syndrome, obesity, high blood 

pressure, and high cholesterol; and

D. Rejuvi-Stem treats, mitigates, or cures multiple diseases and health 

conditions, including pulmonary disease, heart disease, diabetes, memory loss, bone disease, 

arthritis, pain, and high blood pressure.

27. The representations set forth in Paragraph 26 are false or misleading or were not 

substantiated at the time the representations were made.

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28. Therefore, the making of the representations as set forth in Paragraph 26 of this 

Complaint constitutes a deceptive act or practice and the making of false advertisements in 

violation of Sections 5(a) and 12 of the FTC Act, 15 U.S.C. §§ 45(a), 52.

COUNT TWO 

False Claims about Tests and Ingredient 

29. In numerous instances in connection with the advertising, marketing, promotion, 

offering for sale, or sale of Rejuvi-Cell and Rejuvi-Sea, including through the means described in 

Paragraph 19 of this Complaint, Defendants have represented, directly or indirectly, expressly or 

by implication, that: 

A. Clinical studies show that Rejuvi-Cell improves memory by 62%, causes 

weight loss and fat loss, including fat loss of 72%, and causes wrinkles to disappear by 51%;

B. Clinical studies show that Rejuvi-Cell treats, mitigates, or cures 

Alzheimer’s disease, fibromyalgia, arthritis, emphysema, asthma, muscular dystrophy, erectile 

dysfunction, obesity, high blood pressure, and high cholesterol; 

C. Rejuvi-Cell contains human somatotrophin, also known as human growth 

hormone (HGH); and 

D. Research shows that Rejuvi-Sea treats, mitigates, or cures multiple 

diseases and health conditions, including cancer, diabetes, dementia, Alzheimer’s disease, 

Parkinson’s disease, kidney disorders, autoimmune disorders, heart disease, atherosclerosis, liver 

disease, hepatitis, thyroid disorders, asthma, respiratory disorders, rheumatoid arthritis, 

osteoporosis, joint pain depression, and chronic fatigue syndrome. 

30. In truth and in fact:

 A. Clinical studies do not show that Rejuvi-Cell improves memory by 62%, 

causes weight and fat loss, including fat loss of 72%, or causes wrinkles to disappear by 51%; 

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B. Clinical studies do not show that Rejuvi-Cell treats, mitigates, or cures

Alzheimer’s disease, fibromyalgia, arthritis, emphysema, asthma, muscular dystrophy, erectile 

dysfunction, obesity, high blood pressure, or high cholesterol; 

C. Rejuvi-Cell does not contain human somatotrophin, also known as human

growth hormone (HGH), but rather contains porcine (pig) somatotrophin; and 

D. Research does not show that Rejuvi-Sea treats, mitigates, or cures multiple

diseases and health conditions, including cancer, diabetes, dementia, Alzheimer’s disease, 

Parkinson’s disease, kidney disorders, autoimmune disorders, heart disease, atherosclerosis, liver 

disease, hepatitis, thyroid disorders, asthma, respiratory disorders, rheumatoid arthritis, 

osteoporosis, joint pain, depression, and chronic fatigue syndrome. 

31. Therefore, the making of the representations as set forth in Paragraph 29, above,

constitutes a deceptive act or practice and the making of false advertisements in violation of 

Sections 5(a) and 12 of the FTC Act, 15 U.S.C. §§ 45(a), 52. 

COUNT THREE

False or Misleading Claims That Consumer Testimonials Reflect Independent Opinions

32. In numerous instances in connection with the advertising, marketing, promotion,

offering for sale, or sale of Rejuvi-Cell, Rejuvi-Sea, and Rejuvi-Stem, including through the 

means described in Paragraphs 19 and 21, Defendants have represented, directly or indirectly, 

expressly or by implication, that consumer testimonials appearing in their advertising, including 

from individuals identified by the initials D.L.E. or D.E., D.C., and P.H., reflect the independent 

experiences or opinions of ordinary purchasers. 

33. In truth and in fact, in numerous instances, consumer testimonials appearing in

Defendants’ advertising do not reflect the independent experiences or opinions of ordinary 

purchasers because the testimonials from D.L.E. or D.E., D.C., and P.H. were by, respectively, 

Case 2:20-cv-00547 Document 1 Filed 03/19/20 Page 19 of 23
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Dorinda Lee Estrada, Daniel Cahill, and Patricia Henderson, who were employees of Defendant 

HCI when the testimonials were created and disseminated. 

34. Therefore, the making of the representation as set forth in Paragraph 32 

constitutes a deceptive act or practice and the making of false advertisements in violation of 

Sections 5(a) and 12 of the FTC Act, 15 U.S.C. §§ 45(a), 52. 

VIOLATIONS OF THE TELEMARKETING SALES RULE 

COUNT FOUR 

Misrepresentations of Material Aspects of the Performance, Efficacy, 

Nature, or Central Characteristics of the Goods in Violation of the TSR 

35. In numerous instances, in connection with the telemarketing of goods and 

services, Defendants have misrepresented, directly or by implication, material aspects of the 

performance, efficacy, nature, or central characteristics of such goods and services, including, 

but not limited to: 

A. Rejuvi-Cell treats, mitigates, or cures multiple diseases and health 

conditions, including cancer, diabetes, Alzheimer’s disease, fibromyalgia, arthritis, emphysema, 

asthma, muscular dystrophy, obesity, high blood pressure, and high cholesterol;

B. Rejuvi-Cell contains human somatotrophin, also known as human growth 

hormone (HGH);

C. Rejuvi-Sea treats, mitigates, or cures multiple diseases and health 

conditions, including cancer, diabetes, arthritis, bone disease, pain, depression, obesity, and high 

blood pressure; and

D. Rejuvi-Stem treats, mitigates, or cures multiple diseases and health 

conditions, including pulmonary disease, heart disease, diabetes, bone disease, arthritis, and pain.

36. Defendants’ acts and practices, as described in Paragraph 35 above, are deceptive 

telemarketing acts or practices that violate the TSR, 16 C.F.R. § 310.3(a)(2)(iii), (a)(4). 

Case 2:20-cv-00547 Document 1 Filed 03/19/20 Page 20 of 23
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CONSUMER INJURY

37. Consumers are suffering, have suffered, and will continue to suffer substantial 

injury as a result of Defendants’ violations of the FTC Act and the TSR. In addition, 

Defendants have been unjustly enriched as a result of their unlawful acts or practices. Absent 

injunctive relief by this Court, Defendants are likely to continue to injure consumers, reap unjust 

enrichment, and harm the public interest. 

THIS COURT’S POWER TO GRANT RELIEF

38. Section 13(b) of the FTC Act, 15 U.S.C. § 53(b), empowers this Court to grant 

injunctive and such other relief as the Court may deem appropriate to halt and redress violations 

of any provision of law enforced by the FTC, including the Telemarketing Act and the TSR. 

The Court, in the exercise of its equitable jurisdiction, may award ancillary relief, including 

rescission or reformation of contracts, restitution, the refund of monies paid, and the 

disgorgement of ill-gotten monies, to prevent and remedy any violation of any provision of law 

enforced by the FTC. Section 19 of the FTC Act, 15 U.S.C. § 57b, and Section 6(b) of the 

Telemarketing Act, 15 U.S.C. § 6105(b), authorizes this Court to grant such relief as the Court 

finds necessary to redress injury to consumers resulting from Defendants’ violations of the FTC 

Act and the TSR, including rescission or reformation of contracts, and the refund of money. 

PRAYER FOR RELIEF

 Wherefore, Plaintiff FTC, pursuant to Sections 13(b) and 19 of the FTC Act, 15 U.S.C. 

§§ 53(b) and 57b, Section 6(b) of the Telemarketing Act, 15 U.S.C. § 6105(b), and the Court’s 

own equitable powers, requests that the Court: 

 A. Enter a permanent injunction to prevent future violations of the FTC Act and the 

TSR by Defendants; 

 B. Award such relief as the Court finds necessary to redress injury to consumers 

resulting from Defendants’ violations of the FTC Act and the TSR, including rescission or 

Case 2:20-cv-00547 Document 1 Filed 03/19/20 Page 21 of 23
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reformation of contracts, restitution, the refund of monies paid, and the disgorgement of 

ill-gotten monies; and 

C. Award Plaintiff the costs of bringing this action, as well as such other and

additional relief as the Court may determine to be just and proper. 

Respectfully submitted, 

ALDEN F. ABBOTT 

General Counsel 

Dated: ____________________ 

ELIZABETH NACH 

ANNETTE SOBERATS 

Tel: (202) 326-2611, -2921 

E-mail: enach@ftc.gov; asoberats@ftc.gov

Federal Trade Commission

600 Pennsylvania Ave., NW, Mail Stop CC-10528

Washington, DC 20580

Fax: (202) 326-3259

Attorneys for Plaintiff 

FEDERAL TRADE COMMISSION 

March 19, 2020 /s/ Elizabeth Nach

Case 2:20-cv-00547 Document 1 Filed 03/19/20 Page 22 of 23
CERTIFICATE OF SERVICE 

 I hereby certify that on March 19, 2020, I caused the foregoing Complaint for Permanent 

Injunction and Other Equitable Relief to be served via electronic mail upon the following: 

Mary F. Chapman, Esq. 

Law Office of Mary F. Chapman, Ltd. 

8440 W. Lake Mead Blvd., Suite 203 

Las Vegas, NV 89128 

maryf.chapman@juno.com 

 

Dated: March 19, 2020 /s/ Elizabeth K. Nach 

ELIZABETH K. NACH 

Federal Trade Commission 

600 Pennsylvania Ave., N.W. 

Mail Drop CC-10528 

Washington, D.C. 20580 

Tel: (202) 326-2611 (Nach) 

Fax: (202) 326-3259 

Email: enach@ftc.gov 

 ATTORNEY FOR PLAINTIFF 

Case 2:20-cv-00547 Document 1 Filed 03/19/20 Page 23 of 23
Exhibit A

Case 2:20-cv-00547 Document 1-1 Filed 03/19/20 Page 1 of 1
Exhibit B

Case 2:20-cv-00547 Document 1-2 Filed 03/19/20 Page 1 of 1
REJU\/1 CELL SCRIPT 

Hello (customer's name), my name is (your name); 

I'm calling from the Health Center in Southern 

Nevada. How are you today? Great! The reason for 

my call today (customer's name) is to share some 

information with you about Hgh OR Human Growth 

Hormone. Have you ever heard of Hgh before? 

Perhaps this will help, "Most people have heard or 

read something about it. Hgh has been recently 

featured on The Today Show, CNN,-MSNBC and in 

Vanity F,;tir · and Shape Magazines". Did you happen 

to see any of those? 

We can't help everyone, so I need to ask you a 

question? ARE YOU PREGNANT OR NURSING? (If yes, 

end conversation and hang up. If not continue) 

Also have _you had Cancer in the last five years? (If 

yes, sell Phytoplanton) Are you_ an insulin depen.de'1t 

Diabetic (type 1) or a Diabetic who uses INJECTIONS 

and PILLS? (type 2) (If customer is on insulin switch 

Page 11 

000165 

Exhibit C(1)

Case 2:20-cv-00547 Document 1-3 Filed 03/19/20 Page 1 of 7
to Phytolankton. If customer is a Type 2 Diabetic 

using PILLS ONLV •.•.. continue) 

Well to put it simply, hGH is a hormone our bodies 

produced naturally from the time we are born until 

we are about 20 years of age, then our bodies slow 

down the production of hGH and by the time we are 

40, our bodies have almost completely stopped 

producing it all together. It's a proven fact 

(customer's name) that the lack of hGH in our 

bodies is responsible not only for the aging process, 

but also for a wide range of health challenges. Now 

the reason hGH has been featured on so many 

programs is because it works. Our goal is to get 

your hGH levels back up like they were when you 

were a young ad~lt. Now that sounds like a plan, 

doesn't it (smile customer can see your tone) 

(customer's name) until recently the only way to get 

HUMAN GROWTH HORMONE was by a prescriptio'1 -· 

from the Doctor. The problem was that most people 

could not afford the $1,000.00 per month for the 

injections. What we have developed is a specially 

Page I 2 

000166 

Exhibit C(2)

Case 2:20-cv-00547 Document 1-3 Filed 03/19/20 Page 2 of 7
formulated Homeopathic Human Growth Hormone 

Oral Spray. \'ou spray it under your tongue 3 times 

daily. There are no known cases of side effects 

reported in 35 years and it will not interfere with -. 

any medications or supplements that you may be 

already taking (customer's name), you should feel 

results in just a few weeks, you cannot ask for much 

more than that, can you? 

Doctors have proven hGH comes with many of 

Health and Cosmetic benefits. hGH helps to 

smoothen and rehydrate skin, starts to eliminate 

cellulite (women) and can return hair back to its 

natural color if your hair is salt and pepper. It 

Increases muscle mass in men and sexuality Jn ~~,~ 

men and women. 

The New England Journal of Medicine called it the 

MOST Effective anti obesity agent ever discovered 

and they also said it's the best immune system 

enhancer ever found. Hgh WILL INCREASE YOUR 

STRENGTH by 91 % and your ENERGY by 63%! We 

could all use a little more energy, couldn't we? 

Doctors across the country are still using hGH today 

to treat a wide range. of health disorders. Actually 

hGH has proven to be beneficial for people with ·_ _ _ ·.

Page I 3 000167 

Exhibit C(3)

Case 2:20-cv-00547 Document 1-3 Filed 03/19/20 Page 3 of 7
fibromyalgia, hypertension (high blood pressure), 

high cholesterol, arthritis, emphysema, as~hma and 

muscular dystrophy. Do you ha\'e any of those? In 

fact (customer's name), hGH is the only thing that 

had positi\'e results so far on Alzheimer's Disease. 

Here is why it helps with so many things (customer's 

name), hGH rebuilds, reju\'enates, and re-nourishes 

the tissues in the lungs, heart, li\'er and kidneys. 

We can ne\'er be too heatlhy in any of those areas, 

can we? 

If you were to go to a Holistic Doctor and get one 

bottle of hGH spray, they would charge you 

hundreds of dollars per bottle. By participating in 

our three month testimonial program, the first thing 

we will do is price it at S 116.65 per bottle. Each 

bottle lasts a month, bringing the total to $349.95 

plus $15.00 shipping and handling totaling 

$364.95. The second thing that we will do is after 

the three months, we will honor that price for the 

next three years. We will gi\'e you a full 90 day 

money back guarantee. How does that sound?. So 

(Customer's name) now write down my name and 

the name of the company is ••••••• Health Center Inc 

Page I 4 

000168 

Exhibit C(4)

Case 2:20-cv-00547 Document 1-3 Filed 03/19/20 Page 4 of 7
let's get you started! (If "no" or "I don't know") 

then rebuttal (If yes go to, " Getting the Money.") -

GETTING THE MONEV 

A. SHIPPING COMES FIRSTOnce again we ship USPS. What address will be 

shipping it to? Is this a house or an apartment? 

(Get apt # or space #). What is your emai~ address, 

contact number? (NOTE: let them tell you their 

shipping address and repeat the address back to the 

customer. If you read the address on our screen 

lhey may ask how you got their number and you: will 

have to give a rebuttal and risk losing the sale. Also 

by giving you their address, they will have the 

tendency to give their credit card number without 

hesitation) 

B. PAV.MENT MEHTODNow, most (ladies/ gentlemen) just put this on a 

Visa, Master Card, and Discover, American 

Express or debit card. Which card would you like 

to use today? Great! Now, if you can please read 

Page I 5 000169 

Exhibit C(5)

Case 2:20-cv-00547 Document 1-3 Filed 03/19/20 Page 5 of 7
-·--· -·-----·-------

me all the numbers off the front of your (name of 

card) from left to right. (Repeat card number to 

the customer) and the expiration date is? Wh~t 

are the 3 numbers on the back? All I need now is 

your billing address. 

C. GIVE \'OUR INFORMATION 

Contact #: 1-800-269-2793 

Our website: www.healthcenterinc.net 

\'our name: 

D. SECURIT\' CLOSE 

Now, because we also wholesale our speci·ally 

formulated Hgh to the health care field, we to · · -· 

follow certain guidelines. 

We do not auto bill or auto ship. Once you get 

down to your last bottle you will need to call us 

back to reorder. Our #800 is placed on every 

label on the bottle as well as on your invoice. We 

do not share any information about you with 

anyone. Once we process the order your payment 

information is NOT accessible. 

Page I 6 000170 . . . 

Exhibit C(6)

Case 2:20-cv-00547 Document 1-3 Filed 03/19/20 Page 6 of 7
We do not drag our feet on shipping. \'our order 

is shipped the next business day. 

(Customer's name) One of our Health Advocates 

will be giving you a call back shortly, to confirm 

your place in the testimonial program and to 

answer any additional questions you may have .• 

Welcome to the Hgh Family and spray in good 

health!!!!! 

Page I 7 

000171 

Exhibit C(7)

Case 2:20-cv-00547 Document 1-3 Filed 03/19/20 Page 7 of 7
Healtl1 Ce11ter I11c. Mari11e Pl1yto1Jla1ll{to11 For 

Healtl1 a11d Well11ess 

SENIORS DESERVE OUR BEST ... MARINE 

PHYTOPLANKTON for HEALTH and WELLNESS 

We love our seniors and in fact, the majority of our clients are past the age of 70. 

Thru the years we have met sons and daughters, grandchildren, great-grandchildren, 

even great-great grandchildren and we are so grateful for the opportunity to be of 

service to these truly precious people. 

OUR PRODUCTS ...... . 

are always safe, pure and natural and never interfere with your prescriptions or cause allergies. 

We all know that good nutrition enhances health and wellness and that cellular health is

great health. We all know that the body will heal itself if supplied with its vital needs--cell 

replacement, proper nutrition, alkalinity, oxygenation---are absolutely essential to the ageless 

human body. Why deny your self the delight of giving your body what it needs, for health, for 

happiness and for your loved ones. 

For those with AJzhiemer's and the people that love them: 

THE ALZHEIMERS READING ROOM 

CLICK HERE 

Exhibit D(1)

Case 2:20-cv-00547 Document 1-4 Filed 03/19/20 Page 1 of 3
Exhibit D(2)

Case 2:20-cv-00547 Document 1-4 Filed 03/19/20 Page 2 of 3
Exhibit D(3)

Case 2:20-cv-00547 Document 1-4 Filed 03/19/20 Page 3 of 3
Exhibit E 

Case 2:20-cv-00547 Document 1-5 Filed 03/19/20 Page 1 of 1
Exhibit F(1)

Case 2:20-cv-00547 Document 1-6 Filed 03/19/20 Page 1 of 9
Exhibit F(2)

Case 2:20-cv-00547 Document 1-6 Filed 03/19/20 Page 2 of 9
Exhibit F(3)

Case 2:20-cv-00547 Document 1-6 Filed 03/19/20 Page 3 of 9
Exhibit F(4)

Case 2:20-cv-00547 Document 1-6 Filed 03/19/20 Page 4 of 9
Exhibit F(5)

Case 2:20-cv-00547 Document 1-6 Filed 03/19/20 Page 5 of 9
Exhibit F(6)

Case 2:20-cv-00547 Document 1-6 Filed 03/19/20 Page 6 of 9
Exhibit F(7)

Case 2:20-cv-00547 Document 1-6 Filed 03/19/20 Page 7 of 9
Exhibit F(8)

Case 2:20-cv-00547 Document 1-6 Filed 03/19/20 Page 8 of 9
Exhibit F(9)

Case 2:20-cv-00547 Document 1-6 Filed 03/19/20 Page 9 of 9
Hi my name is _____ __, with Health Center Inc. Is this 

_______ ? We are looking for people that are interested in 

improving their health, maybe someone with high blood pressure, 

diabetes, cancer, OR breathing problems and most importantly pain. Or 

those who may just need a little more energy or that want to lose a few 

pounds ....... does that describe you? 

Well, _____ , have you ever heard of Marine Phytoplankton? 

!f_y_es .... Then you know how excellent it is. Ours is four times roore 

:»~oavailabie than any Phytoplankton on the market. We have .... what 

is called ... Uposome Technology ... and we apply that science to Marine 

Phytoplankton. That means that you truly only take a 1000 MG per 

day .... so one of our 60 count caplet bottles .... is a true one month 

supply. Ours is completely odor-less, if you know about p_hytoplankton 

then you know how smelly it is, our product Rejuvi Sea Phytoplankton 

has no odor and it being four times stronger we are kinda like eating· 

everybody's lunch in the phytoplankton industry. This is top of the line 

.... state of the art in the industry .... there is no better at this time. (if 

applicable let them tell you about their experience with mpp--- and 

casually- compare how ours is better). 

Jfno .... well _____ _, do you believe that super nutrition helps 

anybody and any human condition? What if I were to tell you ... that 

what we know about super nutrition .... is now obsolete! Marine 

phytoplankton has changed the entire face of nutrition and nutritional 

healing. This is unprecedented, extreme nutrition---- 750 time the 

calcium as in milk and better calcium than milk-------650 times the 

magnes ium as in spinach-----180 times the 86 as in tuna ..... at alkalizes 

000172 

Exhibit G(1)

Case 2:20-cv-00547 Document 1-7 Filed 03/19/20 Page 1 of 3
your body to keep you from getting sick or so you can't grow can~e_r_ 

cells ..... it o~~.fgenates your deep tissues .... helps your strength and 

-2De~·gt , your m emory and your mood and libido ... even the agina 

::;rocess ! That's just the tip of the iceberg ... that' s not even talking 

about the diseases that good nutrition can alleviate ....... from 

,:~er,;:essioG to diabet es, to obesity or cancer, bone disease, Arthrati~ 

et c. People all over the world are talking about these things and how 

Marine phytoplankton has had profound positive effects on their 

diseases and their lives. You can use this and change your life and 

increase the quality of life ..... at any juncture! Nutrition like this is a 

good bet! Do you agree? 

(AT THIS POINT ENGAGE THE PROSPECT IN CONVERSATION, GET 

AGREEMENTS FROM THEM BY SAYING THINGS LIKE: "BET YOU' LIKE 

TO GET RID OF THAT" ....... OR ...... "EITHER YOU TRY THINGS OR YOU 

DON'T TRY THINGS DON'T YOU AGREE?" AFTER YOU GET TWO 

AGREEMENTS CONTINUE TO NEXT PARAGRAPH} 

Okay ... let me tell you what we are doing .... something very special. .... it is 

a 90 day trial program .... At just two caplets a day .... and 1⁄4 the cost of 

any other phytoplankton product on the market .... we will send you a 90 

day supply, of this amazing nutrient at $116.65 DOLLA RS PER fV10NTH ! 

:);ti,12'- people are paying four times that much ..... for ~ess ......... the 

whole program is $364.95 dollars including shipping .... Not much to pay 

for a bett er living .... don't you agree? ..... AND ...... When you call back to 

reorder .... you will be guaranteed that price for three years. 

let me t e ll you how this all this works ..... 1'11 t ake down your delivery 

:nfcrmaticn anci your payment information. Then I will pass this to m v 

Exhibit G(2)

Case 2:20-cv-00547 Document 1-7 Filed 03/19/20 Page 2 of 3
·:::,.::--c,g'.'an1- :::'Hrect o r ve1ho is going to make sure that ! d id everything 

·:· .-:: :T12c~, tha·;: ·J:h~ ~Hnount is correct and that I ansvvered a H your 

:_·-:.:e:stuo:;~sr ,2iur: ... Once he puts his ok on this .... it goes directly to 

_-, .. ....,.... -. ; .,.,...,~ ...., :~r,{ ~.r .. ":\n~· a~ h • ... I t· y • h". - f '9 .,... 0 •~ h--:1 :::i:.+~t ..... , Ju:::- :.::JuL ,~·, ,:. Jde~ "'eon n:s wa') o you .tg !t away} .ah .... noi.~gd : ... .. 

·=:·,2:.;:iL. :~e-~ ~;our credit card while t start filling out this f o rrn ......... (take 

your time) 

0001 74 

Exhibit G(3)

Case 2:20-cv-00547 Document 1-7 Filed 03/19/20 Page 3 of 3
Exhibit H(1)

Case 2:20-cv-00547 Document 1-8 Filed 03/19/20 Page 1 of 4
Exhibit H(2)

Case 2:20-cv-00547 Document 1-8 Filed 03/19/20 Page 2 of 4
Exhibit H(3)

Case 2:20-cv-00547 Document 1-8 Filed 03/19/20 Page 3 of 4
Exhibit H(4)

Case 2:20-cv-00547 Document 1-8 Filed 03/19/20 Page 4 of 4
Exhibit I(1)

Case 2:20-cv-00547 Document 1-9 Filed 03/19/20 Page 1 of 4
Exhibit I(2)

Case 2:20-cv-00547 Document 1-9 Filed 03/19/20 Page 2 of 4
Exhibit I(3)

Case 2:20-cv-00547 Document 1-9 Filed 03/19/20 Page 3 of 4
Exhibit I(4)

Case 2:20-cv-00547 Document 1-9 Filed 03/19/20 Page 4 of 4
REJUVI-STEM SCRIPT AL TERNA TE 

Hello, ____ _, my name is · I'm calling from 

the Health Center Inc in Southern Nevada. How ARE you today? 

Great! The reason for my call is to share some information with 

you about Adult Stem Cell Enhancement. Have you heard of 

Stem Cell Enhancers?Perhaps this will help, "Most people have 

heard or read something about it. Stem cell therapies are a 

"BIG DEAL" and have been featured in articles in all of the 

leading periodicals, and all of the major News Channels. Did > 

you happen to catch any of those? We are looking for three 

types of people who benefit the most from stem cell 

enhancers. 

The first person we are looking for: A person who is concerned 

about aging (perhaps premature aging), the second, is a person 

suffering medical conditions (like pulmonary disease, heart 

disease, bone disease, arthritis, diabetes), or the last one is a 

person who experiences pain daily basis. Would any of that 

apply to you? (listen with empathy) I am sorry to hear that you 

have had to go thru that and I am glad that I called because our 

company has released a product that could help you, for a long 

time, if not forever. Have you ever heard of regenerative · · -· 

medicine? (listen) Well you've heard of stem cells right? Now 

there is something even better than that and it is you own stem 

cells, adult stem cells. 

To put it simply, stem cells are always in our body from 

conception until death. We can use the stem cells that we have 

000175 

Exhibit J(1)

Case 2:20-cv-00547 Document 1-10 Filed 03/19/20 Page 1 of 3
in our body to slow down aging, reverse diseases and it is a 

proven fact that they work for pain as well. Did you know that? 

The problem is, stem cell replacement therapy and even adult 

stem cell therapy clinics charge $8000.00 every three months 

for this therapy. What we have developed is a special blend of 

natural ingredients that enhance, replenish, and release your 

very own stem cells. You know that adult stem cell therapy is 

called regenerative therapy for a reason. With good stem c~l_ls 

you can regenerate tissues in your body, whether it is lung 

tissue, heart tissue, stomach tissue, skin, brain, joints, bones, 

any tissue Nothing does that like Rejuvi-Stem formula. It is 

called "The magnificent little pill" because when you take two 

of these a day your stem cells improve and your body renews 

itself. This can help you, make you better. It has no side effects, 

it doesn't interfere with any medications, and no allergies have 

ever been reported. The secret is, in the blend of the 

ingredients. The first thing people notice is their skin. It 

thickens thin skin, reduces the appearance of wrink~es, ~nd 

improves elasticity. There is less pain throughout the body, and 

the longer you use it the more effective it becomes. This is Why 

it is called modern miraclel 

We are doing a promotion in your area with the "magnificent 

little pill". Most of the people that order from infomercials, the 

internet and health magazines are paying hundreds of dollars 

per bottle but by participating in this program, you will not be 

paying those prices. Here's how the program works: 

onn17G 

Exhibit J(2)

Case 2:20-cv-00547 Document 1-10 Filed 03/19/20 Page 2 of 3
You use Rejuvi-Stem for 3 months, then just write us a brlef. 

paragraph stating what Rejuvi-Stem has done for you. Now if 

we use your testimonial on our website we will only use your 

initials, not your full name. If you do this, not only will you help 

yourself, but you will help us help others and if you do that for 

us, then here's what we will do for you. 

If you go to a clinic and get one bottle of our Rejuvi-Stem 

formula, they will charge you hundreds of dollars per bottle. 

But by participating in our 3 month testimonial program, the 

first thing we will do will price it at ______ per bottle. 

Each bottle lasts a month bringing the total promotion price to _ 

_______ and there is a fifteen dollar shipping and 

handling·. The second thing we will do, for you helping us help 

others, is that when the 3 months are up, we will honor that 

_____ per bottle price for the next 3 years. Now the 

best thing about this whole thing is that for the first 3 months 

on the testimonial program we will give you a full 90 day 

money back guarantee. Sounds good, doesn't it? 

Now here is how it works: I take down your delivery 

information and I take down your payment information. Once I 

have that, then I pass the order on to my client advocate. He' 

will call you back to make sure that I did my job correctly· and 

once he signs the order it wi ll go directly to shipping where. i(_ · 

will be packed ·and shipped to you right away. Fair enough? 

Great!! Well let's get started. Get your card, a piece of paper 

and a pen. You are about to have a great experience. 

(H; () 177 ·. .I.. 

Exhibit J(3)

Case 2:20-cv-00547 Document 1-10 Filed 03/19/20 Page 3 of 3