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UNITED STATES DISTRICT COURT 

CENTRAL DISTRICT OF CALIFORNIA 

Federal Trade Commission, 

Plaintiff,

 v.

Jason Cardiff, et al.,

Defendants. 

FILED UNDER SEAL 

Case No. 18-cv-2104 

EX PARTE TEMPORARY 

RESTRAINING ORDER WITH 

ASSET FREEZE, 

APPOINTMENT OF A 

TEMPORARY RECEIVER, AND 

OTHER EQUITABLE RELIEF, 

AND ORDER TO SHOW CAUSE 

WHY A PRELIMINARY 

INJUNCTION SHOULD NOT 

ISSUE 

Plaintiff, the Federal Trade Commission, has filed its 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 Restore 

Online Shoppers’ Confidence Act, (“ROSCA”), 15 U.S.C. §§ 8401-8405, and the 

Electronic Fund Transfer Act (“EFTA”), 15 U.S.C. §§ 1693-1693r, and Section 6 

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of the Telemarketing and Consumer Fraud and Abuse Prevention Act (the 

“Telemarketing Act”), 15 U.S.C. § 6105, and has moved, pursuant to Fed. R. Civ. 

P. 65(b), for a temporary restraining order, asset freeze, other equitable relief, and 

an order to show cause why a preliminary injunction should not issue against 

Defendants Jason Cardiff, Eunjung Cardiff, a/k/a Eunjung Lee, a/k/a Eunjung No, 

Danielle Cadiz, a/k/a Danielle Walker, Redwood Scientific Technologies, Inc. 

(California), Redwood Scientific Technologies, Inc. (Nevada), Redwood Scientific 

Technologies, Inc. (Delaware), Identify, LLC, Advanced Men’s Institute Prolongz

LLC, Run Away Products, LLC, and Carols Place Limited Partnership.

FINDINGS OF FACT 

The Court, having considered the Complaint, the ex parte Application for a 

Temporary Restraining Order, declarations, exhibits, and the memorandum of 

points and authorities filed in support thereof, and being otherwise advised, finds 

that: 

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. 

B. In numerous instances, Defendants have misrepresented the 

effectiveness of their dissolvable film strip products for smoking cessation, weight 

loss, and improved male sexual performance, thereby misleading vulnerable 

consumers. Defendants have then further injured many consumers by placing 

them on unauthorized continuity plans that resulted in additional charges to their 

credits cards or withdrawals from their debit accounts. Defendants have also made 

false earnings claims as part of a multilevel marketing plan, and illegally caused 

more than one million robocalls to be made to consumers’ telephones. 

C. There is good cause to believe that Defendants Jason Cardiff, Eunjung 

Cardiff, Danielle Cadiz, Redwood Scientific Technologies, Inc. (California), 

Redwood Scientific Technologies, Inc. (Nevada), Redwood Scientific 

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Technologies, Inc. (Delaware), Identify, LLC, Advanced Men’s Institute Prolongz

LLC, Run Away Products, LLC, and Carols Place Limited Partnership have 

engaged in and are likely to engage in acts or practices that violate Sections 5(a) 

and 12 of the FTC Act, Section 4 of ROSCA, Section 907(a) of EFTA, EFTA’s 

implementing Regulation E, and the Telemarketing Sales Rule (“TSR”), and that 

Plaintiff is therefore likely to prevail on the merits of this action. As demonstrated 

by Defendants’ own advertising and communications, consumer complaints, 

declarations, and the additional documentation filed by the FTC, the Commission 

has established a likelihood of success in showing that Defendants have 

deceptively marketed TBX-FREE, Eupepsia Thin, and Prolongz, placed consumers 

on continuity plans without their prior authorization, charged consumers’ credit 

cards and debited their bank accounts without authorization, caused robocalls to be 

made to more than one million consumers to induce the sale of goods or services, 

and misrepresented the earnings that people who join their multi-level marketing 

program are likely to make. 

D. The FTC is likely to succeed in showing that Corporate Defendants 

Redwood Scientific Technologies, Inc. (California), Redwood Scientific 

Technologies, Inc. (Nevada), Redwood Scientific Technologies, Inc. (Delaware), 

Identify, LLC, Advanced Men’s Institute Prolongz LLC, Run Away Products, 

LLC, and Carols Place Limited Partnership operate as a common enterprise and are 

the alter egos of Jason Cardiff and Eunjung Cardiff. 

E. There is good cause to believe that immediate and irreparable harm 

will result from Defendants’ ongoing violations of the FTC Act, ROSCA, EFTA 

and Regulation E, and the TSR unless Defendants are restrained and enjoined by 

order of this Court. 

F. There is good cause to believe that immediate and irreparable damage 

to the Court’s ability to grant effective final relief for consumers – including 

monetary restitution, rescission, or disgorgement – will occur from the sale, 

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transfer, destruction or other disposition or concealment by Defendants of their 

assets or records, unless Defendants are immediately restrained and enjoined by 

order of this Court; and that, in accordance with Fed. R. Civ. P. 65(b) and Local 

Rule 7-19.2, the interests of justice require that this Order be granted without prior 

notice to Defendants. Thus, there is good cause for relieving Plaintiff of the duty 

to provide Defendants with prior notice of its Motion for a Temporary Restraining 

Order. 

G. Good cause exists for freezing the assets of all Defendants, appointing 

a temporary receiver over the Receivership Entities and over the assets of Jason 

Cardiff and Eunjung Cardiff, permitting Plaintiff and the Receiver immediate 

access to the Defendants’ business premises, and permitting Plaintiff and the 

Receiver to take expedited discovery. 

H. Weighing the equities and considering Plaintiff’s likelihood of 

ultimate success on the merits, a temporary restraining order with an asset freeze, 

the appointment of a temporary receiver, immediate access to business premises, 

expedited discovery, and other equitable relief is in the public interest. 

I. This Court has authority to issue this Order pursuant to Section 13(b) 

of the FTC Act, 15 U.S.C. § 53(b), Federal Rule of Civil Procedure 65, and the All 

Writs Act, 28 U.S.C. § 1651.

J. No security is required of any agency of the United States for issuance 

of a temporary restraining order. Fed. R. Civ. P. 65(c). 

DEFINITIONS

For the purpose of this Order, the following definitions shall apply:

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

any property, wherever located and by whomever held. 

B. “Continuity Program” means any plan, arrangement, or system under 

which a consumer is periodically charged for products or services, without prior 

notification by the seller before each charge. 

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C. “Corporate Defendant(s)” means Redwood Scientific Technologies, 

Inc. (California), Redwood Scientific Technologies, Inc. (Nevada), Redwood 

Scientific Technologies, Inc. (Delaware), Identify, LLC, Advanced Men’s Institute 

Prolongz LLC, Run Away Products, LLC, and Carols Place Limited Partnership,

and each of their subsidiaries, affiliates, successors, and assigns. 

D. “Defendant(s)” means Corporate Defendants, Jason Cardiff, Eunjung 

Cardiff, and Danielle Cadiz, individually, collectively, or in any combination. 

E. “Document” is synonymous in meaning and equal in scope to the 

usage of “document” and “electronically stored information” in Federal Rule of 

Civil Procedure 34(a), Fed. R. Civ. P. 34(a), and includes writings, drawings, 

graphs, charts, photographs, sound and video recordings, images, Internet sites, 

web pages, websites, electronic correspondence, including email and instant 

messages, contracts, accounting data, advertisements, FTP Logs, Server Access 

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

telephone scripts, receipt books, ledgers, personal and business canceled checks 

and check registers, bank statements, appointment books, computer records, 

customer or sales databases, and any other electronically stored information, 

including Documents located on remote servers or cloud computing systems, and 

other data or data compilations from which information can be obtained directly or, 

if necessary, after translation into a reasonably usable form. A draft or nonidentical copy is a separate document within the meaning of the term. 

F. “Electronic Data Host” means any person or entity in the business of 

storing, hosting, or otherwise maintaining electronically stored information. This 

includes, but is not limited to, any entity hosting a website or server, and any entity 

providing “cloud based” electronic storage. 

G. “Individual Defendant(s)” means Jason Cardiff, Eunjung Cardiff, and 

Danielle Cadiz, individually, collectively, or in any combination. 

H. “Negative Option” means, in an offer or agreement to sell or provide

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any good or service, a provision under which the consumer’s silence or failure to 

take an affirmative action to reject a good or service or to cancel the agreement is 

interpreted by the seller or provider as acceptance or continuing acceptance of the 

offer or agreement. 

I. “Person” means a natural person, organization, or other legal entity, 

including a corporation, partnership, proprietorship, association, cooperative, or 

any other group or combination acting as an entity. 

J. “Preauthorized Electronic Fund Transfer” means an electronic fund 

transfer authorized in advance to recur at substantially regular intervals. 

K. “Receiver” means the temporary receiver appointed in Section XV of 

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

L. “Receivership Entities” means Corporate Defendants as well as any 

other entity that has conducted any business related to Defendants’ marketing and 

sale of dissolvable film strips and promotion of the Rengalife multilevel marketing 

program, including receipt of Assets derived from any activity that is the subject of 

the Complaint in this matter, and that the Receiver determines is controlled or 

owned by any Defendant. 

M. “Receivership Property” means any Assets, wherever located, that are: 

(1) owned, controlled, or held by or for the benefit of the Receivership Entities, 

Jason Cardiff, or Eunjung Cardiff, in whole or in part; (2) in the actual or 

constructive possession of the Receivership Entities, Jason Cardiff, or Eunjung 

Cardiff; or (3) owned, controlled, or held by, or in the actual or constructive 

possession of, or otherwise held for the benefit of, any corporation, partnership, 

trust, or other entity directly or indirectly owned or controlled by the Receivership 

Entities, Jason Cardiff, or Eunjung Cardiff, including the Jurikel Family Trust, and 

Carols Place Trust. 

ORDER 

I. PROHIBITED BUSINESS ACTIVITIES 

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IT IS THEREFORE ORDERED that Defendants, Defendants’ officers, 

agents, employees, and attorneys, and all other persons in active concert or 

participation with them, who receive actual notice of this Order by personal service 

or otherwise, whether acting directly or indirectly, in connection with the 

advertising, marketing, promoting, or offering for sale of any goods, services, or 

programs are temporarily restrained and enjoined from misrepresenting or assisting 

others in misrepresenting, expressly or by implication:

A. Any material fact about TBX-FREE, Eupepsia Thin, or Prolongz, 

including, but not limited to: 

1. That TBX-FREE is an effective smoking cessation product; 

2. That TBX-FREE is more effective than either nicotine patches

or nicotine gum in enabling cigarette smokers to stop smoking; 

3. That TBX-FREE enables many cigarette smokers to quit in 

seven to ten days; 

4. That TBX-FREE has an 88% success rate, including among 

people who have smoked cigarettes for more than five years; 

5. That smokers should not need to purchase more than one month

of TBX-FREE; 

6. That clinical studies have been conducted on TBX-FREE, and 

have shown that TBX-FREE is an effective smoking cessation 

product; 

7. That TBX-FREE has been proven in clinical studies to be more

effective than nicotine patches or nicotine gum in enabling 

smokers to stop smoking;

8. That clinical studies of TBX-FREE conducted on 10,600 people

have shown that TBX-FREE has an “88% success rate”; 

9. That The New England Journal of Medicine (“NEJM”), 

Harvard Health Publications, and Johns Hopkins University 

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have published clinical studies proving that TBX-FREE is an 

effective smoking cessation product; 

10. That NEJM’s clinical studies showed that TBX-FREE is ten

times more effective for smoking cessation than nicotine 

replacement therapy;

11. That Eupepsia Thin is an effective appetite suppressant and 

weight loss aid; 

12. That Eupepsia Thin starts working in less than 20 seconds, and 

suppresses a user’s appetite within minutes; 

13. That Eupepsia Thin enables users to lose 10, 20, or even 100 

pounds without dieting, giving up their favorite foods, or 

increasing their exercise; 

14. That Eupepsia Thin users can lose 15 pounds their first month 

without dieting or changing their food or lifestyle; 

15. That Eupepsia Thin users can lose as much as 20 pounds in one 

month and as much as 50 pounds in three months;

16. That Eupepsia Thin is more effective at causing weight loss

than conventional calorie reduction and meal plans; 

17. That Eupepsia Thin enables consumers to avoid gaining back 

weight they lose, without any lifestyle changes. 

18. That clinical studies have been conducted on EupepsiaThin and 

those studies show that it is an effective appetite suppressant

and weight loss aid;

19. That Prolongz substantially increases ejaculation control and 

the duration of sex; 

20. That Prolongz treats or prevents premature ejaculation; 

21. That Prolongz is clinically proven to increase ejaculation 

control and the duration of sex for more than 97% of users;

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22. That Eupepsia Thin is made in the United States; 

23. That individuals appearing in advertising for Eupepsia Thin

used that product successfully to lose weight; and 

24. That consumers who are not satisfied with the product they 

purchased will get their money back; 

B. Any material fact about any multi-level marketing plan, including, but 

not limited to, the income that participants in the plan are likely to 

earn; and 

C. 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. 

II. PROHIBITIONS AGAINST UNFAIR AND DECEPTIVE NEGATIVE 

OPTION MARKETING PRACTICES 

IT IS FURTHER ORDERED that Defendants, Defendants’ officers, 

agents, employees, and attorneys, and all other persons in active concert or 

participation with any of them, who receive actual notice of this Order, whether 

acting directly or indirectly, in connection with the sale of any good or service are 

temporarily restrained and enjoined from charging, causing to be charged,

assisting others in charging, or attempting to charge any consumer in any sale of a 

good or service sold through a negative option without:

A. Clearly and conspicuously disclosing all material terms of the 

negative option features before obtaining the consumer’s billing information; 

B. Obtaining a consumer’s express informed consent, written or similarly 

authorized, to the negative option features before making any charge; and 

C. Providing a simple mechanism for a consumer to stop recurring 

charges from being placed on the consumer’s credit card, debit card, or other 

financial account. 

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III. PROHIBITIONS AGAINST UNAUTHORIZED CHARGES 

IT IS FURTHER ORDERED that Defendants, Defendants’ officers, 

agents, employees, and attorneys, and all other persons in active concert or 

participation with any of them, who receive actual notice of this Order, whether 

acting directly or indirectly, are temporarily restrained and enjoined from charging, 

causing to be charged, assisting others in charging, or attempting to charge any 

consumer for any good or service without first obtaining the consumer’s express 

informed consent, written or similarly authorized, to the charge. 

IV. PROHIBITIONS AGAINST DEBITING CONSUMERS’ BANK 

ACCOUNTS WITHOUT AUTHORIZATION 

IT IS FURTHER ORDERED that Defendants, Defendants’ officers, 

agents, employees, and attorneys, and all other persons in active concert or 

participation with any of them, who receive actual notice of this Order, whether 

acting directly or indirectly, in connection with the sale of any good or service, are 

temporarily restrained and enjoined from:

A. Failing to timely obtain written authorization signed or similarly 

authenticated by the consumer for any Preauthorized Electronic Fund Transfer 

from a consumer’s account before initiating any Preauthorized Electronic Fund 

Transfer; and 

B. Failing to provide to the consumer a copy of a valid written 

authorization signed or similarly authenticated by the consumer for any 

Preauthorized Electronic Fund Transfer from a consumer’s account.

V. PROHIBITION OF PRERECORDED MARKETING CALLS 

IT IS FURTHER ORDERED that Defendants, Defendants’ officers, 

agents, employees, and attorneys, and all other persons in active concert or 

participation with any of them, who receive actual notice of this Order, whether 

acting directly or indirectly, are hereby temporarily restrained and enjoined from

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initiating or causing the initiation of outbound telephone calls delivering 

prerecorded messages to induce the sale of goods or services. 

VI. PROHIBITION ON RELEASE OF CUSTOMER INFORMATION 

IT IS FURTHER ORDERED that Defendants, Defendants’ officers, 

agents, employees, and attorneys, and all other persons in active concert or 

participation with any of them, who receive actual notice of this Order, whether 

acting directly or indirectly, are hereby temporarily restrained and enjoined from:

A. Selling, renting, leasing, transferring, or otherwise disclosing, the 

name, address, birth date, telephone number, email address, credit card number, 

bank account number, Social Security number, or other financial or identifying 

information of any person that any Defendant obtained in connection with any 

activity that pertains to the subject matter of this Order; and

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

number, email address, credit card number, bank account number, Social Security 

number, or other financial or identifying information of any person that any 

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

matter of this Order. 

Provided, however, that Defendants may disclose such identifying 

information to a law enforcement agency, to their attorneys as required for their 

defense, as required by any law, regulation, or court order, or in any filings, 

pleadings or discovery in this action in the manner required by the Federal Rules of 

Civil Procedure and by any protective order in the case. 

VII. ASSET FREEZE 

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

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

with any of them, who receive actual notice of this Order, whether acting directly 

or indirectly, are hereby temporarily restrained and enjoined from:

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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 of any Assets that are: 

1. Owned or controlled, directly or indirectly, by any Defendant,

including, but not limited to, those for which a Defendant is a

signatory on the account;

2. Held, in part or in whole, for the benefit of any Defendant;

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

4. Owned or controlled by, in the actual or constructive possession 

of, or otherwise held for the benefit of, any corporation, 

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

or indirectly owned, managed or controlled by any Defendant. 

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

mail boxes, or storage facilities titled in the name of any Defendant or subject to 

access by any Defendant, except as necessary to comply with written requests from 

the Receiver acting pursuant to its authority under this Order;

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

issued in the name, individually or jointly, of any Corporate Defendant or any 

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

controlled by any Defendant, or of which any Defendant is an officer, director, 

member, or manager. This includes any corporate bankcard or corporate credit 

card account for which any Defendant is, or was on the date that this Order was 

signed, an authorized signer; or 

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

from consumers, clients, or customers of any Defendant; 

The Assets affected by this Section shall include: (1) all Assets of Defendants as 

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

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

the Complaint in this matter or that is prohibited by this Order; and (3) all Assets 

owned or controlled, directly or indirectly, by Jason Cardiff, Eunjung Cardiff, the 

Jurikel Family Trust, or Carols Place Trust. This Section does not prohibit any 

transfers to the Receiver or repatriation of foreign Assets specifically required by 

this Order. 

VIII. DUTIES OF ASSET HOLDERS AND OTHER THIRD PARTIES 

IT IS FURTHER ORDERED that any financial or brokerage institution, 

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

acquiring bank, independent sales organization, third party processor or vendor, 

payment gateway, insurance company, business entity, or person who receives 

actual notice of this Order (by service or otherwise) that: 

(a) has held, controlled, or maintained custody, through an account 

or otherwise, of any Document on behalf of any Defendant or 

any Asset that has been owned or controlled, directly or 

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

benefit of any Defendant; in the actual or constructive 

possession of any Defendant; or owned or controlled by, in the 

actual or constructive possession of, or otherwise held for the

benefit of, any corporation, partnership, asset protection trust, 

or other entity that is directly or indirectly owned, managed or 

controlled by any Defendant; 

(b) has held, controlled, or maintained custody, through an account 

or otherwise, of any Document or Asset associated with credits,

debits, or charges made on behalf of any Defendant, including 

reserve funds held by payment processors, credit card 

processors, merchant banks, acquiring banks, independent sales 

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organizations, third party processors or vendors, payment 

gateways, insurance companies, or other entities; or 

(c) has extended credit to any Defendant, including through a credit 

card account, shall: 

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

withdrawal, removal, alteration, assignment, transfer, pledge, encumbrance, 

disbursement, dissipation, relinquishment, conversion, sale, or other disposal of 

any such Document or Asset, as well as all Documents or other property related to 

such Assets, except by further order of this Court;

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

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

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

C. Provide Plaintiff’s counsel and the Receiver, within three (3) 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 other

Asset has been closed or removed, the date closed or removed, 

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

name of the person or entity to whom such account or other 

Asset was remitted; and 

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 is otherwise subject 

to access by any Defendant; and 

D. Upon the request of Plaintiff’s counsel or the Receiver, promptly 

provide Plaintiff’s counsel and the Receiver with copies of all records or other 

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Documents pertaining to any account covered by this Section 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 safe deposit boxes, commercial mail boxes, and storage facilities. 

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

or repatriation of foreign Assets specifically required by this Order. 

IX. FINANCIAL DISCLOSURES 

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

service of this Order upon them, shall prepare and deliver to Plaintiff’s counsel and 

the Receiver: 

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

Attachment A (Financial Statement of Individual Defendant) for each Individual 

Defendant, and Attachment B (Financial Statement of Corporate Defendant) for 

each Corporate Defendant and for Carols Place Trust and the Jurikel Family Trust; 

and 

B. Completed Attachment C (IRS Form 4506, Request for Copy of a 

Tax Return) for each Individual Defendant and Corporate Defendant. 

X. FOREIGN ASSET REPATRIATION 

IT IS FURTHER ORDERED that within five (5) days following the 

service of this Order, Jason Cardiff, Eunjung Cardiff, Carols Place Trust, and each 

Corporate Defendant shall: 

A. Provide Plaintiff’s counsel and the Receiver with a full accounting, 

verified under oath and accurate as of the date of this Order, of all Assets, 

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Documents, and accounts outside of the United States that are: (1) titled in the 

name, individually or jointly, of any Defendant; (2) held by any person or entity 

for the benefit of any Defendant or for the benefit of, any corporation, partnership, 

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

or controlled by any Defendant; or (3) under the direct or indirect control, whether 

jointly or singly, of any Defendant; 

B. Take all steps necessary to provide the Receiver and Plaintiff’s 

counsel access to all Documents and records that may be held by third parties 

located outside of the territorial United States of America, including signing the 

Consent to Release of Financial Records appended to this Order as Attachment D. 

C. Transfer to the territory of the United States and deliver to the 

Receiver all Documents and Assets located in foreign countries that are: (1) titled 

in the name, individually or jointly, of any Defendant, or any trust or other entity 

for which any Defendant is a beneficiary or trustee; (2) held by any person or 

entity for the benefit of any Defendant or for the benefit of any corporation, 

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

owned, managed or controlled by any Defendant; or (3) under the direct or indirect 

control, whether jointly or singly, of any Defendant; and 

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

Plaintiff’s counsel of the name and location of the financial institution or other 

entity that is the recipient of such Documents or Assets; and (2) serve this Order on 

any such financial institution or other entity. 

XI. NON-INTERFERENCE WITH ASSET FREEZE AND 

REPATRIATION

IT IS FURTHER ORDERED that Defendants, Defendants’ officers, 

agents, employees, and attorneys, and all other persons in active concert or 

participation with any of them, who receive actual notice of this Order, whether 

acting directly or indirectly, are hereby temporarily restrained and enjoined from

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taking any action, directly or indirectly, which may result in the encumbrance, 

transfer, relocation, or dissipation of domestic or foreign Assets, or in the 

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

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

indirectly, that results in a determination by a foreign trustee or other entity that a 

“duress” event has occurred under the terms of a foreign trust agreement until such 

time that all Defendants’ Assets have been fully repatriated pursuant to this Order; 

or 

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

other related entities of either the existence of this Order, or 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 this Order. 

XII. CONSUMER CREDIT REPORTS 

IT IS FURTHER ORDERED that Plaintiff may obtain credit reports 

concerning any Defendants pursuant to Section 604(a)(1) of the Fair Credit 

Reporting Act, 15 U.S.C. 1681b(a)(1), and that, upon written request, any credit 

reporting agency from which such reports are requested shall provide them to 

Plaintiff.

XIII. PRESERVATION OF RECORDS 

IT IS FURTHER ORDERED that Defendants, Defendants’ officers, 

agents, employees, and attorneys, and all other persons in active concert or 

participation with any of them, who receive actual notice of this Order, whether 

acting directly or indirectly, are hereby temporarily restrained and enjoined from:

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

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

indirectly, Documents that relate to: (1) the business, business practices, Assets, or 

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

finances of entities directly or indirectly under the control of any Defendant; or (3) 

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the business practices or finances of entities directly or indirectly under common 

control with any other Defendant; and 

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

accurately, fairly, and completely reflect Defendants’ incomes, disbursements, 

transactions, and use of Defendants’ Assets. 

XIV. REPORT OF NEW BUSINESS ACTIVITY 

IT IS FURTHER ORDERED that Defendants, Defendants’ officers, 

agents, employees, and attorneys, and all other persons in active concert or 

participation with any of them, who receive actual notice of this Order, whether 

acting directly or indirectly, are hereby temporarily restrained and enjoined from

creating, operating, or exercising any control over any business entity, whether 

newly formed or previously inactive, including any partnership, limited 

partnership, joint venture, sole proprietorship, or corporation, without first 

providing Plaintiff’s counsel and the Receiver 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, and employees; and (4) a detailed description of the business entity’s 

intended activities. 

XV. TEMPORARY RECEIVER 

IT IS FURTHER ORDERED that Robb Evans & Associates, LLC is 

appointed as temporary receiver of the Receivership Entities and of the assets of 

Jason Cardiff and Eunjung Cardiff that are: 

1 . Owned, controlled or held by or for the benefit of Jason Cardiff 

or Eunjung Cardiff, in whole or in part; 

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2. In the actual or constructive possession of Jason Cardiff or 

Eunjung Cardiff; or 

3. Owned, controlled or held by, or in the actual or constructive 

possession of, or otherwise held for the benefit of, any 

corporation, partnership, trust, or other entity directly or 

indirectly owned or controlled by Jason Cardiff or Eunjung 

Cardiff; 

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

this Court in acting as Receiver under this Order. 

XVI. DUTIES AND AUTHORITY OF RECEIVER 

IT IS FURTHER ORDERED that the Receiver is directed and authorized 

to accomplish the following: 

A. Assume full control of the Receivership Entities by removing, as the 

Receiver deems necessary or advisable, any director, officer, independent 

contractor, employee, attorney, or agent of any Receivership Entity from control 

of, management of, or participation in, the affairs of the Receivership Entity; 

B. Take exclusive custody, control, and possession of all Assets and 

Documents of, or in the possession, custody, or under the control of, any 

Receivership Entity and all Assets of Jason Cardiff and Eunjung Cardiff covered 

by Part XV of this Order, wherever situated, except for real property used as the 

residence of Jason Cardiff and Eunjung Cardiff; 

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

Assets associated with credits, debits, or charges made on behalf of any 

Receivership Entity, wherever situated, including reserve funds held by payment 

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

sales organizations, third party processors, payment gateways, insurance 

companies, or other entities; 

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

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

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

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

The Receiver shall have full power to sue for, collect, and receive, all Receivership 

Property and all Assets of other persons or entities whose interests are now under 

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

Jason Cardiff or Eunjung Cardiff. Provided, however, that the Receiver shall not 

attempt to collect any amount from a consumer if the Receiver believes the 

consumer’s debt to the Receivership Entities has resulted from the deceptive acts 

or practices or other violations of law alleged in the Complaint in this matter, 

without prior Court approval; 

E. Take exclusive custody, control, and possession of the following 

valuable articles in the possession, custody, or under the control of, Defendants 

Jason Cardiff, Eunjung Cardiff, or Carols Place Limited Partnership, wherever 

located: 

1. Ladies 14K yellow gold and diamond ring. Insured for 

$11,813. 

2. Ladies diamond pendent setting 14 KT. Insured for $23,730. 

3. Ladies Diamond Stud Earrings. Insured for $34,125. 

4. Ladies Diamond Fancy Ring. Insured for $31,763. 

5. Mens Roadster SM WG/WG Paved Bezel. Insured for 

$32,550. 

6. Ladies handmade platinum diamond bracelet. Insured for 

$46,725 

7. Mens GTS 18KT white gold Daytona Rolex. Insured for 

$42,000. 

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8. 5.08 ct round diamond I color S12 Clarity EGL platinum ring.

Insured for $102,076. 

9. Mens Rolex Yacht-Master 18K gold watch. Insured for 

$14,125. 

10. Ladies Love Bra yellow gold 4 dia[] 17 cm. Insured for $9,819. 

11. Ladies yellow gold ring, Serial #UD0824. Insured for $2,284. 

12 Ladies fancy diamond bracelet. Insured for $39,397. 

13. Mens Rolex watch 18KT gold Pearlmaster. Insured for 

$33,180. 

14. Tiffany pearl bracelet. Insured for $3,166. 

15. Ladies emerald and diamond ring. Insured for $24,856.

16. IWC Portofino moon phase watch. Insured for $8,000. 

17. Pre-owner Ladies stainless steel Patek Phili[ppe]. Insured for 

$8,145. 

18. Rolex Vintage Thund[er]. Insured for $9,000.

19. Stuart Moore “Aronade” platinum diamond. Insured for 

$12,650. 

20. Peter Philippe annual calendar wristwatch. Insured for 

$41,300. 

21. 18K yellow gold Tiffany Diamond Bracelet. #B0164. Insured

for $7,600. 

22. “Living Room” Artist Romero Britto. Insured for $12,600.

23. Hermes Birkin bag, size 35 (Togo leather; in Sienna color).

Insured for $20,000. 

24. Hermes Birkin bag, size 35 (Togo leather; Curry). Insured for 

$20,000 

25. Ladies ring round center stone 8.5 cts, VS2 with diamonds. 

Insured for $532,000. 

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26. MenOCOs Patek Philippe gold calendar watch model 5035J. 

Insured for $28,500. 

Defendants Jason Cardiff and Eunjung Cardiff shall deliver all of the foregoing 

articles to the Receiver at a place and time to be determined by the Receiver. 

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

of the Receivership Entities, and perform all acts necessary or advisable to 

preserve such Documents. The Receiver shall: divert mail; preserve all 

Documents of the Receivership Entities that are accessible via electronic means 

(such as online access to financial accounts and access to electronic documents 

held onsite or by Electronic Data Hosts, by changing usernames, passwords or 

other log-in credentials; take possession of all electronic Documents of the 

Receivership Entities stored onsite or remotely; take whatever steps necessary to 

preserve all such Documents; and obtain the assistance of the FTC’s Digital 

Forensic Unit for the purpose of obtaining electronic documents stored onsite or 

remotely. 

G. 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; 

H. Make payments and disbursements from the receivership estate that 

are necessary or advisable for carrying out the directions of, or exercising the 

authority granted by, this Order, and to incur, or authorize the making of, such 

agreements as may be necessary and advisable in discharging his or her duties as 

Receiver. The Receiver shall apply to the Court for prior approval of any payment 

of any debt or obligation incurred by the Receivership Entities prior to the date of 

entry of this Order, except payments that the Receiver deems necessary or 

advisable to secure Assets of the Receivership Entities, such as rental payments; 

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I. Take all steps necessary to secure and take exclusive custody of each 

location from which the Receivership Entities 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, servers, internal networks, or other records maintained at that location; 

and (2) requiring any persons present at the location to leave the premises, to 

provide the Receiver with proof of identification, and/or to demonstrate to the 

satisfaction of the Receiver that such persons are not removing from the premises 

Documents or Assets of the Receivership Entities, including, but not limited to, 

telephones, computers, and tablets paid for by the Receivership Entities. Law 

enforcement personnel, including, but not limited to, police or sheriffs, may assist 

the Receiver in implementing these provisions in order to keep the peace and 

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

provide appropriate and necessary assistance to the Receiver to implement this 

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

J. Take all steps necessary to prevent the modification, destruction, or 

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

by any Defendants, and to provide access to all such web page or websites to 

Plaintiff’s representatives, agents, and assistants, as well as Defendants and their 

representatives; 

K. Enter into and cancel contracts and purchase insurance as advisable or 

necessary; 

L. Prevent the inequitable distribution of Assets and determine, adjust, 

and protect the interests of consumers who have transacted business with the 

Receivership Entities; 

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

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

deliver copies thereof to all parties; 

N. Institute, compromise, adjust, appear in, intervene in, defend, dispose 

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

or arbitration proceedings as the Receiver deems necessary and advisable to 

preserve or recover the Assets of the Receivership Entities, or to carry out the 

Receiver’s mandate under this Order, including, but not limited to, actions 

challenging fraudulent or voidable transfers;

O. Issue subpoenas to obtain Documents and records pertaining to the 

Receivership, and conduct discovery in this action on behalf of the receivership 

estate, in addition to obtaining other discovery as set forth in this Order; 

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

of the Receivership Entities. The Receiver shall deposit all funds of the 

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

disbursements from the receivership estate from such accounts. The Receiver shall 

serve copies of monthly account statements on all parties; 

Q. Maintain accurate records of all receipts and expenditures incurred as 

Receiver;

R. Allow Plaintiffs’ representatives, agents, and assistants, as well as

Defendants’ representatives and Defendants themselves, reasonable access to the 

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

Receivership Entities conduct business. The purpose of this access shall be to 

inspect and copy any and all books, records, Documents, accounts, and other 

property owned by, or in the possession of, the Receivership Entities or their 

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

reasonable conditions of such access; 

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S. 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 the Receivership Entities; 

T. Cooperate with reasonable requests for information or assistance from 

any state or federal civil or criminal law enforcement agency;

U. Suspend business operations of the Receivership Entities if in the 

judgment of the Receiver such operations cannot be continued legally and 

profitably;

V. If the Receiver identifies a nonparty entity as a Receivership Entity, 

promptly notify the entity as well as the parties, and inform the entity that it can 

challenge the Receiver’s determination by filing a motion with the Court. 

Provided, however, that the Receiver may delay providing such notice until the 

Receiver has established control of the nonparty entity and its assets and records, if 

the Receiver determines that notice to the entity or the parties before the Receiver 

establishes control over the entity may result in the destruction of records, 

dissipation of assets, or any other obstruction of the Receiver’s control of the 

entity; 

W. If in the Receiver’s judgment the business operations cannot be 

continued legally and profitably, take all steps necessary to ensure that any of the 

Receivership Entities’ web pages or websites relating to the activities alleged in the 

Complaint cannot be accessed by the public, or are modified for consumer 

education and/or informational purposes, and take all steps necessary to ensure that 

any telephone numbers associated with the Receivership Entities cannot be 

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

information regarding the status of operations; and 

X. Report to this Court on or before the date set for the hearing to Show 

Cause regarding the Preliminary Injunction or as otherwise directed by the Court, 

regarding: (1) the steps taken by the Receiver to implement the terms of the Order; 

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(2) the value of all assets and sum of all liabilities of the Receivership Entities; (3) 

the steps the Receiver intends to take in the future to protect receivership assets, 

recover receivership assets from third parties, and adjust receivership liabilities; (4) 

the Receiver’s opinion on whether any portion of the business of any of the 

Receivership Entities can continue to operate legally and profitably; and (5) any 

other matters that the Receiver believes should be brought to the Court’s attention. 

XVII.TRANSFER OF RECEIVERSHIP PROPERTY TO RECEIVER 

IT IS FURTHER ORDERED that Defendants and any other person with 

possession, custody or control of (1) property of, or records relating to, the 

Receivership Entities or (2) the Assets of Jason Cardiff or Eunjung Cardiff or any 

trusts for which they are beneficiaries or trustees, 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 the Receivership Entities and the Assets of Jason Cardiff or Eunjung 

Cardiff and immediately provide, transfer, or deliver to the Receiver possession, 

custody, and control of, the following:

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

Jason Cardiff or Eunjung Cardiff, except for real property used as the residence of 

Jason Cardiff and Eunjung Cardiff;

B. All Documents or Assets associated with credits, debits, or charges 

made on behalf of any Receivership Entity, wherever situated, including reserve 

funds held by payment processors, credit card processors, merchant banks, 

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

gateways, insurance companies, or other entities; 

C. All Documents of or pertaining to the Receivership Entities or to the 

Assets of Jason Cardiff or Eunjung Cardiff; 

D. All computers, electronic devices, mobile devices, and machines used 

to conduct the business of the Receivership Entities; 

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

whose interests are under the direction, possession, custody, or control of the 

Receivership Entities; and 

F. All keys, codes, user names, passwords, and all other means of 

authentication necessary to gain or to secure access to any Assets or Documents of 

or pertaining to the Receivership Entities, including access to their business 

premises, means of communication, mobile phones, accounts, computer systems

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

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

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

Receiver may file an Affidavit of Non-Compliance regarding the failure and a 

motion seeking compliance or a contempt citation. 

XVIII. PROVISION OF INFORMATION TO RECEIVER 

IT IS FURTHER ORDERED that Receivership Entities and Jason Cardiff 

and Eunjung Cardiff shall immediately provide to the Receiver: 

A. A list of all Assets and accounts of the Receivership Entities that are 

held in any name other than the name of a Receivership Entity, or by any person or 

entity other than a Receivership Entity; 

B. A list of all Assets and accounts of Jason Cardiff and Eunjung Cardiff 

that are held in any name other than their own names, or by any person or entity 

other than themselves; 

C. A list of all agents, employees, officers, attorneys, servants and those 

persons in active concert and participation with the Receivership Entities, or who 

have been associated or done business with the Receivership Entities; and 

D. A description of any documents covered by attorney-client privilege 

or attorney work product, including files where such documents are likely to be 

located, authors or recipients of such documents, and search terms likely to 

identify such electronic documents. 

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XIX. COOPERATION WITH THE RECEIVER 

IT IS FURTHER ORDERED that Defendants, Receivership Entities, 

Defendants’ or Receivership Entities’ officers, agents, employees, and attorneys, 

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

person with possession, custody, or control of: 

1. Receivership Property or records relating to Receivership 

Property; or 

2. Other records relating to the Receivership Entities; 

who receive actual notice of this Order shall fully cooperate with and assist the 

Receiver. This cooperation and assistance shall include, but is not limited to, 

providing information to the Receiver that the Receiver deems necessary to 

exercise the authority and discharge the responsibilities of the Receiver under this 

Order; providing any keys, codes, user names, passwords, and all other means 

required to access any computers, electronic devices, mobile devices, machines 

(onsite or remotely), and any cloud account (including specific method to access 

account) or electronic file in any medium; advising all persons who owe money to 

any Receivership Entity that all debts should be paid directly to the Receiver; and 

transferring funds at the Receiver’s direction and producing records related to the 

Receivership Property and sales of the Receivership Entities. 

XX. NON-INTERFERENCE WITH THE RECEIVER 

IT IS FURTHER ORDERED that Defendants, Receivership Entities, 

Defendants’ or Receivership Entities’ officers, agents, employees, attorneys, and 

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

actual notice of this Order, and any other person served with a copy of this Order, 

are hereby restrained and enjoined from directly or indirectly:

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

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

B. Transacting any of the business of the Receivership Entities; 

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

assigning, liquidating, or otherwise disposing of any Assets owned, controlled, or 

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

Receivership Entities, Jason Cardiff, or Eunjung Cardiff; or 

D. Refusing to cooperate with the Receiver or the Receiver’s duly 

authorized agents in the exercise of their duties or authority under any order of this 

Court. 

XXI. STAY OF ACTIONS 

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

the pendency of the receivership ordered herein, Defendants, Defendants’ officers, 

agents, employees, attorneys, and all other persons in active concert or 

participation with any of them, who 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 action that 

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

Documents of the Receivership Entities or over the assets of Jason Cardiff and 

Eunjung Cardiff, 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 the Receivership Entities; 

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

other action or proceeding against the Receivership Entities, including the issuance 

or employment of process against the Receivership Entities, except that such 

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

limitations; 

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

taking or attempting to take possession, custody, or control of any Asset of the 

Receivership Entities, Jason Cardiff, or Eunjung Cardiff; or attempting to 

foreclose, forfeit, alter, or terminate any interest in any Asset of the Receivership 

Entities, Jason Cardiff, or Eunjung Cardiff, 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 in an action or proceeding by a 

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

XXII.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 Entities, Jason Cardiff, or Eunjung Cardiff. 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. 

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XXIII. RECEIVER’S BOND 

IT IS FURTHER ORDERED that the Receiver shall file with the Clerk of 

this Court a bond in the sum of $15,000 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.

XXIV. IMMEDIATE ACCESS TO BUSINESS PREMISES AND RECORDS

IT IS FURTHER ORDERED that:

A. In order to allow Plaintiff and the Receiver to preserve Assets and 

evidence relevant to this action and to expedite discovery, Plaintiff and the 

Receiver, and their representatives, agents, contractors, and assistants, shall have 

immediate access to the business premises and storage facilities, owned, 

controlled, or used by the Receivership Entities. Such locations include, but are 

not limited to: 820 North Mountain Ave., Suite 100, Upland, CA 91786; 870 

North Mountain Ave., Suites 115 and 118, Upland, CA 91786; any additional 

business locations if they are discovered during the immediate access, and any 

offsite location or commercial mailbox used by the Receivership Entities. The

Receiver may exclude Defendants, Receivership Entities, and their employees 

from the business premises during the immediate access. 

B. Plaintiff and the Receiver, and their representatives, agents, 

contractors, and assistants, are authorized to remove Documents from the 

Receivership Entities’ premises in order that they may be inspected, inventoried, 

and copied. Plaintiff shall return any removed materials to the Receiver within 

five (5) business days of completing inventorying and copying, or such time as is 

agreed upon by Plaintiff and the Receiver; 

C. Plaintiff’s access to the Receivership Entities’ documents pursuant to 

this Section shall not provide grounds for any Defendant to object to any 

subsequent request for documents served by Plaintiff. 

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D. Plaintiff and the Receiver, and their representatives, agents, 

contractors, and assistants, are authorized to obtain the assistance of federal, state

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

implement peacefully the provisions of this Order; 

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

information related to the business practices or finances of the Receivership 

Entities are at a location other than those listed herein, including personal

residence(s) of any Defendant, then, immediately upon receiving notice of this 

order, Defendants and the Receivership Entities shall produce to the Receiver all 

such Documents, computers, and electronic storage devices, along with any codes 

or passwords needed for access. In order to prevent the destruction of computer 

data, upon service of this Order, any such computers or electronic storage devices 

shall be powered down in the normal course of the operating system used on such 

devices and shall not be powered up or used until produced for copying and 

inspection; and 

F. If any communications or records of any Receivership Entity are

stored with an Electronic Data Host, such Entity shall, immediately upon receiving 

notice of this order, provide the Receiver with the username, passwords, and any 

other login credential needed to access the communications and records, and shall 

not attempt to access, or cause a third party to attempt to access, the 

communications or records. 

XXV. DISTRIBUTION OF ORDER BY DEFENDANTS 

IT IS FURTHER ORDERED that Defendants shall immediately provide a 

copy of this Order to each affiliate, telemarketer, marketer, sales entity, successor, 

assign, member, officer, director, employee, agent, independent contractor, client, 

attorney, spouse, subsidiary, division, and representative of any Defendant, and 

shall, within ten (10) days from the date of entry of this Order, provide Plaintiff 

and the Receiver with a sworn statement that this provision of the Order has been 

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satisfied, which statement shall include the names, physical addresses, phone 

number, and email addresses of each such person or entity who received a copy of 

the Order. Furthermore, Defendants shall not take any action that would 

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

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

other persons or entities in active concert or participation with them to disregard 

this Order or believe that they are not bound by its provisions. 

XXVI. EXPEDITED DISCOVERY 

IT IS FURTHER ORDERED that, notwithstanding the provisions of Fed. 

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

34, and 45, Plaintiff and the Receiver are granted leave, at any time after service of 

this Order, to conduct limited expedited discovery for the purpose of discovering: 

(1) the nature, location, status, and extent of Defendants’ Assets; or (2) compliance 

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

proceed as follows: 

A. Plaintiff and the Receiver may take the deposition of parties and nonparties. Forty-eight (48) hours notice shall be sufficient notice for such 

depositions. The limitations and conditions set forth in Rules 30(a)(2)(B) and 

31(a)(2)(B) of the Federal Rules of Civil Procedure regarding subsequent 

depositions of an individual shall not apply to depositions taken pursuant to this 

Section. Any such deposition taken pursuant to this Section shall not be counted 

towards the deposition limit set forth in Rules 30(a)(2)(A) and 31(a)(2)(A) and 

depositions may be taken by telephone or other remote electronic means. 

B. Plaintiff and the Receiver may serve upon parties requests for 

production of Documents or inspection that require production or inspection within 

five (5) days of service, provided, however, that three (3) days of notice shall be 

deemed sufficient for the production of any such Documents that are maintained or 

stored only in an electronic format. 

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C. Plaintiff and the Receiver may serve upon parties interrogatories that 

require response within five (5) days after Plaintiff serves such interrogatories. 

D. Plaintiff and the Receiver may serve subpoenas upon non-parties that 

direct production or inspection within five (5) days of service. 

E. Service of discovery upon a party to this action, taken pursuant to this 

Section, shall be sufficient if made by facsimile, email, or by overnight delivery. 

F. Any expedited discovery taken pursuant to this Section is in addition 

to, and is not subject to, the limits on discovery set forth in the Federal Rules of 

Civil Procedure and the Local Rules of this Court. The expedited discovery 

permitted by this Section does not require a meeting or conference of the parties, 

pursuant to Rules 26(d) & (f) of the Federal Rules of Civil Procedure. 

G. The Parties are exempted from making initial disclosures under Fed. 

R. Civ. P. 26(a)(1) until further order of this Court.

XXVII. SERVICE OF THIS ORDER 

IT IS FURTHER ORDERED that copies of this Order as well as 

Plaintiff’s Ex Parte Application For (1) A Temporary Restraining Order And 

Order To Show Cause Why A Preliminary Injunction Should Not Issue And (2) 

Order Waiving Notice Requirement and all other pleadings, Documents, and 

exhibits filed contemporaneously with that Application (other than the complaint 

and summons), may be served by any means, including facsimile, electronic mail 

or other electronic messaging, personal or overnight delivery, U.S. Mail or FedEx, 

by agents and employees of Plaintiff, by any law enforcement agency, or by 

private process server, upon any Defendant or any person (including any financial 

institution) that may have possession, custody or control of any Asset or Document 

of any Defendant, or that may be subject to any provision of this Order pursuant to 

Rule 65(d)(2) of the Federal Rules of Civil Procedure. For purposes of this 

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

effect service upon the entire entity. 

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XXVIII. CORRESPONDENCE AND SERVICE ON PLAINTIFF 

IT IS FURTHER ORDERED that, for the purpose of this Order, all 

correspondence and service of pleadings on Plaintiff shall be addressed to:

Elizabeth Sanger 

James A. Prunty 

Edwin Rodriguez 

Shira D. Modell 

Federal Trade Commission 

600 Pennsylvania Ave., NW 

Washington, DC 20580 

Tel: (202) 326-2757, -2438, -3147, -3116 

Fax: (202) 326-3259 

Email: esanger@ftc.gov; jprunty@ftc.gov; erodriguez@ftc.gov; 

smodell@ftc.gov 

XXIX. PRELIMINARY INJUNCTION HEARING 

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

Defendants shall appear before this Court on the 23rd day of October, 2018, at 

2:00 p.m. to show cause, if there is any, why this Court should not enter a 

preliminary injunction, pending final ruling on the Complaint against Defendants, 

enjoining the violations of the law alleged in the Complaint, continuing the freeze 

of the Defendants’ Assets, continuing the receivership, and imposing such 

additional relief as may be appropriate. 

XXX. BRIEFS AND AFFIDAVITS CONCERNING PRELIMINARY 

INJUNCTION 

IT IS FURTHER ORDERED that:

A. Defendants shall file with the Court and serve on Plaintiff’s counsel 

any answering pleadings, affidavits, motions, expert reports or declarations, or 

legal memoranda no later than four (4) days prior to the order to show cause 

hearing scheduled pursuant to this Order. Plaintiff may file responsive or 

supplemental pleadings, materials, affidavits, or memoranda with the Court and 

serve the same on counsel for Defendants no later than one (1) day prior to the 

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order to show Cause hearing. Provided that such affidavits, pleadings, motions, 

expert reports, declarations, legal memoranda, or oppositions must be served by 

personal or overnight delivery, facsimile or email, and be received by the other 

party or parties no later than 5:00 p.m. Pacific Time on the appropriate dates set 

forth in this Section. 

B. An evidentiary hearing on Plaintiff’s request for a preliminary 

injunction is not necessary unless Defendants demonstrate that they have, and 

intend to introduce, evidence that raises a genuine and material factual issue. The

question of whether this Court should enter a preliminary injunction shall be 

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

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

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

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

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

and telephone number of each proposed witness, a detailed summary or affidavit 

revealing the substance of each proposed witness’s expected testimony, and an 

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

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

testimony in response to another party’s timely motion to present live testimony 

shall be filed with this Court and served on the other parties at least three (3) days 

prior to the order to show cause hearing. 

Provided, however, that service shall be performed by personal or overnight 

delivery, facsimile, or email, and Documents shall be delivered so that they shall 

be received by the other parties no later than 5:00 p.m. Pacific Time on the 

appropriate dates provided in this Section. 

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_______________________________ 

XXXI. DURATION OF THE ORDER 

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

days from the date of entry noted below, unless within such time, the Order is 

extended for an additional period pursuant to Fed. R. Civ. P. 65(b)(2).

XXXII. RETENTION OF JURISDICTION 

IT IS FURTHER ORDERED that this Court shall retain jurisdiction of 

this matter for all purposes. 

SO ORDERED, this 10th day of October, 2018 @ 3:00 p.m.

UNITED STATES DISTRICT JUDGE 

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