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UNITED STATES DISTRICT COURT 

MIDDLE DISTRICT OF FLORIDA 

FEDERAL TRADE COMMISSION, 

Plaintiff, 

v. 

MICHAEL RANDO, a/k/a Mike Singles, 

individually and as a principal of Prosperity 

Training Technology LLC, Elite Customer 

Services, LLC, Digital Business Scaling 

LLC, First Coast Matchmakers Inc., First 

Coast Matchmakers LLC, and Financial 

Consulting Management Group LLC, 

VALERIE RANDO, a/k/a Valerie Payton, 

Val Rando, and Val Singles, individually 

and as a principal of Prosperity Training 

Technology LLC, Elite Customer Services, 

LLC, Digital Business Scaling LLC, First 

Coast Matchmakers Inc., First Coast 

Matchmakers LLC, and Financial 

Consulting Management Group LLC, 

PROSPERITY TRAINING 

TECHNOLOGY LLC, a Florida limited 

liability company, also d/b/a The Credit 

Game, The Credit Game University, and 

Elite Deletions, 

ELITE CUSTOMER SERVICES, LLC, a 

Florida limited liability company, 

DIGITAL BUSINESS SCALING LLC, a 

Florida limited liability company, 

FIRST COAST MATCHMAKERS INC., a 

Florida corporation, also d/b/a Wholesale 

Tradelines, 

Case No. 3:22-cv-00487-TJCMCR 

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 
 

 

 

 

 

 

 

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FIRST COAST MATCHMAKERS LLC, a 

Florida limited liability company, also 

d/b/a Wholesale Tradelines, 

FINANCIAL CONSULTING 

MANAGEMENT GROUP LLC, a Florida 

limited liability company, and 

RESOURCE MANAGEMENT 

INVESTMENTS, LLC, a Florida limited 

liability company, 

Defendants. 

Plaintiff, the Federal Trade Commission (“FTC”) has filed its Complaint for 

Permanent Injunction, Monetary Relief, and Other Relief pursuant to Sections 13(b) 

and 19 of the Federal Trade Commission Act (“FTC Act”), 15 U.S.C. §§ 53(b) and 

57b, (Dkt. # 1), 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 Michael Rando and Valerie Rando, 

and Prosperity Training Technology LLC; Elite Customer Services, LLC; Digital 

Business Scaling LLC; First Coast Matchmakers Inc.; First Coast Matchmakers 

LLC; Financial Consulting Management Group LLC; and Resource Management 

Investments, LLC. (Dkt. # 4). 

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FINDINGS OF FACT 

The Court, having considered the Complaint, the ex parte Motion 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 operated a credit repair and 

business opportunity scheme in which they, among other things: 

1. Deceptively claim they can quickly and legally improve 

consumers’ credit scores by removing most or all negative items 

on their credit reports, causing a third party’s credit history to 

appear on their credit reports, and manipulating consumers’ 

identifying information, and that these services come with a 

money-back guarantee; 

2. File, or caused to be filed, fake identity theft reports on the FTC’s 

identitytheft.gov website; 

3. Take prohibited advance fees, fail to honor cancellation requests 

and provide refunds, and fail to make required disclosures 

regarding their credit repair services; 

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4. Deceptively claim consumers can profitably and legally operate a 

business selling credit repair services and education and fail to 

make required disclosures regarding their business opportunity; 

and 

C. There is good cause to believe that Defendants Michael Rando; Valerie 

Rando; Prosperity Training Technology LLC; Elite Customer Services, LLC; Digital 

Business Scaling LLC; First Coast Matchmakers Inc.; First Coast Matchmakers 

LLC; Financial Consulting Management Group LLC; and Resource Management 

Investments, LLC have engaged in and are likely to engage in acts or practices that 

violate Section 5(a) of the FTC Act, 15 U.S.C. § 45(a); multiple provisions of the 

Credit Repair Organizations Act (“CROA”), 15 U.S.C. §§ 1679-1679j; multiple 

provisions of the FTC’s Telemarketing Sales Rule (“TSR”), 16 C.F.R. Part 310; and 

multiple provisions of the FTC’s Trade Regulation Rule entitled “Disclosure 

Requirements and Prohibitions Concerning Business Opportunities” (“Business 

Opportunity Rule” or “BOR”), 16 C.F.R. Part 437; and that Plaintiff is therefore 

likely to prevail on the merits of this action. As demonstrated by detailed evidence, 

including declarations from FICO and Equifax, declarations from consumers, 

transcripts of undercover calls, consumer complaint analyses, identity theft report 

analyses, Defendants’ own marketing statements, and the additional documentation 

filed by the FTC, the FTC has established a likelihood of success in showing that 

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Defendants have operated an illegal credit repair and money-making scheme and 

made false, misleading, and deceptive misrepresentations. 

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

result from Defendants’ ongoing violations of the FTC Act, CROA, the TSR, and 

the BOR unless Defendants are restrained and enjoined by order of this Court. 

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

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

rescission or reformation of contracts, the refund of money, and the return of 

property – will occur from the sale, 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), 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. 

F. Good cause exists for appointing a temporary Receiver over the 

Receivership Entities, freezing Defendants’ assets, permitting the Plaintiff and the 

Receiver immediate access to the Defendants’ business premises, and permitting the 

Plaintiff and the Receiver to take expedited discovery. 

G. Weighing the equities and considering Plaintiff’s likelihood of ultimate 

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

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appointment of a temporary Receiver, immediate access to business premises, 

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

H. This Court has authority to issue this Order pursuant to Sections 13(b) 

and 19 of the FTC Act, 15 U.S.C. §§ 53(b) and 57b; Federal Rule of Civil Procedure 

65; and the All Writs Act, 28 U.S.C. § 1651. 

I. 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, whether tangible, intangible, 

digital, intellectual property, or otherwise. 

B. “Corporate Defendant(s)” means Prosperity Training Technology 

LLC; Elite Customer Services, LLC; Digital Business Scaling LLC; First Coast 

Matchmakers Inc.; First Coast Matchmakers LLC; Financial Consulting 

Management Group LLC; Resource Management Investments, LLC; and each of 

their subsidiaries, affiliates, successors, and assigns. 

C. “Credit Repair Service” means any service, in return for payment of 

money or other valuable consideration, for the express or implied purpose of: 1) 

improving any consumer’s credit report, credit record, credit history, credit profile, 

credit score, or credit rating; or 2) providing any advice or assistance to any 

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consumer with regard to any activity or service the purpose of which is to improve a 

consumer’s credit report, credit record, credit history, credit profile, credit score, or 

credit rating. 

D. “Defendants” means Corporate Defendants and Individual 

Defendants, 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 e-mail and instant messages, 

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

written or printed records, handwritten notes, telephone logs, telephone scripts, 

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

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

and any other electronically stored information, including Documents located on 

remote servers or cloud computing systems, and other data or data compilations 

from which information can be obtained directly or, if necessary, after translation 

into a reasonably usable form. A draft or non-identical copy is a separate document 

within the meaning of the term. 

F. “Earnings Claim” means any oral, written, or visual representation to a 

consumer, prospective purchaser, or investor that conveys, expressly or by 

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implication, a specific level or range of actual or potential sales, or gross or net 

income or profits. Earnings claims include, but are not limited to any: 1) chart, table, 

or mathematical calculation that demonstrates possible results based upon a 

combination of variables; and 2) statements from which a consumer, prospective 

purchaser, or investor can reasonably infer that he or she will earn a minimum level 

of income (e.g. “earn enough to buy a Lamborghini,” “earn a six-figure income,” or 

“earn your investment back within one year”). 

G. “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. 

H. “Individual Defendant(s)” means Michael Rando and Valerie Rando, 

individually, collectively, or in any combination. 

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

including a corporation, partnership, sole proprietorship, limited liability company, 

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

J. “Receiver” means the temporary receiver appointed in Section XIII of 

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

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

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

money-making scheme, including receipt of Assets derived from any activity that is 

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the subject of the Complaint in this matter, and that the Receiver determines is 

controlled or owned by any Defendant. 

ORDER 

I. PROHIBITED CREDIT REPAIR ACTIVITIES 

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 Credit Repair Service, 

are temporarily restrained and enjoined from: 

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

implication: 

1. That any Person can remove negative information or hard 

inquires from their own or any other Person’s credit report, credit 

record, credit history, or credit profile; 

2. That any Person can substantially improve their own or any 

other Person’s credit score or credit rating; 

3. That any Person is, or will add any Person as, an additional 

authorized user on any other Person’s credit card or line of credit 

account; 

4. That any Person is or was the victim of identity theft; 

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5. Current or past identifying information (e.g. names, aliases, 

addresses, phone numbers, or employment history) on a 

consumer’s credit report, credit record, credit history, or credit 

profile; 

6. Any other fact material to consumers concerning any Credit 

Repair Service, such as the total costs; any material restrictions, 

limitations, or conditions; or any material aspect of its 

performance, efficacy, nature, or central characteristics; 

B. Charging or receiving money or other valuable consideration for the 

performance of any Credit Repair Service: 1) before such service is fully performed, 

and 2) before providing the consumer with documentation in the form of a consumer 

report from a consumer reporting agency demonstrating the promised results have 

been achieved, with such report having been issued more than six months after the 

results were achieved. 

C. Failing to provide any Person with a written statement of “Consumer 

Credit File Rights Under State and Federal Law,” in the form and manner required 

by 15 U.S.C. § 1679c(a); 

D. Failing to include in contracts for any Credit Repair Service the 

following required terms and conditions: a) a full and detailed description of the 

services to be performed for the consumer, including all guarantees of performance 

and an estimate of the date by which the performance of the services (to be 

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performed by Defendants or any other Person) will be complete or the length of the 

period necessary to perform such services, and b) the specific conspicuous statement 

in bold face type, in immediate proximity to the space reserved for the consumer's 

signature on the contract, regarding the consumers’ right to cancel the contract 

without penalty or obligation at any time before the third business day after the date 

on which the consumer signed the contract; 

E. Failing to provide any Person with a separate form with the heading 

“Notice of Cancellation,” in the form and manner required by 15 U.S.C. § 1679e(b); 

and 

F. Failing to provide any Person with a copy of a completed contract and 

all disclosures required under CROA, 15 U.S.C. §§ 1679-1679j, and a copy of any 

other document such Person is required to sign. 

II. PROHIBITED BUSINESS ACTIVITES 

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 or services, are 

temporarily restrained and enjoined from: 

A. Making any Earnings Claim, unless the Earnings Claim is nonmisleading, and, at the time such claim is made, Defendants: 1) have a reasonable 

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basis for their claim; 2) have in their possession written materials that substantiate 

the claim; and 3) make the written substantiation available upon request to the 

consumer, potential purchaser, investor, the Receiver, or to the FTC; 

B. Failing to provide any consumer, potential purchaser, or investor with 

disclosure documents in the form and manner required by 16 C.F.R. §§ 437.2, 

437.3(a)(1)-(5), and 437.4; 

C. Misrepresenting or assisting others in misrepresenting, expressly or by 

implication: 

1. Any refund, money-back guarantee, or cancellation policy; 

2. That Defendants’ practices or advised practices are legal; 

3. That consumers, using Defendants’ products and services, are 

likely to profitably and legally operate a business selling credit 

repair services and education; 

4. Any other fact material to consumers concerning any good or 

service, such as: the total costs; any material restrictions, 

limitations, or conditions; or any material aspect of its 

performance, efficacy, nature, or central characteristics. 

III. 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 

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indirectly, are hereby temporarily restrained and enjoined from disclosing, using, 

transferring, or benefitting from customer information, including the name, address, 

telephone number, email address, birth date, social security number, other 

identifying information, or any data that enables access to a customer’s account 

(including a credit card, bank account, or other financial account), that any 

Defendant obtained prior to entry 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. 

IV. ASSET FREEZE 

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

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

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

indirectly, are hereby temporarily restrained and enjoined from: 

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

selling, concealing, dissipating, disbursing, assigning, relinquishing, spending, 

withdrawing, 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; 

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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 signor; 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. This Section does not 

prohibit any transfers to the Receiver or repatriation of foreign Assets specifically 

required by this order. SPECIAL NOTE: Provisions shall be made to allow the 

Individual Defendants to incur reasonable personal expenses during the pendency 

of this Order. Provision shall also be made to allow Defendants to hire counsel to 

represent them in this action. 

V. DUTIES OF ASSET HOLDERS AND OTHER THIRD PARTIES 

IT IS FURTHER ORDERED that any financial or brokerage institution, 

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

acquiring bank, independent sales organization, third party processor, payment 

gateway, insurance company, business entity, or person who receives actual notice 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; 

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(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 

organizations, third party processors, 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; provided, however, that this provision 

does not prohibit an Individual Defendant from incurring charges on a personal 

credit card established prior to entry of this Order, up to the pre-existing credit limit; 

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

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

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

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

receiving a copy of this Order, a sworn statement setting forth, for each Asset or 

account covered by this Section: 

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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 

Documents pertaining to each 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. 

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

Receiver or repatriation of foreign Assets specifically required by this order. 

VI. 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 

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

Return) for each Individual and Corporate Defendant. 

VII. FOREIGN ASSET REPATRIATION 

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

of this Order, each 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, 

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

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

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

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

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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 Plaintiff’s counsel and the Receiver 

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 all Documents and Assets 

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

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

or for the benefit of, any corporation, partnership, asset protection trust, or other 

entity that is directly or indirectly owned, managed or controlled by any Defendant; 

or (3) under the direct or indirect control, whether jointly or singly, of any 

Defendant; and 

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

counsel for Plaintiff 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. 

VIII. NON-INTERFERENCE WITH REPATRIATION 

IT IS FURTHER ORDERED that Defendants, Defendants’ officers, agents, 

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

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

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indirectly, are hereby temporarily restrained and enjoined from taking any action, 

directly or indirectly, which may result in the encumbrance or dissipation of foreign 

Assets, or in the hindrance 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. 

IX. 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. 

X. PRESERVATION OF RECORDS 

IT IS FURTHER ORDERED that Defendants, Defendants’ officers, agents, 

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

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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) 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. 

XI. PRESERVATION OF RECORDS BY THIRD PARTIES 

IT IS FURTHER ORDERED that any person who receives actual notice of this 

Order (by service or otherwise) that has held, controlled, or maintained custody of 

any Document on behalf of any Defendant that relates to the business or business 

practices of any Defendant or of any entity directly or indirectly under the control of 

any Defendant are hereby temporarily restrained and enjoined from destroying, 

erasing, falsifying, writing over, mutilating, concealing, altering, transferring, or 

otherwise disposing of, in any manner, directly or indirectly, any such Documents. 

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XII. 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. 

XIII. TEMPORARY RECEIVER 

IT IS FURTHER ORDERED that Maria M. Yip is appointed as temporary 

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

Receiver shall be solely the agent of this Court in acting as Receiver under this 

Order. 

XIV. 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 Receivership Entities by removing, as the 

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

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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, wherever situated; 

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; 

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

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

value of those Assets. The Receiver shall assume control over the income and profits 

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

Entities. The Receiver shall have full power to sue for, collect, and receive, all Assets 

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

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

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

consumer if the Receiver believes the consumer’s debt to the Receivership Entities 

has resulted from the deceptive acts or practices or other violations of law alleged in 

the Complaint in this matter, without prior Court approval; 

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E. 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. 

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

other independent contractors and technical specialists, as the Receiver deems 

advisable or necessary in the performance of duties and responsibilities under the 

authority granted by this Order; 

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

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

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

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

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

obligation incurred by the Receivership Entities prior to the date of entry of this 

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Order, except payments that the Receiver deems necessary or advisable to secure 

Assets of the Receivership Entities, such as rental payments; 

H. 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. Law enforcement personnel, including, but not 

limited to, police or sheriffs, may assist the Receiver in implementing these 

provisions in order to keep the peace and maintain security. If requested by the 

Receiver, the United States Marshal will provide appropriate and necessary 

assistance to the Receiver to implement this Order and is authorized to use any 

necessary and reasonable force to do so; 

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

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

any Defendants, and to provide access to all such web page or websites to Plaintiff’s 

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

representatives; 

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

necessary; 

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

protect the interests of consumers who have transacted business with the 

Receivership Entities; 

L. 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; 

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

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

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

recover the Assets of the Receivership Entities, or to carry out the Receiver’s 

mandate under this Order, including but not limited to, actions challenging 

fraudulent or voidable transfers; 

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

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

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

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

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

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

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

monthly account statements on all parties; 

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

Receiver; 

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

Defendants’ representatives and Defendants themselves, reasonable access to the 

premises of 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; 

R. Allow the 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; 

S. Cooperate with reasonable requests for information or assistance from 

any state or federal civil or criminal law enforcement agency; 

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

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

U. 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 

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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; 

V. 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 

W. Prepare a written report at or before any hearing described in Paragraph 

XXVII, that describes (1) the steps taken by the Receiver to implement the terms of 

the Order; (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 

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

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

XV. TRANSFER OF RECEIVERSHIP PROPERTY TO RECEIVER 

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

possession, custody or control of property of, or records relating to, the Receivership 

Entities 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 

immediately transfer or deliver to the Receiver possession, custody, and control of, 

the following: 

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

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

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

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, including 

all communications occurring via electronic mail, electronic messaging service, or 

encrypted messaging service (including but not limited to Signal or WhatsApp); 

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

conduct the business of the Receivership Entities, even if such computers, electronic 

devices, mobile devices, and machines are also used for non-business purposes; 

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 and passwords necessary to gain or to 

secure access to any Assets or Documents of or pertaining to the Receivership 

Entities, including access to their business premises, means of communication, 

accounts, computer systems (onsite and remote), Electronic Data Hosts, encrypted 

messaging services, or other property. 

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

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

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

motion seeking compliance or a contempt citation. 

XVI. PROVISION OF INFORMATION TO RECEIVER 

IT IS FURTHER ORDERED that Defendants shall 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; 

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B. 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 

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

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

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

electronic documents. 

XVII. 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 property of or records relating to the 

Receivership Entities who receive actual notice of this Order shall fully cooperate 

with and assist the Receiver. This cooperation and assistance shall include, but is not 

limited to, providing information to the Receiver that the Receiver deems necessary 

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

Order; providing any keys, codes, user names and passwords required to access any 

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

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Receiver’s direction and producing records related to the Assets and sales of the 

Receivership Entities. 

XVIII. 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; 

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

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

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

Receivership Entities; or 

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

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

Court. 

XIX. 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 

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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, 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; or 

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; or attempting to foreclose, forfeit, alter, or terminate any 

interest in any Asset of the Receivership Entities, 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 

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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. 

XX. 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. 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. 

XXI. RECEIVER’S BOND 

IT IS FURTHER ORDERED that the Receiver is not required to file with the 

Clerk of this Court a bond until further order of this 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. 

XXII. IMMEDIATE ACCESS TO BUSINESS PREMISES AND RECORDS 

IT IS FURTHER ORDERED that: 

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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, 13107 

Atlantic Blvd, suite 201 Jacksonville, FL 32225, and 13475 Atlantic Blvd., Unit 8, 

Jacksonville, FL 32225, 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; 

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

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

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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 

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. 

XXIII. 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, 

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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, and provide Plaintiff 

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

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. 

XXIV. EXPEDITED DISCOVERY 

IT IS FURTHER ORDERED that, notwithstanding the provisions of the 

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

30(a), 33, 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; (2) the 

nature, location, and extent of Defendants’ business transactions and operations; (3) 

Documents reflecting Defendants’ business transactions and operations; or (4) 

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

shall proceed as follows: 

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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)(A) and 31(a)(2)(A) 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. 

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

require response within five (5) days of service. 

D. The 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 

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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. 

XXV. SERVICE OF THIS ORDER 

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

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

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

may be served by any means, including facsimile transmission, electronic mail or 

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

agents and employees of 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. 

XXVI. 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: 

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Hong Park 

Brian M. Welke 

Sana Chaudhry 

FEDERAL TRADE COMMISSION 

600 Pennsylvania Avenue NW, CC 9528 

Washington, DC 20580 

Telephone: 202-326-2158 (Park); -2897 (Welke); -2679 (Chaudhry) 

Facsimile: 202-326-3768 

Email: hpark@ftc.gov; bwelke@ftc.gov; schaudhry@ftc.gov 

XXVII. PRELIMINARY INJUNCTION HEARING 

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

Defendants shall appear on May 12th, 2022, at 4:30 PM, before the undersigned, in 

the United States Courthouse, Courtroom 10D, 300 North Hogan Street, 

Jacksonville, Florida,

1 to show cause 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 their Assets, 

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

appropriate. The temporary receiver is also directed to appear in person at the 

hearing. 

XXVIII. BRIEFS AND AFFIDAVITS CONCERNING PRELIMINARY 

INJUNCTION 

IT IS FURTHER ORDERED that: 

1 All persons entering the Courthouse must present photo identification to Court 

Security Officers. Although cell phones, laptop computers, and similar electronic 

devices are not generally allowed in the building, counsel are permitted to bring 

those items with them upon presentation to Court Security Officers of this Order. 

The parties are also advised to consult the Court’s current coronavirus protocols, 

which are posted on the Court’s website, www.flmd.uscourts.gov. 

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

response to Plaintiff’s Motion no later than May 10, 2022. Filings must be served by 

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

no later than 5:00 p.m. Eastern Time on the appropriate dates set forth in this 

Section. 

G. The May 12, 2022 hearing will be a non-evidentiary hearing. 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. 

Any motion to permit such testimony may be raised at the May 12, 2022 hearing, 

after which the Court will determine whether an evidentiary hearing is necessary. 

XXIX. RULING ON THE MOTION 

IT IS FURTHER ORDERED that, as described herein, the FTC’s Ex Parte 

Motion for Temporary Restraining Order with Asset Freeze, Immediate Access to 

Documents and Premises, and Appointment of a Receiver with Order to Show 

Cause Why the Court Should not Issue a Preliminary Injunction (Dkt. #4) is 

GRANTED. 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). 

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Case 3:22-cv-00487-TJC-MCR *SEALED* Document 12 Filed 05/03/22 Page 42 of 42 PageID 

305 

XXX. RETENTION OF JURISDICTION 

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

matter for all purposes. 

XXXI. ADMONITION 

This Order gives the FTC broad temporary relief. While the Court believes 

this to be an appropriate use of the Court’s equitable authority, the Court 

cautions the FTC and the Receiver to act appropriately in their interactions with 

Defendants and to exercise the authority given by this Order judiciously. 

SO ORDERED, this 3rd day of May, 2022 at 3:58 PM. 

Copies to: 

Counsel of Record 

Defendants 

42 
Case 3:22-cv-00487-TJC-MCR *SEALED* Document 12-1 Filed 05/03/22 Page 1 of 33 

PageID 306 

Attachment A 
 

FEDERAL TRADE COMMISSION 

FINANCIAL STATEMENT OF INDIVIDUAL DEFENDANT 

Case 3:22-cv-00487-TJC-MCR *SEALED* Document 12-1 Filed 05/03/22 Page 2 of 33 

PageID 307

Definitions and Instructions: 

1. Complete all items. Enter “None” or “N/A” (“Not Applicable”) in the first field only of any item that does not apply 

to you. If you cannot fully answer a question, explain why. 

2. “Dependents” include your spouse, live-in companion, dependent children, or any other person, whom you or your 

spouse (or your children’s other parent) claimed or could have claimed as a dependent for tax purposes at any 

time during the past five years. 

3. “Assets” and “Liabilities” include ALL assets and liabilities, located within the United States or any foreign country 

or territory, whether held individually or jointly and whether held by you, your spouse, or your dependents, or held 

by others for the benefit of you, your spouse, or your dependents. 

4. Attach continuation pages as needed. On the financial statement, state next to the Item number that the Item is 

being continued. On the continuation page(s), identify the Item number(s) being continued. 

5. Type or print legibly. 

6. Initial each page in the space provided in the lower right corner. 

7. Sign and date the completed financial statement on the last page. 

Penalty for False Information: 

Federal law provides that any person may be imprisoned for not more than five years, fined, or both, if such person: 

(1) “in any matter within the jurisdiction of the executive, legislative, or judicial branch of the Government of the 

United States, knowingly and willfully falsifies, conceals or covers up by any trick, scheme, or devise a material fact; 

makes any materially false, fictitious or fraudulent statement or representation; or makes or uses any false writing or 

document knowing the same to contain any materially false, fictitious or fraudulent statement or entry” (18 U.S.C. § 1001); 

(2) “in any . . . statement under penalty of perjury as permitted under section 1746 of title 28, United States Code, 

willfully subscribes as true any material matter which he does not believe to be true” (18 U.S.C. § 1621); or 

(3) “in any ( . . . statement under penalty of perjury as permitted under section 1746 of title 28, United States 

Code) in any proceeding before or ancillary to any court or grand jury of the United States knowingly makes any false 

material declaration or makes or uses any other information . . . knowing the same to contain any false material 

declaration” (18 U.S.C. § 1623). 

For a felony conviction under the provisions cited above, federal law provides that the fine may be not more than the 

greater of (i) $250,000 for an individual or $500,000 for a corporation, or (ii) if the felony results in pecuniary gain to any 

person or pecuniary loss to any person other than the defendant, the greater of twice the gross gain or twice the gross 

loss. 18 U.S.C. § 3571. 

Federal Trade Commission Financial Statement of Individual Defendant 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Case 3:22-cv-00487-TJC-MCR *SEALED* Document 12-1 Filed 05/03/22 Page 3 of 33 

PageID 308 BACKGROUND INFORMATION 

Item 1. Information About You 

Full Name Social Security No. 

Current Address of Primary Residence Driver’s License No. State Issued 

Phone Numbers 

Home: ( ) 

Fax: ( ) 

Date of Birth: / / 

(mm/dd/yyyy) 

Place of Birth 

Rent Own From (Date): / / 

(mm/dd/yyyy) 

E-Mail Address 

Internet Home Page 

Previous Addresses for past five years (if required, use additional pages at end of form) 

Address From: / / Until: / / 

(mm/dd/yyyy) (mm/dd/yyyy) 

Rent Own 

Address From: / / Until: / / 

Rent Own 

Address From: / / Until: / / 

Rent Own 

Identify any other name(s) and/or social security number(s) you have used, and the time period(s) during which they 

were used: 

Item 2. Information About Your Spouse or Live-In Companion 

Spouse/Companion's Name Social Security No. Date of Birth 

/ / 

(mm/dd/yyyy) 

Address (if different from yours) Phone Number 

( ) 

Place of Birth 

Rent Own From (Date): / / 

(mm/dd/yyyy) 

Identify any other name(s) and/or social security number(s) you have used, and the time period(s) during which they were used: 

Employer’s Name and Address Job Title 

Years in Present Job Annual Gross Salary/Wages 

$ 

Item 3. Information About Your Previous Spouse 

Name and Address Social Security No. 

Date of Birth 

/ / 

(mm/dd/yyyy) 

Item 4. Contact Information (name and address of closest living relative other than your spouse) 

Name and Address Phone Number 

( ) 

Initials: 

1 of 10 Federal Trade Commission Financial Statement of Individual Defendant 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Case 3:22-cv-00487-TJC-MCR *SEALED* Document 12-1 Filed 05/03/22 Page 4 of 33 

PageID 309 

Item 5. Information About Dependents (whether or not they reside with you) 

Name and Address Social Security No. Date of Birth 

/ / 

(mm/dd/yyyy) 

Relationship 

Name and Address Social Security No. Date of Birth 

/ / 

(mm/dd/yyyy) 

Relationship 

Name and Address Social Security No. Date of Birth 

/ / 

(mm/dd/yyyy) 

Relationship 

Name and Address Social Security No. Date of Birth 

/ / 

(mm/dd/yyyy) 

Relationship 

Item 6. Employment Information/Employment Income

Provide the following information for this year-to-date and for each of the previous five full years, for each business entity of which you were a director, 

officer, member, partner, employee (including self-employment), agent, owner, shareholder, contractor, participant or consultant at any time during that 

period. “Income” includes, but is not limited to, any salary, commissions, distributions, draws, consulting fees, loans, loan payments, dividends, 

royalties, and benefits for which you did not pay (e.g., health insurance premiums, automobile lease or loan payments) received by you or anyone else 

on your behalf. 

Company Name and Address 

Ownership Interest? Yes No 

Dates Employed Income Received: Y-T-D & 5 Prior Yrs. 

From (Month/Year) 

/ 

To (Month/Year) 

/ 

Year Income 

20 $ 

$ 

$ 

$ 

$ 

$ 

Positions Held From (Month/Year) To (Month/Year) 

/ / 

/ / 

/ / 

Company Name and Address 

Ownership Interest? Yes No 

Dates Employed Income Received: Y-T-D & 5 Prior Yrs. 

From (Month/Year) 

/ 

To (Month/Year) 

/ 

Year Income 

20 $ 

$ 

$ 

$ 

$ 

$ 

Positions Held From (Month/Year) To (Month/Year) 

/ / 

/ / 

/ / 

Company Name and Address 

Ownership Interest? Yes No 

Dates Employed Income Received: Y-T-D & 5 Prior Yrs. 

From (Month/Year) 

/ 

To (Month/Year) 

/ 

Year Income 

20 $ 

$ 

$ 

$ 

$ 

$ 

Positions Held From (Month/Year) To (Month/Year) 

/ / 

/ / 

/ / 

Initials: 

2 of 10 Federal Trade Commission Financial Statement of Individual Defendant 
 

 

 

Case 3:22-cv-00487-TJC-MCR *SEALED* Document 12-1 Filed 05/03/22 Page 5 of 33 

PageID 310 

Item 7. Pending Lawsuits Filed By or Against You or Your Spouse

List all pending lawsuits that have been filed by or against you or your spouse in any court or before an administrative agency in the United States or in 

any foreign country or territory. Note: At Item 12, list lawsuits that resulted in final judgments or settlements in your favor. At Item 21, list lawsuits that 

resulted in final judgments or settlements against you. 

Caption of Proceeding Court or Agency and Location Case No. Nature of 

Proceeding Relief Requested Status or Disposition 

Item 8. Safe Deposit Boxes 

List all safe deposit boxes, located within the United States or in any foreign country or territory, whether held individually or jointly and whether held by 

you, your spouse, or any of your dependents, or held by others for the benefit of you, your spouse, or any of your dependents. 

Name of Owner(s) Name & Address of Depository Institution Box No. Contents 

Initials: 

3 of 10 Federal Trade Commission Financial Statement of Individual Defendant 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Case 3:22-cv-00487-TJC-MCR *SEALED* Document 12-1 Filed 05/03/22 Page 6 of 33 

PageID 311 

FINANCIAL INFORMATION 

REMINDER: When an item asks for information regarding your “assets” and “liabilities” include ALL assets and liabilities, located within 

the United States or in any foreign country or territory, or institution, whether held individually or jointly, and whether held by you, your 

spouse, or any of your dependents, or held by others for the benefit of you, your spouse, or any of your dependents. In addition, provide 

all documents requested in Item 24 with your completed Financial Statement. 

ASSETS 

Item 9. Cash, Bank, and Money Market Accounts 

List cash on hand (as opposed to cash in bank accounts or other financial accounts) and all bank accounts, money market accounts, or other financial 

accounts, including but not limited to checking accounts, savings accounts, and certificates of deposit. The term “cash on hand” includes but is not 

limited to cash in the form of currency, uncashed checks, and money orders. 

a. Amount of Cash on Hand $ Form of Cash on Hand 

b. Name on Account Name & Address of Financial Institution Account No. Current Balance 

$ 

$ 

$ 

$ 

$ 

Item 10. Publicly Traded Securities

List all publicly traded securities, including but not limited to, stocks, stock options, corporate bonds, mutual funds, U.S. government securities (including 

but not limited to treasury bills and treasury notes), and state and municipal bonds. Also list any U.S. savings bonds. 

Owner of Security Issuer Type of Security No. of Units Owned 

Broker House, Address Broker Account No. 

Current Fair Market Value 

$ 

Loan(s) Against Security 

$ 

Owner of Security Issuer Type of Security No. of Units Owned 

Broker House, Address Broker Account No. 

Current Fair Market Value 

$ 

Loan(s) Against Security 

$ 

Owner of Security Issuer Type of Security No. of Units Owned 

Broker House, Address Broker Account No. 

Current Fair Market Value 

$ 

Loan(s) Against Security 

$ 

Initials: 

4 of 10 Federal Trade Commission Financial Statement of Individual Defendant 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Case 3:22-cv-00487-TJC-MCR *SEALED* Document 12-1 Filed 05/03/22 Page 7 of 33 

PageID 312 

Item 11. Non-Public Business and Financial Interests 

List all non-public business and financial interests, including but not limited to any interest in a non-public corporation, subchapter-S corporation, limited 

liability corporation (“LLC”), general or limited partnership, joint venture, sole proprietorship, international business corporation or personal investment 

corporation, and oil or mineral lease. 

Entity’s Name & Address Type of Business or Financial 

Interest (e.g., LLC, partnership) 

Owner 

(e.g., self, spouse) 

Ownership 

% 

If Officer, Director, Member 

or Partner, Exact Title 

Item 12. Amounts Owed to You, Your Spouse, or Your Dependents 

Debtor’s Name & Address Date Obligation 

Incurred (Month/Year) 

/ 

Original Amount Owed 

$ 

Nature of Obligation (if the result of a final court 

judgment or settlement, provide court name 

and docket number) 

Current Amount Owed 

$ 

Payment Schedule 

$ 

Debtor’s Telephone Debtor’s Relationship to You 

Debtor’s Name & Address Date Obligation 

Incurred (Month/Year) 

/ 

Original Amount Owed 

$ 

Nature of Obligation (if the result of a final court 

judgment or settlement, provide court name 

and docket number) 

Current Amount Owed 

$ 

Payment Schedule 

$ 

Debtor’s Telephone Debtor’s Relationship to You 

Item 13. Life Insurance Policies 

List all life insurance policies (including endowment policies) with any cash surrender value. 

Insurance Company’s Name, Address, & Telephone No. Beneficiary Policy No. Face Value 

$ 

Insured Loans Against Policy 

$ 

Surrender Value 

$ 

Insurance Company’s Name, Address, & Telephone No. Beneficiary Policy No. Face Value 

$ 

Insured Loans Against Policy 

$ 

Surrender Value 

$ 

Item 14. Deferred Income Arrangements 

List all deferred income arrangements, including but not limited to, deferred annuities, pensions plans, profit-sharing plans, 401(k) plans, IRAs, Keoghs, 

other retirement accounts, and college savings plans (e.g., 529 Plans). 

Trustee or Administrator’s Name, Address & Telephone No. Name on Account Account No. 

Date Established 

/ / 

(mm/dd/yyyy) 

Type of Plan Surrender Value before 

Taxes and Penalties 

$ 

Trustee or Administrator’s Name, Address & Telephone No. Name on Account Account No. 

Date Established 

/ / 

Type of Plan Surrender Value before 

Taxes and Penalties 

$ 

Initials: 

5 of 10 Federal Trade Commission Financial Statement of Individual Defendant 
 

 

 

 

 

 

 

 

Case 3:22-cv-00487-TJC-MCR *SEALED* Document 12-1 Filed 05/03/22 Page 8 of 33 

PageID 313 Item 15. Pending Insurance Payments or Inheritances

List any pending insurance payments or inheritances owed to you. 

Type Amount Expected Date Expected (mm/dd/yyyy) 

$ / / 

$ / / 

$ / / 

Item 16. Vehicles 

List all cars, trucks, motorcycles, boats, airplanes, and other vehicles. 

Vehicle Type Year Registered Owner’s Name Purchase Price 

$ 

Original Loan Amount 

$ 

Current Balance 

$ 

Make Registration State & No. Account/Loan No. Current Value 

$ 

Monthly Payment 

$ 

Model Address of Vehicle’s Location Lender’s Name and Address 

Vehicle Type Year Registered Owner’s Name Purchase Price 

$ 

Original Loan Amount 

$ 

Current Balance 

$ 

Make Registration State & No. Account/Loan No. Current Value 

$ 

Monthly Payment 

$ 

Model Address of Vehicle’s Location Lender’s Name and Address 

Vehicle Type Year Registered Owner’s Name Purchase Price 

$ 

Original Loan Amount 

$ 

Current Balance 

$ 

Make Registration State & No. Account/Loan No. Current Value 

$ 

Monthly Payment 

$ 

Model Address of Vehicle’s Location Lender’s Name and Address 

Vehicle Type Year Registered Owner’s Name Purchase Price 

$ 

Original Loan Amount 

$ 

Current Balance 

$ 

Make Registration State & No. Account/Loan No. Current Value 

$ 

Monthly Payment 

$ 

Model Address of Vehicle’s Location Lender’s Name and Address 

Item 17. Other Personal Property 

List all other personal property not listed in Items 9-16 by category, whether held for personal use, investment or any other reason, including but not 

limited to coins, stamps, artwork, gemstones, jewelry, bullion, other collectibles, copyrights, patents, and other intellectual property. 

Property Category 

(e.g., artwork, jewelry) Name of Owner Property Location Acquisition Cost Current Value 

$ $ 

$ $ 

$ $ 

Initials: 

6 of 10 Federal Trade Commission Financial Statement of Individual Defendant 
 

 

 

 

 

 

 

 

 

 

 

 

Case 3:22-cv-00487-TJC-MCR *SEALED* Document 12-1 Filed 05/03/22 Page 9 of 33 

PageID 314 Item 18. Real Property

List all real property interests (including any land contract) 

Property’s Location Type of Property Name(s) on Title or Contract and Ownership Percentages 

Acquisition Date (mm/dd/yyyy) 

/ / 

Purchase Price 

$ 

Current Value 

$ 

Basis of Valuation 

Lender’s Name and Address Loan or Account No. Current Balance On First Mortgage or 

Contract 

$ 

Monthly Payment 

$ 

Other Mortgage Loan(s) (describe) Monthly Payment 

$ 

Rental Unit 

Monthly Rent Received 

$ 

Current Balance 

$ 

Property’s Location Type of Property Name(s) on Title or Contract and Ownership Percentages 

Acquisition Date (mm/dd/yyyy) 

/ / 

Purchase Price 

$ 

Current Value 

$ 

Basis of Valuation 

Lender’s Name and Address Loan or Account No. Current Balance On First Mortgage or 

Contract 

$ 

Monthly Payment 

$ 

Other Mortgage Loan(s) (describe) Monthly Payment 

$ 

Rental Unit 

Monthly Rent Received 

$ 

Current Balance 

$ 

LIABILITIES 

Item 19. Credit Cards 

List each credit card account held by you, your spouse, or your dependents, and any other credit cards that you, your spouse, or your dependents use, 

whether issued by a United States or foreign financial institution. 

Name of Credit Card (e.g., Visa, 

MasterCard, Department Store) Account No. Name(s) on Account Current Balance 

$ 

$ 

$ 

$ 

$ 

Item 20. Taxes Payable 

List all taxes, such as income taxes or real estate taxes, owed by you, your spouse, or your dependents. 

Type of Tax Amount Owed Year Incurred 

$ 

$ 

$ 

Initials: 

7 of 10 Federal Trade Commission Financial Statement of Individual Defendant 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Case 3:22-cv-00487-TJC-MCR *SEALED* Document 12-1 Filed 05/03/22 Page 10 of 33 

PageID 315 Item 21. Other Amounts Owed by You, Your Spouse, or Your Dependents 

List all other amounts, not listed elsewhere in this financial statement, owed by you, your spouse, or your dependents. 

Lender/Creditor’s Name, Address, and Telephone No. Nature of Debt (if the result of a court judgment or settlement, provide court name and docket 

number) 

Lender/Creditor’s Relationship to You 

Date Liability Was Incurred 

/ / 

(mm/dd/yyyy) 

Original Amount Owed 

$ 

Current Amount Owed 

$ 

Payment Schedule 

Lender/Creditor’s Name, Address, and Telephone No. Nature of Debt (if the result of a court judgment or settlement, provide court name and docket 

number) 

Lender/Creditor’s Relationship to You 

Date Liability Was Incurred 

/ / 

(mm/dd/yyyy) 

Original Amount Owed 

$ 

Current Amount Owed 

$ 

Payment Schedule 

OTHER FINANCIAL INFORMATION 

Item 22. Trusts and Escrows 

List all funds and other assets that are being held in trust or escrow by any person or entity for you, your spouse, or your dependents. Include any legal 

retainers being held on your behalf by legal counsel. Also list all funds or other assets that are being held in trust or escrow by you, your spouse, or your 

dependents, for any person or entity. 

Trustee or Escrow Agent’s Name & Address Date Established 

(mm/dd/yyyy) Grantor Beneficiaries Present Market Value of Assets* 

/ / $ 

/ / $ 

/ / $ 

*If the market value of any asset is unknown, describe the asset and state its cost, if you know it. 

Item 23. Transfers of Assets 

List each person or entity to whom you have transferred, in the aggregate, more than $5,000 in funds or other assets during the previous five years by 

loan, gift, sale, or other transfer (exclude ordinary and necessary living and business expenses paid to unrelated third parties). For each such person or 

entity, state the total amount transferred during that period. 

Transferee’s Name, Address, & Relationship Property Transferred Aggregate Value* Transfer Date 

(mm/dd/yyyy) 

Type of Transfer 

(e.g., Loan, Gift) 

$ / / 

$ / / 

$ / / 

*If the market value of any asset is unknown, describe the asset and state its cost, if you know it. 

Initials: 

8 of 10 Federal Trade Commission Financial Statement of Individual Defendant 
 

 

 

 

 

 

 

 

 

 

 

Case 3:22-cv-00487-TJC-MCR *SEALED* Document 12-1 Filed 05/03/22 Page 11 of 33 

PageID 316 Item 24. Document Requests

Provide copies of the following documents with your completed Financial Statement. 

Federal tax returns filed during the last three years by or on behalf of you, your spouse, or your dependents. 

All applications for bank loans or other extensions of credit (other than credit cards) that you, your spouse, or your 

dependents have submitted within the last two years, including by obtaining copies from lenders if necessary. 

Item 9 For each bank account listed in Item 9, all account statements for the past 3 years. 

Item 11 

For each business entity listed in Item 11, provide (including by causing to be generated from accounting records) the 

most recent balance sheet, tax return, annual income statement, the most recent year-to-date income statement, and all 

general ledger files from account records. 

Item 17 

All appraisals that have been prepared for any property listed in Item 17, including appraisals done for insurance 

purposes. You may exclude any category of property where the total appraised value of all property in that category is 

less than $2,000. 

Item 18 All appraisals that have been prepared for real property listed in Item 18. 

Item 21 Documentation for all debts listed in Item 21. 

Item 22 All executed documents for any trust or escrow listed in Item 22. Also provide any appraisals, including insurance 

appraisals that have been done for any assets held by any such trust or in any such escrow. 

SUMMARY FINANCIAL SCHEDULES 

Item 25. Combined Balance Sheet for You, Your Spouse, and Your Dependents 

Assets Liabilities 

Cash on Hand (Item 9) $ Loans Against Publicly Traded Securities (Item 10) $ 

Funds Held in Financial Institutions (Item 9) $ Vehicles - Liens (Item 16) $ 

U.S. Government Securities (Item 10) $ Real Property – Encumbrances (Item 18) $ 

Publicly Traded Securities (Item 10) $ Credit Cards (Item 19) $ 

Non-Public Business and Financial Interests (Item 11) $ Taxes Payable (Item 20) $ 

Amounts Owed to You (Item 12) $ Amounts Owed by You (Item 21) $ 

Life Insurance Policies (Item 13) $ Other Liabilities (Itemize) 

Deferred Income Arrangements (Item 14) $ $ 

Vehicles (Item 16) $ $ 

Other Personal Property (Item 17) $ $ 

Real Property (Item 18) $ $ 

Other Assets (Itemize) $ 

$ $ 

$ $ 

$ $ 

Total Assets $ Total Liabilities $ 

Item 26. Combined Current Monthly Income and Expenses for You, Your Spouse, and Your Dependents 

Provide the current monthly income and expenses for you, your spouse, and your dependents. Do not include credit card payments separately; rather, 

include credit card expenditures in the appropriate categories. 

Income (State source of each item) Expenses 

Salary - After Taxes 

Source: $ Mortgage or Rental Payments for Residence(s) $ 

Fees, Commissions, and Royalties 

Source: $ Property Taxes for Residence(s) $ 

Interest 

Source: $ Rental Property Expenses, Including Mortgage Payments, Taxes, 

and Insurance $ 

Dividends and Capital Gains 

Source: $ Car or Other Vehicle Lease or Loan Payments $ 

Gross Rental Income 

Source: $ Food Expenses $ 

Profits from Sole Proprietorships 

Source: $ Clothing Expenses $ 

Distributions from Partnerships, S-Corporations, 

and LLCs 

Source: 

$ 

Utilities 

$ 

Initials: 

9 of 10 Federal Trade Commission Financial Statement of Individual Defendant 
 

 

 

 

 

 

_______________ ___________________________________ 

Case 3:22-cv-00487-TJC-MCR *SEALED* Document 12-1 Filed 05/03/22 Page 12 of 33 

PageID 317 Item 26. Combined Current Monthly Income and Expenses for You, Your Spouse, and Your Dependents (cont.) 

Distributions from Trusts and Estates 

Source: $ Medical Expenses, Including Insurance $ 

Distributions from Deferred Income Arrangements 

Source: $ 

Other Insurance Premiums 

$ 

Social Security Payments $ Other Transportation Expenses $ 

Alimony/Child Support Received $ Other Expenses (Itemize) 

Gambling Income $ $ 

Other Income (Itemize) $ 

$ $ 

$ $ 

$ $ 

Total Income $ Total Expenses $ 

ATTACHMENTS 

Item 27. Documents Attached to this Financial Statement 

List all documents that are being submitted with this financial statement. For any Item 24 documents that are not attached, explain why. 

Item No. Document Relates To Description of Document 

I am submitting this financial statement with the understanding that it may affect action by the Federal Trade 

Commission or a federal court. I have used my best efforts to obtain the information requested in this statement. The 

responses I have provided to the items above are true and contain all the requested facts and information of which I have 

notice or knowledge. I have provided all requested documents in my custody, possession, or control. I know of the 

penalties for false statements under 18 U.S.C. § 1001, 18 U.S.C. § 1621, and 18 U.S.C. § 1623 (five years imprisonment 

and/or fines). I certify under penalty of perjury under the laws of the United States that the foregoing is true and correct. 

Executed on: 

(Date) Signature 

 10 of 10 Federal Trade Commission Financial Statement of Individual Defendant 
Case 3:22-cv-00487-TJC-MCR *SEALED* Document 12-1 Filed 05/03/22 Page 13 of 33 

PageID 318 

Attachment B 
Case 3:22-cv-00487-TJC-MCR *SEALED* Document 12-1 Filed 05/03/22 Page 14 of 33 

PageID 319

FEDERAL TRADE COMMISSION 

FINANCIAL STATEMENT OF CORPORATE DEFENDANT 

Instructions: 

1. Complete all items. Enter “None” or "N/A" (“Not Applicable”) where appropriate. If you cannot fully answer a 

question, explain why. 

2. The font size within each field will adjust automatically as you type to accommodate longer responses. 

3. In completing this financial statement, “the corporation” refers not only to this corporation but also to each of its 

predecessors that are not named defendants in this action. 

4. When an Item asks for information about assets or liabilities “held by the corporation,” include ALL such assets 

and liabilities, located within the United States or elsewhere, held by the corporation or held by others for the 

benefit of the corporation. 

5. Attach continuation pages as needed. On the financial statement, state next to the Item number that the Item is 

being continued. On the continuation page(s), identify the Item number being continued. 

6. Type or print legibly. 

7. An officer of the corporation must sign and date the completed financial statement on the last page and initial 

each page in the space provided in the lower right corner. 

Penalty for False Information: 

Federal law provides that any person may be imprisoned for not more than five years, fined, or both, if such person: 

(1) “in any matter within the jurisdiction of any department or agency of the United States knowingly and 

willfully falsifies, conceals or covers up by any trick, scheme, or device a material fact, or makes any false, 

fictitious or fraudulent statements or representations, or makes or uses any false writing or document knowing the 

same to contain any false, fictitious or fraudulent statement or entry” (18 U.S.C. § 1001); 

(2) “in any . . . statement under penalty of perjury as permitted under section 1746 of title 28, United States Code, 

willfully subscribes as true any material matter which he does not believe to be true” (18 U.S.C. § 1621); or 

(3) “in any (. . . statement under penalty of perjury as permitted under section 1746 of title 28, United States 

Code) in any proceeding before or ancillary to any court or grand jury of the United States knowingly makes any 

false material declaration or makes or uses any other information . . . knowing the same to contain any false 

material declaration.” (18 U.S.C. § 1623) 

For a felony conviction under the provisions cited above, federal law provides that the fine may be not more than the 

greater of (i) $250,000 for an individual or $500,000 for a corporation, or (ii) if the felony results in pecuniary gain to any 

person or pecuniary loss to any person other than the defendant, the greater of twice the gross gain or twice the gross loss. 

18 U.S.C. § 3571. 
Case 3:22-cv-00487-TJC-MCR *SEALED* Document 12-1 Filed 05/03/22 Page 15 of 33 

PageID 320 

BACKGROUND INFORMATION 

Item 1. General Information 

Corporation’s Full Name ___________________________________________________________________________ 

Primary Business Address ______________________________________________________ From (Date) _________ 

Telephone No. _____________________________ Fax No. _____________________________

 E-Mail Address________________________ Internet Home Page________________________ 

All other current addresses & previous addresses for past five years, including post office boxes and mail drops: 

Address____________________________________________________________ From/Until____________________ 

Address____________________________________________________________ From/Until____________________ 

Address____________________________________________________________ From/Until____________________ 

All predecessor companies for past five years: 

Name & Address _________________________________________________________ From/Until ______________ 

Name & Address _________________________________________________________ From/Until ______________ 

Name & Address _________________________________________________________ From/Until ______________ 

Item 2. Legal Information 

Federal Taxpayer ID No. _________________________ State & Date of Incorporation _________________________ 

State Tax ID No. ____________________ State ________________ Profit or Not For Profit _____________________ 

Corporation’s Present Status: Active ________________ Inactive _______________ Dissolved __________________ 

If Dissolved: Date dissolved _________________________ By Whom ______________________________________ 

Reasons _________________________________________________________________________________________ 

Fiscal Year-End (Mo./Day) ________________ Corporation’s Business Activities _____________________________ 

Item 3. Registered Agent 

Name of Registered Agent __________________________________________________________________________ 

Address __________________________________________________________ Telephone No. __________________ 

Page 2 Initials __________ 
_________________________________________________________________________________ ______________ 

_________________________________________________________________________________ ______________ 

_________________________________________________________________________________ ______________ 

_________________________________________________________________________________ ______________ 

____________________________________________________________________ __________ _________________ 

____________________________________________________________________ __________ _________________ 

____________________________________________________________________ __________ _________________ 

____________________________________________________________________ __________ _________________ 

____________________________________________________________________ __________ _________________ 

_______________________________________________________________________________ ________________ 

_______________________________________________________________________________ ________________ 

_______________________________________________________________________________ ________________ 

_______________________________________________________________________________ ________________ 

_______________________________________________________________________________ ________________ 

Case 3:22-cv-00487-TJC-MCR *SEALED* Document 12-1 Filed 05/03/22 Page 16 of 33 

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Item 4. Principal Stockholders 

List all persons and entities that own at least 5% of the corporation’s stock. 

Name & Address % Owned 

Item 5. Board Members 

List all members of the corporation’s Board of Directors. 

Name & Address % Owned Term (From/Until) 

Item 6. Officers 

List all of the corporation’s officers, including de facto officers (individuals with significant management responsibility 

whose titles do not reflect the nature of their positions). 

Name & Address % Owned 

Page 3 Initials __________ 
___________________________________________________________________ ___________________ _________ 

___________________________________________________________________ ___________________ _________ 

___________________________________________________________________ ___________________ _________ 

________________________________________________________________________________________________ 

__________________ __________________________________________________ __________________ ________ 

__________________ __________________________________________________ __________________ ________ 

__________________ __________________________________________________ __________________ ________ 

________________________________________________________________________________________________ 

_________________________________________________________ _________________ ______________________ 

_________________________________________________________ _________________ ______________________ 

_________________________________________________________ _________________ ______________________ 

Case 3:22-cv-00487-TJC-MCR *SEALED* Document 12-1 Filed 05/03/22 Page 17 of 33 

PageID 322 

Item 7. Businesses Related to the Corporation 

List all corporations, partnerships, and other business entities in which this corporation has an ownership interest. 

Name & Address Business Activities % Owned 

State which of these businesses, if any, has ever transacted business with the corporation _______________________ 

Item 8. Businesses Related to Individuals 

List all corporations, partnerships, and other business entities in which the corporation’s principal stockholders, board 

members, or officers (i.e., the individuals listed in Items 4 - 6 above) have an ownership interest. 

Individual’s Name Business Name & Address Business Activities % Owned 

State which of these businesses, if any, have ever transacted business with the corporation _______________________ 

Item 9. Related Individuals 

List all related individuals with whom the corporation has had any business transactions during the three previous fiscal 

years and current fiscal year-to-date. A “related individual” is a spouse, sibling, parent, or child of the principal 

stockholders, board members, and officers (i.e., the individuals listed in Items 4 - 6 above). 

Name and Address Relationship Business Activities 

Page 4 Initials __________ 
____________________ ______________________ ________________________________________ ____________ 

____________________ ______________________ ________________________________________ ____________ 

____________________ ______________________ ________________________________________ ____________ 

____________________ ______________________ ________________________________________ ____________ 

____________________ ______________________ ________________________________________ ____________ 

____________________________________________________________________________ ___________________ 

____________________________________________________________________________ ___________________ 

____________________________________________________________________________ ___________________ 

____________________________________________________________________________ ___________________ 

____________________ ___________________________ ________________________________________________ 

____________________ ___________________________ ________________________________________________ 

____________________ ___________________________ ________________________________________________ 

____________________ ___________________________ ________________________________________________ 

____________________ ___________________________ ________________________________________________ 

Case 3:22-cv-00487-TJC-MCR *SEALED* Document 12-1 Filed 05/03/22 Page 18 of 33 

PageID 323 

Item 10. Outside Accountants 

List all outside accountants retained by the corporation during the last three years. 

Name Firm Name Address CPA/PA? 

Item 11. Corporation’s Recordkeeping 

List all individuals within the corporation with responsibility for keeping the corporation’s financial books and records for 

the last three years. 

Name, Address, & Telephone Number Position(s) Held 

Item 12. Attorneys 

List all attorneys retained by the corporation during the last three years. 

Name Firm Name Address 

Page 5 Initials __________ 
Case 3:22-cv-00487-TJC-MCR *SEALED* Document 12-1 Filed 05/03/22 Page 19 of 33 

PageID 324 

Item 13. Pending Lawsuits Filed by the Corporation 

List all pending lawsuits that have been filed by the corporation in court or before an administrative agency. (List 

lawsuits that resulted in final judgments or settlements in favor of the corporation in Item 25). 

Opposing Party’s Name & Address___________________________________________________________________ 

Court’s Name & Address___________________________________________________________________________ 

Docket No._________________ Relief Requested____________________ Nature of Lawsuit____________________ 

____________________________________ Status______________________________________________________ 

Opposing Party’s Name & Address___________________________________________________________________ 

Court’s Name & Address___________________________________________________________________________ 

Docket No._________________ Relief Requested____________________ Nature of Lawsuit____________________ 

____________________________________ Status______________________________________________________ 

Opposing Party’s Name & Address___________________________________________________________________ 

Court’s Name & Address___________________________________________________________________________ 

Docket No._________________ Relief Requested____________________ Nature of Lawsuit____________________ 

____________________________________ Status______________________________________________________ 

Opposing Party’s Name & Address___________________________________________________________________ 

Court’s Name & Address___________________________________________________________________________ 

Docket No._________________ Relief Requested____________________ Nature of Lawsuit____________________ 

____________________________________ Status______________________________________________________ 

Opposing Party’s Name & Address___________________________________________________________________ 

Court’s Name & Address___________________________________________________________________________ 

Docket No._________________ Relief Requested____________________ Nature of Lawsuit____________________ 

____________________________________ Status______________________________________________________ 

Opposing Party’s Name & Address___________________________________________________________________ 

Court’s Name & Address___________________________________________________________________________ 

Docket No._________________ Relief Requested____________________ Nature of Lawsuit____________________ 

____________________________________ Status______________________________________________________ 

Page 6 Initials __________ 
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PageID 325 

Item 14. Current Lawsuits Filed Against the Corporation 

List all pending lawsuits that have been filed against the corporation in court or before an administrative agency. (List 

lawsuits that resulted in final judgments, settlements, or orders in Items 26 - 27). 

Opposing Party’s Name & Address___________________________________________________________________ 

Court’s Name & Address___________________________________________________________________________ 

Docket No._________________ Relief Requested____________________ Nature of Lawsuit____________________ 

____________________________________ Status______________________________________________________ 

Opposing Party’s Name & Address___________________________________________________________________ 

Court’s Name & Address___________________________________________________________________________ 

Docket No._________________ Relief Requested____________________ Nature of Lawsuit____________________ 

____________________________________ Status______________________________________________________ 

Opposing Party’s Name & Address___________________________________________________________________ 

Court’s Name & Address___________________________________________________________________________ 

Docket No._________________ Relief Requested____________________ Nature of Lawsuit____________________ 

____________________________________ Status______________________________________________________ 

Opposing Party’s Name & Address___________________________________________________________________ 

Court’s Name & Address___________________________________________________________________________ 

Docket No._________________ Relief Requested____________________ Nature of Lawsuit____________________ 

____________________________________ Status______________________________________________________ 

Opposing Party’s Name & Address___________________________________________________________________ 

Court’s Name & Address___________________________________________________________________________ 

Docket No._________________ Relief Requested____________________ Nature of Lawsuit____________________ 

____________________________________ Status______________________________________________________ 

Opposing Party’s Name & Address___________________________________________________________________ 

Court’s Name & Address___________________________________________________________________________ 

Docket No._________________ Relief Requested____________________ Nature of Lawsuit____________________ 

____________________________________ Status______________________________________________________ 

Page 7 Initials __________ 
__________________ ___________________________________________________________________ __________ 

__________________ ___________________________________________________________________ __________ 

__________________ ___________________________________________________________________ __________ 

__________________ ___________________________________________________________________ __________ 

__________________ ___________________________________________________________________ __________ 

Case 3:22-cv-00487-TJC-MCR *SEALED* Document 12-1 Filed 05/03/22 Page 21 of 33 

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Item 15. Bankruptcy Information 

List all state insolvency and federal bankruptcy proceedings involving the corporation. 

Commencement Date _________________ Termination Date _________________ Docket No. __________________ 

If State Court: Court & County _______________________ If Federal Court: District __________________________ 

Disposition ______________________________________________________________________________________ 

Item 16. Safe Deposit Boxes 

List all safe deposit boxes, located within the United States or elsewhere, held by the corporation, or held by others for the 

benefit of the corporation. On a separate page, describe the contents of each box. 

Owner’s Name Name & Address of Depository Institution Box No. 

FINANCIAL INFORMATION 

REMINDER: When an Item asks for information about assets or liabilities “held by the corporation,” include 

ALL such assets and liabilities, located within the United States or elsewhere, held by the corporation or held by 

others for the benefit of the corporation. 

Item 17. Tax Returns 

List all federal and state corporate tax returns filed for the last three complete fiscal years. Attach copies of all returns. 

Federal/ Tax Year Tax Due Tax Paid Tax Due Tax Paid Preparer’s Name 

State/Both Federal Federal State State 

___________ __________ $_________ $_________ $__________ $__________ ______________________________ 

___________ __________ $_________ $_________ $__________ $__________ ______________________________ 

___________ __________ $_________ $_________ $__________ $__________ ______________________________ 

Page 8 Initials __________ 
_________ _____________ ______________________ __________________ _______________________ ________ 

_________ _____________ ______________________ __________________ _______________________ ________ 

_________ _____________ ______________________ __________________ _______________________ ________ 

_________ _____________ ______________________ __________________ _______________________ ________ 

Case 3:22-cv-00487-TJC-MCR *SEALED* Document 12-1 Filed 05/03/22 Page 22 of 33 

PageID 327 

Item 18. Financial Statements 

List all financial statements that were prepared for the corporation’s last three complete fiscal years and for the current 

fiscal year-to-date. Attach copies of all statements, providing audited statements if available. 

Year Balance Sheet Profit & Loss Statement Cash Flow Statement Changes in Owner’s Equity Audited? 

Item 19. Financial Summary 

For each of the last three complete fiscal years and for the current fiscal year-to-date for which the corporation has not 

provided a profit and loss statement in accordance with Item 18 above, provide the following summary financial 

information. 

Current Year-to-Date 1 Year Ago 2 Years Ago 3 Years Ago 

Gross Revenue $_________________ $_______________ $_______________ $_______________ 

Expenses $_________________ $_______________ $_______________ $_______________ 

Net Profit After Taxes $_________________ $_______________ $_______________ $_______________ 

Payables $_________________ 

Receivables $_________________ 

Item 20. Cash, Bank, and Money Market Accounts 

List cash and all bank and money market accounts, including but not limited to, checking accounts, savings accounts, and 

certificates of deposit, held by the corporation. The term “cash” includes currency and uncashed checks. 

Cash on Hand $_________________________ Cash Held for the Corporation’s Benefit $_______________________ 

Name & Address of Financial Institution Signator(s) on Account Account No. Current 

Balance 

_____________________________________ _______________________________ ______________ $___________ 

_____________________________________ _______________________________ ______________ $___________ 

_____________________________________ _______________________________ ______________ $___________ 

_____________________________________ _______________________________ ______________ $___________ 

Page 9 Initials __________ 
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Item 21. Government Obligations and Publicly Traded Securities 

List all U.S. Government obligations, including but not limited to, savings bonds, treasury bills, or treasury notes, held by 

the corporation. Also list all publicly traded securities, including but not limited to, stocks, stock options, registered and 

bearer bonds, state and municipal bonds, and mutual funds, held by the corporation. 

Issuer _________________________________ Type of Security/Obligation __________________________________ 

No. of Units Owned __________ Current Fair Market Value $__________________ Maturity Date _______________ 

Issuer _________________________________ Type of Security/Obligation __________________________________ 

No. of Units Owned __________ Current Fair Market Value $__________________ Maturity Date _______________ 

Item 22. Real Estate 

List all real estate, including leaseholds in excess of five years, held by the corporation. 

Type of Property________________________________ Property’s Location__________________________________ 

Name(s) on Title and Ownership Percentages___________________________________________________________ 

Current Value $____________________ Loan or Account No. __________________________ 

Lender’s Name and Address_________________________________________________________________________ 

Current Balance On First Mortgage $_______________ Monthly Payment $______________ 

Other Loan(s) (describe)____________________________________________ Current Balance $_________________ 

Monthly Payment $__________________ Rental Unit?_________________ Monthly Rent Received $_____________ 

Type of Property________________________________ Property’s Location__________________________________ 

Name(s) on Title and Ownership Percentages___________________________________________________________ 

Current Value $____________________ Loan or Account No. __________________________ 

Lender’s Name and Address_________________________________________________________________________ 

Current Balance On First Mortgage $_______________ Monthly Payment $______________ 

Other Loan(s) (describe)____________________________________________ Current Balance $_________________ 

Monthly Payment $__________________ Rental Unit?_________________ Monthly Rent Received $_____________ 

Page 10 Initials __________ 
 

Case 3:22-cv-00487-TJC-MCR *SEALED* Document 12-1 Filed 05/03/22 Page 24 of 33 

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Item 23. Other Assets 

List all other property, by category, with an estimated value of $2,500 or more, held by the corporation, including but not 

limited to, inventory, machinery, equipment, furniture, vehicles, customer lists, computer software, patents, and other 

intellectual property. 

Property Category Property Location Acquisition Current 

Cost Value 

____________________________ _____________________________________________ $__________ $_________ 

____________________________ _____________________________________________ $__________ $_________ 

____________________________ _____________________________________________ $__________ $_________ 

____________________________ _____________________________________________ $__________ $_________ 

____________________________ _____________________________________________ $__________ $_________ 

____________________________ _____________________________________________ $__________ $_________ 

____________________________ _____________________________________________ $__________ $_________ 

____________________________ _____________________________________________ $__________ $_________ 

____________________________ _____________________________________________ $__________ $_________ 

Item 24. Trusts and Escrows 

List all persons and other entities holding funds or other assets that are in escrow or in trust for the corporation. 

Trustee or Escrow Agent’s Description and Location of Assets Present Market 

Name & Address Value of Assets 

______________________________________ _______________________________________ $_________________ 

______________________________________ _______________________________________ $_________________ 

______________________________________ _______________________________________ $_________________ 

______________________________________ _______________________________________ $_________________ 

______________________________________ _______________________________________ $_________________ 

______________________________________ _______________________________________ $_________________ 

______________________________________ _______________________________________ $_________________ 

Page 11 Initials __________ 
Case 3:22-cv-00487-TJC-MCR *SEALED* Document 12-1 Filed 05/03/22 Page 25 of 33 

PageID 330 

Item 25. Monetary Judgments and Settlements Owed To the Corporation 

List all monetary judgments and settlements, recorded and unrecorded, owed to the corporation. 

Opposing Party’s Name & Address___________________________________________________________________ 

Court’s Name & Address____________________________________________________ Docket No._____________ 

Nature of Lawsuit______________________________ Date of Judgment________________ Amount $____________ 

Opposing Party’s Name & Address___________________________________________________________________ 

Court’s Name & Address____________________________________________________ Docket No._____________ 

Nature of Lawsuit______________________________ Date of Judgment________________ Amount $____________ 

Item 26. Monetary Judgments and Settlements Owed By the Corporation 

List all monetary judgments and settlements, recorded and unrecorded, owed by the corporation. 

Opposing Party’s Name & Address___________________________________________________________________ 

Court’s Name & Address____________________________________________________ Docket No._____________ 

Nature of Lawsuit_______________________________________ Date______________ Amount $______________ 

Opposing Party’s Name & Address___________________________________________________________________ 

Court’s Name & Address____________________________________________________ Docket No._____________ 

Nature of Lawsuit______________________________ Date of Judgment________________ Amount $____________ 

Opposing Party’s Name & Address___________________________________________________________________ 

Court’s Name & Address____________________________________________________ Docket No._____________ 

Nature of Lawsuit______________________________ Date of Judgment________________ Amount $____________ 

Opposing Party’s Name & Address___________________________________________________________________ 

Court’s Name & Address____________________________________________________ Docket No._____________ 

Nature of Lawsuit______________________________ Date of Judgment________________ Amount $____________ 

Opposing Party’s Name & Address___________________________________________________________________ 

Court’s Name & Address____________________________________________________ Docket No._____________ 

Nature of Lawsuit______________________________ Date of Judgment________________ Amount $____________ 

Page 12 Initials __________ 
__________________________________________ _____________________________________________________ 

__________________________________________ _____________________________________________________ 

__________________________________________ _____________________________________________________ 

__________________________________________ _____________________________________________________ 

__________________________________________ _____________________________________________________ 

Case 3:22-cv-00487-TJC-MCR *SEALED* Document 12-1 Filed 05/03/22 Page 26 of 33 

PageID 331 

Item 27. Government Orders and Settlements 

List all existing orders and settlements between the corporation and any federal or state government entities. 

Name of Agency ___________________________________________ Contact Person __________________________ 

Address _____________________________________________________________ Telephone No. _______________ 

Agreement Date ______________ Nature of Agreement __________________________________________________ 

Item 28. Credit Cards 

List all of the corporation’s credit cards and store charge accounts and the individuals authorized to use them. 

Name of Credit Card or Store Names of Authorized Users and Positions Held 

Item 29. Compensation of Employees 

List all compensation and other benefits received from the corporation by the five most highly compensated employees, 

independent contractors, and consultants (other than those individuals listed in Items 5 and 6 above), for the two previous 

fiscal years and current fiscal year-to-date. “Compensation” includes, but is not limited to, salaries, commissions, 

consulting fees, bonuses, dividends, distributions, royalties, pensions, and profit sharing plans. “Other benefits” include, 

but are not limited to, loans, loan payments, rent, car payments, and insurance premiums, whether paid directly to the 

individuals, or paid to others on their behalf. 

Name/Position Current Fiscal 1 Year Ago 2 Years Ago Compensation or 

Year-to-Date Type of Benefits 

_____________________________ $____________ $___________ $____________ ___________________________ 

_____________________________ $____________ $___________ $____________ ___________________________ 

_____________________________ $____________ $___________ $____________ ___________________________ 

_____________________________ $____________ $___________ $____________ ___________________________ 

_____________________________ $____________ $___________ $____________ ___________________________ 

Page 13 Initials __________ 
Case 3:22-cv-00487-TJC-MCR *SEALED* Document 12-1 Filed 05/03/22 Page 27 of 33 

PageID 332 

Item 30. Compensation of Board Members and Officers 

List all compensation and other benefits received from the corporation by each person listed in Items 5 and 6, for the 

current fiscal year-to-date and the two previous fiscal years. “Compensation” includes, but is not limited to, salaries, 

commissions, consulting fees, dividends, distributions, royalties, pensions, and profit sharing plans. “Other benefits” 

include, but are not limited to, loans, loan payments, rent, car payments, and insurance premiums, whether paid directly to 

the individuals, or paid to others on their behalf. 

Name/Position Current Fiscal 1 Year Ago 2 Years Ago Compensation or 

Year-to-Date Type of Benefits 

_____________________________ $____________ $___________ $____________ ___________________________ 

_____________________________ $____________ $___________ $____________ ___________________________ 

_____________________________ $____________ $___________ $____________ ___________________________ 

_____________________________ $____________ $___________ $____________ ___________________________ 

_____________________________ $____________ $___________ $____________ ___________________________ 

_____________________________ $____________ $___________ $____________ ___________________________ 

_____________________________ $____________ $___________ $____________ ___________________________ 

_____________________________ $____________ $___________ $____________ ___________________________ 

Item 31. Transfers of Assets Including Cash and Property 

List all transfers of assets over $2,500 made by the corporation, other than in the ordinary course of business, during the 

previous three years, by loan, gift, sale, or other transfer. 

Transferee’s Name, Address, & Relationship Property Aggregate Transfer Type of Transfer 

Transferred Value Date (e.g., Loan, Gift) 

______________________________________ ________________ $____________ __________ _________________ 

______________________________________ ________________ $____________ __________ _________________ 

______________________________________ ________________ $____________ __________ _________________ 

______________________________________ ________________ $____________ __________ _________________ 

______________________________________ ________________ $____________ __________ _________________ 

Page 14 Initials __________ 
___________________ ____________________________________________________________________________ 

___________________ ____________________________________________________________________________ 

___________________ ____________________________________________________________________________ 

___________________ ____________________________________________________________________________ 

___________________ ____________________________________________________________________________ 

___________________ ____________________________________________________________________________ 

___________________ ____________________________________________________________________________ 

___________________ ____________________________________________________________________________ 

___________________ ____________________________________________________________________________ 

______________________________ _____________________________________________________ 

_____________________________________________________ 

Case 3:22-cv-00487-TJC-MCR *SEALED* Document 12-1 Filed 05/03/22 Page 28 of 33 

PageID 333 

Item 32. Documents Attached to the Financial Statement 

List all documents that are being submitted with the financial statement. 

Item No. Document Description of Document 

Relates To 

I am submitting this financial statement with the understanding that it may affect action by the Federal Trade 

Commission or a federal court. I have used my best efforts to obtain the information requested in this statement. The 

responses I have provided to the items above are true and contain all the requested facts and information of which I have 

notice or knowledge. I have provided all requested documents in my custody, possession, or control. I know of the 

penalties for false statements under 18 U.S.C. § 1001, 18 U.S.C. § 1621, and 18 U.S.C. § 1623 (five years imprisonment 

and/or fines). I certify under penalty of perjury under the laws of the United States that the foregoing is true and correct. 

Executed on: 

(Date) Signature 

Corporate Position 

Page 15 Initials __________ 
Case 3:22-cv-00487-TJC-MCR *SEALED* Document 12-1 Filed 05/03/22 Page 29 of 33 

PageID 334 

Attachment C 
7 

Case 3:22-cv-00487-TJC-MCR *SEALED* Document 12-1 Filed 05/03/22 Page 30 of 33 

PageID 335 

Form 4506

(Novmeber 2021) 

Department of the Treasury 

Internal Revenue Service 

Request for Copy of Tax Return 

a Do not sign this form unless all applicable lines have been completed. 

a Request may be rejected if the form is incomplete or illegible. 

a For more information about Form 4506, visit www.irs.gov/form4506. 

OMB No. 1545-0429 

Tip: Get faster service: Online at www.irs.gov, Get Your Tax Record (Get Transcript) or by calling 1-800-908-9946 for specialized assistance. We 

have teams available to assist. Note: Taxpayers may register to use Get Transcript to view, print, or download the following transcript types: Tax 

Return Transcript (shows most line items including Adjusted Gross Income (AGI) from your original Form 1040-series tax return as filed, along with 

any forms and schedules), Tax Account Transcript (shows basic data such as return type, marital status, AGI, taxable income and all payment types), 

Record of Account Transcript (combines the tax return and tax account transcripts into one complete transcript), Wage and Income Transcript 

(shows data from information returns we receive such as Forms W-2, 1099, 1098 and Form 5498), and Verification of Non-filing Letter (provides 

proof that the IRS has no record of a filed Form 1040-series tax return for the year you request). 

1a Name shown on tax return. If a joint return, enter the name shown first. 1b First social security number on tax return, 

individual taxpayer identification number, or 

employer identification number (see instructions) 

2a If a joint return, enter spouse’s name shown on tax return. 2b Second social security number or individual 

taxpayer identification number if joint tax return 

3 Current name, address (including apt., room, or suite no.), city, state, and ZIP code (see instructions) 

4 Previous address shown on the last return filed if different from line 3 (see instructions) 

5 If the tax return is to be mailed to a third party (such as a mortgage company), enter the third party’s name, address, and telephone number. 

Caution: If the tax return is being sent to the third party, ensure that lines 5 through 7 are completed before signing. (see instructions). 

6 Tax return requested. Form 1040, 1120, 941, etc. and all attachments as originally submitted to the IRS, including Form(s) W-2, 

schedules, or amended returns. Copies of Forms 1040, 1040A, and 1040EZ are generally available for 7 years from filing before they are 

destroyed by law. Other returns may be available for a longer period of time. Enter only one return number. If you need more than one 

type of return, you must complete another Form 4506. a

Note: If the copies must be certified for court or administrative proceedings, check here . . . . . . . . . . . . . . . 

Year or period requested. Enter the ending date of the tax year or period using the mm/dd/yyyy format (see instructions). 

/ / / / / / / / 

/ / / / / / / / 

8 

a 

Fee. There is a $43 fee for each return requested. Full payment must be included with your request or it will 

be rejected. Make your check or money order payable to “United States Treasury.” Enter your SSN, ITIN, 

or EIN and “Form 4506 request” on your check or money order. 

Cost for each return . . . . . . . . . . . . . . . . . . . . . . . . . . . $ 43.00

b Number of returns requested on line 7 . . . . . . . . . . . . . . . . . . . . . . 

c Total cost. Multiply line 8a by line 8b . . . . . . . . . . . . . . . . . . . . . . $ 

9 If we cannot find the tax return, we will refund the fee. If the refund should go to the third party listed on line 5, check he . . . . . re

Caution: Do not sign this form unless all applicable lines have been completed. 

Signature of taxpayer(s). I declare that I am either the taxpayer whose name is shown on line 1a or 2a, or a person authorized to obtain the tax return 

requested. If the request applies to a joint return, at least one spouse must sign. If signed by a corporate officer, 1 percent or more shareholder, partner, 

managing member, guardian, tax matters partner, executor, receiver, administrator, trustee, or party other than the taxpayer, I certify that I have the authority to 

execute Form 4506 on behalf of the taxpayer. Note: This form must be received by IRS within 120 days of the signature date. 

Signatory attests that he/she has read the attestation clause and upon so reading 

declares that he/she has the authority to sign the Form 4506. See instructions. Phone number of taxpayer on line 

1a or 2a 

F

Signature (see instructions) Date 

Sign 

F F F

Here Print/Type name Title (if line 1a above is a corporation, partnership, estate, or trust) 

Spouse’s signature Date 

Print/Type name 

For Privacy Act and Paperwork Reduction Act Notice, see page 2. Cat. No. 41721E Form 4506 (Rev. 11-2021) 
Case 3:22-cv-00487-TJC-MCR *SEALED* Document 12-1 Filed 05/03/22 Page 31 of 33 

PageID 336 

Form 4506 (Rev. 11-2021) Page 2 

Section references are to the Internal Revenue Code 

unless otherwise noted. 

Future Developments 

For the latest information about Form 4506 and its 

instructions, go to www.irs.gov/form4506. 

General Instructions 

Caution: Do not sign this form unless all applicable 

lines, including lines 5 through 7, have been 

completed. 

Designated Recipient Notification. Internal 

Revenue Code, Section 6103(c), limits disclosure 

and use of return information received pursuant to 

the taxpayer’s consent and holds the recipient 

subject to penalties for any unauthorized access, 

other use, or redisclosure without the taxpayer’s 

express permission or request. 

Taxpayer Notification. Internal Revenue Code, 

Section 6103(c), limits disclosure and use of return 

information provided pursuant to your consent and 

holds the recipient subject to penalties, brought by 

private right of action, for any unauthorized access, 

other use, or redisclosure without your express 

permission or request. 

Purpose of form. Use Form 4506 to request a copy 

of your tax return. You can also designate (on line 5) 

a third party to receive the tax return. 

How long will it take? It may take up to 75 

calendar days for us to process your request. 

Where to file. Attach payment and mail Form 4506 

to the address below for the state you lived in, or the 

state your business was in, when that return was 

filed. There are two address charts: one for 

individual returns (Form 1040 series) and one for all 

other returns. 

If you are requesting a return for more than one 

year or period and the chart below shows two 

different addresses, send your request based on the 

address of your most recent return. 

Chart for individual returns 

(Form 1040 series) 

If you filed an 

individual return Mail to: 

and lived in: 

Florida, Louisiana, 

Mississippi, Texas, a 

foreign country, American Internal Revenue Service Samoa, Puerto Rico, RAIVS Team Guam, the Stop 6716 AUSC Commonwealth of the Austin, TX 73301 Northern Mariana Islands, 

the U.S. Virgin Islands, or 

A.P.O. or F.P.O. address 

Alabama, Arkansas, 

Delaware, Georgia, 

Illinois, Indiana, Iowa, 

Kentucky, Maine, 

Massachusetts, Internal Revenue Service 

Minnesota, Missouri, RAIVS Team 

New Hampshire, New Stop 6705 S-2 

Jersey, New York, North Kansas City, MO 64999 

Carolina, Oklahoma, 

South Carolina, 

Tennessee, Vermont, 

Virginia, Wisconsin 

Alaska, Arizona, 

California, Colorado, 

Connecticut, District of 

Columbia, Hawaii, Idaho, 

Kansas, Maryland, Internal Revenue Service 

Michigan, Montana, RAIVS Team 

Nebraska, Nevada, New P.O. Box 9941 

Mexico, North Dakota, Mail Stop 6734 

Ohio, Oregon, Ogden, UT 84409 

Pennsylvania, Rhode 

Island, South Dakota, 

Utah, Washington, West 

Virginia, Wyoming 

Chart for all other returns 

For returns not in 

Form 1040 series, Mail to: if the address on 

the return was in: 

Connecticut, Delaware, 

District of Columbia, 

Georgia, Illinois, Indiana, 

Kentucky, Maine, 

Maryland, 

Massachusetts, Internal Revenue Service 

Michigan, New RAIVS Team 

Hampshire, New Jersey, Stop 6705 S-2 

New York, North Kansas City, MO 

Carolina, Ohio, 64999 

Pennsylvania, Rhode 

Island, South Carolina, 

Tennessee, Vermont, 

Virginia, West Virginia, 

Wisconsin 

Alabama, Alaska, 

Arizona, Arkansas, 

California, Colorado, 

Florida, Hawaii, Idaho, 

Iowa, Kansas, Louisiana, 

Minnesota, Mississippi, 

Missouri, Montana, 

Nebraska, Nevada, New 

Mexico, North Dakota, Internal Revenue Service 

Oklahoma, Oregon, RAIVS Team 

South Dakota, Texas, P.O. Box 9941 

Utah, Washington, Mail Stop 6734 

Wyoming, a foreign Ogden, UT 84409 

country, American 

Samoa, Puerto Rico, 

Guam, the 

Commonwealth of the 

Northern Mariana 

Islands, the U.S. Virgin 

Islands, or A.P.O. or 

F.P.O. address 

Specific Instructions 

Line 1b. Enter the social security number (SSN) or 

individual taxpayer identification number (ITIN) for 

the individual listed on line 1a, or enter the employer 

identification number (EIN) for the business listed on 

line 1a. For example, if you are requesting Form 

1040 that includes Schedule C (Form 1040), enter 

your SSN. 

Line 3. Enter your current address. If you use a P.O. 

box, please include it on this line 3. 

Line 4. Enter the address shown on the last return 

filed if different from the address entered on line 3. 

Note. If the addresses on lines 3 and 4 are different 

and you have not changed your address with the 

IRS, file Form 8822, Change of Address, or Form 

8822-B,Change of Address or Responsible Party — 

Business, with Form 4506. 

Line 7. Enter the end date of the tax year or period 

requested in mm/dd/yyyy format. This may be a 

calendar year, fiscal year or quarter. Enter each 

quarter requested for quarterly returns. Example: 

Enter 12/31/2018 for a calendar year 2018 Form 

1040 return, or 03/31/2017 for a first quarter Form 

941 return. 

Signature and date. Form 4506 must be signed and 

dated by the taxpayer listed on line 1a or 2a. The 

IRS must receive Form 4506 within 120 days of the 

date signed by the taxpayer or it will be rejected. 

Ensure that all applicable lines, including lines 5 

through 7, are completed before signing. 

F! 

CAUTION

You must check the box in the 

signature area to acknowledge you 

have the authority to sign and request 

the information. The form will not be 

processed and returned to you if the box is 

unchecked. 

Individuals. Copies of jointly filed tax returns may 

be furnished to either spouse. Only one signature is 

required. Sign Form 4506 exactly as your name 

appeared on the original return. If you changed your 

name, also sign your current name. 

Corporations. Generally, Form 4506 can be 

signed by: (1) an officer having legal authority to bind 

the corporation, (2) any person designated by the 

board of directors or other governing body, or (3) 

any officer or employee on written request by any 

principal officer and attested to by the secretary or 

other officer. A bona fide shareholder of record 

owning 1 percent or more of the outstanding stock 

of the corporation may submit a Form 4506 but must 

provide documentation to support the requester's 

right to receive the information. 

Partnerships. Generally, Form 4506 can be 

signed by any person who was a member of the 

partnership during any part of the tax period 

requested on line 7. 

All others. See section 6103(e) if the taxpayer has 

died, is insolvent, is a dissolved corporation, or if a 

trustee, guardian, executor, receiver, or 

administrator is acting for the taxpayer. 

Note: If you are Heir at law, Next of kin, or 

Beneficiary you must be able to establish a material 

interest in the estate or trust. 

Documentation. For entities other than individuals, 

you must attach the authorization document. For 

example, this could be the letter from the principal 

officer authorizing an employee of the corporation or 

the letters testamentary authorizing an individual to 

act for an estate. 

Signature by a representative. A representative 

can sign Form 4506 for a taxpayer only if this 

authority has been specifically delegated to the 

representative on Form 2848, line 5a. Form 2848 

showing the delegation must be attached to Form 

4506. 

Privacy Act and Paperwork Reduction Act 

Notice. We ask for the information on this form to 

establish your right to gain access to the requested 

return(s) under the Internal Revenue Code. We need 

this information to properly identify the return(s) and 

respond to your request. If you request a copy of a 

tax return, sections 6103 and 6109 require you to 

provide this information, including your SSN or EIN, 

to process your request. If you do not provide this 

information, we may not be able to process your 

request. Providing false or fraudulent information 

may subject you to penalties. 

Routine uses of this information include giving it to 

the Department of Justice for civil and criminal 

litigation, and cities, states, the District of Columbia, 

and U.S. commonwealths and possessions for use 

in administering their tax laws. We may also 

disclose this information to other countries under a 

tax treaty, to federal and state agencies to enforce 

federal nontax criminal laws, or to federal law 

enforcement and intelligence agencies to combat 

terrorism. 

You are not required to provide the information 

requested on a form that is subject to the Paperwork 

Reduction Act unless the form displays a valid OMB 

control number. Books or records relating to a form 

or its instructions must be retained as long as their 

contents may become material in the administration 

of any Internal Revenue law. Generally, tax returns 

and return information are confidential, as required 

by section 6103. 

The time needed to complete and file Form 4506 

will vary depending on individual circumstances. The 

estimated average time is: Learning about the law 

or the form, 10 min.; Preparing the form, 16 min.; 

and Copying, assembling, and sending the form 

to the IRS, 20 min. 

If you have comments concerning the accuracy of 

these time estimates or suggestions for making 

Form 4506 simpler, we would be happy to hear from 

you. You can write to: 

Internal Revenue Service 

Tax Forms and Publications Division 

1111 Constitution Ave. NW, IR-6526 

Washington, DC 20224. 

Do not send the form to this address. Instead, see 

Where to file on this page. 
Case 3:22-cv-00487-TJC-MCR *SEALED* Document 12-1 Filed 05/03/22 Page 32 of 33 

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Attachment D 
 

 

 

 

 

Case 3:22-cv-00487-TJC-MCR *SEALED* Document 12-1 Filed 05/03/22 Page 33 of 33 

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CONSENT TO RELEASE FINANCIAL RECORDS 

I, __________________________of _______________________, (City, 

State), do hereby direct any bank, saving and loan association, credit union, 

depository institution, finance company, commercial lending company, credit card 

processor, credit card processing entity, automated clearing house, network 

transaction processor, bank debit processing entity, brokerage house, escrow agent, 

money market or mutual fund, title company, commodity trading company, trustee, 

or person that holds, controls, or maintains custody of assets, wherever located, 

that are owned or controlled by me or at which there is an account of any kind 

upon which I am authorized to draw, and its officers, employees, and agents, to 

disclose all information and deliver copies of all documents of every nature in its 

possession or control which relate to the said accounts to any attorney of the 

Federal Trade Commission, and to give evidence relevant thereto, in the matter of [ 

], now pending in the United States District Court of [ ], and this shall be 

irrevocable authority for so doing. 

This direction is intended to apply to the laws of countries other than the 

United States of America which restrict or prohibit disclosure of bank or other 

financial information without the consent of the holder of the account, and shall be 

construed as consent with respect hereto, and the same shall apply to any of the 

accounts for which I may be a relevant principal. 

Dated:_______________ Signature:_____________________________ 

Printed Name:__________________________