FILED CLERK, U.S. DISTRICT COURT 

CENTRAL DISTRICT OF CALIFORNIA 

BY: DEPUTY 

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UNITED STATES DISTRICT COURT 

FOR THE CENTRAL DISTRICT OF CALIFORNIA 

FEDERAL TRADE COMMISSION, 

Plaintiff, 

v. 

BCO CONSULTING SERVICES 

INC., a California corporation, also

d/b/a Students Loan Services LLC; SLA CONSULTING SERVICES 

INC., a California corporation, f/k/a

Student Loan Advocates LLC; GIANNI OLILANG, individually and as an officer of BCO 

CONSULTING SERVICES INC. 

and SLA CONSULTING 

SERVICES INC.; BRANDON CLORES, individually and as an officer of BCO 

CONSULTING SERVICES INC.; KISHAN BHAKTA, individually and as an officer of BCO 

CONSULTING SERVICES INC.;

and 

ALLAN RADAM, individually and as an officer of SLA CONSULTING 

SERVICES INC., 

Defendants. 

Case No. 8:23-cv-00699-JWH (ADSx) 

AMENDED EX PARTE 

TEMPORARY RESTRAINING 

ORDER WITH ASSET FREEZE,

APPOINTMENT OF TEMPORARY 

RECEIVER, AND OTHER 

EQUITABLE RELIEF, AND

ORDER TO SHOW CAUSE WHY A 

PRELIMINARY INJUNCTION 

SHOULD NOT ISSUE 
 

 

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

for Permanent Injunction and Other Equitable Relief pursuant to Sections 13(b) 

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

§§ 53(b) and 57b, the Telemarketing and Consumer Fraud and Abuse 

Prevention Act, 15 U.S.C. §§ 6101-6108, and Section 522(a) of the GrammLeach-Bliley Act (the “GLB Act”), 15 U.S.C. § 6822(a), and the FTC has 

moved, pursuant to Rule 65(b) of the Federal Rules of Civil Procedure, for a 

temporary restraining order, asset freeze, other equitable relief, and an order to 

show cause why a preliminary injunction should not issue against Individual 

Defendants and Corporate Defendant. 

I. FINDINGS OF FACT 

The Court, having considered the Complaint; the ex parte Motion for a 

Temporary Restraining Order, declarations, exhibits, and memorandum of 

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

hereby finds as follows: 

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. There is good cause to believe that in numerous instances, 

Defendants have made material misrepresentations regarding their student loan 

debt relief services, have taken advance fees, and have engaged in illegal 

telemarketing. 

C. There is good cause to believe that Defendants BCO Consulting 

Services Inc., also d/b/a Student Loan Services LLC; SLA Consulting Services 

Inc., f/k/a Student Loan Advocates LLC; Gianni Olilang; Brandon Clores; 

Kishan Bhakta; and Allan Radam have engaged in and are likely to engage in acts 

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

Telemarketing Sales Rule (the “TSR”), 16 C.F.R. Part 310, and Section 521 of 

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the GLB Act, 15 U.S.C. § 6821, and that the FTC is therefore likely to prevail on 

the merits of this action. As demonstrated by consumer declarations, consumer 

complaints, and the additional documentation filed by the FTC, the FTC has 

established a likelihood of success in showing that, in numerous instances, 

Defendants: 

(1) have made deceptive representations in the marketing and 

sale of student debt relief services in violation of Section 5(a) of the FTC 

Act, 15 U.S.C. § 45(a) and the TSR, 16 C.F.R. § 310.4(a)(5)(i); 

(2) have collected unlawful advance fees from consumers in 

violation of the TSR, 16 C.F.R. § 310.4(a)(5)(i); and 

(3) have obtained customer information of a financial institution 

relating to another person by making false, fictitious, or fraudulent 

statements, in violation of Section 521 of the GLB Act, 15 U.S.C. § 6821. 

D. There is good cause to believe that Defendants have collected gross 

revenues of approximately $6.5 million as a result of their unlawful practices. 

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

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

the GLB Act, unless Defendants are restrained and enjoined by order of this 

Court. 

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

damage to the Court’s ability to grant effective final relief for consumers— 

including monetary restitution, rescission, disgorgement, or refunds—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 

Rule 65(b), the interests of justice require that this Order be granted without 

prior notice to Defendants. Thus, there is good cause for relieving the FTC of 

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

Restraining Order. 

G. Good cause exists for appointing a temporary receiver over the 

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

Receiver immediate access to the Defendants’ business premises, and 

permitting the FTC and the Receiver to take expedited discovery. 

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

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

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

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

I. This Court has authority to issue this Order pursuant to 

Section 13(b) of the FTC Act, 15 U.S.C. § 53(b); Section 19 of the FTC Act, 15 

U.S.C. § 57b(b); Rule 65; and the All Writs Act, 28 U.S.C. § 1651. 

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

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

II. DEFINITIONS 

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

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

to, any property, wherever located and by whomever held. 

B. “Assisting Others” includes the following: 

(1) performing customer service functions, including receiving 

or responding to consumer complaints performing customer service 

functions, including receiving or responding to consumer complaints; 

(2) formulating or providing, or arranging for the formulation or 

provision of, any advertising or marketing material, including any 

telephone sales script, direct mail solicitation, or the design, text, or use of 

images of any Internet website, email, or other electronic communication; 

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(3) formulating or providing, or arranging for the formulation or 

provision of, any marketing support material or service, including web or 

Internet Protocol addresses or domain name registration for any Internet 

websites, affiliate marketing services, or media placement services; 

(4) providing names of, or assisting in the generation of, 

potential customers; 

(5) performing marketing, billing, payment processing, or 

payment services of any kind; or 

(6) acting or serving as an owner, officer, director, manager, or 

principal of any entity. 

C. “Corporate Defendant” means BCO Consulting Services Inc., also 

d/b/a Student Loan Services LLC, and SLA Consulting Services Inc., f/k/a 

Student Loan Advocates LLC and their respective subsidiaries, affiliates, 

successors, and assigns. 

D. “Defendant(s)” means Corporate Defendants, Gianni Olilang, 

Brandon Clores, Kishan Bhakta, and Allan Radam, individually, collectively, or 

in any combination. 

E. “Debt Relief Service” means any program or service represented, 

directly or by implication, to renegotiate, settle, or in any way alter the terms of 

payment or other terms of the debt between a person and one or more unsecured 

creditors or debt collectors, including, but not limited to, a reduction in the 

balance, interest rate, or fees owed by a person to an unsecured creditor or debt 

collector. 

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

usage of “document” and “electronically stored information” in Rule 34(a) and 

includes writings, drawings, graphs, charts, photographs, sound and video 

recordings, images, Internet sites, web pages, websites, electronic 

correspondence, including email and instant messages, contracts, accounting 

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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. 

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. “Established Business Relationship” means a relationship between 

the Seller and a person based upon: 

(1) the person’s purchase, rental, or lease of the Seller’s goods 

or services or a financial transaction between the person and Seller, within 

18 months immediately preceding the date of the Telemarketing call; or 

(2) the person’s inquiry or application regarding a product or 

service offered by the Seller, within 3 months immediately preceding the 

date of a Telemarketing call. 

I. “Individual Defendant(s)” means Gianni Olilang, Brandon Clores, 

Kishan Bhakta, and Allan Radam, individually, in any combination, or jointly. 

J. “National Do Not Call Registry” means the “do-not-call” registry 

of telephone numbers maintained by the Commission pursuant to 16 C.F.R. 

§ 310.4(b)(1)(iii)(B). 

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K. “Outbound Telephone Call” means a telephone call initiated by a 

Telemarketer to induce the purchase of goods or services or to solicit a 

charitable contribution. 

L. “Receiver” means the temporary receiver appointed in 

Paragraph 11 of this Order. 

M. “Receivership Entities” means Corporate Defendant as well as any 

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

of Debt Relief Services, including receipt of Assets derived from any activity 

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

determines is controlled or owned by any Defendant. 

N. “Seller” means any person who, in connection with a 

Telemarketing transaction, provides, offers to provide, or arranges for others to 

provide goods or services to the customer in exchange for consideration. 

O. “Telemarketer” means any person who, in connection with 

telemarketing, initiates or receives telephone calls to or from a customer or 

donor. 16 C.F.R. § 310.2(cc). 

P. “Telemarketing” means a plan, program, or campaign (whether or 

not covered by the TSR, 16 C.F.R. Part 310) that is conducted to induce the 

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

telephones. 

III. ORDER 

Good cause appearing therefor, it is hereby ORDERED as follows: 

1. Prohibition on Deceptive Representations. 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: 

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a. misrepresenting or Assisting Others in misrepresenting, 

expressly or by implication, any material fact, including, but not limited 

to: 

i. that consumers who pay for Defendant’s program will 

be enrolled in a loan repayment program and have their loan 

balances forgiven in whole or in part; 

ii. that most or all of consumers’ monthly payments to 

Defendants will be applied to their loan balances; 

iii. that Defendants are contracted by, or otherwise 

affiliated with, the Department of Education; 

iv. that Defendants will assume responsibility for the 

servicing of consumers’ student loans; and 

v. 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; and 

b. making or Assisting Others in making, any representation, 

expressly or by implication, about the benefits, performance, or efficacy of 

any product or service, unless the representation is non-misleading and, at 

the time such representation is made, Defendants possess and rely upon 

competent and reliable evidence that is sufficient in quality and quantity 

based upon standards generally accepted in the relevant fields, when 

considered in light of the entire body of relevant and reliable evidence, to 

substantiate that the representation is true. 

2. Prohibition on Collection of Advanced Fees. Defendants, and their 

officers, agents, employees, and those persons or entities 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 

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ENJOINED from providing, offering to provide, or arranging for others to 

provide any Debt Relief Service and requesting or receiving payment of any fees 

or consideration for any Debt Relief Service, until and unless: 

a. the seller or telemarketer has renegotiated, settled, reduced, 

or otherwise altered the terms of at least one debt pursuant to a settlement 

agreement, debt management plan, or other such valid contractual 

agreement executed by the customer; 

b. the customer has made at least one payment pursuant to that 

settlement agreement, debt management plan, or other valid contractual 

agreement between the customer and the creditor or debt collector; and 

c. to the extent that debts enrolled in a service are renegotiated, 

settled, reduced, or otherwise altered individually, the fee or 

consideration either: 

i. bears the same proportional relationship to the total 

fee for renegotiating, settling, reducing, or altering the terms of the 

entire debt balance as the individual debt amount bears to the entire 

debt amount. The individual debt amount and the entire debt 

amount are those owed at the time the debt was enrolled in the 

service; or 

ii. is a percentage of the amount saved as a result of the 

renegotiation, settlement, reduction, or alteration. The percentage 

charged cannot change from one individual debt to another. The 

amount saved is the difference between the amount owed at the 

time the debt was enrolled in the service and the amount actually 

paid to satisfy the debt. 

3. Prohibition on Release of Customer Information. 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 

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this Order, whether acting directly or indirectly, are hereby temporarily 

RESTRAINED and ENJOINED from: 

a. selling, renting, leasing, transferring, or otherwise disclosing, 

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

card number, bank account number, Social Security number, or other 

financial or identifying information of any person that any Defendant 

obtained in connection with any activity that pertains to the subject 

matter of this Order; and 

b. benefitting from or using the name, address, birth date, 

telephone number, email address, credit card number, bank account 

number, Social Security number, or other financial or identifying 

information of any person that any Defendant obtained in connection with 

any activity that pertains to the subject matter of this Order. 

Provided, however, that Defendants may disclose such identifying information 

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

required by any law, regulation, or court order, or in any filings, pleadings, or 

discovery in this action in the manner required by the Federal Rules of Civil 

Procedure and by any protective order in the case. 

4. Asset Freeze. 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: 

i. owned or controlled, directly or indirectly, by any 

Defendant; 

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ii. held, in part or in whole, for the benefit of any 

Defendant; 

iii. in the actual or constructive possession of any 

Defendant; or 

iv. 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 mailboxes, 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 Paragraph shall include: (1) all Assets of Defendants 

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

this 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 

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Paragraph does not prohibit any transfers to the Receiver or repatriation of 

foreign Assets specifically required by this order. 

5. Duties of Asset Holders and Other Third Parties. 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: 

(1) 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; (2) 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 (3) 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 

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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 mailbox, 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 the FTC’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 Paragraph: 

i. The identification number of each such account or 

Asset; 

ii. 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 

iii. The identification of any safe deposit box, commercial 

mailbox, 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 the FTC’s counsel or the Receiver, 

promptly provide the FTC’s counsel and the Receiver with copies of all 

records or other Documents pertaining to any account covered by this 

Paragraph 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 

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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 mailboxes, and storage 

facilities. 

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

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

6. Financial Disclosures. Each Defendant, within five (5) days of 

service of this Order upon them, shall prepare and deliver to the FTC’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 Corporate Defendant; and 

b. completed Attachment C (IRS Form 4506, Request for Copy 

of a Tax Return) for each Individual and Corporate Defendant. 

7. Foreign Asset Repatriation. Within five (5) days following the 

service of this Order, each Defendant shall: 

a. Provide the FTC’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 that 

are: 

i. titled in the name, individually or jointly, of any 

Defendant; 

ii. 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 

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iii. under the direct or indirect control, whether jointly or 

singly, of any Defendant; 

b. Take all steps necessary to provide the FTC’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 that are: 

i. titled in the name, individually or jointly, of any 

Defendant; 

ii. 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 

iii. under the direct or indirect control, whether jointly or 

singly, of any Defendant; and 

d. The same business day as any repatriation, 

i. notify the Receiver and counsel for the FTC of the 

name and location of the financial institution or other entity that is 

the recipient of such Documents or Assets; and 

ii. serve this Order on any such financial institution or 

other entity. 

8. Non-Interference with Repatriation. 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 taking any action, directly or indirectly, 

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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. 

9. Consumer Credit Reports. the FTC 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, upon written request, any credit 

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

the FTC. 

10. Preservation of Records. Defendants, Defendants’ officers, agents, 

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

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

directly or indirectly, are hereby temporarily RESTRAINED and ENJOINED 

from: 

a. Destroying, erasing, falsifying, writing over, mutilating, 

concealing, altering, transferring, or otherwise disposing of, in any 

manner, directly or indirectly, Documents that relate to: 

i. the business, business practices, Assets, or business or 

personal finances of any Defendant; 

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ii. the business practices or finances of entities directly or 

indirectly under the control of any Defendant; or 

iii. 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. 

11. Report of New Business Activity. 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 the FTC’s counsel and 

the Receiver with a written statement disclosing: 

a. the name of the business entity; 

b. 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. 

12. Temporary Receiver. Thomas W. McNamara 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. 

13. Duties and Authority of Receiver. The Receiver is directed and 

authorized to accomplish the following: 

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a. Assume full control of Receivership Entities by removing, as 

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

independent contractor, employee, attorney, or agent of any Receivership 

Entity from control of, management of, or participation in, the affairs of 

the Receivership Entity; 

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

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

any Receivership Entity, 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 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 

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businesses. Such steps may include, but are not limited to, any of the 

following, as the Receiver deems necessary or advisable: 

i. 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 

ii. 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 the FTC’s 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; 

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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 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 FTC s’ 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 

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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 FTC s’ 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 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; and 

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 

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the Receivership Entities cannot be accessed by the public, or are 

answered solely to provide consumer education or information regarding 

the status of operations. 

14. Transfer of Receivership Property to Receiver. 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; 

d. All computers, electronic devices, mobile devices, and 

machines used to conduct the business of the Receivership Entities; 

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 

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of communication, accounts, computer systems (onsite and remote), 

Electronic Data Hosts, or other property. 

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

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

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

motion seeking compliance or a contempt citation. 

15. Provision of Information to Receiver. 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; 

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. 

16. Cooperation with the Receiver. 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 

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

the Receivership Entities. 

17. Non-Interference with the Receiver. 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 temporarily 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. 

18. Stay of Actions. Except by leave of this Court, during the pendency 

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

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

with any of them, who receive actual notice of this Order, and their 

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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; and 

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 

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. 

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19. Compensation of Receiver. 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. 

20. Receiver’s Bond. The Receiver shall file with the Clerk of this 

Court a bond in the sum of $15,000 with sureties to be approved by the Court, 

conditioned that the Receiver will well and truly perform the duties of the office 

and abide by and perform all acts the Court directs. 

21. Receiver’s Reports. The Receiver shall report to this Court on or 

before any date set for a hearing on whether a Preliminary Injunction should 

issue, regarding: 

a. the steps taken by the Receiver to implement the terms of 

this Order; 

b. the value of all liquidated and unliquidated assets of the 

Receivership Entities; 

c. the sum of all liabilities of the Receivership Entities; 

d. the steps the Receiver intends to take in the future to: 

i. prevent any diminution in the value of assets of the 

Receivership Entities; 

ii. pursue receivership assets from third parties; and 

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iii. adjust the liabilities of the Receivership Entities, if 

appropriate; 

e. whether the business of the Receivership Entities can be 

operated lawfully and profitably; and 

f. any other matters that the Receiver believes should be 

brought to the Court’s attention. 

Provided, however, that if any of the required information would hinder the 

Receiver’s ability to pursue receivership assets, the portions of the Receiver’s 

report containing such information may be filed under seal and not served on the 

parties. 

22. Immediate Access to Business Premises and Records. 

a. In order to allow the FTC and the Receiver to preserve 

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

FTC 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, 151 N. Kraemer Boulevard, 

Suite 100, Placentia, California 92870, or 1665 E. 4th Street, Suite 208, 

Santa Ana, California 92075, 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. The FTC 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. The FTC shall return any removed 

materials to the Receiver within five (5) business days of completing 

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inventorying and copying, or such time as is agreed upon by the FTC and 

the Receiver; 

c. The FTC’s access to the Receivership Entities’ documents 

pursuant to this Paragraph shall not provide grounds for any Defendant to 

object to any subsequent request for documents served by the FTC; 

d. The FTC and the Receiver, and their representatives, 

agents, contractors, and assistants, are authorized to obtain the assistance 

of federal, state, and local law enforcement officers as they deem 

necessary to effect service and to implement peacefully the provisions of 

this Order; 

e. If any Documents, computers, or electronic storage devices 

containing information related to the business practices or finances of the 

Receivership Entities are at a location other than those listed herein, 

including personal residence(s) of any Defendant, then, immediately upon 

receiving notice of this order, Defendants and 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; 

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; and 

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g. Defendants shall contact the FTC’s counsel within three (3) 

days of the service of this Order to make arrangements for production of 

all Documents not kept, stored, or maintained at 151 N. Kraemer 

Boulevard, Suite 100, Placentia, California 92870, or 1665 E. 4th Street, 

Suite 208, Santa Ana, California 92075, related to the business activities 

alleged in the complaint for inspection, inventory, and/or copying. 

23. Distribution of Order by Defendants. Defendants shall 

immediately provide a copy of this Order to each affiliate, telemarketer, 

marketer, sales entity, successor, assign, member, officer, director, employee, 

agent, independent contractor, client, attorney, spouse, subsidiary, division, and 

representative of any Defendant, and shall, within ten (10) days from the date of 

entry of this Order, and provide the FTC 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. 

24. Expedited Discovery. 

a. Notwithstanding the provisions of Rules 26(d) and (f) and 

Rule 30(a)(2)(A)(iii), and pursuant to Rules 30(a), 33, 34, and 45, the 

FTC and the Receiver are granted leave, at any time after service of this 

Order, to conduct limited expedited discovery for the purpose of 

discovering: 

i. 

Assets; 

the nature, location, status, and extent of Defendants’ 

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ii. the nature, location, and extent of Defendants’ 

business transactions and operations; 

iii. Documents reflecting Defendants’ business 

transactions and operations; or 

iv. compliance with this Order. 

b. The limited expedited discovery set forth in this Paragraph 

shall proceed as follows: 

i. the FTC and the Receiver may take the deposition of 

parties and non-parties. 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) regarding 

subsequent depositions of an individual shall not apply to 

depositions taken pursuant to this Paragraph. Any such deposition 

taken pursuant to this Paragraph 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; 

ii. the FTC 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. 

iii. the FTC and the Receiver may serve upon parties 

interrogatories that require response within five (5) days after the 

FTC serves such interrogatories; 

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iv. The FTC and the Receiver may serve subpoenas upon 

non-parties that direct production or inspection within five (5) days 

of service. 

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

pursuant to this Paragraph, shall be sufficient if made by facsimile, 

email, or by overnight delivery. 

vi. Any expedited discovery taken pursuant to this 

Paragraph is in addition to, and is not subject to, the limits on 

discovery set forth in the Federal Rules of Civil Procedure and the 

Local Rules of this Court. The expedited discovery permitted by 

this Paragraph does not require a meeting or conference of the 

parties, pursuant to Rules 26(d) and (f). 

vii. The Parties are exempted from making initial 

disclosures under Rule 26(a)(1) until further order of this Court. 

25. Service of This Order. 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, 

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

FedEx, by agents and employees of the FTC, 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). For purposes of this Paragraph, service upon 

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

the entire entity. 

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26. Correspondence and Service on the FTC. For the purpose of this 

Order, all correspondence and service of pleadings on the FTC shall be 

addressed to the FTC’s counsel of record. 

27. Preliminary Injunction Hearing. Pursuant to Rule 65(b), 

Defendants shall appear before this Court on May 16, 2023, at 2:00 p.m. to show 

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

pending final ruling on the Complaint against Defendants, enjoining the 

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

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

be appropriate. 

28. Briefs and Affidavits Concerning Preliminary Injunction. 

a. Defendants shall file with the Court and serve on the FTC’s 

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

declarations, or legal memoranda no later than May 12, 2023, at 

12:00 noon. The FTC may file responsive or supplemental pleadings, 

materials, affidavits, or memoranda with the Court and serve the same on 

counsel for Defendants no later than May 15, 2023, at 12:00 noon. 

Provided that such affidavits, pleadings, motions, expert reports, 

declarations, legal memoranda, or oppositions must be served by personal 

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

party or parties no later than 12:00 noon on the appropriate dates set forth 

in this Paragraph. 

b. An evidentiary hearing on the FTC’s request for a 

preliminary injunction is not necessary unless Defendants demonstrate 

that they have, and intend to introduce, evidence that raises a genuine and 

material factual issue. The question of whether this Court should enter a 

preliminary injunction shall be resolved on the pleadings, declarations, 

exhibits, and memoranda filed by, and oral argument of, the parties. Live 

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testimony shall be heard only on further order of this Court. Any 

application to permit such testimony shall be filed with the Court and 

served on counsel for the other parties no later than May 12, 2023, at 

12:00 noon. Such application shall set forth the name, address, and 

telephone number of each proposed witness, a detailed summary or 

declaration revealing the substance of each proposed witness's expected 

testimony, and an explanation of why the taking of live testimony would 

be helpful to this Court. Any papers opposing a timely application to 

present live testimony or to present live testimony in response to another 

party's timely motion to present live testimony shall be filed with this 

Court and served on the other parties no later than May 15, 2023, at 

12:00 noon. 

29. Duration of the Order. This Order shall expire after the completion 

14 of the Preliminary Injunction Hearing, unless, before such time, the Order is 

extended for an additional period pursuant to Rule 65(b)(2). 

16 30. Retention of Jurisdiction. This Court shall retain jurisdiction of 

17 this matter for all purposes. 

18 31. Compliance with Rule 65(b)(2). This Order is issued on May 3, 

19 2023, at 10:15 a.m. See Fed. R. Civ. P. 65(b)(2). 

IT IS SO ORDERED. 

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22 Dated: May 3, 2023 

23 NITED ST ATES DISTRICT JUDGE 

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ATTACHMENT A 
 

FEDERAL TRADE COMMISSION 

FINANCIAL STATEMENT OF INDIVIDUAL DEFENDANT 

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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 

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67 Page ID #:1886 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 

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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 

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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: 

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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 

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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: 

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67 Page ID #:1891 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 collect bles, copyrights, patents, and other intellectual property. 

Property Category 

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

$ $ 

$ $ 

$ $ 

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6 of 10 Federal Trade Commission Financial Statement of Individual Defendant 

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67 Page ID #:1892 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 

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67 Page ID #:1893 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, descr be 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, descr be the asset and state its cost, if you know it. 

Initials: 

8 of 10 Federal Trade Commission Financial Statement of Individual Defendant 

Attachment A 
 

 

 

 

 

 

 

 

 

 

 

Case 8:23-cv-00699-JWH-ADS *SEALED* Document 32 *SEALED* Filed 05/03/23 Page 45 of 

67 Page ID #:1894 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 $ 

Distr butions from Partnerships, S-Corporations, 

and LLCs 

Source: 

$ 

Utilities 

$ 

Initials: 

9 of 10 Federal Trade Commission Financial Statement of Individual Defendant 

Attachment A 
 

 

 

 

 

 

_______________ ___________________________________ 

Page ID #:1895 Item 26. Combined Current Monthly Income and Expenses for You, Your Spouse, and Your Dependents (cont.) 

Distr butions from Trusts and Estates 

Source: $ Medical Expenses, Including Insurance $ 

Distr butions 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 

Case 8:23-cv-00699-JWH-ADS *SEALED* Document 32 *SEALED* Filed 05/03/23 Page 46 of 

67 

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 

Attachment A 
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67 Page ID #:1896 

ATTACHMENT B 
 

 

Case 8:23-cv-00699-JWH-ADS *SEALED* Document 32 *SEALED* Filed 05/03/23 Page 48 of 

67 Page ID #:1897

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. 

Attachment B 
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67 Page ID #:1898 

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 __________ 

Attachment B 
_________________________________________________________________________________ ______________ 

_________________________________________________________________________________ ______________ 

_________________________________________________________________________________ ______________ 

_________________________________________________________________________________ ______________ 

____________________________________________________________________ __________ _________________ 

____________________________________________________________________ __________ _________________ 

____________________________________________________________________ __________ _________________ 

____________________________________________________________________ __________ _________________ 

____________________________________________________________________ __________ _________________ 

_______________________________________________________________________________ ________________ 

_______________________________________________________________________________ ________________ 

_______________________________________________________________________________ ________________ 

_______________________________________________________________________________ ________________ 

_______________________________________________________________________________ ________________ 

Case 8:23-cv-00699-JWH-ADS *SEALED* Document 32 *SEALED* Filed 05/03/23 Page 50 of 

67 Page ID #:1899 

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 __________ 

Attachment B 
___________________________________________________________________ ___________________ _________ 

___________________________________________________________________ ___________________ _________ 

___________________________________________________________________ ___________________ _________ 

________________________________________________________________________________________________ 

__________________ __________________________________________________ __________________ ________ 

__________________ __________________________________________________ __________________ ________ 

__________________ __________________________________________________ __________________ ________ 

________________________________________________________________________________________________ 

_________________________________________________________ _________________ ______________________ 

_________________________________________________________ _________________ ______________________ 

_________________________________________________________ _________________ ______________________ 

Case 8:23-cv-00699-JWH-ADS *SEALED* Document 32 *SEALED* Filed 05/03/23 Page 51 of 

67 Page ID #:1900 

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 __________ 

Attachment B 
____________________ ______________________ ________________________________________ ____________ 

____________________ ______________________ ________________________________________ ____________ 

____________________ ______________________ ________________________________________ ____________ 

____________________ ______________________ ________________________________________ ____________ 

____________________ ______________________ ________________________________________ ____________ 

____________________________________________________________________________ ___________________ 

____________________________________________________________________________ ___________________ 

____________________________________________________________________________ ___________________ 

____________________________________________________________________________ ___________________ 

____________________ ___________________________ ________________________________________________ 

____________________ ___________________________ ________________________________________________ 

____________________ ___________________________ ________________________________________________ 

____________________ ___________________________ ________________________________________________ 

____________________ ___________________________ ________________________________________________ 

Case 8:23-cv-00699-JWH-ADS *SEALED* Document 32 *SEALED* Filed 05/03/23 Page 52 of 

67 Page ID #:1901 

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 __________ 

Attachment B 
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67 Page ID #:1902 

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 __________ 

Attachment B 
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67 Page ID #:1903 

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 __________ 

Attachment B 
__________________ ___________________________________________________________________ __________ 

__________________ ___________________________________________________________________ __________ 

__________________ ___________________________________________________________________ __________ 

__________________ ___________________________________________________________________ __________ 

__________________ ___________________________________________________________________ __________ 

Case 8:23-cv-00699-JWH-ADS *SEALED* Document 32 *SEALED* Filed 05/03/23 Page 55 of 

67 Page ID #:1904 

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 __________ 

Attachment B 
_________ _____________ ______________________ __________________ _______________________ ________ 

_________ _____________ ______________________ __________________ _______________________ ________ 

_________ _____________ ______________________ __________________ _______________________ ________ 

_________ _____________ ______________________ __________________ _______________________ ________ 

Case 8:23-cv-00699-JWH-ADS *SEALED* Document 32 *SEALED* Filed 05/03/23 Page 56 of 

67 Page ID #:1905 

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 __________ 

Attachment B 
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67 Page ID #:1906 

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 __________ 

Attachment B 
 

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67 Page ID #:1907 

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 __________ 

Attachment B 
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67 Page ID #:1908 

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 __________ 

Attachment B 
__________________________________________ _____________________________________________________ 

__________________________________________ _____________________________________________________ 

__________________________________________ _____________________________________________________ 

__________________________________________ _____________________________________________________ 

__________________________________________ _____________________________________________________ 

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67 Page ID #:1909 

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 __________ 

Attachment B 
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67 Page ID #:1910 

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 __________ 

Attachment B 
___________________ ____________________________________________________________________________ 

___________________ ____________________________________________________________________________ 

___________________ ____________________________________________________________________________ 

___________________ ____________________________________________________________________________ 

___________________ ____________________________________________________________________________ 

___________________ ____________________________________________________________________________ 

___________________ ____________________________________________________________________________ 

___________________ ____________________________________________________________________________ 

___________________ ____________________________________________________________________________ 

______________________________ _____________________________________________________ 

_____________________________________________________ 

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67 Page ID #:1911 

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 __________ 

Attachment B 
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67 Page ID #:1912 

ATTACHMENT C 
□ 

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Case 8:23-cv-00699-JWH-ADS *SEALED* Document 32 *SEALED* Filed 05/03/23 Page 64 of 

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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) 

Attachment C 
Case 8:23-cv-00699-JWH-ADS *SEALED* Document 32 *SEALED* Filed 05/03/23 Page 65 of 

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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. 

Attachment C 

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. 
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ATTACHMENT D 
 

 

 

 

 

 

 

 

Case 8:23-cv-00699-JWH-ADS *SEALED* Document 32 *SEALED* Filed 05/03/23 Page 67 of 

67 Page ID #:1916 

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:__________________________ 

Attachment D