1 

 2 

 3 

 4 

 5 

 6 

 7 

 8 

 9 

 10 

 11 

 12 

 13 

 14 

 15 

 16 

 17 

 18 

 19 

 20 

 21 

 22 

 23 

 24 

 25 

 26 

 27 

 28 

STEPHEN T. FAIRCHILD 

WA Bar No. 41214; sfairchild@ftc.gov 

RICHARD MCKEWEN

WA Bar No. 45041; rmckewen@ftc.gov 

FEDERAL TRADE COMMISSION 

915 Second Avenue, Suite 2896 

Seattle, WA 98174 

Tel.: (206) 220-6350; Fax: (206) 220-6366 

ROBERT J. QUIGLEY, Local Counsel 

CA Bar No. 302879; rquigley@ftc.gov 

FEDERAL TRADE COMMISSION 

10990 Wilshire Boulevard, Suite 400 

Los Angeles, CA 90024 

Tel.: (310) 824-4300; Fax: (310) 824-4380 

Attorneys for Plaintiff 

UNITED STATES DISTRICT COURT 

CENTRAL DISTRICT OF CALIFORNIA 

FEDERAL TRADE COMMISSION, 

 Plaintiff, 

 v. 

AMERICAN FINANCIAL SUPPORT 

SERVICES INC., et al., 

 Defendants. 

Civ. No. 8:19-cv-02109-JVS (ADSx) 

STIPULATED ORDER FOR 

PERMANENT INJUNCTION AND 

MONETARY JUDGMENT AS TO 

DEFENDANTS CAREY G. HOWE, 

ANNA C. HOWE, SHUNMIN HSU, 

RUDDY PALACIOS, AND OLIVER 

POMAZI 

Case 8:19-cv-02109-JVS-ADS Document 145 Filed 09/09/20 Page 1 of 46 Page ID #:4130
 

 1 

 2 

 3 

 4 

 5 

 6 

 7 

 8 

 9 

 10 

 11 

 12 

 13 

 14 

 15 

 16 

 17 

 18 

 19 

 20 

 21 

 22 

 23 

 24 

 25 

 26 

 27 

 28 

Plaintiff, the Federal Trade Commission (“Commission” or “FTC”), filed its 

Complaint for Permanent Injunction and Other Equitable Relief (“Complaint”), for 

a permanent injunction and other equitable relief in this matter, pursuant to 

Sections 13(b) and 19 of the Federal Trade Commission Act (“FTC Act”), 15 

U.S.C. §§ 53(b), 57b. The Commission and Defendants Carey G. Howe, Anna C. 

Howe, Shunmin Hsu, Ruddy Palacios, and Oliver Pomazi (each a “Stipulating 

Defendant,” and collectively, “Stipulating Defendants”) stipulate to the entry of 

this Stipulated Order for Permanent Injunction and Monetary Judgment as to 

Defendants Carey G. Howe, Anna C. Howe, Shunmin Hsu, Ruddy Palacios, and 

Oliver Pomazi (“Order”) to resolve all matters in dispute in this action between 

them. 

THEREFORE, IT IS ORDERED as follows: 

FINDINGS

1. This Court has jurisdiction over this matter. 

2. The Complaint charges that Defendants participated in deceptive acts or 

practices in violation of Section 5 of the FTC Act, 15 U.S.C. § 45, and the 

Telemarketing Sales Rule, 16 C.F.R. pt. 310, in the marketing and sale of student 

loan debt relief services. 

3. Stipulating Defendants neither admit nor deny any of the allegations in the 

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

action, Stipulating Defendants admit the facts necessary to establish jurisdiction. 

4. Stipulating Defendants waive and release any claim that they may have 

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

prosecution of this action through the date of this Order, and agree to bear their 

own costs and attorney fees. Furthermore, Stipulating Defendants waive and 

release any claims that they may have against the Commission, the Receiver, and 

their agents that relate to this action. 

Case 8:19-cv-02109-JVS-ADS Document 145 Filed 09/09/20 Page 2 of 46 Page ID #:4131
 

 1 

 2 

 3 

 4 

 5 

 6 

 7 

 8 

 9 

 10 

 11 

 12 

 13 

 14 

 15 

 16 

 17 

 18 

 19 

 20 

 21 

 22 

 23 

 24 

 25 

 26 

 27 

 28 

5. Stipulating Defendants and the Commission waive all rights to appeal or 

otherwise challenge or contest the validity of this Order. 

DEFINITIONS

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

A. “Assisting Others” includes: 

 1. 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; 

 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; or 

 5. performing marketing, billing, or payment services of any kind. 

B. “Debt Relief Product or Service” means: 

1. With respect to any mortgage, loan, debt, or obligation between a 

Person and one or more creditors or debt collectors of (a) secured loans or 

(b) unsecured student loans, any Product or Service represented, expressly or 

by implication, to: 

a. stop, prevent, or postpone any mortgage or deed of foreclosure 

sale for a Person’s dwelling, any other sale of collateral, any 

repossession of a Person’s dwelling or other collateral, or otherwise 

Case 8:19-cv-02109-JVS-ADS Document 145 Filed 09/09/20 Page 3 of 46 Page ID #:4132
 

 1 

 2 

 3 

 4 

 5 

 6 

 7 

 8 

 9 

 10 

 11 

 12 

 13 

 14 

 15 

 16 

 17 

 18 

 19 

 20 

 21 

 22 

 23 

 24 

 25 

 26 

 27 

 28 

save a Person’s dwelling or other collateral from foreclosure or 

repossession; 

b. negotiate, obtain, or arrange a modification, or renegotiate, 

settle, or in any way alter any terms of the mortgage, loan, debt, or 

obligation, including a reduction in the amount of interest, principal 

balance, monthly payments, or fees owed by a Person to a creditor or 

debt collector of secured loans or unsecured student loans; 

c. obtain any forbearance or modification in the timing of 

payments from any secured, or unsecured student loan, holder or 

servicer of any mortgage, loan, debt, or obligation; 

d. negotiate, obtain, or arrange any extension of the period of time 

within which a Person may (i) cure his or her default on the mortgage, 

loan, debt, or obligation, (ii) reinstate his or her mortgage, loan, debt, 

or obligation, (iii) redeem a dwelling or other collateral, or (iv) 

exercise any right to reinstate the mortgage, loan, debt, or obligation 

or redeem a dwelling or other collateral; 

e. obtain any waiver of an acceleration clause or balloon payment 

contained in any promissory note or contract secured by any dwelling 

or other collateral; or 

f. negotiate, obtain, or arrange (i) a short sale of a dwelling or 

other collateral, (ii) a deed-in-lieu of foreclosure, or (iii) any other 

disposition of a mortgage, loan, debt, or obligation other than a sale to 

a third party that is not the secured, or unsecured student loan, holder. 

The foregoing shall include any manner of claimed assistance, including 

auditing or examining a Person’s application for the mortgage, loan, debt, or 

obligation. 

// 

// 

Case 8:19-cv-02109-JVS-ADS Document 145 Filed 09/09/20 Page 4 of 46 Page ID #:4133
 

 1 

 2 

 3 

 4 

 5 

 6 

 7 

 8 

 9 

 10 

 11 

 12 

 13 

 14 

 15 

 16 

 17 

 18 

 19 

 20 

 21 

 22 

 23 

 24 

 25 

 26 

 27 

 28 

2. With respect to any loan, debt, or obligation between a Person and one 

or more creditors or debt collectors of unsecured student loans, any Product 

or Service represented, expressly or by implication, to: 

a. repay one or more unsecured student loans, debts, or 

obligations; or 

b. combine unsecured student loans, debts, or obligations into one 

or more new loans, debts, or obligations. 

C. “Person” means any individual, group, unincorporated association, limited 

or general partnership, corporation, or other business entity. 

D. “Product or Service” means any good or service, including any plan or 

program. 

E. “Stipulating Defendants” means Carey G. Howe, Anna C. Howe, Shunmin 

“Mike” Hsu, Ruddy Palacios a/k/a Ruddy Barahona, and Oliver Pomazi, and any 

other names by which they might be known, individually, collectively, or in any 

combination. 

ORDER 

I. BAN ON DEBT RELIEF PRODUCTS AND SERVICES 

 IT IS ORDERED that Stipulating Defendants are permanently restrained and 

enjoined, whether acting directly or through an intermediary, from advertising, 

marketing, promoting, offering for sale, or selling, or Assisting Others in the 

advertising, marketing, promoting, offering for sale, or selling, of any Debt Relief 

Product or Service. 

II. PROHIBITION AGAINST MISREPRESENTATIONS 

 IT IS FURTHER ORDERED that Stipulating Defendants, Stipulating 

Defendants’ officers, agents, employees, and attorneys, and all other Persons in 

active concert or participation with any of them, who receive actual notice of this 

Order, whether acting directly or indirectly, in connection with the advertising, 

marketing, promoting, offering for sale, or selling of any Product or Service, are 

Case 8:19-cv-02109-JVS-ADS Document 145 Filed 09/09/20 Page 5 of 46 Page ID #:4134
 

 1 

 2 

 3 

 4 

 5 

 6 

 7 

 8 

 9 

 10 

 11 

 12 

 13 

 14 

 15 

 16 

 17 

 18 

 19 

 20 

 21 

 22 

 23 

 24 

 25 

 26 

 27 

 28 

permanently restrained and enjoined from misrepresenting, or Assisting Others in 

misrepresenting, expressly or by implication: 

A. any material aspect of the nature or terms of any refund, cancellation, 

exchange, or repurchase policy, including the likelihood of a consumer obtaining a 

full or partial refund, or the circumstances in which a full or partial refund will be 

granted to the consumer; 

B. that any Person is affiliated with, endorsed or approved by, or otherwise 

connected to any other Person; government entity; public, non-profit, or other noncommercial program; or any other program; 

C. the nature, expertise, position, or job title of any Person who provides any 

Product or Service; 

D. that any Person providing a testimonial has purchased, received, or used the 

Product or Service; 

E. that the experience represented in a testimonial of the product, service, plan, 

or program represents the Person’s actual experience resulting from the use of the 

product, service, plan, or program under the circumstances depicted in the 

advertisement; or 

F. any other fact material to consumers concerning any Product or Service, 

such as: the total costs; any material restrictions, limitations, or conditions; or any 

material aspect of its performance, efficacy, nature, or central characteristics. 

III. PROHIBITION AGAINST UNSUBSTANTIATED CLAIMS 

 IT IS FURTHER ORDERED that Stipulating Defendants, Stipulating 

Defendants’ officers, agents, employees, and attorneys, and all other Persons in 

active concert or participation with any of them, who receive actual notice of this 

Order, whether acting directly or indirectly, in connection with the promoting or 

offering for sale of any Product or Service, are permanently restrained and 

enjoined from making any representation or Assisting Others in making any 

representation, expressly or by implication, about the benefits, performance, or 

Case 8:19-cv-02109-JVS-ADS Document 145 Filed 09/09/20 Page 6 of 46 Page ID #:4135
 

 1 

 2 

 3 

 4 

 5 

 6 

 7 

 8 

 9 

 10 

 11 

 12 

 13 

 14 

 15 

 16 

 17 

 18 

 19 

 20 

 21 

 22 

 23 

 24 

 25 

 26 

 27 

 28 

efficacy of any Product or Service, unless the representation is non-misleading, 

including that, at the time such representation is made, they possess and rely upon 

competent and reliable evidence that is sufficient in quality and quantity based on 

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. 

IV. INJUNCTION RELATING TO TELEMARKETING

 IT IS FURTHER ORDERED that Stipulating Defendants, Stipulating 

Defendants’ officers, agents, and employees, and all other Persons in active 

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

whether acting directly or indirectly, in connection with telemarketing, advertising, 

marketing, promoting, offering for sale, or selling of any Product or Service, are 

hereby permanently restrained and enjoined from: 

A. Misrepresenting, directly or by implication, in the sale of goods or services 

any material aspect of the performance, efficacy, nature, or central characteristics 

of goods or services that are the subject of a sales offer; and 

B. Violating the FTC’s Telemarketing Sales Rule, 16 C.F.R. pt. 310, a copy of 

which is attached as Attachment A. 

V. MONETARY JUDGMENT AND PARTIAL SUSPENSION

IT IS FURTHER ORDERED that: 

A. Judgment in the amount of Forty-Three Million Three Hundred ThirtySeven Thousand Two Hundred Ninety-Two Dollars and Eighty-Three Cents 

($43,337,292.83) is entered in favor of the Commission against Stipulating 

Defendants, jointly and severally, as equitable monetary relief. 

B. In partial satisfaction of the judgment imposed by Subsection A, the 

Stipulating Defendants are each ordered to pay to the Commission the following 

amounts: 

Carey G. Howe and Anna C. Howe: $133,496.42 

Case 8:19-cv-02109-JVS-ADS Document 145 Filed 09/09/20 Page 7 of 46 Page ID #:4136
 

 1 

 2 

 3 

 4 

 5 

 6 

 7 

 8 

 9 

 10 

 11 

 12 

 13 

 14 

 15 

 16 

 17 

 18 

 19 

 20 

 21 

 22 

 23 

 24 

 25 

 26 

 27 

 28 

Shunmin Hsu: $43,252.16 

Ruddy Palacios: $260,582.00 

Oliver Pomazi: $54,505.00 

which, as Stipulating Defendants stipulate, their undersigned counsel will hold in 

escrow for no purpose other than payment to the Commission. In addition, 

Stipulating Defendants shall cause to be paid to the Commission all funds held in 

their counsel’s client trust account pursuant to the Court’s order of January 27, 

2020 (Doc. 116). Such payments must be made within seven (7) days of entry of 

this Order by electronic fund transfer in accordance with instructions provided by a 

representative of the Commission. Upon such payments and, if applicable, all 

additional payments, asset transfers, and delivery of proof of deeds of trust

pursuant to Subsection C below, the remainder of the judgment is suspended, 

subject to the Subsections below. 

C. In addition to making the payments required by Subsection B, the following 

Stipulating Defendants shall make an additional deferred payment in the amounts 

listed below. To secure the deferred payments, the Stipulating Defendants hereby 

grant the FTC a lien and security interest in the real property indicated: 

 Carey G. Howe and Anna C. Howe: $80,302.00 (8282 Valencia 

Drive, Huntington Beach, California 92647) 

 Shunmin Hsu: $237,840.76 (12602 Barrett Lane, North Tustin, 

California 92705) 

 Ruddy Palacios: $24,958.29 (1912 Alcor Street, Lomita, California 

90717) 

Within thirty (30) days of entry of this Order, each of these Stipulating Defendants 

shall either record and deliver to the FTC a deed of trust in the real property in the 

amount indicated, or pay the FTC the full amount of the deferred payment. Any 

Stipulating Defendant who records and delivers to the FTC a deed of trust must 

Case 8:19-cv-02109-JVS-ADS Document 145 Filed 09/09/20 Page 8 of 46 Page ID #:4137
 

 1 

 2 

 3 

 4 

 5 

 6 

 7 

 8 

 9 

 10 

 11 

 12 

 13 

 14 

 15 

 16 

 17 

 18 

 19 

 20 

 21 

 22 

 23 

 24 

 25 

 26 

 27 

 28 

pay the FTC the full amount of the deferred payment no later than one-hundred 

eighty (180) days following entry of this Order. 

 Each Stipulating Defendant represents and acknowledges that, as to that 

Stipulating Defendant’s above-listed property, the FTC is relying on the material 

representations that the Stipulating Defendant is the sole owner of the property or 

is otherwise empowered to obtain a voluntary lien and deed of trust thereon; title to 

the property is marketable; and the property is not encumbered by any other lien, 

mortgage, deed of trust, assignment, pledge, security interest, or other interest not 

identified in the Financial Attestations listed in Subsection D below. Stipulating 

Defendants shall maintain in good working order, keep in the same condition, 

cause existing insurance coverage for the property to remain in force, and take no 

action to diminish the value of the property, including any structures, fixtures, and 

appurtenances thereto, as of the date Stipulating Defendants executed their 

Financial Attestations listing the value of such property. Stipulating Defendants 

shall be responsible for paying all fees, costs, or other expenses related to 

recording the voluntary lien and deed of trust described above. 

 Within ten (10) days of the full payment of a Stipulating Defendant’s 

payment obligation under this Subsection C, the FTC will execute and deliver to 

such Stipulating Defendant a fully executed conveyance releasing the FTC’s lien 

and security interest in the subject property, which upon the Stipulating 

Defendant’s receipt may be immediately perfected by recordation. 

D. In the event that any Stipulating Defendant fails to make a required payment 

when due under Subsection B or C, the entire judgment amount, less any amount 

previously paid, shall immediately become due and payable by that Stipulating 

Defendant. Interest computed at the rate prescribed under 28 U.S.C. § 1961, as 

amended, shall immediately begin to accrue on the unpaid balance. Time is of the 

essence for the payments specified in this Section. 

Case 8:19-cv-02109-JVS-ADS Document 145 Filed 09/09/20 Page 9 of 46 Page ID #:4138
 

 1 

 2 

 3 

 4 

 5 

 6 

 7 

 8 

 9 

 10 

 11 

 12 

 13 

 14 

 15 

 16 

 17 

 18 

 19 

 20 

 21 

 22 

 23 

 24 

 25 

 26 

 27 

 28 

E. The Commission’s agreement to the suspension of part of the judgment is 

expressly premised upon the truthfulness, accuracy, and completeness of 

Defendants’ sworn financial statements and related documents (collectively, 

“Financial Attestations”) submitted to the Commission or attached to this Order, 

namely: 

1. the Financial Statement of Individual Defendant Carey G. Howe 

signed on November 16, 2019; 

2. the Addendum to Carey G. Howe’s Individual Financial Disclosure 

Form signed on February 14, 2020, including the additional items; 

3. the Second Addendum to Carey G. Howe’s Individual Financial 

Disclosure Form signed on March 19, 2020, including the attachments; 

4. the Third Addendum to Cary G. Howe’s Individual Financial 

Disclosure Form signed on July 1, 2020; 

5. the Declaration of Carey G. Howe executed on July 24, 2020; 

6. the Declaration of Anna C. Howe executed on July 21, 2020; 

7. the Financial Statement of Individual Defendant Shunmin Hsu signed 

on November 17, 2019, including the attachments; 

8. the Addendum to Shunmin Hsu’s Financial Disclosure Form signed 

on February 12, 2020, including the additional items; 

9. the Second Addendum to Shunmin Hsu’s Financial Disclosure Form 

signed on July 2, 2020; 

10. the Declaration of Shunmin Hsu executed on July 23, 2020; 

11. the Financial Statement of Individual Defendant Ruddy Palacios 

signed on November 18, 2019, including the attachments; 

12. the Addendum to Ruddy Palacios’s Financial Disclosure Form signed 

on February 13, 2020, including the additional items; 

13. the Second Addendum to Ruddy Palacios’s Financial Disclosure form 

signed on June 30, 2020; 

Case 8:19-cv-02109-JVS-ADS Document 145 Filed 09/09/20 Page 10 of 46 Page ID

 #:4139
 

 1 

 2 

 3 

 4 

 5 

 6 

 7 

 8 

 9 

 10 

 11 

 12 

 13 

 14 

 15 

 16 

 17 

 18 

 19 

 20 

 21 

 22 

 23 

 24 

 25 

 26 

 27 

 28 

14. the Payoff Statement for Ruddy Palacios dated June 11, 2020; 

15. the Declaration of Ruddy Palacios executed on July 24, 2020; 

16. the Financial Statement of Individual Defendant Oliver Pomazi signed 

on November 15, 2019; 

17. the Addendum to Oliver Pomazi’s Financial Disclosure Form signed 

on February 12, 2020, including the additional items; and 

18. the Second Addendum to Oliver Pomazi’s Financial Disclosure Form 

signed on July 2, 2020. 

F. The suspension of the judgment will be lifted as to any Stipulating 

Defendant if, upon motion by the Commission, the Court finds that Stipulating 

Defendant failed to disclose any material asset, materially misstated the value of 

any asset, or made any other material misstatement or omission in the Financial 

Attestations identified above. 

G. If the suspension of the judgment is lifted, the judgment becomes 

immediately due as to that Stipulating Defendant in the amount specified in 

Subsection A above (which the parties stipulate only for purposes of this Section 

represents the consumer injury alleged in the Complaint), less any payment 

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

entry of this Order. 

VI. ADDITIONAL MONETARY PROVISIONS

 IT IS FURTHER ORDERED that: 

A. Stipulating Defendants relinquish dominion and all legal and equitable right, 

title, and interest in all assets transferred pursuant to this Order and may not seek 

the return of any assets. 

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

proof, in any subsequent civil litigation by or on behalf of the Commission, 

including in a proceeding to enforce its rights to any payment or monetary 

Case 8:19-cv-02109-JVS-ADS Document 145 Filed 09/09/20 Page 11 of 46 Page ID

 #:4140
 

 1 

 2 

 3 

 4 

 5 

 6 

 7 

 8 

 9 

 10 

 11 

 12 

 13 

 14 

 15 

 16 

 17 

 18 

 19 

 20 

 21 

 22 

 23 

 24 

 25 

 26 

 27 

 28 

judgment pursuant to this Order, such as a nondischargeability complaint in any 

bankruptcy case. 

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

an action by the Commission pursuant to Section 523(a)(2)(A) of the Bankruptcy 

Code, 11 U.S.C. § 523(a)(2)(A), and this Order will have collateral estoppel effect 

for such purposes. 

D. Stipulating Defendants acknowledge that their Taxpayer Identification 

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

Stipulating Defendants previously submitted to the Commission, may be used for 

collecting and reporting on any delinquent amount arising out of this Order, in 

accordance with 31 U.S.C. § 7701. 

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

into a fund administered by the Commission or its designee to be used for 

equitable relief, including consumer redress and any attendant expenses for the 

administration of any redress fund. If a representative of the Commission decides 

that direct redress to consumers is wholly or partially impracticable or money 

remains after redress is completed, the Commission may apply any remaining 

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

as it determines to be reasonably related to Defendants’ practices alleged in the 

Complaint. Any money not used for such equitable relief is to be deposited to the 

U.S. Treasury as disgorgement. Stipulating Defendants have no right to challenge 

any actions the Commission or its representatives may take pursuant to this 

Subsection. 

F. The asset freeze imposed by the preliminary injunction order entered on 

December 17, 2019 (Doc. 79), is modified to permit the payments identified in 

Section V.B–C. The asset freeze shall otherwise remain in full force and effect 

until the completion of all such payments, after which the asset freeze shall be 

dissolved as to the Stipulating Defendants.

Case 8:19-cv-02109-JVS-ADS Document 145 Filed 09/09/20 Page 12 of 46 Page ID

 #:4141
 

 1 

 2 

 3 

 4 

 5 

 6 

 7 

 8 

 9 

 10 

 11 

 12 

 13 

 14 

 15 

 16 

 17 

 18 

 19 

 20 

 21 

 22 

 23 

 24 

 25 

 26 

 27 

 28 

G. Upon completion of all payments identified in Section V.B–C, the Court’s 

order of January 27, 2020, is dissolved. 

 VII. CUSTOMER INFORMATION

IT IS FURTHER ORDERED that Stipulating Defendants, their officers, 

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

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

acting directly or indirectly, in connection with the advertising, marketing, 

promoting, offering for sale, or selling of any Product or Service, are permanently 

restrained and enjoined from directly or indirectly: 

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

to efficiently administer consumer redress. If a representative of the Commission 

requests in writing any information related to redress, Stipulating Defendants must 

provide it, in the form prescribed by the Commission, within 14 days; 

B. disclosing, using, or benefitting from customer information, including the 

name, address, telephone number, email address, social security number, other 

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

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

Defendant obtained prior to entry of this Order in connection with the sale and 

marketing of student loan debt relief services; and 

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

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

representative of the Commission. 

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

may be disclosed, to the extent requested by a government agency or required by 

law, regulation, or court order. 

// 

// 

// 

Case 8:19-cv-02109-JVS-ADS Document 145 Filed 09/09/20 Page 13 of 46 Page ID

 #:4142
 

 1 

 2 

 3 

 4 

 5 

 6 

 7 

 8 

 9 

 10 

 11 

 12 

 13 

 14 

 15 

 16 

 17 

 18 

 19 

 20 

 21 

 22 

 23 

 24 

 25 

 26 

 27 

 28 

VIII. COOPERATION

IT IS FURTHER ORDERED that Stipulating Defendants must fully 

cooperate with representatives of the Commission and the Receiver in this case and 

in any investigation related to or associated with the transactions or the 

occurrences that are the subject of the Complaint. Stipulating Defendants must 

provide truthful and complete information, evidence, and testimony. Stipulating 

Defendants must appear and cause their employees, representatives, or agents to 

appear for interviews, discovery, hearings, trials, and any other proceedings that a 

Commission or Receiver’s representative may reasonably request upon five (5) 

days written notice, or other reasonable notice, at such places and times as a 

Commission or Receiver’s representative may designate, without the service of a 

subpoena. 

IX. ORDER ACKNOWLEDGMENTS

IT IS FURTHER ORDERED that Stipulating Defendants obtain 

acknowledgments of receipt of this Order: 

A. Each Stipulating Defendant, within 7 days of entry of this Order, must 

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

under penalty of perjury, in the form attached to this Order. 

B. For 15 years after entry of this Order, each Stipulating Defendant for any 

business that such Stipulating Defendant, individually or collectively with any 

other Defendants, is the majority owner or controls directly or indirectly, must 

deliver a copy of this Order to: (1) all principals, officers, directors, and LLC 

managers and members; (2) all employees having managerial responsibilities for 

the conduct specified in Section IV and all agents and representatives who 

participate in the conduct specified in Section IV; (3) any payment processor or 

lead broker or generator used by the business; and (4) any business entity resulting 

from any change in structure as set forth in the Section titled Compliance 

Reporting. Delivery must occur within 7 days of entry of this Order for current 

Case 8:19-cv-02109-JVS-ADS Document 145 Filed 09/09/20 Page 14 of 46 Page ID

 #:4143
 

 1 

 2 

 3 

 4 

 5 

 6 

 7 

 8 

 9 

 10 

 11 

 12 

 13 

 14 

 15 

 16 

 17 

 18 

 19 

 20 

 21 

 22 

 23 

 24 

 25 

 26 

 27 

 28 

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

responsibilities. 

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

copy of this Order, that Stipulating Defendant must obtain and deliver to the 

Commission, within 30 days, a signed and dated acknowledgment of receipt of this 

Order, in the form attached to this Order. 

X. COMPLIANCE REPORTING

IT IS FURTHER ORDERED that Stipulating Defendants make timely 

submissions to the Commission: 

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

compliance report, sworn under penalty of perjury. In the compliance report, each 

Individual Defendant must: 

1. identify all telephone numbers and all physical, postal, email and 

Internet addresses, including all residences, as designated points of contact, 

which representatives of the Commission may use to communicate with 

Stipulating Defendant; 

2. identify all business activities, including any business for which such 

Stipulating Defendant performs services whether as an employee or 

otherwise and any entity in which such Stipulating Defendant has any 

ownership interest, including the names, telephone numbers, and physical, 

postal, email, and Internet addresses of all such businesses; 

3. describe in detail the activities of each business, including the goods 

and services offered, the means of advertising, marketing, and sales, and the 

involvement of any other Defendant (which Stipulating Defendants must 

describe if they know or should know due to their own involvement) 

3. describe in detail such Stipulating Defendant’s involvement in each 

such business, including title, role, responsibilities, participation, authority, 

control, and any ownership; 

Case 8:19-cv-02109-JVS-ADS Document 145 Filed 09/09/20 Page 15 of 46 Page ID

 #:4144
 

 1 

 2 

 3 

 4 

 5 

 6 

 7 

 8 

 9 

 10 

 11 

 12 

 13 

 14 

 15 

 16 

 17 

 18 

 19 

 20 

 21 

 22 

 23 

 24 

 25 

 26 

 27 

 28 

4. describe in detail whether and how that Stipulating Defendant is in 

compliance with each Section of this Order; and 

5. provide a copy of each Order Acknowledgment obtained pursuant to 

this Order, unless previously submitted to the Commission. 

B. For 15 years after entry of this Order, each Stipulating Defendant must 

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

change in the following: 

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

designated point of contact; or (b) the structure of any entity that Stipulating 

Defendant has any ownership interest in or controls directly or indirectly that 

may affect compliance obligations arising under this Order, including: 

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

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

2. Additionally, each Stipulating Defendant must report any change in: 

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

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

Stipulating Defendant performs services whether as an employee or 

otherwise and any entity in which such Stipulating Defendant has any 

ownership interest, and identify the name, physical address, and any Internet 

address of the business or entity. 

C. Each Stipulating Defendant must submit to the Commission notice of the 

filing of any bankruptcy petition, insolvency proceeding, or similar proceeding by 

or against such Stipulating Defendant within 14 days of its filing. 

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

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

such as by concluding: “I declare under penalty of perjury under the laws of the 

United States of America that the foregoing is true and correct. Executed on: 

Case 8:19-cv-02109-JVS-ADS Document 145 Filed 09/09/20 Page 16 of 46 Page ID

 #:4145
 

 1 

 2 

 3 

 4 

 5 

 6 

 7 

 8 

 9 

 10 

 11 

 12 

 13 

 14 

 15 

 16 

 17 

 18 

 19 

 20 

 21 

 22 

 23 

 24 

 25 

 26 

 27 

 28 

_____” and supplying the date, signatory’s full name, title (if applicable), and 

signature. 

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

submissions to the Commission pursuant to this Order must be emailed to 

DEbrief@ftc.gov or sent by overnight courier (not the U.S. Postal Service) to: 

Associate Director for Enforcement, Bureau of Consumer Protection, Federal 

Trade Commission, 600 Pennsylvania Avenue NW, Washington, DC 20580. The 

subject line must begin: FTC v. American Financial Support Services Inc., et al., 

X200005. 

XI. RECORDKEEPING

IT IS FURTHER ORDERED that Stipulating Defendants must create certain 

records for 15 years after entry of the Order, and retain each such record for 5 

years. Specifically, each Stipulating Defendant for any business that such 

Stipulating Defendant, individually or collectively with any other Defendants, is a 

majority owner of or controls directly or indirectly, must create and retain the 

following records: 

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

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

an employee or otherwise, that person’s: name; addresses; telephone numbers; job 

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

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

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

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

this Order, including all submissions to the Commission; and 

E. a listing of all payment processors and lead brokers or generators used in the 

conduct of the business. 

// 

// 

Case 8:19-cv-02109-JVS-ADS Document 145 Filed 09/09/20 Page 17 of 46 Page ID

 #:4146
 

 1 

 2 

 3 

 4 

 5 

 6 

 7 

 8 

 9 

 10 

 11 

 12 

 13 

 14 

 15 

 16 

 17 

 18 

 19 

 20 

 21 

 22 

 23 

 24 

 25 

 26 

 27 

 28 

XII. COMPLIANCE MONITORING

IT IS FURTHER ORDERED that, for the purpose of monitoring Stipulating 

Defendants’ compliance with this Order, including the Financial Attestations upon 

which part of the judgment was suspended and any failure to transfer any assets as 

required by this Order: 

A. Within 14 days of receipt of a written request from a representative of the 

Commission, each Stipulating Defendant must: submit additional compliance 

reports or other requested information, which must be sworn under penalty of 

perjury; appear for depositions; and produce documents for inspection and 

copying. The Commission is also authorized to obtain discovery, without further 

leave of court, using any of the procedures prescribed by Federal Rules of Civil 

Procedure 29, 30 (including telephonic depositions), 31, 33, 34, 36, 45, and 69. 

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

communicate directly with each Stipulating Defendant. Such Stipulating 

Defendant must permit representatives of the Commission to interview any 

employee or other person affiliated with any Stipulating Defendant who has agreed 

to such an interview. The person interviewed may have counsel present. 

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

its representatives, as consumers, suppliers, or other individuals or entities, to 

Stipulating Defendants or any individual or entity affiliated with Stipulating 

Defendants, without the necessity of identification or prior notice. Nothing in this 

Order limits the Commission’s lawful use of compulsory process, pursuant to 

Sections 9 and 20 of the FTC Act, 15 U.S.C. §§ 49, 57b-1. 

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

consumer reporting agency must furnish consumer reports concerning Stipulating 

Defendants, pursuant to Section 604(1) of the Fair Credit Reporting Act, 15 U.S.C. 

§ 1681b(a)(1). 

// 

Case 8:19-cv-02109-JVS-ADS Document 145 Filed 09/09/20 Page 18 of 46 Page ID

 #:4147
 

 1 

 2 

 3 

 4 

 5 

 6 

 7 

 8 

 9 

 10 

 11 

 12 

 13 

 14 

 15 

 16 

 17 

 18 

 19 

 20 

 21 

 22 

 23 

 24 

 25 

 26 

 27 

 28 

XIII. DISPOSITION OF APPEALS 

 IT IS FURTHER ORDERED that, within three (3) business days after entry 

of this Order, Stipulating Defendants shall move to dismiss, with prejudice and 

without seeking attorney’s fees and costs, their appeals in the Ninth Circuit Court 

of Appeals arising from this Court’s entry of a Preliminary Injunction, Ninth 

Circuit Case Nos. 20-55091 and 20-55092. 

XIV. RETENTION OF JURISDICTION

IT IS FURTHER ORDERED that this Court retains jurisdiction of this 

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

SO ORDERED this 9th day of September, 2020. 

_______________________________ 

HON. JAMES V. SELNA 

UNITED STATES DISTRICT JUDGE

Case 8:19-cv-02109-JVS-ADS Document 145 Filed 09/09/20 Page 19 of 46 Page ID

 #:4148
 

 1 

 2 

 3 

 4 

 5 

 6 

 7 

 8 

 9 

 10 

 11 

 12 

 13 

 14 

 15 

 16 

 17 

 18 

 19 

 20 

 21 

 22 

 23 

 24 

 25 

 26 

 27 

 28 

UNITED STATES DISTRICT COURT 

CENTRAL DISTRICT OF CALIFORNIA 

FEDERAL TRADE COMMISSION, 

 Plaintiff, 

 v. 

AMERICAN FINANCIAL SUPPORT 

SERVICES INC., et al., 

 Defendants. 

Civ. No. 8:19-cv-02109-JVS (ADSx) 

ACKNOWLEDGEMENT BY 

AFFIDAVIT OF RECEIPT OF 

ORDER BY DEFENDANT 

1. My name is ___________________________. I am a U.S. citizen over the 

age of eighteen, and I have personal knowledge of the facts set forth in this 

Acknowledgement. 

2. I was a Defendant in Federal Trade Commission v. American Financial 

Support Services Inc., et al., which is the court case listed near the top of this page. 

3. On ___________________, 2020, I received a copy of the Stipulated Order 

for Permanent Injunction and Monetary Judgment as to Defendants Carey G. 

Howe, Anna C. Howe, Shunmin Hsu, Ruddy Palacios, and Oliver Pomazi, which 

was signed by the Honorable James V. Selna and entered by the Court on 

_____________, 2020. 

I declare under penalty of perjury under the laws of the United States of America 

that the foregoing is true and correct. 

 Executed on _________________, 2020, at __________________. 

Case 8:19-cv-02109-JVS-ADS Document 145 Filed 09/09/20 Page 20 of 46 Page ID

 #:4149
 

 1 

 2 

 3 

 4 

 5 

 6 

 7 

 8 

 9 

 10 

 11 

 12 

 13 

 14 

 15 

 16 

 17 

 18 

 19 

 20 

 21 

 22 

 23 

 24 

 25 

 26 

 27 

 28 

 _________________________ 

 [Defendant] 

State of ______________, City of ____________ 

Subscribed and sworn to before me 

this ____ day of _______, 20__. 

 

 ______________________ 

 Notary Public 

 

 My commission expires: 

 ______________________ 

Case 8:19-cv-02109-JVS-ADS Document 145 Filed 09/09/20 Page 21 of 46 Page ID

 #:4150
 

 1 

 2 

 3 

 4 

 5 

 6 

 7 

 8 

 9 

 10 

 11 

 12 

 13 

 14 

 15 

 16 

 17 

 18 

 19 

 20 

 21 

 22 

 23 

 24 

 25 

 26 

 27 

 28 

UNITED STATES DISTRICT COURT 

CENTRAL DISTRICT OF CALIFORNIA 

FEDERAL TRADE COMMISSION, 

 Plaintiff, 

 v. 

AMERICAN FINANCIAL SUPPORT 

SERVICES INC., et al., 

 Defendants. 

Civ. No. 8:19-cv-02109-JVS (ADSx) 

ACKNOWLEDGEMENT BY 

DECLARATION OF RECEIPT OF 

ORDER BY A NON-PARTY 

1. I, __________________________________, received a copy of the 

Stipulated Order for Permanent Injunction and Monetary Judgment as to 

Defendants Carey G. Howe, Anna C. Howe, Shunmin Hsu, Ruddy Palacios, and 

Oliver Pomazi in the case of Federal Trade Commission v. American Financial 

Support Services Inc., et al., on _______________________, 20___. 

2. I was not a Defendant in that court case. My title or relationship with 

Defendant(s) ________________________________________ is: 

__________________________________________________________________. 

3. I declare under penalty of perjury under the laws of the United States of 

America that the foregoing is true and correct. 

Executed on _________________, 20___, at _______________________ [place]. 

Signed: 

 _________________________ 

Case 8:19-cv-02109-JVS-ADS Document 145 Filed 09/09/20 Page 22 of 46 Page ID

 #:4151
 

 1 

 2 

 3 

 4 

 5 

 6 

 7 

 8 

 9 

 10 

 11 

 12 

 13 

 14 

 15 

 16 

 17 

 18 

 19 

 20 

 21 

 22 

 23 

 24 

 25 

 26 

 27 

 28 

ATTACHMENT A 

Case 8:19-cv-02109-JVS-ADS Document 145 Filed 09/09/20 Page 23 of 46 Page ID

 #:4152
STIPULATED ORDER FOR PERMANENT INJUNCTION AND MONETARY JUDGMENT 

AS TO DEFENDANTS CAREY G. HOWE, ANNA C. HOWE, SHUNMIN HSU, 

RUDDY PALACIOS, AND OLIVER POMAZI 

Attachment A - page 1

Case 8:19-cv-02109-JVS-ADS Document 145 Filed 09/09/20 Page 24 of 46 Page ID

 #:4153
STIPULATED ORDER FOR PERMANENT INJUNCTION AND MONETARY JUDGMENT 

AS TO DEFENDANTS CAREY G. HOWE, ANNA C. HOWE, SHUNMIN HSU, 

RUDDY PALACIOS, AND OLIVER POMAZI 

Attachment A - page 2

Case 8:19-cv-02109-JVS-ADS Document 145 Filed 09/09/20 Page 25 of 46 Page ID

 #:4154
STIPULATED ORDER FOR PERMANENT INJUNCTION AND MONETARY JUDGMENT 

AS TO DEFENDANTS CAREY G. HOWE, ANNA C. HOWE, SHUNMIN HSU, 

RUDDY PALACIOS, AND OLIVER POMAZI 

Attachment A - page 3

Case 8:19-cv-02109-JVS-ADS Document 145 Filed 09/09/20 Page 26 of 46 Page ID

 #:4155
STIPULATED ORDER FOR PERMANENT INJUNCTION AND MONETARY JUDGMENT 

AS TO DEFENDANTS CAREY G. HOWE, ANNA C. HOWE, SHUNMIN HSU, 

RUDDY PALACIOS, AND OLIVER POMAZI 

Attachment A - page 4

Case 8:19-cv-02109-JVS-ADS Document 145 Filed 09/09/20 Page 27 of 46 Page ID

 #:4156
include a payment order cleared through an Automated Clearinghouse (ACH) 

Network or subject to the Truth in Lending Act, 15 U.S.C. 1601 et seq., and 

Regulation Z, 12 CFR part 1026. 

(dd) 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. 

(ee) State means any state of the United States, the District of Columbia, 

Puerto Rico, the Northern Mariana Islands, and any territory or possession of the 

United States. 

(ff) Telemarketer means any person who, in connection with telemarketing, 

initiates or receives telephone calls to or from a customer or donor. 

(gg) Telemarketing means a plan, program, or campaign which is conducted to 

induce the purchase of goods or services or a charitable contribution, by use of one 

or more telephones and which involves more than one interstate telephone call. The 

term does not include the solicitation of sales through the mailing of a catalog which: 

contains a written description or illustration of the goods or services offered for sale; 

includes the business address of the seller; includes multiple pages of written 

material or illustrations; and has been issued not less frequently than once a year, 

when the person making the solicitation does not solicit customers by telephone but 

only receives calls initiated by customers in response to the catalog and during 

those calls takes orders only without further solicitation. For purposes of the 

previous sentence, the term "further solicitation" does not include providing the 

customer with information about, or attempting to sell, any other item included in the 

same catalog which prompted the customer's call or in a substantially similar 

catalog. 

(hh) Upselling means soliciting the purchase of goods or services following an 

initial transaction during a single telephone call. The upsell is a separate 

telemarketing transaction, not a continuation of the initial transaction. An "external 

upsell" is a solicitation made by or on behalf of a seller different from the seller in the 

initial transaction, regardless of whether the initial transaction and the subsequent 

solicitation are made by the same telemarketer. An "internal upsell" is a solicitation 

made by or on behalf of the same seller as in the initial transaction, regardless of 

whether the initial transaction and subsequent solicitation are made by the same 

telemarketer. 

[75 FR 48516, Aug. 10, 2010, as amended at 80 FR 77557, Dec. 14, 2015] 

STIPULATED ORDER FOR PERMANENT INJUNCTION AND MONETARY JUDGMENT 

AS TO DEFENDANTS CAREY G. HOWE, ANNA C. HOWE, SHUNMIN HSU, 

RUDDY PALACIOS, AND OLIVER POMAZI 

Attachment A - page 5

Case 8:19-cv-02109-JVS-ADS Document 145 Filed 09/09/20 Page 28 of 46 Page ID

 #:4157
STIPULATED ORDER FOR PERMANENT INJUNCTION AND MONETARY JUDGMENT 

AS TO DEFENDANTS CAREY G. HOWE, ANNA C. HOWE, SHUNMIN HSU, 

RUDDY PALACIOS, AND OLIVER POMAZI 

Attachment A - page 6

Case 8:19-cv-02109-JVS-ADS Document 145 Filed 09/09/20 Page 29 of 46 Page ID

 #:4158
STIPULATED ORDER FOR PERMANENT INJUNCTION AND MONETARY JUDGMENT 

AS TO DEFENDANTS CAREY G. HOWE, ANNA C. HOWE, SHUNMIN HSU, 

RUDDY PALACIOS, AND OLIVER POMAZI 

Attachment A - page 7

Case 8:19-cv-02109-JVS-ADS Document 145 Filed 09/09/20 Page 30 of 46 Page ID

 #:4159
STIPULATED ORDER FOR PERMANENT INJUNCTION AND MONETARY JUDGMENT 

AS TO DEFENDANTS CAREY G. HOWE, ANNA C. HOWE, SHUNMIN HSU, 

RUDDY PALACIOS, AND OLIVER POMAZI 

Attachment A - page 8

Case 8:19-cv-02109-JVS-ADS Document 145 Filed 09/09/20 Page 31 of 46 Page ID

 #:4160
STIPULATED ORDER FOR PERMANENT INJUNCTION AND MONETARY JUDGMENT 

AS TO DEFENDANTS CAREY G. HOWE, ANNA C. HOWE, SHUNMIN HSU, 

RUDDY PALACIOS, AND OLIVER POMAZI 

Attachment A - page 9

Case 8:19-cv-02109-JVS-ADS Document 145 Filed 09/09/20 Page 32 of 46 Page ID

 #:4161
STIPULATED ORDER FOR PERMANENT INJUNCTION AND MONETARY JUDGMENT 

AS TO DEFENDANTS CAREY G. HOWE, ANNA C. HOWE, SHUNMIN HSU, 

RUDDY PALACIOS, AND OLIVER POMAZI 

Attachment A - page 10

Case 8:19-cv-02109-JVS-ADS Document 145 Filed 09/09/20 Page 33 of 46 Page ID

 #:4162
STIPULATED ORDER FOR PERMANENT INJUNCTION AND MONETARY JUDGMENT 

AS TO DEFENDANTS CAREY G. HOWE, ANNA C. HOWE, SHUNMIN HSU, 

RUDDY PALACIOS, AND OLIVER POMAZI 

Attachment A - page 11

Case 8:19-cv-02109-JVS-ADS Document 145 Filed 09/09/20 Page 34 of 46 Page ID

 #:4163
STIPULATED ORDER FOR PERMANENT INJUNCTION AND MONETARY JUDGMENT 

AS TO DEFENDANTS CAREY G. HOWE, ANNA C. HOWE, SHUNMIN HSU, 

RUDDY PALACIOS, AND OLIVER POMAZI 

Attachment A - page 12

Case 8:19-cv-02109-JVS-ADS Document 145 Filed 09/09/20 Page 35 of 46 Page ID

 #:4164
STIPULATED ORDER FOR PERMANENT INJUNCTION AND MONETARY JUDGMENT 

AS TO DEFENDANTS CAREY G. HOWE, ANNA C. HOWE, SHUNMIN HSU, 

RUDDY PALACIOS, AND OLIVER POMAZI 

Attachment A - page 13

Case 8:19-cv-02109-JVS-ADS Document 145 Filed 09/09/20 Page 36 of 46 Page ID

 #:4165
STIPULATED ORDER FOR PERMANENT INJUNCTION AND MONETARY JUDGMENT 

AS TO DEFENDANTS CAREY G. HOWE, ANNA C. HOWE, SHUNMIN HSU, 

RUDDY PALACIOS, AND OLIVER POMAZI 

Attachment A - page 14

Case 8:19-cv-02109-JVS-ADS Document 145 Filed 09/09/20 Page 37 of 46 Page ID

 #:4166
STIPULATED ORDER FOR PERMANENT INJUNCTION AND MONETARY JUDGMENT 

AS TO DEFENDANTS CAREY G. HOWE, ANNA C. HOWE, SHUNMIN HSU, 

RUDDY PALACIOS, AND OLIVER POMAZI 

Attachment A - page 15

Case 8:19-cv-02109-JVS-ADS Document 145 Filed 09/09/20 Page 38 of 46 Page ID

 #:4167
STIPULATED ORDER FOR PERMANENT INJUNCTION AND MONETARY JUDGMENT 

AS TO DEFENDANTS CAREY G. HOWE, ANNA C. HOWE, SHUNMIN HSU, 

RUDDY PALACIOS, AND OLIVER POMAZI 

Attachment A - page 16

Case 8:19-cv-02109-JVS-ADS Document 145 Filed 09/09/20 Page 39 of 46 Page ID

 #:4168
STIPULATED ORDER FOR PERMANENT INJUNCTION AND MONETARY JUDGMENT 

AS TO DEFENDANTS CAREY G. HOWE, ANNA C. HOWE, SHUNMIN HSU, 

RUDDY PALACIOS, AND OLIVER POMAZI 

Attachment A - page 17

Case 8:19-cv-02109-JVS-ADS Document 145 Filed 09/09/20 Page 40 of 46 Page ID

 #:4169
STIPULATED ORDER FOR PERMANENT INJUNCTION AND MONETARY JUDGMENT 

AS TO DEFENDANTS CAREY G. HOWE, ANNA C. HOWE, SHUNMIN HSU, 

RUDDY PALACIOS, AND OLIVER POMAZI 

Attachment A - page 18

Case 8:19-cv-02109-JVS-ADS Document 145 Filed 09/09/20 Page 41 of 46 Page ID

 #:4170
STIPULATED ORDER FOR PERMANENT INJUNCTION AND MONETARY JUDGMENT 

AS TO DEFENDANTS CAREY G. HOWE, ANNA C. HOWE, SHUNMIN HSU, 

RUDDY PALACIOS, AND OLIVER POMAZI 

Attachment A - page 19

Case 8:19-cv-02109-JVS-ADS Document 145 Filed 09/09/20 Page 42 of 46 Page ID

 #:4171
STIPULATED ORDER FOR PERMANENT INJUNCTION AND MONETARY JUDGMENT 

AS TO DEFENDANTS CAREY G. HOWE, ANNA C. HOWE, SHUNMIN HSU, 

RUDDY PALACIOS, AND OLIVER POMAZI 

Attachment A - page 20

Case 8:19-cv-02109-JVS-ADS Document 145 Filed 09/09/20 Page 43 of 46 Page ID

 #:4172
STIPULATED ORDER FOR PERMANENT INJUNCTION AND MONETARY JUDGMENT 

AS TO DEFENDANTS CAREY G. HOWE, ANNA C. HOWE, SHUNMIN HSU, 

RUDDY PALACIOS, AND OLIVER POMAZI 

Attachment A - page 21

Case 8:19-cv-02109-JVS-ADS Document 145 Filed 09/09/20 Page 44 of 46 Page ID

 #:4173
STIPULATED ORDER FOR PERMANENT INJUNCTION AND MONETARY JUDGMENT 

AS TO DEFENDANTS CAREY G. HOWE, ANNA C. HOWE, SHUNMIN HSU, 

RUDDY PALACIOS, AND OLIVER POMAZI 

Attachment A - page 22

Case 8:19-cv-02109-JVS-ADS Document 145 Filed 09/09/20 Page 45 of 46 Page ID

 #:4174
STIPULATED ORDER FOR PERMANENT INJUNCTION AND MONETARY JUDGMENT 

AS TO DEFENDANTS CAREY G. HOWE, ANNA C. HOWE, SHUNMIN HSU, 

RUDDY PALACIOS, AND OLIVER POMAZI 

Attachment A - page 23

Case 8:19-cv-02109-JVS-ADS Document 145 Filed 09/09/20 Page 46 of 46 Page ID

 #:4175