Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2235 Filed 05/24/22 Page 1 

of 78 

IN THE UNITED STATES DISTRICT COURT 

FOR THE EASTERN DISTRICT OF MICHIGAN 

FEDERAL TRADE COMMISSION, 

Plaintiff, 

v. 

FINANCIAL EDUCATION 

SERVICES, INC., et al., 

Defendants. 

Case No. 2:22-cv-11120 

Hon. Bernard A. Friedman 

TEMPORARY RESTRAINING ORDER 

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

Permanent Injunction, Monetary Relief, and Other Relief pursuant to Sections 

13(b) and 19 of the FTC Act, 15 U.S.C. §§ 53(b) and 57b, Section 410(b) of the 

Credit Repair Organizations Act (“CROA”), 15 U.S.C. § 1679h(b), and Section 

6(b) of the Telemarketing and Consumer Fraud and Abuse Prevention Act, 15 

U.S.C. § 6105(b), and has moved, pursuant to Fed. R. Civ. P. 65(b), for a 

temporary restraining order, asset freeze, appointment of receiver, and other 

equitable relief. 

FINDINGS OF FACT 

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

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

Page 1 of 45 
Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2236 Filed 05/24/22 Page 2 

of 78 

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

that: 

A. This Court has jurisdiction over the subject matter of this case, and there is 

good cause to believe that it will have jurisdiction over all parties hereto and 

that venue in this district is proper. 

B. There is good cause to believe that: 

1. in numerous instances, in connection with the marketing, telemarketing, and 

sale of credit repair services, Defendants have falsely represented that they 

can significantly improve consumers’ credit scores by, among other things, 

removing permanently negative information from consumers’ credit reports 

or profiles or adding positive payment history to consumers’ credit reports or 

profiles; 

2. in numerous, in connection with the marketing, telemarketing, and sale of 

credit repair services, Defendants have taken advanced fees for their credit 

repair services; 

3. in numerous instances, in connection with the marketing, telemarketing, and 

sale of credit repair services, Defendants have not made required disclosures 

regarding those services; and 

4. Defendants operated and promoted a marketing scheme in which they 

appear to have: 

Page 2 of 45 
Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2237 Filed 05/24/22 Page 3 

of 78 

a. operating an illegal pyramid scheme; 

b. in numerous instances, falsely representing that consumers who become 

agents (“FES Agents”) to recruit new FES Agents will earn substantial 

income; and 

c. providing the means and instrumentalities for the commission of 

deceptive acts and practices by furnishing consumers with promotional 

materials to be used in marketing credit repair services and recruiting 

new FES Agents. 

C. There is good cause to believe that Defendants have engaged in and are likely 

to engage in acts or practices that violate Section 5 of the FTC Act, 15 U.S.C. 

§ 45, multiple provisions of CROA, 15 U.S.C. §§ 1679-1679l, and multiple 

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

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 Defendants have made false, misleading, 

and deceptive representations regarding their credit repair services, taken illegal 

advance fees for those services, failed to make required disclosures regarding 

those services, operated an illegal pyramid scheme, made false, misleading, and 

deceptive representations regarding their investment opportunity, and provided 

Page 3 of 45 
Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2238 Filed 05/24/22 Page 4 

of 78 

consumers with the means and instrumentalities to commit deceptive acts and 

practices. 

D. There is good cause to believe that Defendants have taken in gross revenues of 

approximately $467 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, CROA, and the TSR 

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

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

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

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

property—will occur from the sale, transfer, destruction or other disposition or 

concealment by Defendants of their assets or records, unless Defendants are 

immediately restrained and enjoined by order of this Court; and that, in 

accordance with Fed. R. Civ. P. 65(b), the interests of justice require that this 

Order be granted without prior notice to Defendants. Thus, there is good cause 

for relieving the FTC of 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 

Page 4 of 45 
Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2239 Filed 05/24/22 Page 5 

of 78 

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, immediate 

access to business premises, expedited discovery, and other equitable relief is in 

the public interest. 

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

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

Writs Act, 28 U.S.C. § 1651. 

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

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

DEFINITIONS 

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

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

property, wherever located and by whomever held. 

B. “Consumer” means any Person. 

C. “Corporate Defendants” means Financial Education Services, Inc., United 

Wealth Services, Inc., VR-Tech, LLC, VR-Tech Mgt, LLC, CM Rent Inc., and 

Youth Financial Literacy Foundation. and each of their subsidiaries, affiliates, 

successors, and assigns. 

Page 5 of 45 
Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2240 Filed 05/24/22 Page 6 

of 78 

D. “Credit Repair Service” means any service, in return for payment of money or 

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

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

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

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

improve a consumer’s credit report, credit record, credit history, credit profile, 

credit score, or credit rating. 

E. “Defendants” means Corporate Defendants and Individual Defendants, 

individually, collectively, or in any combination. 

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

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

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

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

pages, websites, electronic correspondence, including e-mail and instant 

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

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

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

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

customer or sales databases and any other electronically stored information, 

including Documents located on remote servers or cloud computing systems, 

Page 6 of 45 
Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2241 Filed 05/24/22 Page 7 

of 78 

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. “Individual Defendants” means Parimal Naik, Michael Toloff, Christopher 

Toloff, and Gerald Thompson, individually, collectively, or in any combination. 

I. “Marketing Program” includes, but is not limited to, any multi-level, affiliate, 

or network marketing program, business opportunity, pyramid marketing 

scheme, Ponzi scheme, or chain marketing scheme. 

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

including a corporation, partnership, sole proprietorship, limited liability 

company, association, cooperative, or any other group or combination acting as 

an entity. 

K. “Public Health and Safety Event” means (1) any public health or safety 

emergency announced or declared by any federal, state, or local governmental 

authority or (2) the existence of any order, regulation, or action by any federal, 

state, or local government authority relating to public health or safety governing 

Page 7 of 45 
Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2242 Filed 05/24/22 Page 8 

of 78 

or otherwise restricting public or commercial activity, such as a quarantine or 

stay-at-home order. 

L. “Receiver” means the temporary receiver appointed in Section XII of this 

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

M. “Receivership Entities” means Corporate Defendants as well as any other 

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

services or investment opportunity, 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. 

ORDER 

PROHIBITED CREDIT REPAIR ACTIVITIES 

I. IT IS THEREFORE ORDERED that, until further order of this Court, 

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, offering 

for sale, providing, or performing of any Credit Repair Service, are temporarily 

restrained and enjoined from: 

A. Misrepresenting or assisting others in misrepresenting, directly or indirectly, 

expressly or by implication: 

Page 8 of 45 
Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2243 Filed 05/24/22 Page 9 

of 78 

1. That any Person can remove negative information or hard inquiries from 

any other Person’s credit report, credit record, credit history, credit 

profile; 

2. That any Person will report any other Person’s rent payment history or 

other positive payment history to any consumer reporting agency or any 

other Person; 

3. That any Person can substantially improve any other Person’s credit 

score or credit rating; 

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

5. That any Person is an additional authorized user on any other Person’s 

credit card or line of credit account; 

6. That any credit building product will substantially improve any Person’s 

credit score or credit rating; or 

7. Any other fact material to consumers concerning any Credit Repair 

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

conditions; or any material aspect of its performance, efficacy, nature, or 

central characteristics; 

B. Filing, causing to be filed, or encouraging any Person to file, with any other 

Person an identity theft report; 

Page 9 of 45 
Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2244 Filed 05/24/22 Page 10 

of 78 

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

performance of any Credit Repair Service before such service is fully 

performed; 

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

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

by Section 405(a) of CROA, 15 U.S.C. § 1679c(a); 

E. Failing to provide any Person with a written and dated contract which meets 

the requirements of Section 406(b) of CROA, 15 U.S.C. § 1679d(b); 

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

required terms and conditions: (1) the terms and conditions of payment, 

including the total amount of all payments to be made by the consumer; (2) a 

full and detailed description of the services to be performed for the 

consumer, including all guarantees of performance and an estimate of the 

date by which the performance of the services (to be performed by 

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

necessary to perform such services, (3) the name and principal business 

address of Defendants or any other Person providing such services, and (4) 

the specific conspicuous statement in bold face type, in immediate proximity 

to the space reserved for the consumer’s signature on the contract, which 

reads as follows: “You may cancel this contract without penalty or 

Page 10 of 45 
Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2245 Filed 05/24/22 Page 11 

of 78 

obligation at any time before midnight of the 3rd business day after the date 

on which you signed the contract. See the attached notice of cancellation 

form for an explanation of this right.” 

G. Failing to provide any Person with a separate form with the heading “Notice 

of Cancellation,” in the form and manner required by Section 407(b) of 

CROA, 15 U.S.C. § 1679e(b); and 

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

disclosures required under CROA and a copy of any other document such 

Person is required to sign. 

PROHIBITED MARKETING PROGRAM ACTIVITIES 

II. IT IS FURTHER ORDERED that, until further order of this Court, 

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 Marketing Program, are temporarily restrained and enjoined 

from: 

A. Engaging in, participating in, assisting others, or providing others with the 

means and instrumentalities to engage or participate in, any Marketing 

Program that: 

Page 11 of 45 
Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2246 Filed 05/24/22 Page 12 

of 78 

1. Pays compensation for recruiting new members; 

2. Encourages, incentivizes, or requires members to purchase goods or 

services to obtain or maintain eligibility for bonuses, rewards, or 

commissions; 

3. Induces others to encourage or incentivize members to purchase goods or 

services to obtain or maintain eligibility for bonuses, rewards, or 

commissions; 

4. Pays any compensation related to the purchase or sale of goods or 

services unless such compensation is for sales to or purchases by persons 

who are not members of the Marketing Program and who are not being 

recruited to become members of the Marketing Program; 

5. Fails to monitor and take all reasonable steps necessary to ensure than 

any compensation paid is for sales to or purchases by persons who are 

not members of the Marketing Program and who are not being recruited 

to become members of the Marketing Program; 

6. Constitutes a pyramid scheme or chain marketing scheme; 

B. Misrepresenting or assisting others in misrepresenting, directly or indirectly, 

expressly or by implication: 

1. that consumers who participate in any Marketing Program will receive or 

are likely to receive substantial income; or 

Page 12 of 45 
Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2247 Filed 05/24/22 Page 13 

of 78 

2. Any other fact material to consumers concerning any Marketing 

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

conditions; or any material aspect of its performance, efficacy, nature, or 

central characteristics. 

PROHIBITION ON RELEASE OF CUSTOMER INFORMATION 

III. IT IS FURTHER ORDERED that, until further order of this Court, 

Defendants, Defendants’ officers, agents, employees, and attorneys, and all 

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

actual notice of this Order, whether acting directly or indirectly, are hereby 

temporarily restrained and enjoined from: 

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

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

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

identifying information of any person that any Defendant obtained in 

connection with any activity that pertains to the subject matter of this Order; 

and 

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

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

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

Page 13 of 45 
Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2248 Filed 05/24/22 Page 14 

of 78 

Defendant obtained in connection with any activity that pertains to the 

subject matter of this Order. 

C. 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. 

ASSET FREEZE 

IV. IT IS FURTHER ORDERED that, until further order of this Court, 

Defendants and their officers, agents, employees, and attorneys, and all other 

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

notice of this Order, whether acting directly or indirectly, are hereby 

temporarily restrained and enjoined from: 

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

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

spending, withdrawing, granting a lien or security interest or other interest 

in, or otherwise disposing of any Assets that are: 

1. owned or controlled, directly or indirectly, by any Defendant; 

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

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

Page 14 of 45 
Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2249 Filed 05/24/22 Page 15 

of 78 

4. owned or controlled by, in the actual or constructive possession of, or 

otherwise held for the benefit of, any corporation, partnership, asset 

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

managed or controlled by any Defendant. 

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

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

access by any Defendant; 

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. 

E. The Assets affected by this Section shall include: (1) all Assets of 

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

Defendants after this Order is entered if those Assets are derived from any 

activity that is the subject of the Complaint in this matter or that is 

Page 15 of 45 
Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2250 Filed 05/24/22 Page 16 

of 78 

prohibited by this Order. This Section does not prohibit any repatriation of 

foreign Assets specifically required by this order. 

DUTIES OF ASSET HOLDERS AND OTHER THIRD PARTIES 

V. IT IS FURTHER ORDERED that, until further order of this Court, any 

financial or brokerage institution, Electronic Data Host, credit card processor, 

payment processor, merchant bank, acquiring bank, independent sales 

organization, third party processor, payment gateway, insurance company, 

business entity, or person who receives actual notice of this Order (by service or 

otherwise) that: (a) has held, controlled, or maintained custody, through an 

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

Asset that has been owned or controlled, directly or indirectly, by any 

Defendant; held, in part or in whole, for the benefit of any Defendant; in the 

actual or constructive possession of any Defendant; or owned or controlled by, 

in the actual or constructive possession of, or otherwise held for the benefit of, 

any corporation, partnership, asset protection trust, or other entity that is 

directly or indirectly owned, managed or controlled by any Defendant; (b) has 

held, controlled, or maintained custody, through an account or otherwise, of any 

Document or Asset associated with credits, debits, or charges made on behalf of 

any Defendant, including reserve funds held by payment processors, credit card 

processors, merchant banks, acquiring banks, independent sales organizations, 

Page 16 of 45 
Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2251 Filed 05/24/22 Page 17 

of 78 

third party processors, payment gateways, insurance companies, or other 

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

card account, shall: 

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

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

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

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

related to such Assets, except by further order of this Court or as directed in 

writing by the Receiver regarding Assets or Documents owned by, held in 

the name of, for the benefit of, or otherwise controlled by any Receivership 

Entity; provided, however, that this provision does not prohibit an Individual 

Defendant from incurring charges on a personal credit card established prior 

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

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

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

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

any Defendant; 

C. Provide FTC counsel and the Receiver, within three (3) days of receiving a 

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

covered by this Section: 

Page 17 of 45 
Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2252 Filed 05/24/22 Page 18 

of 78 

1. The identification number of each such account or Asset; 

2. The balance of each such account, or a description of the nature and 

value of each such Asset as of the close of business on the day on which 

this Order is served, and, if the account or other Asset has been closed or 

removed, the date closed or removed, the total funds removed in order to 

close the account, and the name of the person or entity to whom such 

account or other Asset was remitted; and 

3. The identification of any safe deposit box, commercial mail box, or 

storage facility that is either titled in the name, individually or jointly, of 

any Defendant, or is otherwise subject to access by any Defendant; and 

D. Upon the request of the Receiver, promptly provide him with copies of all 

records or other Documents pertaining to any account covered by this 

Section or Asset, including originals or copies of account applications, 

account statements, signature cards, checks, drafts, deposit tickets, transfers 

to and from the accounts, including wire transfers and wire transfer 

instructions, all other debit and credit instruments or slips, currency 

transaction reports, 1099 forms, and all logs and records pertaining to safe 

deposit boxes, commercial mail boxes, and storage facilities. 

E. Provided, however, that this Section does not prohibit any repatriation of 

foreign Assets specifically required by this order. 

Page 18 of 45 
Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2253 Filed 05/24/22 Page 19 

of 78 

FINANCIAL DISCLOSURES AND ACCOUNTING 

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

service of this Order upon them, shall prepare and deliver to FTC counsel and 

the Receiver: 

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

Attachment A (Financial Statement of Individual Defendant) for Individual 

Defendant, and Attachment B (Financial Statement of Corporate 

Defendant) for Corporate Defendant; 

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

Return) for each Defendant; and 

FOREIGN ASSET REPATRIATION 

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

of this Order, each Defendant shall: 

A. Provide the Receiver with a full accounting, verified under oath and accurate 

as of the date of this Order, of all Assets, Documents, and accounts outside 

of the United States which are: (1) titled in the name, individually or jointly, 

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

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

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

Page 19 of 45 
Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2254 Filed 05/24/22 Page 20 

of 78 

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

whether jointly or singly, of any Defendant; 

B. Take all steps necessary to provide FTC counsel access to all Documents 

and records that may be held by third parties located outside of the territorial 

United States of America, including signing the Consent to Release of 

Financial Records appended to this Order as Attachment D. 

C. Transfer to the territory of the United States and all Documents and Assets 

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

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

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

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

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

whether jointly or singly, of any Defendant; and 

D. The same business day as any repatriation, (1) notify FTC counsel of the 

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

recipient of such Documents or Assets; and (2) serve this Order on any such 

financial institution or other entity. 

NON-INTERFERENCE WITH REPATRIATION 

VIII. IT IS FURTHER ORDERED that, until further order of this Court, 

Defendants, Defendants’ officers, agents, employees, and attorneys, and all 

Page 20 of 45 
Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2255 Filed 05/24/22 Page 21 

of 78 

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, 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. 

CONSUMER CREDIT REPORTS 

IX. IT IS FURTHER ORDERED that 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 that, upon written request, any credit 

Page 21 of 45 
Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2256 Filed 05/24/22 Page 22 

of 78 

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

the FTC. 

PRESERVATION OF RECORDS 

X. IT IS FURTHER ORDERED that, until further order of this Court, 

Defendants, Defendants’ officers, agents, employees, and attorneys, and all 

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

actual notice of this Order, whether acting directly or indirectly, are hereby 

temporarily restrained and enjoined from: 

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

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

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

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

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

or (3) 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. 

Page 22 of 45 
Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2257 Filed 05/24/22 Page 23 

of 78 

REPORT OF NEW BUSINESS ACTIVITY 

XI. IT IS FURTHER ORDERED that, until further order of this Court, 

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 FTC counsel with a 

written statement disclosing: (1) the name of the business entity; (2) the 

address and telephone number of the business entity; (3) the names of the 

business entity’s officers, directors, principals, managers, and employees; and 

(4) a detailed description of the business entity’s intended activities. 

APPOINTMENT OF TEMPORARY RECEIVER 

XII. IT IS FURTHER ORDERED that Patrick A. Miles, Jr. 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. 

Page 23 of 45 
Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2258 Filed 05/24/22 Page 24 

of 78 

DUTIES AND AUTHORITIES OF RECEIVER 

XIII. IT IS FURTHER ORDERED that the Receiver is directed and authorized to 

accomplish the following: 

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

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

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 

Page 24 of 45 
Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2259 Filed 05/24/22 Page 25 

of 78 

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; 

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, or retain an expert, for the 

purpose of obtaining electronic documents stored onsite or remotely. 

Page 25 of 45 
Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2260 Filed 05/24/22 Page 26 

of 78 

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 businesses. Such 

steps may include, but are not limited to, any of the following, as the 

Receiver deems necessary or advisable: (1) securing the location by 

changing the locks and alarm codes and disconnecting any internet access or 

other means of access to the computers, servers, internal networks, or other 

records maintained at that location; and (2) requiring any persons present at 

Page 26 of 45 
Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2261 Filed 05/24/22 Page 27 

of 78 

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; 

Page 27 of 45 
Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2262 Filed 05/24/22 Page 28 

of 78 

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; 

Page 28 of 45 
Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2263 Filed 05/24/22 Page 29 

of 78 

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 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 

Page 29 of 45 
Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2264 Filed 05/24/22 Page 30 

of 78 

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 the 

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

solely to provide consumer education or information regarding the status of 

operations. 

W.Provided, however, that the Receiver may delay undertaking any of the 

duties set forth in this Section XV to the extent that the Receiver determines 

that a Public Health or Safety Event prevents the Receiver from undertaking 

such duties safely; and provided, further, that any such delay shall not be 

deemed a failure of the Receiver to exercise his or her obligations. 

Page 30 of 45 
Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2265 Filed 05/24/22 Page 31 

of 78 

TRANSFER OF RECEIVERSHIP PROPERTY TO RECEIVER 

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

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

Receivership Entities shall, upon notice of this Order by personal service or 

otherwise, fully cooperate with and assist the Receiver in taking and 

maintaining possession, custody, or control of the Assets and Documents of the 

Receivership Entities and immediately transfer or deliver to the Receiver 

possession, custody, and control of, the following: 

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

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

behalf of any Receivership Entity, wherever situated, including reserve 

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

acquiring banks, independent sales organizations, third party processors, 

payment gateways, insurance companies, or other entities; 

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

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 

Page 31 of 45 
Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2266 Filed 05/24/22 Page 32 

of 78 

F. All keys, codes, user names and passwords necessary to gain or to secure 

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

Entities, including access to their business premises, means of 

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

Data Hosts, or other property. 

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

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

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

and a motion seeking compliance or a contempt citation. 

PROVISION OF INFORMATION TO RECEIVER 

XV. IT IS FURTHER ORDERED that Defendants shall immediately provide to 

the Receiver: 

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

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

entity other than a Receivership Entity; 

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 

Page 32 of 45 
Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2267 Filed 05/24/22 Page 33 

of 78 

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. 

COOPERATION WITH THE RECEIVER 

XVI. IT IS FURTHER ORDERED that Defendants; Receivership Entities; 

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

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

and any other person with possession, custody, or control of property of or 

records relating to the Receivership entities who receive actual notice of this 

Order shall fully cooperate with and assist the Receiver. This cooperation and 

assistance shall include, but is not limited to, providing information to the 

Receiver that the Receiver deems necessary to exercise the authority and 

discharge the responsibilities of the Receiver under this Order; providing any 

keys, codes, user names and passwords required to access any computers, 

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

cloud account (including specific method to access account) or electronic file in 

any medium; advising all persons who owe money to any Receivership Entity 

that all debts should be paid directly to the Receiver; and transferring funds at 

Page 33 of 45 
Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2268 Filed 05/24/22 Page 34 

of 78 

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

the Receivership Entities. 

NON-INTERFERENCE WITH THE RECEIVER 

XVII. IT IS FURTHER ORDERED that, until further order of this Court, 

Defendants; Receivership Entities; Defendants’ or Receivership Entities’ 

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

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

other person served with a copy of this Order, are hereby restrained and 

enjoined from directly or indirectly: 

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

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

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

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

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

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

Receivership Entities; or 

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

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

Court. 

Page 34 of 45 
Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2269 Filed 05/24/22 Page 35 

of 78 

STAY OF ACTIONS 

XVIII. IT IS FURTHER ORDERED that: 

A. Except by leave of this Court, during the pendency of the receivership 

ordered herein, Defendants, Defendants’ officers, agents, employees, 

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

of them, who receive actual notice of this Order, and their corporations, 

subsidiaries, divisions, or affiliates, and all investors, creditors, 

stockholders, lessors, customers and other persons seeking to establish or 

enforce any claim, right, or interest against or on behalf of Defendants, 

and all others acting for or on behalf of such persons, are hereby enjoined 

from taking action that would interfere with the exclusive jurisdiction of 

this Court over the Assets or Documents of the Receivership Entities, 

including, but not limited to: 

1. 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; 

2. 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 

Page 35 of 45 
Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2270 Filed 05/24/22 Page 36 

of 78 

Entities, except that such actions may be commenced if necessary to 

toll any applicable statute of limitations; or 

3. 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; or 

B. The Receiver and his agents acting within the scope of such agency 

(“Retained Personnel”) are entitled to rely on all outstanding rules of law 

and orders of this Court and shall not be liable to anyone for their own 

good faith compliance with any order, rule, law, judgment, or decree. In 

no event shall the Receiver or any Retained Personnel be liable to anyone 

for their acts or omissions or their good faith compliance with their duties 

and responsibilities, except as a result of a finding by this Court that they 

acted or failed to act as a result of malfeasance, bad faith, gross 

negligence or in reckless disregard of their duties. Any party, person, or 

entity (except the FTC) seeking recovery from the Receiver or any 

Retained Personnel for conduct in the course of the administration of the 

estate must first obtain leave from this Court. This Court shall retain 

Page 36 of 45 
Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2271 Filed 05/24/22 Page 37 

of 78 

jurisdiction over any action filed against the Receiver or any Retained 

Personnel based upon acts or omissions committed in their representative 

capacities. 

C. 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. 

COMPENSATION OF RECEIVER 

XIX. IT IS FURTHER ORDERED that the Receiver and all personnel hired by the 

Receiver as herein authorized, including counsel to the Receiver and 

accountants, are entitled to reasonable compensation for the performance of 

duties pursuant to this Order and for the cost of actual out-of-pocket expenses 

incurred by them, from the Assets now held by, in the possession or control of, 

or which may be received by, the Receivership Entities. The Receiver shall file 

with the Court and serve on the parties periodic requests for the payment of 

such reasonable compensation, with the first such request filed no more than 

sixty (60) days after the date of entry of this Order. The Receiver shall not 

Page 37 of 45 
Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2272 Filed 05/24/22 Page 38 

of 78 

increase the hourly rates used as the bases for such fee applications without 

prior approval of the Court. 

RECEIVER’S BOND 

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

Court a bond in the sum of $10,000 with sureties to be approved by the Court, 

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

and abide by and perform all acts the Court directs. 28 U.S.C. § 754. 

RECEIVER’S REPORTS 

XXI. IT IS FURTHER ORDERED that the Receiver shall report to this Court on or 

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

issue, regarding (1) the steps taken by the Receiver to implement the terms of 

this Order; (2) the value of all liquidated and unliquidated assets of the 

Receivership Entities; (3) the sum of all liabilities of the Receivership Entities; 

(4) the steps the Receiver intends to take in the future to (a) prevent any 

diminution in the value of assets of the Receivership Entities, (b) pursue 

receivership assets from third parties, and (c) adjust the liabilities of the 

Receivership Entities, if appropriate; (5) whether the business of the 

Receivership Entities can be operated lawfully and profitably; and (6) 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 

Page 38 of 45 
Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2273 Filed 05/24/22 Page 39 

of 78 

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. 

IMMEDIATE ACCESS TO BUSINESS PREMISES AND RECORDS 

XXII. IT IS FURTHER ORDERED that: 

A. In order to allow the FTC and the Receiver to preserve Assets and evidence 

relevant to this action and to expedite discovery and unless the FTC or 

Receiver determines that a Public Health or Safety Event makes it unsafe for 

the FTC or the Receiver to do so, 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, 37735 Enterprise Court, Farmington Hills, Michigan, 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. In the event of a Public Health or Safety Event, the Receiver may, if the 

Receiver determines it safe to do so, enter any of Defendants’ business 

premises after business hours. Any landlord, management office, security 

office, or any other Person that controls access to any such business 

Page 39 of 45 
Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2274 Filed 05/24/22 Page 40 

of 78 

premises shall, immediately upon receiving notice of this order, cooperate 

with the Receiver and take whatever steps necessary to allow the Receiver 

access to such business premises after business hours; and such Persons are 

prohibited from notifying Defendants of the existence of this Order or the 

Receiver’s entry into the business premises until the Receiver has notified 

such Persons in writing that the Receiver has secured such business 

premises. 

C. 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 inventorying and copying, or such time 

as is agreed upon by the FTC and the Receiver; 

D. The FTC’s access to the Receivership Entities’ documents pursuant to this 

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

subsequent request for documents served by the FTC. 

E. 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; 

Page 40 of 45 
Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2275 Filed 05/24/22 Page 41 

of 78 

F. 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. Defendants 

are precluded from introducing in any proceeding in this case any Document 

not so produced. 

G. 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. 

Page 41 of 45 
Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2276 Filed 05/24/22 Page 42 

of 78 

DISTRIBUTION OF ORDER BY DEFENDANTS 

XXIII. IT IS FURTHER ORDERED that Defendants shall immediately provide a 

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

successor, assign, member, officer, director, employee, agent, independent 

contractor, client, attorney, spouse, subsidiary, division, and representative of 

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

Order, and provide FTC counsel 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. 

EXPEDITED DISCOVERY 

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

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

30(a), 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 

Page 42 of 45 
Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2277 Filed 05/24/22 Page 43 

of 78 

discovering: (1) the nature, location, status, and extent of Defendants’ Assets; 

(2) the nature, location, and extent of Defendants’ business transactions and 

operations; (3) Documents reflecting Defendants’ business transactions and 

operations; or (4) compliance with this Order. 

SERVICE OF THIS ORDER 

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

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

exhibits filed contemporaneously with that Motion (other than the complaint 

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

electronic mail or other electronic messaging, personal or overnight delivery, 

U.S. Mail or FedEx, by agents and employees of 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) of the Federal Rules of 

Civil Procedure. For purposes of this Section, service upon any branch, 

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

entity. 

Page 43 of 45 
Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2278 Filed 05/24/22 Page 44 

of 78 

CORRESPONDENCE AND SERVICE ON THE FTC 

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

correspondence and service of pleadings on the FTC shall be addressed to: 

Gregory A. Ashe, K. Michelle Grajales, and Julia E. Heald, Federal Trade 

Commission, 600 Pennsylvania Avenue NW, Room CC-10232, Washington, 

D.C. 20580, email: gashe@ftc.gov, mgrajales@ftc.gov, and jheald@ftc.gov. 

PRELIMINARY INJUNCTION HEARING 

XXVII. IT IS FURTHER ORDERED that: 

A. The Motion for Temporary Restraining Order is also deemed to be a motion 

for a preliminary injunction order, and that the FTC is not required to file or 

serve a separate motion for a preliminary injunction in order to see the entry 

of a preliminary injunction under Federal Rule of Civil Procedure 65. 

B. The Court will consider all materials filed by the FTC in connection with the 

Motion for Temporary Restraining Order to have been filed in connection 

with the FTC’s motion for a preliminary injunction hearing. The FTC shall 

be permitted, but is not required, to file a supplemental brief and supporting 

exhibits in advance of any preliminary injunction hearing. 

C. Defendants wishing to be heard on this matter may appear in this Court, on 

the FTC’s motion for preliminary injunction, before the Honorable Judge 

Bernard A. Friedman, at 2:00 p.m. on Monday, June 6, 2022 in 

Page 44 of 45 
 

Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2279 Filed 05/24/22 Page 45 

of 78 

Courtroom 110 of the United States District Court, Eastern District of 

Michigan, 231 W Lafayette Blvd, Detroit, Michigan 48226, to show 

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

injunction and order preliminary relief against them, pursuant to Rule 65 of 

the Federal Rules of Civil Procedure, extending the temporary relief granted 

in this Order pending a final adjudication on the merits. 

D. This Order shall expire at 11:59 P.M. fourteen days following the entry of 

this order, unless otherwise ordered by this Court. 

RETENTION OF JURISDICTION 

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

this matter for all purposes. 

 IT SO ORDERED, 

s/Bernard A. Friedman 

Dated: May 24, 2022 Bernard A. Friedman 

Detroit, Michigan Senior United States District Judge 

Page 45 of 45 
Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2280 Filed 05/24/22 Page 46 

of 78 

ATTACHMENT A 
 

FEDERAL TRADE COMMISSION 

FINANCIAL STATEMENT OF INDIVIDUAL DEFENDANT 

Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2281 Filed 05/24/22 Page 47 

of 78

Definitions and Instructions: 

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

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

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

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

time during the past five years. 

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

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

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

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

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

5. Type or print legibly. 

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

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

Penalty for False Information: 

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

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

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

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

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

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

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

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

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

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

declaration” (18 U.S.C. § 1623). 

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

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

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

loss. 18 U.S.C. § 3571. 

Federal Trade Commission Financial Statement of Individual Defendant 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2282 Filed 05/24/22 Page 48 

of 78 BACKGROUND INFORMATION 

Item 1. Information About You 

Full Name Social Security No. 

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

Phone Numbers 

Home: ( ) 

Fax: ( ) 

Date of Birth: / / 

(mm/dd/yyyy) 

Place of Birth 

Rent Own From (Date): / / 

(mm/dd/yyyy) 

E-Mail Address 

Internet Home Page 

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

Address From: / / Until: / / 

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

Rent Own 

Address From: / / Until: / / 

Rent Own 

Address From: / / Until: / / 

Rent Own 

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

were used: 

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

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

/ / 

(mm/dd/yyyy) 

Address (if different from yours) Phone Number 

( ) 

Place of Birth 

Rent Own From (Date): / / 

(mm/dd/yyyy) 

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

Employer’s Name and Address Job Title 

Years in Present Job Annual Gross Salary/Wages 

$ 

Item 3. Information About Your Previous Spouse 

Name and Address Social Security No. 

Date of Birth 

/ / 

(mm/dd/yyyy) 

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

Name and Address Phone Number 

( ) 

Initials: 

1 of 10 Federal Trade Commission Financial Statement of Individual Defendant 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2283 Filed 05/24/22 Page 49 

of 78 

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

Name and Address Social Security No. Date of Birth 

/ / 

(mm/dd/yyyy) 

Relationship 

Name and Address Social Security No. Date of Birth 

/ / 

(mm/dd/yyyy) 

Relationship 

Name and Address Social Security No. Date of Birth 

/ / 

(mm/dd/yyyy) 

Relationship 

Name and Address Social Security No. Date of Birth 

/ / 

(mm/dd/yyyy) 

Relationship 

Item 6. Employment Information/Employment Income

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

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

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

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

on your behalf. 

Company Name and Address 

Ownership Interest? Yes No 

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

From (Month/Year) 

/ 

To (Month/Year) 

/ 

Year Income 

20 $ 

$ 

$ 

$ 

$ 

$ 

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

/ / 

/ / 

/ / 

Company Name and Address 

Ownership Interest? Yes No 

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

From (Month/Year) 

/ 

To (Month/Year) 

/ 

Year Income 

20 $ 

$ 

$ 

$ 

$ 

$ 

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

/ / 

/ / 

/ / 

Company Name and Address 

Ownership Interest? Yes No 

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

From (Month/Year) 

/ 

To (Month/Year) 

/ 

Year Income 

20 $ 

$ 

$ 

$ 

$ 

$ 

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

/ / 

/ / 

/ / 

Initials: 

2 of 10 Federal Trade Commission Financial Statement of Individual Defendant 
 

 

 

Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2284 Filed 05/24/22 Page 50 

of 78 

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

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

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

resulted in final judgments or settlements against you. 

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

Proceeding Relief Requested Status or Disposition 

Item 8. Safe Deposit Boxes 

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

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

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

Initials: 

3 of 10 Federal Trade Commission Financial Statement of Individual Defendant 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2285 Filed 05/24/22 Page 51 

of 78 

FINANCIAL INFORMATION 

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

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

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

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

ASSETS 

Item 9. Cash, Bank, and Money Market Accounts 

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

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

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

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

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

$ 

$ 

$ 

$ 

$ 

Item 10. Publicly Traded Securities

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

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

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

Broker House, Address Broker Account No. 

Current Fair Market Value 

$ 

Loan(s) Against Security 

$ 

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

Broker House, Address Broker Account No. 

Current Fair Market Value 

$ 

Loan(s) Against Security 

$ 

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

Broker House, Address Broker Account No. 

Current Fair Market Value 

$ 

Loan(s) Against Security 

$ 

Initials: 

4 of 10 Federal Trade Commission Financial Statement of Individual Defendant 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2286 Filed 05/24/22 Page 52 

of 78 

Item 11. Non-Public Business and Financial Interests 

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

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

corporation, and oil or mineral lease. 

Entity’s Name & Address Type of Business or Financial 

Interest (e.g., LLC, partnership) 

Owner 

(e.g., self, spouse) 

Ownership 

% 

If Officer, Director, Member 

or Partner, Exact Title 

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

Debtor’s Name & Address Date Obligation 

Incurred (Month/Year) 

/ 

Original Amount Owed 

$ 

Nature of Obligation (if the result of a final court 

judgment or settlement, provide court name 

and docket number) 

Current Amount Owed 

$ 

Payment Schedule 

$ 

Debtor’s Telephone Debtor’s Relationship to You 

Debtor’s Name & Address Date Obligation 

Incurred (Month/Year) 

/ 

Original Amount Owed 

$ 

Nature of Obligation (if the result of a final court 

judgment or settlement, provide court name 

and docket number) 

Current Amount Owed 

$ 

Payment Schedule 

$ 

Debtor’s Telephone Debtor’s Relationship to You 

Item 13. Life Insurance Policies 

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

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

$ 

Insured Loans Against Policy 

$ 

Surrender Value 

$ 

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

$ 

Insured Loans Against Policy 

$ 

Surrender Value 

$ 

Item 14. Deferred Income Arrangements 

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

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

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

Date Established 

/ / 

(mm/dd/yyyy) 

Type of Plan Surrender Value before 

Taxes and Penalties 

$ 

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

Date Established 

/ / 

Type of Plan Surrender Value before 

Taxes and Penalties 

$ 

Initials: 

5 of 10 Federal Trade Commission Financial Statement of Individual Defendant 
 

 

 

 

 

 

 

 

Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2287 Filed 05/24/22 Page 53 

of 78 

Item 15. Pending Insurance Payments or Inheritances

List any pending insurance payments or inheritances owed to you. 

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

$ / / 

$ / / 

$ / / 

Item 16. Vehicles 

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

Vehicle Type Year Registered Owner’s Name Purchase Price 

$ 

Original Loan Amount 

$ 

Current Balance 

$ 

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

$ 

Monthly Payment 

$ 

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

Vehicle Type Year Registered Owner’s Name Purchase Price 

$ 

Original Loan Amount 

$ 

Current Balance 

$ 

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

$ 

Monthly Payment 

$ 

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

Vehicle Type Year Registered Owner’s Name Purchase Price 

$ 

Original Loan Amount 

$ 

Current Balance 

$ 

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

$ 

Monthly Payment 

$ 

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

Vehicle Type Year Registered Owner’s Name Purchase Price 

$ 

Original Loan Amount 

$ 

Current Balance 

$ 

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

$ 

Monthly Payment 

$ 

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

Item 17. Other Personal Property 

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

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

Property Category 

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

$ $ 

$ $ 

$ $ 

Initials: 

6 of 10 Federal Trade Commission Financial Statement of Individual Defendant 
 

 

 

 

 

 

 

 

 

 

 

 

Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2288 Filed 05/24/22 Page 54 

of 78 

Item 18. Real Property

List all real property interests (including any land contract) 

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

Acquisition Date (mm/dd/yyyy) 

/ / 

Purchase Price 

$ 

Current Value 

$ 

Basis of Valuation 

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

Contract 

$ 

Monthly Payment 

$ 

Other Mortgage Loan(s) (describe) Monthly Payment 

$ 

Rental Unit 

Monthly Rent Received 

$ 

Current Balance 

$ 

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

Acquisition Date (mm/dd/yyyy) 

/ / 

Purchase Price 

$ 

Current Value 

$ 

Basis of Valuation 

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

Contract 

$ 

Monthly Payment 

$ 

Other Mortgage Loan(s) (describe) Monthly Payment 

$ 

Rental Unit 

Monthly Rent Received 

$ 

Current Balance 

$ 

LIABILITIES 

Item 19. Credit Cards 

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

whether issued by a United States or foreign financial institution. 

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

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

$ 

$ 

$ 

$ 

$ 

Item 20. Taxes Payable 

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

Type of Tax Amount Owed Year Incurred 

$ 

$ 

$ 

Initials: 

7 of 10 Federal Trade Commission Financial Statement of Individual Defendant 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2289 Filed 05/24/22 Page 55 

of 78 

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

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

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

number) 

Lender/Creditor’s Relationship to You 

Date Liability Was Incurred 

/ / 

(mm/dd/yyyy) 

Original Amount Owed 

$ 

Current Amount Owed 

$ 

Payment Schedule 

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

number) 

Lender/Creditor’s Relationship to You 

Date Liability Was Incurred 

/ / 

(mm/dd/yyyy) 

Original Amount Owed 

$ 

Current Amount Owed 

$ 

Payment Schedule 

OTHER FINANCIAL INFORMATION 

Item 22. Trusts and Escrows 

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

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

dependents, for any person or entity. 

Trustee or Escrow Agent’s Name & Address Date Established 

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

/ / $ 

/ / $ 

/ / $ 

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

Item 23. Transfers of Assets 

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

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

entity, state the total amount transferred during that period. 

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

(mm/dd/yyyy) 

Type of Transfer 

(e.g., Loan, Gift) 

$ / / 

$ / / 

$ / / 

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

Initials: 

8 of 10 Federal Trade Commission Financial Statement of Individual Defendant 
 

 

 

 

 

 

 

 

 

 

 

Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2290 Filed 05/24/22 Page 56 

of 78 Item 24. Document Requests

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

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

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

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

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

Item 11 

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

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

general ledger files from account records. 

Item 17 

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

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

less than $2,000. 

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

Item 21 Documentation for all debts listed in Item 21. 

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

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

SUMMARY FINANCIAL SCHEDULES 

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

Assets Liabilities 

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

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

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

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

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

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

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

Deferred Income Arrangements (Item 14) $ $ 

Vehicles (Item 16) $ $ 

Other Personal Property (Item 17) $ $ 

Real Property (Item 18) $ $ 

Other Assets (Itemize) $ 

$ $ 

$ $ 

$ $ 

Total Assets $ Total Liabilities $ 

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

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

include credit card expenditures in the appropriate categories. 

Income (State source of each item) Expenses 

Salary - After Taxes 

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

Fees, Commissions, and Royalties 

Source: $ Property Taxes for Residence(s) $ 

Interest 

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

and Insurance $ 

Dividends and Capital Gains 

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

Gross Rental Income 

Source: $ Food Expenses $ 

Profits from Sole Proprietorships 

Source: $ Clothing Expenses $ 

Distributions from Partnerships, S-Corporations, 

and LLCs 

Source: 

$ 

Utilities 

$ 

Initials: 

9 of 10 Federal Trade Commission Financial Statement of Individual Defendant 
 

 

 

 

 

 

_______________ ___________________________________ 

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

Distributions from Trusts and Estates 

Source: $ Medical Expenses, Including Insurance $ 

Distributions from Deferred Income Arrangements 

Source: $ 

Other Insurance Premiums 

$ 

Social Security Payments $ Other Transportation Expenses $ 

Alimony/Child Support Received $ Other Expenses (Itemize) 

Gambling Income $ $ 

Other Income (Itemize) $ 

$ $ 

$ $ 

$ $ 

Total Income $ Total Expenses $ 

ATTACHMENTS 

Item 27. Documents Attached to this Financial Statement 

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

Item No. Document Relates To Description of Document 

Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2291 Filed 05/24/22 Page 57 

of 78 

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

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

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

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

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

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

Executed on: 

(Date) Signature 

 10 of 10 Federal Trade Commission Financial Statement of Individual Defendant 
Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2292 Filed 05/24/22 Page 58 

of 78 

ATTACHMENT B 
Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2293 Filed 05/24/22 Page 59 

of 78 

FEDERAL TRADE COMMISSION 

FINANCIAL STATEMENT OF CORPORATE DEFENDANT 

Instructions: 

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

question, explain why. 

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

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

predecessors that are not named defendants in this action. 

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

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

benefit of the corporation. 

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

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

6. Type or print legibly. 

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

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

Penalty for False Information: 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

18 U.S.C. § 3571. 
Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2294 Filed 05/24/22 Page 60 

of 78 

BACKGROUND INFORMATION 

Item 1. General Information 

Corporation’s Full Name ___________________________________________________________________________ 

Primary Business Address ______________________________________________________ From (Date) _________ 

Telephone No. _____________________________ Fax No. _____________________________

 E-Mail Address________________________ Internet Home Page________________________ 

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

Address____________________________________________________________ From/Until____________________ 

Address____________________________________________________________ From/Until____________________ 

Address____________________________________________________________ From/Until____________________ 

All predecessor companies for past five years: 

Name & Address _________________________________________________________ From/Until ______________ 

Name & Address _________________________________________________________ From/Until ______________ 

Name & Address _________________________________________________________ From/Until ______________ 

Item 2. Legal Information 

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

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

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

If Dissolved: Date dissolved _________________________ By Whom ______________________________________ 

Reasons _________________________________________________________________________________________ 

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

Item 3. Registered Agent 

Name of Registered Agent __________________________________________________________________________ 

Address __________________________________________________________ Telephone No. __________________ 

Page 2 Initials __________ 
_________________________________________________________________________________ ______________ 

_________________________________________________________________________________ ______________ 

_________________________________________________________________________________ ______________ 

_________________________________________________________________________________ ______________ 

____________________________________________________________________ __________ _________________ 

____________________________________________________________________ __________ _________________ 

____________________________________________________________________ __________ _________________ 

____________________________________________________________________ __________ _________________ 

____________________________________________________________________ __________ _________________ 

_______________________________________________________________________________ ________________ 

_______________________________________________________________________________ ________________ 

_______________________________________________________________________________ ________________ 

_______________________________________________________________________________ ________________ 

_______________________________________________________________________________ ________________ 

Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2295 Filed 05/24/22 Page 61 

of 78 

Item 4. Principal Stockholders 

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

Name & Address % Owned 

Item 5. Board Members 

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

Name & Address % Owned Term (From/Until) 

Item 6. Officers 

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

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

Name & Address % Owned 

Page 3 Initials __________ 
___________________________________________________________________ ___________________ _________ 

___________________________________________________________________ ___________________ _________ 

___________________________________________________________________ ___________________ _________ 

________________________________________________________________________________________________ 

__________________ __________________________________________________ __________________ ________ 

__________________ __________________________________________________ __________________ ________ 

__________________ __________________________________________________ __________________ ________ 

________________________________________________________________________________________________ 

_________________________________________________________ _________________ ______________________ 

_________________________________________________________ _________________ ______________________ 

_________________________________________________________ _________________ ______________________ 

Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2296 Filed 05/24/22 Page 62 

of 78 

Item 7. Businesses Related to the Corporation 

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

Name & Address Business Activities % Owned 

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

Item 8. Businesses Related to Individuals 

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

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

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

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

Item 9. Related Individuals 

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

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

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

Name and Address Relationship Business Activities 

Page 4 Initials __________ 
____________________ ______________________ ________________________________________ ____________ 

____________________ ______________________ ________________________________________ ____________ 

____________________ ______________________ ________________________________________ ____________ 

____________________ ______________________ ________________________________________ ____________ 

____________________ ______________________ ________________________________________ ____________ 

____________________________________________________________________________ ___________________ 

____________________________________________________________________________ ___________________ 

____________________________________________________________________________ ___________________ 

____________________________________________________________________________ ___________________ 

____________________ ___________________________ ________________________________________________ 

____________________ ___________________________ ________________________________________________ 

____________________ ___________________________ ________________________________________________ 

____________________ ___________________________ ________________________________________________ 

____________________ ___________________________ ________________________________________________ 

Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2297 Filed 05/24/22 Page 63 

of 78 

Item 10. Outside Accountants 

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

Name Firm Name Address CPA/PA? 

Item 11. Corporation’s Recordkeeping 

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

the last three years. 

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

Item 12. Attorneys 

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

Name Firm Name Address 

Page 5 Initials __________ 
Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2298 Filed 05/24/22 Page 64 

of 78 

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 __________ 
Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2299 Filed 05/24/22 Page 65 

of 78 

Item 14. Current Lawsuits Filed Against the Corporation 

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

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

Opposing Party’s Name & Address___________________________________________________________________ 

Court’s Name & Address___________________________________________________________________________ 

Docket No._________________ Relief Requested____________________ Nature of Lawsuit____________________ 

____________________________________ Status______________________________________________________ 

Opposing Party’s Name & Address___________________________________________________________________ 

Court’s Name & Address___________________________________________________________________________ 

Docket No._________________ Relief Requested____________________ Nature of Lawsuit____________________ 

____________________________________ Status______________________________________________________ 

Opposing Party’s Name & Address___________________________________________________________________ 

Court’s Name & Address___________________________________________________________________________ 

Docket No._________________ Relief Requested____________________ Nature of Lawsuit____________________ 

____________________________________ Status______________________________________________________ 

Opposing Party’s Name & Address___________________________________________________________________ 

Court’s Name & Address___________________________________________________________________________ 

Docket No._________________ Relief Requested____________________ Nature of Lawsuit____________________ 

____________________________________ Status______________________________________________________ 

Opposing Party’s Name & Address___________________________________________________________________ 

Court’s Name & Address___________________________________________________________________________ 

Docket No._________________ Relief Requested____________________ Nature of Lawsuit____________________ 

____________________________________ Status______________________________________________________ 

Opposing Party’s Name & Address___________________________________________________________________ 

Court’s Name & Address___________________________________________________________________________ 

Docket No._________________ Relief Requested____________________ Nature of Lawsuit____________________ 

____________________________________ Status______________________________________________________ 

Page 7 Initials __________ 
Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2300 Filed 05/24/22 Page 66 

of 78 

Item 15. Bankruptcy Information 

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

Commencement Date _________________ Termination Date _________________ Docket No. __________________ 

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

Disposition ______________________________________________________________________________________ 

Item 16. Safe Deposit Boxes 

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

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

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

__________________ ___________________________________________________________________ __________ 

__________________ ___________________________________________________________________ __________ 

__________________ ___________________________________________________________________ __________ 

__________________ ___________________________________________________________________ __________ 

__________________ ___________________________________________________________________ __________ 

FINANCIAL INFORMATION 

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

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

others for the benefit of the corporation. 

Item 17. Tax Returns 

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

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

State/Both Federal Federal State State 

___________ __________ $_________ $_________ $__________ $__________ ______________________________ 

___________ __________ $_________ $_________ $__________ $__________ ______________________________ 

___________ __________ $_________ $_________ $__________ $__________ ______________________________ 

Page 8 Initials __________ 
_________ _____________ ______________________ __________________ _______________________ ________ 

_________ _____________ ______________________ __________________ _______________________ ________ 

_________ _____________ ______________________ __________________ _______________________ ________ 

_________ _____________ ______________________ __________________ _______________________ ________ 

Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2301 Filed 05/24/22 Page 67 

of 78 

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 __________ 
Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2302 Filed 05/24/22 Page 68 

of 78 

Item 21. Government Obligations and Publicly Traded Securities 

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

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

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

Issuer _________________________________ Type of Security/Obligation __________________________________ 

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

Issuer _________________________________ Type of Security/Obligation __________________________________ 

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

Item 22. Real Estate 

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

Type of Property________________________________ Property’s Location__________________________________ 

Name(s) on Title and Ownership Percentages___________________________________________________________ 

Current Value $____________________ Loan or Account No. __________________________ 

Lender’s Name and Address_________________________________________________________________________ 

Current Balance On First Mortgage $_______________ Monthly Payment $______________ 

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

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

Type of Property________________________________ Property’s Location__________________________________ 

Name(s) on Title and Ownership Percentages___________________________________________________________ 

Current Value $____________________ Loan or Account No. __________________________ 

Lender’s Name and Address_________________________________________________________________________ 

Current Balance On First Mortgage $_______________ Monthly Payment $______________ 

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

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

Page 10 Initials __________ 
 

Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2303 Filed 05/24/22 Page 69 

of 78 

Item 23. Other Assets 

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

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

intellectual property. 

Property Category Property Location Acquisition Current 

Cost Value 

____________________________ _____________________________________________ $__________ $_________ 

____________________________ _____________________________________________ $__________ $_________ 

____________________________ _____________________________________________ $__________ $_________ 

____________________________ _____________________________________________ $__________ $_________ 

____________________________ _____________________________________________ $__________ $_________ 

____________________________ _____________________________________________ $__________ $_________ 

____________________________ _____________________________________________ $__________ $_________ 

____________________________ _____________________________________________ $__________ $_________ 

____________________________ _____________________________________________ $__________ $_________ 

Item 24. Trusts and Escrows 

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

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

Name & Address Value of Assets 

______________________________________ _______________________________________ $_________________ 

______________________________________ _______________________________________ $_________________ 

______________________________________ _______________________________________ $_________________ 

______________________________________ _______________________________________ $_________________ 

______________________________________ _______________________________________ $_________________ 

______________________________________ _______________________________________ $_________________ 

______________________________________ _______________________________________ $_________________ 

Page 11 Initials __________ 
Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2304 Filed 05/24/22 Page 70 

of 78 

Item 25. Monetary Judgments and Settlements Owed To the Corporation 

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

Opposing Party’s Name & Address___________________________________________________________________ 

Court’s Name & Address____________________________________________________ Docket No._____________ 

Nature of Lawsuit______________________________ Date of Judgment________________ Amount $____________ 

Opposing Party’s Name & Address___________________________________________________________________ 

Court’s Name & Address____________________________________________________ Docket No._____________ 

Nature of Lawsuit______________________________ Date of Judgment________________ Amount $____________ 

Item 26. Monetary Judgments and Settlements Owed By the Corporation 

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

Opposing Party’s Name & Address___________________________________________________________________ 

Court’s Name & Address____________________________________________________ Docket No._____________ 

Nature of Lawsuit_______________________________________ Date______________ Amount $______________ 

Opposing Party’s Name & Address___________________________________________________________________ 

Court’s Name & Address____________________________________________________ Docket No._____________ 

Nature of Lawsuit______________________________ Date of Judgment________________ Amount $____________ 

Opposing Party’s Name & Address___________________________________________________________________ 

Court’s Name & Address____________________________________________________ Docket No._____________ 

Nature of Lawsuit______________________________ Date of Judgment________________ Amount $____________ 

Opposing Party’s Name & Address___________________________________________________________________ 

Court’s Name & Address____________________________________________________ Docket No._____________ 

Nature of Lawsuit______________________________ Date of Judgment________________ Amount $____________ 

Opposing Party’s Name & Address___________________________________________________________________ 

Court’s Name & Address____________________________________________________ Docket No._____________ 

Nature of Lawsuit______________________________ Date of Judgment________________ Amount $____________ 

Page 12 Initials __________ 
__________________________________________ _____________________________________________________ 

__________________________________________ _____________________________________________________ 

__________________________________________ _____________________________________________________ 

__________________________________________ _____________________________________________________ 

__________________________________________ _____________________________________________________ 

Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2305 Filed 05/24/22 Page 71 

of 78 

Item 27. Government Orders and Settlements 

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

Name of Agency ___________________________________________ Contact Person __________________________ 

Address _____________________________________________________________ Telephone No. _______________ 

Agreement Date ______________ Nature of Agreement __________________________________________________ 

Item 28. Credit Cards 

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

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

Item 29. Compensation of Employees 

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

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

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

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

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

individuals, or paid to others on their behalf. 

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

Year-to-Date Type of Benefits 

_____________________________ $____________ $___________ $____________ ___________________________ 

_____________________________ $____________ $___________ $____________ ___________________________ 

_____________________________ $____________ $___________ $____________ ___________________________ 

_____________________________ $____________ $___________ $____________ ___________________________ 

_____________________________ $____________ $___________ $____________ ___________________________ 

Page 13 Initials __________ 
Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2306 Filed 05/24/22 Page 72 

of 78 

Item 30. Compensation of Board Members and Officers 

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

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

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

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

the individuals, or paid to others on their behalf. 

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

Year-to-Date Type of Benefits 

_____________________________ $____________ $___________ $____________ ___________________________ 

_____________________________ $____________ $___________ $____________ ___________________________ 

_____________________________ $____________ $___________ $____________ ___________________________ 

_____________________________ $____________ $___________ $____________ ___________________________ 

_____________________________ $____________ $___________ $____________ ___________________________ 

_____________________________ $____________ $___________ $____________ ___________________________ 

_____________________________ $____________ $___________ $____________ ___________________________ 

_____________________________ $____________ $___________ $____________ ___________________________ 

Item 31. Transfers of Assets Including Cash and Property 

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

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

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

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

______________________________________ ________________ $____________ __________ _________________ 

______________________________________ ________________ $____________ __________ _________________ 

______________________________________ ________________ $____________ __________ _________________ 

______________________________________ ________________ $____________ __________ _________________ 

______________________________________ ________________ $____________ __________ _________________ 

Page 14 Initials __________ 
___________________ ____________________________________________________________________________ 

___________________ ____________________________________________________________________________ 

___________________ ____________________________________________________________________________ 

___________________ ____________________________________________________________________________ 

___________________ ____________________________________________________________________________ 

___________________ ____________________________________________________________________________ 

___________________ ____________________________________________________________________________ 

___________________ ____________________________________________________________________________ 

___________________ ____________________________________________________________________________ 

______________________________ _____________________________________________________ 

_____________________________________________________ 

Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2307 Filed 05/24/22 Page 73 

of 78 

Item 32. Documents Attached to the Financial Statement 

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

Item No. Document Description of Document 

Relates To 

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

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

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

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

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

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

Executed on: 

(Date) Signature 

Corporate Position 

Page 15 Initials __________ 
Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2308 Filed 05/24/22 Page 74 

of 78 

ATTACHMENT C 
6 

7 

Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2309 Filed 05/24/22 Page 75 

of 78 

Form 4506

(July 2017) 

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. You may be able to get your tax return or return information from other sources. If you had your tax return completed by a paid preparer, they 

should be able to provide you a copy of the return. The IRS can provide a Tax Return Transcript for many returns free of charge. The transcript 

provides most of the line entries from the original tax return and usually contains the information that a third party (such as a mortgage company) 

requires. See Form 4506-T, Request for Transcript of Tax Return, or you can quickly request transcripts by using our automated self-help service 

tools. Please visit us at IRS.gov and click on “Get a Tax Transcript...” or call 1-800-908-9946. 

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 mailed to a third party, ensure that you have filled in lines 6 and 7 before signing. Sign and date the form once you 

have filled in these lines. Completing these steps helps to protect your privacy. Once the IRS discloses your tax return to the third party listed on line 

5, the IRS has no control over what the third party does with the information. If you would like to limit the third party's authority to disclose your return 

information, you can specify this limitation in your written agreement with the third party. 

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 year or period, using the mm/dd/yyyy format. If you are requesting more than 

eight years or periods, you must attach another Form 4506. 

8 

a 

Fee. There is a $50 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 . . . . . . . . . . . . . . . . . . . . . . . . . . . $ 50.00

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 

Sign 

Here 

F F F

Signature (see instructions) Date 

Title (if line 1a above is a corporation, partnership, estate, or trust) 

Spouse’s signature Date 

For Privacy Act and Paperwork Reduction Act Notice, see page 2. Cat. No. 41721E Form 4506 (Rev. 7-2017) 
Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2310 Filed 05/24/22 Page 76 

of 78 

Form 4506 (Rev. 7-2017) 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. 

Information about any recent developments affecting 

Form 4506, Form 4506-T and Form 4506T-EZ will be 

posted on that page. 

General Instructions 

Caution: Do not sign this form unless all applicable 

lines have been completed. 

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. 

Tip. Use Form 4506-T, Request for Transcript of Tax 

Return, to request tax return transcripts, tax account 

information, W-2 information, 1099 information, 

verification of nonfiling, and records of account. 

Automated transcript request. You can quickly 

request transcripts by using our automated self-help 

service tools. Please visit us at IRS.gov and click on 

“Get a Tax Transcript...” or call 1-800-908-9946. 

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 to the 

address 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: 

Alabama, Kentucky, 

Louisiana, Mississippi, 

Tennessee, 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 

Alaska, Arizona, 

Arkansas, California, 

Colorado, Hawaii, Idaho, 

Illinois, Indiana, Iowa, 

Kansas, Michigan, Internal Revenue Service 

Minnesota, Montana, RAIVS Team 

Nebraska, Nevada, New Stop 37106 

Mexico, North Dakota, Fresno, CA 93888 

Oklahoma, Oregon, 

South Dakota, Utah, 

Washington, Wisconsin, 

Wyoming 

Connecticut, 

Delaware, District of 

Columbia, Florida, 

Georgia, Maine, 

Maryland, Internal Revenue Service Massachusetts, RAIVS Team Missouri, New Stop 6705 P-6 Hampshire, New Jersey, Kansas City, MO New York, North 64999 Carolina, Ohio, 

Pennsylvania, Rhode 

Island, South Carolina, 

Vermont, Virginia, West 

Virginia 

Chart for all other returns 

If you lived in 

or your business Mail to: 

was in: 

Alabama, Alaska, 

Arizona, Arkansas, 

California, Colorado, 

Florida, Hawaii, Idaho, 

Iowa, Kansas, Louisiana, 

Minnesota, Mississippi, 

Missouri, Montana, 

Nebraska, Nevada, 

New Mexico, Internal Revenue Service North Dakota, RAIVS Team Oklahoma, Oregon, P.O. Box 9941 South Dakota, Texas, Mail Stop 6734 Utah, Washington, Ogden, UT 84409 Wyoming, a foreign 

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 

Connecticut, Delaware, 

District of Columbia, 

Georgia, Illinois, Indiana, 

Kentucky, Maine, 

Maryland, 

Massachusetts, Internal Revenue Service 

Michigan, New RAIVS Team 

Hampshire, New Jersey, P.O. Box 145500 

New York, North Stop 2800 F 

Carolina, Cincinnati, OH 45250 

Ohio, Pennsylvania, 

Rhode Island, South 

Carolina, Tennessee, 

Vermont, Virginia, West 

Virginia, Wisconsin 

Specific Instructions 

Line 1b. Enter your employer identification number 

(EIN) if you are requesting a copy of a business 

return. Otherwise, enter the first social security 

number (SSN) or your individual taxpayer 

identification number (ITIN) shown on the return. 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. For a 

business address, file Form 8822-B, Change of 

Address or Responsible Party — Business. 

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 are completed before 

signing. 

F! 

CAUTION

You must check the box in the 

signature area to acknowledge you 

have the authority to sign and request 

the information. The form will not be 

processed and returned to you if the box is 

unchecked. 

Individuals. Copies of jointly filed tax returns may 

be furnished to either spouse. Only one signature is 

required. Sign Form 4506 exactly as your name 

appeared on the original return. If you changed your 

name, also sign your current name. 

Corporations. Generally, Form 4506 can be 

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

the corporation, (2) any person designated by the 

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

any officer or employee on written request by any 

principal officer and attested to by the secretary or 

other officer. A bona fide shareholder of record 

owning 1 percent or more of the outstanding stock 

of the corporation may submit a Form 4506 but must 

provide documentation to support the requester's 

right to receive the information. 

Partnerships. Generally, Form 4506 can be 

signed by any person who was a member of the 

partnership during any part of the tax period 

requested on line 7. 

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

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

trustee, guardian, executor, receiver, or 

administrator is acting for the taxpayer. 

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

Beneficiary you must be able to establish a material 

interest in the estate or trust. 

Documentation. For entities other than individuals, 

you must attach the authorization document. For 

example, this could be the letter from the principal 

officer authorizing an employee of the corporation or 

the letters testamentary authorizing an individual to 

act for an estate. 

Signature by a representative. A representative 

can sign Form 4506 for a taxpayer only if this 

authority has been specifically delegated to the 

representative on Form 2848, line 5. Form 2848 

showing the delegation must be attached to Form 

4506. 

Privacy Act and Paperwork Reduction Act 

Notice. We ask for the information on this form to 

establish your right to gain access to the requested 

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

this information to properly identify the return(s) and 

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

tax return, sections 6103 and 6109 require you to 

provide this information, including your SSN or EIN, 

to process your request. If you do not provide this 

information, we may not be able to process your 

request. Providing false or fraudulent information 

may subject you to penalties. 

Routine uses of this information include giving it to 

the Department of Justice for civil and criminal 

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

and U.S. commonwealths and possessions for use 

in administering their tax laws. We may also 

disclose this information to other countries under a 

tax treaty, to federal and state agencies to enforce 

federal nontax criminal laws, or to federal law 

enforcement and intelligence agencies to combat 

terrorism. 

You are not required to provide the information 

requested on a form that is subject to the Paperwork 

Reduction Act unless the form displays a valid OMB 

control number. Books or records relating to a form 

or its instructions must be retained as long as their 

contents may become material in the administration 

of any Internal Revenue law. Generally, tax returns 

and return information are confidential, as required 

by section 6103. 

The time needed to complete and file Form 4506 

will vary depending on individual circumstances. The 

estimated average time is: Learning about the law 

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

and Copying, assembling, and sending the form 

to the IRS, 20 min. 

If you have comments concerning the accuracy of 

these time estimates or suggestions for making 

Form 4506 simpler, we would be happy to hear from 

you. You can write to: 

Internal Revenue Service 

Tax Forms and Publications Division 

1111 Constitution Ave. NW, IR-6526 

Washington, DC 20224. 

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

Where to file on this page. 
Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2311 Filed 05/24/22 Page 77 

of 78 

ATTACHMENT D 
 

 

 

 

Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2312 Filed 05/24/22 Page 78 

of 78 

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 very 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 

the Federal Trade Commission v. Financial Education Services, Inc., et al., now pending in the 

United States District Court for the Eastern District of Michigan, and this shall be irrevocable 

authority for so doing. 

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