IN THE UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF MARYLAND 

In re SANCTUARY BELIZE 

LITIGATION 

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AMENDED FINAL 

Civil No. PJM 18-3309 

ORDER FOR PERMANENT INJUNCTION AND MONETARY JUDGMENT AGAINST 

DEFENDANTS ANDRIS PUKKE, PETER BAKER, AND LUKE CHADWICK 

The Federal Trade Commission ("FTC") has filed an Amended Complaint for Permanent 

Injunction and Other Equitable Relief ("Amended Complaint"), pursuant to Section 13(b) of the 

Federal Trade Commission Act ("FTC Act"), 15 U.S.C. § ,53(b ), and the Telemarketing and 

Consumer Fraud and Abuse Prevention Act ("Telemarketing Act"), 15 U.S.C. §§ 6101-6108, 

alleging that Defendants ~dris Pukke, Peter Baker, and Luke Chadwick violated the FTC Act 

and the Telemarketing Sales Rule through the deceptive marketing of lots in a development 

known variously as Sanctuary Bay, Sanctuary Belize, and The Reserve (for ease, "Sanctuary 

Belize"). Following a trial on the merits, which commenced on January 22, 2020 and concluded 

on February 12, 2020, and as detailed in the accompanying Memorandum Opinion dated August 

28, 2020, the Court has found Pukke, Baker, and Chadwick liable on all counts. To the extent 

necessary, the Court amends the allegations in the Amended Complaint to conform to the proof 

at trial. The Court's reasoning and specific findings are detailed in the Memorandum Opinion 

dated August 28, 2020. 

IT IS THEREFORE ORDERED: 

FINDINGS 

1. This Court has jurisdiction over this matter. 

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2. The Amended Complaint charges that Andris Pukke, Peter Baker, and Luke 

Chadwick, along with theirfellow Defendants, controlled and participated in deceptive acts or 

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

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Telemarketing Sales Rule, !6 C.F.R. Part 310, in connection with the sale oflots in a 

development in Belize known as Sanctuary Belize. 

3. Although the relevant Findings of Fact are more fully set out in the accompanying 

Memorandum Opinion, and are incorporated herein, the Court makes the following Findings in 

accordance with that Opini?,'n: 

a. Since 2005, Pukke, Baker, and their co-Defendants have sold Jots in the 

development:known by various names and identified herein as Sanctuary Belize. 

b. For h/s part, Luke Chadwick controlled or participated in these acts or 

practices commencing in 2008. 

c. Follo~ing the 2008 settlement between the Receiver and Sittee River 

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Wildlife Res.erve, Pukke, Baker, and Chadwick took steps to hide Andris Pukke's 

involvement'in Sanctuary Belize, including through Pukke's use of aliases such as 

"Marc Romeb" and "Andy Storm." 

d. Under the control of Pukke, Baker and Chadwick, and frequently with 

their direct p:articipation, all Corporate Defendants and Individual Defendants 

participated in the sale of Sanctuary Belize lots through telemarketers in the 

United States, while making the following claims, all of which were and are false 

and materiat: 

i. That Defendants used a "no debt" business model to develop 

'' Sanctuary Belize which would make Jots in Sanctuary Belize a less 

· L risky investment than one in which the developer would make 

payments to lenders; 

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ii. That every dollar Defendants collected from Sanctuary Belize lot 

sales would go back into the development; 

iii. That Defendants would finish Sanctuary Belize quickly, including 

within two to three years, or within five years; 

iv. That the finished Sanctuary Belize would have all of the amenities 

expected of an American luxury resort community, such as: (i) a 

hospital staffed with American physicians and nurses near the 

development; (ii) an emergency medical center near the downtown 

"Marina Village;" (iii) a championship-caliber golf course; (iv) a 

local airport within the development; (v) a new international 

airport nearby with direct flights to and from the United States; (vi) 

a "Marina Village" containing high-end boutiques, restaurants, 

cafes, an American-style grocery store, an elegant casino, and a 

hotel; and (vii) a 250-slip world-class marina; 

v. That consumers could realize the rapid appreciation of their lots 

within Sanctuary Belize because there is a robust resale market 

through which consumers could easily resell their lots should they 

choose to do so; and 

v1. That Andris Pukke has had no meaningful involvement with 

Sanctuary Belize or with the Defaulting Corporate Defendants.1 

1 Defendants also made a claim that lots sold to purchasers would appreciate in value from 100% to 500% within two 

to three years. As set forth in the Memorandum Opinion, the Court did not find this claim to be a violation of the FTC 

Act or the TSR. 

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e. These representations were likely to mislead consumers acting reasonably 

under the circumstances, these representations were material, and consumers 

relied on these representations. 

f. Except for Atlantic International Bank, the Corporate Defendants 

(including Defaulting Defendants) operated as a common enterprise ("SBE") in 

making these claims. 

g. SBE initiates or receives interstate telephone calls from consumers as part 

of a program-to sell services to those consumers. 

h. SBE offers to provide goods and services through telemarketing. 

1. Pukke, Baker, Usher, and Chadwick knew or should have known that the 

claims identified were false at the time they were made, or were at the least 

recklessly indifferent to the truth of the claims. 

j. As a result of these false claims, consumers paid the Defendants at least 

one hundred twenty million, two hundred thousand dollars ($120,200,000). 

k. Usher and the Defaulting Corporate Defendants are jointly and severally 

liable with Pukke, Baker, Usher and to an extent, Chadwick. 

DEFINITIONS 

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

property, wherever located and by whomever held, whether tangible, intangible, digital, or 

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otherwise, including, but not limited to, digital currencies, virtual currencies, digital tokens, and 

cryptocurrencies. For clarity, "Asset" includes Receivership Entities themselves, in addition to 

rights and things the Receivership Entities control. 

B. "Corporate Defendant(s)" means Global Property Alliance, Inc., Sittee River 

Wildlife Reserve, Buy Belize, LLC, Buy International, Inc., Foundation Development 

Management, Inc., Eco-Futures Development, Eco-Futures Belize Limited, Newport Land Group 

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LLC, Power Haus Marketi11g, Sanctuary Belize Property Owners' Association, Prodigy 

Management Group LLC, Foundation Partners, BG Marketing, LLC, Ecological Fox, LLC, 

Belize Real Estate Affiliates LLC, Exotic Investor LLC, Southern Belize Realty LLC, and 

Atlantic International Bank.Ltd and each of their subsidiaries, affiliates, successors, and assigns, 

collectively, individually, or in any combination. 

C. "Defendant(s)" means the Corporate Defendants, Individual Defendants, and 

Relief Defendants, collectively, individually, or in any combination. 

D. "Individual Defendant(s)" means Andris Pukke, Peter Baker, Luke Chadwick, 

John Usher, Rod Kazazi, Brandi Greenfield, Frauk Costanzo, and Michael Santos collectively, 

individually, or in any combination. 

E. "Real Estate Good or Service" means any interest in, service related to, or 

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development of, any real estate containing or involving three or more lots or units of any kind. 

F. "Receiver" n,ieans the receiver appointed in Section VI of this Order and any 

deputy receivers who shall _be named by the temporary receiver. · 

G. "Receivership Asset" means any and all Assets ordered to be turned over or 

relinquished to the Receiver pursuant to this Order. 

H. "Receivership Entities" means the Corporate Defendants ( except Atlantic 

International Bank, Ltd., Ecological Fox, LLC, BG Marketing, LLC, and Foundation Partners), 

2729 Bristol LLC, and 3905 Marcus LLC, as well as any other entity that: (1) was located at, 

registered to, or operated from 3333 Michelson Drive, Suite 500, Irvine, California as of 

November 7, 2018, and assi,sts, facilitates, or otherwise conducts business related to the sale of 

real estate in Belize; (2) assists, facilitates, or otherwise conducts business related to the acts 

identified in the Findings of Fact in this Order, and is owned or controlled by any Defendant; or 

(3) Assets that are otherwise in the Receivership and that are corporations or other legal entities. 

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I. "ReliefDefondant(s)" means Angela Chittenden, Beach Bunny Holdings LLC, 

the Estate of John Pukke, John Vipulis, and Deborah Connelly. 

J. "Telemarketing" means any plan, program, or campaign which is conducted to 

induce the purchase of goods or services by use of one or more telephones, and which involves a 

telephone call, whether or 1)-0t covered by the Telemarketing Sales Rule. 

ORDER2 

I. BAN ON REAL ESTATE GOODS AND SERVICES 

IT IS ORDERED that Pukke, individually, collectively, or in any combination, is 

permanently restrained and;enjoined from advertising, marketing, promoting, or offering for sale, 

or assisting others in the advertising, marketing, promoting, or offering for sale of any Real 

Estate Good or Service, whether directly or through an intermediary, including by consulting, 

brokering, planning, investing, or advising. Further, Baker and Chadwick, individually, 

collectively, or in any combination, are permanently restrained and enjoined from any 

involvement with Sanctuary Belize or any future incarnation. Additionally, Baker and Chadwick, 

individually, collectively, or in any combination, are also permanently restrained and enjoined 

from any involvement with the development known as "Kanantik" or any future incarnation. 

Nothing herein prohibits the Receiver or any transferee of the Receiver from selling any 

Receivership Asset, including any Receivership Asset any Receivership Entity controls. 

II. BAN ON TELEMARKETING 

IT IS FURTHER O)IDERED that Pukke, Baker, and Chadwick individually, collectively, 

or in any combination, are permanently restrained and enjoined from Telemarketing or assisting 

2 Unless otherwise specified in this or any other order of the Court, injnnctive relief shall be permanent in natnre 

and global io geographic application aod nnlimited in temporal application. 

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others in Telemarketing in any commercial enterprise whatsoever, whether directly or through an 

intermediary, including by consulting, brokering, planning, investing, or advising. 

III. PROIDBITION AGAINST MISREPRESENTATIONS IN THE SALE OF ANY 

GOOD OR SERVICE 

IT IS FURTHER ORDERED that Pukke, Baker, and Chadwick individually, collectively, 

or in any combination, 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 h1directly, in connection with advertising, marketing, promoting, or 

offering for sale any good or service of any nature whatsoever, are permanently restrained and 

enjoined from misrepresenting, or assisting others in misrepresenting, expressly or by 

implication: 

A. That the use· of a "no debt" business model makes an investment less risky than 

one in which an entity or individual must make payments to lenders; 

B. That every dollar, or the vast majority of dollars, collected from selling the good 

or service will be used to develop the good or service; 

C. That, unless guaranteed, the good or service will be completed or available within 

a specified period of time, such as a particular number of weeks, months, or years; 

D. That, unless guaranteed, the good or service will feature specific amenities; 

E. That consurrfers can realize the appreciation of their good or service because there 

is a robust resale market through which consumers can easily resell their good or service should 

they choose to do so; 

F. That any particular person or entity has no meaningful involvement with the 

relevant business when the person or entity in fact does; and 

G. That any otl\er fact material to consumers concerning any good or service is true, 

if there is any basis for believing it is not true. This includes, as to any good or service: the total 

:i 

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costs; any material restrictions, limitations, or conditions; or any material aspect of its 

performance, efficacy, nature, or central characteristics. 

IV. ; EQUITABLE MONETARY JUDGMENT 

IT IS FURTHER ORDERED that: 

A. Judgment in'.the amount of one hundred twenty million, two hundred thousand 

dollars ($120,200,000) is entered in favor of the FTC against Pukke and Baker, jointly and 

severally, as equitable monetary relief ("Equitable Monetary Judgment"). Judgment in the 

amount of ninety-one million, nine hundred and two thousand, seven hundred and twenty-five ,, 

dollars and ninety-one cent~:($91,902,725.91) is entered in favor of the FTC against Chadwick, 

jointly and severally with ~e, Baker, Usher and the Defaulting Corporate Defendants. 

B. In accordante with this Order, Pukke, Baker, and Chadwick, their officers, agents, 

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

them, who receive actual notice of this Order, shall transfer to the FTC within thirty (30) days all 

Assets (other than personal'use real estate) subject to the direct or indirect control of Pukke, 

Baker, or Chadwick less th~n or equal to the Equitable Monetary Judgment (as reduced by the 

amounts, if any, already distributed to the FTC), regardless of where they are held and under 

what name they are held. This transfer shall be made by electronic fund transfer in accordance 

with instructions provided by a representative of the FTC. Provided, however, that Pukke, Baker, 

and Chadwick may each withhold no more than a total of $5,000 in such assets other than 

personal use real estate. If any of them intends to withhold any such funds, he shall within thirty 

(30) days of entry of this Order provide prior written notice to counsel for the FTC, sworn to 

under penalty of perjury, that he intends to withhold such Assets and shall submit a written 

report detailing the source (e.g., employment-and, if so, from what employment-or 

inheritance or gift-and, if,so, from whom and when), the location, and the amount of the funds 

Case 1:18-cv-03309-PJM Document 1194 Filed 03/24/21 Page 8 of 35 
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being withheld. Should the rTc deem the proposed withholding inappropriate, it may move the 

Court for appropriate relief. 

C. Pukke, Bakef, and Chadwick shall forever relinquish and no longer have any 

rights to any and all Assets,previously transferred in fact or by operation of law to the Receiver, 

pursuant to the prior Temporary Restraining Order (ECF No. 13) entered on November 5, 2018, 

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the Interim Preliminary Injunction (ECF No. 34) entered on November 20, 2018, or the 

Preliminary Injunction (ECF No. 615) entered on October 3, 2019 (including, without limitation, 

the Receivership Entities themselves). The Receiver shall retain possession or control of those 

Assets (including the Receivership Entities themselves) in accordance with the terms of the 

present Order and the Receiver shall marshal and then liquidate all such assets for the benefit of 

the FTC, in such sequence a,nd at such time or times as the Receiver in its discretion shall deem 

appropriate. For clarity, these Assets (including the Receivership Entities themselves) are 

Receivership Assets. The Receivership Assets (including the Receivership Entities themselves 

and any Assets turned over to the Receiver in satisfaction of the Equitable Monetary Judgment) ., 

shall be held in constructive trust by the Receiver for the sole benefit of the FTC and lot 

purchasers at Sanctuary Belize, so that the Receiver can disburse assets to the lot purchasers. 

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D. Pukke, Baker, and Chadwick, and their officers, agents, employees, and attorneys, 

shall, within thirty (30) day~ of the entry of this Order, take all steps possible or necessary to 

transfer to the Receiver all Assets that Pukke, Baker, or Chadwick own or control, directly or 

indirectly, or which are held for their benefit, that exceed $2,500 in value (as determined by the 

Receiver) that they have not otherwise been ordered to transfer pursuant to paragraph B above. 

Said Defendants shall be entitled to the benefit of any homestead law provided by the State of 

California. Once the Receiver has disbursed to the FTC an amount equal to the Equitable 

Monetary Judgment, the provisions of this sub-paragraph IV.D shall no longer apply. For clarity, 

these Assets are Receivers~ip Assets. Additionally, and also for clarity, Pukke, Baker, and 

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Chadwick each shall have an ongoing obligation, by the end of each calendar month, to apprise 

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the FTC and Receiver of their total current income (and any change in income) and the 

acquisition of any additional Assets new or used, worth, or potentially worth, more than $2,500. 

Additionally, Pukke, Baker, and Chadwick each shall, within the same time period, report to the 

Receiver the acquisition, bY,·any means, of any Asset that may be worth $2,500 or more. Pukke, 

Baker, and Chadwick each has ongoing obligations to transfer to the FTC, in accordance with 

instructions from an FTC representative, employment income in an amount up to the maximum 

allowed under 15 U.S.C. § 1673 (e.g., up to 25% of disposable earnings on a weekly basis), and 

shall transfer to the Receiver all other Assets, new or used, that they acquire or control, by any 

other means, valued at more than $2,500, as determined by the Receiver. For clarity, these 

provisions necessarily pertain to income and Assets acquired after the entry of this Order and 

these obligations shall cont_inue in effect until the Receivership has been closed by the Court, the 

Equitable Monetary Judgment has been fully satisfied, or upon further Order of the Court. If, 

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upon the closure of the Rec~ivership the Equitable Monetary Judgment has not been satisfied, 

Pukke, Baker, and Chadwick each shall make the same reports detailed above to the FTC and, 

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pursuant to instructions from an FTC representative, transfer income and assets to the FTC or for 

the FTC's benefit pursuantto those instructions. Pukke, Baker, and Chadwick shall make the 

required reports to the FTC by email to current FTC counsel ofrecord as well as emailed to 

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

Associate Director for Enforcement, Bureau of Consumer Protection 

Federal Trade Comrilission, 

Attn: In re Sanctuary Belize Litigation, 18-cv-3309 (D. Md.), FTC File No. X040009 

600 Pennsylvania Avenue, NW 

Washington, DC 20580. 

Within fourteen (14) days after receiving instructions from an FTC representative, Pukke, Baker, 

and Chadwick shall then transfer, liquidate, and/or dispose of the Asset(s) in accordance with the 

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FTC's instructions. All reports completed pursuant to this paragraph must be signed and sworn ... 

to under penalty of perjury: 

E. Pukke, Baker, and Chadwick individually, collectively, or in any combination, 

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

participation with any ofth~m, who receive actual notice of this Order, shall fully cooperate with 

and assist the FTC and the Receiver with the turnover of Assets pursuant to this Order, and are 

hereby restrained and enjoined from directly or indirectly: 

1. Interfering with the FTC's and Receiver's efforts to manage, or take 

custody, control, or possession of; the Assets ordered to be turned over to 

the FTC or the Receiver; 

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2. Transacting any of the business of any Receivership Entity or any entity 

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that itself is a Receivership Asset; 

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

assigning, liquidating, or otherwise disposing of any Assets ordered to be 

turned over to the FTC or the Receiver; or ,,: ' 

4. Refusing to cooperate with the FTC or the Receiver, or the Receiver's 

duly:authorized agents, in the exercise of their duties or authority under 

any order of this Court. 

V. ADDITIONAL MONETARY PROVISIONS 

A. Pukke, Bakcir, and Chadwick shall relinquish dominion and all legal and equitable 

right, title, and interest in all Assets turned over or relinquished pursuant to this Order and may 

not seek the return of any Assets, without prior authorization by the Court. 

B. All money paid to the FTC pursuant to this Order may be deposited into a fund 

administered by the FTC or.its designee to be used for equitable relief, including consumer 

redress and any attendant expenses for the administration of any redress fund. Said Defendants 

·, 

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shall have no right to challenge any actions the FTC or its representatives may take pursuant to 

this paragraph, nor may they otherwise challenge the ultimate disposition of the Assets turned 

over to the FTC or the Receiver. 

C. Within thirty (30) days following the entry of this Order, Defendants Pukke, 

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Baker, and Chadwick each shall complete and submit to the FTC and the Receiver the attached 

Financial Statement of Individual Defendant. Thereafter, Pukke, Baker, and Chadwick each shall 

recomplete and submit to th,e FTC and the Receiver the same form (or similar form to be 

provided by the FTC) upon one ( 1) year following the entry of this Order and must recomplete 

and submit to the FTC that same form every year thereafter until they receive notice from the 

FTC that they need not continue to complete such forms or they have satisfied in full the 

Equitable Monetary Judgm~nt. Each such form must be submitted with all of the required and 

specified attachments. Each such form must be signed and sworn to under penalty of perjury. 

The forms must be submitted electronically to FTC counsel of record in this matter in a manner 

to be specified by FTC counsel. Additionally, the forms must be emailed to DEbrief@ftc.gov or 

sent by overnight courier (not the U.S. Postal Service) to: 

Associate Director for Enforcement, Bureau of Consumer Protection 

Federal Trade Cominission 

Attn: In re Sanctuary Belize Litigation, 18-cv-3309 (D. Md.), FTC File No. X040009 

600 Pennsylvania Avenue, NW 

Washington, DC 2Q580. 

D. The asset freeze imposed on Pukke, Baker, and Chadwick pursuant to the prior 

Temporary Restraining Order (ECF No. 13) entered on November 5, 2018, Interim Preliminary 

Injunction (ECF No. 34) entered on November 20, 2018, or Preliminary Injunction (ECF No. 

615) entered on October 3, 2019, is hereby modified to the extent necessary to permit the 

transfers identified in the Equitable Monetary Judgment Section. Upon full satisfaction of the 

Equitable Monetary Judgment, the FTC shall make a full report of satisfaction, at which time the 

Court, upon review and approval of the report, shall dissolve the asset freeze. 

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E. Upon full satisfaction of the Equitable Monetary Judgment, closure of the 

Receivership, or a subsequent order of the Court, following formal notice by the Receiver to the 

Court that the Receiver is satisfied that Pukke and Baker have fully transferred to the 

Receivership all Assets that they hold greater in value than $2,500 ( as determined by the 

Receiver), the Receiver shall return to Puk:ke and Baker any passports it holds in their names 

within thirty (30) days of the giving of notice. The FTC, Pukke, and Baker shall have an 

opportunity to comment upon such proposed transfer of passports. The return of a passport shall 

not be construed as a concession that Puk:ke or Baker has turned over all Assets he is required to 

tum over pursuant to this Order or that he has satisfied the Equitable Monetary Judgment. 

VI. RECEIVER 

IT IS FURTHER ORDERED that Robb Evans & Associates LLC is appointed as 

Receiver for all Assets ordered to be turned over to the Receiver pursuant to this Order. It shall 

have full powers of an equity receiver. The Receiver shall be solely the agent of this Court in 

acting as Receiver under thi,s Order. 

VII. 'DUTIES AND AUTHORITY OF RECEIVER 

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

the following: 

A. Take exclusive control, custody, and possession of all Receivership Assets. 

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

perform all acts necessary or advisable to preserve the value of those Assets. The Receiver shall 

assume control over the income and profits therefrom and all sums of money now or hereafter 

due or owing to any entity that is a Receivership Asset or otherwise due or owing to Pukke, 

Baker, or Chadwick as a re~ult of any Receivership Assets. The Receiver shall have full power to 

sue for, collect, and receive~ all Receivership Assets. Provided, however, that the Receiver shall 

not, without prior Court approval, attempt to collect any amount from a consumer if the Receiver 

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believes the consumer's debt has resulted from deceptive acts or practices or other violations of 

law. 

C. Liquidate, th,rough fair market sales or similar transactions, all Receivership 

Assets, following a motion and order from the Court approving the sale or liquidation. The 

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Receiver shall take steps to: attempt to obtain the full fair market value of any Asset that is 

obtained by the Receivershjp estate in any sale or liquidation. 

D. Disburse periodically to the FTC, lot purchasers, or other third parties as provided 

by separate Court order, less its Court-approved fees and expenses or reasonably anticipated 

potential expenses including, without limitation, expenses or liabilities not yet known at the time 

of the disbursements, as approved by the Court. At the time of a periodic disbursement to the 

FTC, the Receiver shall als_<;i disburse to the FTC the amount of any and all withheld prior ... , 

anticipated potential expenses that were not in fact incurred. 

E. 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 dutie~. and responsibilities under the authority granted by this Order; 

F. Make paym~~ts 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 hfa or her duties as Receiver. The Receiver shall apply to the Court for 

prior approval of any payment of any debt or obligation incurred, except payments that the 

Receiver deems necessary or advisable to secure Receivership Assets, such as rental payments; 

G. Enter into and cancel contracts and purchase insurance as advisable or necessary; 

H. Prevent the i,ilequitable distribution of Assets and determine, adjust, and protect 

the interests of consumers who have transacted business with Pukke, Baker, Chadwick, any 

entity that is a Receivership Asset, or the Receivership Entities; 

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

financial condition of the R~ceivership and file the accounting with the Court and deliver copies 

thereof to all parties; 

J. Institute, compromise, adjust, appear in, intervene in, defend, dispose of, or 

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

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

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Receivership Assets, or to carry out the Receiver's mandate under this Order, including but not 

limited to actions challenging fraudulent or voidable transfers; 

K. Demand fro:n any person or entity documents and records pertaining to the 

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Receivership Assets within,'¢ree (3) days after delivery of the Order by mail, courier, email, or 

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other method by which the recipient receives a copy of this Order, in addition to obtaining 

discovery pursuant to the F 7deral Rules of Civil Procedure, including subpoenas seeking 

documents and/or testimony under Rule 45; 

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

Receivership estate. The Receiver shall deposit all funds of the Receivership estate in such 

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designated accounts and sh~ll make all payments and disbursements from the Receivership estate 

from such accounts. The Receiver shall serve copies of monthly account statements on all 

parties; 

M. 

N. 

I 

Maintain accurate records of all receipts and expenditures incurred as Receiver; ,_, 

Cooperate with reasonable requests for information or assistance from any state or 

federal civil or criminal law; enforcement agency; 

0. Suspend business operations of any entity that is a Receivership Asset if in the 

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

P. If in the Receiver's judgment the business operations of any Receivership Asset 

cannot be continued legally:and profitably, take all steps necessary to ensure that any of the web 

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pages or websites relating td the activities of the Receivership Asset 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 Asset cannot be 

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

'./ 

regarding the status of oper~tions. 

VIII. STAY OF ACTIONS 

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

the Receivership ordered herein, Defendants and their 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, les~ors, customers and other persons seeking to establish or enforce any 

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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 any action that would interfere with the 

exclusive jurisdiction of this Court over the Receivership Assets, including, but not limited to: 

A. Filing or assisting in the filing ofa petition for relief under the Bankruptcy Code, 

11 U.S.C. § 101 et seq., or of any similar insolvency proceeding on behalf of any entity that is a 

Receivership Asset; 

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

or proceeding against any of the Receivership Assets or otherwise seeking an interest in any of 

the Receivership Assets, including the issuance or employment of process, except that such 

actions may be commenced 'if necessary to toll any applicable statute oflimitations; 

C. Filing or enforcing any lien on any Receivership Asset, taking or attempting to 

take possession, custody, or control of any Receivership Asset; or attempting to foreclose, 

forfeit, alter, or terminate any interest in any Receivership Asset, whether such acts are part of a 

judicial proceeding, are acts· of self-help, or otherwise. 

··, 

,, 

Case 1:18-cv-03309-PJM Document 1194 Filed 03/24/21 Page 16 of 35 
17 

Provided, however, 'that this Order does not stay: (I) the commencement or continuation 

of a criminal action or proc_eeding; (2) the commencement or continuation of an action or 

• 

proceeding by a governmental unit to enforce such governmental unit's police or regulatory 

h 

power; or (3) the enforcem~nt 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. 

IX. COMPENSATION OF RECEIVER 

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

herein authorized, including counsel to the Receiver and accountants, are entitled to reasonable 

compensation for the performance of duties pursuant to this Order and for the cost of actual outof-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 estate. 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 n!) more than sixty ( 60) days after the date of entry of this Order. The 

Receiver shall not increase the hourly rates used as the bases for such fee applications without 

prior approval of the Court:,,Whenever the Receiver submits such a request for payment, or at 

other times within the Receiver's discretion, the Receiver shall also submit a report regarding: 

(1) the steps taken by the Temporary Receiver to implement the terms of this Order; (2) the value 

of all liquidated and unliquidated Receivership Assets; (3) the sum of all liabilities of any 

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

diminution in the value of the Receivership Assets and (b) acquire additional Assets from Pukke, 

Baker, Chadwick, or any otl).er person or entity; and (5) any other matter which the Receiver 

believes should be brought:to the Court's attention. Provided, however, if any of the required 

information would hinder the Receiver's ability to pursue Assets, the portions of the Receiver's 

Case 1:18-cv-03309-PJM Document 1194 Filed 03/24/21 Page 17 of 35 
18 

report containing such information may be redacted and be filed for the Court's benefit under 

seal without service on the 'parties. 

X. CUSTOMER INFORMATION 

IT IS FURTHER ORDERED that Pukke, Baker, and Chadwick individually, collectively, 

•,' 

or in any combination, and their officers, agents, employees, and attorneys, and all other persons ,; 

in active concert or participi:tion with any of them, who receive actual notice of this Order, are 

permanently restrained and,enjoined from directly or indirectly: 

A. Failing to provide sufficient customer information to enable the FTC to efficiently 

administer consumer redress. If a representative of the FTC requests in writing any information 

related to redress, Pukke, Baker, and Chadwick each shall provide it, in the form prescribed by 

the FTC, within fourteen (14) days. 

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

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

information, or any data that enables access to a customer's account (including a credit card, 

bank account, or other financial account), that Pukke, Baker, or Chadwick obtained prior to entry 

of this Order; and 

C. Failing to d~stroy such customer information in all forms in their possession, 

custody, or control within 11:1irty (30) days after receipt of written direction to do so from a 

representative of the FTC. : 

c;, 

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

disclosed, to the extent requested by a government agency or required by law, regulation, or 

court order. 

XI. AEKNOWLEDGMENT OF RECEIPT OF ORDER 

IT IS FURTHER ORDERED that Pukke, Baker, and Chadwick shall submit 

acknowledgments of receipt of this Order as follows: 

Case 1:18-cv-03309-PJM Document 1194 Filed 03/24/21 Page 18 of 35 
., 

19 

·' 

A. Pukke, Baker, and Chadwick each shall, within seven (7) days of entry of this 

Order, submit to the FTC a~tten acknowledgment ofreceipt ofthis Order, sworn to under 

penalty of perjury. 

B. For each of.~enty (20) years after entry of this Order, for any business that 

Pukke, Baker, or Chadwick, individually or collectively with any other Defendants, is the 

·+ . 

majority owner of, or controls directly or indirectly, said Defendant shall deliver a copy of this 

:r 

Order to: ( 1) all principals, officers, directors, and LLC managers and members; (2) all 

employees having manage~al responsibilities for marketing, sales, or operations; and (3) any 

business entity resulting from any change in structure as set forth in the Section titled 

Compliance Reporting. Delivery of a copy of this Order must occur within seven (7) days of 

entry of this Order for curr~nt personnel. For all others, Pukke, Baker, and Chadwick shall 

deliver a copy of this Order before they assume their responsibilities with any such business. 

I 

C. From each i4dividual or entity to which Pukke, Baker, or Chadwick delivers a 

copy of this Order, that Defendant shall obtain, within 30 days, a signed and dated 

acknowledgment of receipfof this Order. 

XII. COMPLIANCE REPORTING 

IT IS FURTHER ORDERED that Pukke, Baker, and Chadwick shall make timely 

submissions to the FTC: 

A. One year afWr entry of this Order, Pukke, Baker, and Chadwick shall each submit 

a compliance report, swom'-.to under penalty of perjury, which shall: 

1. (a) identify their primary physical, postal address, email address, and 

telephone number, as designated points of contact, which representatives 

of the FTC may use to communicate with Defendant; (b) identify all of 

that Defendant's businesses, whether owned or controlled by them, :,, 

directly or indirectly, giving all of their names, telephone numbers, and 

Case 1:18-cv-03309-PJM Document 1194 Filed 03/24/21 Page 19 of 35 
20 

physi,cal, postal, email, and Internet addresses; ( c) describe the activities of 

each.such business, including the goods and services offered, the means of 

:· 

advertising, marketing, and sales, and the involvement of any other 

·' 

Defendant (which each must describe the other Defendant in detail, 

inch1ding the other Defendant's title, position, compensation, and duties); 

( d) describe in detail whether and how each Defendant's involvement in 

each:'such business is in compliance with each Section of this Order; and 

( e) provide a copy of each Order Acknowledgment sought and obtained 

';. 

purs~ant to this Order, unless previously submitted to the FTC. 

2. Additionally, in such compliance report, Pukke, Baker and Chadwick 

shall:'.(a) identify all telephone numbers and all their physical, postal, 

email and Internet addresses, including all residences used by them; (b) 

identify all business activities, including any business for which such 

Def~~dant performs services whether as an employee or otherwise and any 

entitf in which such Defendant has any ownership interest, whether 

direc;tly or indirectly; and ( c) describe in detail such Defendant's 

involvement in each such business, including title, role, responsibilities, 

parti~ipation, authority, control, and any ownership. 

B. For each of twenty (20) years after entry of this Order, Pukke, Baker, and 

Chadwick each shall submit a compliance report, sworn to under penalty of perjury, within 

fourteen (14) days of any change in the following: 

1. ( a) ai}y designated point of contact for them; or (b) the structure of any 

entity' that Defendant has any ownership interest in or controls directly or 

' 

indirectly that may affect compliance obligations arising under this Order, 

including details as to the creation, merger, sale, or dissolution of the 

Case 1:18-cv-03309-PJM Document 1194 Filed 03/24/21 Page 20 of 35 
21 

entity or any subsidiary, parent, or affiliate that engages in any acts or 

' 

practices subject to this Order . . , 

' 

2. Additionally, each must report any change in: (a) name, including aliases ,, 

or fi2titious name, or residence address of the Defendant; or (b) any title or 

\C 

role in any business activity, including any business for which a Defendant ., 

performs services whether as an employee or otherwise and any entity in 

which such Defendant has any ownership interest, and identify the name, 

physical address, and any Internet address of the business or entity. 

C. Pukke, Baker, and Chadwick each shall submit to the FTC notice of the filing of 

: 

any bankruptcy petition, insolvency proceeding, or similar proceeding by or against such 

·' 

Defendant, within fourteen,(14) days of any such filing. 

D. Any submission to the FTC required by this Order to be sworn under penalty of 

perjury must be true and acyurate and must comply with 28 U.S.C. § 1746, such as by 

concluding: "I declare under penalty of perjury under the laws of the United States of America ,,, 

that the foregoing is true ari~ correct. Executed on: __ " and supplying the date, the 

isignatory's full name, title (if applicable), and signature. 

E. Unless othe:Wise directed by an FTC representative in writing, all submissions to 

the FTC pursuant to this Order must be emailed to DEbrief@ftc.gov or sent by overnight courier 

" 

-'; 

(not the U.S. Postal Service) to: Associate Director for Enforcement, Bureau of Consumer 

Protection, Federal Trade Commission, 600 Pennsylvania Avenue NW, Washington, DC 20580. 

The subject line must begim/n re Sanctuary Belize Litigation, 18-cv-3309 (D. Md.), FTC File 

No. X040009. 

F. Notwithstan4ing any other provision herein, Pukke must maintain the email 

address ekkup@msn.com, Baker must maintain the email address peterbakerx@gmail.com, and 

Chadwick must maintain the email address luketchadwick@grnail.com. Also notwithstanding 

Case 1:18-cv-03309-PJM Document 1194 Filed 03/24/21 Page 21 of 35 
22 

\' 

any other provision hereini~ervice of any notice, process, or other item that requires any form of 

delivery shall be valid if the FTC serves it: ( 1) to the appropriate aforementioned email address 

of the Defendant; (2) to any other email address identified by the Defendant to whom service is 

directed; or (3) by any othe~ method reasonably calculated to achieve actual notice to the 

Defendant. 

XIII. ALIASES AND NOMINEES 

IT IS FURTHER ORDERED that Pukke, Baker, and Chadwick individually, collectively, 

or in any combination, 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, are 

permanently restrained and enjoined from, directly or indirectly, engaging in any business or 

commercial activity of any 1sort in which Pukke, Baker, or Chadwick has consented to, or 

acquiesced to, the use of fill: alias or pseudonym by them, for them or for any individual 

associated with them and are further permanently restrained and enjoined from, directly or ,;,, 

indirectly, engaging in any business or commercial activity of any sort through the use of 

nominees, strawmen, or any other manner by which their ownership or control is obscured or 

hidden. 

XIV. RECORDKEEPING 

IT IS FURTHER ORDERED that Pukke, Baker, and Chadwick each shall create certain 

records for twenty (20) years after entry of the Order, and shall retain each such record for five ,. 

( 5) years. Specifically, for a,ny business that Pukke, Baker, or Chadwick, individually or \ 

collectively with any other Defendants, is a majority owner or controls directly or indirectly, 

each such business shall create and retain the following records: 

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

Case 1:18-cv-03309-PJM Document 1194 Filed 03/24/21 Page 22 of 35 
23 

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

employee or otherwise, tha! person's: name; addresses; telephone numbers; job title or position; 

dates of service; and (if applicable) the reason for termination of such person's services; 

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

' 

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

D. all records n~cessary to demonstrate full compliance with each provision of this 

Order, including all submissions to the FTC; and 

E. a copy of each unique advertisement or other marketing material of the business. 

~- COMPLIANCE MONITORING 

' 

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

Pukke, Baker, and Chadwick with this Order, including any failure on their part to transfer any 

assets as required by this Order or otherwise to collect on the Equitable Monetary Judgment: 

A. Within fourteen (14) days of receipt ofa written request from a representative of 

' 

the FTC, each Defendant shkll: submit additional compliance reports or other requested ,, 

information, which must be'swom under penalty of perjury; appear for depositions; and produce 

' 

appropriate documents for inspection and copying. The FTC is authorized to obtain discovery, 

without further leave of court, using any of the procedures prescribed by Federal Rules of Civil 

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

B. For matters concerning this Order, the FTC is authorized to communicate directly 

I 

with Pukke, Baker, and Ch~dwick. Pukke, Baker, and Chadwick shall permit representatives of 

the FTC to interview any employee or other person affiliated with any entity any of them may 

own or control, directly or jndirectly, who has agreed to such an interview. The person 

interviewed may have couri1el present. 

C. The FTC may use all other lawful means to interact with Pukke, Baker, 

Chadwick, or any individm1l or entity they are associated or affiliated with, including posing 

Case 1:18-cv-03309-PJM Document 1194 Filed 03/24/21 Page 23 of 35 
24 

undercover through its representatives, as consumers, suppliers, or other individuals or entities, 

'· 

without the necessity of identification or prior notice. 

j",' 

D. Nothing in this Order shall limit the FTC's lawful use of compulsory process, 

pursuant to Sections 9 and 2.0 of the FTC Act, 15 U.S.C. §§ 49, 57b-1. 

· E. Upon written request from a representative of the FTC, any consumer reporting 

agency must furnish consumer reports concerning Pukke, Baker, and Chadwick, pursuant to 

Section 604(1) of the Fair Credit Reporting Act, 15 U.S.C. §1681b(a)(l). 

F. As should already be clear, the parties must at all times act reasonably and in 

good faith. Umeasonable requests for information or umeasonable refusal to comply with such 

requests may result in sancti,ons, including the payment of attorneys' fees. 

XVI. RETENTION OF JURISDICTION 

IT IS FURTHER ORDERED that this Court retains jurisdiction of this matter for 

purposes of construction, n;iodification, and enforcement of this Order. 

SO ORDERED, this ~ay of 1 ~21. 

:l 

! - SSITTE 

UNITED ST TES DISTRICT JUDGE 

Case 1:18-cv-03309-PJM Document 1194 Filed 03/24/21 Page 24 of 35 
Definitions and Instructions: 

FEDERAL TRADE COMMISSION 

FINANCIAL STATEMENT OF INDIVIDUAL DEFENDANT 

1. Complete all items. Enter "Nohe" or "N/A" ("Not Applicable") in the first field only of any item that does not apply 

to you. If you cannot fully ans.wer a question, explain why. 

,(.' 

2. "Dependents" inclu_de yo,ur sppuse, live-in ~ompanion, 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 jlirisdiction 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 17 46 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 

Attachment A 

Case 1:18-cv-03309-PJM Document 1194 Filed 03/24/21 Page 25 of 35 
BACKGROUND INFORMATION 

Item 1. Information About You 

Full Name Social Security No. 

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

Phone Numbers Date of Birth: I I 

Home: ( ) (mm/dd/yyyy) 

Fax: ( ) Place of Birth 

ORent D own From (Date): I I E-Mail Address 

(mm/dd/yyyy) 

Internet Home Page 

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

Address From: I I Until: I I 

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

Rent D own 

Address From: I I Until: I I 

O Rent D own 

Address From: I I Until: I I 

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 

I I 

(mm/dd/vvw) 

Address (if different from yours) Phone Number Place of Birth 

( ) 

LJ Rent LJOwn From (Date): I I 

(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 

I I 

(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 

Attachment A 

Case 1:18-cv-03309-PJM Document 1194 Filed 03/24/21 Page 26 of 35 
Item 5. Information About Dependents (whether or not they reside with you) 

Name and Address Social Security No. Date of Birth 

I I 

(mm/dd/yyyy) 

Relationship 

Name and Address Social Security No. Date of Birth 

I I 

/mm/dd/vvw) 

Relationship 

Name and Address Social Security No. Date of Birth 

I I 

/mm/dd/vvw) 

Relationship 

Name and Address Social Security No. Date of Birth 

I I 

/mm/dd/vvw) 

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

Year Income 

From (Month/Year) To (Month/Year) 

I I 20 $ 

Ownership Interest? Yes D No $ 

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

I I $ 

I I $ 

I I $ 

Company Name and Address Dates Employed Income Received: Y-T-D & 5 Prior Yrs. 

Year Income 

From (Month/Year) To (Month/Year) 

I I 20 $ 

Ownership Interest? Yes D No $ 

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

I I $ 

I I $ 

I I $ 

Company Name and Address Dates Employed Income Received: Y-T-D & 5 Prior Yrs. 

Year Income 

From (Month/Year) To (Month/Year) 

I I 20 $ 

Ownership Interest? D Yes D No $ 

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

I I $ 

I I $ 

I I $ 

Initials: 

2 of 10 Federal Trade Commission Financial Statement of Individual Defendant 

Attachment A 

Case 1:18-cv-03309-PJM Document 1194 Filed 03/24/21 Page 27 of 35 
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 Relief Requested Status or 

Proceedina 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 

Attachment A 

Case 1:18-cv-03309-PJM Document 1194 Filed 03/24/21 Page 28 of 35 
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 reauested in Item 24 with vour comoleted 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 fonn of currency, uricashed checks, and money orders. 

a. Amount of Cash on Hand $ I 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, st~k options, corporate bonds, mutual funds, U.S. government secunt1es (including 

but not limited to treasury bills and treasury notes), and state and municipal bonds. Also 11st any U.S. savings bonds. 

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

Broker House, Address Broker Account No. 

Current Fair Market Value I ~oan(s) Against Security 

$ 

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

Broker House, Address Broker Account No. 

Current Fair Market Value I ~oan(s) Against Security 

$ 

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

Broker House, Address Broker Account No. 

Current Fair Market Value 

I 

Loan(s) Against Security 

$ $ 

Initials: 

4 of 10 Federal Trade Commission Financial Statement of Individual Defendant 

Attachment A 

Case 1:18-cv-03309-PJM Document 1194 Filed 03/24/21 Page 29 of 35 
Item 11. Non-Public Business and Financial Interests 

~ist_ all non-publ!c b~sin~s and financi~I i~terests, includi~ _but not limited to any interest in a non-public corporation, subchapter-S corporation, limited 

habIhty c_orporati~ ( LL~ ). general or limited partnership, JOint venture, sole proprietorship, international business corporation or personal investment 

corporation, and 011 or mineral lease. 

Entity's Name & Address Type of Business or Financial Owner Ownership If Officer, Director, Member 

Interest (e.g., LLC, partnership) (e.g., self, spouse) % or Partner, Exact Title 

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

Debtor's Name & Address Date Obligation Original Amount Owed Nature of Obligation (if the result of a final court 

Incurred (Month/Year) $ judgment or settlement, provide court name 

I and docket number) 

Current Amount Owed Payment Schedule 

$ $ 

Debtor's Telephone Debtor's Relationship to You 

Debtor's Name & Address Date Obligation Original Amount Owed Nature of Obligation (if the result of a final court 

Incurred (Month/Year) $ judgment or settlement, provide court name 

I 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 I Account No. 

Date Established Type of Plan Surrender Value before 

I I Taxes and Penalties 

(mm/dd/yyyy) $ 

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

Date Established Type of Plan Surrender Value before 

I I Taxes and Penalties 

$ 

Initials: 

5 of 10 Federal Trade Commission Financial Statement of Individual Defendant 

Attachment A 

Case 1:18-cv-03309-PJM Document 1194 Filed 03/24/21 Page 30 of 35 
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) 

$ I I 

$ I I 

$ I I 

Item 16. Vehicles 

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

Vehicle Type I Year Registered Owner's Name Purchase Price Original Loan Amount Current Balance 

$ $ s 

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

$ $ 

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

Vehicle Type I Year Registered Owner's Name Purchase Price Original Loan Amount Current Balance 

$ $ $ 

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

s s 

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

Vehicle Type I Year Registered Owner's Name Purchase Price Original Loan Amount Current Balance 

s s $ 

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

$ s 

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

Vehicle Type I Year Registered Owner's Name Purchase Price Original Loan Amount Current Balance 

s s s 

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

$ s 

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 Name of Owner Property Location Acquisition Cost Current Value 

(e.g., artwork, jewelry) 

s $ 

$ s 

$ s 

Initials: 

6 of 10 Federal Trade Commission Financial Statement of Individual Defendant 

Attachment A 

Case 1:18-cv-03309-PJM Document 1194 Filed 03/24/21 Page 31 of 35 
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) I ;urchase Price I ~urrent Value Basis of Valuation 

I I 

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 0 Rental Unit 

$ 

Current Balance Monthly Rent Received 

$ $ 

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

Acquisition Date (mm/dd/yyyy) I ;urchase Price I ~urrent Value Basis of Valuation 

I I 

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 D Rental Unit 

$ 

Current Balance Monthly Rent Received 

$ $ 

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

$ 

$ 

$ 

$ 

$ 

Item 20. Taxes Payable 

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

Type ofTax Amount Owed Year Incurred 

$ 

$ 

$ 

Initials: 

7 of 10 Federal Trade Commission Financial Statement of Individual Defendant 

Attachment A 

Case 1:18-cv-03309-PJM Document 1194 Filed 03/24/21 Page 32 of 35 
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 Original Amount Owed Current Amount Owed Payment Schedule I I 

/mm/dd/wvv) $ $ 

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 Original Amount Owed Current Amount Owed Payment Schedule 

I I 

(mm/dd/vwv\ $ $ 

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 Grantor Beneficiaries Present Market Value of Assets• 

(mm/dd/wvvl 

I I $ 

I I $ 

I I $ 

' If the market value of any asset is unknown, descr be the asset and state its cost, if you know it. 

Item 23. Transfers of Assets 

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

loan, gift, sale, or other transfer (exclude ordinary and necessary fiving 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 Type of Transfer 

(mm/dd/yyyy) (e.g., Loan, Gift) 

$ I I 

$ I I 

$ I I 

*If the market value of any asset is unknown, descr be the asset and state its cost, if you know ii. 

Initials: 

8 of 10 Federal Trade Commission Financial Statement of Individual Defendant 

Attachment A 

Case 1:18-cv-03309-PJM Document 1194 Filed 03/24/21 Page 33 of 35 
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 list~d in Item 9, all account statements for the past 3 years. 

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

Item 11 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. 

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

Item 17 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 Liablllties 

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 , Mortgage or Rental Payments for Residence(s) $ $ 

Source: 

Fees, Commissions, and Royalties $ Property Taxes for Residence(s) $ 

Source: 

Interest $ 

Rental Property Expenses, Including Mortgage Payments, Taxes, $ 

Source: and Insurance 

Dividends and Capital Gains Car or Other Vehicle Lease or Loan Payments $ 

Source: 

$ 

Gross Rental Income $ 

Food Expenses $ 

Source: 

Profits from Sole Proprietorships $ 

Clothing Expenses $ 

Source: 

Distr butions from Partnerships, S-Corporations, Utilities 

and LLCs $ $ 

Source: 

Initials: 

9 of 10 Federal Trade Commission Financial Statement of Individual Defendant 

Attachment A 

Case 1:18-cv-03309-PJM Document 1194 Filed 03/24/21 Page 34 of 35 
Item 26. Combined Current Monthly Income and Expenses for You, Your Spouse, and Your Dependents (cont.) 

Distr butions from Trusts and Estates Medical Expenses, Including Insurance 

Source: $ $ 

Distr butions from Deferred Income Arrangements $ 

Other Insurance Premiums 

Source: $ 

Social Security Payments ' $ Other Transportation Expenses $ 

Alimony/Child Support Received $ Other Expenses (Itemize) 

Gambling Income $ $ 

Other Income (Itemize) $ 

$ $ 

$ $ 

$ $ 

Total Income $ Total Expenses $ 

ATTACHMENTS 

Item 27. Documents Attached to this Financial Statement 

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

Item No. Document Relates To Description of Document 

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

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

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

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

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

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

Executed on: 

(Date) Signature 

10 of 10 Federal Trade Commission Financial Statement of Individual Defendant 

Attachment A 

Case 1:18-cv-03309-PJM Document 1194 Filed 03/24/21 Page 35 of 35