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IN THE UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

UNITED STATES OF AMERICA,

Plaintiff,

v.

EASY HEALTHCARE CORPORATION, a corporation, 

d/b/a EASY HEALTHCARE,

Case No. 1:23-cv-3107

Defendant.

MOTION FOR ENTRY OF STIPULATED ORDER 

FOR PERMANENT INJUNCTION, CIVIL PENALTY JUDGMENT, AND OTHER 

RELIEF

Plaintiff, the United States of America (“Plaintiff”) herby files its “Motion for Entry of 

Stipulated Order for Permanent Injunction, Civil Penalty Judgment, and Other Relief”

(“Order”) reached through settlement negotiations between the parties, which would resolve this 

case. In support of this motion, Plaintiff states as follows:

1. Plaintiff filed its Complaint for Permanent Injunction, Civil Penalty Judgment, 

and Other Relief on May 15, 2023, alleging that Defendant violated Section 5(a) of the FTC Act, 

15 U.S.C. § 45(a), and the HBNR, 16 C.F.R. § 318. [Dkt. 1].

2. All parties are represented by counsel. 

3. The Order has been signed by Defendant and their counsel. The Order also has 

been approved by the Federal Trade Commission and the Department of Justice and signed by 

the filing counsel. The fully executed Order provides that “Plaintiff and Defendant stipulate to 

Case: 1:23-cv-03107 Document #: 3 Filed: 05/17/23 Page 1 of 3 PageID #:32
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the entry of this Stipulated Order for Permanent Injunction, Civil Penalty Judgment, and Other 

Relief (“Order”) to resolve all matters in dispute in this action between them.” Dkt. at 1. 

WHEREFORE, Plaintiff respectfully request that the Court enter the Order. 

 Respectfully submitted,

 

Dated: May 17, 2023 

/s/ Rachel E. Baron 

RACHEL E. BARON 

Trial Attorney

Consumer Protection Branch 

450 5th Street NW

Washington, D.C. 20530 

(202) 598-7719 

 

Attorney for Plaintiff 

UNITED STATES OF AMERICA 

OF COUNSEL: 

FOR THE FEDERAL TRADE COMMISSION

TIFFANY GEORGE

Acting Assistant Director

Division of Privacy and Identity Protection 

DAVID WALKO

RONNIE SOLOMON

Attorneys 

Division of Privacy and Identity Protection 

Federal Trade Commission

600 Pennsylvania Avenue NW 

Mail Stop CC-8232 

Washington, DC 20580 

(202) 326-2880 

(202) 326-2098 

dwalko@ftc.gov

rsolomon@ftc.gov 

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CERTIFICATE OF SERVICE

I, Rachel Baron, an attorney, hereby certify that on May 17, 2023, I caused to be served 

true copies of the foregoing Motion for Entry of Stipulated Order for Permanent Injunction and 

Monetary Order through the CM/ECF System by e-mail and U.S. Mail on the following counsel 

for Defendant Easy Healthcare Corporation: 

Brenda R. Sharton 

Dechert LLP

One International Place, 40th Floor 

Boston, MA 02110 

Brenda.Sharton@dechert.com 

Benjamin M. Sadun 

Dechert LLP

633 West 5th Street, Suite 4900 

Los Angeles, CA 90071 

Benjamin.Sadun@dechert.com 

Hilary Bonaccorsi

Dechert LLP

300 South Tryon Street, Suite 800 

Charlotte, NC 28202 

Hilary.Bonaccorsi@dechert.com

/s/ Rachel E. Baron

 RACHEL E. BARON 

Trial Attorney

 Consumer Protection Branch 

 450 5th Street NW

 Washington, D.C. 20530 

 (202) 598-7719 

Attorney for Plaintiff

 

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