UNITED STATES DISTRICT COURT 

FOR THE EASTERN DISTRICT OF NEW YORK 

FEDERAL TRADE COMMISSION, 

Case No. CV-10-3551 (ILG)(RLM) Plaintiff, 

STIPULATED ORDER FOR 

V. PERMANENT INJUNCTION AND 

MONETARY JUDGMENT AS TO CONSUMER HEAL TH BENEFITS THE GTL DEFENDANTS ASSOCIATION, organized as a Missouri 

not-for-profit, also doing business as CHBA, 

NATIONAL ASSOCIATION FOR AMERICANS, 

organized as a Missouri not-for-profit, also doing 

business as NAFA, 

NATIONAL BENEFITS CONSULTANTS, LLC, a 

Florida limited liability company, also doing 

business as NBC, 

NATIONAL BENEFITS SOLUTIONS, LLC, a 

Florida limited liability company, also doing 

business as NBS, 

LOUIS LEO, individually, as a Managing Member 

ofNATIONAL BENEFITS CONSULTANTS, 

LCC, as a Managing Member of NATIONAL 

BENEFITS SOLUTIONS, LLC, and as the Vice 

President and Treasurer of CONSUMER HEAL TH 

BENEFITS ASSOCIATION, 

RON WERNER, individually, as a Managing 

Member of NATIONAL BENEFITS 

CONSULT ANTS, LLC, as a Managing Member of 

NATIONAL BENEFITS SOLUTIONS, LLC, and 

as President and Managing Partner of CONSUMER 

HEAL TH BENEFITS ASSOCIATION, 

RITA WERNER, individually, and as Senior Vice 

President and Director of Operations of 

CONSUMER HEAL TH BENEFITS 

ASSOCIATION, 

WENDI TOW, individually, as a Managing 

Member of NATIONAL BENEFITS 

Case 1:10-cv-03551-ILG-RLM Document 497 Filed 12/09/21 Page 1 of 18 PageID #: 29989 
CONSULT ANTS, LLC, and as a Managing 

Member of NATIONAL BENEFITS SOLUTIONS, 

LLC, 

JOHN SCHWARTZ, individually, as a Managing 

Member of NATIONAL BENEFITS 

CONSULT ANTS, LLC, and as a Managing 

Member of NATIONAL BENEFITS SOLUTIONS, 

LLC, 

GUARANTEE TRUST LIFE INSURANCE 

COMPANY, an Illinois corporation, 

VANTAGE AMERICA SOLUTIONS, INC., an 

Illinois corporation, 

CENTURY SENIOR SERVICES, a Florida 

corporation, 

JEFFREY BURMAN, individually, as President of 

VANTAGE AMERICA SOLUTIONS, INC., and as 

Vice President of GUARANTEE TRUST LIFE 

INSURANCE COMPANY, 

BARBARA TAUBE, individually, and as Vice 

President of GUARANTEE TRUST LIFE 

INSURANCE COMPANY, and 

RICHARD HOLSON, III, individually, and as 

President of GUARANTEE TRUST LIFE 

INSURANCE COMPANY, 

Defendants. 

Plaintiff, the Federal Trade Commission ("Commission" or "FTC"), filed its Complaint 

for Permanent Injunction and Other Relief, subsequently amended as First Amended Complaint 

for Permanent Injunction and Other Relief ("First Amended Complaint''), pursuant to Sections 

13(b) and 19 of the Federal Trade Commission Act ("FTC Act"), lSU.S.C. §§53(b) and 57b. 

The Commission and Defendants Guarantee Trust Life Insurance Company, Vantage America 

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Solutions, Inc., Century Senior Services, Jeffrey Burman, Barbara Taube, and Richard Holson, III 

(collectively, the "GTL Defendants") stipulate to the entry of this Stipulated Order for Permanent 

Injunction and Monetary Judgment as to the GTL Defendants ("Order") to resolve all matters in 

dispute in this action between them. 

THEREFORE, IT IS ORDERED as follows: 

FINDINGS 

I. This Court has jurisdiction over this matter. 

2. The First Amended Complaint charges that the GTL Defendants participated in deceptive 

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

Telemarketing Sales Rule ("TSR"), 16 C.F .R. Part 310, in connection with the marketing and sale 

of discount medical plans. 

3. The GTL Defendants neither admit nor deny any of the allegations in the First Amended 

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

Defendants admit the facts necessary to establish jurisdiction. 

4. The GTL Defendants waive any claim that they may have under the Equal Access to 

Justice Act, 28 U.S.C. § 2412, concerning the prosecution of this action through the date of this 

Order, and agree to bear their own costs and attorney fees. 

5. The GTL Defendants waive all rights to appeal or otherwise challenge or contest the 

validity of this Order. 

DEFINITIONS 

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

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A. "Clear(ly) and Conspicuous(ly)" means that a required disclosure is difficult to miss 

(i.e., easily noticeable) and easily understandable by ordinary consumers, including in all of the 

following ways: 

1. In any communication that is solely visual or solely audible, the disclosure must be 

made through the same means through which the communication is presented. In any 

communication made through both visual and audible means, such as a television 

advertisement, the disclosure must be presented simultaneously in both the visual and 

audible portions of the communication even if the representation requiring the disclosure 

is made in only one means. 

2. A visual disclosure, by its size, contrast, location, the length of time it appears, and 

other characteristics, must stand out from any accompanying text or other visual elements 

so that it is easily noticed, read, and understood. 

3. An audible disclosure, including by telephone or streaming video, must be 

delivered in a volume, speed, and cadence sufficient for ordinary consumers to easily hear 

and understand it. 

4. In any communication using an interactive electronic medium, such as the Internet 

or software, the disclosure must be unavoidable. 

5. The disclosure must use diction and syntax understandable to ordinary consumers 

and must appear in each language in which the representation that requires the disclosure 

appears. 

6. The disclosure must comply with these requirements in each medium through 

which it is received, including all electronic devices and face-to-face communications. 

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7. The disclosure must not be contradicted or mitigated by, or inconsistent with, 

anything else in the communication. 

8. When the representation or sales practice targets a specific audience, such as 

children, the elderly, or the terminally ill, "ordinary consumers" includes reasonable 

members of that group. 

B. "Defendants" means Consumer Health Benefits Association; National Association for 

Americans; National Benefits Consultants, LLC; National Benefits Solutions, LLC; Guarantee 

Trust Life Insurance Company; Vantage America Solutions, Inc.; Century Senior Services; their 

successors and assigns; Louis Leo; Ron Werner; Rita Werner; Wendi Tow; John Schwartz; 

Jeffrey Burman; Barbara Taube; and Richard Holson, III, individually, collectively, or in any 

combination. 

C. "Escrow Agent" means Steven E. Ostrow, the Court-appointed successor escrow agent in 

this case. 

D. "GTL Corporate Defendants" means Guarantee Trust Life Insurance Company, Vantage 

America Solutions, Inc., Century Senior Services, and their successors and assigns. 

E. "GTL Defendants" means all of the GTL Individual Defendants and all of the GTL 

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

F. "GTL Individual Defendants" means Jeffrey Burman, Barbara Taube, and Richard 

Holson, III. 

G. "Discount Medical Plan(s)" means a business arrangement or contract in which a person, 

in exchange for fees, dues, charges or other consideration, offers access for its members to 

providers of medical or ancillary services and the right to receive discounts on medical or 

ancillary services provided under the discount medical plan from those providers. 

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H. "Insurance" means any good or service that (a) has the effect of transferring or spreading 

risk; (b) is an integral part of the policy relationship between the insurer and the insured; and 

( c) is limited to entities within the insurance industry. 

I. "Seller" means any person who, in connection with a Telemarketing transaction, provides, 

offers to provide, or arranges for others to provide goods or services to the customer in exchange 

for consideration, whether or not such person is under the jurisdiction of the Commission. 

J. "Telemarketer" means any person who, in connection with Telemarketing, initiates or 

receives telephone calls to or from a customer or donor, whether or not such person is under the 

jurisdiction of the Commission. 

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

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

and which involves more than one interstate telephone call. 

ORDER 

I. BAN ON SELLING DISCOUNT MEDICAL PLANS 

IT IS ORDERED that the GTL Defendants are permanently restrained and enjoined from 

advertising, marketing, promoting, offering for sale, or selling, or assisting in the advertising, 

marketing, promoting, offering for sale, or selling, of any Discount Medical Plan. 

II. PROHIBITION AGAINST VIOLATING THE TSR 

With respect to activities that do not constitute the business of Insurance regulated by state 

law, IT IS FURTHER ORDERED that the GTL Defendants, their officers, agents, and employees 

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

notice of this Order, whether acting directly or indirectly, are pennanently restrained and enjoined 

from violating any provision of the Telemarketing Sales Rule, 16 C.F .R. Part 310, attached as 

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Attachment A, including: 

A. Section 310.3(a)(l )(iii) of the TSR, 16 C.F .R. § 310.3(a)(l)(iii), by failing to disclose 

truthfully, in a Clear and Conspicuous manner, before a customer consents to pay for goods or 

services offered in connection with Telemarketing: (1) if the Seller has a policy of not making 

refunds, cancellations, exchanges, or repurchases, a statement informing the customer that this is 

the Seller's policy; or (2) if the Seller or Telemarketer makes a representation about a refund, 

cancellation, exchange, or repurchase policy, a statement of all material terms and conditions of 

such policy; 

B. Section 310.3(a)(2) of the TSR, 16 C.F.R. § 310.3(a)(2), by misrepresenting, directly or by 

implication, in the sale of goods or services any of the following material information: ( 1) the 

total costs to purchase, receive, or use, and the quantity of, any goods or services that are the 

subject of a sales offer; (2) any material restriction, limitation, or condition to purchase, receive, 

or use goods or services that are the subject of a sales offer; (3) any material aspect of the 

performance, efficacy, nature, or central characteristics of goods or services that are the subject of 

a sales offer; or ( 4) any material aspect of the nature or terms of the Seller's refund, cancellation, 

exchange or repurchase policies; and 

C. Section 310.4(d) of the TSR, 16 C.F.R. § 310.4(d), by failing to disclose truthfully, 

promptly, and in a Clear and Conspicuous manner to the person receiving a call in connection 

with Telemarketing: (1) the identity of the Seller; (2) that the purpose of the call is to sell goods 

or services; or (3) the nature of the goods or services. 

III. MONETARY JUDGMENT 

IT IS FURTHER ORDERED that: 

A. Judgment in the amount of Five Million Seven Hundred Fifty Thousand Dollars 

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($5,750,000) is entered in favor of the Commission against the GTL Defendants as monetary 

relief. 

B. The GTL Defendants are ordered to pay to the Commission Five Million Seven Hundred 

Fifty Thousand Dollars ($5,750,000), which, as the GTL Defendants stipulate, their undersigned 

counsel holds in escrow for no purpose other than payment to the Commission. Such payment 

must be made within 7 days of entry of this Order by electronic fund transfer in accordance with 

instructions previously provided by a representative of the Commission. 

C. The GTL Defendants relinquish dominion and all legal and equitable right, title, and 

interest in all assets transferred pursuant to this Order and may not seek the return of any assets. 

D. The facts alleged in the First Amended Complaint establish all elements necessary to 

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

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

E. The GTL Defendants acknowledge that their Taxpayer Identification Number (Social 

Security Number or Employer Identification Numbers) may be used for collecting and reporting 

on any delinquent amount arising out of this Order, in accordance with 31 U.S.C. §770L 

F. All money paid to the Commission pursuant to this Order may be deposited into a fund 

administered by the Commission or its designee to be used for consumer redress and any 

attendant expenses for the administration of any redress fund. If a representative of the 

Commission decides that direct redress to consumers is wholly or partially impracticable or 

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

such other relief (including consumer information remedies) as it determines to be reasonably 

related to Defendants' practices alleged in the First Amended Complaint. Any money not used 

for such relief is to be deposited to the U.S. Treasury. The GTL Defendants have no right to 

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

If the GTL Defendants fail to pay fully the amount due at the time specified, the GTL Defendants 

must cooperate fully with the Commission and their representatives in all attempts to collect the 

judgment. In such an event, the GTL Defendants agree to provide federal and state tax returns 

for the preceding 2 years, and to complete a financial disclosure form fully and accurately within 

IO business days of receiving a request from the Commission. The GTL Defendants further 

authorize the Commission to verify all information provided on any financial disclosure form 

with all appropriate third parties, including financial institutions. 

IV. CUSTOMER INFORMATION 

IT IS FURTHER ORDERED that the GTL Defendants, their officers, agents, and 

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

actual notice of this Order, whether acting directly or indirectly, are permanently restrained and 

enjoined from directly or indirectly: 

A. failing to provide sufficient customer information in their possession, to enable the 

Commission to efficiently administer consumer redress. The GTL Defendants represent that they 

have provided this redress information to the Commission. If a representative of the 

Commission requests in writing any information related to redress, the GTL Defendants must 

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

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

telephone number, email address, social security number, other identifying information, sensitive 

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

card, bank account, or other financial account), that any Defendant obtained prior to entry of this 

Order in connection with the sale of any Discount Medical Plan proffered, marketed, advertised, 

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or sold by or through Consumer Health Benefits Association, National Association for 

Americans, National Benefits Consultants, LLC, and/or National Benefits Solutions, LLC; and 

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

control within 30 days after receipt of written direction to do so from a representative of the 

Commission. 

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

the extent requested by a government agency or required by law, regulation, or court order. 

V. COOPERATION 

IT IS FURTHER ORDERED that the GTL Defendants must fully cooperate with 

representatives of the Commission in this case and in any investigation related to or associated 

with the transactions or the occurrences that are the subject of the First Amended Complaint. 

The GTL Defendants must provide truthful and complete information, evidence, and testimony. 

The GTL Defendants must appear for interviews, discovery, hearings, trials, and any other 

proceedings that a Commission representative may reasonably request upon 7 days written notice, 

or other reasonable notice, at such places and times as a Commission representative may 

designate, without the service of a subpoena. 

VI. ORDER ACKNOWLEDGMENTS 

IT IS FURTHER ORDERED that the GTL Defendants obtain acknowledgments of receipt 

of this Order: 

A. Each GTL Defendant, within 7 days of entry of this Order, must submit to the 

Commission an acknowledgment of receipt of this Order sworn under penalty of perjury. 

B. For 3 years after entry of this Order, (I) each Individual GTL Defendant who is, 

individually or collectively with any other Defendants, the majority owner or controls directly or 

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indirectly a company that engages in activity covered by this Order and (2) each Corporate GTL 

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

managers and members of such companies; (b) all employees, agents, and representatives with 

managerial responsibilities related to the subject matter of this Order and all agents and 

representatives who participate in conduct related to the subject matter of this Order; and (c) any 

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

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

all others, delivery must occur before they assume their responsibilities. 

C. From each individual or entity to which a GTL Defendant delivered a copy of this Order, 

that GTL Defendant must obtain, within 30 days, a signed and dated acknowledgment of receipt 

of this Order. 

VII. COMPLIANCE REPORTING 

IT IS FURTHER ORDERED that the GTL Defendants make timely submissions to the 

Commission: 

A. One year after entry of this Order, each GTL Defendant must submit a compliance report, 

sworn under penalty of perjury: 

l. Each GTL Defendant must: (a) identify the primary physical, postal, and email address 

and telephone number, as designated points of contact, which representatives of the Commission 

may use to communicate with such GTL Defendant; (b) identify all of that GTL Defendant's 

businesses by all of their names, telephone numbers, and physical, postal, email, and Internet 

addresses; ( c) describe the activities of each business, including the goods and services offered, 

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

(which Individual GTL Defendants must describe if they know or should know due to their own 

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involvement); (d) describe in detail whether and how that GTL Defendant is in compliance with 

each Section of this Order; and ( e) provide a copy of each Order Acknowledgment obtained 

pursuant to this Order, unless previously submitted to the Commission. 

2. Additionally, each Individual GTL Defendant must: (a) identify all telephone numbers 

and all physical, postal, email and Internet addresses, including all residences; (b) identify all 

business activities, including any business for which such Individual GTL Defendant performs 

services whether as an employee or otherwise and any such entity in which such Individual GTL 

Defendant has any ownership interest of which Defendants have direct or indirect control; and ( c) 

describe in detail such Individual GTL Defendant's involvement in each such business, including 

title, role, responsibilities, participation, authority, control, and any ownership. 

B. For 5 years after entry of this Order, each GTL Defendant must submit a compliance 

notice, sworn under penalty of perjury, within 14 days of any change in the following: 

I. Each GTL Defendant must report any change in: (a) any designated point of contact; or 

(b) the structure of any Corporate GTL Defendant or any entity that GTL Defendant has any 

ownership interest in or controls directly or indirectly that may affect compliance obligations 

arising under this Order, including: creation, merger, sale, or dissolution of the entity or any 

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

2. Additionally, each Individual GTL Defendant must report any change in: (a) name, 

including aliases or fictitious name, or residence address; or (b) title or role in any business 

activity, including any business for which such GTL Defendant performs services whether as an 

employee or otherwise and any entity in which such GTL Defendant has any ownership interest, 

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

C. Each GTL Defendant must submit to the Commission notice of the filing of any 

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

Defendant within 14 days of its filing. 

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

perjury must be true and accurate and comply with 28 U.S.C. § 1746, such as by concluding: "I 

declare under penalty of perjury under the laws of the United States of America that the foregoing 

is true and correct. Executed on: __ " and supplying the date, signatory's full name, title (if 

applicable), and signature. 

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

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

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

Consumer Protection, Federal Trade Commission, 600 Pennsylvania Avenue NW, Washington, 

DC 20580. The subject line must begin: FTC v. GTL, XI00042. 

VIII. RECORDKEEPING 

IT IS FURTHER ORDERED that the GTL Defendants must create certain records for 5 

years after entry of the Order, and retain each such record for 5 years. Specifically, each GTL 

Defendant for any business that they, individually or collectively with any other Defendants, is a 

majority owner or controls directly or indirectly, must create and retain the following records: 

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

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

otherwise, that person's: name; addresses; telephone numbers; job title or position; dates of 

service; and (if applicable) the reason for termination; 

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

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

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

including all submissions to the Commission; and 

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

IX. COMPLIANCE MONITORING 

IT IS FURTHER ORDERED that, for the purpose of monitoring the GTL Defendants' 

compliance with this Order, including any failure to transfer any assets as required by this Order: 

A. Within 30 days of receipt of a written request from a representative of the Commission, 

each GTL Defendant must: submit additional compliance reports or other requested information, 

which must be sworn under penalty of perjury; appear for depositions; and produce documents for 

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

leave of court, using any of the procedures prescribed by Federal Rules of Civil Procedure 29, :J(j 

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

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

with each GTL Defendant. The GTL Defendants must permit representatives of the Commission 

to interview any employee or other person affiliated with any GTL Defendant who has agreed to 

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

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

representatives as consumers, suppliers, or other individuals or entities, to the GTL Defendants or 

any individual or entity affiliated with the GTL Defendants, without the necessity of identification 

or prior notice. Nothing in this Order limits the Commission's lawful use of compulsory process, 

pursuant to Sections 9 and 20 of the FTC Act, 15 U.S.C. §§ 49, 57b~L 

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

agency must furnish consumer reports concerning the GTL Individual Defendants, pursuant to 

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• Section 604(1) of the Fait- Credit Reporting Act, 15 U.S.C. §168lb(a)(l). 

X. RETENTION OF JURISDICTION • 

... . 

IT IS FURTHER ORDERED that this Court 1·etainsjw·isdiction of this matter for pw-poses 

of construction, modification, and enforcement of this Order. 

SO ORDERED tllis _ 

8th

day of __________ 

 December

, 2021. 

/s/ I. Leo Glasser

I. LEO GLASSER 

UNITED STATES DISTRICT JUDGE 

SO STIPULATED AND AGREED: 

FOR PLAINTIFF: 

FEDERAL TRADE COMMISSION 

Isl Karen Dahlberg O'Connell 

Karen Dahlberg O'Connell, Attorney 

Federal Trade Commission 

Northeast Region 

1 Bowling Green, Suite 318 

New York, NY 10004 

212-607-2821 

212-607-2822 (fax) 

koconne1l@ftc.gov 

.FOR THE GTL DEFENDANTS: 

Date: Ii)/(/ f 

2-f 

Dawn M. Canty 

Gil M. Soffer 

Katten Muchin Rosenman LLP 

525 W. Monroe Street 

Chicago, IL 60661-3693 

dawn.canty@katten.com 

gil.soffer@katten.com 

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Case 1:10-cv-03551-ILG-RLM Document 497 Filed 12/09/21 Page 16 of 18 PagelD #: 30004 

10/ 07/ 2021 11 : 03 4 PAGE 01 

Date: ~/ 

OF GUARANTEE TRUST LIFE INSURANCE 

SOLUTIONS, INC. 

Date: 

OF GUARANTEE TRUST LIFE INSURANCE 

Date: 

F GUARANTEE TRUST LIFE INSURANCE 

ge 16 of 16 

THE GTL DEFENDANTS: 

AN 

UALL Y AND AS AN OFFICE 

COMPANY AND VANTAGE AMERIC 

BARBARA TAUBE 

INDIVIDUALLY AND AS AN OFFICE 

COMPANY 

RICHARD HOLSON, Ill 

lNDIVIDUALL Y AND AS AN OFFICE 

COMPANY 
Case 1:10-cv-03551-ILG-RLM Document 497 Filed 12/09/21 Page 17 of 18 PagelD #: 30005 

THE GTL DEFENDANTS: 

Date: 

JEFFREY BURMAN 

INDlVIDUALLY AND AS AN OFFICER OF GUARANTEE TRUST LIFE INSURANCE 

COMPANY AND VANTAGE AMERJCA SOLUTIONS, INC. 

Date: 10( "11.)...t 

BARBARA TAUBE 

INDIVIDUALLY AND AS AN OFFICER OF GUARANTEE TRUST LIFE INSURANCE 

COMPANY 

Date: 

RICHARD HOLSON, III 

INDIVIDUALLY AND AS AN OFFICER OF GUARANTEE TRUST LIFE INSURANCE 

COMPANY 

Page 16 of 16 
Case 1:10-cv-03551-ILG-RLM Document 497 Filed 12/09/21 Page 18 of 18 PagelD #: 30006 -

THE GTL DEFENDANTS: 

Date: 

JEFFREY BURMAN 

INDIVIDUALLY AND AS AN OFFICER OF GUARANTEE TRUST LIFE INSURANCE 

COI\1PANY AND VANTAGE AMERICA SOLUTIONS, INC. 

Date: 

BARBARA TAUBE 

INDIVIDUALLY AND AS AN OFFICER OF GUARANTEE TRUST LIFE INSURANCE 

COMPANY 

~Q~ Date: \ 0 •Co, '2 l

RIC~SON,III 

INDIVIDUALLY AND AS AN OFFICER OF GUARANTEE TRUST LIFE INSURANCE 

COI\1PANY 

Page 16 of 16