Suppressed 

Plaintiff(s), 

v. 

Suppressed, 

Defendant( s ). 

IN THE UNITED STATES DISTRICT COURT 

FOR THE 

NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

Case No. 17C 194 

Judge Sharon Johnson Coleman 

ORDER 

Motion Hearing held. Plaintiff's ex parte motion for TRO is granted. Enter TRO. Plaintiffs 

motion for leave to file Memorandum in Support of Its Ex Parte Motion For a Temporary 

Restraining Order with Asset Freeze, Appointment of a Receiver, Other Equitable Relief; and 

Order to Show Cause Why a Preliminary Injunction Should Not Issue, in excess of fifteen (15) 

pages is granted. Plaintiff's motion for leave to file under seal is granted. The docket sheet and 

all pleadings and papers filed in this matter shall be sealed. The seal shall lift automatically 

without further order of the Court at 5:00 p.m., Central Time, on Tuesday, January 17, 2017. 

Rule to show cause hearing set before Judge Kennelly on January 25, 2017 at 9:30 a.m. 

Date: 1111/2017 Isl Sharon Johnson Coleman 

Sharon Johnson Coleman 

United States District Court Judge 
UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

FEDERAL TRADE COMMISSION, 

Plaintiff, 

v. 

CREDIT BUREAU CENTER, LLC, 

a limited liability company, formerly known as 

MYSCORE LLC, also doing business as 

EFREESCORE.COM, CREDITUPDATES.COM, 

and FREECREDITNA TION.COM, 

MICHAEL BROWN. 

individually and as owner and manager of 

CREDIT BUREAU CENTER, LLC, 

DANNY PIERCE, individually, and 

ANDREW LLOYD, individually, 

Defendants. 

) 

) 

) 

) Case No. 17-cv-194 

) 

) Judge Kennelly 

) 

) Magistrate Judge Valdez 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

EX PARTE TEMPORARY RESTRANING ORDER WITH ASSET FREEZE, 

APPOINTMENT OF A RECEIVER, OTHER EQUITABLE RELIEF, AND ORDER 

TO SHOW CAUSE WHY A PRELIMINARY INJUNCTION SHOULD NOT ISSUE 

Plaintiff, the Federal Trade Commission ("FTC" or the "Commission"), has filed a 

Complaint for Permanent Injunction and Other Equitable Relief pursuant to Section 13(b) of the 

Federal Trade Commission Act ("FTC Act"), 15 U.S.C. § 53(b), Section 5 of the Restore Online 

Shoppers' Confidence Act ("ROSCA"), 15 U.S.C. § 8404, and Section 62\(a)(l) of the Fair 

Credit Reporting Act ("FCRA"), 15 U.S.C. § 168\s(a)(l), and has moved, pursuant to Federal 

Rule of Civil Procedure 65(b ), for a Temporary Restraining Order with Asset Freeze, 

Appointment of a Receiver, Other Equitable Relief, and an Order to Show Cause Why a 
Preliminary Injunction Should Not Issue against Defendants Credit Bureau Center, LLC, 

Michael Brown, Danny Pierce, and Andrew Lloyd. 

FINDINGS OF FACT 

The Court, having considered the Complaint, the ex parte motion for a temporary 

restraining order, the declarations, exhibits, and memorandum of law filed in support thereof, 

and being otherwise advised, finds that: 

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

cause to believe that it will have jurisdiction over the parties; 

2. Venue in this district is proper; 

3. There is good cause to believe that Defendants Credit Bureau Center, LLC, 

Michael Brown, Danny Pierce, and Andrew Lloyd have engaged in and are likely to engage in 

acts or practices that violate Section 5(a) of the FTC Act, 15 U.S.C. § 45(a), and that Defendants 

Credit Bureau Center, LLC, and Michael Brown have engaged in and are likely to engage in acts 

or practices that violate Section 4(1) and (2) of ROSCA, 15 U.S.C. § 8403(1) & (2), Section 

612(g) of the FCRA, 15 U.S.C. § 168Ij(g), and the Free Annual File Disclosures Rule ("Free 

Reports Rule"), 12 C.F.R. §§ 1022.130-1022.138, and that the FTC is therefore likely to prevail 

on the merits of this action; 

4. There is good cause to believe that immediate and irreparable harm will result 

from the Defendants' ongoing violations of Section 5(a) of the FTC Act, 15 U.S.C. § 45(a), 

Section 4(1) and (2) of ROSCA, 15 U.S.C. § 8403(1) & (2), Section 612(g) of the FCRA, 15 

U.S.C. § 168lj(g), and the Free Reports Rule, 12 C.F.R. §§ 1022.130-1022.138, unless 

Defendants are restrained and enjoined by Order of this Court; 

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

Court's ability to grant effective final relief for consumers, including monetary restitution, 

rescission, disgorgement, or refunds, will occur from the sale, transfer, or other disposition or 

concealment by Defendants of their assets or records if Defendants are provided with advance 

notice of this Order, and that therefore in accordance with Federal Rule of Civil Procedure 65(b), 

the interests of justice require that this Order be granted without prior notice to Defendants. 

There is thus good cause for relieving the FTC of the duty to provide Defendants with prior 

notice of the FTC' s motion; 

6. There is good cause for issuing this Order pursuant to Federal Rule of Civil 

Procedure 65(b ); 

7. Weighing the equities and considering the FTC's likelihood of ultimate success 

on the merits, a temporary restraining order with an asset freeze, appointment of a receiver, other 

equitable relief, and order to show cause why a preliminary injunction should not issue is in the 

public interest; and 

8. The FTC is an independent agency of the United States of America and no 

security is required of any agency of the United States for the issuance of a temporary restraining 

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

DEFINITIONS 

For purposes of this Temporary Restraining Order ("Order"), the following definitions 

shall apply: 

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

any real or personal property, including, but not limited to, "goods," "instruments," "equipment," 

"fixtures," "general intangibles," "inventory," "checks," or "notes," (as these terms are defined 

Page 3 of 32 
in the Uniform Commercial Code), lines of credit, chattels, leaseholds, contracts, mail or other 

deliveries, shares of stock, lists of consumer names, accounts, credits, premises, receivables, 

funds, and all cash, wherever located. 

2. "Assisting Others" includes, but is not limited to: (I) providing administrative 

services, including, but not limited to, filing business registrations with federal, state, or local 

government entities; (2) acting as an officer, director, or registered agent of a business entity; 

(3) establishing bank and/or merchant accounts; (4) handling banking transactions; 

(5) establishing mail accounts and/or mail receiving boxes; (6) forwarding mail received from 

consumers; (7) performing customer service functions, including, but not limited to, receiving or 

responding to consumer complaints; (8) formulating or providing, or arranging for the 

formulation or provision of, any sales script or other marketing material; (9) providing names of, 

or assisting in the generation of, potential customers; or (11) performing or providing marketing 

or billing services of any kind. 

3. "Commission" or "FTC" means the Federal Trade Commission. 

4. "Corporate Defendant" means Credit Bureau Center, LLC, a Delaware limited 

liability company, formerly known as MyScore LLC, and also doing business as 

eFreeScore.com, CreditU pdates.com, and FreeCreditNation.com, and its successors and assigns, 

as well as any subsidiaries, and any fictitious business entities or business names created or used 

by these entities, or any of them. 

5. "Credit Monitoring Service" means any service, plan, program or membership 

that includes, or is represented to include, alerts or monitoring of changes to consumers' credit 

files, credit reports, or credit scores. 

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6. "Defendant(s)" means all of the Individual Defendants and the Corporate 

Defendant, individually, collectively, or in any combination. 

7. "Document(s)" is equal in scope and synonymous in meaning to the usage of the 

term in Federal Rule of Civil Procedure 34(a), and includes writings, drawings, graphs, charts, 

photographs, audio and video recordings, computer records, and any other data compilations 

from which information can be obtained and translated, if necessary, through detection devices 

into reasonably usable form. A draft or non-identical copy is a separate document within the 

meaning of the term. 

8. "Financial Institution" means any bank, savings and loan institution, credit 

union, or any financial depository of any kind, including, but not limited to, any brokerage 

house, trustee, broker-dealer, escrow agent, title company, commodity trading company, or 

precious metal dealer. 

9. "Individual Defendants" means Michael Brown, Dam1y Pierce, and Andrew 

Lloyd, and by whatever other names each may be known. 

I 0. "Negative Option Feature" means, in an offer or agreement to sell or provide 

any goods or services, a provision under which the customer's silence or failure to take an 

affirmative action to reject goods or services or to cancel the agreement is interpreted by the 

seller or provider as acceptance of the offer. 

11. "Person(s)" means a natural person, organization, or other legal entity, including 

a corporation, limited liability company, partnership, sole proprietorship, association, 

cooperative, or any other group or combination acting as an entity. 

12. "Plaintiff' means the Federal Trade Commission. 

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13. "Receiver" or "Temporary Receiver" means the temporary receiver appointed 

in Section VII of this Order and any deputy receivers that shall be named by the temporary 

receiver. 

14. "Receivership Defendant" means Credit Bureau Center, LLC, a Delaware 

limited liability company, formerly known as MyScore LLC, and also doing business as 

eFreeScore.com, CreditUpdates.com, and FreeCreditNation.com, and its successors and assigns, 

as well as any subsidiaries, affiliates, divisions, or sales or customer service operations, and any 

fictitious business entities or business names created or used by these entities. 

I. 

PROHIBITED BUSINESS ACTIVITIES 

IT IS ORDERED that Defondants, and their officers, agents, servants, employees, 

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

actual notice of this Order by personal service or otherwise, whether acting directly or through 

any trust, corporation, subsidiary, division, or other device, in connection with the advertising, 

marketing, promoting, offering for sale, sale, or provision of any good or service, are hereby 

temporarily restrained and enjoined from: 

A. Misrepresenting, or assisting others in misrepresenting, either orally or in writing, 

expressly or by implication, any material fact, including, but not limited to: 

I. That a residential property described in an online ad is currently available for 

rent from someone consumers can contact through that ad; or 

2. That a residential property will be shown to consumers who obtain their 

credit reports and scores through any Defendant's website; 

B. Failing to disclose, or disclose adequately, material terms and conditions of any 

offer of any product or service, including, but not limited to: 

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1. That consumers will be automatically enrolled in a negative option 

continuity plan with additional charges; 

2. That consumers must affirmatively cancel the negative option continuity 

plan before the end of a trial period to avoid additional charges; 

3. That consumers' credit or debit card information will be used to charge 

consumers monthly for the negative option continuity plan; 

4. The costs associated with the negative option continuity plan; and 

5. The means consumers must use to cancel the negative option continuity 

plan to avoid additional charges. 

C. Violating or assisting others in violating, any provision of ROSCA, 15 U.S.C. 

§§ 8401 et seq., including, but not limited to: 

1. Section 4(1) of ROSCA, 15 U.S.C. § 8403(1), by charging, attempting to 

charge, or continuing to charge consumers through a negative option feature without having 

clearly and conspicuously disclosed all material terms of the transaction before obtaining 

consumers' billing information; and 

2. Section 4(2) of ROSCA, 15 U.S.C. § 8403(2), by charging, attempting to 

charge, or continuing to charge consumers through a negative option feature without having 

obtained their express informed consent; and 

D. Operating any website offering free credit reports without displaying across the 

top of each page that mentions free credit reports, and across the top of each page of the ordering 

process, the prominent disclosure required by the Free Reports Rule, 12 C.F.R. § 1022.138, to 

inform consumers of their right to obtain a free credit report from AnnualCreditReport.com or 

(877) 322-8228. 

Page 7 of 32 
II. 

ASSET FREEZE 

IT IS FURTHER ORDERED that Defendants, and their officers, agents, servants, 

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

who receive actual notice of this Order by personal service or otherwise, whether acting directly 

or through any trust, corporation, subsidiary, division, or other device, except as provided herein, 

as stipulated by the parties, or as directed by further order of the Court, are hereby temporarily 

restrained and enjoined from: 

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

concealing, dissipating, disbursing, assigning, spending, withdrawing, granting a lien or security 

interest or other interest in, or otherwise disposing of any funds, real or personal property, 

accounts, contracts, shares of stock, lists of consumer names, or other assets, or any interest 

therein, wherever located, including outside the United States, that are: 

1. Owned, controlled or held by, in whole or in part, for the benefit of, or 

subject to access by, or belonging to, any Defendant; 

2. In the actual or constructive possession of any Defendant; or 

3. In the actual or constructive possession ot~ or owned, controlled, or held 

by, or subject to access by, or belonging to, any other corporation, partnership, trust, or any other 

entity directly or indirectly owned, managed, or controlled by, or w1der common control with, 

any Defendant, including, but not limited to, any assets held by or for any Defendant in any 

account at any bank or savings and loan institution, or with any credit card processing agent, 

automated clearing house processor, network transaction processor, bank debit processing agent, 

customer service agent, commercial mail receiving agency, or mail holding or forwarding 

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company, or any credit union, retirement fund custodian, money market or mutual fund, storage 

company, trustee, or with any broker-dealer, escrow agent, title company, commodity trading 

company, precious metal dealer, or other financial institution or depository of any kind, either 

within or outside the territorial United States; 

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

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

under any Defendant's control, without providing the FTC prior notice and an opportunity to 

inspect the contents in order to determine that they contain no assets covered by this Section; 

C. Cashing any checks or depositing or processing any payments from customers of 

Defendants; 

D. Incurring charges or cash advances on any credit card issued in the name, singly 

or jointly, of any Defendant; or 

E. Incurring liens or encumbrances on real property, personal property, or other 

assets in the name, singly or jointly, of any Defendant or of any corporation, partnership, or other 

entity directly or indirectly owned, managed, or controlled by any Defendant. 

Notwithstanding the asset freeze provisions of Section II.A through E above, and subject 

to prior written agreement with the Commission, Individual Defendants may, upon compliance 

with Section IV (Financial Statements) infra, pay from their individual personal funds 

reasonable, usual, ordinary, and necessary living expenses. 

The funds, property, and assets affected by this Section shall include both existing assets 

and assets acquired after the effective date of this Order. 

Page 9 of 32 
III. 

DUTIES OF THIRD PARTIES HOLDING DEFENDANTS' ASSETS 

IT IS FURTHER ORDERED that any financial institution, business entity, or person 

maintaining or having custody or control of any account or other asset of any Defendant, or any 

corporation, partnership, or other entity directly or indirectly owned, managed, or controlled by, 

or under common control with any Defendant, which is served with a copy of this Order, or 

otherwise has actual or constructive knowledge of this Order, shall: 

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

assignment, transfer, pledge, hypothecation, encumbrance, disbursement, dissipation, 

conversion, sale, liquidation, or other disposal of any of the assets, funds, documents, or other 

property held by, or under its control: 

1. On behalf of, or for the benefit of, any Defendant or any other party 

subject to Section II above; 

2. In any account maintained in the name of~ or for the benefit of, or subject 

to withdrawal by, any Defendant or other party subject to Section II above; and 

3. That are subject to access or use by, or under the signatory power of, any 

Defendant or other party subject to Section 11 above; 

B. Deny Defendants access to any safe deposit boxes or storage facilities that are 

either: 

1. Titled in the name, individually or jointly, of any Defendant, or other party 

subject to Section II above; or 

2. Subject to access by any Defendant or other party subject to Section II 

above; 

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C. Provide the FTC, within five (5) days of the date of service of this Order, a sworn 

statement setting forth: 

I. The identification number of each account or asset titled in the name, 

individually or jointly, of any Defendant, or held on behalf of, or for the benefit of, any 

Defendant or other party subject to Section II above, including all trust accounts managed on 

behalf of any Defendant or subject to any Defendant's control; 

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

of such asset; 

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

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

or is otherwise subject to access or control by any Defendant or other party subject to Section II 

above, whether in whole or in part; and 

4. If the account, safe deposit box, storage facility, or other asset has been 

closed or removed, the date closed or removed and the balance on said date; 

D. Within five (5) days of a request from the FTC, provide the FTC with copies of 

all records or other documents pertaining to each such account or asset, including, but not limited 

to, originals or copies of account applications, account statements, corporate resolutions, 

signature cards, checks, drafts, deposit tickets, transfers to and from the accounts, all other debit 

and credit instruments or slips, cmrency transaction reports, I 099 forms, and safe deposit box 

Jogs; and 

E. The FTC may properly serve this Order on any financial or brokerage institution, 

business entity or person that holds, controls or maintains custody of any account or asset of any 

Defendant or has held, controlled or maintained custody of any account or asset of any 

Page I I of32 
Defendant at any time since January 2014, by facsimile transmission, hand delivery or overnight 

canier. This Section shall apply to existing accounts and assets, assets deposited or accounts 

opened after the effective date of this Order, and any accounts or assets maintained, held or 

controlled since January 2014. This Section shall not prohibit transfers in accordance with any 

provision of this Order, any further order of the Comi, or by written agreement of the parties. 

IV. 

FINANCIAL STATEMENTS 

IT IS FURTHER ORDERED that each Defendant shall serve upon counsel for the 

FTC, no later than five (5) business days after service of this Order, a completed financial 

statement accurate as of the date of entry of this Order, on the forms served on Defendants with 

this Order for Individual Defendants and for Corporate Defendants, as the case may be, signed 

under penalty of pe1j ury. 

The financial statements shall include assets held outside the tenitory of the United 

States, shall be accurate as of the date of the entry of this Order, and shall be verified under oath. 

Defendants shall attach to these completed financial statements copies of all local, state, 

provincial, and federal income and property tax returns, with attachments and schedules, as 

called for by the instructions to the financial statements. 

v. 

MAINTAIN RECORDS AND REPORT NEW BUSINESS ACTIVITY 

IT IS FURTHER ORDERED that Defendants, and their officers, agents, servants, 

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

who receive actual notice of this Order by personal service or otherwise, whether acting directly 

Page 12 of32 
or through any trust, corporation, subsidiary, division, or other device, are hereby temporarily 

restrained and enjoined from: 

A. Failing to make and keep books, records, accounts, bank statements, current 

accountants' reports, general ledgers, general journals, cash receipts ledgers, cash disbursements 

ledgers and source documents, documents indicating title to real or personal prope1iy, and any 

other data which, in reasonable detail, accurately and fairly reflect the incomes, disbursements, 

transactions, dispositions, and uses of Defendants' assets; 

B. Destroying, erasing, mutilating, concealing, altering, transferring, or otherwise 

disposing of, in any manner, directly or indirectly, any documents, including electronically 

stored materials, that relate in any way to the business practices or business or personal finances 

of Defendants; to the business practices or finances of entities directly or indirectly under the 

control of Defendants; or to the business practices or finances of entities directly or indirectly 

under common control with any other Defendant; and 

C. Creating, operating, or exercising any control over any new business entity, 

whether newly formed or previously inactive, including any partnership, limited partnership, 

joint venture, sole proprietorship or corporation, without first providing the FTC with a written 

statement disclosing: (I) the name of the business entity; (2) the address, telephone number, email address, and website address of the business entity; (3) the names of the business entity's 

officers, directors, principals, managers, and employees; and (4) a detailed description of the 

business entity's intended activities. 

Page 13 of32 
VI. 

PROHIBITION ON DISCLOSING CUSTOMER INFORMATION 

IT IS FURTHER ORDERED that Defendants, and their officers, agents, servants, 

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

of them, who receive actual notice of this Order by personal service or otherwise, whether acting 

directly or through any trust, corporation, subsidiary, division, or other device, are hereby 

temporarily restrained and enjoined from: 

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

birth date, telephone number, e-mail address, Social Security number, credit card number, bank 

account number, or other financial or identifying personal information of any person from whom 

or about whom any Defendant obtained such information in connection with activities alleged in 

the FTC's Complaint; and 

B. Benefiting from or using the name, address, birth date, telephone number, e-mail 

address, Social Security number, credit card number, bank account number, or other financial or 

identifying personal information of any person from whom or about whom any Defendant 

obtained such information in connection with activities alleged in the FTC's Complaint; 

Provided, however, that Defendants may disclose such financial or identifying personal 

information to a law enforcement agency or as required by any law, regulation, or court order. 

VII. 

TEMPORARY RECEIVER 

A. APPOINTMENT OF TEMPORARY RECEIVER 

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

Temporary Receiver for Receivership Defendant and any of its affiliates, subsidiaries, divisions, 

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or sales or customer service operations, wherever located, with the full power of an equity 

receiver. The Receiver shall be the agent of this Court, and solely the agent of this Court, in 

acting as Receiver under this Order. The Receiver shall be accountable directly to this Court. 

The Receiver shall comply with all Local Rules of this Court governing receivers. 

B. RECEIVERSHIP DUTIES 

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

accomplish the following: 

1. Assume full control of the Receivership Defendant by removing, as the 

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

or agent of the Receivership Defendant, including any Individual Defendant, from control of, 

management ot: or participation in, the affairs of the Receivership Defendant; 

2. Take exclusive custody, control, and possession of all assets and 

documents oC or in the possession, custody, or under the control of, the Receivership Defendant, 

wherever situated. The Receiver shall have full power to divert mail and to sue for, collect, 

receive, take in possession, hold, and manage all assets and documents of the Receivership 

Defendant and other persons or entities whose interests are now held by or under the direction, 

possession, custody, or control of the Receivership Defendant. Provided, however, that the 

Receiver shall not collect any amount from a consumer or allow the Receivership Defendant to 

continue to debit or otherwise charge a consumer's account, ifthe Receiver believes the 

consumer was a victim of the unfair or deceptive acts or practices alleged in the Complaint in 

this matter; 

3. Use any means necessary to take possession of and to secure all areas of 

the business premises of the Receivership Defendant. Such steps may include, but are not 

Page 15 of32 
limited to, the following as the Receiver deems necessmy or advisable: (a) serving this Order; 

(b) completing a written inventory of all receivership assets; ( c) obtaining pertinent infon11ation 

from all employees and other agents of the Receivership Defendant, including, but not limited to, 

the name, home address, Social Security number, job description, method of compensation, and 

all accrued and unpaid commissions and compensation of each such employee or agent; ( d) 

videotaping all portions of the locations; ( e) securing the locations by changing the locks and 

disconnecting any computer modems or other means of access to the computer or other records 

maintained at the locations; (f) requiring any persons present on the premises at the time this 

Order is served to leave the premises, to provide the Receiver with proof of identification, or to 

demonstrate to the satisfaction of the Receiver that such persons are not removing from the 

premises documents or assets of the Receivership Defendant; and/or (g) employ the assistance of 

law enforcement officers as the Receiver deems necessary to implement the provisions of this 

Order; 

4. Conserve, hold, and manage all receivership assets, and perform all acts 

necessary or advisable to preserve the value of those assets, in order to prevent any irreparable 

loss, damage, or injury to consumers or to creditors of the Receivership Defendant, including, 

but not limited to, obtaining an accounting of the assets and preventing transfer, withdrawal, or 

misapplication of assets, and including the authority to liquidate or close out any open securities 

or commodity futures positions of the Receivership Defendant; 

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

6. Prevent the inequitable distribution of assets and determine, adjust, and 

protect the interests of consumers and creditors who have transacted business with the 

Receivership Defendant; 

Page 16 of32 
7. Manage and administer the business of the Receivership Defendant until 

further order of this Court by performing all incidental acts that the Receiver deems to be 

advisable or necessary, which includes retaining, hiring, or dismissing any employees, 

independent contractors, or agents; 

8. Choose, engage, and employ attorneys, accountants, appraisers, and other 

independent contractors and technical specialists, as the Receiver deems advisable or necessary 

in the performance of duties and responsibilities under the authority granted by this Order; 

9. Make payments and disbursements from the receivership estate that are 

necessary or advisable for carrying out the directions of, or exercising the authority granted by, 

this Order. The Receiver shall apply to the Court for prior approval of any payment of any debt 

or obligation incurred by the Receivership Defendant prior to the date of entry of this Order, 

except payments that the Receiver deems necessary or advisable to secure assets of the 

Receivership Defendant, such as rental payments; 

10. Determine and implement the maimer in which the Receivership 

Defendant will comply with, and prevent violations of, this Order and all other applicable laws; 

11. Institute, compromise, adjust, appear in, intervene in, or become party to 

such actions or proceedings in state, federal or foreign courts that the Receiver deems necessary 

and advisable to preserve or recover the assets of the Receivership Defendant or that the 

Receiver deems necessary and advisable to carry out the Receiver's mandate under this Order; 

12. Defend, compromise, adjust, or otherwise dispose of any or all actions or 

proceedings instituted in the past or in the future against the Receiver in his or her role as 

Receiver, or against the Receivership Defendant that the Receiver deems necessary and 

Page 17 of 32 
advisable to preserve the assets of the Receivership Defendant or that the Receiver deems 

necessary and advisable to carry out the Receiver's mandate under this Order; 

13. Continue and conduct the business of the Receivership Defendant in such 

manner, to such extent, and for such duration as the Receiver may in good faith deem to be 

necessary or appropriate to operate the business profitably and lawfully, if at all; provided, 

however, that the continuation and conduct of the business shall be conditioned upon the 

Receiver's good faith determination that the business can be lawfully operated at a profit using 

the assets of the receivership estate; 

14. Issue subpoenas to obtain docnments and records pertaining to the 

receivership, and conduct discovery in this action on behalf of the receivership estate; 

15. Open one or more bank accounts as designated depositories for funds of 

the Receivership Defendant. The Receiver shall deposit all funds of the Receivership Defendant 

in such a designated account and shall make all payments and disbursements from the 

receivership estate from such an account; 

l 6. Maintain accurate records of all receipts and expenditures that he or she 

makes as Receiver; 

17. Cooperate with reasonable requests for information or assistance from any 

state or federal law enforcement agency, including the FTC; and 

18. File reports with the Court on a timely and reasonable basis. 

C. COOPERATION WITH THE RECEIVER 

IT IS FURTHER ORDERED that: 

1. Defendants and their officers, agents, servants, employees, and attorneys, 

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

Page 18 of32 
notice of this Order by personal service or otherwise, whether acting directly or through any 

trust, corporation, subsidiary, division, or other device, shall fully cooperate with and assist the 

Receiver. This cooperation and assistance shall include, but not be limited to: 

a. Providing any information to the Receiver that the Receiver deems 

necessary to exercising the authority and discharging the responsibilities of the Receiver under 

this Order; 

b. Providing any password required to access any computer, 

electronic file, or telephonic data in any medium; or 

c. Advising all persons who owe money to the Receivership 

Defendant that all debts should be paid directly to the Receiver. 

2. Defendants and their officers, agents, servants, employees, and attorneys, 

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

notice of this Order by personal service or otherwise, whether acting directly or through any 

trust, corporation, subsidiary, division, or other device, are hereby restrained and enjoined from 

directly or indirectly: 

a. Transacting any of the business of the Receivership Defendant; 

b. Destroying, secreting, defacing, transferring, or otherwise altering 

or disposing of any documents of the Receivership Defendant, including, but not limited to, 

books, records, accounts, writings, drawings, graphs, charts, photographs, audio and video 

recordings, computer records, and other data compilations, electronically-stored records, or any 

other records of any kind or nature; 

c. Transfening, receiving, altering, selling, encumbering, pledging, 

assigning, liquidating, or otherwise disposing of any assets owned, controlled, or in the 

Page 19of32 
possession or custody of, or in which an interest is held or claimed by, the Receivership 

Defendant, or the Receiver; 

d. Excusing debts owed to the Receivership Defendant; 

e. Failing to notify the Receiver of any asset, including accounts, of 

the Receivership Defendant held in any name other than the name of the Receivership 

Defendant, or by any person or entity other than the Receivership Defendant, or failing to 

provide any assistance or information requested by the Receiver in connection with obtaining 

possession, custody, or control of such assets; 

f. Doing any act or refraining from any act whatsoever to interfere 

with the Receiver's taking custody, control, possession, or managing of the assets or documents 

subject to this receivership; or to harass or interfere with the Receiver in any way; or to interfere 

in any manner with the exclusive jurisdiction of this Court over the assets or documents of the 

Receivership Defendant; or to refuse to cooperate with the Receiver or the Receiver's duly 

authorized agents in the exercise of their duties or authority under any Order of this Court; or 

g. Filing, or causing to be filed, any petition on behalf of the 

Receivership Defendant for relief under the United States Bankruptcy Code, 11U.S.C.§101 et 

seq., without prior permission from this Court. 

D. DELIVERY OF RECEIVERSHIP PROPERTY 

IT IS FURTHER ORDERED that: 

1. Immediately upon service of this Order upon them, or within such period 

as may be permitted by the Receiver, Defendants or any other person or entity shall transfer or 

deliver possession, custody, and control of the following to the Receiver: 

Page 20 of 32 
a. All assets of the Receivership Defendant, including assets subject 

to repatriation pursuant to Section IX, infi-a; 

b. All documents of the Receivership Defendant, including, but not 

limited to, books and records of accounts, all financial and accounting records, balance sheets, 

income statements, bank records (including monthly statements, canceled checks, records of wire 

transfers, and check registers), client lists, title documents and other papers; 

c. All assets belonging to members of the public now held by the 

Receivership Defendant; and 

d. All keys, codes, and passwords necessary to gain or to secure 

access to any assets or documents of the Receivership Defendant, including, but not limited to, 

access to their business premises, means of communication, accounts, computer systems, mail 

boxes, or other property. This includes providing the necessary means to gain access to 

commercial mail boxes. 

2. In the event any person or entity fails to deliver or transfer any 

receivership asset or document or otherwise fails to comply with any provision of this Section, 

the Receiver may file ex parte an Affidavit of Non-Compliance regarding the failure. Upon 

filing of the affidavit, the Court may authorize, without additional process or demand, Writs of 

Possession or Sequestration or other equitable writs requested by the Receiver. The writs shall 

authorize and direct the United States Marshal or any sheriff or deputy sheriff of any county, or 

any other federal or state law enforcement officer, to seize the asset, document, or other thing 

and to deliver it to the Receiver. 

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E. TRANSFER OF FUNDS TO THE RECEIVER 

IT IS FURTHER ORDERED that, upon service of a copy of this Order, all financial 

institutions, finance companies, commercial lending companies, credit card processing agents or 

agents providing electronic funds transfer services or automated clearing house processing, 

brokerage houses, escrow agents, money market or mutual funds, title companies, commodity 

futures merchants, commodity trading companies, precious metal dealers, trustees, or other 

financial institutions or depositories of any kind, shall cooperate with all reasonable requests of 

the Receiver relating to implementation of this Order, including transferring funds at his or her 

direction and producing records related to the assets of the Receivership Defendant. 

F. STAY OF ACTIONS 

IT IS FURTHER ORDERED that: 

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

herein, Defendants and all other persons and entities be and hereby are stayed from taking any 

action to establish or enforce any claim, right, or interest for, against, on behalf of, in, or in the 

name of, the Receivership Defendant, any of its subsidiaries, affiliates, partnerships, assets, 

documents, or the Receiver or the Receiver's duly authorized agents acting in their capacities as 

such, including, but not limited to, the following actions: 

a. Commencing, prosecuting, continuing, entering, or enforcing any 

suit or proceeding, except that such actions may be filed to toll any applicable statute of 

limitations; 

b. Accelerating the due date of any obligation or claimed obligation; 

filing, perfecting or enforcing any lien; taking or attempting to take possession, custody, or 

control of any asset; attempting to foreclose, forfeit, alter, or terminate any interest in any asset, 

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whether such acts are part of a judicial proceeding, me acts of self-help, or otherwise, or setoff of 

any debt owing to the Receivership Defendant that arose before the date of this Order against any 

claim against the Receivership Defendant; 

c. Executing, issuing, serving, or causing the execution, issuance or 

service of, any legal process, including, but not limited to, attachments, garnishments, 

subpoenas, writs of replevin, writs of execution, or any other form of process whether specified 

in this Order or not; or 

d. Doing any act or thing whatsoever to interfere with the Receiver 

taking custody, control, possession, or management of the assets or documents subject to this 

receivership, or to harass or interfere with the Receiver in any way, or to interfere in any manner 

with the exclusive jurisdiction of this Court over the assets or documents of the Receivership 

Defendant. 

2. This Order does not stay: 

a. The commencement or continuation of a criminal action or 

proceeding; 

b. The commencement or continuation of an action or proceeding by 

a governmental unit to enforce such governmental unit's police or regulatory power; or 

c. The enforcement of a judgment, other than a money judgment, 

obtained in an action or proceeding by a governmental unit to enforce such governmental unit's 

police or regulatory power. 

3. Except as otherwise provided in this Order, all persons and entities in need 

of documentation from the Receiver shall in all instances first attempt to secure such information 

by submitting a formal written request to the Receiver, and, if such request has not been 

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responded to within thirty (30) days of receipt by the Receiver, any such person or entity may 

thereafter seek an Order of this Court with regard to the relief requested. 

G. 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 out-of-pocket expenses incurred by them, from the assets now held by, or in the 

possession or control ot: or which may be received by the Receivership Defendant. The 

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

such reasonable compensation, with the first such request filed no more than sixty (60) days after 

the date of this Order. The Receiver shall not increase the hourly rates used as the bases for such 

fee applications without prior approval of the Court 

H. RECEIVER'S BOND 

IT IS FURTHER ORDERED that the Receiver shall file with the Clerk of this Court a 

bond in the sum of $10,000.00 with sureties to be approved by the Court, conditioned that the 

Receiver will well and truly perform the duties of the office and abide by and perform all acts the 

Court directs. 

VIII. 

ACCESS TO BUSINESS PREMISES 

IT IS FURTHER ORDERED that Defendants, and their officers, agents, servants, 

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

them, who receive actual notice of this Order by personal service or otherwise, whether acting 

directly or through any trust, corporation, subsidiary, division, or other device, and the Receiver, 

Page 24 of 32 
shall allow the FTC's representatives, agents, and assistants, as well as the Receivership 

Defendant's representatives, and the Individual Defendants themselves, reasonable access to all 

of the Receivership Defendant's business premises, or any other premises where the 

Receivership Defendant conducts business or customer service operations. 

The purpose of this access shall be to inspect and copy any and all books, records, 

documents, accounts, and other property owned by, or in the possession of, the Receivership 

Defendant or its agents. The Receiver shall have the discretion to detennine the time, manner, 

and reasonable conditions of such access. The FTC may remove materials from the 

Receivership Defendant's business premises to inspect, inventory, and copy such materials. The 

FTC shall return materials so removed within five (5) business days of completing said inventory 

and copying. The FTC's access to Defendants' documents pursuant to this Section shall not 

provide grounds for any Defendant to object to any subsequent request for documents served by 

any Plaintiff. 

IX. 

REPATRIATION OF ASSETS AND DOCUMENTS 

IT IS FURTHER ORDERED that Defendants shall: 

A. Within three (3) business days following service of this Order, take such steps as 

are necessary to repatriate to the territory of the United States of America all documents and 

assets that are located outside such territory and are held by or for Defendants or are under 

Defendants' direct or indirect control, jointly, severally, or individually; 

B. Within three (3) business days following service of this Order, provide the FTC 

with a full accounting of all documents and assets that are located outside of the territory of the 

United States of America or that have been transferred to the territory of the United States of 

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America pursuant to Subsection A above and are held by or for any Defendant or are under any 

Defendant's direct or indirect control, jointly, severally, or individually, including the names and 

addresses of any foreign or domestic financial institution or other entity holding the documents 

and assets, along with the account numbers and balances; 

C. Hold and retain all such documents and assets and prevent any transfer, 

disposition, or dissipation whatsoever of any such documents or assets; and 

D. Within three (3) business days following service of this Order, provide the FTC 

access to Defendants' records and documents held by financial institutions or other entities 

outside the territory of the United States of America, by signing and delivering to FTC counsel 

the Consent to Release of Financial Records attached to this Order as Attachment A. 

x. 

INTERFERENCE WITH REPATRIATION 

IT IS FURTHER ORDERED that Defendants are hereby temporarily restrained and 

enjoined from taking any action, directly or indirectly, which may result in the encumbrance or 

dissipation of foreign assets, or in the hindrance of the repatriation required by the preceding 

Section IX of this Order, including, but not limited to: 

A. Sending any statement, letter, facsimile, e-mail or wire transmission, or 

telephoning or engaging in any other act, directly or indirectly, that results in a determination by 

a foreign trustee or other entity that a "duress" event has occurred under the terms of a foreign 

trust agreement, until such time that assets have been fully repatriated pursuant to the preceding 

Section of this Order; and 

B. Notifying any trustee, protector or other agent of any foreign trust or other related 

entities of either the existence of this Order, or of the fact that repatriation is required pursuant to 

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a Comi Order, until such time as assets have been fully repatriated pursuant to the preceding 

Section of this Order. 

XI. 

EXPEDITED DISCOVERY 

IT IS FURTHER ORDERED that pursuant to Federal Rules of Civil Procedure 30(a), 

31 (a), 34, and 45, and notwithstanding the provisions of Federal Rules of Civil Procedure 26(d) 

and (f), 30(a)(2)(A), and 3 l(a)(2)(A), the paiiies are granted leave, at any time after entry of this 

Order to: 

A. Take the deposition of any person, whether or not a party, for the purpose of 

discovering the nature, location, status, and extent of the assets of Defendants, and Defendants' 

affiliates and subsidiaries; the nature and location of documents reflecting the business 

transactions of Defendants, and Defendants' affiliates and subsidiaries; the location of any 

premises where Defendants, directly or through any third party, conduct business operations; the 

Defendai1ts' whereabouts; and/or the applicability of any evidentiary privileges to this action; 

and 

B. Demand the production of documents from any person, whether or not a party, 

relating to the nature, status, ai1d extent of the assets of Defendants, and Defendants' affiliates 

and subsidiaries; the nature and location of documents reflecting the business transactions of 

Defendants, and Defendants' affiliates and subsidiaries; the location of any premises where 

Defendants, directly or through any third party, conduct business operations; the Defendants' 

whereabouts; ai1d/or the applicability of any evidentiary privileges to this action. 

Three (3) days' notice shall be deemed sufficient for any such deposition, five (5) days' 

notice shall be deemed sufficient for the production of any such documents, and twenty-four (24) 

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hours' notice shall be deemed sufficient for the production of any such documents that are 

maintained or stored only as electronic data. The provisions of this Section shall apply both to 

parties to this case and to non-parties. The limitations and conditions set forth in Federal Rules 

of Civil Procedure 30(a)(2)(A)(ii) and 3 l(a)(2)(A)(ii) regarding subsequent depositions of an 

individual shall not apply to depositions taken pursuant to this Section. Any such depositions 

taken pursuant to this Section shall not be counted toward any limit on the number of depositions 

under the Federal Rules of Civil Procedure, including those set forth in Federal Rules of Civil 

Procedure 30(a)(2)(A) and 31 (a)(2)(A). Service of discovery upon a party, taken pursuant to this 

Section, shall be sufficient if made through the means described in Section XVII of this Order. 

XU. 

DISTRIBUTION OF ORDER BY DEFENDANTS 

IT IS FURTHER ORDERED that Defendants shall immediately provide a copy of this 

Order to each of their corporations, subsidiaries, affiliates, partners, divisions, sales entities, 

successors, assigns, members, officers, directors, employees, independent contractors, agents, 

servants, attorneys, spouses, representatives, and any other persons in active concert or 

participation with them. Within five (5) calendar days following service of this Order, 

Defendants shall file with this Court and serve on the FTC an affidavit identifying the name, 

title, addresses, telephone numbers, date of service, and manner of service of the persons and 

entities Defendants have served with a copy of this Order in compliance with this provision. 

XIII. 

EXPIRATION DATE OF TEMPORARY RESTRAINING ORDER 

IT IS FURTHER ORDERED that the Temporary Restraining Order granted herein 

shall expire on January 25, 2017, at 5:00 p.m. (Central Time), unless within such time, the Order, 

Page 28 of 32 
for good cause shown, is extended, or unless, as to any Defendant, the Defendant consents that it 

should be extended for a longer period of time. 

XIV. 

ORDER TO SHOW CAUSE REGARDING PRELIMINARY INJUNCTION 

IT IS FURTHER ORDERED, pursuant to Federal Rule of Civil Procedure 65, that each 

Defendant shall appear before this Court on the 25111 day of Jauary, 2017, at 9:30 o'clock a.m. 

(Central Time), at the United States Courthouse, United States District Court for the Northern 

District of Illinois, Chicago, Illinois, Courtroom 2103, to show cause, ifthere is any, why this 

Court should not enter a Preliminary Injunction, pending final ruling on the Complaint against 

Defendants, enjoining them from further violations of Section 5(a) of the FTC Act, 15 U.S.C. § 

45(a), Section 4( 1) and (2) of ROSCA, 15 U.S.C. § 8403(1) & (2), Section 6 l 2(g) of the FCRA, 

15 U.S.C. § 168lj(g), and the Free Reports Rule, 12 C.F.R. §§ 1022.130-1022.138, continuing 

the freeze of their assets, making the temporary Receiver's appointment permanent and imposing 

such additional relief as may be appropriate. 

xv. 

BRIEFS AND AFFIDAVITS CONCERNING PRELIMINARY INJUNCTION 

IT IS FURTHER ORDERED that Defendants shall file with the Court and serve on 

FTC counsel any answering affidavits, pleadings, motions, expert reports or declarations, and/or 

legal memoranda no later than four (4) business days prior to the hearing on the FTC's request 

for a preliminary injunction. The FTC may file responsive or supplemental pleadings, materials, 

affidavits, motions, or memoranda with the Court and serve the same on counsel for Defendants 

no later than one (1) business day prior to the preliminary injunction hearing in this matter, 

provided that service shall be performed by personal or overnight delivery, by electronic filing, 

Page 29 of 32 
by electronic mail, or by facsimile, and documents shall be delivered so that they shall be 

received by the other parties no later than 4:00 p.m. (Central Time) on the appropriate dates 

listed in this Section. 

XVI. 

MOTION FOR LIVE TESTIMONY; WITNESS IDENTIFICATION 

IT IS FURTHER ORDERED that the question of whether this Court should enter a 

preliminary injunction pursuant to Rule 65 of the Federal Rules of Civil Procedure enjoining the 

Defendants during the pendency of this action shall be resolved on the pleadings, declarations, 

exhibits, and memoranda filed by, and oral argument of, the parties. Live testimony shall be 

heard only on further order of this Court or on motion filed with the Court and served on counsel 

for the other parties at least four ( 4) business days prior to the preliminary injunction hearing in 

this matter. Such motion shall set forth the name, address, and telephone number of each 

proposed witness, a detailed summary or affidavit revealing the substance of each proposed 

witness's expected testimony, and an explanation of why the taking of live testimony would be 

helpful to this Court. Any papers opposing a timely motion to present live testimony or to 

present live testimony in response to another party's timely motion to present live testimony 

shall be filed with this Court and served on the other parties at least two (2) business days prior 

to the preliminary injunction hearing in this matter, provided that service shall be performed by 

personal or overnight delivery, by electronic filing, by electronic mail, or by facsimile, and 

documents shall be delivered so that they shall be received by the other parties no later than 4:00 

p.m. (Central Time) on the appropriate dates provided in this Section. 

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Provided.further, however, that an evidentiary hearing on the FTC's request for a 

preliminary injunction is not necessary unless Defendants demonstrate that they have, and intend 

to introduce, evidence that raises a genuine and material factual issue, 

XVII. 

SERVICE OF THIS ORDER 

IT JS FURTHER ORDERED that copies of this Order may be distributed by United 

States First Class Mail, overnight delivery, facsimile, electronic mail, or personally, by agents or 

employees of the FTC, by agents or employees of the Receiver, by any law enforcement agency, 

or by private process server, upon any person, financial institution, or other entity that may have 

possession or control of any property, property right, document, or asset of any Defendant, or 

that may be subject to any provision of this Order. Service upon any branch or office of any 

financial institution or entity shall effect service upon the entire financial institution or entity. 

XVIII. 

CONSUMER REPORTING AGENCIES 

IT IS FURTHER ORDERED that, pursuant to Section 604 of the Fair Credit Repo1iing 

Act, 15 U.S.C. § 168lb, any consumer rep01iing agency may furnish a consumer or credit report 

concerning any Defendant to the FTC. 

XIX. 

SERVICE UPON PLAINTIFF 

IT IS FURTHER ORDERED that Defendants shall serve all pleadings, memoranda, 

correspondence, affidavits, declarations, or other documents related to this Order or the FTC's 

motion for a preliminary injunction by: (1) e-mail at g_wa.rd@Jtc.gov and slevine 1 ({i;flc.gov; and 

(2) facsimile transmission to the FTC at (312) 960-5600, hand delivery to the offices of the FTC 

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at 55 West Monroe Street, Suite 1825, Chicago, Illinois 60603, to the attention of Guy G. Ward 

and Samuel A.A. Levine, or overnight shipment through a third-party commercial carrier for 

delivery at the address listed above. 

xx. 

RETENTION OF JURISDICTION 

IT IS FURTHER ORDERED that this Court shall retain jurisdiction of this matter for 

all purposes. 

SO ORDERED, this 11th day of January, 2017, at 5:00 p.m. 

Page 32 of 32 
ATTACHMENT A 

Consent to Release of Financial Information 
UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

FEDERAL TRADE COMMISSION, 

Plaintiff, 

v. 

CREDIT BUREAU CENTER, LLC, 

a limited liability company, formerly known as 

MYSCORE LLC, also doing business as 

EFREESCORE.COM, CREDITUPDATES.COM, 

and FREECREDITNATION.COM, 

MICHAEL BROWN, 

individually and as owner and manager of 

CREDIT BUREAU CENTER, LLC, 

DANNY PIERCE, individually, and 

ANDREW LLOYD, individually, 

Defendants. 

) 

) 

) 

) Case No. 17-cv-194 

) 

) Judge Kennelly 

) 

) Magistrate Judge Valdez 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

~~~~~~~~~~~~~~~~) 

CONSENT TO RELEASE OF FINANCIAL INFORMATION 

I, 

(city and state), do hereby direct any person, bank, savings and loan association, credit union, 

depository institution, finance company, commercial lending company, payment processor, 

payment processing entity, common carrier, customs broker, commercial mail receiving agency, 

mail holding and/or forwarding company, brokerage house, escrow agent, money market or 

mutual fund, title company, commodity trading company, or trustee, that holds, controls or 

maintains custody of assets, wherever located, that are owned or controlled by me, or any of the 

above Defendants, in whole or in part, or at which I, or any of the above Defendants, have an 

11 
account of any kind upon which I am authorized to draw, and its officers, employees and agents, 

to disclose all information and deliver copies of all documents of every nature in its possession 

or control which relate to the said accounts to any attorney for Plaintiffs, and to give evidence 

relevant thereto, in the above-captioned matter, Federal Trade Commission v. Credit Bureau 

Center, LLC, et al., now pending in the United States District Court for the Northern District of 

Illinois, and this shall be irrevocable authority for so doing. This direction is intended to apply to 

the laws of countries other than the United States of America which restrict or prohibit the 

disclosure of bank or other financial information without the consent of the holder of the 

account, and shall be construed as consent with respect thereto, and the same shall apply to any 

of the accounts for which I may be the relevant principal. 

Dated: ~~~~~~~~~ 

, 2017 

[Signature] 

[Print Name] 

1ll