Case 4:22-cv-00654 Document 2 Filed 07/29/22 Page 1 of 3 PageID #: 36 

UNITED STATES DISTRICT COURT 

EASTERN DISTRICT OF TEXAS 

FEDERAL TRADE COMMISSION, 

Plaintiff, 

v. 

FIRST AMERICAN PAYMENT SYSTEMS, 

LP, a limited partnership, also d/b/a MERIMAC 

CAPITAL, 

ELIOT MANAGEMENT GROUP, LLC, a 

limited liability company, also d/b/a SUNDANCE 

PAYMENT SOLUTIONS, and 

THINK POINT FINANCIAL, LLC, a limited 

liability company, also d/b/a CYPRESS BAY 

SOLUTIONS and IMPULSE PAYMENTS,

 Defendants. 

Case No. ______________ 

JOINT MOTION TO ENTER STIPULATED 

ORDER FOR PERMANENT INJUNCTION, 

MONETARY JUDGMENT, AND OTHER RELIEF 

Plaintiff Federal Trade Commission (“Plaintiff”) and Defendants First American 

Payment Systems, LP, Eliot Management Group, LLC and Think Point Financial, LLC 

(“Defendants”) respectfully submit a proposed Stipulated Order For Permanent Injunction, 

Monetary Judgment, and Other Relief (“Stipulated Order”) attached hereto as Exhibit A, which 

has been signed by Plaintiff’s counsel and the Defendants. The Stipulated Order collectively 

resolves all matters in dispute between Plaintiff and Defendants in this action. Defendants neither 

admit nor deny any of the allegations in the Complaint, except as specifically stated in the 

1 
 

 

 

 

Case 4:22-cv-00654 Document 2 Filed 07/29/22 Page 2 of 3 PageID #: 37 

Stipulated Order. 

Plaintiff’s counsel has presented the Stipulated Order to the full Federal Trade 

Commission, which has now approved it. Accordingly, Plaintiff and Defendants jointly move the 

Court to enter the Stipulated Order. 

DATED this 29th day of July, 2022. 

 Respectfully submitted, 

/s/ Jason C. Moon 

JASON C. MOON, Texas Bar No. 24001188 

THOMAS B. CARTER, Texas Bar No. 03932300 

EDWARD HYNES, New York Bar No. 4887584 

Federal Trade Commission 

1999 Bryan Street, Suite 2150 

Dallas, Texas 75201 

(214) 979-9378; jmoon@ftc.gov (Moon) 

(214) 979-9372; tcarter@ftc.gov (Carter) 

(214) 979-9381; ehynes@ftc.gov (Hynes) 

(214) 953-3079 (Fax) 

Attorneys for Plaintiff 

FEDERAL TRADE COMMISSION 

/s/ Brian Goodrich 

BRIAN GOODRICH 

Texas Bar No. 24119720 

brian.goodrich@hklaw.com 

Tel: (214) 964-9429 

Fax: (214) 964-9501 

Holland & Knight, LLP 

1722 Routh Street, Suite 1500 

Dallas, TX 75201 

Attorney for Defendants 

FIRST AMERICAN PAYMENT SYSTEMS, LP, 

ELIOT MANAGEMENT GROUP, LLC AND 

 THINK POINT FINANCIAL, LLC 

2 
 

 

 

 

Case 4:22-cv-00654 Document 2 Filed 07/29/22 Page 3 of 3 PageID #: 38 

CERTIFICATE OF SERVICE 

The undersigned certifies that on July 29th, 2022, a true and correct copy of the foregoing 

document was served through the CM/ECF system or electronic mail to the following parties or 

counsel: 

Anthony E. DiResta 

Holland & Knight 

800 17th Street N.W., Suite 1100 

Washington DC 20006 

Tel: (202) 469-5164 

anthony.diresta@hklaw.com 

Brian Goodrich 

Holland & Knight 

1722 Routh Street, Suite 1500 

Dallas, TX 75201 

Tel: (214) 964- 9429 

brian.goodrich@hklaw.com 

Ellen T. Berge 

Venable LLP 

600 Massachusetts Avenue, NW 

Washington DC 20001 

Tel: (202) 344-4704 

etberge@venable.com 

Counsel for Defendants 

First American Payment Systems, LP 

Eliot Management Group, LLC 

Think Point Financial, LLC

 /s/ Jason C. Moon 

 Jason C. Moon 

3