Case 1:10-cv-03551-ILG-RLM Document 499 Filed 12/09/21 Page 1 of 18 ~~jtAffi~ 026 

File Date: 

12/9/2021 

U.S. DISTRICT 

COURT-EDNY 

BROOKLYN UNITED STATES DISTRICT COURT OFFICE FOR THE EASTERN DISTRICT OF NEW YORK 

FEDERAL TRADE COMMISSION, 

Plaintiff, 

v. 

CONSUMER HEALTH BENEFITS 

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 ofNATIONAL 

BENEFITS SOLUTIONS, LLC, and as the Vice 

President and Treasurer of CONSUMER HEALTH 

BENEFITS ASSOCIATION, 

RON WERNER, individually, as a Managing 

Member ofNATIONAL BENEFITS 

CONSULTANTS, LLC, as a Managing Member of 

NATIONAL BENEFITS SOLUTIONS, LLC, and 

as President and Managing Partner of CONSUMER 

HEALTH BENEFITS ASSOCIATION, 

RITA WERNER, individually, and as Senior Vice 

President and Director of Operations of 

CONSUMER HEALTH BENEFITS 

ASSOCIATION, 

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

STIPULATED ORDER FOR 

PERMANENT INJUNCTION AND 

MONETARY JUDGMENT AS TO 

DEFENDANT JOHN SCHWARTZ 
WENDI TOW, individually, as a Managing 

Member of NATIONAL BENEFITS 

CONSULT ANTS, LLC, and as a Managing 

Member of NATIONAL BENEFITS SOLUTIONS, 

LLC, 

JOHN SCHWARTZ, individually, as a Managing 

Member of NATIONAL BENEFITS 

CONSULTANTS, 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 

INSURANCECOMPANY,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 

Case 1:10-cv-03551-ILG-RLM Document 499 Filed 12/09/21 Page 2 of 18 PageID #: 30027 
13(b) and 19 of the Federal Trade Commission Act ("FTC Act"), 15 U.S.C. §§ 53(b) and 57b. 

The Commission and Defendant John Schwartz ("Defendant Schwartz") stipulate to the entry of 

this Stipulated Order for Permanent Injunction and Monetary Judgment as to Defendant John 

Schwartz ("Order") to resolve all matters in dispute in this action between them. 

THEREFORE, IT IS ORDERED as follows: 

FINDINGS 

l. This Court has jurisdiction over this matter. 

2. The First Amended Complaint charges that Defendant Schwartz 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 medical discount plans. 

3. Defendant Schwartz neither admits nor denies any of the allegations in the First Amended 

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

Defendant Schwartz admits the facts necessary to establish jurisdiction. 

4. Defendant Schwartz waives any claim that he 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 agrees to bear his own costs and attorney fees. 

5. Defendant Schwartz waives 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. "Healthcare-Related Benefits or Discount Programs" includes any program, 

membership, card, product, or other good or service, which is not insurance, that purports to offer 

discounts, savings, or benefits on healthcare, or access to such discounts, savings, or benefits. 

E. "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. 

F. "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. 

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G. "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. 

H. "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. 

I. "Defendant Schwartz" means John Schwartz. 

ORDER 

I. BAN ON SELLING HEALTHCARE-RELATED 

BENEFITS OR DISCOUNT PROGRAMS 

IT IS ORDERED that Defendant Schwartz is 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 Healthcare-Related Benefits or 

Discount Programs. 

II. PROHIBITION AGAINST MISREPRESENTATIONS 

IT IS FURTHER ORDERED that Defendant Schwartz, his officers, agents, employees, 

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

receive actual notice of this Order, whether acting directly or indirectly, in connection with 

promoting or offering for sale any good or service ( other than Healthcare-Related Benefits or 

Discount Programs) are permanently restrained and enjoined from misrepresenting or assisting 

others in misrepresenting, expressly or by implication: 

A. That consumers will save a substantial sum of money; 

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B. Any material aspect of the nature or terms of the Seller's refund, cancellation, exchange, 

or repurchase policies; and 

C. Any other fact material to consumers concerning any good or service, such as: the total 

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

performance, efficacy, nature, or central characteristics. 

III. PROHIBITION AGAINST VIOLATING THE TSR 

IT IS FURTHER ORDERED that Defendant Schwartz, his officers, agents, employees, 

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

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

restrained and enjoined from violating any provision of the Telemarketing Sales Rule, 16 C.F.R. 

Part 310, attached as Attachment A, including: 

A. Section 310.3(a)(l)(iii) of the TSR, 16C.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: (I) 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, 

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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. 

IV. MONETARY JUDGMENT 

IT IS FURTHER ORDERED that: 

A. Judgment in the amount of Three Million Dollars ($3,000,000) is entered in favor of the 

Commission against Defendant Schwartz as monetary relief. 

8. Defendant Schwartz is ordered to pay to the Commission One Hundred Thousand Dollars 

($100,000), which, as Defendant Schwartz stipulates, his 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. Upon such payment, the remainder of the 

judgment is suspended, subject to the Subsections below. 

C. Defendant Schwartz shall relinquish any and all right, title, and interest he may possess in 

any funds held by the Escrow Agent, including funds held on behalf of any Defendant, in favor of 

the FTC. 

D. The Commission's agreement to the suspension of part of the judgment is expressly 

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premised upon the truthfulness, accuracy, and completeness of Defendant Schwartz's sworn 

financial statements and related documents (collectively, "financial representations") submitted to 

the Commission, namely the Financial Statement of Individual Defendant John Schwartz signed 

on August 3, 2021, including the attachments. 

E. The suspension of the judgment will be lifted as to Defendant Schwartz if, upon motion by 

the Commission, the Court finds that Defendant Schwartz failed to disclose any material asset, 

materially misstated the value of any asset, or made any other material misstatement or omission 

in the financial representations identified above. 

F. If the suspension of the judgment is lifted, the judgment becomes immediately due as to 

Defendant Schwartz in the amount specified in Subsection A. above (which the parties stipulate 

only for purposes of this Section represents the consumer injury alleged in the First Amended 

Complaint), less any payment previously made pursuant to this Section, plus interest computed 

from the date of entry of this Order. 

G. Defendant Schwartz relinquishes 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. 

H. The facts alleged in the First Amended Complaint will be taken as true, without further 

proof, in any subsequent civil litigation by or on behalf of the Commission, including in a 

proceeding to enforce its rights to any payment or monetary judgment pursuant to this Order, such 

as a nondischargeability complaint in any bankruptcy case. 

I. 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. 

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J. Defendant Schwartz acknowledges that his Taxpayer Identification Number (Social 

Security Number), which Defendant Schwartz previously submitted to the Commission, may be 

used for collecting and reporting on any delinquent amount arising out of this Order, in 

accordance with 31 U.S.C. §7701. 

K. 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. Defendant Schwartz has no right to 

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

L. If Defendant Schwartz fails to pay fully the amount due at the time specified, Defendant 

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

collect the judgment. In such an event, Defendant Schwartz agrees to provide federal and state 

tax returns for the preceding 2 years, and to complete a new financial disclosure form fully and 

accurately within IO business days of receiving a request from the Commission. Defendant 

Schwartz further authorizes the Commission to verify all information provided on his financial 

disclosure form with all appropriate third parties, including financial institutions. 

M. The Commission may request any tax-related information, including amended tax returns 

and any other filings, that Defendant Schwartz has the authority to release. Within 14 days of 

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receipt of a written request from a representative of the Commission, Defendant Schwartz must 

take all necessary steps (such as filing a completed IRS Form 4506 or 8821) to cause the Internal 

Revenue Service or other tax authority to provide the information directly to the Commission. 

V. CUSTOMER INFORMATION 

IT IS FURTHER ORDERED that Defendant Schwartz, his officers, agents, employees, 

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

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

restrained and enjoined from directly or indirectly: 

A. 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 medical discount plans; and 

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

control within 30 days after entry of a stipulated final order against the last remaining Defendant 

or 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. 

VI. COOPERATION 

IT IS FURTHER ORDERED that Defendant Schwartz must fully cooperate with 

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

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

Defendant Schwartz must provide truthful and complete information, evidence, and testimony. 

Defendant Schwartz must appear for interviews, discovery, hearings, trials, and any other 

proceedings that a Commission representative may reasonably request upon 5 days written notice, 

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

designate, without the service of a subpoena. 

VII. ORDER ACKNOWLEDGMENTS 

IT IS FURTHER ORDERED that Defendant Schwartz obtain acknowledgments of receipt 

of this Order: 

A. Defendant Schwartz, 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, Defendant Schwartz for any business that he, 

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

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

managers and members; (2) all employees, agents, and representatives with managerial 

responsibilities for conduct related to the subject matter of the Order and all agents and 

representatives who participate in conduct related to the subject matter of the Order; and (3) 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 Defendant Schwartz delivered a copy of this 

Order, Defendant Schwartz must obtain, within 30 days, a signed and dated acknowledgment of 

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receipt of this Order. 

VIII. COMPLIANCE REPORTING 

IT IS FURTHER ORDERED that Defendant Schwartz make timely submissions to the 

Commission: 

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

sworn under penalty of perjury, to: 

I. identify all telephone numbers and all physical, postal, email and Internet 

addresses, including all residences; 

2. identify all business activities, including any business for which Defendant 

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

Defendant Schwartz has any ownership interest; 

3. describe in detail Defendant Schwartz's involvement in each such business, 

including title, role, responsibilities, participation, authority, control, and any ownership; 

4. 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 Defendant Schwartz; 

5. identify all of Defendant Schwartz's businesses by all of their names, telephone 

numbers, and physical, postal, email, and Internet addresses; 

6. 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 Defendant Schwartz must describe if he knows or should know due to 

his own involvement); 

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7. describe in detail whether and how Defendant Schwartz is in compliance with each 

Section of this Order; and 

8. provide a copy of each Order Acknowledgment obtained pursuant to this Order, 

unless previously submitted to the Commission. 

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

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

1. name, including aliases or fictitious name, or residence address; 

2. title or role in any business activity, including any business for which Defendant 

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

Defendant Schwartz has any ownership interest, and identify the name, physical address, 

and any Internet address of the business or entity; 

3. any designated point of contact; or 

4. the structure of any entity that Defendant Schwartz 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. 

C. Defendant Schwartz must submit to the Commission notice of the filing of any bankruptcy 

petition, insolvency proceeding, or similar proceeding by or against him 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 

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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. Schwartz, XI00042. 

IX. RECORDKEEPING 

IT IS FURTHER ORDERED that Defendant Schwartz must create certain records for 5 

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

Schwartz for any business that he, 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; 

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. 

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X. COMPLIANCE MONITORING 

IT IS FURTHER ORDERED that, for the purpose of monitoring Defendant Schwartz's 

compliance with this Order, including the financial representations upon which part of the 

judgment was suspended and any failure to transfer any assets as required by this Order: 

A. Within 14 days of receipt of a written request from a representative of the Commission, 

Defendant Schwartz 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, 30 

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

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

with Defendant Schwartz. Defendant Schwartz must permit representatives of the Commission 

to interview any employee or other person affiliated with him 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 Defendant Schwartz or 

any individual or entity affiliated with Defendant Schwartz, 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 Defendant Schwartz, pursuant to Section 

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

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XI. RETENTION OF JURISDICTION 

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

of construction, modification, and enforcement of this Order. 

SO ORDERED this __ 

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 

l Bowling Green, Suite 318 

New York, NY 10004 

212-607-282 l 

212-607-2822 (fax) 

koconnell@ftc.gov 

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Case 1:10-cv-03551-ILG-RLM Document 499 Filed 12/09/21 Page 18 of 18 PagelD #: 30043 

FOR DEFENDANT SCHWARTZ: 

?L-:- ?__... _ 

Martin R_ Raskin 

Raskin & Raskin, p.A. 

Miami Office 

Suntrust Plaza 

201 Alhambra Circle 

Suite 1050 

Coral Gables, Florida 33134 

305-444-3400 

mraskin@raskinlaw.com 

DEFENDANT SCHWARTZ: 

Date:~/ J0HN SCHWARTZ, INDIVIDUALLY 

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