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IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF MICHIGAN

FEDERAL TRADE COMMISSION,

Case No. 2:22-cv-11120

Plaintiff,

Hon. Bernard A. Friedman

v.

FINANCIAL EDUCATION

SERVICES, INC., et al.,

Defendants.

TEMPORARY RESTRAINING ORDER

Plaintiff, the Federal Trade Commission (“FTC”), has filed its Complaint for

Permanent Injunction, Monetary Relief, and Other Relief pursuant to Sections

13(b) and 19 of the FTC Act, 15 U.S.C. §§ 53(b) and 57b, Section 410(b) of the

Credit Repair Organizations Act (“CROA”), 15 U.S.C. § 1679h(b), and Section

6(b) of the Telemarketing and Consumer Fraud and Abuse Prevention Act, 15

U.S.C. § 6105(b), and has moved, pursuant to Fed. R. Civ. P. 65(b), for a

temporary restraining order, asset freeze, appointment of receiver, and other

equitable relief.

FINDINGS OF FACT

The Court, having considered the Complaint, the ex parte Motion for a

Temporary Restraining Order, declarations, exhibits, and the memorandum of

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points and authorities filed in support thereof, and being otherwise advised, finds

that:

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

good cause to believe that it will have jurisdiction over all parties hereto and

that venue in this district is proper.

B. There is good cause to believe that:

1. in numerous instances, in connection with the marketing, telemarketing, and

sale of credit repair services, Defendants have falsely represented that they

can significantly improve consumers’ credit scores by, among other things,

removing permanently negative information from consumers’ credit reports

or profiles or adding positive payment history to consumers’ credit reports or

profiles;

2. in numerous, in connection with the marketing, telemarketing, and sale of

credit repair services, Defendants have taken advanced fees for their credit

repair services;

3. in numerous instances, in connection with the marketing, telemarketing, and

sale of credit repair services, Defendants have not made required disclosures

regarding those services; and

4. Defendants operated and promoted a marketing scheme in which they

appear to have:

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a. operating an illegal pyramid scheme;

b. in numerous instances, falsely representing that consumers who become

agents (“FES Agents”) to recruit new FES Agents will earn substantial

income; and

c. providing the means and instrumentalities for the commission of

deceptive acts and practices by furnishing consumers with promotional

materials to be used in marketing credit repair services and recruiting

new FES Agents.

C. There is good cause to believe that Defendants have engaged in and are likely

to engage in acts or practices that violate Section 5 of the FTC Act, 15 U.S.C.

§ 45, multiple provisions of CROA, 15 U.S.C. §§ 1679-1679l, and multiple

provisions of the FTC’s Telemarketing Sales Rule (“TSR”), 16 C.F.R. Part 310,

and that the FTC is therefore likely to prevail on the merits of this action. As

demonstrated by consumer declarations, consumer complaints, and the

additional documentation filed by the FTC, the FTC has established a

likelihood of success in showing that Defendants have made false, misleading,

and deceptive representations regarding their credit repair services, taken illegal

advance fees for those services, failed to make required disclosures regarding

those services, operated an illegal pyramid scheme, made false, misleading, and

deceptive representations regarding their investment opportunity, and provided

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consumers with the means and instrumentalities to commit deceptive acts and

practices.

D. There is good cause to believe that Defendants have taken in gross revenues of

approximately $467 million as a result of their unlawful practices.

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

from Defendants’ ongoing violations of the FTC Act, CROA, and the TSR

unless Defendants are restrained and enjoined by order of this Court.

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

Court’s ability to grant effective final relief for consumers—including

rescission or reformation of contracts and the refund of money or return of

property—will occur from the sale, transfer, destruction or other disposition or

concealment by Defendants of their assets or records, unless Defendants are

immediately restrained and enjoined by order of this Court; and that, in

accordance with Fed. R. Civ. P. 65(b), the interests of justice require that this

Order be granted without prior notice to Defendants. Thus, there is good cause

for relieving the FTC of the duty to provide Defendants with prior notice of its

Motion for a Temporary Restraining Order.

G. Good cause exists for appointing a temporary receiver over the Receivership

Entities, freezing Defendants’ assets, permitting the FTC and the Receiver

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immediate access to the Defendants’ business premises, and permitting the FTC

and the Receiver to take expedited discovery.

H. Weighing the equities and considering the FTC’s likelihood of ultimate success

on the merits, a temporary restraining order with an asset freeze, immediate

access to business premises, expedited discovery, and other equitable relief is in

the public interest.

I. This Court has authority to issue this Order pursuant to Section 13(b) of the

FTC Act, 15 U.S.C. § 53(b); Federal Rule of Civil Procedure 65; and the All

Writs Act, 28 U.S.C. § 1651.

J. No security is required of any agency of the United States for issuance of a

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

DEFINITIONS

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

A. “Asset” means any legal or equitable interest in, right to, or claim to, any

property, wherever located and by whomever held.

B. “Consumer” means any Person.

C. “Corporate Defendants” means Financial Education Services, Inc., United

Wealth Services, Inc., VR-Tech, LLC, VR-Tech Mgt, LLC, CM Rent Inc., and

Youth Financial Literacy Foundation. and each of their subsidiaries, affiliates,

successors, and assigns.

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D. “Credit Repair Service” means any service, in return for payment of money or

other valuable consideration, for the express or implied purpose of: (1)

improving any consumer’s credit report, credit record, credit history, credit

profile, credit score, or credit rating; or (2) providing advice or assistance to any

consumer with regard to any activity or service the purpose of which is to

improve a consumer’s credit report, credit record, credit history, credit profile,

credit score, or credit rating.

E. “Defendants” means Corporate Defendants and Individual Defendants,

individually, collectively, or in any combination.

F. “Document” is synonymous in meaning and equal in scope to the usage of

“document” and “electronically stored information” in Federal Rule of Civil

Procedure 34(a), Fed. R. Civ. P. 34(a), and includes writings, drawings, graphs,

charts, photographs, sound and video recordings, images, Internet sites, web

pages, websites, electronic correspondence, including e-mail and instant

messages, contracts, accounting data, advertisements, FTP Logs, Server Access

Logs, books, written or printed records, handwritten notes, telephone logs,

telephone scripts, receipt books, ledgers, personal and business canceled checks

and check registers, bank statements, appointment books, computer records,

customer or sales databases and any other electronically stored information,

including Documents located on remote servers or cloud computing systems,

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and other data or data compilations from which information can be obtained

directly or, if necessary, after translation into a reasonably usable form. A draft

or non-identical copy is a separate document within the meaning of the term.

G. “Electronic Data Host” means any person or entity in the business of storing,

hosting, or otherwise maintaining electronically stored information. This

includes, but is not limited to, any entity hosting a website or server, and any

entity providing “cloud based” electronic storage.

H. “Individual Defendants” means Parimal Naik, Michael Toloff, Christopher

Toloff, and Gerald Thompson, individually, collectively, or in any combination.

I. “Marketing Program” includes, but is not limited to, any multi-level, affiliate,

or network marketing program, business opportunity, pyramid marketing

scheme, Ponzi scheme, or chain marketing scheme.

J. “Person” means a natural person, an organization or other legal entity,

including a corporation, partnership, sole proprietorship, limited liability

company, association, cooperative, or any other group or combination acting as

an entity.

K. “Public Health and Safety Event” means (1) any public health or safety

emergency announced or declared by any federal, state, or local governmental

authority or (2) the existence of any order, regulation, or action by any federal,

state, or local government authority relating to public health or safety governing

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or otherwise restricting public or commercial activity, such as a quarantine or

stay-at-home order.

L. “Receiver” means the temporary receiver appointed in Section XII of this

Order and any deputy receivers that shall be named by the temporary receiver.

M. “Receivership Entities” means Corporate Defendants as well as any other

entity that has conducted any business related to Defendants’ credit repair

services or investment opportunity, including receipt of Assets derived from

any activity that is the subject of the Complaint in this matter, and that the

Receiver determines is controlled or owned by any Defendant.

ORDER

PROHIBITED CREDIT REPAIR ACTIVITIES

I.

IT IS THEREFORE ORDERED that, until further order of this Court,

Defendants, Defendants’ officers, agents, employees, and attorneys, and all

other persons in active concert or participation with them, who receive actual

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

indirectly, in connection with the advertising, marketing, promoting, offering

for sale, providing, or performing of any Credit Repair Service, are temporarily

restrained and enjoined from:

A. Misrepresenting or assisting others in misrepresenting, directly or indirectly,

expressly or by implication:

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1. That any Person can remove negative information or hard inquiries from

any other Person’s credit report, credit record, credit history, credit

profile;

2. That any Person will report any other Person’s rent payment history or

other positive payment history to any consumer reporting agency or any

other Person;

3. That any Person can substantially improve any other Person’s credit

score or credit rating;

4. That any Person is or was a victim of identity theft;

5. That any Person is an additional authorized user on any other Person’s

credit card or line of credit account;

6. That any credit building product will substantially improve any Person’s

credit score or credit rating; or

7. Any other fact material to consumers concerning any Credit Repair

Service, such as the total costs; any material restrictions, limitations, or

conditions; or any material aspect of its performance, efficacy, nature, or

central characteristics;

B. Filing, causing to be filed, or encouraging any Person to file, with any other

Person an identity theft report;

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C. Charging or receiving money or other valuable consideration for the

performance of any Credit Repair Service before such service is fully

performed;

D. Failing to provide any Person with a written statement of “Consumer Credit

File Rights Under State and Federal Law,” in the form and manner required

by Section 405(a) of CROA, 15 U.S.C. § 1679c(a);

E. Failing to provide any Person with a written and dated contract which meets

the requirements of Section 406(b) of CROA, 15 U.S.C. § 1679d(b);

F. Failing to include in contracts for any Credit Repair Service the following

required terms and conditions: (1) the terms and conditions of payment,

including the total amount of all payments to be made by the consumer; (2) a

full and detailed description of the services to be performed for the

consumer, including all guarantees of performance and an estimate of the

date by which the performance of the services (to be performed by

Defendants or any other Person) will be complete or the length of the period

necessary to perform such services, (3) the name and principal business

address of Defendants or any other Person providing such services, and (4)

the specific conspicuous statement in bold face type, in immediate proximity

to the space reserved for the consumer’s signature on the contract, which

reads as follows: “You may cancel this contract without penalty or

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obligation at any time before midnight of the 3rd business day after the date

on which you signed the contract. See the attached notice of cancellation

form for an explanation of this right.”

G. Failing to provide any Person with a separate form with the heading “Notice

of Cancellation,” in the form and manner required by Section 407(b) of

CROA, 15 U.S.C. § 1679e(b); and

H. Failing to provide any Person with a copy of a completed contract and all

disclosures required under CROA and a copy of any other document such

Person is required to sign.

PROHIBITED MARKETING PROGRAM ACTIVITIES

II.

IT IS FURTHER ORDERED that, until further order of this Court,

Defendants, Defendants’ officers, agents, employees, and attorneys, and all

other persons in active concert or participation with them, who receive actual

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

indirectly, in connection with the advertising, marketing, promoting, or offering

for sale of any Marketing Program, are temporarily restrained and enjoined

from:

A. Engaging in, participating in, assisting others, or providing others with the

means and instrumentalities to engage or participate in, any Marketing

Program that:

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1. Pays compensation for recruiting new members;

2. Encourages, incentivizes, or requires members to purchase goods or

services to obtain or maintain eligibility for bonuses, rewards, or

commissions;

3. Induces others to encourage or incentivize members to purchase goods or

services to obtain or maintain eligibility for bonuses, rewards, or

commissions;

4. Pays any compensation related to the purchase or sale of goods or

services unless such compensation is for sales to or purchases by persons

who are not members of the Marketing Program and who are not being

recruited to become members of the Marketing Program;

5. Fails to monitor and take all reasonable steps necessary to ensure than

any compensation paid is for sales to or purchases by persons who are

not members of the Marketing Program and who are not being recruited

to become members of the Marketing Program;

6. Constitutes a pyramid scheme or chain marketing scheme;

B. Misrepresenting or assisting others in misrepresenting, directly or indirectly,

expressly or by implication:

1. that consumers who participate in any Marketing Program will receive or

are likely to receive substantial income; or

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2. Any other fact material to consumers concerning any Marketing

Program, such as the total costs; any material restrictions, limitations, or

conditions; or any material aspect of its performance, efficacy, nature, or

central characteristics.

PROHIBITION ON RELEASE OF CUSTOMER INFORMATION

III.

IT IS FURTHER ORDERED that, until further order of this Court,

Defendants, Defendants’ 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 hereby

temporarily restrained and enjoined from:

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

address, birth date, telephone number, email address, credit card number,

bank account number, Social Security number, or other financial or

identifying information of any person that any Defendant obtained in

connection with any activity that pertains to the subject matter of this Order;

and

B. Benefitting from or using the name, address, birth date, telephone number,

email address, credit card number, bank account number, Social Security

number, or other financial or identifying information of any person that any

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Defendant obtained in connection with any activity that pertains to the

subject matter of this Order.

C. Provided, however, that Defendants may disclose such identifying

information to a law enforcement agency, to their attorneys as required for

their defense, as required by any law, regulation, or court order, or in any

filings, pleadings or discovery in this action in the manner required by the

Federal Rules of Civil Procedure and by any protective order in the case.

ASSET FREEZE

IV.

IT IS FURTHER ORDERED that, until further order of this Court,

Defendants and their 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 hereby

temporarily restrained and enjoined from:

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

selling, concealing, dissipating, disbursing, assigning, relinquishing,

spending, withdrawing, granting a lien or security interest or other interest

in, or otherwise disposing of any Assets that are:

1. owned or controlled, directly or indirectly, by any Defendant;

2. held, in part or in whole, for the benefit of any Defendant;

3. in the actual or constructive possession of any Defendant; or

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4. owned or controlled by, in the actual or constructive possession of, or

otherwise held for the benefit of, any corporation, partnership, asset

protection trust, or other entity that is directly or indirectly owned,

managed or controlled by any Defendant.

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;

C. Incurring charges or cash advances on any credit, debit, or ATM card issued

in the name, individually or jointly, of any Corporate Defendant or any

corporation, partnership, or other entity directly or indirectly owned,

managed, or controlled by any Defendant or of which any Defendant is an

officer, director, member, or manager. This includes any corporate bankcard

or corporate credit card account for which any Defendant is, or was on the

date that this Order was signed, an authorized signor; or

D. Cashing any checks or depositing any money orders or cash received from

consumers, clients, or customers of any Defendant.

E. The Assets affected by this Section shall include: (1) all Assets of

Defendants as of the time this Order is entered; and (2) Assets obtained by

Defendants after this Order is entered if those Assets are derived from any

activity that is the subject of the Complaint in this matter or that is

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prohibited by this Order. This Section does not prohibit any repatriation of

foreign Assets specifically required by this order.

DUTIES OF ASSET HOLDERS AND OTHER THIRD PARTIES

V.

IT IS FURTHER ORDERED that, until further order of this Court, any

financial or brokerage institution, Electronic Data Host, credit card processor,

payment processor, merchant bank, acquiring bank, independent sales

organization, third party processor, payment gateway, insurance company,

business entity, or person who receives actual notice of this Order (by service or

otherwise) that: (a) has held, controlled, or maintained custody, through an

account or otherwise, of any Document on behalf of any Defendant or any

Asset that has been owned or controlled, directly or indirectly, by any

Defendant; held, in part or in whole, for the benefit of any Defendant; in the

actual or constructive possession of any Defendant; or owned or controlled by,

in the actual or constructive possession of, or otherwise held for the benefit of,

any corporation, partnership, asset protection trust, or other entity that is

directly or indirectly owned, managed or controlled by any Defendant; (b) has

held, controlled, or maintained custody, through an account or otherwise, of any

Document or Asset associated with credits, debits, or charges made on behalf of

any Defendant, including reserve funds held by payment processors, credit card

processors, merchant banks, acquiring banks, independent sales organizations,

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third party processors, payment gateways, insurance companies, or other

entities; or (c) has extended credit to any Defendant, including through a credit

card account, shall:

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

removal, alteration, assignment, transfer, pledge, encumbrance,

disbursement, dissipation, relinquishment, conversion, sale, or other disposal

of any such Document or Asset, as well as all Documents or other property

related to such Assets, except by further order of this Court or as directed in

writing by the Receiver regarding Assets or Documents owned by, held in

the name of, for the benefit of, or otherwise controlled by any Receivership

Entity; provided, however, that this provision does not prohibit an Individual

Defendant from incurring charges on a personal credit card established prior

to entry of this Order, up to the pre-existing credit limit;

B. Deny any person except the Receiver access to any safe deposit box,

commercial mail box, or storage facility that is titled in the name of any

Defendant, either individually or jointly, or otherwise subject to access by

any Defendant;

C. Provide FTC counsel and the Receiver, within three (3) days of receiving a

copy of this Order, a sworn statement setting forth, for each Asset or account

covered by this Section:

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1. The identification number of each such account or Asset;

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

value of each such Asset as of the close of business on the day on which

this Order is served, and, if the account or other Asset has been closed or

removed, the date closed or removed, the total funds removed in order to

close the account, and the name of the person or entity to whom such

account or other Asset was remitted; and

3. The identification 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 by any Defendant; and

D. Upon the request of the Receiver, promptly provide him with copies of all

records or other Documents pertaining to any account covered by this

Section or Asset, including originals or copies of account applications,

account statements, signature cards, checks, drafts, deposit tickets, transfers

to and from the accounts, including wire transfers and wire transfer

instructions, all other debit and credit instruments or slips, currency

transaction reports, 1099 forms, and all logs and records pertaining to safe

deposit boxes, commercial mail boxes, and storage facilities.

E. Provided, however, that this Section does not prohibit any repatriation of

foreign Assets specifically required by this order.

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FINANCIAL DISCLOSURES AND ACCOUNTING

VI.

IT IS FURTHER ORDERED that each Defendant, within five (5) days of

service of this Order upon them, shall prepare and deliver to FTC counsel and

the Receiver:

A. Completed financial statements on the forms attached to this Order as

Attachment A (Financial Statement of Individual Defendant) for Individual

Defendant, and Attachment B (Financial Statement of Corporate

Defendant) for Corporate Defendant;

B. Completed Attachment C (IRS Form 4506, Request for Copy of a Tax

Return) for each Defendant; and

FOREIGN ASSET REPATRIATION

VII.

IT IS FURTHER ORDERED that within five (5) days following the service

of this Order, each Defendant shall:

A. Provide the Receiver with a full accounting, verified under oath and accurate

as of the date of this Order, of all Assets, Documents, and accounts outside

of the United States which are: (1) titled in the name, individually or jointly,

of any Defendant; (2) held by any person or entity for the benefit of any

Defendant or for the benefit of, any corporation, partnership, asset protection

trust, or other entity that is directly or indirectly owned, managed or

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controlled by any Defendant; or (3) under the direct or indirect control,

whether jointly or singly, of any Defendant;

B. Take all steps necessary to provide FTC counsel access to all Documents

and records that may be held by third parties located outside of the territorial

United States of America, including signing the Consent to Release of

Financial Records appended to this Order as Attachment D.

C. Transfer to the territory of the United States and all Documents and Assets

located in foreign countries which are: (1) titled in the name, individually or

jointly, of any Defendant; (2) held by any person or entity for the benefit of

any Defendant or for the benefit of, any corporation, partnership, asset

protection trust, or other entity that is directly or indirectly owned, managed

or controlled by any Defendant; or (3) under the direct or indirect control,

whether jointly or singly, of any Defendant; and

D. The same business day as any repatriation, (1) notify FTC counsel of the

name and location of the financial institution or other entity that is the

recipient of such Documents or Assets; and (2) serve this Order on any such

financial institution or other entity.

NON-INTERFERENCE WITH REPATRIATION

VIII.

IT IS FURTHER ORDERED that, until further order of this Court,

Defendants, Defendants’ officers, agents, employees, and attorneys, and all

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

actual notice of this Order, whether acting directly or indirectly, 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 this Order, including,

but not limited to:

A. Sending any communication 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 all Defendants’ Assets have been fully

repatriated pursuant to this Order; or

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 a court order, until such time that all

Defendants’ Assets have been fully repatriated pursuant to this Order.

CONSUMER CREDIT REPORTS

IX.

IT IS FURTHER ORDERED that the FTC may obtain credit reports

concerning any Defendants pursuant to Section 604(a)(1) of the Fair Credit

Reporting Act, 15 U.S.C. 1681b(a)(1), and that, upon written request, any credit

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reporting agency from which such reports are requested shall provide them to

the FTC.

PRESERVATION OF RECORDS

X.

IT IS FURTHER ORDERED that, until further order of this Court,

Defendants, Defendants’ 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 hereby

temporarily restrained and enjoined from:

A. Destroying, erasing, falsifying, writing over, mutilating, concealing, altering,

transferring, or otherwise disposing of, in any manner, directly or indirectly,

Documents that relate to: (1) the business, business practices, Assets, or

business or personal finances of any Defendant; (2) the business practices or

finances of entities directly or indirectly under the control of any Defendant;

or (3) the business practices or finances of entities directly or indirectly

under common control with any other Defendant; and

B. Failing to create and maintain Documents that, in reasonable detail,

accurately, fairly, and completely reflect Defendants’ incomes,

disbursements, transactions, and use of Defendants’ Assets.

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REPORT OF NEW BUSINESS ACTIVITY

XI.

IT IS FURTHER ORDERED that, until further order of this Court,

Defendants, Defendants’ 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 hereby

temporarily restrained and enjoined from creating, operating, or exercising any

control over any business entity, whether newly formed or previously inactive,

including any partnership, limited partnership, joint venture, sole

proprietorship, or corporation, without first providing FTC counsel with a

written statement disclosing: (1) the name of the business entity; (2) the

address and telephone number 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.

APPOINTMENT OF TEMPORARY RECEIVER

XII.

IT IS FURTHER ORDERED that Patrick A. Miles, Jr. is appointed as

temporary receiver of the Receivership Entities with full powers of an equity

receiver. The Receiver shall be solely the agent of this Court in acting as

Receiver under this Order.

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DUTIES AND AUTHORITIES OF RECEIVER

XIII.

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

accomplish the following:

A. Assume full control of Receivership Entities by removing, as the Receiver

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

employee, attorney, or agent of any Receivership Entity from control of,

management of, or participation in, the affairs of the Receivership Entity;

B. Take exclusive custody, control, and possession of all Assets and

Documents of, or in the possession, custody, or under the control of, any

Receivership Entity, wherever situated;

C. Take exclusive custody, control, and possession of all Documents or Assets

associated with credits, debits, or charges made on behalf of any

Receivership Entity, wherever situated, including reserve funds held by

payment processors, credit card processors, merchant banks, acquiring

banks, independent sales organizations, third party processors, payment

gateways, insurance companies, or other entities;

D. Conserve, hold, manage, and prevent the loss of all Assets of the

Receivership Entities, and perform all acts necessary or advisable to

preserve the value of those Assets. The Receiver shall assume control over

the income and profits therefrom and all sums of money now or hereafter

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due or owing to the Receivership Entities. The Receiver shall have full

power to sue for, collect, and receive, all Assets of the Receivership Entities

and of other persons or entities whose interests are now under the direction,

possession, custody, or control of, the Receivership Entities. Provided,

however, that the Receiver shall not attempt to collect any amount from a

consumer if the Receiver believes the consumer’s debt to the Receivership

Entities has resulted from the deceptive acts or practices or other violations

of law alleged in the Complaint in this matter, without prior Court approval;

E. Obtain, conserve, hold, manage, and prevent the loss of all Documents of the

Receivership Entities, and perform all acts necessary or advisable to

preserve such Documents. The Receiver shall: divert mail; preserve all

Documents of the Receivership Entities that are accessible via electronic

means (such as online access to financial accounts and access to electronic

documents held onsite or by Electronic Data Hosts, by changing usernames,

passwords or other log-in credentials; take possession of all electronic

Documents of the Receivership Entities stored onsite or remotely; take

whatever steps necessary to preserve all such Documents; and obtain the

assistance of the FTC’s Digital Forensic Unit, or retain an expert, for the

purpose of obtaining electronic documents stored onsite or remotely.

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F. 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;

G. 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, and to incur, or authorize the making of,

such agreements as may be necessary and advisable in discharging his or her

duties as Receiver. The Receiver shall apply to the Court for prior approval

of any payment of any debt or obligation incurred by the Receivership

Entities prior to the date of entry of this Order, except payments that the

Receiver deems necessary or advisable to secure Assets of the Receivership

Entities, such as rental payments;

H. Take all steps necessary to secure and take exclusive custody of each

location from which the Receivership Entities operate their businesses. Such

steps may include, but are not limited to, any of the following, as the

Receiver deems necessary or advisable: (1) securing the location by

changing the locks and alarm codes and disconnecting any internet access or

other means of access to the computers, servers, internal networks, or other

records maintained at that location; and (2) requiring any persons present at

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the location to leave the premises, to provide the Receiver with proof of

identification, and/or to demonstrate to the satisfaction of the Receiver that

such persons are not removing from the premises Documents or Assets of

the Receivership Entities. Law enforcement personnel, including, but not

limited to, police or sheriffs, may assist the Receiver in implementing these

provisions in order to keep the peace and maintain security. If requested by

the Receiver, the United States Marshal will provide appropriate and

necessary assistance to the Receiver to implement this Order and is

authorized to use any necessary and reasonable force to do so;

I. Take all steps necessary to prevent the modification, destruction, or erasure

of any web page or website registered to and operated, in whole or in part,

by any Defendants, and to provide access to all such web page or websites to

the FTC’s representatives, agents, and assistants, as well as Defendants and

their representatives;

J. Enter into and cancel contracts and purchase insurance as advisable or

necessary;

K. Prevent the inequitable distribution of Assets and determine, adjust, and

protect the interests of consumers who have transacted business with the

Receivership Entities;

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L. Make an accounting, as soon as practicable, of the Assets and financial

condition of the receivership and file the accounting with the Court and

deliver copies thereof to all parties;

M. Institute, compromise, adjust, appear in, intervene in, defend, dispose of, or

otherwise become party to any legal action in state, federal or foreign courts

or arbitration proceedings as the Receiver deems necessary and advisable to

preserve or recover the Assets of the Receivership Entities, or to carry out

the Receiver’s mandate under this Order, including but not limited to,

actions challenging fraudulent or voidable transfers;

N. Issue subpoenas to obtain Documents and records pertaining to the

Receivership, and conduct discovery in this action on behalf of the

receivership estate, in addition to obtaining other discovery as set forth in

this Order;

O. Open one or more bank accounts at designated depositories for funds of the

Receivership Entities. The Receiver shall deposit all funds of the

Receivership Entities in such designated accounts and shall make all

payments and disbursements from the receivership estate from such

accounts. The Receiver shall serve copies of monthly account statements on

all parties;

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P. Maintain accurate records of all receipts and expenditures incurred as

Receiver;

Q. Allow the FTC’s representatives, agents, and assistants, as well as

Defendants’ representatives and Defendants themselves, reasonable access

to the premises of the Receivership Entities, or any other premises where the

Receivership Entities conduct business. 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 Entities

or their agents. The Receiver shall have the discretion to determine the time,

manner, and reasonable conditions of such access;

R. Allow the FTC’s representatives, agents, and assistants, as well as

Defendants and their representatives reasonable access to all Documents in

the possession, custody, or control of the Receivership Entities;

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

state or federal civil or criminal law enforcement agency;

T. Suspend business operations of the Receivership Entities if in the judgment

of the Receiver such operations cannot be continued legally and profitably;

U. If the Receiver identifies a nonparty entity as a Receivership Entity,

promptly notify the entity as well as the parties, and inform the entity that it

can challenge the Receiver’s determination by filing a motion with the

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Court. Provided, however, that the Receiver may delay providing such

notice until the Receiver has established control of the nonparty entity and

its assets and records, if the Receiver determines that notice to the entity or

the parties before the Receiver establishes control over the entity may result

in the destruction of records, dissipation of assets, or any other obstruction

of the Receiver’s control of the entity; and

V. If in the Receiver’s judgment the business operations cannot be continued

legally and profitably, take all steps necessary to ensure that any of the

Receivership Entities’ web pages or websites relating to the activities

alleged in the Complaint cannot be accessed by the public, or are modified

for consumer education and/or informational purposes, and take all steps

necessary to ensure that any telephone numbers associated with the

Receivership Entities cannot be accessed by the public, or are answered

solely to provide consumer education or information regarding the status of

operations.

W.Provided, however, that the Receiver may delay undertaking any of the

duties set forth in this Section XV to the extent that the Receiver determines

that a Public Health or Safety Event prevents the Receiver from undertaking

such duties safely; and provided, further, that any such delay shall not be

deemed a failure of the Receiver to exercise his or her obligations.

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TRANSFER OF RECEIVERSHIP PROPERTY TO RECEIVER

XIV.

IT IS FURTHER ORDERED that Defendants and any other person, with

possession, custody or control of property of, or records relating to, the

Receivership Entities shall, upon notice of this Order by personal service or

otherwise, fully cooperate with and assist the Receiver in taking and

maintaining possession, custody, or control of the Assets and Documents of the

Receivership Entities and immediately transfer or deliver to the Receiver

possession, custody, and control of, the following:

A. All Assets held by or for the benefit of the Receivership Entities;

B. All Documents or Assets associated with credits, debits, or charges made on

behalf of any Receivership Entity, wherever situated, including reserve

funds held by payment processors, credit card processors, merchant banks,

acquiring banks, independent sales organizations, third party processors,

payment gateways, insurance companies, or other entities;

C. All Documents of or pertaining to the Receivership Entities;

D. All computers, electronic devices, mobile devices and machines used to

conduct the business of the Receivership Entities;

E. All Assets and Documents belonging to other persons or entities whose

interests are under the direction, possession, custody, or control of the

Receivership Entities; and

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F. All keys, codes, user names and passwords necessary to gain or to secure

access to any Assets or Documents of or pertaining to the Receivership

Entities, including access to their business premises, means of

communication, accounts, computer systems (onsite and remote), Electronic

Data Hosts, or other property.

G. In the event that any person or entity fails to deliver or transfer any Asset or

Document, or otherwise fails to comply with any provision of this Section,

the Receiver may file an Affidavit of Non-Compliance regarding the failure

and a motion seeking compliance or a contempt citation.

PROVISION OF INFORMATION TO RECEIVER

XV.

IT IS FURTHER ORDERED that Defendants shall immediately provide to

the Receiver:

A. A list of all Assets and accounts of the Receivership Entities that are held in

any name other than the name of a Receivership Entity, or by any person or

entity other than a Receivership Entity;

B. A list of all agents, employees, officers, attorneys, servants and those

persons in active concert and participation with the Receivership Entities, or

who have been associated or done business with the Receivership Entities;

and

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C. A description of any documents covered by attorney-client privilege or

attorney work product, including files where such documents are likely to be

located, authors or recipients of such documents, and search terms likely to

identify such electronic documents.

COOPERATION WITH THE RECEIVER

XVI.

IT IS FURTHER ORDERED that Defendants; Receivership Entities;

Defendants’ or Receivership Entities’ officers, agents, employees, and

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

and any other person with possession, custody, or control of property of or

records relating to the Receivership entities who receive actual notice of this

Order shall fully cooperate with and assist the Receiver. This cooperation and

assistance shall include, but is not limited to, providing information to the

Receiver that the Receiver deems necessary to exercise the authority and

discharge the responsibilities of the Receiver under this Order; providing any

keys, codes, user names and passwords required to access any computers,

electronic devices, mobile devices, and machines (onsite or remotely) and any

cloud account (including specific method to access account) or electronic file in

any medium; advising all persons who owe money to any Receivership Entity

that all debts should be paid directly to the Receiver; and transferring funds at

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the Receiver’s direction and producing records related to the Assets and sales of

the Receivership Entities.

NON-INTERFERENCE WITH THE RECEIVER

XVII.

IT IS FURTHER ORDERED that, until further order of this Court,

Defendants; Receivership Entities; Defendants’ or Receivership Entities’

officers, agents, employees, attorneys, and all other persons in active concert or

participation with any of them, who receive actual notice of this Order, and any

other person served with a copy of this Order, are hereby restrained and

enjoined from directly or indirectly:

A. Interfering with the Receiver’s efforts to manage, or take custody, control, or

possession of, the Assets or Documents subject to the receivership;

B. Transacting any of the business of the Receivership Entities;

C. Transferring, receiving, altering, selling, encumbering, pledging, assigning,

liquidating, or otherwise disposing of any Assets owned, controlled, or in the

possession or custody of, or in which an interest is held or claimed by, the

Receivership Entities; or

D. Refusing 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.

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STAY OF ACTIONS

XVIII.

IT IS FURTHER ORDERED that:

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

ordered herein, Defendants, Defendants’ officers, agents, employees,

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

of them, who receive actual notice of this Order, and their corporations,

subsidiaries, divisions, or affiliates, and all investors, creditors,

stockholders, lessors, customers and other persons seeking to establish or

enforce any claim, right, or interest against or on behalf of Defendants,

and all others acting for or on behalf of such persons, are hereby enjoined

from taking action that would interfere with the exclusive jurisdiction of

this Court over the Assets or Documents of the Receivership Entities,

including, but not limited to:

1. Filing or assisting in the filing of a petition for relief under the

Bankruptcy Code, 11 U.S.C. § 101 et seq., or of any similar

insolvency proceeding on behalf of the Receivership Entities;

2. Commencing, prosecuting, or continuing a judicial, administrative, or

other action or proceeding against the Receivership Entities, including

the issuance or employment of process against the Receivership

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Entities, except that such actions may be commenced if necessary to

toll any applicable statute of limitations; or

3. Filing or enforcing any lien on any asset of the Receivership Entities,

taking or attempting to take possession, custody, or control of any

Asset of the Receivership Entities; or attempting to foreclose, forfeit,

alter, or terminate any interest in any Asset of the Receivership

Entities, whether such acts are part of a judicial proceeding, are acts of

self-help, or otherwise; or

B. The Receiver and his agents acting within the scope of such agency

(“Retained Personnel”) are entitled to rely on all outstanding rules of law

and orders of this Court and shall not be liable to anyone for their own

good faith compliance with any order, rule, law, judgment, or decree. In

no event shall the Receiver or any Retained Personnel be liable to anyone

for their acts or omissions or their good faith compliance with their duties

and responsibilities, except as a result of a finding by this Court that they

acted or failed to act as a result of malfeasance, bad faith, gross

negligence or in reckless disregard of their duties. Any party, person, or

entity (except the FTC) seeking recovery from the Receiver or any

Retained Personnel for conduct in the course of the administration of the

estate must first obtain leave from this Court. This Court shall retain

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jurisdiction over any action filed against the Receiver or any Retained

Personnel based upon acts or omissions committed in their representative

capacities.

C. Provided, however, that this Order does not stay: (1) the commencement

or continuation of a criminal action or proceeding; (2) the

commencement or continuation of an action or proceeding by a

governmental unit to enforce such governmental unit’s police or

regulatory power; or (3) 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.

COMPENSATION OF RECEIVER

XIX.

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, in the possession or control of,

or which may be received by, the Receivership Entities. 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 entry of this Order. The Receiver shall not

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increase the hourly rates used as the bases for such fee applications without

prior approval of the Court.

RECEIVER’S BOND

XX.

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

Court a bond in the sum of $10,000 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. 28 U.S.C. § 754.

RECEIVER’S REPORTS

XXI.

IT IS FURTHER ORDERED that the Receiver shall report to this Court on or

before any date set for a hearing on whether a Preliminary Injunction should

issue, regarding (1) the steps taken by the Receiver to implement the terms of

this Order; (2) the value of all liquidated and unliquidated assets of the

Receivership Entities; (3) the sum of all liabilities of the Receivership Entities;

(4) the steps the Receiver intends to take in the future to (a) prevent any

diminution in the value of assets of the Receivership Entities, (b) pursue

receivership assets from third parties, and (c) adjust the liabilities of the

Receivership Entities, if appropriate; (5) whether the business of the

Receivership Entities can be operated lawfully and profitably; and (6) any other

matters that the Receiver believes should be brought to the Court’s attention.

Provided, however, that if any of the required information would hinder the

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Receiver’s ability to pursue receivership assets, the portions of the Receiver’s

report containing such information may be filed under seal and not served on

the parties.

IMMEDIATE ACCESS TO BUSINESS PREMISES AND RECORDS

XXII.

IT IS FURTHER ORDERED that:

A. In order to allow the FTC and the Receiver to preserve Assets and evidence

relevant to this action and to expedite discovery and unless the FTC or

Receiver determines that a Public Health or Safety Event makes it unsafe for

the FTC or the Receiver to do so, the FTC and the Receiver, and their

representatives, agents, contractors, and assistants, shall have immediate

access to the business premises and storage facilities, owned, controlled, or

used by the Receivership Entities. Such locations include, but are not

limited to, 37735 Enterprise Court, Farmington Hills, Michigan, and any

offsite location or commercial mailbox used by the Receivership Entities.

The Receiver may exclude Defendants, Receivership Entities, and their

employees from the business premises during the immediate access.

B. In the event of a Public Health or Safety Event, the Receiver may, if the

Receiver determines it safe to do so, enter any of Defendants’ business

premises after business hours. Any landlord, management office, security

office, or any other Person that controls access to any such business

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premises shall, immediately upon receiving notice of this order, cooperate

with the Receiver and take whatever steps necessary to allow the Receiver

access to such business premises after business hours; and such Persons are

prohibited from notifying Defendants of the existence of this Order or the

Receiver’s entry into the business premises until the Receiver has notified

such Persons in writing that the Receiver has secured such business

premises.

C. The FTC and the Receiver, and their representatives, agents, contractors, and

assistants, are authorized to remove Documents from the Receivership

Entities’ premises in order that they may be inspected, inventoried, and

copied. The FTC shall return any removed materials to the Receiver within

five (5) business days of completing inventorying and copying, or such time

as is agreed upon by the FTC and the Receiver;

D. The FTC’s access to the Receivership Entities’ documents pursuant to this

Section shall not provide grounds for any Defendant to object to any

subsequent request for documents served by the FTC.

E. The FTC and the Receiver, and their representatives, agents, contractors, and

assistants, are authorized to obtain the assistance of federal, state and local

law enforcement officers as they deem necessary to effect service and to

implement peacefully the provisions of this Order;

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F. If any Documents, computers, or electronic storage devices containing

information related to the business practices or finances of the Receivership

Entities are at a location other than those listed herein, including personal

residence(s) of any Defendant, then, immediately upon receiving notice of

this order, Defendants and Receivership Entities shall produce to the

Receiver all such Documents, computers, and electronic storage devices,

along with any codes or passwords needed for access. In order to prevent

the destruction of computer data, upon service of this Order, any such

computers or electronic storage devices shall be powered down in the

normal course of the operating system used on such devices and shall not be

powered up or used until produced for copying and inspection. Defendants

are precluded from introducing in any proceeding in this case any Document

not so produced.

G. If any communications or records of any Receivership Entity are stored with

an Electronic Data Host, such Entity shall, immediately upon receiving

notice of this order, provide the Receiver with the username, passwords, and

any other login credential needed to access the communications and records,

and shall not attempt to access, or cause a third-party to attempt to access,

the communications or records.

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DISTRIBUTION OF ORDER BY DEFENDANTS

XXIII.

IT IS FURTHER ORDERED that Defendants shall immediately provide a

copy of this Order to each affiliate, telemarketer, marketer, sales entity,

successor, assign, member, officer, director, employee, agent, independent

contractor, client, attorney, spouse, subsidiary, division, and representative of

any Defendant, and shall, within ten (10) days from the date of entry of this

Order, and provide FTC counsel and the Receiver with a sworn statement that

this provision of the Order has been satisfied, which statement shall include the

names, physical addresses, phone number, and email addresses of each such

person or entity who received a copy of the Order. Furthermore, Defendants

shall not take any action that would encourage officers, agents, members,

directors, employees, salespersons, independent contractors, attorneys,

subsidiaries, affiliates, successors, assigns or other persons or entities in active

concert or participation with them to disregard this Order or believe that they

are not bound by its provisions.

EXPEDITED DISCOVERY

XXIV.

IT IS FURTHER ORDERED that, notwithstanding the provisions of the Fed.

R. Civ. P. 26(d) and (f) and 30(a)(2)(A)(iii), and pursuant to Fed. R. Civ. P.

30(a), 34, and 45, the FTC and the Receiver are granted leave, at any time after

service of this Order, to conduct limited expedited discovery for the purpose of

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discovering: (1) the nature, location, status, and extent of Defendants’ Assets;

(2) the nature, location, and extent of Defendants’ business transactions and

operations; (3) Documents reflecting Defendants’ business transactions and

operations; or (4) compliance with this Order.

SERVICE OF THIS ORDER

XXV.

IT IS FURTHER ORDERED that copies of this Order as well as the Motion

for Temporary Restraining Order and all other pleadings, Documents, and

exhibits filed contemporaneously with that Motion (other than the complaint

and summons), may be served by any means, including facsimile transmission,

electronic mail or other electronic messaging, personal or overnight delivery,

U.S. Mail or FedEx, by agents and employees of the FTC, by any law

enforcement agency, or by private process server, upon any Defendant or any

person (including any financial institution) that may have possession, custody

or control of any Asset or Document of any Defendant, or that may be subject

to any provision of this Order pursuant to Rule 65(d)(2) of the Federal Rules of

Civil Procedure. For purposes of this Section, service upon any branch,

subsidiary, affiliate or office of any entity shall effect service upon the entire

entity.

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CORRESPONDENCE AND SERVICE ON THE FTC

XXVI.

IT IS FURTHER ORDERED that, for the purpose of this Order, all

correspondence and service of pleadings on the FTC shall be addressed to:

Gregory A. Ashe, K. Michelle Grajales, and Julia E. Heald, Federal Trade

Commission, 600 Pennsylvania Avenue NW, Room CC-10232, Washington,

D.C. 20580, email: gashe@ftc.gov, mgrajales@ftc.gov, and jheald@ftc.gov.

PRELIMINARY INJUNCTION HEARING

XXVII.

IT IS FURTHER ORDERED that:

A. The Motion for Temporary Restraining Order is also deemed to be a motion

for a preliminary injunction order, and that the FTC is not required to file or

serve a separate motion for a preliminary injunction in order to see the entry

of a preliminary injunction under Federal Rule of Civil Procedure 65.

B. The Court will consider all materials filed by the FTC in connection with the

Motion for Temporary Restraining Order to have been filed in connection

with the FTC’s motion for a preliminary injunction hearing. The FTC shall

be permitted, but is not required, to file a supplemental brief and supporting

exhibits in advance of any preliminary injunction hearing.

C. Defendants wishing to be heard on this matter may appear in this Court, on

the FTC’s motion for preliminary injunction, before the Honorable Judge

Bernard A. Friedman, at 2:00 p.m. on Monday, June 6, 2022 in

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Courtroom 110 of the United States District Court, Eastern District of

Michigan, 231 W Lafayette Blvd, Detroit, Michigan 48226, to show

cause, if there be any, why this Court should not enter a preliminary

injunction and order preliminary relief against them, pursuant to Rule 65 of

the Federal Rules of Civil Procedure, extending the temporary relief granted

in this Order pending a final adjudication on the merits.

D. This Order shall expire at 11:59 P.M. fourteen days following the entry of

this order, unless otherwise ordered by this Court.

RETENTION OF JURISDICTION

XXVIII.

IT IS FURTHER ORDERED that this Court shall retain jurisdiction of

this matter for all purposes.

IT SO ORDERED,

Dated: May 24, 2022

Detroit, Michigan

s/Bernard A. Friedman

Bernard A. Friedman

Senior United States District Judge

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ATTACHMENT A

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of 78COMMISSION

FEDERAL TRADE

FINANCIAL STATEMENT OF INDIVIDUAL DEFENDANT

Definitions and Instructions:

1. Complete all items. Enter “None” or “N/A” (“Not Applicable”) in the first field only of any item that does not apply

to you. If you cannot fully answer a question, explain why.

2. “Dependents” include your spouse, live-in companion, dependent children, or any other person, whom you or your

spouse (or your children’s other parent) claimed or could have claimed as a dependent for tax purposes at any

time during the past five years.

3. “Assets” and “Liabilities” include ALL assets and liabilities, located within the United States or any foreign country

or territory, whether held individually or jointly and whether held by you, your spouse, or your dependents, or held

by others for the benefit of you, your spouse, or your dependents.

4. Attach continuation pages as needed. On the financial statement, state next to the Item number that the Item is

being continued. On the continuation page(s), identify the Item number(s) being continued.

5. Type or print legibly.

6. Initial each page in the space provided in the lower right corner.

7. Sign and date the completed financial statement on the last page.

Penalty for False Information:

Federal law provides that any person may be imprisoned for not more than five years, fined, or both, if such person:

(1) “in any matter within the jurisdiction of the executive, legislative, or judicial branch of the Government of the

United States, knowingly and willfully falsifies, conceals or covers up by any trick, scheme, or devise a material fact;

makes any materially false, fictitious or fraudulent statement or representation; or makes or uses any false writing or

document knowing the same to contain any materially false, fictitious or fraudulent statement or entry” (18 U.S.C. § 1001);

(2) “in any . . . statement under penalty of perjury as permitted under section 1746 of title 28, United States Code,

willfully subscribes as true any material matter which he does not believe to be true” (18 U.S.C. § 1621); or

(3) “in any ( . . . statement under penalty of perjury as permitted under section 1746 of title 28, United States

Code) in any proceeding before or ancillary to any court or grand jury of the United States knowingly makes any false

material declaration or makes or uses any other information . . . knowing the same to contain any false material

declaration” (18 U.S.C. § 1623).

For a felony conviction under the provisions cited above, federal law provides that the fine may be not more than the

greater of (i) $250,000 for an individual or $500,000 for a corporation, or (ii) if the felony results in pecuniary gain to any

person or pecuniary loss to any person other than the defendant, the greater of twice the gross gain or twice the gross

loss. 18 U.S.C. § 3571.

Federal Trade Commission Financial Statement of Individual Defendant

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BACKGROUND INFORMATION

Item 1. Information About You

Full Name

Social Security No.

Current Address of Primary Residence

Driver’s License No.

State Issued

Date of Birth:

/

/

(mm/dd/yyyy)

Place of Birth

Phone Numbers

Home: (

)

Fax: (

)

Rent

Own

From (Date):

E-Mail Address

/

/

(mm/dd/yyyy)

Internet Home Page

Previous Addresses for past five years (if required, use additional pages at end of form)

Address

From:

/

/

(mm/dd/yyyy)

Rent

Address

From:

From:

Rent

/

/

(mm/dd/yyyy)

Own

/

Rent

Address

Until:

/

Until:

/

/

Until:

/

/

Own

/

/

Own

Identify any other name(s) and/or social security number(s) you have used, and the time period(s) during which they

were used:

Item 2. Information About Your Spouse or Live-In Companion

Spouse/Companion's Name

Social Security No.

Address (if different from yours)

Phone Number

(

Date of Birth

/

/

(mm/dd/yyyy)

Place of Birth

)

Rent

/

/

(mm/dd/yyyy)

Identify any other name(s) and/or social security number(s) you have used, and the time period(s) during which they were used:

Employer’s Name and Address

Own

From (Date):

Job Title

Years in Present Job

Annual Gross Salary/Wages

$

Item 3. Information About Your Previous Spouse

Name and Address

Social Security No.

Date of Birth

/

/

(mm/dd/yyyy)

Item 4. Contact Information (name and address of closest living relative other than your spouse)

Name and Address

Phone Number

(

)

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Item 5. Information About Dependents (whether or not they reside with you)

Name and Address

Social Security No.

Date of Birth

/

/

(mm/dd/yyyy)

Relationship

Name and Address

Social Security No.

Date of Birth

/

/

(mm/dd/yyyy)

Relationship

Name and Address

Date of Birth

/

/

(mm/dd/yyyy)

Social Security No.

Relationship

Name and Address

Date of Birth

/

/

(mm/dd/yyyy)

Social Security No.

Relationship

Item 6. Employment Information/Employment Income

Provide the following information for this year-to-date and for each of the previous five full years, for each business entity of which you were a director,

officer, member, partner, employee (including self-employment), agent, owner, shareholder, contractor, participant or consultant at any time during that

period. “Income” includes, but is not limited to, any salary, commissions, distributions, draws, consulting fees, loans, loan payments, dividends,

royalties, and benefits for which you did not pay (e.g., health insurance premiums, automobile lease or loan payments) received by you or anyone else

on your behalf.

Company Name and Address

Ownership Interest?

Yes

Dates Employed

Positions Held

$

$

To (Month/Year)

/

$

/

/

$

/

/

$

$

Income Received: Y-T-D & 5 Prior Yrs.

Year

Income

20

$

$

From (Month/Year)

/

To (Month/Year)

/

From (Month/Year)

/

To (Month/Year)

/

$

/

/

$

/

/

$

No

Company Name and Address

Yes

20

From (Month/Year)

/

Dates Employed

Positions Held

Ownership Interest?

Income

To (Month/Year)

/

Company Name and Address

Yes

Year

From (Month/Year)

/

No

Positions Held

Ownership Interest?

Income Received: Y-T-D & 5 Prior Yrs.

Dates Employed

$

Income Received: Y-T-D & 5 Prior Yrs.

Year

Income

20

$

$

From (Month/Year)

/

To (Month/Year)

/

From (Month/Year)

/

To (Month/Year)

/

$

/

/

$

/

/

$

No

$

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Federal Trade Commission Financial Statement of Individual Defendant

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Item 7. Pending Lawsuits Filed By or Against You or Your Spouse

List all pending lawsuits that have been filed by or against you or your spouse in any court or before an administrative agency in the United States or in

any foreign country or territory. Note: At Item 12, list lawsuits that resulted in final judgments or settlements in your favor. At Item 21, list lawsuits that

resulted in final judgments or settlements against you.

Nature of

Status or

Caption of Proceeding

Court or Agency and Location

Case No.

Relief Requested

Proceeding

Disposition

Item 8. Safe Deposit Boxes

List all safe deposit boxes, located within the United States or in any foreign country or territory, whether held individually or jointly and whether held by

you, your spouse, or any of your dependents, or held by others for the benefit of you, your spouse, or any of your dependents.

Name of Owner(s)

Name & Address of Depository Institution

Box No.

Contents

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FINANCIAL INFORMATION

REMINDER: When an item asks for information regarding your “assets” and “liabilities” include ALL assets and liabilities, located within

the United States or in any foreign country or territory, or institution, whether held individually or jointly, and whether held by you, your

spouse, or any of your dependents, or held by others for the benefit of you, your spouse, or any of your dependents. In addition, provide

all documents requested in Item 24 with your completed Financial Statement.

ASSETS

Item 9. Cash, Bank, and Money Market Accounts

List cash on hand (as opposed to cash in bank accounts or other financial accounts) and all bank accounts, money market accounts, or other financial

accounts, including but not limited to checking accounts, savings accounts, and certificates of deposit. The term “cash on hand” includes but is not

limited to cash in the form of currency, uncashed checks, and money orders.

a. Amount of Cash on Hand $

b. Name on Account

Form of Cash on Hand

Name & Address of Financial Institution

Account No.

Current Balance

$

$

$

$

$

Item 10. Publicly Traded Securities

List all publicly traded securities, including but not limited to, stocks, stock options, corporate bonds, mutual funds, U.S. government securities (including

but not limited to treasury bills and treasury notes), and state and municipal bonds. Also list any U.S. savings bonds.

Owner of Security

Issuer

Broker House, Address

Broker Account No.

Current Fair Market Value

$

Owner of Security

Issuer

Broker House, Address

Broker Account No.

Current Fair Market Value

$

Owner of Security

Issuer

Broker House, Address

Broker Account No.

Current Fair Market Value

$

Type of Security

No. of Units Owned

Loan(s) Against Security

$

Type of Security

No. of Units Owned

Loan(s) Against Security

$

Type of Security

No. of Units Owned

Loan(s) Against Security

$

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Item 11. Non-Public Business and Financial Interests

List all non-public business and financial interests, including but not limited to any interest in a non-public corporation, subchapter-S corporation, limited

liability corporation (“LLC”), general or limited partnership, joint venture, sole proprietorship, international business corporation or personal investment

corporation, and oil or mineral lease.

Entity’s Name & Address

Type of Business or Financial

Interest (e.g., LLC, partnership)

Owner

(e.g., self, spouse)

Ownership

%

If Officer, Director, Member

or Partner, Exact Title

Item 12. Amounts Owed to You, Your Spouse, or Your Dependents

Debtor’s Name & Address

Date Obligation

Incurred (Month/Year)

/

Current Amount Owed

$

Original Amount Owed

$

Payment Schedule

$

Debtor’s Telephone

Debtor’s Relationship to You

Debtor’s Name & Address

Date Obligation

Incurred (Month/Year)

/

Current Amount Owed

$

Debtor’s Telephone

Nature of Obligation (if the result of a final court

judgment or settlement, provide court name

and docket number)

Original Amount Owed

$

Nature of Obligation (if the result of a final court

judgment or settlement, provide court name

and docket number)

Payment Schedule

$

Debtor’s Relationship to You

Item 13. Life Insurance Policies

List all life insurance policies (including endowment policies) with any cash surrender value.

Insurance Company’s Name, Address, & Telephone No.

Beneficiary

Insurance Company’s Name, Address, & Telephone No.

Policy No.

Insured

Loans Against Policy

$

Beneficiary

Policy No.

Insured

Loans Against Policy

$

Face Value

$

Surrender Value

$

Face Value

$

Surrender Value

$

Item 14. Deferred Income Arrangements

List all deferred income arrangements, including but not limited to, deferred annuities, pensions plans, profit-sharing plans, 401(k) plans, IRAs, Keoghs,

other retirement accounts, and college savings plans (e.g., 529 Plans).

Trustee or Administrator’s Name, Address & Telephone No.

Name on Account

Date Established

/

/

(mm/dd/yyyy)

Trustee or Administrator’s Name, Address & Telephone No.

Account No.

Type of Plan

Surrender Value before

Taxes and Penalties

$

Account No.

Type of Plan

Surrender Value before

Taxes and Penalties

$

Name on Account

Date Established

/

/

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Item 15. Pending Insurance Payments or Inheritances

List any pending insurance payments or inheritances owed to you.

Type

Amount Expected

Date Expected (mm/dd/yyyy)

$

/

/

$

/

/

$

/

/

Item 16. Vehicles

List all cars, trucks, motorcycles, boats, airplanes, and other vehicles.

Vehicle Type

Make

Registration State & No.

Purchase Price

$

Account/Loan No.

Model

Address of Vehicle’s Location

Lender’s Name and Address

Registered Owner’s Name

Vehicle Type

Year

Make

Registration State & No.

Purchase Price

$

Account/Loan No.

Model

Address of Vehicle’s Location

Lender’s Name and Address

Registered Owner’s Name

Vehicle Type

Year

Registered Owner’s Name

Make

Registration State & No.

Purchase Price

$

Account/Loan No.

Model

Address of Vehicle’s Location

Lender’s Name and Address

Registered Owner’s Name

Vehicle Type

Year

Year

Make

Registration State & No.

Purchase Price

$

Account/Loan No.

Model

Address of Vehicle’s Location

Lender’s Name and Address

Original Loan Amount

$

Current Value

$

Current Balance

$

Monthly Payment

$

Original Loan Amount

$

Current Value

$

Current Balance

$

Monthly Payment

$

Original Loan Amount

$

Current Value

$

Current Balance

$

Monthly Payment

$

Original Loan Amount

$

Current Value

$

Current Balance

$

Monthly Payment

$

Item 17. Other Personal Property

List all other personal property not listed in Items 9-16 by category, whether held for personal use, investment or any other reason, including but not

limited to coins, stamps, artwork, gemstones, jewelry, bullion, other collectibles, copyrights, patents, and other intellectual property.

Property Category

(e.g., artwork, jewelry)

Name of Owner

Property Location

Acquisition Cost

Current Value

$

$

$

$

$

$

Initials:

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Item 18. Real Property

List all real property interests (including any land contract)

Property’s Location

Type of Property

Acquisition Date (mm/dd/yyyy)

/

/

Lender’s Name and Address

Purchase Price

$

Name(s) on Title or Contract and Ownership Percentages

Current Value

$

Loan or Account No.

Other Mortgage Loan(s) (describe)

Property’s Location

Purchase Price

$

Current Balance On First Mortgage or

Contract

$

Monthly Payment

$

Rental Unit

Monthly Payment

$

Monthly Rent Received

Current Balance

$

$

Name(s) on Title or Contract and Ownership Percentages

Type of Property

Acquisition Date (mm/dd/yyyy)

/

/

Lender’s Name and Address

Basis of Valuation

Current Value

$

Loan or Account No.

Other Mortgage Loan(s) (describe)

Basis of Valuation

Current Balance On First Mortgage or

Contract

$

Monthly Payment

$

Rental Unit

Monthly Payment

$

Current Balance

$

Monthly Rent Received

$

LIABILITIES

Item 19. Credit Cards

List each credit card account held by you, your spouse, or your dependents, and any other credit cards that you, your spouse, or your dependents use,

whether issued by a United States or foreign financial institution.

Name of Credit Card (e.g., Visa,

MasterCard, Department Store)

Account No.

Name(s) on Account

Current Balance

$

$

$

$

$

Item 20. Taxes Payable

List all taxes, such as income taxes or real estate taxes, owed by you, your spouse, or your dependents.

Type of Tax

Amount Owed

Year Incurred

$

$

$

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Item 21. Other Amounts Owed by You, Your Spouse, or Your Dependents

List all other amounts, not listed elsewhere in this financial statement, owed by you, your spouse, or your dependents.

Lender/Creditor’s Name, Address, and Telephone No.

Nature of Debt (if the result of a court judgment or settlement, provide court name and docket

number)

Lender/Creditor’s Relationship to You

Date Liability Was Incurred

Original Amount Owed

Current Amount Owed

Payment Schedule

/

/

$

$

(mm/dd/yyyy)

Lender/Creditor’s Name, Address, and Telephone No. Nature of Debt (if the result of a court judgment or settlement, provide court name and docket

number)

Lender/Creditor’s Relationship to You

Date Liability Was Incurred

/

/

(mm/dd/yyyy)

Original Amount Owed

$

Current Amount Owed

$

Payment Schedule

OTHER FINANCIAL INFORMATION

Item 22. Trusts and Escrows

List all funds and other assets that are being held in trust or escrow by any person or entity for you, your spouse, or your dependents. Include any legal

retainers being held on your behalf by legal counsel. Also list all funds or other assets that are being held in trust or escrow by you, your spouse, or your

dependents, for any person or entity.

Trustee or Escrow Agent’s Name & Address

Date Established

(mm/dd/yyyy)

/

/

Grantor

Beneficiaries

Present Market Value of Assets*

$

/

/

$

/

/

$

*If the market value of any asset is unknown, describe the asset and state its cost, if you know it.

Item 23. Transfers of Assets

List each person or entity to whom you have transferred, in the aggregate, more than $5,000 in funds or other assets during the previous five years by

loan, gift, sale, or other transfer (exclude ordinary and necessary living and business expenses paid to unrelated third parties). For each such person or

entity, state the total amount transferred during that period.

Transferee’s Name, Address, & Relationship

Property Transferred

Aggregate Value*

Transfer Date

(mm/dd/yyyy)

$

/

/

$

/

/

$

/

/

Type of Transfer

(e.g., Loan, Gift)

*If the market value of any asset is unknown, describe the asset and state its cost, if you know it.

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Item 24. Document Requests

Provide copies of the following documents with your completed Financial Statement.

Federal tax returns filed during the last three years by or on behalf of you, your spouse, or your dependents.

All applications for bank loans or other extensions of credit (other than credit cards) that you, your spouse, or your

dependents have submitted within the last two years, including by obtaining copies from lenders if necessary.

Item 9

For each bank account listed in Item 9, all account statements for the past 3 years.

Item 11

For each business entity listed in Item 11, provide (including by causing to be generated from accounting records) the

most recent balance sheet, tax return, annual income statement, the most recent year-to-date income statement, and all

general ledger files from account records.

Item 17

All appraisals that have been prepared for any property listed in Item 17, including appraisals done for insurance

purposes. You may exclude any category of property where the total appraised value of all property in that category is

less than $2,000.

Item 18

All appraisals that have been prepared for real property listed in Item 18.

Item 21

Documentation for all debts listed in Item 21.

Item 22

All executed documents for any trust or escrow listed in Item 22. Also provide any appraisals, including insurance

appraisals that have been done for any assets held by any such trust or in any such escrow.

SUMMARY FINANCIAL SCHEDULES

Item 25. Combined Balance Sheet for You, Your Spouse, and Your Dependents

Assets

Liabilities

Cash on Hand (Item 9)

Funds Held in Financial Institutions (Item 9)

U.S. Government Securities (Item 10)

Publicly Traded Securities (Item 10)

Non-Public Business and Financial Interests (Item 11)

Amounts Owed to You (Item 12)

Life Insurance Policies (Item 13)

Deferred Income Arrangements (Item 14)

Vehicles (Item 16)

Other Personal Property (Item 17)

Real Property (Item 18)

Other Assets (Itemize)

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

Total Assets

Loans Against Publicly Traded Securities (Item 10)

Vehicles - Liens (Item 16)

Real Property – Encumbrances (Item 18)

Credit Cards (Item 19)

Taxes Payable (Item 20)

Amounts Owed by You (Item 21)

Other Liabilities (Itemize)

Total Liabilities

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

Item 26. Combined Current Monthly Income and Expenses for You, Your Spouse, and Your Dependents

Provide the current monthly income and expenses for you, your spouse, and your dependents. Do not include credit card payments separately; rather,

include credit card expenditures in the appropriate categories.

Income (State source of each item)

Salary - After Taxes

Source:

Fees, Commissions, and Royalties

Source:

Interest

Source:

Dividends and Capital Gains

Source:

Gross Rental Income

Source:

Profits from Sole Proprietorships

Source:

Distributions from Partnerships, S-Corporations,

and LLCs

Source:

$

$

$

$

$

$

Expenses

Mortgage or Rental Payments for Residence(s)

Property Taxes for Residence(s)

Rental Property Expenses, Including Mortgage Payments, Taxes,

and Insurance

Car or Other Vehicle Lease or Loan Payments

Food Expenses

Clothing Expenses

$

$

$

$

$

$

Utilities

$

$

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Item 26. Combined Current Monthly Income and Expenses for You, Your Spouse, and Your Dependents (cont.)

Distributions from Trusts and Estates

Source:

Distributions from Deferred Income Arrangements

Source:

Social Security Payments

Alimony/Child Support Received

Gambling Income

$

$

$

$

$

Medical Expenses, Including Insurance

Other Insurance Premiums

Other Transportation Expenses

$

$

$

$

$

$

$

$

$

$

$

Other Expenses (Itemize)

Other Income (Itemize)

Total Income

$

Total Expenses

$

ATTACHMENTS

Item 27. Documents Attached to this Financial Statement

List all documents that are being submitted with this financial statement. For any Item 24 documents that are not attached, explain why.

Item No. Document Relates To

Description of Document

I am submitting this financial statement with the understanding that it may affect action by the Federal Trade

Commission or a federal court. I have used my best efforts to obtain the information requested in this statement. The

responses I have provided to the items above are true and contain all the requested facts and information of which I have

notice or knowledge. I have provided all requested documents in my custody, possession, or control. I know of the

penalties for false statements under 18 U.S.C. § 1001, 18 U.S.C. § 1621, and 18 U.S.C. § 1623 (five years imprisonment

and/or fines). I certify under penalty of perjury under the laws of the United States that the foregoing is true and correct.

Executed on:

_______________

(Date)

___________________________________

Signature

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ATTACHMENT B

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FEDERAL TRADE COMMISSION

FINANCIAL STATEMENT OF CORPORATE DEFENDANT

Instructions:

1.

Complete all items. Enter “None” or "N/A" (“Not Applicable”) where appropriate. If you cannot fully answer a

question, explain why.

2.

The font size within each field will adjust automatically as you type to accommodate longer responses.

3.

In completing this financial statement, “the corporation” refers not only to this corporation but also to each of its

predecessors that are not named defendants in this action.

4.

When an Item asks for information about assets or liabilities “held by the corporation,” include ALL such assets

and liabilities, located within the United States or elsewhere, held by the corporation or held by others for the

benefit of the corporation.

5.

Attach continuation pages as needed. On the financial statement, state next to the Item number that the Item is

being continued. On the continuation page(s), identify the Item number being continued.

6.

Type or print legibly.

7.

An officer of the corporation must sign and date the completed financial statement on the last page and initial

each page in the space provided in the lower right corner.

Penalty for False Information:

Federal law provides that any person may be imprisoned for not more than five years, fined, or both, if such person:

(1) “in any matter within the jurisdiction of any department or agency of the United States knowingly and

willfully falsifies, conceals or covers up by any trick, scheme, or device a material fact, or makes any false,

fictitious or fraudulent statements or representations, or makes or uses any false writing or document knowing the

same to contain any false, fictitious or fraudulent statement or entry” (18 U.S.C. § 1001);

(2) “in any . . . statement under penalty of perjury as permitted under section 1746 of title 28, United States Code,

willfully subscribes as true any material matter which he does not believe to be true” (18 U.S.C. § 1621); or

(3) “in any (. . . statement under penalty of perjury as permitted under section 1746 of title 28, United States

Code) in any proceeding before or ancillary to any court or grand jury of the United States knowingly makes any

false material declaration or makes or uses any other information . . . knowing the same to contain any false

material declaration.” (18 U.S.C. § 1623)

For a felony conviction under the provisions cited above, federal law provides that the fine may be not more than the

greater of (i) $250,000 for an individual or $500,000 for a corporation, or (ii) if the felony results in pecuniary gain to any

person or pecuniary loss to any person other than the defendant, the greater of twice the gross gain or twice the gross loss.

18 U.S.C. § 3571.

Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2294 Filed 05/24/22 Page 60

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BACKGROUND INFORMATION

Item 1.

General Information

Corporation’s Full Name ___________________________________________________________________________

Primary Business Address ______________________________________________________ From (Date) _________

Telephone No. _____________________________ Fax No. _____________________________

E-Mail Address________________________ Internet Home Page________________________

All other current addresses & previous addresses for past five years, including post office boxes and mail drops:

Address____________________________________________________________ From/Until____________________

Address____________________________________________________________ From/Until____________________

Address____________________________________________________________ From/Until____________________

All predecessor companies for past five years:

Name & Address _________________________________________________________ From/Until ______________

Name & Address _________________________________________________________ From/Until ______________

Name & Address _________________________________________________________ From/Until ______________

Item 2.

Legal Information

Federal Taxpayer ID No. _________________________ State & Date of Incorporation _________________________

State Tax ID No. ____________________ State ________________ Profit or Not For Profit _____________________

Corporation’s Present Status: Active ________________ Inactive _______________ Dissolved __________________

If Dissolved: Date dissolved _________________________ By Whom ______________________________________

Reasons _________________________________________________________________________________________

Fiscal Year-End (Mo./Day) ________________ Corporation’s Business Activities _____________________________

Item 3.

Registered Agent

Name of Registered Agent __________________________________________________________________________

Address __________________________________________________________ Telephone No. __________________

Page 2

Initials __________

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Item 4.

Principal Stockholders

List all persons and entities that own at least 5% of the corporation’s stock.

Name & Address

% Owned

_________________________________________________________________________________ ______________

_________________________________________________________________________________ ______________

_________________________________________________________________________________ ______________

_________________________________________________________________________________ ______________

Item 5.

Board Members

List all members of the corporation’s Board of Directors.

Name & Address

% Owned

Term (From/Until)

____________________________________________________________________ __________ _________________

____________________________________________________________________ __________ _________________

____________________________________________________________________ __________ _________________

____________________________________________________________________ __________ _________________

____________________________________________________________________ __________ _________________

Item 6.

Officers

List all of the corporation’s officers, including de facto officers (individuals with significant management responsibility

whose titles do not reflect the nature of their positions).

Name & Address

% Owned

_______________________________________________________________________________ ________________

_______________________________________________________________________________ ________________

_______________________________________________________________________________ ________________

_______________________________________________________________________________ ________________

_______________________________________________________________________________ ________________

Page 3

Initials __________

Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2296 Filed 05/24/22 Page 62

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Item 7.

Businesses Related to the Corporation

List all corporations, partnerships, and other business entities in which this corporation has an ownership interest.

Name & Address

Business Activities

% Owned

___________________________________________________________________ ___________________ _________

___________________________________________________________________ ___________________ _________

___________________________________________________________________ ___________________ _________

State which of these businesses, if any, has ever transacted business with the corporation _______________________

________________________________________________________________________________________________

Item 8.

Businesses Related to Individuals

List all corporations, partnerships, and other business entities in which the corporation’s principal stockholders, board

members, or officers (i.e., the individuals listed in Items 4 - 6 above) have an ownership interest.

Individual’s Name

Business Name & Address

Business Activities

% Owned

__________________ __________________________________________________ __________________ ________

__________________ __________________________________________________ __________________ ________

__________________ __________________________________________________ __________________ ________

State which of these businesses, if any, have ever transacted business with the corporation _______________________

________________________________________________________________________________________________

Item 9.

Related Individuals

List all related individuals with whom the corporation has had any business transactions during the three previous fiscal

years and current fiscal year-to-date. A “related individual” is a spouse, sibling, parent, or child of the principal

stockholders, board members, and officers (i.e., the individuals listed in Items 4 - 6 above).

Name and Address

Relationship

Business Activities

_________________________________________________________ _________________ ______________________

_________________________________________________________ _________________ ______________________

_________________________________________________________ _________________ ______________________

Page 4

Initials __________

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Item 10.

Outside Accountants

List all outside accountants retained by the corporation during the last three years.

Name

Firm Name

Address

CPA/PA?

____________________ ______________________ ________________________________________ ____________

____________________ ______________________ ________________________________________ ____________

____________________ ______________________ ________________________________________ ____________

____________________ ______________________ ________________________________________ ____________

____________________ ______________________ ________________________________________ ____________

Item 11.

Corporation’s Recordkeeping

List all individuals within the corporation with responsibility for keeping the corporation’s financial books and records for

the last three years.

Name, Address, & Telephone Number

Position(s) Held

____________________________________________________________________________ ___________________

____________________________________________________________________________ ___________________

____________________________________________________________________________ ___________________

____________________________________________________________________________ ___________________

Item 12.

Attorneys

List all attorneys retained by the corporation during the last three years.

Name

Firm Name

Address

____________________ ___________________________ ________________________________________________

____________________ ___________________________ ________________________________________________

____________________ ___________________________ ________________________________________________

____________________ ___________________________ ________________________________________________

____________________ ___________________________ ________________________________________________

Page 5

Initials __________

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Item 13.

Pending Lawsuits Filed by the Corporation

List all pending lawsuits that have been filed by the corporation in court or before an administrative agency. (List

lawsuits that resulted in final judgments or settlements in favor of the corporation in Item 25).

Opposing Party’s Name & Address___________________________________________________________________

Court’s Name & Address___________________________________________________________________________

Docket No._________________ Relief Requested____________________ Nature of Lawsuit____________________

____________________________________ Status______________________________________________________

Opposing Party’s Name & Address___________________________________________________________________

Court’s Name & Address___________________________________________________________________________

Docket No._________________ Relief Requested____________________ Nature of Lawsuit____________________

____________________________________ Status______________________________________________________

Opposing Party’s Name & Address___________________________________________________________________

Court’s Name & Address___________________________________________________________________________

Docket No._________________ Relief Requested____________________ Nature of Lawsuit____________________

____________________________________ Status______________________________________________________

Opposing Party’s Name & Address___________________________________________________________________

Court’s Name & Address___________________________________________________________________________

Docket No._________________ Relief Requested____________________ Nature of Lawsuit____________________

____________________________________ Status______________________________________________________

Opposing Party’s Name & Address___________________________________________________________________

Court’s Name & Address___________________________________________________________________________

Docket No._________________ Relief Requested____________________ Nature of Lawsuit____________________

____________________________________ Status______________________________________________________

Opposing Party’s Name & Address___________________________________________________________________

Court’s Name & Address___________________________________________________________________________

Docket No._________________ Relief Requested____________________ Nature of Lawsuit____________________

____________________________________ Status______________________________________________________

Page 6

Initials __________

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Item 14.

Current Lawsuits Filed Against the Corporation

List all pending lawsuits that have been filed against the corporation in court or before an administrative agency. (List

lawsuits that resulted in final judgments, settlements, or orders in Items 26 - 27).

Opposing Party’s Name & Address___________________________________________________________________

Court’s Name & Address___________________________________________________________________________

Docket No._________________ Relief Requested____________________ Nature of Lawsuit____________________

____________________________________ Status______________________________________________________

Opposing Party’s Name & Address___________________________________________________________________

Court’s Name & Address___________________________________________________________________________

Docket No._________________ Relief Requested____________________ Nature of Lawsuit____________________

____________________________________ Status______________________________________________________

Opposing Party’s Name & Address___________________________________________________________________

Court’s Name & Address___________________________________________________________________________

Docket No._________________ Relief Requested____________________ Nature of Lawsuit____________________

____________________________________ Status______________________________________________________

Opposing Party’s Name & Address___________________________________________________________________

Court’s Name & Address___________________________________________________________________________

Docket No._________________ Relief Requested____________________ Nature of Lawsuit____________________

____________________________________ Status______________________________________________________

Opposing Party’s Name & Address___________________________________________________________________

Court’s Name & Address___________________________________________________________________________

Docket No._________________ Relief Requested____________________ Nature of Lawsuit____________________

____________________________________ Status______________________________________________________

Opposing Party’s Name & Address___________________________________________________________________

Court’s Name & Address___________________________________________________________________________

Docket No._________________ Relief Requested____________________ Nature of Lawsuit____________________

____________________________________ Status______________________________________________________

Page 7

Initials __________

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Item 15.

Bankruptcy Information

List all state insolvency and federal bankruptcy proceedings involving the corporation.

Commencement Date _________________ Termination Date _________________ Docket No. __________________

If State Court: Court & County _______________________ If Federal Court: District __________________________

Disposition ______________________________________________________________________________________

Item 16.

Safe Deposit Boxes

List all safe deposit boxes, located within the United States or elsewhere, held by the corporation, or held by others for the

benefit of the corporation. On a separate page, describe the contents of each box.

Owner’s Name

Name & Address of Depository Institution

Box No.

__________________ ___________________________________________________________________ __________

__________________ ___________________________________________________________________ __________

__________________ ___________________________________________________________________ __________

__________________ ___________________________________________________________________ __________

__________________ ___________________________________________________________________ __________

FINANCIAL INFORMATION

REMINDER: When an Item asks for information about assets or liabilities “held by the corporation,” include

ALL such assets and liabilities, located within the United States or elsewhere, held by the corporation or held by

others for the benefit of the corporation.

Item 17.

Tax Returns

List all federal and state corporate tax returns filed for the last three complete fiscal years. Attach copies of all returns.

Federal/

State/Both

Tax Year

Tax Due

Federal

Tax Paid

Federal

Tax Due

State

Tax Paid

State

Preparer’s Name

___________ __________ $_________ $_________ $__________ $__________ ______________________________

___________ __________ $_________ $_________ $__________ $__________ ______________________________

___________ __________ $_________ $_________ $__________ $__________ ______________________________

Page 8

Initials __________

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Item 18.

Financial Statements

List all financial statements that were prepared for the corporation’s last three complete fiscal years and for the current

fiscal year-to-date. Attach copies of all statements, providing audited statements if available.

Year

Balance Sheet

Profit & Loss Statement

Cash Flow Statement Changes in Owner’s Equity Audited?

_________ _____________ ______________________ __________________ _______________________ ________

_________ _____________ ______________________ __________________ _______________________ ________

_________ _____________ ______________________ __________________ _______________________ ________

_________ _____________ ______________________ __________________ _______________________ ________

Item 19.

Financial Summary

For each of the last three complete fiscal years and for the current fiscal year-to-date for which the corporation has not

provided a profit and loss statement in accordance with Item 18 above, provide the following summary financial

information.

Current Year-to-Date

1 Year Ago

2 Years Ago

3 Years Ago

Gross Revenue

$_________________

$_______________

$_______________

$_______________

Expenses

$_________________

$_______________

$_______________

$_______________

Net Profit After Taxes

$_________________

$_______________

$_______________

$_______________

Payables

$_________________

Receivables

$_________________

Item 20.

Cash, Bank, and Money Market Accounts

List cash and all bank and money market accounts, including but not limited to, checking accounts, savings accounts, and

certificates of deposit, held by the corporation. The term “cash” includes currency and uncashed checks.

Cash on Hand $_________________________ Cash Held for the Corporation’s Benefit $_______________________

Name & Address of Financial Institution

Signator(s) on Account

Account No.

Current

Balance

_____________________________________ _______________________________ ______________ $___________

_____________________________________ _______________________________ ______________ $___________

_____________________________________ _______________________________ ______________ $___________

_____________________________________ _______________________________ ______________ $___________

Page 9

Initials __________

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Item 21.

Government Obligations and Publicly Traded Securities

List all U.S. Government obligations, including but not limited to, savings bonds, treasury bills, or treasury notes, held by

the corporation. Also list all publicly traded securities, including but not limited to, stocks, stock options, registered and

bearer bonds, state and municipal bonds, and mutual funds, held by the corporation.

Issuer _________________________________ Type of Security/Obligation __________________________________

No. of Units Owned __________ Current Fair Market Value $__________________ Maturity Date _______________

Issuer _________________________________ Type of Security/Obligation __________________________________

No. of Units Owned __________ Current Fair Market Value $__________________ Maturity Date _______________

Item 22.

Real Estate

List all real estate, including leaseholds in excess of five years, held by the corporation.

Type of Property________________________________ Property’s Location__________________________________

Name(s) on Title and Ownership Percentages___________________________________________________________

Current Value $____________________ Loan or Account No. __________________________

Lender’s Name and Address_________________________________________________________________________

Current Balance On First Mortgage $_______________ Monthly Payment $______________

Other Loan(s) (describe)____________________________________________ Current Balance $_________________

Monthly Payment $__________________ Rental Unit?_________________ Monthly Rent Received $_____________

Type of Property________________________________ Property’s Location__________________________________

Name(s) on Title and Ownership Percentages___________________________________________________________

Current Value $____________________ Loan or Account No. __________________________

Lender’s Name and Address_________________________________________________________________________

Current Balance On First Mortgage $_______________ Monthly Payment $______________

Other Loan(s) (describe)____________________________________________ Current Balance $_________________

Monthly Payment $__________________ Rental Unit?_________________ Monthly Rent Received $_____________

Page 10

Initials __________

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Item 23.

Other Assets

List all other property, by category, with an estimated value of $2,500 or more, held by the corporation, including but not

limited to, inventory, machinery, equipment, furniture, vehicles, customer lists, computer software, patents, and other

intellectual property.

Property Category

Property Location

Acquisition

Cost

Current

Value

____________________________ _____________________________________________ $__________ $_________

____________________________ _____________________________________________ $__________ $_________

____________________________ _____________________________________________ $__________ $_________

____________________________ _____________________________________________ $__________ $_________

____________________________ _____________________________________________ $__________ $_________

____________________________ _____________________________________________ $__________ $_________

____________________________ _____________________________________________ $__________ $_________

____________________________ _____________________________________________ $__________ $_________

____________________________ _____________________________________________ $__________ $_________

Item 24.

Trusts and Escrows

List all persons and other entities holding funds or other assets that are in escrow or in trust for the corporation.

Trustee or Escrow Agent’s

Name & Address

Description and Location of Assets

Present Market

Value of Assets

______________________________________ _______________________________________ $_________________

______________________________________ _______________________________________ $_________________

______________________________________ _______________________________________ $_________________

______________________________________ _______________________________________ $_________________

______________________________________ _______________________________________ $_________________

______________________________________ _______________________________________ $_________________

______________________________________ _______________________________________ $_________________

Page 11

Initials __________

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Item 25.

Monetary Judgments and Settlements Owed To the Corporation

List all monetary judgments and settlements, recorded and unrecorded, owed to the corporation.

Opposing Party’s Name & Address___________________________________________________________________

Court’s Name & Address____________________________________________________ Docket No._____________

Nature of Lawsuit______________________________ Date of Judgment________________ Amount $____________

Opposing Party’s Name & Address___________________________________________________________________

Court’s Name & Address____________________________________________________ Docket No._____________

Nature of Lawsuit______________________________ Date of Judgment________________ Amount $____________

Item 26.

Monetary Judgments and Settlements Owed By the Corporation

List all monetary judgments and settlements, recorded and unrecorded, owed by the corporation.

Opposing Party’s Name & Address___________________________________________________________________

Court’s Name & Address____________________________________________________ Docket No._____________

Nature of Lawsuit_______________________________________ Date______________ Amount $______________

Opposing Party’s Name & Address___________________________________________________________________

Court’s Name & Address____________________________________________________ Docket No._____________

Nature of Lawsuit______________________________ Date of Judgment________________ Amount $____________

Opposing Party’s Name & Address___________________________________________________________________

Court’s Name & Address____________________________________________________ Docket No._____________

Nature of Lawsuit______________________________ Date of Judgment________________ Amount $____________

Opposing Party’s Name & Address___________________________________________________________________

Court’s Name & Address____________________________________________________ Docket No._____________

Nature of Lawsuit______________________________ Date of Judgment________________ Amount $____________

Opposing Party’s Name & Address___________________________________________________________________

Court’s Name & Address____________________________________________________ Docket No._____________

Nature of Lawsuit______________________________ Date of Judgment________________ Amount $____________

Page 12

Initials __________

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Item 27.

Government Orders and Settlements

List all existing orders and settlements between the corporation and any federal or state government entities.

Name of Agency ___________________________________________ Contact Person __________________________

Address _____________________________________________________________ Telephone No. _______________

Agreement Date ______________ Nature of Agreement __________________________________________________

Item 28.

Credit Cards

List all of the corporation’s credit cards and store charge accounts and the individuals authorized to use them.

Name of Credit Card or Store

Names of Authorized Users and Positions Held

__________________________________________ _____________________________________________________

__________________________________________ _____________________________________________________

__________________________________________ _____________________________________________________

__________________________________________ _____________________________________________________

__________________________________________ _____________________________________________________

Item 29.

Compensation of Employees

List all compensation and other benefits received from the corporation by the five most highly compensated employees,

independent contractors, and consultants (other than those individuals listed in Items 5 and 6 above), for the two previous

fiscal years and current fiscal year-to-date. “Compensation” includes, but is not limited to, salaries, commissions,

consulting fees, bonuses, dividends, distributions, royalties, pensions, and profit sharing plans. “Other benefits” include,

but are not limited to, loans, loan payments, rent, car payments, and insurance premiums, whether paid directly to the

individuals, or paid to others on their behalf.

Name/Position

Current Fiscal

Year-to-Date

1 Year Ago

2 Years Ago

Compensation or

Type of Benefits

_____________________________ $____________ $___________ $____________ ___________________________

_____________________________ $____________ $___________ $____________ ___________________________

_____________________________ $____________ $___________ $____________ ___________________________

_____________________________ $____________ $___________ $____________ ___________________________

_____________________________ $____________ $___________ $____________ ___________________________

Page 13

Initials __________

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Item 30.

Compensation of Board Members and Officers

List all compensation and other benefits received from the corporation by each person listed in Items 5 and 6, for the

current fiscal year-to-date and the two previous fiscal years. “Compensation” includes, but is not limited to, salaries,

commissions, consulting fees, dividends, distributions, royalties, pensions, and profit sharing plans. “Other benefits”

include, but are not limited to, loans, loan payments, rent, car payments, and insurance premiums, whether paid directly to

the individuals, or paid to others on their behalf.

Name/Position

Current Fiscal

Year-to-Date

1 Year Ago

2 Years Ago

Compensation or

Type of Benefits

_____________________________ $____________ $___________ $____________ ___________________________

_____________________________ $____________ $___________ $____________ ___________________________

_____________________________ $____________ $___________ $____________ ___________________________

_____________________________ $____________ $___________ $____________ ___________________________

_____________________________ $____________ $___________ $____________ ___________________________

_____________________________ $____________ $___________ $____________ ___________________________

_____________________________ $____________ $___________ $____________ ___________________________

_____________________________ $____________ $___________ $____________ ___________________________

Item 31.

Transfers of Assets Including Cash and Property

List all transfers of assets over $2,500 made by the corporation, other than in the ordinary course of business, during the

previous three years, by loan, gift, sale, or other transfer.

Transferee’s Name, Address, & Relationship

Property

Transferred

Aggregate

Value

Transfer

Date

Type of Transfer

(e.g., Loan, Gift)

______________________________________ ________________ $____________ __________ _________________

______________________________________ ________________ $____________ __________ _________________

______________________________________ ________________ $____________ __________ _________________

______________________________________ ________________ $____________ __________ _________________

______________________________________ ________________ $____________ __________ _________________

Page 14

Initials __________

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Item 32.

Documents Attached to the Financial Statement

List all documents that are being submitted with the financial statement.

Item No. Document

Relates To

Description of Document

___________________ ____________________________________________________________________________

___________________ ____________________________________________________________________________

___________________ ____________________________________________________________________________

___________________ ____________________________________________________________________________

___________________ ____________________________________________________________________________

___________________ ____________________________________________________________________________

___________________ ____________________________________________________________________________

___________________ ____________________________________________________________________________

___________________ ____________________________________________________________________________

I am submitting this financial statement with the understanding that it may affect action by the Federal Trade

Commission or a federal court. I have used my best efforts to obtain the information requested in this statement. The

responses I have provided to the items above are true and contain all the requested facts and information of which I have

notice or knowledge. I have provided all requested documents in my custody, possession, or control. I know of the

penalties for false statements under 18 U.S.C. § 1001, 18 U.S.C. § 1621, and 18 U.S.C. § 1623 (five years imprisonment

and/or fines). I certify under penalty of perjury under the laws of the United States that the foregoing is true and correct.

Executed on:

______________________________

(Date)

_____________________________________________________

Signature

_____________________________________________________

Corporate Position

Page 15

Initials __________

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ATTACHMENT C

Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2309 Filed 05/24/22 Page 75

of 78

Form

4506

Request for Copy of Tax Return

a Do not sign this form unless all applicable lines have been completed.

(July 2017)

OMB No. 1545-0429

a Request may be rejected if the form is incomplete or illegible.

Department of the Treasury

Internal Revenue Service

a For more information about Form 4506, visit www.irs.gov/form4506.

Tip. You may be able to get your tax return or return information from other sources. If you had your tax return completed by a paid preparer, they

should be able to provide you a copy of the return. The IRS can provide a Tax Return Transcript for many returns free of charge. The transcript

provides most of the line entries from the original tax return and usually contains the information that a third party (such as a mortgage company)

requires. See Form 4506-T, Request for Transcript of Tax Return, or you can quickly request transcripts by using our automated self-help service

tools. Please visit us at IRS.gov and click on “Get a Tax Transcript...” or call 1-800-908-9946.

1a Name shown on tax return. If a joint return, enter the name shown first.

1b First social security number on tax return,

individual taxpayer identification number, or

employer identification number (see instructions)

2a If a joint return, enter spouse’s name shown on tax return.

2b Second social security number or individual

taxpayer identification number if joint tax return

3 Current name, address (including apt., room, or suite no.), city, state, and ZIP code (see instructions)

4 Previous address shown on the last return filed if different from line 3 (see instructions)

5 If the tax return is to be mailed to a third party (such as a mortgage company), enter the third party’s name, address, and telephone number.

Caution: If the tax return is being mailed to a third party, ensure that you have filled in lines 6 and 7 before signing. Sign and date the form once you

have filled in these lines. Completing these steps helps to protect your privacy. Once the IRS discloses your tax return to the third party listed on line

5, the IRS has no control over what the third party does with the information. If you would like to limit the third party's authority to disclose your return

information, you can specify this limitation in your written agreement with the third party.

6

Tax return requested. Form 1040, 1120, 941, etc. and all attachments as originally submitted to the IRS, including Form(s) W-2,

schedules, or amended returns. Copies of Forms 1040, 1040A, and 1040EZ are generally available for 7 years from filing before they are

destroyed by law. Other returns may be available for a longer period of time. Enter only one return number. If you need more than one

type of return, you must complete another Form 4506. a

Note: If the copies must be certified for court or administrative proceedings, check here .

.

.

.

.

.

.

.

.

.

.

.

.

.

7

Year or period requested. Enter the ending date of the year or period, using the mm/dd/yyyy format. If you are requesting more than

eight years or periods, you must attach another Form 4506.

8

Fee. There is a $50 fee for each return requested. Full payment must be included with your request or it will

be rejected. Make your check or money order payable to “United States Treasury.” Enter your SSN, ITIN,

or EIN and “Form 4506 request” on your check or money order.

.

.

.

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.

.

.

.

.

.

.

.

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.

.

.

.

.

.

.

50.00

$

a

Cost for each return .

b

c

Number of returns requested on line 7 . . . . . . . . . . . . . . . . . . . . . .

Total cost. Multiply line 8a by line 8b . . . . . . . . . . . . . . . . . . . . . .

$

If we cannot find the tax return, we will refund the fee. If the refund should go to the third party listed on line 5, check here

.

9

.

.

.

.

.

.

Caution: Do not sign this form unless all applicable lines have been completed.

Signature of taxpayer(s). I declare that I am either the taxpayer whose name is shown on line 1a or 2a, or a person authorized to obtain the tax return

requested. If the request applies to a joint return, at least one spouse must sign. If signed by a corporate officer, 1 percent or more shareholder, partner,

managing member, guardian, tax matters partner, executor, receiver, administrator, trustee, or party other than the taxpayer, I certify that I have the authority to

execute Form 4506 on behalf of the taxpayer. Note: This form must be received by IRS within 120 days of the signature date.

Signatory attests that he/she has read the attestation clause and upon so reading

declares that he/she has the authority to sign the Form 4506. See instructions.

F F F

Sign

Here

Signature (see instructions)

Phone number of taxpayer on line

1a or 2a

Date

Title (if line 1a above is a corporation, partnership, estate, or trust)

Spouse’s signature

For Privacy Act and Paperwork Reduction Act Notice, see page 2.

Date

Cat. No. 41721E

Form 4506 (Rev. 7-2017)

Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2310 Filed 05/24/22 Page 76

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Page 2

Form 4506 (Rev. 7-2017)

Section references are to the Internal Revenue Code

unless otherwise noted.

Chart for all other returns

Future Developments

If you lived in

or your business

was in:

For the latest information about Form 4506 and its

instructions, go to www.irs.gov/form4506.

Information about any recent developments affecting

Form 4506, Form 4506-T and Form 4506T-EZ will be

posted on that page.

General Instructions

Caution: Do not sign this form unless all applicable

lines have been completed.

Purpose of form. Use Form 4506 to request a copy

of your tax return. You can also designate (on line 5)

a third party to receive the tax return.

How long will it take? It may take up to 75

calendar days for us to process your request.

Tip. Use Form 4506-T, Request for Transcript of Tax

Return, to request tax return transcripts, tax account

information, W-2 information, 1099 information,

verification of nonfiling, and records of account.

Automated transcript request. You can quickly

request transcripts by using our automated self-help

service tools. Please visit us at IRS.gov and click on

“Get a Tax Transcript...” or call 1-800-908-9946.

Where to file. Attach payment and mail Form 4506

to the address below for the state you lived in, or the

state your business was in, when that return was

filed. There are two address charts: one for

individual returns (Form 1040 series) and one for all

other returns.

If you are requesting a return for more than one

year or period and the chart below shows two

different addresses, send your request to the

address based on the address of your most recent

return.

Chart for individual returns

(Form 1040 series)

If you filed an

individual return

and lived in:

Alabama, Kentucky,

Louisiana, Mississippi,

Tennessee, Texas, a

foreign country, American

Samoa, Puerto Rico,

Guam, the

Commonwealth of the

Northern Mariana Islands,

the U.S. Virgin Islands, or

A.P.O. or F.P.O. address

Alaska, Arizona,

Arkansas, California,

Colorado, Hawaii, Idaho,

Illinois, Indiana, Iowa,

Kansas, Michigan,

Minnesota, Montana,

Nebraska, Nevada, New

Mexico, North Dakota,

Oklahoma, Oregon,

South Dakota, Utah,

Washington, Wisconsin,

Wyoming

Connecticut,

Delaware, District of

Columbia, Florida,

Georgia, Maine,

Maryland,

Massachusetts,

Missouri, New

Hampshire, New Jersey,

New York, North

Carolina, Ohio,

Pennsylvania, Rhode

Island, South Carolina,

Vermont, Virginia, West

Virginia

Mail to:

Internal Revenue Service

RAIVS Team

Stop 6716 AUSC

Austin, TX 73301

Alabama, Alaska,

Arizona, Arkansas,

California, Colorado,

Florida, Hawaii, Idaho,

Iowa, Kansas, Louisiana,

Minnesota, Mississippi,

Missouri, Montana,

Nebraska, Nevada,

New Mexico,

North Dakota,

Oklahoma, Oregon,

South Dakota, Texas,

Utah, Washington,

Wyoming, a foreign

country, American

Samoa, Puerto Rico,

Guam, the

Commonwealth of the

Northern Mariana

Islands, the U.S. Virgin

Islands, or A.P.O. or

F.P.O. address

Connecticut, Delaware,

District of Columbia,

Georgia, Illinois, Indiana,

Kentucky, Maine,

Maryland,

Massachusetts,

Michigan, New

Hampshire, New Jersey,

New York, North

Carolina,

Ohio, Pennsylvania,

Rhode Island, South

Carolina, Tennessee,

Vermont, Virginia, West

Virginia, Wisconsin

Mail to:

Internal Revenue Service

RAIVS Team

P.O. Box 9941

Mail Stop 6734

Ogden, UT 84409

All others. See section 6103(e) if the taxpayer has

died, is insolvent, is a dissolved corporation, or if a

trustee, guardian, executor, receiver, or

administrator is acting for the taxpayer.

Documentation. For entities other than individuals,

you must attach the authorization document. For

example, this could be the letter from the principal

officer authorizing an employee of the corporation or

the letters testamentary authorizing an individual to

act for an estate.

Internal Revenue Service

RAIVS Team

P.O. Box 145500

Stop 2800 F

Cincinnati, OH 45250

Specific Instructions

Line 1b. Enter your employer identification number

(EIN) if you are requesting a copy of a business

return. Otherwise, enter the first social security

number (SSN) or your individual taxpayer

identification number (ITIN) shown on the return. For

example, if you are requesting Form 1040 that

includes Schedule C (Form 1040), enter your SSN.

Line 4. Enter the address shown on the last return

filed if different from the address entered on line 3.

Note: If the addresses on lines 3 and 4 are different

and you have not changed your address with the

IRS, file Form 8822, Change of Address. For a

business address, file Form 8822-B, Change of

Address or Responsible Party — Business.

Signature and date. Form 4506 must be signed and

dated by the taxpayer listed on line 1a or 2a. The

IRS must receive Form 4506 within 120 days of the

date signed by the taxpayer or it will be rejected.

Ensure that all applicable lines are completed before

signing.

!

F

Internal Revenue Service

RAIVS Team

Stop 6705 P-6

Kansas City, MO

64999

Partnerships. Generally, Form 4506 can be

signed by any person who was a member of the

partnership during any part of the tax period

requested on line 7.

Note: If you are Heir at law, Next of kin, or

Beneficiary you must be able to establish a material

interest in the estate or trust.

Line 3. Enter your current address. If you use a P.O.

box, please include it on this line 3.

Internal Revenue Service

RAIVS Team

Stop 37106

Fresno, CA 93888

Corporations. Generally, Form 4506 can be

signed by: (1) an officer having legal authority to bind

the corporation, (2) any person designated by the

board of directors or other governing body, or (3)

any officer or employee on written request by any

principal officer and attested to by the secretary or

other officer. A bona fide shareholder of record

owning 1 percent or more of the outstanding stock

of the corporation may submit a Form 4506 but must

provide documentation to support the requester's

right to receive the information.

You must check the box in the

signature area to acknowledge you

have the authority to sign and request

CAUTION the information. The form will not be

processed and returned to you if the box is

unchecked.

Individuals. Copies of jointly filed tax returns may

be furnished to either spouse. Only one signature is

required. Sign Form 4506 exactly as your name

appeared on the original return. If you changed your

name, also sign your current name.

Signature by a representative. A representative

can sign Form 4506 for a taxpayer only if this

authority has been specifically delegated to the

representative on Form 2848, line 5. Form 2848

showing the delegation must be attached to Form

4506.

Privacy Act and Paperwork Reduction Act

Notice. We ask for the information on this form to

establish your right to gain access to the requested

return(s) under the Internal Revenue Code. We need

this information to properly identify the return(s) and

respond to your request. If you request a copy of a

tax return, sections 6103 and 6109 require you to

provide this information, including your SSN or EIN,

to process your request. If you do not provide this

information, we may not be able to process your

request. Providing false or fraudulent information

may subject you to penalties.

Routine uses of this information include giving it to

the Department of Justice for civil and criminal

litigation, and cities, states, the District of Columbia,

and U.S. commonwealths and possessions for use

in administering their tax laws. We may also

disclose this information to other countries under a

tax treaty, to federal and state agencies to enforce

federal nontax criminal laws, or to federal law

enforcement and intelligence agencies to combat

terrorism.

You are not required to provide the information

requested on a form that is subject to the Paperwork

Reduction Act unless the form displays a valid OMB

control number. Books or records relating to a form

or its instructions must be retained as long as their

contents may become material in the administration

of any Internal Revenue law. Generally, tax returns

and return information are confidential, as required

by section 6103.

The time needed to complete and file Form 4506

will vary depending on individual circumstances. The

estimated average time is: Learning about the law

or the form, 10 min.; Preparing the form, 16 min.;

and Copying, assembling, and sending the form

to the IRS, 20 min.

If you have comments concerning the accuracy of

these time estimates or suggestions for making

Form 4506 simpler, we would be happy to hear from

you. You can write to:

Internal Revenue Service

Tax Forms and Publications Division

1111 Constitution Ave. NW, IR-6526

Washington, DC 20224.

Do not send the form to this address. Instead, see

Where to file on this page.

Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2311 Filed 05/24/22 Page 77

of 78

ATTACHMENT D

Case 2:22-cv-11120-BAF-APP *SEALED* ECF No. 10, PageID.2312 Filed 05/24/22 Page 78

of 78

CONSENT TO RELEASE FINANCIAL RECORDS

I, ____________________________________, of ________________________

___________________________________________ (City, State), do hereby direct any bank,

saving and loan association, credit union, depository institution, finance company, commercial

lending company, credit card processor, credit card processing entity, automated clearing house,

network transaction processor, bank debit processing entity, brokerage house, escrow agent,

money market or mutual fund, title company, commodity trading company, trustee, or person

that holds, controls, or maintains custody of assets, wherever located, that are owned or

controlled by me or at which there is an 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 very nature in its possession or control which relate to the said accounts to any

attorney of the Federal Trade Commission, and to give evidence relevant thereto, in the matter of

the Federal Trade Commission v. Financial Education Services, Inc., et al., now pending in the

United States District Court for the Eastern District of Michigan, and this shall be irrevocable

authority for so doing.

This direction is intended to apply to the laws of countries other than the Unites States of

America which restrict or prohibit disclosure of bank or other financial information without the

consent of the holder of the account, and shall be construed as consent with respect hereto, and

the same shall apply to any of the accounts for which I may be a relevant principal.

Dated:____________________________

Signature:_________________________________

Printed Name:______________________________