therefore, it is - ftc.gov · credit repair services, and that relief defendant has received funds...

Case 9:17-cv-80619-WPD Document 131-1 Entered on FLSD Docket 05/25/2018 of 29

COURT DISTRICT TES A ST UNITED FLORIDA OF DISTRICT SOUTHERN

17-CV-8961.9-WPD No. Case

COMMISSION, TRADE FEDERAL

P1aintiff,

v.

et LLC, SOLUTIONS STUDENT TEGJC STRA al.,

and Defendants,

LLC, PROPERTIES INVESTMENT 0G

Defendant. Relief

INJUNCTION PERMANENT FOR ORDER STIPULATED JUDGMENT MONETARY AND

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

of 3(b) J Section to pursuant (''Complaint"), Relief Equitable Other and Injunction Permanent for

and Telemarketing the 53(b), § U.S.C. IS Act"), ("FTC Act Commission Trade Federal the

and l08, -6 IOl 6 §§ U.S.C. 15 Act"), ("Telemarketing Act Prevention Abuse and Fraud Consumer

§ Commission, The l679h(b). U.S.C. 15 Act, Organizations Repair Credit the of 4IO(b) Section

LLC, Solutions Credit Strategic LLC, Solutions Student Strategic Defendants Receiver, the

LLC, Center Relief Student LLC, Solutions Doc Strategic LLC, Solutions Debt Prep Strategic

Investment 0G Defendant Relief and ("Defendants") Green Dave and LLC, Center Relief Credit

Pennanent for Order Stipulated this of entry the to stipulate Defendant") Relief .. ( LLC Properties

Page I of29

l t

Case 9:17-cv-80619-WPD Document 133 Entered on FLSD Docket 05/29/2018 Page 1 of 29

Case 9:17-cv-80619-WPD Document 131-1 Entered on FLSO Docket 05/25/2018 of 29

action this in dispute in matters all resolve to ("Order") Judgment Monetary and Injunction

based Defendants Corporate of behalf on Order this into entering is Receiver The them. between

to The 42). No. (ECF Injunction J>reliminary Stipulated the under him granted powers the upon

by represented currently not are Defendant Relief and Defendants Corporate that notes Receiver

counsel.

follows: ORDERED as IS IT THEREFORE,

FINDINGS

matter. this over jurisdiction has Court This . I

in practices or acts deceptive in participated Defendants that charges Complaint The 2.

§ Telemarketing FTC's the violated and 45, U.S.C. 15 Act, FTC the of 5 Section of violation

15 ("CROA''), Act Organizations Repair Credit the and C.F.R.Part310, 16 ("TSR"), Rule Sales

the and relief debt loan student of sale and marketing with connection in 679j I 679• I §§ U.S.C.

to funds traceable are that funds received has Defendant Relief that and services, repair credit

funds. the to claim legitimate no has and issue at practices and acts unlawful the from obtained

the in allegations the of any deny nor admit neither Defendant Relief and Defendants 3.

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

jurisdiction. establish to necessary facts the admit Defendant Relief and Defendants

Equal the under have may they that claim any waive Defendant Relief and Defendants 4.

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

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

or challenge otherwise or appeal to rights all waive Defendant Relief and Defendants 5.

Order. this of validity the contest

Page 2 of29


Case 9.f?.cv-80619-WPD Document 131-1 Entered on FLSD Docket 0512512018 of 29

DEFINITIONS

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

A. includes: others" "Assisttog

to responding or receiving including functions, service customer performing I.

complaints; consumer

any of. provision or formulation the for aminging or providing, or formulating 2.

or solicitation, mail direct script, sales telephone any including material, marketing or advertising

electronic other or email, website, Internet any of images of use or text, design, the

communication;

any of, provision or formulation the for arranging or providing, or fonnulating 3.

domain or addresses Protocol Internet or web including service. or material support marketing

placement media or services, marketing affiliate websites, Internet any for registration name

services;

customers; potential of, generation the in assisting or of, names providing 4.

or kind; any of services payment or billing. marketing, performing 5.

entity. any of principal or manager, director, officer, owner, an as serving or acting 6.

program or plan. service, product, any means service" or product repair "Credit B.

history, credit record, credit consumer's any improve to implication, by or expressly represented,

or activity any to regard with consumer any to assistance or advice provide or rating; credit or

credit or history, credit record, credit consumer's a improve to is which of purpose the service

rating.

Page 3 of29



Defendants, Corporate the of all and Defendant Individual the means "Defendants" C.

OT combination. any in collectively, individually,

Credit Strategic LLC. Solutions Student Strategic means Defendants" '"Corporate l.

Relief Student LLC, Solutions Prep Doc Strategic LLC, Solutions Debt Strategic LLC, Solutions

assigns. and successors their and LLC, Center Relief Credit and LLC, Center

Green. Dave means ant" end Def "lndlvldual 2.

program or plan, service, product, any service" or product "Financial D. means

to: implication, by or expressly represented,

any assist or receive, to consumer any for arrange consumer, any provide I.

credit; of extension other or loan a receiving. in consumer

any assist or receive, to consumer any for arrange consumer, any provide 2.

cards; value stored or debit, credit, receiving, in consumer

record. credit consumer's any repair, or improve to arrange or repair, improve, 3.

or rating; credit or history, credit

credit record, credit consumer's any improve to assistance or advice provide 4.

rating. credit or history,

general or limited association, unincorporated group, individual, any means E. ..Person"

entity. business other or corporation, partnership,

Berger of Esq. Marcushamer, M. Isaac and Esq. Lichttnan, H. Charles means "Receiver" F.

and Receiver, Temporary and Receiver as capacities respective their in solely LLP, Singerman

LLP. Singennan Berger including professionals, and agents their

LLC. Properties, Investment 0G means Defendant" "Relief G.

Page 4 of29


vvv~ l I l·Cf.t[lf f g.lfpo a ····· 'OCllmen/ 131-1 Entered on FLSD Docket

051251201 _8_P ____ _

age 5 of29

Squatter 4461 LLC, Remo San 227 LLC, Westgate 18 means Entities" Property ..Rental H.

Land NW 17.50 LLC, Swordfish 5819 LLC, Tropical, 4899 LLC, Concordia 4628 LLC, Home

title fee respective the includes and LLC, Holdings Clafy and LLC, Mirada La 7893 Trust.

Individual and/or Defendant, Relief them, by controlled or owned properties of owners

Falls 6300 Trust, Land 5819 Trust, Land Renaissance to limited not but including Defendant,

NE 14212 Trust, Land Remo San Trust, Land Riverside 2701 Trust, Land NW 8911 Trust, Land

Islands 500 Trust, Land 4461 Trust. Land lnverrary 4158 Trust, Land NW 17343 Trust, Land

Land Westgate 18 Trust, Land Concordia 4628 Trust), Land Islands Three 500 (a/k/a Trust Land

Lake Gate 5280 Trust, Land Sample W. 11152 Trust, Land Tropical 4899 Trust, Land 6009 Trust.

Land Trust, Woodmont 7355 Trust, Land Circle Bellasol 4109 Trust, Land Falls 5961 Trust, Land

Trust. Land NW 1750 Trust, Land Street Johnson 2314

means: service" or product relief debt unseeured or "Secured I.

one and person a between obligation or debt. loan, mortgage. any to respect With 1.

program or plan, service, product, any collectors, debt or creditors more or unsecured or secured

to: implication, by or expressly represented.

a for sale foreclosure of deed or mortgage any postpone or prevent, stop, a.

or dwelling person's a of repoS8ession any collater.tl, of sale other any dwelling, person's

foreclosure from collateral other or dwelling person's a save otherwise or collateral, other

repossession; or

obtain, any in or settle, renegotiate, or modification, a arrange or negotiate, b.

the in reduction a including obligation, or debt. loan, mortgage, the of terms any alter way

of29



a to person a by owed fees or payments, monthly balance, principal interest, of amount

collector; debt or creditor unsecured or secured

any from payments of timing the in modification or forbearance any obtain c.

obligation; or debt, loan, mortgage, any of servicer or holder unsecured or secured

within time of period the of extension any arrange or obtain, negotiate, d.

obligation, or debt, loan. mortgage, the on default her or his cure (i) may person a which

(iii) (ii) other or dwelling a redeem obligation, or debt, loan, mortgage, her or his reinstate

or obligation or debt, loan, mortgage, the reinstate to right any exercise (iv) or collateral,

collateral; other or dwelling a redeem

an contained payment balloon or clause acceleration of waiver any obtain e.

by or collateral; other or dwelling any secured contract or note promissory any in

(i) collateral, other or dwelling a of sale short a arrange or obtain, negotiate, f.

(iii) (ii) or debt, loan, mortgage, a of disposition other any or foredosure, of deed-in-lieu a

loan unsecured or secured the not is that party third a to sale a than other obligation

holder.

a examining or auditing including assistance, claimed of manner any include shall foregoing The

obligation. or debt, loan, mortgage, a for application person's

more or one and person a between obligation or debt, loan, any to respect With 2.

represented, program or plan, service, product, any collectors, debt or creditors unsecured

to: implication, by or expressly

or obligations; or debts, loans, unsecured more or one repay a.

Page 6 of29



loans, new more or one into obligations or debts, loans, unsecured combine b.

or obligations. debts,

ORDER

I. RELIEF DEBT UNSECURED AND SECURED ON BAN SERVICES AND PRODUCTS

from enjoined and restrained pennanentJy are Defendants that ORDERED IS IT

the in others assisting or selling, or sale, for offering promoting, marketing, j!vertising,

debt unsecured or secured any of selling, or sale, for offering promoting, marketing, ~vertising,

service. or product relief

SERVICES AND PRODUCTS REPAIR CREDIT ON BAN 11.

enjoined and restrained permanently are Defendants that ORDERED FURTHER IS IT

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

or product repair credit any of selling, or sale, for offering promoting, marketing, advertising,

service.

TO RELATING MISREPRESENTATIONS AGAINST PROHIBITION III. SERVICES AND PRODUCTS FINANCIAL

employees, agents, officers, Defendants' Defendants, that ORDERED FURTHER IS IT

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

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

service, or product financial any of selling or sale, for offering promoting, marketing, advertising,

in others assisting or misrepresenting, from enjoined and restrained pennanently are

by implication: or expressly misrepresenting,

Page 7 of29


Case 9:17-cv-80619-WPO Document 131-1 Entered on FLSD Docket 05/25/2018 of 29

credit, of extension other or loan any for available are that rates or tenns the A.

including:

fees; other or costs closing , I

payment, baJloon any amount(s), payment monthly schedule, payment the 2.

terms; payment other or

and ch.arge(s), financ.e or rate(s), percentage annual rate(s), interest the J.

adjustable; or fixed are they whether

4. the balance; outstanding or amount, draw amount, credit amount. loan the

term credit; of other any or maturity; or period, draw term, loan

or proceeds, the of out borrower the to disbursed be to cash of amount the 5,

third any to borrower the of behalf on disbursed be to cash of amount the

parties;

and interest both covers amount payment minimum specified any whether 6.

amortization; negative in result can or has credit the whether and principal.

or

subsequent whether or penalty prepayment a have not does credit the that 7.

fees; other and/or penalty prepayment a trigger may refinancing

that or representation; legal receive will consumer a 8.

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

material any or conditions; or limitations, restrictions, material any costs; total

characteristics. central or nature, efficacy, performance, its of aspect

Page 8 of29


... Case 9:17-cv-80619-WPD Document 131-1 Entered on FLSD Docket 05/25/2018 of 29

ANY TO RELATING MISREPRESENTATIONS AGAINST PROHIBITION IV. SERVICES OR PRODUCTS


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

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

or plan, service, product, any of selling or sale, for offering promoting, marketing, advertising.

in others assisting or misrepresenting, from enjoined and restrained permanently are program,

implication: by or expressly misrepresenting,

or exchange, cancellation, refund, any of terms or nature the of aspect material any A.

partial or full a obtaining consumer a of ikelihood I the including policy, repurchase

be partial in the to granted will refund or full a which circumstances the or refund

or programs other in participate to ability their cancel, consumers if or, consumer;

goal; same the meet to intended services

connected otherwise or by, approved or endorsed with, affiliated is person any that B.

other or non-profit, public, entity; government person; other any to

program; other any or program; non-commercial

product, any provides who person any of title job or position, expertise, nature, the C.

or program; or plan, service,

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

material any or conditions; or limitations, restrictions, material any costs; total

characteristics. central or nature, efficacy, perfonrumce, its of aspect

Page 9 of29


case 9:17-cv-80619-WPD Document 131-1 Entered on FLSO Docket 05/25/2018 of 29

CLAIMS UNSUBSTANTIATED AGAINST PROHIBITION V.

that employees, agents, officers, Defendants' Defendants, ORDERED FURTHER IS JT

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

the with connection in indirectly, or directly acting whether Order, this of notice actual rw:eive ,;

any making from enjoined and restrained pcnnanently are service, or produc1 financial any of 5f1e

about implication, by or expressly representation, any making in others assisting or ~tesentation ~

representation the unless service, or product financial any of efficacy or perfonnance, benefits, die

and, upon rely and possess Defendants made, is representation such time the at non.misleading, is

standards on based quantity and quality in sufficient is that evidence reliable and competent

relevant of body entire the of light in considered when fields, relevant the in accepted aenerally

true. is representation the that substantiate to evidence, reliable and

SUSPENSION PARTIAL AND JUDGMENT ARY MONET VI.

that: ORDERED FURTHER IS IT

thousand, nine twenty and hundred seven million, seventeen of amount the in Judgment A.

against Commission the of favor in entered is ($17,729,493) dollars three ninety and hundred four

of portion Defendant's Relief that except severally, and jointly Defendant. Relief and cndants Def

relief. monetary equitable as $2,977,845 exceed not shall judgment the

Defendant: Relief and Defendants against judgment the of satisfaction partial In B.

the for or of, behalf on of, name the in accounts holding institutions financial All l.

from days business 0) l ( ten within shall, Defendant Corporate any of, benefit

agent. designated his or Receiver the to transfer Order, this of copy a of receipt an

to: limited not but including, accounts, such in any, if funds,.

Page 10 of 29


-Case9:17-cv-80619-WPD Document 131-1 Entered on FLSD Docket05/25/2018 of

29

A&D Order. this of copy a of receipt of days business (10) ten Within a.

all agent designated his or Receiver the to transfer to ordered is Mortgage

Credit Strategic of name the in xxxx0013 number account in funds

Green; LLODave Solutions

( ten Applied Order, this of copy a of receipt of days business 0) l Within b.

all agent designated his or Receiver the to transfer to ordered is Bank

Student Strategic of name the in xxxx3387 number account in any, if funds,

LLC. Solutions

of Bank Order, this of copy ofa ofreceipt days business (10) ten Within c.

all agent designated his or Receiver the to transfer to ordered is America

accounts: following the in any, if funds,

Solutions Credit Strategic of name the in 1785 xxxx number account i.

and LLC;

Solutions Student Strategic of name the in 772 xxxxl number account ii.

LLC.

Cynergy Order, this of copy a of receipt of days business (10) ten Within d.

bis or Receiver the to transfer to ordered is Payment Data/Priority

name the in xxxx3055 number account in any, if funds, all agent designated

I.LC. Solutions Prep Doc Strategic of

Francis Order, this of copy a of receipt of days business 0) l ( ten Within e.

transfer to ordered is Systems Merchant Electronic d/b/a Corporation David

Page 11 of 29


case 9:17-cv-80619-WPD Document 131-1 Entered on FLSD Docket 05/25/2018 of 29

number account in any, if funds, all agent designated his or Receiver the to

LLC. Solutions Student Strategic of name the in xxxx6586

Global Order, this of copy a of receipt of days business 0) I ( ten Within f.

designated his or Receiver the to transfer to ordered is Solutions Client

accounts: following the in any, if funds, all agent

Solutions Debt Strategic of name the in xxxx0675 number account i.

LLC;

ii. Solutions Student Strategic of name the in xxxx1064 number account

LLC;

Solutions Credit Strategic of name the in xxxxl088 number account iii.

and LLC;

Solutions Credit Strategic of name the in xxxx2535 number account iv.

LLC.

Merrick 0) I ( ten Within g. Order, this of copy a of receipt of days business

all agent designated his or Receiver the is to transfer to ordered Bank

account in any, if funds, Doc Strategic of name the in xxxx.3055 number

LLC. Solutions Prep

h. PayMitCo Order, this of copy a of receipt of days business 10) ( ten Within

if funds, all agent designated his or Receiver the to transfer to ordered is

of name the in any. LLC. Solutions Student Strategic

Page 12 of 29


Casef:17-cv-80619-WPD Document 131-1 Entered on FLSD Docket 05/25/2018 of 4 29 ''.i

Bank TD Order, this of copy a of receipt of days business 10) ( ten Within i.

to if funds, all agent designated his or Receiver the to transfer ordered is

accounts: following the in any,

Solutions Student Strategic of name the in xxxx4782 number account L

LLC;

Solutions Prep Doc Strategic of name the in xxxx6890 number account ii.

LLC;

LLC; Center Relief Credit of name the in xxxx8424 number account iii.

LLC; Center Relief Student of name the in xxxx8432 number account iv.

Solutions Debt Strategic of name the in xxxx8487 number account v.

LLC;

Solutions Credit Strategic of name the in xxxx:4203 number account vi,

LLC;

Properties; Investment ofDG name the in xxx.x.0665 number account vii.

LLC; Tropical 4899 of name the in xxxx2432 number account viii.

LLC; Holdings Clafy of name the in xxxx2854 number account ix.

LLC; Mirada 7893 La of name the in xxxx6890 number account x.

LLC; Swordfish 5819 of name the in xxxx8101 number account xi.

LLC; Concordia 4628 of name the in xxxx8250 number account xii.

LLC; Home Squatter 4461 of name the in xxxx8268 number account xiii.

and LLC; Westgate 18 of name the in xxxx8276 number account xiv.

LLC. Remo San 227 of name the in xxxx8284 number account xv.

Page 13 of29


-case 9:17-cv-80619-WPD Document 131-1 Entered on FLSD Docket 05/25/2018 of

29

Titanium Order, this of copy a of receipt of days business 0) ! ( ten Within j.

his or the to transfer to ordered is Bank Esquire Payments/ Receiver

name the in xxxx.5770 number account in any, if funds, all agent designated

LLC. Solutions Prep Doc Strategic of

ten V1U1tiv Order, this of copy a of receipt of days business (10) Within k.

his or Receiver the to transfer to ordered is Moneris) as known (formerly

accounts: following the in any, if funds, alt agent designated

Solutions Prep Doc Strategic of name the in xxxx2884 number account i.

and LLC;

Solutions Credit Strategic of name the in xxxx5885 number account ii.

LLC.

Wells Order, this of copy a of receipt of days business 0) I ( ten Within I.

all agent designated its or Receiver the to transfer to ordered is Fargo

Holdings ofClafy name the in xxxx2700 number account in any, if funds,

LLC.

the for or of, behalf on of, name the in accounts holding institutions financial All 2.

receipt from days business 0) I ( ten within shall, Defendant Individual of, benefit

all agent, designated its or Commission the to transfer Order, this of copy ofa

to: limited not but including, accounts, such in any, if funds,

TD Order, this of copy a of receipt of days business 0) I ( ten Within a.

all agent designated its or FTC the to transfer to ordered is Ameritrude

accounts: following the in any, if funds,

Page 14 of 29


-Case 9:17-cv-80619-WPD Document 131-1 Entered on FLSD Docket 05/25/2018 of

29

Services Education liberty of name the in xxxx5069 number i. account

LLC;

Dave of name the in xxxx9.S94 number account and Green; ii.

Green. Dominique of name the in xxxx0871 number account iii.

Bank TD Order, this of copy a of receipt of days business 0) I ( ten Within b.

in any, if funds, all agent designated its or FTC the to transfer to ordered is

accounts: following the

Solutions Support Strategic of name the in xx.xx8479 number accow1t i.

LLC;

ii. Resource and Security Credit of name the in xxxx7898 number account

LLC; Centers

Credit of name the in xxxx7905 number account Services Investment iii.

LLC;

LLC; Zone Credit of name the in x.xxx7921 number account iv.

LLC; Sources Credit Capitol of name the in 7939 xxxx number account v.

Credit of name the in xxxx7947 number account LLC; Solutions Asset vi.

Inc.: Green Dave of name the in xxxx3652 number account vii.

Green ofN. name the in xxxx1232 number accoW1t and UTMA; FL, viii.

UTMA. FL, Green ofT. name the in xxxxl399 number account ix.

First Order, this of copy a of receipt of days business 0) l ( ten Within c.

designated or FTC the to transfer to ordered is Jamaica in Bank Global its

following the in funds, any, if accounts: agentall

Page 15 of29


-WPD Document 131 -1 Entered on FLSD Docket 05/25/2018 of

Case 9:17-cv-80619-29

and Solutions; Sales Call DG of name the in xxxx3323 number account i.

Loans. DG Strategic of name the in xxxx0057 number account ii.

Applied Order, this of copy a of receipt of days business 0) l ( ten Within

designated its or FTC if funds. all agent the to transfer to ordered is Bank

Green. Dave of name the in xxxx7022 number account in any,

Relief Defendants, Order, this of entry of date the of days (7) seven Within 3.

Receiver the as steps such take and fully cooperate shall Entities Property Rental and Defendant,

to information, necessary any providing and documents any executing including require, may

and legal and possession fund, settlement qualified his to or Receiver, the to transfer the cause

The Properties"). Rental "the (collectively, below described property real the to title equitable

to effectuate needed as stamps documentary and taxes required any pay to authorized is Receiver

Receiver the possession, and title of transfer Following Order. this by contemplated transfers the

all and fees, association bomeowner's taxes, utilities, maintenance, all for responsible be shall

such alJ pay to authorized is and Rental the to related nature any of expenses other Propenies

and income ~ntal from including Estate, Receivership the from due come they as expenses

necessary be otherwise may as or Properties, Rental the of more or one of s) sale( from proceeds

Entities Property Rental and Defendant, Relief Defendants, Properties. Rental the maintain to

that Relief Defendants, Properties. Rental the on encumbrances or liens no are there represent

this signing after encumbrances such any add not shall Entities Property Rental and Defendant.

the by paid be shall Properties Rental the transferring of expenses and costs The Order.

Rental the to related being used funds of source the of consideration without Estate Receivership

expressly Entities Property Rental and Defendant, Relief Defendants, transferred. so Property

Page 16 of29



29

waive, forever hereby further and property, homestead not are Properties Rental the that agree

in described Propenies Rental the in interest and title, right, all disclaim and discharge, release,

transfer Entities Property Rental and Defendant, Relief Defendants, Until sub-paragraph. this

Property Rental and Defendant, Relief Defendants, Properties, Rental the of possession and title

any including Properties, Rental the of value the diminish to action no take shall Entities

thereto. appurtenances and fixtures, structures,

to pursuant Receiver the to transferred Properties Rental 22 the to applies provision This

the includes which Motion, Verified Emergency Receiver's on Order Agreed 2017 6, June the

properties: following

33426 FL Beach, Boynton #304, Way Renaissance l a.

33319 FL Tamarac, Ct., Swordfish 5819 h.

33319 FL Lauderhill, #109, Dr. Cir., Falls S 6300 c.

33065 FL Springs, Coral #8, Dr. 28th NW 8911 d.

33065 FL Springs, Coral #303-B, Dr., 2701 e. Riverside

33068 FL Lauderdale, N. Blvd., Remo San 227 f.

33161 FL Miami, Ave., 4th NE 14212 g.

33169 FL Miami, #710, Ave. 7th NW 17343 h.

1. 33319 FL Lauderhill, #503, Dr. lnverrary 4158

33068 FL Lauderdale, North Court, 4461 j. 59th NW

33009 FL Beach, Hallandale #101, Blvd. Islands Three 500 k.

33426 FL Beach, Boynton Ln., Concordia 4628 I.

33426 FL Beach, Boynton #18F, Ln. Westgate 18 m.

Page 17 of29



29

33063 FL Margate, Street. st l NW 6009 n.

33426 FL Beach, Boynton Dr., Gardens Tropical 4899 o.

# 3065 3 FL Springs. Coral 11152, Sample W. 11152 p.

33319 FL Tamarac, #5280. Road Lake Gate 5280 q.

33319 FL Lauderhill, #309, Drive, Circle Falls S. 5961 r.

33916 FL Myers, Fort 114, #l Cir. Bellasol 4109 s.

t. 33321 FL Tamarac, #102 Terrace Woodmont 7355

33020 FL Hollywood, #24D, Street Johnson 2314 u.

33313 FL Lauderhill, #203, Ave. 55th NW 1750 v.

timely and fully to ordered are Entities Property Rental and Defendant, Relief Defendants,

Rental the of any of transfer other or sale rental, maintenance, the in Receiver the with cooperate

upon properties such of title transfer to necessary documents any executing including Properties,

rights has who Person any against claims to respect with all reserves Receiver The sale. their

income, rental recover to Properties Rental the from income rental received or in lived

the of respect in incurred expenses out-of-pocket other or advanced funds for reimbursements

Properties. Rental the of sale for listing or sale, administration. care, maintenance,

and title, right, all assign shall Receiver the Order, this of entry of days 7 Within 4.

property real the on Receiver the to granted previously lien bearing non•interest the to interest

Order Court the to pursuant 33446, Florida Beach, Delray Way, Bridge Banpo 8142 at located

1306, PG 29170 BK OR at County Beach Palm of records the in recorded as 2017, 6, June dated

be lien the challenge not shall Defendants $315,000. shall amount lien The Commission. the to

Commission. the to lien the of assignment the or

Page 18 of29



29

and the above, B Subsection in forth set as transfers, asset other all payment Upon C.

below. Subsections the to subject suspended, is judgment the of remainder

by As the held assets liquidate to directed is Receiver the below, VIII Section in forth set D.

assets remaining the transfer payments, Court-authorized any of satisfaction after and. Receiver

FTC. the to assets these of sale the from proceeds net and

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

Relief and Defendants' of completeness and accuracy, truthfulness, the upon premised

"financial {collectively, documents related and statements financial sworn Defendant's

the namely: Commission, to submitted representations")

the 25, May on signed Green Dave Defendant Individual of Statement Financial l.

attachment~ the including 2017,

by on Green Dave signed Solutions Student Strategic of Statement Financial the 2.

attachments; the including 2017, 8, June

Attachment .. labeled Green Dave Defendant oflndividual Statement Financial the 3.

the attachments: including 2017, I, J July on signed A"

B" "Attachment labeled Defendants Corporate the of Statement Financial the 4.

and attachments; the including 2017, I, t July on Green Dave by signed

Disclosures Financial Supplemental regarding Green Dave of Declaration the S.

undated, A-H. Attachments including Green. Dave by signed

by the motion upon if, Defendant any to as lifted be wiU judgment the of suspension The F.

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

Page 19 of29



29

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

above, identified representations financial

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

for only stipulate parties the (which above A Subsection in specified amount the in Defendant that

made previously payment any less injury), consumer the represents Section this of purposes

Order. this of entry of date the from computed interest plus Section, this to pursuant

right, equitable and legal all and dominion relinquish Defendant Relief and Defendants H.

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

assets.

any in proof, further without true, as taken be will Complaint the in alleged facts The I.

to proceeding a in including by Commission, the of behalf on or litigation civil subsequent

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

case. bankruptcy any in complaint nondischargeability

action an sustain to necessary elements all establish Complaint the in alleged facts The J.

U.S.C. 11 Code, Bankruptcy the of 523(a)(2)(A) Section to pursuant Commission the by

purposes. such for effect estoppel coUatera.l have will Order this and 523(a)(2)(A), §

Numbers Identification their that acknowledge Defendant Relief and Defendants K. Taxpayer

and collecting for used be may Numbers) Identification Employer or Numbers Security (Social

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

§7701.

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

including relief, equitable for used be to designee its or Commission the by administered

Page 20 of29



29

a lf fund. redress any of administration the for expenses attendant any and redress consumer

to partially or wholly is consumers redress direct that decides Commjssion the of representative

any apply may Commission the completed, is redress after remains money or impracticable

it as remedies) information consumer (including relief equitable other such for money remaining

Any Complaint. the in alleged practices Defendants' to related reasonably be to determines

disgorgement. as Treasury U.S. the to deposited be to is relief equitable such for used not money

its or Commission the actions any challenge to right no have Defendant Relief and Defendants

Subsection. this to pursuant take may representatives

the in identified transfers and payments the permit to modified is freeze asset The M.

freeze asset the transfers, and payments those of completion Upon Section. Judgment Monetary

dissolved. is

INFORMATION CUSTOMER VII.


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

or directly from enjoined and restrained permanently are Order, this of notice actual receive

indirectly:

efficiently to Commission the enable to information customer sufficient provide to failing A.

redress this provided have they that represent Defendants redress. consumer administer

any writing in requests Commission the of representative a lf Commission. the to information

the by prescribed form the in it, provide must Defendants redress, to related information

days. 14 within Commission,

Page 21 of29


-WPD Document 131 -1 Entered on FLSD Docket 05/25/2018 of case 9: 17-cv-80619-

29

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

information, identifying other FSA number, security social address, email number, telephone ro,

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

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

and services; repair credit or relief debt loan student of sale the with connection in Order

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

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

Commission.

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

by by court or regulation, law, required or agency government a requested extent the to disclosed,

order.

RECEIVERSHIP OF TERMINATION AND CONTINUATION TEMPORARY VIII.

powers, receivership full retain shaU Receiver the that ORDERED FURTHER IS IT

entered Injunction Preliminary Stipulated the in forth set powers those to limited not but including

entry Upon powers. liquidation full incJuding and 2017, 26, May on maner this in Coun the by

Rental the and property receivership remaining liquidate shall Receiver the Order, this of an

directed is Receiver The computers. and records, files, remaining all of dispose and Properties,

Properties, Rental the of sale the oversee to steps necessary all mke to authority given and

the for contract a into enter to agents. estate real more or one retain to authority the including

bulk sales, block in Properties Rental the sell to or property, each of sale and purchase private

Properties Rental the sell to judgment, business Receiver's the in if or, individually, or sales,

way by sale the administer to auction, public of sale) bulk or blocks, in individually, either (

Page 22 of29


I


to each of sale the close and interim, the in Properties Rental the preserve and maintain to process,

§ U.S.C. 28 under obligations any from relieved expressly hereby is Receiver The property.

§ and Defendants Corporate the up wind to directed is Receiver The 2004. U.S.C. 28 or 2001

may Receiver the or party any but Order, this of entry after days 120 within assets all liquidate

the of termination Upon cause. good for tenn Receiver's the extend Court the that request

the expenses, and costs, fees, approved aJJ of Receiver the to payment finaJ and receivership

Receivership the in assets remaining all agent designated its or FTC the to transfer shall Receiver

costs of payment after remaining Properties Rental the of sale the of proceeds the and Estate

sales. such for necessary

ACKNOWLEDGMENTS ORDER IX.

obtain Defendant Relief and Defendants that ORDERED FURTHER IS IT

Order: this of receipt of acknowledgments

to submit must Order, this of entry of days 7 within Defendant. Relief and Defendant Each A.

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

that business any for Defendant, Individual Order, this of entry after years S For B.

or owner majority the is Defendants, other any with collectively or individually Defendant. such

Order this of copy a deliver must Defendant. Corporate each and indirectly, or directly controls

employees all (2) members; and mauagers LLC and directors, officers. principals, all l) ( to:

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

Order; the of matter subject the to related conduct in participate who representatives and agents

(3) titled Section the in forth set as structure in change any from resulting entity business any and

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

Page 23 of29


Case 9:17-cv-80619-WPD Document 131-1 Entered on FLSD Docket05/25/2018 of 29

responsibilities. their assume they before occur must delivery others. all For persoMet

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

this of receipt of acknowledgment dated and signed a days, 30 within obtain. must Defendant

Order.

REPORTING COMPLIANCE X.

the to submissions timely make Defendants that ORDERED FURTHER IS IT

Commission:

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

perjury: of penalty under sworn

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

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

by to their of all businesses Defendant's that of all identify (b) Defendant; with communicate use

the describe (c) addresses; Internet and email, postal, physical, and numbers, telephone names,

advertising, of means the offered, services and goods the including business, each of activities

Defendant Individual (which Defendant other any of involvement the and sales, and marketing,

in detail describe (d) involvement); own his to due know should or knows ifbe describe must

provide (e) and Order; this of Section each with compliance in is Defendant that how and whether

previously unless Order, this to pursuant obtained Acknowledgment Order each of copy a

Commission. the to submitted

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

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

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

Page 24 of29



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

role, title, including business, such each in involvement Defendant's such detail in describe (c)

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

compliance a submit must Defendant each Order, this of entry after years 20 For B.

following: the in change any of days 4 t within perjury, of penalty under sworn notice,

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

in interest ownership any has Defendant that entity any or Defendant Corporate any of structure

Order, this under arising obligations compliance affect may that indirectly or directly controls or

affiliate or parent, subsidiary, any or entity the of dissolution or sale. merger, creation, including:

Order. this to subject practices or acts any in engages that

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

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

or employee an as whether services performs Defendant such which for business any including

the identify and interest, ownership any has Defendant such which in entity any and otherwise

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

bankruptcy ofany filing the of notice Commission the to submit must Defendant Each C.

by 14 within Defendant such against or proceeding similar or proceeding, insolvency petition,

of filing. its days

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

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

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

Page 25 of29



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

and signature. applicable),

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

ovemight by sent or DEbrieft~fkgov to emailed be must Order this to pursuant Commission the

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

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

v. FTC begin: line subject The 20580. DC no. matter aL, et Solutions, Student Strategic must

Xl70038.

RECORDKEEPING XI.

years 20 for records certain create must Defendants that ORDERED FURTHER IS IT

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

or individually Defendant, such that business any for Defendant Individual and Defendants

must indirectly. or directly controls or owner majority a is Defendants, other any with collectively

records: following the retain and create

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

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

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

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

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

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

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

and Commission; the to submissions all including

Page 26 of29


case 9: 17-cv-80619-WPD Document 131-1 Entered on FLSD Docket 05/25/2018 of 29

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

MONITORING COMPLIANCE XII.

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

part which upon representations financial the i.ncluding Order, this with compliance Defendant's

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

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

other or reports compliance additional submit must: Defendant Relief and Defendant each

and depositions; for appear perjury; of penalty under sworn be must which infonnation, requested

obtain to authorized also Commission The copying. and inspection for documents produce

Rules Federal prescribed procedures the of any using court, of leave further without discovery. by

69. and 45, 36, 34, 33, 31, depositions), telephonic (including 30 29, Procedure Civil of

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

pennit must Defendant Relief and Defendants Defendant. Relief and Defendant each with

any with affiliated person other or employee any interview to Commission the of representatives

counsel have interviewed person The interview. an to agreed has who Defendant may such

present.

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

Relief Defendants, to entities. or individuals other or suppliers, consumers, as representatives

the without Defendant, Relief or Defendants with affiliated entity or individual any or Defendant,

lawful Commission's the limits Order this in Nothing notice. prior or identification of necessity

57b-l. 49, U.S.C. 15 Act, FTC the of 20 and 9 Sections to pursuant process, compulsory of use §§

Page 27 of29



reporting consumer Commission, the of representative a from request written Upon D. any to Section pursuant .Defendant, [ndividual concerning reports consumer furnish must agency

l68Ib(a)(l). § U.S.C. 15 Act, Reporting Credit Fair the of 604(1)

JURISDICTION OF RETENTION XIII.

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

Order. this of enforcement and modification, construction, of

_. ___ ___ of day this ORDERED SO }'n.....:..A-....._~---'· 23..

AGREED: AND STIPULATED SO

COMMISSION: TRADE FEDERAL THE FOR

fl/. ~ tt/~· TANDON MIYA

A5502005) No. Bar Special {Florida WESOLOWSKI M. ADAM

No. Bar Special (Florida 73) l A5502 Commission Trade Federal

CC-10232 NW, Ave., Pennsylvania 600 20580 DC W~ington, ·

{Tandon) 326-2351 (202} (Wesolowski) 326-3068 (202)

[email protected] [email protected]

Plaintiff for Attorneys COMMISSION TRADE FEDERAL

Page 28 of29



DEFENDANT: IVIDUAL

Credit Strategic LLC, Solutions Student Strategic DEFENDANTS TE CORPORA FOR Student LLC, Solutions Debt Strategic LLC, Solutions Prep Doc Stratepe LLC, Solutions

DG DEFENDANT RELIEF and LLC Center Relief Credit ad LLC, Center Relief LLC: Properties Investment

~-~ Date: 3-/f i/.:

Esq. Gaukroger, C. Gavin 7 Receiver the for Counsel 0076489 No. Bar FJorida

LLP SINGERMAN BERGER 000 I Suite Boulevard, Olas Las East 350

333014 Florida Lauderdale. Fort 525-9900 (954) Telephone:

ggaukroger(@beTgersingennan.com

/,,f/ Date: /t./..f/ • Defendants Corporate of officer an as , ~

Credit Strategic LLC, Solutions Student . Strate LLC. Solutions Prep Doc Strategic LLC, Solutions Center Relief Student LLC, Solutions Debt Strategic

Relief and LLC, Center Relief Credit and LLC, LLC Properties Investment DG Defendant

Page 29 of29

I


therefore, it is - ftc.gov · credit repair services, and that relief defendant has received funds...

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