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1
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Government Exhibit # 1ST AMENDED COMPLAINT
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EXTRACTED KEY WORDS
DEFENDANTS FINANCIAL INSTITUTION FTC ACT CUSTOMER GLB ACT VIOLATIONS PRACTICES REPRESENTATIVES COMMISSION RELIEF CONSUMERS COURT PLAINTIFF ENFORCE UNFAIR DECEPTIVE ACTS OFFICER BUSINESS FRAUDULENT FEDERAL TRADE WEB SITE DISGORGEMENT COMMERCE AUTHORIZES ISI FRAUDULENT STATEMENT OBTAINING FDCP ACT INJURY |
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MARYLAND
(NORTHERN DIVISION)
________________________________________________
)
FEDERAL TRADE COMMISSION, ))
Plaintiff, )
)
v. ) Civil No.: AMD-01-1121
)
INFORMATION SEARCH, INC., )
a Maryland corporation, )
35 N. Montford Ave., Baltimore City, MD 21224; ))
and ))
DAVID J. KACALA, individually, )
35 N. Montford Ave., Baltimore City, MD 21224 ))
Defendants. )
________________________________________________)
FIRST AMENDED
COMPLAINT FOR INJUNCTIVE
AND OTHER EQUITABLE RELIEF
Plaintiff Federal Trade Commission ("FTC" or "Commission"), by its undersigned
attorneys, alleges as follows:
1. The Commission brings this action under Sections 5(a) and 13(b) of the Federal Trade
Commission Act ("FTC Act"), 15 U.S.C. §§ 45(a) and 53(b), and Section 522(a) of the
Gramm-Leach-Bliley Act ("GLB Act"), 15 U.S.C. § 6822(a), to secure preliminary and
permanent injunctive relief, rescission of contracts, restitution, redress, disgorgement, and
other equitable relief for defendants' violations of Section 521 of the GLB Act, 15 U.S.C.
§ 6821, and Section 5(a) of the FTC Act, 15 U.S.C. § 45(a).
JURISDICTION AND VENUE
2. Jurisdiction is based on 28 U.S.C. §§ 1331, 1337(a), 1345, and 1355, and on 15 U.S.C.
45(a)(1), 53(b), and 6822(a).
3. Venue in the Northern Division of the District of Maryland is proper under 28 U.S.C.
SNIPPETS:
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2
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EX PARTE TEMP RESTRAINING ORDER
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EXTRACTED KEY WORDS
ASSET BUSINESS ACCOUNT PLAINTIFF ACT BANK ACCOUNT OFFICERS DAVID KACALA CONSUMERS TEMPORARY RESTRAINING BUSINESS ENTITY AGENTS EMPLOYEES WITNESS COURT MATTER PARTIES INTEND FEDERAL TRADE COMMISSION VIOLATING FTC GLB ACT UNITED STATES PURPOSES PERSONAL PROPERTY LISTS HEREBY FUNDS |
Plaintiff,
V.
TN-FORMATION SEARCH, INC.,
and
DAVID KACALA, individually
Defendanlrs.
(Proposed) EXPARTE TEMPORARY RESTRAZNlNG ORDER,
LIMITED ASSET FREEZE AND OTHER EOUITABLE RELIEF
.
Plaintiff, Federal Trade Commission ("Commission"),
permanent injunction and other equitable relief in this matter, pursuant
of the Federal Trade Commission Act ("FTC Act"), I5 U.S.C. $9 35(a)
522(a) of the Gramm-Leach-Bliley Act ("CLB Act"), 15 U.S.C. ij
pork for a Temporary Restraining Order pursuant to Rule 65 of the
Procedure, and the Court having considered the complaint,
memorandum of law filed in support thereof, and now being advised in
1. This Court has jurisdiction of the subject matter 01.
cause to believe it will have jurisdiction of all
2. There is good cause to believe that the Commission
establishing that defendants David J. Kacala and Information
engaged and are likely to engage in acts and practices that
the FTC Act, 15 U.S.C. 4 45(a), and Section 52 1 of the GLB
4 6821;
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3
.
COMPLAINT
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EXTRACTED KEY WORDS
DEFENDANTS FINANCIAL INSTITUTION FTC ACT CUSTOMER GLB ACT VIOLATIONS PRACTICES REPRESENTATIVES COMMISSION CONSUMERS RELIEF PLAINTIFF ENFORCE COURT UNFAIR DECEPTIVE ACTS OFFICER BUSINESS FRAUDULENT FEDERAL TRADE WEB SITE DISGORGEMENT COMMERCE AUTHORIZES ISI FRAUDULENT STATEMENT OBTAINING FDCP ACT INJURY |
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MARYLAND
(NORTHERN DIVISION)
________________________________________________
)
FEDERAL TRADE COMMISSION, ))
Plaintiff, )
)
v. ))
INFORMATION SEARCH, INC., )
a Maryland corporation, )
35 N. Montford Ave., Baltimore City, MD 21224; ))
and ))
DAVID J. KACALA, individually, )
35 N. Montford Ave., Baltimore City, MD 21224 ) Civil No.:
)
Defendants. )
________________________________________________)
COMPLAINT FOR INJUNCTIVE
AND OTHER EQUITABLE RELIEF
Plaintiff Federal Trade Commission ("FTC" or "Commission"), by its undersigned
attorneys, alleges as follows:
1. The Commission brings this action under Sections 5(a) and 13(b) of the Federal Trade
Commission Act ("FTC Act"), 15 U.S.C. §§ 45(a) and 53(b), and Section 522(a) of the
Gramm-Leach-Bliley Act ("GLB Act"), 15 U.S.C. § 6822(a), to secure preliminary and
permanent injunctive relief, rescission of contracts, restitution, redress, disgorgement, and
other equitable relief for defendants' violations of Section 521 of the GLB Act, 15 U.S.C.
§ 6821, and Section 5(a) of the FTC Act, 15 U.S.C. § 45(a).
JURISDICTION AND VENUE
2. Jurisdiction is based on 28 U.S.C. §§ 1331, 1337(a), 1345, and 1355, and on 15 U.S.C.
45(a)(1), 53(b), and 6822(a).
3. Venue in the Northern Division of the District of Maryland is proper under 28 U.S.C.
SNIPPETS:
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4
.
STIPULATED FINAL JUDGMENT
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EXTRACTED KEY WORDS
COMMISSION CUSTOMER INFORMATION ACT FINANCIAL INSTITUTION FTC ACT GLB ACT SALE JUDGEMENT COMPLAINT FEDERAL TRADE COMMISSION DAVID CONNECTION PERMANENT KACALA OFFERING INFORMATION SEARCH PRACTICES EMPLOYEES PERMANENT INJUNCTION GRAMM-LEACH-BLILEY ACT PARAGRAPH COMPLIANCE PROVISION FINANCIAL ASSET REPRESENTATIVES INDIVIDUAL FINANCIAL STATEMENTS VIOLATION PROCUREMENT SETTLEMENT |
UNITED STATES DISTRICT COURT
DISTRICT OF MARYLAND
NORTHERN DIVISION
)
FEDERAL TRADE COMMISSION,
)
)
Plaintiff, ))
v. )
)
INFORMATION SEARCH, INC. )
)
and ))
DAVID J. KACALA, individually, )
Defendants. )
)
)
STIPULATED FINAL JUDGMENT AND ORDER FOR PERMANENT INJUNCTION
AND MONETARY RELIEF AGAINST DEFENDANTS
INFORMATION SEARCH, INC. AND DAVID J. KACALA
Plaintiff, the Federal Trade Commission ("FTC" or "Commission"), commenced this
action on April 17, 2001, by filing a Complaint pursuant to Sections 5(a) and 13(b) of the Federal
Trade Commission Act ("FTC Act"), 15 U.S.C. §§ 45(a) and 53(b), and Section 522(a) of the
Gramm-Leach-Bliley Act ("GLB Act"), 15 U.S.C. § 6822(a), charging Defendants Information
Search, Inc. ("ISI") and David J. Kacala ("Kacala") with engaging in unfair or deceptive acts or
practices that violate Section 5(a) of the FTC Act, 15 U.S.C. § 45(a), and practices in violation of
1
Section 521 of the GLB Act, 15 U.S.C. § 6821, in connection with the procurement, sale and
offering for sale, of customer information of a financial institution.
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