UNITED STATES DISTRICT COURT
                     FOR THE NORTHERN DISTRICT OF TEXAS
                              DALLAS DIVISION

                       THE FEDERAL TRADE COMMISSION,

                                 Plaintiff,

                                     v.

      JOHN MANCINI, an individual, doing business as CREDIT SERVICES,

                                 Defendant.

                              CIVIL ACTION NO.

                 COMPLAINT FOR INJUNCTION AND OTHER RELIEF

   Plaintiff, the Federal Trade Commission ("FTC" or "the Commission"),
   for its complaint, alleges as follows:

   1. The Commission brings this action under Sections 13(b) and 19 of
   the Federal Trade Commission Act ("FTC Act"), 15 U.S.C. §§ 53(b) and
   57b, and Section 410(b) of the Credit Repair Organizations Act, 15
   U.S.C. § 1679h(b), to obtain preliminary and permanent injunctive
   relief, restitution, rescission, disgorgement and other equitable
   relief for defendant's deceptive acts or practices in connection with
   the sale and offering for sale of credit repair services in violation
   of Section 5(a) of the FTC Act, 15 U.S.C. § 45(a), and the Credit
   Repair Organizations Act , 15 U.S.C. § 1679 et seq.

                           JURISDICTION AND VENUE

   2. This Court has jurisdiction of this matter pursuant to 28 U.S.C.
   1331, 1337(a), and 1345, and 15 U.S.C. §§ 53(b), 57b and 1679h((b).

   3. Venue in this district is proper under 28 U.S.C. §§ 1391(b) and
   (c), and 15 U.S.C. § 53(b).

                                THE PARTIES

   4. Plaintiff, the Federal Trade Commission, is an independent agency
   of the United States Government created by statute. 15 U.S.C. §§ 41 et
   seq. The Commission is charged, inter alia, with enforcement of
   Section 5(a) of the FTC Act, 15 U.S.C. § 45(a), which prohibits unfair
   or deceptive acts or practices in or affecting commerce. The
   Commission also enforces the Credit Repair Organizations Act. 15
   U.S.C. §§ 1679h(a). The Commission is authorized to initiate federal

                        UNITED STATES DISTRICT COURT
                     FOR THE NORTHERN DISTRICT OF TEXAS
                              DALLAS DIVISION

                       THE FEDERAL TRADE COMMISSION,

                                 Plaintiff,

                                     v.

      JOHN MANCINI, an individual, doing business as CREDIT SERVICES,

                                 Defendant.

                       CIVIL ACTION NO. 3-98CV0553-X

        STIPULATED FINAL JUDGMENT AND ORDER OF PERMANENT INJUNCTION

   Plaintiff, the Federal Trade Commission ("FTC" or "Commission"),
   commenced this action by filing a Complaint pursuant to Sections 13(b)
   and 19 of the Federal Trade Commission Act ("FTC Act"), 15 U.S.C.
   53(b) and 57b; and Section 410(b) of the Credit Repair Organizations
   Act, 15 U.S.C. §§ 1679h(b), charging the Defendant in this action with
   violations of Section 5 of the FTC Act, 15 U.S.C. § 45(a) and the
   Credit Repair Organizations Act, 15 U.S.C. § 1679 et seq.

   The Commission and Defendant John Mancini, doing business as Credit
   Services, have agreed to the entry of this Stipulated Final Judgment
   and Order for Permanent Injunction ("Order") by this Court in order to
   resolve all matters of dispute between them in this action. The
   Commission and Defendant have consented to entry of this Final Order
   without trial or adjudication of any issue of law or fact herein.

   Upon the consent of the parties hereto, IT IS HEREBY ORDERED,
   ADJUDGED, AND DECREED as follows:

                                  FINDINGS

   1. This Court has jurisdiction of the subject matter of this case and
   of the parties consenting hereto. Venue in this District is proper.

   2. On March 2, 1998, the Commission filed its complaint for a
   permanent injunction and other equitable relief in this matter, and
   moved for an ex parte Temporary Restraining Order ("TRO") pursuant to
   Rule 65 of the Federal Rules of Civil Procedure, Fed. R. Civ. P. 65.
   An ex parte Temporary Restraining Order was entered on March 2, 1998,
   and a Stipulated Preliminary Injunction was entered on March 9, 1998.