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1
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ORDER FOR PRELIMINARY INJUNCTION
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EXTRACTED KEY WORDS
FEDERAL TRADE COMMISSION MARKETING PROGRAM PLAINTIFF OFFICER TEXAS EQUITABLE RELIEF COURT TRUST PARTICIPATION ASSETS USASURANCE GROUP DELAWARE LLC ACT BUSINESS PERSONAL SERVICE JJS FTC PURSUANT MLM MARKETING PROGRAM REPRESENTATIONS EARNINGS ACTIVE CONCERT OFFERING ADVERTISING PROMOTING COLORADO CORPORATION JURISDICTION AKAHICOM |
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4 . t I
UNITED STATES DISTRICT COURT
DISTRICT OF MARYLAND
NORTHERN DIVISION
FEDERAL TRADE COMMISSION,
Plaintiff,
V. 1 ) ORDER FOR
* JOHN T. POLK, individually and as an officer of the ) PRELIMINARY INJUNCTION
corporate defendant(s), ) AND OTHEREQUITABLE
PATRICK FARAH, individually and as an offker of the ) RELIEF
corporate defendant(s),
PETER HIRSCH, individually and as an officer of the
corporate defendant(s),
USASURANCE GROUP, INC., a Colorado corporation,
AKAHI CORP.,. a Texas and Colorado corporation,
AKAHLCOM, ,CORP., a Texas corporation,
2XTREME PERFORMANCE INTERNATIONAL, LLC,
a Delaware LLC,
AFEW, INC., a Delaware corporation,
Defendants.
Plaintiff, the Federal Trade Commission ("FTC" or the "Commission"),. having filed its
for injunctive and other equitable relief in this matter pursuant to Section 13(b) of the Federal
Commission Act ("FTC Act"), 15 U.S.C. 5 53(b), and the Court, having
declarations, exhibits, and memorandum of law filed in support
1. This Court has jurisdiction over the subject matter of this case,
cause to believe it will have jurisdiction of all parties hereto;
2. There is good cause to believe that defendants &&&%Pq& Patrick Farah, w
Hi@, USAsurance Group, Inc., Akahi Corp., Akahicom, Corp, 2Xtreme Performance
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2
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COMPLAINT
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EXTRACTED KEY WORDS
FTC ACT FEDERAL TRADE COMMISSION PRACTICES TEXAS DISTRICT RELIEF MLM BUSINESS VIOLATION AKAHI UNITED STATES COURT COLORADO CORPORATION LLC DECEPTIVE ACTS COMPLAINT AFEW CONSUMERS RECRUITING TOOLS COMPENSATION PLANS INJUNCTIVE RELIEF EQUITABLE RELIEF PLAINTIFF REPRESENTATIONS USASURANCE GROUP DELAWARE CORPORATION SUBSTANTIAL INCOME MARKETING MATERIALS PATRICK FARAH PETER HIRSCH |
UNITED STATES DISTRICT COURT
DISTRICT OF MARYLAND
NORTHERN DIVISION
FEDERAL TRADE COMMISSION
Plaintiff
v.
JOHN T. POLK, individually and as an officer of the corporate
defendant(s),
PATRICK FARAH, individually and as an officer of the corporate
defendant(s),
PETER HIRSCH, individually and as an officer of the corporate
defendant(s),
USASURANCE GROUP, INC., a Colorado corporation,
AKAHI CORP., a Texas and Colorado corporation,
AKAHI.COM, CORP., a Texas corporation,
2XTREME PERFORMANCE INTERNATIONAL, LLC, a Delaware LLC,
AFEW, INC., a Delaware corporation,
Defendants.
CIVIL NO.
COMPLAINT FOR INJUNCTIVE AND OTHER EQUITABLE RELIEF
Plaintiff, the Federal Trade Commission ("FTC" or "Commission"), for
its Complaint alleges as follows:
1. The Commission brings this action under Section 13(b) of the
Federal Trade Commission Act ("FTC Act"), 15 U.S.C. § 53(b), to obtain
preliminary and permanent injunctive relief against the defendants to
prevent them from engaging in deceptive acts or practices in violation
of Section 5(a) of the FTC Act, 15 U.S.C. § 45(a), and to obtain other
equitable relief, including rescission, restitution, and disgorgement,
as is necessary to redress injury to consumers and the public interest
resulting from defendants' violations of the FTC Act.
JURISDICTION AND VENUE
2. Subject matter jurisdiction is conferred upon this Court by 15
U.S.C. §§ 45(a), 53(b), 57b, and 28 U.S.C. §§ 1331, 1337(a), and 1345.
3. Venue in the United States District Court for the District of
Maryland, Northern Division, is proper under 15 U.S.C. § 53(b), as
amended by the FTC Act Amendments of 1994, Pub. L. No. 103-312, 108
Stat. 1691, and 28 U.S.C. §§ 1391(b) and (c).
PLAINTIFF
4. Plaintiff, the Federal Trade Commission, is an independent agency
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3
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STIPULATED FINAL JUDGMENT - POLK
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EXTRACTED KEY WORDS
COMMISSION POLK BUSINESS COURT JOHN AFEW EMPLOYEES MULTI-LEVEL MARKETING ENTRY MARKETING PROGRAM FTC MATTER PURSUANT PURPOSES DISTRICT ACT JUDGEMENT PERSONNEL REPRESENTATIVES COMPLAINT LAW BUSINESS OPPORTUNITY COMPLIANCE FEDERAL TRADE COMMISSION AGENTS SALE UNITED STATES PARAGRAPH PETITION |
UNITED STATES DISTRICT COURT
*T ~CT!!acRS
CLERK
U.S. r,,SIR:CyouG1
O,S-.fq~T
CF hmn Jy,,P* I-P DISTRICT OF MARYLAND
NORTHERN DIVISTON
w
-1
FEDERAL TRADE COMMISSION, >
) CIVIL
Plaintiff, )
V. )
)
JOHN T. POLK, individually and as an officer of the )
corporate defendant(s), ) AS TO
PATRICK FARAH, individually and as an officer of the ) JOHN T. POLK AND AFEW, INC
corporate defendant(s), >
PETER HIRSCH, individually and as an officer of the 1
corporate defendant(s), )
IJSASURANCE GROUP, INC., a Colorado corporation, >
AKAHl CORP., a Texas and Colorado corporation, >
AKAHLCOM CORP., a Texas corporation, >
2XTREME PERFORMANCE INTERNATIONAL, LLC, 1
a Delaware LLC, and >
AFEW, INC., a Delaware corporation, >
)
Defendants. 1
, `--.-
I ; I.. ;,; 1,' :;`t_f.!,l~;
&23
I L _-._-..
--. ..- .--.___
- .--.
On December 9, 1999, plaintiff, the Federal Trade Commission ("FTC" or the
tiled its complaint for injunctive and other equitable relief in this matter pursuant to
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4
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STIPULATED FINAL JUDGMENT - HIRSCH
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EXTRACTED KEY WORDS
COMMISSION COURT FEDERAL TRADE COMPLAINT MULTI-LEVEL MARKETING PROGRAM BUSINESS SALE PURSUANT FTC ACT MATTER PARAGRAPH PETER HIRSCH PARTICIPATION SELLING OFFERING PROMOTING ADVERTISING ASSISTING BUSINESS OPPORTUNITY CAPACITY WHATSOEVER EMPLOYEES MATERIALS LLC PLAINTIFF VIOLATION STIPULATED PRELIMINARY INJUNCTION CONNECTION CONSUMER COMPLAINTS REPRESENTATIVES |
_, ,.-'
`;7;`3 i;;:`,-ICE
`ir l2<i&JRE
UNITEDFJATES DIS'@&~~OURT-, .
DlSTRICT OF MARYLAND
NORTHERN DIVISION
. . FEDERAL TRADE COMMISSION,
) CIVIL NO.
Plaintiff, 1
V. ) STIPULATED
) JUDGMENT
JOHN T. POLK, individually and as an officer of the ) PERMANENT
corporate defendant(s), ) AS TO
PATRlCK FARAH, individually and as an officer of the ) PETER HIRSCH
corporate defendant(s), )
PETER HIRSCH, individually and as an officer of the )
corporate defendant(s), 1
USASURANCE GROUP, INC., a Colorado corporation, )
AKAHI CORP., a Texas and Colorado corporation, )
AKAHLCOM CORP., a Texas corporation, 1
2XTREME PERFORMANCE INTERNATIONAL, LLC, )
a Delaware LLC, and
AFEW, INC., a Delaware corporation,
Defendants.
On December 9, 1999, plaintiff, the Federal Trade Commission ("FTC" or the
filed its complaint for injunctive and other equitable relief in this matter pursuant
Federal Trade Commission Act ("FTC Act"), 15 U.S.C. 0 53(b), charging defendants John
Patrick Farah, Peter Hirsch,`USAsurance Group, Inc., Akahi Corp., Akahixom Corp.,
Performance International, LLC, and AFEW, Inc. with violations of Section 5 of the FTC
9 45(a). On or about January 27,2000, the Court entered a Stipulated Preliminary
. .
Defendant Peter Hirsch. The Commission, by and through its counsel, and defendant Peter
having received advice of counsel, have agreed and stipulated to the entry by this Court of
Final Judgment and Order for Permanent Injunction as to defendant Peter Hirsch ("Final
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5
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STIPULATED FINAL JUDGMENT - FARAH
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EXTRACTED KEY WORDS
COMMISSION PATRICK FARAH COMPLAINT COURT ENTRY FEDERAL TRADE COMMISSION PURSUANT BUSINESS FTC ACT MATTER PERMANENT SALE JUDGEMENT MULTI-LEVEL MARKETING COUNSEL PARTICIPATION TESTIMONY FINANCIAL STATEMENT PARAGRAPH EMPLOYEES REPRESENTATIVES PLAINTIFF PERMANENT INJUNCTION UNITED STATES BUSINESS OPPORTUNITY MATERIALS PERSONAL SERVICE PROMOTING INDEPENDENT CONTRACTOR |
AT RACTII~R~
CLERK U.S. DlSTRLCl CO\JRT
D\$,TR:CT CF WARYahD DEPm
BY
UNITED STATES DISTRICT COURT
DISTRICT OF MARYLAND
NORTHERN DIVISION
FEDERAL TRADE COMMISSION, ) ) CIVIL NO.
Plaintiff, )
V. ) STIPULATED
) JUDGM-ENT AND
JOHN T. POLK, individually and as an officer of the ) PERMANENT
corporate defendant(s), ) AS TO
PATRICK FARAH, individually and as an officer of the ) PATRICK FARAH
corporate defendant(s), )
PETER HIRSCH, individually and as an officer of the )
corporate defendant(s), )
USASURANCE GROUP, INC., a Colorado corporation, )
AKAHI CORP., a Texas and Colorado corporation, 1
AKAHLCOM CORP., a Texas corporation, 1
2XTREME PERFORMANCE INTERNATIONAL, LLC, )
a Delaware LLC, and 1
AFEW, INC., a Delaware corporation, >
1
Defendants. )
On December 9, 1999, plaintiff, the Federal Trade Commission ("FTC" or the
filed its complaint for injunctive and other equitable relief in this matter pursuant to
Federal Trade Commission Act ("FTC Act"), 15 U. SC. 9 53(b), charging defendants John T.
Patrick Farah, Peter Hirsch, USAsurance Group, Inc., Akahi Corp., Akahicom Corp., 2Xtreme
Performance International, LLC, and AFEW, Inc. with violations of Section 5 of the FTC
4 45(a). After holding a hearing on February 24 and 25,2000, hearing testimony and
evidence, this Court entered a Preliminary Injunction as to Defendant Patrick Farah on
2000. The Commission and defendant Patrick Farah, by and through their counsel, have
stipulated to the entry by this Court of a Stipulated Final Judgment and Order for
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