DEBRA A. VALENTINE
   General Counsel

   Rolando Berrelez
   Tanya Nathan
   Federal Trade Commission
   600 Pennsylvania Avenue, N.W.
   Washington, D.C. 20580
   (202) 326-3211

   Attorneys for Plaintiff

                        UNITED STATES DISTRICT COURT
                    FOR THE WESTERN DISTRICT OF KENTUCKY
   FEDERAL TRADE COMMISSION, Plaintiff,

   v.

   LAP FINANCIAL SERVICES, INC.,
   a Kentucky Corporation, and

   LOUIS A. POMERANCE, Defendants.


   Civil No.

                    STIPULATED FINAL JUDGMENT AND ORDER

   Plaintiff, Federal Trade Commission ("Commission"), has filed a
   Complaint for a permanent injunction and other equitable relief
   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 108(c) of
   the Truth in Lending Act ("TILA"), 15 U.S.C. § 1607(c), alleging that
   defendants LAP Financial Services, Inc. and Louis A. Pomerance
   ("defendants") have violated TILA, 15 U.S.C. §§ 1601-1666j, as
   amended, including, but not limited to, the Home Ownership and Equity
   Protection Act of 1994 ("HOEPA"), as amended, TILA's implementing
   Regulation Z, 12 C.F.R. 226, as amended, and Section 5(a) of the FTC
   Act, 15 U.S.C. § 45(a), as amended.

   Plaintiff and defendants, by and through their respective counsel,
   have agreed to entry of this Stipulated Final Judgment and Order
   ("Order") by this Court, without trial or adjudication of any issue of
   fact or law. The said parties having requested the Court to enter this
   Order, it is therefore ORDERED, ADJUDGED, AND DECREED as follows:

                                  FINDINGS

   DEBRA A. VALENTINE
   General Counsel

   Rolando Berrelez
   Tanya Nathan
   Federal Trade Commission
   600 Pennsylvania Avenue N.W.
   Washington, D.C. 20580
   (202) 326-3211

   Attorneys for Plaintiff

                        UNITED STATES DISTRICT COURT
                    FOR THE WESTERN DISTRICT OF KENTUCKY
   FEDERAL TRADE COMMISSION, Plaintiff,

   v.

   LAP FINANCIAL SERVICES, INC.,
   a Kentucky Corporation, and

   LOUIS A. POMERANCE, Defendants.
   Civil No.

                     COMPLAINT FOR PERMANENT INJUNCTION
                         AND OTHER EQUITABLE RELIEF

   Plaintiff, the Federal Trade Commission ("Commission"), by its
   undersigned attorneys, alleges as follows:

                           Jurisdiction and Venue

   1. This is an 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 108(c) of the Truth in Lending Act ("TILA"), 15 U.S.C.
   § 1607(c), to obtain preliminary and permanent injunctive relief,
   rescission, restitution, reformation, disgorgement, and other
   equitable relief against defendants for engaging in acts or practices
   in violation of TILA, 15 U.S.C. §§ 1601-1666j, as amended, including,
   but not limited to, the Home Ownership and Equity Protection Act of
   1994 ("HOEPA"), as amended, and TILA's implementing Regulation Z, 12
   C.F.R. 226, as amended, and for unfair or deceptive acts or practices
   in violation of Section 5(a) of the FTC Act, 15 U.S.C. § 45(a), as
   amended.

   2. This Court has subject matter jurisdiction over this matter
   pursuant to 15 U.S.C. §§ 45(a), 53(b), and 1607(c), and 28 U.S.C.
   1331, 1337(a), and 1345.