1 STEPHEN CALKINS
2 General Counsel
CHARLES A. HARWOOD
3 Regional Director
4 TRACY S. THORLEIFSON, WSBA #16623
MARY T. BENFIELD, WSBA #18835
5 KATHRYN C. DECKER, WSBA #12389
Federal Trade Commission
6 915 Second Ave., Suite 2896
Seattle, WA 98174
7 (206) 220-4481 (Thorleifson)
(206) 220-4472 (Benfield)
8 (206) 220-4486 (Decker)
9 Local Counsel:
RONALD R. GALLEGOS, ASBA # 013227
10 Assistant U.S. Attorney
4000 U.S. Courthouse
11 230 N. 1st Avenue
Phoenix, AZ 85045
12 (602) 514-7661
13 ATTORNEYS FOR PLAINTIFF
14 UNITED STATES DISTRICT COURT
15 DISTRICT OF ARIZONA
16 FEDERAL TRADE COMMISSION,
17 Plaintiff,
18 Civ. No.
v.
19 COMPLAINT FOR
LEON SAJA, individually and doing business as PERMANENT INJUNCTION
20 SOUTHWEST PUBLISHING; DONALD L. AND OTHER EQUITABLE
RITTA, individually and as an officer of Stealth RELIEF
21 Publications, Inc.; and
STEALTH PUBLICATIONS, INC.,
22 Defendants.
23
24 Plaintiff, the Federal Trade Commission ("Commission"), for its complaint alleges as
25 follows:
26 1. The Commission brings this action under Section 13(b) of the Federal Trade
27 Commission Act ("FTC Act"), 15 U.S.C. § 53(b), to obtain preliminary and permanent injunctive
28 relief against the defendants to prevent them from engaging in unfair or deceptive acts or
FEDERAL TRADE
915 Second Ave.,
COMPLAINT -- Page 1 of 11 Seattle,
(206)
SNIPPETS:
STEALTH PUBLICATIONS, INC.,
27 Commission Act, 15 U.S.C. § 53, to obtain preliminary and permanent injunctive
28 relief against the defendants to prevent them from engaging in unfair or deceptive acts or
consumers and the public interest resulting from defendants' violations of the FTC Act.
Stealth transacts business in the District of Arizona.
with others, at all times material to this complaint, Ritta has formulated, directed and
Saja is the sole owner of Southwest.
fundraising rooms, has routinely made material misrepresentations to induce consumers and
businesses to donate to various nonprofit organizations.
America, Disabled Peace Officers of America, National Reserve Peace 10 Officers of America,
Any funds collected over that flat amount are retained by Southwest.
20 materials in soliciting the public.
for the purpose of receiving donations.
United Parcel Service for the amount of the donation or sponsorship.
11 enforcement officers calling on behalf of local, county or state law enforcement groups.
12 impression that the caller is a local officer is reinforced to some donors by the
22 Southwest's telefunders regularly misrepresent that contributions will be used to purchase
donors by telephone, defendants represent, expressly or by implication, that the caller is a
of a local law enforcement agency or fire department in the donor's state or local area.
12 constitutes a deceptive act or practice in violation of Section 5of the FTC Act, § 15
In truth and in fact, in numerous instances, the donor's 10 contribution is not tax
|
