DEBRA A. VALENTINE
General Counsel
CHARLES A. HARWOOD
Regional Director
TRACY S. THORLEIFSON
MAXINE R. STANSELL
Federal Trade Commission
915 Second Avenue, Suite 2896
Seattle, Washington 98174
(206) 220-4481 (Thorleifson)
(206) 220-4474 (Stansell)
(206) 220-6366 (fax)
MONICA TAIT
CA Bar No. 157311
Federal Trade Commission
10877 Wilshire Boulevard
Los Angeles, CA 90024
(310) 824-4318
(310) 824 4380 (fax)
ATTORNEYS FOR PLAINTIFF
UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
FEDERAL TRADE COMMISSION,
Plaintiff,
v.
MITCHELL D. GOLD, individually and as an officer or director of U.S.
Marketing, Inc., and North American Charitable Services, Inc.;
PATRICIA COOLEY GOLD, individually and as a director or manager of
U.S. Marketing, Inc., and North American Charitable Services, Inc.;
HERBERT GOLD, individually and as an officer or director of U.S.
Marketing, Inc.;
CELIA GOLD, individually and as a director or manager of U.S.
Marketing, Inc.;
JONATHAN PHILIP COHEN, individually and as an officer or director of
U.S. Marketing, Inc., and North American Charitable Services, Inc.;
STEVEN JOHN CHINARIAN, individually and as a manager, officer or
director of U.S. Marketing, Inc., and North American Charitable
Services;
U.S. MARKETING, INC., a Nevada Corporation; and
SNIPPETS:
TRACY S. THORLEIFSON MAXINE R. STANSELL
Federal Trade Commission
UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
MITCHELL D. GOLD, individually and as an officer or director of U.S. Marketing, Inc., and
individually and as a director or manager of U.S.
The Commission brings this action under Section 13of the Federal Trade Commission Act ("FTC
ts' violations of the FTC Act.
Venue in the Central District of California is proper under 15 U.S.C. § 53and 28 U.S.C. §
Plaintiff, the Federal Trade Commission, is an independent agency of the United States
The Commission enforces Section 5of the FTC Act, 15 U.S.C. § 45, which prohibits deceptive
Individually or in concert with others, at all times material to this complaint, Mitchell
Defendant Mitchell Gold is married to defendant Patricia Cooley Gold, and all actions
Defendant Herbert Gold is an officer or director of USM.
Defendant Herbert Gold is married to defendant Celia Gold, and all actions conducted by him
Defendant Jonathan Philip Cohen is an officer or director of USM and NACS.
Defendant Steven John Chinarian is a manager, officer or director of USM and is president of
Since at least 1994, defendants have operated as professional fundraisers, contracting with
In addition to directly soliciting the public, defendants also operate through a network of
In numerous instances, defendants and their fundraising agents have not used
These unapproved scripts and printed materials used by defendants and their fundraising
All the subcontractors must do is provide the solicitors, telephone lines and a means to
The solicitors also routinely misrepresent that contributions will directly benefit the
These misrepresentations can be express, such as that donated funds will go to help
In numerous instances, in connection with soliciting contributions from prospective donors,
Such representations include, but are not limited to claims that donated funds will be used
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