JEFFREY KLURFELD, Bar No. 53903
   RAYMOND E. MCKOWN, Bar No. 150975
   Federal Trade Commission
   10877 Wilshire Boulevard, Ste. 700
   Los Angeles, California 90024
   (310) 824-4343 ph.
   (310) 824-4380 fax
   Attorneys for Plaintiff
   FEDERAL TRADE COMMISSION

                        UNITED STATES DISTRICT COURT
                       CENTRAL DISTRICT OF CALIFORNIA
                             EASTERN DIVISION

                   FEDERAL TRADE COMMISSION, Plaintiff,

                                    v.

    RALPH LEWIS MITCHELL, JR., also known as Ralph Lewiss Mitchell, Jr.,
      an individual doing business as Mitchell Enterprises, Millennium
           Group, Diamante Marketing Group, and DMG, Defendant.

            COMPLAINT FOR INJUNCTIVE AND OTHER EQUITABLE RELIEF

   Plaintiff, the Federal Trade Commission ("FTC" or "Commission") for
   its Complaint alleges:

   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 the defendant's deceptive acts or practices in connection
   with the sale and offering for sale of credit repair products in
   violation of Section 5(a) of the FTC Act, 15 U.S.C. § 45(a), and
   Section 404(a)(2) of the Credit Repair Organizations Act, 15 U.S.C.
   § 1679b(a)(2).

                           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 is proper under 28 U.S.C. § 1391 and 15 U.S.C. § 53(b).

                                THE PARTIES

   4. Plaintiff, the Federal Trade Commission, is an independent agency