UNITED STATES DISTRICT COURT
                    FOR THE EASTERN DISTRICT OF MICHIGAN

                         UNITED STATES OF AMERICA,

                                 Plaintiff,

                                     v.

     EQUITY FUNDING & ASSOCIATES, INC., a/k/a EQUITY FUNDING INSURANCE
     AGENCY, INC., a corporation, and JOHN CINI, individually and as an
                        officer of  the corporation,

                                Defendants.

                                 CIVIL NO.

        COMPLAINT FOR CIVIL PENALTIES, INJUNCTIVE, AND  OTHER RELIEF

   Plaintiff, the United States of America, acting upon notification and
   authorization to the Attorney General by the Federal Trade Commission
   ("Commission"), for its complaint alleges that:

   1. Plaintiff brings this action under Sections 5(a)(1), 5(m)(1)(A),
   13(b), 16(a), and 19 of the Federal Trade Commission Act ("FTC Act"),
   15 U.S.C. §§ 45(a)(1), 45 (m)(1)(A), 53(b), 56(a), and 57b, and
   Section 410(b) of the Credit Repair Organizations Act, 15 U.S.C.
   1679h(b), to obtain monetary civil penalties, consumer redress and
   injunctive and other relief for Defendants' violations of the Credit
   Repair Organizations Act, 15 U.S.C. § 1679-1679j; and consumer redress
   and injunctive and other relief for Defendants' violations of Section
   5(a)(1) of the FTC Act, 15 U.S.C. § 45(a)(1).

                           JURISDICTION AND VENUE

   2. This Court has jurisdiction of this matter pursuant to 28 U.S.C.
   1331, 1337(a), 1345, 1355 and pursuant to 15 U.S.C. §§ 45(m)(1)(A),
   53(b), 56(a), 57b, and 1679h(b)(2). This action arises under 15 U.S.C.
   §§ 45(a)(1) and 1679h(b).

   3. Venue in this district is proper under 15 U.S.C. § 53(b) and under
   28 U.S.C. § 1391(b) and (c) and 1395(a).

                                 DEFENDANTS

   4. Defendant Equity Funding & Associates, Inc. (hereinafter "Equity
   Funding") is a Michigan corporation with its office and principal
   place of business located at 7071 Orchard Lake Road, Suite 300, West

                        UNITED STATES DISTRICT COURT
                    FOR THE EASTERN DISTRICT OF MICHIGAN

                    UNITED STATES OF AMERICA, Plaintiff,

                                     v.

     EQUITY FUNDING & ASSOCIATES, INC., a/k/a EQUITY FUNDING INSURANCE
    AGENCY, INC., a corporation, and  JOHN CINI, individually and as an
                  officer of the corporation. Defendants.

                             CIVIL NO. 98-70995

                                JUDGE DUGGAN
                          MAGISTRATE JUDGE KOMIVES

                             STIPULATED CONSENT
                 DECREE AND ORDER FOR PERMANENT INJUNCTION

   Plaintiff United States of America, acting upon notification and
   authorization to the Attorney General by the Federal Trade Commission
   ("FTC" or the "Commission"), has commenced this action by filing the
   Complaint herein. Defendants Equity Funding & Associates, Inc.. and
   John Cini have been served with the summons and the complaint. The
   parties to this action are represented by the attorneys whose names
   appear hereafter; and the parties agree to settlement of this action
   without adjudication of any issue of fact or law and without the
   defendants admitting liability for any of the violations alleged in
   the Complaint;

   NOW, THEREFORE, on the joint motion of the parties, IT IS HEREBY
   ORDERED, ADJUDGED, AND DECREED as follows:

                                  FINDINGS

   1. This Court has jurisdiction of the subject matter of this case and
   of the parties pursuant to 28 U.S.C. §§ 1331, 1337(a), 1345 and 1355,
   and 15 U.S.C. §§ 45, 56(a), 57b, and 1679h(b)(2).

   2. The Complaint states a claim upon which relief may be granted
   against the defendants, under Sections 5(a), 5(m)(1)(A), and 19 of the
   Federal Trade Commission Act ("FTC Act"), 15 U.S.C. §§ 45(a),
   45(m)(1)(A), and 57b; and under Section 410(b) of the Credit Repair
   Organizations Act ("CROA"), 15 U.S.C. § 1679h(b).

   3. The activities of the defendants as alleged in the Complaint are or
   were in or affecting commerce, as defined in 15 U.S.C. § 44. The
   activities of the defendants as alleged in the Complaint bring them