UNITED STATES DISTRICT COURT
                        FOR THE WESTERN DISTRICT OF NEW YORK

___________________________________________
                                                         )
UNITED STATES OF AMERICA,                                ) )
                        Plaintiff,                       ) )
               v.                                        )          Civil Action No.
                                                         )
NORTH AMERICAN CAPITAL CORPORATION, )
        a New York corporation,                          ) )
                        Defendant.                       )
                                                         )
__________________________________________ )
        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(m)(1)(A), 9, 13(b), and 16(a) of the

Federal Trade Commission Act ("FTC Act"), 15 U.S.C. §§ 45(m)(1)(A), 49, 53(b), and 56(a) and

Section 814 of the Fair Debt Collection Practices Act ("FDCP Act"), 15 U.S.C. § 1692 1, to obtain

monetary civil penalties and injunctive or other relief for the Defendant's violations of the FDCP

Act.

                                      JURISDICTION AND VENUE

        2.     This Court has jurisdiction over the action pursuant to 28 U.S.C. §§ 1331, 1337(a),

1345, and 1355, and under 15 U.S.C. §§ 45(m)(1)(A), 49, 53(b), 56(a) and 16921.

        3.     Venue in the Western District of New York is proper under 15 U.S.C. § 53(b) and

under 28 U.S.C. §§ 1391(b) - (c) and § 1395(a).

                                              DEFENDANT


                                          Complaint, Page 1 of 6



       4.      Defendant North American Capital Corporation ("NACC") is a New York

                               UNITED STATES DISTRICT COURT
                        FOR THE WESTERN DISTRICT OF NEW YORK

__________________________________________
                                                         )
UNITED STATES OF AMERICA,                                ) )
                        Plaintiff,                       ) )
               v.                                        )          Civil Action No.
                                                         )
NORTH AMERICAN CAPITAL CORPORATION, )
       a New York corporation,                           ) )
                        Defendant.                       )
                                                         )
__________________________________________ )



                                         CONSENT DECREE

       WHEREAS:  Plaintiff, the United States of America, has commenced this action by filing

the complaint herein; Defendant has waived service of the summons and complaint; the parties have

been represented by the attorneys whose names appear hereafter; and the parties have agreed to

settlement of this action upon the following terms and conditions, without adjudication of any issue

of fact or law and without Defendant admitting liability for any of the matters alleged in the

complaint;

       THEREFORE, on the joint motion of Plaintiff and Defendant, it is hereby ORDERED,

ADJUDGED, and DECREED as follows:

       1.      This Court has jurisdiction of the subject matter and of the parties.

       2.      The complaint states a claim upon which relief may be granted against the




                                       Consent Decree, Page 1 of 12



Defendant under Sections 5(a)(1), 5(m)(1)(A), 9, 13(b), and 16(a) of the Federal Trade

Commission Act, 15 U.S.C. §§ 45(a)(1), 45(m)(1)(A), 49, 53(b), and 56(a), and Section 814 of the