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1
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AMENDED COMPLAINT
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EXTRACTED KEY WORDS
FRANCHISE RULE DEFENDANTS ACT FTC ACT VIOLATIONS BUSINESS COURT COMPLAINT RELIEF CONSUMERS PRACTICES UNITED STATES SOUTHERN DISTRICT FLORIDA PROSPECTIVE FRANCHISEES EARNINGS CLAIM PLAINTIFF FEDERAL TRADE COMMISSION BUSINESS VENTURES CIVIL PENALTIES ATTORNEY DISCLOSURE CONSUMER REDRESS ALLEGES CONNECTION PURSUANT CAROUSEL DISPLAY RACK TRANSACTS BUSINESS AWARD |
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
UNITED STATES OF AMERICA, Plaintiff,
v.
TOYS UNLIMITED INTERNATIONAL, INC., a Delaware Corporation;
ROBERT G. GARROW, individually and as an officer of the corporation;
and
ANDREW B. MOSS, individually, and
BRYAN MYLETT, individually, Defendants.
CIV-HIGHSMITH
Case No. 97-08592
FIRST AMENDED
COMPLAINT FOR CIVIL PENALTIES, CONSUMER REDRESS, PERMANENT INJUNCTION,
AND OTHER EQUITABLE RELIEF
___________________________________
Plaintiff, the United States of America, acting upon notification and
authorization to the Attorney General by the Federal Trade Commission
("FTC" or "the Commission"), pursuant to Section 16(a)(1) of the
Federal Trade Commission Act ("FTC Act"), 15 U.S.C. § 56(a)(1), for
its Complaint alleges:
1. Plaintiff brings this action under Sections 5(a)(1), 5(m)(1)(A),
13(b), 16(a), and 19 of the FTC Act, 15 U.S.C. §§ 45(a)(1),
45(m)(1)(A), 53(b), 56(a), and 57b, to secure civil penalties,
consumer redress, a permanent injunction and other equitable relief
for defendants' violations of the FTC's Trade Regulation Rule entitled
"Disclosure Requirements and Prohibitions Concerning Franchising and
Business Opportunity Ventures" ("the Franchise Rule" or "the Rule"),
16 C.F.R. Part 436.
JURISDICTION AND VENUE
2. This Court has jurisdiction over this matter pursuant to 28 U.S.C.
§§ 1331, 1337(a), 1345, and 1355, and 15 U.S.C. §§ 45(m)(1)(A), 53(b),
56(a), and 57b. This action arises under 15 U.S.C. § 45(a)(1).
3. Venue in the United States District Court for the Southern District
of Florida is proper under 28 U.S.C. §§ 1391(b) and (c), 1395(a), and
15 U.S.C. § 53(b).
DEFENDANTS
SNIPPETS:
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2
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STIPULATED JUDGMENT AND ORDER
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EXTRACTED KEY WORDS
STIPULATED JUDGMENT FEDERAL TRADE COMMISSION MOSS AMENDED COMPLAINT UNITED STATES PARTIES COURT ATTORNEY REPRESENTATIVES BUSINESS OFFICER FRANCHISE FTC LAW PARAGRAPH UNITED STATES DISTRICT ROBERT GARROW PERMANENT PLAINTIFF FRANCHISE RULE REFUND REQUEST EMPLOYEES PROVISION COMPLIANCE MAGISTRATE JUDGE TURNOFF NOTIFICATION SETTLEMENT DOCUMENTS RELEVANT |
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
UNITED STATES OF AMERICA
Plaintiff
v.
TOYS UNLIMITED INTERNATIONAL, INC.
a Delaware Corporation;
ROBERT G. GARROW,
individually and as an officer of the corporation;
ANDREW B. MOSS, individually; and
BRIAN J. MYLETT, individually,
Defendants.
Case No. 97-08592
CIV-HIGHSMITH
MAGISTRATE JUDGE TURNOFF
STIPULATED JUDGMENT AND
ORDER FOR PERMANENT INJUNCTION
AGAINST ANDREW B. MOSS AND
TOYS UNLIMITED INTERNATIONAL, INC.
___________________________________
Plaintiff, the 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 and Amended Complaint herein. Defendants Andrew B. Moss
("Moss") and Toys Unlimited International, Inc. ("Toys Unlimited")
have been served with the summons, Complaint and Amended Complaint,
and have filed an Answer. The parties are represented by the attorneys
whose names appear hereafter. The parties agree to settlement of this
action without adjudication of any issue of fact or law and without
defendants admitting liability for any of the violations alleged in
the Amended Complaint.
THEREFORE, on the joint motion of the parties it is hereby ORDERED,
ADJUDGED AND DECREED as follows:
1. This Court has jurisdiction of the subject matter and of the
parties pursuant to 28 U.S.C. §§ 1331 and 1345, and 15 U.S.C. § 45,
53(b) and 57b.
2. The Amended Complaint states a claim upon which relief may be
granted against defendants, under Sections 5(a), 5(m)(1)(A), 13(b) and
19 of the Federal Trade Commission Act ("FTC Act"), 15 U.S.C.
SNIPPETS:
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3
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STIPULATED FINAL JUDGMENT
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EXTRACTED KEY WORDS
STIPULATED JUDGMENT FEDERAL TRADE COMMISSION GARROW COMPLAINT ATTORNEYS PARTIES REPRESENTATIVES FRANCHISE RULE UNITED STATES COURT AMENDED COMPLAINT BUSINESS OFFICERS ROBERT PERMANENT FTC PARAGRAPH EMPLOYEES UNITED STATES DISTRICT VIOLATIONS PROVISION BUSINESS VENTURE REFUND REQUEST COMPLIANCE MAGISTRATE JUDGE TURNOFF PLAINTIFF NOTIFICATION HEREAFTER SETTLEMENT |
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
UNITED STATES OF AMERICA
Plaintiff
v.
TOYS UNLIMITED INTERNATIONAL, INC.
a Delaware Corporation;
ROBERT G. GARROW,
individually and as an officer of the corporation;
ANDREW B. MOSS, individually; and
BRIAN J. MYLETT, individually,
Defendants.
Case No. 97-08592
CIV-HIGHSMITH
MAGISTRATE JUDGE TURNOFF
STIPULATED JUDGMENT AND
ORDER FOR PERMANENT INJUNCTION
AGAINST ROBERT G. GARROW
___________________________________
Plaintiff, the 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. Defendant Robert G. Garrow ("defendant" or
"Garrow"), has been served with the summons and the Complaint and
Amended Complaint and has filed an Answer. The parties are represented
by the attorneys whose names appear hereafter. The parties agree to
settlement of this action without adjudication of any issue of fact or
law and without defendant admitting liability for any of the
violations alleged in the Amended Complaint.
THEREFORE, on the joint motion of the parties it is hereby ORDERED,
ADJUDGED AND DECREED as follows:
1. This Court has jurisdiction of the subject matter and of the
parties pursuant to 28 USC §§ 1331 and 1345, and 15 U.S.C. § 45, 53(b)
and 57b.
2. The Amended Complaint states a claim upon which relief may be
granted against defendant, under Sections 5(a), 5(m)(1)(A), 9, and
13(b) of the Federal Trade Commission Act ("FTC Act"), 15 U.S.C.
45(a), 45(m)(1)(A), 53(b), and 57b.
SNIPPETS:
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