1 WILLIAM E. KOVACIC
General Counsel
2 JANICE L. CHARTER
3 JEROME M. STEINER, JR.
Federal Trade Commission
4 901 Market Street, Suite 570
San Francisco, CA 94103
5 Phone (415) 848-5100/ fax (415) 848-5184
6 BLAINE T. WELSH
Assistant United States Attorney
7 333 Las Vegas Blvd, South, Suite 5000
Las Vegas, NV 89101
8 Phone (702) 388-6336
9 Attorneys for Plaintiff
Federal Trade Commission
10
11 UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA
12
13 FEDERAL TRADE COMMISSION, CV-S-02-0131-LRH-PAL
14
Plaintiff, COMPLAINT FOR INJUNCTION
15 AND OTHER EQUITABLE
v. RELIEF
16
NATIONAL AUDIT DEFENSE
17 NETWORK, INC., a Nevada
Corporation; TAX COACH, INC.,
18 a Nevada Corporation doing
business as TAX READY;
19 ROBERT BENNINGTON,
20 individually and as an officer
of National Audit Defense
21 Network, Inc., and Tax Coach,
Inc.; CORT CHRISTIE,
22 individually and as an officer
of National Audit Defense
23 Network, Inc.; and AL
RODRIGUEZ, individually,
24
Defendants.
25
26 Plaintiff, the Federal Trade Commission ("the FTC" or "the
27 Commission"), for its complaint alleges:
28
COMPLAINT 1
SNIPPETS:
333 Las Vegas Blvd, South, Suite 5000
Attorneys for Plaintiff Federal Trade Commission
17 NETWORK, INC., a Nevada Corporation;
business as TAX READY;
20 individually and as an officer of National Audit Defense
13of the Federal Trade Commission Act, 15 U.S.C. 3 §§ 45and 53, and the Truth in Lending Act,
U.S.C. § 1601 et seq., to obtain permanent injunctive relief,
and other equitable relief for defendants'
FTC Act, 15 U.S.C. § 45, and Section 226.12of Regulation
Z, 12 C.F.R. § 226.12, which implements the TILA
20 FTC Act, 15 U.S.C. § 45, which prohibits unfair or deceptive
21 acts or practices in or affecting commerce.
22 initiate federal district court proceedings by its own attorneys
23 to enjoin violations of the FTC Act and to secure such equitable
24 relief as may be appropriate in each case, including restitution
services that purport to assist consumers in reducing their
business in the District of Nevada.
Nevada, advertises, promotes, offers for sale, and sells programs 10 and services that
Tax Ready transacts or has transacted
14 officer or director of NADN and Tax Ready.
18 practices set forth in this complaint.
offer consumers an unconditional 30-day money-back guarantee.
25 frustrate consumers in a variety of ways from receiving refunds
26 request refunds pursuant to defendants' money-back guarantees.
creditors to promptly credit a consumer's credit card account 10 upon acceptance of the
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