US Federal Trade Commission: paralinkcomp

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UNITED STATES DISTRICT COURTMIDDLE DISTRICT OF FLORIDATAMPA DIVISIONFEDERAL TRADE COMMISSION,Plaintiff,v.PARA-LINK INTERNATIONAL, INC.,a Florida corporation,AAA FAMILY CENTERS, INC., a Floridacorporation,THE LIBERTY GROUP OF AMERICA,INC., a Florida corporation, DEBORAH R. DOLEN, individually andas an officer of PARA-LINKINTERNATIONAL, INC.,MATTHEW SEE, individually and as anofficer of THE LIBERTY GROUP OFAMERICA, INC., andJUDY GRAVES, individually and as anofficer of PARA-LINKINTERNATIONAL, INC., Defendants.CIVIL NO.COMPLAINT FOR INJUNCTIONAND OTHER EQUITABLERELIEF

Plaintiff, the Federal Trade Commission ("FTC" or "the Commission"), for itscomplaint alleges:1.The FTC brings this action under Sections 5(a) and 13(b)

of the Federal TradeCommission Act ("FTC Act"), 15 U.S.C. §§ 45(a) and 53(b), to obtain temporary,preliminary, and permanent injunctive relief, rescission of contracts, restitution,disgorgement, appointment of a receiver, and other equitable relief for defendants'violations of Section 5(a) of the FTC Act, 15 U.S.C. § 45(a).

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JURISDICTION AND VENUE

2.This Court has subject matter jurisdiction over this action pursuant to 28 U.S.C.§§ 1331, 1337(a), and 1345, and 15 U.S.C. § 53(b). This action arises under15 U.S.C. § 45(a)(1).3.Venue in the United States District Court for the Middle District of Florida is properunder 28 U.S.C. §§ 1391(b) and (c), and 15 U.S.C. § 53(b).

THE PARTIES

4.Plaintiff, the Federal Trade Commission, is an independent agency of the United StatesGovernment created by statute. 15 U.S.C. § 41 et seq. The Commission is charged,inter alia, with enforcement of Section 5(a) of the FTC Act, 15 U.S.C. § 45(a), whichprohibits unfair or deceptive acts or practices in or affecting commerce. TheCommission is authorized to initiate federal district court proceedings, by its ownattorneys, to enjoin violations of the FTC Act in order to secure such equitable relief as may be appropriate in each case, and to obtain consumer redress. 15 U.S.C.§ 53(b).5.Defendant Para-Link International, Inc. (“Para-Link”), a Florida corporation with itsprincipal place of business at 205 Montgomery Avenue, Bldg. 1, Sarasota, FL 34243,advertises, promotes, and sells paralegal training and employment opportunities. Para-Link also uses the address 2020 Pennsylvania Ave., NW, Washington, DC 20006,which is a mail drop. Para-Link formerly operated under the name Para-Link, Inc., adefunct corporation. Para-Link also does business under the name, The NationalAssociation of Independent Paralegals. Para-Link transacts or has transacted businessin the Middle District of Florida.

Page 3 of 126.Defendant AAA Family Centers, Inc., (“AAA”) a Florida corporation with its principalplace of business at 205 Montgomery Avenue, Bldg. 1, Sarasota, FL 34243,advertises, promotes, and sells paralegal training and employment opportunities. AAAtransacts or has transacted business in the Middle District of Florida.7.Defendant The Liberty Group of America, Inc. (“LGA”), a Florida corporation withits principal place of business supposedly located at 1406 Hays St. Suite 2,Tallahassee, Florida 32301, but actually located at 205 Montgomery Avenue, Bldg. 1,Sarasota, FL 34243, advertises, promotes, and sells paralegal training and employmentopportunities. LGA transacts or has transacted business in the Middle District of Florida.8.Defendant Deborah R. Dolen (“Dolen”) is the president of Para-Link and the vice-president of AAA. Dolen’s principal place of business is 205 Montgomery Avenue,Bldg. 1, Sarasota, FL 34243. Dolen also acts as a “consultant” to LGA. At all timesmaterial to this complaint, acting alone or in concert with others, she has formulated,directed, controlled, or participated in the acts and practices of Para-Link, AAA, andLGA, including the acts and practices set forth in this complaint. She transacts or hastransacted business in the Middle District of Florida.9.Defendant Matthew See (“See”) is the Director and President of LGA. See’s principalplace of business is 205 Montgomery Avenue, Bldg. 1, Sarasota, FL 34243. At alltimes material to this complaint, acting alone or in concert with others, he hasformulated, directed, controlled, or participated in the acts and practices of LGA,Para-Link, and AAA, including the acts and practices set forth in this complaint. Hetransacts or has transacted business in the Middle District of Florida.10.Defendant Judy Graves (“Graves”) is the vice-president of Para-Link. Grave’sprincipal place of business is 205 Montgomery Avenue, Bldg. 1, Sarasota, FL 34243.

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