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10 2 13 14 15 16 7 18 19 20 2 22 23 24 25 26 27 28 IWILLIAM E. KOVACIC General Counsel i KATHERINE ROMANO SCHNACK THERESE L. TULLY lrederal Trade Commission Iss East Monroe Street, Suite 1860 chicago, Illinois 60603 (312) 960-5634 [Ph.] (312) 960-5600 [Fax] IPAYE CHEN BARNOUW (CA Bar #168631) Federal Trade Commission 10877 Wilshire Boulevard, Suite 700 tos Angeles, California 90024 (310) 824-4316 [Ph.] (310) 824-4380 [Fax] Attorneys for Plaintiff FEDERAL TRADE COMMISSION UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA WESTERN DIVISION . i EDERAL ‘TRADE, COMMISSION, Civ. No. asodeybses MMM (ATW) we Te Plaintiff, JMEALTHCARE CLAIMS NETWORK, INC., ) STIPULATED FINAL JUDGMENT AND la California corporation, doing) _) ORDER FOR PERMANENT INJUNCTION Isusiness as MED DATA SOLUTIONS and ) AND OTHER EQUITABLE RELIEF SOUTHERN CALIFORNIA BILLING ) AS TO DEFENDANTS ANNE MILLER SERVICES, ) AND STANFORD MILLER STANFORD MILLER, individually and doing business as MEDICAL CLAIMS INBTWORK, CHARLES G. LLOYD, individually and doing business as MED DATA SOLUTIONS, and as an officer of ]HBALTHCARE CLAIMS NETWORK, INC., la California corporation, and JANNE MILLER, individually and doing business as MED DATA SOLUTIONS, and as an officer of HEALTHCARE CLAIMS NETWORK, INC., ja California corporation, Defendants. 31 Seerasy MW B 14 15 16 7 18 19 20 21 23 24 25 26 27 28 Plaintiff, the Federal Trade Commission ("Commission"), ui commenced this action on June 11, 2002 by filing its Complaint for, injunctive and Other Equitable Relief pursuant to Section 13(b) of the Federal Trade Commission Act (“FTC Act”), 15 U.S.C. § 53(b), charging that Defendants Charles G. Lloyd, Anne Miller, and liealthcare Claims Network, Inc., d/b/a Med Data Solutions, Southern california Billing Services, Medical Claims Network, and Probillers, lwere engaged in deceptive acts or practices in violation of Section Is of the FTC Act, 15 U.S.C. § 45, in connection with the advertising, telemarketing, offering for sale, and sale of work-at-home medical billing employment opportunities. The Commission amended its complaint to name Stanford Miller, individually and doing business as Medical Claims Network, as a defendant, and to remove Medical Claims INetwork and Probillers as d/b/a’s for defendant Healthcare Claims INetwork, Inc. ("Amended Complaint”). The Commission and Defendants Anne Miller and Stanford Miller (*Defendants” as defined in this Order), hereby stipulate to entry of this Stipulated Final Judgment and Order for Permanent Injunction and lother Equitable Relief as to Defendants Anne Miller and Stanford Mi1ler (vorder”) . NOW THEREFORE, the Commission and Defendants having requested the Court to enter this Order, IT IS HEREBY ORDERED, ADJUDGED AND DECREED as follows: FINDINGS 1. This is an action by the Commission instituted under sections 5 and 13(b) of the PIC Act, 15 U.S.C. §§ 45 and 53(b). Ithe Amended Complaint seeks permanent injunctive relief against lbefendants in connection with the advertising, offering for sale, 2 woe eo Seoerslsa uN 1B 4 15 16 7 18 19 20 21 22 23 24 25 26 27 28 \ e ® land sale of work-at-home medical billing employment opportunities, land equitable monetary relief in the form of consumer redress and/or disgorgement. : 2. This Court has jurisdiction over the subject matter of this action and the parties. 3. Venue is proper as to all parties in the Central District lof California. 4. The Commission’s Amended Complaint states claims upon which relief may be granted against Defendants under Sections 5(a) land 13(b) of the FIC Act, 15 U.S.C. §§ 45(a) and $3(b). 5. The Commission has the authority under Section 13(b) of the FTC Act to seek the relief it has requested. 6. The activities of Defendants, as alleged in the Amended complaint, are in or affecting commerce, as defined in Section 4 of the FTC Act, 15 U.S.C. § 44. 7. Defendants have entered into this Order freely and without coercion. Defendants further acknowledge that they have lead the provisions of this Order and are prepared to abide by them. 8. The Commission and Defendants stipulate and agree to this lorder, without trial or final adjudication of any issue of fact or haw, to settle and resolve all matters in dispute between them arising from the Amended Complaint up to the date of entry of this lorder. This Order is for settlement purposes only and does not constitute and shall not be interpreted to constitute an admission lby Defendants that they have engaged in violations of any law or regulation, including but not limited to the PIC Act. 9. Defendants waive all rights to seek judicial review or 3