!".

"
:. • ~. I

",
~

i.
~ 'I •

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:

.... .~. ",.

. '"

.

1 2
3

STEPHEN General DAVID
n~N'TF.I..

CALKINS counsel

C. FIX A. SPIRO
Penn. Ave. NW, Rm. 200

FA' aUF ABDULLAH

4 5
6 7

Federal Trade Commission
6th arid
f

Washington~ DC

(202) 32~-3288 (voice) (202) 326-2050 (facsimile) M. 8TBINER, JR.

20580

Et.. ..... '

l\i"'";' _ •• - .....

-

--

11."
.if ..
11 ..

.;~""\

1",,1

RALPH E. STONE

JEROME

S·ERVED

8 9

10 11
12

Federal Trade Commission 901 Market St., Suite 570 San Francisco, CA 94103 (415) 7~4-7920 (voice) (415) 744-7940 (facsimile) States Attorney

DEC I 6 1996

BLAINE T. WELSH Assistant United

13

Las Vegas, NV

701 E. BringRr

(702) 388-6336

89101

14
15
16

Attorneys for Plaintiff

UN1TED STATES DISTRICT
DISTRICT

OF NEVADA
) } ) } ) ) ) ) ) )

COURT

17 18 19 20

FEDERAL

TRADE COMMISSION,

Plaintiff,

v. THADOW, INC., et al.

CV-f.:;-!::I':I-';:i-JiDM

(LRL)

z i. 22
23
24

----------------------------)
INJUNCTION

Defendants.

.

STIPULATED

AND JUDGMENT

FINAL ORDER FOR PERMANENT
FOR MQW~TARY

RBLIRF

26 27

Plaintiff,

Federal

Trade Commission

(nCommissionft), has

1
2

filed a Complaint equitable relief

for a permanent
pursuant

injunction
~3 (b) o f

and other
the Fede:r..-al Tl.-ade charging

to Section

3

r.nmmission Act, defendants individually
violations
a~ amended/

(IIFTC Act II).

15 U. S. C.

s

53 (b).

4
5

Thadow,

Inc .. a corporation,

and Alex Norman, with
Act,

and as an officer of Section
~5 U.S.C.

of said corporation

6
7

S(a) of the Federal Trade Commission
§

1S{~}.

8

Defendants Stipulated

and the Commission

have agreed

to entry

of this

9 10
11
~2

Final Order.for Relief

Permanent

Injunction

and Judgment
have
LzLa L,

for Monetary
consented

(IIFinal Judgmentl1).

Defendants

to the entry of this Final Judgment

withuuL

Defendants

Thadow,

Inc., a corporation.

and Alex Norman, and the Court to

13 14
15 ~G

individually and as an officer plaintiff Federal

of said corporationt have requested

Trade Commission,
Judgment.

enter this Fin~l

The Court accordingly finds:

17
18

(A)
Sections

This is an action by the Commission

instituted

under

S(a) and 13(b) of the FTC Act, lS U.S.C ..§§ 45(a) and

19
20
21.

53(b).

The Complaint
redress

seeks both permanent
for alleged unfair

injunctive

relief
acts or

I

and consumer practices
by

or deceptive

the defendants

in connection

with the offering

to

22 23
24 25
26 27

consumers of prizes or awards in return for the consumers' donation
(B)

of funds to a non-profit
The Commission 15 U.S.C.
fl

charitable

organization. 13{b)

has the authority

under Section

of the hct, requested;

53(b). to seek tha r91i~f it hag

Stipulated

Final Order and Injunction

Page 2 of 17

1

(C)

This Court has jurisdiction jurisdiction

over the subject matter

2
3

of this case and has
VenuE! in the

over each of the der~llfld.llLs. and the Complaint

n'i 8t.ri c:t_ of

t:Jevadais proper,

4
5

states

a claim upon which under 45(a) Sections and 53(b).

relief may be granted
5(a)

against 15

defendants

and 13(b) of the FTC Act,

6
7

u.s.c.

§§
(D)

The activities as defined Defendants

of the dcfcndunto
§

are in or affecting

8 9
10

commerce, (E) neither

in 15 U.S.C. Thadow,

44; while of to

Inc. and Alex Norman,

admitting

nor denying

any of the allegations

11
12

wrongdoing

set Eorth in the complaint,
i

offer no opposition

the E!ntry of this P,;"", 1 c'Tudgment (F)

13 14 15 ~6 17 18 19 20 :;n 22

Each of the defendants
review

has agreed

to waive

all rights
the

to seek judicial validity

or otherwise

challenge

or contest also has

of this Final Judgment.

Each defendant

a9r~~d to waive any claim that the defendant under the Equal Access to Justice

may have held
§

Act, 28 U.S.C.

2412,

concerning

the prosecution

of this action

to the date of entry

of this Final Judgment; (G) addition provided This action and th~ relief awarded herein is in

to, and not in liE!u of, other remedies by law, including

~~ m~y b~ remedies;

both civil and criminal

23
·24

and
(H) interest. Entry of this Final Judgment is in the public

25

26
27

IT IS THEREBY ORDERED, ADJUDGED AND DECREED AS FOLLOWS:

Stipulated

Final Order

and Injunction

Page 3 of 17

1 2
3 For the

DEFINITIONS
I.

pl1rp.t""l~~~ of this Final

Judgment.

the following

4
5 6
7 8

definitions
(A) activity
charitable

shall apply:
"Business of telemarketingll attempts
to

refers

to any business to make any
a pri2~ or

involving

to induce consumers enter any contest

contribution,

for

award,

or to purchase
I

any good or service

by means

of telephone with that

9 10 11
~2

sales presentations the use of other

either exclusively

or in conjunction Provided, however,

forms of marketing.

the "business
ac t
Lv

of telemarketing"
involves

does not include business face-to-face

i.t.y

t.h;':.lt.

8ubstantial

contact between
from

13 14 15

sales agents and all or virtually
whom

all of the consumers

sales agents
(B)

solicit monies;
donation" shall mean money or any other

"Charitable

~6
17 18

thing of value that any person gives Or transfers to, or on
behalf ofl (C) a charitYI "Charity" as defined herein; or entity that is

means

any person

19
20 21

represented
directly nn~ ny

to donors or potential

donors

-- in any manner, to be engaged
in

or by implication

-- to be a charity,
~n

mnr~

~hari.~ahl.~·~n~i.vi~i~~, nr

h~ ~ nt""ln-prt""lfi~

22 23
24 25 26 27

charitable entity pursuant
(D) "Defendants"

to the Internal Revenue Code; and
to either Thadow,

shall refer

Inc., Alex

Norman,

or both of them collectively.

II

II
Stipulated Final Order and Injunction

Page 4 of l7

1

RROHIBITION~GAINST

MISREPRESENTATIONS II.

2
3

IT IS HEREBY ORDERED corporation,

that defendants
individually

Thadow,

Inc., a

4
5

and Alex Norman,

and as an officer of officers, all

said corporation,

and their agents, employees, corporations,
in active

6
7 8 9

servants, and attorneys, other personS
or

successor8,and

entitioo

concert or participation

with them who receive service or otherwise,
(A)

actual notice of this order by personal are hereby restrained with soliCiting and enjoined from: or

10

In connection payments

charitable

donations
[~l~ely

11
~2

soliciting

in return

for prizes or award~,

~~presenting fact material donation

in any manner.

directly

or by implication,

any

13 14 15
lG

to a consumer'S

decision

to make a charitable

or a payment,

including

but not limited to the

following:
{1}
by

Folooly

rcproocnting

in ony m~nner,

direotly

O~

17 18 19
20
21

implication,

that defendants

are in the business

of holding

and distributing had promissd

prizes or awards that consum@rs but did not

other companies
deliveri (~)

FH1~~ly representing

in any manner.

directly

or

22
23 24 2S 26 27

by implication. more prizes

that defendants

will deliver one or

or awards worth as much as or more than donation or payment that
or

the amount of the charitable
coneume~s

m~at maks in order to claim the pri~es

awards;

and

Stipulated

Final Order and Injunction

Page 5 of 17

1

(3)

Falsely

representing

in any manner,

directly
in

or

2 3

by implicat.ion, that paymeuL8

ma.de by CQl1.sumelrs

response

to defendants'

solicitations

ar9 tax-

4

deductible;

and
with engaging in the bus i.ne of ss
I

5 6
7
8

(B) . In connection telemarketing
l

falEely representing
any fact

in any manner

directly decision

or
to

by implioation,
make a

mate:J:"ialto a congum~r'~
I

charitable

donation

to enter a contest

for a prize or

9 10
11

award, or to purchase

any item, product,

good or service.

PROarBITION ON THE SALE OF CLIENT NAMES
III.

~2
13

IT IS FURTHER ORDERED that defendants corporation, and Alex Norman
I

Thadow,

Inc., a

individually

and as an officer of officers,

14 15
lC

said corporation, servants,

and their agents, employees, corporations,
in active

and attorneys,
or entitiee

successors,

and all

other peroonc

concert

or partioipation

17
18

with them who receive service or otherwise, enjoined

actual notice of this order by personal are hereby permanently restrained and

19
~u
21

from selling, renting, leasing, transferring, or
the name, address, information telephone number, or other of any person who paid any monies to

disclosing identifying defendants, charitable

22 23

at any time prior to entry of this Order, as a donation or in return for prizes or awards.

24
2S 26 27

MONITORING AND RECORD KEEPING PROVIEIONE
IV.

IT IS FURTHER ORDERED that defendant~, in connection

with

Stipulated

Final Order and Injunction

Page 6 of 17

1
2

defendant

Thadow

Inc. or in connection Norman
is

with any business
IIli;:l,Jo1:ity

where

(1) defendant.

the

owner,

sole

3 4
5

director, indirectly where

president,

Or otherwise

directly

or and

manages or controls the business,
solicits charitable

6
7

(2) the business
payments

donations

or

in return

for prizes

or awards, or th~

8 9
10

business engages are hereby restrained to retain for a period

in the business

of telemarketing, and

and enjoined of three

from failing to create,

(3) years following specified: which,

the date of

11 12 13
14 lS 16

such creation,

unless otherwise

(A) Books, records detail, accurately services
revenues;

and accounts

in reasonable

and fairly reflect the cost of goods or generated, and the disbursement of such

sold, revenues

(B) Rccord3 accurutcly

reflecting:

the name, address, and

17 18 19 20
21

phone number of each person businesses contractor;

that any of the above~referenced as an independent the date upon

employ in any capacity, including that person's

job title or position;

which the person commenced
the

work: and the date and reason for
"i_f applicable. The businesses

person'

8

t-_F!rmin~r_i(')n,

22 23 24
2S

subject

to this Paragraph

shall retain such records

for any

such person who was terminated

for a period of two (2) years

following the date of termination;
(C) RcCo~dQ containing the names, addresses, phone

26
27

numbers,

dollar

amounts paid, quantity

of items purchased,

and

Stipulated

Final Order and Injunction

Page 7 of 17

1 2
3

description

of items purchased,

for all conSUffiBrs to whom any "
have sold, invoiced
UL"

at the above-referenced
8h"lppp.d

businesses

any goods

or services,

or from whom any of the above-

4
5

referenced businesses accepted money or other items of value;
(D) fairly Records which, in reasonable detail, accurately or award of and

6
7

identify

or describe

each differing

prize

provided

to consumers, of each

the name,

addresse., and phone number

8 9

the source the source (E) whether party:

such prize

or award,

and the price paid to

for each such prize or award. Records that reflect, directly for every consumer or through complaint, any third

10 11
~2

received

or indirectly

13
14
15 16

(1) the consumer's
and the dollar (2)

name, address

I

telephone

number

amount paid by the consumeri complaint,if anYI and the date of

the written

the oomplo.int; (3) the basis of th~ complaint, complained including
l

17 18 19
::,:lU 21

the name

of any salesperson and result validity
(4)

against

and the nature as to the

of any investigation

conducted

of any complaint; and the date of the response; and the date of the

each response

22
23 24
25

(5)

any final resolution
and

resolution; (6)

in the event of a denial

of a refund

request

made by a complainant, (F) Copies

the reason

for such denial} packets,

26
27

of all sales scripts~

training

Stipulated

Final Order

and Injunction

Page 8 of 17

1
2

advertisements, or other marketing materials utilized; and
(G)

Records retlecting all contracts, agreements, marketing,

3 4 S

invoic~s or c.orr8Rponn~n~pwith any sales,

promotional, or advertising company, or customer lead provider.

v.
IT IS FURTHER ORDERED that, for a period of five (5) years
Ezou, Lhe date of entry of thia Final

6
7

Judgment,

defendants

8 9

shall:
(A) Provide a copy of this Final Judgment to, and obtain

10 11
~3

a signed and dated acknowledgement of receipt of same from, each officer or director, each individual serving
mana.gement capacity,
all personnel

in a
to

i nvn1 VF!d in. responding

13
14

consumer complaints

or inquiries,

and all sales personnel, consultants
I

whether designated as employees,

independent

15
~6

contractors or otherwise, immediately upon employing or
retaining such per~on~, for defendant Thadow, Inc. and for any

17 18 19 20
21 22

business where (1) defendant Norman is the majority
owner,

sole

director, president, or otherwise directly or indirectly manages or controls the business, and
where (2) the business solicita charitable donations or

23 24
25

payments in return for prizes or awards, or the business engages in the business of telemarketing;
and

26
27

(B) Maintain

l

and upon reasonable notice make available

stipulated

Final Order

and Injunction

Page 9 of 17

1 2
3

to representatives

of the commission,

the original

signed and

dated acknowledgements
Judgment, as required

of the receipt of copies of this Final
in
thl? above

811hl=:F!l"'.lt_ion of (A)

this

4
S

Paragraph.
VI.

6
7 I.I.\)ltl

IT IS FURTHER ORDERED that for a period of five (5) years
t.he

date of entry or securing shall permit

of

thi e Fin<:Ll Judgment

I

for

purpose.s

of

8

determining defendants

compliance

with this Final Judgment, of the Commission,

9 lO 11
12

representatives

within seven (7) business from the Commission:
(A..)
1l._CCE!a~

days of receipt of written notice

durinG' normal

off1l:!F!:honrs to any office,

or

13
~4

facility business

storing documents,
where
(~) defendant

of defendant

Thadow,

Inc. and any

15

Norman

is the majority
O~

owner, sole

16 17
18 19

director, p~e~ident, indirectly where
(2) the business

othe~wi5e directly or the business, and

manages

or controls

solicits

charitable

donations

or

20
21 22

payments
busin9s~ In providing

in return tor prizes
9ng~g9s in th9

or awards, or the
t~lemarketing.

busin9~~ of

such access, defendants of the Commission to any matter

shall permit

23 24
25

representatives documents

to inspect and copy all contained in this Final

relevant

Judgment; and

26
27

(B)

To depose. the officers,

directors, and employees,

Stipulated

Final Order and Injunction

·Page 10 of

17

·1
2
3

including complaints

all personnel or inquiries, employees
r

involved

in responding

to consumer

and tlll sales pe:c-sonnel, whether

del'll gn.<3.ted as

consultants,

independent

contractors (A) of this

4
5

or otherwise, Paragraph

of any business relating

to which Subsection

applies,

to compliance

with the terms of

6
7

this Final Judgment.
present. monitor Provided, defendants'

The person deposed may have counsel,
further, that the Commi~sion m;;!y nt':hp-rwise

8

compliance

with this Final Judgment
the taking production
consume

by all the and

9
10 11

lawful means available use of compulsory

including seeking
posing

of depositions, of documents,

process

the use of investigators

as

ra or suppliers.

~1
13 14 15 16 17 18 IT IS FURTHER ORDERED

VII.
that for a period of five
(5) years

from the date of entry of this Final Judgment:
(A)
writins,

Defendant

Norman

shall inform the Commission

in

within ten (~O) days of the date of ent.ry of this

Final Judgment, 'of his current status, numbers
including

residence

address

and employment and telephone

the names, business employers,

addresses,

19
20 21 22 23 24 2S 26
27

of any current

and, thereafter,

shall inform

the commission

in writing

o~ any changes

in his T@sid@TIce (30) days of such

addre~9 O~ ~m~lnymp-n~ statu~ within changes,

thirty

in order that compliance can be monitored;

with the provisions

of this

Final Judgment

(B) In the event that defendant

Norman

is or becomes
sOJ.:i.C:it.FI

o.£filiated in any ca.pacity with any businE!ss that charitable

donations

or payments

in return

for prizes

or

Stipulated

Final Order and Injunction

Page 11 of 17

1 2 3 4 5 6 7
8 9

awards,

or that engages in the business of telemarketing,
Norman shall inform the Commission in writ.ing of tht=

defendant business/8 activitiest authority, business.
impoeed in

.::Jcidress nd t.elephone number ..the nature _of its a and the nature and ownership Defendant
thio

of his own duties,

management with the

,interest in connection shall comply
within thirty

Norman

with the requirements (30) dayg of
eTlt-.ry

oubparagraph
l

of this Final Judgment ar is entered to which defendant

if at the time this Final Judgment is not affiliated applies
1

Norman

with any business (30) days of

10 11 12 13 14 15

this subparagraph affiliated

within

thirty

his becoming

with any such business: of this Final Judgment, shall be mailed Office to: written

Fnr the purposes notifications

to the Commission

Director, San Francisco Regional Federal Trade Commission 901 Market Street, Suite 570 San Francisco, CA 94103 D. includes For the purposes the performance

17
18 19 20
21

of this Paragraph

VI,

11 employment

II

of services

as an employeet
'i-nc:lllnf!:!.

ccn!O:ultant, or independent any individual services or business

contra_ct~r; .and nemplnYAr~!I for which defendants

perform
contractor.

as an employee,

consultant, MONETARY

or independent

22
23 24
25

RELIEE

VIII. IT IS FURTHER (A) amount Judgment ORDERED that: against defendants in the any Trade

is her.eby entered for consumer

26 27

of $130/000 expenses

redress

and for paying If the Pederal

attendant stipulated

of administration. and Injunction

Final Order

Page 12 of 17

1

Commission,

in its sole discretion,

determines

that redress

is

2
3

wholly or partially
h~ deposited

impractic..:Ql:Jl~, funds dny States Treasury

not

:so uSied shall

in the United

as equitable as follows: notice of

4 5 6
7
8 9 10 11
~2

disgorgement. Within

The judgment seven

shall be satisfied

(7) business

days after receiving defendants

the entry of this Final Judgment,

shall assign

and tran~fer to the FTC or it~ designated

agent the funds a written

set forth below in this Paragraph,
directive

by issuing

to the financial

institutions

holding

those
or

funds to transfer

the funds in the form of a certified
the Federal Tradl; Cotnrnission or its

cashier's
designated

Ch6Ck to

agent for the purpose redress fund.

of establishing

a

13 14 15 16 17 18 19 20
21

consumer follows: {1}

The funds to be transferred

are as

All the funds, excluding the sum of $7,5001
number 0483180~2 at Bank of Ame~io~

from

Qcoount

NeVada

(mailing address
89193-8600)
I

-- P.O. Box 98600, Las Vegas, NV Inc. (balance as

in the name of Thadow, 5, 1996, $100/738.56);

of September
(2)
P,~1i.k

All the funds in account numb@r 048334767 ~L
of

America

Nevada

(mailing address

-- P.O. Box

22 23
24
2!J

98600, Las Vegas, NV 89193-8600), Faith Foundation $10,729.43);
(3)

in the name of New 5, 1996,

(balance as of September

and
funds; in account number 61687
<=It. ~"i1vp..r

All tha

26 27

State Credit Union

(located at 4221 South McLeod

Stipulated

Final Order and Injunction

Page 13 of 17

1

Drive, Norman

Las Vegas, (balance as

NV 89121),

in the name of Alex 10/ ~996,

2
3

or

september

$24.676.40);

4
5

(B) If defendants
designated through agents

assign

and transfer

to the FTC or its in Sections (A) (1)

all of the funds specified

6
7
8

(A) (3) of this Paragraph,

the monetary

judgment
flllly

establiohcd by this Final Judgment ~hal1 b~ deemed satisfied;

9
10
11

(C) The financiai
specified shall in Sections with

institutions (A) (~) through

holding

the funds

(A) (3) of this Paragraph to tran8feL" Euride

comply

the defendants'

directives

~2

r.n r.h~ commission
directives

or its designated

agent upon receipt

of such

l3 14 15
~G

and upon receipt and

of notice

that this Final Judgment

has been enteredj
(D)
docmed
Q

No portion
payment

of the payment

as herein

provided

shall be

o£ any fine, penalty, or punitive assessment. as to how funds are disbursed, the manner of distribution

17

Defendants

shall be notified

but

18
19 20 2~ 22

shall have no right to contest chosen by the FTC or

its designated IX.

agElnt.

IT IS FURTHER receiving defendant sworn notice

ORDERED

that, within

five

(5) days of

that. this Final Judgment shall submit

has been entered, a truthful A, that shall

23
24 2S 26
27

Norman

to the Commission

statement,

in the form shown on Appendix

rCQ££irm financial

and atte~t to the truth, accuracy. ~nd compl~tenGQa of statements of defendants Norman and Thadow, executed

Stipulated

Final Order

and Injunction

.Page 14 of l 7

1 2
3

on February previously

2, 1995 and March sUbmitted

13, 1995, respectively,

and

to the commission.

The Commission's

agreement

to this Final Judgment
accuracy,

is expressly

premised
I

upon the

4

truthfulness, financial
referenced

and completeness

of defendants

5
6

condition
above,

as represented

in the financial
information

statements
upon which

which contain

material

7

the Commis~ion

relied

in negotiating

and agreeing

to this .PinQl
by the

8
9 10 11
~2

Judgment without
defendants.

the payment

of additional

redress

If, upon motion

by the Commission, financial

the Court

finds to

that any of the above-referenced disclose any material

statement8

failed the

asset, materially

misrepresen'ted

value of any asset,

or made any other material

13 14 15 ~6 17 18 19 20 21 22 23 24
25 26 27

misrepresentation
request

or omission of fact, the Commission herein be reopened
monetary

may

that the Final Judgment to modify defendants'

to allow the Provided,

Commission

liability.

however, that in all other re~p~ct~ this Final Judgm~nt ahall remain Courti

in full force and effect unless and provided
further

otherwise

ordered

by the under

that proceedings

instituted

this provision other

would be in addition
remedies

to and not in lieu of any
by law,

civil or criminal

as may be provided ~h~~ ~hp rnmmi~~inn

inc1.uding ~ny n~hpr prnr~p~ing~
institute purposes contest
motter.

m~y

to enforce

the Final

Judgment.

Solely waives

for the any right to

of this Paragraph,

each defendant

any of the allegations

in the Complaint

filed in this

1/
Stipulated
Final Order and Injunction

Page 15 of 17

1
2
3 IT IS

~IFTING OF ASSET fjLEEZE
X.
PTl'R'T'HF.'R. ORDERED

that the freeze of the defendants' and Order for Preliminary Expedited

4 5

assets,

imposed

in the Stipulation Freeze

!njunction

With A8set

and Order

Permitting

6
7 8 9

Asset Discovery entered
upon: payment

in this proceeding,
I

shall be lifted and (B) defendants' VII of

(A) the entry of thio Fin~l Judgment of the monies as required pursuant

to Paragraph

this Final Judgment.

10
11
12 IT IS

RETENTION OF JURISDICTION,
Xl.
FTJR.'T'HF.RO"RDR"RF.Dthat

the Court retains

jurisdiction and

13 14 15
~6

of this matter enforcement

for purposes

of construction,

modificationt

of this Final Judgment.

II
II

17 18 19
20

II II II II II II II

aa
22
23

24

1/
/1

25 26
27

II
Stipulated Final Order and Injunction Page 16 of 17

1
2

There Order,

being no just reason for delay of entry of this

the Clerk ~hall enter the Order imm~diat~ly.

3
4

STIPULATEDTO:
FOR THE PLAINTIFF: Dated:

5
6
7

}2.tf/9~ TJ
Attorney

Federal Trade Commission
~t-_h ;:;."d Pt"!.nn _ Ave., NW,

tor Plaintitt

Rm.

8
9

Washington,

200

DC

20580

10
11

FOR THE DEFENDANTS:
Dated.

10

il ~/3_ G
)

J!Aj;)ifJ
D T

HESNOFF
Fourth

12 13 14 15
16
e,

fices of

& Chesnoff
St.

for Defendants ------~~~mrman and Thadow,

17 18 19 20 21 22 23 24 ?:s
26 27

Dated:

Thadow,

President of
Inc.

x Individua

IT IS SO ORDERED

~dPM~·
and lnjunction

United States District

Judge

Stipulated ~inal uider

page

~7

1 2 STEPHEN CALl<ING

APPENDfX A
General Counsel

3 4

DAVID C. FIX DANIEL A. SPIRO 5 RA'OUF ABDULLAH Federal Trade Commission 66th and Penn. Ave., NW, Rm. 200 Washington, DC 20580 7 (202) 326-3288 (voice) (202) 326-2050 (faC9imil.e) 8 JEROME M. STEINERr JR. 9 RALPH E. STONE Federal Trade Commission 10 901 Market St .. Suite 570 San Franciscor CA 94103 11 (415) 744-7920 (voice) (415) 744-7940 (facsimile)

12
13 14 15
~6

BLAINE T. WELSH Assistant United
701 E. Bridger Luo Vcgacr NV (702) 388-6336

States Attorney

89101

Attorneys

for Plaintiff
UNITED STATES DISTRICT COUR ..,.

17 18 19
20

DISTRICT
)

OF NEVADA

FEDERAL

TRADE

COMMISSION,

)
)

CV-S-95-75~HDM (LRL)

Plaintiff,
v.

21 22

THADOW
ALEX

and

J

INC. , a corporationr individu<l.11y

) } ) ) ) )

DECLARATION

OF ALEX NORMAN

)
)

NORMAN',

23
24

)

and as an officer corporation, Defenda.nt.s_

of said

)
) ) ) )

25
26

27 28
A-l

~ :2 in 3 4 S
6

I, Alex Norman,
t.h~ financi.al

hereby

state that the intormation
of Alex Norman and Thadow,

contained
Inc.,

st.:=:tt"_F!mF!Tlt_!':

provided to the Federal Trade Commission
March 13, 1995, respectively,

on February

2, 1995 and

were true, accurate,

and complete

on the dates that they were executed.
I hereby declare
unOEL- pEIldl Ly or pe,cj u"'Y

7

t.hat the

foregoing

8
9

is true and correct.

10
11

·Dated:

Alex Norman

12 13 14 15 16

17
18 19
20 21.

22
23
24

25
.26 27

28

A-2

1

CERTIFICATE OF SERVICE
2

3
4: 5 6

I, Daniel servied

Spiro,

hereby

certify

that, on December

4, 1996, I

the Stipulated
for Monetary

Final Order for Permanent
Relief

Injunction

and

Judgment

on the interested
enclosed

parties

to this

action by placing envelope

a true copy thereof prepaid

in a sealed Express

7
8

with postage

and ~ending

it via Federal

to the followinq

address:

10 11 12 13 14 15 16 17 18 19
20

David Chesnoff,

Esq. Law Offices of Goodman 520 S. 4th St. Las Vegas, NV 89101

& Chesnoff

Dated:

Il}"f~&

Federal Trade Commission 6th & Pennsylvania Ave., Wa.8hlngLon, D.C. 20580 Fax (202) 326-3392
Rm. 200

N.W.

Phone

(202) 326-3288

21 22

23
24

25
26

27 28

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