STATE OF ILLINOIS IN THE CIRCUIT COURT OF THE SEVENTH JUDICIAL SANGAMON COUNTY MAY 04 2015 cm Clerk of the Circuit Court THE PEOPLE OF THE STATE OF ILLINOIS, ?8 Plaintiff, -vs- 2N0. I 5 0 1 CONSUMER FINANCIAL RESOURCESTexas Limited Liability Corporation, d/b/ a STUDENT LOAN RESOLVE Defendant. COMPLAINT FOR INJ UNCT IVE AND OTHER RELIEF NOW COMES the Plaintiff, THE PEOPLE OF THE STATE OF ILLINOIS, by LISA MADIGAN, Attorney General of the State of Illinois, and brings this action for' injunctive and other relief against defendants CONSUMER FINANCIAL RESOURCES, LLC d/b/ a STUDENT LOAN RESOLVE (?Student Loan Resolve?) for violations of the Illinois Consumer Fraud and Deceptive Business Practices Act, 815 ILCS 505/1 et seq., and the Illinois Debt Settlement Consumer Protection Act, 225 ILCS 429/1 et seq. PUBLIC INTEREST 1. The Illinois Attorney General believes this action to be in the public interest of the Citizens of the State of Illinois and brings this lawsuit pursuant to the Illinois Consumer Fraud and Deceptive Business Practices Act, 815 ILCS 505/1 et seq. and the Debt Settlement Consumer Protection Act 225 ILCS 429 1 et seq. JURISDICTION AND VENUE 2. This action is brought for and on behalf of THE PEOPLE OF THE STATE Page 1 of 20 OF ILLINOIS, by LISA MADIGAN, Attorney General of the State of Illinois, pursuant to the provisions of the Consumer Fraud and Deceptive Business Practices Act (?Consumer Fraud Act?), 815 ILCS 505/1 et seq., the Debt Settlement Consumer Protection Act (?Debt Settlement Act?) 225 ILCS 429/ 1 et seq., and her common law authority as Attorney General to represent the People of the State of Illinois. 3. Venue for this action properly lies in Sangamon County, Illinois, pursuant to Section 2-_101 and 2-102(a) of the Illinois Code of Civil Procedure, 735 ILCS 5/2-101, in that the Defendant is a foreign corporation not authorized to do business in this State. PARTIES 4. Plaintiff, the People of the State of Illinois, by Lisa Madigan, the Attorney General of the State of Illinois, is authorized to enforce the Consumer Fraud Act and the Debt Settlement Act. 5. Defendant Consumer Financial Resources, LLC d/b/ a Student Loan Resolve is a Texas limited liability corporation with its principal place of business at 303 S. Highway 78 Ste. 202, Wylie, Texas 75098-3957. 6. For purposes of this Complaint, any references to the acts and practices of Student Loan Resolve shall mean that such acts and practices are by and through the acts of its of?cers, owners, members, directors, employees, salesperson, representatives, and/ or other agents. TRADE AND COMMERCE 7. Trade and Commerce under subsection 1(f) of the Consumer Fraud Act, 815 ILCS 505/1(f) mean: the advertising, offering for sale, sale, or distribution of any Page 2 of 20 services and any property, tangible or intangible, real, personal, or mixed, and any other article, commodity, or thing of value wherever situated, and shall include any trade or commerce directly or indirectly affecting the people of this State. 8. Student Loan Resolve was at all times relevant to this Complaint engaged in trade and commerce in the State of Illinois by advertising, offering for sale, selling and accepting money for student loan debt relief services to Illinois residents. Defendant offers, among other things, to provide advice or service on behalf of consumers to obtain a settlement, adjustment, or satisfaction of the consumer?s unsecured student loan debt in an amount less than the current outstanding balance of the debt. BACKGROUND Student Loan Debt 9. Students in Illinois and throughout the country seek higher education to improve their economic prospects and pursue the careers of their dreams. 10. With rising tuition costs, however, many are forced to supplement the cost of their education by taking out student loans. 11. There is currently over $1.1 trillion student loan debt outstanding in the United States which is comprised of over 37 million borrowers who hold an average balance of more than $24,000. 12. Most of this amount consists of federal student loan debt either of loans made directly by the federal government or loans backed by government guarantees. 13. Federal student loans consist of a complicated web of bene?ts and repayment options that are often dif?cult for borrowers to navigate. 14. Once a borrower enters repayment, there are numerous options to select from such as standard plans where the payment remains consistent across the Page 3 of 20 life of the loan or graduated plans that increase the payment over time. 15. There are also income driven payment plans such as income based and income contingent repayment that formulaically set a borrower?s payment based on their ?nancial circumstances. The availability of these options may vary depending on the type of the loan, when it was taken out, and the loan?s status. 16. Additional options such as deferment and forbearances allow a borrower to temporarily postpone their repayments. Disabled borrowers may seek to have the Department of Education discharge their loans completely. Other borrowers may retain possible legal defenses to repayment related to illegal conduct committed by their schools. 17. Repayment options change signi?cantly when a federal student loan is in default, where there is a litany of extraordinary collection tools including administrative garnishment, bene?t interception, and tax offsets. Options for borrowers in default to avoid these outcomes are equally complicated. 18. All repayment Options of federal loans are ultimately set by federal law and the Department of Education?s rules, and neither the Department nor student loan servicers negotiate with borrowers to lower their payments apart from what is legally allowed. Consolidation 19. Reforms made to federal lending programs between 2007 and 2010 began to shift borrowers into the federal direct lending program where loans were made directly by the federal government opposed to federally?insured loans made by private lenders under the Federal Family Education Loan Program (FFEL). This included both originating new loans under the Direct Loan Program and combining multiple FFEL Page 4 of 20 loans into one Direct Consolidation Loan. 20. There are various reasons a borrower may want to consolidate their existing loans, including the ease of having a single servicer and making a single payment. Some borrowers choose to consolidate to get the bene?ts of Public Service Loan Forgiveness, a program that was not previously available for their FFEL loans. Other borrowers choose to consolidate to get out of default and enter an income driven repayment option under a new loan. 21. Nonetheless, there is no one?size-?ts-all approach to repayment or consolidation, and any assessment about whether consolidation is appropriate in a particular case depends on a complete assessment of the borrower?s ?nancial goals, history, and current circumstances. 22. If a borrower ultimately chooses to consolidate, he or she may initiate an application free of charge directly through the Department of Education and may complete their application online and sign with an electronic signature called the ED- PIN. 23. Currently, only a borrower can sign consolidation documents with their PIN. Formal guidance from the Department of Education states that nobody other than the borrower can use their PIN, and that the rights and responsibilities that accompany it may not be transferred to any other person or entity. This guidance further states that it is ?inappropriate for anyone to solicit a pin? and ?contrary to the requirements of the pin process for anyone to use another person?s . . . regardless of whether the owner has been informed of the activity, or even if he or she voluntarily agrees to provide the PIN to the other party.? (Emphasis Added). Such a solicitation is ?not mitigated by any disclosure made to the applicant or by any Page 5 of 20 agreement with the applicant.? And documents signed with someone else?s PIN can be voided by the Department. 24. Regardless of whether consolidation is ultimately appropriate, with the complexity of student loan options and a substantial number of borrowers either in delinquency or default, distressed bOrrowers become desperate to ?nd genuine relief from the often crushing burden of their student loan debts. COURSE OF Defendant?s Ads 25. Student Loan Resolve is a self?described ?document management and processing company? that advertises its student loan services in Illinois and nationwide on the Internet, Facebook, and on late night television with the intent that Illinois consumers rely on its representations. 26. Defendant?s Facebook page boasts that Student Loan Resolve is ?one of the Nation?s leading providers of Student Loan Assistance Programs? and its ?goal is to help consumers with Student Loans reduce their payment, shorten payment terms sometimes both.? Student Loan Resolve?s website also implies it can remove defaults, stop tax offsets, and prevent wage garnishments. 27. As part of this process, Student Loan Resolve claims to be able to protect borrowers? credit, advertising on Facebook that if student loan borrowers cannot afford payments, are making late payments or if their loans are going into default, Student Loan Resolve, ?can help you get back on track so your credit is not affected.? 28. Student Loan Resolve goes on to claim ?We have Forgiveness Programs to help people who are in eligible professions such as Teachers, Nurses, those who work for Non-Pro?ts, Policeman, Fire?ghters and many more for those in Public Service Page 6 of 20 positions.? (Emphasis Added). 29. In reality, however, the availability and eligibility for Public Service Loan Forgiveness is a program created and provided by the federal government. 30. The company mainly offers to prepare a borrower?s consolidation documents and submit them to the Department of Education for a hefty up-front fee. Defendant?s Sales Pitch 31. If a borrower calls Defendant?s SOD-number or initiates an inquiry, they will be connected with a Student Loan Resolve sales agent. 32. Agents typically tell borrowers that there is a one?time consolidation fee ranging from $549?$649, which Student Loan Resolve requires before it does any actual service. i 33. In addition to the up-front fee, borrowers are charged a recurring ?service fee? for Defendant?s ongoing ?consolidation services.? 34. Some borrowers are told this recurring payment will go towards the principal of their consolidation loan. Others are told that the payment is what their new federal Income Based Repayment will be, giving the similar erroneous impression that the fee is actually applied to the balance of their loans. 35. Yet no part of this ?service fee? actually goes to a borrower?s principal. Instead the fee goes into the pocket of Student Loan Resolve. 36. Despite paying the substantial fee for what the borrower can do for free, Defendant may not even actually initiate the process of consolidation as promised. Defendant?s Contract 37. When a borrower signs up for Defendant?s services, he or she executes a contract and provides Student Loan Resolve detailed personal information including Page 7 of 20 their social security number, adjusted gross income, family size, federal student PIN number, and banking information. 38. The agreement has a section describing fees and lists a ?eld for Processing and Administrative Fees. 39. The next section of the agreement shows a Loan Consolidation Fee Schedule, payment date, and a method by which the payment will be withdrawn. 40. After that section comes a Loan Summary column listing the loans to be consolidated followed by ?elds for ?Underwriting Approval? and ?Coordinator Approval.? In fact, Defendant refers to its employees several times throughout the agreement as ?underwriters,? creating the impression that Defendant is involved in approving the loan. 41. Student Loan Resolve?s logo (image on the right below) displayed on its webpage and Facebook pro?le shares plainly identi?able similarities with the logo of Capitol Federal Savings Bank (image on the left), a federally?chartered ?nancial institution. 42. In reality, the Department of Education has the sole ability to underwrite and originate Direct Consolidation Loans. 43. Defendant?s contract continues in Section describing its services and states that Student Loan Resolve will provide consistent communication, document Page 8 of 20 management services, federal programs monitoring, and account management services. 44. Section further states and its team of underwriters and service staff have a plethora of knowledge base regarding client?s enrolled services and although we are not experts at everything nor are our underwriters licensed in any manner, we will do the research necessary to provide timely information regarding consolidation, garnishment, rehabilitation, bankruptcy, forbearance, deferment, loan discharge programs, public service forgiveness and teacher loan forgiveness.? 45. The agreement then implies that Defendant?s access to and use of the borrower?s PIN are legitimate. After it tells borrowers the Department of Education urges people not to share their PIN with others, the agreement goes on to state that ?[y]ou agree we asked your permission in the initial consultation to retrieve your 4 digit PIN NUMBER on your behalf.? 46. The agreement ends by granting Student Loan Resolve a power of attorney with ?the authority and power to act on Client?s behalf as Client would personally. This authority and power is limited to the preparation, signing, and ?ling of documents in accordance with the facilitation of the student Loan Consolidation and other services. Client gives SLR the authority to communicate and negotiate with the DOE, and to act on or behalf of the client, including the signing of the client?s name (if applicable).? 47. The Defendant is not licensed to perform debt management services under Illinois law. Harm Defendant Causes 48. Consumers in Illinois and nationwide who sign up with Student Loan Resolve are charged a signi?cant amount of fees for a process they could have completed Page 9 0f 20 on their own behalf?fees which have could have been applied directly to their loans or toward counsel that properly analyzed all of the borrower?s circumstances. Some consumers may not even get the consolidation services they paid for and are still left with the crushing debt because of the relief Defendant falsely promised it could provide. 49. 50. COUNT I - CONSUMER FRAUD ACT APPLICABLE STATUTE Section 2 of the Consumer Fraud Act, 815 ILCS 505/2, provides: Unfair methods of competition and unfair or deceptive acts or practices, including but not limited to the use or employment of any deception, fraud, false pretense, false promise, misrepresentation or the concealment, suppression or omission of any material fact, with intent that others rely upon the concealment, suppression or omission of such material fact, or the use or employment of any practice described in section 2 of the ?Uniform Deceptive Trade Practices Act?, approved August 5, 1965, in the conduct of any trade or commerce are hereby declared unlawful whether any person has in fact been misled, deceived or damaged thereby. VIOLATIONS The People re-allege and incorporate by reference the allegations in Paragraphs 1 to 48. 51. constitutes unfair and deceptive acts or practices declared unlawful under Section 2 of the Consumer Fraud Act, 815 ILCS 505/ 2, in connection with advertising, offering for Student Loan Resolve has engaged in a course of trade or commerce which sale, selling, and accepting money for student loan debt relief services by: a. Representing expressly or by implication that Defendant will consolidate a borrower?s student loans when, in fact, there are cases where the service may not be performed as promised; Page 10 of 20 b. Representing expressly or by implication that Defendant will apply a borrower?s ?service fee? to the principal of the loan when, in fact, Defendant collects the fee for its own bene?t; c. Representing expressly or by implication that Defendant has legal authority to use a borrower?s Department of Education PIN to sign a borrower?s name to an application for consolidation when, in fact, Defendant lacks such authority; d. Representing expressly or by implication that Defendant is involved in the underwriting process of the borrower?s student loan, when in, fact the underwriting of a borrower?s loan is handled entirely by the Department of Education; e. Representing expressly or by implication that Defendant is a direct provider of student loan assistance programs when, in fact, these programs are established and administered by the federal government; f. Representing expressly or by implication that Defendant is capable of offering student loan forgiveness when in fact, student loan forgiveness is a program offered only by the federal government through the Department of Education; g. Representing expressly or by implication that Defendant is capable of rehabilitating student loan defaults when, in fact, Defendant does not have the capability to negotiate with the Department of Education to do so; h. Representing expressly or by implication that Defendant is capable of preventing wage garnishments when, in fact, Defendant does not have Page 11 of 20 the capability to do so; and i. Representing expressly or by implication that Defendant is capable of stopping student loan tax offsets when, in fact, Defendant does not have the capability to do so. REMEDIES Section 7 of the Consumer Fraud Act, 815 ILCS 505/7, provides: Whenever the Attorney General has reason to believe that any person is using, has used, or is about to use any method, act or practice declared by the Act to be unlawful, and that proceedings would be in the public interest, he may bring an action in the name of the State against such person to restrain by preliminary or permanent injunction the use of such method, act or practice. The Court, in its discretion, may exercise all powers necessary, including but not limited to: injunction, revocation, forfeiture or suspension of any license, charter, franchise, certi?cate or other evidence of authority of any person to do business in this State; appointment of a receiver; dissolution of domestic corporations or association suspension or termination of the right of foreign corporations or associations to do business in this State; and restitution. In addition to the remedies provided herein, the Attorney General may request and this Court may impose a civil penalty in a sum not to exceed $50,000 against any person found by the Court to have engaged in any method, act or practice declared unlawful under this Act. In the event the court ?nds the method, act or practice to have been entered into with intent to defraud, the court has the authority to impose a civil penalty in a sum not to exceed $50,000 per violation. In addition to any other civil penalty provided in this Section, if a person is found by the court to have engaged in any method, act, or practice declared unlawful under this Act, and the violation was committed against a person 65 years of age or older, the court may impose an additional civil penalty not to exceed $10,000 for each violation. Page 12 of 20 50. Section 10 of the Consumer Fraud Act, 815 ILCS 505/ 10, provides that ?in any action brought under the provisions of this Act, the Attorney General is entitled to recover costs for the use of this State.? PRAYER FOR RELIEF - COUNT I WHEREFORE, the plaintiff prays that this honorable Court enter an Order: A. Finding that the defendant has violated Section 2 of the Consumer Fraud Act, 815 ILCS 505/2, by engaging in the unlawful acts and practices alleged herein; B. Preliminarily and permanently enjoining the defendant from engaging in the deceptive and unfair practices alleged herein, or enjoining the defendant from operating in the State of Illinois; C. Declaring that all contracts entered into between the defendant and Illinois consumers by the use of methods and practices declared unlawful are rescinded and requiring that full restitution be made to said consumers; D. Assessing a civil penalty in the amount of Fifty Thousand Dollars ($50,000) if the Court ?nds the defendant has engaged in methods, acts, or practices declared unlawful by the Act without the intent to defraud, if the Court ?nds defendant has engaged in methods, acts or practices declared unlawful by the Act with the intent to defraud, then assessing a statutory civil penalty of $50,000 per violation, all as provided in Section 7 of the Consumer Fraud Act, 815 ILCS 505/7; E. Requiring the defendant to pay all costs for the prosecution and investigation of this action, as provided by Section 10 of the Consumer Fraud Act, 815 ILCS 505/ 10; and F. Providing such other and further equitable relief as justice and equity may require. Page 13 of 20 be unlawful for any person or entity to act as a debt settlement provider except as authorized by this Act and without ?rst having obtained a license under this Act.? disclosures about the risks and limitations its debt settlements services before a 54. 55. COUNT II-DEBT SETTLEMENT ACT APPLICABLE STATUTES Section 15 of the Debt Settlement Act, 225 ILCS 429/ 15, provides ?It shall Section 115 requires a debt settlement provider to give a consumer consumer signs a contract. 225 ILCS 429/ 115. part: 56. 57- Section 125(b) of the Debt Settlement Act states: A debt settlement provider shall not charge or receive from a consumer any enrollment fee, set up fee, up-front fee of any kind, or any maintenance fee, except for a one?time enrollment fee of no more than $50. Section 105 of the Debt Settlement Act, 225 ILCS 429/105, provides in A debt settlement provider shall not represent, expressly or by implication, any results or outcomes of its debt settlement services in any advertising, marketing, or other communication to consumers unless the debt settlement provider possesses substantiation for such representation at the time such representation is made. A debt settlement provider shall not, expressly or by implication, make any unfair or deceptive representations, or any omissions of material facts, in any of its advertising or marketing communications concerning debt settlement services. All advertising. and marketing communications concerning debt settlement services shall disclose the following material information clearly and conspicuously: ?Debt settlement services are not appropriate for everyone. Failure to pay your bills in a timely manner will result in increased Page 14 of 20 balances and will harm your credit rating. Not all creditors will agree to reduce your principal balance, and they may pursued collection, including lawsuits.? 56. Section 145 of the Debt Settlement Act, 225 ILCS 429/145, provides in pertinent part that a debt settlement provider shall not: (1) Charge or collect from a consumer any fee not permitted by, in an amount in excess of the maximum amount permitted by, or at a time earlier than permitted by Section 125 of this Act. (8) Advertise, display, distribute, broadcast, or televise services or permit services to be displayed, advertised, distributed, broadcasted, or televised, in any manner whatsoever, that contains any false, misleading, or deceptive statements or representations with regard to any matter, including services to be performed, the fees to be charged by the debt settlement provider, or the effect those services will have on a consumer's credit rating or on creditor collection efforts. 9i- (12) Enter into a contract with a consumer without ?rst providing the disclosures and ?nancial analysis and making the determinations required by this Section. (13) Misrepresent any material fact, make a material omission, or make a false promise directed to one or more consumers in connection with the solicitation, offering, contracting, or provision of debt settlement service. (17) Employ an unfair, unconscionable, or deceptive act or practice, including the knowing omission of any material information. VIOLATIONS 57. The People re-allege and incorporate by reference the allegations in Paragraphs 1 to 48. Page 15 of 20 58. Defendant has violated Section 15 of the Debt Settlement Act by acting as Debt Settlement Provider but failed to obtain a license; 59. While offering student loan debt relief and settlement services and acting as a debt settlement provider, the Defendant has committed unfair and deceptive acts or practices declared unlawful under Section 105(b) and Section 145 of the Debt Settlement Act by: a. Charging and receiving fees that are prohibited under Section 125 of the Debt Settlement Act in violation of Section 145(1); b. Entering into a contract with a consumer without ?rst providing the disclosures and ?nancial analysis and making the determinations required by the Debt Settlement Act in violation of Section 145(12); c. Making misrepresentations about the effect Defendant?s services will have on a consumer's credit rating in violation of Section 145(8); d. Representing expressly or by implication that Defendant will consolidate a borrower?s student loans when, in fact, there are cases where the service may not be performed as promised in violation of Sections 105(b) and 145 (8), (13). and e. Representing expressly or by implication that Defendant will apply a borrower?s ?service fee? to the principal of the loan when, in fact, the Defendant collects the fee for its own bene?t in violation of Sections 105(b) and 145 (8), (13), and f. Representing expressly or by implication that Defendant has legal authority to use a borrower?s Department of Education PIN to sign a borrower?s name to an application for consolidation when, in fact, Page 16 of 20 Defendant lacks such authority in violation of Sections 105(b) and 145 (8), (13), and g. Representing expressly or by implication that Defendant is involved in the underwriting process of the borrower's student loan when, in fact, the underwriting of a borrower?s loan is handled entirely by the Department of Education in violation of Sections 105(b) and 145 (8), (13), and h. Representing expressly or by implication that Defendant is a direct provider of student loan assistance programs when, in fact, these programs are established and administered by the federal government in violation of Sections 105(b) and 145 (8), (13), and i. Representing expressly or by implication that Defendant is capable of offering student loan forgiveness when in fact, student loan forgiveness is a program offered only by the federal government through the Department of Education in violation of Sections 105(b) and 145 (8), (13), and j. Representing expressly or by implication that Defendant is capable of rehabilitating student loan defaults when, in fact, Defendant does not have the capability to negotiate with the Department of Education to do so in violation of Sections 105(b) and 145 (8), (13), and k. Representing expressly or by implication that Defendant is capable of preventing wage garnishments when, in fact, Defendant does not have the capability to do so in violation of Sections 105(b) and 145 (8), (13), and and Page 17 of 20 l. Representing expressly or by implication that Defendant is capable of stopping student loan tax offsets when, in fact, Defendant does not have the capability to do so in violation of Sections 105(b) and 145 (8), (13). REMEDIES 56. Section 155 of the Debt Settlement Act states in pertinent part: A violation of Section 105, 110, 115, 120, 125, 130, 135, 140, 145 or 150 of this Act constitutes an unlawful practice under the Consumer Fraud and Deceptive Business Practices Act. All remedies, penalties, and authority granted to the Attorney General or State?s Attorney by the consumer Fraud and Deceptive Business Practices Act shall be available to him or her for the enforcement of this Act. 57. Section 10 of the Consumer Fraud Act, 815 ILCS 505/ 10, provides that ?in any action brought under the provisions of the Act, the Attorney General is entitles to recover costs for the use of this State.? PRAYER FOR RELIEF - COUNT II WHEREFORE, the plaintiff prays that this honorable Court enter an Order: A. Finding that Defendant has violated Section 15 of the Debt Settlement Act, 225 ILCS 429/ 1 et seq. by acting as a debt settlement provider except as authorized under this Act and without ?rst having obtained a license B. Finding that Defendant has violated Section 105 of the Debt Settlement Act and thereby the Consumer Fraud Act, by engaging in the unlawful acts and practices alleged herein; C. Finding that Defendant has violated Section 125(b) of the Debt Settlement Act and thereby the Consumer Fraud Act by engaging in the prohibited practices alleged herein; Page 18 of 20 D. Finding that Defendant has violated Section 105(b) of the Debt Settlement Act and thereby the Consumer Fraud Act by engaging in the prohibited practices alleged herein; E. Finding that Defendant has violated Section 145 of the Debt Settlement Act and thereby the Consumer Fraud Act by engaging in the prohibited practices alleged herein; F. Preliminarily and permanently enjoining Defendant from engaging in the unlawful, deceptive, and unfair practices alleged herein; G. Declaring that all contracts entered into between Defendant and Illinois consumers by the use of methods and practices declared unlawful are rescinded and requiring that full restitution be made to said consumers; H. Assessing a civil penalty in the amount of Fifty Thousand Dollars ($50,000) if the Court ?nds the Defendant has engaged in methods, acts, or practices declared unlawful by the Act without the intent to defraud, then assessing a statutory civil penalty of $50,000 per violation, all as provided in Section 7 of the Consumer Fraud Act, 815 ILCS 505/ 7; I. Requiring Defendant to pay all costs for the prosecution and investigation of this action, as provided by Section 10 of the Consumer Fraud Act, 815 ILCS 505/10; and J. Providing such other and further equitable relief as justice and equity may require. Page 19 of 20 Respectfully submitted, THE PEOPLE OF THE STATE OF ILLINOIS, by LISA MADIGAN, ATTORNEY GENERAL OF ILLINOIS (54,1411ch 7% Elizabeth Blackston Consumer Fraud Bureau, Chief WM Paul A. Isaac #6300087 Assistant Attorney General Consumer Fraud Bureau 500 South Second Street Spring?eld, IL 62706 Telephone: (217) 782-4436 Facsimile: (217)782-1097 Email: pisaac@atg.state.il.us Connor Tubbs #6315794 Assistant Attorney General Consumer Fraud Bureau 500 South Second Street Spring?eld, IL 62702 Telephone: (217) 782-4436 Facsimile: (217) 782?1097 Email: etubbs@atg.state.il.us Page 20 of 20