Attorney No. 99000 STATE OF ILLINOIS IN THE CIRCUIT COURT OF COOK COUNTY COUNTY DEPARTMENT - CHANCERY DIVISION THE PEOPLE OF THE STATE OF ILLINOIS, Plaintiff, Case No. 15 CH 07254 v. Judge Rita Novak Calendar 09 NATIONWIDE STUDENT AID, LLC, an Illinois Limited Liability Company not in good standing; JUSTIN KRANZLER, individually, and as a member of NATIONWIDE STUDENT AID, BRIAN MISHOULAM, individually, and as a member of NATIONWIDE STUDENT AID, LLC, Defendants. WITH DEFENDANTS NATIONWIDE STUDENT AID, LLC AND BRIAN MISHOULAM Plaintiff, THE PEOPLE OF THE STATE OF ILLINOIS, by LISA MADIGAN, Attorney General of Illinois, ?led her First Amended Complaint for Injunctive and Other Relief (?Amended Complaint?) against Defendants NATIONWIDE STUDENT AID, LLC JUSTIN KRANZLER, and BRIAN MISHOULAM for Violations of the Consumer Fraud and Deceptive Business Practices Act (?Consumer Fraud Act?), 815 ILCS 505/ 1 et seq., the Credit Services Organizations Act, 815 ILCS 605/1 et seq., and the Debt Settlement Consumer Protection Act (?Debt Settlement Act?), 225 ILCS 429/1 et seq. NOW THEREFORE, with the consent of the Defendants NATIONWIDE and MISHOULAM, IT IS HEREBY ORDERED, ADJUDGED, AND DECREED AS FOLLOWS: FINDINGS 1. This Court has jurisdiction over the subject matter of the Amended Complaint having been ?led herein and over Defendants NATIONWIDE and MISHOULAM. 2. MISHOULAM, by signing this Consent Decree, consents to the personal jurisdiction of this Court, waiving service of process or other personal jurisdictional challenges. 3. Venue in this county is proper pursuant to Section 2-101 of the Illinois Code of Civil Procedure, 735 ILCS 5/1-101. 4. NATIONWIDE and MISHOULAM, at all times relevant hereto, engaged in trade and commerce within the meaning of the Consumer Fraud Act, 815 ILCS 505/ by advertising and offering for sale student loan debt relief services in Illinois, and elsewhere. 5. NATIONWIDE and MISHOULAM deny any liability with respect to the Amended Complaint, but desire to settle all matters alleged in the Amended Complaint Without further litigation. 6. This Consent Decree re?ects the negotiated agreement between the Plaintiff and Defendants NATIONWIDE and MISHOULAM. 7. Defendants NATIONWIDE and MISHOULAM acknowledge that they have read and understand the terms and conditions of this Consent Decree, and understand the legal obligations imposed on them. The undersigned representative of both Defendants acknowledge that he has the authority to bind NATIONWIDE and MISHOULAM to the terms, conditions, and obligations imposed by this Consent Decree. Defendants NATIONWIDE and MISHOULAM further acknowledge that a violation of this Consent Decree may result in proceedings against each and all of them, including but not limited to, an action for contempt of court. DEFINITIONS 8. Except as hereinafter stated and unless a different meaning of the term is clear from its context, the de?nitions of terms used in this Consent Decree shall be the same as those used in the Consumer Fraud Act, 815 ILCS 505/1 et seq., the Credit Services Organizations Act, 815 ILCS 605/1 et seq., and the Debt Settlement Act, 225 ILCS 429/1 et seq. INJUNCTIVE RELIEF 9. NATIONWIDE and any of its subsidiaries, af?liates, assigns, predecessors, successors, sibling corporations acting on behalf of NATIONWIDE, whether under the name of Nationwide Student Aid, LLC or any other name, are hereby permanently enjoined from: A. Operating in the State of Illinois; B. Engaging in the advertising, soliciting, offering for sale and selling of student loan debt settlement and relief services in the State of Illinois. 10. NATIONWIDE and MISHOULAM, their successors, assigns, of?cers, agents, servants, employees, and those persons in active concert or participation with them are hereby permanently enjoined from disclosing, using, or benefitting from customer information, including the name, address, telephone number, email address, social security number, and any other identifying information, that NATIONWIDE or MISHOULAM obtained prior to the entry of this Consent Decree, in connection with the advertising, soliciting, offering for sale and selling student loan debt settlement and relief services. ll. NATIONWIDE and MISHOULAM, its successors, assigns, of?cers, agents, servants, employees, and those persons in active concert or participation with them shall, within 30 days after receipt of written direction to do so from a representative of the Plaintiff, destroy such customer information in all forms in their possession, custody, or control; provided, however, that customer information need not be disposed of, and may be disclosed, to the extent requested by a government agency or required by law, regulation, or by court order. 12. All alleged contracts or agreements between NATIONWIDE and MISHOULAM and their agents, employees and/or representatives and consumers who have purchased NATIONWIDE or services, are hereby rescinded and set aside. PAYMENT TO THE STATE 13. IT IS FURTHER ORDERED that, at or before the entry of this Consent Decree, Defendants NATIONWIDE and MISHOULAM shall pay seven thousand ?ve hundred dollars ($7,500) directly to the Plaintiff. Said payment shall be in the form of a cashier?s or certi?ed check made payable to the ?Attorney General Court Ordered and Voluntary Compliance Payment Projects Fund." SEVERABILITY 14. If any portion of this Consent Decree is held to be invalid, unenforceable, or void for any reason whatsoever, then such portion will be severed from the remainder, and will not affect the validity and enforceability of the remaining portions of the Consent Decree. JURISDICTION RETAINED 15. Jurisdiction is expressly retained by this Court for the purpose of enforcing compliance with this Consent Decree, which enforcement shall be solely upon application of the Attorney General or her successor in of?ce. EFFECTIVE DATE 16. Pursuant to Illinois Supreme Court Rule 304(a), this is a ?nal order and no just reason exists to delay enforcement or appeal of this Consent Decree. SO ORDERED: tunes mm M- '6 Dated: FEB d3 Lm Honorable, 141 SO STIPULATED AND AGREED: Attorneys for Plaintiff People of the State of Illinois By Lisa Madigan, Attorney General of Illinois Dated: Consumer Fraud Bureau Chief Andy Dougherty Joseph Pham Assistant Attorneys General Consumer Fraud Bureau 100 West Randolph Street, 12th ?oor Chicago, Blinois 60601 312/814-3740 jpham@atg.state.il.us SO STIPULATED AND AGREED: Dated: Brian Mishoulam Member of Defendant NATIONWIDE STUDENT All), LLC Brian Mishoulam Dated. Individually W0 Dated has much Ar, A60 Steven tz Attorney for Defen/dant NATIONWIDE STUDENT AID, LLC Attorney for Defendant BRIAN MISHOULAM Amstein Lehr LLP 120 South Riverside Plaza, Suite 1200 Chicago, Illinois 60606 312.876.7134 snmalitz@arnstein.com