1 2 3 4 5 6 7 8 9 10 11 12 ALDEN F. ABBOTT General Counsel JOSHUA S. MILLARD, pro hac vice jmillard@ftc.gov BRIAN M. WELKE, pro hac vice bwelke@ftc.gov FEDERAL TRADE COMMISSION 600 Pennsylvania Ave., N.W., CC-9528 Washington, D.C. 20580 Tel: (202) 326-2454, -2897; Fax: (202) 326-3197 BARBARA CHUN, Local Counsel, Cal. Bar. No. 186907 bchun@ftc.gov FEDERAL TRADE COMMISSION 10990 Wilshire Blvd., Suite 400 Los Angeles, CA 90024 Tel: (310) 824-4312; Fax: (310) 824-4380 Attorneys for Plaintiff 13 UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA 14 15 16 17 18 19 20 Case No. ____________ FEDERAL TRADE COMMISSION, Plaintiff, COMPLAINT FOR PERMANENT INJUNCTION AND OTHER EQUITABLE RELIEF v. 21 22 23 24 25 26 27 IMPETUS ENTERPRISE, INC., a California corporation, also d/b/a Aiding Student Relief, Aiding Students & Teachers, Aidnest, Avec Staffing, and National Education Student and Teacher; FIG TREE & CO., LLC, a California limited liability company, also d/b/a Aiding Student Relief, Aiding Students & Teacher, and Aiding [Lodged Under Seal] 28 1 1 1 2 3 4 5 6 7 8 9 Students & Teachers; TUAN DINH DUONG, a/k/a Thomas Duong, a/k/a Thomas Dinh, individually and as an officer of IMPETUS ENTERPRISE, INC.; BRENDA AVITIA-PENA, individually and as an officer of IMPETUS ENTEPRISE, INC. and FIG TREE & CO., LLC; and BRIAN COLOMBANA d/b/a FUTERO, individually and as an officer of FIG TREE & CO., LLC, Defendants, and 10 11 NOEL SOLUTIONS, LLC, a Wyoming limited liability company, 12 Relief Defendant. 13 14 15 Plaintiff, the Federal Trade Commission (“FTC”), for its Complaint alleges: 16 1. The FTC brings this action under Section 13(b) of the Federal Trade 17 Commission Act (“FTC Act”), 15 U.S.C. § 53(b), and the Telemarketing and 18 Consumer Fraud and Abuse Prevention Act (“Telemarketing Act”), 15 U.S.C. §§ 19 6101-6108, to obtain temporary, preliminary, and permanent injunctive relief, 20 rescission or reformation of contracts, restitution, the refund of monies paid, 21 disgorgement of ill-gotten monies, and other equitable relief for Defendants’ acts 22 or practices in violation of Section 5(a) of the FTC Act, 15 U.S.C. § 45(a), and the 23 FTC’s Telemarketing Sales Rule (“TSR”), 16 C.F.R. Part 310, in connection with 24 their deceptive marketing and sale of student loan debt relief services. 25 26 27 JURISDICTION AND VENUE 2. This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331, 1337(a), and 1345, and 15 U.S.C. §§ 45(a), 53(b), 6102(c), and 6105(b). 28 2 2 1 2 3. Venue is proper in this district under 28 U.S.C. § 1391(b)(1), (b)(2), (c)(1), (c)(2), (c)(3), and (d), and 15 U.S.C. § 53(b). PLAINTIFF 3 4 4. The FTC is an independent agency of the United States Government 5 created by statute. 15 U.S.C. §§ 41-58. The FTC enforces Section 5(a) of the FTC 6 Act, 15 U.S.C. § 45(a), which prohibits unfair or deceptive acts or practices in or 7 affecting commerce. The FTC also enforces the Telemarketing Act, 15 U.S.C. §§ 8 6101-6108. Pursuant to the Telemarketing Act, the FTC promulgated and enforces 9 the TSR, 16 C.F.R. Part 310, which prohibits deceptive and abusive telemarketing 10 acts or practices in or affecting commerce. 11 5. The FTC is authorized to initiate federal district court proceedings, by 12 its own attorneys, to enjoin violations of the FTC Act and the TSR, and to secure 13 such equitable relief as may be appropriate in each case, including rescission or 14 reformation of contracts, restitution, the refund of monies paid, and the 15 disgorgement of ill-gotten monies. 15 U.S.C. §§ 53(b) and 6102(c). DEFENDANTS 16 17 6. Defendant Impetus Enterprise, Inc. (“Impetus”), also doing business 18 as Aiding Student Relief, Aiding Students & Teachers, Aidnest, Avec Staffing, and 19 National Education Student and Teacher, is a California corporation with its 20 principal place of business at 18100 Von Karman Ave., Suite 850, Irvine, 21 California 92612. Impetus transacts or has transacted business in this district and 22 throughout the United States. At all times material to this Complaint, acting alone 23 or in concert with others, or as part of the common enterprise described in 24 paragraph 12, Impetus has advertised, marketed, offered to provide, provided, 25 offered for sale, or sold student loan debt relief services to consumers throughout 26 the United States. 27 28 3 3 1 7. Defendant Fig Tree & Co., LLC (“Fig Tree LLC”), also doing 2 business as Aiding Student Relief, Aiding Students & Teacher, and Aiding 3 Students & Teachers, is a California limited liability company with its principal 4 place of business at 18100 Von Karman Ave., Suite 850, Irvine, California 92612. 5 Fig Tree LLC transacts or has transacted business in this district and throughout 6 the United States. At all times material to this Complaint, acting alone or in 7 concert with others, or as part of the common enterprise described in paragraph 12, 8 Fig Tree LLC has advertised, marketed, offered to provide, provided, offered for 9 sale, or sold student loan debt relief services to consumers throughout the United 10 States. 11 8. Defendant Tuan Dinh Duong, also known as Thomas Duong and 12 Thomas Dinh (“Duong”), has identified himself as or served as the President, 13 director, general manager, sales manager, owner, co-owner, and principal 14 shareholder of Impetus. At all times material to this Complaint, acting alone or in 15 concert with others, he has formulated, directed, controlled, had the authority to 16 control, or participated in the acts and practices set forth in this Complaint. 17 Defendant Duong resides in this district and, in connection with the matters alleged 18 herein, transacts or has transacted business in this district and throughout the 19 United States. 20 9. Defendant Brenda Avitia-Pena (“Avitia-Pena”) has identified herself 21 as or served as the President, CEO, Secretary, CFO, director, and owner of 22 Impetus, and the manager of Fig Tree LLC. At all times material to this 23 Complaint, acting alone or in concert with others, she has formulated, directed, 24 controlled, had the authority to control, or participated in the acts and practices set 25 forth in this Complaint. Defendant Avitia-Pena resides in this district and, in 26 connection with the matters alleged herein, transacts or has transacted business in 27 this district and throughout the United States. 28 4 4 1 10. Defendant Brian Colombana (“Colombana”), who has also done 2 business under the fictitious business name “Futero,” has identified himself as or 3 served as co-owner of Impetus (and CIO of its d/b/a, Avec Staffing), and manager 4 of Fig Tree LLC. At times material to this Complaint, through at least January 5 2018, acting alone or in concert with others, Colombana formulated, directed, 6 controlled, had the authority to control, or participated in the acts and practices set 7 forth in this Complaint. Defendant Colombana resides in this district and, in 8 connection with the matters alleged herein, transacts or has transacted business in 9 this district and throughout the United States. RELIEF DEFENDANT 10 11 11. Relief Defendant Noel Solutions, LLC (“Noel”) has received funds 12 that can be traced directly to Defendants’ deceptive acts or practices alleged below, 13 for which it has no legitimate claim. Noel is a Wyoming limited liability company 14 that reported in a public document that its principal place of business is 1623 15 Central Ave., Suite 201, Cheyenne, Wyoming 82001. Noel also incorporated as a 16 California limited liability company in January 2018, listing its address as 18997 17 Barroso St., Rowland Heights, California 91748. Noel resides in this district and 18 in the district of Wyoming. COMMON ENTERPRISE 19 20 12. Defendants Impetus and Fig Tree LLC (“Corporate Defendants”) have 21 operated as a common enterprise while engaging in the unlawful acts and practices 22 alleged below. Defendants have conducted the business practices described below 23 through interrelated companies that have common ownership, officers, managers, 24 business functions, employees, and office locations, and routinely transfer funds 25 amongst themselves. Because the Corporate Defendants have operated as a 26 common enterprise, each is jointly and severally liable for the acts and practices 27 alleged below. Defendants Duong, Avitia-Pena, and Colombana have formulated, 28 5 5 1 directed, controlled, had the authority to control, or participated in the acts and 2 practices of the Corporate Defendants that constitute the common enterprise. COMMERCE 3 4 13. At all times material to this Complaint, Defendants have maintained a 5 substantial course of trade in or affecting commerce, as “commerce” is defined in 6 Section 4 of the FTC Act, 15 U.S.C. § 44. 7 DEFENDANTS’ UNLAWFUL STUDENT LOAN DEBT RELIEF 8 OPERATION 9 14. Since at least December 2014, Defendants have operated an unlawful 10 debt relief scheme that preys on consumers with student loan debt. In telephone 11 calls and on websites, Defendants promise to reduce consumers’ monthly student 12 loan payments and eliminate all, or a portion of, their student loan debt through 13 enrollment in student loan forgiveness or repayment programs. In many instances, 14 however, Defendants failed to obtain debt forgiveness or monthly payment 15 reductions. In fact, some consumers owed more on their student loans after 16 enrolling in Defendants’ program. 17 18 19 20 15. In exchange for the promised student loan debt relief services, Defendants have charged illegal upfront fees of $499 or more. Background on Student Loan Forgiveness and Repayment Programs 16. Student loan debt is the second largest class of consumer debt; more 21 than 42 million Americans collectively owe nearly $1.5 trillion in student loan 22 debt. The student loan market shows elevated levels of distress relative to other 23 types of consumer debt. 24 17. To address this mounting level of distressed debt, the U.S. 25 Department of Education (“USDE”) and state government agencies administer a 26 limited number of student loan forgiveness and discharge programs. Most 27 consumers, however, do not qualify for these programs because of strict eligibility 28 6 6 1 requirements. For example, one program requires the consumer to demonstrate a 2 total and permanent disability; another applies only to consumers whose school 3 closed while the consumer was still enrolled. A third program, the Borrower 4 Defense to Repayment (“BDR”), may provide a loan discharge if the school, 5 through an act or omission, violated state law directly related to the borrower’s 6 federal student loan or to the educational services for which the loan was provided. 7 18. Other forgiveness programs require borrowers to work in certain 8 professions for a period of years. For example, Teacher Loan Forgiveness applies 9 to teachers who have worked full-time for five years in a low-income elementary 10 or secondary school or educational service agency. Public Service Loan 11 Forgiveness (“PSLF”) applies to employees of governmental units or non-profit 12 organizations who make timely monthly payments for a period of ten years while 13 employed in the public sector. 14 19. The federal government also offers loan forgiveness through income- 15 driven repayment (“IDR”) programs that enable borrowers to reduce their monthly 16 payments and have portions of their loans forgiven. IDR programs allow eligible 17 borrowers to limit their monthly payments based on a percentage of their 18 discretionary monthly income. To remain in an IDR program, borrowers must 19 recertify their income and family size annually. Obtaining forgiveness through 20 IDR programs requires a minimum of 20 or 25 years of qualifying payments, 21 depending on whether borrowers received their first loans on July 1, 2014 or 22 before that date. Because a borrower’s income is likely to fluctuate over the life of 23 the loan, monthly payments under the IDR programs can vary considerably from 24 year to year. If a borrower’s income were to increase over the repayment period, 25 for example, the monthly payment amount could correspondingly increase to the 26 point where those payments would pay off the loan before any amount could be 27 forgiven at the end of the repayment term. No loans have been forgiven yet under 28 7 7 1 any of the IDR programs because the programs have not existed long enough for 2 borrowers to make the minimum number of years of qualifying payments. 3 20. Consumers can apply for BDR, PSLF, IDR, and other loan repayment 4 and forgiveness or discharge programs through USDE or their student loan 5 servicers at no cost; these programs do not require the assistance of a third-party 6 company or payment of application fees. 7 21. USDE will grant forbearance while processing applications for an 8 alternative repayment plan, and in some cases of hardship. During forbearance, 9 unpaid interest is added to the principal balance. 10 11 Defendants’ Deceptive Marketing of Student Loan Debt Relief Services 22. To lure consumers into purchasing their purported student loan debt 12 relief services, Defendants have made false promises to eliminate or reduce 13 consumers’ student loan balances or monthly payments through loan forgiveness 14 or other programs. 15 23. To induce consumers to purchase their purported student loan debt 16 relief services, Defendants have disseminated websites such as aidingstudents.com 17 and aidnest.com, including, but not necessarily limited to, the attached exhibits A 18 through E. Defendants’ websites have contained the following statements, among 19 others: 20 21 22 23 24 25 26 27 Free Assessment Service Guarantee Success Rate Our experts will assess your current student loan program, and determine which programs are available in your situation. We will help you decide which program can help you We are committed to helping customers get lower rates and monthly payments, and we will make the process seamless and straightforward. You will be satisfied with our Our 96% success rate is one of the top ratings in the industry. Our process has been tested, and our success rate proves that it works. We can help you reduce and simplify your payments. Call us today! 28 8 8 1 achieve your goals. Call us today! 2 3 service and our commitment to your success. That’s our guarantee. 4 5 Ex. A at 1 (aidingstudents.com, 2015). 6 7 “We can help you reduce and simplify your payments. Contact one of our specialists today for a free evaluation.” 8 9 Ex. A at 2 (emphasis in original). 10 11 12 “‘Aiding Student Relief has helped countless people reduce their student debt. Their proven business plan has led to one of the highest success rates in the industry.’” 13 14 15 16 17 18 19 20 21 22 23 Ex. A at 4. 100% Customer Satisfaction We can help you reduce and simplify your payments. Call one of our specialists today. Ex. B at 1 (aidingstudents.com, 2016) (emphasis in original). Meet some of our members who have saved big on their student loan debt. Helping You Save Big ---------“Thanks to Aiding Student Relief, I am savings [sic] $250 per month.” Michael Martin Entrepreneur 24 Ex. B at 2 (emphasis in original). 25 “We can help you reduce and simplify your payments . . . .” 26 27 Ex. C at 1 (aidingstudents.com, 2018) (emphasis in original). 28 9 9 1 Student Loan 2 Forgiveness 3 4 5 6 7 8 Loan Forgiveness Forgiveness If you have Federal Student Loans, you’re in the right place to get those loans reduced, forgiven or completely discharged through our student loan forgiveness programs. Get your multiple Federal Student Loans consolidated into one, forget about increasing interests [sic] and pay month to month at the lowest possible cost. 9 10 Student Loan We understand if you’re going through some hardship, and that’s why with us you’ll be able to make monthly payments based on your affordability, for as low as $0.00, depending on your situation. Ex. D at 2 (aidnest.com, 2016). 11 12 13 14 15 16 17 Lower your loan payments by getting in touch with one of our professionals We design a customized repayment plan that will allow you to make payments based on your monthly income, family size, and spending. Get rid of the hassle of extensive paperwork and get the help you deserve. What we can help you achieve [is] a lower payment or lower rate. 18 19 20 21 22 23 24 25 26 27 Ex. E at 6 (aidnest.com, 2018) (emphasis in original). 24. In some instances, consumers view the Defendants’ online advertising and call Defendants’ telemarketers for more information. Defendants also make outbound telemarketing calls and send texts to consumers to offer their services and convince student loan borrowers to sign up for Defendants’ debt relief services. 25. In calls with consumers, Defendants’ telemarketers have told consumers that Defendants can cause consumers’ student loan balances to be reduced, or that consumers’ loan balances would be forgiven after making lower 28 10 10 1 monthly payments. Defendants’ telemarketers have told some consumers that over 2 half their loan balance would be forgiven. Moreover, Defendants’ telemarketers 3 have told some consumers that their loan payments could or would be rapidly 4 reduced to $19 per month, or promptly forgiven. 5 26. Defendants have made other representations concerning loan 6 reduction or forgiveness to consumers in telemarketing their debt relief services. 7 For example, Defendants’ telemarketers have told one or more consumers that 8 “family size,” a metric for determining the amount borrowers pay each month 9 under IDR plans, includes “anyone you help out throughout the year[,] they don’t 10 have to live with you,” even claiming that helping with “gas money, three times 11 out of the year” is enough to include a person in “family size.” Further, 12 Defendants’ telemarketers have offered one or more consumers “basically a 13 guarantee to remain” in an IDR plan, and warned one or more consumers that 14 signing up for an IDR plan with a lender instead would result in a higher loan 15 payment. 16 27. Defendants have not been likely to achieve the lower monthly 17 payments or student loan forgiveness they have advertised, marketed, and 18 promoted to consumers. In many instances, Defendants have failed to obtain the 19 promised lower monthly payments or student loan forgiveness. 20 28. Defendants have charged consumers fees for purported debt relief 21 services before achieving lower monthly payments or student loan forgiveness, 22 and, in many instances, have failed to achieve those results at all on behalf of 23 consumers. 24 25 29. Defendants’ telemarketers have sought and obtained consumers’ payment information by phone or the Internet. 26 27 28 11 11 1 30. Defendants’ total advance fees typically have been in the range of 2 $300-500. Defendants also have charged consumers recurring monthly fees for 3 purported debt relief services, typically charging $19 per month. THE FTC ACT 4 5 6 7 8 31. Section 5(a) of the FTC Act, 15 U.S.C. § 45(a), prohibits “unfair or deceptive acts or practices in or affecting commerce.” 32. Misrepresentations or deceptive omissions of material fact constitute deceptive acts or practices prohibited by Section 5(a) of the FTC Act. 9 VIOLATIONS OF THE FTC ACT 10 Count One 11 (Deceptive Student Loan Debt Relief Representations) 12 33. In numerous instances in connection with the advertising, marketing, 13 promotion, offering for sale, or sale of student loan debt relief services, Defendants 14 have represented, directly or indirectly, expressly or by implication, that consumers 15 who purchase Defendants’ debt relief services will or likely will have their 16 monthly payments reduced or their loan balances forgiven in whole or in part. 17 34. In truth and in fact, in numerous instances in which Defendants have 18 made the representations set forth in Paragraph 33 of this Complaint, such 19 representations were false or not substantiated at the time Defendants made them. 20 35. Therefore, Defendants’ representations as set forth in Paragraph 33 of 21 this Complaint are false or misleading and constitute deceptive acts or practices in 22 violation of Section 5(a) of the FTC Act, 15 U.S.C. § 45(a). 23 24 25 26 THE TELEMARKETING SALES RULE 36. Congress directed the FTC to prescribe rules prohibiting abusive and deceptive telemarketing acts or practices pursuant to the Telemarketing Act, 15 U.S.C. §§ 6101-6108, in 1994. The FTC adopted the original TSR in 1995, 27 28 12 12 1 extensively amended it in 2003, and amended certain sections thereafter. 16 2 C.F.R. Part 310. 3 37. Defendants are “seller[s]” or “telemarketer[s]” engaged in 4 “telemarketing” as defined by the TSR, 16 C.F.R. § 310.2(dd), (ff), and (gg). A 5 “seller” means any person who, in connection with a telemarketing transaction, 6 provides, offers to provide, or arranges for others to provide goods or services to a 7 customer in exchange for consideration. 16 C.F.R. § 310.2(dd). A “telemarketer” 8 means any person who, in connection with telemarketing, initiates or receives 9 telephone calls to or from a customer or donor. 16 C.F.R. § 310.2(ff). 10 “Telemarketing” means a plan, program, or campaign which is conducted to 11 induce the purchase of goods or services or a charitable contribution, by use of one 12 or more telephones and which involves more than one interstate telephone call. 16 13 C.F.R. § 310.2(gg). 14 38. Defendants are sellers or telemarketers of “debt relief services” as 15 defined by the TSR, 16 C.F.R. § 310.2(o). Under the TSR, a “debt relief service” 16 means any program or service represented, directly or by implication, to 17 renegotiate, settle, or in any way alter the terms of payment or other terms of the 18 debt between a person and one or more unsecured creditors or debt collectors, 19 including, but not limited to, a reduction in the balance, interest rate, or fees owed 20 by a person to an unsecured creditor or debt collector. 16 C.F.R. § 310.2(o). 21 39. The TSR prohibits sellers and telemarketers from requesting or 22 receiving payment of any fees or consideration for any debt relief service until and 23 unless: 24 a. The seller or telemarketer has renegotiated, settled, reduced, or 25 otherwise altered the terms of at least one debt pursuant to a 26 settlement agreement, debt management plan, or other such 27 valid contractual agreement executed by the customer; and 28 13 13 b. 1 The customer has made at least one payment pursuant to that 2 settlement agreement, debt management plan, or other valid 3 contractual agreement between the customer and the creditor; 4 and c. 5 To the extent that debts enrolled in a service are renegotiated, 6 settled, reduced, or otherwise altered individually, the fee or 7 consideration either: 8 i. Bears the same proportional relationship to the total fee 9 for renegotiating, settling, reducing, or altering the terms 10 of the entire debt balance as the individual debt amount 11 bears to the entire debt amount. The individual debt 12 amount and the entire debt amount are those owed at the 13 time the debt was enrolled in the service; or ii. 14 Is a percentage of the amount saved as a result of the 15 renegotiation, settlement, reduction, or alteration. The 16 percentage charged cannot change from one individual 17 debt to another. The amount saved is the difference 18 between the amount owed at the time the debt was 19 enrolled in the service and the amount actually paid to 20 satisfy the debt. 16 C.F.R. § 310.4(a)(5)(i). 21 40. The TSR prohibits sellers and telemarketers from misrepresenting 22 directly or by implication, any material aspect of any debt relief service, including, 23 but not limited to, the amount of money or the percentage of the debt amount that a 24 customer may save by using the service. 16 C.F.R. § 310.3(a)(2)(x). 25 26 41. Pursuant to Section 3(c) of the Telemarketing Act, 15 U.S.C § 6102(c), and Section 18(d)(3) of the FTC Act, 15 U.S.C. § 57a(d)(3), a violation 27 28 14 14 1 of the TSR constitutes an unfair or deceptive act or practice in or affecting 2 commerce, in violation of Section 5(a) of the FTC Act, 15 U.S.C. § 45(a). 3 VIOLATIONS OF THE TELEMARKETING SALES RULE 4 Count Two 5 (Advance Fee for Debt Relief Services) 6 42. In numerous instances, in connection with the telemarketing of 7 student loan debt relief services, Defendants have requested or received payment 8 of a fee or consideration for debt relief services before: 9 a. 10 altered the terms of at least one debt pursuant to a settlement 11 agreement, debt management plan, or other such valid contractual 12 agreement executed by the customer; and 13 b. 14 settlement agreement, debt management plan, or other valid 15 contractual agreement between the customer and the creditor. 16 43. Defendants have renegotiated, settled, reduced, or otherwise The customer has made at least one payment pursuant to that Defendants’ acts or practices, as described in Paragraph 40 of this 17 Complaint, are abusive telemarketing acts or practices that violate Section 18 310.4(a)(5)(i) of the TSR, 16 C.F.R. § 310.4(a)(5)(i). 19 Count Three 20 (Material Debt Relief Misrepresentations) 21 44. In numerous instances, in connection with the telemarketing of 22 student loan debt relief services, Defendants have misrepresented, directly or 23 indirectly, expressly or by implication, material aspects of their debt relief services, 24 including, but not limited to that consumers who purchase Defendants’ debt relief 25 services will or likely will have their monthly payments reduced or their loan 26 balances forgiven in whole or in part. 27 28 15 15 1 45. Defendants’ acts and practices, as described in Paragraph 42 of this 2 Complaint, are deceptive telemarketing acts or practices that violate Section 3 310.3(a)(2)(x) of the TSR, 16 C.F.R. § 310.3(a)(2)(x). 4 Count Four 5 (Disgorgement of Ill-Gotten Gains of Relief Defendant) 6 46. Relief Defendant Noel has received, directly or indirectly, funds or 7 other assets from Defendants that are traceable to funds obtained from Defendants’ 8 customers through the unlawful acts or practices described herein. 9 47. Relief Defendant Noel has no legitimate claim to Defendants’ 10 customers’ funds or other assets and will be unjustly enriched if it is not required to 11 disgorge the assets or the value of benefits received as a result of Defendants’ 12 unlawful acts or practices. 13 14 48. assets in constructive trust for the benefit of Defendants’ customers. CONSUMER INJURY 15 16 By reason of the foregoing, Relief Defendant Noel holds funds and 49. Consumers have suffered and will continue to suffer substantial injury 17 as a result of Defendants’ violations of the FTC Act and the TSR. In addition, 18 Defendants have been unjustly enriched as a result of their unlawful acts or 19 practices. Absent injunctive relief by this Court, Defendants are likely to continue 20 to injure consumers, reap unjust enrichment, and harm the public interest. THIS COURT’S POWER TO GRANT RELIEF 21 22 50. Section 13(b) of the FTC Act, 15 U.S.C. § 53(b), empowers this Court 23 to grant injunctive and such other relief as the Court may deem appropriate to halt 24 and redress violations of any provision of law enforced by the FTC. The Court, in 25 the exercise of its equitable jurisdiction, may award ancillary relief, including 26 rescission or reformation of contracts, restitution, the refund of monies paid, and 27 28 16 16 1 the disgorgement of ill-gotten monies, to prevent and remedy any violation of any 2 provision of law enforced by the FTC. 3 51. Section 6(b) of the Telemarketing Act, 15 U.S.C. § 6105(b), 4 authorizes this Court to grant such relief as the Court finds necessary to redress 5 injury to consumers resulting from Defendants’ violations of the TSR, including 6 the rescission or reformation of contracts, and the refund of money. 7 PRAYER FOR RELIEF 8 Wherefore, Plaintiff FTC, pursuant to Section 13(b) of the FTC Act, 15 9 U.S.C. § 53(b), Section 6(b) of the Telemarketing Act, 15 U.S.C. § 6105(b), and 10 the Court’s own equitable powers, requests that the Court: 11 A. Award Plaintiff such preliminary injunctive and ancillary relief as 12 may be necessary to avert the likelihood of consumer injury during 13 the pendency of this action and to preserve the possibility of effective 14 final relief, including but not limited to, temporary and preliminary 15 injunctions, orders freezing assets, immediate access to business 16 premises, appointment of a receiver, and expedited discovery; 17 B. Act and the TSR; 18 19 Enter a permanent injunction to prevent future violations of the FTC C. Award such relief as the Court finds necessary to redress injury to 20 consumers resulting from Defendants’ violations of the FTC Act and 21 the TSR, including but not limited to, rescission or reformation of 22 contracts, restitution, the refund of monies paid, and the disgorgement 23 of ill-gotten monies; 24 D. Enter an order requiring Relief Defendant to disgorge all funds and 25 assets, or the value of the benefit it received from the funds and assets, 26 which are traceable to funds obtained from Defendants’ customers 27 through the unlawful acts or practices described herein; and 28 17 17 1 2 E. Award Plaintiff the costs of bringing this action, as well as such other and additional relief as the Court may determine to be just and proper. 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 18 18 1 2 Dated: November 6, 2018 3 Respectfully submitted, 4 ALDEN F. ABBOTT General Counsel 5 6 7 8 Brian Barbara Chun Attorneys for Plaintiff FEDERAL TRADE COMMISSION 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 19 19 EXHIBIT A STUDENT LOAN CRISIS AND WHAT YOU CAN DO (855) 51 0-5400 BAUSING ALL JNFLA 'iilIN EASY ACCESS f0 LOANS DEGREASINE VALUE IF SUSDIM Free Assessment (DUI experts will assess your current Sunder?. roan program. and tierermzne thlil?: programs are avarianle yam Situation. We Will help ycuu wincl'l can help yeu achieve yew goat. {ail us today! APPLY NOW More Info ?5 Service Guarantee We are commuted to helping Customers get lower rates and montIny payments. anti we Will make the gamma: Se-amiess. and ?mu he sausr'lec! with anur sewn}? anal cun- con-Irm'tment to you: success. That's guarantee. HIST-I DEPOBOOK COM Success Rate Our 96% Success rate vs one the top: ??lings the industry. 0le process has Deer". rested. ant: mm 31301-255 rare prove: That it works. We can heir: ym; reduce anti your payl?nents. Call Ui- Intlay! 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Alcimg to 13"1'e1 311:1'11101'1161 l3ac1511511'31'1511ee We Have Been Featured In FTC-AI D-2 Exhibit A 21 Loan Forgiveness In some cases, individuals with Federal Student Loans may qualify to have a portion of the amount owed may be forgiven. This means your principal balance could be significantly reduced. and you will not be expected to repay the forgiven amount. HI Private Sector Loan Forgiveness if you work for a government organization at a City, state. or federal level. you may qualify for the Public Service Loan Forgiveness program. To qualify, your loans must be consolidated into a specrfic repayment plan. The balance on your federal student loans is forgiven after 120 qualifying SERVICES A Income Based Payments A period of financial hardship may qualify you for an Income Based Repayment Plan. In many cases, this means you pay nothing. Unlike a deferment. the term on your loan continues to reduce while the plan is in place. Your term could reduce while you pay nothing. Permanent Disability Forgivenness lfyour disability is expected to last 60 months or more. you may qualify for permanent disabliity forgiveness. Qualifying for Permanent Disability Forgiveness requires a visit to your doctor, and individuals enrolled in the program are subject to three years of post-discharge monitoring. Loan Consolidation You may be able to combine multiple federal student loans into one new loan with a lower, more affordable payment. Loan consolidation programs can help you qualify for additional programs like loan forgiveness programs or Public Service Loan Forgiveness. Wage Garnishment Prevention Federal law requires that the Department of Education or a guaranty agency notify you before instituting wage garnishment. You have the right to a hearing. where you can challenge the stated amount owed and negotiate the terms of the repayment schedule. we can intervene on Exhibit A 22 payments have been made. prevent wage garnishments. A FEW STATISTICS ABOUT STUDENT LOAN CRISIS l.2Trillion 40 Million $33,000 National Student Debt Students with Debt Average Student Debt The national student loan debt is In 2014, an estimated 40 million The graduating class of 2014 now trillion dollars. 1 trillion of current and former students were in average $33,000 of student loan these are in federal student loans. debt because of student loans. If debt per person. That's $3,000 more Let us help you through this national you are one of the millions of people than the average in 2013. Don't be crisis. Call today for a free struggling to pay student loans, one of the many. Let Aiding Student evaluation. Aiding Student Relief is here to help. Relief advocate for you. "Aiding Student Reliellms helped ('ounlless people reduce llieir student debt. Their proveu business plan has led In one of Iiiglu?sl success rates in the. induslry." John Standiford Associated Exhibit A 23 TESTIMONIALS Thanks to Aiding, Student Relief, I'm saving $250 per month." Michael Maitin Entrepienetn "With so many programs, I didn?t know what was right for me My Student loan aclwsor walked me through my options. and now l'm saving $41 lrmonth.? Aliei Hern'iquez Sales Consultant wag oveiwhelmed, but Aiding Student Relief explained the precess, and made everything clear and simple.? Teacher Consolidating my loans into one payment has made life simple: Now can tow-3 en what matters to me." Stephanie Selandel Smali Business Owner "The experts at Aiding Student Relief were there to help me when I needed it most! A 9 r' Paul Cinistiansen Ne. rse love myJoi?J, but with my high student loan payments. was still barely getting by. I don't knew what I would have done without Aiding Student Relief," Olsen Museum Curator RECENT NEWS Exhibit A 24 Debt Collective Demands The Debt Collective is a group of college students calling themselves the ?Corinthian Fifteen" who are refusing to pay back their Student loans. As part of this effort. the Debt Collective has written an open letter to the Department of {teal lliill'f Student Debt Crisis May be largely about smallesc borrowers US. News World Report-May l6, 2015 last month. the Federal Reserve Bank of New York repm tecl that student loan balances rose to l.6 trillion and that 3.3 percent of that is in I i . I Business Latest: Student Loan Crisis is far from over. Two new reports suggest the student loan crisis is easing somewhat as the economy improves. but the crisis is far it om over. the College Board reports total borrowing fell by 8 percent between 2012- I 3' and 20l'3-i4. The Heat} mire TAKE THE NEXT STEP ll uranr .irr- litll .?illurthlilr'x lrli Airlirn; help. wrirlr: Willi yrlli yinir lr?nrlrir Ir) linrl ?Ml lur yin] i tiriinrl rirw ill lilji About Us . Feller Em; w: trarrecl e-ire cr- to ?rein .I {Saritact u: "or wee siu we": r; arsrinlisljt a lit-ll." evaluation, i APPLY Address A Snider's. De! 9? lit-NJ Eii'C] 1-. i ii?l'i ?l?lrlih I l: ?re-er: hens? 855.510.5400 Ers'igii li'w' ice-n: i:l:r Ti FTC-AI D-6 Exhibit A 25 fiS?in?D PRIVACY POLICY This privacy statement discloses the privacy practices for Aiding Student Relief. Because Aiding Student Relief wants to demonstrate its firm commitment to your privacy, Aiding Student Relief has agreed to disclose its information gathering and dissemination pracncas. Aiding Student Relief will notify you of: INFORMATION COLLECTION AND USE Aiding Student Relief is the sole owner of the information collected on this site We will not sell. share or rent this information to others in ways different from what is disclosed in this statement. Aiding Student Relief collects information through this site from our prospective and existing clients at several different points on our web site. We use their contact Information to send information about our company and to service existing accounts. Users may opt-out of receiving future mailings, see the cholcefopt-out section below. Contact and Financial Information that IS collected is used for verifying your name, addreS' and other information. as well as to bill you for your use ofour sewices using information from third party sources. information about your computer hardware and software is automatically collected by Aiding Student Relief and may be shared in aggregate With third parties whose services are used for traffic analysis purposes. This information includes. your IP address. browser type. domain names, access times and referring Web site addresses. This infon'nation is not tied to personally identifiable information This information is used by Aiding Student Reliefto maintain and Improve the quality of the servuce and to generate statistics regarding use of the Aiding Student Relief site. We use third party services to bill for services and to provide other services like our "Live Help" chat. We store the transcripts from these chats for customer service improvement These third party service providers are not permitted to use your information for any secondary purposes. Thank you and cheers! FTC-AID-T Exhibit A 26 EXHIBIT 01213456 7898 9 ÿ 8 ÿ ÿ ÿ ÿ ÿ ÿ ! ÿ !ÿ"#$ #% ÿ ÿ $ &"'ÿ( ÿ ÿ %ÿ ÿ" # #"&"ÿ& ! 'ÿ)622*ÿ+ÿ7898 ÿ)+30,-0+0* ‚ƒ„ …„†‡ˆ‰„… Š‹‚ŒÿŒ… Š ‹‘‚’ ‰‚“Š‰ÿŒ… ” 3445ÿ789:;<=>ÿ?@:A9B@C:A;D EFÿHIJÿKFLMÿNOPÿQFRPHFÿIJRÿSTUMLTVNÿNOPQÿMINUFJWSXÿYILLÿOJFÿOVÿOPQÿSMFHTILTSWSÿWORINX } ~ Z;@Dÿ[;>\A]=D=99 7;D9;fAg@:AD\ÿh;8>ÿZ;@D9 ij;>g@kf=ÿl@m<=D:9 ^VÿNOPÿIQFÿIÿWFIHKFQ_ÿMP`LTHÿSFQaTHFÿbOQcFQ_ÿOQÿIJ TJRTaTRPILÿbTWKÿWOWILÿIJRÿMFQUIJFJWÿRTSI`TLTWNÿNOP UINÿdPILTVNÿVOQÿWKTSÿMQOeQIUX YOJSOLTRIWTJeÿNOPQÿLOIJSÿWOÿOJFÿJFbÿLOIJÿPJRFQ OJFÿLFJRFQÿUINÿLObFQÿNOPQÿMINUFJWSÿIJRÿUIcF NOPQÿLTVFÿIÿ̀TWÿUOQFÿUIJIeFI`LFX ^VÿNOPÿIQFÿLOOcTJeÿWOÿLObFQÿNOPQÿUOJWKLN MINUFJWS_ÿWKFJÿ^JHOUFÿnISFRÿoFMINUFJW pLIJSÿUINÿ̀FÿWKFÿHOQQFHWÿHKOTHFÿVOQÿNOPX  € [;>k=@>@DC=ÿrÿs=B=><=D: x@>DA9y<=D:ÿl>=]=D:A;D ^VÿNOPÿIQFÿSWTLLÿTJÿSHKOOLÿIJRÿSWQPeeLTJeÿWOÿUIcFÿMINUFJWSÿOJÿNOPQÿSWPRFJW LOIJSXÿtOPÿUINÿdPILTVNÿVOQÿuOQ`FIQIJHFÿvÿwFVFQUFJWX uFRFQILÿLIbÿQFdPTQFSÿWKIWÿWKFÿwFMIQWUFJWÿOVÿzRPHIWTOJÿOQÿePIQIJWFFÿIeFJHN JOWT{FSÿNOPÿ̀FVOQFÿWKFNÿ̀FeTJÿeIQJTSKTJeÿNOPQÿbIeFSX && ".11/ 0' #1 ' 21/ 01345+53555230341 && .11 #!# 2"& ! &"' $.641 51Exhibit B 27 01213456 7898 9 ÿ 8 ÿ ÿ ÿ ÿ ÿ ÿ ! ÿ !ÿ"#$ #% ÿ ÿ $ &"'ÿ( ÿ ÿ %ÿ ÿ" # #"&"ÿ& ! 'ÿ)622*ÿ+ÿ7898 ÿ)+30,-0+0* ‹ xQT[ÿyQz{ZUV[VXXÿ zQ{zT}X Œ Vz}T[V[Yÿ‡ZXT…ZZYP yQz{ZUV[VXX M[ÿXQ}Vÿ~TXVXÿZ[€ZUZ€RTXÿ‚ZYS yV€VzTÿƒYR€V[YÿxQT[Xÿ}TPÿWRTZNP YQÿSTUVÿTÿ„QzYZQ[ÿQNÿYSVÿT}QR[Y Q‚V€ÿ}TPÿ…VÿNQz{ZUV[† MNÿPQRzÿ€ZXT…ZZYPÿZXÿVˆ„V~YV€ÿYQÿTXY ‰Šÿ}Q[YSXÿQzÿ}QzVÿPQRÿ}TP WRTZNPÿNQzÿ„Vz}T[V[Yÿ€ZXT…ZZYP NQz{ZUV[VXX† “ M[~Q}VÿTXV€ÿ TP}V[YX ” R…Z~ÿƒVzUZ~VÿxQT[ yQz{ZUV[VXX Žÿ„VzZQ€ÿQNÿ[T[~ZTÿSTz€XSZ„ÿ}TP WRTZNPÿPQRÿNQzÿT[ÿM[~Q}VÿTXV€ V„TP}V[Yÿ T[†ÿM[ÿ}T[Pÿ~TXVXÿYSZX }VT[XÿPQRÿ„TPÿ[QYSZ[{† MNÿPQRÿ‚Qz‘ÿNQzÿTÿ{QUVz[}V[Y Qz{T[Z’TYZQ[ÿTYÿTÿ~ZYPÿXYTYVÿQz NV€VzTÿVUVÿPQRÿ}TPÿWRTZNPÿNQzÿYSV R…Z~ÿƒVzUZ~VÿxQT[ÿyQz{ZUV[VXX „zQ{zT}† •8@Eÿ–8E78FCB@5C8E —QRÿ}TPÿ…VÿT…VÿYQÿ~Q}…Z[Vÿ}RYZ„V NV€VzTÿXYR€V[YÿQT[XÿZ[YQÿQ[Vÿ[V‚ÿQT[ ‚ZYSÿTÿQ‚Vzÿ}QzVÿT˜Qz€T…Vÿ}Q[YSP „TP}V[Y†ÿxQT[ÿ~Q[XQZ€TYZQ[ÿ„zQ{zT}X ~T[ÿSV„ÿPQRÿWRTZNPÿNQzÿT€€ZYZQ[T „zQ{zT}Xÿ Z‘Vÿ QT[ÿ NQz{ZUV[VXX „zQ{zT}Xÿ Qzÿ R…Z~ÿ ƒVzUZ~Vÿ xQT[ yQz{ZUV[VXX† ™oš›ÿœ™o 3445ÿ7894ÿ8:ÿ8;<ÿ949=4<7ÿ>?8ÿ?@A4ÿ7@A4Bÿ=CDÿ8Eÿ5?4C<ÿ75;B4E5ÿF8@EÿB4=5G H4FICEDÿJ8;ÿK@A4ÿLCD žŸ ¡¢£¤ÿ¦§ÿ̈©ª©¢«ÿ¬¦­ª®¢¦ÿ̄®°©®±²ÿ³ÿ¡´ÿ¤¡µ©¢«¤ÿ¶·¸¹ÿº®»ÿ́§¢¦ ¼½ À ¾Z¿¢ ~S¦T»®Vº»ÿ®¾T zYZ[ ¢®­» Á MNÿPQRÿSTUVÿWRVXYZQ[X \4ÿ?@A4ÿ5?4ÿ@E7>4<7 ];575@EBCEDÿK44<7aÿb@Fcÿ58ÿ8E4ÿ8:ÿ8;<ÿ75;B4E5ÿF8@Eÿ@BAC78<7ÿ58 deeefÿghijkihh mnompÿoqrsrtrqruvÿw && ".11/ 0' #1 ' 21/ 01345+53555230341 && .11 #!# 2"& ! &"' $.641 31Exhibit B 28 01213456 7898 9 ÿ 8 ÿ ÿ ÿ ÿ ÿ ÿ ! ÿ !ÿ"#$ #% ÿ ÿ $ &"'ÿ( ÿ ÿ %ÿ ÿ" # #"&"ÿ& ! 'ÿ)622*ÿ+ÿ7898 ÿ)+30,-0+0* 345467ÿ9:;5<6:ÿ=<>4<74q4>4:o 3@A@BCÿ9DEAFBDÿ=FG@FHÿJKÿLMNÿKOPNÿOQRNSÿOT LMNÿJRTOSUVLJORÿWOPPNWLNXÿORÿLMJKÿQNYKJLNZ [NÿQJPPÿROLÿKNPP\ÿKMVSNÿOSÿSNRLÿLMJK JRTOSUVLJORÿLOÿOLMNSKÿJRÿQV]KÿXJ^NSNRL TSOUÿQMVLÿJKÿXJKWPOKNXÿJRÿLMJKÿKLVLNUNRLZ _Tÿ]O`ÿMVaNÿb`NKLJORKÿSNcVSXJRcÿMOQÿ]O`S JRTOSUVLJORÿJKÿ`KNXÿORÿLMJKÿQNYKJLN dPNVKNÿWORLVWLÿ̀KÿVLÿ @BHefg@A@BChDEAFBDhijek ° rstu ° vwx ° yzs{ ° ru }ÿuzu{_y_z_~ ° €_‚w ÿ€sz_  ° ~utƒÿw„…ÿ s„…_~_s„ƒ ­ÿª¥¨£ÿÿÿ̄ÿÿÿwJXJRcÿƒL`XNRLÿNPJNTÿwPPÿJcMLKÿNKNSaNX p;=ÿ>3:<9:ÿ6<†9 ‡ÿtw{„_v_ u„~ÿuwƒs„ƒ vsÿuv_„w„ _„{ÿsˆ ƒ~ˆ…u„~ÿzsw„ƒ‰ Š‹ŒŽÿ’“ÿ”•–— rOQÿVÿ MVRcNÿOTÿ JL]ÿWVR MVRcNÿ]O`SÿzJTNÿ˜VRXÿzOVR™‰ lp6:3l:ÿ46?p Ÿ ˜¡¡¡™ÿ¢£‡¤¥‡££   JRTO¦VJXJRcKL`XNRLKZWOU ± §¥¥ÿwRLORÿyPaXÿƒ`JLNÿ̈¨LMÿvPOOS OKLVÿtNKV\ÿ wÿ©ª§ª§ š›œ›Œÿ”ž“ÿ”•–— ¬« && ".11/ 0' #1 ' 21/ 01345+53555230341 && .11 #!# 2"& ! &"' $.641 -1Exhibit B 29 EXHIBIT AIDINGSTUDENTRELIEF Something awesome is coming soon We are building something very cool. Stay tuned and be patient. Your patience will be well paid About Us We can help you reduce and. simplify your payments. Cal ore of our ape: Duals [may a Loan Forgiveness Lt Income Based Payments Garnishment Prevention you 3- a teacl' I1 -ollc 03w or an poi 3" ?nance. n'ay qualify you =eceral law requ-re that the Cepanrne Tin-nine ianen ?ere-V-rna-?t Elem ma?; Couca: one! gearaetee agency notify-you rue-,- qual?; fol 1" Dl'l?lclT cafe: [hl?S mes-'3 lie: adj'lng ll'h?y begin gut" YDUI Subscribe 31 Stay Updated Exhibit If wan-1 a: 55 are ?E?Ed'f FELT It?:1 30 Thank you hen; ?ex-f - Epghla weenie-o com EXHIBIT National Education Student & Teacher https://web.archive.org/web/20160117101622/http://www.aidnest.com/ info@aidnest.com (800) 555-1212 HOME ABOUT US SERVICES FAQ BLOG CONTACT HOME ABOUT US SERVICES FAQ BLOG CONTACT 1 of 6 4/6/2018, 9:45 AM Exhibit D 31 National Education Student & Teacher If you have Federal Student Loans, you’re in the right place to get those loans reduced, forgiven or completely discharged through our student loan forgiveness programs. 2 of 6 https://web.archive.org/web/20160117101622/http://www.aidnest.com/ Get your multiple Federal Student Loans consolidated into one, forget about increasing interests and pay month to month at the lowest possible cost. We understand if you’re going through some hardship, and that’s why with us you’ll be able to make monthly payments based on your affordability, for as low as $0.00, depending on your situation. 4/6/2018, 9:45 AM Exhibit D 32 National Education Student & Teacher https://web.archive.org/web/20160117101622/http://www.aidnest.com/ Our knowledge base is designed to provide information regarding some of the critical topics those with student loans must be aware of to be able to make educated decisions regarding their future. If you’re in default, you don’t have to worry anymore – not only can we enroll you into one of our rehabilitation programs, but also your credit score will show in good standing within 6 to 9 months. A wage garnishment is any legal procedure in which some portion of a person’s earnings is required to be withheld by an employer for the payment of a debt. 3 of 6 If you’re in default, you don’t have to worry anymore – not only can we enroll you into one of our rehabilitation programs, but also your credit score will show in good standing within 6 to 9 months. With this program your payments change as your income changes and will not be longer than 25 years. This is the ideal plan if you are in partial financial hardship. Your monthly payments will be lower and you’ll pay more for your loan over time than you would under the 10-year standard plan. Temporarily allowing you to postpone or reduce your federal student loan payments. Postponing or reducing your payments may help you avoid default and future garnishments. Your monthly payments will be lower and you’ll pay more for your loan over time than you would under the 10-year standard. 4/6/2018, 9:45 AM Exhibit D 33 National Education Student & Teacher 4 of 6 https://web.archive.org/web/20160117101622/http://www.aidnest.com/ 4/6/2018, 9:45 AM Exhibit D 34 National Education Student & Teacher 5 of 6 https://web.archive.org/web/20160117101622/http://www.aidnest.com/ 4/6/2018, 9:45 AM Exhibit D 35 National Education Student & Teacher https://web.archive.org/web/20160117101622/http://www.aidnest.com/ pay-grandchild-studen Why 2016 Will Be a Big Year For Student Loans December 30, 2015 12511110_1112367518 Top Student Loan Refinancing Questions of 2015 December 30, 2015 We stand by our consultation and quote. We are so sure and confident about our services and offers that they are all 100% money back guarantee, risk free – if we don’t do what we promise, you’ll get your money back. (800) 555-1212 AidnestStudenLoans@gmail.com 18100 Von Karman Ave Suite 850 Irvine, CA 92612 Futero S.A.S. © 2015 Aidnest.com 6 of 6 4/6/2018, 9:45 AM Exhibit D 36 EXHIBIT AIDNEST Let us help you through this national crisis Call one of our specialists today. Forbearance & Deferment If you are still in school and struggling to make payments on your student loans. You may qualify for Forbearance & Deferment. Garnishment Prevention Federal law requires that the Department of Education or guarantee agency notifies you before they begin garnishing your wages. Loan Forgiveness If you are a teacher, public service worker, or an individual with total and permanent disability you http://aidnest.com/[4/4/2018 11:52:39 AM] Exhibit E 37 AIDNEST Let us help you through this national crisis may qualify for this program. Consolidating Your Loans Consolidating your loans to one new loan under one lender may lower your payments and make your life a bit more manageable. Affordable Payments If you are looking to lower your monthly payments, then Income Based Repayment Plans may be the correct choice for you. Learn more about our services LEARN MORE http://aidnest.com/[4/4/2018 11:52:39 AM] Exhibit E 38 AIDNEST Let us help you through this national crisis Loan Forgiveness Programs Income Based Payments Student Loan Rehabilitation Student Loan Consolidation You may be eligible for Loan Forgiveness Programs In some cases, individuals with Federal Student Loans may qualify to have a portion of the amount owed to be forgiven. Get in touch with our professional team to find out which loan forgiveness program you qualify for and how you can get rid of your unpaid student loan. LEARN MORE http://aidnest.com/[4/4/2018 11:52:39 AM] Exhibit E 39 AIDNEST Let us help you through this national crisis There are no obligations or commitments. YOUR ASSESSMENT IS ABSOLUTELY FREE Meet your Budget One of our advisers will help you meet your payment goals by using your budget and timeline to determine the best plan available. http://aidnest.com/[4/4/2018 11:52:39 AM] Exhibit E 40 AIDNEST Let us help you through this national crisis Simple Process We understand that lowering your payments alone can be difficult. Our intuitive platform allows us to keep the entire process simple.  Customer Satisfaction We are committed to providing you with outstanding service only. We look forward to working with you. 100% money back guarantee No Hassle Money Back Policy http://aidnest.com/[4/4/2018 11:52:39 AM] Exhibit E 41 AIDNEST Let us help you through this national crisis Lower your loan payments by getting in touch with one of our professionals We design a customized repayment plan that will allow you to make payments based on your monthly income, family size, and spending. Get rid of the hassle of extensive paperwork and get the help you deserve. What we can help you achieve a lower payment or lower rate. http://aidnest.com/[4/4/2018 11:52:39 AM] Exhibit E 42 AIDNEST Let us help you through this national crisis How a Change of City can Change your Life We stand by our consultation and quote. We (and Loan)! are so sure and confident about our services The Argument for Tuition-Free College and offers that they are all 100% money back guarantee, risk free – if we don’t do what we promise, you’ll get your money back. CONTACT INFO FOLLOW US info@aidnest.com  855-580-NEST (6378) 18100 Von Karman Ave Suite 850, Irvine, CA 92612 1651 E. Fourth St. Santa Ana, CA 92701 © 2018 AIDNEST Let us help you through this national crisis. http://aidnest.com/[4/4/2018 11:52:39 AM] Exhibit E 43 Services AIDNEST Let us help you through this national crisis INCOME BASED PAYMENTS If you are suffering from a financial hardship, you may be eligible for an Income Based Payment. In this repayment program, you would have a payment based on your income and family size. The payment could be as low as $0.00 per month, with forgiveness at the end of 20-25 years. http://aidnest.com/services/[4/4/2018 11:53:22 AM] Exhibit E 44 Services AIDNEST Let us help you through this national crisis LEARN MORE  LOAN FORGIVENESS If you have Federal Student Loans you may qualify for any of the student loan forgiveness programs that are available to borrowers. You may be eligible for principal reduction, loan forgiveness, or a complete loan discharge depending on your individual circumstance. LEARN MORE  PRIVATE STUDENT LOAN CONSOLIDATION Much like refinancing a mortgage, generally the biggest benefit of private student loan consolidation/student loan refinancing is a lower interest rate http://aidnest.com/services/[4/4/2018 11:53:22 AM] Exhibit E 45 Services AIDNEST Let us help you through this national crisis (something federal consolidations do not offer). LEARN MORE  STUDENT LOAN REHABILITATION You can renew eligibility for new loans and grants and eliminate the loan default by “rehabilitating” a defaulted loan. http://aidnest.com/services/[4/4/2018 11:53:22 AM] Exhibit E 46 Services AIDNEST Let us help you through this national crisis CHECK ELEGIBILITY  WAGE GARNISHMENT A wage garnishment is any legal procedure in which some portion of a person’s earnings is required to be withheld by an employer for the payment of a debt. LEARN MORE  With our fast, friendly and professional services we’ll be glad to help you get your student loans reduced, forgiven or completely discharged. To this end, we’ll assist you in consolidating all your student loans, so  you’ll have only one lender and you’ll start making one monthly payment. Our professionals will walk you through the best and most flexible repayment options, and if it’s also necessary, varied deferment options and rehabilitation programs. http://aidnest.com/services/[4/4/2018 11:53:22 AM] Exhibit E 47 Services AIDNEST Let us help you through this national crisis Our CRM System Our CRM is one of the most advanced in the industry and most importantly, it’s linked directly to the Department of Education (DOE). This keeps your personal and most confidential information safe. Furthermore because our CRM system is linked to the DOE, our approval is 100%. Through our CRM we will be doing continuous monitoring of our process without losing sight of your immediate needs, ensuring that your case has the proper handling and most efficient process. http://aidnest.com/services/[4/4/2018 11:53:22 AM] Exhibit E 48 Services AIDNEST Let us help you through this national crisis RECENT POSTS ABOUT US How a Change of City can Change your Life We stand by our consultation and quote. We (and Loan)! are so sure and confident about our services The Argument for Tuition-Free College and offers that they are all 100% money back guarantee, risk free – if we don’t do what we promise, you’ll get your money back. CONTACT INFO FOLLOW US info@aidnest.com  855-580-NEST (6378) 18100 Von Karman Ave Suite 850, Irvine, CA 92612 1651 E. Fourth St. Santa Ana, CA 92701 © 2018 AIDNEST Let us help you through this national crisis. http://aidnest.com/services/[4/4/2018 11:53:22 AM] Exhibit E 49