" .Case 3:07-cv-00685-JPG-DGW Document 5 Filed 11/02/2007 Page 1 of 20

IN TH UNTED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF ILLINOIS

FEERA TRE COl\SSION

Plaintiff, .

No. 3:07-cv-00685-JPG-DGW

PRACTICAL MATIG, INC. a Florida corporation;

ROBERT M. DESALVO, individualy and as an officer and diector of the corporate defendant; and /vOv 0., VALRI DESALVO, individualy and as an

"VOl

officer and diector of the corporate defendant

Defendants.

STIPULATED ORDER FOR PERMNT INJUNCTION AN FIAL JUDGMENT

Plaintiff, the Federal Trade Commssion ("Commssion" or ' 'FC'' ), has fied a

Complaint for Permanent Injunction and Other Equitable Relief ("Complaint") pursuant to

Section 13(b) of the Federal Trade Commssion Act Act ), 15 D. 53(b), chargingFTC C.

Defendants Practical Marketing, Inc. , Robert M. DeSalvo, and Valerie DeSalvo, with engaging in

deceptive acts or practices in violation of Section 5(a) of the FTC C.Act, 15 D. 45(a), and

with assisting and facilitatig the commssion of deceptive and abusive telemarketing acts and

practices, in violation of Sections 310.3(b) and 310.4 of the Telemarketing Sales Rule ("TSR"

16 C. R. Par 310.

The Commssion and Defendants Practical Marketing, Inc. , Robert M. DeSalvo, and

Valerie DeSalvo , having been represen ed by counsel and acting by and though such counsel

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ve consented to the entr of ths Stipulated Order for Permanent Injunction and Final Judgment

Order ) in settlement of the Commssion s Complaint agaist them, without a tra! or.

adjudication of any issue oflaw or fact herem.

NOW, THREFORE, the Commssion and Defendants Practical Marketig, Inc., Robert

M. DeSalvo, and Valerie DeSalvo, having requested the C ur to enter ths Order, it is hereby.

ORDERED, ADJUGED, AN DECREED:

FININGS

1?s is an action by the COIIission initiated under SeCtion 13(b) of the TC Act

15 V. 53(b). Pusuant to ths section, the Commssion has the authority to seek the relief

contained herein.

C.

The Commssion s Complait states clai upon which relief may be granted

againt Defendants under Sections Sea), 13(b) and 19 of the FTC Act, 15 U. C. 45(a), 53(b)

and 57b, anrl the Telemarketing and Consumer Fraud and Abuse Prevention Act ("Telemarketin

Act"), 15 C. 6101-6108.

. This Cour has jursdiction over the subject matter of this case. and al pares

hereto. Venue in the Southern Distrct of llinois is proper.

The alleged activities of Defendats are in or affectig commerce, as defied in

Section 4 of the FTC Act, 15 D. 44.C.

Defendants, without admttg the allegations set fort in the Commssion

Complait, agree to entr of this Order.

Defendants waive all rights to seek judicial revie\y or oth'erwise challenge or

contest the validity of this Order. Defendants fuer waive and release any claims any of them

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Case' 3:07 cv-00685-J PG-DGW Docwment 5 Filed 11/02/2007 Page 3 of 20

may have against the Commission, its employees, representatives or agents.

Defendats agree that ths Order does not entitle them to seek or obtain attorneys

fees as a prevailing par under the Equal ctess to Justice Act, 28 2412 as amendedC.

by Pub. L 104-121 110 Stat. 847, 863-64 (1996), and Defendants fuer waive any right to .

attorneys ' fees that may arse under said provision of law.

Any vohmtary banptcy petition fied by any Defendat does not automatically

stay ths action, which the Cour fmds is the "commencement or contiuation of an action or

proceedig by a governental unt to enforce such governenta unt's police or regulatory

power " as set fort in 11 D. C. ~ 362(b)(4).

. 9. . ' Any voluntar banptcy petition filed by any Defendat does not divest ths

Cour of jursdiction to enter this Order agaist the Defendant

E:QU oftbs .Order is in the public interest.

ORDER

DEFINTIONS

For puroses ofthis Order, the following defmitions shall apply:

1 O.

1. count number" means any credit or debit card number, ban account

number, deposit account number, personal identification number (' "PIN), access code, or

securty code, needed to charge o consumer s account.debit

Assets" means any legal or equitable interest in, right to, or claim to, any real or

personal propert, including but not limited to 'chattl, goods, instrents, equipment, fixtues

genera int gibles, effects, leaseholds, mail or other deliveries, inventory, checks, notes

accounts, credits, receivab es (as those ters are defmed in the Uniform Corpercial Code), and

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all cash, wherever located.

Assisting others" means providing goods or serces .to any person .or entity

engaged in marketig or telemarketing, including, but not limted to: (a) preparg, pritig, or

transmittg invoices; (b) recordig or verifyg sales solicitations; (c) performg customer

servce fuctions, includig, but not limted to, receivig or responding to consumer complait

obtaing or receivig identifyg and fiancial inormation from consumers, and communcatig

. with consumers on behalf of the seller or telemarketer; (d) providig for or arangig for the

provision of mail or telephone lists; (e) .preparg or providig, or causing to be prepared

provided, telephone sales scripts or other materials for use in connecton with the promotion of

products or seryices to consumers; (f) providig, mailing. or shipping, or arangig for the

provision, mailing, or shipping, of fullent products ot services; (g) providig or arangig for

the provision of telemarketing services; (h) providig or faciltating the means of obtag' payment froII consumers, by providing or faciljtating access to the credit card or ban account' .

payment and collection system; (i) developing, provIdig, or aranging for the provision ofnaIes

of potential customers;. G) providig or arangig for the provision of post offce boxes or the

services of commercial receiving agencies; and (k) perfom1ing or providing marketig services

of any kid.

Consumer" mean any individual, group, uncorporated 'association, limited or

general parership, corporation, or other business entity.

Customer" means any person who has paid, or may be required to pay, for

goods or services offered for sale or sold by Defendants.

Defendant" or "Defendants" means Practical Marketing, Inc., Robert M.

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DeSalvo, and Valerie DeSalvo, and each of them, by whatever names each maybe known.

Document" is synonymous in meang and equal in scope to the usage of the

term inPederal Rule of Civil Procedure 34( a), and includes wrtings, drwings, graphs, chars

photographs, audio and video recordings, computer records, and other data compilations froD;

which inormation "ca be obtaied and 1ranslated, if necessar, though detection devices into

reasonably usable fonn. A draf or non-identical copy is a separate document with the meang

of the ter.

Fulment product or servce" means any product or servce sold or provided

or intended to be sold or provided to consumers.

9. . Seller" shall have the meang set "fort in Secti n 31O.2(z) of the Telemaretig

.sales Rile, 16 C. R. ~ 31O.2(z).

10. Telemarketing" means any plan, program, or campaign ("yhether or not covered

by the Telemaretig Sales Rule, 16 C. R. Par 310) that is conducted to induce the purchase of

goods or services or the payment of money by mean of the use of one or more telephones.

11. Telemarketer" shaH have the meang set fort in Section 31 O.2(bb) of the

Telemarketig Sales Rule, 16 C. R. 9310.2(bb).

I. PROHIITED PRACTICES

IT IS THEREFORE ORDERED that Defendants, and their offcers, agents, directors

" . servants , employees, salespersons, independent contractors , corporations , subsidiares , afliates,

successors, and assigns , and all other persons or entities in active concert or parcipation with

them who receive actual-notice of ths Order by personal service or otherwise, whether acting

directly or though anytrul?t, corporation, subsidiar, division, or other device, or any of them,

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are pennanentlyrestraied and enjoined :fom:

Collecting, selling, renting, brokerig, purchasing, trsferrg, or otlerwise

disclosing, consumers ' account numbers , or assisting others in collectig, selling, "rentig,

brokerig, purchasing, transferrg, or disclosing of consumers ' account numbeIS, in anyform,

luding but not limited to lists, computer tapes or other media, to, from, for, or with any

unaffiliated thid par for any marketig purose. Provided, however that Defendats may

disclose their own customers ' account numbeIS to others for the purose of assistin Defendants

in processing an completig a specific transaction authorized by the Customer; and .

Defendats agree to relinquish any list of consumers ' account numbers to the FTC

that is in their ossession or control and to destroy all other existig copies of the lists in their

possession or control, includig any copies maitaied in computer readale form.

II. MONITORIG REQUIMENTS

IT IS FURTHR 0 RDEREDtla:tD fe:rda:Jts andtheir"offcers;- agents direct6fs; .

servants , employees, salespersons, independent contractors, corporations , subsidiares, affliates,

successors, and assigns, and all other persons or entities in active concert or parcipation with

them who receive actual notice of ths Order by personal service or otherw , whether actig

directly or though any trst, corporation, subsidiar, division, or other device, or any of them, in

connection with collecting, selling, renting, brokerig, purchasing, transferrng, or otherwse

disclosing any inormation about consumers, are permanently restrained and enjoined ITom:

. A. Failing to take reasonable steps suffcient to monitor their clients ' advertsing and.

promotional materials and activities to determine the natue of the proc:ucts or serces being

offered, the costs, terms or conditions of sale, the representations to be made o consumers, and

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the trthflness of these representations;

Failing to promptly investigate fully any complait or refud request received by

Defendants, whether directly from consumers or from thd partes, such as goverent agencies

or Better Business Bureaus, regarding the business practices of Defendants ' clients; notify their

Clients of such complaints or refud requests; determe how the complaints or refud requests

wil be ad essed; and notifY the consumer or thd par from whom Defendans received the

complait or refud request of any action taken;

Failing to temlinate any services whatsoever to any person whom Defendats

know or should know, though the procedures described in Paragraphs A or B of ths Section, or

otherwise, has engaged or is engagig in misrepresentations or omissions of any fact materal to

any consumer s decision regardig any offered transaction bill of accounts without the

consumer s express authorization, or any act or practice prohibited by Section I of ths Order

until such per on ceases engagig in such acts or practices; and

Failig to imediately provide, by cerfied mail, all relevartinormation,

including name, address , and telephone number of any person that Defendants termate servces

, pursuant to Paragraph C of ths Section, to the Federal Trade Commission at the address

provided in Section VI of ths Order.

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ID. COMPLIANCE WITH THE TELEMARKTING SALES RULE

IT IS FURTHER ORDERED that Defendants and their officers, agents irectors,

servants, employees salespersons, independent contractors, corporations, subsidiares, aflites;

successors, and assigns, and all other persons or entities in active concert or parcipation with

them who receive actual notice of ths Order by personal service or otherwise, whether actig-"

diectly or though any trst, corporation, subsidiar, division, or other device, or any of them, .

" are pettanentlyrestrained and enjoined ftom:

Violatig or assistig others in. violating any provision of the TSR, 16 C. R. Par

310, including, but not limted to, Sections 310.3(a), 310.3(c), 3 10.3 (d), or 310.4; 16 C.

~ 31O.3(a), 310.3(c), 310.3(d), or 310.4; and

Failing to obtain and review sample scripts from any seller or telemarketer prior to

rentig or sellig any list to that seller or telemarketer in order to ensure that the r tal or sale of

any such list does not assist the seHer ortelemarketer in violatig anyprovi ion of the TSR, 16 .

ER. Par 310, including, but not limted" , Sections 31 0.3 (a), 31O.3(c), 3 10. 3" (d), or 310.4, 16

R. 99 3 10,3 (a), 3Ut3(c), 310.3(d), or 310.4.

IV. COOPERATION '''ITH FTC COUNSEL

IT IS FURTHR ORDERED that Defendants shall, in connection with ths action or

any subsequent investigations related to or associated with th transactions or the occurences

that are the subject of the FTC' s Complaint, cooperate in good faith with the FTC and appear or

cause their offcers, employees, representatives, or agents to appear at such places and ties as

the FTC shall reasonably request, after wrtten notice, for interviews, conferences , pretral

discovery, review of documents, and for such other matters as may be reasonf!bly requested by

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the FTC. If requested in wrting by the FTC, Defendants shaH appear or cause their offcers

employees , representatives , or agents to appear and provide trthl testiony in any tral

deposition, or other proceeding related to or associated with the tranactions or the occurences

that are the subject of the Complaint, without the servce of a subpoena.

V. COMPLIACE MONITORIG

IT IS FURTHR ORDERED that, for the purose of monitorig anduivestigatig

compliance with any provision of this Order:

With ten (10) days of receipt ofWrtten notice from a representative of the

Commission, Defendants Practical Marketig, Inc.; Robert M. DeSalvo, and Valerie DeSalvo

each shall submit additional written reports, sworn to or a:f1Ied under penalty .ofpeIjur

produce documents for inspection and copyig; appear for .deposition; and/or provide entr

durg normal business hours to any business location in such Defendant' s possession or diect

or indirect C01;tro!" to inspect the business operation; provided however, $at upon application of

the Commssion and for good cause shown, the Cour may enter an order grantigex parte

imediate access to such Defendant' s business premises, wherever located, for the purose of

inspecting and copyig all documents relevant to any matter contained in this Order;

In addition, the Commission is authorized to . monitor compliance with ths Order

by al other lawful means, including but not lited to the following:

Obtaing discovery from any person, without fuer leave of cour, using

the procedures prescribed by Fed. R. Civ. P. 30, 31 , 34 , and 45; and

Posing as consumers and suppliers to Practical Marketing, Inc., Robert M.

DeSalvo, or V alerie DeSa , or Practical Marketig, Inc. ' , Robert M. DeSalvo , orValerie

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Case 3:07 -cv-00685-JPG-DGW Document 5 Filed 11/02/2007 Page 10 of 20

DeSalvo s employees, or any other entity managed or controlled in whole or in par by any of

them, without the necessity of identification or prior notice; and

Defe dants Practical Marketmg, Inc., Robert M. DeSalvo, ane! Valerie DeSalvo

shall pennit representatives of the Commission to interview any employer, consultant

independent contractor, representative, agent, or employee who has agreed to such an interview,

relatig in any way to any conduct subject to ths Order. The person interviewed may have

. counsel present.

Provided however, that nothg in ths Order shall limit the Commssion s lawfl use of

compulsory process, pursuant to Sections 9 and 20 of the FTC Act, 15 C. 9949 and 5Th­

to obtain any ocumentar material, tangible things, test ony, or inormaton relevant to unir

. or deceptive acts or practices in or affecting commerce(with the meang of 15

~ 45(a)(1)).

VI. COMPLIACE REPORTING BY DEFENDAN

IT IS FURTHR ORDERED that, in order that compliance with the provisions of ths

Order may be onitor

For a period of five (5) years from the date of entr ofthis Qrder

Defendants Robert M. DeSalvo and Valerie DeSalvo each shall noti the

Commission of the following:

Any changes in residence, mailing addresses, or telephone numbers

of such Defen(iant, withi ten (10) days of the date of such change;

Any changes in the employment statu (includig self-employment)

of such Defendant, and any change in the ownership interest of such Defendant in any business

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entity, with ten (10) days of the date of such change. Such notice shall include the name and

address o each business that such Defendant is affliated with, employed by, creates or forms

performs services for; a statement of the natue of the business; and a statement of such

Defendant' s duties and responsibilities in connection with the busiTess or employment; and

. c. Any changes in such Defendant' s name or use of any aliases or

fictitious n es; and

Defendats Practical Mareting, Inc. , Robert M. DeSalvo, and Vat rie

DeSalvo shall notif the Commssion of any changes in any Defendant or any business entity that

Robert M. DeSalvo or Valerie DeSalvo diectly or indiectly control(s), or has an ownership

interest in, that may affect compliance obligations ansing under ths Order, includig but not

limted to a dissolution, assignent, sale, merger, or other action that would reslt in the

emergence of a successor entity; the creation or dissolution of a subsidiary, parent, or afate that

engages in any acts or practices subject to ths Order; the filing of a banptcy peti on; or a

change in the corporate name or address, at least th (30) days prior to such change provided

that, with respect to any proposed change in the corporation about which a Defendant lears less

than th (30) days prior to the date such action is to take place, the Defendant shall notify the

Commission. as. soon as is practicable after obtaing such knowledge.

One hundred eigh (180) days after the date of entr of this Order, Defendants

Practical Marketig, Inc. , Robert M. DeSalvo, and Valerie DeSalvo each shal provide a written

report to the Commission, sworn to under penalty of perur, settg fort in detail the maner and

form in which they have complied and are complyig with ths Order. This report shall include

but not be limted to:

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For Defendants Robert M. DeSalvo and Valerie DeSalvo:

The then-cuuent residence: address, mailing addresses and

telephone numbers of.such Defendant;

The then-cuuent employment and business addresses and telephone

numbers of such Defendant, a description of the business activities of each such employer or

business, and the title and responsibilities of such Defendant, for each such employer or business;

and

Any other. changes required to be reported under Paragaph of ths

Section. .

For all Defendants:

A copy of each acknowledgment of receipt of ths Order, obtained

pursuant to Paragraph nof Section ViI; and

Any other changes required to be reported under Paragaph A of ths

Section.

For the puroses of ths Order, Defendants shall, uness otherwise diected by the

Commssion s authoried representatives, mail all wrtten notifications to the Commssion to:

Associate Director for Enforcement Federal Trade Commssion 601 New Jersey Avenue N. Washigton, D.C. 20580

Practical Marketing, Inc. , et al.Civil Action No. ; and

For puroses of the compliance reporting and monitorig requied by this Order

the Commission is authorized to communicate directly with Defendants.

Re: FTC v.

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VII. RECORD KEEPING PROVISIONS

, IS FURTHR ORDERED that, for a period of eight (8) years from the date of entr

of ths Order, for any business where (1) a efendant is the majority owner of the business or

directly or indirectly manages or controls the business, and where (2) the business is engaged in

or assists others engaged in, telemareting) or the sale of leads or consumer lists, Defendats, and

their agent , employees, offcers, corporations, successors, and assigns, and those persons in .

active concert or paricipation with them who receive actual notice of ths Ord r by personal

service or otherwise, are hereby restraied and enjoined from failig to create and retai the

following records:

. A. - : Accounting-records t1at reflect the cost of goods or services sold, revenues

generated, and the disbursement of such revenues;

Personnel records accurately reflecting: the name, address d telephone number

of each person employed in any capacity by such business, includig as an .independent

contractor; that person s job title or position; the date upon which the person commenced work;

. and the date and reason for the person s termination, if applicable;

. Customer files contaiing the names, addresses, phone numbers, dollar amounts

paid, quantity of items or services purchased, and description of items or servces purchased, to

the extent such inonnation is obtained in the ordin course of business;

Complaints and refud requests (whether received directly, indiectly or though

any thd par) and any responses to those complaints or requests;

Copies of all sales scripts, traiing materials,. advertisements, or other marketing

materials; and

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All records and documents necessar to demonstrate ful compliance with each

provision of this Order, including but not limited to, copies of acknowledgments ofr.ceipt of ths

Order, reqllired by Paragraph Dof SectionVIll, and all reports submitted to the FTC pursuat to

Section VI.

VIII. DISTRIUTION OF ORDER y DEFENDANS

IT IS FURTHER ORDERED that, for a period offive (5) years from the date of entr of

ths Order, Defendants shall deliver copies of the Order as diected below:

. A. Defendant Practical Marketing, Inc. : Defendat Practical Maretig, Inc. must.

deliver a copy of ths Order to all of its pricipals, offcers, diectors, and managers. Practical

Marketig, Inc.. also must deliver copies of ths Order to ll of its employees, agents, and

representatives who engage in conduct related to the subject matter of the Order. For curent

. personnel, delivery shallbe with five (5) days of servce of ths Order upon Defendat. . For new

personnel, de ivery shall occu prior to them assuing their responsibilities.

Defendant Robert M. DeSalvo or Valerie DeSalvo as Control Person: For any

business that Defendant Robert M. DeSalvo or Valerie DeSalvo controls, dlec:tly or indirectly, or

in which such Defendant has a maj ority ownership interest, such Defendant.must deliver a copy of .

ths Order to all principals, officers, directors, and managers of that business. Defendat Robert

M. DeSalvo or Valerie DeSalvo must also deliver copies of this Order to all employees, agents,

and representatives of that business who engage in conduct related to the subject matter of the

Order. For CUIent personnel, delivery shall be withn five (5) days of servce of this Order upon

Defendat. For new personnel, delivery shall occur prior to them assuming their responsibilities.

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Defendant Robert M. DeSalvo or Valerie DeSalvo as Employee or Non-

Control Person: For any business where Defendant Robert M. DeSalvo or Valerie DeSalvo is

not a controlling person of a business but otherwise engages in conduct related to the subject

matter of this Order, such Defendant must deliver a copy of ths Order to all pricipals and

managers of such business before engagig in such conduct.

Defendants Practical Marketig, Inc., Robert M. DeSalvo, and Valerle DeSalvo

must secure a signed and dated statement acknowledgig receipt of this Order with th (30)

days of delivery, from all persons receiving a copy of the Order pursuant to ths Section.

. IX ACKNOWLEDGMENT OF RECEIPT OF ORDER BY DEFENDANT

. IT IS FURTHR ORDERED that each Defendant, with five (5) business days of

receipt of ths Order as entered by the Cour, must submit to the Commission a trthl sworn

stateme , in the form shown on Attachment A to this Order, acknowledgig receipt of

Order.

X. SEVERAILITY

IT IS FURTHR ORDERED that the provisions of this Order are separate and severable

from one another. If any provision is stayed or determed to be invalid, the remaing provisions

shall remain in full force and effect. .

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XI. RETENTION OF JUSDICTION

IT IS FURTHER ORDERED that this Court shall retain jursdiction of ths matter for

puroses of constrction, modification, and enforcement of ths Order.

JUGMENT IS THEREFORE ENTERED in favor of the Plaintiff and againt the

Defendants, pursuant to all the terms and conditions recited above.

. IT IS SO ORDERED.

Dated:

United

SO STIPULATED:

J ep+. :21 ) 2-D/)1Dated:

Guy G. War . Federal Trade Commssion 55 W. Monroe St., Suite 1825 Chicago IL 60603 (312) '960 5634 Fax: (312) 960-5600

. A . eyifor deral Trade Commission

Dated: Steven R. Burk 211 E. Rich Avenue DeLand, Florida 32724 (386) 738-9320 Fax: (386)738-9319

. Attorney for Defendants

Dated: Robert M. DeSalvo, as an officer and diector of Practical Marketing, Inc.

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XI. RETENTION OF JUSDICTION

IT IS FURTHER ORDERED that this Cour shall retain jursdiction of ths matter for

puroses of constrction, modification, and eriorcement of ths Order.

JUGMENT IS THEREFORE ENTERED in favor of the Plaintiff and against the .

efendants, pursuant to all the terms and conditions recited above.

IT IS SO ORDERED.

Dated: ' 2007 United S tes District Judge

SO STIPULATED:

Dated: GuyG. Ward Federal Trade Commssion. 55 W..Monroe St., Suite 1825 Chicago, IL 60603 . (312) '.960-5634 Fax:. (312) 960-5600 Attorney for Federal Trade Commssion

Dated: Steven R.. Burk 211 E. RichAvenue DeLand, Florida 32724 (386) 738-9320 Fax: (386) 738-9319

. Attorney for Defendants r".I. I f

i 1.,. d.rCJ7 JL; Dated: b II

Rob M. DeSalvo, as an offcer and director of Practical Marketing, In .

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t. Gase. 3:07-cv-00685-JPG-DGW Document 5 Filed 1 t/02/2007 Page t8 of 20

Dated: 1;94 7

Dated: 0t

Dated: &

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ATTACHMNT A

IN THE UNTED STATES DISTRICT C01,RT FOR THE SOUTHERN DISTRICT OF ILLINOIS

FEDERA TRAE COMMISSION

Plaintiff

Civil Action No.

PRACTICAL MATING, INC. a Florida corporation;

ROBERT M. DESALVO, individualy and as an offcer and diector of the corporate defendat; and )

. VALERI DESALVO, individually and as an offcer and dirctor of the corporate defendant,

Defendats.

AFFIDAVIT OF DEFENDANT ATTESTING TO RECEIPT OF STIPULA TED ORDER FOR PERMENT INJUCTION AN FIAL JUGMENT

, being duly swom, hereby states and affs follows:

My name is . My curent residence addrss is

. I am a citizen of

(state/province and countr), and am over the age of

eighteen. I have personal knowledge of the facts set fort in this Affidavit.

I am a Defendant in FTC v. Practical Marketing, Inc., et aI. Case No.

Cour for the Southern Distrct of Ilinois).(United States Distrct

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Case ' 3:07 -cv-00685-JPG-DGW Document 5 Filed 11/02/2007 Page 20 of 20.r.:

2007, I received a copy ofthe Stipulated Order for

Permanent Injunction and Final Judgent ("Order ), signed by the Honorable

, and entered by the Cour on 2007. A tre

and c.orrect copy of the Order that I received is appended to ths Afdavit

I declare under penalty of perjur under the laws of the United States that the foregoing is

tre and correct. Executed on (date),

(city and state/province).

(Signature of Defendant)

(Print Fu?l Name)

StateIProvince of City of

Subscribed and sworn to before me .

ths day of 200

Notar Public

. My Commission Expires:

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