Federal Trade Commission v. Intercontinental Solutions LLC et al
| Federal Trade Commission |
| Marco Manzi, Ivan Esquivel, Intercontinental Solutions LLC also doing business as Apex Doc Processing LLC doing business as Apex Doc Processing, Express Enrollment LLC also doing business as SLFD Processing, Marco Manzi Pumar, Ivan Alexander and Robert Kissinger |
| Thomas W. McNamara |
| 8:2023cv01495 |
| August 14, 2023 |
| US District Court for the Central District of California |
| Stanley Blumenfeld |
| John D Early |
| Other Statutory Actions |
| 15 U.S.C. § 0053 Federal Trade Commission Act |
| None |
Docket Report
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Filing 37
(IN CHAMBERS) ORDER Continuing Hearing by Judge Stanley Blumenfeld, Jr.: The Court has reviewed the status report at Dkt. No. #36 . The Court continues the in-person status conference from October 13, 2023, to November 3, 2023, at 8:30 a.m. in Courtroom 6C. The parties shall file an updated status report by October 27, 2023.THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY. (jgr) TEXT ONLY ENTRY
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| Filing 36 STATUS REPORT Regarding Resolution of this Matter filed by Plaintiff Federal Trade Commission. (Mosley, Carlton) |
| Filing 35 Notice of Appearance or Withdrawal of Counsel: for attorney Cornelia Julianna Boleyn Gordon counsel for Receiver Thomas W. McNamara. Cornelia J. B. Gordon is no longer counsel of record for the aforementioned party in this case for the reason indicated in the G-123 Notice. Filed by Receiver Thomas W. McNamara. (Gordon, Cornelia) |
| Filing 34 STIPULATED PRELIMINARY INJUNCTION by Judge Stanley Blumenfeld, Jr. re Stipulation #32 . Bond in the sum of $25,000 previously filed by the Receiver with the Clerk of this Court shall remain in effect. See document for further details. (gk) |
| Filing 33 MINUTES OF Order to Show Cause Hearing held before Judge Stanley Blumenfeld, Jr.: The Court heard from the parties on the stipulated preliminary injunction #31 . The parties are ordered to meet and confer and file a revised proposed stipulated preliminary injunction by no later than 8/29/2023 4:00 PM. The Court sets this matter for an in-person Status Conference on 10/13/2023 08:30 AM before Judge Stanley Blumenfeld Jr. A joint report providing the Court with status of the resolution of this matter shall be filed no later than 10/6/2023 9:00 AM. Court Reporter: Amy Diaz. (gk) |
| Filing 32 STIPULATION for Order Order to Enter Preliminary Injunction filed by Plaintiff Federal Trade Commission. (Attachments: #1 Proposed Order Proposed Stipulated Preliminary Injunction)(Mosley, Carlton) |
| Filing 31 Joint NOTICE OF MOTION AND MOTION for Preliminary Injunction STIPULATION TO ENTER PRELIMINARY INJUNCTION filed by Plaintiff Federal Trade Commission. (Attachments: #1 Proposed Order) (Ashe, Gregory) |
| Filing 30 NOTICE TO FILER OF DEFICIENCIES in Electronically Filed Document RE: Notice of Appearance,, #27 . The following error(s) was/were found: Incorrect event selected. Correct event to be used is: Notice of Appearance or Withdrawal of Counsel G123.. In response to this notice, the Court may: (1) order an amended or correct document to be filed; (2) order the document stricken; or (3) take other action as the Court deems appropriate. You need not take any action in response to this notice unless and until the Court directs you to do so. (ak) |
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Filing 29
(IN CHAMBERS) Order Granting Receiver's Application for Leave to Appear Remotely via Zoom #28 by Judge Stanley Blumenfeld, Jr.: Thomas W. McNamara's request to appear remotely at the hearing on the preliminary injunction is GRANTED. Mr. McNamara is permitted to appear by Zoom. Instructions for remote appearance can be found on Judge Blumenfeld's webpage. (jgr) TEXT ONLY ENTRY. NO PDF ASSOCIATED WITH THIS ENTRY.
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| Filing 28 APPLICATION to Appear Remotely Via Zoom at Hearing on Preliminary Injunction set for August 29, 2023 filed by Receiver Thomas W. McNamara. (Attachments: #1 Proposed Order) (Greene, Andrew) |
| Filing 27 NOTICE of Appearance filed by attorney Brent R Phillips on behalf of Defendants Ivan Esquivel, Express Enrollment LLC, Intercontinental Solutions LLC, Robert Kissinger, Marco Manzi (Attorney Brent R Phillips added to party Ivan Esquivel(pty:dft), Attorney Brent R Phillips added to party Express Enrollment LLC(pty:dft), Attorney Brent R Phillips added to party Intercontinental Solutions LLC(pty:dft), Attorney Brent R Phillips added to party Robert Kissinger(pty:dft), Attorney Brent R Phillips added to party Marco Manzi(pty:dft))(Phillips, Brent) |
| Filing 25 Notice of Filing Preliminary Report of Temporary Receiver filed by Receiver Thomas W. McNamara. (Attachments: #1 Exhibit A-A.Preliminary Report of Temporary Receiver, #2 Exhibit Index, #3 Exhibit 1-4th St. Site Schematics & Property Inventory, #4 Exhibit 2-4th St. Sales Script, #5 Exhibit 3-4th St. Checklists & Tiers, #6 Exhibit 4-4th St. Spiffs, #7 Exhibit 5-4th St. Ending Call Script, #8 Exhibit 6-4th St. FAQ & Rebuttals, #9 Exhibit 7-4th St. Recert Script, #10 Exhibit 8-4th St. Welcome-Verification Script, #11 Exhibit 9-T&C Site Schematics & Property Inventory, #12 Exhibit 10-Email re Board, #13 Exhibit 11-Email re NMI Settlement Report, #14 Exhibit 12-Email re Attempted Cancellation by Client, #15 Exhibit 13-T&C Compliance & Verification Script, #16 Exhibit 14-T&C Commission Tiers, #17 Exhibit 15-T&C Spiffs, #18 Exhibit 16-T&C Sales Script, #19 Exhibit 17-Account Records Review, #20 Exhibit 18-Email re Client Complaint, #21 Exhibit 19-Email re Client Complaints, #22 Exhibit 20-Email re Client Complaint, #23 Exhibit 21-Email re FTC v. American Fin'l Support Srvs., #24 Exhibit 22-Screenshot of Whatsapp Messages, #25 Exhibit 23-Manzi California SOS Filings, #26 Exhibit 24-Kissinger California SOS Filings, #27 Exhibit 25-Corporate Organization, #28 Exhibit 26-Esquivel Corporate Filings)(Gordon, Cornelia) |
| Filing 24 Receiver's BOND in the amount of $ 25,000 posted by Receiver Thomas W. McNamara (Attachments: #1 Exhibit A - Receiver's Bond) (Greene, Andrew) |
| Filing 23 Notice of Appearance or Withdrawal of Counsel: for attorney Logan Daniel Smith counsel for Receiver Thomas W. McNamara. Adding Logan D. Smith as counsel of record for Thomas W. McNamara for the reason indicated in the G-123 Notice. Filed by Receiver Thomas W. McNamara. (Attorney Logan Daniel Smith added to party Thomas W. McNamara(pty:rc))(Smith, Logan) |
| Filing 22 Notice of Appearance or Withdrawal of Counsel: for attorney Cornelia Julianna Boleyn Gordon counsel for Receiver Thomas W. McNamara. Adding Cornelia J. B. Gordon as counsel of record for Thomas W. McNamara for the reason indicated in the G-123 Notice. Filed by Receiver Thomas W. McNamara. (Attorney Cornelia Julianna Boleyn Gordon added to party Thomas W. McNamara(pty:rc))(Gordon, Cornelia) |
| Filing 21 Notice of Appearance or Withdrawal of Counsel: for attorney Andrew M Greene counsel for Receiver Thomas W. McNamara. Adding Andrew M. Greene as counsel of record for Thomas W. McNamara for the reason indicated in the G-123 Notice. Filed by Receiver Thomas W. McNamara. (Attorney Andrew M Greene added to party Thomas W. McNamara(pty:rc))(Greene, Andrew) |
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Filing 17
ORDER by Judge Stanley Blumenfeld, Jr. granting #6 Non-Resident Attorney Carlton B Mosley APPLICATION to Appear Pro Hac Vice on behalf of Plaintiff Federal Trade Commission, designating Jeffrey Tang as local counsel. (bm)
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Filing 16
ORDER by Judge Stanley Blumenfeld, Jr. granting #7 Non-Resident Attorney Gregory A Ashe APPLICATION to Appear Pro Hac Vice on behalf of Plaintiff Federal Trade Commission, designating Jeffrey Tang as local counsel. (bm) Modified on 8/17/2023 (bm).
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| Filing 20 EX PARTE TEMPORARY RESTRAINING ORDER WITH ASSET FREEZE, APPOINTMENT OF TEMPORARY RECEIVER, AND OTHER EQUITABLE RELIEF, AND ORDER TO SHOW CAUSE WHY A PRELIMINARY INJUNCTION SHOULD NOT ISSUE (bm) Modified on 8/22/2023 (jgr). |
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Filing 19
ORDER GRANTING FTC'S EX PARTE APPLICATION TO EXCEED WORD LIMIT (bm) Modified on 8/22/2023 (jgr).
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Filing 18
ORDER TEMPORARILY SEALING CASE FILE (bm) Modified on 8/22/2023 (jgr).
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Filing 26
CIVIL STANDING ORDER upon filing of the complaint by Judge Stanley Blumenfeld, Jr. (jgr)
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| Filing 15 Notice to Counsel Re Consent to Proceed Before a United States Magistrate Judge. (car) |
| Filing 14 NOTICE TO PARTIES OF COURT-DIRECTED ADR PROGRAM filed. (car) |
| Filing 13 NOTICE OF ASSIGNMENT to District Judge Stanley Blumenfeld, Jr and Magistrate Judge John D. Early. (car) |
| Filing 12 FTC'S RECOMMENDATION FOR A RECEIVER filed by Plaintiff Federal Trade Commission re: Ex Parte Application for Temporary Restraining Order #3 (car) |
| Filing 11 FTC'S EXHIBITS IN SUPPORT OF ITS EX PARTE APPLICATION FOR TEMPORARY RESTRAINING ORDER AND ORDER TO SHOW CAUSE WHY A PRELIMINARY INJUNCTION SHOULD NOT ISSUE #3 VOLUME 3 filed by Plaintiff Federal Trade Commission. (Attachments: #1 Part 2 of Document, #2 Part 3 of Document)(car) Modified on 8/14/2023 (car). |
| Filing 10 FTC'S EXHIBITS IN SUPPORT OF ITS EX PARTE APPLICATION FOR TEMPORARY RESTRAINING ORDER AND ORDER TO SHOW CAUSE WHY A PRELIMINARY INJUNCTION SHOULD NOT ISSUE, #3 VOLUME 2 filed by Plaintiff Federal Trade Commission. (Attachments: #1 Part 2 of Document, #2 Part 3 of Document, #3 Part 4 of Document)(car) Modified on 8/14/2023 (car). |
| Filing 9 FTC'S EXHIBITS IN SUPPORT OF ITS EX PARTE APPLICATION FOR TEMPORARY RESTRAINING ORDER AND ORDER TO SHOW CAUSE WHY A PRELIMINARY INJUNCTION SHOULD NOT ISSUE, #3 VOLUME 1 filed by Plaintiff Federal Trade Commission. (Attachments: #1 Part 2 of Document, #2 Part 3 of Document, #3 Part 4 of Document)(car) Modified on 8/14/2023 (car). |
| Filing 8 FTC'S EX PARTE APPLICATION TO EXCEED WORD LIMIT AND MEMORANDUM IN SUPPORT THEREOF, filed by Plaintiff Federal Trade Commission. (Attachments: #1 Lodged Proposed Order) (car) |
| Filing 7 APPLICATION of Non-Resident Attorney Gregory A. Ashe to Appear Pro Hac Vice on behalf of Plaintiff Federal Trade Commission (Pro Hac Vice Fee - Not Required for U.S. Government Attorney) filed by Plaintiff Federal Trade Commission. (Attachments: #1 Lodged Proposed Order) (car) |
| Filing 6 APPLICATION OF CARLTON B. MOSLEY TO APPEAR IN THIS ACTION PRO HAC VICE; DECLARATION OF CARLTON B. MOSLEY IN SUPPORT (Pro Hac Vice Fee - Not Required for U.S. Government Attorney) filed by Plaintiff Federal Trade Commission. (Attachments: #1 Lodged Proposed Order) (car) |
| Filing 5 RULE 65 CERTIFICATION AND DECLARATION OF FTC COUNSEL CARLTON MOSLEY IN SUPPORT OF THE FTC'S EX PARTE APPLICATION FOR TEMPORARY RESTRAINING ORDER #3 , EX PARTEAPPLICATION TO TEMPORARILY SEAL CASE FILE #2 , AND ORDER WAIVING EX PARTE NOTICE REQUIREMENT filed by Plaintiff Federal Trade Commission, #3 filed by Plaintiff Federal Trade Commission. (car) |
| Filing 4 MEMORANDUM IN SUPPORT OF THE FTC'S APPLICATION FOR A TEMPORARY RESTRAINING ORDER AND AN ORDER TO SHOW CAUSE WHY A PRELIMINARY INJUNCTION SHOULD NOT ISSUE, #3 filed by Plaintiff Federal Trade Commission. (car) |
| Filing 3 FTC'S EX PARTE APPLICATION FOR (1) TEMPORARY RESTRAINING ORDER AND ORDER TO SHOW CAUSE WHY A PRELIMINARY INJUNCTION SHOULD NOT ISSUE, AND (2) ORDER WAIVING NOTICE REQUIREMENT (Attachments: #1 Lodged Proposed Order) filed by Plaintiff Federal Trade Commission. (car) |
| Filing 2 FTC'S EX PARTE APPLICATION FOR LEAVE TO FILE CASE UNDER TEMPORARY SEAL AND MEMORANDUM IN SUPPORT THEREOF (Attachments: #1 Lodged Proposed Order), filed by Plaintiff Federal Trade Commission. (car) |
| Filing 1 COMPLAINT against Defendants. Case assigned to Judge Stanley Blumenfeld, Jr for all further proceedings. Discovery referred to Magistrate Judge John D. Early., filed by Plaintiff Federal Trade Commission. (Attachments: #1 Civil Cover Sheet) (car) |
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