LINDA M. STOCK (Bar No. 143774)
RUSSELL S. DEITCH (Bar No. 138713)
Federal Trade Commission
10877 Wilshire Blvd., Suite 700
Los Angeles, CA 90024
(310) 824-4343, 824-4316, 824-4317
Fax:(310) 824-4380
Attorneys for Plaintiff
FEDERAL TRADE COMMISSION

UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
WESTERN DIVISION

FEDERAL TRADE COMMISSION,

Plaintiff,

v.

INETINTL.COM, INC., a California corporation, a.k.a. Inet International; CRAIG A. LAWSON, a.k.a. Bob Bryan, individually and as an owner, officer, or manager of INETINTL.COM, INC.; ERIK R. ARNESEN, individually and as an owner, officer, or manager of INETINTL.COM, INC.; and STANLEY R. GOLDBERG, a.k.a. Geoff Stevens, individually and as an owner, officer, or manager of INETINTL.COM, INC.;

Defendants.

Civ. No.

(Proposed)

ORDER FOR PRELIMINARY INJUNCTION WITH ASSET  FREEZE AND APPOINTMENT OF PERMANENT RECEIVER

This matter comes before the Court on Plaintiff Federal Trade Commission's Complaint for an injunction and other equitable relief, and its ex parte Application pursuant to Fed. R. Civ. P. 65(b) for a Temporary Restraining Order ("TRO") with Asset Freeze, Order Appointing a Temporary Receiver, and Order to Show Cause Why a Preliminary Injunction Should Not Issue and Why a Permanent Receiver Should Not Be Appointed. The TRO with Asset Freeze and Order to Show Cause having been granted ex parte and served with the Complaint and summons on all Defendants, and the Court having considered all pleadings, memoranda, declarations, and other exhibits filed with respect to said Application, and having heard oral argument and now being fully advised in the premises, finds:

  1. This Court has jurisdiction of the subject matter of this case, and there is good cause to believe it will have jurisdiction over all parties.
  2. There is good cause to believe that Defendants Inetintl.Com, Inc., also known as Inet International; Craig A. Lawson, also known as Bob Bryan; Erik R. Arnesen; and Stanley R. Goldberg, also known as Geoff Stevens, have engaged in and are likely to engage in acts and practices that violate Section 5(a) of the FTC Act, 15 U.S.C. 45(a), and that Defendants Inetintl.Com, Inc., also known as Inet International; Craig A. Lawson, also known as Bob Bryan; and Erik R. Arnesen have engaged in and are likely to engage in acts and practices that violate the Franchise Rule, 16 C.F.R. Part 436. Plaintiff Commission therefore is likely to prevail on the merits of this action.
  3. There is a substantial likelihood that, absent the continuation of the asset freeze, applicable to all Defendants, Defendants will conceal, dissipate or otherwise divert their assets, thereby defeating the possibility of effective final relief in the form of equitable monetary relief for consumers.
  4. Good cause exists for the appointment of a Permanent Receiver.
  5. Weighing the equities and considering the Commission's likelihood of success in its causes of action, this Preliminary Injunction is in the public interest.
  6. No security is required of any agency of the United States for issuance of a restraining order. Fed. R. Civ. P. 65(c).

ORDER

Definitions

A. "Assets" means any legal or equitable interest in, right to, or claim to, any real and personal property, including but not limited to chattel, goods, instruments, equipment, fixtures, general intangibles, effects, leaseholds, premises, mail or other deliveries, shares of stock, lists of consumer names, inventory, checks, notes, accounts, credits, receivables, and all cash, wherever located.

B. "Document" is synonymous in meaning and equal in scope to the usage of the term in Federal Rule of Civil Procedure 34(a), and includes writings, drawings, graphs, charts, photographs, audio and video recordings, computer records, and other data compilations from which information can be obtained and translated, if necessary, into reasonably usable form through detection devices. A draft or non-identical copy is a separate document within the meaning of the term.

C. "Named Defendants" means Inetintl.Com, Inc., also known as Inet International: Craig A. Lawson, also known as Bob Bryan; Erik R. Arnesen; and Stanley R. Goldberg, also known as Geoff Stevens, and each of them.

D. "Defendants" means the Named Defendants and their officers, agents, servants, employees, attorneys, affiliates or subsidiaries, successors or assigns, and all persons or entities directly or indirectly under their control or under common control with them, and all other persons or entities in active concert or participation with them, who receive actual notice of this Order by personal service or otherwise.

E. "Receivership Defendants" means Craig A. Lawson, also known as Bob Bryan; Inetintl.Com, Inc., also known as Inet International, any affiliates or subsidiaries, successors or assigns, and any corporation, partnership, or other entity directly or indirectly owned, managed, or controlled by, or under common control with, any of the Named Defendants, including but not limited to Arnesen Creative Services, Inet Strategies, and Whit Consultants.

F. "Investment Opportunity" means anything, tangible or intangible, that is offered, offered for sale, sold, or traded based wholly or in part on representations, either express or implied, about past, present, or future income, profit, residuals, or appreciation.

G. "Franchise" means any commercial relationship as defined in the Franchise Rule, 16 C.F.R. Part 436.2 (a), attached hereto as Attachment A.

H. "Business Venture" means any written or oral business arrangement, however denominated, which consists of the payment of any consideration for: (a) the right or means to offer, sell, or distribute goods or services (whether or not identified by a trademark, service mark, trade name, advertising, or other commercial symbol); and (b) assistance to any person or entity in connection with or incident to the establishment, maintenance, or operation of a new business or the entry by an existing business into a new line or type of business.

I. PROHIBITED BUSINESS ACTIVITIES

IT IS THEREFORE ORDERED that Defendants are hereby restrained and enjoined from:

A. Falsely representing, or assisting others in falsely representing, expressly or by implication, orally or in writing, that the purchasers of their franchises or business ventures can reasonably expect to achieve specific levels of earnings;

B. Falsely representing, or assisting others in falsely representing, expressly or by implication, orally or in writing, that company-selected references have purchased the Defendants’ franchises or business ventures;

C. Falsely representing, or assisting others in falsely representing, expressly or by implication, orally or in writing, the experiences of company-selected references with Defendants’ franchises or business ventures;

D. Falsely representing, or assisting others in falsely representing, expressly or by implication, orally or in writing, any other fact material to a consumer's decision to purchase a franchise, business venture, or any investment opportunity; and

E. Violating or assisting others in violating any provision of the Franchise Rule, 16 C.F.R. Part 436, including but not limited to failing to provide franchisees with accurate and complete disclosure documents and failing to give prospective franchisees the earnings claim document required by the Rule.

II. ASSET FREEZE

IT IS FURTHER ORDERED that Defendants are hereby restrained and enjoined from:

A. Transferring, converting, encumbering, selling, concealing, dissipating, disbursing, assigning, spending, withdrawing, perfecting a security interest in, or otherwise disposing of any funds, real or personal property, accounts, contracts, shares of stock or other assets, wherever located, inside or outside the United States of America, that are (a) owned or controlled by Inetintl.Com, Inc., also known as Inet International; Craig A. Lawson, also known as Bob Bryan; Erik R. Arnesen; Stanley R. Goldberg, also known as Geoff Stevens; Arnesen Creative Services; Inet Strategies; Whit Consultants; or their affiliates or subsidiaries, successors or assigns, in whole or in part; or (b) in the actual or constructive possession of Inetintl.Com, Inc., also known as Inet International; Craig A. Lawson, also known as Bob Bryan; Erik R. Arnesen; Stanley R. Goldberg, also known as Geoff Stevens; Arnesen Creative Services; Inet Strategies; Whit Consultants; or their affiliates or subsidiaries, successors or assigns; or (c) owned, controlled by, or in the actual or constructive possession of any corporation, partnership, or other entity directly or indirectly owned, managed, or controlled by, or under common control with, Inetintl.Com, Inc., also known as Inet International; Craig A. Lawson, also known as Bob Bryan; Erik R. Arnesen; Stanley R. Goldberg, also known as Geoff Stevens; Arnesen Creative Services; Inet Strategies; or Whit Consultants; or their affiliates or subsidiaries, successors or assigns, including but not limited to any assets held for or by any of the Named Defendants or subject to access by any Named Defendant or their affiliates or subsidiaries, successors or assigns, at any bank or savings and loan institution (including without limitation assets at Bank of America, 9001 Lincoln Blvd., Los Angeles, California, or any other Bank of America branch, Account Numbers 21623 04915, 21620 04884, 21628 04786, and 21628 05054, or any other account number; and assets at California Federal Bank, 5700 So. Sepulveda, Culver City, California, or any other California Federal Bank Branch), or with any broker, dealer, escrow agent, title company, commodity trading company, precious metal dealer, or other financial institution or depository of any kind;

B. Opening or causing to be opened any safe deposit boxes titled in the name of Inetintl.Com, Inc., also known as Inet International; Craig A. Lawson, also known as Bob Bryan; Erik R. Arnesen; Stanley R. Goldberg, also known as Geoff Stevens any affiliates or subsidiaries, successors or assigns, including but not limited to Arnesen Creative Services; Inet Strategies; Whit Consultants; or subject to access by any of them; and

C. Incurring charges or cash advances on any credit card issued in the name, singly or jointly, of any Named Defendant or Receivership Defendant;

Provided, however, that the Asset Freeze provisions of this Paragraph shall not apply to employment income earned after the date this Order is entered, where said employment is not in violation of the Prohibited Business Activities set forth in Paragraph I of this Order.

D. Notwithstanding the provisions of this Paragraph, Defendants may make transfers as directed by any Permanent Receiver appointed by this Court, or as otherwise ordered by this Court upon proper showing and after notice to the Plaintiff Commission.

III. REPATRIATION OF ASSETS AND DOCUMENTS
LOCATED IN FOREIGN COUNTRIES

IT IS FURTHER ORDERED that Defendants shall:

A. Within three (3) business days following the service of this Order, take such steps as are necessary to transfer to the territory of the United States of America all documents and assets that are located outside of such territory and are held by or for the Named Defendants or Receivership Defendants or are under their direct or indirect control, jointly, severally, or individually;

B. Within three (3) business days following service of this Order, provide Plaintiff Commission and the Permanent Receiver with a full accounting of all documents and assets that are located outside of the territory of the United States of America and are held by or for Named Defendants or Receivership Defendants or are under their direct or indirect control, jointly, severally, or individually;

C. Hold and retain all transferred documents and assets and prevent any transfer, disposition, or dissipation whatsoever of any such assets or funds, except for transfers to the Permanent Receiver; and

D. Provide Plaintiff Commission and the Permanent Receiver with access to records and documents of the Named Defendants or Receivership Defendants held by financial institutions outside the territorial United States of America, by signing the Consent to Release of Financial Records attached hereto as Attachment B;

Provided, however, that no Defendant who complied with Paragraph III, section B. of the Temporary Restraining Order, shall be required to comply with section B of this Paragraph.

IV. FINANCIAL REPORTS

IT IS FURTHER ORDERED that each Named Defendant, within three (3) business days after entry of this Order, prepare and deliver to this Court, counsel for the Commission, and the Permanent Receiver, completed financial statements on the forms attached to the Temporary Restraining Order, for themselves individually and for each business entity under which they conduct business, or of which they are an officer, and for each trust of which they are a trustee. The financial statements shall be accurate as of the date of entry of this Order; provided, however, that no Defendant who provided a Financial Report pursuant to Paragraph IV of the Temporary Restraining Order shall be required to comply with this Paragraph.

V. PRESERVATION OF RECORDS

IT IS FURTHER ORDERED that Defendants are hereby temporarily restrained and enjoined from destroying, erasing, mutilating, concealing, altering, transferring or otherwise disposing of, in any manner, directly or indirectly, any documents that relate to the business practices or business or personal finances of any Named Defendant or Receivership Defendant.

VI. RECORD KEEPING/BUSINESS OPERATIONS

IT IS FURTHER ORDERED that each Named Defendant is hereby restrained and enjoined from:

A. Failing to create and maintain documents that, in reasonable detail, accurately, fairly, and completely reflect such defendants' incomes, disbursements, transactions, and use of money; and

B. Creating, operating, or exercising any control over any business entity, including any partnership, limited partnership, joint venture, sole proprietorship or corporation, without first providing Plaintiff Commission with a written statement disclosing: (1) the name of the business entity; (2) the address and telephone number of the business entity; (3) the names of the business entity's officers, directors, principals, managers and employees; and (4) a detailed description of the business entity's intended activities.

VII. DISTRIBUTION OF ORDER BY DEFENDANTS

IT IS FURTHER ORDERED that the Named Defendants shall immediately provide a copy of this Order to each affiliate, subsidiary, division, sales entity, successor, assign, officer, director, employee, independent contractor, agent, attorney, and representative of the Named Defendants, and shall, within ten (10) days from the date of entry of this Order, provide the Commission and the Permanent Receiver with a sworn statement that the Named Defendants have complied with this provision of the Order, which statement shall include the names and addresses of each such person or entity who received a copy of the Order. A Permanent Receiver has no obligations under this Paragraph.

VIII. APPOINTMENT OF PERMANENT RECEIVER

IT IS FURTHER ORDERED that __________________________ is appointed Permanent Receiver for Craig A. Lawson, also known as Bob Bryan; Inetintl.Com, Inc., also known as Inet International; any affiliates or subsidiaries, successors or assigns, and any corporation, partnership, or other entity directly or indirectly owned, managed, or controlled by, or under common control with, any of the Named Defendants, including but not limited to Arnesen Creative Services, Inet Strategies, and Whit Consultants (hereinafter referred to as the "Receivership Defendants"), with the full power of an equity Receiver; provided, however, that the receivership over the assets of Craig A. Lawson shall not apply to employment income earned after the date this Order is entered, where said employment is not in violation of the Prohibited Business Activities set forth in Paragraph I of this Order. The Receiver shall be the agent of this Court and solely the agent of this Court in acting as Receiver under this Order. The Receiver shall be accountable directly to this Court. The Receiver shall comply with all Local Rules of this Court governing receivers.

IX. RECEIVERSHIP DUTIES

IT IS FURTHER ORDERED that the Permanent Receiver is directed and authorized to accomplish the following:

A. Assume full control of the Receivership Defendants by removing, as the Receiver deems necessary or advisable, any director, officer, independent contractor, employee, or agent of any of the Receivership Defendants, including any Named Defendant, from control of, management of, or participation in, the affairs of the Receivership Defendants;

B. Take exclusive custody, control and possession of all assets and documents of, or in the possession, custody, or under the control of, the Receivership Defendants, wherever situated, including opening any safe deposit boxes titled in the name of any Receivership Defendant. The Receiver shall have full power to divert mail and to sue for, collect, receive, take in possession, hold, and manage all assets and documents of the Receivership Defendants and other persons or entities whose interests are now held by or under the direction, possession, custody, or control of the Receivership Defendants. The Receiver is fully authorized to effect a change in the rights to use any and all post office boxes or private mail facilities in use by the Receivership entities. Provided, however, the Receiver shall not attempt to collect any amount from a consumer if the Receiver believes the consumer was a victim of the deceptive acts or practices alleged in the Complaint in this matter, without prior court approval;

C. Take all steps necessary to secure the business premises of the Receivership Defendants, including but not limited to all such premises located at 2716 Ocean Park Blvd., Santa Monica, California. Such steps may include, but are not limited to, the following as the Receiver deems necessary or advisable: (1) serving and filing this Order, (2) completing a written inventory of all receivership assets, (3) obtaining pertinent information from all employees and other agents of the Receivership Defendants, including, but not limited to, the name, home address, social security number, job description, method of compensation, and all accrued and unpaid commissions and compensation of each such employee or agent, (4) photographing and video taping all portions of the location, (5) securing the location by changing the locks and disconnecting any computer modems or other means of access to the computer or other records maintained at that location, or (6) requiring any persons present on the premises at the time this Order is served to leave the premises, to provide the Receiver with proof of identification, or to demonstrate to the satisfaction of the Receiver that such persons are not removing from the premises documents or assets of the Receivership Defendants. Law enforcement personnel, including the United States Marshal Service, may assist the Receiver in implementing these provisions in order to keep the peace and maintain security.

D. Conserve, hold, and manage all receivership assets, and perform all acts necessary or advisable to preserve the value of those assets, in order to prevent any irreparable loss, damage, or injury to consumers or to creditors of the Receivership Defendants, including, but not limited to, obtaining an accounting of the assets and preventing transfer, withdrawal, or misapplication of assets;

E. Enter into contracts and purchase insurance as advisable or necessary;

F. Prevent the inequitable distribution of assets and determine, adjust, and protect the interests of consumers and creditors who have transacted business with the Receivership Defendants;

G. Manage and administer the business of the Receivership Defendants until further order of this Court by performing all incidental acts that the Receiver deems to be advisable or necessary, which includes retaining, hiring, or dismissing any employees, independent contractors, or agents;

H. Choose, engage, and employ attorneys, accountants, appraisers, and other independent contractors and technical specialists, as the Receiver deems advisable or necessary in the performance of duties and responsibilities under the authority granted by this Order;

I. Make payments and disbursements from the receivership estate that are necessary or advisable for carrying out the directions of, or exercising the authority granted by, this Order. The Receiver shall apply to the Court for prior approval of any payment of any debt or obligation incurred by the Receivership Defendants prior to the date of entry of this Order, except payments that the Receiver deems necessary or advisable to secure assets of the Receivership Defendants, such as rental payments;

J. Determine and implement the manner in which the Receivership Defendants will comply with, and prevent violations of, this Order and all other applicable laws, including, but not limited to, revising sales materials and implementing monitoring procedures;

K. Institute, compromise, adjust, appear in, intervene in, or become party to such actions or proceedings in state, federal or foreign courts that the Receiver deems necessary and advisable to preserve or recover the assets of the Receivership Defendants or that the Receiver deems necessary and advisable to carry out the Receiver's mandate under this Order;

L. Defend, compromise, adjust, or otherwise dispose of any or all actions or proceedings instituted in the past or in the future against the Receiver in his role as Receiver, or against the Receivership Defendants that the Receiver deems necessary and advisable to preserve the assets of the Receivership Defendants or that the Receiver deems necessary and advisable to carry out the Receiver's mandate under this Order;

M. Continue and conduct the business of the Receivership Defendants in such manner, to such extent, and for such duration as the Receiver may in good faith deem to be necessary or appropriate to operate the business profitably and lawfully, if at all; provided, however, that the continuation and conduct of the business shall be conditioned upon the Receiver's good faith determination that the business can be lawfully operated at a profit using the assets of the receivership estate;

N. Issue subpoenas to obtain documents and records pertaining to the receivership, and conduct discovery in this action on behalf of the receivership estate;

O. Open one or more bank accounts as designated depositories for funds of the Receivership Defendants. The Receiver shall deposit all funds of the Receivership Defendants in such a designated account and shall make all payments and disbursements from the receivership estate from such an account; and

P. Maintain accurate records of all receipts and expenditures that he makes as Receiver.

X. COOPERATION WITH THE RECEIVER

IT IS FURTHER ORDERED that Defendants shall fully cooperate with and assist the Permanent Receiver. Defendants' cooperation and assistance shall include, but not be limited to, providing any information to the Receiver that the Receiver deems necessary to exercising the authority and discharging the responsibilities of the Receiver under this Order; providing any password required to access any computer or electronic files in any medium; or advising all persons who owe money to the Receivership Defendants that all debts should be paid directly to the Receiver. Defendants are hereby restrained and enjoined from directly or indirectly:

A. Transacting any of the business of the Receivership Defendants;

B. Destroying, secreting, defacing, transferring, or otherwise altering or disposing of any documents of the Receivership Defendants, including, but not limited to, books, records, accounts, or any other papers of any kind or nature;

C. Transferring, receiving, altering, selling, encumbering, pledging, assigning, liquidating, or otherwise disposing of any assets owned, controlled, or in the possession or custody of, or in which an interest is held or claimed by, the Receivership Defendants, or the Receiver;

D. Excusing debts owed to the Receivership Defendants;

E. Failing to notify the Receiver of any asset, including accounts, of a Receivership Defendant held in any name other than the name of the Receivership Defendant, or by any person or entity other than the Receivership Defendant, or failing to provide any assistance or information requested by the Receiver in connection with obtaining possession, custody, or control of such assets; or

F. Doing any act or refraining from any act whatsoever to interfere with the Receiver's taking custody, control, possession, or managing of the assets or documents subject to this receivership; or to harass or interfere with the Receiver in any way; or to interfere in any manner with the exclusive jurisdiction of this Court over the assets or documents of the Receivership Defendants; or to refuse to cooperate with the Receiver or the Receiver's duly authorized agents in the exercise of their duties or authority under any Order of this Court.

XI. DELIVERY OF RECEIVERSHIP PROPERTY

IT IS FURTHER ORDERED that:

A. Immediately upon service of this Order upon them, or within a period permitted by the Receiver, Defendants or any other person or entity shall transfer or deliver possession, custody, and control of the following to the Receiver:

  1. All assets of the Receivership Defendants;
  2. All documents of the Receivership Defendants, including, but not limited to, books and records of accounts, all financial and accounting records, balance sheets, income statements, bank records (including monthly statements, canceled checks, records of wire transfers, and check registers), client lists, title documents and other papers;
  3. All assets belonging to members of the public now held by the Receivership Defendants; and
  4. All keys, pass cards, and codes necessary to gain or to secure access to any assets or documents of the Receivership Defendants, including, but not limited to, access to their business premises, means of communication, accounts, computer systems, or other property.

B. In the event any person or entity fails to deliver or transfer any asset or otherwise fails to comply with any provision of this Paragraph, the Receiver may file ex parte an Affidavit of Non-Compliance regarding the failure. Upon filing of the Affidavit, the Court may authorize, without additional process or demand, Writs of Possession or Sequestration or other equitable writs requested by the Receiver. The writs shall authorize and direct the United States Marshal or any sheriff or deputy sheriff of any county (pursuant to Fed. R. Civ. P. 4(c)(1) and Local Rule 4.1) to seize the asset, document, or other thing and to deliver it to the Receiver.

XII. BANKRUPTCY PETITIONS

IT IS FURTHER ORDERED that, in light of the appointment of the Permanent Receiver, the Receivership Defendants are hereby prohibited from filing, or causing to be filed, a petition for relief under the United States Bankruptcy Code, 11 U.S.C. 101 et seq., without prior permission from this Court.

XIII. TRANSFER OF FUNDS TO THE RECEIVER

IT IS FURTHER ORDERED that, upon service of a copy of this Order, all banks, broker-dealers, savings and loans, escrow agents, title companies, commodity trading companies, or other financial institutions shall cooperate with all reasonable requests of the Receiver relating to implementation of this Order, including transferring funds at his direction and producing records related to the assets of the Receivership Defendants.

XIV. STAY OF ACTIONS

IT IS FURTHER ORDERED that:

A. Except by leave of this Court, during pendency of the receivership ordered herein, Defendants and all customers, principals, investors, creditors, stockholders, lessors, and other persons seeking to establish or enforce any claim, right, or interest against or on behalf of the Receivership Defendants, and all others acting for or on behalf of such persons, including attorneys, trustees, agents, sheriffs, constables, marshals, and other officers and their deputies, and their respective attorneys, servants, agents and employees, be and are hereby stayed from:

  1. Commencing, prosecuting, continuing, entering, or enforcing any suit or proceeding, except that such actions may be filed to toll any applicable statute of limitations;
  2. Accelerating the due date of any obligation or claimed obligation; filing or enforcing any lien; taking or attempting to take possession, custody, or control of any asset; attempting to foreclose, forfeit, alter, or terminate any interest in any asset, whether such acts are part of a judicial proceeding, are acts of self-help, or otherwise;
  3. Executing, issuing, serving, or causing the execution, issuance or service of, any legal process, including, but not limited to, attachments, garnishments, subpoenas, writs of replevin, writs of execution, or any other form of process whether specified in this Order or not; or
  4. Doing any act or thing whatsoever to interfere with the Receiver taking custody, control, possession, or management of the assets or documents subject to this receivership, or to harass or interfere with the Receiver in any way, or to interfere in any manner with the exclusive jurisdiction of this Court over the assets or documents of the Receivership Defendants.

B. This paragraph does not stay:

  1. The commencement or continuation of a criminal action or proceeding;
  2. The commencement or continuation of an action or proceeding by a governmental unit to enforce such governmental unit's police or regulatory power;
  3. The enforcement of a judgment, other than a money judgment, obtained in an action or proceeding by a governmental unit to enforce such governmental unit's police or regulatory power;
  4. The commencement of any action by the Secretary of the United States Department of Housing and Urban Development to foreclose a mortgage or deed of trust in any case in which the mortgage or deed of trust held by the Secretary is insured or was formerly insured under the National Housing Act and covers property, or combinations of property, consisting of five or more living units; or
  5. The issuance to a Receivership Defendant of a notice of tax deficiency.

C. Except as otherwise provided in this Order, all persons and entities in need of documentation from the Receiver shall in all instances first attempt to secure such information by submitting a formal written request to the Receiver, and, if such request has not been responded to within thirty (30) days of receipt by the Receiver, any such person or entity may thereafter seek an Order of this Court with regard to the relief requested.

XV. COMPENSATION OF PERMANENT RECEIVER

IT IS FURTHER ORDERED that the Permanent Receiver and all personnel and independent contractors hired by the Receiver as herein authorized, including counsel to the Receiver and accountants, are entitled to reasonable compensation for the performance of duties pursuant to this Order and for the cost of actual out-of-pocket expenses incurred by them, from the assets now held by or in the possession or control of or which may be received by the Receivership Defendants. The Receiver shall file with the Court and serve on the parties periodic requests for the payment of such reasonable compensation, with the first such request filed no more than sixty (60) days after the date of this Order. The Receiver shall not increase the hourly rates used as the bases for such fee applications without prior approval of the Court.

XVI. RECEIVER'S BOND

IT IS FURTHER ORDERED that the Receiver shall file with the Clerk of this Court a bond in the sum of __________ with sureties to be approved by the Court, conditioned that the Receiver will well and truly perform the duties of the office and abide by and perform all acts the Court directs.

XVII. SERVICE OF ORDER

IT IS FURTHER ORDERED that copies of this Order may be served by any means, including facsimile transmission, upon any financial institution or other entity or person that may have possession, custody, or control of any documents or assets of any Named Defendant or Receivership Defendant, or that may be subject to any provision of this Order. Service upon any branch or office of any financial institution shall effect service upon the entire financial institution.

XVIII. CONSUMER CREDIT REPORTS

IT IS FURTHER ORDERED that pursuant to Section 604(1) of the Fair Credit Reporting Act, 15 U.S.C. 1681b(1), any consumer reporting agency may furnish a consumer report concerning any Named Defendant or Receivership Defendant to Plaintiff Commission.

XIX. RETENTION OF ASSETS AND RECORDS

IT IS FURTHER ORDERED that any financial or brokerage institution, business entity, or person served with a copy of this Order that holds, controls or maintains custody of any account or asset of the Named Defendants or Receivership Defendants, or has held, controlled or maintained custody of any such account or asset at any time since January 1, 1995 (including without limitation assets at Bank of America, 9001 Lincoln Blvd., Los Angeles, California, or any other Bank of America branch, Account Numbers 21623 04915, 21620 04884, 21628 04786, and 21628 05054, or any other account number; and assets at California Federal Bank, 5700 So. Sepulveda, Culver City, California, or any other California Federal Bank branch), shall:

A. Prohibit the Defendants from withdrawing, removing, assigning, transferring, pledging, encumbering, disbursing, dissipating, converting, selling, or otherwise disposing of any such account or asset except:

  1. as directed by further order of the Court;
  2. for specific transfers authorized in writing by counsel for the Commission; or
  3. as directed by the Permanent Receiver (regarding assets held in the name or for the benefit of the Receivership Defendants);

B. Deny Defendants access to any safe deposit box that is:

  1. titled in the name of Inetintl.Com, Inc., also known as Inet International; Craig A. Lawson, also known as Bob Bryan; Erik R. Arnesen; Stanley R. Goldberg, also known as Geoff Stevens; Arnesen Creative Services; Inet Strategies; Whit Consultants; or their affiliates or subsidiaries, successors or assigns, either individually or jointly; or
  2. otherwise subject to access by the Named Defendants or Receivership Defendants, either individually or jointly;

C. Provide counsel for the Commission and the Permanent Receiver within five (5) business days of receiving a copy of this Order, a sworn statement setting forth:

  1. the identification number of each such account or asset titled in the name, individually or jointly, of the Named Defendants or Receivership Defendants, or held on behalf of, or for the benefit of, any such Defendant;
  2. the balance of each such account, or a description of the nature and value of such asset as of the time this Order is served, and, if the account or other asset has been closed or removed, the date closed or removed, the total funds removed in order to close the account, and the name of the person or entity to whom such account or other asset was remitted; and
  3. the identification of any safe deposit box that is either titled in the name, individually or jointly, of any Named Defendant or Receivership Defendant, or is otherwise subject to access by any such Defendant; Provided, however, that no entity that provided this statement pursuant to the Temporary Restraining Order shall be required to provide this statement pursuant to this Order.

D. Upon the request by the Permanent Receiver or the Commission, promptly provide the Permanent Receiver and the Commission with copies of all records or other documentation pertaining to such account or asset, including but not limited to originals or copies of account applications, account statements, signature cards, checks, drafts, deposit tickets, transfers to and from the accounts, all other debit and credit instruments or slips, currency transaction reports, 1099 forms, and safe deposit box logs; and

E. Cooperate with all reasonable requests of the Permanent Receiver relating to implementation of this Order, including transferring funds at the Receiver's direction and producing records related to the accounts of any Named Defendant or Receivership Defendant.

XX. ACCESS TO DEFENDANTS' BUSINESS PREMISES

IT IS FURTHER ORDERED that the Permanent Receiver shall allow the Commission's representatives, the Named Defendants' representatives, and the Named Defendants themselves reasonable access to the premises of the Receivership Defendants, including but not limited to all such premises located at 2716 Ocean Park Blvd., Santa Monica, California. The purpose of this access shall be to inspect and copy any and all books, records, accounts, and other property owned by or in the possession of the Receivership Defendants. The Receiver shall have the discretion to determine the time and manner of this access.

XXI. RETENTION OF JURISDICTION

IT IS FURTHER ORDERED that this Court shall retain jurisdiction of this matter for all purposes.

No security is required of any agency of the United States for the issuance of a restraining order. Fed. R. Civ. P. 65(c).

SO ORDERED, this ___ day of ____________, 1998, at ____.m.

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United States District Court Judge

Presented by:

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Linda M. Stock
Russell S. Deitch
Attorney for Plaintiff
Federal Trade Commission