defendants. - florida attorney generalfile/travel+buy+owner+complaint.pdf · 11. defendant travel...

IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA

OFFICE OF THE ATTORNEY GENERAL, DEPARTMENT OF LEGAL AFFAIRS, STATE OF FLORIDA,

Plaintiff,

vs.

TRAVEL BUY OWNER, INC., a Florida For Profit Corporation, CFL VENTURES, INC., a Florida For Profit Corporation, ETM MARKETING,

CASE NO. ________________ __

a Florida fictitious company owned by CFL Ventures, Inc., and TROY PHIL MOHABIR, Individually and as Officer/Director of Travel Buy Owner, Inc.,

DEFENDANTS. ____________________________________________ /

COMPLAINT FOR INJUNCTIVE RELIEF, DAMAGES, CIVIL PENALTIES AND OTHER STATUTORY RELIEF

This is an action for injunctive relief, declaratory relief, damages, costs, attorneys'

fees, and penalties brought under the Florida Deceptive and Unfair Trade Practices Act,

Chapter 501, Fla. Stat. and Florida' s Telemarketing Act, Chapter 501 , Part IV, Fla. Stat.

The State of Florida, Office of the Attorney General, Department of Legal Affairs

(hereinafter referred to as "Plaintiff'), sues the Defendants, TRAVEL BUY OWNER,

INC., CFL VENTURES, INC., ETM MARKETING and TROY PHIL MOHABIR

(hereinafter referred to as "Defendants"), and alleges:

JURISDICTION AND VENUE

1. This is an action for injunctive and other statutory relief, brought pursuant to the

Florida Deceptive and Unfair Trade Practices Act, Chapter 501, Part II, Fla. Statutes.

Plaintiff is the enforcing authority of Florida's Deceptive and Unfair Trade Practices Act as

defined in Chapter 501, Part II, Florida Statutes, and is authorized to seek damages,

injunctive and other statutory relief pursuant to this part.

2. This court has subject matter jurisdiction pursuant to the provisions of Chapter

501, Part II, Florida Statutes.

3. The statutory violations alleged herein occur in or affect more than one judicial

circuit in the State of Florida, including Seminole County, and the Eighteenth Judicial

Circuit.

4. Venue is proper in Orange County, Florida as the statutory violations alleged herein

occurred in or affected more than one judicial circuit in the State of Florida, including Polk

County, Manatee and/or Sarasota County and Defendants TRAVEL BUY OWNER, INC.

and CFL VENTURES, INC. are located in Orange County. Venue is proper in the Ninth

Judicial Circuit as the Defendants conduct business in Orange County.

PLAINTIFF

6. The Plaintiff is an "enforcing authority" of Chapter 501 , Part II, Florida Statutes,

and is authorized to bring this action and seek injunctive relief and other statutory relief

pursuant to that chapter.

7. Plaintiff has conducted an investigation of the matters alleged herein and Attorney

General Pamela Jo Bondi has determined that this enforcement action serves the public

interest, as required by §501.207(2), Florida Statutes. The Determination of Public Interest

in attached hereto as Exhibit A.

8. Defendants, at all times material hereto, provided goods or services as defined

within Section 501.203(8), Florida Statutes within the State of Florida and Orange County.

9. Defendants, at all times material hereto, solicited consumers within the definitions

of Section 501.203(7), Florida Statutes.

10. Defendants, at all times material hereto, were engaged in a trade or commerce

within the definition of Section 501.203(8), Florida Statutes (2013).

DEFENDANTS

Travel Buy Owner, Inc.

11. Defendant TRAVEL BUY OWNER, INC. ("TBO"), is a dissolved Florida for-profit

corporation registered with the Florida Department of State, Division of Corporations and

located at 56 E. Pine Street, Orlando, Florida 32801-2660.

12. Defendant, TBO, is a business entity engaged in the timeshare resale advertising

business through telemarketing. TBO employs a staff oftelemarketers to purportedly call

consumers who own timeshares and solicit them to pay TBO a fee to advertise the

consumer's timeshare for sale or rent.

13. At all times relevant to this action Defendant, TBO, engaged in trade or commerce

as defined in §50 1.203(8), Florida Statutes.

CFL Ventures, Inc.

14. Defendant CFL VENTURES, INC. ("CFL"), is an active Florida for-profit

corporation registered with the Florida Department of State, Division of Corporations and

located at 1583 E. Silver Star Road, #254, Ocoee, Florida 34761. ETM MARKETING is an

active fictitious name used by CFL and registered with the Florida Department of State,

Division of Corporations.

12. Based upon information and belief, Defendant, CFL, is a business entity engaged in

the timeshare resale advertising business. CFL has additionally charged consumers for

services timeshare resale advertising services purportedly to be provided by TBO.

13. At all times relevant to this action Defendant, CFL, engaged in trade or commerce

as defined in §50 1.203(8), Florida Statutes.

Troy Phil Mohabir

15. Defendant, TROY PHIL MOHABIR (hereinafter MOHABIR) is a natural person

and owns and operates TBO.

16. As owner, MOHABIR, presently and at all times material to the allegations of this

Complaint, participated in, controlled, or possessed the authority to control TBO's acts

and practices, and possessed actual or constructive knowledge of all material acts and

practices complained of herein.

17. At all times material, MOHABIR, received proceeds from accounts opened in the

name of TBO, containing monies paid by consumers to TBO. The accounts and property

of Defendant, MOHABIR, contain proceeds of the deceptive acts and practices

complained of herein.

18. MOHABIR is registered with the Florida Department of State, Division of

Corporations as both the registered agent and President ofTBO.

19. Upon information and belief, Defendant, MOHABIR is an adult individual residing

in Orange County, Florida.

STATEMENT OF FACTS AND DEFENDANTS' COURSE OF CONDUCT

Generally

20. At all pertinent times, Defendants market and continue to market advertising for

timeshare re-sales to timeshare owners in Florida and throughout the United States via

telemarketing and internet advertising.

21. Commencing on an date unknown, but at least subsequent to January 2009, the

Defendants engaged in a systematic pattern of conduct designed and intended to induce

consumers to pay Defendants an "advertising" and/or "marketing" fee for timeshare

resale services via a series of false and fraudulent misrepresentations.

22. Commencing on a date unknown but subsequent to January 2009, the Defendants

contacted consumers through telephone solicitation and represented that TBO had located

a buyer interested in purchasing the consumer's timeshare who had already paid a deposit

on the sale. Defendants falsely promised the consumer would be receiving the purported

purchaser's deposit if the sale was not completed. Defendants stated that they needed to

collect an up-front "advertising" or "closing" fee to facilitate the sale, which was promised

to take place within 90-120 days. Upon receipt of the "advertising" or "closing" fee,

consumers are no longer contacted by Defendants. When consumers attempt to contact

TBO to determine the sale progress, Defendants make a false statement that the

purchasers are having "credit" or "tax lien" problems and cannot complete the sale.

Plaintiff is not aware of any sale that has been completed by Defendants.

23. In order to utilize Defendants timeshare resale marketing services, Defendants have

required hundreds of consumers to pay Defendants an "advertising fee" or "closing" fee of

up to $ 1,500 each, while Defendants falsely assured the consumer that despite the fees

being for "advertising," Defendants were in actuality facilitating the sale of a timeshare.

24. Based on information and belief, Defendants' scheme was in fact an outright scam.

Defendants often gave consumers the name and phone number of the purportedly

interested timeshare purchasers in an effort to make consumers feel more secure about

the telephone solicitations. Repeatedly, the "interested timeshare purchasers" were the

same people, Ruth and William Snyder, supposedly of Milwaukee, Wisconsin.

25. Based on information and belief, Ruth and Bill Snyder were false identities created

by Defendants to lure consumers to pay up-front fees for services which Defendants never

intended to provide.

26. Defendants made prom1ses and misrepresentations of the contract terms while

telemarketing to consumers over the phone and then furnished written contracts to

consumers which contained completely different terms regarding Defendants timeshare

re-sale services.

27. Defendants charged consumers credit cards or cashed consumers checks without

regard to whether a signed written contract from the consumer delineating all the terms

and conditions ofthe services Defendant provides had been received by the Defendants.

28. Defendants do not provide the consumer who wants to re-sell their timeshare with a

description of the fees and costs relating to the advertising and listing nor do Defendants

provide the ratio of the number of listings of timeshare interests for sale versus the

number of timeshare interests sold by the Defendants for each of the previous 2 calendar

years.

29. Upon Plaintiffs information and belief, Defendants are not providing consumers

with the promised and contracted-for services.

Patricia MacRunnels

30. Patricia MacRunnels, age 56 and a resident of Faribault, Minnesota, was contacted

v1a telephone solicitation by Defendants in March 2011 and told Defendants had a

purchaser for her Mexico timeshare. The purchasers were purportedly William and Ruth

Snyder, and Defendants stated that they were willing to purchase the timeshare for

$48,000. Indeed, Defendants told Ms. MacRunnels that the Snyders had already made a

down payment of $9,600.00 and that the sale would close within 60-90 days. Defendants

requested payment of a $1,500.00 closing fees to complete the sale. After making the

payment of $1,500.00, Ms. MacRunnels did not hear from Defendants until making a

complaint with their credit card, over four months later. At that point, Defendants

claimed the buyer had "lost the paperwork" for the closing. To date, Ms. MacRunnel's

timeshare sale is still outstanding with no further contact from Defendants. The Affidavit

of Pat MacRunnels is attached hereto as Exhibit B.

Monica P. Gandauli

31. Monica P. Gandauli, age 53 and a resident of Kaneohe, Hawaii, was solicited by

telephone in July 2011 by Defendants to sell her timeshare immediately. Defendants told

Ms. Gandauli that they had located a buyer willing to put down a cash deposit of $6,340.00

on her Maui, Hawaii timeshare. The buyers were purportedly William and Ruth Snyder

of Wisconsin, who agreed to pay $31,700 for the timeshare. In fact, Ms. Gandauli was

provided with a "deposit code" and a sales contract number to support that the deposit

had been made and the sale would go through. Defendants then requested Ms. Gandauli

pay an up-front fee of $1,500 for transfer of the title and to process legal documents.

Defendants stated that if the purchase did not go through, Ms. Gandauli would receive the

Snyder's cash deposit. After providing her credit card information to Defendants and

being charged by CFL, Ms. Gandauli was provided a written agreement purporting to be

for advertising services. In November 2011, Defendants told Ms. Gandauli that the

Snyders had a tax lien that needed to be cleared up before the timeshare could close. To

date, Ms. Gandauli's timeshare sale is still outstanding with no further contact from

Defendants. The Affidavit of Monica P. Gandauli is attached hereto as Exhibit C.

Brenda Craner

32. Brenda Craner, age 55 and a resident of Henrico, Virginia, was solicited by

telephone on October 28, 2011 by Defendants to sell her timeshare immediately.

Defendants told Ms. Craner that a buyer in Ohio had made an offer to purchase her

Orlando, Florida timeshare for $15,900.00. Ms. Craner stated that she accepted the offer

in the initial conversation. Defendants told her the potential buyer had made a deposit of

$3,180.00, which she would receive if the sale fell through. Defendants then requested an

up-front fee of $1,500 for the title search, stating that TBO would receive a commission of

$508.00 on the sale. Defendant paid the up-front fee and was thereafter provided with a

written agreement, which she executed on or about November 4, 2011. When Ms. Craner

asked why the agreement stated it was for advertising services, Defendants responded that

the agreement was merely a "formality" and was for the actual sale of the property.

Subsequently, in February 2012, Defendants represented to Ms. Craner that the potential

buyer had liens which needed to be paid before the closing could take place, and estimated

this would occur in July 2012. In August 2012, Defendants stated that the company was

processing the sale. To date, Ms. Craner's timeshare sale is still outstanding with no

further contact from Defendants since September 2012. The Affidavit of Brenda Craner is

attached hereto as Exhibit D.

Jay and Yvonne Beebe

33. Jay and Yvonne Beebe, aged 79 and 75 respectively, and residents of Lake Wales,

Florida, were solicited by telephone in December 2010 by Defendants to sell their

Gatlinburg, Tennessee timeshare immediately. Defendants told the Beebes that buyers

from Michigan, Robert and Anna Gains, had made an offer to purchase their timeshare

for $15,500.00, almost double what they had paid. Defendants also promised to rent out

the timeshare for $3,500.00during the pendency of the sale. Defendants requested payment

of an up-front fee of$1,500.00 to facilitate the sale. After not hearing from Defendants for

three months, the Beebes requested a refund. Defendants agreed to return their money,

but to date the Beebes have not been compensated as agreed, nor have Defendants made

any further contact with the couple. The Affidavit of Yvonne Beebe is attached hereto as

Exhibit E.

34. At the time this Complaint was filed, Plaintiff is aware of at least 261 consumers

who have been similarly defrauded by Defendants ' unfair and deceptive acts and

practices.

COUNT I DECEPTIVE AND UNFAIR TRADE PRACTICES

35. Plaintiff adopts, incorporates herein and re-alleges paragraphs 1 through 34 as if

fully set forth hereinafter and further alleges:

36. Chapter 501.204(1) and 501.202(2), Florida Statutes, declare that unfair and

deceptive acts or practices in the conduct of any trade or commerce are unlawful.

37. The Florida Deceptive and Unfair Trade Practices Act, Chapter 501, Part II,

Florida Statutes, provides that "unfair methods of competition, unconscionable acts or

practices, and unfair or deceptive acts or practices in the conduct of any trade or

commerce are hereby declared unlawful."

38. Defendants have violated and are continue to violate the Florida Deceptive and

Unfair Trade Practices Act Section 501.201, Florida Statutes, by using deceptive and

unfair practices in the marketing and advertising of timeshare re-sale services based on

the above-described acts and practices.

39. These above-described acts and practices of the Defendants have injured and will

likely continue to injury and prejudice the public.

40. Unless the Defendants are permanently enjoined from engaging further in the acts

and practices complained herein, the Defendants will result in irreparable injury to the

public for which there is no adequate remedy at law.

COUNT II VIOLATIONS OF CHAPTER 501, PART IV, FLORIDA STATUTES

FLORIDA TELEMARKETING ACT

41. Plaintiff adopts, incorporates herein andre-alleges paragraphs 1 through 34 as if


42. Section 501.615(1), Florida Statues establishes "a purchase of consumer goods or

services ordered as a result of a commercial telephone solicitation as defined in this part, if

not followed by a signed written contract, is not final. Furthermore, Section 501.059(5)(b),

Florida Statutes establishes that the consumer is not obligated to pay any money unless the

consumer signs and returns a contract to the seller.

43. Section 501.602, Florida Statutes, establishes a policy of "promoting the general

welfare ofthe public and integrity of the telemarketing industry."

44. Defendants have violated and continue to violate Sections 501.615, 501.059, and

501.602 by using deceptive and unfair practices in telemarketing.






COUNT III VIOLATIONS OF CHAPTER 721, PART I, FLORIDA STATUTES

VACATION PLANS AND TIMESHARING

47. Plaintiff adopts, incorporates herein and re-alleges paragraphs 1 through 34 as if


48. Section 721.20 (7), Florida Statutes establishes: "It is unlawful for any broker,

salesperson, or broker-salesperson to collect any advance fee for the listing of a personal

property timeshare interest.

49. Prior to July 1, 2012, Section 721.20 (9)(a), Florida Statutes established: "Prior to

listing or advertising a timeshare interest for resale, a resale service provider shall provide

to the timeshare interest owner a description of any fees or costs relating to the

advertising, listing, or sale of the timeshare interest that the timeshare interest owner, or

any other person, must pay to the resale service provider or any third party, when such

fees or costs are due, and the ratio or percentage of the number of listings of timeshare

interests for sale versus the number of timeshare interests sold by the resale service

provider for each of the previous 2 calendar years."

50. Pursuant to Section 721.20 (9)(b), Florida Statutes, prior to July 1, 2012, a "failure

to disclose this information in writing constitutes an unfair and deceptive trade practice

pursuant to chapter 501. Any contract entered into in violation of this subsection is void

and the purchaser is entitled to a full refund of any moneys paid to the resale service

provider."

51. Defendants have violated Section 721.20, Florida Statues, by taking advance fees for

listing timeshare re-sale properties pursuant to the executed contracts, by not providing

the seller of the timeshare a description of any fees or costs relating to the advertising and

listing, and by not providing the ratio or percentage of the number of listings of timeshare

interests for sale versus the number of timeshare interested sold by Defendants for each

for each of the previous 2 calendar years. Where Defendants did provide a ration or

percentage of the number of listings of timeshare interests for sale versus the number of

timeshare interested sold by Defendants for each for each of the previous 2 calendar years

in its contract, it unfairly and deceptively attempted to disclaim the ratio in violation of

Chapter 501, Part II, Florida Statutes.

52. Defendants have violated Sections 721.20 (7) and 721.20(9)(a) and (b) by using

unfair and deceptive practices in telemarketing and timeshare resale advertising.

53. Individual Defendant MOHABIR controlled and/or had the authority to control,

supervise and manage the acts and practices of TBO that violated of Chapter 501.

MOHABIR further violated Section 721.205(4), Florida Statutes as resale service

providers as well as in their own individual statements to consumers.






PRAYER FOR RELIEF

WHEREFORE, Plaintiff, State of Florida, Office of the Attorney General,

Department of Legal Affairs, respectfully requests that this Court grant:

1. A permanent injunction prohibiting Defendants, and their officers, agents,

servants and employees, and those person in active concert or participation

with them who receive actual notice of the Court's orders, from engaging in

any activity within the State of Florida, or from outside the State of Florida

but involving Florida businesses or Florida residents, which relates in any

way to marketing, timeshares or involves telemarketing or timeshare re

sales.

2. Alternatively, a permanent injunction requiring Defendants to change their

advertising and business practices to ensure that Florida Statutes are not

continued to be violated and consumers are not mislead by Defendants.

3. Freeze all financial assets of Defendants from any waste, dissipation or other

distribution of assets until further order of this Court and enjoin the

Defendants from transferring, conveymg, encumbering, disposing of or

otherwise alienating such assets.

4. Awarding, full restitution for all consumers who were deceived by

Defendants in connection with the advertisements or resale service in

question or in connection with any transactions transpiring in Florida

including solicitation or telemarketing originating from Florida, or payment

received in Florida, purporting to sell, rent or advertise' timeshares.

5. Assessing against Defendants civil penalties in the amount of ten thousand

dollars ($10,000) for each violation of Chapter 501 , part II, pursuant to

section 501.2075, Fla. Stat. and civil penalties in the amount of fifteen

thousand dollars ($15,000) for each violation victimizing a senior citizen,

pursuant to section 50 1.205(7), Fla. Stat.

6. Awarding reasonable attorneys' fees and costs to the Department of Legal

Affairs pursuant to sections 501.2105 and 501.2075, Fla. Stat.

7. Costs; and

8. Such other and further relief as may be just and equitable.

DATED this 2i11 day of February, 2013.

Assistant Attorney General Florida Bar # 598542 Office of the Attorney General Consumer Protection Division 1515 North Flagler Drive, Suite 900 West Palm Beach, Florida 33405 Tel: 561-837-5000 Fax: 561-837-5102 [email protected]

Katherine Kiziah Assistant Attorney General Florida Bar #0017585 Office of the Attorney General Consumer Protection Division 1515 North Flagler Drive, Suite 900 West Palm Beach, Florida 33405 Tel: 561-837-5000 Fax: 561-837-5102 [email protected]

IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA

OFFICE OF THE ATTORNEY GENERAL, DEPARTMENT OF LEGAL AFFAIRS, STATE OF FLORIDA,

Plaintiff, CASE NO. __________________ _

vs.

TRAVEL BUY OWNER, INC., a Florida For Profit Corporation, CFL VENTURES, INC., a Florida For Profit Corporation, ETM MARKETING, a Florida fictitious company owned by CFL Ventures, Inc., and TROY PI-IlL MOHABIR, Individually and as Officer/Director of Travel Buy Owner, Inc.,

DEFENDANTS.

--------------------------------------------~/

DETERMINATION OF PUBLIC INTEREST

COMES NOW, PAMELA JO BONDI, ATTORNEY GENERAL, STATE OF FLORIDA, and states:

1. Pursuant to Section 20. 11 , Florida Statutes, I am the head of the Department of Legal Affairs, State of Florida (hereinafter referred to as the Department).

2 . In this matter, the Department seeks declaratory and injunctive relief, disgorgement, restitution, and civil penalties caused by an act or practice performed in violation of Chapter 501, Part II, Florida Statutes.

3. I have reviewed this matter and I have determined that an enforcement action serves the public interest.

Dated: February~l, 2013

PAMELA JO BONDI ATTORNEY GENERAL STATE OF FLORIDA

Page 1 of 1

PLAINTIFF'S I EXHIBIT ~A...___

, . I

PAM BONDI A TIORNEY GENERAL

STATE OF FLORIDA

OFFICE OF THE ATTORNEY GENERAL Consumer Protection Division AmaDouglas Investigator Supervisor Florida Attorney General's Office 110 SE 6th Street 9th Floor Fort Lauderdale, Florida 33301 (954) 712-4631 Office (954) 527-3708 Fax [email protected]

January 29,2013

In Re: TRAVEL BY OWNER, INC.

The Office of the Attorney General for the State of Florida is investigating TRAVEL BY OWNER, INC. pursuant to Florida's Deceptive and Unfair Trade Practices Act, Chapter 501, Part II, Florida Statutes. The Office of the Attorney General is contacting you because you have either notified us, or another consumer related entity of your interest and concerns regarding this company. If you wish to detail your personal transaction and experience with this company in order to assist us in our investigation, we request that you please complete the enclosed affidavit complaint form. While our office is unable to determine at this time what, if any action may come from this investigation, your time and cooperation will greatly assist us in making such a determination.

Please complete the affidavit in its entirety. Upon completion of the affidavit please forward the ORIGINAL signed affidavit, along with COPIES of any attached documents to:

Office of the Attorney General Consumer Protection Division

Attn: Claudia Machado Victim Services Program Specialist

Office of the Attorney General State of Florida 110 SE 6 Street, lOth Floor Ft. Lauderdale, FL 33301

Please be aware that the Office of the Attorney General does not contract with any outside third parties to assist in pursuing any complaints nor with obtaining restitution for consumers who may have been harmed by unscrupulous businesses. Furthermore, should our office obtain a settlement or court order for a company to provide refunds or restitution, we would never require a consumer to pay a fee of any sort in order to obtain the refund or restitution. Consumers should be cautious of any business that requires an advance fee prior to providing services, especially if that advance fee is required to be paid in the form of a certified check, bank check, money order, or wire transfer.

Should you have any questions or concerns, please contact Victim Services Program Specialist Claudia Machado at 954-712-4641.

Sincerely, Ama Douglas Investigator Supervisor

PLAINTIFF'S :; EXHIBIT

i t)

STATE OF FLORIDA OFFICE OF THE ATTORNEY GENERAL PAM BONDI

In re: Travel Buy Owner, INC.

PLEASE COMPLETE AND RETURN SIGNED AFFIDAVIT AS SOON AS POSSIBLE TO:

By mail: Office of the Attorney General, Consumer Protection Division, Attn: Claudia Machado, 110 SE 6th St., 1Oth Floor, Ft. Lauderdale, FL 33301

By email: [email protected]

CONSUMER AFFIDAVIT

NAME~s.) ~ .Q±:}f1d?!.J..(\(\&_[ /) Date of Birth ~ {Ut { q{i_p (J (Print or W>e namr+- ,

ADDRESS (]fJ.cf ZJ~(JJrxy f-MO.i frt.yt bat-t 1f-t YflrL ~q{)_2( TELEPHONE: Home ( ) ...---- Work &-/J 33_J..-{v772. Cell ( tfo>7 279 ·:z{t)3

E-MAIL sir9v&$']3(@;:liJt up sie~.~if\ Please specify: Are you 60 years old or older? __ Yes _K No

Are you disabled? __ Yes _X_ No

And who, after being duly sworn and deposed, upon his/her personal knowledge, states:

I would like to file a complaint against: -r'm\i& J &v.'{ ~~ \ -=r:ne....- ·

(Please include: person/company name, address and telephone number)

I first became aware of this company/person through (example- internet, telephone, mail solicitation, etc.): ?\ p,lx,txL crX t(

What service(s) were offered to you? 1h_~y 9cU.fl ~l.( kJ_ CL hex r~(L -tv ~ ±l~='sb~ M~

Did you accept the service(s)? Yes L No __ .

If yes, what specifically a out the service(s) interested you?

" ' 114

Did you sign a contract or agreement with this company? Yes ,X_ No __ .

If yes, please attach a copy of the contract

Prior to listing or advertising your timeshare for resale, did the company provide ypu with a description of fees or costs related to the advertising, listing or sale ofj(ur timeshare? Yes X No __ . If yes, was the information provided to you in writing? Yes No __ .

Where is your timeshare deeded? _ __.o..;h)j'-"-'· t~tC-~.-V.c....------------------Were X told by a company representative that your timeshare has a specific retail value?

Yes No . ~ Ifyes, what were you told was the value of your timeshare?$ lf 1!{f) ,Q{)

Were you required to make .a yayment in excess of$75.00USD before signing a ;6;n .. ,,;'\ contract/agreement? Yes A_ No . If yes, amount of payment:$ /1 · ,UJ Contract/Agreement Date: J]U'2all Form of payment (please provide a COPY front and back of any checks, credit car , money order, personal check or receipts that show this fee. - -

If yes, please attaclt a copy

What were you told the payment was for?

~. odl~d-~l~ -{1!]S. lJJf( u >~ do lJ. Cf= LlltS

Were you provided with a receipt or any documentation (contract, letter, agreement, etc.) confirming your payment(s)? Yes~ No __ . /[yes, please attach copies.

Were you informed of the company's Refund Policy? Yes__ No){_. If yes, please indicate the terms of the refund policy as they were explained to you: - ---------------

Have you requested to cancel your contractJJi!ement? Date of cancellation request: 1 ~ / t

YesX No __ .

Did you request a refund? Yes)'!{_ No __ . If yes, did you receive a full or partial refund? Yes No X . If you received a refund, amount?$ ______ _

2J4

Form in which cancellation was requested (email, certified letter, etc.):. __ =-:---------· Please attach copies

Did you contact the company regarding your complaint? Yes L No __ . If so, state the name of the person you talked to and describe what representations were made?

uX1 .~, wJth~ u+ 277._. '733-~Bl x- 0x>z

~J!ftu :if~t~1 ~ !:t;:J\~1;~-/t:Y .9:u Cl. m ch::>V~ papv.2 (JJiro, On \tAl 1\C o\~.k . . Did ~company ever indicate to you that there was a buyer/renter waiting to buy/rent your timeshare?

~~es, what ~i~ the co~pany teu you? ~y. :fnld u5 -+Aa+ o.. UJ i1l1 ~ , c:tAZt:±t sp.~P~ I o. t,C)\~!)\1-- u2U\~ b~ ~~ a.

Were any represenKions, guarantees or promises made to you regardi g the sa e/ren al of your timeshare? Yes No__ If yes, what were you told? LJ 9

--t-6& flt?b, !})\ NL ~~~ ~4~,crX> =lk i' and t..L!@I-A .

~:t·;_Lf I illrk ~ ~::qt~;c W.<Ai+f& G~0 / Ao/

Clearly and in detail, please state your complaint describing events in which they occurred, including the dates, times, and names of individuals with whom you had any contact with. Describe in as much detail

as possible any statements made to you or events which occurred, that you would deem as deceptive, misleading or unfair.

3J4

In order to resolve this ~laint I request (example: a refund, cancellation of contract, etc.): /J £ (!_ • /

oJ:1J1+ a ~ a.J ~, ~cf o:uuPLld ·. We.,also~~ Please Jist below and attach any documents in support of your complaint. By signing b3fw,~~ h_O. ~~- U. certifying that these documents are true and correct copies of the originals. J J'q;{Q()D

The above listed documents included along with this Affidavit, are a true representation of all documents submitted by me, which support my complaint.

FURTHER AFFIANT SAYETH NAUGHT.

My signature authorizes the Attorney General's Office to take any action deemed necessary for purposes of investigation or enforcement. I understand that the Attorney General does not represent private citizens seeking the return of their money or other personal remedies. I am filing this complaint to notify your office of the activities of this company so that it may be determined if law enforcement or legal action is warranted.

Pursuant to Florida Statutes Section 92.525, under penalties of perjury, I declare that I have read the foregoing and that the facts stated in it are true and correct and that I have personal knowledge of the facts stated herein. Pursuant to 28 U.S.C. Section I 746, I declare under penalty of perjury that the foregoing is true and correct. By typing my name in the signature field below, I hereby affirm and manifest my intent to authenticate this writing as aut rized by the Electronic Signature Act of 1966, Florida Statutes, Chapter 668, Part I

Signed:

IMPORTANT: Please be sure to §hill on the line above and attach any relevant documents.

Thank you in advance for your submission.

414

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The UPS Store- Faribault 320 NW 41

h St Ste 200

Ph. 507.332.6772 Fax 507.332.6773

Fax Cover

To:

Date:

From:

Subject:

The UPS Store .. I I

# of Pages (including cover sheet): 3

If \'OU ar!' no! the inumder! :eciptel!!. de ll:JI disclose. copy, r/Jst:iou:~ at use th!S mlo:mali'Jn. If ycu recetverf ihJS rransmissior. in error, please Cd.'l 1mmo::1ia!ei)· :o

ar~angf return of :ne rfoccmenrs at no cos/ to you.

)3/03/11 lZ:::>Ul-'M t:.bT -) 1:-'~ "C. .I~v.l.a. l•ta.'-'•ulluo ... o ..., .......... """ ............ _ -c...o -· -

Phone: 977·793-5231 Fax: 407-442·0656

To: Patricia Macrunnels

Fa>e:5073328773

Re: Attention Patricia M.

From: TRAVEL BUY OWNER INC . .

Pages: 2

Date: March 03, 2011

Thank you for choosing Travel Buy Owner! Attached is the reg1strat1on form We also have a digital vo1ce receipt of the venf1cat1on dialogue on fi le for consumer protection Please s1gn and date then fax or ema11 the registration form immediately.

ThanK you

Compliance Department

Travel Buy Owner Inc. 8879 W Colontal Or Ocoee, Fl 34761 Toll Free·B??-783-5231 Fax·407 -442-0656 W#fl.tbopropert1es.com Email: info@tbopropert1es com PLEASE SIGN AND DATE BY ALL THE FOLLOWING ARROWS

TBO Properties, Ocoee, FL 34761

»This fax was sent v1a the Internet usmg Fax.coml - www fax com <<

PROPERTY ADVERTISING AGREEMENT www .tboproperties.com

info®tbopropartia1.c:om

OWNER( s) Name ......:.::M~•c:.:r..:.u:.:..:nn.:.:•:.:..:I•:........ ____ _:_P..:.a.::.tri:.::c:.::ia _____ _ -:-::-~--:---:-Lnt Fi111 Middle Initial

OWNER(s)Name~M~a~c~r=u~n~ne=I~•~--------~D~a~v~i=d ________________ ___

HOME ADDRESS 1705 Shumway Ave

CITY / STATE/ZIP ___:_:Fa:.:.rl:.:.ba:::u:.::lt ______ ___::M:.:.:..N;__ ___ 65_0,_21 __ _

E-MAILADDRESS [email protected]

DATE: 3/3/2011

DAY TIME PHONE: (507) 330-4571

CELL PHONE:

FAX#

(507) 332-6773

PROPERTY INFORMATION My Ll•tlng Search # (MLS #)l 19337990 ----------------Resort Name Avalon Reef

Resort Address Calle Zazii-Ha SIN, Zona 71slote El Yunque

City I State I Zip_:..:.l•l:..::.a:..:.M~uj:.:.:er..:..e'.:__ _ __ M:.:.:e:....x::_ic_o ___ 7_74_0D _______ _ Country --------Mex1co

Un1t #: E.J..I Week #: l Lockout: YES NO

Bedrooms: 1 Points :...: _ _ _ _ _

Usage : ~ Annual_/ _ Bi Annual Even Yrs _/ _ Odd Yrs Ma intenance: ---- ~Lease

Asking Rental Price : $ 1,500. 00// 2 Weeks Asking Selling Price : S 48,000.00

Tenu: 1. The undmlgned owner{s) granl(s) to Travel Buy Owner (TBO) permission to advertise this property on the Internet, and otherwise, also to make information regarding my property availablt to any poltntial buyers, rsnlm, and or others. 2. Owner(s) undmtandsthat TBO i• an independent ~ompany with no affiliation to any tlmuhar& ruort In anyway and does not negotiate ol!m on their behalf. TBO will forward any and all offers dlreclly to the owner so they ean negotiate the sale or rental of their unit themselves without the Involvement of any brokers, commissions or percentages deducted from agreed nlt/l'lnlal price. 3. Owner(s) maintain(e) full control of their property at all times. 4. Owner(n) has (have) the option lo either accept, decline or ntgolialt all offers. 5. OWntr'(s) understand(s) that advertisements run on 90 day cyeles. 8. TBO assumu that the unltlproperty Will rent Qf It rents), and/or sell (If II sells) within so days of aclvertlument agreement, unless owner advises TBO to the contrary, pr1or to the expiration of the 90 day period. Upon notl~eallon prior to expiration, TBO will nnew the ;ad at no charge until sold (if for sal a) or r~nted (if lorrenn 7. Owner( a) undmtand(s) that the advertising of the property has already begun and that the right of rescission Is 7 days from the date of agreement. 8. Owner(s) agree(s) to keep accurate contact Information up to date at all times w11h TBO and to nollt{ us as soon as poulble In the event of any changes. 8. Owne~s) understand(s) thalli Is their responsibility to view their ad(s) on our web aile and maktaure {hal it reflect• what they requested us to advertise, aa well at keep track of any changes or updates on our privacy/It~ and conditions. 10. 11we understand that the charge will appear on my credit card statement as Travel Buy owner. ,.1

I HHI CARD HOLDER /NfT/ALS -t. l y \. PAYMENT OPTION

I understand that the charge will appear on my credit card statement as Travel Buy owner and acknowledge that all Information is correct and have authorized Travel Buy Owner to charge my: MASTERCARD for the one (1) time non-recurring fee In the amount of: $11500.00 for advertising & document feel.

Credit Cllrd # """'*"'/*"'*"/****/1888

Patricia A. Macrunnels

Neme es eppeers on cerd

1705 Shumway Ave . Fanbault. MN. 55021

Bllltng Address

Card C:W# :._7'-'7..::.0 _ __ _

"OWNER SIGNATURE " OWNER SIGNATURE

.. -)

Cardmember Name: Patricia A Macr<Jnnels . Account Number: 5491043850351888

Merchant

TRAVEL BUY OWNER INC.

Posting Date

March 10, 2011

Type of Dispute: Poor Quality of Product or Services

Amount

$1500.00

We understand that you would like to dispute the above-noted transaction(s) . Please provide us with the following information:

What amount of the transaction(s) are you disputing due to the quality of the products/seNices?

$ 1-sex~ . .. . .. .. . . .I . ·--. . .. . .. - .. . . . -· .... .

On what day did you return the merchandise or cancel the seNice?

_:Jii.~If __ . . _ ... ... .. .. __ .. _ .. ___ --··-·-· __ Continued

= = ... --o _:l: =o = ::: --... =0 --o ="' = ... =o - ... -., = ....

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= "' -~ = =

Cardmember Name: Patricia A MecrunnE>Js Account Number: 5491043850351888

Type of Dispute: Poor Quality of Product or Services- Page 2

Our ability to help you with a claim of poor quality will be greatly affected by how well you can document your position. You can do this by providing a copy of a letter. from another reputable merchant or service provider supporting your claim. If the merchant caused damage, provide documentation that supports the cost of replacing merchandise. Also include copies of any related documents, such as sales slip, invoice, work order, or merchant response.

,.. i\ i ·. {\ \ i ·1, ~ .. ~ i . ' ... ·. :,

Signature: --~.-~\..._J --~d"-·1\\~,\ /) _________ .. ______________ .. __ Date: __ 1itl1J_l_ Best Phone Number to reach you: l5CL1.-l ____ 33;z._-_(ci~-.. -· ________ .. __________ _

Best time to reach you:

' ' ... L 9am to 12pm ET

____ 12pm to 5pm ET

____ After 5pm ET

--.



PLEASE COMPLETE AND RETURN SIGNED AFFIDAVIT AS SOON AS POSSIBLE TO:

By mail: Office of the Attorney General, Consumer Protection Division, Attn: Claudia Machado, 110 SE 6th St., lOth Floor, Ft. Lauderdale, FL 33301


CONSUMER AFFIDAVIT

. ~Jw{,' ~ NAME(Mr./Mrs./Ms.) .J{t~, JdtJn/eAr f DateofBirth ~l/1:;f9.f:'J ADDRESS ~ -S"r;.-1 L,fZ~It.J'jY£e na;t:~~ /II f{,7~ TELEPHONE: Home (~0(3) 2.2 5 -15 J 8 Work ( ) ____ Cell (~/JB 74/-'fZ,~ [)

E-MAIL 1Andttufi ,..,..qJ@hawaAI. rr-. (..om

Please specify: Are you 60 years old or older? __ Yes __ No

Are you disabled? ___:i_ Yes __ No ( /.e~o v;). tv- Ly) And who, after being duly sworn and deposed, upon his/her personal knowledge, states:

Iwouldliketofileacomplaintagainst: lt"'O.V~l ,By ownev, tNc.-· / . l

$6~q w. ~lot\rP) 'Pb--. f-/f.?i Oc..ou, FL st./7~ I . I fi\ (Please include: person/company name, address and telephone number) ~ ~ af/.lf!..c-lt1 t£J 0'

. fhy U46Vc--~

(example - internet, telephone, mail solicitation, · . ' . w: . feU' td«f-.

PLAINTIFF'S :; EXHIBIT ~ c__

Did you sign a contract or agreement with this company? Yes L No __ . ~ lfyes, please attach a copy of the contract

Prior to listing or advertising your timeshare for resale, did the company provide you with a description of fees or costs related to the advertising, listing or sale of your timeshare? Yes No _ _ . If yes, was the information provided to you in writing? Yes__ No

Whe:re: i); vourJ.im~s!Ia9! deeded? 1711-f'A<-- ~/l(..vu/ d/' M~· 1 ~~ .

Stvwf~qr ~ 4~1'1 1.4(,4-(%' ·t..f.mQa../?'ll'l4M ~~,II-, ft761 Were y~ told by a company representative that your timeshar~ has a specific retail value? Yes V No . Ifyes, what were you told was the value of your timeshare? $(1!, 1~0. ~.o

' Were you required to make a payment in excess of$75.00USD before signing a written contract/agreement? Yes ..L_ No _ _ . Ifyes, amount of payment:$ t:;oo. t>D Contract/Agreement Date: C)] lu_ / Zr?U Form of payment (please provide a COPY front and back of any checks, credhw([ money order, personal check or receipts that show this fee.

r~L4 ~ Vt&tt ... . Yf~~ ~~ ~t ~ 1''!Jkr~ tUvtrft~r0) fur-~ If yes, please attach a copy · X~~

What were you told the payment was for? a~ lrJJ & Mr &trfJp(J ~an fl...e- (; '.!:~-~() ts t>l/Y c.osl-~ ~ ow~>/

#/~ -h:~cPev, J;vz l» ~~fl\ !/.)I}UvV.t/rt' To f'~(&;.v '/dt4'6 lltprau.s:s"Wf ofkr£ rA~

Were you provided wit!l-a receipt or any documentation (contract, letter, agreement, etc.) confmning yo'J 1

_ / ,

payment(s)? Yes1 No __ . lfyes, pleaseattach copies. ~{..(,._..._ <:p~ /~It)

Were you informed of the company's Refund Policy? Yes ? No . If yes, ple~e in}iicat:te • terms of the refund policy as they were explained to you: S--;;;:1: ,ttr.--;Jty· /IAA..dlt:on .to #u--'-- ,._j-~"~ dwcif u..__ f>t~S lk-~ .~ ~-ft,q'Jdw- ,J..uAcia H4 h '/"'~ ~ h~ .lk ;u.-.U ~ J.;A drf,mf J ~bPfr2.ao 4d- ~d.et,,>tf-lll,.d ~(o ~ ·

Have you requested to cancel your contract/agpement? No __ . ~ J 1ft z::.L Date of ~~cylY:tiop reS!~est: /1'..(. V~ foul ~ . ~, +r~ J ~ m_ j.JtJ e p W'dT11/i/ ~ -f1t,c.. vrr S~ 6· ~~ fiW /etn ~ , 1J,.,..d IS ~ Didyourequestarefund? Yes~No _ _ . - ·. · ( If yes, did you receive a full or partial re~ Yes _ _ No _ _ . Y~CJ P-660/tt /-.<:-l'1 ntJf/;'"!J ~ If you received a refund, amount?$ i4- (./

2 14

Form in which cancellation was requested (email, certified letter, etc.): j ~ ~ ~ Please attach copies

Did you contact the company regarding your complaint? Yes£ No __ .

I lf so, state the name of the person you talked to and describe what representations were made?

U b:f./ JJ uJ/d ~ ~ ~ ~ Bwu.J'l ; &~hML:f/ ~~ ~~_.f.d_iA~s,/..._ ~ ).. /Q'()j? "1 f#lv<!flv-t;rf~/1....~ ~nil~ ~"''1/';y- d;(-;

covU_iLt4:_ ~ Va¥1 ~{f) d..h _kb;Wl\1 -f-Mc Wn .. .tu-.....,@ ~~~ ~om~:y ever indicate to you tha: ~ere w/ as a buyer~enter waiting to b~/rent you~ timeshare?

If yes, what did the company tell you? /VI!j ~f @~ L.~ ~Jya- /t11-/ltr. J 11114 ~:J ~/ ~ it- "J"h> r/.j

..,.,.._._ ~ t.AHt ~ ida IW-d ~(J lnfrr-'<r/J '"' try ft!...u/.~~-vz M- ,; ~ br£;(;w,.. ~t:.$1"'0 ~

Were any represen2ns, guarantees or promises made to you regarding the sale/rel)t~ of~)' n __ -r timeshare? Yes No If yes, what were you told? tJ ~ ~41' ~

f:j k-£ "-~ ~ lk£ L~ ,__ ~ocr 1 rd.G 3'/o ~ 1/ .;u bi(jfr lzuA-~ :h/; fv,... ~ ~ f.t..t-ft,3<fo

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~ /rt ~ ~n tU-<L J'W~5

The above listed documents included along with this Affidavit, are a true esentation of all -h 4- (} /'tid~ documents submitted by me, which support my complaint. I /fA.( .Y -

FURTHER AFFIANT SAYETHNAUGHT. df" if:!±··;, < ,~'$

I • f"" > My signature authorizes the Attorney General's Office to take any action deemed necessary for purposes ,P tpyd 'rt€.--of investigation or enforcement. I understand that the Attorney General does not represent private citizens seeking the return of their money or other personal remedies. I am filing this complaint to notify your office of the activities of this company so that it may be determined if law enforcement or legal action is warranted.

Pursuant to Florida Statutes Section 92.525, under penalties of perjury, I declare that I have read the foregoing and that the facts stated in it are true and correct and that I have personal knowledge of the facts stated herein. Pursuant to 28 U.S.C. Section 1746, I declare under penalty of perjury that the foregoing is true and correct. By typing my name in the signature field below, I hereby affirm and manifest my intent to authenticate this writing as authorized by the Electronic Signature Act of 1966, Florida Statutes,

Chapter 668, Part I. _ ;-jh _:!__ (___(', Signed: ~M--£"'i./ &__ ~- Dated: wtf/"t.IJ/..:3

I

IMPORTANT: Please be sure to sign on the line above and attach any relevant documents.


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PROPERTY ADVERTISING AGREEMENT www.tboproperties.com

[email protected]

MAIUNG ADDRESS TRAVEL BUY OWNER, INC

8879W Cofonifl Dr, #123 Ocoee, FL 34761

(an) 763-5231 fax (407) 442..0656

DATE: 7/21/2011

OWNER(s) Name Gandauli Monica 'P. DAY TIME PHONE: Last First Middle lniUal (!. (808) 741-9730

OWNER(s) Name 6ft111PA-U L.l (.~fl. I:' L- [;. CELL PHONE:

HOME ADDRESS 45· 521 Loihl St. ~: (808) 235·1518

CITY /STATE/ZIP Kaneohe HI 96744 fAX#

E-MAIL ADDRESS [email protected] ------=-------------~----------------------

PROPERTY INFORMATION My Listing Search# (MLS #): 1966680 --------------Resort Name Sands of Kahana

Resort Address 4299 Lower Honoapiilani Hwy

City I State I Zip Maui HI 96761 Country USA ------------------------------------------- ---------------Unit#: fli Week#: FLT

Bedrooms: 2

Usage:~ Annual_/ __ BiAnnual

Asking Rental Price: $ 1,000.00

Lockout: ___ YES X NO

Points: _______ _

Even Yrs _/ _ Odd Yrs Maintenance: $1,000.00 X DEEDED

Asking Selling Price: $ 31,700.00

T enns: 1. The undersigned owner(s) grant(s) to Travel Buy Owner (TBO) pennlsslon to advertise this property on thelntamet, and otherwise, also to make Information regarding my property available to any potential buyers, renters, and or others. 2. Owner(s) understands that TBO Is an lndtpendent company with no affiliation to any timeshare resort In any way and does not negotiate offers on their behalf. TBO will forward any and all offers directly to the owner so they can negotiate the sale or rental of their unit themselves without the involvement of any brok81'5, commissions or peccentages deducted from agreed sale/rental price. 3. Owner(s) malntaln(s) full control of their property at all times. 4. Owner(s) has (have) the optlon to either accept, decline or negotiate all offers. 5. Owners(s) understand(s) that advertisements run on 90 day cycl85. 6. TBO assumes that the unit/property will rent Qf It rents), and/Of' sell Of It sells) within 90 days of advertisement agreement, unless owner advises TBO to the contrary, prior to the expiration of the 90 day period. Upon notification prior to expiration, TBO will renew the ad at no charge untH sold (tf for sale) or rented (If for rant). 7. Owner(s) understand(s) that the advertising of the property has already begun and that the rtght of rescission is 7 days from the date of agreement 8. Owner(s) agree(s) to keep aceurate contact Information up to date at all times with TBO and to noUfy us as soon as possible In the event of any changes. 9. Owner(s) unclerstand(s) that It Is their responsibility to view their ad(s) on our web site and make sure that It reflects what they requested us to advertise, as wall as keep track of any changes or updates on our privacy/terms and conditions. 1 0.1/we understand that the charge will appear on my credit card statement as CFL Ventures, Inc. ___..._

I '**** CARD HOLDER INITIALS ~ n PAYMENT OPTION

I understand that the charge will appear on my credit card statement as CFL Ventures, Inc. and acknowledge that all Information Is correct and have authorized CFL Ventures, Inc. to charge my: VISA for the one (1) time non-recurring fee in the amount of: $1,500.00 for advertising & document fees.

Credit card # ****/****/****/1904

Monica P. Gandauli

Name as appears on card

45-521 Loihi St. , Kaneohe, HI, 96744

Billing Address

Card CVV#,_: 4""'3""'3 _ __ _

A CARD HOLDER SIGNATURE A Date

~~·

FAX COVER SHEET

TO: TRAVEL BUY OWNER INC. DATE: JULY 26, 2011

ATTN: GREGORY MADISON

FAX#: 1-407 -442-Q656 .

---------·-------··*-""·----------------------~------------------~---------------------------·--------._ ____________ _

FROM: MONICA GANDAULI

PHONE#: 808-235-1518

FAX#:

There are _Q£_ pages including this cover page.

COMMENTS: MR. MADISON, THE REGISTRATION DOCUMENT AS YOU CALLED IT.

BEFORE CHARGING MY CARD, IWILL NEED TO KNOW WHEN THIS WILL TAKE PLACE.

I ALSO UNDERSTAND THAT THIS IS A ONE TIME PAYMENT WHICH INCLUDES ALL DOCUMENT FEES IF MY TIMESHARE IS SOLD AND/OR RENTED, AND THERE WILL BE NO HIDED COST TO SURPRISE ME WITH.

AM I CORRECT?

IF I AM WRONG CAN YOU PLEASE CALL ME TO LET ME KNOW AND UNDERSTAND THESE STEPS CORRECTLY BEFORE CHARGING MY CARD.

ONE MORE QUESTION. DO YOU NEED THE ORIGINAL COPY? OR IS THIS FAXED COPY ENOUGH? PLEASE CALL ME. 808-741-9730/808-235-1518

THANK YOU,

MONICA GANDAULI -- ~vi ht\

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F;om: "TBO Customer Service" <[email protected]> SU·lject: Agreement from Travel Buy Owner

l >..ite: July 26, 2011 11 :20:50 AM HST To: "Monica GandauiP' <gandaulim001 @hawaii.rr.com>

1 Attachment, 207 KB

Attached is everything that was discussed on the telephone. We also have a digital voice receipt of the verification dialogue on file.

Please print, review, sign, and fax or email the document back as soon as possible.

Thank you.

Verification Department

Travel Buy Owner Inc.

8879 W. Colonial Dr.

Ocoee, Fl. 34761

877-783-5231

www .tboproperties.com

Email: [email protected]

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PROPERTY ADVERTISING AGREEMENT lwww.~bo~ro~~ies.coml

l igfo tbo)og i .coml

MAILING ADDRESS TRAVEL BUY OWNER, INC

8879 W Cdonial Or, #123 Ocoee, FL 34761

(Bn) 783-5231 fax (407) 442.0656

OWNER(s) Name Gandauli Lasl

OWNER(s) Name

HOME ADDRESS 45.521

--··-·- ·--- ' ' · ••• t .• .

Monica Fhs1

Loihi St.

Middle lnllial

DATE: 7/21/2011

DAYTIME PHONE: (808) 7 41·9730

CELL PHONE:

(808) 235-1518

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1..

r. Gregory Madison calls me while I was visiting in Fargo North Dakota. Say's He has a buyer for my timeshare in Maui, Sands of Kahana. He said alot, like nwe have an immediate buyer, but to start the paperwork, which takes time to be sign and documented we need the 1 time fee of $1500.00. This was mid July, 2011. I spoke with my husband, I looked Travel by Owner up on the internet. At this time there was no bad things said about TBO. I returned home to find email from Mr. Gregory Madison. Property Advertising Agreement. I called TBO he said it reads that it is for advertising but that is only legality. The $1500 is also for document fees, and all paperwork and advertising that it would take to sell the timeshare. On July 26, 2011 I signed the agreement and I also faxed him some questions, which he never responded to. I would call 2 to 4 times a week. On 9/29/2011 Diane of customer service calls me, telling me that the next step the paper work has been sent through to the buyers-they must return it to TBO then TBO will send me to sign, and I must mail it back and they will send the check! What Check Thinking that we should be closing. I spoke with customer service Denise Torres Supervisor ph. no. 1-877-783-5231 ext, 7009. On 11/28/2011@ 10:00 a.m. pacific Time I rec'd a phone call telling me that someone will be calling me within 24 hours. 24 hours came and went. There was no call on 11/29/2011 I called after 10 a.m. the respeatlafter then a few days later I called her again and was told that she is no longer there, she was on maternity. I asked for Sharlene Brown, management who also ext. 7009, I spoke with on 11/09/2011, she picked up the phone, and told me they had no comments from the buyers-due to they have an outstanding tax lein. and until they get it cleared up there is nothing that can be done . I asked for my money back. She said it will take 30 business days. It had past the dead line. She again said there is nothing she can do, but she will put in the request today, (Nov. 30, 2011) . I called again and again and all they said was I will put a note on my file Gregory Madison who kept avoiding my calls had extension # 8004, Sharlene Brown- who was



PLEASE COMPLETE AND RETURN SIGNED AFFIDAVIT AS SOON AS POSSIDLE TO:

By mail: Office of the Attorney General, Consumer Protection Division, Attn: Claudia Machado, 110 SE 6th St., 1om Floor, Ft. Lauderdale, FL 33301


CONSUMER AFFIDAVIT

NAME (Mr~~))/Ms.) /j{:.C.t\.fr/4. U CeR.f'/f;(. Date of Birth tJ~/95q "'I -1:::' r,- . (Pri t or type name , .

1

ADDRESS (){ . 3 r---A R R..P. N..b r ENR. c.D VI TELEPHONE: Home~()~ ) {).36 -Jd.K5 Work &Jf)CJK/- 0){) Cell(o~ ~ _, a/94-E-MAIL b rwcl & Q .R&tl=~ Cbmcccl-.. Nd-Please specify: Are you 60 years old or older? __ Yes J{}_ No

Are you disabled? __ Yes _j{}_ No

And who, after being duly sworn and deposed, upon his/her personal knowledge, states:

I would like to file a complaint against: JR A vel ~ {)lQfl £R_ --r,h('_ ' (Please include: person/company name, address and telephone number)

Did you accept the service(s)? Yes ·~ No _ .

)

Did you sign a contract or agreement with this company? Yes I No __ .


Prior to listing or advertising your timeshare for resale, did the company provide you with a <\_e~ription of fees or costs related to the advertising, listing or sale of your timesL Yes__ No~. If yes, was the information provided to you in writing? Yes__ No .

Where ,, your timeshare deeded? w o sigttl dh ~ li/,lftkwRd . . n Ov.:YDD. ~L 3;Lf/ q

Were you told by ,XJcompany representative that your timeshare as asp cific retru.l value? I Yes No . j ·a oO If yes, what were you told was the value of your timeshare?$~ ja2 .

Were you required to~ment in excess of$75.00USD before signing a wri~l) contract/agreement?~ o . Ifyes, amount of payment:$ Jt)DQ Contract/Agreement Date: · Form of payment (please provide a COPY front and back of any checks, credit c d, oney order, personal check or receipts that show this fee.

If yes, please attach a copy

\_ Were you provided with a recex or any documentation (contract, letter, agreement, etc.) confirming your payment(s)? Yes __ No . lfyes,please attach copies.

No JO. If yes, please indicate the

Have you requested to cancel y· ~-".::·RAu•

Date of cancellation request: 4:.:.1-t--!-L1i.L¥-...rL.Lr-.w;...._:...t..--=~,.....~

Did you request a refund? Yes_· _ _ No __ . If yes, did you receive a full or partial refund? Yes If you received a refund, amount? $ _ _ -1({)hl----

2 14

Form in which cancellation was requested (email, certified letter, etc.): k~ Q Ocrrl ~.._J) "'Ptease attach copies

Did you contact the company regarding your complaint? Yes _k2_ No __ . If so, state the name of the person you talked to and describe what representations were made?

1;)-16 ~doll RQ!l C!J.iutv~h.2~o w--z:L&.~£Vlt-L~xlo/ ht ~~/!M;f· j4lR)G 0 -J

} ~ 7 -&()/~ aLv- ~k:ruJ-hiC/iitJJ ~ tHvi;.l fl~~~ · J'l~cJo~~2fl!!f4~J~~]Ad~fol~.t =t?Jb&pa:w-~~~~':'""''~um~ Did tqo/Pompany ever indicate to you that there was a buyer7renter waiting to buy/rent your timeshare?~ Yes...l!¥'_ No ·· · If yes, what did the company tell you? ~ b./r --lt_. r-IIJJ I,.-

!L.~J.L ---h ru butJ-eA I0CW f'Jw O.£r1

Were any representations, guarantees or promises made to you regarding the sale/rental of your timeshare? Yes No Ifyes, what were you told? ______ _ -:---+J~---

Clearly and in detail, please state your complaint describing events in which they occurred, including the dates, times, and names of individuals with whom you had any contact with. Describe in as much detail

as possible any statements made to you or events which occurred, that you would deem as deceptive,

misleading or unfair. - ------ ----------- -------

~--~ .... __., Please list below and attach any documents in support of your complaint. By signing below, you are certifying that these documents are true and correct copies of the originals. ----------

The above listed documents included along with this Affidavit, are a true representation of all documents submitted by me, which support my complaint.


My signature authorizes the Attorney General's Office to take any action deemed necessary for purposes of investigation or enforcement. I understand that the Attorney General does not represent private citizens seeking the return of their money or other personal remedies. I am filing this complaint to notify your office of the activities of this company so that it may be determined if law enforcement or legal action is warranted.

Pursuant to Florida Statutes Section 92.525, under penalties of perjury, I declare that I have read the foregoing and that the facts stated in it are true and correct and that I have personal knowledge of the facts stated herein. Pursuant to 28 U.S.C. Section 1746, I declare under penalty of perjury that the foregoing is true and correct. By typing my name in the signature field below, I hereby affirm and manifest my intent to authenticate this writing as authorized by the Electronic Signature Act of 1966, Florida Statutes, Chapter 668, Part I. j

Signed: ~!wa:J.{jf22PvWJ Dated: D2 Jfo/0XJ!j IMPORTANT: Please be sure to sirm on the line above and attach any relevant documents.


4 14

Brenda Craner

From: Brenda Craner Sent: To: Cc:

Friday, September 07, 2012 4:02 PM '[email protected]' '[email protected]'

Subject: FW: COPY: Consumer Contacted You via The BBB Website

Follow Up Flag: Flag Status:

Follow up Flagged

I have not gotten a response from my e-mail or voice messages I have left. Could someone please contact me? 804-852-2194 or 804-236-2285

From: Brenda Craner Sent: Thursday, August 30, 2012 1:56 PM To: '[email protected]' Subject: PN: COPY: Consumer Contacted You via The BBB Website

From: BBB Website [tnailto:[email protected] Sent: Thursday, August 30, 2012 11:56 AM To: ~tboproperties.com; Brenda Craner Subject: COPY: Consumer Contacted You via The BBB Website

The following email was sent on your behalf:

Email: [email protected] Phone: 804-852-2194 Please let me know the status of my time share sale. The buyer paid the lien off and I should have gotten paper work 3rd week of August? I signed agreement with you in Nov 2011 . Should I hire a Lawyer to review to review your documents for this sale. I would like to speak to Allen Santana.

1

Brenda Craner

From: Sent: To:

Subject:

Importance:

Brenda Craner Thursday, August 30, 2012 11:39 AM '[email protected]' Agreement Nov 2011

High

Can you give me my status on where it stands please?

Phone 804-852-2194

Thank You Brenda Craner

Ebiz Speciafist 804-281-1320

1

Brenda Craner

From: Brenda Craner Sent: To:

Thursday, August 30, 2012 1:54 PM '[email protected]'

Subject: FW: Agreement Nov 2011

Importance: High

From: Brenda Craner Sent : Thursday, August 30, 2012 11:39 AM To: '[email protected]' · Subject: Agreement Nov.201l Importance: High

Can you give me my status on where it stands please?

Phone 804-852-2194

Thank You Brenda Craner Ebiz Specialist 804-281-1320

1

Brenda Craner

From: Brenda Craner Sent: To:

Thursday, August 30, 2012 1:56 PM '[email protected]'

Subject: FW: COPY: Consumer Contacted You via The BBB Website

From: BBB Website [mailto:[email protected] Sent: Thursday, August 30, 2012 11:56 AM To: [email protected]; Brenda Craner Subject: COPY: Consumer Contacted You via The BBB Website

The following email was sent on your behalf:

Email: [email protected] Phone: 804-852-2194 Please let me know the status of my time share sale. The buyer paid the lien off and I should have gotten paper work 3rd week of August? I signed agreement with you in Nov 2011. Should I hire a Lawyer to review to review your documents for this sale. I would like to speak to Allen Santana.

1

Brenda Craner

From: Sent: To:

[email protected] Thursday, August 30, 2012 11:32 AM Brenda Craner

Subject: Attachments:

Fwd: Agreement From Travel Buy Owner Brenda J. Craner.pdf

From: "Brenda Craner" <[email protected]> To: [email protected] Sent: Monday, August 20, 2012 9:32:08 AM Subject: FW: Agreement From Travel Buy Owner

From:· [email protected] [ mailto: [email protected]] Sent: Sunday, November 06, 2011 8:31AM To: Brenda Craner Subject: Fwd: Agreement From Travel Buy Owner

From: "Customer Service" <[email protected]> To: "Brenda J . Craner" <[email protected]> Sent: Friday, November 4, 2011 2:30:10 PM Subject: Agreement From Travel Buy Owner

Attached is everything that was discussed on the telephone. We also have a digital voice receipt of the verification dialogue on file.

Please print, review, sign, and fax or email the document back as soon as possible.

I Thank you.

Verification Department

Travel Buy Owner Inc.

8879 W. Colonial Dr.

Ocoee, Fl. 34761

877-783-5231

www. tboproperties.com

Email: [email protected] 1

PROPERTY ADVERTISING AGREEMENT MAILING ADDRESS TRAVEL BUY OWNER, INC

8879 W Colonial Dr, #123 Ocoee, FL 34761 www.tbo prooerties.com

[email protected]

OWNER(s) Name Craner Brenda -----------------------------------------------Last First Middle Initial

OWNER(s)Name __________________________________________ ___

HOME ADDRESS 2333 Farrand Dr.

CITY /STATE/ZIP Richmond VA 23231 -----------------------------------------------E-MAIL ADDRESS [email protected]

(8n) 783-5231

fax (407) 442-0656

DATE: 11/4/2011


CELL PHONE:

(804) 852-2194

FAX#

PROPERTY INFORMATION My Listing Search # (MLS #): 19927047 -----------------Resort Name Westgate Lake

Resort Address 10000 Turkey Lake Road,

City I State I Zip Orlando FL 32819 ------------------------------------------------- Country:.._ _______ u_s_A ____ _

Unit#: Week#: FLT

Bedrooms: 2

Usage: _Annual/~ BiAnnual

Asking Rental Price: $

X

Lockout: YES NO

Points;_: ______ _

Even Yr~- Odd Yrs Maintenance: $600.00 ~DEEDED

Asking Selling Price: $ 15,900.00

Terms: 1. The undersigned owner(s) grant(s) to Travel Buy Owner (TBO) permission to advertise this property on the internet, and otherwise, also to make information regarding my property available to any potential buyers, renters, and or others. 2. Owner(s) understands that TBO is an Independent company with no affiliation to any timeshare resort in any way and does not negotiate offers on their behalf. TBO will forward any and all offers directly to the owner so they can negotiate the safe or rental of their unit themselves without the involvement of any brokers, commissions or percentages deducted from agreed sale/rental price. 3. Owner(s) maintain(s) full control of their property at all times. 4. Owner(s) has (have) the option to either accept, decline or negotiate all offers. 5. Owners(s) understand(s) that advertisements run on 90 day cycles. 6. TBO assumes that the uniUproperty will rent Qf It rents), and/or sell (if it sells) within 90 days of advertisement agreement, unless owner advises TBO to the contrary, prior to the expiration of the 90 day period. Upon notification prior to expiration, TBO will renew the ad at no charge until sold (if for sale) or rented (if for rent). 7. Owner(s) understand(s) that the advertising of the property has already begun and that the right of rescission is 7 days from the date of agreement 8. Owner(s) agree(s) to keep a~curate contact information up to date at all times with TBO and to notify us as soon as possible in the event of any changes. 9. Owner(s) understand(s) that it is their responsibility to view their ad(s) on our web site and make sure that it reflects what they requested us to advertise, as well as keep track of any changes or updates on our privacy/terms and conditions. 10.1/we understand that the charge will appear on my credit card statement as CFL Ventures, Inc. -.....

I ***** CARD HOLDER INITIALS ....,.:;

PAYMENT OPTION

I understand that the charge will appear on my credit card statement as CFL Ventures, Inc. and acknowledge that all information is correct and have authorized CFL Ventures, Inc. to charge my: VISA for the one (1) time non-recurring fee in the amount of: $1 ,500.00 for advertising & document fees.

Card CW#:..: -"6-'-'40"--------

Credit Card # ****/****1****/9065 Expiration Date 02/ 1 3

Brenda J. Craner --------------------.. ..

Name as appears on card /\ CARD HOLDER SIGNATURE A Date

2333 Farrand Dr. , Richmond, VA, 23231

Billing Address AOWNER SIGNATURE /\OWNER SIGNATURE

STATE OF FLORIDA OFFICE OF THE ATIORNEY GENERAL PAM BONDI

In re: Travel by Owner, INC.

PLEASE CQMPLETE AND RETURN SIGNED AFF1DA VIT AS SOON AS POSSmLE TO:

By mail:

By email:

Please specify:

Office of the Attorney General, Consumer Protection Division, Attn: Claudia Machado, 110 SE 6th St., lOth Floor, Ft Lauderdale, FL 33301

[email protected]

CONSUMER AFFIDAVIT

Are you 60 years old or older? _6,_ Yes _ _ No

Are you disabled? _ _ Yes _x_ No

And who, after being duly sworn and deposed, upon his/her persona] knowledge, states:

I would like to file a complaint against:~~ ~ ~ 1

(Please il'lclu.de: personlcomp411y nmne, address (llfd teJepho11e number)

PLAINTIFF'S 11 EXHIBIT

~ - -----""'E=-- -

Did you sign a contract or agreement with this company? Yes_){_ No _ _ .


Prior to listing or advertising your timeshare for resale, did the company provide you with a description of fees or costs related to the advertising, listing or sale of your timeshare? . Yes Jc_ No __ . If yes, was the information provided to you in writing? Yes _X_ No __ .

Where is your timeshare deeded? 9 / '5 U.J~,j; r?~oJf. J2J J/~ JN 371~ '?.

Were ~9u told by a company representative that your timeshare has a specific retail value? Yes....& No . _, If yes, what were you told was the value of your timeshare?$ { 5, tP C?O

I Were you required to make a P.ayment in excess of$75.00USD before signing a written contract/agreement? Yes X No __ . Ifyes,'amount of payment:$ l5() 0 Contract/Agreement Date: I B- ;;; 7- ..?o 10 Form of payment (please provide a COPY front and back of any checks, credit card, money order, personal check or receipts that show this fee.

d&tDaaAtitkdk~~ ~/ ~ What were you told the payment was for?------- -------------

Were you provided with a receipt or any documentation (contract, letter, agreement, etc.) confirming your payment(s)? Yes__ No+· If yes, please attach copies.

Were you informed of the company's Refund Policy? Yes__ No -X-· lfyes, please indicate the terms of the refund policy as they were explained to you:----------------

Have you requested to cancel your <:hn:~c~feement? Yes~ No __ . Date of cancellation request: ~ '!Jzhc!.k, ~ 1..-(J...t..

Didy~nG~No __ . If yes, did you receive a full or partial refund? Yes __ No _K_. If you received a refund, amount? $ ______ _

21 -

~(}AL~J~~~1~ ~~~- - -

In order to resolve this complaint I request (example: ~cellation of contract, etc.): t?2.. -cJit 4~~&~ Please list below and attach any documents in support of your complaint. By signing below, you are certifying that these documents are true and correct copies of the originals. ----------

~ w.JLit., t, \"~ ~ ~ ·o/fiu_.__, i-u ~o to ,

The above listed documents included along with this Affidavit, are a true representation of all documents submitted by me, which support my complainL


My signature authorizes the Attorney General's Office to take any action deemed necessary for purposes of investigation or enforcement. I understand that the Attorney General does not represent private citizens seeking the return of their money or other personal remedies. I am filing this complaint to notify your office of the activities of this company so that it may be determined iflaw enforcement or legal action is warranted.

Pursuant to Florida Statutes Section 92.525, under penalties of perjury, I declare that I have read the foregoing and that the facts stated in it are true and correct and that I have personal knowledge of the facts stated herein. Pursuant to 28 U.S.C. Section 1746, I declare under penalty of perjury that the foregoing is true and correct. By typing my name in the signature field below, I hereby affirm and manifest my intent to authenticate this writing as authorized by the Electronic Signature Act of I 966, Florida Statutes, Chapter 668, Part I.

Signed: Dated: I'- .2j- I 5

IMPORT Please be sure to sien on the line above and attach any relevant documents.


4 1 ·~

u RENAISSANCE.

WASHINGrON, DC HOTEL --./.~~:__ ___ _ 999 9th Street, NWWashlngton, DC 20001

Telephone 202-898-9000 www.dcrenaissancc.com

PROPERTY ADVERTISING AGREEMENT MAI..WGAODAESS

TRAVB..BUVOWNER,INC 8879 w CG::will Dr • .t123 ~. Fl34M1

OWNER(s) Name

OWNER(s) Name

HOME ADORESS

CITY/STATE/ZIP

Beebe lMt

Beebe

www.tbopmoerties.cpm ,..., ,.,..Pep mm

Yvonne R. Fnt Mitle lrili3l

Ja~

24416 County Ro8d 4

NistWI MN 56468

E-MAIL ADDRESS jb1180comcast.net ----~~--~~--~~--~-----------------

(tl77) 783-5231 fax (407) 442-0156

DATE: 1212712010


CELL PHONE:

(211) 963s1750

FAX#

PROPERTY INFORMATION My U.tlng S..rch II (MLS tl) : 19199019 -------------Resort Name w...-Smoky llounblin Raort

Resort Address 915 Westgate Rnort1 Road

37138 r""~ USA aty I State I Zip Galdug ------~-----------------------------------

.......,.,.., .. ., ______ _ Unit#: EL.I Week#:~ Lockout: YES NO Bedrooms: 1 Points:.:..: ____ _

usage: Annual/_ e; Annual Even Yrs/_Odd Yrs Mainl2tlance: $500.00 X DEEDED

Asking Rental Price : $ 1,500.00 II 2 weeks Asking Selling Price: $ 15,800.00

Tams: 1. The llid&iO_. Ollnl(s) ~s} _, T rMII a.. 0.. (TBO) permitsil:rl ki8CMitile llis ~an lie n.net, IIIII alwwlle, * kl,., ilcxxliiillc:tl llllgllding II¥ fii'IIPII1YMiallle IDq....,.. ~ fti'IBI, IIIII« ohn. 2. Oilnel(s) wid&s&idilhllllJOis ~ ildeplldelt~ Wflno lillian klq liAesl1n ~;n ..,.y Sid does ra ~oilers an h*belrttf. T80 .. , i:lrwMf tnt a al c6ls ~ ID lhe OIIIM' *' h!y <*~ ~ lhe s* «nml d thlir lri 'fiOins<Ms lllitW1he illldwluee• d tnt t~Wrs. tuiiiissia"ts « pe~oedlgeS deduded 11om ageed Silltilalllll pice. 3. Olnl(s) ltilli"Mi(s) U ~ d lhei' pqld1y • al fines. 4. Olnrr(s) tas (~~ewe) lle qJbt kleiller ~ decfne« ReP* alollees. 5. OIIIM!(s) ~s) ltlll ~ ,...CI190 drly qdes. 6. TBO esunes lhll1he wilfptp::oty IIIII ldil (if. rents), S'dor sel (it. sels) Mtin !Kl d¥ d IIMrisemen ageema-.lriess a.w ar:Mses TBO ID lle cxray, pld IDh ~ cllleOO diJi period.~ 1~1 prior 1D .-.,, TBOwl ~ llead et no d\llge 11'1111 d:i (liar-) «....eel 'lor ret}. 1. Onl(s) IIKbs&4&) hit fleacM:iliiiiUdfle papa1y ,_ .. bepSid hit fle r9i ol ~is 7 days ian fled* d agleeiMIIt. l o.ns(s}.-<s) ID llel!p ~~:laMe GU'IIIItt ilea••••"" ID dele • al nes 1liltl TBO a ID rdfr us • toan as pol!tie illle ewn d tnt a-ves. 9. Olnr(s) uDnta_.,) hill is ,_....,......, IDW.,...al(s) 111 cuwmsile IIIII IIIIRSIIIt hftr*3 .,.~her ~us IDalwdse, • _. akeep!AI:td "'fc:lwQ!s«~ 111 cu pitra:ffaa•n tudians. 10. Wille Uidti:o111~ hit u.e ~ wii!Aidl' an rffl aecit cad s~aternen~• Tnwel a.. Owner.

PAJMENJ OPTION

I IMcleililtaMIIhat lhe c:hat'ge will appear on my ctedit card JJtatement a. Trlll¥d Buy Owner and adutowCedge tflat all Information Is correct and have authorized Travel Buy Owner to charge my: VISA for the one ( 1) time non-recurring fee In the amount of: $1,500,00 for advertising a document fees.

O'edit Card # ****/****/****/3733 Yvonne R. Beebe

Name as appears on card

24486 County Road 4, Nisswa, MN, 56468

card CVVII:....: ..:..:17'-'·----Expiration Date 01/11

/) ----'-- - ------ijh-nHaiC ~ I .. J ..... CARD HOI..DER SIGNATURE A

/[_ ~ "OWNER SIGNATURE

of 1

From: "Customer Service" <[email protected]> To: "Yvonne Beebe" <[email protected]> Sent: Tuesday, December 28, 2010 1:20PM Attach: Yvonne Beebe.pdf Subject: Agreement from Travel Buy Owner

Thank you for choosing Travel Buy Owner! Attached is the registration form. We also have a

digital voice receipt of the verification dialogue on file for consumer protection. Please sign and

date then fax or email the registration form immediately.

Thank: you.


Travel Buv Owner Inc. 8879 W. Colonial Dr. Ocoee, Fl. 34761 Toll Free:877-783-5231 Fax:407-442-0656 www.tboproperties.com Email: [email protected]

12/28/2010

of I

From: "Customer Service" <[email protected]> To: "Yvonne Beebe" <[email protected]> Sent: Tuesday, December 28, 2010 1:20PM Attach: Yvonne Beebe.pdf Subject: Agreement from Travel Buy Owner

Thank you for choosing Travel Buy Owner! Attached is the registration form. We also have a

digital voice receipt of the verification dialogue on file for consumer protection. Please sign and

date then fax or email the registration form immediately.

Thank you.


Travel Buv Owner Inc. 8879 W. Colonial Dr. Ocoee, Fl. 34761 Toll Free:877-783-5231 Fax:407-442-0656 www.tboproperties.com Email: [email protected]

12/28/2010

defendants. - florida attorney generalfile/travel+buy+owner+complaint.pdf · 11. defendant travel...

Documents