joshua s. millard, brian m. welke, pro hac vice · for which it has no legitimate claim. noel is a...

57
Case 8:18-cv-01987-JLS-KES Document 50-1 Filed 02/05/19 Page 1 of 57 Page ID 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 #:1760 ALDEN F. ABBOTT General Counsel JOSHUA S. MILLARD, pro hac vice [email protected] BRIAN M. WELKE, pro hac vice [email protected] FEDERAL TRADE COMMISSION 600 Pennsylvania Ave., N.W., CC-9528 Washington, D.C. 20580 Tel: (202) 326-2454, -2897; Fax: (202) 326-3197 BARBARA CHUN, Local Counsel, Cal. Bar. No. 186907 [email protected] FEDERAL TRADE COMMISSION 10990 Wilshire Blvd., Suite 400 Los Angeles, CA 90024 Tel: (310) 824-4312; Fax: (310) 824-4380 Attorneys for Plaintiff UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA FEDERAL TRADE COMMISSION, Plaintiff, v. IMPETUS ENTERPRISE, INC., a California corporation, also d/b/a Aiding Student Relief, Aiding Students & Teachers, Aidnest, Avec Staffing, National Education Student and Teacher, Studora, and U.S. Debt Relief; FIG TREE & CO., LLC, a California limited liability company, also d/b/a Aiding Student Relief, Aiding Students 1 Case No. 8:18-cv-01987-JLS-KES FIRST AMENDED COMPLAINT FOR PERMANENT INJUNCTION AND OTHER EQUITABLE RELIEF Attachment A

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Page 1: JOSHUA S. MILLARD, BRIAN M. WELKE, pro hac vice · for which it has no legitimate claim. Noel is a Wyoming limited liability company that reported in a public document that its principal

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 1 of 57 Page ID

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1760

ALDEN F ABBOTT General Counsel JOSHUA S MILLARD pro hac vice jmillardftcgov BRIAN M WELKE pro hac vice bwelkeftcgov FEDERAL TRADE COMMISSION 600 Pennsylvania Ave NW CC-9528 Washington DC 20580 Tel (202) 326-2454 -2897 Fax (202) 326-3197 BARBARA CHUN Local Counsel Cal Bar No 186907 bchunftcgov FEDERAL TRADE COMMISSION 10990 Wilshire Blvd Suite 400 Los Angeles CA 90024 Tel (310) 824-4312 Fax (310) 824-4380 Attorneys for Plaintiff

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA

FEDERAL TRADE COMMISSION

Plaintiff

v

IMPETUS ENTERPRISE INC a California corporation also dba Aiding Student Relief Aiding Students amp Teachers Aidnest Avec Staffing National Education Student and Teacher Studora and US Debt Relief FIG TREE amp CO LLC a California limited liability company also dba Aiding Student Relief Aiding Students

1

Case No 818-cv-01987-JLS-KES

FIRST AMENDED COMPLAINT FOR PERMANENT INJUNCTION AND OTHER EQUITABLE RELIEF

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 2 of 57 Page ID

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1761

amp Teacher and Aiding Students amp Teachers CAPITAL SUN INVESTMENTS LLC a Wyoming limited liability company also dba Studora TUAN DINH DUONG aka Thomas Duong aka Thomas Dinh individually and as an officer of IMPETUS ENTERPRISE INC BRENDA AVITIA-PENA individually and as an officer of IMPETUS ENTEPRISE INC and FIG TREE amp CO LLC BRIAN COLOMBANA dba FUTERO individually and as an officer of FIG TREE amp CO LLC and JIMMY CALDERON individually and as an officer of CAPITAL SUN INVESTMENTS LLC

Defendants and

NOEL SOLUTIONS LLC a Wyoming limited liability company

Relief Defendant

Plaintiff the Federal Trade Commission (ldquoFTCrdquo) for its Complaint alleges

1 The FTC brings this action under Section 13(b) of the Federal Trade

Commission Act (ldquoFTC Actrdquo) 15 USC sect 53(b) and the Telemarketing and

Consumer Fraud and Abuse Prevention Act (ldquoTelemarketing Actrdquo) 15 USC sectsect

6101-6108 to obtain temporary preliminary and permanent injunctive relief

rescission or reformation of contracts restitution the refund of monies paid

disgorgement of ill-gotten monies and other equitable relief for Defendantsrsquo acts

or practices in violation of Section 5(a) of the FTC Act 15 USC sect 45(a) and the

FTCrsquos Telemarketing Sales Rule (ldquoTSRrdquo) 16 CFR Part 310 in connection with

2

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 3 of 57 Page ID

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1762

their deceptive marketing and sale of student loan debt relief services

JURISDICTION AND VENUE

2 This Court has subject matter jurisdiction pursuant to 28 USC sectsect

1331 1337(a) and 1345 and 15 USC sectsect 45(a) 53(b) 6102(c) and 6105(b)

3 Venue is proper in this district under 28 USC sect 1391(b)(1) (b)(2)

(c)(1) (c)(2) (c)(3) and (d) and 15 USC sect 53(b)

PLAINTIFF

4 The FTC is an independent agency of the United States Government

created by statute 15 USC sectsect 41-58 The FTC enforces Section 5(a) of the FTC

Act 15 USC sect 45(a) which prohibits unfair or deceptive acts or practices in or

affecting commerce The FTC also enforces the Telemarketing Act 15 USC sectsect

6101-6108 Pursuant to the Telemarketing Act the FTC promulgated and enforces

the TSR 16 CFR Part 310 which prohibits deceptive and abusive telemarketing

acts or practices in or affecting commerce

5 The FTC is authorized to initiate federal district court proceedings by

its own attorneys to enjoin violations of the FTC Act and the TSR and to secure

such equitable relief as may be appropriate in each case including rescission or

reformation of contracts restitution the refund of monies paid and the

disgorgement of ill-gotten monies 15 USC sectsect 53(b) and 6102(c)

DEFENDANTS

6 Defendant Impetus Enterprise Inc (ldquoImpetusrdquo) also doing business

as Aiding Student Relief Aiding Students amp Teachers Aidnest Avec Staffing

National Education Student and Teacher Studora and US Debt Relief is a

California corporation with its principal place of business at 18100 Von Karman

Ave Suite 850 Irvine California 92612 Impetus transacts or has transacted

business in this district and throughout the United States At all times material to

this Complaint acting alone or in concert with others or as part of the common

3

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 4 of 57 Page ID

1

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3

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24

25

26

27

28

1763

enterprise described in paragraph 14 Impetus has advertised marketed offered to

provide provided offered for sale or sold student loan debt relief services to

consumers throughout the United States

7 Defendant Fig Tree amp Co LLC (ldquoFig Tree LLCrdquo) also doing

business as Aiding Student Relief Aiding Students amp Teacher and Aiding

Students amp Teachers is a California limited liability company with its principal

place of business at 18100 Von Karman Ave Suite 850 Irvine California 92612

Fig Tree LLC transacts or has transacted business in this district and throughout

the United States At all times material to this Complaint acting alone or in

concert with others or as part of the common enterprise described in paragraph 14

Fig Tree LLC has advertised marketed offered to provide provided offered for

sale or sold student loan debt relief services to consumers throughout the United

States

8 Defendant Capital Sun Investments LLC (ldquoCapital Sunrdquo) also doing

business as Studora is a Wyoming limited liability company with its principal

place of business at 1651 East Fourth Street Suite 124 Santa Ana California

92701 Capital Sun transacts or has transacted business in this district and

throughout the United States At times material to this Complaint acting alone or

in concert with others as part of the common enterprise described in paragraph 14

or as a successor in interest to defendant Impetus Capital Sun has advertised

marketed offered to provide provided offered for sale or sold student loan debt

relief services to consumers throughout the United States

9 Defendant Tuan Dinh Duong also known as Thomas Duong and

Thomas Dinh (ldquoDuongrdquo) has identified himself as or served as the President

director general manager sales manager owner co-owner and principal

shareholder of Impetus At all times material to this Complaint acting alone or in

concert with others he has formulated directed controlled had the authority to

4

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 5 of 57 Page ID

1

2

3

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5

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28

1764

control or participated in the acts and practices set forth in this Complaint

Defendant Duong resides in this district and in connection with the matters alleged

herein transacts or has transacted business in this district and throughout the

United States

10 Defendant Brenda Avitia-Pena (ldquoAvitia-Penardquo) has identified herself

as or served as the President CEO Secretary CFO director and owner of

Impetus and the manager of Fig Tree LLC At all times material to this

Complaint acting alone or in concert with others she has formulated directed

controlled had the authority to control or participated in the acts and practices set

forth in this Complaint Defendant Avitia-Pena resides in this district and in

connection with the matters alleged herein transacts or has transacted business in

this district and throughout the United States

11 Defendant Brian Colombana (ldquoColombanardquo) who has also done

business under the fictitious business name ldquoFuterordquo has identified himself as or

served as co-owner of Impetus (and CIO of its dba Avec Staffing) and manager

of Fig Tree LLC At times material to this Complaint through at least January

2018 acting alone or in concert with others Colombana formulated directed

controlled had the authority to control or participated in the acts and practices set

forth in this Complaint Defendant Colombana resides in this district and in

connection with the matters alleged herein transacts or has transacted business in

this district and throughout the United States

12 Defendant Jimmy Calderon (ldquoCalderonrdquo) has identified himself as and

has served as manager of Capital Sun At times material to this Complaint since at

least September 2017 acting alone or in concert with others Calderon formulated

directed controlled had the authority to control or participated in the acts and

practices set forth in this Complaint Defendant Calderon resides in this district

and in connection with the matters alleged herein transacts or has transacted

5

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 6 of 57 Page ID

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26

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28

1765

business in this district and throughout the United States

RELIEF DEFENDANT

13 Relief Defendant Noel Solutions LLC (ldquoNoelrdquo) has received funds

that can be traced directly to Defendantsrsquo deceptive acts or practices alleged below

for which it has no legitimate claim Noel is a Wyoming limited liability company

that reported in a public document that its principal place of business is 1623

Central Ave Suite 201 Cheyenne Wyoming 82001 Noel also incorporated as a

California limited liability company in January 2018 listing its address as 18997

Barroso St Rowland Heights California 91748 Noel transacts or has transacted

business in this district and in the district of Wyoming

COMMON ENTERPRISE

14 Defendants Impetus Fig Tree LLC and Capital Sun (ldquoCorporate

Defendantsrdquo) have operated as a common enterprise while engaging in the

unlawful acts and practices alleged below Defendants have conducted the

business practices described below through interrelated companies that have

common ownership officers managers business functions employees and office

locations and routinely transfer funds amongst themselves Because the Corporate

Defendants have operated as a common enterprise each is jointly and severally

liable for the acts and practices alleged below Defendants Duong Avitia-Pena

Colombana and Calderon have formulated directed controlled had the authority

to control or participated in the acts and practices of the Corporate Defendants that

constitute the common enterprise

COMMERCE

15 At all times material to this Complaint Defendants have maintained a

substantial course of trade in or affecting commerce as ldquocommercerdquo is defined in

Section 4 of the FTC Act 15 USC sect 44

6

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 7 of 57 Page ID

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28

1766

DEFENDANTSrsquo UNLAWFUL STUDENT LOAN DEBT RELIEF

OPERATION

16 Since at least December 2014 through at least the filing of the FTCrsquos

Complaint in this matter in November 2018 Defendants have operated an unlawful

debt relief scheme that preys on consumers with student loan debt In telephone

calls on websites and in mailed advertising Defendants promise to reduce

consumersrsquo monthly student loan payments and eliminate all or a portion of their

student loan debt through enrollment in student loan forgiveness or repayment

programs In many instances however Defendants failed to obtain debt

forgiveness or monthly payment reductions In fact some consumers owed more

on their student loans after enrolling in Defendantsrsquo program

17 In exchange for the promised student loan debt relief services

Defendants have charged illegal upfront fees of $499 or more

Background on Student Loan Forgiveness and Repayment Programs

18 Student loan debt is the second largest class of consumer debt more

than 42 million Americans collectively owe nearly $15 trillion in student loan

debt The student loan market shows elevated levels of distress relative to other

types of consumer debt

19 To address this mounting level of distressed debt the US

Department of Education (ldquoUSDErdquo) and state government agencies administer a

limited number of student loan forgiveness and discharge programs Most

consumers however do not qualify for these programs because of strict eligibility

requirements For example one program requires the consumer to demonstrate a

total and permanent disability another applies only to consumers whose school

closed while the consumer was still enrolled A third program the Borrower

Defense to Repayment (ldquoBDRrdquo) may provide a loan discharge if the school

through an act or omission violated state law directly related to the borrowerrsquos

7

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 8 of 57 Page ID

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1767

federal student loan or to the educational services for which the loan was provided

20 Other forgiveness programs require borrowers to work in certain

professions for a period of years For example Teacher Loan Forgiveness applies

to teachers who have worked full-time for five years in a low-income elementary

or secondary school or educational service agency Public Service Loan

Forgiveness (ldquoPSLFrdquo) applies to employees of governmental units or non-profit

organizations who make timely monthly payments for a period of ten years while

employed in the public sector

21 The federal government also offers loan forgiveness through income-

driven repayment (ldquoIDRrdquo) programs that enable borrowers to reduce their monthly

payments and have portions of their loans forgiven IDR programs allow eligible

borrowers to limit their monthly payments based on a percentage of their

discretionary monthly income To remain in an IDR program borrowers must

recertify their income and family size annually Obtaining forgiveness through

IDR programs requires a minimum of 20 or 25 years of qualifying payments

depending on whether borrowers received their first loans on July 1 2014 or

before that date Because a borrowerrsquos income is likely to fluctuate over the life of

the loan monthly payments under the IDR programs can vary considerably from

year to year If a borrowerrsquos income were to increase over the repayment period

for example the monthly payment amount could correspondingly increase to the

point where those payments would pay off the loan before any amount could be

forgiven at the end of the repayment term No loans have been forgiven yet under

any of the IDR programs because the programs have not existed long enough for

borrowers to make the minimum number of years of qualifying payments

22 Consumers can apply for BDR PSLF IDR and other loan repayment

and forgiveness or discharge programs through USDE or their student loan

servicers at no cost these programs do not require the assistance of a third-party

8

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 9 of 57 Page ID

1

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1768

company or payment of application fees

23 USDE will grant forbearance while processing applications for an

alternative repayment plan and in some cases of hardship During forbearance

unpaid interest is added to the principal balance

Defendantsrsquo Deceptive Marketing of Student Loan Debt Relief Services

24 To lure consumers into purchasing their purported student loan debt

relief services Defendants have made false promises to eliminate or reduce

consumersrsquo student loan balances or monthly payments through loan forgiveness

or other programs

25 To induce consumers to purchase their purported student loan debt

relief services Defendants have disseminated websites such as aidingstudentscom

aidnestcom and studoracom including but not necessarily limited to the

attached exhibits A through F Defendantsrsquo websites have contained the following

statements among others

Free Assessment

Our experts will assess your current student loan program and determine

which programs are available in your

situation We will help you decide which

program can help you achieve your goals Call

us today

Service Guarantee

We are committed to helping customers get

lower rates and monthly payments and we will

make the process seamless and

straightforward You will be satisfied with our

service and our commitment to your success Thatrsquos our

guarantee

Ex A at 1 (aidingstudentscom 2015)

9

Success Rate

Our 96 success rate is one of the top ratings in

the industry Our process has been tested and our

success rate proves that it works We can help you reduce and simplify your payments Call us today

Attachment A

----------

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 10 of 57 Page ID

1

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1769

ldquoWe can help you reduce and simplify your payments Contact one of our specialists today for a free evaluationrdquo

Ex A at 2 (emphasis in original)

ldquolsquoAiding Student Relief has helped countless people reduce their student debt Their proven business plan has led to one of the highest success rates in the industryrsquordquo

Ex A at 4

100 Customer Satisfaction We can help you reduce and simplify your payments Call one of our specialists

today

Ex B at 1 (aidingstudentscom 2016) (emphasis in original)

Meet some of our members who have saved big on their student loan debt Helping You Save Big

ldquoThanks to Aiding Student Relief I am savings [sic] $250 per monthrdquo Michael Martin Entrepreneur

Ex B at 2 (emphasis in original)

ldquoWe can help you reduce and simplify your payments rdquo

Ex C at 1 (aidingstudentscom 2018) (emphasis in original)

Student Loan

Forgiveness

If you have Federal Student Loans yoursquore in the right place to get those

Loan Forgiveness

Get your multiple Federal Student Loans consolidated into one

10

Student Loan

Forgiveness

We understand if yoursquore going through some hardship and thatrsquos why

Attachment A

Case 818-cv-01987-JLS-KES

1

2

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5

6

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Document 50-1 Filed 020519 Page 11 of 57 Page ID 1770

loans reduced forgiven or completely discharged through our student loan forgiveness programs

forget about increasing interests [sic] and pay month to month at the lowest possible cost

with us yoursquoll be able to make monthly payments based on your affordability for as low as $000 depending on your situation

Ex D at 2 (aidnestcom 2016)

Lower your loan payments by getting in touch with one of our professionals We design a customized repayment plan that will allow you to make payments based on your monthly income family size and spending Get rid of the hassle of extensive paperwork and get the help you deserve

What we can help you achieve [is] a lower payment or lower rate

Ex E at 6 (aidnestcom 2018) (emphasis in original)

STUDENT LOAN FORGIVENESS

Wersquoll help you get your loans reduced forgiven or

discharged

INCOME BASED PAYMENTS

Make monthly payments based on your affordability

LOAN CONSOLIDATION

Get multiple Federal Student Loans

consolidated into one low monthly payment

Ex F at 1 (studoracom 2018) (emphasis in original)

26 In some instances consumers view the Defendantsrsquo online advertising

and call Defendantsrsquo telemarketers for more information Defendants also make

outbound telemarketing calls and send texts to consumers to offer their services

and convince student loan borrowers to sign up for Defendantsrsquo debt relief

services

11

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 12 of 57 Page ID

1

2

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1771

27 In calls with consumers Defendantsrsquo telemarketers have told

consumers that Defendants can cause consumersrsquo student loan balances to be

reduced or that consumersrsquo loan balances would be forgiven after making lower

monthly payments Defendantsrsquo telemarketers have told some consumers that over

half their loan balance would be forgiven Moreover Defendantsrsquo telemarketers

have told some consumers that their loan payments could or would be rapidly

reduced to $19 per month or promptly forgiven

28 Defendants have made other representations concerning loan

reduction or forgiveness to consumers in telemarketing their debt relief services

For example Defendantsrsquo telemarketers have told one or more consumers that

ldquofamily sizerdquo a metric for determining the amount borrowers pay each month

under IDR plans includes ldquoanyone you help out throughout the year[] they donrsquot

have to live with yourdquo even claiming that helping with ldquogas money three times

out of the yearrdquo is enough to include a person in ldquofamily sizerdquo Further

Defendantsrsquo telemarketers have offered one or more consumers ldquobasically a

guarantee to remainrdquo in an IDR plan and warned one or more consumers that

signing up for an IDR plan with a lender instead would result in a higher loan

payment

29 Defendants have not been likely to achieve the lower monthly

payments or student loan forgiveness they have advertised marketed and

promoted to consumers In many instances Defendants have failed to obtain the

promised lower monthly payments or student loan forgiveness

30 Defendants have charged consumers fees for purported debt relief

services before achieving lower monthly payments or student loan forgiveness

and in many instances have failed to achieve those results at all on behalf of

consumers

12

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 13 of 57 Page ID

1

2

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23

24

25

26

27

28

1772

31 Defendantsrsquo telemarketers have sought and obtained consumersrsquo

payment information by phone or the Internet

32 Defendantsrsquo total advance fees typically have been in the range of

$300-500 Defendants also have charged consumers recurring monthly fees for

purported debt relief services typically charging $19 per month

THE FTC ACT

33 Section 5(a) of the FTC Act 15 USC sect 45(a) prohibits ldquounfair or

deceptive acts or practices in or affecting commercerdquo

34 Misrepresentations or deceptive omissions of material fact constitute

deceptive acts or practices prohibited by Section 5(a) of the FTC Act

VIOLATIONS OF THE FTC ACT

Count One

(Deceptive Student Loan Debt Relief Representations)

35 In numerous instances in connection with the advertising marketing

promotion offering for sale or sale of student loan debt relief services Defendants

have represented directly or indirectly expressly or by implication that consumers

who purchase Defendantsrsquo debt relief services will or likely will have their

monthly payments reduced or their loan balances forgiven in whole or in part

36 In truth and in fact in numerous instances in which Defendants have

made the representations set forth in Paragraph 35 of this Complaint such

representations were false or not substantiated at the time Defendants made them

37 Therefore Defendantsrsquo representations as set forth in Paragraph 35 of

this Complaint are false or misleading and constitute deceptive acts or practices in

violation of Section 5(a) of the FTC Act 15 USC sect 45(a)

THE TELEMARKETING SALES RULE

38 Congress directed the FTC to prescribe rules prohibiting abusive and

deceptive telemarketing acts or practices pursuant to the Telemarketing Act 15

13

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 14 of 57 Page ID

1

2

3

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5

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22

23

24

25

26

27

28

1773

USC sectsect 6101-6108 in 1994 The FTC adopted the original TSR in 1995

extensively amended it in 2003 and amended certain sections thereafter 16

CFR Part 310

39 Defendants are ldquoseller[s]rdquo or ldquotelemarketer[s]rdquo engaged in

ldquotelemarketingrdquo as defined by the TSR 16 CFR sect 3102(dd) (ff) and (gg) A

ldquosellerrdquo means any person who in connection with a telemarketing transaction

provides offers to provide or arranges for others to provide goods or services to a

customer in exchange for consideration 16 CFR sect 3102(dd) A ldquotelemarketerrdquo

means any person who in connection with telemarketing initiates or receives

telephone calls to or from a customer or donor 16 CFR sect 3102(ff)

ldquoTelemarketingrdquo means a plan program or campaign which is conducted to

induce the purchase of goods or services or a charitable contribution by use of one

or more telephones and which involves more than one interstate telephone call 16

CFR sect 3102(gg)

40 Defendants are sellers or telemarketers of ldquodebt relief servicesrdquo as

defined by the TSR 16 CFR sect 3102(o) Under the TSR a ldquodebt relief servicerdquo

means any program or service represented directly or by implication to

renegotiate settle or in any way alter the terms of payment or other terms of the

debt between a person and one or more unsecured creditors or debt collectors

including but not limited to a reduction in the balance interest rate or fees owed

by a person to an unsecured creditor or debt collector 16 CFR sect 3102(o)

41 The TSR prohibits sellers and telemarketers from requesting or

receiving payment of any fees or consideration for any debt relief service until and

unless

a The seller or telemarketer has renegotiated settled reduced or

otherwise altered the terms of at least one debt pursuant to a

14

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 15 of 57 Page ID

1

2

3

4

5

6

7

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17

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21

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23

24

25

26

27

28

1774

settlement agreement debt management plan or other such

valid contractual agreement executed by the customer and

b The customer has made at least one payment pursuant to that

settlement agreement debt management plan or other valid

contractual agreement between the customer and the creditor

and

c To the extent that debts enrolled in a service are renegotiated

settled reduced or otherwise altered individually the fee or

consideration either

i Bears the same proportional relationship to the total fee

for renegotiating settling reducing or altering the terms

of the entire debt balance as the individual debt amount

bears to the entire debt amount The individual debt

amount and the entire debt amount are those owed at the

time the debt was enrolled in the service or

ii Is a percentage of the amount saved as a result of the

renegotiation settlement reduction or alteration The

percentage charged cannot change from one individual

debt to another The amount saved is the difference

between the amount owed at the time the debt was

enrolled in the service and the amount actually paid to

satisfy the debt 16 CFR sect 3104(a)(5)(i)

42 The TSR prohibits sellers and telemarketers from misrepresenting

directly or by implication any material aspect of any debt relief service including

but not limited to the amount of money or the percentage of the debt amount that a

customer may save by using the service 16 CFR sect 3103(a)(2)(x)

15

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 16 of 57 Page ID

1

2

3

4

5

6

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8

9

10

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12

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1775

43 Pursuant to Section 3(c) of the Telemarketing Act 15 USC

sect 6102(c) and Section 18(d)(3) of the FTC Act 15 USC sect 57a(d)(3) a violation

of the TSR constitutes an unfair or deceptive act or practice in or affecting

commerce in violation of Section 5(a) of the FTC Act 15 USC sect 45(a)

VIOLATIONS OF THE TELEMARKETING SALES RULE

Count Two

(Advance Fee for Debt Relief Services)

44 In numerous instances in connection with the telemarketing of

student loan debt relief services Defendants have requested or received payment

of a fee or consideration for debt relief services before

a Defendants have renegotiated settled reduced or otherwise

altered the terms of at least one debt pursuant to a settlement

agreement debt management plan or other such valid contractual

agreement executed by the customer and

b The customer has made at least one payment pursuant to that

settlement agreement debt management plan or other valid

contractual agreement between the customer and the creditor

45 Defendantsrsquo acts or practices as described in Paragraph 44 of this

Complaint are abusive telemarketing acts or practices that violate Section

3104(a)(5)(i) of the TSR 16 CFR sect 3104(a)(5)(i)

Count Three

(Material Debt Relief Misrepresentations)

46 In numerous instances in connection with the telemarketing of

student loan debt relief services Defendants have misrepresented directly or

indirectly expressly or by implication material aspects of their debt relief services

including but not limited to that consumers who purchase Defendantsrsquo debt relief

services will or likely will have their monthly payments reduced or their loan

16

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 17 of 57 Page ID

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1776

balances forgiven in whole or in part

47 Defendantsrsquo acts and practices as described in Paragraph 46 of this

Complaint are deceptive telemarketing acts or practices that violate Section

3103(a)(2)(x) of the TSR 16 CFR sect 3103(a)(2)(x)

Count Four

(Disgorgement of Ill-Gotten Gains of Relief Defendant)

48 Relief Defendant Noel has received directly or indirectly funds or

other assets from Defendants that are traceable to funds obtained from Defendantsrsquo

customers through the unlawful acts or practices described herein

49 Relief Defendant Noel has no legitimate claim to Defendantsrsquo

customersrsquo funds or other assets and will be unjustly enriched if it is not required to

disgorge the assets or the value of benefits received as a result of Defendantsrsquo

unlawful acts or practices

50 By reason of the foregoing Relief Defendant Noel holds funds and

assets in constructive trust for the benefit of Defendantsrsquo customers

CONSUMER INJURY

51 Consumers have suffered and will continue to suffer substantial injury

as a result of Defendantsrsquo violations of the FTC Act and the TSR In addition

Defendants have been unjustly enriched as a result of their unlawful acts or

practices Absent injunctive relief by this Court Defendants are likely to continue

to injure consumers reap unjust enrichment and harm the public interest

THIS COURTrsquoS POWER TO GRANT RELIEF

52 Section 13(b) of the FTC Act 15 USC sect 53(b) empowers this Court

to grant injunctive and such other relief as the Court may deem appropriate to halt

and redress violations of any provision of law enforced by the FTC The Court in

the exercise of its equitable jurisdiction may award ancillary relief including

rescission or reformation of contracts restitution the refund of monies paid and

17

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 18 of 57 Page ID

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1777

the disgorgement of ill-gotten monies to prevent and remedy any violation of any

provision of law enforced by the FTC

53 Section 6(b) of the Telemarketing Act 15 USC sect 6105(b)

authorizes this Court to grant such relief as the Court finds necessary to redress

injury to consumers resulting from Defendantsrsquo violations of the TSR including

the rescission or reformation of contracts and the refund of money

PRAYER FOR RELIEF

Wherefore Plaintiff FTC pursuant to Section 13(b) of the FTC Act 15

USC sect 53(b) Section 6(b) of the Telemarketing Act 15 USC sect 6105(b) and

the Courtrsquos own equitable powers requests that the Court

A Award Plaintiff such preliminary injunctive and ancillary relief as

may be necessary to avert the likelihood of consumer injury during

the pendency of this action and to preserve the possibility of effective

final relief including but not limited to temporary and preliminary

injunctions orders freezing assets immediate access to business

premises appointment of a receiver and expedited discovery

B Enter a permanent injunction to prevent future violations of the FTC

Act and the TSR

C Award such relief as the Court finds necessary to redress injury to

consumers resulting from Defendantsrsquo violations of the FTC Act and

the TSR including but not limited to rescission or reformation of

contracts restitution the refund of monies paid and the disgorgement

of ill-gotten monies

D Enter an order requiring Relief Defendant to disgorge all funds and

assets or the value of the benefit it received from the funds and assets

which are traceable to funds obtained from Defendantsrsquo customers

through the unlawful acts or practices described herein and

18

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 19 of 57 Page ID 1778

2

3

E Award Plaintiff the costs of bringing this action as well as such other

and additional relief as the Court may determine to be just and proper

Dated February 5 2019

Respectfully submitted

ALDEN F ABBOTT General Counsel

JosaSMillard Brian M Welke middot Barbara Chun (Local Counsel) Attorneys for Plaintiff FEDERAL TRADE COMMISSION

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Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 20 of 57 Page ID 1779

EXHIBIT A

Attachment A

Free Assessment

Our expercs will lt1ssPss you cun ent

swclent lo n program and decermn which progr ms are

avc11l bl rn yoL11 situation We wi I help you cl11cic1e which progr m r1

help you achieve your goals Call us today

Service Guarantee We are commmecl to 11-1 111g

CllStomers get low r rc1ces ancl monthly payments and we w1I

m ke the pror~ss se mless and s r11ghtforwc1rd ou wi ll be sansf1ed

with our service ml OLlr

cornmcmem to you success Thars ow gu~ ancee

Success Rate Ou1 96 ~ surcPss r a e s 11e of he

cop I a ings tn he industry Olr

process has beer tested nd Olli

succ ss r r~ prowbull~ tn t it works

We c n ll~lp yo reduce and -1111ph y our p ~ymP1 ts Call us today

FTC-AID-1

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 21 of 57 Page ID 1780

20

Exhibit A

ABOUT US

We can help you reduce and simplify your pay1ncnts Contact one of our specialists today for

a free evaluation

111middot 1_I 1

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Itbull 11

Ill fl I I

bull ~ 0 I

What Makes Us Great fa1(li1-_~ tur1ent ~e11ef 11as a taf- o~middot tt a middotel elt1)rns bullJn st1ncb110

1middot1ep yriJ Tibullmiddotest fi 1e-ndly f3ce~ 113ve eirej e1tc-nsve1yr =inj ire

fanih1~1 bull11iu1 ti~e nul~nce~ cfscrvern rrent Cdid p11vate stucre11

l1J1ns Th~y viill u~e Ui5 epe tise o loik jUl fJ ycur ~Je~t

i(tres~- f)LH ~U(CtS~ ~HE 1h-~ I lSllt of i_r middotDff ancl iur

C ur ~r_(J~l 1o~w- JCl11~crs f(middotil) 3 00Vtli ~tJegy o r ~dUC2 011i

a1r1plfy yliur- - _Je1middott middotcar payr1t11s 1) Asstrnlins Itle ~atl1t1

2) R~~ear c1-1ng Our st~lff wmiddoti11 (lrJUi~oleaerick ]ll fnfcnTnati(-n befort dtmiddoteJPlr~ t tne ri~n 3) rnnk1middotgbullle i_i1 i e~ear (rr i~ ormiddot1 1 1 etc 1Ne

irvi-s t1ga~ii 111 ps~ib le a~irst 1n(t aptlbull~n 4) 1Nr1 ting VVF p1 eiv lii J 11 iUen u tt-igy IJefore vie Uke ut1c-1l i)ecius~ you d-ese11e 11) undi r~~anci

Lhe pr 1cer S) ~ev1sing Al)ng ~r 1udent Relief 1- 1otT11111tt bull) ti) ci e1H1ve ut-l-~n~-l)O c111 i ri 3 Vbulle -~11 leave n1) sti bull1e u11t111 neltl tecause middot~ve

11~1ve your be~ i1~ t~rest 1t l1ein 6) Si~tcl11ng Our note- =1nd r~c)1 ~ ~1 e thorou~ll ln(I pru1ile 1 ceJ1 po cri1~ 1)f vo111 ~1tuJticn s) iny if-oi

~xpe1 t- 01 eou pped to s~1ty1J_J bullVi r you1 c si- 7) De-gn1ng _ fe ~1 t 1nelt--1- f1ts ti 1middotV 1middotid de~ 1middot1 1 st1 iegy to fit ou 1 1_i dque jtct1in so

011 c111 i Jle y1)u1 1vv1middot1 per feet -ut1e-s ~~0 1 v

1bullVlly 1100~e At(J1n~ Sltl(ltnt Fie11e7) (i1_d aclol~Or~ bull -ii~ (1Ualiftel lci ~~~ISt~h 1noie ype-s middotif JS~iSi_ance u~211 Cd ( (11)itXS i1 jG(l1~t) to ti-tgt

p ~n~ 1not con1p n1es can 11i1p bullbullllh ve )t ~ ~qu1pptCI to bull-bullGr k 1bullv1t1middot1 r~ 11t-2 [uo emiddot 1 lc1 r1s ~~nCI cn even iner-1ne frmiddot tt1e c ~e of 1l~e

~1lt ntslmiddoturelt A1cl1rg Sudent Fie1ef 1middot cis mmiddote to )fe 11d we offe1 t with middotmiddot1eltbullbe 1es nI 3 rncney lock guMai-itee

We Have Been Featured In

FTC-AID-2

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 22 of 57 Page ID 1781

21

Exhibit A

SERVICES Wt w gtL

Loan Forgiveness Income Based Payments Loan Consol idation In some cases individuals with A period of financial hardship may You may be able to combine

Fede1middota1 Student Loans may qualify qualify you for an Income Based nultiple federal student loans into to have a portion of the amount Repayment Plan In many cases this one new loan w ith a lower more

owed may be forgiven This means means you pay nothing Unlike a affordable monthly payment Loan

your principal balnce coulcl be defe1 ment the term on your loan consolidation prngrams can l1elp

significantly reduced and you will continues to reduce while the plan is you qualify for additional programs not be expected to repay the in place Your term could reduce like loan forgiveness programs or

forgiven amount while you pay nothing Public Setvice Loan Forgiveness

a III

Private Sector Loan Forgiveness

If you work for a government

organization at a city state or

federa l level you may qualify for tle

PL1blic Service Loan Forgiveness

program To qualify your loans

must be cotisolidated into a specific

repayment plan The balance on

your federai student loans is

forgiven after 120 qualifying

bull C Permanent Disability

Forgivenness If your disability is expected to last

60 months or more you may qualify

for permanent disability forgiveness

Q1alifying for Permnent Disability

Forgiveness requires a visi t to your

doctor and individL1als enrolled in

the program are subject to three

years of post-discharge monitoring

Wage Garnishment Prevention

Federal law requires that the

Department of Education or a

gua1middotanty agency notify you before

111st1tuting wage garnishment You

have tl1e right to a hearing where

you can challenge the stated

amount owed and negotiate the

terms of the repayment scheclule

We can intervene on YOL1PflJl~1D-3

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 23 of 57 Page ID 1782

22

Exhibit A

payments have been made p1middotevent wage gampnishments

A FEW STATISTICS ABOUT STUDENT LOAN CRISIS

12 Trillion National Student Debt I he nitionil student loin debt is

now 17 trillion dollirs 1 trillion of

these are in federil student loans

Let us help you through this national

crisis Cill today for a free

evaluation

40 Million Students with Debt

In 7014 an estimated 40 million

current and former students were in

debt because of student loans If

you are one of the millions of people

struggling to pay student loans

Aiding Student Relief is here to help

$33000 Average Student Debt

The graduating class of 7014

average $33000 of student loan

debt per person Thats $3000 more

than the average in 2013 Dont be

one of the many Let Aiding Student

Relief advocate for you

Aiding Student Relief has helped cmrnllcss 1woplc reduce their student debt_ Their proven business

plan has led lo one of lhc highest s11cclSS raCs in the inltl11slly

John Standiford Associated

FTC-AID-4

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 24 of 57 Page ID 1783

23

Exhibit A

TESTIMONIALS

Til~nks to Aiding Student Rel ief Im middotI middotva ove1vvhelrnecl but Aiding The expemiddotts at l1icl i11g Student Rel ief

s1v ing $250 per month Strrd r~rt Relief expl~ inecl the were ther~ to help me when I process ancl rnacle everytl1ing cle11middot nelclecl 1t rw)s t

and sirnple

I Michael Ma 1in

Entrep e11eu1 Em iiy Jallo1 Ii Pa ul Ch is tia I1se11

Teacher Nurse

With so many programs I didnt middotconso lrclating my loans into one I love my Job but vith my high

know what was ng ht for me My monthly payment hs made life student loan payment was still

sruclent loan aclvsor walked me si1nple1 Now I can focus on 1Nhn bamiddotely getting by I don t kn ow what I

through my optio ns rnd now Imiddotn matters to me would hwe clone wthout Aiding

saving 54 I 11n1omh Stucie1middott Rel refmiddot

Ariel Hemiquez Sales co)SUltant

Stephani Seland-1 Small Busim~ss Owner

AJ 01en Museum Curator

RECENT NEWS

)lt)

o(l ttDrlTI -5

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 25 of 57 Page ID 1784

24

Exhibit A

Student Debt Crisis Business Latest Debt Collective Demands May be largely about smallest Student

borrnwers US News amp World Loan Crisis is fa frorn ove The Debt Collective is a group of Report-May 162015 last month Two new reports suggest the college students calling the Fedemiddotal Reserve Bank of New student loan crisis is easing them-se1ves the Corinthian York repor ced that stuclent loan somewhat as the economy Fifteen who are refusing to pay balances rose to 16 trillio n and improves but the crisis is far back their student loins As pa t that 113 per cent of that is in from ove the College Board of this effort the Debt Collective repo t~ tot31 borrowing fell by 8 has written an open lette to the pEbull1 cent between 2012-13 and Department of Education f l llJ 20 13-14 The organization

About Us 11 1 i~d1middot1r F th~~- h1~ ff t1middot~11middot=cl =i~=middott- 1middot __31middotmiddotIIgt middot bullmiddot11

middot- I ( )ntir il t l~i -r_il fr~~

Address bull middot tc1ltj-1r_ =i ~

middot l t1~t 1middot1 fcJ middot~_1 1 I l11 - Hbull 1 tr

~t (~~ 1 12bull~11 T 1 1- - 8555105400

FTC-AID-6

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 26 of 57 Page ID 1785

25

Exhibit A

f - g+ in O) ~ PRIVACY POLICY

This privacy statement discloses the privacy practices for AidllII Student Relief Because Aiding Studen Relief wonts to demonstrate ts firm commlcmell to your

privacy Aiding Sudent Relief hes greed to disclose ls 1rifor111atlori g1thering and dlssem1n1t1on prct1cts Aidlns Studtrit Relief will notify you of

INFORMATION COLLECTION At-ID USE

Aiding Student Relief is the sole owner of the rformMlon collected on this site We will not sell shire or rent this information 10 others In way different from what Is

disclosed 1n this statement Aldln1 StudeM Relief collects 1nform111on throuah this site from our prospective end existing clients at several different poin on our web

site We use their contact Informii on to send information bout our company and to service exsMs accounts Users may optbullout of rece11ns future malllngs see the

cholceoptbullout section below Contect and Financial information that 1s collected Is used for verifying your name address and other informa1on as well as to boll you for

your use of our Gerv1ces using Information from third party sourcH Information about your computer hardwre and software Is automatically collected by Aiding

Student Relief and may be shared in asgregate with third parties whose services are used for traffic analysis purposes This Ir formation includes your IP address

browser type domain names access times and referring Web site addresses Ths information is no tied to personally Identifiable Information This 1nformatlor s used

by Aiding Student Relief to malMan no Improve the quality of the Hrvct and to senerae statistics resardlng use of he Aiding Student Relief site We use third party

services to bill for serlces and to provide other services like our Live Help chat We store the transcripts from these chats for customer service Improvement These

third party service providers are not permitted to use your infornon for any secondary purposes

Thank you and cheers

FTC-AID-7

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 27 of 57 Page ID 1786

26

Exhibit A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 28 of 57 Page ID 1787

EXHIBIT B

Attachment A

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AIDINGSTUDENTRELIEF

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4556789fADlt=gtA9BCAD

DZgtA=EFGHIJFKLMNOPFQOGFHIQRSTLKSUMMNOPLHMTFIVRWXHKKNIFNUNOPRLFGSHKSRVRVNQ

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9SI]UQMSNSOQOHHPFK YaSTHHVVJFMHcVGNOJVHHFKKPSUHMLIUOQN_PL[KSVFGJPRSDTHRFPLIP=SNDC==GFdFIP9VaNHQTWSRPbHF_PSKSVNMPMHNIO XNNIIFRKNF7IKSQQMHFNDVPOS9IAeTHPdKSUMMFNKHONP 8aF_KSNVPHTNIMNR[POVFgNPTHLNHIgtMFI YTFHIdFFI D9aHVR_KNKHFHIWIQOTHIQbFFP

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13 deg $ $ampdegdeg degˇ amp $$deg + -+Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 30 of 57 Page ID 1789 () ( vPSZwPxyYTUZUWWzxPyxSWMZWPU|SWUWYZ~YTY~QSWbullYXRwU~UxSdaggerXQ~UZXvPSZWSOVQSYNOXPRSTUSDaggerPxXYPZPNXRUSPQZXPbullU~SOhellipUNPxyYTUZmdash zUxSZUZXndashYWShellipYYXOwPxyYTUZUWWMNOPQx~YWShellipYYXOYWUƒDaggerU|XU~XPSWXfrasllsaquoPZXRWPxPxUOPQSOVQSYNONPxDaggerUxSZUZX~YWShellipYYXONPxyYTUZUWWmdash

rsaquominus MZ|PUpermilSWUzSOUZXWbdquoDaggerUxYP~PNZSZ|YSRSx~WRYDaggerSOVQSYNOOPQNPxSZMZ|PUpermilSWU~rdquoUDaggerSOUZXzSZmdashMZSZO|SWUWXRYWUSZWOPQDaggerSOZPXRYZymdash zQhellipY|daggerUxTY|UvPSZwPxyYTUZUWWMNOPQbullPxlsquoNPxSyPTUxZUZXPxySZYrsquoSXYPZSXS|YXOWXSXUPxNU~UxSUTUOPQSOVQSYNONPxXRUzQhellipY|daggerUxTY|UvPSZwPxyYTUZUWWDaggerxPyxSmdashsbquotrade f8Ef8E78FCB6C8EŁPQSOhellipUShellipUXP|PhellipYZUQXYDaggerUNU~UxSWXQ~UZXPSZWYZXPPZUZUbullPSZbullYXRSPbullUxPxUSŒPx~ShellipUPZXRODaggerSOUZXmdashvPSZ|PZWPY~SXYPZDaggerxPyxSW|SZRUDaggerOPQVQSYNONPxS~~YXYPZSDaggerxPyxSW YlsquoU PSZ NPxyYTUZUWWDaggerxPyxSWPxzQhellipY|daggerUxTY|UvPSZwPxyYTUZUWWmdash ŠmŸŽıłŠm 57gt8A57A5B= 8E65C76B5E6F8EB5=6G

PONM[5 QRSTUVQU PYXWZW lt4556789588lt959=lt CD lt H5FICEDJ8KA5LCD

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28

Attachment A

01 $2 301 $$3 ( Exhibit B

()(

=4ABC9DEAFBD=FGFHIJKLMJNOMN MRNS mn = nrst = svzhellipu t bulltvDaggerrhellipDaggerurbullbulltuhellipv hellipz~ bullmdashldquordquolsquorsquotrade š oŒŠeuro centpound ` umluml 13 deg $ $ampdegdeg degˇ amp $$deg + -+Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 31 of 57 Page ID 1790

ISNRTUKQINKKNNKL[MRJ PUWQI]MRM qyt|tytzxy rsaquoqNfraslbdquoPUhellipsbquoLUyQhellip rfraslbhellipMNSIKVUQ QNJKvUQsMiexclQQJUx[iexcliexcl_vsect_Qyenyenbrvbarbrvbar uSSRNTPL_LUUMKIaJ_WMIJJKVIONNQJJMWRMIIbQQURKLWIIJQbKLUNKMPTMNQQ_KKRY tbullbulldaggersDaggerv~vhellipmdashryrhellip~mdashrhellipDagger ŸLŽUıQŽbłpermilMtradeœsbquoNtrade_ffRŁyISMŒUQWyNUQŠlsaquo rv45657896lt7ltgt5lt PQKLMIQSNRTUKINQVNOOMVKMWNQKLIJPMXJIKMYZMPIOO NJMOOJLURMNRRMKKLIJ klltko ltgtlt85p5gt5 ouvwxrz ^^ ~ minuspermil tffŁ yenpoundpound KNOWDaggerIreggt4lt97ltndash9ƒ Dagger hellipDaggerlsaquo žko74k57ƒ ƒISNcurrenUIWIbJKWMKJYVNTKM KLONNRqIQQSNNRTUKINQQIJ_JMWNQKLIJJJPMXJIKMcOMUJMVNQKUVK_JUKBHdefABCgDEAFBDghidjlaquopoundbrvbariexclnotvIWIQbDaggerK_WMQKbullMOIMSvOObullIbLKJbullMJMRMW ordf copy

01( $2(301$$3( Exhibit B

29

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 32 of 57 Page ID 1791

EXHIBIT C

Attachment A

~ 111 ~tampi 10 11 ~bull ia1111

Something awesome is coming soon We are buildin somethin ve cool Sta tuned and be at1ent Your atience will be well aid

~lbullrbullUiUffl We can help you reduce and simplify your payments

101 Loan For iveness

1~u 0 (middottmiddotbullmiddotmiddot1 1~=I -- _~

HZamp IMUliULlampRampatiEUWi nmiddot middot-il~ fr middot 8rbullbullrcrr-

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~ Income Based Pa ents

bull ~ f I - - I - I - ri u ~u-=lf ~ JU

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middotE-ltecl l2bullJbull iequbullt t11cit t1lt2 CtpCr~middot1e- f

JJd r g-_iraE-1 agltr-middot- ntimiddot middot)middotou

tmiddot_rt- i ic l~1ri ~rbullmiddot middot111~ umiddot -_ d_t-c

fsectmet-Naibullfyen1~poundibllffifftmI

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If -bull 13n ~Cbull t~middot rct1~j d- gtOY- - hO- irmiddot (bulldbull) plltmiddotmiddot- leemiddotmiddot JOu

1r1cbullmiddotn111f11ri ll1fbull fcrn to ~bull~I

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Exhibit C

Case 818-cv-01987-JLS

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age 33 of 57 P

age ID 1792

30

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 34 of 57 Page ID 1793

EXHIBIT D

Attachment A

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bull bull bull bull bull bull bull

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----

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 35 of 57 Page ID 1794

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

infoaidnestcom (800) 555-1212

HOME

ABOUT US

SERVICES

FAQ

BLOG

CONTACT

HOME ABOUT US SERVICES FAQ BLOG CONTACT

1 of 6 462018 945 AM

31

Student Loan Forgiveness Loan Consolidation Student Loan Forgiveness

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 36 of 57 Page ID 1795

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

If you have Federal Student Loans yoursquore in the right place to get those loans reduced forgiven or completely discharged through our student loan forgiveness programs

Get your multiple Federal Student Loans consolidated into one forget about increasing interests and pay month to month at the lowest possible cost

We understand if yoursquore going through some hardship and thatrsquos why with us yoursquoll be able to make monthly payments based on your affordability for as low as $000 depending on your situation

2 of 6 462018 945 AM

32

Knowledge Base

Defaulted Student Loans

Wage Garnishment

Student Loan Rehabilitation

Income Based Repayment Plan

Deferment and Forbearance

Pay As You Earn Repayment Plan

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE Call 561)424-6053 today to go over your options

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 37 of 57 Page ID 1796

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

Our knowledge base is designed to provide information regarding some of the critical topics those with student loans must be aware of to be able to make educated decisions regarding their future

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

A wage garnishment is any legal procedure in which some portion of a personrsquos earnings is required to be withheld by an employer for the payment of a debt

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

With this program your payments change as your income changes and will not be longer than 25 years This is the ideal plan if you are in partial financial hardship Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard plan

Temporarily allowing you to postpone or reduce your federal student loan payments Postponing or reducing your payments may help you avoid default and future garnishments

Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard

3 of 6 462018 945 AM

33

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 38 of 57 Page ID 1797

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

4 of 6 462018 945 AM

34Attachment A

Testimonials

Latest News

Why 2016 Will Be a Big Year For Student Loans

Top Student Loan Refinancing Questions of 2015

Oba mas latest student loan plan

Things You Should Know About Public Service Loan Forgiveness

Recent Posts

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 39 of 57 Page ID 1798

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

5 of 6 462018 945 AM

35

About Us

Contact Info

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 40 of 57 Page ID 1799

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

pay-grandchild-studen

Why 2016 Will Be a Big Year For Student Loans

December 30 2015

12511110_1112367518

Top Student Loan Refinancing Questions of 2015

December 30 2015

We stand by our consultation and quote We are so sure and confident about our services and offers that they are all 100 money back guarantee risk free ndash if we donrsquot do what we promise yoursquoll get your money back

(800) 555-1212 AidnestStudenLoansgmailcom 18100 Von Karman Ave Suite 850 Irvine CA 92612

Futero SAS copy 2015 | Aidnestcom

6 of 6 462018 945

Exhibit D 36Attachment A

AM

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 41 of 57 Page ID 1800

EXHIBIT E

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 42 of 57 Page ID 1801

AIDNEST Let us help you through this national crisis

Call one of our specialists today

Forbearance amp Deferment If you are still in school and struggling to make payments on your student loans You may qualify

for Forbearance amp Deferment

Garnishment Prevention Federal law requires that the Department of Education or guarantee agency notifies you before they

begin garnishing your wages

Loan Forgiveness If you are a teacher public service worker or an individual with total and permanent disability you

httpaidnestcom[442018 115239 AM]

37Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 43 of 57 Page ID 1802

AIDNEST Let us help you through this national crisis

may qualify for this program

Consolidating Your Loans Consolidating your loans to one new loan under one lender may lower your payments and make

your life a bit more manageable

Affordable Payments If you are looking to lower your monthly payments then Income Based Repayment Plans may be

the correct choice for you

Learn more about our services

LEARN MORE

httpaidnestcom[442018 115239 AM]

38Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 44 of 57 Page ID 1803

AIDNEST Let us help you through this national crisis

Loan Forgiveness Programs Income Based Payments Student Loan Rehabilitation

Student Loan Consolidation

You may be eligible for

Loan Forgiveness Programs

In some cases individuals with Federal Student Loans may qualify to have a portion of the amount

owed to be forgiven

Get in touch with our professional team to find out which loan forgiveness program you qualify for and

how you can get rid of your unpaid student loan

L EARN MORE

httpaidnestcom[442018 115239 AM]

39Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 45 of 57 Page ID 1804

AIDNEST Let us help you through this national crisis

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE

Meet your Budget One of our advisers will help you meet your payment goals by using your budget and timeline to

determine the best plan available

httpaidnestcom[442018 115239 AM]

40Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 46 of 57 Page ID 1805

AIDNEST Let us help you through this national crisis

Simple Process We understand that lowering your payments alone can be difficult Our intuitive platform allows us

to keep the entire process simple

Customer Satisfaction We are committed to providing you with outstanding service only We look forward to working

with you

100 money back guarantee No Hassle Money Back Policy

httpaidnestcom[442018 115239 AM]

41Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 47 of 57 Page ID 1806

AIDNEST Let us help you through this national crisis

Lower your loan payments by getting in touch with one of our professionals

We design a customized repayment plan that will allow you to make payments based on your

monthly income family size and spending Get rid of the hassle of extensive paperwork and get the

help you deserve

What we can help you achieve a lower payment or lower rate

httpaidnestcom[442018 115239 AM]

42Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 48 of 57 Page ID 1807

AIDNEST Let us help you through this national crisis

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcom[442018 115239 AM]

43Exhibit E

httpaidnestcomservices[442018 115322 AM]

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 49 of 57 Page ID 1808

Services | AIDNEST Let us help you through this national crisis

INCOME BASED PAYMENTS

If you are suffering from a financial hardship you may be eligible for an

Income Based Payment In this repayment program you would have a

payment based on your income and family size The payment could be as

low as $000 per month with forgiveness at the end of 20-25 years

44

Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 50 of 57 Page ID 1809

L E ARN MORE

LOAN FORGIVENESS

If you have Federal Student Loans you may qualify for any of the student

loan forgiveness programs that are available to borrowers You may be

eligible for principal reduction loan forgiveness or a complete loan

discharge depending on your individual circumstance

L EARN MORE

PRIVATE STUDENT LOAN CONSOLIDATION

Much like refinancing a mortgage generally the biggest benefit of private

student loan consolidationstudent loan refinancing is a lower interest rate

httpaidnestcomservices[442018 115322 AM]

45Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 51 of 57 Page ID 1810

L E ARN MORE

(something federal consolidations do not offer)

STUDENT LOAN REHABILITATION

You can renew eligibility for new loans and grants and eliminate the loan

default by ldquorehabilitatingrdquo a defaulted loan

httpaidnestcomservices[442018 115322 AM]

46Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 52 of 57 Page ID 1811

CHE CK E L E G I B I L I T Y

WAGE GARNISHMENT

A wage garnishment is any legal procedure in which some portion of a

personrsquos earnings is required to be withheld by an employer for the

payment of a debt

L EARN MORE

With our fast friendly and professional services wersquoll be glad to help you get your student loans

reduced forgiven or completely discharged To this end wersquoll assist you in consolidating all your

student loans so yoursquoll have only one lender and yoursquoll start making one monthly payment Our

professionals will walk you through the best and most flexible repayment options and if itrsquos also

necessary varied deferment options and rehabilitation programs

httpaidnestcomservices[442018 115322 AM]

47Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 53 of 57 Page ID 1812

Services | AIDNEST Let us help you through this national crisis

Our CRM System

Our CRM is one of the most advanced in the industry and most importantly itrsquos linked directly to

the Department of Education (DOE) This keeps your personal and most confidential information

safe Furthermore because our CRM system is linked to the DOE our approval is 100 Through

our CRM we will be doing continuous monitoring of our process without losing sight of your

immediate needs ensuring that your case has the proper handling and most efficient process

httpaidnestcomservices[442018 115322 AM]

48Exhibit E

n

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 54 of 57 Page ID 1813

Services | AIDNEST Let us help you through this national crisis

R ECENT POSTS

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

ABOUT US

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcomservices[442018 115322 AM]

49Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 55 of 57 Page ID 1814

EXHIBIT F

s -

bullmiddot - ~ t ~ower Your Student Loan Pay~e~ts oday -- Students Helping Students Save Money

INCOME BASED PAJIIIJITPAIS

I C(gttoUC1 u~

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 56 of 57 Page ID 1815

X + C (D Not secure wwwstudoracom 0

CALL US NOW (85S) 978-S599 middot 1nfostudoracom

HOME SERVICES ABOUT US FAQ CONTACT US BLOC PRIVACY

Offering obligation and commitment free loan relief solutions

STUDENT LOAN FORGIVENESS INCOME BASED PAYMENTS LOAN CONSOLIDATION

We11 help you get your loans reduced forgiven o r Make monthly pdyments based on your affordability Get multiple Federal Student Loans consolidated into

discharged one low monthly payment

Talk to our experts concerning your

student loans

Studora is a pnvatefy owned company that helps consumers like you identify

government programs that fit your financial s1tuat1on Our loan experts will assist you in selecting the appropriate programs that WOltk with your income family size and

desired monthly payment We then prepare the appropriate documents for your review and submission All this f o r one low easy payment

Testimonials

Thank you f o r getting back to me quickly Youve been fabulous Thank you for the confirmation and for your help today Pass

during this whole process Is there a place I can go online that I this on to your sup that you were very professional and very

can leave a comment for your manager Youve made this Robert helpful and brought a sense of relief for me Thank you very

process so easy and answered every question my husband and I much and have a great rest of your day Kudos to you and your

have had teammoneywell spenL

Exhibit F 50

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 57 of 57 Page ID 1816

Services we offer

Stud ora offers document preparation services for all loan forgiveness consolidation and relief services to people who are unable to manage their finances Our mam aim is to

offer complete peace of mind to indiVidual unable to pay their student loan debt

we otter the folloWing document preparation services with complete professional assistance

amFinancial Review ffl Budget Planning

Toe first step to creating a flexible loan repayment plan is financial review we also help create a personal finance plan to ensure that you are able to

Our professmnals will look into your finances and design a custom manage your monthly budget in the most effective way This plan will keep

repayment plan that is affordable and easy to manage your spending to the minimum alloWing you to save more money for loan

repayment

Permanent Disability Forgiveness r-trTeacher Loan Forgiveness (5 You can get rid of your Federal Student Loan if you are permanently disabled Good news for teachers who are under the weight of a massiVe loan You can

now get $17 forgiven on your student loans

Public Service Loan Forgiveness Custom Debt Relief Plans

Want assistance with debt relief Get in touch with our experts who will help If you are a public service agent you can get rid of your loan after 120 days of design a loan repayment and relief plan for you based on your monthly

income and affordability payments

THERE ARE NO OBLIGATIONS OR COMMITMENTS

want to save thousands of dollars Fill out our form and get relief from your student loan for a more

peaceful tomorrow

Your Name

BiHHHi

Exhibit F 51

Attachment A

Page 2: JOSHUA S. MILLARD, BRIAN M. WELKE, pro hac vice · for which it has no legitimate claim. Noel is a Wyoming limited liability company that reported in a public document that its principal

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 2 of 57 Page ID

1

2

3

4

5

6

7

8

9

10

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12

13

14

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17

18

19

20

21

22

23

24

25

26

27

28

1761

amp Teacher and Aiding Students amp Teachers CAPITAL SUN INVESTMENTS LLC a Wyoming limited liability company also dba Studora TUAN DINH DUONG aka Thomas Duong aka Thomas Dinh individually and as an officer of IMPETUS ENTERPRISE INC BRENDA AVITIA-PENA individually and as an officer of IMPETUS ENTEPRISE INC and FIG TREE amp CO LLC BRIAN COLOMBANA dba FUTERO individually and as an officer of FIG TREE amp CO LLC and JIMMY CALDERON individually and as an officer of CAPITAL SUN INVESTMENTS LLC

Defendants and

NOEL SOLUTIONS LLC a Wyoming limited liability company

Relief Defendant

Plaintiff the Federal Trade Commission (ldquoFTCrdquo) for its Complaint alleges

1 The FTC brings this action under Section 13(b) of the Federal Trade

Commission Act (ldquoFTC Actrdquo) 15 USC sect 53(b) and the Telemarketing and

Consumer Fraud and Abuse Prevention Act (ldquoTelemarketing Actrdquo) 15 USC sectsect

6101-6108 to obtain temporary preliminary and permanent injunctive relief

rescission or reformation of contracts restitution the refund of monies paid

disgorgement of ill-gotten monies and other equitable relief for Defendantsrsquo acts

or practices in violation of Section 5(a) of the FTC Act 15 USC sect 45(a) and the

FTCrsquos Telemarketing Sales Rule (ldquoTSRrdquo) 16 CFR Part 310 in connection with

2

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 3 of 57 Page ID

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

1762

their deceptive marketing and sale of student loan debt relief services

JURISDICTION AND VENUE

2 This Court has subject matter jurisdiction pursuant to 28 USC sectsect

1331 1337(a) and 1345 and 15 USC sectsect 45(a) 53(b) 6102(c) and 6105(b)

3 Venue is proper in this district under 28 USC sect 1391(b)(1) (b)(2)

(c)(1) (c)(2) (c)(3) and (d) and 15 USC sect 53(b)

PLAINTIFF

4 The FTC is an independent agency of the United States Government

created by statute 15 USC sectsect 41-58 The FTC enforces Section 5(a) of the FTC

Act 15 USC sect 45(a) which prohibits unfair or deceptive acts or practices in or

affecting commerce The FTC also enforces the Telemarketing Act 15 USC sectsect

6101-6108 Pursuant to the Telemarketing Act the FTC promulgated and enforces

the TSR 16 CFR Part 310 which prohibits deceptive and abusive telemarketing

acts or practices in or affecting commerce

5 The FTC is authorized to initiate federal district court proceedings by

its own attorneys to enjoin violations of the FTC Act and the TSR and to secure

such equitable relief as may be appropriate in each case including rescission or

reformation of contracts restitution the refund of monies paid and the

disgorgement of ill-gotten monies 15 USC sectsect 53(b) and 6102(c)

DEFENDANTS

6 Defendant Impetus Enterprise Inc (ldquoImpetusrdquo) also doing business

as Aiding Student Relief Aiding Students amp Teachers Aidnest Avec Staffing

National Education Student and Teacher Studora and US Debt Relief is a

California corporation with its principal place of business at 18100 Von Karman

Ave Suite 850 Irvine California 92612 Impetus transacts or has transacted

business in this district and throughout the United States At all times material to

this Complaint acting alone or in concert with others or as part of the common

3

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 4 of 57 Page ID

1

2

3

4

5

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13

14

15

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17

18

19

20

21

22

23

24

25

26

27

28

1763

enterprise described in paragraph 14 Impetus has advertised marketed offered to

provide provided offered for sale or sold student loan debt relief services to

consumers throughout the United States

7 Defendant Fig Tree amp Co LLC (ldquoFig Tree LLCrdquo) also doing

business as Aiding Student Relief Aiding Students amp Teacher and Aiding

Students amp Teachers is a California limited liability company with its principal

place of business at 18100 Von Karman Ave Suite 850 Irvine California 92612

Fig Tree LLC transacts or has transacted business in this district and throughout

the United States At all times material to this Complaint acting alone or in

concert with others or as part of the common enterprise described in paragraph 14

Fig Tree LLC has advertised marketed offered to provide provided offered for

sale or sold student loan debt relief services to consumers throughout the United

States

8 Defendant Capital Sun Investments LLC (ldquoCapital Sunrdquo) also doing

business as Studora is a Wyoming limited liability company with its principal

place of business at 1651 East Fourth Street Suite 124 Santa Ana California

92701 Capital Sun transacts or has transacted business in this district and

throughout the United States At times material to this Complaint acting alone or

in concert with others as part of the common enterprise described in paragraph 14

or as a successor in interest to defendant Impetus Capital Sun has advertised

marketed offered to provide provided offered for sale or sold student loan debt

relief services to consumers throughout the United States

9 Defendant Tuan Dinh Duong also known as Thomas Duong and

Thomas Dinh (ldquoDuongrdquo) has identified himself as or served as the President

director general manager sales manager owner co-owner and principal

shareholder of Impetus At all times material to this Complaint acting alone or in

concert with others he has formulated directed controlled had the authority to

4

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 5 of 57 Page ID

1

2

3

4

5

6

7

8

9

10

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12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

1764

control or participated in the acts and practices set forth in this Complaint

Defendant Duong resides in this district and in connection with the matters alleged

herein transacts or has transacted business in this district and throughout the

United States

10 Defendant Brenda Avitia-Pena (ldquoAvitia-Penardquo) has identified herself

as or served as the President CEO Secretary CFO director and owner of

Impetus and the manager of Fig Tree LLC At all times material to this

Complaint acting alone or in concert with others she has formulated directed

controlled had the authority to control or participated in the acts and practices set

forth in this Complaint Defendant Avitia-Pena resides in this district and in

connection with the matters alleged herein transacts or has transacted business in

this district and throughout the United States

11 Defendant Brian Colombana (ldquoColombanardquo) who has also done

business under the fictitious business name ldquoFuterordquo has identified himself as or

served as co-owner of Impetus (and CIO of its dba Avec Staffing) and manager

of Fig Tree LLC At times material to this Complaint through at least January

2018 acting alone or in concert with others Colombana formulated directed

controlled had the authority to control or participated in the acts and practices set

forth in this Complaint Defendant Colombana resides in this district and in

connection with the matters alleged herein transacts or has transacted business in

this district and throughout the United States

12 Defendant Jimmy Calderon (ldquoCalderonrdquo) has identified himself as and

has served as manager of Capital Sun At times material to this Complaint since at

least September 2017 acting alone or in concert with others Calderon formulated

directed controlled had the authority to control or participated in the acts and

practices set forth in this Complaint Defendant Calderon resides in this district

and in connection with the matters alleged herein transacts or has transacted

5

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 6 of 57 Page ID

1

2

3

4

5

6

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8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

1765

business in this district and throughout the United States

RELIEF DEFENDANT

13 Relief Defendant Noel Solutions LLC (ldquoNoelrdquo) has received funds

that can be traced directly to Defendantsrsquo deceptive acts or practices alleged below

for which it has no legitimate claim Noel is a Wyoming limited liability company

that reported in a public document that its principal place of business is 1623

Central Ave Suite 201 Cheyenne Wyoming 82001 Noel also incorporated as a

California limited liability company in January 2018 listing its address as 18997

Barroso St Rowland Heights California 91748 Noel transacts or has transacted

business in this district and in the district of Wyoming

COMMON ENTERPRISE

14 Defendants Impetus Fig Tree LLC and Capital Sun (ldquoCorporate

Defendantsrdquo) have operated as a common enterprise while engaging in the

unlawful acts and practices alleged below Defendants have conducted the

business practices described below through interrelated companies that have

common ownership officers managers business functions employees and office

locations and routinely transfer funds amongst themselves Because the Corporate

Defendants have operated as a common enterprise each is jointly and severally

liable for the acts and practices alleged below Defendants Duong Avitia-Pena

Colombana and Calderon have formulated directed controlled had the authority

to control or participated in the acts and practices of the Corporate Defendants that

constitute the common enterprise

COMMERCE

15 At all times material to this Complaint Defendants have maintained a

substantial course of trade in or affecting commerce as ldquocommercerdquo is defined in

Section 4 of the FTC Act 15 USC sect 44

6

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 7 of 57 Page ID

1

2

3

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15

16

17

18

19

20

21

22

23

24

25

26

27

28

1766

DEFENDANTSrsquo UNLAWFUL STUDENT LOAN DEBT RELIEF

OPERATION

16 Since at least December 2014 through at least the filing of the FTCrsquos

Complaint in this matter in November 2018 Defendants have operated an unlawful

debt relief scheme that preys on consumers with student loan debt In telephone

calls on websites and in mailed advertising Defendants promise to reduce

consumersrsquo monthly student loan payments and eliminate all or a portion of their

student loan debt through enrollment in student loan forgiveness or repayment

programs In many instances however Defendants failed to obtain debt

forgiveness or monthly payment reductions In fact some consumers owed more

on their student loans after enrolling in Defendantsrsquo program

17 In exchange for the promised student loan debt relief services

Defendants have charged illegal upfront fees of $499 or more

Background on Student Loan Forgiveness and Repayment Programs

18 Student loan debt is the second largest class of consumer debt more

than 42 million Americans collectively owe nearly $15 trillion in student loan

debt The student loan market shows elevated levels of distress relative to other

types of consumer debt

19 To address this mounting level of distressed debt the US

Department of Education (ldquoUSDErdquo) and state government agencies administer a

limited number of student loan forgiveness and discharge programs Most

consumers however do not qualify for these programs because of strict eligibility

requirements For example one program requires the consumer to demonstrate a

total and permanent disability another applies only to consumers whose school

closed while the consumer was still enrolled A third program the Borrower

Defense to Repayment (ldquoBDRrdquo) may provide a loan discharge if the school

through an act or omission violated state law directly related to the borrowerrsquos

7

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 8 of 57 Page ID

1

2

3

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5

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16

17

18

19

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22

23

24

25

26

27

28

1767

federal student loan or to the educational services for which the loan was provided

20 Other forgiveness programs require borrowers to work in certain

professions for a period of years For example Teacher Loan Forgiveness applies

to teachers who have worked full-time for five years in a low-income elementary

or secondary school or educational service agency Public Service Loan

Forgiveness (ldquoPSLFrdquo) applies to employees of governmental units or non-profit

organizations who make timely monthly payments for a period of ten years while

employed in the public sector

21 The federal government also offers loan forgiveness through income-

driven repayment (ldquoIDRrdquo) programs that enable borrowers to reduce their monthly

payments and have portions of their loans forgiven IDR programs allow eligible

borrowers to limit their monthly payments based on a percentage of their

discretionary monthly income To remain in an IDR program borrowers must

recertify their income and family size annually Obtaining forgiveness through

IDR programs requires a minimum of 20 or 25 years of qualifying payments

depending on whether borrowers received their first loans on July 1 2014 or

before that date Because a borrowerrsquos income is likely to fluctuate over the life of

the loan monthly payments under the IDR programs can vary considerably from

year to year If a borrowerrsquos income were to increase over the repayment period

for example the monthly payment amount could correspondingly increase to the

point where those payments would pay off the loan before any amount could be

forgiven at the end of the repayment term No loans have been forgiven yet under

any of the IDR programs because the programs have not existed long enough for

borrowers to make the minimum number of years of qualifying payments

22 Consumers can apply for BDR PSLF IDR and other loan repayment

and forgiveness or discharge programs through USDE or their student loan

servicers at no cost these programs do not require the assistance of a third-party

8

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 9 of 57 Page ID

1

2

3

4

5

6

7

8

9

10

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12

13

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17

18

19

20

21

22

23

24

25

26

27

28

1768

company or payment of application fees

23 USDE will grant forbearance while processing applications for an

alternative repayment plan and in some cases of hardship During forbearance

unpaid interest is added to the principal balance

Defendantsrsquo Deceptive Marketing of Student Loan Debt Relief Services

24 To lure consumers into purchasing their purported student loan debt

relief services Defendants have made false promises to eliminate or reduce

consumersrsquo student loan balances or monthly payments through loan forgiveness

or other programs

25 To induce consumers to purchase their purported student loan debt

relief services Defendants have disseminated websites such as aidingstudentscom

aidnestcom and studoracom including but not necessarily limited to the

attached exhibits A through F Defendantsrsquo websites have contained the following

statements among others

Free Assessment

Our experts will assess your current student loan program and determine

which programs are available in your

situation We will help you decide which

program can help you achieve your goals Call

us today

Service Guarantee

We are committed to helping customers get

lower rates and monthly payments and we will

make the process seamless and

straightforward You will be satisfied with our

service and our commitment to your success Thatrsquos our

guarantee

Ex A at 1 (aidingstudentscom 2015)

9

Success Rate

Our 96 success rate is one of the top ratings in

the industry Our process has been tested and our

success rate proves that it works We can help you reduce and simplify your payments Call us today

Attachment A

----------

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 10 of 57 Page ID

1

2

3

4

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6

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21

22

23

24

25

26

27

28

1769

ldquoWe can help you reduce and simplify your payments Contact one of our specialists today for a free evaluationrdquo

Ex A at 2 (emphasis in original)

ldquolsquoAiding Student Relief has helped countless people reduce their student debt Their proven business plan has led to one of the highest success rates in the industryrsquordquo

Ex A at 4

100 Customer Satisfaction We can help you reduce and simplify your payments Call one of our specialists

today

Ex B at 1 (aidingstudentscom 2016) (emphasis in original)

Meet some of our members who have saved big on their student loan debt Helping You Save Big

ldquoThanks to Aiding Student Relief I am savings [sic] $250 per monthrdquo Michael Martin Entrepreneur

Ex B at 2 (emphasis in original)

ldquoWe can help you reduce and simplify your payments rdquo

Ex C at 1 (aidingstudentscom 2018) (emphasis in original)

Student Loan

Forgiveness

If you have Federal Student Loans yoursquore in the right place to get those

Loan Forgiveness

Get your multiple Federal Student Loans consolidated into one

10

Student Loan

Forgiveness

We understand if yoursquore going through some hardship and thatrsquos why

Attachment A

Case 818-cv-01987-JLS-KES

1

2

3

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5

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7

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28

Document 50-1 Filed 020519 Page 11 of 57 Page ID 1770

loans reduced forgiven or completely discharged through our student loan forgiveness programs

forget about increasing interests [sic] and pay month to month at the lowest possible cost

with us yoursquoll be able to make monthly payments based on your affordability for as low as $000 depending on your situation

Ex D at 2 (aidnestcom 2016)

Lower your loan payments by getting in touch with one of our professionals We design a customized repayment plan that will allow you to make payments based on your monthly income family size and spending Get rid of the hassle of extensive paperwork and get the help you deserve

What we can help you achieve [is] a lower payment or lower rate

Ex E at 6 (aidnestcom 2018) (emphasis in original)

STUDENT LOAN FORGIVENESS

Wersquoll help you get your loans reduced forgiven or

discharged

INCOME BASED PAYMENTS

Make monthly payments based on your affordability

LOAN CONSOLIDATION

Get multiple Federal Student Loans

consolidated into one low monthly payment

Ex F at 1 (studoracom 2018) (emphasis in original)

26 In some instances consumers view the Defendantsrsquo online advertising

and call Defendantsrsquo telemarketers for more information Defendants also make

outbound telemarketing calls and send texts to consumers to offer their services

and convince student loan borrowers to sign up for Defendantsrsquo debt relief

services

11

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 12 of 57 Page ID

1

2

3

4

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28

1771

27 In calls with consumers Defendantsrsquo telemarketers have told

consumers that Defendants can cause consumersrsquo student loan balances to be

reduced or that consumersrsquo loan balances would be forgiven after making lower

monthly payments Defendantsrsquo telemarketers have told some consumers that over

half their loan balance would be forgiven Moreover Defendantsrsquo telemarketers

have told some consumers that their loan payments could or would be rapidly

reduced to $19 per month or promptly forgiven

28 Defendants have made other representations concerning loan

reduction or forgiveness to consumers in telemarketing their debt relief services

For example Defendantsrsquo telemarketers have told one or more consumers that

ldquofamily sizerdquo a metric for determining the amount borrowers pay each month

under IDR plans includes ldquoanyone you help out throughout the year[] they donrsquot

have to live with yourdquo even claiming that helping with ldquogas money three times

out of the yearrdquo is enough to include a person in ldquofamily sizerdquo Further

Defendantsrsquo telemarketers have offered one or more consumers ldquobasically a

guarantee to remainrdquo in an IDR plan and warned one or more consumers that

signing up for an IDR plan with a lender instead would result in a higher loan

payment

29 Defendants have not been likely to achieve the lower monthly

payments or student loan forgiveness they have advertised marketed and

promoted to consumers In many instances Defendants have failed to obtain the

promised lower monthly payments or student loan forgiveness

30 Defendants have charged consumers fees for purported debt relief

services before achieving lower monthly payments or student loan forgiveness

and in many instances have failed to achieve those results at all on behalf of

consumers

12

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 13 of 57 Page ID

1

2

3

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22

23

24

25

26

27

28

1772

31 Defendantsrsquo telemarketers have sought and obtained consumersrsquo

payment information by phone or the Internet

32 Defendantsrsquo total advance fees typically have been in the range of

$300-500 Defendants also have charged consumers recurring monthly fees for

purported debt relief services typically charging $19 per month

THE FTC ACT

33 Section 5(a) of the FTC Act 15 USC sect 45(a) prohibits ldquounfair or

deceptive acts or practices in or affecting commercerdquo

34 Misrepresentations or deceptive omissions of material fact constitute

deceptive acts or practices prohibited by Section 5(a) of the FTC Act

VIOLATIONS OF THE FTC ACT

Count One

(Deceptive Student Loan Debt Relief Representations)

35 In numerous instances in connection with the advertising marketing

promotion offering for sale or sale of student loan debt relief services Defendants

have represented directly or indirectly expressly or by implication that consumers

who purchase Defendantsrsquo debt relief services will or likely will have their

monthly payments reduced or their loan balances forgiven in whole or in part

36 In truth and in fact in numerous instances in which Defendants have

made the representations set forth in Paragraph 35 of this Complaint such

representations were false or not substantiated at the time Defendants made them

37 Therefore Defendantsrsquo representations as set forth in Paragraph 35 of

this Complaint are false or misleading and constitute deceptive acts or practices in

violation of Section 5(a) of the FTC Act 15 USC sect 45(a)

THE TELEMARKETING SALES RULE

38 Congress directed the FTC to prescribe rules prohibiting abusive and

deceptive telemarketing acts or practices pursuant to the Telemarketing Act 15

13

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 14 of 57 Page ID

1

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23

24

25

26

27

28

1773

USC sectsect 6101-6108 in 1994 The FTC adopted the original TSR in 1995

extensively amended it in 2003 and amended certain sections thereafter 16

CFR Part 310

39 Defendants are ldquoseller[s]rdquo or ldquotelemarketer[s]rdquo engaged in

ldquotelemarketingrdquo as defined by the TSR 16 CFR sect 3102(dd) (ff) and (gg) A

ldquosellerrdquo means any person who in connection with a telemarketing transaction

provides offers to provide or arranges for others to provide goods or services to a

customer in exchange for consideration 16 CFR sect 3102(dd) A ldquotelemarketerrdquo

means any person who in connection with telemarketing initiates or receives

telephone calls to or from a customer or donor 16 CFR sect 3102(ff)

ldquoTelemarketingrdquo means a plan program or campaign which is conducted to

induce the purchase of goods or services or a charitable contribution by use of one

or more telephones and which involves more than one interstate telephone call 16

CFR sect 3102(gg)

40 Defendants are sellers or telemarketers of ldquodebt relief servicesrdquo as

defined by the TSR 16 CFR sect 3102(o) Under the TSR a ldquodebt relief servicerdquo

means any program or service represented directly or by implication to

renegotiate settle or in any way alter the terms of payment or other terms of the

debt between a person and one or more unsecured creditors or debt collectors

including but not limited to a reduction in the balance interest rate or fees owed

by a person to an unsecured creditor or debt collector 16 CFR sect 3102(o)

41 The TSR prohibits sellers and telemarketers from requesting or

receiving payment of any fees or consideration for any debt relief service until and

unless

a The seller or telemarketer has renegotiated settled reduced or

otherwise altered the terms of at least one debt pursuant to a

14

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 15 of 57 Page ID

1

2

3

4

5

6

7

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13

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24

25

26

27

28

1774

settlement agreement debt management plan or other such

valid contractual agreement executed by the customer and

b The customer has made at least one payment pursuant to that

settlement agreement debt management plan or other valid

contractual agreement between the customer and the creditor

and

c To the extent that debts enrolled in a service are renegotiated

settled reduced or otherwise altered individually the fee or

consideration either

i Bears the same proportional relationship to the total fee

for renegotiating settling reducing or altering the terms

of the entire debt balance as the individual debt amount

bears to the entire debt amount The individual debt

amount and the entire debt amount are those owed at the

time the debt was enrolled in the service or

ii Is a percentage of the amount saved as a result of the

renegotiation settlement reduction or alteration The

percentage charged cannot change from one individual

debt to another The amount saved is the difference

between the amount owed at the time the debt was

enrolled in the service and the amount actually paid to

satisfy the debt 16 CFR sect 3104(a)(5)(i)

42 The TSR prohibits sellers and telemarketers from misrepresenting

directly or by implication any material aspect of any debt relief service including

but not limited to the amount of money or the percentage of the debt amount that a

customer may save by using the service 16 CFR sect 3103(a)(2)(x)

15

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 16 of 57 Page ID

1

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23

24

25

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27

28

1775

43 Pursuant to Section 3(c) of the Telemarketing Act 15 USC

sect 6102(c) and Section 18(d)(3) of the FTC Act 15 USC sect 57a(d)(3) a violation

of the TSR constitutes an unfair or deceptive act or practice in or affecting

commerce in violation of Section 5(a) of the FTC Act 15 USC sect 45(a)

VIOLATIONS OF THE TELEMARKETING SALES RULE

Count Two

(Advance Fee for Debt Relief Services)

44 In numerous instances in connection with the telemarketing of

student loan debt relief services Defendants have requested or received payment

of a fee or consideration for debt relief services before

a Defendants have renegotiated settled reduced or otherwise

altered the terms of at least one debt pursuant to a settlement

agreement debt management plan or other such valid contractual

agreement executed by the customer and

b The customer has made at least one payment pursuant to that

settlement agreement debt management plan or other valid

contractual agreement between the customer and the creditor

45 Defendantsrsquo acts or practices as described in Paragraph 44 of this

Complaint are abusive telemarketing acts or practices that violate Section

3104(a)(5)(i) of the TSR 16 CFR sect 3104(a)(5)(i)

Count Three

(Material Debt Relief Misrepresentations)

46 In numerous instances in connection with the telemarketing of

student loan debt relief services Defendants have misrepresented directly or

indirectly expressly or by implication material aspects of their debt relief services

including but not limited to that consumers who purchase Defendantsrsquo debt relief

services will or likely will have their monthly payments reduced or their loan

16

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 17 of 57 Page ID

1

2

3

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19

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25

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28

1776

balances forgiven in whole or in part

47 Defendantsrsquo acts and practices as described in Paragraph 46 of this

Complaint are deceptive telemarketing acts or practices that violate Section

3103(a)(2)(x) of the TSR 16 CFR sect 3103(a)(2)(x)

Count Four

(Disgorgement of Ill-Gotten Gains of Relief Defendant)

48 Relief Defendant Noel has received directly or indirectly funds or

other assets from Defendants that are traceable to funds obtained from Defendantsrsquo

customers through the unlawful acts or practices described herein

49 Relief Defendant Noel has no legitimate claim to Defendantsrsquo

customersrsquo funds or other assets and will be unjustly enriched if it is not required to

disgorge the assets or the value of benefits received as a result of Defendantsrsquo

unlawful acts or practices

50 By reason of the foregoing Relief Defendant Noel holds funds and

assets in constructive trust for the benefit of Defendantsrsquo customers

CONSUMER INJURY

51 Consumers have suffered and will continue to suffer substantial injury

as a result of Defendantsrsquo violations of the FTC Act and the TSR In addition

Defendants have been unjustly enriched as a result of their unlawful acts or

practices Absent injunctive relief by this Court Defendants are likely to continue

to injure consumers reap unjust enrichment and harm the public interest

THIS COURTrsquoS POWER TO GRANT RELIEF

52 Section 13(b) of the FTC Act 15 USC sect 53(b) empowers this Court

to grant injunctive and such other relief as the Court may deem appropriate to halt

and redress violations of any provision of law enforced by the FTC The Court in

the exercise of its equitable jurisdiction may award ancillary relief including

rescission or reformation of contracts restitution the refund of monies paid and

17

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 18 of 57 Page ID

1

2

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1777

the disgorgement of ill-gotten monies to prevent and remedy any violation of any

provision of law enforced by the FTC

53 Section 6(b) of the Telemarketing Act 15 USC sect 6105(b)

authorizes this Court to grant such relief as the Court finds necessary to redress

injury to consumers resulting from Defendantsrsquo violations of the TSR including

the rescission or reformation of contracts and the refund of money

PRAYER FOR RELIEF

Wherefore Plaintiff FTC pursuant to Section 13(b) of the FTC Act 15

USC sect 53(b) Section 6(b) of the Telemarketing Act 15 USC sect 6105(b) and

the Courtrsquos own equitable powers requests that the Court

A Award Plaintiff such preliminary injunctive and ancillary relief as

may be necessary to avert the likelihood of consumer injury during

the pendency of this action and to preserve the possibility of effective

final relief including but not limited to temporary and preliminary

injunctions orders freezing assets immediate access to business

premises appointment of a receiver and expedited discovery

B Enter a permanent injunction to prevent future violations of the FTC

Act and the TSR

C Award such relief as the Court finds necessary to redress injury to

consumers resulting from Defendantsrsquo violations of the FTC Act and

the TSR including but not limited to rescission or reformation of

contracts restitution the refund of monies paid and the disgorgement

of ill-gotten monies

D Enter an order requiring Relief Defendant to disgorge all funds and

assets or the value of the benefit it received from the funds and assets

which are traceable to funds obtained from Defendantsrsquo customers

through the unlawful acts or practices described herein and

18

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 19 of 57 Page ID 1778

2

3

E Award Plaintiff the costs of bringing this action as well as such other

and additional relief as the Court may determine to be just and proper

Dated February 5 2019

Respectfully submitted

ALDEN F ABBOTT General Counsel

JosaSMillard Brian M Welke middot Barbara Chun (Local Counsel) Attorneys for Plaintiff FEDERAL TRADE COMMISSION

4

5

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22

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24

25

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27

28

19

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 20 of 57 Page ID 1779

EXHIBIT A

Attachment A

Free Assessment

Our expercs will lt1ssPss you cun ent

swclent lo n program and decermn which progr ms are

avc11l bl rn yoL11 situation We wi I help you cl11cic1e which progr m r1

help you achieve your goals Call us today

Service Guarantee We are commmecl to 11-1 111g

CllStomers get low r rc1ces ancl monthly payments and we w1I

m ke the pror~ss se mless and s r11ghtforwc1rd ou wi ll be sansf1ed

with our service ml OLlr

cornmcmem to you success Thars ow gu~ ancee

Success Rate Ou1 96 ~ surcPss r a e s 11e of he

cop I a ings tn he industry Olr

process has beer tested nd Olli

succ ss r r~ prowbull~ tn t it works

We c n ll~lp yo reduce and -1111ph y our p ~ymP1 ts Call us today

FTC-AID-1

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 21 of 57 Page ID 1780

20

Exhibit A

ABOUT US

We can help you reduce and simplify your pay1ncnts Contact one of our specialists today for

a free evaluation

111middot 1_I 1

101

t I 11111 I I

Itbull 11

Ill fl I I

bull ~ 0 I

What Makes Us Great fa1(li1-_~ tur1ent ~e11ef 11as a taf- o~middot tt a middotel elt1)rns bullJn st1ncb110

1middot1ep yriJ Tibullmiddotest fi 1e-ndly f3ce~ 113ve eirej e1tc-nsve1yr =inj ire

fanih1~1 bull11iu1 ti~e nul~nce~ cfscrvern rrent Cdid p11vate stucre11

l1J1ns Th~y viill u~e Ui5 epe tise o loik jUl fJ ycur ~Je~t

i(tres~- f)LH ~U(CtS~ ~HE 1h-~ I lSllt of i_r middotDff ancl iur

C ur ~r_(J~l 1o~w- JCl11~crs f(middotil) 3 00Vtli ~tJegy o r ~dUC2 011i

a1r1plfy yliur- - _Je1middott middotcar payr1t11s 1) Asstrnlins Itle ~atl1t1

2) R~~ear c1-1ng Our st~lff wmiddoti11 (lrJUi~oleaerick ]ll fnfcnTnati(-n befort dtmiddoteJPlr~ t tne ri~n 3) rnnk1middotgbullle i_i1 i e~ear (rr i~ ormiddot1 1 1 etc 1Ne

irvi-s t1ga~ii 111 ps~ib le a~irst 1n(t aptlbull~n 4) 1Nr1 ting VVF p1 eiv lii J 11 iUen u tt-igy IJefore vie Uke ut1c-1l i)ecius~ you d-ese11e 11) undi r~~anci

Lhe pr 1cer S) ~ev1sing Al)ng ~r 1udent Relief 1- 1otT11111tt bull) ti) ci e1H1ve ut-l-~n~-l)O c111 i ri 3 Vbulle -~11 leave n1) sti bull1e u11t111 neltl tecause middot~ve

11~1ve your be~ i1~ t~rest 1t l1ein 6) Si~tcl11ng Our note- =1nd r~c)1 ~ ~1 e thorou~ll ln(I pru1ile 1 ceJ1 po cri1~ 1)f vo111 ~1tuJticn s) iny if-oi

~xpe1 t- 01 eou pped to s~1ty1J_J bullVi r you1 c si- 7) De-gn1ng _ fe ~1 t 1nelt--1- f1ts ti 1middotV 1middotid de~ 1middot1 1 st1 iegy to fit ou 1 1_i dque jtct1in so

011 c111 i Jle y1)u1 1vv1middot1 per feet -ut1e-s ~~0 1 v

1bullVlly 1100~e At(J1n~ Sltl(ltnt Fie11e7) (i1_d aclol~Or~ bull -ii~ (1Ualiftel lci ~~~ISt~h 1noie ype-s middotif JS~iSi_ance u~211 Cd ( (11)itXS i1 jG(l1~t) to ti-tgt

p ~n~ 1not con1p n1es can 11i1p bullbullllh ve )t ~ ~qu1pptCI to bull-bullGr k 1bullv1t1middot1 r~ 11t-2 [uo emiddot 1 lc1 r1s ~~nCI cn even iner-1ne frmiddot tt1e c ~e of 1l~e

~1lt ntslmiddoturelt A1cl1rg Sudent Fie1ef 1middot cis mmiddote to )fe 11d we offe1 t with middotmiddot1eltbullbe 1es nI 3 rncney lock guMai-itee

We Have Been Featured In

FTC-AID-2

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 22 of 57 Page ID 1781

21

Exhibit A

SERVICES Wt w gtL

Loan Forgiveness Income Based Payments Loan Consol idation In some cases individuals with A period of financial hardship may You may be able to combine

Fede1middota1 Student Loans may qualify qualify you for an Income Based nultiple federal student loans into to have a portion of the amount Repayment Plan In many cases this one new loan w ith a lower more

owed may be forgiven This means means you pay nothing Unlike a affordable monthly payment Loan

your principal balnce coulcl be defe1 ment the term on your loan consolidation prngrams can l1elp

significantly reduced and you will continues to reduce while the plan is you qualify for additional programs not be expected to repay the in place Your term could reduce like loan forgiveness programs or

forgiven amount while you pay nothing Public Setvice Loan Forgiveness

a III

Private Sector Loan Forgiveness

If you work for a government

organization at a city state or

federa l level you may qualify for tle

PL1blic Service Loan Forgiveness

program To qualify your loans

must be cotisolidated into a specific

repayment plan The balance on

your federai student loans is

forgiven after 120 qualifying

bull C Permanent Disability

Forgivenness If your disability is expected to last

60 months or more you may qualify

for permanent disability forgiveness

Q1alifying for Permnent Disability

Forgiveness requires a visi t to your

doctor and individL1als enrolled in

the program are subject to three

years of post-discharge monitoring

Wage Garnishment Prevention

Federal law requires that the

Department of Education or a

gua1middotanty agency notify you before

111st1tuting wage garnishment You

have tl1e right to a hearing where

you can challenge the stated

amount owed and negotiate the

terms of the repayment scheclule

We can intervene on YOL1PflJl~1D-3

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 23 of 57 Page ID 1782

22

Exhibit A

payments have been made p1middotevent wage gampnishments

A FEW STATISTICS ABOUT STUDENT LOAN CRISIS

12 Trillion National Student Debt I he nitionil student loin debt is

now 17 trillion dollirs 1 trillion of

these are in federil student loans

Let us help you through this national

crisis Cill today for a free

evaluation

40 Million Students with Debt

In 7014 an estimated 40 million

current and former students were in

debt because of student loans If

you are one of the millions of people

struggling to pay student loans

Aiding Student Relief is here to help

$33000 Average Student Debt

The graduating class of 7014

average $33000 of student loan

debt per person Thats $3000 more

than the average in 2013 Dont be

one of the many Let Aiding Student

Relief advocate for you

Aiding Student Relief has helped cmrnllcss 1woplc reduce their student debt_ Their proven business

plan has led lo one of lhc highest s11cclSS raCs in the inltl11slly

John Standiford Associated

FTC-AID-4

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 24 of 57 Page ID 1783

23

Exhibit A

TESTIMONIALS

Til~nks to Aiding Student Rel ief Im middotI middotva ove1vvhelrnecl but Aiding The expemiddotts at l1icl i11g Student Rel ief

s1v ing $250 per month Strrd r~rt Relief expl~ inecl the were ther~ to help me when I process ancl rnacle everytl1ing cle11middot nelclecl 1t rw)s t

and sirnple

I Michael Ma 1in

Entrep e11eu1 Em iiy Jallo1 Ii Pa ul Ch is tia I1se11

Teacher Nurse

With so many programs I didnt middotconso lrclating my loans into one I love my Job but vith my high

know what was ng ht for me My monthly payment hs made life student loan payment was still

sruclent loan aclvsor walked me si1nple1 Now I can focus on 1Nhn bamiddotely getting by I don t kn ow what I

through my optio ns rnd now Imiddotn matters to me would hwe clone wthout Aiding

saving 54 I 11n1omh Stucie1middott Rel refmiddot

Ariel Hemiquez Sales co)SUltant

Stephani Seland-1 Small Busim~ss Owner

AJ 01en Museum Curator

RECENT NEWS

)lt)

o(l ttDrlTI -5

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 25 of 57 Page ID 1784

24

Exhibit A

Student Debt Crisis Business Latest Debt Collective Demands May be largely about smallest Student

borrnwers US News amp World Loan Crisis is fa frorn ove The Debt Collective is a group of Report-May 162015 last month Two new reports suggest the college students calling the Fedemiddotal Reserve Bank of New student loan crisis is easing them-se1ves the Corinthian York repor ced that stuclent loan somewhat as the economy Fifteen who are refusing to pay balances rose to 16 trillio n and improves but the crisis is far back their student loins As pa t that 113 per cent of that is in from ove the College Board of this effort the Debt Collective repo t~ tot31 borrowing fell by 8 has written an open lette to the pEbull1 cent between 2012-13 and Department of Education f l llJ 20 13-14 The organization

About Us 11 1 i~d1middot1r F th~~- h1~ ff t1middot~11middot=cl =i~=middott- 1middot __31middotmiddotIIgt middot bullmiddot11

middot- I ( )ntir il t l~i -r_il fr~~

Address bull middot tc1ltj-1r_ =i ~

middot l t1~t 1middot1 fcJ middot~_1 1 I l11 - Hbull 1 tr

~t (~~ 1 12bull~11 T 1 1- - 8555105400

FTC-AID-6

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 26 of 57 Page ID 1785

25

Exhibit A

f - g+ in O) ~ PRIVACY POLICY

This privacy statement discloses the privacy practices for AidllII Student Relief Because Aiding Studen Relief wonts to demonstrate ts firm commlcmell to your

privacy Aiding Sudent Relief hes greed to disclose ls 1rifor111atlori g1thering and dlssem1n1t1on prct1cts Aidlns Studtrit Relief will notify you of

INFORMATION COLLECTION At-ID USE

Aiding Student Relief is the sole owner of the rformMlon collected on this site We will not sell shire or rent this information 10 others In way different from what Is

disclosed 1n this statement Aldln1 StudeM Relief collects 1nform111on throuah this site from our prospective end existing clients at several different poin on our web

site We use their contact Informii on to send information bout our company and to service exsMs accounts Users may optbullout of rece11ns future malllngs see the

cholceoptbullout section below Contect and Financial information that 1s collected Is used for verifying your name address and other informa1on as well as to boll you for

your use of our Gerv1ces using Information from third party sourcH Information about your computer hardwre and software Is automatically collected by Aiding

Student Relief and may be shared in asgregate with third parties whose services are used for traffic analysis purposes This Ir formation includes your IP address

browser type domain names access times and referring Web site addresses Ths information is no tied to personally Identifiable Information This 1nformatlor s used

by Aiding Student Relief to malMan no Improve the quality of the Hrvct and to senerae statistics resardlng use of he Aiding Student Relief site We use third party

services to bill for serlces and to provide other services like our Live Help chat We store the transcripts from these chats for customer service Improvement These

third party service providers are not permitted to use your infornon for any secondary purposes

Thank you and cheers

FTC-AID-7

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 27 of 57 Page ID 1786

26

Exhibit A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 28 of 57 Page ID 1787

EXHIBIT B

Attachment A

((

z | ~

AIDINGSTUDENTRELIEF

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27

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8

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^ ˙ ( (

28

Attachment A

01 $2 301 $$3 ( Exhibit B

()(

=4ABC9DEAFBD=FGFHIJKLMJNOMN MRNS mn = nrst = svzhellipu t bulltvDaggerrhellipDaggerurbullbulltuhellipv hellipz~ bullmdashldquordquolsquorsquotrade š oŒŠeuro centpound ` umluml 13 deg $ $ampdegdeg degˇ amp $$deg + -+Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 31 of 57 Page ID 1790

ISNRTUKQINKKNNKL[MRJ PUWQI]MRM qyt|tytzxy rsaquoqNfraslbdquoPUhellipsbquoLUyQhellip rfraslbhellipMNSIKVUQ QNJKvUQsMiexclQQJUx[iexcliexcl_vsect_Qyenyenbrvbarbrvbar uSSRNTPL_LUUMKIaJ_WMIJJKVIONNQJJMWRMIIbQQURKLWIIJQbKLUNKMPTMNQQ_KKRY tbullbulldaggersDaggerv~vhellipmdashryrhellip~mdashrhellipDagger ŸLŽUıQŽbłpermilMtradeœsbquoNtrade_ffRŁyISMŒUQWyNUQŠlsaquo rv45657896lt7ltgt5lt PQKLMIQSNRTUKINQVNOOMVKMWNQKLIJPMXJIKMYZMPIOO NJMOOJLURMNRRMKKLIJ klltko ltgtlt85p5gt5 ouvwxrz ^^ ~ minuspermil tffŁ yenpoundpound KNOWDaggerIreggt4lt97ltndash9ƒ Dagger hellipDaggerlsaquo žko74k57ƒ ƒISNcurrenUIWIbJKWMKJYVNTKM KLONNRqIQQSNNRTUKINQQIJ_JMWNQKLIJJJPMXJIKMcOMUJMVNQKUVK_JUKBHdefABCgDEAFBDghidjlaquopoundbrvbariexclnotvIWIQbDaggerK_WMQKbullMOIMSvOObullIbLKJbullMJMRMW ordf copy

01( $2(301$$3( Exhibit B

29

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 32 of 57 Page ID 1791

EXHIBIT C

Attachment A

~ 111 ~tampi 10 11 ~bull ia1111

Something awesome is coming soon We are buildin somethin ve cool Sta tuned and be at1ent Your atience will be well aid

~lbullrbullUiUffl We can help you reduce and simplify your payments

101 Loan For iveness

1~u 0 (middottmiddotbullmiddotmiddot1 1~=I -- _~

HZamp IMUliULlampRampatiEUWi nmiddot middot-il~ fr middot 8rbullbullrcrr-

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~ Income Based Pa ents

bull ~ f I - - I - I - ri u ~u-=lf ~ JU

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JJd r g-_iraE-1 agltr-middot- ntimiddot middot)middotou

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Exhibit C

Case 818-cv-01987-JLS

-KE

S

Docum

ent 50-1 F

iled 020519 P

age 33 of 57 P

age ID 1792

30

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 34 of 57 Page ID 1793

EXHIBIT D

Attachment A

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Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 35 of 57 Page ID 1794

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

infoaidnestcom (800) 555-1212

HOME

ABOUT US

SERVICES

FAQ

BLOG

CONTACT

HOME ABOUT US SERVICES FAQ BLOG CONTACT

1 of 6 462018 945 AM

31

Student Loan Forgiveness Loan Consolidation Student Loan Forgiveness

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 36 of 57 Page ID 1795

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

If you have Federal Student Loans yoursquore in the right place to get those loans reduced forgiven or completely discharged through our student loan forgiveness programs

Get your multiple Federal Student Loans consolidated into one forget about increasing interests and pay month to month at the lowest possible cost

We understand if yoursquore going through some hardship and thatrsquos why with us yoursquoll be able to make monthly payments based on your affordability for as low as $000 depending on your situation

2 of 6 462018 945 AM

32

Knowledge Base

Defaulted Student Loans

Wage Garnishment

Student Loan Rehabilitation

Income Based Repayment Plan

Deferment and Forbearance

Pay As You Earn Repayment Plan

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE Call 561)424-6053 today to go over your options

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 37 of 57 Page ID 1796

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

Our knowledge base is designed to provide information regarding some of the critical topics those with student loans must be aware of to be able to make educated decisions regarding their future

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

A wage garnishment is any legal procedure in which some portion of a personrsquos earnings is required to be withheld by an employer for the payment of a debt

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

With this program your payments change as your income changes and will not be longer than 25 years This is the ideal plan if you are in partial financial hardship Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard plan

Temporarily allowing you to postpone or reduce your federal student loan payments Postponing or reducing your payments may help you avoid default and future garnishments

Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard

3 of 6 462018 945 AM

33

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 38 of 57 Page ID 1797

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

4 of 6 462018 945 AM

34Attachment A

Testimonials

Latest News

Why 2016 Will Be a Big Year For Student Loans

Top Student Loan Refinancing Questions of 2015

Oba mas latest student loan plan

Things You Should Know About Public Service Loan Forgiveness

Recent Posts

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 39 of 57 Page ID 1798

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

5 of 6 462018 945 AM

35

About Us

Contact Info

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 40 of 57 Page ID 1799

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

pay-grandchild-studen

Why 2016 Will Be a Big Year For Student Loans

December 30 2015

12511110_1112367518

Top Student Loan Refinancing Questions of 2015

December 30 2015

We stand by our consultation and quote We are so sure and confident about our services and offers that they are all 100 money back guarantee risk free ndash if we donrsquot do what we promise yoursquoll get your money back

(800) 555-1212 AidnestStudenLoansgmailcom 18100 Von Karman Ave Suite 850 Irvine CA 92612

Futero SAS copy 2015 | Aidnestcom

6 of 6 462018 945

Exhibit D 36Attachment A

AM

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 41 of 57 Page ID 1800

EXHIBIT E

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 42 of 57 Page ID 1801

AIDNEST Let us help you through this national crisis

Call one of our specialists today

Forbearance amp Deferment If you are still in school and struggling to make payments on your student loans You may qualify

for Forbearance amp Deferment

Garnishment Prevention Federal law requires that the Department of Education or guarantee agency notifies you before they

begin garnishing your wages

Loan Forgiveness If you are a teacher public service worker or an individual with total and permanent disability you

httpaidnestcom[442018 115239 AM]

37Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 43 of 57 Page ID 1802

AIDNEST Let us help you through this national crisis

may qualify for this program

Consolidating Your Loans Consolidating your loans to one new loan under one lender may lower your payments and make

your life a bit more manageable

Affordable Payments If you are looking to lower your monthly payments then Income Based Repayment Plans may be

the correct choice for you

Learn more about our services

LEARN MORE

httpaidnestcom[442018 115239 AM]

38Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 44 of 57 Page ID 1803

AIDNEST Let us help you through this national crisis

Loan Forgiveness Programs Income Based Payments Student Loan Rehabilitation

Student Loan Consolidation

You may be eligible for

Loan Forgiveness Programs

In some cases individuals with Federal Student Loans may qualify to have a portion of the amount

owed to be forgiven

Get in touch with our professional team to find out which loan forgiveness program you qualify for and

how you can get rid of your unpaid student loan

L EARN MORE

httpaidnestcom[442018 115239 AM]

39Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 45 of 57 Page ID 1804

AIDNEST Let us help you through this national crisis

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE

Meet your Budget One of our advisers will help you meet your payment goals by using your budget and timeline to

determine the best plan available

httpaidnestcom[442018 115239 AM]

40Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 46 of 57 Page ID 1805

AIDNEST Let us help you through this national crisis

Simple Process We understand that lowering your payments alone can be difficult Our intuitive platform allows us

to keep the entire process simple

Customer Satisfaction We are committed to providing you with outstanding service only We look forward to working

with you

100 money back guarantee No Hassle Money Back Policy

httpaidnestcom[442018 115239 AM]

41Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 47 of 57 Page ID 1806

AIDNEST Let us help you through this national crisis

Lower your loan payments by getting in touch with one of our professionals

We design a customized repayment plan that will allow you to make payments based on your

monthly income family size and spending Get rid of the hassle of extensive paperwork and get the

help you deserve

What we can help you achieve a lower payment or lower rate

httpaidnestcom[442018 115239 AM]

42Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 48 of 57 Page ID 1807

AIDNEST Let us help you through this national crisis

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcom[442018 115239 AM]

43Exhibit E

httpaidnestcomservices[442018 115322 AM]

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 49 of 57 Page ID 1808

Services | AIDNEST Let us help you through this national crisis

INCOME BASED PAYMENTS

If you are suffering from a financial hardship you may be eligible for an

Income Based Payment In this repayment program you would have a

payment based on your income and family size The payment could be as

low as $000 per month with forgiveness at the end of 20-25 years

44

Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 50 of 57 Page ID 1809

L E ARN MORE

LOAN FORGIVENESS

If you have Federal Student Loans you may qualify for any of the student

loan forgiveness programs that are available to borrowers You may be

eligible for principal reduction loan forgiveness or a complete loan

discharge depending on your individual circumstance

L EARN MORE

PRIVATE STUDENT LOAN CONSOLIDATION

Much like refinancing a mortgage generally the biggest benefit of private

student loan consolidationstudent loan refinancing is a lower interest rate

httpaidnestcomservices[442018 115322 AM]

45Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 51 of 57 Page ID 1810

L E ARN MORE

(something federal consolidations do not offer)

STUDENT LOAN REHABILITATION

You can renew eligibility for new loans and grants and eliminate the loan

default by ldquorehabilitatingrdquo a defaulted loan

httpaidnestcomservices[442018 115322 AM]

46Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 52 of 57 Page ID 1811

CHE CK E L E G I B I L I T Y

WAGE GARNISHMENT

A wage garnishment is any legal procedure in which some portion of a

personrsquos earnings is required to be withheld by an employer for the

payment of a debt

L EARN MORE

With our fast friendly and professional services wersquoll be glad to help you get your student loans

reduced forgiven or completely discharged To this end wersquoll assist you in consolidating all your

student loans so yoursquoll have only one lender and yoursquoll start making one monthly payment Our

professionals will walk you through the best and most flexible repayment options and if itrsquos also

necessary varied deferment options and rehabilitation programs

httpaidnestcomservices[442018 115322 AM]

47Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 53 of 57 Page ID 1812

Services | AIDNEST Let us help you through this national crisis

Our CRM System

Our CRM is one of the most advanced in the industry and most importantly itrsquos linked directly to

the Department of Education (DOE) This keeps your personal and most confidential information

safe Furthermore because our CRM system is linked to the DOE our approval is 100 Through

our CRM we will be doing continuous monitoring of our process without losing sight of your

immediate needs ensuring that your case has the proper handling and most efficient process

httpaidnestcomservices[442018 115322 AM]

48Exhibit E

n

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 54 of 57 Page ID 1813

Services | AIDNEST Let us help you through this national crisis

R ECENT POSTS

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

ABOUT US

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcomservices[442018 115322 AM]

49Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 55 of 57 Page ID 1814

EXHIBIT F

s -

bullmiddot - ~ t ~ower Your Student Loan Pay~e~ts oday -- Students Helping Students Save Money

INCOME BASED PAJIIIJITPAIS

I C(gttoUC1 u~

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 56 of 57 Page ID 1815

X + C (D Not secure wwwstudoracom 0

CALL US NOW (85S) 978-S599 middot 1nfostudoracom

HOME SERVICES ABOUT US FAQ CONTACT US BLOC PRIVACY

Offering obligation and commitment free loan relief solutions

STUDENT LOAN FORGIVENESS INCOME BASED PAYMENTS LOAN CONSOLIDATION

We11 help you get your loans reduced forgiven o r Make monthly pdyments based on your affordability Get multiple Federal Student Loans consolidated into

discharged one low monthly payment

Talk to our experts concerning your

student loans

Studora is a pnvatefy owned company that helps consumers like you identify

government programs that fit your financial s1tuat1on Our loan experts will assist you in selecting the appropriate programs that WOltk with your income family size and

desired monthly payment We then prepare the appropriate documents for your review and submission All this f o r one low easy payment

Testimonials

Thank you f o r getting back to me quickly Youve been fabulous Thank you for the confirmation and for your help today Pass

during this whole process Is there a place I can go online that I this on to your sup that you were very professional and very

can leave a comment for your manager Youve made this Robert helpful and brought a sense of relief for me Thank you very

process so easy and answered every question my husband and I much and have a great rest of your day Kudos to you and your

have had teammoneywell spenL

Exhibit F 50

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 57 of 57 Page ID 1816

Services we offer

Stud ora offers document preparation services for all loan forgiveness consolidation and relief services to people who are unable to manage their finances Our mam aim is to

offer complete peace of mind to indiVidual unable to pay their student loan debt

we otter the folloWing document preparation services with complete professional assistance

amFinancial Review ffl Budget Planning

Toe first step to creating a flexible loan repayment plan is financial review we also help create a personal finance plan to ensure that you are able to

Our professmnals will look into your finances and design a custom manage your monthly budget in the most effective way This plan will keep

repayment plan that is affordable and easy to manage your spending to the minimum alloWing you to save more money for loan

repayment

Permanent Disability Forgiveness r-trTeacher Loan Forgiveness (5 You can get rid of your Federal Student Loan if you are permanently disabled Good news for teachers who are under the weight of a massiVe loan You can

now get $17 forgiven on your student loans

Public Service Loan Forgiveness Custom Debt Relief Plans

Want assistance with debt relief Get in touch with our experts who will help If you are a public service agent you can get rid of your loan after 120 days of design a loan repayment and relief plan for you based on your monthly

income and affordability payments

THERE ARE NO OBLIGATIONS OR COMMITMENTS

want to save thousands of dollars Fill out our form and get relief from your student loan for a more

peaceful tomorrow

Your Name

BiHHHi

Exhibit F 51

Attachment A

Page 3: JOSHUA S. MILLARD, BRIAN M. WELKE, pro hac vice · for which it has no legitimate claim. Noel is a Wyoming limited liability company that reported in a public document that its principal

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 3 of 57 Page ID

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

1762

their deceptive marketing and sale of student loan debt relief services

JURISDICTION AND VENUE

2 This Court has subject matter jurisdiction pursuant to 28 USC sectsect

1331 1337(a) and 1345 and 15 USC sectsect 45(a) 53(b) 6102(c) and 6105(b)

3 Venue is proper in this district under 28 USC sect 1391(b)(1) (b)(2)

(c)(1) (c)(2) (c)(3) and (d) and 15 USC sect 53(b)

PLAINTIFF

4 The FTC is an independent agency of the United States Government

created by statute 15 USC sectsect 41-58 The FTC enforces Section 5(a) of the FTC

Act 15 USC sect 45(a) which prohibits unfair or deceptive acts or practices in or

affecting commerce The FTC also enforces the Telemarketing Act 15 USC sectsect

6101-6108 Pursuant to the Telemarketing Act the FTC promulgated and enforces

the TSR 16 CFR Part 310 which prohibits deceptive and abusive telemarketing

acts or practices in or affecting commerce

5 The FTC is authorized to initiate federal district court proceedings by

its own attorneys to enjoin violations of the FTC Act and the TSR and to secure

such equitable relief as may be appropriate in each case including rescission or

reformation of contracts restitution the refund of monies paid and the

disgorgement of ill-gotten monies 15 USC sectsect 53(b) and 6102(c)

DEFENDANTS

6 Defendant Impetus Enterprise Inc (ldquoImpetusrdquo) also doing business

as Aiding Student Relief Aiding Students amp Teachers Aidnest Avec Staffing

National Education Student and Teacher Studora and US Debt Relief is a

California corporation with its principal place of business at 18100 Von Karman

Ave Suite 850 Irvine California 92612 Impetus transacts or has transacted

business in this district and throughout the United States At all times material to

this Complaint acting alone or in concert with others or as part of the common

3

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 4 of 57 Page ID

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

1763

enterprise described in paragraph 14 Impetus has advertised marketed offered to

provide provided offered for sale or sold student loan debt relief services to

consumers throughout the United States

7 Defendant Fig Tree amp Co LLC (ldquoFig Tree LLCrdquo) also doing

business as Aiding Student Relief Aiding Students amp Teacher and Aiding

Students amp Teachers is a California limited liability company with its principal

place of business at 18100 Von Karman Ave Suite 850 Irvine California 92612

Fig Tree LLC transacts or has transacted business in this district and throughout

the United States At all times material to this Complaint acting alone or in

concert with others or as part of the common enterprise described in paragraph 14

Fig Tree LLC has advertised marketed offered to provide provided offered for

sale or sold student loan debt relief services to consumers throughout the United

States

8 Defendant Capital Sun Investments LLC (ldquoCapital Sunrdquo) also doing

business as Studora is a Wyoming limited liability company with its principal

place of business at 1651 East Fourth Street Suite 124 Santa Ana California

92701 Capital Sun transacts or has transacted business in this district and

throughout the United States At times material to this Complaint acting alone or

in concert with others as part of the common enterprise described in paragraph 14

or as a successor in interest to defendant Impetus Capital Sun has advertised

marketed offered to provide provided offered for sale or sold student loan debt

relief services to consumers throughout the United States

9 Defendant Tuan Dinh Duong also known as Thomas Duong and

Thomas Dinh (ldquoDuongrdquo) has identified himself as or served as the President

director general manager sales manager owner co-owner and principal

shareholder of Impetus At all times material to this Complaint acting alone or in

concert with others he has formulated directed controlled had the authority to

4

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 5 of 57 Page ID

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

1764

control or participated in the acts and practices set forth in this Complaint

Defendant Duong resides in this district and in connection with the matters alleged

herein transacts or has transacted business in this district and throughout the

United States

10 Defendant Brenda Avitia-Pena (ldquoAvitia-Penardquo) has identified herself

as or served as the President CEO Secretary CFO director and owner of

Impetus and the manager of Fig Tree LLC At all times material to this

Complaint acting alone or in concert with others she has formulated directed

controlled had the authority to control or participated in the acts and practices set

forth in this Complaint Defendant Avitia-Pena resides in this district and in

connection with the matters alleged herein transacts or has transacted business in

this district and throughout the United States

11 Defendant Brian Colombana (ldquoColombanardquo) who has also done

business under the fictitious business name ldquoFuterordquo has identified himself as or

served as co-owner of Impetus (and CIO of its dba Avec Staffing) and manager

of Fig Tree LLC At times material to this Complaint through at least January

2018 acting alone or in concert with others Colombana formulated directed

controlled had the authority to control or participated in the acts and practices set

forth in this Complaint Defendant Colombana resides in this district and in

connection with the matters alleged herein transacts or has transacted business in

this district and throughout the United States

12 Defendant Jimmy Calderon (ldquoCalderonrdquo) has identified himself as and

has served as manager of Capital Sun At times material to this Complaint since at

least September 2017 acting alone or in concert with others Calderon formulated

directed controlled had the authority to control or participated in the acts and

practices set forth in this Complaint Defendant Calderon resides in this district

and in connection with the matters alleged herein transacts or has transacted

5

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 6 of 57 Page ID

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

1765

business in this district and throughout the United States

RELIEF DEFENDANT

13 Relief Defendant Noel Solutions LLC (ldquoNoelrdquo) has received funds

that can be traced directly to Defendantsrsquo deceptive acts or practices alleged below

for which it has no legitimate claim Noel is a Wyoming limited liability company

that reported in a public document that its principal place of business is 1623

Central Ave Suite 201 Cheyenne Wyoming 82001 Noel also incorporated as a

California limited liability company in January 2018 listing its address as 18997

Barroso St Rowland Heights California 91748 Noel transacts or has transacted

business in this district and in the district of Wyoming

COMMON ENTERPRISE

14 Defendants Impetus Fig Tree LLC and Capital Sun (ldquoCorporate

Defendantsrdquo) have operated as a common enterprise while engaging in the

unlawful acts and practices alleged below Defendants have conducted the

business practices described below through interrelated companies that have

common ownership officers managers business functions employees and office

locations and routinely transfer funds amongst themselves Because the Corporate

Defendants have operated as a common enterprise each is jointly and severally

liable for the acts and practices alleged below Defendants Duong Avitia-Pena

Colombana and Calderon have formulated directed controlled had the authority

to control or participated in the acts and practices of the Corporate Defendants that

constitute the common enterprise

COMMERCE

15 At all times material to this Complaint Defendants have maintained a

substantial course of trade in or affecting commerce as ldquocommercerdquo is defined in

Section 4 of the FTC Act 15 USC sect 44

6

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 7 of 57 Page ID

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

1766

DEFENDANTSrsquo UNLAWFUL STUDENT LOAN DEBT RELIEF

OPERATION

16 Since at least December 2014 through at least the filing of the FTCrsquos

Complaint in this matter in November 2018 Defendants have operated an unlawful

debt relief scheme that preys on consumers with student loan debt In telephone

calls on websites and in mailed advertising Defendants promise to reduce

consumersrsquo monthly student loan payments and eliminate all or a portion of their

student loan debt through enrollment in student loan forgiveness or repayment

programs In many instances however Defendants failed to obtain debt

forgiveness or monthly payment reductions In fact some consumers owed more

on their student loans after enrolling in Defendantsrsquo program

17 In exchange for the promised student loan debt relief services

Defendants have charged illegal upfront fees of $499 or more

Background on Student Loan Forgiveness and Repayment Programs

18 Student loan debt is the second largest class of consumer debt more

than 42 million Americans collectively owe nearly $15 trillion in student loan

debt The student loan market shows elevated levels of distress relative to other

types of consumer debt

19 To address this mounting level of distressed debt the US

Department of Education (ldquoUSDErdquo) and state government agencies administer a

limited number of student loan forgiveness and discharge programs Most

consumers however do not qualify for these programs because of strict eligibility

requirements For example one program requires the consumer to demonstrate a

total and permanent disability another applies only to consumers whose school

closed while the consumer was still enrolled A third program the Borrower

Defense to Repayment (ldquoBDRrdquo) may provide a loan discharge if the school

through an act or omission violated state law directly related to the borrowerrsquos

7

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 8 of 57 Page ID

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

1767

federal student loan or to the educational services for which the loan was provided

20 Other forgiveness programs require borrowers to work in certain

professions for a period of years For example Teacher Loan Forgiveness applies

to teachers who have worked full-time for five years in a low-income elementary

or secondary school or educational service agency Public Service Loan

Forgiveness (ldquoPSLFrdquo) applies to employees of governmental units or non-profit

organizations who make timely monthly payments for a period of ten years while

employed in the public sector

21 The federal government also offers loan forgiveness through income-

driven repayment (ldquoIDRrdquo) programs that enable borrowers to reduce their monthly

payments and have portions of their loans forgiven IDR programs allow eligible

borrowers to limit their monthly payments based on a percentage of their

discretionary monthly income To remain in an IDR program borrowers must

recertify their income and family size annually Obtaining forgiveness through

IDR programs requires a minimum of 20 or 25 years of qualifying payments

depending on whether borrowers received their first loans on July 1 2014 or

before that date Because a borrowerrsquos income is likely to fluctuate over the life of

the loan monthly payments under the IDR programs can vary considerably from

year to year If a borrowerrsquos income were to increase over the repayment period

for example the monthly payment amount could correspondingly increase to the

point where those payments would pay off the loan before any amount could be

forgiven at the end of the repayment term No loans have been forgiven yet under

any of the IDR programs because the programs have not existed long enough for

borrowers to make the minimum number of years of qualifying payments

22 Consumers can apply for BDR PSLF IDR and other loan repayment

and forgiveness or discharge programs through USDE or their student loan

servicers at no cost these programs do not require the assistance of a third-party

8

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 9 of 57 Page ID

1

2

3

4

5

6

7

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12

13

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17

18

19

20

21

22

23

24

25

26

27

28

1768

company or payment of application fees

23 USDE will grant forbearance while processing applications for an

alternative repayment plan and in some cases of hardship During forbearance

unpaid interest is added to the principal balance

Defendantsrsquo Deceptive Marketing of Student Loan Debt Relief Services

24 To lure consumers into purchasing their purported student loan debt

relief services Defendants have made false promises to eliminate or reduce

consumersrsquo student loan balances or monthly payments through loan forgiveness

or other programs

25 To induce consumers to purchase their purported student loan debt

relief services Defendants have disseminated websites such as aidingstudentscom

aidnestcom and studoracom including but not necessarily limited to the

attached exhibits A through F Defendantsrsquo websites have contained the following

statements among others

Free Assessment

Our experts will assess your current student loan program and determine

which programs are available in your

situation We will help you decide which

program can help you achieve your goals Call

us today

Service Guarantee

We are committed to helping customers get

lower rates and monthly payments and we will

make the process seamless and

straightforward You will be satisfied with our

service and our commitment to your success Thatrsquos our

guarantee

Ex A at 1 (aidingstudentscom 2015)

9

Success Rate

Our 96 success rate is one of the top ratings in

the industry Our process has been tested and our

success rate proves that it works We can help you reduce and simplify your payments Call us today

Attachment A

----------

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 10 of 57 Page ID

1

2

3

4

5

6

7

8

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10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

1769

ldquoWe can help you reduce and simplify your payments Contact one of our specialists today for a free evaluationrdquo

Ex A at 2 (emphasis in original)

ldquolsquoAiding Student Relief has helped countless people reduce their student debt Their proven business plan has led to one of the highest success rates in the industryrsquordquo

Ex A at 4

100 Customer Satisfaction We can help you reduce and simplify your payments Call one of our specialists

today

Ex B at 1 (aidingstudentscom 2016) (emphasis in original)

Meet some of our members who have saved big on their student loan debt Helping You Save Big

ldquoThanks to Aiding Student Relief I am savings [sic] $250 per monthrdquo Michael Martin Entrepreneur

Ex B at 2 (emphasis in original)

ldquoWe can help you reduce and simplify your payments rdquo

Ex C at 1 (aidingstudentscom 2018) (emphasis in original)

Student Loan

Forgiveness

If you have Federal Student Loans yoursquore in the right place to get those

Loan Forgiveness

Get your multiple Federal Student Loans consolidated into one

10

Student Loan

Forgiveness

We understand if yoursquore going through some hardship and thatrsquos why

Attachment A

Case 818-cv-01987-JLS-KES

1

2

3

4

5

6

7

8

9

10

11

12

13

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15

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19

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22

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24

25

26

27

28

Document 50-1 Filed 020519 Page 11 of 57 Page ID 1770

loans reduced forgiven or completely discharged through our student loan forgiveness programs

forget about increasing interests [sic] and pay month to month at the lowest possible cost

with us yoursquoll be able to make monthly payments based on your affordability for as low as $000 depending on your situation

Ex D at 2 (aidnestcom 2016)

Lower your loan payments by getting in touch with one of our professionals We design a customized repayment plan that will allow you to make payments based on your monthly income family size and spending Get rid of the hassle of extensive paperwork and get the help you deserve

What we can help you achieve [is] a lower payment or lower rate

Ex E at 6 (aidnestcom 2018) (emphasis in original)

STUDENT LOAN FORGIVENESS

Wersquoll help you get your loans reduced forgiven or

discharged

INCOME BASED PAYMENTS

Make monthly payments based on your affordability

LOAN CONSOLIDATION

Get multiple Federal Student Loans

consolidated into one low monthly payment

Ex F at 1 (studoracom 2018) (emphasis in original)

26 In some instances consumers view the Defendantsrsquo online advertising

and call Defendantsrsquo telemarketers for more information Defendants also make

outbound telemarketing calls and send texts to consumers to offer their services

and convince student loan borrowers to sign up for Defendantsrsquo debt relief

services

11

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 12 of 57 Page ID

1

2

3

4

5

6

7

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13

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17

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22

23

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25

26

27

28

1771

27 In calls with consumers Defendantsrsquo telemarketers have told

consumers that Defendants can cause consumersrsquo student loan balances to be

reduced or that consumersrsquo loan balances would be forgiven after making lower

monthly payments Defendantsrsquo telemarketers have told some consumers that over

half their loan balance would be forgiven Moreover Defendantsrsquo telemarketers

have told some consumers that their loan payments could or would be rapidly

reduced to $19 per month or promptly forgiven

28 Defendants have made other representations concerning loan

reduction or forgiveness to consumers in telemarketing their debt relief services

For example Defendantsrsquo telemarketers have told one or more consumers that

ldquofamily sizerdquo a metric for determining the amount borrowers pay each month

under IDR plans includes ldquoanyone you help out throughout the year[] they donrsquot

have to live with yourdquo even claiming that helping with ldquogas money three times

out of the yearrdquo is enough to include a person in ldquofamily sizerdquo Further

Defendantsrsquo telemarketers have offered one or more consumers ldquobasically a

guarantee to remainrdquo in an IDR plan and warned one or more consumers that

signing up for an IDR plan with a lender instead would result in a higher loan

payment

29 Defendants have not been likely to achieve the lower monthly

payments or student loan forgiveness they have advertised marketed and

promoted to consumers In many instances Defendants have failed to obtain the

promised lower monthly payments or student loan forgiveness

30 Defendants have charged consumers fees for purported debt relief

services before achieving lower monthly payments or student loan forgiveness

and in many instances have failed to achieve those results at all on behalf of

consumers

12

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 13 of 57 Page ID

1

2

3

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5

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13

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16

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18

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21

22

23

24

25

26

27

28

1772

31 Defendantsrsquo telemarketers have sought and obtained consumersrsquo

payment information by phone or the Internet

32 Defendantsrsquo total advance fees typically have been in the range of

$300-500 Defendants also have charged consumers recurring monthly fees for

purported debt relief services typically charging $19 per month

THE FTC ACT

33 Section 5(a) of the FTC Act 15 USC sect 45(a) prohibits ldquounfair or

deceptive acts or practices in or affecting commercerdquo

34 Misrepresentations or deceptive omissions of material fact constitute

deceptive acts or practices prohibited by Section 5(a) of the FTC Act

VIOLATIONS OF THE FTC ACT

Count One

(Deceptive Student Loan Debt Relief Representations)

35 In numerous instances in connection with the advertising marketing

promotion offering for sale or sale of student loan debt relief services Defendants

have represented directly or indirectly expressly or by implication that consumers

who purchase Defendantsrsquo debt relief services will or likely will have their

monthly payments reduced or their loan balances forgiven in whole or in part

36 In truth and in fact in numerous instances in which Defendants have

made the representations set forth in Paragraph 35 of this Complaint such

representations were false or not substantiated at the time Defendants made them

37 Therefore Defendantsrsquo representations as set forth in Paragraph 35 of

this Complaint are false or misleading and constitute deceptive acts or practices in

violation of Section 5(a) of the FTC Act 15 USC sect 45(a)

THE TELEMARKETING SALES RULE

38 Congress directed the FTC to prescribe rules prohibiting abusive and

deceptive telemarketing acts or practices pursuant to the Telemarketing Act 15

13

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 14 of 57 Page ID

1

2

3

4

5

6

7

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17

18

19

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21

22

23

24

25

26

27

28

1773

USC sectsect 6101-6108 in 1994 The FTC adopted the original TSR in 1995

extensively amended it in 2003 and amended certain sections thereafter 16

CFR Part 310

39 Defendants are ldquoseller[s]rdquo or ldquotelemarketer[s]rdquo engaged in

ldquotelemarketingrdquo as defined by the TSR 16 CFR sect 3102(dd) (ff) and (gg) A

ldquosellerrdquo means any person who in connection with a telemarketing transaction

provides offers to provide or arranges for others to provide goods or services to a

customer in exchange for consideration 16 CFR sect 3102(dd) A ldquotelemarketerrdquo

means any person who in connection with telemarketing initiates or receives

telephone calls to or from a customer or donor 16 CFR sect 3102(ff)

ldquoTelemarketingrdquo means a plan program or campaign which is conducted to

induce the purchase of goods or services or a charitable contribution by use of one

or more telephones and which involves more than one interstate telephone call 16

CFR sect 3102(gg)

40 Defendants are sellers or telemarketers of ldquodebt relief servicesrdquo as

defined by the TSR 16 CFR sect 3102(o) Under the TSR a ldquodebt relief servicerdquo

means any program or service represented directly or by implication to

renegotiate settle or in any way alter the terms of payment or other terms of the

debt between a person and one or more unsecured creditors or debt collectors

including but not limited to a reduction in the balance interest rate or fees owed

by a person to an unsecured creditor or debt collector 16 CFR sect 3102(o)

41 The TSR prohibits sellers and telemarketers from requesting or

receiving payment of any fees or consideration for any debt relief service until and

unless

a The seller or telemarketer has renegotiated settled reduced or

otherwise altered the terms of at least one debt pursuant to a

14

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 15 of 57 Page ID

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

1774

settlement agreement debt management plan or other such

valid contractual agreement executed by the customer and

b The customer has made at least one payment pursuant to that

settlement agreement debt management plan or other valid

contractual agreement between the customer and the creditor

and

c To the extent that debts enrolled in a service are renegotiated

settled reduced or otherwise altered individually the fee or

consideration either

i Bears the same proportional relationship to the total fee

for renegotiating settling reducing or altering the terms

of the entire debt balance as the individual debt amount

bears to the entire debt amount The individual debt

amount and the entire debt amount are those owed at the

time the debt was enrolled in the service or

ii Is a percentage of the amount saved as a result of the

renegotiation settlement reduction or alteration The

percentage charged cannot change from one individual

debt to another The amount saved is the difference

between the amount owed at the time the debt was

enrolled in the service and the amount actually paid to

satisfy the debt 16 CFR sect 3104(a)(5)(i)

42 The TSR prohibits sellers and telemarketers from misrepresenting

directly or by implication any material aspect of any debt relief service including

but not limited to the amount of money or the percentage of the debt amount that a

customer may save by using the service 16 CFR sect 3103(a)(2)(x)

15

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 16 of 57 Page ID

1

2

3

4

5

6

7

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9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

1775

43 Pursuant to Section 3(c) of the Telemarketing Act 15 USC

sect 6102(c) and Section 18(d)(3) of the FTC Act 15 USC sect 57a(d)(3) a violation

of the TSR constitutes an unfair or deceptive act or practice in or affecting

commerce in violation of Section 5(a) of the FTC Act 15 USC sect 45(a)

VIOLATIONS OF THE TELEMARKETING SALES RULE

Count Two

(Advance Fee for Debt Relief Services)

44 In numerous instances in connection with the telemarketing of

student loan debt relief services Defendants have requested or received payment

of a fee or consideration for debt relief services before

a Defendants have renegotiated settled reduced or otherwise

altered the terms of at least one debt pursuant to a settlement

agreement debt management plan or other such valid contractual

agreement executed by the customer and

b The customer has made at least one payment pursuant to that

settlement agreement debt management plan or other valid

contractual agreement between the customer and the creditor

45 Defendantsrsquo acts or practices as described in Paragraph 44 of this

Complaint are abusive telemarketing acts or practices that violate Section

3104(a)(5)(i) of the TSR 16 CFR sect 3104(a)(5)(i)

Count Three

(Material Debt Relief Misrepresentations)

46 In numerous instances in connection with the telemarketing of

student loan debt relief services Defendants have misrepresented directly or

indirectly expressly or by implication material aspects of their debt relief services

including but not limited to that consumers who purchase Defendantsrsquo debt relief

services will or likely will have their monthly payments reduced or their loan

16

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 17 of 57 Page ID

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

1776

balances forgiven in whole or in part

47 Defendantsrsquo acts and practices as described in Paragraph 46 of this

Complaint are deceptive telemarketing acts or practices that violate Section

3103(a)(2)(x) of the TSR 16 CFR sect 3103(a)(2)(x)

Count Four

(Disgorgement of Ill-Gotten Gains of Relief Defendant)

48 Relief Defendant Noel has received directly or indirectly funds or

other assets from Defendants that are traceable to funds obtained from Defendantsrsquo

customers through the unlawful acts or practices described herein

49 Relief Defendant Noel has no legitimate claim to Defendantsrsquo

customersrsquo funds or other assets and will be unjustly enriched if it is not required to

disgorge the assets or the value of benefits received as a result of Defendantsrsquo

unlawful acts or practices

50 By reason of the foregoing Relief Defendant Noel holds funds and

assets in constructive trust for the benefit of Defendantsrsquo customers

CONSUMER INJURY

51 Consumers have suffered and will continue to suffer substantial injury

as a result of Defendantsrsquo violations of the FTC Act and the TSR In addition

Defendants have been unjustly enriched as a result of their unlawful acts or

practices Absent injunctive relief by this Court Defendants are likely to continue

to injure consumers reap unjust enrichment and harm the public interest

THIS COURTrsquoS POWER TO GRANT RELIEF

52 Section 13(b) of the FTC Act 15 USC sect 53(b) empowers this Court

to grant injunctive and such other relief as the Court may deem appropriate to halt

and redress violations of any provision of law enforced by the FTC The Court in

the exercise of its equitable jurisdiction may award ancillary relief including

rescission or reformation of contracts restitution the refund of monies paid and

17

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 18 of 57 Page ID

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

1777

the disgorgement of ill-gotten monies to prevent and remedy any violation of any

provision of law enforced by the FTC

53 Section 6(b) of the Telemarketing Act 15 USC sect 6105(b)

authorizes this Court to grant such relief as the Court finds necessary to redress

injury to consumers resulting from Defendantsrsquo violations of the TSR including

the rescission or reformation of contracts and the refund of money

PRAYER FOR RELIEF

Wherefore Plaintiff FTC pursuant to Section 13(b) of the FTC Act 15

USC sect 53(b) Section 6(b) of the Telemarketing Act 15 USC sect 6105(b) and

the Courtrsquos own equitable powers requests that the Court

A Award Plaintiff such preliminary injunctive and ancillary relief as

may be necessary to avert the likelihood of consumer injury during

the pendency of this action and to preserve the possibility of effective

final relief including but not limited to temporary and preliminary

injunctions orders freezing assets immediate access to business

premises appointment of a receiver and expedited discovery

B Enter a permanent injunction to prevent future violations of the FTC

Act and the TSR

C Award such relief as the Court finds necessary to redress injury to

consumers resulting from Defendantsrsquo violations of the FTC Act and

the TSR including but not limited to rescission or reformation of

contracts restitution the refund of monies paid and the disgorgement

of ill-gotten monies

D Enter an order requiring Relief Defendant to disgorge all funds and

assets or the value of the benefit it received from the funds and assets

which are traceable to funds obtained from Defendantsrsquo customers

through the unlawful acts or practices described herein and

18

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 19 of 57 Page ID 1778

2

3

E Award Plaintiff the costs of bringing this action as well as such other

and additional relief as the Court may determine to be just and proper

Dated February 5 2019

Respectfully submitted

ALDEN F ABBOTT General Counsel

JosaSMillard Brian M Welke middot Barbara Chun (Local Counsel) Attorneys for Plaintiff FEDERAL TRADE COMMISSION

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

19

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 20 of 57 Page ID 1779

EXHIBIT A

Attachment A

Free Assessment

Our expercs will lt1ssPss you cun ent

swclent lo n program and decermn which progr ms are

avc11l bl rn yoL11 situation We wi I help you cl11cic1e which progr m r1

help you achieve your goals Call us today

Service Guarantee We are commmecl to 11-1 111g

CllStomers get low r rc1ces ancl monthly payments and we w1I

m ke the pror~ss se mless and s r11ghtforwc1rd ou wi ll be sansf1ed

with our service ml OLlr

cornmcmem to you success Thars ow gu~ ancee

Success Rate Ou1 96 ~ surcPss r a e s 11e of he

cop I a ings tn he industry Olr

process has beer tested nd Olli

succ ss r r~ prowbull~ tn t it works

We c n ll~lp yo reduce and -1111ph y our p ~ymP1 ts Call us today

FTC-AID-1

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 21 of 57 Page ID 1780

20

Exhibit A

ABOUT US

We can help you reduce and simplify your pay1ncnts Contact one of our specialists today for

a free evaluation

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We Have Been Featured In

FTC-AID-2

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 22 of 57 Page ID 1781

21

Exhibit A

SERVICES Wt w gtL

Loan Forgiveness Income Based Payments Loan Consol idation In some cases individuals with A period of financial hardship may You may be able to combine

Fede1middota1 Student Loans may qualify qualify you for an Income Based nultiple federal student loans into to have a portion of the amount Repayment Plan In many cases this one new loan w ith a lower more

owed may be forgiven This means means you pay nothing Unlike a affordable monthly payment Loan

your principal balnce coulcl be defe1 ment the term on your loan consolidation prngrams can l1elp

significantly reduced and you will continues to reduce while the plan is you qualify for additional programs not be expected to repay the in place Your term could reduce like loan forgiveness programs or

forgiven amount while you pay nothing Public Setvice Loan Forgiveness

a III

Private Sector Loan Forgiveness

If you work for a government

organization at a city state or

federa l level you may qualify for tle

PL1blic Service Loan Forgiveness

program To qualify your loans

must be cotisolidated into a specific

repayment plan The balance on

your federai student loans is

forgiven after 120 qualifying

bull C Permanent Disability

Forgivenness If your disability is expected to last

60 months or more you may qualify

for permanent disability forgiveness

Q1alifying for Permnent Disability

Forgiveness requires a visi t to your

doctor and individL1als enrolled in

the program are subject to three

years of post-discharge monitoring

Wage Garnishment Prevention

Federal law requires that the

Department of Education or a

gua1middotanty agency notify you before

111st1tuting wage garnishment You

have tl1e right to a hearing where

you can challenge the stated

amount owed and negotiate the

terms of the repayment scheclule

We can intervene on YOL1PflJl~1D-3

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 23 of 57 Page ID 1782

22

Exhibit A

payments have been made p1middotevent wage gampnishments

A FEW STATISTICS ABOUT STUDENT LOAN CRISIS

12 Trillion National Student Debt I he nitionil student loin debt is

now 17 trillion dollirs 1 trillion of

these are in federil student loans

Let us help you through this national

crisis Cill today for a free

evaluation

40 Million Students with Debt

In 7014 an estimated 40 million

current and former students were in

debt because of student loans If

you are one of the millions of people

struggling to pay student loans

Aiding Student Relief is here to help

$33000 Average Student Debt

The graduating class of 7014

average $33000 of student loan

debt per person Thats $3000 more

than the average in 2013 Dont be

one of the many Let Aiding Student

Relief advocate for you

Aiding Student Relief has helped cmrnllcss 1woplc reduce their student debt_ Their proven business

plan has led lo one of lhc highest s11cclSS raCs in the inltl11slly

John Standiford Associated

FTC-AID-4

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 24 of 57 Page ID 1783

23

Exhibit A

TESTIMONIALS

Til~nks to Aiding Student Rel ief Im middotI middotva ove1vvhelrnecl but Aiding The expemiddotts at l1icl i11g Student Rel ief

s1v ing $250 per month Strrd r~rt Relief expl~ inecl the were ther~ to help me when I process ancl rnacle everytl1ing cle11middot nelclecl 1t rw)s t

and sirnple

I Michael Ma 1in

Entrep e11eu1 Em iiy Jallo1 Ii Pa ul Ch is tia I1se11

Teacher Nurse

With so many programs I didnt middotconso lrclating my loans into one I love my Job but vith my high

know what was ng ht for me My monthly payment hs made life student loan payment was still

sruclent loan aclvsor walked me si1nple1 Now I can focus on 1Nhn bamiddotely getting by I don t kn ow what I

through my optio ns rnd now Imiddotn matters to me would hwe clone wthout Aiding

saving 54 I 11n1omh Stucie1middott Rel refmiddot

Ariel Hemiquez Sales co)SUltant

Stephani Seland-1 Small Busim~ss Owner

AJ 01en Museum Curator

RECENT NEWS

)lt)

o(l ttDrlTI -5

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 25 of 57 Page ID 1784

24

Exhibit A

Student Debt Crisis Business Latest Debt Collective Demands May be largely about smallest Student

borrnwers US News amp World Loan Crisis is fa frorn ove The Debt Collective is a group of Report-May 162015 last month Two new reports suggest the college students calling the Fedemiddotal Reserve Bank of New student loan crisis is easing them-se1ves the Corinthian York repor ced that stuclent loan somewhat as the economy Fifteen who are refusing to pay balances rose to 16 trillio n and improves but the crisis is far back their student loins As pa t that 113 per cent of that is in from ove the College Board of this effort the Debt Collective repo t~ tot31 borrowing fell by 8 has written an open lette to the pEbull1 cent between 2012-13 and Department of Education f l llJ 20 13-14 The organization

About Us 11 1 i~d1middot1r F th~~- h1~ ff t1middot~11middot=cl =i~=middott- 1middot __31middotmiddotIIgt middot bullmiddot11

middot- I ( )ntir il t l~i -r_il fr~~

Address bull middot tc1ltj-1r_ =i ~

middot l t1~t 1middot1 fcJ middot~_1 1 I l11 - Hbull 1 tr

~t (~~ 1 12bull~11 T 1 1- - 8555105400

FTC-AID-6

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 26 of 57 Page ID 1785

25

Exhibit A

f - g+ in O) ~ PRIVACY POLICY

This privacy statement discloses the privacy practices for AidllII Student Relief Because Aiding Studen Relief wonts to demonstrate ts firm commlcmell to your

privacy Aiding Sudent Relief hes greed to disclose ls 1rifor111atlori g1thering and dlssem1n1t1on prct1cts Aidlns Studtrit Relief will notify you of

INFORMATION COLLECTION At-ID USE

Aiding Student Relief is the sole owner of the rformMlon collected on this site We will not sell shire or rent this information 10 others In way different from what Is

disclosed 1n this statement Aldln1 StudeM Relief collects 1nform111on throuah this site from our prospective end existing clients at several different poin on our web

site We use their contact Informii on to send information bout our company and to service exsMs accounts Users may optbullout of rece11ns future malllngs see the

cholceoptbullout section below Contect and Financial information that 1s collected Is used for verifying your name address and other informa1on as well as to boll you for

your use of our Gerv1ces using Information from third party sourcH Information about your computer hardwre and software Is automatically collected by Aiding

Student Relief and may be shared in asgregate with third parties whose services are used for traffic analysis purposes This Ir formation includes your IP address

browser type domain names access times and referring Web site addresses Ths information is no tied to personally Identifiable Information This 1nformatlor s used

by Aiding Student Relief to malMan no Improve the quality of the Hrvct and to senerae statistics resardlng use of he Aiding Student Relief site We use third party

services to bill for serlces and to provide other services like our Live Help chat We store the transcripts from these chats for customer service Improvement These

third party service providers are not permitted to use your infornon for any secondary purposes

Thank you and cheers

FTC-AID-7

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 27 of 57 Page ID 1786

26

Exhibit A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 28 of 57 Page ID 1787

EXHIBIT B

Attachment A

((

z | ~

AIDINGSTUDENTRELIEF

bull bull bull bull bull

13 deg $ $ampdegdeg deg() ˝ amp $$deg( + -+Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 29 of 57 Page ID 1788

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4556789fADlt=gtA9BCAD

DZgtA=EFGHIJFKLMNOPFQOGFHIQRSTLKSUMMNOPLHMTFIVRWXHKKNIFNUNOPRLFGSHKSRVRVNQ

f e=klHMW

9SI]UQMSNSOQOHHPFK YaSTHHVVJFMHcVGNOJVHHFKKPSUHMLIUOQN_PL[KSVFGJPRSDTHRFPLIP=SNDC==GFdFIP9VaNHQTWSRPbHF_PSKSVNMPMHNIO XNNIIFRKNF7IKSQQMHFNDVPOS9IAeTHPdKSUMMFNKHONP 8aF_KSNVPHTNIMNR[POVFgNPTHLNHIgtMFI YTFHIdFFI D9aHVR_KNKHFHIWIQOTHIQbFFP

lt=Dkgt=L]oHUKMMH ihTFNIORI THHVPRFMVKgtNJ_NFFbIVSJI]IFjdGGVNNN lt=TFKPPNF 9DaFGmVHPGRJMFNNQOSGnPFFTNLUNHPMIMTFVNJOKMIWV

27

]UMNOHPFRKNVSHKKISIRWRrGZNJONgtNjTHKHMI=cQgtORHVPKSOUMddUNKSPIdspNVPNq_ lt=gtBTHFHPb=HFILGFHMt DTFuFIUVFRPNTFIMINVWOPRVOQFIV sFQFPHKKH vaIPNFVcSyOFSPRFMRNVOJH_gtVFDVUJAN9FPwFuVFJLFHMP_VTFFdSIIVdNHUPxI=DQSROJGASHIVdDSNMINONPPaHdOHdPFHRIWVFFHdFIGM˙ 01 $2 301 $$3 ( Exhibit B

8

~ldquo

middot

676EBCEDK5ltAC]5EF_5665E7gt5lt7aFb688E588lt76B5E6F8EBAC78lt76cdddefghijhggklmknmopqprpopst u

13 deg $ $ampdegdeg degˇ amp $$deg + -+Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 30 of 57 Page ID 1789 () ( vPSZwPxyYTUZUWWzxPyxSWMZWPU|SWUWYZ~YTY~QSWbullYXRwU~UxSdaggerXQ~UZXvPSZWSOVQSYNOXPRSTUSDaggerPxXYPZPNXRUSPQZXPbullU~SOhellipUNPxyYTUZmdash zUxSZUZXndashYWShellipYYXOwPxyYTUZUWWMNOPQx~YWShellipYYXOYWUƒDaggerU|XU~XPSWXfrasllsaquoPZXRWPxPxUOPQSOVQSYNONPxDaggerUxSZUZX~YWShellipYYXONPxyYTUZUWWmdash

rsaquominus MZ|PUpermilSWUzSOUZXWbdquoDaggerUxYP~PNZSZ|YSRSx~WRYDaggerSOVQSYNOOPQNPxSZMZ|PUpermilSWU~rdquoUDaggerSOUZXzSZmdashMZSZO|SWUWXRYWUSZWOPQDaggerSOZPXRYZymdash zQhellipY|daggerUxTY|UvPSZwPxyYTUZUWWMNOPQbullPxlsquoNPxSyPTUxZUZXPxySZYrsquoSXYPZSXS|YXOWXSXUPxNU~UxSUTUOPQSOVQSYNONPxXRUzQhellipY|daggerUxTY|UvPSZwPxyYTUZUWWDaggerxPyxSmdashsbquotrade f8Ef8E78FCB6C8EŁPQSOhellipUShellipUXP|PhellipYZUQXYDaggerUNU~UxSWXQ~UZXPSZWYZXPPZUZUbullPSZbullYXRSPbullUxPxUSŒPx~ShellipUPZXRODaggerSOUZXmdashvPSZ|PZWPY~SXYPZDaggerxPyxSW|SZRUDaggerOPQVQSYNONPxS~~YXYPZSDaggerxPyxSW YlsquoU PSZ NPxyYTUZUWWDaggerxPyxSWPxzQhellipY|daggerUxTY|UvPSZwPxyYTUZUWWmdash ŠmŸŽıłŠm 57gt8A57A5B= 8E65C76B5E6F8EB5=6G

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^ ˙ ( (

28

Attachment A

01 $2 301 $$3 ( Exhibit B

()(

=4ABC9DEAFBD=FGFHIJKLMJNOMN MRNS mn = nrst = svzhellipu t bulltvDaggerrhellipDaggerurbullbulltuhellipv hellipz~ bullmdashldquordquolsquorsquotrade š oŒŠeuro centpound ` umluml 13 deg $ $ampdegdeg degˇ amp $$deg + -+Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 31 of 57 Page ID 1790

ISNRTUKQINKKNNKL[MRJ PUWQI]MRM qyt|tytzxy rsaquoqNfraslbdquoPUhellipsbquoLUyQhellip rfraslbhellipMNSIKVUQ QNJKvUQsMiexclQQJUx[iexcliexcl_vsect_Qyenyenbrvbarbrvbar uSSRNTPL_LUUMKIaJ_WMIJJKVIONNQJJMWRMIIbQQURKLWIIJQbKLUNKMPTMNQQ_KKRY tbullbulldaggersDaggerv~vhellipmdashryrhellip~mdashrhellipDagger ŸLŽUıQŽbłpermilMtradeœsbquoNtrade_ffRŁyISMŒUQWyNUQŠlsaquo rv45657896lt7ltgt5lt PQKLMIQSNRTUKINQVNOOMVKMWNQKLIJPMXJIKMYZMPIOO NJMOOJLURMNRRMKKLIJ klltko ltgtlt85p5gt5 ouvwxrz ^^ ~ minuspermil tffŁ yenpoundpound KNOWDaggerIreggt4lt97ltndash9ƒ Dagger hellipDaggerlsaquo žko74k57ƒ ƒISNcurrenUIWIbJKWMKJYVNTKM KLONNRqIQQSNNRTUKINQQIJ_JMWNQKLIJJJPMXJIKMcOMUJMVNQKUVK_JUKBHdefABCgDEAFBDghidjlaquopoundbrvbariexclnotvIWIQbDaggerK_WMQKbullMOIMSvOObullIbLKJbullMJMRMW ordf copy

01( $2(301$$3( Exhibit B

29

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 32 of 57 Page ID 1791

EXHIBIT C

Attachment A

~ 111 ~tampi 10 11 ~bull ia1111

Something awesome is coming soon We are buildin somethin ve cool Sta tuned and be at1ent Your atience will be well aid

~lbullrbullUiUffl We can help you reduce and simplify your payments

101 Loan For iveness

1~u 0 (middottmiddotbullmiddotmiddot1 1~=I -- _~

HZamp IMUliULlampRampatiEUWi nmiddot middot-il~ fr middot 8rbullbullrcrr-

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~ Income Based Pa ents

bull ~ f I - - I - I - ri u ~u-=lf ~ JU

1-bullA ---rc iM1~~ -~-bullCiel rrcl

~- middot IY 2 i C middot middotJ ll1Jmiddot 0 _ middot_middotIr i

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middotE-ltecl l2bullJbull iequbullt t11cit t1lt2 CtpCr~middot1e- f

JJd r g-_iraE-1 agltr-middot- ntimiddot middot)middotou

tmiddot_rt- i ic l~1ri ~rbullmiddot middot111~ umiddot -_ d_t-c

fsectmet-Naibullfyen1~poundibllffifftmI

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1 ~~~~ 1

If -bull 13n ~Cbull t~middot rct1~j d- gtOY- - hO- irmiddot (bulldbull) plltmiddotmiddot- leemiddotmiddot JOu

1r1cbullmiddotn111f11ri ll1fbull fcrn to ~bull~I

Triin- GU

WAWMyenEIRitiRpoundWt 44 ZiAtillampampI

Exhibit C

Case 818-cv-01987-JLS

-KE

S

Docum

ent 50-1 F

iled 020519 P

age 33 of 57 P

age ID 1792

30

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 34 of 57 Page ID 1793

EXHIBIT D

Attachment A

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Type then hit enter to

bull bull bull bull bull bull bull

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Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 35 of 57 Page ID 1794

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

infoaidnestcom (800) 555-1212

HOME

ABOUT US

SERVICES

FAQ

BLOG

CONTACT

HOME ABOUT US SERVICES FAQ BLOG CONTACT

1 of 6 462018 945 AM

31

Student Loan Forgiveness Loan Consolidation Student Loan Forgiveness

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 36 of 57 Page ID 1795

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

If you have Federal Student Loans yoursquore in the right place to get those loans reduced forgiven or completely discharged through our student loan forgiveness programs

Get your multiple Federal Student Loans consolidated into one forget about increasing interests and pay month to month at the lowest possible cost

We understand if yoursquore going through some hardship and thatrsquos why with us yoursquoll be able to make monthly payments based on your affordability for as low as $000 depending on your situation

2 of 6 462018 945 AM

32

Knowledge Base

Defaulted Student Loans

Wage Garnishment

Student Loan Rehabilitation

Income Based Repayment Plan

Deferment and Forbearance

Pay As You Earn Repayment Plan

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE Call 561)424-6053 today to go over your options

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 37 of 57 Page ID 1796

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

Our knowledge base is designed to provide information regarding some of the critical topics those with student loans must be aware of to be able to make educated decisions regarding their future

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

A wage garnishment is any legal procedure in which some portion of a personrsquos earnings is required to be withheld by an employer for the payment of a debt

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

With this program your payments change as your income changes and will not be longer than 25 years This is the ideal plan if you are in partial financial hardship Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard plan

Temporarily allowing you to postpone or reduce your federal student loan payments Postponing or reducing your payments may help you avoid default and future garnishments

Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard

3 of 6 462018 945 AM

33

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 38 of 57 Page ID 1797

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

4 of 6 462018 945 AM

34Attachment A

Testimonials

Latest News

Why 2016 Will Be a Big Year For Student Loans

Top Student Loan Refinancing Questions of 2015

Oba mas latest student loan plan

Things You Should Know About Public Service Loan Forgiveness

Recent Posts

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 39 of 57 Page ID 1798

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

5 of 6 462018 945 AM

35

About Us

Contact Info

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 40 of 57 Page ID 1799

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

pay-grandchild-studen

Why 2016 Will Be a Big Year For Student Loans

December 30 2015

12511110_1112367518

Top Student Loan Refinancing Questions of 2015

December 30 2015

We stand by our consultation and quote We are so sure and confident about our services and offers that they are all 100 money back guarantee risk free ndash if we donrsquot do what we promise yoursquoll get your money back

(800) 555-1212 AidnestStudenLoansgmailcom 18100 Von Karman Ave Suite 850 Irvine CA 92612

Futero SAS copy 2015 | Aidnestcom

6 of 6 462018 945

Exhibit D 36Attachment A

AM

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 41 of 57 Page ID 1800

EXHIBIT E

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 42 of 57 Page ID 1801

AIDNEST Let us help you through this national crisis

Call one of our specialists today

Forbearance amp Deferment If you are still in school and struggling to make payments on your student loans You may qualify

for Forbearance amp Deferment

Garnishment Prevention Federal law requires that the Department of Education or guarantee agency notifies you before they

begin garnishing your wages

Loan Forgiveness If you are a teacher public service worker or an individual with total and permanent disability you

httpaidnestcom[442018 115239 AM]

37Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 43 of 57 Page ID 1802

AIDNEST Let us help you through this national crisis

may qualify for this program

Consolidating Your Loans Consolidating your loans to one new loan under one lender may lower your payments and make

your life a bit more manageable

Affordable Payments If you are looking to lower your monthly payments then Income Based Repayment Plans may be

the correct choice for you

Learn more about our services

LEARN MORE

httpaidnestcom[442018 115239 AM]

38Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 44 of 57 Page ID 1803

AIDNEST Let us help you through this national crisis

Loan Forgiveness Programs Income Based Payments Student Loan Rehabilitation

Student Loan Consolidation

You may be eligible for

Loan Forgiveness Programs

In some cases individuals with Federal Student Loans may qualify to have a portion of the amount

owed to be forgiven

Get in touch with our professional team to find out which loan forgiveness program you qualify for and

how you can get rid of your unpaid student loan

L EARN MORE

httpaidnestcom[442018 115239 AM]

39Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 45 of 57 Page ID 1804

AIDNEST Let us help you through this national crisis

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE

Meet your Budget One of our advisers will help you meet your payment goals by using your budget and timeline to

determine the best plan available

httpaidnestcom[442018 115239 AM]

40Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 46 of 57 Page ID 1805

AIDNEST Let us help you through this national crisis

Simple Process We understand that lowering your payments alone can be difficult Our intuitive platform allows us

to keep the entire process simple

Customer Satisfaction We are committed to providing you with outstanding service only We look forward to working

with you

100 money back guarantee No Hassle Money Back Policy

httpaidnestcom[442018 115239 AM]

41Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 47 of 57 Page ID 1806

AIDNEST Let us help you through this national crisis

Lower your loan payments by getting in touch with one of our professionals

We design a customized repayment plan that will allow you to make payments based on your

monthly income family size and spending Get rid of the hassle of extensive paperwork and get the

help you deserve

What we can help you achieve a lower payment or lower rate

httpaidnestcom[442018 115239 AM]

42Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 48 of 57 Page ID 1807

AIDNEST Let us help you through this national crisis

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcom[442018 115239 AM]

43Exhibit E

httpaidnestcomservices[442018 115322 AM]

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 49 of 57 Page ID 1808

Services | AIDNEST Let us help you through this national crisis

INCOME BASED PAYMENTS

If you are suffering from a financial hardship you may be eligible for an

Income Based Payment In this repayment program you would have a

payment based on your income and family size The payment could be as

low as $000 per month with forgiveness at the end of 20-25 years

44

Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 50 of 57 Page ID 1809

L E ARN MORE

LOAN FORGIVENESS

If you have Federal Student Loans you may qualify for any of the student

loan forgiveness programs that are available to borrowers You may be

eligible for principal reduction loan forgiveness or a complete loan

discharge depending on your individual circumstance

L EARN MORE

PRIVATE STUDENT LOAN CONSOLIDATION

Much like refinancing a mortgage generally the biggest benefit of private

student loan consolidationstudent loan refinancing is a lower interest rate

httpaidnestcomservices[442018 115322 AM]

45Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 51 of 57 Page ID 1810

L E ARN MORE

(something federal consolidations do not offer)

STUDENT LOAN REHABILITATION

You can renew eligibility for new loans and grants and eliminate the loan

default by ldquorehabilitatingrdquo a defaulted loan

httpaidnestcomservices[442018 115322 AM]

46Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 52 of 57 Page ID 1811

CHE CK E L E G I B I L I T Y

WAGE GARNISHMENT

A wage garnishment is any legal procedure in which some portion of a

personrsquos earnings is required to be withheld by an employer for the

payment of a debt

L EARN MORE

With our fast friendly and professional services wersquoll be glad to help you get your student loans

reduced forgiven or completely discharged To this end wersquoll assist you in consolidating all your

student loans so yoursquoll have only one lender and yoursquoll start making one monthly payment Our

professionals will walk you through the best and most flexible repayment options and if itrsquos also

necessary varied deferment options and rehabilitation programs

httpaidnestcomservices[442018 115322 AM]

47Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 53 of 57 Page ID 1812

Services | AIDNEST Let us help you through this national crisis

Our CRM System

Our CRM is one of the most advanced in the industry and most importantly itrsquos linked directly to

the Department of Education (DOE) This keeps your personal and most confidential information

safe Furthermore because our CRM system is linked to the DOE our approval is 100 Through

our CRM we will be doing continuous monitoring of our process without losing sight of your

immediate needs ensuring that your case has the proper handling and most efficient process

httpaidnestcomservices[442018 115322 AM]

48Exhibit E

n

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 54 of 57 Page ID 1813

Services | AIDNEST Let us help you through this national crisis

R ECENT POSTS

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

ABOUT US

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcomservices[442018 115322 AM]

49Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 55 of 57 Page ID 1814

EXHIBIT F

s -

bullmiddot - ~ t ~ower Your Student Loan Pay~e~ts oday -- Students Helping Students Save Money

INCOME BASED PAJIIIJITPAIS

I C(gttoUC1 u~

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 56 of 57 Page ID 1815

X + C (D Not secure wwwstudoracom 0

CALL US NOW (85S) 978-S599 middot 1nfostudoracom

HOME SERVICES ABOUT US FAQ CONTACT US BLOC PRIVACY

Offering obligation and commitment free loan relief solutions

STUDENT LOAN FORGIVENESS INCOME BASED PAYMENTS LOAN CONSOLIDATION

We11 help you get your loans reduced forgiven o r Make monthly pdyments based on your affordability Get multiple Federal Student Loans consolidated into

discharged one low monthly payment

Talk to our experts concerning your

student loans

Studora is a pnvatefy owned company that helps consumers like you identify

government programs that fit your financial s1tuat1on Our loan experts will assist you in selecting the appropriate programs that WOltk with your income family size and

desired monthly payment We then prepare the appropriate documents for your review and submission All this f o r one low easy payment

Testimonials

Thank you f o r getting back to me quickly Youve been fabulous Thank you for the confirmation and for your help today Pass

during this whole process Is there a place I can go online that I this on to your sup that you were very professional and very

can leave a comment for your manager Youve made this Robert helpful and brought a sense of relief for me Thank you very

process so easy and answered every question my husband and I much and have a great rest of your day Kudos to you and your

have had teammoneywell spenL

Exhibit F 50

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 57 of 57 Page ID 1816

Services we offer

Stud ora offers document preparation services for all loan forgiveness consolidation and relief services to people who are unable to manage their finances Our mam aim is to

offer complete peace of mind to indiVidual unable to pay their student loan debt

we otter the folloWing document preparation services with complete professional assistance

amFinancial Review ffl Budget Planning

Toe first step to creating a flexible loan repayment plan is financial review we also help create a personal finance plan to ensure that you are able to

Our professmnals will look into your finances and design a custom manage your monthly budget in the most effective way This plan will keep

repayment plan that is affordable and easy to manage your spending to the minimum alloWing you to save more money for loan

repayment

Permanent Disability Forgiveness r-trTeacher Loan Forgiveness (5 You can get rid of your Federal Student Loan if you are permanently disabled Good news for teachers who are under the weight of a massiVe loan You can

now get $17 forgiven on your student loans

Public Service Loan Forgiveness Custom Debt Relief Plans

Want assistance with debt relief Get in touch with our experts who will help If you are a public service agent you can get rid of your loan after 120 days of design a loan repayment and relief plan for you based on your monthly

income and affordability payments

THERE ARE NO OBLIGATIONS OR COMMITMENTS

want to save thousands of dollars Fill out our form and get relief from your student loan for a more

peaceful tomorrow

Your Name

BiHHHi

Exhibit F 51

Attachment A

Page 4: JOSHUA S. MILLARD, BRIAN M. WELKE, pro hac vice · for which it has no legitimate claim. Noel is a Wyoming limited liability company that reported in a public document that its principal

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 4 of 57 Page ID

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

1763

enterprise described in paragraph 14 Impetus has advertised marketed offered to

provide provided offered for sale or sold student loan debt relief services to

consumers throughout the United States

7 Defendant Fig Tree amp Co LLC (ldquoFig Tree LLCrdquo) also doing

business as Aiding Student Relief Aiding Students amp Teacher and Aiding

Students amp Teachers is a California limited liability company with its principal

place of business at 18100 Von Karman Ave Suite 850 Irvine California 92612

Fig Tree LLC transacts or has transacted business in this district and throughout

the United States At all times material to this Complaint acting alone or in

concert with others or as part of the common enterprise described in paragraph 14

Fig Tree LLC has advertised marketed offered to provide provided offered for

sale or sold student loan debt relief services to consumers throughout the United

States

8 Defendant Capital Sun Investments LLC (ldquoCapital Sunrdquo) also doing

business as Studora is a Wyoming limited liability company with its principal

place of business at 1651 East Fourth Street Suite 124 Santa Ana California

92701 Capital Sun transacts or has transacted business in this district and

throughout the United States At times material to this Complaint acting alone or

in concert with others as part of the common enterprise described in paragraph 14

or as a successor in interest to defendant Impetus Capital Sun has advertised

marketed offered to provide provided offered for sale or sold student loan debt

relief services to consumers throughout the United States

9 Defendant Tuan Dinh Duong also known as Thomas Duong and

Thomas Dinh (ldquoDuongrdquo) has identified himself as or served as the President

director general manager sales manager owner co-owner and principal

shareholder of Impetus At all times material to this Complaint acting alone or in

concert with others he has formulated directed controlled had the authority to

4

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 5 of 57 Page ID

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

1764

control or participated in the acts and practices set forth in this Complaint

Defendant Duong resides in this district and in connection with the matters alleged

herein transacts or has transacted business in this district and throughout the

United States

10 Defendant Brenda Avitia-Pena (ldquoAvitia-Penardquo) has identified herself

as or served as the President CEO Secretary CFO director and owner of

Impetus and the manager of Fig Tree LLC At all times material to this

Complaint acting alone or in concert with others she has formulated directed

controlled had the authority to control or participated in the acts and practices set

forth in this Complaint Defendant Avitia-Pena resides in this district and in

connection with the matters alleged herein transacts or has transacted business in

this district and throughout the United States

11 Defendant Brian Colombana (ldquoColombanardquo) who has also done

business under the fictitious business name ldquoFuterordquo has identified himself as or

served as co-owner of Impetus (and CIO of its dba Avec Staffing) and manager

of Fig Tree LLC At times material to this Complaint through at least January

2018 acting alone or in concert with others Colombana formulated directed

controlled had the authority to control or participated in the acts and practices set

forth in this Complaint Defendant Colombana resides in this district and in

connection with the matters alleged herein transacts or has transacted business in

this district and throughout the United States

12 Defendant Jimmy Calderon (ldquoCalderonrdquo) has identified himself as and

has served as manager of Capital Sun At times material to this Complaint since at

least September 2017 acting alone or in concert with others Calderon formulated

directed controlled had the authority to control or participated in the acts and

practices set forth in this Complaint Defendant Calderon resides in this district

and in connection with the matters alleged herein transacts or has transacted

5

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 6 of 57 Page ID

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

1765

business in this district and throughout the United States

RELIEF DEFENDANT

13 Relief Defendant Noel Solutions LLC (ldquoNoelrdquo) has received funds

that can be traced directly to Defendantsrsquo deceptive acts or practices alleged below

for which it has no legitimate claim Noel is a Wyoming limited liability company

that reported in a public document that its principal place of business is 1623

Central Ave Suite 201 Cheyenne Wyoming 82001 Noel also incorporated as a

California limited liability company in January 2018 listing its address as 18997

Barroso St Rowland Heights California 91748 Noel transacts or has transacted

business in this district and in the district of Wyoming

COMMON ENTERPRISE

14 Defendants Impetus Fig Tree LLC and Capital Sun (ldquoCorporate

Defendantsrdquo) have operated as a common enterprise while engaging in the

unlawful acts and practices alleged below Defendants have conducted the

business practices described below through interrelated companies that have

common ownership officers managers business functions employees and office

locations and routinely transfer funds amongst themselves Because the Corporate

Defendants have operated as a common enterprise each is jointly and severally

liable for the acts and practices alleged below Defendants Duong Avitia-Pena

Colombana and Calderon have formulated directed controlled had the authority

to control or participated in the acts and practices of the Corporate Defendants that

constitute the common enterprise

COMMERCE

15 At all times material to this Complaint Defendants have maintained a

substantial course of trade in or affecting commerce as ldquocommercerdquo is defined in

Section 4 of the FTC Act 15 USC sect 44

6

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 7 of 57 Page ID

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

1766

DEFENDANTSrsquo UNLAWFUL STUDENT LOAN DEBT RELIEF

OPERATION

16 Since at least December 2014 through at least the filing of the FTCrsquos

Complaint in this matter in November 2018 Defendants have operated an unlawful

debt relief scheme that preys on consumers with student loan debt In telephone

calls on websites and in mailed advertising Defendants promise to reduce

consumersrsquo monthly student loan payments and eliminate all or a portion of their

student loan debt through enrollment in student loan forgiveness or repayment

programs In many instances however Defendants failed to obtain debt

forgiveness or monthly payment reductions In fact some consumers owed more

on their student loans after enrolling in Defendantsrsquo program

17 In exchange for the promised student loan debt relief services

Defendants have charged illegal upfront fees of $499 or more

Background on Student Loan Forgiveness and Repayment Programs

18 Student loan debt is the second largest class of consumer debt more

than 42 million Americans collectively owe nearly $15 trillion in student loan

debt The student loan market shows elevated levels of distress relative to other

types of consumer debt

19 To address this mounting level of distressed debt the US

Department of Education (ldquoUSDErdquo) and state government agencies administer a

limited number of student loan forgiveness and discharge programs Most

consumers however do not qualify for these programs because of strict eligibility

requirements For example one program requires the consumer to demonstrate a

total and permanent disability another applies only to consumers whose school

closed while the consumer was still enrolled A third program the Borrower

Defense to Repayment (ldquoBDRrdquo) may provide a loan discharge if the school

through an act or omission violated state law directly related to the borrowerrsquos

7

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 8 of 57 Page ID

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

1767

federal student loan or to the educational services for which the loan was provided

20 Other forgiveness programs require borrowers to work in certain

professions for a period of years For example Teacher Loan Forgiveness applies

to teachers who have worked full-time for five years in a low-income elementary

or secondary school or educational service agency Public Service Loan

Forgiveness (ldquoPSLFrdquo) applies to employees of governmental units or non-profit

organizations who make timely monthly payments for a period of ten years while

employed in the public sector

21 The federal government also offers loan forgiveness through income-

driven repayment (ldquoIDRrdquo) programs that enable borrowers to reduce their monthly

payments and have portions of their loans forgiven IDR programs allow eligible

borrowers to limit their monthly payments based on a percentage of their

discretionary monthly income To remain in an IDR program borrowers must

recertify their income and family size annually Obtaining forgiveness through

IDR programs requires a minimum of 20 or 25 years of qualifying payments

depending on whether borrowers received their first loans on July 1 2014 or

before that date Because a borrowerrsquos income is likely to fluctuate over the life of

the loan monthly payments under the IDR programs can vary considerably from

year to year If a borrowerrsquos income were to increase over the repayment period

for example the monthly payment amount could correspondingly increase to the

point where those payments would pay off the loan before any amount could be

forgiven at the end of the repayment term No loans have been forgiven yet under

any of the IDR programs because the programs have not existed long enough for

borrowers to make the minimum number of years of qualifying payments

22 Consumers can apply for BDR PSLF IDR and other loan repayment

and forgiveness or discharge programs through USDE or their student loan

servicers at no cost these programs do not require the assistance of a third-party

8

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 9 of 57 Page ID

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

1768

company or payment of application fees

23 USDE will grant forbearance while processing applications for an

alternative repayment plan and in some cases of hardship During forbearance

unpaid interest is added to the principal balance

Defendantsrsquo Deceptive Marketing of Student Loan Debt Relief Services

24 To lure consumers into purchasing their purported student loan debt

relief services Defendants have made false promises to eliminate or reduce

consumersrsquo student loan balances or monthly payments through loan forgiveness

or other programs

25 To induce consumers to purchase their purported student loan debt

relief services Defendants have disseminated websites such as aidingstudentscom

aidnestcom and studoracom including but not necessarily limited to the

attached exhibits A through F Defendantsrsquo websites have contained the following

statements among others

Free Assessment

Our experts will assess your current student loan program and determine

which programs are available in your

situation We will help you decide which

program can help you achieve your goals Call

us today

Service Guarantee

We are committed to helping customers get

lower rates and monthly payments and we will

make the process seamless and

straightforward You will be satisfied with our

service and our commitment to your success Thatrsquos our

guarantee

Ex A at 1 (aidingstudentscom 2015)

9

Success Rate

Our 96 success rate is one of the top ratings in

the industry Our process has been tested and our

success rate proves that it works We can help you reduce and simplify your payments Call us today

Attachment A

----------

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 10 of 57 Page ID

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

1769

ldquoWe can help you reduce and simplify your payments Contact one of our specialists today for a free evaluationrdquo

Ex A at 2 (emphasis in original)

ldquolsquoAiding Student Relief has helped countless people reduce their student debt Their proven business plan has led to one of the highest success rates in the industryrsquordquo

Ex A at 4

100 Customer Satisfaction We can help you reduce and simplify your payments Call one of our specialists

today

Ex B at 1 (aidingstudentscom 2016) (emphasis in original)

Meet some of our members who have saved big on their student loan debt Helping You Save Big

ldquoThanks to Aiding Student Relief I am savings [sic] $250 per monthrdquo Michael Martin Entrepreneur

Ex B at 2 (emphasis in original)

ldquoWe can help you reduce and simplify your payments rdquo

Ex C at 1 (aidingstudentscom 2018) (emphasis in original)

Student Loan

Forgiveness

If you have Federal Student Loans yoursquore in the right place to get those

Loan Forgiveness

Get your multiple Federal Student Loans consolidated into one

10

Student Loan

Forgiveness

We understand if yoursquore going through some hardship and thatrsquos why

Attachment A

Case 818-cv-01987-JLS-KES

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Document 50-1 Filed 020519 Page 11 of 57 Page ID 1770

loans reduced forgiven or completely discharged through our student loan forgiveness programs

forget about increasing interests [sic] and pay month to month at the lowest possible cost

with us yoursquoll be able to make monthly payments based on your affordability for as low as $000 depending on your situation

Ex D at 2 (aidnestcom 2016)

Lower your loan payments by getting in touch with one of our professionals We design a customized repayment plan that will allow you to make payments based on your monthly income family size and spending Get rid of the hassle of extensive paperwork and get the help you deserve

What we can help you achieve [is] a lower payment or lower rate

Ex E at 6 (aidnestcom 2018) (emphasis in original)

STUDENT LOAN FORGIVENESS

Wersquoll help you get your loans reduced forgiven or

discharged

INCOME BASED PAYMENTS

Make monthly payments based on your affordability

LOAN CONSOLIDATION

Get multiple Federal Student Loans

consolidated into one low monthly payment

Ex F at 1 (studoracom 2018) (emphasis in original)

26 In some instances consumers view the Defendantsrsquo online advertising

and call Defendantsrsquo telemarketers for more information Defendants also make

outbound telemarketing calls and send texts to consumers to offer their services

and convince student loan borrowers to sign up for Defendantsrsquo debt relief

services

11

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 12 of 57 Page ID

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

1771

27 In calls with consumers Defendantsrsquo telemarketers have told

consumers that Defendants can cause consumersrsquo student loan balances to be

reduced or that consumersrsquo loan balances would be forgiven after making lower

monthly payments Defendantsrsquo telemarketers have told some consumers that over

half their loan balance would be forgiven Moreover Defendantsrsquo telemarketers

have told some consumers that their loan payments could or would be rapidly

reduced to $19 per month or promptly forgiven

28 Defendants have made other representations concerning loan

reduction or forgiveness to consumers in telemarketing their debt relief services

For example Defendantsrsquo telemarketers have told one or more consumers that

ldquofamily sizerdquo a metric for determining the amount borrowers pay each month

under IDR plans includes ldquoanyone you help out throughout the year[] they donrsquot

have to live with yourdquo even claiming that helping with ldquogas money three times

out of the yearrdquo is enough to include a person in ldquofamily sizerdquo Further

Defendantsrsquo telemarketers have offered one or more consumers ldquobasically a

guarantee to remainrdquo in an IDR plan and warned one or more consumers that

signing up for an IDR plan with a lender instead would result in a higher loan

payment

29 Defendants have not been likely to achieve the lower monthly

payments or student loan forgiveness they have advertised marketed and

promoted to consumers In many instances Defendants have failed to obtain the

promised lower monthly payments or student loan forgiveness

30 Defendants have charged consumers fees for purported debt relief

services before achieving lower monthly payments or student loan forgiveness

and in many instances have failed to achieve those results at all on behalf of

consumers

12

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 13 of 57 Page ID

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

1772

31 Defendantsrsquo telemarketers have sought and obtained consumersrsquo

payment information by phone or the Internet

32 Defendantsrsquo total advance fees typically have been in the range of

$300-500 Defendants also have charged consumers recurring monthly fees for

purported debt relief services typically charging $19 per month

THE FTC ACT

33 Section 5(a) of the FTC Act 15 USC sect 45(a) prohibits ldquounfair or

deceptive acts or practices in or affecting commercerdquo

34 Misrepresentations or deceptive omissions of material fact constitute

deceptive acts or practices prohibited by Section 5(a) of the FTC Act

VIOLATIONS OF THE FTC ACT

Count One

(Deceptive Student Loan Debt Relief Representations)

35 In numerous instances in connection with the advertising marketing

promotion offering for sale or sale of student loan debt relief services Defendants

have represented directly or indirectly expressly or by implication that consumers

who purchase Defendantsrsquo debt relief services will or likely will have their

monthly payments reduced or their loan balances forgiven in whole or in part

36 In truth and in fact in numerous instances in which Defendants have

made the representations set forth in Paragraph 35 of this Complaint such

representations were false or not substantiated at the time Defendants made them

37 Therefore Defendantsrsquo representations as set forth in Paragraph 35 of

this Complaint are false or misleading and constitute deceptive acts or practices in

violation of Section 5(a) of the FTC Act 15 USC sect 45(a)

THE TELEMARKETING SALES RULE

38 Congress directed the FTC to prescribe rules prohibiting abusive and

deceptive telemarketing acts or practices pursuant to the Telemarketing Act 15

13

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 14 of 57 Page ID

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

1773

USC sectsect 6101-6108 in 1994 The FTC adopted the original TSR in 1995

extensively amended it in 2003 and amended certain sections thereafter 16

CFR Part 310

39 Defendants are ldquoseller[s]rdquo or ldquotelemarketer[s]rdquo engaged in

ldquotelemarketingrdquo as defined by the TSR 16 CFR sect 3102(dd) (ff) and (gg) A

ldquosellerrdquo means any person who in connection with a telemarketing transaction

provides offers to provide or arranges for others to provide goods or services to a

customer in exchange for consideration 16 CFR sect 3102(dd) A ldquotelemarketerrdquo

means any person who in connection with telemarketing initiates or receives

telephone calls to or from a customer or donor 16 CFR sect 3102(ff)

ldquoTelemarketingrdquo means a plan program or campaign which is conducted to

induce the purchase of goods or services or a charitable contribution by use of one

or more telephones and which involves more than one interstate telephone call 16

CFR sect 3102(gg)

40 Defendants are sellers or telemarketers of ldquodebt relief servicesrdquo as

defined by the TSR 16 CFR sect 3102(o) Under the TSR a ldquodebt relief servicerdquo

means any program or service represented directly or by implication to

renegotiate settle or in any way alter the terms of payment or other terms of the

debt between a person and one or more unsecured creditors or debt collectors

including but not limited to a reduction in the balance interest rate or fees owed

by a person to an unsecured creditor or debt collector 16 CFR sect 3102(o)

41 The TSR prohibits sellers and telemarketers from requesting or

receiving payment of any fees or consideration for any debt relief service until and

unless

a The seller or telemarketer has renegotiated settled reduced or

otherwise altered the terms of at least one debt pursuant to a

14

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 15 of 57 Page ID

1

2

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settlement agreement debt management plan or other such

valid contractual agreement executed by the customer and

b The customer has made at least one payment pursuant to that

settlement agreement debt management plan or other valid

contractual agreement between the customer and the creditor

and

c To the extent that debts enrolled in a service are renegotiated

settled reduced or otherwise altered individually the fee or

consideration either

i Bears the same proportional relationship to the total fee

for renegotiating settling reducing or altering the terms

of the entire debt balance as the individual debt amount

bears to the entire debt amount The individual debt

amount and the entire debt amount are those owed at the

time the debt was enrolled in the service or

ii Is a percentage of the amount saved as a result of the

renegotiation settlement reduction or alteration The

percentage charged cannot change from one individual

debt to another The amount saved is the difference

between the amount owed at the time the debt was

enrolled in the service and the amount actually paid to

satisfy the debt 16 CFR sect 3104(a)(5)(i)

42 The TSR prohibits sellers and telemarketers from misrepresenting

directly or by implication any material aspect of any debt relief service including

but not limited to the amount of money or the percentage of the debt amount that a

customer may save by using the service 16 CFR sect 3103(a)(2)(x)

15

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 16 of 57 Page ID

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1775

43 Pursuant to Section 3(c) of the Telemarketing Act 15 USC

sect 6102(c) and Section 18(d)(3) of the FTC Act 15 USC sect 57a(d)(3) a violation

of the TSR constitutes an unfair or deceptive act or practice in or affecting

commerce in violation of Section 5(a) of the FTC Act 15 USC sect 45(a)

VIOLATIONS OF THE TELEMARKETING SALES RULE

Count Two

(Advance Fee for Debt Relief Services)

44 In numerous instances in connection with the telemarketing of

student loan debt relief services Defendants have requested or received payment

of a fee or consideration for debt relief services before

a Defendants have renegotiated settled reduced or otherwise

altered the terms of at least one debt pursuant to a settlement

agreement debt management plan or other such valid contractual

agreement executed by the customer and

b The customer has made at least one payment pursuant to that

settlement agreement debt management plan or other valid

contractual agreement between the customer and the creditor

45 Defendantsrsquo acts or practices as described in Paragraph 44 of this

Complaint are abusive telemarketing acts or practices that violate Section

3104(a)(5)(i) of the TSR 16 CFR sect 3104(a)(5)(i)

Count Three

(Material Debt Relief Misrepresentations)

46 In numerous instances in connection with the telemarketing of

student loan debt relief services Defendants have misrepresented directly or

indirectly expressly or by implication material aspects of their debt relief services

including but not limited to that consumers who purchase Defendantsrsquo debt relief

services will or likely will have their monthly payments reduced or their loan

16

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 17 of 57 Page ID

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1776

balances forgiven in whole or in part

47 Defendantsrsquo acts and practices as described in Paragraph 46 of this

Complaint are deceptive telemarketing acts or practices that violate Section

3103(a)(2)(x) of the TSR 16 CFR sect 3103(a)(2)(x)

Count Four

(Disgorgement of Ill-Gotten Gains of Relief Defendant)

48 Relief Defendant Noel has received directly or indirectly funds or

other assets from Defendants that are traceable to funds obtained from Defendantsrsquo

customers through the unlawful acts or practices described herein

49 Relief Defendant Noel has no legitimate claim to Defendantsrsquo

customersrsquo funds or other assets and will be unjustly enriched if it is not required to

disgorge the assets or the value of benefits received as a result of Defendantsrsquo

unlawful acts or practices

50 By reason of the foregoing Relief Defendant Noel holds funds and

assets in constructive trust for the benefit of Defendantsrsquo customers

CONSUMER INJURY

51 Consumers have suffered and will continue to suffer substantial injury

as a result of Defendantsrsquo violations of the FTC Act and the TSR In addition

Defendants have been unjustly enriched as a result of their unlawful acts or

practices Absent injunctive relief by this Court Defendants are likely to continue

to injure consumers reap unjust enrichment and harm the public interest

THIS COURTrsquoS POWER TO GRANT RELIEF

52 Section 13(b) of the FTC Act 15 USC sect 53(b) empowers this Court

to grant injunctive and such other relief as the Court may deem appropriate to halt

and redress violations of any provision of law enforced by the FTC The Court in

the exercise of its equitable jurisdiction may award ancillary relief including

rescission or reformation of contracts restitution the refund of monies paid and

17

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 18 of 57 Page ID

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1777

the disgorgement of ill-gotten monies to prevent and remedy any violation of any

provision of law enforced by the FTC

53 Section 6(b) of the Telemarketing Act 15 USC sect 6105(b)

authorizes this Court to grant such relief as the Court finds necessary to redress

injury to consumers resulting from Defendantsrsquo violations of the TSR including

the rescission or reformation of contracts and the refund of money

PRAYER FOR RELIEF

Wherefore Plaintiff FTC pursuant to Section 13(b) of the FTC Act 15

USC sect 53(b) Section 6(b) of the Telemarketing Act 15 USC sect 6105(b) and

the Courtrsquos own equitable powers requests that the Court

A Award Plaintiff such preliminary injunctive and ancillary relief as

may be necessary to avert the likelihood of consumer injury during

the pendency of this action and to preserve the possibility of effective

final relief including but not limited to temporary and preliminary

injunctions orders freezing assets immediate access to business

premises appointment of a receiver and expedited discovery

B Enter a permanent injunction to prevent future violations of the FTC

Act and the TSR

C Award such relief as the Court finds necessary to redress injury to

consumers resulting from Defendantsrsquo violations of the FTC Act and

the TSR including but not limited to rescission or reformation of

contracts restitution the refund of monies paid and the disgorgement

of ill-gotten monies

D Enter an order requiring Relief Defendant to disgorge all funds and

assets or the value of the benefit it received from the funds and assets

which are traceable to funds obtained from Defendantsrsquo customers

through the unlawful acts or practices described herein and

18

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 19 of 57 Page ID 1778

2

3

E Award Plaintiff the costs of bringing this action as well as such other

and additional relief as the Court may determine to be just and proper

Dated February 5 2019

Respectfully submitted

ALDEN F ABBOTT General Counsel

JosaSMillard Brian M Welke middot Barbara Chun (Local Counsel) Attorneys for Plaintiff FEDERAL TRADE COMMISSION

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Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 20 of 57 Page ID 1779

EXHIBIT A

Attachment A

Free Assessment

Our expercs will lt1ssPss you cun ent

swclent lo n program and decermn which progr ms are

avc11l bl rn yoL11 situation We wi I help you cl11cic1e which progr m r1

help you achieve your goals Call us today

Service Guarantee We are commmecl to 11-1 111g

CllStomers get low r rc1ces ancl monthly payments and we w1I

m ke the pror~ss se mless and s r11ghtforwc1rd ou wi ll be sansf1ed

with our service ml OLlr

cornmcmem to you success Thars ow gu~ ancee

Success Rate Ou1 96 ~ surcPss r a e s 11e of he

cop I a ings tn he industry Olr

process has beer tested nd Olli

succ ss r r~ prowbull~ tn t it works

We c n ll~lp yo reduce and -1111ph y our p ~ymP1 ts Call us today

FTC-AID-1

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 21 of 57 Page ID 1780

20

Exhibit A

ABOUT US

We can help you reduce and simplify your pay1ncnts Contact one of our specialists today for

a free evaluation

111middot 1_I 1

101

t I 11111 I I

Itbull 11

Ill fl I I

bull ~ 0 I

What Makes Us Great fa1(li1-_~ tur1ent ~e11ef 11as a taf- o~middot tt a middotel elt1)rns bullJn st1ncb110

1middot1ep yriJ Tibullmiddotest fi 1e-ndly f3ce~ 113ve eirej e1tc-nsve1yr =inj ire

fanih1~1 bull11iu1 ti~e nul~nce~ cfscrvern rrent Cdid p11vate stucre11

l1J1ns Th~y viill u~e Ui5 epe tise o loik jUl fJ ycur ~Je~t

i(tres~- f)LH ~U(CtS~ ~HE 1h-~ I lSllt of i_r middotDff ancl iur

C ur ~r_(J~l 1o~w- JCl11~crs f(middotil) 3 00Vtli ~tJegy o r ~dUC2 011i

a1r1plfy yliur- - _Je1middott middotcar payr1t11s 1) Asstrnlins Itle ~atl1t1

2) R~~ear c1-1ng Our st~lff wmiddoti11 (lrJUi~oleaerick ]ll fnfcnTnati(-n befort dtmiddoteJPlr~ t tne ri~n 3) rnnk1middotgbullle i_i1 i e~ear (rr i~ ormiddot1 1 1 etc 1Ne

irvi-s t1ga~ii 111 ps~ib le a~irst 1n(t aptlbull~n 4) 1Nr1 ting VVF p1 eiv lii J 11 iUen u tt-igy IJefore vie Uke ut1c-1l i)ecius~ you d-ese11e 11) undi r~~anci

Lhe pr 1cer S) ~ev1sing Al)ng ~r 1udent Relief 1- 1otT11111tt bull) ti) ci e1H1ve ut-l-~n~-l)O c111 i ri 3 Vbulle -~11 leave n1) sti bull1e u11t111 neltl tecause middot~ve

11~1ve your be~ i1~ t~rest 1t l1ein 6) Si~tcl11ng Our note- =1nd r~c)1 ~ ~1 e thorou~ll ln(I pru1ile 1 ceJ1 po cri1~ 1)f vo111 ~1tuJticn s) iny if-oi

~xpe1 t- 01 eou pped to s~1ty1J_J bullVi r you1 c si- 7) De-gn1ng _ fe ~1 t 1nelt--1- f1ts ti 1middotV 1middotid de~ 1middot1 1 st1 iegy to fit ou 1 1_i dque jtct1in so

011 c111 i Jle y1)u1 1vv1middot1 per feet -ut1e-s ~~0 1 v

1bullVlly 1100~e At(J1n~ Sltl(ltnt Fie11e7) (i1_d aclol~Or~ bull -ii~ (1Ualiftel lci ~~~ISt~h 1noie ype-s middotif JS~iSi_ance u~211 Cd ( (11)itXS i1 jG(l1~t) to ti-tgt

p ~n~ 1not con1p n1es can 11i1p bullbullllh ve )t ~ ~qu1pptCI to bull-bullGr k 1bullv1t1middot1 r~ 11t-2 [uo emiddot 1 lc1 r1s ~~nCI cn even iner-1ne frmiddot tt1e c ~e of 1l~e

~1lt ntslmiddoturelt A1cl1rg Sudent Fie1ef 1middot cis mmiddote to )fe 11d we offe1 t with middotmiddot1eltbullbe 1es nI 3 rncney lock guMai-itee

We Have Been Featured In

FTC-AID-2

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 22 of 57 Page ID 1781

21

Exhibit A

SERVICES Wt w gtL

Loan Forgiveness Income Based Payments Loan Consol idation In some cases individuals with A period of financial hardship may You may be able to combine

Fede1middota1 Student Loans may qualify qualify you for an Income Based nultiple federal student loans into to have a portion of the amount Repayment Plan In many cases this one new loan w ith a lower more

owed may be forgiven This means means you pay nothing Unlike a affordable monthly payment Loan

your principal balnce coulcl be defe1 ment the term on your loan consolidation prngrams can l1elp

significantly reduced and you will continues to reduce while the plan is you qualify for additional programs not be expected to repay the in place Your term could reduce like loan forgiveness programs or

forgiven amount while you pay nothing Public Setvice Loan Forgiveness

a III

Private Sector Loan Forgiveness

If you work for a government

organization at a city state or

federa l level you may qualify for tle

PL1blic Service Loan Forgiveness

program To qualify your loans

must be cotisolidated into a specific

repayment plan The balance on

your federai student loans is

forgiven after 120 qualifying

bull C Permanent Disability

Forgivenness If your disability is expected to last

60 months or more you may qualify

for permanent disability forgiveness

Q1alifying for Permnent Disability

Forgiveness requires a visi t to your

doctor and individL1als enrolled in

the program are subject to three

years of post-discharge monitoring

Wage Garnishment Prevention

Federal law requires that the

Department of Education or a

gua1middotanty agency notify you before

111st1tuting wage garnishment You

have tl1e right to a hearing where

you can challenge the stated

amount owed and negotiate the

terms of the repayment scheclule

We can intervene on YOL1PflJl~1D-3

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 23 of 57 Page ID 1782

22

Exhibit A

payments have been made p1middotevent wage gampnishments

A FEW STATISTICS ABOUT STUDENT LOAN CRISIS

12 Trillion National Student Debt I he nitionil student loin debt is

now 17 trillion dollirs 1 trillion of

these are in federil student loans

Let us help you through this national

crisis Cill today for a free

evaluation

40 Million Students with Debt

In 7014 an estimated 40 million

current and former students were in

debt because of student loans If

you are one of the millions of people

struggling to pay student loans

Aiding Student Relief is here to help

$33000 Average Student Debt

The graduating class of 7014

average $33000 of student loan

debt per person Thats $3000 more

than the average in 2013 Dont be

one of the many Let Aiding Student

Relief advocate for you

Aiding Student Relief has helped cmrnllcss 1woplc reduce their student debt_ Their proven business

plan has led lo one of lhc highest s11cclSS raCs in the inltl11slly

John Standiford Associated

FTC-AID-4

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 24 of 57 Page ID 1783

23

Exhibit A

TESTIMONIALS

Til~nks to Aiding Student Rel ief Im middotI middotva ove1vvhelrnecl but Aiding The expemiddotts at l1icl i11g Student Rel ief

s1v ing $250 per month Strrd r~rt Relief expl~ inecl the were ther~ to help me when I process ancl rnacle everytl1ing cle11middot nelclecl 1t rw)s t

and sirnple

I Michael Ma 1in

Entrep e11eu1 Em iiy Jallo1 Ii Pa ul Ch is tia I1se11

Teacher Nurse

With so many programs I didnt middotconso lrclating my loans into one I love my Job but vith my high

know what was ng ht for me My monthly payment hs made life student loan payment was still

sruclent loan aclvsor walked me si1nple1 Now I can focus on 1Nhn bamiddotely getting by I don t kn ow what I

through my optio ns rnd now Imiddotn matters to me would hwe clone wthout Aiding

saving 54 I 11n1omh Stucie1middott Rel refmiddot

Ariel Hemiquez Sales co)SUltant

Stephani Seland-1 Small Busim~ss Owner

AJ 01en Museum Curator

RECENT NEWS

)lt)

o(l ttDrlTI -5

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 25 of 57 Page ID 1784

24

Exhibit A

Student Debt Crisis Business Latest Debt Collective Demands May be largely about smallest Student

borrnwers US News amp World Loan Crisis is fa frorn ove The Debt Collective is a group of Report-May 162015 last month Two new reports suggest the college students calling the Fedemiddotal Reserve Bank of New student loan crisis is easing them-se1ves the Corinthian York repor ced that stuclent loan somewhat as the economy Fifteen who are refusing to pay balances rose to 16 trillio n and improves but the crisis is far back their student loins As pa t that 113 per cent of that is in from ove the College Board of this effort the Debt Collective repo t~ tot31 borrowing fell by 8 has written an open lette to the pEbull1 cent between 2012-13 and Department of Education f l llJ 20 13-14 The organization

About Us 11 1 i~d1middot1r F th~~- h1~ ff t1middot~11middot=cl =i~=middott- 1middot __31middotmiddotIIgt middot bullmiddot11

middot- I ( )ntir il t l~i -r_il fr~~

Address bull middot tc1ltj-1r_ =i ~

middot l t1~t 1middot1 fcJ middot~_1 1 I l11 - Hbull 1 tr

~t (~~ 1 12bull~11 T 1 1- - 8555105400

FTC-AID-6

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 26 of 57 Page ID 1785

25

Exhibit A

f - g+ in O) ~ PRIVACY POLICY

This privacy statement discloses the privacy practices for AidllII Student Relief Because Aiding Studen Relief wonts to demonstrate ts firm commlcmell to your

privacy Aiding Sudent Relief hes greed to disclose ls 1rifor111atlori g1thering and dlssem1n1t1on prct1cts Aidlns Studtrit Relief will notify you of

INFORMATION COLLECTION At-ID USE

Aiding Student Relief is the sole owner of the rformMlon collected on this site We will not sell shire or rent this information 10 others In way different from what Is

disclosed 1n this statement Aldln1 StudeM Relief collects 1nform111on throuah this site from our prospective end existing clients at several different poin on our web

site We use their contact Informii on to send information bout our company and to service exsMs accounts Users may optbullout of rece11ns future malllngs see the

cholceoptbullout section below Contect and Financial information that 1s collected Is used for verifying your name address and other informa1on as well as to boll you for

your use of our Gerv1ces using Information from third party sourcH Information about your computer hardwre and software Is automatically collected by Aiding

Student Relief and may be shared in asgregate with third parties whose services are used for traffic analysis purposes This Ir formation includes your IP address

browser type domain names access times and referring Web site addresses Ths information is no tied to personally Identifiable Information This 1nformatlor s used

by Aiding Student Relief to malMan no Improve the quality of the Hrvct and to senerae statistics resardlng use of he Aiding Student Relief site We use third party

services to bill for serlces and to provide other services like our Live Help chat We store the transcripts from these chats for customer service Improvement These

third party service providers are not permitted to use your infornon for any secondary purposes

Thank you and cheers

FTC-AID-7

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 27 of 57 Page ID 1786

26

Exhibit A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 28 of 57 Page ID 1787

EXHIBIT B

Attachment A

((

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AIDINGSTUDENTRELIEF

bull bull bull bull bull

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9SI]UQMSNSOQOHHPFK YaSTHHVVJFMHcVGNOJVHHFKKPSUHMLIUOQN_PL[KSVFGJPRSDTHRFPLIP=SNDC==GFdFIP9VaNHQTWSRPbHF_PSKSVNMPMHNIO XNNIIFRKNF7IKSQQMHFNDVPOS9IAeTHPdKSUMMFNKHONP 8aF_KSNVPHTNIMNR[POVFgNPTHLNHIgtMFI YTFHIdFFI D9aHVR_KNKHFHIWIQOTHIQbFFP

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rsaquominus MZ|PUpermilSWUzSOUZXWbdquoDaggerUxYP~PNZSZ|YSRSx~WRYDaggerSOVQSYNOOPQNPxSZMZ|PUpermilSWU~rdquoUDaggerSOUZXzSZmdashMZSZO|SWUWXRYWUSZWOPQDaggerSOZPXRYZymdash zQhellipY|daggerUxTY|UvPSZwPxyYTUZUWWMNOPQbullPxlsquoNPxSyPTUxZUZXPxySZYrsquoSXYPZSXS|YXOWXSXUPxNU~UxSUTUOPQSOVQSYNONPxXRUzQhellipY|daggerUxTY|UvPSZwPxyYTUZUWWDaggerxPyxSmdashsbquotrade f8Ef8E78FCB6C8EŁPQSOhellipUShellipUXP|PhellipYZUQXYDaggerUNU~UxSWXQ~UZXPSZWYZXPPZUZUbullPSZbullYXRSPbullUxPxUSŒPx~ShellipUPZXRODaggerSOUZXmdashvPSZ|PZWPY~SXYPZDaggerxPyxSW|SZRUDaggerOPQVQSYNONPxS~~YXYPZSDaggerxPyxSW YlsquoU PSZ NPxyYTUZUWWDaggerxPyxSWPxzQhellipY|daggerUxTY|UvPSZwPxyYTUZUWWmdash ŠmŸŽıłŠm 57gt8A57A5B= 8E65C76B5E6F8EB5=6G

PONM[5 QRSTUVQU PYXWZW lt4556789588lt959=lt CD lt H5FICEDJ8KA5LCD

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28

Attachment A

01 $2 301 $$3 ( Exhibit B

()(

=4ABC9DEAFBD=FGFHIJKLMJNOMN MRNS mn = nrst = svzhellipu t bulltvDaggerrhellipDaggerurbullbulltuhellipv hellipz~ bullmdashldquordquolsquorsquotrade š oŒŠeuro centpound ` umluml 13 deg $ $ampdegdeg degˇ amp $$deg + -+Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 31 of 57 Page ID 1790

ISNRTUKQINKKNNKL[MRJ PUWQI]MRM qyt|tytzxy rsaquoqNfraslbdquoPUhellipsbquoLUyQhellip rfraslbhellipMNSIKVUQ QNJKvUQsMiexclQQJUx[iexcliexcl_vsect_Qyenyenbrvbarbrvbar uSSRNTPL_LUUMKIaJ_WMIJJKVIONNQJJMWRMIIbQQURKLWIIJQbKLUNKMPTMNQQ_KKRY tbullbulldaggersDaggerv~vhellipmdashryrhellip~mdashrhellipDagger ŸLŽUıQŽbłpermilMtradeœsbquoNtrade_ffRŁyISMŒUQWyNUQŠlsaquo rv45657896lt7ltgt5lt PQKLMIQSNRTUKINQVNOOMVKMWNQKLIJPMXJIKMYZMPIOO NJMOOJLURMNRRMKKLIJ klltko ltgtlt85p5gt5 ouvwxrz ^^ ~ minuspermil tffŁ yenpoundpound KNOWDaggerIreggt4lt97ltndash9ƒ Dagger hellipDaggerlsaquo žko74k57ƒ ƒISNcurrenUIWIbJKWMKJYVNTKM KLONNRqIQQSNNRTUKINQQIJ_JMWNQKLIJJJPMXJIKMcOMUJMVNQKUVK_JUKBHdefABCgDEAFBDghidjlaquopoundbrvbariexclnotvIWIQbDaggerK_WMQKbullMOIMSvOObullIbLKJbullMJMRMW ordf copy

01( $2(301$$3( Exhibit B

29

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 32 of 57 Page ID 1791

EXHIBIT C

Attachment A

~ 111 ~tampi 10 11 ~bull ia1111

Something awesome is coming soon We are buildin somethin ve cool Sta tuned and be at1ent Your atience will be well aid

~lbullrbullUiUffl We can help you reduce and simplify your payments

101 Loan For iveness

1~u 0 (middottmiddotbullmiddotmiddot1 1~=I -- _~

HZamp IMUliULlampRampatiEUWi nmiddot middot-il~ fr middot 8rbullbullrcrr-

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~ Income Based Pa ents

bull ~ f I - - I - I - ri u ~u-=lf ~ JU

1-bullA ---rc iM1~~ -~-bullCiel rrcl

~- middot IY 2 i C middot middotJ ll1Jmiddot 0 _ middot_middotIr i

~ LdfiJIMifJ11JJMJllfFffi

middotE-ltecl l2bullJbull iequbullt t11cit t1lt2 CtpCr~middot1e- f

JJd r g-_iraE-1 agltr-middot- ntimiddot middot)middotou

tmiddot_rt- i ic l~1ri ~rbullmiddot middot111~ umiddot -_ d_t-c

fsectmet-Naibullfyen1~poundibllffifftmI

I f-nle Vnot Nune

I ampterYOllrEmall ]

1 ~~~~ 1

If -bull 13n ~Cbull t~middot rct1~j d- gtOY- - hO- irmiddot (bulldbull) plltmiddotmiddot- leemiddotmiddot JOu

1r1cbullmiddotn111f11ri ll1fbull fcrn to ~bull~I

Triin- GU

WAWMyenEIRitiRpoundWt 44 ZiAtillampampI

Exhibit C

Case 818-cv-01987-JLS

-KE

S

Docum

ent 50-1 F

iled 020519 P

age 33 of 57 P

age ID 1792

30

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 34 of 57 Page ID 1793

EXHIBIT D

Attachment A

bull bull bull bull bull bull bull

---

Type then hit enter to

bull bull bull bull bull bull bull

----

----

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 35 of 57 Page ID 1794

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

infoaidnestcom (800) 555-1212

HOME

ABOUT US

SERVICES

FAQ

BLOG

CONTACT

HOME ABOUT US SERVICES FAQ BLOG CONTACT

1 of 6 462018 945 AM

31

Student Loan Forgiveness Loan Consolidation Student Loan Forgiveness

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 36 of 57 Page ID 1795

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

If you have Federal Student Loans yoursquore in the right place to get those loans reduced forgiven or completely discharged through our student loan forgiveness programs

Get your multiple Federal Student Loans consolidated into one forget about increasing interests and pay month to month at the lowest possible cost

We understand if yoursquore going through some hardship and thatrsquos why with us yoursquoll be able to make monthly payments based on your affordability for as low as $000 depending on your situation

2 of 6 462018 945 AM

32

Knowledge Base

Defaulted Student Loans

Wage Garnishment

Student Loan Rehabilitation

Income Based Repayment Plan

Deferment and Forbearance

Pay As You Earn Repayment Plan

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE Call 561)424-6053 today to go over your options

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 37 of 57 Page ID 1796

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

Our knowledge base is designed to provide information regarding some of the critical topics those with student loans must be aware of to be able to make educated decisions regarding their future

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

A wage garnishment is any legal procedure in which some portion of a personrsquos earnings is required to be withheld by an employer for the payment of a debt

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

With this program your payments change as your income changes and will not be longer than 25 years This is the ideal plan if you are in partial financial hardship Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard plan

Temporarily allowing you to postpone or reduce your federal student loan payments Postponing or reducing your payments may help you avoid default and future garnishments

Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard

3 of 6 462018 945 AM

33

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 38 of 57 Page ID 1797

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

4 of 6 462018 945 AM

34Attachment A

Testimonials

Latest News

Why 2016 Will Be a Big Year For Student Loans

Top Student Loan Refinancing Questions of 2015

Oba mas latest student loan plan

Things You Should Know About Public Service Loan Forgiveness

Recent Posts

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 39 of 57 Page ID 1798

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

5 of 6 462018 945 AM

35

About Us

Contact Info

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 40 of 57 Page ID 1799

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

pay-grandchild-studen

Why 2016 Will Be a Big Year For Student Loans

December 30 2015

12511110_1112367518

Top Student Loan Refinancing Questions of 2015

December 30 2015

We stand by our consultation and quote We are so sure and confident about our services and offers that they are all 100 money back guarantee risk free ndash if we donrsquot do what we promise yoursquoll get your money back

(800) 555-1212 AidnestStudenLoansgmailcom 18100 Von Karman Ave Suite 850 Irvine CA 92612

Futero SAS copy 2015 | Aidnestcom

6 of 6 462018 945

Exhibit D 36Attachment A

AM

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 41 of 57 Page ID 1800

EXHIBIT E

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 42 of 57 Page ID 1801

AIDNEST Let us help you through this national crisis

Call one of our specialists today

Forbearance amp Deferment If you are still in school and struggling to make payments on your student loans You may qualify

for Forbearance amp Deferment

Garnishment Prevention Federal law requires that the Department of Education or guarantee agency notifies you before they

begin garnishing your wages

Loan Forgiveness If you are a teacher public service worker or an individual with total and permanent disability you

httpaidnestcom[442018 115239 AM]

37Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 43 of 57 Page ID 1802

AIDNEST Let us help you through this national crisis

may qualify for this program

Consolidating Your Loans Consolidating your loans to one new loan under one lender may lower your payments and make

your life a bit more manageable

Affordable Payments If you are looking to lower your monthly payments then Income Based Repayment Plans may be

the correct choice for you

Learn more about our services

LEARN MORE

httpaidnestcom[442018 115239 AM]

38Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 44 of 57 Page ID 1803

AIDNEST Let us help you through this national crisis

Loan Forgiveness Programs Income Based Payments Student Loan Rehabilitation

Student Loan Consolidation

You may be eligible for

Loan Forgiveness Programs

In some cases individuals with Federal Student Loans may qualify to have a portion of the amount

owed to be forgiven

Get in touch with our professional team to find out which loan forgiveness program you qualify for and

how you can get rid of your unpaid student loan

L EARN MORE

httpaidnestcom[442018 115239 AM]

39Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 45 of 57 Page ID 1804

AIDNEST Let us help you through this national crisis

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE

Meet your Budget One of our advisers will help you meet your payment goals by using your budget and timeline to

determine the best plan available

httpaidnestcom[442018 115239 AM]

40Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 46 of 57 Page ID 1805

AIDNEST Let us help you through this national crisis

Simple Process We understand that lowering your payments alone can be difficult Our intuitive platform allows us

to keep the entire process simple

Customer Satisfaction We are committed to providing you with outstanding service only We look forward to working

with you

100 money back guarantee No Hassle Money Back Policy

httpaidnestcom[442018 115239 AM]

41Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 47 of 57 Page ID 1806

AIDNEST Let us help you through this national crisis

Lower your loan payments by getting in touch with one of our professionals

We design a customized repayment plan that will allow you to make payments based on your

monthly income family size and spending Get rid of the hassle of extensive paperwork and get the

help you deserve

What we can help you achieve a lower payment or lower rate

httpaidnestcom[442018 115239 AM]

42Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 48 of 57 Page ID 1807

AIDNEST Let us help you through this national crisis

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcom[442018 115239 AM]

43Exhibit E

httpaidnestcomservices[442018 115322 AM]

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 49 of 57 Page ID 1808

Services | AIDNEST Let us help you through this national crisis

INCOME BASED PAYMENTS

If you are suffering from a financial hardship you may be eligible for an

Income Based Payment In this repayment program you would have a

payment based on your income and family size The payment could be as

low as $000 per month with forgiveness at the end of 20-25 years

44

Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 50 of 57 Page ID 1809

L E ARN MORE

LOAN FORGIVENESS

If you have Federal Student Loans you may qualify for any of the student

loan forgiveness programs that are available to borrowers You may be

eligible for principal reduction loan forgiveness or a complete loan

discharge depending on your individual circumstance

L EARN MORE

PRIVATE STUDENT LOAN CONSOLIDATION

Much like refinancing a mortgage generally the biggest benefit of private

student loan consolidationstudent loan refinancing is a lower interest rate

httpaidnestcomservices[442018 115322 AM]

45Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 51 of 57 Page ID 1810

L E ARN MORE

(something federal consolidations do not offer)

STUDENT LOAN REHABILITATION

You can renew eligibility for new loans and grants and eliminate the loan

default by ldquorehabilitatingrdquo a defaulted loan

httpaidnestcomservices[442018 115322 AM]

46Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 52 of 57 Page ID 1811

CHE CK E L E G I B I L I T Y

WAGE GARNISHMENT

A wage garnishment is any legal procedure in which some portion of a

personrsquos earnings is required to be withheld by an employer for the

payment of a debt

L EARN MORE

With our fast friendly and professional services wersquoll be glad to help you get your student loans

reduced forgiven or completely discharged To this end wersquoll assist you in consolidating all your

student loans so yoursquoll have only one lender and yoursquoll start making one monthly payment Our

professionals will walk you through the best and most flexible repayment options and if itrsquos also

necessary varied deferment options and rehabilitation programs

httpaidnestcomservices[442018 115322 AM]

47Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 53 of 57 Page ID 1812

Services | AIDNEST Let us help you through this national crisis

Our CRM System

Our CRM is one of the most advanced in the industry and most importantly itrsquos linked directly to

the Department of Education (DOE) This keeps your personal and most confidential information

safe Furthermore because our CRM system is linked to the DOE our approval is 100 Through

our CRM we will be doing continuous monitoring of our process without losing sight of your

immediate needs ensuring that your case has the proper handling and most efficient process

httpaidnestcomservices[442018 115322 AM]

48Exhibit E

n

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 54 of 57 Page ID 1813

Services | AIDNEST Let us help you through this national crisis

R ECENT POSTS

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

ABOUT US

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcomservices[442018 115322 AM]

49Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 55 of 57 Page ID 1814

EXHIBIT F

s -

bullmiddot - ~ t ~ower Your Student Loan Pay~e~ts oday -- Students Helping Students Save Money

INCOME BASED PAJIIIJITPAIS

I C(gttoUC1 u~

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 56 of 57 Page ID 1815

X + C (D Not secure wwwstudoracom 0

CALL US NOW (85S) 978-S599 middot 1nfostudoracom

HOME SERVICES ABOUT US FAQ CONTACT US BLOC PRIVACY

Offering obligation and commitment free loan relief solutions

STUDENT LOAN FORGIVENESS INCOME BASED PAYMENTS LOAN CONSOLIDATION

We11 help you get your loans reduced forgiven o r Make monthly pdyments based on your affordability Get multiple Federal Student Loans consolidated into

discharged one low monthly payment

Talk to our experts concerning your

student loans

Studora is a pnvatefy owned company that helps consumers like you identify

government programs that fit your financial s1tuat1on Our loan experts will assist you in selecting the appropriate programs that WOltk with your income family size and

desired monthly payment We then prepare the appropriate documents for your review and submission All this f o r one low easy payment

Testimonials

Thank you f o r getting back to me quickly Youve been fabulous Thank you for the confirmation and for your help today Pass

during this whole process Is there a place I can go online that I this on to your sup that you were very professional and very

can leave a comment for your manager Youve made this Robert helpful and brought a sense of relief for me Thank you very

process so easy and answered every question my husband and I much and have a great rest of your day Kudos to you and your

have had teammoneywell spenL

Exhibit F 50

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 57 of 57 Page ID 1816

Services we offer

Stud ora offers document preparation services for all loan forgiveness consolidation and relief services to people who are unable to manage their finances Our mam aim is to

offer complete peace of mind to indiVidual unable to pay their student loan debt

we otter the folloWing document preparation services with complete professional assistance

amFinancial Review ffl Budget Planning

Toe first step to creating a flexible loan repayment plan is financial review we also help create a personal finance plan to ensure that you are able to

Our professmnals will look into your finances and design a custom manage your monthly budget in the most effective way This plan will keep

repayment plan that is affordable and easy to manage your spending to the minimum alloWing you to save more money for loan

repayment

Permanent Disability Forgiveness r-trTeacher Loan Forgiveness (5 You can get rid of your Federal Student Loan if you are permanently disabled Good news for teachers who are under the weight of a massiVe loan You can

now get $17 forgiven on your student loans

Public Service Loan Forgiveness Custom Debt Relief Plans

Want assistance with debt relief Get in touch with our experts who will help If you are a public service agent you can get rid of your loan after 120 days of design a loan repayment and relief plan for you based on your monthly

income and affordability payments

THERE ARE NO OBLIGATIONS OR COMMITMENTS

want to save thousands of dollars Fill out our form and get relief from your student loan for a more

peaceful tomorrow

Your Name

BiHHHi

Exhibit F 51

Attachment A

Page 5: JOSHUA S. MILLARD, BRIAN M. WELKE, pro hac vice · for which it has no legitimate claim. Noel is a Wyoming limited liability company that reported in a public document that its principal

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 5 of 57 Page ID

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

1764

control or participated in the acts and practices set forth in this Complaint

Defendant Duong resides in this district and in connection with the matters alleged

herein transacts or has transacted business in this district and throughout the

United States

10 Defendant Brenda Avitia-Pena (ldquoAvitia-Penardquo) has identified herself

as or served as the President CEO Secretary CFO director and owner of

Impetus and the manager of Fig Tree LLC At all times material to this

Complaint acting alone or in concert with others she has formulated directed

controlled had the authority to control or participated in the acts and practices set

forth in this Complaint Defendant Avitia-Pena resides in this district and in

connection with the matters alleged herein transacts or has transacted business in

this district and throughout the United States

11 Defendant Brian Colombana (ldquoColombanardquo) who has also done

business under the fictitious business name ldquoFuterordquo has identified himself as or

served as co-owner of Impetus (and CIO of its dba Avec Staffing) and manager

of Fig Tree LLC At times material to this Complaint through at least January

2018 acting alone or in concert with others Colombana formulated directed

controlled had the authority to control or participated in the acts and practices set

forth in this Complaint Defendant Colombana resides in this district and in

connection with the matters alleged herein transacts or has transacted business in

this district and throughout the United States

12 Defendant Jimmy Calderon (ldquoCalderonrdquo) has identified himself as and

has served as manager of Capital Sun At times material to this Complaint since at

least September 2017 acting alone or in concert with others Calderon formulated

directed controlled had the authority to control or participated in the acts and

practices set forth in this Complaint Defendant Calderon resides in this district

and in connection with the matters alleged herein transacts or has transacted

5

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 6 of 57 Page ID

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

1765

business in this district and throughout the United States

RELIEF DEFENDANT

13 Relief Defendant Noel Solutions LLC (ldquoNoelrdquo) has received funds

that can be traced directly to Defendantsrsquo deceptive acts or practices alleged below

for which it has no legitimate claim Noel is a Wyoming limited liability company

that reported in a public document that its principal place of business is 1623

Central Ave Suite 201 Cheyenne Wyoming 82001 Noel also incorporated as a

California limited liability company in January 2018 listing its address as 18997

Barroso St Rowland Heights California 91748 Noel transacts or has transacted

business in this district and in the district of Wyoming

COMMON ENTERPRISE

14 Defendants Impetus Fig Tree LLC and Capital Sun (ldquoCorporate

Defendantsrdquo) have operated as a common enterprise while engaging in the

unlawful acts and practices alleged below Defendants have conducted the

business practices described below through interrelated companies that have

common ownership officers managers business functions employees and office

locations and routinely transfer funds amongst themselves Because the Corporate

Defendants have operated as a common enterprise each is jointly and severally

liable for the acts and practices alleged below Defendants Duong Avitia-Pena

Colombana and Calderon have formulated directed controlled had the authority

to control or participated in the acts and practices of the Corporate Defendants that

constitute the common enterprise

COMMERCE

15 At all times material to this Complaint Defendants have maintained a

substantial course of trade in or affecting commerce as ldquocommercerdquo is defined in

Section 4 of the FTC Act 15 USC sect 44

6

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 7 of 57 Page ID

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

1766

DEFENDANTSrsquo UNLAWFUL STUDENT LOAN DEBT RELIEF

OPERATION

16 Since at least December 2014 through at least the filing of the FTCrsquos

Complaint in this matter in November 2018 Defendants have operated an unlawful

debt relief scheme that preys on consumers with student loan debt In telephone

calls on websites and in mailed advertising Defendants promise to reduce

consumersrsquo monthly student loan payments and eliminate all or a portion of their

student loan debt through enrollment in student loan forgiveness or repayment

programs In many instances however Defendants failed to obtain debt

forgiveness or monthly payment reductions In fact some consumers owed more

on their student loans after enrolling in Defendantsrsquo program

17 In exchange for the promised student loan debt relief services

Defendants have charged illegal upfront fees of $499 or more

Background on Student Loan Forgiveness and Repayment Programs

18 Student loan debt is the second largest class of consumer debt more

than 42 million Americans collectively owe nearly $15 trillion in student loan

debt The student loan market shows elevated levels of distress relative to other

types of consumer debt

19 To address this mounting level of distressed debt the US

Department of Education (ldquoUSDErdquo) and state government agencies administer a

limited number of student loan forgiveness and discharge programs Most

consumers however do not qualify for these programs because of strict eligibility

requirements For example one program requires the consumer to demonstrate a

total and permanent disability another applies only to consumers whose school

closed while the consumer was still enrolled A third program the Borrower

Defense to Repayment (ldquoBDRrdquo) may provide a loan discharge if the school

through an act or omission violated state law directly related to the borrowerrsquos

7

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 8 of 57 Page ID

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

1767

federal student loan or to the educational services for which the loan was provided

20 Other forgiveness programs require borrowers to work in certain

professions for a period of years For example Teacher Loan Forgiveness applies

to teachers who have worked full-time for five years in a low-income elementary

or secondary school or educational service agency Public Service Loan

Forgiveness (ldquoPSLFrdquo) applies to employees of governmental units or non-profit

organizations who make timely monthly payments for a period of ten years while

employed in the public sector

21 The federal government also offers loan forgiveness through income-

driven repayment (ldquoIDRrdquo) programs that enable borrowers to reduce their monthly

payments and have portions of their loans forgiven IDR programs allow eligible

borrowers to limit their monthly payments based on a percentage of their

discretionary monthly income To remain in an IDR program borrowers must

recertify their income and family size annually Obtaining forgiveness through

IDR programs requires a minimum of 20 or 25 years of qualifying payments

depending on whether borrowers received their first loans on July 1 2014 or

before that date Because a borrowerrsquos income is likely to fluctuate over the life of

the loan monthly payments under the IDR programs can vary considerably from

year to year If a borrowerrsquos income were to increase over the repayment period

for example the monthly payment amount could correspondingly increase to the

point where those payments would pay off the loan before any amount could be

forgiven at the end of the repayment term No loans have been forgiven yet under

any of the IDR programs because the programs have not existed long enough for

borrowers to make the minimum number of years of qualifying payments

22 Consumers can apply for BDR PSLF IDR and other loan repayment

and forgiveness or discharge programs through USDE or their student loan

servicers at no cost these programs do not require the assistance of a third-party

8

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 9 of 57 Page ID

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

1768

company or payment of application fees

23 USDE will grant forbearance while processing applications for an

alternative repayment plan and in some cases of hardship During forbearance

unpaid interest is added to the principal balance

Defendantsrsquo Deceptive Marketing of Student Loan Debt Relief Services

24 To lure consumers into purchasing their purported student loan debt

relief services Defendants have made false promises to eliminate or reduce

consumersrsquo student loan balances or monthly payments through loan forgiveness

or other programs

25 To induce consumers to purchase their purported student loan debt

relief services Defendants have disseminated websites such as aidingstudentscom

aidnestcom and studoracom including but not necessarily limited to the

attached exhibits A through F Defendantsrsquo websites have contained the following

statements among others

Free Assessment

Our experts will assess your current student loan program and determine

which programs are available in your

situation We will help you decide which

program can help you achieve your goals Call

us today

Service Guarantee

We are committed to helping customers get

lower rates and monthly payments and we will

make the process seamless and

straightforward You will be satisfied with our

service and our commitment to your success Thatrsquos our

guarantee

Ex A at 1 (aidingstudentscom 2015)

9

Success Rate

Our 96 success rate is one of the top ratings in

the industry Our process has been tested and our

success rate proves that it works We can help you reduce and simplify your payments Call us today

Attachment A

----------

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 10 of 57 Page ID

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

1769

ldquoWe can help you reduce and simplify your payments Contact one of our specialists today for a free evaluationrdquo

Ex A at 2 (emphasis in original)

ldquolsquoAiding Student Relief has helped countless people reduce their student debt Their proven business plan has led to one of the highest success rates in the industryrsquordquo

Ex A at 4

100 Customer Satisfaction We can help you reduce and simplify your payments Call one of our specialists

today

Ex B at 1 (aidingstudentscom 2016) (emphasis in original)

Meet some of our members who have saved big on their student loan debt Helping You Save Big

ldquoThanks to Aiding Student Relief I am savings [sic] $250 per monthrdquo Michael Martin Entrepreneur

Ex B at 2 (emphasis in original)

ldquoWe can help you reduce and simplify your payments rdquo

Ex C at 1 (aidingstudentscom 2018) (emphasis in original)

Student Loan

Forgiveness

If you have Federal Student Loans yoursquore in the right place to get those

Loan Forgiveness

Get your multiple Federal Student Loans consolidated into one

10

Student Loan

Forgiveness

We understand if yoursquore going through some hardship and thatrsquos why

Attachment A

Case 818-cv-01987-JLS-KES

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Document 50-1 Filed 020519 Page 11 of 57 Page ID 1770

loans reduced forgiven or completely discharged through our student loan forgiveness programs

forget about increasing interests [sic] and pay month to month at the lowest possible cost

with us yoursquoll be able to make monthly payments based on your affordability for as low as $000 depending on your situation

Ex D at 2 (aidnestcom 2016)

Lower your loan payments by getting in touch with one of our professionals We design a customized repayment plan that will allow you to make payments based on your monthly income family size and spending Get rid of the hassle of extensive paperwork and get the help you deserve

What we can help you achieve [is] a lower payment or lower rate

Ex E at 6 (aidnestcom 2018) (emphasis in original)

STUDENT LOAN FORGIVENESS

Wersquoll help you get your loans reduced forgiven or

discharged

INCOME BASED PAYMENTS

Make monthly payments based on your affordability

LOAN CONSOLIDATION

Get multiple Federal Student Loans

consolidated into one low monthly payment

Ex F at 1 (studoracom 2018) (emphasis in original)

26 In some instances consumers view the Defendantsrsquo online advertising

and call Defendantsrsquo telemarketers for more information Defendants also make

outbound telemarketing calls and send texts to consumers to offer their services

and convince student loan borrowers to sign up for Defendantsrsquo debt relief

services

11

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 12 of 57 Page ID

1

2

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4

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28

1771

27 In calls with consumers Defendantsrsquo telemarketers have told

consumers that Defendants can cause consumersrsquo student loan balances to be

reduced or that consumersrsquo loan balances would be forgiven after making lower

monthly payments Defendantsrsquo telemarketers have told some consumers that over

half their loan balance would be forgiven Moreover Defendantsrsquo telemarketers

have told some consumers that their loan payments could or would be rapidly

reduced to $19 per month or promptly forgiven

28 Defendants have made other representations concerning loan

reduction or forgiveness to consumers in telemarketing their debt relief services

For example Defendantsrsquo telemarketers have told one or more consumers that

ldquofamily sizerdquo a metric for determining the amount borrowers pay each month

under IDR plans includes ldquoanyone you help out throughout the year[] they donrsquot

have to live with yourdquo even claiming that helping with ldquogas money three times

out of the yearrdquo is enough to include a person in ldquofamily sizerdquo Further

Defendantsrsquo telemarketers have offered one or more consumers ldquobasically a

guarantee to remainrdquo in an IDR plan and warned one or more consumers that

signing up for an IDR plan with a lender instead would result in a higher loan

payment

29 Defendants have not been likely to achieve the lower monthly

payments or student loan forgiveness they have advertised marketed and

promoted to consumers In many instances Defendants have failed to obtain the

promised lower monthly payments or student loan forgiveness

30 Defendants have charged consumers fees for purported debt relief

services before achieving lower monthly payments or student loan forgiveness

and in many instances have failed to achieve those results at all on behalf of

consumers

12

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 13 of 57 Page ID

1

2

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22

23

24

25

26

27

28

1772

31 Defendantsrsquo telemarketers have sought and obtained consumersrsquo

payment information by phone or the Internet

32 Defendantsrsquo total advance fees typically have been in the range of

$300-500 Defendants also have charged consumers recurring monthly fees for

purported debt relief services typically charging $19 per month

THE FTC ACT

33 Section 5(a) of the FTC Act 15 USC sect 45(a) prohibits ldquounfair or

deceptive acts or practices in or affecting commercerdquo

34 Misrepresentations or deceptive omissions of material fact constitute

deceptive acts or practices prohibited by Section 5(a) of the FTC Act

VIOLATIONS OF THE FTC ACT

Count One

(Deceptive Student Loan Debt Relief Representations)

35 In numerous instances in connection with the advertising marketing

promotion offering for sale or sale of student loan debt relief services Defendants

have represented directly or indirectly expressly or by implication that consumers

who purchase Defendantsrsquo debt relief services will or likely will have their

monthly payments reduced or their loan balances forgiven in whole or in part

36 In truth and in fact in numerous instances in which Defendants have

made the representations set forth in Paragraph 35 of this Complaint such

representations were false or not substantiated at the time Defendants made them

37 Therefore Defendantsrsquo representations as set forth in Paragraph 35 of

this Complaint are false or misleading and constitute deceptive acts or practices in

violation of Section 5(a) of the FTC Act 15 USC sect 45(a)

THE TELEMARKETING SALES RULE

38 Congress directed the FTC to prescribe rules prohibiting abusive and

deceptive telemarketing acts or practices pursuant to the Telemarketing Act 15

13

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 14 of 57 Page ID

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24

25

26

27

28

1773

USC sectsect 6101-6108 in 1994 The FTC adopted the original TSR in 1995

extensively amended it in 2003 and amended certain sections thereafter 16

CFR Part 310

39 Defendants are ldquoseller[s]rdquo or ldquotelemarketer[s]rdquo engaged in

ldquotelemarketingrdquo as defined by the TSR 16 CFR sect 3102(dd) (ff) and (gg) A

ldquosellerrdquo means any person who in connection with a telemarketing transaction

provides offers to provide or arranges for others to provide goods or services to a

customer in exchange for consideration 16 CFR sect 3102(dd) A ldquotelemarketerrdquo

means any person who in connection with telemarketing initiates or receives

telephone calls to or from a customer or donor 16 CFR sect 3102(ff)

ldquoTelemarketingrdquo means a plan program or campaign which is conducted to

induce the purchase of goods or services or a charitable contribution by use of one

or more telephones and which involves more than one interstate telephone call 16

CFR sect 3102(gg)

40 Defendants are sellers or telemarketers of ldquodebt relief servicesrdquo as

defined by the TSR 16 CFR sect 3102(o) Under the TSR a ldquodebt relief servicerdquo

means any program or service represented directly or by implication to

renegotiate settle or in any way alter the terms of payment or other terms of the

debt between a person and one or more unsecured creditors or debt collectors

including but not limited to a reduction in the balance interest rate or fees owed

by a person to an unsecured creditor or debt collector 16 CFR sect 3102(o)

41 The TSR prohibits sellers and telemarketers from requesting or

receiving payment of any fees or consideration for any debt relief service until and

unless

a The seller or telemarketer has renegotiated settled reduced or

otherwise altered the terms of at least one debt pursuant to a

14

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 15 of 57 Page ID

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

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21

22

23

24

25

26

27

28

1774

settlement agreement debt management plan or other such

valid contractual agreement executed by the customer and

b The customer has made at least one payment pursuant to that

settlement agreement debt management plan or other valid

contractual agreement between the customer and the creditor

and

c To the extent that debts enrolled in a service are renegotiated

settled reduced or otherwise altered individually the fee or

consideration either

i Bears the same proportional relationship to the total fee

for renegotiating settling reducing or altering the terms

of the entire debt balance as the individual debt amount

bears to the entire debt amount The individual debt

amount and the entire debt amount are those owed at the

time the debt was enrolled in the service or

ii Is a percentage of the amount saved as a result of the

renegotiation settlement reduction or alteration The

percentage charged cannot change from one individual

debt to another The amount saved is the difference

between the amount owed at the time the debt was

enrolled in the service and the amount actually paid to

satisfy the debt 16 CFR sect 3104(a)(5)(i)

42 The TSR prohibits sellers and telemarketers from misrepresenting

directly or by implication any material aspect of any debt relief service including

but not limited to the amount of money or the percentage of the debt amount that a

customer may save by using the service 16 CFR sect 3103(a)(2)(x)

15

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 16 of 57 Page ID

1

2

3

4

5

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12

13

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16

17

18

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22

23

24

25

26

27

28

1775

43 Pursuant to Section 3(c) of the Telemarketing Act 15 USC

sect 6102(c) and Section 18(d)(3) of the FTC Act 15 USC sect 57a(d)(3) a violation

of the TSR constitutes an unfair or deceptive act or practice in or affecting

commerce in violation of Section 5(a) of the FTC Act 15 USC sect 45(a)

VIOLATIONS OF THE TELEMARKETING SALES RULE

Count Two

(Advance Fee for Debt Relief Services)

44 In numerous instances in connection with the telemarketing of

student loan debt relief services Defendants have requested or received payment

of a fee or consideration for debt relief services before

a Defendants have renegotiated settled reduced or otherwise

altered the terms of at least one debt pursuant to a settlement

agreement debt management plan or other such valid contractual

agreement executed by the customer and

b The customer has made at least one payment pursuant to that

settlement agreement debt management plan or other valid

contractual agreement between the customer and the creditor

45 Defendantsrsquo acts or practices as described in Paragraph 44 of this

Complaint are abusive telemarketing acts or practices that violate Section

3104(a)(5)(i) of the TSR 16 CFR sect 3104(a)(5)(i)

Count Three

(Material Debt Relief Misrepresentations)

46 In numerous instances in connection with the telemarketing of

student loan debt relief services Defendants have misrepresented directly or

indirectly expressly or by implication material aspects of their debt relief services

including but not limited to that consumers who purchase Defendantsrsquo debt relief

services will or likely will have their monthly payments reduced or their loan

16

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 17 of 57 Page ID

1

2

3

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5

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27

28

1776

balances forgiven in whole or in part

47 Defendantsrsquo acts and practices as described in Paragraph 46 of this

Complaint are deceptive telemarketing acts or practices that violate Section

3103(a)(2)(x) of the TSR 16 CFR sect 3103(a)(2)(x)

Count Four

(Disgorgement of Ill-Gotten Gains of Relief Defendant)

48 Relief Defendant Noel has received directly or indirectly funds or

other assets from Defendants that are traceable to funds obtained from Defendantsrsquo

customers through the unlawful acts or practices described herein

49 Relief Defendant Noel has no legitimate claim to Defendantsrsquo

customersrsquo funds or other assets and will be unjustly enriched if it is not required to

disgorge the assets or the value of benefits received as a result of Defendantsrsquo

unlawful acts or practices

50 By reason of the foregoing Relief Defendant Noel holds funds and

assets in constructive trust for the benefit of Defendantsrsquo customers

CONSUMER INJURY

51 Consumers have suffered and will continue to suffer substantial injury

as a result of Defendantsrsquo violations of the FTC Act and the TSR In addition

Defendants have been unjustly enriched as a result of their unlawful acts or

practices Absent injunctive relief by this Court Defendants are likely to continue

to injure consumers reap unjust enrichment and harm the public interest

THIS COURTrsquoS POWER TO GRANT RELIEF

52 Section 13(b) of the FTC Act 15 USC sect 53(b) empowers this Court

to grant injunctive and such other relief as the Court may deem appropriate to halt

and redress violations of any provision of law enforced by the FTC The Court in

the exercise of its equitable jurisdiction may award ancillary relief including

rescission or reformation of contracts restitution the refund of monies paid and

17

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 18 of 57 Page ID

1

2

3

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1777

the disgorgement of ill-gotten monies to prevent and remedy any violation of any

provision of law enforced by the FTC

53 Section 6(b) of the Telemarketing Act 15 USC sect 6105(b)

authorizes this Court to grant such relief as the Court finds necessary to redress

injury to consumers resulting from Defendantsrsquo violations of the TSR including

the rescission or reformation of contracts and the refund of money

PRAYER FOR RELIEF

Wherefore Plaintiff FTC pursuant to Section 13(b) of the FTC Act 15

USC sect 53(b) Section 6(b) of the Telemarketing Act 15 USC sect 6105(b) and

the Courtrsquos own equitable powers requests that the Court

A Award Plaintiff such preliminary injunctive and ancillary relief as

may be necessary to avert the likelihood of consumer injury during

the pendency of this action and to preserve the possibility of effective

final relief including but not limited to temporary and preliminary

injunctions orders freezing assets immediate access to business

premises appointment of a receiver and expedited discovery

B Enter a permanent injunction to prevent future violations of the FTC

Act and the TSR

C Award such relief as the Court finds necessary to redress injury to

consumers resulting from Defendantsrsquo violations of the FTC Act and

the TSR including but not limited to rescission or reformation of

contracts restitution the refund of monies paid and the disgorgement

of ill-gotten monies

D Enter an order requiring Relief Defendant to disgorge all funds and

assets or the value of the benefit it received from the funds and assets

which are traceable to funds obtained from Defendantsrsquo customers

through the unlawful acts or practices described herein and

18

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 19 of 57 Page ID 1778

2

3

E Award Plaintiff the costs of bringing this action as well as such other

and additional relief as the Court may determine to be just and proper

Dated February 5 2019

Respectfully submitted

ALDEN F ABBOTT General Counsel

JosaSMillard Brian M Welke middot Barbara Chun (Local Counsel) Attorneys for Plaintiff FEDERAL TRADE COMMISSION

4

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19

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 20 of 57 Page ID 1779

EXHIBIT A

Attachment A

Free Assessment

Our expercs will lt1ssPss you cun ent

swclent lo n program and decermn which progr ms are

avc11l bl rn yoL11 situation We wi I help you cl11cic1e which progr m r1

help you achieve your goals Call us today

Service Guarantee We are commmecl to 11-1 111g

CllStomers get low r rc1ces ancl monthly payments and we w1I

m ke the pror~ss se mless and s r11ghtforwc1rd ou wi ll be sansf1ed

with our service ml OLlr

cornmcmem to you success Thars ow gu~ ancee

Success Rate Ou1 96 ~ surcPss r a e s 11e of he

cop I a ings tn he industry Olr

process has beer tested nd Olli

succ ss r r~ prowbull~ tn t it works

We c n ll~lp yo reduce and -1111ph y our p ~ymP1 ts Call us today

FTC-AID-1

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 21 of 57 Page ID 1780

20

Exhibit A

ABOUT US

We can help you reduce and simplify your pay1ncnts Contact one of our specialists today for

a free evaluation

111middot 1_I 1

101

t I 11111 I I

Itbull 11

Ill fl I I

bull ~ 0 I

What Makes Us Great fa1(li1-_~ tur1ent ~e11ef 11as a taf- o~middot tt a middotel elt1)rns bullJn st1ncb110

1middot1ep yriJ Tibullmiddotest fi 1e-ndly f3ce~ 113ve eirej e1tc-nsve1yr =inj ire

fanih1~1 bull11iu1 ti~e nul~nce~ cfscrvern rrent Cdid p11vate stucre11

l1J1ns Th~y viill u~e Ui5 epe tise o loik jUl fJ ycur ~Je~t

i(tres~- f)LH ~U(CtS~ ~HE 1h-~ I lSllt of i_r middotDff ancl iur

C ur ~r_(J~l 1o~w- JCl11~crs f(middotil) 3 00Vtli ~tJegy o r ~dUC2 011i

a1r1plfy yliur- - _Je1middott middotcar payr1t11s 1) Asstrnlins Itle ~atl1t1

2) R~~ear c1-1ng Our st~lff wmiddoti11 (lrJUi~oleaerick ]ll fnfcnTnati(-n befort dtmiddoteJPlr~ t tne ri~n 3) rnnk1middotgbullle i_i1 i e~ear (rr i~ ormiddot1 1 1 etc 1Ne

irvi-s t1ga~ii 111 ps~ib le a~irst 1n(t aptlbull~n 4) 1Nr1 ting VVF p1 eiv lii J 11 iUen u tt-igy IJefore vie Uke ut1c-1l i)ecius~ you d-ese11e 11) undi r~~anci

Lhe pr 1cer S) ~ev1sing Al)ng ~r 1udent Relief 1- 1otT11111tt bull) ti) ci e1H1ve ut-l-~n~-l)O c111 i ri 3 Vbulle -~11 leave n1) sti bull1e u11t111 neltl tecause middot~ve

11~1ve your be~ i1~ t~rest 1t l1ein 6) Si~tcl11ng Our note- =1nd r~c)1 ~ ~1 e thorou~ll ln(I pru1ile 1 ceJ1 po cri1~ 1)f vo111 ~1tuJticn s) iny if-oi

~xpe1 t- 01 eou pped to s~1ty1J_J bullVi r you1 c si- 7) De-gn1ng _ fe ~1 t 1nelt--1- f1ts ti 1middotV 1middotid de~ 1middot1 1 st1 iegy to fit ou 1 1_i dque jtct1in so

011 c111 i Jle y1)u1 1vv1middot1 per feet -ut1e-s ~~0 1 v

1bullVlly 1100~e At(J1n~ Sltl(ltnt Fie11e7) (i1_d aclol~Or~ bull -ii~ (1Ualiftel lci ~~~ISt~h 1noie ype-s middotif JS~iSi_ance u~211 Cd ( (11)itXS i1 jG(l1~t) to ti-tgt

p ~n~ 1not con1p n1es can 11i1p bullbullllh ve )t ~ ~qu1pptCI to bull-bullGr k 1bullv1t1middot1 r~ 11t-2 [uo emiddot 1 lc1 r1s ~~nCI cn even iner-1ne frmiddot tt1e c ~e of 1l~e

~1lt ntslmiddoturelt A1cl1rg Sudent Fie1ef 1middot cis mmiddote to )fe 11d we offe1 t with middotmiddot1eltbullbe 1es nI 3 rncney lock guMai-itee

We Have Been Featured In

FTC-AID-2

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 22 of 57 Page ID 1781

21

Exhibit A

SERVICES Wt w gtL

Loan Forgiveness Income Based Payments Loan Consol idation In some cases individuals with A period of financial hardship may You may be able to combine

Fede1middota1 Student Loans may qualify qualify you for an Income Based nultiple federal student loans into to have a portion of the amount Repayment Plan In many cases this one new loan w ith a lower more

owed may be forgiven This means means you pay nothing Unlike a affordable monthly payment Loan

your principal balnce coulcl be defe1 ment the term on your loan consolidation prngrams can l1elp

significantly reduced and you will continues to reduce while the plan is you qualify for additional programs not be expected to repay the in place Your term could reduce like loan forgiveness programs or

forgiven amount while you pay nothing Public Setvice Loan Forgiveness

a III

Private Sector Loan Forgiveness

If you work for a government

organization at a city state or

federa l level you may qualify for tle

PL1blic Service Loan Forgiveness

program To qualify your loans

must be cotisolidated into a specific

repayment plan The balance on

your federai student loans is

forgiven after 120 qualifying

bull C Permanent Disability

Forgivenness If your disability is expected to last

60 months or more you may qualify

for permanent disability forgiveness

Q1alifying for Permnent Disability

Forgiveness requires a visi t to your

doctor and individL1als enrolled in

the program are subject to three

years of post-discharge monitoring

Wage Garnishment Prevention

Federal law requires that the

Department of Education or a

gua1middotanty agency notify you before

111st1tuting wage garnishment You

have tl1e right to a hearing where

you can challenge the stated

amount owed and negotiate the

terms of the repayment scheclule

We can intervene on YOL1PflJl~1D-3

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 23 of 57 Page ID 1782

22

Exhibit A

payments have been made p1middotevent wage gampnishments

A FEW STATISTICS ABOUT STUDENT LOAN CRISIS

12 Trillion National Student Debt I he nitionil student loin debt is

now 17 trillion dollirs 1 trillion of

these are in federil student loans

Let us help you through this national

crisis Cill today for a free

evaluation

40 Million Students with Debt

In 7014 an estimated 40 million

current and former students were in

debt because of student loans If

you are one of the millions of people

struggling to pay student loans

Aiding Student Relief is here to help

$33000 Average Student Debt

The graduating class of 7014

average $33000 of student loan

debt per person Thats $3000 more

than the average in 2013 Dont be

one of the many Let Aiding Student

Relief advocate for you

Aiding Student Relief has helped cmrnllcss 1woplc reduce their student debt_ Their proven business

plan has led lo one of lhc highest s11cclSS raCs in the inltl11slly

John Standiford Associated

FTC-AID-4

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 24 of 57 Page ID 1783

23

Exhibit A

TESTIMONIALS

Til~nks to Aiding Student Rel ief Im middotI middotva ove1vvhelrnecl but Aiding The expemiddotts at l1icl i11g Student Rel ief

s1v ing $250 per month Strrd r~rt Relief expl~ inecl the were ther~ to help me when I process ancl rnacle everytl1ing cle11middot nelclecl 1t rw)s t

and sirnple

I Michael Ma 1in

Entrep e11eu1 Em iiy Jallo1 Ii Pa ul Ch is tia I1se11

Teacher Nurse

With so many programs I didnt middotconso lrclating my loans into one I love my Job but vith my high

know what was ng ht for me My monthly payment hs made life student loan payment was still

sruclent loan aclvsor walked me si1nple1 Now I can focus on 1Nhn bamiddotely getting by I don t kn ow what I

through my optio ns rnd now Imiddotn matters to me would hwe clone wthout Aiding

saving 54 I 11n1omh Stucie1middott Rel refmiddot

Ariel Hemiquez Sales co)SUltant

Stephani Seland-1 Small Busim~ss Owner

AJ 01en Museum Curator

RECENT NEWS

)lt)

o(l ttDrlTI -5

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 25 of 57 Page ID 1784

24

Exhibit A

Student Debt Crisis Business Latest Debt Collective Demands May be largely about smallest Student

borrnwers US News amp World Loan Crisis is fa frorn ove The Debt Collective is a group of Report-May 162015 last month Two new reports suggest the college students calling the Fedemiddotal Reserve Bank of New student loan crisis is easing them-se1ves the Corinthian York repor ced that stuclent loan somewhat as the economy Fifteen who are refusing to pay balances rose to 16 trillio n and improves but the crisis is far back their student loins As pa t that 113 per cent of that is in from ove the College Board of this effort the Debt Collective repo t~ tot31 borrowing fell by 8 has written an open lette to the pEbull1 cent between 2012-13 and Department of Education f l llJ 20 13-14 The organization

About Us 11 1 i~d1middot1r F th~~- h1~ ff t1middot~11middot=cl =i~=middott- 1middot __31middotmiddotIIgt middot bullmiddot11

middot- I ( )ntir il t l~i -r_il fr~~

Address bull middot tc1ltj-1r_ =i ~

middot l t1~t 1middot1 fcJ middot~_1 1 I l11 - Hbull 1 tr

~t (~~ 1 12bull~11 T 1 1- - 8555105400

FTC-AID-6

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 26 of 57 Page ID 1785

25

Exhibit A

f - g+ in O) ~ PRIVACY POLICY

This privacy statement discloses the privacy practices for AidllII Student Relief Because Aiding Studen Relief wonts to demonstrate ts firm commlcmell to your

privacy Aiding Sudent Relief hes greed to disclose ls 1rifor111atlori g1thering and dlssem1n1t1on prct1cts Aidlns Studtrit Relief will notify you of

INFORMATION COLLECTION At-ID USE

Aiding Student Relief is the sole owner of the rformMlon collected on this site We will not sell shire or rent this information 10 others In way different from what Is

disclosed 1n this statement Aldln1 StudeM Relief collects 1nform111on throuah this site from our prospective end existing clients at several different poin on our web

site We use their contact Informii on to send information bout our company and to service exsMs accounts Users may optbullout of rece11ns future malllngs see the

cholceoptbullout section below Contect and Financial information that 1s collected Is used for verifying your name address and other informa1on as well as to boll you for

your use of our Gerv1ces using Information from third party sourcH Information about your computer hardwre and software Is automatically collected by Aiding

Student Relief and may be shared in asgregate with third parties whose services are used for traffic analysis purposes This Ir formation includes your IP address

browser type domain names access times and referring Web site addresses Ths information is no tied to personally Identifiable Information This 1nformatlor s used

by Aiding Student Relief to malMan no Improve the quality of the Hrvct and to senerae statistics resardlng use of he Aiding Student Relief site We use third party

services to bill for serlces and to provide other services like our Live Help chat We store the transcripts from these chats for customer service Improvement These

third party service providers are not permitted to use your infornon for any secondary purposes

Thank you and cheers

FTC-AID-7

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 27 of 57 Page ID 1786

26

Exhibit A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 28 of 57 Page ID 1787

EXHIBIT B

Attachment A

((

z | ~

AIDINGSTUDENTRELIEF

bull bull bull bull bull

13 deg $ $ampdegdeg deg() ˝ amp $$deg( + -+Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 29 of 57 Page ID 1788

bulldaggerDagger Daggermdashndash Daggerhellip ƒfrasl hellip lsaquorsaquobullminuspermilminushellip bdquolsaquoldquo rsaquordquobulllsquo fraslbullrsquopermillsaquofraslpermilminushellip sbquo

4556789fADlt=gtA9BCAD

DZgtA=EFGHIJFKLMNOPFQOGFHIQRSTLKSUMMNOPLHMTFIVRWXHKKNIFNUNOPRLFGSHKSRVRVNQ

f e=klHMW

9SI]UQMSNSOQOHHPFK YaSTHHVVJFMHcVGNOJVHHFKKPSUHMLIUOQN_PL[KSVFGJPRSDTHRFPLIP=SNDC==GFdFIP9VaNHQTWSRPbHF_PSKSVNMPMHNIO XNNIIFRKNF7IKSQQMHFNDVPOS9IAeTHPdKSUMMFNKHONP 8aF_KSNVPHTNIMNR[POVFgNPTHLNHIgtMFI YTFHIdFFI D9aHVR_KNKHFHIWIQOTHIQbFFP

lt=Dkgt=L]oHUKMMH ihTFNIORI THHVPRFMVKgtNJ_NFFbIVSJI]IFjdGGVNNN lt=TFKPPNF 9DaFGmVHPGRJMFNNQOSGnPFFTNLUNHPMIMTFVNJOKMIWV

27

]UMNOHPFRKNVSHKKISIRWRrGZNJONgtNjTHKHMI=cQgtORHVPKSOUMddUNKSPIdspNVPNq_ lt=gtBTHFHPb=HFILGFHMt DTFuFIUVFRPNTFIMINVWOPRVOQFIV sFQFPHKKH vaIPNFVcSyOFSPRFMRNVOJH_gtVFDVUJAN9FPwFuVFJLFHMP_VTFFdSIIVdNHUPxI=DQSROJGASHIVdDSNMINONPPaHdOHdPFHRIWVFFHdFIGM˙ 01 $2 301 $$3 ( Exhibit B

8

~ldquo

middot

676EBCEDK5ltAC]5EF_5665E7gt5lt7aFb688E588lt76B5E6F8EBAC78lt76cdddefghijhggklmknmopqprpopst u

13 deg $ $ampdegdeg degˇ amp $$deg + -+Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 30 of 57 Page ID 1789 () ( vPSZwPxyYTUZUWWzxPyxSWMZWPU|SWUWYZ~YTY~QSWbullYXRwU~UxSdaggerXQ~UZXvPSZWSOVQSYNOXPRSTUSDaggerPxXYPZPNXRUSPQZXPbullU~SOhellipUNPxyYTUZmdash zUxSZUZXndashYWShellipYYXOwPxyYTUZUWWMNOPQx~YWShellipYYXOYWUƒDaggerU|XU~XPSWXfrasllsaquoPZXRWPxPxUOPQSOVQSYNONPxDaggerUxSZUZX~YWShellipYYXONPxyYTUZUWWmdash

rsaquominus MZ|PUpermilSWUzSOUZXWbdquoDaggerUxYP~PNZSZ|YSRSx~WRYDaggerSOVQSYNOOPQNPxSZMZ|PUpermilSWU~rdquoUDaggerSOUZXzSZmdashMZSZO|SWUWXRYWUSZWOPQDaggerSOZPXRYZymdash zQhellipY|daggerUxTY|UvPSZwPxyYTUZUWWMNOPQbullPxlsquoNPxSyPTUxZUZXPxySZYrsquoSXYPZSXS|YXOWXSXUPxNU~UxSUTUOPQSOVQSYNONPxXRUzQhellipY|daggerUxTY|UvPSZwPxyYTUZUWWDaggerxPyxSmdashsbquotrade f8Ef8E78FCB6C8EŁPQSOhellipUShellipUXP|PhellipYZUQXYDaggerUNU~UxSWXQ~UZXPSZWYZXPPZUZUbullPSZbullYXRSPbullUxPxUSŒPx~ShellipUPZXRODaggerSOUZXmdashvPSZ|PZWPY~SXYPZDaggerxPyxSW|SZRUDaggerOPQVQSYNONPxS~~YXYPZSDaggerxPyxSW YlsquoU PSZ NPxyYTUZUWWDaggerxPyxSWPxzQhellipY|daggerUxTY|UvPSZwPxyYTUZUWWmdash ŠmŸŽıłŠm 57gt8A57A5B= 8E65C76B5E6F8EB5=6G

PONM[5 QRSTUVQU PYXWZW lt4556789588lt959=lt CD lt H5FICEDJ8KA5LCD

A565E7gt57 œšžeuroiexclcentpoundyenbrvbarsectbrvbareurocopypoundsectlaquoeuropoundlaquobrvbarlaquoregplusmncentbrvbareurocent microparalaquo europoundž raquoY|frac14frac12 plusmncurrenRSUraquoSxXYZeuropoundlaquo laquoeurolaquoordf frac34

^ ˙ ( (

28

Attachment A

01 $2 301 $$3 ( Exhibit B

()(

=4ABC9DEAFBD=FGFHIJKLMJNOMN MRNS mn = nrst = svzhellipu t bulltvDaggerrhellipDaggerurbullbulltuhellipv hellipz~ bullmdashldquordquolsquorsquotrade š oŒŠeuro centpound ` umluml 13 deg $ $ampdegdeg degˇ amp $$deg + -+Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 31 of 57 Page ID 1790

ISNRTUKQINKKNNKL[MRJ PUWQI]MRM qyt|tytzxy rsaquoqNfraslbdquoPUhellipsbquoLUyQhellip rfraslbhellipMNSIKVUQ QNJKvUQsMiexclQQJUx[iexcliexcl_vsect_Qyenyenbrvbarbrvbar uSSRNTPL_LUUMKIaJ_WMIJJKVIONNQJJMWRMIIbQQURKLWIIJQbKLUNKMPTMNQQ_KKRY tbullbulldaggersDaggerv~vhellipmdashryrhellip~mdashrhellipDagger ŸLŽUıQŽbłpermilMtradeœsbquoNtrade_ffRŁyISMŒUQWyNUQŠlsaquo rv45657896lt7ltgt5lt PQKLMIQSNRTUKINQVNOOMVKMWNQKLIJPMXJIKMYZMPIOO NJMOOJLURMNRRMKKLIJ klltko ltgtlt85p5gt5 ouvwxrz ^^ ~ minuspermil tffŁ yenpoundpound KNOWDaggerIreggt4lt97ltndash9ƒ Dagger hellipDaggerlsaquo žko74k57ƒ ƒISNcurrenUIWIbJKWMKJYVNTKM KLONNRqIQQSNNRTUKINQQIJ_JMWNQKLIJJJPMXJIKMcOMUJMVNQKUVK_JUKBHdefABCgDEAFBDghidjlaquopoundbrvbariexclnotvIWIQbDaggerK_WMQKbullMOIMSvOObullIbLKJbullMJMRMW ordf copy

01( $2(301$$3( Exhibit B

29

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 32 of 57 Page ID 1791

EXHIBIT C

Attachment A

~ 111 ~tampi 10 11 ~bull ia1111

Something awesome is coming soon We are buildin somethin ve cool Sta tuned and be at1ent Your atience will be well aid

~lbullrbullUiUffl We can help you reduce and simplify your payments

101 Loan For iveness

1~u 0 (middottmiddotbullmiddotmiddot1 1~=I -- _~

HZamp IMUliULlampRampatiEUWi nmiddot middot-il~ fr middot 8rbullbullrcrr-

_J l _ 1 _f _ur -~t~ u L liYu

~ Income Based Pa ents

bull ~ f I - - I - I - ri u ~u-=lf ~ JU

1-bullA ---rc iM1~~ -~-bullCiel rrcl

~- middot IY 2 i C middot middotJ ll1Jmiddot 0 _ middot_middotIr i

~ LdfiJIMifJ11JJMJllfFffi

middotE-ltecl l2bullJbull iequbullt t11cit t1lt2 CtpCr~middot1e- f

JJd r g-_iraE-1 agltr-middot- ntimiddot middot)middotou

tmiddot_rt- i ic l~1ri ~rbullmiddot middot111~ umiddot -_ d_t-c

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I f-nle Vnot Nune

I ampterYOllrEmall ]

1 ~~~~ 1

If -bull 13n ~Cbull t~middot rct1~j d- gtOY- - hO- irmiddot (bulldbull) plltmiddotmiddot- leemiddotmiddot JOu

1r1cbullmiddotn111f11ri ll1fbull fcrn to ~bull~I

Triin- GU

WAWMyenEIRitiRpoundWt 44 ZiAtillampampI

Exhibit C

Case 818-cv-01987-JLS

-KE

S

Docum

ent 50-1 F

iled 020519 P

age 33 of 57 P

age ID 1792

30

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 34 of 57 Page ID 1793

EXHIBIT D

Attachment A

bull bull bull bull bull bull bull

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Type then hit enter to

bull bull bull bull bull bull bull

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Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 35 of 57 Page ID 1794

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

infoaidnestcom (800) 555-1212

HOME

ABOUT US

SERVICES

FAQ

BLOG

CONTACT

HOME ABOUT US SERVICES FAQ BLOG CONTACT

1 of 6 462018 945 AM

31

Student Loan Forgiveness Loan Consolidation Student Loan Forgiveness

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 36 of 57 Page ID 1795

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

If you have Federal Student Loans yoursquore in the right place to get those loans reduced forgiven or completely discharged through our student loan forgiveness programs

Get your multiple Federal Student Loans consolidated into one forget about increasing interests and pay month to month at the lowest possible cost

We understand if yoursquore going through some hardship and thatrsquos why with us yoursquoll be able to make monthly payments based on your affordability for as low as $000 depending on your situation

2 of 6 462018 945 AM

32

Knowledge Base

Defaulted Student Loans

Wage Garnishment

Student Loan Rehabilitation

Income Based Repayment Plan

Deferment and Forbearance

Pay As You Earn Repayment Plan

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE Call 561)424-6053 today to go over your options

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 37 of 57 Page ID 1796

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

Our knowledge base is designed to provide information regarding some of the critical topics those with student loans must be aware of to be able to make educated decisions regarding their future

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

A wage garnishment is any legal procedure in which some portion of a personrsquos earnings is required to be withheld by an employer for the payment of a debt

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

With this program your payments change as your income changes and will not be longer than 25 years This is the ideal plan if you are in partial financial hardship Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard plan

Temporarily allowing you to postpone or reduce your federal student loan payments Postponing or reducing your payments may help you avoid default and future garnishments

Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard

3 of 6 462018 945 AM

33

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 38 of 57 Page ID 1797

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

4 of 6 462018 945 AM

34Attachment A

Testimonials

Latest News

Why 2016 Will Be a Big Year For Student Loans

Top Student Loan Refinancing Questions of 2015

Oba mas latest student loan plan

Things You Should Know About Public Service Loan Forgiveness

Recent Posts

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 39 of 57 Page ID 1798

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

5 of 6 462018 945 AM

35

About Us

Contact Info

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 40 of 57 Page ID 1799

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

pay-grandchild-studen

Why 2016 Will Be a Big Year For Student Loans

December 30 2015

12511110_1112367518

Top Student Loan Refinancing Questions of 2015

December 30 2015

We stand by our consultation and quote We are so sure and confident about our services and offers that they are all 100 money back guarantee risk free ndash if we donrsquot do what we promise yoursquoll get your money back

(800) 555-1212 AidnestStudenLoansgmailcom 18100 Von Karman Ave Suite 850 Irvine CA 92612

Futero SAS copy 2015 | Aidnestcom

6 of 6 462018 945

Exhibit D 36Attachment A

AM

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 41 of 57 Page ID 1800

EXHIBIT E

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 42 of 57 Page ID 1801

AIDNEST Let us help you through this national crisis

Call one of our specialists today

Forbearance amp Deferment If you are still in school and struggling to make payments on your student loans You may qualify

for Forbearance amp Deferment

Garnishment Prevention Federal law requires that the Department of Education or guarantee agency notifies you before they

begin garnishing your wages

Loan Forgiveness If you are a teacher public service worker or an individual with total and permanent disability you

httpaidnestcom[442018 115239 AM]

37Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 43 of 57 Page ID 1802

AIDNEST Let us help you through this national crisis

may qualify for this program

Consolidating Your Loans Consolidating your loans to one new loan under one lender may lower your payments and make

your life a bit more manageable

Affordable Payments If you are looking to lower your monthly payments then Income Based Repayment Plans may be

the correct choice for you

Learn more about our services

LEARN MORE

httpaidnestcom[442018 115239 AM]

38Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 44 of 57 Page ID 1803

AIDNEST Let us help you through this national crisis

Loan Forgiveness Programs Income Based Payments Student Loan Rehabilitation

Student Loan Consolidation

You may be eligible for

Loan Forgiveness Programs

In some cases individuals with Federal Student Loans may qualify to have a portion of the amount

owed to be forgiven

Get in touch with our professional team to find out which loan forgiveness program you qualify for and

how you can get rid of your unpaid student loan

L EARN MORE

httpaidnestcom[442018 115239 AM]

39Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 45 of 57 Page ID 1804

AIDNEST Let us help you through this national crisis

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE

Meet your Budget One of our advisers will help you meet your payment goals by using your budget and timeline to

determine the best plan available

httpaidnestcom[442018 115239 AM]

40Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 46 of 57 Page ID 1805

AIDNEST Let us help you through this national crisis

Simple Process We understand that lowering your payments alone can be difficult Our intuitive platform allows us

to keep the entire process simple

Customer Satisfaction We are committed to providing you with outstanding service only We look forward to working

with you

100 money back guarantee No Hassle Money Back Policy

httpaidnestcom[442018 115239 AM]

41Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 47 of 57 Page ID 1806

AIDNEST Let us help you through this national crisis

Lower your loan payments by getting in touch with one of our professionals

We design a customized repayment plan that will allow you to make payments based on your

monthly income family size and spending Get rid of the hassle of extensive paperwork and get the

help you deserve

What we can help you achieve a lower payment or lower rate

httpaidnestcom[442018 115239 AM]

42Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 48 of 57 Page ID 1807

AIDNEST Let us help you through this national crisis

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcom[442018 115239 AM]

43Exhibit E

httpaidnestcomservices[442018 115322 AM]

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 49 of 57 Page ID 1808

Services | AIDNEST Let us help you through this national crisis

INCOME BASED PAYMENTS

If you are suffering from a financial hardship you may be eligible for an

Income Based Payment In this repayment program you would have a

payment based on your income and family size The payment could be as

low as $000 per month with forgiveness at the end of 20-25 years

44

Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 50 of 57 Page ID 1809

L E ARN MORE

LOAN FORGIVENESS

If you have Federal Student Loans you may qualify for any of the student

loan forgiveness programs that are available to borrowers You may be

eligible for principal reduction loan forgiveness or a complete loan

discharge depending on your individual circumstance

L EARN MORE

PRIVATE STUDENT LOAN CONSOLIDATION

Much like refinancing a mortgage generally the biggest benefit of private

student loan consolidationstudent loan refinancing is a lower interest rate

httpaidnestcomservices[442018 115322 AM]

45Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 51 of 57 Page ID 1810

L E ARN MORE

(something federal consolidations do not offer)

STUDENT LOAN REHABILITATION

You can renew eligibility for new loans and grants and eliminate the loan

default by ldquorehabilitatingrdquo a defaulted loan

httpaidnestcomservices[442018 115322 AM]

46Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 52 of 57 Page ID 1811

CHE CK E L E G I B I L I T Y

WAGE GARNISHMENT

A wage garnishment is any legal procedure in which some portion of a

personrsquos earnings is required to be withheld by an employer for the

payment of a debt

L EARN MORE

With our fast friendly and professional services wersquoll be glad to help you get your student loans

reduced forgiven or completely discharged To this end wersquoll assist you in consolidating all your

student loans so yoursquoll have only one lender and yoursquoll start making one monthly payment Our

professionals will walk you through the best and most flexible repayment options and if itrsquos also

necessary varied deferment options and rehabilitation programs

httpaidnestcomservices[442018 115322 AM]

47Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 53 of 57 Page ID 1812

Services | AIDNEST Let us help you through this national crisis

Our CRM System

Our CRM is one of the most advanced in the industry and most importantly itrsquos linked directly to

the Department of Education (DOE) This keeps your personal and most confidential information

safe Furthermore because our CRM system is linked to the DOE our approval is 100 Through

our CRM we will be doing continuous monitoring of our process without losing sight of your

immediate needs ensuring that your case has the proper handling and most efficient process

httpaidnestcomservices[442018 115322 AM]

48Exhibit E

n

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 54 of 57 Page ID 1813

Services | AIDNEST Let us help you through this national crisis

R ECENT POSTS

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

ABOUT US

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcomservices[442018 115322 AM]

49Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 55 of 57 Page ID 1814

EXHIBIT F

s -

bullmiddot - ~ t ~ower Your Student Loan Pay~e~ts oday -- Students Helping Students Save Money

INCOME BASED PAJIIIJITPAIS

I C(gttoUC1 u~

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 56 of 57 Page ID 1815

X + C (D Not secure wwwstudoracom 0

CALL US NOW (85S) 978-S599 middot 1nfostudoracom

HOME SERVICES ABOUT US FAQ CONTACT US BLOC PRIVACY

Offering obligation and commitment free loan relief solutions

STUDENT LOAN FORGIVENESS INCOME BASED PAYMENTS LOAN CONSOLIDATION

We11 help you get your loans reduced forgiven o r Make monthly pdyments based on your affordability Get multiple Federal Student Loans consolidated into

discharged one low monthly payment

Talk to our experts concerning your

student loans

Studora is a pnvatefy owned company that helps consumers like you identify

government programs that fit your financial s1tuat1on Our loan experts will assist you in selecting the appropriate programs that WOltk with your income family size and

desired monthly payment We then prepare the appropriate documents for your review and submission All this f o r one low easy payment

Testimonials

Thank you f o r getting back to me quickly Youve been fabulous Thank you for the confirmation and for your help today Pass

during this whole process Is there a place I can go online that I this on to your sup that you were very professional and very

can leave a comment for your manager Youve made this Robert helpful and brought a sense of relief for me Thank you very

process so easy and answered every question my husband and I much and have a great rest of your day Kudos to you and your

have had teammoneywell spenL

Exhibit F 50

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 57 of 57 Page ID 1816

Services we offer

Stud ora offers document preparation services for all loan forgiveness consolidation and relief services to people who are unable to manage their finances Our mam aim is to

offer complete peace of mind to indiVidual unable to pay their student loan debt

we otter the folloWing document preparation services with complete professional assistance

amFinancial Review ffl Budget Planning

Toe first step to creating a flexible loan repayment plan is financial review we also help create a personal finance plan to ensure that you are able to

Our professmnals will look into your finances and design a custom manage your monthly budget in the most effective way This plan will keep

repayment plan that is affordable and easy to manage your spending to the minimum alloWing you to save more money for loan

repayment

Permanent Disability Forgiveness r-trTeacher Loan Forgiveness (5 You can get rid of your Federal Student Loan if you are permanently disabled Good news for teachers who are under the weight of a massiVe loan You can

now get $17 forgiven on your student loans

Public Service Loan Forgiveness Custom Debt Relief Plans

Want assistance with debt relief Get in touch with our experts who will help If you are a public service agent you can get rid of your loan after 120 days of design a loan repayment and relief plan for you based on your monthly

income and affordability payments

THERE ARE NO OBLIGATIONS OR COMMITMENTS

want to save thousands of dollars Fill out our form and get relief from your student loan for a more

peaceful tomorrow

Your Name

BiHHHi

Exhibit F 51

Attachment A

Page 6: JOSHUA S. MILLARD, BRIAN M. WELKE, pro hac vice · for which it has no legitimate claim. Noel is a Wyoming limited liability company that reported in a public document that its principal

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 6 of 57 Page ID

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

1765

business in this district and throughout the United States

RELIEF DEFENDANT

13 Relief Defendant Noel Solutions LLC (ldquoNoelrdquo) has received funds

that can be traced directly to Defendantsrsquo deceptive acts or practices alleged below

for which it has no legitimate claim Noel is a Wyoming limited liability company

that reported in a public document that its principal place of business is 1623

Central Ave Suite 201 Cheyenne Wyoming 82001 Noel also incorporated as a

California limited liability company in January 2018 listing its address as 18997

Barroso St Rowland Heights California 91748 Noel transacts or has transacted

business in this district and in the district of Wyoming

COMMON ENTERPRISE

14 Defendants Impetus Fig Tree LLC and Capital Sun (ldquoCorporate

Defendantsrdquo) have operated as a common enterprise while engaging in the

unlawful acts and practices alleged below Defendants have conducted the

business practices described below through interrelated companies that have

common ownership officers managers business functions employees and office

locations and routinely transfer funds amongst themselves Because the Corporate

Defendants have operated as a common enterprise each is jointly and severally

liable for the acts and practices alleged below Defendants Duong Avitia-Pena

Colombana and Calderon have formulated directed controlled had the authority

to control or participated in the acts and practices of the Corporate Defendants that

constitute the common enterprise

COMMERCE

15 At all times material to this Complaint Defendants have maintained a

substantial course of trade in or affecting commerce as ldquocommercerdquo is defined in

Section 4 of the FTC Act 15 USC sect 44

6

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 7 of 57 Page ID

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

1766

DEFENDANTSrsquo UNLAWFUL STUDENT LOAN DEBT RELIEF

OPERATION

16 Since at least December 2014 through at least the filing of the FTCrsquos

Complaint in this matter in November 2018 Defendants have operated an unlawful

debt relief scheme that preys on consumers with student loan debt In telephone

calls on websites and in mailed advertising Defendants promise to reduce

consumersrsquo monthly student loan payments and eliminate all or a portion of their

student loan debt through enrollment in student loan forgiveness or repayment

programs In many instances however Defendants failed to obtain debt

forgiveness or monthly payment reductions In fact some consumers owed more

on their student loans after enrolling in Defendantsrsquo program

17 In exchange for the promised student loan debt relief services

Defendants have charged illegal upfront fees of $499 or more

Background on Student Loan Forgiveness and Repayment Programs

18 Student loan debt is the second largest class of consumer debt more

than 42 million Americans collectively owe nearly $15 trillion in student loan

debt The student loan market shows elevated levels of distress relative to other

types of consumer debt

19 To address this mounting level of distressed debt the US

Department of Education (ldquoUSDErdquo) and state government agencies administer a

limited number of student loan forgiveness and discharge programs Most

consumers however do not qualify for these programs because of strict eligibility

requirements For example one program requires the consumer to demonstrate a

total and permanent disability another applies only to consumers whose school

closed while the consumer was still enrolled A third program the Borrower

Defense to Repayment (ldquoBDRrdquo) may provide a loan discharge if the school

through an act or omission violated state law directly related to the borrowerrsquos

7

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 8 of 57 Page ID

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

1767

federal student loan or to the educational services for which the loan was provided

20 Other forgiveness programs require borrowers to work in certain

professions for a period of years For example Teacher Loan Forgiveness applies

to teachers who have worked full-time for five years in a low-income elementary

or secondary school or educational service agency Public Service Loan

Forgiveness (ldquoPSLFrdquo) applies to employees of governmental units or non-profit

organizations who make timely monthly payments for a period of ten years while

employed in the public sector

21 The federal government also offers loan forgiveness through income-

driven repayment (ldquoIDRrdquo) programs that enable borrowers to reduce their monthly

payments and have portions of their loans forgiven IDR programs allow eligible

borrowers to limit their monthly payments based on a percentage of their

discretionary monthly income To remain in an IDR program borrowers must

recertify their income and family size annually Obtaining forgiveness through

IDR programs requires a minimum of 20 or 25 years of qualifying payments

depending on whether borrowers received their first loans on July 1 2014 or

before that date Because a borrowerrsquos income is likely to fluctuate over the life of

the loan monthly payments under the IDR programs can vary considerably from

year to year If a borrowerrsquos income were to increase over the repayment period

for example the monthly payment amount could correspondingly increase to the

point where those payments would pay off the loan before any amount could be

forgiven at the end of the repayment term No loans have been forgiven yet under

any of the IDR programs because the programs have not existed long enough for

borrowers to make the minimum number of years of qualifying payments

22 Consumers can apply for BDR PSLF IDR and other loan repayment

and forgiveness or discharge programs through USDE or their student loan

servicers at no cost these programs do not require the assistance of a third-party

8

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 9 of 57 Page ID

1

2

3

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28

1768

company or payment of application fees

23 USDE will grant forbearance while processing applications for an

alternative repayment plan and in some cases of hardship During forbearance

unpaid interest is added to the principal balance

Defendantsrsquo Deceptive Marketing of Student Loan Debt Relief Services

24 To lure consumers into purchasing their purported student loan debt

relief services Defendants have made false promises to eliminate or reduce

consumersrsquo student loan balances or monthly payments through loan forgiveness

or other programs

25 To induce consumers to purchase their purported student loan debt

relief services Defendants have disseminated websites such as aidingstudentscom

aidnestcom and studoracom including but not necessarily limited to the

attached exhibits A through F Defendantsrsquo websites have contained the following

statements among others

Free Assessment

Our experts will assess your current student loan program and determine

which programs are available in your

situation We will help you decide which

program can help you achieve your goals Call

us today

Service Guarantee

We are committed to helping customers get

lower rates and monthly payments and we will

make the process seamless and

straightforward You will be satisfied with our

service and our commitment to your success Thatrsquos our

guarantee

Ex A at 1 (aidingstudentscom 2015)

9

Success Rate

Our 96 success rate is one of the top ratings in

the industry Our process has been tested and our

success rate proves that it works We can help you reduce and simplify your payments Call us today

Attachment A

----------

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 10 of 57 Page ID

1

2

3

4

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6

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22

23

24

25

26

27

28

1769

ldquoWe can help you reduce and simplify your payments Contact one of our specialists today for a free evaluationrdquo

Ex A at 2 (emphasis in original)

ldquolsquoAiding Student Relief has helped countless people reduce their student debt Their proven business plan has led to one of the highest success rates in the industryrsquordquo

Ex A at 4

100 Customer Satisfaction We can help you reduce and simplify your payments Call one of our specialists

today

Ex B at 1 (aidingstudentscom 2016) (emphasis in original)

Meet some of our members who have saved big on their student loan debt Helping You Save Big

ldquoThanks to Aiding Student Relief I am savings [sic] $250 per monthrdquo Michael Martin Entrepreneur

Ex B at 2 (emphasis in original)

ldquoWe can help you reduce and simplify your payments rdquo

Ex C at 1 (aidingstudentscom 2018) (emphasis in original)

Student Loan

Forgiveness

If you have Federal Student Loans yoursquore in the right place to get those

Loan Forgiveness

Get your multiple Federal Student Loans consolidated into one

10

Student Loan

Forgiveness

We understand if yoursquore going through some hardship and thatrsquos why

Attachment A

Case 818-cv-01987-JLS-KES

1

2

3

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5

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7

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28

Document 50-1 Filed 020519 Page 11 of 57 Page ID 1770

loans reduced forgiven or completely discharged through our student loan forgiveness programs

forget about increasing interests [sic] and pay month to month at the lowest possible cost

with us yoursquoll be able to make monthly payments based on your affordability for as low as $000 depending on your situation

Ex D at 2 (aidnestcom 2016)

Lower your loan payments by getting in touch with one of our professionals We design a customized repayment plan that will allow you to make payments based on your monthly income family size and spending Get rid of the hassle of extensive paperwork and get the help you deserve

What we can help you achieve [is] a lower payment or lower rate

Ex E at 6 (aidnestcom 2018) (emphasis in original)

STUDENT LOAN FORGIVENESS

Wersquoll help you get your loans reduced forgiven or

discharged

INCOME BASED PAYMENTS

Make monthly payments based on your affordability

LOAN CONSOLIDATION

Get multiple Federal Student Loans

consolidated into one low monthly payment

Ex F at 1 (studoracom 2018) (emphasis in original)

26 In some instances consumers view the Defendantsrsquo online advertising

and call Defendantsrsquo telemarketers for more information Defendants also make

outbound telemarketing calls and send texts to consumers to offer their services

and convince student loan borrowers to sign up for Defendantsrsquo debt relief

services

11

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 12 of 57 Page ID

1

2

3

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1771

27 In calls with consumers Defendantsrsquo telemarketers have told

consumers that Defendants can cause consumersrsquo student loan balances to be

reduced or that consumersrsquo loan balances would be forgiven after making lower

monthly payments Defendantsrsquo telemarketers have told some consumers that over

half their loan balance would be forgiven Moreover Defendantsrsquo telemarketers

have told some consumers that their loan payments could or would be rapidly

reduced to $19 per month or promptly forgiven

28 Defendants have made other representations concerning loan

reduction or forgiveness to consumers in telemarketing their debt relief services

For example Defendantsrsquo telemarketers have told one or more consumers that

ldquofamily sizerdquo a metric for determining the amount borrowers pay each month

under IDR plans includes ldquoanyone you help out throughout the year[] they donrsquot

have to live with yourdquo even claiming that helping with ldquogas money three times

out of the yearrdquo is enough to include a person in ldquofamily sizerdquo Further

Defendantsrsquo telemarketers have offered one or more consumers ldquobasically a

guarantee to remainrdquo in an IDR plan and warned one or more consumers that

signing up for an IDR plan with a lender instead would result in a higher loan

payment

29 Defendants have not been likely to achieve the lower monthly

payments or student loan forgiveness they have advertised marketed and

promoted to consumers In many instances Defendants have failed to obtain the

promised lower monthly payments or student loan forgiveness

30 Defendants have charged consumers fees for purported debt relief

services before achieving lower monthly payments or student loan forgiveness

and in many instances have failed to achieve those results at all on behalf of

consumers

12

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 13 of 57 Page ID

1

2

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22

23

24

25

26

27

28

1772

31 Defendantsrsquo telemarketers have sought and obtained consumersrsquo

payment information by phone or the Internet

32 Defendantsrsquo total advance fees typically have been in the range of

$300-500 Defendants also have charged consumers recurring monthly fees for

purported debt relief services typically charging $19 per month

THE FTC ACT

33 Section 5(a) of the FTC Act 15 USC sect 45(a) prohibits ldquounfair or

deceptive acts or practices in or affecting commercerdquo

34 Misrepresentations or deceptive omissions of material fact constitute

deceptive acts or practices prohibited by Section 5(a) of the FTC Act

VIOLATIONS OF THE FTC ACT

Count One

(Deceptive Student Loan Debt Relief Representations)

35 In numerous instances in connection with the advertising marketing

promotion offering for sale or sale of student loan debt relief services Defendants

have represented directly or indirectly expressly or by implication that consumers

who purchase Defendantsrsquo debt relief services will or likely will have their

monthly payments reduced or their loan balances forgiven in whole or in part

36 In truth and in fact in numerous instances in which Defendants have

made the representations set forth in Paragraph 35 of this Complaint such

representations were false or not substantiated at the time Defendants made them

37 Therefore Defendantsrsquo representations as set forth in Paragraph 35 of

this Complaint are false or misleading and constitute deceptive acts or practices in

violation of Section 5(a) of the FTC Act 15 USC sect 45(a)

THE TELEMARKETING SALES RULE

38 Congress directed the FTC to prescribe rules prohibiting abusive and

deceptive telemarketing acts or practices pursuant to the Telemarketing Act 15

13

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 14 of 57 Page ID

1

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22

23

24

25

26

27

28

1773

USC sectsect 6101-6108 in 1994 The FTC adopted the original TSR in 1995

extensively amended it in 2003 and amended certain sections thereafter 16

CFR Part 310

39 Defendants are ldquoseller[s]rdquo or ldquotelemarketer[s]rdquo engaged in

ldquotelemarketingrdquo as defined by the TSR 16 CFR sect 3102(dd) (ff) and (gg) A

ldquosellerrdquo means any person who in connection with a telemarketing transaction

provides offers to provide or arranges for others to provide goods or services to a

customer in exchange for consideration 16 CFR sect 3102(dd) A ldquotelemarketerrdquo

means any person who in connection with telemarketing initiates or receives

telephone calls to or from a customer or donor 16 CFR sect 3102(ff)

ldquoTelemarketingrdquo means a plan program or campaign which is conducted to

induce the purchase of goods or services or a charitable contribution by use of one

or more telephones and which involves more than one interstate telephone call 16

CFR sect 3102(gg)

40 Defendants are sellers or telemarketers of ldquodebt relief servicesrdquo as

defined by the TSR 16 CFR sect 3102(o) Under the TSR a ldquodebt relief servicerdquo

means any program or service represented directly or by implication to

renegotiate settle or in any way alter the terms of payment or other terms of the

debt between a person and one or more unsecured creditors or debt collectors

including but not limited to a reduction in the balance interest rate or fees owed

by a person to an unsecured creditor or debt collector 16 CFR sect 3102(o)

41 The TSR prohibits sellers and telemarketers from requesting or

receiving payment of any fees or consideration for any debt relief service until and

unless

a The seller or telemarketer has renegotiated settled reduced or

otherwise altered the terms of at least one debt pursuant to a

14

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 15 of 57 Page ID

1

2

3

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5

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7

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13

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24

25

26

27

28

1774

settlement agreement debt management plan or other such

valid contractual agreement executed by the customer and

b The customer has made at least one payment pursuant to that

settlement agreement debt management plan or other valid

contractual agreement between the customer and the creditor

and

c To the extent that debts enrolled in a service are renegotiated

settled reduced or otherwise altered individually the fee or

consideration either

i Bears the same proportional relationship to the total fee

for renegotiating settling reducing or altering the terms

of the entire debt balance as the individual debt amount

bears to the entire debt amount The individual debt

amount and the entire debt amount are those owed at the

time the debt was enrolled in the service or

ii Is a percentage of the amount saved as a result of the

renegotiation settlement reduction or alteration The

percentage charged cannot change from one individual

debt to another The amount saved is the difference

between the amount owed at the time the debt was

enrolled in the service and the amount actually paid to

satisfy the debt 16 CFR sect 3104(a)(5)(i)

42 The TSR prohibits sellers and telemarketers from misrepresenting

directly or by implication any material aspect of any debt relief service including

but not limited to the amount of money or the percentage of the debt amount that a

customer may save by using the service 16 CFR sect 3103(a)(2)(x)

15

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 16 of 57 Page ID

1

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23

24

25

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28

1775

43 Pursuant to Section 3(c) of the Telemarketing Act 15 USC

sect 6102(c) and Section 18(d)(3) of the FTC Act 15 USC sect 57a(d)(3) a violation

of the TSR constitutes an unfair or deceptive act or practice in or affecting

commerce in violation of Section 5(a) of the FTC Act 15 USC sect 45(a)

VIOLATIONS OF THE TELEMARKETING SALES RULE

Count Two

(Advance Fee for Debt Relief Services)

44 In numerous instances in connection with the telemarketing of

student loan debt relief services Defendants have requested or received payment

of a fee or consideration for debt relief services before

a Defendants have renegotiated settled reduced or otherwise

altered the terms of at least one debt pursuant to a settlement

agreement debt management plan or other such valid contractual

agreement executed by the customer and

b The customer has made at least one payment pursuant to that

settlement agreement debt management plan or other valid

contractual agreement between the customer and the creditor

45 Defendantsrsquo acts or practices as described in Paragraph 44 of this

Complaint are abusive telemarketing acts or practices that violate Section

3104(a)(5)(i) of the TSR 16 CFR sect 3104(a)(5)(i)

Count Three

(Material Debt Relief Misrepresentations)

46 In numerous instances in connection with the telemarketing of

student loan debt relief services Defendants have misrepresented directly or

indirectly expressly or by implication material aspects of their debt relief services

including but not limited to that consumers who purchase Defendantsrsquo debt relief

services will or likely will have their monthly payments reduced or their loan

16

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 17 of 57 Page ID

1

2

3

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19

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28

1776

balances forgiven in whole or in part

47 Defendantsrsquo acts and practices as described in Paragraph 46 of this

Complaint are deceptive telemarketing acts or practices that violate Section

3103(a)(2)(x) of the TSR 16 CFR sect 3103(a)(2)(x)

Count Four

(Disgorgement of Ill-Gotten Gains of Relief Defendant)

48 Relief Defendant Noel has received directly or indirectly funds or

other assets from Defendants that are traceable to funds obtained from Defendantsrsquo

customers through the unlawful acts or practices described herein

49 Relief Defendant Noel has no legitimate claim to Defendantsrsquo

customersrsquo funds or other assets and will be unjustly enriched if it is not required to

disgorge the assets or the value of benefits received as a result of Defendantsrsquo

unlawful acts or practices

50 By reason of the foregoing Relief Defendant Noel holds funds and

assets in constructive trust for the benefit of Defendantsrsquo customers

CONSUMER INJURY

51 Consumers have suffered and will continue to suffer substantial injury

as a result of Defendantsrsquo violations of the FTC Act and the TSR In addition

Defendants have been unjustly enriched as a result of their unlawful acts or

practices Absent injunctive relief by this Court Defendants are likely to continue

to injure consumers reap unjust enrichment and harm the public interest

THIS COURTrsquoS POWER TO GRANT RELIEF

52 Section 13(b) of the FTC Act 15 USC sect 53(b) empowers this Court

to grant injunctive and such other relief as the Court may deem appropriate to halt

and redress violations of any provision of law enforced by the FTC The Court in

the exercise of its equitable jurisdiction may award ancillary relief including

rescission or reformation of contracts restitution the refund of monies paid and

17

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 18 of 57 Page ID

1

2

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1777

the disgorgement of ill-gotten monies to prevent and remedy any violation of any

provision of law enforced by the FTC

53 Section 6(b) of the Telemarketing Act 15 USC sect 6105(b)

authorizes this Court to grant such relief as the Court finds necessary to redress

injury to consumers resulting from Defendantsrsquo violations of the TSR including

the rescission or reformation of contracts and the refund of money

PRAYER FOR RELIEF

Wherefore Plaintiff FTC pursuant to Section 13(b) of the FTC Act 15

USC sect 53(b) Section 6(b) of the Telemarketing Act 15 USC sect 6105(b) and

the Courtrsquos own equitable powers requests that the Court

A Award Plaintiff such preliminary injunctive and ancillary relief as

may be necessary to avert the likelihood of consumer injury during

the pendency of this action and to preserve the possibility of effective

final relief including but not limited to temporary and preliminary

injunctions orders freezing assets immediate access to business

premises appointment of a receiver and expedited discovery

B Enter a permanent injunction to prevent future violations of the FTC

Act and the TSR

C Award such relief as the Court finds necessary to redress injury to

consumers resulting from Defendantsrsquo violations of the FTC Act and

the TSR including but not limited to rescission or reformation of

contracts restitution the refund of monies paid and the disgorgement

of ill-gotten monies

D Enter an order requiring Relief Defendant to disgorge all funds and

assets or the value of the benefit it received from the funds and assets

which are traceable to funds obtained from Defendantsrsquo customers

through the unlawful acts or practices described herein and

18

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 19 of 57 Page ID 1778

2

3

E Award Plaintiff the costs of bringing this action as well as such other

and additional relief as the Court may determine to be just and proper

Dated February 5 2019

Respectfully submitted

ALDEN F ABBOTT General Counsel

JosaSMillard Brian M Welke middot Barbara Chun (Local Counsel) Attorneys for Plaintiff FEDERAL TRADE COMMISSION

4

5

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8

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10

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14

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16

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21

22

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24

25

26

27

28

19

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 20 of 57 Page ID 1779

EXHIBIT A

Attachment A

Free Assessment

Our expercs will lt1ssPss you cun ent

swclent lo n program and decermn which progr ms are

avc11l bl rn yoL11 situation We wi I help you cl11cic1e which progr m r1

help you achieve your goals Call us today

Service Guarantee We are commmecl to 11-1 111g

CllStomers get low r rc1ces ancl monthly payments and we w1I

m ke the pror~ss se mless and s r11ghtforwc1rd ou wi ll be sansf1ed

with our service ml OLlr

cornmcmem to you success Thars ow gu~ ancee

Success Rate Ou1 96 ~ surcPss r a e s 11e of he

cop I a ings tn he industry Olr

process has beer tested nd Olli

succ ss r r~ prowbull~ tn t it works

We c n ll~lp yo reduce and -1111ph y our p ~ymP1 ts Call us today

FTC-AID-1

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 21 of 57 Page ID 1780

20

Exhibit A

ABOUT US

We can help you reduce and simplify your pay1ncnts Contact one of our specialists today for

a free evaluation

111middot 1_I 1

101

t I 11111 I I

Itbull 11

Ill fl I I

bull ~ 0 I

What Makes Us Great fa1(li1-_~ tur1ent ~e11ef 11as a taf- o~middot tt a middotel elt1)rns bullJn st1ncb110

1middot1ep yriJ Tibullmiddotest fi 1e-ndly f3ce~ 113ve eirej e1tc-nsve1yr =inj ire

fanih1~1 bull11iu1 ti~e nul~nce~ cfscrvern rrent Cdid p11vate stucre11

l1J1ns Th~y viill u~e Ui5 epe tise o loik jUl fJ ycur ~Je~t

i(tres~- f)LH ~U(CtS~ ~HE 1h-~ I lSllt of i_r middotDff ancl iur

C ur ~r_(J~l 1o~w- JCl11~crs f(middotil) 3 00Vtli ~tJegy o r ~dUC2 011i

a1r1plfy yliur- - _Je1middott middotcar payr1t11s 1) Asstrnlins Itle ~atl1t1

2) R~~ear c1-1ng Our st~lff wmiddoti11 (lrJUi~oleaerick ]ll fnfcnTnati(-n befort dtmiddoteJPlr~ t tne ri~n 3) rnnk1middotgbullle i_i1 i e~ear (rr i~ ormiddot1 1 1 etc 1Ne

irvi-s t1ga~ii 111 ps~ib le a~irst 1n(t aptlbull~n 4) 1Nr1 ting VVF p1 eiv lii J 11 iUen u tt-igy IJefore vie Uke ut1c-1l i)ecius~ you d-ese11e 11) undi r~~anci

Lhe pr 1cer S) ~ev1sing Al)ng ~r 1udent Relief 1- 1otT11111tt bull) ti) ci e1H1ve ut-l-~n~-l)O c111 i ri 3 Vbulle -~11 leave n1) sti bull1e u11t111 neltl tecause middot~ve

11~1ve your be~ i1~ t~rest 1t l1ein 6) Si~tcl11ng Our note- =1nd r~c)1 ~ ~1 e thorou~ll ln(I pru1ile 1 ceJ1 po cri1~ 1)f vo111 ~1tuJticn s) iny if-oi

~xpe1 t- 01 eou pped to s~1ty1J_J bullVi r you1 c si- 7) De-gn1ng _ fe ~1 t 1nelt--1- f1ts ti 1middotV 1middotid de~ 1middot1 1 st1 iegy to fit ou 1 1_i dque jtct1in so

011 c111 i Jle y1)u1 1vv1middot1 per feet -ut1e-s ~~0 1 v

1bullVlly 1100~e At(J1n~ Sltl(ltnt Fie11e7) (i1_d aclol~Or~ bull -ii~ (1Ualiftel lci ~~~ISt~h 1noie ype-s middotif JS~iSi_ance u~211 Cd ( (11)itXS i1 jG(l1~t) to ti-tgt

p ~n~ 1not con1p n1es can 11i1p bullbullllh ve )t ~ ~qu1pptCI to bull-bullGr k 1bullv1t1middot1 r~ 11t-2 [uo emiddot 1 lc1 r1s ~~nCI cn even iner-1ne frmiddot tt1e c ~e of 1l~e

~1lt ntslmiddoturelt A1cl1rg Sudent Fie1ef 1middot cis mmiddote to )fe 11d we offe1 t with middotmiddot1eltbullbe 1es nI 3 rncney lock guMai-itee

We Have Been Featured In

FTC-AID-2

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 22 of 57 Page ID 1781

21

Exhibit A

SERVICES Wt w gtL

Loan Forgiveness Income Based Payments Loan Consol idation In some cases individuals with A period of financial hardship may You may be able to combine

Fede1middota1 Student Loans may qualify qualify you for an Income Based nultiple federal student loans into to have a portion of the amount Repayment Plan In many cases this one new loan w ith a lower more

owed may be forgiven This means means you pay nothing Unlike a affordable monthly payment Loan

your principal balnce coulcl be defe1 ment the term on your loan consolidation prngrams can l1elp

significantly reduced and you will continues to reduce while the plan is you qualify for additional programs not be expected to repay the in place Your term could reduce like loan forgiveness programs or

forgiven amount while you pay nothing Public Setvice Loan Forgiveness

a III

Private Sector Loan Forgiveness

If you work for a government

organization at a city state or

federa l level you may qualify for tle

PL1blic Service Loan Forgiveness

program To qualify your loans

must be cotisolidated into a specific

repayment plan The balance on

your federai student loans is

forgiven after 120 qualifying

bull C Permanent Disability

Forgivenness If your disability is expected to last

60 months or more you may qualify

for permanent disability forgiveness

Q1alifying for Permnent Disability

Forgiveness requires a visi t to your

doctor and individL1als enrolled in

the program are subject to three

years of post-discharge monitoring

Wage Garnishment Prevention

Federal law requires that the

Department of Education or a

gua1middotanty agency notify you before

111st1tuting wage garnishment You

have tl1e right to a hearing where

you can challenge the stated

amount owed and negotiate the

terms of the repayment scheclule

We can intervene on YOL1PflJl~1D-3

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 23 of 57 Page ID 1782

22

Exhibit A

payments have been made p1middotevent wage gampnishments

A FEW STATISTICS ABOUT STUDENT LOAN CRISIS

12 Trillion National Student Debt I he nitionil student loin debt is

now 17 trillion dollirs 1 trillion of

these are in federil student loans

Let us help you through this national

crisis Cill today for a free

evaluation

40 Million Students with Debt

In 7014 an estimated 40 million

current and former students were in

debt because of student loans If

you are one of the millions of people

struggling to pay student loans

Aiding Student Relief is here to help

$33000 Average Student Debt

The graduating class of 7014

average $33000 of student loan

debt per person Thats $3000 more

than the average in 2013 Dont be

one of the many Let Aiding Student

Relief advocate for you

Aiding Student Relief has helped cmrnllcss 1woplc reduce their student debt_ Their proven business

plan has led lo one of lhc highest s11cclSS raCs in the inltl11slly

John Standiford Associated

FTC-AID-4

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 24 of 57 Page ID 1783

23

Exhibit A

TESTIMONIALS

Til~nks to Aiding Student Rel ief Im middotI middotva ove1vvhelrnecl but Aiding The expemiddotts at l1icl i11g Student Rel ief

s1v ing $250 per month Strrd r~rt Relief expl~ inecl the were ther~ to help me when I process ancl rnacle everytl1ing cle11middot nelclecl 1t rw)s t

and sirnple

I Michael Ma 1in

Entrep e11eu1 Em iiy Jallo1 Ii Pa ul Ch is tia I1se11

Teacher Nurse

With so many programs I didnt middotconso lrclating my loans into one I love my Job but vith my high

know what was ng ht for me My monthly payment hs made life student loan payment was still

sruclent loan aclvsor walked me si1nple1 Now I can focus on 1Nhn bamiddotely getting by I don t kn ow what I

through my optio ns rnd now Imiddotn matters to me would hwe clone wthout Aiding

saving 54 I 11n1omh Stucie1middott Rel refmiddot

Ariel Hemiquez Sales co)SUltant

Stephani Seland-1 Small Busim~ss Owner

AJ 01en Museum Curator

RECENT NEWS

)lt)

o(l ttDrlTI -5

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 25 of 57 Page ID 1784

24

Exhibit A

Student Debt Crisis Business Latest Debt Collective Demands May be largely about smallest Student

borrnwers US News amp World Loan Crisis is fa frorn ove The Debt Collective is a group of Report-May 162015 last month Two new reports suggest the college students calling the Fedemiddotal Reserve Bank of New student loan crisis is easing them-se1ves the Corinthian York repor ced that stuclent loan somewhat as the economy Fifteen who are refusing to pay balances rose to 16 trillio n and improves but the crisis is far back their student loins As pa t that 113 per cent of that is in from ove the College Board of this effort the Debt Collective repo t~ tot31 borrowing fell by 8 has written an open lette to the pEbull1 cent between 2012-13 and Department of Education f l llJ 20 13-14 The organization

About Us 11 1 i~d1middot1r F th~~- h1~ ff t1middot~11middot=cl =i~=middott- 1middot __31middotmiddotIIgt middot bullmiddot11

middot- I ( )ntir il t l~i -r_il fr~~

Address bull middot tc1ltj-1r_ =i ~

middot l t1~t 1middot1 fcJ middot~_1 1 I l11 - Hbull 1 tr

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FTC-AID-6

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 26 of 57 Page ID 1785

25

Exhibit A

f - g+ in O) ~ PRIVACY POLICY

This privacy statement discloses the privacy practices for AidllII Student Relief Because Aiding Studen Relief wonts to demonstrate ts firm commlcmell to your

privacy Aiding Sudent Relief hes greed to disclose ls 1rifor111atlori g1thering and dlssem1n1t1on prct1cts Aidlns Studtrit Relief will notify you of

INFORMATION COLLECTION At-ID USE

Aiding Student Relief is the sole owner of the rformMlon collected on this site We will not sell shire or rent this information 10 others In way different from what Is

disclosed 1n this statement Aldln1 StudeM Relief collects 1nform111on throuah this site from our prospective end existing clients at several different poin on our web

site We use their contact Informii on to send information bout our company and to service exsMs accounts Users may optbullout of rece11ns future malllngs see the

cholceoptbullout section below Contect and Financial information that 1s collected Is used for verifying your name address and other informa1on as well as to boll you for

your use of our Gerv1ces using Information from third party sourcH Information about your computer hardwre and software Is automatically collected by Aiding

Student Relief and may be shared in asgregate with third parties whose services are used for traffic analysis purposes This Ir formation includes your IP address

browser type domain names access times and referring Web site addresses Ths information is no tied to personally Identifiable Information This 1nformatlor s used

by Aiding Student Relief to malMan no Improve the quality of the Hrvct and to senerae statistics resardlng use of he Aiding Student Relief site We use third party

services to bill for serlces and to provide other services like our Live Help chat We store the transcripts from these chats for customer service Improvement These

third party service providers are not permitted to use your infornon for any secondary purposes

Thank you and cheers

FTC-AID-7

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 27 of 57 Page ID 1786

26

Exhibit A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 28 of 57 Page ID 1787

EXHIBIT B

Attachment A

((

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AIDINGSTUDENTRELIEF

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f e=klHMW

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lt=Dkgt=L]oHUKMMH ihTFNIORI THHVPRFMVKgtNJ_NFFbIVSJI]IFjdGGVNNN lt=TFKPPNF 9DaFGmVHPGRJMFNNQOSGnPFFTNLUNHPMIMTFVNJOKMIWV

27

]UMNOHPFRKNVSHKKISIRWRrGZNJONgtNjTHKHMI=cQgtORHVPKSOUMddUNKSPIdspNVPNq_ lt=gtBTHFHPb=HFILGFHMt DTFuFIUVFRPNTFIMINVWOPRVOQFIV sFQFPHKKH vaIPNFVcSyOFSPRFMRNVOJH_gtVFDVUJAN9FPwFuVFJLFHMP_VTFFdSIIVdNHUPxI=DQSROJGASHIVdDSNMINONPPaHdOHdPFHRIWVFFHdFIGM˙ 01 $2 301 $$3 ( Exhibit B

8

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13 deg $ $ampdegdeg degˇ amp $$deg + -+Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 30 of 57 Page ID 1789 () ( vPSZwPxyYTUZUWWzxPyxSWMZWPU|SWUWYZ~YTY~QSWbullYXRwU~UxSdaggerXQ~UZXvPSZWSOVQSYNOXPRSTUSDaggerPxXYPZPNXRUSPQZXPbullU~SOhellipUNPxyYTUZmdash zUxSZUZXndashYWShellipYYXOwPxyYTUZUWWMNOPQx~YWShellipYYXOYWUƒDaggerU|XU~XPSWXfrasllsaquoPZXRWPxPxUOPQSOVQSYNONPxDaggerUxSZUZX~YWShellipYYXONPxyYTUZUWWmdash

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^ ˙ ( (

28

Attachment A

01 $2 301 $$3 ( Exhibit B

()(

=4ABC9DEAFBD=FGFHIJKLMJNOMN MRNS mn = nrst = svzhellipu t bulltvDaggerrhellipDaggerurbullbulltuhellipv hellipz~ bullmdashldquordquolsquorsquotrade š oŒŠeuro centpound ` umluml 13 deg $ $ampdegdeg degˇ amp $$deg + -+Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 31 of 57 Page ID 1790

ISNRTUKQINKKNNKL[MRJ PUWQI]MRM qyt|tytzxy rsaquoqNfraslbdquoPUhellipsbquoLUyQhellip rfraslbhellipMNSIKVUQ QNJKvUQsMiexclQQJUx[iexcliexcl_vsect_Qyenyenbrvbarbrvbar uSSRNTPL_LUUMKIaJ_WMIJJKVIONNQJJMWRMIIbQQURKLWIIJQbKLUNKMPTMNQQ_KKRY tbullbulldaggersDaggerv~vhellipmdashryrhellip~mdashrhellipDagger ŸLŽUıQŽbłpermilMtradeœsbquoNtrade_ffRŁyISMŒUQWyNUQŠlsaquo rv45657896lt7ltgt5lt PQKLMIQSNRTUKINQVNOOMVKMWNQKLIJPMXJIKMYZMPIOO NJMOOJLURMNRRMKKLIJ klltko ltgtlt85p5gt5 ouvwxrz ^^ ~ minuspermil tffŁ yenpoundpound KNOWDaggerIreggt4lt97ltndash9ƒ Dagger hellipDaggerlsaquo žko74k57ƒ ƒISNcurrenUIWIbJKWMKJYVNTKM KLONNRqIQQSNNRTUKINQQIJ_JMWNQKLIJJJPMXJIKMcOMUJMVNQKUVK_JUKBHdefABCgDEAFBDghidjlaquopoundbrvbariexclnotvIWIQbDaggerK_WMQKbullMOIMSvOObullIbLKJbullMJMRMW ordf copy

01( $2(301$$3( Exhibit B

29

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 32 of 57 Page ID 1791

EXHIBIT C

Attachment A

~ 111 ~tampi 10 11 ~bull ia1111

Something awesome is coming soon We are buildin somethin ve cool Sta tuned and be at1ent Your atience will be well aid

~lbullrbullUiUffl We can help you reduce and simplify your payments

101 Loan For iveness

1~u 0 (middottmiddotbullmiddotmiddot1 1~=I -- _~

HZamp IMUliULlampRampatiEUWi nmiddot middot-il~ fr middot 8rbullbullrcrr-

_J l _ 1 _f _ur -~t~ u L liYu

~ Income Based Pa ents

bull ~ f I - - I - I - ri u ~u-=lf ~ JU

1-bullA ---rc iM1~~ -~-bullCiel rrcl

~- middot IY 2 i C middot middotJ ll1Jmiddot 0 _ middot_middotIr i

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middotE-ltecl l2bullJbull iequbullt t11cit t1lt2 CtpCr~middot1e- f

JJd r g-_iraE-1 agltr-middot- ntimiddot middot)middotou

tmiddot_rt- i ic l~1ri ~rbullmiddot middot111~ umiddot -_ d_t-c

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Triin- GU

WAWMyenEIRitiRpoundWt 44 ZiAtillampampI

Exhibit C

Case 818-cv-01987-JLS

-KE

S

Docum

ent 50-1 F

iled 020519 P

age 33 of 57 P

age ID 1792

30

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 34 of 57 Page ID 1793

EXHIBIT D

Attachment A

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Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 35 of 57 Page ID 1794

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

infoaidnestcom (800) 555-1212

HOME

ABOUT US

SERVICES

FAQ

BLOG

CONTACT

HOME ABOUT US SERVICES FAQ BLOG CONTACT

1 of 6 462018 945 AM

31

Student Loan Forgiveness Loan Consolidation Student Loan Forgiveness

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 36 of 57 Page ID 1795

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

If you have Federal Student Loans yoursquore in the right place to get those loans reduced forgiven or completely discharged through our student loan forgiveness programs

Get your multiple Federal Student Loans consolidated into one forget about increasing interests and pay month to month at the lowest possible cost

We understand if yoursquore going through some hardship and thatrsquos why with us yoursquoll be able to make monthly payments based on your affordability for as low as $000 depending on your situation

2 of 6 462018 945 AM

32

Knowledge Base

Defaulted Student Loans

Wage Garnishment

Student Loan Rehabilitation

Income Based Repayment Plan

Deferment and Forbearance

Pay As You Earn Repayment Plan

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE Call 561)424-6053 today to go over your options

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 37 of 57 Page ID 1796

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

Our knowledge base is designed to provide information regarding some of the critical topics those with student loans must be aware of to be able to make educated decisions regarding their future

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

A wage garnishment is any legal procedure in which some portion of a personrsquos earnings is required to be withheld by an employer for the payment of a debt

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

With this program your payments change as your income changes and will not be longer than 25 years This is the ideal plan if you are in partial financial hardship Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard plan

Temporarily allowing you to postpone or reduce your federal student loan payments Postponing or reducing your payments may help you avoid default and future garnishments

Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard

3 of 6 462018 945 AM

33

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 38 of 57 Page ID 1797

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

4 of 6 462018 945 AM

34Attachment A

Testimonials

Latest News

Why 2016 Will Be a Big Year For Student Loans

Top Student Loan Refinancing Questions of 2015

Oba mas latest student loan plan

Things You Should Know About Public Service Loan Forgiveness

Recent Posts

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 39 of 57 Page ID 1798

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

5 of 6 462018 945 AM

35

About Us

Contact Info

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 40 of 57 Page ID 1799

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

pay-grandchild-studen

Why 2016 Will Be a Big Year For Student Loans

December 30 2015

12511110_1112367518

Top Student Loan Refinancing Questions of 2015

December 30 2015

We stand by our consultation and quote We are so sure and confident about our services and offers that they are all 100 money back guarantee risk free ndash if we donrsquot do what we promise yoursquoll get your money back

(800) 555-1212 AidnestStudenLoansgmailcom 18100 Von Karman Ave Suite 850 Irvine CA 92612

Futero SAS copy 2015 | Aidnestcom

6 of 6 462018 945

Exhibit D 36Attachment A

AM

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 41 of 57 Page ID 1800

EXHIBIT E

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 42 of 57 Page ID 1801

AIDNEST Let us help you through this national crisis

Call one of our specialists today

Forbearance amp Deferment If you are still in school and struggling to make payments on your student loans You may qualify

for Forbearance amp Deferment

Garnishment Prevention Federal law requires that the Department of Education or guarantee agency notifies you before they

begin garnishing your wages

Loan Forgiveness If you are a teacher public service worker or an individual with total and permanent disability you

httpaidnestcom[442018 115239 AM]

37Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 43 of 57 Page ID 1802

AIDNEST Let us help you through this national crisis

may qualify for this program

Consolidating Your Loans Consolidating your loans to one new loan under one lender may lower your payments and make

your life a bit more manageable

Affordable Payments If you are looking to lower your monthly payments then Income Based Repayment Plans may be

the correct choice for you

Learn more about our services

LEARN MORE

httpaidnestcom[442018 115239 AM]

38Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 44 of 57 Page ID 1803

AIDNEST Let us help you through this national crisis

Loan Forgiveness Programs Income Based Payments Student Loan Rehabilitation

Student Loan Consolidation

You may be eligible for

Loan Forgiveness Programs

In some cases individuals with Federal Student Loans may qualify to have a portion of the amount

owed to be forgiven

Get in touch with our professional team to find out which loan forgiveness program you qualify for and

how you can get rid of your unpaid student loan

L EARN MORE

httpaidnestcom[442018 115239 AM]

39Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 45 of 57 Page ID 1804

AIDNEST Let us help you through this national crisis

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE

Meet your Budget One of our advisers will help you meet your payment goals by using your budget and timeline to

determine the best plan available

httpaidnestcom[442018 115239 AM]

40Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 46 of 57 Page ID 1805

AIDNEST Let us help you through this national crisis

Simple Process We understand that lowering your payments alone can be difficult Our intuitive platform allows us

to keep the entire process simple

Customer Satisfaction We are committed to providing you with outstanding service only We look forward to working

with you

100 money back guarantee No Hassle Money Back Policy

httpaidnestcom[442018 115239 AM]

41Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 47 of 57 Page ID 1806

AIDNEST Let us help you through this national crisis

Lower your loan payments by getting in touch with one of our professionals

We design a customized repayment plan that will allow you to make payments based on your

monthly income family size and spending Get rid of the hassle of extensive paperwork and get the

help you deserve

What we can help you achieve a lower payment or lower rate

httpaidnestcom[442018 115239 AM]

42Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 48 of 57 Page ID 1807

AIDNEST Let us help you through this national crisis

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcom[442018 115239 AM]

43Exhibit E

httpaidnestcomservices[442018 115322 AM]

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 49 of 57 Page ID 1808

Services | AIDNEST Let us help you through this national crisis

INCOME BASED PAYMENTS

If you are suffering from a financial hardship you may be eligible for an

Income Based Payment In this repayment program you would have a

payment based on your income and family size The payment could be as

low as $000 per month with forgiveness at the end of 20-25 years

44

Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 50 of 57 Page ID 1809

L E ARN MORE

LOAN FORGIVENESS

If you have Federal Student Loans you may qualify for any of the student

loan forgiveness programs that are available to borrowers You may be

eligible for principal reduction loan forgiveness or a complete loan

discharge depending on your individual circumstance

L EARN MORE

PRIVATE STUDENT LOAN CONSOLIDATION

Much like refinancing a mortgage generally the biggest benefit of private

student loan consolidationstudent loan refinancing is a lower interest rate

httpaidnestcomservices[442018 115322 AM]

45Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 51 of 57 Page ID 1810

L E ARN MORE

(something federal consolidations do not offer)

STUDENT LOAN REHABILITATION

You can renew eligibility for new loans and grants and eliminate the loan

default by ldquorehabilitatingrdquo a defaulted loan

httpaidnestcomservices[442018 115322 AM]

46Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 52 of 57 Page ID 1811

CHE CK E L E G I B I L I T Y

WAGE GARNISHMENT

A wage garnishment is any legal procedure in which some portion of a

personrsquos earnings is required to be withheld by an employer for the

payment of a debt

L EARN MORE

With our fast friendly and professional services wersquoll be glad to help you get your student loans

reduced forgiven or completely discharged To this end wersquoll assist you in consolidating all your

student loans so yoursquoll have only one lender and yoursquoll start making one monthly payment Our

professionals will walk you through the best and most flexible repayment options and if itrsquos also

necessary varied deferment options and rehabilitation programs

httpaidnestcomservices[442018 115322 AM]

47Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 53 of 57 Page ID 1812

Services | AIDNEST Let us help you through this national crisis

Our CRM System

Our CRM is one of the most advanced in the industry and most importantly itrsquos linked directly to

the Department of Education (DOE) This keeps your personal and most confidential information

safe Furthermore because our CRM system is linked to the DOE our approval is 100 Through

our CRM we will be doing continuous monitoring of our process without losing sight of your

immediate needs ensuring that your case has the proper handling and most efficient process

httpaidnestcomservices[442018 115322 AM]

48Exhibit E

n

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 54 of 57 Page ID 1813

Services | AIDNEST Let us help you through this national crisis

R ECENT POSTS

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

ABOUT US

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcomservices[442018 115322 AM]

49Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 55 of 57 Page ID 1814

EXHIBIT F

s -

bullmiddot - ~ t ~ower Your Student Loan Pay~e~ts oday -- Students Helping Students Save Money

INCOME BASED PAJIIIJITPAIS

I C(gttoUC1 u~

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 56 of 57 Page ID 1815

X + C (D Not secure wwwstudoracom 0

CALL US NOW (85S) 978-S599 middot 1nfostudoracom

HOME SERVICES ABOUT US FAQ CONTACT US BLOC PRIVACY

Offering obligation and commitment free loan relief solutions

STUDENT LOAN FORGIVENESS INCOME BASED PAYMENTS LOAN CONSOLIDATION

We11 help you get your loans reduced forgiven o r Make monthly pdyments based on your affordability Get multiple Federal Student Loans consolidated into

discharged one low monthly payment

Talk to our experts concerning your

student loans

Studora is a pnvatefy owned company that helps consumers like you identify

government programs that fit your financial s1tuat1on Our loan experts will assist you in selecting the appropriate programs that WOltk with your income family size and

desired monthly payment We then prepare the appropriate documents for your review and submission All this f o r one low easy payment

Testimonials

Thank you f o r getting back to me quickly Youve been fabulous Thank you for the confirmation and for your help today Pass

during this whole process Is there a place I can go online that I this on to your sup that you were very professional and very

can leave a comment for your manager Youve made this Robert helpful and brought a sense of relief for me Thank you very

process so easy and answered every question my husband and I much and have a great rest of your day Kudos to you and your

have had teammoneywell spenL

Exhibit F 50

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 57 of 57 Page ID 1816

Services we offer

Stud ora offers document preparation services for all loan forgiveness consolidation and relief services to people who are unable to manage their finances Our mam aim is to

offer complete peace of mind to indiVidual unable to pay their student loan debt

we otter the folloWing document preparation services with complete professional assistance

amFinancial Review ffl Budget Planning

Toe first step to creating a flexible loan repayment plan is financial review we also help create a personal finance plan to ensure that you are able to

Our professmnals will look into your finances and design a custom manage your monthly budget in the most effective way This plan will keep

repayment plan that is affordable and easy to manage your spending to the minimum alloWing you to save more money for loan

repayment

Permanent Disability Forgiveness r-trTeacher Loan Forgiveness (5 You can get rid of your Federal Student Loan if you are permanently disabled Good news for teachers who are under the weight of a massiVe loan You can

now get $17 forgiven on your student loans

Public Service Loan Forgiveness Custom Debt Relief Plans

Want assistance with debt relief Get in touch with our experts who will help If you are a public service agent you can get rid of your loan after 120 days of design a loan repayment and relief plan for you based on your monthly

income and affordability payments

THERE ARE NO OBLIGATIONS OR COMMITMENTS

want to save thousands of dollars Fill out our form and get relief from your student loan for a more

peaceful tomorrow

Your Name

BiHHHi

Exhibit F 51

Attachment A

Page 7: JOSHUA S. MILLARD, BRIAN M. WELKE, pro hac vice · for which it has no legitimate claim. Noel is a Wyoming limited liability company that reported in a public document that its principal

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 7 of 57 Page ID

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

1766

DEFENDANTSrsquo UNLAWFUL STUDENT LOAN DEBT RELIEF

OPERATION

16 Since at least December 2014 through at least the filing of the FTCrsquos

Complaint in this matter in November 2018 Defendants have operated an unlawful

debt relief scheme that preys on consumers with student loan debt In telephone

calls on websites and in mailed advertising Defendants promise to reduce

consumersrsquo monthly student loan payments and eliminate all or a portion of their

student loan debt through enrollment in student loan forgiveness or repayment

programs In many instances however Defendants failed to obtain debt

forgiveness or monthly payment reductions In fact some consumers owed more

on their student loans after enrolling in Defendantsrsquo program

17 In exchange for the promised student loan debt relief services

Defendants have charged illegal upfront fees of $499 or more

Background on Student Loan Forgiveness and Repayment Programs

18 Student loan debt is the second largest class of consumer debt more

than 42 million Americans collectively owe nearly $15 trillion in student loan

debt The student loan market shows elevated levels of distress relative to other

types of consumer debt

19 To address this mounting level of distressed debt the US

Department of Education (ldquoUSDErdquo) and state government agencies administer a

limited number of student loan forgiveness and discharge programs Most

consumers however do not qualify for these programs because of strict eligibility

requirements For example one program requires the consumer to demonstrate a

total and permanent disability another applies only to consumers whose school

closed while the consumer was still enrolled A third program the Borrower

Defense to Repayment (ldquoBDRrdquo) may provide a loan discharge if the school

through an act or omission violated state law directly related to the borrowerrsquos

7

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 8 of 57 Page ID

1

2

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23

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28

1767

federal student loan or to the educational services for which the loan was provided

20 Other forgiveness programs require borrowers to work in certain

professions for a period of years For example Teacher Loan Forgiveness applies

to teachers who have worked full-time for five years in a low-income elementary

or secondary school or educational service agency Public Service Loan

Forgiveness (ldquoPSLFrdquo) applies to employees of governmental units or non-profit

organizations who make timely monthly payments for a period of ten years while

employed in the public sector

21 The federal government also offers loan forgiveness through income-

driven repayment (ldquoIDRrdquo) programs that enable borrowers to reduce their monthly

payments and have portions of their loans forgiven IDR programs allow eligible

borrowers to limit their monthly payments based on a percentage of their

discretionary monthly income To remain in an IDR program borrowers must

recertify their income and family size annually Obtaining forgiveness through

IDR programs requires a minimum of 20 or 25 years of qualifying payments

depending on whether borrowers received their first loans on July 1 2014 or

before that date Because a borrowerrsquos income is likely to fluctuate over the life of

the loan monthly payments under the IDR programs can vary considerably from

year to year If a borrowerrsquos income were to increase over the repayment period

for example the monthly payment amount could correspondingly increase to the

point where those payments would pay off the loan before any amount could be

forgiven at the end of the repayment term No loans have been forgiven yet under

any of the IDR programs because the programs have not existed long enough for

borrowers to make the minimum number of years of qualifying payments

22 Consumers can apply for BDR PSLF IDR and other loan repayment

and forgiveness or discharge programs through USDE or their student loan

servicers at no cost these programs do not require the assistance of a third-party

8

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 9 of 57 Page ID

1

2

3

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5

6

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27

28

1768

company or payment of application fees

23 USDE will grant forbearance while processing applications for an

alternative repayment plan and in some cases of hardship During forbearance

unpaid interest is added to the principal balance

Defendantsrsquo Deceptive Marketing of Student Loan Debt Relief Services

24 To lure consumers into purchasing their purported student loan debt

relief services Defendants have made false promises to eliminate or reduce

consumersrsquo student loan balances or monthly payments through loan forgiveness

or other programs

25 To induce consumers to purchase their purported student loan debt

relief services Defendants have disseminated websites such as aidingstudentscom

aidnestcom and studoracom including but not necessarily limited to the

attached exhibits A through F Defendantsrsquo websites have contained the following

statements among others

Free Assessment

Our experts will assess your current student loan program and determine

which programs are available in your

situation We will help you decide which

program can help you achieve your goals Call

us today

Service Guarantee

We are committed to helping customers get

lower rates and monthly payments and we will

make the process seamless and

straightforward You will be satisfied with our

service and our commitment to your success Thatrsquos our

guarantee

Ex A at 1 (aidingstudentscom 2015)

9

Success Rate

Our 96 success rate is one of the top ratings in

the industry Our process has been tested and our

success rate proves that it works We can help you reduce and simplify your payments Call us today

Attachment A

----------

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 10 of 57 Page ID

1

2

3

4

5

6

7

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10

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15

16

17

18

19

20

21

22

23

24

25

26

27

28

1769

ldquoWe can help you reduce and simplify your payments Contact one of our specialists today for a free evaluationrdquo

Ex A at 2 (emphasis in original)

ldquolsquoAiding Student Relief has helped countless people reduce their student debt Their proven business plan has led to one of the highest success rates in the industryrsquordquo

Ex A at 4

100 Customer Satisfaction We can help you reduce and simplify your payments Call one of our specialists

today

Ex B at 1 (aidingstudentscom 2016) (emphasis in original)

Meet some of our members who have saved big on their student loan debt Helping You Save Big

ldquoThanks to Aiding Student Relief I am savings [sic] $250 per monthrdquo Michael Martin Entrepreneur

Ex B at 2 (emphasis in original)

ldquoWe can help you reduce and simplify your payments rdquo

Ex C at 1 (aidingstudentscom 2018) (emphasis in original)

Student Loan

Forgiveness

If you have Federal Student Loans yoursquore in the right place to get those

Loan Forgiveness

Get your multiple Federal Student Loans consolidated into one

10

Student Loan

Forgiveness

We understand if yoursquore going through some hardship and thatrsquos why

Attachment A

Case 818-cv-01987-JLS-KES

1

2

3

4

5

6

7

8

9

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11

12

13

14

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19

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24

25

26

27

28

Document 50-1 Filed 020519 Page 11 of 57 Page ID 1770

loans reduced forgiven or completely discharged through our student loan forgiveness programs

forget about increasing interests [sic] and pay month to month at the lowest possible cost

with us yoursquoll be able to make monthly payments based on your affordability for as low as $000 depending on your situation

Ex D at 2 (aidnestcom 2016)

Lower your loan payments by getting in touch with one of our professionals We design a customized repayment plan that will allow you to make payments based on your monthly income family size and spending Get rid of the hassle of extensive paperwork and get the help you deserve

What we can help you achieve [is] a lower payment or lower rate

Ex E at 6 (aidnestcom 2018) (emphasis in original)

STUDENT LOAN FORGIVENESS

Wersquoll help you get your loans reduced forgiven or

discharged

INCOME BASED PAYMENTS

Make monthly payments based on your affordability

LOAN CONSOLIDATION

Get multiple Federal Student Loans

consolidated into one low monthly payment

Ex F at 1 (studoracom 2018) (emphasis in original)

26 In some instances consumers view the Defendantsrsquo online advertising

and call Defendantsrsquo telemarketers for more information Defendants also make

outbound telemarketing calls and send texts to consumers to offer their services

and convince student loan borrowers to sign up for Defendantsrsquo debt relief

services

11

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 12 of 57 Page ID

1

2

3

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28

1771

27 In calls with consumers Defendantsrsquo telemarketers have told

consumers that Defendants can cause consumersrsquo student loan balances to be

reduced or that consumersrsquo loan balances would be forgiven after making lower

monthly payments Defendantsrsquo telemarketers have told some consumers that over

half their loan balance would be forgiven Moreover Defendantsrsquo telemarketers

have told some consumers that their loan payments could or would be rapidly

reduced to $19 per month or promptly forgiven

28 Defendants have made other representations concerning loan

reduction or forgiveness to consumers in telemarketing their debt relief services

For example Defendantsrsquo telemarketers have told one or more consumers that

ldquofamily sizerdquo a metric for determining the amount borrowers pay each month

under IDR plans includes ldquoanyone you help out throughout the year[] they donrsquot

have to live with yourdquo even claiming that helping with ldquogas money three times

out of the yearrdquo is enough to include a person in ldquofamily sizerdquo Further

Defendantsrsquo telemarketers have offered one or more consumers ldquobasically a

guarantee to remainrdquo in an IDR plan and warned one or more consumers that

signing up for an IDR plan with a lender instead would result in a higher loan

payment

29 Defendants have not been likely to achieve the lower monthly

payments or student loan forgiveness they have advertised marketed and

promoted to consumers In many instances Defendants have failed to obtain the

promised lower monthly payments or student loan forgiveness

30 Defendants have charged consumers fees for purported debt relief

services before achieving lower monthly payments or student loan forgiveness

and in many instances have failed to achieve those results at all on behalf of

consumers

12

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 13 of 57 Page ID

1

2

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22

23

24

25

26

27

28

1772

31 Defendantsrsquo telemarketers have sought and obtained consumersrsquo

payment information by phone or the Internet

32 Defendantsrsquo total advance fees typically have been in the range of

$300-500 Defendants also have charged consumers recurring monthly fees for

purported debt relief services typically charging $19 per month

THE FTC ACT

33 Section 5(a) of the FTC Act 15 USC sect 45(a) prohibits ldquounfair or

deceptive acts or practices in or affecting commercerdquo

34 Misrepresentations or deceptive omissions of material fact constitute

deceptive acts or practices prohibited by Section 5(a) of the FTC Act

VIOLATIONS OF THE FTC ACT

Count One

(Deceptive Student Loan Debt Relief Representations)

35 In numerous instances in connection with the advertising marketing

promotion offering for sale or sale of student loan debt relief services Defendants

have represented directly or indirectly expressly or by implication that consumers

who purchase Defendantsrsquo debt relief services will or likely will have their

monthly payments reduced or their loan balances forgiven in whole or in part

36 In truth and in fact in numerous instances in which Defendants have

made the representations set forth in Paragraph 35 of this Complaint such

representations were false or not substantiated at the time Defendants made them

37 Therefore Defendantsrsquo representations as set forth in Paragraph 35 of

this Complaint are false or misleading and constitute deceptive acts or practices in

violation of Section 5(a) of the FTC Act 15 USC sect 45(a)

THE TELEMARKETING SALES RULE

38 Congress directed the FTC to prescribe rules prohibiting abusive and

deceptive telemarketing acts or practices pursuant to the Telemarketing Act 15

13

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 14 of 57 Page ID

1

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22

23

24

25

26

27

28

1773

USC sectsect 6101-6108 in 1994 The FTC adopted the original TSR in 1995

extensively amended it in 2003 and amended certain sections thereafter 16

CFR Part 310

39 Defendants are ldquoseller[s]rdquo or ldquotelemarketer[s]rdquo engaged in

ldquotelemarketingrdquo as defined by the TSR 16 CFR sect 3102(dd) (ff) and (gg) A

ldquosellerrdquo means any person who in connection with a telemarketing transaction

provides offers to provide or arranges for others to provide goods or services to a

customer in exchange for consideration 16 CFR sect 3102(dd) A ldquotelemarketerrdquo

means any person who in connection with telemarketing initiates or receives

telephone calls to or from a customer or donor 16 CFR sect 3102(ff)

ldquoTelemarketingrdquo means a plan program or campaign which is conducted to

induce the purchase of goods or services or a charitable contribution by use of one

or more telephones and which involves more than one interstate telephone call 16

CFR sect 3102(gg)

40 Defendants are sellers or telemarketers of ldquodebt relief servicesrdquo as

defined by the TSR 16 CFR sect 3102(o) Under the TSR a ldquodebt relief servicerdquo

means any program or service represented directly or by implication to

renegotiate settle or in any way alter the terms of payment or other terms of the

debt between a person and one or more unsecured creditors or debt collectors

including but not limited to a reduction in the balance interest rate or fees owed

by a person to an unsecured creditor or debt collector 16 CFR sect 3102(o)

41 The TSR prohibits sellers and telemarketers from requesting or

receiving payment of any fees or consideration for any debt relief service until and

unless

a The seller or telemarketer has renegotiated settled reduced or

otherwise altered the terms of at least one debt pursuant to a

14

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 15 of 57 Page ID

1

2

3

4

5

6

7

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13

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24

25

26

27

28

1774

settlement agreement debt management plan or other such

valid contractual agreement executed by the customer and

b The customer has made at least one payment pursuant to that

settlement agreement debt management plan or other valid

contractual agreement between the customer and the creditor

and

c To the extent that debts enrolled in a service are renegotiated

settled reduced or otherwise altered individually the fee or

consideration either

i Bears the same proportional relationship to the total fee

for renegotiating settling reducing or altering the terms

of the entire debt balance as the individual debt amount

bears to the entire debt amount The individual debt

amount and the entire debt amount are those owed at the

time the debt was enrolled in the service or

ii Is a percentage of the amount saved as a result of the

renegotiation settlement reduction or alteration The

percentage charged cannot change from one individual

debt to another The amount saved is the difference

between the amount owed at the time the debt was

enrolled in the service and the amount actually paid to

satisfy the debt 16 CFR sect 3104(a)(5)(i)

42 The TSR prohibits sellers and telemarketers from misrepresenting

directly or by implication any material aspect of any debt relief service including

but not limited to the amount of money or the percentage of the debt amount that a

customer may save by using the service 16 CFR sect 3103(a)(2)(x)

15

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 16 of 57 Page ID

1

2

3

4

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17

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22

23

24

25

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27

28

1775

43 Pursuant to Section 3(c) of the Telemarketing Act 15 USC

sect 6102(c) and Section 18(d)(3) of the FTC Act 15 USC sect 57a(d)(3) a violation

of the TSR constitutes an unfair or deceptive act or practice in or affecting

commerce in violation of Section 5(a) of the FTC Act 15 USC sect 45(a)

VIOLATIONS OF THE TELEMARKETING SALES RULE

Count Two

(Advance Fee for Debt Relief Services)

44 In numerous instances in connection with the telemarketing of

student loan debt relief services Defendants have requested or received payment

of a fee or consideration for debt relief services before

a Defendants have renegotiated settled reduced or otherwise

altered the terms of at least one debt pursuant to a settlement

agreement debt management plan or other such valid contractual

agreement executed by the customer and

b The customer has made at least one payment pursuant to that

settlement agreement debt management plan or other valid

contractual agreement between the customer and the creditor

45 Defendantsrsquo acts or practices as described in Paragraph 44 of this

Complaint are abusive telemarketing acts or practices that violate Section

3104(a)(5)(i) of the TSR 16 CFR sect 3104(a)(5)(i)

Count Three

(Material Debt Relief Misrepresentations)

46 In numerous instances in connection with the telemarketing of

student loan debt relief services Defendants have misrepresented directly or

indirectly expressly or by implication material aspects of their debt relief services

including but not limited to that consumers who purchase Defendantsrsquo debt relief

services will or likely will have their monthly payments reduced or their loan

16

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 17 of 57 Page ID

1

2

3

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19

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25

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1776

balances forgiven in whole or in part

47 Defendantsrsquo acts and practices as described in Paragraph 46 of this

Complaint are deceptive telemarketing acts or practices that violate Section

3103(a)(2)(x) of the TSR 16 CFR sect 3103(a)(2)(x)

Count Four

(Disgorgement of Ill-Gotten Gains of Relief Defendant)

48 Relief Defendant Noel has received directly or indirectly funds or

other assets from Defendants that are traceable to funds obtained from Defendantsrsquo

customers through the unlawful acts or practices described herein

49 Relief Defendant Noel has no legitimate claim to Defendantsrsquo

customersrsquo funds or other assets and will be unjustly enriched if it is not required to

disgorge the assets or the value of benefits received as a result of Defendantsrsquo

unlawful acts or practices

50 By reason of the foregoing Relief Defendant Noel holds funds and

assets in constructive trust for the benefit of Defendantsrsquo customers

CONSUMER INJURY

51 Consumers have suffered and will continue to suffer substantial injury

as a result of Defendantsrsquo violations of the FTC Act and the TSR In addition

Defendants have been unjustly enriched as a result of their unlawful acts or

practices Absent injunctive relief by this Court Defendants are likely to continue

to injure consumers reap unjust enrichment and harm the public interest

THIS COURTrsquoS POWER TO GRANT RELIEF

52 Section 13(b) of the FTC Act 15 USC sect 53(b) empowers this Court

to grant injunctive and such other relief as the Court may deem appropriate to halt

and redress violations of any provision of law enforced by the FTC The Court in

the exercise of its equitable jurisdiction may award ancillary relief including

rescission or reformation of contracts restitution the refund of monies paid and

17

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 18 of 57 Page ID

1

2

3

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1777

the disgorgement of ill-gotten monies to prevent and remedy any violation of any

provision of law enforced by the FTC

53 Section 6(b) of the Telemarketing Act 15 USC sect 6105(b)

authorizes this Court to grant such relief as the Court finds necessary to redress

injury to consumers resulting from Defendantsrsquo violations of the TSR including

the rescission or reformation of contracts and the refund of money

PRAYER FOR RELIEF

Wherefore Plaintiff FTC pursuant to Section 13(b) of the FTC Act 15

USC sect 53(b) Section 6(b) of the Telemarketing Act 15 USC sect 6105(b) and

the Courtrsquos own equitable powers requests that the Court

A Award Plaintiff such preliminary injunctive and ancillary relief as

may be necessary to avert the likelihood of consumer injury during

the pendency of this action and to preserve the possibility of effective

final relief including but not limited to temporary and preliminary

injunctions orders freezing assets immediate access to business

premises appointment of a receiver and expedited discovery

B Enter a permanent injunction to prevent future violations of the FTC

Act and the TSR

C Award such relief as the Court finds necessary to redress injury to

consumers resulting from Defendantsrsquo violations of the FTC Act and

the TSR including but not limited to rescission or reformation of

contracts restitution the refund of monies paid and the disgorgement

of ill-gotten monies

D Enter an order requiring Relief Defendant to disgorge all funds and

assets or the value of the benefit it received from the funds and assets

which are traceable to funds obtained from Defendantsrsquo customers

through the unlawful acts or practices described herein and

18

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 19 of 57 Page ID 1778

2

3

E Award Plaintiff the costs of bringing this action as well as such other

and additional relief as the Court may determine to be just and proper

Dated February 5 2019

Respectfully submitted

ALDEN F ABBOTT General Counsel

JosaSMillard Brian M Welke middot Barbara Chun (Local Counsel) Attorneys for Plaintiff FEDERAL TRADE COMMISSION

4

5

6

7

8

9

10

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12

13

14

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16

17

18

19

20

21

22

23

24

25

26

27

28

19

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 20 of 57 Page ID 1779

EXHIBIT A

Attachment A

Free Assessment

Our expercs will lt1ssPss you cun ent

swclent lo n program and decermn which progr ms are

avc11l bl rn yoL11 situation We wi I help you cl11cic1e which progr m r1

help you achieve your goals Call us today

Service Guarantee We are commmecl to 11-1 111g

CllStomers get low r rc1ces ancl monthly payments and we w1I

m ke the pror~ss se mless and s r11ghtforwc1rd ou wi ll be sansf1ed

with our service ml OLlr

cornmcmem to you success Thars ow gu~ ancee

Success Rate Ou1 96 ~ surcPss r a e s 11e of he

cop I a ings tn he industry Olr

process has beer tested nd Olli

succ ss r r~ prowbull~ tn t it works

We c n ll~lp yo reduce and -1111ph y our p ~ymP1 ts Call us today

FTC-AID-1

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 21 of 57 Page ID 1780

20

Exhibit A

ABOUT US

We can help you reduce and simplify your pay1ncnts Contact one of our specialists today for

a free evaluation

111middot 1_I 1

101

t I 11111 I I

Itbull 11

Ill fl I I

bull ~ 0 I

What Makes Us Great fa1(li1-_~ tur1ent ~e11ef 11as a taf- o~middot tt a middotel elt1)rns bullJn st1ncb110

1middot1ep yriJ Tibullmiddotest fi 1e-ndly f3ce~ 113ve eirej e1tc-nsve1yr =inj ire

fanih1~1 bull11iu1 ti~e nul~nce~ cfscrvern rrent Cdid p11vate stucre11

l1J1ns Th~y viill u~e Ui5 epe tise o loik jUl fJ ycur ~Je~t

i(tres~- f)LH ~U(CtS~ ~HE 1h-~ I lSllt of i_r middotDff ancl iur

C ur ~r_(J~l 1o~w- JCl11~crs f(middotil) 3 00Vtli ~tJegy o r ~dUC2 011i

a1r1plfy yliur- - _Je1middott middotcar payr1t11s 1) Asstrnlins Itle ~atl1t1

2) R~~ear c1-1ng Our st~lff wmiddoti11 (lrJUi~oleaerick ]ll fnfcnTnati(-n befort dtmiddoteJPlr~ t tne ri~n 3) rnnk1middotgbullle i_i1 i e~ear (rr i~ ormiddot1 1 1 etc 1Ne

irvi-s t1ga~ii 111 ps~ib le a~irst 1n(t aptlbull~n 4) 1Nr1 ting VVF p1 eiv lii J 11 iUen u tt-igy IJefore vie Uke ut1c-1l i)ecius~ you d-ese11e 11) undi r~~anci

Lhe pr 1cer S) ~ev1sing Al)ng ~r 1udent Relief 1- 1otT11111tt bull) ti) ci e1H1ve ut-l-~n~-l)O c111 i ri 3 Vbulle -~11 leave n1) sti bull1e u11t111 neltl tecause middot~ve

11~1ve your be~ i1~ t~rest 1t l1ein 6) Si~tcl11ng Our note- =1nd r~c)1 ~ ~1 e thorou~ll ln(I pru1ile 1 ceJ1 po cri1~ 1)f vo111 ~1tuJticn s) iny if-oi

~xpe1 t- 01 eou pped to s~1ty1J_J bullVi r you1 c si- 7) De-gn1ng _ fe ~1 t 1nelt--1- f1ts ti 1middotV 1middotid de~ 1middot1 1 st1 iegy to fit ou 1 1_i dque jtct1in so

011 c111 i Jle y1)u1 1vv1middot1 per feet -ut1e-s ~~0 1 v

1bullVlly 1100~e At(J1n~ Sltl(ltnt Fie11e7) (i1_d aclol~Or~ bull -ii~ (1Ualiftel lci ~~~ISt~h 1noie ype-s middotif JS~iSi_ance u~211 Cd ( (11)itXS i1 jG(l1~t) to ti-tgt

p ~n~ 1not con1p n1es can 11i1p bullbullllh ve )t ~ ~qu1pptCI to bull-bullGr k 1bullv1t1middot1 r~ 11t-2 [uo emiddot 1 lc1 r1s ~~nCI cn even iner-1ne frmiddot tt1e c ~e of 1l~e

~1lt ntslmiddoturelt A1cl1rg Sudent Fie1ef 1middot cis mmiddote to )fe 11d we offe1 t with middotmiddot1eltbullbe 1es nI 3 rncney lock guMai-itee

We Have Been Featured In

FTC-AID-2

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 22 of 57 Page ID 1781

21

Exhibit A

SERVICES Wt w gtL

Loan Forgiveness Income Based Payments Loan Consol idation In some cases individuals with A period of financial hardship may You may be able to combine

Fede1middota1 Student Loans may qualify qualify you for an Income Based nultiple federal student loans into to have a portion of the amount Repayment Plan In many cases this one new loan w ith a lower more

owed may be forgiven This means means you pay nothing Unlike a affordable monthly payment Loan

your principal balnce coulcl be defe1 ment the term on your loan consolidation prngrams can l1elp

significantly reduced and you will continues to reduce while the plan is you qualify for additional programs not be expected to repay the in place Your term could reduce like loan forgiveness programs or

forgiven amount while you pay nothing Public Setvice Loan Forgiveness

a III

Private Sector Loan Forgiveness

If you work for a government

organization at a city state or

federa l level you may qualify for tle

PL1blic Service Loan Forgiveness

program To qualify your loans

must be cotisolidated into a specific

repayment plan The balance on

your federai student loans is

forgiven after 120 qualifying

bull C Permanent Disability

Forgivenness If your disability is expected to last

60 months or more you may qualify

for permanent disability forgiveness

Q1alifying for Permnent Disability

Forgiveness requires a visi t to your

doctor and individL1als enrolled in

the program are subject to three

years of post-discharge monitoring

Wage Garnishment Prevention

Federal law requires that the

Department of Education or a

gua1middotanty agency notify you before

111st1tuting wage garnishment You

have tl1e right to a hearing where

you can challenge the stated

amount owed and negotiate the

terms of the repayment scheclule

We can intervene on YOL1PflJl~1D-3

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 23 of 57 Page ID 1782

22

Exhibit A

payments have been made p1middotevent wage gampnishments

A FEW STATISTICS ABOUT STUDENT LOAN CRISIS

12 Trillion National Student Debt I he nitionil student loin debt is

now 17 trillion dollirs 1 trillion of

these are in federil student loans

Let us help you through this national

crisis Cill today for a free

evaluation

40 Million Students with Debt

In 7014 an estimated 40 million

current and former students were in

debt because of student loans If

you are one of the millions of people

struggling to pay student loans

Aiding Student Relief is here to help

$33000 Average Student Debt

The graduating class of 7014

average $33000 of student loan

debt per person Thats $3000 more

than the average in 2013 Dont be

one of the many Let Aiding Student

Relief advocate for you

Aiding Student Relief has helped cmrnllcss 1woplc reduce their student debt_ Their proven business

plan has led lo one of lhc highest s11cclSS raCs in the inltl11slly

John Standiford Associated

FTC-AID-4

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 24 of 57 Page ID 1783

23

Exhibit A

TESTIMONIALS

Til~nks to Aiding Student Rel ief Im middotI middotva ove1vvhelrnecl but Aiding The expemiddotts at l1icl i11g Student Rel ief

s1v ing $250 per month Strrd r~rt Relief expl~ inecl the were ther~ to help me when I process ancl rnacle everytl1ing cle11middot nelclecl 1t rw)s t

and sirnple

I Michael Ma 1in

Entrep e11eu1 Em iiy Jallo1 Ii Pa ul Ch is tia I1se11

Teacher Nurse

With so many programs I didnt middotconso lrclating my loans into one I love my Job but vith my high

know what was ng ht for me My monthly payment hs made life student loan payment was still

sruclent loan aclvsor walked me si1nple1 Now I can focus on 1Nhn bamiddotely getting by I don t kn ow what I

through my optio ns rnd now Imiddotn matters to me would hwe clone wthout Aiding

saving 54 I 11n1omh Stucie1middott Rel refmiddot

Ariel Hemiquez Sales co)SUltant

Stephani Seland-1 Small Busim~ss Owner

AJ 01en Museum Curator

RECENT NEWS

)lt)

o(l ttDrlTI -5

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 25 of 57 Page ID 1784

24

Exhibit A

Student Debt Crisis Business Latest Debt Collective Demands May be largely about smallest Student

borrnwers US News amp World Loan Crisis is fa frorn ove The Debt Collective is a group of Report-May 162015 last month Two new reports suggest the college students calling the Fedemiddotal Reserve Bank of New student loan crisis is easing them-se1ves the Corinthian York repor ced that stuclent loan somewhat as the economy Fifteen who are refusing to pay balances rose to 16 trillio n and improves but the crisis is far back their student loins As pa t that 113 per cent of that is in from ove the College Board of this effort the Debt Collective repo t~ tot31 borrowing fell by 8 has written an open lette to the pEbull1 cent between 2012-13 and Department of Education f l llJ 20 13-14 The organization

About Us 11 1 i~d1middot1r F th~~- h1~ ff t1middot~11middot=cl =i~=middott- 1middot __31middotmiddotIIgt middot bullmiddot11

middot- I ( )ntir il t l~i -r_il fr~~

Address bull middot tc1ltj-1r_ =i ~

middot l t1~t 1middot1 fcJ middot~_1 1 I l11 - Hbull 1 tr

~t (~~ 1 12bull~11 T 1 1- - 8555105400

FTC-AID-6

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 26 of 57 Page ID 1785

25

Exhibit A

f - g+ in O) ~ PRIVACY POLICY

This privacy statement discloses the privacy practices for AidllII Student Relief Because Aiding Studen Relief wonts to demonstrate ts firm commlcmell to your

privacy Aiding Sudent Relief hes greed to disclose ls 1rifor111atlori g1thering and dlssem1n1t1on prct1cts Aidlns Studtrit Relief will notify you of

INFORMATION COLLECTION At-ID USE

Aiding Student Relief is the sole owner of the rformMlon collected on this site We will not sell shire or rent this information 10 others In way different from what Is

disclosed 1n this statement Aldln1 StudeM Relief collects 1nform111on throuah this site from our prospective end existing clients at several different poin on our web

site We use their contact Informii on to send information bout our company and to service exsMs accounts Users may optbullout of rece11ns future malllngs see the

cholceoptbullout section below Contect and Financial information that 1s collected Is used for verifying your name address and other informa1on as well as to boll you for

your use of our Gerv1ces using Information from third party sourcH Information about your computer hardwre and software Is automatically collected by Aiding

Student Relief and may be shared in asgregate with third parties whose services are used for traffic analysis purposes This Ir formation includes your IP address

browser type domain names access times and referring Web site addresses Ths information is no tied to personally Identifiable Information This 1nformatlor s used

by Aiding Student Relief to malMan no Improve the quality of the Hrvct and to senerae statistics resardlng use of he Aiding Student Relief site We use third party

services to bill for serlces and to provide other services like our Live Help chat We store the transcripts from these chats for customer service Improvement These

third party service providers are not permitted to use your infornon for any secondary purposes

Thank you and cheers

FTC-AID-7

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 27 of 57 Page ID 1786

26

Exhibit A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 28 of 57 Page ID 1787

EXHIBIT B

Attachment A

((

z | ~

AIDINGSTUDENTRELIEF

bull bull bull bull bull

13 deg $ $ampdegdeg deg() ˝ amp $$deg( + -+Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 29 of 57 Page ID 1788

bulldaggerDagger Daggermdashndash Daggerhellip ƒfrasl hellip lsaquorsaquobullminuspermilminushellip bdquolsaquoldquo rsaquordquobulllsquo fraslbullrsquopermillsaquofraslpermilminushellip sbquo

4556789fADlt=gtA9BCAD

DZgtA=EFGHIJFKLMNOPFQOGFHIQRSTLKSUMMNOPLHMTFIVRWXHKKNIFNUNOPRLFGSHKSRVRVNQ

f e=klHMW

9SI]UQMSNSOQOHHPFK YaSTHHVVJFMHcVGNOJVHHFKKPSUHMLIUOQN_PL[KSVFGJPRSDTHRFPLIP=SNDC==GFdFIP9VaNHQTWSRPbHF_PSKSVNMPMHNIO XNNIIFRKNF7IKSQQMHFNDVPOS9IAeTHPdKSUMMFNKHONP 8aF_KSNVPHTNIMNR[POVFgNPTHLNHIgtMFI YTFHIdFFI D9aHVR_KNKHFHIWIQOTHIQbFFP

lt=Dkgt=L]oHUKMMH ihTFNIORI THHVPRFMVKgtNJ_NFFbIVSJI]IFjdGGVNNN lt=TFKPPNF 9DaFGmVHPGRJMFNNQOSGnPFFTNLUNHPMIMTFVNJOKMIWV

27

]UMNOHPFRKNVSHKKISIRWRrGZNJONgtNjTHKHMI=cQgtORHVPKSOUMddUNKSPIdspNVPNq_ lt=gtBTHFHPb=HFILGFHMt DTFuFIUVFRPNTFIMINVWOPRVOQFIV sFQFPHKKH vaIPNFVcSyOFSPRFMRNVOJH_gtVFDVUJAN9FPwFuVFJLFHMP_VTFFdSIIVdNHUPxI=DQSROJGASHIVdDSNMINONPPaHdOHdPFHRIWVFFHdFIGM˙ 01 $2 301 $$3 ( Exhibit B

8

~ldquo

middot

676EBCEDK5ltAC]5EF_5665E7gt5lt7aFb688E588lt76B5E6F8EBAC78lt76cdddefghijhggklmknmopqprpopst u

13 deg $ $ampdegdeg degˇ amp $$deg + -+Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 30 of 57 Page ID 1789 () ( vPSZwPxyYTUZUWWzxPyxSWMZWPU|SWUWYZ~YTY~QSWbullYXRwU~UxSdaggerXQ~UZXvPSZWSOVQSYNOXPRSTUSDaggerPxXYPZPNXRUSPQZXPbullU~SOhellipUNPxyYTUZmdash zUxSZUZXndashYWShellipYYXOwPxyYTUZUWWMNOPQx~YWShellipYYXOYWUƒDaggerU|XU~XPSWXfrasllsaquoPZXRWPxPxUOPQSOVQSYNONPxDaggerUxSZUZX~YWShellipYYXONPxyYTUZUWWmdash

rsaquominus MZ|PUpermilSWUzSOUZXWbdquoDaggerUxYP~PNZSZ|YSRSx~WRYDaggerSOVQSYNOOPQNPxSZMZ|PUpermilSWU~rdquoUDaggerSOUZXzSZmdashMZSZO|SWUWXRYWUSZWOPQDaggerSOZPXRYZymdash zQhellipY|daggerUxTY|UvPSZwPxyYTUZUWWMNOPQbullPxlsquoNPxSyPTUxZUZXPxySZYrsquoSXYPZSXS|YXOWXSXUPxNU~UxSUTUOPQSOVQSYNONPxXRUzQhellipY|daggerUxTY|UvPSZwPxyYTUZUWWDaggerxPyxSmdashsbquotrade f8Ef8E78FCB6C8EŁPQSOhellipUShellipUXP|PhellipYZUQXYDaggerUNU~UxSWXQ~UZXPSZWYZXPPZUZUbullPSZbullYXRSPbullUxPxUSŒPx~ShellipUPZXRODaggerSOUZXmdashvPSZ|PZWPY~SXYPZDaggerxPyxSW|SZRUDaggerOPQVQSYNONPxS~~YXYPZSDaggerxPyxSW YlsquoU PSZ NPxyYTUZUWWDaggerxPyxSWPxzQhellipY|daggerUxTY|UvPSZwPxyYTUZUWWmdash ŠmŸŽıłŠm 57gt8A57A5B= 8E65C76B5E6F8EB5=6G

PONM[5 QRSTUVQU PYXWZW lt4556789588lt959=lt CD lt H5FICEDJ8KA5LCD

A565E7gt57 œšžeuroiexclcentpoundyenbrvbarsectbrvbareurocopypoundsectlaquoeuropoundlaquobrvbarlaquoregplusmncentbrvbareurocent microparalaquo europoundž raquoY|frac14frac12 plusmncurrenRSUraquoSxXYZeuropoundlaquo laquoeurolaquoordf frac34

^ ˙ ( (

28

Attachment A

01 $2 301 $$3 ( Exhibit B

()(

=4ABC9DEAFBD=FGFHIJKLMJNOMN MRNS mn = nrst = svzhellipu t bulltvDaggerrhellipDaggerurbullbulltuhellipv hellipz~ bullmdashldquordquolsquorsquotrade š oŒŠeuro centpound ` umluml 13 deg $ $ampdegdeg degˇ amp $$deg + -+Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 31 of 57 Page ID 1790

ISNRTUKQINKKNNKL[MRJ PUWQI]MRM qyt|tytzxy rsaquoqNfraslbdquoPUhellipsbquoLUyQhellip rfraslbhellipMNSIKVUQ QNJKvUQsMiexclQQJUx[iexcliexcl_vsect_Qyenyenbrvbarbrvbar uSSRNTPL_LUUMKIaJ_WMIJJKVIONNQJJMWRMIIbQQURKLWIIJQbKLUNKMPTMNQQ_KKRY tbullbulldaggersDaggerv~vhellipmdashryrhellip~mdashrhellipDagger ŸLŽUıQŽbłpermilMtradeœsbquoNtrade_ffRŁyISMŒUQWyNUQŠlsaquo rv45657896lt7ltgt5lt PQKLMIQSNRTUKINQVNOOMVKMWNQKLIJPMXJIKMYZMPIOO NJMOOJLURMNRRMKKLIJ klltko ltgtlt85p5gt5 ouvwxrz ^^ ~ minuspermil tffŁ yenpoundpound KNOWDaggerIreggt4lt97ltndash9ƒ Dagger hellipDaggerlsaquo žko74k57ƒ ƒISNcurrenUIWIbJKWMKJYVNTKM KLONNRqIQQSNNRTUKINQQIJ_JMWNQKLIJJJPMXJIKMcOMUJMVNQKUVK_JUKBHdefABCgDEAFBDghidjlaquopoundbrvbariexclnotvIWIQbDaggerK_WMQKbullMOIMSvOObullIbLKJbullMJMRMW ordf copy

01( $2(301$$3( Exhibit B

29

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 32 of 57 Page ID 1791

EXHIBIT C

Attachment A

~ 111 ~tampi 10 11 ~bull ia1111

Something awesome is coming soon We are buildin somethin ve cool Sta tuned and be at1ent Your atience will be well aid

~lbullrbullUiUffl We can help you reduce and simplify your payments

101 Loan For iveness

1~u 0 (middottmiddotbullmiddotmiddot1 1~=I -- _~

HZamp IMUliULlampRampatiEUWi nmiddot middot-il~ fr middot 8rbullbullrcrr-

_J l _ 1 _f _ur -~t~ u L liYu

~ Income Based Pa ents

bull ~ f I - - I - I - ri u ~u-=lf ~ JU

1-bullA ---rc iM1~~ -~-bullCiel rrcl

~- middot IY 2 i C middot middotJ ll1Jmiddot 0 _ middot_middotIr i

~ LdfiJIMifJ11JJMJllfFffi

middotE-ltecl l2bullJbull iequbullt t11cit t1lt2 CtpCr~middot1e- f

JJd r g-_iraE-1 agltr-middot- ntimiddot middot)middotou

tmiddot_rt- i ic l~1ri ~rbullmiddot middot111~ umiddot -_ d_t-c

fsectmet-Naibullfyen1~poundibllffifftmI

I f-nle Vnot Nune

I ampterYOllrEmall ]

1 ~~~~ 1

If -bull 13n ~Cbull t~middot rct1~j d- gtOY- - hO- irmiddot (bulldbull) plltmiddotmiddot- leemiddotmiddot JOu

1r1cbullmiddotn111f11ri ll1fbull fcrn to ~bull~I

Triin- GU

WAWMyenEIRitiRpoundWt 44 ZiAtillampampI

Exhibit C

Case 818-cv-01987-JLS

-KE

S

Docum

ent 50-1 F

iled 020519 P

age 33 of 57 P

age ID 1792

30

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 34 of 57 Page ID 1793

EXHIBIT D

Attachment A

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Type then hit enter to

bull bull bull bull bull bull bull

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----

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 35 of 57 Page ID 1794

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

infoaidnestcom (800) 555-1212

HOME

ABOUT US

SERVICES

FAQ

BLOG

CONTACT

HOME ABOUT US SERVICES FAQ BLOG CONTACT

1 of 6 462018 945 AM

31

Student Loan Forgiveness Loan Consolidation Student Loan Forgiveness

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 36 of 57 Page ID 1795

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

If you have Federal Student Loans yoursquore in the right place to get those loans reduced forgiven or completely discharged through our student loan forgiveness programs

Get your multiple Federal Student Loans consolidated into one forget about increasing interests and pay month to month at the lowest possible cost

We understand if yoursquore going through some hardship and thatrsquos why with us yoursquoll be able to make monthly payments based on your affordability for as low as $000 depending on your situation

2 of 6 462018 945 AM

32

Knowledge Base

Defaulted Student Loans

Wage Garnishment

Student Loan Rehabilitation

Income Based Repayment Plan

Deferment and Forbearance

Pay As You Earn Repayment Plan

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE Call 561)424-6053 today to go over your options

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 37 of 57 Page ID 1796

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

Our knowledge base is designed to provide information regarding some of the critical topics those with student loans must be aware of to be able to make educated decisions regarding their future

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

A wage garnishment is any legal procedure in which some portion of a personrsquos earnings is required to be withheld by an employer for the payment of a debt

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

With this program your payments change as your income changes and will not be longer than 25 years This is the ideal plan if you are in partial financial hardship Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard plan

Temporarily allowing you to postpone or reduce your federal student loan payments Postponing or reducing your payments may help you avoid default and future garnishments

Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard

3 of 6 462018 945 AM

33

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 38 of 57 Page ID 1797

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

4 of 6 462018 945 AM

34Attachment A

Testimonials

Latest News

Why 2016 Will Be a Big Year For Student Loans

Top Student Loan Refinancing Questions of 2015

Oba mas latest student loan plan

Things You Should Know About Public Service Loan Forgiveness

Recent Posts

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 39 of 57 Page ID 1798

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

5 of 6 462018 945 AM

35

About Us

Contact Info

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 40 of 57 Page ID 1799

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

pay-grandchild-studen

Why 2016 Will Be a Big Year For Student Loans

December 30 2015

12511110_1112367518

Top Student Loan Refinancing Questions of 2015

December 30 2015

We stand by our consultation and quote We are so sure and confident about our services and offers that they are all 100 money back guarantee risk free ndash if we donrsquot do what we promise yoursquoll get your money back

(800) 555-1212 AidnestStudenLoansgmailcom 18100 Von Karman Ave Suite 850 Irvine CA 92612

Futero SAS copy 2015 | Aidnestcom

6 of 6 462018 945

Exhibit D 36Attachment A

AM

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 41 of 57 Page ID 1800

EXHIBIT E

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 42 of 57 Page ID 1801

AIDNEST Let us help you through this national crisis

Call one of our specialists today

Forbearance amp Deferment If you are still in school and struggling to make payments on your student loans You may qualify

for Forbearance amp Deferment

Garnishment Prevention Federal law requires that the Department of Education or guarantee agency notifies you before they

begin garnishing your wages

Loan Forgiveness If you are a teacher public service worker or an individual with total and permanent disability you

httpaidnestcom[442018 115239 AM]

37Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 43 of 57 Page ID 1802

AIDNEST Let us help you through this national crisis

may qualify for this program

Consolidating Your Loans Consolidating your loans to one new loan under one lender may lower your payments and make

your life a bit more manageable

Affordable Payments If you are looking to lower your monthly payments then Income Based Repayment Plans may be

the correct choice for you

Learn more about our services

LEARN MORE

httpaidnestcom[442018 115239 AM]

38Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 44 of 57 Page ID 1803

AIDNEST Let us help you through this national crisis

Loan Forgiveness Programs Income Based Payments Student Loan Rehabilitation

Student Loan Consolidation

You may be eligible for

Loan Forgiveness Programs

In some cases individuals with Federal Student Loans may qualify to have a portion of the amount

owed to be forgiven

Get in touch with our professional team to find out which loan forgiveness program you qualify for and

how you can get rid of your unpaid student loan

L EARN MORE

httpaidnestcom[442018 115239 AM]

39Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 45 of 57 Page ID 1804

AIDNEST Let us help you through this national crisis

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE

Meet your Budget One of our advisers will help you meet your payment goals by using your budget and timeline to

determine the best plan available

httpaidnestcom[442018 115239 AM]

40Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 46 of 57 Page ID 1805

AIDNEST Let us help you through this national crisis

Simple Process We understand that lowering your payments alone can be difficult Our intuitive platform allows us

to keep the entire process simple

Customer Satisfaction We are committed to providing you with outstanding service only We look forward to working

with you

100 money back guarantee No Hassle Money Back Policy

httpaidnestcom[442018 115239 AM]

41Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 47 of 57 Page ID 1806

AIDNEST Let us help you through this national crisis

Lower your loan payments by getting in touch with one of our professionals

We design a customized repayment plan that will allow you to make payments based on your

monthly income family size and spending Get rid of the hassle of extensive paperwork and get the

help you deserve

What we can help you achieve a lower payment or lower rate

httpaidnestcom[442018 115239 AM]

42Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 48 of 57 Page ID 1807

AIDNEST Let us help you through this national crisis

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcom[442018 115239 AM]

43Exhibit E

httpaidnestcomservices[442018 115322 AM]

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 49 of 57 Page ID 1808

Services | AIDNEST Let us help you through this national crisis

INCOME BASED PAYMENTS

If you are suffering from a financial hardship you may be eligible for an

Income Based Payment In this repayment program you would have a

payment based on your income and family size The payment could be as

low as $000 per month with forgiveness at the end of 20-25 years

44

Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 50 of 57 Page ID 1809

L E ARN MORE

LOAN FORGIVENESS

If you have Federal Student Loans you may qualify for any of the student

loan forgiveness programs that are available to borrowers You may be

eligible for principal reduction loan forgiveness or a complete loan

discharge depending on your individual circumstance

L EARN MORE

PRIVATE STUDENT LOAN CONSOLIDATION

Much like refinancing a mortgage generally the biggest benefit of private

student loan consolidationstudent loan refinancing is a lower interest rate

httpaidnestcomservices[442018 115322 AM]

45Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 51 of 57 Page ID 1810

L E ARN MORE

(something federal consolidations do not offer)

STUDENT LOAN REHABILITATION

You can renew eligibility for new loans and grants and eliminate the loan

default by ldquorehabilitatingrdquo a defaulted loan

httpaidnestcomservices[442018 115322 AM]

46Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 52 of 57 Page ID 1811

CHE CK E L E G I B I L I T Y

WAGE GARNISHMENT

A wage garnishment is any legal procedure in which some portion of a

personrsquos earnings is required to be withheld by an employer for the

payment of a debt

L EARN MORE

With our fast friendly and professional services wersquoll be glad to help you get your student loans

reduced forgiven or completely discharged To this end wersquoll assist you in consolidating all your

student loans so yoursquoll have only one lender and yoursquoll start making one monthly payment Our

professionals will walk you through the best and most flexible repayment options and if itrsquos also

necessary varied deferment options and rehabilitation programs

httpaidnestcomservices[442018 115322 AM]

47Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 53 of 57 Page ID 1812

Services | AIDNEST Let us help you through this national crisis

Our CRM System

Our CRM is one of the most advanced in the industry and most importantly itrsquos linked directly to

the Department of Education (DOE) This keeps your personal and most confidential information

safe Furthermore because our CRM system is linked to the DOE our approval is 100 Through

our CRM we will be doing continuous monitoring of our process without losing sight of your

immediate needs ensuring that your case has the proper handling and most efficient process

httpaidnestcomservices[442018 115322 AM]

48Exhibit E

n

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 54 of 57 Page ID 1813

Services | AIDNEST Let us help you through this national crisis

R ECENT POSTS

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

ABOUT US

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcomservices[442018 115322 AM]

49Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 55 of 57 Page ID 1814

EXHIBIT F

s -

bullmiddot - ~ t ~ower Your Student Loan Pay~e~ts oday -- Students Helping Students Save Money

INCOME BASED PAJIIIJITPAIS

I C(gttoUC1 u~

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 56 of 57 Page ID 1815

X + C (D Not secure wwwstudoracom 0

CALL US NOW (85S) 978-S599 middot 1nfostudoracom

HOME SERVICES ABOUT US FAQ CONTACT US BLOC PRIVACY

Offering obligation and commitment free loan relief solutions

STUDENT LOAN FORGIVENESS INCOME BASED PAYMENTS LOAN CONSOLIDATION

We11 help you get your loans reduced forgiven o r Make monthly pdyments based on your affordability Get multiple Federal Student Loans consolidated into

discharged one low monthly payment

Talk to our experts concerning your

student loans

Studora is a pnvatefy owned company that helps consumers like you identify

government programs that fit your financial s1tuat1on Our loan experts will assist you in selecting the appropriate programs that WOltk with your income family size and

desired monthly payment We then prepare the appropriate documents for your review and submission All this f o r one low easy payment

Testimonials

Thank you f o r getting back to me quickly Youve been fabulous Thank you for the confirmation and for your help today Pass

during this whole process Is there a place I can go online that I this on to your sup that you were very professional and very

can leave a comment for your manager Youve made this Robert helpful and brought a sense of relief for me Thank you very

process so easy and answered every question my husband and I much and have a great rest of your day Kudos to you and your

have had teammoneywell spenL

Exhibit F 50

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 57 of 57 Page ID 1816

Services we offer

Stud ora offers document preparation services for all loan forgiveness consolidation and relief services to people who are unable to manage their finances Our mam aim is to

offer complete peace of mind to indiVidual unable to pay their student loan debt

we otter the folloWing document preparation services with complete professional assistance

amFinancial Review ffl Budget Planning

Toe first step to creating a flexible loan repayment plan is financial review we also help create a personal finance plan to ensure that you are able to

Our professmnals will look into your finances and design a custom manage your monthly budget in the most effective way This plan will keep

repayment plan that is affordable and easy to manage your spending to the minimum alloWing you to save more money for loan

repayment

Permanent Disability Forgiveness r-trTeacher Loan Forgiveness (5 You can get rid of your Federal Student Loan if you are permanently disabled Good news for teachers who are under the weight of a massiVe loan You can

now get $17 forgiven on your student loans

Public Service Loan Forgiveness Custom Debt Relief Plans

Want assistance with debt relief Get in touch with our experts who will help If you are a public service agent you can get rid of your loan after 120 days of design a loan repayment and relief plan for you based on your monthly

income and affordability payments

THERE ARE NO OBLIGATIONS OR COMMITMENTS

want to save thousands of dollars Fill out our form and get relief from your student loan for a more

peaceful tomorrow

Your Name

BiHHHi

Exhibit F 51

Attachment A

Page 8: JOSHUA S. MILLARD, BRIAN M. WELKE, pro hac vice · for which it has no legitimate claim. Noel is a Wyoming limited liability company that reported in a public document that its principal

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 8 of 57 Page ID

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1767

federal student loan or to the educational services for which the loan was provided

20 Other forgiveness programs require borrowers to work in certain

professions for a period of years For example Teacher Loan Forgiveness applies

to teachers who have worked full-time for five years in a low-income elementary

or secondary school or educational service agency Public Service Loan

Forgiveness (ldquoPSLFrdquo) applies to employees of governmental units or non-profit

organizations who make timely monthly payments for a period of ten years while

employed in the public sector

21 The federal government also offers loan forgiveness through income-

driven repayment (ldquoIDRrdquo) programs that enable borrowers to reduce their monthly

payments and have portions of their loans forgiven IDR programs allow eligible

borrowers to limit their monthly payments based on a percentage of their

discretionary monthly income To remain in an IDR program borrowers must

recertify their income and family size annually Obtaining forgiveness through

IDR programs requires a minimum of 20 or 25 years of qualifying payments

depending on whether borrowers received their first loans on July 1 2014 or

before that date Because a borrowerrsquos income is likely to fluctuate over the life of

the loan monthly payments under the IDR programs can vary considerably from

year to year If a borrowerrsquos income were to increase over the repayment period

for example the monthly payment amount could correspondingly increase to the

point where those payments would pay off the loan before any amount could be

forgiven at the end of the repayment term No loans have been forgiven yet under

any of the IDR programs because the programs have not existed long enough for

borrowers to make the minimum number of years of qualifying payments

22 Consumers can apply for BDR PSLF IDR and other loan repayment

and forgiveness or discharge programs through USDE or their student loan

servicers at no cost these programs do not require the assistance of a third-party

8

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 9 of 57 Page ID

1

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1768

company or payment of application fees

23 USDE will grant forbearance while processing applications for an

alternative repayment plan and in some cases of hardship During forbearance

unpaid interest is added to the principal balance

Defendantsrsquo Deceptive Marketing of Student Loan Debt Relief Services

24 To lure consumers into purchasing their purported student loan debt

relief services Defendants have made false promises to eliminate or reduce

consumersrsquo student loan balances or monthly payments through loan forgiveness

or other programs

25 To induce consumers to purchase their purported student loan debt

relief services Defendants have disseminated websites such as aidingstudentscom

aidnestcom and studoracom including but not necessarily limited to the

attached exhibits A through F Defendantsrsquo websites have contained the following

statements among others

Free Assessment

Our experts will assess your current student loan program and determine

which programs are available in your

situation We will help you decide which

program can help you achieve your goals Call

us today

Service Guarantee

We are committed to helping customers get

lower rates and monthly payments and we will

make the process seamless and

straightforward You will be satisfied with our

service and our commitment to your success Thatrsquos our

guarantee

Ex A at 1 (aidingstudentscom 2015)

9

Success Rate

Our 96 success rate is one of the top ratings in

the industry Our process has been tested and our

success rate proves that it works We can help you reduce and simplify your payments Call us today

Attachment A

----------

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 10 of 57 Page ID

1

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22

23

24

25

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28

1769

ldquoWe can help you reduce and simplify your payments Contact one of our specialists today for a free evaluationrdquo

Ex A at 2 (emphasis in original)

ldquolsquoAiding Student Relief has helped countless people reduce their student debt Their proven business plan has led to one of the highest success rates in the industryrsquordquo

Ex A at 4

100 Customer Satisfaction We can help you reduce and simplify your payments Call one of our specialists

today

Ex B at 1 (aidingstudentscom 2016) (emphasis in original)

Meet some of our members who have saved big on their student loan debt Helping You Save Big

ldquoThanks to Aiding Student Relief I am savings [sic] $250 per monthrdquo Michael Martin Entrepreneur

Ex B at 2 (emphasis in original)

ldquoWe can help you reduce and simplify your payments rdquo

Ex C at 1 (aidingstudentscom 2018) (emphasis in original)

Student Loan

Forgiveness

If you have Federal Student Loans yoursquore in the right place to get those

Loan Forgiveness

Get your multiple Federal Student Loans consolidated into one

10

Student Loan

Forgiveness

We understand if yoursquore going through some hardship and thatrsquos why

Attachment A

Case 818-cv-01987-JLS-KES

1

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28

Document 50-1 Filed 020519 Page 11 of 57 Page ID 1770

loans reduced forgiven or completely discharged through our student loan forgiveness programs

forget about increasing interests [sic] and pay month to month at the lowest possible cost

with us yoursquoll be able to make monthly payments based on your affordability for as low as $000 depending on your situation

Ex D at 2 (aidnestcom 2016)

Lower your loan payments by getting in touch with one of our professionals We design a customized repayment plan that will allow you to make payments based on your monthly income family size and spending Get rid of the hassle of extensive paperwork and get the help you deserve

What we can help you achieve [is] a lower payment or lower rate

Ex E at 6 (aidnestcom 2018) (emphasis in original)

STUDENT LOAN FORGIVENESS

Wersquoll help you get your loans reduced forgiven or

discharged

INCOME BASED PAYMENTS

Make monthly payments based on your affordability

LOAN CONSOLIDATION

Get multiple Federal Student Loans

consolidated into one low monthly payment

Ex F at 1 (studoracom 2018) (emphasis in original)

26 In some instances consumers view the Defendantsrsquo online advertising

and call Defendantsrsquo telemarketers for more information Defendants also make

outbound telemarketing calls and send texts to consumers to offer their services

and convince student loan borrowers to sign up for Defendantsrsquo debt relief

services

11

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 12 of 57 Page ID

1

2

3

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1771

27 In calls with consumers Defendantsrsquo telemarketers have told

consumers that Defendants can cause consumersrsquo student loan balances to be

reduced or that consumersrsquo loan balances would be forgiven after making lower

monthly payments Defendantsrsquo telemarketers have told some consumers that over

half their loan balance would be forgiven Moreover Defendantsrsquo telemarketers

have told some consumers that their loan payments could or would be rapidly

reduced to $19 per month or promptly forgiven

28 Defendants have made other representations concerning loan

reduction or forgiveness to consumers in telemarketing their debt relief services

For example Defendantsrsquo telemarketers have told one or more consumers that

ldquofamily sizerdquo a metric for determining the amount borrowers pay each month

under IDR plans includes ldquoanyone you help out throughout the year[] they donrsquot

have to live with yourdquo even claiming that helping with ldquogas money three times

out of the yearrdquo is enough to include a person in ldquofamily sizerdquo Further

Defendantsrsquo telemarketers have offered one or more consumers ldquobasically a

guarantee to remainrdquo in an IDR plan and warned one or more consumers that

signing up for an IDR plan with a lender instead would result in a higher loan

payment

29 Defendants have not been likely to achieve the lower monthly

payments or student loan forgiveness they have advertised marketed and

promoted to consumers In many instances Defendants have failed to obtain the

promised lower monthly payments or student loan forgiveness

30 Defendants have charged consumers fees for purported debt relief

services before achieving lower monthly payments or student loan forgiveness

and in many instances have failed to achieve those results at all on behalf of

consumers

12

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 13 of 57 Page ID

1

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28

1772

31 Defendantsrsquo telemarketers have sought and obtained consumersrsquo

payment information by phone or the Internet

32 Defendantsrsquo total advance fees typically have been in the range of

$300-500 Defendants also have charged consumers recurring monthly fees for

purported debt relief services typically charging $19 per month

THE FTC ACT

33 Section 5(a) of the FTC Act 15 USC sect 45(a) prohibits ldquounfair or

deceptive acts or practices in or affecting commercerdquo

34 Misrepresentations or deceptive omissions of material fact constitute

deceptive acts or practices prohibited by Section 5(a) of the FTC Act

VIOLATIONS OF THE FTC ACT

Count One

(Deceptive Student Loan Debt Relief Representations)

35 In numerous instances in connection with the advertising marketing

promotion offering for sale or sale of student loan debt relief services Defendants

have represented directly or indirectly expressly or by implication that consumers

who purchase Defendantsrsquo debt relief services will or likely will have their

monthly payments reduced or their loan balances forgiven in whole or in part

36 In truth and in fact in numerous instances in which Defendants have

made the representations set forth in Paragraph 35 of this Complaint such

representations were false or not substantiated at the time Defendants made them

37 Therefore Defendantsrsquo representations as set forth in Paragraph 35 of

this Complaint are false or misleading and constitute deceptive acts or practices in

violation of Section 5(a) of the FTC Act 15 USC sect 45(a)

THE TELEMARKETING SALES RULE

38 Congress directed the FTC to prescribe rules prohibiting abusive and

deceptive telemarketing acts or practices pursuant to the Telemarketing Act 15

13

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 14 of 57 Page ID

1

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24

25

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28

1773

USC sectsect 6101-6108 in 1994 The FTC adopted the original TSR in 1995

extensively amended it in 2003 and amended certain sections thereafter 16

CFR Part 310

39 Defendants are ldquoseller[s]rdquo or ldquotelemarketer[s]rdquo engaged in

ldquotelemarketingrdquo as defined by the TSR 16 CFR sect 3102(dd) (ff) and (gg) A

ldquosellerrdquo means any person who in connection with a telemarketing transaction

provides offers to provide or arranges for others to provide goods or services to a

customer in exchange for consideration 16 CFR sect 3102(dd) A ldquotelemarketerrdquo

means any person who in connection with telemarketing initiates or receives

telephone calls to or from a customer or donor 16 CFR sect 3102(ff)

ldquoTelemarketingrdquo means a plan program or campaign which is conducted to

induce the purchase of goods or services or a charitable contribution by use of one

or more telephones and which involves more than one interstate telephone call 16

CFR sect 3102(gg)

40 Defendants are sellers or telemarketers of ldquodebt relief servicesrdquo as

defined by the TSR 16 CFR sect 3102(o) Under the TSR a ldquodebt relief servicerdquo

means any program or service represented directly or by implication to

renegotiate settle or in any way alter the terms of payment or other terms of the

debt between a person and one or more unsecured creditors or debt collectors

including but not limited to a reduction in the balance interest rate or fees owed

by a person to an unsecured creditor or debt collector 16 CFR sect 3102(o)

41 The TSR prohibits sellers and telemarketers from requesting or

receiving payment of any fees or consideration for any debt relief service until and

unless

a The seller or telemarketer has renegotiated settled reduced or

otherwise altered the terms of at least one debt pursuant to a

14

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 15 of 57 Page ID

1

2

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1774

settlement agreement debt management plan or other such

valid contractual agreement executed by the customer and

b The customer has made at least one payment pursuant to that

settlement agreement debt management plan or other valid

contractual agreement between the customer and the creditor

and

c To the extent that debts enrolled in a service are renegotiated

settled reduced or otherwise altered individually the fee or

consideration either

i Bears the same proportional relationship to the total fee

for renegotiating settling reducing or altering the terms

of the entire debt balance as the individual debt amount

bears to the entire debt amount The individual debt

amount and the entire debt amount are those owed at the

time the debt was enrolled in the service or

ii Is a percentage of the amount saved as a result of the

renegotiation settlement reduction or alteration The

percentage charged cannot change from one individual

debt to another The amount saved is the difference

between the amount owed at the time the debt was

enrolled in the service and the amount actually paid to

satisfy the debt 16 CFR sect 3104(a)(5)(i)

42 The TSR prohibits sellers and telemarketers from misrepresenting

directly or by implication any material aspect of any debt relief service including

but not limited to the amount of money or the percentage of the debt amount that a

customer may save by using the service 16 CFR sect 3103(a)(2)(x)

15

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 16 of 57 Page ID

1

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23

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28

1775

43 Pursuant to Section 3(c) of the Telemarketing Act 15 USC

sect 6102(c) and Section 18(d)(3) of the FTC Act 15 USC sect 57a(d)(3) a violation

of the TSR constitutes an unfair or deceptive act or practice in or affecting

commerce in violation of Section 5(a) of the FTC Act 15 USC sect 45(a)

VIOLATIONS OF THE TELEMARKETING SALES RULE

Count Two

(Advance Fee for Debt Relief Services)

44 In numerous instances in connection with the telemarketing of

student loan debt relief services Defendants have requested or received payment

of a fee or consideration for debt relief services before

a Defendants have renegotiated settled reduced or otherwise

altered the terms of at least one debt pursuant to a settlement

agreement debt management plan or other such valid contractual

agreement executed by the customer and

b The customer has made at least one payment pursuant to that

settlement agreement debt management plan or other valid

contractual agreement between the customer and the creditor

45 Defendantsrsquo acts or practices as described in Paragraph 44 of this

Complaint are abusive telemarketing acts or practices that violate Section

3104(a)(5)(i) of the TSR 16 CFR sect 3104(a)(5)(i)

Count Three

(Material Debt Relief Misrepresentations)

46 In numerous instances in connection with the telemarketing of

student loan debt relief services Defendants have misrepresented directly or

indirectly expressly or by implication material aspects of their debt relief services

including but not limited to that consumers who purchase Defendantsrsquo debt relief

services will or likely will have their monthly payments reduced or their loan

16

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 17 of 57 Page ID

1

2

3

4

5

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19

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28

1776

balances forgiven in whole or in part

47 Defendantsrsquo acts and practices as described in Paragraph 46 of this

Complaint are deceptive telemarketing acts or practices that violate Section

3103(a)(2)(x) of the TSR 16 CFR sect 3103(a)(2)(x)

Count Four

(Disgorgement of Ill-Gotten Gains of Relief Defendant)

48 Relief Defendant Noel has received directly or indirectly funds or

other assets from Defendants that are traceable to funds obtained from Defendantsrsquo

customers through the unlawful acts or practices described herein

49 Relief Defendant Noel has no legitimate claim to Defendantsrsquo

customersrsquo funds or other assets and will be unjustly enriched if it is not required to

disgorge the assets or the value of benefits received as a result of Defendantsrsquo

unlawful acts or practices

50 By reason of the foregoing Relief Defendant Noel holds funds and

assets in constructive trust for the benefit of Defendantsrsquo customers

CONSUMER INJURY

51 Consumers have suffered and will continue to suffer substantial injury

as a result of Defendantsrsquo violations of the FTC Act and the TSR In addition

Defendants have been unjustly enriched as a result of their unlawful acts or

practices Absent injunctive relief by this Court Defendants are likely to continue

to injure consumers reap unjust enrichment and harm the public interest

THIS COURTrsquoS POWER TO GRANT RELIEF

52 Section 13(b) of the FTC Act 15 USC sect 53(b) empowers this Court

to grant injunctive and such other relief as the Court may deem appropriate to halt

and redress violations of any provision of law enforced by the FTC The Court in

the exercise of its equitable jurisdiction may award ancillary relief including

rescission or reformation of contracts restitution the refund of monies paid and

17

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 18 of 57 Page ID

1

2

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24

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1777

the disgorgement of ill-gotten monies to prevent and remedy any violation of any

provision of law enforced by the FTC

53 Section 6(b) of the Telemarketing Act 15 USC sect 6105(b)

authorizes this Court to grant such relief as the Court finds necessary to redress

injury to consumers resulting from Defendantsrsquo violations of the TSR including

the rescission or reformation of contracts and the refund of money

PRAYER FOR RELIEF

Wherefore Plaintiff FTC pursuant to Section 13(b) of the FTC Act 15

USC sect 53(b) Section 6(b) of the Telemarketing Act 15 USC sect 6105(b) and

the Courtrsquos own equitable powers requests that the Court

A Award Plaintiff such preliminary injunctive and ancillary relief as

may be necessary to avert the likelihood of consumer injury during

the pendency of this action and to preserve the possibility of effective

final relief including but not limited to temporary and preliminary

injunctions orders freezing assets immediate access to business

premises appointment of a receiver and expedited discovery

B Enter a permanent injunction to prevent future violations of the FTC

Act and the TSR

C Award such relief as the Court finds necessary to redress injury to

consumers resulting from Defendantsrsquo violations of the FTC Act and

the TSR including but not limited to rescission or reformation of

contracts restitution the refund of monies paid and the disgorgement

of ill-gotten monies

D Enter an order requiring Relief Defendant to disgorge all funds and

assets or the value of the benefit it received from the funds and assets

which are traceable to funds obtained from Defendantsrsquo customers

through the unlawful acts or practices described herein and

18

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 19 of 57 Page ID 1778

2

3

E Award Plaintiff the costs of bringing this action as well as such other

and additional relief as the Court may determine to be just and proper

Dated February 5 2019

Respectfully submitted

ALDEN F ABBOTT General Counsel

JosaSMillard Brian M Welke middot Barbara Chun (Local Counsel) Attorneys for Plaintiff FEDERAL TRADE COMMISSION

4

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22

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27

28

19

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 20 of 57 Page ID 1779

EXHIBIT A

Attachment A

Free Assessment

Our expercs will lt1ssPss you cun ent

swclent lo n program and decermn which progr ms are

avc11l bl rn yoL11 situation We wi I help you cl11cic1e which progr m r1

help you achieve your goals Call us today

Service Guarantee We are commmecl to 11-1 111g

CllStomers get low r rc1ces ancl monthly payments and we w1I

m ke the pror~ss se mless and s r11ghtforwc1rd ou wi ll be sansf1ed

with our service ml OLlr

cornmcmem to you success Thars ow gu~ ancee

Success Rate Ou1 96 ~ surcPss r a e s 11e of he

cop I a ings tn he industry Olr

process has beer tested nd Olli

succ ss r r~ prowbull~ tn t it works

We c n ll~lp yo reduce and -1111ph y our p ~ymP1 ts Call us today

FTC-AID-1

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 21 of 57 Page ID 1780

20

Exhibit A

ABOUT US

We can help you reduce and simplify your pay1ncnts Contact one of our specialists today for

a free evaluation

111middot 1_I 1

101

t I 11111 I I

Itbull 11

Ill fl I I

bull ~ 0 I

What Makes Us Great fa1(li1-_~ tur1ent ~e11ef 11as a taf- o~middot tt a middotel elt1)rns bullJn st1ncb110

1middot1ep yriJ Tibullmiddotest fi 1e-ndly f3ce~ 113ve eirej e1tc-nsve1yr =inj ire

fanih1~1 bull11iu1 ti~e nul~nce~ cfscrvern rrent Cdid p11vate stucre11

l1J1ns Th~y viill u~e Ui5 epe tise o loik jUl fJ ycur ~Je~t

i(tres~- f)LH ~U(CtS~ ~HE 1h-~ I lSllt of i_r middotDff ancl iur

C ur ~r_(J~l 1o~w- JCl11~crs f(middotil) 3 00Vtli ~tJegy o r ~dUC2 011i

a1r1plfy yliur- - _Je1middott middotcar payr1t11s 1) Asstrnlins Itle ~atl1t1

2) R~~ear c1-1ng Our st~lff wmiddoti11 (lrJUi~oleaerick ]ll fnfcnTnati(-n befort dtmiddoteJPlr~ t tne ri~n 3) rnnk1middotgbullle i_i1 i e~ear (rr i~ ormiddot1 1 1 etc 1Ne

irvi-s t1ga~ii 111 ps~ib le a~irst 1n(t aptlbull~n 4) 1Nr1 ting VVF p1 eiv lii J 11 iUen u tt-igy IJefore vie Uke ut1c-1l i)ecius~ you d-ese11e 11) undi r~~anci

Lhe pr 1cer S) ~ev1sing Al)ng ~r 1udent Relief 1- 1otT11111tt bull) ti) ci e1H1ve ut-l-~n~-l)O c111 i ri 3 Vbulle -~11 leave n1) sti bull1e u11t111 neltl tecause middot~ve

11~1ve your be~ i1~ t~rest 1t l1ein 6) Si~tcl11ng Our note- =1nd r~c)1 ~ ~1 e thorou~ll ln(I pru1ile 1 ceJ1 po cri1~ 1)f vo111 ~1tuJticn s) iny if-oi

~xpe1 t- 01 eou pped to s~1ty1J_J bullVi r you1 c si- 7) De-gn1ng _ fe ~1 t 1nelt--1- f1ts ti 1middotV 1middotid de~ 1middot1 1 st1 iegy to fit ou 1 1_i dque jtct1in so

011 c111 i Jle y1)u1 1vv1middot1 per feet -ut1e-s ~~0 1 v

1bullVlly 1100~e At(J1n~ Sltl(ltnt Fie11e7) (i1_d aclol~Or~ bull -ii~ (1Ualiftel lci ~~~ISt~h 1noie ype-s middotif JS~iSi_ance u~211 Cd ( (11)itXS i1 jG(l1~t) to ti-tgt

p ~n~ 1not con1p n1es can 11i1p bullbullllh ve )t ~ ~qu1pptCI to bull-bullGr k 1bullv1t1middot1 r~ 11t-2 [uo emiddot 1 lc1 r1s ~~nCI cn even iner-1ne frmiddot tt1e c ~e of 1l~e

~1lt ntslmiddoturelt A1cl1rg Sudent Fie1ef 1middot cis mmiddote to )fe 11d we offe1 t with middotmiddot1eltbullbe 1es nI 3 rncney lock guMai-itee

We Have Been Featured In

FTC-AID-2

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 22 of 57 Page ID 1781

21

Exhibit A

SERVICES Wt w gtL

Loan Forgiveness Income Based Payments Loan Consol idation In some cases individuals with A period of financial hardship may You may be able to combine

Fede1middota1 Student Loans may qualify qualify you for an Income Based nultiple federal student loans into to have a portion of the amount Repayment Plan In many cases this one new loan w ith a lower more

owed may be forgiven This means means you pay nothing Unlike a affordable monthly payment Loan

your principal balnce coulcl be defe1 ment the term on your loan consolidation prngrams can l1elp

significantly reduced and you will continues to reduce while the plan is you qualify for additional programs not be expected to repay the in place Your term could reduce like loan forgiveness programs or

forgiven amount while you pay nothing Public Setvice Loan Forgiveness

a III

Private Sector Loan Forgiveness

If you work for a government

organization at a city state or

federa l level you may qualify for tle

PL1blic Service Loan Forgiveness

program To qualify your loans

must be cotisolidated into a specific

repayment plan The balance on

your federai student loans is

forgiven after 120 qualifying

bull C Permanent Disability

Forgivenness If your disability is expected to last

60 months or more you may qualify

for permanent disability forgiveness

Q1alifying for Permnent Disability

Forgiveness requires a visi t to your

doctor and individL1als enrolled in

the program are subject to three

years of post-discharge monitoring

Wage Garnishment Prevention

Federal law requires that the

Department of Education or a

gua1middotanty agency notify you before

111st1tuting wage garnishment You

have tl1e right to a hearing where

you can challenge the stated

amount owed and negotiate the

terms of the repayment scheclule

We can intervene on YOL1PflJl~1D-3

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 23 of 57 Page ID 1782

22

Exhibit A

payments have been made p1middotevent wage gampnishments

A FEW STATISTICS ABOUT STUDENT LOAN CRISIS

12 Trillion National Student Debt I he nitionil student loin debt is

now 17 trillion dollirs 1 trillion of

these are in federil student loans

Let us help you through this national

crisis Cill today for a free

evaluation

40 Million Students with Debt

In 7014 an estimated 40 million

current and former students were in

debt because of student loans If

you are one of the millions of people

struggling to pay student loans

Aiding Student Relief is here to help

$33000 Average Student Debt

The graduating class of 7014

average $33000 of student loan

debt per person Thats $3000 more

than the average in 2013 Dont be

one of the many Let Aiding Student

Relief advocate for you

Aiding Student Relief has helped cmrnllcss 1woplc reduce their student debt_ Their proven business

plan has led lo one of lhc highest s11cclSS raCs in the inltl11slly

John Standiford Associated

FTC-AID-4

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 24 of 57 Page ID 1783

23

Exhibit A

TESTIMONIALS

Til~nks to Aiding Student Rel ief Im middotI middotva ove1vvhelrnecl but Aiding The expemiddotts at l1icl i11g Student Rel ief

s1v ing $250 per month Strrd r~rt Relief expl~ inecl the were ther~ to help me when I process ancl rnacle everytl1ing cle11middot nelclecl 1t rw)s t

and sirnple

I Michael Ma 1in

Entrep e11eu1 Em iiy Jallo1 Ii Pa ul Ch is tia I1se11

Teacher Nurse

With so many programs I didnt middotconso lrclating my loans into one I love my Job but vith my high

know what was ng ht for me My monthly payment hs made life student loan payment was still

sruclent loan aclvsor walked me si1nple1 Now I can focus on 1Nhn bamiddotely getting by I don t kn ow what I

through my optio ns rnd now Imiddotn matters to me would hwe clone wthout Aiding

saving 54 I 11n1omh Stucie1middott Rel refmiddot

Ariel Hemiquez Sales co)SUltant

Stephani Seland-1 Small Busim~ss Owner

AJ 01en Museum Curator

RECENT NEWS

)lt)

o(l ttDrlTI -5

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 25 of 57 Page ID 1784

24

Exhibit A

Student Debt Crisis Business Latest Debt Collective Demands May be largely about smallest Student

borrnwers US News amp World Loan Crisis is fa frorn ove The Debt Collective is a group of Report-May 162015 last month Two new reports suggest the college students calling the Fedemiddotal Reserve Bank of New student loan crisis is easing them-se1ves the Corinthian York repor ced that stuclent loan somewhat as the economy Fifteen who are refusing to pay balances rose to 16 trillio n and improves but the crisis is far back their student loins As pa t that 113 per cent of that is in from ove the College Board of this effort the Debt Collective repo t~ tot31 borrowing fell by 8 has written an open lette to the pEbull1 cent between 2012-13 and Department of Education f l llJ 20 13-14 The organization

About Us 11 1 i~d1middot1r F th~~- h1~ ff t1middot~11middot=cl =i~=middott- 1middot __31middotmiddotIIgt middot bullmiddot11

middot- I ( )ntir il t l~i -r_il fr~~

Address bull middot tc1ltj-1r_ =i ~

middot l t1~t 1middot1 fcJ middot~_1 1 I l11 - Hbull 1 tr

~t (~~ 1 12bull~11 T 1 1- - 8555105400

FTC-AID-6

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 26 of 57 Page ID 1785

25

Exhibit A

f - g+ in O) ~ PRIVACY POLICY

This privacy statement discloses the privacy practices for AidllII Student Relief Because Aiding Studen Relief wonts to demonstrate ts firm commlcmell to your

privacy Aiding Sudent Relief hes greed to disclose ls 1rifor111atlori g1thering and dlssem1n1t1on prct1cts Aidlns Studtrit Relief will notify you of

INFORMATION COLLECTION At-ID USE

Aiding Student Relief is the sole owner of the rformMlon collected on this site We will not sell shire or rent this information 10 others In way different from what Is

disclosed 1n this statement Aldln1 StudeM Relief collects 1nform111on throuah this site from our prospective end existing clients at several different poin on our web

site We use their contact Informii on to send information bout our company and to service exsMs accounts Users may optbullout of rece11ns future malllngs see the

cholceoptbullout section below Contect and Financial information that 1s collected Is used for verifying your name address and other informa1on as well as to boll you for

your use of our Gerv1ces using Information from third party sourcH Information about your computer hardwre and software Is automatically collected by Aiding

Student Relief and may be shared in asgregate with third parties whose services are used for traffic analysis purposes This Ir formation includes your IP address

browser type domain names access times and referring Web site addresses Ths information is no tied to personally Identifiable Information This 1nformatlor s used

by Aiding Student Relief to malMan no Improve the quality of the Hrvct and to senerae statistics resardlng use of he Aiding Student Relief site We use third party

services to bill for serlces and to provide other services like our Live Help chat We store the transcripts from these chats for customer service Improvement These

third party service providers are not permitted to use your infornon for any secondary purposes

Thank you and cheers

FTC-AID-7

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 27 of 57 Page ID 1786

26

Exhibit A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 28 of 57 Page ID 1787

EXHIBIT B

Attachment A

((

z | ~

AIDINGSTUDENTRELIEF

bull bull bull bull bull

13 deg $ $ampdegdeg deg() ˝ amp $$deg( + -+Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 29 of 57 Page ID 1788

bulldaggerDagger Daggermdashndash Daggerhellip ƒfrasl hellip lsaquorsaquobullminuspermilminushellip bdquolsaquoldquo rsaquordquobulllsquo fraslbullrsquopermillsaquofraslpermilminushellip sbquo

4556789fADlt=gtA9BCAD

DZgtA=EFGHIJFKLMNOPFQOGFHIQRSTLKSUMMNOPLHMTFIVRWXHKKNIFNUNOPRLFGSHKSRVRVNQ

f e=klHMW

9SI]UQMSNSOQOHHPFK YaSTHHVVJFMHcVGNOJVHHFKKPSUHMLIUOQN_PL[KSVFGJPRSDTHRFPLIP=SNDC==GFdFIP9VaNHQTWSRPbHF_PSKSVNMPMHNIO XNNIIFRKNF7IKSQQMHFNDVPOS9IAeTHPdKSUMMFNKHONP 8aF_KSNVPHTNIMNR[POVFgNPTHLNHIgtMFI YTFHIdFFI D9aHVR_KNKHFHIWIQOTHIQbFFP

lt=Dkgt=L]oHUKMMH ihTFNIORI THHVPRFMVKgtNJ_NFFbIVSJI]IFjdGGVNNN lt=TFKPPNF 9DaFGmVHPGRJMFNNQOSGnPFFTNLUNHPMIMTFVNJOKMIWV

27

]UMNOHPFRKNVSHKKISIRWRrGZNJONgtNjTHKHMI=cQgtORHVPKSOUMddUNKSPIdspNVPNq_ lt=gtBTHFHPb=HFILGFHMt DTFuFIUVFRPNTFIMINVWOPRVOQFIV sFQFPHKKH vaIPNFVcSyOFSPRFMRNVOJH_gtVFDVUJAN9FPwFuVFJLFHMP_VTFFdSIIVdNHUPxI=DQSROJGASHIVdDSNMINONPPaHdOHdPFHRIWVFFHdFIGM˙ 01 $2 301 $$3 ( Exhibit B

8

~ldquo

middot

676EBCEDK5ltAC]5EF_5665E7gt5lt7aFb688E588lt76B5E6F8EBAC78lt76cdddefghijhggklmknmopqprpopst u

13 deg $ $ampdegdeg degˇ amp $$deg + -+Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 30 of 57 Page ID 1789 () ( vPSZwPxyYTUZUWWzxPyxSWMZWPU|SWUWYZ~YTY~QSWbullYXRwU~UxSdaggerXQ~UZXvPSZWSOVQSYNOXPRSTUSDaggerPxXYPZPNXRUSPQZXPbullU~SOhellipUNPxyYTUZmdash zUxSZUZXndashYWShellipYYXOwPxyYTUZUWWMNOPQx~YWShellipYYXOYWUƒDaggerU|XU~XPSWXfrasllsaquoPZXRWPxPxUOPQSOVQSYNONPxDaggerUxSZUZX~YWShellipYYXONPxyYTUZUWWmdash

rsaquominus MZ|PUpermilSWUzSOUZXWbdquoDaggerUxYP~PNZSZ|YSRSx~WRYDaggerSOVQSYNOOPQNPxSZMZ|PUpermilSWU~rdquoUDaggerSOUZXzSZmdashMZSZO|SWUWXRYWUSZWOPQDaggerSOZPXRYZymdash zQhellipY|daggerUxTY|UvPSZwPxyYTUZUWWMNOPQbullPxlsquoNPxSyPTUxZUZXPxySZYrsquoSXYPZSXS|YXOWXSXUPxNU~UxSUTUOPQSOVQSYNONPxXRUzQhellipY|daggerUxTY|UvPSZwPxyYTUZUWWDaggerxPyxSmdashsbquotrade f8Ef8E78FCB6C8EŁPQSOhellipUShellipUXP|PhellipYZUQXYDaggerUNU~UxSWXQ~UZXPSZWYZXPPZUZUbullPSZbullYXRSPbullUxPxUSŒPx~ShellipUPZXRODaggerSOUZXmdashvPSZ|PZWPY~SXYPZDaggerxPyxSW|SZRUDaggerOPQVQSYNONPxS~~YXYPZSDaggerxPyxSW YlsquoU PSZ NPxyYTUZUWWDaggerxPyxSWPxzQhellipY|daggerUxTY|UvPSZwPxyYTUZUWWmdash ŠmŸŽıłŠm 57gt8A57A5B= 8E65C76B5E6F8EB5=6G

PONM[5 QRSTUVQU PYXWZW lt4556789588lt959=lt CD lt H5FICEDJ8KA5LCD

A565E7gt57 œšžeuroiexclcentpoundyenbrvbarsectbrvbareurocopypoundsectlaquoeuropoundlaquobrvbarlaquoregplusmncentbrvbareurocent microparalaquo europoundž raquoY|frac14frac12 plusmncurrenRSUraquoSxXYZeuropoundlaquo laquoeurolaquoordf frac34

^ ˙ ( (

28

Attachment A

01 $2 301 $$3 ( Exhibit B

()(

=4ABC9DEAFBD=FGFHIJKLMJNOMN MRNS mn = nrst = svzhellipu t bulltvDaggerrhellipDaggerurbullbulltuhellipv hellipz~ bullmdashldquordquolsquorsquotrade š oŒŠeuro centpound ` umluml 13 deg $ $ampdegdeg degˇ amp $$deg + -+Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 31 of 57 Page ID 1790

ISNRTUKQINKKNNKL[MRJ PUWQI]MRM qyt|tytzxy rsaquoqNfraslbdquoPUhellipsbquoLUyQhellip rfraslbhellipMNSIKVUQ QNJKvUQsMiexclQQJUx[iexcliexcl_vsect_Qyenyenbrvbarbrvbar uSSRNTPL_LUUMKIaJ_WMIJJKVIONNQJJMWRMIIbQQURKLWIIJQbKLUNKMPTMNQQ_KKRY tbullbulldaggersDaggerv~vhellipmdashryrhellip~mdashrhellipDagger ŸLŽUıQŽbłpermilMtradeœsbquoNtrade_ffRŁyISMŒUQWyNUQŠlsaquo rv45657896lt7ltgt5lt PQKLMIQSNRTUKINQVNOOMVKMWNQKLIJPMXJIKMYZMPIOO NJMOOJLURMNRRMKKLIJ klltko ltgtlt85p5gt5 ouvwxrz ^^ ~ minuspermil tffŁ yenpoundpound KNOWDaggerIreggt4lt97ltndash9ƒ Dagger hellipDaggerlsaquo žko74k57ƒ ƒISNcurrenUIWIbJKWMKJYVNTKM KLONNRqIQQSNNRTUKINQQIJ_JMWNQKLIJJJPMXJIKMcOMUJMVNQKUVK_JUKBHdefABCgDEAFBDghidjlaquopoundbrvbariexclnotvIWIQbDaggerK_WMQKbullMOIMSvOObullIbLKJbullMJMRMW ordf copy

01( $2(301$$3( Exhibit B

29

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 32 of 57 Page ID 1791

EXHIBIT C

Attachment A

~ 111 ~tampi 10 11 ~bull ia1111

Something awesome is coming soon We are buildin somethin ve cool Sta tuned and be at1ent Your atience will be well aid

~lbullrbullUiUffl We can help you reduce and simplify your payments

101 Loan For iveness

1~u 0 (middottmiddotbullmiddotmiddot1 1~=I -- _~

HZamp IMUliULlampRampatiEUWi nmiddot middot-il~ fr middot 8rbullbullrcrr-

_J l _ 1 _f _ur -~t~ u L liYu

~ Income Based Pa ents

bull ~ f I - - I - I - ri u ~u-=lf ~ JU

1-bullA ---rc iM1~~ -~-bullCiel rrcl

~- middot IY 2 i C middot middotJ ll1Jmiddot 0 _ middot_middotIr i

~ LdfiJIMifJ11JJMJllfFffi

middotE-ltecl l2bullJbull iequbullt t11cit t1lt2 CtpCr~middot1e- f

JJd r g-_iraE-1 agltr-middot- ntimiddot middot)middotou

tmiddot_rt- i ic l~1ri ~rbullmiddot middot111~ umiddot -_ d_t-c

fsectmet-Naibullfyen1~poundibllffifftmI

I f-nle Vnot Nune

I ampterYOllrEmall ]

1 ~~~~ 1

If -bull 13n ~Cbull t~middot rct1~j d- gtOY- - hO- irmiddot (bulldbull) plltmiddotmiddot- leemiddotmiddot JOu

1r1cbullmiddotn111f11ri ll1fbull fcrn to ~bull~I

Triin- GU

WAWMyenEIRitiRpoundWt 44 ZiAtillampampI

Exhibit C

Case 818-cv-01987-JLS

-KE

S

Docum

ent 50-1 F

iled 020519 P

age 33 of 57 P

age ID 1792

30

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 34 of 57 Page ID 1793

EXHIBIT D

Attachment A

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Type then hit enter to

bull bull bull bull bull bull bull

----

----

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 35 of 57 Page ID 1794

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

infoaidnestcom (800) 555-1212

HOME

ABOUT US

SERVICES

FAQ

BLOG

CONTACT

HOME ABOUT US SERVICES FAQ BLOG CONTACT

1 of 6 462018 945 AM

31

Student Loan Forgiveness Loan Consolidation Student Loan Forgiveness

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 36 of 57 Page ID 1795

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

If you have Federal Student Loans yoursquore in the right place to get those loans reduced forgiven or completely discharged through our student loan forgiveness programs

Get your multiple Federal Student Loans consolidated into one forget about increasing interests and pay month to month at the lowest possible cost

We understand if yoursquore going through some hardship and thatrsquos why with us yoursquoll be able to make monthly payments based on your affordability for as low as $000 depending on your situation

2 of 6 462018 945 AM

32

Knowledge Base

Defaulted Student Loans

Wage Garnishment

Student Loan Rehabilitation

Income Based Repayment Plan

Deferment and Forbearance

Pay As You Earn Repayment Plan

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE Call 561)424-6053 today to go over your options

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 37 of 57 Page ID 1796

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

Our knowledge base is designed to provide information regarding some of the critical topics those with student loans must be aware of to be able to make educated decisions regarding their future

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

A wage garnishment is any legal procedure in which some portion of a personrsquos earnings is required to be withheld by an employer for the payment of a debt

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

With this program your payments change as your income changes and will not be longer than 25 years This is the ideal plan if you are in partial financial hardship Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard plan

Temporarily allowing you to postpone or reduce your federal student loan payments Postponing or reducing your payments may help you avoid default and future garnishments

Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard

3 of 6 462018 945 AM

33

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 38 of 57 Page ID 1797

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

4 of 6 462018 945 AM

34Attachment A

Testimonials

Latest News

Why 2016 Will Be a Big Year For Student Loans

Top Student Loan Refinancing Questions of 2015

Oba mas latest student loan plan

Things You Should Know About Public Service Loan Forgiveness

Recent Posts

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 39 of 57 Page ID 1798

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

5 of 6 462018 945 AM

35

About Us

Contact Info

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 40 of 57 Page ID 1799

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

pay-grandchild-studen

Why 2016 Will Be a Big Year For Student Loans

December 30 2015

12511110_1112367518

Top Student Loan Refinancing Questions of 2015

December 30 2015

We stand by our consultation and quote We are so sure and confident about our services and offers that they are all 100 money back guarantee risk free ndash if we donrsquot do what we promise yoursquoll get your money back

(800) 555-1212 AidnestStudenLoansgmailcom 18100 Von Karman Ave Suite 850 Irvine CA 92612

Futero SAS copy 2015 | Aidnestcom

6 of 6 462018 945

Exhibit D 36Attachment A

AM

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 41 of 57 Page ID 1800

EXHIBIT E

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 42 of 57 Page ID 1801

AIDNEST Let us help you through this national crisis

Call one of our specialists today

Forbearance amp Deferment If you are still in school and struggling to make payments on your student loans You may qualify

for Forbearance amp Deferment

Garnishment Prevention Federal law requires that the Department of Education or guarantee agency notifies you before they

begin garnishing your wages

Loan Forgiveness If you are a teacher public service worker or an individual with total and permanent disability you

httpaidnestcom[442018 115239 AM]

37Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 43 of 57 Page ID 1802

AIDNEST Let us help you through this national crisis

may qualify for this program

Consolidating Your Loans Consolidating your loans to one new loan under one lender may lower your payments and make

your life a bit more manageable

Affordable Payments If you are looking to lower your monthly payments then Income Based Repayment Plans may be

the correct choice for you

Learn more about our services

LEARN MORE

httpaidnestcom[442018 115239 AM]

38Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 44 of 57 Page ID 1803

AIDNEST Let us help you through this national crisis

Loan Forgiveness Programs Income Based Payments Student Loan Rehabilitation

Student Loan Consolidation

You may be eligible for

Loan Forgiveness Programs

In some cases individuals with Federal Student Loans may qualify to have a portion of the amount

owed to be forgiven

Get in touch with our professional team to find out which loan forgiveness program you qualify for and

how you can get rid of your unpaid student loan

L EARN MORE

httpaidnestcom[442018 115239 AM]

39Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 45 of 57 Page ID 1804

AIDNEST Let us help you through this national crisis

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE

Meet your Budget One of our advisers will help you meet your payment goals by using your budget and timeline to

determine the best plan available

httpaidnestcom[442018 115239 AM]

40Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 46 of 57 Page ID 1805

AIDNEST Let us help you through this national crisis

Simple Process We understand that lowering your payments alone can be difficult Our intuitive platform allows us

to keep the entire process simple

Customer Satisfaction We are committed to providing you with outstanding service only We look forward to working

with you

100 money back guarantee No Hassle Money Back Policy

httpaidnestcom[442018 115239 AM]

41Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 47 of 57 Page ID 1806

AIDNEST Let us help you through this national crisis

Lower your loan payments by getting in touch with one of our professionals

We design a customized repayment plan that will allow you to make payments based on your

monthly income family size and spending Get rid of the hassle of extensive paperwork and get the

help you deserve

What we can help you achieve a lower payment or lower rate

httpaidnestcom[442018 115239 AM]

42Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 48 of 57 Page ID 1807

AIDNEST Let us help you through this national crisis

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcom[442018 115239 AM]

43Exhibit E

httpaidnestcomservices[442018 115322 AM]

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 49 of 57 Page ID 1808

Services | AIDNEST Let us help you through this national crisis

INCOME BASED PAYMENTS

If you are suffering from a financial hardship you may be eligible for an

Income Based Payment In this repayment program you would have a

payment based on your income and family size The payment could be as

low as $000 per month with forgiveness at the end of 20-25 years

44

Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 50 of 57 Page ID 1809

L E ARN MORE

LOAN FORGIVENESS

If you have Federal Student Loans you may qualify for any of the student

loan forgiveness programs that are available to borrowers You may be

eligible for principal reduction loan forgiveness or a complete loan

discharge depending on your individual circumstance

L EARN MORE

PRIVATE STUDENT LOAN CONSOLIDATION

Much like refinancing a mortgage generally the biggest benefit of private

student loan consolidationstudent loan refinancing is a lower interest rate

httpaidnestcomservices[442018 115322 AM]

45Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 51 of 57 Page ID 1810

L E ARN MORE

(something federal consolidations do not offer)

STUDENT LOAN REHABILITATION

You can renew eligibility for new loans and grants and eliminate the loan

default by ldquorehabilitatingrdquo a defaulted loan

httpaidnestcomservices[442018 115322 AM]

46Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 52 of 57 Page ID 1811

CHE CK E L E G I B I L I T Y

WAGE GARNISHMENT

A wage garnishment is any legal procedure in which some portion of a

personrsquos earnings is required to be withheld by an employer for the

payment of a debt

L EARN MORE

With our fast friendly and professional services wersquoll be glad to help you get your student loans

reduced forgiven or completely discharged To this end wersquoll assist you in consolidating all your

student loans so yoursquoll have only one lender and yoursquoll start making one monthly payment Our

professionals will walk you through the best and most flexible repayment options and if itrsquos also

necessary varied deferment options and rehabilitation programs

httpaidnestcomservices[442018 115322 AM]

47Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 53 of 57 Page ID 1812

Services | AIDNEST Let us help you through this national crisis

Our CRM System

Our CRM is one of the most advanced in the industry and most importantly itrsquos linked directly to

the Department of Education (DOE) This keeps your personal and most confidential information

safe Furthermore because our CRM system is linked to the DOE our approval is 100 Through

our CRM we will be doing continuous monitoring of our process without losing sight of your

immediate needs ensuring that your case has the proper handling and most efficient process

httpaidnestcomservices[442018 115322 AM]

48Exhibit E

n

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 54 of 57 Page ID 1813

Services | AIDNEST Let us help you through this national crisis

R ECENT POSTS

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

ABOUT US

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcomservices[442018 115322 AM]

49Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 55 of 57 Page ID 1814

EXHIBIT F

s -

bullmiddot - ~ t ~ower Your Student Loan Pay~e~ts oday -- Students Helping Students Save Money

INCOME BASED PAJIIIJITPAIS

I C(gttoUC1 u~

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 56 of 57 Page ID 1815

X + C (D Not secure wwwstudoracom 0

CALL US NOW (85S) 978-S599 middot 1nfostudoracom

HOME SERVICES ABOUT US FAQ CONTACT US BLOC PRIVACY

Offering obligation and commitment free loan relief solutions

STUDENT LOAN FORGIVENESS INCOME BASED PAYMENTS LOAN CONSOLIDATION

We11 help you get your loans reduced forgiven o r Make monthly pdyments based on your affordability Get multiple Federal Student Loans consolidated into

discharged one low monthly payment

Talk to our experts concerning your

student loans

Studora is a pnvatefy owned company that helps consumers like you identify

government programs that fit your financial s1tuat1on Our loan experts will assist you in selecting the appropriate programs that WOltk with your income family size and

desired monthly payment We then prepare the appropriate documents for your review and submission All this f o r one low easy payment

Testimonials

Thank you f o r getting back to me quickly Youve been fabulous Thank you for the confirmation and for your help today Pass

during this whole process Is there a place I can go online that I this on to your sup that you were very professional and very

can leave a comment for your manager Youve made this Robert helpful and brought a sense of relief for me Thank you very

process so easy and answered every question my husband and I much and have a great rest of your day Kudos to you and your

have had teammoneywell spenL

Exhibit F 50

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 57 of 57 Page ID 1816

Services we offer

Stud ora offers document preparation services for all loan forgiveness consolidation and relief services to people who are unable to manage their finances Our mam aim is to

offer complete peace of mind to indiVidual unable to pay their student loan debt

we otter the folloWing document preparation services with complete professional assistance

amFinancial Review ffl Budget Planning

Toe first step to creating a flexible loan repayment plan is financial review we also help create a personal finance plan to ensure that you are able to

Our professmnals will look into your finances and design a custom manage your monthly budget in the most effective way This plan will keep

repayment plan that is affordable and easy to manage your spending to the minimum alloWing you to save more money for loan

repayment

Permanent Disability Forgiveness r-trTeacher Loan Forgiveness (5 You can get rid of your Federal Student Loan if you are permanently disabled Good news for teachers who are under the weight of a massiVe loan You can

now get $17 forgiven on your student loans

Public Service Loan Forgiveness Custom Debt Relief Plans

Want assistance with debt relief Get in touch with our experts who will help If you are a public service agent you can get rid of your loan after 120 days of design a loan repayment and relief plan for you based on your monthly

income and affordability payments

THERE ARE NO OBLIGATIONS OR COMMITMENTS

want to save thousands of dollars Fill out our form and get relief from your student loan for a more

peaceful tomorrow

Your Name

BiHHHi

Exhibit F 51

Attachment A

Page 9: JOSHUA S. MILLARD, BRIAN M. WELKE, pro hac vice · for which it has no legitimate claim. Noel is a Wyoming limited liability company that reported in a public document that its principal

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 9 of 57 Page ID

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1768

company or payment of application fees

23 USDE will grant forbearance while processing applications for an

alternative repayment plan and in some cases of hardship During forbearance

unpaid interest is added to the principal balance

Defendantsrsquo Deceptive Marketing of Student Loan Debt Relief Services

24 To lure consumers into purchasing their purported student loan debt

relief services Defendants have made false promises to eliminate or reduce

consumersrsquo student loan balances or monthly payments through loan forgiveness

or other programs

25 To induce consumers to purchase their purported student loan debt

relief services Defendants have disseminated websites such as aidingstudentscom

aidnestcom and studoracom including but not necessarily limited to the

attached exhibits A through F Defendantsrsquo websites have contained the following

statements among others

Free Assessment

Our experts will assess your current student loan program and determine

which programs are available in your

situation We will help you decide which

program can help you achieve your goals Call

us today

Service Guarantee

We are committed to helping customers get

lower rates and monthly payments and we will

make the process seamless and

straightforward You will be satisfied with our

service and our commitment to your success Thatrsquos our

guarantee

Ex A at 1 (aidingstudentscom 2015)

9

Success Rate

Our 96 success rate is one of the top ratings in

the industry Our process has been tested and our

success rate proves that it works We can help you reduce and simplify your payments Call us today

Attachment A

----------

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 10 of 57 Page ID

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1769

ldquoWe can help you reduce and simplify your payments Contact one of our specialists today for a free evaluationrdquo

Ex A at 2 (emphasis in original)

ldquolsquoAiding Student Relief has helped countless people reduce their student debt Their proven business plan has led to one of the highest success rates in the industryrsquordquo

Ex A at 4

100 Customer Satisfaction We can help you reduce and simplify your payments Call one of our specialists

today

Ex B at 1 (aidingstudentscom 2016) (emphasis in original)

Meet some of our members who have saved big on their student loan debt Helping You Save Big

ldquoThanks to Aiding Student Relief I am savings [sic] $250 per monthrdquo Michael Martin Entrepreneur

Ex B at 2 (emphasis in original)

ldquoWe can help you reduce and simplify your payments rdquo

Ex C at 1 (aidingstudentscom 2018) (emphasis in original)

Student Loan

Forgiveness

If you have Federal Student Loans yoursquore in the right place to get those

Loan Forgiveness

Get your multiple Federal Student Loans consolidated into one

10

Student Loan

Forgiveness

We understand if yoursquore going through some hardship and thatrsquos why

Attachment A

Case 818-cv-01987-JLS-KES

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Document 50-1 Filed 020519 Page 11 of 57 Page ID 1770

loans reduced forgiven or completely discharged through our student loan forgiveness programs

forget about increasing interests [sic] and pay month to month at the lowest possible cost

with us yoursquoll be able to make monthly payments based on your affordability for as low as $000 depending on your situation

Ex D at 2 (aidnestcom 2016)

Lower your loan payments by getting in touch with one of our professionals We design a customized repayment plan that will allow you to make payments based on your monthly income family size and spending Get rid of the hassle of extensive paperwork and get the help you deserve

What we can help you achieve [is] a lower payment or lower rate

Ex E at 6 (aidnestcom 2018) (emphasis in original)

STUDENT LOAN FORGIVENESS

Wersquoll help you get your loans reduced forgiven or

discharged

INCOME BASED PAYMENTS

Make monthly payments based on your affordability

LOAN CONSOLIDATION

Get multiple Federal Student Loans

consolidated into one low monthly payment

Ex F at 1 (studoracom 2018) (emphasis in original)

26 In some instances consumers view the Defendantsrsquo online advertising

and call Defendantsrsquo telemarketers for more information Defendants also make

outbound telemarketing calls and send texts to consumers to offer their services

and convince student loan borrowers to sign up for Defendantsrsquo debt relief

services

11

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 12 of 57 Page ID

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1771

27 In calls with consumers Defendantsrsquo telemarketers have told

consumers that Defendants can cause consumersrsquo student loan balances to be

reduced or that consumersrsquo loan balances would be forgiven after making lower

monthly payments Defendantsrsquo telemarketers have told some consumers that over

half their loan balance would be forgiven Moreover Defendantsrsquo telemarketers

have told some consumers that their loan payments could or would be rapidly

reduced to $19 per month or promptly forgiven

28 Defendants have made other representations concerning loan

reduction or forgiveness to consumers in telemarketing their debt relief services

For example Defendantsrsquo telemarketers have told one or more consumers that

ldquofamily sizerdquo a metric for determining the amount borrowers pay each month

under IDR plans includes ldquoanyone you help out throughout the year[] they donrsquot

have to live with yourdquo even claiming that helping with ldquogas money three times

out of the yearrdquo is enough to include a person in ldquofamily sizerdquo Further

Defendantsrsquo telemarketers have offered one or more consumers ldquobasically a

guarantee to remainrdquo in an IDR plan and warned one or more consumers that

signing up for an IDR plan with a lender instead would result in a higher loan

payment

29 Defendants have not been likely to achieve the lower monthly

payments or student loan forgiveness they have advertised marketed and

promoted to consumers In many instances Defendants have failed to obtain the

promised lower monthly payments or student loan forgiveness

30 Defendants have charged consumers fees for purported debt relief

services before achieving lower monthly payments or student loan forgiveness

and in many instances have failed to achieve those results at all on behalf of

consumers

12

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 13 of 57 Page ID

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1772

31 Defendantsrsquo telemarketers have sought and obtained consumersrsquo

payment information by phone or the Internet

32 Defendantsrsquo total advance fees typically have been in the range of

$300-500 Defendants also have charged consumers recurring monthly fees for

purported debt relief services typically charging $19 per month

THE FTC ACT

33 Section 5(a) of the FTC Act 15 USC sect 45(a) prohibits ldquounfair or

deceptive acts or practices in or affecting commercerdquo

34 Misrepresentations or deceptive omissions of material fact constitute

deceptive acts or practices prohibited by Section 5(a) of the FTC Act

VIOLATIONS OF THE FTC ACT

Count One

(Deceptive Student Loan Debt Relief Representations)

35 In numerous instances in connection with the advertising marketing

promotion offering for sale or sale of student loan debt relief services Defendants

have represented directly or indirectly expressly or by implication that consumers

who purchase Defendantsrsquo debt relief services will or likely will have their

monthly payments reduced or their loan balances forgiven in whole or in part

36 In truth and in fact in numerous instances in which Defendants have

made the representations set forth in Paragraph 35 of this Complaint such

representations were false or not substantiated at the time Defendants made them

37 Therefore Defendantsrsquo representations as set forth in Paragraph 35 of

this Complaint are false or misleading and constitute deceptive acts or practices in

violation of Section 5(a) of the FTC Act 15 USC sect 45(a)

THE TELEMARKETING SALES RULE

38 Congress directed the FTC to prescribe rules prohibiting abusive and

deceptive telemarketing acts or practices pursuant to the Telemarketing Act 15

13

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 14 of 57 Page ID

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1773

USC sectsect 6101-6108 in 1994 The FTC adopted the original TSR in 1995

extensively amended it in 2003 and amended certain sections thereafter 16

CFR Part 310

39 Defendants are ldquoseller[s]rdquo or ldquotelemarketer[s]rdquo engaged in

ldquotelemarketingrdquo as defined by the TSR 16 CFR sect 3102(dd) (ff) and (gg) A

ldquosellerrdquo means any person who in connection with a telemarketing transaction

provides offers to provide or arranges for others to provide goods or services to a

customer in exchange for consideration 16 CFR sect 3102(dd) A ldquotelemarketerrdquo

means any person who in connection with telemarketing initiates or receives

telephone calls to or from a customer or donor 16 CFR sect 3102(ff)

ldquoTelemarketingrdquo means a plan program or campaign which is conducted to

induce the purchase of goods or services or a charitable contribution by use of one

or more telephones and which involves more than one interstate telephone call 16

CFR sect 3102(gg)

40 Defendants are sellers or telemarketers of ldquodebt relief servicesrdquo as

defined by the TSR 16 CFR sect 3102(o) Under the TSR a ldquodebt relief servicerdquo

means any program or service represented directly or by implication to

renegotiate settle or in any way alter the terms of payment or other terms of the

debt between a person and one or more unsecured creditors or debt collectors

including but not limited to a reduction in the balance interest rate or fees owed

by a person to an unsecured creditor or debt collector 16 CFR sect 3102(o)

41 The TSR prohibits sellers and telemarketers from requesting or

receiving payment of any fees or consideration for any debt relief service until and

unless

a The seller or telemarketer has renegotiated settled reduced or

otherwise altered the terms of at least one debt pursuant to a

14

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 15 of 57 Page ID

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1774

settlement agreement debt management plan or other such

valid contractual agreement executed by the customer and

b The customer has made at least one payment pursuant to that

settlement agreement debt management plan or other valid

contractual agreement between the customer and the creditor

and

c To the extent that debts enrolled in a service are renegotiated

settled reduced or otherwise altered individually the fee or

consideration either

i Bears the same proportional relationship to the total fee

for renegotiating settling reducing or altering the terms

of the entire debt balance as the individual debt amount

bears to the entire debt amount The individual debt

amount and the entire debt amount are those owed at the

time the debt was enrolled in the service or

ii Is a percentage of the amount saved as a result of the

renegotiation settlement reduction or alteration The

percentage charged cannot change from one individual

debt to another The amount saved is the difference

between the amount owed at the time the debt was

enrolled in the service and the amount actually paid to

satisfy the debt 16 CFR sect 3104(a)(5)(i)

42 The TSR prohibits sellers and telemarketers from misrepresenting

directly or by implication any material aspect of any debt relief service including

but not limited to the amount of money or the percentage of the debt amount that a

customer may save by using the service 16 CFR sect 3103(a)(2)(x)

15

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 16 of 57 Page ID

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1775

43 Pursuant to Section 3(c) of the Telemarketing Act 15 USC

sect 6102(c) and Section 18(d)(3) of the FTC Act 15 USC sect 57a(d)(3) a violation

of the TSR constitutes an unfair or deceptive act or practice in or affecting

commerce in violation of Section 5(a) of the FTC Act 15 USC sect 45(a)

VIOLATIONS OF THE TELEMARKETING SALES RULE

Count Two

(Advance Fee for Debt Relief Services)

44 In numerous instances in connection with the telemarketing of

student loan debt relief services Defendants have requested or received payment

of a fee or consideration for debt relief services before

a Defendants have renegotiated settled reduced or otherwise

altered the terms of at least one debt pursuant to a settlement

agreement debt management plan or other such valid contractual

agreement executed by the customer and

b The customer has made at least one payment pursuant to that

settlement agreement debt management plan or other valid

contractual agreement between the customer and the creditor

45 Defendantsrsquo acts or practices as described in Paragraph 44 of this

Complaint are abusive telemarketing acts or practices that violate Section

3104(a)(5)(i) of the TSR 16 CFR sect 3104(a)(5)(i)

Count Three

(Material Debt Relief Misrepresentations)

46 In numerous instances in connection with the telemarketing of

student loan debt relief services Defendants have misrepresented directly or

indirectly expressly or by implication material aspects of their debt relief services

including but not limited to that consumers who purchase Defendantsrsquo debt relief

services will or likely will have their monthly payments reduced or their loan

16

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 17 of 57 Page ID

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1776

balances forgiven in whole or in part

47 Defendantsrsquo acts and practices as described in Paragraph 46 of this

Complaint are deceptive telemarketing acts or practices that violate Section

3103(a)(2)(x) of the TSR 16 CFR sect 3103(a)(2)(x)

Count Four

(Disgorgement of Ill-Gotten Gains of Relief Defendant)

48 Relief Defendant Noel has received directly or indirectly funds or

other assets from Defendants that are traceable to funds obtained from Defendantsrsquo

customers through the unlawful acts or practices described herein

49 Relief Defendant Noel has no legitimate claim to Defendantsrsquo

customersrsquo funds or other assets and will be unjustly enriched if it is not required to

disgorge the assets or the value of benefits received as a result of Defendantsrsquo

unlawful acts or practices

50 By reason of the foregoing Relief Defendant Noel holds funds and

assets in constructive trust for the benefit of Defendantsrsquo customers

CONSUMER INJURY

51 Consumers have suffered and will continue to suffer substantial injury

as a result of Defendantsrsquo violations of the FTC Act and the TSR In addition

Defendants have been unjustly enriched as a result of their unlawful acts or

practices Absent injunctive relief by this Court Defendants are likely to continue

to injure consumers reap unjust enrichment and harm the public interest

THIS COURTrsquoS POWER TO GRANT RELIEF

52 Section 13(b) of the FTC Act 15 USC sect 53(b) empowers this Court

to grant injunctive and such other relief as the Court may deem appropriate to halt

and redress violations of any provision of law enforced by the FTC The Court in

the exercise of its equitable jurisdiction may award ancillary relief including

rescission or reformation of contracts restitution the refund of monies paid and

17

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 18 of 57 Page ID

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1777

the disgorgement of ill-gotten monies to prevent and remedy any violation of any

provision of law enforced by the FTC

53 Section 6(b) of the Telemarketing Act 15 USC sect 6105(b)

authorizes this Court to grant such relief as the Court finds necessary to redress

injury to consumers resulting from Defendantsrsquo violations of the TSR including

the rescission or reformation of contracts and the refund of money

PRAYER FOR RELIEF

Wherefore Plaintiff FTC pursuant to Section 13(b) of the FTC Act 15

USC sect 53(b) Section 6(b) of the Telemarketing Act 15 USC sect 6105(b) and

the Courtrsquos own equitable powers requests that the Court

A Award Plaintiff such preliminary injunctive and ancillary relief as

may be necessary to avert the likelihood of consumer injury during

the pendency of this action and to preserve the possibility of effective

final relief including but not limited to temporary and preliminary

injunctions orders freezing assets immediate access to business

premises appointment of a receiver and expedited discovery

B Enter a permanent injunction to prevent future violations of the FTC

Act and the TSR

C Award such relief as the Court finds necessary to redress injury to

consumers resulting from Defendantsrsquo violations of the FTC Act and

the TSR including but not limited to rescission or reformation of

contracts restitution the refund of monies paid and the disgorgement

of ill-gotten monies

D Enter an order requiring Relief Defendant to disgorge all funds and

assets or the value of the benefit it received from the funds and assets

which are traceable to funds obtained from Defendantsrsquo customers

through the unlawful acts or practices described herein and

18

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 19 of 57 Page ID 1778

2

3

E Award Plaintiff the costs of bringing this action as well as such other

and additional relief as the Court may determine to be just and proper

Dated February 5 2019

Respectfully submitted

ALDEN F ABBOTT General Counsel

JosaSMillard Brian M Welke middot Barbara Chun (Local Counsel) Attorneys for Plaintiff FEDERAL TRADE COMMISSION

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19

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 20 of 57 Page ID 1779

EXHIBIT A

Attachment A

Free Assessment

Our expercs will lt1ssPss you cun ent

swclent lo n program and decermn which progr ms are

avc11l bl rn yoL11 situation We wi I help you cl11cic1e which progr m r1

help you achieve your goals Call us today

Service Guarantee We are commmecl to 11-1 111g

CllStomers get low r rc1ces ancl monthly payments and we w1I

m ke the pror~ss se mless and s r11ghtforwc1rd ou wi ll be sansf1ed

with our service ml OLlr

cornmcmem to you success Thars ow gu~ ancee

Success Rate Ou1 96 ~ surcPss r a e s 11e of he

cop I a ings tn he industry Olr

process has beer tested nd Olli

succ ss r r~ prowbull~ tn t it works

We c n ll~lp yo reduce and -1111ph y our p ~ymP1 ts Call us today

FTC-AID-1

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 21 of 57 Page ID 1780

20

Exhibit A

ABOUT US

We can help you reduce and simplify your pay1ncnts Contact one of our specialists today for

a free evaluation

111middot 1_I 1

101

t I 11111 I I

Itbull 11

Ill fl I I

bull ~ 0 I

What Makes Us Great fa1(li1-_~ tur1ent ~e11ef 11as a taf- o~middot tt a middotel elt1)rns bullJn st1ncb110

1middot1ep yriJ Tibullmiddotest fi 1e-ndly f3ce~ 113ve eirej e1tc-nsve1yr =inj ire

fanih1~1 bull11iu1 ti~e nul~nce~ cfscrvern rrent Cdid p11vate stucre11

l1J1ns Th~y viill u~e Ui5 epe tise o loik jUl fJ ycur ~Je~t

i(tres~- f)LH ~U(CtS~ ~HE 1h-~ I lSllt of i_r middotDff ancl iur

C ur ~r_(J~l 1o~w- JCl11~crs f(middotil) 3 00Vtli ~tJegy o r ~dUC2 011i

a1r1plfy yliur- - _Je1middott middotcar payr1t11s 1) Asstrnlins Itle ~atl1t1

2) R~~ear c1-1ng Our st~lff wmiddoti11 (lrJUi~oleaerick ]ll fnfcnTnati(-n befort dtmiddoteJPlr~ t tne ri~n 3) rnnk1middotgbullle i_i1 i e~ear (rr i~ ormiddot1 1 1 etc 1Ne

irvi-s t1ga~ii 111 ps~ib le a~irst 1n(t aptlbull~n 4) 1Nr1 ting VVF p1 eiv lii J 11 iUen u tt-igy IJefore vie Uke ut1c-1l i)ecius~ you d-ese11e 11) undi r~~anci

Lhe pr 1cer S) ~ev1sing Al)ng ~r 1udent Relief 1- 1otT11111tt bull) ti) ci e1H1ve ut-l-~n~-l)O c111 i ri 3 Vbulle -~11 leave n1) sti bull1e u11t111 neltl tecause middot~ve

11~1ve your be~ i1~ t~rest 1t l1ein 6) Si~tcl11ng Our note- =1nd r~c)1 ~ ~1 e thorou~ll ln(I pru1ile 1 ceJ1 po cri1~ 1)f vo111 ~1tuJticn s) iny if-oi

~xpe1 t- 01 eou pped to s~1ty1J_J bullVi r you1 c si- 7) De-gn1ng _ fe ~1 t 1nelt--1- f1ts ti 1middotV 1middotid de~ 1middot1 1 st1 iegy to fit ou 1 1_i dque jtct1in so

011 c111 i Jle y1)u1 1vv1middot1 per feet -ut1e-s ~~0 1 v

1bullVlly 1100~e At(J1n~ Sltl(ltnt Fie11e7) (i1_d aclol~Or~ bull -ii~ (1Ualiftel lci ~~~ISt~h 1noie ype-s middotif JS~iSi_ance u~211 Cd ( (11)itXS i1 jG(l1~t) to ti-tgt

p ~n~ 1not con1p n1es can 11i1p bullbullllh ve )t ~ ~qu1pptCI to bull-bullGr k 1bullv1t1middot1 r~ 11t-2 [uo emiddot 1 lc1 r1s ~~nCI cn even iner-1ne frmiddot tt1e c ~e of 1l~e

~1lt ntslmiddoturelt A1cl1rg Sudent Fie1ef 1middot cis mmiddote to )fe 11d we offe1 t with middotmiddot1eltbullbe 1es nI 3 rncney lock guMai-itee

We Have Been Featured In

FTC-AID-2

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 22 of 57 Page ID 1781

21

Exhibit A

SERVICES Wt w gtL

Loan Forgiveness Income Based Payments Loan Consol idation In some cases individuals with A period of financial hardship may You may be able to combine

Fede1middota1 Student Loans may qualify qualify you for an Income Based nultiple federal student loans into to have a portion of the amount Repayment Plan In many cases this one new loan w ith a lower more

owed may be forgiven This means means you pay nothing Unlike a affordable monthly payment Loan

your principal balnce coulcl be defe1 ment the term on your loan consolidation prngrams can l1elp

significantly reduced and you will continues to reduce while the plan is you qualify for additional programs not be expected to repay the in place Your term could reduce like loan forgiveness programs or

forgiven amount while you pay nothing Public Setvice Loan Forgiveness

a III

Private Sector Loan Forgiveness

If you work for a government

organization at a city state or

federa l level you may qualify for tle

PL1blic Service Loan Forgiveness

program To qualify your loans

must be cotisolidated into a specific

repayment plan The balance on

your federai student loans is

forgiven after 120 qualifying

bull C Permanent Disability

Forgivenness If your disability is expected to last

60 months or more you may qualify

for permanent disability forgiveness

Q1alifying for Permnent Disability

Forgiveness requires a visi t to your

doctor and individL1als enrolled in

the program are subject to three

years of post-discharge monitoring

Wage Garnishment Prevention

Federal law requires that the

Department of Education or a

gua1middotanty agency notify you before

111st1tuting wage garnishment You

have tl1e right to a hearing where

you can challenge the stated

amount owed and negotiate the

terms of the repayment scheclule

We can intervene on YOL1PflJl~1D-3

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 23 of 57 Page ID 1782

22

Exhibit A

payments have been made p1middotevent wage gampnishments

A FEW STATISTICS ABOUT STUDENT LOAN CRISIS

12 Trillion National Student Debt I he nitionil student loin debt is

now 17 trillion dollirs 1 trillion of

these are in federil student loans

Let us help you through this national

crisis Cill today for a free

evaluation

40 Million Students with Debt

In 7014 an estimated 40 million

current and former students were in

debt because of student loans If

you are one of the millions of people

struggling to pay student loans

Aiding Student Relief is here to help

$33000 Average Student Debt

The graduating class of 7014

average $33000 of student loan

debt per person Thats $3000 more

than the average in 2013 Dont be

one of the many Let Aiding Student

Relief advocate for you

Aiding Student Relief has helped cmrnllcss 1woplc reduce their student debt_ Their proven business

plan has led lo one of lhc highest s11cclSS raCs in the inltl11slly

John Standiford Associated

FTC-AID-4

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 24 of 57 Page ID 1783

23

Exhibit A

TESTIMONIALS

Til~nks to Aiding Student Rel ief Im middotI middotva ove1vvhelrnecl but Aiding The expemiddotts at l1icl i11g Student Rel ief

s1v ing $250 per month Strrd r~rt Relief expl~ inecl the were ther~ to help me when I process ancl rnacle everytl1ing cle11middot nelclecl 1t rw)s t

and sirnple

I Michael Ma 1in

Entrep e11eu1 Em iiy Jallo1 Ii Pa ul Ch is tia I1se11

Teacher Nurse

With so many programs I didnt middotconso lrclating my loans into one I love my Job but vith my high

know what was ng ht for me My monthly payment hs made life student loan payment was still

sruclent loan aclvsor walked me si1nple1 Now I can focus on 1Nhn bamiddotely getting by I don t kn ow what I

through my optio ns rnd now Imiddotn matters to me would hwe clone wthout Aiding

saving 54 I 11n1omh Stucie1middott Rel refmiddot

Ariel Hemiquez Sales co)SUltant

Stephani Seland-1 Small Busim~ss Owner

AJ 01en Museum Curator

RECENT NEWS

)lt)

o(l ttDrlTI -5

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 25 of 57 Page ID 1784

24

Exhibit A

Student Debt Crisis Business Latest Debt Collective Demands May be largely about smallest Student

borrnwers US News amp World Loan Crisis is fa frorn ove The Debt Collective is a group of Report-May 162015 last month Two new reports suggest the college students calling the Fedemiddotal Reserve Bank of New student loan crisis is easing them-se1ves the Corinthian York repor ced that stuclent loan somewhat as the economy Fifteen who are refusing to pay balances rose to 16 trillio n and improves but the crisis is far back their student loins As pa t that 113 per cent of that is in from ove the College Board of this effort the Debt Collective repo t~ tot31 borrowing fell by 8 has written an open lette to the pEbull1 cent between 2012-13 and Department of Education f l llJ 20 13-14 The organization

About Us 11 1 i~d1middot1r F th~~- h1~ ff t1middot~11middot=cl =i~=middott- 1middot __31middotmiddotIIgt middot bullmiddot11

middot- I ( )ntir il t l~i -r_il fr~~

Address bull middot tc1ltj-1r_ =i ~

middot l t1~t 1middot1 fcJ middot~_1 1 I l11 - Hbull 1 tr

~t (~~ 1 12bull~11 T 1 1- - 8555105400

FTC-AID-6

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 26 of 57 Page ID 1785

25

Exhibit A

f - g+ in O) ~ PRIVACY POLICY

This privacy statement discloses the privacy practices for AidllII Student Relief Because Aiding Studen Relief wonts to demonstrate ts firm commlcmell to your

privacy Aiding Sudent Relief hes greed to disclose ls 1rifor111atlori g1thering and dlssem1n1t1on prct1cts Aidlns Studtrit Relief will notify you of

INFORMATION COLLECTION At-ID USE

Aiding Student Relief is the sole owner of the rformMlon collected on this site We will not sell shire or rent this information 10 others In way different from what Is

disclosed 1n this statement Aldln1 StudeM Relief collects 1nform111on throuah this site from our prospective end existing clients at several different poin on our web

site We use their contact Informii on to send information bout our company and to service exsMs accounts Users may optbullout of rece11ns future malllngs see the

cholceoptbullout section below Contect and Financial information that 1s collected Is used for verifying your name address and other informa1on as well as to boll you for

your use of our Gerv1ces using Information from third party sourcH Information about your computer hardwre and software Is automatically collected by Aiding

Student Relief and may be shared in asgregate with third parties whose services are used for traffic analysis purposes This Ir formation includes your IP address

browser type domain names access times and referring Web site addresses Ths information is no tied to personally Identifiable Information This 1nformatlor s used

by Aiding Student Relief to malMan no Improve the quality of the Hrvct and to senerae statistics resardlng use of he Aiding Student Relief site We use third party

services to bill for serlces and to provide other services like our Live Help chat We store the transcripts from these chats for customer service Improvement These

third party service providers are not permitted to use your infornon for any secondary purposes

Thank you and cheers

FTC-AID-7

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 27 of 57 Page ID 1786

26

Exhibit A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 28 of 57 Page ID 1787

EXHIBIT B

Attachment A

((

z | ~

AIDINGSTUDENTRELIEF

bull bull bull bull bull

13 deg $ $ampdegdeg deg() ˝ amp $$deg( + -+Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 29 of 57 Page ID 1788

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4556789fADlt=gtA9BCAD

DZgtA=EFGHIJFKLMNOPFQOGFHIQRSTLKSUMMNOPLHMTFIVRWXHKKNIFNUNOPRLFGSHKSRVRVNQ

f e=klHMW

9SI]UQMSNSOQOHHPFK YaSTHHVVJFMHcVGNOJVHHFKKPSUHMLIUOQN_PL[KSVFGJPRSDTHRFPLIP=SNDC==GFdFIP9VaNHQTWSRPbHF_PSKSVNMPMHNIO XNNIIFRKNF7IKSQQMHFNDVPOS9IAeTHPdKSUMMFNKHONP 8aF_KSNVPHTNIMNR[POVFgNPTHLNHIgtMFI YTFHIdFFI D9aHVR_KNKHFHIWIQOTHIQbFFP

lt=Dkgt=L]oHUKMMH ihTFNIORI THHVPRFMVKgtNJ_NFFbIVSJI]IFjdGGVNNN lt=TFKPPNF 9DaFGmVHPGRJMFNNQOSGnPFFTNLUNHPMIMTFVNJOKMIWV

27

]UMNOHPFRKNVSHKKISIRWRrGZNJONgtNjTHKHMI=cQgtORHVPKSOUMddUNKSPIdspNVPNq_ lt=gtBTHFHPb=HFILGFHMt DTFuFIUVFRPNTFIMINVWOPRVOQFIV sFQFPHKKH vaIPNFVcSyOFSPRFMRNVOJH_gtVFDVUJAN9FPwFuVFJLFHMP_VTFFdSIIVdNHUPxI=DQSROJGASHIVdDSNMINONPPaHdOHdPFHRIWVFFHdFIGM˙ 01 $2 301 $$3 ( Exhibit B

8

~ldquo

middot

676EBCEDK5ltAC]5EF_5665E7gt5lt7aFb688E588lt76B5E6F8EBAC78lt76cdddefghijhggklmknmopqprpopst u

13 deg $ $ampdegdeg degˇ amp $$deg + -+Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 30 of 57 Page ID 1789 () ( vPSZwPxyYTUZUWWzxPyxSWMZWPU|SWUWYZ~YTY~QSWbullYXRwU~UxSdaggerXQ~UZXvPSZWSOVQSYNOXPRSTUSDaggerPxXYPZPNXRUSPQZXPbullU~SOhellipUNPxyYTUZmdash zUxSZUZXndashYWShellipYYXOwPxyYTUZUWWMNOPQx~YWShellipYYXOYWUƒDaggerU|XU~XPSWXfrasllsaquoPZXRWPxPxUOPQSOVQSYNONPxDaggerUxSZUZX~YWShellipYYXONPxyYTUZUWWmdash

rsaquominus MZ|PUpermilSWUzSOUZXWbdquoDaggerUxYP~PNZSZ|YSRSx~WRYDaggerSOVQSYNOOPQNPxSZMZ|PUpermilSWU~rdquoUDaggerSOUZXzSZmdashMZSZO|SWUWXRYWUSZWOPQDaggerSOZPXRYZymdash zQhellipY|daggerUxTY|UvPSZwPxyYTUZUWWMNOPQbullPxlsquoNPxSyPTUxZUZXPxySZYrsquoSXYPZSXS|YXOWXSXUPxNU~UxSUTUOPQSOVQSYNONPxXRUzQhellipY|daggerUxTY|UvPSZwPxyYTUZUWWDaggerxPyxSmdashsbquotrade f8Ef8E78FCB6C8EŁPQSOhellipUShellipUXP|PhellipYZUQXYDaggerUNU~UxSWXQ~UZXPSZWYZXPPZUZUbullPSZbullYXRSPbullUxPxUSŒPx~ShellipUPZXRODaggerSOUZXmdashvPSZ|PZWPY~SXYPZDaggerxPyxSW|SZRUDaggerOPQVQSYNONPxS~~YXYPZSDaggerxPyxSW YlsquoU PSZ NPxyYTUZUWWDaggerxPyxSWPxzQhellipY|daggerUxTY|UvPSZwPxyYTUZUWWmdash ŠmŸŽıłŠm 57gt8A57A5B= 8E65C76B5E6F8EB5=6G

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^ ˙ ( (

28

Attachment A

01 $2 301 $$3 ( Exhibit B

()(

=4ABC9DEAFBD=FGFHIJKLMJNOMN MRNS mn = nrst = svzhellipu t bulltvDaggerrhellipDaggerurbullbulltuhellipv hellipz~ bullmdashldquordquolsquorsquotrade š oŒŠeuro centpound ` umluml 13 deg $ $ampdegdeg degˇ amp $$deg + -+Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 31 of 57 Page ID 1790

ISNRTUKQINKKNNKL[MRJ PUWQI]MRM qyt|tytzxy rsaquoqNfraslbdquoPUhellipsbquoLUyQhellip rfraslbhellipMNSIKVUQ QNJKvUQsMiexclQQJUx[iexcliexcl_vsect_Qyenyenbrvbarbrvbar uSSRNTPL_LUUMKIaJ_WMIJJKVIONNQJJMWRMIIbQQURKLWIIJQbKLUNKMPTMNQQ_KKRY tbullbulldaggersDaggerv~vhellipmdashryrhellip~mdashrhellipDagger ŸLŽUıQŽbłpermilMtradeœsbquoNtrade_ffRŁyISMŒUQWyNUQŠlsaquo rv45657896lt7ltgt5lt PQKLMIQSNRTUKINQVNOOMVKMWNQKLIJPMXJIKMYZMPIOO NJMOOJLURMNRRMKKLIJ klltko ltgtlt85p5gt5 ouvwxrz ^^ ~ minuspermil tffŁ yenpoundpound KNOWDaggerIreggt4lt97ltndash9ƒ Dagger hellipDaggerlsaquo žko74k57ƒ ƒISNcurrenUIWIbJKWMKJYVNTKM KLONNRqIQQSNNRTUKINQQIJ_JMWNQKLIJJJPMXJIKMcOMUJMVNQKUVK_JUKBHdefABCgDEAFBDghidjlaquopoundbrvbariexclnotvIWIQbDaggerK_WMQKbullMOIMSvOObullIbLKJbullMJMRMW ordf copy

01( $2(301$$3( Exhibit B

29

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 32 of 57 Page ID 1791

EXHIBIT C

Attachment A

~ 111 ~tampi 10 11 ~bull ia1111

Something awesome is coming soon We are buildin somethin ve cool Sta tuned and be at1ent Your atience will be well aid

~lbullrbullUiUffl We can help you reduce and simplify your payments

101 Loan For iveness

1~u 0 (middottmiddotbullmiddotmiddot1 1~=I -- _~

HZamp IMUliULlampRampatiEUWi nmiddot middot-il~ fr middot 8rbullbullrcrr-

_J l _ 1 _f _ur -~t~ u L liYu

~ Income Based Pa ents

bull ~ f I - - I - I - ri u ~u-=lf ~ JU

1-bullA ---rc iM1~~ -~-bullCiel rrcl

~- middot IY 2 i C middot middotJ ll1Jmiddot 0 _ middot_middotIr i

~ LdfiJIMifJ11JJMJllfFffi

middotE-ltecl l2bullJbull iequbullt t11cit t1lt2 CtpCr~middot1e- f

JJd r g-_iraE-1 agltr-middot- ntimiddot middot)middotou

tmiddot_rt- i ic l~1ri ~rbullmiddot middot111~ umiddot -_ d_t-c

fsectmet-Naibullfyen1~poundibllffifftmI

I f-nle Vnot Nune

I ampterYOllrEmall ]

1 ~~~~ 1

If -bull 13n ~Cbull t~middot rct1~j d- gtOY- - hO- irmiddot (bulldbull) plltmiddotmiddot- leemiddotmiddot JOu

1r1cbullmiddotn111f11ri ll1fbull fcrn to ~bull~I

Triin- GU

WAWMyenEIRitiRpoundWt 44 ZiAtillampampI

Exhibit C

Case 818-cv-01987-JLS

-KE

S

Docum

ent 50-1 F

iled 020519 P

age 33 of 57 P

age ID 1792

30

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 34 of 57 Page ID 1793

EXHIBIT D

Attachment A

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Type then hit enter to

bull bull bull bull bull bull bull

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----

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 35 of 57 Page ID 1794

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

infoaidnestcom (800) 555-1212

HOME

ABOUT US

SERVICES

FAQ

BLOG

CONTACT

HOME ABOUT US SERVICES FAQ BLOG CONTACT

1 of 6 462018 945 AM

31

Student Loan Forgiveness Loan Consolidation Student Loan Forgiveness

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 36 of 57 Page ID 1795

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

If you have Federal Student Loans yoursquore in the right place to get those loans reduced forgiven or completely discharged through our student loan forgiveness programs

Get your multiple Federal Student Loans consolidated into one forget about increasing interests and pay month to month at the lowest possible cost

We understand if yoursquore going through some hardship and thatrsquos why with us yoursquoll be able to make monthly payments based on your affordability for as low as $000 depending on your situation

2 of 6 462018 945 AM

32

Knowledge Base

Defaulted Student Loans

Wage Garnishment

Student Loan Rehabilitation

Income Based Repayment Plan

Deferment and Forbearance

Pay As You Earn Repayment Plan

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE Call 561)424-6053 today to go over your options

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 37 of 57 Page ID 1796

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

Our knowledge base is designed to provide information regarding some of the critical topics those with student loans must be aware of to be able to make educated decisions regarding their future

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

A wage garnishment is any legal procedure in which some portion of a personrsquos earnings is required to be withheld by an employer for the payment of a debt

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

With this program your payments change as your income changes and will not be longer than 25 years This is the ideal plan if you are in partial financial hardship Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard plan

Temporarily allowing you to postpone or reduce your federal student loan payments Postponing or reducing your payments may help you avoid default and future garnishments

Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard

3 of 6 462018 945 AM

33

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 38 of 57 Page ID 1797

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

4 of 6 462018 945 AM

34Attachment A

Testimonials

Latest News

Why 2016 Will Be a Big Year For Student Loans

Top Student Loan Refinancing Questions of 2015

Oba mas latest student loan plan

Things You Should Know About Public Service Loan Forgiveness

Recent Posts

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 39 of 57 Page ID 1798

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

5 of 6 462018 945 AM

35

About Us

Contact Info

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 40 of 57 Page ID 1799

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

pay-grandchild-studen

Why 2016 Will Be a Big Year For Student Loans

December 30 2015

12511110_1112367518

Top Student Loan Refinancing Questions of 2015

December 30 2015

We stand by our consultation and quote We are so sure and confident about our services and offers that they are all 100 money back guarantee risk free ndash if we donrsquot do what we promise yoursquoll get your money back

(800) 555-1212 AidnestStudenLoansgmailcom 18100 Von Karman Ave Suite 850 Irvine CA 92612

Futero SAS copy 2015 | Aidnestcom

6 of 6 462018 945

Exhibit D 36Attachment A

AM

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 41 of 57 Page ID 1800

EXHIBIT E

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 42 of 57 Page ID 1801

AIDNEST Let us help you through this national crisis

Call one of our specialists today

Forbearance amp Deferment If you are still in school and struggling to make payments on your student loans You may qualify

for Forbearance amp Deferment

Garnishment Prevention Federal law requires that the Department of Education or guarantee agency notifies you before they

begin garnishing your wages

Loan Forgiveness If you are a teacher public service worker or an individual with total and permanent disability you

httpaidnestcom[442018 115239 AM]

37Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 43 of 57 Page ID 1802

AIDNEST Let us help you through this national crisis

may qualify for this program

Consolidating Your Loans Consolidating your loans to one new loan under one lender may lower your payments and make

your life a bit more manageable

Affordable Payments If you are looking to lower your monthly payments then Income Based Repayment Plans may be

the correct choice for you

Learn more about our services

LEARN MORE

httpaidnestcom[442018 115239 AM]

38Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 44 of 57 Page ID 1803

AIDNEST Let us help you through this national crisis

Loan Forgiveness Programs Income Based Payments Student Loan Rehabilitation

Student Loan Consolidation

You may be eligible for

Loan Forgiveness Programs

In some cases individuals with Federal Student Loans may qualify to have a portion of the amount

owed to be forgiven

Get in touch with our professional team to find out which loan forgiveness program you qualify for and

how you can get rid of your unpaid student loan

L EARN MORE

httpaidnestcom[442018 115239 AM]

39Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 45 of 57 Page ID 1804

AIDNEST Let us help you through this national crisis

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE

Meet your Budget One of our advisers will help you meet your payment goals by using your budget and timeline to

determine the best plan available

httpaidnestcom[442018 115239 AM]

40Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 46 of 57 Page ID 1805

AIDNEST Let us help you through this national crisis

Simple Process We understand that lowering your payments alone can be difficult Our intuitive platform allows us

to keep the entire process simple

Customer Satisfaction We are committed to providing you with outstanding service only We look forward to working

with you

100 money back guarantee No Hassle Money Back Policy

httpaidnestcom[442018 115239 AM]

41Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 47 of 57 Page ID 1806

AIDNEST Let us help you through this national crisis

Lower your loan payments by getting in touch with one of our professionals

We design a customized repayment plan that will allow you to make payments based on your

monthly income family size and spending Get rid of the hassle of extensive paperwork and get the

help you deserve

What we can help you achieve a lower payment or lower rate

httpaidnestcom[442018 115239 AM]

42Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 48 of 57 Page ID 1807

AIDNEST Let us help you through this national crisis

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcom[442018 115239 AM]

43Exhibit E

httpaidnestcomservices[442018 115322 AM]

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 49 of 57 Page ID 1808

Services | AIDNEST Let us help you through this national crisis

INCOME BASED PAYMENTS

If you are suffering from a financial hardship you may be eligible for an

Income Based Payment In this repayment program you would have a

payment based on your income and family size The payment could be as

low as $000 per month with forgiveness at the end of 20-25 years

44

Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 50 of 57 Page ID 1809

L E ARN MORE

LOAN FORGIVENESS

If you have Federal Student Loans you may qualify for any of the student

loan forgiveness programs that are available to borrowers You may be

eligible for principal reduction loan forgiveness or a complete loan

discharge depending on your individual circumstance

L EARN MORE

PRIVATE STUDENT LOAN CONSOLIDATION

Much like refinancing a mortgage generally the biggest benefit of private

student loan consolidationstudent loan refinancing is a lower interest rate

httpaidnestcomservices[442018 115322 AM]

45Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 51 of 57 Page ID 1810

L E ARN MORE

(something federal consolidations do not offer)

STUDENT LOAN REHABILITATION

You can renew eligibility for new loans and grants and eliminate the loan

default by ldquorehabilitatingrdquo a defaulted loan

httpaidnestcomservices[442018 115322 AM]

46Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 52 of 57 Page ID 1811

CHE CK E L E G I B I L I T Y

WAGE GARNISHMENT

A wage garnishment is any legal procedure in which some portion of a

personrsquos earnings is required to be withheld by an employer for the

payment of a debt

L EARN MORE

With our fast friendly and professional services wersquoll be glad to help you get your student loans

reduced forgiven or completely discharged To this end wersquoll assist you in consolidating all your

student loans so yoursquoll have only one lender and yoursquoll start making one monthly payment Our

professionals will walk you through the best and most flexible repayment options and if itrsquos also

necessary varied deferment options and rehabilitation programs

httpaidnestcomservices[442018 115322 AM]

47Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 53 of 57 Page ID 1812

Services | AIDNEST Let us help you through this national crisis

Our CRM System

Our CRM is one of the most advanced in the industry and most importantly itrsquos linked directly to

the Department of Education (DOE) This keeps your personal and most confidential information

safe Furthermore because our CRM system is linked to the DOE our approval is 100 Through

our CRM we will be doing continuous monitoring of our process without losing sight of your

immediate needs ensuring that your case has the proper handling and most efficient process

httpaidnestcomservices[442018 115322 AM]

48Exhibit E

n

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 54 of 57 Page ID 1813

Services | AIDNEST Let us help you through this national crisis

R ECENT POSTS

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

ABOUT US

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcomservices[442018 115322 AM]

49Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 55 of 57 Page ID 1814

EXHIBIT F

s -

bullmiddot - ~ t ~ower Your Student Loan Pay~e~ts oday -- Students Helping Students Save Money

INCOME BASED PAJIIIJITPAIS

I C(gttoUC1 u~

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 56 of 57 Page ID 1815

X + C (D Not secure wwwstudoracom 0

CALL US NOW (85S) 978-S599 middot 1nfostudoracom

HOME SERVICES ABOUT US FAQ CONTACT US BLOC PRIVACY

Offering obligation and commitment free loan relief solutions

STUDENT LOAN FORGIVENESS INCOME BASED PAYMENTS LOAN CONSOLIDATION

We11 help you get your loans reduced forgiven o r Make monthly pdyments based on your affordability Get multiple Federal Student Loans consolidated into

discharged one low monthly payment

Talk to our experts concerning your

student loans

Studora is a pnvatefy owned company that helps consumers like you identify

government programs that fit your financial s1tuat1on Our loan experts will assist you in selecting the appropriate programs that WOltk with your income family size and

desired monthly payment We then prepare the appropriate documents for your review and submission All this f o r one low easy payment

Testimonials

Thank you f o r getting back to me quickly Youve been fabulous Thank you for the confirmation and for your help today Pass

during this whole process Is there a place I can go online that I this on to your sup that you were very professional and very

can leave a comment for your manager Youve made this Robert helpful and brought a sense of relief for me Thank you very

process so easy and answered every question my husband and I much and have a great rest of your day Kudos to you and your

have had teammoneywell spenL

Exhibit F 50

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 57 of 57 Page ID 1816

Services we offer

Stud ora offers document preparation services for all loan forgiveness consolidation and relief services to people who are unable to manage their finances Our mam aim is to

offer complete peace of mind to indiVidual unable to pay their student loan debt

we otter the folloWing document preparation services with complete professional assistance

amFinancial Review ffl Budget Planning

Toe first step to creating a flexible loan repayment plan is financial review we also help create a personal finance plan to ensure that you are able to

Our professmnals will look into your finances and design a custom manage your monthly budget in the most effective way This plan will keep

repayment plan that is affordable and easy to manage your spending to the minimum alloWing you to save more money for loan

repayment

Permanent Disability Forgiveness r-trTeacher Loan Forgiveness (5 You can get rid of your Federal Student Loan if you are permanently disabled Good news for teachers who are under the weight of a massiVe loan You can

now get $17 forgiven on your student loans

Public Service Loan Forgiveness Custom Debt Relief Plans

Want assistance with debt relief Get in touch with our experts who will help If you are a public service agent you can get rid of your loan after 120 days of design a loan repayment and relief plan for you based on your monthly

income and affordability payments

THERE ARE NO OBLIGATIONS OR COMMITMENTS

want to save thousands of dollars Fill out our form and get relief from your student loan for a more

peaceful tomorrow

Your Name

BiHHHi

Exhibit F 51

Attachment A

Page 10: JOSHUA S. MILLARD, BRIAN M. WELKE, pro hac vice · for which it has no legitimate claim. Noel is a Wyoming limited liability company that reported in a public document that its principal

----------

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 10 of 57 Page ID

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1769

ldquoWe can help you reduce and simplify your payments Contact one of our specialists today for a free evaluationrdquo

Ex A at 2 (emphasis in original)

ldquolsquoAiding Student Relief has helped countless people reduce their student debt Their proven business plan has led to one of the highest success rates in the industryrsquordquo

Ex A at 4

100 Customer Satisfaction We can help you reduce and simplify your payments Call one of our specialists

today

Ex B at 1 (aidingstudentscom 2016) (emphasis in original)

Meet some of our members who have saved big on their student loan debt Helping You Save Big

ldquoThanks to Aiding Student Relief I am savings [sic] $250 per monthrdquo Michael Martin Entrepreneur

Ex B at 2 (emphasis in original)

ldquoWe can help you reduce and simplify your payments rdquo

Ex C at 1 (aidingstudentscom 2018) (emphasis in original)

Student Loan

Forgiveness

If you have Federal Student Loans yoursquore in the right place to get those

Loan Forgiveness

Get your multiple Federal Student Loans consolidated into one

10

Student Loan

Forgiveness

We understand if yoursquore going through some hardship and thatrsquos why

Attachment A

Case 818-cv-01987-JLS-KES

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Document 50-1 Filed 020519 Page 11 of 57 Page ID 1770

loans reduced forgiven or completely discharged through our student loan forgiveness programs

forget about increasing interests [sic] and pay month to month at the lowest possible cost

with us yoursquoll be able to make monthly payments based on your affordability for as low as $000 depending on your situation

Ex D at 2 (aidnestcom 2016)

Lower your loan payments by getting in touch with one of our professionals We design a customized repayment plan that will allow you to make payments based on your monthly income family size and spending Get rid of the hassle of extensive paperwork and get the help you deserve

What we can help you achieve [is] a lower payment or lower rate

Ex E at 6 (aidnestcom 2018) (emphasis in original)

STUDENT LOAN FORGIVENESS

Wersquoll help you get your loans reduced forgiven or

discharged

INCOME BASED PAYMENTS

Make monthly payments based on your affordability

LOAN CONSOLIDATION

Get multiple Federal Student Loans

consolidated into one low monthly payment

Ex F at 1 (studoracom 2018) (emphasis in original)

26 In some instances consumers view the Defendantsrsquo online advertising

and call Defendantsrsquo telemarketers for more information Defendants also make

outbound telemarketing calls and send texts to consumers to offer their services

and convince student loan borrowers to sign up for Defendantsrsquo debt relief

services

11

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 12 of 57 Page ID

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1771

27 In calls with consumers Defendantsrsquo telemarketers have told

consumers that Defendants can cause consumersrsquo student loan balances to be

reduced or that consumersrsquo loan balances would be forgiven after making lower

monthly payments Defendantsrsquo telemarketers have told some consumers that over

half their loan balance would be forgiven Moreover Defendantsrsquo telemarketers

have told some consumers that their loan payments could or would be rapidly

reduced to $19 per month or promptly forgiven

28 Defendants have made other representations concerning loan

reduction or forgiveness to consumers in telemarketing their debt relief services

For example Defendantsrsquo telemarketers have told one or more consumers that

ldquofamily sizerdquo a metric for determining the amount borrowers pay each month

under IDR plans includes ldquoanyone you help out throughout the year[] they donrsquot

have to live with yourdquo even claiming that helping with ldquogas money three times

out of the yearrdquo is enough to include a person in ldquofamily sizerdquo Further

Defendantsrsquo telemarketers have offered one or more consumers ldquobasically a

guarantee to remainrdquo in an IDR plan and warned one or more consumers that

signing up for an IDR plan with a lender instead would result in a higher loan

payment

29 Defendants have not been likely to achieve the lower monthly

payments or student loan forgiveness they have advertised marketed and

promoted to consumers In many instances Defendants have failed to obtain the

promised lower monthly payments or student loan forgiveness

30 Defendants have charged consumers fees for purported debt relief

services before achieving lower monthly payments or student loan forgiveness

and in many instances have failed to achieve those results at all on behalf of

consumers

12

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 13 of 57 Page ID

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1772

31 Defendantsrsquo telemarketers have sought and obtained consumersrsquo

payment information by phone or the Internet

32 Defendantsrsquo total advance fees typically have been in the range of

$300-500 Defendants also have charged consumers recurring monthly fees for

purported debt relief services typically charging $19 per month

THE FTC ACT

33 Section 5(a) of the FTC Act 15 USC sect 45(a) prohibits ldquounfair or

deceptive acts or practices in or affecting commercerdquo

34 Misrepresentations or deceptive omissions of material fact constitute

deceptive acts or practices prohibited by Section 5(a) of the FTC Act

VIOLATIONS OF THE FTC ACT

Count One

(Deceptive Student Loan Debt Relief Representations)

35 In numerous instances in connection with the advertising marketing

promotion offering for sale or sale of student loan debt relief services Defendants

have represented directly or indirectly expressly or by implication that consumers

who purchase Defendantsrsquo debt relief services will or likely will have their

monthly payments reduced or their loan balances forgiven in whole or in part

36 In truth and in fact in numerous instances in which Defendants have

made the representations set forth in Paragraph 35 of this Complaint such

representations were false or not substantiated at the time Defendants made them

37 Therefore Defendantsrsquo representations as set forth in Paragraph 35 of

this Complaint are false or misleading and constitute deceptive acts or practices in

violation of Section 5(a) of the FTC Act 15 USC sect 45(a)

THE TELEMARKETING SALES RULE

38 Congress directed the FTC to prescribe rules prohibiting abusive and

deceptive telemarketing acts or practices pursuant to the Telemarketing Act 15

13

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 14 of 57 Page ID

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1773

USC sectsect 6101-6108 in 1994 The FTC adopted the original TSR in 1995

extensively amended it in 2003 and amended certain sections thereafter 16

CFR Part 310

39 Defendants are ldquoseller[s]rdquo or ldquotelemarketer[s]rdquo engaged in

ldquotelemarketingrdquo as defined by the TSR 16 CFR sect 3102(dd) (ff) and (gg) A

ldquosellerrdquo means any person who in connection with a telemarketing transaction

provides offers to provide or arranges for others to provide goods or services to a

customer in exchange for consideration 16 CFR sect 3102(dd) A ldquotelemarketerrdquo

means any person who in connection with telemarketing initiates or receives

telephone calls to or from a customer or donor 16 CFR sect 3102(ff)

ldquoTelemarketingrdquo means a plan program or campaign which is conducted to

induce the purchase of goods or services or a charitable contribution by use of one

or more telephones and which involves more than one interstate telephone call 16

CFR sect 3102(gg)

40 Defendants are sellers or telemarketers of ldquodebt relief servicesrdquo as

defined by the TSR 16 CFR sect 3102(o) Under the TSR a ldquodebt relief servicerdquo

means any program or service represented directly or by implication to

renegotiate settle or in any way alter the terms of payment or other terms of the

debt between a person and one or more unsecured creditors or debt collectors

including but not limited to a reduction in the balance interest rate or fees owed

by a person to an unsecured creditor or debt collector 16 CFR sect 3102(o)

41 The TSR prohibits sellers and telemarketers from requesting or

receiving payment of any fees or consideration for any debt relief service until and

unless

a The seller or telemarketer has renegotiated settled reduced or

otherwise altered the terms of at least one debt pursuant to a

14

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 15 of 57 Page ID

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1774

settlement agreement debt management plan or other such

valid contractual agreement executed by the customer and

b The customer has made at least one payment pursuant to that

settlement agreement debt management plan or other valid

contractual agreement between the customer and the creditor

and

c To the extent that debts enrolled in a service are renegotiated

settled reduced or otherwise altered individually the fee or

consideration either

i Bears the same proportional relationship to the total fee

for renegotiating settling reducing or altering the terms

of the entire debt balance as the individual debt amount

bears to the entire debt amount The individual debt

amount and the entire debt amount are those owed at the

time the debt was enrolled in the service or

ii Is a percentage of the amount saved as a result of the

renegotiation settlement reduction or alteration The

percentage charged cannot change from one individual

debt to another The amount saved is the difference

between the amount owed at the time the debt was

enrolled in the service and the amount actually paid to

satisfy the debt 16 CFR sect 3104(a)(5)(i)

42 The TSR prohibits sellers and telemarketers from misrepresenting

directly or by implication any material aspect of any debt relief service including

but not limited to the amount of money or the percentage of the debt amount that a

customer may save by using the service 16 CFR sect 3103(a)(2)(x)

15

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 16 of 57 Page ID

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1775

43 Pursuant to Section 3(c) of the Telemarketing Act 15 USC

sect 6102(c) and Section 18(d)(3) of the FTC Act 15 USC sect 57a(d)(3) a violation

of the TSR constitutes an unfair or deceptive act or practice in or affecting

commerce in violation of Section 5(a) of the FTC Act 15 USC sect 45(a)

VIOLATIONS OF THE TELEMARKETING SALES RULE

Count Two

(Advance Fee for Debt Relief Services)

44 In numerous instances in connection with the telemarketing of

student loan debt relief services Defendants have requested or received payment

of a fee or consideration for debt relief services before

a Defendants have renegotiated settled reduced or otherwise

altered the terms of at least one debt pursuant to a settlement

agreement debt management plan or other such valid contractual

agreement executed by the customer and

b The customer has made at least one payment pursuant to that

settlement agreement debt management plan or other valid

contractual agreement between the customer and the creditor

45 Defendantsrsquo acts or practices as described in Paragraph 44 of this

Complaint are abusive telemarketing acts or practices that violate Section

3104(a)(5)(i) of the TSR 16 CFR sect 3104(a)(5)(i)

Count Three

(Material Debt Relief Misrepresentations)

46 In numerous instances in connection with the telemarketing of

student loan debt relief services Defendants have misrepresented directly or

indirectly expressly or by implication material aspects of their debt relief services

including but not limited to that consumers who purchase Defendantsrsquo debt relief

services will or likely will have their monthly payments reduced or their loan

16

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 17 of 57 Page ID

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1776

balances forgiven in whole or in part

47 Defendantsrsquo acts and practices as described in Paragraph 46 of this

Complaint are deceptive telemarketing acts or practices that violate Section

3103(a)(2)(x) of the TSR 16 CFR sect 3103(a)(2)(x)

Count Four

(Disgorgement of Ill-Gotten Gains of Relief Defendant)

48 Relief Defendant Noel has received directly or indirectly funds or

other assets from Defendants that are traceable to funds obtained from Defendantsrsquo

customers through the unlawful acts or practices described herein

49 Relief Defendant Noel has no legitimate claim to Defendantsrsquo

customersrsquo funds or other assets and will be unjustly enriched if it is not required to

disgorge the assets or the value of benefits received as a result of Defendantsrsquo

unlawful acts or practices

50 By reason of the foregoing Relief Defendant Noel holds funds and

assets in constructive trust for the benefit of Defendantsrsquo customers

CONSUMER INJURY

51 Consumers have suffered and will continue to suffer substantial injury

as a result of Defendantsrsquo violations of the FTC Act and the TSR In addition

Defendants have been unjustly enriched as a result of their unlawful acts or

practices Absent injunctive relief by this Court Defendants are likely to continue

to injure consumers reap unjust enrichment and harm the public interest

THIS COURTrsquoS POWER TO GRANT RELIEF

52 Section 13(b) of the FTC Act 15 USC sect 53(b) empowers this Court

to grant injunctive and such other relief as the Court may deem appropriate to halt

and redress violations of any provision of law enforced by the FTC The Court in

the exercise of its equitable jurisdiction may award ancillary relief including

rescission or reformation of contracts restitution the refund of monies paid and

17

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 18 of 57 Page ID

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1777

the disgorgement of ill-gotten monies to prevent and remedy any violation of any

provision of law enforced by the FTC

53 Section 6(b) of the Telemarketing Act 15 USC sect 6105(b)

authorizes this Court to grant such relief as the Court finds necessary to redress

injury to consumers resulting from Defendantsrsquo violations of the TSR including

the rescission or reformation of contracts and the refund of money

PRAYER FOR RELIEF

Wherefore Plaintiff FTC pursuant to Section 13(b) of the FTC Act 15

USC sect 53(b) Section 6(b) of the Telemarketing Act 15 USC sect 6105(b) and

the Courtrsquos own equitable powers requests that the Court

A Award Plaintiff such preliminary injunctive and ancillary relief as

may be necessary to avert the likelihood of consumer injury during

the pendency of this action and to preserve the possibility of effective

final relief including but not limited to temporary and preliminary

injunctions orders freezing assets immediate access to business

premises appointment of a receiver and expedited discovery

B Enter a permanent injunction to prevent future violations of the FTC

Act and the TSR

C Award such relief as the Court finds necessary to redress injury to

consumers resulting from Defendantsrsquo violations of the FTC Act and

the TSR including but not limited to rescission or reformation of

contracts restitution the refund of monies paid and the disgorgement

of ill-gotten monies

D Enter an order requiring Relief Defendant to disgorge all funds and

assets or the value of the benefit it received from the funds and assets

which are traceable to funds obtained from Defendantsrsquo customers

through the unlawful acts or practices described herein and

18

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 19 of 57 Page ID 1778

2

3

E Award Plaintiff the costs of bringing this action as well as such other

and additional relief as the Court may determine to be just and proper

Dated February 5 2019

Respectfully submitted

ALDEN F ABBOTT General Counsel

JosaSMillard Brian M Welke middot Barbara Chun (Local Counsel) Attorneys for Plaintiff FEDERAL TRADE COMMISSION

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Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 20 of 57 Page ID 1779

EXHIBIT A

Attachment A

Free Assessment

Our expercs will lt1ssPss you cun ent

swclent lo n program and decermn which progr ms are

avc11l bl rn yoL11 situation We wi I help you cl11cic1e which progr m r1

help you achieve your goals Call us today

Service Guarantee We are commmecl to 11-1 111g

CllStomers get low r rc1ces ancl monthly payments and we w1I

m ke the pror~ss se mless and s r11ghtforwc1rd ou wi ll be sansf1ed

with our service ml OLlr

cornmcmem to you success Thars ow gu~ ancee

Success Rate Ou1 96 ~ surcPss r a e s 11e of he

cop I a ings tn he industry Olr

process has beer tested nd Olli

succ ss r r~ prowbull~ tn t it works

We c n ll~lp yo reduce and -1111ph y our p ~ymP1 ts Call us today

FTC-AID-1

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 21 of 57 Page ID 1780

20

Exhibit A

ABOUT US

We can help you reduce and simplify your pay1ncnts Contact one of our specialists today for

a free evaluation

111middot 1_I 1

101

t I 11111 I I

Itbull 11

Ill fl I I

bull ~ 0 I

What Makes Us Great fa1(li1-_~ tur1ent ~e11ef 11as a taf- o~middot tt a middotel elt1)rns bullJn st1ncb110

1middot1ep yriJ Tibullmiddotest fi 1e-ndly f3ce~ 113ve eirej e1tc-nsve1yr =inj ire

fanih1~1 bull11iu1 ti~e nul~nce~ cfscrvern rrent Cdid p11vate stucre11

l1J1ns Th~y viill u~e Ui5 epe tise o loik jUl fJ ycur ~Je~t

i(tres~- f)LH ~U(CtS~ ~HE 1h-~ I lSllt of i_r middotDff ancl iur

C ur ~r_(J~l 1o~w- JCl11~crs f(middotil) 3 00Vtli ~tJegy o r ~dUC2 011i

a1r1plfy yliur- - _Je1middott middotcar payr1t11s 1) Asstrnlins Itle ~atl1t1

2) R~~ear c1-1ng Our st~lff wmiddoti11 (lrJUi~oleaerick ]ll fnfcnTnati(-n befort dtmiddoteJPlr~ t tne ri~n 3) rnnk1middotgbullle i_i1 i e~ear (rr i~ ormiddot1 1 1 etc 1Ne

irvi-s t1ga~ii 111 ps~ib le a~irst 1n(t aptlbull~n 4) 1Nr1 ting VVF p1 eiv lii J 11 iUen u tt-igy IJefore vie Uke ut1c-1l i)ecius~ you d-ese11e 11) undi r~~anci

Lhe pr 1cer S) ~ev1sing Al)ng ~r 1udent Relief 1- 1otT11111tt bull) ti) ci e1H1ve ut-l-~n~-l)O c111 i ri 3 Vbulle -~11 leave n1) sti bull1e u11t111 neltl tecause middot~ve

11~1ve your be~ i1~ t~rest 1t l1ein 6) Si~tcl11ng Our note- =1nd r~c)1 ~ ~1 e thorou~ll ln(I pru1ile 1 ceJ1 po cri1~ 1)f vo111 ~1tuJticn s) iny if-oi

~xpe1 t- 01 eou pped to s~1ty1J_J bullVi r you1 c si- 7) De-gn1ng _ fe ~1 t 1nelt--1- f1ts ti 1middotV 1middotid de~ 1middot1 1 st1 iegy to fit ou 1 1_i dque jtct1in so

011 c111 i Jle y1)u1 1vv1middot1 per feet -ut1e-s ~~0 1 v

1bullVlly 1100~e At(J1n~ Sltl(ltnt Fie11e7) (i1_d aclol~Or~ bull -ii~ (1Ualiftel lci ~~~ISt~h 1noie ype-s middotif JS~iSi_ance u~211 Cd ( (11)itXS i1 jG(l1~t) to ti-tgt

p ~n~ 1not con1p n1es can 11i1p bullbullllh ve )t ~ ~qu1pptCI to bull-bullGr k 1bullv1t1middot1 r~ 11t-2 [uo emiddot 1 lc1 r1s ~~nCI cn even iner-1ne frmiddot tt1e c ~e of 1l~e

~1lt ntslmiddoturelt A1cl1rg Sudent Fie1ef 1middot cis mmiddote to )fe 11d we offe1 t with middotmiddot1eltbullbe 1es nI 3 rncney lock guMai-itee

We Have Been Featured In

FTC-AID-2

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 22 of 57 Page ID 1781

21

Exhibit A

SERVICES Wt w gtL

Loan Forgiveness Income Based Payments Loan Consol idation In some cases individuals with A period of financial hardship may You may be able to combine

Fede1middota1 Student Loans may qualify qualify you for an Income Based nultiple federal student loans into to have a portion of the amount Repayment Plan In many cases this one new loan w ith a lower more

owed may be forgiven This means means you pay nothing Unlike a affordable monthly payment Loan

your principal balnce coulcl be defe1 ment the term on your loan consolidation prngrams can l1elp

significantly reduced and you will continues to reduce while the plan is you qualify for additional programs not be expected to repay the in place Your term could reduce like loan forgiveness programs or

forgiven amount while you pay nothing Public Setvice Loan Forgiveness

a III

Private Sector Loan Forgiveness

If you work for a government

organization at a city state or

federa l level you may qualify for tle

PL1blic Service Loan Forgiveness

program To qualify your loans

must be cotisolidated into a specific

repayment plan The balance on

your federai student loans is

forgiven after 120 qualifying

bull C Permanent Disability

Forgivenness If your disability is expected to last

60 months or more you may qualify

for permanent disability forgiveness

Q1alifying for Permnent Disability

Forgiveness requires a visi t to your

doctor and individL1als enrolled in

the program are subject to three

years of post-discharge monitoring

Wage Garnishment Prevention

Federal law requires that the

Department of Education or a

gua1middotanty agency notify you before

111st1tuting wage garnishment You

have tl1e right to a hearing where

you can challenge the stated

amount owed and negotiate the

terms of the repayment scheclule

We can intervene on YOL1PflJl~1D-3

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 23 of 57 Page ID 1782

22

Exhibit A

payments have been made p1middotevent wage gampnishments

A FEW STATISTICS ABOUT STUDENT LOAN CRISIS

12 Trillion National Student Debt I he nitionil student loin debt is

now 17 trillion dollirs 1 trillion of

these are in federil student loans

Let us help you through this national

crisis Cill today for a free

evaluation

40 Million Students with Debt

In 7014 an estimated 40 million

current and former students were in

debt because of student loans If

you are one of the millions of people

struggling to pay student loans

Aiding Student Relief is here to help

$33000 Average Student Debt

The graduating class of 7014

average $33000 of student loan

debt per person Thats $3000 more

than the average in 2013 Dont be

one of the many Let Aiding Student

Relief advocate for you

Aiding Student Relief has helped cmrnllcss 1woplc reduce their student debt_ Their proven business

plan has led lo one of lhc highest s11cclSS raCs in the inltl11slly

John Standiford Associated

FTC-AID-4

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 24 of 57 Page ID 1783

23

Exhibit A

TESTIMONIALS

Til~nks to Aiding Student Rel ief Im middotI middotva ove1vvhelrnecl but Aiding The expemiddotts at l1icl i11g Student Rel ief

s1v ing $250 per month Strrd r~rt Relief expl~ inecl the were ther~ to help me when I process ancl rnacle everytl1ing cle11middot nelclecl 1t rw)s t

and sirnple

I Michael Ma 1in

Entrep e11eu1 Em iiy Jallo1 Ii Pa ul Ch is tia I1se11

Teacher Nurse

With so many programs I didnt middotconso lrclating my loans into one I love my Job but vith my high

know what was ng ht for me My monthly payment hs made life student loan payment was still

sruclent loan aclvsor walked me si1nple1 Now I can focus on 1Nhn bamiddotely getting by I don t kn ow what I

through my optio ns rnd now Imiddotn matters to me would hwe clone wthout Aiding

saving 54 I 11n1omh Stucie1middott Rel refmiddot

Ariel Hemiquez Sales co)SUltant

Stephani Seland-1 Small Busim~ss Owner

AJ 01en Museum Curator

RECENT NEWS

)lt)

o(l ttDrlTI -5

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 25 of 57 Page ID 1784

24

Exhibit A

Student Debt Crisis Business Latest Debt Collective Demands May be largely about smallest Student

borrnwers US News amp World Loan Crisis is fa frorn ove The Debt Collective is a group of Report-May 162015 last month Two new reports suggest the college students calling the Fedemiddotal Reserve Bank of New student loan crisis is easing them-se1ves the Corinthian York repor ced that stuclent loan somewhat as the economy Fifteen who are refusing to pay balances rose to 16 trillio n and improves but the crisis is far back their student loins As pa t that 113 per cent of that is in from ove the College Board of this effort the Debt Collective repo t~ tot31 borrowing fell by 8 has written an open lette to the pEbull1 cent between 2012-13 and Department of Education f l llJ 20 13-14 The organization

About Us 11 1 i~d1middot1r F th~~- h1~ ff t1middot~11middot=cl =i~=middott- 1middot __31middotmiddotIIgt middot bullmiddot11

middot- I ( )ntir il t l~i -r_il fr~~

Address bull middot tc1ltj-1r_ =i ~

middot l t1~t 1middot1 fcJ middot~_1 1 I l11 - Hbull 1 tr

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FTC-AID-6

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 26 of 57 Page ID 1785

25

Exhibit A

f - g+ in O) ~ PRIVACY POLICY

This privacy statement discloses the privacy practices for AidllII Student Relief Because Aiding Studen Relief wonts to demonstrate ts firm commlcmell to your

privacy Aiding Sudent Relief hes greed to disclose ls 1rifor111atlori g1thering and dlssem1n1t1on prct1cts Aidlns Studtrit Relief will notify you of

INFORMATION COLLECTION At-ID USE

Aiding Student Relief is the sole owner of the rformMlon collected on this site We will not sell shire or rent this information 10 others In way different from what Is

disclosed 1n this statement Aldln1 StudeM Relief collects 1nform111on throuah this site from our prospective end existing clients at several different poin on our web

site We use their contact Informii on to send information bout our company and to service exsMs accounts Users may optbullout of rece11ns future malllngs see the

cholceoptbullout section below Contect and Financial information that 1s collected Is used for verifying your name address and other informa1on as well as to boll you for

your use of our Gerv1ces using Information from third party sourcH Information about your computer hardwre and software Is automatically collected by Aiding

Student Relief and may be shared in asgregate with third parties whose services are used for traffic analysis purposes This Ir formation includes your IP address

browser type domain names access times and referring Web site addresses Ths information is no tied to personally Identifiable Information This 1nformatlor s used

by Aiding Student Relief to malMan no Improve the quality of the Hrvct and to senerae statistics resardlng use of he Aiding Student Relief site We use third party

services to bill for serlces and to provide other services like our Live Help chat We store the transcripts from these chats for customer service Improvement These

third party service providers are not permitted to use your infornon for any secondary purposes

Thank you and cheers

FTC-AID-7

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 27 of 57 Page ID 1786

26

Exhibit A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 28 of 57 Page ID 1787

EXHIBIT B

Attachment A

((

z | ~

AIDINGSTUDENTRELIEF

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f e=klHMW

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27

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8

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^ ˙ ( (

28

Attachment A

01 $2 301 $$3 ( Exhibit B

()(

=4ABC9DEAFBD=FGFHIJKLMJNOMN MRNS mn = nrst = svzhellipu t bulltvDaggerrhellipDaggerurbullbulltuhellipv hellipz~ bullmdashldquordquolsquorsquotrade š oŒŠeuro centpound ` umluml 13 deg $ $ampdegdeg degˇ amp $$deg + -+Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 31 of 57 Page ID 1790

ISNRTUKQINKKNNKL[MRJ PUWQI]MRM qyt|tytzxy rsaquoqNfraslbdquoPUhellipsbquoLUyQhellip rfraslbhellipMNSIKVUQ QNJKvUQsMiexclQQJUx[iexcliexcl_vsect_Qyenyenbrvbarbrvbar uSSRNTPL_LUUMKIaJ_WMIJJKVIONNQJJMWRMIIbQQURKLWIIJQbKLUNKMPTMNQQ_KKRY tbullbulldaggersDaggerv~vhellipmdashryrhellip~mdashrhellipDagger ŸLŽUıQŽbłpermilMtradeœsbquoNtrade_ffRŁyISMŒUQWyNUQŠlsaquo rv45657896lt7ltgt5lt PQKLMIQSNRTUKINQVNOOMVKMWNQKLIJPMXJIKMYZMPIOO NJMOOJLURMNRRMKKLIJ klltko ltgtlt85p5gt5 ouvwxrz ^^ ~ minuspermil tffŁ yenpoundpound KNOWDaggerIreggt4lt97ltndash9ƒ Dagger hellipDaggerlsaquo žko74k57ƒ ƒISNcurrenUIWIbJKWMKJYVNTKM KLONNRqIQQSNNRTUKINQQIJ_JMWNQKLIJJJPMXJIKMcOMUJMVNQKUVK_JUKBHdefABCgDEAFBDghidjlaquopoundbrvbariexclnotvIWIQbDaggerK_WMQKbullMOIMSvOObullIbLKJbullMJMRMW ordf copy

01( $2(301$$3( Exhibit B

29

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 32 of 57 Page ID 1791

EXHIBIT C

Attachment A

~ 111 ~tampi 10 11 ~bull ia1111

Something awesome is coming soon We are buildin somethin ve cool Sta tuned and be at1ent Your atience will be well aid

~lbullrbullUiUffl We can help you reduce and simplify your payments

101 Loan For iveness

1~u 0 (middottmiddotbullmiddotmiddot1 1~=I -- _~

HZamp IMUliULlampRampatiEUWi nmiddot middot-il~ fr middot 8rbullbullrcrr-

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~ Income Based Pa ents

bull ~ f I - - I - I - ri u ~u-=lf ~ JU

1-bullA ---rc iM1~~ -~-bullCiel rrcl

~- middot IY 2 i C middot middotJ ll1Jmiddot 0 _ middot_middotIr i

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If -bull 13n ~Cbull t~middot rct1~j d- gtOY- - hO- irmiddot (bulldbull) plltmiddotmiddot- leemiddotmiddot JOu

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WAWMyenEIRitiRpoundWt 44 ZiAtillampampI

Exhibit C

Case 818-cv-01987-JLS

-KE

S

Docum

ent 50-1 F

iled 020519 P

age 33 of 57 P

age ID 1792

30

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 34 of 57 Page ID 1793

EXHIBIT D

Attachment A

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Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 35 of 57 Page ID 1794

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

infoaidnestcom (800) 555-1212

HOME

ABOUT US

SERVICES

FAQ

BLOG

CONTACT

HOME ABOUT US SERVICES FAQ BLOG CONTACT

1 of 6 462018 945 AM

31

Student Loan Forgiveness Loan Consolidation Student Loan Forgiveness

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 36 of 57 Page ID 1795

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

If you have Federal Student Loans yoursquore in the right place to get those loans reduced forgiven or completely discharged through our student loan forgiveness programs

Get your multiple Federal Student Loans consolidated into one forget about increasing interests and pay month to month at the lowest possible cost

We understand if yoursquore going through some hardship and thatrsquos why with us yoursquoll be able to make monthly payments based on your affordability for as low as $000 depending on your situation

2 of 6 462018 945 AM

32

Knowledge Base

Defaulted Student Loans

Wage Garnishment

Student Loan Rehabilitation

Income Based Repayment Plan

Deferment and Forbearance

Pay As You Earn Repayment Plan

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE Call 561)424-6053 today to go over your options

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 37 of 57 Page ID 1796

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

Our knowledge base is designed to provide information regarding some of the critical topics those with student loans must be aware of to be able to make educated decisions regarding their future

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

A wage garnishment is any legal procedure in which some portion of a personrsquos earnings is required to be withheld by an employer for the payment of a debt

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

With this program your payments change as your income changes and will not be longer than 25 years This is the ideal plan if you are in partial financial hardship Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard plan

Temporarily allowing you to postpone or reduce your federal student loan payments Postponing or reducing your payments may help you avoid default and future garnishments

Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard

3 of 6 462018 945 AM

33

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 38 of 57 Page ID 1797

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

4 of 6 462018 945 AM

34Attachment A

Testimonials

Latest News

Why 2016 Will Be a Big Year For Student Loans

Top Student Loan Refinancing Questions of 2015

Oba mas latest student loan plan

Things You Should Know About Public Service Loan Forgiveness

Recent Posts

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 39 of 57 Page ID 1798

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

5 of 6 462018 945 AM

35

About Us

Contact Info

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 40 of 57 Page ID 1799

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

pay-grandchild-studen

Why 2016 Will Be a Big Year For Student Loans

December 30 2015

12511110_1112367518

Top Student Loan Refinancing Questions of 2015

December 30 2015

We stand by our consultation and quote We are so sure and confident about our services and offers that they are all 100 money back guarantee risk free ndash if we donrsquot do what we promise yoursquoll get your money back

(800) 555-1212 AidnestStudenLoansgmailcom 18100 Von Karman Ave Suite 850 Irvine CA 92612

Futero SAS copy 2015 | Aidnestcom

6 of 6 462018 945

Exhibit D 36Attachment A

AM

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 41 of 57 Page ID 1800

EXHIBIT E

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 42 of 57 Page ID 1801

AIDNEST Let us help you through this national crisis

Call one of our specialists today

Forbearance amp Deferment If you are still in school and struggling to make payments on your student loans You may qualify

for Forbearance amp Deferment

Garnishment Prevention Federal law requires that the Department of Education or guarantee agency notifies you before they

begin garnishing your wages

Loan Forgiveness If you are a teacher public service worker or an individual with total and permanent disability you

httpaidnestcom[442018 115239 AM]

37Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 43 of 57 Page ID 1802

AIDNEST Let us help you through this national crisis

may qualify for this program

Consolidating Your Loans Consolidating your loans to one new loan under one lender may lower your payments and make

your life a bit more manageable

Affordable Payments If you are looking to lower your monthly payments then Income Based Repayment Plans may be

the correct choice for you

Learn more about our services

LEARN MORE

httpaidnestcom[442018 115239 AM]

38Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 44 of 57 Page ID 1803

AIDNEST Let us help you through this national crisis

Loan Forgiveness Programs Income Based Payments Student Loan Rehabilitation

Student Loan Consolidation

You may be eligible for

Loan Forgiveness Programs

In some cases individuals with Federal Student Loans may qualify to have a portion of the amount

owed to be forgiven

Get in touch with our professional team to find out which loan forgiveness program you qualify for and

how you can get rid of your unpaid student loan

L EARN MORE

httpaidnestcom[442018 115239 AM]

39Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 45 of 57 Page ID 1804

AIDNEST Let us help you through this national crisis

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE

Meet your Budget One of our advisers will help you meet your payment goals by using your budget and timeline to

determine the best plan available

httpaidnestcom[442018 115239 AM]

40Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 46 of 57 Page ID 1805

AIDNEST Let us help you through this national crisis

Simple Process We understand that lowering your payments alone can be difficult Our intuitive platform allows us

to keep the entire process simple

Customer Satisfaction We are committed to providing you with outstanding service only We look forward to working

with you

100 money back guarantee No Hassle Money Back Policy

httpaidnestcom[442018 115239 AM]

41Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 47 of 57 Page ID 1806

AIDNEST Let us help you through this national crisis

Lower your loan payments by getting in touch with one of our professionals

We design a customized repayment plan that will allow you to make payments based on your

monthly income family size and spending Get rid of the hassle of extensive paperwork and get the

help you deserve

What we can help you achieve a lower payment or lower rate

httpaidnestcom[442018 115239 AM]

42Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 48 of 57 Page ID 1807

AIDNEST Let us help you through this national crisis

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcom[442018 115239 AM]

43Exhibit E

httpaidnestcomservices[442018 115322 AM]

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 49 of 57 Page ID 1808

Services | AIDNEST Let us help you through this national crisis

INCOME BASED PAYMENTS

If you are suffering from a financial hardship you may be eligible for an

Income Based Payment In this repayment program you would have a

payment based on your income and family size The payment could be as

low as $000 per month with forgiveness at the end of 20-25 years

44

Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 50 of 57 Page ID 1809

L E ARN MORE

LOAN FORGIVENESS

If you have Federal Student Loans you may qualify for any of the student

loan forgiveness programs that are available to borrowers You may be

eligible for principal reduction loan forgiveness or a complete loan

discharge depending on your individual circumstance

L EARN MORE

PRIVATE STUDENT LOAN CONSOLIDATION

Much like refinancing a mortgage generally the biggest benefit of private

student loan consolidationstudent loan refinancing is a lower interest rate

httpaidnestcomservices[442018 115322 AM]

45Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 51 of 57 Page ID 1810

L E ARN MORE

(something federal consolidations do not offer)

STUDENT LOAN REHABILITATION

You can renew eligibility for new loans and grants and eliminate the loan

default by ldquorehabilitatingrdquo a defaulted loan

httpaidnestcomservices[442018 115322 AM]

46Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 52 of 57 Page ID 1811

CHE CK E L E G I B I L I T Y

WAGE GARNISHMENT

A wage garnishment is any legal procedure in which some portion of a

personrsquos earnings is required to be withheld by an employer for the

payment of a debt

L EARN MORE

With our fast friendly and professional services wersquoll be glad to help you get your student loans

reduced forgiven or completely discharged To this end wersquoll assist you in consolidating all your

student loans so yoursquoll have only one lender and yoursquoll start making one monthly payment Our

professionals will walk you through the best and most flexible repayment options and if itrsquos also

necessary varied deferment options and rehabilitation programs

httpaidnestcomservices[442018 115322 AM]

47Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 53 of 57 Page ID 1812

Services | AIDNEST Let us help you through this national crisis

Our CRM System

Our CRM is one of the most advanced in the industry and most importantly itrsquos linked directly to

the Department of Education (DOE) This keeps your personal and most confidential information

safe Furthermore because our CRM system is linked to the DOE our approval is 100 Through

our CRM we will be doing continuous monitoring of our process without losing sight of your

immediate needs ensuring that your case has the proper handling and most efficient process

httpaidnestcomservices[442018 115322 AM]

48Exhibit E

n

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 54 of 57 Page ID 1813

Services | AIDNEST Let us help you through this national crisis

R ECENT POSTS

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

ABOUT US

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcomservices[442018 115322 AM]

49Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 55 of 57 Page ID 1814

EXHIBIT F

s -

bullmiddot - ~ t ~ower Your Student Loan Pay~e~ts oday -- Students Helping Students Save Money

INCOME BASED PAJIIIJITPAIS

I C(gttoUC1 u~

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 56 of 57 Page ID 1815

X + C (D Not secure wwwstudoracom 0

CALL US NOW (85S) 978-S599 middot 1nfostudoracom

HOME SERVICES ABOUT US FAQ CONTACT US BLOC PRIVACY

Offering obligation and commitment free loan relief solutions

STUDENT LOAN FORGIVENESS INCOME BASED PAYMENTS LOAN CONSOLIDATION

We11 help you get your loans reduced forgiven o r Make monthly pdyments based on your affordability Get multiple Federal Student Loans consolidated into

discharged one low monthly payment

Talk to our experts concerning your

student loans

Studora is a pnvatefy owned company that helps consumers like you identify

government programs that fit your financial s1tuat1on Our loan experts will assist you in selecting the appropriate programs that WOltk with your income family size and

desired monthly payment We then prepare the appropriate documents for your review and submission All this f o r one low easy payment

Testimonials

Thank you f o r getting back to me quickly Youve been fabulous Thank you for the confirmation and for your help today Pass

during this whole process Is there a place I can go online that I this on to your sup that you were very professional and very

can leave a comment for your manager Youve made this Robert helpful and brought a sense of relief for me Thank you very

process so easy and answered every question my husband and I much and have a great rest of your day Kudos to you and your

have had teammoneywell spenL

Exhibit F 50

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 57 of 57 Page ID 1816

Services we offer

Stud ora offers document preparation services for all loan forgiveness consolidation and relief services to people who are unable to manage their finances Our mam aim is to

offer complete peace of mind to indiVidual unable to pay their student loan debt

we otter the folloWing document preparation services with complete professional assistance

amFinancial Review ffl Budget Planning

Toe first step to creating a flexible loan repayment plan is financial review we also help create a personal finance plan to ensure that you are able to

Our professmnals will look into your finances and design a custom manage your monthly budget in the most effective way This plan will keep

repayment plan that is affordable and easy to manage your spending to the minimum alloWing you to save more money for loan

repayment

Permanent Disability Forgiveness r-trTeacher Loan Forgiveness (5 You can get rid of your Federal Student Loan if you are permanently disabled Good news for teachers who are under the weight of a massiVe loan You can

now get $17 forgiven on your student loans

Public Service Loan Forgiveness Custom Debt Relief Plans

Want assistance with debt relief Get in touch with our experts who will help If you are a public service agent you can get rid of your loan after 120 days of design a loan repayment and relief plan for you based on your monthly

income and affordability payments

THERE ARE NO OBLIGATIONS OR COMMITMENTS

want to save thousands of dollars Fill out our form and get relief from your student loan for a more

peaceful tomorrow

Your Name

BiHHHi

Exhibit F 51

Attachment A

Page 11: JOSHUA S. MILLARD, BRIAN M. WELKE, pro hac vice · for which it has no legitimate claim. Noel is a Wyoming limited liability company that reported in a public document that its principal

Case 818-cv-01987-JLS-KES

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Document 50-1 Filed 020519 Page 11 of 57 Page ID 1770

loans reduced forgiven or completely discharged through our student loan forgiveness programs

forget about increasing interests [sic] and pay month to month at the lowest possible cost

with us yoursquoll be able to make monthly payments based on your affordability for as low as $000 depending on your situation

Ex D at 2 (aidnestcom 2016)

Lower your loan payments by getting in touch with one of our professionals We design a customized repayment plan that will allow you to make payments based on your monthly income family size and spending Get rid of the hassle of extensive paperwork and get the help you deserve

What we can help you achieve [is] a lower payment or lower rate

Ex E at 6 (aidnestcom 2018) (emphasis in original)

STUDENT LOAN FORGIVENESS

Wersquoll help you get your loans reduced forgiven or

discharged

INCOME BASED PAYMENTS

Make monthly payments based on your affordability

LOAN CONSOLIDATION

Get multiple Federal Student Loans

consolidated into one low monthly payment

Ex F at 1 (studoracom 2018) (emphasis in original)

26 In some instances consumers view the Defendantsrsquo online advertising

and call Defendantsrsquo telemarketers for more information Defendants also make

outbound telemarketing calls and send texts to consumers to offer their services

and convince student loan borrowers to sign up for Defendantsrsquo debt relief

services

11

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 12 of 57 Page ID

1

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1771

27 In calls with consumers Defendantsrsquo telemarketers have told

consumers that Defendants can cause consumersrsquo student loan balances to be

reduced or that consumersrsquo loan balances would be forgiven after making lower

monthly payments Defendantsrsquo telemarketers have told some consumers that over

half their loan balance would be forgiven Moreover Defendantsrsquo telemarketers

have told some consumers that their loan payments could or would be rapidly

reduced to $19 per month or promptly forgiven

28 Defendants have made other representations concerning loan

reduction or forgiveness to consumers in telemarketing their debt relief services

For example Defendantsrsquo telemarketers have told one or more consumers that

ldquofamily sizerdquo a metric for determining the amount borrowers pay each month

under IDR plans includes ldquoanyone you help out throughout the year[] they donrsquot

have to live with yourdquo even claiming that helping with ldquogas money three times

out of the yearrdquo is enough to include a person in ldquofamily sizerdquo Further

Defendantsrsquo telemarketers have offered one or more consumers ldquobasically a

guarantee to remainrdquo in an IDR plan and warned one or more consumers that

signing up for an IDR plan with a lender instead would result in a higher loan

payment

29 Defendants have not been likely to achieve the lower monthly

payments or student loan forgiveness they have advertised marketed and

promoted to consumers In many instances Defendants have failed to obtain the

promised lower monthly payments or student loan forgiveness

30 Defendants have charged consumers fees for purported debt relief

services before achieving lower monthly payments or student loan forgiveness

and in many instances have failed to achieve those results at all on behalf of

consumers

12

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 13 of 57 Page ID

1

2

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22

23

24

25

26

27

28

1772

31 Defendantsrsquo telemarketers have sought and obtained consumersrsquo

payment information by phone or the Internet

32 Defendantsrsquo total advance fees typically have been in the range of

$300-500 Defendants also have charged consumers recurring monthly fees for

purported debt relief services typically charging $19 per month

THE FTC ACT

33 Section 5(a) of the FTC Act 15 USC sect 45(a) prohibits ldquounfair or

deceptive acts or practices in or affecting commercerdquo

34 Misrepresentations or deceptive omissions of material fact constitute

deceptive acts or practices prohibited by Section 5(a) of the FTC Act

VIOLATIONS OF THE FTC ACT

Count One

(Deceptive Student Loan Debt Relief Representations)

35 In numerous instances in connection with the advertising marketing

promotion offering for sale or sale of student loan debt relief services Defendants

have represented directly or indirectly expressly or by implication that consumers

who purchase Defendantsrsquo debt relief services will or likely will have their

monthly payments reduced or their loan balances forgiven in whole or in part

36 In truth and in fact in numerous instances in which Defendants have

made the representations set forth in Paragraph 35 of this Complaint such

representations were false or not substantiated at the time Defendants made them

37 Therefore Defendantsrsquo representations as set forth in Paragraph 35 of

this Complaint are false or misleading and constitute deceptive acts or practices in

violation of Section 5(a) of the FTC Act 15 USC sect 45(a)

THE TELEMARKETING SALES RULE

38 Congress directed the FTC to prescribe rules prohibiting abusive and

deceptive telemarketing acts or practices pursuant to the Telemarketing Act 15

13

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 14 of 57 Page ID

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24

25

26

27

28

1773

USC sectsect 6101-6108 in 1994 The FTC adopted the original TSR in 1995

extensively amended it in 2003 and amended certain sections thereafter 16

CFR Part 310

39 Defendants are ldquoseller[s]rdquo or ldquotelemarketer[s]rdquo engaged in

ldquotelemarketingrdquo as defined by the TSR 16 CFR sect 3102(dd) (ff) and (gg) A

ldquosellerrdquo means any person who in connection with a telemarketing transaction

provides offers to provide or arranges for others to provide goods or services to a

customer in exchange for consideration 16 CFR sect 3102(dd) A ldquotelemarketerrdquo

means any person who in connection with telemarketing initiates or receives

telephone calls to or from a customer or donor 16 CFR sect 3102(ff)

ldquoTelemarketingrdquo means a plan program or campaign which is conducted to

induce the purchase of goods or services or a charitable contribution by use of one

or more telephones and which involves more than one interstate telephone call 16

CFR sect 3102(gg)

40 Defendants are sellers or telemarketers of ldquodebt relief servicesrdquo as

defined by the TSR 16 CFR sect 3102(o) Under the TSR a ldquodebt relief servicerdquo

means any program or service represented directly or by implication to

renegotiate settle or in any way alter the terms of payment or other terms of the

debt between a person and one or more unsecured creditors or debt collectors

including but not limited to a reduction in the balance interest rate or fees owed

by a person to an unsecured creditor or debt collector 16 CFR sect 3102(o)

41 The TSR prohibits sellers and telemarketers from requesting or

receiving payment of any fees or consideration for any debt relief service until and

unless

a The seller or telemarketer has renegotiated settled reduced or

otherwise altered the terms of at least one debt pursuant to a

14

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 15 of 57 Page ID

1

2

3

4

5

6

7

8

9

10

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13

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17

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19

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25

26

27

28

1774

settlement agreement debt management plan or other such

valid contractual agreement executed by the customer and

b The customer has made at least one payment pursuant to that

settlement agreement debt management plan or other valid

contractual agreement between the customer and the creditor

and

c To the extent that debts enrolled in a service are renegotiated

settled reduced or otherwise altered individually the fee or

consideration either

i Bears the same proportional relationship to the total fee

for renegotiating settling reducing or altering the terms

of the entire debt balance as the individual debt amount

bears to the entire debt amount The individual debt

amount and the entire debt amount are those owed at the

time the debt was enrolled in the service or

ii Is a percentage of the amount saved as a result of the

renegotiation settlement reduction or alteration The

percentage charged cannot change from one individual

debt to another The amount saved is the difference

between the amount owed at the time the debt was

enrolled in the service and the amount actually paid to

satisfy the debt 16 CFR sect 3104(a)(5)(i)

42 The TSR prohibits sellers and telemarketers from misrepresenting

directly or by implication any material aspect of any debt relief service including

but not limited to the amount of money or the percentage of the debt amount that a

customer may save by using the service 16 CFR sect 3103(a)(2)(x)

15

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 16 of 57 Page ID

1

2

3

4

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16

17

18

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23

24

25

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27

28

1775

43 Pursuant to Section 3(c) of the Telemarketing Act 15 USC

sect 6102(c) and Section 18(d)(3) of the FTC Act 15 USC sect 57a(d)(3) a violation

of the TSR constitutes an unfair or deceptive act or practice in or affecting

commerce in violation of Section 5(a) of the FTC Act 15 USC sect 45(a)

VIOLATIONS OF THE TELEMARKETING SALES RULE

Count Two

(Advance Fee for Debt Relief Services)

44 In numerous instances in connection with the telemarketing of

student loan debt relief services Defendants have requested or received payment

of a fee or consideration for debt relief services before

a Defendants have renegotiated settled reduced or otherwise

altered the terms of at least one debt pursuant to a settlement

agreement debt management plan or other such valid contractual

agreement executed by the customer and

b The customer has made at least one payment pursuant to that

settlement agreement debt management plan or other valid

contractual agreement between the customer and the creditor

45 Defendantsrsquo acts or practices as described in Paragraph 44 of this

Complaint are abusive telemarketing acts or practices that violate Section

3104(a)(5)(i) of the TSR 16 CFR sect 3104(a)(5)(i)

Count Three

(Material Debt Relief Misrepresentations)

46 In numerous instances in connection with the telemarketing of

student loan debt relief services Defendants have misrepresented directly or

indirectly expressly or by implication material aspects of their debt relief services

including but not limited to that consumers who purchase Defendantsrsquo debt relief

services will or likely will have their monthly payments reduced or their loan

16

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 17 of 57 Page ID

1

2

3

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1776

balances forgiven in whole or in part

47 Defendantsrsquo acts and practices as described in Paragraph 46 of this

Complaint are deceptive telemarketing acts or practices that violate Section

3103(a)(2)(x) of the TSR 16 CFR sect 3103(a)(2)(x)

Count Four

(Disgorgement of Ill-Gotten Gains of Relief Defendant)

48 Relief Defendant Noel has received directly or indirectly funds or

other assets from Defendants that are traceable to funds obtained from Defendantsrsquo

customers through the unlawful acts or practices described herein

49 Relief Defendant Noel has no legitimate claim to Defendantsrsquo

customersrsquo funds or other assets and will be unjustly enriched if it is not required to

disgorge the assets or the value of benefits received as a result of Defendantsrsquo

unlawful acts or practices

50 By reason of the foregoing Relief Defendant Noel holds funds and

assets in constructive trust for the benefit of Defendantsrsquo customers

CONSUMER INJURY

51 Consumers have suffered and will continue to suffer substantial injury

as a result of Defendantsrsquo violations of the FTC Act and the TSR In addition

Defendants have been unjustly enriched as a result of their unlawful acts or

practices Absent injunctive relief by this Court Defendants are likely to continue

to injure consumers reap unjust enrichment and harm the public interest

THIS COURTrsquoS POWER TO GRANT RELIEF

52 Section 13(b) of the FTC Act 15 USC sect 53(b) empowers this Court

to grant injunctive and such other relief as the Court may deem appropriate to halt

and redress violations of any provision of law enforced by the FTC The Court in

the exercise of its equitable jurisdiction may award ancillary relief including

rescission or reformation of contracts restitution the refund of monies paid and

17

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 18 of 57 Page ID

1

2

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1777

the disgorgement of ill-gotten monies to prevent and remedy any violation of any

provision of law enforced by the FTC

53 Section 6(b) of the Telemarketing Act 15 USC sect 6105(b)

authorizes this Court to grant such relief as the Court finds necessary to redress

injury to consumers resulting from Defendantsrsquo violations of the TSR including

the rescission or reformation of contracts and the refund of money

PRAYER FOR RELIEF

Wherefore Plaintiff FTC pursuant to Section 13(b) of the FTC Act 15

USC sect 53(b) Section 6(b) of the Telemarketing Act 15 USC sect 6105(b) and

the Courtrsquos own equitable powers requests that the Court

A Award Plaintiff such preliminary injunctive and ancillary relief as

may be necessary to avert the likelihood of consumer injury during

the pendency of this action and to preserve the possibility of effective

final relief including but not limited to temporary and preliminary

injunctions orders freezing assets immediate access to business

premises appointment of a receiver and expedited discovery

B Enter a permanent injunction to prevent future violations of the FTC

Act and the TSR

C Award such relief as the Court finds necessary to redress injury to

consumers resulting from Defendantsrsquo violations of the FTC Act and

the TSR including but not limited to rescission or reformation of

contracts restitution the refund of monies paid and the disgorgement

of ill-gotten monies

D Enter an order requiring Relief Defendant to disgorge all funds and

assets or the value of the benefit it received from the funds and assets

which are traceable to funds obtained from Defendantsrsquo customers

through the unlawful acts or practices described herein and

18

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 19 of 57 Page ID 1778

2

3

E Award Plaintiff the costs of bringing this action as well as such other

and additional relief as the Court may determine to be just and proper

Dated February 5 2019

Respectfully submitted

ALDEN F ABBOTT General Counsel

JosaSMillard Brian M Welke middot Barbara Chun (Local Counsel) Attorneys for Plaintiff FEDERAL TRADE COMMISSION

4

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19

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 20 of 57 Page ID 1779

EXHIBIT A

Attachment A

Free Assessment

Our expercs will lt1ssPss you cun ent

swclent lo n program and decermn which progr ms are

avc11l bl rn yoL11 situation We wi I help you cl11cic1e which progr m r1

help you achieve your goals Call us today

Service Guarantee We are commmecl to 11-1 111g

CllStomers get low r rc1ces ancl monthly payments and we w1I

m ke the pror~ss se mless and s r11ghtforwc1rd ou wi ll be sansf1ed

with our service ml OLlr

cornmcmem to you success Thars ow gu~ ancee

Success Rate Ou1 96 ~ surcPss r a e s 11e of he

cop I a ings tn he industry Olr

process has beer tested nd Olli

succ ss r r~ prowbull~ tn t it works

We c n ll~lp yo reduce and -1111ph y our p ~ymP1 ts Call us today

FTC-AID-1

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 21 of 57 Page ID 1780

20

Exhibit A

ABOUT US

We can help you reduce and simplify your pay1ncnts Contact one of our specialists today for

a free evaluation

111middot 1_I 1

101

t I 11111 I I

Itbull 11

Ill fl I I

bull ~ 0 I

What Makes Us Great fa1(li1-_~ tur1ent ~e11ef 11as a taf- o~middot tt a middotel elt1)rns bullJn st1ncb110

1middot1ep yriJ Tibullmiddotest fi 1e-ndly f3ce~ 113ve eirej e1tc-nsve1yr =inj ire

fanih1~1 bull11iu1 ti~e nul~nce~ cfscrvern rrent Cdid p11vate stucre11

l1J1ns Th~y viill u~e Ui5 epe tise o loik jUl fJ ycur ~Je~t

i(tres~- f)LH ~U(CtS~ ~HE 1h-~ I lSllt of i_r middotDff ancl iur

C ur ~r_(J~l 1o~w- JCl11~crs f(middotil) 3 00Vtli ~tJegy o r ~dUC2 011i

a1r1plfy yliur- - _Je1middott middotcar payr1t11s 1) Asstrnlins Itle ~atl1t1

2) R~~ear c1-1ng Our st~lff wmiddoti11 (lrJUi~oleaerick ]ll fnfcnTnati(-n befort dtmiddoteJPlr~ t tne ri~n 3) rnnk1middotgbullle i_i1 i e~ear (rr i~ ormiddot1 1 1 etc 1Ne

irvi-s t1ga~ii 111 ps~ib le a~irst 1n(t aptlbull~n 4) 1Nr1 ting VVF p1 eiv lii J 11 iUen u tt-igy IJefore vie Uke ut1c-1l i)ecius~ you d-ese11e 11) undi r~~anci

Lhe pr 1cer S) ~ev1sing Al)ng ~r 1udent Relief 1- 1otT11111tt bull) ti) ci e1H1ve ut-l-~n~-l)O c111 i ri 3 Vbulle -~11 leave n1) sti bull1e u11t111 neltl tecause middot~ve

11~1ve your be~ i1~ t~rest 1t l1ein 6) Si~tcl11ng Our note- =1nd r~c)1 ~ ~1 e thorou~ll ln(I pru1ile 1 ceJ1 po cri1~ 1)f vo111 ~1tuJticn s) iny if-oi

~xpe1 t- 01 eou pped to s~1ty1J_J bullVi r you1 c si- 7) De-gn1ng _ fe ~1 t 1nelt--1- f1ts ti 1middotV 1middotid de~ 1middot1 1 st1 iegy to fit ou 1 1_i dque jtct1in so

011 c111 i Jle y1)u1 1vv1middot1 per feet -ut1e-s ~~0 1 v

1bullVlly 1100~e At(J1n~ Sltl(ltnt Fie11e7) (i1_d aclol~Or~ bull -ii~ (1Ualiftel lci ~~~ISt~h 1noie ype-s middotif JS~iSi_ance u~211 Cd ( (11)itXS i1 jG(l1~t) to ti-tgt

p ~n~ 1not con1p n1es can 11i1p bullbullllh ve )t ~ ~qu1pptCI to bull-bullGr k 1bullv1t1middot1 r~ 11t-2 [uo emiddot 1 lc1 r1s ~~nCI cn even iner-1ne frmiddot tt1e c ~e of 1l~e

~1lt ntslmiddoturelt A1cl1rg Sudent Fie1ef 1middot cis mmiddote to )fe 11d we offe1 t with middotmiddot1eltbullbe 1es nI 3 rncney lock guMai-itee

We Have Been Featured In

FTC-AID-2

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 22 of 57 Page ID 1781

21

Exhibit A

SERVICES Wt w gtL

Loan Forgiveness Income Based Payments Loan Consol idation In some cases individuals with A period of financial hardship may You may be able to combine

Fede1middota1 Student Loans may qualify qualify you for an Income Based nultiple federal student loans into to have a portion of the amount Repayment Plan In many cases this one new loan w ith a lower more

owed may be forgiven This means means you pay nothing Unlike a affordable monthly payment Loan

your principal balnce coulcl be defe1 ment the term on your loan consolidation prngrams can l1elp

significantly reduced and you will continues to reduce while the plan is you qualify for additional programs not be expected to repay the in place Your term could reduce like loan forgiveness programs or

forgiven amount while you pay nothing Public Setvice Loan Forgiveness

a III

Private Sector Loan Forgiveness

If you work for a government

organization at a city state or

federa l level you may qualify for tle

PL1blic Service Loan Forgiveness

program To qualify your loans

must be cotisolidated into a specific

repayment plan The balance on

your federai student loans is

forgiven after 120 qualifying

bull C Permanent Disability

Forgivenness If your disability is expected to last

60 months or more you may qualify

for permanent disability forgiveness

Q1alifying for Permnent Disability

Forgiveness requires a visi t to your

doctor and individL1als enrolled in

the program are subject to three

years of post-discharge monitoring

Wage Garnishment Prevention

Federal law requires that the

Department of Education or a

gua1middotanty agency notify you before

111st1tuting wage garnishment You

have tl1e right to a hearing where

you can challenge the stated

amount owed and negotiate the

terms of the repayment scheclule

We can intervene on YOL1PflJl~1D-3

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 23 of 57 Page ID 1782

22

Exhibit A

payments have been made p1middotevent wage gampnishments

A FEW STATISTICS ABOUT STUDENT LOAN CRISIS

12 Trillion National Student Debt I he nitionil student loin debt is

now 17 trillion dollirs 1 trillion of

these are in federil student loans

Let us help you through this national

crisis Cill today for a free

evaluation

40 Million Students with Debt

In 7014 an estimated 40 million

current and former students were in

debt because of student loans If

you are one of the millions of people

struggling to pay student loans

Aiding Student Relief is here to help

$33000 Average Student Debt

The graduating class of 7014

average $33000 of student loan

debt per person Thats $3000 more

than the average in 2013 Dont be

one of the many Let Aiding Student

Relief advocate for you

Aiding Student Relief has helped cmrnllcss 1woplc reduce their student debt_ Their proven business

plan has led lo one of lhc highest s11cclSS raCs in the inltl11slly

John Standiford Associated

FTC-AID-4

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 24 of 57 Page ID 1783

23

Exhibit A

TESTIMONIALS

Til~nks to Aiding Student Rel ief Im middotI middotva ove1vvhelrnecl but Aiding The expemiddotts at l1icl i11g Student Rel ief

s1v ing $250 per month Strrd r~rt Relief expl~ inecl the were ther~ to help me when I process ancl rnacle everytl1ing cle11middot nelclecl 1t rw)s t

and sirnple

I Michael Ma 1in

Entrep e11eu1 Em iiy Jallo1 Ii Pa ul Ch is tia I1se11

Teacher Nurse

With so many programs I didnt middotconso lrclating my loans into one I love my Job but vith my high

know what was ng ht for me My monthly payment hs made life student loan payment was still

sruclent loan aclvsor walked me si1nple1 Now I can focus on 1Nhn bamiddotely getting by I don t kn ow what I

through my optio ns rnd now Imiddotn matters to me would hwe clone wthout Aiding

saving 54 I 11n1omh Stucie1middott Rel refmiddot

Ariel Hemiquez Sales co)SUltant

Stephani Seland-1 Small Busim~ss Owner

AJ 01en Museum Curator

RECENT NEWS

)lt)

o(l ttDrlTI -5

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 25 of 57 Page ID 1784

24

Exhibit A

Student Debt Crisis Business Latest Debt Collective Demands May be largely about smallest Student

borrnwers US News amp World Loan Crisis is fa frorn ove The Debt Collective is a group of Report-May 162015 last month Two new reports suggest the college students calling the Fedemiddotal Reserve Bank of New student loan crisis is easing them-se1ves the Corinthian York repor ced that stuclent loan somewhat as the economy Fifteen who are refusing to pay balances rose to 16 trillio n and improves but the crisis is far back their student loins As pa t that 113 per cent of that is in from ove the College Board of this effort the Debt Collective repo t~ tot31 borrowing fell by 8 has written an open lette to the pEbull1 cent between 2012-13 and Department of Education f l llJ 20 13-14 The organization

About Us 11 1 i~d1middot1r F th~~- h1~ ff t1middot~11middot=cl =i~=middott- 1middot __31middotmiddotIIgt middot bullmiddot11

middot- I ( )ntir il t l~i -r_il fr~~

Address bull middot tc1ltj-1r_ =i ~

middot l t1~t 1middot1 fcJ middot~_1 1 I l11 - Hbull 1 tr

~t (~~ 1 12bull~11 T 1 1- - 8555105400

FTC-AID-6

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 26 of 57 Page ID 1785

25

Exhibit A

f - g+ in O) ~ PRIVACY POLICY

This privacy statement discloses the privacy practices for AidllII Student Relief Because Aiding Studen Relief wonts to demonstrate ts firm commlcmell to your

privacy Aiding Sudent Relief hes greed to disclose ls 1rifor111atlori g1thering and dlssem1n1t1on prct1cts Aidlns Studtrit Relief will notify you of

INFORMATION COLLECTION At-ID USE

Aiding Student Relief is the sole owner of the rformMlon collected on this site We will not sell shire or rent this information 10 others In way different from what Is

disclosed 1n this statement Aldln1 StudeM Relief collects 1nform111on throuah this site from our prospective end existing clients at several different poin on our web

site We use their contact Informii on to send information bout our company and to service exsMs accounts Users may optbullout of rece11ns future malllngs see the

cholceoptbullout section below Contect and Financial information that 1s collected Is used for verifying your name address and other informa1on as well as to boll you for

your use of our Gerv1ces using Information from third party sourcH Information about your computer hardwre and software Is automatically collected by Aiding

Student Relief and may be shared in asgregate with third parties whose services are used for traffic analysis purposes This Ir formation includes your IP address

browser type domain names access times and referring Web site addresses Ths information is no tied to personally Identifiable Information This 1nformatlor s used

by Aiding Student Relief to malMan no Improve the quality of the Hrvct and to senerae statistics resardlng use of he Aiding Student Relief site We use third party

services to bill for serlces and to provide other services like our Live Help chat We store the transcripts from these chats for customer service Improvement These

third party service providers are not permitted to use your infornon for any secondary purposes

Thank you and cheers

FTC-AID-7

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 27 of 57 Page ID 1786

26

Exhibit A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 28 of 57 Page ID 1787

EXHIBIT B

Attachment A

((

z | ~

AIDINGSTUDENTRELIEF

bull bull bull bull bull

13 deg $ $ampdegdeg deg() ˝ amp $$deg( + -+Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 29 of 57 Page ID 1788

bulldaggerDagger Daggermdashndash Daggerhellip ƒfrasl hellip lsaquorsaquobullminuspermilminushellip bdquolsaquoldquo rsaquordquobulllsquo fraslbullrsquopermillsaquofraslpermilminushellip sbquo

4556789fADlt=gtA9BCAD

DZgtA=EFGHIJFKLMNOPFQOGFHIQRSTLKSUMMNOPLHMTFIVRWXHKKNIFNUNOPRLFGSHKSRVRVNQ

f e=klHMW

9SI]UQMSNSOQOHHPFK YaSTHHVVJFMHcVGNOJVHHFKKPSUHMLIUOQN_PL[KSVFGJPRSDTHRFPLIP=SNDC==GFdFIP9VaNHQTWSRPbHF_PSKSVNMPMHNIO XNNIIFRKNF7IKSQQMHFNDVPOS9IAeTHPdKSUMMFNKHONP 8aF_KSNVPHTNIMNR[POVFgNPTHLNHIgtMFI YTFHIdFFI D9aHVR_KNKHFHIWIQOTHIQbFFP

lt=Dkgt=L]oHUKMMH ihTFNIORI THHVPRFMVKgtNJ_NFFbIVSJI]IFjdGGVNNN lt=TFKPPNF 9DaFGmVHPGRJMFNNQOSGnPFFTNLUNHPMIMTFVNJOKMIWV

27

]UMNOHPFRKNVSHKKISIRWRrGZNJONgtNjTHKHMI=cQgtORHVPKSOUMddUNKSPIdspNVPNq_ lt=gtBTHFHPb=HFILGFHMt DTFuFIUVFRPNTFIMINVWOPRVOQFIV sFQFPHKKH vaIPNFVcSyOFSPRFMRNVOJH_gtVFDVUJAN9FPwFuVFJLFHMP_VTFFdSIIVdNHUPxI=DQSROJGASHIVdDSNMINONPPaHdOHdPFHRIWVFFHdFIGM˙ 01 $2 301 $$3 ( Exhibit B

8

~ldquo

middot

676EBCEDK5ltAC]5EF_5665E7gt5lt7aFb688E588lt76B5E6F8EBAC78lt76cdddefghijhggklmknmopqprpopst u

13 deg $ $ampdegdeg degˇ amp $$deg + -+Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 30 of 57 Page ID 1789 () ( vPSZwPxyYTUZUWWzxPyxSWMZWPU|SWUWYZ~YTY~QSWbullYXRwU~UxSdaggerXQ~UZXvPSZWSOVQSYNOXPRSTUSDaggerPxXYPZPNXRUSPQZXPbullU~SOhellipUNPxyYTUZmdash zUxSZUZXndashYWShellipYYXOwPxyYTUZUWWMNOPQx~YWShellipYYXOYWUƒDaggerU|XU~XPSWXfrasllsaquoPZXRWPxPxUOPQSOVQSYNONPxDaggerUxSZUZX~YWShellipYYXONPxyYTUZUWWmdash

rsaquominus MZ|PUpermilSWUzSOUZXWbdquoDaggerUxYP~PNZSZ|YSRSx~WRYDaggerSOVQSYNOOPQNPxSZMZ|PUpermilSWU~rdquoUDaggerSOUZXzSZmdashMZSZO|SWUWXRYWUSZWOPQDaggerSOZPXRYZymdash zQhellipY|daggerUxTY|UvPSZwPxyYTUZUWWMNOPQbullPxlsquoNPxSyPTUxZUZXPxySZYrsquoSXYPZSXS|YXOWXSXUPxNU~UxSUTUOPQSOVQSYNONPxXRUzQhellipY|daggerUxTY|UvPSZwPxyYTUZUWWDaggerxPyxSmdashsbquotrade f8Ef8E78FCB6C8EŁPQSOhellipUShellipUXP|PhellipYZUQXYDaggerUNU~UxSWXQ~UZXPSZWYZXPPZUZUbullPSZbullYXRSPbullUxPxUSŒPx~ShellipUPZXRODaggerSOUZXmdashvPSZ|PZWPY~SXYPZDaggerxPyxSW|SZRUDaggerOPQVQSYNONPxS~~YXYPZSDaggerxPyxSW YlsquoU PSZ NPxyYTUZUWWDaggerxPyxSWPxzQhellipY|daggerUxTY|UvPSZwPxyYTUZUWWmdash ŠmŸŽıłŠm 57gt8A57A5B= 8E65C76B5E6F8EB5=6G

PONM[5 QRSTUVQU PYXWZW lt4556789588lt959=lt CD lt H5FICEDJ8KA5LCD

A565E7gt57 œšžeuroiexclcentpoundyenbrvbarsectbrvbareurocopypoundsectlaquoeuropoundlaquobrvbarlaquoregplusmncentbrvbareurocent microparalaquo europoundž raquoY|frac14frac12 plusmncurrenRSUraquoSxXYZeuropoundlaquo laquoeurolaquoordf frac34

^ ˙ ( (

28

Attachment A

01 $2 301 $$3 ( Exhibit B

()(

=4ABC9DEAFBD=FGFHIJKLMJNOMN MRNS mn = nrst = svzhellipu t bulltvDaggerrhellipDaggerurbullbulltuhellipv hellipz~ bullmdashldquordquolsquorsquotrade š oŒŠeuro centpound ` umluml 13 deg $ $ampdegdeg degˇ amp $$deg + -+Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 31 of 57 Page ID 1790

ISNRTUKQINKKNNKL[MRJ PUWQI]MRM qyt|tytzxy rsaquoqNfraslbdquoPUhellipsbquoLUyQhellip rfraslbhellipMNSIKVUQ QNJKvUQsMiexclQQJUx[iexcliexcl_vsect_Qyenyenbrvbarbrvbar uSSRNTPL_LUUMKIaJ_WMIJJKVIONNQJJMWRMIIbQQURKLWIIJQbKLUNKMPTMNQQ_KKRY tbullbulldaggersDaggerv~vhellipmdashryrhellip~mdashrhellipDagger ŸLŽUıQŽbłpermilMtradeœsbquoNtrade_ffRŁyISMŒUQWyNUQŠlsaquo rv45657896lt7ltgt5lt PQKLMIQSNRTUKINQVNOOMVKMWNQKLIJPMXJIKMYZMPIOO NJMOOJLURMNRRMKKLIJ klltko ltgtlt85p5gt5 ouvwxrz ^^ ~ minuspermil tffŁ yenpoundpound KNOWDaggerIreggt4lt97ltndash9ƒ Dagger hellipDaggerlsaquo žko74k57ƒ ƒISNcurrenUIWIbJKWMKJYVNTKM KLONNRqIQQSNNRTUKINQQIJ_JMWNQKLIJJJPMXJIKMcOMUJMVNQKUVK_JUKBHdefABCgDEAFBDghidjlaquopoundbrvbariexclnotvIWIQbDaggerK_WMQKbullMOIMSvOObullIbLKJbullMJMRMW ordf copy

01( $2(301$$3( Exhibit B

29

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 32 of 57 Page ID 1791

EXHIBIT C

Attachment A

~ 111 ~tampi 10 11 ~bull ia1111

Something awesome is coming soon We are buildin somethin ve cool Sta tuned and be at1ent Your atience will be well aid

~lbullrbullUiUffl We can help you reduce and simplify your payments

101 Loan For iveness

1~u 0 (middottmiddotbullmiddotmiddot1 1~=I -- _~

HZamp IMUliULlampRampatiEUWi nmiddot middot-il~ fr middot 8rbullbullrcrr-

_J l _ 1 _f _ur -~t~ u L liYu

~ Income Based Pa ents

bull ~ f I - - I - I - ri u ~u-=lf ~ JU

1-bullA ---rc iM1~~ -~-bullCiel rrcl

~- middot IY 2 i C middot middotJ ll1Jmiddot 0 _ middot_middotIr i

~ LdfiJIMifJ11JJMJllfFffi

middotE-ltecl l2bullJbull iequbullt t11cit t1lt2 CtpCr~middot1e- f

JJd r g-_iraE-1 agltr-middot- ntimiddot middot)middotou

tmiddot_rt- i ic l~1ri ~rbullmiddot middot111~ umiddot -_ d_t-c

fsectmet-Naibullfyen1~poundibllffifftmI

I f-nle Vnot Nune

I ampterYOllrEmall ]

1 ~~~~ 1

If -bull 13n ~Cbull t~middot rct1~j d- gtOY- - hO- irmiddot (bulldbull) plltmiddotmiddot- leemiddotmiddot JOu

1r1cbullmiddotn111f11ri ll1fbull fcrn to ~bull~I

Triin- GU

WAWMyenEIRitiRpoundWt 44 ZiAtillampampI

Exhibit C

Case 818-cv-01987-JLS

-KE

S

Docum

ent 50-1 F

iled 020519 P

age 33 of 57 P

age ID 1792

30

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 34 of 57 Page ID 1793

EXHIBIT D

Attachment A

bull bull bull bull bull bull bull

---

Type then hit enter to

bull bull bull bull bull bull bull

----

----

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 35 of 57 Page ID 1794

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

infoaidnestcom (800) 555-1212

HOME

ABOUT US

SERVICES

FAQ

BLOG

CONTACT

HOME ABOUT US SERVICES FAQ BLOG CONTACT

1 of 6 462018 945 AM

31

Student Loan Forgiveness Loan Consolidation Student Loan Forgiveness

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 36 of 57 Page ID 1795

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

If you have Federal Student Loans yoursquore in the right place to get those loans reduced forgiven or completely discharged through our student loan forgiveness programs

Get your multiple Federal Student Loans consolidated into one forget about increasing interests and pay month to month at the lowest possible cost

We understand if yoursquore going through some hardship and thatrsquos why with us yoursquoll be able to make monthly payments based on your affordability for as low as $000 depending on your situation

2 of 6 462018 945 AM

32

Knowledge Base

Defaulted Student Loans

Wage Garnishment

Student Loan Rehabilitation

Income Based Repayment Plan

Deferment and Forbearance

Pay As You Earn Repayment Plan

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE Call 561)424-6053 today to go over your options

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 37 of 57 Page ID 1796

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

Our knowledge base is designed to provide information regarding some of the critical topics those with student loans must be aware of to be able to make educated decisions regarding their future

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

A wage garnishment is any legal procedure in which some portion of a personrsquos earnings is required to be withheld by an employer for the payment of a debt

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

With this program your payments change as your income changes and will not be longer than 25 years This is the ideal plan if you are in partial financial hardship Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard plan

Temporarily allowing you to postpone or reduce your federal student loan payments Postponing or reducing your payments may help you avoid default and future garnishments

Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard

3 of 6 462018 945 AM

33

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 38 of 57 Page ID 1797

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

4 of 6 462018 945 AM

34Attachment A

Testimonials

Latest News

Why 2016 Will Be a Big Year For Student Loans

Top Student Loan Refinancing Questions of 2015

Oba mas latest student loan plan

Things You Should Know About Public Service Loan Forgiveness

Recent Posts

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 39 of 57 Page ID 1798

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

5 of 6 462018 945 AM

35

About Us

Contact Info

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 40 of 57 Page ID 1799

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

pay-grandchild-studen

Why 2016 Will Be a Big Year For Student Loans

December 30 2015

12511110_1112367518

Top Student Loan Refinancing Questions of 2015

December 30 2015

We stand by our consultation and quote We are so sure and confident about our services and offers that they are all 100 money back guarantee risk free ndash if we donrsquot do what we promise yoursquoll get your money back

(800) 555-1212 AidnestStudenLoansgmailcom 18100 Von Karman Ave Suite 850 Irvine CA 92612

Futero SAS copy 2015 | Aidnestcom

6 of 6 462018 945

Exhibit D 36Attachment A

AM

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 41 of 57 Page ID 1800

EXHIBIT E

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 42 of 57 Page ID 1801

AIDNEST Let us help you through this national crisis

Call one of our specialists today

Forbearance amp Deferment If you are still in school and struggling to make payments on your student loans You may qualify

for Forbearance amp Deferment

Garnishment Prevention Federal law requires that the Department of Education or guarantee agency notifies you before they

begin garnishing your wages

Loan Forgiveness If you are a teacher public service worker or an individual with total and permanent disability you

httpaidnestcom[442018 115239 AM]

37Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 43 of 57 Page ID 1802

AIDNEST Let us help you through this national crisis

may qualify for this program

Consolidating Your Loans Consolidating your loans to one new loan under one lender may lower your payments and make

your life a bit more manageable

Affordable Payments If you are looking to lower your monthly payments then Income Based Repayment Plans may be

the correct choice for you

Learn more about our services

LEARN MORE

httpaidnestcom[442018 115239 AM]

38Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 44 of 57 Page ID 1803

AIDNEST Let us help you through this national crisis

Loan Forgiveness Programs Income Based Payments Student Loan Rehabilitation

Student Loan Consolidation

You may be eligible for

Loan Forgiveness Programs

In some cases individuals with Federal Student Loans may qualify to have a portion of the amount

owed to be forgiven

Get in touch with our professional team to find out which loan forgiveness program you qualify for and

how you can get rid of your unpaid student loan

L EARN MORE

httpaidnestcom[442018 115239 AM]

39Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 45 of 57 Page ID 1804

AIDNEST Let us help you through this national crisis

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE

Meet your Budget One of our advisers will help you meet your payment goals by using your budget and timeline to

determine the best plan available

httpaidnestcom[442018 115239 AM]

40Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 46 of 57 Page ID 1805

AIDNEST Let us help you through this national crisis

Simple Process We understand that lowering your payments alone can be difficult Our intuitive platform allows us

to keep the entire process simple

Customer Satisfaction We are committed to providing you with outstanding service only We look forward to working

with you

100 money back guarantee No Hassle Money Back Policy

httpaidnestcom[442018 115239 AM]

41Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 47 of 57 Page ID 1806

AIDNEST Let us help you through this national crisis

Lower your loan payments by getting in touch with one of our professionals

We design a customized repayment plan that will allow you to make payments based on your

monthly income family size and spending Get rid of the hassle of extensive paperwork and get the

help you deserve

What we can help you achieve a lower payment or lower rate

httpaidnestcom[442018 115239 AM]

42Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 48 of 57 Page ID 1807

AIDNEST Let us help you through this national crisis

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcom[442018 115239 AM]

43Exhibit E

httpaidnestcomservices[442018 115322 AM]

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 49 of 57 Page ID 1808

Services | AIDNEST Let us help you through this national crisis

INCOME BASED PAYMENTS

If you are suffering from a financial hardship you may be eligible for an

Income Based Payment In this repayment program you would have a

payment based on your income and family size The payment could be as

low as $000 per month with forgiveness at the end of 20-25 years

44

Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 50 of 57 Page ID 1809

L E ARN MORE

LOAN FORGIVENESS

If you have Federal Student Loans you may qualify for any of the student

loan forgiveness programs that are available to borrowers You may be

eligible for principal reduction loan forgiveness or a complete loan

discharge depending on your individual circumstance

L EARN MORE

PRIVATE STUDENT LOAN CONSOLIDATION

Much like refinancing a mortgage generally the biggest benefit of private

student loan consolidationstudent loan refinancing is a lower interest rate

httpaidnestcomservices[442018 115322 AM]

45Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 51 of 57 Page ID 1810

L E ARN MORE

(something federal consolidations do not offer)

STUDENT LOAN REHABILITATION

You can renew eligibility for new loans and grants and eliminate the loan

default by ldquorehabilitatingrdquo a defaulted loan

httpaidnestcomservices[442018 115322 AM]

46Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 52 of 57 Page ID 1811

CHE CK E L E G I B I L I T Y

WAGE GARNISHMENT

A wage garnishment is any legal procedure in which some portion of a

personrsquos earnings is required to be withheld by an employer for the

payment of a debt

L EARN MORE

With our fast friendly and professional services wersquoll be glad to help you get your student loans

reduced forgiven or completely discharged To this end wersquoll assist you in consolidating all your

student loans so yoursquoll have only one lender and yoursquoll start making one monthly payment Our

professionals will walk you through the best and most flexible repayment options and if itrsquos also

necessary varied deferment options and rehabilitation programs

httpaidnestcomservices[442018 115322 AM]

47Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 53 of 57 Page ID 1812

Services | AIDNEST Let us help you through this national crisis

Our CRM System

Our CRM is one of the most advanced in the industry and most importantly itrsquos linked directly to

the Department of Education (DOE) This keeps your personal and most confidential information

safe Furthermore because our CRM system is linked to the DOE our approval is 100 Through

our CRM we will be doing continuous monitoring of our process without losing sight of your

immediate needs ensuring that your case has the proper handling and most efficient process

httpaidnestcomservices[442018 115322 AM]

48Exhibit E

n

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 54 of 57 Page ID 1813

Services | AIDNEST Let us help you through this national crisis

R ECENT POSTS

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

ABOUT US

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcomservices[442018 115322 AM]

49Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 55 of 57 Page ID 1814

EXHIBIT F

s -

bullmiddot - ~ t ~ower Your Student Loan Pay~e~ts oday -- Students Helping Students Save Money

INCOME BASED PAJIIIJITPAIS

I C(gttoUC1 u~

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 56 of 57 Page ID 1815

X + C (D Not secure wwwstudoracom 0

CALL US NOW (85S) 978-S599 middot 1nfostudoracom

HOME SERVICES ABOUT US FAQ CONTACT US BLOC PRIVACY

Offering obligation and commitment free loan relief solutions

STUDENT LOAN FORGIVENESS INCOME BASED PAYMENTS LOAN CONSOLIDATION

We11 help you get your loans reduced forgiven o r Make monthly pdyments based on your affordability Get multiple Federal Student Loans consolidated into

discharged one low monthly payment

Talk to our experts concerning your

student loans

Studora is a pnvatefy owned company that helps consumers like you identify

government programs that fit your financial s1tuat1on Our loan experts will assist you in selecting the appropriate programs that WOltk with your income family size and

desired monthly payment We then prepare the appropriate documents for your review and submission All this f o r one low easy payment

Testimonials

Thank you f o r getting back to me quickly Youve been fabulous Thank you for the confirmation and for your help today Pass

during this whole process Is there a place I can go online that I this on to your sup that you were very professional and very

can leave a comment for your manager Youve made this Robert helpful and brought a sense of relief for me Thank you very

process so easy and answered every question my husband and I much and have a great rest of your day Kudos to you and your

have had teammoneywell spenL

Exhibit F 50

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 57 of 57 Page ID 1816

Services we offer

Stud ora offers document preparation services for all loan forgiveness consolidation and relief services to people who are unable to manage their finances Our mam aim is to

offer complete peace of mind to indiVidual unable to pay their student loan debt

we otter the folloWing document preparation services with complete professional assistance

amFinancial Review ffl Budget Planning

Toe first step to creating a flexible loan repayment plan is financial review we also help create a personal finance plan to ensure that you are able to

Our professmnals will look into your finances and design a custom manage your monthly budget in the most effective way This plan will keep

repayment plan that is affordable and easy to manage your spending to the minimum alloWing you to save more money for loan

repayment

Permanent Disability Forgiveness r-trTeacher Loan Forgiveness (5 You can get rid of your Federal Student Loan if you are permanently disabled Good news for teachers who are under the weight of a massiVe loan You can

now get $17 forgiven on your student loans

Public Service Loan Forgiveness Custom Debt Relief Plans

Want assistance with debt relief Get in touch with our experts who will help If you are a public service agent you can get rid of your loan after 120 days of design a loan repayment and relief plan for you based on your monthly

income and affordability payments

THERE ARE NO OBLIGATIONS OR COMMITMENTS

want to save thousands of dollars Fill out our form and get relief from your student loan for a more

peaceful tomorrow

Your Name

BiHHHi

Exhibit F 51

Attachment A

Page 12: JOSHUA S. MILLARD, BRIAN M. WELKE, pro hac vice · for which it has no legitimate claim. Noel is a Wyoming limited liability company that reported in a public document that its principal

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 12 of 57 Page ID

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

1771

27 In calls with consumers Defendantsrsquo telemarketers have told

consumers that Defendants can cause consumersrsquo student loan balances to be

reduced or that consumersrsquo loan balances would be forgiven after making lower

monthly payments Defendantsrsquo telemarketers have told some consumers that over

half their loan balance would be forgiven Moreover Defendantsrsquo telemarketers

have told some consumers that their loan payments could or would be rapidly

reduced to $19 per month or promptly forgiven

28 Defendants have made other representations concerning loan

reduction or forgiveness to consumers in telemarketing their debt relief services

For example Defendantsrsquo telemarketers have told one or more consumers that

ldquofamily sizerdquo a metric for determining the amount borrowers pay each month

under IDR plans includes ldquoanyone you help out throughout the year[] they donrsquot

have to live with yourdquo even claiming that helping with ldquogas money three times

out of the yearrdquo is enough to include a person in ldquofamily sizerdquo Further

Defendantsrsquo telemarketers have offered one or more consumers ldquobasically a

guarantee to remainrdquo in an IDR plan and warned one or more consumers that

signing up for an IDR plan with a lender instead would result in a higher loan

payment

29 Defendants have not been likely to achieve the lower monthly

payments or student loan forgiveness they have advertised marketed and

promoted to consumers In many instances Defendants have failed to obtain the

promised lower monthly payments or student loan forgiveness

30 Defendants have charged consumers fees for purported debt relief

services before achieving lower monthly payments or student loan forgiveness

and in many instances have failed to achieve those results at all on behalf of

consumers

12

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 13 of 57 Page ID

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

1772

31 Defendantsrsquo telemarketers have sought and obtained consumersrsquo

payment information by phone or the Internet

32 Defendantsrsquo total advance fees typically have been in the range of

$300-500 Defendants also have charged consumers recurring monthly fees for

purported debt relief services typically charging $19 per month

THE FTC ACT

33 Section 5(a) of the FTC Act 15 USC sect 45(a) prohibits ldquounfair or

deceptive acts or practices in or affecting commercerdquo

34 Misrepresentations or deceptive omissions of material fact constitute

deceptive acts or practices prohibited by Section 5(a) of the FTC Act

VIOLATIONS OF THE FTC ACT

Count One

(Deceptive Student Loan Debt Relief Representations)

35 In numerous instances in connection with the advertising marketing

promotion offering for sale or sale of student loan debt relief services Defendants

have represented directly or indirectly expressly or by implication that consumers

who purchase Defendantsrsquo debt relief services will or likely will have their

monthly payments reduced or their loan balances forgiven in whole or in part

36 In truth and in fact in numerous instances in which Defendants have

made the representations set forth in Paragraph 35 of this Complaint such

representations were false or not substantiated at the time Defendants made them

37 Therefore Defendantsrsquo representations as set forth in Paragraph 35 of

this Complaint are false or misleading and constitute deceptive acts or practices in

violation of Section 5(a) of the FTC Act 15 USC sect 45(a)

THE TELEMARKETING SALES RULE

38 Congress directed the FTC to prescribe rules prohibiting abusive and

deceptive telemarketing acts or practices pursuant to the Telemarketing Act 15

13

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 14 of 57 Page ID

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

1773

USC sectsect 6101-6108 in 1994 The FTC adopted the original TSR in 1995

extensively amended it in 2003 and amended certain sections thereafter 16

CFR Part 310

39 Defendants are ldquoseller[s]rdquo or ldquotelemarketer[s]rdquo engaged in

ldquotelemarketingrdquo as defined by the TSR 16 CFR sect 3102(dd) (ff) and (gg) A

ldquosellerrdquo means any person who in connection with a telemarketing transaction

provides offers to provide or arranges for others to provide goods or services to a

customer in exchange for consideration 16 CFR sect 3102(dd) A ldquotelemarketerrdquo

means any person who in connection with telemarketing initiates or receives

telephone calls to or from a customer or donor 16 CFR sect 3102(ff)

ldquoTelemarketingrdquo means a plan program or campaign which is conducted to

induce the purchase of goods or services or a charitable contribution by use of one

or more telephones and which involves more than one interstate telephone call 16

CFR sect 3102(gg)

40 Defendants are sellers or telemarketers of ldquodebt relief servicesrdquo as

defined by the TSR 16 CFR sect 3102(o) Under the TSR a ldquodebt relief servicerdquo

means any program or service represented directly or by implication to

renegotiate settle or in any way alter the terms of payment or other terms of the

debt between a person and one or more unsecured creditors or debt collectors

including but not limited to a reduction in the balance interest rate or fees owed

by a person to an unsecured creditor or debt collector 16 CFR sect 3102(o)

41 The TSR prohibits sellers and telemarketers from requesting or

receiving payment of any fees or consideration for any debt relief service until and

unless

a The seller or telemarketer has renegotiated settled reduced or

otherwise altered the terms of at least one debt pursuant to a

14

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 15 of 57 Page ID

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settlement agreement debt management plan or other such

valid contractual agreement executed by the customer and

b The customer has made at least one payment pursuant to that

settlement agreement debt management plan or other valid

contractual agreement between the customer and the creditor

and

c To the extent that debts enrolled in a service are renegotiated

settled reduced or otherwise altered individually the fee or

consideration either

i Bears the same proportional relationship to the total fee

for renegotiating settling reducing or altering the terms

of the entire debt balance as the individual debt amount

bears to the entire debt amount The individual debt

amount and the entire debt amount are those owed at the

time the debt was enrolled in the service or

ii Is a percentage of the amount saved as a result of the

renegotiation settlement reduction or alteration The

percentage charged cannot change from one individual

debt to another The amount saved is the difference

between the amount owed at the time the debt was

enrolled in the service and the amount actually paid to

satisfy the debt 16 CFR sect 3104(a)(5)(i)

42 The TSR prohibits sellers and telemarketers from misrepresenting

directly or by implication any material aspect of any debt relief service including

but not limited to the amount of money or the percentage of the debt amount that a

customer may save by using the service 16 CFR sect 3103(a)(2)(x)

15

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 16 of 57 Page ID

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1775

43 Pursuant to Section 3(c) of the Telemarketing Act 15 USC

sect 6102(c) and Section 18(d)(3) of the FTC Act 15 USC sect 57a(d)(3) a violation

of the TSR constitutes an unfair or deceptive act or practice in or affecting

commerce in violation of Section 5(a) of the FTC Act 15 USC sect 45(a)

VIOLATIONS OF THE TELEMARKETING SALES RULE

Count Two

(Advance Fee for Debt Relief Services)

44 In numerous instances in connection with the telemarketing of

student loan debt relief services Defendants have requested or received payment

of a fee or consideration for debt relief services before

a Defendants have renegotiated settled reduced or otherwise

altered the terms of at least one debt pursuant to a settlement

agreement debt management plan or other such valid contractual

agreement executed by the customer and

b The customer has made at least one payment pursuant to that

settlement agreement debt management plan or other valid

contractual agreement between the customer and the creditor

45 Defendantsrsquo acts or practices as described in Paragraph 44 of this

Complaint are abusive telemarketing acts or practices that violate Section

3104(a)(5)(i) of the TSR 16 CFR sect 3104(a)(5)(i)

Count Three

(Material Debt Relief Misrepresentations)

46 In numerous instances in connection with the telemarketing of

student loan debt relief services Defendants have misrepresented directly or

indirectly expressly or by implication material aspects of their debt relief services

including but not limited to that consumers who purchase Defendantsrsquo debt relief

services will or likely will have their monthly payments reduced or their loan

16

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 17 of 57 Page ID

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1776

balances forgiven in whole or in part

47 Defendantsrsquo acts and practices as described in Paragraph 46 of this

Complaint are deceptive telemarketing acts or practices that violate Section

3103(a)(2)(x) of the TSR 16 CFR sect 3103(a)(2)(x)

Count Four

(Disgorgement of Ill-Gotten Gains of Relief Defendant)

48 Relief Defendant Noel has received directly or indirectly funds or

other assets from Defendants that are traceable to funds obtained from Defendantsrsquo

customers through the unlawful acts or practices described herein

49 Relief Defendant Noel has no legitimate claim to Defendantsrsquo

customersrsquo funds or other assets and will be unjustly enriched if it is not required to

disgorge the assets or the value of benefits received as a result of Defendantsrsquo

unlawful acts or practices

50 By reason of the foregoing Relief Defendant Noel holds funds and

assets in constructive trust for the benefit of Defendantsrsquo customers

CONSUMER INJURY

51 Consumers have suffered and will continue to suffer substantial injury

as a result of Defendantsrsquo violations of the FTC Act and the TSR In addition

Defendants have been unjustly enriched as a result of their unlawful acts or

practices Absent injunctive relief by this Court Defendants are likely to continue

to injure consumers reap unjust enrichment and harm the public interest

THIS COURTrsquoS POWER TO GRANT RELIEF

52 Section 13(b) of the FTC Act 15 USC sect 53(b) empowers this Court

to grant injunctive and such other relief as the Court may deem appropriate to halt

and redress violations of any provision of law enforced by the FTC The Court in

the exercise of its equitable jurisdiction may award ancillary relief including

rescission or reformation of contracts restitution the refund of monies paid and

17

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 18 of 57 Page ID

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1777

the disgorgement of ill-gotten monies to prevent and remedy any violation of any

provision of law enforced by the FTC

53 Section 6(b) of the Telemarketing Act 15 USC sect 6105(b)

authorizes this Court to grant such relief as the Court finds necessary to redress

injury to consumers resulting from Defendantsrsquo violations of the TSR including

the rescission or reformation of contracts and the refund of money

PRAYER FOR RELIEF

Wherefore Plaintiff FTC pursuant to Section 13(b) of the FTC Act 15

USC sect 53(b) Section 6(b) of the Telemarketing Act 15 USC sect 6105(b) and

the Courtrsquos own equitable powers requests that the Court

A Award Plaintiff such preliminary injunctive and ancillary relief as

may be necessary to avert the likelihood of consumer injury during

the pendency of this action and to preserve the possibility of effective

final relief including but not limited to temporary and preliminary

injunctions orders freezing assets immediate access to business

premises appointment of a receiver and expedited discovery

B Enter a permanent injunction to prevent future violations of the FTC

Act and the TSR

C Award such relief as the Court finds necessary to redress injury to

consumers resulting from Defendantsrsquo violations of the FTC Act and

the TSR including but not limited to rescission or reformation of

contracts restitution the refund of monies paid and the disgorgement

of ill-gotten monies

D Enter an order requiring Relief Defendant to disgorge all funds and

assets or the value of the benefit it received from the funds and assets

which are traceable to funds obtained from Defendantsrsquo customers

through the unlawful acts or practices described herein and

18

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 19 of 57 Page ID 1778

2

3

E Award Plaintiff the costs of bringing this action as well as such other

and additional relief as the Court may determine to be just and proper

Dated February 5 2019

Respectfully submitted

ALDEN F ABBOTT General Counsel

JosaSMillard Brian M Welke middot Barbara Chun (Local Counsel) Attorneys for Plaintiff FEDERAL TRADE COMMISSION

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Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 20 of 57 Page ID 1779

EXHIBIT A

Attachment A

Free Assessment

Our expercs will lt1ssPss you cun ent

swclent lo n program and decermn which progr ms are

avc11l bl rn yoL11 situation We wi I help you cl11cic1e which progr m r1

help you achieve your goals Call us today

Service Guarantee We are commmecl to 11-1 111g

CllStomers get low r rc1ces ancl monthly payments and we w1I

m ke the pror~ss se mless and s r11ghtforwc1rd ou wi ll be sansf1ed

with our service ml OLlr

cornmcmem to you success Thars ow gu~ ancee

Success Rate Ou1 96 ~ surcPss r a e s 11e of he

cop I a ings tn he industry Olr

process has beer tested nd Olli

succ ss r r~ prowbull~ tn t it works

We c n ll~lp yo reduce and -1111ph y our p ~ymP1 ts Call us today

FTC-AID-1

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 21 of 57 Page ID 1780

20

Exhibit A

ABOUT US

We can help you reduce and simplify your pay1ncnts Contact one of our specialists today for

a free evaluation

111middot 1_I 1

101

t I 11111 I I

Itbull 11

Ill fl I I

bull ~ 0 I

What Makes Us Great fa1(li1-_~ tur1ent ~e11ef 11as a taf- o~middot tt a middotel elt1)rns bullJn st1ncb110

1middot1ep yriJ Tibullmiddotest fi 1e-ndly f3ce~ 113ve eirej e1tc-nsve1yr =inj ire

fanih1~1 bull11iu1 ti~e nul~nce~ cfscrvern rrent Cdid p11vate stucre11

l1J1ns Th~y viill u~e Ui5 epe tise o loik jUl fJ ycur ~Je~t

i(tres~- f)LH ~U(CtS~ ~HE 1h-~ I lSllt of i_r middotDff ancl iur

C ur ~r_(J~l 1o~w- JCl11~crs f(middotil) 3 00Vtli ~tJegy o r ~dUC2 011i

a1r1plfy yliur- - _Je1middott middotcar payr1t11s 1) Asstrnlins Itle ~atl1t1

2) R~~ear c1-1ng Our st~lff wmiddoti11 (lrJUi~oleaerick ]ll fnfcnTnati(-n befort dtmiddoteJPlr~ t tne ri~n 3) rnnk1middotgbullle i_i1 i e~ear (rr i~ ormiddot1 1 1 etc 1Ne

irvi-s t1ga~ii 111 ps~ib le a~irst 1n(t aptlbull~n 4) 1Nr1 ting VVF p1 eiv lii J 11 iUen u tt-igy IJefore vie Uke ut1c-1l i)ecius~ you d-ese11e 11) undi r~~anci

Lhe pr 1cer S) ~ev1sing Al)ng ~r 1udent Relief 1- 1otT11111tt bull) ti) ci e1H1ve ut-l-~n~-l)O c111 i ri 3 Vbulle -~11 leave n1) sti bull1e u11t111 neltl tecause middot~ve

11~1ve your be~ i1~ t~rest 1t l1ein 6) Si~tcl11ng Our note- =1nd r~c)1 ~ ~1 e thorou~ll ln(I pru1ile 1 ceJ1 po cri1~ 1)f vo111 ~1tuJticn s) iny if-oi

~xpe1 t- 01 eou pped to s~1ty1J_J bullVi r you1 c si- 7) De-gn1ng _ fe ~1 t 1nelt--1- f1ts ti 1middotV 1middotid de~ 1middot1 1 st1 iegy to fit ou 1 1_i dque jtct1in so

011 c111 i Jle y1)u1 1vv1middot1 per feet -ut1e-s ~~0 1 v

1bullVlly 1100~e At(J1n~ Sltl(ltnt Fie11e7) (i1_d aclol~Or~ bull -ii~ (1Ualiftel lci ~~~ISt~h 1noie ype-s middotif JS~iSi_ance u~211 Cd ( (11)itXS i1 jG(l1~t) to ti-tgt

p ~n~ 1not con1p n1es can 11i1p bullbullllh ve )t ~ ~qu1pptCI to bull-bullGr k 1bullv1t1middot1 r~ 11t-2 [uo emiddot 1 lc1 r1s ~~nCI cn even iner-1ne frmiddot tt1e c ~e of 1l~e

~1lt ntslmiddoturelt A1cl1rg Sudent Fie1ef 1middot cis mmiddote to )fe 11d we offe1 t with middotmiddot1eltbullbe 1es nI 3 rncney lock guMai-itee

We Have Been Featured In

FTC-AID-2

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 22 of 57 Page ID 1781

21

Exhibit A

SERVICES Wt w gtL

Loan Forgiveness Income Based Payments Loan Consol idation In some cases individuals with A period of financial hardship may You may be able to combine

Fede1middota1 Student Loans may qualify qualify you for an Income Based nultiple federal student loans into to have a portion of the amount Repayment Plan In many cases this one new loan w ith a lower more

owed may be forgiven This means means you pay nothing Unlike a affordable monthly payment Loan

your principal balnce coulcl be defe1 ment the term on your loan consolidation prngrams can l1elp

significantly reduced and you will continues to reduce while the plan is you qualify for additional programs not be expected to repay the in place Your term could reduce like loan forgiveness programs or

forgiven amount while you pay nothing Public Setvice Loan Forgiveness

a III

Private Sector Loan Forgiveness

If you work for a government

organization at a city state or

federa l level you may qualify for tle

PL1blic Service Loan Forgiveness

program To qualify your loans

must be cotisolidated into a specific

repayment plan The balance on

your federai student loans is

forgiven after 120 qualifying

bull C Permanent Disability

Forgivenness If your disability is expected to last

60 months or more you may qualify

for permanent disability forgiveness

Q1alifying for Permnent Disability

Forgiveness requires a visi t to your

doctor and individL1als enrolled in

the program are subject to three

years of post-discharge monitoring

Wage Garnishment Prevention

Federal law requires that the

Department of Education or a

gua1middotanty agency notify you before

111st1tuting wage garnishment You

have tl1e right to a hearing where

you can challenge the stated

amount owed and negotiate the

terms of the repayment scheclule

We can intervene on YOL1PflJl~1D-3

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 23 of 57 Page ID 1782

22

Exhibit A

payments have been made p1middotevent wage gampnishments

A FEW STATISTICS ABOUT STUDENT LOAN CRISIS

12 Trillion National Student Debt I he nitionil student loin debt is

now 17 trillion dollirs 1 trillion of

these are in federil student loans

Let us help you through this national

crisis Cill today for a free

evaluation

40 Million Students with Debt

In 7014 an estimated 40 million

current and former students were in

debt because of student loans If

you are one of the millions of people

struggling to pay student loans

Aiding Student Relief is here to help

$33000 Average Student Debt

The graduating class of 7014

average $33000 of student loan

debt per person Thats $3000 more

than the average in 2013 Dont be

one of the many Let Aiding Student

Relief advocate for you

Aiding Student Relief has helped cmrnllcss 1woplc reduce their student debt_ Their proven business

plan has led lo one of lhc highest s11cclSS raCs in the inltl11slly

John Standiford Associated

FTC-AID-4

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 24 of 57 Page ID 1783

23

Exhibit A

TESTIMONIALS

Til~nks to Aiding Student Rel ief Im middotI middotva ove1vvhelrnecl but Aiding The expemiddotts at l1icl i11g Student Rel ief

s1v ing $250 per month Strrd r~rt Relief expl~ inecl the were ther~ to help me when I process ancl rnacle everytl1ing cle11middot nelclecl 1t rw)s t

and sirnple

I Michael Ma 1in

Entrep e11eu1 Em iiy Jallo1 Ii Pa ul Ch is tia I1se11

Teacher Nurse

With so many programs I didnt middotconso lrclating my loans into one I love my Job but vith my high

know what was ng ht for me My monthly payment hs made life student loan payment was still

sruclent loan aclvsor walked me si1nple1 Now I can focus on 1Nhn bamiddotely getting by I don t kn ow what I

through my optio ns rnd now Imiddotn matters to me would hwe clone wthout Aiding

saving 54 I 11n1omh Stucie1middott Rel refmiddot

Ariel Hemiquez Sales co)SUltant

Stephani Seland-1 Small Busim~ss Owner

AJ 01en Museum Curator

RECENT NEWS

)lt)

o(l ttDrlTI -5

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 25 of 57 Page ID 1784

24

Exhibit A

Student Debt Crisis Business Latest Debt Collective Demands May be largely about smallest Student

borrnwers US News amp World Loan Crisis is fa frorn ove The Debt Collective is a group of Report-May 162015 last month Two new reports suggest the college students calling the Fedemiddotal Reserve Bank of New student loan crisis is easing them-se1ves the Corinthian York repor ced that stuclent loan somewhat as the economy Fifteen who are refusing to pay balances rose to 16 trillio n and improves but the crisis is far back their student loins As pa t that 113 per cent of that is in from ove the College Board of this effort the Debt Collective repo t~ tot31 borrowing fell by 8 has written an open lette to the pEbull1 cent between 2012-13 and Department of Education f l llJ 20 13-14 The organization

About Us 11 1 i~d1middot1r F th~~- h1~ ff t1middot~11middot=cl =i~=middott- 1middot __31middotmiddotIIgt middot bullmiddot11

middot- I ( )ntir il t l~i -r_il fr~~

Address bull middot tc1ltj-1r_ =i ~

middot l t1~t 1middot1 fcJ middot~_1 1 I l11 - Hbull 1 tr

~t (~~ 1 12bull~11 T 1 1- - 8555105400

FTC-AID-6

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 26 of 57 Page ID 1785

25

Exhibit A

f - g+ in O) ~ PRIVACY POLICY

This privacy statement discloses the privacy practices for AidllII Student Relief Because Aiding Studen Relief wonts to demonstrate ts firm commlcmell to your

privacy Aiding Sudent Relief hes greed to disclose ls 1rifor111atlori g1thering and dlssem1n1t1on prct1cts Aidlns Studtrit Relief will notify you of

INFORMATION COLLECTION At-ID USE

Aiding Student Relief is the sole owner of the rformMlon collected on this site We will not sell shire or rent this information 10 others In way different from what Is

disclosed 1n this statement Aldln1 StudeM Relief collects 1nform111on throuah this site from our prospective end existing clients at several different poin on our web

site We use their contact Informii on to send information bout our company and to service exsMs accounts Users may optbullout of rece11ns future malllngs see the

cholceoptbullout section below Contect and Financial information that 1s collected Is used for verifying your name address and other informa1on as well as to boll you for

your use of our Gerv1ces using Information from third party sourcH Information about your computer hardwre and software Is automatically collected by Aiding

Student Relief and may be shared in asgregate with third parties whose services are used for traffic analysis purposes This Ir formation includes your IP address

browser type domain names access times and referring Web site addresses Ths information is no tied to personally Identifiable Information This 1nformatlor s used

by Aiding Student Relief to malMan no Improve the quality of the Hrvct and to senerae statistics resardlng use of he Aiding Student Relief site We use third party

services to bill for serlces and to provide other services like our Live Help chat We store the transcripts from these chats for customer service Improvement These

third party service providers are not permitted to use your infornon for any secondary purposes

Thank you and cheers

FTC-AID-7

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 27 of 57 Page ID 1786

26

Exhibit A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 28 of 57 Page ID 1787

EXHIBIT B

Attachment A

((

z | ~

AIDINGSTUDENTRELIEF

bull bull bull bull bull

13 deg $ $ampdegdeg deg() ˝ amp $$deg( + -+Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 29 of 57 Page ID 1788

bulldaggerDagger Daggermdashndash Daggerhellip ƒfrasl hellip lsaquorsaquobullminuspermilminushellip bdquolsaquoldquo rsaquordquobulllsquo fraslbullrsquopermillsaquofraslpermilminushellip sbquo

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DZgtA=EFGHIJFKLMNOPFQOGFHIQRSTLKSUMMNOPLHMTFIVRWXHKKNIFNUNOPRLFGSHKSRVRVNQ

f e=klHMW

9SI]UQMSNSOQOHHPFK YaSTHHVVJFMHcVGNOJVHHFKKPSUHMLIUOQN_PL[KSVFGJPRSDTHRFPLIP=SNDC==GFdFIP9VaNHQTWSRPbHF_PSKSVNMPMHNIO XNNIIFRKNF7IKSQQMHFNDVPOS9IAeTHPdKSUMMFNKHONP 8aF_KSNVPHTNIMNR[POVFgNPTHLNHIgtMFI YTFHIdFFI D9aHVR_KNKHFHIWIQOTHIQbFFP

lt=Dkgt=L]oHUKMMH ihTFNIORI THHVPRFMVKgtNJ_NFFbIVSJI]IFjdGGVNNN lt=TFKPPNF 9DaFGmVHPGRJMFNNQOSGnPFFTNLUNHPMIMTFVNJOKMIWV

27

]UMNOHPFRKNVSHKKISIRWRrGZNJONgtNjTHKHMI=cQgtORHVPKSOUMddUNKSPIdspNVPNq_ lt=gtBTHFHPb=HFILGFHMt DTFuFIUVFRPNTFIMINVWOPRVOQFIV sFQFPHKKH vaIPNFVcSyOFSPRFMRNVOJH_gtVFDVUJAN9FPwFuVFJLFHMP_VTFFdSIIVdNHUPxI=DQSROJGASHIVdDSNMINONPPaHdOHdPFHRIWVFFHdFIGM˙ 01 $2 301 $$3 ( Exhibit B

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rsaquominus MZ|PUpermilSWUzSOUZXWbdquoDaggerUxYP~PNZSZ|YSRSx~WRYDaggerSOVQSYNOOPQNPxSZMZ|PUpermilSWU~rdquoUDaggerSOUZXzSZmdashMZSZO|SWUWXRYWUSZWOPQDaggerSOZPXRYZymdash zQhellipY|daggerUxTY|UvPSZwPxyYTUZUWWMNOPQbullPxlsquoNPxSyPTUxZUZXPxySZYrsquoSXYPZSXS|YXOWXSXUPxNU~UxSUTUOPQSOVQSYNONPxXRUzQhellipY|daggerUxTY|UvPSZwPxyYTUZUWWDaggerxPyxSmdashsbquotrade f8Ef8E78FCB6C8EŁPQSOhellipUShellipUXP|PhellipYZUQXYDaggerUNU~UxSWXQ~UZXPSZWYZXPPZUZUbullPSZbullYXRSPbullUxPxUSŒPx~ShellipUPZXRODaggerSOUZXmdashvPSZ|PZWPY~SXYPZDaggerxPyxSW|SZRUDaggerOPQVQSYNONPxS~~YXYPZSDaggerxPyxSW YlsquoU PSZ NPxyYTUZUWWDaggerxPyxSWPxzQhellipY|daggerUxTY|UvPSZwPxyYTUZUWWmdash ŠmŸŽıłŠm 57gt8A57A5B= 8E65C76B5E6F8EB5=6G

PONM[5 QRSTUVQU PYXWZW lt4556789588lt959=lt CD lt H5FICEDJ8KA5LCD

A565E7gt57 œšžeuroiexclcentpoundyenbrvbarsectbrvbareurocopypoundsectlaquoeuropoundlaquobrvbarlaquoregplusmncentbrvbareurocent microparalaquo europoundž raquoY|frac14frac12 plusmncurrenRSUraquoSxXYZeuropoundlaquo laquoeurolaquoordf frac34

^ ˙ ( (

28

Attachment A

01 $2 301 $$3 ( Exhibit B

()(

=4ABC9DEAFBD=FGFHIJKLMJNOMN MRNS mn = nrst = svzhellipu t bulltvDaggerrhellipDaggerurbullbulltuhellipv hellipz~ bullmdashldquordquolsquorsquotrade š oŒŠeuro centpound ` umluml 13 deg $ $ampdegdeg degˇ amp $$deg + -+Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 31 of 57 Page ID 1790

ISNRTUKQINKKNNKL[MRJ PUWQI]MRM qyt|tytzxy rsaquoqNfraslbdquoPUhellipsbquoLUyQhellip rfraslbhellipMNSIKVUQ QNJKvUQsMiexclQQJUx[iexcliexcl_vsect_Qyenyenbrvbarbrvbar uSSRNTPL_LUUMKIaJ_WMIJJKVIONNQJJMWRMIIbQQURKLWIIJQbKLUNKMPTMNQQ_KKRY tbullbulldaggersDaggerv~vhellipmdashryrhellip~mdashrhellipDagger ŸLŽUıQŽbłpermilMtradeœsbquoNtrade_ffRŁyISMŒUQWyNUQŠlsaquo rv45657896lt7ltgt5lt PQKLMIQSNRTUKINQVNOOMVKMWNQKLIJPMXJIKMYZMPIOO NJMOOJLURMNRRMKKLIJ klltko ltgtlt85p5gt5 ouvwxrz ^^ ~ minuspermil tffŁ yenpoundpound KNOWDaggerIreggt4lt97ltndash9ƒ Dagger hellipDaggerlsaquo žko74k57ƒ ƒISNcurrenUIWIbJKWMKJYVNTKM KLONNRqIQQSNNRTUKINQQIJ_JMWNQKLIJJJPMXJIKMcOMUJMVNQKUVK_JUKBHdefABCgDEAFBDghidjlaquopoundbrvbariexclnotvIWIQbDaggerK_WMQKbullMOIMSvOObullIbLKJbullMJMRMW ordf copy

01( $2(301$$3( Exhibit B

29

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 32 of 57 Page ID 1791

EXHIBIT C

Attachment A

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Something awesome is coming soon We are buildin somethin ve cool Sta tuned and be at1ent Your atience will be well aid

~lbullrbullUiUffl We can help you reduce and simplify your payments

101 Loan For iveness

1~u 0 (middottmiddotbullmiddotmiddot1 1~=I -- _~

HZamp IMUliULlampRampatiEUWi nmiddot middot-il~ fr middot 8rbullbullrcrr-

_J l _ 1 _f _ur -~t~ u L liYu

~ Income Based Pa ents

bull ~ f I - - I - I - ri u ~u-=lf ~ JU

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~ LdfiJIMifJ11JJMJllfFffi

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JJd r g-_iraE-1 agltr-middot- ntimiddot middot)middotou

tmiddot_rt- i ic l~1ri ~rbullmiddot middot111~ umiddot -_ d_t-c

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If -bull 13n ~Cbull t~middot rct1~j d- gtOY- - hO- irmiddot (bulldbull) plltmiddotmiddot- leemiddotmiddot JOu

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Exhibit C

Case 818-cv-01987-JLS

-KE

S

Docum

ent 50-1 F

iled 020519 P

age 33 of 57 P

age ID 1792

30

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 34 of 57 Page ID 1793

EXHIBIT D

Attachment A

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Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 35 of 57 Page ID 1794

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

infoaidnestcom (800) 555-1212

HOME

ABOUT US

SERVICES

FAQ

BLOG

CONTACT

HOME ABOUT US SERVICES FAQ BLOG CONTACT

1 of 6 462018 945 AM

31

Student Loan Forgiveness Loan Consolidation Student Loan Forgiveness

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 36 of 57 Page ID 1795

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

If you have Federal Student Loans yoursquore in the right place to get those loans reduced forgiven or completely discharged through our student loan forgiveness programs

Get your multiple Federal Student Loans consolidated into one forget about increasing interests and pay month to month at the lowest possible cost

We understand if yoursquore going through some hardship and thatrsquos why with us yoursquoll be able to make monthly payments based on your affordability for as low as $000 depending on your situation

2 of 6 462018 945 AM

32

Knowledge Base

Defaulted Student Loans

Wage Garnishment

Student Loan Rehabilitation

Income Based Repayment Plan

Deferment and Forbearance

Pay As You Earn Repayment Plan

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE Call 561)424-6053 today to go over your options

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 37 of 57 Page ID 1796

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

Our knowledge base is designed to provide information regarding some of the critical topics those with student loans must be aware of to be able to make educated decisions regarding their future

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

A wage garnishment is any legal procedure in which some portion of a personrsquos earnings is required to be withheld by an employer for the payment of a debt

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

With this program your payments change as your income changes and will not be longer than 25 years This is the ideal plan if you are in partial financial hardship Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard plan

Temporarily allowing you to postpone or reduce your federal student loan payments Postponing or reducing your payments may help you avoid default and future garnishments

Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard

3 of 6 462018 945 AM

33

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 38 of 57 Page ID 1797

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

4 of 6 462018 945 AM

34Attachment A

Testimonials

Latest News

Why 2016 Will Be a Big Year For Student Loans

Top Student Loan Refinancing Questions of 2015

Oba mas latest student loan plan

Things You Should Know About Public Service Loan Forgiveness

Recent Posts

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 39 of 57 Page ID 1798

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

5 of 6 462018 945 AM

35

About Us

Contact Info

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 40 of 57 Page ID 1799

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

pay-grandchild-studen

Why 2016 Will Be a Big Year For Student Loans

December 30 2015

12511110_1112367518

Top Student Loan Refinancing Questions of 2015

December 30 2015

We stand by our consultation and quote We are so sure and confident about our services and offers that they are all 100 money back guarantee risk free ndash if we donrsquot do what we promise yoursquoll get your money back

(800) 555-1212 AidnestStudenLoansgmailcom 18100 Von Karman Ave Suite 850 Irvine CA 92612

Futero SAS copy 2015 | Aidnestcom

6 of 6 462018 945

Exhibit D 36Attachment A

AM

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 41 of 57 Page ID 1800

EXHIBIT E

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 42 of 57 Page ID 1801

AIDNEST Let us help you through this national crisis

Call one of our specialists today

Forbearance amp Deferment If you are still in school and struggling to make payments on your student loans You may qualify

for Forbearance amp Deferment

Garnishment Prevention Federal law requires that the Department of Education or guarantee agency notifies you before they

begin garnishing your wages

Loan Forgiveness If you are a teacher public service worker or an individual with total and permanent disability you

httpaidnestcom[442018 115239 AM]

37Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 43 of 57 Page ID 1802

AIDNEST Let us help you through this national crisis

may qualify for this program

Consolidating Your Loans Consolidating your loans to one new loan under one lender may lower your payments and make

your life a bit more manageable

Affordable Payments If you are looking to lower your monthly payments then Income Based Repayment Plans may be

the correct choice for you

Learn more about our services

LEARN MORE

httpaidnestcom[442018 115239 AM]

38Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 44 of 57 Page ID 1803

AIDNEST Let us help you through this national crisis

Loan Forgiveness Programs Income Based Payments Student Loan Rehabilitation

Student Loan Consolidation

You may be eligible for

Loan Forgiveness Programs

In some cases individuals with Federal Student Loans may qualify to have a portion of the amount

owed to be forgiven

Get in touch with our professional team to find out which loan forgiveness program you qualify for and

how you can get rid of your unpaid student loan

L EARN MORE

httpaidnestcom[442018 115239 AM]

39Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 45 of 57 Page ID 1804

AIDNEST Let us help you through this national crisis

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE

Meet your Budget One of our advisers will help you meet your payment goals by using your budget and timeline to

determine the best plan available

httpaidnestcom[442018 115239 AM]

40Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 46 of 57 Page ID 1805

AIDNEST Let us help you through this national crisis

Simple Process We understand that lowering your payments alone can be difficult Our intuitive platform allows us

to keep the entire process simple

Customer Satisfaction We are committed to providing you with outstanding service only We look forward to working

with you

100 money back guarantee No Hassle Money Back Policy

httpaidnestcom[442018 115239 AM]

41Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 47 of 57 Page ID 1806

AIDNEST Let us help you through this national crisis

Lower your loan payments by getting in touch with one of our professionals

We design a customized repayment plan that will allow you to make payments based on your

monthly income family size and spending Get rid of the hassle of extensive paperwork and get the

help you deserve

What we can help you achieve a lower payment or lower rate

httpaidnestcom[442018 115239 AM]

42Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 48 of 57 Page ID 1807

AIDNEST Let us help you through this national crisis

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcom[442018 115239 AM]

43Exhibit E

httpaidnestcomservices[442018 115322 AM]

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 49 of 57 Page ID 1808

Services | AIDNEST Let us help you through this national crisis

INCOME BASED PAYMENTS

If you are suffering from a financial hardship you may be eligible for an

Income Based Payment In this repayment program you would have a

payment based on your income and family size The payment could be as

low as $000 per month with forgiveness at the end of 20-25 years

44

Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 50 of 57 Page ID 1809

L E ARN MORE

LOAN FORGIVENESS

If you have Federal Student Loans you may qualify for any of the student

loan forgiveness programs that are available to borrowers You may be

eligible for principal reduction loan forgiveness or a complete loan

discharge depending on your individual circumstance

L EARN MORE

PRIVATE STUDENT LOAN CONSOLIDATION

Much like refinancing a mortgage generally the biggest benefit of private

student loan consolidationstudent loan refinancing is a lower interest rate

httpaidnestcomservices[442018 115322 AM]

45Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 51 of 57 Page ID 1810

L E ARN MORE

(something federal consolidations do not offer)

STUDENT LOAN REHABILITATION

You can renew eligibility for new loans and grants and eliminate the loan

default by ldquorehabilitatingrdquo a defaulted loan

httpaidnestcomservices[442018 115322 AM]

46Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 52 of 57 Page ID 1811

CHE CK E L E G I B I L I T Y

WAGE GARNISHMENT

A wage garnishment is any legal procedure in which some portion of a

personrsquos earnings is required to be withheld by an employer for the

payment of a debt

L EARN MORE

With our fast friendly and professional services wersquoll be glad to help you get your student loans

reduced forgiven or completely discharged To this end wersquoll assist you in consolidating all your

student loans so yoursquoll have only one lender and yoursquoll start making one monthly payment Our

professionals will walk you through the best and most flexible repayment options and if itrsquos also

necessary varied deferment options and rehabilitation programs

httpaidnestcomservices[442018 115322 AM]

47Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 53 of 57 Page ID 1812

Services | AIDNEST Let us help you through this national crisis

Our CRM System

Our CRM is one of the most advanced in the industry and most importantly itrsquos linked directly to

the Department of Education (DOE) This keeps your personal and most confidential information

safe Furthermore because our CRM system is linked to the DOE our approval is 100 Through

our CRM we will be doing continuous monitoring of our process without losing sight of your

immediate needs ensuring that your case has the proper handling and most efficient process

httpaidnestcomservices[442018 115322 AM]

48Exhibit E

n

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 54 of 57 Page ID 1813

Services | AIDNEST Let us help you through this national crisis

R ECENT POSTS

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

ABOUT US

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcomservices[442018 115322 AM]

49Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 55 of 57 Page ID 1814

EXHIBIT F

s -

bullmiddot - ~ t ~ower Your Student Loan Pay~e~ts oday -- Students Helping Students Save Money

INCOME BASED PAJIIIJITPAIS

I C(gttoUC1 u~

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 56 of 57 Page ID 1815

X + C (D Not secure wwwstudoracom 0

CALL US NOW (85S) 978-S599 middot 1nfostudoracom

HOME SERVICES ABOUT US FAQ CONTACT US BLOC PRIVACY

Offering obligation and commitment free loan relief solutions

STUDENT LOAN FORGIVENESS INCOME BASED PAYMENTS LOAN CONSOLIDATION

We11 help you get your loans reduced forgiven o r Make monthly pdyments based on your affordability Get multiple Federal Student Loans consolidated into

discharged one low monthly payment

Talk to our experts concerning your

student loans

Studora is a pnvatefy owned company that helps consumers like you identify

government programs that fit your financial s1tuat1on Our loan experts will assist you in selecting the appropriate programs that WOltk with your income family size and

desired monthly payment We then prepare the appropriate documents for your review and submission All this f o r one low easy payment

Testimonials

Thank you f o r getting back to me quickly Youve been fabulous Thank you for the confirmation and for your help today Pass

during this whole process Is there a place I can go online that I this on to your sup that you were very professional and very

can leave a comment for your manager Youve made this Robert helpful and brought a sense of relief for me Thank you very

process so easy and answered every question my husband and I much and have a great rest of your day Kudos to you and your

have had teammoneywell spenL

Exhibit F 50

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 57 of 57 Page ID 1816

Services we offer

Stud ora offers document preparation services for all loan forgiveness consolidation and relief services to people who are unable to manage their finances Our mam aim is to

offer complete peace of mind to indiVidual unable to pay their student loan debt

we otter the folloWing document preparation services with complete professional assistance

amFinancial Review ffl Budget Planning

Toe first step to creating a flexible loan repayment plan is financial review we also help create a personal finance plan to ensure that you are able to

Our professmnals will look into your finances and design a custom manage your monthly budget in the most effective way This plan will keep

repayment plan that is affordable and easy to manage your spending to the minimum alloWing you to save more money for loan

repayment

Permanent Disability Forgiveness r-trTeacher Loan Forgiveness (5 You can get rid of your Federal Student Loan if you are permanently disabled Good news for teachers who are under the weight of a massiVe loan You can

now get $17 forgiven on your student loans

Public Service Loan Forgiveness Custom Debt Relief Plans

Want assistance with debt relief Get in touch with our experts who will help If you are a public service agent you can get rid of your loan after 120 days of design a loan repayment and relief plan for you based on your monthly

income and affordability payments

THERE ARE NO OBLIGATIONS OR COMMITMENTS

want to save thousands of dollars Fill out our form and get relief from your student loan for a more

peaceful tomorrow

Your Name

BiHHHi

Exhibit F 51

Attachment A

Page 13: JOSHUA S. MILLARD, BRIAN M. WELKE, pro hac vice · for which it has no legitimate claim. Noel is a Wyoming limited liability company that reported in a public document that its principal

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 13 of 57 Page ID

1

2

3

4

5

6

7

8

9

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13

14

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18

19

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22

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25

26

27

28

1772

31 Defendantsrsquo telemarketers have sought and obtained consumersrsquo

payment information by phone or the Internet

32 Defendantsrsquo total advance fees typically have been in the range of

$300-500 Defendants also have charged consumers recurring monthly fees for

purported debt relief services typically charging $19 per month

THE FTC ACT

33 Section 5(a) of the FTC Act 15 USC sect 45(a) prohibits ldquounfair or

deceptive acts or practices in or affecting commercerdquo

34 Misrepresentations or deceptive omissions of material fact constitute

deceptive acts or practices prohibited by Section 5(a) of the FTC Act

VIOLATIONS OF THE FTC ACT

Count One

(Deceptive Student Loan Debt Relief Representations)

35 In numerous instances in connection with the advertising marketing

promotion offering for sale or sale of student loan debt relief services Defendants

have represented directly or indirectly expressly or by implication that consumers

who purchase Defendantsrsquo debt relief services will or likely will have their

monthly payments reduced or their loan balances forgiven in whole or in part

36 In truth and in fact in numerous instances in which Defendants have

made the representations set forth in Paragraph 35 of this Complaint such

representations were false or not substantiated at the time Defendants made them

37 Therefore Defendantsrsquo representations as set forth in Paragraph 35 of

this Complaint are false or misleading and constitute deceptive acts or practices in

violation of Section 5(a) of the FTC Act 15 USC sect 45(a)

THE TELEMARKETING SALES RULE

38 Congress directed the FTC to prescribe rules prohibiting abusive and

deceptive telemarketing acts or practices pursuant to the Telemarketing Act 15

13

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 14 of 57 Page ID

1

2

3

4

5

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17

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23

24

25

26

27

28

1773

USC sectsect 6101-6108 in 1994 The FTC adopted the original TSR in 1995

extensively amended it in 2003 and amended certain sections thereafter 16

CFR Part 310

39 Defendants are ldquoseller[s]rdquo or ldquotelemarketer[s]rdquo engaged in

ldquotelemarketingrdquo as defined by the TSR 16 CFR sect 3102(dd) (ff) and (gg) A

ldquosellerrdquo means any person who in connection with a telemarketing transaction

provides offers to provide or arranges for others to provide goods or services to a

customer in exchange for consideration 16 CFR sect 3102(dd) A ldquotelemarketerrdquo

means any person who in connection with telemarketing initiates or receives

telephone calls to or from a customer or donor 16 CFR sect 3102(ff)

ldquoTelemarketingrdquo means a plan program or campaign which is conducted to

induce the purchase of goods or services or a charitable contribution by use of one

or more telephones and which involves more than one interstate telephone call 16

CFR sect 3102(gg)

40 Defendants are sellers or telemarketers of ldquodebt relief servicesrdquo as

defined by the TSR 16 CFR sect 3102(o) Under the TSR a ldquodebt relief servicerdquo

means any program or service represented directly or by implication to

renegotiate settle or in any way alter the terms of payment or other terms of the

debt between a person and one or more unsecured creditors or debt collectors

including but not limited to a reduction in the balance interest rate or fees owed

by a person to an unsecured creditor or debt collector 16 CFR sect 3102(o)

41 The TSR prohibits sellers and telemarketers from requesting or

receiving payment of any fees or consideration for any debt relief service until and

unless

a The seller or telemarketer has renegotiated settled reduced or

otherwise altered the terms of at least one debt pursuant to a

14

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 15 of 57 Page ID

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

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17

18

19

20

21

22

23

24

25

26

27

28

1774

settlement agreement debt management plan or other such

valid contractual agreement executed by the customer and

b The customer has made at least one payment pursuant to that

settlement agreement debt management plan or other valid

contractual agreement between the customer and the creditor

and

c To the extent that debts enrolled in a service are renegotiated

settled reduced or otherwise altered individually the fee or

consideration either

i Bears the same proportional relationship to the total fee

for renegotiating settling reducing or altering the terms

of the entire debt balance as the individual debt amount

bears to the entire debt amount The individual debt

amount and the entire debt amount are those owed at the

time the debt was enrolled in the service or

ii Is a percentage of the amount saved as a result of the

renegotiation settlement reduction or alteration The

percentage charged cannot change from one individual

debt to another The amount saved is the difference

between the amount owed at the time the debt was

enrolled in the service and the amount actually paid to

satisfy the debt 16 CFR sect 3104(a)(5)(i)

42 The TSR prohibits sellers and telemarketers from misrepresenting

directly or by implication any material aspect of any debt relief service including

but not limited to the amount of money or the percentage of the debt amount that a

customer may save by using the service 16 CFR sect 3103(a)(2)(x)

15

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 16 of 57 Page ID

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

1775

43 Pursuant to Section 3(c) of the Telemarketing Act 15 USC

sect 6102(c) and Section 18(d)(3) of the FTC Act 15 USC sect 57a(d)(3) a violation

of the TSR constitutes an unfair or deceptive act or practice in or affecting

commerce in violation of Section 5(a) of the FTC Act 15 USC sect 45(a)

VIOLATIONS OF THE TELEMARKETING SALES RULE

Count Two

(Advance Fee for Debt Relief Services)

44 In numerous instances in connection with the telemarketing of

student loan debt relief services Defendants have requested or received payment

of a fee or consideration for debt relief services before

a Defendants have renegotiated settled reduced or otherwise

altered the terms of at least one debt pursuant to a settlement

agreement debt management plan or other such valid contractual

agreement executed by the customer and

b The customer has made at least one payment pursuant to that

settlement agreement debt management plan or other valid

contractual agreement between the customer and the creditor

45 Defendantsrsquo acts or practices as described in Paragraph 44 of this

Complaint are abusive telemarketing acts or practices that violate Section

3104(a)(5)(i) of the TSR 16 CFR sect 3104(a)(5)(i)

Count Three

(Material Debt Relief Misrepresentations)

46 In numerous instances in connection with the telemarketing of

student loan debt relief services Defendants have misrepresented directly or

indirectly expressly or by implication material aspects of their debt relief services

including but not limited to that consumers who purchase Defendantsrsquo debt relief

services will or likely will have their monthly payments reduced or their loan

16

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 17 of 57 Page ID

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

1776

balances forgiven in whole or in part

47 Defendantsrsquo acts and practices as described in Paragraph 46 of this

Complaint are deceptive telemarketing acts or practices that violate Section

3103(a)(2)(x) of the TSR 16 CFR sect 3103(a)(2)(x)

Count Four

(Disgorgement of Ill-Gotten Gains of Relief Defendant)

48 Relief Defendant Noel has received directly or indirectly funds or

other assets from Defendants that are traceable to funds obtained from Defendantsrsquo

customers through the unlawful acts or practices described herein

49 Relief Defendant Noel has no legitimate claim to Defendantsrsquo

customersrsquo funds or other assets and will be unjustly enriched if it is not required to

disgorge the assets or the value of benefits received as a result of Defendantsrsquo

unlawful acts or practices

50 By reason of the foregoing Relief Defendant Noel holds funds and

assets in constructive trust for the benefit of Defendantsrsquo customers

CONSUMER INJURY

51 Consumers have suffered and will continue to suffer substantial injury

as a result of Defendantsrsquo violations of the FTC Act and the TSR In addition

Defendants have been unjustly enriched as a result of their unlawful acts or

practices Absent injunctive relief by this Court Defendants are likely to continue

to injure consumers reap unjust enrichment and harm the public interest

THIS COURTrsquoS POWER TO GRANT RELIEF

52 Section 13(b) of the FTC Act 15 USC sect 53(b) empowers this Court

to grant injunctive and such other relief as the Court may deem appropriate to halt

and redress violations of any provision of law enforced by the FTC The Court in

the exercise of its equitable jurisdiction may award ancillary relief including

rescission or reformation of contracts restitution the refund of monies paid and

17

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 18 of 57 Page ID

1

2

3

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17

18

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21

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23

24

25

26

27

28

1777

the disgorgement of ill-gotten monies to prevent and remedy any violation of any

provision of law enforced by the FTC

53 Section 6(b) of the Telemarketing Act 15 USC sect 6105(b)

authorizes this Court to grant such relief as the Court finds necessary to redress

injury to consumers resulting from Defendantsrsquo violations of the TSR including

the rescission or reformation of contracts and the refund of money

PRAYER FOR RELIEF

Wherefore Plaintiff FTC pursuant to Section 13(b) of the FTC Act 15

USC sect 53(b) Section 6(b) of the Telemarketing Act 15 USC sect 6105(b) and

the Courtrsquos own equitable powers requests that the Court

A Award Plaintiff such preliminary injunctive and ancillary relief as

may be necessary to avert the likelihood of consumer injury during

the pendency of this action and to preserve the possibility of effective

final relief including but not limited to temporary and preliminary

injunctions orders freezing assets immediate access to business

premises appointment of a receiver and expedited discovery

B Enter a permanent injunction to prevent future violations of the FTC

Act and the TSR

C Award such relief as the Court finds necessary to redress injury to

consumers resulting from Defendantsrsquo violations of the FTC Act and

the TSR including but not limited to rescission or reformation of

contracts restitution the refund of monies paid and the disgorgement

of ill-gotten monies

D Enter an order requiring Relief Defendant to disgorge all funds and

assets or the value of the benefit it received from the funds and assets

which are traceable to funds obtained from Defendantsrsquo customers

through the unlawful acts or practices described herein and

18

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 19 of 57 Page ID 1778

2

3

E Award Plaintiff the costs of bringing this action as well as such other

and additional relief as the Court may determine to be just and proper

Dated February 5 2019

Respectfully submitted

ALDEN F ABBOTT General Counsel

JosaSMillard Brian M Welke middot Barbara Chun (Local Counsel) Attorneys for Plaintiff FEDERAL TRADE COMMISSION

4

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Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 20 of 57 Page ID 1779

EXHIBIT A

Attachment A

Free Assessment

Our expercs will lt1ssPss you cun ent

swclent lo n program and decermn which progr ms are

avc11l bl rn yoL11 situation We wi I help you cl11cic1e which progr m r1

help you achieve your goals Call us today

Service Guarantee We are commmecl to 11-1 111g

CllStomers get low r rc1ces ancl monthly payments and we w1I

m ke the pror~ss se mless and s r11ghtforwc1rd ou wi ll be sansf1ed

with our service ml OLlr

cornmcmem to you success Thars ow gu~ ancee

Success Rate Ou1 96 ~ surcPss r a e s 11e of he

cop I a ings tn he industry Olr

process has beer tested nd Olli

succ ss r r~ prowbull~ tn t it works

We c n ll~lp yo reduce and -1111ph y our p ~ymP1 ts Call us today

FTC-AID-1

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 21 of 57 Page ID 1780

20

Exhibit A

ABOUT US

We can help you reduce and simplify your pay1ncnts Contact one of our specialists today for

a free evaluation

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We Have Been Featured In

FTC-AID-2

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 22 of 57 Page ID 1781

21

Exhibit A

SERVICES Wt w gtL

Loan Forgiveness Income Based Payments Loan Consol idation In some cases individuals with A period of financial hardship may You may be able to combine

Fede1middota1 Student Loans may qualify qualify you for an Income Based nultiple federal student loans into to have a portion of the amount Repayment Plan In many cases this one new loan w ith a lower more

owed may be forgiven This means means you pay nothing Unlike a affordable monthly payment Loan

your principal balnce coulcl be defe1 ment the term on your loan consolidation prngrams can l1elp

significantly reduced and you will continues to reduce while the plan is you qualify for additional programs not be expected to repay the in place Your term could reduce like loan forgiveness programs or

forgiven amount while you pay nothing Public Setvice Loan Forgiveness

a III

Private Sector Loan Forgiveness

If you work for a government

organization at a city state or

federa l level you may qualify for tle

PL1blic Service Loan Forgiveness

program To qualify your loans

must be cotisolidated into a specific

repayment plan The balance on

your federai student loans is

forgiven after 120 qualifying

bull C Permanent Disability

Forgivenness If your disability is expected to last

60 months or more you may qualify

for permanent disability forgiveness

Q1alifying for Permnent Disability

Forgiveness requires a visi t to your

doctor and individL1als enrolled in

the program are subject to three

years of post-discharge monitoring

Wage Garnishment Prevention

Federal law requires that the

Department of Education or a

gua1middotanty agency notify you before

111st1tuting wage garnishment You

have tl1e right to a hearing where

you can challenge the stated

amount owed and negotiate the

terms of the repayment scheclule

We can intervene on YOL1PflJl~1D-3

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 23 of 57 Page ID 1782

22

Exhibit A

payments have been made p1middotevent wage gampnishments

A FEW STATISTICS ABOUT STUDENT LOAN CRISIS

12 Trillion National Student Debt I he nitionil student loin debt is

now 17 trillion dollirs 1 trillion of

these are in federil student loans

Let us help you through this national

crisis Cill today for a free

evaluation

40 Million Students with Debt

In 7014 an estimated 40 million

current and former students were in

debt because of student loans If

you are one of the millions of people

struggling to pay student loans

Aiding Student Relief is here to help

$33000 Average Student Debt

The graduating class of 7014

average $33000 of student loan

debt per person Thats $3000 more

than the average in 2013 Dont be

one of the many Let Aiding Student

Relief advocate for you

Aiding Student Relief has helped cmrnllcss 1woplc reduce their student debt_ Their proven business

plan has led lo one of lhc highest s11cclSS raCs in the inltl11slly

John Standiford Associated

FTC-AID-4

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 24 of 57 Page ID 1783

23

Exhibit A

TESTIMONIALS

Til~nks to Aiding Student Rel ief Im middotI middotva ove1vvhelrnecl but Aiding The expemiddotts at l1icl i11g Student Rel ief

s1v ing $250 per month Strrd r~rt Relief expl~ inecl the were ther~ to help me when I process ancl rnacle everytl1ing cle11middot nelclecl 1t rw)s t

and sirnple

I Michael Ma 1in

Entrep e11eu1 Em iiy Jallo1 Ii Pa ul Ch is tia I1se11

Teacher Nurse

With so many programs I didnt middotconso lrclating my loans into one I love my Job but vith my high

know what was ng ht for me My monthly payment hs made life student loan payment was still

sruclent loan aclvsor walked me si1nple1 Now I can focus on 1Nhn bamiddotely getting by I don t kn ow what I

through my optio ns rnd now Imiddotn matters to me would hwe clone wthout Aiding

saving 54 I 11n1omh Stucie1middott Rel refmiddot

Ariel Hemiquez Sales co)SUltant

Stephani Seland-1 Small Busim~ss Owner

AJ 01en Museum Curator

RECENT NEWS

)lt)

o(l ttDrlTI -5

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 25 of 57 Page ID 1784

24

Exhibit A

Student Debt Crisis Business Latest Debt Collective Demands May be largely about smallest Student

borrnwers US News amp World Loan Crisis is fa frorn ove The Debt Collective is a group of Report-May 162015 last month Two new reports suggest the college students calling the Fedemiddotal Reserve Bank of New student loan crisis is easing them-se1ves the Corinthian York repor ced that stuclent loan somewhat as the economy Fifteen who are refusing to pay balances rose to 16 trillio n and improves but the crisis is far back their student loins As pa t that 113 per cent of that is in from ove the College Board of this effort the Debt Collective repo t~ tot31 borrowing fell by 8 has written an open lette to the pEbull1 cent between 2012-13 and Department of Education f l llJ 20 13-14 The organization

About Us 11 1 i~d1middot1r F th~~- h1~ ff t1middot~11middot=cl =i~=middott- 1middot __31middotmiddotIIgt middot bullmiddot11

middot- I ( )ntir il t l~i -r_il fr~~

Address bull middot tc1ltj-1r_ =i ~

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FTC-AID-6

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 26 of 57 Page ID 1785

25

Exhibit A

f - g+ in O) ~ PRIVACY POLICY

This privacy statement discloses the privacy practices for AidllII Student Relief Because Aiding Studen Relief wonts to demonstrate ts firm commlcmell to your

privacy Aiding Sudent Relief hes greed to disclose ls 1rifor111atlori g1thering and dlssem1n1t1on prct1cts Aidlns Studtrit Relief will notify you of

INFORMATION COLLECTION At-ID USE

Aiding Student Relief is the sole owner of the rformMlon collected on this site We will not sell shire or rent this information 10 others In way different from what Is

disclosed 1n this statement Aldln1 StudeM Relief collects 1nform111on throuah this site from our prospective end existing clients at several different poin on our web

site We use their contact Informii on to send information bout our company and to service exsMs accounts Users may optbullout of rece11ns future malllngs see the

cholceoptbullout section below Contect and Financial information that 1s collected Is used for verifying your name address and other informa1on as well as to boll you for

your use of our Gerv1ces using Information from third party sourcH Information about your computer hardwre and software Is automatically collected by Aiding

Student Relief and may be shared in asgregate with third parties whose services are used for traffic analysis purposes This Ir formation includes your IP address

browser type domain names access times and referring Web site addresses Ths information is no tied to personally Identifiable Information This 1nformatlor s used

by Aiding Student Relief to malMan no Improve the quality of the Hrvct and to senerae statistics resardlng use of he Aiding Student Relief site We use third party

services to bill for serlces and to provide other services like our Live Help chat We store the transcripts from these chats for customer service Improvement These

third party service providers are not permitted to use your infornon for any secondary purposes

Thank you and cheers

FTC-AID-7

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 27 of 57 Page ID 1786

26

Exhibit A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 28 of 57 Page ID 1787

EXHIBIT B

Attachment A

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AIDINGSTUDENTRELIEF

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4556789fADlt=gtA9BCAD

DZgtA=EFGHIJFKLMNOPFQOGFHIQRSTLKSUMMNOPLHMTFIVRWXHKKNIFNUNOPRLFGSHKSRVRVNQ

f e=klHMW

9SI]UQMSNSOQOHHPFK YaSTHHVVJFMHcVGNOJVHHFKKPSUHMLIUOQN_PL[KSVFGJPRSDTHRFPLIP=SNDC==GFdFIP9VaNHQTWSRPbHF_PSKSVNMPMHNIO XNNIIFRKNF7IKSQQMHFNDVPOS9IAeTHPdKSUMMFNKHONP 8aF_KSNVPHTNIMNR[POVFgNPTHLNHIgtMFI YTFHIdFFI D9aHVR_KNKHFHIWIQOTHIQbFFP

lt=Dkgt=L]oHUKMMH ihTFNIORI THHVPRFMVKgtNJ_NFFbIVSJI]IFjdGGVNNN lt=TFKPPNF 9DaFGmVHPGRJMFNNQOSGnPFFTNLUNHPMIMTFVNJOKMIWV

27

]UMNOHPFRKNVSHKKISIRWRrGZNJONgtNjTHKHMI=cQgtORHVPKSOUMddUNKSPIdspNVPNq_ lt=gtBTHFHPb=HFILGFHMt DTFuFIUVFRPNTFIMINVWOPRVOQFIV sFQFPHKKH vaIPNFVcSyOFSPRFMRNVOJH_gtVFDVUJAN9FPwFuVFJLFHMP_VTFFdSIIVdNHUPxI=DQSROJGASHIVdDSNMINONPPaHdOHdPFHRIWVFFHdFIGM˙ 01 $2 301 $$3 ( Exhibit B

8

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13 deg $ $ampdegdeg degˇ amp $$deg + -+Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 30 of 57 Page ID 1789 () ( vPSZwPxyYTUZUWWzxPyxSWMZWPU|SWUWYZ~YTY~QSWbullYXRwU~UxSdaggerXQ~UZXvPSZWSOVQSYNOXPRSTUSDaggerPxXYPZPNXRUSPQZXPbullU~SOhellipUNPxyYTUZmdash zUxSZUZXndashYWShellipYYXOwPxyYTUZUWWMNOPQx~YWShellipYYXOYWUƒDaggerU|XU~XPSWXfrasllsaquoPZXRWPxPxUOPQSOVQSYNONPxDaggerUxSZUZX~YWShellipYYXONPxyYTUZUWWmdash

rsaquominus MZ|PUpermilSWUzSOUZXWbdquoDaggerUxYP~PNZSZ|YSRSx~WRYDaggerSOVQSYNOOPQNPxSZMZ|PUpermilSWU~rdquoUDaggerSOUZXzSZmdashMZSZO|SWUWXRYWUSZWOPQDaggerSOZPXRYZymdash zQhellipY|daggerUxTY|UvPSZwPxyYTUZUWWMNOPQbullPxlsquoNPxSyPTUxZUZXPxySZYrsquoSXYPZSXS|YXOWXSXUPxNU~UxSUTUOPQSOVQSYNONPxXRUzQhellipY|daggerUxTY|UvPSZwPxyYTUZUWWDaggerxPyxSmdashsbquotrade f8Ef8E78FCB6C8EŁPQSOhellipUShellipUXP|PhellipYZUQXYDaggerUNU~UxSWXQ~UZXPSZWYZXPPZUZUbullPSZbullYXRSPbullUxPxUSŒPx~ShellipUPZXRODaggerSOUZXmdashvPSZ|PZWPY~SXYPZDaggerxPyxSW|SZRUDaggerOPQVQSYNONPxS~~YXYPZSDaggerxPyxSW YlsquoU PSZ NPxyYTUZUWWDaggerxPyxSWPxzQhellipY|daggerUxTY|UvPSZwPxyYTUZUWWmdash ŠmŸŽıłŠm 57gt8A57A5B= 8E65C76B5E6F8EB5=6G

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28

Attachment A

01 $2 301 $$3 ( Exhibit B

()(

=4ABC9DEAFBD=FGFHIJKLMJNOMN MRNS mn = nrst = svzhellipu t bulltvDaggerrhellipDaggerurbullbulltuhellipv hellipz~ bullmdashldquordquolsquorsquotrade š oŒŠeuro centpound ` umluml 13 deg $ $ampdegdeg degˇ amp $$deg + -+Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 31 of 57 Page ID 1790

ISNRTUKQINKKNNKL[MRJ PUWQI]MRM qyt|tytzxy rsaquoqNfraslbdquoPUhellipsbquoLUyQhellip rfraslbhellipMNSIKVUQ QNJKvUQsMiexclQQJUx[iexcliexcl_vsect_Qyenyenbrvbarbrvbar uSSRNTPL_LUUMKIaJ_WMIJJKVIONNQJJMWRMIIbQQURKLWIIJQbKLUNKMPTMNQQ_KKRY tbullbulldaggersDaggerv~vhellipmdashryrhellip~mdashrhellipDagger ŸLŽUıQŽbłpermilMtradeœsbquoNtrade_ffRŁyISMŒUQWyNUQŠlsaquo rv45657896lt7ltgt5lt PQKLMIQSNRTUKINQVNOOMVKMWNQKLIJPMXJIKMYZMPIOO NJMOOJLURMNRRMKKLIJ klltko ltgtlt85p5gt5 ouvwxrz ^^ ~ minuspermil tffŁ yenpoundpound KNOWDaggerIreggt4lt97ltndash9ƒ Dagger hellipDaggerlsaquo žko74k57ƒ ƒISNcurrenUIWIbJKWMKJYVNTKM KLONNRqIQQSNNRTUKINQQIJ_JMWNQKLIJJJPMXJIKMcOMUJMVNQKUVK_JUKBHdefABCgDEAFBDghidjlaquopoundbrvbariexclnotvIWIQbDaggerK_WMQKbullMOIMSvOObullIbLKJbullMJMRMW ordf copy

01( $2(301$$3( Exhibit B

29

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 32 of 57 Page ID 1791

EXHIBIT C

Attachment A

~ 111 ~tampi 10 11 ~bull ia1111

Something awesome is coming soon We are buildin somethin ve cool Sta tuned and be at1ent Your atience will be well aid

~lbullrbullUiUffl We can help you reduce and simplify your payments

101 Loan For iveness

1~u 0 (middottmiddotbullmiddotmiddot1 1~=I -- _~

HZamp IMUliULlampRampatiEUWi nmiddot middot-il~ fr middot 8rbullbullrcrr-

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~ Income Based Pa ents

bull ~ f I - - I - I - ri u ~u-=lf ~ JU

1-bullA ---rc iM1~~ -~-bullCiel rrcl

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JJd r g-_iraE-1 agltr-middot- ntimiddot middot)middotou

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1r1cbullmiddotn111f11ri ll1fbull fcrn to ~bull~I

Triin- GU

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Exhibit C

Case 818-cv-01987-JLS

-KE

S

Docum

ent 50-1 F

iled 020519 P

age 33 of 57 P

age ID 1792

30

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 34 of 57 Page ID 1793

EXHIBIT D

Attachment A

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Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 35 of 57 Page ID 1794

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

infoaidnestcom (800) 555-1212

HOME

ABOUT US

SERVICES

FAQ

BLOG

CONTACT

HOME ABOUT US SERVICES FAQ BLOG CONTACT

1 of 6 462018 945 AM

31

Student Loan Forgiveness Loan Consolidation Student Loan Forgiveness

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 36 of 57 Page ID 1795

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

If you have Federal Student Loans yoursquore in the right place to get those loans reduced forgiven or completely discharged through our student loan forgiveness programs

Get your multiple Federal Student Loans consolidated into one forget about increasing interests and pay month to month at the lowest possible cost

We understand if yoursquore going through some hardship and thatrsquos why with us yoursquoll be able to make monthly payments based on your affordability for as low as $000 depending on your situation

2 of 6 462018 945 AM

32

Knowledge Base

Defaulted Student Loans

Wage Garnishment

Student Loan Rehabilitation

Income Based Repayment Plan

Deferment and Forbearance

Pay As You Earn Repayment Plan

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE Call 561)424-6053 today to go over your options

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 37 of 57 Page ID 1796

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

Our knowledge base is designed to provide information regarding some of the critical topics those with student loans must be aware of to be able to make educated decisions regarding their future

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

A wage garnishment is any legal procedure in which some portion of a personrsquos earnings is required to be withheld by an employer for the payment of a debt

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

With this program your payments change as your income changes and will not be longer than 25 years This is the ideal plan if you are in partial financial hardship Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard plan

Temporarily allowing you to postpone or reduce your federal student loan payments Postponing or reducing your payments may help you avoid default and future garnishments

Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard

3 of 6 462018 945 AM

33

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 38 of 57 Page ID 1797

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

4 of 6 462018 945 AM

34Attachment A

Testimonials

Latest News

Why 2016 Will Be a Big Year For Student Loans

Top Student Loan Refinancing Questions of 2015

Oba mas latest student loan plan

Things You Should Know About Public Service Loan Forgiveness

Recent Posts

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 39 of 57 Page ID 1798

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

5 of 6 462018 945 AM

35

About Us

Contact Info

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 40 of 57 Page ID 1799

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

pay-grandchild-studen

Why 2016 Will Be a Big Year For Student Loans

December 30 2015

12511110_1112367518

Top Student Loan Refinancing Questions of 2015

December 30 2015

We stand by our consultation and quote We are so sure and confident about our services and offers that they are all 100 money back guarantee risk free ndash if we donrsquot do what we promise yoursquoll get your money back

(800) 555-1212 AidnestStudenLoansgmailcom 18100 Von Karman Ave Suite 850 Irvine CA 92612

Futero SAS copy 2015 | Aidnestcom

6 of 6 462018 945

Exhibit D 36Attachment A

AM

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 41 of 57 Page ID 1800

EXHIBIT E

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 42 of 57 Page ID 1801

AIDNEST Let us help you through this national crisis

Call one of our specialists today

Forbearance amp Deferment If you are still in school and struggling to make payments on your student loans You may qualify

for Forbearance amp Deferment

Garnishment Prevention Federal law requires that the Department of Education or guarantee agency notifies you before they

begin garnishing your wages

Loan Forgiveness If you are a teacher public service worker or an individual with total and permanent disability you

httpaidnestcom[442018 115239 AM]

37Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 43 of 57 Page ID 1802

AIDNEST Let us help you through this national crisis

may qualify for this program

Consolidating Your Loans Consolidating your loans to one new loan under one lender may lower your payments and make

your life a bit more manageable

Affordable Payments If you are looking to lower your monthly payments then Income Based Repayment Plans may be

the correct choice for you

Learn more about our services

LEARN MORE

httpaidnestcom[442018 115239 AM]

38Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 44 of 57 Page ID 1803

AIDNEST Let us help you through this national crisis

Loan Forgiveness Programs Income Based Payments Student Loan Rehabilitation

Student Loan Consolidation

You may be eligible for

Loan Forgiveness Programs

In some cases individuals with Federal Student Loans may qualify to have a portion of the amount

owed to be forgiven

Get in touch with our professional team to find out which loan forgiveness program you qualify for and

how you can get rid of your unpaid student loan

L EARN MORE

httpaidnestcom[442018 115239 AM]

39Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 45 of 57 Page ID 1804

AIDNEST Let us help you through this national crisis

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE

Meet your Budget One of our advisers will help you meet your payment goals by using your budget and timeline to

determine the best plan available

httpaidnestcom[442018 115239 AM]

40Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 46 of 57 Page ID 1805

AIDNEST Let us help you through this national crisis

Simple Process We understand that lowering your payments alone can be difficult Our intuitive platform allows us

to keep the entire process simple

Customer Satisfaction We are committed to providing you with outstanding service only We look forward to working

with you

100 money back guarantee No Hassle Money Back Policy

httpaidnestcom[442018 115239 AM]

41Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 47 of 57 Page ID 1806

AIDNEST Let us help you through this national crisis

Lower your loan payments by getting in touch with one of our professionals

We design a customized repayment plan that will allow you to make payments based on your

monthly income family size and spending Get rid of the hassle of extensive paperwork and get the

help you deserve

What we can help you achieve a lower payment or lower rate

httpaidnestcom[442018 115239 AM]

42Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 48 of 57 Page ID 1807

AIDNEST Let us help you through this national crisis

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcom[442018 115239 AM]

43Exhibit E

httpaidnestcomservices[442018 115322 AM]

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 49 of 57 Page ID 1808

Services | AIDNEST Let us help you through this national crisis

INCOME BASED PAYMENTS

If you are suffering from a financial hardship you may be eligible for an

Income Based Payment In this repayment program you would have a

payment based on your income and family size The payment could be as

low as $000 per month with forgiveness at the end of 20-25 years

44

Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 50 of 57 Page ID 1809

L E ARN MORE

LOAN FORGIVENESS

If you have Federal Student Loans you may qualify for any of the student

loan forgiveness programs that are available to borrowers You may be

eligible for principal reduction loan forgiveness or a complete loan

discharge depending on your individual circumstance

L EARN MORE

PRIVATE STUDENT LOAN CONSOLIDATION

Much like refinancing a mortgage generally the biggest benefit of private

student loan consolidationstudent loan refinancing is a lower interest rate

httpaidnestcomservices[442018 115322 AM]

45Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 51 of 57 Page ID 1810

L E ARN MORE

(something federal consolidations do not offer)

STUDENT LOAN REHABILITATION

You can renew eligibility for new loans and grants and eliminate the loan

default by ldquorehabilitatingrdquo a defaulted loan

httpaidnestcomservices[442018 115322 AM]

46Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 52 of 57 Page ID 1811

CHE CK E L E G I B I L I T Y

WAGE GARNISHMENT

A wage garnishment is any legal procedure in which some portion of a

personrsquos earnings is required to be withheld by an employer for the

payment of a debt

L EARN MORE

With our fast friendly and professional services wersquoll be glad to help you get your student loans

reduced forgiven or completely discharged To this end wersquoll assist you in consolidating all your

student loans so yoursquoll have only one lender and yoursquoll start making one monthly payment Our

professionals will walk you through the best and most flexible repayment options and if itrsquos also

necessary varied deferment options and rehabilitation programs

httpaidnestcomservices[442018 115322 AM]

47Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 53 of 57 Page ID 1812

Services | AIDNEST Let us help you through this national crisis

Our CRM System

Our CRM is one of the most advanced in the industry and most importantly itrsquos linked directly to

the Department of Education (DOE) This keeps your personal and most confidential information

safe Furthermore because our CRM system is linked to the DOE our approval is 100 Through

our CRM we will be doing continuous monitoring of our process without losing sight of your

immediate needs ensuring that your case has the proper handling and most efficient process

httpaidnestcomservices[442018 115322 AM]

48Exhibit E

n

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 54 of 57 Page ID 1813

Services | AIDNEST Let us help you through this national crisis

R ECENT POSTS

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

ABOUT US

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcomservices[442018 115322 AM]

49Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 55 of 57 Page ID 1814

EXHIBIT F

s -

bullmiddot - ~ t ~ower Your Student Loan Pay~e~ts oday -- Students Helping Students Save Money

INCOME BASED PAJIIIJITPAIS

I C(gttoUC1 u~

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 56 of 57 Page ID 1815

X + C (D Not secure wwwstudoracom 0

CALL US NOW (85S) 978-S599 middot 1nfostudoracom

HOME SERVICES ABOUT US FAQ CONTACT US BLOC PRIVACY

Offering obligation and commitment free loan relief solutions

STUDENT LOAN FORGIVENESS INCOME BASED PAYMENTS LOAN CONSOLIDATION

We11 help you get your loans reduced forgiven o r Make monthly pdyments based on your affordability Get multiple Federal Student Loans consolidated into

discharged one low monthly payment

Talk to our experts concerning your

student loans

Studora is a pnvatefy owned company that helps consumers like you identify

government programs that fit your financial s1tuat1on Our loan experts will assist you in selecting the appropriate programs that WOltk with your income family size and

desired monthly payment We then prepare the appropriate documents for your review and submission All this f o r one low easy payment

Testimonials

Thank you f o r getting back to me quickly Youve been fabulous Thank you for the confirmation and for your help today Pass

during this whole process Is there a place I can go online that I this on to your sup that you were very professional and very

can leave a comment for your manager Youve made this Robert helpful and brought a sense of relief for me Thank you very

process so easy and answered every question my husband and I much and have a great rest of your day Kudos to you and your

have had teammoneywell spenL

Exhibit F 50

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 57 of 57 Page ID 1816

Services we offer

Stud ora offers document preparation services for all loan forgiveness consolidation and relief services to people who are unable to manage their finances Our mam aim is to

offer complete peace of mind to indiVidual unable to pay their student loan debt

we otter the folloWing document preparation services with complete professional assistance

amFinancial Review ffl Budget Planning

Toe first step to creating a flexible loan repayment plan is financial review we also help create a personal finance plan to ensure that you are able to

Our professmnals will look into your finances and design a custom manage your monthly budget in the most effective way This plan will keep

repayment plan that is affordable and easy to manage your spending to the minimum alloWing you to save more money for loan

repayment

Permanent Disability Forgiveness r-trTeacher Loan Forgiveness (5 You can get rid of your Federal Student Loan if you are permanently disabled Good news for teachers who are under the weight of a massiVe loan You can

now get $17 forgiven on your student loans

Public Service Loan Forgiveness Custom Debt Relief Plans

Want assistance with debt relief Get in touch with our experts who will help If you are a public service agent you can get rid of your loan after 120 days of design a loan repayment and relief plan for you based on your monthly

income and affordability payments

THERE ARE NO OBLIGATIONS OR COMMITMENTS

want to save thousands of dollars Fill out our form and get relief from your student loan for a more

peaceful tomorrow

Your Name

BiHHHi

Exhibit F 51

Attachment A

Page 14: JOSHUA S. MILLARD, BRIAN M. WELKE, pro hac vice · for which it has no legitimate claim. Noel is a Wyoming limited liability company that reported in a public document that its principal

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 14 of 57 Page ID

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1773

USC sectsect 6101-6108 in 1994 The FTC adopted the original TSR in 1995

extensively amended it in 2003 and amended certain sections thereafter 16

CFR Part 310

39 Defendants are ldquoseller[s]rdquo or ldquotelemarketer[s]rdquo engaged in

ldquotelemarketingrdquo as defined by the TSR 16 CFR sect 3102(dd) (ff) and (gg) A

ldquosellerrdquo means any person who in connection with a telemarketing transaction

provides offers to provide or arranges for others to provide goods or services to a

customer in exchange for consideration 16 CFR sect 3102(dd) A ldquotelemarketerrdquo

means any person who in connection with telemarketing initiates or receives

telephone calls to or from a customer or donor 16 CFR sect 3102(ff)

ldquoTelemarketingrdquo means a plan program or campaign which is conducted to

induce the purchase of goods or services or a charitable contribution by use of one

or more telephones and which involves more than one interstate telephone call 16

CFR sect 3102(gg)

40 Defendants are sellers or telemarketers of ldquodebt relief servicesrdquo as

defined by the TSR 16 CFR sect 3102(o) Under the TSR a ldquodebt relief servicerdquo

means any program or service represented directly or by implication to

renegotiate settle or in any way alter the terms of payment or other terms of the

debt between a person and one or more unsecured creditors or debt collectors

including but not limited to a reduction in the balance interest rate or fees owed

by a person to an unsecured creditor or debt collector 16 CFR sect 3102(o)

41 The TSR prohibits sellers and telemarketers from requesting or

receiving payment of any fees or consideration for any debt relief service until and

unless

a The seller or telemarketer has renegotiated settled reduced or

otherwise altered the terms of at least one debt pursuant to a

14

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 15 of 57 Page ID

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1774

settlement agreement debt management plan or other such

valid contractual agreement executed by the customer and

b The customer has made at least one payment pursuant to that

settlement agreement debt management plan or other valid

contractual agreement between the customer and the creditor

and

c To the extent that debts enrolled in a service are renegotiated

settled reduced or otherwise altered individually the fee or

consideration either

i Bears the same proportional relationship to the total fee

for renegotiating settling reducing or altering the terms

of the entire debt balance as the individual debt amount

bears to the entire debt amount The individual debt

amount and the entire debt amount are those owed at the

time the debt was enrolled in the service or

ii Is a percentage of the amount saved as a result of the

renegotiation settlement reduction or alteration The

percentage charged cannot change from one individual

debt to another The amount saved is the difference

between the amount owed at the time the debt was

enrolled in the service and the amount actually paid to

satisfy the debt 16 CFR sect 3104(a)(5)(i)

42 The TSR prohibits sellers and telemarketers from misrepresenting

directly or by implication any material aspect of any debt relief service including

but not limited to the amount of money or the percentage of the debt amount that a

customer may save by using the service 16 CFR sect 3103(a)(2)(x)

15

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 16 of 57 Page ID

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1775

43 Pursuant to Section 3(c) of the Telemarketing Act 15 USC

sect 6102(c) and Section 18(d)(3) of the FTC Act 15 USC sect 57a(d)(3) a violation

of the TSR constitutes an unfair or deceptive act or practice in or affecting

commerce in violation of Section 5(a) of the FTC Act 15 USC sect 45(a)

VIOLATIONS OF THE TELEMARKETING SALES RULE

Count Two

(Advance Fee for Debt Relief Services)

44 In numerous instances in connection with the telemarketing of

student loan debt relief services Defendants have requested or received payment

of a fee or consideration for debt relief services before

a Defendants have renegotiated settled reduced or otherwise

altered the terms of at least one debt pursuant to a settlement

agreement debt management plan or other such valid contractual

agreement executed by the customer and

b The customer has made at least one payment pursuant to that

settlement agreement debt management plan or other valid

contractual agreement between the customer and the creditor

45 Defendantsrsquo acts or practices as described in Paragraph 44 of this

Complaint are abusive telemarketing acts or practices that violate Section

3104(a)(5)(i) of the TSR 16 CFR sect 3104(a)(5)(i)

Count Three

(Material Debt Relief Misrepresentations)

46 In numerous instances in connection with the telemarketing of

student loan debt relief services Defendants have misrepresented directly or

indirectly expressly or by implication material aspects of their debt relief services

including but not limited to that consumers who purchase Defendantsrsquo debt relief

services will or likely will have their monthly payments reduced or their loan

16

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 17 of 57 Page ID

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1776

balances forgiven in whole or in part

47 Defendantsrsquo acts and practices as described in Paragraph 46 of this

Complaint are deceptive telemarketing acts or practices that violate Section

3103(a)(2)(x) of the TSR 16 CFR sect 3103(a)(2)(x)

Count Four

(Disgorgement of Ill-Gotten Gains of Relief Defendant)

48 Relief Defendant Noel has received directly or indirectly funds or

other assets from Defendants that are traceable to funds obtained from Defendantsrsquo

customers through the unlawful acts or practices described herein

49 Relief Defendant Noel has no legitimate claim to Defendantsrsquo

customersrsquo funds or other assets and will be unjustly enriched if it is not required to

disgorge the assets or the value of benefits received as a result of Defendantsrsquo

unlawful acts or practices

50 By reason of the foregoing Relief Defendant Noel holds funds and

assets in constructive trust for the benefit of Defendantsrsquo customers

CONSUMER INJURY

51 Consumers have suffered and will continue to suffer substantial injury

as a result of Defendantsrsquo violations of the FTC Act and the TSR In addition

Defendants have been unjustly enriched as a result of their unlawful acts or

practices Absent injunctive relief by this Court Defendants are likely to continue

to injure consumers reap unjust enrichment and harm the public interest

THIS COURTrsquoS POWER TO GRANT RELIEF

52 Section 13(b) of the FTC Act 15 USC sect 53(b) empowers this Court

to grant injunctive and such other relief as the Court may deem appropriate to halt

and redress violations of any provision of law enforced by the FTC The Court in

the exercise of its equitable jurisdiction may award ancillary relief including

rescission or reformation of contracts restitution the refund of monies paid and

17

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 18 of 57 Page ID

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1777

the disgorgement of ill-gotten monies to prevent and remedy any violation of any

provision of law enforced by the FTC

53 Section 6(b) of the Telemarketing Act 15 USC sect 6105(b)

authorizes this Court to grant such relief as the Court finds necessary to redress

injury to consumers resulting from Defendantsrsquo violations of the TSR including

the rescission or reformation of contracts and the refund of money

PRAYER FOR RELIEF

Wherefore Plaintiff FTC pursuant to Section 13(b) of the FTC Act 15

USC sect 53(b) Section 6(b) of the Telemarketing Act 15 USC sect 6105(b) and

the Courtrsquos own equitable powers requests that the Court

A Award Plaintiff such preliminary injunctive and ancillary relief as

may be necessary to avert the likelihood of consumer injury during

the pendency of this action and to preserve the possibility of effective

final relief including but not limited to temporary and preliminary

injunctions orders freezing assets immediate access to business

premises appointment of a receiver and expedited discovery

B Enter a permanent injunction to prevent future violations of the FTC

Act and the TSR

C Award such relief as the Court finds necessary to redress injury to

consumers resulting from Defendantsrsquo violations of the FTC Act and

the TSR including but not limited to rescission or reformation of

contracts restitution the refund of monies paid and the disgorgement

of ill-gotten monies

D Enter an order requiring Relief Defendant to disgorge all funds and

assets or the value of the benefit it received from the funds and assets

which are traceable to funds obtained from Defendantsrsquo customers

through the unlawful acts or practices described herein and

18

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 19 of 57 Page ID 1778

2

3

E Award Plaintiff the costs of bringing this action as well as such other

and additional relief as the Court may determine to be just and proper

Dated February 5 2019

Respectfully submitted

ALDEN F ABBOTT General Counsel

JosaSMillard Brian M Welke middot Barbara Chun (Local Counsel) Attorneys for Plaintiff FEDERAL TRADE COMMISSION

4

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19

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 20 of 57 Page ID 1779

EXHIBIT A

Attachment A

Free Assessment

Our expercs will lt1ssPss you cun ent

swclent lo n program and decermn which progr ms are

avc11l bl rn yoL11 situation We wi I help you cl11cic1e which progr m r1

help you achieve your goals Call us today

Service Guarantee We are commmecl to 11-1 111g

CllStomers get low r rc1ces ancl monthly payments and we w1I

m ke the pror~ss se mless and s r11ghtforwc1rd ou wi ll be sansf1ed

with our service ml OLlr

cornmcmem to you success Thars ow gu~ ancee

Success Rate Ou1 96 ~ surcPss r a e s 11e of he

cop I a ings tn he industry Olr

process has beer tested nd Olli

succ ss r r~ prowbull~ tn t it works

We c n ll~lp yo reduce and -1111ph y our p ~ymP1 ts Call us today

FTC-AID-1

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 21 of 57 Page ID 1780

20

Exhibit A

ABOUT US

We can help you reduce and simplify your pay1ncnts Contact one of our specialists today for

a free evaluation

111middot 1_I 1

101

t I 11111 I I

Itbull 11

Ill fl I I

bull ~ 0 I

What Makes Us Great fa1(li1-_~ tur1ent ~e11ef 11as a taf- o~middot tt a middotel elt1)rns bullJn st1ncb110

1middot1ep yriJ Tibullmiddotest fi 1e-ndly f3ce~ 113ve eirej e1tc-nsve1yr =inj ire

fanih1~1 bull11iu1 ti~e nul~nce~ cfscrvern rrent Cdid p11vate stucre11

l1J1ns Th~y viill u~e Ui5 epe tise o loik jUl fJ ycur ~Je~t

i(tres~- f)LH ~U(CtS~ ~HE 1h-~ I lSllt of i_r middotDff ancl iur

C ur ~r_(J~l 1o~w- JCl11~crs f(middotil) 3 00Vtli ~tJegy o r ~dUC2 011i

a1r1plfy yliur- - _Je1middott middotcar payr1t11s 1) Asstrnlins Itle ~atl1t1

2) R~~ear c1-1ng Our st~lff wmiddoti11 (lrJUi~oleaerick ]ll fnfcnTnati(-n befort dtmiddoteJPlr~ t tne ri~n 3) rnnk1middotgbullle i_i1 i e~ear (rr i~ ormiddot1 1 1 etc 1Ne

irvi-s t1ga~ii 111 ps~ib le a~irst 1n(t aptlbull~n 4) 1Nr1 ting VVF p1 eiv lii J 11 iUen u tt-igy IJefore vie Uke ut1c-1l i)ecius~ you d-ese11e 11) undi r~~anci

Lhe pr 1cer S) ~ev1sing Al)ng ~r 1udent Relief 1- 1otT11111tt bull) ti) ci e1H1ve ut-l-~n~-l)O c111 i ri 3 Vbulle -~11 leave n1) sti bull1e u11t111 neltl tecause middot~ve

11~1ve your be~ i1~ t~rest 1t l1ein 6) Si~tcl11ng Our note- =1nd r~c)1 ~ ~1 e thorou~ll ln(I pru1ile 1 ceJ1 po cri1~ 1)f vo111 ~1tuJticn s) iny if-oi

~xpe1 t- 01 eou pped to s~1ty1J_J bullVi r you1 c si- 7) De-gn1ng _ fe ~1 t 1nelt--1- f1ts ti 1middotV 1middotid de~ 1middot1 1 st1 iegy to fit ou 1 1_i dque jtct1in so

011 c111 i Jle y1)u1 1vv1middot1 per feet -ut1e-s ~~0 1 v

1bullVlly 1100~e At(J1n~ Sltl(ltnt Fie11e7) (i1_d aclol~Or~ bull -ii~ (1Ualiftel lci ~~~ISt~h 1noie ype-s middotif JS~iSi_ance u~211 Cd ( (11)itXS i1 jG(l1~t) to ti-tgt

p ~n~ 1not con1p n1es can 11i1p bullbullllh ve )t ~ ~qu1pptCI to bull-bullGr k 1bullv1t1middot1 r~ 11t-2 [uo emiddot 1 lc1 r1s ~~nCI cn even iner-1ne frmiddot tt1e c ~e of 1l~e

~1lt ntslmiddoturelt A1cl1rg Sudent Fie1ef 1middot cis mmiddote to )fe 11d we offe1 t with middotmiddot1eltbullbe 1es nI 3 rncney lock guMai-itee

We Have Been Featured In

FTC-AID-2

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 22 of 57 Page ID 1781

21

Exhibit A

SERVICES Wt w gtL

Loan Forgiveness Income Based Payments Loan Consol idation In some cases individuals with A period of financial hardship may You may be able to combine

Fede1middota1 Student Loans may qualify qualify you for an Income Based nultiple federal student loans into to have a portion of the amount Repayment Plan In many cases this one new loan w ith a lower more

owed may be forgiven This means means you pay nothing Unlike a affordable monthly payment Loan

your principal balnce coulcl be defe1 ment the term on your loan consolidation prngrams can l1elp

significantly reduced and you will continues to reduce while the plan is you qualify for additional programs not be expected to repay the in place Your term could reduce like loan forgiveness programs or

forgiven amount while you pay nothing Public Setvice Loan Forgiveness

a III

Private Sector Loan Forgiveness

If you work for a government

organization at a city state or

federa l level you may qualify for tle

PL1blic Service Loan Forgiveness

program To qualify your loans

must be cotisolidated into a specific

repayment plan The balance on

your federai student loans is

forgiven after 120 qualifying

bull C Permanent Disability

Forgivenness If your disability is expected to last

60 months or more you may qualify

for permanent disability forgiveness

Q1alifying for Permnent Disability

Forgiveness requires a visi t to your

doctor and individL1als enrolled in

the program are subject to three

years of post-discharge monitoring

Wage Garnishment Prevention

Federal law requires that the

Department of Education or a

gua1middotanty agency notify you before

111st1tuting wage garnishment You

have tl1e right to a hearing where

you can challenge the stated

amount owed and negotiate the

terms of the repayment scheclule

We can intervene on YOL1PflJl~1D-3

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 23 of 57 Page ID 1782

22

Exhibit A

payments have been made p1middotevent wage gampnishments

A FEW STATISTICS ABOUT STUDENT LOAN CRISIS

12 Trillion National Student Debt I he nitionil student loin debt is

now 17 trillion dollirs 1 trillion of

these are in federil student loans

Let us help you through this national

crisis Cill today for a free

evaluation

40 Million Students with Debt

In 7014 an estimated 40 million

current and former students were in

debt because of student loans If

you are one of the millions of people

struggling to pay student loans

Aiding Student Relief is here to help

$33000 Average Student Debt

The graduating class of 7014

average $33000 of student loan

debt per person Thats $3000 more

than the average in 2013 Dont be

one of the many Let Aiding Student

Relief advocate for you

Aiding Student Relief has helped cmrnllcss 1woplc reduce their student debt_ Their proven business

plan has led lo one of lhc highest s11cclSS raCs in the inltl11slly

John Standiford Associated

FTC-AID-4

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 24 of 57 Page ID 1783

23

Exhibit A

TESTIMONIALS

Til~nks to Aiding Student Rel ief Im middotI middotva ove1vvhelrnecl but Aiding The expemiddotts at l1icl i11g Student Rel ief

s1v ing $250 per month Strrd r~rt Relief expl~ inecl the were ther~ to help me when I process ancl rnacle everytl1ing cle11middot nelclecl 1t rw)s t

and sirnple

I Michael Ma 1in

Entrep e11eu1 Em iiy Jallo1 Ii Pa ul Ch is tia I1se11

Teacher Nurse

With so many programs I didnt middotconso lrclating my loans into one I love my Job but vith my high

know what was ng ht for me My monthly payment hs made life student loan payment was still

sruclent loan aclvsor walked me si1nple1 Now I can focus on 1Nhn bamiddotely getting by I don t kn ow what I

through my optio ns rnd now Imiddotn matters to me would hwe clone wthout Aiding

saving 54 I 11n1omh Stucie1middott Rel refmiddot

Ariel Hemiquez Sales co)SUltant

Stephani Seland-1 Small Busim~ss Owner

AJ 01en Museum Curator

RECENT NEWS

)lt)

o(l ttDrlTI -5

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 25 of 57 Page ID 1784

24

Exhibit A

Student Debt Crisis Business Latest Debt Collective Demands May be largely about smallest Student

borrnwers US News amp World Loan Crisis is fa frorn ove The Debt Collective is a group of Report-May 162015 last month Two new reports suggest the college students calling the Fedemiddotal Reserve Bank of New student loan crisis is easing them-se1ves the Corinthian York repor ced that stuclent loan somewhat as the economy Fifteen who are refusing to pay balances rose to 16 trillio n and improves but the crisis is far back their student loins As pa t that 113 per cent of that is in from ove the College Board of this effort the Debt Collective repo t~ tot31 borrowing fell by 8 has written an open lette to the pEbull1 cent between 2012-13 and Department of Education f l llJ 20 13-14 The organization

About Us 11 1 i~d1middot1r F th~~- h1~ ff t1middot~11middot=cl =i~=middott- 1middot __31middotmiddotIIgt middot bullmiddot11

middot- I ( )ntir il t l~i -r_il fr~~

Address bull middot tc1ltj-1r_ =i ~

middot l t1~t 1middot1 fcJ middot~_1 1 I l11 - Hbull 1 tr

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FTC-AID-6

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 26 of 57 Page ID 1785

25

Exhibit A

f - g+ in O) ~ PRIVACY POLICY

This privacy statement discloses the privacy practices for AidllII Student Relief Because Aiding Studen Relief wonts to demonstrate ts firm commlcmell to your

privacy Aiding Sudent Relief hes greed to disclose ls 1rifor111atlori g1thering and dlssem1n1t1on prct1cts Aidlns Studtrit Relief will notify you of

INFORMATION COLLECTION At-ID USE

Aiding Student Relief is the sole owner of the rformMlon collected on this site We will not sell shire or rent this information 10 others In way different from what Is

disclosed 1n this statement Aldln1 StudeM Relief collects 1nform111on throuah this site from our prospective end existing clients at several different poin on our web

site We use their contact Informii on to send information bout our company and to service exsMs accounts Users may optbullout of rece11ns future malllngs see the

cholceoptbullout section below Contect and Financial information that 1s collected Is used for verifying your name address and other informa1on as well as to boll you for

your use of our Gerv1ces using Information from third party sourcH Information about your computer hardwre and software Is automatically collected by Aiding

Student Relief and may be shared in asgregate with third parties whose services are used for traffic analysis purposes This Ir formation includes your IP address

browser type domain names access times and referring Web site addresses Ths information is no tied to personally Identifiable Information This 1nformatlor s used

by Aiding Student Relief to malMan no Improve the quality of the Hrvct and to senerae statistics resardlng use of he Aiding Student Relief site We use third party

services to bill for serlces and to provide other services like our Live Help chat We store the transcripts from these chats for customer service Improvement These

third party service providers are not permitted to use your infornon for any secondary purposes

Thank you and cheers

FTC-AID-7

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 27 of 57 Page ID 1786

26

Exhibit A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 28 of 57 Page ID 1787

EXHIBIT B

Attachment A

((

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AIDINGSTUDENTRELIEF

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27

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8

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28

Attachment A

01 $2 301 $$3 ( Exhibit B

()(

=4ABC9DEAFBD=FGFHIJKLMJNOMN MRNS mn = nrst = svzhellipu t bulltvDaggerrhellipDaggerurbullbulltuhellipv hellipz~ bullmdashldquordquolsquorsquotrade š oŒŠeuro centpound ` umluml 13 deg $ $ampdegdeg degˇ amp $$deg + -+Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 31 of 57 Page ID 1790

ISNRTUKQINKKNNKL[MRJ PUWQI]MRM qyt|tytzxy rsaquoqNfraslbdquoPUhellipsbquoLUyQhellip rfraslbhellipMNSIKVUQ QNJKvUQsMiexclQQJUx[iexcliexcl_vsect_Qyenyenbrvbarbrvbar uSSRNTPL_LUUMKIaJ_WMIJJKVIONNQJJMWRMIIbQQURKLWIIJQbKLUNKMPTMNQQ_KKRY tbullbulldaggersDaggerv~vhellipmdashryrhellip~mdashrhellipDagger ŸLŽUıQŽbłpermilMtradeœsbquoNtrade_ffRŁyISMŒUQWyNUQŠlsaquo rv45657896lt7ltgt5lt PQKLMIQSNRTUKINQVNOOMVKMWNQKLIJPMXJIKMYZMPIOO NJMOOJLURMNRRMKKLIJ klltko ltgtlt85p5gt5 ouvwxrz ^^ ~ minuspermil tffŁ yenpoundpound KNOWDaggerIreggt4lt97ltndash9ƒ Dagger hellipDaggerlsaquo žko74k57ƒ ƒISNcurrenUIWIbJKWMKJYVNTKM KLONNRqIQQSNNRTUKINQQIJ_JMWNQKLIJJJPMXJIKMcOMUJMVNQKUVK_JUKBHdefABCgDEAFBDghidjlaquopoundbrvbariexclnotvIWIQbDaggerK_WMQKbullMOIMSvOObullIbLKJbullMJMRMW ordf copy

01( $2(301$$3( Exhibit B

29

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 32 of 57 Page ID 1791

EXHIBIT C

Attachment A

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Something awesome is coming soon We are buildin somethin ve cool Sta tuned and be at1ent Your atience will be well aid

~lbullrbullUiUffl We can help you reduce and simplify your payments

101 Loan For iveness

1~u 0 (middottmiddotbullmiddotmiddot1 1~=I -- _~

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~ Income Based Pa ents

bull ~ f I - - I - I - ri u ~u-=lf ~ JU

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Exhibit C

Case 818-cv-01987-JLS

-KE

S

Docum

ent 50-1 F

iled 020519 P

age 33 of 57 P

age ID 1792

30

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 34 of 57 Page ID 1793

EXHIBIT D

Attachment A

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Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 35 of 57 Page ID 1794

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

infoaidnestcom (800) 555-1212

HOME

ABOUT US

SERVICES

FAQ

BLOG

CONTACT

HOME ABOUT US SERVICES FAQ BLOG CONTACT

1 of 6 462018 945 AM

31

Student Loan Forgiveness Loan Consolidation Student Loan Forgiveness

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 36 of 57 Page ID 1795

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

If you have Federal Student Loans yoursquore in the right place to get those loans reduced forgiven or completely discharged through our student loan forgiveness programs

Get your multiple Federal Student Loans consolidated into one forget about increasing interests and pay month to month at the lowest possible cost

We understand if yoursquore going through some hardship and thatrsquos why with us yoursquoll be able to make monthly payments based on your affordability for as low as $000 depending on your situation

2 of 6 462018 945 AM

32

Knowledge Base

Defaulted Student Loans

Wage Garnishment

Student Loan Rehabilitation

Income Based Repayment Plan

Deferment and Forbearance

Pay As You Earn Repayment Plan

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE Call 561)424-6053 today to go over your options

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 37 of 57 Page ID 1796

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

Our knowledge base is designed to provide information regarding some of the critical topics those with student loans must be aware of to be able to make educated decisions regarding their future

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

A wage garnishment is any legal procedure in which some portion of a personrsquos earnings is required to be withheld by an employer for the payment of a debt

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

With this program your payments change as your income changes and will not be longer than 25 years This is the ideal plan if you are in partial financial hardship Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard plan

Temporarily allowing you to postpone or reduce your federal student loan payments Postponing or reducing your payments may help you avoid default and future garnishments

Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard

3 of 6 462018 945 AM

33

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 38 of 57 Page ID 1797

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

4 of 6 462018 945 AM

34Attachment A

Testimonials

Latest News

Why 2016 Will Be a Big Year For Student Loans

Top Student Loan Refinancing Questions of 2015

Oba mas latest student loan plan

Things You Should Know About Public Service Loan Forgiveness

Recent Posts

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 39 of 57 Page ID 1798

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

5 of 6 462018 945 AM

35

About Us

Contact Info

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 40 of 57 Page ID 1799

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

pay-grandchild-studen

Why 2016 Will Be a Big Year For Student Loans

December 30 2015

12511110_1112367518

Top Student Loan Refinancing Questions of 2015

December 30 2015

We stand by our consultation and quote We are so sure and confident about our services and offers that they are all 100 money back guarantee risk free ndash if we donrsquot do what we promise yoursquoll get your money back

(800) 555-1212 AidnestStudenLoansgmailcom 18100 Von Karman Ave Suite 850 Irvine CA 92612

Futero SAS copy 2015 | Aidnestcom

6 of 6 462018 945

Exhibit D 36Attachment A

AM

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 41 of 57 Page ID 1800

EXHIBIT E

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 42 of 57 Page ID 1801

AIDNEST Let us help you through this national crisis

Call one of our specialists today

Forbearance amp Deferment If you are still in school and struggling to make payments on your student loans You may qualify

for Forbearance amp Deferment

Garnishment Prevention Federal law requires that the Department of Education or guarantee agency notifies you before they

begin garnishing your wages

Loan Forgiveness If you are a teacher public service worker or an individual with total and permanent disability you

httpaidnestcom[442018 115239 AM]

37Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 43 of 57 Page ID 1802

AIDNEST Let us help you through this national crisis

may qualify for this program

Consolidating Your Loans Consolidating your loans to one new loan under one lender may lower your payments and make

your life a bit more manageable

Affordable Payments If you are looking to lower your monthly payments then Income Based Repayment Plans may be

the correct choice for you

Learn more about our services

LEARN MORE

httpaidnestcom[442018 115239 AM]

38Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 44 of 57 Page ID 1803

AIDNEST Let us help you through this national crisis

Loan Forgiveness Programs Income Based Payments Student Loan Rehabilitation

Student Loan Consolidation

You may be eligible for

Loan Forgiveness Programs

In some cases individuals with Federal Student Loans may qualify to have a portion of the amount

owed to be forgiven

Get in touch with our professional team to find out which loan forgiveness program you qualify for and

how you can get rid of your unpaid student loan

L EARN MORE

httpaidnestcom[442018 115239 AM]

39Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 45 of 57 Page ID 1804

AIDNEST Let us help you through this national crisis

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE

Meet your Budget One of our advisers will help you meet your payment goals by using your budget and timeline to

determine the best plan available

httpaidnestcom[442018 115239 AM]

40Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 46 of 57 Page ID 1805

AIDNEST Let us help you through this national crisis

Simple Process We understand that lowering your payments alone can be difficult Our intuitive platform allows us

to keep the entire process simple

Customer Satisfaction We are committed to providing you with outstanding service only We look forward to working

with you

100 money back guarantee No Hassle Money Back Policy

httpaidnestcom[442018 115239 AM]

41Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 47 of 57 Page ID 1806

AIDNEST Let us help you through this national crisis

Lower your loan payments by getting in touch with one of our professionals

We design a customized repayment plan that will allow you to make payments based on your

monthly income family size and spending Get rid of the hassle of extensive paperwork and get the

help you deserve

What we can help you achieve a lower payment or lower rate

httpaidnestcom[442018 115239 AM]

42Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 48 of 57 Page ID 1807

AIDNEST Let us help you through this national crisis

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcom[442018 115239 AM]

43Exhibit E

httpaidnestcomservices[442018 115322 AM]

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 49 of 57 Page ID 1808

Services | AIDNEST Let us help you through this national crisis

INCOME BASED PAYMENTS

If you are suffering from a financial hardship you may be eligible for an

Income Based Payment In this repayment program you would have a

payment based on your income and family size The payment could be as

low as $000 per month with forgiveness at the end of 20-25 years

44

Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 50 of 57 Page ID 1809

L E ARN MORE

LOAN FORGIVENESS

If you have Federal Student Loans you may qualify for any of the student

loan forgiveness programs that are available to borrowers You may be

eligible for principal reduction loan forgiveness or a complete loan

discharge depending on your individual circumstance

L EARN MORE

PRIVATE STUDENT LOAN CONSOLIDATION

Much like refinancing a mortgage generally the biggest benefit of private

student loan consolidationstudent loan refinancing is a lower interest rate

httpaidnestcomservices[442018 115322 AM]

45Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 51 of 57 Page ID 1810

L E ARN MORE

(something federal consolidations do not offer)

STUDENT LOAN REHABILITATION

You can renew eligibility for new loans and grants and eliminate the loan

default by ldquorehabilitatingrdquo a defaulted loan

httpaidnestcomservices[442018 115322 AM]

46Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 52 of 57 Page ID 1811

CHE CK E L E G I B I L I T Y

WAGE GARNISHMENT

A wage garnishment is any legal procedure in which some portion of a

personrsquos earnings is required to be withheld by an employer for the

payment of a debt

L EARN MORE

With our fast friendly and professional services wersquoll be glad to help you get your student loans

reduced forgiven or completely discharged To this end wersquoll assist you in consolidating all your

student loans so yoursquoll have only one lender and yoursquoll start making one monthly payment Our

professionals will walk you through the best and most flexible repayment options and if itrsquos also

necessary varied deferment options and rehabilitation programs

httpaidnestcomservices[442018 115322 AM]

47Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 53 of 57 Page ID 1812

Services | AIDNEST Let us help you through this national crisis

Our CRM System

Our CRM is one of the most advanced in the industry and most importantly itrsquos linked directly to

the Department of Education (DOE) This keeps your personal and most confidential information

safe Furthermore because our CRM system is linked to the DOE our approval is 100 Through

our CRM we will be doing continuous monitoring of our process without losing sight of your

immediate needs ensuring that your case has the proper handling and most efficient process

httpaidnestcomservices[442018 115322 AM]

48Exhibit E

n

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 54 of 57 Page ID 1813

Services | AIDNEST Let us help you through this national crisis

R ECENT POSTS

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

ABOUT US

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcomservices[442018 115322 AM]

49Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 55 of 57 Page ID 1814

EXHIBIT F

s -

bullmiddot - ~ t ~ower Your Student Loan Pay~e~ts oday -- Students Helping Students Save Money

INCOME BASED PAJIIIJITPAIS

I C(gttoUC1 u~

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 56 of 57 Page ID 1815

X + C (D Not secure wwwstudoracom 0

CALL US NOW (85S) 978-S599 middot 1nfostudoracom

HOME SERVICES ABOUT US FAQ CONTACT US BLOC PRIVACY

Offering obligation and commitment free loan relief solutions

STUDENT LOAN FORGIVENESS INCOME BASED PAYMENTS LOAN CONSOLIDATION

We11 help you get your loans reduced forgiven o r Make monthly pdyments based on your affordability Get multiple Federal Student Loans consolidated into

discharged one low monthly payment

Talk to our experts concerning your

student loans

Studora is a pnvatefy owned company that helps consumers like you identify

government programs that fit your financial s1tuat1on Our loan experts will assist you in selecting the appropriate programs that WOltk with your income family size and

desired monthly payment We then prepare the appropriate documents for your review and submission All this f o r one low easy payment

Testimonials

Thank you f o r getting back to me quickly Youve been fabulous Thank you for the confirmation and for your help today Pass

during this whole process Is there a place I can go online that I this on to your sup that you were very professional and very

can leave a comment for your manager Youve made this Robert helpful and brought a sense of relief for me Thank you very

process so easy and answered every question my husband and I much and have a great rest of your day Kudos to you and your

have had teammoneywell spenL

Exhibit F 50

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 57 of 57 Page ID 1816

Services we offer

Stud ora offers document preparation services for all loan forgiveness consolidation and relief services to people who are unable to manage their finances Our mam aim is to

offer complete peace of mind to indiVidual unable to pay their student loan debt

we otter the folloWing document preparation services with complete professional assistance

amFinancial Review ffl Budget Planning

Toe first step to creating a flexible loan repayment plan is financial review we also help create a personal finance plan to ensure that you are able to

Our professmnals will look into your finances and design a custom manage your monthly budget in the most effective way This plan will keep

repayment plan that is affordable and easy to manage your spending to the minimum alloWing you to save more money for loan

repayment

Permanent Disability Forgiveness r-trTeacher Loan Forgiveness (5 You can get rid of your Federal Student Loan if you are permanently disabled Good news for teachers who are under the weight of a massiVe loan You can

now get $17 forgiven on your student loans

Public Service Loan Forgiveness Custom Debt Relief Plans

Want assistance with debt relief Get in touch with our experts who will help If you are a public service agent you can get rid of your loan after 120 days of design a loan repayment and relief plan for you based on your monthly

income and affordability payments

THERE ARE NO OBLIGATIONS OR COMMITMENTS

want to save thousands of dollars Fill out our form and get relief from your student loan for a more

peaceful tomorrow

Your Name

BiHHHi

Exhibit F 51

Attachment A

Page 15: JOSHUA S. MILLARD, BRIAN M. WELKE, pro hac vice · for which it has no legitimate claim. Noel is a Wyoming limited liability company that reported in a public document that its principal

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 15 of 57 Page ID

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1774

settlement agreement debt management plan or other such

valid contractual agreement executed by the customer and

b The customer has made at least one payment pursuant to that

settlement agreement debt management plan or other valid

contractual agreement between the customer and the creditor

and

c To the extent that debts enrolled in a service are renegotiated

settled reduced or otherwise altered individually the fee or

consideration either

i Bears the same proportional relationship to the total fee

for renegotiating settling reducing or altering the terms

of the entire debt balance as the individual debt amount

bears to the entire debt amount The individual debt

amount and the entire debt amount are those owed at the

time the debt was enrolled in the service or

ii Is a percentage of the amount saved as a result of the

renegotiation settlement reduction or alteration The

percentage charged cannot change from one individual

debt to another The amount saved is the difference

between the amount owed at the time the debt was

enrolled in the service and the amount actually paid to

satisfy the debt 16 CFR sect 3104(a)(5)(i)

42 The TSR prohibits sellers and telemarketers from misrepresenting

directly or by implication any material aspect of any debt relief service including

but not limited to the amount of money or the percentage of the debt amount that a

customer may save by using the service 16 CFR sect 3103(a)(2)(x)

15

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 16 of 57 Page ID

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43 Pursuant to Section 3(c) of the Telemarketing Act 15 USC

sect 6102(c) and Section 18(d)(3) of the FTC Act 15 USC sect 57a(d)(3) a violation

of the TSR constitutes an unfair or deceptive act or practice in or affecting

commerce in violation of Section 5(a) of the FTC Act 15 USC sect 45(a)

VIOLATIONS OF THE TELEMARKETING SALES RULE

Count Two

(Advance Fee for Debt Relief Services)

44 In numerous instances in connection with the telemarketing of

student loan debt relief services Defendants have requested or received payment

of a fee or consideration for debt relief services before

a Defendants have renegotiated settled reduced or otherwise

altered the terms of at least one debt pursuant to a settlement

agreement debt management plan or other such valid contractual

agreement executed by the customer and

b The customer has made at least one payment pursuant to that

settlement agreement debt management plan or other valid

contractual agreement between the customer and the creditor

45 Defendantsrsquo acts or practices as described in Paragraph 44 of this

Complaint are abusive telemarketing acts or practices that violate Section

3104(a)(5)(i) of the TSR 16 CFR sect 3104(a)(5)(i)

Count Three

(Material Debt Relief Misrepresentations)

46 In numerous instances in connection with the telemarketing of

student loan debt relief services Defendants have misrepresented directly or

indirectly expressly or by implication material aspects of their debt relief services

including but not limited to that consumers who purchase Defendantsrsquo debt relief

services will or likely will have their monthly payments reduced or their loan

16

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 17 of 57 Page ID

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1776

balances forgiven in whole or in part

47 Defendantsrsquo acts and practices as described in Paragraph 46 of this

Complaint are deceptive telemarketing acts or practices that violate Section

3103(a)(2)(x) of the TSR 16 CFR sect 3103(a)(2)(x)

Count Four

(Disgorgement of Ill-Gotten Gains of Relief Defendant)

48 Relief Defendant Noel has received directly or indirectly funds or

other assets from Defendants that are traceable to funds obtained from Defendantsrsquo

customers through the unlawful acts or practices described herein

49 Relief Defendant Noel has no legitimate claim to Defendantsrsquo

customersrsquo funds or other assets and will be unjustly enriched if it is not required to

disgorge the assets or the value of benefits received as a result of Defendantsrsquo

unlawful acts or practices

50 By reason of the foregoing Relief Defendant Noel holds funds and

assets in constructive trust for the benefit of Defendantsrsquo customers

CONSUMER INJURY

51 Consumers have suffered and will continue to suffer substantial injury

as a result of Defendantsrsquo violations of the FTC Act and the TSR In addition

Defendants have been unjustly enriched as a result of their unlawful acts or

practices Absent injunctive relief by this Court Defendants are likely to continue

to injure consumers reap unjust enrichment and harm the public interest

THIS COURTrsquoS POWER TO GRANT RELIEF

52 Section 13(b) of the FTC Act 15 USC sect 53(b) empowers this Court

to grant injunctive and such other relief as the Court may deem appropriate to halt

and redress violations of any provision of law enforced by the FTC The Court in

the exercise of its equitable jurisdiction may award ancillary relief including

rescission or reformation of contracts restitution the refund of monies paid and

17

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 18 of 57 Page ID

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1777

the disgorgement of ill-gotten monies to prevent and remedy any violation of any

provision of law enforced by the FTC

53 Section 6(b) of the Telemarketing Act 15 USC sect 6105(b)

authorizes this Court to grant such relief as the Court finds necessary to redress

injury to consumers resulting from Defendantsrsquo violations of the TSR including

the rescission or reformation of contracts and the refund of money

PRAYER FOR RELIEF

Wherefore Plaintiff FTC pursuant to Section 13(b) of the FTC Act 15

USC sect 53(b) Section 6(b) of the Telemarketing Act 15 USC sect 6105(b) and

the Courtrsquos own equitable powers requests that the Court

A Award Plaintiff such preliminary injunctive and ancillary relief as

may be necessary to avert the likelihood of consumer injury during

the pendency of this action and to preserve the possibility of effective

final relief including but not limited to temporary and preliminary

injunctions orders freezing assets immediate access to business

premises appointment of a receiver and expedited discovery

B Enter a permanent injunction to prevent future violations of the FTC

Act and the TSR

C Award such relief as the Court finds necessary to redress injury to

consumers resulting from Defendantsrsquo violations of the FTC Act and

the TSR including but not limited to rescission or reformation of

contracts restitution the refund of monies paid and the disgorgement

of ill-gotten monies

D Enter an order requiring Relief Defendant to disgorge all funds and

assets or the value of the benefit it received from the funds and assets

which are traceable to funds obtained from Defendantsrsquo customers

through the unlawful acts or practices described herein and

18

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 19 of 57 Page ID 1778

2

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E Award Plaintiff the costs of bringing this action as well as such other

and additional relief as the Court may determine to be just and proper

Dated February 5 2019

Respectfully submitted

ALDEN F ABBOTT General Counsel

JosaSMillard Brian M Welke middot Barbara Chun (Local Counsel) Attorneys for Plaintiff FEDERAL TRADE COMMISSION

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Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 20 of 57 Page ID 1779

EXHIBIT A

Attachment A

Free Assessment

Our expercs will lt1ssPss you cun ent

swclent lo n program and decermn which progr ms are

avc11l bl rn yoL11 situation We wi I help you cl11cic1e which progr m r1

help you achieve your goals Call us today

Service Guarantee We are commmecl to 11-1 111g

CllStomers get low r rc1ces ancl monthly payments and we w1I

m ke the pror~ss se mless and s r11ghtforwc1rd ou wi ll be sansf1ed

with our service ml OLlr

cornmcmem to you success Thars ow gu~ ancee

Success Rate Ou1 96 ~ surcPss r a e s 11e of he

cop I a ings tn he industry Olr

process has beer tested nd Olli

succ ss r r~ prowbull~ tn t it works

We c n ll~lp yo reduce and -1111ph y our p ~ymP1 ts Call us today

FTC-AID-1

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 21 of 57 Page ID 1780

20

Exhibit A

ABOUT US

We can help you reduce and simplify your pay1ncnts Contact one of our specialists today for

a free evaluation

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What Makes Us Great fa1(li1-_~ tur1ent ~e11ef 11as a taf- o~middot tt a middotel elt1)rns bullJn st1ncb110

1middot1ep yriJ Tibullmiddotest fi 1e-ndly f3ce~ 113ve eirej e1tc-nsve1yr =inj ire

fanih1~1 bull11iu1 ti~e nul~nce~ cfscrvern rrent Cdid p11vate stucre11

l1J1ns Th~y viill u~e Ui5 epe tise o loik jUl fJ ycur ~Je~t

i(tres~- f)LH ~U(CtS~ ~HE 1h-~ I lSllt of i_r middotDff ancl iur

C ur ~r_(J~l 1o~w- JCl11~crs f(middotil) 3 00Vtli ~tJegy o r ~dUC2 011i

a1r1plfy yliur- - _Je1middott middotcar payr1t11s 1) Asstrnlins Itle ~atl1t1

2) R~~ear c1-1ng Our st~lff wmiddoti11 (lrJUi~oleaerick ]ll fnfcnTnati(-n befort dtmiddoteJPlr~ t tne ri~n 3) rnnk1middotgbullle i_i1 i e~ear (rr i~ ormiddot1 1 1 etc 1Ne

irvi-s t1ga~ii 111 ps~ib le a~irst 1n(t aptlbull~n 4) 1Nr1 ting VVF p1 eiv lii J 11 iUen u tt-igy IJefore vie Uke ut1c-1l i)ecius~ you d-ese11e 11) undi r~~anci

Lhe pr 1cer S) ~ev1sing Al)ng ~r 1udent Relief 1- 1otT11111tt bull) ti) ci e1H1ve ut-l-~n~-l)O c111 i ri 3 Vbulle -~11 leave n1) sti bull1e u11t111 neltl tecause middot~ve

11~1ve your be~ i1~ t~rest 1t l1ein 6) Si~tcl11ng Our note- =1nd r~c)1 ~ ~1 e thorou~ll ln(I pru1ile 1 ceJ1 po cri1~ 1)f vo111 ~1tuJticn s) iny if-oi

~xpe1 t- 01 eou pped to s~1ty1J_J bullVi r you1 c si- 7) De-gn1ng _ fe ~1 t 1nelt--1- f1ts ti 1middotV 1middotid de~ 1middot1 1 st1 iegy to fit ou 1 1_i dque jtct1in so

011 c111 i Jle y1)u1 1vv1middot1 per feet -ut1e-s ~~0 1 v

1bullVlly 1100~e At(J1n~ Sltl(ltnt Fie11e7) (i1_d aclol~Or~ bull -ii~ (1Ualiftel lci ~~~ISt~h 1noie ype-s middotif JS~iSi_ance u~211 Cd ( (11)itXS i1 jG(l1~t) to ti-tgt

p ~n~ 1not con1p n1es can 11i1p bullbullllh ve )t ~ ~qu1pptCI to bull-bullGr k 1bullv1t1middot1 r~ 11t-2 [uo emiddot 1 lc1 r1s ~~nCI cn even iner-1ne frmiddot tt1e c ~e of 1l~e

~1lt ntslmiddoturelt A1cl1rg Sudent Fie1ef 1middot cis mmiddote to )fe 11d we offe1 t with middotmiddot1eltbullbe 1es nI 3 rncney lock guMai-itee

We Have Been Featured In

FTC-AID-2

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 22 of 57 Page ID 1781

21

Exhibit A

SERVICES Wt w gtL

Loan Forgiveness Income Based Payments Loan Consol idation In some cases individuals with A period of financial hardship may You may be able to combine

Fede1middota1 Student Loans may qualify qualify you for an Income Based nultiple federal student loans into to have a portion of the amount Repayment Plan In many cases this one new loan w ith a lower more

owed may be forgiven This means means you pay nothing Unlike a affordable monthly payment Loan

your principal balnce coulcl be defe1 ment the term on your loan consolidation prngrams can l1elp

significantly reduced and you will continues to reduce while the plan is you qualify for additional programs not be expected to repay the in place Your term could reduce like loan forgiveness programs or

forgiven amount while you pay nothing Public Setvice Loan Forgiveness

a III

Private Sector Loan Forgiveness

If you work for a government

organization at a city state or

federa l level you may qualify for tle

PL1blic Service Loan Forgiveness

program To qualify your loans

must be cotisolidated into a specific

repayment plan The balance on

your federai student loans is

forgiven after 120 qualifying

bull C Permanent Disability

Forgivenness If your disability is expected to last

60 months or more you may qualify

for permanent disability forgiveness

Q1alifying for Permnent Disability

Forgiveness requires a visi t to your

doctor and individL1als enrolled in

the program are subject to three

years of post-discharge monitoring

Wage Garnishment Prevention

Federal law requires that the

Department of Education or a

gua1middotanty agency notify you before

111st1tuting wage garnishment You

have tl1e right to a hearing where

you can challenge the stated

amount owed and negotiate the

terms of the repayment scheclule

We can intervene on YOL1PflJl~1D-3

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 23 of 57 Page ID 1782

22

Exhibit A

payments have been made p1middotevent wage gampnishments

A FEW STATISTICS ABOUT STUDENT LOAN CRISIS

12 Trillion National Student Debt I he nitionil student loin debt is

now 17 trillion dollirs 1 trillion of

these are in federil student loans

Let us help you through this national

crisis Cill today for a free

evaluation

40 Million Students with Debt

In 7014 an estimated 40 million

current and former students were in

debt because of student loans If

you are one of the millions of people

struggling to pay student loans

Aiding Student Relief is here to help

$33000 Average Student Debt

The graduating class of 7014

average $33000 of student loan

debt per person Thats $3000 more

than the average in 2013 Dont be

one of the many Let Aiding Student

Relief advocate for you

Aiding Student Relief has helped cmrnllcss 1woplc reduce their student debt_ Their proven business

plan has led lo one of lhc highest s11cclSS raCs in the inltl11slly

John Standiford Associated

FTC-AID-4

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 24 of 57 Page ID 1783

23

Exhibit A

TESTIMONIALS

Til~nks to Aiding Student Rel ief Im middotI middotva ove1vvhelrnecl but Aiding The expemiddotts at l1icl i11g Student Rel ief

s1v ing $250 per month Strrd r~rt Relief expl~ inecl the were ther~ to help me when I process ancl rnacle everytl1ing cle11middot nelclecl 1t rw)s t

and sirnple

I Michael Ma 1in

Entrep e11eu1 Em iiy Jallo1 Ii Pa ul Ch is tia I1se11

Teacher Nurse

With so many programs I didnt middotconso lrclating my loans into one I love my Job but vith my high

know what was ng ht for me My monthly payment hs made life student loan payment was still

sruclent loan aclvsor walked me si1nple1 Now I can focus on 1Nhn bamiddotely getting by I don t kn ow what I

through my optio ns rnd now Imiddotn matters to me would hwe clone wthout Aiding

saving 54 I 11n1omh Stucie1middott Rel refmiddot

Ariel Hemiquez Sales co)SUltant

Stephani Seland-1 Small Busim~ss Owner

AJ 01en Museum Curator

RECENT NEWS

)lt)

o(l ttDrlTI -5

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 25 of 57 Page ID 1784

24

Exhibit A

Student Debt Crisis Business Latest Debt Collective Demands May be largely about smallest Student

borrnwers US News amp World Loan Crisis is fa frorn ove The Debt Collective is a group of Report-May 162015 last month Two new reports suggest the college students calling the Fedemiddotal Reserve Bank of New student loan crisis is easing them-se1ves the Corinthian York repor ced that stuclent loan somewhat as the economy Fifteen who are refusing to pay balances rose to 16 trillio n and improves but the crisis is far back their student loins As pa t that 113 per cent of that is in from ove the College Board of this effort the Debt Collective repo t~ tot31 borrowing fell by 8 has written an open lette to the pEbull1 cent between 2012-13 and Department of Education f l llJ 20 13-14 The organization

About Us 11 1 i~d1middot1r F th~~- h1~ ff t1middot~11middot=cl =i~=middott- 1middot __31middotmiddotIIgt middot bullmiddot11

middot- I ( )ntir il t l~i -r_il fr~~

Address bull middot tc1ltj-1r_ =i ~

middot l t1~t 1middot1 fcJ middot~_1 1 I l11 - Hbull 1 tr

~t (~~ 1 12bull~11 T 1 1- - 8555105400

FTC-AID-6

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 26 of 57 Page ID 1785

25

Exhibit A

f - g+ in O) ~ PRIVACY POLICY

This privacy statement discloses the privacy practices for AidllII Student Relief Because Aiding Studen Relief wonts to demonstrate ts firm commlcmell to your

privacy Aiding Sudent Relief hes greed to disclose ls 1rifor111atlori g1thering and dlssem1n1t1on prct1cts Aidlns Studtrit Relief will notify you of

INFORMATION COLLECTION At-ID USE

Aiding Student Relief is the sole owner of the rformMlon collected on this site We will not sell shire or rent this information 10 others In way different from what Is

disclosed 1n this statement Aldln1 StudeM Relief collects 1nform111on throuah this site from our prospective end existing clients at several different poin on our web

site We use their contact Informii on to send information bout our company and to service exsMs accounts Users may optbullout of rece11ns future malllngs see the

cholceoptbullout section below Contect and Financial information that 1s collected Is used for verifying your name address and other informa1on as well as to boll you for

your use of our Gerv1ces using Information from third party sourcH Information about your computer hardwre and software Is automatically collected by Aiding

Student Relief and may be shared in asgregate with third parties whose services are used for traffic analysis purposes This Ir formation includes your IP address

browser type domain names access times and referring Web site addresses Ths information is no tied to personally Identifiable Information This 1nformatlor s used

by Aiding Student Relief to malMan no Improve the quality of the Hrvct and to senerae statistics resardlng use of he Aiding Student Relief site We use third party

services to bill for serlces and to provide other services like our Live Help chat We store the transcripts from these chats for customer service Improvement These

third party service providers are not permitted to use your infornon for any secondary purposes

Thank you and cheers

FTC-AID-7

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 27 of 57 Page ID 1786

26

Exhibit A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 28 of 57 Page ID 1787

EXHIBIT B

Attachment A

((

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AIDINGSTUDENTRELIEF

bull bull bull bull bull

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rsaquominus MZ|PUpermilSWUzSOUZXWbdquoDaggerUxYP~PNZSZ|YSRSx~WRYDaggerSOVQSYNOOPQNPxSZMZ|PUpermilSWU~rdquoUDaggerSOUZXzSZmdashMZSZO|SWUWXRYWUSZWOPQDaggerSOZPXRYZymdash zQhellipY|daggerUxTY|UvPSZwPxyYTUZUWWMNOPQbullPxlsquoNPxSyPTUxZUZXPxySZYrsquoSXYPZSXS|YXOWXSXUPxNU~UxSUTUOPQSOVQSYNONPxXRUzQhellipY|daggerUxTY|UvPSZwPxyYTUZUWWDaggerxPyxSmdashsbquotrade f8Ef8E78FCB6C8EŁPQSOhellipUShellipUXP|PhellipYZUQXYDaggerUNU~UxSWXQ~UZXPSZWYZXPPZUZUbullPSZbullYXRSPbullUxPxUSŒPx~ShellipUPZXRODaggerSOUZXmdashvPSZ|PZWPY~SXYPZDaggerxPyxSW|SZRUDaggerOPQVQSYNONPxS~~YXYPZSDaggerxPyxSW YlsquoU PSZ NPxyYTUZUWWDaggerxPyxSWPxzQhellipY|daggerUxTY|UvPSZwPxyYTUZUWWmdash ŠmŸŽıłŠm 57gt8A57A5B= 8E65C76B5E6F8EB5=6G

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28

Attachment A

01 $2 301 $$3 ( Exhibit B

()(

=4ABC9DEAFBD=FGFHIJKLMJNOMN MRNS mn = nrst = svzhellipu t bulltvDaggerrhellipDaggerurbullbulltuhellipv hellipz~ bullmdashldquordquolsquorsquotrade š oŒŠeuro centpound ` umluml 13 deg $ $ampdegdeg degˇ amp $$deg + -+Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 31 of 57 Page ID 1790

ISNRTUKQINKKNNKL[MRJ PUWQI]MRM qyt|tytzxy rsaquoqNfraslbdquoPUhellipsbquoLUyQhellip rfraslbhellipMNSIKVUQ QNJKvUQsMiexclQQJUx[iexcliexcl_vsect_Qyenyenbrvbarbrvbar uSSRNTPL_LUUMKIaJ_WMIJJKVIONNQJJMWRMIIbQQURKLWIIJQbKLUNKMPTMNQQ_KKRY tbullbulldaggersDaggerv~vhellipmdashryrhellip~mdashrhellipDagger ŸLŽUıQŽbłpermilMtradeœsbquoNtrade_ffRŁyISMŒUQWyNUQŠlsaquo rv45657896lt7ltgt5lt PQKLMIQSNRTUKINQVNOOMVKMWNQKLIJPMXJIKMYZMPIOO NJMOOJLURMNRRMKKLIJ klltko ltgtlt85p5gt5 ouvwxrz ^^ ~ minuspermil tffŁ yenpoundpound KNOWDaggerIreggt4lt97ltndash9ƒ Dagger hellipDaggerlsaquo žko74k57ƒ ƒISNcurrenUIWIbJKWMKJYVNTKM KLONNRqIQQSNNRTUKINQQIJ_JMWNQKLIJJJPMXJIKMcOMUJMVNQKUVK_JUKBHdefABCgDEAFBDghidjlaquopoundbrvbariexclnotvIWIQbDaggerK_WMQKbullMOIMSvOObullIbLKJbullMJMRMW ordf copy

01( $2(301$$3( Exhibit B

29

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 32 of 57 Page ID 1791

EXHIBIT C

Attachment A

~ 111 ~tampi 10 11 ~bull ia1111

Something awesome is coming soon We are buildin somethin ve cool Sta tuned and be at1ent Your atience will be well aid

~lbullrbullUiUffl We can help you reduce and simplify your payments

101 Loan For iveness

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Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 34 of 57 Page ID 1793

EXHIBIT D

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Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 35 of 57 Page ID 1794

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

infoaidnestcom (800) 555-1212

HOME

ABOUT US

SERVICES

FAQ

BLOG

CONTACT

HOME ABOUT US SERVICES FAQ BLOG CONTACT

1 of 6 462018 945 AM

31

Student Loan Forgiveness Loan Consolidation Student Loan Forgiveness

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 36 of 57 Page ID 1795

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

If you have Federal Student Loans yoursquore in the right place to get those loans reduced forgiven or completely discharged through our student loan forgiveness programs

Get your multiple Federal Student Loans consolidated into one forget about increasing interests and pay month to month at the lowest possible cost

We understand if yoursquore going through some hardship and thatrsquos why with us yoursquoll be able to make monthly payments based on your affordability for as low as $000 depending on your situation

2 of 6 462018 945 AM

32

Knowledge Base

Defaulted Student Loans

Wage Garnishment

Student Loan Rehabilitation

Income Based Repayment Plan

Deferment and Forbearance

Pay As You Earn Repayment Plan

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE Call 561)424-6053 today to go over your options

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 37 of 57 Page ID 1796

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

Our knowledge base is designed to provide information regarding some of the critical topics those with student loans must be aware of to be able to make educated decisions regarding their future

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

A wage garnishment is any legal procedure in which some portion of a personrsquos earnings is required to be withheld by an employer for the payment of a debt

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

With this program your payments change as your income changes and will not be longer than 25 years This is the ideal plan if you are in partial financial hardship Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard plan

Temporarily allowing you to postpone or reduce your federal student loan payments Postponing or reducing your payments may help you avoid default and future garnishments

Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard

3 of 6 462018 945 AM

33

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 38 of 57 Page ID 1797

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

4 of 6 462018 945 AM

34Attachment A

Testimonials

Latest News

Why 2016 Will Be a Big Year For Student Loans

Top Student Loan Refinancing Questions of 2015

Oba mas latest student loan plan

Things You Should Know About Public Service Loan Forgiveness

Recent Posts

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 39 of 57 Page ID 1798

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

5 of 6 462018 945 AM

35

About Us

Contact Info

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 40 of 57 Page ID 1799

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

pay-grandchild-studen

Why 2016 Will Be a Big Year For Student Loans

December 30 2015

12511110_1112367518

Top Student Loan Refinancing Questions of 2015

December 30 2015

We stand by our consultation and quote We are so sure and confident about our services and offers that they are all 100 money back guarantee risk free ndash if we donrsquot do what we promise yoursquoll get your money back

(800) 555-1212 AidnestStudenLoansgmailcom 18100 Von Karman Ave Suite 850 Irvine CA 92612

Futero SAS copy 2015 | Aidnestcom

6 of 6 462018 945

Exhibit D 36Attachment A

AM

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 41 of 57 Page ID 1800

EXHIBIT E

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 42 of 57 Page ID 1801

AIDNEST Let us help you through this national crisis

Call one of our specialists today

Forbearance amp Deferment If you are still in school and struggling to make payments on your student loans You may qualify

for Forbearance amp Deferment

Garnishment Prevention Federal law requires that the Department of Education or guarantee agency notifies you before they

begin garnishing your wages

Loan Forgiveness If you are a teacher public service worker or an individual with total and permanent disability you

httpaidnestcom[442018 115239 AM]

37Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 43 of 57 Page ID 1802

AIDNEST Let us help you through this national crisis

may qualify for this program

Consolidating Your Loans Consolidating your loans to one new loan under one lender may lower your payments and make

your life a bit more manageable

Affordable Payments If you are looking to lower your monthly payments then Income Based Repayment Plans may be

the correct choice for you

Learn more about our services

LEARN MORE

httpaidnestcom[442018 115239 AM]

38Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 44 of 57 Page ID 1803

AIDNEST Let us help you through this national crisis

Loan Forgiveness Programs Income Based Payments Student Loan Rehabilitation

Student Loan Consolidation

You may be eligible for

Loan Forgiveness Programs

In some cases individuals with Federal Student Loans may qualify to have a portion of the amount

owed to be forgiven

Get in touch with our professional team to find out which loan forgiveness program you qualify for and

how you can get rid of your unpaid student loan

L EARN MORE

httpaidnestcom[442018 115239 AM]

39Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 45 of 57 Page ID 1804

AIDNEST Let us help you through this national crisis

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE

Meet your Budget One of our advisers will help you meet your payment goals by using your budget and timeline to

determine the best plan available

httpaidnestcom[442018 115239 AM]

40Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 46 of 57 Page ID 1805

AIDNEST Let us help you through this national crisis

Simple Process We understand that lowering your payments alone can be difficult Our intuitive platform allows us

to keep the entire process simple

Customer Satisfaction We are committed to providing you with outstanding service only We look forward to working

with you

100 money back guarantee No Hassle Money Back Policy

httpaidnestcom[442018 115239 AM]

41Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 47 of 57 Page ID 1806

AIDNEST Let us help you through this national crisis

Lower your loan payments by getting in touch with one of our professionals

We design a customized repayment plan that will allow you to make payments based on your

monthly income family size and spending Get rid of the hassle of extensive paperwork and get the

help you deserve

What we can help you achieve a lower payment or lower rate

httpaidnestcom[442018 115239 AM]

42Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 48 of 57 Page ID 1807

AIDNEST Let us help you through this national crisis

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcom[442018 115239 AM]

43Exhibit E

httpaidnestcomservices[442018 115322 AM]

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 49 of 57 Page ID 1808

Services | AIDNEST Let us help you through this national crisis

INCOME BASED PAYMENTS

If you are suffering from a financial hardship you may be eligible for an

Income Based Payment In this repayment program you would have a

payment based on your income and family size The payment could be as

low as $000 per month with forgiveness at the end of 20-25 years

44

Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 50 of 57 Page ID 1809

L E ARN MORE

LOAN FORGIVENESS

If you have Federal Student Loans you may qualify for any of the student

loan forgiveness programs that are available to borrowers You may be

eligible for principal reduction loan forgiveness or a complete loan

discharge depending on your individual circumstance

L EARN MORE

PRIVATE STUDENT LOAN CONSOLIDATION

Much like refinancing a mortgage generally the biggest benefit of private

student loan consolidationstudent loan refinancing is a lower interest rate

httpaidnestcomservices[442018 115322 AM]

45Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 51 of 57 Page ID 1810

L E ARN MORE

(something federal consolidations do not offer)

STUDENT LOAN REHABILITATION

You can renew eligibility for new loans and grants and eliminate the loan

default by ldquorehabilitatingrdquo a defaulted loan

httpaidnestcomservices[442018 115322 AM]

46Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 52 of 57 Page ID 1811

CHE CK E L E G I B I L I T Y

WAGE GARNISHMENT

A wage garnishment is any legal procedure in which some portion of a

personrsquos earnings is required to be withheld by an employer for the

payment of a debt

L EARN MORE

With our fast friendly and professional services wersquoll be glad to help you get your student loans

reduced forgiven or completely discharged To this end wersquoll assist you in consolidating all your

student loans so yoursquoll have only one lender and yoursquoll start making one monthly payment Our

professionals will walk you through the best and most flexible repayment options and if itrsquos also

necessary varied deferment options and rehabilitation programs

httpaidnestcomservices[442018 115322 AM]

47Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 53 of 57 Page ID 1812

Services | AIDNEST Let us help you through this national crisis

Our CRM System

Our CRM is one of the most advanced in the industry and most importantly itrsquos linked directly to

the Department of Education (DOE) This keeps your personal and most confidential information

safe Furthermore because our CRM system is linked to the DOE our approval is 100 Through

our CRM we will be doing continuous monitoring of our process without losing sight of your

immediate needs ensuring that your case has the proper handling and most efficient process

httpaidnestcomservices[442018 115322 AM]

48Exhibit E

n

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 54 of 57 Page ID 1813

Services | AIDNEST Let us help you through this national crisis

R ECENT POSTS

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

ABOUT US

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcomservices[442018 115322 AM]

49Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 55 of 57 Page ID 1814

EXHIBIT F

s -

bullmiddot - ~ t ~ower Your Student Loan Pay~e~ts oday -- Students Helping Students Save Money

INCOME BASED PAJIIIJITPAIS

I C(gttoUC1 u~

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 56 of 57 Page ID 1815

X + C (D Not secure wwwstudoracom 0

CALL US NOW (85S) 978-S599 middot 1nfostudoracom

HOME SERVICES ABOUT US FAQ CONTACT US BLOC PRIVACY

Offering obligation and commitment free loan relief solutions

STUDENT LOAN FORGIVENESS INCOME BASED PAYMENTS LOAN CONSOLIDATION

We11 help you get your loans reduced forgiven o r Make monthly pdyments based on your affordability Get multiple Federal Student Loans consolidated into

discharged one low monthly payment

Talk to our experts concerning your

student loans

Studora is a pnvatefy owned company that helps consumers like you identify

government programs that fit your financial s1tuat1on Our loan experts will assist you in selecting the appropriate programs that WOltk with your income family size and

desired monthly payment We then prepare the appropriate documents for your review and submission All this f o r one low easy payment

Testimonials

Thank you f o r getting back to me quickly Youve been fabulous Thank you for the confirmation and for your help today Pass

during this whole process Is there a place I can go online that I this on to your sup that you were very professional and very

can leave a comment for your manager Youve made this Robert helpful and brought a sense of relief for me Thank you very

process so easy and answered every question my husband and I much and have a great rest of your day Kudos to you and your

have had teammoneywell spenL

Exhibit F 50

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 57 of 57 Page ID 1816

Services we offer

Stud ora offers document preparation services for all loan forgiveness consolidation and relief services to people who are unable to manage their finances Our mam aim is to

offer complete peace of mind to indiVidual unable to pay their student loan debt

we otter the folloWing document preparation services with complete professional assistance

amFinancial Review ffl Budget Planning

Toe first step to creating a flexible loan repayment plan is financial review we also help create a personal finance plan to ensure that you are able to

Our professmnals will look into your finances and design a custom manage your monthly budget in the most effective way This plan will keep

repayment plan that is affordable and easy to manage your spending to the minimum alloWing you to save more money for loan

repayment

Permanent Disability Forgiveness r-trTeacher Loan Forgiveness (5 You can get rid of your Federal Student Loan if you are permanently disabled Good news for teachers who are under the weight of a massiVe loan You can

now get $17 forgiven on your student loans

Public Service Loan Forgiveness Custom Debt Relief Plans

Want assistance with debt relief Get in touch with our experts who will help If you are a public service agent you can get rid of your loan after 120 days of design a loan repayment and relief plan for you based on your monthly

income and affordability payments

THERE ARE NO OBLIGATIONS OR COMMITMENTS

want to save thousands of dollars Fill out our form and get relief from your student loan for a more

peaceful tomorrow

Your Name

BiHHHi

Exhibit F 51

Attachment A

Page 16: JOSHUA S. MILLARD, BRIAN M. WELKE, pro hac vice · for which it has no legitimate claim. Noel is a Wyoming limited liability company that reported in a public document that its principal

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 16 of 57 Page ID

1

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1775

43 Pursuant to Section 3(c) of the Telemarketing Act 15 USC

sect 6102(c) and Section 18(d)(3) of the FTC Act 15 USC sect 57a(d)(3) a violation

of the TSR constitutes an unfair or deceptive act or practice in or affecting

commerce in violation of Section 5(a) of the FTC Act 15 USC sect 45(a)

VIOLATIONS OF THE TELEMARKETING SALES RULE

Count Two

(Advance Fee for Debt Relief Services)

44 In numerous instances in connection with the telemarketing of

student loan debt relief services Defendants have requested or received payment

of a fee or consideration for debt relief services before

a Defendants have renegotiated settled reduced or otherwise

altered the terms of at least one debt pursuant to a settlement

agreement debt management plan or other such valid contractual

agreement executed by the customer and

b The customer has made at least one payment pursuant to that

settlement agreement debt management plan or other valid

contractual agreement between the customer and the creditor

45 Defendantsrsquo acts or practices as described in Paragraph 44 of this

Complaint are abusive telemarketing acts or practices that violate Section

3104(a)(5)(i) of the TSR 16 CFR sect 3104(a)(5)(i)

Count Three

(Material Debt Relief Misrepresentations)

46 In numerous instances in connection with the telemarketing of

student loan debt relief services Defendants have misrepresented directly or

indirectly expressly or by implication material aspects of their debt relief services

including but not limited to that consumers who purchase Defendantsrsquo debt relief

services will or likely will have their monthly payments reduced or their loan

16

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 17 of 57 Page ID

1

2

3

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1776

balances forgiven in whole or in part

47 Defendantsrsquo acts and practices as described in Paragraph 46 of this

Complaint are deceptive telemarketing acts or practices that violate Section

3103(a)(2)(x) of the TSR 16 CFR sect 3103(a)(2)(x)

Count Four

(Disgorgement of Ill-Gotten Gains of Relief Defendant)

48 Relief Defendant Noel has received directly or indirectly funds or

other assets from Defendants that are traceable to funds obtained from Defendantsrsquo

customers through the unlawful acts or practices described herein

49 Relief Defendant Noel has no legitimate claim to Defendantsrsquo

customersrsquo funds or other assets and will be unjustly enriched if it is not required to

disgorge the assets or the value of benefits received as a result of Defendantsrsquo

unlawful acts or practices

50 By reason of the foregoing Relief Defendant Noel holds funds and

assets in constructive trust for the benefit of Defendantsrsquo customers

CONSUMER INJURY

51 Consumers have suffered and will continue to suffer substantial injury

as a result of Defendantsrsquo violations of the FTC Act and the TSR In addition

Defendants have been unjustly enriched as a result of their unlawful acts or

practices Absent injunctive relief by this Court Defendants are likely to continue

to injure consumers reap unjust enrichment and harm the public interest

THIS COURTrsquoS POWER TO GRANT RELIEF

52 Section 13(b) of the FTC Act 15 USC sect 53(b) empowers this Court

to grant injunctive and such other relief as the Court may deem appropriate to halt

and redress violations of any provision of law enforced by the FTC The Court in

the exercise of its equitable jurisdiction may award ancillary relief including

rescission or reformation of contracts restitution the refund of monies paid and

17

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 18 of 57 Page ID

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1777

the disgorgement of ill-gotten monies to prevent and remedy any violation of any

provision of law enforced by the FTC

53 Section 6(b) of the Telemarketing Act 15 USC sect 6105(b)

authorizes this Court to grant such relief as the Court finds necessary to redress

injury to consumers resulting from Defendantsrsquo violations of the TSR including

the rescission or reformation of contracts and the refund of money

PRAYER FOR RELIEF

Wherefore Plaintiff FTC pursuant to Section 13(b) of the FTC Act 15

USC sect 53(b) Section 6(b) of the Telemarketing Act 15 USC sect 6105(b) and

the Courtrsquos own equitable powers requests that the Court

A Award Plaintiff such preliminary injunctive and ancillary relief as

may be necessary to avert the likelihood of consumer injury during

the pendency of this action and to preserve the possibility of effective

final relief including but not limited to temporary and preliminary

injunctions orders freezing assets immediate access to business

premises appointment of a receiver and expedited discovery

B Enter a permanent injunction to prevent future violations of the FTC

Act and the TSR

C Award such relief as the Court finds necessary to redress injury to

consumers resulting from Defendantsrsquo violations of the FTC Act and

the TSR including but not limited to rescission or reformation of

contracts restitution the refund of monies paid and the disgorgement

of ill-gotten monies

D Enter an order requiring Relief Defendant to disgorge all funds and

assets or the value of the benefit it received from the funds and assets

which are traceable to funds obtained from Defendantsrsquo customers

through the unlawful acts or practices described herein and

18

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 19 of 57 Page ID 1778

2

3

E Award Plaintiff the costs of bringing this action as well as such other

and additional relief as the Court may determine to be just and proper

Dated February 5 2019

Respectfully submitted

ALDEN F ABBOTT General Counsel

JosaSMillard Brian M Welke middot Barbara Chun (Local Counsel) Attorneys for Plaintiff FEDERAL TRADE COMMISSION

4

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Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 20 of 57 Page ID 1779

EXHIBIT A

Attachment A

Free Assessment

Our expercs will lt1ssPss you cun ent

swclent lo n program and decermn which progr ms are

avc11l bl rn yoL11 situation We wi I help you cl11cic1e which progr m r1

help you achieve your goals Call us today

Service Guarantee We are commmecl to 11-1 111g

CllStomers get low r rc1ces ancl monthly payments and we w1I

m ke the pror~ss se mless and s r11ghtforwc1rd ou wi ll be sansf1ed

with our service ml OLlr

cornmcmem to you success Thars ow gu~ ancee

Success Rate Ou1 96 ~ surcPss r a e s 11e of he

cop I a ings tn he industry Olr

process has beer tested nd Olli

succ ss r r~ prowbull~ tn t it works

We c n ll~lp yo reduce and -1111ph y our p ~ymP1 ts Call us today

FTC-AID-1

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 21 of 57 Page ID 1780

20

Exhibit A

ABOUT US

We can help you reduce and simplify your pay1ncnts Contact one of our specialists today for

a free evaluation

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~1lt ntslmiddoturelt A1cl1rg Sudent Fie1ef 1middot cis mmiddote to )fe 11d we offe1 t with middotmiddot1eltbullbe 1es nI 3 rncney lock guMai-itee

We Have Been Featured In

FTC-AID-2

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 22 of 57 Page ID 1781

21

Exhibit A

SERVICES Wt w gtL

Loan Forgiveness Income Based Payments Loan Consol idation In some cases individuals with A period of financial hardship may You may be able to combine

Fede1middota1 Student Loans may qualify qualify you for an Income Based nultiple federal student loans into to have a portion of the amount Repayment Plan In many cases this one new loan w ith a lower more

owed may be forgiven This means means you pay nothing Unlike a affordable monthly payment Loan

your principal balnce coulcl be defe1 ment the term on your loan consolidation prngrams can l1elp

significantly reduced and you will continues to reduce while the plan is you qualify for additional programs not be expected to repay the in place Your term could reduce like loan forgiveness programs or

forgiven amount while you pay nothing Public Setvice Loan Forgiveness

a III

Private Sector Loan Forgiveness

If you work for a government

organization at a city state or

federa l level you may qualify for tle

PL1blic Service Loan Forgiveness

program To qualify your loans

must be cotisolidated into a specific

repayment plan The balance on

your federai student loans is

forgiven after 120 qualifying

bull C Permanent Disability

Forgivenness If your disability is expected to last

60 months or more you may qualify

for permanent disability forgiveness

Q1alifying for Permnent Disability

Forgiveness requires a visi t to your

doctor and individL1als enrolled in

the program are subject to three

years of post-discharge monitoring

Wage Garnishment Prevention

Federal law requires that the

Department of Education or a

gua1middotanty agency notify you before

111st1tuting wage garnishment You

have tl1e right to a hearing where

you can challenge the stated

amount owed and negotiate the

terms of the repayment scheclule

We can intervene on YOL1PflJl~1D-3

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 23 of 57 Page ID 1782

22

Exhibit A

payments have been made p1middotevent wage gampnishments

A FEW STATISTICS ABOUT STUDENT LOAN CRISIS

12 Trillion National Student Debt I he nitionil student loin debt is

now 17 trillion dollirs 1 trillion of

these are in federil student loans

Let us help you through this national

crisis Cill today for a free

evaluation

40 Million Students with Debt

In 7014 an estimated 40 million

current and former students were in

debt because of student loans If

you are one of the millions of people

struggling to pay student loans

Aiding Student Relief is here to help

$33000 Average Student Debt

The graduating class of 7014

average $33000 of student loan

debt per person Thats $3000 more

than the average in 2013 Dont be

one of the many Let Aiding Student

Relief advocate for you

Aiding Student Relief has helped cmrnllcss 1woplc reduce their student debt_ Their proven business

plan has led lo one of lhc highest s11cclSS raCs in the inltl11slly

John Standiford Associated

FTC-AID-4

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 24 of 57 Page ID 1783

23

Exhibit A

TESTIMONIALS

Til~nks to Aiding Student Rel ief Im middotI middotva ove1vvhelrnecl but Aiding The expemiddotts at l1icl i11g Student Rel ief

s1v ing $250 per month Strrd r~rt Relief expl~ inecl the were ther~ to help me when I process ancl rnacle everytl1ing cle11middot nelclecl 1t rw)s t

and sirnple

I Michael Ma 1in

Entrep e11eu1 Em iiy Jallo1 Ii Pa ul Ch is tia I1se11

Teacher Nurse

With so many programs I didnt middotconso lrclating my loans into one I love my Job but vith my high

know what was ng ht for me My monthly payment hs made life student loan payment was still

sruclent loan aclvsor walked me si1nple1 Now I can focus on 1Nhn bamiddotely getting by I don t kn ow what I

through my optio ns rnd now Imiddotn matters to me would hwe clone wthout Aiding

saving 54 I 11n1omh Stucie1middott Rel refmiddot

Ariel Hemiquez Sales co)SUltant

Stephani Seland-1 Small Busim~ss Owner

AJ 01en Museum Curator

RECENT NEWS

)lt)

o(l ttDrlTI -5

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 25 of 57 Page ID 1784

24

Exhibit A

Student Debt Crisis Business Latest Debt Collective Demands May be largely about smallest Student

borrnwers US News amp World Loan Crisis is fa frorn ove The Debt Collective is a group of Report-May 162015 last month Two new reports suggest the college students calling the Fedemiddotal Reserve Bank of New student loan crisis is easing them-se1ves the Corinthian York repor ced that stuclent loan somewhat as the economy Fifteen who are refusing to pay balances rose to 16 trillio n and improves but the crisis is far back their student loins As pa t that 113 per cent of that is in from ove the College Board of this effort the Debt Collective repo t~ tot31 borrowing fell by 8 has written an open lette to the pEbull1 cent between 2012-13 and Department of Education f l llJ 20 13-14 The organization

About Us 11 1 i~d1middot1r F th~~- h1~ ff t1middot~11middot=cl =i~=middott- 1middot __31middotmiddotIIgt middot bullmiddot11

middot- I ( )ntir il t l~i -r_il fr~~

Address bull middot tc1ltj-1r_ =i ~

middot l t1~t 1middot1 fcJ middot~_1 1 I l11 - Hbull 1 tr

~t (~~ 1 12bull~11 T 1 1- - 8555105400

FTC-AID-6

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 26 of 57 Page ID 1785

25

Exhibit A

f - g+ in O) ~ PRIVACY POLICY

This privacy statement discloses the privacy practices for AidllII Student Relief Because Aiding Studen Relief wonts to demonstrate ts firm commlcmell to your

privacy Aiding Sudent Relief hes greed to disclose ls 1rifor111atlori g1thering and dlssem1n1t1on prct1cts Aidlns Studtrit Relief will notify you of

INFORMATION COLLECTION At-ID USE

Aiding Student Relief is the sole owner of the rformMlon collected on this site We will not sell shire or rent this information 10 others In way different from what Is

disclosed 1n this statement Aldln1 StudeM Relief collects 1nform111on throuah this site from our prospective end existing clients at several different poin on our web

site We use their contact Informii on to send information bout our company and to service exsMs accounts Users may optbullout of rece11ns future malllngs see the

cholceoptbullout section below Contect and Financial information that 1s collected Is used for verifying your name address and other informa1on as well as to boll you for

your use of our Gerv1ces using Information from third party sourcH Information about your computer hardwre and software Is automatically collected by Aiding

Student Relief and may be shared in asgregate with third parties whose services are used for traffic analysis purposes This Ir formation includes your IP address

browser type domain names access times and referring Web site addresses Ths information is no tied to personally Identifiable Information This 1nformatlor s used

by Aiding Student Relief to malMan no Improve the quality of the Hrvct and to senerae statistics resardlng use of he Aiding Student Relief site We use third party

services to bill for serlces and to provide other services like our Live Help chat We store the transcripts from these chats for customer service Improvement These

third party service providers are not permitted to use your infornon for any secondary purposes

Thank you and cheers

FTC-AID-7

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 27 of 57 Page ID 1786

26

Exhibit A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 28 of 57 Page ID 1787

EXHIBIT B

Attachment A

((

z | ~

AIDINGSTUDENTRELIEF

bull bull bull bull bull

13 deg $ $ampdegdeg deg() ˝ amp $$deg( + -+Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 29 of 57 Page ID 1788

bulldaggerDagger Daggermdashndash Daggerhellip ƒfrasl hellip lsaquorsaquobullminuspermilminushellip bdquolsaquoldquo rsaquordquobulllsquo fraslbullrsquopermillsaquofraslpermilminushellip sbquo

4556789fADlt=gtA9BCAD

DZgtA=EFGHIJFKLMNOPFQOGFHIQRSTLKSUMMNOPLHMTFIVRWXHKKNIFNUNOPRLFGSHKSRVRVNQ

f e=klHMW

9SI]UQMSNSOQOHHPFK YaSTHHVVJFMHcVGNOJVHHFKKPSUHMLIUOQN_PL[KSVFGJPRSDTHRFPLIP=SNDC==GFdFIP9VaNHQTWSRPbHF_PSKSVNMPMHNIO XNNIIFRKNF7IKSQQMHFNDVPOS9IAeTHPdKSUMMFNKHONP 8aF_KSNVPHTNIMNR[POVFgNPTHLNHIgtMFI YTFHIdFFI D9aHVR_KNKHFHIWIQOTHIQbFFP

lt=Dkgt=L]oHUKMMH ihTFNIORI THHVPRFMVKgtNJ_NFFbIVSJI]IFjdGGVNNN lt=TFKPPNF 9DaFGmVHPGRJMFNNQOSGnPFFTNLUNHPMIMTFVNJOKMIWV

27

]UMNOHPFRKNVSHKKISIRWRrGZNJONgtNjTHKHMI=cQgtORHVPKSOUMddUNKSPIdspNVPNq_ lt=gtBTHFHPb=HFILGFHMt DTFuFIUVFRPNTFIMINVWOPRVOQFIV sFQFPHKKH vaIPNFVcSyOFSPRFMRNVOJH_gtVFDVUJAN9FPwFuVFJLFHMP_VTFFdSIIVdNHUPxI=DQSROJGASHIVdDSNMINONPPaHdOHdPFHRIWVFFHdFIGM˙ 01 $2 301 $$3 ( Exhibit B

8

~ldquo

middot

676EBCEDK5ltAC]5EF_5665E7gt5lt7aFb688E588lt76B5E6F8EBAC78lt76cdddefghijhggklmknmopqprpopst u

13 deg $ $ampdegdeg degˇ amp $$deg + -+Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 30 of 57 Page ID 1789 () ( vPSZwPxyYTUZUWWzxPyxSWMZWPU|SWUWYZ~YTY~QSWbullYXRwU~UxSdaggerXQ~UZXvPSZWSOVQSYNOXPRSTUSDaggerPxXYPZPNXRUSPQZXPbullU~SOhellipUNPxyYTUZmdash zUxSZUZXndashYWShellipYYXOwPxyYTUZUWWMNOPQx~YWShellipYYXOYWUƒDaggerU|XU~XPSWXfrasllsaquoPZXRWPxPxUOPQSOVQSYNONPxDaggerUxSZUZX~YWShellipYYXONPxyYTUZUWWmdash

rsaquominus MZ|PUpermilSWUzSOUZXWbdquoDaggerUxYP~PNZSZ|YSRSx~WRYDaggerSOVQSYNOOPQNPxSZMZ|PUpermilSWU~rdquoUDaggerSOUZXzSZmdashMZSZO|SWUWXRYWUSZWOPQDaggerSOZPXRYZymdash zQhellipY|daggerUxTY|UvPSZwPxyYTUZUWWMNOPQbullPxlsquoNPxSyPTUxZUZXPxySZYrsquoSXYPZSXS|YXOWXSXUPxNU~UxSUTUOPQSOVQSYNONPxXRUzQhellipY|daggerUxTY|UvPSZwPxyYTUZUWWDaggerxPyxSmdashsbquotrade f8Ef8E78FCB6C8EŁPQSOhellipUShellipUXP|PhellipYZUQXYDaggerUNU~UxSWXQ~UZXPSZWYZXPPZUZUbullPSZbullYXRSPbullUxPxUSŒPx~ShellipUPZXRODaggerSOUZXmdashvPSZ|PZWPY~SXYPZDaggerxPyxSW|SZRUDaggerOPQVQSYNONPxS~~YXYPZSDaggerxPyxSW YlsquoU PSZ NPxyYTUZUWWDaggerxPyxSWPxzQhellipY|daggerUxTY|UvPSZwPxyYTUZUWWmdash ŠmŸŽıłŠm 57gt8A57A5B= 8E65C76B5E6F8EB5=6G

PONM[5 QRSTUVQU PYXWZW lt4556789588lt959=lt CD lt H5FICEDJ8KA5LCD

A565E7gt57 œšžeuroiexclcentpoundyenbrvbarsectbrvbareurocopypoundsectlaquoeuropoundlaquobrvbarlaquoregplusmncentbrvbareurocent microparalaquo europoundž raquoY|frac14frac12 plusmncurrenRSUraquoSxXYZeuropoundlaquo laquoeurolaquoordf frac34

^ ˙ ( (

28

Attachment A

01 $2 301 $$3 ( Exhibit B

()(

=4ABC9DEAFBD=FGFHIJKLMJNOMN MRNS mn = nrst = svzhellipu t bulltvDaggerrhellipDaggerurbullbulltuhellipv hellipz~ bullmdashldquordquolsquorsquotrade š oŒŠeuro centpound ` umluml 13 deg $ $ampdegdeg degˇ amp $$deg + -+Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 31 of 57 Page ID 1790

ISNRTUKQINKKNNKL[MRJ PUWQI]MRM qyt|tytzxy rsaquoqNfraslbdquoPUhellipsbquoLUyQhellip rfraslbhellipMNSIKVUQ QNJKvUQsMiexclQQJUx[iexcliexcl_vsect_Qyenyenbrvbarbrvbar uSSRNTPL_LUUMKIaJ_WMIJJKVIONNQJJMWRMIIbQQURKLWIIJQbKLUNKMPTMNQQ_KKRY tbullbulldaggersDaggerv~vhellipmdashryrhellip~mdashrhellipDagger ŸLŽUıQŽbłpermilMtradeœsbquoNtrade_ffRŁyISMŒUQWyNUQŠlsaquo rv45657896lt7ltgt5lt PQKLMIQSNRTUKINQVNOOMVKMWNQKLIJPMXJIKMYZMPIOO NJMOOJLURMNRRMKKLIJ klltko ltgtlt85p5gt5 ouvwxrz ^^ ~ minuspermil tffŁ yenpoundpound KNOWDaggerIreggt4lt97ltndash9ƒ Dagger hellipDaggerlsaquo žko74k57ƒ ƒISNcurrenUIWIbJKWMKJYVNTKM KLONNRqIQQSNNRTUKINQQIJ_JMWNQKLIJJJPMXJIKMcOMUJMVNQKUVK_JUKBHdefABCgDEAFBDghidjlaquopoundbrvbariexclnotvIWIQbDaggerK_WMQKbullMOIMSvOObullIbLKJbullMJMRMW ordf copy

01( $2(301$$3( Exhibit B

29

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 32 of 57 Page ID 1791

EXHIBIT C

Attachment A

~ 111 ~tampi 10 11 ~bull ia1111

Something awesome is coming soon We are buildin somethin ve cool Sta tuned and be at1ent Your atience will be well aid

~lbullrbullUiUffl We can help you reduce and simplify your payments

101 Loan For iveness

1~u 0 (middottmiddotbullmiddotmiddot1 1~=I -- _~

HZamp IMUliULlampRampatiEUWi nmiddot middot-il~ fr middot 8rbullbullrcrr-

_J l _ 1 _f _ur -~t~ u L liYu

~ Income Based Pa ents

bull ~ f I - - I - I - ri u ~u-=lf ~ JU

1-bullA ---rc iM1~~ -~-bullCiel rrcl

~- middot IY 2 i C middot middotJ ll1Jmiddot 0 _ middot_middotIr i

~ LdfiJIMifJ11JJMJllfFffi

middotE-ltecl l2bullJbull iequbullt t11cit t1lt2 CtpCr~middot1e- f

JJd r g-_iraE-1 agltr-middot- ntimiddot middot)middotou

tmiddot_rt- i ic l~1ri ~rbullmiddot middot111~ umiddot -_ d_t-c

fsectmet-Naibullfyen1~poundibllffifftmI

I f-nle Vnot Nune

I ampterYOllrEmall ]

1 ~~~~ 1

If -bull 13n ~Cbull t~middot rct1~j d- gtOY- - hO- irmiddot (bulldbull) plltmiddotmiddot- leemiddotmiddot JOu

1r1cbullmiddotn111f11ri ll1fbull fcrn to ~bull~I

Triin- GU

WAWMyenEIRitiRpoundWt 44 ZiAtillampampI

Exhibit C

Case 818-cv-01987-JLS

-KE

S

Docum

ent 50-1 F

iled 020519 P

age 33 of 57 P

age ID 1792

30

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 34 of 57 Page ID 1793

EXHIBIT D

Attachment A

bull bull bull bull bull bull bull

---

Type then hit enter to

bull bull bull bull bull bull bull

----

----

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 35 of 57 Page ID 1794

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

infoaidnestcom (800) 555-1212

HOME

ABOUT US

SERVICES

FAQ

BLOG

CONTACT

HOME ABOUT US SERVICES FAQ BLOG CONTACT

1 of 6 462018 945 AM

31

Student Loan Forgiveness Loan Consolidation Student Loan Forgiveness

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 36 of 57 Page ID 1795

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

If you have Federal Student Loans yoursquore in the right place to get those loans reduced forgiven or completely discharged through our student loan forgiveness programs

Get your multiple Federal Student Loans consolidated into one forget about increasing interests and pay month to month at the lowest possible cost

We understand if yoursquore going through some hardship and thatrsquos why with us yoursquoll be able to make monthly payments based on your affordability for as low as $000 depending on your situation

2 of 6 462018 945 AM

32

Knowledge Base

Defaulted Student Loans

Wage Garnishment

Student Loan Rehabilitation

Income Based Repayment Plan

Deferment and Forbearance

Pay As You Earn Repayment Plan

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE Call 561)424-6053 today to go over your options

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 37 of 57 Page ID 1796

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

Our knowledge base is designed to provide information regarding some of the critical topics those with student loans must be aware of to be able to make educated decisions regarding their future

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

A wage garnishment is any legal procedure in which some portion of a personrsquos earnings is required to be withheld by an employer for the payment of a debt

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

With this program your payments change as your income changes and will not be longer than 25 years This is the ideal plan if you are in partial financial hardship Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard plan

Temporarily allowing you to postpone or reduce your federal student loan payments Postponing or reducing your payments may help you avoid default and future garnishments

Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard

3 of 6 462018 945 AM

33

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 38 of 57 Page ID 1797

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

4 of 6 462018 945 AM

34Attachment A

Testimonials

Latest News

Why 2016 Will Be a Big Year For Student Loans

Top Student Loan Refinancing Questions of 2015

Oba mas latest student loan plan

Things You Should Know About Public Service Loan Forgiveness

Recent Posts

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 39 of 57 Page ID 1798

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

5 of 6 462018 945 AM

35

About Us

Contact Info

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 40 of 57 Page ID 1799

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

pay-grandchild-studen

Why 2016 Will Be a Big Year For Student Loans

December 30 2015

12511110_1112367518

Top Student Loan Refinancing Questions of 2015

December 30 2015

We stand by our consultation and quote We are so sure and confident about our services and offers that they are all 100 money back guarantee risk free ndash if we donrsquot do what we promise yoursquoll get your money back

(800) 555-1212 AidnestStudenLoansgmailcom 18100 Von Karman Ave Suite 850 Irvine CA 92612

Futero SAS copy 2015 | Aidnestcom

6 of 6 462018 945

Exhibit D 36Attachment A

AM

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 41 of 57 Page ID 1800

EXHIBIT E

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 42 of 57 Page ID 1801

AIDNEST Let us help you through this national crisis

Call one of our specialists today

Forbearance amp Deferment If you are still in school and struggling to make payments on your student loans You may qualify

for Forbearance amp Deferment

Garnishment Prevention Federal law requires that the Department of Education or guarantee agency notifies you before they

begin garnishing your wages

Loan Forgiveness If you are a teacher public service worker or an individual with total and permanent disability you

httpaidnestcom[442018 115239 AM]

37Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 43 of 57 Page ID 1802

AIDNEST Let us help you through this national crisis

may qualify for this program

Consolidating Your Loans Consolidating your loans to one new loan under one lender may lower your payments and make

your life a bit more manageable

Affordable Payments If you are looking to lower your monthly payments then Income Based Repayment Plans may be

the correct choice for you

Learn more about our services

LEARN MORE

httpaidnestcom[442018 115239 AM]

38Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 44 of 57 Page ID 1803

AIDNEST Let us help you through this national crisis

Loan Forgiveness Programs Income Based Payments Student Loan Rehabilitation

Student Loan Consolidation

You may be eligible for

Loan Forgiveness Programs

In some cases individuals with Federal Student Loans may qualify to have a portion of the amount

owed to be forgiven

Get in touch with our professional team to find out which loan forgiveness program you qualify for and

how you can get rid of your unpaid student loan

L EARN MORE

httpaidnestcom[442018 115239 AM]

39Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 45 of 57 Page ID 1804

AIDNEST Let us help you through this national crisis

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE

Meet your Budget One of our advisers will help you meet your payment goals by using your budget and timeline to

determine the best plan available

httpaidnestcom[442018 115239 AM]

40Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 46 of 57 Page ID 1805

AIDNEST Let us help you through this national crisis

Simple Process We understand that lowering your payments alone can be difficult Our intuitive platform allows us

to keep the entire process simple

Customer Satisfaction We are committed to providing you with outstanding service only We look forward to working

with you

100 money back guarantee No Hassle Money Back Policy

httpaidnestcom[442018 115239 AM]

41Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 47 of 57 Page ID 1806

AIDNEST Let us help you through this national crisis

Lower your loan payments by getting in touch with one of our professionals

We design a customized repayment plan that will allow you to make payments based on your

monthly income family size and spending Get rid of the hassle of extensive paperwork and get the

help you deserve

What we can help you achieve a lower payment or lower rate

httpaidnestcom[442018 115239 AM]

42Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 48 of 57 Page ID 1807

AIDNEST Let us help you through this national crisis

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcom[442018 115239 AM]

43Exhibit E

httpaidnestcomservices[442018 115322 AM]

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 49 of 57 Page ID 1808

Services | AIDNEST Let us help you through this national crisis

INCOME BASED PAYMENTS

If you are suffering from a financial hardship you may be eligible for an

Income Based Payment In this repayment program you would have a

payment based on your income and family size The payment could be as

low as $000 per month with forgiveness at the end of 20-25 years

44

Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 50 of 57 Page ID 1809

L E ARN MORE

LOAN FORGIVENESS

If you have Federal Student Loans you may qualify for any of the student

loan forgiveness programs that are available to borrowers You may be

eligible for principal reduction loan forgiveness or a complete loan

discharge depending on your individual circumstance

L EARN MORE

PRIVATE STUDENT LOAN CONSOLIDATION

Much like refinancing a mortgage generally the biggest benefit of private

student loan consolidationstudent loan refinancing is a lower interest rate

httpaidnestcomservices[442018 115322 AM]

45Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 51 of 57 Page ID 1810

L E ARN MORE

(something federal consolidations do not offer)

STUDENT LOAN REHABILITATION

You can renew eligibility for new loans and grants and eliminate the loan

default by ldquorehabilitatingrdquo a defaulted loan

httpaidnestcomservices[442018 115322 AM]

46Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 52 of 57 Page ID 1811

CHE CK E L E G I B I L I T Y

WAGE GARNISHMENT

A wage garnishment is any legal procedure in which some portion of a

personrsquos earnings is required to be withheld by an employer for the

payment of a debt

L EARN MORE

With our fast friendly and professional services wersquoll be glad to help you get your student loans

reduced forgiven or completely discharged To this end wersquoll assist you in consolidating all your

student loans so yoursquoll have only one lender and yoursquoll start making one monthly payment Our

professionals will walk you through the best and most flexible repayment options and if itrsquos also

necessary varied deferment options and rehabilitation programs

httpaidnestcomservices[442018 115322 AM]

47Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 53 of 57 Page ID 1812

Services | AIDNEST Let us help you through this national crisis

Our CRM System

Our CRM is one of the most advanced in the industry and most importantly itrsquos linked directly to

the Department of Education (DOE) This keeps your personal and most confidential information

safe Furthermore because our CRM system is linked to the DOE our approval is 100 Through

our CRM we will be doing continuous monitoring of our process without losing sight of your

immediate needs ensuring that your case has the proper handling and most efficient process

httpaidnestcomservices[442018 115322 AM]

48Exhibit E

n

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 54 of 57 Page ID 1813

Services | AIDNEST Let us help you through this national crisis

R ECENT POSTS

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

ABOUT US

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

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copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcomservices[442018 115322 AM]

49Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 55 of 57 Page ID 1814

EXHIBIT F

s -

bullmiddot - ~ t ~ower Your Student Loan Pay~e~ts oday -- Students Helping Students Save Money

INCOME BASED PAJIIIJITPAIS

I C(gttoUC1 u~

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 56 of 57 Page ID 1815

X + C (D Not secure wwwstudoracom 0

CALL US NOW (85S) 978-S599 middot 1nfostudoracom

HOME SERVICES ABOUT US FAQ CONTACT US BLOC PRIVACY

Offering obligation and commitment free loan relief solutions

STUDENT LOAN FORGIVENESS INCOME BASED PAYMENTS LOAN CONSOLIDATION

We11 help you get your loans reduced forgiven o r Make monthly pdyments based on your affordability Get multiple Federal Student Loans consolidated into

discharged one low monthly payment

Talk to our experts concerning your

student loans

Studora is a pnvatefy owned company that helps consumers like you identify

government programs that fit your financial s1tuat1on Our loan experts will assist you in selecting the appropriate programs that WOltk with your income family size and

desired monthly payment We then prepare the appropriate documents for your review and submission All this f o r one low easy payment

Testimonials

Thank you f o r getting back to me quickly Youve been fabulous Thank you for the confirmation and for your help today Pass

during this whole process Is there a place I can go online that I this on to your sup that you were very professional and very

can leave a comment for your manager Youve made this Robert helpful and brought a sense of relief for me Thank you very

process so easy and answered every question my husband and I much and have a great rest of your day Kudos to you and your

have had teammoneywell spenL

Exhibit F 50

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 57 of 57 Page ID 1816

Services we offer

Stud ora offers document preparation services for all loan forgiveness consolidation and relief services to people who are unable to manage their finances Our mam aim is to

offer complete peace of mind to indiVidual unable to pay their student loan debt

we otter the folloWing document preparation services with complete professional assistance

amFinancial Review ffl Budget Planning

Toe first step to creating a flexible loan repayment plan is financial review we also help create a personal finance plan to ensure that you are able to

Our professmnals will look into your finances and design a custom manage your monthly budget in the most effective way This plan will keep

repayment plan that is affordable and easy to manage your spending to the minimum alloWing you to save more money for loan

repayment

Permanent Disability Forgiveness r-trTeacher Loan Forgiveness (5 You can get rid of your Federal Student Loan if you are permanently disabled Good news for teachers who are under the weight of a massiVe loan You can

now get $17 forgiven on your student loans

Public Service Loan Forgiveness Custom Debt Relief Plans

Want assistance with debt relief Get in touch with our experts who will help If you are a public service agent you can get rid of your loan after 120 days of design a loan repayment and relief plan for you based on your monthly

income and affordability payments

THERE ARE NO OBLIGATIONS OR COMMITMENTS

want to save thousands of dollars Fill out our form and get relief from your student loan for a more

peaceful tomorrow

Your Name

BiHHHi

Exhibit F 51

Attachment A

Page 17: JOSHUA S. MILLARD, BRIAN M. WELKE, pro hac vice · for which it has no legitimate claim. Noel is a Wyoming limited liability company that reported in a public document that its principal

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 17 of 57 Page ID

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balances forgiven in whole or in part

47 Defendantsrsquo acts and practices as described in Paragraph 46 of this

Complaint are deceptive telemarketing acts or practices that violate Section

3103(a)(2)(x) of the TSR 16 CFR sect 3103(a)(2)(x)

Count Four

(Disgorgement of Ill-Gotten Gains of Relief Defendant)

48 Relief Defendant Noel has received directly or indirectly funds or

other assets from Defendants that are traceable to funds obtained from Defendantsrsquo

customers through the unlawful acts or practices described herein

49 Relief Defendant Noel has no legitimate claim to Defendantsrsquo

customersrsquo funds or other assets and will be unjustly enriched if it is not required to

disgorge the assets or the value of benefits received as a result of Defendantsrsquo

unlawful acts or practices

50 By reason of the foregoing Relief Defendant Noel holds funds and

assets in constructive trust for the benefit of Defendantsrsquo customers

CONSUMER INJURY

51 Consumers have suffered and will continue to suffer substantial injury

as a result of Defendantsrsquo violations of the FTC Act and the TSR In addition

Defendants have been unjustly enriched as a result of their unlawful acts or

practices Absent injunctive relief by this Court Defendants are likely to continue

to injure consumers reap unjust enrichment and harm the public interest

THIS COURTrsquoS POWER TO GRANT RELIEF

52 Section 13(b) of the FTC Act 15 USC sect 53(b) empowers this Court

to grant injunctive and such other relief as the Court may deem appropriate to halt

and redress violations of any provision of law enforced by the FTC The Court in

the exercise of its equitable jurisdiction may award ancillary relief including

rescission or reformation of contracts restitution the refund of monies paid and

17

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 18 of 57 Page ID

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the disgorgement of ill-gotten monies to prevent and remedy any violation of any

provision of law enforced by the FTC

53 Section 6(b) of the Telemarketing Act 15 USC sect 6105(b)

authorizes this Court to grant such relief as the Court finds necessary to redress

injury to consumers resulting from Defendantsrsquo violations of the TSR including

the rescission or reformation of contracts and the refund of money

PRAYER FOR RELIEF

Wherefore Plaintiff FTC pursuant to Section 13(b) of the FTC Act 15

USC sect 53(b) Section 6(b) of the Telemarketing Act 15 USC sect 6105(b) and

the Courtrsquos own equitable powers requests that the Court

A Award Plaintiff such preliminary injunctive and ancillary relief as

may be necessary to avert the likelihood of consumer injury during

the pendency of this action and to preserve the possibility of effective

final relief including but not limited to temporary and preliminary

injunctions orders freezing assets immediate access to business

premises appointment of a receiver and expedited discovery

B Enter a permanent injunction to prevent future violations of the FTC

Act and the TSR

C Award such relief as the Court finds necessary to redress injury to

consumers resulting from Defendantsrsquo violations of the FTC Act and

the TSR including but not limited to rescission or reformation of

contracts restitution the refund of monies paid and the disgorgement

of ill-gotten monies

D Enter an order requiring Relief Defendant to disgorge all funds and

assets or the value of the benefit it received from the funds and assets

which are traceable to funds obtained from Defendantsrsquo customers

through the unlawful acts or practices described herein and

18

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 19 of 57 Page ID 1778

2

3

E Award Plaintiff the costs of bringing this action as well as such other

and additional relief as the Court may determine to be just and proper

Dated February 5 2019

Respectfully submitted

ALDEN F ABBOTT General Counsel

JosaSMillard Brian M Welke middot Barbara Chun (Local Counsel) Attorneys for Plaintiff FEDERAL TRADE COMMISSION

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Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 20 of 57 Page ID 1779

EXHIBIT A

Attachment A

Free Assessment

Our expercs will lt1ssPss you cun ent

swclent lo n program and decermn which progr ms are

avc11l bl rn yoL11 situation We wi I help you cl11cic1e which progr m r1

help you achieve your goals Call us today

Service Guarantee We are commmecl to 11-1 111g

CllStomers get low r rc1ces ancl monthly payments and we w1I

m ke the pror~ss se mless and s r11ghtforwc1rd ou wi ll be sansf1ed

with our service ml OLlr

cornmcmem to you success Thars ow gu~ ancee

Success Rate Ou1 96 ~ surcPss r a e s 11e of he

cop I a ings tn he industry Olr

process has beer tested nd Olli

succ ss r r~ prowbull~ tn t it works

We c n ll~lp yo reduce and -1111ph y our p ~ymP1 ts Call us today

FTC-AID-1

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 21 of 57 Page ID 1780

20

Exhibit A

ABOUT US

We can help you reduce and simplify your pay1ncnts Contact one of our specialists today for

a free evaluation

111middot 1_I 1

101

t I 11111 I I

Itbull 11

Ill fl I I

bull ~ 0 I

What Makes Us Great fa1(li1-_~ tur1ent ~e11ef 11as a taf- o~middot tt a middotel elt1)rns bullJn st1ncb110

1middot1ep yriJ Tibullmiddotest fi 1e-ndly f3ce~ 113ve eirej e1tc-nsve1yr =inj ire

fanih1~1 bull11iu1 ti~e nul~nce~ cfscrvern rrent Cdid p11vate stucre11

l1J1ns Th~y viill u~e Ui5 epe tise o loik jUl fJ ycur ~Je~t

i(tres~- f)LH ~U(CtS~ ~HE 1h-~ I lSllt of i_r middotDff ancl iur

C ur ~r_(J~l 1o~w- JCl11~crs f(middotil) 3 00Vtli ~tJegy o r ~dUC2 011i

a1r1plfy yliur- - _Je1middott middotcar payr1t11s 1) Asstrnlins Itle ~atl1t1

2) R~~ear c1-1ng Our st~lff wmiddoti11 (lrJUi~oleaerick ]ll fnfcnTnati(-n befort dtmiddoteJPlr~ t tne ri~n 3) rnnk1middotgbullle i_i1 i e~ear (rr i~ ormiddot1 1 1 etc 1Ne

irvi-s t1ga~ii 111 ps~ib le a~irst 1n(t aptlbull~n 4) 1Nr1 ting VVF p1 eiv lii J 11 iUen u tt-igy IJefore vie Uke ut1c-1l i)ecius~ you d-ese11e 11) undi r~~anci

Lhe pr 1cer S) ~ev1sing Al)ng ~r 1udent Relief 1- 1otT11111tt bull) ti) ci e1H1ve ut-l-~n~-l)O c111 i ri 3 Vbulle -~11 leave n1) sti bull1e u11t111 neltl tecause middot~ve

11~1ve your be~ i1~ t~rest 1t l1ein 6) Si~tcl11ng Our note- =1nd r~c)1 ~ ~1 e thorou~ll ln(I pru1ile 1 ceJ1 po cri1~ 1)f vo111 ~1tuJticn s) iny if-oi

~xpe1 t- 01 eou pped to s~1ty1J_J bullVi r you1 c si- 7) De-gn1ng _ fe ~1 t 1nelt--1- f1ts ti 1middotV 1middotid de~ 1middot1 1 st1 iegy to fit ou 1 1_i dque jtct1in so

011 c111 i Jle y1)u1 1vv1middot1 per feet -ut1e-s ~~0 1 v

1bullVlly 1100~e At(J1n~ Sltl(ltnt Fie11e7) (i1_d aclol~Or~ bull -ii~ (1Ualiftel lci ~~~ISt~h 1noie ype-s middotif JS~iSi_ance u~211 Cd ( (11)itXS i1 jG(l1~t) to ti-tgt

p ~n~ 1not con1p n1es can 11i1p bullbullllh ve )t ~ ~qu1pptCI to bull-bullGr k 1bullv1t1middot1 r~ 11t-2 [uo emiddot 1 lc1 r1s ~~nCI cn even iner-1ne frmiddot tt1e c ~e of 1l~e

~1lt ntslmiddoturelt A1cl1rg Sudent Fie1ef 1middot cis mmiddote to )fe 11d we offe1 t with middotmiddot1eltbullbe 1es nI 3 rncney lock guMai-itee

We Have Been Featured In

FTC-AID-2

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 22 of 57 Page ID 1781

21

Exhibit A

SERVICES Wt w gtL

Loan Forgiveness Income Based Payments Loan Consol idation In some cases individuals with A period of financial hardship may You may be able to combine

Fede1middota1 Student Loans may qualify qualify you for an Income Based nultiple federal student loans into to have a portion of the amount Repayment Plan In many cases this one new loan w ith a lower more

owed may be forgiven This means means you pay nothing Unlike a affordable monthly payment Loan

your principal balnce coulcl be defe1 ment the term on your loan consolidation prngrams can l1elp

significantly reduced and you will continues to reduce while the plan is you qualify for additional programs not be expected to repay the in place Your term could reduce like loan forgiveness programs or

forgiven amount while you pay nothing Public Setvice Loan Forgiveness

a III

Private Sector Loan Forgiveness

If you work for a government

organization at a city state or

federa l level you may qualify for tle

PL1blic Service Loan Forgiveness

program To qualify your loans

must be cotisolidated into a specific

repayment plan The balance on

your federai student loans is

forgiven after 120 qualifying

bull C Permanent Disability

Forgivenness If your disability is expected to last

60 months or more you may qualify

for permanent disability forgiveness

Q1alifying for Permnent Disability

Forgiveness requires a visi t to your

doctor and individL1als enrolled in

the program are subject to three

years of post-discharge monitoring

Wage Garnishment Prevention

Federal law requires that the

Department of Education or a

gua1middotanty agency notify you before

111st1tuting wage garnishment You

have tl1e right to a hearing where

you can challenge the stated

amount owed and negotiate the

terms of the repayment scheclule

We can intervene on YOL1PflJl~1D-3

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 23 of 57 Page ID 1782

22

Exhibit A

payments have been made p1middotevent wage gampnishments

A FEW STATISTICS ABOUT STUDENT LOAN CRISIS

12 Trillion National Student Debt I he nitionil student loin debt is

now 17 trillion dollirs 1 trillion of

these are in federil student loans

Let us help you through this national

crisis Cill today for a free

evaluation

40 Million Students with Debt

In 7014 an estimated 40 million

current and former students were in

debt because of student loans If

you are one of the millions of people

struggling to pay student loans

Aiding Student Relief is here to help

$33000 Average Student Debt

The graduating class of 7014

average $33000 of student loan

debt per person Thats $3000 more

than the average in 2013 Dont be

one of the many Let Aiding Student

Relief advocate for you

Aiding Student Relief has helped cmrnllcss 1woplc reduce their student debt_ Their proven business

plan has led lo one of lhc highest s11cclSS raCs in the inltl11slly

John Standiford Associated

FTC-AID-4

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 24 of 57 Page ID 1783

23

Exhibit A

TESTIMONIALS

Til~nks to Aiding Student Rel ief Im middotI middotva ove1vvhelrnecl but Aiding The expemiddotts at l1icl i11g Student Rel ief

s1v ing $250 per month Strrd r~rt Relief expl~ inecl the were ther~ to help me when I process ancl rnacle everytl1ing cle11middot nelclecl 1t rw)s t

and sirnple

I Michael Ma 1in

Entrep e11eu1 Em iiy Jallo1 Ii Pa ul Ch is tia I1se11

Teacher Nurse

With so many programs I didnt middotconso lrclating my loans into one I love my Job but vith my high

know what was ng ht for me My monthly payment hs made life student loan payment was still

sruclent loan aclvsor walked me si1nple1 Now I can focus on 1Nhn bamiddotely getting by I don t kn ow what I

through my optio ns rnd now Imiddotn matters to me would hwe clone wthout Aiding

saving 54 I 11n1omh Stucie1middott Rel refmiddot

Ariel Hemiquez Sales co)SUltant

Stephani Seland-1 Small Busim~ss Owner

AJ 01en Museum Curator

RECENT NEWS

)lt)

o(l ttDrlTI -5

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 25 of 57 Page ID 1784

24

Exhibit A

Student Debt Crisis Business Latest Debt Collective Demands May be largely about smallest Student

borrnwers US News amp World Loan Crisis is fa frorn ove The Debt Collective is a group of Report-May 162015 last month Two new reports suggest the college students calling the Fedemiddotal Reserve Bank of New student loan crisis is easing them-se1ves the Corinthian York repor ced that stuclent loan somewhat as the economy Fifteen who are refusing to pay balances rose to 16 trillio n and improves but the crisis is far back their student loins As pa t that 113 per cent of that is in from ove the College Board of this effort the Debt Collective repo t~ tot31 borrowing fell by 8 has written an open lette to the pEbull1 cent between 2012-13 and Department of Education f l llJ 20 13-14 The organization

About Us 11 1 i~d1middot1r F th~~- h1~ ff t1middot~11middot=cl =i~=middott- 1middot __31middotmiddotIIgt middot bullmiddot11

middot- I ( )ntir il t l~i -r_il fr~~

Address bull middot tc1ltj-1r_ =i ~

middot l t1~t 1middot1 fcJ middot~_1 1 I l11 - Hbull 1 tr

~t (~~ 1 12bull~11 T 1 1- - 8555105400

FTC-AID-6

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 26 of 57 Page ID 1785

25

Exhibit A

f - g+ in O) ~ PRIVACY POLICY

This privacy statement discloses the privacy practices for AidllII Student Relief Because Aiding Studen Relief wonts to demonstrate ts firm commlcmell to your

privacy Aiding Sudent Relief hes greed to disclose ls 1rifor111atlori g1thering and dlssem1n1t1on prct1cts Aidlns Studtrit Relief will notify you of

INFORMATION COLLECTION At-ID USE

Aiding Student Relief is the sole owner of the rformMlon collected on this site We will not sell shire or rent this information 10 others In way different from what Is

disclosed 1n this statement Aldln1 StudeM Relief collects 1nform111on throuah this site from our prospective end existing clients at several different poin on our web

site We use their contact Informii on to send information bout our company and to service exsMs accounts Users may optbullout of rece11ns future malllngs see the

cholceoptbullout section below Contect and Financial information that 1s collected Is used for verifying your name address and other informa1on as well as to boll you for

your use of our Gerv1ces using Information from third party sourcH Information about your computer hardwre and software Is automatically collected by Aiding

Student Relief and may be shared in asgregate with third parties whose services are used for traffic analysis purposes This Ir formation includes your IP address

browser type domain names access times and referring Web site addresses Ths information is no tied to personally Identifiable Information This 1nformatlor s used

by Aiding Student Relief to malMan no Improve the quality of the Hrvct and to senerae statistics resardlng use of he Aiding Student Relief site We use third party

services to bill for serlces and to provide other services like our Live Help chat We store the transcripts from these chats for customer service Improvement These

third party service providers are not permitted to use your infornon for any secondary purposes

Thank you and cheers

FTC-AID-7

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 27 of 57 Page ID 1786

26

Exhibit A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 28 of 57 Page ID 1787

EXHIBIT B

Attachment A

((

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AIDINGSTUDENTRELIEF

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28

Attachment A

01 $2 301 $$3 ( Exhibit B

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Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 32 of 57 Page ID 1791

EXHIBIT C

Attachment A

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Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 34 of 57 Page ID 1793

EXHIBIT D

Attachment A

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Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 35 of 57 Page ID 1794

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

infoaidnestcom (800) 555-1212

HOME

ABOUT US

SERVICES

FAQ

BLOG

CONTACT

HOME ABOUT US SERVICES FAQ BLOG CONTACT

1 of 6 462018 945 AM

31

Student Loan Forgiveness Loan Consolidation Student Loan Forgiveness

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 36 of 57 Page ID 1795

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

If you have Federal Student Loans yoursquore in the right place to get those loans reduced forgiven or completely discharged through our student loan forgiveness programs

Get your multiple Federal Student Loans consolidated into one forget about increasing interests and pay month to month at the lowest possible cost

We understand if yoursquore going through some hardship and thatrsquos why with us yoursquoll be able to make monthly payments based on your affordability for as low as $000 depending on your situation

2 of 6 462018 945 AM

32

Knowledge Base

Defaulted Student Loans

Wage Garnishment

Student Loan Rehabilitation

Income Based Repayment Plan

Deferment and Forbearance

Pay As You Earn Repayment Plan

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE Call 561)424-6053 today to go over your options

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 37 of 57 Page ID 1796

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

Our knowledge base is designed to provide information regarding some of the critical topics those with student loans must be aware of to be able to make educated decisions regarding their future

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

A wage garnishment is any legal procedure in which some portion of a personrsquos earnings is required to be withheld by an employer for the payment of a debt

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

With this program your payments change as your income changes and will not be longer than 25 years This is the ideal plan if you are in partial financial hardship Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard plan

Temporarily allowing you to postpone or reduce your federal student loan payments Postponing or reducing your payments may help you avoid default and future garnishments

Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard

3 of 6 462018 945 AM

33

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 38 of 57 Page ID 1797

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

4 of 6 462018 945 AM

34Attachment A

Testimonials

Latest News

Why 2016 Will Be a Big Year For Student Loans

Top Student Loan Refinancing Questions of 2015

Oba mas latest student loan plan

Things You Should Know About Public Service Loan Forgiveness

Recent Posts

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 39 of 57 Page ID 1798

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

5 of 6 462018 945 AM

35

About Us

Contact Info

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 40 of 57 Page ID 1799

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

pay-grandchild-studen

Why 2016 Will Be a Big Year For Student Loans

December 30 2015

12511110_1112367518

Top Student Loan Refinancing Questions of 2015

December 30 2015

We stand by our consultation and quote We are so sure and confident about our services and offers that they are all 100 money back guarantee risk free ndash if we donrsquot do what we promise yoursquoll get your money back

(800) 555-1212 AidnestStudenLoansgmailcom 18100 Von Karman Ave Suite 850 Irvine CA 92612

Futero SAS copy 2015 | Aidnestcom

6 of 6 462018 945

Exhibit D 36Attachment A

AM

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 41 of 57 Page ID 1800

EXHIBIT E

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 42 of 57 Page ID 1801

AIDNEST Let us help you through this national crisis

Call one of our specialists today

Forbearance amp Deferment If you are still in school and struggling to make payments on your student loans You may qualify

for Forbearance amp Deferment

Garnishment Prevention Federal law requires that the Department of Education or guarantee agency notifies you before they

begin garnishing your wages

Loan Forgiveness If you are a teacher public service worker or an individual with total and permanent disability you

httpaidnestcom[442018 115239 AM]

37Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 43 of 57 Page ID 1802

AIDNEST Let us help you through this national crisis

may qualify for this program

Consolidating Your Loans Consolidating your loans to one new loan under one lender may lower your payments and make

your life a bit more manageable

Affordable Payments If you are looking to lower your monthly payments then Income Based Repayment Plans may be

the correct choice for you

Learn more about our services

LEARN MORE

httpaidnestcom[442018 115239 AM]

38Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 44 of 57 Page ID 1803

AIDNEST Let us help you through this national crisis

Loan Forgiveness Programs Income Based Payments Student Loan Rehabilitation

Student Loan Consolidation

You may be eligible for

Loan Forgiveness Programs

In some cases individuals with Federal Student Loans may qualify to have a portion of the amount

owed to be forgiven

Get in touch with our professional team to find out which loan forgiveness program you qualify for and

how you can get rid of your unpaid student loan

L EARN MORE

httpaidnestcom[442018 115239 AM]

39Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 45 of 57 Page ID 1804

AIDNEST Let us help you through this national crisis

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE

Meet your Budget One of our advisers will help you meet your payment goals by using your budget and timeline to

determine the best plan available

httpaidnestcom[442018 115239 AM]

40Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 46 of 57 Page ID 1805

AIDNEST Let us help you through this national crisis

Simple Process We understand that lowering your payments alone can be difficult Our intuitive platform allows us

to keep the entire process simple

Customer Satisfaction We are committed to providing you with outstanding service only We look forward to working

with you

100 money back guarantee No Hassle Money Back Policy

httpaidnestcom[442018 115239 AM]

41Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 47 of 57 Page ID 1806

AIDNEST Let us help you through this national crisis

Lower your loan payments by getting in touch with one of our professionals

We design a customized repayment plan that will allow you to make payments based on your

monthly income family size and spending Get rid of the hassle of extensive paperwork and get the

help you deserve

What we can help you achieve a lower payment or lower rate

httpaidnestcom[442018 115239 AM]

42Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 48 of 57 Page ID 1807

AIDNEST Let us help you through this national crisis

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcom[442018 115239 AM]

43Exhibit E

httpaidnestcomservices[442018 115322 AM]

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 49 of 57 Page ID 1808

Services | AIDNEST Let us help you through this national crisis

INCOME BASED PAYMENTS

If you are suffering from a financial hardship you may be eligible for an

Income Based Payment In this repayment program you would have a

payment based on your income and family size The payment could be as

low as $000 per month with forgiveness at the end of 20-25 years

44

Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 50 of 57 Page ID 1809

L E ARN MORE

LOAN FORGIVENESS

If you have Federal Student Loans you may qualify for any of the student

loan forgiveness programs that are available to borrowers You may be

eligible for principal reduction loan forgiveness or a complete loan

discharge depending on your individual circumstance

L EARN MORE

PRIVATE STUDENT LOAN CONSOLIDATION

Much like refinancing a mortgage generally the biggest benefit of private

student loan consolidationstudent loan refinancing is a lower interest rate

httpaidnestcomservices[442018 115322 AM]

45Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 51 of 57 Page ID 1810

L E ARN MORE

(something federal consolidations do not offer)

STUDENT LOAN REHABILITATION

You can renew eligibility for new loans and grants and eliminate the loan

default by ldquorehabilitatingrdquo a defaulted loan

httpaidnestcomservices[442018 115322 AM]

46Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 52 of 57 Page ID 1811

CHE CK E L E G I B I L I T Y

WAGE GARNISHMENT

A wage garnishment is any legal procedure in which some portion of a

personrsquos earnings is required to be withheld by an employer for the

payment of a debt

L EARN MORE

With our fast friendly and professional services wersquoll be glad to help you get your student loans

reduced forgiven or completely discharged To this end wersquoll assist you in consolidating all your

student loans so yoursquoll have only one lender and yoursquoll start making one monthly payment Our

professionals will walk you through the best and most flexible repayment options and if itrsquos also

necessary varied deferment options and rehabilitation programs

httpaidnestcomservices[442018 115322 AM]

47Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 53 of 57 Page ID 1812

Services | AIDNEST Let us help you through this national crisis

Our CRM System

Our CRM is one of the most advanced in the industry and most importantly itrsquos linked directly to

the Department of Education (DOE) This keeps your personal and most confidential information

safe Furthermore because our CRM system is linked to the DOE our approval is 100 Through

our CRM we will be doing continuous monitoring of our process without losing sight of your

immediate needs ensuring that your case has the proper handling and most efficient process

httpaidnestcomservices[442018 115322 AM]

48Exhibit E

n

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 54 of 57 Page ID 1813

Services | AIDNEST Let us help you through this national crisis

R ECENT POSTS

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

ABOUT US

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcomservices[442018 115322 AM]

49Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 55 of 57 Page ID 1814

EXHIBIT F

s -

bullmiddot - ~ t ~ower Your Student Loan Pay~e~ts oday -- Students Helping Students Save Money

INCOME BASED PAJIIIJITPAIS

I C(gttoUC1 u~

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 56 of 57 Page ID 1815

X + C (D Not secure wwwstudoracom 0

CALL US NOW (85S) 978-S599 middot 1nfostudoracom

HOME SERVICES ABOUT US FAQ CONTACT US BLOC PRIVACY

Offering obligation and commitment free loan relief solutions

STUDENT LOAN FORGIVENESS INCOME BASED PAYMENTS LOAN CONSOLIDATION

We11 help you get your loans reduced forgiven o r Make monthly pdyments based on your affordability Get multiple Federal Student Loans consolidated into

discharged one low monthly payment

Talk to our experts concerning your

student loans

Studora is a pnvatefy owned company that helps consumers like you identify

government programs that fit your financial s1tuat1on Our loan experts will assist you in selecting the appropriate programs that WOltk with your income family size and

desired monthly payment We then prepare the appropriate documents for your review and submission All this f o r one low easy payment

Testimonials

Thank you f o r getting back to me quickly Youve been fabulous Thank you for the confirmation and for your help today Pass

during this whole process Is there a place I can go online that I this on to your sup that you were very professional and very

can leave a comment for your manager Youve made this Robert helpful and brought a sense of relief for me Thank you very

process so easy and answered every question my husband and I much and have a great rest of your day Kudos to you and your

have had teammoneywell spenL

Exhibit F 50

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 57 of 57 Page ID 1816

Services we offer

Stud ora offers document preparation services for all loan forgiveness consolidation and relief services to people who are unable to manage their finances Our mam aim is to

offer complete peace of mind to indiVidual unable to pay their student loan debt

we otter the folloWing document preparation services with complete professional assistance

amFinancial Review ffl Budget Planning

Toe first step to creating a flexible loan repayment plan is financial review we also help create a personal finance plan to ensure that you are able to

Our professmnals will look into your finances and design a custom manage your monthly budget in the most effective way This plan will keep

repayment plan that is affordable and easy to manage your spending to the minimum alloWing you to save more money for loan

repayment

Permanent Disability Forgiveness r-trTeacher Loan Forgiveness (5 You can get rid of your Federal Student Loan if you are permanently disabled Good news for teachers who are under the weight of a massiVe loan You can

now get $17 forgiven on your student loans

Public Service Loan Forgiveness Custom Debt Relief Plans

Want assistance with debt relief Get in touch with our experts who will help If you are a public service agent you can get rid of your loan after 120 days of design a loan repayment and relief plan for you based on your monthly

income and affordability payments

THERE ARE NO OBLIGATIONS OR COMMITMENTS

want to save thousands of dollars Fill out our form and get relief from your student loan for a more

peaceful tomorrow

Your Name

BiHHHi

Exhibit F 51

Attachment A

Page 18: JOSHUA S. MILLARD, BRIAN M. WELKE, pro hac vice · for which it has no legitimate claim. Noel is a Wyoming limited liability company that reported in a public document that its principal

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 18 of 57 Page ID

1

2

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5

6

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27

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1777

the disgorgement of ill-gotten monies to prevent and remedy any violation of any

provision of law enforced by the FTC

53 Section 6(b) of the Telemarketing Act 15 USC sect 6105(b)

authorizes this Court to grant such relief as the Court finds necessary to redress

injury to consumers resulting from Defendantsrsquo violations of the TSR including

the rescission or reformation of contracts and the refund of money

PRAYER FOR RELIEF

Wherefore Plaintiff FTC pursuant to Section 13(b) of the FTC Act 15

USC sect 53(b) Section 6(b) of the Telemarketing Act 15 USC sect 6105(b) and

the Courtrsquos own equitable powers requests that the Court

A Award Plaintiff such preliminary injunctive and ancillary relief as

may be necessary to avert the likelihood of consumer injury during

the pendency of this action and to preserve the possibility of effective

final relief including but not limited to temporary and preliminary

injunctions orders freezing assets immediate access to business

premises appointment of a receiver and expedited discovery

B Enter a permanent injunction to prevent future violations of the FTC

Act and the TSR

C Award such relief as the Court finds necessary to redress injury to

consumers resulting from Defendantsrsquo violations of the FTC Act and

the TSR including but not limited to rescission or reformation of

contracts restitution the refund of monies paid and the disgorgement

of ill-gotten monies

D Enter an order requiring Relief Defendant to disgorge all funds and

assets or the value of the benefit it received from the funds and assets

which are traceable to funds obtained from Defendantsrsquo customers

through the unlawful acts or practices described herein and

18

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 19 of 57 Page ID 1778

2

3

E Award Plaintiff the costs of bringing this action as well as such other

and additional relief as the Court may determine to be just and proper

Dated February 5 2019

Respectfully submitted

ALDEN F ABBOTT General Counsel

JosaSMillard Brian M Welke middot Barbara Chun (Local Counsel) Attorneys for Plaintiff FEDERAL TRADE COMMISSION

4

5

6

7

8

9

10

11

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14

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17

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22

23

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28

19

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 20 of 57 Page ID 1779

EXHIBIT A

Attachment A

Free Assessment

Our expercs will lt1ssPss you cun ent

swclent lo n program and decermn which progr ms are

avc11l bl rn yoL11 situation We wi I help you cl11cic1e which progr m r1

help you achieve your goals Call us today

Service Guarantee We are commmecl to 11-1 111g

CllStomers get low r rc1ces ancl monthly payments and we w1I

m ke the pror~ss se mless and s r11ghtforwc1rd ou wi ll be sansf1ed

with our service ml OLlr

cornmcmem to you success Thars ow gu~ ancee

Success Rate Ou1 96 ~ surcPss r a e s 11e of he

cop I a ings tn he industry Olr

process has beer tested nd Olli

succ ss r r~ prowbull~ tn t it works

We c n ll~lp yo reduce and -1111ph y our p ~ymP1 ts Call us today

FTC-AID-1

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 21 of 57 Page ID 1780

20

Exhibit A

ABOUT US

We can help you reduce and simplify your pay1ncnts Contact one of our specialists today for

a free evaluation

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What Makes Us Great fa1(li1-_~ tur1ent ~e11ef 11as a taf- o~middot tt a middotel elt1)rns bullJn st1ncb110

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l1J1ns Th~y viill u~e Ui5 epe tise o loik jUl fJ ycur ~Je~t

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FTC-AID-2

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 22 of 57 Page ID 1781

21

Exhibit A

SERVICES Wt w gtL

Loan Forgiveness Income Based Payments Loan Consol idation In some cases individuals with A period of financial hardship may You may be able to combine

Fede1middota1 Student Loans may qualify qualify you for an Income Based nultiple federal student loans into to have a portion of the amount Repayment Plan In many cases this one new loan w ith a lower more

owed may be forgiven This means means you pay nothing Unlike a affordable monthly payment Loan

your principal balnce coulcl be defe1 ment the term on your loan consolidation prngrams can l1elp

significantly reduced and you will continues to reduce while the plan is you qualify for additional programs not be expected to repay the in place Your term could reduce like loan forgiveness programs or

forgiven amount while you pay nothing Public Setvice Loan Forgiveness

a III

Private Sector Loan Forgiveness

If you work for a government

organization at a city state or

federa l level you may qualify for tle

PL1blic Service Loan Forgiveness

program To qualify your loans

must be cotisolidated into a specific

repayment plan The balance on

your federai student loans is

forgiven after 120 qualifying

bull C Permanent Disability

Forgivenness If your disability is expected to last

60 months or more you may qualify

for permanent disability forgiveness

Q1alifying for Permnent Disability

Forgiveness requires a visi t to your

doctor and individL1als enrolled in

the program are subject to three

years of post-discharge monitoring

Wage Garnishment Prevention

Federal law requires that the

Department of Education or a

gua1middotanty agency notify you before

111st1tuting wage garnishment You

have tl1e right to a hearing where

you can challenge the stated

amount owed and negotiate the

terms of the repayment scheclule

We can intervene on YOL1PflJl~1D-3

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 23 of 57 Page ID 1782

22

Exhibit A

payments have been made p1middotevent wage gampnishments

A FEW STATISTICS ABOUT STUDENT LOAN CRISIS

12 Trillion National Student Debt I he nitionil student loin debt is

now 17 trillion dollirs 1 trillion of

these are in federil student loans

Let us help you through this national

crisis Cill today for a free

evaluation

40 Million Students with Debt

In 7014 an estimated 40 million

current and former students were in

debt because of student loans If

you are one of the millions of people

struggling to pay student loans

Aiding Student Relief is here to help

$33000 Average Student Debt

The graduating class of 7014

average $33000 of student loan

debt per person Thats $3000 more

than the average in 2013 Dont be

one of the many Let Aiding Student

Relief advocate for you

Aiding Student Relief has helped cmrnllcss 1woplc reduce their student debt_ Their proven business

plan has led lo one of lhc highest s11cclSS raCs in the inltl11slly

John Standiford Associated

FTC-AID-4

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 24 of 57 Page ID 1783

23

Exhibit A

TESTIMONIALS

Til~nks to Aiding Student Rel ief Im middotI middotva ove1vvhelrnecl but Aiding The expemiddotts at l1icl i11g Student Rel ief

s1v ing $250 per month Strrd r~rt Relief expl~ inecl the were ther~ to help me when I process ancl rnacle everytl1ing cle11middot nelclecl 1t rw)s t

and sirnple

I Michael Ma 1in

Entrep e11eu1 Em iiy Jallo1 Ii Pa ul Ch is tia I1se11

Teacher Nurse

With so many programs I didnt middotconso lrclating my loans into one I love my Job but vith my high

know what was ng ht for me My monthly payment hs made life student loan payment was still

sruclent loan aclvsor walked me si1nple1 Now I can focus on 1Nhn bamiddotely getting by I don t kn ow what I

through my optio ns rnd now Imiddotn matters to me would hwe clone wthout Aiding

saving 54 I 11n1omh Stucie1middott Rel refmiddot

Ariel Hemiquez Sales co)SUltant

Stephani Seland-1 Small Busim~ss Owner

AJ 01en Museum Curator

RECENT NEWS

)lt)

o(l ttDrlTI -5

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 25 of 57 Page ID 1784

24

Exhibit A

Student Debt Crisis Business Latest Debt Collective Demands May be largely about smallest Student

borrnwers US News amp World Loan Crisis is fa frorn ove The Debt Collective is a group of Report-May 162015 last month Two new reports suggest the college students calling the Fedemiddotal Reserve Bank of New student loan crisis is easing them-se1ves the Corinthian York repor ced that stuclent loan somewhat as the economy Fifteen who are refusing to pay balances rose to 16 trillio n and improves but the crisis is far back their student loins As pa t that 113 per cent of that is in from ove the College Board of this effort the Debt Collective repo t~ tot31 borrowing fell by 8 has written an open lette to the pEbull1 cent between 2012-13 and Department of Education f l llJ 20 13-14 The organization

About Us 11 1 i~d1middot1r F th~~- h1~ ff t1middot~11middot=cl =i~=middott- 1middot __31middotmiddotIIgt middot bullmiddot11

middot- I ( )ntir il t l~i -r_il fr~~

Address bull middot tc1ltj-1r_ =i ~

middot l t1~t 1middot1 fcJ middot~_1 1 I l11 - Hbull 1 tr

~t (~~ 1 12bull~11 T 1 1- - 8555105400

FTC-AID-6

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 26 of 57 Page ID 1785

25

Exhibit A

f - g+ in O) ~ PRIVACY POLICY

This privacy statement discloses the privacy practices for AidllII Student Relief Because Aiding Studen Relief wonts to demonstrate ts firm commlcmell to your

privacy Aiding Sudent Relief hes greed to disclose ls 1rifor111atlori g1thering and dlssem1n1t1on prct1cts Aidlns Studtrit Relief will notify you of

INFORMATION COLLECTION At-ID USE

Aiding Student Relief is the sole owner of the rformMlon collected on this site We will not sell shire or rent this information 10 others In way different from what Is

disclosed 1n this statement Aldln1 StudeM Relief collects 1nform111on throuah this site from our prospective end existing clients at several different poin on our web

site We use their contact Informii on to send information bout our company and to service exsMs accounts Users may optbullout of rece11ns future malllngs see the

cholceoptbullout section below Contect and Financial information that 1s collected Is used for verifying your name address and other informa1on as well as to boll you for

your use of our Gerv1ces using Information from third party sourcH Information about your computer hardwre and software Is automatically collected by Aiding

Student Relief and may be shared in asgregate with third parties whose services are used for traffic analysis purposes This Ir formation includes your IP address

browser type domain names access times and referring Web site addresses Ths information is no tied to personally Identifiable Information This 1nformatlor s used

by Aiding Student Relief to malMan no Improve the quality of the Hrvct and to senerae statistics resardlng use of he Aiding Student Relief site We use third party

services to bill for serlces and to provide other services like our Live Help chat We store the transcripts from these chats for customer service Improvement These

third party service providers are not permitted to use your infornon for any secondary purposes

Thank you and cheers

FTC-AID-7

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 27 of 57 Page ID 1786

26

Exhibit A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 28 of 57 Page ID 1787

EXHIBIT B

Attachment A

((

z | ~

AIDINGSTUDENTRELIEF

bull bull bull bull bull

13 deg $ $ampdegdeg deg() ˝ amp $$deg( + -+Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 29 of 57 Page ID 1788

bulldaggerDagger Daggermdashndash Daggerhellip ƒfrasl hellip lsaquorsaquobullminuspermilminushellip bdquolsaquoldquo rsaquordquobulllsquo fraslbullrsquopermillsaquofraslpermilminushellip sbquo

4556789fADlt=gtA9BCAD

DZgtA=EFGHIJFKLMNOPFQOGFHIQRSTLKSUMMNOPLHMTFIVRWXHKKNIFNUNOPRLFGSHKSRVRVNQ

f e=klHMW

9SI]UQMSNSOQOHHPFK YaSTHHVVJFMHcVGNOJVHHFKKPSUHMLIUOQN_PL[KSVFGJPRSDTHRFPLIP=SNDC==GFdFIP9VaNHQTWSRPbHF_PSKSVNMPMHNIO XNNIIFRKNF7IKSQQMHFNDVPOS9IAeTHPdKSUMMFNKHONP 8aF_KSNVPHTNIMNR[POVFgNPTHLNHIgtMFI YTFHIdFFI D9aHVR_KNKHFHIWIQOTHIQbFFP

lt=Dkgt=L]oHUKMMH ihTFNIORI THHVPRFMVKgtNJ_NFFbIVSJI]IFjdGGVNNN lt=TFKPPNF 9DaFGmVHPGRJMFNNQOSGnPFFTNLUNHPMIMTFVNJOKMIWV

27

]UMNOHPFRKNVSHKKISIRWRrGZNJONgtNjTHKHMI=cQgtORHVPKSOUMddUNKSPIdspNVPNq_ lt=gtBTHFHPb=HFILGFHMt DTFuFIUVFRPNTFIMINVWOPRVOQFIV sFQFPHKKH vaIPNFVcSyOFSPRFMRNVOJH_gtVFDVUJAN9FPwFuVFJLFHMP_VTFFdSIIVdNHUPxI=DQSROJGASHIVdDSNMINONPPaHdOHdPFHRIWVFFHdFIGM˙ 01 $2 301 $$3 ( Exhibit B

8

~ldquo

middot

676EBCEDK5ltAC]5EF_5665E7gt5lt7aFb688E588lt76B5E6F8EBAC78lt76cdddefghijhggklmknmopqprpopst u

13 deg $ $ampdegdeg degˇ amp $$deg + -+Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 30 of 57 Page ID 1789 () ( vPSZwPxyYTUZUWWzxPyxSWMZWPU|SWUWYZ~YTY~QSWbullYXRwU~UxSdaggerXQ~UZXvPSZWSOVQSYNOXPRSTUSDaggerPxXYPZPNXRUSPQZXPbullU~SOhellipUNPxyYTUZmdash zUxSZUZXndashYWShellipYYXOwPxyYTUZUWWMNOPQx~YWShellipYYXOYWUƒDaggerU|XU~XPSWXfrasllsaquoPZXRWPxPxUOPQSOVQSYNONPxDaggerUxSZUZX~YWShellipYYXONPxyYTUZUWWmdash

rsaquominus MZ|PUpermilSWUzSOUZXWbdquoDaggerUxYP~PNZSZ|YSRSx~WRYDaggerSOVQSYNOOPQNPxSZMZ|PUpermilSWU~rdquoUDaggerSOUZXzSZmdashMZSZO|SWUWXRYWUSZWOPQDaggerSOZPXRYZymdash zQhellipY|daggerUxTY|UvPSZwPxyYTUZUWWMNOPQbullPxlsquoNPxSyPTUxZUZXPxySZYrsquoSXYPZSXS|YXOWXSXUPxNU~UxSUTUOPQSOVQSYNONPxXRUzQhellipY|daggerUxTY|UvPSZwPxyYTUZUWWDaggerxPyxSmdashsbquotrade f8Ef8E78FCB6C8EŁPQSOhellipUShellipUXP|PhellipYZUQXYDaggerUNU~UxSWXQ~UZXPSZWYZXPPZUZUbullPSZbullYXRSPbullUxPxUSŒPx~ShellipUPZXRODaggerSOUZXmdashvPSZ|PZWPY~SXYPZDaggerxPyxSW|SZRUDaggerOPQVQSYNONPxS~~YXYPZSDaggerxPyxSW YlsquoU PSZ NPxyYTUZUWWDaggerxPyxSWPxzQhellipY|daggerUxTY|UvPSZwPxyYTUZUWWmdash ŠmŸŽıłŠm 57gt8A57A5B= 8E65C76B5E6F8EB5=6G

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^ ˙ ( (

28

Attachment A

01 $2 301 $$3 ( Exhibit B

()(

=4ABC9DEAFBD=FGFHIJKLMJNOMN MRNS mn = nrst = svzhellipu t bulltvDaggerrhellipDaggerurbullbulltuhellipv hellipz~ bullmdashldquordquolsquorsquotrade š oŒŠeuro centpound ` umluml 13 deg $ $ampdegdeg degˇ amp $$deg + -+Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 31 of 57 Page ID 1790

ISNRTUKQINKKNNKL[MRJ PUWQI]MRM qyt|tytzxy rsaquoqNfraslbdquoPUhellipsbquoLUyQhellip rfraslbhellipMNSIKVUQ QNJKvUQsMiexclQQJUx[iexcliexcl_vsect_Qyenyenbrvbarbrvbar uSSRNTPL_LUUMKIaJ_WMIJJKVIONNQJJMWRMIIbQQURKLWIIJQbKLUNKMPTMNQQ_KKRY tbullbulldaggersDaggerv~vhellipmdashryrhellip~mdashrhellipDagger ŸLŽUıQŽbłpermilMtradeœsbquoNtrade_ffRŁyISMŒUQWyNUQŠlsaquo rv45657896lt7ltgt5lt PQKLMIQSNRTUKINQVNOOMVKMWNQKLIJPMXJIKMYZMPIOO NJMOOJLURMNRRMKKLIJ klltko ltgtlt85p5gt5 ouvwxrz ^^ ~ minuspermil tffŁ yenpoundpound KNOWDaggerIreggt4lt97ltndash9ƒ Dagger hellipDaggerlsaquo žko74k57ƒ ƒISNcurrenUIWIbJKWMKJYVNTKM KLONNRqIQQSNNRTUKINQQIJ_JMWNQKLIJJJPMXJIKMcOMUJMVNQKUVK_JUKBHdefABCgDEAFBDghidjlaquopoundbrvbariexclnotvIWIQbDaggerK_WMQKbullMOIMSvOObullIbLKJbullMJMRMW ordf copy

01( $2(301$$3( Exhibit B

29

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 32 of 57 Page ID 1791

EXHIBIT C

Attachment A

~ 111 ~tampi 10 11 ~bull ia1111

Something awesome is coming soon We are buildin somethin ve cool Sta tuned and be at1ent Your atience will be well aid

~lbullrbullUiUffl We can help you reduce and simplify your payments

101 Loan For iveness

1~u 0 (middottmiddotbullmiddotmiddot1 1~=I -- _~

HZamp IMUliULlampRampatiEUWi nmiddot middot-il~ fr middot 8rbullbullrcrr-

_J l _ 1 _f _ur -~t~ u L liYu

~ Income Based Pa ents

bull ~ f I - - I - I - ri u ~u-=lf ~ JU

1-bullA ---rc iM1~~ -~-bullCiel rrcl

~- middot IY 2 i C middot middotJ ll1Jmiddot 0 _ middot_middotIr i

~ LdfiJIMifJ11JJMJllfFffi

middotE-ltecl l2bullJbull iequbullt t11cit t1lt2 CtpCr~middot1e- f

JJd r g-_iraE-1 agltr-middot- ntimiddot middot)middotou

tmiddot_rt- i ic l~1ri ~rbullmiddot middot111~ umiddot -_ d_t-c

fsectmet-Naibullfyen1~poundibllffifftmI

I f-nle Vnot Nune

I ampterYOllrEmall ]

1 ~~~~ 1

If -bull 13n ~Cbull t~middot rct1~j d- gtOY- - hO- irmiddot (bulldbull) plltmiddotmiddot- leemiddotmiddot JOu

1r1cbullmiddotn111f11ri ll1fbull fcrn to ~bull~I

Triin- GU

WAWMyenEIRitiRpoundWt 44 ZiAtillampampI

Exhibit C

Case 818-cv-01987-JLS

-KE

S

Docum

ent 50-1 F

iled 020519 P

age 33 of 57 P

age ID 1792

30

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 34 of 57 Page ID 1793

EXHIBIT D

Attachment A

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Type then hit enter to

bull bull bull bull bull bull bull

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----

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 35 of 57 Page ID 1794

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

infoaidnestcom (800) 555-1212

HOME

ABOUT US

SERVICES

FAQ

BLOG

CONTACT

HOME ABOUT US SERVICES FAQ BLOG CONTACT

1 of 6 462018 945 AM

31

Student Loan Forgiveness Loan Consolidation Student Loan Forgiveness

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 36 of 57 Page ID 1795

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

If you have Federal Student Loans yoursquore in the right place to get those loans reduced forgiven or completely discharged through our student loan forgiveness programs

Get your multiple Federal Student Loans consolidated into one forget about increasing interests and pay month to month at the lowest possible cost

We understand if yoursquore going through some hardship and thatrsquos why with us yoursquoll be able to make monthly payments based on your affordability for as low as $000 depending on your situation

2 of 6 462018 945 AM

32

Knowledge Base

Defaulted Student Loans

Wage Garnishment

Student Loan Rehabilitation

Income Based Repayment Plan

Deferment and Forbearance

Pay As You Earn Repayment Plan

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE Call 561)424-6053 today to go over your options

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 37 of 57 Page ID 1796

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

Our knowledge base is designed to provide information regarding some of the critical topics those with student loans must be aware of to be able to make educated decisions regarding their future

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

A wage garnishment is any legal procedure in which some portion of a personrsquos earnings is required to be withheld by an employer for the payment of a debt

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

With this program your payments change as your income changes and will not be longer than 25 years This is the ideal plan if you are in partial financial hardship Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard plan

Temporarily allowing you to postpone or reduce your federal student loan payments Postponing or reducing your payments may help you avoid default and future garnishments

Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard

3 of 6 462018 945 AM

33

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 38 of 57 Page ID 1797

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

4 of 6 462018 945 AM

34Attachment A

Testimonials

Latest News

Why 2016 Will Be a Big Year For Student Loans

Top Student Loan Refinancing Questions of 2015

Oba mas latest student loan plan

Things You Should Know About Public Service Loan Forgiveness

Recent Posts

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 39 of 57 Page ID 1798

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

5 of 6 462018 945 AM

35

About Us

Contact Info

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 40 of 57 Page ID 1799

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

pay-grandchild-studen

Why 2016 Will Be a Big Year For Student Loans

December 30 2015

12511110_1112367518

Top Student Loan Refinancing Questions of 2015

December 30 2015

We stand by our consultation and quote We are so sure and confident about our services and offers that they are all 100 money back guarantee risk free ndash if we donrsquot do what we promise yoursquoll get your money back

(800) 555-1212 AidnestStudenLoansgmailcom 18100 Von Karman Ave Suite 850 Irvine CA 92612

Futero SAS copy 2015 | Aidnestcom

6 of 6 462018 945

Exhibit D 36Attachment A

AM

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 41 of 57 Page ID 1800

EXHIBIT E

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 42 of 57 Page ID 1801

AIDNEST Let us help you through this national crisis

Call one of our specialists today

Forbearance amp Deferment If you are still in school and struggling to make payments on your student loans You may qualify

for Forbearance amp Deferment

Garnishment Prevention Federal law requires that the Department of Education or guarantee agency notifies you before they

begin garnishing your wages

Loan Forgiveness If you are a teacher public service worker or an individual with total and permanent disability you

httpaidnestcom[442018 115239 AM]

37Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 43 of 57 Page ID 1802

AIDNEST Let us help you through this national crisis

may qualify for this program

Consolidating Your Loans Consolidating your loans to one new loan under one lender may lower your payments and make

your life a bit more manageable

Affordable Payments If you are looking to lower your monthly payments then Income Based Repayment Plans may be

the correct choice for you

Learn more about our services

LEARN MORE

httpaidnestcom[442018 115239 AM]

38Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 44 of 57 Page ID 1803

AIDNEST Let us help you through this national crisis

Loan Forgiveness Programs Income Based Payments Student Loan Rehabilitation

Student Loan Consolidation

You may be eligible for

Loan Forgiveness Programs

In some cases individuals with Federal Student Loans may qualify to have a portion of the amount

owed to be forgiven

Get in touch with our professional team to find out which loan forgiveness program you qualify for and

how you can get rid of your unpaid student loan

L EARN MORE

httpaidnestcom[442018 115239 AM]

39Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 45 of 57 Page ID 1804

AIDNEST Let us help you through this national crisis

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE

Meet your Budget One of our advisers will help you meet your payment goals by using your budget and timeline to

determine the best plan available

httpaidnestcom[442018 115239 AM]

40Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 46 of 57 Page ID 1805

AIDNEST Let us help you through this national crisis

Simple Process We understand that lowering your payments alone can be difficult Our intuitive platform allows us

to keep the entire process simple

Customer Satisfaction We are committed to providing you with outstanding service only We look forward to working

with you

100 money back guarantee No Hassle Money Back Policy

httpaidnestcom[442018 115239 AM]

41Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 47 of 57 Page ID 1806

AIDNEST Let us help you through this national crisis

Lower your loan payments by getting in touch with one of our professionals

We design a customized repayment plan that will allow you to make payments based on your

monthly income family size and spending Get rid of the hassle of extensive paperwork and get the

help you deserve

What we can help you achieve a lower payment or lower rate

httpaidnestcom[442018 115239 AM]

42Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 48 of 57 Page ID 1807

AIDNEST Let us help you through this national crisis

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcom[442018 115239 AM]

43Exhibit E

httpaidnestcomservices[442018 115322 AM]

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 49 of 57 Page ID 1808

Services | AIDNEST Let us help you through this national crisis

INCOME BASED PAYMENTS

If you are suffering from a financial hardship you may be eligible for an

Income Based Payment In this repayment program you would have a

payment based on your income and family size The payment could be as

low as $000 per month with forgiveness at the end of 20-25 years

44

Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 50 of 57 Page ID 1809

L E ARN MORE

LOAN FORGIVENESS

If you have Federal Student Loans you may qualify for any of the student

loan forgiveness programs that are available to borrowers You may be

eligible for principal reduction loan forgiveness or a complete loan

discharge depending on your individual circumstance

L EARN MORE

PRIVATE STUDENT LOAN CONSOLIDATION

Much like refinancing a mortgage generally the biggest benefit of private

student loan consolidationstudent loan refinancing is a lower interest rate

httpaidnestcomservices[442018 115322 AM]

45Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 51 of 57 Page ID 1810

L E ARN MORE

(something federal consolidations do not offer)

STUDENT LOAN REHABILITATION

You can renew eligibility for new loans and grants and eliminate the loan

default by ldquorehabilitatingrdquo a defaulted loan

httpaidnestcomservices[442018 115322 AM]

46Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 52 of 57 Page ID 1811

CHE CK E L E G I B I L I T Y

WAGE GARNISHMENT

A wage garnishment is any legal procedure in which some portion of a

personrsquos earnings is required to be withheld by an employer for the

payment of a debt

L EARN MORE

With our fast friendly and professional services wersquoll be glad to help you get your student loans

reduced forgiven or completely discharged To this end wersquoll assist you in consolidating all your

student loans so yoursquoll have only one lender and yoursquoll start making one monthly payment Our

professionals will walk you through the best and most flexible repayment options and if itrsquos also

necessary varied deferment options and rehabilitation programs

httpaidnestcomservices[442018 115322 AM]

47Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 53 of 57 Page ID 1812

Services | AIDNEST Let us help you through this national crisis

Our CRM System

Our CRM is one of the most advanced in the industry and most importantly itrsquos linked directly to

the Department of Education (DOE) This keeps your personal and most confidential information

safe Furthermore because our CRM system is linked to the DOE our approval is 100 Through

our CRM we will be doing continuous monitoring of our process without losing sight of your

immediate needs ensuring that your case has the proper handling and most efficient process

httpaidnestcomservices[442018 115322 AM]

48Exhibit E

n

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 54 of 57 Page ID 1813

Services | AIDNEST Let us help you through this national crisis

R ECENT POSTS

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

ABOUT US

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcomservices[442018 115322 AM]

49Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 55 of 57 Page ID 1814

EXHIBIT F

s -

bullmiddot - ~ t ~ower Your Student Loan Pay~e~ts oday -- Students Helping Students Save Money

INCOME BASED PAJIIIJITPAIS

I C(gttoUC1 u~

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 56 of 57 Page ID 1815

X + C (D Not secure wwwstudoracom 0

CALL US NOW (85S) 978-S599 middot 1nfostudoracom

HOME SERVICES ABOUT US FAQ CONTACT US BLOC PRIVACY

Offering obligation and commitment free loan relief solutions

STUDENT LOAN FORGIVENESS INCOME BASED PAYMENTS LOAN CONSOLIDATION

We11 help you get your loans reduced forgiven o r Make monthly pdyments based on your affordability Get multiple Federal Student Loans consolidated into

discharged one low monthly payment

Talk to our experts concerning your

student loans

Studora is a pnvatefy owned company that helps consumers like you identify

government programs that fit your financial s1tuat1on Our loan experts will assist you in selecting the appropriate programs that WOltk with your income family size and

desired monthly payment We then prepare the appropriate documents for your review and submission All this f o r one low easy payment

Testimonials

Thank you f o r getting back to me quickly Youve been fabulous Thank you for the confirmation and for your help today Pass

during this whole process Is there a place I can go online that I this on to your sup that you were very professional and very

can leave a comment for your manager Youve made this Robert helpful and brought a sense of relief for me Thank you very

process so easy and answered every question my husband and I much and have a great rest of your day Kudos to you and your

have had teammoneywell spenL

Exhibit F 50

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 57 of 57 Page ID 1816

Services we offer

Stud ora offers document preparation services for all loan forgiveness consolidation and relief services to people who are unable to manage their finances Our mam aim is to

offer complete peace of mind to indiVidual unable to pay their student loan debt

we otter the folloWing document preparation services with complete professional assistance

amFinancial Review ffl Budget Planning

Toe first step to creating a flexible loan repayment plan is financial review we also help create a personal finance plan to ensure that you are able to

Our professmnals will look into your finances and design a custom manage your monthly budget in the most effective way This plan will keep

repayment plan that is affordable and easy to manage your spending to the minimum alloWing you to save more money for loan

repayment

Permanent Disability Forgiveness r-trTeacher Loan Forgiveness (5 You can get rid of your Federal Student Loan if you are permanently disabled Good news for teachers who are under the weight of a massiVe loan You can

now get $17 forgiven on your student loans

Public Service Loan Forgiveness Custom Debt Relief Plans

Want assistance with debt relief Get in touch with our experts who will help If you are a public service agent you can get rid of your loan after 120 days of design a loan repayment and relief plan for you based on your monthly

income and affordability payments

THERE ARE NO OBLIGATIONS OR COMMITMENTS

want to save thousands of dollars Fill out our form and get relief from your student loan for a more

peaceful tomorrow

Your Name

BiHHHi

Exhibit F 51

Attachment A

Page 19: JOSHUA S. MILLARD, BRIAN M. WELKE, pro hac vice · for which it has no legitimate claim. Noel is a Wyoming limited liability company that reported in a public document that its principal

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 19 of 57 Page ID 1778

2

3

E Award Plaintiff the costs of bringing this action as well as such other

and additional relief as the Court may determine to be just and proper

Dated February 5 2019

Respectfully submitted

ALDEN F ABBOTT General Counsel

JosaSMillard Brian M Welke middot Barbara Chun (Local Counsel) Attorneys for Plaintiff FEDERAL TRADE COMMISSION

4

5

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7

8

9

10

11

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22

23

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27

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Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 20 of 57 Page ID 1779

EXHIBIT A

Attachment A

Free Assessment

Our expercs will lt1ssPss you cun ent

swclent lo n program and decermn which progr ms are

avc11l bl rn yoL11 situation We wi I help you cl11cic1e which progr m r1

help you achieve your goals Call us today

Service Guarantee We are commmecl to 11-1 111g

CllStomers get low r rc1ces ancl monthly payments and we w1I

m ke the pror~ss se mless and s r11ghtforwc1rd ou wi ll be sansf1ed

with our service ml OLlr

cornmcmem to you success Thars ow gu~ ancee

Success Rate Ou1 96 ~ surcPss r a e s 11e of he

cop I a ings tn he industry Olr

process has beer tested nd Olli

succ ss r r~ prowbull~ tn t it works

We c n ll~lp yo reduce and -1111ph y our p ~ymP1 ts Call us today

FTC-AID-1

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 21 of 57 Page ID 1780

20

Exhibit A

ABOUT US

We can help you reduce and simplify your pay1ncnts Contact one of our specialists today for

a free evaluation

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We Have Been Featured In

FTC-AID-2

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 22 of 57 Page ID 1781

21

Exhibit A

SERVICES Wt w gtL

Loan Forgiveness Income Based Payments Loan Consol idation In some cases individuals with A period of financial hardship may You may be able to combine

Fede1middota1 Student Loans may qualify qualify you for an Income Based nultiple federal student loans into to have a portion of the amount Repayment Plan In many cases this one new loan w ith a lower more

owed may be forgiven This means means you pay nothing Unlike a affordable monthly payment Loan

your principal balnce coulcl be defe1 ment the term on your loan consolidation prngrams can l1elp

significantly reduced and you will continues to reduce while the plan is you qualify for additional programs not be expected to repay the in place Your term could reduce like loan forgiveness programs or

forgiven amount while you pay nothing Public Setvice Loan Forgiveness

a III

Private Sector Loan Forgiveness

If you work for a government

organization at a city state or

federa l level you may qualify for tle

PL1blic Service Loan Forgiveness

program To qualify your loans

must be cotisolidated into a specific

repayment plan The balance on

your federai student loans is

forgiven after 120 qualifying

bull C Permanent Disability

Forgivenness If your disability is expected to last

60 months or more you may qualify

for permanent disability forgiveness

Q1alifying for Permnent Disability

Forgiveness requires a visi t to your

doctor and individL1als enrolled in

the program are subject to three

years of post-discharge monitoring

Wage Garnishment Prevention

Federal law requires that the

Department of Education or a

gua1middotanty agency notify you before

111st1tuting wage garnishment You

have tl1e right to a hearing where

you can challenge the stated

amount owed and negotiate the

terms of the repayment scheclule

We can intervene on YOL1PflJl~1D-3

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 23 of 57 Page ID 1782

22

Exhibit A

payments have been made p1middotevent wage gampnishments

A FEW STATISTICS ABOUT STUDENT LOAN CRISIS

12 Trillion National Student Debt I he nitionil student loin debt is

now 17 trillion dollirs 1 trillion of

these are in federil student loans

Let us help you through this national

crisis Cill today for a free

evaluation

40 Million Students with Debt

In 7014 an estimated 40 million

current and former students were in

debt because of student loans If

you are one of the millions of people

struggling to pay student loans

Aiding Student Relief is here to help

$33000 Average Student Debt

The graduating class of 7014

average $33000 of student loan

debt per person Thats $3000 more

than the average in 2013 Dont be

one of the many Let Aiding Student

Relief advocate for you

Aiding Student Relief has helped cmrnllcss 1woplc reduce their student debt_ Their proven business

plan has led lo one of lhc highest s11cclSS raCs in the inltl11slly

John Standiford Associated

FTC-AID-4

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 24 of 57 Page ID 1783

23

Exhibit A

TESTIMONIALS

Til~nks to Aiding Student Rel ief Im middotI middotva ove1vvhelrnecl but Aiding The expemiddotts at l1icl i11g Student Rel ief

s1v ing $250 per month Strrd r~rt Relief expl~ inecl the were ther~ to help me when I process ancl rnacle everytl1ing cle11middot nelclecl 1t rw)s t

and sirnple

I Michael Ma 1in

Entrep e11eu1 Em iiy Jallo1 Ii Pa ul Ch is tia I1se11

Teacher Nurse

With so many programs I didnt middotconso lrclating my loans into one I love my Job but vith my high

know what was ng ht for me My monthly payment hs made life student loan payment was still

sruclent loan aclvsor walked me si1nple1 Now I can focus on 1Nhn bamiddotely getting by I don t kn ow what I

through my optio ns rnd now Imiddotn matters to me would hwe clone wthout Aiding

saving 54 I 11n1omh Stucie1middott Rel refmiddot

Ariel Hemiquez Sales co)SUltant

Stephani Seland-1 Small Busim~ss Owner

AJ 01en Museum Curator

RECENT NEWS

)lt)

o(l ttDrlTI -5

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 25 of 57 Page ID 1784

24

Exhibit A

Student Debt Crisis Business Latest Debt Collective Demands May be largely about smallest Student

borrnwers US News amp World Loan Crisis is fa frorn ove The Debt Collective is a group of Report-May 162015 last month Two new reports suggest the college students calling the Fedemiddotal Reserve Bank of New student loan crisis is easing them-se1ves the Corinthian York repor ced that stuclent loan somewhat as the economy Fifteen who are refusing to pay balances rose to 16 trillio n and improves but the crisis is far back their student loins As pa t that 113 per cent of that is in from ove the College Board of this effort the Debt Collective repo t~ tot31 borrowing fell by 8 has written an open lette to the pEbull1 cent between 2012-13 and Department of Education f l llJ 20 13-14 The organization

About Us 11 1 i~d1middot1r F th~~- h1~ ff t1middot~11middot=cl =i~=middott- 1middot __31middotmiddotIIgt middot bullmiddot11

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FTC-AID-6

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 26 of 57 Page ID 1785

25

Exhibit A

f - g+ in O) ~ PRIVACY POLICY

This privacy statement discloses the privacy practices for AidllII Student Relief Because Aiding Studen Relief wonts to demonstrate ts firm commlcmell to your

privacy Aiding Sudent Relief hes greed to disclose ls 1rifor111atlori g1thering and dlssem1n1t1on prct1cts Aidlns Studtrit Relief will notify you of

INFORMATION COLLECTION At-ID USE

Aiding Student Relief is the sole owner of the rformMlon collected on this site We will not sell shire or rent this information 10 others In way different from what Is

disclosed 1n this statement Aldln1 StudeM Relief collects 1nform111on throuah this site from our prospective end existing clients at several different poin on our web

site We use their contact Informii on to send information bout our company and to service exsMs accounts Users may optbullout of rece11ns future malllngs see the

cholceoptbullout section below Contect and Financial information that 1s collected Is used for verifying your name address and other informa1on as well as to boll you for

your use of our Gerv1ces using Information from third party sourcH Information about your computer hardwre and software Is automatically collected by Aiding

Student Relief and may be shared in asgregate with third parties whose services are used for traffic analysis purposes This Ir formation includes your IP address

browser type domain names access times and referring Web site addresses Ths information is no tied to personally Identifiable Information This 1nformatlor s used

by Aiding Student Relief to malMan no Improve the quality of the Hrvct and to senerae statistics resardlng use of he Aiding Student Relief site We use third party

services to bill for serlces and to provide other services like our Live Help chat We store the transcripts from these chats for customer service Improvement These

third party service providers are not permitted to use your infornon for any secondary purposes

Thank you and cheers

FTC-AID-7

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 27 of 57 Page ID 1786

26

Exhibit A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 28 of 57 Page ID 1787

EXHIBIT B

Attachment A

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AIDINGSTUDENTRELIEF

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27

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8

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28

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01 $2 301 $$3 ( Exhibit B

()(

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01( $2(301$$3( Exhibit B

29

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 32 of 57 Page ID 1791

EXHIBIT C

Attachment A

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Something awesome is coming soon We are buildin somethin ve cool Sta tuned and be at1ent Your atience will be well aid

~lbullrbullUiUffl We can help you reduce and simplify your payments

101 Loan For iveness

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Exhibit C

Case 818-cv-01987-JLS

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Docum

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iled 020519 P

age 33 of 57 P

age ID 1792

30

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 34 of 57 Page ID 1793

EXHIBIT D

Attachment A

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Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 35 of 57 Page ID 1794

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

infoaidnestcom (800) 555-1212

HOME

ABOUT US

SERVICES

FAQ

BLOG

CONTACT

HOME ABOUT US SERVICES FAQ BLOG CONTACT

1 of 6 462018 945 AM

31

Student Loan Forgiveness Loan Consolidation Student Loan Forgiveness

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 36 of 57 Page ID 1795

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

If you have Federal Student Loans yoursquore in the right place to get those loans reduced forgiven or completely discharged through our student loan forgiveness programs

Get your multiple Federal Student Loans consolidated into one forget about increasing interests and pay month to month at the lowest possible cost

We understand if yoursquore going through some hardship and thatrsquos why with us yoursquoll be able to make monthly payments based on your affordability for as low as $000 depending on your situation

2 of 6 462018 945 AM

32

Knowledge Base

Defaulted Student Loans

Wage Garnishment

Student Loan Rehabilitation

Income Based Repayment Plan

Deferment and Forbearance

Pay As You Earn Repayment Plan

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE Call 561)424-6053 today to go over your options

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 37 of 57 Page ID 1796

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

Our knowledge base is designed to provide information regarding some of the critical topics those with student loans must be aware of to be able to make educated decisions regarding their future

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

A wage garnishment is any legal procedure in which some portion of a personrsquos earnings is required to be withheld by an employer for the payment of a debt

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

With this program your payments change as your income changes and will not be longer than 25 years This is the ideal plan if you are in partial financial hardship Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard plan

Temporarily allowing you to postpone or reduce your federal student loan payments Postponing or reducing your payments may help you avoid default and future garnishments

Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard

3 of 6 462018 945 AM

33

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 38 of 57 Page ID 1797

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

4 of 6 462018 945 AM

34Attachment A

Testimonials

Latest News

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Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 39 of 57 Page ID 1798

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

5 of 6 462018 945 AM

35

About Us

Contact Info

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 40 of 57 Page ID 1799

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

pay-grandchild-studen

Why 2016 Will Be a Big Year For Student Loans

December 30 2015

12511110_1112367518

Top Student Loan Refinancing Questions of 2015

December 30 2015

We stand by our consultation and quote We are so sure and confident about our services and offers that they are all 100 money back guarantee risk free ndash if we donrsquot do what we promise yoursquoll get your money back

(800) 555-1212 AidnestStudenLoansgmailcom 18100 Von Karman Ave Suite 850 Irvine CA 92612

Futero SAS copy 2015 | Aidnestcom

6 of 6 462018 945

Exhibit D 36Attachment A

AM

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 41 of 57 Page ID 1800

EXHIBIT E

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 42 of 57 Page ID 1801

AIDNEST Let us help you through this national crisis

Call one of our specialists today

Forbearance amp Deferment If you are still in school and struggling to make payments on your student loans You may qualify

for Forbearance amp Deferment

Garnishment Prevention Federal law requires that the Department of Education or guarantee agency notifies you before they

begin garnishing your wages

Loan Forgiveness If you are a teacher public service worker or an individual with total and permanent disability you

httpaidnestcom[442018 115239 AM]

37Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 43 of 57 Page ID 1802

AIDNEST Let us help you through this national crisis

may qualify for this program

Consolidating Your Loans Consolidating your loans to one new loan under one lender may lower your payments and make

your life a bit more manageable

Affordable Payments If you are looking to lower your monthly payments then Income Based Repayment Plans may be

the correct choice for you

Learn more about our services

LEARN MORE

httpaidnestcom[442018 115239 AM]

38Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 44 of 57 Page ID 1803

AIDNEST Let us help you through this national crisis

Loan Forgiveness Programs Income Based Payments Student Loan Rehabilitation

Student Loan Consolidation

You may be eligible for

Loan Forgiveness Programs

In some cases individuals with Federal Student Loans may qualify to have a portion of the amount

owed to be forgiven

Get in touch with our professional team to find out which loan forgiveness program you qualify for and

how you can get rid of your unpaid student loan

L EARN MORE

httpaidnestcom[442018 115239 AM]

39Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 45 of 57 Page ID 1804

AIDNEST Let us help you through this national crisis

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE

Meet your Budget One of our advisers will help you meet your payment goals by using your budget and timeline to

determine the best plan available

httpaidnestcom[442018 115239 AM]

40Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 46 of 57 Page ID 1805

AIDNEST Let us help you through this national crisis

Simple Process We understand that lowering your payments alone can be difficult Our intuitive platform allows us

to keep the entire process simple

Customer Satisfaction We are committed to providing you with outstanding service only We look forward to working

with you

100 money back guarantee No Hassle Money Back Policy

httpaidnestcom[442018 115239 AM]

41Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 47 of 57 Page ID 1806

AIDNEST Let us help you through this national crisis

Lower your loan payments by getting in touch with one of our professionals

We design a customized repayment plan that will allow you to make payments based on your

monthly income family size and spending Get rid of the hassle of extensive paperwork and get the

help you deserve

What we can help you achieve a lower payment or lower rate

httpaidnestcom[442018 115239 AM]

42Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 48 of 57 Page ID 1807

AIDNEST Let us help you through this national crisis

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcom[442018 115239 AM]

43Exhibit E

httpaidnestcomservices[442018 115322 AM]

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 49 of 57 Page ID 1808

Services | AIDNEST Let us help you through this national crisis

INCOME BASED PAYMENTS

If you are suffering from a financial hardship you may be eligible for an

Income Based Payment In this repayment program you would have a

payment based on your income and family size The payment could be as

low as $000 per month with forgiveness at the end of 20-25 years

44

Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 50 of 57 Page ID 1809

L E ARN MORE

LOAN FORGIVENESS

If you have Federal Student Loans you may qualify for any of the student

loan forgiveness programs that are available to borrowers You may be

eligible for principal reduction loan forgiveness or a complete loan

discharge depending on your individual circumstance

L EARN MORE

PRIVATE STUDENT LOAN CONSOLIDATION

Much like refinancing a mortgage generally the biggest benefit of private

student loan consolidationstudent loan refinancing is a lower interest rate

httpaidnestcomservices[442018 115322 AM]

45Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 51 of 57 Page ID 1810

L E ARN MORE

(something federal consolidations do not offer)

STUDENT LOAN REHABILITATION

You can renew eligibility for new loans and grants and eliminate the loan

default by ldquorehabilitatingrdquo a defaulted loan

httpaidnestcomservices[442018 115322 AM]

46Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 52 of 57 Page ID 1811

CHE CK E L E G I B I L I T Y

WAGE GARNISHMENT

A wage garnishment is any legal procedure in which some portion of a

personrsquos earnings is required to be withheld by an employer for the

payment of a debt

L EARN MORE

With our fast friendly and professional services wersquoll be glad to help you get your student loans

reduced forgiven or completely discharged To this end wersquoll assist you in consolidating all your

student loans so yoursquoll have only one lender and yoursquoll start making one monthly payment Our

professionals will walk you through the best and most flexible repayment options and if itrsquos also

necessary varied deferment options and rehabilitation programs

httpaidnestcomservices[442018 115322 AM]

47Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 53 of 57 Page ID 1812

Services | AIDNEST Let us help you through this national crisis

Our CRM System

Our CRM is one of the most advanced in the industry and most importantly itrsquos linked directly to

the Department of Education (DOE) This keeps your personal and most confidential information

safe Furthermore because our CRM system is linked to the DOE our approval is 100 Through

our CRM we will be doing continuous monitoring of our process without losing sight of your

immediate needs ensuring that your case has the proper handling and most efficient process

httpaidnestcomservices[442018 115322 AM]

48Exhibit E

n

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 54 of 57 Page ID 1813

Services | AIDNEST Let us help you through this national crisis

R ECENT POSTS

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

ABOUT US

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcomservices[442018 115322 AM]

49Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 55 of 57 Page ID 1814

EXHIBIT F

s -

bullmiddot - ~ t ~ower Your Student Loan Pay~e~ts oday -- Students Helping Students Save Money

INCOME BASED PAJIIIJITPAIS

I C(gttoUC1 u~

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 56 of 57 Page ID 1815

X + C (D Not secure wwwstudoracom 0

CALL US NOW (85S) 978-S599 middot 1nfostudoracom

HOME SERVICES ABOUT US FAQ CONTACT US BLOC PRIVACY

Offering obligation and commitment free loan relief solutions

STUDENT LOAN FORGIVENESS INCOME BASED PAYMENTS LOAN CONSOLIDATION

We11 help you get your loans reduced forgiven o r Make monthly pdyments based on your affordability Get multiple Federal Student Loans consolidated into

discharged one low monthly payment

Talk to our experts concerning your

student loans

Studora is a pnvatefy owned company that helps consumers like you identify

government programs that fit your financial s1tuat1on Our loan experts will assist you in selecting the appropriate programs that WOltk with your income family size and

desired monthly payment We then prepare the appropriate documents for your review and submission All this f o r one low easy payment

Testimonials

Thank you f o r getting back to me quickly Youve been fabulous Thank you for the confirmation and for your help today Pass

during this whole process Is there a place I can go online that I this on to your sup that you were very professional and very

can leave a comment for your manager Youve made this Robert helpful and brought a sense of relief for me Thank you very

process so easy and answered every question my husband and I much and have a great rest of your day Kudos to you and your

have had teammoneywell spenL

Exhibit F 50

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 57 of 57 Page ID 1816

Services we offer

Stud ora offers document preparation services for all loan forgiveness consolidation and relief services to people who are unable to manage their finances Our mam aim is to

offer complete peace of mind to indiVidual unable to pay their student loan debt

we otter the folloWing document preparation services with complete professional assistance

amFinancial Review ffl Budget Planning

Toe first step to creating a flexible loan repayment plan is financial review we also help create a personal finance plan to ensure that you are able to

Our professmnals will look into your finances and design a custom manage your monthly budget in the most effective way This plan will keep

repayment plan that is affordable and easy to manage your spending to the minimum alloWing you to save more money for loan

repayment

Permanent Disability Forgiveness r-trTeacher Loan Forgiveness (5 You can get rid of your Federal Student Loan if you are permanently disabled Good news for teachers who are under the weight of a massiVe loan You can

now get $17 forgiven on your student loans

Public Service Loan Forgiveness Custom Debt Relief Plans

Want assistance with debt relief Get in touch with our experts who will help If you are a public service agent you can get rid of your loan after 120 days of design a loan repayment and relief plan for you based on your monthly

income and affordability payments

THERE ARE NO OBLIGATIONS OR COMMITMENTS

want to save thousands of dollars Fill out our form and get relief from your student loan for a more

peaceful tomorrow

Your Name

BiHHHi

Exhibit F 51

Attachment A

Page 20: JOSHUA S. MILLARD, BRIAN M. WELKE, pro hac vice · for which it has no legitimate claim. Noel is a Wyoming limited liability company that reported in a public document that its principal

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 20 of 57 Page ID 1779

EXHIBIT A

Attachment A

Free Assessment

Our expercs will lt1ssPss you cun ent

swclent lo n program and decermn which progr ms are

avc11l bl rn yoL11 situation We wi I help you cl11cic1e which progr m r1

help you achieve your goals Call us today

Service Guarantee We are commmecl to 11-1 111g

CllStomers get low r rc1ces ancl monthly payments and we w1I

m ke the pror~ss se mless and s r11ghtforwc1rd ou wi ll be sansf1ed

with our service ml OLlr

cornmcmem to you success Thars ow gu~ ancee

Success Rate Ou1 96 ~ surcPss r a e s 11e of he

cop I a ings tn he industry Olr

process has beer tested nd Olli

succ ss r r~ prowbull~ tn t it works

We c n ll~lp yo reduce and -1111ph y our p ~ymP1 ts Call us today

FTC-AID-1

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 21 of 57 Page ID 1780

20

Exhibit A

ABOUT US

We can help you reduce and simplify your pay1ncnts Contact one of our specialists today for

a free evaluation

111middot 1_I 1

101

t I 11111 I I

Itbull 11

Ill fl I I

bull ~ 0 I

What Makes Us Great fa1(li1-_~ tur1ent ~e11ef 11as a taf- o~middot tt a middotel elt1)rns bullJn st1ncb110

1middot1ep yriJ Tibullmiddotest fi 1e-ndly f3ce~ 113ve eirej e1tc-nsve1yr =inj ire

fanih1~1 bull11iu1 ti~e nul~nce~ cfscrvern rrent Cdid p11vate stucre11

l1J1ns Th~y viill u~e Ui5 epe tise o loik jUl fJ ycur ~Je~t

i(tres~- f)LH ~U(CtS~ ~HE 1h-~ I lSllt of i_r middotDff ancl iur

C ur ~r_(J~l 1o~w- JCl11~crs f(middotil) 3 00Vtli ~tJegy o r ~dUC2 011i

a1r1plfy yliur- - _Je1middott middotcar payr1t11s 1) Asstrnlins Itle ~atl1t1

2) R~~ear c1-1ng Our st~lff wmiddoti11 (lrJUi~oleaerick ]ll fnfcnTnati(-n befort dtmiddoteJPlr~ t tne ri~n 3) rnnk1middotgbullle i_i1 i e~ear (rr i~ ormiddot1 1 1 etc 1Ne

irvi-s t1ga~ii 111 ps~ib le a~irst 1n(t aptlbull~n 4) 1Nr1 ting VVF p1 eiv lii J 11 iUen u tt-igy IJefore vie Uke ut1c-1l i)ecius~ you d-ese11e 11) undi r~~anci

Lhe pr 1cer S) ~ev1sing Al)ng ~r 1udent Relief 1- 1otT11111tt bull) ti) ci e1H1ve ut-l-~n~-l)O c111 i ri 3 Vbulle -~11 leave n1) sti bull1e u11t111 neltl tecause middot~ve

11~1ve your be~ i1~ t~rest 1t l1ein 6) Si~tcl11ng Our note- =1nd r~c)1 ~ ~1 e thorou~ll ln(I pru1ile 1 ceJ1 po cri1~ 1)f vo111 ~1tuJticn s) iny if-oi

~xpe1 t- 01 eou pped to s~1ty1J_J bullVi r you1 c si- 7) De-gn1ng _ fe ~1 t 1nelt--1- f1ts ti 1middotV 1middotid de~ 1middot1 1 st1 iegy to fit ou 1 1_i dque jtct1in so

011 c111 i Jle y1)u1 1vv1middot1 per feet -ut1e-s ~~0 1 v

1bullVlly 1100~e At(J1n~ Sltl(ltnt Fie11e7) (i1_d aclol~Or~ bull -ii~ (1Ualiftel lci ~~~ISt~h 1noie ype-s middotif JS~iSi_ance u~211 Cd ( (11)itXS i1 jG(l1~t) to ti-tgt

p ~n~ 1not con1p n1es can 11i1p bullbullllh ve )t ~ ~qu1pptCI to bull-bullGr k 1bullv1t1middot1 r~ 11t-2 [uo emiddot 1 lc1 r1s ~~nCI cn even iner-1ne frmiddot tt1e c ~e of 1l~e

~1lt ntslmiddoturelt A1cl1rg Sudent Fie1ef 1middot cis mmiddote to )fe 11d we offe1 t with middotmiddot1eltbullbe 1es nI 3 rncney lock guMai-itee

We Have Been Featured In

FTC-AID-2

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 22 of 57 Page ID 1781

21

Exhibit A

SERVICES Wt w gtL

Loan Forgiveness Income Based Payments Loan Consol idation In some cases individuals with A period of financial hardship may You may be able to combine

Fede1middota1 Student Loans may qualify qualify you for an Income Based nultiple federal student loans into to have a portion of the amount Repayment Plan In many cases this one new loan w ith a lower more

owed may be forgiven This means means you pay nothing Unlike a affordable monthly payment Loan

your principal balnce coulcl be defe1 ment the term on your loan consolidation prngrams can l1elp

significantly reduced and you will continues to reduce while the plan is you qualify for additional programs not be expected to repay the in place Your term could reduce like loan forgiveness programs or

forgiven amount while you pay nothing Public Setvice Loan Forgiveness

a III

Private Sector Loan Forgiveness

If you work for a government

organization at a city state or

federa l level you may qualify for tle

PL1blic Service Loan Forgiveness

program To qualify your loans

must be cotisolidated into a specific

repayment plan The balance on

your federai student loans is

forgiven after 120 qualifying

bull C Permanent Disability

Forgivenness If your disability is expected to last

60 months or more you may qualify

for permanent disability forgiveness

Q1alifying for Permnent Disability

Forgiveness requires a visi t to your

doctor and individL1als enrolled in

the program are subject to three

years of post-discharge monitoring

Wage Garnishment Prevention

Federal law requires that the

Department of Education or a

gua1middotanty agency notify you before

111st1tuting wage garnishment You

have tl1e right to a hearing where

you can challenge the stated

amount owed and negotiate the

terms of the repayment scheclule

We can intervene on YOL1PflJl~1D-3

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 23 of 57 Page ID 1782

22

Exhibit A

payments have been made p1middotevent wage gampnishments

A FEW STATISTICS ABOUT STUDENT LOAN CRISIS

12 Trillion National Student Debt I he nitionil student loin debt is

now 17 trillion dollirs 1 trillion of

these are in federil student loans

Let us help you through this national

crisis Cill today for a free

evaluation

40 Million Students with Debt

In 7014 an estimated 40 million

current and former students were in

debt because of student loans If

you are one of the millions of people

struggling to pay student loans

Aiding Student Relief is here to help

$33000 Average Student Debt

The graduating class of 7014

average $33000 of student loan

debt per person Thats $3000 more

than the average in 2013 Dont be

one of the many Let Aiding Student

Relief advocate for you

Aiding Student Relief has helped cmrnllcss 1woplc reduce their student debt_ Their proven business

plan has led lo one of lhc highest s11cclSS raCs in the inltl11slly

John Standiford Associated

FTC-AID-4

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 24 of 57 Page ID 1783

23

Exhibit A

TESTIMONIALS

Til~nks to Aiding Student Rel ief Im middotI middotva ove1vvhelrnecl but Aiding The expemiddotts at l1icl i11g Student Rel ief

s1v ing $250 per month Strrd r~rt Relief expl~ inecl the were ther~ to help me when I process ancl rnacle everytl1ing cle11middot nelclecl 1t rw)s t

and sirnple

I Michael Ma 1in

Entrep e11eu1 Em iiy Jallo1 Ii Pa ul Ch is tia I1se11

Teacher Nurse

With so many programs I didnt middotconso lrclating my loans into one I love my Job but vith my high

know what was ng ht for me My monthly payment hs made life student loan payment was still

sruclent loan aclvsor walked me si1nple1 Now I can focus on 1Nhn bamiddotely getting by I don t kn ow what I

through my optio ns rnd now Imiddotn matters to me would hwe clone wthout Aiding

saving 54 I 11n1omh Stucie1middott Rel refmiddot

Ariel Hemiquez Sales co)SUltant

Stephani Seland-1 Small Busim~ss Owner

AJ 01en Museum Curator

RECENT NEWS

)lt)

o(l ttDrlTI -5

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 25 of 57 Page ID 1784

24

Exhibit A

Student Debt Crisis Business Latest Debt Collective Demands May be largely about smallest Student

borrnwers US News amp World Loan Crisis is fa frorn ove The Debt Collective is a group of Report-May 162015 last month Two new reports suggest the college students calling the Fedemiddotal Reserve Bank of New student loan crisis is easing them-se1ves the Corinthian York repor ced that stuclent loan somewhat as the economy Fifteen who are refusing to pay balances rose to 16 trillio n and improves but the crisis is far back their student loins As pa t that 113 per cent of that is in from ove the College Board of this effort the Debt Collective repo t~ tot31 borrowing fell by 8 has written an open lette to the pEbull1 cent between 2012-13 and Department of Education f l llJ 20 13-14 The organization

About Us 11 1 i~d1middot1r F th~~- h1~ ff t1middot~11middot=cl =i~=middott- 1middot __31middotmiddotIIgt middot bullmiddot11

middot- I ( )ntir il t l~i -r_il fr~~

Address bull middot tc1ltj-1r_ =i ~

middot l t1~t 1middot1 fcJ middot~_1 1 I l11 - Hbull 1 tr

~t (~~ 1 12bull~11 T 1 1- - 8555105400

FTC-AID-6

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 26 of 57 Page ID 1785

25

Exhibit A

f - g+ in O) ~ PRIVACY POLICY

This privacy statement discloses the privacy practices for AidllII Student Relief Because Aiding Studen Relief wonts to demonstrate ts firm commlcmell to your

privacy Aiding Sudent Relief hes greed to disclose ls 1rifor111atlori g1thering and dlssem1n1t1on prct1cts Aidlns Studtrit Relief will notify you of

INFORMATION COLLECTION At-ID USE

Aiding Student Relief is the sole owner of the rformMlon collected on this site We will not sell shire or rent this information 10 others In way different from what Is

disclosed 1n this statement Aldln1 StudeM Relief collects 1nform111on throuah this site from our prospective end existing clients at several different poin on our web

site We use their contact Informii on to send information bout our company and to service exsMs accounts Users may optbullout of rece11ns future malllngs see the

cholceoptbullout section below Contect and Financial information that 1s collected Is used for verifying your name address and other informa1on as well as to boll you for

your use of our Gerv1ces using Information from third party sourcH Information about your computer hardwre and software Is automatically collected by Aiding

Student Relief and may be shared in asgregate with third parties whose services are used for traffic analysis purposes This Ir formation includes your IP address

browser type domain names access times and referring Web site addresses Ths information is no tied to personally Identifiable Information This 1nformatlor s used

by Aiding Student Relief to malMan no Improve the quality of the Hrvct and to senerae statistics resardlng use of he Aiding Student Relief site We use third party

services to bill for serlces and to provide other services like our Live Help chat We store the transcripts from these chats for customer service Improvement These

third party service providers are not permitted to use your infornon for any secondary purposes

Thank you and cheers

FTC-AID-7

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 27 of 57 Page ID 1786

26

Exhibit A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 28 of 57 Page ID 1787

EXHIBIT B

Attachment A

((

z | ~

AIDINGSTUDENTRELIEF

bull bull bull bull bull

13 deg $ $ampdegdeg deg() ˝ amp $$deg( + -+Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 29 of 57 Page ID 1788

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4556789fADlt=gtA9BCAD

DZgtA=EFGHIJFKLMNOPFQOGFHIQRSTLKSUMMNOPLHMTFIVRWXHKKNIFNUNOPRLFGSHKSRVRVNQ

f e=klHMW

9SI]UQMSNSOQOHHPFK YaSTHHVVJFMHcVGNOJVHHFKKPSUHMLIUOQN_PL[KSVFGJPRSDTHRFPLIP=SNDC==GFdFIP9VaNHQTWSRPbHF_PSKSVNMPMHNIO XNNIIFRKNF7IKSQQMHFNDVPOS9IAeTHPdKSUMMFNKHONP 8aF_KSNVPHTNIMNR[POVFgNPTHLNHIgtMFI YTFHIdFFI D9aHVR_KNKHFHIWIQOTHIQbFFP

lt=Dkgt=L]oHUKMMH ihTFNIORI THHVPRFMVKgtNJ_NFFbIVSJI]IFjdGGVNNN lt=TFKPPNF 9DaFGmVHPGRJMFNNQOSGnPFFTNLUNHPMIMTFVNJOKMIWV

27

]UMNOHPFRKNVSHKKISIRWRrGZNJONgtNjTHKHMI=cQgtORHVPKSOUMddUNKSPIdspNVPNq_ lt=gtBTHFHPb=HFILGFHMt DTFuFIUVFRPNTFIMINVWOPRVOQFIV sFQFPHKKH vaIPNFVcSyOFSPRFMRNVOJH_gtVFDVUJAN9FPwFuVFJLFHMP_VTFFdSIIVdNHUPxI=DQSROJGASHIVdDSNMINONPPaHdOHdPFHRIWVFFHdFIGM˙ 01 $2 301 $$3 ( Exhibit B

8

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676EBCEDK5ltAC]5EF_5665E7gt5lt7aFb688E588lt76B5E6F8EBAC78lt76cdddefghijhggklmknmopqprpopst u

13 deg $ $ampdegdeg degˇ amp $$deg + -+Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 30 of 57 Page ID 1789 () ( vPSZwPxyYTUZUWWzxPyxSWMZWPU|SWUWYZ~YTY~QSWbullYXRwU~UxSdaggerXQ~UZXvPSZWSOVQSYNOXPRSTUSDaggerPxXYPZPNXRUSPQZXPbullU~SOhellipUNPxyYTUZmdash zUxSZUZXndashYWShellipYYXOwPxyYTUZUWWMNOPQx~YWShellipYYXOYWUƒDaggerU|XU~XPSWXfrasllsaquoPZXRWPxPxUOPQSOVQSYNONPxDaggerUxSZUZX~YWShellipYYXONPxyYTUZUWWmdash

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28

Attachment A

01 $2 301 $$3 ( Exhibit B

()(

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01( $2(301$$3( Exhibit B

29

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 32 of 57 Page ID 1791

EXHIBIT C

Attachment A

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~lbullrbullUiUffl We can help you reduce and simplify your payments

101 Loan For iveness

1~u 0 (middottmiddotbullmiddotmiddot1 1~=I -- _~

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~ Income Based Pa ents

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Exhibit C

Case 818-cv-01987-JLS

-KE

S

Docum

ent 50-1 F

iled 020519 P

age 33 of 57 P

age ID 1792

30

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 34 of 57 Page ID 1793

EXHIBIT D

Attachment A

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bull bull bull bull bull bull bull

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Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 35 of 57 Page ID 1794

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

infoaidnestcom (800) 555-1212

HOME

ABOUT US

SERVICES

FAQ

BLOG

CONTACT

HOME ABOUT US SERVICES FAQ BLOG CONTACT

1 of 6 462018 945 AM

31

Student Loan Forgiveness Loan Consolidation Student Loan Forgiveness

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 36 of 57 Page ID 1795

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

If you have Federal Student Loans yoursquore in the right place to get those loans reduced forgiven or completely discharged through our student loan forgiveness programs

Get your multiple Federal Student Loans consolidated into one forget about increasing interests and pay month to month at the lowest possible cost

We understand if yoursquore going through some hardship and thatrsquos why with us yoursquoll be able to make monthly payments based on your affordability for as low as $000 depending on your situation

2 of 6 462018 945 AM

32

Knowledge Base

Defaulted Student Loans

Wage Garnishment

Student Loan Rehabilitation

Income Based Repayment Plan

Deferment and Forbearance

Pay As You Earn Repayment Plan

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE Call 561)424-6053 today to go over your options

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 37 of 57 Page ID 1796

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

Our knowledge base is designed to provide information regarding some of the critical topics those with student loans must be aware of to be able to make educated decisions regarding their future

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

A wage garnishment is any legal procedure in which some portion of a personrsquos earnings is required to be withheld by an employer for the payment of a debt

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

With this program your payments change as your income changes and will not be longer than 25 years This is the ideal plan if you are in partial financial hardship Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard plan

Temporarily allowing you to postpone or reduce your federal student loan payments Postponing or reducing your payments may help you avoid default and future garnishments

Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard

3 of 6 462018 945 AM

33

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 38 of 57 Page ID 1797

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

4 of 6 462018 945 AM

34Attachment A

Testimonials

Latest News

Why 2016 Will Be a Big Year For Student Loans

Top Student Loan Refinancing Questions of 2015

Oba mas latest student loan plan

Things You Should Know About Public Service Loan Forgiveness

Recent Posts

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 39 of 57 Page ID 1798

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

5 of 6 462018 945 AM

35

About Us

Contact Info

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 40 of 57 Page ID 1799

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

pay-grandchild-studen

Why 2016 Will Be a Big Year For Student Loans

December 30 2015

12511110_1112367518

Top Student Loan Refinancing Questions of 2015

December 30 2015

We stand by our consultation and quote We are so sure and confident about our services and offers that they are all 100 money back guarantee risk free ndash if we donrsquot do what we promise yoursquoll get your money back

(800) 555-1212 AidnestStudenLoansgmailcom 18100 Von Karman Ave Suite 850 Irvine CA 92612

Futero SAS copy 2015 | Aidnestcom

6 of 6 462018 945

Exhibit D 36Attachment A

AM

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 41 of 57 Page ID 1800

EXHIBIT E

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 42 of 57 Page ID 1801

AIDNEST Let us help you through this national crisis

Call one of our specialists today

Forbearance amp Deferment If you are still in school and struggling to make payments on your student loans You may qualify

for Forbearance amp Deferment

Garnishment Prevention Federal law requires that the Department of Education or guarantee agency notifies you before they

begin garnishing your wages

Loan Forgiveness If you are a teacher public service worker or an individual with total and permanent disability you

httpaidnestcom[442018 115239 AM]

37Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 43 of 57 Page ID 1802

AIDNEST Let us help you through this national crisis

may qualify for this program

Consolidating Your Loans Consolidating your loans to one new loan under one lender may lower your payments and make

your life a bit more manageable

Affordable Payments If you are looking to lower your monthly payments then Income Based Repayment Plans may be

the correct choice for you

Learn more about our services

LEARN MORE

httpaidnestcom[442018 115239 AM]

38Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 44 of 57 Page ID 1803

AIDNEST Let us help you through this national crisis

Loan Forgiveness Programs Income Based Payments Student Loan Rehabilitation

Student Loan Consolidation

You may be eligible for

Loan Forgiveness Programs

In some cases individuals with Federal Student Loans may qualify to have a portion of the amount

owed to be forgiven

Get in touch with our professional team to find out which loan forgiveness program you qualify for and

how you can get rid of your unpaid student loan

L EARN MORE

httpaidnestcom[442018 115239 AM]

39Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 45 of 57 Page ID 1804

AIDNEST Let us help you through this national crisis

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE

Meet your Budget One of our advisers will help you meet your payment goals by using your budget and timeline to

determine the best plan available

httpaidnestcom[442018 115239 AM]

40Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 46 of 57 Page ID 1805

AIDNEST Let us help you through this national crisis

Simple Process We understand that lowering your payments alone can be difficult Our intuitive platform allows us

to keep the entire process simple

Customer Satisfaction We are committed to providing you with outstanding service only We look forward to working

with you

100 money back guarantee No Hassle Money Back Policy

httpaidnestcom[442018 115239 AM]

41Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 47 of 57 Page ID 1806

AIDNEST Let us help you through this national crisis

Lower your loan payments by getting in touch with one of our professionals

We design a customized repayment plan that will allow you to make payments based on your

monthly income family size and spending Get rid of the hassle of extensive paperwork and get the

help you deserve

What we can help you achieve a lower payment or lower rate

httpaidnestcom[442018 115239 AM]

42Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 48 of 57 Page ID 1807

AIDNEST Let us help you through this national crisis

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcom[442018 115239 AM]

43Exhibit E

httpaidnestcomservices[442018 115322 AM]

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 49 of 57 Page ID 1808

Services | AIDNEST Let us help you through this national crisis

INCOME BASED PAYMENTS

If you are suffering from a financial hardship you may be eligible for an

Income Based Payment In this repayment program you would have a

payment based on your income and family size The payment could be as

low as $000 per month with forgiveness at the end of 20-25 years

44

Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 50 of 57 Page ID 1809

L E ARN MORE

LOAN FORGIVENESS

If you have Federal Student Loans you may qualify for any of the student

loan forgiveness programs that are available to borrowers You may be

eligible for principal reduction loan forgiveness or a complete loan

discharge depending on your individual circumstance

L EARN MORE

PRIVATE STUDENT LOAN CONSOLIDATION

Much like refinancing a mortgage generally the biggest benefit of private

student loan consolidationstudent loan refinancing is a lower interest rate

httpaidnestcomservices[442018 115322 AM]

45Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 51 of 57 Page ID 1810

L E ARN MORE

(something federal consolidations do not offer)

STUDENT LOAN REHABILITATION

You can renew eligibility for new loans and grants and eliminate the loan

default by ldquorehabilitatingrdquo a defaulted loan

httpaidnestcomservices[442018 115322 AM]

46Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 52 of 57 Page ID 1811

CHE CK E L E G I B I L I T Y

WAGE GARNISHMENT

A wage garnishment is any legal procedure in which some portion of a

personrsquos earnings is required to be withheld by an employer for the

payment of a debt

L EARN MORE

With our fast friendly and professional services wersquoll be glad to help you get your student loans

reduced forgiven or completely discharged To this end wersquoll assist you in consolidating all your

student loans so yoursquoll have only one lender and yoursquoll start making one monthly payment Our

professionals will walk you through the best and most flexible repayment options and if itrsquos also

necessary varied deferment options and rehabilitation programs

httpaidnestcomservices[442018 115322 AM]

47Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 53 of 57 Page ID 1812

Services | AIDNEST Let us help you through this national crisis

Our CRM System

Our CRM is one of the most advanced in the industry and most importantly itrsquos linked directly to

the Department of Education (DOE) This keeps your personal and most confidential information

safe Furthermore because our CRM system is linked to the DOE our approval is 100 Through

our CRM we will be doing continuous monitoring of our process without losing sight of your

immediate needs ensuring that your case has the proper handling and most efficient process

httpaidnestcomservices[442018 115322 AM]

48Exhibit E

n

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 54 of 57 Page ID 1813

Services | AIDNEST Let us help you through this national crisis

R ECENT POSTS

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

ABOUT US

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcomservices[442018 115322 AM]

49Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 55 of 57 Page ID 1814

EXHIBIT F

s -

bullmiddot - ~ t ~ower Your Student Loan Pay~e~ts oday -- Students Helping Students Save Money

INCOME BASED PAJIIIJITPAIS

I C(gttoUC1 u~

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 56 of 57 Page ID 1815

X + C (D Not secure wwwstudoracom 0

CALL US NOW (85S) 978-S599 middot 1nfostudoracom

HOME SERVICES ABOUT US FAQ CONTACT US BLOC PRIVACY

Offering obligation and commitment free loan relief solutions

STUDENT LOAN FORGIVENESS INCOME BASED PAYMENTS LOAN CONSOLIDATION

We11 help you get your loans reduced forgiven o r Make monthly pdyments based on your affordability Get multiple Federal Student Loans consolidated into

discharged one low monthly payment

Talk to our experts concerning your

student loans

Studora is a pnvatefy owned company that helps consumers like you identify

government programs that fit your financial s1tuat1on Our loan experts will assist you in selecting the appropriate programs that WOltk with your income family size and

desired monthly payment We then prepare the appropriate documents for your review and submission All this f o r one low easy payment

Testimonials

Thank you f o r getting back to me quickly Youve been fabulous Thank you for the confirmation and for your help today Pass

during this whole process Is there a place I can go online that I this on to your sup that you were very professional and very

can leave a comment for your manager Youve made this Robert helpful and brought a sense of relief for me Thank you very

process so easy and answered every question my husband and I much and have a great rest of your day Kudos to you and your

have had teammoneywell spenL

Exhibit F 50

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 57 of 57 Page ID 1816

Services we offer

Stud ora offers document preparation services for all loan forgiveness consolidation and relief services to people who are unable to manage their finances Our mam aim is to

offer complete peace of mind to indiVidual unable to pay their student loan debt

we otter the folloWing document preparation services with complete professional assistance

amFinancial Review ffl Budget Planning

Toe first step to creating a flexible loan repayment plan is financial review we also help create a personal finance plan to ensure that you are able to

Our professmnals will look into your finances and design a custom manage your monthly budget in the most effective way This plan will keep

repayment plan that is affordable and easy to manage your spending to the minimum alloWing you to save more money for loan

repayment

Permanent Disability Forgiveness r-trTeacher Loan Forgiveness (5 You can get rid of your Federal Student Loan if you are permanently disabled Good news for teachers who are under the weight of a massiVe loan You can

now get $17 forgiven on your student loans

Public Service Loan Forgiveness Custom Debt Relief Plans

Want assistance with debt relief Get in touch with our experts who will help If you are a public service agent you can get rid of your loan after 120 days of design a loan repayment and relief plan for you based on your monthly

income and affordability payments

THERE ARE NO OBLIGATIONS OR COMMITMENTS

want to save thousands of dollars Fill out our form and get relief from your student loan for a more

peaceful tomorrow

Your Name

BiHHHi

Exhibit F 51

Attachment A

Page 21: JOSHUA S. MILLARD, BRIAN M. WELKE, pro hac vice · for which it has no legitimate claim. Noel is a Wyoming limited liability company that reported in a public document that its principal

Free Assessment

Our expercs will lt1ssPss you cun ent

swclent lo n program and decermn which progr ms are

avc11l bl rn yoL11 situation We wi I help you cl11cic1e which progr m r1

help you achieve your goals Call us today

Service Guarantee We are commmecl to 11-1 111g

CllStomers get low r rc1ces ancl monthly payments and we w1I

m ke the pror~ss se mless and s r11ghtforwc1rd ou wi ll be sansf1ed

with our service ml OLlr

cornmcmem to you success Thars ow gu~ ancee

Success Rate Ou1 96 ~ surcPss r a e s 11e of he

cop I a ings tn he industry Olr

process has beer tested nd Olli

succ ss r r~ prowbull~ tn t it works

We c n ll~lp yo reduce and -1111ph y our p ~ymP1 ts Call us today

FTC-AID-1

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 21 of 57 Page ID 1780

20

Exhibit A

ABOUT US

We can help you reduce and simplify your pay1ncnts Contact one of our specialists today for

a free evaluation

111middot 1_I 1

101

t I 11111 I I

Itbull 11

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bull ~ 0 I

What Makes Us Great fa1(li1-_~ tur1ent ~e11ef 11as a taf- o~middot tt a middotel elt1)rns bullJn st1ncb110

1middot1ep yriJ Tibullmiddotest fi 1e-ndly f3ce~ 113ve eirej e1tc-nsve1yr =inj ire

fanih1~1 bull11iu1 ti~e nul~nce~ cfscrvern rrent Cdid p11vate stucre11

l1J1ns Th~y viill u~e Ui5 epe tise o loik jUl fJ ycur ~Je~t

i(tres~- f)LH ~U(CtS~ ~HE 1h-~ I lSllt of i_r middotDff ancl iur

C ur ~r_(J~l 1o~w- JCl11~crs f(middotil) 3 00Vtli ~tJegy o r ~dUC2 011i

a1r1plfy yliur- - _Je1middott middotcar payr1t11s 1) Asstrnlins Itle ~atl1t1

2) R~~ear c1-1ng Our st~lff wmiddoti11 (lrJUi~oleaerick ]ll fnfcnTnati(-n befort dtmiddoteJPlr~ t tne ri~n 3) rnnk1middotgbullle i_i1 i e~ear (rr i~ ormiddot1 1 1 etc 1Ne

irvi-s t1ga~ii 111 ps~ib le a~irst 1n(t aptlbull~n 4) 1Nr1 ting VVF p1 eiv lii J 11 iUen u tt-igy IJefore vie Uke ut1c-1l i)ecius~ you d-ese11e 11) undi r~~anci

Lhe pr 1cer S) ~ev1sing Al)ng ~r 1udent Relief 1- 1otT11111tt bull) ti) ci e1H1ve ut-l-~n~-l)O c111 i ri 3 Vbulle -~11 leave n1) sti bull1e u11t111 neltl tecause middot~ve

11~1ve your be~ i1~ t~rest 1t l1ein 6) Si~tcl11ng Our note- =1nd r~c)1 ~ ~1 e thorou~ll ln(I pru1ile 1 ceJ1 po cri1~ 1)f vo111 ~1tuJticn s) iny if-oi

~xpe1 t- 01 eou pped to s~1ty1J_J bullVi r you1 c si- 7) De-gn1ng _ fe ~1 t 1nelt--1- f1ts ti 1middotV 1middotid de~ 1middot1 1 st1 iegy to fit ou 1 1_i dque jtct1in so

011 c111 i Jle y1)u1 1vv1middot1 per feet -ut1e-s ~~0 1 v

1bullVlly 1100~e At(J1n~ Sltl(ltnt Fie11e7) (i1_d aclol~Or~ bull -ii~ (1Ualiftel lci ~~~ISt~h 1noie ype-s middotif JS~iSi_ance u~211 Cd ( (11)itXS i1 jG(l1~t) to ti-tgt

p ~n~ 1not con1p n1es can 11i1p bullbullllh ve )t ~ ~qu1pptCI to bull-bullGr k 1bullv1t1middot1 r~ 11t-2 [uo emiddot 1 lc1 r1s ~~nCI cn even iner-1ne frmiddot tt1e c ~e of 1l~e

~1lt ntslmiddoturelt A1cl1rg Sudent Fie1ef 1middot cis mmiddote to )fe 11d we offe1 t with middotmiddot1eltbullbe 1es nI 3 rncney lock guMai-itee

We Have Been Featured In

FTC-AID-2

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 22 of 57 Page ID 1781

21

Exhibit A

SERVICES Wt w gtL

Loan Forgiveness Income Based Payments Loan Consol idation In some cases individuals with A period of financial hardship may You may be able to combine

Fede1middota1 Student Loans may qualify qualify you for an Income Based nultiple federal student loans into to have a portion of the amount Repayment Plan In many cases this one new loan w ith a lower more

owed may be forgiven This means means you pay nothing Unlike a affordable monthly payment Loan

your principal balnce coulcl be defe1 ment the term on your loan consolidation prngrams can l1elp

significantly reduced and you will continues to reduce while the plan is you qualify for additional programs not be expected to repay the in place Your term could reduce like loan forgiveness programs or

forgiven amount while you pay nothing Public Setvice Loan Forgiveness

a III

Private Sector Loan Forgiveness

If you work for a government

organization at a city state or

federa l level you may qualify for tle

PL1blic Service Loan Forgiveness

program To qualify your loans

must be cotisolidated into a specific

repayment plan The balance on

your federai student loans is

forgiven after 120 qualifying

bull C Permanent Disability

Forgivenness If your disability is expected to last

60 months or more you may qualify

for permanent disability forgiveness

Q1alifying for Permnent Disability

Forgiveness requires a visi t to your

doctor and individL1als enrolled in

the program are subject to three

years of post-discharge monitoring

Wage Garnishment Prevention

Federal law requires that the

Department of Education or a

gua1middotanty agency notify you before

111st1tuting wage garnishment You

have tl1e right to a hearing where

you can challenge the stated

amount owed and negotiate the

terms of the repayment scheclule

We can intervene on YOL1PflJl~1D-3

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 23 of 57 Page ID 1782

22

Exhibit A

payments have been made p1middotevent wage gampnishments

A FEW STATISTICS ABOUT STUDENT LOAN CRISIS

12 Trillion National Student Debt I he nitionil student loin debt is

now 17 trillion dollirs 1 trillion of

these are in federil student loans

Let us help you through this national

crisis Cill today for a free

evaluation

40 Million Students with Debt

In 7014 an estimated 40 million

current and former students were in

debt because of student loans If

you are one of the millions of people

struggling to pay student loans

Aiding Student Relief is here to help

$33000 Average Student Debt

The graduating class of 7014

average $33000 of student loan

debt per person Thats $3000 more

than the average in 2013 Dont be

one of the many Let Aiding Student

Relief advocate for you

Aiding Student Relief has helped cmrnllcss 1woplc reduce their student debt_ Their proven business

plan has led lo one of lhc highest s11cclSS raCs in the inltl11slly

John Standiford Associated

FTC-AID-4

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 24 of 57 Page ID 1783

23

Exhibit A

TESTIMONIALS

Til~nks to Aiding Student Rel ief Im middotI middotva ove1vvhelrnecl but Aiding The expemiddotts at l1icl i11g Student Rel ief

s1v ing $250 per month Strrd r~rt Relief expl~ inecl the were ther~ to help me when I process ancl rnacle everytl1ing cle11middot nelclecl 1t rw)s t

and sirnple

I Michael Ma 1in

Entrep e11eu1 Em iiy Jallo1 Ii Pa ul Ch is tia I1se11

Teacher Nurse

With so many programs I didnt middotconso lrclating my loans into one I love my Job but vith my high

know what was ng ht for me My monthly payment hs made life student loan payment was still

sruclent loan aclvsor walked me si1nple1 Now I can focus on 1Nhn bamiddotely getting by I don t kn ow what I

through my optio ns rnd now Imiddotn matters to me would hwe clone wthout Aiding

saving 54 I 11n1omh Stucie1middott Rel refmiddot

Ariel Hemiquez Sales co)SUltant

Stephani Seland-1 Small Busim~ss Owner

AJ 01en Museum Curator

RECENT NEWS

)lt)

o(l ttDrlTI -5

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 25 of 57 Page ID 1784

24

Exhibit A

Student Debt Crisis Business Latest Debt Collective Demands May be largely about smallest Student

borrnwers US News amp World Loan Crisis is fa frorn ove The Debt Collective is a group of Report-May 162015 last month Two new reports suggest the college students calling the Fedemiddotal Reserve Bank of New student loan crisis is easing them-se1ves the Corinthian York repor ced that stuclent loan somewhat as the economy Fifteen who are refusing to pay balances rose to 16 trillio n and improves but the crisis is far back their student loins As pa t that 113 per cent of that is in from ove the College Board of this effort the Debt Collective repo t~ tot31 borrowing fell by 8 has written an open lette to the pEbull1 cent between 2012-13 and Department of Education f l llJ 20 13-14 The organization

About Us 11 1 i~d1middot1r F th~~- h1~ ff t1middot~11middot=cl =i~=middott- 1middot __31middotmiddotIIgt middot bullmiddot11

middot- I ( )ntir il t l~i -r_il fr~~

Address bull middot tc1ltj-1r_ =i ~

middot l t1~t 1middot1 fcJ middot~_1 1 I l11 - Hbull 1 tr

~t (~~ 1 12bull~11 T 1 1- - 8555105400

FTC-AID-6

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 26 of 57 Page ID 1785

25

Exhibit A

f - g+ in O) ~ PRIVACY POLICY

This privacy statement discloses the privacy practices for AidllII Student Relief Because Aiding Studen Relief wonts to demonstrate ts firm commlcmell to your

privacy Aiding Sudent Relief hes greed to disclose ls 1rifor111atlori g1thering and dlssem1n1t1on prct1cts Aidlns Studtrit Relief will notify you of

INFORMATION COLLECTION At-ID USE

Aiding Student Relief is the sole owner of the rformMlon collected on this site We will not sell shire or rent this information 10 others In way different from what Is

disclosed 1n this statement Aldln1 StudeM Relief collects 1nform111on throuah this site from our prospective end existing clients at several different poin on our web

site We use their contact Informii on to send information bout our company and to service exsMs accounts Users may optbullout of rece11ns future malllngs see the

cholceoptbullout section below Contect and Financial information that 1s collected Is used for verifying your name address and other informa1on as well as to boll you for

your use of our Gerv1ces using Information from third party sourcH Information about your computer hardwre and software Is automatically collected by Aiding

Student Relief and may be shared in asgregate with third parties whose services are used for traffic analysis purposes This Ir formation includes your IP address

browser type domain names access times and referring Web site addresses Ths information is no tied to personally Identifiable Information This 1nformatlor s used

by Aiding Student Relief to malMan no Improve the quality of the Hrvct and to senerae statistics resardlng use of he Aiding Student Relief site We use third party

services to bill for serlces and to provide other services like our Live Help chat We store the transcripts from these chats for customer service Improvement These

third party service providers are not permitted to use your infornon for any secondary purposes

Thank you and cheers

FTC-AID-7

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 27 of 57 Page ID 1786

26

Exhibit A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 28 of 57 Page ID 1787

EXHIBIT B

Attachment A

((

z | ~

AIDINGSTUDENTRELIEF

bull bull bull bull bull

13 deg $ $ampdegdeg deg() ˝ amp $$deg( + -+Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 29 of 57 Page ID 1788

bulldaggerDagger Daggermdashndash Daggerhellip ƒfrasl hellip lsaquorsaquobullminuspermilminushellip bdquolsaquoldquo rsaquordquobulllsquo fraslbullrsquopermillsaquofraslpermilminushellip sbquo

4556789fADlt=gtA9BCAD

DZgtA=EFGHIJFKLMNOPFQOGFHIQRSTLKSUMMNOPLHMTFIVRWXHKKNIFNUNOPRLFGSHKSRVRVNQ

f e=klHMW

9SI]UQMSNSOQOHHPFK YaSTHHVVJFMHcVGNOJVHHFKKPSUHMLIUOQN_PL[KSVFGJPRSDTHRFPLIP=SNDC==GFdFIP9VaNHQTWSRPbHF_PSKSVNMPMHNIO XNNIIFRKNF7IKSQQMHFNDVPOS9IAeTHPdKSUMMFNKHONP 8aF_KSNVPHTNIMNR[POVFgNPTHLNHIgtMFI YTFHIdFFI D9aHVR_KNKHFHIWIQOTHIQbFFP

lt=Dkgt=L]oHUKMMH ihTFNIORI THHVPRFMVKgtNJ_NFFbIVSJI]IFjdGGVNNN lt=TFKPPNF 9DaFGmVHPGRJMFNNQOSGnPFFTNLUNHPMIMTFVNJOKMIWV

27

]UMNOHPFRKNVSHKKISIRWRrGZNJONgtNjTHKHMI=cQgtORHVPKSOUMddUNKSPIdspNVPNq_ lt=gtBTHFHPb=HFILGFHMt DTFuFIUVFRPNTFIMINVWOPRVOQFIV sFQFPHKKH vaIPNFVcSyOFSPRFMRNVOJH_gtVFDVUJAN9FPwFuVFJLFHMP_VTFFdSIIVdNHUPxI=DQSROJGASHIVdDSNMINONPPaHdOHdPFHRIWVFFHdFIGM˙ 01 $2 301 $$3 ( Exhibit B

8

~ldquo

middot

676EBCEDK5ltAC]5EF_5665E7gt5lt7aFb688E588lt76B5E6F8EBAC78lt76cdddefghijhggklmknmopqprpopst u

13 deg $ $ampdegdeg degˇ amp $$deg + -+Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 30 of 57 Page ID 1789 () ( vPSZwPxyYTUZUWWzxPyxSWMZWPU|SWUWYZ~YTY~QSWbullYXRwU~UxSdaggerXQ~UZXvPSZWSOVQSYNOXPRSTUSDaggerPxXYPZPNXRUSPQZXPbullU~SOhellipUNPxyYTUZmdash zUxSZUZXndashYWShellipYYXOwPxyYTUZUWWMNOPQx~YWShellipYYXOYWUƒDaggerU|XU~XPSWXfrasllsaquoPZXRWPxPxUOPQSOVQSYNONPxDaggerUxSZUZX~YWShellipYYXONPxyYTUZUWWmdash

rsaquominus MZ|PUpermilSWUzSOUZXWbdquoDaggerUxYP~PNZSZ|YSRSx~WRYDaggerSOVQSYNOOPQNPxSZMZ|PUpermilSWU~rdquoUDaggerSOUZXzSZmdashMZSZO|SWUWXRYWUSZWOPQDaggerSOZPXRYZymdash zQhellipY|daggerUxTY|UvPSZwPxyYTUZUWWMNOPQbullPxlsquoNPxSyPTUxZUZXPxySZYrsquoSXYPZSXS|YXOWXSXUPxNU~UxSUTUOPQSOVQSYNONPxXRUzQhellipY|daggerUxTY|UvPSZwPxyYTUZUWWDaggerxPyxSmdashsbquotrade f8Ef8E78FCB6C8EŁPQSOhellipUShellipUXP|PhellipYZUQXYDaggerUNU~UxSWXQ~UZXPSZWYZXPPZUZUbullPSZbullYXRSPbullUxPxUSŒPx~ShellipUPZXRODaggerSOUZXmdashvPSZ|PZWPY~SXYPZDaggerxPyxSW|SZRUDaggerOPQVQSYNONPxS~~YXYPZSDaggerxPyxSW YlsquoU PSZ NPxyYTUZUWWDaggerxPyxSWPxzQhellipY|daggerUxTY|UvPSZwPxyYTUZUWWmdash ŠmŸŽıłŠm 57gt8A57A5B= 8E65C76B5E6F8EB5=6G

PONM[5 QRSTUVQU PYXWZW lt4556789588lt959=lt CD lt H5FICEDJ8KA5LCD

A565E7gt57 œšžeuroiexclcentpoundyenbrvbarsectbrvbareurocopypoundsectlaquoeuropoundlaquobrvbarlaquoregplusmncentbrvbareurocent microparalaquo europoundž raquoY|frac14frac12 plusmncurrenRSUraquoSxXYZeuropoundlaquo laquoeurolaquoordf frac34

^ ˙ ( (

28

Attachment A

01 $2 301 $$3 ( Exhibit B

()(

=4ABC9DEAFBD=FGFHIJKLMJNOMN MRNS mn = nrst = svzhellipu t bulltvDaggerrhellipDaggerurbullbulltuhellipv hellipz~ bullmdashldquordquolsquorsquotrade š oŒŠeuro centpound ` umluml 13 deg $ $ampdegdeg degˇ amp $$deg + -+Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 31 of 57 Page ID 1790

ISNRTUKQINKKNNKL[MRJ PUWQI]MRM qyt|tytzxy rsaquoqNfraslbdquoPUhellipsbquoLUyQhellip rfraslbhellipMNSIKVUQ QNJKvUQsMiexclQQJUx[iexcliexcl_vsect_Qyenyenbrvbarbrvbar uSSRNTPL_LUUMKIaJ_WMIJJKVIONNQJJMWRMIIbQQURKLWIIJQbKLUNKMPTMNQQ_KKRY tbullbulldaggersDaggerv~vhellipmdashryrhellip~mdashrhellipDagger ŸLŽUıQŽbłpermilMtradeœsbquoNtrade_ffRŁyISMŒUQWyNUQŠlsaquo rv45657896lt7ltgt5lt PQKLMIQSNRTUKINQVNOOMVKMWNQKLIJPMXJIKMYZMPIOO NJMOOJLURMNRRMKKLIJ klltko ltgtlt85p5gt5 ouvwxrz ^^ ~ minuspermil tffŁ yenpoundpound KNOWDaggerIreggt4lt97ltndash9ƒ Dagger hellipDaggerlsaquo žko74k57ƒ ƒISNcurrenUIWIbJKWMKJYVNTKM KLONNRqIQQSNNRTUKINQQIJ_JMWNQKLIJJJPMXJIKMcOMUJMVNQKUVK_JUKBHdefABCgDEAFBDghidjlaquopoundbrvbariexclnotvIWIQbDaggerK_WMQKbullMOIMSvOObullIbLKJbullMJMRMW ordf copy

01( $2(301$$3( Exhibit B

29

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 32 of 57 Page ID 1791

EXHIBIT C

Attachment A

~ 111 ~tampi 10 11 ~bull ia1111

Something awesome is coming soon We are buildin somethin ve cool Sta tuned and be at1ent Your atience will be well aid

~lbullrbullUiUffl We can help you reduce and simplify your payments

101 Loan For iveness

1~u 0 (middottmiddotbullmiddotmiddot1 1~=I -- _~

HZamp IMUliULlampRampatiEUWi nmiddot middot-il~ fr middot 8rbullbullrcrr-

_J l _ 1 _f _ur -~t~ u L liYu

~ Income Based Pa ents

bull ~ f I - - I - I - ri u ~u-=lf ~ JU

1-bullA ---rc iM1~~ -~-bullCiel rrcl

~- middot IY 2 i C middot middotJ ll1Jmiddot 0 _ middot_middotIr i

~ LdfiJIMifJ11JJMJllfFffi

middotE-ltecl l2bullJbull iequbullt t11cit t1lt2 CtpCr~middot1e- f

JJd r g-_iraE-1 agltr-middot- ntimiddot middot)middotou

tmiddot_rt- i ic l~1ri ~rbullmiddot middot111~ umiddot -_ d_t-c

fsectmet-Naibullfyen1~poundibllffifftmI

I f-nle Vnot Nune

I ampterYOllrEmall ]

1 ~~~~ 1

If -bull 13n ~Cbull t~middot rct1~j d- gtOY- - hO- irmiddot (bulldbull) plltmiddotmiddot- leemiddotmiddot JOu

1r1cbullmiddotn111f11ri ll1fbull fcrn to ~bull~I

Triin- GU

WAWMyenEIRitiRpoundWt 44 ZiAtillampampI

Exhibit C

Case 818-cv-01987-JLS

-KE

S

Docum

ent 50-1 F

iled 020519 P

age 33 of 57 P

age ID 1792

30

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 34 of 57 Page ID 1793

EXHIBIT D

Attachment A

bull bull bull bull bull bull bull

---

Type then hit enter to

bull bull bull bull bull bull bull

----

----

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 35 of 57 Page ID 1794

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

infoaidnestcom (800) 555-1212

HOME

ABOUT US

SERVICES

FAQ

BLOG

CONTACT

HOME ABOUT US SERVICES FAQ BLOG CONTACT

1 of 6 462018 945 AM

31

Student Loan Forgiveness Loan Consolidation Student Loan Forgiveness

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 36 of 57 Page ID 1795

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

If you have Federal Student Loans yoursquore in the right place to get those loans reduced forgiven or completely discharged through our student loan forgiveness programs

Get your multiple Federal Student Loans consolidated into one forget about increasing interests and pay month to month at the lowest possible cost

We understand if yoursquore going through some hardship and thatrsquos why with us yoursquoll be able to make monthly payments based on your affordability for as low as $000 depending on your situation

2 of 6 462018 945 AM

32

Knowledge Base

Defaulted Student Loans

Wage Garnishment

Student Loan Rehabilitation

Income Based Repayment Plan

Deferment and Forbearance

Pay As You Earn Repayment Plan

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE Call 561)424-6053 today to go over your options

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 37 of 57 Page ID 1796

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

Our knowledge base is designed to provide information regarding some of the critical topics those with student loans must be aware of to be able to make educated decisions regarding their future

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

A wage garnishment is any legal procedure in which some portion of a personrsquos earnings is required to be withheld by an employer for the payment of a debt

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

With this program your payments change as your income changes and will not be longer than 25 years This is the ideal plan if you are in partial financial hardship Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard plan

Temporarily allowing you to postpone or reduce your federal student loan payments Postponing or reducing your payments may help you avoid default and future garnishments

Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard

3 of 6 462018 945 AM

33

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 38 of 57 Page ID 1797

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

4 of 6 462018 945 AM

34Attachment A

Testimonials

Latest News

Why 2016 Will Be a Big Year For Student Loans

Top Student Loan Refinancing Questions of 2015

Oba mas latest student loan plan

Things You Should Know About Public Service Loan Forgiveness

Recent Posts

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 39 of 57 Page ID 1798

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

5 of 6 462018 945 AM

35

About Us

Contact Info

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 40 of 57 Page ID 1799

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

pay-grandchild-studen

Why 2016 Will Be a Big Year For Student Loans

December 30 2015

12511110_1112367518

Top Student Loan Refinancing Questions of 2015

December 30 2015

We stand by our consultation and quote We are so sure and confident about our services and offers that they are all 100 money back guarantee risk free ndash if we donrsquot do what we promise yoursquoll get your money back

(800) 555-1212 AidnestStudenLoansgmailcom 18100 Von Karman Ave Suite 850 Irvine CA 92612

Futero SAS copy 2015 | Aidnestcom

6 of 6 462018 945

Exhibit D 36Attachment A

AM

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 41 of 57 Page ID 1800

EXHIBIT E

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 42 of 57 Page ID 1801

AIDNEST Let us help you through this national crisis

Call one of our specialists today

Forbearance amp Deferment If you are still in school and struggling to make payments on your student loans You may qualify

for Forbearance amp Deferment

Garnishment Prevention Federal law requires that the Department of Education or guarantee agency notifies you before they

begin garnishing your wages

Loan Forgiveness If you are a teacher public service worker or an individual with total and permanent disability you

httpaidnestcom[442018 115239 AM]

37Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 43 of 57 Page ID 1802

AIDNEST Let us help you through this national crisis

may qualify for this program

Consolidating Your Loans Consolidating your loans to one new loan under one lender may lower your payments and make

your life a bit more manageable

Affordable Payments If you are looking to lower your monthly payments then Income Based Repayment Plans may be

the correct choice for you

Learn more about our services

LEARN MORE

httpaidnestcom[442018 115239 AM]

38Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 44 of 57 Page ID 1803

AIDNEST Let us help you through this national crisis

Loan Forgiveness Programs Income Based Payments Student Loan Rehabilitation

Student Loan Consolidation

You may be eligible for

Loan Forgiveness Programs

In some cases individuals with Federal Student Loans may qualify to have a portion of the amount

owed to be forgiven

Get in touch with our professional team to find out which loan forgiveness program you qualify for and

how you can get rid of your unpaid student loan

L EARN MORE

httpaidnestcom[442018 115239 AM]

39Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 45 of 57 Page ID 1804

AIDNEST Let us help you through this national crisis

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE

Meet your Budget One of our advisers will help you meet your payment goals by using your budget and timeline to

determine the best plan available

httpaidnestcom[442018 115239 AM]

40Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 46 of 57 Page ID 1805

AIDNEST Let us help you through this national crisis

Simple Process We understand that lowering your payments alone can be difficult Our intuitive platform allows us

to keep the entire process simple

Customer Satisfaction We are committed to providing you with outstanding service only We look forward to working

with you

100 money back guarantee No Hassle Money Back Policy

httpaidnestcom[442018 115239 AM]

41Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 47 of 57 Page ID 1806

AIDNEST Let us help you through this national crisis

Lower your loan payments by getting in touch with one of our professionals

We design a customized repayment plan that will allow you to make payments based on your

monthly income family size and spending Get rid of the hassle of extensive paperwork and get the

help you deserve

What we can help you achieve a lower payment or lower rate

httpaidnestcom[442018 115239 AM]

42Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 48 of 57 Page ID 1807

AIDNEST Let us help you through this national crisis

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcom[442018 115239 AM]

43Exhibit E

httpaidnestcomservices[442018 115322 AM]

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 49 of 57 Page ID 1808

Services | AIDNEST Let us help you through this national crisis

INCOME BASED PAYMENTS

If you are suffering from a financial hardship you may be eligible for an

Income Based Payment In this repayment program you would have a

payment based on your income and family size The payment could be as

low as $000 per month with forgiveness at the end of 20-25 years

44

Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 50 of 57 Page ID 1809

L E ARN MORE

LOAN FORGIVENESS

If you have Federal Student Loans you may qualify for any of the student

loan forgiveness programs that are available to borrowers You may be

eligible for principal reduction loan forgiveness or a complete loan

discharge depending on your individual circumstance

L EARN MORE

PRIVATE STUDENT LOAN CONSOLIDATION

Much like refinancing a mortgage generally the biggest benefit of private

student loan consolidationstudent loan refinancing is a lower interest rate

httpaidnestcomservices[442018 115322 AM]

45Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 51 of 57 Page ID 1810

L E ARN MORE

(something federal consolidations do not offer)

STUDENT LOAN REHABILITATION

You can renew eligibility for new loans and grants and eliminate the loan

default by ldquorehabilitatingrdquo a defaulted loan

httpaidnestcomservices[442018 115322 AM]

46Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 52 of 57 Page ID 1811

CHE CK E L E G I B I L I T Y

WAGE GARNISHMENT

A wage garnishment is any legal procedure in which some portion of a

personrsquos earnings is required to be withheld by an employer for the

payment of a debt

L EARN MORE

With our fast friendly and professional services wersquoll be glad to help you get your student loans

reduced forgiven or completely discharged To this end wersquoll assist you in consolidating all your

student loans so yoursquoll have only one lender and yoursquoll start making one monthly payment Our

professionals will walk you through the best and most flexible repayment options and if itrsquos also

necessary varied deferment options and rehabilitation programs

httpaidnestcomservices[442018 115322 AM]

47Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 53 of 57 Page ID 1812

Services | AIDNEST Let us help you through this national crisis

Our CRM System

Our CRM is one of the most advanced in the industry and most importantly itrsquos linked directly to

the Department of Education (DOE) This keeps your personal and most confidential information

safe Furthermore because our CRM system is linked to the DOE our approval is 100 Through

our CRM we will be doing continuous monitoring of our process without losing sight of your

immediate needs ensuring that your case has the proper handling and most efficient process

httpaidnestcomservices[442018 115322 AM]

48Exhibit E

n

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 54 of 57 Page ID 1813

Services | AIDNEST Let us help you through this national crisis

R ECENT POSTS

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

ABOUT US

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcomservices[442018 115322 AM]

49Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 55 of 57 Page ID 1814

EXHIBIT F

s -

bullmiddot - ~ t ~ower Your Student Loan Pay~e~ts oday -- Students Helping Students Save Money

INCOME BASED PAJIIIJITPAIS

I C(gttoUC1 u~

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 56 of 57 Page ID 1815

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HOME SERVICES ABOUT US FAQ CONTACT US BLOC PRIVACY

Offering obligation and commitment free loan relief solutions

STUDENT LOAN FORGIVENESS INCOME BASED PAYMENTS LOAN CONSOLIDATION

We11 help you get your loans reduced forgiven o r Make monthly pdyments based on your affordability Get multiple Federal Student Loans consolidated into

discharged one low monthly payment

Talk to our experts concerning your

student loans

Studora is a pnvatefy owned company that helps consumers like you identify

government programs that fit your financial s1tuat1on Our loan experts will assist you in selecting the appropriate programs that WOltk with your income family size and

desired monthly payment We then prepare the appropriate documents for your review and submission All this f o r one low easy payment

Testimonials

Thank you f o r getting back to me quickly Youve been fabulous Thank you for the confirmation and for your help today Pass

during this whole process Is there a place I can go online that I this on to your sup that you were very professional and very

can leave a comment for your manager Youve made this Robert helpful and brought a sense of relief for me Thank you very

process so easy and answered every question my husband and I much and have a great rest of your day Kudos to you and your

have had teammoneywell spenL

Exhibit F 50

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 57 of 57 Page ID 1816

Services we offer

Stud ora offers document preparation services for all loan forgiveness consolidation and relief services to people who are unable to manage their finances Our mam aim is to

offer complete peace of mind to indiVidual unable to pay their student loan debt

we otter the folloWing document preparation services with complete professional assistance

amFinancial Review ffl Budget Planning

Toe first step to creating a flexible loan repayment plan is financial review we also help create a personal finance plan to ensure that you are able to

Our professmnals will look into your finances and design a custom manage your monthly budget in the most effective way This plan will keep

repayment plan that is affordable and easy to manage your spending to the minimum alloWing you to save more money for loan

repayment

Permanent Disability Forgiveness r-trTeacher Loan Forgiveness (5 You can get rid of your Federal Student Loan if you are permanently disabled Good news for teachers who are under the weight of a massiVe loan You can

now get $17 forgiven on your student loans

Public Service Loan Forgiveness Custom Debt Relief Plans

Want assistance with debt relief Get in touch with our experts who will help If you are a public service agent you can get rid of your loan after 120 days of design a loan repayment and relief plan for you based on your monthly

income and affordability payments

THERE ARE NO OBLIGATIONS OR COMMITMENTS

want to save thousands of dollars Fill out our form and get relief from your student loan for a more

peaceful tomorrow

Your Name

BiHHHi

Exhibit F 51

Attachment A

Page 22: JOSHUA S. MILLARD, BRIAN M. WELKE, pro hac vice · for which it has no legitimate claim. Noel is a Wyoming limited liability company that reported in a public document that its principal

ABOUT US

We can help you reduce and simplify your pay1ncnts Contact one of our specialists today for

a free evaluation

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FTC-AID-2

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 22 of 57 Page ID 1781

21

Exhibit A

SERVICES Wt w gtL

Loan Forgiveness Income Based Payments Loan Consol idation In some cases individuals with A period of financial hardship may You may be able to combine

Fede1middota1 Student Loans may qualify qualify you for an Income Based nultiple federal student loans into to have a portion of the amount Repayment Plan In many cases this one new loan w ith a lower more

owed may be forgiven This means means you pay nothing Unlike a affordable monthly payment Loan

your principal balnce coulcl be defe1 ment the term on your loan consolidation prngrams can l1elp

significantly reduced and you will continues to reduce while the plan is you qualify for additional programs not be expected to repay the in place Your term could reduce like loan forgiveness programs or

forgiven amount while you pay nothing Public Setvice Loan Forgiveness

a III

Private Sector Loan Forgiveness

If you work for a government

organization at a city state or

federa l level you may qualify for tle

PL1blic Service Loan Forgiveness

program To qualify your loans

must be cotisolidated into a specific

repayment plan The balance on

your federai student loans is

forgiven after 120 qualifying

bull C Permanent Disability

Forgivenness If your disability is expected to last

60 months or more you may qualify

for permanent disability forgiveness

Q1alifying for Permnent Disability

Forgiveness requires a visi t to your

doctor and individL1als enrolled in

the program are subject to three

years of post-discharge monitoring

Wage Garnishment Prevention

Federal law requires that the

Department of Education or a

gua1middotanty agency notify you before

111st1tuting wage garnishment You

have tl1e right to a hearing where

you can challenge the stated

amount owed and negotiate the

terms of the repayment scheclule

We can intervene on YOL1PflJl~1D-3

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 23 of 57 Page ID 1782

22

Exhibit A

payments have been made p1middotevent wage gampnishments

A FEW STATISTICS ABOUT STUDENT LOAN CRISIS

12 Trillion National Student Debt I he nitionil student loin debt is

now 17 trillion dollirs 1 trillion of

these are in federil student loans

Let us help you through this national

crisis Cill today for a free

evaluation

40 Million Students with Debt

In 7014 an estimated 40 million

current and former students were in

debt because of student loans If

you are one of the millions of people

struggling to pay student loans

Aiding Student Relief is here to help

$33000 Average Student Debt

The graduating class of 7014

average $33000 of student loan

debt per person Thats $3000 more

than the average in 2013 Dont be

one of the many Let Aiding Student

Relief advocate for you

Aiding Student Relief has helped cmrnllcss 1woplc reduce their student debt_ Their proven business

plan has led lo one of lhc highest s11cclSS raCs in the inltl11slly

John Standiford Associated

FTC-AID-4

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 24 of 57 Page ID 1783

23

Exhibit A

TESTIMONIALS

Til~nks to Aiding Student Rel ief Im middotI middotva ove1vvhelrnecl but Aiding The expemiddotts at l1icl i11g Student Rel ief

s1v ing $250 per month Strrd r~rt Relief expl~ inecl the were ther~ to help me when I process ancl rnacle everytl1ing cle11middot nelclecl 1t rw)s t

and sirnple

I Michael Ma 1in

Entrep e11eu1 Em iiy Jallo1 Ii Pa ul Ch is tia I1se11

Teacher Nurse

With so many programs I didnt middotconso lrclating my loans into one I love my Job but vith my high

know what was ng ht for me My monthly payment hs made life student loan payment was still

sruclent loan aclvsor walked me si1nple1 Now I can focus on 1Nhn bamiddotely getting by I don t kn ow what I

through my optio ns rnd now Imiddotn matters to me would hwe clone wthout Aiding

saving 54 I 11n1omh Stucie1middott Rel refmiddot

Ariel Hemiquez Sales co)SUltant

Stephani Seland-1 Small Busim~ss Owner

AJ 01en Museum Curator

RECENT NEWS

)lt)

o(l ttDrlTI -5

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 25 of 57 Page ID 1784

24

Exhibit A

Student Debt Crisis Business Latest Debt Collective Demands May be largely about smallest Student

borrnwers US News amp World Loan Crisis is fa frorn ove The Debt Collective is a group of Report-May 162015 last month Two new reports suggest the college students calling the Fedemiddotal Reserve Bank of New student loan crisis is easing them-se1ves the Corinthian York repor ced that stuclent loan somewhat as the economy Fifteen who are refusing to pay balances rose to 16 trillio n and improves but the crisis is far back their student loins As pa t that 113 per cent of that is in from ove the College Board of this effort the Debt Collective repo t~ tot31 borrowing fell by 8 has written an open lette to the pEbull1 cent between 2012-13 and Department of Education f l llJ 20 13-14 The organization

About Us 11 1 i~d1middot1r F th~~- h1~ ff t1middot~11middot=cl =i~=middott- 1middot __31middotmiddotIIgt middot bullmiddot11

middot- I ( )ntir il t l~i -r_il fr~~

Address bull middot tc1ltj-1r_ =i ~

middot l t1~t 1middot1 fcJ middot~_1 1 I l11 - Hbull 1 tr

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FTC-AID-6

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 26 of 57 Page ID 1785

25

Exhibit A

f - g+ in O) ~ PRIVACY POLICY

This privacy statement discloses the privacy practices for AidllII Student Relief Because Aiding Studen Relief wonts to demonstrate ts firm commlcmell to your

privacy Aiding Sudent Relief hes greed to disclose ls 1rifor111atlori g1thering and dlssem1n1t1on prct1cts Aidlns Studtrit Relief will notify you of

INFORMATION COLLECTION At-ID USE

Aiding Student Relief is the sole owner of the rformMlon collected on this site We will not sell shire or rent this information 10 others In way different from what Is

disclosed 1n this statement Aldln1 StudeM Relief collects 1nform111on throuah this site from our prospective end existing clients at several different poin on our web

site We use their contact Informii on to send information bout our company and to service exsMs accounts Users may optbullout of rece11ns future malllngs see the

cholceoptbullout section below Contect and Financial information that 1s collected Is used for verifying your name address and other informa1on as well as to boll you for

your use of our Gerv1ces using Information from third party sourcH Information about your computer hardwre and software Is automatically collected by Aiding

Student Relief and may be shared in asgregate with third parties whose services are used for traffic analysis purposes This Ir formation includes your IP address

browser type domain names access times and referring Web site addresses Ths information is no tied to personally Identifiable Information This 1nformatlor s used

by Aiding Student Relief to malMan no Improve the quality of the Hrvct and to senerae statistics resardlng use of he Aiding Student Relief site We use third party

services to bill for serlces and to provide other services like our Live Help chat We store the transcripts from these chats for customer service Improvement These

third party service providers are not permitted to use your infornon for any secondary purposes

Thank you and cheers

FTC-AID-7

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 27 of 57 Page ID 1786

26

Exhibit A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 28 of 57 Page ID 1787

EXHIBIT B

Attachment A

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9SI]UQMSNSOQOHHPFK YaSTHHVVJFMHcVGNOJVHHFKKPSUHMLIUOQN_PL[KSVFGJPRSDTHRFPLIP=SNDC==GFdFIP9VaNHQTWSRPbHF_PSKSVNMPMHNIO XNNIIFRKNF7IKSQQMHFNDVPOS9IAeTHPdKSUMMFNKHONP 8aF_KSNVPHTNIMNR[POVFgNPTHLNHIgtMFI YTFHIdFFI D9aHVR_KNKHFHIWIQOTHIQbFFP

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27

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8

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28

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01 $2 301 $$3 ( Exhibit B

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29

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 32 of 57 Page ID 1791

EXHIBIT C

Attachment A

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Something awesome is coming soon We are buildin somethin ve cool Sta tuned and be at1ent Your atience will be well aid

~lbullrbullUiUffl We can help you reduce and simplify your payments

101 Loan For iveness

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Exhibit C

Case 818-cv-01987-JLS

-KE

S

Docum

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age 33 of 57 P

age ID 1792

30

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 34 of 57 Page ID 1793

EXHIBIT D

Attachment A

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Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 35 of 57 Page ID 1794

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

infoaidnestcom (800) 555-1212

HOME

ABOUT US

SERVICES

FAQ

BLOG

CONTACT

HOME ABOUT US SERVICES FAQ BLOG CONTACT

1 of 6 462018 945 AM

31

Student Loan Forgiveness Loan Consolidation Student Loan Forgiveness

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 36 of 57 Page ID 1795

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

If you have Federal Student Loans yoursquore in the right place to get those loans reduced forgiven or completely discharged through our student loan forgiveness programs

Get your multiple Federal Student Loans consolidated into one forget about increasing interests and pay month to month at the lowest possible cost

We understand if yoursquore going through some hardship and thatrsquos why with us yoursquoll be able to make monthly payments based on your affordability for as low as $000 depending on your situation

2 of 6 462018 945 AM

32

Knowledge Base

Defaulted Student Loans

Wage Garnishment

Student Loan Rehabilitation

Income Based Repayment Plan

Deferment and Forbearance

Pay As You Earn Repayment Plan

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE Call 561)424-6053 today to go over your options

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 37 of 57 Page ID 1796

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

Our knowledge base is designed to provide information regarding some of the critical topics those with student loans must be aware of to be able to make educated decisions regarding their future

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

A wage garnishment is any legal procedure in which some portion of a personrsquos earnings is required to be withheld by an employer for the payment of a debt

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

With this program your payments change as your income changes and will not be longer than 25 years This is the ideal plan if you are in partial financial hardship Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard plan

Temporarily allowing you to postpone or reduce your federal student loan payments Postponing or reducing your payments may help you avoid default and future garnishments

Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard

3 of 6 462018 945 AM

33

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 38 of 57 Page ID 1797

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

4 of 6 462018 945 AM

34Attachment A

Testimonials

Latest News

Why 2016 Will Be a Big Year For Student Loans

Top Student Loan Refinancing Questions of 2015

Oba mas latest student loan plan

Things You Should Know About Public Service Loan Forgiveness

Recent Posts

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 39 of 57 Page ID 1798

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

5 of 6 462018 945 AM

35

About Us

Contact Info

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 40 of 57 Page ID 1799

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

pay-grandchild-studen

Why 2016 Will Be a Big Year For Student Loans

December 30 2015

12511110_1112367518

Top Student Loan Refinancing Questions of 2015

December 30 2015

We stand by our consultation and quote We are so sure and confident about our services and offers that they are all 100 money back guarantee risk free ndash if we donrsquot do what we promise yoursquoll get your money back

(800) 555-1212 AidnestStudenLoansgmailcom 18100 Von Karman Ave Suite 850 Irvine CA 92612

Futero SAS copy 2015 | Aidnestcom

6 of 6 462018 945

Exhibit D 36Attachment A

AM

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 41 of 57 Page ID 1800

EXHIBIT E

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 42 of 57 Page ID 1801

AIDNEST Let us help you through this national crisis

Call one of our specialists today

Forbearance amp Deferment If you are still in school and struggling to make payments on your student loans You may qualify

for Forbearance amp Deferment

Garnishment Prevention Federal law requires that the Department of Education or guarantee agency notifies you before they

begin garnishing your wages

Loan Forgiveness If you are a teacher public service worker or an individual with total and permanent disability you

httpaidnestcom[442018 115239 AM]

37Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 43 of 57 Page ID 1802

AIDNEST Let us help you through this national crisis

may qualify for this program

Consolidating Your Loans Consolidating your loans to one new loan under one lender may lower your payments and make

your life a bit more manageable

Affordable Payments If you are looking to lower your monthly payments then Income Based Repayment Plans may be

the correct choice for you

Learn more about our services

LEARN MORE

httpaidnestcom[442018 115239 AM]

38Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 44 of 57 Page ID 1803

AIDNEST Let us help you through this national crisis

Loan Forgiveness Programs Income Based Payments Student Loan Rehabilitation

Student Loan Consolidation

You may be eligible for

Loan Forgiveness Programs

In some cases individuals with Federal Student Loans may qualify to have a portion of the amount

owed to be forgiven

Get in touch with our professional team to find out which loan forgiveness program you qualify for and

how you can get rid of your unpaid student loan

L EARN MORE

httpaidnestcom[442018 115239 AM]

39Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 45 of 57 Page ID 1804

AIDNEST Let us help you through this national crisis

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE

Meet your Budget One of our advisers will help you meet your payment goals by using your budget and timeline to

determine the best plan available

httpaidnestcom[442018 115239 AM]

40Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 46 of 57 Page ID 1805

AIDNEST Let us help you through this national crisis

Simple Process We understand that lowering your payments alone can be difficult Our intuitive platform allows us

to keep the entire process simple

Customer Satisfaction We are committed to providing you with outstanding service only We look forward to working

with you

100 money back guarantee No Hassle Money Back Policy

httpaidnestcom[442018 115239 AM]

41Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 47 of 57 Page ID 1806

AIDNEST Let us help you through this national crisis

Lower your loan payments by getting in touch with one of our professionals

We design a customized repayment plan that will allow you to make payments based on your

monthly income family size and spending Get rid of the hassle of extensive paperwork and get the

help you deserve

What we can help you achieve a lower payment or lower rate

httpaidnestcom[442018 115239 AM]

42Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 48 of 57 Page ID 1807

AIDNEST Let us help you through this national crisis

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcom[442018 115239 AM]

43Exhibit E

httpaidnestcomservices[442018 115322 AM]

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 49 of 57 Page ID 1808

Services | AIDNEST Let us help you through this national crisis

INCOME BASED PAYMENTS

If you are suffering from a financial hardship you may be eligible for an

Income Based Payment In this repayment program you would have a

payment based on your income and family size The payment could be as

low as $000 per month with forgiveness at the end of 20-25 years

44

Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 50 of 57 Page ID 1809

L E ARN MORE

LOAN FORGIVENESS

If you have Federal Student Loans you may qualify for any of the student

loan forgiveness programs that are available to borrowers You may be

eligible for principal reduction loan forgiveness or a complete loan

discharge depending on your individual circumstance

L EARN MORE

PRIVATE STUDENT LOAN CONSOLIDATION

Much like refinancing a mortgage generally the biggest benefit of private

student loan consolidationstudent loan refinancing is a lower interest rate

httpaidnestcomservices[442018 115322 AM]

45Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 51 of 57 Page ID 1810

L E ARN MORE

(something federal consolidations do not offer)

STUDENT LOAN REHABILITATION

You can renew eligibility for new loans and grants and eliminate the loan

default by ldquorehabilitatingrdquo a defaulted loan

httpaidnestcomservices[442018 115322 AM]

46Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 52 of 57 Page ID 1811

CHE CK E L E G I B I L I T Y

WAGE GARNISHMENT

A wage garnishment is any legal procedure in which some portion of a

personrsquos earnings is required to be withheld by an employer for the

payment of a debt

L EARN MORE

With our fast friendly and professional services wersquoll be glad to help you get your student loans

reduced forgiven or completely discharged To this end wersquoll assist you in consolidating all your

student loans so yoursquoll have only one lender and yoursquoll start making one monthly payment Our

professionals will walk you through the best and most flexible repayment options and if itrsquos also

necessary varied deferment options and rehabilitation programs

httpaidnestcomservices[442018 115322 AM]

47Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 53 of 57 Page ID 1812

Services | AIDNEST Let us help you through this national crisis

Our CRM System

Our CRM is one of the most advanced in the industry and most importantly itrsquos linked directly to

the Department of Education (DOE) This keeps your personal and most confidential information

safe Furthermore because our CRM system is linked to the DOE our approval is 100 Through

our CRM we will be doing continuous monitoring of our process without losing sight of your

immediate needs ensuring that your case has the proper handling and most efficient process

httpaidnestcomservices[442018 115322 AM]

48Exhibit E

n

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 54 of 57 Page ID 1813

Services | AIDNEST Let us help you through this national crisis

R ECENT POSTS

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

ABOUT US

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcomservices[442018 115322 AM]

49Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 55 of 57 Page ID 1814

EXHIBIT F

s -

bullmiddot - ~ t ~ower Your Student Loan Pay~e~ts oday -- Students Helping Students Save Money

INCOME BASED PAJIIIJITPAIS

I C(gttoUC1 u~

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 56 of 57 Page ID 1815

X + C (D Not secure wwwstudoracom 0

CALL US NOW (85S) 978-S599 middot 1nfostudoracom

HOME SERVICES ABOUT US FAQ CONTACT US BLOC PRIVACY

Offering obligation and commitment free loan relief solutions

STUDENT LOAN FORGIVENESS INCOME BASED PAYMENTS LOAN CONSOLIDATION

We11 help you get your loans reduced forgiven o r Make monthly pdyments based on your affordability Get multiple Federal Student Loans consolidated into

discharged one low monthly payment

Talk to our experts concerning your

student loans

Studora is a pnvatefy owned company that helps consumers like you identify

government programs that fit your financial s1tuat1on Our loan experts will assist you in selecting the appropriate programs that WOltk with your income family size and

desired monthly payment We then prepare the appropriate documents for your review and submission All this f o r one low easy payment

Testimonials

Thank you f o r getting back to me quickly Youve been fabulous Thank you for the confirmation and for your help today Pass

during this whole process Is there a place I can go online that I this on to your sup that you were very professional and very

can leave a comment for your manager Youve made this Robert helpful and brought a sense of relief for me Thank you very

process so easy and answered every question my husband and I much and have a great rest of your day Kudos to you and your

have had teammoneywell spenL

Exhibit F 50

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 57 of 57 Page ID 1816

Services we offer

Stud ora offers document preparation services for all loan forgiveness consolidation and relief services to people who are unable to manage their finances Our mam aim is to

offer complete peace of mind to indiVidual unable to pay their student loan debt

we otter the folloWing document preparation services with complete professional assistance

amFinancial Review ffl Budget Planning

Toe first step to creating a flexible loan repayment plan is financial review we also help create a personal finance plan to ensure that you are able to

Our professmnals will look into your finances and design a custom manage your monthly budget in the most effective way This plan will keep

repayment plan that is affordable and easy to manage your spending to the minimum alloWing you to save more money for loan

repayment

Permanent Disability Forgiveness r-trTeacher Loan Forgiveness (5 You can get rid of your Federal Student Loan if you are permanently disabled Good news for teachers who are under the weight of a massiVe loan You can

now get $17 forgiven on your student loans

Public Service Loan Forgiveness Custom Debt Relief Plans

Want assistance with debt relief Get in touch with our experts who will help If you are a public service agent you can get rid of your loan after 120 days of design a loan repayment and relief plan for you based on your monthly

income and affordability payments

THERE ARE NO OBLIGATIONS OR COMMITMENTS

want to save thousands of dollars Fill out our form and get relief from your student loan for a more

peaceful tomorrow

Your Name

BiHHHi

Exhibit F 51

Attachment A

Page 23: JOSHUA S. MILLARD, BRIAN M. WELKE, pro hac vice · for which it has no legitimate claim. Noel is a Wyoming limited liability company that reported in a public document that its principal

SERVICES Wt w gtL

Loan Forgiveness Income Based Payments Loan Consol idation In some cases individuals with A period of financial hardship may You may be able to combine

Fede1middota1 Student Loans may qualify qualify you for an Income Based nultiple federal student loans into to have a portion of the amount Repayment Plan In many cases this one new loan w ith a lower more

owed may be forgiven This means means you pay nothing Unlike a affordable monthly payment Loan

your principal balnce coulcl be defe1 ment the term on your loan consolidation prngrams can l1elp

significantly reduced and you will continues to reduce while the plan is you qualify for additional programs not be expected to repay the in place Your term could reduce like loan forgiveness programs or

forgiven amount while you pay nothing Public Setvice Loan Forgiveness

a III

Private Sector Loan Forgiveness

If you work for a government

organization at a city state or

federa l level you may qualify for tle

PL1blic Service Loan Forgiveness

program To qualify your loans

must be cotisolidated into a specific

repayment plan The balance on

your federai student loans is

forgiven after 120 qualifying

bull C Permanent Disability

Forgivenness If your disability is expected to last

60 months or more you may qualify

for permanent disability forgiveness

Q1alifying for Permnent Disability

Forgiveness requires a visi t to your

doctor and individL1als enrolled in

the program are subject to three

years of post-discharge monitoring

Wage Garnishment Prevention

Federal law requires that the

Department of Education or a

gua1middotanty agency notify you before

111st1tuting wage garnishment You

have tl1e right to a hearing where

you can challenge the stated

amount owed and negotiate the

terms of the repayment scheclule

We can intervene on YOL1PflJl~1D-3

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 23 of 57 Page ID 1782

22

Exhibit A

payments have been made p1middotevent wage gampnishments

A FEW STATISTICS ABOUT STUDENT LOAN CRISIS

12 Trillion National Student Debt I he nitionil student loin debt is

now 17 trillion dollirs 1 trillion of

these are in federil student loans

Let us help you through this national

crisis Cill today for a free

evaluation

40 Million Students with Debt

In 7014 an estimated 40 million

current and former students were in

debt because of student loans If

you are one of the millions of people

struggling to pay student loans

Aiding Student Relief is here to help

$33000 Average Student Debt

The graduating class of 7014

average $33000 of student loan

debt per person Thats $3000 more

than the average in 2013 Dont be

one of the many Let Aiding Student

Relief advocate for you

Aiding Student Relief has helped cmrnllcss 1woplc reduce their student debt_ Their proven business

plan has led lo one of lhc highest s11cclSS raCs in the inltl11slly

John Standiford Associated

FTC-AID-4

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 24 of 57 Page ID 1783

23

Exhibit A

TESTIMONIALS

Til~nks to Aiding Student Rel ief Im middotI middotva ove1vvhelrnecl but Aiding The expemiddotts at l1icl i11g Student Rel ief

s1v ing $250 per month Strrd r~rt Relief expl~ inecl the were ther~ to help me when I process ancl rnacle everytl1ing cle11middot nelclecl 1t rw)s t

and sirnple

I Michael Ma 1in

Entrep e11eu1 Em iiy Jallo1 Ii Pa ul Ch is tia I1se11

Teacher Nurse

With so many programs I didnt middotconso lrclating my loans into one I love my Job but vith my high

know what was ng ht for me My monthly payment hs made life student loan payment was still

sruclent loan aclvsor walked me si1nple1 Now I can focus on 1Nhn bamiddotely getting by I don t kn ow what I

through my optio ns rnd now Imiddotn matters to me would hwe clone wthout Aiding

saving 54 I 11n1omh Stucie1middott Rel refmiddot

Ariel Hemiquez Sales co)SUltant

Stephani Seland-1 Small Busim~ss Owner

AJ 01en Museum Curator

RECENT NEWS

)lt)

o(l ttDrlTI -5

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 25 of 57 Page ID 1784

24

Exhibit A

Student Debt Crisis Business Latest Debt Collective Demands May be largely about smallest Student

borrnwers US News amp World Loan Crisis is fa frorn ove The Debt Collective is a group of Report-May 162015 last month Two new reports suggest the college students calling the Fedemiddotal Reserve Bank of New student loan crisis is easing them-se1ves the Corinthian York repor ced that stuclent loan somewhat as the economy Fifteen who are refusing to pay balances rose to 16 trillio n and improves but the crisis is far back their student loins As pa t that 113 per cent of that is in from ove the College Board of this effort the Debt Collective repo t~ tot31 borrowing fell by 8 has written an open lette to the pEbull1 cent between 2012-13 and Department of Education f l llJ 20 13-14 The organization

About Us 11 1 i~d1middot1r F th~~- h1~ ff t1middot~11middot=cl =i~=middott- 1middot __31middotmiddotIIgt middot bullmiddot11

middot- I ( )ntir il t l~i -r_il fr~~

Address bull middot tc1ltj-1r_ =i ~

middot l t1~t 1middot1 fcJ middot~_1 1 I l11 - Hbull 1 tr

~t (~~ 1 12bull~11 T 1 1- - 8555105400

FTC-AID-6

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 26 of 57 Page ID 1785

25

Exhibit A

f - g+ in O) ~ PRIVACY POLICY

This privacy statement discloses the privacy practices for AidllII Student Relief Because Aiding Studen Relief wonts to demonstrate ts firm commlcmell to your

privacy Aiding Sudent Relief hes greed to disclose ls 1rifor111atlori g1thering and dlssem1n1t1on prct1cts Aidlns Studtrit Relief will notify you of

INFORMATION COLLECTION At-ID USE

Aiding Student Relief is the sole owner of the rformMlon collected on this site We will not sell shire or rent this information 10 others In way different from what Is

disclosed 1n this statement Aldln1 StudeM Relief collects 1nform111on throuah this site from our prospective end existing clients at several different poin on our web

site We use their contact Informii on to send information bout our company and to service exsMs accounts Users may optbullout of rece11ns future malllngs see the

cholceoptbullout section below Contect and Financial information that 1s collected Is used for verifying your name address and other informa1on as well as to boll you for

your use of our Gerv1ces using Information from third party sourcH Information about your computer hardwre and software Is automatically collected by Aiding

Student Relief and may be shared in asgregate with third parties whose services are used for traffic analysis purposes This Ir formation includes your IP address

browser type domain names access times and referring Web site addresses Ths information is no tied to personally Identifiable Information This 1nformatlor s used

by Aiding Student Relief to malMan no Improve the quality of the Hrvct and to senerae statistics resardlng use of he Aiding Student Relief site We use third party

services to bill for serlces and to provide other services like our Live Help chat We store the transcripts from these chats for customer service Improvement These

third party service providers are not permitted to use your infornon for any secondary purposes

Thank you and cheers

FTC-AID-7

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 27 of 57 Page ID 1786

26

Exhibit A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 28 of 57 Page ID 1787

EXHIBIT B

Attachment A

((

z | ~

AIDINGSTUDENTRELIEF

bull bull bull bull bull

13 deg $ $ampdegdeg deg() ˝ amp $$deg( + -+Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 29 of 57 Page ID 1788

bulldaggerDagger Daggermdashndash Daggerhellip ƒfrasl hellip lsaquorsaquobullminuspermilminushellip bdquolsaquoldquo rsaquordquobulllsquo fraslbullrsquopermillsaquofraslpermilminushellip sbquo

4556789fADlt=gtA9BCAD

DZgtA=EFGHIJFKLMNOPFQOGFHIQRSTLKSUMMNOPLHMTFIVRWXHKKNIFNUNOPRLFGSHKSRVRVNQ

f e=klHMW

9SI]UQMSNSOQOHHPFK YaSTHHVVJFMHcVGNOJVHHFKKPSUHMLIUOQN_PL[KSVFGJPRSDTHRFPLIP=SNDC==GFdFIP9VaNHQTWSRPbHF_PSKSVNMPMHNIO XNNIIFRKNF7IKSQQMHFNDVPOS9IAeTHPdKSUMMFNKHONP 8aF_KSNVPHTNIMNR[POVFgNPTHLNHIgtMFI YTFHIdFFI D9aHVR_KNKHFHIWIQOTHIQbFFP

lt=Dkgt=L]oHUKMMH ihTFNIORI THHVPRFMVKgtNJ_NFFbIVSJI]IFjdGGVNNN lt=TFKPPNF 9DaFGmVHPGRJMFNNQOSGnPFFTNLUNHPMIMTFVNJOKMIWV

27

]UMNOHPFRKNVSHKKISIRWRrGZNJONgtNjTHKHMI=cQgtORHVPKSOUMddUNKSPIdspNVPNq_ lt=gtBTHFHPb=HFILGFHMt DTFuFIUVFRPNTFIMINVWOPRVOQFIV sFQFPHKKH vaIPNFVcSyOFSPRFMRNVOJH_gtVFDVUJAN9FPwFuVFJLFHMP_VTFFdSIIVdNHUPxI=DQSROJGASHIVdDSNMINONPPaHdOHdPFHRIWVFFHdFIGM˙ 01 $2 301 $$3 ( Exhibit B

8

~ldquo

middot

676EBCEDK5ltAC]5EF_5665E7gt5lt7aFb688E588lt76B5E6F8EBAC78lt76cdddefghijhggklmknmopqprpopst u

13 deg $ $ampdegdeg degˇ amp $$deg + -+Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 30 of 57 Page ID 1789 () ( vPSZwPxyYTUZUWWzxPyxSWMZWPU|SWUWYZ~YTY~QSWbullYXRwU~UxSdaggerXQ~UZXvPSZWSOVQSYNOXPRSTUSDaggerPxXYPZPNXRUSPQZXPbullU~SOhellipUNPxyYTUZmdash zUxSZUZXndashYWShellipYYXOwPxyYTUZUWWMNOPQx~YWShellipYYXOYWUƒDaggerU|XU~XPSWXfrasllsaquoPZXRWPxPxUOPQSOVQSYNONPxDaggerUxSZUZX~YWShellipYYXONPxyYTUZUWWmdash

rsaquominus MZ|PUpermilSWUzSOUZXWbdquoDaggerUxYP~PNZSZ|YSRSx~WRYDaggerSOVQSYNOOPQNPxSZMZ|PUpermilSWU~rdquoUDaggerSOUZXzSZmdashMZSZO|SWUWXRYWUSZWOPQDaggerSOZPXRYZymdash zQhellipY|daggerUxTY|UvPSZwPxyYTUZUWWMNOPQbullPxlsquoNPxSyPTUxZUZXPxySZYrsquoSXYPZSXS|YXOWXSXUPxNU~UxSUTUOPQSOVQSYNONPxXRUzQhellipY|daggerUxTY|UvPSZwPxyYTUZUWWDaggerxPyxSmdashsbquotrade f8Ef8E78FCB6C8EŁPQSOhellipUShellipUXP|PhellipYZUQXYDaggerUNU~UxSWXQ~UZXPSZWYZXPPZUZUbullPSZbullYXRSPbullUxPxUSŒPx~ShellipUPZXRODaggerSOUZXmdashvPSZ|PZWPY~SXYPZDaggerxPyxSW|SZRUDaggerOPQVQSYNONPxS~~YXYPZSDaggerxPyxSW YlsquoU PSZ NPxyYTUZUWWDaggerxPyxSWPxzQhellipY|daggerUxTY|UvPSZwPxyYTUZUWWmdash ŠmŸŽıłŠm 57gt8A57A5B= 8E65C76B5E6F8EB5=6G

PONM[5 QRSTUVQU PYXWZW lt4556789588lt959=lt CD lt H5FICEDJ8KA5LCD

A565E7gt57 œšžeuroiexclcentpoundyenbrvbarsectbrvbareurocopypoundsectlaquoeuropoundlaquobrvbarlaquoregplusmncentbrvbareurocent microparalaquo europoundž raquoY|frac14frac12 plusmncurrenRSUraquoSxXYZeuropoundlaquo laquoeurolaquoordf frac34

^ ˙ ( (

28

Attachment A

01 $2 301 $$3 ( Exhibit B

()(

=4ABC9DEAFBD=FGFHIJKLMJNOMN MRNS mn = nrst = svzhellipu t bulltvDaggerrhellipDaggerurbullbulltuhellipv hellipz~ bullmdashldquordquolsquorsquotrade š oŒŠeuro centpound ` umluml 13 deg $ $ampdegdeg degˇ amp $$deg + -+Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 31 of 57 Page ID 1790

ISNRTUKQINKKNNKL[MRJ PUWQI]MRM qyt|tytzxy rsaquoqNfraslbdquoPUhellipsbquoLUyQhellip rfraslbhellipMNSIKVUQ QNJKvUQsMiexclQQJUx[iexcliexcl_vsect_Qyenyenbrvbarbrvbar uSSRNTPL_LUUMKIaJ_WMIJJKVIONNQJJMWRMIIbQQURKLWIIJQbKLUNKMPTMNQQ_KKRY tbullbulldaggersDaggerv~vhellipmdashryrhellip~mdashrhellipDagger ŸLŽUıQŽbłpermilMtradeœsbquoNtrade_ffRŁyISMŒUQWyNUQŠlsaquo rv45657896lt7ltgt5lt PQKLMIQSNRTUKINQVNOOMVKMWNQKLIJPMXJIKMYZMPIOO NJMOOJLURMNRRMKKLIJ klltko ltgtlt85p5gt5 ouvwxrz ^^ ~ minuspermil tffŁ yenpoundpound KNOWDaggerIreggt4lt97ltndash9ƒ Dagger hellipDaggerlsaquo žko74k57ƒ ƒISNcurrenUIWIbJKWMKJYVNTKM KLONNRqIQQSNNRTUKINQQIJ_JMWNQKLIJJJPMXJIKMcOMUJMVNQKUVK_JUKBHdefABCgDEAFBDghidjlaquopoundbrvbariexclnotvIWIQbDaggerK_WMQKbullMOIMSvOObullIbLKJbullMJMRMW ordf copy

01( $2(301$$3( Exhibit B

29

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 32 of 57 Page ID 1791

EXHIBIT C

Attachment A

~ 111 ~tampi 10 11 ~bull ia1111

Something awesome is coming soon We are buildin somethin ve cool Sta tuned and be at1ent Your atience will be well aid

~lbullrbullUiUffl We can help you reduce and simplify your payments

101 Loan For iveness

1~u 0 (middottmiddotbullmiddotmiddot1 1~=I -- _~

HZamp IMUliULlampRampatiEUWi nmiddot middot-il~ fr middot 8rbullbullrcrr-

_J l _ 1 _f _ur -~t~ u L liYu

~ Income Based Pa ents

bull ~ f I - - I - I - ri u ~u-=lf ~ JU

1-bullA ---rc iM1~~ -~-bullCiel rrcl

~- middot IY 2 i C middot middotJ ll1Jmiddot 0 _ middot_middotIr i

~ LdfiJIMifJ11JJMJllfFffi

middotE-ltecl l2bullJbull iequbullt t11cit t1lt2 CtpCr~middot1e- f

JJd r g-_iraE-1 agltr-middot- ntimiddot middot)middotou

tmiddot_rt- i ic l~1ri ~rbullmiddot middot111~ umiddot -_ d_t-c

fsectmet-Naibullfyen1~poundibllffifftmI

I f-nle Vnot Nune

I ampterYOllrEmall ]

1 ~~~~ 1

If -bull 13n ~Cbull t~middot rct1~j d- gtOY- - hO- irmiddot (bulldbull) plltmiddotmiddot- leemiddotmiddot JOu

1r1cbullmiddotn111f11ri ll1fbull fcrn to ~bull~I

Triin- GU

WAWMyenEIRitiRpoundWt 44 ZiAtillampampI

Exhibit C

Case 818-cv-01987-JLS

-KE

S

Docum

ent 50-1 F

iled 020519 P

age 33 of 57 P

age ID 1792

30

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 34 of 57 Page ID 1793

EXHIBIT D

Attachment A

bull bull bull bull bull bull bull

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bull bull bull bull bull bull bull

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Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 35 of 57 Page ID 1794

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

infoaidnestcom (800) 555-1212

HOME

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1 of 6 462018 945 AM

31

Student Loan Forgiveness Loan Consolidation Student Loan Forgiveness

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 36 of 57 Page ID 1795

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

If you have Federal Student Loans yoursquore in the right place to get those loans reduced forgiven or completely discharged through our student loan forgiveness programs

Get your multiple Federal Student Loans consolidated into one forget about increasing interests and pay month to month at the lowest possible cost

We understand if yoursquore going through some hardship and thatrsquos why with us yoursquoll be able to make monthly payments based on your affordability for as low as $000 depending on your situation

2 of 6 462018 945 AM

32

Knowledge Base

Defaulted Student Loans

Wage Garnishment

Student Loan Rehabilitation

Income Based Repayment Plan

Deferment and Forbearance

Pay As You Earn Repayment Plan

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE Call 561)424-6053 today to go over your options

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 37 of 57 Page ID 1796

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

Our knowledge base is designed to provide information regarding some of the critical topics those with student loans must be aware of to be able to make educated decisions regarding their future

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

A wage garnishment is any legal procedure in which some portion of a personrsquos earnings is required to be withheld by an employer for the payment of a debt

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

With this program your payments change as your income changes and will not be longer than 25 years This is the ideal plan if you are in partial financial hardship Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard plan

Temporarily allowing you to postpone or reduce your federal student loan payments Postponing or reducing your payments may help you avoid default and future garnishments

Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard

3 of 6 462018 945 AM

33

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 38 of 57 Page ID 1797

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

4 of 6 462018 945 AM

34Attachment A

Testimonials

Latest News

Why 2016 Will Be a Big Year For Student Loans

Top Student Loan Refinancing Questions of 2015

Oba mas latest student loan plan

Things You Should Know About Public Service Loan Forgiveness

Recent Posts

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 39 of 57 Page ID 1798

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

5 of 6 462018 945 AM

35

About Us

Contact Info

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 40 of 57 Page ID 1799

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

pay-grandchild-studen

Why 2016 Will Be a Big Year For Student Loans

December 30 2015

12511110_1112367518

Top Student Loan Refinancing Questions of 2015

December 30 2015

We stand by our consultation and quote We are so sure and confident about our services and offers that they are all 100 money back guarantee risk free ndash if we donrsquot do what we promise yoursquoll get your money back

(800) 555-1212 AidnestStudenLoansgmailcom 18100 Von Karman Ave Suite 850 Irvine CA 92612

Futero SAS copy 2015 | Aidnestcom

6 of 6 462018 945

Exhibit D 36Attachment A

AM

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 41 of 57 Page ID 1800

EXHIBIT E

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 42 of 57 Page ID 1801

AIDNEST Let us help you through this national crisis

Call one of our specialists today

Forbearance amp Deferment If you are still in school and struggling to make payments on your student loans You may qualify

for Forbearance amp Deferment

Garnishment Prevention Federal law requires that the Department of Education or guarantee agency notifies you before they

begin garnishing your wages

Loan Forgiveness If you are a teacher public service worker or an individual with total and permanent disability you

httpaidnestcom[442018 115239 AM]

37Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 43 of 57 Page ID 1802

AIDNEST Let us help you through this national crisis

may qualify for this program

Consolidating Your Loans Consolidating your loans to one new loan under one lender may lower your payments and make

your life a bit more manageable

Affordable Payments If you are looking to lower your monthly payments then Income Based Repayment Plans may be

the correct choice for you

Learn more about our services

LEARN MORE

httpaidnestcom[442018 115239 AM]

38Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 44 of 57 Page ID 1803

AIDNEST Let us help you through this national crisis

Loan Forgiveness Programs Income Based Payments Student Loan Rehabilitation

Student Loan Consolidation

You may be eligible for

Loan Forgiveness Programs

In some cases individuals with Federal Student Loans may qualify to have a portion of the amount

owed to be forgiven

Get in touch with our professional team to find out which loan forgiveness program you qualify for and

how you can get rid of your unpaid student loan

L EARN MORE

httpaidnestcom[442018 115239 AM]

39Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 45 of 57 Page ID 1804

AIDNEST Let us help you through this national crisis

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE

Meet your Budget One of our advisers will help you meet your payment goals by using your budget and timeline to

determine the best plan available

httpaidnestcom[442018 115239 AM]

40Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 46 of 57 Page ID 1805

AIDNEST Let us help you through this national crisis

Simple Process We understand that lowering your payments alone can be difficult Our intuitive platform allows us

to keep the entire process simple

Customer Satisfaction We are committed to providing you with outstanding service only We look forward to working

with you

100 money back guarantee No Hassle Money Back Policy

httpaidnestcom[442018 115239 AM]

41Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 47 of 57 Page ID 1806

AIDNEST Let us help you through this national crisis

Lower your loan payments by getting in touch with one of our professionals

We design a customized repayment plan that will allow you to make payments based on your

monthly income family size and spending Get rid of the hassle of extensive paperwork and get the

help you deserve

What we can help you achieve a lower payment or lower rate

httpaidnestcom[442018 115239 AM]

42Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 48 of 57 Page ID 1807

AIDNEST Let us help you through this national crisis

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcom[442018 115239 AM]

43Exhibit E

httpaidnestcomservices[442018 115322 AM]

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 49 of 57 Page ID 1808

Services | AIDNEST Let us help you through this national crisis

INCOME BASED PAYMENTS

If you are suffering from a financial hardship you may be eligible for an

Income Based Payment In this repayment program you would have a

payment based on your income and family size The payment could be as

low as $000 per month with forgiveness at the end of 20-25 years

44

Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 50 of 57 Page ID 1809

L E ARN MORE

LOAN FORGIVENESS

If you have Federal Student Loans you may qualify for any of the student

loan forgiveness programs that are available to borrowers You may be

eligible for principal reduction loan forgiveness or a complete loan

discharge depending on your individual circumstance

L EARN MORE

PRIVATE STUDENT LOAN CONSOLIDATION

Much like refinancing a mortgage generally the biggest benefit of private

student loan consolidationstudent loan refinancing is a lower interest rate

httpaidnestcomservices[442018 115322 AM]

45Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 51 of 57 Page ID 1810

L E ARN MORE

(something federal consolidations do not offer)

STUDENT LOAN REHABILITATION

You can renew eligibility for new loans and grants and eliminate the loan

default by ldquorehabilitatingrdquo a defaulted loan

httpaidnestcomservices[442018 115322 AM]

46Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 52 of 57 Page ID 1811

CHE CK E L E G I B I L I T Y

WAGE GARNISHMENT

A wage garnishment is any legal procedure in which some portion of a

personrsquos earnings is required to be withheld by an employer for the

payment of a debt

L EARN MORE

With our fast friendly and professional services wersquoll be glad to help you get your student loans

reduced forgiven or completely discharged To this end wersquoll assist you in consolidating all your

student loans so yoursquoll have only one lender and yoursquoll start making one monthly payment Our

professionals will walk you through the best and most flexible repayment options and if itrsquos also

necessary varied deferment options and rehabilitation programs

httpaidnestcomservices[442018 115322 AM]

47Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 53 of 57 Page ID 1812

Services | AIDNEST Let us help you through this national crisis

Our CRM System

Our CRM is one of the most advanced in the industry and most importantly itrsquos linked directly to

the Department of Education (DOE) This keeps your personal and most confidential information

safe Furthermore because our CRM system is linked to the DOE our approval is 100 Through

our CRM we will be doing continuous monitoring of our process without losing sight of your

immediate needs ensuring that your case has the proper handling and most efficient process

httpaidnestcomservices[442018 115322 AM]

48Exhibit E

n

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 54 of 57 Page ID 1813

Services | AIDNEST Let us help you through this national crisis

R ECENT POSTS

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

ABOUT US

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcomservices[442018 115322 AM]

49Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 55 of 57 Page ID 1814

EXHIBIT F

s -

bullmiddot - ~ t ~ower Your Student Loan Pay~e~ts oday -- Students Helping Students Save Money

INCOME BASED PAJIIIJITPAIS

I C(gttoUC1 u~

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 56 of 57 Page ID 1815

X + C (D Not secure wwwstudoracom 0

CALL US NOW (85S) 978-S599 middot 1nfostudoracom

HOME SERVICES ABOUT US FAQ CONTACT US BLOC PRIVACY

Offering obligation and commitment free loan relief solutions

STUDENT LOAN FORGIVENESS INCOME BASED PAYMENTS LOAN CONSOLIDATION

We11 help you get your loans reduced forgiven o r Make monthly pdyments based on your affordability Get multiple Federal Student Loans consolidated into

discharged one low monthly payment

Talk to our experts concerning your

student loans

Studora is a pnvatefy owned company that helps consumers like you identify

government programs that fit your financial s1tuat1on Our loan experts will assist you in selecting the appropriate programs that WOltk with your income family size and

desired monthly payment We then prepare the appropriate documents for your review and submission All this f o r one low easy payment

Testimonials

Thank you f o r getting back to me quickly Youve been fabulous Thank you for the confirmation and for your help today Pass

during this whole process Is there a place I can go online that I this on to your sup that you were very professional and very

can leave a comment for your manager Youve made this Robert helpful and brought a sense of relief for me Thank you very

process so easy and answered every question my husband and I much and have a great rest of your day Kudos to you and your

have had teammoneywell spenL

Exhibit F 50

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 57 of 57 Page ID 1816

Services we offer

Stud ora offers document preparation services for all loan forgiveness consolidation and relief services to people who are unable to manage their finances Our mam aim is to

offer complete peace of mind to indiVidual unable to pay their student loan debt

we otter the folloWing document preparation services with complete professional assistance

amFinancial Review ffl Budget Planning

Toe first step to creating a flexible loan repayment plan is financial review we also help create a personal finance plan to ensure that you are able to

Our professmnals will look into your finances and design a custom manage your monthly budget in the most effective way This plan will keep

repayment plan that is affordable and easy to manage your spending to the minimum alloWing you to save more money for loan

repayment

Permanent Disability Forgiveness r-trTeacher Loan Forgiveness (5 You can get rid of your Federal Student Loan if you are permanently disabled Good news for teachers who are under the weight of a massiVe loan You can

now get $17 forgiven on your student loans

Public Service Loan Forgiveness Custom Debt Relief Plans

Want assistance with debt relief Get in touch with our experts who will help If you are a public service agent you can get rid of your loan after 120 days of design a loan repayment and relief plan for you based on your monthly

income and affordability payments

THERE ARE NO OBLIGATIONS OR COMMITMENTS

want to save thousands of dollars Fill out our form and get relief from your student loan for a more

peaceful tomorrow

Your Name

BiHHHi

Exhibit F 51

Attachment A

Page 24: JOSHUA S. MILLARD, BRIAN M. WELKE, pro hac vice · for which it has no legitimate claim. Noel is a Wyoming limited liability company that reported in a public document that its principal

payments have been made p1middotevent wage gampnishments

A FEW STATISTICS ABOUT STUDENT LOAN CRISIS

12 Trillion National Student Debt I he nitionil student loin debt is

now 17 trillion dollirs 1 trillion of

these are in federil student loans

Let us help you through this national

crisis Cill today for a free

evaluation

40 Million Students with Debt

In 7014 an estimated 40 million

current and former students were in

debt because of student loans If

you are one of the millions of people

struggling to pay student loans

Aiding Student Relief is here to help

$33000 Average Student Debt

The graduating class of 7014

average $33000 of student loan

debt per person Thats $3000 more

than the average in 2013 Dont be

one of the many Let Aiding Student

Relief advocate for you

Aiding Student Relief has helped cmrnllcss 1woplc reduce their student debt_ Their proven business

plan has led lo one of lhc highest s11cclSS raCs in the inltl11slly

John Standiford Associated

FTC-AID-4

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 24 of 57 Page ID 1783

23

Exhibit A

TESTIMONIALS

Til~nks to Aiding Student Rel ief Im middotI middotva ove1vvhelrnecl but Aiding The expemiddotts at l1icl i11g Student Rel ief

s1v ing $250 per month Strrd r~rt Relief expl~ inecl the were ther~ to help me when I process ancl rnacle everytl1ing cle11middot nelclecl 1t rw)s t

and sirnple

I Michael Ma 1in

Entrep e11eu1 Em iiy Jallo1 Ii Pa ul Ch is tia I1se11

Teacher Nurse

With so many programs I didnt middotconso lrclating my loans into one I love my Job but vith my high

know what was ng ht for me My monthly payment hs made life student loan payment was still

sruclent loan aclvsor walked me si1nple1 Now I can focus on 1Nhn bamiddotely getting by I don t kn ow what I

through my optio ns rnd now Imiddotn matters to me would hwe clone wthout Aiding

saving 54 I 11n1omh Stucie1middott Rel refmiddot

Ariel Hemiquez Sales co)SUltant

Stephani Seland-1 Small Busim~ss Owner

AJ 01en Museum Curator

RECENT NEWS

)lt)

o(l ttDrlTI -5

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 25 of 57 Page ID 1784

24

Exhibit A

Student Debt Crisis Business Latest Debt Collective Demands May be largely about smallest Student

borrnwers US News amp World Loan Crisis is fa frorn ove The Debt Collective is a group of Report-May 162015 last month Two new reports suggest the college students calling the Fedemiddotal Reserve Bank of New student loan crisis is easing them-se1ves the Corinthian York repor ced that stuclent loan somewhat as the economy Fifteen who are refusing to pay balances rose to 16 trillio n and improves but the crisis is far back their student loins As pa t that 113 per cent of that is in from ove the College Board of this effort the Debt Collective repo t~ tot31 borrowing fell by 8 has written an open lette to the pEbull1 cent between 2012-13 and Department of Education f l llJ 20 13-14 The organization

About Us 11 1 i~d1middot1r F th~~- h1~ ff t1middot~11middot=cl =i~=middott- 1middot __31middotmiddotIIgt middot bullmiddot11

middot- I ( )ntir il t l~i -r_il fr~~

Address bull middot tc1ltj-1r_ =i ~

middot l t1~t 1middot1 fcJ middot~_1 1 I l11 - Hbull 1 tr

~t (~~ 1 12bull~11 T 1 1- - 8555105400

FTC-AID-6

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 26 of 57 Page ID 1785

25

Exhibit A

f - g+ in O) ~ PRIVACY POLICY

This privacy statement discloses the privacy practices for AidllII Student Relief Because Aiding Studen Relief wonts to demonstrate ts firm commlcmell to your

privacy Aiding Sudent Relief hes greed to disclose ls 1rifor111atlori g1thering and dlssem1n1t1on prct1cts Aidlns Studtrit Relief will notify you of

INFORMATION COLLECTION At-ID USE

Aiding Student Relief is the sole owner of the rformMlon collected on this site We will not sell shire or rent this information 10 others In way different from what Is

disclosed 1n this statement Aldln1 StudeM Relief collects 1nform111on throuah this site from our prospective end existing clients at several different poin on our web

site We use their contact Informii on to send information bout our company and to service exsMs accounts Users may optbullout of rece11ns future malllngs see the

cholceoptbullout section below Contect and Financial information that 1s collected Is used for verifying your name address and other informa1on as well as to boll you for

your use of our Gerv1ces using Information from third party sourcH Information about your computer hardwre and software Is automatically collected by Aiding

Student Relief and may be shared in asgregate with third parties whose services are used for traffic analysis purposes This Ir formation includes your IP address

browser type domain names access times and referring Web site addresses Ths information is no tied to personally Identifiable Information This 1nformatlor s used

by Aiding Student Relief to malMan no Improve the quality of the Hrvct and to senerae statistics resardlng use of he Aiding Student Relief site We use third party

services to bill for serlces and to provide other services like our Live Help chat We store the transcripts from these chats for customer service Improvement These

third party service providers are not permitted to use your infornon for any secondary purposes

Thank you and cheers

FTC-AID-7

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 27 of 57 Page ID 1786

26

Exhibit A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 28 of 57 Page ID 1787

EXHIBIT B

Attachment A

((

z | ~

AIDINGSTUDENTRELIEF

bull bull bull bull bull

13 deg $ $ampdegdeg deg() ˝ amp $$deg( + -+Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 29 of 57 Page ID 1788

bulldaggerDagger Daggermdashndash Daggerhellip ƒfrasl hellip lsaquorsaquobullminuspermilminushellip bdquolsaquoldquo rsaquordquobulllsquo fraslbullrsquopermillsaquofraslpermilminushellip sbquo

4556789fADlt=gtA9BCAD

DZgtA=EFGHIJFKLMNOPFQOGFHIQRSTLKSUMMNOPLHMTFIVRWXHKKNIFNUNOPRLFGSHKSRVRVNQ

f e=klHMW

9SI]UQMSNSOQOHHPFK YaSTHHVVJFMHcVGNOJVHHFKKPSUHMLIUOQN_PL[KSVFGJPRSDTHRFPLIP=SNDC==GFdFIP9VaNHQTWSRPbHF_PSKSVNMPMHNIO XNNIIFRKNF7IKSQQMHFNDVPOS9IAeTHPdKSUMMFNKHONP 8aF_KSNVPHTNIMNR[POVFgNPTHLNHIgtMFI YTFHIdFFI D9aHVR_KNKHFHIWIQOTHIQbFFP

lt=Dkgt=L]oHUKMMH ihTFNIORI THHVPRFMVKgtNJ_NFFbIVSJI]IFjdGGVNNN lt=TFKPPNF 9DaFGmVHPGRJMFNNQOSGnPFFTNLUNHPMIMTFVNJOKMIWV

27

]UMNOHPFRKNVSHKKISIRWRrGZNJONgtNjTHKHMI=cQgtORHVPKSOUMddUNKSPIdspNVPNq_ lt=gtBTHFHPb=HFILGFHMt DTFuFIUVFRPNTFIMINVWOPRVOQFIV sFQFPHKKH vaIPNFVcSyOFSPRFMRNVOJH_gtVFDVUJAN9FPwFuVFJLFHMP_VTFFdSIIVdNHUPxI=DQSROJGASHIVdDSNMINONPPaHdOHdPFHRIWVFFHdFIGM˙ 01 $2 301 $$3 ( Exhibit B

8

~ldquo

middot

676EBCEDK5ltAC]5EF_5665E7gt5lt7aFb688E588lt76B5E6F8EBAC78lt76cdddefghijhggklmknmopqprpopst u

13 deg $ $ampdegdeg degˇ amp $$deg + -+Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 30 of 57 Page ID 1789 () ( vPSZwPxyYTUZUWWzxPyxSWMZWPU|SWUWYZ~YTY~QSWbullYXRwU~UxSdaggerXQ~UZXvPSZWSOVQSYNOXPRSTUSDaggerPxXYPZPNXRUSPQZXPbullU~SOhellipUNPxyYTUZmdash zUxSZUZXndashYWShellipYYXOwPxyYTUZUWWMNOPQx~YWShellipYYXOYWUƒDaggerU|XU~XPSWXfrasllsaquoPZXRWPxPxUOPQSOVQSYNONPxDaggerUxSZUZX~YWShellipYYXONPxyYTUZUWWmdash

rsaquominus MZ|PUpermilSWUzSOUZXWbdquoDaggerUxYP~PNZSZ|YSRSx~WRYDaggerSOVQSYNOOPQNPxSZMZ|PUpermilSWU~rdquoUDaggerSOUZXzSZmdashMZSZO|SWUWXRYWUSZWOPQDaggerSOZPXRYZymdash zQhellipY|daggerUxTY|UvPSZwPxyYTUZUWWMNOPQbullPxlsquoNPxSyPTUxZUZXPxySZYrsquoSXYPZSXS|YXOWXSXUPxNU~UxSUTUOPQSOVQSYNONPxXRUzQhellipY|daggerUxTY|UvPSZwPxyYTUZUWWDaggerxPyxSmdashsbquotrade f8Ef8E78FCB6C8EŁPQSOhellipUShellipUXP|PhellipYZUQXYDaggerUNU~UxSWXQ~UZXPSZWYZXPPZUZUbullPSZbullYXRSPbullUxPxUSŒPx~ShellipUPZXRODaggerSOUZXmdashvPSZ|PZWPY~SXYPZDaggerxPyxSW|SZRUDaggerOPQVQSYNONPxS~~YXYPZSDaggerxPyxSW YlsquoU PSZ NPxyYTUZUWWDaggerxPyxSWPxzQhellipY|daggerUxTY|UvPSZwPxyYTUZUWWmdash ŠmŸŽıłŠm 57gt8A57A5B= 8E65C76B5E6F8EB5=6G

PONM[5 QRSTUVQU PYXWZW lt4556789588lt959=lt CD lt H5FICEDJ8KA5LCD

A565E7gt57 œšžeuroiexclcentpoundyenbrvbarsectbrvbareurocopypoundsectlaquoeuropoundlaquobrvbarlaquoregplusmncentbrvbareurocent microparalaquo europoundž raquoY|frac14frac12 plusmncurrenRSUraquoSxXYZeuropoundlaquo laquoeurolaquoordf frac34

^ ˙ ( (

28

Attachment A

01 $2 301 $$3 ( Exhibit B

()(

=4ABC9DEAFBD=FGFHIJKLMJNOMN MRNS mn = nrst = svzhellipu t bulltvDaggerrhellipDaggerurbullbulltuhellipv hellipz~ bullmdashldquordquolsquorsquotrade š oŒŠeuro centpound ` umluml 13 deg $ $ampdegdeg degˇ amp $$deg + -+Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 31 of 57 Page ID 1790

ISNRTUKQINKKNNKL[MRJ PUWQI]MRM qyt|tytzxy rsaquoqNfraslbdquoPUhellipsbquoLUyQhellip rfraslbhellipMNSIKVUQ QNJKvUQsMiexclQQJUx[iexcliexcl_vsect_Qyenyenbrvbarbrvbar uSSRNTPL_LUUMKIaJ_WMIJJKVIONNQJJMWRMIIbQQURKLWIIJQbKLUNKMPTMNQQ_KKRY tbullbulldaggersDaggerv~vhellipmdashryrhellip~mdashrhellipDagger ŸLŽUıQŽbłpermilMtradeœsbquoNtrade_ffRŁyISMŒUQWyNUQŠlsaquo rv45657896lt7ltgt5lt PQKLMIQSNRTUKINQVNOOMVKMWNQKLIJPMXJIKMYZMPIOO NJMOOJLURMNRRMKKLIJ klltko ltgtlt85p5gt5 ouvwxrz ^^ ~ minuspermil tffŁ yenpoundpound KNOWDaggerIreggt4lt97ltndash9ƒ Dagger hellipDaggerlsaquo žko74k57ƒ ƒISNcurrenUIWIbJKWMKJYVNTKM KLONNRqIQQSNNRTUKINQQIJ_JMWNQKLIJJJPMXJIKMcOMUJMVNQKUVK_JUKBHdefABCgDEAFBDghidjlaquopoundbrvbariexclnotvIWIQbDaggerK_WMQKbullMOIMSvOObullIbLKJbullMJMRMW ordf copy

01( $2(301$$3( Exhibit B

29

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 32 of 57 Page ID 1791

EXHIBIT C

Attachment A

~ 111 ~tampi 10 11 ~bull ia1111

Something awesome is coming soon We are buildin somethin ve cool Sta tuned and be at1ent Your atience will be well aid

~lbullrbullUiUffl We can help you reduce and simplify your payments

101 Loan For iveness

1~u 0 (middottmiddotbullmiddotmiddot1 1~=I -- _~

HZamp IMUliULlampRampatiEUWi nmiddot middot-il~ fr middot 8rbullbullrcrr-

_J l _ 1 _f _ur -~t~ u L liYu

~ Income Based Pa ents

bull ~ f I - - I - I - ri u ~u-=lf ~ JU

1-bullA ---rc iM1~~ -~-bullCiel rrcl

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Exhibit C

Case 818-cv-01987-JLS

-KE

S

Docum

ent 50-1 F

iled 020519 P

age 33 of 57 P

age ID 1792

30

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 34 of 57 Page ID 1793

EXHIBIT D

Attachment A

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Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 35 of 57 Page ID 1794

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

infoaidnestcom (800) 555-1212

HOME

ABOUT US

SERVICES

FAQ

BLOG

CONTACT

HOME ABOUT US SERVICES FAQ BLOG CONTACT

1 of 6 462018 945 AM

31

Student Loan Forgiveness Loan Consolidation Student Loan Forgiveness

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 36 of 57 Page ID 1795

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

If you have Federal Student Loans yoursquore in the right place to get those loans reduced forgiven or completely discharged through our student loan forgiveness programs

Get your multiple Federal Student Loans consolidated into one forget about increasing interests and pay month to month at the lowest possible cost

We understand if yoursquore going through some hardship and thatrsquos why with us yoursquoll be able to make monthly payments based on your affordability for as low as $000 depending on your situation

2 of 6 462018 945 AM

32

Knowledge Base

Defaulted Student Loans

Wage Garnishment

Student Loan Rehabilitation

Income Based Repayment Plan

Deferment and Forbearance

Pay As You Earn Repayment Plan

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE Call 561)424-6053 today to go over your options

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 37 of 57 Page ID 1796

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

Our knowledge base is designed to provide information regarding some of the critical topics those with student loans must be aware of to be able to make educated decisions regarding their future

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

A wage garnishment is any legal procedure in which some portion of a personrsquos earnings is required to be withheld by an employer for the payment of a debt

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

With this program your payments change as your income changes and will not be longer than 25 years This is the ideal plan if you are in partial financial hardship Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard plan

Temporarily allowing you to postpone or reduce your federal student loan payments Postponing or reducing your payments may help you avoid default and future garnishments

Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard

3 of 6 462018 945 AM

33

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 38 of 57 Page ID 1797

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

4 of 6 462018 945 AM

34Attachment A

Testimonials

Latest News

Why 2016 Will Be a Big Year For Student Loans

Top Student Loan Refinancing Questions of 2015

Oba mas latest student loan plan

Things You Should Know About Public Service Loan Forgiveness

Recent Posts

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 39 of 57 Page ID 1798

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

5 of 6 462018 945 AM

35

About Us

Contact Info

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 40 of 57 Page ID 1799

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

pay-grandchild-studen

Why 2016 Will Be a Big Year For Student Loans

December 30 2015

12511110_1112367518

Top Student Loan Refinancing Questions of 2015

December 30 2015

We stand by our consultation and quote We are so sure and confident about our services and offers that they are all 100 money back guarantee risk free ndash if we donrsquot do what we promise yoursquoll get your money back

(800) 555-1212 AidnestStudenLoansgmailcom 18100 Von Karman Ave Suite 850 Irvine CA 92612

Futero SAS copy 2015 | Aidnestcom

6 of 6 462018 945

Exhibit D 36Attachment A

AM

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 41 of 57 Page ID 1800

EXHIBIT E

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 42 of 57 Page ID 1801

AIDNEST Let us help you through this national crisis

Call one of our specialists today

Forbearance amp Deferment If you are still in school and struggling to make payments on your student loans You may qualify

for Forbearance amp Deferment

Garnishment Prevention Federal law requires that the Department of Education or guarantee agency notifies you before they

begin garnishing your wages

Loan Forgiveness If you are a teacher public service worker or an individual with total and permanent disability you

httpaidnestcom[442018 115239 AM]

37Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 43 of 57 Page ID 1802

AIDNEST Let us help you through this national crisis

may qualify for this program

Consolidating Your Loans Consolidating your loans to one new loan under one lender may lower your payments and make

your life a bit more manageable

Affordable Payments If you are looking to lower your monthly payments then Income Based Repayment Plans may be

the correct choice for you

Learn more about our services

LEARN MORE

httpaidnestcom[442018 115239 AM]

38Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 44 of 57 Page ID 1803

AIDNEST Let us help you through this national crisis

Loan Forgiveness Programs Income Based Payments Student Loan Rehabilitation

Student Loan Consolidation

You may be eligible for

Loan Forgiveness Programs

In some cases individuals with Federal Student Loans may qualify to have a portion of the amount

owed to be forgiven

Get in touch with our professional team to find out which loan forgiveness program you qualify for and

how you can get rid of your unpaid student loan

L EARN MORE

httpaidnestcom[442018 115239 AM]

39Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 45 of 57 Page ID 1804

AIDNEST Let us help you through this national crisis

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE

Meet your Budget One of our advisers will help you meet your payment goals by using your budget and timeline to

determine the best plan available

httpaidnestcom[442018 115239 AM]

40Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 46 of 57 Page ID 1805

AIDNEST Let us help you through this national crisis

Simple Process We understand that lowering your payments alone can be difficult Our intuitive platform allows us

to keep the entire process simple

Customer Satisfaction We are committed to providing you with outstanding service only We look forward to working

with you

100 money back guarantee No Hassle Money Back Policy

httpaidnestcom[442018 115239 AM]

41Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 47 of 57 Page ID 1806

AIDNEST Let us help you through this national crisis

Lower your loan payments by getting in touch with one of our professionals

We design a customized repayment plan that will allow you to make payments based on your

monthly income family size and spending Get rid of the hassle of extensive paperwork and get the

help you deserve

What we can help you achieve a lower payment or lower rate

httpaidnestcom[442018 115239 AM]

42Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 48 of 57 Page ID 1807

AIDNEST Let us help you through this national crisis

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcom[442018 115239 AM]

43Exhibit E

httpaidnestcomservices[442018 115322 AM]

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 49 of 57 Page ID 1808

Services | AIDNEST Let us help you through this national crisis

INCOME BASED PAYMENTS

If you are suffering from a financial hardship you may be eligible for an

Income Based Payment In this repayment program you would have a

payment based on your income and family size The payment could be as

low as $000 per month with forgiveness at the end of 20-25 years

44

Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 50 of 57 Page ID 1809

L E ARN MORE

LOAN FORGIVENESS

If you have Federal Student Loans you may qualify for any of the student

loan forgiveness programs that are available to borrowers You may be

eligible for principal reduction loan forgiveness or a complete loan

discharge depending on your individual circumstance

L EARN MORE

PRIVATE STUDENT LOAN CONSOLIDATION

Much like refinancing a mortgage generally the biggest benefit of private

student loan consolidationstudent loan refinancing is a lower interest rate

httpaidnestcomservices[442018 115322 AM]

45Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 51 of 57 Page ID 1810

L E ARN MORE

(something federal consolidations do not offer)

STUDENT LOAN REHABILITATION

You can renew eligibility for new loans and grants and eliminate the loan

default by ldquorehabilitatingrdquo a defaulted loan

httpaidnestcomservices[442018 115322 AM]

46Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 52 of 57 Page ID 1811

CHE CK E L E G I B I L I T Y

WAGE GARNISHMENT

A wage garnishment is any legal procedure in which some portion of a

personrsquos earnings is required to be withheld by an employer for the

payment of a debt

L EARN MORE

With our fast friendly and professional services wersquoll be glad to help you get your student loans

reduced forgiven or completely discharged To this end wersquoll assist you in consolidating all your

student loans so yoursquoll have only one lender and yoursquoll start making one monthly payment Our

professionals will walk you through the best and most flexible repayment options and if itrsquos also

necessary varied deferment options and rehabilitation programs

httpaidnestcomservices[442018 115322 AM]

47Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 53 of 57 Page ID 1812

Services | AIDNEST Let us help you through this national crisis

Our CRM System

Our CRM is one of the most advanced in the industry and most importantly itrsquos linked directly to

the Department of Education (DOE) This keeps your personal and most confidential information

safe Furthermore because our CRM system is linked to the DOE our approval is 100 Through

our CRM we will be doing continuous monitoring of our process without losing sight of your

immediate needs ensuring that your case has the proper handling and most efficient process

httpaidnestcomservices[442018 115322 AM]

48Exhibit E

n

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 54 of 57 Page ID 1813

Services | AIDNEST Let us help you through this national crisis

R ECENT POSTS

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

ABOUT US

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcomservices[442018 115322 AM]

49Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 55 of 57 Page ID 1814

EXHIBIT F

s -

bullmiddot - ~ t ~ower Your Student Loan Pay~e~ts oday -- Students Helping Students Save Money

INCOME BASED PAJIIIJITPAIS

I C(gttoUC1 u~

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 56 of 57 Page ID 1815

X + C (D Not secure wwwstudoracom 0

CALL US NOW (85S) 978-S599 middot 1nfostudoracom

HOME SERVICES ABOUT US FAQ CONTACT US BLOC PRIVACY

Offering obligation and commitment free loan relief solutions

STUDENT LOAN FORGIVENESS INCOME BASED PAYMENTS LOAN CONSOLIDATION

We11 help you get your loans reduced forgiven o r Make monthly pdyments based on your affordability Get multiple Federal Student Loans consolidated into

discharged one low monthly payment

Talk to our experts concerning your

student loans

Studora is a pnvatefy owned company that helps consumers like you identify

government programs that fit your financial s1tuat1on Our loan experts will assist you in selecting the appropriate programs that WOltk with your income family size and

desired monthly payment We then prepare the appropriate documents for your review and submission All this f o r one low easy payment

Testimonials

Thank you f o r getting back to me quickly Youve been fabulous Thank you for the confirmation and for your help today Pass

during this whole process Is there a place I can go online that I this on to your sup that you were very professional and very

can leave a comment for your manager Youve made this Robert helpful and brought a sense of relief for me Thank you very

process so easy and answered every question my husband and I much and have a great rest of your day Kudos to you and your

have had teammoneywell spenL

Exhibit F 50

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 57 of 57 Page ID 1816

Services we offer

Stud ora offers document preparation services for all loan forgiveness consolidation and relief services to people who are unable to manage their finances Our mam aim is to

offer complete peace of mind to indiVidual unable to pay their student loan debt

we otter the folloWing document preparation services with complete professional assistance

amFinancial Review ffl Budget Planning

Toe first step to creating a flexible loan repayment plan is financial review we also help create a personal finance plan to ensure that you are able to

Our professmnals will look into your finances and design a custom manage your monthly budget in the most effective way This plan will keep

repayment plan that is affordable and easy to manage your spending to the minimum alloWing you to save more money for loan

repayment

Permanent Disability Forgiveness r-trTeacher Loan Forgiveness (5 You can get rid of your Federal Student Loan if you are permanently disabled Good news for teachers who are under the weight of a massiVe loan You can

now get $17 forgiven on your student loans

Public Service Loan Forgiveness Custom Debt Relief Plans

Want assistance with debt relief Get in touch with our experts who will help If you are a public service agent you can get rid of your loan after 120 days of design a loan repayment and relief plan for you based on your monthly

income and affordability payments

THERE ARE NO OBLIGATIONS OR COMMITMENTS

want to save thousands of dollars Fill out our form and get relief from your student loan for a more

peaceful tomorrow

Your Name

BiHHHi

Exhibit F 51

Attachment A

Page 25: JOSHUA S. MILLARD, BRIAN M. WELKE, pro hac vice · for which it has no legitimate claim. Noel is a Wyoming limited liability company that reported in a public document that its principal

TESTIMONIALS

Til~nks to Aiding Student Rel ief Im middotI middotva ove1vvhelrnecl but Aiding The expemiddotts at l1icl i11g Student Rel ief

s1v ing $250 per month Strrd r~rt Relief expl~ inecl the were ther~ to help me when I process ancl rnacle everytl1ing cle11middot nelclecl 1t rw)s t

and sirnple

I Michael Ma 1in

Entrep e11eu1 Em iiy Jallo1 Ii Pa ul Ch is tia I1se11

Teacher Nurse

With so many programs I didnt middotconso lrclating my loans into one I love my Job but vith my high

know what was ng ht for me My monthly payment hs made life student loan payment was still

sruclent loan aclvsor walked me si1nple1 Now I can focus on 1Nhn bamiddotely getting by I don t kn ow what I

through my optio ns rnd now Imiddotn matters to me would hwe clone wthout Aiding

saving 54 I 11n1omh Stucie1middott Rel refmiddot

Ariel Hemiquez Sales co)SUltant

Stephani Seland-1 Small Busim~ss Owner

AJ 01en Museum Curator

RECENT NEWS

)lt)

o(l ttDrlTI -5

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 25 of 57 Page ID 1784

24

Exhibit A

Student Debt Crisis Business Latest Debt Collective Demands May be largely about smallest Student

borrnwers US News amp World Loan Crisis is fa frorn ove The Debt Collective is a group of Report-May 162015 last month Two new reports suggest the college students calling the Fedemiddotal Reserve Bank of New student loan crisis is easing them-se1ves the Corinthian York repor ced that stuclent loan somewhat as the economy Fifteen who are refusing to pay balances rose to 16 trillio n and improves but the crisis is far back their student loins As pa t that 113 per cent of that is in from ove the College Board of this effort the Debt Collective repo t~ tot31 borrowing fell by 8 has written an open lette to the pEbull1 cent between 2012-13 and Department of Education f l llJ 20 13-14 The organization

About Us 11 1 i~d1middot1r F th~~- h1~ ff t1middot~11middot=cl =i~=middott- 1middot __31middotmiddotIIgt middot bullmiddot11

middot- I ( )ntir il t l~i -r_il fr~~

Address bull middot tc1ltj-1r_ =i ~

middot l t1~t 1middot1 fcJ middot~_1 1 I l11 - Hbull 1 tr

~t (~~ 1 12bull~11 T 1 1- - 8555105400

FTC-AID-6

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 26 of 57 Page ID 1785

25

Exhibit A

f - g+ in O) ~ PRIVACY POLICY

This privacy statement discloses the privacy practices for AidllII Student Relief Because Aiding Studen Relief wonts to demonstrate ts firm commlcmell to your

privacy Aiding Sudent Relief hes greed to disclose ls 1rifor111atlori g1thering and dlssem1n1t1on prct1cts Aidlns Studtrit Relief will notify you of

INFORMATION COLLECTION At-ID USE

Aiding Student Relief is the sole owner of the rformMlon collected on this site We will not sell shire or rent this information 10 others In way different from what Is

disclosed 1n this statement Aldln1 StudeM Relief collects 1nform111on throuah this site from our prospective end existing clients at several different poin on our web

site We use their contact Informii on to send information bout our company and to service exsMs accounts Users may optbullout of rece11ns future malllngs see the

cholceoptbullout section below Contect and Financial information that 1s collected Is used for verifying your name address and other informa1on as well as to boll you for

your use of our Gerv1ces using Information from third party sourcH Information about your computer hardwre and software Is automatically collected by Aiding

Student Relief and may be shared in asgregate with third parties whose services are used for traffic analysis purposes This Ir formation includes your IP address

browser type domain names access times and referring Web site addresses Ths information is no tied to personally Identifiable Information This 1nformatlor s used

by Aiding Student Relief to malMan no Improve the quality of the Hrvct and to senerae statistics resardlng use of he Aiding Student Relief site We use third party

services to bill for serlces and to provide other services like our Live Help chat We store the transcripts from these chats for customer service Improvement These

third party service providers are not permitted to use your infornon for any secondary purposes

Thank you and cheers

FTC-AID-7

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 27 of 57 Page ID 1786

26

Exhibit A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 28 of 57 Page ID 1787

EXHIBIT B

Attachment A

((

z | ~

AIDINGSTUDENTRELIEF

bull bull bull bull bull

13 deg $ $ampdegdeg deg() ˝ amp $$deg( + -+Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 29 of 57 Page ID 1788

bulldaggerDagger Daggermdashndash Daggerhellip ƒfrasl hellip lsaquorsaquobullminuspermilminushellip bdquolsaquoldquo rsaquordquobulllsquo fraslbullrsquopermillsaquofraslpermilminushellip sbquo

4556789fADlt=gtA9BCAD

DZgtA=EFGHIJFKLMNOPFQOGFHIQRSTLKSUMMNOPLHMTFIVRWXHKKNIFNUNOPRLFGSHKSRVRVNQ

f e=klHMW

9SI]UQMSNSOQOHHPFK YaSTHHVVJFMHcVGNOJVHHFKKPSUHMLIUOQN_PL[KSVFGJPRSDTHRFPLIP=SNDC==GFdFIP9VaNHQTWSRPbHF_PSKSVNMPMHNIO XNNIIFRKNF7IKSQQMHFNDVPOS9IAeTHPdKSUMMFNKHONP 8aF_KSNVPHTNIMNR[POVFgNPTHLNHIgtMFI YTFHIdFFI D9aHVR_KNKHFHIWIQOTHIQbFFP

lt=Dkgt=L]oHUKMMH ihTFNIORI THHVPRFMVKgtNJ_NFFbIVSJI]IFjdGGVNNN lt=TFKPPNF 9DaFGmVHPGRJMFNNQOSGnPFFTNLUNHPMIMTFVNJOKMIWV

27

]UMNOHPFRKNVSHKKISIRWRrGZNJONgtNjTHKHMI=cQgtORHVPKSOUMddUNKSPIdspNVPNq_ lt=gtBTHFHPb=HFILGFHMt DTFuFIUVFRPNTFIMINVWOPRVOQFIV sFQFPHKKH vaIPNFVcSyOFSPRFMRNVOJH_gtVFDVUJAN9FPwFuVFJLFHMP_VTFFdSIIVdNHUPxI=DQSROJGASHIVdDSNMINONPPaHdOHdPFHRIWVFFHdFIGM˙ 01 $2 301 $$3 ( Exhibit B

8

~ldquo

middot

676EBCEDK5ltAC]5EF_5665E7gt5lt7aFb688E588lt76B5E6F8EBAC78lt76cdddefghijhggklmknmopqprpopst u

13 deg $ $ampdegdeg degˇ amp $$deg + -+Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 30 of 57 Page ID 1789 () ( vPSZwPxyYTUZUWWzxPyxSWMZWPU|SWUWYZ~YTY~QSWbullYXRwU~UxSdaggerXQ~UZXvPSZWSOVQSYNOXPRSTUSDaggerPxXYPZPNXRUSPQZXPbullU~SOhellipUNPxyYTUZmdash zUxSZUZXndashYWShellipYYXOwPxyYTUZUWWMNOPQx~YWShellipYYXOYWUƒDaggerU|XU~XPSWXfrasllsaquoPZXRWPxPxUOPQSOVQSYNONPxDaggerUxSZUZX~YWShellipYYXONPxyYTUZUWWmdash

rsaquominus MZ|PUpermilSWUzSOUZXWbdquoDaggerUxYP~PNZSZ|YSRSx~WRYDaggerSOVQSYNOOPQNPxSZMZ|PUpermilSWU~rdquoUDaggerSOUZXzSZmdashMZSZO|SWUWXRYWUSZWOPQDaggerSOZPXRYZymdash zQhellipY|daggerUxTY|UvPSZwPxyYTUZUWWMNOPQbullPxlsquoNPxSyPTUxZUZXPxySZYrsquoSXYPZSXS|YXOWXSXUPxNU~UxSUTUOPQSOVQSYNONPxXRUzQhellipY|daggerUxTY|UvPSZwPxyYTUZUWWDaggerxPyxSmdashsbquotrade f8Ef8E78FCB6C8EŁPQSOhellipUShellipUXP|PhellipYZUQXYDaggerUNU~UxSWXQ~UZXPSZWYZXPPZUZUbullPSZbullYXRSPbullUxPxUSŒPx~ShellipUPZXRODaggerSOUZXmdashvPSZ|PZWPY~SXYPZDaggerxPyxSW|SZRUDaggerOPQVQSYNONPxS~~YXYPZSDaggerxPyxSW YlsquoU PSZ NPxyYTUZUWWDaggerxPyxSWPxzQhellipY|daggerUxTY|UvPSZwPxyYTUZUWWmdash ŠmŸŽıłŠm 57gt8A57A5B= 8E65C76B5E6F8EB5=6G

PONM[5 QRSTUVQU PYXWZW lt4556789588lt959=lt CD lt H5FICEDJ8KA5LCD

A565E7gt57 œšžeuroiexclcentpoundyenbrvbarsectbrvbareurocopypoundsectlaquoeuropoundlaquobrvbarlaquoregplusmncentbrvbareurocent microparalaquo europoundž raquoY|frac14frac12 plusmncurrenRSUraquoSxXYZeuropoundlaquo laquoeurolaquoordf frac34

^ ˙ ( (

28

Attachment A

01 $2 301 $$3 ( Exhibit B

()(

=4ABC9DEAFBD=FGFHIJKLMJNOMN MRNS mn = nrst = svzhellipu t bulltvDaggerrhellipDaggerurbullbulltuhellipv hellipz~ bullmdashldquordquolsquorsquotrade š oŒŠeuro centpound ` umluml 13 deg $ $ampdegdeg degˇ amp $$deg + -+Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 31 of 57 Page ID 1790

ISNRTUKQINKKNNKL[MRJ PUWQI]MRM qyt|tytzxy rsaquoqNfraslbdquoPUhellipsbquoLUyQhellip rfraslbhellipMNSIKVUQ QNJKvUQsMiexclQQJUx[iexcliexcl_vsect_Qyenyenbrvbarbrvbar uSSRNTPL_LUUMKIaJ_WMIJJKVIONNQJJMWRMIIbQQURKLWIIJQbKLUNKMPTMNQQ_KKRY tbullbulldaggersDaggerv~vhellipmdashryrhellip~mdashrhellipDagger ŸLŽUıQŽbłpermilMtradeœsbquoNtrade_ffRŁyISMŒUQWyNUQŠlsaquo rv45657896lt7ltgt5lt PQKLMIQSNRTUKINQVNOOMVKMWNQKLIJPMXJIKMYZMPIOO NJMOOJLURMNRRMKKLIJ klltko ltgtlt85p5gt5 ouvwxrz ^^ ~ minuspermil tffŁ yenpoundpound KNOWDaggerIreggt4lt97ltndash9ƒ Dagger hellipDaggerlsaquo žko74k57ƒ ƒISNcurrenUIWIbJKWMKJYVNTKM KLONNRqIQQSNNRTUKINQQIJ_JMWNQKLIJJJPMXJIKMcOMUJMVNQKUVK_JUKBHdefABCgDEAFBDghidjlaquopoundbrvbariexclnotvIWIQbDaggerK_WMQKbullMOIMSvOObullIbLKJbullMJMRMW ordf copy

01( $2(301$$3( Exhibit B

29

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 32 of 57 Page ID 1791

EXHIBIT C

Attachment A

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Something awesome is coming soon We are buildin somethin ve cool Sta tuned and be at1ent Your atience will be well aid

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101 Loan For iveness

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Exhibit C

Case 818-cv-01987-JLS

-KE

S

Docum

ent 50-1 F

iled 020519 P

age 33 of 57 P

age ID 1792

30

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 34 of 57 Page ID 1793

EXHIBIT D

Attachment A

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Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 35 of 57 Page ID 1794

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

infoaidnestcom (800) 555-1212

HOME

ABOUT US

SERVICES

FAQ

BLOG

CONTACT

HOME ABOUT US SERVICES FAQ BLOG CONTACT

1 of 6 462018 945 AM

31

Student Loan Forgiveness Loan Consolidation Student Loan Forgiveness

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 36 of 57 Page ID 1795

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

If you have Federal Student Loans yoursquore in the right place to get those loans reduced forgiven or completely discharged through our student loan forgiveness programs

Get your multiple Federal Student Loans consolidated into one forget about increasing interests and pay month to month at the lowest possible cost

We understand if yoursquore going through some hardship and thatrsquos why with us yoursquoll be able to make monthly payments based on your affordability for as low as $000 depending on your situation

2 of 6 462018 945 AM

32

Knowledge Base

Defaulted Student Loans

Wage Garnishment

Student Loan Rehabilitation

Income Based Repayment Plan

Deferment and Forbearance

Pay As You Earn Repayment Plan

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE Call 561)424-6053 today to go over your options

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 37 of 57 Page ID 1796

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

Our knowledge base is designed to provide information regarding some of the critical topics those with student loans must be aware of to be able to make educated decisions regarding their future

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

A wage garnishment is any legal procedure in which some portion of a personrsquos earnings is required to be withheld by an employer for the payment of a debt

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

With this program your payments change as your income changes and will not be longer than 25 years This is the ideal plan if you are in partial financial hardship Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard plan

Temporarily allowing you to postpone or reduce your federal student loan payments Postponing or reducing your payments may help you avoid default and future garnishments

Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard

3 of 6 462018 945 AM

33

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 38 of 57 Page ID 1797

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

4 of 6 462018 945 AM

34Attachment A

Testimonials

Latest News

Why 2016 Will Be a Big Year For Student Loans

Top Student Loan Refinancing Questions of 2015

Oba mas latest student loan plan

Things You Should Know About Public Service Loan Forgiveness

Recent Posts

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 39 of 57 Page ID 1798

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

5 of 6 462018 945 AM

35

About Us

Contact Info

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 40 of 57 Page ID 1799

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

pay-grandchild-studen

Why 2016 Will Be a Big Year For Student Loans

December 30 2015

12511110_1112367518

Top Student Loan Refinancing Questions of 2015

December 30 2015

We stand by our consultation and quote We are so sure and confident about our services and offers that they are all 100 money back guarantee risk free ndash if we donrsquot do what we promise yoursquoll get your money back

(800) 555-1212 AidnestStudenLoansgmailcom 18100 Von Karman Ave Suite 850 Irvine CA 92612

Futero SAS copy 2015 | Aidnestcom

6 of 6 462018 945

Exhibit D 36Attachment A

AM

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 41 of 57 Page ID 1800

EXHIBIT E

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 42 of 57 Page ID 1801

AIDNEST Let us help you through this national crisis

Call one of our specialists today

Forbearance amp Deferment If you are still in school and struggling to make payments on your student loans You may qualify

for Forbearance amp Deferment

Garnishment Prevention Federal law requires that the Department of Education or guarantee agency notifies you before they

begin garnishing your wages

Loan Forgiveness If you are a teacher public service worker or an individual with total and permanent disability you

httpaidnestcom[442018 115239 AM]

37Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 43 of 57 Page ID 1802

AIDNEST Let us help you through this national crisis

may qualify for this program

Consolidating Your Loans Consolidating your loans to one new loan under one lender may lower your payments and make

your life a bit more manageable

Affordable Payments If you are looking to lower your monthly payments then Income Based Repayment Plans may be

the correct choice for you

Learn more about our services

LEARN MORE

httpaidnestcom[442018 115239 AM]

38Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 44 of 57 Page ID 1803

AIDNEST Let us help you through this national crisis

Loan Forgiveness Programs Income Based Payments Student Loan Rehabilitation

Student Loan Consolidation

You may be eligible for

Loan Forgiveness Programs

In some cases individuals with Federal Student Loans may qualify to have a portion of the amount

owed to be forgiven

Get in touch with our professional team to find out which loan forgiveness program you qualify for and

how you can get rid of your unpaid student loan

L EARN MORE

httpaidnestcom[442018 115239 AM]

39Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 45 of 57 Page ID 1804

AIDNEST Let us help you through this national crisis

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE

Meet your Budget One of our advisers will help you meet your payment goals by using your budget and timeline to

determine the best plan available

httpaidnestcom[442018 115239 AM]

40Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 46 of 57 Page ID 1805

AIDNEST Let us help you through this national crisis

Simple Process We understand that lowering your payments alone can be difficult Our intuitive platform allows us

to keep the entire process simple

Customer Satisfaction We are committed to providing you with outstanding service only We look forward to working

with you

100 money back guarantee No Hassle Money Back Policy

httpaidnestcom[442018 115239 AM]

41Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 47 of 57 Page ID 1806

AIDNEST Let us help you through this national crisis

Lower your loan payments by getting in touch with one of our professionals

We design a customized repayment plan that will allow you to make payments based on your

monthly income family size and spending Get rid of the hassle of extensive paperwork and get the

help you deserve

What we can help you achieve a lower payment or lower rate

httpaidnestcom[442018 115239 AM]

42Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 48 of 57 Page ID 1807

AIDNEST Let us help you through this national crisis

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcom[442018 115239 AM]

43Exhibit E

httpaidnestcomservices[442018 115322 AM]

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 49 of 57 Page ID 1808

Services | AIDNEST Let us help you through this national crisis

INCOME BASED PAYMENTS

If you are suffering from a financial hardship you may be eligible for an

Income Based Payment In this repayment program you would have a

payment based on your income and family size The payment could be as

low as $000 per month with forgiveness at the end of 20-25 years

44

Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 50 of 57 Page ID 1809

L E ARN MORE

LOAN FORGIVENESS

If you have Federal Student Loans you may qualify for any of the student

loan forgiveness programs that are available to borrowers You may be

eligible for principal reduction loan forgiveness or a complete loan

discharge depending on your individual circumstance

L EARN MORE

PRIVATE STUDENT LOAN CONSOLIDATION

Much like refinancing a mortgage generally the biggest benefit of private

student loan consolidationstudent loan refinancing is a lower interest rate

httpaidnestcomservices[442018 115322 AM]

45Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 51 of 57 Page ID 1810

L E ARN MORE

(something federal consolidations do not offer)

STUDENT LOAN REHABILITATION

You can renew eligibility for new loans and grants and eliminate the loan

default by ldquorehabilitatingrdquo a defaulted loan

httpaidnestcomservices[442018 115322 AM]

46Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 52 of 57 Page ID 1811

CHE CK E L E G I B I L I T Y

WAGE GARNISHMENT

A wage garnishment is any legal procedure in which some portion of a

personrsquos earnings is required to be withheld by an employer for the

payment of a debt

L EARN MORE

With our fast friendly and professional services wersquoll be glad to help you get your student loans

reduced forgiven or completely discharged To this end wersquoll assist you in consolidating all your

student loans so yoursquoll have only one lender and yoursquoll start making one monthly payment Our

professionals will walk you through the best and most flexible repayment options and if itrsquos also

necessary varied deferment options and rehabilitation programs

httpaidnestcomservices[442018 115322 AM]

47Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 53 of 57 Page ID 1812

Services | AIDNEST Let us help you through this national crisis

Our CRM System

Our CRM is one of the most advanced in the industry and most importantly itrsquos linked directly to

the Department of Education (DOE) This keeps your personal and most confidential information

safe Furthermore because our CRM system is linked to the DOE our approval is 100 Through

our CRM we will be doing continuous monitoring of our process without losing sight of your

immediate needs ensuring that your case has the proper handling and most efficient process

httpaidnestcomservices[442018 115322 AM]

48Exhibit E

n

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 54 of 57 Page ID 1813

Services | AIDNEST Let us help you through this national crisis

R ECENT POSTS

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

ABOUT US

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcomservices[442018 115322 AM]

49Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 55 of 57 Page ID 1814

EXHIBIT F

s -

bullmiddot - ~ t ~ower Your Student Loan Pay~e~ts oday -- Students Helping Students Save Money

INCOME BASED PAJIIIJITPAIS

I C(gttoUC1 u~

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 56 of 57 Page ID 1815

X + C (D Not secure wwwstudoracom 0

CALL US NOW (85S) 978-S599 middot 1nfostudoracom

HOME SERVICES ABOUT US FAQ CONTACT US BLOC PRIVACY

Offering obligation and commitment free loan relief solutions

STUDENT LOAN FORGIVENESS INCOME BASED PAYMENTS LOAN CONSOLIDATION

We11 help you get your loans reduced forgiven o r Make monthly pdyments based on your affordability Get multiple Federal Student Loans consolidated into

discharged one low monthly payment

Talk to our experts concerning your

student loans

Studora is a pnvatefy owned company that helps consumers like you identify

government programs that fit your financial s1tuat1on Our loan experts will assist you in selecting the appropriate programs that WOltk with your income family size and

desired monthly payment We then prepare the appropriate documents for your review and submission All this f o r one low easy payment

Testimonials

Thank you f o r getting back to me quickly Youve been fabulous Thank you for the confirmation and for your help today Pass

during this whole process Is there a place I can go online that I this on to your sup that you were very professional and very

can leave a comment for your manager Youve made this Robert helpful and brought a sense of relief for me Thank you very

process so easy and answered every question my husband and I much and have a great rest of your day Kudos to you and your

have had teammoneywell spenL

Exhibit F 50

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 57 of 57 Page ID 1816

Services we offer

Stud ora offers document preparation services for all loan forgiveness consolidation and relief services to people who are unable to manage their finances Our mam aim is to

offer complete peace of mind to indiVidual unable to pay their student loan debt

we otter the folloWing document preparation services with complete professional assistance

amFinancial Review ffl Budget Planning

Toe first step to creating a flexible loan repayment plan is financial review we also help create a personal finance plan to ensure that you are able to

Our professmnals will look into your finances and design a custom manage your monthly budget in the most effective way This plan will keep

repayment plan that is affordable and easy to manage your spending to the minimum alloWing you to save more money for loan

repayment

Permanent Disability Forgiveness r-trTeacher Loan Forgiveness (5 You can get rid of your Federal Student Loan if you are permanently disabled Good news for teachers who are under the weight of a massiVe loan You can

now get $17 forgiven on your student loans

Public Service Loan Forgiveness Custom Debt Relief Plans

Want assistance with debt relief Get in touch with our experts who will help If you are a public service agent you can get rid of your loan after 120 days of design a loan repayment and relief plan for you based on your monthly

income and affordability payments

THERE ARE NO OBLIGATIONS OR COMMITMENTS

want to save thousands of dollars Fill out our form and get relief from your student loan for a more

peaceful tomorrow

Your Name

BiHHHi

Exhibit F 51

Attachment A

Page 26: JOSHUA S. MILLARD, BRIAN M. WELKE, pro hac vice · for which it has no legitimate claim. Noel is a Wyoming limited liability company that reported in a public document that its principal

Student Debt Crisis Business Latest Debt Collective Demands May be largely about smallest Student

borrnwers US News amp World Loan Crisis is fa frorn ove The Debt Collective is a group of Report-May 162015 last month Two new reports suggest the college students calling the Fedemiddotal Reserve Bank of New student loan crisis is easing them-se1ves the Corinthian York repor ced that stuclent loan somewhat as the economy Fifteen who are refusing to pay balances rose to 16 trillio n and improves but the crisis is far back their student loins As pa t that 113 per cent of that is in from ove the College Board of this effort the Debt Collective repo t~ tot31 borrowing fell by 8 has written an open lette to the pEbull1 cent between 2012-13 and Department of Education f l llJ 20 13-14 The organization

About Us 11 1 i~d1middot1r F th~~- h1~ ff t1middot~11middot=cl =i~=middott- 1middot __31middotmiddotIIgt middot bullmiddot11

middot- I ( )ntir il t l~i -r_il fr~~

Address bull middot tc1ltj-1r_ =i ~

middot l t1~t 1middot1 fcJ middot~_1 1 I l11 - Hbull 1 tr

~t (~~ 1 12bull~11 T 1 1- - 8555105400

FTC-AID-6

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 26 of 57 Page ID 1785

25

Exhibit A

f - g+ in O) ~ PRIVACY POLICY

This privacy statement discloses the privacy practices for AidllII Student Relief Because Aiding Studen Relief wonts to demonstrate ts firm commlcmell to your

privacy Aiding Sudent Relief hes greed to disclose ls 1rifor111atlori g1thering and dlssem1n1t1on prct1cts Aidlns Studtrit Relief will notify you of

INFORMATION COLLECTION At-ID USE

Aiding Student Relief is the sole owner of the rformMlon collected on this site We will not sell shire or rent this information 10 others In way different from what Is

disclosed 1n this statement Aldln1 StudeM Relief collects 1nform111on throuah this site from our prospective end existing clients at several different poin on our web

site We use their contact Informii on to send information bout our company and to service exsMs accounts Users may optbullout of rece11ns future malllngs see the

cholceoptbullout section below Contect and Financial information that 1s collected Is used for verifying your name address and other informa1on as well as to boll you for

your use of our Gerv1ces using Information from third party sourcH Information about your computer hardwre and software Is automatically collected by Aiding

Student Relief and may be shared in asgregate with third parties whose services are used for traffic analysis purposes This Ir formation includes your IP address

browser type domain names access times and referring Web site addresses Ths information is no tied to personally Identifiable Information This 1nformatlor s used

by Aiding Student Relief to malMan no Improve the quality of the Hrvct and to senerae statistics resardlng use of he Aiding Student Relief site We use third party

services to bill for serlces and to provide other services like our Live Help chat We store the transcripts from these chats for customer service Improvement These

third party service providers are not permitted to use your infornon for any secondary purposes

Thank you and cheers

FTC-AID-7

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 27 of 57 Page ID 1786

26

Exhibit A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 28 of 57 Page ID 1787

EXHIBIT B

Attachment A

((

z | ~

AIDINGSTUDENTRELIEF

bull bull bull bull bull

13 deg $ $ampdegdeg deg() ˝ amp $$deg( + -+Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 29 of 57 Page ID 1788

bulldaggerDagger Daggermdashndash Daggerhellip ƒfrasl hellip lsaquorsaquobullminuspermilminushellip bdquolsaquoldquo rsaquordquobulllsquo fraslbullrsquopermillsaquofraslpermilminushellip sbquo

4556789fADlt=gtA9BCAD

DZgtA=EFGHIJFKLMNOPFQOGFHIQRSTLKSUMMNOPLHMTFIVRWXHKKNIFNUNOPRLFGSHKSRVRVNQ

f e=klHMW

9SI]UQMSNSOQOHHPFK YaSTHHVVJFMHcVGNOJVHHFKKPSUHMLIUOQN_PL[KSVFGJPRSDTHRFPLIP=SNDC==GFdFIP9VaNHQTWSRPbHF_PSKSVNMPMHNIO XNNIIFRKNF7IKSQQMHFNDVPOS9IAeTHPdKSUMMFNKHONP 8aF_KSNVPHTNIMNR[POVFgNPTHLNHIgtMFI YTFHIdFFI D9aHVR_KNKHFHIWIQOTHIQbFFP

lt=Dkgt=L]oHUKMMH ihTFNIORI THHVPRFMVKgtNJ_NFFbIVSJI]IFjdGGVNNN lt=TFKPPNF 9DaFGmVHPGRJMFNNQOSGnPFFTNLUNHPMIMTFVNJOKMIWV

27

]UMNOHPFRKNVSHKKISIRWRrGZNJONgtNjTHKHMI=cQgtORHVPKSOUMddUNKSPIdspNVPNq_ lt=gtBTHFHPb=HFILGFHMt DTFuFIUVFRPNTFIMINVWOPRVOQFIV sFQFPHKKH vaIPNFVcSyOFSPRFMRNVOJH_gtVFDVUJAN9FPwFuVFJLFHMP_VTFFdSIIVdNHUPxI=DQSROJGASHIVdDSNMINONPPaHdOHdPFHRIWVFFHdFIGM˙ 01 $2 301 $$3 ( Exhibit B

8

~ldquo

middot

676EBCEDK5ltAC]5EF_5665E7gt5lt7aFb688E588lt76B5E6F8EBAC78lt76cdddefghijhggklmknmopqprpopst u

13 deg $ $ampdegdeg degˇ amp $$deg + -+Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 30 of 57 Page ID 1789 () ( vPSZwPxyYTUZUWWzxPyxSWMZWPU|SWUWYZ~YTY~QSWbullYXRwU~UxSdaggerXQ~UZXvPSZWSOVQSYNOXPRSTUSDaggerPxXYPZPNXRUSPQZXPbullU~SOhellipUNPxyYTUZmdash zUxSZUZXndashYWShellipYYXOwPxyYTUZUWWMNOPQx~YWShellipYYXOYWUƒDaggerU|XU~XPSWXfrasllsaquoPZXRWPxPxUOPQSOVQSYNONPxDaggerUxSZUZX~YWShellipYYXONPxyYTUZUWWmdash

rsaquominus MZ|PUpermilSWUzSOUZXWbdquoDaggerUxYP~PNZSZ|YSRSx~WRYDaggerSOVQSYNOOPQNPxSZMZ|PUpermilSWU~rdquoUDaggerSOUZXzSZmdashMZSZO|SWUWXRYWUSZWOPQDaggerSOZPXRYZymdash zQhellipY|daggerUxTY|UvPSZwPxyYTUZUWWMNOPQbullPxlsquoNPxSyPTUxZUZXPxySZYrsquoSXYPZSXS|YXOWXSXUPxNU~UxSUTUOPQSOVQSYNONPxXRUzQhellipY|daggerUxTY|UvPSZwPxyYTUZUWWDaggerxPyxSmdashsbquotrade f8Ef8E78FCB6C8EŁPQSOhellipUShellipUXP|PhellipYZUQXYDaggerUNU~UxSWXQ~UZXPSZWYZXPPZUZUbullPSZbullYXRSPbullUxPxUSŒPx~ShellipUPZXRODaggerSOUZXmdashvPSZ|PZWPY~SXYPZDaggerxPyxSW|SZRUDaggerOPQVQSYNONPxS~~YXYPZSDaggerxPyxSW YlsquoU PSZ NPxyYTUZUWWDaggerxPyxSWPxzQhellipY|daggerUxTY|UvPSZwPxyYTUZUWWmdash ŠmŸŽıłŠm 57gt8A57A5B= 8E65C76B5E6F8EB5=6G

PONM[5 QRSTUVQU PYXWZW lt4556789588lt959=lt CD lt H5FICEDJ8KA5LCD

A565E7gt57 œšžeuroiexclcentpoundyenbrvbarsectbrvbareurocopypoundsectlaquoeuropoundlaquobrvbarlaquoregplusmncentbrvbareurocent microparalaquo europoundž raquoY|frac14frac12 plusmncurrenRSUraquoSxXYZeuropoundlaquo laquoeurolaquoordf frac34

^ ˙ ( (

28

Attachment A

01 $2 301 $$3 ( Exhibit B

()(

=4ABC9DEAFBD=FGFHIJKLMJNOMN MRNS mn = nrst = svzhellipu t bulltvDaggerrhellipDaggerurbullbulltuhellipv hellipz~ bullmdashldquordquolsquorsquotrade š oŒŠeuro centpound ` umluml 13 deg $ $ampdegdeg degˇ amp $$deg + -+Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 31 of 57 Page ID 1790

ISNRTUKQINKKNNKL[MRJ PUWQI]MRM qyt|tytzxy rsaquoqNfraslbdquoPUhellipsbquoLUyQhellip rfraslbhellipMNSIKVUQ QNJKvUQsMiexclQQJUx[iexcliexcl_vsect_Qyenyenbrvbarbrvbar uSSRNTPL_LUUMKIaJ_WMIJJKVIONNQJJMWRMIIbQQURKLWIIJQbKLUNKMPTMNQQ_KKRY tbullbulldaggersDaggerv~vhellipmdashryrhellip~mdashrhellipDagger ŸLŽUıQŽbłpermilMtradeœsbquoNtrade_ffRŁyISMŒUQWyNUQŠlsaquo rv45657896lt7ltgt5lt PQKLMIQSNRTUKINQVNOOMVKMWNQKLIJPMXJIKMYZMPIOO NJMOOJLURMNRRMKKLIJ klltko ltgtlt85p5gt5 ouvwxrz ^^ ~ minuspermil tffŁ yenpoundpound KNOWDaggerIreggt4lt97ltndash9ƒ Dagger hellipDaggerlsaquo žko74k57ƒ ƒISNcurrenUIWIbJKWMKJYVNTKM KLONNRqIQQSNNRTUKINQQIJ_JMWNQKLIJJJPMXJIKMcOMUJMVNQKUVK_JUKBHdefABCgDEAFBDghidjlaquopoundbrvbariexclnotvIWIQbDaggerK_WMQKbullMOIMSvOObullIbLKJbullMJMRMW ordf copy

01( $2(301$$3( Exhibit B

29

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 32 of 57 Page ID 1791

EXHIBIT C

Attachment A

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Something awesome is coming soon We are buildin somethin ve cool Sta tuned and be at1ent Your atience will be well aid

~lbullrbullUiUffl We can help you reduce and simplify your payments

101 Loan For iveness

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Exhibit C

Case 818-cv-01987-JLS

-KE

S

Docum

ent 50-1 F

iled 020519 P

age 33 of 57 P

age ID 1792

30

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 34 of 57 Page ID 1793

EXHIBIT D

Attachment A

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Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 35 of 57 Page ID 1794

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

infoaidnestcom (800) 555-1212

HOME

ABOUT US

SERVICES

FAQ

BLOG

CONTACT

HOME ABOUT US SERVICES FAQ BLOG CONTACT

1 of 6 462018 945 AM

31

Student Loan Forgiveness Loan Consolidation Student Loan Forgiveness

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 36 of 57 Page ID 1795

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

If you have Federal Student Loans yoursquore in the right place to get those loans reduced forgiven or completely discharged through our student loan forgiveness programs

Get your multiple Federal Student Loans consolidated into one forget about increasing interests and pay month to month at the lowest possible cost

We understand if yoursquore going through some hardship and thatrsquos why with us yoursquoll be able to make monthly payments based on your affordability for as low as $000 depending on your situation

2 of 6 462018 945 AM

32

Knowledge Base

Defaulted Student Loans

Wage Garnishment

Student Loan Rehabilitation

Income Based Repayment Plan

Deferment and Forbearance

Pay As You Earn Repayment Plan

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE Call 561)424-6053 today to go over your options

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 37 of 57 Page ID 1796

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

Our knowledge base is designed to provide information regarding some of the critical topics those with student loans must be aware of to be able to make educated decisions regarding their future

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

A wage garnishment is any legal procedure in which some portion of a personrsquos earnings is required to be withheld by an employer for the payment of a debt

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

With this program your payments change as your income changes and will not be longer than 25 years This is the ideal plan if you are in partial financial hardship Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard plan

Temporarily allowing you to postpone or reduce your federal student loan payments Postponing or reducing your payments may help you avoid default and future garnishments

Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard

3 of 6 462018 945 AM

33

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 38 of 57 Page ID 1797

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

4 of 6 462018 945 AM

34Attachment A

Testimonials

Latest News

Why 2016 Will Be a Big Year For Student Loans

Top Student Loan Refinancing Questions of 2015

Oba mas latest student loan plan

Things You Should Know About Public Service Loan Forgiveness

Recent Posts

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 39 of 57 Page ID 1798

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

5 of 6 462018 945 AM

35

About Us

Contact Info

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 40 of 57 Page ID 1799

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

pay-grandchild-studen

Why 2016 Will Be a Big Year For Student Loans

December 30 2015

12511110_1112367518

Top Student Loan Refinancing Questions of 2015

December 30 2015

We stand by our consultation and quote We are so sure and confident about our services and offers that they are all 100 money back guarantee risk free ndash if we donrsquot do what we promise yoursquoll get your money back

(800) 555-1212 AidnestStudenLoansgmailcom 18100 Von Karman Ave Suite 850 Irvine CA 92612

Futero SAS copy 2015 | Aidnestcom

6 of 6 462018 945

Exhibit D 36Attachment A

AM

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 41 of 57 Page ID 1800

EXHIBIT E

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 42 of 57 Page ID 1801

AIDNEST Let us help you through this national crisis

Call one of our specialists today

Forbearance amp Deferment If you are still in school and struggling to make payments on your student loans You may qualify

for Forbearance amp Deferment

Garnishment Prevention Federal law requires that the Department of Education or guarantee agency notifies you before they

begin garnishing your wages

Loan Forgiveness If you are a teacher public service worker or an individual with total and permanent disability you

httpaidnestcom[442018 115239 AM]

37Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 43 of 57 Page ID 1802

AIDNEST Let us help you through this national crisis

may qualify for this program

Consolidating Your Loans Consolidating your loans to one new loan under one lender may lower your payments and make

your life a bit more manageable

Affordable Payments If you are looking to lower your monthly payments then Income Based Repayment Plans may be

the correct choice for you

Learn more about our services

LEARN MORE

httpaidnestcom[442018 115239 AM]

38Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 44 of 57 Page ID 1803

AIDNEST Let us help you through this national crisis

Loan Forgiveness Programs Income Based Payments Student Loan Rehabilitation

Student Loan Consolidation

You may be eligible for

Loan Forgiveness Programs

In some cases individuals with Federal Student Loans may qualify to have a portion of the amount

owed to be forgiven

Get in touch with our professional team to find out which loan forgiveness program you qualify for and

how you can get rid of your unpaid student loan

L EARN MORE

httpaidnestcom[442018 115239 AM]

39Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 45 of 57 Page ID 1804

AIDNEST Let us help you through this national crisis

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE

Meet your Budget One of our advisers will help you meet your payment goals by using your budget and timeline to

determine the best plan available

httpaidnestcom[442018 115239 AM]

40Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 46 of 57 Page ID 1805

AIDNEST Let us help you through this national crisis

Simple Process We understand that lowering your payments alone can be difficult Our intuitive platform allows us

to keep the entire process simple

Customer Satisfaction We are committed to providing you with outstanding service only We look forward to working

with you

100 money back guarantee No Hassle Money Back Policy

httpaidnestcom[442018 115239 AM]

41Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 47 of 57 Page ID 1806

AIDNEST Let us help you through this national crisis

Lower your loan payments by getting in touch with one of our professionals

We design a customized repayment plan that will allow you to make payments based on your

monthly income family size and spending Get rid of the hassle of extensive paperwork and get the

help you deserve

What we can help you achieve a lower payment or lower rate

httpaidnestcom[442018 115239 AM]

42Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 48 of 57 Page ID 1807

AIDNEST Let us help you through this national crisis

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcom[442018 115239 AM]

43Exhibit E

httpaidnestcomservices[442018 115322 AM]

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 49 of 57 Page ID 1808

Services | AIDNEST Let us help you through this national crisis

INCOME BASED PAYMENTS

If you are suffering from a financial hardship you may be eligible for an

Income Based Payment In this repayment program you would have a

payment based on your income and family size The payment could be as

low as $000 per month with forgiveness at the end of 20-25 years

44

Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 50 of 57 Page ID 1809

L E ARN MORE

LOAN FORGIVENESS

If you have Federal Student Loans you may qualify for any of the student

loan forgiveness programs that are available to borrowers You may be

eligible for principal reduction loan forgiveness or a complete loan

discharge depending on your individual circumstance

L EARN MORE

PRIVATE STUDENT LOAN CONSOLIDATION

Much like refinancing a mortgage generally the biggest benefit of private

student loan consolidationstudent loan refinancing is a lower interest rate

httpaidnestcomservices[442018 115322 AM]

45Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 51 of 57 Page ID 1810

L E ARN MORE

(something federal consolidations do not offer)

STUDENT LOAN REHABILITATION

You can renew eligibility for new loans and grants and eliminate the loan

default by ldquorehabilitatingrdquo a defaulted loan

httpaidnestcomservices[442018 115322 AM]

46Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 52 of 57 Page ID 1811

CHE CK E L E G I B I L I T Y

WAGE GARNISHMENT

A wage garnishment is any legal procedure in which some portion of a

personrsquos earnings is required to be withheld by an employer for the

payment of a debt

L EARN MORE

With our fast friendly and professional services wersquoll be glad to help you get your student loans

reduced forgiven or completely discharged To this end wersquoll assist you in consolidating all your

student loans so yoursquoll have only one lender and yoursquoll start making one monthly payment Our

professionals will walk you through the best and most flexible repayment options and if itrsquos also

necessary varied deferment options and rehabilitation programs

httpaidnestcomservices[442018 115322 AM]

47Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 53 of 57 Page ID 1812

Services | AIDNEST Let us help you through this national crisis

Our CRM System

Our CRM is one of the most advanced in the industry and most importantly itrsquos linked directly to

the Department of Education (DOE) This keeps your personal and most confidential information

safe Furthermore because our CRM system is linked to the DOE our approval is 100 Through

our CRM we will be doing continuous monitoring of our process without losing sight of your

immediate needs ensuring that your case has the proper handling and most efficient process

httpaidnestcomservices[442018 115322 AM]

48Exhibit E

n

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 54 of 57 Page ID 1813

Services | AIDNEST Let us help you through this national crisis

R ECENT POSTS

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

ABOUT US

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcomservices[442018 115322 AM]

49Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 55 of 57 Page ID 1814

EXHIBIT F

s -

bullmiddot - ~ t ~ower Your Student Loan Pay~e~ts oday -- Students Helping Students Save Money

INCOME BASED PAJIIIJITPAIS

I C(gttoUC1 u~

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 56 of 57 Page ID 1815

X + C (D Not secure wwwstudoracom 0

CALL US NOW (85S) 978-S599 middot 1nfostudoracom

HOME SERVICES ABOUT US FAQ CONTACT US BLOC PRIVACY

Offering obligation and commitment free loan relief solutions

STUDENT LOAN FORGIVENESS INCOME BASED PAYMENTS LOAN CONSOLIDATION

We11 help you get your loans reduced forgiven o r Make monthly pdyments based on your affordability Get multiple Federal Student Loans consolidated into

discharged one low monthly payment

Talk to our experts concerning your

student loans

Studora is a pnvatefy owned company that helps consumers like you identify

government programs that fit your financial s1tuat1on Our loan experts will assist you in selecting the appropriate programs that WOltk with your income family size and

desired monthly payment We then prepare the appropriate documents for your review and submission All this f o r one low easy payment

Testimonials

Thank you f o r getting back to me quickly Youve been fabulous Thank you for the confirmation and for your help today Pass

during this whole process Is there a place I can go online that I this on to your sup that you were very professional and very

can leave a comment for your manager Youve made this Robert helpful and brought a sense of relief for me Thank you very

process so easy and answered every question my husband and I much and have a great rest of your day Kudos to you and your

have had teammoneywell spenL

Exhibit F 50

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 57 of 57 Page ID 1816

Services we offer

Stud ora offers document preparation services for all loan forgiveness consolidation and relief services to people who are unable to manage their finances Our mam aim is to

offer complete peace of mind to indiVidual unable to pay their student loan debt

we otter the folloWing document preparation services with complete professional assistance

amFinancial Review ffl Budget Planning

Toe first step to creating a flexible loan repayment plan is financial review we also help create a personal finance plan to ensure that you are able to

Our professmnals will look into your finances and design a custom manage your monthly budget in the most effective way This plan will keep

repayment plan that is affordable and easy to manage your spending to the minimum alloWing you to save more money for loan

repayment

Permanent Disability Forgiveness r-trTeacher Loan Forgiveness (5 You can get rid of your Federal Student Loan if you are permanently disabled Good news for teachers who are under the weight of a massiVe loan You can

now get $17 forgiven on your student loans

Public Service Loan Forgiveness Custom Debt Relief Plans

Want assistance with debt relief Get in touch with our experts who will help If you are a public service agent you can get rid of your loan after 120 days of design a loan repayment and relief plan for you based on your monthly

income and affordability payments

THERE ARE NO OBLIGATIONS OR COMMITMENTS

want to save thousands of dollars Fill out our form and get relief from your student loan for a more

peaceful tomorrow

Your Name

BiHHHi

Exhibit F 51

Attachment A

Page 27: JOSHUA S. MILLARD, BRIAN M. WELKE, pro hac vice · for which it has no legitimate claim. Noel is a Wyoming limited liability company that reported in a public document that its principal

f - g+ in O) ~ PRIVACY POLICY

This privacy statement discloses the privacy practices for AidllII Student Relief Because Aiding Studen Relief wonts to demonstrate ts firm commlcmell to your

privacy Aiding Sudent Relief hes greed to disclose ls 1rifor111atlori g1thering and dlssem1n1t1on prct1cts Aidlns Studtrit Relief will notify you of

INFORMATION COLLECTION At-ID USE

Aiding Student Relief is the sole owner of the rformMlon collected on this site We will not sell shire or rent this information 10 others In way different from what Is

disclosed 1n this statement Aldln1 StudeM Relief collects 1nform111on throuah this site from our prospective end existing clients at several different poin on our web

site We use their contact Informii on to send information bout our company and to service exsMs accounts Users may optbullout of rece11ns future malllngs see the

cholceoptbullout section below Contect and Financial information that 1s collected Is used for verifying your name address and other informa1on as well as to boll you for

your use of our Gerv1ces using Information from third party sourcH Information about your computer hardwre and software Is automatically collected by Aiding

Student Relief and may be shared in asgregate with third parties whose services are used for traffic analysis purposes This Ir formation includes your IP address

browser type domain names access times and referring Web site addresses Ths information is no tied to personally Identifiable Information This 1nformatlor s used

by Aiding Student Relief to malMan no Improve the quality of the Hrvct and to senerae statistics resardlng use of he Aiding Student Relief site We use third party

services to bill for serlces and to provide other services like our Live Help chat We store the transcripts from these chats for customer service Improvement These

third party service providers are not permitted to use your infornon for any secondary purposes

Thank you and cheers

FTC-AID-7

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 27 of 57 Page ID 1786

26

Exhibit A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 28 of 57 Page ID 1787

EXHIBIT B

Attachment A

((

z | ~

AIDINGSTUDENTRELIEF

bull bull bull bull bull

13 deg $ $ampdegdeg deg() ˝ amp $$deg( + -+Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 29 of 57 Page ID 1788

bulldaggerDagger Daggermdashndash Daggerhellip ƒfrasl hellip lsaquorsaquobullminuspermilminushellip bdquolsaquoldquo rsaquordquobulllsquo fraslbullrsquopermillsaquofraslpermilminushellip sbquo

4556789fADlt=gtA9BCAD

DZgtA=EFGHIJFKLMNOPFQOGFHIQRSTLKSUMMNOPLHMTFIVRWXHKKNIFNUNOPRLFGSHKSRVRVNQ

f e=klHMW

9SI]UQMSNSOQOHHPFK YaSTHHVVJFMHcVGNOJVHHFKKPSUHMLIUOQN_PL[KSVFGJPRSDTHRFPLIP=SNDC==GFdFIP9VaNHQTWSRPbHF_PSKSVNMPMHNIO XNNIIFRKNF7IKSQQMHFNDVPOS9IAeTHPdKSUMMFNKHONP 8aF_KSNVPHTNIMNR[POVFgNPTHLNHIgtMFI YTFHIdFFI D9aHVR_KNKHFHIWIQOTHIQbFFP

lt=Dkgt=L]oHUKMMH ihTFNIORI THHVPRFMVKgtNJ_NFFbIVSJI]IFjdGGVNNN lt=TFKPPNF 9DaFGmVHPGRJMFNNQOSGnPFFTNLUNHPMIMTFVNJOKMIWV

27

]UMNOHPFRKNVSHKKISIRWRrGZNJONgtNjTHKHMI=cQgtORHVPKSOUMddUNKSPIdspNVPNq_ lt=gtBTHFHPb=HFILGFHMt DTFuFIUVFRPNTFIMINVWOPRVOQFIV sFQFPHKKH vaIPNFVcSyOFSPRFMRNVOJH_gtVFDVUJAN9FPwFuVFJLFHMP_VTFFdSIIVdNHUPxI=DQSROJGASHIVdDSNMINONPPaHdOHdPFHRIWVFFHdFIGM˙ 01 $2 301 $$3 ( Exhibit B

8

~ldquo

middot

676EBCEDK5ltAC]5EF_5665E7gt5lt7aFb688E588lt76B5E6F8EBAC78lt76cdddefghijhggklmknmopqprpopst u

13 deg $ $ampdegdeg degˇ amp $$deg + -+Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 30 of 57 Page ID 1789 () ( vPSZwPxyYTUZUWWzxPyxSWMZWPU|SWUWYZ~YTY~QSWbullYXRwU~UxSdaggerXQ~UZXvPSZWSOVQSYNOXPRSTUSDaggerPxXYPZPNXRUSPQZXPbullU~SOhellipUNPxyYTUZmdash zUxSZUZXndashYWShellipYYXOwPxyYTUZUWWMNOPQx~YWShellipYYXOYWUƒDaggerU|XU~XPSWXfrasllsaquoPZXRWPxPxUOPQSOVQSYNONPxDaggerUxSZUZX~YWShellipYYXONPxyYTUZUWWmdash

rsaquominus MZ|PUpermilSWUzSOUZXWbdquoDaggerUxYP~PNZSZ|YSRSx~WRYDaggerSOVQSYNOOPQNPxSZMZ|PUpermilSWU~rdquoUDaggerSOUZXzSZmdashMZSZO|SWUWXRYWUSZWOPQDaggerSOZPXRYZymdash zQhellipY|daggerUxTY|UvPSZwPxyYTUZUWWMNOPQbullPxlsquoNPxSyPTUxZUZXPxySZYrsquoSXYPZSXS|YXOWXSXUPxNU~UxSUTUOPQSOVQSYNONPxXRUzQhellipY|daggerUxTY|UvPSZwPxyYTUZUWWDaggerxPyxSmdashsbquotrade f8Ef8E78FCB6C8EŁPQSOhellipUShellipUXP|PhellipYZUQXYDaggerUNU~UxSWXQ~UZXPSZWYZXPPZUZUbullPSZbullYXRSPbullUxPxUSŒPx~ShellipUPZXRODaggerSOUZXmdashvPSZ|PZWPY~SXYPZDaggerxPyxSW|SZRUDaggerOPQVQSYNONPxS~~YXYPZSDaggerxPyxSW YlsquoU PSZ NPxyYTUZUWWDaggerxPyxSWPxzQhellipY|daggerUxTY|UvPSZwPxyYTUZUWWmdash ŠmŸŽıłŠm 57gt8A57A5B= 8E65C76B5E6F8EB5=6G

PONM[5 QRSTUVQU PYXWZW lt4556789588lt959=lt CD lt H5FICEDJ8KA5LCD

A565E7gt57 œšžeuroiexclcentpoundyenbrvbarsectbrvbareurocopypoundsectlaquoeuropoundlaquobrvbarlaquoregplusmncentbrvbareurocent microparalaquo europoundž raquoY|frac14frac12 plusmncurrenRSUraquoSxXYZeuropoundlaquo laquoeurolaquoordf frac34

^ ˙ ( (

28

Attachment A

01 $2 301 $$3 ( Exhibit B

()(

=4ABC9DEAFBD=FGFHIJKLMJNOMN MRNS mn = nrst = svzhellipu t bulltvDaggerrhellipDaggerurbullbulltuhellipv hellipz~ bullmdashldquordquolsquorsquotrade š oŒŠeuro centpound ` umluml 13 deg $ $ampdegdeg degˇ amp $$deg + -+Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 31 of 57 Page ID 1790

ISNRTUKQINKKNNKL[MRJ PUWQI]MRM qyt|tytzxy rsaquoqNfraslbdquoPUhellipsbquoLUyQhellip rfraslbhellipMNSIKVUQ QNJKvUQsMiexclQQJUx[iexcliexcl_vsect_Qyenyenbrvbarbrvbar uSSRNTPL_LUUMKIaJ_WMIJJKVIONNQJJMWRMIIbQQURKLWIIJQbKLUNKMPTMNQQ_KKRY tbullbulldaggersDaggerv~vhellipmdashryrhellip~mdashrhellipDagger ŸLŽUıQŽbłpermilMtradeœsbquoNtrade_ffRŁyISMŒUQWyNUQŠlsaquo rv45657896lt7ltgt5lt PQKLMIQSNRTUKINQVNOOMVKMWNQKLIJPMXJIKMYZMPIOO NJMOOJLURMNRRMKKLIJ klltko ltgtlt85p5gt5 ouvwxrz ^^ ~ minuspermil tffŁ yenpoundpound KNOWDaggerIreggt4lt97ltndash9ƒ Dagger hellipDaggerlsaquo žko74k57ƒ ƒISNcurrenUIWIbJKWMKJYVNTKM KLONNRqIQQSNNRTUKINQQIJ_JMWNQKLIJJJPMXJIKMcOMUJMVNQKUVK_JUKBHdefABCgDEAFBDghidjlaquopoundbrvbariexclnotvIWIQbDaggerK_WMQKbullMOIMSvOObullIbLKJbullMJMRMW ordf copy

01( $2(301$$3( Exhibit B

29

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 32 of 57 Page ID 1791

EXHIBIT C

Attachment A

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Something awesome is coming soon We are buildin somethin ve cool Sta tuned and be at1ent Your atience will be well aid

~lbullrbullUiUffl We can help you reduce and simplify your payments

101 Loan For iveness

1~u 0 (middottmiddotbullmiddotmiddot1 1~=I -- _~

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~ Income Based Pa ents

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Exhibit C

Case 818-cv-01987-JLS

-KE

S

Docum

ent 50-1 F

iled 020519 P

age 33 of 57 P

age ID 1792

30

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 34 of 57 Page ID 1793

EXHIBIT D

Attachment A

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Type then hit enter to

bull bull bull bull bull bull bull

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----

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 35 of 57 Page ID 1794

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

infoaidnestcom (800) 555-1212

HOME

ABOUT US

SERVICES

FAQ

BLOG

CONTACT

HOME ABOUT US SERVICES FAQ BLOG CONTACT

1 of 6 462018 945 AM

31

Student Loan Forgiveness Loan Consolidation Student Loan Forgiveness

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 36 of 57 Page ID 1795

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

If you have Federal Student Loans yoursquore in the right place to get those loans reduced forgiven or completely discharged through our student loan forgiveness programs

Get your multiple Federal Student Loans consolidated into one forget about increasing interests and pay month to month at the lowest possible cost

We understand if yoursquore going through some hardship and thatrsquos why with us yoursquoll be able to make monthly payments based on your affordability for as low as $000 depending on your situation

2 of 6 462018 945 AM

32

Knowledge Base

Defaulted Student Loans

Wage Garnishment

Student Loan Rehabilitation

Income Based Repayment Plan

Deferment and Forbearance

Pay As You Earn Repayment Plan

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE Call 561)424-6053 today to go over your options

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 37 of 57 Page ID 1796

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

Our knowledge base is designed to provide information regarding some of the critical topics those with student loans must be aware of to be able to make educated decisions regarding their future

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

A wage garnishment is any legal procedure in which some portion of a personrsquos earnings is required to be withheld by an employer for the payment of a debt

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

With this program your payments change as your income changes and will not be longer than 25 years This is the ideal plan if you are in partial financial hardship Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard plan

Temporarily allowing you to postpone or reduce your federal student loan payments Postponing or reducing your payments may help you avoid default and future garnishments

Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard

3 of 6 462018 945 AM

33

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 38 of 57 Page ID 1797

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

4 of 6 462018 945 AM

34Attachment A

Testimonials

Latest News

Why 2016 Will Be a Big Year For Student Loans

Top Student Loan Refinancing Questions of 2015

Oba mas latest student loan plan

Things You Should Know About Public Service Loan Forgiveness

Recent Posts

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 39 of 57 Page ID 1798

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

5 of 6 462018 945 AM

35

About Us

Contact Info

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 40 of 57 Page ID 1799

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

pay-grandchild-studen

Why 2016 Will Be a Big Year For Student Loans

December 30 2015

12511110_1112367518

Top Student Loan Refinancing Questions of 2015

December 30 2015

We stand by our consultation and quote We are so sure and confident about our services and offers that they are all 100 money back guarantee risk free ndash if we donrsquot do what we promise yoursquoll get your money back

(800) 555-1212 AidnestStudenLoansgmailcom 18100 Von Karman Ave Suite 850 Irvine CA 92612

Futero SAS copy 2015 | Aidnestcom

6 of 6 462018 945

Exhibit D 36Attachment A

AM

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 41 of 57 Page ID 1800

EXHIBIT E

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 42 of 57 Page ID 1801

AIDNEST Let us help you through this national crisis

Call one of our specialists today

Forbearance amp Deferment If you are still in school and struggling to make payments on your student loans You may qualify

for Forbearance amp Deferment

Garnishment Prevention Federal law requires that the Department of Education or guarantee agency notifies you before they

begin garnishing your wages

Loan Forgiveness If you are a teacher public service worker or an individual with total and permanent disability you

httpaidnestcom[442018 115239 AM]

37Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 43 of 57 Page ID 1802

AIDNEST Let us help you through this national crisis

may qualify for this program

Consolidating Your Loans Consolidating your loans to one new loan under one lender may lower your payments and make

your life a bit more manageable

Affordable Payments If you are looking to lower your monthly payments then Income Based Repayment Plans may be

the correct choice for you

Learn more about our services

LEARN MORE

httpaidnestcom[442018 115239 AM]

38Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 44 of 57 Page ID 1803

AIDNEST Let us help you through this national crisis

Loan Forgiveness Programs Income Based Payments Student Loan Rehabilitation

Student Loan Consolidation

You may be eligible for

Loan Forgiveness Programs

In some cases individuals with Federal Student Loans may qualify to have a portion of the amount

owed to be forgiven

Get in touch with our professional team to find out which loan forgiveness program you qualify for and

how you can get rid of your unpaid student loan

L EARN MORE

httpaidnestcom[442018 115239 AM]

39Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 45 of 57 Page ID 1804

AIDNEST Let us help you through this national crisis

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE

Meet your Budget One of our advisers will help you meet your payment goals by using your budget and timeline to

determine the best plan available

httpaidnestcom[442018 115239 AM]

40Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 46 of 57 Page ID 1805

AIDNEST Let us help you through this national crisis

Simple Process We understand that lowering your payments alone can be difficult Our intuitive platform allows us

to keep the entire process simple

Customer Satisfaction We are committed to providing you with outstanding service only We look forward to working

with you

100 money back guarantee No Hassle Money Back Policy

httpaidnestcom[442018 115239 AM]

41Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 47 of 57 Page ID 1806

AIDNEST Let us help you through this national crisis

Lower your loan payments by getting in touch with one of our professionals

We design a customized repayment plan that will allow you to make payments based on your

monthly income family size and spending Get rid of the hassle of extensive paperwork and get the

help you deserve

What we can help you achieve a lower payment or lower rate

httpaidnestcom[442018 115239 AM]

42Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 48 of 57 Page ID 1807

AIDNEST Let us help you through this national crisis

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcom[442018 115239 AM]

43Exhibit E

httpaidnestcomservices[442018 115322 AM]

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 49 of 57 Page ID 1808

Services | AIDNEST Let us help you through this national crisis

INCOME BASED PAYMENTS

If you are suffering from a financial hardship you may be eligible for an

Income Based Payment In this repayment program you would have a

payment based on your income and family size The payment could be as

low as $000 per month with forgiveness at the end of 20-25 years

44

Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 50 of 57 Page ID 1809

L E ARN MORE

LOAN FORGIVENESS

If you have Federal Student Loans you may qualify for any of the student

loan forgiveness programs that are available to borrowers You may be

eligible for principal reduction loan forgiveness or a complete loan

discharge depending on your individual circumstance

L EARN MORE

PRIVATE STUDENT LOAN CONSOLIDATION

Much like refinancing a mortgage generally the biggest benefit of private

student loan consolidationstudent loan refinancing is a lower interest rate

httpaidnestcomservices[442018 115322 AM]

45Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 51 of 57 Page ID 1810

L E ARN MORE

(something federal consolidations do not offer)

STUDENT LOAN REHABILITATION

You can renew eligibility for new loans and grants and eliminate the loan

default by ldquorehabilitatingrdquo a defaulted loan

httpaidnestcomservices[442018 115322 AM]

46Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 52 of 57 Page ID 1811

CHE CK E L E G I B I L I T Y

WAGE GARNISHMENT

A wage garnishment is any legal procedure in which some portion of a

personrsquos earnings is required to be withheld by an employer for the

payment of a debt

L EARN MORE

With our fast friendly and professional services wersquoll be glad to help you get your student loans

reduced forgiven or completely discharged To this end wersquoll assist you in consolidating all your

student loans so yoursquoll have only one lender and yoursquoll start making one monthly payment Our

professionals will walk you through the best and most flexible repayment options and if itrsquos also

necessary varied deferment options and rehabilitation programs

httpaidnestcomservices[442018 115322 AM]

47Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 53 of 57 Page ID 1812

Services | AIDNEST Let us help you through this national crisis

Our CRM System

Our CRM is one of the most advanced in the industry and most importantly itrsquos linked directly to

the Department of Education (DOE) This keeps your personal and most confidential information

safe Furthermore because our CRM system is linked to the DOE our approval is 100 Through

our CRM we will be doing continuous monitoring of our process without losing sight of your

immediate needs ensuring that your case has the proper handling and most efficient process

httpaidnestcomservices[442018 115322 AM]

48Exhibit E

n

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 54 of 57 Page ID 1813

Services | AIDNEST Let us help you through this national crisis

R ECENT POSTS

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

ABOUT US

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcomservices[442018 115322 AM]

49Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 55 of 57 Page ID 1814

EXHIBIT F

s -

bullmiddot - ~ t ~ower Your Student Loan Pay~e~ts oday -- Students Helping Students Save Money

INCOME BASED PAJIIIJITPAIS

I C(gttoUC1 u~

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 56 of 57 Page ID 1815

X + C (D Not secure wwwstudoracom 0

CALL US NOW (85S) 978-S599 middot 1nfostudoracom

HOME SERVICES ABOUT US FAQ CONTACT US BLOC PRIVACY

Offering obligation and commitment free loan relief solutions

STUDENT LOAN FORGIVENESS INCOME BASED PAYMENTS LOAN CONSOLIDATION

We11 help you get your loans reduced forgiven o r Make monthly pdyments based on your affordability Get multiple Federal Student Loans consolidated into

discharged one low monthly payment

Talk to our experts concerning your

student loans

Studora is a pnvatefy owned company that helps consumers like you identify

government programs that fit your financial s1tuat1on Our loan experts will assist you in selecting the appropriate programs that WOltk with your income family size and

desired monthly payment We then prepare the appropriate documents for your review and submission All this f o r one low easy payment

Testimonials

Thank you f o r getting back to me quickly Youve been fabulous Thank you for the confirmation and for your help today Pass

during this whole process Is there a place I can go online that I this on to your sup that you were very professional and very

can leave a comment for your manager Youve made this Robert helpful and brought a sense of relief for me Thank you very

process so easy and answered every question my husband and I much and have a great rest of your day Kudos to you and your

have had teammoneywell spenL

Exhibit F 50

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 57 of 57 Page ID 1816

Services we offer

Stud ora offers document preparation services for all loan forgiveness consolidation and relief services to people who are unable to manage their finances Our mam aim is to

offer complete peace of mind to indiVidual unable to pay their student loan debt

we otter the folloWing document preparation services with complete professional assistance

amFinancial Review ffl Budget Planning

Toe first step to creating a flexible loan repayment plan is financial review we also help create a personal finance plan to ensure that you are able to

Our professmnals will look into your finances and design a custom manage your monthly budget in the most effective way This plan will keep

repayment plan that is affordable and easy to manage your spending to the minimum alloWing you to save more money for loan

repayment

Permanent Disability Forgiveness r-trTeacher Loan Forgiveness (5 You can get rid of your Federal Student Loan if you are permanently disabled Good news for teachers who are under the weight of a massiVe loan You can

now get $17 forgiven on your student loans

Public Service Loan Forgiveness Custom Debt Relief Plans

Want assistance with debt relief Get in touch with our experts who will help If you are a public service agent you can get rid of your loan after 120 days of design a loan repayment and relief plan for you based on your monthly

income and affordability payments

THERE ARE NO OBLIGATIONS OR COMMITMENTS

want to save thousands of dollars Fill out our form and get relief from your student loan for a more

peaceful tomorrow

Your Name

BiHHHi

Exhibit F 51

Attachment A

Page 28: JOSHUA S. MILLARD, BRIAN M. WELKE, pro hac vice · for which it has no legitimate claim. Noel is a Wyoming limited liability company that reported in a public document that its principal

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 28 of 57 Page ID 1787

EXHIBIT B

Attachment A

((

z | ~

AIDINGSTUDENTRELIEF

bull bull bull bull bull

13 deg $ $ampdegdeg deg() ˝ amp $$deg( + -+Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 29 of 57 Page ID 1788

bulldaggerDagger Daggermdashndash Daggerhellip ƒfrasl hellip lsaquorsaquobullminuspermilminushellip bdquolsaquoldquo rsaquordquobulllsquo fraslbullrsquopermillsaquofraslpermilminushellip sbquo

4556789fADlt=gtA9BCAD

DZgtA=EFGHIJFKLMNOPFQOGFHIQRSTLKSUMMNOPLHMTFIVRWXHKKNIFNUNOPRLFGSHKSRVRVNQ

f e=klHMW

9SI]UQMSNSOQOHHPFK YaSTHHVVJFMHcVGNOJVHHFKKPSUHMLIUOQN_PL[KSVFGJPRSDTHRFPLIP=SNDC==GFdFIP9VaNHQTWSRPbHF_PSKSVNMPMHNIO XNNIIFRKNF7IKSQQMHFNDVPOS9IAeTHPdKSUMMFNKHONP 8aF_KSNVPHTNIMNR[POVFgNPTHLNHIgtMFI YTFHIdFFI D9aHVR_KNKHFHIWIQOTHIQbFFP

lt=Dkgt=L]oHUKMMH ihTFNIORI THHVPRFMVKgtNJ_NFFbIVSJI]IFjdGGVNNN lt=TFKPPNF 9DaFGmVHPGRJMFNNQOSGnPFFTNLUNHPMIMTFVNJOKMIWV

27

]UMNOHPFRKNVSHKKISIRWRrGZNJONgtNjTHKHMI=cQgtORHVPKSOUMddUNKSPIdspNVPNq_ lt=gtBTHFHPb=HFILGFHMt DTFuFIUVFRPNTFIMINVWOPRVOQFIV sFQFPHKKH vaIPNFVcSyOFSPRFMRNVOJH_gtVFDVUJAN9FPwFuVFJLFHMP_VTFFdSIIVdNHUPxI=DQSROJGASHIVdDSNMINONPPaHdOHdPFHRIWVFFHdFIGM˙ 01 $2 301 $$3 ( Exhibit B

8

~ldquo

middot

676EBCEDK5ltAC]5EF_5665E7gt5lt7aFb688E588lt76B5E6F8EBAC78lt76cdddefghijhggklmknmopqprpopst u

13 deg $ $ampdegdeg degˇ amp $$deg + -+Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 30 of 57 Page ID 1789 () ( vPSZwPxyYTUZUWWzxPyxSWMZWPU|SWUWYZ~YTY~QSWbullYXRwU~UxSdaggerXQ~UZXvPSZWSOVQSYNOXPRSTUSDaggerPxXYPZPNXRUSPQZXPbullU~SOhellipUNPxyYTUZmdash zUxSZUZXndashYWShellipYYXOwPxyYTUZUWWMNOPQx~YWShellipYYXOYWUƒDaggerU|XU~XPSWXfrasllsaquoPZXRWPxPxUOPQSOVQSYNONPxDaggerUxSZUZX~YWShellipYYXONPxyYTUZUWWmdash

rsaquominus MZ|PUpermilSWUzSOUZXWbdquoDaggerUxYP~PNZSZ|YSRSx~WRYDaggerSOVQSYNOOPQNPxSZMZ|PUpermilSWU~rdquoUDaggerSOUZXzSZmdashMZSZO|SWUWXRYWUSZWOPQDaggerSOZPXRYZymdash zQhellipY|daggerUxTY|UvPSZwPxyYTUZUWWMNOPQbullPxlsquoNPxSyPTUxZUZXPxySZYrsquoSXYPZSXS|YXOWXSXUPxNU~UxSUTUOPQSOVQSYNONPxXRUzQhellipY|daggerUxTY|UvPSZwPxyYTUZUWWDaggerxPyxSmdashsbquotrade f8Ef8E78FCB6C8EŁPQSOhellipUShellipUXP|PhellipYZUQXYDaggerUNU~UxSWXQ~UZXPSZWYZXPPZUZUbullPSZbullYXRSPbullUxPxUSŒPx~ShellipUPZXRODaggerSOUZXmdashvPSZ|PZWPY~SXYPZDaggerxPyxSW|SZRUDaggerOPQVQSYNONPxS~~YXYPZSDaggerxPyxSW YlsquoU PSZ NPxyYTUZUWWDaggerxPyxSWPxzQhellipY|daggerUxTY|UvPSZwPxyYTUZUWWmdash ŠmŸŽıłŠm 57gt8A57A5B= 8E65C76B5E6F8EB5=6G

PONM[5 QRSTUVQU PYXWZW lt4556789588lt959=lt CD lt H5FICEDJ8KA5LCD

A565E7gt57 œšžeuroiexclcentpoundyenbrvbarsectbrvbareurocopypoundsectlaquoeuropoundlaquobrvbarlaquoregplusmncentbrvbareurocent microparalaquo europoundž raquoY|frac14frac12 plusmncurrenRSUraquoSxXYZeuropoundlaquo laquoeurolaquoordf frac34

^ ˙ ( (

28

Attachment A

01 $2 301 $$3 ( Exhibit B

()(

=4ABC9DEAFBD=FGFHIJKLMJNOMN MRNS mn = nrst = svzhellipu t bulltvDaggerrhellipDaggerurbullbulltuhellipv hellipz~ bullmdashldquordquolsquorsquotrade š oŒŠeuro centpound ` umluml 13 deg $ $ampdegdeg degˇ amp $$deg + -+Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 31 of 57 Page ID 1790

ISNRTUKQINKKNNKL[MRJ PUWQI]MRM qyt|tytzxy rsaquoqNfraslbdquoPUhellipsbquoLUyQhellip rfraslbhellipMNSIKVUQ QNJKvUQsMiexclQQJUx[iexcliexcl_vsect_Qyenyenbrvbarbrvbar uSSRNTPL_LUUMKIaJ_WMIJJKVIONNQJJMWRMIIbQQURKLWIIJQbKLUNKMPTMNQQ_KKRY tbullbulldaggersDaggerv~vhellipmdashryrhellip~mdashrhellipDagger ŸLŽUıQŽbłpermilMtradeœsbquoNtrade_ffRŁyISMŒUQWyNUQŠlsaquo rv45657896lt7ltgt5lt PQKLMIQSNRTUKINQVNOOMVKMWNQKLIJPMXJIKMYZMPIOO NJMOOJLURMNRRMKKLIJ klltko ltgtlt85p5gt5 ouvwxrz ^^ ~ minuspermil tffŁ yenpoundpound KNOWDaggerIreggt4lt97ltndash9ƒ Dagger hellipDaggerlsaquo žko74k57ƒ ƒISNcurrenUIWIbJKWMKJYVNTKM KLONNRqIQQSNNRTUKINQQIJ_JMWNQKLIJJJPMXJIKMcOMUJMVNQKUVK_JUKBHdefABCgDEAFBDghidjlaquopoundbrvbariexclnotvIWIQbDaggerK_WMQKbullMOIMSvOObullIbLKJbullMJMRMW ordf copy

01( $2(301$$3( Exhibit B

29

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 32 of 57 Page ID 1791

EXHIBIT C

Attachment A

~ 111 ~tampi 10 11 ~bull ia1111

Something awesome is coming soon We are buildin somethin ve cool Sta tuned and be at1ent Your atience will be well aid

~lbullrbullUiUffl We can help you reduce and simplify your payments

101 Loan For iveness

1~u 0 (middottmiddotbullmiddotmiddot1 1~=I -- _~

HZamp IMUliULlampRampatiEUWi nmiddot middot-il~ fr middot 8rbullbullrcrr-

_J l _ 1 _f _ur -~t~ u L liYu

~ Income Based Pa ents

bull ~ f I - - I - I - ri u ~u-=lf ~ JU

1-bullA ---rc iM1~~ -~-bullCiel rrcl

~- middot IY 2 i C middot middotJ ll1Jmiddot 0 _ middot_middotIr i

~ LdfiJIMifJ11JJMJllfFffi

middotE-ltecl l2bullJbull iequbullt t11cit t1lt2 CtpCr~middot1e- f

JJd r g-_iraE-1 agltr-middot- ntimiddot middot)middotou

tmiddot_rt- i ic l~1ri ~rbullmiddot middot111~ umiddot -_ d_t-c

fsectmet-Naibullfyen1~poundibllffifftmI

I f-nle Vnot Nune

I ampterYOllrEmall ]

1 ~~~~ 1

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Exhibit C

Case 818-cv-01987-JLS

-KE

S

Docum

ent 50-1 F

iled 020519 P

age 33 of 57 P

age ID 1792

30

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 34 of 57 Page ID 1793

EXHIBIT D

Attachment A

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Type then hit enter to

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----

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 35 of 57 Page ID 1794

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

infoaidnestcom (800) 555-1212

HOME

ABOUT US

SERVICES

FAQ

BLOG

CONTACT

HOME ABOUT US SERVICES FAQ BLOG CONTACT

1 of 6 462018 945 AM

31

Student Loan Forgiveness Loan Consolidation Student Loan Forgiveness

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 36 of 57 Page ID 1795

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

If you have Federal Student Loans yoursquore in the right place to get those loans reduced forgiven or completely discharged through our student loan forgiveness programs

Get your multiple Federal Student Loans consolidated into one forget about increasing interests and pay month to month at the lowest possible cost

We understand if yoursquore going through some hardship and thatrsquos why with us yoursquoll be able to make monthly payments based on your affordability for as low as $000 depending on your situation

2 of 6 462018 945 AM

32

Knowledge Base

Defaulted Student Loans

Wage Garnishment

Student Loan Rehabilitation

Income Based Repayment Plan

Deferment and Forbearance

Pay As You Earn Repayment Plan

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE Call 561)424-6053 today to go over your options

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 37 of 57 Page ID 1796

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

Our knowledge base is designed to provide information regarding some of the critical topics those with student loans must be aware of to be able to make educated decisions regarding their future

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

A wage garnishment is any legal procedure in which some portion of a personrsquos earnings is required to be withheld by an employer for the payment of a debt

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

With this program your payments change as your income changes and will not be longer than 25 years This is the ideal plan if you are in partial financial hardship Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard plan

Temporarily allowing you to postpone or reduce your federal student loan payments Postponing or reducing your payments may help you avoid default and future garnishments

Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard

3 of 6 462018 945 AM

33

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 38 of 57 Page ID 1797

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

4 of 6 462018 945 AM

34Attachment A

Testimonials

Latest News

Why 2016 Will Be a Big Year For Student Loans

Top Student Loan Refinancing Questions of 2015

Oba mas latest student loan plan

Things You Should Know About Public Service Loan Forgiveness

Recent Posts

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 39 of 57 Page ID 1798

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

5 of 6 462018 945 AM

35

About Us

Contact Info

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 40 of 57 Page ID 1799

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

pay-grandchild-studen

Why 2016 Will Be a Big Year For Student Loans

December 30 2015

12511110_1112367518

Top Student Loan Refinancing Questions of 2015

December 30 2015

We stand by our consultation and quote We are so sure and confident about our services and offers that they are all 100 money back guarantee risk free ndash if we donrsquot do what we promise yoursquoll get your money back

(800) 555-1212 AidnestStudenLoansgmailcom 18100 Von Karman Ave Suite 850 Irvine CA 92612

Futero SAS copy 2015 | Aidnestcom

6 of 6 462018 945

Exhibit D 36Attachment A

AM

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 41 of 57 Page ID 1800

EXHIBIT E

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 42 of 57 Page ID 1801

AIDNEST Let us help you through this national crisis

Call one of our specialists today

Forbearance amp Deferment If you are still in school and struggling to make payments on your student loans You may qualify

for Forbearance amp Deferment

Garnishment Prevention Federal law requires that the Department of Education or guarantee agency notifies you before they

begin garnishing your wages

Loan Forgiveness If you are a teacher public service worker or an individual with total and permanent disability you

httpaidnestcom[442018 115239 AM]

37Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 43 of 57 Page ID 1802

AIDNEST Let us help you through this national crisis

may qualify for this program

Consolidating Your Loans Consolidating your loans to one new loan under one lender may lower your payments and make

your life a bit more manageable

Affordable Payments If you are looking to lower your monthly payments then Income Based Repayment Plans may be

the correct choice for you

Learn more about our services

LEARN MORE

httpaidnestcom[442018 115239 AM]

38Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 44 of 57 Page ID 1803

AIDNEST Let us help you through this national crisis

Loan Forgiveness Programs Income Based Payments Student Loan Rehabilitation

Student Loan Consolidation

You may be eligible for

Loan Forgiveness Programs

In some cases individuals with Federal Student Loans may qualify to have a portion of the amount

owed to be forgiven

Get in touch with our professional team to find out which loan forgiveness program you qualify for and

how you can get rid of your unpaid student loan

L EARN MORE

httpaidnestcom[442018 115239 AM]

39Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 45 of 57 Page ID 1804

AIDNEST Let us help you through this national crisis

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE

Meet your Budget One of our advisers will help you meet your payment goals by using your budget and timeline to

determine the best plan available

httpaidnestcom[442018 115239 AM]

40Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 46 of 57 Page ID 1805

AIDNEST Let us help you through this national crisis

Simple Process We understand that lowering your payments alone can be difficult Our intuitive platform allows us

to keep the entire process simple

Customer Satisfaction We are committed to providing you with outstanding service only We look forward to working

with you

100 money back guarantee No Hassle Money Back Policy

httpaidnestcom[442018 115239 AM]

41Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 47 of 57 Page ID 1806

AIDNEST Let us help you through this national crisis

Lower your loan payments by getting in touch with one of our professionals

We design a customized repayment plan that will allow you to make payments based on your

monthly income family size and spending Get rid of the hassle of extensive paperwork and get the

help you deserve

What we can help you achieve a lower payment or lower rate

httpaidnestcom[442018 115239 AM]

42Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 48 of 57 Page ID 1807

AIDNEST Let us help you through this national crisis

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcom[442018 115239 AM]

43Exhibit E

httpaidnestcomservices[442018 115322 AM]

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 49 of 57 Page ID 1808

Services | AIDNEST Let us help you through this national crisis

INCOME BASED PAYMENTS

If you are suffering from a financial hardship you may be eligible for an

Income Based Payment In this repayment program you would have a

payment based on your income and family size The payment could be as

low as $000 per month with forgiveness at the end of 20-25 years

44

Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 50 of 57 Page ID 1809

L E ARN MORE

LOAN FORGIVENESS

If you have Federal Student Loans you may qualify for any of the student

loan forgiveness programs that are available to borrowers You may be

eligible for principal reduction loan forgiveness or a complete loan

discharge depending on your individual circumstance

L EARN MORE

PRIVATE STUDENT LOAN CONSOLIDATION

Much like refinancing a mortgage generally the biggest benefit of private

student loan consolidationstudent loan refinancing is a lower interest rate

httpaidnestcomservices[442018 115322 AM]

45Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 51 of 57 Page ID 1810

L E ARN MORE

(something federal consolidations do not offer)

STUDENT LOAN REHABILITATION

You can renew eligibility for new loans and grants and eliminate the loan

default by ldquorehabilitatingrdquo a defaulted loan

httpaidnestcomservices[442018 115322 AM]

46Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 52 of 57 Page ID 1811

CHE CK E L E G I B I L I T Y

WAGE GARNISHMENT

A wage garnishment is any legal procedure in which some portion of a

personrsquos earnings is required to be withheld by an employer for the

payment of a debt

L EARN MORE

With our fast friendly and professional services wersquoll be glad to help you get your student loans

reduced forgiven or completely discharged To this end wersquoll assist you in consolidating all your

student loans so yoursquoll have only one lender and yoursquoll start making one monthly payment Our

professionals will walk you through the best and most flexible repayment options and if itrsquos also

necessary varied deferment options and rehabilitation programs

httpaidnestcomservices[442018 115322 AM]

47Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 53 of 57 Page ID 1812

Services | AIDNEST Let us help you through this national crisis

Our CRM System

Our CRM is one of the most advanced in the industry and most importantly itrsquos linked directly to

the Department of Education (DOE) This keeps your personal and most confidential information

safe Furthermore because our CRM system is linked to the DOE our approval is 100 Through

our CRM we will be doing continuous monitoring of our process without losing sight of your

immediate needs ensuring that your case has the proper handling and most efficient process

httpaidnestcomservices[442018 115322 AM]

48Exhibit E

n

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 54 of 57 Page ID 1813

Services | AIDNEST Let us help you through this national crisis

R ECENT POSTS

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

ABOUT US

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcomservices[442018 115322 AM]

49Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 55 of 57 Page ID 1814

EXHIBIT F

s -

bullmiddot - ~ t ~ower Your Student Loan Pay~e~ts oday -- Students Helping Students Save Money

INCOME BASED PAJIIIJITPAIS

I C(gttoUC1 u~

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 56 of 57 Page ID 1815

X + C (D Not secure wwwstudoracom 0

CALL US NOW (85S) 978-S599 middot 1nfostudoracom

HOME SERVICES ABOUT US FAQ CONTACT US BLOC PRIVACY

Offering obligation and commitment free loan relief solutions

STUDENT LOAN FORGIVENESS INCOME BASED PAYMENTS LOAN CONSOLIDATION

We11 help you get your loans reduced forgiven o r Make monthly pdyments based on your affordability Get multiple Federal Student Loans consolidated into

discharged one low monthly payment

Talk to our experts concerning your

student loans

Studora is a pnvatefy owned company that helps consumers like you identify

government programs that fit your financial s1tuat1on Our loan experts will assist you in selecting the appropriate programs that WOltk with your income family size and

desired monthly payment We then prepare the appropriate documents for your review and submission All this f o r one low easy payment

Testimonials

Thank you f o r getting back to me quickly Youve been fabulous Thank you for the confirmation and for your help today Pass

during this whole process Is there a place I can go online that I this on to your sup that you were very professional and very

can leave a comment for your manager Youve made this Robert helpful and brought a sense of relief for me Thank you very

process so easy and answered every question my husband and I much and have a great rest of your day Kudos to you and your

have had teammoneywell spenL

Exhibit F 50

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 57 of 57 Page ID 1816

Services we offer

Stud ora offers document preparation services for all loan forgiveness consolidation and relief services to people who are unable to manage their finances Our mam aim is to

offer complete peace of mind to indiVidual unable to pay their student loan debt

we otter the folloWing document preparation services with complete professional assistance

amFinancial Review ffl Budget Planning

Toe first step to creating a flexible loan repayment plan is financial review we also help create a personal finance plan to ensure that you are able to

Our professmnals will look into your finances and design a custom manage your monthly budget in the most effective way This plan will keep

repayment plan that is affordable and easy to manage your spending to the minimum alloWing you to save more money for loan

repayment

Permanent Disability Forgiveness r-trTeacher Loan Forgiveness (5 You can get rid of your Federal Student Loan if you are permanently disabled Good news for teachers who are under the weight of a massiVe loan You can

now get $17 forgiven on your student loans

Public Service Loan Forgiveness Custom Debt Relief Plans

Want assistance with debt relief Get in touch with our experts who will help If you are a public service agent you can get rid of your loan after 120 days of design a loan repayment and relief plan for you based on your monthly

income and affordability payments

THERE ARE NO OBLIGATIONS OR COMMITMENTS

want to save thousands of dollars Fill out our form and get relief from your student loan for a more

peaceful tomorrow

Your Name

BiHHHi

Exhibit F 51

Attachment A

Page 29: JOSHUA S. MILLARD, BRIAN M. WELKE, pro hac vice · for which it has no legitimate claim. Noel is a Wyoming limited liability company that reported in a public document that its principal

((

z | ~

AIDINGSTUDENTRELIEF

bull bull bull bull bull

13 deg $ $ampdegdeg deg() ˝ amp $$deg( + -+Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 29 of 57 Page ID 1788

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4556789fADlt=gtA9BCAD

DZgtA=EFGHIJFKLMNOPFQOGFHIQRSTLKSUMMNOPLHMTFIVRWXHKKNIFNUNOPRLFGSHKSRVRVNQ

f e=klHMW

9SI]UQMSNSOQOHHPFK YaSTHHVVJFMHcVGNOJVHHFKKPSUHMLIUOQN_PL[KSVFGJPRSDTHRFPLIP=SNDC==GFdFIP9VaNHQTWSRPbHF_PSKSVNMPMHNIO XNNIIFRKNF7IKSQQMHFNDVPOS9IAeTHPdKSUMMFNKHONP 8aF_KSNVPHTNIMNR[POVFgNPTHLNHIgtMFI YTFHIdFFI D9aHVR_KNKHFHIWIQOTHIQbFFP

lt=Dkgt=L]oHUKMMH ihTFNIORI THHVPRFMVKgtNJ_NFFbIVSJI]IFjdGGVNNN lt=TFKPPNF 9DaFGmVHPGRJMFNNQOSGnPFFTNLUNHPMIMTFVNJOKMIWV

27

]UMNOHPFRKNVSHKKISIRWRrGZNJONgtNjTHKHMI=cQgtORHVPKSOUMddUNKSPIdspNVPNq_ lt=gtBTHFHPb=HFILGFHMt DTFuFIUVFRPNTFIMINVWOPRVOQFIV sFQFPHKKH vaIPNFVcSyOFSPRFMRNVOJH_gtVFDVUJAN9FPwFuVFJLFHMP_VTFFdSIIVdNHUPxI=DQSROJGASHIVdDSNMINONPPaHdOHdPFHRIWVFFHdFIGM˙ 01 $2 301 $$3 ( Exhibit B

8

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676EBCEDK5ltAC]5EF_5665E7gt5lt7aFb688E588lt76B5E6F8EBAC78lt76cdddefghijhggklmknmopqprpopst u

13 deg $ $ampdegdeg degˇ amp $$deg + -+Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 30 of 57 Page ID 1789 () ( vPSZwPxyYTUZUWWzxPyxSWMZWPU|SWUWYZ~YTY~QSWbullYXRwU~UxSdaggerXQ~UZXvPSZWSOVQSYNOXPRSTUSDaggerPxXYPZPNXRUSPQZXPbullU~SOhellipUNPxyYTUZmdash zUxSZUZXndashYWShellipYYXOwPxyYTUZUWWMNOPQx~YWShellipYYXOYWUƒDaggerU|XU~XPSWXfrasllsaquoPZXRWPxPxUOPQSOVQSYNONPxDaggerUxSZUZX~YWShellipYYXONPxyYTUZUWWmdash

rsaquominus MZ|PUpermilSWUzSOUZXWbdquoDaggerUxYP~PNZSZ|YSRSx~WRYDaggerSOVQSYNOOPQNPxSZMZ|PUpermilSWU~rdquoUDaggerSOUZXzSZmdashMZSZO|SWUWXRYWUSZWOPQDaggerSOZPXRYZymdash zQhellipY|daggerUxTY|UvPSZwPxyYTUZUWWMNOPQbullPxlsquoNPxSyPTUxZUZXPxySZYrsquoSXYPZSXS|YXOWXSXUPxNU~UxSUTUOPQSOVQSYNONPxXRUzQhellipY|daggerUxTY|UvPSZwPxyYTUZUWWDaggerxPyxSmdashsbquotrade f8Ef8E78FCB6C8EŁPQSOhellipUShellipUXP|PhellipYZUQXYDaggerUNU~UxSWXQ~UZXPSZWYZXPPZUZUbullPSZbullYXRSPbullUxPxUSŒPx~ShellipUPZXRODaggerSOUZXmdashvPSZ|PZWPY~SXYPZDaggerxPyxSW|SZRUDaggerOPQVQSYNONPxS~~YXYPZSDaggerxPyxSW YlsquoU PSZ NPxyYTUZUWWDaggerxPyxSWPxzQhellipY|daggerUxTY|UvPSZwPxyYTUZUWWmdash ŠmŸŽıłŠm 57gt8A57A5B= 8E65C76B5E6F8EB5=6G

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28

Attachment A

01 $2 301 $$3 ( Exhibit B

()(

=4ABC9DEAFBD=FGFHIJKLMJNOMN MRNS mn = nrst = svzhellipu t bulltvDaggerrhellipDaggerurbullbulltuhellipv hellipz~ bullmdashldquordquolsquorsquotrade š oŒŠeuro centpound ` umluml 13 deg $ $ampdegdeg degˇ amp $$deg + -+Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 31 of 57 Page ID 1790

ISNRTUKQINKKNNKL[MRJ PUWQI]MRM qyt|tytzxy rsaquoqNfraslbdquoPUhellipsbquoLUyQhellip rfraslbhellipMNSIKVUQ QNJKvUQsMiexclQQJUx[iexcliexcl_vsect_Qyenyenbrvbarbrvbar uSSRNTPL_LUUMKIaJ_WMIJJKVIONNQJJMWRMIIbQQURKLWIIJQbKLUNKMPTMNQQ_KKRY tbullbulldaggersDaggerv~vhellipmdashryrhellip~mdashrhellipDagger ŸLŽUıQŽbłpermilMtradeœsbquoNtrade_ffRŁyISMŒUQWyNUQŠlsaquo rv45657896lt7ltgt5lt PQKLMIQSNRTUKINQVNOOMVKMWNQKLIJPMXJIKMYZMPIOO NJMOOJLURMNRRMKKLIJ klltko ltgtlt85p5gt5 ouvwxrz ^^ ~ minuspermil tffŁ yenpoundpound KNOWDaggerIreggt4lt97ltndash9ƒ Dagger hellipDaggerlsaquo žko74k57ƒ ƒISNcurrenUIWIbJKWMKJYVNTKM KLONNRqIQQSNNRTUKINQQIJ_JMWNQKLIJJJPMXJIKMcOMUJMVNQKUVK_JUKBHdefABCgDEAFBDghidjlaquopoundbrvbariexclnotvIWIQbDaggerK_WMQKbullMOIMSvOObullIbLKJbullMJMRMW ordf copy

01( $2(301$$3( Exhibit B

29

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 32 of 57 Page ID 1791

EXHIBIT C

Attachment A

~ 111 ~tampi 10 11 ~bull ia1111

Something awesome is coming soon We are buildin somethin ve cool Sta tuned and be at1ent Your atience will be well aid

~lbullrbullUiUffl We can help you reduce and simplify your payments

101 Loan For iveness

1~u 0 (middottmiddotbullmiddotmiddot1 1~=I -- _~

HZamp IMUliULlampRampatiEUWi nmiddot middot-il~ fr middot 8rbullbullrcrr-

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~ Income Based Pa ents

bull ~ f I - - I - I - ri u ~u-=lf ~ JU

1-bullA ---rc iM1~~ -~-bullCiel rrcl

~- middot IY 2 i C middot middotJ ll1Jmiddot 0 _ middot_middotIr i

~ LdfiJIMifJ11JJMJllfFffi

middotE-ltecl l2bullJbull iequbullt t11cit t1lt2 CtpCr~middot1e- f

JJd r g-_iraE-1 agltr-middot- ntimiddot middot)middotou

tmiddot_rt- i ic l~1ri ~rbullmiddot middot111~ umiddot -_ d_t-c

fsectmet-Naibullfyen1~poundibllffifftmI

I f-nle Vnot Nune

I ampterYOllrEmall ]

1 ~~~~ 1

If -bull 13n ~Cbull t~middot rct1~j d- gtOY- - hO- irmiddot (bulldbull) plltmiddotmiddot- leemiddotmiddot JOu

1r1cbullmiddotn111f11ri ll1fbull fcrn to ~bull~I

Triin- GU

WAWMyenEIRitiRpoundWt 44 ZiAtillampampI

Exhibit C

Case 818-cv-01987-JLS

-KE

S

Docum

ent 50-1 F

iled 020519 P

age 33 of 57 P

age ID 1792

30

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 34 of 57 Page ID 1793

EXHIBIT D

Attachment A

bull bull bull bull bull bull bull

---

Type then hit enter to

bull bull bull bull bull bull bull

----

----

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 35 of 57 Page ID 1794

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

infoaidnestcom (800) 555-1212

HOME

ABOUT US

SERVICES

FAQ

BLOG

CONTACT

HOME ABOUT US SERVICES FAQ BLOG CONTACT

1 of 6 462018 945 AM

31

Student Loan Forgiveness Loan Consolidation Student Loan Forgiveness

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 36 of 57 Page ID 1795

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

If you have Federal Student Loans yoursquore in the right place to get those loans reduced forgiven or completely discharged through our student loan forgiveness programs

Get your multiple Federal Student Loans consolidated into one forget about increasing interests and pay month to month at the lowest possible cost

We understand if yoursquore going through some hardship and thatrsquos why with us yoursquoll be able to make monthly payments based on your affordability for as low as $000 depending on your situation

2 of 6 462018 945 AM

32

Knowledge Base

Defaulted Student Loans

Wage Garnishment

Student Loan Rehabilitation

Income Based Repayment Plan

Deferment and Forbearance

Pay As You Earn Repayment Plan

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE Call 561)424-6053 today to go over your options

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 37 of 57 Page ID 1796

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

Our knowledge base is designed to provide information regarding some of the critical topics those with student loans must be aware of to be able to make educated decisions regarding their future

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

A wage garnishment is any legal procedure in which some portion of a personrsquos earnings is required to be withheld by an employer for the payment of a debt

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

With this program your payments change as your income changes and will not be longer than 25 years This is the ideal plan if you are in partial financial hardship Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard plan

Temporarily allowing you to postpone or reduce your federal student loan payments Postponing or reducing your payments may help you avoid default and future garnishments

Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard

3 of 6 462018 945 AM

33

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 38 of 57 Page ID 1797

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

4 of 6 462018 945 AM

34Attachment A

Testimonials

Latest News

Why 2016 Will Be a Big Year For Student Loans

Top Student Loan Refinancing Questions of 2015

Oba mas latest student loan plan

Things You Should Know About Public Service Loan Forgiveness

Recent Posts

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 39 of 57 Page ID 1798

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

5 of 6 462018 945 AM

35

About Us

Contact Info

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 40 of 57 Page ID 1799

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

pay-grandchild-studen

Why 2016 Will Be a Big Year For Student Loans

December 30 2015

12511110_1112367518

Top Student Loan Refinancing Questions of 2015

December 30 2015

We stand by our consultation and quote We are so sure and confident about our services and offers that they are all 100 money back guarantee risk free ndash if we donrsquot do what we promise yoursquoll get your money back

(800) 555-1212 AidnestStudenLoansgmailcom 18100 Von Karman Ave Suite 850 Irvine CA 92612

Futero SAS copy 2015 | Aidnestcom

6 of 6 462018 945

Exhibit D 36Attachment A

AM

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 41 of 57 Page ID 1800

EXHIBIT E

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 42 of 57 Page ID 1801

AIDNEST Let us help you through this national crisis

Call one of our specialists today

Forbearance amp Deferment If you are still in school and struggling to make payments on your student loans You may qualify

for Forbearance amp Deferment

Garnishment Prevention Federal law requires that the Department of Education or guarantee agency notifies you before they

begin garnishing your wages

Loan Forgiveness If you are a teacher public service worker or an individual with total and permanent disability you

httpaidnestcom[442018 115239 AM]

37Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 43 of 57 Page ID 1802

AIDNEST Let us help you through this national crisis

may qualify for this program

Consolidating Your Loans Consolidating your loans to one new loan under one lender may lower your payments and make

your life a bit more manageable

Affordable Payments If you are looking to lower your monthly payments then Income Based Repayment Plans may be

the correct choice for you

Learn more about our services

LEARN MORE

httpaidnestcom[442018 115239 AM]

38Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 44 of 57 Page ID 1803

AIDNEST Let us help you through this national crisis

Loan Forgiveness Programs Income Based Payments Student Loan Rehabilitation

Student Loan Consolidation

You may be eligible for

Loan Forgiveness Programs

In some cases individuals with Federal Student Loans may qualify to have a portion of the amount

owed to be forgiven

Get in touch with our professional team to find out which loan forgiveness program you qualify for and

how you can get rid of your unpaid student loan

L EARN MORE

httpaidnestcom[442018 115239 AM]

39Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 45 of 57 Page ID 1804

AIDNEST Let us help you through this national crisis

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE

Meet your Budget One of our advisers will help you meet your payment goals by using your budget and timeline to

determine the best plan available

httpaidnestcom[442018 115239 AM]

40Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 46 of 57 Page ID 1805

AIDNEST Let us help you through this national crisis

Simple Process We understand that lowering your payments alone can be difficult Our intuitive platform allows us

to keep the entire process simple

Customer Satisfaction We are committed to providing you with outstanding service only We look forward to working

with you

100 money back guarantee No Hassle Money Back Policy

httpaidnestcom[442018 115239 AM]

41Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 47 of 57 Page ID 1806

AIDNEST Let us help you through this national crisis

Lower your loan payments by getting in touch with one of our professionals

We design a customized repayment plan that will allow you to make payments based on your

monthly income family size and spending Get rid of the hassle of extensive paperwork and get the

help you deserve

What we can help you achieve a lower payment or lower rate

httpaidnestcom[442018 115239 AM]

42Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 48 of 57 Page ID 1807

AIDNEST Let us help you through this national crisis

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcom[442018 115239 AM]

43Exhibit E

httpaidnestcomservices[442018 115322 AM]

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 49 of 57 Page ID 1808

Services | AIDNEST Let us help you through this national crisis

INCOME BASED PAYMENTS

If you are suffering from a financial hardship you may be eligible for an

Income Based Payment In this repayment program you would have a

payment based on your income and family size The payment could be as

low as $000 per month with forgiveness at the end of 20-25 years

44

Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 50 of 57 Page ID 1809

L E ARN MORE

LOAN FORGIVENESS

If you have Federal Student Loans you may qualify for any of the student

loan forgiveness programs that are available to borrowers You may be

eligible for principal reduction loan forgiveness or a complete loan

discharge depending on your individual circumstance

L EARN MORE

PRIVATE STUDENT LOAN CONSOLIDATION

Much like refinancing a mortgage generally the biggest benefit of private

student loan consolidationstudent loan refinancing is a lower interest rate

httpaidnestcomservices[442018 115322 AM]

45Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 51 of 57 Page ID 1810

L E ARN MORE

(something federal consolidations do not offer)

STUDENT LOAN REHABILITATION

You can renew eligibility for new loans and grants and eliminate the loan

default by ldquorehabilitatingrdquo a defaulted loan

httpaidnestcomservices[442018 115322 AM]

46Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 52 of 57 Page ID 1811

CHE CK E L E G I B I L I T Y

WAGE GARNISHMENT

A wage garnishment is any legal procedure in which some portion of a

personrsquos earnings is required to be withheld by an employer for the

payment of a debt

L EARN MORE

With our fast friendly and professional services wersquoll be glad to help you get your student loans

reduced forgiven or completely discharged To this end wersquoll assist you in consolidating all your

student loans so yoursquoll have only one lender and yoursquoll start making one monthly payment Our

professionals will walk you through the best and most flexible repayment options and if itrsquos also

necessary varied deferment options and rehabilitation programs

httpaidnestcomservices[442018 115322 AM]

47Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 53 of 57 Page ID 1812

Services | AIDNEST Let us help you through this national crisis

Our CRM System

Our CRM is one of the most advanced in the industry and most importantly itrsquos linked directly to

the Department of Education (DOE) This keeps your personal and most confidential information

safe Furthermore because our CRM system is linked to the DOE our approval is 100 Through

our CRM we will be doing continuous monitoring of our process without losing sight of your

immediate needs ensuring that your case has the proper handling and most efficient process

httpaidnestcomservices[442018 115322 AM]

48Exhibit E

n

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 54 of 57 Page ID 1813

Services | AIDNEST Let us help you through this national crisis

R ECENT POSTS

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

ABOUT US

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcomservices[442018 115322 AM]

49Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 55 of 57 Page ID 1814

EXHIBIT F

s -

bullmiddot - ~ t ~ower Your Student Loan Pay~e~ts oday -- Students Helping Students Save Money

INCOME BASED PAJIIIJITPAIS

I C(gttoUC1 u~

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 56 of 57 Page ID 1815

X + C (D Not secure wwwstudoracom 0

CALL US NOW (85S) 978-S599 middot 1nfostudoracom

HOME SERVICES ABOUT US FAQ CONTACT US BLOC PRIVACY

Offering obligation and commitment free loan relief solutions

STUDENT LOAN FORGIVENESS INCOME BASED PAYMENTS LOAN CONSOLIDATION

We11 help you get your loans reduced forgiven o r Make monthly pdyments based on your affordability Get multiple Federal Student Loans consolidated into

discharged one low monthly payment

Talk to our experts concerning your

student loans

Studora is a pnvatefy owned company that helps consumers like you identify

government programs that fit your financial s1tuat1on Our loan experts will assist you in selecting the appropriate programs that WOltk with your income family size and

desired monthly payment We then prepare the appropriate documents for your review and submission All this f o r one low easy payment

Testimonials

Thank you f o r getting back to me quickly Youve been fabulous Thank you for the confirmation and for your help today Pass

during this whole process Is there a place I can go online that I this on to your sup that you were very professional and very

can leave a comment for your manager Youve made this Robert helpful and brought a sense of relief for me Thank you very

process so easy and answered every question my husband and I much and have a great rest of your day Kudos to you and your

have had teammoneywell spenL

Exhibit F 50

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 57 of 57 Page ID 1816

Services we offer

Stud ora offers document preparation services for all loan forgiveness consolidation and relief services to people who are unable to manage their finances Our mam aim is to

offer complete peace of mind to indiVidual unable to pay their student loan debt

we otter the folloWing document preparation services with complete professional assistance

amFinancial Review ffl Budget Planning

Toe first step to creating a flexible loan repayment plan is financial review we also help create a personal finance plan to ensure that you are able to

Our professmnals will look into your finances and design a custom manage your monthly budget in the most effective way This plan will keep

repayment plan that is affordable and easy to manage your spending to the minimum alloWing you to save more money for loan

repayment

Permanent Disability Forgiveness r-trTeacher Loan Forgiveness (5 You can get rid of your Federal Student Loan if you are permanently disabled Good news for teachers who are under the weight of a massiVe loan You can

now get $17 forgiven on your student loans

Public Service Loan Forgiveness Custom Debt Relief Plans

Want assistance with debt relief Get in touch with our experts who will help If you are a public service agent you can get rid of your loan after 120 days of design a loan repayment and relief plan for you based on your monthly

income and affordability payments

THERE ARE NO OBLIGATIONS OR COMMITMENTS

want to save thousands of dollars Fill out our form and get relief from your student loan for a more

peaceful tomorrow

Your Name

BiHHHi

Exhibit F 51

Attachment A

Page 30: JOSHUA S. MILLARD, BRIAN M. WELKE, pro hac vice · for which it has no legitimate claim. Noel is a Wyoming limited liability company that reported in a public document that its principal

8

~ldquo

middot

676EBCEDK5ltAC]5EF_5665E7gt5lt7aFb688E588lt76B5E6F8EBAC78lt76cdddefghijhggklmknmopqprpopst u

13 deg $ $ampdegdeg degˇ amp $$deg + -+Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 30 of 57 Page ID 1789 () ( vPSZwPxyYTUZUWWzxPyxSWMZWPU|SWUWYZ~YTY~QSWbullYXRwU~UxSdaggerXQ~UZXvPSZWSOVQSYNOXPRSTUSDaggerPxXYPZPNXRUSPQZXPbullU~SOhellipUNPxyYTUZmdash zUxSZUZXndashYWShellipYYXOwPxyYTUZUWWMNOPQx~YWShellipYYXOYWUƒDaggerU|XU~XPSWXfrasllsaquoPZXRWPxPxUOPQSOVQSYNONPxDaggerUxSZUZX~YWShellipYYXONPxyYTUZUWWmdash

rsaquominus MZ|PUpermilSWUzSOUZXWbdquoDaggerUxYP~PNZSZ|YSRSx~WRYDaggerSOVQSYNOOPQNPxSZMZ|PUpermilSWU~rdquoUDaggerSOUZXzSZmdashMZSZO|SWUWXRYWUSZWOPQDaggerSOZPXRYZymdash zQhellipY|daggerUxTY|UvPSZwPxyYTUZUWWMNOPQbullPxlsquoNPxSyPTUxZUZXPxySZYrsquoSXYPZSXS|YXOWXSXUPxNU~UxSUTUOPQSOVQSYNONPxXRUzQhellipY|daggerUxTY|UvPSZwPxyYTUZUWWDaggerxPyxSmdashsbquotrade f8Ef8E78FCB6C8EŁPQSOhellipUShellipUXP|PhellipYZUQXYDaggerUNU~UxSWXQ~UZXPSZWYZXPPZUZUbullPSZbullYXRSPbullUxPxUSŒPx~ShellipUPZXRODaggerSOUZXmdashvPSZ|PZWPY~SXYPZDaggerxPyxSW|SZRUDaggerOPQVQSYNONPxS~~YXYPZSDaggerxPyxSW YlsquoU PSZ NPxyYTUZUWWDaggerxPyxSWPxzQhellipY|daggerUxTY|UvPSZwPxyYTUZUWWmdash ŠmŸŽıłŠm 57gt8A57A5B= 8E65C76B5E6F8EB5=6G

PONM[5 QRSTUVQU PYXWZW lt4556789588lt959=lt CD lt H5FICEDJ8KA5LCD

A565E7gt57 œšžeuroiexclcentpoundyenbrvbarsectbrvbareurocopypoundsectlaquoeuropoundlaquobrvbarlaquoregplusmncentbrvbareurocent microparalaquo europoundž raquoY|frac14frac12 plusmncurrenRSUraquoSxXYZeuropoundlaquo laquoeurolaquoordf frac34

^ ˙ ( (

28

Attachment A

01 $2 301 $$3 ( Exhibit B

()(

=4ABC9DEAFBD=FGFHIJKLMJNOMN MRNS mn = nrst = svzhellipu t bulltvDaggerrhellipDaggerurbullbulltuhellipv hellipz~ bullmdashldquordquolsquorsquotrade š oŒŠeuro centpound ` umluml 13 deg $ $ampdegdeg degˇ amp $$deg + -+Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 31 of 57 Page ID 1790

ISNRTUKQINKKNNKL[MRJ PUWQI]MRM qyt|tytzxy rsaquoqNfraslbdquoPUhellipsbquoLUyQhellip rfraslbhellipMNSIKVUQ QNJKvUQsMiexclQQJUx[iexcliexcl_vsect_Qyenyenbrvbarbrvbar uSSRNTPL_LUUMKIaJ_WMIJJKVIONNQJJMWRMIIbQQURKLWIIJQbKLUNKMPTMNQQ_KKRY tbullbulldaggersDaggerv~vhellipmdashryrhellip~mdashrhellipDagger ŸLŽUıQŽbłpermilMtradeœsbquoNtrade_ffRŁyISMŒUQWyNUQŠlsaquo rv45657896lt7ltgt5lt PQKLMIQSNRTUKINQVNOOMVKMWNQKLIJPMXJIKMYZMPIOO NJMOOJLURMNRRMKKLIJ klltko ltgtlt85p5gt5 ouvwxrz ^^ ~ minuspermil tffŁ yenpoundpound KNOWDaggerIreggt4lt97ltndash9ƒ Dagger hellipDaggerlsaquo žko74k57ƒ ƒISNcurrenUIWIbJKWMKJYVNTKM KLONNRqIQQSNNRTUKINQQIJ_JMWNQKLIJJJPMXJIKMcOMUJMVNQKUVK_JUKBHdefABCgDEAFBDghidjlaquopoundbrvbariexclnotvIWIQbDaggerK_WMQKbullMOIMSvOObullIbLKJbullMJMRMW ordf copy

01( $2(301$$3( Exhibit B

29

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 32 of 57 Page ID 1791

EXHIBIT C

Attachment A

~ 111 ~tampi 10 11 ~bull ia1111

Something awesome is coming soon We are buildin somethin ve cool Sta tuned and be at1ent Your atience will be well aid

~lbullrbullUiUffl We can help you reduce and simplify your payments

101 Loan For iveness

1~u 0 (middottmiddotbullmiddotmiddot1 1~=I -- _~

HZamp IMUliULlampRampatiEUWi nmiddot middot-il~ fr middot 8rbullbullrcrr-

_J l _ 1 _f _ur -~t~ u L liYu

~ Income Based Pa ents

bull ~ f I - - I - I - ri u ~u-=lf ~ JU

1-bullA ---rc iM1~~ -~-bullCiel rrcl

~- middot IY 2 i C middot middotJ ll1Jmiddot 0 _ middot_middotIr i

~ LdfiJIMifJ11JJMJllfFffi

middotE-ltecl l2bullJbull iequbullt t11cit t1lt2 CtpCr~middot1e- f

JJd r g-_iraE-1 agltr-middot- ntimiddot middot)middotou

tmiddot_rt- i ic l~1ri ~rbullmiddot middot111~ umiddot -_ d_t-c

fsectmet-Naibullfyen1~poundibllffifftmI

I f-nle Vnot Nune

I ampterYOllrEmall ]

1 ~~~~ 1

If -bull 13n ~Cbull t~middot rct1~j d- gtOY- - hO- irmiddot (bulldbull) plltmiddotmiddot- leemiddotmiddot JOu

1r1cbullmiddotn111f11ri ll1fbull fcrn to ~bull~I

Triin- GU

WAWMyenEIRitiRpoundWt 44 ZiAtillampampI

Exhibit C

Case 818-cv-01987-JLS

-KE

S

Docum

ent 50-1 F

iled 020519 P

age 33 of 57 P

age ID 1792

30

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 34 of 57 Page ID 1793

EXHIBIT D

Attachment A

bull bull bull bull bull bull bull

---

Type then hit enter to

bull bull bull bull bull bull bull

----

----

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 35 of 57 Page ID 1794

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

infoaidnestcom (800) 555-1212

HOME

ABOUT US

SERVICES

FAQ

BLOG

CONTACT

HOME ABOUT US SERVICES FAQ BLOG CONTACT

1 of 6 462018 945 AM

31

Student Loan Forgiveness Loan Consolidation Student Loan Forgiveness

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 36 of 57 Page ID 1795

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

If you have Federal Student Loans yoursquore in the right place to get those loans reduced forgiven or completely discharged through our student loan forgiveness programs

Get your multiple Federal Student Loans consolidated into one forget about increasing interests and pay month to month at the lowest possible cost

We understand if yoursquore going through some hardship and thatrsquos why with us yoursquoll be able to make monthly payments based on your affordability for as low as $000 depending on your situation

2 of 6 462018 945 AM

32

Knowledge Base

Defaulted Student Loans

Wage Garnishment

Student Loan Rehabilitation

Income Based Repayment Plan

Deferment and Forbearance

Pay As You Earn Repayment Plan

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE Call 561)424-6053 today to go over your options

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 37 of 57 Page ID 1796

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

Our knowledge base is designed to provide information regarding some of the critical topics those with student loans must be aware of to be able to make educated decisions regarding their future

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

A wage garnishment is any legal procedure in which some portion of a personrsquos earnings is required to be withheld by an employer for the payment of a debt

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

With this program your payments change as your income changes and will not be longer than 25 years This is the ideal plan if you are in partial financial hardship Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard plan

Temporarily allowing you to postpone or reduce your federal student loan payments Postponing or reducing your payments may help you avoid default and future garnishments

Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard

3 of 6 462018 945 AM

33

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 38 of 57 Page ID 1797

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

4 of 6 462018 945 AM

34Attachment A

Testimonials

Latest News

Why 2016 Will Be a Big Year For Student Loans

Top Student Loan Refinancing Questions of 2015

Oba mas latest student loan plan

Things You Should Know About Public Service Loan Forgiveness

Recent Posts

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 39 of 57 Page ID 1798

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

5 of 6 462018 945 AM

35

About Us

Contact Info

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 40 of 57 Page ID 1799

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

pay-grandchild-studen

Why 2016 Will Be a Big Year For Student Loans

December 30 2015

12511110_1112367518

Top Student Loan Refinancing Questions of 2015

December 30 2015

We stand by our consultation and quote We are so sure and confident about our services and offers that they are all 100 money back guarantee risk free ndash if we donrsquot do what we promise yoursquoll get your money back

(800) 555-1212 AidnestStudenLoansgmailcom 18100 Von Karman Ave Suite 850 Irvine CA 92612

Futero SAS copy 2015 | Aidnestcom

6 of 6 462018 945

Exhibit D 36Attachment A

AM

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 41 of 57 Page ID 1800

EXHIBIT E

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 42 of 57 Page ID 1801

AIDNEST Let us help you through this national crisis

Call one of our specialists today

Forbearance amp Deferment If you are still in school and struggling to make payments on your student loans You may qualify

for Forbearance amp Deferment

Garnishment Prevention Federal law requires that the Department of Education or guarantee agency notifies you before they

begin garnishing your wages

Loan Forgiveness If you are a teacher public service worker or an individual with total and permanent disability you

httpaidnestcom[442018 115239 AM]

37Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 43 of 57 Page ID 1802

AIDNEST Let us help you through this national crisis

may qualify for this program

Consolidating Your Loans Consolidating your loans to one new loan under one lender may lower your payments and make

your life a bit more manageable

Affordable Payments If you are looking to lower your monthly payments then Income Based Repayment Plans may be

the correct choice for you

Learn more about our services

LEARN MORE

httpaidnestcom[442018 115239 AM]

38Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 44 of 57 Page ID 1803

AIDNEST Let us help you through this national crisis

Loan Forgiveness Programs Income Based Payments Student Loan Rehabilitation

Student Loan Consolidation

You may be eligible for

Loan Forgiveness Programs

In some cases individuals with Federal Student Loans may qualify to have a portion of the amount

owed to be forgiven

Get in touch with our professional team to find out which loan forgiveness program you qualify for and

how you can get rid of your unpaid student loan

L EARN MORE

httpaidnestcom[442018 115239 AM]

39Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 45 of 57 Page ID 1804

AIDNEST Let us help you through this national crisis

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE

Meet your Budget One of our advisers will help you meet your payment goals by using your budget and timeline to

determine the best plan available

httpaidnestcom[442018 115239 AM]

40Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 46 of 57 Page ID 1805

AIDNEST Let us help you through this national crisis

Simple Process We understand that lowering your payments alone can be difficult Our intuitive platform allows us

to keep the entire process simple

Customer Satisfaction We are committed to providing you with outstanding service only We look forward to working

with you

100 money back guarantee No Hassle Money Back Policy

httpaidnestcom[442018 115239 AM]

41Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 47 of 57 Page ID 1806

AIDNEST Let us help you through this national crisis

Lower your loan payments by getting in touch with one of our professionals

We design a customized repayment plan that will allow you to make payments based on your

monthly income family size and spending Get rid of the hassle of extensive paperwork and get the

help you deserve

What we can help you achieve a lower payment or lower rate

httpaidnestcom[442018 115239 AM]

42Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 48 of 57 Page ID 1807

AIDNEST Let us help you through this national crisis

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcom[442018 115239 AM]

43Exhibit E

httpaidnestcomservices[442018 115322 AM]

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 49 of 57 Page ID 1808

Services | AIDNEST Let us help you through this national crisis

INCOME BASED PAYMENTS

If you are suffering from a financial hardship you may be eligible for an

Income Based Payment In this repayment program you would have a

payment based on your income and family size The payment could be as

low as $000 per month with forgiveness at the end of 20-25 years

44

Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 50 of 57 Page ID 1809

L E ARN MORE

LOAN FORGIVENESS

If you have Federal Student Loans you may qualify for any of the student

loan forgiveness programs that are available to borrowers You may be

eligible for principal reduction loan forgiveness or a complete loan

discharge depending on your individual circumstance

L EARN MORE

PRIVATE STUDENT LOAN CONSOLIDATION

Much like refinancing a mortgage generally the biggest benefit of private

student loan consolidationstudent loan refinancing is a lower interest rate

httpaidnestcomservices[442018 115322 AM]

45Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 51 of 57 Page ID 1810

L E ARN MORE

(something federal consolidations do not offer)

STUDENT LOAN REHABILITATION

You can renew eligibility for new loans and grants and eliminate the loan

default by ldquorehabilitatingrdquo a defaulted loan

httpaidnestcomservices[442018 115322 AM]

46Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 52 of 57 Page ID 1811

CHE CK E L E G I B I L I T Y

WAGE GARNISHMENT

A wage garnishment is any legal procedure in which some portion of a

personrsquos earnings is required to be withheld by an employer for the

payment of a debt

L EARN MORE

With our fast friendly and professional services wersquoll be glad to help you get your student loans

reduced forgiven or completely discharged To this end wersquoll assist you in consolidating all your

student loans so yoursquoll have only one lender and yoursquoll start making one monthly payment Our

professionals will walk you through the best and most flexible repayment options and if itrsquos also

necessary varied deferment options and rehabilitation programs

httpaidnestcomservices[442018 115322 AM]

47Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 53 of 57 Page ID 1812

Services | AIDNEST Let us help you through this national crisis

Our CRM System

Our CRM is one of the most advanced in the industry and most importantly itrsquos linked directly to

the Department of Education (DOE) This keeps your personal and most confidential information

safe Furthermore because our CRM system is linked to the DOE our approval is 100 Through

our CRM we will be doing continuous monitoring of our process without losing sight of your

immediate needs ensuring that your case has the proper handling and most efficient process

httpaidnestcomservices[442018 115322 AM]

48Exhibit E

n

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 54 of 57 Page ID 1813

Services | AIDNEST Let us help you through this national crisis

R ECENT POSTS

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

ABOUT US

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcomservices[442018 115322 AM]

49Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 55 of 57 Page ID 1814

EXHIBIT F

s -

bullmiddot - ~ t ~ower Your Student Loan Pay~e~ts oday -- Students Helping Students Save Money

INCOME BASED PAJIIIJITPAIS

I C(gttoUC1 u~

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 56 of 57 Page ID 1815

X + C (D Not secure wwwstudoracom 0

CALL US NOW (85S) 978-S599 middot 1nfostudoracom

HOME SERVICES ABOUT US FAQ CONTACT US BLOC PRIVACY

Offering obligation and commitment free loan relief solutions

STUDENT LOAN FORGIVENESS INCOME BASED PAYMENTS LOAN CONSOLIDATION

We11 help you get your loans reduced forgiven o r Make monthly pdyments based on your affordability Get multiple Federal Student Loans consolidated into

discharged one low monthly payment

Talk to our experts concerning your

student loans

Studora is a pnvatefy owned company that helps consumers like you identify

government programs that fit your financial s1tuat1on Our loan experts will assist you in selecting the appropriate programs that WOltk with your income family size and

desired monthly payment We then prepare the appropriate documents for your review and submission All this f o r one low easy payment

Testimonials

Thank you f o r getting back to me quickly Youve been fabulous Thank you for the confirmation and for your help today Pass

during this whole process Is there a place I can go online that I this on to your sup that you were very professional and very

can leave a comment for your manager Youve made this Robert helpful and brought a sense of relief for me Thank you very

process so easy and answered every question my husband and I much and have a great rest of your day Kudos to you and your

have had teammoneywell spenL

Exhibit F 50

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 57 of 57 Page ID 1816

Services we offer

Stud ora offers document preparation services for all loan forgiveness consolidation and relief services to people who are unable to manage their finances Our mam aim is to

offer complete peace of mind to indiVidual unable to pay their student loan debt

we otter the folloWing document preparation services with complete professional assistance

amFinancial Review ffl Budget Planning

Toe first step to creating a flexible loan repayment plan is financial review we also help create a personal finance plan to ensure that you are able to

Our professmnals will look into your finances and design a custom manage your monthly budget in the most effective way This plan will keep

repayment plan that is affordable and easy to manage your spending to the minimum alloWing you to save more money for loan

repayment

Permanent Disability Forgiveness r-trTeacher Loan Forgiveness (5 You can get rid of your Federal Student Loan if you are permanently disabled Good news for teachers who are under the weight of a massiVe loan You can

now get $17 forgiven on your student loans

Public Service Loan Forgiveness Custom Debt Relief Plans

Want assistance with debt relief Get in touch with our experts who will help If you are a public service agent you can get rid of your loan after 120 days of design a loan repayment and relief plan for you based on your monthly

income and affordability payments

THERE ARE NO OBLIGATIONS OR COMMITMENTS

want to save thousands of dollars Fill out our form and get relief from your student loan for a more

peaceful tomorrow

Your Name

BiHHHi

Exhibit F 51

Attachment A

Page 31: JOSHUA S. MILLARD, BRIAN M. WELKE, pro hac vice · for which it has no legitimate claim. Noel is a Wyoming limited liability company that reported in a public document that its principal

()(

=4ABC9DEAFBD=FGFHIJKLMJNOMN MRNS mn = nrst = svzhellipu t bulltvDaggerrhellipDaggerurbullbulltuhellipv hellipz~ bullmdashldquordquolsquorsquotrade š oŒŠeuro centpound ` umluml 13 deg $ $ampdegdeg degˇ amp $$deg + -+Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 31 of 57 Page ID 1790

ISNRTUKQINKKNNKL[MRJ PUWQI]MRM qyt|tytzxy rsaquoqNfraslbdquoPUhellipsbquoLUyQhellip rfraslbhellipMNSIKVUQ QNJKvUQsMiexclQQJUx[iexcliexcl_vsect_Qyenyenbrvbarbrvbar uSSRNTPL_LUUMKIaJ_WMIJJKVIONNQJJMWRMIIbQQURKLWIIJQbKLUNKMPTMNQQ_KKRY tbullbulldaggersDaggerv~vhellipmdashryrhellip~mdashrhellipDagger ŸLŽUıQŽbłpermilMtradeœsbquoNtrade_ffRŁyISMŒUQWyNUQŠlsaquo rv45657896lt7ltgt5lt PQKLMIQSNRTUKINQVNOOMVKMWNQKLIJPMXJIKMYZMPIOO NJMOOJLURMNRRMKKLIJ klltko ltgtlt85p5gt5 ouvwxrz ^^ ~ minuspermil tffŁ yenpoundpound KNOWDaggerIreggt4lt97ltndash9ƒ Dagger hellipDaggerlsaquo žko74k57ƒ ƒISNcurrenUIWIbJKWMKJYVNTKM KLONNRqIQQSNNRTUKINQQIJ_JMWNQKLIJJJPMXJIKMcOMUJMVNQKUVK_JUKBHdefABCgDEAFBDghidjlaquopoundbrvbariexclnotvIWIQbDaggerK_WMQKbullMOIMSvOObullIbLKJbullMJMRMW ordf copy

01( $2(301$$3( Exhibit B

29

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 32 of 57 Page ID 1791

EXHIBIT C

Attachment A

~ 111 ~tampi 10 11 ~bull ia1111

Something awesome is coming soon We are buildin somethin ve cool Sta tuned and be at1ent Your atience will be well aid

~lbullrbullUiUffl We can help you reduce and simplify your payments

101 Loan For iveness

1~u 0 (middottmiddotbullmiddotmiddot1 1~=I -- _~

HZamp IMUliULlampRampatiEUWi nmiddot middot-il~ fr middot 8rbullbullrcrr-

_J l _ 1 _f _ur -~t~ u L liYu

~ Income Based Pa ents

bull ~ f I - - I - I - ri u ~u-=lf ~ JU

1-bullA ---rc iM1~~ -~-bullCiel rrcl

~- middot IY 2 i C middot middotJ ll1Jmiddot 0 _ middot_middotIr i

~ LdfiJIMifJ11JJMJllfFffi

middotE-ltecl l2bullJbull iequbullt t11cit t1lt2 CtpCr~middot1e- f

JJd r g-_iraE-1 agltr-middot- ntimiddot middot)middotou

tmiddot_rt- i ic l~1ri ~rbullmiddot middot111~ umiddot -_ d_t-c

fsectmet-Naibullfyen1~poundibllffifftmI

I f-nle Vnot Nune

I ampterYOllrEmall ]

1 ~~~~ 1

If -bull 13n ~Cbull t~middot rct1~j d- gtOY- - hO- irmiddot (bulldbull) plltmiddotmiddot- leemiddotmiddot JOu

1r1cbullmiddotn111f11ri ll1fbull fcrn to ~bull~I

Triin- GU

WAWMyenEIRitiRpoundWt 44 ZiAtillampampI

Exhibit C

Case 818-cv-01987-JLS

-KE

S

Docum

ent 50-1 F

iled 020519 P

age 33 of 57 P

age ID 1792

30

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 34 of 57 Page ID 1793

EXHIBIT D

Attachment A

bull bull bull bull bull bull bull

---

Type then hit enter to

bull bull bull bull bull bull bull

----

----

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 35 of 57 Page ID 1794

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

infoaidnestcom (800) 555-1212

HOME

ABOUT US

SERVICES

FAQ

BLOG

CONTACT

HOME ABOUT US SERVICES FAQ BLOG CONTACT

1 of 6 462018 945 AM

31

Student Loan Forgiveness Loan Consolidation Student Loan Forgiveness

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 36 of 57 Page ID 1795

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

If you have Federal Student Loans yoursquore in the right place to get those loans reduced forgiven or completely discharged through our student loan forgiveness programs

Get your multiple Federal Student Loans consolidated into one forget about increasing interests and pay month to month at the lowest possible cost

We understand if yoursquore going through some hardship and thatrsquos why with us yoursquoll be able to make monthly payments based on your affordability for as low as $000 depending on your situation

2 of 6 462018 945 AM

32

Knowledge Base

Defaulted Student Loans

Wage Garnishment

Student Loan Rehabilitation

Income Based Repayment Plan

Deferment and Forbearance

Pay As You Earn Repayment Plan

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE Call 561)424-6053 today to go over your options

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 37 of 57 Page ID 1796

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

Our knowledge base is designed to provide information regarding some of the critical topics those with student loans must be aware of to be able to make educated decisions regarding their future

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

A wage garnishment is any legal procedure in which some portion of a personrsquos earnings is required to be withheld by an employer for the payment of a debt

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

With this program your payments change as your income changes and will not be longer than 25 years This is the ideal plan if you are in partial financial hardship Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard plan

Temporarily allowing you to postpone or reduce your federal student loan payments Postponing or reducing your payments may help you avoid default and future garnishments

Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard

3 of 6 462018 945 AM

33

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 38 of 57 Page ID 1797

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

4 of 6 462018 945 AM

34Attachment A

Testimonials

Latest News

Why 2016 Will Be a Big Year For Student Loans

Top Student Loan Refinancing Questions of 2015

Oba mas latest student loan plan

Things You Should Know About Public Service Loan Forgiveness

Recent Posts

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 39 of 57 Page ID 1798

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

5 of 6 462018 945 AM

35

About Us

Contact Info

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 40 of 57 Page ID 1799

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

pay-grandchild-studen

Why 2016 Will Be a Big Year For Student Loans

December 30 2015

12511110_1112367518

Top Student Loan Refinancing Questions of 2015

December 30 2015

We stand by our consultation and quote We are so sure and confident about our services and offers that they are all 100 money back guarantee risk free ndash if we donrsquot do what we promise yoursquoll get your money back

(800) 555-1212 AidnestStudenLoansgmailcom 18100 Von Karman Ave Suite 850 Irvine CA 92612

Futero SAS copy 2015 | Aidnestcom

6 of 6 462018 945

Exhibit D 36Attachment A

AM

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 41 of 57 Page ID 1800

EXHIBIT E

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 42 of 57 Page ID 1801

AIDNEST Let us help you through this national crisis

Call one of our specialists today

Forbearance amp Deferment If you are still in school and struggling to make payments on your student loans You may qualify

for Forbearance amp Deferment

Garnishment Prevention Federal law requires that the Department of Education or guarantee agency notifies you before they

begin garnishing your wages

Loan Forgiveness If you are a teacher public service worker or an individual with total and permanent disability you

httpaidnestcom[442018 115239 AM]

37Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 43 of 57 Page ID 1802

AIDNEST Let us help you through this national crisis

may qualify for this program

Consolidating Your Loans Consolidating your loans to one new loan under one lender may lower your payments and make

your life a bit more manageable

Affordable Payments If you are looking to lower your monthly payments then Income Based Repayment Plans may be

the correct choice for you

Learn more about our services

LEARN MORE

httpaidnestcom[442018 115239 AM]

38Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 44 of 57 Page ID 1803

AIDNEST Let us help you through this national crisis

Loan Forgiveness Programs Income Based Payments Student Loan Rehabilitation

Student Loan Consolidation

You may be eligible for

Loan Forgiveness Programs

In some cases individuals with Federal Student Loans may qualify to have a portion of the amount

owed to be forgiven

Get in touch with our professional team to find out which loan forgiveness program you qualify for and

how you can get rid of your unpaid student loan

L EARN MORE

httpaidnestcom[442018 115239 AM]

39Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 45 of 57 Page ID 1804

AIDNEST Let us help you through this national crisis

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE

Meet your Budget One of our advisers will help you meet your payment goals by using your budget and timeline to

determine the best plan available

httpaidnestcom[442018 115239 AM]

40Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 46 of 57 Page ID 1805

AIDNEST Let us help you through this national crisis

Simple Process We understand that lowering your payments alone can be difficult Our intuitive platform allows us

to keep the entire process simple

Customer Satisfaction We are committed to providing you with outstanding service only We look forward to working

with you

100 money back guarantee No Hassle Money Back Policy

httpaidnestcom[442018 115239 AM]

41Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 47 of 57 Page ID 1806

AIDNEST Let us help you through this national crisis

Lower your loan payments by getting in touch with one of our professionals

We design a customized repayment plan that will allow you to make payments based on your

monthly income family size and spending Get rid of the hassle of extensive paperwork and get the

help you deserve

What we can help you achieve a lower payment or lower rate

httpaidnestcom[442018 115239 AM]

42Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 48 of 57 Page ID 1807

AIDNEST Let us help you through this national crisis

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcom[442018 115239 AM]

43Exhibit E

httpaidnestcomservices[442018 115322 AM]

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 49 of 57 Page ID 1808

Services | AIDNEST Let us help you through this national crisis

INCOME BASED PAYMENTS

If you are suffering from a financial hardship you may be eligible for an

Income Based Payment In this repayment program you would have a

payment based on your income and family size The payment could be as

low as $000 per month with forgiveness at the end of 20-25 years

44

Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 50 of 57 Page ID 1809

L E ARN MORE

LOAN FORGIVENESS

If you have Federal Student Loans you may qualify for any of the student

loan forgiveness programs that are available to borrowers You may be

eligible for principal reduction loan forgiveness or a complete loan

discharge depending on your individual circumstance

L EARN MORE

PRIVATE STUDENT LOAN CONSOLIDATION

Much like refinancing a mortgage generally the biggest benefit of private

student loan consolidationstudent loan refinancing is a lower interest rate

httpaidnestcomservices[442018 115322 AM]

45Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 51 of 57 Page ID 1810

L E ARN MORE

(something federal consolidations do not offer)

STUDENT LOAN REHABILITATION

You can renew eligibility for new loans and grants and eliminate the loan

default by ldquorehabilitatingrdquo a defaulted loan

httpaidnestcomservices[442018 115322 AM]

46Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 52 of 57 Page ID 1811

CHE CK E L E G I B I L I T Y

WAGE GARNISHMENT

A wage garnishment is any legal procedure in which some portion of a

personrsquos earnings is required to be withheld by an employer for the

payment of a debt

L EARN MORE

With our fast friendly and professional services wersquoll be glad to help you get your student loans

reduced forgiven or completely discharged To this end wersquoll assist you in consolidating all your

student loans so yoursquoll have only one lender and yoursquoll start making one monthly payment Our

professionals will walk you through the best and most flexible repayment options and if itrsquos also

necessary varied deferment options and rehabilitation programs

httpaidnestcomservices[442018 115322 AM]

47Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 53 of 57 Page ID 1812

Services | AIDNEST Let us help you through this national crisis

Our CRM System

Our CRM is one of the most advanced in the industry and most importantly itrsquos linked directly to

the Department of Education (DOE) This keeps your personal and most confidential information

safe Furthermore because our CRM system is linked to the DOE our approval is 100 Through

our CRM we will be doing continuous monitoring of our process without losing sight of your

immediate needs ensuring that your case has the proper handling and most efficient process

httpaidnestcomservices[442018 115322 AM]

48Exhibit E

n

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 54 of 57 Page ID 1813

Services | AIDNEST Let us help you through this national crisis

R ECENT POSTS

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

ABOUT US

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcomservices[442018 115322 AM]

49Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 55 of 57 Page ID 1814

EXHIBIT F

s -

bullmiddot - ~ t ~ower Your Student Loan Pay~e~ts oday -- Students Helping Students Save Money

INCOME BASED PAJIIIJITPAIS

I C(gttoUC1 u~

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 56 of 57 Page ID 1815

X + C (D Not secure wwwstudoracom 0

CALL US NOW (85S) 978-S599 middot 1nfostudoracom

HOME SERVICES ABOUT US FAQ CONTACT US BLOC PRIVACY

Offering obligation and commitment free loan relief solutions

STUDENT LOAN FORGIVENESS INCOME BASED PAYMENTS LOAN CONSOLIDATION

We11 help you get your loans reduced forgiven o r Make monthly pdyments based on your affordability Get multiple Federal Student Loans consolidated into

discharged one low monthly payment

Talk to our experts concerning your

student loans

Studora is a pnvatefy owned company that helps consumers like you identify

government programs that fit your financial s1tuat1on Our loan experts will assist you in selecting the appropriate programs that WOltk with your income family size and

desired monthly payment We then prepare the appropriate documents for your review and submission All this f o r one low easy payment

Testimonials

Thank you f o r getting back to me quickly Youve been fabulous Thank you for the confirmation and for your help today Pass

during this whole process Is there a place I can go online that I this on to your sup that you were very professional and very

can leave a comment for your manager Youve made this Robert helpful and brought a sense of relief for me Thank you very

process so easy and answered every question my husband and I much and have a great rest of your day Kudos to you and your

have had teammoneywell spenL

Exhibit F 50

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 57 of 57 Page ID 1816

Services we offer

Stud ora offers document preparation services for all loan forgiveness consolidation and relief services to people who are unable to manage their finances Our mam aim is to

offer complete peace of mind to indiVidual unable to pay their student loan debt

we otter the folloWing document preparation services with complete professional assistance

amFinancial Review ffl Budget Planning

Toe first step to creating a flexible loan repayment plan is financial review we also help create a personal finance plan to ensure that you are able to

Our professmnals will look into your finances and design a custom manage your monthly budget in the most effective way This plan will keep

repayment plan that is affordable and easy to manage your spending to the minimum alloWing you to save more money for loan

repayment

Permanent Disability Forgiveness r-trTeacher Loan Forgiveness (5 You can get rid of your Federal Student Loan if you are permanently disabled Good news for teachers who are under the weight of a massiVe loan You can

now get $17 forgiven on your student loans

Public Service Loan Forgiveness Custom Debt Relief Plans

Want assistance with debt relief Get in touch with our experts who will help If you are a public service agent you can get rid of your loan after 120 days of design a loan repayment and relief plan for you based on your monthly

income and affordability payments

THERE ARE NO OBLIGATIONS OR COMMITMENTS

want to save thousands of dollars Fill out our form and get relief from your student loan for a more

peaceful tomorrow

Your Name

BiHHHi

Exhibit F 51

Attachment A

Page 32: JOSHUA S. MILLARD, BRIAN M. WELKE, pro hac vice · for which it has no legitimate claim. Noel is a Wyoming limited liability company that reported in a public document that its principal

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 32 of 57 Page ID 1791

EXHIBIT C

Attachment A

~ 111 ~tampi 10 11 ~bull ia1111

Something awesome is coming soon We are buildin somethin ve cool Sta tuned and be at1ent Your atience will be well aid

~lbullrbullUiUffl We can help you reduce and simplify your payments

101 Loan For iveness

1~u 0 (middottmiddotbullmiddotmiddot1 1~=I -- _~

HZamp IMUliULlampRampatiEUWi nmiddot middot-il~ fr middot 8rbullbullrcrr-

_J l _ 1 _f _ur -~t~ u L liYu

~ Income Based Pa ents

bull ~ f I - - I - I - ri u ~u-=lf ~ JU

1-bullA ---rc iM1~~ -~-bullCiel rrcl

~- middot IY 2 i C middot middotJ ll1Jmiddot 0 _ middot_middotIr i

~ LdfiJIMifJ11JJMJllfFffi

middotE-ltecl l2bullJbull iequbullt t11cit t1lt2 CtpCr~middot1e- f

JJd r g-_iraE-1 agltr-middot- ntimiddot middot)middotou

tmiddot_rt- i ic l~1ri ~rbullmiddot middot111~ umiddot -_ d_t-c

fsectmet-Naibullfyen1~poundibllffifftmI

I f-nle Vnot Nune

I ampterYOllrEmall ]

1 ~~~~ 1

If -bull 13n ~Cbull t~middot rct1~j d- gtOY- - hO- irmiddot (bulldbull) plltmiddotmiddot- leemiddotmiddot JOu

1r1cbullmiddotn111f11ri ll1fbull fcrn to ~bull~I

Triin- GU

WAWMyenEIRitiRpoundWt 44 ZiAtillampampI

Exhibit C

Case 818-cv-01987-JLS

-KE

S

Docum

ent 50-1 F

iled 020519 P

age 33 of 57 P

age ID 1792

30

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 34 of 57 Page ID 1793

EXHIBIT D

Attachment A

bull bull bull bull bull bull bull

---

Type then hit enter to

bull bull bull bull bull bull bull

----

----

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 35 of 57 Page ID 1794

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

infoaidnestcom (800) 555-1212

HOME

ABOUT US

SERVICES

FAQ

BLOG

CONTACT

HOME ABOUT US SERVICES FAQ BLOG CONTACT

1 of 6 462018 945 AM

31

Student Loan Forgiveness Loan Consolidation Student Loan Forgiveness

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 36 of 57 Page ID 1795

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

If you have Federal Student Loans yoursquore in the right place to get those loans reduced forgiven or completely discharged through our student loan forgiveness programs

Get your multiple Federal Student Loans consolidated into one forget about increasing interests and pay month to month at the lowest possible cost

We understand if yoursquore going through some hardship and thatrsquos why with us yoursquoll be able to make monthly payments based on your affordability for as low as $000 depending on your situation

2 of 6 462018 945 AM

32

Knowledge Base

Defaulted Student Loans

Wage Garnishment

Student Loan Rehabilitation

Income Based Repayment Plan

Deferment and Forbearance

Pay As You Earn Repayment Plan

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE Call 561)424-6053 today to go over your options

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 37 of 57 Page ID 1796

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

Our knowledge base is designed to provide information regarding some of the critical topics those with student loans must be aware of to be able to make educated decisions regarding their future

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

A wage garnishment is any legal procedure in which some portion of a personrsquos earnings is required to be withheld by an employer for the payment of a debt

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

With this program your payments change as your income changes and will not be longer than 25 years This is the ideal plan if you are in partial financial hardship Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard plan

Temporarily allowing you to postpone or reduce your federal student loan payments Postponing or reducing your payments may help you avoid default and future garnishments

Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard

3 of 6 462018 945 AM

33

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 38 of 57 Page ID 1797

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

4 of 6 462018 945 AM

34Attachment A

Testimonials

Latest News

Why 2016 Will Be a Big Year For Student Loans

Top Student Loan Refinancing Questions of 2015

Oba mas latest student loan plan

Things You Should Know About Public Service Loan Forgiveness

Recent Posts

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 39 of 57 Page ID 1798

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

5 of 6 462018 945 AM

35

About Us

Contact Info

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 40 of 57 Page ID 1799

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

pay-grandchild-studen

Why 2016 Will Be a Big Year For Student Loans

December 30 2015

12511110_1112367518

Top Student Loan Refinancing Questions of 2015

December 30 2015

We stand by our consultation and quote We are so sure and confident about our services and offers that they are all 100 money back guarantee risk free ndash if we donrsquot do what we promise yoursquoll get your money back

(800) 555-1212 AidnestStudenLoansgmailcom 18100 Von Karman Ave Suite 850 Irvine CA 92612

Futero SAS copy 2015 | Aidnestcom

6 of 6 462018 945

Exhibit D 36Attachment A

AM

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 41 of 57 Page ID 1800

EXHIBIT E

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 42 of 57 Page ID 1801

AIDNEST Let us help you through this national crisis

Call one of our specialists today

Forbearance amp Deferment If you are still in school and struggling to make payments on your student loans You may qualify

for Forbearance amp Deferment

Garnishment Prevention Federal law requires that the Department of Education or guarantee agency notifies you before they

begin garnishing your wages

Loan Forgiveness If you are a teacher public service worker or an individual with total and permanent disability you

httpaidnestcom[442018 115239 AM]

37Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 43 of 57 Page ID 1802

AIDNEST Let us help you through this national crisis

may qualify for this program

Consolidating Your Loans Consolidating your loans to one new loan under one lender may lower your payments and make

your life a bit more manageable

Affordable Payments If you are looking to lower your monthly payments then Income Based Repayment Plans may be

the correct choice for you

Learn more about our services

LEARN MORE

httpaidnestcom[442018 115239 AM]

38Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 44 of 57 Page ID 1803

AIDNEST Let us help you through this national crisis

Loan Forgiveness Programs Income Based Payments Student Loan Rehabilitation

Student Loan Consolidation

You may be eligible for

Loan Forgiveness Programs

In some cases individuals with Federal Student Loans may qualify to have a portion of the amount

owed to be forgiven

Get in touch with our professional team to find out which loan forgiveness program you qualify for and

how you can get rid of your unpaid student loan

L EARN MORE

httpaidnestcom[442018 115239 AM]

39Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 45 of 57 Page ID 1804

AIDNEST Let us help you through this national crisis

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE

Meet your Budget One of our advisers will help you meet your payment goals by using your budget and timeline to

determine the best plan available

httpaidnestcom[442018 115239 AM]

40Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 46 of 57 Page ID 1805

AIDNEST Let us help you through this national crisis

Simple Process We understand that lowering your payments alone can be difficult Our intuitive platform allows us

to keep the entire process simple

Customer Satisfaction We are committed to providing you with outstanding service only We look forward to working

with you

100 money back guarantee No Hassle Money Back Policy

httpaidnestcom[442018 115239 AM]

41Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 47 of 57 Page ID 1806

AIDNEST Let us help you through this national crisis

Lower your loan payments by getting in touch with one of our professionals

We design a customized repayment plan that will allow you to make payments based on your

monthly income family size and spending Get rid of the hassle of extensive paperwork and get the

help you deserve

What we can help you achieve a lower payment or lower rate

httpaidnestcom[442018 115239 AM]

42Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 48 of 57 Page ID 1807

AIDNEST Let us help you through this national crisis

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcom[442018 115239 AM]

43Exhibit E

httpaidnestcomservices[442018 115322 AM]

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 49 of 57 Page ID 1808

Services | AIDNEST Let us help you through this national crisis

INCOME BASED PAYMENTS

If you are suffering from a financial hardship you may be eligible for an

Income Based Payment In this repayment program you would have a

payment based on your income and family size The payment could be as

low as $000 per month with forgiveness at the end of 20-25 years

44

Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 50 of 57 Page ID 1809

L E ARN MORE

LOAN FORGIVENESS

If you have Federal Student Loans you may qualify for any of the student

loan forgiveness programs that are available to borrowers You may be

eligible for principal reduction loan forgiveness or a complete loan

discharge depending on your individual circumstance

L EARN MORE

PRIVATE STUDENT LOAN CONSOLIDATION

Much like refinancing a mortgage generally the biggest benefit of private

student loan consolidationstudent loan refinancing is a lower interest rate

httpaidnestcomservices[442018 115322 AM]

45Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 51 of 57 Page ID 1810

L E ARN MORE

(something federal consolidations do not offer)

STUDENT LOAN REHABILITATION

You can renew eligibility for new loans and grants and eliminate the loan

default by ldquorehabilitatingrdquo a defaulted loan

httpaidnestcomservices[442018 115322 AM]

46Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 52 of 57 Page ID 1811

CHE CK E L E G I B I L I T Y

WAGE GARNISHMENT

A wage garnishment is any legal procedure in which some portion of a

personrsquos earnings is required to be withheld by an employer for the

payment of a debt

L EARN MORE

With our fast friendly and professional services wersquoll be glad to help you get your student loans

reduced forgiven or completely discharged To this end wersquoll assist you in consolidating all your

student loans so yoursquoll have only one lender and yoursquoll start making one monthly payment Our

professionals will walk you through the best and most flexible repayment options and if itrsquos also

necessary varied deferment options and rehabilitation programs

httpaidnestcomservices[442018 115322 AM]

47Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 53 of 57 Page ID 1812

Services | AIDNEST Let us help you through this national crisis

Our CRM System

Our CRM is one of the most advanced in the industry and most importantly itrsquos linked directly to

the Department of Education (DOE) This keeps your personal and most confidential information

safe Furthermore because our CRM system is linked to the DOE our approval is 100 Through

our CRM we will be doing continuous monitoring of our process without losing sight of your

immediate needs ensuring that your case has the proper handling and most efficient process

httpaidnestcomservices[442018 115322 AM]

48Exhibit E

n

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 54 of 57 Page ID 1813

Services | AIDNEST Let us help you through this national crisis

R ECENT POSTS

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

ABOUT US

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcomservices[442018 115322 AM]

49Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 55 of 57 Page ID 1814

EXHIBIT F

s -

bullmiddot - ~ t ~ower Your Student Loan Pay~e~ts oday -- Students Helping Students Save Money

INCOME BASED PAJIIIJITPAIS

I C(gttoUC1 u~

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 56 of 57 Page ID 1815

X + C (D Not secure wwwstudoracom 0

CALL US NOW (85S) 978-S599 middot 1nfostudoracom

HOME SERVICES ABOUT US FAQ CONTACT US BLOC PRIVACY

Offering obligation and commitment free loan relief solutions

STUDENT LOAN FORGIVENESS INCOME BASED PAYMENTS LOAN CONSOLIDATION

We11 help you get your loans reduced forgiven o r Make monthly pdyments based on your affordability Get multiple Federal Student Loans consolidated into

discharged one low monthly payment

Talk to our experts concerning your

student loans

Studora is a pnvatefy owned company that helps consumers like you identify

government programs that fit your financial s1tuat1on Our loan experts will assist you in selecting the appropriate programs that WOltk with your income family size and

desired monthly payment We then prepare the appropriate documents for your review and submission All this f o r one low easy payment

Testimonials

Thank you f o r getting back to me quickly Youve been fabulous Thank you for the confirmation and for your help today Pass

during this whole process Is there a place I can go online that I this on to your sup that you were very professional and very

can leave a comment for your manager Youve made this Robert helpful and brought a sense of relief for me Thank you very

process so easy and answered every question my husband and I much and have a great rest of your day Kudos to you and your

have had teammoneywell spenL

Exhibit F 50

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 57 of 57 Page ID 1816

Services we offer

Stud ora offers document preparation services for all loan forgiveness consolidation and relief services to people who are unable to manage their finances Our mam aim is to

offer complete peace of mind to indiVidual unable to pay their student loan debt

we otter the folloWing document preparation services with complete professional assistance

amFinancial Review ffl Budget Planning

Toe first step to creating a flexible loan repayment plan is financial review we also help create a personal finance plan to ensure that you are able to

Our professmnals will look into your finances and design a custom manage your monthly budget in the most effective way This plan will keep

repayment plan that is affordable and easy to manage your spending to the minimum alloWing you to save more money for loan

repayment

Permanent Disability Forgiveness r-trTeacher Loan Forgiveness (5 You can get rid of your Federal Student Loan if you are permanently disabled Good news for teachers who are under the weight of a massiVe loan You can

now get $17 forgiven on your student loans

Public Service Loan Forgiveness Custom Debt Relief Plans

Want assistance with debt relief Get in touch with our experts who will help If you are a public service agent you can get rid of your loan after 120 days of design a loan repayment and relief plan for you based on your monthly

income and affordability payments

THERE ARE NO OBLIGATIONS OR COMMITMENTS

want to save thousands of dollars Fill out our form and get relief from your student loan for a more

peaceful tomorrow

Your Name

BiHHHi

Exhibit F 51

Attachment A

Page 33: JOSHUA S. MILLARD, BRIAN M. WELKE, pro hac vice · for which it has no legitimate claim. Noel is a Wyoming limited liability company that reported in a public document that its principal

~ 111 ~tampi 10 11 ~bull ia1111

Something awesome is coming soon We are buildin somethin ve cool Sta tuned and be at1ent Your atience will be well aid

~lbullrbullUiUffl We can help you reduce and simplify your payments

101 Loan For iveness

1~u 0 (middottmiddotbullmiddotmiddot1 1~=I -- _~

HZamp IMUliULlampRampatiEUWi nmiddot middot-il~ fr middot 8rbullbullrcrr-

_J l _ 1 _f _ur -~t~ u L liYu

~ Income Based Pa ents

bull ~ f I - - I - I - ri u ~u-=lf ~ JU

1-bullA ---rc iM1~~ -~-bullCiel rrcl

~- middot IY 2 i C middot middotJ ll1Jmiddot 0 _ middot_middotIr i

~ LdfiJIMifJ11JJMJllfFffi

middotE-ltecl l2bullJbull iequbullt t11cit t1lt2 CtpCr~middot1e- f

JJd r g-_iraE-1 agltr-middot- ntimiddot middot)middotou

tmiddot_rt- i ic l~1ri ~rbullmiddot middot111~ umiddot -_ d_t-c

fsectmet-Naibullfyen1~poundibllffifftmI

I f-nle Vnot Nune

I ampterYOllrEmall ]

1 ~~~~ 1

If -bull 13n ~Cbull t~middot rct1~j d- gtOY- - hO- irmiddot (bulldbull) plltmiddotmiddot- leemiddotmiddot JOu

1r1cbullmiddotn111f11ri ll1fbull fcrn to ~bull~I

Triin- GU

WAWMyenEIRitiRpoundWt 44 ZiAtillampampI

Exhibit C

Case 818-cv-01987-JLS

-KE

S

Docum

ent 50-1 F

iled 020519 P

age 33 of 57 P

age ID 1792

30

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 34 of 57 Page ID 1793

EXHIBIT D

Attachment A

bull bull bull bull bull bull bull

---

Type then hit enter to

bull bull bull bull bull bull bull

----

----

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 35 of 57 Page ID 1794

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

infoaidnestcom (800) 555-1212

HOME

ABOUT US

SERVICES

FAQ

BLOG

CONTACT

HOME ABOUT US SERVICES FAQ BLOG CONTACT

1 of 6 462018 945 AM

31

Student Loan Forgiveness Loan Consolidation Student Loan Forgiveness

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 36 of 57 Page ID 1795

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

If you have Federal Student Loans yoursquore in the right place to get those loans reduced forgiven or completely discharged through our student loan forgiveness programs

Get your multiple Federal Student Loans consolidated into one forget about increasing interests and pay month to month at the lowest possible cost

We understand if yoursquore going through some hardship and thatrsquos why with us yoursquoll be able to make monthly payments based on your affordability for as low as $000 depending on your situation

2 of 6 462018 945 AM

32

Knowledge Base

Defaulted Student Loans

Wage Garnishment

Student Loan Rehabilitation

Income Based Repayment Plan

Deferment and Forbearance

Pay As You Earn Repayment Plan

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE Call 561)424-6053 today to go over your options

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 37 of 57 Page ID 1796

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

Our knowledge base is designed to provide information regarding some of the critical topics those with student loans must be aware of to be able to make educated decisions regarding their future

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

A wage garnishment is any legal procedure in which some portion of a personrsquos earnings is required to be withheld by an employer for the payment of a debt

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

With this program your payments change as your income changes and will not be longer than 25 years This is the ideal plan if you are in partial financial hardship Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard plan

Temporarily allowing you to postpone or reduce your federal student loan payments Postponing or reducing your payments may help you avoid default and future garnishments

Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard

3 of 6 462018 945 AM

33

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 38 of 57 Page ID 1797

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

4 of 6 462018 945 AM

34Attachment A

Testimonials

Latest News

Why 2016 Will Be a Big Year For Student Loans

Top Student Loan Refinancing Questions of 2015

Oba mas latest student loan plan

Things You Should Know About Public Service Loan Forgiveness

Recent Posts

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 39 of 57 Page ID 1798

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

5 of 6 462018 945 AM

35

About Us

Contact Info

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 40 of 57 Page ID 1799

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

pay-grandchild-studen

Why 2016 Will Be a Big Year For Student Loans

December 30 2015

12511110_1112367518

Top Student Loan Refinancing Questions of 2015

December 30 2015

We stand by our consultation and quote We are so sure and confident about our services and offers that they are all 100 money back guarantee risk free ndash if we donrsquot do what we promise yoursquoll get your money back

(800) 555-1212 AidnestStudenLoansgmailcom 18100 Von Karman Ave Suite 850 Irvine CA 92612

Futero SAS copy 2015 | Aidnestcom

6 of 6 462018 945

Exhibit D 36Attachment A

AM

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 41 of 57 Page ID 1800

EXHIBIT E

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 42 of 57 Page ID 1801

AIDNEST Let us help you through this national crisis

Call one of our specialists today

Forbearance amp Deferment If you are still in school and struggling to make payments on your student loans You may qualify

for Forbearance amp Deferment

Garnishment Prevention Federal law requires that the Department of Education or guarantee agency notifies you before they

begin garnishing your wages

Loan Forgiveness If you are a teacher public service worker or an individual with total and permanent disability you

httpaidnestcom[442018 115239 AM]

37Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 43 of 57 Page ID 1802

AIDNEST Let us help you through this national crisis

may qualify for this program

Consolidating Your Loans Consolidating your loans to one new loan under one lender may lower your payments and make

your life a bit more manageable

Affordable Payments If you are looking to lower your monthly payments then Income Based Repayment Plans may be

the correct choice for you

Learn more about our services

LEARN MORE

httpaidnestcom[442018 115239 AM]

38Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 44 of 57 Page ID 1803

AIDNEST Let us help you through this national crisis

Loan Forgiveness Programs Income Based Payments Student Loan Rehabilitation

Student Loan Consolidation

You may be eligible for

Loan Forgiveness Programs

In some cases individuals with Federal Student Loans may qualify to have a portion of the amount

owed to be forgiven

Get in touch with our professional team to find out which loan forgiveness program you qualify for and

how you can get rid of your unpaid student loan

L EARN MORE

httpaidnestcom[442018 115239 AM]

39Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 45 of 57 Page ID 1804

AIDNEST Let us help you through this national crisis

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE

Meet your Budget One of our advisers will help you meet your payment goals by using your budget and timeline to

determine the best plan available

httpaidnestcom[442018 115239 AM]

40Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 46 of 57 Page ID 1805

AIDNEST Let us help you through this national crisis

Simple Process We understand that lowering your payments alone can be difficult Our intuitive platform allows us

to keep the entire process simple

Customer Satisfaction We are committed to providing you with outstanding service only We look forward to working

with you

100 money back guarantee No Hassle Money Back Policy

httpaidnestcom[442018 115239 AM]

41Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 47 of 57 Page ID 1806

AIDNEST Let us help you through this national crisis

Lower your loan payments by getting in touch with one of our professionals

We design a customized repayment plan that will allow you to make payments based on your

monthly income family size and spending Get rid of the hassle of extensive paperwork and get the

help you deserve

What we can help you achieve a lower payment or lower rate

httpaidnestcom[442018 115239 AM]

42Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 48 of 57 Page ID 1807

AIDNEST Let us help you through this national crisis

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcom[442018 115239 AM]

43Exhibit E

httpaidnestcomservices[442018 115322 AM]

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 49 of 57 Page ID 1808

Services | AIDNEST Let us help you through this national crisis

INCOME BASED PAYMENTS

If you are suffering from a financial hardship you may be eligible for an

Income Based Payment In this repayment program you would have a

payment based on your income and family size The payment could be as

low as $000 per month with forgiveness at the end of 20-25 years

44

Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 50 of 57 Page ID 1809

L E ARN MORE

LOAN FORGIVENESS

If you have Federal Student Loans you may qualify for any of the student

loan forgiveness programs that are available to borrowers You may be

eligible for principal reduction loan forgiveness or a complete loan

discharge depending on your individual circumstance

L EARN MORE

PRIVATE STUDENT LOAN CONSOLIDATION

Much like refinancing a mortgage generally the biggest benefit of private

student loan consolidationstudent loan refinancing is a lower interest rate

httpaidnestcomservices[442018 115322 AM]

45Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 51 of 57 Page ID 1810

L E ARN MORE

(something federal consolidations do not offer)

STUDENT LOAN REHABILITATION

You can renew eligibility for new loans and grants and eliminate the loan

default by ldquorehabilitatingrdquo a defaulted loan

httpaidnestcomservices[442018 115322 AM]

46Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 52 of 57 Page ID 1811

CHE CK E L E G I B I L I T Y

WAGE GARNISHMENT

A wage garnishment is any legal procedure in which some portion of a

personrsquos earnings is required to be withheld by an employer for the

payment of a debt

L EARN MORE

With our fast friendly and professional services wersquoll be glad to help you get your student loans

reduced forgiven or completely discharged To this end wersquoll assist you in consolidating all your

student loans so yoursquoll have only one lender and yoursquoll start making one monthly payment Our

professionals will walk you through the best and most flexible repayment options and if itrsquos also

necessary varied deferment options and rehabilitation programs

httpaidnestcomservices[442018 115322 AM]

47Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 53 of 57 Page ID 1812

Services | AIDNEST Let us help you through this national crisis

Our CRM System

Our CRM is one of the most advanced in the industry and most importantly itrsquos linked directly to

the Department of Education (DOE) This keeps your personal and most confidential information

safe Furthermore because our CRM system is linked to the DOE our approval is 100 Through

our CRM we will be doing continuous monitoring of our process without losing sight of your

immediate needs ensuring that your case has the proper handling and most efficient process

httpaidnestcomservices[442018 115322 AM]

48Exhibit E

n

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 54 of 57 Page ID 1813

Services | AIDNEST Let us help you through this national crisis

R ECENT POSTS

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

ABOUT US

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcomservices[442018 115322 AM]

49Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 55 of 57 Page ID 1814

EXHIBIT F

s -

bullmiddot - ~ t ~ower Your Student Loan Pay~e~ts oday -- Students Helping Students Save Money

INCOME BASED PAJIIIJITPAIS

I C(gttoUC1 u~

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 56 of 57 Page ID 1815

X + C (D Not secure wwwstudoracom 0

CALL US NOW (85S) 978-S599 middot 1nfostudoracom

HOME SERVICES ABOUT US FAQ CONTACT US BLOC PRIVACY

Offering obligation and commitment free loan relief solutions

STUDENT LOAN FORGIVENESS INCOME BASED PAYMENTS LOAN CONSOLIDATION

We11 help you get your loans reduced forgiven o r Make monthly pdyments based on your affordability Get multiple Federal Student Loans consolidated into

discharged one low monthly payment

Talk to our experts concerning your

student loans

Studora is a pnvatefy owned company that helps consumers like you identify

government programs that fit your financial s1tuat1on Our loan experts will assist you in selecting the appropriate programs that WOltk with your income family size and

desired monthly payment We then prepare the appropriate documents for your review and submission All this f o r one low easy payment

Testimonials

Thank you f o r getting back to me quickly Youve been fabulous Thank you for the confirmation and for your help today Pass

during this whole process Is there a place I can go online that I this on to your sup that you were very professional and very

can leave a comment for your manager Youve made this Robert helpful and brought a sense of relief for me Thank you very

process so easy and answered every question my husband and I much and have a great rest of your day Kudos to you and your

have had teammoneywell spenL

Exhibit F 50

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 57 of 57 Page ID 1816

Services we offer

Stud ora offers document preparation services for all loan forgiveness consolidation and relief services to people who are unable to manage their finances Our mam aim is to

offer complete peace of mind to indiVidual unable to pay their student loan debt

we otter the folloWing document preparation services with complete professional assistance

amFinancial Review ffl Budget Planning

Toe first step to creating a flexible loan repayment plan is financial review we also help create a personal finance plan to ensure that you are able to

Our professmnals will look into your finances and design a custom manage your monthly budget in the most effective way This plan will keep

repayment plan that is affordable and easy to manage your spending to the minimum alloWing you to save more money for loan

repayment

Permanent Disability Forgiveness r-trTeacher Loan Forgiveness (5 You can get rid of your Federal Student Loan if you are permanently disabled Good news for teachers who are under the weight of a massiVe loan You can

now get $17 forgiven on your student loans

Public Service Loan Forgiveness Custom Debt Relief Plans

Want assistance with debt relief Get in touch with our experts who will help If you are a public service agent you can get rid of your loan after 120 days of design a loan repayment and relief plan for you based on your monthly

income and affordability payments

THERE ARE NO OBLIGATIONS OR COMMITMENTS

want to save thousands of dollars Fill out our form and get relief from your student loan for a more

peaceful tomorrow

Your Name

BiHHHi

Exhibit F 51

Attachment A

Page 34: JOSHUA S. MILLARD, BRIAN M. WELKE, pro hac vice · for which it has no legitimate claim. Noel is a Wyoming limited liability company that reported in a public document that its principal

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 34 of 57 Page ID 1793

EXHIBIT D

Attachment A

bull bull bull bull bull bull bull

---

Type then hit enter to

bull bull bull bull bull bull bull

----

----

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 35 of 57 Page ID 1794

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

infoaidnestcom (800) 555-1212

HOME

ABOUT US

SERVICES

FAQ

BLOG

CONTACT

HOME ABOUT US SERVICES FAQ BLOG CONTACT

1 of 6 462018 945 AM

31

Student Loan Forgiveness Loan Consolidation Student Loan Forgiveness

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 36 of 57 Page ID 1795

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

If you have Federal Student Loans yoursquore in the right place to get those loans reduced forgiven or completely discharged through our student loan forgiveness programs

Get your multiple Federal Student Loans consolidated into one forget about increasing interests and pay month to month at the lowest possible cost

We understand if yoursquore going through some hardship and thatrsquos why with us yoursquoll be able to make monthly payments based on your affordability for as low as $000 depending on your situation

2 of 6 462018 945 AM

32

Knowledge Base

Defaulted Student Loans

Wage Garnishment

Student Loan Rehabilitation

Income Based Repayment Plan

Deferment and Forbearance

Pay As You Earn Repayment Plan

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE Call 561)424-6053 today to go over your options

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 37 of 57 Page ID 1796

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

Our knowledge base is designed to provide information regarding some of the critical topics those with student loans must be aware of to be able to make educated decisions regarding their future

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

A wage garnishment is any legal procedure in which some portion of a personrsquos earnings is required to be withheld by an employer for the payment of a debt

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

With this program your payments change as your income changes and will not be longer than 25 years This is the ideal plan if you are in partial financial hardship Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard plan

Temporarily allowing you to postpone or reduce your federal student loan payments Postponing or reducing your payments may help you avoid default and future garnishments

Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard

3 of 6 462018 945 AM

33

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 38 of 57 Page ID 1797

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

4 of 6 462018 945 AM

34Attachment A

Testimonials

Latest News

Why 2016 Will Be a Big Year For Student Loans

Top Student Loan Refinancing Questions of 2015

Oba mas latest student loan plan

Things You Should Know About Public Service Loan Forgiveness

Recent Posts

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 39 of 57 Page ID 1798

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

5 of 6 462018 945 AM

35

About Us

Contact Info

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 40 of 57 Page ID 1799

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

pay-grandchild-studen

Why 2016 Will Be a Big Year For Student Loans

December 30 2015

12511110_1112367518

Top Student Loan Refinancing Questions of 2015

December 30 2015

We stand by our consultation and quote We are so sure and confident about our services and offers that they are all 100 money back guarantee risk free ndash if we donrsquot do what we promise yoursquoll get your money back

(800) 555-1212 AidnestStudenLoansgmailcom 18100 Von Karman Ave Suite 850 Irvine CA 92612

Futero SAS copy 2015 | Aidnestcom

6 of 6 462018 945

Exhibit D 36Attachment A

AM

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 41 of 57 Page ID 1800

EXHIBIT E

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 42 of 57 Page ID 1801

AIDNEST Let us help you through this national crisis

Call one of our specialists today

Forbearance amp Deferment If you are still in school and struggling to make payments on your student loans You may qualify

for Forbearance amp Deferment

Garnishment Prevention Federal law requires that the Department of Education or guarantee agency notifies you before they

begin garnishing your wages

Loan Forgiveness If you are a teacher public service worker or an individual with total and permanent disability you

httpaidnestcom[442018 115239 AM]

37Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 43 of 57 Page ID 1802

AIDNEST Let us help you through this national crisis

may qualify for this program

Consolidating Your Loans Consolidating your loans to one new loan under one lender may lower your payments and make

your life a bit more manageable

Affordable Payments If you are looking to lower your monthly payments then Income Based Repayment Plans may be

the correct choice for you

Learn more about our services

LEARN MORE

httpaidnestcom[442018 115239 AM]

38Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 44 of 57 Page ID 1803

AIDNEST Let us help you through this national crisis

Loan Forgiveness Programs Income Based Payments Student Loan Rehabilitation

Student Loan Consolidation

You may be eligible for

Loan Forgiveness Programs

In some cases individuals with Federal Student Loans may qualify to have a portion of the amount

owed to be forgiven

Get in touch with our professional team to find out which loan forgiveness program you qualify for and

how you can get rid of your unpaid student loan

L EARN MORE

httpaidnestcom[442018 115239 AM]

39Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 45 of 57 Page ID 1804

AIDNEST Let us help you through this national crisis

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE

Meet your Budget One of our advisers will help you meet your payment goals by using your budget and timeline to

determine the best plan available

httpaidnestcom[442018 115239 AM]

40Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 46 of 57 Page ID 1805

AIDNEST Let us help you through this national crisis

Simple Process We understand that lowering your payments alone can be difficult Our intuitive platform allows us

to keep the entire process simple

Customer Satisfaction We are committed to providing you with outstanding service only We look forward to working

with you

100 money back guarantee No Hassle Money Back Policy

httpaidnestcom[442018 115239 AM]

41Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 47 of 57 Page ID 1806

AIDNEST Let us help you through this national crisis

Lower your loan payments by getting in touch with one of our professionals

We design a customized repayment plan that will allow you to make payments based on your

monthly income family size and spending Get rid of the hassle of extensive paperwork and get the

help you deserve

What we can help you achieve a lower payment or lower rate

httpaidnestcom[442018 115239 AM]

42Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 48 of 57 Page ID 1807

AIDNEST Let us help you through this national crisis

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcom[442018 115239 AM]

43Exhibit E

httpaidnestcomservices[442018 115322 AM]

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 49 of 57 Page ID 1808

Services | AIDNEST Let us help you through this national crisis

INCOME BASED PAYMENTS

If you are suffering from a financial hardship you may be eligible for an

Income Based Payment In this repayment program you would have a

payment based on your income and family size The payment could be as

low as $000 per month with forgiveness at the end of 20-25 years

44

Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 50 of 57 Page ID 1809

L E ARN MORE

LOAN FORGIVENESS

If you have Federal Student Loans you may qualify for any of the student

loan forgiveness programs that are available to borrowers You may be

eligible for principal reduction loan forgiveness or a complete loan

discharge depending on your individual circumstance

L EARN MORE

PRIVATE STUDENT LOAN CONSOLIDATION

Much like refinancing a mortgage generally the biggest benefit of private

student loan consolidationstudent loan refinancing is a lower interest rate

httpaidnestcomservices[442018 115322 AM]

45Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 51 of 57 Page ID 1810

L E ARN MORE

(something federal consolidations do not offer)

STUDENT LOAN REHABILITATION

You can renew eligibility for new loans and grants and eliminate the loan

default by ldquorehabilitatingrdquo a defaulted loan

httpaidnestcomservices[442018 115322 AM]

46Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 52 of 57 Page ID 1811

CHE CK E L E G I B I L I T Y

WAGE GARNISHMENT

A wage garnishment is any legal procedure in which some portion of a

personrsquos earnings is required to be withheld by an employer for the

payment of a debt

L EARN MORE

With our fast friendly and professional services wersquoll be glad to help you get your student loans

reduced forgiven or completely discharged To this end wersquoll assist you in consolidating all your

student loans so yoursquoll have only one lender and yoursquoll start making one monthly payment Our

professionals will walk you through the best and most flexible repayment options and if itrsquos also

necessary varied deferment options and rehabilitation programs

httpaidnestcomservices[442018 115322 AM]

47Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 53 of 57 Page ID 1812

Services | AIDNEST Let us help you through this national crisis

Our CRM System

Our CRM is one of the most advanced in the industry and most importantly itrsquos linked directly to

the Department of Education (DOE) This keeps your personal and most confidential information

safe Furthermore because our CRM system is linked to the DOE our approval is 100 Through

our CRM we will be doing continuous monitoring of our process without losing sight of your

immediate needs ensuring that your case has the proper handling and most efficient process

httpaidnestcomservices[442018 115322 AM]

48Exhibit E

n

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 54 of 57 Page ID 1813

Services | AIDNEST Let us help you through this national crisis

R ECENT POSTS

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

ABOUT US

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcomservices[442018 115322 AM]

49Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 55 of 57 Page ID 1814

EXHIBIT F

s -

bullmiddot - ~ t ~ower Your Student Loan Pay~e~ts oday -- Students Helping Students Save Money

INCOME BASED PAJIIIJITPAIS

I C(gttoUC1 u~

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 56 of 57 Page ID 1815

X + C (D Not secure wwwstudoracom 0

CALL US NOW (85S) 978-S599 middot 1nfostudoracom

HOME SERVICES ABOUT US FAQ CONTACT US BLOC PRIVACY

Offering obligation and commitment free loan relief solutions

STUDENT LOAN FORGIVENESS INCOME BASED PAYMENTS LOAN CONSOLIDATION

We11 help you get your loans reduced forgiven o r Make monthly pdyments based on your affordability Get multiple Federal Student Loans consolidated into

discharged one low monthly payment

Talk to our experts concerning your

student loans

Studora is a pnvatefy owned company that helps consumers like you identify

government programs that fit your financial s1tuat1on Our loan experts will assist you in selecting the appropriate programs that WOltk with your income family size and

desired monthly payment We then prepare the appropriate documents for your review and submission All this f o r one low easy payment

Testimonials

Thank you f o r getting back to me quickly Youve been fabulous Thank you for the confirmation and for your help today Pass

during this whole process Is there a place I can go online that I this on to your sup that you were very professional and very

can leave a comment for your manager Youve made this Robert helpful and brought a sense of relief for me Thank you very

process so easy and answered every question my husband and I much and have a great rest of your day Kudos to you and your

have had teammoneywell spenL

Exhibit F 50

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 57 of 57 Page ID 1816

Services we offer

Stud ora offers document preparation services for all loan forgiveness consolidation and relief services to people who are unable to manage their finances Our mam aim is to

offer complete peace of mind to indiVidual unable to pay their student loan debt

we otter the folloWing document preparation services with complete professional assistance

amFinancial Review ffl Budget Planning

Toe first step to creating a flexible loan repayment plan is financial review we also help create a personal finance plan to ensure that you are able to

Our professmnals will look into your finances and design a custom manage your monthly budget in the most effective way This plan will keep

repayment plan that is affordable and easy to manage your spending to the minimum alloWing you to save more money for loan

repayment

Permanent Disability Forgiveness r-trTeacher Loan Forgiveness (5 You can get rid of your Federal Student Loan if you are permanently disabled Good news for teachers who are under the weight of a massiVe loan You can

now get $17 forgiven on your student loans

Public Service Loan Forgiveness Custom Debt Relief Plans

Want assistance with debt relief Get in touch with our experts who will help If you are a public service agent you can get rid of your loan after 120 days of design a loan repayment and relief plan for you based on your monthly

income and affordability payments

THERE ARE NO OBLIGATIONS OR COMMITMENTS

want to save thousands of dollars Fill out our form and get relief from your student loan for a more

peaceful tomorrow

Your Name

BiHHHi

Exhibit F 51

Attachment A

Page 35: JOSHUA S. MILLARD, BRIAN M. WELKE, pro hac vice · for which it has no legitimate claim. Noel is a Wyoming limited liability company that reported in a public document that its principal

bull bull bull bull bull bull bull

---

Type then hit enter to

bull bull bull bull bull bull bull

----

----

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 35 of 57 Page ID 1794

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

infoaidnestcom (800) 555-1212

HOME

ABOUT US

SERVICES

FAQ

BLOG

CONTACT

HOME ABOUT US SERVICES FAQ BLOG CONTACT

1 of 6 462018 945 AM

31

Student Loan Forgiveness Loan Consolidation Student Loan Forgiveness

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 36 of 57 Page ID 1795

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

If you have Federal Student Loans yoursquore in the right place to get those loans reduced forgiven or completely discharged through our student loan forgiveness programs

Get your multiple Federal Student Loans consolidated into one forget about increasing interests and pay month to month at the lowest possible cost

We understand if yoursquore going through some hardship and thatrsquos why with us yoursquoll be able to make monthly payments based on your affordability for as low as $000 depending on your situation

2 of 6 462018 945 AM

32

Knowledge Base

Defaulted Student Loans

Wage Garnishment

Student Loan Rehabilitation

Income Based Repayment Plan

Deferment and Forbearance

Pay As You Earn Repayment Plan

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE Call 561)424-6053 today to go over your options

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 37 of 57 Page ID 1796

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

Our knowledge base is designed to provide information regarding some of the critical topics those with student loans must be aware of to be able to make educated decisions regarding their future

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

A wage garnishment is any legal procedure in which some portion of a personrsquos earnings is required to be withheld by an employer for the payment of a debt

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

With this program your payments change as your income changes and will not be longer than 25 years This is the ideal plan if you are in partial financial hardship Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard plan

Temporarily allowing you to postpone or reduce your federal student loan payments Postponing or reducing your payments may help you avoid default and future garnishments

Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard

3 of 6 462018 945 AM

33

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 38 of 57 Page ID 1797

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

4 of 6 462018 945 AM

34Attachment A

Testimonials

Latest News

Why 2016 Will Be a Big Year For Student Loans

Top Student Loan Refinancing Questions of 2015

Oba mas latest student loan plan

Things You Should Know About Public Service Loan Forgiveness

Recent Posts

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 39 of 57 Page ID 1798

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

5 of 6 462018 945 AM

35

About Us

Contact Info

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 40 of 57 Page ID 1799

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

pay-grandchild-studen

Why 2016 Will Be a Big Year For Student Loans

December 30 2015

12511110_1112367518

Top Student Loan Refinancing Questions of 2015

December 30 2015

We stand by our consultation and quote We are so sure and confident about our services and offers that they are all 100 money back guarantee risk free ndash if we donrsquot do what we promise yoursquoll get your money back

(800) 555-1212 AidnestStudenLoansgmailcom 18100 Von Karman Ave Suite 850 Irvine CA 92612

Futero SAS copy 2015 | Aidnestcom

6 of 6 462018 945

Exhibit D 36Attachment A

AM

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 41 of 57 Page ID 1800

EXHIBIT E

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 42 of 57 Page ID 1801

AIDNEST Let us help you through this national crisis

Call one of our specialists today

Forbearance amp Deferment If you are still in school and struggling to make payments on your student loans You may qualify

for Forbearance amp Deferment

Garnishment Prevention Federal law requires that the Department of Education or guarantee agency notifies you before they

begin garnishing your wages

Loan Forgiveness If you are a teacher public service worker or an individual with total and permanent disability you

httpaidnestcom[442018 115239 AM]

37Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 43 of 57 Page ID 1802

AIDNEST Let us help you through this national crisis

may qualify for this program

Consolidating Your Loans Consolidating your loans to one new loan under one lender may lower your payments and make

your life a bit more manageable

Affordable Payments If you are looking to lower your monthly payments then Income Based Repayment Plans may be

the correct choice for you

Learn more about our services

LEARN MORE

httpaidnestcom[442018 115239 AM]

38Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 44 of 57 Page ID 1803

AIDNEST Let us help you through this national crisis

Loan Forgiveness Programs Income Based Payments Student Loan Rehabilitation

Student Loan Consolidation

You may be eligible for

Loan Forgiveness Programs

In some cases individuals with Federal Student Loans may qualify to have a portion of the amount

owed to be forgiven

Get in touch with our professional team to find out which loan forgiveness program you qualify for and

how you can get rid of your unpaid student loan

L EARN MORE

httpaidnestcom[442018 115239 AM]

39Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 45 of 57 Page ID 1804

AIDNEST Let us help you through this national crisis

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE

Meet your Budget One of our advisers will help you meet your payment goals by using your budget and timeline to

determine the best plan available

httpaidnestcom[442018 115239 AM]

40Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 46 of 57 Page ID 1805

AIDNEST Let us help you through this national crisis

Simple Process We understand that lowering your payments alone can be difficult Our intuitive platform allows us

to keep the entire process simple

Customer Satisfaction We are committed to providing you with outstanding service only We look forward to working

with you

100 money back guarantee No Hassle Money Back Policy

httpaidnestcom[442018 115239 AM]

41Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 47 of 57 Page ID 1806

AIDNEST Let us help you through this national crisis

Lower your loan payments by getting in touch with one of our professionals

We design a customized repayment plan that will allow you to make payments based on your

monthly income family size and spending Get rid of the hassle of extensive paperwork and get the

help you deserve

What we can help you achieve a lower payment or lower rate

httpaidnestcom[442018 115239 AM]

42Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 48 of 57 Page ID 1807

AIDNEST Let us help you through this national crisis

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcom[442018 115239 AM]

43Exhibit E

httpaidnestcomservices[442018 115322 AM]

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 49 of 57 Page ID 1808

Services | AIDNEST Let us help you through this national crisis

INCOME BASED PAYMENTS

If you are suffering from a financial hardship you may be eligible for an

Income Based Payment In this repayment program you would have a

payment based on your income and family size The payment could be as

low as $000 per month with forgiveness at the end of 20-25 years

44

Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 50 of 57 Page ID 1809

L E ARN MORE

LOAN FORGIVENESS

If you have Federal Student Loans you may qualify for any of the student

loan forgiveness programs that are available to borrowers You may be

eligible for principal reduction loan forgiveness or a complete loan

discharge depending on your individual circumstance

L EARN MORE

PRIVATE STUDENT LOAN CONSOLIDATION

Much like refinancing a mortgage generally the biggest benefit of private

student loan consolidationstudent loan refinancing is a lower interest rate

httpaidnestcomservices[442018 115322 AM]

45Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 51 of 57 Page ID 1810

L E ARN MORE

(something federal consolidations do not offer)

STUDENT LOAN REHABILITATION

You can renew eligibility for new loans and grants and eliminate the loan

default by ldquorehabilitatingrdquo a defaulted loan

httpaidnestcomservices[442018 115322 AM]

46Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 52 of 57 Page ID 1811

CHE CK E L E G I B I L I T Y

WAGE GARNISHMENT

A wage garnishment is any legal procedure in which some portion of a

personrsquos earnings is required to be withheld by an employer for the

payment of a debt

L EARN MORE

With our fast friendly and professional services wersquoll be glad to help you get your student loans

reduced forgiven or completely discharged To this end wersquoll assist you in consolidating all your

student loans so yoursquoll have only one lender and yoursquoll start making one monthly payment Our

professionals will walk you through the best and most flexible repayment options and if itrsquos also

necessary varied deferment options and rehabilitation programs

httpaidnestcomservices[442018 115322 AM]

47Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 53 of 57 Page ID 1812

Services | AIDNEST Let us help you through this national crisis

Our CRM System

Our CRM is one of the most advanced in the industry and most importantly itrsquos linked directly to

the Department of Education (DOE) This keeps your personal and most confidential information

safe Furthermore because our CRM system is linked to the DOE our approval is 100 Through

our CRM we will be doing continuous monitoring of our process without losing sight of your

immediate needs ensuring that your case has the proper handling and most efficient process

httpaidnestcomservices[442018 115322 AM]

48Exhibit E

n

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 54 of 57 Page ID 1813

Services | AIDNEST Let us help you through this national crisis

R ECENT POSTS

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

ABOUT US

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcomservices[442018 115322 AM]

49Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 55 of 57 Page ID 1814

EXHIBIT F

s -

bullmiddot - ~ t ~ower Your Student Loan Pay~e~ts oday -- Students Helping Students Save Money

INCOME BASED PAJIIIJITPAIS

I C(gttoUC1 u~

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 56 of 57 Page ID 1815

X + C (D Not secure wwwstudoracom 0

CALL US NOW (85S) 978-S599 middot 1nfostudoracom

HOME SERVICES ABOUT US FAQ CONTACT US BLOC PRIVACY

Offering obligation and commitment free loan relief solutions

STUDENT LOAN FORGIVENESS INCOME BASED PAYMENTS LOAN CONSOLIDATION

We11 help you get your loans reduced forgiven o r Make monthly pdyments based on your affordability Get multiple Federal Student Loans consolidated into

discharged one low monthly payment

Talk to our experts concerning your

student loans

Studora is a pnvatefy owned company that helps consumers like you identify

government programs that fit your financial s1tuat1on Our loan experts will assist you in selecting the appropriate programs that WOltk with your income family size and

desired monthly payment We then prepare the appropriate documents for your review and submission All this f o r one low easy payment

Testimonials

Thank you f o r getting back to me quickly Youve been fabulous Thank you for the confirmation and for your help today Pass

during this whole process Is there a place I can go online that I this on to your sup that you were very professional and very

can leave a comment for your manager Youve made this Robert helpful and brought a sense of relief for me Thank you very

process so easy and answered every question my husband and I much and have a great rest of your day Kudos to you and your

have had teammoneywell spenL

Exhibit F 50

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 57 of 57 Page ID 1816

Services we offer

Stud ora offers document preparation services for all loan forgiveness consolidation and relief services to people who are unable to manage their finances Our mam aim is to

offer complete peace of mind to indiVidual unable to pay their student loan debt

we otter the folloWing document preparation services with complete professional assistance

amFinancial Review ffl Budget Planning

Toe first step to creating a flexible loan repayment plan is financial review we also help create a personal finance plan to ensure that you are able to

Our professmnals will look into your finances and design a custom manage your monthly budget in the most effective way This plan will keep

repayment plan that is affordable and easy to manage your spending to the minimum alloWing you to save more money for loan

repayment

Permanent Disability Forgiveness r-trTeacher Loan Forgiveness (5 You can get rid of your Federal Student Loan if you are permanently disabled Good news for teachers who are under the weight of a massiVe loan You can

now get $17 forgiven on your student loans

Public Service Loan Forgiveness Custom Debt Relief Plans

Want assistance with debt relief Get in touch with our experts who will help If you are a public service agent you can get rid of your loan after 120 days of design a loan repayment and relief plan for you based on your monthly

income and affordability payments

THERE ARE NO OBLIGATIONS OR COMMITMENTS

want to save thousands of dollars Fill out our form and get relief from your student loan for a more

peaceful tomorrow

Your Name

BiHHHi

Exhibit F 51

Attachment A

Page 36: JOSHUA S. MILLARD, BRIAN M. WELKE, pro hac vice · for which it has no legitimate claim. Noel is a Wyoming limited liability company that reported in a public document that its principal

Student Loan Forgiveness Loan Consolidation Student Loan Forgiveness

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 36 of 57 Page ID 1795

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

If you have Federal Student Loans yoursquore in the right place to get those loans reduced forgiven or completely discharged through our student loan forgiveness programs

Get your multiple Federal Student Loans consolidated into one forget about increasing interests and pay month to month at the lowest possible cost

We understand if yoursquore going through some hardship and thatrsquos why with us yoursquoll be able to make monthly payments based on your affordability for as low as $000 depending on your situation

2 of 6 462018 945 AM

32

Knowledge Base

Defaulted Student Loans

Wage Garnishment

Student Loan Rehabilitation

Income Based Repayment Plan

Deferment and Forbearance

Pay As You Earn Repayment Plan

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE Call 561)424-6053 today to go over your options

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 37 of 57 Page ID 1796

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

Our knowledge base is designed to provide information regarding some of the critical topics those with student loans must be aware of to be able to make educated decisions regarding their future

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

A wage garnishment is any legal procedure in which some portion of a personrsquos earnings is required to be withheld by an employer for the payment of a debt

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

With this program your payments change as your income changes and will not be longer than 25 years This is the ideal plan if you are in partial financial hardship Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard plan

Temporarily allowing you to postpone or reduce your federal student loan payments Postponing or reducing your payments may help you avoid default and future garnishments

Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard

3 of 6 462018 945 AM

33

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 38 of 57 Page ID 1797

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

4 of 6 462018 945 AM

34Attachment A

Testimonials

Latest News

Why 2016 Will Be a Big Year For Student Loans

Top Student Loan Refinancing Questions of 2015

Oba mas latest student loan plan

Things You Should Know About Public Service Loan Forgiveness

Recent Posts

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 39 of 57 Page ID 1798

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

5 of 6 462018 945 AM

35

About Us

Contact Info

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 40 of 57 Page ID 1799

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

pay-grandchild-studen

Why 2016 Will Be a Big Year For Student Loans

December 30 2015

12511110_1112367518

Top Student Loan Refinancing Questions of 2015

December 30 2015

We stand by our consultation and quote We are so sure and confident about our services and offers that they are all 100 money back guarantee risk free ndash if we donrsquot do what we promise yoursquoll get your money back

(800) 555-1212 AidnestStudenLoansgmailcom 18100 Von Karman Ave Suite 850 Irvine CA 92612

Futero SAS copy 2015 | Aidnestcom

6 of 6 462018 945

Exhibit D 36Attachment A

AM

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 41 of 57 Page ID 1800

EXHIBIT E

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 42 of 57 Page ID 1801

AIDNEST Let us help you through this national crisis

Call one of our specialists today

Forbearance amp Deferment If you are still in school and struggling to make payments on your student loans You may qualify

for Forbearance amp Deferment

Garnishment Prevention Federal law requires that the Department of Education or guarantee agency notifies you before they

begin garnishing your wages

Loan Forgiveness If you are a teacher public service worker or an individual with total and permanent disability you

httpaidnestcom[442018 115239 AM]

37Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 43 of 57 Page ID 1802

AIDNEST Let us help you through this national crisis

may qualify for this program

Consolidating Your Loans Consolidating your loans to one new loan under one lender may lower your payments and make

your life a bit more manageable

Affordable Payments If you are looking to lower your monthly payments then Income Based Repayment Plans may be

the correct choice for you

Learn more about our services

LEARN MORE

httpaidnestcom[442018 115239 AM]

38Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 44 of 57 Page ID 1803

AIDNEST Let us help you through this national crisis

Loan Forgiveness Programs Income Based Payments Student Loan Rehabilitation

Student Loan Consolidation

You may be eligible for

Loan Forgiveness Programs

In some cases individuals with Federal Student Loans may qualify to have a portion of the amount

owed to be forgiven

Get in touch with our professional team to find out which loan forgiveness program you qualify for and

how you can get rid of your unpaid student loan

L EARN MORE

httpaidnestcom[442018 115239 AM]

39Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 45 of 57 Page ID 1804

AIDNEST Let us help you through this national crisis

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE

Meet your Budget One of our advisers will help you meet your payment goals by using your budget and timeline to

determine the best plan available

httpaidnestcom[442018 115239 AM]

40Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 46 of 57 Page ID 1805

AIDNEST Let us help you through this national crisis

Simple Process We understand that lowering your payments alone can be difficult Our intuitive platform allows us

to keep the entire process simple

Customer Satisfaction We are committed to providing you with outstanding service only We look forward to working

with you

100 money back guarantee No Hassle Money Back Policy

httpaidnestcom[442018 115239 AM]

41Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 47 of 57 Page ID 1806

AIDNEST Let us help you through this national crisis

Lower your loan payments by getting in touch with one of our professionals

We design a customized repayment plan that will allow you to make payments based on your

monthly income family size and spending Get rid of the hassle of extensive paperwork and get the

help you deserve

What we can help you achieve a lower payment or lower rate

httpaidnestcom[442018 115239 AM]

42Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 48 of 57 Page ID 1807

AIDNEST Let us help you through this national crisis

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcom[442018 115239 AM]

43Exhibit E

httpaidnestcomservices[442018 115322 AM]

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 49 of 57 Page ID 1808

Services | AIDNEST Let us help you through this national crisis

INCOME BASED PAYMENTS

If you are suffering from a financial hardship you may be eligible for an

Income Based Payment In this repayment program you would have a

payment based on your income and family size The payment could be as

low as $000 per month with forgiveness at the end of 20-25 years

44

Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 50 of 57 Page ID 1809

L E ARN MORE

LOAN FORGIVENESS

If you have Federal Student Loans you may qualify for any of the student

loan forgiveness programs that are available to borrowers You may be

eligible for principal reduction loan forgiveness or a complete loan

discharge depending on your individual circumstance

L EARN MORE

PRIVATE STUDENT LOAN CONSOLIDATION

Much like refinancing a mortgage generally the biggest benefit of private

student loan consolidationstudent loan refinancing is a lower interest rate

httpaidnestcomservices[442018 115322 AM]

45Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 51 of 57 Page ID 1810

L E ARN MORE

(something federal consolidations do not offer)

STUDENT LOAN REHABILITATION

You can renew eligibility for new loans and grants and eliminate the loan

default by ldquorehabilitatingrdquo a defaulted loan

httpaidnestcomservices[442018 115322 AM]

46Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 52 of 57 Page ID 1811

CHE CK E L E G I B I L I T Y

WAGE GARNISHMENT

A wage garnishment is any legal procedure in which some portion of a

personrsquos earnings is required to be withheld by an employer for the

payment of a debt

L EARN MORE

With our fast friendly and professional services wersquoll be glad to help you get your student loans

reduced forgiven or completely discharged To this end wersquoll assist you in consolidating all your

student loans so yoursquoll have only one lender and yoursquoll start making one monthly payment Our

professionals will walk you through the best and most flexible repayment options and if itrsquos also

necessary varied deferment options and rehabilitation programs

httpaidnestcomservices[442018 115322 AM]

47Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 53 of 57 Page ID 1812

Services | AIDNEST Let us help you through this national crisis

Our CRM System

Our CRM is one of the most advanced in the industry and most importantly itrsquos linked directly to

the Department of Education (DOE) This keeps your personal and most confidential information

safe Furthermore because our CRM system is linked to the DOE our approval is 100 Through

our CRM we will be doing continuous monitoring of our process without losing sight of your

immediate needs ensuring that your case has the proper handling and most efficient process

httpaidnestcomservices[442018 115322 AM]

48Exhibit E

n

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 54 of 57 Page ID 1813

Services | AIDNEST Let us help you through this national crisis

R ECENT POSTS

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

ABOUT US

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcomservices[442018 115322 AM]

49Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 55 of 57 Page ID 1814

EXHIBIT F

s -

bullmiddot - ~ t ~ower Your Student Loan Pay~e~ts oday -- Students Helping Students Save Money

INCOME BASED PAJIIIJITPAIS

I C(gttoUC1 u~

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 56 of 57 Page ID 1815

X + C (D Not secure wwwstudoracom 0

CALL US NOW (85S) 978-S599 middot 1nfostudoracom

HOME SERVICES ABOUT US FAQ CONTACT US BLOC PRIVACY

Offering obligation and commitment free loan relief solutions

STUDENT LOAN FORGIVENESS INCOME BASED PAYMENTS LOAN CONSOLIDATION

We11 help you get your loans reduced forgiven o r Make monthly pdyments based on your affordability Get multiple Federal Student Loans consolidated into

discharged one low monthly payment

Talk to our experts concerning your

student loans

Studora is a pnvatefy owned company that helps consumers like you identify

government programs that fit your financial s1tuat1on Our loan experts will assist you in selecting the appropriate programs that WOltk with your income family size and

desired monthly payment We then prepare the appropriate documents for your review and submission All this f o r one low easy payment

Testimonials

Thank you f o r getting back to me quickly Youve been fabulous Thank you for the confirmation and for your help today Pass

during this whole process Is there a place I can go online that I this on to your sup that you were very professional and very

can leave a comment for your manager Youve made this Robert helpful and brought a sense of relief for me Thank you very

process so easy and answered every question my husband and I much and have a great rest of your day Kudos to you and your

have had teammoneywell spenL

Exhibit F 50

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 57 of 57 Page ID 1816

Services we offer

Stud ora offers document preparation services for all loan forgiveness consolidation and relief services to people who are unable to manage their finances Our mam aim is to

offer complete peace of mind to indiVidual unable to pay their student loan debt

we otter the folloWing document preparation services with complete professional assistance

amFinancial Review ffl Budget Planning

Toe first step to creating a flexible loan repayment plan is financial review we also help create a personal finance plan to ensure that you are able to

Our professmnals will look into your finances and design a custom manage your monthly budget in the most effective way This plan will keep

repayment plan that is affordable and easy to manage your spending to the minimum alloWing you to save more money for loan

repayment

Permanent Disability Forgiveness r-trTeacher Loan Forgiveness (5 You can get rid of your Federal Student Loan if you are permanently disabled Good news for teachers who are under the weight of a massiVe loan You can

now get $17 forgiven on your student loans

Public Service Loan Forgiveness Custom Debt Relief Plans

Want assistance with debt relief Get in touch with our experts who will help If you are a public service agent you can get rid of your loan after 120 days of design a loan repayment and relief plan for you based on your monthly

income and affordability payments

THERE ARE NO OBLIGATIONS OR COMMITMENTS

want to save thousands of dollars Fill out our form and get relief from your student loan for a more

peaceful tomorrow

Your Name

BiHHHi

Exhibit F 51

Attachment A

Page 37: JOSHUA S. MILLARD, BRIAN M. WELKE, pro hac vice · for which it has no legitimate claim. Noel is a Wyoming limited liability company that reported in a public document that its principal

Knowledge Base

Defaulted Student Loans

Wage Garnishment

Student Loan Rehabilitation

Income Based Repayment Plan

Deferment and Forbearance

Pay As You Earn Repayment Plan

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE Call 561)424-6053 today to go over your options

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 37 of 57 Page ID 1796

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

Our knowledge base is designed to provide information regarding some of the critical topics those with student loans must be aware of to be able to make educated decisions regarding their future

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

A wage garnishment is any legal procedure in which some portion of a personrsquos earnings is required to be withheld by an employer for the payment of a debt

If yoursquore in default you donrsquot have to worry anymore ndash not only can we enroll you into one of our rehabilitation programs but also your credit score will show in good standing within 6 to 9 months

With this program your payments change as your income changes and will not be longer than 25 years This is the ideal plan if you are in partial financial hardship Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard plan

Temporarily allowing you to postpone or reduce your federal student loan payments Postponing or reducing your payments may help you avoid default and future garnishments

Your monthly payments will be lower and yoursquoll pay more for your loan over time than you would under the 10-year standard

3 of 6 462018 945 AM

33

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 38 of 57 Page ID 1797

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

4 of 6 462018 945 AM

34Attachment A

Testimonials

Latest News

Why 2016 Will Be a Big Year For Student Loans

Top Student Loan Refinancing Questions of 2015

Oba mas latest student loan plan

Things You Should Know About Public Service Loan Forgiveness

Recent Posts

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 39 of 57 Page ID 1798

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

5 of 6 462018 945 AM

35

About Us

Contact Info

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 40 of 57 Page ID 1799

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

pay-grandchild-studen

Why 2016 Will Be a Big Year For Student Loans

December 30 2015

12511110_1112367518

Top Student Loan Refinancing Questions of 2015

December 30 2015

We stand by our consultation and quote We are so sure and confident about our services and offers that they are all 100 money back guarantee risk free ndash if we donrsquot do what we promise yoursquoll get your money back

(800) 555-1212 AidnestStudenLoansgmailcom 18100 Von Karman Ave Suite 850 Irvine CA 92612

Futero SAS copy 2015 | Aidnestcom

6 of 6 462018 945

Exhibit D 36Attachment A

AM

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 41 of 57 Page ID 1800

EXHIBIT E

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 42 of 57 Page ID 1801

AIDNEST Let us help you through this national crisis

Call one of our specialists today

Forbearance amp Deferment If you are still in school and struggling to make payments on your student loans You may qualify

for Forbearance amp Deferment

Garnishment Prevention Federal law requires that the Department of Education or guarantee agency notifies you before they

begin garnishing your wages

Loan Forgiveness If you are a teacher public service worker or an individual with total and permanent disability you

httpaidnestcom[442018 115239 AM]

37Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 43 of 57 Page ID 1802

AIDNEST Let us help you through this national crisis

may qualify for this program

Consolidating Your Loans Consolidating your loans to one new loan under one lender may lower your payments and make

your life a bit more manageable

Affordable Payments If you are looking to lower your monthly payments then Income Based Repayment Plans may be

the correct choice for you

Learn more about our services

LEARN MORE

httpaidnestcom[442018 115239 AM]

38Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 44 of 57 Page ID 1803

AIDNEST Let us help you through this national crisis

Loan Forgiveness Programs Income Based Payments Student Loan Rehabilitation

Student Loan Consolidation

You may be eligible for

Loan Forgiveness Programs

In some cases individuals with Federal Student Loans may qualify to have a portion of the amount

owed to be forgiven

Get in touch with our professional team to find out which loan forgiveness program you qualify for and

how you can get rid of your unpaid student loan

L EARN MORE

httpaidnestcom[442018 115239 AM]

39Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 45 of 57 Page ID 1804

AIDNEST Let us help you through this national crisis

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE

Meet your Budget One of our advisers will help you meet your payment goals by using your budget and timeline to

determine the best plan available

httpaidnestcom[442018 115239 AM]

40Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 46 of 57 Page ID 1805

AIDNEST Let us help you through this national crisis

Simple Process We understand that lowering your payments alone can be difficult Our intuitive platform allows us

to keep the entire process simple

Customer Satisfaction We are committed to providing you with outstanding service only We look forward to working

with you

100 money back guarantee No Hassle Money Back Policy

httpaidnestcom[442018 115239 AM]

41Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 47 of 57 Page ID 1806

AIDNEST Let us help you through this national crisis

Lower your loan payments by getting in touch with one of our professionals

We design a customized repayment plan that will allow you to make payments based on your

monthly income family size and spending Get rid of the hassle of extensive paperwork and get the

help you deserve

What we can help you achieve a lower payment or lower rate

httpaidnestcom[442018 115239 AM]

42Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 48 of 57 Page ID 1807

AIDNEST Let us help you through this national crisis

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcom[442018 115239 AM]

43Exhibit E

httpaidnestcomservices[442018 115322 AM]

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 49 of 57 Page ID 1808

Services | AIDNEST Let us help you through this national crisis

INCOME BASED PAYMENTS

If you are suffering from a financial hardship you may be eligible for an

Income Based Payment In this repayment program you would have a

payment based on your income and family size The payment could be as

low as $000 per month with forgiveness at the end of 20-25 years

44

Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 50 of 57 Page ID 1809

L E ARN MORE

LOAN FORGIVENESS

If you have Federal Student Loans you may qualify for any of the student

loan forgiveness programs that are available to borrowers You may be

eligible for principal reduction loan forgiveness or a complete loan

discharge depending on your individual circumstance

L EARN MORE

PRIVATE STUDENT LOAN CONSOLIDATION

Much like refinancing a mortgage generally the biggest benefit of private

student loan consolidationstudent loan refinancing is a lower interest rate

httpaidnestcomservices[442018 115322 AM]

45Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 51 of 57 Page ID 1810

L E ARN MORE

(something federal consolidations do not offer)

STUDENT LOAN REHABILITATION

You can renew eligibility for new loans and grants and eliminate the loan

default by ldquorehabilitatingrdquo a defaulted loan

httpaidnestcomservices[442018 115322 AM]

46Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 52 of 57 Page ID 1811

CHE CK E L E G I B I L I T Y

WAGE GARNISHMENT

A wage garnishment is any legal procedure in which some portion of a

personrsquos earnings is required to be withheld by an employer for the

payment of a debt

L EARN MORE

With our fast friendly and professional services wersquoll be glad to help you get your student loans

reduced forgiven or completely discharged To this end wersquoll assist you in consolidating all your

student loans so yoursquoll have only one lender and yoursquoll start making one monthly payment Our

professionals will walk you through the best and most flexible repayment options and if itrsquos also

necessary varied deferment options and rehabilitation programs

httpaidnestcomservices[442018 115322 AM]

47Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 53 of 57 Page ID 1812

Services | AIDNEST Let us help you through this national crisis

Our CRM System

Our CRM is one of the most advanced in the industry and most importantly itrsquos linked directly to

the Department of Education (DOE) This keeps your personal and most confidential information

safe Furthermore because our CRM system is linked to the DOE our approval is 100 Through

our CRM we will be doing continuous monitoring of our process without losing sight of your

immediate needs ensuring that your case has the proper handling and most efficient process

httpaidnestcomservices[442018 115322 AM]

48Exhibit E

n

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 54 of 57 Page ID 1813

Services | AIDNEST Let us help you through this national crisis

R ECENT POSTS

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

ABOUT US

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcomservices[442018 115322 AM]

49Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 55 of 57 Page ID 1814

EXHIBIT F

s -

bullmiddot - ~ t ~ower Your Student Loan Pay~e~ts oday -- Students Helping Students Save Money

INCOME BASED PAJIIIJITPAIS

I C(gttoUC1 u~

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 56 of 57 Page ID 1815

X + C (D Not secure wwwstudoracom 0

CALL US NOW (85S) 978-S599 middot 1nfostudoracom

HOME SERVICES ABOUT US FAQ CONTACT US BLOC PRIVACY

Offering obligation and commitment free loan relief solutions

STUDENT LOAN FORGIVENESS INCOME BASED PAYMENTS LOAN CONSOLIDATION

We11 help you get your loans reduced forgiven o r Make monthly pdyments based on your affordability Get multiple Federal Student Loans consolidated into

discharged one low monthly payment

Talk to our experts concerning your

student loans

Studora is a pnvatefy owned company that helps consumers like you identify

government programs that fit your financial s1tuat1on Our loan experts will assist you in selecting the appropriate programs that WOltk with your income family size and

desired monthly payment We then prepare the appropriate documents for your review and submission All this f o r one low easy payment

Testimonials

Thank you f o r getting back to me quickly Youve been fabulous Thank you for the confirmation and for your help today Pass

during this whole process Is there a place I can go online that I this on to your sup that you were very professional and very

can leave a comment for your manager Youve made this Robert helpful and brought a sense of relief for me Thank you very

process so easy and answered every question my husband and I much and have a great rest of your day Kudos to you and your

have had teammoneywell spenL

Exhibit F 50

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 57 of 57 Page ID 1816

Services we offer

Stud ora offers document preparation services for all loan forgiveness consolidation and relief services to people who are unable to manage their finances Our mam aim is to

offer complete peace of mind to indiVidual unable to pay their student loan debt

we otter the folloWing document preparation services with complete professional assistance

amFinancial Review ffl Budget Planning

Toe first step to creating a flexible loan repayment plan is financial review we also help create a personal finance plan to ensure that you are able to

Our professmnals will look into your finances and design a custom manage your monthly budget in the most effective way This plan will keep

repayment plan that is affordable and easy to manage your spending to the minimum alloWing you to save more money for loan

repayment

Permanent Disability Forgiveness r-trTeacher Loan Forgiveness (5 You can get rid of your Federal Student Loan if you are permanently disabled Good news for teachers who are under the weight of a massiVe loan You can

now get $17 forgiven on your student loans

Public Service Loan Forgiveness Custom Debt Relief Plans

Want assistance with debt relief Get in touch with our experts who will help If you are a public service agent you can get rid of your loan after 120 days of design a loan repayment and relief plan for you based on your monthly

income and affordability payments

THERE ARE NO OBLIGATIONS OR COMMITMENTS

want to save thousands of dollars Fill out our form and get relief from your student loan for a more

peaceful tomorrow

Your Name

BiHHHi

Exhibit F 51

Attachment A

Page 38: JOSHUA S. MILLARD, BRIAN M. WELKE, pro hac vice · for which it has no legitimate claim. Noel is a Wyoming limited liability company that reported in a public document that its principal

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 38 of 57 Page ID 1797

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

4 of 6 462018 945 AM

34Attachment A

Testimonials

Latest News

Why 2016 Will Be a Big Year For Student Loans

Top Student Loan Refinancing Questions of 2015

Oba mas latest student loan plan

Things You Should Know About Public Service Loan Forgiveness

Recent Posts

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 39 of 57 Page ID 1798

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

5 of 6 462018 945 AM

35

About Us

Contact Info

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 40 of 57 Page ID 1799

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

pay-grandchild-studen

Why 2016 Will Be a Big Year For Student Loans

December 30 2015

12511110_1112367518

Top Student Loan Refinancing Questions of 2015

December 30 2015

We stand by our consultation and quote We are so sure and confident about our services and offers that they are all 100 money back guarantee risk free ndash if we donrsquot do what we promise yoursquoll get your money back

(800) 555-1212 AidnestStudenLoansgmailcom 18100 Von Karman Ave Suite 850 Irvine CA 92612

Futero SAS copy 2015 | Aidnestcom

6 of 6 462018 945

Exhibit D 36Attachment A

AM

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 41 of 57 Page ID 1800

EXHIBIT E

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 42 of 57 Page ID 1801

AIDNEST Let us help you through this national crisis

Call one of our specialists today

Forbearance amp Deferment If you are still in school and struggling to make payments on your student loans You may qualify

for Forbearance amp Deferment

Garnishment Prevention Federal law requires that the Department of Education or guarantee agency notifies you before they

begin garnishing your wages

Loan Forgiveness If you are a teacher public service worker or an individual with total and permanent disability you

httpaidnestcom[442018 115239 AM]

37Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 43 of 57 Page ID 1802

AIDNEST Let us help you through this national crisis

may qualify for this program

Consolidating Your Loans Consolidating your loans to one new loan under one lender may lower your payments and make

your life a bit more manageable

Affordable Payments If you are looking to lower your monthly payments then Income Based Repayment Plans may be

the correct choice for you

Learn more about our services

LEARN MORE

httpaidnestcom[442018 115239 AM]

38Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 44 of 57 Page ID 1803

AIDNEST Let us help you through this national crisis

Loan Forgiveness Programs Income Based Payments Student Loan Rehabilitation

Student Loan Consolidation

You may be eligible for

Loan Forgiveness Programs

In some cases individuals with Federal Student Loans may qualify to have a portion of the amount

owed to be forgiven

Get in touch with our professional team to find out which loan forgiveness program you qualify for and

how you can get rid of your unpaid student loan

L EARN MORE

httpaidnestcom[442018 115239 AM]

39Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 45 of 57 Page ID 1804

AIDNEST Let us help you through this national crisis

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE

Meet your Budget One of our advisers will help you meet your payment goals by using your budget and timeline to

determine the best plan available

httpaidnestcom[442018 115239 AM]

40Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 46 of 57 Page ID 1805

AIDNEST Let us help you through this national crisis

Simple Process We understand that lowering your payments alone can be difficult Our intuitive platform allows us

to keep the entire process simple

Customer Satisfaction We are committed to providing you with outstanding service only We look forward to working

with you

100 money back guarantee No Hassle Money Back Policy

httpaidnestcom[442018 115239 AM]

41Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 47 of 57 Page ID 1806

AIDNEST Let us help you through this national crisis

Lower your loan payments by getting in touch with one of our professionals

We design a customized repayment plan that will allow you to make payments based on your

monthly income family size and spending Get rid of the hassle of extensive paperwork and get the

help you deserve

What we can help you achieve a lower payment or lower rate

httpaidnestcom[442018 115239 AM]

42Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 48 of 57 Page ID 1807

AIDNEST Let us help you through this national crisis

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcom[442018 115239 AM]

43Exhibit E

httpaidnestcomservices[442018 115322 AM]

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 49 of 57 Page ID 1808

Services | AIDNEST Let us help you through this national crisis

INCOME BASED PAYMENTS

If you are suffering from a financial hardship you may be eligible for an

Income Based Payment In this repayment program you would have a

payment based on your income and family size The payment could be as

low as $000 per month with forgiveness at the end of 20-25 years

44

Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 50 of 57 Page ID 1809

L E ARN MORE

LOAN FORGIVENESS

If you have Federal Student Loans you may qualify for any of the student

loan forgiveness programs that are available to borrowers You may be

eligible for principal reduction loan forgiveness or a complete loan

discharge depending on your individual circumstance

L EARN MORE

PRIVATE STUDENT LOAN CONSOLIDATION

Much like refinancing a mortgage generally the biggest benefit of private

student loan consolidationstudent loan refinancing is a lower interest rate

httpaidnestcomservices[442018 115322 AM]

45Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 51 of 57 Page ID 1810

L E ARN MORE

(something federal consolidations do not offer)

STUDENT LOAN REHABILITATION

You can renew eligibility for new loans and grants and eliminate the loan

default by ldquorehabilitatingrdquo a defaulted loan

httpaidnestcomservices[442018 115322 AM]

46Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 52 of 57 Page ID 1811

CHE CK E L E G I B I L I T Y

WAGE GARNISHMENT

A wage garnishment is any legal procedure in which some portion of a

personrsquos earnings is required to be withheld by an employer for the

payment of a debt

L EARN MORE

With our fast friendly and professional services wersquoll be glad to help you get your student loans

reduced forgiven or completely discharged To this end wersquoll assist you in consolidating all your

student loans so yoursquoll have only one lender and yoursquoll start making one monthly payment Our

professionals will walk you through the best and most flexible repayment options and if itrsquos also

necessary varied deferment options and rehabilitation programs

httpaidnestcomservices[442018 115322 AM]

47Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 53 of 57 Page ID 1812

Services | AIDNEST Let us help you through this national crisis

Our CRM System

Our CRM is one of the most advanced in the industry and most importantly itrsquos linked directly to

the Department of Education (DOE) This keeps your personal and most confidential information

safe Furthermore because our CRM system is linked to the DOE our approval is 100 Through

our CRM we will be doing continuous monitoring of our process without losing sight of your

immediate needs ensuring that your case has the proper handling and most efficient process

httpaidnestcomservices[442018 115322 AM]

48Exhibit E

n

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 54 of 57 Page ID 1813

Services | AIDNEST Let us help you through this national crisis

R ECENT POSTS

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

ABOUT US

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcomservices[442018 115322 AM]

49Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 55 of 57 Page ID 1814

EXHIBIT F

s -

bullmiddot - ~ t ~ower Your Student Loan Pay~e~ts oday -- Students Helping Students Save Money

INCOME BASED PAJIIIJITPAIS

I C(gttoUC1 u~

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 56 of 57 Page ID 1815

X + C (D Not secure wwwstudoracom 0

CALL US NOW (85S) 978-S599 middot 1nfostudoracom

HOME SERVICES ABOUT US FAQ CONTACT US BLOC PRIVACY

Offering obligation and commitment free loan relief solutions

STUDENT LOAN FORGIVENESS INCOME BASED PAYMENTS LOAN CONSOLIDATION

We11 help you get your loans reduced forgiven o r Make monthly pdyments based on your affordability Get multiple Federal Student Loans consolidated into

discharged one low monthly payment

Talk to our experts concerning your

student loans

Studora is a pnvatefy owned company that helps consumers like you identify

government programs that fit your financial s1tuat1on Our loan experts will assist you in selecting the appropriate programs that WOltk with your income family size and

desired monthly payment We then prepare the appropriate documents for your review and submission All this f o r one low easy payment

Testimonials

Thank you f o r getting back to me quickly Youve been fabulous Thank you for the confirmation and for your help today Pass

during this whole process Is there a place I can go online that I this on to your sup that you were very professional and very

can leave a comment for your manager Youve made this Robert helpful and brought a sense of relief for me Thank you very

process so easy and answered every question my husband and I much and have a great rest of your day Kudos to you and your

have had teammoneywell spenL

Exhibit F 50

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 57 of 57 Page ID 1816

Services we offer

Stud ora offers document preparation services for all loan forgiveness consolidation and relief services to people who are unable to manage their finances Our mam aim is to

offer complete peace of mind to indiVidual unable to pay their student loan debt

we otter the folloWing document preparation services with complete professional assistance

amFinancial Review ffl Budget Planning

Toe first step to creating a flexible loan repayment plan is financial review we also help create a personal finance plan to ensure that you are able to

Our professmnals will look into your finances and design a custom manage your monthly budget in the most effective way This plan will keep

repayment plan that is affordable and easy to manage your spending to the minimum alloWing you to save more money for loan

repayment

Permanent Disability Forgiveness r-trTeacher Loan Forgiveness (5 You can get rid of your Federal Student Loan if you are permanently disabled Good news for teachers who are under the weight of a massiVe loan You can

now get $17 forgiven on your student loans

Public Service Loan Forgiveness Custom Debt Relief Plans

Want assistance with debt relief Get in touch with our experts who will help If you are a public service agent you can get rid of your loan after 120 days of design a loan repayment and relief plan for you based on your monthly

income and affordability payments

THERE ARE NO OBLIGATIONS OR COMMITMENTS

want to save thousands of dollars Fill out our form and get relief from your student loan for a more

peaceful tomorrow

Your Name

BiHHHi

Exhibit F 51

Attachment A

Page 39: JOSHUA S. MILLARD, BRIAN M. WELKE, pro hac vice · for which it has no legitimate claim. Noel is a Wyoming limited liability company that reported in a public document that its principal

Testimonials

Latest News

Why 2016 Will Be a Big Year For Student Loans

Top Student Loan Refinancing Questions of 2015

Oba mas latest student loan plan

Things You Should Know About Public Service Loan Forgiveness

Recent Posts

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 39 of 57 Page ID 1798

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

5 of 6 462018 945 AM

35

About Us

Contact Info

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 40 of 57 Page ID 1799

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

pay-grandchild-studen

Why 2016 Will Be a Big Year For Student Loans

December 30 2015

12511110_1112367518

Top Student Loan Refinancing Questions of 2015

December 30 2015

We stand by our consultation and quote We are so sure and confident about our services and offers that they are all 100 money back guarantee risk free ndash if we donrsquot do what we promise yoursquoll get your money back

(800) 555-1212 AidnestStudenLoansgmailcom 18100 Von Karman Ave Suite 850 Irvine CA 92612

Futero SAS copy 2015 | Aidnestcom

6 of 6 462018 945

Exhibit D 36Attachment A

AM

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 41 of 57 Page ID 1800

EXHIBIT E

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 42 of 57 Page ID 1801

AIDNEST Let us help you through this national crisis

Call one of our specialists today

Forbearance amp Deferment If you are still in school and struggling to make payments on your student loans You may qualify

for Forbearance amp Deferment

Garnishment Prevention Federal law requires that the Department of Education or guarantee agency notifies you before they

begin garnishing your wages

Loan Forgiveness If you are a teacher public service worker or an individual with total and permanent disability you

httpaidnestcom[442018 115239 AM]

37Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 43 of 57 Page ID 1802

AIDNEST Let us help you through this national crisis

may qualify for this program

Consolidating Your Loans Consolidating your loans to one new loan under one lender may lower your payments and make

your life a bit more manageable

Affordable Payments If you are looking to lower your monthly payments then Income Based Repayment Plans may be

the correct choice for you

Learn more about our services

LEARN MORE

httpaidnestcom[442018 115239 AM]

38Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 44 of 57 Page ID 1803

AIDNEST Let us help you through this national crisis

Loan Forgiveness Programs Income Based Payments Student Loan Rehabilitation

Student Loan Consolidation

You may be eligible for

Loan Forgiveness Programs

In some cases individuals with Federal Student Loans may qualify to have a portion of the amount

owed to be forgiven

Get in touch with our professional team to find out which loan forgiveness program you qualify for and

how you can get rid of your unpaid student loan

L EARN MORE

httpaidnestcom[442018 115239 AM]

39Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 45 of 57 Page ID 1804

AIDNEST Let us help you through this national crisis

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE

Meet your Budget One of our advisers will help you meet your payment goals by using your budget and timeline to

determine the best plan available

httpaidnestcom[442018 115239 AM]

40Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 46 of 57 Page ID 1805

AIDNEST Let us help you through this national crisis

Simple Process We understand that lowering your payments alone can be difficult Our intuitive platform allows us

to keep the entire process simple

Customer Satisfaction We are committed to providing you with outstanding service only We look forward to working

with you

100 money back guarantee No Hassle Money Back Policy

httpaidnestcom[442018 115239 AM]

41Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 47 of 57 Page ID 1806

AIDNEST Let us help you through this national crisis

Lower your loan payments by getting in touch with one of our professionals

We design a customized repayment plan that will allow you to make payments based on your

monthly income family size and spending Get rid of the hassle of extensive paperwork and get the

help you deserve

What we can help you achieve a lower payment or lower rate

httpaidnestcom[442018 115239 AM]

42Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 48 of 57 Page ID 1807

AIDNEST Let us help you through this national crisis

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcom[442018 115239 AM]

43Exhibit E

httpaidnestcomservices[442018 115322 AM]

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 49 of 57 Page ID 1808

Services | AIDNEST Let us help you through this national crisis

INCOME BASED PAYMENTS

If you are suffering from a financial hardship you may be eligible for an

Income Based Payment In this repayment program you would have a

payment based on your income and family size The payment could be as

low as $000 per month with forgiveness at the end of 20-25 years

44

Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 50 of 57 Page ID 1809

L E ARN MORE

LOAN FORGIVENESS

If you have Federal Student Loans you may qualify for any of the student

loan forgiveness programs that are available to borrowers You may be

eligible for principal reduction loan forgiveness or a complete loan

discharge depending on your individual circumstance

L EARN MORE

PRIVATE STUDENT LOAN CONSOLIDATION

Much like refinancing a mortgage generally the biggest benefit of private

student loan consolidationstudent loan refinancing is a lower interest rate

httpaidnestcomservices[442018 115322 AM]

45Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 51 of 57 Page ID 1810

L E ARN MORE

(something federal consolidations do not offer)

STUDENT LOAN REHABILITATION

You can renew eligibility for new loans and grants and eliminate the loan

default by ldquorehabilitatingrdquo a defaulted loan

httpaidnestcomservices[442018 115322 AM]

46Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 52 of 57 Page ID 1811

CHE CK E L E G I B I L I T Y

WAGE GARNISHMENT

A wage garnishment is any legal procedure in which some portion of a

personrsquos earnings is required to be withheld by an employer for the

payment of a debt

L EARN MORE

With our fast friendly and professional services wersquoll be glad to help you get your student loans

reduced forgiven or completely discharged To this end wersquoll assist you in consolidating all your

student loans so yoursquoll have only one lender and yoursquoll start making one monthly payment Our

professionals will walk you through the best and most flexible repayment options and if itrsquos also

necessary varied deferment options and rehabilitation programs

httpaidnestcomservices[442018 115322 AM]

47Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 53 of 57 Page ID 1812

Services | AIDNEST Let us help you through this national crisis

Our CRM System

Our CRM is one of the most advanced in the industry and most importantly itrsquos linked directly to

the Department of Education (DOE) This keeps your personal and most confidential information

safe Furthermore because our CRM system is linked to the DOE our approval is 100 Through

our CRM we will be doing continuous monitoring of our process without losing sight of your

immediate needs ensuring that your case has the proper handling and most efficient process

httpaidnestcomservices[442018 115322 AM]

48Exhibit E

n

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 54 of 57 Page ID 1813

Services | AIDNEST Let us help you through this national crisis

R ECENT POSTS

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

ABOUT US

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcomservices[442018 115322 AM]

49Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 55 of 57 Page ID 1814

EXHIBIT F

s -

bullmiddot - ~ t ~ower Your Student Loan Pay~e~ts oday -- Students Helping Students Save Money

INCOME BASED PAJIIIJITPAIS

I C(gttoUC1 u~

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 56 of 57 Page ID 1815

X + C (D Not secure wwwstudoracom 0

CALL US NOW (85S) 978-S599 middot 1nfostudoracom

HOME SERVICES ABOUT US FAQ CONTACT US BLOC PRIVACY

Offering obligation and commitment free loan relief solutions

STUDENT LOAN FORGIVENESS INCOME BASED PAYMENTS LOAN CONSOLIDATION

We11 help you get your loans reduced forgiven o r Make monthly pdyments based on your affordability Get multiple Federal Student Loans consolidated into

discharged one low monthly payment

Talk to our experts concerning your

student loans

Studora is a pnvatefy owned company that helps consumers like you identify

government programs that fit your financial s1tuat1on Our loan experts will assist you in selecting the appropriate programs that WOltk with your income family size and

desired monthly payment We then prepare the appropriate documents for your review and submission All this f o r one low easy payment

Testimonials

Thank you f o r getting back to me quickly Youve been fabulous Thank you for the confirmation and for your help today Pass

during this whole process Is there a place I can go online that I this on to your sup that you were very professional and very

can leave a comment for your manager Youve made this Robert helpful and brought a sense of relief for me Thank you very

process so easy and answered every question my husband and I much and have a great rest of your day Kudos to you and your

have had teammoneywell spenL

Exhibit F 50

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 57 of 57 Page ID 1816

Services we offer

Stud ora offers document preparation services for all loan forgiveness consolidation and relief services to people who are unable to manage their finances Our mam aim is to

offer complete peace of mind to indiVidual unable to pay their student loan debt

we otter the folloWing document preparation services with complete professional assistance

amFinancial Review ffl Budget Planning

Toe first step to creating a flexible loan repayment plan is financial review we also help create a personal finance plan to ensure that you are able to

Our professmnals will look into your finances and design a custom manage your monthly budget in the most effective way This plan will keep

repayment plan that is affordable and easy to manage your spending to the minimum alloWing you to save more money for loan

repayment

Permanent Disability Forgiveness r-trTeacher Loan Forgiveness (5 You can get rid of your Federal Student Loan if you are permanently disabled Good news for teachers who are under the weight of a massiVe loan You can

now get $17 forgiven on your student loans

Public Service Loan Forgiveness Custom Debt Relief Plans

Want assistance with debt relief Get in touch with our experts who will help If you are a public service agent you can get rid of your loan after 120 days of design a loan repayment and relief plan for you based on your monthly

income and affordability payments

THERE ARE NO OBLIGATIONS OR COMMITMENTS

want to save thousands of dollars Fill out our form and get relief from your student loan for a more

peaceful tomorrow

Your Name

BiHHHi

Exhibit F 51

Attachment A

Page 40: JOSHUA S. MILLARD, BRIAN M. WELKE, pro hac vice · for which it has no legitimate claim. Noel is a Wyoming limited liability company that reported in a public document that its principal

About Us

Contact Info

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 40 of 57 Page ID 1799

National Education Student amp Teacher httpswebarchiveorgweb20160117101622httpwwwaidnestcom

pay-grandchild-studen

Why 2016 Will Be a Big Year For Student Loans

December 30 2015

12511110_1112367518

Top Student Loan Refinancing Questions of 2015

December 30 2015

We stand by our consultation and quote We are so sure and confident about our services and offers that they are all 100 money back guarantee risk free ndash if we donrsquot do what we promise yoursquoll get your money back

(800) 555-1212 AidnestStudenLoansgmailcom 18100 Von Karman Ave Suite 850 Irvine CA 92612

Futero SAS copy 2015 | Aidnestcom

6 of 6 462018 945

Exhibit D 36Attachment A

AM

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 41 of 57 Page ID 1800

EXHIBIT E

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 42 of 57 Page ID 1801

AIDNEST Let us help you through this national crisis

Call one of our specialists today

Forbearance amp Deferment If you are still in school and struggling to make payments on your student loans You may qualify

for Forbearance amp Deferment

Garnishment Prevention Federal law requires that the Department of Education or guarantee agency notifies you before they

begin garnishing your wages

Loan Forgiveness If you are a teacher public service worker or an individual with total and permanent disability you

httpaidnestcom[442018 115239 AM]

37Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 43 of 57 Page ID 1802

AIDNEST Let us help you through this national crisis

may qualify for this program

Consolidating Your Loans Consolidating your loans to one new loan under one lender may lower your payments and make

your life a bit more manageable

Affordable Payments If you are looking to lower your monthly payments then Income Based Repayment Plans may be

the correct choice for you

Learn more about our services

LEARN MORE

httpaidnestcom[442018 115239 AM]

38Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 44 of 57 Page ID 1803

AIDNEST Let us help you through this national crisis

Loan Forgiveness Programs Income Based Payments Student Loan Rehabilitation

Student Loan Consolidation

You may be eligible for

Loan Forgiveness Programs

In some cases individuals with Federal Student Loans may qualify to have a portion of the amount

owed to be forgiven

Get in touch with our professional team to find out which loan forgiveness program you qualify for and

how you can get rid of your unpaid student loan

L EARN MORE

httpaidnestcom[442018 115239 AM]

39Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 45 of 57 Page ID 1804

AIDNEST Let us help you through this national crisis

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE

Meet your Budget One of our advisers will help you meet your payment goals by using your budget and timeline to

determine the best plan available

httpaidnestcom[442018 115239 AM]

40Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 46 of 57 Page ID 1805

AIDNEST Let us help you through this national crisis

Simple Process We understand that lowering your payments alone can be difficult Our intuitive platform allows us

to keep the entire process simple

Customer Satisfaction We are committed to providing you with outstanding service only We look forward to working

with you

100 money back guarantee No Hassle Money Back Policy

httpaidnestcom[442018 115239 AM]

41Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 47 of 57 Page ID 1806

AIDNEST Let us help you through this national crisis

Lower your loan payments by getting in touch with one of our professionals

We design a customized repayment plan that will allow you to make payments based on your

monthly income family size and spending Get rid of the hassle of extensive paperwork and get the

help you deserve

What we can help you achieve a lower payment or lower rate

httpaidnestcom[442018 115239 AM]

42Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 48 of 57 Page ID 1807

AIDNEST Let us help you through this national crisis

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcom[442018 115239 AM]

43Exhibit E

httpaidnestcomservices[442018 115322 AM]

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 49 of 57 Page ID 1808

Services | AIDNEST Let us help you through this national crisis

INCOME BASED PAYMENTS

If you are suffering from a financial hardship you may be eligible for an

Income Based Payment In this repayment program you would have a

payment based on your income and family size The payment could be as

low as $000 per month with forgiveness at the end of 20-25 years

44

Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 50 of 57 Page ID 1809

L E ARN MORE

LOAN FORGIVENESS

If you have Federal Student Loans you may qualify for any of the student

loan forgiveness programs that are available to borrowers You may be

eligible for principal reduction loan forgiveness or a complete loan

discharge depending on your individual circumstance

L EARN MORE

PRIVATE STUDENT LOAN CONSOLIDATION

Much like refinancing a mortgage generally the biggest benefit of private

student loan consolidationstudent loan refinancing is a lower interest rate

httpaidnestcomservices[442018 115322 AM]

45Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 51 of 57 Page ID 1810

L E ARN MORE

(something federal consolidations do not offer)

STUDENT LOAN REHABILITATION

You can renew eligibility for new loans and grants and eliminate the loan

default by ldquorehabilitatingrdquo a defaulted loan

httpaidnestcomservices[442018 115322 AM]

46Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 52 of 57 Page ID 1811

CHE CK E L E G I B I L I T Y

WAGE GARNISHMENT

A wage garnishment is any legal procedure in which some portion of a

personrsquos earnings is required to be withheld by an employer for the

payment of a debt

L EARN MORE

With our fast friendly and professional services wersquoll be glad to help you get your student loans

reduced forgiven or completely discharged To this end wersquoll assist you in consolidating all your

student loans so yoursquoll have only one lender and yoursquoll start making one monthly payment Our

professionals will walk you through the best and most flexible repayment options and if itrsquos also

necessary varied deferment options and rehabilitation programs

httpaidnestcomservices[442018 115322 AM]

47Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 53 of 57 Page ID 1812

Services | AIDNEST Let us help you through this national crisis

Our CRM System

Our CRM is one of the most advanced in the industry and most importantly itrsquos linked directly to

the Department of Education (DOE) This keeps your personal and most confidential information

safe Furthermore because our CRM system is linked to the DOE our approval is 100 Through

our CRM we will be doing continuous monitoring of our process without losing sight of your

immediate needs ensuring that your case has the proper handling and most efficient process

httpaidnestcomservices[442018 115322 AM]

48Exhibit E

n

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 54 of 57 Page ID 1813

Services | AIDNEST Let us help you through this national crisis

R ECENT POSTS

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

ABOUT US

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcomservices[442018 115322 AM]

49Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 55 of 57 Page ID 1814

EXHIBIT F

s -

bullmiddot - ~ t ~ower Your Student Loan Pay~e~ts oday -- Students Helping Students Save Money

INCOME BASED PAJIIIJITPAIS

I C(gttoUC1 u~

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 56 of 57 Page ID 1815

X + C (D Not secure wwwstudoracom 0

CALL US NOW (85S) 978-S599 middot 1nfostudoracom

HOME SERVICES ABOUT US FAQ CONTACT US BLOC PRIVACY

Offering obligation and commitment free loan relief solutions

STUDENT LOAN FORGIVENESS INCOME BASED PAYMENTS LOAN CONSOLIDATION

We11 help you get your loans reduced forgiven o r Make monthly pdyments based on your affordability Get multiple Federal Student Loans consolidated into

discharged one low monthly payment

Talk to our experts concerning your

student loans

Studora is a pnvatefy owned company that helps consumers like you identify

government programs that fit your financial s1tuat1on Our loan experts will assist you in selecting the appropriate programs that WOltk with your income family size and

desired monthly payment We then prepare the appropriate documents for your review and submission All this f o r one low easy payment

Testimonials

Thank you f o r getting back to me quickly Youve been fabulous Thank you for the confirmation and for your help today Pass

during this whole process Is there a place I can go online that I this on to your sup that you were very professional and very

can leave a comment for your manager Youve made this Robert helpful and brought a sense of relief for me Thank you very

process so easy and answered every question my husband and I much and have a great rest of your day Kudos to you and your

have had teammoneywell spenL

Exhibit F 50

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 57 of 57 Page ID 1816

Services we offer

Stud ora offers document preparation services for all loan forgiveness consolidation and relief services to people who are unable to manage their finances Our mam aim is to

offer complete peace of mind to indiVidual unable to pay their student loan debt

we otter the folloWing document preparation services with complete professional assistance

amFinancial Review ffl Budget Planning

Toe first step to creating a flexible loan repayment plan is financial review we also help create a personal finance plan to ensure that you are able to

Our professmnals will look into your finances and design a custom manage your monthly budget in the most effective way This plan will keep

repayment plan that is affordable and easy to manage your spending to the minimum alloWing you to save more money for loan

repayment

Permanent Disability Forgiveness r-trTeacher Loan Forgiveness (5 You can get rid of your Federal Student Loan if you are permanently disabled Good news for teachers who are under the weight of a massiVe loan You can

now get $17 forgiven on your student loans

Public Service Loan Forgiveness Custom Debt Relief Plans

Want assistance with debt relief Get in touch with our experts who will help If you are a public service agent you can get rid of your loan after 120 days of design a loan repayment and relief plan for you based on your monthly

income and affordability payments

THERE ARE NO OBLIGATIONS OR COMMITMENTS

want to save thousands of dollars Fill out our form and get relief from your student loan for a more

peaceful tomorrow

Your Name

BiHHHi

Exhibit F 51

Attachment A

Page 41: JOSHUA S. MILLARD, BRIAN M. WELKE, pro hac vice · for which it has no legitimate claim. Noel is a Wyoming limited liability company that reported in a public document that its principal

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 41 of 57 Page ID 1800

EXHIBIT E

Attachment A

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 42 of 57 Page ID 1801

AIDNEST Let us help you through this national crisis

Call one of our specialists today

Forbearance amp Deferment If you are still in school and struggling to make payments on your student loans You may qualify

for Forbearance amp Deferment

Garnishment Prevention Federal law requires that the Department of Education or guarantee agency notifies you before they

begin garnishing your wages

Loan Forgiveness If you are a teacher public service worker or an individual with total and permanent disability you

httpaidnestcom[442018 115239 AM]

37Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 43 of 57 Page ID 1802

AIDNEST Let us help you through this national crisis

may qualify for this program

Consolidating Your Loans Consolidating your loans to one new loan under one lender may lower your payments and make

your life a bit more manageable

Affordable Payments If you are looking to lower your monthly payments then Income Based Repayment Plans may be

the correct choice for you

Learn more about our services

LEARN MORE

httpaidnestcom[442018 115239 AM]

38Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 44 of 57 Page ID 1803

AIDNEST Let us help you through this national crisis

Loan Forgiveness Programs Income Based Payments Student Loan Rehabilitation

Student Loan Consolidation

You may be eligible for

Loan Forgiveness Programs

In some cases individuals with Federal Student Loans may qualify to have a portion of the amount

owed to be forgiven

Get in touch with our professional team to find out which loan forgiveness program you qualify for and

how you can get rid of your unpaid student loan

L EARN MORE

httpaidnestcom[442018 115239 AM]

39Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 45 of 57 Page ID 1804

AIDNEST Let us help you through this national crisis

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE

Meet your Budget One of our advisers will help you meet your payment goals by using your budget and timeline to

determine the best plan available

httpaidnestcom[442018 115239 AM]

40Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 46 of 57 Page ID 1805

AIDNEST Let us help you through this national crisis

Simple Process We understand that lowering your payments alone can be difficult Our intuitive platform allows us

to keep the entire process simple

Customer Satisfaction We are committed to providing you with outstanding service only We look forward to working

with you

100 money back guarantee No Hassle Money Back Policy

httpaidnestcom[442018 115239 AM]

41Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 47 of 57 Page ID 1806

AIDNEST Let us help you through this national crisis

Lower your loan payments by getting in touch with one of our professionals

We design a customized repayment plan that will allow you to make payments based on your

monthly income family size and spending Get rid of the hassle of extensive paperwork and get the

help you deserve

What we can help you achieve a lower payment or lower rate

httpaidnestcom[442018 115239 AM]

42Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 48 of 57 Page ID 1807

AIDNEST Let us help you through this national crisis

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcom[442018 115239 AM]

43Exhibit E

httpaidnestcomservices[442018 115322 AM]

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 49 of 57 Page ID 1808

Services | AIDNEST Let us help you through this national crisis

INCOME BASED PAYMENTS

If you are suffering from a financial hardship you may be eligible for an

Income Based Payment In this repayment program you would have a

payment based on your income and family size The payment could be as

low as $000 per month with forgiveness at the end of 20-25 years

44

Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 50 of 57 Page ID 1809

L E ARN MORE

LOAN FORGIVENESS

If you have Federal Student Loans you may qualify for any of the student

loan forgiveness programs that are available to borrowers You may be

eligible for principal reduction loan forgiveness or a complete loan

discharge depending on your individual circumstance

L EARN MORE

PRIVATE STUDENT LOAN CONSOLIDATION

Much like refinancing a mortgage generally the biggest benefit of private

student loan consolidationstudent loan refinancing is a lower interest rate

httpaidnestcomservices[442018 115322 AM]

45Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 51 of 57 Page ID 1810

L E ARN MORE

(something federal consolidations do not offer)

STUDENT LOAN REHABILITATION

You can renew eligibility for new loans and grants and eliminate the loan

default by ldquorehabilitatingrdquo a defaulted loan

httpaidnestcomservices[442018 115322 AM]

46Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 52 of 57 Page ID 1811

CHE CK E L E G I B I L I T Y

WAGE GARNISHMENT

A wage garnishment is any legal procedure in which some portion of a

personrsquos earnings is required to be withheld by an employer for the

payment of a debt

L EARN MORE

With our fast friendly and professional services wersquoll be glad to help you get your student loans

reduced forgiven or completely discharged To this end wersquoll assist you in consolidating all your

student loans so yoursquoll have only one lender and yoursquoll start making one monthly payment Our

professionals will walk you through the best and most flexible repayment options and if itrsquos also

necessary varied deferment options and rehabilitation programs

httpaidnestcomservices[442018 115322 AM]

47Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 53 of 57 Page ID 1812

Services | AIDNEST Let us help you through this national crisis

Our CRM System

Our CRM is one of the most advanced in the industry and most importantly itrsquos linked directly to

the Department of Education (DOE) This keeps your personal and most confidential information

safe Furthermore because our CRM system is linked to the DOE our approval is 100 Through

our CRM we will be doing continuous monitoring of our process without losing sight of your

immediate needs ensuring that your case has the proper handling and most efficient process

httpaidnestcomservices[442018 115322 AM]

48Exhibit E

n

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 54 of 57 Page ID 1813

Services | AIDNEST Let us help you through this national crisis

R ECENT POSTS

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

ABOUT US

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcomservices[442018 115322 AM]

49Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 55 of 57 Page ID 1814

EXHIBIT F

s -

bullmiddot - ~ t ~ower Your Student Loan Pay~e~ts oday -- Students Helping Students Save Money

INCOME BASED PAJIIIJITPAIS

I C(gttoUC1 u~

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 56 of 57 Page ID 1815

X + C (D Not secure wwwstudoracom 0

CALL US NOW (85S) 978-S599 middot 1nfostudoracom

HOME SERVICES ABOUT US FAQ CONTACT US BLOC PRIVACY

Offering obligation and commitment free loan relief solutions

STUDENT LOAN FORGIVENESS INCOME BASED PAYMENTS LOAN CONSOLIDATION

We11 help you get your loans reduced forgiven o r Make monthly pdyments based on your affordability Get multiple Federal Student Loans consolidated into

discharged one low monthly payment

Talk to our experts concerning your

student loans

Studora is a pnvatefy owned company that helps consumers like you identify

government programs that fit your financial s1tuat1on Our loan experts will assist you in selecting the appropriate programs that WOltk with your income family size and

desired monthly payment We then prepare the appropriate documents for your review and submission All this f o r one low easy payment

Testimonials

Thank you f o r getting back to me quickly Youve been fabulous Thank you for the confirmation and for your help today Pass

during this whole process Is there a place I can go online that I this on to your sup that you were very professional and very

can leave a comment for your manager Youve made this Robert helpful and brought a sense of relief for me Thank you very

process so easy and answered every question my husband and I much and have a great rest of your day Kudos to you and your

have had teammoneywell spenL

Exhibit F 50

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 57 of 57 Page ID 1816

Services we offer

Stud ora offers document preparation services for all loan forgiveness consolidation and relief services to people who are unable to manage their finances Our mam aim is to

offer complete peace of mind to indiVidual unable to pay their student loan debt

we otter the folloWing document preparation services with complete professional assistance

amFinancial Review ffl Budget Planning

Toe first step to creating a flexible loan repayment plan is financial review we also help create a personal finance plan to ensure that you are able to

Our professmnals will look into your finances and design a custom manage your monthly budget in the most effective way This plan will keep

repayment plan that is affordable and easy to manage your spending to the minimum alloWing you to save more money for loan

repayment

Permanent Disability Forgiveness r-trTeacher Loan Forgiveness (5 You can get rid of your Federal Student Loan if you are permanently disabled Good news for teachers who are under the weight of a massiVe loan You can

now get $17 forgiven on your student loans

Public Service Loan Forgiveness Custom Debt Relief Plans

Want assistance with debt relief Get in touch with our experts who will help If you are a public service agent you can get rid of your loan after 120 days of design a loan repayment and relief plan for you based on your monthly

income and affordability payments

THERE ARE NO OBLIGATIONS OR COMMITMENTS

want to save thousands of dollars Fill out our form and get relief from your student loan for a more

peaceful tomorrow

Your Name

BiHHHi

Exhibit F 51

Attachment A

Page 42: JOSHUA S. MILLARD, BRIAN M. WELKE, pro hac vice · for which it has no legitimate claim. Noel is a Wyoming limited liability company that reported in a public document that its principal

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 42 of 57 Page ID 1801

AIDNEST Let us help you through this national crisis

Call one of our specialists today

Forbearance amp Deferment If you are still in school and struggling to make payments on your student loans You may qualify

for Forbearance amp Deferment

Garnishment Prevention Federal law requires that the Department of Education or guarantee agency notifies you before they

begin garnishing your wages

Loan Forgiveness If you are a teacher public service worker or an individual with total and permanent disability you

httpaidnestcom[442018 115239 AM]

37Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 43 of 57 Page ID 1802

AIDNEST Let us help you through this national crisis

may qualify for this program

Consolidating Your Loans Consolidating your loans to one new loan under one lender may lower your payments and make

your life a bit more manageable

Affordable Payments If you are looking to lower your monthly payments then Income Based Repayment Plans may be

the correct choice for you

Learn more about our services

LEARN MORE

httpaidnestcom[442018 115239 AM]

38Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 44 of 57 Page ID 1803

AIDNEST Let us help you through this national crisis

Loan Forgiveness Programs Income Based Payments Student Loan Rehabilitation

Student Loan Consolidation

You may be eligible for

Loan Forgiveness Programs

In some cases individuals with Federal Student Loans may qualify to have a portion of the amount

owed to be forgiven

Get in touch with our professional team to find out which loan forgiveness program you qualify for and

how you can get rid of your unpaid student loan

L EARN MORE

httpaidnestcom[442018 115239 AM]

39Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 45 of 57 Page ID 1804

AIDNEST Let us help you through this national crisis

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE

Meet your Budget One of our advisers will help you meet your payment goals by using your budget and timeline to

determine the best plan available

httpaidnestcom[442018 115239 AM]

40Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 46 of 57 Page ID 1805

AIDNEST Let us help you through this national crisis

Simple Process We understand that lowering your payments alone can be difficult Our intuitive platform allows us

to keep the entire process simple

Customer Satisfaction We are committed to providing you with outstanding service only We look forward to working

with you

100 money back guarantee No Hassle Money Back Policy

httpaidnestcom[442018 115239 AM]

41Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 47 of 57 Page ID 1806

AIDNEST Let us help you through this national crisis

Lower your loan payments by getting in touch with one of our professionals

We design a customized repayment plan that will allow you to make payments based on your

monthly income family size and spending Get rid of the hassle of extensive paperwork and get the

help you deserve

What we can help you achieve a lower payment or lower rate

httpaidnestcom[442018 115239 AM]

42Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 48 of 57 Page ID 1807

AIDNEST Let us help you through this national crisis

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcom[442018 115239 AM]

43Exhibit E

httpaidnestcomservices[442018 115322 AM]

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 49 of 57 Page ID 1808

Services | AIDNEST Let us help you through this national crisis

INCOME BASED PAYMENTS

If you are suffering from a financial hardship you may be eligible for an

Income Based Payment In this repayment program you would have a

payment based on your income and family size The payment could be as

low as $000 per month with forgiveness at the end of 20-25 years

44

Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 50 of 57 Page ID 1809

L E ARN MORE

LOAN FORGIVENESS

If you have Federal Student Loans you may qualify for any of the student

loan forgiveness programs that are available to borrowers You may be

eligible for principal reduction loan forgiveness or a complete loan

discharge depending on your individual circumstance

L EARN MORE

PRIVATE STUDENT LOAN CONSOLIDATION

Much like refinancing a mortgage generally the biggest benefit of private

student loan consolidationstudent loan refinancing is a lower interest rate

httpaidnestcomservices[442018 115322 AM]

45Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 51 of 57 Page ID 1810

L E ARN MORE

(something federal consolidations do not offer)

STUDENT LOAN REHABILITATION

You can renew eligibility for new loans and grants and eliminate the loan

default by ldquorehabilitatingrdquo a defaulted loan

httpaidnestcomservices[442018 115322 AM]

46Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 52 of 57 Page ID 1811

CHE CK E L E G I B I L I T Y

WAGE GARNISHMENT

A wage garnishment is any legal procedure in which some portion of a

personrsquos earnings is required to be withheld by an employer for the

payment of a debt

L EARN MORE

With our fast friendly and professional services wersquoll be glad to help you get your student loans

reduced forgiven or completely discharged To this end wersquoll assist you in consolidating all your

student loans so yoursquoll have only one lender and yoursquoll start making one monthly payment Our

professionals will walk you through the best and most flexible repayment options and if itrsquos also

necessary varied deferment options and rehabilitation programs

httpaidnestcomservices[442018 115322 AM]

47Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 53 of 57 Page ID 1812

Services | AIDNEST Let us help you through this national crisis

Our CRM System

Our CRM is one of the most advanced in the industry and most importantly itrsquos linked directly to

the Department of Education (DOE) This keeps your personal and most confidential information

safe Furthermore because our CRM system is linked to the DOE our approval is 100 Through

our CRM we will be doing continuous monitoring of our process without losing sight of your

immediate needs ensuring that your case has the proper handling and most efficient process

httpaidnestcomservices[442018 115322 AM]

48Exhibit E

n

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 54 of 57 Page ID 1813

Services | AIDNEST Let us help you through this national crisis

R ECENT POSTS

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

ABOUT US

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcomservices[442018 115322 AM]

49Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 55 of 57 Page ID 1814

EXHIBIT F

s -

bullmiddot - ~ t ~ower Your Student Loan Pay~e~ts oday -- Students Helping Students Save Money

INCOME BASED PAJIIIJITPAIS

I C(gttoUC1 u~

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 56 of 57 Page ID 1815

X + C (D Not secure wwwstudoracom 0

CALL US NOW (85S) 978-S599 middot 1nfostudoracom

HOME SERVICES ABOUT US FAQ CONTACT US BLOC PRIVACY

Offering obligation and commitment free loan relief solutions

STUDENT LOAN FORGIVENESS INCOME BASED PAYMENTS LOAN CONSOLIDATION

We11 help you get your loans reduced forgiven o r Make monthly pdyments based on your affordability Get multiple Federal Student Loans consolidated into

discharged one low monthly payment

Talk to our experts concerning your

student loans

Studora is a pnvatefy owned company that helps consumers like you identify

government programs that fit your financial s1tuat1on Our loan experts will assist you in selecting the appropriate programs that WOltk with your income family size and

desired monthly payment We then prepare the appropriate documents for your review and submission All this f o r one low easy payment

Testimonials

Thank you f o r getting back to me quickly Youve been fabulous Thank you for the confirmation and for your help today Pass

during this whole process Is there a place I can go online that I this on to your sup that you were very professional and very

can leave a comment for your manager Youve made this Robert helpful and brought a sense of relief for me Thank you very

process so easy and answered every question my husband and I much and have a great rest of your day Kudos to you and your

have had teammoneywell spenL

Exhibit F 50

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 57 of 57 Page ID 1816

Services we offer

Stud ora offers document preparation services for all loan forgiveness consolidation and relief services to people who are unable to manage their finances Our mam aim is to

offer complete peace of mind to indiVidual unable to pay their student loan debt

we otter the folloWing document preparation services with complete professional assistance

amFinancial Review ffl Budget Planning

Toe first step to creating a flexible loan repayment plan is financial review we also help create a personal finance plan to ensure that you are able to

Our professmnals will look into your finances and design a custom manage your monthly budget in the most effective way This plan will keep

repayment plan that is affordable and easy to manage your spending to the minimum alloWing you to save more money for loan

repayment

Permanent Disability Forgiveness r-trTeacher Loan Forgiveness (5 You can get rid of your Federal Student Loan if you are permanently disabled Good news for teachers who are under the weight of a massiVe loan You can

now get $17 forgiven on your student loans

Public Service Loan Forgiveness Custom Debt Relief Plans

Want assistance with debt relief Get in touch with our experts who will help If you are a public service agent you can get rid of your loan after 120 days of design a loan repayment and relief plan for you based on your monthly

income and affordability payments

THERE ARE NO OBLIGATIONS OR COMMITMENTS

want to save thousands of dollars Fill out our form and get relief from your student loan for a more

peaceful tomorrow

Your Name

BiHHHi

Exhibit F 51

Attachment A

Page 43: JOSHUA S. MILLARD, BRIAN M. WELKE, pro hac vice · for which it has no legitimate claim. Noel is a Wyoming limited liability company that reported in a public document that its principal

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 43 of 57 Page ID 1802

AIDNEST Let us help you through this national crisis

may qualify for this program

Consolidating Your Loans Consolidating your loans to one new loan under one lender may lower your payments and make

your life a bit more manageable

Affordable Payments If you are looking to lower your monthly payments then Income Based Repayment Plans may be

the correct choice for you

Learn more about our services

LEARN MORE

httpaidnestcom[442018 115239 AM]

38Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 44 of 57 Page ID 1803

AIDNEST Let us help you through this national crisis

Loan Forgiveness Programs Income Based Payments Student Loan Rehabilitation

Student Loan Consolidation

You may be eligible for

Loan Forgiveness Programs

In some cases individuals with Federal Student Loans may qualify to have a portion of the amount

owed to be forgiven

Get in touch with our professional team to find out which loan forgiveness program you qualify for and

how you can get rid of your unpaid student loan

L EARN MORE

httpaidnestcom[442018 115239 AM]

39Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 45 of 57 Page ID 1804

AIDNEST Let us help you through this national crisis

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE

Meet your Budget One of our advisers will help you meet your payment goals by using your budget and timeline to

determine the best plan available

httpaidnestcom[442018 115239 AM]

40Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 46 of 57 Page ID 1805

AIDNEST Let us help you through this national crisis

Simple Process We understand that lowering your payments alone can be difficult Our intuitive platform allows us

to keep the entire process simple

Customer Satisfaction We are committed to providing you with outstanding service only We look forward to working

with you

100 money back guarantee No Hassle Money Back Policy

httpaidnestcom[442018 115239 AM]

41Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 47 of 57 Page ID 1806

AIDNEST Let us help you through this national crisis

Lower your loan payments by getting in touch with one of our professionals

We design a customized repayment plan that will allow you to make payments based on your

monthly income family size and spending Get rid of the hassle of extensive paperwork and get the

help you deserve

What we can help you achieve a lower payment or lower rate

httpaidnestcom[442018 115239 AM]

42Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 48 of 57 Page ID 1807

AIDNEST Let us help you through this national crisis

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcom[442018 115239 AM]

43Exhibit E

httpaidnestcomservices[442018 115322 AM]

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 49 of 57 Page ID 1808

Services | AIDNEST Let us help you through this national crisis

INCOME BASED PAYMENTS

If you are suffering from a financial hardship you may be eligible for an

Income Based Payment In this repayment program you would have a

payment based on your income and family size The payment could be as

low as $000 per month with forgiveness at the end of 20-25 years

44

Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 50 of 57 Page ID 1809

L E ARN MORE

LOAN FORGIVENESS

If you have Federal Student Loans you may qualify for any of the student

loan forgiveness programs that are available to borrowers You may be

eligible for principal reduction loan forgiveness or a complete loan

discharge depending on your individual circumstance

L EARN MORE

PRIVATE STUDENT LOAN CONSOLIDATION

Much like refinancing a mortgage generally the biggest benefit of private

student loan consolidationstudent loan refinancing is a lower interest rate

httpaidnestcomservices[442018 115322 AM]

45Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 51 of 57 Page ID 1810

L E ARN MORE

(something federal consolidations do not offer)

STUDENT LOAN REHABILITATION

You can renew eligibility for new loans and grants and eliminate the loan

default by ldquorehabilitatingrdquo a defaulted loan

httpaidnestcomservices[442018 115322 AM]

46Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 52 of 57 Page ID 1811

CHE CK E L E G I B I L I T Y

WAGE GARNISHMENT

A wage garnishment is any legal procedure in which some portion of a

personrsquos earnings is required to be withheld by an employer for the

payment of a debt

L EARN MORE

With our fast friendly and professional services wersquoll be glad to help you get your student loans

reduced forgiven or completely discharged To this end wersquoll assist you in consolidating all your

student loans so yoursquoll have only one lender and yoursquoll start making one monthly payment Our

professionals will walk you through the best and most flexible repayment options and if itrsquos also

necessary varied deferment options and rehabilitation programs

httpaidnestcomservices[442018 115322 AM]

47Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 53 of 57 Page ID 1812

Services | AIDNEST Let us help you through this national crisis

Our CRM System

Our CRM is one of the most advanced in the industry and most importantly itrsquos linked directly to

the Department of Education (DOE) This keeps your personal and most confidential information

safe Furthermore because our CRM system is linked to the DOE our approval is 100 Through

our CRM we will be doing continuous monitoring of our process without losing sight of your

immediate needs ensuring that your case has the proper handling and most efficient process

httpaidnestcomservices[442018 115322 AM]

48Exhibit E

n

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 54 of 57 Page ID 1813

Services | AIDNEST Let us help you through this national crisis

R ECENT POSTS

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

ABOUT US

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcomservices[442018 115322 AM]

49Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 55 of 57 Page ID 1814

EXHIBIT F

s -

bullmiddot - ~ t ~ower Your Student Loan Pay~e~ts oday -- Students Helping Students Save Money

INCOME BASED PAJIIIJITPAIS

I C(gttoUC1 u~

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 56 of 57 Page ID 1815

X + C (D Not secure wwwstudoracom 0

CALL US NOW (85S) 978-S599 middot 1nfostudoracom

HOME SERVICES ABOUT US FAQ CONTACT US BLOC PRIVACY

Offering obligation and commitment free loan relief solutions

STUDENT LOAN FORGIVENESS INCOME BASED PAYMENTS LOAN CONSOLIDATION

We11 help you get your loans reduced forgiven o r Make monthly pdyments based on your affordability Get multiple Federal Student Loans consolidated into

discharged one low monthly payment

Talk to our experts concerning your

student loans

Studora is a pnvatefy owned company that helps consumers like you identify

government programs that fit your financial s1tuat1on Our loan experts will assist you in selecting the appropriate programs that WOltk with your income family size and

desired monthly payment We then prepare the appropriate documents for your review and submission All this f o r one low easy payment

Testimonials

Thank you f o r getting back to me quickly Youve been fabulous Thank you for the confirmation and for your help today Pass

during this whole process Is there a place I can go online that I this on to your sup that you were very professional and very

can leave a comment for your manager Youve made this Robert helpful and brought a sense of relief for me Thank you very

process so easy and answered every question my husband and I much and have a great rest of your day Kudos to you and your

have had teammoneywell spenL

Exhibit F 50

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 57 of 57 Page ID 1816

Services we offer

Stud ora offers document preparation services for all loan forgiveness consolidation and relief services to people who are unable to manage their finances Our mam aim is to

offer complete peace of mind to indiVidual unable to pay their student loan debt

we otter the folloWing document preparation services with complete professional assistance

amFinancial Review ffl Budget Planning

Toe first step to creating a flexible loan repayment plan is financial review we also help create a personal finance plan to ensure that you are able to

Our professmnals will look into your finances and design a custom manage your monthly budget in the most effective way This plan will keep

repayment plan that is affordable and easy to manage your spending to the minimum alloWing you to save more money for loan

repayment

Permanent Disability Forgiveness r-trTeacher Loan Forgiveness (5 You can get rid of your Federal Student Loan if you are permanently disabled Good news for teachers who are under the weight of a massiVe loan You can

now get $17 forgiven on your student loans

Public Service Loan Forgiveness Custom Debt Relief Plans

Want assistance with debt relief Get in touch with our experts who will help If you are a public service agent you can get rid of your loan after 120 days of design a loan repayment and relief plan for you based on your monthly

income and affordability payments

THERE ARE NO OBLIGATIONS OR COMMITMENTS

want to save thousands of dollars Fill out our form and get relief from your student loan for a more

peaceful tomorrow

Your Name

BiHHHi

Exhibit F 51

Attachment A

Page 44: JOSHUA S. MILLARD, BRIAN M. WELKE, pro hac vice · for which it has no legitimate claim. Noel is a Wyoming limited liability company that reported in a public document that its principal

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 44 of 57 Page ID 1803

AIDNEST Let us help you through this national crisis

Loan Forgiveness Programs Income Based Payments Student Loan Rehabilitation

Student Loan Consolidation

You may be eligible for

Loan Forgiveness Programs

In some cases individuals with Federal Student Loans may qualify to have a portion of the amount

owed to be forgiven

Get in touch with our professional team to find out which loan forgiveness program you qualify for and

how you can get rid of your unpaid student loan

L EARN MORE

httpaidnestcom[442018 115239 AM]

39Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 45 of 57 Page ID 1804

AIDNEST Let us help you through this national crisis

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE

Meet your Budget One of our advisers will help you meet your payment goals by using your budget and timeline to

determine the best plan available

httpaidnestcom[442018 115239 AM]

40Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 46 of 57 Page ID 1805

AIDNEST Let us help you through this national crisis

Simple Process We understand that lowering your payments alone can be difficult Our intuitive platform allows us

to keep the entire process simple

Customer Satisfaction We are committed to providing you with outstanding service only We look forward to working

with you

100 money back guarantee No Hassle Money Back Policy

httpaidnestcom[442018 115239 AM]

41Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 47 of 57 Page ID 1806

AIDNEST Let us help you through this national crisis

Lower your loan payments by getting in touch with one of our professionals

We design a customized repayment plan that will allow you to make payments based on your

monthly income family size and spending Get rid of the hassle of extensive paperwork and get the

help you deserve

What we can help you achieve a lower payment or lower rate

httpaidnestcom[442018 115239 AM]

42Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 48 of 57 Page ID 1807

AIDNEST Let us help you through this national crisis

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcom[442018 115239 AM]

43Exhibit E

httpaidnestcomservices[442018 115322 AM]

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 49 of 57 Page ID 1808

Services | AIDNEST Let us help you through this national crisis

INCOME BASED PAYMENTS

If you are suffering from a financial hardship you may be eligible for an

Income Based Payment In this repayment program you would have a

payment based on your income and family size The payment could be as

low as $000 per month with forgiveness at the end of 20-25 years

44

Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 50 of 57 Page ID 1809

L E ARN MORE

LOAN FORGIVENESS

If you have Federal Student Loans you may qualify for any of the student

loan forgiveness programs that are available to borrowers You may be

eligible for principal reduction loan forgiveness or a complete loan

discharge depending on your individual circumstance

L EARN MORE

PRIVATE STUDENT LOAN CONSOLIDATION

Much like refinancing a mortgage generally the biggest benefit of private

student loan consolidationstudent loan refinancing is a lower interest rate

httpaidnestcomservices[442018 115322 AM]

45Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 51 of 57 Page ID 1810

L E ARN MORE

(something federal consolidations do not offer)

STUDENT LOAN REHABILITATION

You can renew eligibility for new loans and grants and eliminate the loan

default by ldquorehabilitatingrdquo a defaulted loan

httpaidnestcomservices[442018 115322 AM]

46Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 52 of 57 Page ID 1811

CHE CK E L E G I B I L I T Y

WAGE GARNISHMENT

A wage garnishment is any legal procedure in which some portion of a

personrsquos earnings is required to be withheld by an employer for the

payment of a debt

L EARN MORE

With our fast friendly and professional services wersquoll be glad to help you get your student loans

reduced forgiven or completely discharged To this end wersquoll assist you in consolidating all your

student loans so yoursquoll have only one lender and yoursquoll start making one monthly payment Our

professionals will walk you through the best and most flexible repayment options and if itrsquos also

necessary varied deferment options and rehabilitation programs

httpaidnestcomservices[442018 115322 AM]

47Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 53 of 57 Page ID 1812

Services | AIDNEST Let us help you through this national crisis

Our CRM System

Our CRM is one of the most advanced in the industry and most importantly itrsquos linked directly to

the Department of Education (DOE) This keeps your personal and most confidential information

safe Furthermore because our CRM system is linked to the DOE our approval is 100 Through

our CRM we will be doing continuous monitoring of our process without losing sight of your

immediate needs ensuring that your case has the proper handling and most efficient process

httpaidnestcomservices[442018 115322 AM]

48Exhibit E

n

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 54 of 57 Page ID 1813

Services | AIDNEST Let us help you through this national crisis

R ECENT POSTS

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

ABOUT US

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcomservices[442018 115322 AM]

49Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 55 of 57 Page ID 1814

EXHIBIT F

s -

bullmiddot - ~ t ~ower Your Student Loan Pay~e~ts oday -- Students Helping Students Save Money

INCOME BASED PAJIIIJITPAIS

I C(gttoUC1 u~

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 56 of 57 Page ID 1815

X + C (D Not secure wwwstudoracom 0

CALL US NOW (85S) 978-S599 middot 1nfostudoracom

HOME SERVICES ABOUT US FAQ CONTACT US BLOC PRIVACY

Offering obligation and commitment free loan relief solutions

STUDENT LOAN FORGIVENESS INCOME BASED PAYMENTS LOAN CONSOLIDATION

We11 help you get your loans reduced forgiven o r Make monthly pdyments based on your affordability Get multiple Federal Student Loans consolidated into

discharged one low monthly payment

Talk to our experts concerning your

student loans

Studora is a pnvatefy owned company that helps consumers like you identify

government programs that fit your financial s1tuat1on Our loan experts will assist you in selecting the appropriate programs that WOltk with your income family size and

desired monthly payment We then prepare the appropriate documents for your review and submission All this f o r one low easy payment

Testimonials

Thank you f o r getting back to me quickly Youve been fabulous Thank you for the confirmation and for your help today Pass

during this whole process Is there a place I can go online that I this on to your sup that you were very professional and very

can leave a comment for your manager Youve made this Robert helpful and brought a sense of relief for me Thank you very

process so easy and answered every question my husband and I much and have a great rest of your day Kudos to you and your

have had teammoneywell spenL

Exhibit F 50

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 57 of 57 Page ID 1816

Services we offer

Stud ora offers document preparation services for all loan forgiveness consolidation and relief services to people who are unable to manage their finances Our mam aim is to

offer complete peace of mind to indiVidual unable to pay their student loan debt

we otter the folloWing document preparation services with complete professional assistance

amFinancial Review ffl Budget Planning

Toe first step to creating a flexible loan repayment plan is financial review we also help create a personal finance plan to ensure that you are able to

Our professmnals will look into your finances and design a custom manage your monthly budget in the most effective way This plan will keep

repayment plan that is affordable and easy to manage your spending to the minimum alloWing you to save more money for loan

repayment

Permanent Disability Forgiveness r-trTeacher Loan Forgiveness (5 You can get rid of your Federal Student Loan if you are permanently disabled Good news for teachers who are under the weight of a massiVe loan You can

now get $17 forgiven on your student loans

Public Service Loan Forgiveness Custom Debt Relief Plans

Want assistance with debt relief Get in touch with our experts who will help If you are a public service agent you can get rid of your loan after 120 days of design a loan repayment and relief plan for you based on your monthly

income and affordability payments

THERE ARE NO OBLIGATIONS OR COMMITMENTS

want to save thousands of dollars Fill out our form and get relief from your student loan for a more

peaceful tomorrow

Your Name

BiHHHi

Exhibit F 51

Attachment A

Page 45: JOSHUA S. MILLARD, BRIAN M. WELKE, pro hac vice · for which it has no legitimate claim. Noel is a Wyoming limited liability company that reported in a public document that its principal

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 45 of 57 Page ID 1804

AIDNEST Let us help you through this national crisis

There are no obligations or commitments YOUR ASSESSMENT IS ABSOLUTELY FREE

Meet your Budget One of our advisers will help you meet your payment goals by using your budget and timeline to

determine the best plan available

httpaidnestcom[442018 115239 AM]

40Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 46 of 57 Page ID 1805

AIDNEST Let us help you through this national crisis

Simple Process We understand that lowering your payments alone can be difficult Our intuitive platform allows us

to keep the entire process simple

Customer Satisfaction We are committed to providing you with outstanding service only We look forward to working

with you

100 money back guarantee No Hassle Money Back Policy

httpaidnestcom[442018 115239 AM]

41Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 47 of 57 Page ID 1806

AIDNEST Let us help you through this national crisis

Lower your loan payments by getting in touch with one of our professionals

We design a customized repayment plan that will allow you to make payments based on your

monthly income family size and spending Get rid of the hassle of extensive paperwork and get the

help you deserve

What we can help you achieve a lower payment or lower rate

httpaidnestcom[442018 115239 AM]

42Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 48 of 57 Page ID 1807

AIDNEST Let us help you through this national crisis

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcom[442018 115239 AM]

43Exhibit E

httpaidnestcomservices[442018 115322 AM]

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 49 of 57 Page ID 1808

Services | AIDNEST Let us help you through this national crisis

INCOME BASED PAYMENTS

If you are suffering from a financial hardship you may be eligible for an

Income Based Payment In this repayment program you would have a

payment based on your income and family size The payment could be as

low as $000 per month with forgiveness at the end of 20-25 years

44

Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 50 of 57 Page ID 1809

L E ARN MORE

LOAN FORGIVENESS

If you have Federal Student Loans you may qualify for any of the student

loan forgiveness programs that are available to borrowers You may be

eligible for principal reduction loan forgiveness or a complete loan

discharge depending on your individual circumstance

L EARN MORE

PRIVATE STUDENT LOAN CONSOLIDATION

Much like refinancing a mortgage generally the biggest benefit of private

student loan consolidationstudent loan refinancing is a lower interest rate

httpaidnestcomservices[442018 115322 AM]

45Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 51 of 57 Page ID 1810

L E ARN MORE

(something federal consolidations do not offer)

STUDENT LOAN REHABILITATION

You can renew eligibility for new loans and grants and eliminate the loan

default by ldquorehabilitatingrdquo a defaulted loan

httpaidnestcomservices[442018 115322 AM]

46Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 52 of 57 Page ID 1811

CHE CK E L E G I B I L I T Y

WAGE GARNISHMENT

A wage garnishment is any legal procedure in which some portion of a

personrsquos earnings is required to be withheld by an employer for the

payment of a debt

L EARN MORE

With our fast friendly and professional services wersquoll be glad to help you get your student loans

reduced forgiven or completely discharged To this end wersquoll assist you in consolidating all your

student loans so yoursquoll have only one lender and yoursquoll start making one monthly payment Our

professionals will walk you through the best and most flexible repayment options and if itrsquos also

necessary varied deferment options and rehabilitation programs

httpaidnestcomservices[442018 115322 AM]

47Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 53 of 57 Page ID 1812

Services | AIDNEST Let us help you through this national crisis

Our CRM System

Our CRM is one of the most advanced in the industry and most importantly itrsquos linked directly to

the Department of Education (DOE) This keeps your personal and most confidential information

safe Furthermore because our CRM system is linked to the DOE our approval is 100 Through

our CRM we will be doing continuous monitoring of our process without losing sight of your

immediate needs ensuring that your case has the proper handling and most efficient process

httpaidnestcomservices[442018 115322 AM]

48Exhibit E

n

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 54 of 57 Page ID 1813

Services | AIDNEST Let us help you through this national crisis

R ECENT POSTS

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

ABOUT US

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcomservices[442018 115322 AM]

49Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 55 of 57 Page ID 1814

EXHIBIT F

s -

bullmiddot - ~ t ~ower Your Student Loan Pay~e~ts oday -- Students Helping Students Save Money

INCOME BASED PAJIIIJITPAIS

I C(gttoUC1 u~

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 56 of 57 Page ID 1815

X + C (D Not secure wwwstudoracom 0

CALL US NOW (85S) 978-S599 middot 1nfostudoracom

HOME SERVICES ABOUT US FAQ CONTACT US BLOC PRIVACY

Offering obligation and commitment free loan relief solutions

STUDENT LOAN FORGIVENESS INCOME BASED PAYMENTS LOAN CONSOLIDATION

We11 help you get your loans reduced forgiven o r Make monthly pdyments based on your affordability Get multiple Federal Student Loans consolidated into

discharged one low monthly payment

Talk to our experts concerning your

student loans

Studora is a pnvatefy owned company that helps consumers like you identify

government programs that fit your financial s1tuat1on Our loan experts will assist you in selecting the appropriate programs that WOltk with your income family size and

desired monthly payment We then prepare the appropriate documents for your review and submission All this f o r one low easy payment

Testimonials

Thank you f o r getting back to me quickly Youve been fabulous Thank you for the confirmation and for your help today Pass

during this whole process Is there a place I can go online that I this on to your sup that you were very professional and very

can leave a comment for your manager Youve made this Robert helpful and brought a sense of relief for me Thank you very

process so easy and answered every question my husband and I much and have a great rest of your day Kudos to you and your

have had teammoneywell spenL

Exhibit F 50

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 57 of 57 Page ID 1816

Services we offer

Stud ora offers document preparation services for all loan forgiveness consolidation and relief services to people who are unable to manage their finances Our mam aim is to

offer complete peace of mind to indiVidual unable to pay their student loan debt

we otter the folloWing document preparation services with complete professional assistance

amFinancial Review ffl Budget Planning

Toe first step to creating a flexible loan repayment plan is financial review we also help create a personal finance plan to ensure that you are able to

Our professmnals will look into your finances and design a custom manage your monthly budget in the most effective way This plan will keep

repayment plan that is affordable and easy to manage your spending to the minimum alloWing you to save more money for loan

repayment

Permanent Disability Forgiveness r-trTeacher Loan Forgiveness (5 You can get rid of your Federal Student Loan if you are permanently disabled Good news for teachers who are under the weight of a massiVe loan You can

now get $17 forgiven on your student loans

Public Service Loan Forgiveness Custom Debt Relief Plans

Want assistance with debt relief Get in touch with our experts who will help If you are a public service agent you can get rid of your loan after 120 days of design a loan repayment and relief plan for you based on your monthly

income and affordability payments

THERE ARE NO OBLIGATIONS OR COMMITMENTS

want to save thousands of dollars Fill out our form and get relief from your student loan for a more

peaceful tomorrow

Your Name

BiHHHi

Exhibit F 51

Attachment A

Page 46: JOSHUA S. MILLARD, BRIAN M. WELKE, pro hac vice · for which it has no legitimate claim. Noel is a Wyoming limited liability company that reported in a public document that its principal

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 46 of 57 Page ID 1805

AIDNEST Let us help you through this national crisis

Simple Process We understand that lowering your payments alone can be difficult Our intuitive platform allows us

to keep the entire process simple

Customer Satisfaction We are committed to providing you with outstanding service only We look forward to working

with you

100 money back guarantee No Hassle Money Back Policy

httpaidnestcom[442018 115239 AM]

41Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 47 of 57 Page ID 1806

AIDNEST Let us help you through this national crisis

Lower your loan payments by getting in touch with one of our professionals

We design a customized repayment plan that will allow you to make payments based on your

monthly income family size and spending Get rid of the hassle of extensive paperwork and get the

help you deserve

What we can help you achieve a lower payment or lower rate

httpaidnestcom[442018 115239 AM]

42Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 48 of 57 Page ID 1807

AIDNEST Let us help you through this national crisis

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcom[442018 115239 AM]

43Exhibit E

httpaidnestcomservices[442018 115322 AM]

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 49 of 57 Page ID 1808

Services | AIDNEST Let us help you through this national crisis

INCOME BASED PAYMENTS

If you are suffering from a financial hardship you may be eligible for an

Income Based Payment In this repayment program you would have a

payment based on your income and family size The payment could be as

low as $000 per month with forgiveness at the end of 20-25 years

44

Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 50 of 57 Page ID 1809

L E ARN MORE

LOAN FORGIVENESS

If you have Federal Student Loans you may qualify for any of the student

loan forgiveness programs that are available to borrowers You may be

eligible for principal reduction loan forgiveness or a complete loan

discharge depending on your individual circumstance

L EARN MORE

PRIVATE STUDENT LOAN CONSOLIDATION

Much like refinancing a mortgage generally the biggest benefit of private

student loan consolidationstudent loan refinancing is a lower interest rate

httpaidnestcomservices[442018 115322 AM]

45Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 51 of 57 Page ID 1810

L E ARN MORE

(something federal consolidations do not offer)

STUDENT LOAN REHABILITATION

You can renew eligibility for new loans and grants and eliminate the loan

default by ldquorehabilitatingrdquo a defaulted loan

httpaidnestcomservices[442018 115322 AM]

46Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 52 of 57 Page ID 1811

CHE CK E L E G I B I L I T Y

WAGE GARNISHMENT

A wage garnishment is any legal procedure in which some portion of a

personrsquos earnings is required to be withheld by an employer for the

payment of a debt

L EARN MORE

With our fast friendly and professional services wersquoll be glad to help you get your student loans

reduced forgiven or completely discharged To this end wersquoll assist you in consolidating all your

student loans so yoursquoll have only one lender and yoursquoll start making one monthly payment Our

professionals will walk you through the best and most flexible repayment options and if itrsquos also

necessary varied deferment options and rehabilitation programs

httpaidnestcomservices[442018 115322 AM]

47Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 53 of 57 Page ID 1812

Services | AIDNEST Let us help you through this national crisis

Our CRM System

Our CRM is one of the most advanced in the industry and most importantly itrsquos linked directly to

the Department of Education (DOE) This keeps your personal and most confidential information

safe Furthermore because our CRM system is linked to the DOE our approval is 100 Through

our CRM we will be doing continuous monitoring of our process without losing sight of your

immediate needs ensuring that your case has the proper handling and most efficient process

httpaidnestcomservices[442018 115322 AM]

48Exhibit E

n

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 54 of 57 Page ID 1813

Services | AIDNEST Let us help you through this national crisis

R ECENT POSTS

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

ABOUT US

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcomservices[442018 115322 AM]

49Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 55 of 57 Page ID 1814

EXHIBIT F

s -

bullmiddot - ~ t ~ower Your Student Loan Pay~e~ts oday -- Students Helping Students Save Money

INCOME BASED PAJIIIJITPAIS

I C(gttoUC1 u~

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 56 of 57 Page ID 1815

X + C (D Not secure wwwstudoracom 0

CALL US NOW (85S) 978-S599 middot 1nfostudoracom

HOME SERVICES ABOUT US FAQ CONTACT US BLOC PRIVACY

Offering obligation and commitment free loan relief solutions

STUDENT LOAN FORGIVENESS INCOME BASED PAYMENTS LOAN CONSOLIDATION

We11 help you get your loans reduced forgiven o r Make monthly pdyments based on your affordability Get multiple Federal Student Loans consolidated into

discharged one low monthly payment

Talk to our experts concerning your

student loans

Studora is a pnvatefy owned company that helps consumers like you identify

government programs that fit your financial s1tuat1on Our loan experts will assist you in selecting the appropriate programs that WOltk with your income family size and

desired monthly payment We then prepare the appropriate documents for your review and submission All this f o r one low easy payment

Testimonials

Thank you f o r getting back to me quickly Youve been fabulous Thank you for the confirmation and for your help today Pass

during this whole process Is there a place I can go online that I this on to your sup that you were very professional and very

can leave a comment for your manager Youve made this Robert helpful and brought a sense of relief for me Thank you very

process so easy and answered every question my husband and I much and have a great rest of your day Kudos to you and your

have had teammoneywell spenL

Exhibit F 50

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 57 of 57 Page ID 1816

Services we offer

Stud ora offers document preparation services for all loan forgiveness consolidation and relief services to people who are unable to manage their finances Our mam aim is to

offer complete peace of mind to indiVidual unable to pay their student loan debt

we otter the folloWing document preparation services with complete professional assistance

amFinancial Review ffl Budget Planning

Toe first step to creating a flexible loan repayment plan is financial review we also help create a personal finance plan to ensure that you are able to

Our professmnals will look into your finances and design a custom manage your monthly budget in the most effective way This plan will keep

repayment plan that is affordable and easy to manage your spending to the minimum alloWing you to save more money for loan

repayment

Permanent Disability Forgiveness r-trTeacher Loan Forgiveness (5 You can get rid of your Federal Student Loan if you are permanently disabled Good news for teachers who are under the weight of a massiVe loan You can

now get $17 forgiven on your student loans

Public Service Loan Forgiveness Custom Debt Relief Plans

Want assistance with debt relief Get in touch with our experts who will help If you are a public service agent you can get rid of your loan after 120 days of design a loan repayment and relief plan for you based on your monthly

income and affordability payments

THERE ARE NO OBLIGATIONS OR COMMITMENTS

want to save thousands of dollars Fill out our form and get relief from your student loan for a more

peaceful tomorrow

Your Name

BiHHHi

Exhibit F 51

Attachment A

Page 47: JOSHUA S. MILLARD, BRIAN M. WELKE, pro hac vice · for which it has no legitimate claim. Noel is a Wyoming limited liability company that reported in a public document that its principal

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 47 of 57 Page ID 1806

AIDNEST Let us help you through this national crisis

Lower your loan payments by getting in touch with one of our professionals

We design a customized repayment plan that will allow you to make payments based on your

monthly income family size and spending Get rid of the hassle of extensive paperwork and get the

help you deserve

What we can help you achieve a lower payment or lower rate

httpaidnestcom[442018 115239 AM]

42Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 48 of 57 Page ID 1807

AIDNEST Let us help you through this national crisis

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcom[442018 115239 AM]

43Exhibit E

httpaidnestcomservices[442018 115322 AM]

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 49 of 57 Page ID 1808

Services | AIDNEST Let us help you through this national crisis

INCOME BASED PAYMENTS

If you are suffering from a financial hardship you may be eligible for an

Income Based Payment In this repayment program you would have a

payment based on your income and family size The payment could be as

low as $000 per month with forgiveness at the end of 20-25 years

44

Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 50 of 57 Page ID 1809

L E ARN MORE

LOAN FORGIVENESS

If you have Federal Student Loans you may qualify for any of the student

loan forgiveness programs that are available to borrowers You may be

eligible for principal reduction loan forgiveness or a complete loan

discharge depending on your individual circumstance

L EARN MORE

PRIVATE STUDENT LOAN CONSOLIDATION

Much like refinancing a mortgage generally the biggest benefit of private

student loan consolidationstudent loan refinancing is a lower interest rate

httpaidnestcomservices[442018 115322 AM]

45Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 51 of 57 Page ID 1810

L E ARN MORE

(something federal consolidations do not offer)

STUDENT LOAN REHABILITATION

You can renew eligibility for new loans and grants and eliminate the loan

default by ldquorehabilitatingrdquo a defaulted loan

httpaidnestcomservices[442018 115322 AM]

46Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 52 of 57 Page ID 1811

CHE CK E L E G I B I L I T Y

WAGE GARNISHMENT

A wage garnishment is any legal procedure in which some portion of a

personrsquos earnings is required to be withheld by an employer for the

payment of a debt

L EARN MORE

With our fast friendly and professional services wersquoll be glad to help you get your student loans

reduced forgiven or completely discharged To this end wersquoll assist you in consolidating all your

student loans so yoursquoll have only one lender and yoursquoll start making one monthly payment Our

professionals will walk you through the best and most flexible repayment options and if itrsquos also

necessary varied deferment options and rehabilitation programs

httpaidnestcomservices[442018 115322 AM]

47Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 53 of 57 Page ID 1812

Services | AIDNEST Let us help you through this national crisis

Our CRM System

Our CRM is one of the most advanced in the industry and most importantly itrsquos linked directly to

the Department of Education (DOE) This keeps your personal and most confidential information

safe Furthermore because our CRM system is linked to the DOE our approval is 100 Through

our CRM we will be doing continuous monitoring of our process without losing sight of your

immediate needs ensuring that your case has the proper handling and most efficient process

httpaidnestcomservices[442018 115322 AM]

48Exhibit E

n

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 54 of 57 Page ID 1813

Services | AIDNEST Let us help you through this national crisis

R ECENT POSTS

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

ABOUT US

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcomservices[442018 115322 AM]

49Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 55 of 57 Page ID 1814

EXHIBIT F

s -

bullmiddot - ~ t ~ower Your Student Loan Pay~e~ts oday -- Students Helping Students Save Money

INCOME BASED PAJIIIJITPAIS

I C(gttoUC1 u~

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 56 of 57 Page ID 1815

X + C (D Not secure wwwstudoracom 0

CALL US NOW (85S) 978-S599 middot 1nfostudoracom

HOME SERVICES ABOUT US FAQ CONTACT US BLOC PRIVACY

Offering obligation and commitment free loan relief solutions

STUDENT LOAN FORGIVENESS INCOME BASED PAYMENTS LOAN CONSOLIDATION

We11 help you get your loans reduced forgiven o r Make monthly pdyments based on your affordability Get multiple Federal Student Loans consolidated into

discharged one low monthly payment

Talk to our experts concerning your

student loans

Studora is a pnvatefy owned company that helps consumers like you identify

government programs that fit your financial s1tuat1on Our loan experts will assist you in selecting the appropriate programs that WOltk with your income family size and

desired monthly payment We then prepare the appropriate documents for your review and submission All this f o r one low easy payment

Testimonials

Thank you f o r getting back to me quickly Youve been fabulous Thank you for the confirmation and for your help today Pass

during this whole process Is there a place I can go online that I this on to your sup that you were very professional and very

can leave a comment for your manager Youve made this Robert helpful and brought a sense of relief for me Thank you very

process so easy and answered every question my husband and I much and have a great rest of your day Kudos to you and your

have had teammoneywell spenL

Exhibit F 50

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 57 of 57 Page ID 1816

Services we offer

Stud ora offers document preparation services for all loan forgiveness consolidation and relief services to people who are unable to manage their finances Our mam aim is to

offer complete peace of mind to indiVidual unable to pay their student loan debt

we otter the folloWing document preparation services with complete professional assistance

amFinancial Review ffl Budget Planning

Toe first step to creating a flexible loan repayment plan is financial review we also help create a personal finance plan to ensure that you are able to

Our professmnals will look into your finances and design a custom manage your monthly budget in the most effective way This plan will keep

repayment plan that is affordable and easy to manage your spending to the minimum alloWing you to save more money for loan

repayment

Permanent Disability Forgiveness r-trTeacher Loan Forgiveness (5 You can get rid of your Federal Student Loan if you are permanently disabled Good news for teachers who are under the weight of a massiVe loan You can

now get $17 forgiven on your student loans

Public Service Loan Forgiveness Custom Debt Relief Plans

Want assistance with debt relief Get in touch with our experts who will help If you are a public service agent you can get rid of your loan after 120 days of design a loan repayment and relief plan for you based on your monthly

income and affordability payments

THERE ARE NO OBLIGATIONS OR COMMITMENTS

want to save thousands of dollars Fill out our form and get relief from your student loan for a more

peaceful tomorrow

Your Name

BiHHHi

Exhibit F 51

Attachment A

Page 48: JOSHUA S. MILLARD, BRIAN M. WELKE, pro hac vice · for which it has no legitimate claim. Noel is a Wyoming limited liability company that reported in a public document that its principal

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 48 of 57 Page ID 1807

AIDNEST Let us help you through this national crisis

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcom[442018 115239 AM]

43Exhibit E

httpaidnestcomservices[442018 115322 AM]

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 49 of 57 Page ID 1808

Services | AIDNEST Let us help you through this national crisis

INCOME BASED PAYMENTS

If you are suffering from a financial hardship you may be eligible for an

Income Based Payment In this repayment program you would have a

payment based on your income and family size The payment could be as

low as $000 per month with forgiveness at the end of 20-25 years

44

Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 50 of 57 Page ID 1809

L E ARN MORE

LOAN FORGIVENESS

If you have Federal Student Loans you may qualify for any of the student

loan forgiveness programs that are available to borrowers You may be

eligible for principal reduction loan forgiveness or a complete loan

discharge depending on your individual circumstance

L EARN MORE

PRIVATE STUDENT LOAN CONSOLIDATION

Much like refinancing a mortgage generally the biggest benefit of private

student loan consolidationstudent loan refinancing is a lower interest rate

httpaidnestcomservices[442018 115322 AM]

45Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 51 of 57 Page ID 1810

L E ARN MORE

(something federal consolidations do not offer)

STUDENT LOAN REHABILITATION

You can renew eligibility for new loans and grants and eliminate the loan

default by ldquorehabilitatingrdquo a defaulted loan

httpaidnestcomservices[442018 115322 AM]

46Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 52 of 57 Page ID 1811

CHE CK E L E G I B I L I T Y

WAGE GARNISHMENT

A wage garnishment is any legal procedure in which some portion of a

personrsquos earnings is required to be withheld by an employer for the

payment of a debt

L EARN MORE

With our fast friendly and professional services wersquoll be glad to help you get your student loans

reduced forgiven or completely discharged To this end wersquoll assist you in consolidating all your

student loans so yoursquoll have only one lender and yoursquoll start making one monthly payment Our

professionals will walk you through the best and most flexible repayment options and if itrsquos also

necessary varied deferment options and rehabilitation programs

httpaidnestcomservices[442018 115322 AM]

47Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 53 of 57 Page ID 1812

Services | AIDNEST Let us help you through this national crisis

Our CRM System

Our CRM is one of the most advanced in the industry and most importantly itrsquos linked directly to

the Department of Education (DOE) This keeps your personal and most confidential information

safe Furthermore because our CRM system is linked to the DOE our approval is 100 Through

our CRM we will be doing continuous monitoring of our process without losing sight of your

immediate needs ensuring that your case has the proper handling and most efficient process

httpaidnestcomservices[442018 115322 AM]

48Exhibit E

n

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 54 of 57 Page ID 1813

Services | AIDNEST Let us help you through this national crisis

R ECENT POSTS

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

ABOUT US

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcomservices[442018 115322 AM]

49Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 55 of 57 Page ID 1814

EXHIBIT F

s -

bullmiddot - ~ t ~ower Your Student Loan Pay~e~ts oday -- Students Helping Students Save Money

INCOME BASED PAJIIIJITPAIS

I C(gttoUC1 u~

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 56 of 57 Page ID 1815

X + C (D Not secure wwwstudoracom 0

CALL US NOW (85S) 978-S599 middot 1nfostudoracom

HOME SERVICES ABOUT US FAQ CONTACT US BLOC PRIVACY

Offering obligation and commitment free loan relief solutions

STUDENT LOAN FORGIVENESS INCOME BASED PAYMENTS LOAN CONSOLIDATION

We11 help you get your loans reduced forgiven o r Make monthly pdyments based on your affordability Get multiple Federal Student Loans consolidated into

discharged one low monthly payment

Talk to our experts concerning your

student loans

Studora is a pnvatefy owned company that helps consumers like you identify

government programs that fit your financial s1tuat1on Our loan experts will assist you in selecting the appropriate programs that WOltk with your income family size and

desired monthly payment We then prepare the appropriate documents for your review and submission All this f o r one low easy payment

Testimonials

Thank you f o r getting back to me quickly Youve been fabulous Thank you for the confirmation and for your help today Pass

during this whole process Is there a place I can go online that I this on to your sup that you were very professional and very

can leave a comment for your manager Youve made this Robert helpful and brought a sense of relief for me Thank you very

process so easy and answered every question my husband and I much and have a great rest of your day Kudos to you and your

have had teammoneywell spenL

Exhibit F 50

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 57 of 57 Page ID 1816

Services we offer

Stud ora offers document preparation services for all loan forgiveness consolidation and relief services to people who are unable to manage their finances Our mam aim is to

offer complete peace of mind to indiVidual unable to pay their student loan debt

we otter the folloWing document preparation services with complete professional assistance

amFinancial Review ffl Budget Planning

Toe first step to creating a flexible loan repayment plan is financial review we also help create a personal finance plan to ensure that you are able to

Our professmnals will look into your finances and design a custom manage your monthly budget in the most effective way This plan will keep

repayment plan that is affordable and easy to manage your spending to the minimum alloWing you to save more money for loan

repayment

Permanent Disability Forgiveness r-trTeacher Loan Forgiveness (5 You can get rid of your Federal Student Loan if you are permanently disabled Good news for teachers who are under the weight of a massiVe loan You can

now get $17 forgiven on your student loans

Public Service Loan Forgiveness Custom Debt Relief Plans

Want assistance with debt relief Get in touch with our experts who will help If you are a public service agent you can get rid of your loan after 120 days of design a loan repayment and relief plan for you based on your monthly

income and affordability payments

THERE ARE NO OBLIGATIONS OR COMMITMENTS

want to save thousands of dollars Fill out our form and get relief from your student loan for a more

peaceful tomorrow

Your Name

BiHHHi

Exhibit F 51

Attachment A

Page 49: JOSHUA S. MILLARD, BRIAN M. WELKE, pro hac vice · for which it has no legitimate claim. Noel is a Wyoming limited liability company that reported in a public document that its principal

httpaidnestcomservices[442018 115322 AM]

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 49 of 57 Page ID 1808

Services | AIDNEST Let us help you through this national crisis

INCOME BASED PAYMENTS

If you are suffering from a financial hardship you may be eligible for an

Income Based Payment In this repayment program you would have a

payment based on your income and family size The payment could be as

low as $000 per month with forgiveness at the end of 20-25 years

44

Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 50 of 57 Page ID 1809

L E ARN MORE

LOAN FORGIVENESS

If you have Federal Student Loans you may qualify for any of the student

loan forgiveness programs that are available to borrowers You may be

eligible for principal reduction loan forgiveness or a complete loan

discharge depending on your individual circumstance

L EARN MORE

PRIVATE STUDENT LOAN CONSOLIDATION

Much like refinancing a mortgage generally the biggest benefit of private

student loan consolidationstudent loan refinancing is a lower interest rate

httpaidnestcomservices[442018 115322 AM]

45Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 51 of 57 Page ID 1810

L E ARN MORE

(something federal consolidations do not offer)

STUDENT LOAN REHABILITATION

You can renew eligibility for new loans and grants and eliminate the loan

default by ldquorehabilitatingrdquo a defaulted loan

httpaidnestcomservices[442018 115322 AM]

46Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 52 of 57 Page ID 1811

CHE CK E L E G I B I L I T Y

WAGE GARNISHMENT

A wage garnishment is any legal procedure in which some portion of a

personrsquos earnings is required to be withheld by an employer for the

payment of a debt

L EARN MORE

With our fast friendly and professional services wersquoll be glad to help you get your student loans

reduced forgiven or completely discharged To this end wersquoll assist you in consolidating all your

student loans so yoursquoll have only one lender and yoursquoll start making one monthly payment Our

professionals will walk you through the best and most flexible repayment options and if itrsquos also

necessary varied deferment options and rehabilitation programs

httpaidnestcomservices[442018 115322 AM]

47Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 53 of 57 Page ID 1812

Services | AIDNEST Let us help you through this national crisis

Our CRM System

Our CRM is one of the most advanced in the industry and most importantly itrsquos linked directly to

the Department of Education (DOE) This keeps your personal and most confidential information

safe Furthermore because our CRM system is linked to the DOE our approval is 100 Through

our CRM we will be doing continuous monitoring of our process without losing sight of your

immediate needs ensuring that your case has the proper handling and most efficient process

httpaidnestcomservices[442018 115322 AM]

48Exhibit E

n

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 54 of 57 Page ID 1813

Services | AIDNEST Let us help you through this national crisis

R ECENT POSTS

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

ABOUT US

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcomservices[442018 115322 AM]

49Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 55 of 57 Page ID 1814

EXHIBIT F

s -

bullmiddot - ~ t ~ower Your Student Loan Pay~e~ts oday -- Students Helping Students Save Money

INCOME BASED PAJIIIJITPAIS

I C(gttoUC1 u~

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 56 of 57 Page ID 1815

X + C (D Not secure wwwstudoracom 0

CALL US NOW (85S) 978-S599 middot 1nfostudoracom

HOME SERVICES ABOUT US FAQ CONTACT US BLOC PRIVACY

Offering obligation and commitment free loan relief solutions

STUDENT LOAN FORGIVENESS INCOME BASED PAYMENTS LOAN CONSOLIDATION

We11 help you get your loans reduced forgiven o r Make monthly pdyments based on your affordability Get multiple Federal Student Loans consolidated into

discharged one low monthly payment

Talk to our experts concerning your

student loans

Studora is a pnvatefy owned company that helps consumers like you identify

government programs that fit your financial s1tuat1on Our loan experts will assist you in selecting the appropriate programs that WOltk with your income family size and

desired monthly payment We then prepare the appropriate documents for your review and submission All this f o r one low easy payment

Testimonials

Thank you f o r getting back to me quickly Youve been fabulous Thank you for the confirmation and for your help today Pass

during this whole process Is there a place I can go online that I this on to your sup that you were very professional and very

can leave a comment for your manager Youve made this Robert helpful and brought a sense of relief for me Thank you very

process so easy and answered every question my husband and I much and have a great rest of your day Kudos to you and your

have had teammoneywell spenL

Exhibit F 50

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 57 of 57 Page ID 1816

Services we offer

Stud ora offers document preparation services for all loan forgiveness consolidation and relief services to people who are unable to manage their finances Our mam aim is to

offer complete peace of mind to indiVidual unable to pay their student loan debt

we otter the folloWing document preparation services with complete professional assistance

amFinancial Review ffl Budget Planning

Toe first step to creating a flexible loan repayment plan is financial review we also help create a personal finance plan to ensure that you are able to

Our professmnals will look into your finances and design a custom manage your monthly budget in the most effective way This plan will keep

repayment plan that is affordable and easy to manage your spending to the minimum alloWing you to save more money for loan

repayment

Permanent Disability Forgiveness r-trTeacher Loan Forgiveness (5 You can get rid of your Federal Student Loan if you are permanently disabled Good news for teachers who are under the weight of a massiVe loan You can

now get $17 forgiven on your student loans

Public Service Loan Forgiveness Custom Debt Relief Plans

Want assistance with debt relief Get in touch with our experts who will help If you are a public service agent you can get rid of your loan after 120 days of design a loan repayment and relief plan for you based on your monthly

income and affordability payments

THERE ARE NO OBLIGATIONS OR COMMITMENTS

want to save thousands of dollars Fill out our form and get relief from your student loan for a more

peaceful tomorrow

Your Name

BiHHHi

Exhibit F 51

Attachment A

Page 50: JOSHUA S. MILLARD, BRIAN M. WELKE, pro hac vice · for which it has no legitimate claim. Noel is a Wyoming limited liability company that reported in a public document that its principal

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 50 of 57 Page ID 1809

L E ARN MORE

LOAN FORGIVENESS

If you have Federal Student Loans you may qualify for any of the student

loan forgiveness programs that are available to borrowers You may be

eligible for principal reduction loan forgiveness or a complete loan

discharge depending on your individual circumstance

L EARN MORE

PRIVATE STUDENT LOAN CONSOLIDATION

Much like refinancing a mortgage generally the biggest benefit of private

student loan consolidationstudent loan refinancing is a lower interest rate

httpaidnestcomservices[442018 115322 AM]

45Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 51 of 57 Page ID 1810

L E ARN MORE

(something federal consolidations do not offer)

STUDENT LOAN REHABILITATION

You can renew eligibility for new loans and grants and eliminate the loan

default by ldquorehabilitatingrdquo a defaulted loan

httpaidnestcomservices[442018 115322 AM]

46Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 52 of 57 Page ID 1811

CHE CK E L E G I B I L I T Y

WAGE GARNISHMENT

A wage garnishment is any legal procedure in which some portion of a

personrsquos earnings is required to be withheld by an employer for the

payment of a debt

L EARN MORE

With our fast friendly and professional services wersquoll be glad to help you get your student loans

reduced forgiven or completely discharged To this end wersquoll assist you in consolidating all your

student loans so yoursquoll have only one lender and yoursquoll start making one monthly payment Our

professionals will walk you through the best and most flexible repayment options and if itrsquos also

necessary varied deferment options and rehabilitation programs

httpaidnestcomservices[442018 115322 AM]

47Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 53 of 57 Page ID 1812

Services | AIDNEST Let us help you through this national crisis

Our CRM System

Our CRM is one of the most advanced in the industry and most importantly itrsquos linked directly to

the Department of Education (DOE) This keeps your personal and most confidential information

safe Furthermore because our CRM system is linked to the DOE our approval is 100 Through

our CRM we will be doing continuous monitoring of our process without losing sight of your

immediate needs ensuring that your case has the proper handling and most efficient process

httpaidnestcomservices[442018 115322 AM]

48Exhibit E

n

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 54 of 57 Page ID 1813

Services | AIDNEST Let us help you through this national crisis

R ECENT POSTS

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

ABOUT US

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcomservices[442018 115322 AM]

49Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 55 of 57 Page ID 1814

EXHIBIT F

s -

bullmiddot - ~ t ~ower Your Student Loan Pay~e~ts oday -- Students Helping Students Save Money

INCOME BASED PAJIIIJITPAIS

I C(gttoUC1 u~

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 56 of 57 Page ID 1815

X + C (D Not secure wwwstudoracom 0

CALL US NOW (85S) 978-S599 middot 1nfostudoracom

HOME SERVICES ABOUT US FAQ CONTACT US BLOC PRIVACY

Offering obligation and commitment free loan relief solutions

STUDENT LOAN FORGIVENESS INCOME BASED PAYMENTS LOAN CONSOLIDATION

We11 help you get your loans reduced forgiven o r Make monthly pdyments based on your affordability Get multiple Federal Student Loans consolidated into

discharged one low monthly payment

Talk to our experts concerning your

student loans

Studora is a pnvatefy owned company that helps consumers like you identify

government programs that fit your financial s1tuat1on Our loan experts will assist you in selecting the appropriate programs that WOltk with your income family size and

desired monthly payment We then prepare the appropriate documents for your review and submission All this f o r one low easy payment

Testimonials

Thank you f o r getting back to me quickly Youve been fabulous Thank you for the confirmation and for your help today Pass

during this whole process Is there a place I can go online that I this on to your sup that you were very professional and very

can leave a comment for your manager Youve made this Robert helpful and brought a sense of relief for me Thank you very

process so easy and answered every question my husband and I much and have a great rest of your day Kudos to you and your

have had teammoneywell spenL

Exhibit F 50

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 57 of 57 Page ID 1816

Services we offer

Stud ora offers document preparation services for all loan forgiveness consolidation and relief services to people who are unable to manage their finances Our mam aim is to

offer complete peace of mind to indiVidual unable to pay their student loan debt

we otter the folloWing document preparation services with complete professional assistance

amFinancial Review ffl Budget Planning

Toe first step to creating a flexible loan repayment plan is financial review we also help create a personal finance plan to ensure that you are able to

Our professmnals will look into your finances and design a custom manage your monthly budget in the most effective way This plan will keep

repayment plan that is affordable and easy to manage your spending to the minimum alloWing you to save more money for loan

repayment

Permanent Disability Forgiveness r-trTeacher Loan Forgiveness (5 You can get rid of your Federal Student Loan if you are permanently disabled Good news for teachers who are under the weight of a massiVe loan You can

now get $17 forgiven on your student loans

Public Service Loan Forgiveness Custom Debt Relief Plans

Want assistance with debt relief Get in touch with our experts who will help If you are a public service agent you can get rid of your loan after 120 days of design a loan repayment and relief plan for you based on your monthly

income and affordability payments

THERE ARE NO OBLIGATIONS OR COMMITMENTS

want to save thousands of dollars Fill out our form and get relief from your student loan for a more

peaceful tomorrow

Your Name

BiHHHi

Exhibit F 51

Attachment A

Page 51: JOSHUA S. MILLARD, BRIAN M. WELKE, pro hac vice · for which it has no legitimate claim. Noel is a Wyoming limited liability company that reported in a public document that its principal

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 51 of 57 Page ID 1810

L E ARN MORE

(something federal consolidations do not offer)

STUDENT LOAN REHABILITATION

You can renew eligibility for new loans and grants and eliminate the loan

default by ldquorehabilitatingrdquo a defaulted loan

httpaidnestcomservices[442018 115322 AM]

46Exhibit E

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 52 of 57 Page ID 1811

CHE CK E L E G I B I L I T Y

WAGE GARNISHMENT

A wage garnishment is any legal procedure in which some portion of a

personrsquos earnings is required to be withheld by an employer for the

payment of a debt

L EARN MORE

With our fast friendly and professional services wersquoll be glad to help you get your student loans

reduced forgiven or completely discharged To this end wersquoll assist you in consolidating all your

student loans so yoursquoll have only one lender and yoursquoll start making one monthly payment Our

professionals will walk you through the best and most flexible repayment options and if itrsquos also

necessary varied deferment options and rehabilitation programs

httpaidnestcomservices[442018 115322 AM]

47Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 53 of 57 Page ID 1812

Services | AIDNEST Let us help you through this national crisis

Our CRM System

Our CRM is one of the most advanced in the industry and most importantly itrsquos linked directly to

the Department of Education (DOE) This keeps your personal and most confidential information

safe Furthermore because our CRM system is linked to the DOE our approval is 100 Through

our CRM we will be doing continuous monitoring of our process without losing sight of your

immediate needs ensuring that your case has the proper handling and most efficient process

httpaidnestcomservices[442018 115322 AM]

48Exhibit E

n

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 54 of 57 Page ID 1813

Services | AIDNEST Let us help you through this national crisis

R ECENT POSTS

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

ABOUT US

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcomservices[442018 115322 AM]

49Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 55 of 57 Page ID 1814

EXHIBIT F

s -

bullmiddot - ~ t ~ower Your Student Loan Pay~e~ts oday -- Students Helping Students Save Money

INCOME BASED PAJIIIJITPAIS

I C(gttoUC1 u~

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 56 of 57 Page ID 1815

X + C (D Not secure wwwstudoracom 0

CALL US NOW (85S) 978-S599 middot 1nfostudoracom

HOME SERVICES ABOUT US FAQ CONTACT US BLOC PRIVACY

Offering obligation and commitment free loan relief solutions

STUDENT LOAN FORGIVENESS INCOME BASED PAYMENTS LOAN CONSOLIDATION

We11 help you get your loans reduced forgiven o r Make monthly pdyments based on your affordability Get multiple Federal Student Loans consolidated into

discharged one low monthly payment

Talk to our experts concerning your

student loans

Studora is a pnvatefy owned company that helps consumers like you identify

government programs that fit your financial s1tuat1on Our loan experts will assist you in selecting the appropriate programs that WOltk with your income family size and

desired monthly payment We then prepare the appropriate documents for your review and submission All this f o r one low easy payment

Testimonials

Thank you f o r getting back to me quickly Youve been fabulous Thank you for the confirmation and for your help today Pass

during this whole process Is there a place I can go online that I this on to your sup that you were very professional and very

can leave a comment for your manager Youve made this Robert helpful and brought a sense of relief for me Thank you very

process so easy and answered every question my husband and I much and have a great rest of your day Kudos to you and your

have had teammoneywell spenL

Exhibit F 50

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 57 of 57 Page ID 1816

Services we offer

Stud ora offers document preparation services for all loan forgiveness consolidation and relief services to people who are unable to manage their finances Our mam aim is to

offer complete peace of mind to indiVidual unable to pay their student loan debt

we otter the folloWing document preparation services with complete professional assistance

amFinancial Review ffl Budget Planning

Toe first step to creating a flexible loan repayment plan is financial review we also help create a personal finance plan to ensure that you are able to

Our professmnals will look into your finances and design a custom manage your monthly budget in the most effective way This plan will keep

repayment plan that is affordable and easy to manage your spending to the minimum alloWing you to save more money for loan

repayment

Permanent Disability Forgiveness r-trTeacher Loan Forgiveness (5 You can get rid of your Federal Student Loan if you are permanently disabled Good news for teachers who are under the weight of a massiVe loan You can

now get $17 forgiven on your student loans

Public Service Loan Forgiveness Custom Debt Relief Plans

Want assistance with debt relief Get in touch with our experts who will help If you are a public service agent you can get rid of your loan after 120 days of design a loan repayment and relief plan for you based on your monthly

income and affordability payments

THERE ARE NO OBLIGATIONS OR COMMITMENTS

want to save thousands of dollars Fill out our form and get relief from your student loan for a more

peaceful tomorrow

Your Name

BiHHHi

Exhibit F 51

Attachment A

Page 52: JOSHUA S. MILLARD, BRIAN M. WELKE, pro hac vice · for which it has no legitimate claim. Noel is a Wyoming limited liability company that reported in a public document that its principal

Services | AIDNEST Let us help you through this national crisis

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 52 of 57 Page ID 1811

CHE CK E L E G I B I L I T Y

WAGE GARNISHMENT

A wage garnishment is any legal procedure in which some portion of a

personrsquos earnings is required to be withheld by an employer for the

payment of a debt

L EARN MORE

With our fast friendly and professional services wersquoll be glad to help you get your student loans

reduced forgiven or completely discharged To this end wersquoll assist you in consolidating all your

student loans so yoursquoll have only one lender and yoursquoll start making one monthly payment Our

professionals will walk you through the best and most flexible repayment options and if itrsquos also

necessary varied deferment options and rehabilitation programs

httpaidnestcomservices[442018 115322 AM]

47Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 53 of 57 Page ID 1812

Services | AIDNEST Let us help you through this national crisis

Our CRM System

Our CRM is one of the most advanced in the industry and most importantly itrsquos linked directly to

the Department of Education (DOE) This keeps your personal and most confidential information

safe Furthermore because our CRM system is linked to the DOE our approval is 100 Through

our CRM we will be doing continuous monitoring of our process without losing sight of your

immediate needs ensuring that your case has the proper handling and most efficient process

httpaidnestcomservices[442018 115322 AM]

48Exhibit E

n

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 54 of 57 Page ID 1813

Services | AIDNEST Let us help you through this national crisis

R ECENT POSTS

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

ABOUT US

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcomservices[442018 115322 AM]

49Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 55 of 57 Page ID 1814

EXHIBIT F

s -

bullmiddot - ~ t ~ower Your Student Loan Pay~e~ts oday -- Students Helping Students Save Money

INCOME BASED PAJIIIJITPAIS

I C(gttoUC1 u~

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 56 of 57 Page ID 1815

X + C (D Not secure wwwstudoracom 0

CALL US NOW (85S) 978-S599 middot 1nfostudoracom

HOME SERVICES ABOUT US FAQ CONTACT US BLOC PRIVACY

Offering obligation and commitment free loan relief solutions

STUDENT LOAN FORGIVENESS INCOME BASED PAYMENTS LOAN CONSOLIDATION

We11 help you get your loans reduced forgiven o r Make monthly pdyments based on your affordability Get multiple Federal Student Loans consolidated into

discharged one low monthly payment

Talk to our experts concerning your

student loans

Studora is a pnvatefy owned company that helps consumers like you identify

government programs that fit your financial s1tuat1on Our loan experts will assist you in selecting the appropriate programs that WOltk with your income family size and

desired monthly payment We then prepare the appropriate documents for your review and submission All this f o r one low easy payment

Testimonials

Thank you f o r getting back to me quickly Youve been fabulous Thank you for the confirmation and for your help today Pass

during this whole process Is there a place I can go online that I this on to your sup that you were very professional and very

can leave a comment for your manager Youve made this Robert helpful and brought a sense of relief for me Thank you very

process so easy and answered every question my husband and I much and have a great rest of your day Kudos to you and your

have had teammoneywell spenL

Exhibit F 50

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 57 of 57 Page ID 1816

Services we offer

Stud ora offers document preparation services for all loan forgiveness consolidation and relief services to people who are unable to manage their finances Our mam aim is to

offer complete peace of mind to indiVidual unable to pay their student loan debt

we otter the folloWing document preparation services with complete professional assistance

amFinancial Review ffl Budget Planning

Toe first step to creating a flexible loan repayment plan is financial review we also help create a personal finance plan to ensure that you are able to

Our professmnals will look into your finances and design a custom manage your monthly budget in the most effective way This plan will keep

repayment plan that is affordable and easy to manage your spending to the minimum alloWing you to save more money for loan

repayment

Permanent Disability Forgiveness r-trTeacher Loan Forgiveness (5 You can get rid of your Federal Student Loan if you are permanently disabled Good news for teachers who are under the weight of a massiVe loan You can

now get $17 forgiven on your student loans

Public Service Loan Forgiveness Custom Debt Relief Plans

Want assistance with debt relief Get in touch with our experts who will help If you are a public service agent you can get rid of your loan after 120 days of design a loan repayment and relief plan for you based on your monthly

income and affordability payments

THERE ARE NO OBLIGATIONS OR COMMITMENTS

want to save thousands of dollars Fill out our form and get relief from your student loan for a more

peaceful tomorrow

Your Name

BiHHHi

Exhibit F 51

Attachment A

Page 53: JOSHUA S. MILLARD, BRIAN M. WELKE, pro hac vice · for which it has no legitimate claim. Noel is a Wyoming limited liability company that reported in a public document that its principal

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 53 of 57 Page ID 1812

Services | AIDNEST Let us help you through this national crisis

Our CRM System

Our CRM is one of the most advanced in the industry and most importantly itrsquos linked directly to

the Department of Education (DOE) This keeps your personal and most confidential information

safe Furthermore because our CRM system is linked to the DOE our approval is 100 Through

our CRM we will be doing continuous monitoring of our process without losing sight of your

immediate needs ensuring that your case has the proper handling and most efficient process

httpaidnestcomservices[442018 115322 AM]

48Exhibit E

n

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 54 of 57 Page ID 1813

Services | AIDNEST Let us help you through this national crisis

R ECENT POSTS

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

ABOUT US

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcomservices[442018 115322 AM]

49Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 55 of 57 Page ID 1814

EXHIBIT F

s -

bullmiddot - ~ t ~ower Your Student Loan Pay~e~ts oday -- Students Helping Students Save Money

INCOME BASED PAJIIIJITPAIS

I C(gttoUC1 u~

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 56 of 57 Page ID 1815

X + C (D Not secure wwwstudoracom 0

CALL US NOW (85S) 978-S599 middot 1nfostudoracom

HOME SERVICES ABOUT US FAQ CONTACT US BLOC PRIVACY

Offering obligation and commitment free loan relief solutions

STUDENT LOAN FORGIVENESS INCOME BASED PAYMENTS LOAN CONSOLIDATION

We11 help you get your loans reduced forgiven o r Make monthly pdyments based on your affordability Get multiple Federal Student Loans consolidated into

discharged one low monthly payment

Talk to our experts concerning your

student loans

Studora is a pnvatefy owned company that helps consumers like you identify

government programs that fit your financial s1tuat1on Our loan experts will assist you in selecting the appropriate programs that WOltk with your income family size and

desired monthly payment We then prepare the appropriate documents for your review and submission All this f o r one low easy payment

Testimonials

Thank you f o r getting back to me quickly Youve been fabulous Thank you for the confirmation and for your help today Pass

during this whole process Is there a place I can go online that I this on to your sup that you were very professional and very

can leave a comment for your manager Youve made this Robert helpful and brought a sense of relief for me Thank you very

process so easy and answered every question my husband and I much and have a great rest of your day Kudos to you and your

have had teammoneywell spenL

Exhibit F 50

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 57 of 57 Page ID 1816

Services we offer

Stud ora offers document preparation services for all loan forgiveness consolidation and relief services to people who are unable to manage their finances Our mam aim is to

offer complete peace of mind to indiVidual unable to pay their student loan debt

we otter the folloWing document preparation services with complete professional assistance

amFinancial Review ffl Budget Planning

Toe first step to creating a flexible loan repayment plan is financial review we also help create a personal finance plan to ensure that you are able to

Our professmnals will look into your finances and design a custom manage your monthly budget in the most effective way This plan will keep

repayment plan that is affordable and easy to manage your spending to the minimum alloWing you to save more money for loan

repayment

Permanent Disability Forgiveness r-trTeacher Loan Forgiveness (5 You can get rid of your Federal Student Loan if you are permanently disabled Good news for teachers who are under the weight of a massiVe loan You can

now get $17 forgiven on your student loans

Public Service Loan Forgiveness Custom Debt Relief Plans

Want assistance with debt relief Get in touch with our experts who will help If you are a public service agent you can get rid of your loan after 120 days of design a loan repayment and relief plan for you based on your monthly

income and affordability payments

THERE ARE NO OBLIGATIONS OR COMMITMENTS

want to save thousands of dollars Fill out our form and get relief from your student loan for a more

peaceful tomorrow

Your Name

BiHHHi

Exhibit F 51

Attachment A

Page 54: JOSHUA S. MILLARD, BRIAN M. WELKE, pro hac vice · for which it has no legitimate claim. Noel is a Wyoming limited liability company that reported in a public document that its principal

n

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 54 of 57 Page ID 1813

Services | AIDNEST Let us help you through this national crisis

R ECENT POSTS

How a Change of City can Change your Life

(and Loan)

The Argument for Tuition-Free College

CONTACT I N FO

infoaidnestcom

855-580-NEST (6378)

18100 Von Karman Ave Suite 850

Irvine CA 92612

1651 E Fourth St

Santa Ana CA 92701

ABOUT US

We stand by our consultation and quote We

are so sure and confident about our services

and offers that they are all 100 money back

guarantee risk free ndash if we donrsquot do what we

promise yoursquoll get your money back

FOLLOW US

copy 2018 AIDNEST Let us help you through this national

crisis

httpaidnestcomservices[442018 115322 AM]

49Exhibit E

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 55 of 57 Page ID 1814

EXHIBIT F

s -

bullmiddot - ~ t ~ower Your Student Loan Pay~e~ts oday -- Students Helping Students Save Money

INCOME BASED PAJIIIJITPAIS

I C(gttoUC1 u~

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 56 of 57 Page ID 1815

X + C (D Not secure wwwstudoracom 0

CALL US NOW (85S) 978-S599 middot 1nfostudoracom

HOME SERVICES ABOUT US FAQ CONTACT US BLOC PRIVACY

Offering obligation and commitment free loan relief solutions

STUDENT LOAN FORGIVENESS INCOME BASED PAYMENTS LOAN CONSOLIDATION

We11 help you get your loans reduced forgiven o r Make monthly pdyments based on your affordability Get multiple Federal Student Loans consolidated into

discharged one low monthly payment

Talk to our experts concerning your

student loans

Studora is a pnvatefy owned company that helps consumers like you identify

government programs that fit your financial s1tuat1on Our loan experts will assist you in selecting the appropriate programs that WOltk with your income family size and

desired monthly payment We then prepare the appropriate documents for your review and submission All this f o r one low easy payment

Testimonials

Thank you f o r getting back to me quickly Youve been fabulous Thank you for the confirmation and for your help today Pass

during this whole process Is there a place I can go online that I this on to your sup that you were very professional and very

can leave a comment for your manager Youve made this Robert helpful and brought a sense of relief for me Thank you very

process so easy and answered every question my husband and I much and have a great rest of your day Kudos to you and your

have had teammoneywell spenL

Exhibit F 50

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 57 of 57 Page ID 1816

Services we offer

Stud ora offers document preparation services for all loan forgiveness consolidation and relief services to people who are unable to manage their finances Our mam aim is to

offer complete peace of mind to indiVidual unable to pay their student loan debt

we otter the folloWing document preparation services with complete professional assistance

amFinancial Review ffl Budget Planning

Toe first step to creating a flexible loan repayment plan is financial review we also help create a personal finance plan to ensure that you are able to

Our professmnals will look into your finances and design a custom manage your monthly budget in the most effective way This plan will keep

repayment plan that is affordable and easy to manage your spending to the minimum alloWing you to save more money for loan

repayment

Permanent Disability Forgiveness r-trTeacher Loan Forgiveness (5 You can get rid of your Federal Student Loan if you are permanently disabled Good news for teachers who are under the weight of a massiVe loan You can

now get $17 forgiven on your student loans

Public Service Loan Forgiveness Custom Debt Relief Plans

Want assistance with debt relief Get in touch with our experts who will help If you are a public service agent you can get rid of your loan after 120 days of design a loan repayment and relief plan for you based on your monthly

income and affordability payments

THERE ARE NO OBLIGATIONS OR COMMITMENTS

want to save thousands of dollars Fill out our form and get relief from your student loan for a more

peaceful tomorrow

Your Name

BiHHHi

Exhibit F 51

Attachment A

Page 55: JOSHUA S. MILLARD, BRIAN M. WELKE, pro hac vice · for which it has no legitimate claim. Noel is a Wyoming limited liability company that reported in a public document that its principal

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 55 of 57 Page ID 1814

EXHIBIT F

s -

bullmiddot - ~ t ~ower Your Student Loan Pay~e~ts oday -- Students Helping Students Save Money

INCOME BASED PAJIIIJITPAIS

I C(gttoUC1 u~

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 56 of 57 Page ID 1815

X + C (D Not secure wwwstudoracom 0

CALL US NOW (85S) 978-S599 middot 1nfostudoracom

HOME SERVICES ABOUT US FAQ CONTACT US BLOC PRIVACY

Offering obligation and commitment free loan relief solutions

STUDENT LOAN FORGIVENESS INCOME BASED PAYMENTS LOAN CONSOLIDATION

We11 help you get your loans reduced forgiven o r Make monthly pdyments based on your affordability Get multiple Federal Student Loans consolidated into

discharged one low monthly payment

Talk to our experts concerning your

student loans

Studora is a pnvatefy owned company that helps consumers like you identify

government programs that fit your financial s1tuat1on Our loan experts will assist you in selecting the appropriate programs that WOltk with your income family size and

desired monthly payment We then prepare the appropriate documents for your review and submission All this f o r one low easy payment

Testimonials

Thank you f o r getting back to me quickly Youve been fabulous Thank you for the confirmation and for your help today Pass

during this whole process Is there a place I can go online that I this on to your sup that you were very professional and very

can leave a comment for your manager Youve made this Robert helpful and brought a sense of relief for me Thank you very

process so easy and answered every question my husband and I much and have a great rest of your day Kudos to you and your

have had teammoneywell spenL

Exhibit F 50

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 57 of 57 Page ID 1816

Services we offer

Stud ora offers document preparation services for all loan forgiveness consolidation and relief services to people who are unable to manage their finances Our mam aim is to

offer complete peace of mind to indiVidual unable to pay their student loan debt

we otter the folloWing document preparation services with complete professional assistance

amFinancial Review ffl Budget Planning

Toe first step to creating a flexible loan repayment plan is financial review we also help create a personal finance plan to ensure that you are able to

Our professmnals will look into your finances and design a custom manage your monthly budget in the most effective way This plan will keep

repayment plan that is affordable and easy to manage your spending to the minimum alloWing you to save more money for loan

repayment

Permanent Disability Forgiveness r-trTeacher Loan Forgiveness (5 You can get rid of your Federal Student Loan if you are permanently disabled Good news for teachers who are under the weight of a massiVe loan You can

now get $17 forgiven on your student loans

Public Service Loan Forgiveness Custom Debt Relief Plans

Want assistance with debt relief Get in touch with our experts who will help If you are a public service agent you can get rid of your loan after 120 days of design a loan repayment and relief plan for you based on your monthly

income and affordability payments

THERE ARE NO OBLIGATIONS OR COMMITMENTS

want to save thousands of dollars Fill out our form and get relief from your student loan for a more

peaceful tomorrow

Your Name

BiHHHi

Exhibit F 51

Attachment A

Page 56: JOSHUA S. MILLARD, BRIAN M. WELKE, pro hac vice · for which it has no legitimate claim. Noel is a Wyoming limited liability company that reported in a public document that its principal

s -

bullmiddot - ~ t ~ower Your Student Loan Pay~e~ts oday -- Students Helping Students Save Money

INCOME BASED PAJIIIJITPAIS

I C(gttoUC1 u~

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 56 of 57 Page ID 1815

X + C (D Not secure wwwstudoracom 0

CALL US NOW (85S) 978-S599 middot 1nfostudoracom

HOME SERVICES ABOUT US FAQ CONTACT US BLOC PRIVACY

Offering obligation and commitment free loan relief solutions

STUDENT LOAN FORGIVENESS INCOME BASED PAYMENTS LOAN CONSOLIDATION

We11 help you get your loans reduced forgiven o r Make monthly pdyments based on your affordability Get multiple Federal Student Loans consolidated into

discharged one low monthly payment

Talk to our experts concerning your

student loans

Studora is a pnvatefy owned company that helps consumers like you identify

government programs that fit your financial s1tuat1on Our loan experts will assist you in selecting the appropriate programs that WOltk with your income family size and

desired monthly payment We then prepare the appropriate documents for your review and submission All this f o r one low easy payment

Testimonials

Thank you f o r getting back to me quickly Youve been fabulous Thank you for the confirmation and for your help today Pass

during this whole process Is there a place I can go online that I this on to your sup that you were very professional and very

can leave a comment for your manager Youve made this Robert helpful and brought a sense of relief for me Thank you very

process so easy and answered every question my husband and I much and have a great rest of your day Kudos to you and your

have had teammoneywell spenL

Exhibit F 50

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 57 of 57 Page ID 1816

Services we offer

Stud ora offers document preparation services for all loan forgiveness consolidation and relief services to people who are unable to manage their finances Our mam aim is to

offer complete peace of mind to indiVidual unable to pay their student loan debt

we otter the folloWing document preparation services with complete professional assistance

amFinancial Review ffl Budget Planning

Toe first step to creating a flexible loan repayment plan is financial review we also help create a personal finance plan to ensure that you are able to

Our professmnals will look into your finances and design a custom manage your monthly budget in the most effective way This plan will keep

repayment plan that is affordable and easy to manage your spending to the minimum alloWing you to save more money for loan

repayment

Permanent Disability Forgiveness r-trTeacher Loan Forgiveness (5 You can get rid of your Federal Student Loan if you are permanently disabled Good news for teachers who are under the weight of a massiVe loan You can

now get $17 forgiven on your student loans

Public Service Loan Forgiveness Custom Debt Relief Plans

Want assistance with debt relief Get in touch with our experts who will help If you are a public service agent you can get rid of your loan after 120 days of design a loan repayment and relief plan for you based on your monthly

income and affordability payments

THERE ARE NO OBLIGATIONS OR COMMITMENTS

want to save thousands of dollars Fill out our form and get relief from your student loan for a more

peaceful tomorrow

Your Name

BiHHHi

Exhibit F 51

Attachment A

Page 57: JOSHUA S. MILLARD, BRIAN M. WELKE, pro hac vice · for which it has no legitimate claim. Noel is a Wyoming limited liability company that reported in a public document that its principal

Case 818-cv-01987-JLS-KES Document 50-1 Filed 020519 Page 57 of 57 Page ID 1816

Services we offer

Stud ora offers document preparation services for all loan forgiveness consolidation and relief services to people who are unable to manage their finances Our mam aim is to

offer complete peace of mind to indiVidual unable to pay their student loan debt

we otter the folloWing document preparation services with complete professional assistance

amFinancial Review ffl Budget Planning

Toe first step to creating a flexible loan repayment plan is financial review we also help create a personal finance plan to ensure that you are able to

Our professmnals will look into your finances and design a custom manage your monthly budget in the most effective way This plan will keep

repayment plan that is affordable and easy to manage your spending to the minimum alloWing you to save more money for loan

repayment

Permanent Disability Forgiveness r-trTeacher Loan Forgiveness (5 You can get rid of your Federal Student Loan if you are permanently disabled Good news for teachers who are under the weight of a massiVe loan You can

now get $17 forgiven on your student loans

Public Service Loan Forgiveness Custom Debt Relief Plans

Want assistance with debt relief Get in touch with our experts who will help If you are a public service agent you can get rid of your loan after 120 days of design a loan repayment and relief plan for you based on your monthly

income and affordability payments

THERE ARE NO OBLIGATIONS OR COMMITMENTS

want to save thousands of dollars Fill out our form and get relief from your student loan for a more

peaceful tomorrow

Your Name

BiHHHi

Exhibit F 51

Attachment A