Student Debt Doctor Complaint for Permanent Injunction and ...
Sealed
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
_,,,,,,__~
FU.Eu by______D.C.
OCT 0 2 2017
FEDERAL TRADE COMMISSION,
Plaintiff,
v.
STUDENT DEBT DOCTOR LLC, a Florida limited liability company,
and
GARY BRENT WHITE, JR., individually and as an officer ofDefendant Student Debt Doctor LLC,
Defendants.
Case NoC. -f-\"---D-II\tlITROULE~
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COMPLAINT FOR PERMANENT INJUNCTION AND OTHER EQUITABLE RELIEF Plaintiff, the Federal Trade Comntission (".FTC"), for its Complaint alleges: J. The FTC brings this actjon under Section 13(b) of the Federal Trade
ComJTrission Act ("FTC Act"), 15 1LS.C. ? 53(b), and the Telemarketing and Consumer Fraud and Abuse Prevention Act ("Telemarketing Act"), 15 U.S.C. ?? 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 mornes, and other equitable
relief for Defendants' acts or practices in violation of Section 5(a) of the FTC Act, 15 U.S.C. ? 45(a), and the FTC's Telemarketing Sales Rule ("TSR"), 16 C.F.R. Part 310, in connection with Defendants' deceptive marketing and :;ale of student loan debt relief ~rvi~s.
JURISDICTION AND VENUE
2. This Court has subject-matter jurisdiction pursuant to 28 U.S.C. ?? 1331, 13J7(a), and 1345, an ................
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