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Sealed FILED by D.C.

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

APR 0 7 m
CASE NO-

SECURITIES AND EXCHANGE COMMISSION,

1 X

A _, O f\ A 2 06TEVEN M. LARIMORE -c n U f r U Rclerk u-s DIST-CT-

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v J^ s. d. of fla. - miami

Plaintiff,
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CfV)-MIDDLEBROOKS
) )

.ICS ENTERPRISES, INC., d/b/a JCS ENTERPRISES SERVICES, INC., T.B.T.I. INC., JOSEPH SIGNORE, and PAUL L. SCHUMACK, II,

) ) ) )
) ) )

UNDER SEAL

Defendants.

)
COMPLAINT FOR INJUNCTIVE AND OTHER RELIEF

Plaintiff Securities and Exchange Commission alleges:

1.

The Commission brings this action to enjoin two Florida companies and their

principals from continuing to defraud investors through the ongoing sale of securities involving
investments in Virtual Concierge machines ("VCMs"") in violation of the anti-fraud and registration provisions of the federal securities laws. 2. From at least as early as 2011, JCS Enterprises. Inc. d/b/a JCS Enterprises

Services, Inc. ("JCS*'), T.B.T.I. Inc. ("T.B.T.I."), through and at the direction of their respective

principals Joseph Signore, and Paul L. Schumack, II, fraudulently raised at least $40 million
from hundreds of investors nationwide. The Defendants guaranteed exorbitant returns, ranging
from 80 to 120% annually and up to 500% over the life of a three- or four-year investment

contract, by guaranteeing a S300 monthly return for the life of the contract.
3. Signore and Schumack represented to investors their money would be invested in Participation in the Virtual Concierge program entailed

the Virtual Concierge program.

purchasing a VCM. The VCMs are free-standing or wall-mounted ATM-like machines the
Defendants promised to place at various locations (e.g. hotels, airports, stadiums), to enable
businesses to advertise their products and services via touch screen and printable tickets or
coupons.

4.

The Defendants touted advertising revenue as the driving force backing the

guaranteed rate ofreturn. They promised to locate, place, and manage the VCMs to generate the purported advertising revenue to pay investors their returns. Investors did not have to do
anything to earn their money.

5.

Signore and Schumack touted the VCMs as a revolutionary product and a fail-safe

investment. In reality, however, they and their companies operated a Ponzi scheme, where,

through numerous misrepresentations and omissions, they used new investor funds to make payments to earlier investors. Advertising revenue was indeed miniscule in comparison to
investor funds.

6.

Like all Ponzi schemes, this one ultimately collapsed once new investor funds

dried up. The majority of investors stopped receiving their monthly payments January 2014.
Nevertheless, during this time frame, the Defendants continued to solicit investors. 7. Furthermore, throughout the fraud, the Defendants also siphoned off significant

sums of investor money for their own use, including diverting money to themselves and family members, and using money to fund other business ventures, for recreational purposes, and to
satisfy financial obligations.

8.

Through their conduct, JCS, T.B.T.I., Signore and Schumack each have violated

and continue to violate the anti-fraud and registration provisions of the federal securities laws.

9.

The Commission seeks an order permanently enjoining the Defendants from

further violations of Sections 5(a) and (c) and 17(a) of the Securities Act of 1933 ("Securities

Act") [15 U.S.C. 77e(a), 77e(c) and 77q(a)], and Section 10(b) of the Securities Exchange Act of 1934 ("Exchange Act") [15 U.S.C. 78j(b)], and Rule 10b-5 thereunder [17 C.F.R. 240.10b5]-

10.

The Commission also seeks disgorgement of all ill-gotten gains, including

prejudgment interest thereon; anorder directing the Defendants to pay civil money penalties; and
any other relief that may be necessary and appropriate.
DEFENDANTS

11.

Signore, 49, is Chairman and President of JCS, and resides in West Palm Beach,

Florida. On December 16, 2003, Signore voluntarily petitioned for bankruptcy under Chapter 7 of the United States Bankruptcy Code in the District of New Jersey, and was discharged from

this bankruptcy on or about March 4, 2004. On February 10, 2006, Signore was adjudicated

guilty per a plea agreement to theft charges emanating from two separate indictments brought by
the State of New Jersey. Signore first pled guilty to charges he failed to share the proceeds from
the sale of an automobile with a charity to which he was legally obligated. Signore had to pay
$11,475 in restitution to the National Multiple Sclerosis Society, as well as nominal amounts to

other organizations, and fees. Signore also pled guilty to unlawfully obtaining vehicles owned

by Sears Roebuck & Company, selling the vehicles, and retaining the proceeds for himself and
his co-defendant. He was sentenced to four years' probation, restitution of $47,850, and other
nominal fines and fees.

12.

Schumack, 56, is President of T.B.T.I, and resides in Pompano Beach, Florida.

13.

JCS is a Delaware corporation, incorporated in 2011, with its principal place of

business in Jupiter, Florida. JCS and its investment offerings are not registered with the
Commission in any capacity.

14.

T.B.T.I. is a Florida corporation, incorporated in 2001, with its principal place of

business in Highland Beach and/or Boca Raton, Florida. T.B.T.I. and its investment offerings
are not registered with the Commission in any capacity.
JURISDICTION AND VENUE

15.

The Court h'as jurisdiction over this action pursuant to Sections 20(b) and22(a) of

the Securities Act, 15 U.S.C. 77t(b) and 77v(a), and Sections 21(d) 21(e) and 27, of the
Exchange Act, 15 U.S.C. 78u(d), 78u(e) and 78aa.

16.

This Court has personal jurisdiction over the Defendants, and venue is proper in

the Southern District of Florida, because many of the Defendants' acts and transactions

constituting violations of the Securities Act and the Exchange Act occurred in the Southern
District of Florida. In addition, JCS's and T.B.T.I's principal places of business are in the

Southern District of Florida, and Signore and Schumack reside in the Southern District of
Florida.

17.

In connection with the conduct alleged in this Complaint, the Defendants, directly

and indirectly, singly or in concert with others, have made use of the means or instrumentalities
of interstate commerce, the means or instruments of transportation and communication in
interstate commerce, and the mails.

THE FRAUDULENT SCHEME

A. Agreement between JCS and T.B.T.I.

18.

In 2011, JCS and T.B.T.I. entered into an agreement, whereby T.B.T.I. would be

the sales agent for JCS and the Virtual Concierge program. T.B.T.I. contracted directly with
investors.

19.

Though JCS had an agreement with T.B.T.I. to be its sales agent, JCS also

solicited investors and contracted with them directly.

20.

Investors entered into contracts with TBTI and also directly with JCS to invest in

JCS's Virtual Concierge program. these contracts.

Schumack and Signore, respectively, were signatories to The

Investors could choose between an aggressive or passive option.

aggressive option burdened investors with responsibility, but allowed for greater returns. The
passive option left the investor with no responsibility, required no effort, and guaranteed them $300 monthly returns per VCM. The Defendants continuously and clearly stressed the passive option as the best choice for the investors.
21. The several versions of these passive contracts all required investors to pay a

one-time fee, ranging from $2,600 to $4,500 per VCM, while guaranteeing exorbitant $300 monthly returns for a three or four-year period, renewable at the end of the term. As summarized

in the "Concept of the Operation" section of T.B.T.I's contracts, it required the investors to do
nothing except make their initial investment, and insulated the investors from any risk or
liability.

22.

Investors did not have to install, maintain, update content on, or find a location Investors were entitled to a full

for, their VCM. They were not liable for theft or damage.

refund within six months for any reason.

A separate clause entitled "Failure to Receive

Commissions" in T.B.T.I's contracts explicitly provided that investors would have legal recourse

against T.B.T.I. and JCS in the event they did not receive their monthly $300 returns.
23. The Defendants also promised to inform investors where their VCM was located

and give them a password to monitor the activity of their VCM online. 24. The Defendants provided investors with invoices indicating the number of VCMs

purchased and their cost. In certain circumstances these invoices included a line-item entitled
"Shipping and installation to hotel," without a hotel name.
25. The Defendants permitted the investors to pay via credit card for ease. Despite

invoices appearing to have originated from T.B.T.I for those who contracted with T.B.T.I.,
investor debit statements indicated the investor funds were debited to JCS.
C. Defendants Misled Investors by Misrepresenting Material Facts and Failing to
Disclose Material Information

1.

Misrepresentations Regarding Exorbitant Rates of Return

26.

The Defendants promoted the VCM investment via the internet, email, telephone

and in-person seminars. They promoted participation in the Virtual Concierge program as a guaranteed money-making venture. This guarantee was false, as it was based on the improper use of investor funds, not advertising revenue, which the Defendants represented as the basis for
the guarantee.
a. Online Misrepresentations

27.

JCS marketed participation in the program and its VCMs on its website,

http://icsenterprise.net. which was identical to the website http://makingmonevvc.com. JCS's

identical websites held out JCS as "an experienced manufacturing, sales and marketing company

located in Jupiter, FL, specializing in Virtual Concierge wall and free standing units for
business." Its websites explained the "endless possibilities" for use of a VCM. On JCS's

dedicated VCM page, it touted the VCMs as "Monthly revenue generating business opportunities." This was false, as the Defendants were generating virtually no revenue.
28. JCS also promoted VCMs on the internet through YouTube. In one YouTube

video, the scene begins with an apparent investor polishing his new Cadillac. The investor's

friend proclaims, "What an amazing car! How can you afford this?" The investor responds,
"My Virtual Concierge." A similar scene then ensues with a different investor showing her friend her new pool. A spokesperson then appears and asks the viewer, "Do you want to make
more money? Then it is time for you to own a Virtual Concierge." After explaining the VCM, and asserting to potential investors that the VCM will "generate income for years," the

spokesperson informs, "You can find a location, or we will find one for you." He then
' proclaims, with a corresponding graphic at his side, that with a $3,500 investment, the investor
has the potential for "Huge returns."
29. The video continues with a testimonial from someone only identified as "Paul,"

who claims to be an actual Virtual Concierge program investor who generated a "high six figure income" in his first year of ownership. "Cathi," an apparent second investor, then appears, and
states that in less than a year, she has made close to $100,000. Afterward, the host reinforces

that the investor does not "need any experience or a location.

We give you everything you

need." The video then turns to a third investor polishing a different new car and asking his friend what he thinks. The friend responds, "Great new ride." The investor, unsolicited, states, "Thanks to my Virtual Concierge Business." The video ends by directing investors to JCS's
website, http://makingmonevvc.com.

30.

The concept of "huge" returns for investors was completely illusory. In reality,

continued operation of the Virtual Concierge program, as well as monthly payments to investors,
depended upon JCS's and T.B.T.I's receipt of new investor funds. The Defendants did not tell
investors they were using their investments to pay "returns" to existing investors, or that
investors' own "returns" would depend on new investors purchasing VCMs.

31.

In a separate YouTube video, the same spokesperson provides instructions on

how to purchase a VCM. The video also directs investors to http://makingmonevvc.com. The

spokesperson reiterates that JCS can find the investor a location for the VCM. Instructions are
then given to download the buyer agreement and then return it signed via fax, email or U.S.

Mail. The spokesperson explains that payment JCS accepts payment online in its "V-Mall", or
via check to JCS's corporate headquarters. After explaining how to track one's VCM, the

spokesperson proclaims the Defendants will install the investor's VCM in four to six weeks. In
reality, investors could not track the location of their VCMs, and there were not nearly enough
VCMs manufactured to keep pace with the investments in them.

32.

T.B.T.I. promoted the same VCMs on its website, http://atmhospitalitv.com.

T.B.T.I. touted itself as a full-service financial transaction company that had formed strategic alliances with leading industry professionals to provide the best possible service to its clients and commission to its properties. T.B.T.I. promoted VCMs as the "newest addition" to its product line. T.B.T.I.'s website stated, "Our unique concept and highly visual screens provide your guests with the convenience of accessing local and national business offers and savings at the touch of a fingertip." T.B.T.I's website promoted the use of VCMs in hotels, hospitals, stadiums, and at universities. T.B.T.I's dedicated VC advertising page stated, "The sky is the limit for

advertising revenue form (sic) our Virtual Concierge network!"

Correspondence from

Schumack to potential investors alsodirected them to JCS's YouTube videos and JCS's website.
33. These promotional videos and websites were glaring falsities perpetuating the

fraud. There was virtually no advertising revenue. Thus, the investors were not going to
"generate income for years".
b. Email Correspondence

34.

Schumack sent emails soliciting investors, and also sent emails to investors

confirming investment return checks had been mailed, and discussed the nuances of the

purported status of the investment, including prospective corporate hosts for the VCMs. To give
himself the aura of authenticity and gain investors' trust, Schumack's oversized and bolded

signature block to many of his emails touted his graduation from West Point Military Academy
in 1979. Below this was a Bible passage from 1 Corinthians 10:31: "Whatever you do, do it all

for the glory of God." This created a false sense of security for investors.
35. Included in at least one of Schumack's emails to investors was a message

encouraging existing investors to solicit new investors. Included in the email was a pre-prepared
email on behalf of investors to use in their solicitations. This email extolled the virtues of the

investment opportunity the existing investor had been exposed to and then provided a purported financial analysis as to why the investment was guaranteed to succeed. Schumack then set forth a calculation that represented a VCM would generate $1,900 a month in revenue, mostly from advertising, and thus after expenses, a VCM would net $455 a month in profit. There was
however, no basis in reality, for this calculation.

c. Employee Sales Meetings and Investor Sales Pitches

36.

Signore, at times, would lead in-house sales meetings with his staff. Signore

provided marketing materials to his sales staff to distribute to potential investors. Signore
provided details to JCS's sales agents as to the passive investment program. Signore never told
the sales agents to discuss any risks associated with the investment with investors, and described
the $300 monthly payment as guaranteed.

37.

Schumack and representatives from JCS participated in seminars touting

investments in the Virtual Concierge program throughout the country. They worked in tandem
and referred to the roles of T.B.T.I. and JCS in conjunction with one another. They misled

investors into believing that investment in the Virtual Concierge program was a fail-safe
investment where they did not have to participate to ensure its success. Moreover, Schumack

and the JCS representatives created a false sense of urgency by telling investors they needed to
invest immediately to guarantee a receipt of their return by the following month. 38. Schumack also promoted the investment via telephone, making similar

representations to potential investors as to the virtues of the passive program and the VMC's
guaranteed returns. Schumack stated T.B.T.I. worked "hand-in-glove" in promoting the VCM
investment with JCS.

39.

Schumack and JCS representatives also gave investors personal tours of JCS's

headquarters to provide comfort and confidence in their investments. They told investors of the
passive nature of the program, showed promotional videos, gave a guided tour of the facility including the production warehouse, and guaranteed the returns. In reality, the production of

VCMs did not come close to the amount of VCMs investors had purchased, and the "guaranteed"
returns were a farce.

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2. Signore and Schumack Misappropriated Investor Funds

40.

In comingling investor money from the JCS accounts, Signore personally used

investor funds, including diverting approximately $2,000,000 to himself, his wife and son.

Signore also diverted approximately $90,000 to a business jointly operated by himself and his
wife, and approximately $44,000 to Schumack personally. Debit charges from JCS accounts

indicate expenses such as restaurants, merchandising stores, a tanning salon, and significant
other credit card bills, totaling approximately $56,000. Signore also diverted $91,000 into a

separate business venture of his and his wife. The Defendants certainly did not tell investors
they would use their funds for these purposes.

41.

Similarly, the money from T.B.T.I's accounts where investor funds were

deposited was also used for personal expenses. Schumack's wife signed a check for $500,000,
made out to the IRS. Schumack signed a check for $50,000 for the benefit of another business
venture of his. Furthermore, Schumack diverted more than $100,000 to support the same

business venture of Signore and his wife which Signore had diverted funds into from JCS's bank
account.

42.

Furthermore, T.B.T.I. has transferred approximately $4 million from its investor

account to an unrelated account from which the Schumack and others executed more than 100

cash withdrawals totaling about $4.8 million - 91% of the total account balance. Schumack and
others used another $23,000 for personal expenses, including restaurants, merchandising stores,

and a nutrient therapy center. Again, the Defendants did not tell investors they would use their
money for these purposes.

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3. Misrepresentations Regarding VCM Placement and Buvback

43.

The Defendants told investors they would give them information about the

location of their VCMs, and would be able to access this information online through JCS's

website.

These representations were false. The Defendants did not place VCMs at anywhere

near the rate of those purchased by investors. Moreover, the option for investors to track their
websites often did not work at all, and to the extent they did, location information was unavailable. Further, the Defendants gave invoices to investors which were ambiguous as to the
VCM's locations.

44.

T.B.T.I. further misrepresented investors would have the right to sell back their

VCMs "for whatever reason," within the first six months of ownership, as stated in their investment contracts, This too was false, as investor requests for repurchases were ignored.
4. The Scheme Unravels Yet Misrepresentations Continue

45.

The majority of their investors stopped receiving their monthly payments in

approximately January 2014. Immediately prior to that, Schumack continued to lie to investors
in an effort to generate more capital by providing a bulletin stating their last opportunity to invest was expiring at year end 2013. Schumack later fabricated excuses to placate irate investors who
were no longer receiving their returns, telling them their checks were forthcoming. They were
not. Soon thereafter, T.B.T.I. stopped answering its phones.
46. JCS also continued the fraud as when investors began complaining, JCS issued a

press release, which it posted on its website, indicating it was investigating the matter.

In

denying any wrongdoing, JCS placed the blame squarely on T.B.T.I., and claimed it had only an
arms-length relationship with T.B.T.I. This was patently false.

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47.

Additionally, in individual correspondence to its investors, JCS perpetuated the

myth that the operation was a legitimate one and that it had been defrauded. JCS then offered a
"settlement" of $300 in exchange for the investor to forego pursuing further legal action.
However, it was not JCS which was defrauded ~ it was the investors.

48.

Further, JCS, despite claiming that the Virtual Concierge program was closed,

continued to promote the program on its website and via YouTube.

Sale of Unregistered Securities in Violation of Sections 5fa) and 5(c> of the Securities Act

49.

The Commission repeats and realleges paragraphs 1 through 39 of this Complaint

as if fully restated herein.

50.

No registration statement was filed or in effect with the Commission pursuant to

the Securities Act and no exemption from registration exists with respect to the securities and
transactions described in this Complaint.

51.

The Defendants, from at least as early as 2011, through present directly or

indirectly have: (a) made use of the means or instruments of transportation or communication in
interstate commerce or of the mails to sell securities, through the use or medium of a prospectus

or otherwise; (b) carried securities or caused such securities to be carried through the mails or in interstate commerce, by any means or instruments of transportation, for the purpose of sale or delivery after sale; and (c) made use of the means or instruments of transportation or
communication in interstate commerce or of the mails to offer to sell or offer to buy through the

use or medium of any prospectus or otherwise, without a registration statement having been filed
or being in effect with the Commission as to such securities.

13

52.

By reason of the foregoing, the Defendants directly or indirectly violated, and,

unless enjoined, are reasonably likely to continue to violate, Sections 5(a) and 5(c) of the
Securities Act of 1933 (the "Securities Act") [15 U.S.C. 77e(a) and 77e(c)].
COUNT II
Fraud in the Offer or Sale of Securities in Violation of

Section 17(a)(1) of the Securities Act

53.

The Commission repeats and realleges paragraphs 1 through 48 of this Complaint

as if fully restated herein.

indirectly, in the offer or sale of securities, by use of the means or instruments of transportation
or communication in interstate commerce and by use of the mails, have knowingly, willfully or recklessly employed devices, schemes or artifices to defraud.
55. By reason of the foregoing, the Defendants directly or indirectly violated, and,

unless enjoined, are reasonably likely to continue to violate, Section 17(a)(1) of the Securities Act
[15 U.S.C. 77q(a)(l)].
COUNT III

Fraud in the Offer or Sale of Securities in Violation of Section 17(a)(2) of the Securities Act

56.

The Commission repeats and realleges paragraphs 1 through 39 and 45 through 48

of this Complaint as if fully restated herein.

indirectly, in the offer or sale of securities, by the use of means or instruments of transportation or communication in interstate commerce, or of the mails have: (a) obtained money or property

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by means ofuntrue statements ofmaterial fact or by omitting to state material facts necessary in
order to make the statements made, in the light of the circumstances under which they were
made, not misleading.

58.

By reason of the foregoing, the Defendants, directly or indirectly violated, and,

unless enjoined, are reasonably likely to continue to violate, Section 17(a)(2) of the Securities
Act [15 U.S.C. 77q(a)(2)].
COUNT IV

Fraud in the Offer or Sale of Securities in Violation of

59.

The Commission repeats and realleges paragraphs 1 through 48 of this Complaint

as if fully restated herein.

60.

From at least as early as 2011 through the present, the Defendants, directly or

indirectly, in the offer or sale of securities, by use of the means or instruments of transportation
or communication in interstate commerce and by use of the mails, have engaged in acts,

transactions, practices or courses of business which operated as a fraud or deceit upon purchasers
of securities.

61.

By reason of the foregoing, the Defendants, directly or indirectly violated, and,

unless enjoined, are reasonably likely to continue to violate, Section 17(a)(3) of the Securities
Act [15 U.S.C. 77q(a)(3)].
COUNT V

Fraud in Violation of Section 10(b) and Rule 10b-5(b) of the Exchange Act

62.

The Commission repeats and realleges paragraphs 1 through 39 and 45 through 48

of its Complaint.
15

63.

From at least as early as 2011 through the present, the Defendants, directly or

indirectly, by use of the means and instrumentalities of interstate commerce, and of the mails in
connection with the purchase or sale of securities, knowingly, willfully or recklessly have made
untrue.statements of material facts and omitted to state material facts necessary in order to make

the statements made, in light of the circumstances under which they were made, not misleading.

64.

By reason of the foregoing, the Defendants directly or indirectly violated, and,

unless enjoined, are reasonably likely to continue to violate, Section 10(b) of the Exchange Act
of 1934 (the "Exchange Act") [15 U.S.C. 78j(b)] and Exchange Act Rule 10b-5(b) [17 C.F.R.
240.10b-5(b)].
COUNT VI

Fraud in Violation of Section 10(b) and Rules 10b-5(a) and (c) of the Exchange Act

65.
66.

The Commission repeats and realleges paragraphs 1 through 48 of its Complaint.

indirectly, by use of the means and instrumentalities of interstate commerce, and of the mails in
connection with the purchase or sale of securities, knowingly, willfully or recklessly have: (1)

employed devices, schemes or artifices to defraud; or (2) engaged in acts, practices and courses
of business which have operated, are now operating and will operate as a fraud upon the purchasers of such securities.
67. By reason of the foregoing, the Defendants directly or indirectly violated, and,

unless enjoined, are reasonably likely to continue to violate, Section 10(b) of the Exchange Act of 1934 (the "Exchange Act") [15 U.S.C. 78j(b)] and Exchange Act Rules 10b-5(a) and (c) [17
C.F.R. 240.10b-5(a) and (c)].

16

RELIEF REQUESTED

WHEREFORE, the Commission respectfully requests that the Court:

Declaratory Relief

Declare, determine and find that the Defendants have committed the violations of the

federal securities laws alleged herein.

Temporary Restraining Order. Preliminary Injunction and Permanent Injunction

Issue a Temporary Restraining Order, a Preliminary Injunction and a Permanent

Injunction, restraining and enjoining the Defendants their officers, agents, servants, employees,
attorneys, and all persons in active concert or participation with them, and each of them, from

violating Sections 5(a), 5(c), 17(a)(1), (2) and (3) of the Securities Act, and Section 10(b) and
Rule 10b-5 of the Exchange Act.
III.

Disgorgement

Issue an Order directing the Defendants to disgorge all ill-gotten gains, including prejudgment interest, resulting from the acts or courses of conduct alleged in this Complaint.
IV. Penalties

Issue an Order directing all Defendants to pay civil money penalties pursuant to Section 20(d) of the Securities Act, 15 U.S.C. 77t(d), and Section 21(d) of the Exchange Act, 15 U.S.C. 78u(d) for their securities law violations.

17

Further Relief

Grant such other and further relief as may be necessary and appropriate.
VI. Retention of Jurisdiction

Further, the Commission respectfully requests that the Court retain jurisdiction over this action in order to implement and carry out the terms of all orders and decrees that it may enter, or to entertain any suitable application or motion by the Commission for additional relief within the
jurisdiction of this Court.

April 7,2014

Respectfully sykitted.

By:
Koonin
Senior Trial Counsel
Florida Bar No. 474479

Telephone: (305) 982-6385

StafFAttorney
CourtIDNo.:A5501961

Telephone: (305) 982-6364

Attorneys for Plaintiff

801 Brickell Avenue, Suite 1800 Miami, Florida 33131

Telephone: (305) 982-6300 Facsimile: (305)536-4154

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