Based the forgoing, the Court shall issue a initial injunction consistent utilizing the definitions established below.

Based the forgoing, the Court shall issue a initial injunction consistent utilizing the definitions established below.


1. “Asset” means any appropriate or interest that is equitable, right to, or claim to, any genuine, individual, or intellectual home including, however restricted to, chattel, products, instruments, gear, fixtures, basic intangibles, results, leaseholds, agreements, mail or any other deliveries, stocks of stock, securities, inventory, checks, records, records, credits, receivables (as those terms are defined into the Uniform Commercial Code), cash, trusts, including yet not restricted to asset protection trusts, and book funds or other records related to any re re payments prepared with respect to any Defendant, including, although not restricted to, such reserve funds held by way of a re re payment processor, bank card processor, or bank.

2. “Defendants” means (a) each Tucker Defendant and (b) each Relief Defendant. Moreover, anyone insofar while he or this woman is acting when you look at the capability of a officer, representative, servant, employee, or lawyer of any Tucker Defendant or any Relief Defendant, and anyone or entity in active concert or involvement with some of the foregoing who gets real notice for this purchase by individual service or perhaps, is likely to adhere to this purchase, see Fed.R.Civ.P. 65(d), whether these people or entities are acting straight or via a trust, organization, subsidiary, unit, or other unit.

3. “Document” is synonymous in meaning and equal in range towards the use of the expression when you look at the Federal Rules of Civil Procedure 34(a), and includes composing, drawings, graphs, maps, sites, webpages, those sites, electronic communication, including e-mail and immediate messages, photographs, sound and video clip tracks, agreements, accounting information, adverts (including, although not restricted to, ads positioned on the Around The Globe Web), FTP Logs, Server Access Logs, USENET Newsgroup postings, Around The Globe website pages, publications, written or printed documents, handwritten records, phone logs, phone scripts, receipt publications, ledgers, individual and company canceled checks and look registers, bank statements, visit publications, computer documents, along with other information compilations from where information can be had and translated, if required, through detection products into fairly usable kind. A draft or copy that is non-identical a split document in the concept of the word.

4. “Person” means a normal individual, company, or other appropriate entity, including a business, partnership, proprietorship, relationship, cooperative, federal government or government subdivision or agency, or just about any other team or combination acting being an entity.

5. “Plaintiff” or “Commission” or “FTC” means the Federal Trade Commission.

6. “Relief Defendants” means Kim Tucker, Park 269, LLC, and their successors, assigns, affiliates, or subsidiaries.

7. “Representatives” means Defendants’ officers, agents, servants, workers, and lawyers, and just about every other individual or entity in active concert or involvement together with them whom gets real notice with this purchase by individual solution or else.

8. “Tucker Defendants” means Scott A. Tucker, AMG Capital Management, LLC, amount 5 Motorsports, LLC, Ebony Creek Capital Corporation, LeadFlash asking LLC, Broadmoor Capital Partners, LLC, and Nereyda M. Tucker, as Executor of this Estate of Blaine A. Tucker, and their successors, entities, assigns, affiliates, or subsidiaries.


IT REALLY IS HEREBY REQUESTED that the Tucker Defendants’ movement for Extension of the time (ECF No. 786) together with Relief Defendants’ movement for Extension of the time (ECF No. 792) are DENIED as moot.

IT REALLY IS FURTHER REQUESTED that the Tucker Defendants’ movement to Reconsider (ECF No. 808) is REJECTED.

IT REALLY IS FURTHER REQUESTED that the FTC’s Motion to Unseal (ECF No. 810) is AWARDED in part and DENIED in part. The Clerk is bought to UNSEAL the documents that are following Declaration of Natalie C. Dempsey (ECF No. 803-8); OneClickCash Traning Manual (ECF No. 803-9); and UCL Team Meeting Minutes (ECF No. 803-10). Blaine Tucker’s residing Trust (ECF No. 803-7) will stay filed under SEAL.

IT REALLY IS FURTHER REQUESTED that the FTC’s movement for Preliminary Injunction (ECF No. 780) is ISSUED pursuant to your terms that are following