New York Paralegal

WASHINGTON – A federal jury today convicted Lance K. Poulsen, former president, owner and chief executive officer of National Century Financial Enterprises (NCFE) of conspiracy, fraud and money laundering, Acting Assistant Attorney General Matthew Friedrich of the Criminal Division and U.S. Attorney Gregory G. Lockhart for the Southern District of Ohio announced. The charges stemmed from a scheme to deceive investors about the financial health of NCFE that cost investors more than $2 billion. The company, which was based in Dublin, Ohio, was one of the largest healthcare finance companies in the United States until it filed for bankruptcy in November 2002. The Columbus, Ohio, jury convicted Poulsen, 65, after a four-week trial on all 12 charged counts contained in a July 2007 superseding indictment, including one count of conspiracy, six counts of securities fraud, one count of wire fraud, one count of money laundering conspiracy and three counts of concealment money laundering. At tri...

WASHINGTON — The Department of Justice announced today that it will require Verizon Communications Corp. (Verizon) to divest assets in 100 areas in 22 states in order to proceed with its $28 billion acquisition of Alltel Corp. The Department said that the transaction as originally proposed would have substantially lessened competition to the detriment of consumers of mobile wireless telecommunications services in those areas, and likely would result in higher prices, lower quality and reduced network investments. The divestitures cover the entire states of North Dakota and South Dakota; large portions of the states of Colorado, Georgia, Kansas, Montana, South Carolina, Utah and Wyoming; and portions of the states of Alabama, Arizona, California, Idaho, Illinois, Iowa, Minnesota, Nebraska, Nevada, New Mexico, North Carolina, Ohio and Virginia. The Department’s Antitrust Division, along with the Attorneys General of the states of Alabama, California, Iowa, Kansas, Minnesota, North Dakota...

WASHINGTON – The former director of permits for the U.S. Virgin Islands Department of Planning and Natural Resources (DPNR) was sentenced today to 14 months in prison for his role in a $1.4 million bribery and kickback scheme, Acting Assistant Attorney General Matthew Friedrich of the Criminal Division and Acting U.S. Attorney Paul A. Murphy of the District of the Virgin Islands announced. U.S. District Chief Judge Curtis V. Gomez also ordered Brent E. Blyden, 46, to pay $125,755 in restitution as well as a personal money judgment in the amount of $ 20,000, and sentenced Blyden to serve three years of supervised release following his release from prison. In addition, Judge Gomez banned Blyden from federal and local government employment for five years. More...

MILBURN, N.J. -- The U.S. Department of Labor has ordered The Charles Schwab Corp. to reinstate and pay back pay and damages to two employees who were fired in violation of the whistleblower provision of the Sarbanes-Oxley Act of 2002. The whistleblower complaint was filed with the Occupational Safety and Health Administration (OSHA) on June 15, 2007, naming The Charles Schwab Corp., Charles Schwab & Co. Inc., Charles Schwab Bank and three individuals as defendants. The complaint alleged that the two employees were terminated because they objected to and refused to participate in a scheme at a branch office to falsify entries in Schwab's database system. An investigation conducted by OSHA's Whistleblower Protection Program determined that there was merit to the allegations. "This case sends a clear message that OSHA will not tolerate retaliation against corporate whistleblowers," said Robert Kulick, OSHA's regional administrator in New York. "While OSHA i...

SEATTLE - Hotel giant WorldMark by Wyndham will pay $370,000 and furnish significant remedial relief to settle a sexual harassment lawsuit filed by the U.S. Equal Employment Opportunity Commission (EEOC), the agency announced on 10/23/08. The EEOC had charged that the company failed to stop the manager of its Birch Bay Resort in Blaine, Wash., from sexually harassing young male employees. According to the EEOC’s investigation, the resort manager, male and in his 40s, repeatedly subjected young male employees between the ages of 17 and 25 to unwelcome touching of a sexual nature, comments about their physical appearance, and sexually charged situations. One of the former employees said, “I was humiliated by what was happening to me at work -- everyone knew and many people just laughed about it. It was really hard to talk about what happened to me, reporting it to the EEOC, but it was worth it. At least now I know it’s not going to happen again to another teenager.” Sexual harassme...

OCT 27 -- (Washington, D.C.) – Drug Enforcement Administration Acting Administrator Michele M. Leonhart and Facundo Rosas, Under Secretary for Intelligence and Strategy, Mexican Federal Police, announced today one of the most significant arrests ever in the ongoing battle against global drug trafficking. On Saturday, Oct. 25, Eduardo Arellano-Felix, a Consolidated Priority Organization Target or CPOT, was apprehended after a drawn out gun battle with a Mexican Special Tactical Team in Tijuana, Baja California, Mexico. Intelligence gathered by DEA and San Diego Field Division identified Arellano-Felix’s hideout in the Otay Mesa area of Tijuana; and once Mexican authorities announced their presence at the location later in the day, one of the most sought after drug traffickers in the world started shooting. After several shots were fired, Mexican authorities were able to gain access to the residence and Arellano-Felix was apprehended without further incident. No one was injured in t...

In an open letter to Congressional leadership, Governor David A. Paterson today urged Congress to include state representation in oversight responsibilities for the implementation of the Emergency Economic Stabilization Act (EESA). Additionally, Governor Paterson announced that he will testify before the House Ways & Means Committee on Wednesday for a hearing on “Economic Recovery, Job Creation and Investment in America,” in which he will urge the Federal Government to take specific action to address the national financial crisis. In his letter to House Speaker Nancy Pelosi, Senate Majority Leader Harry Reid, Senate Minority Leader Mitch McConnell, and House Minority Leader John Boehner, Governor Paterson called for the states to have representation on the five-member Congressional Oversight Panel created as part of the EESA. This Oversight Panel is charged with overseeing the implementation of the Treasury’s multifaceted program, including the effectiveness of its foreclosure miti...

(HUD) - WASHINGTON - U.S. Department of Housing and Urban Development Secretary Steve Preston today announced that 400,000 families have refinanced their mortgages with HUD’s affordable mortgage insurance program. Since expanding its refinance program in September 2007, HUD’sFederal Housing Administration (FHA) has helped more distressed homeowners keep their homes by utilizing FHA’s safe and affordable mortgage financing. FHA refinancing is on pace to help 500,000 families by the end of this year. “Thanks to FHA’s expanded programs, hundreds of thousands of families now have peace of mind knowing they have a stable, more affordable mortgage,” said Preston. “Today, we are proud to say that FHA has helped more than 400,000 struggling families keep their homes while also creating greater liquidity in the mortgage market.” Since its creation in 1934, FHA has helped more than 35 million families become homeowners. Nationwide, the number of mortgages insured by FHA was nearly three tim...

(openPR) - Toronto, Canada—October 24th, 2008—According to several reports both Presidential candidates Barack Obama and Senator John McCain are concerned about the possibility of election fraud and are consulting the top law firms of America to tackle the potentially volatile situation. Campaign groups of both presidential parties have already started putting together the top team of lawyers to represent the interests of their respective candidates. While both campaigns maintain having a team of lawyers is nothing new and there is no real worry or threat of electoral fraud, many experts believe that ever since the Florida fiasco of 2000 took place, both parties want to make sure that there is no repeat of such an incident and even if it does take place, they are fully prepared to tackle the situation. And it is not just the presidential campaign teams who are talking about electoral fraud but even legal networking sites like lawyerahead.com are abuzz with activity from its registered...

Washington – Sarah Pender was behind bars serving a 110-year sentence before she escaped in August from the Rockville Correctional Facility in Indiana. Today, she is the most wanted woman in America after being added to the U.S. Marshals 15 Most Wanted fugitive list. Pender, 29, was convicted in 2002 on two counts of murder. In 2000, Pender and her boyfriend purchased a shotgun and returned to their residence where they shot their two roommates. After killing the roommates, Pender and her boyfriend disposed of the bodies in a trash dumpster. While serving her sentence, prison authorities believe Pender befriended a correctional officer, who allegedly helped her escape. Prison security footage on the day she escaped shows Pender walking toward a prison exit at the same time the guard drove into the facility to get gasoline. Authorities believe the guard hid her in the vehicle and drove her off the prison grounds where she met up with her get-away driver. “Sarah Pender is a dangerous fug...

EEOC Settles Suit for Young Men Who Were Sexually Abused SEATTLE - Hotel giant WorldMark by Wyndham will pay $370,000 and furnish significant remedial relief to settle a sexual harassment lawsuit filed by the U.S. Equal Employment Opportunity Commission (EEOC), the agency announced today. The EEOC had charged that the company failed to stop the manager of its Birch Bay Resort in Blaine, Wash., from sexually harassing young male employees. According to the EEOC’s investigation, the resort manager, male and in his 40s, repeatedly subjected young male employees between the ages of 17 and 25 to unwelcome touching of a sexual nature, comments about their physical appearance, and sexually charged situations.

Benton J. Campbell, United States Attorney for the Eastern District of New York, and Kenneth Donohue, Inspector General for the Department of Housing and Urban Development, announced the filing of a civil complaint against Madison Home Equities, Inc., a mortgage lender located in Carle Place, Long Island, seeking a court-ordered injunction to prevent the company from making loans insured by the Federal Housing Administration (“FHA”). The complaint also seeks relief against Madison’s president, Nadine Malone. The case is pending before United States District Judge Nicholas G. Garaufis. As alleged in the civil complaint, Madison participates in a federal program sponsored by the United States Department of Housing and Urban Development (“HUD”) which authorizes Madison to make mortgage loans that are insured by FHA in the event of default. As a condition of participation in the program, Madison must determine that all borrowers who receive FHA-insured mortgage loans meet HUD lending stand...

Today Attorney General Cuomo sent the attached letter to Edward Liddy, the CEO of AIG. The letter sets forth that: (1) AIG will freeze any payments under former-CEO Martin Sullivan's $19 million contract; and (2) AIG has confirmed that no payments will be made out of the $600 million compensation and bonus pools of the Financial Products subsidiary. The letter also states the Attorney General's position that taxpayers should be repaid before any executives and that new executive pay structures should eliminate improper incentives.

(openPR) - Cavalier Telephone, trusted provider of DSL and telephone service in 15 states including the District of Columbia, sued Verizon Virginia for misuse of 911 customer data. RICHMOND, VA - Cavalier Telephone, an integrated provider of telecommunications and data including local and long distance telephone services and DSL high speed Internet, has sued Verizon Virginia, Inc. in the U.S. District Court for the Eastern District of Virginia. The lawsuit is based on Verizon's unlawful use of the Virginia 911 database. Verizon has relied heavily on the Virginia 911 database to support certain petitions filed by Verizon before the Federal Communications Commission and the Virginia State Corporation Commission. Cavalier's complaint seeks injunctive and declaratory relief. "The 911 database is a public asset and Verizon has violated the public trust by subverting it to private gain. The 911 system was created to assist law enforcement and emergency services and to facilitat...

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WASHINGTON — The Department of Justice filed a civil antitrust lawsuit today in U.S. District Court in Chicago to block the proposed acquisition by JBS S.A., currently the third-largest U.S. beef packer, of National Beef Packing Company LLC, the fourth-largest U.S. beef packer. The Department said that the proposed deal would combine two of the top four U.S. beef packers resulting in lower prices paid to cattle suppliers and higher beef prices for consumers. The Attorneys General of Colorado, Iowa, Kansas, Minnesota, Missouri, Montana, North Dakota, Ohio, Oklahoma, Oregon, South Dakota, Texas and Wyoming are joining the Department’s lawsuit. JBS, headquartered in Brazil, is in the process of acquiring Smithfield Beef Group Inc. from Smithfield Foods Inc. The Department is not challenging JBS’s acquisition of Smithfield Beef Group Inc. In 2007, JBS purchased Colorado-based Swift Foods Company. Beef packers purchase annually $30 billion in fed cattle from feedlots, slaughter them, and pr...

New York-( 10/16/08)-Attorney General Andrew M. Cuomo met today with Edward M. Liddy, the new Chairman and Chief Executive Officer of American International Group, Inc. (“AIG”) In a candid discussion, the Attorney General laid out his serious concerns regarding executive compensation issues and exorbitant expenses at AIG. The meeting in the Attorney General’s New York City Offices occurred one day after Attorney General Cuomo informed AIG that it must recover improper bonuses and other payments and perks from its former executives or Cuomo would do so pursuant to New York law. During the meeting, Mr. Liddy agreed to take several significant actions with respect to expenditures at AIG. First, AIG has agreed to provide the New York Attorney General’s Office with an accounting of all compensation paid to its senior executives and has agreed to assist the Attorney General’s Office in recovering any illegal expenditures. This includes all forms of compensation paid to former CEO Martin Sull...

October 15, 2008 American International Group Board of Directors C/O Secretary of the Board American International Group, Inc. 70 Pine Street New York, NY, 10270 Re: Fraudulent Conveyance Investigation at AIG Dear Members of the Board: Over the past several months, this Office has become aware of unwarranted and outrageous expenditures by American International Group, Inc. ("AIG") even as the company slipped towards insolvency. As you of course know, the taxpayers of this country are now supporting AIG through rescue financing, which makes such expenditures even more irresponsible and damaging. As described below, we demand that the Board of Directors (the "Board") cease and desist any such further expenditures, and review, rescind, and recover all past unreasonable expenditures. The Board must also immediately institute new protections to prevent future abuses, and provide this Office with an accounting of executive compensation and benefits. We hereby place AIG an...

Kathryn L. Myers, associate professor and coordinator of paralegal studies at Saint Mary-of-the-Woods College (SMWC), will attend the American Association for Paralegal Education Conference Oct. 15-18 in Dallas, Texas. Myers attends the conference every year, presenting in at least one session, and for the past eight years, she has served as the conference chairperson. As chairperson, she works with a three-person committee to create approximately 50 sessions with more than 125 speakers/panelists. This year, Myers will present five different conference sessions. The first session, entitled “Engaging Kathryn MyersStudents through Humor,” will provide attendees with ways to grab students' attention while achieving academic learning, and the second session, entitled “Fun with Legal Research and Writing,” is part of the writing workshop series that has been a hallmark of the conferences. The third session addresses service to the profession and taking advantage of volunteer opportuniti...

WASHINGTON –U.S. Citizenship and Immigration Services (USCIS) announced today that prospective adoptive parents already in the process of adopting a child from a country that has implemented the Hague Convention on Protection of Children and Co-operation in Respect of Intercountry Adoption (Hague Adoption Convention) who filed a Form I-600A, Application for Advance Processing of Orphan Petition, prior to April 1, 2008, and who have received the one time no-charge extension, may file one additional Form I-600A, and continue to proceed with their intercountry adoption through the “orphan” process. The new Form I-600A must be filed before the current approval expires, and only if the prospective adoptive parents have not yet filed the corresponding Form I-600, Petition to Classify Orphan as an Immediate Relative. U.S. law and regulations allow individuals who began the intercountry adoption process by filing Form I-600A or Form I-600, before April 1, 2008, to continue using these pre-Ha...

WASHINGTON - The Justice Department announced today the filing of a lawsuit against the State of Vermont and Vermont Secretary of State Deborah L. Markowitz, alleging violations of the Uniformed Overseas Citizen Absentee Voting Act (UOCAVA). UOCAVA is designed to ensure that uniformed military members and overseas citizens may effectively participate in federal elections. Vermont and the Secretary are responsible for collecting and reporting the number of military voters and overseas citizens who are sent ballots, return them and have them successfully cast in each federal general election. Vermont has failed to fulfill this important obligation ever since it became law in the Help America Vote Act of 2002. The complaint filed in the U.S. District Court in Burlington, Vt., seeks a declaration that Vermont has previously violated the law, and seeks an injunction against any future noncompliance. "Accurate and complete information about whether our uniformed service members and over...

WASHINGTON – The U.S. Equal Employment Opportunity Commission (EEOC) today announced that the Supreme Court has denied a petition for review by Federal Express Corporation (FedEx) of a ruling by the U.S. Court of Appeals for the Fourth Circuit upholding a $100,000 punitive damages award in an EEOC lawsuit under the Americans With Disabilities Act (ADA) on behalf of a deaf package handler. On March 2, 2006, a federal jury in Baltimore found in favor of the EEOC in its lawsuit against FedEx for violating the ADA. The EEOC had charged the Memphis, Tenn.-based global shipping giant with failing to provide reasonable accommodations to Ronald Lockhart, a profoundly deaf employee who worked as a package handler at the company's Baltimore Ramp, which is located at the Baltimore-Washington International Airport. The EEOC’s suit charged FedEx with violating the ADA by failing to provide Lockhart with American Sign Language interpreters and notes for mandatory employee meetings and trainings,...

Many people look to the government hoping to find out how to apply for a grant or to get "free money," which they have seen advertised on television or in various publications. However, grants usually go to state and local governments or nonprofit organizations, which then use the money to operate assistance programs locally. USA.gov has information about legitimate grant and loan opportunities. Individuals looking for government grants and loans should visit GovBenefits.gov. GovBenefits.gov is the official government benefits web site, encompassing more than 400 federal and 600 state programs funded by various agencies. This site allows you to complete a confidential questionnaire and receive a list of programs that may apply to your situation. States and organizations looking for grants should visit Grants.gov. Another source of information is the Catalog of Federal Domestic Assistance (CFDA), which is a directory of over 15 types of federal assistance, including grants ...

The United States Patent and Trademark Office will hold its annual Trademark Expo next May 8-9 at the agency’s headquarters in Alexandria, Virginia. The 2008 Expo attracted 7,000 people and received wide media coverage. Next year’s two day event will focus again on educating the public about the value and important role trademarks play in our society and the global marketplace. It will feature themed displays, company booths, costumed characters interactive exhibits and trademark related seminars for attendees. An intensified effort will be made this year to attract school children to the event. All individuals, companies, non-profit organizations and educational institutions that own a valid registered United States trademark are invited to apply to exhibit. The deadline for applications is January 9, 2009. Applications will be evaluated on the following criteria: Brand recognition, educational value of the proposed exhibit and category diversity. Space is limited so apply today. Thos...

WASHINGTON – David C. Kernell, 20, was indicted by a federal grand jury in Knoxville, Tenn., for intentionally accessing without authorization the e-mail account of Alaska governor Sarah Palin, Acting Assistant Attorney General Matthew Friedrich of the Criminal Division and U.S. Attorney James R. Dedrick for the Eastern District of Tennessee announced today. Kernell turned himself into federal authorities for arrest and will be arraigned today before U.S. Magistrate Judge C. Clifford Shirley. The single count indictment, returned on Oct. 7, 2008, and unsealed today, alleges that on approximately Sept. 16, 2008, Kernell, a resident of Knoxville, obtained unauthorized access to Gov. Palin’s personal e-mail account by allegedly resetting the account password. According to the indictment, after answering a series of security questions that allowed him to reset the password and gain access to the e-mail account, Kernell allegedly read the contents of the account and made screenshots of the ...

WASHINGTON - Armor Holdings Products LLC has agreed to pay the United States $30 million to resolve allegations that it violated the False Claims Act by knowingly manufacturing and selling defective Zylon bullet-proof vests, the Justice Department announced today. The United States alleged that Armor Holdings manufactured and sold Zylon bullet-proof vests despite possessing information showing that the Zylon materials degraded quickly over time and were not suitable for ballistic use. The Armor Holdings vests were purchased by the federal government, and by various state, local and tribal law enforcement agencies that were partially reimbursed by the United States under the Justice Department’s Bulletproof Vest Partnership program. Armor Holdings’ Zylon vests contained either woven Zylon or a Zylon laminate insert called Z Shield. The Zylon fiber used in both types of vests was manufactured by Toyobo Co. Ltd. In July 2007, the United States sued Toyobo for its manufacture and sale of Z...

By: Joel Irving Join me this Sunday morning at 10:00 a.m., as I talk with Christine M. Parizo. Ms. Parizo is a PACE Registered Paralegal through the National Federation of Paralegal Associations, the author of “ A Paralegal’s Blog ” and is employed by a small firm in Western Massachusetts as a litigation paralegal. Ms. Parizo and I will be discussing mandatory licensing of paralegals along with some other issues pertaining to the paralegal profession. The link to the show is: http://www.blogtalkradio.com/Joel-Irving and the call in number is: (347) 677-0863.

ALBANY, N.Y. (October 6, 2008) – Attorney General Andrew M. Cuomo today announced a settlement agreement with a retired Saint Lawrence County Attorney who was improperly listed as an employee of four public sector entities, including the Village of Canton, the Saint Lawrence-Lewis Board of Cooperative Educational Services (“BOCES”), the Colton Pierrepont School District, and the Lisbon Central School District. John D. Elmer retired in January 1998 and began receiving a small annual pension through the New York State Employees’ Retirement Fund (“ERS”). Under the settlement, Elmer will pay the State of New York $42,000, will cease receiving state-funded pension benefits of any kind, and will forfeit any claims to monetary contributions he may have made to ERS in connection with his purported “employments.” At various times between 1974 and 1998, Elmer was listed as an employee of four public sector entities: the Village of Canton (1974 to 1980), Saint Lawrence-Lewis BOCES (1974 to 1998)...

National Breast Cancer Awareness Month (NBCAM) organization is comprised of several national public service organizations, professional medical associations, and government agencies working in partnership to build breast cancer awareness, share information and provide access to screening services. NBCAM, and http://nbcam.org/ , are a year-round resource for patients, survivors, caregivers and the general public. Since its beginning more than 20 years ago, NBCAM has been dedicated to increasing awareness of breast cancer issues, especially the importance of early detection. NBCAM has evolved along with the national dialogue on breast cancer. Many strides have been made in breast cancer awareness and treatment, but even more still needs to be accomplished. We are focused on encouraging women to take charge of their own breast health, by practicing regular self-breast exams, making sure to schedule an annual mammogram, adhering to prescribed treatment and knowing the facts about recurrenc...

A federal judge has banned Kevin Trudeau from infomercials in which he has an interest for three years and ordered him to pay more than $5 million in profits from his book, "The Weight Loss Cure 'They' Don't Want You to Know About." The ruling confirms an earlier contempt finding against Trudeau – the second time he has been found in contempt of court in the past four years. In August, Judge Robert W. Gettleman of the U.S. District Court for the Northern District of Illinois stood by his conclusion in 2007 that Trudeau "clearly, and no doubt intentionally," violated a provision of a 2004 stipulated court order that prohibits Trudeau from misrepresenting the content of books in his infomercials. The judge stated that "the Infomercial[s] falsely and intentionally led thousands (probably hundreds of thousands) of consumers to believe that the Weight Loss Book would describe an 'easy,' 'simple' protocol that, once 'finished' wo...

(openPR) - Teenage girl group Runway MMC are using innovative marketing techniques to separate themselves from other up and coming pop groups in order to propel their hit new single up the national pop charts. The single “Runway” was released by b.i.y.a.y.c.d.a. Inc. on September 16th 2008 exclusively via Apple’s iTunes Music Store (the recently named #1 music retailer in the world). The group Runway MMC has also released their own line of clothing with personal individual style that sets them apart from each other. appealing to teenage girls to stores across the US including 200 WET SEAL stores. As a result of the initial success of the clothing line, Apple iTunes and Runway MMC have structured national promotion whereby 25,000 customers of the Runway MMC clothing line will be able to download the group’s first single “Runway” for free through the iTunes Music Store. Runway MMC was formed when three multi ethnic young ladies started performing together in Los Angeles in 2007. Meghan ...

WASHINGTON – Helio Castroneves, a U.S. resident and two-time winner of the Indianapolis 500, was indicted by a grand jury today on charges of conspiracy to defraud the United States of income taxes and with six separate counts of income tax evasion for tax years 1999 through 2004, announced the Justice Department, U.S. Attorney for the Southern District of Florida R. Alexander Acosta and Internal Revenue Service-Criminal Investigation (IRS-CI) Special Agent-in-Charge Michael E. Yasofsky Jr. Also charged in the indictment were Helio Castroneves’ sister and business manager, Katiucia Castroneves of Miami, and his attorney, Alan R. Miller of Michigan. Count one of the indictment charges Helio Castroneves, Katiucia Castroneves and Miller with conspiring to defraud the United States by using an offshore Panamanian shell corporation – Seven Promotions Corporation (Seven Promotions) – to fraudulently conceal from the IRS income received from two sources: Coimex Internacional SA (Coimex) and P...

Under the terms of a settlement announced by the Federal Trade Commission today, a list broker, formerly based in Arizona, and the two companies he ran have agreed to a proposed court order barring them from violating the agency’s Telemarketing Sales Rule (TSR). The proposed order settles a Commission complaint charging that the defendants assisted and facilitated telemarketers of fraudulent “advance-fee” credit cards by providing them with unencrypted consumer information. The FTC complaint alleged the defendants sold “full data leads” to these telemarketers that included consumers’ bank account and routing information, credit card numbers, credit card security codes, and credit card expiration dates, without first obtaining authorization from consumers to do so, all the while knowing that the data would be used in schemes designed to mislead and defraud consumers. The proposed order also contains a suspended $120,000 judgment against the defendants. The full judgment will be imposed ...