Pre-Paid Legal Services, Inc

Text (OCR of the scan at left; may contain errors)

IN THE MATIER OF PRE-PAID LEGAL SERVICES, INC.

CONSENT ORDER, ETC., IN REGARD TO ALLEGED VIOLATION OF SEC. 5 OF THE FEDERAL TRADE COMMISSION ACT Docket C-3729. Complaint, Apri/4, 1997--Decision, Apri/4, 1997 This consent order prohibits, among other things, an Oklahoma-based corporation from making certain false and misleading claims concerning the benefits and appropriateness of living trusts or any legal instrument or service it offers and requires the respondent to clearly and conspicuously disclose to consumers that such trusts may be legally challenged on similar grounds as wills, that living trusts may not be appropriate in all instances, and that the transfer of an individual's assets into a ltving trust is not included in the price of creating the trust. In addition, the respondent must offer a $165 refund to every r.urchaser of an American Association for Senior Citizens trust who hasn t already received a refund and who doesn't live in certain states that have already been offered partial refunds in connection with an earlier multi-state settlement. Apperances ~or the Commission: Elizabeth M Palmquist.

For the respondent: Margaret Feinstein, Dickstein, Shapiro, Morin & Oshinsky, Washington, D.C.

COMPLAINT The Federal Trade Commission, having reason to believe that The Administrative Company, a corporation, Michael P. Mcintyre, individually and as an officer and director of The Administrative Company, and Pre-Paid Legal Services, Inc. (''Pre-Paid"), a corporation (collectively, "respondents"), have violated the provisions of Section 5 of the Federal Trade Commission Act, as amended, 15 U.S.C. 45, and it appearing to the Commission that a proceeding by it in respect thereof would be in the public interest, alleges: PARAGRAPH 1. Respondent Michael P. Mcintyre's current address is 4328 Hollow Oak, Dallas, Texas.

Respondent The Administrative Company has ceased doing business. Its address is the same as that of Michael P. Mcintyre. Respondent Pre-Paid Legal Services, Inc., is an Oklahoma corporation, with its principal office or place of business at 321 E. Main Street, Ada, Oklahoma.

PRE-PAID LEGAL SERVICES, INC. 983 982 Complaint PAR. 2. Respondents, at all times relevant to this complaint, have advertised, promoted, offered for sale, and sold living trusts to consumers. A living trust is a trust into which an individual can place all of his or her assets during his or her lifetime and, by transferring ownership of the assets to the name of the trust, thereby remove the assets from the individual's estate.

PAR. 3. The acts and practices of respondents alleged in this complaint have been in or affecting commerce, as "commerce" is defined in Section 4 of the Federal Trade Commission Act. PAR. 4. In the course of marketing their products to the public, respondents, directly or through commissioned sales agents, have caused to be disseminated sales literature concerning living trusts, including, but not necessarily limited to, the attached Exhibits 1 and 2. This literature contains the following statements: (a) It is your legal right as a UNITED STATES Tax Payer to establish a Living Trust. By establishing a Living Trust, at your death your estate avoids PROBATING YOUR WILL which can COST SEVERAL THOUSANDS of dollars in legal and executor fees and TAKE SEVERAL YEARS before being transferred to your family and loved ones. YOU RETAIN FULL CONTROL OF ALL ASSETS! YOU COULD SAVE THOUSANDS OF HARD EARNED DOLLARS! Exh. 1.

(b) A LIVING TRUST eliminates ALL PROBATE FEES and COST.... With a LIVING 'IR.UST, your family will not have to go through probate, and can avoid paying expensive probate fees and costs. Exh. 2, p. 18. (c) A LIVING TRUST allows a quick DISTRIBUTION to your heirs. Assets in probate court are often frozen two years or more, even with a WILL. A LIVING TRUST allows these same assets to be distributed within days to your loved ones, since a LIVING TRUST avoids Probate Court. Exh. 2, p. 17. (d) Total assets [pass through a] living trust [to] spouse or heirs [in] 1-3 days. Exh, 2, p. 24.

(e) A LIVING TRUST prevents a WILL CONTEST. . .. Through a LIVING TRUST your wishes will be carried out without interference. Exh. 2, p. 17. (f) Membership entitles you to:

1. FREE LEGAL SERVICES FOR PREPARATION OF A REVOCABLE LIVING TRUST BY A QUALIFIED ATTORNEY IN YOUR STATE AND A FREE ''POUR-OVER" WILL. Exh. 2, p. 8.

(g) AN A-B LIVING TRUST protects against catastrophic MEDICAL COSTS ... . With an A-B LIVING TRUST, if you become seriously ill, your trustee can make gifts of your property to your heirs, and three years thereafter, can seek government benefits for your care, so that the bulk of your estate will go to your heirs. Exh. 2, p. 19.

Complaint 123 F.T.C. (h) Is There Anything Bad About a Living Trust? No. There is nothing bad about a Living Trust. Exh. 2, p. 20.

PAR. 5. Through the use of the statements contained in the sales literature referred to in paragraph four, including, but not necessarily limited to, the sales literature attached as Exhibits 1 and 2, respondents have represented, directly or by implication, that: (a) The use of a living trust avoids all probate.and administrative costs.

(b) At death, a living trust allows assets to be distributed immediately or almost immediately.

(c) A living trust cannot be challenged.

(d) Living trusts are prepared by local attorneys. (e) A living trust protects against catastrophic medical costs. (f) A living trust is the appropriate estate planning device for every consumer.

(g) There are no disadvantages to a living trust. PAR. 6. In truth and in fact:

(a) A living trust does not always avoid probate and administrative costs.

(b) The use of a living trust does not necessarily result in immediate distribution of assets since creditors may file claims against the trust instrument.

(c) A living trust is not immune from challenge. (d) Most living trusts prepared for AASC members were not prepared by local attorneys. Instead, of the 3,064 living trusts prepared for AASC members in 43 states, approximately 3,000 were prepared by an Arizona attorney licensed to practice law solely in Arizona and New York.

(e) A living trust does not protect against catast!ophic medical costs.

(f) A living trust is not appropriate for everyone. The determination of whether a living trust is appropriate for a particular consumer requires an examination of the assets that compose the consumer's estate, the potential tax consequences of the estate plan, and the objectives of the consumer.

(g) There are disadvantages to a living trust. For example, while probate law imposes a statutory deadline beyond which creditors can PRE-PAID LEGAL SERVICES, INC. 985 982 Complaint no longer file claims against a will, in some states, there is no law limiting the time that creditors may file claims against a tnist instrument.

Therefore, the representations set forth in paragraph five were, and are, false and misleading.

PAR. 7. Through the use of the statements contained in the sales literature referred to in paragr~ph four, ip.cluding~ but not necessarily limited to, the sales literature attached as Exhibits 1 and 2, respondents have represented, directly. or by .implication, that at the time they made the representations.. set forth in paragraph five, respondents possessed and relied upon. a reasonable basis that substantiated such representations.

PAR. 8. In truth and in fact, at the time they made the representations set forth in paragraph five, respondents did not possess and rely upon a reasonable basis that substantiated such representations. Therefore, the represent~tion set forth in paragraph seven was, and is, false and misleading.

PAR. 9. In their advertising, promoting, offering for sale, and sale of living trusts, respondents have failed to disclose that the transfer of an individual's assets into the living trust was not included in the price paid for creating the living trust and that it would be the responsibility of the individual purchaser to transfer assets into the trust, once created, or to arrange for another individual or entity to do so. This fact would be material to consumers in deciding whether to purchase a living trust and from whom to purchase a living trust. The failure to disclose this fact was, and is, a deceptive act or practice. PAR. 10. The acts and practices of respondents as alleged in this complaint constitute unfair or deceptive acts or practices in or affecting commerce in violation of Section 5 (a) of the Federal Trade Commission Act.

Complaint 123 F.T.C. EXHIDITl A.A.S.C.

- 1155 15th Street NW. Suite 8t0 Wash D C 20077 - t637 . ., . . ing~n... -' TO OPEN 'V.

IMMEDIATELY! I I 1~*I * CAR-RT-S C RT•• c~- 0 2 A37 II 0 81 4 8 1 2 S 2 6 4 154 9 541 V':~ITURA AVE SAN I'IHEO CA 94403-3223 SPECIAL BULLETIN:

It IS your le£al right as a UNITED STATES Tax Payer to establish a Living Trus:_ By establishing a Living Trust. at your death ycur estate avcids PROBATING YOUR WILL which can COST SEVERAL THOUSANDS of dollars in legal and executor fees and TAKE SEVERAL YEARS t:.efore being lransferred to your lamily anc loved ones. YOU RETAIN FULL CONTROL OF ALL ASSETS! YOU COULD SAVE THOUSANDS OF HARD EARNED DOLLARS! INFORMATION IS AVAILABLE ON HOW TO OBTAIN A FREE LIVING TRUST Just fill CL;t and ~eum this pcs:c.ge paid card . .a.c;as **'*:*t! CAR~RT- SOR T•• CR- 02 A37A _081 4812 5264 1 549 5 41 tJENTUIIA AVE SAN ~AT EO CA 94403 - 3223 ----~---..-~------lk- .1' :-··-·:- ·.: ------ ---- J PRE-PAID LEGAL SERVICES, INC. 987 982 Complaint EXHIBIT2 !;~-'. · ,

NATIONWIDE NON-PROFIT ORGANIZATION 1155 15th Street!:, N.\1'/.

Suit E 810 'ffc::~;-;w.~t ::m. D.C. ;o-:.:c·c~ 1-800-880-1310 Complaint 123 F.T.C. EXHIBIT2 . ~. .." . ;._ .. •• ~ .! ,j:;

• ',1 Dear Member: ..·. We welcome you to the wor!io~rful world of meanii'J9h.il benefits and services provided as part of your membership in .THE AME,RIQAN, ASSOCIATION FOR SENIOR CITIZENS. . · . ... _., .. . · As the senior officer of this non·profit Association. and one who is on the sunny side of sixty, I assure you I v~loe my . flil.embE!JShip and enjoy the many benefits available to all of our members. · ... ·:. .:! This Association was founded sevefC\11-years ago ~'nd entrusted with the responsibility of getting the message to people our age, $0 that we can receive every benefit and advantage to make sure the dona·rs we have. spent a lifetime earning and saving will pass on to our heirs as intact ·a~ <Under Sam.will allow. ~.. . .. With this responsibility as our driving t.drce, our.Assciciation explored every conceivable avenue available before makirig the decision to educate our membership on the value and importance of REVOCABLE LIVING TRUSTS. =r -l - :.

It is also important for you to know and ·u~derstand what this Association is committed to in regard to a PRE-PAID LE.\3AL benefit that actually pays the legal fees for your REVOCABLE LIVING TRUST. and.provides many other legal benefits. Look. at the following pages to understand our c~mmitment to you in this respect. In addition. we have sought ·meaningful and worthwhile consumer benefits and services for our membership. We are sure you can recognize the value of these benefits for you and your family. We are happy you have joined our " YOUNG AT HEART' adult Association. A living trust is the most important gift you can give to your loved ones.

Also. a portion of American Association of Senior Citizens member ship dues are used to support the research efforts of medical research facilities. and others. as they seek t;letter":treatment and cures relating to our senior citizens. AASC Medical f1eseircl1 Foundation's charter. as explained in the following section, is to continually· stay abreast of current research efforts throughout the United States to determine.who'i• • should- r..eceive financial support from the Foundation. Please kn~~ '{ve ar.e.hel-e to make things a little better for you and all of our growing family of m members. '"As soon as we receive ·your application I will see that your membership k_it is' forwarded to ,YOU.

Warmest personal regards, ,£1-.,.u.J'-t[~ Donald T. Ber!inn Executive Oirecccr PRE-PAID LEGAL SERVICES, INC. 989 982 Complaint EXHffiiT2 . ' _:-.-.

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MEDICAL RESEARCH FOUNDATION Complaint 123 F.T.C. EXHffiiT2 As Directors on the Board of AASC Medical Research Foundation, we are charged with guiding the Foundation to fulfill its charter of supporting worthy medical research that relates to better health care. for our senior citizens. In many cases, this money has a direct impact on community awareness, education and health care delivery. About our President ...

Donovan F. Ward, M.D.

AASC Medical Research Foundation President. Past President af the American Medical Association.

A Fellow of the American College of Surgeons. President of the Fifty Year Club of American Medicine. Member of the AMA's committees on Medical Practice and Public Relations.

Past President and National Director, American Health Care Advisory Found;:;tan.

PRE-PAID LEGAL SERVICES, INC. 991 982 Complaint EXHTBIT2 Our other Directors are ... Robert P. Ewing, is pas• Howard E. Cartwright, Chairman and President of of Chicago is past CEO of Bankers Life and Casualty College of American Company and is a rustee of Pathologists. past Director of the MacArthur Foundation. a College of American Qirector of Ewnston Illinois Pathologists.Foundation and a Hospital and a former Director member of American of the Health Insurance Association of Medical Society Association of America. Executives. • Denis J. Fu, M.D., a Joseph W Lawrence, M.D,, Samuel A. Sherman, M.p., practicing physician in Hawaii. has a long and distinguished has a long list of · has served as a medical career in PIJblic Health and is accomplishments including: consultant for various· s::ate currently the Health Offi1:2r fer past President of the California and national development Lee Count'i. Aorida. a positicn Medical Association. programs. he has held since 1960. All of our listed Directors are also members of the Advisory Board of American Alexander L Sadowski, Donald T. Berlinn, has Association of Vice President has accumulated ovee been D.D.S., of ITT Senior Citizens and l.Jfe Insurance Company hours of cont inuing 1000 education. served on the New Agency and President of advise the Mexico State Dental Medical Air Services Assoc:atJon's Finance Association. the nation's firs• Association on Comnllttee and is bot.~ past nat•onwide air ambulance president and secretar·1 of tle service. Currently Fres•dent developing new Sout hwest D•str.ct Oe~tcl of Affordable Dental Soc:ety. Connec::on and Asscc:ator: benefits or improving Manaoement Group ar.c existing benefits for- Fresicie~t of Arr.er.can Ass\;c;at;cn for Se:""10r our senior citizens. C.:::ze.,s r I Complaint 123 F.T.C. EXHIBIT2 Financial support is provided by the AASC Medical Research Foundation to the following and other research facilities: • American Medical Association • American Heart Association • American Public Health Foundation • . Alzheimers Disease and Related Disorders Association • California Medical Education and Research Foundation • Leukemia Research Foundation • Mt Sinai Foundation • National Multiple Sclerosis Society • National Kidney Foundation • Regional Cancer Treatment Center - Iowa • University of Iowa Dept. of Immunology • University of San Francisco Cardiovascular Research In addition, the Foundation has given grants to the following, and others: ON LOK Senior Health Services Cancer Research Foundation Iowa Methodist Health Foundation of North Texas March of Dimes - Walk America Allegheny-Singer Research Institute University of Iowa College of !Yiedicine University of Florida - Oncology San Antonio Area Lupus F9undation St. Jude's Children's Hospital Tulane University Medical Center, Sloan-Ket tering Cancer Center Dept. of Pediatric-Cardiology North California Transplant Sank Cancer Counseling, Inc. ALB & Neuromuscular Research Tarrant County Cancer Care Services Foundation Cystic Fibrosis Foundation Children's Hospital Medical Center Univ. of Connecticut Health Center Florida G-eriatric Research Jean Marie Colbert Bone Marrow Foundation Transplant Center Regional Cancer Foundation Children's Heart Foundation Children's M emorial Foundation Fred Hutchinson Cancer Research Cancer Care Services Center Tne AASC M ecical F<esear::~ F~ur.cat:on was formerly known as the American Health Care Advisory Assoc'at:on F~undat:on. providing ftnanc:al sucport to c.~e above and other l""!!searc.~ faciiit:es. PRE-PAID LEGAL SERVICES, INC. 993 982 Complaint EXHIBIT2 AASC Provides for its Members the Benefits of Pre-Paid Legal Services, In.c.® A lew ol tile most common person! worrii!!S and bus-.ess ac:.vit1es needing an atwmey"s professional counsel and assis::ance include:

Ttwut:cil~ oeoc~ -- c-.-Fnuo Aa,co hnucCO\ ~- Colnttx:.or" c........ - -f'"'""'l•"'-""'~ or.cu.. """'""'-~MHc-oo ~--- ......e-.c.... en.......,._Aoou.... -..... Ctvnn- Tl'rr.IU Brinlotcvj i An American Stockl Exchange Company Paid Over 80,000 Attorneys Paid Over $80,000,000 in Legal Fees Over 5,000,000 Members Have Access to Services Nationwide Complaint 123 F.T.C. EXHIBIT2 embership entitles you to: fij} FREE LEGAL SERVICES FOR PREPARATION OF A REVOCABLE LIVING TRUST BY A QUALIFIED ATTORNEY IN YOUR STATE 1 AND A FREE "POUR-OVER" WILL (see following section) LEGAL SERVICES .AT DEATH 2 IN-OFFICE ATTORNEY CONSULTATION 3 UNLIMITED TELEPHONE CONSULTATIONS WITH A PROVIDER ATTORNEY 4 MOTOR VEHICLE LEGAL SERVICE s TRIAL DEFENSE FUND 6 IRS AUDIT PROTECTION 7 LEGAL ASSISTANCE IN MANY CASES 8 PRE-PAID LEGAL SERVICES, INC. 995 982 Complaint EXHffiiT2 nlimited Telephone Consultations: [J} • As a member of AASC. you may call the Pre-Paid Legal Toll-Free Number, 1-800- 654-7757. from 8:30 a.m.-5:00 p.m . any business day. Pre-Paid Legal will direct you to your provider attorney for legal advice. • You do not need to guess about your legal rights or spend hundreds of dollars for consultations with an attomey. In the privacy of your own home, you simply call the attorney and he will answer questions concerning ANY personal or legal matters. The following are just a few examples of the types of questions you may need answered:

1. "I am 67 years old and collecting social security. Is it legal for me to claim a deduction for a dependent who earns an income?"

2. "My company is trying to force me into retirement by offering me an early retirement buyout. What are my rights?"

3. "It has been 12 weeks since I was in the hospital and my insurance company has still not paid the $1,500 hospital bill. How long do they have to settle the claim?" 4. "My neighbor's teenage son, despite my requests to stop, continues to play loud music that keeps me awake at night. Is there anything I can do?" 5. "I had a contractor fix my roof, it still leaks and the contractor will not return my call. What can I do?"

6. "My husband is in a nursing home. I do not· feel he is getting the proper care. Aren't there certain standards set by the state that nursing homes must follow? What are my husband's options?"

7. "I inherited some land in another state and I would like to lease it out. How do I do this?"

In addition to advising you of your rights, the attorney, if necessary, will personally call or send a letter to help resolve your problem. Complaint 123 F.T.C. EXHIBIT2 P to SO Hours Legal Assist~·nce [!] at Death: Everyone needs a lawyer upon the death of a family member for settlement of the estate and. consultation with the surviving spouse or children: • To finalize trust documents • To resolve. liens contesting the trust, including the IRS • For out-of-state property settlements and property sales· • For deed transfers • To resolve claims of creditors, including hospitals, funeral homes, etc. • For protection against any perspn who attempts to challenge the estate The settlement of an estate is a complicated and lengthy process. Qualified attorneys usually charge between $175-$300 per hbur for their services. This translates into a cost of approximately $8,750 - $15,000 for 50 hours of legal assistance to settle an estate. As a member of AASC, your membership entitles you tG up tG 50 hours of legal assistance, depending on your member classification. A True Story;

A Senior Citizen of Dixon, Illinois joined AASC in June of 1991. In July. 1991, he passed away. His children, rather than beginning the long and costly process of finding an attomey to probate his estate, simply called the AASC members' toll-free number. A Pre-Paid Legal attomey immediately began to settle the estate. "My father only became a member six weeks ago but we feel so fortunate that he did We immediately called a provider attomey and were so relieved to learn that we would have the legal work on my father's estate done immediately thanks to Pre-Paid Legal The service is invaluable," said the daughter. PRE-PAID LEGAL SERVICES, INC. 997 Complaint982 EXHIBIT2 n -Office Consultation: 0 ONE PER YEAR AASC provides its members with a Living Trust. Each year· it should be reviewed and updated with changes concerning: • Any Legal Matter • Investments • Deeds • Property and Real Estate • Cars, Trucks· and Equipment • Bank Accounts • C.O.'s Complaint 123 F.T.C. EXHffiiT2 motor Vehicle Legal Service /l)] Expense Benefits: Nearly every American drives some form of mqtor vehicle every day. You are at risk, ~very time you get behind the wheel of your car.· AASC is proud to offer you a wide variety of coverage in the area of motor vehicles. Read below to discover the valuable benefits you will have after enrollment . . ~ MINOR LEGAL EX PEN lies: If a Hcensed member, spouse, or any covered dependent, while· driving any licensed motor vehicle, i10 accused of an alleged traffic violation, the Company pays your attorney fees, pursuant to the following schedule: Up to $75 for legal assistance regarding such charge; up to 5125 for legal assistance requiring court appearance; up to 5200 for legal assistance which includes trial work. • MAJOR LEGAL EXPENSES: If a licensed member, spouse or any covered dependent, while driving any licensed motor vehicle, is accused of a criminal charge such as manslaughter. involuntary manslaughter, negligent homicide or vehicular homicide, ~he Company will pay your attorney fees based on a maximum hourly rate of $100. • SUSPENDED DRIVER'S LICENSE: The Company provides for professional assistance, and if necessary, maintenance of your driver's license. The Company will pay a reasonable attorney fee for the suspended driver's license services up to $250 per occurrence to your attorney. , • LEGAL COLLECTION SERVICE: Should your licensed auto. private boat or motorcycle be damaged in an accident, the Company will assist you in collecting damages done to your vehicle. The Company provides legal assistance, win, lose, or draw. in collecting damages when your auto, private boat or motorcycle is involved in an accident, and will pay up to 5250 per occurrence to your attorney... • PERSONAL INJURY LEGAL EXPENSES: The Company will pay your attorney fees. win, lose, or draw. up to $250 per occurrence to collect or file for personal injuries of $1000 or less received while driving. riding. or when struck as a pedestrian by any motor vehicle·.

-. - .. . ·--~-:.. . -~~- - __ __ PRE-PAID LEGAL SERVICES, INC. 999 982 Complai_nt EXIDBIT2 5,000 Trial Defense Fund:· • I fJ All too often you read in the paper about someone being sued over what you would consider a trivial matter .. . It couldn't happen to you. But everday. people just like you are sued by neighbors. friends. co-workers. even family. In this sue happy society, it is great to know that your AASC membership offers benefits to cover just that. The Company will pay up to a maximum of $5.000 in attorney fees the first membership year for either the member or members spouse, if he or she is named Defendant or Respondent in a covered civil or criminal action in a court of law. The criminal action must be one which arises aut of the direct performance of the Covered Person's employment activities. The trial defense fund benefit will even pay for the attorney even though your insurance company may have retained one for you, if the choice of attorney is not yours and you feel you need your own personal attorney.

BENEFITS TO BE PAID AS FOLLOWS:

Benefits are based on a maximum hourly rate of $100 and are to be· paid as follows: Up to 5250 for any and all legal services rendered in defense of the covered lawsuit prior to the actual trial.

Up to 5300 per day for each actual day of trial, including covered crimi,al preliminary hearings not .to exceed .an annual aggregate trial defense fund pf 55.000 per membership. Upon renewal of the membership the Covered Person will receive additional trial defense benefits at no additional cost to the member. The trial defense fund increases. as follows: 2nd The trial defense fund will be increased to an annual aggregate sum of $10,000 Year Renewal per ~embe~ship payable up to $300 for any and all legal ser:vic~s re~dered. p~or l preliminaryto tnal andhear1ngs.up to $350 per day for each actual day of tnal, including cnm1nal l 3rd The trial defense fund will be increased to an annual aggregate sum of $15,000i ~members ser:vic~s re~dered. p~ior hip payable up to for any and all legal $350 to tnal and up to per day for each actual day of tnal, including cnm1nal $400l' Year Renewal preliminaryper hearings. 4th The tnal defense fund will be increased to an annual aggregate sum of $20.000 Year Renewal per membershrp payable up to $400 for any and all legal servic~s re~dered prior to trtal and up to $450 per cay for esch actual day of t nal, 1ncludrng criminal preliminary heartngs.

5th The trial defense fund will be increased to an annual aggr egate sum of $25.000 Year Renewal ;:er membershtp pay':ble up to $450 for ~ny and all legal services render ed prior to tr:al and uo to S.::;OO per day for e.=cn ac::;al day of trtal. tncludtng crimtnal preliminary he:r:nc;s. - : :.;; • .:..-e.-c.:ir: ..!.,;s.::c .;.: -;;, 'cr Etr~er .:.c..:!"S rooo FEDERAL TRADE COMMISSION DECISIONS Complaint 123 F.T.C. EXHffiiT2 RS Audit Protecti<:m Service: 0 I.R.S. . .. The idea of an audit strikes fea_r in even the most careful tax payer. Why not enjoy the peace of rfiind that the AASC membership offers through the IRS Audit Protection Service? Here are the details. · - The Comp~ny . will pay up to a maximum' of $5,000 in professional fees for either the member, spouse, or dependent children. to the member's choice of any licensed pubfic accountant, certified public accountant. enrolled agent or attomey or any combination thereof when a member is. notified in writing by the ' tn~email Revenue Service liRSJ of an audit of such member's tax return or such member is requested in writing tq appear at the offices of the IRS concerning such _me;n!;leriHax return . . BENEFITS TO BE PAID AS FOLLOWS;

Up to s1oo for cbnsultation, -advice and/or as-sistance, ~pen receipt of written notice from the IRS that the member's tax retum is being audited·or such member is requested in writing to appear at the offi~es of the I~S concerning such member's tax return. In the event settlement is not achieved with the IRS within thirty. C30J days, then up to S25o· beginning orr the thirty-first C31 l day to provide the member, spouse, or dependent children representation at the audit and at the audit and for negotiations, conferences, telephone conversations, settlement conferences, subsequent thereto, but.prior to the institution of litigation. In the event settlement is not achieved without litigation, then payment will be made up to the balance of $5,000 in professional fees in either event of the IRS suing the member or the member paying the disputed tax and then suing the IRS. Such payment to be ~ade at up to a rate of 5300 per day of each day of trial appearance. Coverage begins with the return due on April 15 of the year this contract is eHeotive.

PRE-PAID LEGAL SERVICES,' INC. - .·1'001 982 Complaint EXHIBIT2 J •• 't . .

M~n)/ Ca~e~: IJ'e~~j Assistance in .. - •' . AASC membership provides• ' · • legal-·' ..., •• • '. ·J a . • . ' in.r;npny cases..· including as~is.tance. . .{ .. \ .· r .the,.fo/lowing . ~- ._. , 1· ... .. .. "="·· PHONE CALLS AND Letters ON YOUR BEHALF- A letter or phone call from your Plan Attorney can get you the results you want fast and cut through the red tape. You and your Plan Att;orney can nq~ qecid~.togethflS ~hen this is the best legal step for you. There is no charge forthe first letter. U'J.i;y 'further ·· f.ees are to b~ ~et .by the Plan. Attorney .and are: . the sole re~pan~jiib.iljty af the Named Member ~n .the Co"tracts . . . _ . • . ·, -:~. .. . ...; --: - i·- • . - REliiEW OF CONTRACTS AND DOCUMENTS , You can ~ave an unlimited number of legal documen~s of up ,to three pag~s. each reviewed by your Plan Attorney, free of charge. Your . Plan Attorney. will1,give you · an analysis of the dfilCUments -and sugges-t changes for your benefit or any Other necessary. proqedures. before you sign! LEGAL FORMS BENEFIT Imagine having access to. .the most often needed legal -d9cur:nents - just a phone call •.. away! :·Jh~ .'d.ocume~ts you need will be prepared for you at a greatly .reduce.d ~te. but don't worry, still with the same care and concern for your welfare. A list of legal forms a~ailable. along_with the nominal charges, will-be in your contract -packed~ Complete ,informa~ion about the forms you need can be obtained with just a phone call to your Plan Attorney. Complaint 123 F.T.C. EXHIBIT2 . .

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:j~ :_; ~;;' i_, ...·.':.. ; . I - · ALL ABOUT A LIVING TRUST 4llf41!1~-""""=--'-""""'= ------ -- --------------------"""""""'"""'' "'"""'"""'....,;... PRE-PAID LEGAL SERVICES, INC. 1003 982 Complaint EXHIDIT2 dvantages of a Living Trust {jJ PROBATE:

A LIVING TRUST avoids a complex PROBATE proceeding. Probate is the court pro- 1cess designed to transfer title of assets to your heirs. A Probate is required even when there is a WILL The Probate Court procedure is complicated by laws requiring your Executor to obtain special court approval to take any actions, including paying your bills. and distributing your assets.

With a LIVING TRUST, the title to property is transferred through the trust, so that your heirs can easily receive these assets, and will not have to go through complex Probate Court proceedings.

DISTRIBUTION:

A LIVING TRUST allows a quick DISTRIBUTION to your heirs. Assets in probate 2court are often frozen two years or more. even with a WILL A LIVING TRUST allows these same assets to be distributed within days to your loved ones. since a LIVING TRUST avoids Probate Court. PRIVACY:

A LIVING TRUST is completely PRIVATE. There is no privacy with a public Probate 3Court Proceeding. A LIVING TRUST is a private document, the size and distribution of your estate remains confidential.

WILL CONTEST:

A LIVING TRUST prevents a WILL CONTEST. In Pro!:!ate Court, anyone can easily 4contest a WILL. even without a lawyer. Through a LIVING TRUST your wishes will be carried out without interference. CONTROL:

A LIVING TRUST enables you to CONTROL your assets. By making a gift of all of 5your proper t y t o your heirs. you may eliminate probate. However, once the gift is made you have lost ownership of your proper t y. which you may later need for your support.

A LIVING TRUST allows you to retain control of your property, and upon your demise. YOU CONTROL WHEN AND HOW MUCH YOUR BENEFICIARY WILL RECEIVE. Complaint 123 F.T:C. EXHIBIT2 DISABLED HEIRS:

A LIVING TRUST preserves benefits for DISABLED HEIRS. A disabled their· gene~ally 6loses government assistance payment.s upon receiving an inheritance. . A LIVING TRUST can authorize your successor trustee to make special distributions for a disabled their while still preserving government·benefits. PROBATE FEES:

A LIVING TRUST elfminates ALL PA08ATE FEES and COST. Probate tees are based 7on the entire value of an estate, without deducting bills or '!.'ortgage. The probate expense can be as much as the foiJowing, or more: GROSS ESTATE SIZE ·APPROXIMATE EXPENSES $100,000. $10,000. . $300,000. $30,000. $500,000. $50,000. This example also applies to all other mortgaged property owned in every state. If a couple owns property in four states there would bt:: four probates required. With a LIVING TRUST, your family will not have to go through probate, and can avoid paying expensive probate fees and costs.

JOINT TENANCY:

A LIVING TRUST avoids JOINT TENANCY problems. Joint tenancy is: a ·method 8 of avoiding probate, where, upon death of one co-owner, the survivor becomes the full owner of the property.

1. As an owner, yo.ur child has the power ' to interfere with your decision to sell or refinance the property.

2. If your child should go through divorce, the other spouse may claim an interest in the property.

3. If your child should owe taxes, the tax collector may take your property to satisfy the tax obligation.

4. If your child should be found liable in any lawsuit, your property may be sold to pay the judgment.

With a LIVING TRUST. probate is entirely avoided and there is not exposure of your assets to the debts or liabilities of your child. CONSERVATOR:

A LIVING TRUST avoids a CONSERVATOR. If you ever become incapacitated, the 9Probate Court will appoint a conservator to manage your property. and your estate will be required to pay court fees and costs for the conservatorship each year. With a LIVING TRUST. your t.-ustee can manage your property if- you are unable to handle your affairs. and ther e are no court fees and costs. PRE-PAID LEGAL SERVICES, INC. 1005 982 Complaint EXHffiiT2 INCOME TAXES:

A LIVING TRUST saves sizeable INCOME TAXES. When a couple holds property 10 or stocks in joint tenancy, the surviving spouse is required to pay a capital gains tax upon sale. This tax is based upon one-half of the increase in value of the property since the time of its purchase.

In a LIVING TRUST. title is transferred into the trust. This entirely eliminates ·the Federal Capital Gains Tax on all increases in value up to the date of death. ESTATE TAXES:

An A·B LIVING TRUST saves substantial ESTATE TAXES. Estate taxes are paid 11 to the federal government for the transfer of property upon death. Federal estate taxes are based on the size of the estate and are imposed where the net value of an estate is larger than $600,000.00. The Federal Estate Taxes are almost onehalf of the estate after deducting $600.000.00. A Living Trust saves substantial estate taxes as follows: NET ESTATE APPROXIMATE TAX SAVINGS $ 800,000. $ 75.000. $1,000,000. $153.000. $1,200,000. $235.000. MEDICAL COSTS:

AN A· B LIVING TRUST protects against catastrophic MEDICAL COSTS. If you 12 should ever require care in a convalescent hospital or long term nursing home, the medical expense could eventually wipe out your estate, thereby denying you the opportunity to leave your property to your loved ones. With an A-8 LIVING TRUST. if you become seriously ill, your trustee can make gifts of your property to your heirs, and three years t hereafter. can seek government benefits for your care, so that the bulk of your estate will go to your heirs. 1006 FEDERAL TRADE COMMISSION DECISI<;:lns Complaint 123 F.T.C. EXHIBIT2 questions Most Commonly Asked [!} Q: Is There Anything Bad About a Living Trust? A: No. There is nothing bad about a Living Trust. It is a traditional and well-proven estate planning tool that has been used, in one form or another, for hundreds of years.

Any problems people have with a properly prepared Living Trust have nothing to do with the trust itself, but with the property left out of it because they failed to change titles and beneficiary designations tb the name of their trust. The trust still works - but any property left out risks being probated. If you desire to completely avoid probate, all assets must be in your Living Trust. It does not take much time to change the titles and beneficiary designations, and once it is done your Living Trust is easy to maintain.

Q: Wt'!ere Should I Keep My Living Trust Documents? A: We suggest that you make several copies of your original documents and give a copy to each of your back-up trustees. Make sure you tell them where the original documents are located. We suggest you keep the original trust document in your safe deposit box or another safe place and keep one copy at home so you can review it from timf;l to time. !Make sure your safety deposit box is titled in the name of your trust. so your back-up trustee will have no trouble gaining accessJ Q: Can I Put Out-Of-State Property Into The Trust? A: Yes, you can, and in fact, you should. It you do not transfer out-of-state property into your trust, your heirs will need to have a separate probate in each state in which you own real estate. This may result in probate fees for each state. If, however. the property is transferred into your trust. the probate systems of all of the states ·involved are avoided.

Q: What If I Move To Another State? A: Call Pre-Paid Legal at 1-800-654-7757 to locate a Pre-Paid attomey nearest you. Ask for a review. M ost states follow the same general rules, so if something needs changing, only those parts are changed that need to be under the laws of that state. You do not need a completely new document. Q: What If I Buy Property In Another State? A: Before you buy property in another state. especially real estate. check to make sure it can be titled in the same way as in your home state. A bank or title insurance company in the state where the property is locat ed can tef you _if the title you want to use is acceptable in that state.

PRE-PAID LEGAL SERVICES, INC. 1007 982 Complaint EXIDBIT 2 Q: Does Transferring Property Into a Trust Cause a Reappraisal Of The Property So That Property Taxes Are Raised? A: No, it does not. Revenue and Taxation Code 62 specifically st at es t hat a t r ansfer into a Revocable Living Trust does not cause a reappraisal of the property. Q: How Should Property And Accounts Be Titled? A : As a general rule. all of your property should be tit led in the name of your t rust. Here are some examples:

If you are single:

"(your namely, Trustee under trust dated (insert date you signed your trust]." If you are married:

"!your name and your spouse's namely, Trus tees under trust dated !insert date you signed your trustl."

Very often you will see the letter s "UTO" used as a shortened version of the words "under trust dated."

Q : If I Own Partial Interest In Property With Others, Can I Transfer That Interest Into A Trust? A : Yes. You can t transfer your share of any property into the t rust without affecting the shares of the others. · Q : If I Want To Sell Assets Or Add New Assets To The Trust, Will I Need To Return To The Attorney's Office Each Time? A: N o. you w ill not. You can sell assets and add new assets yourself without requiring a change of the trust.

Q: Can I Sell Assets I Have In The Trust Without Any Complications? A : Yes, you can. You can freely sell your property even if it is in the name of the trust. The only differ ence will be that escrow company officials may ask for a copy of the trust document s.

Q : Can IRAs, KEOGHS And Other Tax Deferred Investments Be Transferred Into The Trust? A: IRAs. KEOGHS and ot her tax deferred investment s cannot be transferr ed into the trust. However. the trust can be the beneficiary of those investments. Each case must be discussed with an attorney t o determine whether 1t is better to name the trust as beneficiary. or the individuals themselves as beneficiaries. ..

Complaint 123 F.T.C. EXHIBIT2 Q: What About Adding Other Persons On My AccountsrOeeds, Eti:.? A: Never add another person on the title of your property or your accounts (this includes parents and children) without first checking with your attorney. It could cause you or your family some very serious problems. possibly even defeating the purposes of your trust or exposing you to a lawsuit. Q: When Willi Need To Update My Living Trust? A: There is no special time to change your trust, although it; is a good idea to review your living trust at least every year. As a general rule, you should change your trust anytime it no longer is what you want. Any major chaf]ge in your family, such as marriage. divorce, death, adoption. birth, etc. should cause you to think about your trust. If one of your trustees/guardians can rio longer fulfill their responsibilities you should make changes accordingly.

Remember that you should keep a separate list of your Special Gifts. Q : How Do I Fund My Trust? A: YOU CAN FUND YOUR TRUST BY THE FOLLOWING THREE STEPS: 1. Go to your bank and change the name .on savings, money market and certificate of deposit accounts to the name of the family trust. Also. place trust in safety deposit box.

2. If you own stocks or bonds. contact your stock tiroker to change the name to the name of the family trust.

3. Finally, if you have real estate, you may use. the Quick-Claim Deed to transfer it yourself or you may contact a title company to transfer the title to the name of the family trust.

IF YOU HAVE ANY QUESTIONS CONCERNING THE FUNDING OF YOUR TRUST. CALL PRE-PAID LEGAL AT 1-800-654-7757.

· PRE-PAID LEGAL SERVICES, INC. 1009 982 Complaint EXHffiiT2 isadvantages of Going Through Probate [jJ l. Impounded or frozen accounts 2. lmpoun~ed safety deposit box 3. Probate court cost (100/o or morel 4. Waiting period 11-3 years) S. Attorney fees (very costly) 6. Administration fees 7. Public disclosures . 8 .. Impounded mail 9. Forced asset liquidations 10. Expensive litigation 11. Possible Federal Estate Taxes and/or State Inheritance Taxes Complaint 123 F.T.C. EXHIBIT2 eath Probate versus [jJ Revocable Living Trust Total Assets • Home • Auto • Cash • Land • C.O.s • Real Estate • Savings • Ute Insurance • Checking • Pension Anything of Value Probate Process Living Trust 7 • You\maintain control while you are • Attomey Fees alive • Administrator Fees • You name someone you trust to handle Assets after death • Possible Contestibility • Avoids Probate • Public Disclosure • No Delay • Impounded Assets · • Privacy • No Impounded Assets / SPOUSE 1-3 1-3 or YEARS DAYS Heirs PRE-PAID LEGAL SERVICES, INC. 1011 982 Complaint EXlllBIT2 reventing These Situations {i A LIVING TRUST WOULD HAVE PREVENTED THIS SITUATION: Martha had been a widow for just one year when she put all of her property, including her house. into joint ownership with her married son. She did this thinking that when she died. her property wou_ld automatically go to her son without the need for probate. Several years later. her son and his wife separated and Martha decided to sell her house so she could move in with her son. But she soon discovered she could not sell the house without her daughter-in-law's signature on the· deed. The daughter-in-law was still legally married to her son and was entitled by law to a "marital interest" in the property. The title company would not insure clear title to the buyer without the daughterin-law's signature because it was not clear what her "interest" would be- and the daughterin-law refused to sign unless she got part of the money when the house was sold. Martha was stuck! She did not know that joint ownership with a married person can include that person's spouse. And because Martha had placed her house in joint ownership. Martha lost control of her own home.

A LIVING TRUST WOULD HAVE PREVENTED THIS SITUATION: Bill and Agnes were an elderly couple who put everything they owned ... including their home and stock . .. in their adult unmarried daughter's name. They believed that this would avoid probate and that all of their property would pass directly to their daughter who was an only child, when they were both gone. A year later, Bill died of a heart attack. Several months after that. the daughter was killed in an auto accident. Agnes never believed she would survive both her husband and daughter. To add t o her distress, Agnes now owned nothing in her own name. Everything was in her daughter's name! She was forced to probate her daughter's estate to get back her~ property. During this long process she had to rely on the court to grant her living expenses. Sometimes the court would approve expenses • - . sometimes not- And during a declining stock market. she helplessly watched the value of her stocks fall to only a fraction of their previous value because the court could not react in time for them to be sold quickly enough. Agnes lost her financial independence plus a substantial portion of her assets to probate ... just trying to get back what was hers in the first place. THE CONSEQUENCES IF A JOINT OWNER CANNOT SIGN: Most married couples own their property jointly, and they assume that if one of them becomes disabled or incompetent. the other can continue to take care of their personal and financial affairs without interruption. But look at what happened to Henry and Mary:

Henry and Mary were success ful and responsible adults. They made safe investments and planned carefully for their future. They owned ever ything jointly and even had WILLS, leaving everything to each other. But in jus: seconds their lives changed drama.t.c.ally. Henry was in a tragic car accident, anc suffered e.~tens ive head injuries and I<H2' FEDERAL TRADE COMMISSION DECISIONS Complaint 123 F.T.C. EXHffiiT2 brain damage. Mary could continue to write checks and pay their day to day bills because only one of their signatures was required on their checking account. But soon the cash started running out, and Mary r ealized she needed bl sell some of their investments, and maybe their house, to pay for Henry's care and the other bills. Mary was unable to sell any of their jointly owned property without both signa~ures. and since Henry could not sign his name, the only way Mary could sell their property was to place Henry inbl a probate guardianship. and have the court sign for him. Henry's WILL was no help at all because he was still alive.

Mary had no idea how expensive and. cumbersome this legi:JI "joint ownership" can be. Not only did she have to deal with Henry's situation and the .effect of this tragedy on their personal lives, but she also had to deal with the !=Court system. She was especially frustrated that she had to pa,y for the court to approve the sale of their awn property and then get the court's approval on how Henry's. share of that money was spent even when it was used to pay their personal bills and take care of Henry! When Henry finally died more than ·five years later, Mary fourid herself back in probate court - this time to probate Henry's WILL THE SAME THING CAN EASILY HAPPEN TO YOU if you own property through joint ownership. Many older parents list their adult sons or: daughters as joint owners on their property £especially real estate and C.D.sl. mainly to. avdid probate when they die. A1Jd many mistakenly assume that their adult child will automatically be able to take over for them if they become disabled or incompetent. !y1ost people·;ust do not know how easily join~ ownership can lead to a probate guardianship: ·, · ~5 PRE-PAID LEGAL SERVICES, INC. 1013 982 Complaint EXHIBIT2 OTHER MEMBERSHIP BENEFITS& SERVICES 1014 FEDERAL 1TRADE COMMISSION DECISIONS Complaint 123 F.T.C. EXHIDIT2 medical Air Ambulance Services l1!il Specialized Facilities ... often at distant locations, available to our members at NO out-of-pocket cost when the need arises.

Ten Separate Services .. . Some Lifesaving . .. Some Peace of Mind:

• EMERGENCY AIR TRANSPORTATION to any specialized hospital in the nation with what could be the single life sustaining element available to you or a member of your family.

• ESCORT TRANSPORTATION for your spouse, family member or companion to accompany you in flight if space permits. • NON-INJURY TRANSPORTATION to have a family member flown round trip by common carrier to the city where you are hospitalized for more than seven days. · • REPATRIATION, should the patient and his attending physician determine that recuperation nearer home is feasible, air transportation will be provided. • ORGAN RETRIEVAL/ORGAN RECIPIENT TRANSPORTATION. If a member requires a heart, heart/lung, liver, kidney, lung, or pancreas transplant, this service will transport the organ to the recipient or fly the recipient candidate to the organ.

• RETURN TRANSPORTATION either by air ambulance or scheduled air carrier for your return home.

• MINOR CHILDREN RETURN, including an attendant, if necessary, when minor children are stranded as a result of you being hospitalized out of town. • VEHICLE RETURN. Privately owned or rented cars, vans. motorhomes, or travel trailers left unattended as a result of the medical emergency will be returned to your residence.

• PHYSICAL REMAINS RETURN. \Nill return mortal remains. PRE-PAID LEGAL SERVICES, INC. 1015 982 Complaint EXHffiiT 2 Listen to What People Say About Medical Air Services: louis C. Timrr. Katherine G. Bennett 716-328-9824 • Rochester. New York 716·637·646B • Brockport. New York ''We could not have asked for better creacm!"nc. "The Bennetts are staunch believers that everyone in fact we have been ceiling our friends abour: should be a member of Medical Air Services. lflu MASA." showed concern far beyond the service anyone could e~pect. "

lee and Violet Frost Margaret Kreutzer 618-832-6538 • Anna, Illinois 204-326-9972 • Edinburg, Texas "We are satisfied with your service we take eve~y opportunity to encourage friends r:o enroll m "I am very pleased with the services I received from MASA." your company after the death of my husband." Mrs. James rThelmal Wilkinson Frankie Adkins 515-652-3244 • Ottumiba, Iowa 512-42B·2534 • Brunswick, Missouri "~ made a call to Medical Air Services and fo(ind 'We have only good thoughts and remarks to make of Medical Air Services. •· out our daughter's flight to be with her critically ill father would be caken care of. We certainly thank your "flight for life" service and don't .intend to be Mr. Victor 5 . Kalinoski without it." 218-681-4767 • Thief River Falls, Minnesota "It was a 400 mile trip one way. We were very Mrs. Joyce Evans pleased in that no time was wasted and everything 816-638-456.1· • Urich. Mis.souri seemed very well planned. We recommend this "Words cannot e~press what I feel for your com- service very highly. " pany. lbu were all so helpful and courteous. I would love co enroll some of my friends who have not heard Harold and Ruth Wendt of'your services. Piease send me some enrollment 715-229-2770 • Owen, Wisconsin applications." "I am now well on che way cc recovery from open heart surgery while in Te~as in April We e~pre.ss Stanley Snodgras·s our special thanks for the fine and prompt serwce 513-922-4562 • Cincinnati, Ohio. Medical Air Services provided during our emer · MASA will always be a pare of our insurance pro- gency. Besides providing air service home, we es- gram as long as it is ava1table to us. On a scale pecially appreciated having a driver take our auto- of one to ten, we rate you a ten plus." mobile 1700 miles to INisconsin. • Mr. and Mrs. Robert Taylor Christine J. Adamson 612-894·9709 • Bumsville, Minnesota 313-659-6080 • Flushing, Michigan "We wish to thank you for the "hassle free" way "We feel this service is very valuable for the security in which you handled all the arrangements co fly it provided and we feel it is one of the best invest- me ar:Jd my injured husband home after he fraccu:-ed ments we have ever made." a vertebra in his back. We say thanks for all your help.· Bruce Theel 701-477-5244 • Rolla, North Dakota Helen Redekal "Your company 1S providing a cn'cical medical service 507·938-4241 • Canby, Minnesota co the population living in remote areas. without "In this day and age it is very difficult to believe air facilities closer to major medical centers. Could some company would stand behind their premises you sell hospitals such a service. so that more and re:ct sa efficiently and promptly in our cris[s. people are infcrmed of this marvelous service you 1 hishly rec:Jrr.me'ld this service ta e2c.'1 and give ct s;..:ch a re5scnccie rate?" everiDne." Complaint 123 F.T.C. EXHIBIT2 Prescription Program fl:EJ The lowest price available at your local pharmacy! • Over 30,000 participating neighborhood pharmacies • Fill all your prescription needs AT or BELOW average wholesale prices ail Order Pharmacy fJ!j} #;;.·, - The preferred option for maintenance medications! • TOLL FREE ORDER - Comparison cost line • NO shipping or handling charges • Doctor-Verified prescriptions • Easy to use • Convenient at-home delivery Savings that really add up! PRE-PAID LEGAL SERVICES, INC. 10l7 982 . Complaint EXHIBIT2.

[fordable· Dentii) Conn·ectionl !IJ Free & Discounted Dental Service • FREE Oiagn.o~s :

• FREE Dental History • FREE Bite ·Wing X-Rays • FREE Flouride Treat}nent for Child.ren·"': · • FREE Oral· Hygiene lnstructiOI}S • FREE Oral Cancer Examination .....

Discounts of 20°/o to 50°/o off the ' Dental Providers sua/ and.custi:;mary.ll fees. • Prosthoaontists • General ~entis tr~ • Orthodontists . -~.. . . . : • impl.antologists. • Endodontists .. ,..

Complaint 123 F.T.C. EXHIBIT2 yewear Savings /1 SPECS brings you savings at Sears, Montgomery Ward, JC Penney, Dillard's, Mqrsfiall Fields,_.RQyal Optical and riiany.:·_~th~ij stores.

You recejve the SPECi:LVisipri Ptan free .~s . It's so easy! There's no waiting, no forms to part of your member.1j:lip benefit !')package.:.. complete, and no limitations - all merchan- The SPECS Vision Plan is Cls(gned .to offer . dise is in.cluded. Most locations are open both you and you.r . family $avil!§s 'bf IJP.'to evenings and weekends for your convenience. 60% on all your eye care l)needs. . . And, you can pay for your order with your store credit card. Simply present· the SPECS card at any of the 1,500 participating· Sears; Montgomery Ward, ·Jc Penney; Dillard's, Marshall Fields, Royal Optical and many other eyewear departments located throughout the country and let the savings begin TYPICAL SAVINGS YOUR Frames Cost Frames up to $54 retail - you save 600fo .............. .. ... ........ $20.00 Frames $55 to $74- you save 600Jo . . .................. . ......... $30.00 Frames over $74 ......... . . .................... ... . ... .. ... . ...... 50°/o off Lenses Single Vision - you save 450fo ...... . .... . . . . . . . .. . . .......... . . . ... $28.00 Bifocal - you save 40% ........ . .... ... ... . ..... . . . . .... . ... . ... . .. $50.00 Trifocal - you save 40% ... . .. . ..... .. ... .. ......... . .............. $60.00 Lenticular- you save 500fo .............. .. . . . . . . . ... . ... . ... . . . . . . $95.00 Contact Lenses & Non-Prescription Sunglasses 200/o Discount from regular retail prices Eye Examinations Spectacle: $5 off regular fee Contact: $10 off regular fee ~·Eye ExammatJons are prcv.Ced by Ooc:.ors of Optometry located 1n or a~jac~nt to most par:i6pat1ng ooocal deoart:nents. Tt:e fee tor flc:.:ng and dispens;ng spec:.aces Unc:ud,ng unl1mitted aqusunentsJ is only $8. Ther"!!: 1s no ~~scens.ng fee for cor.c.ac:.s. c·ss·.. .1mercan ~ssoc•at:on !or !:e:"~•crCW!!rs PRE-PAID LEGAL SERVICES, INC. 1019 982 Complaint EXHIBIT2 hearing Aid Discounts {ll Save 60°/a or MORE! • All world famous name brands.

• W hen is a $400 hearing aid better than an $800 hearing aid? When it's the same hearing aid!! 30 day No cost- No obligation FREE home trial Hear better today! hiropractic Discounts {g Nationwide network of over 2200 licensed chiropractors.

• Free Chiropractic Evaluation! • Pr refer red Client 15% discount.

Headaches • Neck Pain • Pain In Lower Back. Hips or Legs Tight M muscles or Spasms • Decreased Flexibtlity Abdominal Pain • Dizziness or Blurred Vision Shoulder or Arm Pain • Numbness in E.rtreniictes Breathing Difficulties Get rid of that pain! Complaint 123 F.T.C. EXIllBIT2 discount Shopping Service [j} · Members save up to 50°/o on thousands of nationally advertised items.

As a Member you'll enjoy huge savings through substantial discounts on most major consumer purchases. It's easy. Just pick up the phone and you'll receive the guaranteed lowest price available for the item you want. Use your price to comparison shop at your local stores.

• Audio Equipment • Sewing Machines • Cameras • Video Recorders -• Carpeting • Exerci~e Equipment • China and Silverware • Televisi9ns ti Diamonds • Typewriters • ··Fine Jewelry • Video Tapes • Furniture • Binoculars • Personal Computers • Air Conditioners • Luggage • Major Appliances Plus thousands of • Pianos and Organs other items! You'll save hundreds of dollars! o~S9 1. ~ .1ssccat:tv\ ~ Seno- c:t:zens PRE-PAID LEGAL SERVICES, INC. 1021 982 Complaint EXHIBIT2 rocery Coupon Program @ Manufacturer's coupons for brand name items you want, need, and use!!! Save hundreds and hundreds of dollars each year on your grocery bills.

Saving Money on groceries · has never been easier.

123 F.T.C. Complaint EXHIBIT2 iftCatalog {H Savings Galore! Over 550 Items! Our members SAVE up to 80°/o Cameras • Jewelry • Hou~ehold Appliances • Silver Plate Luggage • China • Watches • Telephones I I Silverware • Tools • Leather Goods • Fur Coats \II . Receive impressive savings on gifts for E~ A~~ W~ G~ ·C~ I ) ·SAMPLE SAVINGS II Suggested Item Retail Your Price Ladies or mens quartz Diamond Watch .. .. . . ..... . . ........ $ 119.00 .......... ............. S 23.00 35mm Camera - auto focus.

auto wind, auto loading ....... ........ $ 269.00 .. .......... . ... . . . . .. S 69.00 Cordless telephone . . . . . . . . .... . . ... . $ 179.00 .... . .. . . ... . . .. . . .... S 59.00 Ladies Black Eel-Skin purse . . . .. . . ... $ 345.00 . ... . ... ... . . . . . .... . . S 69.00 Nor wegian blue Fox fur coat ...... . . . . $1250.00 ...... . ..... . ... . ... . . 5256.00 ---- - PRE-PAID LEGAL SERVICES, INC. 1023 982 Complaint EXHIBIT2 :{!j .acatioil & Travel Discounts · _Your membership travel services are waiting for you NOW Let our travel consultants accommodate you! • Prompt. courteous, professional assistance • Lowest Ct!rr~ntly available air fares • Up to 50fo off on air fares to many destinations worldwide - • $100,000 Accident lnst,Irance on selected flights • Discounts from many of the world's most desired resorts, cruise lines, and tour packages Get that dream vacation! Guarantees 50°/o Savings • At over 2000 hotels, motels, and resort condominiums.

• Available at thousands of destinations worlwide.

The world can be yours! Complaint 123 F.T.C. EXHIBIT2 ew Car Discounts IE Save $1000 or MORE! For a nominal service charge you'll receive a computer printout showing the dealers cost for the make and model you want.

Information that gives you a price advantage! Knowing what your dealer knows can g~t you the very best price on the car you want. sed Car Discounts DJ Outstanding savings on late-model pre-owned cars.

For a modest fee, you will receive a price quote for the late-model car of your choice that will also include the retail price and trade-in value ..

Make your best deal! Every car is prepared for sale w;a.der guidelines which meet the highest standards and conditions. • PRE-PAID LEGAL SERVICES, INC. 1025 982 Complaint EXHIBIT2 /.... I /} ree Kodak Film .. _______ -~: :::. , I ..:::: ·.... __ _ A $350 Value!! · • Our members are provided certificates for 10 FREE rolls of KODAK Color Film. • Send in a roll of film for processing - Receive a new roll of film FREE. • MONEY BACK GUARANTEE: You pay only for the prints that come out! iscounts on Flowers /Jl Fre_sh & Beautiful • Over 5,000 participating Florists worldwide. • Open 24 hours a day - 7 days a week ar Rental Discounts {g SAVE 10°/o to 40°/o every time you rent a carl • Free upgrade in car class at Hertz, Avis, National. • Special exclusive flat-rates·at National and Alamo. family Entertainment Discounts /} SJrfiJlGS"EH--31'''" At such places as: um.-U§I ~~!A3&/l!lif!,/1.

Ar.d we are neaotiat ;na new entert 2inment disc::ums e•Jery day that -will be acded t o your membership as available! · - Something for everyone! .

Complaint 123 F.T.C. EXHffiiT2 NATIONWIDE NON-PROFIT ORGANIZATION FEDERAL TRADE COMMISSION DECISIONS FINDINGS, OPINIONS AND ORDERS JANUARY 1, 1997 TO JUNE 30, 1997 PUBLISHED BY THE COMMISSION VOLUME 123 Compiled by Commission Services Branch of the Office of the Secretary Patricia C. Epperson, Editor U.S. GOVERNMENT PRINTING OFFICE WASHINGTON: 1998 For sale by the U.S. Government Printing Office Superintendent of Documents, Mail Stop: SSOP, Washington, DC 20402-9328 ISBN 0-16-049794-9 MEMBERS OF THE FEDERAL TRADE COMMISSION DURING THE PERIOD JANUARY 1, 1997 TO JUNE 30, 1997 ROBERT PITOFSKY, Chairman Took oath of office April 12, 1995.

MARY L. Azcuenaga, Commissioner Took oath of office November 27, 1984.

JANET D. STEIGER, Commissioner Took oath of office August 11, 1989.

Roscoe B. STAREK, III, Commissioner Took oath of office November 14, 1990.

CHRISTINE A. VARNEY, Commissioner Took oath of office October 14, 1994.

DONALD S. CLARK, Secretary Appointed August 28, 1988.

II CONTENTS Page Members of the Commission . . . . . . . . . . . . . . . . . . II Table of Cases v Findings, Opinions and Orders 1 Response to Petitions to Quash:

Altmeyer Home Stores, Inc. . . . . . . . . . . . . . . . . . . . 1730 Altmeyer Home Stores, Inc. . . . . . . . . . . . . . . . . . . . 1740 Table of Commodities . . . . . . . . . . .. . . .. . . . . . . . . 1741 Index 1745 m TABLE OF CASES Unless otherwise indicated in parentheses, the names below refer to cases in which orders to cease and desist have been entered by the Commission. The names in italics refer to cases which the Commission has dismissed.

Dkt. No. Name Page C-3733 15 54 Corporation, et al. . . . . . . . . . . . . . . . . . . . . . . 11 08 C-3748 2943174 Canada, Inc., et al. .. ... . .. .... ..... . 1465 C-3703 AAF International . .......... . ... . . . .. . .. . .. . . 40 C-3703 AAF-McQuay, Inc. . . . .... ........... . . . . ... .. 40 C-3745 Abbott Laboratories .. .. . .. . .. . .. . . .... . . .... 1378 C-3731 Administrative Company, et al., The . .. . ..... .. 1047 G-3755 Advanced Health Care Systems . . . . . . . . . . . . . . . 1596 C-3702 Allen, Horace R. . .. . . .. . . . . . . ... . ..... .. .. . . . 23 C-3739 American Cyanamid Company . . ..... . .. .. . . . . 1257 C-3740 American Home Products Corporation . ..... ... . 1279 C-3711 American Honda Motor Co., Inc. . .. .. .. .. ..... . 262 C-3712 American Isuzu Motors, Inc .. .. . . . . . .... ... . . . . 275 C-3747 Amerifit, Inc. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1454 9270 Association Intemationale des Interpretes de Conference . . . . . . . . . . . . . . . .. .. . 465 C-375'6 Autodesk, Inc., et al. . . . . .. . .. .. ... . ..... . . .. i694 C-3726 Baxter International; Inc. . . ....... . . ..... .. ... . 904 "' C-3708 Bie, Victoria . .. . ..... .. .. ... .... . .... . . . .. . . 96 C-3704 Billings Physician Hospital Alliance, Inc . .. . . ... . .. 62 C-3708 Body Gold ... .. . . . . ... ........ . ... . . . . . .. ... 96 C-3754 Bodywell, Inc., et al. .... . . . . ... ..... . ... .. . . 1577 C-3754 Bodywell U.S.A . . .... . . . .... . ... . ..... ... .. 1577 C-3723 Boeing Company, The .. . . . . . . . .. ...... .... . .. 812 9276 BST Enterprises (Final Order) . .. . . ... . . . .. . .. . 1394 C-3715 California Suncare, Inc., et al. . . . ... . .... ... ... . 332 C-3755 Cambridge Direct Sales . ... .... .. .... . ... . . . . 1596 C-3725 Chiron Corporation .... . . .. . .. . . . .... .. . . . ... 842 C-3715 Christal, Donald J ....... . .. . . . . .. ... . . . . ... .. 332 C-3725 Ciba-Geigy Corporation ... . . .. . .. . .... .. . .. . . 842 C-3725 Ciba-Geigy Limited, et al. . . . . . ... . . .. . . .... .. . 842 C-3702 Clausen, Brandon R. . ... . .. . ..... .... . . . . . .. .. 23 v VI FEDERAL TRADE COMMISSION DECISIONS Dkt. No. Name Page C-3705 Computer Business Services, Inc., et al. ... ... .... . 75 C-3719 Comtrad Industries Inc . . .. . . . .... . ...... . .... 749 C-3706 Conopco, Inc. . ..... .. .. ............. .. ... .. 131 C-3757 Cooperative Computing, Inc. . .... .......... .. 1706 C-3724 Cramer, Sanford .. . ..... ..... ..... ... ..... .. 832 C-3755 Dean Distributors, Inc. . ..................... 1596 C-3752 Deerfield Corporation ....................... 1535 9189 Detroit Auto Dealers Association, Inc., et al. .. . .. 1427 C-3705 Douglass, Andrew L .. . . .......... ....... ... . .. 75 C-3705 Douglass, Matthew R .. ..... . ... ..... .... . .. ... 75 C-3705 Douglass, Peter B . ... .. ........ ....... ... .... . 75 C-3751 Effective Health, Inc ................. . . ... ... 1525 C-3702 Filtration Manufacturing, Inc., et al. ... . ....... . .. 23 C-3718 Gandee, William S. . .. ... .. ....... .... ....... 698 C-3742 General Mills, Inc ..... . .... ..... ..... . ...... 1328 C-3710 General Motors Corporation ................... 241 C-3744 Gerber Products Company ................... 1365 C-3753 Guildwood Direct Limited ... ......... .... . .. 1558 C-3752 Ratto, Gerald E .......... . ... : ·ot • •• • 1535 C-3734 Herb Gordon Auto World .................... 1172 C-3734 Herb Gordon Auto World, Inc., et al. . .. . ... .... 1172 C-3734 Herb Gordon Dodge .. .... .. . ..... .. .. ...... 1172 C-3734 Herb Gordon Mercedes-Benz .......... . .... .. 1172 C-3734 Herb Gordon Nissan .. ...... . .... . .... ...... 1172 C-3734 Herb Gordon Oldsmobile .. ... . . ... .......... 1172 C-3734 Herb Gordon Used Cars ..................... 1172 C-3734 Herb Gordon Volvo ........... .. .. ..... ..... 1172 C-3752 Holcomb, Clark M ........ . .. . . ... ..... .. .. . 1535 C-3732 Ruling Bros. Chevrolet Inc., et al. . .. . .......... 1098 C-3732 Ruling Bros. Chrysler/Plymouth, Inc ..... . ...... 1098 C-3732 Ruling Buick, Inc. . .. .. .. ..... .... .. .. ... .... 1098 C-3751 Interactive Medical Technologies, Ltd., et al. ..... 1525 C-3753 Intermed Laboratories ........ ............ . .. 1558 FEDERAL TRADE COMMISSION DECISIONS VII Dkt.·No. Name Page 9270 International Association of Conference Interpreters, et al. (Final Order) .... .. . . ..... .. 465 C-3721 J.C. Penney Company Inc., et al. ....... . . . . . .... 778 C-3722 J.C. Penney Company Inc., et al. . . ... . . . .. . . . ... 795 C-3727 Jeanette L. Douglass .. . ... . ... . . . .... .. . . . . .. 935 C-3736 Karon, Thomas W. . ... .. . .. . ...... . . . .. . . . . 1213 C-3752 KCD Holdings, Inc., et al. .. . . ... . . . . . .... . . ... 1535 C-3752 KCD Incorporated .. . . . .... . ... .. .. . . . .. ... . 1535 C-3720 Kroll, Issie ...... . .. ....... . .. .... ..... . . . .. 762 C-3709 Liberty Media Corporation . ...... .. . .. ........ 171 C-3746 Mahle GMBH, et al. .. ..... . .. . . . ....... . . .. 1431 C-3746 Mahle, Inc . . ...... . . . ... ·. . . . . .... .. . .. . .. . . 1431 C-3735 Martin, Vance R .. . .... ... ... ... ...... .. .. . . 1187 C-3714 Mazda Motor of America, Inc. . . ..... . . .... . . . . 312 C-3731 Mcintyre, Michael P. . . ... .. . .... . .. . .. . .. ... 1047 C-3755 Medibase . . . . . . .... . . ...... .. .... ...... .. . 1596 C-3733 Mellinger, Brainerd L. III . ... . . . . ... . . ...... . . 1108 C-3746 Metal Leve, Inc . . . . . .. .. ... . ... . . .. . ........ 1431 C-3746 Metal Leve, S.A . .. .. ... .. . ... .. . .. .... ... .. 1431 C-3713 Mitsubishi Motor Sales of America, Inc. . . . ...... 288 C-3735 Moneytree, Inc., et al., The .. ..... .. .. . .. . . . . . 1187 C-3704 Montana Associated Physicians, Inc., et al. .. ... ... 62 C-3736 Nationwide Syndications, Inc., et al. ... . . . ... .. . 1213 C-3718 Natural Innovations, Inc., et al. ..... . .... ..... . . 698 C-3725 Novartis AG . . ... ....... ........... ... .. ... 842 C-3707 Oscherowitz, Steven .. .. . ..... .. ... . . .. .. .. . . 149 C-3754 Passage, Gerard Du . . .. .. ........ . . ... ... ... 1577 C-3750 Pelzer, William Jr. . . ... .. . ... ... .. .......... 1519 C-3577 Penn Traffic Company, The (Modifying Order) ... .. 57 C-3716 Phaseout of America, Inc., et al . . .. . .... .. . . . ... 395 C-3728 Phillips Petroleum Company .. . ..... ...... ... . :952 C-3730 Pizzeria Uno Corporation . . . .... . .. .... . ... .. 1038 C-3720 Premier Products, Inc., et al. .... . ... .. ...... . . . 762 C-3729 Pre-Paid Legal Services, Inc ..... . . . .. . . . .. . .. .. 982 VITI FEDERAL TRADE COMMISSION DECISIONS Dkt. No. Name Page C-3716 Products & Patents, Ltd . ............. .. .... ... 395 C-3724 Progressive Mortgage Corporation, et al. ...... ... 832 C-3752 Richards, Bonnie L ............. . .... . ... .... 1535 C-3748 Runner, Patrice . ......... . .... . ..... .. . . ... 1465 C-3720 Sander, Michael . . ............ . .. . . .. .. .. ... . 762 C-3725 Sandoz Corporation ........... . ..... . ... .. .. . 842 C-3725 Sandoz Ltd. . .... . ....... . ... . ... . .... .. .... 842 C-3702 Savell, Gary L. . . . . . . . . . . . . . . . . . . . . . . . . ....... 23 C-3741 Schering-Plough Healthcare Products, Inc .... .. .. 1301 C-3584 Schwegmann Giant Super Markets, Inc. (Modifying Order) . .. .. .. ... . .. . . ......... . 672 C-3749 Shell, William E. M.D . ... ... ................ 1477 C-3756 Softdesk, Inc. . . . .... . ... ......... . . ... . .... 1694 C-3737 Splitfire, Inc. . .. . . ... ............ .. ... .... . 1231 C-3649 SSC Associates, L.P. . ........ .... . ...... .. .. 1721 C-3649 Stop & Shop Companies, Inc., et al., The (Modifying Order) ............ . ... ... ..... 1721 C-3709 Tele-Communications, Inc ...... . ... . ..... ... .. 171 C-3743 Tenet Healthcare Corporation ................. 1337 C-3721 Thrift Drug, Inc. . .. ......................... 778 C-3722 Thrift Drug, Inc. . .. . . . .. ....... ~ .... . ...... . 795 C-3709 Time Warner, Inc., et al. ...... .... ........ .. .. 171 9255 Trans Union Corporation (Interlocutory Order) .. . . 393 9255 Trans Union Corporation (Interlocutory Order) .... 840 C-3709 Turner Broadcasting System, Inc. . . .... ... . . .. . . 171 C-3720 T.V.P. Corporation . ... . . .. . ... . . ... ..... .... 762 C-3720 T.V. Products, Inc ... .. . ... .. ...... . .... ... . .. 762 C-3748 United Research Center, Inc ... .... .. ..... ... . . 1465 9270 United States Region of the International Association of Conference Interpreters ... ... .. . 465 C-3707 Universal Merchants, Inc., et al. ... .. .. ... ...... 149 C-3730 Uno Restaurant Corporation, et al. . . . . ... . . . .. . 1038 C-3730 Uno Restaurants, Inc. . ................. .. . .. 1038 C-3706 Van Den Bergh Foods Company ........ .. .. . .. . 131 FEDERAL TRADE COMMISSION DECISIONS IX Dkt. No. Name Page C-3700 Wesley-Jessen Corporation . . . ... . .......... .. ... 1 9276 Woodruff, Michael ............ .. .......... . 1394 C-3717 World Media T.V., Inc . .... . . .. .. . .......... .. 676 C-3738 Zale Corporation .. . ..... . ............ . ..... 1244 FEDERAL TRADE COMMISSION DECISIONS FINDINGS, OPINIONS AND ORDERS JANUARY 1, 1997 TO JUNE 30, 1997 PUBLISHED BY THE COMMISSION VOLUME 123 Compiled by Commission Services Branch of the Office of the Secretary Patricia C. Epperson, Editor U.S. GOVERNMENT PRINTING OFFICE WASHINGTON : 1998 For sale by the U.S. Government Printing Office Superintendent of Documents, Mail Stop: SSOP, Washington, DC 20402-9328 ISBN 0-1 6 - 049794-9 CONTENTS Page Members of the Commission . . . . . . . . . . . . . . . . . . II Table of Cases v Findings, Opinions and Orders 1 Response to Petitions to Quash:

Altmeyer Home Stores, Inc. . . . . . . . . . . . . . . . . . . . 1730 Altmeyer Home Stores, Inc. . . . . . . . . . . . . . . . . . . . 1740 Table of Commodities . . . . . . . . . . . . . . . . . . . . . . . . 17 41 Index 1745 III TABLE OF CASES Unless otherwise indicated in parentheses, the names below refer to cases in which orders to cease and desist have been entered by the Commission. The names in italics refer to cases which the Commission has dismissed.

Dkt. No. Name Page C-3733 1554 Corporation, et al. . ...... . ........ . . .. .. 1108 C-3748 2943174 Canada, Inc., et al. . ............. ... . 1465 C-3703 ~ International . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40 C-3703 ~-McQuay, Inc . .... ... .. . . .......... . .... . 40 C-3745 Abbott Laboratories .. .. ... . . . . . . . . ... ....... 1378 C-3731 Administrative Company, et al., The . . . .. . .. . .. 1047 G-3755 Advanced Health Care Systems .. ... . . . ...... . 1596 C-3702 Allen, Horace R. . . . . . . ....... . ... . ... . ....... 23 C-3739 American Cyanamid Company ......... . . .. ... 1257 C-3740 American Home Products Corporation . ... .. .. . . 1279 C-3711 American Honda Motor Co., Inc. . . ... .. ... .. .. . 262 C-3712 American Isuzu Motors, Inc ....... . ....... .. . . . 275 C-3747 Amerifit, Inc. . .... .. .. . . . . .... .. . ... ... .. .. 1454 9270 Association Intemationale des Interpretes de Conference ... . . . . . . . . . ..... . .. 465 C-375·6 Autodesk, Inc., et al. .. .. .... . . . .. .. ... .. ... . f694 C-3726 Baxter International; Inc. . .. .. ;. . .. . . . ..... . .. .. 904 C-3708 Bie, Victoria .. . .. . ........... .. ... . ......... 96 C-3704 Billings Physician Hospital Alliance, Inc .. .. ..... . . 62 C-3708 Body Gold . ...... . .. ... . .. ... . . . . . . . .... . ... 96 C-3754 Bodywell, Inc., et al. .... . ... .. . ......... . ... 1577 C-3754 Bodywell U.S.A . . ....... . ... . . ... ... .. ..... 1577 C-3723 Boeing Company, The . . . .. .. . . ......... . . . ... 812 9276 BST Enterprises (Final Order) ... .... . . . ... . . . . 1394 C-3715 California Suncare, Inc., et al. . . .. . ......... . ... 332 C-3755 Cambridge Direct Sales . ..... .. .. . . . . ... .. . .. 1596 C-3725 Chiron Corporation . .... ..... ... . . .. .. . ..... . 842 C-3715 Christal, Donald J . . . . .. .. .. ... ......... .. .... 332 C-3725 Ciba-Geigy Corporation . ...... .. .. . ... . .. . ... 842 C-3725 Ciba-Geigy Limited, et al. ..... . ... ... .. . .... .. 842 C-3702 Clausen, Brandon R. . . ... .... . ... ... ... . ..... . 23 v MEMBERS OF THE FEDERAL TRADE COMMISSION DURING THE PERIOD JANUARY 1, 1997 TO JUNE 30, 1997 ROBERT PITOFSKY, Chairman Took oath of office April 12, 1995.

MARY L. Azcuenaga, Commissioner Took oath of office November 27, 1984.

JANET D. STEIGER, Commissioner Took oath of office August 11, 1989.

Roscoe B. STAREK, III, Commissioner Took oath of office November 14, 1990.

CHRISTINE A. VARNEY, Commissioner Took oath of office October 14, 1994.

DONALD S. CLARK, Secretary Appointed August 28, 1988.

II VI FEDERAL TRADE COMMISSION DECISIONS Dkt. No. Name Page C-3705 Computer Business Services, Inc., et al. ......... .. 75 C-3719 Comtrad Industries Inc . . . . . . . . . . . . . . . . . . . . . . .749 C-3706 Conopco, Inc. . ........ ... .. . .. . ..... ....... 131 C-3757 Cooperative Computing, Inc. . . .. . ............ 1706 C-3724 Cramer, Sanford . .. .. . ... . .. . . . .. ..... ...... 832 C-3755 Dean Distributors, Inc. . ... .. . . . .... .. ....... 1596 C-3752 Deerfield Corporation ......... . . .. .......... 1535 9189 Detroit Auto Dealers Association, Inc., et al. ..... 1427 C-3705 Douglass, Andrew L .. ... .. .. ...... ... . . .... . . . 7 5 C-3705 Douglass, Matthew R ......................... . 75 C-3705 Douglass, Peter B . . .... . ..... . ... . ....... .. . . . 75 . C-3751 Effective Health, Inc .. ... ..... . .............. 1525 C-3702 Filtration Manufacturing, Inc., et al. ............ .. 23 C-3718 Gandee, Williams ........ . .................. 698 C-3742 General Mills, Inc ............ ~ .... .......... 1328 C-3710 General Motors Corporation .... . .............. 241 C-3744 Gerber Products Company .. . ............... . 1365 C-3753 Guildwood Direct Limited ................... 1558 C-3752 Ratto, Gerald E .... ... .. . .... : ·wt • • • 1535 C-3734 Herb Gordon Auto World .................... 1172 C-3734 Herb Gordon Auto World, Inc., et al. ........... 1172 C-3734 Herb Gordon Dodge ..... . ... ...... ......... 1172 C-3734 Herb Gordon Mercedes-Benz ....... . ......... 1172 C-3734 Herb Gordon Nissan . .... . .. .. .... .. ........ 1172 C-3734 Herb Gordon Oldsmobile .... .. .. .. .......... 1172 C-3734 Herb Gordon Used Cars .... .......... . ..... . 1172 C-3734 Herb Gordon Volvo .. ..... .. . ..... .. ..... . . . 1172 C-3752 Holcomb, Clark M .... . ...... .. ... . ......... 1535 C-3732 Ruling Bros. Chevrolet Inc., et al. .............. 1098 C-3732 Ruling Bros. Chrysler/Plymouth, Inc .. .. ........ 1098 C-3732 Ruling Buick, Inc. . .... .~ .......... .. . ........ 1098 C-3751 Interactive Medical Technologies, Ltd., et al. ..... 1525 C-3753 Intermed Laboratories ....... .. ............... 1558 FEDERAL TRADE COMMISSION DECISIONS VII Dkt.·No. Name Page 9270 International Association of Conference Interpreters, et al. (Final Order) . . ..... ... . . .. . 465 C-3721 J.C. Penney Company Inc., et al. ... . ... .... ..... 778 C-3722 J.C. Penney Company Inc., et al. . .............. . 795 C-3727 Jeanette L. Douglass .... .. .. . ............... . 935 C-3736 Karon, Thomas W. . .... ............... ..... 1213 C-3752 KCD Holdings, Inc., et al. . ................ ... 1535 G-3752 KCD Incorporated .......................... 1535 C-3720 Kroll, Issie ................................ . 762 C-3709 Liberty Media Corporation ..... . . .. ... . ....... 171 C-3746 Mahle GMBH, et al. . . . ... . ... . . ... ......... 1431 C-3746 Mahle, Inc . .. ........... ·....... ... . ... . . ... 1431 C-3735 Martin, Vance R. . ... . . ... ................. . 1187 C-3714 Mazda Motor of America, Inc. . ................ 312 C-3731 Mcintyre, Michael P. . ... .. . . ..... . ..... . ... . 1047 C-3755 Medibase . . .... . .. .. . .. . ........... . .. .... 1596 C-3733 Mellinger, Brainerd L. III .. . ... .. . . ........... 1108 C-3746 Metal Leve, Inc ....... .. ... ..... ....... ... .. 1431 C-3746 Metal Leve, S.A. . ... . ... . . ............ . .. .. 1431 C-3713 Mitsubishi Motor Sales of America, Inc. . ..... .. . 288 C-3735 Moneytree, Inc., et al., The .. .. . ... ......... .. 1187 C-3704 Montana Associated Physicians, Inc., et al. .. .... .. 62 C-3736 Nationwide Syndications, Inc., et al. .......... . . 1213 C-3718 Natural Innovations, Inc., et al. .. .... .. . .. ..... . 698 C-3725 Novartis AG .... . ... .... . .... ............ . . 842 C-3 707 Oscherowitz, Steven .... . . . . ................. 149 C-3754 Passage, Gerard Du ........... . ... . . ....... . 1577 C-3750 Pelzer, William Jr. .... . ... . ....... .. ..... ... 1519 C-3577 Penn Traffic Company, The (Modifying Order) ..... 57 C-3716 Phaseout of America, Inc., et al. ...... . .. . ...... 395 C-3 728 Phillips Petroleum Company ........... . .... . . .·952 C-3730 Pizzeria Uno Corporation .................... 1038 C-3720 Premier Products, Inc., et al. . .. ....... .. . ...... 762 C-3 729 Pre-Paid Legal Services, Inc .......... ... .. .. ... 982 VITI FEDERAL TRADE COMMISSION DECISIONS Dkt. No. Name Page C-3716 Products & Patents, Ltd ............ ... ...... . . 395 C-3724 Progressive Mortgage Corporation, et al. ..... . ... 832 C-3752 Richards, Bonnie L . ....... . .. ............. .. 1535 C-3748 Runner, Patrice . ........................... 1465 C-3720 Sander, Michael . ... .. ..... . ....... ...... .... 762 C-3725 Sandoz Corporation .......... . ........ . ...... 842 C-3725 Sandoz Ltd. . ............. . . ................ 842 C-3702 Savell, Gary L ............. . .. .. .. .. .. : ....... 23 C-3741 Schering-Plough Healthcare Products, Inc .. .. .... 1301 C-3584 Schwegmann Giant Super Markets, Inc. (Modifying Order) ....... . .......... . ... . .. 672 C-3749 Shell, William E. M.D. . . ...... .. . ..... .... .. 1477 C-3756 Softdesk, Inc. . . ............ .. .... .. . . .... .. 1694 C-3737 Splitfire, Inc. . . .. ............ . ...... . .. .... 1231 C-3649 SSC Associates, L.P. . ............... . ....... 1721 C-3649 Stop & Shop Companies, Inc., et al., The (Modifying Order) ................ . ..... . . 1721 C-3709 Tele-Communications, Inc. . . . . . . . . . . . . . . . . . . . . 171 C-3743 Tenet Healthcare Corporation .. . . . ... .. ... .. . . 1337 C-3721 Thrift Drug, Inc. . ................. .... .. .. .. 778 C-3722 Thrift Drug, Inc. . .............. ~ .. .. .... .. .. 795 C-3709 Time Warner, Inc., et al. . ..................... 171 9255 Trans Union Corporation (Interlocutory Order) .... 393 9255 Trans Union Corporation (Interlocutory Order) . . .. 840 C-3709 Turner Broadcasting System, Inc. . .. .. .. ... . . ... 171 C-3720 T. V .P. Corporation . . ............. . .. . .. .. . .. 7 62 C-3720 T.V. Products, Inc . . ... . .. . ............. .. .... 762 C-3748 United Research Center, Inc . ... ... . ..... .... . . 1465 9270 United States Region of the International Association of Conference Interpreters ......... 465 C-3707 Universal Merchants, Inc., et al. .. . .... .. ....... 149 C-3730 Uno Restaurant Corporation, et al. ..... . ....... 1038 C-3730 Uno Restaurants, Inc. . . .... ................. 1038 C-3706 Van Den Bergh Foods Company .............. . . 131 FEDERAL TRADE COMMISSION DECISIONS IX Dkt. No. N arne Page C-3700 Wesley-Jessen Corporation ............. . .... . ... 1 9276 Woodruff, Michael ......................... 1394 C-3717 World Media T.V., Inc ........................ 676 C-3738 Zale Corporation ......... . . ................ 1244 Findings, Opinions, and Orders