Administrative Company

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

IN THE MATTER OF THE ADMINISTRATIVE COMPANY, ET AL.

CONSENT ORDER, ETC., INREGARD TO ALLEGED VIOLATION OF SEC. 5 OF THE FEDERAL TRADE COMMISSION ACT Docket C-3731. Complaint, April 14, 1997--Decision, April 14, 1997 This consent order prohibits, among other things, a Texas-based corporation and its officer from making certain false, misleading or unsubstantiated claims concerning the benefits and appropriateness of living trusts or any legal instrument or service they offer and requires the respondents 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 living trust is not included in the price of creating the trust. Appearances For the Commission: Elizabeth M. Palmquist. For the respondents: Tony Chiccio, Chiccio & Associates Dallas, TX.

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. MclIntyre'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.

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 Complaint 123 F.T.C.

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 TRUST, 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.

(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: THE ADMINISTRATIVE COMPANY, ET AL. 1049 1047 Complaint (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. (ce) 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 catastrophic 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 no longer file claims against a will, in some states, there is no law limiting the time that creditors may file claims against a trust 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 paragraph four, including, but not necessarily Complaint 123 F.T.C.

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 representation 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.

THE ADMINISTRATIVE COMPANY, ET AL. 1051 1047 Complaint EXHIBIT 1 i <° AASC. ( : ~ + 4155 15th Street NW, Suite 610 w :

: at OC 20077-1637 \ ’ ~ 4 i: :

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78 30 96.923859 Living5 1 13 1 1 16 1962 1713 80 25 96.441246 Trust.2 1 14 0 0 0 828 1759 1212 135 -1 3 1 14 1 0 0 828 1759 1212 135 -1 4 1 14 1 1 0 831 1759 1209 35 -1 5 1 14 1 1 1 831 1762 37 31 96.475349 By5 1 14 1 1 2 882 1764 171 30 96.807045 establishing5 1 14 1 1 3 1065 1771 17 18 96.798477 a5 1 14 1 1 4 1095 1764 80 30 96.774429 Living5 1 14 1 1 5 1187 1764 75 28 96.761665 Trust,5 1 14 1 1 6 1276 1765 26 23 96.761665 at5 1 14 1 1 7 1317 1769 58 25 96.983749 yours 1 14 1 1 8 1388 1763 80 24 97.005272 deaths 1 14 1 1 9 1480 1768 63 24 97.011520 yours 1 14 1 1 10 1556 1763 87 24 96.502220 estates 1 14 1 1 11 1656 1761 85 25 93.303558 avoids5 1 14 1 1 12 1755 1759 179 26 92.422356 PROBATING5 1 14 1 1 13 1948 1759 92 26 95.912941 YOUR4 1 14 1 2 0 831 1795 1208 29 -1 5 1 14 1 2 1 831 1797 73 26 93.473091 WILL5 1 14 1 2 2 921 1798 86 25 93.473091 which5 1 14 1 2 3 1024 1806 52 17 96.722778 cans 1 14 1 2 4 1093 1799 87 25 96.565422 COSTS 1 14 1 2 5 1195 1798 145 26 94.582100 SEVERAL5 1 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1 4 2 915 1867 67 25 96.454208 YOU5 1 14 1 4 3 992 1867 109 27 95.951401 RETAINS 1 14 1 4 4 1111 1869 74 25 95.086327 FULL5 1 14 1 4 5 1195 1867 154 26 95.917267 CONTROLS 1 14 1 4 6 1359 1867 44 25 95.917267 OF5 1 14 1 4 7 1413 1867 56 25 95.353676 ALL5 1 14 1 4 8 1480 1866 130 25 95.353676 ASSETS!2 1 15 0 0 0 926 1919 1005 163 -1 3 1 15 1 0 0 926 1919 1005 163 -1 4 1 15 1 1 0 1154 1919 553 32 -1 5 1 15 1 1 1 1154 1923 73 28 96.761520 YOU5 1 15 1 1 2 1240 1921 126 30 96.154060 COULD5 1 15 1 1 3 1378 1920 90 30 94.367989 SAVES 1 15 1 1 4 1480 1919 227 30 94.367989 THOUSANDS4 1 15 1 2 0 1175 1960 510 32 -1 5 1 15 1 2 1 1175 1963 48 29 96.548431 OF5 1 15 1 2 2 1234 1963 102 29 96.520813 HARD5 1 15 1 2 3 1347 1960 147 31 96.330124 EARNED5 1 15 1 2 4 1506 1960 179 30 96.728546 DOLLARS!4 1 15 1 3 0 926 2014 1005 25 -1 5 1 15 1 3 1 926 2017 197 21 96.375961 INFORMATION5 1 15 1 3 2 1135 2018 25 21 84.903687 IS5 1 15 1 3 3 1171 2017 149 21 95.884201 AVAILABLE5 1 15 1 3 4 1334 2017 37 20 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1 19 3 2 0 1396 2281 461 33 -1 5 1 19 3 2 1 1396 2281 56 33 46.591751 a3?5 1 19 3 2 2 1476 2301 6 13 78.996460 ,5 1 19 3 2 3 1494 2285 53 21 84.400963 0815 1 19 3 2 4 1576 2283 75 23 81.737564 48125 1 19 3 2 5 1678 2283 71 22 82.053085 $2645 1 19 3 2 6 1769 2283 88 30 65.141251 -1549.2 1 20 0 0 0 813 2323 1068 65 -1 3 1 20 1 0 0 813 2323 1068 61 -1 4 1 20 1 1 0 813 2323 986 23 -1 5 1 20 1 1 1 813 2324 57 16 94.691925 Homes 1 20 1 1 2 879 2323 84 22 92.895294 Phone:5 1 20 1 1 3 953 2319 14 31 86.821579 (5 1 20 1 1 4 1029 2326 4 20 92.973892 )5 1 20 1 1 5 1795 2343 4 3 66.292160 34 1 20 1 2 0 1356 2346 525 42 -1 5 1 20 1 2 1 1356 2349 50 33 64.030769 54]5 1 20 1 2 2 1426 2346 142 42 31.778168 AVENTURA5 1 20 1 2 3 1595 2351 55 20 96.669312 AVE5 1 20 1 2 4 1802 2352 58 11 0.000000 RAIS.5 1 20 1 2 5 1873 2359 8 3 40.172127 x2 1 21 0 0 0 1356 2382 473 29 -1 3 1 21 1 0 0 1356 2382 473 29 -1 4 1 21 1 1 0 1356 2382 473 29 -1 5 1 21 1 1 1 1356 2384 53 27 94.515541 SANS 1 21 1 1 2 1434 2383 93 23 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0 838 2451 52 22 -1 4 1 27 1 1 0 838 2451 52 22 -1 5 1 27 1 1 1 838 2455 13 18 24.693680 ae Complaint 123 F.T.C.

EXHIBIT 2 Nose ai i4 1 5 1 2 0 1061 963 79 88 -1 5 1 5 1 2 1 1061 963 79 88 77.756668 Mii4 1 5 1 3 0 986 940 331 200 -1 5 1 5 1 3 1 986 940 213 180 24.672119 ines 1 5 1 3 2 1177 990 140 150 42.034149 BN)2 1 6 0 0 0 1093 1071 184 81 -1 3 1 6 1 0 0 1093 1071 184 81 -1 4 1 6 1 1 0 1093 1071 184 81 -1 5 1 6 1 1 1 1093 1071 58 63 6.100510 g5 1 6 1 1 2 1139 1094 138 58 0.000000 AWGN2 1 7 0 0 0 1202 807 213 402 -1 3 1 7 1 0 0 1202 807 213 402 -1 4 1 7 1 1 0 1202 807 213 402 -1 5 1 7 1 1 1 1202 807 213 402 36.856186 ca2 1 8 0 0 0 602 531 1158 871 -1 3 1 8 1 0 0 602 531 1158 871 -1 4 1 8 1 1 0 602 531 1158 871 -1 5 1 8 1 1 1 602 531 1158 871 95.000000 2 1 9 0 0 0 616 1452 1104 49 -1 3 1 9 1 0 0 616 1452 1104 49 -1 4 1 9 1 1 0 616 1452 1104 49 -1 5 1 9 1 1 1 616 1453 157 37 0.000000 Kak5 1 9 1 1 2 801 1448 90 63 0.000000 KKa5 1 9 1 1 3 921 1452 87 49 6.944427 KK5 1 9 1 1 4 1037 1448 91 63 6.944427 Kak5 1 9 1 1 5 1158 1448 27 63 0.000000 Kk5 1 9 1 1 6 1215 1457 87 37 0.000000 KK5 1 9 1 1 7 1331 1448 37 63 9.175262 Kk5 1 9 1 1 8 1394 1448 30 63 4.530754 Kk5 1 9 1 1 9 1452 1456 150 37 0.000000 kkk5 1 9 1 1 10 1630 1456 90 37 0.000000 Kk2 1 10 0 0 0 991 1767 344 163 -1 3 1 10 1 0 0 991 1767 344 163 -1 4 1 10 1 1 0 1017 1767 299 33 -1 5 1 10 1 1 1 1017 1767 299 33 95.947510 NATIONWIDE4 1 10 1 2 0 1021 1831 291 34 -1 5 1 10 1 2 1 1021 1831 291 34 96.292458 NON-PROFIT4 1 10 1 3 0 991 1896 344 34 -1 5 1 10 1 3 1 991 1896 344 34 95.966713 ORGANIZATION2 1 11 0 0 0 943 2029 428 135 -1 3 1 11 1 0 0 943 2029 428 135 -1 4 1 11 1 1 0 962 2029 397 33 -1 5 1 11 1 1 1 962 2030 80 30 92.908188 11555 1 11 1 1 2 1059 2029 75 31 96.224869 15th5 1 11 1 1 3 1149 2029 117 33 93.223869 Street,5 1 11 1 1 4 1280 2029 79 29 89.126205 N.W.4 1 11 1 2 0 1075 2079 165 29 -1 5 1 11 1 2 1 1075 2079 88 29 96.222160 Suites 1 11 1 2 2 1176 2079 64 29 95.805130 8104 1 11 1 3 0 943 2127 428 37 -1 5 1 11 1 3 1 943 2128 211 36 95.328331 Washington,5 1 11 1 3 2 1170 2127 64 30 95.762848 D.C.5 1 11 1 3 3 1249 2127 122 29 91.499908 200052 1 12 0 0 0 999 2203 314 31 -1 3 1 12 1 0 0 999 2203 314 31 -1 4 1 12 1 1 0 999 2203 314 31 -1 5 1 12 1 1 1 999 2203 314 31 69.324768 1-800-880-13102 1 13 0 0 0 2281 13 39 412 -1 3 1 13 1 0 0 2281 13 39 412 -1 4 1 13 1 1 0 2281 13 39 412 -1 5 1 13 1 1 1 2281 13 39 412 95.000000 2 1 14 0 0 0 2280 13 52 719 -1 3 1 14 1 0 0 2280 13 52 719 -1 4 1 14 1 1 0 2280 13 52 719 -1 5 1 14 1 1 1 2280 13 52 719 95.000000 2 1 15 0 0 0 2282 13 52 768 -1 3 1 15 1 0 0 2282 13 52 768 -1 4 1 15 1 1 0 2282 13 52 768 -1 5 1 15 1 1 1 2282 13 52 768 95.000000 THE ADMINISTRATIVE COMPANY, ET AL. 1053 1047 Complaint EXHIBIT 2 te 7 & Dear Member:

We welcome you to the wonderful warld of meaningful benefits and services provided as part of your membership in THE AMERICAN ASSOCIATION FOR SENIOR CITIZENS.

As the senior officer of this non-profit Association, and one who is on the sunny side of sixty, | assure you | value my membership and enjoy the many benefits available to all of our members.

This Association was founded several years ago and entrusted with the responsibility of getting the message to people our age so that we can receive every benefit and advantage to make sure the dollars we have spent a lifetime earning and saving will pass on to our heirs as intact as Uncle Sam will allow. With this responsibility as our driving force, our Association explored every conceivable avenue available before making the decision to educate our membership on the value and importance of REVOCABLE LIVING TRUSTS. know and understand what this Association is com- It is also important for you to mitted to in regard to a PRE-PAID LEGAL 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 commitment 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 membership dues are used to support the research efforts of medical research facilities, and others, as they seek better treatment and cures relating to our senior citizens. AASC Medical Research Foundation’s charter, as explained in the following section, is to continually stay abreast of current research efforts throughout the United States ta determine who should receive financial support fram the Foundation. Please know we are here to make things a little better for you and all of our growing family of members. As soon as we receive your application | will see that your membership kit is forwarded to you.

Warmest personal regards, | ere See Donald T. Berlinn Executive Director <°SS° Amecsa> 435ccaten ter Sener C.tzers wo Complaint EXHIBIT 2 MEDICAL RESEARCH FOUNDATION — THE ADMINISTRATIVE COMPANY, ET AL. 1055 1047 Complaint EXHIBIT 2 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 of 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 Foundation.

Complaint 123 F.T.C.

EXHIBIT 2 Our other Directors are... Robert P. Ewing, is past Howard E. Cartwright, Chairman and President of of Chicago is past CEO of Bankers Life and Casualty College of Amencan Company and is a Trustee of Pathologists, past Director of the MacArthur Foundation, a College of American Director of Evanston Illinois Pathologists Foundation and a member of American Denis J. Fu, M.D., a practicing physician in Hawaii, has served as a medical consultant for various state and national development programs.

Alexander L Sadowski, D.D.S., has accumulated over 1000 hours of continuing education, served on the New Mexico State Dental Association's Finance Committee and is both past president and secretary of the Southwest Distnct Dental Society.

Hospital and a former Director of the Health Insurance Association of America.

Joseph W Lawrence, M.D., has a long and distinguished career in Public Health and is currently the Health Officer for Lee County, Florida, a position he has held since 1960.

Donald T. Berlinn, has been Vice President of ITT Life Insurance Company Agency and President of Medical Air Services Association, the nation’s first nationwide air ambulance service. Currently Presicent of Affardable Dental Connection and Associat:on Management Group anc Fresident af Amencan Association for Senior Ciuzens.

Association of Medical Saciety Executives.

Samuel R. Sherman, M.D.

has a long ist of accomplishments including:

past President of the California Medical Association.

All of our listed Directors. are also members of the Advisory Board of American Association of Senior Citizens and advise the Association on developing new benefits or improving existing benefits for.

our senior citizens.

in ©19G* Smencar Assce.ait~ or Server Dor cecs THE ADMINISTRATIVE COMPANY, ET AL. 1057 1047 Complaint EXHIBIT 2 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 Met Sinai Foundation National Multiple Sclerosis Saciety National Kidney Foundation Regional Cancer Treatment Center — lowa University of lawa Dept. of Immunology University of San Francisco Cardiovascular Research In addition, the Foundation has given grants to the following, and others: Cancer Research Foundation of North Texas Allegheny-Singer Research Institute University of Florida — Oncology St. Jude's Children’s Hospital Sloan-Kettering Cancer Center North California Transplant Bank ALS & Neuromuscular Research Foundation Children’s Hospital Medical Center Florida Geriatric Research Foundation Regional Cancer Foundation Children’s Memorial Foundation Cancer Care Services ON LOK Senior Health Services lowa Methodist Health Foundation March of Dimes — Walk America University of lowa College of Medicine ‘San Antonio Area Lupus Foundation Tulane University Medical Center, Dept. of Pediatric-Cardiology Cancer Counseling, Inc.

Tarrant County Cancer Care Services Cystic Fibrosis Foundation Univ. of Connecticut Health Center Jean Marie Colbert Bone Marrow Transplant Center Children’s Heart Foundation Fred Hutchinson Cancer Research Center The AASC Medical Research Foundation was formerly known as the American Health Care Advisory Association Foundation, providing financial support to the above and other research facilites. ©1891, Amencan Associaton for Senior Ciczens om Complaint 123 F.T.C.

EXHIBIT 2 AASC Provides for its Members the Benefits of Pre-Paid Legal Services, Inc.® A few of the most common personal worries and business activities needing an attomey’s professional counsel and assistance include:

Threat of a Lawsuit Adoption Consumer Fraud Oevt Collection Domestic Problems Tares Auto TFansaction Partnerships Formng a Corporation Contractor Orpute Lease Changs Property Purchase Fuses Motor Vehicle Fleets Marufacturer Problems Evcton Creditor Harressmenc Cormenal Threacs Bankruptcy An American Stock 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 £1891, Amencan Assce:at.en fer Serice Couzens THE ADMINISTRATIVE COMPANY, ET AL. 1059 1047 Complaint EXHIBIT 2 embership entitles you to:

FREE LEGAL SERVICES FOR PREPARATION OF A REVOCABLE LIVING TRUST BY A QUALIFIED ATTORNEY IN YOUR STATE AND A FREE “POUR-OVER” WILL (see following section) LEGAL SERVICES AT DEATH UNLIMITED TELEPHONE CONSULTATIONS WITH A PROVIDER ATTORNEY MOTOR VEHICLE LEGAL SERVICE 3 IN-OFFICE ATTORNEY CONSULTATION 6 TRIAL DEFENSE FUND i IRS AUDIT PROTECTION B LEGAL ASSISTANCE IN MANY CASES £1991. Amencan Assoc:aten for Senior Cozens Complaint L23:B-T-E.

EXHIBIT 2 nlimited Telephone Consultations:

® 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 attorney. 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 questians you may need answered:

1. “lam 67 years old and collecting social security. Is it legal for me to claim a deduction fara 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 | 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. My5 1 9 6 1 3 638 1602 159 31 80.651581 neighbor's5 1 9 6 1 4 818 1606 127 28 96.560013 teenage5 1 9 6 1 5 965 1609 63 22 96.510483 son,5 1 9 6 1 6 1047 1602 116 30 96.142632 despite5 1 9 6 1 7 1182 1608 48 24 96.734192 my5 1 9 6 1 8 1249 1603 146 28 96.841354 requests5 1 9 6 1 9 1416 1603 33 22 96.462074 to5 1 9 6 1 10 1467 1603 78 27 96.462074 stop,5 1 9 6 1 11 1566 1599 155 27 87.348663 continues5 1 9 6 1 12 1733 1603 40 23 51.766933 to5 1 9 6 1 13 1792 1600 63 32 96.534248 plays 1 9 6 1 14 1874 1600 63 26 96.245216 loud4 1 9 6 2 0 548 1636 1051 35 -1 5 1 9 6 2 1 548 1639 97 25 95.084091 music5 1 9 6 2 2 659 1640 67 25 96.505554 that5 1 9 6 2 3 739 1640 91 31 95.997650 keeps5 1 9 6 2 4 843 1647 48 18 96.397820 me5 1 9 6 2 5 903 1641 99 25 96.476181 awake5 1 9 6 2 6 1015 1644 31 22 96.622528 at5 1 9 6 2 7 1058 1639 85 32 96.537560 night.5 1 9 6 2 8 1156 1638 25 26 86.915039 Is5 1 9 6 2 9 1194 1638 87 26 96.120895 there5 1 9 6 2 10 1293 1637 135 31 96.586746 anything5 1 9 6 2 11 1442 1638 5 24 95.923302 |5 1 9 6 2 12 1461 1644 53 19 96.370316 cans 1 9 6 2 13 1527 1636 72 27 77.032501 do? 5. “!5 1 9 7 1 3 587 1699 57 25 96.220764 had5 1 9 7 1 4 661 1705 17 19 94.472900 a5 1 9 7 1 5 696 1704 178 22 95.973595 contractors 1 9 7 1 6 891 1699 32 27 95.973595 fix5 1 9 7 1 7 941 1707 47 24 96.198212 my5 1 9 7 1 8 1005 1699 68 29 96.779137 roof,5 1 9 7 1 9 1091 1699 22 26 95.737686 it5 1 9 7 1 10 1130 1698 52 26 95.380074 still5 1 9 7 1 11 1199 1698 82 26 94.673927 leaks5 1 9 7 1 12 1298 1696 58 27 96.236313 ands 1 9 7 1 13 1374 1696 51 26 96.236313 thes 1 9 7 1 14 1442 1700 178 23 96.676758 contractors 1 9 7 1 15 1635 1696 47 27 96.840187 will5 1 9 7 1 16 1699 1701 53 22 96.541985 not5 1 9 7 1 17 1767 1701 103 23 95.008980 returns 1 9 7 1 18 1887 1704 45 26 96.402443 my4 1 9 7 2 0 543 1737 338 27 -1 5 1 9 7 2 1 543 1737 62 26 95.547501 call.5 1 9 7 2 2 617 1737 94 26 95.272919 What5 1 9 7 2 3 722 1744 57 20 94.275299 cans 1 9 7 2 4 792 1737 5 27 94.006134 |5 1 9 7 2 5 809 1737 72 27 72.965370 do?”2 1 10 0 0 0 473 1792 1458 76 -1 3 1 10 1 0 0 473 1792 1458 76 -1 4 1 10 1 1 0 473 1792 1458 38 -1 5 1 10 1 1 1 473 1792 30 26 58.897476 6.5 1 10 1 1 2 542 1797 68 32 91.494781 “My5 1 10 1 1 3 624 1797 135 26 96.754898 husband5 1 10 1 1 4 774 1798 24 26 95.167458 is5 1 10 1 1 5 814 1798 24 26 95.167458 in5 1 10 1 1 6 853 1804 17 20 95.862968 a5 1 10 1 1 7 885 1798 116 32 96.222549 nursing5 1 10 1 1 8 1015 1798 94 26 96.222549 home.5 1 10 1 1 9 1124 1797 5 25 95.141472 |5 1 10 1 1 10 1145 1797 35 26 96.954170 do5 1 10 1 1 11 1194 1800 53 22 96.978615 not5 1 10 1 1 12 1262 1795 55 26 89.128502 feels 1 10 1 1 13 1332 1795 36 25 96.944656 he5 1 10 1 1 14 1383 1795 24 25 96.855125 is5 1 10 1 1 15 1422 1795 113 32 96.202194 getting5 1 10 1 1 16 1550 1794 54 26 96.771027 thes 1 10 1 1 17 1617 1801 108 25 95.648064 proper5 1 10 1 1 18 1737 1801 78 21 96.366806 care.5 1 10 1 1 19 1829 1795 102 27 82.499390 Aren't4 1 10 1 2 0 540 1833 1389 35 -1 5 1 10 1 2 1 540 1835 90 25 96.925888 there5 1 10 1 2 2 648 1836 116 26 96.224434 certain5 1 10 1 2 3 783 1836 163 26 96.737923 standards5 1 10 1 2 4 966 1840 51 22 96.720070 sets 1 10 1 2 5 1034 1836 35 32 96.856384 by5 1 10 1 2 6 1087 1836 51 25 96.664017 thes 1 10 1 2 7 1156 1838 86 22 96.534523 states 1 10 1 2 8 1263 1833 68 26 96.516136 that5 1 10 1 2 9 1347 1833 119 31 96.701782 nursing5 1 10 1 2 10 1483 1833 107 26 96.387466 homes5 1 10 1 2 11 1610 1838 83 21 96.423225 must5 1 10 1 2 12 1711 1833 109 26 86.066185 follow?5 1 10 1 2 13 1838 1833 91 26 96.665298 What2 1 11 0 0 0 468 1873 789 87 -1 3 1 11 1 0 0 468 1873 789 87 -1 4 1 11 1 1 0 538 1873 447 32 -1 5 1 11 1 1 1 538 1879 55 20 96.662041 ares 1 11 1 1 2 606 1879 47 25 96.212059 my5 1 11 1 1 3 665 1873 157 28 83.708794 husband's5 1 11 1 1 4 834 1874 151 31 94.137177 options?”4 1 11 1 2 0 468 1929 789 31 -1 5 1 11 1 2 1 468 1929 24 24 75.333817 75 1 11 1 2 2 536 1933 22 26 55.269043 “|5 1 11 1 2 3 579 1933 143 26 96.068199 inherited5 1 11 1 2 4 741 1941 87 19 96.395241 some5 1 11 1 2 5 848 1933 63 26 95.138321 lands 1 11 1 2 6 930 1935 24 24 95.915047 in5 1 11 1 2 7 973 1934 126 26 96.683937 another5 1 11 1 2 8 1116 1936 84 22 95.705353 states 1 11 1 2 9 1219 1938 38 20 95.705353 an2 1 12 0 0 0 465 1971 1455 89 -1 3 1 12 1 0 0 465 1971 1455 89 -1 4 1 12 1 1 0 535 1971 146 26 -1 5 1 12 1 1 1 535 1971 39 26 96.492302 do5 1 12 1 1 2 586 1971 95 26 74.793793 this?”4 1 12 1 2 0 465 2025 1455 35 -1 5 1 12 1 2 1 465 2026 30 26 73.523544 In5 1 12 1 2 2 507 2026 146 26 95.752747 additions 1 12 1 2 3 664 2031 36 21 96.507980 to5 1 12 1 2 4 711 2028 146 32 96.593040 advising5 1 12 1 2 5 868 2035 59 25 96.884636 you5 1 12 1 2 6 939 2029 33 25 96.324158 of5 1 12 1 2 7 982 2036 78 24 95.671913 yours 1 12 1 2 8 1071 2028 114 30 96.289429 rights,5 1 12 1 2 9 1195 2026 59 26 96.336967 thes 1 12 1 2 10 1264 2029 161 27 95.466583 attorney,5 1 12 1 2 11 1436 2025 24 26 96.226562 if5 1 12 1 2 12 1468 2032 190 25 96.153587 necessary,5 1 12 1 2 13 1668 2026 60 26 96.153587 will5 1 12 1 2 14 1739 2026 181 32 93.891418 personally2 1 13 0 0 0 462 2064 878 33 -1 3 1 13 1 0 0 462 2064 878 33 -1 4 1 13 1 1 0 462 2064 878 33 -1 5 1 13 1 1 1 462 2065 59 25 93.500969 calls 1 13 1 1 2 535 2073 39 17 94.873871 or5 1 13 1 1 3 585 2065 84 25 96.655426 sends 1 13 1 1 4 682 2073 19 17 96.708786 a5 1 13 1 1 5 715 2066 100 26 95.509331 letters 1 13 1 1 6 826 2071 36 20 96.679878 to5 1 13 1 1 7 874 2066 73 31 96.744400 helps 1 13 1 1 8 959 2067 124 25 96.322189 resolves 1 13 1 1 9 1095 2073 79 24 96.071373 yours 1 13 1 1 10 1185 2064 155 32 96.406860 problem.2 1 14 0 0 0 1260 1929 665 29 -1 3 1 14 1 0 0 1260 1929 665 29 -1 4 1 14 1 1 0 1260 1929 665 29 -1 5 1 14 1 1 1 1260 1932 17 25 93.016365 d5 1 14 1 1 2 1296 1930 6 25 80.014069 |5 1 14 1 1 3 1322 1929 91 26 94.511909 would5 1 14 1 1 4 1433 1930 49 26 58.833992 likes 1 14 1 1 5 1501 1933 32 23 96.556641 to5 1 14 1 1 6 1552 1930 86 26 95.178696 leases 1 14 1 1 7 1654 1930 23 26 95.379929 it5 1 14 1 1 8 1695 1935 58 21 95.267700 out.5 1 14 1 1 9 1773 1930 73 28 95.704460 How5 1 14 1 1 10 1864 1930 37 27 88.874649 da5 1 14 1 1 11 1919 1930 6 25 95.315453 |2 1 15 0 0 0 453 2431 1461 84 -1 3 1 15 1 0 0 453 2431 1461 84 -1 4 1 15 1 1 0 453 2431 1461 84 -1 5 1 15 1 1 1 453 2431 1461 84 95.000000 2 1 16 0 0 0 454 2485 485 20 -1 3 1 16 1 0 0 454 2485 485 20 -1 4 1 16 1 1 0 454 2485 485 20 -1 5 1 16 1 1 1 454 2485 65 17 30.073837 €399%,5 1 16 1 1 2 529 2486 95 16 87.819778 Amercsn5 1 16 1 1 3 634 2485 115 17 46.648067 Asscc.aticn5 1 16 1 1 4 758 2487 26 16 80.786835 fers 1 16 1 1 5 792 2487 63 17 90.318466 Semor5 1 16 1 1 6 862 2487 77 18 38.913960 Cozens THE ADMINISTRATIVE COMPANY, ET AL. 1061 Complaint EXHIBIT 2 pto 50 Hours Legal Assistance 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 person who attempts to challenge the estate The settlement of an estate is a complicated and lengthy process. Qualified attorneys usually charge between $175—S300 per hour 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 to up to 50 hours of legal assistance, depending on your member classification. A True Story:

A Senior Citizen of Dixon, Iinais joined AASC in June of 1997. In July, 1991, he passed away. His children, rather than beginning the long and costly process of finding an attorney to probate his estate, simply called the AASC members’ toll-free number. A Pre-Paid Legal attorney 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 attorney 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. ©1991, Amencsn Assoc:aton for Senior C.cz27$ Complaint 123 F.T.C.

EXHIBIT 2 n-Office Consultation:

ONE PER YEAR AASC provides its members with a Living Trust. Each year it should be reviewed and updated with changes concerning: e Any Legal Matter e Investments.

» Deeds e Property and Real Estate Cars, Trucks and Equipment Bank Accounts ° C.D.s 186%, Ameccan Assec:atcn fer Samer C.c.zecs THE ADMINISTRATIVE COMPANY, ET AL. 1063 Complaint EXHIBIT 2 motor Vehicle Legal Service Expense Benefits:

Nearly every American drives some form of motor vehicle every day. You are at risk, every 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 EXPENSES: If a licensed member, spouse, or any covered dependent, while driving any licensed motor vehicle, is 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 S125 for legal assistance requiring court appearance; up to S200 for legal assistance which includes trial work. MAJOR LEGAL EXPENSES: /f 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, the 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 ta S250 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 $250 per occurrence to your attorney. PERSONAL INJURY LEGAL EXPENSES: The Company will pay your attorney fees. win, lose, or draw, up to S250 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.

*5951, Amercan Associaton for Servor C.nzers Complaint 123 F.T.C.

EXHIBIT 2 S| 5,000 Trial Defense Fund:

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 member's 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 out of the direct perform of the C ed 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 S250 for any and all legal services rendered in defense of the covered lawsuit prior to the actual trial.

Up to $300 per day for each actual day of trial, including covered criminal preliminary hearings not to exceed an annual aggregate trial defense fund of 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: 2 nd The trial defense fund will be increased to an annual aggregate sum of $10,000 Year Ranewal PE" membership payable up to $300 for any and all legal services rendered prior to trial and up to S350 per day for each actual day of trial, including criminal preliminary hearings.

The trial defense fund will be increased to an annual aggregate sum of $15,000 eens, per membership payable up to S350 for any and all legal services rendered prior to trial and up to S400 per day for each actual day of trial, including criminal preliminary hearings.

The trial defense fund will be increased to an annual aggregdte sum of S20,000 eth, per membership payable up to S400 for any and all legal services rendered prior to trial and up ta $450 per day far each actual day of tral, including criminal preliminary hearings.

The trial defense fund will be increased to an annual aggregate sum of S25,000 r membership payable up to S450 for any and all legal services rendered prior | and up to S500 per day for each actual day of trial, including criminal 5th Year Renewal pe to tna preliminary hearings.

FISS1. Amencan Assac:ation for Senor C.czens THE ADMINISTRATIVE COMPANY, ET AL. 1065 1047 Complaint EXHIBIT 2 [] RS Audit Protection Service:

\1.A.S.... The idea of an audit strikes fear in even the most careful tax payer, Why not enjoy the Peace of mind that the AASC membership offers shequgn tt the IAS Audit Protection Service? Here are the details.

The Company 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 public. accountant, certified public accountant, enrolled agent or attorney or any combination thereof when a member is notified in writing by the Internal Revenue Service (IRS), of an audit of such member's tax return or such member is requested in writing to appear at the offices of the IRS concerning such member's tax return. BENEFITS TO BE PAID AS FOLLOWS:

Up to $100 for consultation, advice and/or assistance, upon receipt of written notice from the IRS that the member's tax return is being audited or such member is requested in writing to appear at the offices of the IRS concerning such member's tax‘ return. In the event settlement is not achieved with the IRS within thirty (30) days, then up to $250 beginning on the thirty-first (91) 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 made at up to a rate of $300 per day of each day of trial appearance. Coverage begins with the return due on April 15 of the year this contract is effective.

©1951, Amercan Associaton for Senor Garens Complaint 123 F.T.C.

EXHIBIT 2 legal Assistance in Many Cases:

AASC membership provides legal assistance in many cases including the following... .

PHONE CALLS AND LETTERS ON YOUR BEHALF A letter or phone call fram your Plan Attorney can get you the results you want fast and cut through the red tape. You and your Plan Attorney can now decide together when this is the best legal step for you. There is no’ charge for the first letter. ny further fees are to be set by the Plan Attorney and are the sole responsibility of the Named Member on the Contract.) REVIEW OF CONTRACTS AND DOCUMENTS You can have an unlimited number of legal documents of up to three pages each reviewed by your Plan Attorney, free of charge. Your Plan Attorney will give you an analysis of the documents and suggest changes for your benefit or any other necessary procedures, before you sign! LEGAL FORMS BENEFIT Imagine having access to the most often needed legal documents — just a phone call away! The documents you need will be prepared for you at a greatly reduced rate, but don't worry, still with the same care and concern for your welfare. A list of legal forms available, along with the nominal charges, will be in your contract packet. Complete information about the forms you need can be obtained with just a phone call to your Plan Attorney. A =SG1 Ameccan Assce:at-on fer Sever Ccers THE ADMINISTRATIVE COMPANY, ET AL. ° 1047 Complaint EXHIBIT 2 ALL ABOUT A LIVING TRUST Complaint 123 F.T.C.

EXHIBIT 2 (Al dvantages of a Living Trust PROBATE:

A LIVING TRUST avoids a complex PROBATE proceeding. Probate is the court process 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 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. PRIVACY:

A LIVING TRUST is completely PRIVATE. There is no privacy with a public Probate Court Proceeding.

A LIVING TRUST is a private document, the size and distribution of your estate remains confidential.

4 WILL CONTEST:

A LIVING TRUST prevents a WILL CONTEST. In Probate Court, anyone can easily contest 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 your property to your heirs, you may eliminate probate. However, once the gift is made you have lost ownership of your property, which you may later need far 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. t3E91 Amercar Asscc.at.cn for Semer C.ucers THE ADMINISTRATIVE COMPANY, ET AL. 1069 1047 Complaint EXHIBIT 2 DISABLED HEIRS:

A LIVING TRUST preserves benefits for DISABLED HEIRS. A disabled their generally loses government assistance payments upon receiving an inheritance. A LIVING TRUST can authorize your successor trustee ta make special distributions for a disabled their while still preserving government benefits. PROBATE FEES:

A LIVING TRUST eliminates ALL PROBATE FEES and COST. Probate fees are based on the entire value of an estate, without deducting bills or mortgage. The probate expense can be as much as the following, or more: GROSS ESTATE SIZE APPROXIMATE EXPENSES $100,000. $10,000.

$300,000. $30,000.

$50,000.

$500,000.

This example also applies to all other mortgaged property owned in every state. If a couple owns property in four states there would be 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 of avoiding probate, where, upon death of one co-owner, the survivor becomes the full owner of the property.

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

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

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 Probate 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 trustee can manage your property if-you are unabie to handle your affairs, and there are no court fees and costs. ©1§91, Amencan Association lor Senior Ciuzens Complaint 123 F.T.C.

EXHIBIT 2 | INCOME TAXES:

A LIVING TRUST saves sizeable INCOME TAXES. When a couple holds property 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. ll ESTATE TAXES:

An A-B LIVING TRUST saves substantial ESTATE TAXES. Estate taxes are paid 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 SGOO,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: APPROXIMATE TAX SAVINGS NET ESTATE $ 800,000, $ 75,000.

$1,000,000. $153,000.

$1,200,000. . $235,000.

l MEDICAL COSTS: . .

AN A-B LIVING TRUST protects against catastrophic MEDICAL COSTS. If you ’ : 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-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. ia 185%. Amencsn Assaciatcn fer Senor Cczers THE ADMINISTRATIVE COMPANY, ET AL. 1071 1047 Complaint EXHIBIT 2 questions Most Commonly Asked Q: Is There Anything Bad About a Living Trust? A : No. There is nothing bad about a Living Trust. Itis a traditional and well-proven estate planning tool that has been used, in one form or another, for hundreds of x 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 to 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: Where Should | 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 time 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 access) Q: Can | Put Out-Of-State Property Into The Trust? A: Yes, you can, and in fact, you should. If 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 | Move To Another State? A Call Pre-Paid Legal at 1-800-654-7757 to locate a Pre-Paid attorney nearest you. Ask for a review. Most 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. What If | Buy Property In Another State? 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 located can tell you if the title you want to use is acceptable in that state.

pi £7991, Amencan Assocation for Serwor Citizens Complaint 123 F.T.C.

EXHIBIT 2 Q: Does Transferring Property Into a Trust Cause a Reappraisal Of The Property So That Property Taxes Are Raised? AA: No, it does not. Revenue and Taxation Code 62 specifically states that a transfer into a Revocable Living Trust does not cause a reappraisal of the property. How Should Property And Accounts Be Titled? As a general rule, all of your property should be titled in the name of your trust. Here are some examples:

ah) If you are single: ‘ .

“(your name), Trustee under trust dated (insert date you signed your trust." If you are married: 2 “(your name and your spouse's name), Trustees under trust dated linsert date you signed your trust)."

Very often you will see the letters “UTD" used as a shortened version of the words “under trust dated." : .

If 1 Qwn Partial Interest In Property With Others, Can | Transfer That Interest Into A Trust? ;

Yes. You can transfer your share of any property into the trust without affecting the shares of the others.

» oO Q: If 1 Want To Sell Assets Or Add New Assets To The Trust, Will | Need To Return To The Attorney's Office Each Time? No, you will not. You can sell assets and add new assets yourself without requiring a change of the trust.

ps Can I Sell Assets | Have In The Trust Without Any Complications? Yes, you can. You can freely sell your property even if it is in the name of the trust. The only difference will be that escrow company officials may ask for a copy of the trust documents.

ane) Can IRAs, KEOGHS And Other Tax Deferred Investments Be Transferred Into The Trust? IRAs, KEOGHS and other tax deferred investments cannot be transferred into the trust. However, the trust can be the beneficiary of those investments. Each case must be discussed with an attorney to determine whether it is better to name the trust as beneficiary, or the individuals themselves as beneficiaries. PO €1SS1, Amencan Assec-at.cn for Sener Citzers THE ADMINISTRATIVE COMPANY, ET AL. 1073 1047 Complaint EXHIBIT 2 Q: What About Adding Other Persons On My Accounts, Deeds, Etc.? 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. pe : 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 change 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 no longer fulfill their responsibilities you should make changes accordingly.

QO: When Will | Need To Update My Living Trust? A Remember that you should keep a separate list of your Special Gifts. Q: How Do! Fund My Trust? A: YOU CAN FUND YOUR TAUST BY THE FOLLOWING THREE STEPS: Go to your bank and change the name on savings, money market and certificate 1.

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 broker to change the name to the name of the family trust.

3. Finally, if you have real estate, you may use the Guick-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.

91591, Amencan Assocation tor Seruar Cauizens fn N Complaint EXHIBIT 2 isadvantages of Going Through Probate 1. Impounded or frozen accounts . Impounded safety deposit box . Probate court cost (10% or more) . Waiting period (1-3 years) 5. Attorney fees (very costly) 6. Administration fees Z. Public disclosures 8. Impounded mail . Forced asset liquidations 10. Expensive litigation 11. Possible Federal Estate Taxes and/or State Inheritance Taxes £1S91, Amencan Assoc:at.on for Senicr C-uzens nd THE ADMINISTRATIVE COMPANY, ET AL.

Complaint EXHIBIT 2 eath Probate versus Revocable Living Trust Probate Process Total Assets @ Home e e Cash e e CDs e @ Savings e @ Checking e Anything of Value Auto Land Real Estate Life Insurance Pension Living Trust 1-3 YEARS e Attorney Fees ® Administrator Fees e@ Possible Contestibility @ Public Disclosure :

Impounded Assets e@ You maintain control while you are alive ® You name someone you trust to handle Assets after death Avoids Probate No Delay Privacy No Impounded Assets SPOUSE 1-3 sod pays Heirs ©1991, Amencan Assocaton for Senior Cozens Complaint T23:P.T-C:

EXHIBIT 2 reventing These Situations 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 would 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 hause 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 awn 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 to 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 own 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 ta 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 successful and responsible adults. They made safe investments and planned carefully for their future. They owned everything jointly and even had WILLS, leaving everything to each other. But in just seconds their lives changed dramatically, Henry was in a tragic car accident, and suffered extensive head injuries and #3951. Amencan Assce:at.cn tor Senor C.uzens THE ADMINISTRATIVE COMPANY, ET AL. 1077 1047 Complaint EXHIBIT 2 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 realized she needed to 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 signatures, and since Henry could not sign his name, the only way Mary could sell their property was to place Henry into 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 legal “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 pay for the court to approve the sale of their own 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 found herself back in probate court — this time to probate Henry's WILL R 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.s), mainly to avoid probate when they die. And many mistakenly assume that their adult child will automatically be able to take over for them if they become disabled or incompetent. Most people just do not know how easily joint ownership can lead to a probate guardianship. ©7591. Amencan Assoc-aton fer Semor Citzens Complaint 123 F.T.C:

EXHIBIT 2 OTHER MEMBERSHIP BENEFITS & SERVICES THE ADMINISTRATIVE COMPANY, ET AL. 1079 1047 Complaint EXHIBIT 2 Breet.

medical Air Ambulance Services 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, ferry member or companion to accompany you in flight if space permits. ~ = = NON-INJUAY 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 1 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. Will return mortal remains. 28 ©7991, Amercan Assocaton for Senor Cuzens Complaint EXHIBIT 2 Listen to What People Say About Medical Air Services: Louis C, Timm 716-328-9824 © Rochester, New York “We could not have asked for better treatment, in fact we have been telling our friends about MASA."

Lee and Violet Frost 618-832-6538 e Anna, Illinois “We are satisfied with your service we take every opportunity to encourage friends ta enroll in MASA.”

Mrs. James (Thelma) Wilkinson 515-652-3244 « Ottumiba, lawa “We have only good thoughts and remarks ta make of Medical Air Services.”

Mr. Victor S. Kalinaski 218-681-4767 « Thief Fiver Falls, Minnesota “It was a 400 mile trip one way. We were very pleased in that no time was wasted and everything seemed very well planned. We recommend this service very highly.”

Harold and Ruth Wendt - 715-229-2770 « Owen, Wisconsin “| am now well on the way to recovery from open heart surgery while in Texas in Apri. We express our special thanks for the fine and prompt service Medical Air Services provided during our emergency. Besides providing air service home, we especially appreciated having a driver take our automobile 1700 miles to Wisconsin.”

Christine J. Adamson 313-659-6080 s Flushing, Michigan “We feel this service is very valuable far the security it provided and we feel it is one of the best investments we have ever made.”

Bruce Theel 701-477-5244 « Rolla. North Dakota “Your company is providing a critical medical service to the population living in remote areas, without air facilities closer ta major medical centers. Could you self hospitals such a service, so that more people are informed of Chis marvelous service you give at such 2 reasonable rate?”

Katherine G. Bennett 716-637-6468 ¢ Brockport, New York “The Bennetts are staunch believers that 6.<"vone should be a member of Medical Air Services. You showed concern far beyond the service anyone could expect.” , Margaret Kreutzer 204-326-9972 « Edinbury, Texas “lam very pleased with the services | received from your company after the death of my husband." Frankie Adkins 512-428-2594 e Brunswick, Missouri “We made a call ta Medical Air Services and found out our daughters flight to be with her cnitically ill father would be taken care of. We certainly thank your “flight for life" service and don't intend to be without it.”

Mrs, Joyce Evans B16-638-4561 e Urich, Missouri “Words cannot express what | feel for your company. You were all so helpful and courteous. | would love to enroll some of my friends who have not heard of your services. Please send me some enrollment applications.”

Stanley Snedgrass 513-922-4562 « Cincinnati, Ohio MASA will always be a part of our insurance program as long as it is available to us. On a scale of one to ten, we rate you a ten plus.”

Mr. and Mrs, Robert Taylor 612-894-9709 e Burnsville, Minnesota “We wish to thank you for the “hassle free” way in which you handled all the arrangements to fiy me and my injured husband home after he fractured a vertebra in his back. We say thanks for all your help.”

Helen Redekal 507-938-4241 « Canby, Minnesota “In this day and age it is very difficult to believe some company would stand behind their promises and react so efficiently and promptly in aur crisis. | highly recommend this service to each and everyone.”

€°SSt Amercan Associaton ‘cr Senor C-czens a) ny w THE ADMINISTRATIVE COMPANY, ET AL. 1081 1047 Complaint EXHIBIT 2 RX! Prescription Program The lowest price available at your local pharmacy! © Over 30,000 participating neighborhood pharmacies e Fill all your prescription needs AT or BELOW average wholesale prices ail Order Pharmacy The preferred option for maintenance medications! e TOLL FREE ORDER — Comparison cost line © NO shipping or handling charges ® Doctor-Verified prescriptions e Easy to use ® Convenient at-home delivery Savings that really add up! | £1991. Amencan Associaton for Senior Ciuzens Complaint 123 F.T.C.

EXHIBIT 2 hy ffordable Dental Connection Free & Discounted Dental Service e FREE Diagnosis e FREE Dental History e FREE Bite Wing X-Rays e FREE Flouride Treatment for Children e FREE Oral Hygiene Instructions e FREE Oral Cancer Examination < Discounts of 20% to 50% off the Dental Providers “usual and customary” fees. e General Dentistry e Orthodontists e Endodontists e Prosthodontists e Implantologists e Oral Surgeons *SS1, Amercse ~ssoc:atica fer Sawer C.tcecs THE ADMINISTRATIVE COMPANY, ET AL.

Complaint EXHIBIT 2 yewear Savings SPECS brings you savings at Sears, © Montgomery Ward, JC Penney, Dillards, Marshall Fields, Royal Optical, and many other stores.

You receive the SPECS Vision Plan free as part of your membership benefit package.

The SPECS Vision Plan is designed to offer bath you and your family savings of up to 60% on all your eyecare needs.

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.

It's so easy! There's no waiting, no forms to complete, and no limitations — all merchandise is included. Most locations are open evenings and weekends for your convenience. And, you can pay for your order with your store credit card.

Frames Lenses Eye Examinations Spectacle: 55 off regular fee Contact: $10 off regular fee “Eye Examinations are provided by Doctors af Optometry located in or adjacent to mast participaung optical departments. The fee for fitting and dispensing spectacies Gncluding unlimited adjustments) is only $B. There is no dispensing fee for contacts.

reer eter ee eee eee eee Frames up to $54 retail — you save 60% Frames $55 to $74 — you save 60% Frames over S74 ......--.-0-202000ee Pee eee eee eee eee eee eee ee Single Vision — you save 45% ........

Bifocal — you save 40% ...........++-- Trifocal — you save 40% .......-...+-- Lenticular — you save 50% .......-.- Contact Lenses & Non-Prescription Sunglasses 20% Discount from regular retail prices ete eee eee eee eet eee eee PPT Tee ee ere eee eee eee eee errr reer eee eee eee ee ee TYPICAL SAVINGS YOUR Cost $30.00 ©7991. Amencan Associaton for Senor Ciuzens 1083.

Complaint 123: F. TC.

EXHIBIT 2 earnng Aid Discounts Save 60% or MORE! e All world famous name brands.

e@ When is a $400 hearing aid better than an $800 hearing aid? When it's the same hearing aidl! 30 da y No cost - No obligation FREE home trial , Hear better today! [# hiropractic Discounts Nationwide network of over 2200 licensed chiropractors. cA @ Free Chiropractic Evaluation! © Preferred Client 15% discount.

Headaches @ Neck Pain @ Pain In Lower Back, Hips or Legs Tight Muscles or Spasms @ Decreased Flexibility Abdominal Pain @ Dizziness or Blurred Vision Shoulder or Arm Pain @ Numbness in Extremities Breathing Difficulties Get rid of that pain! — *°SS1 Amercar Associaton fer Sence C.tezens THE ADMINISTRATIVE COMPANY, ET AL. 1085 1047 Complaint EXHIBIT 2 discount Shopping Service Members save up to 50% 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.

@ Sewing Machines @ Audio Equipment @ Video Recorders ‘@ Cameras ® Carpeting e@ Exercise Equipment ® China and Silverware © Televisions ® Diamonds ® Typewriters ® Fine Jewelry ® Video Tapes ® Furniture ® Binoculars ® Personal Computers e Air Conditioners ® Luggage @ Major Appliances Plus thousands of ® Pianos and Organs other items! ~ You'll save hundreds of dollars! ©1991, American Association for Senor Citizens Complaint 123 F.T.C.

EXHIBIT 2 GI rocery Coupon Program Manufacturers 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.

THE ADMINISTRATIVE COMPANY, ET AL. 1087 1047 Complaint EXHIBIT 2 ift Ca talog Savings Galore! Our members SAVE (Ose ats up to 8O% Cameras e Jewelry ® Household Appliances e Silver Plate Watches e ‘Telephones Luggage e China ® Leather Goods e Fur Coats Silverware e Tools @ - Receive impressive sa vings on gifts for | SAMPLE SAVINGS Suggested Item Retail Your Price Ladies or mens quartz Diamond Watch............000-00-55 BIG OO: toiea geet eeetiea set S$ 23.00 35mm Camera - auto focus, auto wind, auto loading.............-. BS PSSOG «sures Goatees Ss 69.00 Cordless telephone.....-......-.--++ G W7S00. os iscesesgisseeseaas S 59.00 Ladies Black Eel-Skin purse.......... SAS 0G: s ci cadaacealtes seen 3% S 69.00 Norwegian blue Fox fur coat........-- S128G:00),.2 2. cacestewe cede cs $256.00 ©4991, Amencan Assocation for Semor Citizens Complaint 123 F.T.C.

EXHIBIT 2 cation & Travel Discounts Your membership travel services are waiting for you NOW. Let our travel consultants accommodate you! e Prompt, courteous, professional assistance Lowest currently available air fares Up to 5% off on air fares to many destinations worldwide - @ $100,000 FREE Travel Accident Insurance on selected flights e. Discounts from many of the world's most desired resorts, cruise lines, and tour packages Get that dream vacation! otel, Motel, Resort Condominium Discounts SoRN Guarantees 50% Savings e Atover 2000 hotels, motels, and resort condominiums.

e Available at thousands of destinations worlwide.

he world can be yours! 3? £1991, Amencan Association for Senor Ciuzens THE ADMINISTRATIVE COMPANY, ET AL. 1089 1047 Complaint EXHIBIT 2 ew Car Discounts 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 get you the very best price on the car you want sed Car Discounts 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 under guidelines which meet the highest standards and conditions. ©4991, Amencan Assoc:aton far Serwor Citizens Complaint 123 F.T.C.

EXHIBIT 2 ree Kodak Film 7 A $350 Value! A hae ees ne a @ Qur 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 Fresh & Beautiful @ Over 5,000 participating Florists worldwide. @ Open 24 hours a day — 7 days a week ar Rental Discounts SAVE 10% to 40% every time you rent a car! ® Free upgrade in car class at Hertz, Avis, National. ® Special exclusive flat-rates at National and Alamo. family Entertainment Discounts At such places aS: qussieasa:

Rages Ballon Markie And we are negotiating new entertainment discounts ; every day that will be added to your membership as available! Something for everyone! £1991, Amencan Assoc:at.ca for Senor C.zens 3s THE ADMINISTRATIVE COMPANY, ET AL. 1091 1047 Complaint EXHIBIT 2 AAS NATIONWIDE NON-PROFIT ORGANIZATION Decision and Order 123 F.T.C.

DECISION AND ORDER The Federal Trade Commission having initiated an investigation of certain acts and practices of the respondents named in the caption hereof, and the respondents having been furnished thereafter with a copy of a draft of complaint which the Denver Regional Office proposed to present to the Commission for its consideration and which, if issued by the Commission, would charge respondents with violation of the Federal Trade Commission Act; and The respondents, the attorney for the individual respondent, and counsel for the Commission having thereafter executed an agreement containing a consent order, an admission by the respondents of all the jurisdictional facts set forth in the aforesaid draft of complaint, a statement that the signing of said agreement is for settlement purposes only and does not constitute an admission by respondents that the law has been violated as alleged in such complaint, or that the facts as alleged in such complaint, other than jurisdictional facts, are true, and waivers and other provisions as required by the Commission's Rules; and The Commission having thereafter considered the matter and having determined that it had reason to believe that the respondents have violated the said Act, and that a complaint should issue stating its charges in that respect, and having thereupon accepted the executed consent agreement and placed such agreement on the public record for a period of sixty (60) days, now in further conformity with the procedure prescribed in Section 2.34 of its Rules, the Commission hereby issues its complaint, makes the following jurisdictional findings and enters the following order:

1. Respondent The Administrative Company is a corporation organized under and by virtue of the laws of the State of Texas, with its current address at 4328 Hollow Oak, in the City of Dallas, State of Texas. The Administrative Company has ceased doing business. Respondent Michael P..MclIntyre's current address is 4328 Hollow Oak, in the City of Dallas, State of Texas. 2. The Federal Trade Commission has jurisdiction of the subject matter of this proceeding and of the respondents, and the proceeding is in the public interest.

THE ADMINISTRATIVE COMPANY, ET AL. 1093 1047 Decision and Order DEFINITIONS For purposes of this order:

a. Living5 1 3 1 1 3 874 649 134 43 94.180687 trust means 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.

b. Probate is the legal process that validates a will, which is a legal document that contains instructions to the court on how an individual's assets and liabilities are to be divided and distributed at death.

ORDER I.

It is ordered, That respondents The Administrative Company, a corporation, its successors and assigns, and its officers; Michael P. McIntyre, individually and as an officer and director of The Administrative Company; and respondents' agents, representatives, and employees, directly or through any corporation, subsidiary, division, or other device, in connection with the advertising, promoting, offering for sale, or sale of living trusts, do forthwith cease and desist from misrepresenting, in any manner, directly or by implication, orally or in writing, 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.

A living trust cannot be challenged.

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

There are no disadvantages to a living trust. amo a Decision and Order 123 F.T.C.

I.

It is further ordered, That respondents The Administrative Company, a corporation, its successors and assigns, and its officers; Michael P. McIntyre, individually and as an officer and director of The © Administrative Company; and _ respondents’ agents, representatives and employees, directly or through any corporation, subsidiary, division, or other device, in connection with the promoting, offering for sale, or sale of living trusts, do forthwith cease and desist from failing to disclose, clearly and conspicuously, in writing, and prior to the consummation of the sale, the following information:

A. Living trusts may be challenged on similar grounds as wills. B. Living trusts may not be appropriate in all instances, and all estate planning options should be examined before determining which estate plan best suits ‘a particular individual's needs and wishes. Il.

It is further ordered, That respondents The Administrative Company, a corporation, its successors and assigns, and its officers; Michael P. McIntyre, individually and as an officer and director of The Administrative Company; and _ respondents' agents, representatives and employees, directly or through any corporation, subsidiary, division, or other device, in connection with the promoting, offering for sale, or sale of living trusts, do forthwith cease and desist from failing to disclose, clearly and conspicuously, in writing, and prior to the consummation of the sale, the following information, if true:

A. The availability of informal probate under this state's statutes allows minimal or no contact with the courts and reduces the time required to probate a will.

B. The transfer of an individual's assets into the living trust is not included in the price of creating the living trust. C. It is the sole responsibility of the purchaser of the living trust to transfer assets into the trust.

D. Creditors have a longer period of time to file a claim against a living trust than against a probated estate. THE ADMINISTRATIVE COMPANY, ET AL. 1095 1047 Decision and Order IV.

It is further ordered, That respondents The Administrative Company, a corporation, its successors and assigns, and its officers; Michael P. McIntyre, individually and as an officer and director of The Administrative Company; and respondents' agents, representatives and employees, directly or through any corporation, subsidiary, division, or other device, in connection with the advertising, promoting, offering for sale, or sale of any legal instrument, service or program, do forthwith cease and desist from making, directly or by implication, orally or in writing: A. Any statement or representation of material fact that is false or misleading; and _ B, Any statement or representation about the advantages, risks or consequences of such legal instrument, service or program unless, at the time of making the statement or reperseniniion, they possess and tely upon a reasonable basis.

V.

It is further ordered, That, for a period of five (5) years from the date of issuance of this order, respondents, and their successors and assigns, shall maintain and upon request make available to representatives of the Federal Trade Commission for inspection and copying all documents relating to living trusts or the preparation of living trusts that are developed, written, reviewed, authorized, or used by respondents, their successors and assigns, their officers, and their agents, representatives and employees, directly or through any corporation, subsidiary, division, or other device. VI.

It is further ordered, That, in connection with the advertising, promoting, offering for sale, or sale of living trusts, respondents shall maintain, for a period of five (5) years from the date of issuance of this order, books, records, and accounts which, in reasonable detail, will demonstrate compliance with this order and accurately, fairly, and completely reflect the incomes, disbursements, transactions, and use of monies by respondents and, upon reasonable notice, make such books, records, and accounts available to representatives of the Federal Trade Commission for inspection and copying. Decision and Order 123 F.T.C.

VI.

It is further ordered, That the corporate respondent shall notify the Federal Trade Commission, through its Denver Regional Office unless otherwise directed, at least thirty (30) days prior to any proposed change in the corporate respondent, such as dissolution, assignment, or sale resulting in the emergence of a successor corporation, the creation or dissolution of new corporations, subsidiaries or affiliates of the respondent, the planned filing of a bankruptcy petition, or any other corporate change that may affect compliance obligations arising out of this order. VIL.

It is further ordered, That respondent Michael P. McIntyre shall, for a period of five (5) years from the date of issuance of this order, notify the Federal Trade Commission, through its Denver Regional Office unless otherwise directed, within forty-five (45) days of the discontinuance of his present business or employment, including selfemployment and of his affiliation with a new business or employment, including self-employment. Each notice of affiliation with any new business or employment shall include the respondent's new business address and telephone number, current home address and a statement describing the nature of the business or employment and his duties and responsibilities.

IX.

It is further ordered, That respondents shall: A. Within thirty (30) days of service of this order upon them, provide a copy of this order to each of respondents' current principals, officers, directors and managers and to all personnel, agents and representatives who are or have been participating or engaging in any manner in respondents' living trust sales activities. B. For a period of five (5) years from the date of issuance of this order, provide a copy of this order to each of respondents' principals, officers, directors and managers, and to all personnel, agents and representatives who are participating or engaging in any manner in respondents' living trust sales activities, within three (3) days after the person assumes his or her position.

THE ADMINISTRATIVE COMPANY, ET AL. 1097 1047 Decision and Order X.

It is further ordered, That this order will terminate on April 14, 2017, or twenty years from the most recent date that the United States or the Federal Trade Commission files a complaint (with-or without an accompanying consent decree) in federal court alleging: any violation of the order, whichever comes later; provided, however, that the filing of such a complaint will not affect the duration of: A. Any paragraph i in this order that terminates in less than twenty years;

B. This order's application to any respondent that is not sed as a defendant in such complaint; and C. This order if such complaint is filed after the order has terminated pursuant to this paragraph.

Provided further, that if such complaint is dismissed or a ‘federal court rules that the respondent did not violate any provision ‘of the order, and the dismissal or ruling is either not appealed or upheld on appeal, then the order will terminate according to this paragraph as though the complaint was never filed, except that the order will not terminate between the date such complaint is filed and the later of the deadline for appealing such dismissal or ruling and the date such dismissal or ruling is upheld on appeal.

XI.

It is further ordered, That respondents shall, within sixty (60) days of service of this order upon them, and at such other times as the Federal Trade Commission may require, file with the Commission a report, in writing, setting forth in detail the manner and form in which they have complied with this order.

Complaint 123 F.T.C.