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Patrick J. Reilly, Esq. Nevada Bar No. 6103 Leslie M. Nino, Esq. Nevada Bar No. 11672 Holland & Hart LLP 9555 Hillwood Drive, Second Floor Las Vegas, Nevada 89134 Tel: (702) 669-4600 Fax: (702) 669-4650 [email protected] Attorneys for Relief Defendants Kim C. Tucker and Park 269 LLC
UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA
FEDERAL TRADE COMMISSION, Plaintiff, vs. AMG SERVICES, INC., an Oklahoma Tribal Entity; RED CEDAR SERVICES, INC., an Oklahoma Tribal Entity, also dba 500 FastCash; SFS, INC., a Nebraska Tribal Entity, also dba OneClickCash; TRIBAL FINANCIAL SERVICES, an Oklahoma Tribal Entity, also dba Ameriloan, UnitedCashLoans, USFastCash, and Miami Nation Enterprises; AMG CAPITAL MANAGEMENT, LLC, a Nevada Limited Liability Company; LEVEL 5 MOTORSPORTS, LLC, a Nevada Limited Liability Company; LEADFLASH CONSULTING, LLC, a Nevada Limited Liability company; PARTNER WEEKLY, LLC, a Nevada Limited Liability Company; BLACK CREEK CAPITAL CORPORATION, a Nevada Corporation; BROADMOOR CAPITAL PARTNERS, LLC, a Nevada Limited Liability Company; THE MUIR LAW FIRM, LLC, a Kansas Limited Liability Company; SCOTT A. TUCKER, in his individual and corporate capacity; BLAINE A. TUCKER, in his individual and corporate capacity; TIMOTHY J. MUIR, in his individual and corporate capacity; DON E. BRADY, in his individual and corporate capacity; and TROY L. LITTLEAXE, in his individual and corporate
Case No. : 2:12-cv-00536-GMN-VCF RELIEF DEFENDANTS KIM C. TUCKER AND PARK 269 LLC’S OPPOSITION TO PLAINTIFF TRADE COMMISSIONS’ MOTION FOR PRELIMINARY INJUNCTION AND OTHER EQUITABLE RELIEF (DOC. NO. 4) (Oral Argument Requested)
Case 2:12-cv-00536-GMN -VCF Document 62 Filed 05/04/12 Page 1 of 12
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capacity, Defendants, and PARK 269 LLC, a Kansas Limited Liability Company; and KIM C. TUCKER, in her individual and corporate capacity, Relief Defendants.
Relief Defendants Kim C. Tucker (“Ms. Tucker”) and Park 269, LLC (“Park 269”), by
and through their attorneys, Holland and Hart, LLP, hereby oppose Plaintiff Federal Trade
Commission’s Motion for Preliminary Injunction and Other Equitable Relief [Doc. No. 4] and
Plaintiff’s Memorandum of Points and Authorities in Support of Motion for Preliminary
Injunction and Other Equitable Relief [Doc. No. 5] (the “Motion”). This Opposition is made
pursuant to LR 7-2 and is based on the pleadings on file herein and the points and authorities
below.
I. INTRODUCTION
The FTC has named Ms. Tucker and Park 269 as Relief Defendants, seeking
disgorgement of monies that they have allegedly received, directly or indirectly, from certain of
the defendants named in this action. The FTC does not allege that Ms. Tucker or Park 269
actually engaged in any deceptive or unlawful lending or debt collection practice, or that they
collaborated with or otherwise controlled the Tribal Lending Entities (defined as Red Cedar
Services, Inc., Tribal Financial Services Corporation, and SFS, Inc.) so as to subject them to any
liability. Rather, the FTC, based on nothing more than hollow conclusions, speculation and
innuendo, claims that Ms. Tucker and Park 269 received or are in possession of “ill-gotten gains”
from the alleged deceptive or unlawful practices of the Tribal Lending Entities named in this
action. In turn, based on equally deficient and unsupported allegations in its Motion, the FTC
asks this Court to force Ms. Tucker and Park 269, by way of a mandatory injunction, to provide
overreaching, irrelevant, burdensome, and private financial information.
The FTC’s Motion is without merit and should be flatly denied. First, it is beyond
dispute that disgorgement against a relief defendant will not lie if the FTC does not establish the
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lenders engaged in a fraudulent, deceptive or unlawful practice in the first instance. As set forth
in the Tribal Defendants’ Opposition Brief, which is incorporated here, the FTC cannot establish
any likelihood of success on the merits of its request for an injunction because it cannot
demonstrate that any of the Tribal Lending Entities actually violated the FTC Act, the TILA, or
the EFTA. Without an unlawful practice, there can be no “ill-gotten gains” linked to such
practice from which any claim for disgorgement would flow.
Even assuming arguendo that the FTC could establish some violation of any of these
provisions, the monies that the FTC asks the Relief Defendants to disgorge did not come from
the Tribal Lending Entities1; those distributions came from two non-lenders—Black Creek
Capital Corporation (“Black Creek”) and AMG Services, Inc. (“AMG”).2
Finally, the FTC has not properly alleged or submitted competent evidence showing that
the disbursements of funds made to the Relief Defendants were in fact “ill-gotten gains,” or that
the Relief Defendants have no legitimate claim to those monies, as required for disgorgement.
For all of these reasons, the FTC is unlikely to prevail on the merits as to the claims asserted Ms.
Tucker and Park 269 and its Motion for Preliminary Injunction should be summarily denied.
Accordingly, to
prevail on its claim of disgorgement, the FTC must establish that each of these non-lender
entities is jointly and severally liable for the alleged lending practices as part of a “common
enterprise” with the Tribal Lending Entities. As set forth in the Tucker Defendants’ Opposition
to the Motion for Preliminary Injunction, which is incorporated here, the FTC has not properly
alleged, let alone established with any competent evidence, that these non-lenders were part of
some common enterprise that directed or controlled the lending activities from which any
liability as a “collaborating defendant” could arise.
/ / /
/ / /
1 Although the FTC’s Motion vaguely references distributions made to Ms. Tucker from Broadmoor Capital Partners, LLC (“Broadmoor”) (Motion, p. 35), the FTC does not identify any such distributions, nor does Budich’s Declaration show any payments to Ms. Tucker from Broadmoor. (Motion, PX22, p. 618). 2 The FTC’s Motion erroneously claims that AMG is a lender. As set forth in the Tribal Defendants’ Opposition, AMG does not make any short-term, online loans. Rather, AMG is a shared services provider that provides employee staffing and related services to the Tribal Lending Entities. AMG is also tribally-owned.
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II. ARGUMENT
A. STANDARD FOR INJUNCTIVE RELIEF
“A preliminary injunction is an extraordinary remedy never awarded as of right.” Winter
v. Natural Resources Defense Council, Inc., 555 U.S. 7, 24 (2008). “An injunction is a matter of
equitable discretion; it does not follow from success on the merits as a matter of course.” Id. at
32 (quoting Romero–Barcelo, 456 U.S. 305, 313 (1982) (“[A] federal judge sitting as chancellor
is not mechanically obligated to grant an injunction for every violation of law”)). In order to
obtain injunctive relief, the FTC must make “a proper showing that weighing the equities and
considering the Commission’s likelihood of ultimate success, such action would be in the public
interest.” 15 U.S.C. § 53(b)(2). This is consistent with Federal Rule of Civil Procedure 65, which
requires evidence be “admissible at trial.” Fed. R. Civ. P. 65(a)(2); see also Winter, 555 U.S. at
20-22 (plaintiff is required to submit admissible evidence supporting his contention that he is
entitled to the relief he seeks). As the United States Supreme Court has stated, “a preliminary
injunction is an extraordinary and drastic remedy, one that should not be granted unless the
movant, by a clear showing, carries the burden of persuasion.” Mazurek v. Armstrong, 520 U.S.
968, 973 (1997) (internal quotation omitted).
B. THE FTC FAILS TO ESTABLISH ANY OF THE PREREQUISITES FOR
INJUNCTIVE RELIEF, AND ITS MOTION SHOULD BE DENIED.
In order to even reach a claim of disgorgement against Ms. Tucker or Park 269, the FTC
must first establish (1) the Lending Defendants engaged in an unlawful or deceptive practices;
(2) AMG and/or Black Creek were part of a “common enterprise” with the Tribal Lending
Entities to engage in such alleged unlawful or deceptive practices; (3) monies distributed to Ms.
Tucker or Park 269 from AMG and/or Black Creek were directly derived from unlawful or
deceptive lending practices and thus constitute “ill-gotten gains”; and (4) Ms. Tucker and Park
269 have no legitimate claim to the monies paid. The FTC has not met and cannot meet any of
these levels of proof necessary to require Ms. Tucker or Park 269 to disgorge any funds, let alone
subject them to a mandatory injunction.
/ / /
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1. As Set Forth In The Tribal Lending Defendants’ Opposition, The FTC Cannot
Establish That It Is Entitled To A Preliminary Injunction
.
The FTC is unlikely to prevail on the merits of its claims against the Tribal Lending
Defendants in the first instance, which automatically precludes the claims against the Relief
Defendants sought here. Ms. Tucker and Park 269 incorporate the facts, evidence and arguments
contained in the Tribal Lending Defendants’ Opposition to the FTC’s Motion for Preliminary
Injunction as though fully set forth here. As set forth in that briefing, the FTC’ Motion for
Preliminary Injunction should be denied because the FTC cannot establish that an unlawful or
deceptive practice occurred, that irreparable harm will occur if an injunction is not issued, or that
the balance of the equities weighs in favor of injunctive relief. These same arguments apply with
equal force to all claims asserted against Ms. Tucker and Park 269 here.
2. As Set Forth In The Tucker Defendants’ Opposition, The FTC Cannot Establish The Non-Lenders are Part of a Common Enterprise with the Tribal Lending Entities Required for Collaborating Defendant Liability
.
Setting aside the foregoing, the FTC is not entitled to disgorgement of funds from Ms.
Tucker or Park 269, or to an injunction forcing them to disclose irrelevant, burdensome and
private financial information, because the FTC cannot trace these disbursements to the lending
activities. Ms. Tucker and Park 269 did not receive disbursements from any of the Tribal
Lending Entities—they received disbursements from AMG and Black Creek. Thus, the FTC, as
a second step in its burden of proof, must establish that Black Creek and AMG are part of a
common enterprise involving the lending practices, and are therefore, jointly and severally liable
for the alleged conduct of the Tribal Lending Entities. The FTC has not done so. Ms. Tucker
and Park 269 incorporate the facts, evidence and arguments contained in the Tucker Defendants’
Opposition to the FTC’s Motion for Preliminary Injunction as though fully set forth here. As the
Tucker Defendants demonstrate, the FTC has not properly alleged, let alone submitted
admissible evidence showing that the non-lenders were part of any common enterprise with the
Tribal Lending Entities involving the alleged unlawful activity upon which individual or joint
and several liability could arise. On this basis alone, the FTC’s Motion for Preliminary
Injunction must be denied as to Ms. Tucker and Park 269.
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As set forth in detail in the Tucker Defendants’ Opposition, the FTC (1) offers only
vague and legally insignificant evidence in support of its request for injunctive relief; (2) fails to
plead its claims against defendants with particularity as required by Federal Rule of Civil
Procedure 9(b); and (3) improperly lumps all defendants together and fails to show how each
defendant is individually liable for the conduct alleged. As such, the FTC’s claims against the
non-lenders fail as a matter of law and cannot support the FTC’s request for preliminary
injunction here. See, e.g., Chavez-Gallegos v. First Magnus Fin. Corp., 2011 WL 6402182, *1
(D. Nev. Dec. 20, 2011) (denying preliminary injunction where complaint only offered
conclusory allegations that failed to show plausible claims for relief regarding alleged lending
violations). Because the FTC cannot show that Black Creek or AMG are liable for the alleged
unlawful or deceptive practices of the Tribal Lending Entities, monies paid to Relief Defendants
from Black Creek or AMG are not “ill-gotten gains” that are required to be disgorged.
3.
The FTC is Unlikely to Prevail on the Merits for Disgorgement from the Relief Defendants Because Monies Disbursed were not Ill-Gotten Gains.
Even though the FTC cannot establish that the Tribal Lending Entities actually engaged
in some unlawful or deceptive practice, and cannot demonstrate that non-lenders Black Creek or
AMG were part of a common enterprise with the Tribal Lending Entities involving such
practices, there are additional reasons why the FTC cannot prevail on the merits of its claims
against the Relief Defendants.
A court may order disgorgement from a relief defendant who has engaged in no
wrongdoing only upon a finding that the relief defendant “(1) is in possession of ill-gotten funds,
and (2) lacks a legitimate claim to those funds.” Commodity Futures Trading Com'n v. Walsh,
618 F.3d 218, 225 (2d Cir. 2010). If a relief defendant establishes a legitimate claim to the funds
in his or her possession, they are not subject to disgorgement. Id. at 226–27. The ill-gotten gains
must be linked to the unlawful practices of the liable defendants. “A relief defendant can show
a legitimate claim to the funds received by showing that some services were performed in
consideration for the monies.” FTC v. Bronson Partners, LLC, 674 F. Supp.2d 373, 392 (D.
Conn. 2009). The burden rests with the Commission to show that the funds in the possession of
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a relief defendant are ill-gotten. FTC v. Direct Mktg. Concepts, 569 F. Supp.2d 285, 312 (D.
Mass. 2008). The FTC has not made and cannot make such a showing here.
In particular, the FTC seeks disgorgement from Ms. Tucker of $844,263 in monies she
received from Black Creek, as well as $4,133,599 in monies Ms. Tucker jointly received with
her husband Scott Tucker from Black Creek. (Motion, p. 13). The FTC baldly claims that Ms.
Tucker has no legitimate claim to these assets, solely because they are traceable to funds
obtained as part of the Lender’s deceptive and unlawful lending practices. (Id). The FTC offers
no competent evidence to support this conclusion. The FTC offers only hearsay, unauthenticated
and foundationally devoid conclusions in the Declaration of Victoria Budich,3
When one carefully looks at Ms. Budich’s Declaration, and the summary of the Black
Creek bank account, it is readily apparent that the vast majority of the monies flowing in and out
of that account have no connection whatsoever to the Tribal Lending Entities, or their lending
activities. Indeed, of the approximately $40 million deposited into that account over a 3 year
period, only $4,363,083 can be traced as coming from the “Lending Defendants” as erroneously
defined by the FTC’s pleadings (AMG, Red Cedar Services, Inc., MTE Financial Services, Inc.,
SFS, Inc., and TFS Corp.). (Motion, PX22, p. 616-17, ¶81). Thus, any so-called “ill-gotten
gains” that could even arguably be traced to the Black Creek bank account are only a small
fraction of the monies actually flowing through that account from non-lending activities.
Because approximately $36 million clearly cannot be linked to the Tribal Lending Entities, or
their lending activities, the FTC cannot simply assume that monies paid to Ms. Tucker from that
account were in fact connected to, or derived from, any unlawful lending practices. Thus, the
FTC has not met its burden of showing that Ms. Tucker received any “ill-gotten gains,” or that
who has purported
to have summarized the monies flowing in and out of Black Creek based on bank statements and
other financial information obtained through the FTC’s investigation. That so-called “evidence”,
however, actually demonstrates the fatal flaws in the FTC’s claims.
3 Relief Defendants hereby join in the Tucker Defendants’ Motion to Strike, as well as in the separate Motion to Strike filed by defendants Timothy J. Muir and the Muir Law Firm, LLC. For the reasons set forth therein, the FTC’s pleadings should be stricken, or alternatively, the Declaration of Victoria Budich and the references to the financial documents therein should be stricken.
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she was not legitimately entitled to the disbursements made. Absent such showing, the FTC is
not entitled to the injunctive or equitable relief it seeks against the Relief Defendants, and its
Motion should be denied.
C. THE PROPOSED INJUNCTION IS OVERLY BROAD AND IS NOTHING
MORE THAN AN IMPROPER FISHING EXPEDITION
Preliminary injunctions “must be narrowly tailored … to remedy only the specific harms
shown by the Plaintiffs, rather than ‘to enjoin all possible breaches of the law.’” Price v. City of
Stockton, 390 F.3d 1105, 1117 (9th Cir. 2004) (citation omitted); see also Califano v. Yamasaki,
442 U.S. 682, 702 (1979) (“[I]njunctive relief should be no more burdensome to the defendant
than necessary to provide complete relief to the plaintiffs.”) The FTC’s proposed Order as to the
Relief Defendants does not meet these standards and should be rejected. The FTC seeks to use
preliminary injunctive relief as a means to conduct a fishing expedition by way of overly broad,
irrelevant and harassing disclosure requirements that have no bearing on the claims against the
Relief Defendants here.
The FTC concedes in its Motion that the only distributions as to the Relief Defendants at
issue here are those made from AMG and Black Creek. Those distributions have been
specifically identified, and the FTC has gone to great lengths to list out various payments made
by or on behalf of Relief Defendants from the AMG and Black Creek bank accounts. The FTC
does not claim that other distributions have been made or that other monies or assets should be
disgorged. Yet, without any explanation or justification, the FTC asks this Court to force Ms.
Tucker and Park 269 to complete onerous and overreaching financial statements and provide
myriad documents that seek information that is not even arguably relevant to these narrowly-
defined distributions.
For example, the FTC wants Ms. Tucker to provide the names and social security
numbers of her children; a detailed breakdown of all income received from any source and all
expenses for an undefined period; all lawsuits involving Ms. Tucker or her spouse for an
undefined period; all life insurance policies held by Ms. Tucker or her spouse; a complete
description of all assets, including personal property, real estate, vehicles, and securities owned
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by either Ms. Tucker or her spouse; a complete description of all liabilities of either Ms. Tucker
or her spouse, going so far as to require a listing of credit card balances. (Proposed Order,
Attachment 1). Similarly, notwithstanding that it already has much of the information that it
seeks, the FTC wants this Court to force Park 269 and Ms. Tucker to identify all of Park 269’s
current and former members, managers, accountants, and attorneys over the past three years, as
well as provide detailed descriptions of its business transactions, its assets and its liabilities.
(Proposed Order, Attachment 2).
The FTC’s “preliminary” relief request as to these defendants is nothing more than
burdensome and intrusive full accountings. The FTC’s Proposed Order is premature to say the
least. As set forth above, the FTC cannot establish any right to recover the relief it seeks from
Ms. Tucker and Park 269 and cannot prevail on the merits of its claims. Therefore, no injunctive
relief is proper. The proper time to seek relevant and narrowly-tailored financial information
from Relief Defendants, if at all, is in connection with routine discovery that may be commenced
consistent with the Federal Rules of Civil Procedure if and only if this Court has determined that
the FTC has stated a claim against defendants upon which relief can be granted. The FTC offers
no justification for its extraordinary remedy of “expedited discovery,” let alone the draconian
fishing expedition that it seeks to employ against admittedly non-culpable parties here. “Judges
are trusted to prevent ‘fishing expeditions’ or an undirected rummaging through bank books and
records for evidence of some unknown wrongdoing.” Cuomo v. Clearing House Ass'n, L.L.C.,
557 U.S. 519, 129 S. Ct. 2710, 2717 (2009).
/ / /
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III. CONCLUSION
Based on the foregoing, the Relief Defendants respectfully request that the Court deny
the FTC’s Motion for Preliminary Injunction against them, and award them such further relief to
which they may be entitled
DATED this 4th day of May, 2012.
_______/s/ Patrick J. ReillyPatrick J. Reilly, Esq.
___________________
Leslie M. Nino, Esq. Holland & Hart LLP 9555 Hillwood Drive, Second Floor Las Vegas, Nevada 89134 Attorneys for Relief Defendants Kim C. Tucker and Park 269 LLC
Case 2:12-cv-00536-GMN -VCF Document 62 Filed 05/04/12 Page 10 of 12
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CERTIFICATE OF SERVICE
I hereby certify that on the 4th day of May, 2012, a true and correct copy of the foregoing
RELIEF DEFENDANTS KIM C. TUCKER AND PARK 269 LLC’S OPPOSITION TO
PLAINTIFF TRADE COMMISSIONS’ MOTION FOR PRELIMINARY INJUNCTION
AND OTHER EQUITABLE RELIEF (DOC. NO. 4) AND PLAINTIFF’S
MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF MOTION FOR
PRELIMINARY INJUNCTION AND OTHER EQUITABLE RELIEF (DOC. NO. 5) was
served on counsel through the Court’s electronic service system as follows:
Daniel G. Bodgen, Esq.
Electronic Service:
United States Attorney District of Nevada Blaine T. Welsh, Esq. Assistant United States Attorney 333 Las Vegas Blvd. South, Suite 5000 Las Vegas, Nevada 89101 Tel: (702) 388-6336 Fax: (702) 388-6787 Email: [email protected] Willard K. Tom, Esq. General Counsel Nikhil Singhvi, Esq. Julie G. Bush, Esq. Jason D. Schall, Esq. Federal Trade Commission 600 Pennsylvania Avenue, NW Mailstop NJ-3168 Washington, D.C. 20580 Tel: (202) 326-3480 (Singhvi) Fax: (202) 326-3629 Email: [email protected]
[email protected] [email protected]
Attorneys for Plaintiff Federal Trade Commission
Von S. Heinz, Esq. Leif Reid, Esq. Darren J. Lemieux Lewis & Roca, LLP 3993 Howard Hughes Parkway Suite 600 Las Vegas, Nevada 89169 Tel: (702) 949-8200 Fax: (702) 949-8351 Email: [email protected] [email protected] [email protected] Attorneys for Defendants AMG Capital Management, LL C; Level 5 Motorsports, LLC; LeadFlash Consulting LLC; Blackcreek Capital Corporation; Broadmoor Capital Partners LLC; Scott A. Tucker; Blaine A. Tucker
Case 2:12-cv-00536-GMN -VCF Document 62 Filed 05/04/12 Page 11 of 12
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David J. Merrill, Esq. 10161 Park Run Drive, suite 150 Las Vegas, Nevada 89145 Tel: (702) 566-1935 Fax: (702) 924-0787 Email:P [email protected] Attorneys for Defendants AMG Services, Inc.; Red Cedar Services, Inc. dba 500FastCash; SFS, Inc. dba OneCl.ickCash; Tribal Financial Services, dba Ameriloan, UnitedCashnLoans, USFastCash, Miami Nation Enterprises
Jay Young, Esq. Marquis Aurbach Coffing 10001 Park Run Drive Las Vegas, Nevada 89145 Tel:P (702) 382-0711 Fax: (702) 856-8900 Email: [email protected] Attorneys for Defendant Robert D. Campbell
L. Christopher Rose, Esq. Jolley Urga Wirth Woodbury & Standish 3800 Howard Hughes Parkway Sixteenth Floor Las Vegas, Nevada 89169 Tel: (702) 699-7500 Fax: (702) 699-7555 Email: [email protected] Attorneys for Timothy J. Muir and The Muir Law Firm, LLC
Andrew P. Gordon, Esq. McDonald Carano & Wilson LLP 2300 West Sahara Avenue, Suite 1000 Las Vegas, Nevada 89102 Tel: (702) 873-4100 Fax: (702) 8739966 Email: [email protected] Attorneys for Partner Weekly, LLC
Paul C. Ray, Esq. Paul C. Ray, Chtd. 8670 West Cheyenne Avenue, Suite 120 Las Vegas, Nevada 89129 Tel: (702) 823-2292 Fax: (702) 823-2384 Email: [email protected] Attorneys for Troy L. Littleaxe
Greg Brower, Esq. Brian R. Reeve, Esq. Snell & Wilmer 3883 Howard Hughes Parkway Suite 1100 Las Vegas, Nevada 89169 Tel: (702) 784-5200 Fax: (702) 784-5252 Email: [email protected] [email protected] Attorneys for Don E. Brady
Via U.S. Mail
:
Nathan F. Garrett, Esq. Whitney Paige Strack, Esq. Graves Bartle Marcus & Garrett, LLC 1100 Main Street, suite 2700 Kansas City, MO 64105 Tel: (816) 256-3181 Fax: Email: [email protected] [email protected] Attorneys for Don E. Brady
An employee of Holland & Hart LLP /s/ Susann Thompson
Case 2:12-cv-00536-GMN -VCF Document 62 Filed 05/04/12 Page 12 of 12
