Lawsuits & Settlements

SAN FRANCISCO – Attorney General Kamala D. Harris today announced a $90.8 million national settlement, which includes some $6.3 million for California agencies, with the multinational Swiss bank UBS AG over allegations of anticompetitive and fraudulent conduct in the municipal bond derivatives industry.

“This financial fraud harmed school districts, cities, state agencies, and non-profit groups,” Attorney General Harris said. “The multi-million dollar settlement provides restitution to those victimized and sends a strong warning to anyone contemplating similar scams.”

California participated with federal agencies and 24 other states in the negotiations that led to today’s settlement. In addition to the approximately $6.3 million in restitution, California will be entitled to a share of the $2.5 million civil penalty and $5 million in investigation costs that UBS has agreed to pay.

Under the settlement, UBS agreed to pay back a total of $90.8 million to local and state agencies nationwide, as well as to non-profit groups, that had municipal bond derivative contracts with UBS, or used UBS as a broker, between 2001 and 2004. That restitution is part of a $160 million settlement package that includes federal agencies.

Municipal bond derivatives are contracts that tax-exempt issuers use to reinvest the proceeds of bond offerings until the funds are needed, or to hedge interest rate risk.

In 2008, a group of states began an investigation of allegations that certain large financial institutions, including national banks, insurance companies, brokers and swap advisors, engaged in various schemes to rig bids and commit other deceptive, unfair and fraudulent conduct in the municipal bond derivatives market.

The investigation, which is continuing, revealed collusive and deceptive conduct involving individuals at UBS and other financial institutions, along with certain brokers with whom they had working relationships. This conduct took the form of bid-rigging, submission of non-competitive courtesy bids and submission to government agencies, among others, of fraudulent certifications of compliance with U.S. Treasury regulations.

Regardless of the means used to perpetrate the schemes, the objective was to enrich the financial institution and/or the broker at the expense of the issuer, depriving the issuer of a competitive, transparent marketplace.

As a result of such this conduct, state, local and not-for-profit entities entered into municipal bond derivatives contracts on less advantageous terms than they would have otherwise.

Other states joining California in today’s settlement are Alabama, Colorado, Connecticut, District of Columbia, Florida, Idaho, Illinois, Kansas, Maryland, Massachusetts, Michigan, Missouri, Montana, Nevada, New Jersey, New York, North Carolina, Ohio, Oregon, Pennsylvania, South Carolina, Texas, Tennessee and Wisconsin.

The Attorney General’s investigative team in the office’s antitrust section included Senior Assistant Attorney General Kathleen Foote; Supervising Deputy Attorney General Natalie S. Manzo; Deputy Attorneys General Paula Lauren Gibson, Winston Chen and Ben Labow; Annette Goode-Parker, senior legal analyst; and Sheila Rhoads, legal analyst.

As a part of the same investigation, California reached a $67 million multi-state settlement in December with Bank of America for illegal activity by some of its employees in investing the proceeds of municipal bonds. This activity amounted to bid rigging, price fixing, and other anti-competitive practices that defrauded state agencies, local governments and non-profit groups. California’s share was about $6 million.

SAN FRANCISCO --- Attorney General Kamala D. Harris today announced a settlement with the drug store chain CVS Pharmacy, Inc. for overcharging the state’s Medi-Cal program for prescription drugs.

CVS Pharmacy will reimburse California more than $1.76 million as part of a $17.5 million settlement with the U.S. Department of Justice and nine other states, including Alabama, Florida, Indiana, Massachusetts, Michigan, Minnesota, New Hampshire, Nevada and Rhode Island.

“CVS chose to short-change taxpayers and undermine our healthcare safety net with these actions,” said Attorney General Harris. “We are all better off now that this deception has been uncovered.”

Starting in late 2002 and continuing through 2010, CVS submitted prescription drug claims to Medi-Cal for individuals who were covered by both Medi-Cal and a third-party insurance plan. The pharmacy should have first billed the primary insurer – and sought Medi-Cal reimbursement only for the remaining amount, typically the co-pay.

In 2008, a CVS pharmacist in Minnesota stepped forward to alert the authorities of the overbilling.

A multi-state investigation, in which billing and payment information was analyzed and cross-referenced to private insurance payment, found that CVS billed more than the amount allowed for so-called dual-eligible claims.

Investigating the case and negotiating the settlement with CVS were the California Attorney General’s Bureau of Medi-Cal Fraud and Elder Abuse, along with the U.S. Department of Justice, the U.S. Attorney’s Office for the Western District of Wisconsin, the U.S. Department of Health and Human Services - Office of Inspector General, and the attorneys general of the other settling states.

As part of the agreement, CVS will train its employees in accurate billing procedures. CVS has started working with individual states to make sure it bills correctly for dual-eligible beneficiaries. Pharmacy payments will also be audited on a regular basis by an independent review organization.

The funds recovered for California will be paid to the Department of Health Care Services to reimburse the state’s Medi-Cal program.

The California investigation and settlement negotiations were overseen by Supervising Deputy Attorney General Nicholas Paul and Deputy Attorneys General Erika Hiramatsu, Matt Kilman and Eliseo Sisneros.

A copy of the settlement agreement is available at ag.ca.gov.

SACRAMENTO – Attorney General Kamala D. Harris today asked a Sacramento County Superior Court to hold “Tax Lady” Roni Deutch in contempt of court, imprison her for five days on each violation and fine her thousands of dollars for shredding millions of pages of documents and failing to pay refunds to her clients in violation of a court order.

“Deutch showed herself to be a predator for profit, preying on innocent, hard-working people who were simply hoping to settle their accounts with the IRS,” Attorney General Harris said. “By defrauding these victims, and then pleading poverty, she created a real danger that her clients will never receive their advance fees back.”

In August, the Attorney General filed a $34 million lawsuit against Deutch for swindling thousands of people facing serious and expensive tax collection problems with the IRS. On August 31, the court issued an order that prohibited Deutch from destroying evidence.

“Despite this order,” the Attorney General said in today’s action, “Deutch has been routinely shredding documents on an almost a weekly basis.” The Attorney General estimates that to date Deutch has shredded some 1,643,000 to 2,708,600 pages of documents. Deutch’s shredding campaign has permanently deprived the Attorney General of evidence needed to fully prosecute the action against her.

Deutch’s law firm, based in Sacramento County, had revenues of at least $25 million a year. She spent $3 million a year on advertising, much of it on late-night cable TV, and frequently offered tax advice on popular TV shows. In her pitches, she promised to significantly reduce the IRS tax debts of people who signed up with her firm. Instead, she took thousands of dollars in up-front fees from clients but offered little or no help in lowering their tax bills. Hundreds of clients complained to the Attorney General and other government agencies.

In addition to shredding documents, the Attorney General also charged that Deutch violated a November 17 preliminary injunction by failing to issue some $435,000 in refunds to her clients within 60 days. Instead she “decided to disperse funds to friends, family and other creditors. By draining her estate and that of the law firm, Deutch has placed her clients at serious risk of never receiving their refunds.”

For instance, Deutch opted to transfer hundreds of thousands of dollars in equity from the sale of her home to a media firm. She also personally withdrew $241,000 from the law firm’s accounts and her personal accounts at just one bank. In addition, since the preliminary injunction order was issued, Deutch made more than $21,000 in unnecessary expenditures, including gifts to family and friends, and a payment to a NASCAR racing team.

The Attorney General asked the court to fine Deutch $1,000 and imprison her for five days for each count of contempt, to immediately freeze Deutch’s personal assets, and to appoint a receiver to manage her law firm’s business operations.

Copies of the court filings are attached to the version of this press release found at ag.ca.gov.

LOS ANGELES -- Attorney General Kamala D. Harris today filed a lawsuit against one of the nation’s largest funeral trusts, which pooled the funds of more than 27,000 California consumers who prepaid for funerals for themselves or loved ones, charging that the organization engaged in conspiracy and kickbacks while illegally diverting some $14 million.

Attorney General Harris filed the suit, seeking a permanent injunction and restitution to consumers, against the California Master Trust, the California Funeral Directors Association, and other defendants in Los Angeles Superior Court. The suit was filed on behalf of the Cemetery and Funeral Bureau of the Department of Consumer Affairs, which regulates the funeral industry in California.

“The defendants preyed upon thousands of Californians at one of the most vulnerable times of their lives,” Attorney General Harris said. “This lawsuit will make sure their money goes where it was intended: to pay for their funerals or the funerals of loved ones.”

The trust, created in 1985 by the funeral directors, is a “preneed” funeral trust that pools the prepaid funeral payments of individual purchasers throughout California. It controls about $63.5 million.

By the end of 2009, some 27,000 California consumers who were customers of more than 300 funeral establishments, had entrusted funds with the organization for their own or loved ones’ funeral services. They were “among California’s most vulnerable and trusting consumers,” according to the suit.

Preneed funeral contracts are usually purchased by the elderly and paid in installments. Seven years elapse on average between a consumer’s purchase of a preneed contract and the beneficiary’s death.

The suit alleges that millions of dollars of consumers’ money paid to the trust was misspent or mismanaged, that defendants paid at least $4.6 million in illegal kickbacks to funeral homes, and that the defendants paid themselves excessive administrative fees.

The suit seeks an injunction to halt such illegal activities plus restitution of about $14 million with interest. It also seeks to wrest control of the trust away from the Funeral Directors Service Corp., a subsidiary of the California Funeral Directors Association, and place it under a new trustee, and seeks a full accounting of the trust’s financial transactions as well as the defendants’ financial transactions with the trust since 2000.

Many of the problems with the California Master Trust were uncovered in an extensive audit conducted by the Cemetery and Funeral Bureau and released in June 2010.

Prosecuting the case are deputy attorney generals Nancy Kaiser and Geoffrey Ward.

Consumers with questions can call the Cemetery and Funeral Bureau toll-free at 800-952-5210.

SACRAMENTO – California Attorney General Kamala D. Harris and 37 other attorneys general today announced a $68.5 million settlement with AstraZeneca Pharmaceuticals for unfair and deceptive practices in its marketing of the antipsychotic drug Seroquel.

Today’s settlement is the largest multi-state settlement with a pharmaceutical company in history. California will receive more than $5.2 million, the largest share among the states in the consumer protection settlement.

“The health and well-being of patients should drive drug prescriptions in California, not the profits of a pharmaceutical company,” said Attorney General Harris. “This settlement puts an end to unscrupulous marketing practices and protects consumers from misguided, and potentially dangerous, treatment with Seroquel for uses the FDA has not approved.”

The complaint, filed today with the proposed judgment, alleges that AstraZeneca promoted Seroquel for unapproved uses, failed to adequately disclose potential side effects to health care providers, and withheld scientific studies that called into question the drug’s safety and efficacy.

Seroquel is an antipsychotic medication used to treat schizophrenia and bipolar disorder. It was approved by the Food and Drug Administration (FDA) for treatment of these conditions in adults, but AstraZeneca promoted the drug for children and the elderly to treat a variety of medical conditions, including anxiety, depression, post traumatic stress disorder, Alzheimer’s disease and dementia.

Doctors may prescribe medications for unapproved or “off-label” uses, but drug makers are prohibited from promoting drugs for treatment of medical conditions not approved by the FDA.

A three-year investigation, led by the attorneys general of Florida and Illinois, revealed that AstraZeneca also failed to adequately disclose side effects associated with Seroquel, including weight gain, hyperglycemia, diabetes and cardiovascular complications.

As part of today’s settlement, AstraZeneca agreed to not promote Seroquel in a false, misleading or deceptive manner, including for “off-label” uses. AstraZeneca is required to provide accurate and scientifically balanced responses to requests about off-label usage. The drug maker is also required to enact policies to ensure financial incentives are not given to salespeople for off-label marketing and post payments made to physicians on a website.

States joining California and the District of Columbia in today’s settlement include Arizona, Colorado, Connecticut, Delaware, Florida, Hawaii, Idaho, Illinois, Iowa, Kansas, Louisiana, Maine, Maryland, Massachusetts, Michigan, Minnesota, Missouri, Nebraska, Nevada, New Hampshire, New Jersey, New York, North Carolina, North Dakota, Ohio, Oklahoma, Oregon, Pennsylvania, Rhode Island, South Dakota, Tennessee, Texas, Vermont, Washington, West Virginia and Wisconsin.

Copies of the related documents are attached to the online version of this release at ag.ca.gov.

LOS ANGELES -- Attorney General Kamala D. Harris filed a lawsuit today seeking restitution and civil penalties totaling $803,100 in a scam that defrauded 33 African American churches in Southern California. Promoters promised that the leased computer kiosks would enhance the experience of parishioners, but the scheme ended up creating big debts for the churches.

The Attorney General’s lawsuit, filed today in Los Angeles Superior Court, names Television Broadcasting Online, Ltd., Urban Interfaith Network, Willie Perkins, Michael Morris, Wayne Wilson, Tanya Wilson, Balboa Capital Corp., and United Leasing Associates of America, Ltd. It charges them with violations of the state’s unfair competition and false advertising laws, and seeks restitution, civil penalties and an injunction to prevent any further illegal activities.

“This was a cruel and hypocritical scheme,” said Attorney General Harris. “The perpetrators preyed on institutions of faith. Let this be a lesson to others who may look to defraud our community organizations: you will be caught and you will be held accountable.”

The Attorney General’s complaint states that defendants Television Broadcasting Online, Ltd., Urban Interfaith Network, Willie Perkins, and Michael Morris “engaged in a nationwide scam” in which they persuaded “195 African American churches in 15 different states to enter into expensive and onerous leases for shoddy computer equipment housed in wooden cabinets.” They promised the churches the kiosks would be free, advertisers would make the lease payments and the churches would be under no financial obligation.

By 2006, the scam reached California, where 33 African American churches were persuaded to enter into leases for the kiosks. Twenty-four of the churches are located in Los Angeles County, five in Riverside County and four in San Bernardino County.

Defendants Wayne and Tanya Wilson -- on behalf of Television Broadcasting Online, Ltd., Urban Interfaith Network, Willie Perkins and Michael Morris -- pitched themselves to the California churches, according to the Attorney General’s complaint, as representing “a business/religious entity, national in scope, with strong ties to both the African American community and enlightened corporate sponsors” that wanted to help this religious community. They said the computer kiosks would connect the churches and their parishioners to “national advertisers, government, businesses and even generate some revenue for themselves.”

When the churches failed to pay the monthly lease payments, Balboa and United filed collection suits, seeking full payment plus interest, attorneys’ fees and costs.

According to the Attorney General’s complaint, the leasing companies, Balboa and United, are liable because the other defendants were acting as their agents and because, even after the leasing companies learned of the misrepresentations, they failed to alert churches to the scam and vigorously continued to enforce the terms of the leases.

Wayne and Tanya Wilson live in Rancho Cucamonga. Balboa Capital Corp. is based in Irvine. United Leasing is based in Brookfield, Wisconsin. Urban Interfaith Network, Inc. and Television Broadcasting Online, Ltd. are based in Oxon Hill, Maryland. Perkins and Morris were convicted in Michigan of racketeering, conspiracy, and false pretenses in connection with the scam. Morris is serving 5 to 20 years, and Perkins is serving 4 to 20 years.

A copy of the complaint is attached to the press release at ag.ca.gov

LOS ANGELES - Attorney General Kamala D. Harris today announced a $6.5 million settlement of a predatory lending case against Angelo Mozilo and David Sambol, former officers of Countrywide Financial Corporation. Attorney General Harris announced the settlement money will be used to establish an innovative statewide California Foreclosure Crisis Relief Fund to combat the effects of California’s high rates of foreclosure and mortgage delinquency.

“Our prior settlement with Countrywide provided restitution for foreclosed homeowners and set in motion loan modification programs that have helped tens of thousands of consumers,” Attorney General Harris said. “We will use the current settlement to help Californians affected by the mortgage crisis by providing grants to agencies that help homeowners facing foreclosure with relocation assistance and providing money to state and local agencies to prosecute mortgage fraud.”

During the 18 months ending last September, 282,000 California homes went into foreclosure, and in the last three months of 2010, notices of default were filed on another 70,000 homes in the state.

This settlement concludes litigation filed by Attorney General Edmund G. Brown Jr. in June 2008 against Countrywide Financial Corp., Countrywide Home Loans and Full Spectrum Lending, as well as Mozilo and Sambol. The financial relief provided under the current settlement augments the Attorney General’s October 2008 settlement with Countrywide to provide loan modifications and other foreclosure relief valued at $8.68 billion nationwide, with $3.5 billion provided to California borrowers.

According to the lawsuit, leading up to the mortgage crisis, Countrywide lured borrowers with low “teaser’’ rates often as low as 1 percent adjustable rate loans. Its loan officers obscured the downsides of these loans, which included rapidly rising rates after teaser rates expired, big prepayment penalties, and negative amortization in which a borrower’s total loan costs rose even as additional payments were made. Countrywide also loosened its mortgage standards and verification procedures in order to write more loans.

As a result of these practices, tens of thousands of homeowners with Countrywide loans ended up in default and foreclosure. The Attorney General’s lawsuit alleged that Mozilo and Sambol knew of these practices and allowed them to continue.

The complaint alleged that Countrywide sought to increase its share of the nationwide mortgage market to 30 percent through a deceptive scheme to mass produce loans – with little concern about borrowers’ long-term ability to afford them. It then would sell the loans on the secondary market to earn the highest possible premiums.

The settlement with Mozilo, the CEO of Countrywide, and Sambol, its president, was filed today in Los Angeles Superior Court. Mozilo and Sambol left Countrywide when it was purchased by Bank of America in July 2008.

Bank of America acquired Countrywide’s loan portfolio and assumed responsibility to make restitution to mortgage holders who qualify under the terms of the Attorney General’s 2008 settlement. Since that settlement, Countrywide has made more than 32,000 modifications, worth more than $1.3 billion, on loans made to California borrowers and has paid $28 million in cash to Californians who lost their homes to foreclosure.

A copy of the Countrywide complaint and today’s settlement are attached to the online copy of this press release at ag.ca.gov.

LOS ANGELES -- California Attorney General Kamala D. Harris today announced a settlement that places conditions on the $30 billion joint venture of Comcast and NBC Universal to safeguard innovation and protect consumer choice.

California reached this settlement in conjunction with the U.S. Department of Justice and the state attorneys general of Washington, Texas, Florida and Missouri.

“This settlement will preserve the right of consumers to enjoy the best content at the best prices and also encourages a competitive environment where innovation can thrive,” Attorney General Harris said. “With these protections, this settlement strikes the right balance between protecting consumers and ensuring a fair playing field without preventing economic development.”

Comcast, based in Philadelphia, is the largest cable television company in the nation. It is the dominant cable provider in several California markets, including the Bay Area, Sacramento and Fresno. Comcast also offers Internet and telephone services to homes and businesses, and owns several popular cable channels, including regional sports channels and the E! Entertainment channel.

The combination would give Comcast ownership of NBC Universal’s programs, local stations, production facilities, cable channels including MSNBC, CNBC, Bravo and USA Network, and a major film studio. NBC Universal, based in New York City, is also part owner of Hulu.com, which distributes television programming and other video over the Internet.

The settlement prohibits Comcast/NBC Universal from withholding its content from competitors, including other cable companies and Internet providers, who control the “pipes” to consumers. It prevents Comcast/NBC Universal from unfairly raising the price for its content to other cable companies or Internet providers, which could have the subsequent result of these companies raising pay television prices for their viewers. It also prevents Comcast/NBC Universal from restricting or degrading access of its content to other cable companies or Internet providers.

Comcast must relinquish all control over Hulu.com, and it must continue to supply NBC content to the website.

California will be able to independently enforce provisions in the settlement for at least seven years. Under the terms of the settlement, the court retains jurisdiction that will allow California or any other party to enforce the agreement, modify it and punish violations.

For example, California will be able to prevent Comcast/NBC Universal from retaliating against any broadcast TV network, cable programmer, local TV station, or video producer for providing video programs to a Comcast competitor. The settlement gives California the power to enforce Comcast’s obligation to provide any online video distributor the same programs it provides to any tradition pay television system with equivalent terms and conditions. Comcast is also prohibited from restricting the further distribution of its video programs by companies to whom it sells programs.

The FCC also issued an order today approving the proposed transaction with conditions.

A copy of the complaint and settlement are attached to the online version of this press release at ag.ca.gov.

LOS ANGELES – Attorney General Kamala D. Harris today announced that her office had stopped Bioelements, Inc., a cosmetics company operating in California, from engaging in “a blatant price-fixing scheme” in which it prohibited retailers from selling its products online at a discount.

“Bioelements operated a blatant price-fixing scheme by requiring online retailers to sell its products at high prices,” Harris said. “Price manipulation harms consumers, competition and our business community. We will continue to be vigilant in protecting our markets from these kinds of abuses.”

The settlement is one of the first applications of California’s strict, pro-consumer antitrust law banning vertical price-fixing in the wake of a controversial 2007 U.S. Supreme Court decision that weakened federal law in this area. Vertical price-fixing occurs when companies along the distribution chain conspire to set the price of a product or service at an artificially high level. In California, prices must be set independently -- and competitively -- by distributors and retailers.

Bioelements markets a line of human beauty-care products under its BIOELEMENTS trademark, offering skin products it claims have quasi-medicinal properties such as reducing wrinkles. These products -- known as “cosmesceuticals” because they supposedly merge the attributes of cosmetics and pharmaceuticals -- are sold at beauty salons across California, as well as on the Internet.

An investigation initiated by Harris’ predecessor as attorney general, Edmund G. Brown Jr., revealed evidence that since 2009, Bioelements had entered into dozens of contracts with other companies that required them to sell Bioelements’ products online for at least as much as the retail prices prescribed by Bioelements. (There were no express pricing requirements for products sold in person or in shops.)

In doing so, Bioelements violated California’s antitrust and unfair competition laws.

Under the settlement, in the form of a stipulated court judgment signed Tuesday by Riverside Superior Court Judge Harold W. Hopp, Bioelements is required to:

• Permanently refrain from fixing resale prices for its merchandise

• Inform distributors and retailers with whom Bioelements made price-fixing contracts that Bioelements considers the contracts void and will not try to enforce them

• Pay a total of $51,000 in civil penalties and attorney fees.

The 2007 U.S. Supreme Court decision Leegin Creative Leather Products, Inc. v. PSKS, Inc. sharply curtailed federal antitrust law pertaining to vertical price-fixing, but did not affect California’s strict state antitrust law. In the last three years, the California Attorney General has sent two open letters to Congress urging passage of legislation reinstating federal safeguards against vertical price-fixing schemes like Bioelements’. In February 2010, the Attorney General obtained an injunction under California law against another cosmetics company, DermaQuest, Inc., which halted a price-fixing scheme similar to Bioelements’.

A copy of People v. Bioelements civil complaint and the stipulated judgment are attached to the press release online at www.ag.ca.gov.

SAN DIEGO – Attorney General Edmund G. Brown Jr. today announced a $2.4 million settlement with the perpetrators of an illegal scheme that threatened thousands of companies throughout California with fines or even suspension of their right to conduct business if they failed to return official-looking but fraudulent forms along with a mandatory filing fee.

“These imposters used phony documents that appeared to originate from a government office to gain payment from law-abiding businesses,” Brown said. “This settlement puts a stop to their scheme and secures restitution for the companies that were cheated.”

The civil settlement filed in San Diego Superior Court names Annual Review Board, Inc.; Business Filings Division; Corpfilers.com, LLC; George Alan Miller; Rebecca J. Miller; Argishti Keshishyan, and Kristina Keshishyan. The settlement requires the defendants to make restitution of $1,750,000 to customers and pay an additional $650,000 in penalties and costs to the state.

To preserve the defendants’ assets, the Attorney General moved successfully last year to freeze their bank accounts.

The bogus operation constitutes what is known as a corporate filing scheme. Solicited victims were told they had to pay a $195 filing fee accompanying return of the phony documents.

Brown’s investigation found that the defendants, based in Los Angeles County, misled well over 5,000 customers into paying by utilizing phony forms that:

•Had an official looking seal
•Used a “control number”
•Had a “Corporation Number” or “LLC Number”
•Used official sounding titles and names, such as “Corporation Division”, that implied a governmental connection
•Specified a “due date” and employed the phrase “Remit Immediately!”
•Described the payment as an annual fee
•Warned that failure to respond could lead to the recipient being suspended and losing its right to conduct business

The investigation was triggered by a flood of complaints to the Attorney General’s office from businesses that had been victimized. The scheme flourished because the forms seemed routine and the payments demanded were small.

As part of the settlement, the defendants are permanently enjoined from making fraudulent representations. Brown urged businesses to be vigilant against similar scams.

Restitution will be handled by a claims administrator who will be named by the Attorney General’s office. More information will be available on the Attorney General’s website at http://ag.ca.gov/.

This is the latest settlement of eight actions the Attorney General has prosecuted against corporate filing schemes. In a case tried in San Diego Superior Court last year, Brown won a $1.2 million judgment against Gaston Muhammad and Ronna Green for running a corporate filing scheme that swindled California companies.

A copy of the complaint and the stipulation for entry of judgment filed in the San Diego County Superior Court are attached.