Free Notice (Other) - District Court of California - California

Case 3:08-cv-01718-VRW

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WILLIAM BLUMENTHAL General Counsel JANICE L. CHARTER Colo. Bar No. 12750 DAVID M. NEWMAN Cal. Bar No. 54218 THOMAS DAHDOUH N.Y. Bar No. 2222370 Federal Trade Commission 901 Market Street, Suite 570 San Francisco, CA 94103 Phone (415) 848-5100/ Fax (415) 848-5184 [email protected] [email protected] [email protected] Attorneys for Plaintiff Federal Trade Commission UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION FEDERAL TRADE COMMISSION, Plaintiff, v. NEXTCLICK MEDIA, LLC, a Delaware limited liability company, dba StopSmoking180.com, StopSmokingResolution.com, BeautifulSkin.com, and OnLineDirectProducts; NEXT INTERNET, LLC, a Delaware limited liability company; KENNETH CHAN, individually and as an officer of NEXTCLICK MEDIA, LLC, and NEXT INTERNET, LLC; and ALBERT CHEN, individually and as an officer of NEXTCLICK MEDIA, LLC, 4:08-cv-01718 VRW

PLAINTIFF'S RECOMMENDATION FOR TEMPORARY RECEIVER

Defendants. Plaintiff the Federal Trade Commission ("FTC" or "Commission"), in conjunction with its application for a temporary restraining order with asset freeze and other equitable
Recommendation for Receiver

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relief, including appointment of a temporary receiver, submits the name of Stephen E. Andersen as a candidate for the Court to consider for appointment as a temporary receiver in the above-captioned matter. As noted in the attached resume, Ex. A, Mr. Andersen possesses outstanding qualifications to serve in this regard. A principal at Pine Grove Associates since 1995, he has most recently served as a receiver in an SEC action in the Northern District of California involving a $17 million real estate investment scheme. He has also served as a receiver in a major criminal bank fraud matter in state Superior Court in Contra Costa County. Before 1995, he was a commercial banker specializing in commercial, real estate, and construction lending, problem loan resolution, and the disposition of foreclosed property. He is assisted by others in his firm, including Stephan A. Werth, a Certified Public Accountant, Certified Financial Planner, and Certified Fraud Examiner. Should he need legal counsel, he will avail himself of the services of Jamie L. Dupree, whose qualifications are listed on Ex. B. Mr. Andersen's rates are shown on Ex. C. Based on all of these factors, the Commission believes that Mr. Andersen is eminently qualified to serve as a receiver in this matter.

Respectfully submitted this March day of 31, 2008,

/S/ JANICE L. CHARTER DAVID M. NEWMAN THOMAS DAHDOUH Federal Trade Commission Attorneys for Plaintiff Federal Trade Commission

Recommendation for Receiver

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