Federal Trade Commission v. Lead Express, Inc.

District Court, D. Nevada·Decided May 19, 2020·No. 2:20-cv-00840·Unknown

Opinion

3 Federal Trade Commission, Case No.: 2:20-cv-00840-JAD-NJK

4 Plaintiff Filed Under Seal

5 v. Order Granting in Part Ex Parte Emergency Motion for Temporary 6 Lead Express, Inc., et al., Restraining Order and Requiring Defendants to Show Cause 7 Defendants [ECF No. 3] 8

9 The Federal Trade Commission (FTC) sues a host of individuals and entities for a 10 permanent injunction and other equitable relief under 15 U.S.C. §§ 53(b), 57b, 6105(b), 1607(c), 11 and 1693o(c), alleging that they operate a massive payday-lending scheme that baits consumers 12 with telemarketed loans that have a fixed number of principal-plus-interest payments but 13 switches to unlimited finance-fee-only payments after the consumer agrees.1 The FTC moves on 14 an ex parte and emergency basis for an order temporarily restraining defendants from engaging 15 in the scheme, destroying records of the scheme’s operations, or dissipating assets.2 It also seeks 16 an order requiring the defendants to show cause why the temporary restraining order—if one is 17 entered—should not be converted into a preliminary injunction. Finally, the FTC seeks an order 18 appointing a receiver, authorizing limited discovery into the location and identity of defendants’ 19 documents and assets, and authorizing the FTC to immediately access defendants’ businesses. 20 21 1 ECF No. 1 (complaint). The FTC’s claims arise under the Federal Trade Commission Act, the 22 Telemarketing and Consumer Fraud and Abuse Prevention Act, the Truth in Lending Act, the Electronic Fund Transfer Act, and the rules and regulations that have been promulgated to 23 implement those Acts. 2 ECF No. 3 (emergency motion). 1 For the reasons set forth below, I grant in part the motion for a temporary restraining 2 order; I order the defendants to show cause why (1) the restraining order should not be converted 3 into a preliminary injunction (2) a receiver should not be appointed, (3) foreign assets should not 4 be repatriated, and (4) the FTC should not be allowed expedited discovery and access to the 5 defendants’ businesses; and I set those matters for hearing on June 2, 2020, at 3:00 p.m.

6 Discussion 7 A. Standard to obtain temporary restraining order without notice 8 The FTC moves for a temporary restraining order without notice under the second 9 proviso of 15 U.S.C. § 53(b) and Rule 65(b) of the Federal Rules of Civil Procedure.3 The 10 second proviso of § 53(b) “allows the FTC to seek injunctive relief without initiating 11 administrative action and states: ‘Provided further, That in proper cases the Commission may 12 seek, and after proper proof, the court may issue, a permanent injunction.’”4 The Ninth Circuit 13 has interpreted this language as authorizing a district court “to grant whatever preliminary 14 injunctions are justified by the usual equitable standards and are sought in accordance with

15 [FRCP] 65(a).”5 Section 53(b) relaxes the FTC’s burden when seeking an injunction or a 16 restraining order by eliminating the irreparable harm requirement, but it demands that notice be 17 given to the defendant before a court can grant either form of relief.6 Thus, § 53(b) does not 18 support the FTC’s request for a temporary restraining order without notice. 19

20 3 Id. at 42–43 & n.14 (15 U.S.C. § 53(b)), 55–56 (Rule 65(b)). 4 F.T.C. v. Consumer Defense, LLC, 926 F.3d 1208, 1212 (9th Cir. 2019) (quoting 15 U.S.C. § 21 53(b)). 5 Id. (quoting F.T.C. v. Singer, Inc., 668 F.2d 1107, 1111 (9th Cir. 1982)). 22 6 15 U.S.C. § 53(b) (“Upon a proper showing that, weighing the equities and considering the 23 Commission’s likelihood of ultimate success, such action would be in the public interest, and after notice to the defendant, a temporary restraining order or a preliminary injunction may be granted without bond . . . .”). The Ninth Circuit recently confirmed that its “precedent 1 Rule 65 does authorize a district court to “issue a temporary restraining order without 2 written or oral notice to the adverse party or its attorney[,]” but only if two conditions are met.7 3 First, specific facts that “clearly show that immediate and irreparable, loss, or damage will result 4 to the movant before the adverse party can be heard in opposition” must be established by 5 affidavit or verified complaint.8 Second, “the movant’s attorney” must certify “in writing any

6 efforts made to give notice and the reasons why it should not be required.”9 7 The FTC has not provided any authority to show that it can cobble a hybrid standard from 8 § 53(b) and Rule 65(b) that allows the court to grant an ex parte restraining order without the 9 FTC showing that immediate and irreparable harm will result without that relief. So, the FTC 10 can either give notice to the defendants and proceed with its motion for a restraining order under 11 § 53(b) or it can meet Rule 65’s demanding burdens for a restraining order without notice. 12 Because the FTC seeks secrecy until it obtains and serves a restraining order on the defendants10 13 and has provided the court with thousands of pages of evidence, I construe its motion as seeking 14 the latter and proceed to determine if the FTC has met the standard for that relief.

15 1. Imminent irreparable harm 16 The Supreme Court has instructed that ex parte “temporary restraining orders are no 17 doubt necessary in certain circumstances, but under federal law they should be restricted to 18 19 eliminating the requirement of a showing of irreparable harm in cases of statutory enforcement, 20 where an injunction is authorized by the applicable statute,” which “pre-dates the Supreme Court’s” decision in Winter v. Natural Resources Defense Council, Inc., 555 U.S. 76 (2008), 21 “remains intact.” Consumer Defense, LLC, 926 F.3d at 1213–14. 7 Fed. R. Civ. P. 65(b)(1). 22 8 Id. at 65(b)(1)(A). 23 9 Id. at 65(b)(1)(B). 10 See ECF No. 2 (motion to seal). 1 serving their underlying purpose of preserving the status quo and preventing irreparable harm 2 just so long as is necessary to hold a hearing, and no longer.”11 “In cases where notice could 3 have been given to the adverse party, courts have recognized ‘a very narrow band of cases in 4 which ex parte orders are proper because notice to the defendant would render fruitless the 5 further prosecution of the action.’”12 To meet this standard, the plaintiff “‘must show that

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Federal Trade Commission v. Lead Express, Inc., (D. Nev. 2020).

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