United States of America v. Metro Data Management, Inc. et al
Filing
51
FINAL JUDGMENT: The clerk of the court shall close this case. Ordered by Judge Sandra J. Feuerstein on 5/5/2016. (Florio, Lisa)
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA,
Plaintiff,
-against-
STIPULATED CONSENT
DECREE AND FINAL
JUDGMENT
Civil Action No. 14-6791 (SJF)(GRB)
METRO DATA MANAGEMENT, INC.
d/b/a DATA MARKETING GROUP, LTD.,
KEITHA ROCCO, individually and as an
Officer of Metro Data Management, Inc.,
9097 9394 QUEBEC INC. d/b/a INFOGEST
DIRECT MARKETING, MARY THANOS,
DANIEL SOUSSE, PHILIP LETT,
DESTINY RESEARCH CENTER, LTD.,
MARTIN DETTLING, MARIA DUVAL,
and PATRICK GUERIN.
FILED
IN CLf:Rl'';:- OFFICE
U S DISTRIC"f COUfn E 0 N y
*
t\1\'(
05 Z016
*
LONG ISLAND OFFICE
Defendants.
WHEREAS, the United States commenced this action against Defendant 9097 9394
Quebec Inc. d/b/a Infogest Direct Marketing ("Infogest") by filing a Complaint in this Court,
and added additional defendants Mary Thanos, Daniel Sousse, Philip Lett, Martin Dettling,
Destiny Research Center, Ltd. ("DRC"), Maria Duval and Patrick Guerin (collectively
sometimes hereinafter the "defendants") by filing an Amended Complaint in this Court, a copy
of which is attached hereto as Exhibit A; and
WHEREAS, the Amended Complaint states a claim for relief under the Fraud Injunction
Statute, 18 U.S. C. § 1345; and
United States v. Metro Data Management, Inc., eta/., 14-CV-6791 (SJF)(GRB)
Stipulated Consent Decree and Final Judgment
WHEREAS, on November 19,2014, having considered the ex parte application of the
United States, the Court issued a temporary restraining order as to, inter alia, Defendant
lnfogest; and
WHEREAS, the United States and Defendants Infogest, Thanos, Sousse, Lett, Dettling,
DRC, Duval and Guerin wish to settle this action upon the following terms without further
litigation;
WHEREAS, the parties hereby agree to fully and finally settle this matter without any
admissions of liability or wrongdoing on the part of Defendants Infogest, Thanos, Sousse, Lett,
Dettling, DRC, Duval and Guerin;
WHEREAS, neither this Stipulated Consent Decree and Final Judgment, nor the fact that
defendants have agreed to a permanent injunction, shall constitute an admission of liability, be
admitted into evidence or otherwise used against them in any other matter, save for a matter to
enforce this Stipulated Consent Decree and Final Judgment;
WHEREAS, the defendants are not citizens or residents of the United States but wish to
finally resolve the matters alleged in the Amended Complaint without further litigation and
therefore agree that this Court may enter and enforce this Stipulated Consent Decree and Final
Judgment against them in the United States, but specifically do not submit to this Court's
jurisdiction (or the jurisdiction of any court in the United States) for any other purpose by
entering into this Stipulated Consent Decree and Final Judgment.
NOW THEREFORE, it is hereby ORDERED, ADJUDGED and DECREED that:
Pursuant to 18 U.S.C. § 1345 and the inherent power of this Court:
1.
i.
Defendants Infogest, Thanos, Sousse, Lett, Dettling, DRC, Duval and Guerin,
their agents, officers, employees, and successors, and all other persons and
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United States v. Metro Data Management, Inc., eta/., 14-CV-6791 (SJF)(GRB)
Stipulated Consent Decree and Final Judgment
entities in active concert or participation with them are jointly and severally
permanently enjoined from committing mail fraud, as defined by 18 U.S.C.
§ 1341;
ii.
Defendants Infogest, Thanos, Sousse, Lett, Dettling, DRC, Duval and Guerin,
their agents, officers, employees, and successors, and all other persons and
entities in active concert or participation with them are jointly and severally
permanently enjoined from using the United States mails or causing others to
use the United States mails to distribute:
1.
any advertisements, solicitations, or promotional materials on behalf of
DRC, Maria Duval, Patrick Guerin or any other actual or fictional
individual or entity purporting to offer psychic, clairvoyant or
astrological items or services for a fee;
2.
any advertisements, solicitations, or promotional materials that falsely
represent, directly or indirectly, expressly or impliedly, that the
recipient of the mailing was specifically selected to receive the mailing
based on a reason other than the fact that the recipient's name appears
on a mailing list;
3.
any advertisements, solicitations, or promotional materials that
represent, directly or indirectly, expressly or impliedly, that services or
items offered for purchase will:
(a) increase the recipient's odds and/or probability of winning a lottery
or other game of chance;
(b) bring the recipient luck or good fortune; or
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United States v. Metro Data Management, Inc., eta/., 14-CV-6791 (SJF)(GRB)
Stipulated Consent Decree and Final Judgment
(c) entitle the recipient to receive an inheritance or other payment
from a party other than the seller of the goods and services; or
4.
any other false and misleading advertisements, solicitations, or
promotional materials;
iii.
Defendants Infogest, Thanos, Sousse, Lett, Dettling, DRC, Duval and Guerin,
their agents, officers, employees, and successors, and all other persons and
entities in active concert or participation with them are jointly and severally
permanently enjoined from taking any action to receive or causing to be
delivered any incoming mail, at any address anywhere in the United States,
which is responsive to any advertisements, solicitations, or promotional
materials on behalf ofDRC, Maria Duval, Patrick Guerin or any other actual
or fictional individual or entity purporting to offer psychic, clairvoyant or
astrological items or services for a fee.
iv.
Defendants Infogest, Thanos, Sousse, Lett, Dettling, DRC, Duval and Guerin,
their agents, officers, employees, and successors, and all other persons and
entities in active concert or participation with them are jointly and severally
permanently enjoined from using, possessing, having control over, or
forwarding mail from or to any address, Post Office Box, or Commercial Mail
Receiving Agency (CMRA) Box, which has been used by the Defendants or
their agents to receive any incoming mail which is responsive to any
advertisements, solicitations, payments, or promotional materials sent in the
United States on behalf of any actual, or fictional htdividual or entity
purporting to offer psychic, clairvoyant, or astrological items or services for a
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United States v. Metro Data Management, Inc., eta/., 14-CV-6791 (SJF)(GRB)
Stipulated Consent Decree and Final Judgment
fee, to include but not limited to:
I. 1285 Baring Boulevard, #411, Sparks, NV, 89434
2. 1285 Baring Boulevard, #409, Sparks, NV 89434
3. 201 West Lake Street, #555, Chicago, IL 60606;
v.
Defendants Infogest, Thanos, Sousse, Lett, Dettling, DRC, Duval and Guerin,
their agents, officers, employees, and successors, and all other persons and
entities in active concert or participation with them are jointly and severally
permanently enjoined from selling, offering for sale, licensing, renting,
disclosing or utilizing for any purpose other than the defense of any legal
action any lists of consumers or mailing lists of any type that have been
compiled from consumers in the United States who have responded to
solicitations bearing the names Destiny Research Center, Maria Duval, or
Patrick Guerin, except that defendants may disclose such lists to their legal
counsel as necessary for the defense of any other (a) pending legal actions in
which a Defendant has been named as a party, or (b) pending criminal
investigations where a Defendant has been identified by law enforcement as a
target of the investigation;
vi.
Within 30 days of the date of entry of this Stipulated Consent Decree and
Final Order, Defendants Infogest, Thanos, Sousse, Lett, Dettling, DRC, Duval
and Guerin, their agents, officers, employees, and successors, and all other
persons and entities in active concert or participation with them are ordered to
dispose of any lists of consumers or mailing lists of any type that are currently
in their possession or control, compiled from consumers in the United States
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United States v. Metro Data Management, Inc., eta/., 14-CV-6791 (SJF)(GRB)
Stipulated Consent Decree and Final Judgment
who have responded to solicitations bearing the names Destiny Research
Center, Maria Duval, or Patrick Guerin or order any custodian who has
possession of any such lists to dispose of them, unless retention by
defendant's legal counsel of such lists is necessary for the defense of any
other (a) pending legal actions in which a Defendant has been named as a
party, or (b) pending criminal investigations where a Defendant has been
identified by law enforcement as a target of the investigation. Disposal shall
be by means that protect against unauthorized access to the customer
information, such as by burning or shredding any papers, and by erasing or
destroying any electronic media, to ensure that the customer information
cannot practicably be read or reconstructed. With respect to any lists that are
personally disposed of by Defendants Infogest, Thanos, Sousse, Lett, Dettling,
DRC, Duval and Guerin, these Defendants shall, after completing any
disposal, provide to Plaintiff a certification, sworn under penalty of perjury,
detailing what materials were identified for disposal and in what manner
disposal was accomplished, and certifying that Defendants no longer have in
their possession any such lists. Any Defendants who do not have in their
possession or control any such lists shall provide to Plaintiff a certification
that they do not possess any such lists, sworn under penalty ofpeJjury. Any
Defendants who retain such lists for purposes of the defense of any other
pending legal actions shall provide to Plaintiff a certification, sworn under
penalty of peJjury, stating that such lists are retained and the format in which
such lists are retained. With respect to any lists that are in the custody of a
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United States v. Metro Data Management, Inc., eta/., 14-CV-6791 (SJF)(GRB)
Stipulated Consent Decree and Final Judgment
third party, Defendants Infogest and DRC shall provide Plaintiffs with
certifications, sworn under penalty of perjury:
I. listing the names and addresses of all third party custodians in
possession of such lists;
2. listing the individuals at the third party custodians that defendants
contacted to direct the third party custodians to dispose of such lists;
3. listing the individual who contacted the third party custodians on
behalf of defendants, and the dates, time and manner by which
defendants directed the third party custodians to dispose of such list;
4. listing the individuals at the third party custodians that responded to
confirm that disposal was accomplished;
5. listing the date, time and manner in which the individual responded to
confirm that disposal was accomplished; and
6. identifying any third party custodian that did not confirm that disposal
was accomplished;
vii.
Defendants Infogest, Thanos, Sousse, Lett, Dettling, DRC, Duval and Guerin,
their agents, officers, employees, and successors, and all other persons and
entities in active concert or participation with them are jointly and severally
permanently enjoined from performing "caging services" including processing
direct mail payments and orders, with regard to direct mail solicitations sent
through United States mail on behalf of Destiny Research Center, Maria
Duval, Patrick Guerin or any other actual or fictional individual or entity
purporting to offer psychic, clairvoyant or astrological items or services for a
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United States v. Metro Data Management, Inc., eta/., 14-CV-6791 (SJF)(GRB)
Stipulated Consent Decree and Final Judgment
fee;
viii.
The United States Postal Inspection Service is authorized to open any and all
United States Mail detained by the United States Postal Inspection Service
pursuant to the Temporary Restraining Order in this matter. The United
States Postal Inspection Service shall return any currency, bearer instruments
(including but not limited to money orders and travelers checks), and any
personal effects that can be positively identified with its sender. This return
shall include a letter notifying the sender of the disposition of this matter,
attached here as Exhibit B. The United States Postal Inspection Service is
authorized to destroy any and all remaining detained mail (including but not
limited to envelopes, order forms, correspondence, personal checks, and
payment card information (PCI)).
ix.
Within seven (7) days after the entry of this Stipulated Consent Decree and
Final Judgment, Defendants are ordered to submit to the United States an
acknowledgment of receipt of this Consent Decree and Final Judgment sworn
under penalty of perjury;
2.
This Stipulated Consent Decree and Final Judgment shall not be modified except
in writing by the Parties and approved by the Court.
3.
This Stipulated Consent Decree and Final Judgment shall be governed by the laws
of the United States.
4.
The Parties agree to bear their own costs and attorneys' fees in this action.
5.
The temporary restraining order entered on November 19, 2014, is superseded by
this Stipulated Consent Decree and Final Judgment and is hereby vacated and
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United States v. Metro Data Management, Inc., eta/., 14-CV-6791 (SJF)(GRB)
Stipulated Consent Decree and Final Judgment
dissolved.
6.
Within fourteen (14) days after the entry of this Stipulated Consent Decree and
Final Judgment, the United States shail cause the Chief Postal Inspector for the
United States Postal Service to seek and obtain an order in the administrative
action In re Destiny Research Center, Ltd. and Martin Dettling and Maria Duval
(filed on or about November 14, 2014), dismissing the administrative Complaint
with prejudice, vacating the Orders and Cease and Desist Order attached to the
administrative Complaint, and vacating any other orders or judgments issued in
that proceeding.
7.
This Stipulated Consent Decree and Final Judgment contains the entire agreement
between the Parties with respect to the subject matter herein. The Parties
acknowledge that there are no understandings relating to the settlement other than
those expressly contained in this Stipulated Consent Decree and Final Judgment.
8.
The undersigned signatories each represent that he, she or it is fully authorized to
enter into the terms and conditions of this Stipulated Consent Decree and Final
Judgment and to execute and legally bind to this document the Party which he,
she or it represents.
9.
Defendants hereby agree to waive, release, and remit any and all claims, either
directly or indirectly against the United States and its agencies, employees,
representatives and agents, including but not limited to the Department of Justice,
the United States Postal Inspection Service, and their employees, with respect to
this action.
10.
This Stipulated Consent Decree and Final Judgment may be executed in
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United States v. Metro Data Management, Inc., eta/., 14-CV-6791 (SJF)(GRB)
Stipulated Consent Decree and Final Judgment
counterparts, each of which constitutes an original and all of which constitute one
and the same Stipulated Consent Decree and Final Judgment. Signatures
delivered by facsimile transmission, or as .pdf attachments to emails, shall
constitute acceptable, binding signatures for purposes of this Stipulated Consent
Decree and Final Judgment.
II.
This Stipulated Consent Decree and Final Judgment shall constitute a final
judgment and order in this action, United States v. Metro Data Management, Inc.,
et al., Civil Action No. 14-6791 (SJFXGRB), as to Defendants Infogest, Thanos,
Sousse, Lett, Dettling, DRC, Duval and Guerin.
jurisdiction over the enforcement and inte r
ts Stipulated Consent
o resolve all disputes arising hereunder as may
""""""'"""!'~t.
The C\cr~ o{ -lne C.O\.lrt 6t\Ql\ c..\ose... -1t1 1 ~ c..O..~c.,...
SO ORDERED this S tb day of H Oj
,2016.
A
s/ Sandra J. Feuerstein
m~NORABLE~ANDRA J. FEUERSTEIN
UNITED STATES DISTRICT JUDGE
Page 10 of15
UrritedStatu •.loktroDotaMau:;g111oon1, Inc., otal., 14-CV-6791 (SJF)(GRB)
SlipuJa1ed c..- Docne ond finaiJudplent
IT IS HEREBY AGREED:
TBii UNWjD SlATES OF AMERICA
Dated: Brooklyn, New York
Fplna; _, 2016
Apr;/ 13
ROBERT L. CAPERS
United States Attorney
Eutem DistrictofNew York
By:
et--~+=:?
agelatos
Assistant United States Attorney
Tel. (718) 254:-6182
Dated: Washington, DC
Febi-;_,2016
BENJAMIN C. MIZER
Principal Deputy Assistant Attorney General
Civil Division
United States Department of Justice
Afn\ ''
JONATHAN F. OLIN
•
Deputy AssisJant Attorney General
MICHAELS. BLUME
DiRc:tor
Consumer Protection Branch
By:
tiM!-
Ann F. Entwistle
Trial Attorney
U.S. Department of Justice
Tel. (202) 305-3630
Page 11 of15
Unird States v. Metro /JaJa Managemenl, Inc., et aJ., 14-CV-6791 (SJFXGRB)
Stipulated Consent Decree and Final Judgment
THEINFOGESTDEFENDANTS
MANATT, PHELPS & PHILLIPS, LLP
Counsel for Defendants
9097 9394 Quebec Inc. d/b/a
Infogest Direct Marketing, Mary Thanos,
Daniel Sousse and Philip Lett
Dated: New York, New York
FebiUIIf'Y _, 2016
f\tAJ... "'1
By:
L~~~
Arunabha Bhoumik
Members
Tel. (212) 790-4500
9097 9394 QuEBEC INC.
DIB/A INFOGEST DIRECT MARKETING
Dated: Quebec, Canada
February__, 2016
By:
Axel Wend
President
Dated: Quebec, Canada
February __, 20 16
MARY THANOS
Mary Thanos
Dated: Quebec, Canada
February_, 2016
DANIEL SOUSSE
Daniel Sousse
Dated: Quebec, Canada
February__, 2016
PHILIP LETT
Philip Lett
Page 12 oflS
United S/olu v. Mara Dola MfJIIt/gU/1114 Ina., II a!, 14-CV-6791 (SJF)(ORB)
Stipulated Consent Decree and Final Judpnt
TUEINFQGESJDEfENDANTS
Dated: New York, New York
February_, 2016
MANATT, PHELPS&: PmLLIPS, LLP
Counsel for Defendants
9097 9394 Quebec Inc. dlb/a
Infogest Direct Marketing, Mary Thanos,
Daniel Sousse and Philip Lett
By:
Linda Goldstein
Arunabha Bhoumik
Members
Tel. (212) 790-4500
9697 9394 QUEBEC INC.
Dated: Quebec, Canada
February_, 2016
DIB/A INFOGEST DIRECT MARKETING
By:
Axel Wend
President
Dated: Quebec, Canada
MARY THANOS
February_, 2016
Mary Thanos
Dated: Quebec, Canada
DANIEL SOUSSE
February_, 2016
Daniel Sousse
Dated: Quebec, Canada
February_, 2016
PmLIPLETT
Philip Lett
Page 11 of15
UrriiMI Stat., v. Me/l"o Data Altmagemen4 Inc., et a/., 14-CV-6791 (SJF)(GRB)
Stipulated Consent Decree and Final Judgment
THE INFQGEST DEfENDANTS
MANATI', PHELPS & PHILLIPS, LLP
Counsel for Defendants
9097 9394 Quebec Inc. d/b/a
Infogest Direct Marketing, Mary Thanos,
Daniel Sousse and Philip Lett
Dated: New York. New York
February__, 2016
By:
Linda Goldstein
Arunabba Bhoum.ik
Members
Tel. (212) 790-4500
9097 ~QuEBEC INC.
DIB/A INFOGEST DIRECI' MARKETING
Datc4: Quebec, Canada
February_, 2016
By:
Axel Wend
President
Dated: Quebec, Canada
February~ 2016
Dated: Quebec, Canada
February_, 2016
MARY THANOS
~
DANIEL SOUSSE
Daniel Sousse
Dated: Quebec, Canada
February__, 2016
PHILIPLETI
PhiUpLett
Page ll oflS
UnimdStatuv. MIITODGIGM-w.n4 btc., otaL, 14-CV-6791 (SJF)(ORB)
S1ipullled eo-t Decree and Final Judgment
THE INFOGEST PEf1iNPANTS
Dated: New York, New York
MANAIT, PHELPS & PlfiLLIPS, LLP
Counsel for Defendants
9097 9394 Quebec Inc. d/bla
February__, 2016
Infogest Direct Marketing. Mary Thanos,
Daniel Sousse and Philip Lett
By:
Linda GoldS!Ciin
Arunabba Bhoumik
Mombers
Tel. (212) 790-4500
!10!17 !13!14 QuEBEC INC.
Dated: Quebec, Canada
February__, 2016
D/B/A INII'OGEST DIRECT MARKETING
By:
Axel Wend
President
Dated: Quebec, Canada
MARY THANOS
February__, 2016
Mary Thanos
Dated: Quebec, Canada
February jj 2016
DANIEL SOUSSE
lJ~·J Jr., J fz_.
Daniel Sousse
Dated: Quebec, Canada
February~
PHILIP LETT
2016
Philip Lett
Page 1l of l!i
Uni~d Slata
v. Metro Data Malffl6""1nt, Inc., eta/., 14-CV-t
15
---""..J
Unl,dStatesv. Metro Data Management, Inc., etaL, 14-CV-6791 (SJFXGRB)
Stipulated Consent Decree and Final Judgment
PATRICK GUERIN
Dated:1 S/'t !2o14 France
PATRICK GUERIN
February --' 20 16
I,
i\\ale..Rk (k,NAJA
Dear ,
I have now received your "CONFIRMATION FORM" giving your
consent to receive Absolute Power, in the form of the WORDS OF
POWER, along with your payment.
I'd like to congratulate you on your fast response to my
previous letter, and for accepting my offer to join the elite
circle of initiates. This is the sort of opportunity not
everyone gets.
It's a Secret that really can bring you everything your heart
desires. There's no limit to the ways it can help you (money,
problems,
difficult
luck,
love,
winnings,
solving
family
situations, etc.).
The Words of Power are a magnificent privilege, but they also
carry a responsibility. You can of course use them as you wish,
and as often as you wish, but always to do good.
In all sincerity though, I don't doubt you, ,
because I know you're a worthy person. That's why I decided to
send you this incredibly powerful Secret.
I'm absolutely delighted to put this precious Secret in your
hands- the WORDS OF POWER, contained in a very special book.
I recommend you read it very carefully, because it's
important to really absorb the full force of the Words of
Power.
Exhibit B
I'm also giving you some practical tips, so you can make the
best use of them, and achieve whatever it is you most want, in
all areas of your personal, social and professional life.
Consider this book a friend who will remain by your side, so
your life will be forever beautiful and rich!
As promised I will reveal
Table for Activating Numbers
the exact dates and times so
winning a fortune and making
below your mysterious gift - «the
with Great Luck Potential» with
you can boost your chances of
a success of your life.
I would advise you to note down these dates and numbers.
I've calculated them specifically for you for the coming
months. These are the intensely lucky, perhaps 'magical' dates
on which the astral forces charged with luck, money, love and
success will be finely attuned with your personal
sensibilities.
Table for Activating Numbers
with Great Luck Potential
Day
AUitUSt 3"' 2011
Aueust 25"' 2011
September 1'1 2011
September 7"' 2011
October 15"' 2011
October 27"' 2011
November 3"' 2011
November 17"' 2011
December 1'1 2011
December 21" 2011
Januarv 3"' 2012
Januarv 12"' 2012
Time
14.00
09.00
16.00
20.00
10.00
11.00
18.00
09.00
13.00
13.00
18.00
20.00
Special numbers
with !(Teat luck votential
1-56-45-46-32-20
42-15-20-12-35-8
25-47-2-25-41-39
Etc.
On these special days you might want to buy a lottery ticket,
schedule meetings and plan all sorts of important jobs, as
well, of course, as using these numbers WITH the corresponding
Words of Power. Your intuition will tell you the best way to do
this.
If you do this you'll boost the strength of the Words of
Power and I can assure you that the results will amaze you.
Exhibit B
You'll finally be able to get everything you've wanted and
dreamed of for so long!
A veritable "avalanche" of happy events will flood into your
life, as the luck that has been "blocked" for many long years
is finally released...
All that remains now is to initiate you into this magnificent
secret, so you can use it and finally take the step across the
threshold into a fulfilling and successful life.
You can be sure I'll be using all my skill as an established
clairvoyant and my occult gift to help you along.
I hope, from the bottom of my heart, that you find happiness
and prosperity with these incredible Words of Power ...
Firstname, from today onwards, a new life is starting
for you! And I 'm so happy for you I
Your true friend,
Maria Duval
Exhibit B
EXHIBIT C
So,
now g internationally
acclaimed peych1cs have p:red1cted
what your future holds in store for you. ..
it's fantastic news, -
'1'114
Pl
,ol•l•l"llllllll'lddl• 11•1!oll•l•llu•ll•llu
1
-
take note of these 4 things
that are very .important for you:
MARIA DuvAL
October 16, 2013,
Powerbell,
Winnings,
Problems solved
ol-TV--Montllu•:r-n
September 19, 2013
-pndledo..
Mantllult,GIII
radloPI<+--
leataredlao-700
utw £lM~ardcla
lbo-WiodiO
...............
.......!hkaiiJ .......
(more tlwl20 Ill date)
Ability 10 Jlftlllet llle
I'DIIInamlhuadla
..-....,die
:But first, let me explain how this all startEd.
--.odeallllc
aatborilleo
It all began with a strange telephone calL ••
At that moment, I happened to be working on some
It'.4-.
~ c.,j..c.'ndi; u •••
~
Destiny Research Center
?&... ~-..~
LCEU 019103
xhibit C
L
important fi1ee, and 8JIIOllg them YOUR FILE, because
new and unexpected e1emen'tl3 had just oome to light.
some totally
This new information was incredibly exciting because, as
ya11're soan goil'lg to see, it calls for sWeeping cJlangeB and
i.JIIp1:UVe.nentB in your life. But then, the telephone rang...
I wouldn't normally take a telel:lhoJle call while I'm doil'lg
this kind of met1culouiJ work since lt can be ~ ~
and I need to stay totally concentrated. But thiS t1me I had a
~feeling that this call was different. More importantly,
I had a feeling that it was~ linked to the work I was
doing for you. :And I wasn't _ .
When I picked up the ha.r1daet. I ~1!red the warm. gentle
voice of my friend, the renowned ~ Patrick Guerin.
This seer has a worldwide reputation. He also has the rare
and special power to make people ~ win and ~AIN at the
lutlm~ and other~ of "chance , ~~
y '18i'ge
of money {eee the extra informa
that I have
enclosed especla11y for you)!
amoun
He ~= replied that he had w;l;ij!Jnel,y J.mpurt.wlt
and canf
information to give tliiSe peopl:eiiiCI that
he oouldn't tell me any more aver the pllon& He also told
me he Deed¢ my help!
He and I ~ that we al:a>lutel.y had to meet to discuss
this in person. We agreed to meet early the next day...
I CtNUT YOU AND YOUR F!JTtJRF!
Once he was sitting down in my office, Patrick Guerin told
Exhibit C
me he had experienced incredible visions of ~ clarity,
the likes of which he had rarely ever experienced.
In his v1s1ons. there were some ~le he didn't· know
was able make out some 'tJ1!ll8S about them. one of
the
he knew far sure was that I was in contact with you
quite o
in the last few weeks.
al~!
Patrick Guerin could see that this specific ~P of
some eer:i.ous problems, particUlarly in
the- area of money. Their lives weren't how they wanted it
to be and they of'ten felt desperately alone, BEiek:1ng a way .
out of their current Bituat:l.on.
people were plagued by
At this point,
and among them, he saw
internatfrmal renown KNOWS
saw he could help these people
Yes, this great PsYchic of
help theSi:l peop"li really win
erf~cfu{ ~~of "chance" that cou1d make
solutions to the
'tattling!
woes! ~t%C ~ ~tly
~
"I know I can ees11y change their lives, Maria!" he told me.
But the ~ part of the stpry is that in his vision,
this great psychiC and seer wasn't a1orie in dvj,ng his help to
these few ~ specific pecmle becauae I. Marla DuVal, was
pravi.dil'lg them with valuable, vital help as well!
rk.~4tvt~~..d.~-··
I saw the same thing far you!
of shock.
nxmey, the
When Patrick Guerin had finished, I ~ state
'BAsicaJJy1_ rd seen the same thing far you, cha.ngeB, "Cne new life...
·
The
Money. Mg ch.anges and a new life. •.
There's no doubt at all. •
that J!2Y are anx:mg this
small group of people about
Patrick Guerin and I had such
c:Jear Visions. Too man;y very apec1fic pieoes of information that
he gave to me are ao CJ.eariy llnked to you that it simply
cannot be a coincidence.
Do you remem
. .earlier when I told ~ that just
befare I .e:ot that
call I was alao work1ng on your
file? Well it was
LY_ ~uae I had seen th.eee changes in
you;- future that had picked up yt?Ur file and was gettfilg
i'eady to write to you! You can imagine my amazement.
·
Yes-- I too have seen~ win an initial large sum of
nxmey Cur"'!''m'.lottery, and rve 8.1ao seen that all your
f?~~ ~z£:4 ~ CIP~C«~.. Ce
~~/~~···
019103
Exhibit C
III08t ~t problems are going 1xJ find a haPP.Y and positive
so1utiori!
•
That could never happen!
So, now you're going to bettet• understand why what Patrick
Guerin told me came as such a shock! Surely, you can no ~
doubt that ~ life reap.y is ll:Ci.ru!: to ~ and nnney and
happiness are finally going to 'De 1:iY your siDe!
w~'t'lr=,~c.= ~~ ~oefit
When Patrick Guerin had finished ~ me what he'd seen in
future I had not a shadow of doubt tha't :YO\! were a part of
his visions. I then exp1ained what I had seen. .. allll08t the same
things! He wasn't surprised because, as I mentioned, in his vision
he'd seen that I was going 1xJ he1p.
your
We both wanted to be abeol.utel~:le'r
l;ain there was
no mistake and that we were both
t the same
individuals, inol.'Udi.rlsl: you in this case,
So, we showed each
ather our notes whicli I attached at the
bf this letter. And
as. you can see, it REALLY fits! The message is perfectl.y ol.ear for
both of us!
Y~ ~ ,,.;., ~ ~' ~
.(Wt.Pt''/' NPd -1144 4div- ~ ~~.,;.,
Patrick Guerin knows a ~ part of the he1p you're going to
need 1xJ win this money and mrt out all yt)!11" III08t urgent money
prob1enl3 while I knoW the ather parte. In fact, 'betweeil us, we
have the so1ution to all your moot urgent problems!
· That's whv ~ 'Wf!!ve decided to join forces and poo1 our
knowledge to~
rr~~
,~-..._~;
I
From our respective visions, it was~ cl.ear that
for_ you to receive this first ]l:lg win and to sort out ~
problemS, Patrick Guerin and I must work ~ and poo1
our knowledge and skill. And that's just w
done.
We l.ocked oursel.ves in for_ 3 -~ys and wcrked tqgether
around the c1ock to perfect a br1lllant, unique and very
r--
Exhibit C
dynamic and peraxuali?Pd help plan that comes in 2 part&
But firBt, ~must unc:lerstand 1111 that with this help you
are definitely going to be able to~ very quickly to this
first i.Jnportabt sum of money and see an your mOst urgent
probl.erne disappear!
Action 1: Your invaluable GUIDE to your NEW LIFE
We've written down ~(fve seen for you in one
unique, invaluable but ~
tforward doctiinent. I f
you reed this guide, Y!'U're ~
have all the tips and
information you need to eeiiJe tne opportunities that come
your way, at exactly the right moment.
Pbr example, Y!'U're go.1,ng to lmow what day and what
nwnbers you need to p~ win ~ and ae.'ain (all you're
going to need to do is
off
numbei'Swtdnilicate to
you on your lutbel=tickets). You're going to lmow exactly what
you need to do to
~life, 00rt out~ p:robleme and
~more thine:s
It's all clearly expla1neC1 in a
~tforwarcf manner, simply follow tne instructions that
PatrUlk Guerin and I are goillg to give you.
Action 2: our EFPID.l'lvE aid and supwrt!
With this Guide and the support and psychic assistance I
talked about above,~ are~ to receive from life
all that you are Owed and eii
expect... in other
words, rooney and the aolution of your current probleme.
Patrick Guerin and I have seen it: With our ~ ~
and ha'PPineea~ ~ to ~ into your life! It's Written in
your tiiture.
_you ve to
tO ~ ~ life change is
grasp the hand of f:riendship we are holC11rlg out to you. The
rest, absolutely evervtll1rut else, is up to tliat great psyohic
Patrick Guerin and riiyself, Maria Duval.
I.et us use the power of our vibrations and luck and
money is going to flow into your life, as surely as they
seem to be aVOiding you now.
Most imp:n tantly of all, you must accept these changes
as they hapPen to you, because an opportuni:tv that jOU ignore
is an opportunity that usually NEVER SHOWS fJp AGAIN!
=
:For all this happineea to~ life, for ~
make
t1fCt br:lm with ~on your e... it canJiSt,CIW;for
~iqys
tO f1ri8.lly
All you need do is flll out and return, as aoon as possible.
M.u. ~ ~~· Pk• ~ ~ ....
019103
Exhibit C
~al
the
.Aesistanoe Form on the last page of this letter.
More irnport!mtly, do it mnt away because, i f I may remind
we saw that the first Ptidtive event is set to happen in your
( life in just a few days' time! So, act now.
you,
GOO]) NEwS/
We are offering a part of our help
for
free!
You may perhaps be th.1.rlk!ng that assistance as special as we
are offer:l.ri£ you today could be ~ expensive. There are, after
all, going to lJe two very :renowned Psych1.cs act:lJ'lg on your behalf
and world.J'lg very hard for :you.
:But as ~ know, we are nat motivated ~ DJO!ll!Y_. What we want,
more than anvthirll;t. is ygur happi.pllffl' That would be the beet
reward we oaUl.d a8K for.
That's why Wf!ve decided, together, to offer you the first
1JBrt of our lisB:lstanoe
~'11 have to pay for
le the ~tion and
ani:m:U.ng: fees of sending
your Invaluable Guide for a New Life to yOU.
t}fiseta!P"
:But that's nat all! For us to be sure you're not ~
even the sl.iroltest risk, we are also offerlllg ~ a .run and
JmC!md1tl.ol'la1. money-back guarantee. This means thatlilthe
~.Y ~ event that ever:vthinsl: we've predicted for you
doesn't ha~ need only~ lef us Know and you're go1IIg ~to
receive an
te and .fUll refUnd. So, you are not~~
any risk at all by pl.ac1ng your faith in us and asking for
our help.
It's now time to fill out and mail off your ~aJ
.Aesistanoe Form wi~. Patrick Guerin and I know life
is ti.Oinl£ to give you ever;thing you've ever wanted. Hanni""
is ~ way to you.
&.vrrlwt and
sincere friend,
..:;;{.~~~~
Maria Duval
PS: In celebration of your NEW LIPE, we've ~ a
ll1VS'Ilerious and extraordinilrv rlft for you - a 'POWel.'fu1 Talisman
tliat can attract MONEY and "'Lt:rCK. It's the same TaUsman that
Patrick Guerin car:aes with 1iiiilall the time. He's never shared
it before, but in yo1,U' case he had no hesitation. The meet
poweri'ul and ancfi!nt Talisman we have ever known is now YOURS!
Exhibit C
7
~ ~ '..,. ;/(,.~
p~ 6;~ ~ ·dul~ ~
My
r•#
$1.
~~
dear-·
We.have never met yet I know so many things about you!
Yes, I had very clear visions and I know your life is going to change
very soon, but only if you make the right decisions today.
I know the life you• re leading right now is not all you hoped for_.
I know you're currently immersed in serious problems that are casting a
shadow over your existence-. I also know you need URGENT help sorting out
your money problems so that you can have a decent standard of living_ And,
finally, I know you deserve MUCH MORE out of life than you're currently ·
getting.
I've seen you winning an initial, very large, sum of money_ I've
seen all your most urgent problems find a solution, one after the other_
I've seen a new life taking shape·on your horizon, more wonderful and
fulfilling that you could ever imagine._ I've seen joy and happiness light
up your face_ I've seen a person full of energy, getting the absolute most
out of life -And that person is you
lllllt
I can say this and confirm it: Your life really is going to change,
in ways more significant than you can imagine, and I'm not the pnly
psychic to have seen it! I can't emphasize enough the fact that all
the good things I saw heading your way. Maria Duval saw them too! I
have never heard of this happening in the history of clairvoyance! So,
this is irrefutable proof that your life really is going to change
over the coming weeks!
Just imagine-. For all this amazing happiness, and all this joy we
have seen coming into your life, the only thing you have to do is agree
to accept the help Maria Duval and I are offering you by simply returning
the enclosed Special Assistance Form today. If I could do it for you I
would, but unfortunately I can't do that. You and you alone can do this.
I am telling you to accept this sincere and selfless offer we are
making you today. You won't regret it and your future happiness may depend
on it. Maria Duval and I are awaiting your news with great impatience,
Your devoted and sincere friend,
P..S. M~sf i ~ttMrfanf b{ all, d ~ if
Evtl'lf is C.Oittil'/9 vtry s~011(
1117141
bec.4vst y~vr
f;rsf
Lvc.J..y
019103
Exhibit C
Notes taken by me d'tll'ing the Vision I had alxnzt
---- -· --· ····------· ----· "
-- -- -·-· ----·
._,._
·----
----~--
~-
~--
~- __ .
~
--
•
I
'
f
So, you see - _ there- JB no doubt; l:nth Patrick
Guerin and I saW"'the' same haPPillees and the same ahalJgee
linked to :YOU! There iB a~utely no .reason why ~
that we are Pl'edicting for you COUldn't cxxne trQe.
Y--. ,..:., 6 ,c..t:~"""' ~.,...;,.(A...a,.,. p.._ -.11:.. ,...,z'
.....,...
------------
Exhibit C
l
\
00 :Both of you saw far me, at the oom tl-!!lfl the following great ohangee:
1 A first happy event in 'l7 day!i!o
Many major wins an gamee of chanoe.
J.n cmd to all my most urgent problems.
Good news in my relatianahi:t:a and my emotional life.
other (s:ignif1cant) wins on games of chance!
A tatally new and much happier life!
Yes, I want these transf'cmnati.ons in my life and so would ask you kindly to perform:
QO
My Grand CerEIJIO!lY which can make me a WINNER and a.llow me to SEE and
these many important opportunit:l.es that are ooming my way, part:lcularly
1n the area of MONEY!
SEizE
.Aml_,~lease send
me:
lX) Mv rqyster1oufl -bt.J1A!!!RD with the power to attract LUCK and MONEY.
(X) My Inyaluah]e Guide to my New T.1f19. in which I'm goii:)g to find all the
need to grasp my many chanoes at ~ the right time when
they oome along. SUCh as far example: The days and numbers I should play to
ma:x:l.m1m my chances to win, and win BIG! What I need to do to change my life
and see an end to my problems.
!nfarmat1on I
00
What you most want far me is my haPPiilees. That's why you've decided
of your help far f'l:'ee, I only pay the cost of
the preparation and mailing of my Invaluable Guide to a New Life (just f.:O)
which I am encJnsing with this Aas1.stance Form 1n the following manner:
to offer me the first part
I encJoee a ( ) check ar ( ) money arder
far a total of S50, (which 1ncludee all
fees and f1:rErt-Class delivery fees) made out
to: Destiny R arch Center, ar ( ) cash.
or by Credit card: ( ) Mastercard ( ) visa
Gard. Gard. No=
Please check your address below and,
i f neceesery, correct using CAPITAL
LRl'l'E!RB. Thank you.
~~is:
Expiry date (MM/Yl): - - ' - -
132!m()
~~------------------·
Your
Complete
a.'arantee
:sro
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