STATE OF NORTH CAROLINA

WAKE COUNTY

 

IN THE GENERAL COURT OF JUSTICE

SUPERIOR COURT DIVISION

NO. 03 CVS __________

STATE OF NORTH CAROLINA ex rel.

ROY COOPER, Attorney General,

                Plaintiff,

                vs.

FACE NATIONAL MODELS & TALENT, L.L.C.,

JENNIFER LYNN GILL, and CHAD E. JOHNSON,

                Defendants.

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TEMPORARY RESTRAINING ORDER

THIS CAUSE came on before the undersigned Superior Court Judge on the Attorney General's motion for a temporary restraining order pursuant to N.C.G.S. § 75-14, Rule 65 of the North Carolina Rules of Civil Procedure, and Chapter 114 of the North Carolina General Statutes. It appears to the Court from the verified complaint and the motion and affidavits filed herein that there is good and sufficient cause to believe that the defendants Face National Models & Talent, L.L.C. (Face), Jennifer Lynn Gill, and Chad E. Johnson are engaged in unfair and deceptive commercial practices in violation of N.C.G.S. § 75-1.1.

It further appears to the Court that immediate and continuing loss to the consuming public will occur unless defendants are temporarily enjoined from violations of the law, and the Court therefore finds the plaintiff State of North Carolina is entitled to a temporary restraining order.

IT IS THEREFORE ORDERED that defendants, their agents, employees, and persons acting in concert with them are temporarily restrained from:

1. Offering or providing for a fee photography services of any kind, including the production or development of comp cards, to any of Face's customers or prospective customers and receiving or collecting money for such services;

2. Offering or providing any type of seminar, class, conference, or convention for which consumers pay a fee to receive information, instruction, or training about any aspect of the modeling business;

3. Disposing of any funds in Face accounts at the time of the entry of this order, including both bank accounts and brokerage accounts; and

4. Destroying, removing, transferring, erasing, or otherwise disposing of any business or financial records, relating to the defendants' modeling business or relating to moneys obtained or disbursed from any consumers in connection with Face's operations.

IT IS FURTHER ORDERED that at least three (3) days prior to the preliminary injunction hearing in this matter, and in no event later than two (2) weeks after entry of this Order, defendants shall provide plaintiff with:

(a) Completed financial statements which identify income, disbursements, and assets for defendants and which are accurate as of the date of service of this Order upon defendants;

(b) A list of all bank accounts or brokerage accounts, including the current balances of those accounts, held in the name of any defendant individually or jointly; and

(c) A list containing the names, addresses, and telephone numbers of all customers who have paid money to defendant Face and, for each customer, the amount of money paid to Face as well as the services Face has provided to each customer.

IT IS FURTHER ORDERED that this matter be heard before the Superior Court Judge presiding at the Wake County Courthouse, Courtroom ________ on _____________________, 2003, at _______ ___. M., or as soon thereafter as this matter can be heard, on the State's motion for a preliminary injunction.

This the ______ day of _________________, 2003, at ________ ___. M.

__________________________________

Superior Court Judge

WE CONSENT:
STATE OF NORTH CAROLINA
ex rel. ROY COOPER,
Attorney General

Harriet F. Worley
____________________


Assistant Attorney General

  Miles S. Levine
____________________


Counsel for Defendants

Face National Models & Talent, L.L.C.,

Jennifer Lynn Gill
Chad E. Johnson
Face National Models & Talent L.L.C.

Jennifer Lynn Gill
____________________
  Jennifer Lynn Gill (Individually)
____________________
     
Chad E. Johnson (Individually)
____________________
   

CERTIFICATE OF SERVICE

I do hereby certify that I have this day served upon defendants the foregoing TEMPORARY RESTRAINING ORDER by personal delivery to:

Miles S. Levine, Attorney for Defendants Face National Models & Talent, L.L.C., Jennifer Lynn Gill and Chad E. Johnson

GOODMAN, CARR, LAUGHRUN, LEVINE AND MURRAY
301 South McDowell Street, Suite 602
Charlotte, NC 28204

This the _____ day of March, 2003.

ROY COOPER
Attorney General

__________________________

Harriet F. Worley
Assistant Attorney General
Consumer Protection Division

N.C. Department of Justice