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1 STATE OF FLORIDA OFFICE OF THE ATTORNEY GENERAL, DEPARTMENT OF LEGAL AFFAIRS IN THE INVESTIGATION OF: HYPER GROUP LLC, a Florida Limited Liability Company, TONY PARDO, Individually and d/b/a FIRST CHOICE ADVOCATES, AG Case# L Respondents ~/ ASSURANCE OF VOLUNTARY COMPLIANCE PURSUANT to the provisions of Chapter 501, Part II of the Florida Statutes, Florida's Deceptive and Unfair Trade Practices Act, the OFFICE OF THE ATTORNEY GENERAL, DEPARTMENT OF LEGAL AFFAIRS (hereinafter referred to as the "Department"), caused an investigation to be made into the business practices of HYPER GROUP, LLC, Tony Pardo d/b/a First Choice Advocates (hereinafter "Respondents"). Respondent, HYPER GROUP, LLC is a Florida Limited Liability Company with its principal place of business registered as 1844 Nob Hill Road, Plantation, Florida Tony Pardo is the principal officer of HYPER GROUP LLC. Respondent TONY PARDO, an individual, operated an unincorporated business under the trade name FIRST CHOICE ADVOCATES with is principal place of business as 1844 Nob Hill Road, Plantation, Florida Respondents are prepared to enter into this Assurance of Voluntary Compliance (hereafter referred to as the "A VC") without an admission that Respondents have violated 1 Initial~

2 Florida's Deceptive and Unfair Trade Practices Act or any other law and for the purpose of resolution of this matter only with the Department. The Department, by and through the undersigned Assistant Attorney General, and the undersigned Director of the Economic Crimes Division, being in agreement, accept this A VC in termination of this investigation, as set out in the terms of this A VC, as to Respondents only, pursuant to Section (6), Florida Statutes, and by virtue of the authority vested in the Department by said statute. I. STIPULATED FACTS The Department and Respondents hereby agree and stipulate to the following: 1. During the time frame beginning sometime in January 20 I 0 and thereafter, Respondents engaged in the business of offering services to timeshare owners. 2. Respondents offered recovery services to timeshare owners who were previously targeted and schemed by timeshare companies. 3. The Department has investigated allegations that through its website and other communications with consumers, Respondents allegedly stated or implied a relationship with the Florida Office of the Attorney General and/or other state or federal agencies and/or made other misrepresentations that constitute an unfair or deceptive trade practices under the Florida Deceptive and Unfair Trade Practices Act. 4. Respondents make no admission of guilt nor admit that they engaged in any wrongdoing or committed any violation of Florida Statute 501, Part II. This AVC contains neither findings of fact nor conclusions of law. 2 Initi~

3 5. Respondents and the Department desire to resolve all issues arising during the course of this investigation. 6. This A VC is based upon the stipulated facts set forth in Paragraphs 1-4 above. The Department shall not be estopped from taking further action in this matter should the facts described herein be shown to be incorrect in any material way, or the AVC not be complied with in full by Respondents. II. TERMS 7. Respondents have voluntarily ceased representing any relationship or association with the Florida Office of the Attorney General or any other state or federal agency. 8. Respondents and its representatives, agents, employees, successors, assigns, independent contractors or any other person who acts under, by, through, or on behalf of Respondent, directly or indirectly, or through any corporate or other device, shall comply with the Florida Deceptive and Unfair Trade Practices Act, Chapter 501, Part II, Florida Statutes. 9. Specifically, Respondents and its representatives, agents, employees, successors, assigns, independent contractors or any other person who acts under, by, through, or on behalf of Respondents, directly or indirectly, shall cease any representation, express or implied, that Respondents have any association, affiliation, relationship, or is otherwise acting for, on behalf, under the auspices, or with the approval of the Office of the Attorney General for the State of Florida or any other federal or state agency unless Respondents are specifically licensed or otherwise authorized by said agency to make such representation. 10. Respondents shall dissolve the entities that are the subject of this Agreement, as well as TIMESHARE BY OWNER OF SUNRISE, LLC, which is a corporation involved in the 3 lniti~

4 timeshare resale industry. Respondents agree they will have no further involvement with TIMESHARE BY OWNER OF SUNRISE, LLC. 11. Respondents shall not, directly or indirectly, including through any other entity or fictitious name, market, advertise, sell or provide recovery related services involving timeshare owners for which a fee for such service is charged, including but not limited to, the following business and/or fictitious names with which TONY PARDO and/or TONY PARDO's immediate family members are associated with: a. TKM FINANCIAL ASSOCIATES, LLC b. TIMESHARES BY OWNER OF SUNRISE, LLC c. PARAGON MARKETING & PROMOTIONS, INC. d. CHEAP SHIP 12. It is further agreed by the parties that Respondents shall be responsible for making the substantive terms and conditions of this agreement known to the officers, employees, agents, representatives, or any other persons that are substantially affected by this A VC and are involved in the businesses, projects and activities of Respondents. The obligation imposed by this paragraph is continuing in nature and shall apply to new officers, employees, agents, representatives or any other persons who become engaged in the entity's business activities, including any future business activities in which Respondents engage. 13. It is further agreed by the parties that Respondents shall not affect any change in the form of doing business, or the organizational identity of any of the existing business entities, or create any new business entities, as a method of avoiding the terms and conditions set forth in this AVC. 4 lnitia17jf.-

5 14. Nothing in this A VC shall be construed as a waiver of any private rights of any person or release of any private rights, causes of action, or remedies of any person against Respondent or any other person or entity. III. STIPULATED PAYMENT 15. The parties agree that Respondents shall pay the total sum of NINE THOUSAND DOLLARS ($9,000.00) as settlement in full of any and all claims that were or could have been asserted against Respondents, which amount shall be allocated by the Department in its sole discretion for consumer restitution in accordance with (6), Florida Statutes. The payment shall be submitted in accordance with Paragraph 17 of this A VC herein to Theresa Therilus, Assistant Attorney General, with the original AVC executed by Respondents and their counsel. 16. Respondents are directed to pay to the Department, TWO THOUSAND FIVE HUNDRED DOLLARS ($ ) ("Escrow Funds") to satisfy future consumer restitution for a period of sixty (60) days from the date of execution of this A VC. In the event actual restitution for future complainants exceeds the amount of the Escrow Funds, then the Escrow Funds will be distributed pro-rata to the complainants who come forward within the sixty (60) day period. However, no individual consumer will receive more than the amount they are actually owed. Upon the passing of these sixty ( 60) day period, any remaining monies shall revert back to the Department of Legal Affairs Revolving Trust Fund. 17. Payment shall be made as follows: A single payment of ELEVEN THOUSAND FIVE HUNDRED DOLLARS ($11,500.00) shall be submitted at the time of execution ofthis A VC. Payment shall be made by cashier's check or other certified funds made payable to the 5 Initials~

6 Department of Legal Affairs and shall be submitted to Theresa Therilus, Assistant Attorney General. 18. The Office ofthe Attorney General is waiving payment of any statutory penalties for violation of Florida Statutes Section 501, of up to $15,000 per violation, by Respondent in consideration of the parties' entry into this A VC. 19. The original A VC, bearing the notarized signatures of Respondents and the above-described payment will be delivered to the attention of: Theresa Therilus, Assistant Attorney General, Office of Attorney General, Economic Crimes Division, 110 SE 6th Street, loth Floor, Fort Lauderdale, FL IV. BUSINESS RECORDS 20. Respondents agree to retain documents and other information reasonably sufficient to establish compliance with the provisions herein, and shall provide reasonable access to such documents and information to the Department upon request. V. FUTURE VIOLATIONS 21. It is hereby agreed by the parties that any failure to comply with the terms and conditions of this A VC is by statute prima facie evidence of a violation of Chapter 50 I, Part II, Florida Statutes, and will subject Respondents to any and all civil penalties and sanctions authorized by law, including attorney's fees and costs. 6 Initial~

7 VI. CLOSURE OF INVESTIGATION 22. It is further agreed by the parties that upon the receipt of the agreed upon payments from Respondents, the Office of the Attorney General agrees to close its civil investigation into the activities of Respondents, as set forth above, without prejudice to any remaining investigation as to other entities. The parties agree that this A VC has been entered into based on the truthfulness ofthe information provided by Respondents. VII. EFFECTIVE DATE OF AVC OF VOLUNTARY COMPLIANCE 23. It is further agreed by the parties that the effective date of this A VC shall be the date of its execution and delivery by all the parties, including each of the parties reflected by the signature lines below. Acceptance by the Office of the Attorney General shall be established by the signature of the Director of Economic Crimes. The receipt by the Office of the Attorney General of any monies pursuant to the AVC does not constitute acceptance by the Director of Economic Crimes, and any monies received shall be returned to Respondents at the address indicated below the signature lines of Respondents if this A VC is not accepted and executed by the Director of Economic Crimes. 24. It is further agreed that facsimile copies of signatures and notary seals may be accepted as original for the purposes of establishing the existence of this agreement. This A VC may be executed in multiple counterparts. Each counterpart when so executed shall be deemed an original and all of which together shall constitute one and the same agreement. 7 Initia~

8 VIII. NOTICE TO PARTIES 25. It is further agreed that future notice to any of the parties to this A VC may be made by notice sent certified mail to at the addresses set forth below unless either party notifies the other by certified mail of another address to which notices should be provided. IX. CONSTRUCTION OF AGREEMENT 26. It is further agreed that the parties jointly participated in the negotiation of the terms of this A VC. No provision of this A VC shall be construed for, or against, any party, on the grounds that one party had more control over establishing the terms of this A VC, than another. In witness whereof, Respondents have caused this AVC to be executed in the county and state listed below, as ofthe date affixed thereon. By my signature I hereby affirm that I am acting in my capacity and within my authority as corporate representative, as well as in my individual capacity, and that by my signature I am binding myself and the business to the terms and conditions of this A VC. SIGNATURE PAGE FOLLOWS: 8

9 Tony Pardo, d/b/a FIRST CHOICE ADVOCATES 1844 Nob Hill Road Plantation, Florida BEFORE ME, an officer duly authorized to take acknowledgments in the State of Florida, TONY PARDO, personally appeared, individually, and as an individual doing business as FIRST CHOICE ADVOCATES who produced \1-\) l- as identification. He acknowledged St!'ore me that he executed the foregoing instrument for the purposes therein stated on th~ day of~-r, 2011 and that each above statement is true and correct. Subscribed to before me this ~~day of ~... ~ NOTARY PUBLIC ~.. ~~~.. J. MULLINGS, 2 : ~ Commission # EE Expires November 28, 2014 Bonded Thru Troy Fain Insurance SOQ (print, type, or stamp commissioned Notary Public) Personally known or Produced Identification Type ofldentification Produced: ~\:)b., ~ (check one) 9 Initials Tf

10 HYPER GRO;w, LLC~ Signed: Its: By: f -f--'-'--'-c;;;.., HG&t<-1 STATE OF FLORIDA COUNTY OF BROWARD "'T. BEFORE ME, an officer duly authorized to take acknowledgments in the State of Florida, 01'~ ~o-tt\o, appeared~ of Hyper Group LLC, who produced ~ ~L as identification. S/he acknowledged before me that he executed the foregoing instrument for the purposes therein stated on the ~~day of~, ~~~v, \- l'\_. s-~il\t:t:-~ ''"""'' J. MU~li~GS Subscribed to before me this~~ day of~, ~ ( i;i' : ~ Co~m,ss,on # EE ~~~: Exp!res November ",,,9f.t,~,... Bonded Thru Troy Fain Insurance a00-a NOTARY PUBLIC (print, type, or stamp commissioned Notary Public) Personally known or Produced Identification V (check one) Type of Identification Produced: "-...:...:...c~:::..!::l.-= Witnessed: By: Andrew Cove, Esq. Counsel for Hyper Group, LLC and Tony Pardo Florida Bar No S 21st Avenue Hollywood, Florida Ph: Initials~

11 12/30/ :55 FAX COVE&Associates_- ~ 002/002 HYPERGRoUP,uy ( Signed: : ( -f-,_..., d.., -~~- Its: By: Ha&t1 STATE OF FLORIDA COUNTY OF BROWARD BEFORE ME, an officer duly ~cuthorized to take acknowledgments in the State of Florida, \ 0~ ~o-tdq, appeared~ - of HYPer Group LLC, who produced ~ ~L as identification. Slhe acknowledged be:fore me that he executed the foregoing instrwnent for The pujposes therein stated on the ~"'"'"day o(~u... ~.Q.D Subscribed to before me this 'lie!~ d.a,y o(~'w, NOTARY PUBLIC (print, type, or stamp commissioned Notary Public) Personally known or Produced Identification V (check one) Type ofldentification Produced:_:~;\..~)=-== v;~ e:r~lt( < By:... Andrew Cove, Esq. Counsel for Hyper Group, LLC and Tony Pardo Florida Bar No S 21~ 1 Avenue Hollywood, Florida Ph: Initial~

12 ACCEPTANCE BY THE OFFICE OF THE ATTORNEY GENERAL Dated: Dated: t/jf?- J~~r---n THERESA. THERILUS Assistant Attorney General 110 S.E. 6th Street, 9th Floor Fort Lauderdale, FL (954) (954) facsimile Economi IVISIOn Department of Legal Affairs OFFICE OF THE ATTORNEY GENERAL 1515 North Flagler Drive West Palm Beach, FL (561) Initials --

PURSUANT to the provisions of Chapter 501, Part II, Florida Statutes, Florida's

PURSUANT to the provisions of Chapter 501, Part II, Florida Statutes, Florida's STATE OF FLORIDA OFFICE OF THE ATTORNEY GENERAL, DEPARTMENT OF LEGAL AFFAIRS IN THE INVESTIGATION OF: AG Case# L09-3-12.J"t DIRECT MORTGAGE SOLUTIONS, INC., and OSV ALDO CAMPOS, Respondents. ----------------------'