Practices Act", Florida Statutes (2010), the STATE OF FLORIDA, OFFICE OF THE

STATE OF FLORIDA OFFICE OF THE ATTORNEY GENERAL DEPARTMENT OF LEGAL AFFAIRS In the Matter of: Wisdom of the Ages Worldwide, Inc. AG Case Number: 11-3-1036 Respondent ASSURANCE OF VO LUNT ARY COMPLIANCE PURSUANT TO Chapter 501, Part II, "The Florida Deceptive and Unfair Trade Practices Act", Florida Statutes (2010), the STATE OF FLORIDA, OFFICE OF THE ATTORNEY GENERAL, DEPARTMENT OF LEGAL AFFAIRS (hereafter the "Department") has investigated certain acts and practices of Wisdom of the Ages Worldwide, Inc. (hereinafter the "Respondent".) Respondent enters into this Assurance of Voluntary Compliance (hereafter the "AVC") with the Department without an admission of wrongdoing and for the purpose of resolving this matter only. Pursuant to Section 501.207(6), Florida Statutes (2010), the Department accepts this A VC in termination of its investigation into certain acts and practices of Respondents related to its charitable cash raffle. 1. BACKGROUND 1.1 Respondent, Wisdom of the Ages Worldwide, Inc., is a Florida corporation with its current principal place of business located in Pensacola, Florida. Respondent is registered with the Division of Consumer Services of the Florida Department of Agriculture and Consumer Services ("DCS") as a charitable organization under license number CH30756. 1.2 Respondent represents to the Department that it is charitable organization as defined in Section 496.404(1 ), Florida Statutes (2010), and is validly and currently registered Page I of7

with DCS under license number CH30756. It further represents to the Department that it is a tax exempt organization under Section 50l(c)(3) of the Internal Revenue Code, and is organized and operated exclusively for the exempt purposes set forth in section 501 ( c )(3). 1.3 The Department initiated its investigation of the business practices of Respondent on February I, 2011. The Department's investigation revealed that the Respondent had organized and was in the process of' conducting a charity cash raffle known as the "CharityCashRaffle.com" (the "Raffle"). Respondent created and maintained a website at charitycashraffle.com (the "Website") where it sold tickets for the Raffle, and where it set forth the terms and conditions of the Raffle. 1.4 Respondent offered a cash pnze of $50,000.00 (the "Prize") in the Raffle. However, the Respondent did not have the Prize money when it organized the Raffle. Instead, Respondent intended to obtain the Prize money through sale of tickets to the Raffle. Among other terms and conditions, Respondent stated that the "drawing to be held when the entire allotment of 5000 tickets are sold". The Respondent set the date of the drawing for April 15, 2011, but provided that the "drawing date may be accelerated or extended" depending on ticket sales. 1.5 The Department contends that Respondent's Raffle as organized and conducted was in violation of various provisions of Section 894.0935, Florida Statutes (2010). At the time of the Department's initial contact with the Respondent, Respondent had sold Raffle tickets to 55 consumers. The total amount of contributions collected by Respondent for the Raffle was $2,432.00. 1.6 Respondent has agreed to cease the Raffle, and has refunded the $2,432.00 to the consumers who purchased Raffle tickets or otherwise donated monies to Respondent in connection with the Raffle. Respondent has already posted the following notice on the Website: Pagelof7 ~ ~

"The CharityCashRaftle.com up to $50,000 Charity Raftle has been closed, no grand prize will be awarded, and ticket contributions will be returned by check in the mail to the address that was provided. Thank you very much for your support and we apologize for the lack of success with this charity raftle." 2. JURISDICTION AND VENUE 2.1 The parties agree that the State of Florida has jurisdiction over Respondents for the purposes of entering into this AVC and any enforcement actions arising out of this AVC. 2.2 It is further agreed by the parties that venue for any matters relating to or arising out of this AVC shall lie solely in Orange County, Florida. 3. COMPLIANCE TERMS 3.1 Respondents shall not violate any applicable law, rule, and/or regulation, including, but not limited to, the following: (a) The Florida Deceptive and Unfair Trade Practices Act as contained in Chapter 501, Part II, Florida Statutes (2010); (b) Section 849.0935, Florida Statute (2010); ( c) The "Solicitation of Contributions Act." as contained in Chapter 496, Florida Statutes (2010) 3.2 Respondent shall discontinue and cease the Raffle, and shall refund all monies to all consumers who purchased tickets or otherwise donated monies to Respondent in connection with the Raffle. Within 30 days from the Respondent's execution of this AVC, Respondent shall provide to the Department an affidavit in a form acceptable to the Department attesting to the refunds in compliance with this A VC. 3.3 In the event Respondent conducts any future raftles, it shall do so solely and strictly in compliance all Florida statutes, laws, rules and regulations, including Section Page3of7 ~ i1litillls

849.0935, Florida Statute (2010) and Th~ "Solicitation of Contributions Act." as contained in Chapter 496, Florida Statutes (2010). 3.4 Respondent acknowledges and agrees that any failure to comply with the terms and conditions of this A VC is by statute prima facia evidence of a violation of Chapter 501, Part II, Florida Statutes (2010), and may subject Respondent to any and all civil penalties and sanctions provided by law, including awarding of attorneys' fees and costs. 4. MONETARY TERMS 4.1 Upon execution of this A VC, Respondent shall pay to the Department the total sum of Five Hundred and No/100 Dollars ($500.00) for investigative costs, attorneys' fees and future monitoring. Payment shall be made by certified or cashier's check payable to the Department of Legal Affairs Revolving Trust Fund and shall be sent to Robert G. Clements, Assistant Attorney General, 135 West Central Blvd, Suite 1000, Orlando, FL 32801. 4.2 In the event that Respondent fails to timely pay the above amount, Respondent shall be in default of this A VC and hereby stipulates to entry of a final judgment in favor of the Department for the outstanding amounts due. Evidence of the failure to pay in accordance the terms and conditions of this.a VC may be in the form of an affidavit from the Department. 4.3 Respondent acknowledges and agrees that any failure to comply with the terms and conditions of this AVC is by statute prima facia evidence of a violation of Chapter 501, Part II, Florida Statutes (2010), and may subject Respondent to any and all civil penalties and sanctions provided by law, including awarding of attorneys' fees and costs. 5. EFFECTIVE UPON ACCEPTANCE 5.1 The Department's Director may refuse to accept this AVC at his discretion, and the A VC shall only become effective upon its acceptance and signing by the Director. 5.2 This AVC may be signed in multiple counterparts, each of which shall be Page4of7 ~ ~

5.2 This AVC may be signed in multiple counterparts, each of which shall be considered an original, and all of which together will constitute one and the same agreement. 6. BUSINESS RECORDS 6.1 In connection with the Department's future monitoring of Respondent, Respondent agrees to retain documents and other information reasonably sufficient to establish compliance with the provisions of this AVC, and shall provide the Department reasonable access to such documents and information upon written request from the Department. 7. CONSTRUCTION OF AVC 7.1 This AVC is the result of joint negotiations between the parties and shall be deemed to have been drafted by both the Department and the Respondent. In the event of a dispute, this AV C shall not be construed against the Department or the Respondent. 7.2 Respondent shall in no way represent that the Department has approved any of the Respondent's business practices, and shall not use the existence of this AVC to in any way imply such approval. 8. APPLICABILITY 8.1 This A VC shall apply to and continuously bind Respondent and their affiliated entities, successors, assigns and each of its officers, directors, agents, servants, employees, and attorneys, whether acting directly or through any corporation, subsidiary, division, or other entity. 9. CHANGES IN LAW OR BUSINESS PRACTICES 9.1 It is further agreed by the parties that if any statutes change due to amendment, repeal, or disposition by the legislature, an agency, or court so that they would permit any action prohibited by any section of this AVC, that section of this AVC shall no longer have any force or effect. Page 5 of7

9.2 If any clause, provision, or section of the AVC shall, for any reason, be held illegal, invalid, or unenforceable, such illegality, invalidity, or unenforceability shall not affect any other clause, provision, or section of this AVC, and this AVC shall be construed and enforced as if such illegal, invalid, or unenforceable clause, section, or other provision had not been contained herein. IN WITNESS WHEREOF, Respondent has caused this A VC to be executed by an authorized representative in the County and State listed below, as of the date affixed thereon. Wisdom of the Ages Worldwide, Inc. ST A TE OF Jif,OIIDM }<. COUNTY OF '1 ~:s!~ Its: President Date: 6 "'}1-, 2011 ~BEFORE ME, an officer duly authorized to take acknowledgments in the State of B~tida, personally appeared Jesse J. Bass, as President of Wisdom of the Ages Worldwide, Inc., who acknowledged before me t at he executed the foregoing instrument for the purposes therein stated, on this ~ay of, 201 lr. ~ l/\ Sworn to and subscribed befo~ me this _-11...: day of fj l t.f, 2011..,. Notary Public State of Wasblagton CALVINBMAY MY COMMISSION EXPIRES June 24, 2014 tl~ Personally known o~. NOTARY PUBLIC (print, type or stamp commissioned name of Notary Public) t> J.oO "":". l.)0 - tl 1 -VIJ_ Produced identification (check?je) t.../7 / : "... ~..... 1\ Type of Identification Produced: -v Page 6 of7

ements ssistant Attorney General ffice of the Attorney General Department of Legal Affairs 135 West Central Blvd., Suite 1000 Orlando, Florida 32801 (407) 245-0833 phone, (407) 245-0365 Fax J_ --! Accepted this day of / C' 11~ '2011. Division of Economic Crimes Office of the Attorney General Department of Legal Affairs 135 West Central Blvd., Suite 1000 Orlando, Florida 32801 Page 7 of7

ctor f co omic Crimes ffice of the Attorney General Department of Legal Affairs The Capitol Tallahassee, Florida 32399-1050 Accepted this day of )_l_/,_!'"'l, 2011. Page 8 of8 Initials

STATE OF FLORIDA OFFICE OF THE ATTORNEY GENERAL DEPARTMENT OF LEGAL AFFAIRS In the Matter of: Wisdom of the Ages Worldwide, Inc. AG Case Number: 11-3-1036 Respondent AFFIDAVIT OF JESSE J. BASS BEFORE ME, the undersigned authority, this day personally appeared JESSE J. BASS, who states: 1. I am president of Respondent, Wisdom of the Ages Worldwide, Inc. ("Wisdom"), which is a Florida corporation with its principal place of business currently located in Pensacola, Florida. Wisdom is registered with the Division of Consumer Services of the Florida Department of Agriculture and Consumer Services ("DCS") as a charitable organization under license number CH30756. 2. Wisdom organized a charity cash raffle known as the "CharityCashRaffle.com" (the "Raffle") and created and maintained a website at charitycashraffle.com (the "Website") where it sold tickets for the Raffle. 3. Wisdom sold tickets for the Raffle to 55 consumers. The total amount of contributions collected by Wisdom for the Raffle was $2,432.00. Wisdom has refunded all the monies collected from the consumers for the Raffle and has ceased the Raffle. FURTHER AFFIANT SAYETH NAUGHT. Pagel of2

k/ikt--- STATE OF Fl:t)RIDA"" j /,. COUNTY OF ~ t ~ tj~efore ME, an officer duly authorized to take acknowledgments in the State of Florida-, personally appeared Jesse J. Bass, who acknowledged b~ore me that he executed the foregoing instrument for the purposes therein stated, on this _.t_( day of ~, 2011. <), r, '-" Sworn to ~~~ubscribed before me this -LL day of fv \ C.,f, 2011. Notary Public State of Wa1hlnpon CALVINBMAY MY COMMISSION EXPIRES June 24, 2014 (print, type or stamp commissioned name of Notary Public) Personally known or / Produced ide~tific~tion t/ (check one) ~Llf) 1 c._ 0? r--0 Type ofldentificat10n Produced: (...t.. [JL -l~ 0- b { U " Page 2 of2 ~s