Complaint Counsel's Post Trial Brief - Federal Trade Commission

96. Respondent James Feijo is responsible for the development, creation, production, and
pricing of the DCO Products. (CX 39; R15 (J. Feijo, Dep. at 116); R16 (P. Feijo, Dep. at
77)).
97. Respondent James Feijo and his wife, Patrcia Feijo, have been solely responsible for
creating, drafting, and approving the directions for usage ofthe DCO products. (CX 39).
98. Respondent James Feijo and Patrcia Feijo developed the recommended dosages of
DCO Products. (CX 39; R16 (P. Feijo, Dep. at 117, 166-67, 192)).
99. Respondent James Feijo is the trstee for all Danel Chapter One assets, including all
fuds, which are to be held in trst. (CX 39; J. Feijo, HOJ Tr. 73).
100. Respondent DCO has ban accounts with Citizens Ban. (CX 49).
101. All of the revenue eared by Respondent DCO is deposited in the DCO ban account
before being distrbuted, at Respondent James Feijo's discretion, to other ban accounts
such as a "Creation Science Funding," "Radio Leasing Interational," "Business Parers
Checking," and "Business Parers Money Market Fund." (J. Feijo, HOJ Tr. 206-08,
227,230).
102. Patrcia Feijo is a signatory to DCO's ban account and wrtes checks on behalf of
DCO account. (R16 (P. Feijo, Dep. at 54); P. Feijo, HOJ Tr. 276).
103. Jil Feijo, James Feijo's daughter, pays DCO's bils. (J. Feijo, HOJ Tr. 204).
3. Respondents Do Not Maintain Records
104. DCO has a policy of
not maintaing records. (J. Feijo, HOJ Tr. 73, 83).
105. Respondent James Feijo did not change DCO's document retention policies after learg
that the FTC had brought a proceeding against him and DCO. (J. Feijo, HOJ Tr. 80).
106. DCO did not change its document retention policies after receivig the Cour's fist and
second orders to produce cerain documents to Complaint Counsel. (J. Feijo, HOJ Tr.
81-83).
107. Respondent James Feijo had the authority to change DCO's document retention policy
after receivig the Cour's orders to produce cerain documents to Complaint Counsel if
he thought the records would show that DCO was a nonprofit corporation. (J. Feijo, HOJ
Tr. 83).
108. DCO continued to thow out documents, including Maro's purchase order form, even
after receiving the Cour's orders to produce certain documents to Complaint Counsel.
(J. Feijo, HOJ Tr. 83).
4. Respondents Profit from the Sale of the DCO Products
109. James and Patrcia Feijo live in the Portsmouth, Rhode Island proper owned by
Messiah Y'Shua Shalom as well as in a three-bedroom proper in Deereld Beach,
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