Complaint Counsel's Post Trial Brief - Federal Trade Commission

3209,3210,3217,3218,3225,3235,3238,3245,3251, 3255, 3264, 3265, 3274, 3275,
3284).
123. According to American Express statements for DCO's Amercan Express Business Gold
Card, approximately $28,582 was charged for automobile expenses durng the period
December 2005 - March 2009. (CX 48 at FTC-DCO 2966, 2975,3003,3011,3019,
3027,3039,3049,3050,3057,3065,3068,3082,3103, 3105, 3113, 3127, 3129, 3165,
3173,3181,3189, 3208B, 3231, 3238, 3245, 3264, 3265, 3271, 3273, 3284).
124. According to Amercan Express statements for DCO's Amercan Express B.usiness Gold
Card, approximately $1,077 was charged for cigar expenses durg the perod December
2005 - March 2009. (CX 48 at FTC-DCO 3113, 3121, 3181, 3197, 3208M, 3245, 3264,
3273).
125. Respondent DCO also has credit cards with Ban of Amerca and Chase Ban. (J. Feijo,
HOJ Tr. 161).
126. According to Citizens Ban statements for DCO's and related entities' checkig
accounts, approximately $51,087 was electronically tranfered from these checkig
accounts to Ban of Amerca durg the perod Februar 2007 - March 2009. (CX 49 at
FTC-DCO 3352, 3359, 3363, 3367, 3674, 3680, 3685, 3701, 3706, 3726, 3733, 3741,
3750).
127. According to Citizens Ban statements for DCO's and related entities' checkig
accounts, approximately $30,277 was paid by check from DCO's Creation Science
Funding account to Ban of Amerca durng the perod Janua 2007 - April
49 at FTC-DCO 3448, 3456, 3470, 3472, 3498).
2007. (CX
128. According to Citizens Ban statements for DCO's and related entities' checkig
accounts, approximately $25,837 was paid by check from DCO's Creation Science
Funding account to Chase Card Serces durng the perod Januar 2007 - April 2007.
(CX 49 at FTC-DCO 3441,3464,3470,3493,3497).
129. Respondent James Feijo does not retain any receipts for his credit card purchases and
credit card payments are automatically debited. (J. Feijo, HOJ Tr. 163-64).
130. Respondent James Feijo does not have his own individual ban account. (J. Feijo, HOJ
Tr. 208).
131. Respondent James Feijo pays his daughter Jil $700 per week for her work at Danel
Chapter One. (J. Feijo, HOJ Tr. 204-05).
132. Although he personally paid income taxes prior to DCO's incorporation as a corporation
sole, Respondent James Feijo has since stopped personally payig income taxes. (J.
Feijo, HOJ Tr. 86).
133. Respondents do not pay any state sales tax based on the sale ofDCO products though
the DCO Web site. (J. Feijo, HOJ Tr. 210).
11