Complaint Counsel's Post Trial Brief - Federal Trade Commission

CCPF ~ 16-18. In 2002, James Feijo organzed DCO as a corporation sole under Washington
state laws. CCPF ~ 1. James Feijo serves as DCO's Overseer, trstee for all DCO assets, and
custodian ofDCO's financial records. CCPF ir 4,99, 105, 107. Patrcia Feijo is DCO's
Secretar. CCPF ~ 5. Neither James nor Patrcia Feijo is a doctor or research scientist. CCPF
~~ 147-49.
Respondents' pricipal offce and place of
business is located in Portsmouth, Rhode
Island, where the Feijos live. CCPF ~ 3. DCO's two Rhode Island buildings contain an Order
Center and a warehouse for the products that DCO offers to the public. CCPF ~ 9. James Feijo
established another Washigton corporation sole -- Messiah Y'Shua Shalom -- which he uses to
own the Rhode Island proper. CCPF ir 10-11.
B. Respondents are Responsible for the Development and Sale of the DCO
Products
1. The Feijos Developed the DCO Products, Their Labels, and
Their Advertsements
As the Overseer for DCO, James Feijo has responsibility for and control of
its operations.
CCPF ir 4,95. James Feijo developed, created, and produced the DCO Products. CCPF ~ 96.
He established the DCO Products' price. CCPF ~ 96. He and Patrcia Feijo have been solely
responsible for creating, drafting, and approvig the DCO Products' directions and
recommended usages. CCPF ~ 97. They also developed the suggested dosages. CCPF ir 98.
The identity and amount of each ingredient is contained on the product labels. CCPF ~ 74. DCO
contracts with Universal Nutrtion to manufactue approximately 35-40 products, including
Bio*Shark, GDU, and BioMixx. CCPF ~ 81.
James Feijo and his wife, Patrcia Feijo, are responsible for the information contained in
DCO's adverising materials, including the BioGuide, the Cancer Newsletter, and the Web sites
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