discretion, extend the time for Ford to sell his Bowie residence.

Any such extension shall be in writing.

VI.

Judgment is hereby entered against Ford in the amount of $863,646.62, plus interest at the rates established by the Internal Revenue Service for underpayment of taxes from May 15, 1991, representing disgorgement of all sums received by Ford, directly or indirectly, from ILN. Upon satisfaction of $863,646.62 of such claims, plus all accrued interest, no further disgorgement shall be required, provided, however, that if Ford is shown to have received more than $863,646.62 from ILN, directly or indirectly, then the amount of this judgment shall be increased accordingly.

VII.

Ford and his agents, servants, employees, attorneys, and those persons in active concert or participation with him who receive actual notice of this order by personal service or otherwise, are permanently enjoined for a period of three years from the date of this Final Judgment from destroying, mutilating, concealing, altering, or disposing of any items, including, but not limited to, any books, records, documents, contracts, agreements, assignments, obligations, tape recordings, computer media or other property of the defendants, relating to the activities described in the Amended Complaint in this action or to ILN or its affiliates or subsidiaries.

VIII.

Subject to the assertion of any applicable privileges, Ford shall cooperate and shall cause Gwendolyn Ford to cooperate in all respects with the efforts of the Trustee and the Commission pursuant to this Final Judgment; shall give the Trustee and the Commission all reasonable assistance, including powers of attorney and assignments, and such testimony, information, and documents as the Trustee requires to carry out his duties detailed above, or as the Commission requires in connection with any continuing investigation of the matters alleged in the Complaint or otherwise relating to International Loan Network.

IX.

In accordance with his agreement in his Consent and Undertakings, Ford shall continue to be considered a party to

this action for purposes of the Right to Financial Privacy Act of 1978 (12 U.S.C. 3401 et seq.] and, as if still a party to this action, shall respond to requests for discovery by the Commission in accordance with the Federal Rules of Civil Procedure and the applicable local rules.

X.

IT IS ORDERED, ADJUDGED AND DECREED, that Ford shall comply with the annexed Consent and Undertakings of Melvin J. Ford,

which are incorporated herein with the same force as if fully set forth in this Final Judgment.

There being no just reason for delay, the Clerk of the Court is hereby directed, pursuant to Rule 54 (b) of the Federal Rules of Civil Procedure, to enter this Final Judgment forthwith.

19th

SO ORDERED, this

day of November, 1992, at 9 Am.

Jan 7 Hogan

THOMAS F. HOGAN

UNITED STATES DISTRICT PODGE

SEC.v. Inte: ational Loan Network ...968 F.2d 1304, 297 U.S.App D.Cap://www.mimlaw.com/library/cases/mim/federal/dcsecint!load92.htm

LAW LIBRARY

Before RUTH BADER GINSBURG, HENDERSON and RANDOLPH, Circuit Judges.
Opinion for the court filed by Circuit Judge KAREN LECRAFT HENDERSON.

KAREN LECRAFT HENDERSON, Circuit Judge:

[T]he movement of money creates wealth. What we believe is that if you organize people
and get mor.ey moving, it can actually create wealth.

-Melvin J. Ford [FN1]

FNI. Los Angeles, California President's Night, April 18, 1991. Joint Appendix (JA) 150.
Money is always there but the pockets change.

--Gertrude Stein [FN2]

FN2. As attributed in Michael C. Thomsett, A Treasury of Business Quotations 102 (1990).

Appellants Melvin J. Ford and Odell Mundey appeal from the district court's opinion
holding that the operation of certain investment programs by the International Loan

SEC v. Late-ational Loan Network .968 F.2d 1304, 297 U.S.App.D.Ch@://www.mimlaw.com/library/cases/mim/federal/desecintload92.htm

Network, Inc. (ILN) constitutes the fraudulent offer or sale of unregistered securities in
violation of federal securities law and from the preliminary injunction, based thereon,
prohibiting the appellants from continuing to operate those programs and freezing ILN's
assets. For the reasons set out below, we affirm the trial court's opinion and preliminary
injunction.

Ford is the founder and president of ILN, which he describes as "a financial distribution
network whose members believe that through the control of money and through the control
of real estate you can accumulate wealth and become financially independent." JA 131. To
promote ILN's various financial enrichment programs, Ford travels throughout the country
addressing ILN members and prospective members, with evangelical fervor, at revival-style
"President's Night" gatherings. *1306 **24 Mundey is vice president of ILN. ILN's
programs, which are described at length in the district court's opinion, see SEC v.
International Loan Network, Inc., 770 F.Supp. 678, 682-87 (D.D.C.1991), may be
summarized as follows:

(1) Memberships: First, ILN sells "basic" and "club" memberships. A basic membership
costs $125 and entitles the member to various benefits including discount shopping, travel
and car rental. A basic member can purchase a club membership for an additional $100,
$500, or $1,000 payment and receive in return investment advice through newsletters,
seminars, and so on. In addition, Club members at the $500 and $1,000 level are entitled to
participate in ILN's "Property Rights Acquisition" program, which is described infra.

(2) Capital Fund Bonus System: The Capital Fund Bonus System (CFBS) is a pyramid sales
program that Ford has characterized as "the most powerful financial system since banking."
JA 150. To participate in this program, a person signs on as an "Individual Representative"
(IR) to sell ILN memberships for a fifty per cent commission. In addition, he receives
fifteen per cent commissions on sales made by members he recruits and by their recruits and
ten per cent commissions on sales by the next two levels of recruits "downline."

(3) Property Rights Acquisition Program: The Property Rights Acquisition (PRA) program
is the fourth in a series of related ventures. In its first three incarnations, as more fully
described by the district court, 770 F.Supp. at 683-85, the program promised large cash
payments or valuable real property rights within 180 days to qualified members who made
an immediate cash payment of $1,000 to $10,000. The present program, begun in March,
1991, is substantially more modest, at least on paper. According to the program's brochure,
the purchaser of a PRA now obtains only instructional videotapes, the right to enroll in real
estate courses and access to a computer listing service. [FN3]

FN3. Without making any finding on the matter, the district court suggested the possibility
that the PRA program migh: still be orally promoted as an investment contract similar to its
predecessors. 770 F.Supp. at 693.

(4) Maximum Consideration Program: The Maximum Consideration program is described
in ILN's written materials as a "special award opportunity for representatives of ILN who
have evidenced that they are in the process of acquiring real property for purposes other
than a personal residence." JA 108. To be eligible for the award, a person must (1) sell
$3,000 worth of PRA memberships, (2) make an earnest money deposit on an agreement to
purchase real estate for other thar residential use, which can be satisfied by a PRA purchase,
ard (3) sign an "acknowledgment" form that states, inter alia: "I agree that Maximum
Consideration is a special award paid at the sole discretion of ILN and only the top ten
qualifiers are guaranteed an award," JA 111. Each of the top ten qualifiers is guaranteed an
award of at least $5,000, while the discretionary awards to others may reach five times their
onginal PRA purchase price or real estate contract deposit, "based upon PRA sales volume,
the amount of money invested, and the length of time they have been in the program." 770
F.Supp. at 686. According to Ford, an individual purchasing $16,000 worth of PRAS could
receive an award of up to $80,000 because "all of a sudden the velocity of money increases