Usacomplaints.com » Internet & Web » Complaint / Review: Tony Seruga, Digital Mavericks, Inc., Maverick REI, Inc., Anthony Joseph Seruga - Tony Seruga, Digital Mavericks, Maverick REI, Anthony Joseph Seruga Tony Seruga Scam, He stole hundreds of thousands of dollars from hundreds of his clients. #226893

Complaint / Review
Tony Seruga, Digital Mavericks, Inc., Maverick REI, Inc., Anthony Joseph Seruga
Tony Seruga, Digital Mavericks, Maverick REI, Anthony Joseph Seruga Tony Seruga Scam, He stole hundreds of thousands of dollars from hundreds of his clients

What follows is the text of a comlaint that was filed by 35 of Tony Seruga's clients who all felt that he had ripped them off for $10,000 each.

He did had 2 programs in which he failed to deliver on as promised. The most blatent deception occurred with his "All I want is Traffic" program, which he promised to deliver targeted traffic to websites, and in most cases, delivered zero trtaffic. Wghen clients demanded refunds, he then threatened them with a lawsuit - eventhough he delivered nothing.

June 11

Federal Trade Commission
600 Pennsylvania Avenue N.W.
Washington, D.C. 20580

Subject: Complaint Anthony Joseph Seruga (Tony Seruga)

We wish to file a formal complaint against Anthony Joseph Seruga, of Digital Mavericks.inc. For deceptive trade practices and unfair trade practices, specifically for false claims, misrepresentation and breach of warranty. The specifics of our complaint are documented in detail below.

This complaint is regarding two programs, BABB (Build A Better Business) an internet marketing training/coaching program which delivered little to no value to participants over the past 12 months. The second, AWIT (All I Want Is Traffic) was an internet traffic program which did not deliver the promised traffic.

Estimated Known Injuries over the past 12 months:

$300,000 in immediate ignored/denied refund requests
Over $1,000, 000 in direct payments to Mr. Seruga
Indirectly over $200,000 was lost in following Mr. Serugas advice in investing in development projects he proposed
Conservatively 65,000 hours of peoples time over the past 12 months - at least 25 hours/week for 52 weeks for 50 people
30 small businesses severely set back due to spurious business advice

While the dollar volume lost may not be that high compared to relative cases handed by your organization, we believe this case is worth looking into because

Mr. Seruga has aggressively intimidated program members into keeping quiet; as he perpetrates future scams you may not hear about them due to peoples fear of speaking out
He is aiming to create a new program, orders of magnitude larger than the ones which affected us
This is a leading edge area, where people worldwide have been defrauded in highly sophisticated internet marketing coaching. This type of fraud will likely happen in many other markets before long, and investigating this case will give your organization a head start to preventing it in future.

This complaint is being filed with great fear of retribution by Mr. Seruga as he has repeatedly threatened members of this group. There are 35 people who have agreed to participate in this complaint, but many others who fear Tony to the point that they would rather keep their name out of it despite losing tens of thousands of dollars each. We ask that you protect the privacy of all those listed below from retaliation from Mr. Seruga.

While Mr. Seruga was the primary participant, there are 2 other people that provided means and instrumentalities to commit deceptive acts, Rick Duris and Chip Tarver.

There are two main areas we feel warrant investigation:

1. Deceptive Trade Practices:
Failure to have substantiation for claims
o Mr. Seruga claims he is owning and running 53 multimillion dollar businesses. All attempts to verify this claim have proven this not to be accurate
Representations made but not delivered
o In the BABB program:
Quality training was not provided.in fact, much of the material was read from $20 books available from Amazon.com, or taught by his daughter using material from her college marketing course
He did not deliver each person a $1M business
The marketing systems promised were not delivered
He didnt create a million dollar business himself during the BABB program
o In the AWIT program:
He did not deliver most of the promised traffic
He has not paid affiliate commissions due to BABB members that brought their friends into the AWIT program
Guarantees and Warranties:
o Mr. Seruga has been unreachable and non-responsive on refund requests
o He forces people to wait 6 months before offering a refund. We assume this is because chargeback and other remedies will have expired
o Mr. Seruga guaranteed to start up the million dollar business for his BABB members if they were unable to. Naturally this has also not been delivered.

2. Unfair trade practices:
Oppressive:
o Mr. Seruga has his coaching members very scared of him some even believe he is more powerful than the government and that speaking out will cause massive harm to them and their families
o Both the AWIT and BABB programs have a $7500 chargeback penalty meaning that if they attempt to issue a chargeback via their credit card company, they are legally obligated to pay Mr. Seruga $7500
o Many people have been kicked out of Mr. Serugas programs without a refund for asking probing questions. This happened on BABB and its predecessors, TMC and TMC2.
O A $5000 per instance penalty is included in Mr. Serugas created-after-the-fact T&C for speaking out about his programs.
Unscrupulous
o The programs have 6 month delayed refund clauses, making it difficult for many people to issue chargebacks when refund requests are finally denied
o Customers that signed up for the AWIT and BABB program saw no terms and conditions at the time of sale. However after the sale, terms and conditions were placed on the AWIT and BABB website, including the 6 month delay, $7500 chargeback penalty, and $5000 speaking publicly penalty
o The minimal traffic delivered by the AWIT program was reported to be very low quality, certainly not the same traffic that fortune 500 companies buy, as claimed in the signup process
Unethical
o Much of the BABB program consisted of Mr. Seruga reading word for word from $20 copyrighted books available from Amazon.com. A similar technique was also used during the TMC program.
O He also provided other ebooks and audios to all members, which we have later learned did not have licenses. We are aware these are not enforcement issues you take responsibility for, however we are including these for completeness.

While we are providing information about two of Mr. Serugas programs, BABB and AWIT, there have been many others we are aware of, which have left people equally unhappy, and that what we are reporting today is merely the tip of the iceberg. People often do not report their problems with Mr. Seruga due to the extreme intimidation from Mr. Seruga and his associates and their personal limited resources.

TMC, The Millionaire Club, was a program similar to BABB that was run in 2003. (see Appendix C)
TMCII, The Millionaire Club II (see EXHIBIT H)
Billionaire Entrepreneurs Summit (see Appendix D)
BusinessBuildersLeads.com, a program that went into litigation in 2004
Insiders Club, with Jay Abraham, an LA based marketer
Partners in Profits, with Jay Abraham, an LA based marketer, which has had problems
MaverickREI.com, his upcoming program

Mr. Seruga has also had several run-ins with the US criminal system on charges similar to the ones we are documenting today. (See EXHIBIT F)

While it is not our place to talk about an outcome from your organization, we would very much like to see Mr. Seruga and his associates barred via a consent decree, along with a suit filed for civil penalties and consumer redress so that we can receive our refunds.

This complaint is being filed jointly by 35 clients of Tony Seruga (names were delted from this post for privacy reasons)

Supporting Evidence
Digital Mavericks, Inc. Is incorporated in the State of Nevada, but listed with the BBB in the State of California at Digital Mavericks, Inc., 555 N. El Camino Real, #A-460, San Clemente, California, 92672

There are two programs that we know about, Build a Better Business, (BABB), and All I Want is Traffic (AIWIT).in selling the BABB program, he referred to it as Tony Serugas Millionaire Mavericks.

Although we do not know the total amount of money involved, we do know that approximately 50 people each paid $10,777.00 for the BABB program, for a total of approx. $538,000.00. For the AIWIT, the estimates are a little rougher, as we do not know how many people participated in that program. We do know the minimum purchase was $2,500.00. We also know that many people bought more than one slot up to a maximum of 5 slots, or $12,500.00. Tony reported on the internet that he sold out of 200 slots of that program within a couple of weeks. Doing the math there, and estimating the average purchase to be $5,000, that is at least an additional $1,000, 000.00 taken in. To further back up this estimate, we have a report from one of his former staff members, telling us that he took in $270,000 the first day the AIWIT program was offered.

Many of the BABB participants also bought into the AIWIT program, but in addition, there were many AIWIT buyers who did not participate in BABB. All totaled, we estimate 200 to 300 people were involved in one way or another. Most of the money was collected via the internet using either Paypal or credit cards.

Below is a description of each program:

BABB
This was a program where Tony Seruga promised to mentor a select group of 50 people with the end objective of helping each of them to build a $1,000, 000 business or greater. He had a very strong guarantee, which is described in EXHIBIT A, where he promised that he would either help us each to get our $1,000, 000 business, or he would have his staff BUILD IT FOR US.

The program was to take 26 weeks, and then he was to have our businesses built within 6 months after the 26 week program. It was supposed to start around May 1.

Included in this complaint are surveys completed by many of the BABB, AIWIT, and other former Tony Seruga victims voicing their dissatisfaction with the entire BABB program and with Tony Seruga personally. We have not found one single person who has received what was promised, and we have yet to find a single person who has received a voluntary refund by Tony Seruga. Several, who have voiced dissatisfaction with his programs have been threatened with various legal actions or kicked out of the programs without a refund.

It has now been over a year since it started, and not only has he not delivered, but contacting him or his staff is extremely difficult. Many of the victims have initiated chargebacks with their credit card companies, which are still pending, but many have been unable to do so because they paid via Paypal, and Paypal will only deal with a dispute within 45 days of the charge.

He promised for months to deliver a system that would allow us all to easily build the million dollar business. We have dozens of audio recordings with him voicing these promises, which were never delivered. It is a fact that he has never delivered the "system", nor anyones million dollar business.

Tonys refund policy, which was not shown at all, (as you can see in EXHIBIT B), in the initial sales letter prior to purchase is as follows. Also note, the sales letter was a PDF file, which cannot be altered, and you see not mention of terms and conditions. Thus, no one knowingly agreed to these terms. (See EXHIBIT B)

Not only were these terms and conditions NOT presented at the time of order, there are two key sets of terms that point to his expectations of unhappy clients, which thus leads one to conclude he knew exactly what he was doing right form the start, and had no intention of delivering on his promises.

Contained in EXHIBIT B is a clause that contains a $7500 penalty for initiating a chargeback.in EXHIBIT E, you see a clause that says you are not allowed to disparage Tony Seruga or any of his associates, no matter what, or you face a $5,000 penalty for each occurrence. Based on that condition alone, we would all be violating that by making this complaint.

Add the fact that these terms were essentially hidden from us at the time of purchase, and you get a man trying to pull a fast one.

Who does business that way? Only guys who are looking to steal from innocent people by using threats and intimidation to stop them form demanding that he actually deliver on his contract.

It is clear to us that these terms and conditions are written to make it next to impossible to obtain a refund which makes his refund guarantee essentially a joke.

AIWIT
This program was much more cut and dry. Tony promised to deliver targeted traffic, that was generated by emails that he or his traffic associates sent out with links that would bring an interested party back to our websites. (Traffic is visitors to a website.) The price was $. 05 per actual visitor to our site, sold in blocks of 50,000 for $2,500.00 each. He allowed any one person to purchase 5 blocks for a total of $12,500.00

This program was initiated in late January, and to date, we have yet to find a single person who has received the traffic as promised. A couple of guys got less than 500 leads, and then the traffic stopped. Most have not received a single visitor some 4 months after the purchase was made.

An email sent out to solicit sales is below: (See EXHIBIT C) The original sales page online has been removed by Tony.

With this program, Tony also claims to had terms and conditions attached to it that stated contained the same $7500 penalty for a chargeback shown in EXHIBIT B. He has used this clause to threaten several people who wanted a refund because they had not received traffic, and subsequently threatened to do a chargeback. One such threat can be seen in EXHIBIT D.

Note, just like in the BABB program, those terms and conditions cannot be seen anywhere in this offer. Plus, since we cannot even see a copy of the original offer, since Tony has removed it from view, it is our contention that we did not agree to those terms, and even if we did, complete failure to deliver a product would give anyone grounds to demand an immediate refund no matter what the terms and conditions.

In other words, he has not delivered a product, and then threatens people who want their money back. We dont believe anyone has the right to take a persons money do nothing to deliver on the good or services promised, and then threaten to sue a person for wanting their money back. This act seems criminal.

The bottom line is he is not delivering traffic per his agreement, and expects us all to let him get away with it.

Given all the problems, the group of dissatisfied customers is growing, and through some research, we have found that he has done this type of thing before.in he ran a program called the The Millionaires Club, which was very similar to BABB. We have a list of names and email addresses of members, and we have two people who actually worked with Tony during this time period who has said that there were 50 very unhappy clients then as well.in addition, they were both cheated out of thousands of dollars. They are both willing to testify against him.

Finally, with both the BABB program, and also the AIWIT program, Tony offered affiliates the opportunity to earn commissions by helping him to sell the programs. To date, we have not found anyone who has actually been paid any commissions.

There is speculation that he has lied about his personal financial status to gain our trust, (he told us that he was worth hundreds of millions of dollars), that he has lied about his income, about the number of multi-million dollar businesses that he owns (he claimed he had over 53 multi-million dollar businesses), about his traffic contacts and ability to generate traffic. He spoke often of the traffic mafia, but never told us how we could access this group (most likely a lie). It is also alleged by writers who own copyright protected material, that he used their material without permission and presented it as his own to the BABB group. Marketing Sherpa is a well known publisher, and they have told us specifically that they have not given Tony permission to distribute their materials, yet he has done so.

Through our research we have found that Tony has a track record of doing these types of things, and have found no one to date that will say they felt good about knowing Tony. For more commentary about Tony Seruga, go to http://www.tonyseruga. Blogspot.com/

We only represent a partial list of the total members who we know are also extremely dissatisfied with Tony Seruga. We do have a total list of email addresses for the BABB group which we can forward to you for you to interview each member individually.

Exhibit a

Excerpt from his sales letter (complete letter enclosed)

Yes, I will guarantee your success—HERES HOW: And as I said earlier, I am more than willing to guarantee your success.

What does that mean?

Simply put, it means if you actively participate in the full 26-week training, and you dont succeed in building a ultra-profitable, million-dollar, Internet-based business of your own within six months AFTER you complete the training, I will give you your money back.

Its just that simple.

I promise my team and I will do our part. All I ask is a sincere, good faith effort on your part. Just be on all the conference calls (or listen to the re-plays we post to the private website), invest a modest five to fifteen hours a week of your time, follow the stepby-
step instructions I give you (no short cuts, please) and do the
straightforward homework I ask.

Then, if youre not delighted with your a million-dollar business education, or if you not ecstatic with the kind of money youre making from the business, just send me a personal note telling me what you did and what happened, and Ill refund your money promptly. PLUS—If You Cant Do It, Ill Do It For You (My Ultimate Ill Prove it to You Guarantee)

Heres the BEST part of my extraordinary guarantee: To show you how serious and how certain I am of your ultimate success, in addition to refunding your money, if you cant make my training work for you, if you cant build a winning, ultra-profitable business WITHIN SIX MONTHS AFTER THE TRAINING ENDS:

I will start up your business for you—using the exact same principles you learned from me!

EXHIBIT B
4. The refund policy. If you are unhappy with the program, and wish to receive a refund, our requirement is very simple, and more than fair. You must have at least participated in all aspects of the program, and completed the full training, (due to the real world nature of this program, completion may take up to 12 months or longer), including all of the project assignments, i.E., all worksheets, homework, business audits, etc., etc. And during the six months following the conclusion of the program, you attempted to implement the training by following the step by step instructions contained in the outline provided. You must also request help as necessary and give Digital Mavericks, Inc. Every opportunity to assist you during that six month period of implementation. If the minimal conditions have been met, you may, in six months from the conclusion of the program, receive a FULL refund. Once again, this six month period allows you time to implement the training and systems in your own business and if you are serious about this program, is more than fair. At the conclusion of that six month implementation period, you then have 45 days to evaluate your results, and request a refund if you are not happy. During that 45 day period, simply send your refund request in writing, along with copies of all of your assignments to: Digital Mavericks, Inc., 555 N. El Camino Real, #A-460, San Clemente, California, 92672.
And, we'll even go one better, as you shall not only receive a FULL refund at that point, but you shall also receive an offer of collaboration, to help you achieve your financial goals. We shall require that we be paid for actual costs we incur, plus a reasonable percentage of the profits generated. You will also be allowed to keep the $5,000 Dan Kennedys Millionaire Entrepreneurs Library.
All transactions, moneys paid and all monthly dues paid are non refundable under any circumstances other than those described above under our official refund policy. Due to the nature of the materials and services offered, they are not returnable.
You agree not to stop payment or charge back PayPal, Visa, Mastercard, American Express, Discover or any other payment method under any circumstances. If you do, you also agree to waive your rights to defense and that you agree to immediately pay to Tony Seruga and Digital Mavericks Inc., the original amount of the charge back or stop payment, plus any additional outstanding payments due as well as a penalty of $7,500 USD. You agree that the court venue is in Orange County, CA should Tony Seruga and/or Digital Mavericks, Inc. Decide to bypass arbitration as described in paragraph 8.

EXHIBIT C
Subject: Thank You for Signing Up at All I Want Is TRAFFIC
Date: 23 Jan 00:55: 09 -0000
From: "All I Want Is Traffic"

Re: This is IMPORTANT! Please read this email immediately. It concerns your free VIP pass opportunity for your new "All I Want Is Traffic!" Co-Op.

Thank you for joining us and our notification list for your "All I Want Is Traffic!" Co-Op. This is a very smart move on your part.

Here's why...

For the person or company who wants a boatload of real traffic and doesn't have the time, skills or desire to work their fanny off to get it, this exclusive one-time opportunity is "as good as it gets."

As one of only 100 extremely fortunate Charter Members to have full access to this brand new Traffic Co-Op, you are 100% guaranteed to receive 50,000 high-quality, highly targeted real visitors to your website... For a price that is absolutely and completely irresistible.

NEVER before has anyone made this kind of a guarantee.

And as you're about to discover shortly, never before as anyone stepped up and offered to do 100% of the work for you, driving tens of thousands of real, live prospects straight to your site who are ready to see what you offer.

So now that you're on our private notification list, good job!

You should be congratulated on taking a critical first step.

But - that alone might not put you within striking distance of being able to sign up for this exclusive co-op opportunity when it becomes quickly available within the next few days.

Why? Because there WILL be a mad rush of thousands of people who will want to be guaranteed one of the only 100 extremely limited Charter Memberships.

Think about that: There are ONLY 100 positions available.

Let's be realistic. Given this incredible one-time opportunity, have you considered the real chances of you and only 99 other fortunate and decisive people getting in ahead of the tens of thousands of others who are just as determined as you are?

I'm sure you get the point.

So if you're really seriously considering the opportunity and you are determined to grab your position and ability to sign - up before these very scarce 100 Charter Membership units completely disappear, you'll surely want to use every advantage and tool at your disposal to stack the cards in your favor.

Agreed?

So here's how you can immediately tip the odds and stack the deck in your favor...

Get to work right now and secure one of less than a dozen available FREE "Front of the Line" VIP PASSES to our "ALL I WANT IS TRAFFIC!" Co-Op...

We want to get the word out about this extraordinary traffic co-op we're creating. The best part is we're willing to very generously reward you for your willingness and help in 'spreading the word' on our behalf.

Do this with us and you can WIN!!!

What do you have to do to get your own super-exclusive VIP PASS?

It's really very simple and super easy. Just enter the names and email addresses of 10 of your friends below - and when they opt-in and confirm via email their desire to join our notification list, you'll automatically be awarded one of the super-exclusive FREE "Front of the Line" VIP PASSES.

What are the benefits of having an exclusive VIP PASS in hand?

Number #1 - having a VIP PASS means you'll be one of the first people in line who has the opportunity to sign up for your exclusive 100-person-max traffic co-op.

You'll be given one full hour advanced access to the order page so that you can be one of the very first to sign-up before the stampede starts and it gets really crazy around here!

One full hour — before everyone else can even get in...

This is important because you should fully expect our co-op to fill up FAST. Our accurate expectation based upon initial feedback is that, most likely, within minutes of the doors opening and the order page being made initially available, we expect the traffic co-op to fully sell out and fill up so we'll have to quickly pull the order page offline.

Your BEST strategy, if you're determined to get in (and to make sure that you won't get unintentionally shutout), is to help us spread the word so you can 'cheat the line.'

When you help us, you'll have one of less than a dozen front-of-the-line access passes. You'll be guaranteed real access to being a part of this phenomenal traffic pricing deal before everyone else pulls the rug out from under you.

And if you'll remember the video, you know we're talking about buying $100 bills for $10 all day long...

When people see the incredibly low price to be a part of this one-time limited opportunity, you can bet the farm and be assured our exclusive traffic co-op will SELL OUT.

Of that, you can be certain. Bet the farm on it... Take it to the bank...

Number #2 - as you'll soon learn, the early bird "go getters" who sign-up the fastest will get preferential treatment from us once they are in the co-op. I cannot divulge the reasons now - and I'm not in a position to go into any of the details yet - but rest assured... This will be a very good thing for you when you are one of the first people to sign-up to be in this super-exclusive traffic co-op.

So simply enter the names and email addresses of 10 of your friends below, ones who you think would benefit the most from hearing about our unique traffic co-op.

Let us know who we can expect will want to be notified. Here's how to get started now: Click this link:

Http://www.alliwantistraffic.com/addmore/

When your friends join our private notification list with you, and then confirm their participation via email, you'll be given ONE FULL HOUR advanced notice before the general masses are allowed to even open the gate and peer inside...

And if you have more than 10 friends who you think would want to be a part of this opportunity, that's awesome. As you'll soon discover, there's a valuable prize on the way for the top five people who invite the largest number of friends.

So - tip the odds... Stack the deck... Cheat the line... And get a decidedly unfair advantage over everyone else today - right now.invite your 10 best marketing friends, and give yourself an "unfair advantage" over everyone else...

Grab one of the very few super-exclusive FREE VIP PASSES for yourself. Be selfish for a change; think about yourself first and consider all the others second...

[Although you'll also be doing a very nice favor for them, too! ]

Go ahead. Do it now before you forget by visiting:

Http://www.alliwantistraffic.com/addmore/

Thank You,

Your "All I Want Is Traffic" Co-Op Advance Team
http://AllIWantIsTraffic.com

PS: One last thing... You'll be personally notified via email when each of your friends signs up to be on our notification list. When your friends see our outrageous traffic offer, you going to be their best friend forever because you turned them on to such a great opportunity.

All I Want Is Traffic, LLC., 555 N El Camino Real, Suite A-460, San Clemente, CA 92672, USA

Exhibit d

Message to Rick Duris Tonys right hand man

Rick:

Your message was harsh, unkind and unempathetic of my situation.

I hope you know I would like nothing better than to reverse the chargeback and receive what I paid for - 50,000 quality visitors from you and your company. I have no expectations of what these visitors will do once they reach my site and I do not hold you or your company accountable for their actions, though your marketing material promised these visitors would be positively responsive.

Please understand that I'm just a poor marketer. Poor, but not stupid. Poor, but not a newcomer to online sales. After 10 years online I know how to track ads and visitors to a particular webpage.

How would you feel if you were in my situation?

Please simply begin sending the visitors as promised and re-examine your posture with a kind and
understanding heart.

Message from Rick Duris in response:

Rick Duris wrote:

I have been notified you have charged back your order. I want to let you know that if you proceed with the chargeback, you WILL be sued.
You are making a big mistake, it was a very bad idea. One that will have lasting consequences.
Here are the terms and conditions you signed up under. They are very clear:

Http://www.alliwantistraffic.com/liveoffer/warranties.html

When ordering Internet advertising (whether email, leads or actual Website visitors), you authorize All I Want Is Traffic, LLC Digital Mavericks, Inc. To immediately charge your credit card the total amount described in your order towards the purchase of
Internet advertising. You fully understand and accept All I Want Is Traffic, LLC Digital
Mavericks, Inc. No-refund and no-cancellation policies and further acknowledge that All I Want Is Traffic, LLC and Digital Mavericks, Inc. Does not provide any type of performance guarantee or return on investment. You further agree to unconditionally
repay these charges to your bank per the terms of your card holder service agreement.
You agree not to stop payment or charge back PayPal, Visa, Mastercard, American Express, Discover or any other payment method under any circumstances. If you do, you also agree to waive your rights to defense and that you agree to immediately pay to All I want IS Traffic, and/or Digital Mavericks Inc., the original amount of the charge back or stop payment, plus any additional outstanding payments due as well as a penalty of $7,500 USD. You agree that the court venue is in Orange County, CA.

You are being given 24 hours to reverse the chargeback, or we WILL enforce the above agreement and get a judgment, including the original amount plus the $7500 penalty.
We will win. We have won every case we have filed in the last nine years.
Then, we WILL go on to tag your permanent credit record and begin the collection process.
This will NOT go away. You will lose. You can count on it.
You have 24 hours.

Regards,

Rick Duris

EXHIBIT E
20. Non-Disparagement
You agree that you will not disparage anyone associated with the ALL I Want Is Traffic, LLC Advertising Co-Op, including All I Want Is Traffic, LLC, it's affiliate marketer Digital Mavericks, Inc., any of their affiliates, employees, officers, executives, directors, agents or their other customers/clients. This extends to any traffic brokers and/or partners.in the event you violates this paragraph, you acknowledges and agree that All I Want Is Traffic, LLC and their affiliates, including their affiliate marketer Digital Mavericks, Inc., will suffer damages that will be difficult to calculate and, for this reason, you agree that you will pay All I Want Is Traffic, LLC, and/or their affiliate marketer Digital Mavericks, Inc. The sum of Five Thousand Dollars ($5,000.00) per occurrence, as a penalty.

EXHIBIT F
The following is a list of cases involving Tony Seruga

Press Enterprise (Riverside, CA)

July 16,1997 wednesday riverside; hemet-san jacinto; moreno valley;san bernardino county

Section: local; pg. B02a

LENGTH: 249 words

HEADLINE: Man sought in business sign scam

BYLINE: The Press-Enterprise

BODY:
Riverside County sheriff's investigators are warning area businesses to be on the alert for a well-dressed, heavyset man they say is running a business sign scam.

Anthony Seruga identifies himself as a representative of an Irvine sign-making company, said Sgt. Mark Lohman of the Riverside County Sheriff's Department.

The salesman asks merchants if they want a sign made and installed for their business. When a contract is signed, he asks for a down payment. He then disappears with the money, Lohman said.

Two Jurupa-area businesses, one in Glen Avon and another in Rubidoux, have been hit, Lohman said.

The merchants were contacted in March by a man they identified as Seruga and signed contracts promising delivery three months later, Lohman said. When the merchants tried to contact Seruga's company, GEI Visual Display in Irvine, they were unsuccessful, he said.

"When he's supposed to deliver, he's nowhere to be found, "
Lohman said. The company was not at the address on the contracts, he said.

Seruga is described as a white male, 35 years old, 5 feet 10 inches tall and weighing more than 300 pounds. He has blue eyes, brown hair and is described as well dressed.

Lohman said he has an active felony warrant for forgery in San Bernardino County.investigators have been passing out fliers to Jurupa-area business owners, he said.

Anyone who may have information about Seruga is asked to call Detective Mike Markov at 275-2650.

Name: seruga, anthony j (male)

Consumer Name Last Updated: 2/28

Address:
1615 via calendula
san clemente, ca 92673-3734

Name: seruga, anthony j

Also Known As:
SERUGA, ANTHONY

Social Security Number: (REDACTED BY usacomplaints.com)

Address:
168 AVENIDA DEL MAR APT. 143
SAN CLEMENTE, CA 92672-4016
Address Updated: 10/1

Previous Addresses:
1301 FREMONT ST APT. 20
LAS VEGAS, NV 89101-5409
Address Updated: 7/13

124 E F ST APT. 15
ONTARIO, CA 91764-3749
Address Updated: 8/1

1042 N MOUNTAIN AVE APT. B458
UPLAND, CA 91786-3695
Address Updated: 11/13

2000 PARADISE RD
LAS VEGAS, NV 89104-2511
Address Updated: 7/18

15984 TYROL DR
FONTANA, CA 92337-7383
Address Updated: 7/18

Birthdate: 8/1961

Telephone: 732-0290

1.in Riverside, CA, in 1997, there was an arrest warrant filed for obtaining money under false pretenses:
Case RIM358571 Defendant 96028 SERUGA, ANTHONY JOSEPH

Arrest Charges
Count Charge Severity Description Violation Date Plea

1 PC M532 (A) M Obtain Money False Pretenses 05/28/1997

2.in San Bernadino, there were 5 cases against Mr. Seruga, including theft of personal property, forgery and a felony theft charge.

Case MSB032833 Defendant 18258 SERUGA, ANTHONY JOSEPH
Filed Charges
Count Charge Severity Description Violation Date Plea

1 pc m484 (a) m theft of personal property 06/20/1997 not guilty
2 pc m484 (a) m theft of personal property 06/20/1997

Case MSB033743 Defendant 18258 SERUGA, ANTHONY JOSEPH
Arrest Charges
Count Charge Severity Description Violation Date Plea

1 pc m484 (a) m theft of personal property 12/15/1997

Case FWV011144 Defendant 70658 SERUGA, ANTHONY JOSEPH

Arrest Charges
Count Charge Severity Description Violation Date Plea

1 pc 470 (a) f forgery 02/13/1996

Case MVA014385 Defendant 91619 SERUGA, ANTHONY JOSEPH
Arrest Charges
Count Charge Severity Description Violation Date Plea

1 PC M647 (F) M DISORDERLY CONDUCT: PERSON UND INFLUENCE OF ALCOH/DRUGS 08/02/1996
Case MRE07366 Defendant 128302 SERUGA, ANTHONY JOSEPH
Arrest Charges
Count Charge Severity Description Violation Date Plea

1 pc 484 (b) f theft: nonreturn of rental prop (over $400) 02/13/1997

3.in Orange county, he and his wife have been defendants in a breach of contract civil case:
CASE SUMMARY
Case No. Case Title Case Type Filing Date Category
04CC10224 BLACKMNAN VS SERUGA BREACH OF CONTRACT/WARRANTY 10/08 CIVIL



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