MAR/07/2013/THU 10:59 AM Circuit Clerk FAX No. 217 747 5105 P. 00 l/00 I

STATE OF ILUNOIS IN THE CIRcmT COURT OF UlE SEVENTH JUDICIAL CIRCUIT

SANGAMON.COUNTY

THE PEOPLE OF THE STATE OF ILLINOlS,

Plaintiff,

.-vs-I

DICK VAN DYKE FINANCIAL, LTD. and

) ) ) ) ) ) ) ) ). ) ) )

NO. tJ 2. 0 1 3 c. H 0 0 2 0 71

RlCHARD LEE VAN DYKE, JR, individually and as President of DICK VAN DYKE FINANCIAL, LTD.

Defend~ts-

COMPLAINT FORINJUNCfiVE.AND OTHER RELIEF

NOW COMES the pl~tiff, THE PEOPLE OF THE S'l'ATE OF ILUNOIS, by LISA MADIGAN,

Attorney General of the State of illinois, and bx:ings this action for injunct:i.'9'e and other relief against

defendants, DICK vAN om FINAN~ LTD. ~d ru~ LEE VAN nYn:, .rlt, for vi~lations of . .

the illinois Consumer Fraud and Deceptive Business Practices Act, 815 ILCS 505/1 et seq. and the

Uniform Deceptive Trade Practices Act, 815 ILCS 510/1 et seq.

PUBLIC INTEREST

1. The Illinois Attorney: General believes this action to be in the public interest· of the citizens of the

State of Ulinois and brings this lawsuit pursuant to the illinois Consumer Fraud and DeceptiVe Business I . . .

Practices Act, 815 ILCS 505/j(a) ,and the Dnifonn Deceptive Trade Practices Act, 815 ILCS 510/1 et seq.

JURISDICTION AND VENUE

2. This action is brought for and on behalf ofTaE PEOPLE OF THE STATE OF ILUNOIS, by USA

MADIGAN, Attorney Genera1 of the State of illinois, pursuant to the proviSions of the Consumer Fraud I •

and Deceptive :Susiness Prac~ces Act ("Consumer Fraud Act"), 815 :rr:.c.s·sos/dJtseq. ab.dth~ Uniform

Deceptive Trade Pl'actices Act, 8~5 IJ,.CS 510/1 et seq. and her common law authority asAti:orneyCeneral . !

to represent the People of th~ State of Illinois. .. ·' .. : :.

3. Venue for this action; properly lies in Sangamon County, Illin6~; ptirsuant to S~ctiona 2~io.1 and 2-

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102 of the Illinois Code of Civil Procedure, 735 ILCS 5/2-101 and 2-102, in that Sangamon County

is the Defendants' county of residence.

PARTIES

4· Plaintiff, THE PEOPLE OF THE STATE OF ILLINOIS, by LISA MADIGAN, the Attorn~y General

of the State of Illinois, is authorized to enforce the Consumer Fraud Act and the Uniform Deceptive Trade

Practices Act.

5. Defendant, Dick Van Dyke Financial Ltd., is an Illinois corporation with its principal place of

business at 1028 S. Walnut Street, Springfield, IL. 62704.

6. For purposes of this Complaint for Injunctive and Other Relief, any references to the acts and

practices of Dick Van Dyke Financial, Ltd. shall mean that such acts and practices are by and through the

acts of Dick Van Dyke Financial, Ltd.'s officers, owners, members, directors, employees, salespersons,

representatives and/or other agents.

7· The defendant, Richard Lee Van Dyke, Jr., is sued individually and in his capacity as

President of Dick Van Dyke Financial, Ltd.

8. The defendant, Richard Lee Van Dyke, Jr. formulated, directed, controlled and had knowledge

of the acts and practices of the defendant, Dick Van Dyke Financial, Ltd. and, at all times relevant hereto,

was President of defendant Dick Van Dyke Financial, Ltd.

g. To adhere to the fiction of separate corporate existence between the defendant, Richard Lee Van

Dyke, Jr. and Dick Van Dyke Financial, Ltd. would serve to sanction fraud and promote injustice.

TRADE AND COMMERCE

10. Subsection 1(f) ofthe Consumer Fraud Act, 815 ILCS 505/l(f), defines "trade" and "commerce" as

follows:

The terms 'trade' and 'commerce' mean the advertising, offering for sale, · sale, or distribution of any services and any property, tangible or intangible, real, personal, or mixed, and any other article, commodity, or thing of value wherever situated, and shall include any trade or commerce directly or indirectly affecting the people of this State.

11. The Defendants, Dick Van Dyke Financial, Ltd. and Richard Lee Van Dyke, Jr. were at all

times relevant hereto engaged in trade and commerce in the State of Illinois by advertising,

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offering for sale, selling and accepting money for insurance products.

SUMMARY

Defendant Dick Van Dyke engages in a pattern of conduct whereby he gains the trust of

senior citizens by holding himself out as an objective, knowledgeable and unbiased financial

services expert for consumers facing retirement, when in fact his undisclosed agenda is to sell

deferred annuities as a one-size-fits-all financial solution for senior citizens. Through at least July

31, 2012, Defendants' website www.dickvandykefinancial.com employed multiple marketing

strategies and statements to portray Defendant Dick Van Dyke as a financial services provider

with specialized expertise in advising elderly consumers facing retirement in a full range of

financial, legal, and tax, and related matters. For example, the Mission Statement on Defendants'

website states: "Our Mission: Assist our clients in achieving their goals and objectives by

integrating all aspects of their financial well being; including estate, investment, insurance, legal,

and tax strategies. We assist them in gaining clarity amidst a world of increasing complexity. We

serve as our client's Financial Quarterback by assisting them with a successful team approach."

Despite representations of providing a full range of financial and other services, since January

2012, Defendants Dick Van Dyke Financial, Ltd. and bick Van Dyke have been licensed only as

an insurance agency and producer respectively.

DEFENDANTS' UNFAIR AND DECEPTIVE BUSINESS PRACTICES

12. Defendants solicit consumers through two websites, www.dickvandykefinanical.com and

www.annuitvratesinstantly.com.

13. Defendant Dick Van Dyke failed to renew his registration as an investment advisor for

securities effective December 31, 2011, purportedly to avoid conflicts of interest and the burden of

increasing regulatory requirements imposed on the securities industry by the new Dodd-Frank

legislation. According to his website, www.dickvandykefinanical.com, this decision allowed him to

focus on the relevant financial service needs of his clients.

14. Since July 2005 to the present, Dick Van Dyke has held an Illinois insur~nce producer

license, as well as individual non-resident insurance agent licenses in other states.

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.,

15. Since November 2005 to the present, Dick Van Dyke Financial, Ltd. has held an Illinois

Insurance Agency License.

16. Upon information and belief, there are only two employees of Dick Van Dyke Financial,

Ltd., Defendant Dick Van Dyke and his wife, Alma Van Dyke, who serves as office manager.

-17. Between the time period of January 2012 through at least July 31,2012, a virtual

spokesman appeared when visitors first visit www.dickvandykefinanical.com. During the relevant

time period, the virtual spokesman stated as follows:

"If you want a successful financial plan these days, you need a financial advisor you can

really trust. You need to know as much as you can about that person's credentials, background, and

certification. So on this site, you'll find third party reports about Dick Van Dyke such as the Better

Business Bureau, Society of Certified Senior Advisors and the National Ethics Bureau's extensive 7

year background check. Make sure you check out the validation documents, disclosures, and

references which is near the middle of this page. He believes in' principles like full disclosure and

transparency and he doesn't sell investments on commission which means he's on your side so you

get to reach your goals first before he does. When's the last time ~n investment advisor put you

first?"

18. The claim that Defendant Dick Van Dyke does not sell investments on commission is

deceptive because the vast majority of his business is the sale of deferred annuities that are sold on

commission.

19. Over 90% of defendants' business involve commission based annuity sales, which includes

sales of replacement annuities.

20. The representation by the virtual spokesman that Defendant Dick Van Dyke is an

investment advisor is deceptive because during the relevant time period of January 2012 to at least

Jule 31, 20I2, Dick Van Dyke was not a registered investment advisor as required by the Illinois

Securities Act.

21. The certification by the Society of Certified Senior Advisors referenced by the virtual

. spokesperson is a purported credential intended to convey expertise in senior financial matters.

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·.

22. Defendants' inclusion of this purported credential is deceptive because this designation

does not qualify a person to provide investment advice under Illinois law (14 Ill. Admin.

Code, Part 130 (Use of Senior Certifications and Professional Designations).

23. In fact, the Certified Senior Advisor designation is obtained by paying a fee to take either a

three and a half day live course, or a home study course, followed by a multiple choice

examination. Part of the study includes marketing to seniors. This purported credential is obtained

primarily for marketing purposes to earn the trust and confidence of seniors. . .

24_. The certification by the National Ethics Bureau referenced by the virtual

spokesperson is a purported credential intended to promote trust and gain confidence.

25. Defendants' inclusion of this purported credential is deceptive because National Ethics

Bureau is a Colorado based for-profit organization with sponsors, many of which appear to be in

· the annuity and insurance industry. Once again, this purported credential was developed primarily

for marketing purposes. No education or exam is required, and there are no continuing education

requirements.

26. Another purported credential displayed on the Defendants' website under validation

do~uments, is that of Certified Annuity Advisor.

27. Defendants' inclusion of this purported credential is deceptive because the issuing entity is

no longer in existence, and the original certification did not require any continuing education or

provide a complaint process once an individual was certified. Once again, this purported credential

was a marketing tool for gaining trust and confidence of older consumers.

28. Defendant Dick Van Dyke also displays an "ARI Code of Ethics and Requirements" on

the website www.dickvandykefinancial.com under validation documents. "ARI" stands for

Annuity Rates Instantly, the name of another website that Defendant Dick Van Dyke purportedly

owns, created, and operates.

29. Defendants' inclusion of the purported credential, ARI Code of Ethics and Requirements,

is deceptive because no education or exam is required, no complaint process is in place, and it is a

self-conferred credential. This document was created by Defendant Dick Van Dyke to gain the

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trust and confidence of older consumers.

30. Defendant Dick Van Dyke states in the disclosure section of his website that he "earns

commissions as mandated by state law on insurance products." This is deceptive because there is

· considerable flexibility under the Illinois Insurance Code as to how producers are paid. Some use

salary type arrangements, particularly where the producer is just starting out.

31. Defendants' website section "Our Firm" contains a section titled "Meet Our Financial

Team."

32. Here, Defendant Dick Van Dyke makes the unsubstantiated claim that he conducts

workshops for individuals and other advisors on the internet or in a classroom setting, available by

invitation.

33. Defendant Dick Van Dyke makes an additional claim as follows: "Recognized as an advisor

on retirement issues, Dick, utilizing his business and financial experience, assists retirees with

their concerns in retirement by helping them preserve assets with growth and an increasing

income, while avoiding unnecessary estate and income tax issues." This is deceptive because,

despite representations of providing a full range of financial services, since January 2012,

Defendant Dick Van Dyke has been licensed only as an insurance producer.

34. In the relevant tiine period, under the section "Meet Our Financial Team," Defendants'

website identifies Matt Neuman as Marketing Vice President. This is deceptive because Matt

Neuman is not and has never been employed by Defendants. In fact, Matt Neuman is Vice

President of Marketing at Advisors Excel, LLC an insurance field marketing organization located in

Topeka, Kansas.

35. On Advisors Excel, LLC's website, www.advisorsexcel.com, Mr. Neuman is described as

one of the most successful annuity marketers in the country who has been an integral part of

developing Advisors Excel into a $2 billion firm ip.just 5 years. In truth and in fact, Mr. Neuman

and his organization provide the Defendants with tools and strategies to "keep improving numbers

and profits" from the sale of annuities. Moreover, according to its website, Advisors

Excel operates exclusively on a commission basis from producers like Mr. Van Dyke, who have

Page 6 of 14

agreements with Advisors Excel.

36. In the relevant time period, under the section "Meet Our Financial Team," Defendants'

website identifies Melinda Graham as Sales Coordinator. This is deceptive because Melinda

Graham is not now and has never been employed by Defendants. In fact, Ms. Graham is Sales

Coordinator at Advisors Excel, LLC, an insurance field marketing organization located in Topeka,

Kansas.

37· On Advisors Excel, ~LC's website, www.advisorsexcel.com, Ms. Graham is described as a

sales coordinator who partners with Matt Neuman to bring a high service level and deepen the

relationships with the producers they work with on a daily basis.

38. Defendants' website during the relevant time period identifies office locations as a main

branch at 1028 South Walnut, Springfield, IL, and other branch locations at 700 Commerce Drive,

Suite 500, Oak Brook, IL (Chicago Branch) and· at 111 West Port Plaza, 6th Fl., St. Louis, MO 63146

(St. Louis Branch). This is deceptive because Defendant did not maintain branch offices in St.

Louis, MOor Chicago, IL as represented. The St. Louis and Chicago addresses were merely

locations where space could be rented oh an as needed basis.

39. On Defendants' website, consumers are offered a complimentary social security

consult~tion. The consultation involves obtaining detailed information about consumers; income

and assets, purportedly for retirement planning purposes. Defendant Dick Van Dyke fails to

disclose to seniors that the true purpose of this consultation is to qualify the consumers as a

prospect for selling insurance products, particularly deferred annuities.

40. The social security website, www.socialsecurity.gov provides information, calculators, and

links to websites that provide essentially the same information that Defendant Dick Van Dyke

offers in his free social security consultations.

41. The representations cited above, on which Defendants intend consumers will rely, as well

as others on Defendants' website, lead consumers to believe Defendant Dick Van Dyke is an

objective, knowledgeable and unbiased financial services expert for consumers facing retirement,

when in fact he is an insurance salesman.

Page 7 of 14

42. Beginning in 2006, Defendant Richard Lee Van Dyke, Jr. also solicited consumers 55 and

older through events described as educational seminars offering a free meal or refreshments held

at local hotels, restaurants, and other venues

43. As a result of attendance at such events, some consumers purchased deferred indexed

annuities, including replacement annuities, from Defendants.

44. An invitation to such an event held in 2009 is attached hereto as Exhibit A. Among other

things, the invitation, titled Stealth Tax Bill Hits Millions of Unsuspecting Retirees, states:

This Seminar Is:

NOT a sales seminar

·NOT an annuity presentation

NOT a Free meal come-on to get you to buy something

45· · These statements are deceptive, because the true purpose of the event was to schedule and

make individual sales presentations for deferred indexed annuities to attendees.

COUNT I-CONSUMER FRAUD AND DECEPTIVE BUSINESS PRACTICES ACT

APPLICABLE STATUTE

46. Section 2 of the Consumer Fraud and Deceptive Business Practices Act, 815 ILCS 505/2,

provides:

Unfair methods of competition and unfair or deceptive acts or practices, .

including but not limited to the use or employment of any deception, fraud, false

pretense, false promise, misrepresentation or the concealment, suppression or

omission of any material fact, with intent that others rely upon the concealment,

suppression or omission of such material fact, or the use or employment of any

practice described in Section 2 of the 'Uniform Deceptive Trade Practices Act',

approved August 5, 1965, in the conduct of any trade or commerce are hereby

declared unlawful whether any person has in fact been misled, deceived or

damaged thereby.

VIOLATIONS

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CONSUMJE~ lFJRAUD AND ])JECJElPTJME BUSJINJESS lP'lRAC'f][CJES ACT

47·. The People re-allege and incorporate by reference the allegations in Paragraphs 1 to 45.

48. While engaged in trade or commerce, the Defendants have committed unfair and deceptive acts or

practices declared unlawful under Section 2 of the Consumer Fraud Act, 815 ILCS 505/2, by:

A. representing, expressly or by implication, after January 1, 2012, that

Defendants do not sell investments on commission, when in fact the vast majority of the

investment products sold by Defendants are sold on commission;

B. representing, expressly or by implication, that Defendant Dick Van Dyke is

a registered investment advisor, when in fact he was not registered as such during the time

period relevant to this complaint;

C. representing, expressly or by implication, that the Certified Senior Advisor

credential qualifies Defendant Dick Van Dyke to provide investment advice to seniors,

when in fact it does not and instead is primarily a marketing tool;

D. representing, expressly or by implication, that the National Ethics Bureau

credential qualifies Defendant Dick Van Dyke as a professional seniors can trust, when in

fact it is primarily a marketing tool created by the insurance industry;

E. representing, expressly or by implication, that the Certified Annuity

Advisor credential qualifies Defendant Dick Van Dyke to provide investment advice about

annuities to seniors, when in fact it does not and the issuing entity is no longer in

existence;

F. representing, expressly or by implication, that the "ARI Code of Ethics and.

Requirements" credential qualifies Defendant Dick Van Dyke as a professional seniors can

trust, when in fact it is primarily a marketing tool created by the Defendant Dick Van Dyke

himself;

G. representing, expressly or by implication, that Defendant Dick Van Dyke

conducts workshops for individuals and other advisors on the internet or in a classroom

setting, without any basis for such representation;

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H. representing , expressly or by implication, that state law mandates that

Defendant Dick Van Dyke be paid commissions for selling insurance products, when in fact

such is not the case;

I. representing, expressly or by implication, after January 1, 2012, that

. Defendant Dick Van Dyke provides a full range of investment, tax and estate assistance to

seniors, when in fact Defendant Dick Van Dyke was only licensed to sell insurance products

in the time period relevant to this complaint;

J. representing, expressly or by implication, that Matt Neuman is Vice

President of Marketing for Defendant Dick Van Dyke Financial, when in fact Matt Neuman

is not now and has never been employed by Defendants.

K. repres~nting , expressly or by implication, that Melinda Graham is Sales

Coordinator for Defendant Dick Van Dyke Financial, when in fact Melinda Graham is not

now and has never been employed by Defendants; and

L. failing to disclose clearly aild conspicuously to consumers the materi~l fact

that the purpose ofthe offer for a free social security consultation is to qualify the consumer

as a prospect to sell insurance products.

M. failing to disclose clearly and conspicuously to consumers the material fact

that attendance at an educational seminar may result in a sales presentation for annuities

and other insurance products.

REMEDIES

49. Section 7 of the Consumer Fraud and Deceptive Business Practices Act, 815 ILCS 505/7, provides:

(a) Whenever the Attorney General has reason to believe that any person is using, has

used, or is about to use any method, act or practice declared by the Act to be unlawful,

and that proceedings would be in the public interest, he may bring an action in the

name of the State against such person to restrain by preliminary or permanent

injunction the use of such method, act or practice. The Court, in its discretion, may

exercise all powers necessary, including but not limited to: injunction, revocation,

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forfeiture or suspension of any license, charter, franchise, certificate or other evidence

of authority of any person to do business ·in this State; appointment of a receiver;

dissolution of domestic corporations or association suspension or termination of the

right of foreign corporations or associations to do business in this State; and

restitution.

(b) In addition to the remedies provided herein, the Attorney General may

request and this Court may impose a civil penalty in a sum not to exceed $so,ooo

against any person found by the Court to have engaged in any method, act or practice

declared unlawful under this Act. In the event the court finds the method, act or

practice to have been entered into with intent to defraud, the court has the authority to

impose a civil penalty in a sum not to exceed $so,ooo per violation.

(c) In addition to any other civil penalty provided in this Section, if a person is

found by the court to have engaged in any method, act, or practice declared unlawful

under this Act, and the violation was committed against a person 65 years of age or

older, the court may impose an additional civil penalty not to exceed $10,000 for each

violation.

so. Section 10 of the Consumer Fraud Act, 815 ILCS 505/10, provides that "in any action brought

under the provisions of this Act, the Attorney General is entitled to recover costs for the use of this State."

PRAYER FOR RELIEF-COUNT I

WHEREFORE, the plaintiff prays that this honorable Court enter an Order:

A. Finding that the defendant has violated Section 2 of the Consumer Fraud and Deceptive

Business Practices Act, 815 ILCS 505/2, by but not limited to, the unlawful acts and practices alleged

herein;

B. Preliminarily and permanently enjoining the defendant from'engaging in the deceptive

and unfair practices alleged herein;

C. Disgorging from the defendants all commissions earned from replacement annuity sales;

D. Assessing a civil penalty in the amount of Fifty Thousand Dollars ($so,ooo) if the Court

Page 11 of 14

finds the Defendant has engaged in methods, acts, or practices declared unlawful by the Act without the

intent to defraud, if the Court finds Defendant has engaged in methods, acts or practices declared . unlawful by the Act with the intent to defraud, then assessing a statutory civil penalty of $50,000, all as

provided in Section 7 of the Coi_lsumer Fraud Act, 815 ILCS 505/7;

E. Assessing an additional civil penalty in the amount ofTen Thousand Dollars ($10,000)

per violation of the Consumer Fraud Act found by the Court to have been committed by the Defendant

against a person 65 years of age and older as provided in Section 7(c) of the Consumer Fraud Act, 815

ILCS 505/?(c);

F. Requiring the defendant to pay all costs for the prosecution and investigation of this

action, as provided by Section 10 of the Consumer Fraud Act, 815 ILCS 505/10; and ·

G. Providing such other and further equitable relief as justice and equity may require.

COUNT II- UNIFORM DECEPTIVE TRADE PRACTICES ACT

51. Plaintiff re-alleges the allegations contained in paragraphs 1 through 45 above.

APPLICABLE STATUTE

52. Section 2 of the Deceptive Trade Practices Act provides in relevant part:

. (a) . A person engages in a deceptive trade practice when, in the course of his or her

business, vocation, or occupation, the person:

***

(5) represents that goods or services have sponsorship, approval . · ..

that they do not have or that a person has a sponsorship, approval, status, affiliation, or

connection that he or she does not have;

(b) In order to prevail in an action under this Act, a plaintiff need not prove competition

between the parties or actual confusion or misunderstanding.

VIOJLATIONS

53. Defendants, in connection With the advertising, offering for sale, and selling of financial

services, have represented that their financial services have a status or affiliation which they do not have

violation of section 2(a)(5 ) of the Deceptive Trade Practices Act by representing, expressly or by ·

Page 12 of 14

implication:

a. that Defendant Dick Van Dyke is a registered investment advisor, when in fact such is not the case;

and

b. that Defendant Dick Van Dyke is an objective, knowledgeable and unbiased financial services expert

for consumers facing retirement, when in fact Defendant is simply an insurance salesman whose

primary business is to sell deferred annuities as a one-size-fits-all financial solution for senior

citizens.

REMEDIES

54· Section 2 of the Deceptive Trade Practices Act is recognized as a prohibited practice to be

treated similarly to prohibited practices under section 2 of the Consumer Fraud Act:

Unfair methods of competition and unfair or deceptive acts or

practices ... or the use or employment of any practice described in

section 2 of the 'Uniform Deceptive Trade Practices Act,' [815 ILCS

510/2 et seq ... .in the conduct of any trade or commerce are

Hereby declared unlawful whether any person has in fact been

misled, deceived or damaged thereby ... Sis ILCS 505/2.

55· Since section 2 of the Deceptive Trade Practices Act is treated the same as a violation

of section 2 of the Consumer Fraud Act, the rights and remedies available to the Attorney General

under the Consumer Fraud Act, are similarly available to the court to remedyviolations of the

Uniform Trade Practices Act.

PlRAYER FOR RELIEF-COUNT II

56. WHEREFORE, the plaintiff prays that this honorable Court enter an Order:

A. Finding that the defendants have violated sections 2(a)(5) of the Deceptive Trade Practices

Act, as described herein;

B. Enjoining the defendants from engaging in the business of advertising, offering for sale,

selling and accepting money for insurance products, in violation of the Deceptive Trade Practices Act;

C. Disgorging from the defendants all commissions earned from replacement annuity sales;

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D. Assessing a civil penalty in the amount of Fifty Thousand Dollars ( $50,000) per violation ·

of the Deceptive Trade Practices Act found by the Court to have been committed by the defendants with

the intent to defraud; if the Court finds the defendants have engaged in methods, acts or practices declared

unlawful by the Act, without the intent to defraud, then assessing a statutory civil penalty of Fifty Thousand

Dollars ($50,000), all as provided in section 7 ofthe Consumer Fraud and Deceptive Business Practices

Act (815 ILCS 505/7);

E. Assessing an additional civil penalty in the amount of Ten Thousand Dollars ( $10,000) per

violation of the Deceptive Trade Practices Act found by the Court to have been committed by the

defendants against a person 65 years of age and older as provided in section 7(c) of the Consumer Fraud

and Deceptive Business Practices Act, 815 ILCS 505/?(c);

F. Requiring the defendants to pay all costs for the prosecution and investigation of this

action, as provided by section 10 of the Consumer Fraud and Deceptive Business Practices Act ( 815 ILCS

505/10); and

E. Providing such other and further equitable relief as justice and equity may require.

Respectfully submitted,

THE PEOPLE OF THE STATE OF ILLINOIS, by LISA MADIGAN, ATTORNEY GENERAL OF ILLINOIS

c

tlv~1~kJ~ -)~~A~~ Elizabeth Blackston

~~r Fraud Bureau, Chief.

Clf.J.-et?.Gt{;)jwxlt · R'ebecca Pruitt (ARDC #6209774) Assistant Attorney General Consumer Fraud Bureau 500 South Second Street Springfield, IL 62706 Telephone: (217) 782-4436

Page 14 of 14

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OJ/ou am flo~ .Yn/Otted to~ .

AN INFORMATIVE AND ENTERTAINING EVENT

FoRADULTs 55 AND OVER

{~',....-----.. " PLANTIFF'S

EXHIBIT A Page 1 of 2

- -- ·-·---·-----------------------------

..

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This Seminar:

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• Is the easiest way for you to learn all about the inner secrets used by the "Rich" to eliminate significant taxes during your retirement .

This Seminar Is:

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• NOT an annuity presentation

• NOT a Free meal come-on to get you to buy something

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'Light refreshments will be served ____ :...._ .. _.,. -:. -.:: L..~- __ ,_,...:.~:-· ~-.:;::- :-;-:-..:....:-: ;-_,· ,·.: ... ~ ·-·.

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'.:..· PLANTIFF'S EXHIBIT A Page 2 of 2

STATE OF ILLINOIS IN THE CIRCUIT COURT OF THE SEVENTH JUDICIAL CIRCUIT

SANGAMON.COUNTY

THE PEOPLE OF THE STATE OF ILLINOIS, ) ) ) )

Plaintiff,

-vs- ) NO. )

DICK VAN DYKE FINANCIAL, LTD. and )

RICHARD LEE VAN DYKE, JR., individually and j I 2 0 1 3 c H 0 0 2' 0 7J ) as President of DICK VAN DYKE FINANCIAL, LTD. )

Defendants. )

To each defendant: Dick Van Dyke Financial, LTD.

YOU ARE SUMMONED and required to~le an answer .to the complaint in this case, a copy of which is hereto attached, or otherwise file yo'tir appearance, in the office of the clerk of this court, 200 South 91

h Street, Room 405, Springfield, Illinois 62701, Within 30 days after service of this summons, not counting the day of service. IF YOU FAIL TO DO SO, A JUDGMENT BY DEFAULT MAY BE ENTERED AGAINST YOU FOR THE RELIEF ASKED IN THE COMPLAINT.

To the officer: please serve the Defendant's business agent Richard Lee Van Dyke at 1028 South Walnut, Springfield, Illinois.

Name Attorney for Addre.ss City Telephone

Rebecca Pruitt Plaintiff 500 South Second Street Springfield, IL 62706 (217) 782-4436

(i i. Clerk of the CoUrt

Associate.Circuit Clerk- Int. Deputy

Date of service: , 2013. (To be inserted by officer on copy left with defendant or other person)

STATE OF ILLINOIS IN THE CIRCUIT COURT OF THE SEVENTH JUDICIAL CIRCUIT

SANGAMON COUNTY

THE PEOPLE OF THE STATE OF ILLINOIS, ) ) ) ) ) ) ) ) ) ) ) )

Plaintiff,

-vs- NO.

DICK VAN DYKE FINANCIAL, LTD. and

RICHARD LEE VAN DYKE, JR, individually and · as President of DICK VAN DYKE FINANCIAL, LTD.

~·20 13CH00207J

Defendants.

SUMMONS

To each defendant:· Richard Lee Van Dyke, Jr.,_ individually and as President of Dick Van Dyke Financial, LTD.

YOU ARE SUMMONED and required to file an answer to the complaint in this case~ a copy of which is hereto attached, or otherwise file your appearance, in the office of the clerk of this court, 200 South 9th Street, Room 405, Springfield, Illinois 62701, within 30. days after service· of this summons, not counting the day of ser\rice. IF YOU FAIL TO DO SO, A .Jl!DGMENT BY

. DEFAULT MAY BE. ENTERED AGAINST YOU FOR THE RELIEF . ASKED IN THE COMPLAINT.

To the officer: please serve the Defendant at i028 South Walnut, Springfield, Illinois.

This summons must be returned by the officer or other person to whom it was given for service, with endorsement of service and fees,ifaby, immediately after service. If service cannot be made, this summons shall be returned so endorsed. This summons may not be served later than 3 0 d aft · d l,\umnu,,,,

ays er Its ate. MAR 0 7 2013 ~'''''''lUDic/''''"·:-.

Name Attorney for Address City Telephone

Rebecca Pruitt Plaintiff 500 South Second Street Springfield, IL 62706 (217) 782-4436

WITNESS, ' .... ~~ C\ 2013. 4-,;/';~t..~ l: ~~ ,~ . .-··\

,.. ~~ ~. ~~~ J

Clerk of the Court \,c;,~\ -,')/,, .> ~':c~ o"''"'"""""'"" ~ .

"~~ .. , couN\'f .. -',J]'''rnrnu ;~~· ~~\..,.,\t~

Associate Circuit Clerk - Int. Deputy

Date of service: , 20 13 .. (To be inserted by officer on copy left with defendant or otm~r person)· ·