UNITED
STATES DISTRICT COURT Magistrate Judge Seltzer FEDERAL TRADE COMMISSION, Plaintiff, v. DIANE M. JONAS, individually and as a principal of The Business Opportunity Center, Inc.; PAUL A. JONAS, individually; JAMES W. RAIM, individually and as a partner in Market Systems, Ltd.; ROBERT BRIAN ROEMER, individually and as Treasurer of The Business Opportunity Center, Inc.; THE BUSINESS OPPORTUNITY CENTER, INC., a Florida corporation, d/b/a The Neutralizer; MARKET SYSTEMS, LTD., an Illinois partnership; NATURAL HEALTH SYSTEMS, INC., an Illinois corporation; PROGRESSIVE PRODUCTS, INC., an Illinois corporation; TAMI BRENNAN McCLURE, individually and as an officer of Natural Health Systems, Inc., and partner in Market Systems, Ltd.; PAUL S. JANUS, individually and as an officer of Progressive Products, Inc., and a partner in Market Systems, Ltd.; and RICHARD A. HERBERT, M.D., individually and as a partner in Market Systems, Ltd.; Defendants. CIV 95-8429-ZLOCH PLAINTIFF'S MOTION TO AMEND COMPLAINT Pursuant to Federal Rule of Civil Procedure 15(a), Plaintiff Federal Trade Commission requests permission to amend its original complaint, which was filed on July 10, 1995. The amended complaint joins six additional defendants who, in concert with the five defendants originally named, engaged in deceptive acts or practices in violation of Section 5(a) of the Federal Trade Commission Act, 15 U.S.C. 45(a). In support, the Commission references its memorandum filed in support of its application for a second ex parte temporary restraining order, which was filed contemporaneously with this motion. Respectfully Submitted, STEPHEN CALKINS LAWRENCE H. NORTON _________________________ |