National Association for Members [ NAM ]

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then failing to do so;

  1. failing and refusing to maintain Willow Creek campground to the minimum standard required to comply with the Campground Licensing and Recreational Area Act;

  2. operating a campground/Willow Creek Resorts without a Recreational Area license; and

  3. selling campground memberships and membership upgrades without having a Recreational Area license for such campground.

B. RESTITUTION

The Court enters a judgment, as and for restitution, in favor of the Plaintiff and against the Defendants in the amount of Twenty Five Thousand Dollars and no/100 ($25,000.00). Such amount shall be utilized to pay restitution to the consumers identified in attached Exhibit 1. The check or money order shall be made payable to the "Illinois Attorney General Consumer Trust Account".

The judgment in this matter shall be paid off within thirty (30) days of the Willow Creek Resorts property, with a physical address of 3905 South Bend Road, Rockford, Illinois, being sold by the Defendants. Defendants shall notify the Plaintiff in writing within fourteen (14) calendar days of the sale date that the Willow Creek Resorts property has been sold. Such written notice shall be addressed to the Plaintiff as follows: Illinois Attorney General, Consumer Fraud Bureau, 100 West Randolph Street, 12th floor, Chicago, Illinois, 60601.

  1. This is a final and appealable judgment and no just reason exists to delay enforcement or appeal.

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