Robert A. Eder - Page 5




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               In 2000, petitioner began sending out direct mail                      
          information, promoting Reliv products and the opportunity to                
          become “healthy & rich”.  Some of these direct mail materials               
          indicated that petitioner had been using Reliv products for many            
          months and that they had reduced his symptoms of various chronic            
          illnesses and contributed to his “overall feeling of good                   
          health.”                                                                    
               Using an Internet database at his local public library,                
          petitioner secured names and addresses of women in the northwest            
          Indiana area to whom he would send the direct mail information.             
          Each week, petitioner selected names and addresses of about 48              
          women to whom he would mail postcards.  Petitioner would follow             
          up the first postcard with a second and a third and then attempt            
          to telephone some of these women.  Each month, he would talk to             
          several of them on the telephone for 15 or 20 minutes, making his           
          Reliv pitch.  On rare occasions, petitioner would meet with one             
          of these women at the local library to give them Reliv materials.           
          As far as the record reveals, none of these contacts ever                   
          resulted in petitioner’s making any Reliv sales or sponsoring any           
          Reliv distributors.                                                         
               On Tuesday evenings and Saturday mornings, petitioner                  
          attended Reliv meetings approximately 10 miles from his home.               
          During 2002, petitioner attended national Reliv conferences in              
          Reno, Nevada, and St. Louis, Missouri.                                      







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