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Federal Communications Commission DA 16-527
Before the
Federal Communications Commission
Washington, DC 20554
In the Matter of
Sabrina Javani
d/b/a EZ Business Loans
Steven Anthony Pashmfoush a/k/a Steven Pasha, 
Steven A. Pashmfouroush, Steven Anthony 
Pashfouroush
Operating as EZ Business Loans
Anthony Galdieri
Operating as EZ Business Loans
1
Apparent Liability for Forfeiture
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)
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)
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)
)
)
)
)
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File No.:  EB-TCD-12-00000256
NAL/Acct. No.:  201232170008
FRNs:  0021898572
             0021898606
             0021898614
ORDER
Adopted:  June 14, 2016 Released:  June 14, 2016
By the Chief, Enforcement Bureau:
1. The Enforcement Bureau (Bureau) of the Federal Communications Commission has 
entered into Consent Decrees to resolve its investigation into whether Sabrina Javani and Steven A. 
Pashmfouroush, operating as EZ Business Loans, sent unsolicited advertisements, or “junk faxes,” to 
consumers’ telephone facsimile machines. Enforcement of the junk fax rules protects consumers from 
fax advertisements that they did not agree to receive, which intrude on privacy, interfere with receipt of 
wanted communications, and impose costs for paper and ink.  
2. As of the date of the Consent Decrees, Ms. Javani and Mr. Pashmfouroush warrant that 
they ceased operating EZ Business Loans and that neither they nor any business they control sends junk 
faxes to consumers’ telephone facsimile machines.  Mr. Pashmfouroush admits that he sent junk faxes in 
violation of federal law and Ms. Javani represents that she did not send, or direct others to send, any junk 
faxes to consumers’ telephone facsimile machines.  Both Mr. Pashmfouroush and Ms. Javani provided 
financial documentation to the Bureau demonstrating that they are unable to pay the $1,680,000 penalty 
proposed by the Commission in this matter.  To settle this matter, Mr. Pashmfouroush agrees that neither 
he nor any business that he controls will send any type of advertisement to a telephone facsimile machine 
and Ms. Javani agrees that neither she nor any business that she controls will send any type of unsolicited 
advertisement to a telephone facsimile machine.  If Mr. Pashmfouroush, Ms. Javani, or any business 
either person controls violates the terms of the Consent Decrees, they will pay the full $1,680,000 penalty 
proposed by the Commission.
3. After reviewing the terms of the Consent Decrees and evaluating the facts before us, we 
find that the public interest would be served by adopting the Consent Decrees and resolving the Notice of 
Apparent Liability for Forfeiture (NAL) regarding Ms. Javani’s, Mr. Pashmfouroush’s, and EZ Business 
                                                     
1
Following the issuance of the proposed forfeiture in this matter, the Enforcement Bureau determined that Anthony 
Galdieri and Steven Anthony Pashmfoush a/k/a Steven Pasha, Steven A. Pashmfouroush, Steven Anthony 
Pashfouroush are the same individual.
Federal Communications Commission DA 16-527
2
Loans’s compliance with Section 227(b)(1)(C) of the Communications Act of 1934, as amended (Act),
2
and Section 64.1200(a)(4) of the Commission’s rules (Rules).
3
4. Accordingly, IT IS ORDERED that, pursuant to Sections 4(i) and 503(b) of the Act
4
and 
the authority delegated by Sections 0.111 and 0.311 of the Rules,
5
the attached Consent Decree IS 
ADOPTED and its terms incorporated by reference.
5. IT IS FURTHER ORDERED that the above-captioned matter IS TERMINATED and
the NAL IS RESOLVED in accordance with the terms of the attached Consent Decree.
6. IT IS FURTHER ORDERED that a copy of this Order and Consent Decree shall be 
sent by first class mail and certified mail, return receipt requested, to Sabrina Javani, 221 South Gale
Drive, Unit 306, Beverly Hills, CA 90211, and to Edward A. Maldonado, Maldonado Law Group, 3399 
NW 72
nd
Ave. #216, Miami, FL 33122.
FEDERAL COMMUNICATIONS COMMISSION
Travis LeBlanc
Chief
Enforcement Bureau
                                                     
2
47 U.S.C. § 227(b)(1)(C).
3
47 CFR § 64.1200(a)(4).
4
47 U.S.C. §§ 154(i), 503(b).
5
47 CFR §§ 0.111, 0.311.
Federal Communications Commission DA 16-527
Before the
Federal Communications Commission
Washington, DC 20554
In the Matter of
Sabrina Javani
)
)
)
)
)
File No.:  EB-TCD-12-00000256
NAL/Acct. No.:  201232170008  
FRN:  0021898572
CONSENT DECREE
1. The Enforcement Bureau of the Federal Communications Commission and Sabrina 
Javani, by their authorized representatives, hereby enter into this Consent Decree for the purpose of 
terminating the Enforcement Bureau’s investigation into whether Sabrina Javani violated Section 
227(b)(1)(C) of the Communications Act of 1934, as amended,
1
and Section 64.1200(a)(4) of the 
Commission’s rules
2
in connection with delivering unsolicited advertisements, or “junk faxes,” to 
consumers’ telephone facsimile machines.
I. DEFINITIONS
2. For the purposes of this Consent Decree, the following definitions shall apply:
(a) “Act” means the Communications Act of 1934, as amended.
3
(b) “Adopting Order” means an order of the Bureau adopting the terms of this Consent 
Decree without change, addition, deletion, or modification.
(c) “Advertisement” shall have the meaning set forth in Section 64.1200(f)(1) of the 
Rules.
4
(d) “Bureau” means the Enforcement Bureau of the Federal Communications 
Commission.
(e) “Commission” and “FCC” mean the Federal Communications Commission and all 
of its bureaus and offices.
(f) “Communications Laws” means collectively, the Act, the Rules, and the published 
and promulgated orders and decisions of the Commission to which Sabrina Javani is 
subject by virtue of her business activities, including but not limited to the 
Unsolicited Facsimile Rules.
(g) “Compliance Reports” means the reports Sabrina Javani is required to file with the 
Commission described in this Consent Decree at paragraph 12.
                                                     
1
47 U.S.C. § 227(b)(1)(C).
2
47 CFR § 64.1200(a)(4).  Several amendments to Section 64.1200 took effect after the Notice of Apparent 
Liability for Forfeiture was issued in this case.  The rule governing unsolicited advertisements to telephone facsimile 
machines in this case was not substantively changed, but was renumbered from Section 64.1200(a)(3) to 
64.1200(a)(4).  Federal Communications Commission, Telephone Consumer Protection Act of 1991, 77 Fed. Reg. 
34233 (June 11, 2012).
3
47 U.S.C. § 151 et seq.
4
47 CFR § 64.1200(f)(1).
Federal Communications Commission DA 16-527
2
(h) “Effective Date” means the date by which both the Bureau and Sabrina Javani have 
signed the Consent Decree.
(i) “Investigation” means the investigation commenced by the Bureau in EB-TCD-12-
00000256 regarding whether Sabrina Javani, who previously operated EZ Business 
Loans, violated the Unsolicited Facsimile Rules.
(j) “Parties” means Sabrina Javani and the Bureau, each of which is a “Party.”
(k) “Rules” means the Commission’s regulations found in Title 47 of the Code of 
Federal Regulations.
(l) “Unsolicited Advertisement” shall have the meaning set forth in Section 
64.1200(f)(15) of the Rules.
5
(m) “Unsolicited Facsimile Rules” means Section 227 of the Act, Section 64.1200 of the 
Rules, and other provisions of the Act, the Rules, and Commission orders related to
the delivery of Unsolicited Advertisements to telephone facsimile machines.
6
  
II. BACKGROUND
3. The Unsolicited Facsimile Rules prohibit “any person within the United States, or any 
person outside the United States if the recipient is within the United States . . . to use any telephone 
facsimile machine, computer, or other device to send, to a telephone facsimile machine, an unsolicited 
advertisement.”
7
  The Unsolicited Facsimile Rules seek to protect consumers from fax advertisements that 
they did not agree to receive, which intrude on privacy, interfere with receipt of wanted communications, 
and impose costs for paper and ink. 
4. On October 6, 2010, in response to numerous consumer complaints alleging receipt of 
Unsolicited Advertisements from EZ Business Loans, which Sabrina Javani operated, the Bureau issued a 
Citation to EZ Business Loans for violating the Unsolicited Facsimile Rules.
8
  On July 10, 2012, based on 
additional consumer complaints reporting that EZ Business Loans continued faxing Unsolicited 
Advertisements, the Commission released a Notice of Apparent Liability for Forfeiture (NAL) finding 
willful and repeated violations of the Unsolicited Facsimile Rules by EZ Business Loans, Sabrina Javani, 
and her associate Steven A. Pashmfouroush.
9
  The NAL proposed a forfeiture of $1,680,000 jointly and 
severally against these parties in light of the intentional nature of the violations and the parties’ history of 
prior offenses.
10
  
5. On December 27, 2013, Sabrina Javani responded to the NAL, claiming an inability to 
pay the proposed forfeiture and seeking to initiate settlement negotiations.
11
  Subsequently, Sabrina Javani 
submitted tax returns to demonstrate limited gross income in support of her inability to pay claim.
                                                     
5
47 CFR § 64.1200(f)(15).
6
47 U.S.C. § 227; 47 CFR § 64.1200.
7
  47 U.S.C. §227(b)(1)(C).  See 47 CFR § 64.1200(a)(4) (prohibiting use of “a telephone facsimile machine, 
computer, or other device to send an unsolicited advertisement to a telephone facsimile machine”).
8
Citation from Joshua P. Zeldis, Assistant Chief, Telecommunications Consumers Division, FCC Enforcement 
Bureau, to EZ Business Loans (Oct. 6, 2010) (on file in EB-TCD-12-00000256).
9
Sabrina Javani d/b/a EZ Business Loans et al., Notice of Apparent Liability for Forfeiture, 27 FCC Rcd 7921 
(2012).
10
Id. at 7927, para. 12.
11
Initial Response of Sabrina Javani to Notice of Apparent Liability and Request for Consent Decree Negotiations 
(filed Dec. 27, 2013) (on file in EB-TCD-12-00000256).
Federal Communications Commission DA 16-527
3
III. TERMS OF AGREEMENT
6. Adopting Order.  The provisions of this Consent Decree shall be incorporated by the 
Bureau in an Adopting Order.
7. Jurisdiction.  Sabrina Javani agrees that the Bureau has jurisdiction over her and the 
matters contained in this Consent Decree and has the authority to enter into and adopt this Consent 
Decree.
8. Effective Date; Violations.  The Parties agree that this Consent Decree shall become 
effective on the Effective Date as defined herein.  As of the Effective Date, the Parties agree that this 
Consent Decree shall have the same force and effect as any other order of the Commission.  
9. Termination of Investigation.  In express reliance on the covenants and representations 
in this Consent Decree and to avoid further expenditure of public resources, the Bureau agrees to 
terminate the Investigation.  In consideration for the termination of the Investigation, Sabrina Javani
agrees to the terms, conditions, and procedures contained herein.  The Bureau further agrees that, in the 
absence of new material evidence, it will not use the facts developed in the Investigation through the 
Effective Date, or the existence of this Consent Decree, to institute, on its own motion, any new 
proceeding, formal or informal, or take any action on its own motion against Sabrina Javani concerning 
the matters that were the subject of the Investigation.  
10. Representations; Warranties.  Sabrina Javani represents that she did not use or direct to 
be used, any telephone facsimile machine, computer, or other device to send, to a telephone facsimile 
machine, any Unsolicited Advertisement for EZ Business Loans.  Sabrina Javani warrants that, as of the 
Effective Date, she has ceased operating as EZ Business Loans and, further, that she neither uses nor 
directs the use of any telephone facsimile machine, computer, or other device to send any type of 
Unsolicited Advertisement to a telephone facsimile machine. 
11. Injunctive Obligation.  Sabrina Javani agrees that, as a material condition to this 
Consent Decree, neither she nor any business that she controls will use, or direct the use of, any telephone 
facsimile machine, computer, or other device to send any type of Unsolicited Advertisement to a 
telephone facsimile machine from the Effective Date forward without limitation.  Pursuant to this 
agreement, Sabrina Javani and any business that she controls shall not use, or direct the use of, any 
telephone facsimile machine, computer, or other device to send any type of Unsolicited Advertisement to 
a telephone facsimile machine from the Effective Date forward without limitation.    
12. Compliance Reports.  Sabrina Javani shall file compliance reports with the Commission 
ninety (90) calendar days after the Effective Date, twelve (12) months after the Effective Date, twenty-
four (24) months after the Effective Date, and thirty-six (36) months after the Effective Date.  
(a) Each Compliance Report shall contain a certification by Sabrina Javani that neither 
she nor any business that she controls has used or directed the use of any telephone 
facsimile machine, computer, or other device to send any type of Unsolicited 
Advertisement to a telephone facsimile machine during the relevant period.  
(b) Sabrina Javani’s certification shall comply with Section 1.16 of the Rules and be 
subscribed to as true under penalty of perjury in substantially the form set forth 
therein.
12
(c) If Sabrina Javani cannot provide the requisite certification, she shall provide the 
Commission with a detailed explanation of the reason(s) why and describe fully:  (i) 
each instance of noncompliance; (ii) the steps that she has taken or will take to 
                                                     
12
47 CFR § 1.16.
Federal Communications Commission DA 16-527
4
remedy such noncompliance, including the schedule on which such proposed 
remedial actions will be taken; and (iii) the steps that she has taken or will take to 
prevent the recurrence of any such noncompliance, including the schedule on which 
such preventative action will be taken.
(d) All Compliance Reports shall be submitted to the Chief, Telecommunications 
Consumers Division, Enforcement Bureau, Federal Communications Commission, 
4-C224, 445 12
th
Street, S.W., Washington, DC 20554, with a copy submitted 
electronically to Richard Hindman and to Mary Romano at 
richard.hindman@fcc.gov and mary.romano@fcc.gov. 
13. Termination Date. The requirements set forth in paragraph 12 of this Consent Decree 
shall expire thirty-six (36) months after the Effective Date.
14. Default Civil Penalty.  Sabrina Javani agrees that upon an Event of Default (as described 
below in paragraph 15), she shall pay a civil penalty to the United States Treasury in the amount of one 
million, six hundred eighty thousand dollars ($1,680,000) (the Default Civil Penalty).  Sabrina Javani
acknowledges and agrees that upon an Event of Default, the Default Civil Penalty shall become a “Claim” 
or “Debt” as defined in Section 3701(b)(1) of the Debt Collection Improvement Act of 1996 (DCIA),
13
and all procedures for collection of the Default Civil Penalty may, at the Commission’s discretion, be 
initiated.  
15. Event of Default.  Sabrina Javani agrees that an Event of Default shall occur if:  (1) she 
or any business that she controls uses or directs the use of any telephone facsimile machine, computer, or 
other device to send any type of Unsolicited Advertisement to a telephone facsimile machine after the 
Effective Date; or (2) the Commission releases an order finding that she materially misstated her financial 
condition in the documents she produced to support her inability to pay claim.  Upon an Event of Default, 
all procedures for collection permitted by the DCIA and other provisions of law
14
may, at the 
Commission’s discretion, be initiated and the following shall become immediately due and payable, 
without notice, presentment, demand, protest, or notice of protest of any kind, all of which are waived by 
Sabrina Javani:  (a) the Default Civil Penalty, which shall accrue interest computed using the U.S. Prime 
Rate in effect on the date of the Event of Default plus 4.75 percent per annum from the date of the Event 
of Default until payment in full; (b) any penalties permitted and/or required by the law, including but not
limited to 31 U.S.C. § 3717; and (c) any administrative charge(s), including the costs of collection, 
litigation, and attorneys’ fees.
16. Waivers.  As of the Effective Date, Sabrina Javani waives any and all rights she may 
have to seek administrative or judicial reconsideration, review, appeal or stay, or to otherwise challenge 
or contest the validity of this Consent Decree and the Adopting Order.  Sabrina Javani shall retain the 
right to challenge Commission interpretation of the Consent Decree or any terms contained herein.  If 
either Party (or the United States on behalf of the Commission) brings a judicial action to enforce the 
terms of the Consent Decree or the Adopting Order, neither Sabrina Javani nor the Commission shall 
contest the validity of the Consent Decree or the Adopting Order, and Sabrina Javani shall waive any 
statutory right to a trial de novo.  Sabrina Javani hereby agrees to waive any claims she may otherwise 
have under the Equal Access to Justice Act
15
relating to the matters addressed in this Consent Decree.
17. Severability.  The Parties agree that if any of the provisions of the Consent Decree shall 
be held unenforceable by any court of competent jurisdiction, such unenforceability shall not render 
unenforceable the entire Consent Decree, but rather the entire Consent Decree shall be construed as if not 
                                                     
13
Debt Collection Improvement Act of 1996, Pub. L. No. 104-134, 110 Stat. 1321, 1358 (Apr. 26, 1996) (DCIA).
14
See 14 CFR § 1.1910 et seq., Collection of Claims Owed the United States.
15
See 5 U.S.C. § 504; 47 CFR §§ 1.1501–1.1530.
Federal Communications Commission DA 16-527
5
containing the particular unenforceable provision or provisions, and the rights and obligations of the 
Parties shall be construed and enforced accordingly.
18. Invalidity.  In the event that this Consent Decree in its entirety is rendered invalid by any 
court of competent jurisdiction, it shall become null and void and may not be used in any manner in any 
legal proceeding.
19. Subsequent Rule or Order.  The Parties agree that if any provision of the Consent 
Decree conflicts with any subsequent Rule or Order adopted by the Commission (except an Order 
specifically intended to revise the terms of this Consent Decree to which Sabrina Javani does not 
expressly consent) that provision will be superseded by such Rule or Order.
20. Final Settlement.  The Parties agree and acknowledge that this Consent Decree shall 
constitute a final settlement between the Parties with respect to the Investigation.  The Parties further 
agree that this Consent Decree does not constitute either an adjudication on the merits or a factual or legal 
finding regarding any compliance or noncompliance with the requirements of the Communications 
Laws.
21. Modifications.  This Consent Decree cannot be modified without the advance written 
consent of both Parties.
22. Paragraph Headings.  The headings of the paragraphs in this Consent Decree are 
inserted for convenience only and are not intended to affect the meaning or interpretation of this Consent 
Decree.
23. Authorized Representative.  Each Party represents and warrants to the other that it has 
full power and authority to enter into this Consent Decree.  Each person signing this Consent Decree on 
behalf of a Party hereby represents that he or she is fully authorized by the Party to execute this Consent 
Decree and to bind the Party to its terms and conditions.
24. Counterparts.  This Consent Decree may be signed in counterpart (including 
electronically or by facsimile).  Each counterpart, when executed and delivered, shall be an original, and 
all of the counterparts together shall constitute one and the same fully executed instrument.
________________________________
Travis LeBlanc
Chief
Enforcement Bureau
________________________________
Date
________________________________
Sabrina Javani
________________________________
Date