TRACY L. SUNDERLAGE; LINDA

IN THE UNITED STATES DISTRICT COURT FOR THE
NORTHERN DISTRICT OF ILLINOIS
UNITED STATES OF AMERICA, )
 )
Plaintiff, )
 )
v. )
 )
TRACY L. SUNDERLAGE; LINDA  )   Civil No. 11-cv-4713
SUNDERLAGE; SUNDERLAGE RESOURCE  )
GROUP INTERNATIONAL, LTD. a/k/a SRG  )
INTERNATIONAL LTD.; SRG  )
INTERNATIONAL U.S. LLC; MAVEN U.S.  )
LLC d/b/a MAVEN LLC; and RANDALL  )
ADMINISTRATION LLC,  )
 )
Defendants. )
COMPLAINT FOR PERMANENT INJUNCTION AND OTHER RELIEF
Plaintiff United States of America, for its complaint against defendants Tracy L.
Sunderlage, Linda Sunderlage, Sunderlage Resource Group International, Ltd., also known as
SRG International Ltd., SRG International U.S. LLC, Maven U.S. LLC, and Randall
Administration LLC (collectively, “Defendants”), states as follows:
NATURE OF ACTION
1. Defendants organize, operate, and promote a scheme that claims to enable participating
owners of small, closely-held companies (“Owners”) to ible contributions to
purported “welfare benefit plans” for the ostensible purpose of providing employee benefits like
life insurance and health insurance.  But in fact the bulk of the money is routed into various
investments that are held solely for the Owners’ future use (“the Employee Benefit Scheme”).