In the Matter of the Complaint Against

 MUMMERS,
 P. O. Box 27013 at
 Philadelphia, PA 19118-7013, et al.

 and

 LAW ENFORCEMENT ACADEMY,
 P. O. Box 703 at
 Carlisle, PA 17013-0703, et al.  

 P.S. Docket No. 22/67; P.S. Docket No. 22/99

 August 31, 1987

 James A. Cohen Judicial Officer

 APPEARANCE FOR COMPLAINANT:
 Sandra C. McFeeley, Esq. 
 Consumer Protection Division
 Law Department
 United States Postal Service
 Washington, DC 20260-1112

 APPEARANCES FOR RESPONDENT:
 Timothy J. May, Esq. 
 John L. Oberdorfer, Esq. 
 Patton, Boggs Blow For Show Office, Inc.
 and Keith Bisaha
 2550 M Street, N.W. 
 Washington, DC 20037-1350

Lewiston Exchange Club
Show Fund
P. O. Box 7841
Lewiston, ME 04240-7841

Peter Piper's Den
P. O. Box 247
Nashua, NH 03061-0247

Manchester Knights of Columbus
Show Fund
P. O. Box 5438
Manchester, NH 03108-5438

Pine Tree Chapter
American Red Cross Show Fund
P. O. Box 1809
Bangor, ME 04401-1809

Augusta Knights of Columbus
Show Fund
P. O. Box 5621
Augusta, ME 04330-5621

In addition, Complainant seeks a supplemental Cease and Desist Order, which is authorized in the Agreements, against Respondents Show Office, Inc., Robert R. Schwarz, Jr., Richard Centrella, Keith Bisaha and Robert Phetteplace, as well as Extravagana, Inc., and Tickets America, Inc.

On April 17, 1987, an Interim Detention Order as authorized by paragraph 6 of the Consent Agreements was issued directing the detention of mail to the five names and addresses to which funds were solicited. In the Interim Detention Order, Respondents were granted a period of ten days in which to file a reply to the Petition. While a reply has been filed by Respondents Keith Bisaha and Show Office, Inc., no reply has been filed by the remainder of the Respondents within the time allowed, or as of the date of this Decision. In the absence of a reply, the allegations of the Petition, which are supported by the exhibits attached thereto, are deemed to be admitted by Respondents Extravaganza, Inc., Tickets America, Inc., Richard J. Garden, Robert Verbeem, Robert R. Schwarz, Jr., Robert Phetteplace, and Richard Centrella. The unchallenged allegations make a prima facie showing that these Respondents continue to solicit money for fund raising activities by means of false representations in violation of the terms of the two Agreements.

Respondents Show Office, Inc. and Keith Bisaha contend that they were not signatories to either of the Consent Agreements or in privity with those Respondents who signed the Agreements and therefore are not bound by the terms of those Agreements. As a result, they argue that their due process rights have been violated and the Petition should be dismissed, the Interim Detention Order vacated, and a hearing held.

The uncontested facts establish that at the time the Consent Agreements were executed and during the period some of the prior Cease and Desist Orders were in effect, Mr. Bisaha performed work for Respondent Tickets America, Inc.; was an employee of Respondent Extravaganza, Inc.; acquired and became president of Respondent Tickets America, Inc.; and subsequently established and became the owner and sole officer of Show Office, Inc. Under this combined set of circumstances, Mr. Bisaha and Show Office, Inc. are clearly in privity with the Respondents who signed the Consent Agreements and subject to the terms of those Agreements. See Regal Knitwear, Co. v. NLRB , 324 U.S. 9 (1945); NLRB v. Sequoia District Counsel of Carpenters, AFL-CIO , 568 F.2d 628 (9th. Cir. 1977); United States v. Palacios , 556 F.2d 1359 (5th. Cir. 1977), quoting Nye and Nissen v. United States , 336 U.S. 613 (1949); J. R. Clark v. Jones , 288 F.2d 279 (7th. Cir. 1961); Diet Products, Inc. v. United States Postal Service , No. CV-81-0486 (E.D.N.Y. April 2, 1981); United States Postal Service v. Columbia Research Corp . No. 79 C 2065 (N.D. Ill., Jan. 24, 1980) Consequently, the imposition of the Interim Detention and other Orders sought in the Petition does not violate their due process rights.

Respondents Bisaha and Show Office, Inc. have not raised any genuine issue of material fact concerning the alleged violation of the terms of the Consent Agreements and have therefore not shown good cause for a hearing to be held. Thus, for the reasons stated in the Petition, which are supported by the exhibits attached thereto, it is concluded that Respondents Bisaha and Show Office, Inc. solicit money for fund raising activities by means of false representations in violation of the terms of the two Consent Agreements.

Accordingly, pursuant to the terms of the Agreements and as authorized by 39 U.S.C. 3005, the False Representation Order and supplemental Cease and Desist Order sought in the Petition are issued with this Decision.