Case: 1:03-cv-03904 Document #: 812 Filed: 01/27/14 Page 1 of 4 PageID #:14748

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION FEDERAL TRADE COMMISSION, Plaintiff, v. KEVIN TRUDEAU, Defendant. ) ) ) Ca e N!." #$%C%$&#' ) ) H!n. R!(e)t *. +ettle,an ) ) ) ) )

RECEIVER-S MOTION FOR LEAVE TO FILE SUR%REPL. OPPOSIN+ PROPOSED INTERVENORS- MOTION TO INTERVENE Robb Evans & Associates LLC (the Receiver), the court appointed receiver of the assets of Keven Trudeau and the Trudeau Entities et al , hereb! respectfull! "ove for leave (#otion) to file its $ur%Repl! &pposin' (roposed )ntervenors* #otion to )ntervene, a cop! of +hich is attached hereto as E,hibit - )n further support of its #otion, the Receiver states. &n /ove"ber -0, 12-3, (err! Kiral! and certain other "e"bers of the 4lobal

)nfor"ation /et+or5 (collectivel!, the (roposed )ntervenors), filed their #otion to )ntervene (ursuant to 6 R C ( 17 (the #otion to )ntervene) 1 8urin' a /ove"ber 1-, 12-3 status hearin', the Court entered a briefin' schedule

a'reed to b! the parties the "ade responses to the #otion to )ntervene due on 8ece"ber 12, 12-3, and replies due on 9anuar! -:, 12-7 ;85t <021= 3 &n 6rida!, 8ece"ber 12, the 6TC filed its response opposin' the #otion to

)ntervene >avin' coordinated +ith the 6TC +ith respect to its opposition, includin' providin' a supportin' affidavit, and in order to avoid the e,pense to the receivership estate of preparin' a

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Case: 1:03-cv-03904 Document #: 812 Filed: 01/27/14 Page 2 of 4 PageID #:14749

substantiall! duplicative response, the Receiver filed a brief state"ent ?oinin' the 6TC*s response on #onda!, 8ece"ber 13, 12-3 7 The (roposed )ntervenors filed their repl! on 9anuar! 12, 12-7 )n their repl!, the

(roposed )ntervenors launch a ne+ attac5 on the Receiver*s "ana'e"ent of 4)/, includin' attachin' a ne+ affidavit raisin' additional alle'ations re'ardin' the Receiver*s actions 6or e,a"ple, the (roposed )ntervenors "isleadin'l! alle'e, a"on' other thin's, that the Receiver has infor"ed "e"bers that the Receiver intends to shut%do+n 4)/, that the Receiver has censored 4)/*s +ebsite, and has i"properl! e,cluded "e"ber*s access to the 4)/ resources The (roposed )ntervenors also attach an affidavit +ron'l! clai"in' that the Receiver has threatened le'al action a'ainst 4)/ "e"bers si"pl! for cancelin' their "e"bership The Receiver stron'l! disputes these clai"s and see5s leave to file the attached sur%repl! to set the record strai'ht Absent an! sho+in' that the (roposed )ntervenors have an! le'al ri'ht to substitute their business ?ud'"ent for that of the Receiver, the (roposed )ntervenors* attac5s on the Receiver are of little relevance, e,cept that such "isinfor"ation ris5s har"in' the receivership estate b! further under"inin' 4)/*s relationship +ith its client%"e"bers @ Additionall!, since ?oinin' the 6TC*s response, the Receiver has beco"e a+are

that #r Kiral!, the lead proposed intervenor, has been ca"pai'nin' to encoura'e other 4)/ "e"bers to cancel their "e"berships and ?oin a co"petin' club that he is for"in' in order to har" the value of 4)/ and drive do+n the price that he +ould have to pa! to purchase 4)/ or its assets The Receiver thus also see5s to file its sur%repl! for the purpose of "a5in' a record of these additional facts, +hich cast substantial doubt re'ardin' the (roposed )ntervenors* true interests in this liti'ation

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Case: 1:03-cv-03904 Document #: 812 Filed: 01/27/14 Page 3 of 4 PageID #:14750

*HEREFORE, the Receiver respectfull! reAuests the Court enter an &rder 'rantin' the Receiver leave to file the $ur%repl! &pposin' the (roposed )ntervenor*s #otion to )ntervene

8ated. 9anuar! 1:, 12-7

Respectfull! sub"itted, RO// EVANS 0 ASSOCIATES LLC, RECEIVER B!. CsC Blair DanEi' (&ne of )ts Attorne!s) Blair R DanEi' (/o F1:31G3) 9ohn 6 >iltE (/o F10G:77) Kath! Hantuch (/o F1G7237) HILT1 *ANTUCH 0 1AN1I+ LLC @3 Hest 9ac5son Blvd , $uite 12@ Chica'o, )llinois F2F27 Telephone. 3-1 @FF G220 6a,. 3-1 @FF G2-@ Counsel for Robb Evans & Associates, Receiver

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Case: 1:03-cv-03904 Document #: 812 Filed: 01/27/14 Page 4 of 4 PageID #:14751

CERTIFICATE OF SERVICE ), Blair R DanEi', an attorne!, hereb! certif! that, on the 1:th da! of 9anuar!, 12-7, ) caused a true and correct cop! of the fore'oin' Receiver*s #otion for Leave to 6ile $ur%Repl! &pposin' (roposed )ntervenors* #otion to )ntervene to be served throu'h the Court*s Electronic Case 6ilin' $!ste" on the follo+in'.

Ki"ball Richard Anderson 5andersonI+inston co" Tho"as Lee Kirsch, )) t5irschI+inston co" Katherine E Rohlf 5cros+ellI+inston co" #ichael #ora ""oraIftc 'ov 9onathan Cohen 9cohen1Iftc 'ov A"anda B Kostner a5ostnerIftc 'ov 8avid &*Toole dotooleIftc 'ov Ti"oth! A $hi"5o tashi"5oI'"ail co" 8aniel $tephen $hi"5o 8shi"5o2@I'"ail co" Andre+ 4ordon ab'I'ordonla+ltd co" 9ustin $cheid debrabuettnerIaol co"

CsC Blair R DanEi'

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Case: 1:03-cv-03904 Document #: 812-1 Filed: 01/27/14 Page 1 of 10 PageID #:14752

EXHIBIT 1

GIN Network Truth (the smart group)

Case: 1:03-cv-03904 Document #: 812-1 Filed: 01/27/14 Page 2 of 10 PageID #:14753

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION FEDERAL TRADE COMMISSION, Plaintiff, v. KEVIN TRUDEAU, D f n!ant. " " " Ca# N$.% &'(C(')&* " " H$n. R$+ ,t -. . ttl /an " " " " "

RECEIVER0S SUR(REPL1 IN OPPOSITION TO PROPOSED INTERVENORS0 MOTION TO INTERVENE In their reply, the Proposed Intervenors grossly mischaracterize the Receivers management of GIN apparently to create the sense of some false crisis requiring intervention notwithstanding that the Proposed Intervenors fail to demonstrate any actual legal interest in GIN that would afford them the right to su stitute their usiness !udgment for the Receivers" Indeed, as detailed in the #$%s Response and ignored in the Proposed Intervenors Reply, the &em ership 'greement entered into y the Proposed Intervenors ma(es clear that eing a mem er of GIN confers no ownership interest in GIN or legal right to control any of GINs educational materials" )See #$% Response *+(t" ,-.-/ at 012"3 Nevertheless, y perpetuating the misinformation a out the Receivers management of GIN, the Proposed Intervenors undermine GIN and correspondingly damage the receivership estate" In fact, contrary to the Proposed Intervenors assertions, the Receiver has wor(ed diligently to manage GIN with the e4pressed intent of ena ling GIN to continue as a legally and financially via le organization providing its mem ers )i.e. its customers3 with various educational and social enefits" 's detailed elow, while purporting to act in this case out of a

GIN Network Truth (the smart group)

Case: 1:03-cv-03904 Document #: 812-1 Filed: 01/27/14 Page 3 of 10 PageID #:14754

desire to continue the educational and social enefits of GIN )despite having no cogniza le ownership interest in GIN3, one of the Proposed Intervenors has actively campaigned out of court to encourage other GIN mem ers to cease paying their dues to GIN to force the Receiver to sell GINs assets to his newly formed competing clu at favora le prices" 6uch efforts further elie the e4istence of any valid reason to permit intervention here and the %ourt should accordingly deny the &otion" I. THE RECEIVER HAS MANA.ED .IN SO THAT IT MA1 CONTINUE TO OPERATE AS A LE.ALL1 AND FINANCIALL1 VIABLE OR.ANI2ATION. A. Rat3 , T3an S34t .IN D$5n, t3 R 6 iv , Int n!# t$ Sta+ili7 .IN S$ T3at a N 5 O5n , Can C$ntin4 t$ O8 ,at .IN L 9all:.

$he Proposed Intervenors mislead the %ourt y claiming that the Receiver has informed GIN mem ers that the Receiver 7intends to shut down GIN and sell off its assets"8 )Reply at 5"3 $he Proposed Intervenors have failed to cite a single instance in which the Receiver ever told GIN mem ers that it intended to shut down GIN" In fact, the Receiver stated the opposite, i.e. that the Receiver is wor(ing to preserve GIN as a going concern" $he Receiver wrote to GINs mem ers9 7It is the Receivers hope that GIN will survive as a true clu and ecome financially sta le so that it can continue in operation for many years to come"8 )See :4" ' );5<;0<5.;0 GIN 'nnouncement3 at 5"3 Rather than intending to shut down the clu and liquidate its assets as the Proposed Intervenors state, the Receiver e4plained to GINs mem ers that 7it is the intention of the Receiver to get permission from the %ourt to transfer GINs operations for a fair price to a new owner or ownership group"8 )Id.3 =ater in the same announcement, the Receiver reiterated9 7's a reminder, the Receiver is here for the purpose of sta ilizing the organization, providing guidance so that it can e operated legally and ecome financially sta le with the end goal eing to transfer GIN operations for a fair price and end our oversight"8 )Id.3

GIN Network Truth (the smart group)

Case: 1:03-cv-03904 Document #: 812-1 Filed: 01/27/14 Page 4 of 10 PageID #:14755

$o that end goal of preserving GIN as a going concern, the Receiver is mindful of the %ourts order that the Receiver is authorized to operate GIN 7only to the e4tent it is possi le to operate such usiness legally and profita ly"8 )Receivership >rder *+(t" , ?25/ at @ A);53"3 $hus, the Receiver has made changes to GINs mar(eting materials to eliminate false and deceptive claims as well as unsu stantiated income claims that the former $rudeau1controlled regime used, including claims that GIN is a 7perpetual money ma(ing machine8 and that its educational materials were endorsed y a secret international ca al of thirty illionaires" =i(ewise, the Receiver has evaluated the appropriateness of the affiliate program which had een flagged y oth the #$% and the %ourt as a source of concern that it was an improper pyramid scheme an 7'mway without the soap"8 Bpon reviewing the affiliate program, including the e4pert report of Peter C" Aander Nat, an economist and one of the countrys leading e4perts on pyramid schemes )see #$% Response *+(t" , -.-/ :4" %"3, the Receiver )who includes professionals well1e4perienced with multi1level mar(eting schemes3 e4ercised its usiness !udgment that it was in GINs interest that the affiliate program should e discontinued" Dy ringing GINs operations into compliance and after esta lishing a month or so of demonstrated performance post1affiliate program, the Receiver elieves that GIN will e in a position to e sold for a fair price as a going concern" $he Receiver anticipates eing in a position to entertain e4pressions of interest in purchasing GIN within the ne4t few wee(s" B. -it3 t3 E;6 8ti$n $f a Finan6iall: In#$lv nt C,4i# , t3 R 6 iv , Ha# C$ntin4 ! t3 S$6ial an! E!46ati$nal A6tiviti # $f .IN.

$he Proposed Intervenors assert that the Receiver has 7cancelled social and education events that had een scheduled y the %lu and its mem ers"8 )Reply at ;"3 $he Proposed Intervenors offer no specifics that would allow the %ourt or the parties to evaluate such statements" In fact, the Receiver is only aware of having cancelled a single event9 a seven day 0

GIN Network Truth (the smart group)

Case: 1:03-cv-03904 Document #: 812-1 Filed: 01/27/14 Page 5 of 10 PageID #:14756

cruise scheduled for Canuary 5.;2" 's the Receiver e4plained in its #irst Report filed on 6eptem er E, 5.;0 )more than 2 months ago3, the Receiver canceled the cruise ecause at the time the Receiver assumed control of GIN there were insufficient cash receipts to pay the outstanding F5"GE million lia ility necessary to go forward with the cruise" )#irst Report *+(t" , ?2?1;/ at ;?1;-"3 Hhatever disappointment GINs clients may have over the cancellation, the Proposed Intervenors have shown no grounds that would permit them to intervene and su stitute their usiness !udgment for the Receivers regarding GINs operations" #urther, contrary to the Proposed Intervenors most recent assertions, the Receiver has sought to continue the remaining full slate of educational and social programs" Prior to the Receivers involvement, GIN had retained a third party vendor, $he Iy rid Group, to plan and e4ecute smaller regional social and education events on ehalf of GIN" $he Receiver has caused GIN to continue that relationship on e4actly the same terms as it had pre1receivership" 's reflected in the following ta le ased on information provided y the Iy rid Group, GIN has continued on average to hold more than a hundred educational and social events each month during the receivership"
TABLE 1% S4//a,: $f .IN Ev nt# D4,in9 R 6 iv ,#3i8

Ma<$, Ev nt# A494#t >&1' S 8t /+ , >&1' O6t$+ , >&1' N$v /+ , >&1' D 6 /+ , >&1' ; ;

L$6al C3a8t , M tin9# GE E; GG G. 2G

M /+ ,#3i8 Ov ,vi 5 M tin9# 5G 0E ;J ;5 ?

S466 ## Ma#t ,: C$4,# # 0E 0? 0? 0? 0;

S /ina, = Rall: 2 J E 0 0

T$tal ;5; ;20 ;;? ;.5 -E

GIN Network Truth (the smart group)

Case: 1:03-cv-03904 Document #: 812-1 Filed: 01/27/14 Page 6 of 10 PageID #:14757

$hus, with the e4ception of the money losing cruise, which the Proposed Intervenors should have een aware was cancelled since at least early 6eptem er 5.;0, the Receiver has continued GINs social and educational activities uninterrupted" C. Ot3 , T3an t$ R /$v Fal# an! D 6 8tiv Clai/# F,$/ .IN0# A!v ,ti#in9, t3 R 6 iv , Ha# C$ntin4 ! P,$vi!in9 U8!at # t$ M /+ ,# R 9a,!in9 .IN0# A6tiviti #.

$he Proposed Intervenors also assert without any specificity that the Receiver has 7restricted access to information and updates usually provided y the %lu "8 )Reply at ;"3 In fact, the Receiver has not restricted access to information and updates usually provided y GIN nor have the Proposed Intervenors identified any right to information that is eing denied them" +uring the first wee(s of the receivership, as the Receiver was assuming control of GIN, ordinary operations may have een interrupted" 6ince then, however, GIN has continued to send out announcements regarding its activities on a regular asis, meaning several times a wee(" $hese announcements generally include information a out spea(ers at various regional training events and other social and educational1oriented information as well as updates on policies and procedures" Relatedly, the Proposed Intervenors claim that the Receiver has 7censored the content of GINs we site"8 )Reply at ;"3 Decause the Proposed Intervenors did not e4plain or demonstrate the asis of this claim, the Receiver is again left to guess to what they might e referring" In fact, the Receiver has only modified GINs we site to remove misleading and unsu stantiated income claims, as well as references to the affiliate program that has een discontinued as li(ely constituting an impermissi le pyramid scheme"

GIN Network Truth (the smart group)

Case: 1:03-cv-03904 Document #: 812-1 Filed: 01/27/14 Page 7 of 10 PageID #:14758

D.

T3 R 6 iv , Ha# In#4, ! T3at .IN Ha# t3 A88,$8,iat an! N 6 ##a,: Mana9 / nt.

In their Reply, the Proposed Intervenors falsely state that the Receiver has left GIN without management" )Reply at ;, E"3 Plainly this is not the case" 6hortly after assuming control of GIN, the then1acting %:> of GIN resigned" $he Receiver wor(ed closely with GINs four highest1ran(ing officers during the initial transition" $he Receiver replaced the acting %:> with a %hief >perating >fficer" $he Receiver also laid1off the %#> of GIN ecause the Receiver assumed control of GINs accounting functions rendering the %#>s services duplicative" Hhere appropriate to minimize e4penses, the Receiver has su sequently laid1off several other personnel, ut at all times has ensured that GIN was appropriately managed and staffed" #urther, pre1receivership, GIN had two advisory oards9 one 'ffiliate 'dvisory Doard and a &em ers Doard" %om ined these advisory oards had appro4imately ;0 mem ers" $hese advisory oards had no formal management authority, ut served to afford GIN mem ers a means to provide input to GINs management" Iaving terminated the affiliate program, two separate advisory oards were no longer required" $he Receiver adopted recommendations of GINs staff to create a new GIN Round $a le consisting of seven individuals and two alternates elected y active mem ers in good standing" #ormer mem ers of the 'ffiliate and &em er advisory oards currently comprise the =eadership Round $a le" $o foster communication, the Receiver further agreed to participate in a monthly conference call with the Round $a le" Hhether any of these changes are the asis for Proposed Intervenors vague allegations that the Receiver has left GIN without management, the fact remains that the Receiver has duly e4ercised its usiness !udgment to ensure the GIN has een well1managed"

GIN Network Truth (the smart group)

Case: 1:03-cv-03904 Document #: 812-1 Filed: 01/27/14 Page 8 of 10 PageID #:14759

II.

THE PROPOSED INTERVENORS0 TRUE INTERESTS APPEAR TO BE TO SEEK TO UNDERMINE .IN FOR THE BENEFIT OF THEIR COMPETIN. CLUB. 't the same time that the Proposed Intervenors see( to intervene in this litigation, Perry

Kiraly, the lead proposed intervenor, is see(ing to undermine GIN y suggesting to GIN mem ers that they cease paying their dues and lure GIN employees away from GIN in order to force a sale of GINs assets on advantageous terms" #or e4ample, in a Canuary J, 5.;2 email to 7#ellow GIN mem ers,8 &r" Kiraly writes9 76o what is the most powerful purchasing position we can e inL Hell, in my opinion, if the GIN #+N is no longer funding the Receivers salary and K$s fine y way of dues collectedM and there is no staff to run the clu , the Receiver would very e inclined to sell the assets in short order to the highest idder"8 ):4" D );<J<5.;0 :mail from P" Kiraly3" $he Proposed Intervenors misleadingly allege that the Receiver 7threatened the dues paying mem ers that they must continue to pay dues or else face litigation for conspiracy and tortious interference"8 )Reply at -"3 Neither the Receiver nor its counsel has ever made that assertion" %ounsel for the Receiver did opine to counsel for the Proposed Intervenors that actions ta(en to encourage GINs mem er1customers to cease paying their dues for the purpose of harming GIN )and there y depressing its sale price3 could constitute tortious interference" Neither the Receiver nor its counsel have raised the issue of whether such actions would constitute conspiracy nor have they made any statements directly to any GIN mem er threatening any action for tortious interference or conspiracy" In an announcement to GIN &em ers, the Receiver did comment that 7actions y a few rogue &em ers encouraging other &em ers to stop paying dues constitutes a violation of the *Receivership/ >rder as it interferes with the duties of the Receiver"8 ):4" ' at 5"3

GIN Network Truth (the smart group)

Case: 1:03-cv-03904 Document #: 812-1 Filed: 01/27/14 Page 9 of 10 PageID #:14760

$o e certain, to the e4tent that evidence ears out efforts y an individual or individuals to financially ruin GIN y intentionally interfering with GINs relationship with its customers in order to suppress its value and force a fire sale of its assets, the Receiver reserves all rights to ring appropriate claims, including for tortious interference" Notwithstanding such reservation, out of an appreciation of the sometimes e4treme passion of GINs mem ership, the Receiver has demonstrated su stantial restraint in not pressing its full array of legal remedies against a myriad of parties that have defamed the Receiver and inappropriately interfered with the receivership"; CONCLUSION In their Reply, as detailed a ove, the Proposed Intervenors rely on a num er of misleading allegations regarding the Receivers management of GIN" 6uch unsu stantiated rhetoric provides no asis for intervention here though perpetuating misleading information a out GIN serves to undermine GIN and the receivership estate" Hhile the Proposed Intervenors may disagree with the changes instituted y the Receiver as is nearly inevita le in an organization with thousands of client1mem ers the Proposed Intervenors fail to esta lish how

$he Proposed Intervenors also assert that the Receiver 7restricted or cut off access to the %lu s we site to several of the Intervenors"8 )Reply at ;"3 'gain, the Proposed Intervenors failed to identify what or whose access the Receiver purportedly restricted or, more importantly, why the denial of such access gives the Proposed Intervenors any standing here" $he Receiver is aware that consistent with the terms of the mem ership agreement, GIN has suspended the mem ership )and thus his access to the mem er area of the GIN we site3 of Perry Kiraly ecause, among other reasons, his conduct in encouraging other mem ers to cease paying their monthly dues and to !oin a competing clu violate GINs mem ership agreement"

GIN Network Truth (the smart group)

Case: 1:03-cv-03904 Document #: 812-1 Filed: 01/27/14 Page 10 of 10 PageID #:14761

such disagreement gives them any legally cogniza le interest for intervening" $he %ourt should deny their motion to intervene" +ated9 Canuary 5?, 5.;2 Respectfully su mitted, ROBB EVANS = ASSOCIATES LLC, RECEIVER Dy9 <s< Dlair Nanzig )>ne of Its 'ttorneys3 Dlair R" Nanzig )No" E5?05J03 Cohn #" Iiltz )No" E5-J?223 Kathy Hantuch )No" E5J2.023 HILT2 -ANTUCH = 2AN2I. LLC G0 Hest Cac(son Dlvd", 6uite 5.G %hicago, Illinois E.E.2 $elephone9 0;5"GEE"J..#a49 0;5"GEE"J.;G Counsel for Robb Evans & Associates, Receiver

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Case: 1:03-cv-03904 Document #: 812-2 Filed: 01/27/14 Page 1 of 3 PageID #:14762

EXHIBIT A

GIN Network Truth (the smart group)

Case: 1:03-cv-03904 Document #: 812-2 Filed: 01/27/14 Page 2 of 3 PageID #:14763

CLICK HERE TO VIEW THIS E-MAIL AS A WEB PAGE FOR ACCESS TO THE LINKS BELOW, PLEASE LOG IN TO YOUR GIN ACCOUNT HERE

MESSAGE FROM THE RECEIVER

Dear GIN Members: The Receiver has been advised that certain Members of GIN have engaged in a concerted effort to encourage other Members to discontinue payment of their monthly dues in hopes this would somehow derail the efforts of the Receiver. The Receiver would li e to ta e this opportunity to clarify our current and future plans with regards to the operations of GIN.

!s most of you now" on !ugust #" $%&' the (.). District *ourt for the Northern District of Illinois entered an +rder !ppointing a Receiver and Implementing !ncillary Relief ,+rder-. The +rder appointed Robb .vans / !ssociates 00* as Receiver over the assets of 1evin Trudeau" including but not limited to Global Information Networ 2DN" 3ebsite )olutions ()!" and all Trudeau .ntities whether foreign or domestic. ! copy of the +rder can be viewed on our website at www.robbevans.com.

)ection 4 of the +rder outlines the duties and authority of the Receiver. )ubsection &$ reads in pertinent part" "Continue to conduct the businesses of any Trudeau Entity, but only to the extent it is possible to operate such businesses legally and profitably..." ,.mphasis added-. (nder the direction of the Receiver" GIN has made a number of changes in its Mar eting approach. These changes are designed to meet the first criteria in )ection &$" that is" that the business must be run legally. GIN staff is wor ing diligently to design an enhanced Member benefits program which includes" among other things" the e5pansion of GIN6s accredited education curriculum" providing a wider variety of education topics and event formats" sponsoring local and ma7or events" trainings" recognition and facilitating networ ing opportunities designed for overall personal growth and improvement. The second duty of the Receiver under )ection &$ of the +rder re8uires the Receiver to determine if the company can be operated profitably. !ctions by a few rogue Members encouraging other Members to stop paying dues constitutes a violation of the +rder as it interferes with the duties of the Receiver. It is the Receiver6s hope that GIN will survive as a true club and become financially stable so that it can continue in operation for many years to come. !ssuming GIN can become financially stable and be operated profitability" it is the intention of the Receiver to get permission from the *ourt to transfer GIN

GIN Network Truth (the smart group)

Case: 1:03-cv-03904 Document #: 812-2 Filed: 01/27/14 Page 3 of 3 PageID #:14764

operations for a fair price to a new owner or ownership group. The Receiver6s oversight of the GIN operations could then be terminated and GIN would be operated by the new owners. .fforts to disrupt these initiates and the continued business operations of GIN can unfairly penali9e thousands of other Members that are currently engaged in GIN6s training system and the new Member benefits. The receiver supports recommendations from the GIN staff to create a new GIN Round Table made up of seven individuals elected by active Members in good standing. Members that are loyal and remain optimistic about the future of GIN would ma e good candidates to serve on the GIN Round Table. There are a tremendous number of rumors and misinformation being circulated by a few Members. The Receiver recogni9es the need to support a strong interchange of ideas and information with Members that : now and understand: the field. The GIN Round Table would provide a forum that could help to defuse the rumors and present factual information. The Receiver would be willing to participate in a monthly conference call with the GIN Round Table. !s a reminder" the Receiver is here for the purpose of stabili9ing the organi9ation" providing guidance so that it can be operated legally and become financially stable with the end goal being to transfer GIN operations for a fair price and end our oversight.

NOTE: CCO!"#N$ TO T%E #N&O!' T#ON $ T%E!E" () T%E !ECE#*E! O& T%E $+O( + #N&O!' T#ON NET,O!-, T%E ENT#T) !E&E!!E" TO . T%E $#N CO/NC#+ "OE. NOT E0#.T N" T%E!E&O!E N) !E&E!ENCE O! EN"O!.E'ENT O& T%#. ENT#T) () N) O& T%E $+O( + #N&O!' T#ON NET,O!-1. 2!E*#O/. T! #NE!.3%O.T. .%O/+" NOT (E #NTE!2!ETE" . N EN"O!.E'ENT, (ENE&#T O! 2 !T O& T%E T! #N#N$ C/!!#C/+/' O& T%E $#N O!$ N#4 T#ON. $#N1. &&#+# TE 2!O$! ' ' ) +.O (E !E&E!!E" TO #N 2 .T T! #N#N$. O! E"/C T#ON + ' TE!# +.. $#N1. &&#+# TE 2!O$! ' O&&#C# ++) EN". ON NO*E'(E! 56, 7685.

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Case: 1:03-cv-03904 Document #: 812-3 Filed: 01/27/14 Page 1 of 7 PageID #:14765

EXHIBIT B

GIN Network Truth (the smart group)

Case: 1:03-cv-03904 Document #: 812-3 Filed: 01/27/14 Page 2 of 7 PageID #:14766

SWGF Update: PERRY KIRALY

January 9, 2014

Dear Fellow GIN Members,

It has come to my awareness that the biggest

uestion among the Members

!resently is regar"ing the !urchase o# GIN or GIN IP $Intellectual Pro!erty i%e% the &uccess Mastery 'ourses an" other au"io, (i"eo an" written material owne" by GIN FDN)%

*s most o# you are aware, the !urchase o# GIN+s I, $only) has been an" still is among the !ro!ose" agen"as o# &-GF.-IN, but #orm the most !ower#ul negotiating !osition we can be in%

&o what is the most !ower#ul !urchasing !osition we can be in/ -ell, in my o!inion, i# the GIN FDN is no longer #un"ing the 0ecei(er+s salary an" 12+s #ine by way o# "ues collecte"3 an" there is no sta## to run the club, the 0ecei(er woul" (ery be incline" to sell the assets in short or"er to the highest bi""er%

Now some ha(e suggeste" that they might 4ust shut the club "own i# it sto!s ma5ing money3 out o# s!ite/ 2hough I truly "oubt that the 0ecei(er, out o# s!ite, woul" not try to sell a thing that ha" some (alue3 i# they "i" an" as5e" the court to 4ust shut GIN FDN "own an" aban"one" it 6 goo", then we get the I, #or #ree%

7n"erstan" also why "o we not want to buy an" continue to use GIN FDN as our legal entity an" ha(e begun the !rocess o# establishing -IN or the -orl" In#ormation Networ5 as that new entity/ 8ne, is because GIN FDN is ri""le" with legal liabilities% 2wo, is that so much negati(e !ress now surroun"s that name it coul" !ro(e "etrimental to #uture recruitment o# members% *n" three, as

GIN Network Truth (the smart group)

Case: 1:03-cv-03904 Document #: 812-3 Filed: 01/27/14 Page 3 of 7 PageID #:14767

Mr% &him5o !ointe" out, the name GIN coul" be challenge" by a News *gency that has been using that name #or many years be#ore GIN was establishe"%

&o, can we $all the Members o# the club) get together to stan" as 8ne an" !ool our resources to buy the I,/

0e!resenting &-GF.-IN, I communicate" with Greg 1ramer who re!resente" himsel# as the s!o5esman #or the 0ecei(er en"orse" 90oun" 2able: grou!% I communicate" with him in an attem!t to unite all members as one an" accom!lish a !ower#ul negotiating !osition as mentione" abo(e% I ma"e it clear that that a#ter months o# (ery har" wor5 an" a substantial amount o# Members contributions, &-GF.-IN has e(erything in !lace #or this ne;t ste! to ta5e !lace<

2he attorneys ha(e been retaine" an" are u! to s!ee" on e(ery as!ect o# accom!lishing our goal o# ac uiring the I, assets an" launching our club un"er the new legal entity 6 -IN=

2he #un" is set u! to contribute to #or the !urchase o# GIN IP assets, as well as to !ay the legal an" all other e;!enses relating to the reestablishment o# e(erything we en4oy about the club%

*n" we ha(e the bac5ing o# a!!ro;imately >00 Members an" counting that ha(e re ueste" to be !lace" on the ,lainti## list, !lus other contributors that ha(e not as yet re ueste" to be on the list%

I #urther o##ere" to Mr% 1ramer an" the entire 0ecei(er ?n"orse" 0oun" 2able grou!, who ha(e yet to i"enti#y themsel(es3 I o##e" to arrange a con#erence call with our attorney, 2imothy &him5o, whom I hire" to re!resent all GIN Members% I o##ere" this to allow all o# these 0oun" 2able !artici!ants the o!!ortunity to communicate with our attorney an" as5 any uestion they "esire" to clari#y

anything they were unclear about regar"ing what we+(e "one so #ar or !lan to "o #rom this !oint on%

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Case: 1:03-cv-03904 Document #: 812-3 Filed: 01/27/14 Page 4 of 7 PageID #:14768

Mr% 1ramer tol" me yester"ay e(ening that he woul" relay this o##er to the entirety o# the 0oun" 2able grou! an" get bac5 to me% &e(eral hours ago, I recei(e" Mr% 1ramer+s re!ly% @e state" that there is no nee" #or him an" his 0oun" 2able grou! to s!ea5 with Mr% &him5o #or they #elt that the o!inion letter I sent out by Mr% &him5o this morning was uite clear an" that he, Greg 1ramer, was going to get another o!inion%

&o while Mr% 1ramer gets his other o!inion be#ore he an" the 0oun" 2able grou! can "eci"e to 4oin with &-GF.-IN to !urchase the I, assets an" create a !ower#ul negotiating #orce o# One #or all Members3 let me o##er you something #or "ee! consi"eration regar"ing this situation%

&ome suggest that it a!!ears to be a choice between starting a new club or buying GIN FDN an" its assets% It isn+t% * new legal entity is necessary #or whate(er grou! !urchases the I, assets #or the reasons liste" at the bottom o# !age 1 o# this u!"ate%

&o the only thing that will e(en necessitate a choice re(ol(es aroun" whether Greg an" 0oun" 2able crew choose to stan" as 8ne with &-GF.-IN in the !urchase o# the I,Aassets%

&houl" Greg an" 0oun" 2able crew choose not to stan" as 8ne with &-GF.-IN then what criteria "oes one utiliBe in their e(aluation o# who to sen" #un"s to/ 2his may seem li5e a "i##icult choice to ma5e3 it isn+t when you

consi"er the #ollowing<

-e all 5now that the GIN &ta## are constraine" an" controlle" by the 0ecei(er by way o# the court or"er a!!ointing the 0ecei(er% 2his is true because the GIN sta## ha(e been an" currently are in 9concert: with a 2ru"eau entity% *n" all 2ru"eau entities are now un"er the control an" 4uris"iction o# the court $see attache" court or"er below in a ,DF "oc)%

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Case: 1:03-cv-03904 Document #: 812-3 Filed: 01/27/14 Page 5 of 7 PageID #:14769

-hat is a brilliant mo(e on the !art o# the 0ecei(er is that as soon as this 90oun" 2able: grou! hea"e" by Greg 1ramer was #orme", it !lace" e(ery !artici!ant therein un"er the control o# the 0ecei(er% 2his is true because the Receiver endorsed in writing the appointment of this Round Table group and its activities, which puts them in concert with a Trudeau Entity, thus binding them, even if they quite, to the terms in the court order appointing the Receiver

In all #airness I "on+t thin5 that e(en these 90oun" 2able: !artici!ants new what they were getting themsel(es into3 at least not all o# them% Cut be that as it may, the choice o# where to !ut your #un"s is now getting easier%

Dou will #in" that since this 90oun" 2able: grou! is now technically in 9concert: with a 2ru"eau ?ntity controlle" by the 0ecei(er that they will be able to utiliBe the GIN FDN to #urther their agen"a an" raise #un"s by way o# site announcements% o##icial GIN

2his ne;t criterion is o# ma4or im!ortance an" shoul" ma5e it clear where not to sen" your #un"s% I# you #un" the 90oun" 2able: grou! the #un"s will li5ely go into a GIN.0ecei(er account which will gi(e the 0ecei(er "irect control o(er an" ownershi! o# that money e(en i# the 90oun" 2able: grou!+s bi" #or the I, assets isn+t acce!te"=

?(en i# the 90oun" 2able: grou! says, oh no, where going to establish a se!arate escrow or other title" account% It won+t remo(e that account #rom 0ecei(er control because the 90oun" 2able: grou! will ha(e o!ene" the account% 2he 90oun" 2able: grou! being in 9concert: with the 2ru"eau ?ntity GIN FDN gi(es the 0ecei(er com!lete control o(er it%

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Case: 1:03-cv-03904 Document #: 812-3 Filed: 01/27/14 Page 6 of 7 PageID #:14770

It "oesn+t matter what the account o!ene" by the 90oun" 2able: grou! is title" or earmar5e"3 once an account is o!ene" by a grou! that is or was in 9concertE with a 2ru"eau ?ntity at the time is sub4ect to 0ecei(er control% *n" the 0ecei(er can an" will brea5 any agreement ma"e with a ban5 hol"ing 2ru"eau ?ntity assets 4ust as they ha(e bro5en the numerous agreements ma"e with the GIN membershi! to "ate%

2his conclu"es my o!inion o# the rele(ant criteria with which to ma5e your "ecision as to where to sen" your money to !urchase the I, assets o# GIN FDN%

In bringing this u!"ate to a close I must em!hasiBe the urgency o# time we ha(e le#t to raise the #un"ing #or the !urchase o# the I, assets as well as the nee" to continue to close the ga! on the balance "ue #or legal e;!enses an" the restart o# the club%

1ee! in min" that we ha(e outsi"er$s) that "o not hol" the same i"eals as those u!on which this club was #oun"e" that will be in the bi""ing #or the I, assets% &o let+s now 4oin together an" get this #un" going now% I# the remain"er o# the acti(e membershi! sen"s the e ui(alent o# the amount o# a month o# "ues o(er the ne;t cou!le o# months that shoul" be enough to secure these I, assets an" get on with the rebuil"ing o# our club%

Do it now #ellow Members3 "o it now while there is still time to "o it%

In closing, let me ma5e it clear that I am a citiBen o# the 7nite" &tates o# *merica an" ha(e e;ercise" my 1st *men"ment right to e;!ress my o!inion herein% 2he o!inion e;!resse" in this u!"ate is not meant to suggest or encourage any course o# action% 2he in#ormation !ro(i"e" herein is solely #or e"ucational an" entertainment !ur!oses base" u!on i"iosyncratic imagination an" con4ecture% No e;actitu"e o# content is im!lie"% ?(eryone must e(aluate an" ma5e u! their own min" on any course o# action they ta5e%

GIN Network Truth (the smart group)

Case: 1:03-cv-03904 Document #: 812-3 Filed: 01/27/14 Page 7 of 7 PageID #:14771

2han5 you,

,erry 1iraly

GIN Network Truth (the smart group)

Case: 1:03-cv-03904 Document #: 813 Filed: 01/27/14 Page 1 of 3 PageID #:14772

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION FEDERAL TRADE COMMISSION, Plaintiff, v. KEVIN TRUDEAU, Defendant. ) ) ) Ca e N!." #$%C%$&#' ) ) H!n. R!(e)t *. +ettle,an ) ) ) ) )

NOTICE OF MOTION PLEASE TAKE NOTICE that, on Thursday, January 30, 2014, at 10:00 a. ., or as soon th!r!a"t!r as #ouns!$ ay %! h!ard, th! und!rs&'n!d sha$$ a((!ar %!"or! th! )onora%$! *o%!rt +. ,!tt$! an, -n&t!d Stat!s .&str&#t Court "or th! North!rn .&str&#t o" I$$&no&s, East!rn .&/&s&on, or su#h oth!r 0ud'! as ay %! s&tt&n' &n h&s ($a#! &n Courtroo 1103, 212 S. .!ar%orn Str!!t, Ch&#a'o, I$$&no&s 30304, and sha$$ (r!s!nt th! Re-eive). M!ti!n f!) Leave t! File S/)%Re0l1 O00! in2 P)!0! ed Inte)ven!) . M!ti!n t! Inte)vene, a #o(y o" 4h&#h &s h!r!%y s!r/!d u(on you. .at!d: January 21, 2014 *!s(!#t"u$$y Su% &tt!d, RO33 EVANS 4 ASSOCIATES LLC, RECEIVER 5y: 6s6 5$a&r 7an8&' 9On! o" Its Attorn!ys: 5$a&r *. 7an8&' 9No. 3213223: John ;. )&$t8 9No.32<2144: Kathy +antu#h 9No. 3224034: HILT5 *ANTUCH 4 5AN5I+ LLC =3 +!st Ja#>son 5$/d., Su&t! 20= Ch&#a'o, I$$&no&s 30304 T!$!(hon!: 312.=33.200< ;a?: 312.=33.201= Counsel for Robb Evans & Associates, Receiver

GIN Network Truth (the smart group)

Case: 1:03-cv-03904 Document #: 813 Filed: 01/27/14 Page 2 of 3 PageID #:14773

CERTIFICATE OF SERVICE I, 5$a&r *. 7an8&', an attorn!y, h!r!%y #!rt&"y that, on th! 21th day o" January, 2014, I #aus!d a tru! and #orr!#t #o(y o" th! "or!'o&n' Not&#! o" @ot&on to %! s!r/!d throu'h th! CourtAs E$!#tron&# Cas! ;&$&n' Syst! on th! "o$$o4&n':

K& %a$$ *&#hard And!rson >and!rsonB4&nston.#o Tho as L!! K&rs#h, II t>&rs#hB4&nston.#o Kath!r&n! E. *oh$" >#ros4!$$B4&nston.#o @&#ha!$ @ora oraB"t#.'o/ Jonathan Coh!n J#oh!n2B"t#.'o/ A anda 5. Kostn!r a>ostn!rB"t#.'o/ .a/&d OAToo$! dotoo$!B"t#.'o/ T& othy A. Sh& >o tash& >oB' a&$.#o .an&!$ St!(h!n Sh& >o .sh& >o0=B' a&$.#o Andr!4 ,ordon a%'B'ordon$a4$td.#o Just&n S#h!&d d!%ra%u!ttn!rBao$.#o

6s6 5$a&r *. 7an8&'

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Case: 1:03-cv-03904 Document #: 813 Filed: 01/27/14 Page 3 of 3 PageID #:14774

6s6 5$a&r *. 7an8&'

GIN Network Truth (the smart group)