Trudeau Civil Case Document 805 0 Receivers Status Report For December 19 Hearing PLUS Exhibits 12-17-13

Case: 1:03-cv-03904 Document #: 805 Filed: 12/17/13 Page 1 of 10 PageID #:14391
UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION FEDERAL TRADE COMMISSION, Plaintiff, v. KEVIN TRUDEAU, Defendant. ) ) ) Case No.: 03-C-3904 ) ) Hon. Robert W. Gettleman ) ) ) ) )
RECEIVERS STATUS REPORT FOR DECEMBER 19, 2013 HEARING During the course of the status hearing held on December 5, 2013, the Court suggested that in anticipation of the hearing currently scheduled for December 19, 2013, it would assist the Court for the Receiver to submit a written status regarding its various requests to Mr. Trudeau. Accordingly, the Receiver submits the following report: BACKGROUND The Receiver is unaware of any material change regarding the status of any of its outstanding requests to Mr. Trudeau. Further, the Receiver is unaware of any steps taken by Mr. Trudeau since the last hearing to purge his contempt. Accordingly, coercive sanctions remain appropriate and necessary to obtain Mr. Trudeaus complete compliance with the Courts orders and thereby maximize recovery on behalf of consumers. While counsel for Mr. Trudeau has sent emails nominally requesting the information sought by the Receiver from Mr. Trudeaus various surrogates, Mr. Trudeaus compliance must be measured by the results of his efforts, i.e. whether there has been actual disclosure. Only Mr. Trudeau knows which strings to pull in order to cause a full disclosure of all of his assets. disclosure by any measure. As detailed below, Mr. Trudeau has not made a full
GIN Network Truth (the smart group)
Accounting and Bank Records for WSS and GSS Under the Receivership Order, both Website Solutions Switzerland (WSS) and Global Sales Solutions (GSS) are designated as Trudeau Entities. As such, Mr. Trudeau is required to turnover all books and records related to those entities. The Receivership Order details the documents to be turned over as including: all books and records of Assets including funds and property, all financial and accounting records, balance sheets, income statements, bank records (including Monthly statements, canceled checks, records of wire transfers, records of ACH transactions, and check registries), corporate minutes, contracts, customer and consumer lists, title documents, and electronic records. (Receivership Order VI(3).) The Receiver has repeatedly sought such records for WSS and GSS. In an October 17, 2013 email authorizing Mr. Trudeau to contact Mr. Lee Kenny and Ms. Barbara Schoop in order to effect the turnover of assets, the Receiver expressly requested a complete accounting with bank statements and backup copies of deposits, wire transfers and checks (front and back) from the inception of the account to date) for both WSS and GSS. (See Ex. A (10/17/2013 Email from B. Kane to K. Trudeau).) In letters to counsel for Mr. Trudeau dated October 23 and 25, 2013, the Receiver again identified the turnover of accounting and bank records for WSS and GSS (among others) as specific steps Mr. Trudeau could take to assist the Receiver. (See Group Ex. B (10/23/2013 Letter from B. Zanzig to K. Anderson 1 & 3 and 10/25/2013 Letter from B. Zanzig to K. Anderson 2, 5.)1 On October 26, 2013, counsel for Mr. Trudeau forwarded to the Receiver correspondence from Mr. Kenny attaching limited account statements for WSS and GSS. (Ex. C (10/26/2013
1
For the sake of completeness, these letters were previously filed with the Court and appear on the docket as entries nos. 783 and 786, respectively. Additionally, the response by Mr. Trudeaus counsel to the October 25, 2013 letter [Dkt. #786] also appears on the docket as entry no. 787.
Email from K. Rolfe to B. Kane et al.) (attachments omitted).)2 Specifically, with respect to GSS, the Receiver was provided a statement for an account at Credit Suisse showing the last 1000 entries, which appears to include the inception of the account in October 2012, and reflects that over 99% of the funds comes from Global Information Network Fdn (GIN-FDN). Despite the fact that the Receiver agreed to treat such documents as confidential pursuant to the Confidentiality Order entered on February 14, 2008, nearly all of the account entries have some portion of them blacked-out thereby hampering a review of even these limited records. With respect to WSS, the Receiver has been provided a single half page ledger purporting to show an account for Website Solutions GmbH for the period January 1, 2013 through February 15, 2013, including a substantial balance as of February 15, 2013. Again, approximately 98% of the funds reflected on this statement come from GIN-FDN. The Receiver received no other statements or internal accounting records (much less the detailed records required by the Receivership Order) for either WSS or GSS. Nor has the Receiver been provided access to or control over the funds in either WSS or GSS bank accounts. In addition to the subsequent status hearings during which the Receiver has repeatedly raised the lack of disclosure with respect to these two entities, the Receiver specifically requested records relating to WSS and GSS on at least two other occasions. In a November 14, 2013 email to Mr. Trudeau, the Receiver explained that Mr. Trudeaus surrogates had still not provided the accounting and bank records for WSS and GSS. (Ex. D (11/14/2013 Email from K. Johnson and B. Kane to K. Trudeau).) Most recently, in a December 4, 2013 email, the Receiver
To induce Mr. Kenny to provide such documents, the Receiver has agreed to treat the account statements produced by him as confidential pursuant to the confidentiality order entered in this case. Accordingly, the Receiver is omitting these documents from this publicly filed document. To the extent the Court wishes to review these statements, the Receiver is prepared to provide the Court copies for in camera review or, if authorized, will file them under seal.
again told Mr. Trudeau (through counsel) that providing the missing accounting and banking records for WSS (among others) was one of the steps Mr. Trudeau might take toward purging his contempt. (Ex. E (12/4/2013 Email from B. Zanzig to T. Kirsh).) On December 4, 2013, the evening before the last hearing, counsel for Trudeau sent a number of emails to Mr. Trudeaus surrogates requesting the additional records relating to GSS and WSS. (Group Ex. F (email exchanges between K. Rolfe and L. Kenny and B. Schoop). Although Mr. Kenny asserts that he has fully complied with the Receivers requests, the Receiver has been provided no records regarding WSS or GSS other than those described above. Accounting and Bank Records for Future Transactions Company and Office Pool. Parallel with its requests for information regarding WSS and GSS, the Receiver has also sought information regarding two other related entities, Future Transactions Company Ltd. (FTC) and Office Pool GmbH (Office Pool). (See Exs. A, B, D & E.) Although neither were expressly identified in the Receivership Order, both FTC and Office Pool appear to be closely intertwined with the flow of funds among GIN-FDN, GSS, and WSS. For example, as the Receiver identified in its first supplemental report, since January 2013, GIN-FDN has transferred more than $644,000 to Office Pool, purportedly on account of commission payments due to Mr. Trudeau. (See Receivers 1st Supp. Rpt. [Dkt. #750] at Ex. 6 (p.2).) With respect to FTC, Mr. Kenny conceded that FTC had paid 251,569.46 British Pounds (or more than $400,000) on account of Mr. Trudeaus legal fees, corresponding to approximately a third of FTC income belying any suggestion that the FTC is an independent entity beyond Mr. Trudeaus
control. (Ex. G (10/27/2013 Email from L. Kenny) at 2 (discussing transfers made by FTC for benefit of K. Trudeau).)3 In order to trace the flow of funds from the various Trudeau Entities through these entities, the Receiver has requested an accounting of such payments, including accounting and bank records from their inception. On October 26, 2013, Mr. Kenny provided a bank statement for one account for Office Pool held at the Swiss bank, Zurcher Kantonalbank. (See Ex. C (attachments omitted).) That statement reflects that Office Pool holds another account, which was not provided to the Receiver. On October 28, 2013, Mr. Kenny provided bank statements for an account held at HSBC in the name of Future Transactions Company Limited. Rather than providing account statements from inception, Mr. Kenny only provided account statements from 2013. Again, despite the Receivers agreement to treat such statements as confidential pursuant to the confidentiality order entered in this case, nearly all of the transaction descriptions on both statements were redacted in some part. In addition, the Receiver has sought an accounting of payments made by Office Pool to Mr. Trudeau or on his behalf, and for payments received by Office Pool on account of Mr. Trudeau, including supporting documents such as invoices. (See Exs. A, B, & D.) To date, no such information or supporting documentation has been provided to the Receiver. Access to William Hill Account As the Receiver previously reported, Mr. Trudeau maintains an account with the online casino operator William Hill. On November 14, 2013, the Receiver notified Mr. Trudeau that the access credentials he previously provided to the Receiver no longer provided access to the account. (See Ex. D.) The Receiver has requested that Mr. Trudeau direct the William Hill
3
This email was original disclosed to the Court as Exhibit 6 to Trudeaus counsels October 28, 2013 correspondence with the Receiver. (See Dkt. #787.)
entity to wire the remaining funds in the account to the Receivers account. (Id.) To date, the Receiver has not been provided such funds. NBT Trading / APC Trading Limited. Michael van Roon, an asset-protection specialist that purports to represent Mr. Trudeaus wife, Natalia Babenko, reported that one of the Trudeau Entities, NBT Trading Ltd., likely still had a bank account in Hong Kong with a balance of around $30,000. (See Ex. H (10/24/2013 Email from M. van Roon to K. Rohlf) at 3.) The Receiver has requested that Mr. Trudeau cause such funds to be transferred to the Receiver. (See Ex. D.) To date, the Receiver has not been provided such funds. Migros Bank Account Transfers As the Receiver reported in its Third Supplemental Report, Mr. Trudeau violated the Courts prior orders by failing to turnover the funds held in an account at Migros Bank in Switzerland. (See Receivers 3d Supp. Rpt. [Dkt. #796].) Instead, on August 23, 2013 nearly a month after the Court froze Mr. Trudeaus assets, Mr. Trudeau or someone authorized by him transferred 67,909 Swiss Francs from such account to third parties, including 62,671 Swiss Francs to FTC, and 5,000 Swiss Francs to Brandy Burkhardt, who the Receiver understands is Mr. Trudeaus personal assistant. (Id.) On November 18, 2013, the Receiver demanded Mr. Trudeau return such funds to the Receivership estate. (See id at 2.) Subsequently, at the request of Mr. Trudeaus counsel, Ms. Burkhardt wired the 5,000 Swiss Francs to the Receiver. On November 27, 2013, the Receiver directly contacted Mr. Kenny and requested the return of the funds transferred to FTC. (See Ex. I (11/27/2013 Email from B. Kane to L. Kenny).) In his initial reply, Mr. Kenny responded that the Mr. Trudeaus counsel had made a
similar request to him. (Id.) After purporting to investigate the transaction, Mr. Kenny later offered a convoluted explanation that the transfer was somehow related to monies advanced to Mr. Trudeau to test one of our gambling information products. (See Ex. J (12/2/2013 Email from L. Kenny to K. Rohlf).) Mr. Kenny refused to return the funds transferred in violation of the Courts order unless the Receiver agreed to turn over the balance of funds in the William Hill account, which Mr. Kenny now claims belongs to FTC. (Id.) During previous status hearings, counsel for Mr. Trudeau has attempted to explain these violations as the result of transfers authorized before the Courts asset freeze. Such explanations ignore the intervening month in which Mr. Trudeau could have taken steps to disclose the account and turnover the funds to the Receiver before the August 23 transfers were effective. Trudeaus UBS and Zurcher Kantonalbank Accounts In addition to his account at Migros Bank, Mr. Trudeau also held bank accounts at both UBS and Zurcher Kantonalbank. In an effort to obtain the records from those accounts, the Receiver provided those institutions a letter requesting such records and attached a certified copy of the Receivership Order with a corresponding apostile and a direction letter signed by Mr. Trudeau. While Migros Bank provided the requested account statements, both UBS and Zurcher Kantonalbank invoked Swiss banking privacy laws that they asserted precluded compliance with requests from third parties. Accordingly, in its December 4 email to Trudeaus counsel, the Receiver urged Mr. Trudeau to contact those institutions to obtain all records relating to his accounts and to transfer any remaining funds to the Receiver. (Ex. E.) The Receiver is unaware of any action taken with respect to this request.
The Receivers Ongoing Investigation As reported at the last hearing, the Receiver has discovered a previously unknown account held in Natalia Babenkos name at Bank of New York Mellon. The Receiver has issued a subpoena seeking such records, which is initially returnable on December 20, 2013. The Receiver has recently obtained additional records from the MGM Grand Casino in Las Vegas, Nevada reflecting substantial gambling activity by Mr. Trudeau in 2012. The Receiver analyzed these records and has identified a currency transaction report evidencing redemption of casino chips for $153,075 in cash and is in the process of attempting to identify any corresponding deposits of cash in Mr. Trudeaus accounts. (See Ex. K (Currency Transaction Report by Casinos).) Although Mr. Trudeau enumerated the MGM Grand as one of the possible casinos at which he maintained an account, Mr. Trudeau never disclosed or suggested that he had withdrawn more than $150,000 in cash from an account at MGM Grand as recently as April 2012. (Ex. L (Decl. of J. Cohen) 3 & 5.) In failing to fully come clean regarding this transaction, Mr. Trudeau failed to provide the Receiver with a full accounting of his assets and delayed the Receiver and the FTC from then investigating the source of such funds and the current disposition of those amount. (See id. 4.) In addition, the Receiver has located documents that appear to show that Mr. Trudeau has or had an account at BTA Bank in Kiev, Ukraine. The Receiver currently does not have any information about this account. (See Ex. M.) CONCLUSION As reflected above, Mr. Trudeau has failed to make a full disclosure and accounting of his assets and should remain coercively incarcerated until he does so. For such sanctions to have a coercive effect, Mr. Trudeau must understand that he will remain incarcerated until he takes
action to purge such contempt, rather than merely wait for the next status hearing to see if the Receiver has discovered any new assets or has completed his report.4 Rather than continue to set short status dates, the Receiver believes that coercive sanctions will be most effective if longer status dates are set with the caveat that Mr. Trudeau may at any time request a hearing in order to demonstrate that he had taken some concrete actions that have had the effect of purging his contempt. Dated: December 17, 2013 Respectfully submitted, ROBB EVANS & ASSOCIATES LLC, RECEIVER By: /s/ Blair Zanzig (One of Its Attorneys) Blair R. Zanzig (No. 6273293) John Hiltz (No. 6289744) Kathy Wantuch (No. 6294034) HILTZ WANTUCH & ZANZIG LLC 53 West Jackson Blvd., Suite 205 Chicago, Illinois 60604 Telephone: 312.566.9008 Fax: 312.566.9015 Counsel for Robb Evans & Associates, Receiver
Courts have recognized that incarceration for civil contempt may continue indefinitelyuntil the Court determines that at incarceration no longer has a coercive effect. See United States ex rel. Thom v. Jenkins, 760 F.2d 736, 740 (7th Cir. 1985) (We also note that although incarceration for civil contempt may continue indefinitely, it cannot last forever. If after many months, or perhaps even several years, the district judge becomes convinced that, although Thom is able to pay he will steadfastly refuse to yield to the coercion of incarceration, the judge would be obligated to release Thom since incarceration would no longer serve the purpose of the civil contempt order-coercing payment.) (internal citation omitted). Indeed, to the extent that Mr. Trudeau believes that his incarceration for civil contempt is close to an end whether he takes action or not, Mr. Trudeau will have little incentive to purge such contempt.
CERTIFICATE OF SERVICE I, Blair R. Zanzig, an attorney, hereby certify that, on the 17th day of December, 2013, I caused a true and correct copy of the foregoing Receivers Status Report for the December 19, 2013 Hearing to be served through the Courts Electronic Case Filing System on the following:
Kimball Richard Anderson kanderson@winston.com Thomas Lee Kirsch, II tkirsch@winston.com Katherine E. Rohlf kcroswell@winston.com Michael Mora mmora@ftc.gov Jonathan Cohen Jcohen2@ftc.gov Amanda B. Kostner akostner@ftc.gov David OToole dotoole@ftc.gov
/s/ Blair R. Zanzig
Case: 1:03-cv-03904 Document #: 805-1 Filed: 12/17/13 Page 1 of 4 PageID #:14401
EXHIBIT A
Case: 1:03-cv-03904 Document #: 805-1 Filed: 12/17/13 Page 2 of 4 PageID #:14402 Blair Zanzig
From: Sent: To: Cc: Subject: brick kane < Thursday, October 17, 2013 11:15 AM 'Kevin Trudeau'; 'Kenton Johnson' 'Thomas L. Kirsch'; Blair Zanzig RE:
Kevin, I will be sending you an email within the next hour or two with some information we need from Lee Kenny and Barbara Schoop. After you receive that email, you have our permission to contact them. Brick -----Original Message----From: Kevin Trudeau [mailto: Sent: Thursday, October 17, 2013 4:56 AM To: Kenton Johnson Cc: ; Thomas L. Kirsch Subject:
Kenton, I need to be able to call and email Lee Kenny and Barbara Schoop and order them to turn over the GIN and WSS bank accounts to you. May I have permission to contact them? The court said I need to ask you before I do that. Kevin Trudeau ----No virus found in this message. Checked by AVG - www.avg.com Version: 2012.0.2242 / Virus Database: 3222/6255 - Release Date: 10/16/13
GIN Network Truth1 (the smart group)
From: Sent: To: Cc: Subject: Attachments: brick kane < Thursday, October 17, 2013 12:33 PM 'Kevin Trudeau'; 'Kenton Johnson' 'Thomas L. Kirsch'; Blair Zanzig RE: List..pdf >
Kevin, Please see attached. Brick
-----Original Message----From: Kevin Trudeau [mailto: Sent: Thursday, October 17, 2013 4:56 AM To: Kenton Johnson Cc: brick_kane@ ; Thomas L. Kirsch Subject:
Kenton, I need to be able to call and email Lee Kenny and Barbara Schoop and order them to turn over the GIN and WSS bank accounts to you. May I have permission to contact them? The court said I need to ask you before I do that. Kevin Trudeau ----No virus found in this message. Checked by AVG - www.avg.com Version: 2012.0.2242 / Virus Database: 3222/6255 - Release Date: 10/16/13
1. Website Solutions Switzerland: Provide a complete accounting with bank statements and backup copies of deposits, wire transfers, and checks (front and back) from the inception of the account to date. 2. Futures Transactions: Provide a complete accounting with bank statements and backup copies of deposits, wire transfers, and checks (front and back) from the inception of the account to date.
3. Office Pool: Provide a list of payments from this company for the benefit of Kevin Trudeau or persons acting in concert as defined in August 7, 2013 Order. Provide a list of receipts that the company received as of result of Kevin Trudeau. Provide invoices from Office Pool for services provided and payments received for the service provided for the benefit of Kevin Trudeau or persons acting in concert as defined in August 7, 2013 Order.. 4. Global Sales Solutions AG: Provide a complete accounting with bank statements and backup copies of deposits, wire transfers, and checks (front and back) from the inception of the account to date.
EXHIBIT B
Case: Case:1:03-cv-03904 1:03-cv-03904Document Document#: #:805-2 783-1Filed: Filed:12/17/13 10/24/13Page Page2 4of of10 7 PageID PageID#:14004 #:14406
HILTZ WANTUCH & ZANZIG Sender's Direct: Sender's Email:
October 23,2Ot3
VIA EMAIT Kimball R. Anderson
Winston & Strawn
LLP
35 West Wacker Drive Chicago, lL 60601-9703
Re:
FTC v. Kevin
Trudeau, No. 03-C-3904 (N.D. lll.)
Dear Kimball,
write in response to your October 22,2OI3letter to Brick Kane and Kenton Johnson of the Receiver's office.
I
First, the Court - not the Receiver has established the conditions Mr. Trudeau needs to satisfy in order to purge his contempt. The Receiver is not empowered to provide a list, as you put it, of "additional information needed from Mr. Trudeau so that he can purge his contempt finding." Mr. Trudeau may at any time purge his contempt by meeting the conditions the Court has set. Relatedly, the Receiver rejects your linking completion of the Receiver's forensic accounting to Mr. Trudeau's ability to purge his
contempt. As set forth in the briefing before the Court, the Receiver is forced to conduct a forensic accounting because of Mr. Trudeau's failure to provide full disclosure consistent with the Court's rulings.
In an effort to accommodate the spirit of your request, the Receiver sets forth below a summary of the issues on which, based on its work to date, it is seeking additional information and has requested Mr. Trudeau's assistance. Again, in setting forth these items, the Receiver is not purporting to create an
exhaustive list of steps Mr. Trudeau must take to purge his contempt; nor is this an "action plan" for Mr. Trudeau to purge his contempt. Only Mr. Trudeau has full information regarding his assets. Mr. Trudeau should disclose any information he is aware of relating to his assets or otherwise addressed in the Court's order regardless of whether it is specifically asked for here. Mr. Trudeau should read these items expansively to seek the broadest possible disclosure. Mr. Trudeau should be as detailed and specific as possible in his disclosures, including identifliing where appropriate specific dates and accounts.
L.
As required by Court's August 7,2Ot3 Order (the "Receivership
Orde/'), Mr. Trudeau should
deliver to the Receiver possession and custody of "All Documents of Trudeau and all Trudeau Entities." As the Receivership Order further specifies, such documents include without limitation: "all books and records of Assets including funds and property, all financial and accounting records, balance sheets, income statements, bank records (including monthly statements, canceled checks, records of wire transfers, records of ACH transactions, and check registries), corporate minutes, contracts, customer and consumer lists, title documents, and
Kimball Anderson, Page 2
october 23,20L3
electronic records." (Receivership Order at S Vl(3).) To date, the Receiver has not received complete records from the following Trudeau Entities: 0913372 B.C. Ltd.; 0913376 B.C. Ltd.; Advantage Solutions Ltd; APC Trading Limited; Global Information Network FDN; Global Sales Solutions A.G.; KMT Fiduciary Trust; Natural Cures Holdings Inc.; NBT Trading Limited; N.T. Trading S.A.; Website Solutions Switzerland GmbH.
2. Although largely duplicative of the documents required to be produced under the Receivership
Order, Mr. Trudeau should produce the items identified in the attachment to Brick Kane's October L7,2Ot3, L2:33 PM email to Mr. Trudeau.
3.
Provide a full and verifiable description of the relationship between GIN-FDN, Website Solutions Switzerland ("WSS"), Office Pool, Future Transactions Company, and Global Sales Solutions ("GSS") and his relationship with such entities, including copies of all agreements and correspondence among such entities themselves and with Mr. Trudeau, and all evidence of any financial transfers among any of them. In the course of providing such information and without limitation, Mr. Trudeau should fully explain and account for the following:
a.
The transfers of Mr. Trudeau's GIN commissions from GIN-FDN to Office Pool in the amount of 5644,727.70 from January 1,20L3 through September 6,2Ot3. In explaining these transfers, Mr. Trudeau should provide (i) the reasons for such transfers, including any agreements or correspondence verifying such explanations, and (ii) the present
disposition of such funds.
b.
Marc Lane's relationship with any those entities, including all transfers from GIN-FDN,
WSS, Office Pool, Future Transactions Company, and GSS to Mr. Lane such as the wire transfer evidenced by PXA:24 attached to the FTC's Reply in Support of Coercive
Sanctions [Dkt. #767-1]. Such explanation should include all related documents, including any agreements, correspondence and financial records'
c.
The royalty agreement with Future Transactions Company referenced in the December 10,2OL2 email from Mr. Trudeau to Neal Sant and Jeff Devine, a copy of which was attached as PXA:9 to the FTC's Statement Concerning Defendant's Letters of Direction [Dkt. #7741, and an accounting of all payments made pursuant to such agreement.
d.
Account for all payments received by WSS on account of speaking engagements or other services provided by Mr. Trudeau and provide all documents relating to such payments, including agreements and correspondence, accounting records evidencing such payments, and the present disposition of such payments.
4.
Provide a full accounting of all income received by Mr. Trudeau or paid on account of Mr. Trudeau from the entities listed in paragraph number 1 above including without limitation his GIN commissions and revenues from his infomercials. Such accounting should specifically identify the accounts to which such transfers were made, or if paid on Mr. Trudeau's account (such as the GIN commissions paid to Office Pool), the reasons for such payments and the
current disposition of such funds.
October 23,2013
5.
Provide a full accounting of all transfers from Trudeau or the Trudeau Entities to Mr. Trudeau's wife or for her benefit (including to any members of her family) greater than 55,000, including without limitation, the nature and circumstances of such transfer (e.g. wire transfer, gift of gold bars or jewelry etc.), the specific source of funds used for the transfer, including any accounts to which such transfers were made, and the present disposition of such funds or other assets.
In the course of providing this information, Mr. Trudeau should fully account for transfers made in connection with the Kiev apartment described in the FTC's and Receiver's pleadings regarding the imposition of coercive sanctions and the accompanying exhibits. Mr. Trudeau should turnover such apartment to the Receiver, or otherwise provide verifiable evidence establishing his inability to do so.
b.
Account for the transfer of S15,345.02 from GIN-FDN to Nataliya Babenko's account at the Global Bank of Commerce in Antigua on August 20,20'J,3 (as evidenced by the wire transfer record attached as Exhibit 7 of the Receiver's Supplemental Report [Dkt. # 7501), including the reason for such payment and the present disposition of such funds.
6.
Describe the circumstances and purpose surrounding the formation of each of the off-shore Trudeau Entities, including identifying any business or other activities such entities conducted and any assets owned by such entities. To the extent that such entities were formed as part of an "asset protection strategy," identify the assets such strategy was designed to protect. ldentify and provide all evidence relating to such description, including all communications relating to these entities, the identity of all persons with knowledge of such entities and their activities, all information necessary for the Receiver to assume control of these entities. ln the course of providing such explanation, Mr. Trudeau should account for the following:
a.
The reasons that Mr. Trudeau requested corporate formation documents for NT Trading S.A. (Panama) as reflected in the April 21, 2009 emailfrom Mr. Trudeau to NealSant, which is attached as Exhibit PXA:8 to the FTC's Statement Regarding the Need for Coercive Sanctions [Dkt. # 759] (the "FTC's Statement"). The circumstances surrounding the Power of Attorney prepared by Marc Lane relating to NTTrading S.A., as evidenced by exhibits PXA:9 and PXA:1-0 attached to the FTC's
b.
Statement IDkt. #759].

c
The circumstance surrounding the "ari deal" (presumably a reference to Ari Wasserman), referred to in the November 25,2012 emailfrom Mr. Trudeau to Neal Sant (attached as exhibit PXA:L5 to the FTC's Reply in Support of Coercive lncarceration), including the terms of such deal and the reasons that such deal "should be with nbt trading limited" rather than in Mr. Trudeau's personal name as Mr. Trudeau indicated in the referenced email, and all records relating to such deal.
7.
Provide a full and verifiable accounting of all purchases of precious metals, including any coins, by Mr. Trudeau, his wife, any of the Trudeau Entities, or anyone acting on Mr. Trudeau's behalf. Such accounting should include, without limitation, the circumstances and reasons for the purchase, the parties to the purchase, the items purchased, the terms of the sale (e.g. quantity and price), the specific source of funds used to purchase such items, and the present disposition
October 23,2Ot3 of such items. lf such items have since been sold, Mr. Trudeau should provide the details of such sale and account for the proceeds from such sale. In the course of providing this information, Mr. Trudeau should specifically account for the additional gold described in the records cited in the FTC's Statement [Dkt. # 759] at 7 under the heading "More Gold" and
accompanying footnotes.
8.
provide a full and verifiable accounting of the cufflinks identified in the Receiver's Statement Supporting the lmposition of Coercive Sanctions [Dkt. #764] at 8-9 and Exhibit C' Such accounting should identify the current disposition of such cufflinks or account for the proceeds
from their sale.

please do not hesitate
to contact me if you have any questions regarding the foregoing'
Blair R. Zanzi
Member
Cc:
BrickKane( Ke nton Johnso n
HILTZ WANTUCH & ZANZIG Sender's Direct: Sender's Email:
October 25,2OL3
VIA EMAIL Kimball
R.
Anderson
LLp
Winston & Strawn
35 West Wacker Drive Chicago, lL 60501-9703
Re:
FTC v. Kevin
Trudeou, No. 03-C-3904 (N.D. il1.)
Dear Kimball, During the hearing on October 24,2O!3, the Court asked the Receiver to identify steps that Mr. Trudeau could take while incarcerated to assist the Receiver.
As a threshold matter, the Receiver obserues that Mr. Trudeau, like any contemnor who is incarcerated, may take steps to purge his contempt by providing sufficient instructions to others who can act on those
Trudeau (and his counsel) have told the Court that they do not dispute that Mr. Trudeau possesses control over the Trudeau Entities. Mr. Trudeau and his counsel have also represented to the Court that Mr. Trudeau's surrogates overseas have already fully committed to cooperating by following Mr. Trudeau's instructions. lf so, it would seem all that is left is for Mr. Trudeau to give the necessary
commands. Otherwise, a contemnor could always escape incarceration by claiming that confinement itself prevents him from personally purging his contempt. Here, unlike other contemnors who have been held in contempt over their claims that they had no ability to control persons overseas,l Mr.
instructions.
Further, the Receiver understands that under Bureau of Prison policy as reflected in the MCC Chicago Inmate Admission and Orientation Handbook,
k.pdf, Mr. Trudeau has access to telephones and mail. Although Mr. Trudeau has yet to request any, the Receiver would support, and believes the court would be amenable to ordering, any special access that Mr. Trudeau requires.
with the forgoing in mind, the Receiver identifies the following actions Mr. Trudeau can take while incarcerated - all of which address issues raised during the first two months of the Receivership, including most recently in my October 23, 2Ot3letter to you:
Affordable Media, LLC, t7g F.3d 7228, L243-44 (9th Cir. 1999) (affirming contempt finding over defendants' objections that they did not control overseas trust and refusing to legitimize defendants' asset protection scheme that was working precisely as the defendants, had intended).
See, e.g., FTC v.
Kimball Anderson, page 2
October 25,2073
7'
First and foremost, as the Court has rejected Mr. Trudeau's claimed inability to pay the judgment against him, Mr. Trudeau should pay the judgment. Mr. Trudeau uniquely possesses the knowledge of what assets are available to pay the judgment and how they can be turned over' From his cell, he should use such knowledge to cause the judgment to be paid by using the same methods to make such payments that are available to any other contemnor who is coercively incarcerated for failing to turnover their assets. At a minimum, Mr. Trudeau should take the following steps towards paying the judgment:
a'
b.
Mr. Trudeau should cause the turnover of the Kiev apartment purchased with funds from the Trudeau Entities. Mr. Trudeau should cause the turnover of the 515,345.02 transferred to his wife,s Global Bank of Commerce account in Antigua after the Court's asset freeze was put into place as well as any other funds transferred to his wife by Mr. Trudeau, the Trudeau Entities or any of their surrogates.
c'
d.
Mr' Trudeau should cause the turnover of all gold bars, precious metals, coins, and jewelry (including cuff links)that he and/or his wife purchased using monies derived from the Trudeau Entities, or turnover the proceeds from the sale of such assets.
Mr. Trudeau should cause the turnover of the approximate Stso,ooo that Mr. Trudeau says exists in accounts owned by Website Solutions Switzerland and Global Sales
Solutions, and any other funds held for his benefit.
lf the funds that Mr. Trudeau turns over pursuant to paragraph L above are insufficient to satisfy the judgment, Mr. Trudeau should also do the following:
2.
Mr. Trudeau can cause the documents identified in Brick Kane's October !7,2oL3,12:33 pM email to Mr. Trudeau to be turned over to the Receiver. For your convenience, I have quoted those items here: "Website Solutions Switzerland: Provide a complete accountinB with bank statements and backup copies of deposits, wire transfers, and checks (front and back) from the inception of the account to date. "Futures Transactions: Provide a complete accounting with bank statements and backup copies of deposits, wire transfers, and checks (front and back) from the inception of the account to date.
"office Pool: Provide a list of payments from this company for the benefit of Kevin Trudeau or persons 'acting in concert' as defined in [the] August 7,2Ot3 Order. provide a list of receipts that the company received as [a] result of Keven Trudeau. provide invoices from Office Pool for services provided and payments received for the service provided for the benefit of Kevin Trudeau or person 'acting in concert' as defined in August 7 ,20L3 Order[.]
Kimball Anderson, Page October 25,2OL3
3
"Global Sales Solutions AG: Provide a complete accounting with bank statements and backup copies of deposits, wire transfers, and checks (front and back) from the inception of the account to date.,,
3.
Mr. Trudeau can cause the production of complete accounting records for GIN-FDN, including without limitation balance sheet, income statements and general ledger. Mr. Trudeau can provide copies of all of his personal bank statements and copies of checks from 2004to 2007.
4.
While the Receiver rejects the premise that Mr. Trudeau can only be required to complete tasks that he himself can personally physically perform from prison - an interpretation that would dramatically limit the effectiveness of coercive incarceration - the Receiver identifies the following disclosures Mr. Trudeau should make:
5.
Mr. Trudeau can provide a written statement describing the relationship between GIN-FDN, Website Solutions Switzerland ("WSS"), Office Pool, Future Transactions Company, and Global Sales Solutions ("GSS") and his relationship with such entities. In the course of providing such information and without limitation, Mr. Trudeau should fully explain the following:
a. b.
The transfers of Mr. Trudeau's GIN commissions from GIN-FDN to Office pool totaling 5644,727 .70 from January I,2OI3 through September 6,2013. The circumstances surrounding the royalty agreement between Mr. Trudeau and Future Transactions Company referenced in the December 10, 2012 email from Mr. Trudeau to Neal Sant and Jeff Devine, a copy of which was attached as PXA:9 to the FTC's Statement Concerning Defendant's Letters of Direction lDkt. #774). The purported payment of legal fees on behalf of Mr. Trudeau totaling 251,,569 British Pounds (or $402,919.88 based on today's exchange rate), which is approximately a third
c'
of that company's revenue as reported by Lee Kenny in his Octob er 23,2013 email to Katherine Rohlf, especially given that Mr. Trudeau has asserted that Future Transactions Company is a legitimate business independently owned by Lee Kenny. Mr. Trudeau should explain what transfers he, the Trudeau Entities, or other persons/entities acting on his behalf have made to Future Transactions Company.
6.
Mr. Trudeau should provide a written statement describing the circumstances and purposes surrounding the formation of each of the off-shore Trudeau Entities, including identifying any business or other activities such entities conducted and any assets owned by such entities. To the extent that such entities were formed as part of an "asset protection strategy," Mr. Trudeau should describe the assets such strategy was designed to protect. Given Mr. Trudeau's prior suggestions that such entities were not active, Mr. Trudeau should account for the following:
a.
The reasons that Mr. Trudeau requested corporate formation documents for NT Trading S.A. (Panama) as reflected in the April 21, 2OO9 email from Mr. Trudeau to Neal Sant,
which is attached as Exhibit PXA:8 to the FTC's Statement Regarding the Need for Coercive Sanctions [Dkt. # 759] (the "FTC's Statement,,).
October 25,20t3
b.
The circumstances surrounding the Power of Attorney prepared by Marc Lane relating to NT Trading s.A., as evidenced by exhibits pXA:9 and pXA:10 attached to the FTC,s Statement IDkt. #759]. The circumstance surrounding the "ari dear" (presumably a reference to Ari wasserman), referred to in the November 2s,2ol2 email from Mr. Trudeau to Neal
sant (attached as exhibit PXA:15 to the FTC's Reply in support of coercive Incarceration), including the terms of such deal and the reasons that such deal ',should be with "nbt trading limited" rather than in Mr. Trudeau's personal name as Mr. Trudeau indicated in the referenced email.
7.
Mr' Trudeau should provide a written statement describing all purchases of precious metals, including any coins, by Mr. Trudeau, his wife, any of the Trudeau Entities, or anyone acting on Mr. Trudeau's behalf. Such description should include, without limitation, the circumstances and reasons for the purchase, the parties to the purchase, the items purchased, the terms of the sale (e.g' quantity and price), the specific source of funds used to purchase such items, and the present disposition of such items. lf such items have since been sold, Mr. Trudeau should provide the details of such sale and account for the proceeds from such sale. In the course of providing this information, Mr. Trudeau should specifically address the additional gold described in the records cited in the FTC's Statement [Dkt. # 759] at 7 under the heading "More Gold,, and accompanying footnotes.
Mr. Trudeau should provide a written statement explaining what documents or sources of information Mr. Trudeau consulted in order to provide the Receiver the login information associated with the St. George Bank account.
8.
While the Receiver has compiled this list in good faith, the Receiver stresses that it is not, nor could be, exhaustive. InlightofthesubstantialevidencethatMr.Trudeauhaslongplanned(andpaidsubstantial sums to expert asset protection advisors) to put his assets beyond the reach of the FTC and consumers, only Mr. Trudeau ultimately can know what he needs to do to put those assets in the possession of the Receiver. The items reflected above together with the issues set forth in the briefing before the Court and the Receiver's earlier correspondence reflects the Receive/s view of areas where Mr. Trudeau has not fully disclosed everything within his power. However, as the FTC acknowledged in its Statement Concerning Defendant's Letters of Direction, with which the Receiver fully agrees, if the Court nevertheless "concludes that Mr. Trudeau has honestly disclosed everything he knows concerning his assets, and thus can do nothing further, then Mr. Trudeau should be released." [Dkt. #774 at7.l
the Receiver has steadfastly maintained throughout, the next step forward is for the Receiver to continue to pursue the forensic accounting - a process that will likely take months to complete. The Receiver does not believe that systematically reviewing accounting records with Mr. Trudeau is a productive use of Receivership funds, especially in light of Mr. Trudeau's continued insistence (albeit contrary to the Court's findings) that he was not involved in, and lacks independent knowledge of, his personal finances and the financial activity of the Trudeau Entities. The Receiver is well-qualified to follow the accounting trail wherever it may lead.
As
Case: Case: 1:03-cv-03904 1:03-cv-03904 Document Document #: #: 805-2 786-1 Filed: Filed: 12/17/13 10/25/13 Page Page 10 5 of 5 10 PageID PageID #:14163 #:14414
October 25,2OL3
Please do not hesitate
to contact me if you have any { uestions regarding the foregoing.
Very truly yours,
Cc:
BrickKane(
Kenton Johnson (
)
EXHIBIT C
From: Sent: To: Cc: Subject: Attachments: Rohlf, Katherine E. < > Saturday, October 26, 2013 2:26 PM brick kane ( ); 'Kenton Johnson' ( ); Blair Zanzig Anderson, Kimball R.; Kirsch, Thomas L.; Sullivan, Andrew C.; kevin FW: FTC v. Trudeau - Request for Information office pool wss accounts.pdf; GSS accounts.pdf
Dear Brick, Please find attached documentation from Lee Kenny regarding WSS, GSS and Office Pool. Please let us know ASAP what other information you need regarding these entities, as Mr. Kenny is the one in possession of this information. We also encourage you to reach out to Mr. Kenny directly. He has now demonstrated that he is willing to cooperate (not only through words, but also through actions), so please ask him for whatever else you need (and cc us on any correspondence). Please note that these documents are produced pursuant to the confidentiality order entered in this case (Docket No. 106). Per the court hearing yesterday, it is expected that these documents will be kept confidential. If for some reason these documents need to be filed with the Court (we ask that this be done only if absolutely necessary), they must be filed under seal. Please let me know if you have any questions or concerns. Regards, Katherine Katherine E. Rohlf
Associate Winston & Strawn LLP 35 W. Wacker Drive Chicago, IL 60601-9703
Bio | VCard | Email | www.winston.com
From: Lee Kenny ] Sent: Friday, October 25, 2013 2:29 PM To: Rohlf, Katherine E. Cc: Anderson, Kimball R.; Kirsch, Thomas L.; Sullivan, Andrew C. Subject: RE: FTC v. Trudeau - Request for Information
Dear Katherine

Please find attached office pools, WSS accounting bank statements. These are provided upon the condition of sealing them as per the protective order and are to be confidential. Please could you be kind enough to forward them to the relevant staff at the receiver I am going to see if I can get GSS next, Future Trans will be Monday morning UK time Best regards Lee From: Rohlf, Katherine E. [ ] Sent: 24 October 2013 19:03 To: Lee Kenny Cc: Anderson, Kimball R.; Kirsch, Thomas L.; Sullivan, Andrew C.; 'Brick Kane Website Solt Receiver'; kenton_johnson@ ; bzanzig@ Subject: RE: FTC v. Trudeau - Request for Information Thanks Lee. We were in court today and Mr. Trudeau is incarcerated until at least Monday. I told the Judge that you were willing to turn over documents, but wanted some assurance that these documents would be kept out of the public realm. The Court told me that these documents would not automatically be made public, and that you could produce these documents to the Receiver under the protection of the protective order entered in this case (attached). Though there is no guarantee that none of these documents will make their way into court filings in the future, the document would need to be filed under seal and would remain under seal until further order of the Court. The FTC and the Receiver (through his attorney) made representations on the record today that they were not seeking to disclose this type of information in the public realm unnecessarily and they respect the protective order. With that understanding, I renew my request that you send the requested documents to the Receiver as soon as possible (via email if possible to make it faster). I think your cooperation in producing these documents would go a long way. As always, please contact me with any questions or concerns. Regards, Katherine Katherine E. Rohlf
From: Lee Kenny [ Sent: Thursday, October 24, 2013 8:37 AM To: Rohlf, Katherine E.

Cc: Anderson, Kimball R.; Kirsch, Thomas L.; Sullivan, Andrew C.; 'Brick Kane Website Solt Receiver'; 'kenton_johnson@ ' Subject: RE: FTC v. Trudeau - Request for Information
This will take time as we have few staff left and its across 2 countries. I may be able to get a sage style (Accounting software) download and copies of bank statements, but would only consider doing so if they were going to be sealed and not open to the public. As we saw with TV coverage earlier this year, information released in court documents led to reporters visiting businesses. As I own these businesses and continue to work with them, I dont want to jeopardise relationships. This is something again Ive been offering to the receiver for over a month so they can follow the money trail as it were, and confirm that there has been no undisclosed funds sent to benefit Kevin directly or indirectly. I look forward to hearing from the receiver on this point Hope things go well in court today Best regards Lee
From: Rohlf, Katherine E. [ ] Sent: 23 October 2013 22:22 To: Lee Kenny Cc: Anderson, Kimball R.; Kirsch, Thomas L.; Sullivan, Andrew C.; 'Brick Kane Website Solt Receiver'; kenton_johnson Subject: RE: FTC v. Trudeau - Request for Information
Thanks very much for this information, Lee. Would you be able to send us all supporting documentation for the numbers youve outlined below (bank statements, financial/accounting statements, etc.)? If possible, you could email PDFs to all of the recipients on this email. Otherwise, if you could send photocopies to myself or the Receiver it would be truly appreciated. Thanks again for all your work on this. Katherine E. Rohlf
From: Lee Kenny [mailto:lee@ ] Sent: Wednesday, October 23, 2013 4:18 PM To: Rohlf, Katherine E. Cc: Anderson, Kimball R.; Kirsch, Thomas L.; Sullivan, Andrew C.; 'Brick Kane Website Solt Receiver'; kenton_johnson@ Subject: RE: FTC v. Trudeau - Request for Information

Dear Katherine Following on from my response to Kevin last week, I am happy (as I have offered to Brick and Anita at Robb Evans over the past month or two) to share some top line numbers from my businesses here in Europe. I believe the receiver has a responsibility to see if they can identify and repatriate money and/or assets of Kevins in order to contribute to the past judgement or at the very least confirm that they believe no money is being concealed. Whilst Kevin doesnt have any ownership or control in any of my companies, I would like to see him released so he can start to work (and presumably contribute to settling the judgement) again.
I hope the above helps Kevins case. Hes a good guy at heart and has positively impacted millions of people over the years. Id like to see him free to do the same again soon. Best regards Lee Kenny
From: Rohlf, Katherine E. [mailto: ] Sent: 22 October 2013 22:41 To: Lee Kenny Cc: Anderson, Kimball R.; Kirsch, Thomas L.; Sullivan, Andrew C.; kevin Subject: FTC v. Trudeau - Request for Information Dear Mr. Kenny, My name is Katherine Rohlf and I am an attorney representing Kevin Trudeau in litigation against the Federal Trade Commission. I understand that Mr. Trudeau sent you correspondence within the last week, and that you have agreed to provide Mr. Trudeau and/or the Receiver in this matter with certain information requested by Mr. Trudeau. As you may or may not know, Mr. Trudeau has been coercively incarcerated, and will therefore have very limited access to email or other methods of communication going forward. I therefore write to encourage you to send the requested information directly to me at the address below so that I can turn it over to the Receiver as soon as possible. I would also encourage you to correspond directly with the Receiver with regard to these matters (please copy me on any correspondence and send me duplicates of the information that is sent to the Receiver). The Receivers contact information is as follows: Robb Evans & Associates LLC Brick Kane Kenton Johnson 11450 Sheldon Street Sun Valley, California 91352-1121 Telephone: Facsimile:
We sincerely appreciate your assistance and cooperation on this matter. We have another hearing set in this case for Thursday morning (October 24) at 10:00 Central Time. To the extent you could provide us with the information in your possession before then, we would truly appreciate it. Please do not hesitate to contact me if you have any questions or concerns. Kind regards, Katherine Katherine E. Rohlf
The contents of this message may be privileged and confidential. Therefore, if this message has been received
Case: 1:03-cv-03904 Document #: 805-3 Filed: 12/17/13 Page 9 of 9 PageID #:14423 in error, please delete it without reading it. Your receipt of this message is not intended to waive any applicable privilege. Please do not disseminate this message without the permission of the author. ****************************************************************************** Any tax advice contained in this email was not intended to be used, and cannot be used, by you (or any other taxpayer) to avoid penalties under the Internal Revenue Code of 1986, as amended. The contents of this message may be privileged and confidential. Therefore, if this message has been received in error, please delete it without reading it. Your receipt of this message is not intended to waive any applicable privilege. Please do not disseminate this message without the permission of the author. ****************************************************************************** Any tax advice contained in this email was not intended to be used, and cannot be used, by you (or any other taxpayer) to avoid penalties under the Internal Revenue Code of 1986, as amended. The contents of this message may be privileged and confidential. Therefore, if this message has been received in error, please delete it without reading it. Your receipt of this message is not intended to waive any applicable privilege. Please do not disseminate this message without the permission of the author. ****************************************************************************** Any tax advice contained in this email was not intended to be used, and cannot be used, by you (or any other taxpayer) to avoid penalties under the Internal Revenue Code of 1986, as amended. The contents of this message may be privileged and confidential. Therefore, if this message has been received in error, please delete it without reading it. Your receipt of this message is not intended to waive any applicable privilege. Please do not disseminate this message without the permission of the author. ****************************************************************************** Any tax advice contained in this email was not intended to be used, and cannot be used, by you (or any other taxpayer) to avoid penalties under the Internal Revenue Code of 1986, as amended.
EXHIBIT D
From: Kenton Johnson [ Sent: Thursday, November 14, 2013 5:53 PM To: 'Kevin Trudeau'; 'Kirsch, Thomas L.' Cc: 'Brick Kane'; 'Anita Jen' Subject: FW:
Kevin Trudeau, We have received and read your email below. The Receiver's office is obtaining District Court approval to sell the personal property in the Ojai house and in the Oak Brook house. Most items of personal property at the Ojai house are covered by and subject to your signed bill of sale dated March 28, 2012. The bill of sale sold and transferred the personal property to Trustar Productions, Inc. , a Receivership Entity, in consideration of $143,750 of relief from indebtedness. Most of the value of the personal property was $100,000 for the three vehicles in the garage. The vehicles are not in the garage or on the property. Earlier you told Kenton Johnson the vehicles were sold. For your convenience we have attached the notarized bill of sale dated March 28, 2012, the Exhibit 1 titled Personal Property Appraisal, and the two-page Personal Property schedule. We have also included a schedule titled Transactions by Account produced from the QuickBooks accounting records maintained at the Chicago office. The schedule is a record of transactions between Trustar Productions, Inc. and Kevin Trudeau. The last entry is dated May 16, 2012 and records a credit of $143,750 for property provided to TruStar. There is no credit recorded for proceeds from selling the three vehicles that were located in the garage at the Ojai property. Our office will be holding the proceeds from the sale of the items that are not included on the Exhibit 1, Personal Property Appraisal. The estimated value of these items is 20% to 25% of the value of the missing vehicles. If our office locates properly credited sale proceeds from the missing vehicles, we will re-discuss this issue.
You and Kenton Johnson walked through the Oak Brook house and verified less than 10 items that appear to be your prior personal property. The items included two or three chairs in the upstairs office, a kitchen table, and a few other miscellaneous chairs and items. We will have those items properly identified and marked, and will set aside the proceeds from selling them. We have not yet decided how to access and take control of any personal property in the apartment in Zurich, Switzerland. Your expense claim includes two items totaling $436.41 that were charged after the appointment of the Receiver on August 7, 2013. We will consider those two items as offsets to the amounts you charged on the St. George Australian bank account after the Receiver's appointment. We have several comments about turning over of assets and full control of all assets. We are unable to continue to access the William Hill online gaming account. Previously, you told us the account was located at williamhill.com, account , with the user name of , and the password ; the security question answer . We need you to direct the William Hill entity to wire any remaining funds to the Receiver's account. We will forward complete bank wiring instructions. You are aware that Michel van Roon, an attorney for your wife Natalyia Babenko, separately sent to you and your attorney a list of, and other information about, entities for which Michel van Roon helped with the setup. Part of the information stated that NBT Trading LTD probably still has a company bank account with a balance of around US$30,000. We need you to specifically ask Natalyia Babenko to forward the remaining funds to the Receiver's account or to direct the bank to forward the funds. Part of the information that Michel van Roon forwarded to you and to your attorney was that all correspondence and invoicing for APC Trading Limited and for NBT Trading LTD were transferred to the registered agent CMS Limited in Hong Kong. We need you to ask Natalyia Babenko to have CMS Limited provide a list of the assets of these two companies or confirm that the companies have no assets. We need you to ask either Natalyia Babenko or Michel van Roon to communicate with the trustee of the Sovereign Trust located in the Cook Islands and have the trustee provide a list of the assets of the Trust or confirm the Trust has no assets. We need you to communicate with Barbara Schoop at Office Pool and ask her to once again read the letter you sent her via email on October 18, 2013. Among other things, tell her that she did not complete the following list of your requests: Did not complete actions to grant the Receiver immediate access, including, but not limited to, log-in and password information, to all funds in any accounts of Website Solutions Switzerland;
Did not provide any information you requested about transactions between Office Pool, Kevin Trudeau, Global Information Network Fdn, and Global Sales Solutions AG; Did not turn over any and all assets of Website Solutions Switzerland and Global Sales Solutions AG to the Receiver and did not provide a declaration to the Receiver that she turned over to the Receiver any and all such assets. We need you to communicate with Lee Kenny and ask him to once again read the letter you sent to him via email on October 18, 2013. Tell him the three brief schedules he prepared and forwarded do not in any way provide the information, documentation, and funds that you listed in your 10 separately set out requests. We need you to describe in writing as clearly as possible the circumstances and details of an arrangement you made on or around November 25, 2012 with Ari Wasserman. Your emails at that time stated that you directed all transactions should be with NBT Trading Limited rather than in your personal name. We want to understand the projected scope and amount of the projected transactions and the scope and amount of transactions that were actually completed. The Receiver's staff is continuing with the forensic accounting and reconstruction and review of many documents. As that process continues, we expect to have additional questions and requests for you. For the Receiver Kenton Johnson and Brick Kane -----Original Message----From: Kevin Trudeau [mailto: Sent: Sunday, November 10, 2013 4:50 PM To: Kenton Johnson; brick_kane@ Subject:
] ; Thomas L. Kirsch
I would like to set up a call or a personal meeting thursday or friday of this week to discuss the following.. -estate sales at Ojai and Oak Brook and what items my wife and I can keep -funriture in zurich -the attached expense report that I talked to you about a while ago...these are charges that were put on my credit card for the ojai property and the corporate storage units and I need to be reimbursed.
-turning over of assets...I think everything has been disclosed and I want to make sure you have control of everything. If not...I need to talk with you about what I can do to make sure you have full control of all the assets and what I need to do. many thanks Kevin Trudeau
EXHIBIT E
From: Sent: To: Cc: Subject: Blair Zanzig Wednesday, December 4, 2013 4:40 PM 'Kirsch, Thomas L.'; kenton.johnson@ ; brick kane (brick_kane@ ) Anderson, Kimball R.; Rohlf, Katherine E. RE: Request of Future Transaction Co from receiver
Tom, The Receiver is unaware of anything that Mr. Trudeau has done since the last hearing that would purge his contempt and thus the Receiver believes that continued custody is appropriate. As the judge pointed out at the last hearing, foremost, Mr. Trudeau needs to convince the Court that he has made a full disclosure and turned over all assets, including those that have not been disclosed to date. The Receiver is unaware of anything Mr. Trudeau has done since the last hearing that would give the Court grounds for finding that Mr. Trudeau has satisfied that requirement. In addition, we have in the past enumerated in detail in both letters and during the numerous hearings before the court, the information the Receiver is seeking most recently, in a November 14th email from Brick and Kent to Mr. Trudeau on which you were copied. The Receiver has never received a response to that email and believes nearly all of the items enumerated there remain open. The Receiver has also not received the accounting/banking records for WSS that the Receiver has long requested, nor has the Receiver received the accounting/banking records for Future Transactions Company or Office Pool. Further, we have recently been informed by UBS and Zurcher Kantonalbank in Switzerland, citing Swiss Banking secrecy laws, that they refuse to provide information regarding Mr. Trudeaus accounts held at those banks to third parties such as the Receiver. Thus, the Receiver urges Mr. Trudeau to directly contact those institutions and obtain all records relating to his accounts there and turnover any funds remaining in those accounts. The Receiver acknowledges that since the last hearing, at Mr. Trudeaus request, Ms. Burkhardt turned over the 5,000 CHF transferred to her from the Migros account. The Receiver is also aware that Mr. Trudeau (through counsel) requested that Lee Kenny return the funds transferred to Future Transactions Company from the Migros account in August, but that to date Mr. Kenny has failed to return those funds. Please let the Receiver know before the hearing tomorrow if there are any other steps Mr. Trudeau has taken since the last hearing that you contend purge his contempt. Thanks, Blair
From: Kirsch, Thomas L. [mailto: ] Sent: Wednesday, December 4, 2013 1:41 PM To: Blair Zanzig; kenton.johnson@ ; brick kane (brick_kane@ Cc: Anderson, Kimball R.; Rohlf, Katherine E. Subject: FW: Request of Future Transaction Co from receiver
In advance of tomorrows hearing, can you please let me know what your position will be regarding continued incarceration?
Case: 1:03-cv-03904 Document #: 805-5 Filed: 12/17/13 Page 3 of 3 PageID #:14431 If your position will be the Kevin should remain in custody, please advise me what he should do to purge the contempt. Thanks.
EXHIBIT F
From: Sent: To: Cc: Rohlf, Katherine E. < > Wednesday, December 4, 2013 6:08 PM barbara.schoop@ brick kane (brick_kane@ ); 'Kenton Johnson' (kenton.johnson@ ); Blair Zanzig; Anderson, Kimball R.; Kirsch, Thomas L.; Sullivan, Andrew C. Urgent - FTC v. Trudeau - Request for Information Barbara Schoop.pdf High
Subject: Attachments: Importance:
Dear Ms. Schoop, My name is Katherine Rohlf and I am an attorney for Kevin Trudeau. I write to follow up regarding Kevin's letter of direction that he sent you in October (attached here for your convenience). Specifically, the Receiver has asked that we follow up with you with regard to the following three action items: 1) Please immediately complete any and all necessary actions to grant the Receiver immediate access, including login-ins and password information, to all funds in any accounts held by or for Website Solutions Switzerland; 2) Please immediately provide all information requested in the attached letter regarding the transactions between Office Pool, Kevin Trudeau, Global Information Network FDN, and Global Sales Solutions AG; and 3) Please immediately turn over any and all assets of Website Solutions Switzerland and Global Sales Solutions AG to the Receiver. Please wire these assets to the following account (held by the Receiver): FIRST REPUBLIC BANK
ABA SWIFT: Credit: Credit: Assets of Kevin Trudeau, Receivership QSF, Robb Evans & Associates LLC, Receiver Account # Attention: T F(
We also renew the request in Mr. Trudeau's letter that you provide the Receiver with a sworn declaration stating that all assets have been turned over to the Receiver once complete. If for any reason you cant complete any of the action items in the letter or in the above list, please let us know as soon as possible (and let us know the reasons). Please let me know if you have any questions or concerns.

Regards, Katherine Katherine E. Rohlf Associate Winston & Strawn LLP 35 W. Wacker Drive Chicago, IL 60601-9703
http://www.winston.com
----- Forwarded message from "Barbara Schoop" <barbara.schoop@ Date: Sat, 19 Oct 2013 04:42:45 +0000 Subject: Confirmation To: "'Kevin Trudeau'" <kevin > Hi Kevin
> -----
I like to confirm of course, that I will cooperative and will provide info asked as soon as practical. If you like, I can send you the full accounting and the full pay roll accounting for WSS, since you where one of the employees of WSS. All numbers are updated and corresponded to the bank statement. Let me know if you need that. Regards Barbara Schoop _________________________________ Office Pool GmbH Lindenstrasse 20 8302 Kloten/ZH Switzerland
The contents of this message may be privileged and confidential. Therefore, if this message has been received in error, please delete it without reading it. Your receipt of this message is not intended to waive any applicable privilege. Please do not disseminate this message without the permission of the author. ****************************************************************************** Any tax advice contained in this email was not intended to be used, and cannot be used, by you (or any other taxpayer) to avoid penalties under the Internal Revenue Code of 1986, as amended.
From: Sent: To: Cc: Rohlf, Katherine E. < > Wednesday, December 4, 2013 6:18 PM lee@ brick kane (brick_kane@ ); 'Kenton Johnson' (kenton.johnson@ ); Blair Zanzig; Anderson, Kimball R.; Kirsch, Thomas L.; Sullivan, Andrew C. Urgent - FTC v. Trudeau - Additional Information Requested Lee Kenny.pdf High
Subject: Attachments: Importance:
Dear Lee, As you know, I am counsel for Kevin Trudeau. I want to sincerely thank you for the assistance youve given us so far. I write to follow up regarding the letter of direction that Kevin sent you in October (attached for your convenience). The Receiver has indicated that the information that you have previously provided (which, as you know, we forwarded to the Receiver), does not fulfill all of the requests in the attached letter. Please respond fully to each and every request in this letter to the extent possible. If you are not able to take the action(s) requested in any portion of this letter, please let us know immediately (including the reasons why). I would encourage you to have direct contact with the Receiver in order to iron out any remaining issues (the Receiver and their attorney, Mr. Zanzig, are copied on this email). Please do not hesitate to contact me with any questions or concerns. Regards, Katherine Katherine E. Rohlf
From: Sent: To: Cc: Lee Kenny < > Thursday, December 5, 2013 1:34 AM Rohlf, Katherine E. brick kane ( ); 'Kenton Johnson' (kenton.johnson@ ); Blair Zanzig; Anderson, Kimball R.; Kirsch, Thomas L.; Sullivan, Andrew C.; Barbara Schoop (barbara.schoop@ ) RE: Urgent - FTC v. Trudeau - Additional Information Requested
Subject:
Hi I believe weve already responded to every point in this request previously. Please accept this as a response to your emails to both myself and Barbara over the past 24 hours To summarise: All financial records of each company including 100% of the inward transactions and 100% of the outgoing transactions have all been provided to Brick & Anita at Robb Evans, despite the company not being owned or controlled by Kevin or any of his entities or associates. 100% of all money in GIN foundation and all statements have been wired to Robb Evans. This bank account was closed, the closing balance transferred to Robb Evans with proof sent to the receiver. WSS & GSS have provided 100% of all bank statements showing inward and outward transactions to Robb Evans. It has also provided details of liabilities that currently outweigh assets. Both these companies are not under control or ownership of Kevin or any associate or business owned by Kevin. Despite no contact or dialogue from the receivers we have continued to cooperate and answer every question posed by the receiver, a courtesy that has not be extended back to us. We continue to fully cooperate as we wish to assist Kevin in his legal troubles, however we are not simply prepared to hand over assets to Kevin. Best regards Lee
From: Rohlf, Katherine E. [mailto:KRohlf@ ] Sent: 05 December 2013 00:18 To: Lee Kenny Cc: brick kane (brick_kane@ ); 'Kenton Johnson' (kenton.johnson@ bzanzig@ Anderson, Kimball R.; Kirsch, Thomas L.; Sullivan, Andrew C. Subject: Urgent - FTC v. Trudeau - Additional Information Requested Importance: High Dear Lee,
);

As you know, I am counsel for Kevin Trudeau. I want to sincerely thank you for the assistance youve given us so far. I write to follow up regarding the letter of direction that Kevin sent you in October (attached for your convenience). The Receiver has indicated that the information that you have previously provided (which, as you know, we forwarded to the Receiver), does not fulfill all of the requests in the attached letter. Please respond fully to each and every request in this letter to the extent possible. If you are not able to take the action(s) requested in any portion of this letter, please let us know immediately (including the reasons why). I would encourage you to have direct contact with the Receiver in order to iron out any remaining issues (the Receiver and their attorney, Mr. Zanzig, are copied on this email). Please do not hesitate to contact me with any questions or concerns. Regards, Katherine Katherine E. Rohlf
EXHIBIT G
Case: Case: 1:03-cv-03904 1:03-cv-03904 Document Document #: #: 787-2 805-7 Filed: Filed: 10/28/13 12/17/13 Page Page 16 2 of 3 17 PageID PageID #:14443 #:14186 Rohlf, Katherine E.
From: Sent: To: Cc: Lee Kenny Sunday, October 27, 2013 4:39 PM Rohlf, Katherine E. Anderson, Kimball R.; Kirsch, Thomas L.; Sullivan, Andrew C.; 'Brick Kane Website Solt Receiver'; kenton_johnson bzanzig RE: FTC v. Trudeau - Requests from Receiver
Subject:
SeebelowinCAPS Lee From:Rohlf,KatherineE. Sent:26October201323:32 To:LeeKenny Cc:Anderson,KimballR.;Kirsch,ThomasL.;Sullivan,AndrewC.;bzanzig@ brickkane (brick_kane@ 'KentonJohnson'(kenton.johnson Subject:FTCv.TrudeauRequestsfromReceiver DearLee, BasedonarecentletterfromtheReceiver(yesterdayafternoon),Ibelievethisistheadditionalinformationthatwe needfromyou: (1) CompleteaccountingrecordsforGINFDN,includingwithoutlimitationbalancesheet,incomestatementsand generalledger. a. IfyoubelieveyouhavealreadyprovidedthisinformationtotheReceiver,pleaseindicatesoviaemail (theReceiveriscopiedhere).ALLBANKSTATEMENTS,SAGEACCOUNTINGBACKUPSANDMONEYWAS SENTFROMGINTORECEIVERINSEPTEMBER (2) DocumentsregardingFutureTransactions.Iunderstandthatyourteamisalreadyworkingoncompilingthis information,andyouplantosendthatinformationalongonMonday.CORRECT (3) AwrittenstatementdescribingtherelationshipbetweenGINFDN,WSS,OfficePool,FutureTransactionsand GSS,includingMr.Trudeausrelationshipwithsuchentities(ifany).Inrelationtothisrequest,wewouldlike specificinformationandadescriptionofthecircumstancesregardingthefollowing(paragraphs(a),(b)and(c) belowwerecopiedandpasteddirectlyfromtheletterfromtheReceiver):PRESUMABLYKEVINCANPROVIDE THISFROMHISPERSPECTIVE a. ThetransfersofMr.Trudeau'sGINcommissionsfromGINFDNtoOfficepooltotaling$644,727.70from January1,2013throughSeptember6,2013.THESEWEREWSS/GSSSCOMMISSIONSINRETURNFOR WRITINGSUCCESSMASTERYCOURSELEVELS112.THEYWERECALCULATEDFROMTHOSEMEMBERS WHOJOINEDGINUSINGASPECIFICAFFILIATECODE. b. ThecircumstancessurroundingtheroyaltyagreementbetweenMr.TrudeauandFutureTransactions CompanyreferencedintheDecember10,2012emailfromMr.TrudeautoNealSantandJeffDevine,a copyofwhichwasattachedasPXA:9totheFTC'sStatementConcerningDefendant'sLettersofDirection
(Dkt.#774).[Lee,Ihaveattachedthisdocumenttothisemailforyourreference/context]I UNDERSTANDKEVINWASUNHAPPYWITHHOWHISSPEAKINGFEESAND/ORROYALTIESHADBEEN HANDLEDINTHEPAST.FUTURETRANSAGREEDTOTAKETHISOVERINRETURNFORPROVIDINGKEVIN AGREEINGTOBEEMPLOYMEDBYONEOFMYCOMPANIESINZURICH c. ThepurportedpaymentoflegalfeesonbehalfofMr.Trudeautotaling251,569BritishPounds(or $402,919.88basedontoday'sexchangerate),whichisapproximatelyathirdofthatcompany'srevenue asreportedbyLeeKennyinhisOctober23,2013emailtoKatherineRohlf,especiallygiventhatMr. TrudeauhasassertedthatFutureTransactionsCompanyisalegitimatebusinessindependentlyowned byLeeKenny.Mr.Trudeaushouldexplainwhattransfershe,theTrudeauEntities,orother persons/entitiesactingonhisbehalfhavemadetoFutureTransactionsCompany.THISISDIRECTEDTO KEVIN,BUTWHENICOMBINETHECOSTSOFEMPLOYINGKEVINVERSUSTHEINCOMEHEWASABLETO ASSISTINGENERATINGACROSSALLMYBUSINESSES,IWASHAPPYTODONATETOWARDSHISLEGAL FEESTOASSISTHIMGETARESOLUTIONSOHECOULDFOCUSMOREONDOINGMORESEMINARSAND BOOKSETC.SOMEPEOPLEDONATETOPOLITICALPARTIES,FORMEIWANTEDTOHELPKEVINWITHHIS CURRENTCHALLENGES.
Asalways,weappreciateyourassistancewithallofthis.Letmeknowifyouhaveanyquestions.Weencourage youtocorresponddirectlywiththeReceiveraboutthesematters(copyingusonallcorrespondence). Regards, Katherine Katherine E. Rohlf

EXHIBIT H
Case: Case: 1:03-cv-03904 1:03-cv-03904 Document Document #: #: 787-2 805-8 Filed: Filed: 10/28/13 12/17/13 Page Page 10 2 of 4 17 PageID PageID #:14446 #:14180 Rohlf, Katherine E.
From: Sent: To: Cc: Subject: Rohlf, Katherine E. Saturday, October 26, 2013 5:37 PM brick kane ( ); 'Kenton Johnson' ( ); bzanzig Anderson, Kimball R.; Kirsch, Thomas L.; Sullivan, Andrew C.; FW: FTC v. Trudeau - Request for Information
DearBrick, PleasefindbelowinformationwereceivedfromMichelVanRoonregardingtheoffshoreentities.Aswehavenoted before,wehighlyencourageyoutocontactMr.VanRoondirectly,asheisthekeeperoftheinformationyouare seekingwithregardtotheseentities.Mr.VanRoonhasindicatedanddemonstratedhiswillingnesstocooperate. Regards, Katherine Katherine E. Rohlf

From: Michel van Roon ] Sent: Thursday, October 24, 2013 4:47 PM To: Rohlf, Katherine E. Cc: Anderson, Kimball R.; Kirsch, Thomas L.; Sullivan, Andrew C.; Subject: RE: FTC v. Trudeau - Request for Information
HiKatherine, BelowpleasefindthelistoftheentitieswherewehaveassistedMs.NataliiaBabenkoonwiththesetup.Thisisthe sameoverviewaswehavesenttoMr.Trudeauearlierthisweek. APCTRADINGLIMITED:Belizecompany,dateofincorporation02/07/2008 Director:NataliiaBabenko Shareholder:NataliiaBabenko Secretary:BerkleySecretariesInc. Remark:allcorrespondenceandinvoicingrelatedtothecompanywastransferredtothecompanys registeredagentinHK(CMSLimited)in2010atrequestofNataliia. accordingtoourbestofknowledgenobankaccountwaseversetupforthiscompany
NBTTRADINGLTD:HongKongcompany,dateofincorporation08/07/2008 Director:APCTradingLtd Shareholder:APCTradingLimited Secretary:BercleySecretariesLtd Remark:allcorrespondenceandinvoicingrelatedtothecompanywastransferredtothecompanys registeredagentinHK(CMSLimited)in2010atrequestofNataliia. accordingtoourfilesthecompanyopenedabankaccountwithValartisBankinLiechtensteinin March2009.Accountsignature:NataliiaBabenko NTTRADINGSA:Panamacompany,dateofincorporation02/07/2008 Directors:VernonEmmanuelSalazarZurita,LiliaJudithTovarDeLeon,DelioJoseDeLeonMela Secretary:LiliaJudithTovarDeLeon Status:Dormant/Abandoned Remark:companywasabandonedatrequestofNataliiaBabenkoinJuly2010 companytoourbestofknowledgeneveropenedabankaccount Mr.KevinTrudeauheldaPOAtoactonbehalfofthecompanybutwehavenoindicationthisPOA haseverbeenused(nordowehaveanywayofverifyingthis) SOVEREIGNTRUST:CookIslandTrust,dateofestablishment26/05/2009 Settlor:NataliiaBabenko Beneficiary:APCTradingSA(butthismayhavebeenchanged,wouldneedtoverifywithtrustee) Trustee:AsiacityCookIslands Protector:Codrington Remark:toourbestofknowledgethetrusteeneversetupabankaccountforthetrust,butwedneedto verifywiththetrusteeifyouwant foranyassetsheldbythetrustwewouldneedtoliaisewiththetrustee HereexceptforNBTTradingLimited(aHKcompany)wearenotawareofanyofthesestructureshavinganyassets.As wearenotthedirectorand/orshareholderorthesecompanieswehoweverarenotinapositiontomakeanyformal declarationtothiseffect.Asthecompaniesareeffectivelymanagedbythedirectors,accountscouldhavebeenopened withoutanybodyeverhavinginvolvedus.ThisespeciallyastheadministrationofNBTandAPCweretransferredtothe registeredagentinHKinmid2010whichmeansthatwehavenorecentvisibilityontheseentitiesAsaresultwe/you wouldprobablyneedtoliaisewiththedirectorsorthevariousentities(orthetrusteeincaseofthetrust)toobtainsuch declaration. ForthePanamacompanyNTTradingSA,acompanyforwhichalsoapowerofattorneywasissuedtoMr.Trudeau,I believeitwouldbeunlikelythatthecompanyhasanyassets.Thisasthiscompanywasabandonedatrequestofthe clientinJuly2010andtogetherwiththisthecompanysbearersharecertificateshavebeenreturnedtothecompanys registeredagent.Thismakesthatthecompanyisnotingoodstanding. Fromourendwewouldbemorethanhappytoassistyou,Mr.Trudeauand/ortheReceiverwithcollectionofthese documentsandtoassistinobtainingtherespectivedeclarationsbutnotsurehowthiswouldworkfee/costwise. Alreadyoverthelastdays/weekwehavespentconsiderabletimeinpullingtogetherdifferentdocumentsand correspondingwithvariouscounterpartiesandnormallywewouldexpectforsuchtimetobecompensated.Hereour
standardprocedureistoworkbasedonaretainerwherewekeeptrackofthetimespentwhichisthenoffsetagainst sucharetaineragainstapreagreedhourlyrate.Butnotsurehowthisworksincaseslikethis. Lastbutnotleast,aswasraisedinearliercorrespondencewithMr.TrudeauandIbelievealsotheReceiver: forNBTTrading(theHKcompany)wehavefoundindicationthatthecompanywouldstillhavea companybankaccountwithabalanceofaroundUSD30000,=. wehaveinformationwhichwouldsuggestthatMs.Babenkohadapersonalaccountwithabankin theCarribean.Wearenotsurethisispartofthescopeofyourenquirybutwantedtomakesure youwereaware.Heretodatehoweverwehavenoindicationastowhatthestatusofsuchaccount is. Herepleaseletusknowhowyouwouldlikeustoproceed. KindRegards, Michel
EXHIBIT I
From: Lee Kenny [mailto: ] Sent: Wednesday, November 27, 2013 1:07 PM To: brick kane Cc: Anita Jen; krohlf@ ; Kimball R. Anderson; tkirsch@ Subject: Re: Kevin Trudeau funds transfer
Hi Brick Thanks I think you mean the Future transactions Company account rather than my account? If so Katherine mentioned it this week. There seems to be some confusion so will be sitting with Paul tomorrow to discuss and respond accordingly. In the meantime perhaps your team would be kind enough to respond regarding the hold that has been put in naturalcures.com domain at go daddy. So far Anita has refused to clarify the situation. However we are expecting notification from Robb Evans that this is to be lifted so we can carry on business as normal. Your response would be appreciated Best regards Lee On 27 Nov 2013, at 20:08, "brick kane" <brick_kane@robbevans.com> wrote: Lee, I hope you are well. On August 23, 2013 Kevin transferred $62,671.00 to your account from his account at Migros Bank in Switzerland. Please see attached detail. This transfer was in violation of the District Courts order. Please immediately return these funds to the receiver. Our wire instructions are: FIRST REPUBLIC BANK

Los Angeles, CA 90017 ABA SWIFT: Credit: Credit: Assets of Kevin Trudeau, Receivership QSF, Robb Evans & Associates LLC, Receiver Account # Attention: T (213) F (213)
Regards, Brick Brick Kane President & Chief Operating Officer Robb Evans & Associates LLC
<796. Receiver's Third Supplemental Report.pdf>
No virus found in this message. Checked by AVG - www.avg.com Version: 2012.0.2247 / Virus Database: 3629/6372 - Release Date: 11/27/13
EXHIBIT J
From: Lee Kenny < > Date: December 2, 2013 at 11:10:32 PM PST To: "Rohlf, Katherine E." < > Cc: 'Brick Kane Website Solt Receiver' < >, "KAnderson@ "< Subject: Request of Future Transaction Co from receiver Dear Katherine
>, "Kirsch, Thomas L." >
Apologies for the delay, my finance chap was on vacation and it took a while to catch up once he returned. I have now investigated the circumstances surrounding the transfer. Firstly, the inbound transfer was logged on our system as coming from William Hill, a European bookmaker/casino. As the receiver will see from the bank statements we sent over several weeks ago it shows as being sent from Herr, so there was no way to have seen it was from Kevins account. Money was deposited directly from Future Transactions in to an account with William hill for the purpose of further testing one of our gambling information products. The amount deposited was 35,000 (approx. 52,000 chf) and was sent from the UK to William Hill on 2nd April 2013. As part of Kevins duties whilst employed by the swiss company, he was to test new patterns of play to ensure efficacy before we released them to our customers. We asked Kevin to return those funds via William Hill in Mid to late June. We understood the delay to be caused by his visits to the US where he was unable to access the site. The company in question are also notoriously slow at processing withdrawal requests. Our understanding is that the William hill account actually has close to 80,000 swiss francs in it according to media reports, all of which belong to Future Transactions Company. Therefore I propose that the receiver reclaims the required funds from that account. Failing that if the receiver confirms that they have no hold on the William hill account and we are free to withdraw from that account without any negative consequences then well be happy to do that and reimburse them at that point. Brick has been ccd to this email. Please also note that Robb Evans currently owes Snowflake an amount of $28,793.43 which represents withholdings held by Meritus bank from our natural cures merchant

facility which was managed through Website Solutions entities whilst we transitioned post-acquisition. If it wishes to offset that as part payment then claim the remainder from one of the two above methods, they should let us know so we can make arrangements. Please let me know the route they wish to proceed and well be happy to assist. Best regards Lee
EXHIBIT K
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Trudeau Civil Case Document 805 0 Receivers Status Report For December 19 Hearing PLUS Exhibits 12-17-13

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Trudeau Civil Case Document 805 0 Receivers Status Report For December 19 Hearing PLUS Exhibits 12-17-13

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Case: 1:03-cv-03904 Document #: 805 Filed: 12/17/13 Page 1 of 10 PageID #:14391

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Case: 1:03-cv-03904 Document #: 805 Filed: 12/17/13 Page 2 of 10 PageID #:14392

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Case: 1:03-cv-03904 Document #: 805 Filed: 12/17/13 Page 3 of 10 PageID #:14393

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Case: 1:03-cv-03904 Document #: 805 Filed: 12/17/13 Page 4 of 10 PageID #:14394

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Case: 1:03-cv-03904 Document #: 805 Filed: 12/17/13 Page 5 of 10 PageID #:14395

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Case: 1:03-cv-03904 Document #: 805 Filed: 12/17/13 Page 6 of 10 PageID #:14396

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Case: 1:03-cv-03904 Document #: 805 Filed: 12/17/13 Page 7 of 10 PageID #:14397

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Case: 1:03-cv-03904 Document #: 805 Filed: 12/17/13 Page 8 of 10 PageID #:14398

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Case: 1:03-cv-03904 Document #: 805 Filed: 12/17/13 Page 9 of 10 PageID #:14399

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Case: 1:03-cv-03904 Document #: 805 Filed: 12/17/13 Page 10 of 10 PageID #:14400

/s/ Blair R. Zanzig

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Case: 1:03-cv-03904 Document #: 805-1 Filed: 12/17/13 Page 1 of 4 PageID #:14401

GIN Network Truth (the smart group)

GIN Network Truth1 (the smart group)

Kevin, Please see attached. Brick

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Case: 1:03-cv-03904 Document #: 805-1 Filed: 12/17/13 Page 4 of 4 PageID #:14404

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Case: 1:03-cv-03904 Document #: 805-2 Filed: 12/17/13 Page 1 of 10 PageID #:14405

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HILTZ WANTUCH & ZANZIG Sender's Direct: Sender's Email:

Winston & Strawn

35 West Wacker Drive Chicago, lL 60601-9703

Trudeau, No. 03-C-3904 (N.D. lll.)

As required by Court's August 7,2Ot3 Order (the "Receivership

Orde/'), Mr. Trudeau should

GIN Network Truth (the smart group)

disposition of such funds.

current disposition of such funds.

GIN Network Truth (the smart group)

Statement IDkt. #759].

GIN Network Truth (the smart group)

from their sale.

to contact me if you have any questions regarding the foregoing'

BrickKane( Ke nton Johnso n

GIN Network Truth (the smart group)

HILTZ WANTUCH & ZANZIG Sender's Direct: Sender's Email:

Winston & Strawn

35 West Wacker Drive Chicago, lL 60501-9703

Trudeou, No. 03-C-3904 (N.D. il1.)

See, e.g., FTC v.

GIN Network Truth (the smart group)

GIN Network Truth (the smart group)

GIN Network Truth (the smart group)

GIN Network Truth (the smart group)

to contact me if you have any { uestions regarding the foregoing.

Very truly yours,

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Case: 1:03-cv-03904 Document #: 805-3 Filed: 12/17/13 Page 1 of 9 PageID #:14415

GIN Network Truth (the smart group)

Bio | VCard | Email | www.winston.com

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Case: 1:03-cv-03904 Document #: 805-3 Filed: 12/17/13 Page 3 of 9 PageID #:14417