Trudeau Civil Case Document 857 Thru 859 Receivers Motion For Entry of An Order Approving Sale of GIN Etc 04-28-14

GIN Network Truth (the smart group)
UNITED STATES DISTRICT COURT FOR

THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION

FEDERAL TRADE COMMISSION,

Plaintiff,

v.

KEVIN TRUDEAU,

Defendant.

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Cae N!." #$%C%$&#'

H!n. R!(e)t *. +ettle,an

RECEIVER-S MOTION FOR ENTR. OF AN ORDER APPROVIN+ SALE OF +IN
CLU/ ASSETS FREE AND CLEAR OF ALL LIENS, CLAIMS AND ENCUM/RANCES

Robb Evans & Associates LLC, in its capacity as the court-appointed receiver for the
assets of Kevin Trudeau and the Trudeau Entities et al. (the Receiver!", by and throu#h its
undersi#ned counsel, hereby $oves for entry of an order (the %otion!" approvin# the sale of
certain receivership assets related to the operation of the &lobal 'nfor$ation (et)or* (the &'(
Club!" free and clear of all liens and encu$brances. 'n support of its %otion, the Receiver states
as follo)s+
I. INTRODUCTION
,. 'n this $otion, the Receiver see*s approval to sell substantially all of the assets of
the &'( Club to an invest$ent #roup consistin# of current &'( Club $e$bers for -.//,/// in
cash, plus a percenta#e of future $e$ber dues paid in $onthly install$ents over the ne0t ,.
$onths. The assets to be sold lar#ely consist of intan#ible property, includin# intellectual
property o)ned by the &'( Club as )ell as its $e$bership databases, but also include the used
office furniture and e1uip$ent located at the &'( Club2s offices in 3est$ont, 'llinois. The sale
is in the best interests of the receivership estate in that it affords the receivership estate an
Case: 1:03-cv-03904 Document #: 857 Filed: 04/28/14 Page 1 of 20 PageID #:15658
.

upfront cash pay$ent, )hile also providin# a share of future inco$e derived fro$ the &'(
Club2s assets. 4y contrast, none of the other offers received by the Receiver provided for a
si$ilar initial cash pay$ent and instead relied e0clusively on a share of uncertain future inco$e.
The Receiver see*s approval to sell such assets free and clear of any liens or other
encu$brances, )ith such liens, if any, attachin# to the proceeds of the sale in the sa$e a$ount
and priority as currently e0ists. The Receiver is una)are of any such liens. Ta*in# into account
the declinin# $e$bership of the &'( Club and its li$ited operational history follo)in# the
discontinuation of its i$proper affiliate pro#ra$ and $isleadin# $ar*etin#, the proposed sale
$ore that ade1uately reflects the fair $ar*et value of the &'( Club assets, and, in the Receiver2s
sound business 5ud#$ent, constitutes the hi#hest and best offer for those assets. Accordin#ly,
the Receiver ur#es the Court to approve the proposed sale.
II. /ACK+ROUND
A. THE RECEIVERSHIP ESTATE.
.. 6n 7uly ,8, ./,., the 9TC $oved to hold :efendant Kevin Trudeau (Trudeau!"
in conte$pt for failin# to co$ply )ith the Court2s 7une ., ./,/ order directin# Trudeau to pay to
the 9ederal Trade Co$$ission (9TC!" -8;.< $illion correspondin# to the consu$er loss
resultin# fro$ Trudeau2s contu$acious info$ercial $ar*etin# of the Weight Loss Cures boo*.
(9TC Conte$pt %otion =:*t. >?@,A."
8. 9ollo)in# nearly a year of discovery and a subse1uent evidentiary hearin#, the
Court #ranted the 9TC2s $otion holdin# Trudeau in conte$pt. (6rder =:*t. >;.BA." As part of
its findin#s, the Court held that Trudeau had created and controlled a nu$ber of do$estic and
offshore entities throu#h )hich he operated the &'( Club, includin# &'( CDA 'nc. (&'(!",
&lobal 'nfor$ation (et)or* 9:( (&lobal!", and 3ebsite Dolutions CDA 'nc. (3ebsite
8

Dolutions!" (collectively )ith Trudeau, the &'( Dellers!". (9TC 9indin#s EE ''.A.. & 4 =:*t.
>;,8A."
,
The Court also found that Trudeau controlled Trudeau Approved Froducts, 'nc.
(TAF!". (Id. E ''.A.?." The &'( Dellers to#ether )ith TAF shall be referred to as the Dellers.!
?. 'n order to $a0i$iGe recovery to consu$ers and pursuant to its order dated
Au#ust ;, ./,8 (the Receivership 6rder!", the Court appointed Robb Evans & Associates LLC
as the receiver over Trudeau2s Assets! and the Trudeau Entities! (as those ter$s are defined in
the Receivership 6rder". (Receivership 6rder H 'I =:*t. >;?.A." Each of the Dellers is a
Trudeau Entity! under the Receivership 6rder and thus part of the receivership estate. (Id. H
'.(B"."
/. THE +IN CLU/ OPERATIONS.
J. The Court authoriGed the Receiver to operate the &'( Club, but only to the e0tent
it could be operated le#ally and )ithout loss to the receivership estate. (Id. E I(,."." The Court
also authoriGed the Receiver to sell, li1uidate, or auction any $ar*etable Assets of Trudeau or
the Trudeau Entities, or the Trudeau Entities the$selves.! (Id. H I(,8"." Accordin#ly, as
previously reported to the Court and the &'( Club2s $e$bers, the Receiver has been )or*in# to
stabiliGe the &'( Club so that it could be operated as a le#al and financially stable co$pany and
ulti$ately transferred to ne) o)ners for a fair price. (See, e.g., Kane :ecl. E ? & E0. A
(Receiver2s ,.K,8K./,? Announce$ent"L Receiver2s Decond Report =:*t. >@,JA at ?."
.
The
Receiver echoed those intentions a nu$ber of ti$es, includin# in a 7anuary <, ./,? $essa#e to
&'( Club $e$bers e0plainin#+ =iAt is the intention of the Receiver to #et per$ission fro$ the

,
The Court adopted 9indin#s '' throu#h I' and Conclusions ' throu#h 'I of the 9TC2s
proposed findin#s of fact and conclusions of la). (;K.<K./,8 6rder at E (." =:*t. >;.BA."
.
Kane :eclaration! or Kane :ecl.! refers to the :eclaration of 4ric* Kane in Dupport of the
Receiver2s %otion to Dell the &'( Club Assets 9ree and Clear of All Liens, Clai$s and
Encu$brances filed concurrently )ith this %otion. Kane E0. MM! refers to the correspondin#
e0hibit attached to the Kane :eclaration.
?

Court to transfer &'( operations for a fair price to a ne) o)ner or o)nership #roup )hich $ay
include &'( $e$bers.! (Kane :ecl. E ? & E0. 4 (Receiver2s ,K<K./,? Announce$ent"."
<. At the outset of the Receivership, the &'( Club had substantial pre-receivership
clai$s a#ainst it totalin# at least - B.J $illion.
8
(Kane :ecl. E J." Cnder the Receivership 6rder,
the Receiver )as precluded fro$ payin# any such pre-receivership debts )ithout additional court
approval and such a$ounts re$ain unpaid. (Receivership 6rder H I.(;"." Duch pre-receivership
debts $ay include, a$on# other thin#s, clai$s by &'( Club $e$bers and affiliates to certain
bonus and incentive pay$ents under various $e$ber recruit$ent pro#ra$s, includin# &o &etter,
Du$$er Dales 4onanGa, Du$$er Dales 4onanGa Dponsor, &et 8 Fro#ra$, (e)sletter, 3ee*ly
Audio Re)ards, Cruise voucher recipients, Iisionary and 9ounder bonuses, LaGy %an order
refunds and 'nner Circle bonuses. (See Kane :ecl. EJ & E0. 4 (Receiver2s ,K<K./,?
Announce$ent."
;. The Receiver too* a nu$ber of steps to stabiliGe the &'( Club2s finances.
3or*in# )ith the &'( Club2s $ana#e$ent, the Receiver reduced overhead e0penses by, a$on#
other thin#s, reducin# staffin# levels to appropriate levels. (Receiver2s Decond Report =:*t. >
@,J-,A at .." The Receiver canceled a $e$ber cruise scheduled for 7anuary ./,? )here there
)ere insufficient funds to pay other)ise re1uired deposits. (Receiver2s 9irst Report =:*t. >;?;-
,A at ,@-,B." The Receiver approved e0penditures to fund a 9a$ily Reunion! conference in
3ashin#ton :.C. in 6ctober ./,8 that resulted in a net surplus to the &'( Club. (Receiver2s
Decond Dupple$ental Report =:*t. >;@J-,A at ,." The Receiver continued the &'( Club2s pre-
receivership relationship )ith the Nybrid &roup to provide various educational and social events
for the &'( $e$bership. 'n (ove$ber ./,8, the Receiver hired the for$er &'( Events and

8
(othin# in this %otion is intended to ad$it the validity of any particular pre-receivership
clai$.
J

Education %ana#er as Chief 6peratin# 6fficer to assist the Receiver and $e$bers of the
$ana#e$ent tea$ in creatin# a path to offer $e$bership events that are cost-beneficial for
$e$bers and to up#rade so$e of the trainin# curriculu$. (Receiver2s Decond Report =:*t.
>@,J-,A at ,."
@. 9urther, the Receiver addressed concerns, echoed by the 9TC and the Court,
re#ardin# the le#ality of certain aspects of the &'( Club. The Receiver independently evaluated
the &'( Club2s Affiliate Fro#ra$,! includin# the e0pert report of econo$ist Feter Iander (at
prepared for the 9TC. (Kane :ecl. E <L see also 9TC Resp. to %ot. To 'ntervene =:*t. >@/@A at
E0. C (Iander (at Report"." The Receiver concluded that the then-e0istin# Affiliate Fro#ra$,
)hich paid co$$issions to affiliates for recruitin# additional $e$bers, li*ely a$ounted to an
ille#al pyra$id sche$e. (Kane :ecl. E <." Accordin#ly, on (ove$ber 8/, ./,8, the Receiver
ter$inated the Affiliate Fro#ra$ and ceased payin# co$$issions. (Id." The Receiver paid the
last co$$ission pay$ents in :ece$ber ./,8 for co$$issions earned in (ove$ber ./,8. (Id."
The Receiver also too* steps to re$ove 1uestionable state$ents and inco$e clai$s fro$ the &'(
Club2s )ebsite, includin# postin# a disclai$er on the )ebsite statin# that contrary to references
$ade in &'(2s $ar*etin# $aterials to a &'( Council! consistin# of a #roup of purported
billionaires that endorsed the &'( Club trainin# $aterials, the Receiver had uncovered no
evidence that such a council in fact e0isted. (Receiver2s Decond Report =:*t. >@,J-,A at ,."
B. Althou#h the Receiver has been able to operate the &'( Club profitably since
assu$in# control, the &'( Club has e0perienced a substantial decline in $e$bership fro$ its
pea* in ./,, )hen the &'( Club had a total of 8;,.<@ co$bined $e$bers and affiliates.
(Receiver2s 9irst Report =:*t. ;?;-,A at ,?." That do)n)ard trend has continued since the
appoint$ent of the Receiver, the ter$ination of the Affiliate Fro#ra$, and in the face of active
<

ca$pai#ns by various #roups of for$er $e$bers to encoura#e other $e$bers to discontinue
pay$ent of their dues. (Kane :ecl. E ;." 'n Au#ust ./,8, the &'( Club had ;,,J8 dues payin#
$e$bers and by :ece$ber 8,, ./,8, after the Receiver paid the final Affiliate Fro#ra$
co$$issions, the &'( Club had ?,;8< dues payin# $e$bers. (Receiver2s Decond Report =:*t. >
@,J-,A at .."
C. THE RECEIVER-S MARKETIN+ OF THE +IN CLU/-S ASSETS.
,/. &iven the uni1ue nature of the &'( Club, the Receiver deter$ined that the $ost
li*ely buyers, as )ell as those )ho placed the hi#hest value on the &'( Club2s assets, )ere
a$on# e0istin# &'( Club $e$bers. (Kane :ecl. E @." Accordin#ly, on %arch ,;, ./,?, the
Receiver announced that it )as solicitin# )ritten letters of intent to purchase the assets of the
&'( Club. (Id. E @ & E0. C."
,,. 'n response to its re1uests for proposals, the Receiver received nearly ./
in1uiries e0pressin# interest in ac1uirin# the &'( Club2s assets. (Kane :ecl. E B." The Receiver
declined to pursue a nu$ber of offers that included substantial and unli*ely contin#encies, such
as proposals that all $e$bers contribute -,,/// to purchase the &'( Club2s assets. (Id. E B."
The Receiver also re5ected offers that sou#ht to purchase only certain assets of the &'( Club,
such as its $e$bership list, for a$ounts far less than their value. (Id. E B." 6ther $ore
substantial offers sub$itted to the Receiver proposed consideration consistin# e0clusively of
future install$ent pay$ents deter$ined as a percenta#e of net profits, )ith no initial cash
pay$ent. (Id. E ,/."
,.. 9inally, AOD Consultin#, LLC (the Furchaser!", consistin# of an invest$ent
#roup of current &'( %e$bers )ho have a lon#-ti$e association )ith the &'( Club, proposed
to purchase substantially all of the &'( Club2s assets for consideration of -.//,/// cash at
;

closin#, plus install$ent pay$ents for t)elve $onths of @P of e0istin# $e$ber dues and ?P of
ne) $e$ber dues. (Id. E ,,." (o other offer proposed a si$ilarly substantial up-front pay$ent
at closin#. (Id." E0ercisin# its business 5ud#$ent, the Receiver dee$ed the offer fro$ the
Furchaser to be the hi#hest offer and in the best interests of the receivership estate. (Id. E ,8."
D. THE ASSET PURCHASE A+REEMENT.
,8. After ar$s-len#th ne#otiations, the Dellers and Furchaser entered into that certain
Asset Furchase A#ree$ent dated April ,<, ./,? (the AFA!", sub5ect to court approval. (Kane
:ecl. E ,?." A true and correct copy of the AFA is attached as E0hibit : to the Kane
:eclaration. &iven the Receiver2s )idely distributed re1uests for offers and as a necessary
induce$ent to the Furchaser, such sale shall not be sub5ect to overbiddin#. (Id."
,?. The principal ter$s of the AFA are as follo)s+
Consideration. The Furchaser shall pay the su$ of -.//,/// plus t)elve $onthly
pay$ents calculated as the $onthly a##re#ate of (a" @P of #ross collected
$e$bership dues for the calendar $onth endin# on the day precedin# the due
date of each Furchase Frice 'nstall$ent for all &'( Club $e$bers )ho )ere
$e$bers as of the Closin# :ateL and (b" ?P of #ross collected $e$bership dues
for the calendar $onth endin# on the day precedin# the due date of each Furchase
Frice 'nstall$ent for all &'( Club $e$bers )ho beco$e $e$bers of &'( Club
after the Closin# :ate.

Assets to be Ac1uired by Furchaser. The Furchaser shall purchase fro$ the
Dellers, the Dellers2 ri#ht, title and interest in+

(a" all trainin# $aterials o)ned by any of the &'( Dellers, )hether in hard
copy or electronic for$at, includin# but not li$ited to all audio and video
recordin#s, printed $aterials, )ebinars, )ebsite and )ebsite content,
$ar*etin# $aterials, audio and video $asters, and any physical copies of
such audio, visual or printed $aterials located at the five Trainin#
%aterial Locations! (as defined in the AFA" (collectively, the Trainin#
%aterials!", e0cludin# any Trainin# %aterials deter$ined by the Court,
9TC or Receiver to constitute a violation of the 9ederal Trade
Co$$ission Act or other applicable la)L

(b" all &'( custo$er databases )hich evidence or ite$iGe past or current
&'( $e$bers, associates or affiliates re#ardless of their past or present
@

$e$bership status in the &'( Club, and all ri#hts to pay$ent of initial
$e$bership fees, $onthly dues and all other revenue derived fro$ &'(
Club $e$bers, associates or affiliates based upon such $e$bership,
association or affiliation (the %e$bership :atabases!"L

(c" all intellectual property o)ned or licensed by any of the &'( Dellers
and used in connection )ith the &'( Club, if any e0ists, consistin# of
trade$ar*s, copyri#hts, trade na$es and lo#os (the 'ntellectual
Froperty!"L

(d" all infor$ation technolo#y o)ned by any of the &'( Dellers )hich )as
created or ac1uired in connection )ith the past or present operations of
any of the &'( Dellers and used in connection )ith the &'( Club,
includin# but not li$ited to custo$iGed code, pass)ords, soft)are
pro#ra$s, database infor$ation, custo$er files and business reports
(collectively, the 'nfor$ation Technolo#y!", e0cludin# any 'nfor$ation
Technolo#y deter$ined by the Court, 9TC or Receiver to constitute a
violation of the 9ederal Trade Co$$ission Act or other applicable la)L

(e" all furniture, office e1uip$ent, supplies, co$puters, telephone syste$s
and audiovisual e1uip$ent o)ned by any of the &'( Dellers presently
located at the 3est$ont 6ffices (the 9urniture and E1uip$ent!"L and

(f" all finished products o)ned by TAF located at the :uarte Froperty!
(as defined in the AFA" consistin# of appro0i$ately 8,8// 8/-day supplies
of nutritional supple$ents (the TAF Assets!".

The Trainin# %aterials, %e$bership :atabases, 'ntellectual Froperty,
'nfor$ation Technolo#y, 9urniture and E1uip$ent, and TAF Assets shall
be collectively referred to as the Furchased Assets.!

AD 'D! Dale. The Furchased Assets are sold AD 'D! )ithout representations or
)arranties by the Dellers, e0press or i$plied, )ith respect to any $atter relatin# to
the Furchased Assets.

9ree and Clear Dale. The Furchased Assets shall be transferred to the Furchaser
free and clear of all Encu$brances and Liabilities e0cept for any Encu$brances
that $ay e0ist as a result of the stora#e or )arehousin# of the TAF Assets.

Assu$ption of Liabilities. The Furchaser shall assu$e all liabilities arisin# fro$
and after the closin# date out of or relatin# to the Furchaser2s o)nership or
operation of the Furchased Assets, includin# clai$s that use of the Furchased
Assets by the Furchaser infrin#es on the ri#hts of any third partyL and liabilities
for ta0es in connection )ith the ac1uisition of the Furchased Assets or attributable
to the o)nership or operation of the Furchased Assets after the closin# date.

B

,J. 'n li#ht of the substantial disputed and undisputed pre-receivership obli#ations
potentially o)ed by the Dellers, e0ceedin# any reasonable esti$ate of the value of the Furchased
Assets, the Furchaser e0pressly re1uired that the order approvin# the sale provide that the
Furchased Assets shall be transferred to the Furchaser free and clear of any and all
Encu$brances! or Liabilities! (as those ter$s are defined in the AFA", includin# but not
li$ited, to any clai$s (*no)n or un*no)n", includin# those that $ay be asserted by current or
past $e$bers, associates or affiliates )ith respect to the &'( Club. (Kane :ecl. E0. : (AFA" at
H<.,(b"."
E. N!ti0e P)!0ed1)e.
,<. 6n April ,;, ./,?, the Receiver issued a 5oint state$ent )ith the Furchaser to the
&'( Club $e$bers announcin# the AFA. (Kane :ecl. E ,< & E0. E." 6n April .,, ./,?, the
Receiver filed its %otion for Entry of an 6rder (A" Dettin# Nearin# for Approval of the Dale of
&'( Club Assets and (4" Approvin# the 9or$ and %anner of (otice =:*t. >@J8A (the (otice
Frocedures %otion!". As approved by the Court, in addition to the parties to this case, the
Receiver provided notice of the sale to the follo)in#+ (i" all *no)n disputed and undisputed
creditors of the DellersL (ii" all persons )ho are $e$bers or affiliates of the &'( ClubL and (iii"
all persons )ho sub$itted e0pressions of interest in response to the Receiver2s %arch ,;, ./,?
re1uest for letters of intent. (Kane :ecl. E ,;." Dpecifically, the Receiver electronically sent the
(otice of Dale! to the last *no)n e$ail addresses of .?,,8/ individuals associated )ith the &'(
Club $e$bership list. Additionally, the Receiver sent @88 copies of the (otice of Dale via first
class C.D. %ail to the last *no)n address of disputed and undisputed creditors of the Dellers.
?

?
4ecause so$e individuals fell into $ore than one cate#ory of persons to )ho$ the Receiver
provided notice, those individuals $ay have received both electronic and hard copies of the
,/

The 6b5ections to the proposed sale are to be filed no later than J+// p.$. (C:T" on %ay ,.,
./,? (the 6b5ection :eadline!". A final hearin# to approve the AFA is presently set for %ay
.;, ./,?, at ,+8/ p.$. (C:T". As such, parties in interest )ill be afforded no less than ,; days
notice prior to the 6b5ection :eadline and 8, days notice prior to the final hearin#.
,;. The Receiver no) re1uests the Court approve and confir$ the sale of the
Furchased Assets to the Furchaser on the ter$s set forth in the AFA, free and clear of all liens,
clai$s, and encu$brances as in the best interests of the receivership estate and authoriGe the
Receiver to ta*e all necessary steps to the conclude such sale.
III. /ASIS FOR RELIEF
A. THE COURT SHOULD APPROVE THE SALE OF THE PURCHASED ASSETS AS IN THE /EST
INTERESTS OF THE RECEIVERSHIP ESTATE.

,@. A federal district court presidin# over an e1uity receivership e0ercises the
traditional, co$$on la) po)ers of e1uity and thereby has broad po)ers in fashionin#
appropriate relief. Liberte Capital Group, LLC v. Capwill, ?<. 9.8d J?8, JJ, (<
th
Cir. .//<"L see
also 9ed. R. Civ. F. << (The practice in the ad$inistration of estate by receivers . . . shall be in
accordance )ith the practice heretofore follo)ed in the courts of the Cnited Dtates or as provided
in rules pro$ul#ated by the district court.!". Arisin# fro$ that authority, the Court is e$po)ered
to order the sale of receivership property. See SEC v. American Capital Invs., Inc., B@ 9.8d
,,88, ,,?? (B
th
Cir. ,BB<" (approvin# receiver2s decision to sell receivership estate property",
abro#ated on other #rounds, Steel Co. v. Citizens or a !etter Environment, J.8 C.D. @8 (,BB@"
Q't is #enerally conceded that a court of e1uity havin# custody and control of property has the
po)er to order a sale of the sa$e in its discretion. The po)er of sale necessarily follo)s the

(otice of Dale. Also, as of the filin# of this %otion, appro0i$ately .,./; of the e$ails sent by
the Receiver )ere returned as undeliverable. (Kane :ecl. E ,;."
,,

po)er to ta*e possession and control of and to preserve property, restin# in the soverei#nty and
e0ercised throu#h courts of chancery, or courts havin# statutory po)er to $a*e the sale.!2 Id.
(1uotin# . Clar" on #eceivers H ?@. (8d ed. ,BB."" (e$phasis o$itted"L see also SEC v. Elliot,
BJ8 9..d ,J</, ,J<< (,,
th
Cir. ,BB." (authoriGin# receiver2s disposal of receivership assets".
,B. The Court also has )ide discretion to set the ter$s and procedures used to sell
personal property so as to $a0i$iGe the proceeds fro$ such sales. See $.S. v. Stonehill, @8 9.8d
,,J<, ,,</ (B
th
Cir. ,BB<" (holdin# that district court had discretion under .@ C.D.C. H .//? to
tailor re1uire$ents for sellin# personal property"L $nited States v. !ranch Coal Corp., 8B/ 9..d
;, ,/ (8d Cir. ,B<@" (holdin# that court2s e0ercise of discretion in settin# ter$s and conditions
for 5udicial sales )ill be undisturbed other than for abuse of discretion". Cnder .@ C.D.C. H
.//?, the Court is afforded discretion to order the sale of personal property )ithout i$posin# the
sa$e procedural re1uire$ents set for the sale of real property. .@ C.D.C. H .//? (providin# that
sale of personal property shall follo) re1uire$ents of sale of real property unless the court
orders other)ise.!". 'n deter$inin# )hether to approve a sale, the Court $ay ta*e into account
the uni1ue facts and circu$stances surroundin# the proposed sale, includin# the precarious
financial condition of the assets bein# sold. %anzer v. &uines, ?,. 9..d ..,, ...-..8 (8d Cir.
,B<B" (approvin# e0pedited sale in the absence of financial appraisal and li$ited notice in li#ht
of corporation2s deterioratin# financial condition". 'ndeed, in overseein# a receivership, the
Court $ust $a*e rules )hich are practicable as )ell as e1uitable.! See SEC v. &ard', @/8 9..d
,/8?, ,/8B (B
th
Cir. ,B@<".
./. The Court should approve the proposed sale of the Furchased Assets to the
Furchaser as in the best interests of the receivership estate. As a threshold $atter, in locatin# a
)illin# buyer, the Dellers faced a nu$ber of obstacles ste$$in# fro$ the uni1ue nature of the
,.

assets bein# offered for sale. 9irst, the Furchased Assets lar#ely consists of uni1ue intan#ible
property that are not readily valued. 9or e0a$ple, because of the Deller2s inco$plete records, the
Dellers cannot (and under the AFA do not" )arrant the e0istence of any specific intellectual
property such as trade$ar*s, copyri#hts, trade na$es or lo#os. (See Kane :ecl. E0. : (AFA" H
,.,(c" (if any e0ists!" & ?., (li$itin# )arranties and representations of Dellers to the e0istence
of authority to enter into the AFA"." 9urther, #iven the relatively recent and necessary chan#es
to the &'( Club described above, includin# the ter$ination of the 1uestionable Affiliate Fro#ra$
and discontinuation of the use of $isleadin# inco$e clai$s fro$ the &'( Club $ar*etin#, the
Dellers had little relevant operational history to provide potential buyers to forecast the &'(
Club2s future perfor$ance. %oreover, in the )a*e of the prolon#ed uncertainty re#ardin# the
future of the &'( Club, the &'( Club has e0perienced a sustained trend of declinin#
$e$bershipRthe pri$ary source of the &'( Club2s revenues. (See Receiver2s Decond Report
=:*t. > @,J-,A at . (describin# decline in $e$bership durin# course of receivership"."
.,. (ot)ithstandin# these obstacles, under the ter$s of the proposed sale, the
receivership estate )ill receive i$$ediate cash consideration of -.//,///, plus a percenta#e of
future $e$bership dues over the course of the ne0t t)elve $onths. (See Kane :ecl. E0. :
(AFA" H..,." E0ercisin# its sound business 5ud#$ent, the Receiver dee$s the proposed sale to
be the hi#hest and best offer received. Critically, the proposed sale appropriately balances ris*s
to the receivership estate by ensurin# a certain $ini$u$ recovery (-.//,/// cash due at closin#"
)hile also providin# an additional return based on the &'( Club2s actual future perfor$ance.
(Kane :ecl. E ,8." (o other co$petin# offer si$ilarly #uaranteed the receivership estate a
substantial $ini$u$ recovery. (Id. E ,,."
,8

... Additionally, #iven the Furchaser2s stron# and len#thy connection )ith the &'(
Club and invest$ent in the success of the &'( Club, as reflected by the Furchaser2s substantial
up-front pay$ent, the Furchaser has both the fa$iliarity and incentive to successfully operate the
&'( Club thereby $a0i$iGin# the value of the install$ent pay$ents due the Dellers. (Id. E ,8."
4y contrast, bidders that proposed to rely e0clusively on a share of future revenue )ithout
co$$ittin# to a substantial up-front pay$ent had less incentive to $a0i$iGe future revenues in
turn $a*in# the value of offers relyin# solely on a share of such revenues $ore uncertain.
.8. To induce the Furchaser to enter into the AFA, the Dellers a#reed to o$it any
provisions providin# for overbiddin#. The Receiver had already publicly invited offers for the
Furchased Assets )ithout receivin# any other co$petin# bids that #uaranteed the receivership
estate a si$ilar recovery. (Id. E ,?." As such, overbiddin# )ould have been unli*ely to result in
any $aterial increase in price )hile potentially ris*in# the loss of the Furchaser2s offer and
attendant recovery for the receivership estate. (Id." The Furchaser is unaffiliated )ith the
Receiver and the ter$s of the AFA )ere proposed, ne#otiated, and entered into )ithout
collusion, in #ood faith, and fro$ ar$2s len#th bar#ainin# position. (See id. EE ,., ,?."
.?. 'ndeed, havin# e0posed the Furchased Assets to the $ar*etplace by )idely
solicitin# bids fro$ li*ely buyers )ho )ere $ost fa$iliar )ith the assets, the consideration
provided by the proposed sale reflects the fair $ar*et value of the Furchased Assets. See !an" o
America (at. %rust and Sav. Ass)n v. *+, (orth LaSalle Street -artnership, J.< C.D. ?8?, ?J;
(,BBB"(reco#niGin# that the best )ay to deter$ine value is e0posure to a $ar*et!". As such, the
Court should approve the proposed sale to the Furchaser on the ter$s set forth in the AFA as in
the best interests of the receivership estate.
,?

/. THE COURT HAS THE AUTHORIT. TO SELL THE ASSETS FREE AND CLEAR OF LIENS
AND ENCUM/RANCES.

.J. 't has lon# been reco#niGed that a federal court presidin# over a receivership $ay
authoriGe the assets of the receivership to be sold fee and clear of liens and related clai$s. See
#egions !an" v. Eg'ptian Concrete Co., (o. /8-cv-,.</, .//B 3L ??8,,88, at S; (E.:. %o.
:ec. ,, .//B" (collectin# authority"L see also .iners) !an" o Wil"es/!arre v. Ac"er, << 9..d
@J/, @J8 (.d Cir. ,B88" (A court of e1uity, under proper circu$stances, has the po)er to order
a receiver to sell property free and clear of all encu$brances.!". Cnder Local Rule <<.,, the
Court is to ad$inister receivership estates si$ilar to that in ban*ruptcy cases.! Local Rule <<.,.
As a cornerstone of federal ban*ruptcy la), ban*ruptcy courts, )hich, li*e courts ad$inisterin#
receivership estates, are courts of e1uity, $ay authoriGe the sale of estate assets free and clear of
liens and interests. ,, C.D.C. H 8<8.
.<. Nere, the Receiver is una)are of any perfected security interests in any of the
Furchased Assets. (Kane :ecl. E ,J." (evertheless, any such liens or interests shall attach to the
proceeds of the sale in the sa$e a$ount, and )ith the sa$e validity, e0tent and priority as
currently e0ists. As the proposed sale reflects the $ar*et value of the Furchased Assets and as
any e0istin# liens are to be transferred to the proceeds, no creditors )ill be pre5udiced by such
sale. Accordin#ly, the Court should e0ercise its e1uitable po)er to approve the proposed sale
free and clear of all liens and encu$brances.
*HEREFORE, Robb Evans & Associates LLC, in its capacity as court-appointed
Receiver, respectfully re1uests the Court enter an order substantially in the for$ of attached
E0hibit ,+ (a" #rantin# the %otionL (b" approvin# the sale of the Furchased Assets by private sale
to the Furchaser under the ter$s of the AFAL (c" providin# the Furchased Assets shall be
transferred to the Furchaser free and clear of all liens and encu$brances, if any, )ith such liens
,J

to attach to the proceeds of the sale in the sa$e a$ount, and )ith the sa$e validity, e0tent and
priority as currently e0istsL (d" authoriGin# the Receiver to e0ecute all docu$ents and
instru$ents necessary or convenient to co$plete, i$ple$ent, effectuate and close the sale of the
Furchased Assets to the FurchaserL and (e" #rantin# such other relief as the Court dee$s 5ust and
proper.
:ated+ April .@, ./,? Respectfully sub$itted,

RO// EVANS 2 ASSOCIATES LLC,
RECEIVER

4y+ KsK 4lair R. TanGi#
(6ne of 'ts Attorneys"

4lair R. TanGi# ((o. <.;8.B8"
7ohn NiltG ((o. <.@B;??"
Kathy 3antuch ((o. <.B?/8?"
HILT3 *ANTUCH 2 3AN3I+ LLC
J8 3est 7ac*son 4lvd., Duite ./J
Chica#o, 'llinois </</?
Telephone+ 8,..J<<.B//@
9a0+ 8,..J<<.B/,J

Counsel or #obb Evans 0 Associates LLC, in
its capacit' as #eceiver

CERTIFICATE OF SERVICE

', 4lair R. TanGi#, an attorney, hereby certify that, on the .@
th
day of April ./,?, ' caused
a true and correct copy of the fore#oin# Receiver2s %otion 9or Entry of an 6rder Approvin#
Dale of &in Club Assets 9ree And Clear of All Liens, Clai$ and Encu$brances to be served via
the Court2s electronic case filin# syste$ on the follo)in#+

Ki$ball Richard Anderson
*andersonU)inston.co$

Tho$as Lee Kirsch, ''
t*irschU)inston.co$

Andre) Dullivan
acsullivanU)inston.co$

%ichael %ora
$$oraUftc.#ov

7onathan Cohen
7cohen.Uftc.#ov

A$anda 4. Kostner
a*ostnerUftc.#ov

:avid 62Toole
dotooleUftc.#ov

KsK 4lair R. TanGi#
E4HI/IT 5


EASTERN DIVISION


Plaintiff,

v.

KEVIN TRUDEAU,

Defendant.

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Cae N!." #$%C%$&#'


ORDER APPROVIN+ SALE OF +IN CLU/ ASSETS
FREE AND CLEAR OF ALL LIENS, CLAIMS AND ENCUM/RANCES

This $atter co$in# to the Court on the Receiver2s %otion 9or Entry of an 6rder
Approvin# the Dale of the &'( Club Assets 9ree and Clear of All Liens, Clai$s and
Encu$brances (the %otion!"L the Court havin# revie)ed the %otion and :eclaration of 4ric*
Kane in Dupport of the %otionL all parties in interest havin# due noticeL and the Court bein#
other)ise fully advised as to the pre$isesL
't is hereby 6R:ERE:+
,. The %otion is #rantedL
.. As the AFA )as ne#otiated, proposed and entered into )ithout collusion, in #ood
faith, and fro$ ar$2s len#th bar#ainin# positions the sale of the Furchased Assets by private sale
to the Furchaser under the ter$s of the AFA is approved.
,

8. '$$ediately upon satisfaction of all of the conditions set forth in the AFA, the
Furchased Assets sold to Furchaser pursuant to the AFA shall be transferred to Furchaser free

1
Cnless other)ise defined herein, all capitaliGed ter$s shall have the $eanin# ascribed to the$
in the %otion.

and clear of all Encu$brances! (as defined in the AFA" and free and clear of any and all
Liabilities! (as defined in the AFA", includin# but not li$ited, to any clai$s (*no)n or
un*no)n", past, present or asserted or to be asserted by current or past $e$bers, associates or
affiliates )ith respect to the &'( Club, e0cept for any Encu$brance that $ay e0ist as a result of
the stora#e or )arehousin# of the TAF AssetsL
?. Any currently e0istin# liens or encu$brances on the Furchased Assets shall attach
to the proceeds of the sale in the sa$e a$ount, and )ith the sa$e validity, e0tent and priority as
currently e0ists.
J. The Receiver is authoriGed and directed to e0ecute all docu$ents and instru$ents
necessary or convenient to co$plete, i$ple$ent, effectuate and close the sale of the Furchased
Assets to the Furchaser.
<. The Court retains 5urisdiction to resolve any controversy or clai$ arisin# out of or
relatin# to this A#ree$ent, or the breach hereof.
;. The AFA and the transactions conte$plated thereby $ay be specifically enforced
a#ainst and bindin# upon, and not sub5ect to re5ection or avoidance by, the Dellers or their
respective successors and assi#ns.

:ATE:+ %ay MM, ./,? E(TER+

MMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMM
C('TE: DTATED :'DTR'CT C6CRT 7C:&E


Frepared by+
4lair R. TanGi# (AR:C > <.;8.B8"
N'LTT 3A(TCCN & TA(T'& LLC
3est 7ac*son 4lvd., Duite ./J
Chica#o, 'llinois </</?

Counsel or #obb Evans 0 Associates LLC, in its capacit' as #eceiver
EASTERN DIVISION


Plaintiff,

v.

KEVIN TRUDEAU,

Defendant.

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)

Cae N!." #$%C%$&#'


DECLARATION OF -RICK KANE IN SUPPORT OF RECEIVER.S
MOTION FOR ENTR/ OF AN ORDER APPROVIN+ SALE OF +IN CLU-
ASSETS FREE AND CLEAR OF ALL LIENS, CLAIMS AND ENCUM-RANCES

I, Brick Kane, state as follows:
1. I am President of Robb Evans & Associates LL !t"e #Receiver$%, t"e co&rt'
a((ointed receiver in t"e above'ca(tioned action. I am one of t"e de(&ties res(onsible for t"e
da)'to'da) s&(ervision and administration of t"e receivers"i( estate, incl&din* t"e investi*ation
of assets and (otential assets of t"e receivers"i( estate and t"e sale of s&c" assets.
+. I s&bmit t"is declaration in s&((ort of t"e Receiver,s -otion for Entr) of an .rder
A((rovin* /ale of 0I1 l&b Assets 2ree and lear of All Liens, laims and Enc&mbrances.
3. E4ce(t w"ere indicated ot"erwise, I base t"is declaration on m) (ersonal
knowled*e, incl&din* on information I "ave *ained from t"e books and records of t"e
receivers"i( estate and receivers"i( entities. If called as a witness in t"is matter, I co&ld and
wo&ld com(etentl) testif) to t"e matters set fort" below.
5. /ince its a((ointment, t"e Receiver "as been workin* to stabili6e t"e o(erations
of t"e 0lobal Information 1etwork !t"e #0I1 l&b$% so t"at it co&ld be o(erated as a le*al and
financiall) stable com(an) and &ltimatel) transferred to new owners for a fair (rice. 7"e
+

Receiver comm&nicated t"ose intentions to t"e members of t"e 0I1 l&b on a n&mber of
occasions, incl&din* in anno&ncements to t"e 0I1 l&b members dated 8ecember 13, +913 and
:an&ar) ;, +915. A tr&e and correct co() of t"e 8ecember 13, +913 anno&ncement is attac"ed to
t"is declaration as E4"ibit A. A tr&e and correct co() of t"e :an&ar) ;, +915 anno&ncement is
attac"ed to t"is declaration as E4"ibit B.
<. At t"e o&tset of t"e Receivers"i(, t"e 0I1 l&b "ad s&bstantial (re'receivers"i(
claims a*ainst it, bot" dis(&ted and &ndis(&ted, totalin* at least =>.< million. /&c" (re'
receivers"i( debts ma) incl&de claims b) 0I1 l&b members and affiliates to certain bon&s and
incentive (a)ments &nder vario&s member recr&itment (ro*rams, incl&din* 0o 0etter, /&mmer
/ales Bonan6a, /&mmer /ales Bonan6a /(onsor, 0et 3 Pro*ram, 1ewsletter, ?eekl) A&dio
Rewards, r&ise vo&c"er reci(ients, @isionar) and 2o&nder bon&ses, La6) -an order ref&nds
and Inner ircle bon&ses.
;. In li*"t of concerns re*ardin* t"e le*alit) of certain as(ects of t"e 0I1 l&b,s
o(erations, t"e Receiver eval&ated t"e 0I1 l&b,s #Affiliate Pro*ram,$ incl&din* t"e e4(ert
re(ort of economist Peter @ander 1at (re(ared for t"e 27. 7"e Receiver concl&ded t"at t"e
t"en'e4istin* Affiliate Pro*ram, w"ic" (aid commissions to affiliates for recr&itin* additional
members, likel) amo&nted to an ille*al ()ramid sc"eme. Accordin*l), on 1ovember 39, +913,
t"e Receiver terminated t"e Affiliate Pro*ram and ceased (a)in* commissions. 7"e Receiver
(aid t"e last commission (a)ments in 8ecember +913 for commissions earned in 1ovember
+913.
A. 7"e 0I1 l&b "as contin&ed to e4(erience a decline in members"i( since t"e
a((ointment of t"e Receiver, t"e termination of t"e Affiliate Pro*ram, and in t"e face of active
3

cam(ai*ns b) vario&s *ro&(s of former members to enco&ra*e ot"er members to discontin&e
(a)ment of t"eir d&es.
B. 0iven t"e &niC&e nat&re of t"e 0I1 l&b, t"e Receiver determined t"at t"e most
likel) b&)ers, as well as t"ose w"o (laced t"e "i*"est val&e on t"e 0I1 l&b,s assets, were
amon* e4istin* 0I1 l&b members. Accordin*l), on -arc" 1A, +915, t"e Receiver anno&nced
t"at it was solicitin* written letters of intent to (&rc"ase t"e assets of t"e 0I1 l&b. A tr&e and
correct co() of t"e Receiver,s -arc" 1A, +915 anno&ncement is attac"ed to t"is declaration as
E4"ibit .
>. In res(onse to its reC&ests for (ro(osals, t"e Receiver received nearl) +9
inC&iries e4(ressin* interest in acC&irin* t"e 0I1 l&b,s assets. 7"e Receiver declined to (&rs&e
a n&mber of offers t"at incl&ded s&bstantial and &nlikel) contin*encies, s&c" as (ro(osals t"at all
0I1 l&b members contrib&te =1,999 to (&rc"ase t"e 0I1 l&b,s assets. 7"e Receiver also
reDected offers t"at so&*"t to (&rc"ase onl) certain assets of t"e 0I1 l&b, s&c" as its
members"i( list, for amo&nts far less t"an t"eir val&e.
19. 7"e Receiver received two offers t"at (ro(osed consideration consistin*
e4cl&sivel) of f&t&re installment (a)ments determined as a (ercenta*e of net (rofits, wit" no
initial cas" (a)ment. 7"e Receiver deemed t"ese offers to be "i*"l) s(ec&lative beca&se t"e)
reC&ired t"e Receiver to t&rn over o(erational control of t"e 0I1 l&b t"ereb) de(rivin* t"e
Receiver of control over e4(enses t"at wo&ld, in (art, determine t"e net (rofit.
11. 2inall), AE/ ons&ltin*, LL !t"e #P&rc"aser$% (ro(osed to (&rc"ase
s&bstantiall) all of t"e 0I1 l&b,s assets for consideration of =+99,999 cas" at closin*, (l&s
installment (a)ments for twelve mont"s of BF of e4istin* member d&es and 5F of new member
d&es. 1o ot"er offer (ro(osed a similarl) s&bstantial &('front (a)ment at closin*.
5

1+. G(on information and belief, t"e P&rc"aser consists of an investment *ro&( of
c&rrent 0I1 -embers w"o "ave a lon*'time association wit" t"e 0I1 l&b. 7"e P&rc"aser is
&naffiliated wit" t"e Receiver.
13. 7"e Receiver deems t"e P&rc"aser,s offer to be t"e "i*"est and best offer received
beca&se, amon* ot"er t"in*s, t"e (ro(osed sale ens&res a certain minim&m recover) to t"e
receivers"i( estate b) (rovidin* a s&bstantial cas" (a)ment at closin*, w"ile also (rovidin* an
additional ret&rn based on t"e 0I1 l&b,s act&al f&t&re (erformance. 2&rt"er, *iven t"e
P&rc"aser,s stron* and len*t") connection wit" t"e 0I1 l&b and willin*ness to make a
s&bstantial initial cas" (a)ment, t"e P&rc"aser a((ears to "ave bot" t"e familiarit) and incentive
to s&ccessf&ll) o(erate t"e 0I1 l&b t"ereb) ma4imi6in* t"e val&e of t"e (ro(osed installment
(a)ments.
15. After *ood fait", arms'len*t" ne*otiations, t"e /ellers and P&rc"aser entered into
t"at certain Asset P&rc"ase A*reement dated A(ril 1;, +915 !t"e #APA$%, s&bDect to co&rt
a((roval. A tr&e and correct co() of t"e APA is attac"ed to t"is declaration as E4"ibit 8. 7o
ind&ce t"e P&rc"aser to enter into t"e APA, t"e APA omits an) (rovisions (rovidin* for
overbiddin*. 0iven t"at t"e Receiver "ad alread) (&blicl) invited ot"er offers for t"e 0I1
l&b,s assets wit"o&t receivin* an) ot"er com(etin* bids t"at *&aranteed t"e receivers"i( estate
a similar recover), t"e Receiver believes t"at overbiddin* wo&ld "ave been &nlikel) to res&lt in
an) material increase in (rice w"ile (otentiall) riskin* t"e loss of t"e P&rc"aser,s offer and
attendant recover) for t"e receivers"i( estate.
1<. 7"e Receiver is &naware of an) (erfected sec&rit) interests in an) of t"e assets to
be transferred to t"e P&rc"aser &nder t"e APA.

I, Blair R. Jan6i*, an attorne), "ereb) certif) t"at, on t"e +B
t"
da) of A(ril +915, I ca&sed
a tr&e and correct co() of t"e fore*oin* 8eclaration of Brick Kane in /&((ort of Receiver,s
-otion 2or Entr) of an .rder A((rovin* /ale of 0in l&b Assets 2ree And lear of All Liens,
laim and Enc&mbrances to be served via t"e o&rt,s electronic case filin* s)stem on t"e
followin*:

Kimball Ric"ard Anderson
kandersonKwinston.com

7"omas Lee Kirsc", II
tkirsc"Kwinston.com

Andrew /&llivan
acs&llivanKwinston.com

-ic"ael -ora
mmoraKftc.*ov

:onat"an o"en
:co"en+Kftc.*ov

Amanda B. Kostner
akostnerKftc.*ov

8avid .,7oole
dotooleKftc.*ov

LsL Blair R. Jan6i*
EXHIBIT A
Case: 1:03-cv-03904 Document #: 858-1 Filed: 04/28/14 Page 1 of 34 PageID #:15684
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 like to take this opportunity to clarify our current
and future plans with regards to the operations of GIN.
As most of you know, on August 7, 2013 the U.S. District Court for the Northern District of Illinois
entered an Order Appointing a Receiver and Implementing Ancillary Relief (Order). The Order
appointed Robb Evans & Associates LLC as Receiver over the assets of Kevin Trudeau, including but
not limited to Global Information Network FDN, Website Solutions USA, and all Trudeau Entities
whether foreign or domestic. A copy of the Order can be viewed on our website at
www.robbevans.com.
Section V of the Order outlines the duties and authority of the Receiver. Subsection 12 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..." (Emphasis added). Under the direction
of the Receiver, GIN has made a number of changes in its Marketing approach. These changes are
designed to meet the first criteria in Section 12, that is, that the business must be run legally. GIN staff
is working diligently to design an enhanced Member benefits program which includes, among other
things, the expansion of GIN's accredited education curriculum, providing a wider variety of education
topics and event formats, sponsoring local and major events, trainings, recognition and facilitating
networking opportunities designed for overall personal growth and improvement.
The second duty of the Receiver under Section 12 of the Order requires the Receiver to determine if
the company can be operated profitably. Actions by a few rogue Members encouraging other
Members to stop paying dues constitutes a violation of the Order as it interferes with the duties of the
Receiver.
It is the Receiver's 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. Assuming GIN can become financially stable and be
operated profitability, it is the intention of the Receiver to get permission from the Court to transfer GIN
operations for a fair price to a new owner or ownership group. The Receiver's oversight of the GIN
operations could then be terminated and GIN would be operated by the new owners.
Efforts to disrupt these initiates and the continued business operations of GIN can unfairly penalize
thousands of other Members that are currently engaged in GIN's 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 make 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 recognizes the need to support a strong interchange of ideas and information
with Members that "know 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.
As a reminder, the Receiver is here for the purpose of stabilizing the organization, 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: ACCORDING TO THE INFORMATION GATHERED BY THE RECEIVER OF THE GLOBAL INFORMATION NETWORK, THE
ENTITY REFERRED TO AS THE GIN COUNCIL DOES NOT EXIST AND THEREFORE ANY REFERENCE OR ENDORSEMENT OF
THIS ENTITY BY ANY OF THE GLOBAL INFORMATION NETWORKS PREVIOUS TRAINERS/HOSTS SHOULD NOT BE
INTERPRETED AS AN ENDORSEMENT, BENEFIT OR PART OF THE TRAINING CURRICULUM OF THE GIN ORGANIZATION. GINS
AFFILIATE PROGRAM MAY ALSO BE REFERRED TO IN PAST TRAININGS OR EDUCATIONAL MATERIALS. GINS AFFILIATE
PROGRAM OFFICIALLY ENDS ON NOVEMBER 30, 2013.
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EXHIBIT B
EXHIBIT C
EXHIBIT D
EXHIBIT E
EASTERN DIVISION


Plaintiff,

v.

KEVIN TRUDEAU,

Defendant.

)
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)
)
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)
)
)
)

Cae N!." #$%C%$&#'


NOTICE OF MOTION

PLEASE TAKE NOTICE that, on Tuesday, May 27, 2014, at 1:30 !"!, o# as soon
the#ea$te# as %ounse& "ay 'e hea#d, the unde#s()ned sha&& aea# 'e$o#e the *ono#a'&e +o'e#t ,!
-ett&e"an, .n(ted States /(st#(%t Cou#t $o# the No#the#n /(st#(%t o$ I&&(no(s, Easte#n /(0(s(on, o#
su%h othe# 1ud)e as "ay 'e s(tt(n) (n h(s &a%e (n Cou#t#oo" 1703, 212 S! /ea#'o#n St#eet,
Ch(%a)o, I&&(no(s 30304, and sha&& #esent the Re-eive). M!ti!n f!) Ent)/ !f an A00)!vin1
Sale !f +IN Cl2( Aet F)ee and Clea) !f All Lien, Clai, and En-2,()an-e, a %oy o$
4h(%h (s he#e'y se#0ed uon you!

/ated: A#(& 25, 2014 +ese%t$u&&y Su'"(tted,
RO33 EVANS 4 ASSOCIATES LLC,
RECEIVER

6y: 7s7 6&a(# 8an9()
:One o$ Its Atto#neys;

6&a(# +! 8an9() :No! 3273223;
<ohn =! *(&t9 :No!3252744;
Kathy ,antu%h :No! 3224034;
HILT5 *ANTUCH 4 5AN5I+ LLC
>3 ,est <a%?son 6&0d!, Su(te 20>
Ch(%a)o, I&&(no(s 30304
Te&ehone: 312!>33!2005
=a@: 312!>33!201>

Counsel for Robb Evans & Associates LLC,
Receiver

I, 6&a(# +! 8an9(), an atto#ney, he#e'y %e#t($y that, on the 25
th
day o$ A#(&, 2014, I
%aused a t#ue and %o##e%t %oy o$ the $o#e)o(n) Not(%e o$ Mot(on to 'e se#0ed th#ou)h the
Cou#tAs E&e%t#on(% Case =(&(n) Syste" on the $o&&o4(n):

K("'a&& +(%ha#d Ande#son
?ande#sonB4(nston!%o"

Tho"as Lee K(#s%h, II
t?(#s%hB4(nston!%o"

And#e4 C! Su&&(0an
a%su&&(0anB4(nston!%o"

M(%hae& Mo#a
""o#aB$t%!)o0

<onathan Cohen
<%ohen2B$t%!)o0

A"anda 6! Kostne#
a?ostne#B$t%!)o0

/a0(d OAToo&e
dotoo&eB$t%!)o0

7s7 6&a(# +! 8an9()

Trudeau Civil Case Document 857 Thru 859 Receivers Motion For Entry of An Order Approving Sale of GIN Etc 04-28-14

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Trudeau Civil Case Document 857 Thru 859 Receivers Motion For Entry of An Order Approving Sale of GIN Etc 04-28-14

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UNITED STATES DISTRICT COURT FOR

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