Trudeau Civil Case Documents 790 and Exhibits 11-15-13 Receivers First Motion for Interim Approval of Fees and Expenses

8/13/2019 Trudeau Civil Case Documents 790 and Exhibits 11-15-13 Receivers First Motion for Interim Approval of Fees and Expenses

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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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Case No.: 03-C-3904

Hon. Robert W. Gettleman

RECEIVERS FIRST MOTION FOR

INTERIM APPROVAL OF FEES AND EXPENSES

Robb Evans & Associates, LLC (the Receiver), in its capacity as court-appointed

receiver over the assets of Kevin Trudeau and the Trudeau Entities, respectfully submits this first

interim fee application seeking approval to pay fees and expenses of the Receiver and

professionals retained by the Receiver, including the law firm Hiltz Wantuch & Zanzig LLC

(HWZ). In this application, the Receiver seeks approval of fees and expenses incurred during

the first two months of the receivership, from August 7, 2013, through September 30, 2013 (the

First Interim Period). In further support of its motion, the Receiver states as follows:

BACKGROUND

1. On August 7, 2013, the Court entered the Order Appointing a Receiver andImplementing Ancillary Relief [Dkt. # 742] (the Receivership Order) appointing Robb Evans

& Associates LLC as receiver over the assets of Defendant Kevin Trudeau (Trudeau), the

Trudeau Entities, and any affiliates or subsidiaries thereof controlled by Trudeau or any Trudeau

Case: 1:03-cv-03904 Document #: 790 Filed: 11/15/13 Page 1 of 11 PageID #:14190


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Entity.1 In appointing the Receiver, the Court adopted the FTCs recommendation that any such

receiver should be a forensic accountant with asset-tracing experience.

2. Under the Receivership Order, the Receiver was authorized to retain attorneys andother professionals as the Receiver deemed advisable or necessary in the performance of the

Receivers duties. (Receivership Order at V(6).) Pursuant to such authority, the Receiver

retained the law firm of Hiltz Wantuch & Zanzig LLC (HWZ) to represent the Receiver and

assist it in carrying out its duties in the matter.

3. As detailed below, for the First Interim Period of August 7, 2013, throughSeptember 30, 2013, the Receiver presently seeks approval of its professional fees in the total

amount of $289,405.40, and out-of-pocket expenses totaling $17,869.92, including travel-related

expenses. Additionally, the Receiver seeks authority to pay legal fees incurred during the First

Interim Period by HWZ totaling $42,486.

4. Pursuant to the terms of the Receivership Order, the Receiver and itsprofessionals, are entitled to reasonable compensation for the performance of duties undertaken

pursuant to this order and for the cost of actual out-of-pocket expenses they incur. (Receivership

Order XII(1).) If approved, such compensation is to be paid first from assets recovered

pursuant to the Receivership Order, and then, if necessary, from the Escrow Account described

in the Receivership Order. (Id.at XII(4) & (5).) As reflected in the financial report

accompanying the Receivers Second Supplemental Report [Dkt. #785], which is re-attached

here for the parties convenience as Exhibit A, as of September 30, 2013, before applying

Receivership fees and expenses, the Receiver recovered net proceeds of approximately $2.7 MM

1Capitalized terms not otherwise defined herein shall have the meaning ascribed to them in theReceivership Order.



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including $1,512,077.07 from operating the Receivership entities, exclusive of $486,854.80 in

reserves held by the receivership estatescredit card processor.

5. Accordingly, the Receiver has more than sufficient funds to pay the professionalfees and expenses, including legal fees, requested herein from assets recovered pursuant to the

Receivership Order, without needing to draw on the Escrow Account. Indeed, even after

applying all professional fees and expenses, the receivership estate will still have a net balance of

nearly $1 million. (See Ex. A.)

OVERVIEW OF RECEIVERS ACTIVITIESAND FEES

6.

The Receiver filed its First Report on September 6, 2013, in which it detailed its

activities from the time of its appointment through September 5, 2013. The Receiver submitted

its First Supplemental Report on September 16, 2013, detailing, among other things, (a) its

discovery of the Australian bank account held at St. George Bank Ltd., and (b) its initial analysis

of certain bank records for GIN-FDN, including post-receivership transfer to Trudeaus wifes

bank account in Antigua. Following the submission of those reports, the Receiver participated in

a number of hearings before the Court in which the Receiver further updated the Court on the

Receivers ongoing activities. On October 25, 2013, the Receiver filed its Second Supplemental

Report in which it updated the Court on the financial condition of the receivership estate from

the inception of the receivership through September 30, 2013.

7. In addition, the Receiver has maintained detailed records of the billable time it hasdevoted to this matter and for which it is now seeking authority to pay. Attached as Exhibit B to

this application are comprehensive invoices prepared by the Receiver (and redacted for privilege)

setting forth the specific tasks performed and the time spent performing those tasks by the

Receivers timekeepers.



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8. As reflected in more detail in its reports to the Court and the attached detailedinvoices, the Receiver provides the following overview of its activities during the First Interim

Period:

9. During the first two months of the receivership, the Receiver assumed control ofnumerous Trudeau Entities located in the United States as well as certain of the personal assets

of Trudeau. The Receiver has further sought to exert control over the remaining Trudeau

Entities located overseas, and investigate and identify the existence of any as yet undisclosed

assets.

10.

As part of assuming control over the various Trudeau Entities, the Receiver has

conducted a top to bottom review of those entities operations, including their accounting and

payroll functions. In the course of that review, the Receiver has met with current management

and staff, and reviewed the books and records of the companies. The Receiver has sought to

minimize expenses, including reducing staffing levels to correspond to the Trudeau entities

ongoing needs. The Receiver cancelled a previously planned cruise for GIN members after

determining that the companies lack sufficient funding to finance the event. The Receiver

approved the expenditure of $340,000 to fund initial expenses for a pre-planned membership

event in Washington D.C. that the Receiver anticipates it will recover from the proceeds from

such event. The Receiver continues to oversee managements operation of the Trudeau Entities.

11. Mindful of the Courts direction in the Receivership Order that the Receiver mayonly continue and conduct the business of any of the Trudeau Entities to the extent it is possible

to operate such business legally, the Receiver has continued to review the legality of such

businesses and has commenced tailoring the Trudeau Entities operations accordingly. For

example, the Receiver has begun the process of causing the Trudeau Entities to remove false and



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misleading claims from its websites. As reflected in its First Report, the Receiver is continuing

to work on a marketing plan that can be operated lawfully. As provided by the Receivership

Order, if the Receiver determines that a Trudeau Entity cannot be operated legally, the Receiver

will promptly notify the Court and parties and seek the Courts permission to terminate the

entitys respective operations.

12. Soon after assuming control of the various domestic Trudeau Entities, theReceiver determined that credit card payments from their consumers were being routed to an

overseas accounts located in the Isle of Man. The Receiver took steps to cause a domestic credit

card processor to take over such transactions and deposit the proceeds in a domestic bank

account. Through these actions, excluding reserve amounts retained by the credit card processor,

the Receiver has captured in excess of $1.4 million in credit card charges that otherwise would

have been transferred off-shore.

13. The Receiver has also met with Trudeau and his counsel on numerous occasionsto coordinate the turnover of known receivership assets and to further identify and investigate the

possible existence of any other assets. The Receiver has taken steps to terminate the lease

relating to the White Oak Property and assume control of Trudeaus possessions therein. The

Receiver has also taken control over Trudeaus real property located in Ojai, California and the

related sale process.

14. As directed by the Receivership Order, and after soliciting the input of bothTrudeau and the FTC, the Receiver prepared a necessary and ordinary living expenses budget for

Trudeau and administered that budget until the Court terminated such allowance in its September

26, 2013 Order [Dkt. #760] granting the FTCs motion to modify the Receivership Order.



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15. The Receiver has also reviewed records relating to Trudeaus legal defense fundand coordinated the transitioned the administration of such fund to Trudeaus present counsel.

16. In connection with its investigation of the existence of other undisclosed assets,the Receiver has obtained and analyzed records from Marc Lane, Trudeaus former asset

protection advisor.

17. During the First Interim Period, the Receiver also attempted to coordinate withLee Kenny, a close associate of Trudeau who appears to nominally control GIN-FDN from

England. As reported in the Receivers first report, Lee Kenny had promised the production of

all accounting records related to GIN-FDN, but, until more recently, had only produced certain

bank statements.

18. The Receiver has also served the Receivership Order on various financialinstitutions at which the Trudeau Entities appeared to hold accounts. The Receiver assumed

control over such accounts and requested relevant banking records to facilitate an analysis of the

flow of funds into and out of such accounts. Using information obtained from such records, the

Receiver also coordinated with its counsel to issue subpoenas for bank records of third parties

that appear to have received substantial funds from the Trudeau Entities.

19. During the First Interim Period, the Receiver also attended multiple hearingsbefore the Court addressing Trudeaus failure to fully cooperate with the Receiver and otherwise

violate the Courts prior orders. On September 18, 2013, the Court found Trudeau in contempt

ordering him coercively incarcerated. The Court directed the Receiver to interview Trudeau at

the Metropolitan Correctional Center that evening and report back to the Court the following

day. On September 19, 2013, the Receiver appeared before the Court and reported on the results

of its interview and additional investigation. The Court directed Trudeau to be released and set a



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status hearing for the following week, requiring the Receiver to again report on Trudeaus

compliance with the Receivers instructions during the interim. The Receiver met and

correspond with Trudeau through the following week. On September 26, 2013, the Receiver

again appeared before the Court to report on the activities of the preceding week. As a result of

the events related to these hearing, the Receiver (with its counsel) devoted an intense effort to

preparing for each hearing, attempting to solicit Trudeaus cooperation, and following up on any

new information provided. Throughout, the Receiver and its counsel also coordinated with the

FTC so as to draw upon the FTCs familiarity with the substantial evidentiary record in this case.

20.

During the First Interim Period, the Receivers personnel collectively devoted

1,048.1 hours to this matter, incurring fees totaling $289,405.40, for an effective blended rate of

approximately $276 per hour. The principal members of the Receivers firm and senior

associates working on this matter billed at an hourly rate of $301.50. All of the fees charged by

the Receiver in this matter reflect a 10% discount from the firms private sector rates. As

required by the Receivership Order, the compensation sought in this motion is consistent with

the rate structure and terms outlined in Exhibit 1 of the FTCs Statement With Respect to the

Appointment of a Receiver [Dkt. #730]. (See Receivership Order XII(2).)

21. In addition to the professional fees sought by the Receiver, the Receiver has alsoincurred $17,869.92 in out-of-pocket expenses. The vast majority of these expenses are costs

associated with travel by the Receivers personnel to Chicago during August 2013 to meet with

Trudeau and visit the Trudeau Entitiesfacilities in Westmont, Illinois in order to effect control

over those entities and meet with the Trudeau Entities staff and management. Such travel

expenses total $16,352.68.The remaining expenses for which the Receiver seeks reimbursement



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are as follows: $582.82 for investigative search costs; $149.05 for office telephone and supplies;

$653.80 for postage and delivery expenses; $131.57 for subpoena and document reproduction.

OVERVIEW OF LEGAL SERVICES AND FEES

22. Receivers counsel maintained detailed records of the billable time for which theReceiver now seeks authority to pay. Attached as Exhibit C to this Motion is a comprehensive

invoice prepared by HWZ (and redacted for privilege) setting forth the specific tasks performed

and the time spent performing those tasks by HWZstimekeepers.

23. As reflected in the detailed invoice, during the First Interim Period, HWZprovided the following services to the Receiver:

Advised the Receiver concerning its authority and obligations under theReceivership Order.

Assisted the Receiver in preparing an ordinary and necessary living expensebudget provided for under the Receivership Order, including advising theReceiver regarding comparable standards used by IRS and under BankruptcyCode.

Advised Receiver regarding FTCs motion to modify the Receivership Order todeny Trudeau living expense budget.

Advised Receiver regarding rights in connection with Oak Park Property,including corresponding with counsel for owner of Oak Park Property todesignated property as Business Premises under Receivership Order.

Advised Trustee in connection interference by L. Kenny with Receivers controlof GIN-FDN.

Assisted the Receiver in revising, finalizing and filing the Receivers First Reportand two supplemental reports.

Prepared and served on the Receivers behalf sevensubpoenas to variousfinancial institutions seeking to locate assets or potential assets of the receivershipestate.

Prepared and filed various pleading regarding imposition of coercive sanctions,including responses to statements filed by FTC and Trudeau.



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Attended multiple hearings before the Court in connection with imposition ofcoercive sanctions and subsequent hearings affording Trudeau opportunity topurge contempt.

Advised and assisted Receiver in preparing for and interviewing Trudeauregarding disposition of potential assets of the receivership, including interviewconducted during Trudeaus incarceration.

Advised Receiver regarding responses to various entities asserting claims againstreceivership estate for pre-receivership obligations.

24. During the two months comprising the First Interim Period, HWZs professionalsexpended 118.6 hours on this matter. Blair Zanzig, one of HWZs members, was principally

responsible for providing these services. Mr. Zanzig is an experienced attorney with expertise in

complex civil litigation who has represented receivers in similar matters. For the services outline

above and as detailed in the attached invoices, HWZ has invoiced the Receiver for fees totaling

$42,486. For similar matters, Mr. Zanzig ordinarily bills $400 an hour, but in recognition of the

interests of consumers in this case, HWZ has agreed to discount such rate by 10%. Thus, HWZs

invoice reflects an effect rate of $360 per hour for attorney time and $150 per hour for

administrative/paralegal tasks. The Receiver believes these rates are comparable, if not less than,

those the Receiver has seen in connection with other comparable matters.

WHEREFORE, Receiver respectfully requests the Court enter an Order (a) approving

the fees and expensesincurred by the Receiver Robb Evans & Associates LLC for the First

Interim Period in the amount of $307,275.30; (b) approving the legal fees incurred by Receivers

counsel Hiltz Wantuch & Zanzig LLC for the First Interim Period in the amount of $42,486; (c)

authorize the Receiver to immediately pay all such approved fees and expenses from funds held



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by the Receiver; and (d) grant the Receiver such further relief as the Court deems just and

proper.

Dated: November 15, 2013 Respectfully submitted,

ROBB EVANS & ASSOCIATES LLC,

RECEIVER

By: /s/ Blair Zanzig(One of Its Attorneys)

Blair R. Zanzig (No. 6273293)John F. Hiltz (No.6289744)Kathy Wantuch (No. 6294034)HILTZ WANTUCH & ZANZIG LLC

53 West Jackson Blvd., Suite 205Chicago, Illinois 60604Telephone: 312.566.9008Fax: 312.566.9015

Counsel for Robb Evans & Associates, Receiver



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CERTIFICATE OF SERVICE

I, Blair R. Zanzig, an attorney, hereby certify that, on the 15thday of November, 2013, I

caused a true and correct copy of the foregoing ReceiversFirst Motion For Interim Approval of

Fees and Expenses to be served through the Courts Electronic Case Filing System on the

following:

Kimball Richard [email protected]

Thomas Lee Kirsch, [email protected]

Katherine E. [email protected]

Michael [email protected]

Jonathan [email protected]

Amanda B. [email protected]

David [email protected]

/s/ Blair R. Zanzig

mailto:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]


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EXHIBIT A

Case: 1:03-cv-03904 Document #: 790-1 Filed: 11/15/13 Page 1 of 5 PageID #:14201


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ROBB EVANS ASSOCIATES LLC

Receiver of

The Assets of Kevin Trudeau, the Trudeau Entities, et al.

Administrative Expenses and Fund BalanceFrom Inception (August 7, 2013) to September 30, 2013

Aug 31, 13 Sep 30, 13 TOTAL

Corporate Account Funds

Global Information Network 225,000.00 0.00 225,000.00

Global Info Network Foundation 0.00 262,116.42 262,116.42

I-Payout Systems Inc. 2,687.11 0.00 2,687.11

K.T. Corporation Limited 2,617.02 0.00 2,617.02

Natural Cures Health Insurance 0.00 50,304.26 50,304.26

Natural Cures Inc.

Baytree National B&T 30,618.28 0.00 30,618.28

Cardflex Payment Solutions Inc. 35,880.20 0.00 35,880.20

Meritus Payment Solutions 0.00 0.00 0.00

National Bank of California 78,134.57 0.00 78,134.57

Total Natural Cures Inc. 144,633.05 0.00 144,633.05

Tru-Com LLC 804.01 0.00 804.01

Trudeau Approved Products 101,377.04 0.00 101,377.04

Trustar Productions Inc. 1,376.72 0.00 1,376.72

Website Solutions USA 422,249.48 0.00 422,249.48

Total Corporate Account Funds 900,744.43 312,420.68 1,213,165.11

Incoming Receipts

Global Information Network

Receiver Account

Copyright Royalties 0.00 9,374.88 9,374.88

Event Commissions 0.00 2,426.25 2,426.25

Membership Dues & Upgrades-Chk 7,975.00 21,267.81 29,242.81

Membership Dues & Upgrades - CC

Credit Card Charges 663,484.95 1,270,082.49 1,933,567.44

Reserves Balance - Funds Not Available (212,272.47) (273,369.39) (485,641.86)Refunds (1,350.00) (4,750.00) (6,100.00)

Chargebacks (600.00) (2,507.81) (3,107.81)

Total Membership Dues & Upgrades - CC 449,262.48 989,455.29 1,438,717.77

Total Receiver Account 457,237.48 1,022,524.23 1,479,761.71

Non-Receiver Account

Remote Deposit 8,633.85 4,627.30 13,261.15

Total Non-Receiver Account 8,633.85 4,627.30 13,261.15

Total Global Information Network 465,871.33 1,027,151.53 1,493,022.86

Trudeau Approved Products

Receiver Account

Credit Card Sales

Credit Card Charges 0.00 5,497.88 5,497.88

Reserves Balance - Funds Not Available 0.00 (1,212.94) (1,212.94)

Chargebacks 0.00 (199.85) (199.85)

Refunds 0.00 (646.05) (646.05)

Total Credit Card Sales 0.00 3,439.04 3,439.04

Total Receiver Account 0.00 3,439.04 3,439.04

Page 1 of 4



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Receiver of




Non-Receiver Account

Bankcard MTOT Dep 6,547.61 0.00 6,547.61

SBC VSMC Deposits 5,316.42 3,751.14 9,067.56Total Non-Receiver Account 11,864.03 3,751.14 15,615.17

Total Trudeau Approved Products 11,864.03 7,190.18 19,054.21

Total Incoming Receipts 477,735.36 1,034,341.71 1,512,077.07

Interest Income 2.57 76.24 78.81

Miscellaneous Income 1,003.65 0.00 1,003.65

Total Funds Collected 1,379,486.01 1,346,838.63 2,726,324.64

Expense

Business Operation ExpensesAlarm & Security 0.00 105.00 105.00

Bank Fees 141.07 180.71 321.78

Cellular Services 0.00 0.00 0.00

Colocation Server Services 0.00 5,050.00 5,050.00

Contest Winner Vehicle Lease 7,250.00 7,250.00 14,500.00

Credit Card Discounts & Fees

Verifi 170.35 97.60 267.95

NMC 0.00 17,721.04 17,721.04

Meritus Merchant 19.95 19.95 39.90

Authnet Gateway Fees 79.00 1,527.55 1,606.55

GIN CC Discounts 33,174.25 63,504.13 96,678.38

Trudeau App Product CC Discount 518.34 1,413.08 1,931.42

Total Credit Card Discounts & Fees 33,961.89 84,283.35 118,245.24

Document Destruction Services 0.00 290.80 290.80

Electricity 1,587.89 1,482.30 3,070.19

Employer Payroll Taxes 12,188.79 9,860.16 22,048.95

Equipment Rental 0.00 520.34 520.34

Exigo Services 0.00 12,500.00 12,500.00

Event Management Fees 0.00 100,000.00 100,000.00

Gift Cards 0.00 215.35 215.35

G.I.N. Commission Payments 0.00 258,000.00 258,000.00

GIN Family Reunion Event Exp 0.00 340,239.70 340,239.70

Health Insurance & Benefits 0.00 47,337.35 47,337.35

Independent Contractor Fees 31,352.08 13,305.00 44,657.08Intercompany Payroll Allocation 7,200.00 0.00 7,200.00

Inventory Disposal/Shredding 0.00 0.00 0.00

Inventory Storage 72.68 525.00 597.68

Janitorial Services 610.00 3,475.00 4,085.00

Locksmith Services 0.00 251.90 251.90

Member/Affiliate Communications 0.00 0.00 0.00

Natural Gas 200.73 254.78 455.51

Office Rent 0.00 22,164.16 22,164.16

Office Supplies 0.00 418.44 418.44

Page 2 of 4



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Receiver of




Payroll Expenses 166,500.10 134,115.48 300,615.58

Payroll Processing Fees 452.10 411.10 863.20

Phone & Internet Services 755.28 2,776.41 3,531.69

Prior Period CC Return 300.00 150.00 450.00Promotional Expenses 5,000.00 96.80 5,096.80

Sales & Use Taxes 27.36 0.00 27.36

Security Services 960.00 0.00 960.00

Shipping & Packaging 3,715.64 5,678.51 9,394.15

Software Support Service 0.00 3,894.00 3,894.00

Transportation Services 0.00 772.59 772.59

Travel Expenses 2,130.53 2,848.02 4,978.55

Unspecified Business Expenses 0.00 0.00 0.00

Website Services 2,253.51 1,452.57 3,706.08

Total Business Operation Expenses 276,659.65 1,059,904.82 1,336,564.47

Ojai, CA Residential Property

Electricity 0.00 1,303.22 1,303.22

Landscaping Maintenance 0.00 1,121.83 1,121.83

Natural Gas 0.00 280.83 280.83

Pool Maintenance 0.00 120.00 120.00

Security & Caretaking 0.00 4,358.98 4,358.98

Water 0.00 1,299.81 1,299.81

Total Ojai, CA Residential Property 0.00 8,484.67 8,484.67

Payment to Winston & Strawn LLP 0.00 33,128.28 33,128.28

Kevin Trudeau Living Expense 4,676.00 4,676.00 9,352.00

Receiver Fees & Expenses

Receiver Fees

Receiver

R. Evans 535.50 38.25 573.75

B. Kane 17,245.80 14,502.15 31,747.95

K. Johnson 35,697.60 29,607.30 65,304.90

V. Miller 28,401.30 1,326.60 29,727.90

A. Jen 22,612.50 17,456.85 40,069.35

Total Receiver 104,492.70 62,931.15 167,423.85

Senior Staff

L. Lee 14,984.55 6,030.00 21,014.55

T. Chung 18,301.05 14,954.40 33,255.45

F. Jen 21,617.55 25,506.90 47,124.45

C. Callahan 2,992.50 3,397.50 6,390.00E. Roop 3,064.50 0.00 3,064.50

C. DeCius 801.00 7,335.00 8,136.00

N. Wolf 30.00 0.00 30.00

J. Dadbin 0.00 819.50 819.50

Total Senior Staff 61,791.15 58,043.30 119,834.45

Support Staff 545.00 1,602.10 2,147.10

Total Receiver Fees 166,828.85 122,576.55 289,405.40

Page 3 of 4



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Receiver of




Receiver Expenses

Bank Fees 0.00 0.00 0.00

Investigative Search Costs 452.00 130.82 582.82Office Telephone & Supplies 0.00 149.05 149.05

Postage & Delivery 95.26 558.54 653.80

Subpoena/Document Reproduction 22.00 109.57 131.57

Travel Expenses 16,352.68 0.00 16,352.68

Total Receiver Expenses 16,921.94 947.98 17,869.92

Legal Fees & Costs

Legal Fees 15,912.00 26,424.00 42,336.00

Legal Costs 0.00 150.00 150.00

Total Legal Fees & Costs 15,912.00 26,574.00 42,486.00

Total Receiver Fees & Expenses 199,662.79 150,098.53 349,761.32

Total Expense 480,998.44 1,256,292.30 1,737,290.74

Fund Balance 898,487.57 90,546.33 989,033.90

Page 4 of 4



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EXHIBIT C



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TO:ROBB EVANS & ASSOCIATES, LLCReceiver of the Assets of Kevin Trudeau et al.11450 Sheldon StreetSun Valley, California 9L352-L72L

HTLTZ WANTUCH & ZANZIG

SUMMARY

INVOICE NO: 1081SEPTEMBER 25,2013

PAYMENT DUE UPON RECEIPT

s17,680

-5L,768

S15,912

FEE FOR PROFESSIONAL SERVICESRENDERED PER ATTACHED DETAILLESS 10 DISCOUNT INRECOGNITION OF PUBLICINTERESTS

TOTAL CURRENT AMOUNT DUE



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GIN Network Truth (the smart group) INVOICE NO: 1081SEPTEMBER 25,2013PAYMENT DUE UPON RECEIPT

DETAIL

Date TMK Description of Services Rendered Time

8/L2/20t3 BRZ

REVIEWED DOCKET, HEARING TRANSCRIPTS AND RELATEDBACKG ROU ND DOCUM ENTS REGARDI NG TRUDEAU RECEIVERSH IP.CONFERRED WITH B. KANE REGARDING .REVIEWED MATERIALS AND FOLLOW-UP TELEPHONE CONFERENCERELATED TO SAME. RESEARCHED APPLICABLE IRS AND BANKRUPTCYSTANDARDS FOR LIVING EXPENSES. CONFERRED WITH K. WANTUCHAND J. HILTZ REGARDING SAME. REVIEWED LIVING EXPENSEBUDGET PROPOSED BY K. TRUDEAU. CONFERRED WITH B. KANEAND K. JOHNSON REGARDING SAME. REVIEWED CORRESPONDENCEFROM FTC AND K. TRUDEAU'S COUNSEL REGARDING SAME.

8.7

8/L3/2Or3 BRZ

TELEPHONE CALL WITH J. COHEN REGARDING CASE STATUS ANDRELATED MATTERS. TELEPHONE CONFERENCE WITH B. KANE AND K'JOHNSON REGARDING SAME AND GIN PROCESSING CHARGES.REVIEWED KEY PLEADING RELATING TO RECEIVERSHIP. DRAFTEDPROPOSED ORDINARY AND NECESSARY LIVING EXPENSE BUDGET.

7.8

8lt4/2OL3 BRZCONFERRED WITH K. WANTUCH REGARDING K. TRUDEAU LIVINGEXPENSE BUDGET

MET WITH B. KANE AND K. JOHNSON REGARDING K'TRUDEAU LIVING EXPENSE BUDGET. ANALYZED AND RECONCILEDBUDGETS PROPOSED BY K. TRUDEAU AND RECEIVER. RESEARCHEDAPPLICABLE STANDARDS.

5.2

8/t4/2OL3 KWREVIEWED PROPOSED LIVING EXPENSE BUDGET FOR K. TRUDEAU.CONFERRED WITH B. ZANZIG REGARDING .4

8/15l2OL3 BRZREVIEWED CORRESPONDENCE FROM FTC REGARDING L. KENNYINTERFERENCE WITH RECEIVER,S OPERATION OF GIN FOUNDATION.TELEPHONE CALL WITH J. COHEN REGARDING SAME.CORRESPONDED WITH B. KANE AND K. JOHNSON REGARDING SAME.

1.8



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GIN Network Truth (the smart group)INVOICE NO: 1081

SEPTEMBER25,2OT3PAYMENT DUE UPON RECEIPT

Date TMK Description of Services Rendered Time

8/Le/2Ot3 BRZ

REVIEWED SUBPOENA ISSUED BY FTC TO KOBRA & KIM.CORRESPONDED WITH B. KANE REGARDING MESSAGE TO GINM EM BERS/EM PLOYEES REGARDING L. KEN NY PARTICIPATION.REVIEWED CORRESPONDENCE WITH K. TRUDEAU REGARDINGLIVING EXPENSE BUDGET. ADVISED RECEIVER REGARDING SAMEAND REGARDING REQUEST TO K. TRUDEAU TO DIRECT L. KENNYCOOPERATION. TELEPHONE CALL WITH FTC REGARDING CASESTATUS AND RELATED ISSUES. DRAFTED LETTER TO K. TRUDEAUCOUNSEL REGARDING SAME.

4.t

8l2O/2013 BRZ

REVIEWED SWORN FINANCIAL STATEMENT PROVIDED BY K.TRUDEAU COUNSEL. CONFERRED WITH B. KANE REGARDING OAKPARK PREMISES AND NOTICE TO TREAT AS BUSINESS PREMISES.DRAFTED NOTICE LETTER. REVIEWED CORRESPONDENCEREGARDING OBJECTIONS BY FTC TO K. TRUDEAU LIVING EXPENSEBUDGET. ADVISED RECEIVER REGARDING SAME.

4.2

8/27/20t3 BRZ

DRAFTED LETTER TO L. KENNY REGARDING TERMINATION OFCONTINUED EMPLOYMENT AND RELATED MATTERS. CONFERREDWITH B. KANE AND K. JOHNSON REGARDING SAME. PREPARED ANDFILED APPEARANCE ON BEHALF OF RECEIVER. FINALIZED NOTICELETTER REGARDING WHITE OAK PROPERTY. TELEPHONECONFERENCE WITH J. COHEN REGARDING CASE STATUS.

6.8

8/22/2013 BRZ REVIEWED CORRESPONDENCE REGARDING L. KENNY COOPERATION.ADVISED RECEIVER REGARDING SAME. .6

8/26/2073 BRZCORRESPONDED WITH B. KANE AND K. JOHNSON REGARDINGRECEIVER,S FIRST REPORT. TELEPHONE CONFERENCE WITH J.COHEN REGARDING SAME AND RELATED ISSUES.

7.4

8/28120L3 BRZREVIEWED DRAFT PLEADINGS RELATED TO K. TRUDEAU LIVINGEXPENSES. TELEPHONE CONFERENCE WITH A. JEN REGARDING A.GORDON TAX LAWYERS. REVIEWED RELATED CORRESPONDENCE.

.8

8/2s/2Ot3 BRZ CONFERRED WITH A. JEN REGARDING DIRECTIONS TO K. TRUDEAUTAX LAWYERS. .4

8/30/2013 BRZ REVIEWED AND ANALYZED FTC MOTION TO MODIFY RECEIVERSHIPORDER. TELEPHONE CONFERENCE WITH FTC REGARDING SAME. 1.6



21/27

GIN Network Truth (the smart group) INVOICE NO: 1081SEPTEMBER 25,2013PAYMENT DUE UPON RECEIPT

Time and Fee Summary:Timekeeper Hours Rate Fee ValueBlair R. Tanzie 43.8 s400 sL7,52OKathv Wantuch .4 s400 s15o

TOTAL 44.2 s17,680



22/27


HILTZWANTUCH &ZANZIG

TO:ROBB EVANS & ASSOCIATES, LLCReceiver of the Assets of Kevin Trudeau et al.11450 Sheldon StreetSun Valley, California 9L3SZ-LL}L

INVOICE NO:1082ocToBER 7,20t3

PAYMENT DUE UPON RECEIPT

s29,360

-s2,936

Srso

526,s74

SUMMARYFEE FOR PROFESSIONAL SERVICESRENDERED PER ATTACHED DETAILLESS 10 DISCOUNT INRECOGNITION OF PUBLICINTERESTS

COSTS AND ADMINISTRATIVEEXPENSES PER ATTACHED DETAIL

TOTAT CURRENT AMOUNT DUE



23/27

GIN Network Truth (the smart group) |NVOICE NO: 1082ocToBER 7,20t3PAYMENT DUE UPON RECEIPTDETAIT

Description of Services RenderedTELEPHONE CALL WITH B. KANE AND K. JOHNSON REGARDING. TELEPHONE CONFERENCE WITH J.COHEN REGARDING VARIOUS CONCERNS OF FTC IMPLICATINGRECEIVER.

e/s/20L3RESEARCHED RECEIVER'S AUTHORITY TO ASSERT CONTROL OVER K.TRUDEAU HUSHMAIL ACCOUNT AND RELATED PROCEDURES.CORRESPONDED WITH B. KANE AND K. JOHNSON REGARDINGSAME. CORRESPONDED WITH B. KANE AND K. JOHNSONREGARDING

REVIEWED AND REVISED RECEIVER'S FIRST REPORT. CONFERREDWITH B. KANE AND K. JOHNSON REGARDING . COORDINATEDFILING OF RECEIVER'S FIRST REPORT.TELEPHONE CONFERENCE WITH A. GORDON REGARDING RETAINERRECEIVED FROM K. TRUDEAU. CORRESPONDED WITH A. JENREGARDING CORRESPONDED WITH B. KANE AND K.JOHNSON REGARDING

REVEIWED CORRESPONDENCE FROM GIN MEMBERS.

9/rtl2073CORRESPONDED WITH B. KANE AND K. JOHNSON REGARDING

DRAFTED LETTER TO GORDON LAW GROUP REGARDING RETURNOF RETAINER.

9112/2013FINALIZED LETTER TO GORDON LAW GROUP REGARDINGRETAINER. DRAFTED SUBPOENA RIDER SEEKING BANK RECORDS.CORRESPONDED WITH B. KANE AND A. JEN REGARDINGREVIEWED RECEIVER'S CORRESPONDENCE WITH K. TRUDEAUREGARDING ST. GEORGE BANK ACCOUNT.

9/L6/2013

TELEPHONE CONFERENCE WITH P. DEADY AND D. DONNELLONREGARDING PRE-RECEIVERSHIP ATTORNEY FEE CLAIMS. REVIEWEDAND REVISED RECEIVER'S SUPPLEMENTAL REPORT.CORRESPONDED WITH B. KANE AND K. JOHNSON REGARDINGCOORDINATED FILING OF SUPPLEMENTAL REPORT.DRAFTED CEASE AND DESIST LETTER REGARDING SOCIAL MEDIAPOSTS BY CERTAIN GIN MEMBERS.



24/27

GIN Network Truth (the smart group) |NVO|CE NO: 1082ocToBER 7,2013PAYMENT DUE UPON RECEIPTDate TMK Description of Services Rendered Time

e/17120L3 BRZFINALIZED CEASE AND DESIST LETTERS REGARDING SOCIAL MEDIA.CORRESPONDED WITH LESSOR OF OAK PARK PROPERWREGARDING SALE OF PERSONAL PROPERW.

.6

e/78/20L3 BRZ

PREPARED FOR HEARING ON RECEIVER'S FIRST REPORT AND FTCMOTION TO MODIFY. MET WITH K. JOHNSON REGARDINGMET WITH J. COHEN AND K. JOHNSON REGARDING HEARING.ATTENDED HEARING. COORDINATED WITH MARSHALL'S SERVICEREGARDING INTERVIEW OF K. TRUDEAU. PREPARED FORINTERVIEW OF K. TRUDEAU WITH K. JOHNSON. MET WITH J.COHEN REGARDING SAME. ATTENDED INTERVIEW AT MCC.REVIEWED APPELLATE FILING BY K. TRUDEAU.

12.7

e/19/2013 BRZ

PREPARED FOR STATUS HEARING FOLLOWING K. TRUDEAUINCARCERATION. MET WITH K. JOHNSON

METWITH J. COHEN REGARDING HEARING. CORRESPONDED WITH K.TRUDEAU AND COUNSEL REGARDING FOLLOW-UP INTERVIEW.DRAFTED LETTER TO K. TRUDEAU REGARDING OBLIGATIONS TODISCLOSE ASSETS.

5.4

s/20/2013 BRZMET WITH K. JOHNSON IN PREPARATION FOR INTERVIEW WITH K.TRUDEAU. CORRESPONDED WITH K. TRUDEAU AND COUNSELREGARDING INTERVIEW. INTERVIEWED K. TRUDEAU REGARDINGFU RTH ER ASSET DISCLOSURE.

4.8

e/23/2013 BRZREVIEWED CORRESPONDENCE FROM FTC REGARDINGRECEIVERSHIP RECOVERY OF ASSETS. TELEPHONE CONFERENCEWITH J. COHEN REGARDING SAME. CONFERRED WITH B. KANEAND K. JOHNSON REGARDING SAME.

7.4

e/24/2013 BRZDRAFTED SUBPOENA FOR BANK ACCOUNT RECORDS.CORRESPONDED WITH K. JOHNSON REGARDING K. TRUDEAUINTERVIEW AND RELATED MATTERS. FINALIZED CEASE AND DESISTLETTER TO A. HUSSEIN.

2.6

9/2s/2073 BRZPREPARED FOR INTERVIEW WITH K. TRUDEAU, INCLUDING REVIEWOF RELATED DOCUMENTS AND OUTLINE OF ISSUES. MET WITH K.JOHNSON AND J. COHEN IN PREPARATION FOR SAME. TELEPHONECONFERENCE WITH COUNSEL FOR K. TRUDEAU REGARDINGATTENDANCE OF FTC. INTERVIEWED K. TRUDEAU REGARDINGASSET DISCLOSURE.

8.7

e/2s/20L3 ADMIN FINALIZED AUGUST INVOICE FOR LEGAL SERVICES. 1.0



25/27

GIN Network Truth (the smart group) INVOICE NO: 1082OCTOBER 7,20L3PAYMENT DUE UPON RECEIPT

Description of Services Rendered

e/26/2073

PREPARED FOR STATUS HEARING, INCLUDING DRAFTING OUTLINEOF PRESENTATION TO COURT. TELEPHONE CALL WITH J. COHENREGARDING SAME. MET WITH K. JOHNSON IN PREPARATION FORHEARING, INCLUDING TELEPHONE CONFERENCE WITH B. KANEAND A. JEN REGARDING SUPPORTING DOCUMENTATION ANDDEVELOPMENTS. ATTENDED COURT HEARING. INVESTIGATEDACCESS TO MIGROS BANK ACCOUNT WITH K. JOHNSON.

9/27/2013

REVIEWED WILLIAM HILL TRANSACTION REPORT. FORWARDEDSAME TO COUNSEL FOR FTC AND K. TRUDEAU. TELEPHONE CALLWITH J. COEHN AND B. KANE REGARDING RECEIVERSHIP ISSUES,INCLUDING EFFECT OF COORDINATING REVIEW OF PREVIOUSDISCOVERY. BEGAN DRAFTING RECEIVER STATEMENT REGARDINGCOERCIVE SANCTIONS. RESEARCHED FACTUAL SUPPORT INCONNECTION WITH EVALUATION OF POSSIBLE USE OF COERCIVESANCTIONS. REVIEWED PROPOSED ORDER ON FTC'S MOTION TOMODIFY RECEIVERSHIP ORDER AND RESPONSE BY K. TRUDEAU.

s/30/2013

TELEPHONE CONFERENCE WITH J. COHEN REGARDING EFFECT OFCOERCIVE SANCTIONS ON RECEIVERSHIP ESTATE ANDIMPLICATIONS OF POSSIBLE FEDERAL GOVERNMENT SHUT-DOWNON HEARING SCHEDULE. REVIEWED AND ANALYZED FTCPLEADI NGS RECOMM ENDING I M POSITION OF COERCIVESANCTIONS. CONFERRED WITH B. KANE AND K. JOHNSONREGARDING SAME. REVIEWED AND ANALYZED EARLIER HEARINGTRANSCRIPT IMPOSING RECEIVERSHIP AND RELATED PLEADINGS INCONNECTION WITH PREPARATION OF RECEIVER'S STATEMENTREGARDING COERCIVE SANCTIONS.

Time and Fee Summary:Timekeeper Hours Rate Fee ValueBlair R. Tanzig 73.4 S+oo s29,360Admin 1.0 s1s0 Slso



26/27


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

NOTICE OF MOTION

PLEASE TAKE NOTICE that, on Thursday, November 21, 2013, at 1:30 p.m., or as

soon thereafter as counsel may be heard, the undersigned shall appear before the Honorable

Robert W. Gettleman, United States District Court for the Northern District of Illinois, EasternDivision, or such other judge as may be sitting in his place in Courtroom 1703, 219 S. Dearborn

Street, Chicago, Illinois 60604, and shall present the Receivers First Motion for Interim

Approval of Fees and Expenses, a copy of which is hereby served upon you.

Dated: November 15, 2013 Respectfully Submitted,

ROBB EVANS & ASSOCIATES LLC,

RECEIVER

By: /s/ Blair Zanzig

(One of Its Attorneys)

Blair R. Zanzig (No. 6273293)

John F. Hiltz (No.6289744)Kathy Wantuch (No. 6294034)

HILTZ WANTUCH & ZANZIG LLC

53 West Jackson Blvd., Suite 205

Chicago, Illinois 60604Telephone: 312.566.9008

Fax: 312.566.9015

Counsel for Robb Evans & Associates, Receiver



27/27


CERTIFICATE OF SERVICE

I, Blair R. Zanzig, an attorney, hereby certify that, on the 15th day of November, 2013, Icaused a true and correct copy of the foregoing Notice of Motion to be served via the CourtsElectronic Case Filing System on the following:

Kimball Richard [email protected]

Thomas Lee Kirsch, [email protected]

Katherine E. Rohlf

[email protected]

Michael Mora

[email protected]

Jonathan Cohen

[email protected]

Amanda B. Kostner

[email protected]

David OToole

[email protected]

/s/ Blair R. Zanzig

mailto:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]