united states district court for the northern … · 2018. 9. 3. · kevin trudeau, defendant. ) )...

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

RECEIVER’S 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. Trudeau’s complete compliance with the Court’s 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. Trudeau’s various

surrogates, Mr. Trudeau’s 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. As detailed below, Mr. Trudeau has not made a full

disclosure by any measure.

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

2

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. Trudeau’s counsel to the October 25, 2013 letter [Dkt. #786] also appears on the docket as entry no. 787.


3

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. Trudeau’s 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

2 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.


4

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. Trudeau’s

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 Receiver’s 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 Receiver’s 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. Trudeau’s legal fees, corresponding to approximately a third of

FTC income belying any suggestion that the FTC is an independent entity beyond Mr. Trudeau’s


5

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 Receiver’s 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 Trudeau’s counsel’s October 28, 2013 correspondence with the Receiver. (See Dkt. #787.)


6

entity to wire the remaining funds in the account to the Receiver’s 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. Trudeau’s

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

Court’s prior orders by failing to turnover the funds held in an account at Migros Bank in

Switzerland. (See Receiver’s 3d Supp. Rpt. [Dkt. #796].) Instead, on August 23, 2013 – nearly a

month after the Court froze Mr. Trudeau’s 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. Trudeau’s 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. Trudeau’s 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. Trudeau’s counsel had made a


7

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 Court’s 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 Court’s 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.

Trudeau’s 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 Trudeau’s 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.


8

The Receiver’s Ongoing Investigation

As reported at the last hearing, the Receiver has discovered a previously unknown

account held in Natalia Babenko’s 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. Trudeau’s 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


9

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

4 Courts have recognized that incarceration for civil contempt may continue indefinitely––until 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.


EXHIBIT A

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

1

Blair Zanzig

From: brick kane <Sent: Thursday, October 17, 2013 11:15 AMTo: 'Kevin Trudeau'; 'Kenton Johnson'Cc: 'Thomas L. Kirsch'; Blair ZanzigSubject: 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


1

Blair Zanzig

From: brick kane < >Sent: Thursday, October 17, 2013 12:33 PMTo: 'Kevin Trudeau'; 'Kenton Johnson'Cc: 'Thomas L. Kirsch'; Blair ZanzigSubject: RE: Attachments: 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


HILTZ WANTUCH & ZANZIG

Sender's Direct: Sender's Email:

October 23,2Ot3

VIA EMAIT

Kimball R. AndersonWinston & Strawn LLP

35 West Wacker Drive

Chicago, lL 60601-9703

Re: FTC v. Kevin Trudeau, No. 03-C-3904 (N.D. lll.)

Dear Kimball,

I write in response to your October 22,2OI3letter to Brick Kane and Kenton Johnson of the Receiver's

office.

First, the Court - not the Receiver - has established the conditions Mr. Trudeau needs to satisfy in orderto purge his contempt. The Receiver is not empowered to provide a list, as you put it, of "additionalinformation needed from Mr. Trudeau so that he can purge his contempt finding." Mr. Trudeau may atany 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 forensicaccounting 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 theissues 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 withoutlimitation: "all books and records of Assets including funds and property, all financial and

accounting records, balance sheets, income statements, bank records (including monthlystatements, canceled checks, records of wire transfers, records of ACH transactions, and check

registries), corporate minutes, contracts, customer and consumer lists, title documents, and

Case: 1:03-cv-03904 Document #: 783-1 Filed: 10/24/13 Page 4 of 7 PageID #:14004Case: 1:03-cv-03904 Document #: 805-2 Filed: 12/17/13 Page 2 of 10 PageID #:14406

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 towhich 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 fortransfers made in connection with the Kiev apartment described in the FTC's and

Receiver's pleadings regarding the imposition of coercive sanctions and theaccompanying exhibits. Mr. Trudeau should turnover such apartment to the Receiver,

or otherwise provide verifiable evidence establishing his inability to do so.

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 wiretransfer 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-shoreTrudeau Entities, including identifying any business or other activities such entities conductedand any assets owned by such entities. To the extent that such entities were formed as part ofan "asset protection strategy," identify the assets such strategy was designed to protect.

ldentify and provide all evidence relating to such description, including all communicationsrelating to these entities, the identity of all persons with knowledge of such entities and theiractivities, all information necessary for the Receiver to assume control of these entities. ln thecourse of providing such explanation, Mr. Trudeau should account for the following:

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 forCoercive Sanctions [Dkt. # 759] (the "FTC's Statement").

The circumstances surrounding the Power of Attorney prepared by Marc Lane relatingto NTTrading S.A., as evidenced by exhibits PXA:9 and PXA:1-0 attached to the FTC's

Statement IDkt. #759].

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 Coercivelncarceration), 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 thepurchase, 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

b.

a.

b.

c



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. AndersonWinston & Strawn LLp

35 West Wacker DriveChicago, 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. Trudeaucould 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 thosecommands. Otherwise, a contemnor could always escape incarceration by claiming that confinementitself prevents him from personally purging his contempt. Here, unlike other contemnors who havebeen held in contempt over their claims that they had no ability to control persons overseas,l Mr.Trudeau (and his counsel) have told the Court that they do not dispute that Mr. Trudeau possessescontrol over the Trudeau Entities. Mr. Trudeau and his counsel have also represented to the Court thatMr. 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 necessaryinstructions.

Further, the Receiver understands that under Bureau of Prison policy as reflected in the MCC ChicagoInmate Admission and Orientation Handbook,

k.pdf, Mr. Trudeau has access totelephones and mail. Although Mr. Trudeau has yet to request any, the Receiver would support, andbelieves 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 whileincarcerated - all of which address issues raised during the first two months of the Receivership,including most recently in my October 23, 2Ot3letter to you:

t See, e.g., FTC v. Affordable Media, LLC, t7g F.3d 7228, L243-44 (9th Cir. 1999) (affirming contemptfinding over defendants' objections that they did not control overseas trust and refusing to legitimizedefendants' asset protection scheme that was working precisely as the defendants, had intended).


Kimball Anderson, page 2

October 25,2073

7' First and foremost, as the Court has rejected Mr. Trudeau's claimed inability to pay thejudgment against him, Mr. Trudeau should pay the judgment. Mr. Trudeau uniquely possessesthe knowledge of what assets are available to pay the judgment and how they can be turnedover' From his cell, he should use such knowledge to cause the judgment to be paid by usingthe same methods to make such payments that are available to any other contemnor who iscoercively incarcerated for failing to turnover their assets. At a minimum, Mr. Trudeau shouldtake the following steps towards paying the judgment:

a' Mr. Trudeau should cause the turnover of the Kiev apartment purchased with fundsfrom the Trudeau Entities.

b. Mr. Trudeau should cause the turnover of the 515,345.02 transferred to his wife,sGlobal Bank of Commerce account in Antigua after the Court's asset freeze was put intoplace as well as any other funds transferred to his wife by Mr. Trudeau, the TrudeauEntities or any of their surrogates.

c' Mr' Trudeau should cause the turnover of all gold bars, precious metals, coins, andjewelry (including cuff links)that he and/or his wife purchased using monies derivedfrom the Trudeau Entities, or turnover the proceeds from the sale of such assets.

d. Mr. Trudeau should cause the turnover of the approximate Stso,ooo that Mr. Trudeausays exists in accounts owned by Website Solutions Switzerland and Global SalesSolutions, 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 thejudgment, Mr. Trudeau should also do the following:

2. Mr. Trudeau can cause the documents identified in Brick Kane's October !7,2oL3,12:33 pMemail to Mr. Trudeau to be turned over to the Receiver. For your convenience, I have quotedthose items here:

"Website Solutions Switzerland: Provide a complete accountinB with bank statementsand backup copies of deposits, wire transfers, and checks (front and back) from theinception of the account to date.

"Futures Transactions: Provide a complete accounting with bank statements andbackup copies of deposits, wire transfers, and checks (front and back) from theinception of the account to date.

"office Pool: Provide a list of payments from this company for the benefit of KevinTrudeau or persons 'acting in concert' as defined in [the] August 7,2Ot3 Order. providea list of receipts that the company received as [a] result of Keven Trudeau. provideinvoices from Office Pool for services provided and payments received for the serviceprovided for the benefit of Kevin Trudeau or person 'acting in concert' as defined inAugust 7 ,20L3 Order[.]



October 25,2OL3

"Global Sales Solutions AG: Provide a complete accounting with bank statements andbackup copies of deposits, wire transfers, and checks (front and back) from theinception of the account to date.,,

Mr. Trudeau can cause the production of complete accounting records for GIN-FDN, includingwithout limitation balance sheet, income statements and general ledger.

Mr. Trudeau can provide copies of all of his personal bank statements and copies of checks from2004to 2007.

While the Receiver rejects the premise that Mr. Trudeau can only be required to complete tasks that hehimself can personally physically perform from prison - an interpretation that would dramatically limitthe effectiveness of coercive incarceration - the Receiver identifies the following disclosures Mr.Trudeau should make:

Mr. Trudeau can provide a written statement describing the relationship between GIN-FDN,Website Solutions Switzerland ("WSS"), Office Pool, Future Transactions Company, and GlobalSales Solutions ("GSS") and his relationship with such entities. In the course of providing suchinformation and without limitation, Mr. Trudeau should fully explain the following:

a. The transfers of Mr. Trudeau's GIN commissions from GIN-FDN to Office pool totaling5644,727 .70 from January I,2OI3 through September 6,2013.

b. The circumstances surrounding the royalty agreement between Mr. Trudeau and FutureTransactions Company referenced in the December 10, 2012 email from Mr. Trudeau toNeal Sant and Jeff Devine, a copy of which was attached as PXA:9 to the FTC's StatementConcerning Defendant's Letters of Direction lDkt. #774).

c' The purported payment of legal fees on behalf of Mr. Trudeau totaling 251,,569 BritishPounds (or $402,919.88 based on today's exchange rate), which is approximately a thirdof that company's revenue as reported by Lee Kenny in his Octob er 23,2013 email toKatherine Rohlf, especially given that Mr. Trudeau has asserted that Future TransactionsCompany is a legitimate business independently owned by Lee Kenny. Mr. Trudeaushould explain what transfers he, the Trudeau Entities, or other persons/entities actingon his behalf have made to Future Transactions Company.

Mr. Trudeau should provide a written statement describing the circumstances and purposessurrounding the formation of each of the off-shore Trudeau Entities, including identifying anybusiness or other activities such entities conducted and any assets owned by such entities. Tothe extent that such entities were formed as part of an "asset protection strategy," Mr. Trudeaushould describe the assets such strategy was designed to protect. Given Mr. Trudeau's priorsuggestions 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 TradingS.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 forCoercive Sanctions [Dkt. # 759] (the "FTC's Statement,,).

3.

4.

5.

6.


Kimball Anderson, page 4October 25,20t3

The circumstances surrounding the Power of Attorney prepared by Marc Lane relatingto NT Trading s.A., as evidenced by exhibits pXA:9 and pXA:10 attached to the FTC,sStatement IDkt. #759].

The circumstance surrounding the "ari dear" (presumably a reference to Ariwasserman), referred to in the November 2s,2ol2 email from Mr. Trudeau to Nealsant (attached as exhibit PXA:15 to the FTC's Reply in support of coerciveIncarceration), including the terms of such deal and the reasons that such deal ',shouldbe with "nbt trading limited" rather than in Mr. Trudeau's personal name as Mr.Trudeau indicated in the referenced email.

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 onMr. Trudeau's behalf. Such description should include, without limitation, the circumstancesand reasons for the purchase, the parties to the purchase, the items purchased, the terms of thesale (e.g' quantity and price), the specific source of funds used to purchase such items, and thepresent disposition of such items. lf such items have since been sold, Mr. Trudeau shouldprovide the details of such sale and account for the proceeds from such sale. In the course ofproviding this information, Mr. Trudeau should specifically address the additional gold describedin the records cited in the FTC's Statement [Dkt. # 759] at 7 under the heading "More Gold,, andaccompanying footnotes.

Mr. Trudeau should provide a written statement explaining what documents or sources ofinformation Mr. Trudeau consulted in order to provide the Receiver the login informationassociated with the St. George Bank account.

While the Receiver has compiled this list in good faith, the Receiver stresses that it is not, nor could be,exhaustive. InlightofthesubstantialevidencethatMr.Trudeauhaslongplanned(andpaidsubstantialsums 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 theReceiver. The items reflected above together with the issues set forth in the briefing before the Courtand the Receiver's earlier correspondence reflects the Receive/s view of areas where Mr. Trudeau hasnot fully disclosed everything within his power. However, as the FTC acknowledged in its StatementConcerning Defendant's Letters of Direction, with which the Receiver fully agrees, if the Courtnevertheless "concludes that Mr. Trudeau has honestly disclosed everything he knows concerning hisassets, and thus can do nothing further, then Mr. Trudeau should be released." [Dkt. #774 at7.l

As the Receiver has steadfastly maintained throughout, the next step forward is for the Receiver tocontinue to pursue the forensic accounting - a process that will likely take months to complete. TheReceiver does not believe that systematically reviewing accounting records with Mr. Trudeau is aproductive use of Receivership funds, especially in light of Mr. Trudeau's continued insistence (albeitcontrary to the Court's findings) that he was not involved in, and lacks independent knowledge of, hispersonal finances and the financial activity of the Trudeau Entities. The Receiver is well-qualified tofollow the accounting trail wherever it may lead.

b.

7.

8.


Kimball Anderson, page 5October 25,2OL3

Please do not hesitate to contact me if you have any {

Very truly yours,

uestions regarding the foregoing.

Cc: BrickKane(Kenton Johnson ( )


EXHIBIT C


1

Blair Zanzig

From: Rohlf, Katherine E. < >Sent: Saturday, October 26, 2013 2:26 PMTo: brick kane ( ); 'Kenton Johnson'

( ); Blair ZanzigCc: Anderson, Kimball R.; Kirsch, Thomas L.; Sullivan, Andrew C.; kevinSubject: FW: FTC v. Trudeau - Request for InformationAttachments: 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


2

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 Associate Winston & Strawn LLP 35 W. Wacker Drive Chicago, IL 60601-9703


From: Lee Kenny [ ] Sent: Thursday, October 24, 2013 8:37 AM To: Rohlf, Katherine E.


3

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 don’t want to jeopardise relationships. This is something again I’ve 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 you’ve 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 Associate Winston & Strawn LLP 35 W. Wacker Drive Chicago, IL 60601-9703


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


4

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 Kevin’s in order to contribute to the past judgement or at the very least confirm that they believe no money is being concealed. Whilst Kevin doesn’t 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.


5


6

I hope the above helps Kevin’s case. He’s a good guy at heart and has positively impacted millions of people over the years. I’d like to see him free to do the same again soon. Best regards Lee Kenny


7

From: Rohlf, Katherine E. [mailto: ] Sent: 22 October 2013 22:41 To: Lee Kenny Cc: Anderson, Kimball R.; Kirsch, Thomas L.; Sullivan, Andrew C.; kevinSubject: 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 Receiver’s 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 Associate Winston & Strawn LLP 35 W. Wacker Drive Chicago, IL 60601-9703


The contents of this message may be privileged and confidential. Therefore, if this message has been received


8

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


1

Blair Zanzig

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.


2

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;


3

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@ ; Thomas L. Kirsch Subject: 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.


4

-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


1

Blair Zanzig

From: Blair ZanzigSent: Wednesday, December 4, 2013 4:40 PMTo: 'Kirsch, Thomas L.'; kenton.johnson@ ; brick kane

(brick_kane@ )Cc: Anderson, Kimball R.; Rohlf, Katherine E.Subject: 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. Trudeau’s 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. Trudeau’s 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 tomorrow’s hearing, can you please let me know what your position will be regarding continued incarceration?


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


1

Blair Zanzig

From: Rohlf, Katherine E. < >Sent: Wednesday, December 4, 2013 6:08 PMTo: barbara.schoop@Cc: brick kane (brick_kane@ ); 'Kenton Johnson'

(kenton.johnson@ ); Blair Zanzig; Anderson, Kimball R.; Kirsch, Thomas L.; Sullivan, Andrew C.

Subject: Urgent - FTC v. Trudeau - Request for InformationAttachments: Barbara Schoop.pdf

Importance: High

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 can’t 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.


2

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.


1

Blair Zanzig

From: Rohlf, Katherine E. < >Sent: Wednesday, December 4, 2013 6:18 PMTo: lee@Cc: brick kane (brick_kane@ ); 'Kenton Johnson'

(kenton.johnson@ ); Blair Zanzig; Anderson, Kimball R.; Kirsch, Thomas L.; Sullivan, Andrew C.

Subject: Urgent - FTC v. Trudeau - Additional Information RequestedAttachments: Lee Kenny.pdf

Importance: High

Dear Lee, As you know, I am counsel for Kevin Trudeau. I want to sincerely thank you for the assistance you’ve 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 Associate Winston & Strawn LLP 35 W. Wacker Drive Chicago, IL 60601-9703




1

Blair Zanzig

From: Lee Kenny < >Sent: Thursday, December 5, 2013 1:34 AMTo: Rohlf, Katherine E.Cc: brick kane ( ); 'Kenton Johnson'

(kenton.johnson@ ); Blair Zanzig; Anderson, Kimball R.; Kirsch, Thomas L.; Sullivan, Andrew C.; Barbara Schoop (barbara.schoop@ )

Subject: RE: Urgent - FTC v. Trudeau - Additional Information Requested

Hi I believe we’ve 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,


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As you know, I am counsel for Kevin Trudeau. I want to sincerely thank you for the assistance you’ve 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 Associate Winston & Strawn LLP 35 W. Wacker Drive Chicago, IL 60601-9703




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Rohlf, Katherine E.

From: Lee Kenny Sent: Sunday, October 27, 2013 4:39 PMTo: Rohlf, Katherine E.Cc: Anderson, Kimball R.; Kirsch, Thomas L.; Sullivan, Andrew C.;

'Brick Kane Website Solt Receiver'; kenton_johnson bzanzig

Subject: RE: FTC v. Trudeau - Requests from Receiver

See below in CAPS Lee

From: Rohlf, Katherine E. Sent: 26 October 2013 23:32 To: Lee Kenny Cc: Anderson, Kimball R.; Kirsch, Thomas L.; Sullivan, Andrew C.; bzanzig@ brick kane (brick_kane@ 'Kenton Johnson' (kenton.johnson Subject: FTC v. Trudeau ‐ Requests from Receiver Dear Lee,

Based on a recent letter from the Receiver (yesterday afternoon), I believe this is the additional information that we need from you:

(1) Complete accounting records for GIN‐FDN, including without limitation balance sheet, income statements and general ledger.

a. If you believe you have already provided this information to the Receiver, please indicate so via email (the Receiver is copied here). ALL BANK STATEMENTS, SAGE ACCOUNTING BACK UPS AND MONEY WAS SENT FROM GIN TO RECEIVER IN SEPTEMBER

(2) Documents regarding Future Transactions. I understand that your team is already working on compiling this information, and you plan to send that information along on Monday. CORRECT

(3) A written statement describing the relationship between GIN‐FDN, WSS, Office Pool, Future Transactions and GSS, including Mr. Trudeau’s relationship with such entities (if any). In relation to this request, we would like specific information and a description of the circumstances regarding the following (paragraphs (a), (b) and (c) below were copied and pasted directly from the letter from the Receiver): PRESUMABLY KEVIN CAN PROVIDE THIS FROM HIS PERSPECTIVE

a. The transfers of Mr. Trudeau's GIN commissions from GIN‐FDN to Office pool totaling $644,727.70 from January 1, 2013 through September 6, 2013. THESE WERE WSS/GSS’S COMMISSIONS IN RETURN FOR WRITING SUCCESS MASTERY COURSE LEVELS 1‐12. THEY WERE CALCULATED FROM THOSE MEMBERS WHO JOINED GIN USING A SPECIFIC AFFILIATE CODE.

b. 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


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(Dkt. #774). [Lee, I have attached this document to this email for your reference/context] I UNDERSTAND KEVIN WAS UNHAPPY WITH HOW HIS SPEAKING FEES AND/OR ROYALTIES HAD BEEN HANDLED IN THE PAST. FUTURE TRANS AGREED TO TAKE THIS OVER IN RETURN FOR PROVIDING KEVIN AGREEING TO BE EMPLOYMED BY ONE OF MY COMPANIES IN ZURICH

c. 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 of that company's revenue as reported by Lee Kenny in his October 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. THIS IS DIRECTED TO KEVIN, BUT WHEN I COMBINE THE COSTS OF EMPLOYING KEVIN VERSUS THE INCOME HE WAS ABLE TO ASSIST IN GENERATING ACROSS ALL MY BUSINESSES, I WAS HAPPY TO DONATE TOWARDS HIS LEGAL FEES TO ASSIST HIM GET A RESOLUTION SO HE COULD FOCUS MORE ON DOING MORE SEMINARS AND BOOKS ETC. SOME PEOPLE DONATE TO POLITICAL PARTIES, FOR ME I WANTED TO HELP KEVIN WITH HIS CURRENT CHALLENGES.

As always, we appreciate your assistance with all of this. Let me know if you have any questions. We encourage

you to correspond directly with the Receiver about these matters (copying us on all correspondence). Regards, Katherine

Katherine E. Rohlf Associate Winston & Strawn LLP 35 W. Wacker Drive Chicago, IL 60601-9703




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Rohlf, Katherine E.

From: Rohlf, Katherine E.Sent: Saturday, October 26, 2013 5:37 PMTo: brick kane ( ); 'Kenton Johnson'

( ); bzanzigCc: Anderson, Kimball R.; Kirsch, Thomas L.; Sullivan, Andrew C.; Subject: FW: FTC v. Trudeau - Request for Information

Dear Brick, Please find below information we received from Michel Van Roon regarding the offshore entities. As we have noted before, we highly encourage you to contact Mr. Van Roon directly, as he is the keeper of the information you are seeking with regard to these entities. Mr. Van Roon has indicated and demonstrated his willingness to cooperate. Regards, Katherine

Katherine E. Rohlf Associate Winston & Strawn LLP 35 W. Wacker Drive Chicago, IL 60601-9703


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 Hi Katherine, Below please find the list of the entities where we have assisted Ms. Nataliia Babenko on with the setup. This is the same overview as we have sent to Mr. Trudeau earlier this week. APC TRADING LIMITED: Belize company, date of incorporation 02/07/2008 Director: Nataliia Babenko Shareholder: Nataliia Babenko Secretary: Berkley Secretaries Inc. Remark: ‐ all correspondence and invoicing related to the company was transferred to the company’s registered agent in HK (CMS Limited) in 2010 at request of Nataliia.

‐ according to our best of knowledge no bank account was ever setup for this company


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NBT TRADING LTD: Hong Kong company, date of incorporation 08/07/2008 Director: APC Trading Ltd Shareholder: APC Trading Limited Secretary: Bercley Secretaries Ltd Remark: ‐ all correspondence and invoicing related to the company was transferred to the company’s registered agent in HK (CMS Limited) in 2010 at request of Nataliia.

‐ according to our files the company opened a bank account with Valartis Bank in Liechtenstein in March 2009. Account signature: Nataliia Babenko

NT TRADING SA: Panama company, date of incorporation 02/07/2008 Directors: Vernon Emmanuel Salazar Zurita, Lilia Judith Tovar De Leon, Delio Jose De Leon Mela Secretary: Lilia Judith Tovar De Leon Status: Dormant / Abandoned Remark: ‐ company was abandoned at request of Nataliia Babenko in July 2010

‐ company to our best of knowledge never opened a bank account ‐ Mr. Kevin Trudeau held a POA to act on behalf of the company but we have no indication this POA

has ever been used (nor do we have any way of verifying this) SOVEREIGN TRUST: Cook Island Trust, date of establishment 26/05/2009 Settlor: Nataliia Babenko Beneficiary: APC Trading SA (but this may have been changed, would need to verify with trustee) Trustee: Asiacity Cook Islands Protector: Codrington Remark: ‐ to our best of knowledge the trustee never setup a bank account for the trust , but we’d need to verify with the trustee if you want

‐ for any assets held by the trust we would need to liaise with the trustee Here except for NBT Trading Limited ( a HK company) we are not aware of any of these structures having any assets. As we are not the director and/or shareholder or these companies we however are not in a position to make any formal declaration to this effect. As the companies are effectively managed by the directors, accounts could have been opened without anybody ever having involved us. This especially as the administration of NBT and APC were transferred to the registered agent in HK in mid 2010 which means that we have no recent visibility on these entities As a result we / you would probably need to liaise with the directors or the various entities (or the trustee in case of the trust) to obtain suchdeclaration. For the Panama company NT Trading SA, a company for which also a power of attorney was issued to Mr. Trudeau, I believe it would be unlikely that the company has any assets. This as this company was abandoned at request of the client in July 2010 and together with this the company’s bearer share certificates have been returned to the company’s registered agent. This makes that the company is not in good –standing. From our end we would be more than happy to assist you, Mr. Trudeau and/or the Receiver with collection of these documents and to assist in obtaining the respective declarations but not sure how this would work fee / cost wise. Already over the last days / week we have spent considerable time in pulling together different documents and corresponding with various counterparties and normally we would expect for such time to be compensated. Here our


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standard procedure is to work based on a retainer where we keep track of the time spent which is then offset against such a retainer against a pre agreed hourly rate. But not sure how this works in cases like this. Last but not least, as was raised in earlier correspondence with Mr. Trudeau and I believe also the Receiver:

‐ for NBT Trading (the HK company) we have found indication that the company would still have a company bank account with a balance of around USD 30’000,=.

‐ we have information which would suggest that Ms. Babenko had a personal account with a bank in the Carribean. We are not sure this is part of the scope of your enquiry but wanted to make sure you were aware. Here to date however we have no indication as to what the status of such account is.

Here please let us know how you would like us to proceed. Kind Regards, Michel


EXHIBIT I


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Blair Zanzig

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" <[email protected]> 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 Court’s order. Please immediately return these funds to the receiver. Our wire instructions are:

FIRST REPUBLIC BANK


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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


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Blair Zanzig

From: Lee Kenny < > Date: December 2, 2013 at 11:10:32 PM PST To: "Rohlf, Katherine E." < > Cc: 'Brick Kane Website Solt Receiver' < >, "Kirsch, Thomas L."

>, "KAnderson@ " < > Subject: Request of Future Transaction Co from receiver

Dear Katherine 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 Kevin’s 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 Kevin’s 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 we’ll be happy to do that and reimburse them at that point. Brick has been cc’d 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


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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 we’ll be happy to assist. Best regards Lee


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