trudeau civil case document 865 0 and exhibits receivers third motion for interim approval of fees...

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 THIRD 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

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

professionals retained by the Receiver, including legal fees. In this application, the Receiver

seeks approval of fees and expenses incurred during the period from January 1, 2014 through

May 31, 2014 (the Third 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 and

Implementing 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 #: 865 Filed: 07/07/14 Page 1 of 13 PageID #:15740

GIN Network Truth (the smart group)2

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 and

other professionals that 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. The Receiver has also obtained specialized

counsel as appropriate and necessary to advise it regarding specific issues that have arisen.

3. Pursuant to the terms of the Receivership Order, the Receiver and its

professionals 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).)

4. On November 21, 2013, the Court granted the Receivers First Motion for

Approval of Fees and Expenses covering the period from August 7, 2013, through September 30,

2013, approving the Receivers professional fees of $289,405.40, out-of-pocket expenses of

$17,869.92 and HWZs legal fees of $42,486.

5. On March 19, 2014, the Court granted the Receivers Second Motion for

Approval of Fees and Expenses covering the period from October 1, 2013, through December

31, 2013, approving the Receivers professional fees of $246,315.50, out-of-pocket expenses of

$15,030.12, and legal fees and expenses of $76,770.16, which includes $9,419.99 to

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

Receivership Order.



Liechtenstein and Australian law firms who assisted the Receiver with its investigation of

overseas accounts.

6. In this Motion, for the Third Interim Period, the Receiver seeks approval of its

professional fees totaling $239,651.95 and out-of-pocket expenses of $50,455.79. In addition,

the Receiver seeks approval of legal fees and expenses totaling $117,628,27, consisting of fees

and expenses of $98,620.45 to HWZ; $18,265.32 to McKenna Long & Aldrigde LLP who

provided additional assistance to the Receiver in connection with the sale of the GIN Assets; and

$742.50 to Meridian Lawyers the Australian law firm that assisted the Receiver with certain

overseas accounts.

7. As reflected in the financial report accompanying the Receivers most recent

report filed on concurrently with this Motion and reattached here as Exhibit A, during the Third

Interim Period, the Receiver collected net funds totaling $3,059,696.32 before Receivers fees

and expenses, including legal fees.

8. Accordingly, the Receiver has more than sufficient funds to pay the professional

fees 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 sought here, as of May 31, 2014, the receivership

estate has a net balance of approximately $5.2 million, excluding an additional $1.1 million in

credit card reserve accounts.

OVERVIEW OF RECEIVERS ACTIVITIES AND FEES

9. During the Third Interim Period, the Receiver continued its management of

Trudeau Entities, including the Global Information Network (GIN), conducted a sale process



to liquidate the GIN Club assets, real property located in Ojai, California, and certain personal

property belonging to Trudeau and certain of the Trudeau Entities.

10. The Receiver has maintained detailed records of the billable time it has devoted to

this matter and for which it is now seeking authority to pay. Attached as Exhibits B, C, D, E,

and F to this application are comprehensive invoices for January 2014, February 2014, March

2014, April 2014, and May 2014, 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. The Receiver also prepared and submitted status reports on January 28, 2014 [Dkt.

# 815] and March 17, 2014 [Dkt. # 841], and motions seeking the sale of certain real and

personal property on February 18, 2014 [Dkt. #824] and April 28, 2014 [Dkt. #852] further

detailing its activities and investigation during the Third Interim Period. As reflected in more

detail in its invoices and reports to the Court, the Receiver provides the following overview of its

activities during the Second Interim Period:

11. The Receiver has continued to manage the Trudeau Entities, including the Global

Information Network (GIN). As part of those duties, the Receiver oversees and coordinates

with GINs management and employees regarding various routine operational issues, including

accounting functions. During early 2014, the Receiver completed its work with GINs

management to restructure GINs membership and marketing program, including the

implementation of a new Members Reward Program and GIN Leadership Counsel. The

Receiver also addressed and resolved various claims asserted against the Trudeau Entities,

including a lawsuit by a former vendor over a pre-receivership debt as well as employee wage

claims. The Receiver also has reviewed claims and communicated with various current and

former GIN members regarding pre-receivership incentive programs offered by GIN.



12. During the Third Interim Period, the Receiver monitored and attempted to

ameliorate the negative impact to GIN Club operations of communications by the lead proposed

intervenor to GIN Club members regarding his efforts to establish a competing club and

misinformation regarding the Receivers management of the GIN Club. In January 2014, the

Receiver prepared and filed a sur-reply opposing the motion to intervene to address new

allegations regarding the Receivers management of the GIN Club raised by the proposed

intervenors in their reply.

13. During the Third Interim Period, the Receiver conducted a sale process to seek a

buyer for the assets of the GIN Club. As part of such process, the Receiver communicated with

potential purchasers, including monitoring and addressing communications to GIN Members by

various third parties competing to take over GIN Club or to establish competing clubs. Once a

buyer was identified, the Receiver proceeded to negotiate an asset purchase agreement structured

to minimize future liability to the receivership estate while obtaining material value for largely

intangible assets. As part of the due diligence phase, the Receiver also conducted an

investigation into the status of various copyrights and trademarks registered to the Trudeau

Entities. Finally, the Receiver worked with counsel to obtain Court approval for such sale,

including establishing notice procedures and, in turn, providing notice of the sale to thousands of

GIN members, vendors and other known creditors of GIN.

14. Further, in connection with the sale of the GIN Clubs assets, the Receiver also

worked with its counsel to reject the office lease for GINs offices located in Westmont, Illinois.

15. The Receiver also completed the sale of certain real property located in Ojai,

California that previously served as Trudeaus California residence (though owned by one of the

Trudeau Entities). In addition to the usual negotiations with the buyer, the Receiver also had to



address a number of additional issues arising from the unique circumstances of this case to

successfully close the sale. The Receiver investigated and resolved issues related to a purported

lien arising from a previous line of credit to Trudeau or one of the Trudeau Entities that clouded

title of the Ojai real property. Although the Receiver resolved the lien issue favorably, doing so

required additional work by the Receiver and its counsel because the purported lien holder had

become insolvent and the nominal lienholders assets (including any lien on the Ojai real

property) had been transferred en mass to its warehouse lender, without any corresponding

recording filed with the appropriate recorders office. Further, the title company underwriting

the sale raised a number of issues requiring response and negotiation by the Receiver regarding

the sale of the property, including concerns regarding the jurisdiction of the court to compel the

sale.

16. During the Third Interim Period, the Receiver also sought and obtained Court

approval to sell certain personal property located at the Ojai real property and in Trudeaus

former residence in Oak Brook, Illinois. The Receiver worked with its auctioneer to conduct the

sale of personal property in Ojai, which resulted in over $70,000 of net proceeds to the

receivership estate. In connection with such sale, the Receiver also negotiated and resolved

personal exemption claims by Trudeau.

17. The Receiver reviewed claims of the owner of the Oak Brook residential property

previously rented to Kevin Trudeau through one of the Trudeau Entities and coordinated through

counsel to address such claims.

18. The Receiver continued investigating various overseas accounts held by Trudeau

or the Trudeau entities, including working with Trudeaus counsel to compel the turnover funds



in such accounts. As a result, during the Third Interim Period, funds totaling $86,838.69 were

recovered by the receivership from the William Hill account and Migros Bank.

19. The Receiver reviewed and analyzed banking records from the various institutions

holding past or present accounts for Trudeau or the Trudeau Entities. The Receiver coordinated

with its counsel to issue subpoenas for additional bank records of third parties. As a result of

these efforts among other things, during the Third Interim Period, the Receiver recovered

$21,181.24 from accounts held at Banco Popular, Pershing LLC, and Northern Trust. In

addition, in January 2014, the Receiver also recovered the $22,000 previously paid to Mr.

Trudeaus tax attorneys in violation of the Courts order.

20. The Receiver also continued to attempt to coordinate with Mr. Lee Kenny and

other Trudeau associates regarding the overseas Trudeau Entities and related firms, including

GIN FDN, Website Solutions Switzerland, Global Sales Solution, Future Transactions Company,

and Office Pool.

21. As part of its investigation, the Receiver became aware of forensic images taken

of laptops used by Neil Sant, in his capacity as a Website Solutions employee that were in the

possession and control of former counsel for Website Solutions and Neil Sant. Sant is one of the

individuals Trudeau identified as handling all aspects of his financial affairs. During the Third

Interim Period, the Receiver successfully sought the turnover of these records requiring extended

negotiations with former counsel to address attorney lien claims and asserted Fifth Amendment

concerns.

22. The Receiver has also participated in a number of hearings (and corresponding

effort to prepare for such hearings) addressing the status of Trudeaus compliance with the

Courts orders. In connection with these hearings, the Receiver solicited Trudeaus cooperation,



followed up on any new information, prepared pleadings and supplemental reports to the Court,

and coordinated its efforts with the FTC. Among other things, at Trudeaus request, the Receiver

coordinated a further interview with Trudeau held in early February 2014, and assisted the

Receivers counsel to prepare for conducting the interview.

23. The Receiver also worked with the IRS to respond to and its subpoena seeking

information regarding the financial affairs of Trudeau and certain of the Trudeau Entities.

24. During the Third Interim Period, the Receivers personnel collectively devoted

1064 hours to this matter (295.5 hours in January 2014, 167.5 hours in February 2014, 264.2

hours in March 2014, 192.3 hours in April 2014, and 144.5 hours in May 2014), incurring fees

totaling $239,651.95, for an effective blended rate of approximately $225.24 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).)

25. In addition to the professional fees sought by the Receiver, the Receiver has also

incurred $50,455.79 in out-of-pocket expenses during the five-month Third Interim Period. In

addition to the ordinary operational expenses associated with the receivership estate, these

expenses include $32,986.84 in March and $8,000 in May associated with obtaining and

uploading searchable forensic images from laptops used by Neil Sant. The remaining expenses

for which the Receiver seeks reimbursement are as follows: $997.28 for office telephone and

supplies; $4,096.09 for postage and delivery expenses; $3,420.74 for travel expenses, $561.50



for other investigative search costs, $42.89 for document reproduction, and $350.45 for website

support.

OVERVIEW OF LEGAL SERVICES AND FEES

26. Receivers counsel maintained detailed records of the billable time for which the

Receiver now seeks authority to pay. Attached as Exhibit G 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 HWZs timekeepers.

27. As reflected in the detailed invoice, during the Third Interim Period, HWZ

provided the following services to the Receiver:

Prepared, served and prosecuted on the Receivers behalf subpoenas to various financial institutions seeking to locate assets or potential assets of the receivership

estate.

Conferred and coordinated with parties on behalf of Receiver, including FTC and counsel for Trudeau.

Advised Reciver in connection with motion to intervene filed by certain members of GIN, including preparing and filing sur-reply addressing allegations regarding

Receivers management of GIN.

Assisted the Receiver in revising, finalizing and filing Receivers January 28, 2014 and March 17, 2014 Status Reports.

Attended multiple hearings before the Court in connection with imposition of coercive sanctions and subsequent hearings affording Trudeau opportunity to

purge contempt.

Conducted interview of Trudeau on behalf of Receiver.

Advised Receiver in connection with sale of certain real and personal property, including preparing motions seeking court approval and supporting declarations,

negotiating with third party lien holders and title company regarding issues

involving closing.

Advised Receiver in connection with sale of assets of GIN, including, among other things, local and state tax implications, legal standards relating to sale of

assets free and clear of liens, and preparing motions seeking approval of notice

procedures and approval of sale with supporting declarations.



Worked with Receiver to reject Westmont office lease.

Assisted the Receiver in resolving issues with internet company regarding transfer of receivership domain address and investigating additional domains owned by

receivership entities.

Negotiated with former counsel for Website Solutions regarding turnover of forensic image of laptop used by Neil Sant, including resolving attorney lien

claim issues and asserted Fifth Amendment issues.

Assisted the Receiver in responding to IRS subpoena.

Advised the Receiver with respect to claims asserted by former employees under the Illinois Wage Claim Act and coordinated with Illinois Department of labor

regarding same.

Assisted Receiver in responding to pre-receivership claims by third parties,

Advised Receiver regarding responses to various entities asserting claims against receivership estate for pre-receivership obligations, including dismissal of a

lawsuit prepared by former vendor.

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

28. During the five months comprising the Third Interim Period, HWZ expended

272.5 hours on this matter (59.3 hours in January 2014, 72.2 hours in February 2014, 52.3 hours

in March 2014, 76 hours in April 2014, and 12.7 hours in May 2014). Blair Zanzig, one of

HWZs members, was principally responsible for providing these services. For the services

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

totaling $97,164. 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 rates by

10%. Thus, HWZs invoice reflects an effect rate of $360 per hour for attorney time. The

Receiver believes these rates are comparable, if not less than, those the Receiver has seen in

connection with other similar matters.



29. In addition to its professional fees, HWZ has incurred out-of-pocket expenses of

$1,456.45, consisting of primarily of court costs associated with fees to special consulting

counsel regarding Illinois Wage Act claims ($540); costs of certified copies of various sale

orders ($105.8) , transcript costs ($193.05); overnight courier fees (338.8), and PACER charges

($278.80).

30. Further, in light of the unique nature of the assets of GIN being offered for sale

and the attendant complexities of such sale, the Receiver retained transactional counsel at the law

firm McKenna Long & Aldridge, LLP (McKenna) to assist the Receiver in structuring the sale

of GIN Assets and negotiate a final asset purchase agreement. Attached as Exhibit H to this

Motion is an invoice prepared by McKenna setting forth the specific tasks performed and the

time spent performing those tasks. McKenna expended a limited 34.2 hours on this matter and

incurred fees and expenses totaling $18,253.35. In light of the necessary specialized expertise

provided by McKenna, the Receiver believes such rates are appropriate and commensurate with

the fees charged by McKenna and approved by courts in similar matters.

31. Finally, the Receiver incurred $742.50 in legal fees to Meridian Lawyers, an

Australian law firm that has assisted the Receiver in its investigation into financial accounts held

by the Trudeau Entities in Australia.

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

the fees and expenses incurred by the Receiver Robb Evans & Associates LLC for the Third

Interim Period in the amount of $290,107.74; (b) approving the legal fees and expenses incurred

by Receivers counsel Hiltz Wantuch & Zanzig LLC for the Third Interim Period in the amount

of $98,620.45; (c) approving legal fees and expenses incurred by McKenna Long and Aldridge,

LLP totaling $18,265.32; (d) approving legal fees incurred by Meridian Lawyers in the Third



Interim Period totaling $742.50, (e) approving the Receiver to immediately pay all such

approved fees and expenses from funds held by the Receiver; and (f) granting the Receiver such

further relief as the Court deems just and proper.

Dated: July 6, 2014 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)

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 LLC,

Receiver


GIN Network Truth (the smart group)

CERTIFICATE OF SERVICE

I, Blair R. Zanzig, an attorney, hereby certify that, on the 6th day of July 2014, I caused a

true and correct copy of the foregoing Receivers Third Motion For Interim Approval of Fees

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

Kimball Richard Anderson

[email protected]

Thomas Lee Kirsch, II

[email protected]

Andrew Sullivan

[email protected]

Michael Mora

[email protected]

Jonathan Cohen

[email protected]

Amanda B. Kostner

[email protected]

David OToole [email protected]

/s/ Blair R. Zanzig


INDEX OF EXHIBITS

Ex. A Administrative Expenses and Fund Balance for Inception

(August 7, 2013) through May 31, 2014

Ex. B Invoice from Robb Evans & Associates LLC,

dated January 31, 2014

Ex. C Invoice from Robb Evans & Associates LLC,

dated February 28, 2014

Ex. D Invoice from Robb Evans & Associates LLC, dated

March 31, 2014

Ex. E Invoice from Robb Evans & Associates LLC, dated April

30, 2014

Ex. F Invoice from Robb Evans & Associates LLC, dated May

31, 2014

Ex. G Invoice from Hiltz Wantuch & Zanzig LLC, dated July

1, 2014

Ex. H Invoice from McKenna Long & Aldridge, LLP, date

April 30, 2014

Case: 1:03-cv-03904 Document #: 865-1 Filed: 07/07/14 Page 1 of 11 PageID #:15753

EXHIBIT A


ROBB EVANS & ASSOCIATES LLC

Receiver of

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

Administrative Expenses and Fund Balance From Inception (August 7, 2013) to May 31, 2014

Previously

Reported and

Approved Jan 14 Feb 14 Mar 14 Apr 14 May 14

1/1/14-

5/31/14 TOTAL

Proceeds from Sale of Assets

Sale of GIN 0.00 0.00 0.00 0.00 20,000.00 180,000.00 200,000.00 200,000.00Sale of 601 Del Oro Ojai, CA 0.00 0.00 0.00 0.00 89,434.49 0.00 89,434.49 89,434.49K. Trudeau Personal Property 0.00 0.00 0.00 78,308.00 (6,878.25) 0.00 71,429.75 71,429.75

Total Proceeds from Sale of Assets 0.00 0.00 0.00 78,308.00 102,556.24 180,000.00 360,864.24 360,864.24

Corporate Account Funds

William Hill Online Account 0.00 0.00 0.00 0.00 82,684.72 0.00 82,684.72 82,684.72Norther Trust 0.00 0.00 218.24 0.00 0.00 0.00 218.24 218.24Mary Patricia Benz Atty at Law 0.00 0.00 0.00 4,050.00 0.00 0.00 4,050.00 4,050.00Hellbenders/Trustar Prod. 0.00 0.00 0.00 2,697.31 0.00 0.00 2,697.31 2,697.31Migros Bank 0.00 0.00 4,153.97 0.00 0.00 0.00 4,153.97 4,153.97Banco Popular 0.00 20,582.27 0.00 0.00 0.00 0.00 20,582.27 20,582.27Brandy Burkhardt 5,307.50 0.00 0.00 0.00 0.00 0.00 0.00 5,307.50Debra A. Buettner P.C. 0.00 10,664.50 0.00 0.00 0.00 0.00 10,664.50 10,664.50Global Information Network 225,000.00 0.00 0.00 0.00 0.00 0.00 0.00 225,000.00Global Info Network Foundation 263,803.76 0.00 0.00 0.00 0.00 0.00 0.00 263,803.76GIN FDN Event Account 1,435,373.80 0.00 0.00 0.00 0.00 0.00 0.00 1,435,373.80I-Payout Systems Inc. 2,687.11 0.00 0.00 0.00 0.00 0.00 0.00 2,687.11K.T. Corporation Limited 2,617.02 0.00 0.00 0.00 0.00 0.00 0.00 2,617.02K.T. Radio Network Inc. 9,133.35 0.00 0.00 0.00 0.00 0.00 0.00 9,133.35Marc J. Lane Wealth Group 18,846.41 0.00 0.00 0.00 0.00 0.00 0.00 18,846.41Natural Cures Health Insurance 50,304.26 0.00 0.00 0.00 0.00 0.00 0.00 50,304.26Natural Cures Inc.

Baytree National B&T 30,618.28 0.00 0.00 0.00 0.00 0.00 0.00 30,618.28Cardflex Payment Solutions Inc. 37,779.20 0.00 0.00 0.00 0.00 0.00 0.00 37,779.20Meritus Payment Solutions 5,000.00 0.00 0.00 0.00 45,393.72 0.00 45,393.72 50,393.72National Bank of California

Merchant # 52,870.26 0.00 0.00 0.00 0.00 0.00 0.00 52,870.26Merchant # 10,719.00 0.00 0.00 0.00 0.00 0.00 0.00 10,719.00Merchant # 5,613.14 0.00 0.00 0.00 0.00 0.00 0.00 5,613.14Merchant # 8,932.17 0.00 0.00 0.00 0.00 0.00 0.00 8,932.17

Total National Bank of California 78,134.57 0.00 0.00 0.00 0.00 0.00 0.00 78,134.57

Total Natural Cures Inc. 151,532.05 0.00 0.00 0.00 45,393.72 0.00 45,393.72 196,925.77

Page 1 of 9



Receiver of



Previously

Reported and


1/1/14-

5/31/14 TOTAL

NBX Reserve Funds 0.00 0.00 0.00 1,449,985.46 0.00 0.00 1,449,985.46 1,449,985.46Park Federal Savings Bank 13,657.54 0.00 0.00 0.00 0.00 0.00 0.00 13,657.54Pershing LLC 0.00 380.73 0.00 0.00 0.00 0.00 380.73 380.73The Gordon Law Group LTD 0.00 11,335.50 0.00 0.00 0.00 0.00 11,335.50 11,335.50Tru-Com LLC 804.01 0.00 0.00 0.00 0.00 0.00 0.00 804.01Trudeau Approved Products 106,384.23 0.00 0.00 0.00 0.00 0.00 0.00 106,384.23Trustar Productions Inc. 1,376.72 0.00 0.00 0.00 0.00 0.00 0.00 1,376.72Website Solutions USA 422,249.48 0.00 0.00 0.00 0.00 0.00 0.00 422,249.48

Total Corporate Account Funds 2,709,077.24 42,963.00 4,372.21 1,456,732.77 128,078.44 0.00 1,632,146.42 4,341,223.66

Incoming Receipts

Global Information Network

Receiver Account

Copyright Royalties 14,743.63 3,409.10 1,792.02 7,081.91 27,457.43 2,675.23 42,415.69 57,159.32Event Commissions 6,920.95 0.00 0.00 4,103.80 0.00 0.00 4,103.80 11,024.75Membership Dues & Upgrades-Chk 70,456.31 3,588.98 1,872.03 4,545.00 2,900.00 2,554.20 15,460.21 85,916.52Membership Dues & Upgrades - CC

Membership Dues & Upgrades - CC 5,792,706.77 762,876.00 585,910.00 527,057.00 447,260.00 432,994.00 2,756,097.00 8,548,803.77Refunds & Returns (62,180.00) (32,040.00) (8,550.00) (9,480.00) (4,540.00) (3,460.00) (58,070.00) (120,250.00)Chargebacks (12,306.66) (7,756.34) (2,516.46) (4,203.00) (2,914.37) (2,678.13) (20,068.30) (32,374.96)Voided Sales (865,283.95) 0.00 0.00 0.00 0.00 0.00 0.00 (865,283.95)Reserves Balance - Not Available (1,265,314.12) (188,986.25) (146,440.00) 73,935.72 204,190.62 184,525.87 127,225.96 (1,138,088.16)

Total Membership Dues & Upgrades - CC 3,587,622.04 534,093.41 428,403.54 587,309.72 643,996.25 611,381.74 2,805,184.66 6,392,806.70

Total Receiver Account 3,679,742.93 541,091.49 432,067.59 603,040.43 674,353.68 616,611.17 2,867,164.36 6,546,907.29

Non-Receiver Account

Remote Deposit 13,261.15 0.00 0.00 0.00 0.00 0.00 0.00 13,261.15Total Non-Receiver Account 13,261.15 0.00 0.00 0.00 0.00 0.00 0.00 13,261.15

Total Global Information Network 3,693,004.08 541,091.49 432,067.59 603,040.43 674,353.68 616,611.17 2,867,164.36 6,560,168.44

Trudeau Approved Products

Receiver Account

Credit Card Sales

Credit Card Sales 73,957.84 0.00 0.00 0.00 0.00 0.00 0.00 73,957.84

Page 2 of 9



Receiver of



Previously

Reported and


1/1/14-

5/31/14 TOTAL

Chargebacks (685.92) (79.90) 0.00 (150.00) 0.00 0.00 (229.90) (915.82)Reserves (18,275.81) 0.00 0.00 0.00 0.00 0.00 0.00 (18,275.81)Refunds/Returns (3,762.72) (259.75) 0.00 0.00 0.00 (249.75) (509.50) (4,272.22)

Total Credit Card Sales 51,233.39 (339.65) 0.00 (150.00) 0.00 (249.75) (739.40) 50,493.99

Total Receiver Account 51,233.39 (339.65) 0.00 (150.00) 0.00 (249.75) (739.40) 50,493.99

Non-Receiver Account

Bankcard MTOT Dep 6,547.61 0.00 0.00 0.00 0.00 0.00 0.00 6,547.61SBC VSMC Deposits 9,067.56 0.00 0.00 0.00 0.00 0.00 0.00 9,067.56

Total Non-Receiver Account 15,615.17 0.00 0.00 0.00 0.00 0.00 0.00 15,615.17

Total Trudeau Approved Products 66,848.56 (339.65) 0.00 (150.00) 0.00 (249.75) (739.40) 66,109.16

GIN FDN Event Registration

GIN FDN Event Registration 49.00 2,279.00 15,330.00 13,718.00 99.00 0.00 31,426.00 31,475.00Refund of Registration Fees (6,142.65) 0.00 (567.00) (683.10) 0.00 0.00 (1,250.10) (7,392.75)Reserves 0.00 (227.90) (1,418.10) (1,281.10) 0.00 0.00 (2,927.10) (2,927.10)

Total GIN FDN Event Registration (6,093.65) 2,051.10 13,344.90 11,753.80 99.00 0.00 27,248.80 21,155.15

Sale of Inventory Stock 7,746.50 0.00 0.00 0.00 12,657.28 8,794.16 21,451.44 29,197.94

Total Incoming Receipts 3,761,505.49 542,802.94 445,412.49 614,644.23 687,109.96 625,155.58 2,915,125.20 6,676,630.69

Interest Income 479.33 116.60 53.10 61.88 18.37 37.56 287.51 766.84Miscellaneous Income

Refunds 1,644.29 0.00 0.00 0.00 0.00 29.66 29.66 1,673.95Tax Refunds 1,560.55 0.00 0.00 0.00 0.00 0.00 0.00 1,560.55Other 1,633.89 0.00 0.00 0.00 0.00 0.00 0.00 1,633.89

Total Miscellaneous Income 4,838.73 0.00 0.00 0.00 0.00 29.66 29.66 4,868.39

Total Funds Collected 6,475,900.79 585,882.54 449,837.80 2,149,746.88 917,763.01 805,222.80 4,908,453.03 11,384,353.82

Expenses

GIN FDN Event Expenses

Cellular & Communications 0.00 0.00 0.00 0.00 0.00 1,327.41 1,327.41 1,327.41Toronto Oct. 2013

Ticket Sales Commission 0.00 0.00 0.00 3,577.00 0.00 0.00 3,577.00 3,577.00

Page 3 of 9



Receiver of



Previously

Reported and


1/1/14-

5/31/14 TOTAL

Speaker Fees 0.00 0.00 0.00 1,788.50 0.00 0.00 1,788.50 1,788.50

Total Toronto Oct. 2013 0.00 0.00 0.00 5,365.50 0.00 0.00 5,365.50 5,365.50

PowerUp! Los Angeles

Food & Beverage 0.00 0.00 0.00 0.00 0.00 1,048.20 1,048.20 1,048.20Meals & Incidentals 0.00 0.00 0.00 530.38 0.00 1,833.55 2,363.93 2,363.93Taxi & Parking 0.00 0.00 0.00 180.74 0.00 116.37 297.11 297.11Car Rental 0.00 0.00 0.00 157.76 0.00 0.00 157.76 157.76Rooms/Lodging 0.00 0.00 0.00 2,572.81 0.00 0.00 2,572.81 2,572.81Speaker Fees 0.00 0.00 0.00 8,000.00 0.00 0.00 8,000.00 8,000.00Airfare 0.00 0.00 0.00 1,250.00 0.00 4,139.15 5,389.15 5,389.15Per Diem Expenses 0.00 0.00 0.00 198.00 0.00 0.00 198.00 198.00Venue Rental 0.00 0.00 0.00 2,500.00 0.00 5,395.01 7,895.01 7,895.01

Total PowerUp! Los Angeles 0.00 0.00 0.00 15,389.69 0.00 12,532.28 27,921.97 27,921.97

Power Up Paris!

Ground Transportation 0.00 0.00 0.00 215.41 0.00 173.00 388.41 388.41Meals & Incidentals 0.00 0.00 0.00 569.40 916.45 715.24 2,201.09 2,201.09Lodging/Rooms 0.00 0.00 0.00 3,047.79 0.00 0.00 3,047.79 3,047.79A/V Rental 0.00 0.00 2,118.17 0.00 0.00 0.00 2,118.17 2,118.17Venue Rental 0.00 0.00 5,431.20 123.90 0.00 0.00 5,555.10 5,555.10Translation Services 0.00 0.00 1,955.50 2,541.00 0.00 0.00 4,496.50 4,496.50Airfare 0.00 0.00 0.00 1,232.90 0.00 19.98 1,252.88 1,252.88Speaker Fees 0.00 0.00 0.00 2,250.00 0.00 0.00 2,250.00 2,250.00Speaker Expenses 0.00 0.00 1,632.70 0.00 0.00 230.74 1,863.44 1,863.44

Total Power Up Paris! 0.00 0.00 11,137.57 9,980.40 916.45 1,138.96 23,173.38 23,173.38

Level 6 Training & 5 Exams

Staff Expenses 0.00 0.00 634.74 0.00 0.00 0.00 634.74 634.74Parking & Tolls 0.00 0.00 140.00 0.00 0.00 0.00 140.00 140.00Food & Beverage 0.00 0.00 1,390.00 0.00 0.00 9.40 1,399.40 1,399.40Venue Rental 0.00 0.00 2,810.00 0.00 0.00 0.00 2,810.00 2,810.00

Total Level 6 Training & 5 Exams 0.00 0.00 4,974.74 0.00 0.00 9.40 4,984.14 4,984.14

Leadership Round Table Mtg

Airfare 0.00 0.00 0.00 0.00 0.00 337.00 337.00 337.00Meals & Incidentals 0.00 0.00 0.00 0.00 0.00 1,708.27 1,708.27 1,708.27

Page 4 of 9



Receiver of



Previously

Reported and


1/1/14-

5/31/14 TOTAL

Promotion & Supplies 0.00 0.00 0.00 0.00 0.00 560.92 560.92 560.92Food & Beverage 0.00 0.00 1,335.00 0.00 0.00 2,302.76 3,637.76 3,637.76Venue Rental 0.00 0.00 734.25 0.00 0.00 0.00 734.25 734.25

Total Leadership Round Table Mtg 0.00 0.00 2,069.25 0.00 0.00 4,908.95 6,978.20 6,978.20

Power Up! Chicago 2/22/14

Ground Transportation 0.00 0.00 0.00 178.08 0.00 0.00 178.08 178.08Meals & Incidentals 0.00 0.00 0.00 149.90 0.00 381.34 531.24 531.24Staff Expenses 0.00 0.00 919.05 0.00 0.00 100.44 1,019.49 1,019.49Parking & Tolls 0.00 0.00 127.00 0.00 0.00 26.00 153.00 153.00Airfare & Taxi 0.00 0.00 522.74 400.00 0.00 0.00 922.74 922.74Speaker Lodging & Expenses 0.00 0.00 414.29 0.00 0.00 226.45 640.74 640.74Audio & Visual 0.00 0.00 3,044.39 19.00 0.00 0.00 3,063.39 3,063.39Food & Beverage 0.00 0.00 203.41 0.00 0.00 0.00 203.41 203.41Speaker Fees 0.00 6,000.00 2,000.00 2,250.00 0.00 0.00 10,250.00 10,250.00Venue Rental 0.00 1,128.22 0.00 0.00 0.00 0.00 1,128.22 1,128.22

Total Power Up! Chicago 2/22/14 0.00 7,128.22 7,230.88 2,996.98 0.00 734.23 18,090.31 18,090.31

Bank Fees 15.00 0.00 0.00 0.00 0.00 726.57 726.57 741.57Authnet Gateway Fees 126.94 39.95 42.91 82.59 65.71 0.00 231.16 358.10Credit Card Discounts 185.85 113.95 714.00 1,206.74 54.35 137.28 2,226.32 2,412.17Credit Card Fees 46.86 113.91 130.89 7.95 417.16 47.90 717.81 764.67Event Management Expenses 6,667.74 0.00 9,824.02 0.00 0.00 3,858.23 13,682.25 20,349.99Event Management Fees 200,000.00 50,000.00 50,000.00 50,000.00 50,000.00 50,000.00 250,000.00 450,000.00Gift Cards 215.35 0.00 0.00 0.00 0.00 0.00 0.00 215.35GIN Family Reunion Event Exp 599,980.73 2,723.96 0.00 0.00 0.00 0.00 2,723.96 602,704.69Recording/Production Costs 0.00 73.16 0.00 0.00 0.00 0.00 73.16 73.16Speaker Fees 1,258.00 0.00 0.00 0.00 0.00 0.00 0.00 1,258.00Speaker Gifts 0.00 21.44 0.00 0.00 0.00 0.00 21.44 21.44Ticket Sales Commissions 710.50 0.00 0.00 0.00 0.00 0.00 0.00 710.50Travel Expenses 5,486.95 0.00 0.00 0.00 0.00 0.00 0.00 5,486.95

Total GIN FDN Event Expenses 814,693.92 60,214.59 86,124.26 85,029.85 51,453.67 75,421.21 358,243.58 1,172,937.50

Business Operation Expenses

Penalties & Interest 0.00 0.00 0.00 131.28 0.00 0.00 131.28 131.28Worker Compensation Insurance 0.00 0.00 0.00 3,359.25 0.00 0.00 3,359.25 3,359.25UPC/Trademark Registrations Fee 0.00 0.00 0.00 206.91 0.00 0.00 206.91 206.91

Page 5 of 9



Receiver of



Previously

Reported and


1/1/14-

5/31/14 TOTAL

Music License Fees 0.00 150.00 0.00 0.00 0.00 0.00 150.00 150.00Alarm & Security 210.00 0.00 0.00 105.00 0.00 0.00 105.00 315.00Bank Fees 321.78 0.00 0.00 0.00 0.00 0.00 0.00 321.78Cellular Services 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00Colocation Server Services 20,200.00 5,050.00 5,050.00 7,050.00 7,050.00 7,050.00 31,250.00 51,450.00Communication Consulting 0.00 12,822.00 12,330.00 12,000.00 0.00 0.00 37,152.00 37,152.00Contest Winner Vehicle Lease 36,250.00 7,250.00 0.00 0.00 0.00 0.00 7,250.00 43,500.00Corporate Insurance Premiums 0.00 263.34 1,033.34 23,563.97 270.34 270.34 25,401.33 25,401.33Credit Card Discounts & Fees

CC Fees

Authnet Gateway Fees 8,463.20 811.70 708.50 649.40 580.60 506.10 3,256.30 11,719.50Meritus Merchant 114.90 0.00 0.00 0.00 0.00 0.00 0.00 114.90NMC Credit Card Fees 111,392.93 20,508.86 18,839.90 14,856.89 13,136.12 11,834.00 79,175.77 190,568.70Verifi 267.95 0.00 0.00 0.00 0.00 0.00 0.00 267.95

Total CC Fees 120,238.98 21,320.56 19,548.40 15,506.29 13,716.72 12,340.10 82,432.07 202,671.05

CC Discounts

GIN CC Discounts 244,163.60 38,143.80 29,295.50 26,315.35 22,666.00 21,412.20 137,832.85 381,996.45Trudeau App Product CC Discount 5,386.87 0.00 51.73 0.00 0.00 0.00 51.73 5,438.60

Total CC Discounts 249,550.47 38,143.80 29,347.23 26,315.35 22,666.00 21,412.20 137,884.58 387,435.05

Total Credit Card Discounts & Fees 369,789.45 59,464.36 48,895.63 41,821.64 36,382.72 33,752.30 220,316.65 590,106.10

Document Destruction Services 348.96 0.00 0.00 0.00 0.00 0.00 0.00 348.96Domain License 0.00 0.00 2,300.00 0.00 0.00 0.00 2,300.00 2,300.00Electricity 6,131.57 2,231.05 1,278.68 989.22 0.00 1,686.66 6,185.61 12,317.18Employer Payroll Taxes 48,576.72 11,693.18 10,267.65 9,260.81 18,783.44 13,084.64 63,089.72 111,666.44Equipment Rental 1,452.53 231.87 109.59 141.98 0.00 108.66 592.10 2,044.63Exigo Services 50,491.43 12,746.19 12,746.40 12,746.51 12,746.65 12,746.74 63,732.49 114,223.92G.I.N. Commission Payments 745,495.40 0.00 0.00 0.00 3,676.00 0.00 3,676.00 749,171.40Health Insurance & Benefits 141,623.15 35,478.52 33,480.56 30,259.31 35,937.71 64,620.70 199,776.80 341,399.95Independent Contractor Fees 93,791.08 6,716.00 5,096.00 6,134.10 5,993.00 7,097.00 31,036.10 124,827.18Intercompany Payroll Allocation 7,200.00 0.00 0.00 0.00 0.00 0.00 0.00 7,200.00Inventory Disposal/Shredding 565.00 0.00 0.00 0.00 0.00 0.00 0.00 565.00Inventory Storage 2,920.96 334.48 334.48 334.48 334.48 14,723.63 16,061.55 18,982.51Janitorial Services 6,735.00 750.00 1,600.00 800.00 0.00 1,000.00 4,150.00 10,885.00Locksmith Services 251.90 0.00 0.00 0.00 0.00 0.00 0.00 251.90

Page 6 of 9



Receiver of



Previously

Reported and


1/1/14-

5/31/14 TOTAL

Meals & Entertainment 263.83 0.00 7,973.40 0.00 0.00 0.00 7,973.40 8,237.23Member/Affiliate Communications 6,000.00 6,000.00 0.00 0.00 (6,960.00) 0.00 (960.00) 5,040.00Natural Gas 2,176.27 4,002.05 0.00 1,904.03 1,985.02 694.51 8,585.61 10,761.88Office Rent 89,682.46 22,117.43 22,132.79 23,540.29 23,724.51 23,553.50 115,068.52 204,750.98Office Sublease Commission 1,996.43 0.00 0.00 0.00 0.00 0.00 0.00 1,996.43Office Supplies 1,110.43 1,006.28 0.00 279.07 0.00 1,709.67 2,995.02 4,105.45Payroll Expenses 717,077.48 109,773.61 103,351.46 103,973.16 103,703.16 160,570.42 581,371.81 1,298,449.29Payroll Processing Fees 2,207.55 370.10 702.10 373.10 370.10 569.15 2,384.55 4,592.10Phone & Internet Services 16,986.56 3,801.23 3,135.30 3,091.83 2,332.22 2,399.52 14,760.10 31,746.66PO Box Rent 396.00 0.00 0.00 126.00 126.00 240.00 492.00 888.00Postage & Delivery 46.00 307.47 29.18 2,600.12 1,657.71 1,507.45 6,101.93 6,147.93Prior Period CC Return 450.00 0.00 0.00 0.00 0.00 0.00 0.00 450.00Promotional Expenses 5,096.80 0.00 303.06 0.00 110.00 0.00 413.06 5,509.86Sales & Use Taxes 1,255.52 0.00 0.00 758.20 0.00 0.00 758.20 2,013.72Security Services 960.00 0.00 0.00 0.00 0.00 0.00 0.00 960.00Shipping & Packaging 17,280.22 901.12 457.07 100.28 0.00 0.00 1,458.47 18,738.69Software Support Service 7,788.00 3,473.39 2,940.00 8,654.74 403.00 189.90 15,661.03 23,449.03Storage Unit Rent 2,651.00 1,498.00 0.00 1,486.00 0.00 718.00 3,702.00 6,353.00Transportation Services 772.59 0.00 0.00 0.00 0.00 0.00 0.00 772.59Unspecified Business Expenses 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00Website Services 9,819.05 2,362.39 579.79 552.49 0.00 4,818.45 8,313.12 18,132.17

Total Business Operation Expenses 2,416,371.12 310,794.06 276,126.48 296,343.77 248,626.06 353,111.24 1,485,001.61 3,901,372.73

Ojai, CA Residential Property

Appraisal Fees 800.00 0.00 150.00 0.00 0.00 0.00 150.00 950.00Electricity 5,729.40 495.39 409.16 583.60 202.03 0.00 1,690.18 7,419.58Landscaping Maintenance 2,054.30 0.00 300.00 629.29 0.00 0.00 929.29 2,983.59Maintenance & Repairs 295.00 0.00 0.00 0.00 0.00 0.00 0.00 295.00Natural Gas 378.05 0.00 205.93 0.00 0.00 95.42 301.35 679.40Pool Maintenance 520.00 120.00 120.00 120.00 0.00 0.00 360.00 880.00Property Taxes 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00Security Alarm Monitoring 447.85 144.00 0.00 0.00 0.00 0.00 144.00 591.85Security & Caretaking 4,358.98 0.00 0.00 0.00 0.00 0.00 0.00 4,358.98Telephone 261.95 94.56 0.00 77.79 0.00 0.00 172.35 434.30Title Insurance 0.00 0.00 0.00 0.00 700.00 0.00 700.00 700.00Water 2,499.78 407.34 0.00 468.93 188.08 0.00 1,064.35 3,564.13

Total Ojai, CA Residential Property 17,345.31 1,261.29 1,185.09 1,879.61 1,090.11 95.42 5,511.52 22,856.83

Page 7 of 9



Receiver of



Previously

Reported and


1/1/14-

5/31/14 TOTAL

Payment to Winston & Strawn LLP 33,128.28 0.00 0.00 0.00 0.00 0.00 0.00 33,128.28Kevin Trudeau Living Expense 9,352.00 0.00 0.00 0.00 0.00 0.00 0.00 9,352.00Receiver Fees & Expenses

Receiver Fees

Receiver

R. Evans 573.75 0.00 0.00 0.00 191.25 76.50 267.75 841.50B. Kane 54,450.90 7,326.45 2,713.50 2,984.85 1,748.70 3,768.75 18,542.25 72,993.15K. Johnson 97,716.15 4,522.50 4,251.15 4,040.10 5,366.70 422.10 18,602.55 116,318.70V. Miller 97,083.00 11,306.25 4,130.55 6,693.30 29,697.75 14,863.95 66,691.80 163,774.80A. Jen 74,048.40 10,311.30 2,864.25 4,221.00 3,889.35 2,412.00 23,697.90 97,746.30

Total Receiver 323,872.20 33,466.50 13,959.45 17,939.25 40,893.75 21,543.30 127,802.25 451,674.45

Senior Staff

L. Lee 31,356.00 1,899.45 452.25 814.05 271.35 452.25 3,889.35 35,245.35T. Chung 44,561.70 11,728.35 7,024.95 18,512.10 0.00 211.05 37,476.45 82,038.15F. Jen 79,957.80 11,065.05 5,517.45 9,256.05 241.20 211.05 26,290.80 106,248.60C. Callahan 8,955.00 1,237.50 630.00 7,492.50 1,845.00 0.00 11,205.00 20,160.00E. Roop 5,535.00 0.00 0.00 0.00 243.00 3,280.50 3,523.50 9,058.50C. DeCius 27,846.00 4,941.00 3,285.00 3,897.00 3,168.00 3,978.00 19,269.00 47,115.00N. Wolf 102.00 0.00 0.00 6.00 12.00 0.00 18.00 120.00J. Dadbin 4,950.00 2,321.00 2,134.00 1,826.00 533.50 93.50 6,908.00 11,858.00

Total Senior Staff 203,263.50 33,192.35 19,043.65 41,803.70 6,314.05 8,226.35 108,580.10 311,843.60

Support Staff 8,585.20 536.00 258.70 814.40 1,208.50 452.00 3,269.60 11,854.80

Total Receiver Fees 535,720.90 67,194.85 33,261.80 60,557.35 48,416.30 30,221.65 239,651.95 775,372.85

Receiver Expenses

Bank Fees 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00Investigative Search Costs 590.60 0.00 0.00 32,986.84 539.00 22.50 33,548.34 34,138.94Office Telephone & Supplies 506.51 333.19 125.91 130.58 132.43 275.17 997.28 1,503.79Postage & Delivery 2,136.24 1,848.04 277.33 943.57 334.12 693.03 4,096.09 6,232.33Subpoena/Document Reproduction 1,669.48 42.89 0.00 0.00 0.00 8,000.00 8,042.89 9,712.37Travel Expenses 27,460.45 0.00 0.00 0.00 3,420.74 0.00 3,420.74 30,881.19Website Support 536.76 44.36 62.10 26.62 102.03 115.34 350.45 887.21

Total Receiver Expenses 32,900.04 2,268.48 465.34 34,087.61 4,528.32 9,106.04 50,455.79 83,355.83

Page 8 of 9



Receiver of



Previously

Reported and


1/1/14-

5/31/14 TOTAL

Legal Fees & Costs

Hiltz Wantuch & Zanzig

Legal Fees 108,684.00 0.00 0.00 0.00 0.00 97,164.00 97,164.00 205,848.00Legal Costs 1,152.17 0.00 0.00 0.00 0.00 1,456.45 1,456.45 2,608.62

Total Hiltz Wantuch & Zanzig 109,836.17 0.00 0.00 0.00 0.00 98,620.45 98,620.45 208,456.62

Holzhacker

Legal Fees 7,783.20 0.00 0.00 0.00 0.00 0.00 0.00 7,783.20Legal Costs 11.84 0.00 0.00 0.00 0.00 0.00 0.00 11.84

Total Holzhacker 7,795.04 0.00 0.00 0.00 0.00 0.00 0.00 7,795.04

McKenna Long & Aldridge LLP

Legal Fees 0.00 0.00 0.00 0.00 18,253.35 0.00 18,253.35 18,253.35Legal Costs 0.00 0.00 0.00 0.00 11.97 0.00 11.97 11.97

Total McKenna Long & Aldridge LLP 0.00 0.00 0.00 0.00 18,265.32 0.00 18,265.32 18,265.32

Meridian Lawyers

Legal Fees 1,188.00 0.00 742.50 0.00 0.00 0.00 742.50 1,930.50Legal Costs 436.95 0.00 0.00 0.00 0.00 0.00 0.00 436.95

Total Meridian Lawyers 1,624.95 0.00 742.50 0.00 0.00 0.00 742.50 2,367.45

Total Legal Fees & Costs 119,256.16 0.00 742.50 0.00 18,265.32 98,620.45 117,628.27 236,884.43

Total Receiver Fees & Expenses 687,877.10 69,463.33 34,469.64 94,644.96 71,209.94 137,948.14 407,736.01 1,095,613.11

Total Expenses 3,978,767.73 441,733.27 397,905.47 477,898.19 372,379.78 566,576.01 2,256,492.72 6,235,260.45

Net Transactions 144,149.27 51,932.33 1,671,848.69 545,383.23 238,646.79 2,651,960.31

Fund Balance 2,497,133.06 5,149,093.37

Page 9 of 9


EXHIBIT B


EXHIBIT C


EXHIBIT D


EXHIBIT E


EXHIBIT F


EXHIBIT G

HILTZ WANTUCH & ZANZIG

TO:

ROBB EVANS & ASSOCIATES, LLCReceiver of the Assets of Kevin Trudeau et al.1.1450 Sheldon StreetSun Vaf ley, California 9L3SZ-ILZL

INVOICE PERIOD:0r/ o! / 2oL4 - os / 30 / 2OL4

INVO|CE NO:2025luLY t,2ot4

PAYMENT DUE UPON RECEIPT

s107,960

-s10,796

s1,456.45

s98,620.45

SUMMARY

FEE FOR PROFESSIONAL SERVICESRENDERED PER ATTACHED DETAIL

LESS 10% DISCOUNT INRECOGNITION OF PUBLICINTERESTS

COSTS AND ADMINISTRATIVEEXPENSES PER ATTACHED DETAIL

TOTAL CURRENT AMOUNT DUE

INVOICE NO: 2025 JULY 1, 2014


2

DETAIL

Date TMK Description of Services Rendered Time

01/06/2014

BRZ

CONFERRED WITH RECEIVER REGARDING

. CORRESPONDED WITH K. TRUDEAU TAX COUNSEL REGARDING SAME.

.4

01/07/2014 BRZ

CONFERRED WITH COUNSEL FOR BNY MELLON REGARDING RESPONSE TO SUBPOENA. DRAFTED SUBPOENA AND NOTICE OF SUBPOENA TO PERSHING REGARDING RECEIVERSHIP ACCOUNTS. REVIEWED CORRESPONDENCE REGARDING RETURN OF RETAINER BY K. TRUDEAU TAX COUNSEL. CONFERRED WITH RECEIVER REGARDING

. REVIEWED CORRESPONDENCE AND BACKGROUND DOCUMENTS REGARDING SAME.

3.6

01/08/2014 BRZ

REVIEWED CORRESPONDENCE FROM PROPOSED INTERVENORS COUNSEL REGARDING GIN STATUS. CONFERRED WITH RECEIVER REGARDING

.

.8

01/09/2014 BRZ

CONFERRED WITH RECEIVER REGARDING . REVIEWED

CORRESPONDENCE WITH RBS BANK AND RELATED BACKGROUND DOCUMENTS REGARDING SAME.

2.2

01/10/2014 BRZ


. REVIEWED RELATED CORRESPONDENCE. FINALIZED AND SERVED SUBPOENAS TO THIRD PARTY FINANCIAL INSTITUTIONS.

1.7

01/14/2014 BRZ

TELEPHONE CONFERENCE WITH RBS BANK COUNSEL REGARDING OJAI PROPERTY LIEN ISSUES. REVIEWED DRAFT LIEN RELEASES. CONFERRED WITH RECEIVER REGARDING

.

1.4



3

01/15/2014 BRZ

TELEPHONE CONFERENCE WITH RBS BANK COUNSEL REGARDING LIEN ISSUES. CONFERRED WITH RECEIVER REGARDING SAME. DRAFTED LETTER TO OAK BROOK PROPERTY OWNER REGARDING DISPUTED PERSONAL PROPERTY.

2.3

01/16/2014 BRZ

CORRESPONDED WITH RBS BANK COUNSEL AND RECEIVER REGARDING OJAI PROPERTY LIEN ISSUES. CONFERRED WITH RECEIVER REGARDING

.6

1/17/2014 BRZ

FINALIZED LETTER REGARDING DISPUTED PERSONAL PROPERTY. REVIEWED CORRESPONDENCE REGARDING WILLIAM HILL ACCOUNT. CORRESPONDED WITH L. KENNEY REGARDING REQUEST FOR BANK STATEMENTS. TELEPHONE CONFERENCE WITH POPULAR BANK COMPLIANCE DEPARTMENT REGARDING TURNOVER OF FUNDS. TELEPHONE CONFERENCE WITH FINANCIAL INSTITUTIONS REGARDING RESPONSE TO SUBPOENAS.

2.5

1/20/2014 BRZ

REVIEWED INTERVENORS REPLY IN SUPPORT OF MOTION TO INTERVENE. TELEPHONE CONFERENCE POPULAR BANK COMPLIANCE DEPARTMENT REGARDING TURNOVER OF FUNDS.

.7

01/21/2014 BRZ


. TELEPHONE CONFERENCE WITH SUBPOENA RESPONSE DEPARTMENT FOR PERSHING LLC. REVIEWED COLLECTION ACTION AGAINST WEBSITE SOLUTIONS. CORRESPONDED WITH RECEIVER AND TAX COUNSEL FOR K. TRUDEAU REGARDING FINANCIAL RECORDS.

3.2

1/22/2014 BRZ


. REVIEWED CORRESPONDENCE FROM L. KENNY REGARDING PRODUCTION OF BANK STATEMENTS. TELEPHONE CONFERENCE WITH RECEIVER AND FTC REGARDING CONTURSI SUBPOENA. REVIEWED CORRESPONDENCE FROM COUNSEL FOR K. TRUDEAU REGARDING SWISS ACCOUNTS.

1.2

1/23/2014 BRZ CONFERRED WITH RECEIVER REGARDING

DRAFTED SUR-REPLY TO PROPOSED INTERVENORS REPLY BRIEF.

5.8



4

1/24/2014 BRZ

DRAFTED LETTER TO POPULAR BANK COMPLIANCE DEPARTMENT REGARDING TURNOVER OF FUNDS. DRAFTED SUR-REPLY TO PROPOSED INTERVENORS REPLY BRIEF. CONFERRED WITH RECEIVER REGARDING SAME. TELEPHONE CONFERENCE WITH FTC AND RECEIVER REGARDING STATUS HEARING. TELEPHONE CONFERENCE WITH COUNSEL FOR WEBSITE SOLUTIONS REGARDING DISMISSAL OF COLLECTION ACTION.

7.3

01/26/2014 BRZ REVIEWED CORRESPONDENCE REGARDING SUR-REPLY TO PROPOSED INTERVENORS RESPONSE. REVISED SUR-REPLY.

.8

01/27/2014 BRZ

DRAFTED SUR-REPLY OPPOSING MOTION TO INTERVENE AND MOTION FOR LEAVE TO FILE. FINALIZED AND COORDINATED FILING OF SAME. CONFERRED WITH RECEIVER REGARDING SAME. COORDINATED TURNOVER OF FUNDS WITH POPULAR BANK SUBPOENA COMPLIANCE DEPARTMENT. CONFERRED WITH RECEIVER REGARDING

. CORRESPONDED WITH COUNSEL FOR WEST PUBLISHING CONFIRMING DISMISSAL OF COLLECTION ACTION. TELEPHONE CONFERENCE WITH D. DONNELLON REGARDING WEBSITE SOLUTION ELECTRONIC DATA PRESERVATION. CONFERRED WITH RECEIVER REGARDING STATUS REPORT. REVISED STATUS REPORT.

8.2

01/28/2014 BRZ

CONFERRED WITH RECEIVER REGARDING STATUS REPORT. FINALIZED REPORT AND COORDINATED FILING OF SAME. REVIEWED AND ANALYZED PROPOSED INTERVENORS OPPOSITION TO MOTION TO FILE SUR-REPLY. REVIEWED CORRESPONDENCE AND ACCOMPANYING DOCUMENTS FROM COUNSEL FOR K. TRUDEAU REGARDING SWISS ACCOUNTS. TELEPHONE CONFERENCE WITH P. DEADY AND D. DONNELLON REGARDING WEBSITE SOLUTIONS LAPTOP PRESERVATION AND TURNOVER.

3.8

01/29/2014 BRZ

PREPARED FOR STATUS HEARING, INCLUDING REVIEWED BRIEFING ON MOTION TO INTERVENE AND RELATED STATUS REPORTS. CONFERRED WITH RECEIVER REGARDING STATUS OF THIRD PARTY SUBPOENAS.

2.7



5

01/30/2014 BRZ

ATTENDED STATUS HEARING REGARDING MOTION TO INTERVENE AND RELATED MATTERS. CONFERRED WITH RECEIVER REGARDING SAME. MET WITH COUNSEL FOR FTC REGARDING CASE STATUS. TELEPHONE CONFERENCE WITH P. DEADY REGARDING FORENSIC IMAGE OF WEBSITE SOLUTIONS LAPTOP. REVIEWED CORRESPONDENCE FROM COUNSEL FOR K. TRUDEAU REGARDING FURTHER INTERVIEW OF TRUDEAU. TELEPHONE CONFERENCE WITH K. ROHLF REGARDING SAME. CONFERRED WITH RECEIVER AND FTC REGARDING SAME.

6.7

01/31/2014 BRZ

REVIEWED SOCIAL MEDIA REPORTS FORWARDED BY RECEIVER REGARDING MANAGEMENT OF GIN. CONFERRED WITH RECEIVER REGARDING . CORRESPONDED WITH COUNSEL FOR K. TRUDEAU REGARDING FURTHER INTERVIEW OF K. TRUDEAU. CONFERRED WITH RECEIVER REGARDING SAME. REVIEWED CORRESPONDENCE FROM P. DEADY REGARDING OUTSTANDING LEGAL BILLS TO WEBSITE SOLUTIONS AND RECEIVERS REQUEST FOR TURNOVER OF WEBSITE SOLUTIONS LAPTOP.

3.4

02/03/2014 BRZ

PREPARED FOR INTERVIEW WITH K. TRUDEAU, INCLUDING REVIEW OF FINANCIAL DOCUMENTS. MET WITH COUNSEL FOR FTC IN PREPARATION FOR INTERVIEW. TELEPHONE CONFERENCE WITH RECEIVER REGARDING SAME. MET WITH K. TRUDEAU AT MCC WITH HIS COUNSEL, COUNSEL FOR FTC AND CO-COUNSEL. CORRESPONDED WITH RECEIVER REGARDING TURNOVER OF FORENSIC IMAGE OF WEBSITE SOLUTIONS LAPTOP.

8.7

02/03/2014 JFH MET WITH B. ZANZIG AND J. COHEN IN PREPARATION FOR TRUDEAU INTERVIEW. ATTENDED MEETING WITH K. TRUDEAU AT MCC.

5.21

02/05/2014 BRZ

TELEPHONE CONFERENCE WITH P. DEADY REGARDING TURNOVER OF FORENSIC IMAGE OF WEBSITE SOLUTIONS LAPTOP. REVIEWED CORRESPONDENCE FROM D. DONNELLON REGARDING SAME. CONFERRED WITH RECEIVER AND COUNSEL FOR FTC REGARDING SAME.

1.1

1 Billed at paralegal rate of $200 per hour.



6

02/06/2014 BRZ

CORRESPONDED WITH RECEIVER REGARDING THIRD REVIEWED COMMUNICATIONS BETWEEN

PROPOSED INTERVENORS AND GIN MEMBERS REGARDING RECEIVERS ACTIVITIES. CORRESPONDED WITH D. DONNELLON REGARDING FORENSIC IMAGE OF WEBSITE SOLUTIONS LAPTOP. DRAFTED LETTER TO FORMER WEBSITE SOLUTIONS COUNSEL REGARDING SAME. RESEARCHED LEGAL STANDARDS RELATING TO ATTORNEY LIEN CLAIMS FOR UNPAID FEES. TELEPHONE CONFERENCE WITH FORMER WEBSITE SOLUTIONS COUNSEL REGARDING SAME. REVIEWED CORRESPONDENCE AND RELATED DOCUMENTS FROM COUNSEL FOR K. TRUDEAU REGARDING DEMAND LETTERS. CONFERRED WITH COUNSEL FOR FTC REGARDING PRIOR SUBPOENAS TO LAW FIRMS REPRESENTING WEBSITE SOLUTIONS AND N. SANT.

6.7

02/07/2014 BRZ

REVIEWED RESPONSE FROM AND CORRESPONDED WITH D. DONNELLON REGARDING FORENSIC IMAGE OF WEBSITE SOLUTIONS LAPTOP. CONFERRED WITH RECEIVER REGARDING SAME. REVIEWED LETTER FROM LENDER REGARDING SALE OF OJAI PROPERTY. CONFERRED WITH RECEIVER REGARDING SAME.

.8

02/10/2014 BRZ

REVIEWED CORRESPONDENCE FROM P. DEADY REGARDING TURNOVER OF FORENSIC IMAGE OF WEBSITE SOLUTIONS LAPTOP. BEGAN WORK ON MOTION TO SELL REAL PROPERTY, INCLUDING RESEARCHING FACTUAL BASIS.

3.4

02/12/2014 BRZ

DRAFTED MOTION FOR SALE OF REAL PROPERTY AND DECLARATION IN SUPPORT OF SAME. RESEARCHED APPLICABLE LEGAL STANDARDS SUPPORTING JUDICIAL SALE OF REAL PROPERTY BY RECEIVER.

5.2

02/13/2014 BRZ

REVIEWED AND ANALYZED IRS SUBPOENAS REQUESTING DOCUMENTS REGARDING TRUSTAR AND K. TRUDEAU. CORRESPONDED WITH RECEIVER REGARDING SAME. DRAFTED MOTION FOR SALE OF REAL PROPERTY. CORRESPONDED WITH RECEIVER REGARDING SUPPORTING EVIDENCE. RESEARCHED APPLICABLE LEGAL STANDARDS SUPPORTING JUDICIAL SALE OF REAL PROPERTY BY RECEIVER.

6.4



7

02/14/2014 BRZ

REVIEWED CORRESPONDENCE WITH FTC AND COUNSEL FOR K. TRUDEAU REGARDING COMPLIANCE WITH RECEIVERSHIP ORDER. CONFERRED WITH RECEIVER REGARDING . RESEARCHED LEGAL STANDARDS GOVERNING JUDICIAL SALE OF REAL PROPERTY BY RECEIVER.

2.8

02/16/2014 BRZ

REVIEWED NOTICE OF APPEAL AND RELATED DOCUMENTS FILED BE PROPOSED INTERVENORS. CONFERRED WITH RECEIVER REGARDING SAME. COORDINATED WITH IRS REGARDING RESPONSE TO SUBPOENAS.

.4

02/17/2014 BRZ DRAFTED MOTION TO APPROVE SALE OF REAL PROPERTY AND SUPPORTING DECLARATION. CORRESPONDED WITH RECEIVER REGARDING SAME.

5.4

02/18/2014 BRZ

CONFERRED WITH RECEIVER REGARDING SALE MOTION AND SUPPORTING DECLARATION. REVISED SAME. DRAFTED MOTION FOR APPROVAL OF RECEIVERSHIP FEES AND EXPENSES.

4.2

02/19/2014 BRZ

FINALIZED MOTION TO SELL REAL PROPERTY AND SUPPORTING DECLARATION BY K. JOHNSON. COORDINATED FILING OF SAME. CONFERRED WITH RECEIVER REGARDING SAME. REVIEWED AND ANALYZED PROPOSED INTERVENORS APPELLATE MOTION FOR INJUNCTION TO STAY SALE OF GIN ASSETS PENDING APPEAL.

6.3

02/20/2014 BRZ

CORRESPONDED WITH C. RICHMOND REGARDING MOTION FOR SALE OF REAL PROPERTY AND SUPPORTING DECLARATION. CORRESPONDED WITH COUNSEL FOR K. TRUDEAU REGARDING MOTION TO SELL REAL AND PERSONAL PROPERTY. CONFERRED WITH RECEIVER REGARDING SAME. DRAFTED MOTION FOR APPROVAL OF FEES AND EXPENSES. CORRESPONDED WITH COUNSEL FOR OWNER OF OAK BROOK PROPERTY REGARDING MOTION TO SELL PERSONAL PROPERTY AND STORAGE OF PERSONAL PROPERTY.

3.8

02/24/2014 BRZ CORRESPONDED WITH COUNSEL FOR K. TRUDEAU REGARDING PERSONAL PROPERTY INVENTORY AND SALE. CONFERRED WITH RECEIVER REGARDING SAME.

.3



8

02/25/2014 BRZ

ATTENDED HEARING ON MOTION TO APPROVE SALE OF REAL PROPERTY. CONFERRED WITH RECEIVER REGARDING SAME. DRAFTED PROPOSED ORDER APPROVING SALE OF REAL PROPERTY. CONFERRED WITH COUNSEL FOR K. TRUDEAU AND FTC REGARDING TERMS OF ORDER. REVIEWED SEVENTH CIRCUIT ORDER DENYING MOTION FOR STAY. CONFERRED WITH RECEIVER REGARDING SAME. CONFERRED WITH RECEIVER REGARDING

4.7

02/26/2014 BRZ

CORRESPONDED AND CONFERRED WITH COUNSEL FOR K. TRUDEAU AND FTC REGARDING AGREED ORDER ON SALE OF PERSONAL PROPERTY. RESEARCHED APPLICABLE BANKRUPTCY EXEMPTIONS AND TERMS OF RECEIVERSHIP ORDER. CONFERRED WITH RECEIVER REGARDING SAME. REVISED TERMS OF AGREED ORDER.

3.8

02/27/2014 BRZ

CORRESPONDED AND CONFERRED WITH COUNSEL FOR K. TRUDEAU AND FTC REGARDING AGREED ORDER ON SALE OF PERSONAL PROPERTY. FINALIZED AGREED ORDER. CONFERRED WITH RECEIVER REGARDING SAME. CONFERRED WITH RECEIVER AND COUNSEL FOR K. TRUDEAU REGARDING MIGROS BANK ACCOUNT.

2.6

02/28/2014 BRZ CONFERRED WITH RECEIVER AND CHAMBERS REGARDING ENTRY OF ORDER APPROVING SALE OF PERSONAL PROPERTY.

.4

03/03/2014 BRZ CONFERRED WITH RECEIVER REGARDING CONFORMED COPIES OF ORDER APPROVING SALE OF REAL PROPERTY PER LENDERS REQUEST.

.5

03/04/2014 BRZ COORDINATED WITH RECEIVER

.5

03/05/2014 BRZ

DRAFTED MOTION TO COMPEL TURNOVER OF FORENSIC IMAGE OF WEBSITE SOLUTIONS LAPTOP. RESEARCHED RELATED LEGAL STANDARDS. COORDINATED WITH RECEIVER

CONFERRED WITH IRS AGENT REGARDING RESPONSE TO SUBPOENA.

4.2



9

03/06/2014 BRZ

DRAFTED MOTION TO COMPEL TURNOVER OF FORENSIC IMAGE OF WEBSITE SOLUTION LAPTOP. REVIEWED CORRESPONDENCE AND ACCOMPANYING DOCUMENTS FROM COUNSEL FOR K. TRUDEAU REGARDING MIGROS BANK ACCOUNT. CONFERRED WITH RECEIVER REGARDING

. RESEARCHED RELATED LEGAL STANDARDS AND LOCAL PROCEDURE. DRAFTED CORRESPONDENCE TO CALIFORNIA DISTRICT COURT WITH CERTIFIED COPIES OF SALE ORDER. DRAFTED LETTER TO TITLE COMPANY REGARDING CONCERNS OVER JURISDICTION OF COURT TO ENTER SALE ORDER. TELEPHONE CONFERENCES WITH FORMER COUNSEL FOR WEBSITE SOLUTIONS REGARDING TURNOVER OF FORENSIC IMAGE OF LAPTOP.

7.2

03/07/2014 BRZ

REVIEWED DOCKETING STATEMENT FILED BY PROPOSED INTERVENORS IN APPEAL. MET WITH IRS AGENT REGARDING RESPONSE TO SUBPOENA. CONFERRED WITH RECEIVER REGARDING

. REVISED LETTER REGARDING SAME. COORDINATED WITH FTC REGARDING RELEASE OF FTC ABSTRACT OF JUDGMENT WITH RESPECT TO OJAI PROPERTY. FINALIZED MOTION TO COMPEL TURNOVER. TELEPHONE CONFERENCE AND CORRESPONDENCE WITH FORMER COUNSEL FOR WEBSITE SOLUTIONS SETTLING ISSUES REGARDING TURNOVER OF FORENSIC IMAGE OF LAPTOP.

6.8

03/10/2014 BRZ

TELEPHONE CONFERENCE WITH RECEIVER AND FORMER COUNSEL FOR WEBSITE SOLUTIONS REGARDING TECHNICAL ISSUES FOR REVIEW OF LAPTOP FORENSIC IMAGES. DRAFTED SETTLEMENT AGREEMENT MEMORIALIZING TERMS REGARDING TURNOVER OF LAPTOP. CORRESPONDED WITH TITLE COMPANY REGARDING LENDERS CONCERNS WITH SALE OF OJAI PROPERTY.

3.2

03/11/2014 BRZ CORRESPONDED WITH RECEIVER AND COUNSEL FOR FTC REGARDING WITHDRAWAL OF ABSTRACT OF JUDGMENT IN CONNECTION WITH SALE OF OJAI PROPERTY.

.3



10

3/12/2014 BRZ

CORRESPONDED WITH FORMER COUNSEL FOR WEBSITE SOLUTIONS AND RECEIVER REGARDING SETTLEMENT AGREEMENT. COORDINATED FINALIZATION OF FTC RELEASE WITH TITLE COMPANY AND RECEIVER. CORRESPONDED WITH RECEIVER REGARDING SALE OF PERSONAL PROPERTY IN OAK BROOK. REVIEWED STATEMENT FILED BY TRUDEAU IN CONNECTION WITH SENTENCING REFERENCING RECEIVERS CONDUCT. ADVISED RECEIVER REGARDING SAME. COORDINATED WITH K. TRUDEAUS COUNSEL AND RECEIVER REGARDING SHIPMENT OF PERSONAL ITEMS EXEMPTED FROM SALE.

.8

03/13/2014 BRZ

TELEPHONE CALL WITH VENDOR REGARDING REVIEW OF FORENSIC IMAGE OF WEBSITE SOLUTIONS LAPTOP. REVIEWED ENGAGEMENT LETTER. CONFERRED WITH RECEIVER AND COURT REGARDING STATUS OF RECORDING OF SALE ORDER IN CENTRAL DISTRICT OF CALIFORNIA. REVIEWED CORRESPONDENCE FROM TITLE COMPANY UNDERWRITER REGARDING SALE OF OJAI PROPERTY. ADVISED RECEIVER REGARDING RESPONSE. TELEPHONE CONFERENCE WITH FTC AND RECEIVER REGARDING CASE STATUS.

1.3

03/14/2014 BRZ

FINALIZED MOTION TO APPROVE FEES AND EXPENSES AND COORDINATED FILING OF SAME. REVIEWED FTCS STATEMENT IN ADVANCE OF STATUS HEARING. CONFERRED WITH RECEIVER REGARDING SAME.

2.7

03/17/2014 BRZ FINALIZED RECEIVERS STATUS REPORT AND COORDINATED FILING OF SAME.

2.3

03/18/2014 BRZ

PREPARED FOR STATUS HEARING, INCLUDING REVIEW OF RELEVANT PLEADINGS. CONFERRED WITH RECEIVER REGARDING SAME . DRAFTED CONSENT TO ORDER APPROVING SALE OF REAL PROPERTY FOR SIGNATURE BY K. TRUDEAU. CONFERRED WITH COUNSEL FOR K. TRUDEAU REGARDING SAME.

5.6

03/19/2014 BRZ

REVIEWED CORRESPONDENCE FROM K. TRUDEAU COUNSEL REGARDING ST. GEORGE BANK. ATTENDED STATUS HEARING ADDRESSING INCARCERATION ISSUES. CONFERRED WITH RECEIVER REGARDING SAME. MET WITH J. COHEN REGARDING STATUS HEARING.

4.2



11

03/20/2014 BRZ COORDINATED WITH RECEIVER REGARDING ADDITIONAL SUPPORT FOR TITLE COMPANY IN SUPPORT OF SALE OF OJAI REAL PROPERTY.

.3

03/25/2014 BRZ

REVIEWED MOTION TO DISMISS APPEAL FILED BY PROPOSED INTERVENORS. TELEPHONE CONFERENCE WITH RECEIVER REGARDING

RESEARCHED LEGAL STANDARDS REGARDING SALE OF ASSETS FREE AND CLEAR. CORRESPONDED WITH RECEIVER REGARDING SAME.

5.7

03/30/2014 BRZ DRAFTED ASSET PURCHASE AGREEMENT IN CONNECTION WITH SALE OF GIN ASSETS. RESEARCHED RELATED LEGAL STANDARDS REGARDING SAME.

3.2

03/31/2014 BRZ DRAFTED ASSET PURCHASE AGREEMENT IN CONNECTION WITH SALE OF GIN ASSETS.

3.5

04/1/2014 BRZ


REVIEWED CORRESPONDENCE AMONG RECEIVER AND COUNSEL FOR K. TRUDEAU REGARDING WILLIAM HILL ACCOUNT. TELEPHONE CONFERENCE WITH RECEIVER REGARDING

DRAFTED ASSET PURCHASE AGREEMENT.

4.5

04/02/2014 BRZ

RESEARCHED

. CORRESPONDED AND CONFERRED WITH RECEIVER AND TRANSACTION COUNSEL REGARDING SAME.

6.4

04/03/2014 BRZ DRAFTED MOTION FOR APPROVAL OF SALE OF GIN ASSETS. RESEARCHED APPLICABLE LEGAL STANDARDS.

6.3

04/07/2014 BRZ DRAFTED MOTION FOR APPROVAL OF SALE OF GIN ASSETS AND SUPPORTING DECLARATION.

5.4

04/08/2014 BRZ REVIEWED ASSET PURCHASE AGREEMENT. CORRESPONDED WITH RECEIVER AND TRANSACTION COUNSEL REGARDING SAME.

1.3



12

04/09/2014 BRZ

TELEPHONE CONFERENCE WITH RECEIVER AND TRANSACTION COUNSEL REGARDING

. DRAFTED NOTICE PROCEDURES MOTION. RESEARCHED

.

2.1

04/11/2014 BRZ REVIEWED ILLINOIS DEPARTMENT OF LABOR NOTICE OF WAGE CLAIM. CONFERRED WITH RECEIVER REGARDING SAME.

1.4

04/14/2014 BRZ

CONFERRED WITH J. HILTZ REGARDING RESEARCH OF LEGAL STANDARDS RELATING TO ILLINOIS REQUIREMENT RELATING TO

.

.8

04/14/2014 JFH RESEARCHED ILLINOIS WAGE PAYMENT AND COLLECTION ACT

. .4

04/15/2014 BRZ DRAFTED PROPOSED SALE NOTICE. RESEARCHED NOTICE REQUIREMENT FOR JUDICIAL SALES OF ASSETS FREE AND CLEAR OF LIENS.

2.3

04/16/2014 JFH CONFERRED WITH D. STEVENS REGARDING POSSIBLE DEFENSES TO WAGE CLAIM.

.6

04/16/2014 BRZ

CONFERRED WITH ILLINOIS DEPARTMENT OF LABOR REGARDING EXTENSION OF TIME TO RESPOND TO WAGE CLAIM. DRAFTED MOTION TO APPROVE NOTICE PROCEDURES.

2.3

04/17/2014 BRZ

REVIEWED MATERIALS RELATING TO SALE OF GIN ASSETS PROVIDED BY RECEIVER, INCLUDING FINAL ASSET SALE AGREEMENT. CONFERRED WITH RECEIVER REGARDING

. DRAFTED MOTION TO APPROVE NOTICE PROCEDURES AND SALE NOTICE.

5.2

04/18/2014 BRZ

DRAFTED MOTION TO SET FINAL HEARING AND APPROVE THE FORM AND MANNER OF NOTICE, INCLUDING SUMMARY OF PRINCIPLE TERMS OF SALE. CORRESPONDED WITH RECEIVER REGARDING SAME.

4.2



13

04/21

trudeau civil case document 865 0 and exhibits receivers third motion for interim approval of fees...

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