Trudeau Civil Case Document 812 0 and Exhibits Receivers Sur Reply to Intervenors 01-27-14

8/13/2019 Trudeau Civil Case Document 812 0 and Exhibits Receivers Sur Reply to Intervenors 01-27-14

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GIN Network Truth (the smart group)

UNITED STATES DISTRICT COURT FOR

THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

FEDERAL TRADE COMMISSION,

Plaintiff,

v.

KEVIN TRUDEAU,

Defendant.

)

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)

)

)

)

)

)

)

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

H!n. R!(et *. +ettlean

RECEIVER-S MOTION FOR LEAVE TO FILE SUR%REPL

OPPOSIN+ PROPOSED INTERVENORS- MOTION TO INTERVENE

Robb Evans & Associates LLC (the Receiver), the court appointed receiver of the

assets of Keven Trudeau and the Trudeau Entities et al, hereb! respectfull! "ove for leave

(#otion) to file its $ur%Repl! pposin' roposed ntervenors* #otion to ntervene, a cop! of

+hich is attached hereto as Ehibit - n further support of its #otion, the Receiver states.

- n /ove"ber -0, 12-3, err! Kiral! and certain other "e"bers of the 4lobalnfor"ation /et+or5 (collectivel!, the roposed ntervenors), filed their #otion to ntervene

ursuant to 6RC 17 (the #otion to ntervene)

1 8urin' a /ove"ber 1-, 12-3 status hearin', the Court entered a briefin' schedulea'reed to b! the parties the "ade responses to the #otion to ntervene due on 8ece"ber 12,

12-3, and replies due on 9anuar! -:, 12-7 ;85t


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GIN Network Truth (the smart group)1

substantiall! duplicative response, the Receiver filed a brief state"ent ?oinin' the 6TC*s

response on #onda!, 8ece"ber 13, 12-3

7 The roposed ntervenors filed their repl! on 9anuar! 12, 12-7 n their repl!, theroposed ntervenors launch a ne+ attac5 on the Receiver*s "ana'e"ent of 4/, includin'

attachin' a ne+ affidavit raisin' additional alle'ations re'ardin' the Receiver*s actions 6or

ea"ple, the roposed ntervenors "isleadin'l! alle'e, a"on' other thin's, that the Receiver

has infor"ed "e"bers that the Receiver intends to shut%do+n 4/, that the Receiver has

censored 4/*s +ebsite, and has i"properl! ecluded "e"ber*s access to the 4/ resources

The roposed ntervenors also attach an affidavit +ron'l! clai"in' that the Receiver has

threatened le'al action a'ainst 4/ "e"bers si"pl! for cancelin' their "e"bership The

Receiver stron'l! disputes these clai"s and see5s leave to file the attached sur%repl! to set the

record strai'ht Absent an! sho+in' that the roposed ntervenors have an! le'al ri'ht to

substitute their business ?ud'"ent for that of the Receiver, the roposed ntervenors* attac5s on

the Receiver are of little relevance, ecept that such "isinfor"ation ris5s har"in' the

receivership estate b! further under"inin' 4/*s relationship +ith its client%"e"bers

@ Additionall!, since ?oinin' the 6TC*s response, the Receiver has beco"e a+arethat #r Kiral!, the lead proposed intervenor, has been ca"pai'nin' to encoura'e other 4/

"e"bers to cancel their "e"berships and ?oin a co"petin' club that he is for"in' in order to

har" the value of 4/ and drive do+n the price that he +ould have to pa! to purchase 4/ or its

assets The Receiver thus also see5s to file its sur%repl! for the purpose of "a5in' a record of

these additional facts, +hich cast substantial doubt re'ardin' the roposed ntervenors* true

interests in this liti'ation

Case: 1:03-cv-03904 Document #: 812 Filed: 01/27/14 Page 2 of 4 PageID #:14749


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CERTIFICATE OF SERVICE

, Blair R Dani', an attorne!, hereb! certif! that, on the 1:thda! of 9anuar!, 12-7,

caused a true and correct cop! of the fore'oin' Receiver*s #otion for Leave to 6ile $ur%Repl!

pposin' roposed ntervenors* #otion to ntervene to be served throu'h the Court*s Electronic

Case 6ilin' $!ste" on the follo+in'.

Ki"ball Richard Anderson

5andersonI+instonco"

Tho"as Lee Kirsch,

t5irschI+instonco"

Katherine E Rohlf

5cros+ellI+instonco"

#ichael #ora

""oraIftc'ov

9onathan Cohen

9cohen1Iftc'ov

A"anda B Kostner

a5ostnerIftc'ov

8avid *Toole

dotooleIftc'ov

Ti"oth! A $hi"5otashi"5oI'"ailco"

8aniel $tephen $hi"5o8shi"5o2@I'"ailco"

Andre+ 4ordonab'I'ordonla+ltdco"

9ustin $cheiddebrabuettnerIaolco"

s Blair R Dani'



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EXHIBIT 1

Case: 1:03-cv-03904 Document #: 812-1 Filed: 01/27/14 Page 1 of 10 PageID #:14752


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UNITED STATES DISTRICT COURT FOR

THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

FEDERAL TRADE COMMISSION,

Plaintiff,

v.

KEVIN TRUDEAU,

Dfn!ant.

"

""

"

"

"

"

"

"

"

Ca# N$.% &'(C(')&*

H$n. R$+t -. ttl/an

RECEIVER0S SUR(REPL IN OPPOSITION TO

PROPOSED INTERVENORS0 MOTION TO INTERVENE

In their reply, the Proposed Intervenors grossly mischaracterize the Receivers

management of GIN apparently to create the sense of some false crisis requiring intervention

notwithstanding that the Proposed Intervenors fail to demonstrate any actual legal interest in GIN

that would afford them the right to sustitute their usiness !udgment for the Receivers" Indeed,

as detailed in the #$%s Response and ignored in the Proposed Intervenors Reply, the

&emership 'greement entered into y the Proposed Intervenors ma(es clear that eing a

memer of GIN confers no ownership interest in GIN or legal right to control any of GINs

educational materials" )See #$% Response *+(t" -.-/ at 012"3

Nevertheless, y perpetuating the misinformation aout the Receivers management of

GIN, the Proposed Intervenors undermine GIN and correspondingly damage the receivership

estate" In fact, contrary to the Proposed Intervenors assertions, the Receiver has wor(ed

diligently to manage GIN with the e4pressed intent of enaling GIN to continue as a legally and

financially viale organization providing its memers )i.e.its customers3 with various

educational and social enefits" 's detailed elow, while purporting to act in this case out of a



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desire to continue the educational and social enefits of GIN )despite having no cognizale

ownership interest in GIN3, one of the Proposed Intervenors has actively campaigned out of

court to encourage other GIN memers to cease paying their dues to GIN to force the Receiver to

sell GINs assets to his newly formed competing clu at favorale prices" 6uch efforts further

elie the e4istence of any valid reason to permit intervention here and the %ourt should

accordingly deny the &otion"

I. THE RECEIVER HAS MANAED INSO THAT IT MA CONTINUE TO OPERATE AS ALEALL AND FINANCIALL VIABLE ORANI2ATION.

A. Rat3 T3an S34t IN D$5n, t3 R6iv Intn!# t$ Sta+ili7 IN S$ T3ata N5 O5n Can C$ntin4 t$ O8at IN L9all:.

$he Proposed Intervenors mislead the %ourt y claiming that the Receiver has informed

GIN memers that the Receiver 7intends to shut down GIN and sell off its assets"8 )Reply at 5"3

$he Proposed Intervenors have failed to cite a single instance in which the Receiver ever told

GIN memers that it intended to shut down GIN" In fact, the Receiver stated the opposite, i.e.

that the Receiver is wor(ing to preserve GIN as a going concern" $he Receiver wrote to GINs

memers9 7It is the Receivers hope that GIN will survive as a true clu and ecome financially

stale so that it can continue in operation for many years to come"8 )See :4" ' );5


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$o that end goal of preserving GIN as a going concern, the Receiver is mindful of the

%ourts order that the Receiver is authorized to operate GIN 7only to the e4tent it is possile to

operate such usiness legally and profitaly"8 )Receivership >rder *+(t" ?25/ at @ A);53"3

$hus, the Receiver has made changes to GINs mar(eting materials to eliminate false and

deceptive claims as well as unsustantiated income claims that the former $rudeau1controlled

regime used, including claims that GIN is a 7perpetual money ma(ing machine8 and that its

educational materials were endorsed y a secret international caal of thirty illionaires"

=i(ewise, the Receiver has evaluated the appropriateness of the affiliate program which had een

flagged y oth the #$% and the %ourt as a source of concern that it was an improper pyramid

scheme an 7'mway without the soap"8 Bpon reviewing the affiliate program, including the

e4pert report of Peter C" Aander Nat, an economist and one of the countrys leading e4perts on

pyramid schemes )see #$% Response *+(t" -.-/ :4" %"3, the Receiver )who includes

professionals well1e4perienced with multi1level mar(eting schemes3 e4ercised its usiness

!udgment that it was in GINs interest that the affiliate program should e discontinued"

Dy ringing GINs operations into compliance and after estalishing a month or so of

demonstrated performance post1affiliate program, the Receiver elieves that GIN will e in a

position to e sold for a fair price as a going concern" $he Receiver anticipates eing in a

position to entertain e4pressions of interest in purchasing GIN within the ne4t few wee(s"

B. -it3 t3 E;68ti$n $f a Finan6iall: In#$lvnt C4i#, t3 R6iv Ha#C$ntin4! t3 S$6ial an! E!46ati$nal A6tiviti# $f IN.

$he Proposed Intervenors assert that the Receiver has 7cancelled social and education

events that had een scheduled y the %lu and its memers"8 )Reply at ;"3 $he Proposed

Intervenors offer no specifics that would allow the %ourt or the parties to evaluate such

statements" In fact, the Receiver is only aware of having cancelled a single event9 a seven day



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cruise scheduled for Canuary 5.;2" 's the Receiver e4plained in its #irst Report filed on

6eptemer E, 5.;0 )more than 2 months ago3, the Receiver canceled the cruise ecause at the

time the Receiver assumed control of GIN there were insufficient cash receipts to pay the

outstanding F5"E million liaility necessary to go forward with the cruise" )#irst Report *+(t"

?2?1;/ at ;?1;-"3 Hhatever disappointment GINs clients may have over the cancellation, the

Proposed Intervenors have shown no grounds that would permit them to intervene and sustitute

their usiness !udgment for the Receivers regarding GINs operations"

#urther, contrary to the Proposed Intervenors most recent assertions, the Receiver has

sought to continue the remaining full slate of educational and social programs" Prior to the

Receivers involvement, GIN had retained a third party vendor, $he yrid Group, to plan and

e4ecute smaller regional social and education events on ehalf of GIN" $he Receiver has caused

GIN to continue that relationship on e4actly the same terms as it had pre1receivership" 's

reflected in the following tale ased on information provided y the yrid Group, GIN has

continued on average to hold more than a hundred educational and social events each month

during the receivership"

TABLE 1% S4//a: $f IN Evnt# D4in9 R6iv#3i8

Ma&1' ; E 5 0E 2 ;5;

S8t/+ >&1' E; 0E 0? J ;20

O6t$+ >&1' ; ;J 0? E ;;?

N$v/+ >&1' . ;5 0? 0 ;.5

D6/+ >&1' 2 ? 0; 0 -E



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$hus, with the e4ception of the money losing cruise, which the Proposed Intervenors should have

een aware was cancelled since at least early 6eptemer 5.;0, the Receiver has continued GINs

social and educational activities uninterrupted"

C. Ot3 T3an t$ R/$v Fal# an! D68tiv Clai/# F$/ IN0# A!vti#in9,t3 R6iv Ha# C$ntin4! P$vi!in9 U8!at# t$ M/+# R9a!in9

IN0# A6tiviti#.

$he Proposed Intervenors also assert without any specificity that the Receiver has

7restricted access to information and updates usually provided y the %lu"8 )Reply at ;"3 In

fact, the Receiver has not restricted access to information and updates usually provided y GIN

nor have the Proposed Intervenors identified any right to information that is eing denied them"

+uring the first wee(s of the receivership, as the Receiver was assuming control of GIN,

ordinary operations may have een interrupted" 6ince then, however, GIN has continued to send

out announcements regarding its activities on a regular asis, meaning several times a wee("

$hese announcements generally include information aout spea(ers at various regional training

events and other social and educational1oriented information as well as updates on policies and

procedures"

Relatedly, the Proposed Intervenors claim that the Receiver has 7censored the content of

GINs wesite"8 )Reply at ;"3 Decause the Proposed Intervenors did not e4plain or demonstrate

the asis of this claim, the Receiver is again left to guess to what they might e referring" In fact,

the Receiver has only modified GINs wesite to remove misleading and unsustantiated income

claims, as well as references to the affiliate program that has een discontinued as li(ely

constituting an impermissile pyramid scheme"



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GIN Network Truth (the smart group)E

D. T3 R6iv Ha# In#4! T3at IN Ha# t3 A88$8iat an! N6##a:Mana9/nt.

In their Reply, the Proposed Intervenors falsely state that the Receiver has left GIN

without management" )Reply at ;, E"3 Plainly this is not the case" 6hortly after assuming

control of GIN, the then1acting %:> of GIN resigned" $he Receiver wor(ed closely with GINs

four highest1ran(ing officers during the initial transition" $he Receiver replaced the acting %:>

with a %hief >perating >fficer" $he Receiver also laid1off the %#> of GIN ecause the

Receiver assumed control of GINs accounting functions rendering the %#>s services

duplicative" Hhere appropriate to minimize e4penses, the Receiver has susequently laid1off

several other personnel, ut at all times has ensured that GIN was appropriately managed and

staffed"

#urther, pre1receivership, GIN had two advisory oards9 one 'ffiliate 'dvisory Doard

and a &emers Doard" %omined these advisory oards had appro4imately ;0 memers"

$hese advisory oards had no formal management authority, ut served to afford GIN memers

a means to provide input to GINs management" aving terminated the affiliate program, two

separate advisory oards were no longer required" $he Receiver adopted recommendations of

GINs staff to create a new GIN Round $ale consisting of seven individuals and two alternates

elected y active memers in good standing" #ormer memers of the 'ffiliate and &emer

advisory oards currently comprise the =eadership Round $ale" $o foster communication, the

Receiver further agreed to participate in a monthly conference call with the Round $ale"

Hhether any of these changes are the asis for Proposed Intervenors vague allegations that the

Receiver has left GIN without management, the fact remains that the Receiver has duly e4ercised

its usiness !udgment to ensure the GIN has een well1managed"



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GIN Network Truth (the smart group)?

II. THE PROPOSED INTERVENORS0TRUE INTERESTS APPEAR TO BE TO SEEK TOUNDERMINE INFOR THE BENEFIT OF THEIR COMPETIN CLUB.

't the same time that the Proposed Intervenors see( to intervene in this litigation, Perry

Kiraly, the lead proposed intervenor, is see(ing to undermine GIN y suggesting to GIN

memers that they cease paying their dues and lure GIN employees away from GIN in order to

force a sale of GINs assets on advantageous terms" #or e4ample, in a Canuary J, 5.;2 email to

7#ellow GIN memers,8 &r" Kiraly writes9 76o what is the most powerful purchasing position

we can e inL Hell, in my opinion, if the GIN #+N is no longer funding the Receivers salary

and K$s fine y way of dues collectedM and there is no staff to run the clu, the Receiver would

very e inclined to sell the assets in short order to the highest idder"8 ):4" D );


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GIN Network Truth (the smart group)-

$o e certain, to the e4tent that evidence ears out efforts y an individual or individuals

to financially ruin GIN y intentionally interfering with GINs relationship with its customers in

order to suppress its value and force a fire sale of its assets, the Receiver reserves all rights to

ring appropriate claims, including for tortious interference" Notwithstanding such reservation,

out of an appreciation of the sometimes e4treme passion of GINs memership, the Receiver has

demonstrated sustantial restraint in not pressing its full array of legal remedies against a myriad

of parties that have defamed the Receiver and inappropriately interfered with the receivership";

CONCLUSION

In their Reply, as detailed aove, the Proposed Intervenors rely on a numer of

misleading allegations regarding the Receivers management of GIN" 6uch unsustantiated

rhetoric provides no asis for intervention here though perpetuating misleading information

aout GIN serves to undermine GIN and the receivership estate" Hhile the Proposed Intervenors

may disagree with the changes instituted y the Receiver as is nearly inevitale in an

organization with thousands of client1memers the Proposed Intervenors fail to estalish how

;$he Proposed Intervenors also assert that the Receiver 7restricted or cut off access to the %luswesite to several of the Intervenors"8 )Reply at ;"3 'gain, the Proposed Intervenors failed toidentify what or whose access the Receiver purportedly restricted or, more importantly, why thedenial of such access gives the Proposed Intervenors any standing here" $he Receiver is awarethat consistent with the terms of the memership agreement, GIN has suspended the memership)and thus his access to the memer area of the GIN wesite3 of Perry Kiraly ecause, amongother reasons, his conduct in encouraging other memers to cease paying their monthly dues andto !oin a competing clu violate GINs memership agreement"



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GIN Network Truth (the smart group)J

such disagreement gives them any legally cognizale interest for intervening" $he %ourt should

deny their motion to intervene"

+ated9 Canuary 5?, 5.;2 Respectfully sumitted,

ROBB EVANS = ASSOCIATES LLC,

RECEIVER

Dy9 ne of Its 'ttorneys3

Dlair R" anzig )No" E5?05J03Cohn #" iltz )No" E5-J?223Kathy Hantuch )No" E5J2.023

HILT2 -ANTUCH = 2AN2I LLC

0 Hest Cac(son Dlvd", 6uite 5.%hicago, Illinois E.E.2$elephone9 0;5"EE"J..-#a49 0;5"EE"J.;

Counsel for Robb Evans & Associates, Receiver



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EXHIBIT A



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CLICK HERE TO VIEW THIS E-MAIL AS A WEB PAGE

FOR ACCESS TO THE LINKS BELOW, PLEASE LOG IN TO YOUR GIN ACCOUNT HERE

MESSAGE FROM THE RECEIVER

Dear GIN Members:

The Receiver has been advised that certain Members of GIN have engaged in a concerted effort to

encourage other Members to discontinue payment of their monthly dues in hopes this would somehow

derail the efforts of the Receiver. The Receiver would lie to tae this opportunity to clarify our currentand future plans with regards to the operations of GIN.

!s most of you now" on !ugust #" $%&' the (.). District *ourt for the Northern District of Illinois

entered an +rder !ppointing a Receiver and Implementing !ncillary Relief ,+rder-. The +rder

appointed Robb vans / !ssociates 00* as Receiver over the assets of 1evin Trudeau" including but

not limited to Global Information Networ 2DN" 3ebsite )olutions ()!" and all Trudeau ntities

whether foreign or domestic. ! copy of the +rder can be viewed on our website at

www.robbevans.com.

)ection 4 of the +rder outlines the duties and authority of the Receiver. )ubsection &$ reads in

pertinent part" "Continue to conduct the businesses of any Trudeau Entity, but only to the extent it is

possible to operate such businesses legally and profitably..." ,mphasis added-. (nder the direction

of the Receiver" GIN has made a number of changes in its Mareting approach. These changes are

designed to meet the first criteria in )ection &$" that is" that the business must be run legally. GIN staff

is woring diligently to design an enhanced Member benefits program which includes" among other

things" the e5pansion of GIN6s accredited education curriculum" providing a wider variety of education

topics and event formats" sponsoring local and ma7or events" trainings" recognition and facilitating

networing opportunities designed for overall personal growth and improvement.

The second duty of the Receiver under )ection &$ of the +rder re8uires the Receiver to determine if

the company can be operated profitably. !ctions by a few rogue Members encouraging other

Members to stop paying dues constitutes a violation of the +rder as it interferes with the duties of the

Receiver.

It is the Receiver6s hope that GIN will survive as a true club and become financially stable so that it can

continue in operation for many years to come. !ssuming GIN can become financially stable and be

operated profitability" it is the intention of the Receiver to get permission from the *ourt to transfer GIN



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operations for a fair price to a new owner or ownership group. The Receiver6s oversight of the GIN

operations could then be terminated and GIN would be operated by the new owners.

fforts to disrupt these initiates and the continued business operations of GIN can unfairly penali9e

thousands of other Members that are currently engaged in GIN6s training system and the new Member

benefits.

The receiver supports recommendations from the GIN staff to create a new GIN Round Table made

up of seven individuals elected by active Members in good standing. Members that are loyal and

remain optimistic about the future of GIN would mae good candidates to serve on the GIN Round

Table. There are a tremendous number of rumors and misinformation being circulated by a few

Members. The Receiver recogni9es the need to support a strong interchange of ideas and information

with Members that now and understand the field. The GIN Round Table would provide a forum that

could help to defuse the rumors and present factual information. The Receiver would be willing to

participate in a monthly conference call with the GIN Round Table.

!s a reminder" the Receiver is here for the purpose of stabili9ing the organi9ation" providing guidance

so that it can be operated legally and become financially stable with the end goal being to transfer GINoperations for a fair price and end our oversight.

NOTE: CCO!#N$ TO T%E #N&O!'T#ON $T%E!E () T%E !ECE#*E! O& T%E $+O(+ #N&O!'T#ON NETO!-, T%EENT#T) !E&E!!E TO T%E $#N CO/NC#+ OE NOT E0#T N T%E!E&O!E N) !E&E!ENCE O! ENO!E'ENT O&T%# ENT#T) () N) O& T%E $+O(+ #N&O!'T#ON NETO!-1 2!E*#O/ T!#NE!3%OT %O/+ NOT (E#NTE!2!ETE N ENO!E'ENT, (ENET O! 2!T O& T%E T!#N#N$ C/!!#C/+/' O& T%E $#N O!$N#4T#ON. $#N1&+#TE 2!O$!' ') +O (E !E&E!!E TO #N 2T T!#N#N$ O! E/CT#ON+ 'TE!#+. $#N1 &+#TE2!O$!' O&C#++) EN ON NO*E'(E! 56, 7685.

CLICK HERETO AVOID RECEIVING FUTURE E-MAILS FROM US.

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18/27


EXHIBIT B



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SWGF Update: PERRY KIRALY

January 9, 2014

Dear Fellow GIN Members,

It has come to my awareness that the biggest uestion among the Members

!resently is regar"ing the !urchase o# GIN or GIN IP$Intellectual Pro!erty i%e% the

&uccess Mastery 'ourses an" other au"io, (i"eo an" written material owne" by

GIN FDN)%

*s most o# you are aware, the !urchase o# GIN+s I $only) has been an" still is

among the !ro!ose" agen"as o# &-GF.-IN, but #orm the most !ower#ul

negotiating !osition we can be in%

&o what is the most !ower#ul !urchasing !osition we can be in/ -ell, in my

o!inion, i# the GIN FDN is no longer #un"ing the ecei(er+s salary an" +s #ine

by way o# "ues collecte"3 an" there is no sta## to run the club, the ecei(er woul"

(ery be incline" to sell the assets in short or"er to the highest bi""er%

Now some ha(e suggeste" that they might ust shut the club "own i# it sto!s

ma5ing money3 out o# s!ite/ hough I truly "oubt that the ecei(er, out o# s!ite,

woul" not try to sell a thing that ha" some (alue3 i# they "i" an" as5e" the court

to ust shut GIN FDN "own an" aban"one" it 6 goo", then we get the I #or #ree%

7n"erstan" also why "o we not want to buy an" continue to use GIN FDN as our

legal entity an" ha(e begun the !rocess o# establishing -IN or the -orl"

In#ormation Networ5 as that new entity/ 8ne, is because GIN FDN is ri""le"

with legal liabilities% wo, is that so much negati(e !ress now surroun"s that

name it coul" !ro(e "etrimental to #uture recruitment o# members% *n" three, as



20/27


Mr% &him5o !ointe" out, the name GIN coul" be challenge" by a News *gency

that has been using that name #or many years be#ore GIN was establishe"%

&o, can we $all the Members o# the club) get together to stan" as 8ne an" !ool

our resources to buy the I/

e!resenting &-GF.-IN, I communicate" with Greg ramer who re!resente"

himsel# as the s!o5esman #or the ecei(er en"orse" oun" able: grou!% I

communicate" with him in an attem!t to unite all members as one an"

accom!lish a !ower#ul negotiating !osition as mentione" abo(e% I ma"e it clear

that that a#ter months o# (ery har" wor5 an" a substantial amount o# Members

contributions, &-GF.-IN has e(erything in !lace #or this ne;t ste! to ta5e !lace00 Members an" counting

that ha(e reueste" to be !lace" on the lainti## list, !lus other

contributors that ha(e not as yet reueste" to be on the list%

I #urther o##ere" to Mr% ramer an" the entire ecei(er ?n"orse" oun" able

grou!, who ha(e yet to i"enti#y themsel(es3 I o##e" to arrange a con#erence call

with our attorney, imothy &him5o, whom I hire" to re!resent all GIN Members% I

o##ere" this to allow all o# these oun" able !artici!ants the o!!ortunity to

communicate with our attorney an" as5 any uestion they "esire" to clari#y

anything they were unclear about regar"ing what we+(e "one so #ar or !lan to "o

#rom this !oint on%



21/27


Mr% ramer tol" me yester"ay e(ening that he woul" relay this o##er to the

entirety o# the oun" able grou! an" get bac5 to me% &e(eral hours ago, I

recei(e" Mr% ramer+s re!ly% @e state" that there is no nee" #or him an" his

oun" able grou! to s!ea5 with Mr% &him5o #or they #elt that the o!inion letter I

sent out by Mr% &him5o this morning was uite clear an" that he, Greg ramer,

was going to get another o!inion%

&o while Mr% ramer gets his other o!inion be#ore he an" the oun" able grou!

can "eci"e to oin with &-GF.-IN to !urchase the I assets an" create a

!ower#ul negotiating #orce o# One#or all Members3 let me o##er you something #or

"ee! consi"eration regar"ing this situation%

&ome suggest that it a!!ears to be a choice between starting a new club or

buying GIN FDN an" its assets% It isn+t% * new legal entity is necessary #or

whate(er grou! !urchases the I assets #or the reasons liste" at the bottom o#

!age 1 o# this u!"ate%

&o the only thing that will e(en necessitate a choice re(ol(es aroun" whether

Greg an" oun" able crew choose to stan" as 8ne with &-GF.-IN in the

!urchase o# the IAassets%

&houl" Greg an" oun" able crew choose not to stan" as 8ne with

&-GF.-IN then what criteria "oes one utiliBe in their e(aluation o# who to sen"

#un"s to/ his may seem li5e a "i##icult choice to ma5e3 it isn+t when you

consi"er the #ollowingo

tash&>oB'a&$.#o

an&!$ St!(h!n Sh&>o

sh&>o0=B'a&$.#o

Andr! ordon

a%'B'ordon$a$td.#o

Just&n S#h!&d

d!%ra%u!ttn!rBao$.#o

6s6 5$a&r *. 7an8&'



27/27

6s6 5$a&r *. 7an8&'


Documents

Trudeau Civil Case Document 812 0 and Exhibits Receivers Sur Reply to Intervenors 01-27-14