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UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
UNITED STATES OF AMERICA, )
Plaintiff, )) Case No. 10-CR-00886v. )
) Honorable Ronald A. GuzmanKEVIN TRUDEAU, )
Defendant. )____________________________________
MOTION TO ALLOW DEFENDANT KEVIN TRUDEAU TO TRAVEL
INTERNATIONALLY AND FOR TEMPORARY RETURN OF HIS PASSPORT
Defendant Kevin Trudeau, by and through his attorneys, respectfully moves this Court
for an order permitting Trudeau to travel internationally from July 23, 2013 through July 29,
2013, and for an order directing Pretrial Services to temporarily return Trudeaus passport to
him. In support of this motion, the defendant states as follows:
1. On June 27, 2013, this Court held an arraignment of Trudeau, and ordered him tosurrender his U.S. and Italian passports to Pretrial Services. Trudeau complied with that Order.
2. On July 1, 2013 this Court entered an order setting conditions of release as toTrudeau, and entered a secured bond as to Trudeau in this amount of $209,000, which is secured
by a piece of property owned by Trudeaus parents. Pretrial Services remained in possession of
Trudeaus passports. The Court noted that Trudeau would need to seek Court permission before
being allowed to travel internationally.
3. Also on July 1, 2013, this Court approved Trudeau to travel internationally toCanada from July 1 through July 9, 2013 on business. Trudeau promptly returned his passport to
Pretrial Services upon his return on July 10, 2013.
4. Trudeau is scheduled to speak at the Dolder Grand Hotel in Zurich, Switzerland
on July 26 through July 28, 2013. (Ex. 1, Devine Decl. at 2-3.) Around 160 people have
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purchased tickets to attend that seminar, which is being put on by the Global Information
Network. (Id. at 2, 4.) The attendees are traveling from over nine different countries and
have already booked their travel. (Id. at 4-5.) Each attendee has prepaid between $3,399 to
$5,599 to attend this conference. (Id. at 4.) If Trudeau is unable to fulfill his obligation, the
attendees will be the injured parties, losing money on travel expenses. (Id. at 5.)
5. The Global Information Network would also suffer substantial losses. (Id. at 6.)
The Hybrid Group, the company that is producing this conference, has coordinated and executed
numerous contracts on behalf of the Global Information Network, and the Global Information
Network has paid expenses in connection with these contracts. (Id.
) The vast majority of
expenses have been paid up front, including hotel accommodations, food and beverage,
entertainment, transportation, printing services, etc. (Id.) Because these contracts are already in
place and the vast majority of expenses have been prepaid, if this event were cancelled the
Global Information Network would lose all of the money already paid for travel expenses, food
and beverage expenditures for attendees, all hotel occupancy charges and taxes, audio/visual
production, translation services, transportation of attendees and staff, tours for attendees, printing
of conference materials, staff time, shipping of conference supplies, website development, etc.
(Id.) The Global Information Network will easily suffer over $500,000 in losses if Trudeau is
unable to attend this conference and the event is cancelled. (Id.)
6. In addition, if the Global Information Network cancels the conference, The
Hybrid Group would be under an obligation to issue refunds to all customers. (Id. at 7.) This
would mean that The Hybrid Group would have to refund all money received back to customers,
and then pay an additional 3-4% in processing charges. (Id.) This will likely result in around
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$30,000 in processing charges. (Id.) Either The Hybrid Group or the Global Information
Network will incur this $30,000 loss if the event is cancelled. (Id.)
7. Trudeau is a motivational speaker and his livelihood depends on his ability totravel and give seminars. As such, it is vital that Trudeau be allowed to travel to Zurich,
Switzerland to give this seminar. Trudeaus employment would be in jeopardy if he were not
allowed to travel.
8. Due to potential jetlag complications and Trudeaus need to prepare on-site forthe conference, he asks to be permitted to fly to Zurich in advance of the conference on the
evening of July 23, 2013. He will return immediately after the conference on July 29, 2013. If
this Court grants Trudeaus motion, Trudeau will provide his travel itinerary as well as his
contact information to the U.S. Attorneys Office, as well as to Pretrial Services.
9. Judge Gettleman set a hearing in Case No. 03-3904 for July 26, 2013 at 2:00 p.m.Trudeau was ordered to attend this hearing. Trudeau has moved to continue the July 26, 2013
hearing or, in the alternative, to waive Trudeaus appearance at that hearing. Judge Gettleman
has not yet ruled on that motion. Trudeau requests that, in the event that his motion before Judge
Gettleman is granted, Trudeau be allowed to travel to Zurich, Switzerland to fulfill his
obligations to his employer.
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WHEREFORE, Trudeau respectfully requests that this Court grant his motion, allow him
to travel to Zurich, Switzerland from July 23 through July 29, and direct Pretrial Services to
temporarily return Trudeaus passport to Mr. Trudeau. A proposed order is attached hereto as
Exhibit 2.
Dated: July 18, 2013.
Respectfully submitted,
KEVIN TRUDEAU
By: /s/ Thomas L. Kirsch IIOne of His Attorneys
Kimball R. Anderson ([email protected])Thomas L. Kirsch II ([email protected])Katherine E. Rohlf ([email protected])WINSTON & STRAWN LLP35 West Wacker DriveChicago, Illinois 60601312-558-5600
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CERTIFICATE OF SERVICE
I, Thomas L. Kirsch II, an attorney, hereby certify that on July 18, 2013, I caused to beserved true copies of MOTION TO ALLOW DEFENDANT KEVIN TRUDEAU TO TRAVELINTERNATIONALLY AND FOR TEMPORARY RETURN OF HIS PASSPORT, and
accompanying exhibits by filing such document through the Courts Electronic Case FilingSystem, which will send notification of such filing to:
Marc KrickbaumApril PerryUnited States Attorneys Office219 South Dearborn StreetSuite 500Chicago, Illinois 60604
/s/ Thomas L. Kirsch IIThomas L. Kirsch IIAttorney for Kevin Trudeau
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Exhibit 1
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ExhibitA
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ZurichSummerConferenceJuly2628,2013HotelInformation:TheDolderGrand
Kurhausstrasse65
8032Zurich
Switzerland
RegistrationInformation: 160paidattendees Therewillbeguestsfrom9differentcountriesattendingthisevent
o UnitedStateso Canadao Franceo Germanyo Japano Netherlandso Switzerlando Denmarko CzechRepublic
ConferenceScheduleFridayJuly26,2013PreArrangedExcursions
Schedule:
10:30departuresfromHotel
ZurichTourbycoachandonfoot
1:30 3:00Arrivalsbacktothehotel
Registration
4:00pm
WelcomeReception
5:45pm 6:45pm
General
Session
Featuring
Speaker
Mr.
Kevin
Trudeau
7:00pm
Saturday,July27,2013Breakfast
7:00am 9:00am
GeneralSessionFeaturingSpeakerMr.KevinTrudeau
9:00am12:00pm
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BuffetLunch
12:00pm1:30pm
GalaDinner&Entertainment
6:00pm10:00pm
GalaLocation:175peopleattending
Location:KaufleutenRestaurant
Pelikanplatz
8001Zurich
Switzerland
Sunday,July28,2013Breakfast
7:00am 9:00am
General
Session
9:00am12:00pmFeaturingSpeakerMr.KevinTrudeau
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Exhibit 2
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UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
UNITED STATES OF AMERICA, )Plaintiff, )
) Case No. 10-CR-00886
v. )) Honorable Ronald A. Guzman
KEVIN TRUDEAU, )
Defendant. )____________________________________
[PROPOSED] ORDER GRANTING MOTION TO ALLOW DEFENDANT KEVIN
TRUDEAU TO TRAVEL INTERNATIONALLY AND FOR TEMPORARY RETURN OF
HIS PASSPORT
This matter is before the Court on the Motion to Allow Defendant Kevin Trudeau to
Travel Internationally and for Temporary Return of his Passport (Motion). Having considered
the Motion, and being sufficiently advised, the Court hereby ORDERS that the Motion is
GRANTED. Therefore, it is hereby ORDERED that Trudeau is permitted to travel to Zurich,
Switzerland from July 23, 2013 through July 29, 2013. It is further ORDERED that Pretrial
Services temporarily return Trudeaus passport to him. Trudeau is ORDERED to return his
passport to Pretrial Services no later than July 30, 2013.
DONE this _________ day of July 2013.
_____________________________________
Hon. Ronald A. Guzman
United States District Court Judge
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