Trudeau Criminal Case Document 72 0 Main Includes 72 1 and 72 2

7/27/2019 Trudeau Criminal Case Document 72 0 Main Includes 72 1 and 72 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-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

Case: 1:10-cr-00886 Document #: 72 Filed: 07/18/13 Page 1 of 5 PageID #:460


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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

Case: 1:10-cr-00886 Document #: 72-1 Filed: 07/18/13 Page 1 of 7 PageID #:465


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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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