trudeau civil case document 759 0 and 759 1-09-30 13 ftc statement and exhibits re need for coercive...

7/27/2019 Trudeau Civil Case Document 759 0 and 759 1-09-30 13 FTC Statement and Exhibits Re Need for Coercive Sancti

1/197GIN Network Truth (the smart group)

IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

FEDERAL TRADE COMMISSION,

Plaintiff,

v.

KEVIN TRUDEAU,

Defendant.

)))

)))))))))

Case No. 03-C-3904

Hon. Robert W. Gettleman

FTCS STATEMENT REGARDING THE NEED FOR COERCIVE SANCTIONS

I. INTRODUCTIONMore than two months have passed since the Court found Trudeau in contempt a third

time. See DE729 (July 26, 2013). Since then, the Receiver has invested substantial time and

resources (that would otherwise go to consumers) attempting to untangle the morass of

intercompany transfers, offshore entities, and dubious bookkeeping that Trudeau created over the

past decade. Simply put, there is no realistic probability that the Receiver will locate the bulk of

Trudeaus assets without his cooperation, and there is zero probability that Trudeau will ever

cooperate voluntarily.1 In fact, notwithstanding the Courts unambiguous threat to replace the

more lenient approach it selected with coercive incarceration, Trudeau has violated the July 26

and August 7 Orders at least five times.2

The FTC has not moved to hold Trudeau in contempt

1As discussed further below, Trudeau purportedly could not remember any details

regarding significant new evidence the Receiver discovered indicating that Trudeau acquiredadditional gold bars (beyond the ten already known) and gold coins between 2008 and 2011, seeinfra at 6, except to say that he thought his wife had them.

2As discussed further below, these five instances include: (1) failing to disclose the

Australian account; (2) spending and transferring assets from that account; (3) destroyingdocuments; (4) failing to disclose an offshore gaming account; and (5) lying to the Receiver, asthe Receivers reports document. There are additional instances of noncooperation that theReceiver has asked the FTC not to raise because, in the Receivers view, doing so would impairthe Receivers ability to recover certain assets.

Case: 1:03-cv-03904 Document #: 759 Filed: 09/30/13 Page 1 of 12 PageID #:13355


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repeatedly because, at this stage, there is no point to doing soaccumulating additional

contempt findings will not help redress Trudeaus victims.

The continuation of the current collection plan has drained significant public resources in

a fruitless attempt to collect Trudeaus assets. Worse yet, without coercive incarceration, the

costs of the Receivership almost certainly will outstrip the assets ultimately collected. Thus, the

choice at this point is stark: either incarcerate Trudeau for however long it takes to coerce him to

turn over all the assets he controls, or continue depleting the assets available to Trudeaus

victims. In the event that the Court chooses the latter, the FTC will of course follow any order of

the Court, but it cannot continue wasting public funds chasing down the avalanche of Trudeaus

lies and deception. Unfortunately, absent coercive incarceration, there is nothing further the FTC

reasonably can do to help Trudeaus victims.

II. BACKGROUNDA. The Courts Repeated WarningsAfter a year of discovery and a full evidentiary hearing, the Court found Trudeau in

contempt of its 2010 order that he redress his victims. DE729 (July 26, 2013). The Court also

froze Trudeaus assets,3see id., and placed them in a receivership, DE742 (Aug. 7, 2013).

Although the FTC argued that Trudeau would never disclose his assets voluntarily, the Court

granted Trudeaus request that he receive, in effect, one last chance to avoid a coercive

sanction. Specifically, having studied the extensive record establishing that Trudeau hid assets

offshore as part of an elaborate effort to conceal his wealth from his victims, the Court warned

Trudeau: I would be absolutely within reason and the law and the facts of this case to

incarcerate [you] today. PXA:1 at 30:20-22.4 Although the Court accepted Trudeaus

3 Like its subsequent order, the Court warned that [f]ailure to comply with the directionscontained in this order [including the asset freeze] will result in Trudeaus immediateincarceration until such compliance is achieved. DE729 at 3 (July 26, 2013) (emphasisadded).

4 Due to the potential government shutdown, the FTC will arrange to send the Chamberscopy of this filing and the supporting exhibits to the Court via Federal Express, for anticipateddelivery on Tuesday, October 1.



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destroyed documents; (4) failed to disclose an offshore gaming account; and (5) lied to the

Receiver multiple times.

1. Non-Disclosure of the Australian AccountThe Receivership Order required Trudeau to immediately . . . deliver to the Receiver

possession and custody of . . . [a]ll [of his] funds, Assets, and property[.] DE742 at 11-12; see

also id. at 14 (restraining Trudeau from [d]oing any act or thing whatsoever that impedes the

Receivers taking custody of his assets). As the FTC and the Receiver already have brought to

the Courts attention, Trudeau directly violated the Receivership Order by failing to disclose an

Australian account containing approximately $15,000 at the time the Court entered the

Receivership Order.5 See PXA:2; FTC Br. (DE749) (Sept. 16, 2013); Receivers Supp. Report

(DE750-1) (Sept. 16, 2013).

2. Spending and Transfers from the Australian AccountThe Courts July 26 asset freeze prohibited Trudeau from transferring or spending any

money except for ordinary and necessary living expenses. DE729 at 3. As the FTC and the

Receiver already have explained, Trudeau ignored this order as well. See FTC Br. (DE749)

(Sept. 16, 2013); Receivers Supp. Report (DE750-1) (Sept. 16, 2013). Among other things,

Trudeau transferred 20,000 Australian dollars to pay tax attorneys and also spent Receivership

5As the Court already has observed, Trudeau did not disclose this account voluntarily.

His January 25, 2013 sworn financial statement provided no address for the bank, or whatcountry the bank was located in, or the account number. See DE535 at 4. Furthermore, Trudeaurepresented under oath that the account had less than $1500 net of liability. See id. At thetime, the account had more than 141,000 Australian dollars. PXA:3. Even if Trudeaus grosslydeceptive January 25 disclosure qualified as pseudo-compliance with the August 7Receivership Orderand it does notit is undisputed that he did not act affirmatively to providethe assets to the Receiver, as the Receivership Order requires. See DE742 at 11-12. Notably, insubsequent interviews with the FTC and the Receiver, Trudeau explained that he did not disclose

this account because someone purportedly loaned him the money (in an undocumentedtransaction), ostensibly to pursue gambling research. PXA at 15. Trudeau acts as though hebelieves that, ifin his mindan asset belongs to someone else, then he does not have todisclose it. By way of example, if Trudeau purchased and controls gold bars, but (in his mind)they belong to his wife, he wouldnt need to disclose where they are. In fact, as the Court willrecall, throughout his sworn financial statement, Trudeau repeatedly denied having anyknowledge whatsoever regarding his wifes assets. See DE742. Coercive incarceration wouldencourage Trudeau to rethink the distinction he apparently draws between what assets he feelsbelong to his wife and what assets he controls.



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assets at a spa, on an expensive haircut, on cigars, on alcohol, and on other expenses indefensible

as ordinary and necessary. See FTC Br. (DE749) (Sept. 16, 2013); Receivers Supp. Report

(DE750-1) (Sept. 16, 2013).

3. Destruction of DocumentsThe Receivership Order prohibits Trudeau from [d]estroying, secreting, defacing,

transferring, or otherwise altering or disposing any [of his] Documents.6

DE742 (Aug. 7, 2013)

at 13. When the Receiver interviewed Trudeau on September 18, Trudeau admitted that he had

deleted emails from his hushmail account, and further explained that he regularly deletes

99% of his email.7 PXA at 16.

4. Non-Disclosure of the Offshore Gaming AccountNotwithstanding the Receivership Orders provisions, Trudeau did not disclose an online

gaming account with offshore internet casino operator William Hill. See www.williamhill.com/

(viewed Sept. 28, 2013). The Receiver obtained records showing that the account contains

approximately 73,000 Swiss francs (worth roughly $80,000).8 PXA:4. Significantly, the records

also establish that this is not an account Trudeau opened years ago and thus might have

forgotten.9 There is significant gambling activity on the account as recently as June of this

year. Seeid.

5. Lying to the ReceiverThe Court ordered Trudeau to cooperate with the Receiverfully. DE742 (Aug. 7,

2013) (emphasis added). Suffice it to say, lying to the Receiver is non-cooperation. Putting

6 Documents include, among many things, electronic mail. See DE742 at 3-4 (Aug.7, 2013).

7 Trudeau agreed to stop deleting email, although it is unclear to the FTC whether he hascomplied with this promise. It is also unknown whether any of the deleted email can be restored,but this may be challenging given that Canadian-based hushmail markets itself as a privacy-oriented email service. See www.hushmail.com/about/ (viewed Sept. 28, 2013).

8See also www.bloomberg.com/quote/CHFUSD:CUR(viewed Sept. 30, 2013) (one

Swiss Franc is worth approximately 1.1 U.S. dollars).9

In response to the Receivers questions, Trudeau stated that someone loaned him themoney in the accountin yet another undocumented transaction. PXA at 15.



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aside all of Trudeaus many memory failures and convoluted explanations regarding his assets,

Trudeau made at least two demonstrably false statements to the Receiver. First, Trudeau told the

Receiver [t]here are no hidden assets anywhere in the world. See Receivers Supp. Report, Ex.

1 (DE750-1) (Sept. 16, 2013) (Sept. 7, 2013 email). In reality, and at minimum, he had not

disclosed his Australian account or his offshore gaming account. Second, after the Receiver

discovered the Australian account, Trudeau denied having log-in information. See Receivers

Supp. Report, Ex. 3 (Sept. 9, 2013 email) (DE750-1) (Sept. 16, 2013). In fact, Trudeau denied

having the log-in information notwithstanding the Receivers observation to him that you must

have correspondence or online access or how could you have initiated the July 29, 2013 wire

transfer? Id. Of course, Trudeau did have log-in information, which he provided to the

Receiver two days later. See Receivers Supp. Report (Sept. 16, 2013) at 2. In fact, [b]elying

any suggestion that Trudeau lacked the ability to log into the account, many transactions on the

account were Internet-based. Receivers Supp. Report (Sept. 16, 2013) at 2.

Notably, the FTC emphasizes the two misrepresentations above because they are

demonstrably false, but there is no reason to believe that most of what Trudeau has informed the

Receiver is not equally deceptive.10

10 In fact, as discussed below, the record of Trudeaus communications with the Receiveris replete with examples of stories that are implausible, bizarre, or simply not credible. Forinstance, neither the Receiver nor the FTC believes Trudeaus representation that he did notknow who is running the GIN Foundation [(GIN FDN)]. Receivers Report (747-1) (Sept. 6,2013) at 5. After the FTC presented massive evidence that Trudeau controls GIN FDN, theCourt found that he controlled GIN FDN along with the other GIN-related entities. See DE742

(Aug. 7, 2013) at 1; DE729 (July 26, 2013) at 1. Indeed, the Receiver recently filed a June 29,2012 employment agreement appointing Lee Kenny as GIN FDNs Executive Director. SeeReceivers Report (747-1) (Sept. 6, 2013), Ex. 1. Trudeaus wife, Nataliya Babenko, signed onGIN FDNs behalf, which renders Trudeaus claimed ignorance exceptionally dubious. See id.As an aside, Trudeau isnt honest even with respect to issues irrelevant to the Receivership. Inone of his interviews with the Receiver and the FTC, Trudeau bragged that he developed abaccarat system that shifts the odds from the casinos favor to the gamblers. PXA at 18.Assuming the casino plays rationally, it is not mathematically possible that Trudeau inventedsuch a system.



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C. Trudeaus Implausible Explanations Regarding His AssetsAlthough Trudeau provided the Receiver with information, most of it is useless or raises

more questions than it answers. For instance:

Gold. Trudeaus attempt to explain the gold bars he purchased illustrates theinconsistent and implausible information he has provided. As the Court mayrecall from the evidentiary hearing, Trudeau purchased ten gold bars from GoldenLion Mint in 2008, which Neil Sant personally swapped for Scotia bars ofequivalent value in October 2011. See PXA:5 (100 oz. of gold). At theSeptember 18 interview, Trudeau initially informed the Receiver that Babenkopurchased the bars on her own (she simply asked Trudeau for advice regardingwhere to buy them). PXA at 17. When confronted with evidence that themoney for the purchase came from an account in his name, see PXA:5 at 4,Trudeau stated that he may have purchased them for her as a gift, PXA at 17.Besides changing his story, it is simply not credible that someone would forgetwhether he purchased $100,000 in gold bars as a gift for his wife.

More Gold. Significantly, the Receiver located new documents stronglysuggesting that Trudeau possesses much more gold than previously understood.In particular, newly-discovered Golden Lion Mint invoices show that Trudeauswapped another 270 ounces of gold between June 13, 2011 and October 18,2011,11 PXA:6 at 3-8, and a newly-discovered email refers to the shipment ofsome of these bars as Kevins package), id. at 6 (emphasis added).12Furthermore, the Receiver discovered documents showing that $110,000 worth ofgold coins were shipped to Trudeaus Ojai, California home in October 2008.13

PXA:7. It is implausible that Trudeau doesnt know where this gold is, or that hecannot recover it from his wifes nominal possession.

Offshore Entities. In his interview with the Receiver, Trudeau stated,unbelievably, that the various offshore entities were created in part because it is

11 According to the newly-discovered invoices: 100 ounces were swapped onJune 13, 2011, see PXA:6 at 4; 70 ounces were swapped on or about June 30, 2011, seeid. at 5 (invoice referring to shipment of 70 oz. on a date to be determined); id. at 6 (emailregarding shipment of Kevins package); 30 ounces were scheduled to be swapped onAugust 8, 2011, seeid. at 5; 20 ounces were swapped on September 3, seeid. at 7; and 50ounces were swapped on October 18, 2011, seeid. at 8. Also according to the newly-discovered invoices, shipments were variously made to Sant in Westmont, to Babenko inOjai, and to Trudeau in Ojai. The invoices also refer to various silver transactions.

12 In 2012, Trudeau asked offshore asset protection advisor Michel van Roon fora place in Switzerland where I can buy gold. PXA:12. When interviewed, Trudeaustated that he inquired because he was considering locating a good source for gold inSwitzerland that he could endorse or promote to others (as opposed to a source he coulduse himself). PXA at 22.

13 Babenko is listed as the recipient. See PXA:7 at 1. The $110,043 cashierscheck used to pay for the coins was purchased by Patrick Lee (a Natural Cures employee,see PXA:11 at 2) from a bank branch in Ojai, see PXA:7 at 2.



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supposedly beneficial to have an already-created shell business entity that one canput to use in the future (because then it will already have a history). PXA at 19. This is not credible because there is no (legitimate) benefit to having acompany with a history of doing nothing.

14Additionally, Sovereign Trust is a

pure asset protection vehicleit isnt a business entity at all. Furthermore, in2009, Trudeau asked offshore asset protection advisor Michel van Roon to

provide him asap with articles of incorporation and bylaws for all thecompanies. PXA:8. Trudeau would not have made this request if he was notundertaking some sort of activity with the offshore entities, and his obfuscationregarding his offshore entities again shows that he has not been forthcoming.

N.T. Trading. N.T. Trading is a Babenko-owned entity organized in Panama,and Trudeaus purported ignorance regarding this entity further illustrates his lackof candor. In July 2008, N.T. Tradings officers executed a full power of attorneyin Trudeaus favor. PXA:9. In his interview with the Receiver, Trudeau deniedknowing that he had received such a power of attorney. PXA at 20. It isdifficult to imagine why Trudeau would have obtained a full power of attorney

unless he was using N.T. Trading for some purpose. Indeed, in 2009, Marc Lanediscovered that Trudeau obtained the power of attorney. Lane asked Trudeau ifhe could have it revoked because the power of attorney would defeat the assetprotection strategy. PXA:10. Trudeau responded: not yet. Id. Wheninterviewed, Trudeau explained that he asked Lane not to have the power ofattorney revoked yet because it would be too expensive to have Lane performthe work. PXA at 21. Given the remarkable pace at which Trudeauaccumulated (and paid) legal fees, this explanation is not credible.

Ukrainian Apartment. When interviewed, Trudeau stated that he know[s]nothing about the transaction in which Website Solutions USA (WSU) sent

more than $350,000 to Ukraine to pay off a mortgage on an apartment. PXA at 23. Trudeau suggested that Sant may have authorized this transaction withoutconsulting him, and that he cannot recall whether Babenko even asked him aboutit. Id. Given the extensive record that Trudeau controls WSU, the Courts factualfindings to that effect, and Babenkos apparent lack of relative financialsophistication, it is unbelievable that Trudeau actually knows little or nothingabout this transaction, as he claims.

Other Transfers. Although the FTC is mindful of the Receivers caution thatmany transactions recorded in the books of the GIN-related entities may neverhave occurred (or may have been recorded inaccurately), the Receivers report

shows that Babenko may have received roughly $1.65 million (including the

14There are various illegitimate benefits, including the ability to claim that the company

has been existence for a longer period, which can help the company obtain bank accounts,payment processing, and other financial services. Trudeau also claimed that the offshore entitieswere created for asset protection and because of their tax advantages, see PXA 19, butneither of these purposes makes any sense if the companies never had any assets, as Trudeauclaims.



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money for the apartment).15

Trudeau may have received approximately $4.2million (including the $2 million loan from he used to fund the Court-orderedescrow account).16 The accounting entries illustrate the many transfers fromTrudeaus companies that remain unexplained.

17

The Antigua Account. To provide a final example of Trudeaus dubiousexplanations concerning asset transfers,18 as recently as six weeks ago, GIN FDNtransferred $16,305.79 to a previously unknown account in Babenkos name atthe Global Bank of Commerce in Antigua. Obviously, the Receiver did notapprove this transfer. Trudeau denied knowing anything about this account.

19

PXA at 24.

Significantly, Trudeau acts as if assets he controls through nominees (including his wife)

arent really his. For instance, Trudeau informed the FTC and the Receiver that assets in the

Australian account and the gaming account came from undocumented loans, PXA at 15,

25, suggesting that (in Trudeaus mind) they arent really his. Trudeau also repeatedly (and

implausibly) denies any knowledge concerning his wifes assets, see id. at 26, as he did in his

January 25, 2013 sworn financial statement, in which he denies having even rudimentary

knowledge concerning assets Babenko holds, such as whether she owns a car, jewelry, or the

gold bars that Trudeau now claims are hers, see DE535. Based on the extensive evidentiary

15 This number is derived by adding the number ($1,501,590.39) listed as due from

Babenko on the Consolidated Statements of Balance Sheet attached to the Receivers FirstReport (DE747-2) (Sept. 6, 2013), to the approximately $149,000 Babenko was paid . . . fromMarch 6, 2013 through August 20, 2013. Receivers Supp. Report (DE750-1) (Sept. 16, 2013)at 2.

16This number is derived by subtracting the number due to Trudeau ($5,513,875.34)

from the number due from Trudeau ($9,707,311.67). See Consolidated Statements of BalanceSheet, Receivers First Report (DE747-2) (Sept. 6, 2013).

17 Trudeau also has not explained what happened to the royalties he received from variousinfomercials since 2007. The FTC understands that Trudeau received approximately $4.2million through Trustar Productions and other entities he controls.

18In fact, even information Trudeau provides regarding less significant matters is dubious

and sometimes hard to accept with a straight face. When Trudeau was asked about the $684.44debited from his Australian account for charges at Renaissance Hotels on July 28, 2013, seePXA:13 at 4 (after the asset freeze), Trudeau explained that he used his card to reserve a roomfor a friend who came to support him at the July 26 hearing, but the friend skipped out on thebill, so Trudeaus account was charged. PXA at 28. Trudeau could not remember his friendsname (although his (or her) first name might have been Val). Id. at 28.

19 After the Receiver presented evidence of the Antigua account, Trudeau acknowledgedthat Babenko has/had this account, but stated that he has no info about this account or anyother of Babenkos accounts. See PXA at 24.



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record, and consistent with the Courts express finding that Trudeau controls various offshore

entities through Babenko, it is likely that Babenko likely holds most of Trudeaus offshore

wealth as his nominee.

III. THE PAST TWO MONTHS HAVE PROVEN THAT COERCIVEINCARCERATION IS NECESSARY.

The last two months have established conclusively that this last chance option simply

isnt working.20

Trudeau has violated the Courts two most recent orders at least five times. The

Receiver cannot get straight answers from Trudeau. Meanwhile, as time continues passing, the

expenses associated with the Receivership continue to grow, and consumers chances to obtain a

real recovery continue to dwindle.

When deciding whether to use incarceration as a coercive sanction, courts must consider

the character and magnitude of the harm threatened by continued contumacy, andthe probable

effectiveness of any suggested action in bringing about the result desired . United States v.

United Mine Workers of Am., 330 U.S. 258, 303-04 (1947) (footnotes omitted) (emphasis

added). The last two months have proven that the probable effectiveness of any approach is

zero if it depends on Trudeau voluntarily disclosing his assets to the Receiver or anyone else.

The magnitude of the harm remains substantialthe injury to Trudeaus more than 850,000victimsand the last two months have brought these consumers no closer to redress.

IV. CONCLUSIONImmediate coercive incarceration is the only option to obtain consumer redress that does

not depend on Trudeaus voluntary cooperation. The FTC sees no value to consumers by

continuing to give Trudeau chance after chancein fact, the continued passage of time works to

their substantial detriment. At this unfortunate point, there is nothing further the FTC reasonably

20As described above, the Court already found that it has the legal authority to

incarcerate Trudeau as a coercive sanction at this time. DE742 (Aug. 7, 2013); see also PXA:1at 30:20-22 (I would be absolutely within reason and the law and the facts of this case toincarcerate [you] today[.]). The Court also warned Trudeau (repeatedly) that failure tocooperate fully would result in his immediate incarceration.



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can do to obtain relief for Trudeaus victims. The FTC also cannot continue investing scarce

resources monitoring Trudeaus endless stream of order violations, evasions, and outright lies.

The FTC again urges the Court to coercively incarcerate Trudeau until the Court determines that

he has satisfied one of several precise purge conditions:21

(1) He fully complies with this Courts June 2, 2010 order (DE372);(2) He establishes that he has no present ability to comply with the Courts

June 2, 2010 order beyond what he has already done; or

(3) He establishes that continued incarceration will not have a coercive effect.

Dated: September 30, 2013

David OToole ([email protected])Federal Trade Commission55 West Monroe Street, Suite 1825Chicago, Illinois 60603-5001Phone: (312) 960-5601Fax: (312) 960-5600

Respectfully Submitted,

/s/ Jonathan CohenMichael Mora ([email protected])Jonathan Cohen ([email protected])Amanda B. Kostner ([email protected])Federal Trade Commission600 Pennsylvania Ave., N.W. M-8102BWashington, DC 20580Phone: 202-326-3373; -2551; -2880Fax: 202-326-2551

21There is nothing Trudeau can do to further the goals of the Receivership outside of

prison that he cannot do from within prison. However, the FTC requests that any coerciveincarceration order provide the Receiver with access to Trudeau in the event that the Receiverneeds Trudeau to execute documents or make phone calls under the Receivers supervision.



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CERTIFICATE OF SERVICE

I, Jonathan Cohen, hereby certify that on September 30, 2013, I caused to beserved true copies of the foregoing by electronic means, by filing such documents through theCourts Electronic Case Filing System, which will send notification of such filing to:

Kimball Richard Anderson

[email protected]

Thomas Lee Kirsch, [email protected]

Katherine E. [email protected]

Blair R. [email protected]

/s/ Jonathan CohenJonathan Cohen ([email protected])Attorney for PlaintiffFederal Trade Commission



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IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

FEDERAL TRADE COMMISSION,

Plaintiff,

v.

KEVIN TRUDEAU,

Defendant.

)

)

))

))

)

))

)

)

)

Case No. 03-C-3904

Hon. Robert W. Gettleman

EXHIBIT RELATED TO

FTCS STATEMENT REGARDING THE NEED FOR COERCIVE SANCTIONS

Case: 1:03-cv-03904 Document #: 759-1 Filed: 09/30/13 Page 1 of 185 PageID #:13367


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EXHIBIT A



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PXA:4 at 120

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FTC PXA:5



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)7&;

PXA:5 at 1



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)7&;

PXA:5 at 2



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)7&;

PXA:5 at 3



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)7&;

PXA:5 at 4



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)7&;

PXA:5 at 5



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FTC PXA:6



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GIN Network Truth (the smart group) PXA:6 at 1



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FTC PXA:7



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FTC PXA:10



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GIN Network Truth (the smart group) /$1(B$77251(


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FTC PXA:11



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)7&;

PXA:11 at 1



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Natural Cures

Last Name First Name

Andrews Deno Natural Cures

Barman Mitali Natural Cures

Birnbaum Joel Natural Cures

Contursi Janine Natural Cures

Dow Michael Natural Cures

Erazo Lindsay Natural Cures

Granzin Mark Natural Cures

Jackson Jeff Natural Cures

Johnson Donna Natural Cures

Krumwiede JoAnn Natural Cures

Lee Sam Natural Cures

Lee Patrick Natural Cures

Lee Stephen Natural Cures

Maloney Adam Natural Cures

Maraccini David Natural Cures

Meyer Robert Natural Cures

Monchunski Lisa Natural Cures

Nafpliotis Nick Natural Cures

Sant Neil Natural Cures

Torresso Steven Natural Cures

Trudeau Kevin Natural Cures

Wink Peter Natural Cures

Zeeb Richard Natural Cures

)7&;

PXA:11 at 2



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KT Radio


Burkhardt Brandy KT Radio

DuBiel Matt KT Radio

Hickman Terry KT Radio

Noonan Michael KT Radio

Peletis Jonathan KT Radio

Silverstein Kenneth KT Radio

Skweres Andrew KT Radio

Yeast Joel KT Radio

Interns

Altier Holly KT Radio

Owaynat Islam KT Radio

Miners Travis KT Radio

Seiler Steve KT Radio

Shonk Jason KT Radio

Lonnita Sims KT Radio

UK


Booth Mike UK EmployeesPaid by NC

Carroll Adam UK EmployeesPaid by NC

Kenny Lee UK EmployeesPaid by NC

Richardson Niall UK EmployeesPaid by NC

Thompson Paul UK EmployeesPaid by NC

)7&;

PXA:11 at 3



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FTC PXA:12



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GIN Network Truth (the smart group)PXA:12



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FTC PXA:13



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PXA:13 at 1

PXA:13 at 1



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PXA:13 at 6Case: 1:03-cv-03904 Document #: 759-1 Filed: 09/30/13 Page 185 of 185 PageID #:13551