Case: 1:10-cr-00886 Document #: 170 Filed: 03/31/14 Page 2 of 4 PageID #:4567

sentence for the healthy 51-year-old Trudeau. Given the age and seriously deteriorating health of both of his parents, however, it almost certainly means that if Trudeau is not able to see his parents before he starts his term of incarceration, he will never see either of his parents alive again. 4. Both of Trudeaus parents are in their late 80s. Both suffer from serious health

conditions for which there is no cure. Both of Trudeaus parents are too sick to travel. 5. Trudeau has demonstrated that he is not a flight risk. Not only did he comply

with all of the conditions of his bond in the criminal case, he reported for each and every court appearance in the civil case, (No. 03 C 3904), correctly predicting that some of those appearances would result in his coercive incarceration at the Metropolitan Correctional Center. 6. In addition, Trudeau voluntarily returned from Switzerland to submit himself to

the jurisdiction of this Court in connection with his criminal case. 7. On June 27, 2013 and July 1, 2013, respectively, Trudeau turned in his United

States and Italian passports to the United States Pretrial Services Office. The Pretrial Services Office has been in possession of both passports, the only ones Trudeau possesses, from those dates. 8. Trudeau is not a danger to the community. He has never been accused, much less

convicted, of a crime of violence. To the extent that the government would maintain that he presents a risk of fraud, at this juncture and for the short time that remains before he is to report to prison, this is a practical impossibility. 9. Trudeau understands that there is a short period of time that remains before he is

designated to the Bureau of Prison facility at which he is to serve his ten-year-term. His

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Case: 1:10-cr-00886 Document #: 170 Filed: 03/31/14 Page 3 of 4 PageID #:4568

only wish during the time that remains is to spend some time with his mother and father, effectively to say goodbye to them. He would have no objection to being on electronic monitoring confined to his parents home in Massachusetts for the brief time a bond might issue in this case. 10. Trudeaus parents have been consulted about this motion and are willing to re-

execute the Forfeiture Agreement, the Quit Claim Deed and all the required paperwork to reinstitute Trudeaus bond on the same terms on which it was granted on July 1, 2013. For all of the reasons enumerated above, Trudeau, requests that this Court enter an Order reinstating his bond until the time that he is given to report to the Bureau of Prisons and allowing his to self-surrender to his designated BOP institution to serve his 120-month sentence.

Respectfully submitted,

By: /s/ Carolyn P. Gurland One of His Attorneys

CAROLYN P. GURLAND 2731 North Mildred Ave. Chicago, IL 60614 (312) 420-9263 cgurland@comcast.net

THOMAS L. KIRSCH II WINSTON & STRAWN 35 West Wacker Drive Chicago, IL 60601 tkirsch@winson.com

Attorneys for Defendant

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Case: 1:10-cr-00886 Document #: 170 Filed: 03/31/14 Page 4 of 4 PageID #:4569

CERTIFICATE OF SERVICE I, Carolyn Pelling Gurland, an attorney for Defendant Kevin Trudeau, hereby certify that on this, the 31st day of March, 2014, I caused the above-described document to be filed on the CM/ECF system of the United States District Court for the Northern District of Illinois, which constitutes service of the same.

/s/ Carolyn P. Gurland

CAROLYN PELLING GURLAND 2731 North Mildred Ave. Chicago, Il 60614 Tel. (312) 420-9263

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Case: 1:10-cr-00886 Document #: 171 Filed: 03/31/14 Page 1 of 2 PageID #:4570

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

UNITED STATES OF AMERICA, Plaintiff,

) ) ) v. ) ) KEVIN TRUDEAU, ) Defendant. ) ____________________________________)

Case No. 10-CR-00886 Honorable Ronald A. Guzman

NOTICE OF MOTION

TO:

Marc Krickbaum April Perry United States Attorneys Office 219 South Dearborn Street Suite 500 Chicago, IL 60604

PLEASE TAKE NOTICE that the undersigned will appear before the Honorable Ronald A. Guzman on Thursday April 3, 2014 at 9:30 a.m. in Courtroom 1219 in the Federal Office Building, 219 South Dearborn Street, Chicago, Illinois, or before any judge sitting in his stead, and present DEFENDANT KEVIN TRUDEAUS MOTION FOR AN ORDER REINSTATING BOND UNTIL THE BUREAU OF PRISONS REPORT DATE, a copy of which has been served upon you by the Courts electronic filing system. Respectfully submitted, By: /s/ Carolyn P. Gurland__ 2731 North Mildred Ave. Chicago, IL 60614 (312) 420-9263 cgurland@comcast.net Attorney for Defendant Kevin Trudeau

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Case: 1:10-cr-00886 Document #: 171 Filed: 03/31/14 Page 2 of 2 PageID #:4571

CERTIFICATE OF SERVICE I, Carolyn P. Gurland, an attorney, hereby certify that on March 31, 2014 I caused to be served true copies of the above Notice of Motion by filing such document through the Courts Electronic Case Filing System, which will send notification of such filing to: Marc Krickbaum April Perry United States Attorneys Office 219 South Dearborn Street Suite 500 Chicago, IL 60604

/s/ Carolyn P. Gurland Carolyn P. Gurland Attorney for Defendant Kevin Trudeau

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