GIN Network Truth (the smart group)

No. 14-1869
In the United States Court of Appeals
for the Seventh Circuit
__________

UNITED STATES OF AMERICA,
PLAINTIFF-APPELLEE

v.

KEVIN TRUDEAU,
DEFENDANT-APPELLANT
__________

APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE
NORTHERN DISTRICT OF ILLINOIS, NO. 10-CR-886-1
HON. RONALD A. GUZMAN, PRESIDING
__________

DEFENDANT-APPELLANT KEVIN TRUDEAUS
MOTION FOR EXTENSION OF TIME

Pursuant to Federal Rule of Appellate Procedure 26(b), Defendant-Appellant
Kevin M. Trudeau (Mr. Trudeau) respectfully requests an extension of time from
July 24, 2014 to August 22, 2014 to file his appellants brief and appendix. Pursuant
to Circuit Rule 26, this motion is supported by the attached declaration of
Christopher M. Bruno. The Government does not oppose this motion.




Case: 14-1869 Document: 19-1 Filed: 07/11/2014 Pages: 2 (1 of 6)
GIN Network Truth (the smart group)
-2-


Dated: July 11, 2014 Respectfully submitted,
/s/ Christopher M. Bruno
Christopher M. Bruno
Winston & Strawn LLP
1700 K Street, NW
Washington, DC 20006-3817
(202) 282-5000
cmbruno@winston.com

Thomas L. Kirsch, II
Winston & Strawn LLP
35 West Wacker Drive
Chicago, IL 60601
(312) 558-5600
TKirsch@winston.com
Counsel for Kevin M. Trudeau
Case: 14-1869 Document: 19-1 Filed: 07/11/2014 Pages: 2 (2 of 6)
GIN Network Truth (the smart group)
UNITED STATES COURT OF APPEALS
FOR THE SEVENTH CIRCUIT
United States of America,

Plaintiff-Appellee
v.

Kevin Trudeau,
Defendant-Appellant.

)
)
)
)
)
)
)
)
)
)
)



Case No. 14-1869

Appeal from the United States District
Court for the Northern District of
Illinois,
Eastern Division.

No. 10-cr-886-1


DECLARATION OF CHRISTOPHER M. BRUNO IN SUPPORT
OF DEFENDANT-APPELLANT KEVIN TRUDEAUS
MOTION FOR EXTENSION OF TIME

I, Christopher M. Bruno, declare as follows:
1. I am an attorney with Winston & Strawn, LLP, and a member of the Bar of
the State of New York. I serve as lead counsel of record for Defendant-Appellant
and have primary responsibility for his brief in this appeal.
2. Winston & Strawn LLP was trial counsel for Mr. Trudeau and has continued
to represent him on this appeal on a pro bono basis. I was recently admitted to the
bar of the Seventh Circuit and entered my appearance on July 3, 2014. On June 17,
2014, the Court notified Mr. Trudeau that all necessary fees for his appeal had been
paid in full, after Winston & Strawn LLP paid the appellate fees.
3. Trudeaus brief is currently due on or before July 24, 2014. Defendant-
Trudeau has not previously sought an extension of time to file his brief. Trudeaus
Motion is not filed for purposes of delay.
Case: 14-1869 Document: 19-2 Filed: 07/11/2014 Pages: 3 (3 of 6)
GIN Network Truth (the smart group)
-3-

4. This appeal presents unusually complicated issues of law. On appeal,
Trudeau expects to raise issues regarding pretrial motions, a denial of motion for
judgment of acquittal, and sentencing. Each part of this appeal is made more
complicated by the nature of criminal contempta unique crime that carries special
considerations. Because of the rarity with which criminal contempt is charged, the
case law on criminal contempt is relatively scarce and undeveloped. In fact, the
crime is understood to be so rare that the Seventh Circuit offers no pattern jury
instruction. Raising these issues requires significantly more research than an
ordinary appeal.
5. The district court itself recognized the complexity of the issues at hand. The
final pretrial conference extended over approximately five days, spanning several
weeks. This appeal will likely present matters not merely of evidentiary evaluation,
but also of statutory construction. These statutory interpretation questions appear
to be ones of first impression in this Circuit.
6. Although I have worked and continue to work diligently on this appeal, the
sheer number and breadth of legal issues causes this representation to require an
unusual amount of consideration to mount an effective defense.
7. In addition, I am currently engaged in several other matters, of which the
following have competing deadlines with this briefs present due date and which
require my attention as well:
Novartis v. Hospira, Case No. 2:12-cv-03967, pending in the
United States District Court for the District of New Jersey.
Case: 14-1869 Document: 19-2 Filed: 07/11/2014 Pages: 3 (4 of 6)
GIN Network Truth (the smart group)
-3-

Estate of Sanders v. Commr, Case No. 4614-11 (U.S. Tax Ct.).
Matters for biopharmaceutical companies presently
contemplating commencing litigation or anticipating litigation.
8. Finally, Mr. Trudeau is currently in the custody of the Federal Bureau of
Prisons at Maxwell Air Force Base Prison Camp. Given that he is incarcerated at a
location far from my office, I do not meet with him in person. Accordingly, to provide
him counsel, I am required to separately schedule calls with him and communicate
by mail. Although the Bureau of Prisons has been accommodating, these realities
create delays in the process of effectively preparing Mr. Trudeaus appeal.
9. Transferring responsibility for this appeal to another attorney at Winston &
Strawn, LLP would be an inefficient use of resources, given the time I have already
spent researching the legal issues and reviewing the record in this matter.
10. Furthermore, transferring responsibility of the other matters would be
impractical considering the time and contributions I have already invested in them.
11. I anticipate that I can prepare and file Trudeaus brief by August 22, 2014.
I declare to the best of my under penalty of perjury under the laws of the
United States of America that the foregoing is true and correct.
Executed in Chicago, IL, on July 11, 2014.

/s/ Christopher M. Bruno_
Christopher M. Bruno, Esq.


Case: 14-1869 Document: 19-2 Filed: 07/11/2014 Pages: 3 (5 of 6)
GIN Network Truth (the smart group)
CERTIFICATE OF SERVICE

I, Christopher M. Bruno, an attorney, certify that on July 11, 2014, I caused
the foregoing DEFENDANT-APPELLANT KEVIN TRUDEAUS MOTION FOR
EXTENSION OF TIME to be served by filing such document through the Seventh
Circuits Electronic Case Filing System, which will send notification of such filing
to:




Date: July 11, 2014
/s/ Christopher M. Bruno
Christopher M. Bruno
WINSTON & STRAWN LLP
1700 K Street, NW
Washington, DC 20006-3817
(202) 282-5000

Counsel for Kevin M. Trudeau





Case: 14-1869 Document: 19-3 Filed: 07/11/2014 Pages: 1 (6 of 6)