UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION UNITED STATES OF AMERICA, Plaintiff, v. KEVIN TRUDEAU, Defendant. ____________________________________ ) ) ) ) ) ) )
UNOPPOSED MOTION FOR SHORT CONTINUANCE OF TRIAL DATE Defendant Kevin Trudeau, by and through his attorneys, respectfully moves this Court for a short continuance of the trial date currently set in this case for August 26, 2013. In support of this motion, the defendant states as follows: 1. 2. A jury trial is currently scheduled to begin in this case on August 26, 2013. On Friday August 2, 2013, the government informed counsel for Trudeau that the
government has recently received over 17,000 pages of documents from the Federal Trade Commission (FTC). These documents relate to litigation between the FTC and ITV, a
company involved in the infomercial for the Weight Loss Cure book at issue in this case. As such, these documents have the potential to be central to the defense. 3. The government intends to produce these documents to the defense as soon as
possible. The government has indicated that it is in the process of scanning the ITV documents in preparation for producing those documents to the defense, and intends to produce the documents this week. 4. The defense requires sufficient time to review and digest these documents for
possible use at trial. Even if the government produces these documents in the coming week, the
defense will not have sufficient time to review and analyze such a large volume of documents and meaningfully incorporate them into its theory of the case. 5. As a result of these newly discovered documents, the government has indicated
that it does not oppose a continuance of the trial date. WHEREFORE, Trudeau respectfully requests that this Court grant his motion and continue the trial date in this case.
Dated: August 5, 2013 Respectfully submitted, KEVIN TRUDEAU By: /s/ Thomas L. Kirsch II One of His Attorneys
Kimball R. Anderson (kanderson@winston.com) Thomas L. Kirsch II (tkirsch@winston.com) Katherine E. Rohlf (krohlf@winston.com) WINSTON & STRAWN LLP 35 West Wacker Drive Chicago, Illinois 60601 312-558-5600
CERTIFICATE OF SERVICE I, Thomas L. Kirsch II, an attorney, hereby certify that on August 5, 2013, I caused to be served true copies of UNOPPOSED MOTION FOR SHORT CONTINUANCE OF TRIAL DATE, and accompanying exhibits 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, Illinois 60604