Central District Consumer Bankruptcy Attorney's Association

Dear Jeff:
Suggest using Database query language to select all customers with sales < 4 years
then output information to a file that can be attached to Creditor Matrixwith client
approval. Client's personnel should be able to do the job or hire a
contractor.
Good Luck starts with a strategy and a plan. Form a strategic alliance
with
Robert J. Suhajda, MS,CPA
17721 Norwalk Blvd. #43
Artesia, CA 90701
562-924-8922
Income Tax for Attorneys, Bankruptcy, IRS representation,
Fiduciary income tax returns, Estate and Gift tax returns,
Trust Protector, Independent Trustee, Court Accountings
In a message dated 2/23/2010 5:15:54 P.M. Pacific Standard Time,
DavidTilem@TilemLaw.com writes:
Jeff:
I had that case several years ago, say about 15 years ago. We used the
debtor's computers to provide a disk of the matrix (remember those good old
days?) I would call the Court Clerk's office, explain the issue and see
what they might suggest. One other thought. I had a similar case where Ifiled both the entity and the principal. The Clerk's office was able to
"copy" the list from one debtor to the other. I don't know if that is still
possible, but this happened only about 7 years ago (before BAPCPA).
Alternative #2: Hire 20 college kids at $10/hour.
David A. Tilem
Certified Bankruptcy Specialist*
Law Offices of David A. Tilem (a debt relief agency)
206 N. Jackson Street, #201, , G, ,
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Motion to limit notice........???
But, really.. once you have a mailing list it is all up to the clerk in a chapter 7.

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I have a PC that owns a company that sells, lets say, widgets. He owns all the stock in Widgetco, and the company has sold a LOT of widgets to a LOT of people over the last 4 years, say 60,000+/- cutomers, all of whose contact information is stored in Widgetco's customer database.
PC has been pretty lax about corporate formalities and adhering to corporate seperateness. Well, lets say VERY lax. Corporate $$ and personal $$ are hopelessly co-mingled. A potential nightmare for the PC if faced with civil alter ego claims.
A while back, the PC learned that some of his sales staff have made some pretty remarkable claims, well, flatly untrue claims to be honest, while pedalling widgets for Widgetco. The attorney general, well, the several attorneys general, who investigated Widgetco threatened civil and criminal actions. Widgetco agreed recently to some pretty heavy civil penalties, and got covenants not to pursue criminal actions in the bargain.
Curiously, sales have dropped off considerably now that the sales staff has been properly "re-educated". Widgetco is still in business, barely.
PC was investigated by the AGs for his role in Widgetco's sales practices, and avoided criminal prosecution, barely. His very good criminal lawyer got an agreement that limits PC's max PERSONAL contribution to the settlement, to a number, and if Widgetco pays that much in its settlement, PC is off the hook, civilly, and criminally with the AGs. PC is desperately trying to keep Widgetco alive long enough to make it to the "magic number" that it needs to pay the AGs on the consent decree, so he is off the hook personally. Today, it looks like he WILL get there.
The DAY after that, PC would like to fold Widgetco's doors and file a personal Chapter 7. He otherwise qualifies, and I agree that he should file that Chapter 7. His personal debt is eye-popping, even for a 20 year vetran of these wars like me, and he has lost most of his personal assets in real estate and stock market losses.
Next fact: he might have one asset, a small piece of real estate that could interest an agressive trustee in a Ch7, so there is the possibility that a 7 could be an "asset" case. Finally, if sued by an individual Widgetco customer, we can assume that plaintiffs would include claims like, well, "fraud".
Here is what I conclude. I see 60,000 +/- potential claimants in the personal chapter 7 all of whom are pretty easily accessible in terms of their last known address. Normally I don't care if everyone in a no asset, no bar date case gets notice, (see Beezley). The exceptions to that are, of course, potential asset cases and if the claimants have potential 523 calims, both of which are present here.
If I file this case for PC I want to list 60,000 potential creditors. Is there any procedural way to avoid a list that big? Can potential creditors be served by publication? Seems like no if we actually know who they are.
Unless the Widgetco computer will interface with my BK program, I'll have to charge $10,000+/- to hire someone to do data input, alone. If anyone has any experience with managing a creditor matrix of this size, I'd love to hear about it.
Thanks.

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