Office of United States Trustee 

Bradley D. Jones, Trial Attorney 

115 South Union Street, Room 210 

Alexandria, VA 22314 

(703) 557-7228 

bradley.d.jones@usdoj.gov Page 1 of 17 

IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE EASTERN DISTRICT OF VIRGINIA 

Alexandria Division 

In re: 

Tiffany Bestani, 

fka Tiffany Devash 

 Debtor. 

Bankr. Case No. 16-12768-BFK 

 Chapter 7 

JUDY A. ROBBINS, 

United States Trustee for Region 4, 

 Plaintiff, 

 v. 

Tiffany Bestani, 

fka Tiffany Devash 

 Defendant. 

Adversary Proc. No. 

COMPLAINT TO REVOKE DISCHARGE 

 Judy A. Robbins, the United States Trustee for Region 4, by counsel, hereby files this 

complaint under 11 U.S.C. § 727(d) seeking the revocation of the Defendant’s discharge. As 

grounds, she alleges as follows: 

PARTIES

1. Plaintiff, Judy A. Robbins, is the United States Trustee for Region 4, with a 

business address in care of the Office of the United States Trustee, 115 South Union St., Suite 

210, Alexandria, Virginia 22314. 

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2. Defendant, Tiffany Bestani, is an individual, and may be served with a summons 

at her address of record: 1415 North Taft Street, Apt. 284, Arlington, VA 22201. Defendant is 

represented by counsel, Robert Sergio Brandt, in her bankruptcy proceeding. 

JURISDICTION

3. This Court has jurisdiction over this adversary proceeding under 28 U.S.C. 

§ 1334(a), 28 U.S.C. § 157, and 11 U.S.C. § 727(d). This matter is a core proceeding under 28 

U.S.C. § 157(b)(2)(A), (J), and (O). Venue is proper in this Court. 28 U.S.C. § 1409(a). 

4. Plaintiff has standing to seek revocation of Defendant’s discharge in this case. 11 

U.S.C. §§ 307 and 727(e). 

FACTS 

5. On August 11, 2016, the Defendant, Tiffany Bestani filed a voluntary chapter 7 

petition. Dkt. No. 1. 

6. H. Jason Gold was appointed chapter 7 trustee. See Dkt. Nos. 3, 22. 

7. On August 11, 2016, along with her voluntary petition the Defendant filed her 

Schedules and her Statement of Financial Affairs. Dkt. No. 1. 

8. The Schedules included a “Schedule A/B: Property,” which requires debtors to 

list their assets, including all of their real and personal property. Id. at 10-14. 

9. The Defendant completed Schedule A/B, listing the total value of her property as 

$38,212. Id. at 14. Of these, the value of the Defendant’s car accounted for the majority of her 

scheduled property. 

10. Line 26 of the Defendant’s Schedule A/B requires the Defendant to list Patents, 

copyrights, trademarks, trade secrets, and other intellectual property that she owns. Id. at 13. As 

examples, the Schedules provide “Internet domain names, websites, proceeds from royalties and 

licensing agreements.” Id.

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11. In response to Line 26, the Defendant checked the box for “No,” indicating that 

she had no such property. Id.

12. Nowhere on Schedule A/B, nor anywhere else in her Schedules, does the 

Defendant disclose any ownership in any internet domains, websites, or her entitlement to any 

revenue generated from any internet sites. See Dkt. No. 1. 

13. Line 30 of the Defendant’s Schedule A/B requires the Defendant to list “Other 

amounts someone owes to you.” Id. at 13. 

14. In response to Line 30, the Defendant checked the box for “No,” indicating that 

she had no such property. Id.

15. Nowhere in response to Line 30, nor anywhere else on her Schedules, does the 

Defendant disclose her entitlement to any portion of revenue generated from any websites or 

domain names. 

16. Line 34 of the Defendant’s Schedule A/B requires the Defendant to list “other 

contingent and unliquidated claims of every nature, including counterclaims of the debtor and 

rights to set off claims.” Id. at 14. If the Defendant does have such property, the form requires 

the Defendant to “Describe each claim.” Id. (emphasis added). 

17. In response to this question, the Defendant checked the box for “Yes.” In her 

description the Defendant stated that she has a “possible lawsuit that has not been pursued 

against former employer three years ago.” 

18. The Defendant valued this possible law suit as worth $1.00. 

19. The Defendant listed no other claims in response to Line 34 and nowhere in her 

response to Line 34 or anywhere else on her Schedules does the Defendant disclose other 

possible claims that she may have, including an entitlement to revenue or proceeds from any 

websites or her entitlement to ownership of any websites. 

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20. Line 35 of the Defendant’s Schedule A/B requires the Defendant to list “any 

financial assets you did not already list.” Id. at 14. 

21. In response to this question, the Defendant checked the box for “No,” indicating 

that there were no financial assets that she had that the Defendant did not already disclose on her 

Schedule A/B. 

22. With her Schedules, the Defendant filed a Declaration About an Individual 

Debtor’s Schedules, which includes a statement “Under the penalty of perjury, I declare that I 

have read the summary and schedules filed with this declaration and that they are true and 

correct.” Id. at 31. The Defendant signed her name under this statement on August 11, 2016. 

23. No amended Schedule A/B has been filed to list assets that were otherwise 

omitted. 

Three Days Before Her Meeting of Creditors, the Defendant Files Suit Seeking in Excess of 

$50,000 Dollars, Including Revenue Generated from the Website She Co-Founded 

24. A § 341(a) Meeting of Creditors (“341 Meeting”) was scheduled for September 

26, 2016 at 10:00 a.m.1

 Dkt. No. 9. 

25. Three days prior to the meeting, on September 23, 2016, the Defendant filed a 

Complaint in the Superior Court of the State of California, County of Santa Clara against Eric 

Grossweiner and Bayshore Software Technologies, Inc., Case No. 16-CV-300261 (“the 

Complaint”).2

26. The Complaint was filed by the Defendant, proceeding pro se, and listed as her 

contact information the same address that she provided as her address of record in her 

bankruptcy filing as well as her telephone number and email address. 

 1

 The § 341(a) Meeting was originally scheduled for October 3, 2016 at 10:00AM but at the request of the 

Defendant, the meeting was rescheduled to an earlier date. See Dkt. Nos. 3, 9-10. 

2

 The Defendant later filed a First Amended Complaint on February 27, 2017 and signed a Verified First 

Amended Complaint on March 8, 2017. 

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27. With the Complaint was filed a Civil Cover Sheet.3 On this Cover Sheet, in the 

box for “Jurisdiction,” the Defendant checked the box indicating that the “Action is an Unlimited 

Civil Case (exceeds $25,000).” 

28. Line 10 of the Cover Sheet requires the Plaintiff to describe the relief sought. On 

this line the Defendant checked two boxes: the first for damages, where she indicates that she is 

seeking damages in the amount of “$50,000+”; and the second box for “other,” where she 

indicates that she is seeking a “percentage of gross revenues or proceeds of sale as specified in 

the breached contract and arrears.” 

29. On Line BC-1 of the Cover Sheet, the Defendant describes the essential terms of 

the agreement with two sentences: one describing her wage claim but including a second 

sentence for another claim, which states, “Plaintiff was to be paid a contractually agreed amount 

in perpetuity based on the gross revenues of Bayshore’s site Collarme or receive half the 

proceeds in case of sale.” 

30. On Line BC-2, she describes two acts that constituted a breach of the agreement: 

the first a failure to pay certain wages and the second as the “failure to pay revenue sharing 

proceeds from April 2013 through the present.” 

31. On Line BC-4, the Defendant states that she has suffered damages “in an amount 

exceeding $25,000 based upon the revenues of Bayshore Software Technologies.” 

32. The Defendant also indicated that Bayshore Software Technologies, Inc. and Mr. 

Grossweiner had “made and withdrawn settlement offers” to her with respect to her claims. 

33. The Complaint Cover Sheet bears the Defendant’s signature and was signed on 

August 24, 2016, less than two weeks after her bankruptcy case was filed. 

 3

 This Cover Sheet included Form PLD-C-001 and PLD-C-001(1), which are approved for Optional Use by 

the Judicial Counsel of California for actions involving Contract and Breach of Contract claims. 

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34. The Complaint attached to the Cover Sheet was signed two days later on August 

26. 

35. The Complaint alleges that the Defendant developed a website business, 

Collarme.com, with Mr. Grossweiner and his company Bayshore Software Technologies, Inc. 

According to the Defendant, Collarme.com is “a free dating website for individuals active in the 

alternative lifestyle community.” 

36. The Defendant describes Collarme.com as a “joint project” which the Defendant 

“co-founded” beginning around 2002 and continuing through 2007. 

37. At its peak, the website became “a viable business entity generating more than 

$40,000 per month” and “had over 1 million active user accounts and was growing in 

popularity.” 

38. The Defendant alleged that when she began work on the site, she worked “without 

regular compensation or grant of a formal equity interest in Bayshore or Collarme” but with “the 

explicit understanding that she would financially benefit from its eventual sale.” 

39. In June 2012, the Defendant alleged that she signed an agreement whereby she 

received a monthly consulting fee and also accrued “during the term of the contract a permanent 

entitlement to a share in Collarme’s gross revenues and share of proceeds in the event Collarme 

were sold.” 

40. At the time the alleged agreement was terminated, the Defendant alleged that the 

website was generating operating profits in excess of $20,000 a month. 

41. In her Prayer for Relief, the Defendant sought unpaid wages but she also sought 

the “revenue sharing payments to which she is entitled under the Agreement from April 2013 to 

the present.” 

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42. In addition, the Defendant asked the Court to order the Defendants to pay “12% 

of its gross revenues in perpetuity” to her or, in the event damages could not be paid, have the 

Court order a supervised dissolution of Bayshore Technologies, Inc., “which under the terms of 

the Agreement would entitle Plaintiff to half of the proceeds received.” 

43. The Complaint was signed by the Defendant, pro se, on August 26, fifteen days 

after her bankruptcy filing and about one month prior to her meeting of creditors. 

44. The Defendant never amended her previously filed schedules to disclose the 

damages she sought for revenue sharing or the dissolution of Bayshore Technologies, Inc. nor 

did she amend the complaint to value her lawsuit as worth more than $1 – even though she had 

just filed a complaint seeking over $50,000 in damages. 

The Defendant Misrepresents the Nature of Her Suit at Her Meeting of Creditors 

45. On September 26, 2016 the § 341 Meeting was conducted in this case, and the 

Defendant testified under penalty of perjury after being duly sworn by the trustee. 

46. In response to questions by the trustee, the Defendant testified that she had signed 

the Petition, Schedules, Statements, and that she had read the papers before she signed them. 

47. She further testified she was personally familiar with all of the information in her 

bankruptcy papers and that the information was true to the best of her knowledge. 

48. When the trustee asked if there were any errors, omissions, or mistakes in the 

papers, she testified, “Not that I know of.” 

49. The trustee then asked the Defendant, “All of your assets are listed?” The 

Defendant responded, “Yes.” 

50. Near the conclusion of the § 341 Meeting the trustee asks “What was that lawsuit? 

Possible lawsuit I remember seeing?” 

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51. Counsel for the Defendant replied, “Former Employer.” The Defendant then 

testified, “Yeah, it was a former employer. They didn’t pay me the last three months and then 

when I contacted them, they said I was required to go through arbitration, but they didn’t want to 

pay for arbitration. And then when I contacted someone - -”. 

52. The trustee then asked the Defendant why they didn’t pay her, the Defendant 

testified, “They said they didn’t have the money.” He then asks, “How much was it, roughly”? 

The Defendant testified, “I think about 12,000.” 

53. At no time, at her § 341(a) Meeting did the Defendant disclose her ownership of 

Collarme.com or any other websites, that she had filed a lawsuit, that she was actively pursuing 

that lawsuit, that the Defendant was seeking a portion of revenues from the company in addition 

to her wage claims, or that the amount she was seeking was more than $50,000. 

54. Based on the testimony of the Defendant the trustee filed a Chapter 7 Trustee’s 

Report of No Distribution on September 30, 2016. Dkt. No. 12. 

55. The Defendant received a discharge on December 7, 2016 and the case was closed 

five days later. Dkt. Nos. 13, 15. 

In the California Litigation the Defendant Admits Owning Collarme.com and that Domain 

Name was Transferred to Her at Least Two Years Prior to Her Bankruptcy Filing 

56. On September 15, 2017, Mr. Grossweiner and BayShore Software Technologies, 

Inc. filed an Ex Parte Application for a Temporary Restraining Order and Order to Show Cause 

in the lawsuit pending in Santa Clara Superior Court. 

57. The Application sought to restrain the Defendant from accessing or modifying 

accounts related to 27 adult websites and domain names, including Collarme.com. 

58. All of these websites were registered through the domain registration and hosting 

service, GoDaddy.com. 

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59. The Application alleged that in early September 2017, Mr. Grossweiner and 

BayShore Technologies, Inc., through counsel, gave notice to the chapter 7 trustee of the 

litigation and that the trustee was the true party in interest. 

60. The chapter 7 trustee filed a Declaration in support of the Ex Parte Application, 

declaring that as trustee of the Defendant’s Bankruptcy Estate, he is the party responsible for the 

assets of the estate and “the sole party in control of those assets.” Dkt. No. 19-3 at 2. 

61. The assets of the Bankruptcy Estate in this case included any personal property of 

the Defendant including her unliquidated causes of action and lawsuits, which include any claims 

that the Defendant has with respect to the 27 websites at issue with the Application for a 

Temporary Restraining Order. Id. 

62. According to the Declaration filed by the chapter 7 trustee, “at no time did I give 

Plaintiff Bestani permission to prosecute the claims in this the above-titled action.” 

63. The trustee’s Declaration further states that in his capacity as trustee of the 

Defendant’s bankruptcy estate, he had reached an agreement with Mr. Grossweiner to transfer to 

him any of the Estate’s claims in the litigation filed by the Defendant as well as the 27 Domain 

Names at issue in the Application for a Temporary Restraining Order. 

64. On October 6, the Defendant filed an Opposition to the Application for a 

Temporary Restraining Order as well as Declaration in Support of Her Opposition. 

65. The Opposition states that a Temporary Restraining Order was inappropriate in 

part because one of the domain names at issue, Collarme.com belonged to the Defendant. 

66. In her October 5 Declaration, the Defendant stated that she is “the sole registrant 

and owner of the domain name ‘collarme.com’ and have been since approximately 2004.” She 

attached to her declaration a copy of communications she had with GoDaddy, which in her view 

demonstrated that she “is the owner of the domain ‘collarme.com.’” 

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67. The Defendant further declared that “In 2014, I contacted GoDaddy to request 

that the collarme.com domain name be transferred to my GoDaddy Account. I was entitled to the 

transfer of the domain name because I am the sole registrant and owner of the collarme.com 

domain.” 

68. The Defendant further explains that “GoDaddy conducted the transfer based on 

my proof of ownership of collarme.com.” 

69. However, nothing in the Defendant’s Declaration explains why she failed to list 

her ownership interest in Collarme.com, or any other website the Defendant has an interest in, on 

her Bankruptcy Schedules or disclose her ownership interest at her § 341(a) Meeting of 

Creditors. 

70. Similarly, nothing in the Defendant’s Declaration explains why she failed to 

disclose the full nature of the litigation that she was pursuing , rather than merely characterizing 

the dispute as a “possible lawsuit that has not been pursued against former employer three years 

ago.” 

71. Nor does the Defendant’s Declaration explain why she valued the lawsuit at $1 in 

her schedules. The Declaration also does not explain why the Defendant suggested at her 

Meeting of Creditors that the amount in controversy was $12,000, when she was actually 

pursuing a claim to seek a portion of the revenues generated from a website with tens of 

thousands of dollars in monthly revenues, which the Defendant knew provided her with a cause 

of action seeking damages of at least $50,000 or more. 

The Trustee Reopens the Bankruptcy Case to Administer the Undisclosed Assets 

72. On September 29, 2017 the chapter 7 trustee filed a Motion to Reopen the Case 

(“Motion to Reopen”). Dkt. No. 16. 

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73. In his Motion to Reopen, the trustee states that in September 2017 he became 

aware of assets that were not disclosed to the trustee. Specifically, the Defendant’s interest in 

certain domain names and related accounts which related to a lawsuit pending in Santa Clara 

Superior Court. Id. at 1, ¶6. 

74. After conducting a hearing on October 24, 2017, an Order Reopening the Case 

and Directing the Appointment of a Trustee was entered on October 31, 2017. Dkt. No. 21. 

75. On November 1, 2017 the United States Trustee appointed H. Jason Gold as 

chapter 7 trustee in the reopened case. Dkt. No. 22 

76. After being appointed trustee, Mr. Gold filed a Motion to Sell Domain Names 

under Section 363(b) ( the “Motion to Sell”). Dkt. No. 23. 

77. The Motion to Sell asks that the Court to approve the sale by quitclaim deed of 27 

domain names at issue in the California Litigation Mr. Grossweiner, the Defendant’s former 

business partner, for $16,500.00. Id. The sale also includes certain releases regarding any claims 

that the Defendant has with respect to the 27 websites. 

COUNT I 

REVOCATION OF DISCHARGE UNDER 11 U.S.C. § 727(d)(1) 

DISCHARGE OBTAINED THROUGH FRAUD 

78. The Plaintiff incorporates the allegations set for in paragraphs 1 through 77. 

79. The Defendant obtained her chapter 7 discharge through fraud. 

80. The United States Trustee did not know of the fraud until after the granting of the 

chapter 7 discharge. 

The Defendant Knowingly and Fraudulently Concealed Her Interest in Her Website and 

Her California Litigation Claims That Sought a Portion of That Site’s Revenues 

81. In particular, the Defendant obtained her chapter 7 discharge through fraud as a 

result of her concealment of her website and her significant litigation claims from the chapter 7 

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trustee, which if known prior to the discharge being granted would have resulted in the denial of 

her discharge under 11 U.S.C. § 727(a)(2). 

82. The Defendant’s ownership interest in Collarme.com was an asset of the 

Defendant’s bankruptcy estate after the date of the filing of the petition. 

83. The Defendant’s litigation claims against Bayshore Software Technologies, Inc. 

and Mr. Grossweiner were also property of the bankruptcy estate after the filing of the petition. 

84. The chapter 7 trustee is an officer of the estate charged with custody of property 

under Title 11 and was entitled to liquidate these assets in order to distribute the proceeds to 

creditors of the bankruptcy estate. 

85. In order to prevent those assets from being administered in her bankruptcy, the 

Defendant knowingly and fraudulently concealed her ownership of those assets. 

86. The Defendant concealed her ownership interest in her website by not disclosing 

it on her bankruptcy schedules or in her testimony at her § 341(a) Meeting. 

87. The Defendant concealed from the chapter 7 trustee her breach of contract claims 

against Mr. Grossweiner and Bayshore Software Technologies, Inc. 

88. The Defendant engaged in concealment by acts designed to mislead the trustee, 

including only partially describing the nature of the claims at issue, purposefully disclosing only 

the claim that was the least lucrative on her Schedule A/B, failing to disclose her claim for a 

portion of the website revenue or 50% of the proceeds on dissolution, and by only describing in 

her Schedule A/B the dispute as a “possible lawsuit” that “had not been pursued” from “three 

years ago,” when in fact the Defendant was actively pursuing the litigation. 

89. The Defendant’s concealment was done with the intent to hinder, delay, or 

defraud the chapter 7 trustee and the Defendant’s creditors. 

90. The Defendant’s discharge should therefore be revoked. 

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The Defendant Knowingly and Fraudulently Made False 

Oaths on Her Schedules and at Her § 341(a) Meeting 

91. The Defendant also obtained her chapter 7 discharge through fraud as a result of 

her knowing and fraudulent false oaths in connection with her personal bankruptcy case, which if 

know prior to the discharge being granted would have resulted in the denial of her discharge 

under 11 U.S.C. § 727(a)(4)(A). 

92. The Defendant knowingly and fraudulently in this bankruptcy case made false 

oaths by: 

a. Checking the box indicating, “No” on Line 26 of her Schedule A/B in response to 

the requirement to list internet domain names, websites, proceeds from royalties 

and licensing agreements or any other intellectual property. The Defendant knew 

that she owned the domain name Collarme.com – having been the sole registrant 

since approximately 2004 and having obtained the transfer of that domain name to 

her GoDaddy account in 2014 in response to proof of ownership that she had 

submitted. The Defendant also knew, based on the websites history of earning 

monthly revenues in excess of $20,000-$40,000 per month and generating over 1 

million active users, that the website was potentially valuable; 

b. Checking the box indicating, “No” on Line 30 of her Schedule A/B in response to 

the requirement to list “Other Amounts Someone Owes to You.” The Defendant 

knew that she had entered into an Agreement whereby a portion of the monthly 

revenues of her website were payable to her or that she may have had an 

entitlement to force the sale of Bayshore Software Technologies, Inc. and obtain 

half of the revenues from that sale. However, despite knowing that money was 

owed to her on that basis, the Defendant did not list her entitlement to those 

funds. The Defendant knew that this asset was valuable at the time she completed 

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her Schedules because she filed a lawsuit to recover those funds a few weeks later 

while her bankruptcy was pending; 

c. Listing only “possible lawsuit that has not been pursue against former employer 

three years ago” in response to the requirement on Line 34 to list “other 

contingent and unliquidated claims of every nature, including counterclaims of 

the debtor and rights to set off claims.” At the time she completed her Schedule 

A/B/, the Defendant knew her partial response was deceptive and failed to reveal 

the true nature of the litigation, which sought to recover tens of thousands of 

dollars in revenue due to the Defendant’s ownership and development of a 

valuable website in addition to the wage claim she did describe. The Defendant’s 

description that the lawsuit “has not been pursued” was also deceptive because at 

the time the Defendant completed her Schedule A/B she knew that she was going 

to file a suit to recover the wages and revenue sharing owed to her; 

d. Valuing the lawsuit against Mr. Grossweiner and Bayshore Software 

Technologies, Inc. as worth only $1 when the Defendant knew in actuality that 

her cause of action was substantially more valuable. The Defendant knew that the 

claim was worth substantially more because just a few weeks later, she filed suit 

in California seeking substantial damages and estimating that she was entitled to 

receive amounts in excess of $50,000; 

e. Checking the box indicating, “No” on Line 35 of her Schedule A/B in response to 

the requirement to list “any financial assets that you did not already list,” when 

the Defendant knew she did not list valuable assets. At the time she completed her 

Schedules, the Defendant knew that she did not list anywhere on her Schedules 

either her ownership of Collarme.com, her entitlement to revenues from the 

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website, or her entitlement to half of the proceeds of the company in the event it 

was dissolved; 

f. Stating at her § 341(a) Meeting of Creditors that she did not know of any errors, 

omissions or mistakes in her Schedules when the Defendant knew that she 

omitted listing her ownership interest in Collarme.com as well as the claims in her 

litigation that sought revenue sharing or half the value of Bayshore Software 

Technologies Inc. in a dissolution sale; 

g. Stating at her § 341(a) Meeting of Creditors that she listed all of her assets when 

the Defendant failed to list her ownership interest in Collarme.com or her claims 

against Bayshore Software Technologies, Inc. and Mr. Grossweiner, which sought 

a portion of the company’s revenue or half its dissolution value; and 

h. Stating at her § 341(a) Meeting of Creditors that her suit was only for “about 

$12,000” when the Defendant knew that she had filed a complaint that was 

seeking damages in excess of $50,000. 

93. Despite making these false statements in her Schedules and at her § 341(a) 

Meeting of Creditors, the Defendant signed her Schedules under penalty of perjury and testified 

under penalty of perjury at her § 341(a) Meeting. 

94. The Defendant’s knowing and fraudulent false oaths prevented the discovery of 

her ownership of Collarme.com or her significant litigation claims while her bankruptcy case 

was pending, which enabled her to obtain her discharge. 

95. The Defendant’s discharge should therefore be revoked. 

COUNT II 

REVOCATION OF DISCHARGE UNDER 11 U.S.C. § 727(d)(2) 

FRAUDULENT ACQUISION OF ESTATE PROPERTY 

96. The Plaintiff incorporates the allegations set for in paragraphs 1 through 95. 

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97. The Defendant acquired property that is property of the chapter 7 estate, as well 

as an entitlement to acquire estate property, and knowingly and fraudulently failed to report the 

acquisition of that property, or entitlement, or to deliver or surrender that property to the chapter 

7 trustee. 

98. In particular, the Defendant’s unpursued litigation claims against Bayshore 

Software Technologies, Inc. and Mr. Grossweiner were property of the bankruptcy estate at the 

time the bankruptcy petition was filed. 

99. By filing the California Litigation while her bankruptcy case was pending, 

pursuing those causes of action, and exercising control over that litigation, the Defendant 

acquired property that was property of her bankruptcy estate. 

100. The Defendant knew that the claims she was pursuing were bankruptcy estate 

property because she had listed one of her unpursued litigation claims on her bankruptcy 

schedules filed just a few weeks before. 

101. However, despite knowing that these claims were bankruptcy estate property, the 

Defendant knowingly and fraudulently failed to report the acquisition of or entitlement to such 

property or to deliver or surrender such property to the trustee. 

102. In fact, despite filing these litigation claims and knowing that the claims were 

property of her bankruptcy estate, the Defendant failed to report that she was pursuing these 

claims when asked about the litigation by the chapter 7 trustee at her § 341(a) Meeting. The 

Defendant also failed to disclose the true nature of the claims to the trustee at § 341(a) Meeting. 

103. The Defendant never delivered or surrendered such property to the trustee. 

104. The Defendant’s discharge should therefore be revoked. 

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WHEREFORE, the United States Trustee respectfully requests that this Court revoke 

the Defendant’s discharge and grant such further relief as is just and proper. 

December 4, 2017 JUDY A. ROBBINS 

 U.S. TRUSTEE, REGION 4 

 By: /s/ Bradley D. Jones

 Bradley D. Jones (VSB No. 85095) 

 Trial Attorney 

 Office of United States Trustee 

 115 South Union Street, Suite 210 

 Alexandria, VA 22314 

 (703) 557-7228 

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