Dylan G. Trache, Va. Bar No. 45939 

NELSON MULLINS RILEY & SCARBOROUGH LLP 

101 Constitution Avenue, NW, Suite 900 

Washington, DC 20001 

(202) 689-2800 

Counsel to the Plan Trustee 

UNITED STATES BANKRUPTCY COURT 

EASTERN DISTRICT OF VIRGINIA 

Alexandria Division 

In re: 

UNIMEX CORPORATION, 

Debtor. 

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Bankruptcy Case 

No. 20-12535-BFK 

Chapter 11 

JOLENE E. WEE, PLAN TRUSTEE OF 

UNIMEX CORPORATION, 

c/o Nelson Mullins Riley & Scarborough LLP 

101 Constitution Ave., NW, Suite 900 

Washington, DC 20001 

Plaintiff,

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v. ) Adversary Proceeding No. _________ 

WEIWEI JIAN, 

20904 Butterwood Falls Terrace 

Sterling, Virginia 20165 

And 

Buffer Zone, LLC 

Weiwei Jian, Registered Agent 

21351 Gentry Dr., Suite 130 

Sterling, VA 20166 

And 

Gold Creek Properties, LLC 

Weiwei Jian, Registered Agent 

21351 Gentry Dr., Suite 130 

Sterling, VA 20166 

Defendants.

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COMPLAINT TO AVOID TRANSFERS, 

RECOVER PROPERTY AND FOR RELATED RELIEF 

COMES NOW Jolene E. Wee, the Plan Trustee (“Trustee” or “Plaintiff”) for Unimex 

Corporation (“Unimex” or “Debtor”), by and through her undersigned counsel, and files this 

Complaint for Breach of Settlement Agreement (“Complaint”) against Weiwei Jian, Buffer 

Zone, LLC and Gold Creek Properties, LLC (“Defendants”), stating to the Court as follows: 

PARTIES 

1. Plaintiff Jolene E. Wee is the court-appointed Plan Trustee of Debtor’s 

bankruptcy estate, 447 Broadway Street, 2nd FL 502, New York, NY 10013. Any service 

related to this matter should be directed to Plaintiff’s undersigned counsel. 

2. Defendant WeiWei Jian is the Debtor’s President and sole shareholder. Defendant 

WeiWei Jian is the sole member of Defendant Buffer Zone, LLC and Defendant Gold Creek 

Properties, LLC. He resides at 20904 Butterwood Falls Terrace, Sterling, Virginia 20165. 

BACKGROUND AND JURISDICTION 

3. This Court has jurisdiction over this proceeding pursuant to 28 U.S.C. §§ 1334 

and 157. 

4. This matter is a core proceeding pursuant to 28 U.S.C. § 157(b)(2). 

5. Venue is proper in this Court pursuant to 28 U.S.C. § 1409. 

6. On November 16, 2020 (the “Petition Date”), the Debtor filed a voluntary petition 

for relief under chapter 11 of Title 11 of the United States Code, 11 U.S.C. §§ 101-1532 (as 

amended, the “Bankruptcy Code”) in the United States Bankruptcy Court for the Eastern District 

of Virginia, Alexandria Division (the “Court”) commencing its chapter 11 case (the “Bankruptcy 

Case”). 

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7. On November 18, 2020, Jolene Wee was subsequently appointed as subchapter V 

trustee. 

8. By Order entered on April 5, 2021 (“Confirmation Order”), the Court confirmed 

the Debtor’s Amended Plan of Reorganization for Small Business Under Chapter 11 (“Plan”). 

9. Article 10 of the Plan as amended by the Confirmation Order authorized the 

Trustee to pursue certain Avoidance Actions under Chapter 5 of the Bankruptcy Code. 

10. On November 14, 2022, the Trustee commenced an adversary proceeding against 

Weiwei Jian in the United States Bankruptcy Court for the Eastern District of Virginia, seeking 

to avoid certain equity distributions and other transfers as specified therein and the entry of 

judgment for the benefit of the Estate pursuant to 11 U.S.C. §§ 544(b), 548, 549 and 550 (the 

“Adversary Proceeding”). 

11. On January 4, 2024, trial commenced on the Adversary Proceeding. 

12. Following the commencement of trial, counsel for the Trustee and counsel for 

Jian have engaged in settlement negotiations to resolve the allegations in the complaint without 

further litigation. Jian disputed that the transfers were avoidable. The proposed terms of the 

settlement were announced on the record on March 1, 2024. 

13. Thereafter, the parties executed a Settlement Agreement (the “Settlement 

Agreement”). A true and correct copy the Settlement Agreement is attached hereto as Exhibit 

A. 

14. By Order entered on May 7, 2024, the Court approved the Settlement Agreement. 

15. Under the terms of the Settlement Agreement, Defendants were required to pay the 

Trustee the sum of $237,500.00 in satisfaction of the Trustee’s claims in the Adversary Proceeding 

to be paid as follows: $100,000.00 was to be paid no later than May 1, 2024 and the remaining 

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$137,500.00 was to be paid monthly installments in the amount of $5,729.17 due on the 1st day of 

the month thereafter for 24 months, commencing on June 1, 2024 and ending on May 1, 2026. 

16. Jian paid the first $100,000.00 required by the terms of the Settlement Agreement. 

17. Jian failed to timely pay the June 2024 monthly installment of $5,729.17 required 

by the terms of the Settlement Agreement. 

18. On June 12, 2024, the Trustee served a notice of default with respect to the June 

2024 monthly installment. 

19. Prior to the expiration of the thirty (30) day period under Paragraph 2 of the 

Settlement Agreement, Jian paid the June 2024 monthly installment. 

20. Jian failed to timely pay the July 2024 monthly installment of $5,729.17. required 

by the terms of the Settlement Agreement. 

21. On July 17, 2024, the Trustee served a notice of default with respect to the July 

2024 monthly installment. A true and copy of this Notice of Default is attached hereto as 

Exhibit B. 

22. Jian failed to make the July 2024 monthly installment by August 16, 2024. 

COUNT I – BREACH OF CONTRACT 

23. The Plaintiff repeats and realleges every allegation contained in the above 

paragraphs, inclusive, as though fully set forth herein. 

24. The Settlement Agreement required Jian to make payment in the amount of 

$5,729.17 on or before July 1, 2026. 

25. After Jian failed to make payment in the amount of in the amount of $5,729.17 for 

July 2024, the Trustee served a Notice of Default as required by the Settlement Agreement. 

26. The deadline for Jian to cure his default was August 16, 2024. 

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27. Jian failed to cure his default prior to August 16, 2024. 

28. Under the terms of the Settlement Agreement, as a result of Jian’s failure to cure 

his default within thirty (30) days, the Trustee is authorized to immediately seek judgement for 

the remaining amount due under the Settlement Agreement plus eighteen percent (18%). 

29. The remaining amount due under the Settlement Agreement is $131,770.83. 

30. The Trustee is entitled to judgment against Jian in the amount of $155,489.58. 

WHEREFORE, the Plaintiff prays for judgment for Plaintiff and against the Defendants 

WeiWei Jian, Buffer Zone, LLC and Gold Creek Properties, LLC jointly and severally in the 

amount of $155,489.58 plus allowed costs. 

Dated: August 23, 2024 

Respectfully submitted, 

JOLENE E. WEE, PLAN TRUSTEE 

By Counsel 

NELSON MULLINS RILEY & SCARBOROUGH LLP 

101 Constitution Avenue, NW, Suite 900 

Washington, DC 20001 

Telephone: (202) 689-2800 

Email: dylan.trache@nelsonmullins.com

By: /s/ Dylan G. Trache 

Dylan G. Trache, Va. Bar No. 45939 

Counsel to the Plan Trustee

4854-6775-5738 

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