TABAS & SOLOFF, P.A. · INGRAHAM BUILDING, 25 SOUTHEAST SECOND AVENUE, SUITE 248, MIAMI, FLORIDA 33131 ∙ (305) 375-8171

UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

MIAMI DIVISION

In re:

CASE NO.: 19-25435-BKC-LMI

AAA MACHINERY PARTS AND RENTALS, LLC Chapter 7

Debtor.

/

JOEL L. TABAS, CHAPTER 7 TRUSTEE, 

Plaintiff, Adv. Case No.:

v.

UBEFUNDING LLC and ANGEL ROMER 

MORALES.

Defendants.

/

COMPLAINT 

Plaintiff, Joel L. Tabas, as Chapter 7 trustee (the “Plaintiff” or “Trustee”) of the 

bankruptcy estate of AAA Machinery Parts and Rentals, LLC. through counsel, sues 

Defendants, UBEFunding LLC (“UBEF”) and Angel Romer Morales (“Morales”, 

collectively with UBEF shall be referred to as the “Defendants”), and alleges as follows:

JURISDICTION AND VENUE

1. This is an adversary proceeding governed by Fed. R. Bankr. P. 7001, et 

seq., seeking avoidance of fraudulent transfers pursuant 11 U.S.C. § 548 and §§ 726.105 

and 726.106 of the Florida Statutes and the recovery of such avoided transfers pursuant 

to 11 U.S.C. §§ 544, 550 and 551 and §§ 726.108 and 726.109 of the Florida Statutes.

2. The Court has jurisdiction over this adversary proceeding pursuant to 28 

U.S.C. §§ 157(b) and 1334. 

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TABAS & SOLOFF, P.A. · INGRAHAM BUILDING, 25 SOUTHEAST SECOND AVENUE, SUITE 248, MIAMI, FLORIDA 33131 ∙ (305) 375-8171

3. This is a core proceeding pursuant to 28 U.S.C. § 157(b)(2)(A), (F) and (H).

4. Venue is proper in this district pursuant to 28 U.S.C. § 1409(a).

THE PARTIES 

5. Plaintiff is the duly-appointed Chapter 7 Trustee of the debtor, AAA 

Machinery Parts and Rentals, LLC (the “Debtor”) and brings this action solely in his 

capacity as Trustee.

6. Plaintiff’s principal place of business is in Miami-Dade County, Florida.

7. UBEF, is a Florida Limited Liability Company with its principal place of 

business in Miami-Dade County, Florida.

8. Morales is an individual residing in Volusia County, Florida with sufficient 

contacts in Miami-Dade County, Florida and is sui juris.

9. At all times material hereto, Morales was the Vice-President of the Debtor

and is therefore an insider as that term is defined in 11 U.S.C. §§ 101(31)(B)(ii) and 

101(31)(B)(iii). 

FACTUAL BACKGROUND

A. Bankruptcy Case

10. On November 15, 2019 (the “Petition Date”), the Debtor filed a voluntary 

petition for relief under chapter 7 of the Bankruptcy Code. Shortly thereafter, Plaintiff was 

appointed Chapter 7 Trustee of the Debtor’s bankruptcy estate.

11. The § 341 Meeting of Creditors was held and concluded on December 11, 

2019.

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B. The Initial Transfer of Real Property

12. The Debtor owned the real property located at 493 NW 98th Ct. Unit 493, 

Miami, FL 33172 with the following legal description:

Unit 493, Building 46, East Wind Lake Village Condominium, a 

Condominium, all as set forth in the Declaration of Condominium and 

the Exhibits attached thereto and forming a part thereof, as recorded 

in Official Records Book 9546, Page 500, and all amendments 

thereto, of the Public Records of Miami-Dade County, Florida. The 

above description includes, but is not limited to, all appurtenances to 

the condominium unit above described, including the undivided 

interest in the common elements of said condominium. 

Parcel Identification Number: 30-4005-014-1350

(the “Real Property”)

13. On December 21, 2018, the Debtor executed a Warranty Deed, recorded in 

the Public Records of Miami Dade County, Florida on January 28, 2019, transferring the 

Real Property to UBEF (the “Initial Transfer”). A true and correct copy of the Warranty 

Deed is attached hereto as Exhibit “A.”

C. The Subsequent Transfer of Real Property

14. The same day the Warranty Deed was executed, UBEF executed a Quit 

Claim Deed, recorded in the Public Records of Miami Dade County, Florida on December 

28, 2020, transferring the Real Property to Morales (the “Subsequent Transfer”). A true 

and correct copy of the Quit claim Deed is attached hereto as Exhibit “B.” 

15. Upon information and belief, UBEF acted as a strawman to conceal the true 

nature of the intended transfer of Real Property: the transfer of the Debtor’s interest in the 

Real Property to an officer of the Debtor, Morales, for no consideration.

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16. The Debtor did not receive value for the Initial Transfer or the Subsequent 

Transfer (collectively, the “Transfers”). 

COUNT I

AVOIDANCE AND RECOVERY OF THE

TRANSFER PURSUANT TO 11 U.S.C. §§ 548(a)(1)(A) 

17. Plaintiff incorporates and realleges paragraphs 1 through 16 of this 

Complaint as though fully set forth herein.

18. Pursuant to 11 U.S.C. § 548(a)(1)(A), a Chapter 7 trustee may avoid any 

transfer of an interest of the debtor in property, or any obligation incurred by the debtor, 

that was made or incurred on or within two years before the date of the filing of the petition, 

if the debtor voluntarily or involuntarily - made such transfer or incurred such obligation 

with actual intent to hinder, delay or defraud any entity to which the debtor was or became, 

on or after the date that such transfer was made or such obligation was incurred, indebted.

19. At or near the time of the Initial Transfer: (i) the Debtor was insolvent or 

became insolvent shortly thereafter; (ii) the Debtor did not receive reasonably equivalent 

value in exchange for making the Initial Transfer; and (iii) the Initial Transfer took place 

around the time the Debtor was the defendant, in three separate state court actions 

initiated in Miami-Dade County. 

20. The Initial Transfer constitutes a transfer of interest in property of the Debtor 

to UBEF within two years of the Petition Date.

21. The Debtor did not receive reasonably equivalent value in exchange for 

making the Initial Transfer.

22. The Debtor made the Initial Transfer with the actual intent to hinder, delay 

or defraud its creditors.

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TABAS & SOLOFF, P.A. · INGRAHAM BUILDING, 25 SOUTHEAST SECOND AVENUE, SUITE 248, MIAMI, FLORIDA 33131 ∙ (305) 375-8171

23. As a result of the above, the Trustee can avoid the Initial Transfer pursuant 

to Section 548(a)(1)(A) of the Bankruptcy Code and recover the value thereof for the 

benefit of the estate pursuant to Section 550 of the Bankruptcy Code. 

WHEREFORE, Plaintiff, Joel L. Tabas, as Chapter 7 Trustee of the bankruptcy 

estate of AAA Machinery Parts and Rentals, LLC respectfully requests this Court enter 

judgment on his behalf and against Defendant, UBEFunding LLC, as follows:

a. Determining that the Initial Transfer delivered to UBEFunding LLC, as set 

forth above, is a fraudulent transfer and is therefore avoided pursuant to § 

548(a)(1)(A) of the Bankruptcy Code;

b. Determining that UBEFunding LLC is the initial transferee and/or the entity 

for whose benefit the Initial Transfer was made;

c. Awarding costs of suit; and

d. Granting such other and further relief as this Court deems just and proper.

COUNT II

RECOVERY OF FRAUDULENT TRANSFERS PURSUANT 

TO 11 U.S.C. § 550(a)(1) OF THE BANKRUPTCY CODE

24. Plaintiff incorporates and realleges paragraphs 1 through 16 and 18 through 

23 of this Complaint as though fully set forth herein.

25. Pursuant to 11 U.S.C. § 550, in a fraudulent transfer action commenced 

under Section 548 of the Bankruptcy Code, the trustee may recover, for the benefit of the 

estate, the property transferred, or if the court so orders, the value of such property, from 

- (1) the initial transferee of such transfer or the entity for whose benefit such transfer was 

made; or (2) any immediate or mediate transferee of such initial transferee.

26. UBEF was the initial transferee of the Initial Transfer and/or the entity for 

whose benefit the Initial Transfer was made.

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TABAS & SOLOFF, P.A. · INGRAHAM BUILDING, 25 SOUTHEAST SECOND AVENUE, SUITE 248, MIAMI, FLORIDA 33131 ∙ (305) 375-8171

27. As a result of the Initial Transfer, UBEF received the Real Property.

28. The Initial Transfer is avoidable by the Plaintiff pursuant to Section 548 of 

the Bankruptcy Code, and as a result, the Initial Transfer, is recoverable by Plaintiff 

pursuant to Section 550 of the Bankruptcy Code.

WHEREFORE, Plaintiff, Joel L. Tabas, as Chapter 7 Trustee of the bankruptcy 

estate of AAA Machinery Parts and Rentals, LLC respectfully requests this Court enter 

judgment on his behalf and against Defendant, UBEFunding LLC, as follows:

a. Declaring UBEFunding LLC the initial transferee of the Initial Transfer;

b. warding damages in the total amount of the Initial Transfer, plus prejudgment interest, in favor of Plaintiff and directing UBEFunding LLC to turn 

over the Initial Transfer pursuant to 11 U.S.C. § 550 of the Bankruptcy 

Code;

c. Awarding costs of suit; and

d. Granting such other and further relief as this Court deems just and proper.

COUNT III

AVOIDANCE AND RECOVERY OF THE

TRANSFER PURSUANT TO 11 U.S.C. §§ 548(a)(1)(B) 

29. Plaintiff incorporates and realleges paragraphs 1 through 16 of this 

Complaint as though fully set forth herein.

30. Pursuant to 11 U.S.C. § 548(a)(1)(B), a Chapter 7 trustee may avoid any 

transfer of an interest of the debtor in property, or any obligation incurred by the debtor, 

that was made or incurred on or within two years before the date of the filing of the petition, 

if the debtor voluntarily or involuntarily - (i) received less than reasonably equivalent value 

in exchange for such transfer or obligation; and (ii)(I) was insolvent on the date that such 

transfer was made or such obligation was incurred, or became insolvent as a result of 

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TABAS & SOLOFF, P.A. · INGRAHAM BUILDING, 25 SOUTHEAST SECOND AVENUE, SUITE 248, MIAMI, FLORIDA 33131 ∙ (305) 375-8171

such transfer or obligation; (II) was engaged in business or a transaction, or was about to 

engage in business or a transaction, for which any property remaining with the debtor 

was an unreasonably small capital; (III) intended to incur, or believed that the debtor 

would incur, debts that would be beyond the debtor’s ability to pay as such debts matured; 

or (IV) made such transfer to or for the benefit of an insider, or incurred such obligation 

to or for the benefit of an insider, under an employment contract and not in the ordinary 

course of business.

31. The Initial Transfer constitutes a transfer of interest in property of the Debtor 

to UBEF within two years of the Petition Date.

32. The Debtor did not receive reasonably equivalent value in exchange for 

making the Initial Transfer.

33. At the time that the Debtor made the Initial Transfer:

a. The Debtor was insolvent or became insolvent shortly thereafter

b. The Debtor was engaged in business or a transaction, or was about to 

engage in business or a transaction, for which any property remaining with 

capital was an unreasonably small capital; or

c. The Debtor intended to incur, or believed that it would incur, debts that 

would be beyond The Debtor’s ability to pay as such debts matured.

34. As a result of the above, the Trustee can avoid the Initial Transfer to UBEF

pursuant to Section 548(a)(1)(B) of the Bankruptcy Code.

WHEREFORE, Plaintiff, Joel L. Tabas, as Chapter 7 Trustee of the bankruptcy 

estate of AAA Machinery Parts and Rentals, LLC respectfully requests this Court enter 

judgment on his behalf and against Defendant, UBEFunding LLC, as follows:

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TABAS & SOLOFF, P.A. · INGRAHAM BUILDING, 25 SOUTHEAST SECOND AVENUE, SUITE 248, MIAMI, FLORIDA 33131 ∙ (305) 375-8171

a. Determining that the Initial Transfer delivered to UBEFunding LLC, as 

set forth above, is a fraudulent transfer and is therefore avoided 

pursuant to § 548(a)(1)(B) of the Bankruptcy Code; 

b. Determining that UBEFunding LLC is the initial transferee and/or the 

entity for whose benefit the Initial Transfer was made;

c. Awarding costs of suit; and

d. Granting such other and further relief as this Court deems just and 

proper.

COUNT IV

RECOVERY OF FRAUDULENT TRANSFERS PURSUANT 

TO 11 U.S.C. § 550(a)(1) OF THE BANKRUPTCY CODE

35. Plaintiff incorporates and realleges paragraphs 1 through 16 and 30 through 

34 of this Complaint as though fully set forth herein.

36. Pursuant to 11 U.S.C. § 550, in a fraudulent transfer action commenced 

under Section 548 of the Bankruptcy Code, the trustee may recover, for the benefit of the 

estate, the property transferred, or if the court so orders, the value of such property, from 

– (1) the initial transferee of such transfer or the entity for whose benefit such transfer 

was made; or (2) any immediate or mediate transferee of such initial transferee. 

37. UBEF was the initial transferee of the Initial Transfer and/or the entity for 

whose benefit the Initial Transfer was made.

38. The Initial Transfer is avoidable by the Plaintiff pursuant to Section 548 of 

the Bankruptcy Code and, as a result, the Initial Transfer is recoverable by the Plaintiff 

pursuant to 11 U.S.C. § 550 of the Bankruptcy Code.

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TABAS & SOLOFF, P.A. · INGRAHAM BUILDING, 25 SOUTHEAST SECOND AVENUE, SUITE 248, MIAMI, FLORIDA 33131 ∙ (305) 375-8171

WHEREFORE, Plaintiff, Joel L. Tabas, as Chapter 7 Trustee of the bankruptcy 

estate of AAA Machinery Parts and Rentals, LLC respectfully requests this Court enter 

judgment on his behalf and against Defendant, UBEFunding LLC, as follows:

a. Declaring UBEFunding LLC the initial transferee of the Initial Transfer;

b. Awarding damages in the total amount of the Initial Transfer, plus prejudgment interest, in favor of Plaintiff and directing UBEFunding LLC to 

turn over the Initial Transfer pursuant to 11 U.S.C. § 550 of the 

Bankruptcy Code;

c. Awarding costs of suit; and

d. Granting such other and further relief as this Court deems just and 

proper.

COUNT V

AVOIDANCE OF FRAUDULENT TRANSFER PURSUANT 

TO 11 U.S.C. § 544(b)(1) AND FLA. STAT. § 726.105(1)(a)

39. Plaintiff realleges paragraphs 1 through 16 of this Complaint as though fully 

set forth herein.

40. Within the four (4) year period immediately preceding the Petition Date, the 

Debtor made the Initial Transfer directly to UBEF.

41. The Initial Transfer constitutes a transfer of an interest of the Debtor’s, and 

now, Plaintiff’s property.

42. The Debtor made the Initial Transfer to UBEF with the intent to hinder, 

delay, or defraud a creditor of the Debtor whose claim arose prior to the dates of the Initial 

Transfer.

43. The Debtor had at least one creditor who could have avoided the Initial 

Transfer on the Petition Date.

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TABAS & SOLOFF, P.A. · INGRAHAM BUILDING, 25 SOUTHEAST SECOND AVENUE, SUITE 248, MIAMI, FLORIDA 33131 ∙ (305) 375-8171

WHEREFORE, Plaintiff, Joel L. Tabas, as Chapter 7 Trustee of the bankruptcy 

estate of AAA Machinery Parts and Rentals, LLC respectfully requests this Court enter 

judgment on his behalf and against Defendant, UBEFunding LLC, as follows:

a. declaring the Initial Transfer a fraudulent transfer pursuant to § 

726.105(1)(a) of the Florida Statutes;

b. ordering that the Initial Transfer be avoided pursuant to § 726.105(1)(a) of 

the Florida Statutes; 

c. awarding costs of suit; and

d. granting such other and further relief as this Court deems just and proper.

COUNT VI

RECOVERY OF TRANSFER PURSUANT TO 

FLA. STAT. §§ 726.108 AND 726.109 AND 11 U.S.C. §§ 550 

44. The Plaintiff realleges each and every allegation contained in Paragraphs 1 

through 16 and 40 through 43 of this Complaint as though fully set forth herein.

45. UBEF was the initial transferee of the Initial Transfer and/or the entity for 

whose benefit the Initial Transfer was made.

46. The Initial Transfer is avoidable by the Plaintiff pursuant to Section 

726.105(1)(a), and as a result, the Initial Transfer, is recoverable by Plaintiff pursuant to 

Sections 726.108 and 726.109 of the Florida Statutes and Sections 544 and 550 of the 

Bankruptcy Code.

WHEREFORE, Plaintiff, Joel L. Tabas, as Chapter 7 Trustee of the bankruptcy 

estate of AAA Machinery Parts and Rentals, LLC respectfully requests this Court enter 

judgment on his behalf and against Defendant, UBEFunding LLC, as follows:

a. Declaring UBEFunding LLC the initial transferee of the Initial Transfer;

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TABAS & SOLOFF, P.A. · INGRAHAM BUILDING, 25 SOUTHEAST SECOND AVENUE, SUITE 248, MIAMI, FLORIDA 33131 ∙ (305) 375-8171

b. awarding damages in the total amount of the Initial Transfer, plus prejudgment interest, in favor of Plaintiff and directing UBEFunding LLC to turn 

over the Initial Transfer pursuant to Sections 726.108 and 726.109 of the 

Florida Statutes and Sections 544 and 550 of the Bankruptcy Code; 

c. awarding costs of suit; and

d. granting such other and further relief as this Court deems just and proper.

COUNT VII

AVOIDANCE OF FRAUDULENT TRANSFER PURSUANT 

TO 11 U.S.C. § 544(b)(1) AND FLA. STAT. 726.105(1)(b) 

47. Plaintiff realleges paragraphs 1 through 16 of this Complaint as though fully 

set forth herein.

48. Within the four (4) year period immediately preceding the Petition Date, the 

Debtor made the Initial Transfer directly to UBEF.

49. The Initial Transfer constituted a transfer of an interest of the Debtor’s, and 

now, Plaintiff’s property.

50. The Debtor did not receive reasonably equivalent value in exchange for the 

Initial Transfer.

51. The Initial Transfer was made to UBEF: (1) when the Debtor was insolvent; 

(2) when the Debtor was engaged in business or a transaction, or was about to engage 

in business or a transaction, for which any property remaining with the Debtor was 

unreasonably small capital; or (3) when the Debtor intended to incur or, believed that it 

would incur, debts that would be beyond the Debtor’s ability to pay as such debts matured.

52. The Debtor had at least one creditor who could have avoided the Initial 

Transfer on the Petition Date.

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TABAS & SOLOFF, P.A. · INGRAHAM BUILDING, 25 SOUTHEAST SECOND AVENUE, SUITE 248, MIAMI, FLORIDA 33131 ∙ (305) 375-8171

WHEREFORE, Plaintiff, Joel L. Tabas, as Chapter 7 Trustee of the bankruptcy 

estate of AAA Machinery Parts and Rentals, LLC respectfully requests this Court enter 

judgment on his behalf and against Defendant, UBEFunding LLC, as follows:

a. declaring the Initial Transfer a fraudulent transfer pursuant to § 

726.105(1)(b) of the Florida Statutes;

b. ordering that the Initial Transfer be avoided pursuant to § 726.105(1)(b) of 

the Florida Statutes; 

c. awarding costs of suit; and

d. granting such other and further relief as this Court deems just and proper.

COUNT VIII

RECOVERY OF TRANSFER PURSUANT TO 

FLA. STAT. §§ 726.108 AND 726.109 AND 11 U.S.C. §§ 550 

53. The Plaintiff realleges each and every allegation contained in Paragraphs 1 

through 16 and 48 through 52 of this Complaint as though fully set forth herein.

54. UBEF was the initial transferee of the Initial Transfer.

55. The Initial Transfer is avoidable by the Plaintiff pursuant to Section 

726.105(1)(b), and as a result, the Initial Transfer is recoverable by Plaintiff pursuant to 

Sections 726.108 and 726.109 of the Florida Statutes and Sections 544 and 550 of the 

Bankruptcy Code.

WHEREFORE, Plaintiff, Joel L. Tabas, as Chapter 7 Trustee of the bankruptcy 

estate of AAA Machinery Parts and Rentals, LLC respectfully requests this Court enter 

judgment on his behalf and against Defendant, UBEFunding LLC, as follows:

a. declaring UBEFunding LLC the initial transferees of the Initial 

Transfer; 

b. awarding damages in the total amount of the Initial Transfer, plus prejudgment interest, in favor of Plaintiff and directing UBEFunding LLC

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to turn over the Initial Transfer pursuant to Sections 726.108 and 

726.109 of the Florida Statutes and Sections 544 and 550 of the 

Bankruptcy Code; 

c. awarding costs of suit; and

d. granting such other and further relief as this Court deems just and 

proper.

COUNT IX

AVOIDANCE OF FRAUDULENT TRANSFER PURSUANT 

TO 11 U.S.C. § 544(b)(1) AND FLA. STAT. 726.106(1) 

56. Plaintiff realleges paragraphs 1 through 16 of this Complaint as though fully 

set forth herein.

57. Within the four (4) year period immediately preceding the Petition Date, the 

Debtor made the Initial Transfer to UBEF.

58. The Initial Transfer constitutes a transfer of an interest of the Debtor’s, and 

now, Plaintiff’s property.

59. The Debtor did not receive reasonably equivalent value in exchange for the 

Initial Transfer.

60. The Debtor was insolvent at the time of the Initial Transfer or became 

insolvent as a result of the Initial Transfer.

61. The Debtor had at least one creditor who could have avoided the Initial 

Transfer on the Petition Date.

WHEREFORE, Plaintiff, Joel L. Tabas, as Chapter 7 Trustee of the bankruptcy 

estate of AAA Machinery Parts and Rentals, LLC respectfully requests this Court enter 

judgment on his behalf and against Defendant, UBEFunding LLC, as follows:

a. declaring the Initial Transfer a fraudulent transfer pursuant to § 726.106(1) 

of the Florida Statutes;

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TABAS & SOLOFF, P.A. · INGRAHAM BUILDING, 25 SOUTHEAST SECOND AVENUE, SUITE 248, MIAMI, FLORIDA 33131 ∙ (305) 375-8171

b. ordering that the Initial Transfer be avoided pursuant to § 726.106(1) of the 

Florida Statutes; 

c. awarding costs of suit; and

d. granting such other and further relief as this Court deems just and proper.

COUNT X

RECOVERY OF TRANSFER PURSUANT TO 

FLA. STAT. §§ 726.108 AND 726.109 AND 11 U.S.C. §§ 550 

62. The Plaintiff realleges each and every allegation contained in Paragraphs 1 

through 16 and 57 through 61 of this Complaint as though fully set forth herein.

63. UBEF was the initial transferee of the Initial Transfer.

64. The Initial Transfer is avoidable by the Plaintiff pursuant to Section 

726.106(1) and as a result, the Initial Transfer is recoverable by Plaintiff pursuant to 

Sections 726.108 and 726.109 of the Florida Statutes and Sections 544 and 550 of the 

Bankruptcy Code.

WHEREFORE, Plaintiff, Joel L. Tabas, as Chapter 7 Trustee of the bankruptcy 

estate of AAA Machinery Parts and Rentals, LLC respectfully requests this Court enter 

judgment on his behalf and against Defendant, UBEFunding LLC, as follows:

a. declaring the UBEFunding LLC the initial transferees of the Initial Transfer; 

b. awarding damages in the total amount of the Initial Transfer, plus prejudgment interest, in favor of Plaintiff and directing UBEFunding LLC to turn 

over the Initial Transfer pursuant to Sections 726.108 and 726.109 of the 

Florida Statutes and Sections 544 and 550 of the Bankruptcy Code;

c. awarding costs of suit; and

d. granting such other and further relief as this Court deems just and proper.

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COUNT XI

RECOVERY OF SUBSEQUENT TRANSFER PURSUANT TO 

FLA. STAT. §§ 726.108 AND 726.109 AND 11 U.S.C. §§ 550 AND 551

65. The Plaintiff realleges each and every allegation contained in Paragraphs 1 

through 16, 18 through 23, 30 through 34, 40 through 43, 48 through 52, and 57 through 

61 of this Complaint as though fully set forth herein.

66. The Initial Transfer is avoidable by the Plaintiff pursuant to 11 U.S.C. §§ 

544 and 548 of the Bankruptcy Code and §§ 726.105 and 726.106 of the Florida Statutes.

67. As a result of the Transfers, Morales received the Real Property.

68. Pursuant to 11 U.S.C. § 550, in a fraudulent transfer action commenced 

under Section 548 of the Bankruptcy Code, the trustee may recover, for the benefit of the 

estate, the property transferred, or if the court so orders, the value of such property, from 

- (1) the initial transferee of such transfer or the entity for whose benefit such transfer was 

made; or (2) any immediate or mediate transferee of such initial transferee.

69. Morales was the subsequent transferee of the Transfers. Morales lacked 

good faith, and is liable for the Subsequent Transfer under §§ 550 and 551 of the 

Bankruptcy Code and under §§ 726.108 and 726.109 of the Florida Statutes.

WHEREFORE, Plaintiff, Joel L. Tabas, as Chapter 7 Trustee of the bankruptcy 

estate of AAA Machinery Parts and Rentals, LLC respectfully requests this Court enter 

judgment on his behalf and against Defendant, Angel Romer Morales, as follows:

a. declaring Angel Romer Morales the subsequent transferee of the Transfers;

b. awarding damages in the total amount of the Subsequent Transfer, plus 

pre-judgment interest, in favor of Plaintiff and directing Angel Romer 

Morales to turn over the Subsequent Transfer pursuant to §§ 550 and 551 

of the Bankruptcy Code and under §§ 726.108 and 726.109 of the Florida 

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Statutes;

c. awarding costs of suit; and

d. granting such other and further relief as this Court deems just and proper.

Dated this 4

th day of March, 2021.

Respectfully submitted,

/s/ Jessika A. Graham

Joel L. Tabas

Florida Bar No. 516902

Jessika A. Graham

Florida Bar No. 72452

Tabas & Soloff, P.A.

Attorneys for Plaintiff, Joel L. Tabas

Ingraham Building

25 SE Second Avenue – Suite 248

Miami, Florida 33131

Telephone: (305) 375-8171

Facsimile: (305) 381-7708

jtabas@tabassoloff.com

jgraham@tabassoloff.com

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