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scion

02/09/16 3:41 PM

#67481 RE: ca boy #67471

Management authorized the filing of an adversary proceeding against Welch that will be shown to be totally without merit, and even if it were not, the recovery the adversary proceeding seeks is the return of shares in the Debtor that would appear to be worthless based on the Debtor’s prospects for rehabilitation under chapter 11, a waste of estate assets;

9. The actions of Debtor’s current management exhibit dishonesty, incompetence, gross mismanagement of the Debtor’s affairs, and constitute cause to convert this case or appoint a trustee. Further, the Debtor has assets of less than $1,000, no business operations, and no indication that there is a reasonable likelihood of rehabilitation under chapter 11.

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OCR extract -
Doc 33 PDF file
http://www.scribd.com/doc/210775038/Republic-of-Texas-Brands-3-36434-Bjh11-BK-Doc-33