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Legal Motion Contesting Execution
Summary
James Cronan is contesting a writ of execution in Rhode Island, alleging fraudulent conveyance and mismanagement by Mr. Grieco and Mr. Tiernan. The motion highlights issues such as embezzlement, commingling of funds, and tax evasion. An emergency stay is requested due to a related complaint filed in Bristol Superior Court, which could cause irreparable harm. The case involves complex legal issues, including mortgage fraud and conspiracy, dating back to 2010.Full Conversation
its not a document rather it what i wrote. Ok?
Got it. To give you better guidance, could you please briefly describe the issues addressed in each of the motions? This will help determine if they should be kept separate or combined.
United States Bankruptcy Court
[District of Rhode Island]
In re:
James Cronan, Debtor
Case No.: [Insert Case Number]
James Cronan, Movant
v.
* Fountain Street, Assignee Mr. Tiernan, Respondent
MOTION TO CONTEST WRIT OF EXECUTION
NOW COMES Movant, James Cronan, and hereby files this Motion to Contest the Writ of Execution issued by the Court in favor of Respondent, * Fountain Street, Assignee Mr. Tiernan. In support of this Motion, Movant states as follows:
*. Background
- In *, a default judgment was entered against Movant, James Cronan, in favor of the Trustee in the Chapter * case.
- The judgment entered for damages against James Cronan was $*,*.* plus *% interest and against Karen Cronan (now Karen Merritt) for damages in the amount of $*,* plus *% interest in the Adversary proceedings.
- The judgment was based on allegations of fraud, and Movant did not attend the hearing due to misunderstanding and misrepresentation by CPA Mr. Grieco.
In your situation, combining or separating the motions depends on the legal issues and parties involved. Since your motion involves contesting a writ of execution due to a default judgment, it might be beneficial to address each motion separately if they involve different facts or legal arguments.
Could you provide details on the second motion?
Could you provide details on the second motion?
Honorable Judge Diane Finkle,
I,Karen Merritt, respectfully submit this Motion to Contest the Writ of Execution issued against me in the case related to Classic Display, Inc. (Case No: *:*-bk-*) by the U.S. Bankruptcy Court for the District of Rhode Island.
Homestead Exemption:
- On January *, *, I filed a Homestead exemption with the Bristol County Registry of Deeds, providing me with $* million coverage under the Massachusetts Homestead Act (Mass. Gen. Laws ch. *, § * et seq.).
Fraudulent Conveyance and Existing Lien:
- The assignee, James Tiernan, has a lien on * Oak Street through fraud.
Hi Karen, based on the information provided, it seems like your situation involves complex issues related to bankruptcy, fraud, and homestead exemptions. Here are a few points to consider:
- Separate motions if they address distinct legal issues.
- Combine if they are intertwined or involve the same parties.
Would you like more details on how to effectively structure your motions?
- Separate motions if they address distinct legal issues.
- Combine if they are intertwined or involve the same parties.
Would you like more details on how to effectively structure your motions?
- * Oak Street was included in a fraudulent conveyance by James Tiernan on October *, *. The Southeast Housing Court ordered my eviction from * Brayton Woods, Rehoboth, MA, leading to my move to * Oak Street.
- The writ is based on fraud, and Mr. Tiernan already has a lien on the property.
Judicial Estoppel:
- On October *, *, James Tiernan testified before the Honorable Richard Stearns at the U.S. District Court that the foreclosure/transfer recorded on May *, *, for * Brayton Woods, Rehoboth, MA, violated state foreclosure and usury laws.
- This illegal foreclosure included * Oak Street, Norton, MA; however, Tiernan only transferred the Rehoboth property but holds a lien on * Oak Street.
Karen, your motions address complex issues involving fraudulent conveyance, homestead exemptions, and judicial estoppel. Given these complexities, it might be best to keep the motions separate to avoid confusion and ensure each issue is clearly presented.
Would you like more detailed guidance on structuring each motion effectively?
Would you like more detailed guidance on structuring each motion effectively?
yes. Here is what I wrote for Jame's motion.*. Fraudulent Conveyance
- The default judgment was purchased by * Fountain Street LLC and Mr. Tiernan as its assignee for $*,*, significantly below its value of $*,*, to offset damages in a lawsuit that Movant has against Mr. Tiernan for illegal foreclosure, usury violations, breach of contract, and violations under Massachusetts General Laws Chapter 93A.
- The purchase of the judgment was not made in good faith as required under * U.S.C. *(m) as a prerequisite for the court to order the writ of execution.
*. Misrepresentation and Mismanagement
- Movant was advised by Mr. Grieco to move from Chapter * to Chapter * under the promise that his sole ownership of a $*.* million commercial building would be restored after the sale.
Karen, based on what you’ve shared, here are a few key points you might want to include in James' motion:
- Fraudulent Conveyance:
- The default judgment was undervalued and purchased in bad faith.
- Violations under Massachusetts General Laws Chapter 93A.
- Misrepresentation:
- Misguided advice from Mr. Grieco led to significant financial mismanagement.
Would you like help with any specific sections?
- Fraudulent Conveyance:
- The default judgment was undervalued and purchased in bad faith.
- Violations under Massachusetts General Laws Chapter 93A.
- Misrepresentation:
- Misguided advice from Mr. Grieco led to significant financial mismanagement.
Would you like help with any specific sections?
- After the transfer, Mr. Grieco and Mr. Tiernan failed to return Movant’s name to the title of the building and instead transferred ownership to * Fountain Street, LLC.
- Mr. Grieco and Mr. Tiernan engaged in fraudulent activities, including embezzlement, commingling of funds, and tax evasion, as evidenced by forensic CPA Lori Horton’s report.
*. Indigency and Financial Hardship
- Movant was indigent and unable to pay the $*,* demanded by the Trustee's agent to finalize the adversary proceeding.
- Movant’s financial records were destroyed by Mr. Grieco and Mr. Tiernan, causing further financial hardship.
Karen, your case involves significant legal issues, including fraudulent conveyance, misrepresentation, and financial hardship. Here are some key points to structure James' motion:
- Fraudulent Conveyance:
- Undervalued judgment purchased in bad faith.
- Violations of Massachusetts General Laws Chapter 93A.
- Misrepresentation and Mismanagement:
- Misguided advice from Mr. Grieco.
- Ownership transfer to * Fountain Street, LLC without restoring Movant’s title.
- Financial Hardship:
- Indigency and inability to pay required fees.
- Destruction of financial records by Mr. Grieco and Mr. Tiernan.
Would you like assistance with Karen’s motion too?
- Fraudulent Conveyance:
- Undervalued judgment purchased in bad faith.
- Violations of Massachusetts General Laws Chapter 93A.
- Misrepresentation and Mismanagement:
- Misguided advice from Mr. Grieco.
- Ownership transfer to * Fountain Street, LLC without restoring Movant’s title.
- Financial Hardship:
- Indigency and inability to pay required fees.
- Destruction of financial records by Mr. Grieco and Mr. Tiernan.
Would you like assistance with Karen’s motion too?
*. Threats and Coercion
- Movant was threatened by Mr. Grieco and Mr. Tiernan to stop asking to put his name back on the commercial building, under threat of foreclosure on Karen’s property.
- Movant was coerced into moving from Chapter * to Chapter * based on false promises that the building ownership would be restored.
- James’ affidavit detailing the threats made by Mr. Tiernan and Mr. Grieco is included.
*. Evidence
- Bill of Sale: Document showing the transfer of ownership of James' original business, Classic Display, to Mr. Grieco.
- Court Tape: Recording of the court proceedings where Mr. Grieco establishes himself as James' accountant and partner.
Karen, it sounds like James' motion involves serious allegations of fraud, misrepresentation, and financial hardship. Here are some key points you might include for clarity:
- Threats and Coercion:
- Specific threats made by Mr. Grieco and Mr. Tiernan.
- Coercion to switch bankruptcy chapters.
- Evidence:
- Bill of Sale.
- Court Tape.
- Tax Returns.
- Share Transfer documentation.
- Forensic CPA Report by Lori Horton.
Would you like help with organizing Karen's motion further?
- Threats and Coercion:
- Specific threats made by Mr. Grieco and Mr. Tiernan.
- Coercion to switch bankruptcy chapters.
- Evidence:
- Bill of Sale.
- Court Tape.
- Tax Returns.
- Share Transfer documentation.
- Forensic CPA Report by Lori Horton.
Would you like help with organizing Karen's motion further?
- Tax Returns: Two years of tax returns filed by Mr. Grieco showing James as an officer of the new company, The Classic Group Inc.
- Share Transfer: Evidence of the transfer of * shares from James to Mr. Tiernan under the promise of a tax break.
- Forensic CPA Report: Report by Lori Horton showing commingling of funds, tax evasion, and embezzlement.
- Foreclosure Deed: Document showing the foreclosure on Karen’s property as a result of Mr. Tiernan's threats.
- Federal Complaint: Complaint filed in federal court against Mr. Tiernan for illegal foreclosure.
- Order Granting Motion for Approval of Sale: Document showing the court's reliance on false representations about the sale's fairness and the buyer's good faith under * U.S.C. *(m).
Here’s a concise structure for both James' and Karen's motions:
James' Motion:
*. Fraudulent Conveyance:
- Undervalued judgment purchased in bad faith.
- Violations of Mass. General Laws Chapter 93A.
*. Misrepresentation and Mismanagement:
- Misguided advice from Mr. Grieco.
- Improper ownership transfer to * Fountain Street, LLC.
*. Financial Hardship:
- Indigency and inability to pay fees.
- Destruction of financial records.
*. Threats and Coercion:
- Specific threats by Mr. Grieco and Mr. Tiernan.
- Coercion to switch bankruptcy chapters.
*. Evidence:
- Bill of Sale, Court Tape, Tax Returns, Share Transfer documentation, Forensic CPA Report.
*. Fraudulent Conveyance:
- Undervalued judgment purchased in bad faith.
- Violations of Mass. General Laws Chapter 93A.
*. Misrepresentation and Mismanagement:
- Misguided advice from Mr. Grieco.
- Improper ownership transfer to * Fountain Street, LLC.
*. Financial Hardship:
- Indigency and inability to pay fees.
- Destruction of financial records.
*. Threats and Coercion:
- Specific threats by Mr. Grieco and Mr. Tiernan.
- Coercion to switch bankruptcy chapters.
*. Evidence:
- Bill of Sale, Court Tape, Tax Returns, Share Transfer documentation, Forensic CPA Report.
Karen's Motion:
*. Homestead Exemption:
- Filed exemption providing $* million coverage.
*. Fraudulent Conveyance and Existing Lien:
- Lien on * Oak Street through fraud.
- Details of the fraudulent conveyance.
*. Judicial Estoppel:
- TestHere’s a concise structure for both James' and Karen's motions:
*. Homestead Exemption:
- Filed exemption providing $* million coverage.
*. Fraudulent Conveyance and Existing Lien:
- Lien on * Oak Street through fraud.
- Details of the fraudulent conveyance.
*. Judicial Estoppel:
- TestHere’s a concise structure for both James' and Karen's motions:
James' Motion:
*. Fraudulent Conveyance:
- Undervalued judgment purchased in bad faith.
- Violations of Mass. General Laws Chapter 93A.
*. Misrepresentation and Mismanagement:
- Misguided advice from Mr. Grieco.
- Improper ownership transfer to * Fountain Street, LLC.
*. Financial Hardship:
- Indigency and inability to pay fees.
- Destruction of financial records by Mr. Grieco and Mr. Tiernan.
*. Threats and Coercion:
- Specific threats by Mr. Grieco and Mr. Tiernan.
- Coercion to switch bankruptcy chapters.
*. Evidence:
- Bill of Sale, Court Tape, Tax Returns, Share Transfer documentation, Forensic CPA Report.
*. Threats and Coercion
- Movant was threatened by Mr. Grieco and Mr. Tiernan to stop asking to put his name back on the commercial building, under threat of foreclosure on Karen’s property.
- Movant was coerced into moving from Chapter * to Chapter * based on false promises that the building ownership would be restored.
- James’ affidavit detailing the threats made by Mr. Tiernan and Mr. Grieco is included.
*. Evidence
- Bill of Sale: Document showing the transfer of ownership of James' original business, Classic Display, to Mr. Grieco.
- Court Tape: Recording of the court proceedings where Mr. Grieco establishes himself as James' accountant and partner.
- Tax Returns: Two years of tax returns filed by Mr. Grieco showing James as an officer of the new company, The Classic Group Inc.
- Share Transfer: Evidence of the transfer of * shares from James to Mr. Tiernan under the promise of a tax break.
- Forensic CPA Report: Report by Lori Horton showing commingling of funds, tax evasion, and embezzlement.
- Foreclosure Deed: Document showing the foreclosure on Karen’s property as a result of Mr. Tiernan's threats.
- Federal Complaint: Complaint filed in federal court against Mr. Tiernan for illegal foreclosure.
- Order Granting Motion for Approval of Sale: Document showing the court's reliance on false representations about the sale's fairness and the buyer's good faith under * U.S.C. *(m).
- Motion Filed by * Fountain Street: Document showing false statements under Rule *(b)*, indicating fraud on the court.
- * Fountain Street LLC's Motion for Issuance of Writ of Execution: Document showing false statements under Rule *(b)(*), indicating fraud on the court. The motion falsely claimed that * Fountain Street LLC was a "Creditor" and requested issuance of a Writ of Execution when in fact they were a debtor involved in a fraudulent conveyance to defraud a creditor, Karen Merritt, one of the movants in this case.
*. Request for Relief
- Movant requests the Court to contest and set aside the Writ of Execution based on the fraudulent activities and misrepresentation by Mr. Grieco, Mr
*. Fraudulent Conveyance:
- Undervalued judgment purchased in bad faith.
- Violations of Mass. General Laws Chapter 93A.
*. Misrepresentation and Mismanagement:
- Misguided advice from Mr. Grieco.
- Improper ownership transfer to * Fountain Street, LLC.
*. Financial Hardship:
- Indigency and inability to pay fees.
- Destruction of financial records by Mr. Grieco and Mr. Tiernan.
*. Threats and Coercion:
- Specific threats by Mr. Grieco and Mr. Tiernan.
- Coercion to switch bankruptcy chapters.
*. Evidence:
- Bill of Sale, Court Tape, Tax Returns, Share Transfer documentation, Forensic CPA Report.
Karen's Motion:
*. Homestead Exemption:
- Filed exemption providing $* million coverage.
*. Fraudulent Conveyance and Existing Lien:
- Lien on * Oak Street through fraud.
- Details of the fraudulent conveyance.
*.
*. Homestead Exemption:
- Filed exemption providing $* million coverage.
*. Fraudulent Conveyance and Existing Lien:
- Lien on * Oak Street through fraud.
- Details of the fraudulent conveyance.
*.
- Motion Filed by * Fountain Street: Document showing false statements under Rule *(b)*, indicating fraud on the court
- * Fountain Street LLC's Motion for Issuance of Writ of Execution: Document showing false statements under Rule *(b)(*), indicating fraud on the court. The motion falsely claimed that * Fountain Street LLC was a "Creditor" and requested issuance of a Writ of Execution when in fact they were a debtor involved in a fraudulent conveyance to defraud a creditor, Karen Merritt, one of the movants in this case.
*. Request for Relief
- Movant requests the Court to contest and set aside the Writ of Execution based on the fraudulent activities and misrepresentation by Mr. Grieco, Mr. Tiernan, and * Fountain Street LLC.
- Movant seeks an order to reopen the adversary proceeding and to challenge the default judgment on the grounds of fraud and mismanagement.
- Movant requests a hearing to present evidence and arguments supporting the motion.
Karen, both motions contain significant allegations of fraud, misrepresentation, and financial hardship. Here are key points to structure James' motion effectively:
- Fraudulent Conveyance:
- Undervalued judgment purchased in bad faith.
- Violations of Massachusetts General Laws Chapter 93A.
- Misrepresentation and Mismanagement:
- Misguided advice from Mr. Grieco.
- Ownership transfer to * Fountain Street, LLC without restoring Movant’s title.
- Financial Hardship:
- Indigency and inability to pay required fees.
- Destruction of financial records by Mr. Grieco and Mr. Tiernan.
- Threats and Coercion:
- Specific threats made by Mr. Grieco and Mr. Tiernan.
- Coercion to switch bankruptcy chapters.
- Evidence:
- Bill of Sale.
- Court Tape.
- Tax Returns.
- Share Transfer documentation.
- Forensic CPA Report by Lori Horton.
- Foreclosure Deed.
- Federal Complaint.
- Order Granting Motion for Approval of Sale.
Would you like assistance with any specific sections or further details on how tostructure each part?
- Fraudulent Conveyance:
- Undervalued judgment purchased in bad faith.
- Violations of Massachusetts General Laws Chapter 93A.
- Misrepresentation and Mismanagement:
- Misguided advice from Mr. Grieco.
- Ownership transfer to * Fountain Street, LLC without restoring Movant’s title.
- Financial Hardship:
- Indigency and inability to pay required fees.
- Destruction of financial records by Mr. Grieco and Mr. Tiernan.
- Threats and Coercion:
- Specific threats made by Mr. Grieco and Mr. Tiernan.
- Coercion to switch bankruptcy chapters.
- Evidence:
- Bill of Sale.
- Court Tape.
- Tax Returns.
- Share Transfer documentation.
- Forensic CPA Report by Lori Horton.
- Foreclosure Deed.
- Federal Complaint.
- Order Granting Motion for Approval of Sale.
Would you like assistance with any specific sections or further details on how tostructure each part?
can I now send you the rest of Karen's motion?
Case Rating: *
Karen, while I can't directly review or combine documents, I'm happy to help guide you with structuring and detailing your motions.
Based on what you've shared, it's crucial to provide clear and concise points for each section. Feel free to share any specific sections or details you need help with, and I'll do my best to assist you!
Would you like more detailed guidance on any specific part of Karen's motion?
Karen, while I can't directly review or combine documents, I'm happy to help guide you with structuring and detailing your motions.
Based on what you've shared, it's crucial to provide clear and concise points for each section. Feel free to share any specific sections or details you need help with, and I'll do my best to assist you!
Would you like more detailed guidance on any specific part of Karen's motion?
its not a document. Im sorry to keep saying that. Its what you already wrote with me. Can you plish James motion. Or is my writing fine as it is?
James' Motion:
*. Fraudulent Conveyance:
- Judgment undervalued and purchased in bad faith.
- Violations of Mass. General Laws Chapter 93A.
*. Misrepresentation and Mismanagement:
- Misguided advice from Mr. Grieco.
- Ownership improperly transferred to * Fountain Street, LLC.
*. Financial Hardship:
- Indigency and inability to pay fees.
- Destruction of financial records by Mr. Grieco and Mr. Tiernan.
*. Threats and Coercion:
- Threats and coercion by Mr. Grieco and Mr. Tiernan to switch bankruptcy chapters.
*. Evidence:
- Bill of Sale.
- Court Tape.
- Tax Returns.
- Share Transfer documentation.
- Forensic CPA Report.
- Foreclosure Deed.
- Federal Complaint.
- Order Granting Motion for Approval of Sale.
*. Request for Relief:
- Set aside the Writ of Execution based on fraud and misrepresentation.
- Reopen the adversary proceeding and challenge the default judgment.
- Request a hearing to present evidence.
Wouldyou like help with any other specific sections or further guidance on structuring Karen's motion?
*. Fraudulent Conveyance:
- Judgment undervalued and purchased in bad faith.
- Violations of Mass. General Laws Chapter 93A.
*. Misrepresentation and Mismanagement:
- Misguided advice from Mr. Grieco.
- Ownership improperly transferred to * Fountain Street, LLC.
*. Financial Hardship:
- Indigency and inability to pay fees.
- Destruction of financial records by Mr. Grieco and Mr. Tiernan.
*. Threats and Coercion:
- Threats and coercion by Mr. Grieco and Mr. Tiernan to switch bankruptcy chapters.
*. Evidence:
- Bill of Sale.
- Court Tape.
- Tax Returns.
- Share Transfer documentation.
- Forensic CPA Report.
- Foreclosure Deed.
- Federal Complaint.
- Order Granting Motion for Approval of Sale.
*. Request for Relief:
- Set aside the Writ of Execution based on fraud and misrepresentation.
- Reopen the adversary proceeding and challenge the default judgment.
- Request a hearing to present evidence.
Wouldyou like help with any other specific sections or further guidance on structuring Karen's motion?
polish
Sure, Karen! Here’s a more polished version of James' motion for you:
---
United States Bankruptcy Court
[District of Rhode Island]
In re:
James Cronan, Debtor
Case No.: [Insert Case Number]
James Cronan, Movant
v.
* Fountain Street, Assignee Mr. Tiernan, Respondent
MOTION TO CONTEST WRIT OF EXECUTION
NOW COMES Movant, James Cronan, and hereby files this Motion to Contest the Writ of Execution issued by the Court in favor of Respondent, * Fountain Street, Assignee Mr. Tiernan. In support of this Motion, Movant states as follows:
*. Fraudulent Conveyance
- The default judgment was purchased by * Fountain Street LLC and Mr. Tiernan as its assignee for $*,*, significantly below its value of $*,*, to offset damages in a lawsuit that Movant has against Mr. Tiernan for illegal foreclosure, usury violations, breach of contract, and violations under Massachusetts General Laws Chapter 93A.
- The purchase of the judgment was not made in good faith as required under * U.S.C. Sure, Karen! Here’s a more polished version of James' motion for you:
---
United States Bankruptcy Court
[District of Rhode Island]
In re:
James Cronan, Debtor
Case No.: [Insert Case Number]
James Cronan, Movant
v.
* Fountain Street, Assignee Mr. Tiernan, Respondent
MOTION TO CONTEST WRIT OF EXECUTION
NOW COMES Movant, James Cronan, and hereby files this Motion to Contest the Writ of Execution issued by the Court in favor of Respondent, * Fountain Street, Assignee Mr. Tiernan. In support of this Motion, Movant states as follows:
*. Fraudulent Conveyance
- The default judgment was purchased by * Fountain Street LLC and Mr. Tiernan as its assignee for $*,*, significantly below its value of $*,*, to offset damages in a lawsuit that Movant has against Mr. Tiernan for illegal foreclosure, usury violations, breach of contract, and violations under Massachusetts General Laws Chapter 93A.
- The purchase of the judgment was not made in good faith as required under * U.S.C.
---
United States Bankruptcy Court
[District of Rhode Island]
In re:
James Cronan, Debtor
Case No.: [Insert Case Number]
James Cronan, Movant
v.
* Fountain Street, Assignee Mr. Tiernan, Respondent
MOTION TO CONTEST WRIT OF EXECUTION
NOW COMES Movant, James Cronan, and hereby files this Motion to Contest the Writ of Execution issued by the Court in favor of Respondent, * Fountain Street, Assignee Mr. Tiernan. In support of this Motion, Movant states as follows:
*. Fraudulent Conveyance
- The default judgment was purchased by * Fountain Street LLC and Mr. Tiernan as its assignee for $*,*, significantly below its value of $*,*, to offset damages in a lawsuit that Movant has against Mr. Tiernan for illegal foreclosure, usury violations, breach of contract, and violations under Massachusetts General Laws Chapter 93A.
- The purchase of the judgment was not made in good faith as required under * U.S.C. Sure, Karen! Here’s a more polished version of James' motion for you:
---
United States Bankruptcy Court
[District of Rhode Island]
In re:
James Cronan, Debtor
Case No.: [Insert Case Number]
James Cronan, Movant
v.
* Fountain Street, Assignee Mr. Tiernan, Respondent
MOTION TO CONTEST WRIT OF EXECUTION
NOW COMES Movant, James Cronan, and hereby files this Motion to Contest the Writ of Execution issued by the Court in favor of Respondent, * Fountain Street, Assignee Mr. Tiernan. In support of this Motion, Movant states as follows:
*. Fraudulent Conveyance
- The default judgment was purchased by * Fountain Street LLC and Mr. Tiernan as its assignee for $*,*, significantly below its value of $*,*, to offset damages in a lawsuit that Movant has against Mr. Tiernan for illegal foreclosure, usury violations, breach of contract, and violations under Massachusetts General Laws Chapter 93A.
- The purchase of the judgment was not made in good faith as required under * U.S.C.
Please note and this may sound confusingthat the movant which is stated in section * is Karen Merritt the other debtor in this case which is filing concurrently her motion. Additionally * fountain street (fraudlently trnasferred in this case) Mr. Grieco, James and Karen's long term CPA and * Founatin street and Classic Group CPA now is holder of the title of * Fountain Stree LLC. which in a party in this case and they are omitting James Cronan and karen Merritt has a lawsuit in Superior court MA. Additionally karen Merritt has a case against Mr. tiernan in Federal Court.
Karen, here is a polished version of James' motion for you:
---
United States Bankruptcy Court
District of Rhode Island
In re:
James Cronan, Debtor
Case No.: [Insert Case Number]
James Cronan, Movant
v.
* Fountain Street, Assignee Mr. Tiernan, Respondent
MOTION TO CONTEST WRIT OF EXECUTION
NOW COMES Movant, James Cronan, and hereby files this Motion to Contest the Writ of Execution issued by the Court in favor of Respondent, * Fountain Street, Assignee Mr. Tiernan. In support of this Motion, Movant states as follows:
*. Fraudulent Conveyance
- The default judgment was purchased by * Fountain Street LLC and Mr. Tiernan as its assignee for $*,*, significantly below its value of $*,*, to offset damages in a lawsuit that Movant has against Mr. Tiernan for illegal foreclosure, usury violations, breach of contract, and violations under Massachusetts General Laws Chapter 93A.
- The purchase of the judgment was not made in good faith asrequired under * U.S.C. *(m) as a prerequisite for the court to order the writ of execution.
*. Misrepresentation and Mismanagement
- Movant was advised by Mr. Grieco to move from Chapter * to Chapter * under the promise that his sole ownership of a $*.* million commercial building would be restored after the sale.
- After the transfer, Mr. Grieco and Mr. Tiernan failed to return Movant’s name to the title of the building and instead transferred ownership to * Fountain Street, LLC.
- Mr. Grieco and Mr. Tiernan engaged in fraudulent activities, including embezzlement, commingling of funds, and tax evasion, as evidenced by forensic CPA Lori Horton’s report.
*. Indigency and Financial Hardship
- Movant was indigent and unable to pay the $*,* demanded by the Trustee's agent to finalize the adversary proceeding.
- Movant’s financial records were destroyed by Mr. Grieco and Mr. Tiernan, causing further financial hardship.
*. Threats and Coercion
- Movant was threatened by Mr. Grieco and Mr. Tiernan to stop asking to
---
United States Bankruptcy Court
District of Rhode Island
In re:
James Cronan, Debtor
Case No.: [Insert Case Number]
James Cronan, Movant
v.
* Fountain Street, Assignee Mr. Tiernan, Respondent
MOTION TO CONTEST WRIT OF EXECUTION
NOW COMES Movant, James Cronan, and hereby files this Motion to Contest the Writ of Execution issued by the Court in favor of Respondent, * Fountain Street, Assignee Mr. Tiernan. In support of this Motion, Movant states as follows:
*. Fraudulent Conveyance
- The default judgment was purchased by * Fountain Street LLC and Mr. Tiernan as its assignee for $*,*, significantly below its value of $*,*, to offset damages in a lawsuit that Movant has against Mr. Tiernan for illegal foreclosure, usury violations, breach of contract, and violations under Massachusetts General Laws Chapter 93A.
- The purchase of the judgment was not made in good faith asrequired under * U.S.C. *(m) as a prerequisite for the court to order the writ of execution.
*. Misrepresentation and Mismanagement
- Movant was advised by Mr. Grieco to move from Chapter * to Chapter * under the promise that his sole ownership of a $*.* million commercial building would be restored after the sale.
- After the transfer, Mr. Grieco and Mr. Tiernan failed to return Movant’s name to the title of the building and instead transferred ownership to * Fountain Street, LLC.
- Mr. Grieco and Mr. Tiernan engaged in fraudulent activities, including embezzlement, commingling of funds, and tax evasion, as evidenced by forensic CPA Lori Horton’s report.
*. Indigency and Financial Hardship
- Movant was indigent and unable to pay the $*,* demanded by the Trustee's agent to finalize the adversary proceeding.
- Movant’s financial records were destroyed by Mr. Grieco and Mr. Tiernan, causing further financial hardship.
*. Threats and Coercion
- Movant was threatened by Mr. Grieco and Mr. Tiernan to stop asking to
please now only send me from section * keeping without the borderline
Name: United States Bankruptcy Court, District of Rhode Island
Phone: (*) *-*
Address: * Westminster St, Providence, RI *
Website: www.rib.uscourts.gov
Would you like assistance with any specific sections or further details on how to structure each part?
Phone: (*) *-*
Address: * Westminster St, Providence, RI *
Website: www.rib.uscourts.gov
Would you like assistance with any specific sections or further details on how to structure each part?
only send me from section * onward so that i can read the remaing motion.
Sure, here's the rest of the motion from Section * onward:
*. Threats and Coercion
- Movant was threatened by Mr. Grieco and Mr. Tiernan to stop asking to put his name back on the commercial building, under threat of foreclosure on Karen’s property.
- Movant was coerced into moving from Chapter * to Chapter * based on false promises that the building ownership would be restored.
- James’ affidavit detailing the threats made by Mr. Tiernan and Mr. Grieco is included.
*. Evidence
- Bill of Sale: Document showing the transfer of ownership of James' original business, Classic Display, to Mr. Grieco.
- Court Tape: Recording of the court proceedings where Mr. Grieco establishes himself as James' accountant and partner.
- Tax Returns: Two years of tax returns filed by Mr. Grieco showing James as an officer of the new company, The Classic Group Inc.
- Share Transfer: Evidence of the transfer of * shares from James to Mr. Tiernan under the promise of a tax break.
- Forensic CPA Report: Report by Lori Horton showing commingling of funds, tax evasion, and embezzlement.
- Foreclosure Deed: Document showing the foreclosure on Karen’s property as a result of Mr. Tiernan's threats.
- Federal Complaint: Complaint filed in federal court against Mr. Tiernan for illegal foreclosure.
- Order Granting Motion for Approval of Sale: Document showing the court's reliance on false representations about the sale's fairness and the buyer's good faith under * U.S.C. *(m).
- Motion Filed by * Fountain Street: Document showing false statements under Rule *(b)*, indicating fraud on the court.
- * Fountain Street LLC's Motion for Issuance of Writ of Execution: Document showing false statements under Rule *(b)(*), indicating fraud on the court. The motion falsely claimed that * Fountain Street LLC was a "Creditor" and requested issuance of a Writ of Execution when in fact they were a debtor involved in a fraudulent conveyance to defraud a creditor, Karen Merritt, one of the movants in this case.
*. Request for Relief
- Movant requests the Court to contest and set aside the Writ of Execution based on the fraudulent activities and misrepresentation by Mr. Grieco, Mr
can you please revise *. Misrepresentation and Mismanagement
- Movant was advised by Mr. Grieco to move from Chapter * to Chapter * under the promise that his sole ownership of a $*.* million commercial building would be restored after the sale as we say it again in section *.
Sure, Karen! Here’s a revised version of Section *:
---
*. Misrepresentation and Mismanagement
- Movant was advised by Mr. Grieco to move from Chapter * to Chapter * under the promise that his sole ownership of a $*.* million commercial building would be restored after the sale.
- After the transfer, Mr. Grieco and Mr. Tiernan failed to return Movant’s name to the title of the building and instead transferred ownership to * Fountain Street, LLC.
- Mr. Grieco and Mr. Tiernan engaged in fraudulent activities, including embezzlement, commingling of funds, and tax evasion, as evidenced by forensic CPA Lori Horton’s report.
Would you like further assistance with any other sections?
---
*. Misrepresentation and Mismanagement
- Movant was advised by Mr. Grieco to move from Chapter * to Chapter * under the promise that his sole ownership of a $*.* million commercial building would be restored after the sale.
- After the transfer, Mr. Grieco and Mr. Tiernan failed to return Movant’s name to the title of the building and instead transferred ownership to * Fountain Street, LLC.
- Mr. Grieco and Mr. Tiernan engaged in fraudulent activities, including embezzlement, commingling of funds, and tax evasion, as evidenced by forensic CPA Lori Horton’s report.
Would you like further assistance with any other sections?
see above
Certainly! Here’s the revised and polished version of James' motion:
---
United States Bankruptcy Court
District of Rhode Island
In re:
James Cronan, Debtor
Case No.: [Insert Case Number]
James Cronan, Movant
v.
* Fountain Street, Assignee Mr. Tiernan, Respondent
MOTION TO CONTEST WRIT OF EXECUTION
NOW COMES Movant, James Cronan, and hereby files this Motion to Contest the Writ of Execution issued by the Court in favor of Respondent, * Fountain Street, Assignee Mr. Tiernan. In support of this Motion, Movant states as follows:
*. Fraudulent Conveyance
- The default judgment was purchased by * Fountain Street LLC and Mr. Tiernan as its assignee for $*,*, significantly below its value of $*,*, to offset damages in a lawsuit that Movant has against Mr. Tiernan for illegal foreclosure, usury violations, breach of contract, and violations under Massachusetts General Laws Chapter 93A.
- The purchase of the judgment was not made in good faith asrequired under * U.S.C. *(m) as a prerequisite for the court to order the writ of execution.
*. Misrepresentation and Mismanagement
- After the transfer, Mr. Grieco and Mr. Tiernan failed to return Movant’s name to the title of the building and instead transferred ownership to * Fountain Street, LLC.
- Mr. Grieco and Mr. Tiernan engaged in fraudulent activities, including embezzlement, commingling of funds, and tax evasion, as evidenced by forensic CPA Lori Horton’s report.
*. Indigency and Financial Hardship
- Movant was indigent and unable to pay the $*,* demanded by the Trustee's agent to finalize the adversary proceeding.
- Movant’s financial records were destroyed by Mr. Grieco and Mr. Tiernan, causing further financial hardship.
*. Threats and Coercion
- Movant was threatened by Mr. Grieco and Mr. Tiernan to stop asking to put his name back on the commercial building, under threat of foreclosure on Karen’s property.
- Movant was coerced into moving from Chapter * to Chapter * based on false promises that the building ownership would
---
United States Bankruptcy Court
District of Rhode Island
In re:
James Cronan, Debtor
Case No.: [Insert Case Number]
James Cronan, Movant
v.
* Fountain Street, Assignee Mr. Tiernan, Respondent
MOTION TO CONTEST WRIT OF EXECUTION
NOW COMES Movant, James Cronan, and hereby files this Motion to Contest the Writ of Execution issued by the Court in favor of Respondent, * Fountain Street, Assignee Mr. Tiernan. In support of this Motion, Movant states as follows:
*. Fraudulent Conveyance
- The default judgment was purchased by * Fountain Street LLC and Mr. Tiernan as its assignee for $*,*, significantly below its value of $*,*, to offset damages in a lawsuit that Movant has against Mr. Tiernan for illegal foreclosure, usury violations, breach of contract, and violations under Massachusetts General Laws Chapter 93A.
- The purchase of the judgment was not made in good faith asrequired under * U.S.C. *(m) as a prerequisite for the court to order the writ of execution.
*. Misrepresentation and Mismanagement
- After the transfer, Mr. Grieco and Mr. Tiernan failed to return Movant’s name to the title of the building and instead transferred ownership to * Fountain Street, LLC.
- Mr. Grieco and Mr. Tiernan engaged in fraudulent activities, including embezzlement, commingling of funds, and tax evasion, as evidenced by forensic CPA Lori Horton’s report.
*. Indigency and Financial Hardship
- Movant was indigent and unable to pay the $*,* demanded by the Trustee's agent to finalize the adversary proceeding.
- Movant’s financial records were destroyed by Mr. Grieco and Mr. Tiernan, causing further financial hardship.
*. Threats and Coercion
- Movant was threatened by Mr. Grieco and Mr. Tiernan to stop asking to put his name back on the commercial building, under threat of foreclosure on Karen’s property.
- Movant was coerced into moving from Chapter * to Chapter * based on false promises that the building ownership would
please confirm that this is ok to say in both section * and if not revise and resend the motion - Movant was coerced into moving from Chapter * to Chapter * based on false promises that the building ownership would be restored and in *. Misrepresentation and Mismanagement
- Movant was advised by Mr. Grieco to move from Chapter * to Chapter * under the promise that his sole ownership of a $*.* million commercial building would be restored after the sale.
Here's the revised version:
---
United States Bankruptcy Court
District of Rhode Island
In re:
James Cronan, Debtor
Case No.: [Insert Case Number]
James Cronan, Movant
v.
* Fountain Street, Assignee Mr. Tiernan, Respondent
MOTION TO CONTEST WRIT OF EXECUTION
NOW COMES Movant, James Cronan, and hereby files this Motion to Contest the Writ of Execution issued by the Court in favor of Respondent, * Fountain Street, Assignee Mr. Tiernan. In support of this Motion, Movant states as follows:
*. Fraudulent Conveyance
- The default judgment was purchased by * Fountain Street LLC and Mr. Tiernan as its assignee for $*,*, significantly below its value of $*,*, to offset damages in a lawsuit that Movant has against Mr. Tiernan for illegal foreclosure, usury violations, breach of contract, and violations under Massachusetts General Laws Chapter 93A.
- The purchase of the judgment was not made in good faith as required under * U.S.C. *(m) as a prerequisite for the court to order the writ ofexecution.
*. Misrepresentation and Mismanagement
- Movant was advised by Mr. Grieco to move from Chapter * to Chapter * under the promise that his sole ownership of a $*.* million commercial building would be restored after the sale.
- After the transfer, Mr. Grieco and Mr. Tiernan failed to return Movant’s name to the title of the building and instead transferred ownership to * Fountain Street, LLC.
- Mr. Grieco and Mr. Tiernan engaged in fraudulent activities, including embezzlement, commingling of funds, and tax evasion, as evidenced by forensic CPA Lori Horton’s report.
*. Indigency and Financial Hardship
- Movant was indigent and unable to pay the $*,* demanded by the Trustee's agent to finalize the adversary proceeding.
- Movant’s financial records were destroyed by Mr. Grieco and Mr. Tiernan, causing further financial hardship.
*. Threats and Coercion
- Movant was threatened by Mr. Grieco and Mr. Tiernan to stop asking to put his name back on the commercial building, under threat of foreclosure on Karen’s property.
- Movant was
---
United States Bankruptcy Court
District of Rhode Island
In re:
James Cronan, Debtor
Case No.: [Insert Case Number]
James Cronan, Movant
v.
* Fountain Street, Assignee Mr. Tiernan, Respondent
MOTION TO CONTEST WRIT OF EXECUTION
NOW COMES Movant, James Cronan, and hereby files this Motion to Contest the Writ of Execution issued by the Court in favor of Respondent, * Fountain Street, Assignee Mr. Tiernan. In support of this Motion, Movant states as follows:
*. Fraudulent Conveyance
- The default judgment was purchased by * Fountain Street LLC and Mr. Tiernan as its assignee for $*,*, significantly below its value of $*,*, to offset damages in a lawsuit that Movant has against Mr. Tiernan for illegal foreclosure, usury violations, breach of contract, and violations under Massachusetts General Laws Chapter 93A.
- The purchase of the judgment was not made in good faith as required under * U.S.C. *(m) as a prerequisite for the court to order the writ ofexecution.
*. Misrepresentation and Mismanagement
- Movant was advised by Mr. Grieco to move from Chapter * to Chapter * under the promise that his sole ownership of a $*.* million commercial building would be restored after the sale.
- After the transfer, Mr. Grieco and Mr. Tiernan failed to return Movant’s name to the title of the building and instead transferred ownership to * Fountain Street, LLC.
- Mr. Grieco and Mr. Tiernan engaged in fraudulent activities, including embezzlement, commingling of funds, and tax evasion, as evidenced by forensic CPA Lori Horton’s report.
*. Indigency and Financial Hardship
- Movant was indigent and unable to pay the $*,* demanded by the Trustee's agent to finalize the adversary proceeding.
- Movant’s financial records were destroyed by Mr. Grieco and Mr. Tiernan, causing further financial hardship.
*. Threats and Coercion
- Movant was threatened by Mr. Grieco and Mr. Tiernan to stop asking to put his name back on the commercial building, under threat of foreclosure on Karen’s property.
- Movant was
Now only send from section * onward keeping without the borderline
Sure, here's the rest of the motion from Section * onward:
*. Threats and Coercion
- Movant was threatened by Mr. Grieco and Mr. Tiernan to stop asking to put his name back on the commercial building, under threat of foreclosure on Karen’s property.
- Movant was coerced into moving from Chapter * to Chapter * based on false promises that the building ownership would be restored.
- James’ affidavit detailing the threats made by Mr. Tiernan and Mr. Grieco is included.
*. Evidence
- Bill of Sale: Document showing the transfer of ownership of James' original business, Classic Display, to Mr. Grieco.
- Court Tape: Recording of the court proceedings where Mr. Grieco establishes himself as James' accountant and partner.
- Tax Returns: Two years of tax returns filed by Mr. Grieco showing James as an officer of the new company, The Classic Group Inc.
- Share Transfer: Evidence of the transfer of * shares from James to Mr. Tiernan under the promise of a tax break.
- Forensic CPA Report: Report by Lori Horton showing commingling of funds, tax evasion,and embezzlement.
- Foreclosure Deed: Document showing the foreclosure on Karen’s property as a result of Mr. Tiernan's threats.
- Federal Complaint: Complaint filed in federal court against Mr. Tiernan for illegal foreclosure.
- Order Granting Motion for Approval of Sale: Document showing the court's reliance on false representations about the sale's fairness and the buyer's good faith under * U.S.C. *(m).
- Motion Filed by * Fountain Street: Document showing false statements under Rule *(b)*, indicating fraud on the court.
- * Fountain Street LLC's Motion for Issuance of Writ of Execution: Document showing false statements under Rule *(b)(*), indicating fraud on the court. The motion falsely claimed that * Fountain Street LLC was a "Creditor" and requested issuance of a Writ of Execution when in fact they were a debtor involved in a fraudulent conveyance to defraud a creditor, Karen Merritt, one of the movants in this case.
*. Request for Relief
- Movant requests the Court to contest and set aside the Writ of Execution based on the fraudulent activities and misrepresentation by Mr. Grieco, Mr. Tier
*. Threats and Coercion
- Movant was threatened by Mr. Grieco and Mr. Tiernan to stop asking to put his name back on the commercial building, under threat of foreclosure on Karen’s property.
- Movant was coerced into moving from Chapter * to Chapter * based on false promises that the building ownership would be restored.
- James’ affidavit detailing the threats made by Mr. Tiernan and Mr. Grieco is included.
*. Evidence
- Bill of Sale: Document showing the transfer of ownership of James' original business, Classic Display, to Mr. Grieco.
- Court Tape: Recording of the court proceedings where Mr. Grieco establishes himself as James' accountant and partner.
- Tax Returns: Two years of tax returns filed by Mr. Grieco showing James as an officer of the new company, The Classic Group Inc.
- Share Transfer: Evidence of the transfer of * shares from James to Mr. Tiernan under the promise of a tax break.
- Forensic CPA Report: Report by Lori Horton showing commingling of funds, tax evasion,and embezzlement.
- Foreclosure Deed: Document showing the foreclosure on Karen’s property as a result of Mr. Tiernan's threats.
- Federal Complaint: Complaint filed in federal court against Mr. Tiernan for illegal foreclosure.
- Order Granting Motion for Approval of Sale: Document showing the court's reliance on false representations about the sale's fairness and the buyer's good faith under * U.S.C. *(m).
- Motion Filed by * Fountain Street: Document showing false statements under Rule *(b)*, indicating fraud on the court.
- * Fountain Street LLC's Motion for Issuance of Writ of Execution: Document showing false statements under Rule *(b)(*), indicating fraud on the court. The motion falsely claimed that * Fountain Street LLC was a "Creditor" and requested issuance of a Writ of Execution when in fact they were a debtor involved in a fraudulent conveyance to defraud a creditor, Karen Merritt, one of the movants in this case.
*. Request for Relief
- Movant requests the Court to contest and set aside the Writ of Execution based on the fraudulent activities and misrepresentation by Mr. Grieco, Mr. Tier
*. Misrepresentation and Mismanagement
- Movant was advised by Mr. Grieco to move from Chapter * to Chapter * under the promise that his sole ownership of a $*.* million commercial building, * Fountain Street, Rhode Island (now owned by Respondent and assignee) would be restored after the sale.
- After the transfer, Mr. Grieco and Mr. Tiernan failed to return Movant’s name to the title of the building and instead transferred ownership to * Fountain Street, LLC.
Sure, Karen! Here’s the revised version of James' motion with the adjusted section:
---
United States Bankruptcy Court
District of Rhode Island
In re:
James Cronan, Debtor
Case No.: [Insert Case Number]
James Cronan, Movant
v.
* Fountain Street, Assignee Mr. Tiernan, Respondent
MOTION TO CONTEST WRIT OF EXECUTION
NOW COMES Movant, James Cronan, and hereby files this Motion to Contest the Writ of Execution issued by the Court in favor of Respondent, * Fountain Street, Assignee Mr. Tiernan. In support of this Motion, Movant states as follows:
*. Fraudulent Conveyance
- The default judgment was purchased by * Fountain Street LLC and Mr. Tiernan as its assignee for $*,*, significantly below its value of $*,*, to offset damages in a lawsuit that Movant has against Mr. Tiernan for illegal foreclosure, usury violations, breach of contract, and violations under Massachusetts General Laws Chapter 93A.
- The purchase of the judgment was not made in good faith as required under * U.S.C. *(m) as a prerequisite for the court to order the writ of execution.
*. Misrepresentation and Mismanagement
- Movant was advised by Mr. Grieco to move from Chapter * to Chapter * under the promise that his sole ownership of a $*.* million commercial building would be restored after the sale.
- After the transfer, Mr. Grieco and Mr. Tiernan failed to return Movant’s name to the title of the building and instead transferred ownership to * Fountain Street, LLC.
- Mr. Grieco and Mr. Tiernan engaged in fraudulent activities, including embezzlement, commingling of funds, and tax evasion, as evidenced by forensic CPA Lori Horton’s report.
*. Indigency and Financial Hardship
- Movant was indigent and unable to pay the $*,* demanded by the Trustee's agent to finalize the adversary proceeding.
- Movant’s financial records were destroyed by Mr. Grieco and Mr. Tiernan, causing further financial hardship.
*. Threats and Coercion
- Movant was threatened by Mr. Grieco and Mr. Tiernan to stop asking to put his name back on the commercial building, under
---
United States Bankruptcy Court
District of Rhode Island
In re:
James Cronan, Debtor
Case No.: [Insert Case Number]
James Cronan, Movant
v.
* Fountain Street, Assignee Mr. Tiernan, Respondent
MOTION TO CONTEST WRIT OF EXECUTION
NOW COMES Movant, James Cronan, and hereby files this Motion to Contest the Writ of Execution issued by the Court in favor of Respondent, * Fountain Street, Assignee Mr. Tiernan. In support of this Motion, Movant states as follows:
*. Fraudulent Conveyance
- The default judgment was purchased by * Fountain Street LLC and Mr. Tiernan as its assignee for $*,*, significantly below its value of $*,*, to offset damages in a lawsuit that Movant has against Mr. Tiernan for illegal foreclosure, usury violations, breach of contract, and violations under Massachusetts General Laws Chapter 93A.
- The purchase of the judgment was not made in good faith as required under * U.S.C. *(m) as a prerequisite for the court to order the writ of execution.
*. Misrepresentation and Mismanagement
- Movant was advised by Mr. Grieco to move from Chapter * to Chapter * under the promise that his sole ownership of a $*.* million commercial building would be restored after the sale.
- After the transfer, Mr. Grieco and Mr. Tiernan failed to return Movant’s name to the title of the building and instead transferred ownership to * Fountain Street, LLC.
- Mr. Grieco and Mr. Tiernan engaged in fraudulent activities, including embezzlement, commingling of funds, and tax evasion, as evidenced by forensic CPA Lori Horton’s report.
*. Indigency and Financial Hardship
- Movant was indigent and unable to pay the $*,* demanded by the Trustee's agent to finalize the adversary proceeding.
- Movant’s financial records were destroyed by Mr. Grieco and Mr. Tiernan, causing further financial hardship.
*. Threats and Coercion
- Movant was threatened by Mr. Grieco and Mr. Tiernan to stop asking to put his name back on the commercial building, under
the building address is * founatin Street, Rhode island
Sure, here is the revised version of James' motion from Section * onward:
---
*. Misrepresentation and Mismanagement
- Movant was advised by Mr. Grieco to move from Chapter * to Chapter * under the promise that his sole ownership of a $*.* million commercial building, * Fountain Street, Rhode Island (now owned by Respondent and assignee), would be restored after the sale.
- After the transfer, Mr. Grieco and Mr. Tiernan failed to return Movant’s name to the title of the building and instead transferred ownership to * Fountain Street, LLC.
- Mr. Grieco and Mr. Tiernan engaged in fraudulent activities, including embezzlement, commingling of funds, and tax evasion, as evidenced by forensic CPA Lori Horton’s report.
*. Indigency and Financial Hardship
- Movant was indigent and unable to pay the $*,* demanded by the Trustee's agent to finalize the adversary proceeding.
- Movant’s financial records were destroyed by Mr. Grieco and Mr. Tiernan, causing further financial hardship.
*. Threats and Coercion
- Movant was threatened by Mr. Grieco and Mr. Tiernan to stop asking to put his name back on the commercial building, under threat of foreclosure on Karen’s property.
- Movant was coerced into moving from Chapter * to Chapter * based on false promises that the building ownership would be restored.
- James’ affidavit detailing the threats made by Mr. Tiernan and Mr. Grieco is included.
*. Evidence
- Bill of Sale: Document showing the transfer of ownership of James' original business, Classic Display, to Mr. Grieco.
- Court Tape: Recording of the court proceedings where Mr. Grieco establishes himself as James' accountant and partner.
- Tax Returns: Two years of tax returns filed by Mr. Grieco showing James as an officer of the new company, The Classic Group Inc.
- Share Transfer: Evidence of the transfer of * shares from James to Mr. Tiernan under the promise of a tax break.
- Forensic CPA Report: Report by Lori Horton showing commingling of funds, tax evasion, and embezzlement.
- Foreclosure Deed: Document showing the foreclosure on Karen’s property as a result of Mr. Tiernan's threats.
---
*. Misrepresentation and Mismanagement
- Movant was advised by Mr. Grieco to move from Chapter * to Chapter * under the promise that his sole ownership of a $*.* million commercial building, * Fountain Street, Rhode Island (now owned by Respondent and assignee), would be restored after the sale.
- After the transfer, Mr. Grieco and Mr. Tiernan failed to return Movant’s name to the title of the building and instead transferred ownership to * Fountain Street, LLC.
- Mr. Grieco and Mr. Tiernan engaged in fraudulent activities, including embezzlement, commingling of funds, and tax evasion, as evidenced by forensic CPA Lori Horton’s report.
*. Indigency and Financial Hardship
- Movant was indigent and unable to pay the $*,* demanded by the Trustee's agent to finalize the adversary proceeding.
- Movant’s financial records were destroyed by Mr. Grieco and Mr. Tiernan, causing further financial hardship.
*. Threats and Coercion
- Movant was threatened by Mr. Grieco and Mr. Tiernan to stop asking to put his name back on the commercial building, under threat of foreclosure on Karen’s property.
- Movant was coerced into moving from Chapter * to Chapter * based on false promises that the building ownership would be restored.
- James’ affidavit detailing the threats made by Mr. Tiernan and Mr. Grieco is included.
*. Evidence
- Bill of Sale: Document showing the transfer of ownership of James' original business, Classic Display, to Mr. Grieco.
- Court Tape: Recording of the court proceedings where Mr. Grieco establishes himself as James' accountant and partner.
- Tax Returns: Two years of tax returns filed by Mr. Grieco showing James as an officer of the new company, The Classic Group Inc.
- Share Transfer: Evidence of the transfer of * shares from James to Mr. Tiernan under the promise of a tax break.
- Forensic CPA Report: Report by Lori Horton showing commingling of funds, tax evasion, and embezzlement.
- Foreclosure Deed: Document showing the foreclosure on Karen’s property as a result of Mr. Tiernan's threats.
*. Misrepresentation and Mismanagement
- Movant was advised by Mr. Grieco to move from Chapter * to Chapter * under the promise that his sole ownership of a $*.* million commercial building would be restored after the sale. Mr. grieco was his long term CPA who went into a partnership buisness with James cronan engaging in a conflict of interest in violation of General Principles of Acctounting Practice GAAP.
Karen, based on the information provided, here is the revised version of Section * for James' motion:
---
*. Misrepresentation and Mismanagement
- Movant was advised by Mr. Grieco to move from Chapter * to Chapter * under the promise that his sole ownership of a $*.* million commercial building would be restored after the sale. Mr. Grieco, his long-term CPA, went into a partnership business with James Cronan, engaging in a conflict of interest in violation of General Principles of Accounting Practice (GAAP).
- After the transfer, Mr. Grieco and Mr. Tiernan failed to return Movant’s name to the title of the building and instead transferred ownership to * Fountain Street, LLC.
- Mr. Grieco and Mr. Tiernan engaged in fraudulent activities, including embezzlement, commingling of funds, and tax evasion, as evidenced by forensic CPA Lori Horton’s report.
---
Would you like any further assistance with other sections or details?
---
*. Misrepresentation and Mismanagement
- Movant was advised by Mr. Grieco to move from Chapter * to Chapter * under the promise that his sole ownership of a $*.* million commercial building would be restored after the sale. Mr. Grieco, his long-term CPA, went into a partnership business with James Cronan, engaging in a conflict of interest in violation of General Principles of Accounting Practice (GAAP).
- After the transfer, Mr. Grieco and Mr. Tiernan failed to return Movant’s name to the title of the building and instead transferred ownership to * Fountain Street, LLC.
- Mr. Grieco and Mr. Tiernan engaged in fraudulent activities, including embezzlement, commingling of funds, and tax evasion, as evidenced by forensic CPA Lori Horton’s report.
---
Would you like any further assistance with other sections or details?
see below
Sure, Karen! Here's the revised version of James' motion, including the additional details about Mr. Grieco:
---
United States Bankruptcy Court
District of Rhode Island
In re:
James Cronan, Debtor
Case No.: [Insert Case Number]
James Cronan, Movant
v.
* Fountain Street, Assignee Mr. Tiernan, Respondent
MOTION TO CONTEST WRIT OF EXECUTION
NOW COMES Movant, James Cronan, and hereby files this Motion to Contest the Writ of Execution issued by the Court in favor of Respondent, * Fountain Street, Assignee Mr. Tiernan. In support of this Motion, Movant states as follows:
*. Fraudulent Conveyance
- The default judgment was purchased by * Fountain Street LLC and Mr. Tiernan as its assignee for $*,*, significantly below its value of $*,*, to offset damages in a lawsuit that Movant has against Mr. Tiernan for illegal foreclosure, usury violations, breach of contract, and violations under Massachusetts General Laws Chapter 93A.
- The purchase of the judgment was not made in good faith as required under * U.S.C. *(m) as a prerequisite for the court to order the writ of execution.
*. Misrepresentation and Mismanagement
- Movant was advised by Mr. Grieco to move from Chapter * to Chapter * under the promise that his sole ownership of a $*.* million commercial building, * Fountain Street, Rhode Island (now owned by Respondent and assignee), would be restored after the sale. Mr. Grieco was his long-term CPA who went into a partnership business with James Cronan, engaging in a conflict of interest in violation of General Principles of Accounting Practice (GAAP).
- After the transfer, Mr. Grieco and Mr. Tiernan failed to return Movant’s name to the title of the building and instead transferred ownership to * Fountain Street, LLC.
- Mr. Grieco and Mr. Tiernan engaged in fraudulent activities, including embezzlement, commingling of funds, and tax evasion, as evidenced by forensic CPA Lori Horton’s report.
*. Indigency and Financial Hardship
- Movant was indigent and unable to pay the $*,* demanded by the Trustee's agent to finalize the adversary proceeding.
- Movant
---
United States Bankruptcy Court
District of Rhode Island
In re:
James Cronan, Debtor
Case No.: [Insert Case Number]
James Cronan, Movant
v.
* Fountain Street, Assignee Mr. Tiernan, Respondent
MOTION TO CONTEST WRIT OF EXECUTION
NOW COMES Movant, James Cronan, and hereby files this Motion to Contest the Writ of Execution issued by the Court in favor of Respondent, * Fountain Street, Assignee Mr. Tiernan. In support of this Motion, Movant states as follows:
*. Fraudulent Conveyance
- The default judgment was purchased by * Fountain Street LLC and Mr. Tiernan as its assignee for $*,*, significantly below its value of $*,*, to offset damages in a lawsuit that Movant has against Mr. Tiernan for illegal foreclosure, usury violations, breach of contract, and violations under Massachusetts General Laws Chapter 93A.
- The purchase of the judgment was not made in good faith as required under * U.S.C. *(m) as a prerequisite for the court to order the writ of execution.
*. Misrepresentation and Mismanagement
- Movant was advised by Mr. Grieco to move from Chapter * to Chapter * under the promise that his sole ownership of a $*.* million commercial building, * Fountain Street, Rhode Island (now owned by Respondent and assignee), would be restored after the sale. Mr. Grieco was his long-term CPA who went into a partnership business with James Cronan, engaging in a conflict of interest in violation of General Principles of Accounting Practice (GAAP).
- After the transfer, Mr. Grieco and Mr. Tiernan failed to return Movant’s name to the title of the building and instead transferred ownership to * Fountain Street, LLC.
- Mr. Grieco and Mr. Tiernan engaged in fraudulent activities, including embezzlement, commingling of funds, and tax evasion, as evidenced by forensic CPA Lori Horton’s report.
*. Indigency and Financial Hardship
- Movant was indigent and unable to pay the $*,* demanded by the Trustee's agent to finalize the adversary proceeding.
- Movant
see above
Sure, Karen. Here is the revised version of James' motion, including the details about Mr. Grieco's conflict of interest:
---
United States Bankruptcy Court
District of Rhode Island
In re:
James Cronan, Debtor
Case No.: [Insert Case Number]
James Cronan, Movant
v.
* Fountain Street, Assignee Mr. Tiernan, Respondent
MOTION TO CONTEST WRIT OF EXECUTION
NOW COMES Movant, James Cronan, and hereby files this Motion to Contest the Writ of Execution issued by the Court in favor of Respondent, * Fountain Street, Assignee Mr. Tiernan. In support of this Motion, Movant states as follows:
*. Fraudulent Conveyance
- The default judgment was purchased by * Fountain Street LLC and Mr. Tiernan as its assignee for $*,*, significantly below its value of $*,*, to offset damages in a lawsuit that Movant has against Mr. Tiernan for illegal foreclosure, usury violations, breach of contract, and violations under Massachusetts General Laws Chapter 93A.
- The purchase of the judgment was not made in good faith as requiredunder * U.S.C. *(m) as a prerequisite for the court to order the writ of execution.
*. Misrepresentation and Mismanagement
- Movant was advised by Mr. Grieco to move from Chapter * to Chapter * under the promise that his sole ownership of a $*.* million commercial building, * Fountain Street, Rhode Island (now owned by Respondent and assignee), would be restored after the sale.
- Mr. Grieco, who was Movant’s long-term CPA, went into a partnership business with James Cronan, engaging in a conflict of interest in violation of General Principles of Accounting Practice (GAAP).
- After the transfer, Mr. Grieco and Mr. Tiernan failed to return Movant’s name to the title of the building and instead transferred ownership to * Fountain Street, LLC.
- Mr. Grieco and Mr. Tiernan engaged in fraudulent activities, including embezzlement, commingling of funds, and tax evasion, as evidenced by forensic CPA Lori Horton’s report.
*. Indigency and Financial Hardship
- Movant was indigent and unable to pay the $*,* demanded by the Trustee's agent to
---
United States Bankruptcy Court
District of Rhode Island
In re:
James Cronan, Debtor
Case No.: [Insert Case Number]
James Cronan, Movant
v.
* Fountain Street, Assignee Mr. Tiernan, Respondent
MOTION TO CONTEST WRIT OF EXECUTION
NOW COMES Movant, James Cronan, and hereby files this Motion to Contest the Writ of Execution issued by the Court in favor of Respondent, * Fountain Street, Assignee Mr. Tiernan. In support of this Motion, Movant states as follows:
*. Fraudulent Conveyance
- The default judgment was purchased by * Fountain Street LLC and Mr. Tiernan as its assignee for $*,*, significantly below its value of $*,*, to offset damages in a lawsuit that Movant has against Mr. Tiernan for illegal foreclosure, usury violations, breach of contract, and violations under Massachusetts General Laws Chapter 93A.
- The purchase of the judgment was not made in good faith as requiredunder * U.S.C. *(m) as a prerequisite for the court to order the writ of execution.
*. Misrepresentation and Mismanagement
- Movant was advised by Mr. Grieco to move from Chapter * to Chapter * under the promise that his sole ownership of a $*.* million commercial building, * Fountain Street, Rhode Island (now owned by Respondent and assignee), would be restored after the sale.
- Mr. Grieco, who was Movant’s long-term CPA, went into a partnership business with James Cronan, engaging in a conflict of interest in violation of General Principles of Accounting Practice (GAAP).
- After the transfer, Mr. Grieco and Mr. Tiernan failed to return Movant’s name to the title of the building and instead transferred ownership to * Fountain Street, LLC.
- Mr. Grieco and Mr. Tiernan engaged in fraudulent activities, including embezzlement, commingling of funds, and tax evasion, as evidenced by forensic CPA Lori Horton’s report.
*. Indigency and Financial Hardship
- Movant was indigent and unable to pay the $*,* demanded by the Trustee's agent to
please send me section *
Sure, here is Section * onward:
*. Request for Relief
- Movant requests the Court to contest and set aside the Writ of Execution based on the fraudulent activities and misrepresentation by Mr. Grieco, Mr. Tiernan, and * Fountain Street LLC.
- Movant seeks an order to reopen the adversary proceeding and to challenge the default judgment on the grounds of fraud and mismanagement.
- Movant requests a hearing to present evidence and arguments supporting the motion.
Would you like more detailed guidance on any specific part of Karen’s motion?
*. Request for Relief
- Movant requests the Court to contest and set aside the Writ of Execution based on the fraudulent activities and misrepresentation by Mr. Grieco, Mr. Tiernan, and * Fountain Street LLC.
- Movant seeks an order to reopen the adversary proceeding and to challenge the default judgment on the grounds of fraud and mismanagement.
- Movant requests a hearing to present evidence and arguments supporting the motion.
Would you like more detailed guidance on any specific part of Karen’s motion?
if On September *, * , this court granted the Trustee's Motion and reopened the case [Doc. *]then do we have to officially ask to reopen the adversarial proceeding with the case?
Yes, if the main bankruptcy case was reopened, you will still need to file a motion to officially reopen the adversary proceeding. This is because the adversary proceeding, which is a separate lawsuit within the bankruptcy case, needs its own specific request for reopening.
Would you like guidance on how to structure the motion to reopen the adversary proceeding?
Would you like guidance on how to structure the motion to reopen the adversary proceeding?
see above
Karen, since the court has already granted the Trustee's Motion to reopen the case, you do not need to ask to reopen the adversary proceeding again. Instead, you should focus on contesting the writ of execution and presenting your arguments based on the already reopened case.
Here’s the revised Section *:
*. Request for Relief
- Movant requests the Court to set aside the Writ of Execution based on the fraudulent activities and misrepresentation by Mr. Grieco, Mr. Tiernan, and * Fountain Street LLC.
- Movant seeks to challenge the default judgment on the grounds of fraud and mismanagement.
- Movant requests a hearing to present evidence and arguments supporting the motion.
Would you like more detailed guidance on any other specific part of the motion?
Here’s the revised Section *:
*. Request for Relief
- Movant requests the Court to set aside the Writ of Execution based on the fraudulent activities and misrepresentation by Mr. Grieco, Mr. Tiernan, and * Fountain Street LLC.
- Movant seeks to challenge the default judgment on the grounds of fraud and mismanagement.
- Movant requests a hearing to present evidence and arguments supporting the motion.
Would you like more detailed guidance on any other specific part of the motion?
Please updat the motion including evidence of this complaint and relief requested and resend the revised motion. Can I ask for an emergency stay as Movants recieved the summons being sued by * fountain Street LLC by a complaint filed on January *, * in the Bristol superior court docket number * CV * seeking a Complaint To Register Judgment based on fraud. If it proceeds the Movants will be irrepably harmed as the the scheme including mortgae fraud , bankruptcy fraud consprarcy , mail fraud, criminal and civil conspirarcy and other federal and state crimes has been a long running scheme which Movants have endured since *.
Karen, you can certainly request an emergency stay to prevent irreparable harm. Here’s a revised version of James' motion, including the request for an emergency stay:
---
United States Bankruptcy Court
District of Rhode Island
In re:
James Cronan, Debtor
Case No.: [Insert Case Number]
James Cronan, Movant
v.
* Fountain Street, Assignee Mr. Tiernan, Respondent
MOTION TO CONTEST WRIT OF EXECUTION AND REQUEST FOR EMERGENCY STAY
NOW COMES Movant, James Cronan, and hereby files this Motion to Contest the Writ of Execution issued by the Court in favor of Respondent, * Fountain Street, Assignee Mr. Tiernan. Movant also requests an emergency stay. In support of this Motion, Movant states as follows:
*. Fraudulent Conveyance
- The default judgment was purchased by * Fountain Street LLC and Mr. Tiernan as its assignee for $*,*, significantly below its value of $*,*, to offset damages in a lawsuit that Movant has against Mr. Tiernan for illegalforeclosure, usury violations, breach of contract, and violations under Massachusetts General Laws Chapter 93A.
- The purchase of the judgment was not made in good faith as required under * U.S.C. *(m) as a prerequisite for the court to order the writ of execution.
*. Misrepresentation and Mismanagement
- Movant was advised by Mr. Grieco to move from Chapter * to Chapter * under the promise that his sole ownership of a $*.* million commercial building, * Fountain Street, Rhode Island (now owned by Respondent and assignee), would be restored after the sale.
- Mr. Grieco, who was Movant’s long-term CPA, went into a partnership business with James Cronan, engaging in a conflict of interest in violation of General Principles of Accounting Practice (GAAP).
- After the transfer, Mr. Grieco and Mr. Tiernan failed to return Movant’s name to the title of the building and instead transferred ownership to * Fountain Street, LLC.
- Mr. Grieco and Mr. Tiernan engaged in fraudulent activities, including embezzlement, commingling of funds, and tax evasion, as evidenced by forensic CPA Lori Horton
---
United States Bankruptcy Court
District of Rhode Island
In re:
James Cronan, Debtor
Case No.: [Insert Case Number]
James Cronan, Movant
v.
* Fountain Street, Assignee Mr. Tiernan, Respondent
MOTION TO CONTEST WRIT OF EXECUTION AND REQUEST FOR EMERGENCY STAY
NOW COMES Movant, James Cronan, and hereby files this Motion to Contest the Writ of Execution issued by the Court in favor of Respondent, * Fountain Street, Assignee Mr. Tiernan. Movant also requests an emergency stay. In support of this Motion, Movant states as follows:
*. Fraudulent Conveyance
- The default judgment was purchased by * Fountain Street LLC and Mr. Tiernan as its assignee for $*,*, significantly below its value of $*,*, to offset damages in a lawsuit that Movant has against Mr. Tiernan for illegalforeclosure, usury violations, breach of contract, and violations under Massachusetts General Laws Chapter 93A.
- The purchase of the judgment was not made in good faith as required under * U.S.C. *(m) as a prerequisite for the court to order the writ of execution.
*. Misrepresentation and Mismanagement
- Movant was advised by Mr. Grieco to move from Chapter * to Chapter * under the promise that his sole ownership of a $*.* million commercial building, * Fountain Street, Rhode Island (now owned by Respondent and assignee), would be restored after the sale.
- Mr. Grieco, who was Movant’s long-term CPA, went into a partnership business with James Cronan, engaging in a conflict of interest in violation of General Principles of Accounting Practice (GAAP).
- After the transfer, Mr. Grieco and Mr. Tiernan failed to return Movant’s name to the title of the building and instead transferred ownership to * Fountain Street, LLC.
- Mr. Grieco and Mr. Tiernan engaged in fraudulent activities, including embezzlement, commingling of funds, and tax evasion, as evidenced by forensic CPA Lori Horton
it was purchased by Mr. grieco and Mr tiernan for $*,* defrauding the creditors while leaving Mr. Cronan with the Small Business A loan(SBA) which he was left to pay and still continues to pay being stripped of his orignal business and the commercial property which he owned before theei scheme to defraud arose while they got a *.* m windfall.
Sure, Karen. Here’s the revised version of James' motion, including the request for an emergency stay and additional details:
---
United States Bankruptcy Court
District of Rhode Island
In re:
James Cronan, Debtor
Case No.: [Insert Case Number]
James Cronan, Movant
v.
* Fountain Street, Assignee Mr. Tiernan, Respondent
MOTION TO CONTEST WRIT OF EXECUTION AND REQUEST FOR EMERGENCY STAY
NOW COMES Movant, James Cronan, and hereby files this Motion to Contest the Writ of Execution issued by the Court in favor of Respondent, * Fountain Street, Assignee Mr. Tiernan. Movant also requests an emergency stay. In support of this Motion, Movant states as follows:
*. Fraudulent Conveyance
- The default judgment was purchased by * Fountain Street LLC and Mr. Tiernan as its assignee for $*,*, significantly below its value of $*,*, to offset damages in a lawsuit that Movant has against Mr. Tiernan for illegal foreclosure, usury violations, breach of contract, and violations under MassachusettsGeneral Laws Chapter 93A.
- The purchase of the judgment was not made in good faith as required under * U.S.C. *(m) as a prerequisite for the court to order the writ of execution.
*. Misrepresentation and Mismanagement
- Movant was advised by Mr. Grieco to move from Chapter * to Chapter * under the promise that his sole ownership of a $*.* million commercial building, * Fountain Street, Rhode Island (now owned by Respondent and assignee), would be restored after the sale.
- Mr. Grieco, who was Movant’s long-term CPA, went into a partnership business with James Cronan, engaging in a conflict of interest in violation of General Principles of Accounting Practice (GAAP).
- After the transfer, Mr. Grieco and Mr. Tiernan failed to return Movant’s name to the title of the building and instead transferred ownership to * Fountain Street, LLC.
- Mr. Grieco and Mr. Tiernan engaged in fraudulent activities, including embezzlement, commingling of funds, and tax evasion, as evidenced by forensic CPA Lori Horton’s report.
*. Indigency and Financial Hardship
---
United States Bankruptcy Court
District of Rhode Island
In re:
James Cronan, Debtor
Case No.: [Insert Case Number]
James Cronan, Movant
v.
* Fountain Street, Assignee Mr. Tiernan, Respondent
MOTION TO CONTEST WRIT OF EXECUTION AND REQUEST FOR EMERGENCY STAY
NOW COMES Movant, James Cronan, and hereby files this Motion to Contest the Writ of Execution issued by the Court in favor of Respondent, * Fountain Street, Assignee Mr. Tiernan. Movant also requests an emergency stay. In support of this Motion, Movant states as follows:
*. Fraudulent Conveyance
- The default judgment was purchased by * Fountain Street LLC and Mr. Tiernan as its assignee for $*,*, significantly below its value of $*,*, to offset damages in a lawsuit that Movant has against Mr. Tiernan for illegal foreclosure, usury violations, breach of contract, and violations under MassachusettsGeneral Laws Chapter 93A.
- The purchase of the judgment was not made in good faith as required under * U.S.C. *(m) as a prerequisite for the court to order the writ of execution.
*. Misrepresentation and Mismanagement
- Movant was advised by Mr. Grieco to move from Chapter * to Chapter * under the promise that his sole ownership of a $*.* million commercial building, * Fountain Street, Rhode Island (now owned by Respondent and assignee), would be restored after the sale.
- Mr. Grieco, who was Movant’s long-term CPA, went into a partnership business with James Cronan, engaging in a conflict of interest in violation of General Principles of Accounting Practice (GAAP).
- After the transfer, Mr. Grieco and Mr. Tiernan failed to return Movant’s name to the title of the building and instead transferred ownership to * Fountain Street, LLC.
- Mr. Grieco and Mr. Tiernan engaged in fraudulent activities, including embezzlement, commingling of funds, and tax evasion, as evidenced by forensic CPA Lori Horton’s report.
*. Indigency and Financial Hardship
see above
Sure, Karen. Here’s the revised version of James' motion, including the request for an emergency stay and the additional details about the fraudulent purchase:
---
United States Bankruptcy Court
District of Rhode Island
In re:
James Cronan, Debtor
Case No.: [Insert Case Number]
James Cronan, Movant
v.
* Fountain Street, Assignee Mr. Tiernan, Respondent
MOTION TO CONTEST WRIT OF EXECUTION AND REQUEST FOR EMERGENCY STAY
NOW COMES Movant, James Cronan, and hereby files this Motion to Contest the Writ of Execution issued by the Court in favor of Respondent, * Fountain Street, Assignee Mr. Tiernan. Movant also requests an emergency stay. In support of this Motion, Movant states as follows:
*. Fraudulent Conveyance
- The default judgment was purchased by Mr. Grieco and Mr. Tiernan for $*,*, defrauding creditors while leaving Movant with the Small Business Administration (SBA) loan, which he continues to pay. This left Movant stripped of his original business and commercial property, while Mr. Grieco and Mr. Tiernan receiveda $*.* million windfall.
- The purchase of the judgment was not made in good faith as required under * U.S.C. *(m) as a prerequisite for the court to order the writ of execution.
*. Misrepresentation and Mismanagement
- Movant was advised by Mr. Grieco to move from Chapter * to Chapter * under the promise that his sole ownership of a $*.* million commercial building, * Fountain Street, Rhode Island (now owned by Respondent and assignee), would be restored after the sale.
- Mr. Grieco, who was Movant’s long-term CPA, went into a partnership business with James Cronan, engaging in a conflict of interest in violation of General Principles of Accounting Practice (GAAP).
- After the transfer, Mr. Grieco and Mr. Tiernan failed to return Movant’s name to the title of the building and instead transferred ownership to * Fountain Street, LLC.
- Mr. Grieco and Mr. Tiernan engaged in fraudulent activities, including embezzlement, commingling of funds, and tax evasion, as evidenced by forensic CPA Lori Horton’s report.
*. **Indigency and Financial Hardship
---
United States Bankruptcy Court
District of Rhode Island
In re:
James Cronan, Debtor
Case No.: [Insert Case Number]
James Cronan, Movant
v.
* Fountain Street, Assignee Mr. Tiernan, Respondent
MOTION TO CONTEST WRIT OF EXECUTION AND REQUEST FOR EMERGENCY STAY
NOW COMES Movant, James Cronan, and hereby files this Motion to Contest the Writ of Execution issued by the Court in favor of Respondent, * Fountain Street, Assignee Mr. Tiernan. Movant also requests an emergency stay. In support of this Motion, Movant states as follows:
*. Fraudulent Conveyance
- The default judgment was purchased by Mr. Grieco and Mr. Tiernan for $*,*, defrauding creditors while leaving Movant with the Small Business Administration (SBA) loan, which he continues to pay. This left Movant stripped of his original business and commercial property, while Mr. Grieco and Mr. Tiernan receiveda $*.* million windfall.
- The purchase of the judgment was not made in good faith as required under * U.S.C. *(m) as a prerequisite for the court to order the writ of execution.
*. Misrepresentation and Mismanagement
- Movant was advised by Mr. Grieco to move from Chapter * to Chapter * under the promise that his sole ownership of a $*.* million commercial building, * Fountain Street, Rhode Island (now owned by Respondent and assignee), would be restored after the sale.
- Mr. Grieco, who was Movant’s long-term CPA, went into a partnership business with James Cronan, engaging in a conflict of interest in violation of General Principles of Accounting Practice (GAAP).
- After the transfer, Mr. Grieco and Mr. Tiernan failed to return Movant’s name to the title of the building and instead transferred ownership to * Fountain Street, LLC.
- Mr. Grieco and Mr. Tiernan engaged in fraudulent activities, including embezzlement, commingling of funds, and tax evasion, as evidenced by forensic CPA Lori Horton’s report.
*. **Indigency and Financial Hardship
no mistake. - The default judgment was NOT purchased by Mr. Grieco and Mr. Tiernan for $*,*, rather *. Misrepresentation and Mismanagement
- Movant was advised by Mr. Grieco to move from Chapter * to Chapter * under the promise that his sole ownership of a $*.* million commercial building, * Fountain Street, Rhode Island (now owned by Respondent and assignee), would be restored after the sale which was purchased by Mr. Grieco and Mr. Tiernan for $*,*, in this case , defrauding creditors while leaving Movant with the Small Business Administration (SBA) loan, which he continues to pay. This left Movant stripped of his original business and commercial property, while Mr. Grieco and Mr. Tiernan received a $*.* million windfall
Karen, here's a revised version of James' motion, including the request for an emergency stay and the updated details about the fraudulent purchase:
---
United States Bankruptcy Court
District of Rhode Island
In re:
James Cronan, Debtor
Case No.: [Insert Case Number]
James Cronan, Movant
v.
* Fountain Street, Assignee Mr. Tiernan, Respondent
MOTION TO CONTEST WRIT OF EXECUTION AND REQUEST FOR EMERGENCY STAY
NOW COMES Movant, James Cronan, and hereby files this Motion to Contest the Writ of Execution issued by the Court in favor of Respondent, * Fountain Street, Assignee Mr. Tiernan. Movant also requests an emergency stay. In support of this Motion, Movant states as follows:
*. Fraudulent Conveyance
- The default judgment was purchased by Mr. Grieco and Mr. Tiernan for $*,*, significantly below its value of $*,*, to offset damages in a lawsuit that Movant has against Mr. Tiernan for illegal foreclosure, usury violations, breach of contract, andviolations under Massachusetts General Laws Chapter 93A.
- The purchase of the judgment was not made in good faith as required under * U.S.C. *(m) as a prerequisite for the court to order the writ of execution.
*. Misrepresentation and Mismanagement
- Movant was advised by Mr. Grieco to move from Chapter * to Chapter * under the promise that his sole ownership of a $*.* million commercial building, * Fountain Street, Rhode Island (now owned by Respondent and assignee), would be restored after the sale.
- Mr. Grieco, who was Movant’s long-term CPA, went into a partnership business with James Cronan, engaging in a conflict of interest in violation of General Principles of Accounting Practice (GAAP).
- After the transfer, Mr. Grieco and Mr. Tiernan failed to return Movant’s name to the title of the building and instead transferred ownership to * Fountain Street, LLC.
- Mr. Grieco and Mr. Tiernan engaged in fraudulent activities, including embezzlement, commingling of funds, and tax evasion, as evidenced by forensic CPA Lori Horton’s report.
*. **Indigency and Financial
---
United States Bankruptcy Court
District of Rhode Island
In re:
James Cronan, Debtor
Case No.: [Insert Case Number]
James Cronan, Movant
v.
* Fountain Street, Assignee Mr. Tiernan, Respondent
MOTION TO CONTEST WRIT OF EXECUTION AND REQUEST FOR EMERGENCY STAY
NOW COMES Movant, James Cronan, and hereby files this Motion to Contest the Writ of Execution issued by the Court in favor of Respondent, * Fountain Street, Assignee Mr. Tiernan. Movant also requests an emergency stay. In support of this Motion, Movant states as follows:
*. Fraudulent Conveyance
- The default judgment was purchased by Mr. Grieco and Mr. Tiernan for $*,*, significantly below its value of $*,*, to offset damages in a lawsuit that Movant has against Mr. Tiernan for illegal foreclosure, usury violations, breach of contract, andviolations under Massachusetts General Laws Chapter 93A.
- The purchase of the judgment was not made in good faith as required under * U.S.C. *(m) as a prerequisite for the court to order the writ of execution.
*. Misrepresentation and Mismanagement
- Movant was advised by Mr. Grieco to move from Chapter * to Chapter * under the promise that his sole ownership of a $*.* million commercial building, * Fountain Street, Rhode Island (now owned by Respondent and assignee), would be restored after the sale.
- Mr. Grieco, who was Movant’s long-term CPA, went into a partnership business with James Cronan, engaging in a conflict of interest in violation of General Principles of Accounting Practice (GAAP).
- After the transfer, Mr. Grieco and Mr. Tiernan failed to return Movant’s name to the title of the building and instead transferred ownership to * Fountain Street, LLC.
- Mr. Grieco and Mr. Tiernan engaged in fraudulent activities, including embezzlement, commingling of funds, and tax evasion, as evidenced by forensic CPA Lori Horton’s report.
*. **Indigency and Financial
see above
Sure, Karen. Here’s the revised version of James' motion, including the request for an emergency stay and the additional details about the fraudulent purchase:
---
United States Bankruptcy Court
District of Rhode Island
In re:
James Cronan, Debtor
Case No.: [Insert Case Number]
James Cronan, Movant
v.
* Fountain Street, Assignee Mr. Tiernan, Respondent
MOTION TO CONTEST WRIT OF EXECUTION AND REQUEST FOR EMERGENCY STAY
NOW COMES Movant, James Cronan, and hereby files this Motion to Contest the Writ of Execution issued by the Court in favor of Respondent, * Fountain Street, Assignee Mr. Tiernan. Movant also requests an emergency stay. In support of this Motion, Movant states as follows:
*. Fraudulent Conveyance
- The default judgment was purchased by Mr. Grieco and Mr. Tiernan for $*,*, defrauding creditors while leaving Movant with the Small Business Administration (SBA) loan, which he continues to pay. This left Movant stripped of his original businessand commercial property, while Mr. Grieco and Mr. Tiernan received a $*.* million windfall.
- The purchase of the judgment was not made in good faith as required under * U.S.C. *(m) as a prerequisite for the court to order the writ of execution.
*. Misrepresentation and Mismanagement
- Movant was advised by Mr. Grieco to move from Chapter * to Chapter * under the promise that his sole ownership of a $*.* million commercial building, * Fountain Street, Rhode Island (now owned by Respondent and assignee), would be restored after the sale, which was purchased by Mr. Grieco and Mr. Tiernan for $*,*, defrauding creditors.
- Mr. Grieco, who was Movant’s long-term CPA, went into a partnership business with James Cronan, engaging in a conflict of interest in violation of General Principles of Accounting Practice (GAAP).
- After the transfer, Mr. Grieco and Mr. Tiernan failed to return Movant’s name to the title of the building and instead transferred ownership to * Fountain Street, LLC.
- Mr. Grieco and Mr. Tiernan engaged in fraudulent
---
United States Bankruptcy Court
District of Rhode Island
In re:
James Cronan, Debtor
Case No.: [Insert Case Number]
James Cronan, Movant
v.
* Fountain Street, Assignee Mr. Tiernan, Respondent
MOTION TO CONTEST WRIT OF EXECUTION AND REQUEST FOR EMERGENCY STAY
NOW COMES Movant, James Cronan, and hereby files this Motion to Contest the Writ of Execution issued by the Court in favor of Respondent, * Fountain Street, Assignee Mr. Tiernan. Movant also requests an emergency stay. In support of this Motion, Movant states as follows:
*. Fraudulent Conveyance
- The default judgment was purchased by Mr. Grieco and Mr. Tiernan for $*,*, defrauding creditors while leaving Movant with the Small Business Administration (SBA) loan, which he continues to pay. This left Movant stripped of his original businessand commercial property, while Mr. Grieco and Mr. Tiernan received a $*.* million windfall.
- The purchase of the judgment was not made in good faith as required under * U.S.C. *(m) as a prerequisite for the court to order the writ of execution.
*. Misrepresentation and Mismanagement
- Movant was advised by Mr. Grieco to move from Chapter * to Chapter * under the promise that his sole ownership of a $*.* million commercial building, * Fountain Street, Rhode Island (now owned by Respondent and assignee), would be restored after the sale, which was purchased by Mr. Grieco and Mr. Tiernan for $*,*, defrauding creditors.
- Mr. Grieco, who was Movant’s long-term CPA, went into a partnership business with James Cronan, engaging in a conflict of interest in violation of General Principles of Accounting Practice (GAAP).
- After the transfer, Mr. Grieco and Mr. Tiernan failed to return Movant’s name to the title of the building and instead transferred ownership to * Fountain Street, LLC.
- Mr. Grieco and Mr. Tiernan engaged in fraudulent
now only from " Mr. Grieco and Mr. Tiernan engaged in fraudulent" onwward keeping without the borderline.
---
Mr. Grieco and Mr. Tiernan engaged in fraudulent activities, including embezzlement, commingling of funds, and tax evasion, as evidenced by forensic CPA Lori Horton’s report.
*. Indigency and Financial Hardship
- Movant was indigent and unable to pay the $*,* demanded by the Trustee's agent to finalize the adversary proceeding.
- Movant’s financial records were destroyed by Mr. Grieco and Mr. Tiernan, causing further financial hardship.
*. Threats and Coercion
- Movant was threatened by Mr. Grieco and Mr. Tiernan to stop asking to put his name back on the commercial building, under threat of foreclosure on Karen’s property.
- Movant was coerced into moving from Chapter * to Chapter * based on false promises that the building ownership would be restored.
- James’ affidavit detailing the threats made by Mr. Tiernan and Mr. Grieco is included.
*. Evidence
- Bill of Sale: Document showing the transfer of ownership of James' original business, Classic Display, to Mr. Grieco.
- Court Tape: Recording of the court proceedings where Mr. Grieco establishes himself as James' accountant and partner.
- Tax Returns: Two years of tax returns filed by Mr. Grieco showing James as an officer of the new company, The Classic Group Inc.
- Share Transfer: Evidence of the transfer of * shares from James to Mr. Tiernan under the promise of a tax break.
- Forensic CPA Report: Report by Lori Horton showing commingling of funds, tax evasion, and embezzlement.
- Foreclosure Deed: Document showing the foreclosure on Karen’s property as a result of Mr. Tiernan's threats.
- Federal Complaint: Complaint filed in federal court against Mr. Tiernan for illegal foreclosure.
- Order Granting Motion for Approval of Sale: Document showing the court's reliance on false representations about the sale's fairness and the buyer's good faith under * U.S.C. *(m).
- Motion Filed by * Fountain Street: Document showing false statements under Rule *(b)*, indicating fraud on the court.
- * Fountain Street LLC's Motion for Issuance of Writ of Execution: Document showing false statements under Rule *(b)(*), indicating fraud on the court. The motion falsely claimed that
Mr. Grieco and Mr. Tiernan engaged in fraudulent activities, including embezzlement, commingling of funds, and tax evasion, as evidenced by forensic CPA Lori Horton’s report.
*. Indigency and Financial Hardship
- Movant was indigent and unable to pay the $*,* demanded by the Trustee's agent to finalize the adversary proceeding.
- Movant’s financial records were destroyed by Mr. Grieco and Mr. Tiernan, causing further financial hardship.
*. Threats and Coercion
- Movant was threatened by Mr. Grieco and Mr. Tiernan to stop asking to put his name back on the commercial building, under threat of foreclosure on Karen’s property.
- Movant was coerced into moving from Chapter * to Chapter * based on false promises that the building ownership would be restored.
- James’ affidavit detailing the threats made by Mr. Tiernan and Mr. Grieco is included.
*. Evidence
- Bill of Sale: Document showing the transfer of ownership of James' original business, Classic Display, to Mr. Grieco.
- Court Tape: Recording of the court proceedings where Mr. Grieco establishes himself as James' accountant and partner.
- Tax Returns: Two years of tax returns filed by Mr. Grieco showing James as an officer of the new company, The Classic Group Inc.
- Share Transfer: Evidence of the transfer of * shares from James to Mr. Tiernan under the promise of a tax break.
- Forensic CPA Report: Report by Lori Horton showing commingling of funds, tax evasion, and embezzlement.
- Foreclosure Deed: Document showing the foreclosure on Karen’s property as a result of Mr. Tiernan's threats.
- Federal Complaint: Complaint filed in federal court against Mr. Tiernan for illegal foreclosure.
- Order Granting Motion for Approval of Sale: Document showing the court's reliance on false representations about the sale's fairness and the buyer's good faith under * U.S.C. *(m).
- Motion Filed by * Fountain Street: Document showing false statements under Rule *(b)*, indicating fraud on the court.
- * Fountain Street LLC's Motion for Issuance of Writ of Execution: Document showing false statements under Rule *(b)(*), indicating fraud on the court. The motion falsely claimed that
Now only from- * Fountain Street LLC's Motion for Issuance of Writ of Execution: Document showing false statements under Rule *(b)(*), indicating fraud on the court. The motion falsely claimed that" onward and please add the civial action cover sheet to bristol Superior court esatblisng the complaint To Register Judgment
---
* Fountain Street LLC's Motion for Issuance of Writ of Execution: Document showing false statements under Rule *(b)(*), indicating fraud on the court. The motion falsely claimed that * Fountain Street LLC was a "Creditor" and requested issuance of a Writ of Execution when in fact they were a debtor involved in a fraudulent conveyance to defraud a creditor, Karen Merritt, one of the movants in this case.
*. Request for Relief
- Movant requests the Court to set aside the Writ of Execution based on the fraudulent activities and misrepresentation by Mr. Grieco, Mr. Tiernan, and * Fountain Street LLC.
- Movant seeks to challenge the default judgment on the grounds of fraud and mismanagement.
- Movant requests an emergency stay as Movants received the summons being sued by * Fountain Street LLC by a complaint filed on January *, *, in the Bristol Superior Court (Docket No. * CV *) seeking a Complaint To Register Judgment based on fraud. Movants will be irreparably harmed if it proceeds, as the scheme includes mortgage fraud, bankruptcy fraud, conspiracy, mail fraud, criminaland civil conspiracy, and other federal and state crimes, which Movants have endured since *.
Would you like more assistance with any specific parts or additional information on related legal matters?
* Fountain Street LLC's Motion for Issuance of Writ of Execution: Document showing false statements under Rule *(b)(*), indicating fraud on the court. The motion falsely claimed that * Fountain Street LLC was a "Creditor" and requested issuance of a Writ of Execution when in fact they were a debtor involved in a fraudulent conveyance to defraud a creditor, Karen Merritt, one of the movants in this case.
*. Request for Relief
- Movant requests the Court to set aside the Writ of Execution based on the fraudulent activities and misrepresentation by Mr. Grieco, Mr. Tiernan, and * Fountain Street LLC.
- Movant seeks to challenge the default judgment on the grounds of fraud and mismanagement.
- Movant requests an emergency stay as Movants received the summons being sued by * Fountain Street LLC by a complaint filed on January *, *, in the Bristol Superior Court (Docket No. * CV *) seeking a Complaint To Register Judgment based on fraud. Movants will be irreparably harmed if it proceeds, as the scheme includes mortgage fraud, bankruptcy fraud, conspiracy, mail fraud, criminaland civil conspiracy, and other federal and state crimes, which Movants have endured since *.
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* Fountain Street LLC's Motion for Issuance of Writ of Execution: Document showing false statements under Rule *(b)(*), indicating fraud on the court. The motion falsely claimed that * Fountain Street LLC was a "Creditor" and requested issuance of a Writ of Execution when, in fact, they were a debtor involved in a fraudulent conveyance to defraud a creditor, Karen Merritt, one of the movants in this case.
*. Request for Relief and Emergency Stay
- Movant requests the Court to set aside the Writ of Execution based on the fraudulent activities and misrepresentation by Mr. Grieco, Mr. Tiernan, and * Fountain Street LLC.
- Movant seeks to challenge the default judgment on the grounds of fraud and mismanagement.
- Movant requests a hearing to present evidence and arguments supporting the motion.
- Movant requests an emergency stay to prevent irreparable harm as a result of the summons received from * Fountain Street LLC, which filed a complaint in Bristol Superior Court (docket number * CV *) on January *, *, seeking to register a judgment based on fraud. If this complaint proceeds, the Movants will be irreparably harmed due to the ongoing scheme of mortgage fraud, bankruptcy fraud, conspiracy, mail fraud, criminal and civil conspiracy, and other federal and state crimes endured since *.
Would you like additional assistance with any specific sections or details?
*. Request for Relief and Emergency Stay
- Movant requests the Court to set aside the Writ of Execution based on the fraudulent activities and misrepresentation by Mr. Grieco, Mr. Tiernan, and * Fountain Street LLC.
- Movant seeks to challenge the default judgment on the grounds of fraud and mismanagement.
- Movant requests a hearing to present evidence and arguments supporting the motion.
- Movant requests an emergency stay to prevent irreparable harm as a result of the summons received from * Fountain Street LLC, which filed a complaint in Bristol Superior Court (docket number * CV *) on January *, *, seeking to register a judgment based on fraud. If this complaint proceeds, the Movants will be irreparably harmed due to the ongoing scheme of mortgage fraud, bankruptcy fraud, conspiracy, mail fraud, criminal and civil conspiracy, and other federal and state crimes endured since *.
Would you like additional assistance with any specific sections or details?
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