Document 546
Case 08-71107
…10. White has blatantly indicated that no matter what the judgment, he intends to do everything possible to hide assets and frustrate collection of the judgment and the administration of justice. In one of White’s recent filings, White states: “The question is what terms are the judgment creditors [Unnamed Citizens] . . . willing to accept? Given that Debtor can simply operate under a company name and avoid the judgment indefinitely, there may not be a point in maintaining any property in his name any longer.” (Dkt. no. 538, p. 4).
11. Due to Debtor’s avowed intention to frustrate collection it is the position of the Unnamed Citizens that they would be better served by dismissal of the action. Given that Debtor is still incarcerated, and may be incarcerated for many years, the interests of the Unnamed Citizens are better served by being able to act quickly to attach the few assets remaining in the estate. Converting this case to a Chapter 7 case would do little more than waste the time of the Chapter 7 Trustee and the assets of the estate paying for the costs of administration.
WHEREFORE, the Unnamed Citizens respectfully request that this Court deny William A White’s Motion to Convert to Chapter 7 and grant the U.S. Trustee’s Motion to Dismiss; and for such other and further relief as may be proper.
Respectfully submitted, this 2nd day of November, 2010.
/s/ Richard E. Hagerty
Richard E. Hagerty, VSB No. 47673
Troutman Sanders LLP
1660 International Drive, Suite 600
McLean, VA
734-4326
(703) 448-6520 fax
richard.hagerty@troutmansanders.com