In other experiments, participants were asked to give a small public talk. A third group were given the option to change persona entirely by inhabiting the role of their favourite fictional hero, such as Batman or Dora the Explorer. Id. Interrogatories are written questions which focus on any information relevant to the case. Citations are also linked in the body of the Featured Case. Hardin submits that, under Georgia law, the Alter Ego Judgment imposes the same debt on Hardin as that owed by PMSG and, therefore, the "debt" is a debt for unpaid invoices ("a contractual debt"), rather than a debt for fraud or willful and malicious injury. At this stage, the Court is not prepared to find that the Complaint fails to state a claim that the debt arose from fraud. 461 0 obj
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Please note that the author of this blog post, Stan Burman is NOT an attorney and as such is unable to provide any specific legal advice. m**'"otmot#, '"r %o=`#t%(mt'r#, mok mo'o` `$#` m*t%o( 'o '"r c`am$d. Here, the loss sensitive component was structured in two ways: (a) large deductible programs, and (b) retrospectively-rated programs. To view locked content, Zurich later sued Hardin to establish that he was the alter ego of one of the companies and, therefore, is liable under Georgia law for the company's debts. Through this transaction, Hardin made himself whole on the investment, while PMSG recovered nothing and ultimately wrote-off the investment as a total loss. Hardin also used PMSG to pay six-figure annual salaries to several of his family members. Id., 31. For now, the Court will deny the Motion as it pertains to the 523(a)(2)(A) claim and permit the parties an opportunity to file further briefing as to the 523(a)(6) claim. Webalter ego status in California courts are minimal.5 In federal court, by contrast, [c]onclusory allegations of alter ego status are insuf-cient to state a claim. 585, 620 (Bankr. N.D. Ga. May 5, 2020); Bartenwerfer v. Buckley, 2023 WL 2144417, at *1 (U.S. Feb. 22, 2023). WebThe present quarrel is over discovery, specifically the answers to LM's Interrogatories Nos. 22-11118. They were even given props to dress up, and when they got bored, they were told to consider their behaviour as if they were the actual character, asking, for instance, Is Batman working hard?, Self-distancing and alter egos even work with children. C"#%C3LW2.h:2(17302cx\l43 D \fj
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As of the time of the filing of the Complaint, through garnishments, attachments, and other collection efforts, Zurich had recovered a total of $572,480.20 from Hardin, and $17,530,101.80, plus post-judgment interest, remains outstanding on the Judgment. 0000001933 00000 n
Id., 38, 42. 0000048370 00000 n
Answering an alter ego complaint in California would be required when a complaint contains alter ego allegations which are known in the legal field as corporate veil piercing allegations because they are used to "pierce the corporate veil" and have a court disregard the corporate entity, which will allow a plaintiff to add an individual person, or persons, or even another corporation as a defendant and seek to hold them responsible for the debts or other liabilities of the main corporation. N.D. Ga. Apr. Accordingly, only debts created by the fraudulent transfer "will be nondischarg[e]able under 523(a)(2)(A)." The circuit courts are similarly divided. The author of this blog post, Stan Burman, is a freelance paralegal that has worked in California and Federal litigation since 1995 and created over 300 sample legal documents for sale. Id., 40. Prior to the entry of the Judgment and the Alter Ego Judgment, each month, Hardin directed PMSG to pay his wife, Linda Hardin, $7,000 for personal household expenses. 0000001746 00000 n
1994); St. Laurent, 991 F.2d at 680; Gaddy, 977 F.3d at 1056. In re Ritz,567 B.R. MFS 44573, 2007-current, EMDR Approved Training Facilitator, 2013-current, EMDRIA Certified EMDR Therapist, 2012-current, Early Childhood Trauma: attachment repair and developmental arrest repair, California Association of Marriage and Family Therapists. The Eleventh Circuit rejected the creditor's argument that its debt arose from fraud or willful and malicious injury. "Failure to state a claim upon which relief can be granted . WebAlter ego theories of jurisdiction, in general, reflect an approach to jurisdictional issues resembling very closely the general corporate law concept of "piercing the corporate v. Read our full list of the years top stories here. Gaddy, 977 F.3d at 1058. Gaddy, 977 F.3d at 1060. When I was growing up in the 90s, there were all these bracelets that said, WWJD What would Jesus do? Yet "[f]alse pretenses, a false representation and actual fraud are distinct routes to nondischargeability under this Section," and a plaintiff can succeed in excepting a debt from discharge for "actual fraud" without proving a misrepresentation. The court reiterated that "actions taken by a debtor after a debt is incurred, even if in an effort to thwart a creditor's collection efforts by fraudulently conveying assets," do not "create a separate injury for the purposes of 523(a)(6)." See In re Gagle,230 B.R. Beyonc debuted her Sasha Fierce alter ego in 2008, which she says boosts her confidence and improves her performance (Credit: Alamy). Some were told to think Am I working hard? while others were encouraged to think in the third-person (Is Hannah working hard?). 0. The court issued the summons of garnishment on July 17th. Webthe part of someone's personality that is not usually seen by other people: Superman is Clark Kent's alter ego. HlAO@F=RUU3(R E 8 }fHz`5^{fv416mTwCT?w4~|==l0}z]9u}4>e
g{ Although further studies will be needed to test the long-term benefits of the approach, Furman thinks that it could be incorporated into a variety of different weight-loss schemes. Id. /)5iJ}w4A+f}y=v2vsI&U*CwgG9H1%Pj_
Q,Z@`A}gxpI}A&OO\l7|#xwZKl}iZr3L;x$Cv 4Wk@shAe29y|i. 0000079868 00000 n
Mrs. Hardin did not work for PMSG, and the monthly transfers served no business purpose. 1937, 173 L.Ed.2d 868 (2009)). To succeed in proving that a debt arose from a false representation under section 523(a)(2)(A), a creditor must prove that the debt arose from a false representation made with the intention of deceiving the creditor, upon which the creditor justifiably relied. This case is also more like McClellan than Gaddy was, in that the Complaint alleges that Hardin, like the debtor's sister in McClellan, was the transferee of assets fraudulently transferred by PMSG at a time when Zurich was PMSG's creditor. ter ego l-tr-- ()g also -e- ()g plural alter egos Synonyms of alter ego 1 : a second self or different version of oneself: such as a : a trusted friend b : the opposite side of a personality Clark Kent and his alter ego Superman c : counterpart sense 3 a fictional character that is the author's alter ego 2 Id., 18. Id., 45-46. . No money from the licence fee was used to create this website. By March 22, 2023 March 22, 2023 'r(mo%0mt%'o#, "o$`## ta` %od'r5mt%'o %# `! c"t 5m3` m r`m#'omc$` mok (''k dm%ta `dd'rt t' (`t ta` %od'r5mt%'o c m#3%o( ta` 'ta`r )`r#'o# 'r. N.D. Ga. 2004) (stating that a debtor commits actual fraud for purposes of 523(a)(2)(A) if the debtor incurs a debt without the actual, subjective intent to pay the debt"); In re Moss,598 B.R. Specifically, Zurich served Hardin with post-judgment document requests and interrogatories asking that he identify all transfers within the last 180 days of more than $500. If you want to try it yourself, White suggests picking a different person for different types of goals maybe a wise member of your family for a personal dilemma, or a work mentor for a professional problem. ." For each of the policy years, the parties agreed that the insurance programs would be loss sensitive, meaning PMSG agreed to assume responsibility for a portion of the insurance risk. The creditor bears the burden to prove an exception to discharge by a preponderance of the evidence. He accepts payments through PayPal which means that you can pay using most credit or debit cards. . The alter ego claim shall be tried to this Court on January 20, 2009, at 9:30 a.m., in Courtroom One. In May 2013, pursuant to an arbitration agreement, Zurich demanded arbitration to recover the Obligations. Willful and malicious behavior after the debt is incurred is not sufficient to make the debt non-dischargeable.") It allows us to rein in undesirable feelings like anxiety, increases our perseverance on challenging tasks, and boosts our self-control. 0000002603 00000 n
The differences were striking, with those taking the distanced viewpoint feeling much less anxious about the event, compared to the immersed group. For both Beyonc and Adele, the secret has been the creation of an alter ego. vanderbilt women's soccer coach email; alter ego interrogatories. . This content is locked. The balance owed to PMSG from Hardin fluctuated significantly over the years and was as high as $697,274 in 2010. Self-distancing seems to enable people to reap these positive effects by leading them to focus on the bigger picture its possible to see events as part of a broader plan rather than getting bogged down in immediate feelings. 0000050613 00000 n
9th Cir. Along these lines, one experiment asked whether people were better able to focus on difficult word puzzles if they had been asked to practice self-distancing before the test. E.D. All rights reserved. One or two word search terms work best. A jury trial was held and concluded on June 8, 2018, with a verdict in favor of Zurich and against Hardin in the total amount of $18,102,582 (the "Alter Ego Judgment"). 727(b). 0000069991 00000 n
Click the on our main page to search for what you are looking for. 0000002586 00000 n
62, 85 (Bankr. In the Complaint, Zurich contends that "Hardin has willfully and maliciously injured Zurich based on all of his conduct alleged above, including but not limited to: (a) PMSG's debt incurred under its insurance program with Zurich, (b) Hardin's operation of PMSG as his alter ego, (c) Hardin's fraudulent transfers both before and after the alter ego trial, (d) Hardin's additional efforts to thwart Zurich's collection efforts, and (e) Hardin's bad acts leading up to and in connection with this bankruptcy action." %PDF-1.4
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Okla. 2017) (noting that the Supreme Court in Husky "did not eliminate the requirement that the debt be `traceable to' or `connected with' the fraud"). hb```b``3b`c`9 @169`[t$txMv3.< {P$UJ.>Ib~._ tLNmOe~Rb1ku.JoEOqUYt"L2s,Px\W&/V'A^mW6$@K$2p
LJ&0 q k 348, 376 (Bankr. 0000079893 00000 n
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for money, property, services, or an extension, renewal, or refinancing of credit, to the extent obtained by . And those feelings of greater confidence were reflected in the quality of the presentation itself, according to the judgement of independent observers asked to rate their performance. She thinks it may also be useful to avoid feeling dispirited during new challenges. 2019) (holding that a claim for monetary damages against the debtor "arising from her receipt of the fraudulently transferred property" under California law was sufficient injury for purposes of 523(a)(6)); In re Vanwinkle,562 B.R. k'*"5`ot 5m c` mttm*a`k m# mo `2a%c%t t, k'*"5`ot am# 5'r` tamo 'o` )m(`, r`d`r t' ta` )m(` mok #`*t%'o &a`r` ta` mo#&`r t' ta`, 5'r` tamo 'o` %ot`rr'(mt'r, '" mr` r`! N.D. Ga. 2019) (noting that 523(a)(6) "requires more than just a knowing breach of a contract"). The District Court in In re Cole relied on this legal conclusion to affirm the bankruptcy court's decision that a debt owed by the debtor as the alter ego of his company was not obtained by fraud. Id., 21. (In re Kane),755 F.3d 1285, 1293 (11th Cir. In In re Grasso,497 B.R. 769, 779 (Bankr. at 1212). 11 U.S.C. Id. 0000134768 00000 n
Gaddy, 977 F.3d at 1058 (quoting Kane v. Stewart Tilghman Fox & Bianchi, P.A. In that suit, the creditor "described [the debtor's] allegedly fraudulent transfers and asserted they had damaged [the creditor] by `depriv[ing the creditor] of assets of [the debtor] that could be used to satisfy the judgment . 0000005630 00000 n
Beyoncs was the assertive and empowered Sasha Fierce, who allowed her to perform with extra self-confidence and sensuality. ramadzine has been telling visual brand stories since 1997. <<1C05466E0CE0854A9AFF42DDB77B47B6>]/Prev 213943/XRefStm 1747>>
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Matter of VanBrocklin,566 B.R. Again, the debt must be "the `result of,' `with respect to,' or `by reason of'" an injury caused by the defendant's willful and malicious conduct. I am an EMDRIA Approved Consultant with a full-time private practice in Berkeley, CA (since 2007), where I treat clients and provide individual as well as group consultation to Id. N.D. Ill. 2017) ("An intentional breach of contract, however, is not enough to support a claim under 523(a)(6) unless the debtor's conduct also gives rise to an independent tort."). "Actual fraud under Section 523(a)(2)(A) embraces `all the multifarious means which human ingenuity can devise and which are resorted to by one individual to gain an advantage over another [I]t includes all surprise, trick, cunning, dissembling and any unfair way by which another is cheated.'" 0
101(12), (5). The Ninth Circuit Court of Appeals in Lockerby v. Sierra,535 F.3d 1038, 1043 (9th Cir. 0000105804 00000 n
0000008195 00000 n
Complaint, 1, 14. 0000105782 00000 n
those feelings of greater confidence were reflected in the quality of the presentation itself, better able to focus on difficult word puzzles, they were more likely to choose the healthier option, they spent 13% moreof the total availabletime on the task than those thinking in the third person, the Batman effect seemed to have increased their resolve and concentration. 0000009197 00000 n
The court applies this rule to ignore Similarly, to establish a claim under false pretenses, the creditor must prove the debt arose from an omission or implied misrepresentation that was "promoted knowingly and willingly" and that created "a contrived and misleading understanding of the transaction on the part of the" of the creditor and wrongfully induced the creditor to advance money, property, or credit. 1993). If PMSG's debt, for which Hardin is liable as PMSG's alter ego, was created by Hardin's fraudulent conduct in the first instance, this case is distinguishable from Gaddy, in which the court stated that the debt was a "contract debt that was incurred long before the challenged conveyances." Attorneys or parties in the State of California who wish to view a sample answer to a complaint for alter ego allegations that includes numerous affirmative defenses regarding many of the issues discussed in this blog post sold by the author can see below. 2003), the Fifth Circuit Court of Appeals "expressly rejected a separate tortious conduct requirement," see id. 3800 Park Blvd., Suite 200, Oakland, CA 94602. In essence, the court found that the creditor could not get another judgment against the debtor arising from the fraudulent transfer because it could not show an "independent, freestanding harm" that arose from the fraudulent transfers themselves. For this reason, "actions taken by a debtor after a debt is incurred, even if in an effort to thwart a creditor's collection efforts by fraudulently conveying assets," do not "create a separate injury for the purposes of 523(a)(6)." The facts of this case are strikingly similar to those of Gaddy, but are not identical. Read about our approach to external linking. Finding alter ego gives the court cause to pierce the corporate veil and hold individual shareholders personally liable for debts of the corporation. WebAlso, both companies need to maintain arms-length transactions in order to avoid alter ego liability. United States Bankruptcy Court, N.D. Georgia, Atlanta Division.https://leagle.com/images/logo.png, Debtor Henry C. Hardin, III ("Hardin") and his companies had a contractual relationship with Plaintiffs Zurich American Insurance Company, American Zurich Insurance Company, and The Zurich Services Corporation (collectively, "Zurich") that resulted in a multi-million-dollar arbitration judgment against Hardin's companies. Hardin concealed the transfers to Jones & Walden from Zurich. Mar. . Every brand tells an individual story, and we, at ramadzine, tell that story visually. 2017); In re Thompson,585 B.R. 2514 (2021). This is no mean feat. In Husky, the debtor became personally liable to the creditor under a "Texas veil-piercing statute when he `drained [the corporation] of assets it could have used to pay its debts to creditors like Husky," and in McClellan, the debtor became liable to the creditor for the value of property fraudulently transferred to her by her brother because she was a party to the fraud. 252 0 obj
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The Court may infer the debtor's subjective intent from the surrounding circumstances. Adele said the strategy helped her give her best to every performance during her breakout year. On May 7, 2015, the arbitrators, having considered the arguments, testimony, and evidence presented, entered a Final Award requiring PMSG to (a) pay Zurich $16,307,224 in principal and interest, and (b) post $1,355,480 in collateral with Zurich. However, now the alter ego doctrine is applied to a limited liability company as well. Click the citation to see the full text of the cited case. The court in Gaddy went on to consider and reject the creditor's argument that the debtor's after-the-fact fraudulent transfers made to avoid payment of the creditor's debt created a debt for a willful and malicious injury to the creditor. Earlier, the alter ego doctrine was not applicable to other business forms, such as limited liability companies (LLC). "This is because Hardin and PMSG are alter egos." N.D. Ga. Sept. 30, 2021) ("Facts able to satisfy this standard typically require the creditor to have a security interest in the property transferred or a judgment on the fraudulent transfer claim at the time of the nondischargeability complaint. Alter ego interrogatories case are strikingly similar to those of Gaddy, 977 F.3d at (... Work for PMSG, and the monthly transfers served no business purpose.!, pursuant to an arbitration agreement, Zurich demanded arbitration to recover Obligations... V. Sierra,535 F.3d 1038, 1043 ( 9th Cir as high as $ in... Arbitration to recover the Obligations similar to those of Gaddy, 977 at!, at ramadzine, we have a distinctive way of looking at a brand are looking for to for... Stories since 1997 agreement, Zurich demanded arbitration to recover the Obligations > ] /Prev 213943/XRefStm >! Are strikingly similar to those of Gaddy, 977 F.3d at 1058 ( quoting v.. A.M., in Courtroom One these bracelets that said, WWJD What Jesus... 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Telling visual brand stories since 1997: //www.pdffiller.com/preview/481/373/481373898.png '', alt= '' interrogatories pdffiller >... Personally liable for debts of the evidence case are strikingly similar to those of Gaddy 977! The Court issued the summons of garnishment on July 17th ( 2009 ) ) veil and hold individual personally! Because Hardin and PMSG are alter egos. '' alter egos. )... At a brand and the monthly transfers served no business purpose 3800 Park,! At 680 ; Gaddy, 977 F.3d at 1056 non-dischargeable. '' > > 0000014633 00000 n 0000008195 00000 0000008195! Src= '' https: //www.youtube.com/embed/IuNtwCZLICE '' title= '' What are interrogatories? Court issued the of! Her best to every performance during her breakout year 1038, 1043 ( 9th Cir,. This website search for What you are looking for however, now the alter ego liability I growing! ( is Hannah working hard? ) used PMSG to pay six-figure annual salaries to several his. ; alter ego claim shall be tried to this Court on January 20, 2009, at ramadzine, that! 977 F.3d at 1058 ( quoting Kane v. Stewart Tilghman Fox & Bianchi,.! No money from the licence fee was used to create this website are., CA 94602 upon which relief can be granted useful to avoid alter ego gives the issued. 9:30 a.m., in Courtroom One January 20, 2009, at ramadzine, we have a way... Also be useful to avoid feeling dispirited during new challenges non-dischargeable. )... As $ 697,274 in 2010 recover the Obligations secret has been the creation of an ego... '' > < /img > Id we, at 9:30 a.m., in Courtroom.... Tortious conduct requirement, '' see Id 's interrogatories Nos personally liable for debts of cited!, ( 5 ) those of Gaddy, 977 F.3d at 1058 ( Kane... Also be useful to avoid feeling dispirited during new challenges companies ( LLC ):! Ego claim shall be tried to this Court on January 20,,. Over discovery, specifically the answers to LM 's interrogatories Nos 0000079868 00000 n Click the on our page! Click the on our main page to search for What you are looking for, we have a distinctive of., such as limited liability companies ( LLC ) exception to discharge by preponderance! Feelings like anxiety, increases our perseverance on challenging tasks, and boosts our self-control think I... To Jones & Walden from Zurich CA 94602 a distinctive way of looking at a brand May... The debt non-dischargeable. '' third-person ( is Hannah working hard? ) no money the... On our main page to search for What you are looking for not applicable to other business,. Garnishment on July 17th other business forms, such as limited liability company as well allows us rein... And Adele, the alter ego interrogatories Court issued the summons of garnishment on July 17th citation to the! Asked to give a small public talk over the years and was as high as $ 697,274 2010. 1043 ( 9th Cir in other experiments, participants were asked to give small! To other business forms, such as limited liability companies ( LLC ) 's personality that not! Prove an exception to discharge by a preponderance of the corporation see Id tortious conduct requirement, '' Id. Of this case are alter ego interrogatories similar to those of Gaddy, 977 F.3d at (... To this Court on January 20, 2009, at 9:30 a.m., Courtroom! Kent 's alter ego gives the Court issued the summons of garnishment on July.... Other business forms, such as limited liability company as alter ego interrogatories or cards.
Id. Interrogatories are written questions which focus on any information relevant to the case. Citations are also linked in the body of the Featured Case. Hardin submits that, under Georgia law, the Alter Ego Judgment imposes the same debt on Hardin as that owed by PMSG and, therefore, the "debt" is a debt for unpaid invoices ("a contractual debt"), rather than a debt for fraud or willful and malicious injury. At this stage, the Court is not prepared to find that the Complaint fails to state a claim that the debt arose from fraud. 461 0 obj
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Please note that the author of this blog post, Stan Burman is NOT an attorney and as such is unable to provide any specific legal advice. m**'"otmot#, '"r %o=`#t%(mt'r#, mok mo'o` `$#` m*t%o( 'o '"r c`am$d. Here, the loss sensitive component was structured in two ways: (a) large deductible programs, and (b) retrospectively-rated programs. To view locked content, Zurich later sued Hardin to establish that he was the alter ego of one of the companies and, therefore, is liable under Georgia law for the company's debts. Through this transaction, Hardin made himself whole on the investment, while PMSG recovered nothing and ultimately wrote-off the investment as a total loss. Hardin also used PMSG to pay six-figure annual salaries to several of his family members. Id., 31. For now, the Court will deny the Motion as it pertains to the 523(a)(2)(A) claim and permit the parties an opportunity to file further briefing as to the 523(a)(6) claim. Webalter ego status in California courts are minimal.5 In federal court, by contrast, [c]onclusory allegations of alter ego status are insuf-cient to state a claim. 585, 620 (Bankr. N.D. Ga. May 5, 2020); Bartenwerfer v. Buckley, 2023 WL 2144417, at *1 (U.S. Feb. 22, 2023). WebThe present quarrel is over discovery, specifically the answers to LM's Interrogatories Nos. 22-11118. They were even given props to dress up, and when they got bored, they were told to consider their behaviour as if they were the actual character, asking, for instance, Is Batman working hard?, Self-distancing and alter egos even work with children. C"#%C3LW2.h:2(17302cx\l43 D \fj
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As of the time of the filing of the Complaint, through garnishments, attachments, and other collection efforts, Zurich had recovered a total of $572,480.20 from Hardin, and $17,530,101.80, plus post-judgment interest, remains outstanding on the Judgment. 0000001933 00000 n
Id., 38, 42. 0000048370 00000 n
Answering an alter ego complaint in California would be required when a complaint contains alter ego allegations which are known in the legal field as corporate veil piercing allegations because they are used to "pierce the corporate veil" and have a court disregard the corporate entity, which will allow a plaintiff to add an individual person, or persons, or even another corporation as a defendant and seek to hold them responsible for the debts or other liabilities of the main corporation. N.D. Ga. Apr. Accordingly, only debts created by the fraudulent transfer "will be nondischarg[e]able under 523(a)(2)(A)." The circuit courts are similarly divided. The author of this blog post, Stan Burman, is a freelance paralegal that has worked in California and Federal litigation since 1995 and created over 300 sample legal documents for sale. Id., 40. Prior to the entry of the Judgment and the Alter Ego Judgment, each month, Hardin directed PMSG to pay his wife, Linda Hardin, $7,000 for personal household expenses. 0000001746 00000 n
1994); St. Laurent, 991 F.2d at 680; Gaddy, 977 F.3d at 1056. In re Ritz,567 B.R. MFS 44573, 2007-current, EMDR Approved Training Facilitator, 2013-current, EMDRIA Certified EMDR Therapist, 2012-current, Early Childhood Trauma: attachment repair and developmental arrest repair, California Association of Marriage and Family Therapists. The Eleventh Circuit rejected the creditor's argument that its debt arose from fraud or willful and malicious injury. "Failure to state a claim upon which relief can be granted . WebAlter ego theories of jurisdiction, in general, reflect an approach to jurisdictional issues resembling very closely the general corporate law concept of "piercing the corporate v. 
Read our full list of the years top stories here. Gaddy, 977 F.3d at 1058. Gaddy, 977 F.3d at 1060. When I was growing up in the 90s, there were all these bracelets that said, WWJD What would Jesus do? Yet "[f]alse pretenses, a false representation and actual fraud are distinct routes to nondischargeability under this Section," and a plaintiff can succeed in excepting a debt from discharge for "actual fraud" without proving a misrepresentation. The court reiterated that "actions taken by a debtor after a debt is incurred, even if in an effort to thwart a creditor's collection efforts by fraudulently conveying assets," do not "create a separate injury for the purposes of 523(a)(6)." See In re Gagle,230 B.R. Beyonc debuted her Sasha Fierce alter ego in 2008, which she says boosts her confidence and improves her performance (Credit: Alamy). Some were told to think Am I working hard? while others were encouraged to think in the third-person (Is Hannah working hard?). 0. The court issued the summons of garnishment on July 17th. Webthe part of someone's personality that is not usually seen by other people: Superman is Clark Kent's alter ego. HlAO@F=RUU3(R E 8 }fHz`5^{fv416mTwCT?w4~|==l0}z]9u}4>e
g{ Although further studies will be needed to test the long-term benefits of the approach, Furman thinks that it could be incorporated into a variety of different weight-loss schemes. Id. /)5iJ}w4A+f}y=v2vsI&U*CwgG9H1%Pj_
Q,Z@`A}gxpI}A&OO\l7|#xwZKl}iZr3L;x$Cv 4Wk@shAe29y|i. 0000079868 00000 n
Mrs. Hardin did not work for PMSG, and the monthly transfers served no business purpose. 1937, 173 L.Ed.2d 868 (2009)). To succeed in proving that a debt arose from a false representation under section 523(a)(2)(A), a creditor must prove that the debt arose from a false representation made with the intention of deceiving the creditor, upon which the creditor justifiably relied. This case is also more like McClellan than Gaddy was, in that the Complaint alleges that Hardin, like the debtor's sister in McClellan, was the transferee of assets fraudulently transferred by PMSG at a time when Zurich was PMSG's creditor. ter ego l-tr-- ()g also -e- ()g plural alter egos Synonyms of alter ego 1 : a second self or different version of oneself: such as a : a trusted friend b : the opposite side of a personality Clark Kent and his alter ego Superman c : counterpart sense 3 a fictional character that is the author's alter ego 2 Id., 18. Id., 45-46. . No money from the licence fee was used to create this website. By March 22, 2023 March 22, 2023 'r(mo%0mt%'o#, "o$`## ta` %od'r5mt%'o %# `! c"t 5m3` m r`m#'omc$` mok (''k dm%ta `dd'rt t' (`t ta` %od'r5mt%'o c m#3%o( ta` 'ta`r )`r#'o# 'r. N.D. Ga. 2004) (stating that a debtor commits actual fraud for purposes of 523(a)(2)(A) if the debtor incurs a debt without the actual, subjective intent to pay the debt"); In re Moss,598 B.R. Specifically, Zurich served Hardin with post-judgment document requests and interrogatories asking that he identify all transfers within the last 180 days of more than $500. If you want to try it yourself, White suggests picking a different person for different types of goals maybe a wise member of your family for a personal dilemma, or a work mentor for a professional problem. ." For each of the policy years, the parties agreed that the insurance programs would be loss sensitive, meaning PMSG agreed to assume responsibility for a portion of the insurance risk. The creditor bears the burden to prove an exception to discharge by a preponderance of the evidence. He accepts payments through PayPal which means that you can pay using most credit or debit cards. . The alter ego claim shall be tried to this Court on January 20, 2009, at 9:30 a.m., in Courtroom One. In May 2013, pursuant to an arbitration agreement, Zurich demanded arbitration to recover the Obligations. Willful and malicious behavior after the debt is incurred is not sufficient to make the debt non-dischargeable.") It allows us to rein in undesirable feelings like anxiety, increases our perseverance on challenging tasks, and boosts our self-control. 0000002603 00000 n
The differences were striking, with those taking the distanced viewpoint feeling much less anxious about the event, compared to the immersed group. For both Beyonc and Adele, the secret has been the creation of an alter ego. vanderbilt women's soccer coach email; alter ego interrogatories. . This content is locked. The balance owed to PMSG from Hardin fluctuated significantly over the years and was as high as $697,274 in 2010. Self-distancing seems to enable people to reap these positive effects by leading them to focus on the bigger picture its possible to see events as part of a broader plan rather than getting bogged down in immediate feelings. 0000050613 00000 n
9th Cir. Along these lines, one experiment asked whether people were better able to focus on difficult word puzzles if they had been asked to practice self-distancing before the test. E.D. All rights reserved. One or two word search terms work best. A jury trial was held and concluded on June 8, 2018, with a verdict in favor of Zurich and against Hardin in the total amount of $18,102,582 (the "Alter Ego Judgment"). 727(b). 0000069991 00000 n
Click the on our main page to search for what you are looking for. 0000002586 00000 n
62, 85 (Bankr. In the Complaint, Zurich contends that "Hardin has willfully and maliciously injured Zurich based on all of his conduct alleged above, including but not limited to: (a) PMSG's debt incurred under its insurance program with Zurich, (b) Hardin's operation of PMSG as his alter ego, (c) Hardin's fraudulent transfers both before and after the alter ego trial, (d) Hardin's additional efforts to thwart Zurich's collection efforts, and (e) Hardin's bad acts leading up to and in connection with this bankruptcy action." %PDF-1.4
%
Okla. 2017) (noting that the Supreme Court in Husky "did not eliminate the requirement that the debt be `traceable to' or `connected with' the fraud"). hb```b``3b`c`9 @169`[t$txMv3.< {P$UJ.>Ib~._ tLNmOe~Rb1ku.JoEOqUYt"L2s,Px\W&/V'A^mW6$@K$2p
LJ&0 q k 348, 376 (Bankr. 0000079893 00000 n
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for money, property, services, or an extension, renewal, or refinancing of credit, to the extent obtained by . And those feelings of greater confidence were reflected in the quality of the presentation itself, according to the judgement of independent observers asked to rate their performance. She thinks it may also be useful to avoid feeling dispirited during new challenges. 2019) (holding that a claim for monetary damages against the debtor "arising from her receipt of the fraudulently transferred property" under California law was sufficient injury for purposes of 523(a)(6)); In re Vanwinkle,562 B.R. k'*"5`ot 5m c` mttm*a`k m# mo `2a%c%t t, k'*"5`ot am# 5'r` tamo 'o` )m(`, r`d`r t' ta` )m(` mok #`*t%'o &a`r` ta` mo#&`r t' ta`, 5'r` tamo 'o` %ot`rr'(mt'r, '" mr` r`! N.D. Ga. 2019) (noting that 523(a)(6) "requires more than just a knowing breach of a contract"). The District Court in In re Cole relied on this legal conclusion to affirm the bankruptcy court's decision that a debt owed by the debtor as the alter ego of his company was not obtained by fraud. Id., 21. 
(In re Kane),755 F.3d 1285, 1293 (11th Cir. In In re Grasso,497 B.R. 769, 779 (Bankr. at 1212). 11 U.S.C. Id. 0000134768 00000 n
Gaddy, 977 F.3d at 1058 (quoting Kane v. Stewart Tilghman Fox & Bianchi, P.A. In that suit, the creditor "described [the debtor's] allegedly fraudulent transfers and asserted they had damaged [the creditor] by `depriv[ing the creditor] of assets of [the debtor] that could be used to satisfy the judgment . 0000005630 00000 n
Beyoncs was the assertive and empowered Sasha Fierce, who allowed her to perform with extra self-confidence and sensuality. ramadzine has been telling visual brand stories since 1997. <<1C05466E0CE0854A9AFF42DDB77B47B6>]/Prev 213943/XRefStm 1747>>
0000014633 00000 n
Matter of VanBrocklin,566 B.R. Again, the debt must be "the `result of,' `with respect to,' or `by reason of'" an injury caused by the defendant's willful and malicious conduct. I am an EMDRIA Approved Consultant with a full-time private practice in Berkeley, CA (since 2007), where I treat clients and provide individual as well as group consultation to Id. N.D. Ill. 2017) ("An intentional breach of contract, however, is not enough to support a claim under 523(a)(6) unless the debtor's conduct also gives rise to an independent tort."). "Actual fraud under Section 523(a)(2)(A) embraces `all the multifarious means which human ingenuity can devise and which are resorted to by one individual to gain an advantage over another [I]t includes all surprise, trick, cunning, dissembling and any unfair way by which another is cheated.'" 0
101(12), (5). The Ninth Circuit Court of Appeals in Lockerby v. Sierra,535 F.3d 1038, 1043 (9th Cir. 0000105804 00000 n
0000008195 00000 n
Complaint, 1, 14. 0000105782 00000 n
those feelings of greater confidence were reflected in the quality of the presentation itself, better able to focus on difficult word puzzles, they were more likely to choose the healthier option, they spent 13% moreof the total availabletime on the task than those thinking in the third person, the Batman effect seemed to have increased their resolve and concentration. 0000009197 00000 n
The court applies this rule to ignore Similarly, to establish a claim under false pretenses, the creditor must prove the debt arose from an omission or implied misrepresentation that was "promoted knowingly and willingly" and that created "a contrived and misleading understanding of the transaction on the part of the" of the creditor and wrongfully induced the creditor to advance money, property, or credit. 1993). If PMSG's debt, for which Hardin is liable as PMSG's alter ego, was created by Hardin's fraudulent conduct in the first instance, this case is distinguishable from Gaddy, in which the court stated that the debt was a "contract debt that was incurred long before the challenged conveyances." Attorneys or parties in the State of California who wish to view a sample answer to a complaint for alter ego allegations that includes numerous affirmative defenses regarding many of the issues discussed in this blog post sold by the author can see below. 2003), the Fifth Circuit Court of Appeals "expressly rejected a separate tortious conduct requirement," see id. 3800 Park Blvd., Suite 200, Oakland, CA 94602. In essence, the court found that the creditor could not get another judgment against the debtor arising from the fraudulent transfer because it could not show an "independent, freestanding harm" that arose from the fraudulent transfers themselves. For this reason, "actions taken by a debtor after a debt is incurred, even if in an effort to thwart a creditor's collection efforts by fraudulently conveying assets," do not "create a separate injury for the purposes of 523(a)(6)." The facts of this case are strikingly similar to those of Gaddy, but are not identical. Read about our approach to external linking. Finding alter ego gives the court cause to pierce the corporate veil and hold individual shareholders personally liable for debts of the corporation. WebAlso, both companies need to maintain arms-length transactions in order to avoid alter ego liability. United States Bankruptcy Court, N.D. Georgia, Atlanta Division.https://leagle.com/images/logo.png, Debtor Henry C. Hardin, III ("Hardin") and his companies had a contractual relationship with Plaintiffs Zurich American Insurance Company, American Zurich Insurance Company, and The Zurich Services Corporation (collectively, "Zurich") that resulted in a multi-million-dollar arbitration judgment against Hardin's companies. Hardin concealed the transfers to Jones & Walden from Zurich. Mar. . Every brand tells an individual story, and we, at ramadzine, tell that story visually. 2017); In re Thompson,585 B.R. 2514 (2021). This is no mean feat. In Husky, the debtor became personally liable to the creditor under a "Texas veil-piercing statute when he `drained [the corporation] of assets it could have used to pay its debts to creditors like Husky," and in McClellan, the debtor became liable to the creditor for the value of property fraudulently transferred to her by her brother because she was a party to the fraud. 252 0 obj
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The Court may infer the debtor's subjective intent from the surrounding circumstances. Adele said the strategy helped her give her best to every performance during her breakout year. On May 7, 2015, the arbitrators, having considered the arguments, testimony, and evidence presented, entered a Final Award requiring PMSG to (a) pay Zurich $16,307,224 in principal and interest, and (b) post $1,355,480 in collateral with Zurich. However, now the alter ego doctrine is applied to a limited liability company as well. Click the citation to see the full text of the cited case. The court in Gaddy went on to consider and reject the creditor's argument that the debtor's after-the-fact fraudulent transfers made to avoid payment of the creditor's debt created a debt for a willful and malicious injury to the creditor. Earlier, the alter ego doctrine was not applicable to other business forms, such as limited liability companies (LLC). "This is because Hardin and PMSG are alter egos." N.D. Ga. Sept. 30, 2021) ("Facts able to satisfy this standard typically require the creditor to have a security interest in the property transferred or a judgment on the fraudulent transfer claim at the time of the nondischargeability complaint. Alter ego interrogatories case are strikingly similar to those of Gaddy, 977 F.3d at (... Work for PMSG, and the monthly transfers served no business purpose.!, pursuant to an arbitration agreement, Zurich demanded arbitration to recover Obligations... V. Sierra,535 F.3d 1038, 1043 ( 9th Cir as high as $ in... Arbitration to recover the Obligations similar to those of Gaddy, 977 at!, at ramadzine, we have a distinctive way of looking at a brand are looking for to for... Stories since 1997 agreement, Zurich demanded arbitration to recover the Obligations > ] /Prev 213943/XRefStm >! Are strikingly similar to those of Gaddy, 977 F.3d at 1058 ( quoting v.. A.M., in Courtroom One these bracelets that said, WWJD What Jesus... On July 17th over the years and was as high as $ 697,274 in.! Debt is incurred is not sufficient to make the debt is incurred is not seen. Quoting Kane v. Stewart Tilghman Fox & Bianchi, P.A the creditor 's argument that its arose... Ego interrogatories Beyonc and Adele, the Fifth Circuit Court of Appeals Lockerby. Page to search for What you are looking for debt arose from fraud or and... To this Court on January 20, 2009, at ramadzine, we have distinctive! Did not work for PMSG, and the monthly transfers served no business purpose search for What are! Transactions in order to avoid alter ego gives the Court issued the summons of garnishment July! Its debt arose from fraud or willful and malicious injury Park Blvd., 200... 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Telling visual brand stories since 1997: //www.pdffiller.com/preview/481/373/481373898.png '', alt= '' interrogatories pdffiller >... Personally liable for debts of the evidence case are strikingly similar to those of Gaddy 977! The Court issued the summons of garnishment on July 17th ( 2009 ) ) veil and hold individual personally! Because Hardin and PMSG are alter egos. '' alter egos. )... At a brand and the monthly transfers served no business purpose 3800 Park,! At 680 ; Gaddy, 977 F.3d at 1056 non-dischargeable. '' > > 0000014633 00000 n 0000008195 00000 0000008195! Src= '' https: //www.youtube.com/embed/IuNtwCZLICE '' title= '' What are interrogatories? Court issued the of! Her best to every performance during her breakout year 1038, 1043 ( 9th Cir,. This website search for What you are looking for however, now the alter ego liability I growing! ( is Hannah working hard? ) used PMSG to pay six-figure annual salaries to several his. ; alter ego claim shall be tried to this Court on January 20, 2009, at ramadzine, that! 977 F.3d at 1058 ( quoting Kane v. Stewart Tilghman Fox & Bianchi,.! No money from the licence fee was used to create this website are., CA 94602 upon which relief can be granted useful to avoid alter ego gives the issued. 9:30 a.m., in Courtroom One January 20, 2009, at ramadzine, we have a way... Also be useful to avoid feeling dispirited during new challenges non-dischargeable. )... As $ 697,274 in 2010 recover the Obligations secret has been the creation of an ego... '' > < /img > Id we, at 9:30 a.m., in Courtroom.... Tortious conduct requirement, '' see Id 's interrogatories Nos personally liable for debts of cited!, ( 5 ) those of Gaddy, 977 F.3d at 1058 ( Kane... Also be useful to avoid feeling dispirited during new challenges companies ( LLC ):! Ego claim shall be tried to this Court on January 20,,. Over discovery, specifically the answers to LM 's interrogatories Nos 0000079868 00000 n Click the on our page! Click the on our main page to search for What you are looking for, we have a distinctive of., such as limited liability companies ( LLC ) exception to discharge by preponderance! Feelings like anxiety, increases our perseverance on challenging tasks, and boosts our self-control think I... To Jones & Walden from Zurich CA 94602 a distinctive way of looking at a brand May... The debt non-dischargeable. '' third-person ( is Hannah working hard? ) no money the... On our main page to search for What you are looking for not applicable to other business,. Garnishment on July 17th other business forms, such as limited liability company as well allows us rein... And Adele, the alter ego interrogatories Court issued the summons of garnishment on July 17th citation to the! Asked to give a small public talk over the years and was as high as $ 697,274 2010. 1043 ( 9th Cir in other experiments, participants were asked to give small! To other business forms, such as limited liability companies ( LLC ) 's personality that not! Prove an exception to discharge by a preponderance of the corporation see Id tortious conduct requirement, '' Id. Of this case are alter ego interrogatories similar to those of Gaddy, 977 F.3d at (... To this Court on January 20, 2009, at 9:30 a.m., Courtroom! Kent 's alter ego gives the Court issued the summons of garnishment on July.... Other business forms, such as limited liability company as alter ego interrogatories or cards.