Editing Openai/68543586-b3fc-8004-86a9-b3760b4894b0 (section)

=== Assistant: Great, this is a very helpful and detailed snapshot of your situation. ===
Great, this is a '''very helpful and detailed snapshot''' of your situation. With that info, I can provide more '''targeted and constructive advice'''. Here's how you and the other members can proceed:

==== - The case is a '''Chapter 7 no‑asset filing''' in the Southern District of Texas: DE Marketing LLC, case '''4:25‑bk‑33305''', filed '''June 9, 2025''' txs.uscourts.gov<ref>{{cite web|title=txs.uscourts.gov|url=https://www.inforuptcy.com/browse-filings/texas-southern-bankruptcy-court/4%3A25-bk-33305/bankruptcy-case-de-marketing-llc|publisher=inforuptcy.com|access-date=2025-12-06}}</ref>. ====
* You'll need the Schedule of Assets and Liabilities (A/B), the Statement of Financial Affairs, and possibly Schedules E/F and G.
* These are accessible via PACER (court's electronic docket system) or through a clerk’s office. You'll need a PACER account and pay per page, or ask your attorney to retrieve them.

These documents are essential to check what assets or transfers DE Marketing actually disclosed under oath.

==== Look for discrepancies like: ====
* Undisclosed transfers or bulk asset sales to new entities (Clickerr, MyInboxPro, Push Platform) soon before the filing.
* Ownership of valuable assets—like the claimed 31 million‑subscriber email list—being shifted into a new LLC.
* Sudden lack of bank accounts or property in the old business.

You can search:
* Texas Secretary of State records for new LLCs linked to the same owner, especially Clickerr, MyInboxPro, Push Platform.
* UCC filings to track changes in asset pledges.
* All communications (emails, dashboard logs) showing promised payments or ownership of subscriber lists.

==== - Send a formal complaint letter to Chapter 7 Trustee Ronald J. Sommers, including: - Copies of contracts, commission agreements, emails promising payment. - Evidence of asset transfers or dashboards being wiped. - The fact that 1099s were issued but no funds were paid. ====
* Consider asking the court to authorize a Rule 2004 examination—a discovery tool allowing: - Document production from DE Marketing or its insiders. - Depositions of officers or related companies (e.g., Clickerr/Push Platform).

This requires a motion and possibly pooled resources with other affected members.

==== - Adversary Proceedings: - If you uncover fraudulent transfers (e.g., email lists moved improperly), you can challenge those under §§ 544, 548 of the Bankruptcy Code. - You can ask the court to recover transferred assets or their value. ====
* Veil-Piercing or Third-Party Liability: - If assets were moved to a new sister company controlled by the same owner, you may be able to hold him personally accountable. - This often involves showing that the new entity is just a shell that's continuing the same business operations.

==== - A group of 3,000+ creditors owed $2 million+ has significant power: - Shared counsel and pooled costs increase the chance of success. - A creditor committee (even informal) could file motions, join adversary proceedings, or fund investigative actions. ====
* The Trustee will take a much stronger interest if hundreds of creditors raise coordinated complaints.

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==== Your situation strongly suggests a fraudulent asset transfer scheme: ====
* Thousands issued 1099s but not paid.
* Subscriber list and operations revived under a new entity.
* Lack of asset disclosure in bankruptcy.

By pulling the schedules, documenting the asset shift, and using the Trustee’s investigative powers, there's a solid path to recovering assets or compelling the owner to account for where they went.

Would you like help drafting the Trustee complaint or the Rule 2004 motion? Or should I walk you through downloading and reviewing the bankruptcy schedules?