Jay Tien Chiang

OCR transcription for search; preserved printed pages are authoritative

19

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

AUTHENTI
U.S. GOVER
INFORMA]

Case 2:10-bk-15473-PC Doc 33 Filed 08/31/10 Entered 09/03/10 08:40:26 Desc

Main Document

Page 1 of 8

ENTERED
SEP - 2 2010

CLERK U.S. BANKRUPTCY COURT
CENTRAL DISTRICT OF CALIFORNIA
BY: Deputy Clark

UNITED STATES BANKRUPTCY COURT
CENTRAL DISTRICT OF CALIFORNIA

In re:
JAY TIEN CHIANG,
Debtor.

ee ere Sie Minera! Ming! ieee ame tee ee et” “a So”

I], INTRODUCTION

Jay Tien Chiang (“Chiang") is the
debtor in a case pending in Toronto, Canada
under the Canadian Bankruptcy and
Insolvency Act. Mendlowitz & Associates, Inc.
(“Mendlowitz”), the trustee in the Canadian
case, brings this chapter 15' petition for
recognition of the Canadian case as the

‘ Unless otherwise indicated, all chapter,

section and rule references are to the
Bankruptcy Code, 11 US.C.A. §§ 101-1532
(2008) and to the Federal Rules of Bankruptcy
Procedure, Rules 1001-9036.

TED
ENT
N

GPO

Case No.: 2:10-bk-154735B
Chapter 15

OPINION GRANTING RECOGNITION
ON FOREIGN MAIN PROCEEDING
IN CANADA

Date: June 22, 2010

Time: 2:00 p.m.
Citrm: 1575
Floor: 715th

debtor's foreign main proceeding. Creditor
Korea Data Systems (USA) Inc. (“KDS”),
Chiang's main creditor, supports recognition of
the Canadian proceeding as a foreign main
proceeding. However, Winner International
Group Limited (“Winner”) opposes recognition
of the Canadian proceeding on the grounds of
insufficient evidence.

Winner argues that Chiang has no
center of main interests (“CoMI"} in Canada or
in any other country, and that he has no
establishment? in Canada. Thus, Winner

? An establishment, for chapter 15 purposes,
is a “place of operations where the debtor

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Case 2:10-bk-15473-PC Doc 33 Filed 08/31/10 Entered 09/03/10 08:40:26 Desc

Main Document

argues, the Canadian proceeding cannot be
recognized as either a main or a nonmain
proceeding under chapter 15.

The court holds that, for every debtor,
there is a country where the debtor's CoMI is
located, and every debtor has one (but not
more than one) CoMI. In this case, the
debtor's residence is located in Canada, and
thus he enjoys the presumption, which is
unrebutted, that his CoMI is located in
Canada.* Accordingly, the court recognizes
the Canadian proceeding as the foreign main
proceeding for the debtor.*

ll. RELEVANT FACTS

Debtor and his brother Julius Chiang
created a computer business, Amazing
Technologies Inc. ("Amazing Technologies”), a
California corporation, in the 1980’s. KDS
claims that Amazing Technologies owes it
some $10 million for computer monitors
delivered in the early 1990's. Chiang and his
brother settled that dispute in 1993 by
personally guaranteeing the payment of $8.5
million to KDS.

After non-payment of the debt for a
period of five years, KDS obtained a judgment
from the Orange County Superior Court in
1998 awarding it $9.7 million against the
Chiang brothers on their guarantees. The
court further found that the Chiang brothers
engaged in fraud and breached their fiduciary
duties when they illegally transferred funds,
securities, and real property to their family
members.

KDS obtained a second California
judgment of $5 million against the Chiangs in

carries out a non-transitory economic activity .
J.” § 1502(2).

5° For the purposes of international bankruptcy
law, it is necessary only to determine the
country where a debtors CoMI is located.
Where it may be located within a country is not
important for these purposes.

4 Just as a debtor can have only one CoM,
the debtor can also have only one main
proceeding, filed in the country where the
CoMI is located.

Page 2 of 8

1999. In 2008, the Orange County Superior
Court granted a 10-year renewal of the
judgments against the Chiang brothers, which
by then totaled $17,896,867.

Chiang filed a voluntary bankruptcy
petition in Canada on September 28, 1998.
The Canadian court subsequently found that,
while the bankruptcy case was pending,
Chiang fraudulently transferred, received, and
hid assets while living a ‘lavish lifestyle.” That
court has held Chiang in contempt on six
occasions for violating court orders. In
addition, the Ontario Court of Appeal sent
debtor to prison on the grounds that his
continuous violations were “one of the worst
cases of civil contempt to come before this
court.” Mencfowitz & Associates Inc. v.
Chiang, [2009] 0.A.C. at 9 (Can.).

In 2008, Mendlowitz discovered an
E-Trade securities account, opened in
Winner's name in 2006 in Hong Kong, with a
$2.8 million balance.® On February 20, 2009,
the Ontario Superior Court, suspecting that
Winner held the account on behalf of Chiang,

5 Debtor filed his Canadian case under the
Bankruptcy and Insolvency Act, R.S.C., ch. B
3, § 49 (1985) (Can.}. Canada has a second
bankruptcy law, the Companies’ Creditors
Arrangement Act (the “CCAA"), a 1930's
vintage statute (with periodic amendments)
that is most often used for corporate
arrangements. Companies’ Creditors
Arrangement Act., R.S.C., ch. C-36 (1985)
(Can.)} See Jacob Ziegel, Corporate Groups
and Cross-Border insolvencies:
A Canada-United States Perspective,
7 Fordham J. Corp. & Fin. L. 367, 384-86;
See also, e.g., in re Metcalfe & Mansfield
Alternative Invs., 421 B.R. 685 (Bankr.
S.D.N.Y. 2040).

® Debtor has a questionable history regarding
the disclosure of assets, and doubts were
revealed about debtor's ownership of the
E-Trade account when E-Trade account's
statements were found by a_ private
investigator in garbage left at the curb for
collection in front of debtors Canada
residence.

10

1i

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Case 2:10-bk-15473-PC Doc 33 Filed 08/31/10 Entered 09/03/10 08:40:26 Desc

Main Document

issued a Mareva order’ freezing the E-trade
account pending further determination of its
ownership. The court modified the order later
in 2009 to include expressly the E-Trade
account here at issue. That order was
reinstated by the Ontario Superior Court on
March 13, 2009 and reaffirmed on April 27,
2010.

In the meantime, KDS filed an action
against E-Trade, Winner, and Chiang in the
Los Angeles County Superior Court on
December 10, 2009 seeking a temporary
restraining order (“TRO”) as to the E-Trade
account. The Superior Court issued the TRO®
on April 15, 2009.°

” See Mareva Compania Naviera SA v.

International Buikcarriers SA, [1975] 2 Lloyd's
Rep 509. Mareva injunctions are not available
in the United States. In Grupo Mexicano de
Desarrolio v. Alliance Bond Fund, 527 U.S.
308, 327-29 (1999), the U.S. Supreme Court
stated that Mareva relief was unknown to
traditional equity practice:

[I]t is instructive that the English Court of
Chancery, from which the First
Congress borrowed in conferring
equitable powers on the federal courts,
did not provide an injunctive remedy
such as this until 1975... . [T]he
adoption of Mareva injunctions was a
dramatic departure from prior practice. .
.. [FJederal courts in this country have
traditionally applied the principle that
courts of equity will not, as a general
matter, interfere with the debtor's
disposition of his property at the
instance of a non judgment creditor. We
think it incompatible with our traditionally
cautious approach to equitable powers,
which leaves any substantial expansion
of past practice to Congress, to decree
the elimination of this — significant
protection for debtors.

® The TRO allowed Winner to sell stocks but
prohibited the purchase of stocks or taking of
money out of the E-Trade account in order to
be protected in case the market crashed.

* The Los Angeles County Superior Court
subsequently dismissed its case without

Page 3 of 8

On February 15, 2010, Mendlowitz
filed this chapter 15 petition for recognition of
the Canadian foreign proceeding pursuant to §
1515. Thereafter, Mendlowitz removed the
Superior Court action to this court.

Upon recognition, Mendlowitz, joined
by KDS, requests cooperation with the
Canadian courts and extension of the interim
relief pursuant to § 1521. Winner opposes the
motion on the grounds that the Canadian case
is not a “foreign main proceeding”. E-Trade
concedes that U.S. courts (but not Canadian
courts) have personal jurisdiction over it.

This court previously granted interim
relief pursuant to § 1519 freezing the E-Trade
account, pending recognition of the Canadian
bankruptey case as a foreign proceeding.

Ill. DISCUSSION

Chapter 15, enacted in 2005,"°
incorporates into U.S. law the Model Law on
Cross-Border Insolvency (“Model Law")"
promulgated by the United Nations
Commission on International Trade Law
(“UNCITRAL”). The purpose of the Model Law
is to coordinate international insolvency
proceedings in more than one country for the
purpose of promoting economic certainty and
efficiency in cross-border insolvency cases.

To promote harmony among national
insolvency laws, UNCITRAL recommends that
each country adopt the Model Law as part of
its domestic insolvency regime. While
allowing for necessary adjustments, the Guide
to Enactment advises that a country make
only minor changes to the Model Law in the
course of the adaption process. See SAMUEL
L. BUFFORD, UNITED STATES INTERNATIONAL

prejudice on March 12, 2010, apparently to
clear its docket after the removal of the case
to this court.

© Chapter 15 of the Bankruptcy Code was
enacted as part of the Bankruptcy Abuse
Prevention and Consumer Protection Act,
Pub. L. No. 109-8, 119 Stat. 23 (2005).

"' Section 1501; see UNCITRAL MODEL LAW
ON CROSS-BORDER INSOLVENCY WITH GUIDE TO
ENACTMENT, May 30, 1997 [hereinafter MODEL
Law & GuIDE].

10

11

12

13

14

15

16

1?

18

19

20

21

22

23

24

25

26

27

28

Case 2:10-bk-15473-PC Doc 33 Filed 08/31/10 Entered 09/03/10 08:40:26 Desc

Main Document

INSOLVENCY LAW 3 (Oxford Univ. Press 2009};
see also Guide at 12. Consequently, the
Model Law is a_ valuable, persuasive
instrument that U.S. courts use to interpret
chapter 15. See § 1508.

In complement to the Model Law, the
European Union Council has adopted its
Regulation on Insolvency Proceedings (“EIR”),
which can shed light on the meaning and
interpretation of chapter 15 terms. See
Council Regulation 1346/2000, 2000 OJ.
(L160) 1-18 (as amended). In fact, the EIR
was finalized one year before the Model Law,
and they use many common concepts.

A. Recognition of
a Foreign Proceeding

Section 1517(a)'* governs the
recognition of a foreign insolvency proceeding.
“Foreign proceeding” is defined in § 101(23),
which states in relevant part:

a “foreign proceeding” [is] a collective
judicial or administrative proceeding in
a foreign country, including an interim
proceeding, under a law relating to
insolvency . . . in which proceeding
the assets and affairs of the debtor
are subject to control or supervision
by a foreign court... .

Recognition of a foreign proceeding
under § 1517 must meet three procedural and
two substantive requirements. See in re Ran,

*? Section 1515(a) states:

{a Subject to section 1506, after
notice and aé hearing, an order
recognizing a foreign proceeding shall
be entered if—

(1) such foreign proceeding for which
recognition is sought is a foreign main
preceeding or foreign nonmain
proceeding within the meaning of
section 1502)

(2) the foreign representative
applying for recognition is a person or
body; and

(3) the petition meets the
requirements of section 1515.

Page 4 of 8

607 F.3d 1017, 1021-22 (Sth Cir. 2010). The
procedural requirements are imposed by §
1517(a)(3), which requires a petition for
recognition to meet the requirements of §
1515.

Section 1515, in turn, imposes three
pleading requirements. First, § 1515(a)
requires that the foreign representative have
filed a petition for recognition. Second,
§ 1515(b) requires the petitioner to establish
that a foreign proceeding exists, and that the
petitioner has been appointed as the foreign
representative. The first two paragraphs of
this subsection specify what constitutes
sufficient evidence, and specify that the
petitioner may satisfy this requirement by
providing a “certified copy of the decision
commencing such foreign proceeding and
appeinting the foreign representative,” “a
certificate from the foreign court affirming the
existence of the foreign proceeding and the
appointment of the foreign representative,” or
other evidence acceptable to the court that a
foreign proceeding has been filed and the
appointment of the movant as an authorized
representative thereof. Third, § 1515(c)
requires that the petition for recognition be
accompanied by a statement identifying all
foreign proceedings with respect to the debtor
that are known to the foreign representative.

Mendlowitz has satisfied all of these
procedural requirements. Thus, § 1517(a)(3)
has been satisfied. In addition, Mendlowitz
has also met the requirements of § 1517(a}(2)
because "the foreign representative applying
for recognition is a person or body[.]"

Thus, the only substantive issue
before the court is the requirement of
§ 1517(a)(1}: whether the foreign proceeding
for which recognition is sought is a foreign
main or nonmain proceeding. If the foreign
proceeding is neither a foreign main
proceeding nor a foreign nonmain proceeding
then it is simply ineligible for recognition under
chapter 15. See Ran, 607 F.3d at 1022; In re
Bear Stearns High-Grade Structured Credit
Strategies Master Fund, Lfd., 389 B.R. 3285,
334 (S.D.N.¥.2008); see also, In re SPhinx,
Ltd., 351 B.R. 103, 120 n.22
(Bankr.S.D.N.¥.2006), affd, 371 B.R. 10
(8.D.N.¥. 2007).

Recognition under § 1517 is not a
“rubber stamp exercise.” See, e.g., Ran, 607
F.3d at 1021: In re Basis Yield Alpha Fund

10

11

12

13

14

15

16

1?

18

19

20

ai

22

23

24

25

26

27

28

Case 2:10-bk-15473-PC Doc 33 Filed 08/31/10 Entered 09/03/10 08:40:26 Desc

Main Document

(Master), 381 B.R. 37, 40 (Bankr. $.D.NY.
2008). Even in the absence of an objection, a
court must undertake its own jurisdictional
analysis and grant or deny recognition under
chapter 15 as the facts of each case warrant.
See Ran, 607 F.3d at 1021; Bear Stearns
High-Grade, 389 B.R. at 335. The ultimate
burden of proof on the requirements for
recognition is on the foreign representative.
See, e.g., Ran, 607 F.3d at 1021.

B. Recognition of
the Foreign Main Proceeding

In this chapter 15 case, Mendlowitz
seeks recognition of the Canadian proceeding
as a foreign main proceeding. The recognition
of a foreign proceeding as a main proceeding
brings certain statutory benefits to the debtor.
Section 1520{a) specifies that, upon
recognition: {a) the automatic stay provisions
of §§ 364 and 362 apply with respect to a
debtors U.S. property within the territorial
jurisdiction of the United States; (b) §§ 363,
549 and 552 apply to a transfer of interest of
the debtor in U.S. property; (c) the foreign
representative may operate the debtor's
business in the United States and may
exercise the powers of a trustee pursuant to
8§ 363 (use, sale or lease of property} and
552" (postpetition effect of security interests):
and (d) § 552 applies to U.S. property of the
debtor.

In this case, Mendlowitz wants to
invoke subparagraph (a) of § 1520 to prevent
Winner from dissipating assets of the E-Trade
account until final determination of the
ownership thereof by the Canadian court.

Such protection could perhaps be
obtained under § 1521, which authorizes the
court to grant “any appropriate relief"
requested by the foreign representative after

It is not exactly clear how § 552 would apply
in this subsection. Furthermore, the reference
to § 552 is a typographical error: the legislative
history indicates that it should state that § 542
applies (requiring the turnover of property to
the estate). See H.R. REP. No. 109-31, pt. 1,
at 115 (2005), as reprinted in 2005
U.S.C.C.A.N. 88, 177.

Page 5 of 8

recognition of a foreign main proceeding.
The “any appropriate relief’ language is
extremely broad. See id. However, there
would likely be a delay before such relief could
be granted after the recognition order while,
under § 1520, the application of the automatic
stay arises immediately upon the recognition
of a foreign main proceeding.

To qualify the foreign proceeding as a
foreign main proceeding, Mendlowitz must
show that debtor's CoMI is located in Canada.
See § 1502(4), defining “foreign main
proceeding” as a foreign proceeding pending
in the country where the debtor has its CoMi.

CoMI is a term of art that is used only
in the international insolvency or bankruptcy
context. However, the term is not defined in
chapter 15 or elsewhere in U.S. bankruptcy
law. Indeed, it is also not defined in the Model
Law (from which chapter 15 derives), or the
EIR (from which the Model Law borrowed the
term).

Some guidance is provided in the
Recital 13 of the EIR, which states that, “[a]
centre of main interests should correspond to
the place where the debtor conducts the
administration of his interests on a regular
basis and is therefore ascertainable to third
parties.” MIGUEL VIRGOS & ETIENNE SCHMIDT,
REPORT ON THE CONVENTION ON INSOLVENCY
PROCEEDINGS {] 75, at 48-50 (1996), available
at http:// aei. pitt. edu/ 952/ 01/ insolvency_
report_ schmidt_ 1988. pdf (hereinafter
Virgos/Schmidt Report).’°

4 See, e.g, SAMUEL L. BUFFORD, UNITED
STATES INTERNATIONAL INSOLVENCY LAW 2008-
2009, J 1.8 (2009) (stating that, upon
recognition of a foreign nonmain proceeding,
the court may issue an order specifying that §
362, as well as many other provisions of the
U.S, bankruptcy code, applies in a chapter 15
case after the recognition of a foreign nonmain
roceeding.
° This definition originated from the unofficial
but authoritative European explanatory
Virgos/Schmidt Report, which stated that a
“centre of main interests must be interpreted
as the place where a debtor conducts the
administration of his interests on a regular
basis and is therefore ascertainable by third
parties.” fd. at 75. This report was originally
designed to be the authorized guide to the EU

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Case 2:10-bk-15473-PC Doc 33 Filed 08/31/10 Entered 09/03/10 08:40:26 Desc

Main Document

This language carries two important
consequences. First, a debtor may not have
more than one CoMI. Second, the location of
the CoMI is an objective determination based
on the viewpoint of third parties (usually
creditors).

In addition, a debtor must have a
CoMI and it must be in a specific country. The
international insolvency legal regime is based
on the assumption that every international
entity has a home or a CoMI that is located in
the country where the debtor's main
proceeding may be commenced. That country
has the greatest interest in the status of the
debtor and in the outcome of the insolvency
case. That country has also the greatest
interest in the debtor because that country
provides the legal regime that governs much
of the debtor's commercial activities in most
cases, including many matters unrelated to
insolvency law.

lf a debtor has no CoMI, as Winner
contends in this case, there is no legal regime
governing the debtor's commercial activities.
A debtor's activities could be unregulated, and
the entity could be operating outside the law.
There would be no law providing for such a
debter's incorporation or status, no law giving
sanction to its contracts and other commercial
activities, no law governing its tort liabilities, no
law providing for limited liability for its
investors, and no law providing a home court
for its insolvency problems. The international
insolvency regime firmly rejects such a
possibility.

Accordingly, in this case, Chiang must
have a CoMI in a specific country. Given this
mandate, Winner offers no alternative to
Canada as the location of Chiang’s CoMI and
does not bring sufficient evidence to the
contrary.

c. § 1516 Presumption of
Location of CoM

Notwithstanding the lack of a definition
of CoMI, § 1516 provides substantial help in
determining the CoMI. For an_ individual,

Page 6 of 8

§ 1516(c)"® presumes that the CoMI is located
in the country of the debtors “habitual
residence.” Evidence as to the location of an
individual's habitual residence is sufficient to
trigger the presumption.

“Habitual residence” is a term that is
also not defined in the bankruptcy code. We
need not address this problem in this case,
because it is not disputed that Chiang’s
habitual residence is in Richmond Hill,
Ontario, Canada. Further, at the time of the
filing of this chapter 15 case, Chiang shared
his habitual residence with his wife Christina
Chiang and two children and debtors two
children attended Upper Canada College, a
school in Toronto. The Chiang family has
strong personal ties to Canada. Chiang and
his family have traveled and have always
come back to Canada, and Chiang also has
assets in Canada. Finally, Chiang has
permanent legal status in Canada. He holds a
Canadian passport that was temporarily
confiscated by a Canadian court in order to
preserve international assets.

Section 1516 shifts the burden to the
opponent to rebut this presumption. However,
chapter 15 does not indicate the type of
evidence required for such a rebuttal. Bear
Stearns High-Grade, 389 B.R. at 325.

In the case of an individual debtor, a
party needs to use the appropriate factors and
not the factors applicable exclusively to a
corporate debtor. See Ran, 607 F.3d at 1024;
Bear Stearns High-Grade, 389 B.R. at 325. In
the present case, in order to rebut the
presumption, Winner mistakenly applies
factors pertinent to a corporate debtor
encompassing the specific characteristics of a
corporation such as the location of company
personnel, assets, books, and records. Winner
has not provided pertinent and sufficient
evidence to overcome § # 1516(c}’s
presumption of the location of the debtor's
habitual residence. In consequence, the court
finds that Winner has failed to provide
sufficient evidence that the debtor's CoMI is
not located in Canada.

Convention. While the EU Convention was
never adopted, however, it still retains
interpretative vitality so long as its origins are
properly understood.

® Section 1515(c) provides in relevant part:
“In the absence of evidence to the contrary,
the . . . habitual residence in the case of an
individual, is presumed to be the center of the
debtor's main interests.”

10

12

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Case 2:10-bk-15473-PC Doc 33 Filed 08/31/10 Entered 09/03/10 08:40:26 Desc
Main Document Page 7 of 8

In the present case, this court finds
that the Canadian proceeding is properly
recognized as debtors foreign main
proceeding. Debtors CoMI is in Canada,
where debtor maintains his habitual residence.

D. Recognition of
the Canadian Bankruptcy Case as the
Foreign Main Proceeding

Given the courts determination that
the debtor's CoMI is located in Canada, where
the foreign proceeding is pending for which
recognition is sought, the court finds that the
foreign proceeding is a foreign main
proceeding under § 1520. It follows that a
number of provisions of the U.S. bankruptcy
code apply automatically in this chapter 15
case. Most relevant in this case is that that
automatic stay provided in § 362 applies to the
debtor's property in the United States,
including the assets in the E-Trade account.

I¥. CONCLUSION

This court holds that the Canadian
proceeding is the debtor's foreign main
proceeding pursuant to § 1517({a). Debtor's
habitual residence, which presumptively
establisnes an individual debtor's CoMl, is
located in Canada, and insufficient evidence to
the contrary has been presented to rebut that
presumption.

For the foregoing reasons, this court
orders recognition of the Canadian proceeding
as debtor’s foreign main proceeding pursuant
to § 1517. Further, the court extends the
order for interim relief granted on March 23,
2010, staying the E-Trade account subject to
further order of this court. See § 1521.

The eventual determination of the
rightful owner of the E-Trade account is left to
Canadian courts to be decided in due course.

Dated: August 31, WA

WA hen § | L. Bufford
Unitett Stat nkruptcy Judge

10

11

12

13

14

15

16

17

18

193

20

ai

22

23

24

25

26

2?

28

Case 2:10-bk-15473-PC Doc 33 Filed 08/31/10 Entered 09/03/10 08:40:26 Desc
Main Document Page 8 of 8

NOTE TO USERS OF THIS FORM:
1) Attach this form to the last page of a proposed Order or Judgment. Do not file as a separate document.
2) The title of the judgment or order and all service information must be filled in by the party lodging the order.
3) Category I. below: The United States trustee and case trustee (if any) will always be in this category.
4) Category Il. below: List ONLY addresses for debtor (and attorney), movant (or attorney) and person/entity (or
attorney} who filed an opposition to the requested relief. DO NOT list an address if person/entity is listed in
category |.

NOTICE OF ENTERED ORDER AND SERVICE LIST

Notice is given by the court that a judgment or order entitled (specify) OPINION GRANTING
RECOGNITION TO FOREIGN MAIN PROCEEDING IN CANADA was entered on the date
indicated as “Entered” on the first page of this judgment or order and will be served in the manner
indicated below:

I. SERVED BY THE COURT VIA NOTICE OF ELECTRONIC FILING (“NEF") - Pursuant to controlling
General Order(s) and Local Bankruptcy Rule(s), the foregoing document was served on the following
person(s) by the court via NEF and hyperlink to the judgment or order. As of August 31, 2010, the
following person(s) are currently on the Electronic Mail Notice List for this bankruptcy case or adversary
proceeding to receive NEF transmission at the email address(es) indicated below.

Richard M. Moneymaker, Esq. rmm@moneymakerlaw.com
United States Trustee ustpregion16.la.ecf@usdoj.gov
Dare Law, Esq. dare. law@usdoj.gov

[] Service information continued on attached page
ll. SERVED BY THE COURT VIA U.S. MAIL: A copy of this notice and a true copy of this judgment or

order was sent by United States Mail, first class, postage prepaid, to the following person(s) and/or
entity(ies} at the address(es) indicated below:

Jay Tien Chiang
10 Cortina Court
ON L4B 3G8
Richmond Hill
Canada

C1 Service information continued on attached page

lt. TO BE SERVED BY THE LODGING PARTY: Within 72 hours after receipt of a copy of this
judgment or order which bears an “Entered” stamp, the party lodging the judgment or order will serve a
complete copy bearing an “Entered” stamp by U.S. Mail, overnight mail, facsimile transmission or email
and file a proof of service of the entered order on the following person(s} and/or entity(ies) at the
address(es), facsimile transmission number(s), and/or email address(es) indicated below:

LJ Service information continued on attached page

ADDITIONAL SERVICE INFORMATION (if needed):