| | Amended Motion to Dismiss Document Filed by Martin Seidler for Defendant Christopher Isaac Mass. (Attachments: # 1 Proposed Order) (Seidler, Martin) (related document(s): 17 Motion to Dismiss Amended Complaint Filed by Martin Seidler for Defendant Christopher Isaac Mass. (Attachments: # 1 Proposed Order proposed Order) (Seidler, Martin) (related document(s): 15 First Amended Complaint () filed by Brian C. Guequierre for Plaintiff David Ellerbe (Attachments: # 1 Exhibit Ex A Secured Promissory Note # 2 Exhibit Ex B Proposed Terms for Promissory Note # 3 Exhibit Ex C Ellerbe v Mass underlying litigation # 4 Exhibit Ex D Divorce Decree # 5 Exhibit Exhibit E Bob Miller POC and Handwritten Correspondence from Chris Mass # 6 Exhibit Ex F Mark Chimenti Deposition on Written Questions # 7 Exhibit Ex F pt2 Texts btwn Mark Chimenti and Chris Mass # 8 Exhibit Ex G Chris Mass Interrogatory Responses # 9 Exhibit Ex H Chris Mass Admissions responses # 10 Exhibit Ex I Chris Mass 140k transfer to Johnette Mass April 2020 # 11 Exhibit Ex J Undisclosed California Real Estate Fraud case vs Chris Mass # 12 Exhibit Ex K Chris Mass answer California Fraud Case # 13 Exhibit Ex L Mike Starks Deposition on Written Questions # 14 Exhibit Ex M Texas Sunrise Purchase Agreement # 15 Exhibit Ex N Texas Sunrise formation docs # 16 Exhibit Ex O Texas Sunrise payment checks) (Guequierre, Brian) (related document(s): 1 Adversary case 24-01042. Complaint (Missing Cover Sheet) filed by David Ellerbe (attorney Brian C. Guequierre) against Christopher Isaac Mass (Filing Fee: $ 350.00) (Nature(s) of Suit:(41 objection/revocation of discharge-727 (c),(d),(e). (62 (Dischargeability - 523(a)(2), false pretenses, false representation, actual fraud)),(67 (Dischargeability - 523(a)(4), fraud as fiduciary, embezzlement, larceny))). (Attachments: # 1 Exhibit Ex A Secured Promissory Note # 2 Exhibit Ex B Payment terms for promissory note # 3 Exhibit Ex C State Court Litigation # 4 Exhibit Ex D Divorce Decree & Lis Pendens # 5 Exhibit Ex E handwritten statement against interest from debtor) (Guequierre, Brian) Modified on 7/26/2024 (Benitez, Estella). Modified on 8/16/2024.)) Text Modified on 5/13/2025.)
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