10-12240-hom Doc#25 Filed 10/18/10 Entered 10/18/10 11:03:02 Main Document Pg 1 of 4 ivi Usrrm Starrs Baxxurrercourr FILED FoR THE WESTERN DISTRICT OF TEXAS AUSTIN DIVISION OCT 15 2010 i Y COURT InRe el \ Case No, 10-1240 CHAPTER LL Micuar. J. CoKeR Debtor RESPONSE OF REBECCA AND CHRISTOPHER BUFFUM. ‘To MOTION OF THE UNITED STATES TRUSTEE TO DIsMIss Cask. Or, IN THE ALTERNATIVE T CASE TO A CASE UNDER CHAPTER 7 To Conve} TO ‘THE HONORABLE UNITED STATES BANKRUPTCY JUDGE: Rebecca Buffum and Christopher Buffum, creditors holding both secured and unsecured claims against the Debtor, respectfully state: 1. The Chapter 11 Case of Michael J. Coker should be dismissed. 2. Coker has admitted, under oath, this ease and the companion case of his lover, In Re John J. Madsen, Case No. 10-12239 (dismissed on October 6, 2010) was to avoid pending litigation in Michael Coker and Jobn Madsen v. Chris Buffiam and Rebecca Buffum and sandy Creek Yacht Club, Cause No. C-1-CV-10-002345, County Court at Law Number One, Travis County, Texas (the “Buffum Case”). Coker and John Madsen were scheduled for trial on the morning they filed their respective bankruptcies and were both the subjects of Writs of Attachment compelling their arrest - Coker did not file either schedules or a statement of financial affairs until AETER the Trustee moved for dismissal of this case. REseoNse To US, THusTEe's MoTiON To Dismiss Ox CoNvERT (Case No. 10-12240-66. Pagel oft10-12240-hcm Doc#25 Filed 10/18/10 Entered 10/18/10 11:03:02 Main Document Pg 2 of 4 4. Coker has admitted, under oath, that the statement of financial affairs and schedules are false, four examples of which are: (a) At least $30,000.00 of known property was omitted from the schedules. The property is known to be Coker’s because he filed at least four sworn affidavits in the Buffum case claiming ownership of the property and that the value of the property was at least $30,000.00. In fact, Coker sued the Buffums to recover the omitted property and the property is currently, pursuant to a State Court order sitting in a storage facility. (b) Liens listed as being against automobiles were fabricated by Coker; (Coker stated he owned no interest in real estate, but admitted under oath he actually owns a royalty interest in a producing oil well, @ cer admitted under oath that he did not list a pending patent as an asset 5. Coker has claimed to own personal property of enormous value, but has refused repeated inquiries from creditors and the U.S. Trustee to specifically identify the property or to permit access to the property for the purpose of verification. 6. Coker has admitted the valuations for much of the personal property listed in his schedules was essentially “made up” and were not based on current market value. 7. Coker has claimed reorganization is possible because of the $735,000 he is owned by a company ~ Globe'Track Wireless, Inc. - he controls, which he is to be paid upon the “funding” by three different financial organizations of GlobeTrack Wireless. However, Coker has refused, under oath, to identify the funding sources. Coker has refused to produce any proof of the actual existence of the $735,000 debt~ identified as salary. 8. Coker has admitted, under oath, the income amount listed in Schedule 1 is false. 9. Coker has admitted Schedule G is false. Reseonst To US. Trustee's Maron To Disiss Ox Convent caseo. 11 2240-66) Page? ot10-12240-hom Doc#25 Filed 10/18/10 Entered 10/18/10 11:03:02 Main Document Pg 3 of 4 10. Coker has sworn that GlobeTrack Wireless, Inc. is a going concern and his stock ownership is worth at least $4,600,000.00, but in fact GlobeTrack Wireless, Inc. has no employees other than Coker and his lover Madsen and GlobeTrack Wireless has been locked out of its place of business for non-payment of rent. 11, This case is nothing more than a litigation tactic in a long and continuing pattern of abuse of both State and Federal legal systems and a massive, deliberate, criminal fraud on this Court and Coker’s creditors. Respectfully, Rebecca and Christopher Buffum request this Court dismiss the Case with prejudice to its being refilled for at least 180 days. Respectfully submitted, ‘THE STRATTON Law Fir, P. C. PUTONTI & Escover, P.C. JOHN W. Escover 2101 Lakeway Blvd.; Suite 230 Lakeway, Texas 78734 Office ‘Telephone: 512 263-0939 Office Facsimile: 512 263-0943 ee LL ‘John Robert Stratton Emai hn@Puront ox 2232 Austin, Texas 78768-2232 Office Telephone: 512 445-6262 Office Facsimile: $12 444-3726 Email: JRSi Stratton. Attorneys for Rebecca and Christopher Buy Resronse To US. THusTEE's MONON To Disiss O8 ConvERT (CaseNo. 1012040 Page ot10-12240-hem Doc#25 Filed 10/18/10 Entered 10/18/10 11:03:02 Main Document Pg 4 of 4 CERTIFICATE OF SERVICE Signature above certifies a true copy of this document was delivered to the entities on the Debtors’ Mailing Matrix on 15 October 2010 by first class, postage pre-paid United States mail. Response TOUS. TRUSTEE'S MOTION To Disuiss Ox CoNvERT ‘Case No. 10:12240.66 Paget of