Bankruptcy Fraud Complaint Filed 3-29-2012

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JEREMY W. FAITH (State Bar No. 190647)MEGHANN TRIPLETT (State Bar No. 268005) GOODMAN FAITH, LLP 21550 Oxnard Street, Suite 830 Woodland Hills, California 91367 Telephone: (818) 887-2500 Facsimile: (818) 887-2501 E-mail: [email protected] E-mail: [email protected] Attorneys for Elissa D. Miller, Chapter 7 Trustee

UNITED STATES BANKRUPTCY COURT CENTRAL DISTRICT OF CALIFORNIA

LOS ANGELES DIVISION

In re COMPUTER CZECH, LLC,

Debtor.

Case No.: 2:11-bk-37453-BR

Chapter 7

ELISSA D. MILLER, CHAPTER 7 TRUSTEE,

Plaintiff,v. ABACUS IT, INC., a California Corporation and JIRKA AMBROZ, an individual, Defendants.

Adv. No ________________ COMPLAINT FOR: (1) AVOIDANCE OF INTENTIONAL FRAUDULENT TRANSFER AND RECOVERY OF SAME [11 U.S.C. §§ 544, 548, 550; CAL. CIV. CODE §§ 3439.04; 3439.07]; (2) AVOIDENCE OF CONSTRUCTIVE FRAUDULENT TRANSFER AND RECOVERY OF SAME [11 U.S.C. §§ 544, 548, 550; CAL. CIV. CODE §§ 3439.04; 3439.07]; (3) CONVERSION; (4) UNJUST ENRICHMENT; (5) ALTER EGO (6) INJUNCTIVE RELIEF; AND (7)TURNOVER OF PROPERTY OF THE ESTATE [11 U.S.C. § 542];

Case 2:11-bk-37453-BR Doc 19 Filed 03/29/12 Entered 03/29/12 15:54:30 Desc Main Document Page 1 of 14

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TO THE HONORABLE BARRY RUSSEL, UNITED STATES BANKRUTPCY JUDGE:

Elissa D. Miller (“Trustee” or “Plaintiff”), solely in her capacity as the duly appointed and

acting Chapter 7 trustee for the bankruptcy estate of Computer Czech, LLC (“Debtor”),

respectfully complains and alleges as follows:

I. JURISDICTION AND VENUE

1. This Court has jurisdiction over this adversary proceeding pursuant to 28 U.S.C.

§§ 151, 157 and 1334 as this is a core proceeding under 28 U.S.C. § 157(b)(2)(A), (H) and (O)

and to the extent any related claims are determined not to be a core proceeding, the Plaintiff

consents to an entry of final judgment and orders by the Bankruptcy Court. Venue is proper in

this District under 28 U.S.C. § 1409(a), as this adversary proceeding arises under title 11 or arises

in or relates to a case under title 11 which is pending in this District in that this proceeding arises

in and is related to the Debtor’s bankruptcy case, which was commenced through the filing of a

voluntary petition for relief under Chapter 7 of the Bankruptcy Code on June 25, 2011 (the

“Petition Date”) pending in the Central District of California, Los Angeles Division as In re

Computer Czech, LLC, Case No. . 2:10-bk-37453-BR.

2. This is an adversary proceeding filed pursuant to the Federal Rule of Bankruptcy

Procedure 7001(1) (a proceeding to recover money or property).

3. Plaintiff, as Trustee, has standing to bring this action under 11 U.S.C. §§ 323, 542,

544, 548, and 550.

4. To the extent that the Plaintiff asserts claims under 11 U.S.C. § 544, the Plaintiff is

informed and believes and based thereon alleges that there exists in this case one or more

creditors holding unsecured claims allowable under 11 U.S.C. § 502 or are not allowable under

11 U.S.C. § 502(e), who can avoid the respective transfers as set forth below under California or

other applicable law.

II. PARTIES

5. Plaintiff is the duly appointed, qualified and acting Chapter 7 Trustee for the

Debtor’s bankruptcy estate (“Estate”), and brings the claims asserted herein in that capacity.

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6. Plaintiff is informed and believes that Defendant Abacus, IT, Inc. (“Abacus”) is a

California Corporation with its principal place of business in Los Angeles California.

7. Plaintiff is informed and believes that Defendant Jirka Ambroz (“Ambroz”) is an

individual residing in Los Angeles County, California. Plaintiff is informed and believes and

alleges thereon that Ambroz is the president, CEO and majority shareholder of Computer Czech,

Inc., is and was at all relevant times herein an insider, as that term is defined by Section 101(31)

of the Bankruptcy Code (an “Insider”), of the Debtor.

8. At all times mentioned herein, a unity of interest and ownership existed between

the Debtor and Abacus and Ambroz, such that the separateness of these Defendants from the

Debtor never existed. Plaintiff is further informed and believes and based thereon alleges that the

Debtor failed to adhere to corporate formalities and that its corporate form should be ignored.

9. Adherence to the fiction of the separate existence of the individually named

defendant Ambroz as entities distinct from the Debtor and Abacus would permit an abuse of the

corporate privilege and would sanction fraud and promote injustice.

III. GENERAL ALLEGATIONS

10. Plaintiff is informed and believes that Ambroz formed Abacus on May 12, 2011,

approximately one month prior to the Petition Date.

11. Plaintiff is informed and believes that Abacus and Ambroz has taken over the

Debtor’s operations and its assets without purchasing them from the Estate (the “Transfer”).

These assets include the Debtor’s telephone numbers, business location, the Debtor’s contracts,

the Debtor’s customer list and contacts, the Debtor’s software, inventory, intellectual properties

(including, but not limited to concepts, trademarks and trade names), and equipment.

12. Plaintiff is informed and believes that on May 17, 2011, Ambroz sent an email to

the Debtor’s entire customer list announcing that “[he] along with all of the best Computer Czech

technicians, will be technicians and employees of Abacus IT, Inc. Computer Czech LLC has

formally closed. . .” and further, that “Abacus IT ha[s] acquired the same phone numbers used by

Computer Czech and [Ambroz’s] personal cell remains the same to assist you with all your

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computer needs.” Attached hereto as Exhibit 1 is a true and correct copy of the email

announcement from Computer Czech LLC.

13. Abacus is answering the Debtor’s telephone number as “Abacus IT” and by all

accounts is carrying on business as if it were the Debtor.

14. Based on a preliminary analysis, the Debtor’s assets include but are not limited to:

(1) goodwill for the client list and a profitable operating business, (2) the Debtor’s entire business

infrastructure; (3) accounts receivable, and (4) cash in the Debtor’s bank accounts; and (5)

inventory.

FIRST CLAIM FOR RELIEF

Avoidance and Recovery of Intentional Fraudulent Transfers as to All Defendants

[11 U.S.C. §§ 544, 548, 550; Cal. Civ. Code §§ 3439.04, 3439.07]

15. Plaintiff hereby realleges and incorporates by reference the allegations set forth in

Paragraphs 1 through 14 as though set forth in full.

16. The Transfer alleged in paragraph 14 is of the Debtor’s property. Plaintiff

specifically reserves the right to amend this Complaint to allege additional transfers which may

become known after further investigation and discovery.

17. Plaintiff is informed and believes and based thereon alleges that the Transfer

occurred on or after May 12, 2011, within two (2) years before the Petition Date.

18. Plaintiff is informed and believes and based thereon alleges that the Transfer was

made:

(a) with actual intent to hinder, delay, or defraud the Debtor’s creditors;

(b) for no consideration or for less than reasonably equivalent value; and

(c) at a time when the Debtor was insolvent and/or rendered insolvent as a

result of the Transfer.


for the benefit of an insider of the Debtor.

20. Plaintiff is informed and believes and based thereon alleges that the Defendants

retained possession or control of the Transfer.


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of substantially all of the Debtor’s assets.

22. Plaintiff is informed and believes and based therein alleges that the Debtor became

insolvent shortly after the Transfer was made or concurrent therewith.

23. Based on the foregoing, Plaintiff may avoid the Transfer and recover the

equivalent value for the Estate from the Defendants for whose benefit the Transfer was made

pursuant to 11U.S.C. §§ 544, 548 and 550, and California Civil Code §§ 3439.04 and 3439.07.

SECOND CLAIM FOR RELIEF

Avoidance of Constructive Fraudulent Transfers Against All Defendants

[11 U.S.C. §§ 544, 548, 550; Cal. Civ. Code §§ 3439.04, 3439.05, 3439.07]



25. Plaintiff is informed and believes and based thereon alleges that there are present

creditors of the Debtor which were listed at the time of the Transfer that still remain unpaid as of

the Petition Date. Plaintiff is informed and believes and based thereon alleges that future

creditors of the Debtor existed following the Transfer who remain unpaid as of the Petition Date.


made within two (2) years before the Petition Date.


made:

(a) for less than reasonably equivalent value or any value, in exchange for said

Transfer;

(b) while the Debtor intended to incur or believed or reasonably should have

believed the Debtor would incur debts beyond the Debtor’s ability to pay them as they

became due; and/or

(c) at a time when the Debtor was insolvent and/or was rendered insolvent

and/or rendered insolvent as a result of the Transfer.

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28. Based on the foregoing, Plaintiff may avoid the Transfer and recover the

equivalent value for the Estate from the Defendants for whose benefit the Transfer was made

pursuant to 11U.S.C. §§ 544, 548 and 550, and California Civil Code §§ 3439.04 and 3439.07.

THIRD CLAIM FOR RELIEF

Conversion Against All Defendants

[Cal. Civ. Code § 1033]



30. At all time herein mentioned, the Debtor was, and still is, entitled to possession of

the following personal property: accounts receivable, telephone number, customer list, cash,

inventory and equipment transferred to Defendants.

31. Plaintiff is informed and believes and based thereon alleges that, Defendants, by

falsely and fraudulently transferring the accounts receivable, telephone number, customer list,

cash, inventory and equipment of the Debtor to Defendants, misappropriated and converted to

their own personal use and possession, property of the Estate.

32. On or about May 2011, the above-mentioned property had a value in an amount to

be determined at trial.

33. As a direct and proximate result of the acts of Defendants as herein alleged, the

Estate was damaged, thereby depriving the Estate of assets which could be liquidated for the

benefit of creditors.

34. The aforementioned acts of Defendants were willful, wanton, malicious, and

oppressive. Defendants’ conduct was done with the intent to deprive the Estate of property which

could be used to benefit creditors; such conduct justifies the awarding of exemplary and punitive

damages in an amount to be determined at trial.

FOURTH CLAIM FOR RELIEF

Unjust Enrichment as to All Defendants




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36. Plaintiff is informed and believes and based thereon alleges that the assets subject

to the Transfer generate substantial revenues for Defendants; all of which, but for the Transfer

would have flowed to the Debtor.

37. The Transfer (including any other transfers from the Debtor to the Defendants

discovered after the date of this Complaint) is recoverable from the Defendants pursuant to 11

U.S.C. § 550 to the extent such Transfer is avoided.

FIFTH CLAIM FOR RELIEF

Alter Ego Against Defendant Jirka Ambroz


paragraphs 1 through 36 as though set forth in full.

39. Plaintiff is informed and believes and based thereon alleges that Ambroz was the

alter ego of the Debtor.

40. Plaintiff is informed and believes and based thereupon alleges that Ambroz ran the

financial and business operations of the Debtor without regard to the requirements of applicable

law, and purported to deal with its capital, equity, assets, business, trade name and property

contrary to the requirements of applicable law in California, including the California Corporations

Code. Further, that this was done as part of a plan or scheme to run the Debtor for the personal

and corporate benefit of Ambroz. Further, that the Debtor was adversely dominated and

controlled by Ambroz for his own benefit and not that of the Debtor, and as part of intentional

breaches of fiduciary duty and actual fiduciary conflicts of interest, proximately resulting in the

damages to the Debtor and its Estate as set forth above.

41. Plaintiff is informed and believes and based thereon alleges that the Debtor was

further deprived of independent legal advice at all stages of its existence, and was unable to

effectively defend itself from breaches of duty, conversion, waste, and fraud perpetrated on it by

Ambroz, at all times in issue.

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SIXTH CLAIM FOR RELIEF

Injunctive Relief Against All Defendants

[18 U.S.C. § 1964(a)]



43. Plaintiff is informed and believes and based thereon alleges that the Defendants

have conspired to transfer and/or conceal assets of the Debtor and have no rightful interest in the

Debtors’ property.

44. As such, Plaintiff request, an interim, interlocutory and permanent injunction

restraining Abacus and Ambroz from disposing of their assets and business records, pending trial,

including an order freezing any bank or financial accounts of the Defendants and preserving their

business records, other than in the ordinary course of business or as ordered and approved by the

Court.

SEVENTH CLAIM FOR RELIEF

Turnover of Property of the Estate

[11 U.S.C. § 542]



46. Defendants are in possession of property of the Estate, namely the Debtor’s

customer list, telephone number, accounts receivable, and other assets.

47. Pursuant to 11 U.S.C. § 542, Plaintiff, as Trustee, is entitled to turnover of this

property which is currently being used by Abacus.

WHEREFORE, Plaintiff prays for Judgment against Defendant as follows:

1. For avoidance of the Transfer under 11 U.S.C. §§ 544, 548 and/or Cal. Civ. Code

§§ 3439.04, 3439.05, 3439.07, 3439.09, and for an order recovering the Transfer under 11 U.S.C.

§ 550 for the benefit of the Estate or the value of said Transfer for the benefit of the Estate;

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2. For a return of the Debtor’s client list, intellectual property, telephone number,

accounts receivable, inventory and other property of the Estate or payment of the value of such

property to Plaintiff;

3. For entry of a Judgment against the Defendants for the value of the Transfer,

together with interest thereon at the legal rate from the date of each of the Transfers;

4. For an award of attorney’s fees along with costs of suit incurred herein;

5. For equitable relief against Defendants in the form of such injunctive, and related

relief as might be appropriate in accordance with 18 U.S.C. § 1964(a), including an interim,

interlocutory and permanent injunction restraining the Defendants from disposing of the assets of

the Debtor, as approved by this Court, pending trial; and

6. For such other and further relief as the Court may deem just and proper under the

circumstances of this case.

RESERVATION OF RIGHTS

Plaintiff reserves all of her rights to amend this Complaint as she deems necessary and

appropriate, including, without limitation, adding any additional allegations, claims for relief, or

prayer for relief.

DATED: March 29, 2012 GOODMAN FAITH, LLP

By: _ /s/ Meghann Triplett_________

Jeremy W. Faith Meghann Triplett

Attorneys for Elissa Miller, Chapter 7 Trustee


Omar Cooley <[email protected]>

Announcement from Computer Czech LLC

Computer Czech LLC <[email protected]> Tue, May 17, 2011 at 5:37 PM

Reply-To: Computer Czech LLC <[email protected]>

To: [email protected]

"In the world of technology..... the only constant is change."

Dear Valued Clients:

I am pleased to announce that effective immediately, I, Jirka Ambroz, along with all of the best Computer Czech

technicians, will be technicians and employees of Abacus IT, Inc. Computer Czech LLC has formally closed. (I know

many of you will be glad because of mispronounciations or the misspellings of Computer Czech :)

Abacus IT, Inc. will provide first rate computer technical support, personal service at your convenience, all at a fair

price. Abacus IT, Inc will be better equipped to handle the support and repair of current and future technologies,

many of which have not even been introduced to the market place.

The location of Abacus IT, Inc. is at 9052 Santa Monica Blvd, West Hollywood, CA 90069 for your

convenience. Abacus IT have acquired the same phone numbers used by Computer Czech and my personal cell

phone remains the same to assist you with all your computer needs. Abacus will also have a larger focus on

computer repair, network installation and related technology sales and services.

I look forward to our next meeting and servicing all your computer needs.

Jirka Ambroz

Abacus IT, Inc.

9052 Santa Monica Blvd.

West Hollywood, CA 90069

Office: 310-271-9771

Cell: 213-926-9312

Unsubscribe me from this list.

Gmail - Announcement from Computer Czech LLC https://mail.google.com/mail/?ui=2&ik=5df85b0479&view=pt&cat=Schw...

1 of 1 6/9/2011 1:23 PM

Exhibit 1 10


FORM B104 (08/07) 2007 USBC, Central District of California

ADVERSARY PROCEEDING COVER SHEET(Instructions on Page 2)

ADVERSARY PROCEEDING NUMBER(Court Use Only)

PLAINTIFFS DEFENDANTS

ATTORNEYS (Firm Name, Address, and Telephone No.) ATTORNEYS (If Known)

PARTY (Check One Box Only)

G Debtor G U.S. Trustee/Bankruptcy Admin

G Creditor G Other

G Trustee

PARTY (Check One Box Only)

G Debtor G U.S. Trustee/Bankruptcy Admin

G Creditor G Other

G Trustee

CAUSE OF ACTION (WRITE A BRIEF STATEMENT OF CAUSE OF ACTION, INCLUDING ALL U.S. STATUTES INVOLVED)

NATURE OF SUIT(Number up to five (5) boxes starting with lead cause of action as 1, first alternative cause as 2, second alternative cause as 3, etc.)

FRBP 7001(1) – Recovery of Money/Property

G 11-Recovery of money/property - §542 turnover of property

G 12-Recovery of money/property - §547 preference

G 13-Recovery of money/property - §548 fraudulent transfer

G 14-Recovery of money/property - other

FRBP 7001(2) – Validity, Priority or Extent of Lien

G 21-Validity, priority or extent of lien or other interest in property

FRBP 7001(3) – Approval of Sale of Property

G 31-Approval of sale of property of estate and of a co-owner - §363(h)

FRBP 7001(4) – Objection/Revocation of Discharge

G 41-Objection / revocation of discharge - §727(c),(d),(e)

FRBP 7001(5) – Revocation of ConfirmationG 51-Revocation of confirmation

FRBP 7001(6) – Dischargeability

G 66-Dischargeability - §523(a)(1),(14),(14A) priority tax claims

G 62-Dischargeability - §523(a)(2), false pretenses, false

representation, actual fraud

G 67-Dischargeability - §523(a)(4), fraud as fiduciary, embezzlement,

larceny

(continued next column)

FRBP 7001(6) – Dischargeability (continued)G 61-Dischargeability - §523(a)(5), domestic support

G 68-Dischargeability - §523(a)(6), willful and malicious injury

G 63-Dischargeability - §523(a)(8), student loan

G 64-Dischargeability - §523(a)(15), divorce or separation obligation

(other than domestic support)

G 65-Dischargeability - other

FRBP 7001(7) – Injunctive ReliefG 71-Injunctive relief – imposition of stay

G 72-Injunctive relief – other

FRBP 7001(8) Subordination of Claim or InterestG 81-Subordination of claim or interest

FRBP 7001(9) Declaratory JudgmentG 91-Declaratory judgment

FRBP 7001(10) Determination of Removed ActionG 01-Determination of removed claim or cause

OtherG SS-SIPA Case – 15 U.S.C. §§78aaa et.seq.G 02-Other (e.g. other actions that would have been brought in state

court if unrelated to bankruptcy case)

G Check if this case involves a substantive issue of state law G Check if this is asserted to be a class action under FRCP 23

G Check if a jury trial is demanded in complaint Demand $

Other Relief Sought

Elissa D. Miller, Chapter 7 Trustee ABACUS IT, INC., a California Corporation andJIRKA AMBROZ, an individual

Goodman Faith, LLP21550 Oxnard St. Ste 830, Woodland Hills, CA 91367Phone: (818) 887-2500

✔

✔

(1) AVOIDANCE OF INTENTIONAL FRAUDULENT TRANSFER AND RECOVERY OF SAME - 11 U.S.C. §§ 544, 548, 550; (2)AVOIDENCE OF CONSTRUCTIVE FRAUDULENT TRANSFER AND RECOVERY OF SAME - 11 U.S.C. §§ 544, 548, 550; (3)INJUNCTIVE RELIEF; AND (4) TURNOVER OF PROPERTY OF THE ESTATE - 11 U.S.C. § 542

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FORM B104 (08/07), page 2 2007 USBC, Central District of California

BANKRUPTCY CASE IN WHICH THIS ADVERSARY PROCEEDING ARISESNAME OF DEBTOR BANKRUPTCY CASE NO.

DISTRICT IN WHICH CASE IS PENDING DIVISIONAL OFFICE NAME OF JUDGE

RELATED ADVERSARY PROCEEDING (IF ANY)

PLAINTIFF DEFENDANT ADVERSARY PROCEEDING NO.

DISTRICT IN WHICH ADVERSARY IS PENDING DIVISIONAL OFFICE NAME OF JUDGE

SIGNATURE OF ATTORNEY (OR PLAINTIFF)

DATE PRINT NAME OF ATTORNEY (OR PLAINTIFF)

INSTRUCTIONS

The filing of a bankruptcy case creates an "estate" under the jurisdiction of the bankruptcy court which consists of all ofthe property of the debtor, wherever that property is located. Because the bankruptcy estate is so extensive and the jurisdictionof the court so broad, there may be lawsuits over the property or property rights of the estate. There also may be lawsuitsconcerning the debtor’s discharge. If such a lawsuit is filed in a bankruptcy court, it is called an adversary proceeding.

A party filing an adversary proceeding must also must complete and file Form 104, the Adversary Proceeding Cover Sheet,unless the party files the adversary proceeding electronically through the court’s Case Management/Electronic Case Filingsystem (CM/ECF). (CM/ECF captures the information on Form 104 as part of the filing process.) When completed, the coversheet summarizes basic information on the adversary proceeding. The clerk of court needs the information to process theadversary proceeding and prepare required statistical reports on court activity.

The cover sheet and the information contained on it do not replace or supplement the filing and service of pleadings orother papers as required by law, the Bankruptcy Rules, or the local rules of court. The cover sheet, which is largely self-explanatory, must be completed by the plaintiff’s attorney (or by the plaintiff if the plaintiff is not represented by an attorney).A separate cover sheet must be submitted to the clerk for each complaint filed.

Plaintiffs and Defendents. Give the names of the plaintiffs and defendants exactly as they appear on the complaint.

Attorneys. Give the names and addresses of the attorneys, if known.

Party. Check the most appropriate box in the first column for the plaintiffs and the second column for the defendants.

Demand. Enter the dollar amount being demanded in the complaint.

Signature. This cover sheet must be signed by the attorney of record in the box on the second page of the form. If the plaintiffis represented by a law firm, a member of the firm must sign. If the plaintiff is pro se, that is, not presented by an attorney, theplaintiff must sign.

/s/ MEGHANN TRIPLETT

COMPUTER CZECH, LLC 2:10-bk-37453-B

CENTRAL DISTRICT OF CALFORNIA LOS ANGELES BARRY RUSSEL

3/29/12 Meghann Triplett


This form is mandatory. It has been approved for use by the United States Bankruptcy Court for the Central District of California.

February 2010 (COA-SA) F 7004-1

Attorney or Party Name, Address, Telephone & FAX Numbers, and California State Bar Number FOR COURT USE ONLY

Attorney for Plaintiff

UNITED STATES BANKRUPTCY COURTCENTRAL DISTRICT OF CALIFORNIA

In re: CHAPTER ______

CASE NUMBER

Debtor. ADVERSARY NUMBER

Plaintiff(s),(The Boxes and Blank Lines below are for the Court’s

Use Only) (Do Not Fill Them In)

vs. SUMMONS AND NOTICE OF

Defendant(s).STATUS CONFERENCE

TO THE DEFENDANT: A Complaint has been filed by the Plaintiff against you. If you wish to defend yourself, you must filewith the Court a written pleading, in duplicate, in response to the Complaint. You must also send a copy of your writtenresponse to the party shown in the upper left-hand corner of this page. Unless you have filed in duplicate and served aresponsive pleading by ____________________________, the Court may enter a judgment by default against you for the reliefdemanded in the Complaint.

A Status Conference on the proceeding commenced by the Complaint has been set for:

Hearing Date: Time: Courtroom: Floor:

255 East Temple Street, Los Angeles 411 West Fourth Street, Santa Ana

21041 Burbank Boulevard, Woodland Hills 1415 State Street, Santa Barbara

3420 Twelfth Street, Riverside

PLEASE TAKE NOTICE that if the trial of the proceeding is anticipated to take less than two (2) hours, the parties may stipulateto conduct the trial of the case on the date specified, instead of holding a Status Conference. Such a stipulation must belodged with the Court at least two (2) Court days before the date set forth above and is subject to Court approval. The Courtmay continue the trial to another date if necessary to accommodate the anticipated length of the trial.

KATHLEEN J. CAMPBELLDate of Issuance: ___________________________ Clerk of Court

By: ____________________________________ Deputy Clerk

JEREMY W. FAITH (State Bar No. 190647)MEGHANN TRIPLETT (State Bar No. 268005)GOODMAN FAITH, LLP21550 Oxnard Street, Suite 830Woodland Hills, California 91367Telephone: (818) 887-2500Facsimile: (818) 887-2501

ELISSA D. MILLER, CHAPTER 7 TRUSTEE

COMPUTER CZECH, LLC

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2:10-bk-37453-BR

ELISSA D. MILLER, CHAPTER 7 TRUSTEE

ABACUS IT, INC., a Ca. Corp. and JIRKA AMBROZ, an Individual


Summons and Notice of Status Conference - Page 2 F 7004-1In re (SHORT TITLE)

Debtor(s).

CASE NO.:

This form is mandatory. It has been approved for use by the United States Bankruptcy Court for the Central District of California.

February 2010 (COA-SA) F 7004-1

NOTE: When using this form to indicate service of a proposed order, DO NOT list any person or entity in Category I.Proposed orders do not generate an NEF because only orders that have been entered are placed on a CM/ECF docket.

PROOF OF SERVICE OF DOCUMENTI am over the age of 18 and not a party to this bankruptcy case or adversary proceeding. My business address is:

A true and correct copy of the foregoing document described as will be served or was served (a) on the judgein chambers in the form and manner required by LBR 5005-2(d), and (b) in the manner indicated below:

I. TO BE SERVED BY THE COURT VIA NOTICE OF ELECTRONIC FILING (“NEF”) - Pursuant to controlling GeneralOrder(s) and Local Bankruptcy Rule(s) (“LBR”), the foregoing document will be served by the court via NEF and hyperlink tothe document. On ________________________ I checked the CM/ECF docket for this bankruptcy case or adversaryproceeding and determined that the following person(s) are on the Electronic Mail Notice List to receive NEF transmission atthe email addressed indicated below:

G Service information continued on attached page

II. SERVED BY U.S. MAIL OR OVERNIGHT MAIL (indicate method for each person or entity served):On _________________________ I served the following person(s) and/or entity(ies) at the last known address(es) in thisbankruptcy case or adversary proceeding by placing a true and correct copy thereof in a sealed envelope in the United StatesMail, first class, postage prepaid, and/or with an overnight mail service addressed as follow. Listing the judge here constitutesa declaration that mailing to the judge will be completed no later than 24 hours after the document is filed.


III. SERVED BY PERSONAL DELIVERY, FACSIMILE TRANSMISSION OR EMAIL (indicate method for each person or entityserved): Pursuant to F.R.Civ.P. 5 and/or controlling LBR, on _______________________ I served the following person(s)and/or entity(ies) by personal delivery, or (for those who consented in writing to such service method) by facsimile transmissionand/or email as follows. Listing the judge here constitutes a declaration that mailing to the judge will be completed no laterthan 24 hours after the document is filed.


I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct.

_________________________________________________________ _____________________________________Date Type Name Signature

COMPUTER CZECH, LLC

2:10-bk-37453-BR


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Bankruptcy Fraud Complaint Filed 3-29-2012

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