Estate’s right, title and interest in and to any and all contract rights, payments of any kind, arising from (1) any and all of Debtor’s alleged ownership interests in ATS
Estate’s right, title and interest in and to any and all contract rights, payments of any kind, arising from (1) any and all of Debtor’s alleged ownership interests in ATS (albeit disputed), including all Debtor’s ATS shares and any and all rights to distributions or other payments from ATS1; (2) Any and all of Debtor’s alleged claims against ATS and/or its principals, Michael Trunnel and David Sagherian (both individually and in all ATS corporate capacities), including, but is not limited to any and all pre-petition claims alleged (or not alleged) by the Debtor in his Bankruptcy Schedules (including amended Schedules), any and all derivative claims alleged (or not alleged) by the Debtor as a putative shareholder of ATS, and any and all other alleged claims by the Debtor and/or Estate against ATS, and/or its principals whether contingent, unliquidated or disputed; and (3) any and all of the of the Debtor’s alleged claims in his Bankruptcy Schedules (including amended Schedules) for, “Money owed to Debtor from his former partnership ATS Accounting (collectively, the “Personal Property”) as identified in the Asset Purchase Agreement dated September 15, 2021 (“APA”)
1 For purposes of disclosure, the ATS shares are subject to restrictions on transfer and other restrictions imposed by the ATS corporate agreements. Buyers are taking the ATS shares, subject to all restrictions.
Method of Sale
Offer Subject to Overbid
The Trustee proposes to sell the Personal Property to proposed buyer, ATS Accounting Group, Inc. pursuant to 11 U.S.C. §§ 363(b) and (f) for a purchase price of $25,000. The Personal Property is being sold on an “AS IS, WHERE IS” basis without any warranties, express or implied, and without any contingencies, and free and clear of all liens, claims interests, and encumbrances, with such liens, claims, interests, and encumbrances to attach to sale proceeds. Potential purchasers seeking to submit an overbid must submit offers to counsel for the Trustee and Trustee no later than two (2) days before the hearing on the Motion (October 20, 2021) via email directed to David Seror (firstname.lastname@example.org) and Tamar Terzian (email@example.com) of intent to overbid and proof of financial ability to close escrow.
The initial Overbid is: $27,000; Subsequent Overbid Increments are: $500. To qualify, Overbidders must deposit: $27,000 and provide proof of financial ability to close escrow. The deposit must be remitted to the Trustee no later than two days prior to the hearing, payment in the form of a cashier’s check only (no other form of payment shall be accepted) made payable to “David Seror, Chapter 7 Trustee”.
October 20, 2021 at 10:30 a.m. before the
Honorable Maureen A. Tighe
Tamar Terzian, Esq.
21650 Oxnard Street, Suite 500
Woodland Hills, CA 91367
Telephone: (818) 827-9000
Facsimile: (818) 827-9099
In re: TADEH AHANI AVANESSIANS
Case No.: 1:20-bk-11196-MT