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UNITED STATES BANKRUPTCY COURT

FOR THE DISTRICT OF MASSACHUSETTS
WESTERN DIVISION

In re:
SPECTRUM ANALYTICAL, INC.

Chapter 11
Case No.15-30404-HJB
Jointly Administered

Debtor(s)
In re
HANIBAL TECHNOLOGY, LLC

Chapter 11
Case No.15-30405-HJB

Debtor(s)

TRUSTEE'S OBJECTION TO EMERGENCY MOTION

TO CONTINUE CREDITORS' MEETINGS

NOW COMES Steven Weiss, Chapter 11 Trustee (the "Trustee"), and hereby opposes the
Emergency Motion of Dr. Hanibal Tayeh to Continue Creditors' Meeting [Docket No. 141,
referred to herein as the "Motion"]. In support thereof, the Trustee respectfully states as follows:
RESPONSES TO ALLEGATIONS IN MOTION
1. The Trustee neither admits nor denies when Tayeh became aware of a criminal
investigation.
2. The Trustee admits the allegations in 2 of the Motion regarding Tayeh's personal
counsel; however, in further response to the allegations, Tayeh's presence at the meeting of
creditors is in his capacity as a responsible officer of each of the Debtors, and counsel for the
Debtors is available.
3. The Trustee neither admits nor denies the allegations in 3 of the Motion, as they
constitute statements of law to which no response is required.
4. The Trustee denies the allegations in 4 of the Motion.

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5. The Trustee denies the allegations in 5 of the Motion, as counsel for Spectrum and
Hanibal Technology, LLC will be present.

ADDITIONAL MATTERS RELEVANT TO MOTION

6.

Although it is not stated in the Motion, late on Monday the Debtors' bankruptcy

counsel called the Trustee, stating that Tayeh had made plane reservations to travel to Saudi
Arabia, allegedly to continue to pursue business interests in that country. At approximately
10:30 today, Debtors' counsel provided a copy of Dr. Tayeh's purported travel itinerary (a oneway ticket), a copy of which is annexed hereto as Exhibit "A". The Trustee promptly notified
Debtors' counsel that the Trustee would not consent to a continuance.
7. It was only after that denial that Tayeh's personal counsel requested a continuance for
personal reasons and filed the Motion.
8. On information and belief, the Office of the United States Trustee also opposes a
continuance.
9. The Trustee states that Dr. Tayeh's testimony at the meetings of creditors is necessary
to the administration of these cases, for multiple reasons. As the Court is aware, the events that
occurred (or did not occur) in Saudi Arabia are critical elements in administration of these cases.
"Technology" was the Debtors' agent for foreign operations, including those in Saudi Arabia.
While the Trustee has obtained considerable information and assistance from Spectrum's
employees about Spectrum's operations, they were not involved in "Technology's" operations. In
addition, the Trustee's preliminary review of the Debtors' books and records reflect large
transfers from Spectrum to Technology, authorized by Dr. Tayeh, seven figure intercompany
receivables, loans by a number of entities to Technology at potentially usurious rates, and large
payments on those loans in the year before the Chapter 11 petitions were filed.

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10. In short, Dr. Tayeh's testimonyor, conversely, his decision to invoke his rights not
to testify under oathis critical to the Trustee's ability to administer these cases.
WHEREFORE, the Trustee respectfully prays:

1.

That the Motion be denied; and

2.

For such further relief as this Court deems just and proper.

Dated this 16th day of June, 2015.

Respectfully submitted,

STEVEN WEISS,
CHAPTER 11 TRUSTEE
By: _/s/ Steven Weiss ___
Steven Weiss, Esquire
BBO# 545619
sweiss@ssfpc.com
Shatz, Schwartz and Fentin, PC
1441 Main Street, Suite 1100
Springfield, MA 01103
(413) 737-1131

15\0212\Objection.Motion.Dr.Karam.1601

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EXHIBIT A
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UNITED STATES BANKRUPTCY COURT

FOR THE DISTRICT OF MASSACHUSETTS
WESTERN DIVISION
In re:
SPECTRUM ANALYTICAL, INC.

Chapter 11
Case No.: 15-30404-HJB

Debtor(s)
In re:
HANIBAL TECHNOLOGY, LLC

Chapter 11
Case No.: 15-30405-HJB

Debtor(s)
CERTIFICATE OF SERVICE
I, Steven Weiss, of Shatz Schwartz and Fentin, P.C., do hereby certify that on June 16, 2015, a
copy of the foregoing Objection was mailed via electronic and/or first-class mail, postage pre-paid, to the
following:Spectrum
Analytical, Inc.
830 Silver Street
Agawam, MA 01001
Hannibal Technology, LLC
830 Silver Street
Agawam, MA 01001
Michael B. Katz
Kevin V. Maltby
Spencer A. Stone
Bacon Wilson, P.C.
33 State St.
Springfield, MA 01103
Richard King
Stephen E. Meunier
Office of the US Trustee
446 Main St., 14th Floor
Worcester, MA 01608
W. Mark Russo
Ferrucci Russo, P.C.
55 Pine St., 4th Floor

Providence, RI 02903
Bank Rhode Island
Joseph M. DiOrio
Gardner H. Palmer, Jr.
DiOrio Law Office
144 Westminster Street, Suite 302
Providence, RI 02903
John A. Dorsey, Esq.
Ferrucci Russo, P.C.
55 Pine St., 4th Floor
Providence, RI 02903
Honor S. Heath, Esq.
EverSource Energy Legal Dept.
107 Selden St.
Berlin, CT 06037
Michael A. Kelly, Esq.
Kelly & Mancini, P.C.
128 Dorrance Street, Suite 300
Providence, RI 02903
/S/ Steven Weiss
Steven Weiss, Esquire