Bankruptcy Case 15-34752 Petition

Case 19-03434 Document 1 Filed in TXSB on 04/10/19 Page 1 of 40
IN THE UNITED STATES BANKRUPTCY COURT

FOR THE SOUTHERN DISTRICT OF TEXAS
HOUSTON DIVISION
IN RE: §
§
SYED RIZWAN MOHIUDDIN, § Case No. 15-34752
§ (Chapter 7)
Debtor. §
§
RANDY WILLIAMS, §
CHAPTER 7 TRUSTEE, §
§
Plaintiff, §
§
vs. §
§ Adversary No.
SYED RIZWAN MOHIUDDIN a/k/a § _____________________
RIZWAN a/k/a SYED RIZWAN a/k/a §
RAY a/k/a RAY MOHIUDDIN a/k/a SYED §
MOHIUDDIN, SYED GHOUSE §
MOHIUDDIN a/k/a SYED GHOUSE a/k/a §
GHOUSE, MONA LISA MOHIUDDIN, §
MARIYA MOHIUDDIN, SYED AMAAN §
MOHIUDDIN, S. A. M., A MINOR §
CHILD BY AND THROUGH HIS NEXT §
FRIEND SYED RIZWAN MOHIUDDIN, §
JENNIFER RIZVI a/k/a JENNIFER §
SYDENHAM, RAHEEL KHAN, MARZIA §
KHAN a/k/a MARZIA KAMAL, §
MAHVISH KHAN, AJAY GADDAPATI §
a/k/a AJAY GADDIPATI, §
RAVISHANKER MALLAPURAM, TECH §
BRIX CONSULTING SERVICES, INC., §
KULDIP SINGH a/k/a/ KD SINGH, §
JIMIN WANG, NATHAN J. MAYS, SRM §
MOLECULAR, INC., SRM PETROLEUM §
PRODUCTS, INC. D/B/A INDEPENDENT §
TITLE SERVICE, SRM TERMINAL, §
LLC, MMAF, LLC, MMAF §
INVESTMENT HOLDINGS, INC. a/k/a §
MMAF HOLDINGS, INC. a/k/a M.M.A.F. §
HOLDINGS, INC., MMAF & JIMIN §
INVESTMENT, LLC, LE JARDIN §
EVENTS a/k/a MONA LISA EVENTS §
AND BANQUET, LLC, SELINSKY §
PLAINTIFF’S VERIFIED ORIGINAL COMPLAINT AND Page 1 of 40
EMERGENCY APPLICATION FOR TEMPORARY RESTRAINING ORDER
AND PRELIMINARY INJUNCTION
PALMS APARTMENTS, LLC, §

DOCTORS HOSPITAL 1997, L.P. d/b/a §
UNITED MEMORIAL MEDICAL §
CENTER, 510 WEST TIDWELL, LLC, §
TIDWELL/PARKWAY VENTURES, §
LLC, TIDWELL/PARKWAY PROPERTY §
HOLDINGS, LP d/b/a FOUR STAR §
CAPITAL, LAEEQ HEALTH SYSTEMS, §
LLC, LAEEQ MOB, LP d/b/a MMJA §
VENTURES, LAEEQ MOB §
MANAGEMENT, LLC, LAEEQ 511 §
INTERESTS, LLC a/k/a 511 §
INVESTMENTS, TIDWELL MOB §
MANAGEMENT, LLC, TIDWELL MOB, §
LP, 5921 INTERESTS, LTD, DG §
REALTY, LLC, and BREAKTIME §
STORES 30, LLC, §
Defendants.
PLAINTIFF’S VERIFIED ORIGINAL COMPLAINT AND EMERGENCY

APPLICATION FOR TEMPORARY RESTRAINING ORDER
THE EMERGENCY APPLICATION FOR TEMPORARY RESTRAINING ORDER

AND PRELIMINARY INJUNCTION CONTAINED IN THE COMPLAINT
(“APPLICATION”) SEEKS ENTRY OF AN ORDER THAT MAY ADVERSELY
AFFECT YOU. IF YOU OPPOSE THE MOTION, YOU SHOULD IMMEDIATELY
CONTACT THE MOVING PARTY TO RESOLVE THE DISPUTE. IF YOU AND THE
MOVING PARTY CANNOT AGREE, YOU MUST FILE A RESPONSE AND SEND A
COPY TO THE MOVING PARTY. YOUR RESPONSE MUST STATE WHY THE
MOTION SHOULD NOT BE GRANTED. IF YOU DO NOT FILE A TIMELY
RESPONSE, THE RELIEF MAY BE GRANTED WITHOUT FURTHER NOTICE TO
YOU. IF YOU OPPOSE THE MOTION AND HAVE NOT REACHED AN
AGREEMENT, YOU MUST ATTEND THE HEARING. UNLESS THE PARTIES
AGREE OTHERWISE, THE COURT MAY CONSIDER EVIDENCE AT THE
HEARING AND MAY DECIDE THE MOTION AT THE HEARING.
EMERGENCY RELIEF HAS BEEN REQUESTED. IF THE COURT CONSIDERS

THE MOTION ON AN EMERGENCY BASIS, THEN YOU WILL HAVE LESS THAN
21 DAYS TO ANSWER. IF YOU OBJECT TO THE REQUESTED RELIEF OR IF
YOU BELIEVE THAT THE EMERGENCY CONSIDERATION IS NOT
WARRANTED, YOU SHOULD FILE AN IMMEDIATE RESPONSE.
REPRESENTED PARTIES SHOULD ACT THROUGH THEIR ATTORNEY.

Randy Williams (the “Trustee”) initiates the above styled adversary proceeding
(“Adversary Proceeding”) and files this Plaintiff’s Verified Original Complaint and Application
for a Temporary Restraining Order and Preliminary Injunction (the “Complaint”) against Syed
Rizwan Mohiuddin a/k/a Rizwan a/k/a Syed Rizwan a/k/a Ray a/k/a Ray Mohiuddin a/k/a Syed
Mohiuddin, Syed Ghouse Mohiuddin a/k/a Syed Ghouse a/k/a Ghouse, Mona Lisa Mohiuddin,
Mariya Mohiuddin, Syed Amaan Mohiuddin, S. A. M., a minor child, by and through his Next
Friend, Syed Rizwan Mohiuddin, Jennifer Rizvi a/k/a Jennifer Sydenham, Raheel Khan, Marzia
Khan a/k/a Marzia Kamal, Mahvish Khan, Ajay Gaddapati a/k/a Ajay Gaddipati, Ravishanker
Mallapuram, Kuldip Singh a/k/a KD Singh, Jimin Wang, Nathan J. Mays, SRM Molecular, Inc.,
SRM Petroleum Products, Inc. d/b/a Independent Title Service, SRM Terminal, LLC, MMAF,
LLC, MMAF Investment Holdings, Inc. a/k/a MMAF Holdings, Inc. a/k/a M.M.A.F. Holdings,
Inc.,1 MMAF & JIMIN INVESTMENT, LLC, Le Jardin Events a/k/a Mona Lisa Events and
Banquet, LLC, Selinsky Palms Apartments, LLC, Doctors Hospital 1997, L.P. d/b/a United
Memorial Medical Center, 510 West Tidwell, LLC, Tidwell/Parkway Ventures, LLC,
Tidwell/Parkway Property Holdings, LP d/b/a Four Star Capital, Laeeq Health Systems, LLC,
Laeeq MOB, LP d/b/a MMJA Ventures, Laeeq MOB Management, LLC, Laeeq 511 Interests a/k/a
511 Investments, LLC, Tidwell MOB Management, LLC, and Tidwell MOB, LP, 5921 Interests,
Ltd, DG Reality, LLC and BREAKTIME STORES 30, LLC (collectively, the “Defendants”).
PARTIES AND JURISDICTION
1. The Trustee is the Chapter 7 Trustee in the above captioned case (the “Bankruptcy
Case”) and may be served with process in the Adversary Proceeding through the undersigned
counsel.
1
There is both a Texas registered entity and a Delaware registered entity with this same name. The Trustee seeks a
declaratory judgment that he owns both of these entities.
2. Syed Rizwan Mohiuddin a/k/a Rizwan a/k/a Syed Rizwan a/k/a Ray a/k/a Ray
Mohiuddin a/k/a Syed Mohiuddin (the “Debtor”) is an individual who resides in Houston, Texas
and is the debtor in the Bankruptcy Case. Debtor can be served by United States certified and first
class mail at the place where he resides at 5622 Havenwoods Drive, Houston, Texas 77066, or
wherever he may be found.
3. Syed Ghouse Mohiuddin a/k/a Ghouse (“Ghouse”) is an individual and brother of
Debtor residing in Spring, Texas. Syed Ghouse Mohiuddin can be served by United States certified
and first class mail at the place where he resides at 18106 Hampton Park, Spring, Texas 77379, or
4. Mona Lisa Mohiuddin (“Mona”) is an individual and wife of Debtor residing in
Houston, Texas. Mona will be served by United States certified and first class mail at the place
where she resides at 5622 Havenwoods Drive, Houston, Texas 77066, or wherever she may be
found.
5. Mariya Mohiuddin (“Mariya”) is an individual and daughter of Debtor residing in
Houston, Texas. Mariya will be served by United States certified and first class mail at the place
found.
6. Syed Amaan Mohiuddin, commonly referred to as Amaan (“Amaan”), is an
individual and son of Debtor residing in Houston, Texas. Amman will be served by United States
certified and first class mail at the place where he resides at 5622 Havenwoods Drive, Houston,
Texas 77066, or wherever he may be found.
7. S. A. M., commonly referred to as F. (“F”), is an individual and son of Debtor
residing in Houston, Texas. F is sued by and through his Next Friend, Syed Rizwan Mohiuddin

(Debtor) and will be served by United States certified and first class mail where Debtor resides at
5622 Havenwoods Drive, Houston, Texas 77066, or wherever Debtor may be found.
8. Jennifer Rizvi a/k/a Jennifer Sydenham (“Jennifer”) is an individual residing in
Houston, Texas, who is a sister-in law and business associate of Debtor. Jennifer can be served
by United States certified and first class mail at the place where she resides located at
5623 Havenwoods Drive, Houston, Texas 77066, or wherever she may be found.
9. Raheel Khan, commonly referred to as Bunty (“Raheel”), is an individual and
brother-in-law of Debtor residing in Houston, Texas. Raheel can be served by United States
certified and first class mail at the place where he resides at 5623 Havenwoods Drive, Houston,
10. Marzia Khan a/k/a Marzia Kamal (“Marzia”) is an individual and sister-in-law of
Debtor residing in Houston, Texas. Marzia can be served by United States certified and first class
mail at the place where she resides at 5623 Havenwoods Drive, Houston, Texas 77066, or
wherever she may be found.
11. Mahvish Khan (“Mahvish”) is an individual and sister-in-law of Debtor residing in
Houston, Texas. Mahvish can be served by United States certified and first class mail at the place
found.
12. Ghouse, Mona, Mariya, Amaan, F, Jennifer, Raheel, Marzia and Mahvish are
jointly and individually referred to as the “Debtor’s Family Members.”
13. Ajay Gaddapati a/k/a Ajay Gaddipati (“Ajay”) is an individual and business
associate of Debtor residing in Houston, Texas. Ajay can be served by United States certified and

first class mail at his residence located at 19030 Crescent Bay Drive, Houston, Texas 77094, or
14. Ravishanker Mallapuram a/k/a Ravi (“Ravi”) is an individual and business
associate of Debtor residing in Houston, Texas. Ravi can be served by United States certified and
first class mail at his residence located at 13605 Summer Cloud Lane, Pearland, Texas 77584, or
15. Tech Brix Consulting Services, Inc. (“Tech Brix”) is a Texas corporation that is
believed to be owned by Ravi. Tech Brix can be served through its registered agent, Ravi, by
United States certified and first class mail at 1124 Southwest Freeway, Suite 250-2, Houston, TX
77031, or through Ravi at his place of residence, located at 13605 Summer Cloud Lane, Pearland,
16. Kuldip Singh a/k/a KD Singh (“Kuldip”) is an individual and business associate of
Debtor residing in Houston, Texas. Kuldip can be served by United States certified and first class
mail at his residence located at 6419 Gusty Trail Lane, Houston, Texas 77041, or wherever he may
be found.
17. Jimin Wang (“Wang”) is an individual and business associate of Debtor residing in
Houston, Texas. Wang can be served by United States certified and first class mail at his place of
business located at 9888 Bellaire Boulevard, Houston, Texas 77036, or wherever he may be found.
18. Nathan J. Mays (“Mays”) is an individual and business associate of Debtor residing
in Houston, Texas. Mays can be served by United States certified and first class mail at his place
of business located at 914 Preston, Suite 3N, Houston, Texas 77002, or wherever he may be found.
19. Ajay, Ravi, Kuldip, Wang and Mays are jointly and individually referred to as the
“Debtor’s Associates.”

20. SRM Molecular, Inc. (“SRM Molecular”) is a forfeited Texas corporation. SRM
Molecular can be served by United States certified and first class mail through its registered agent,
William B. Ramsey, at 1 Riverway, Houston, TX 77056. SRM Molecular can also be served at
2800 Post Oak, Suite 4100 Houston, TX 77056, which is the listed office of its director, Syed
Rizwan Mohiuddin, or at 5622 Havenwoods, Houston, TX 77066, or wherever Syed Rizwan
Mohiuddin may be found.
21. SRM Petroleum Products, Inc. d/b/a Independent Title Service (“SRM
Petroleum”) is a forfeited Texas corporation. SRM Petroleum can be served by United States
certified and first class mail through its registered agent and manager, Syed Rizwan Mohiuddin,
at 2800 Post Oak, Suite 4100 Houston, TX 77056. SRM Petroleum can also be served through
Syed Rizwan Mohiuddin, an officer eligible to accept service on behalf of SRM Petroleum, at
5622 Havenwoods, Houston, TX 77066, or wherever he may be found.
22. SRM Terminal, LLC (“SRM Terminal”) is a Texas limited liability corporation.
SRM Terminal can be served by United States certified and first class mail through its registered
agent, William B. Ramsey, at 1 Riverway, Houston, TX 77056. Alternatively, SRM Terminal can
be served through its managers, MMAF LLC, at 2800 Post Oak, Suite 4100 Houston, TX 77056
or Syed Ghouse Mohiuddin, at the place where he resides, 18106 Hampton Park, Spring, TX
77379, or wherever he may be found.
23. SRM Molecular, Inc., SRM Petroleum Products, Inc. d/b/a Independent Title
Service, SRM Terminal, LLC are jointly and individually referred to as the “SRM Entities.”
24. MMAF, LLC, is a Texas limited liability corporation. MMAF, LLC can be served
by United States certified and first class mail through its registered agent and manager, Syed
Ghouse Mohiuddin, at 402 Main Street, Suite 300, Houston, TX 77002. Syed Ghouse Mohiuddin

can also be served at the place where he resides, 18106 Hampton Park, Spring, TX 77379, or
wherever he may be found. MMAF LLC can also be served through Syed Rizwan Mohiuddin, an
officer eligible to accept service, at the place where he resides, 5622 Havenwoods, Houston, TX
77066, or wherever he may be found.
25. MMAF Holdings, Inc. is a forfeited Texas corporation. MMAF Holdings, Inc. is a
Delaware corporation. MMAF Investment Holdings, Inc. does not appear to be a real entity.
Trustee believes that Debtor refers to these entities interchangeably. M.M.A.F. Holdings, Inc.
(Texas) can be served by United States certified and first class mail through its registered agent,
Mona Mohiuddin, at 2500 North Post Oak Boulevard, Suite 5800, Houston, TX 77027 or at
Havenwoods, Houston, TX 77066, or wherever she may be found. Alternatively, M.M.A.F.
Holdings, Inc. can also be served through Syed Rizwan Mohiuddin, an officer eligible to accept
service, at 5622 Havenwoods, Houston, TX 77066, or wherever he may be found. MMAF
Holdings, Inc. (Delaware) can be served by United States certified and first class mail through its
registered agent, The Company Corporation, at 251 Little Falls Drive, Wilmington, DE 19808, or
through Mona Mohiuddin or Syed Rizwan Mohiuddin, officers eligible to accept service, at 5622
Havenwoods, Houston, TX 77066, or wherever either of them may be found.
26. MMAF, LLC and MMAF Investment Holdings, Inc. a/k/a MMAF Holdings, Inc.
a/k/a M.M.A.F. Holdings, Inc. are jointly and individually referred to as the “MMAF Entities.”
27. MMAF & JIMIN INVESTMENT, LLC (“Citgo Entity”) is a Texas limited liability
corporation. Citgo Entity can be served by United States certified and first class mail through its
registered agent and manager, Jimin Wang at 9888 Bellaire Boulevard, Houston, TX 77066.
Alternatively, the Citgo Entity can be served through Syed Rizwan Mohiuddin, an officer eligible
to accept service at 5622 Havenwoods, Houston, TX 77066, or wherever he may be found.

28. Le Jardin Events a/k/a Mona Lisa Events and Banquet, LLC (“Event Entity”) is a
Texas limited liability corporation. Event Entity can be served by United States certified and first
class mail through its registered agent and manager, Mona Mohiuddin, at 17103 Bamwood Road,
Houston, Texas 77090 or at 5622 Havenwoods, Houston, TX 77066, or wherever she may be
found. Alternatively, the Event Entity can be served through Syed Rizwan Mohiuddin, an officer
eligible to accept service, at 5622 Havenwoods, Houston, TX 77066, or wherever he may be found.
29. Selinsky Palms Apartments, LLC a/k/a Crestmont Senior Living (“Apartment
Entity”) is a limited liability corporation and may be served by United States certified and first
class mail through its registered agent, Malya Ramachandra, at 212 Crosstimbers, Suite 130,
Houston, TX 77022, or through its manager, Syed Ghouse Mohiuddin, at 18106 Hampton Park,
Spring, TX 77379, or wherever he may be found. Alternatively, Selinsky Palms Apartments, LLC
may also be served through Syed Rizwan Mohiuddin, an officer eligible to accept service, at 5622
Havenwoods, Houston, TX 77066, or wherever he may be found.
30. Doctors Hospital 1997, L.P. d/b/a United Memorial Medical Center, (“Doctors
Hospital 1997”) is a Texas limited partnership and may be served by United States certified and
first class mail through its general partner, 510 W. Tidwell, LLC, or through its registered agent,
Michael Bullard, at 510 W. Tidwell Road, Houston, TX 77091. Doctor’s Hospital 1997 may also
be served through Syed Rizwan Mohiuddin, an officer eligible to accept service, at 5622
31. 510 West Tidwell, LLC is a Texas limited liability corporation that may be served
by United States certified and first class mail through its registered agent, Syed Mohiuddin, at
2800 Post Oak, Houston, TX 77056, Suite 4100, or 5622 Havenwoods, Houston, TX 77066, or
wherever he may be found. Alternatively, 510 West Tidwell, LLC may be served through its

manager Ravi, at his residence located at 13605 Summer Cloud Lane, Pearland, Texas 77584, or
32. Tidwell/Parkway Ventures, LLC is a Texas limited liability corporation that may
be served by United States certified and first class mail through its manager, Syed Rizwan
Mohiuddin at 5622 Havenwoods, Houston, TX 77066 or through its registered agent, Robert A.
Turner, at 510 W. Tidwell Road, Houston, TX 77094.
33. Tidwell/Parkway Property Holdings, LP d/b/a Four Star Capital (“TPPH”) is a
Texas limited partnership and may be served by United States certified and first class mail through
its general partner, 510 W. Tidwell, LLC, or through its registered agent, Michael Bullard, at 510
W. Tidwell Road, Houston, TX 77091. TPPH may also be served through Syed Rizwan
Mohiuddin, an officer eligible to accept service, at the place where he resides, 5622 Havenwoods,
Houston, TX 77066, or wherever he may be found.,
34. Laeeq Health Systems, LLC is a Texas limited liability corporation that may be
served by United States certified and first class mail through its manager, Ajay Gaddipati, at 3203
Southford Manor Lane, Katy, TX 77494 or through its registered agent, or through Syed Rizwan
Mohiuddin, an officer eligible to accept service, at 5622 Havenwoods Drive, Houston, TX 77066.
35. Doctor’s Hospital 1997, 510 West Tidwell, LLC, Tidwell/Parkway Ventures, LLC,
TPPH and Laeeq Health Systems, LLC will herein after be referred to as the “Doctors Hospital
Entities.”
36. Laeeq MOB, LP d/b/a MMJA Ventures (“Laeeq MOB, LP”) is a Texas limited
partnership that that may be served by United States certified and first class mail through its general
partner, Laeeq MOB Management, LLC, at 509 W. Tidwell Road, Suite 170, Houston, TX 77091.
Laeeq MOB, LP may also be served through its registered agent, Ajay Gaddipati, at 509 W.

Tidwell Road, Suite 170, Houston, TX 77091, or at his residence located at 19030 Crescent Bay
Drive, Houston, Texas 77094, or wherever he may be found. Laeeq MOB, LP may also be served
through Syed Rizwan Mohiuddin, an officer eligible to accept service, at 5622 Havenwoods,
Houston, TX 77066, or wherever he may be found.
37. Laeeq MOB Management, LLC is a Texas limited liability corporation that may be
served by United States certified and first class mail through its director, Syed G. Mohiuddin, or
its registered agent, Ajay Gaddipati, at 509 W. Tidwell Road, Suite 170, Houston, TX 77091, or
at his residence located at 19030 Crescent Bay Drive, Houston, Texas 77094, or wherever he may
be found. Laeeq MOB Management, LLC may also be served through Syed Rizwan Mohiuddin,
an officer eligible to accept service, at 5622 Havenwoods, Houston, TX 77066, or wherever he
may be found.,
38. Laeeq MOB, LP and Laeeq MOB Management, LLC are jointly and individually
referred to as the “MOB Entities.”
39. Laeeq 511 Interest, LLC a/k/a 511 Investments (“Laeeq 511”) is a Texas limited
liability corporation that may be served by United States certified and first class mail through its
registered agent, Prabhugoada Patil, at 511 W. Tidwell, Houston, TX 77091. Laeeq 511 may also
be served through its manager Syed Ghouse Mohiuddin at 511 W. Tidwell, Houston, TX 77091,
at the place where he resides, 18106 Hampton Park, Spring, TX 77379, or wherever he may be
found. Laeeq 511 may also be served through Syed Rizwan Mohiuddin, an officer eligible to
accept service, at 5622 Havenwoods, Houston, TX 77066, or wherever he may be found.
40. Tidwell MOB Management, LLC is a Texas limited liability corporation that may
be served by United States certified and first class mail through its registered agent and manager,
Asaf R. Qadeer, at 8660 Memorial Drive, Houston, TX 77024. Tidwell MOB Management, LLC

may also be served through its manager, Syed H. Reza, at 6525 FM 2920 Suite 202, Spring, TX
77379, or through Syed Rizwan Mohiuddin, an officer eligible to accept service, at 5622
41. Tidwell MOB, LP is a Texas limited partnership that that may be served by United
States certified and first class mail through its general partner, Tidwell MOB Management, LLC,
or its registered agent, Asaf R. Qadeer, each at 8660 Memorial Drive, Houston, TX 77024.
Tidwell MOB, LP may also be served through Syed Rizwan Mohiuddin, an officer eligible to
accept service, at the place where he resides, 5622 Havenwoods, Houston, TX 77066, or wherever
he may be found.
42. Laeeq 511, Tidwell MOB Management, LLC, and Tidwell MOB, LP are jointly
and individually referred to as the “Clinic Entities.”
43. SRM Entities, MMAF Entities, Citgo Entity, Event Entity, Apartment Entity,
Doctors Hospital Entities, MOB Entities and Clinic Entities are jointly and individually referred
to as the “Business Entities.”
44. 5921 Interests, Ltd is a Texas limited partnership that may be served by United
States certified and first class mail through its registered agent, David N. Greenberg, at 5959
Richmond Ave., Suite 440, Houston, Texas 77057.
45. DG Realty, LLC is a Texas limited liability company that may be served by United
States certified and first class mail through its registered agent, David N. Greenberg, at 5959
Richmond Ave., Suite 440, Houston, Texas 77057.
46. BREAKTIME STORES 30, LLC is a Texas limited liability company that may be
served by United States certified and first class mail through its registered agent, Ray A.
Cunningham, Sr., at 610 W. Main, Suite 101, League City, Texas 77573. BREAKTIME STORES

30, LLC may also be served via its owner, Omair Bashir at P.O. Box 572968, Houston, Texas
77257.
47. 5921 Interests, Ltd., DG Reality, LLC and BREAKTIME STORES 30, LLC are
jointly and individually referred to as the “Parker Transfer Entities.”
48. This is a core proceeding pursuant to 11 U.S.C. § 541 and 28 U.S.C. § 157(b)(2)(A),
(b)(2)(B), and (b)(2)(O).
49. Venue is proper in this district pursuant to 28 U.S.C. § 1409(a).
50. The Court has jurisdiction over this matter pursuant to 11 U.S.C. § 541 and 28
U.S.C. §§ 157 and 1334. Relief is sought pursuant to 11 U.S.C. § 541, 28 U.S.C. § 2201 and
Bankruptcy Rule 7001.
SUMMARY OF THIS ADVERSARY PROCEEDING
51. The Trustee seeks a declaratory judgment that the Business Entities are property of
Debtor’s Chapter 7 bankruptcy estate and are subject to administration by the Trustee.
52. Debtor previously stated that he is the sole owner of the Business Entities. At other
times, Debtor asserted: 1) that Debtor owns various percentages less than 100%, 2) that Debtor’s
Family Members own various percentages, and 3) that Debtor’s Associates own various
percentages. Should any of Debtor’s Family Members or Debtor’s Associates contest the
Trustee’s ownership and assert an interest in any of the Business Entities, the Trustee also seeks
an award of attorney’s fees against such Debtor’s Family Members or Debtor’s Associates.
53. Moreover, to the extent that any property of the estate is not in the Trustee’s
possession, the Trustee seeks immediate turnover of that property. And, to the extent that any
property of the estate was transferred by or among Defendants post-petition, such transfers are
avoidable pursuant to the Bankruptcy Code.

54. Lastly, the Trustee also seeks a temporary restraining order and preliminary
injunction (“TRO”) to preserve the bankruptcy estate by restricting how assets, ownership
interests, property and money can be transferred.
STATEMENT OF FACTS
55. The Bankruptcy Case is an involuntary Chapter 7 commenced on September 9,
2015 (the “Petition Date”) and on November 17, 2015, Randy Williams was duly appointed as
successor trustee for the Bankruptcy Case.
56. To date, Debtor asserts his Fifth Amendment privilege and he has failed and refused
to complete bankruptcy schedules and statements of financial affairs. The Trustee believes Debtor
is using the Fifth Amendment to shield his elaborate scheme of hiding his assets to avoid paying
his creditors.
57. Despite Debtor’s refusal to disclose his assets and ownership interests to the
Bankruptcy Court, the Trustee, and creditors throughout the pendency of the Bankruptcy Case, the
Trustee undertook significant third party discovery. The Trustee uncovered numerous business
interests owned by Debtor or held for Debtor in the name of Debtor’s Family Members or Debtor’s
Associates.
58. Written documentation and public filings reflect that Debtor is the sole owner of
the Business Entities and/or the sole officer exerting control and management of the Business
Entities.
59. Evidence obtained by the Trustee, including evidence from both Debtor’s Family
Members and Debtor’s Associates, establishes that Debtor exercises sole financial control,
management authority and owns interests in the Business Entities.2 Before and after the petition
2
See Exhibit A, Declaration of Randy Williams and Exhibit B, Declaration of Stephen Daughters in support of the
Complaint and exhibits included in the Appendix attached hereto and incorporated herein by reference.
date, Debtor repeatedly transferred funds between the Business Entities’ bank accounts to cover
personal expenses, service personal debts, and initiate new business ventures. Allegations
concerning each of these Business Entities follow below in paragraphs 60 through 68.
60. SRM Entities concern a petroleum related business. Based on discovery
conducted and information obtained, the Trustee believes Debtor owned a 100% interest in the
SRM Entities, including their assets and real estate, as of the Petition Date. One of the SRM
Entities, SRM Terminal, LLC, is the listed owner of a petroleum products storage facility,
commonly referred to as a “tank farm” located at 12927 Highway 146 North, Mount Belvieu,
Texas 77523 (“SRM Tank Farm”). Debtor used the SRM Tank Farm and the SRM Entities as
assets on personal financial statements to obtain large loans—the proceeds of which he has used
to acquire other property in the name of other Defendants.
61. MMAF Entities are used interchangeably by Debtor for various business purposes.
These purposes include: 1) owning the real estate at both 5622 Havenwoods Drive, Houston, Texas
77066 (“5622 Havenwoods”) and 5623 Havenwoods Drive, Houston, Texas 77066 (“5623
Havenwoods”), 2) holding interests in other Business Entities, including Laeeq Health Systems,
LLC, and 3) serving as an asset listed on personal financial statements submitted by Debtor during
this Bankruptcy Case. Though Debtor asserted at various times that Ghouse, Kuldip, Mona,
Mariya, Amann, F, and Mays own various interests in the MMAF Entities, based on discovery
conducted and information obtained, the Trustee believes Debtor owns 100% of each of the
MMAF Entities and their assets and real estate as of the Petition Date, including 5622
Havenwoods. Based on discovery conducted and information obtained, Trustee believes Debtor
acquired 5623 Havenwoods with proceeds of property of the estate post-petition.

62. Citgo Entity owns a Citgo branded gas station and the real property located at 4903
Airline Drive #12, Houston, Texas 77022 which includes additional space that is leased to
commercial tenants. Based on discovery conducted and information obtained, Trustee believes
Debtor owns 35% of the Citgo Entity, including its assets and real estate, as of the Petition Date.
63. Event Entity owns real property consisting of three lots including one that is a
commercial event venue space. The addresses for these lots are: 17119 Bamwood Drive, Houston,
Texas 77090; 17103 Bamwood Drive, Houston, Texas 77090; and 17111 Bamwood Drive,
Houston, Texas 77090 (“Bamwood Properties”). Based on discovery conducted and information
obtained, the Trustee believes Debtor owns 100% of the Event Entity, including its assets and the
Bamwood Properties, as of the Petition Date.
64. Apartment Entity owns real property located at 5638 Selinsky Road, Houston
Texas 77048, which is currently vacant, unimproved land. An apartment complex once occupied
this lot. However, the Trustee discovered that the complex was demolished by the City of Houston
during the Bankruptcy Case. In fact, Debtor retained separate bankruptcy counsel to file a separate
bankruptcy case on behalf of Apartment Entity in an unsuccessful effort to stop the demolition.3
Based on discovery conducted and information obtained, before the Petition Date Debtor entered
into one or more agreements to acquire Apartment Entity. Based on discovery conducted and
information obtained, the Trustee believes Debtor currently owns 100% of Apartment Entity,
including its assets and real property, as a result of money payments funneled by Debtor through
the Doctors Hospital Entities to third parties during the Bankruptcy Case.
65. Doctors Hospital Entities own real estate, including improved and unimproved
commercial real estate, a hospital facility, and a private hospital enterprise (collectively, the
3
See In re Selinsky Palms Apartments, LLC, Case No. 17-32434 (Bankr. S.D. Tex. Apr. 21, 2017) (ECF No. 1).
“Hospital”). The unimproved plots of commercial land are either adjacent to Doctors Hospital or
are the site of a former hospital that has been demolished. These unimproved plots are found at
5734 Stuebner Airline Road, Houston, Texas 77091 and 233 W. Parker Road, Houston, Texas
77076. Doctors Hospital sits on five different tracts of land which can be found at the following
addresses and Harris County Appraisal District account numbers: 510 W. Tidwell Road, Houston,
Texas 77091 (610010000001), 510 W. Tidwell Road #117, Houston, Texas 77091
(610010000004), 508 W. Tidwell Road, Houston, Texas 77091 (610010000005), 508 W. Tidwell
Road, Houston, Texas 77091 (610010000006), and 510 W. Tidwell Road, Houston, Texas 77091
(610010000001). Based on discovery conducted and information obtained, the Trustee believes
Debtor owned no less than a 55% interest in the Doctors Hospital Entities and their assets,
including the foregoing real estate, as of the Petition Date. Since the Petition Date, transfers of
assets and ownership interests from other Business Entities (which Debtor owns and are property
of the estate or proceeds of property of the estate) indicate that Debtor now owns no less than an
86% interest in the Doctors Hospital Entities, including their assets and real estate.
66. MOB Entities own a medical office building at 509 W. Tidwell Road, Houston,
Texas 77091, located across the street from Doctors Hospital. Based on discovery conducted to
date, Debtor acquired at least a 55% interest in the MOB Entities post-petition using proceeds of
property of the estate. While the ownership interest arose after the Petition Date, it was acquired
during the Bankruptcy Case as a result of transfers from Business Entities that Debtor owned as
of the Petition Date.
67. Clinic Entities own a medical imaging clinic at 511 W. Tidwell Road, Houston,
Texas 77091,4 which is across the street from Doctors Hospital. Based on information obtained
4
Hereinafter referred to collectively with the real property described in paragraphs 60-68 as the “Real Property.”
and discovery conducted to date, Debtor acquired at least a 55% interest in the Clinic Entities post-
petition from proceeds of property of the estate. That is, while Debtor’s ownership interest arose
after the Petition Date, it was acquired during the Bankruptcy Case as a result of transfers from
Business Entities that Debtor owned as of the Petition Date.
68. Parker Transfer Entities were involved in multiple transactions concerning the
real property at 233 W. Parker Road, Houston, Texas 77076 (the “Parker Property”). As of the
Petition Date, Debtor owned at least a 55% interest in the Parker Property, which at the time was
a single lot, by and through his ownership interest in Tidwell/Parkway Property Holdings, LP.
Since the Petition Date, the Parker Property has been subdivided into four separate lots as a result
of a series of transactions. For purposes of this Complaint, these four lots are identified as “Parker
Property 1” and “Parker Property 2”5 “Parker Property 3,”6 and “Parker Property 4.”7 Debtor
caused the transactions to be initiated and now Tidwell/Parkway Property Holdings, LP (herein,
one of the Doctors Hospital Entities), owns Parker Property 1. BREAKTIME STORES 30, LLC,
whose principle is Omair Bashir (a brother in law of Debtor), purportedly owns Parker Property 2
and Parker Property 3. 5921 Interests, Ltd., whose principle is David Greenberg, purportedly owns
the remainder of Parker Property 4.
5
Parker Property 1 and Parker Property 2 include: TWO 1.2629 (55,011 SQUARE FOOT TRACTS) OUT OF
RESERVE A, BLOCK ONE OF PARKER PLAZA AT FORTY-FIVE, AN ADDITION IN HARRIS COUNTY
ACCORDING TO THE MAP OR PLAT THEREOF RECORDED IN FILM CODE NO. 679849 OF THE HARRIS
COUNTY MAP RECORDS.
6
Parker Property 3 is: A 2.2267 (96,996 SQUARE FOOT TRACT) OUT OF RESERVE A, BLOCK ONE OF
PARKER PLAZA AT FORTY FIVE, AN ADDITION IN HARRIS COUNTY ACCORDING TO THE MAP OR
PLAT THEREOF RECORDED IN FILM CODE NO. 679849 OF THE HARRIS COUNTY MAP RECORDS.
7
Parker Property 4 is the remainder of: A 6.913 ACRE (301,147 SQUARE FOOT) TRACT OF LAND SITUATED
IN THE ASHBEL SMITH SURVEY, ABSTRACT NUMBER 726, HOUSTON, HARRIS COUNTY, TEXAS,
BEING PART OF LOT 8 AND PART OF LOT 9 OF LITTLE YORK ANNEX, AN ADDITION IN HARRIS
COUNTY ACCORDING TO THE MAP OR PLAT THEREOF RECORDED IN VOLUME 95, PAGE 309 OF THE
HARRIS COUNTY DEED RECORDS, which was not transferred from 5921 Interests, Ltd.

69. To administer Debtor’s bankruptcy estate, it is necessary both to determine all
ownership claims and interests in and to the Business Entities and to prevent Debtor from
continuing to freely move assets among the Business Entities as it suits his personal needs and
whims. Consequently, the Trustee files the Adversary Proceeding against those Business Entities
and Defendants known to the Trustee. The Trustee has reason to believe that there may be more
entities and properties which Debtor owns and are property of the bankruptcy estate but which
Debtor has hidden or failed to disclose to the Trustee. As such, the Trustee anticipates seeking
amendments to the Complaint and the TRO as discovery in the Adversary Proceeding progresses.
It is also possible that further litigation will be filed to recover additional interests of Debtor.
CAUSES OF ACTION
I. Request for Declaratory Judgment that the Business Entities and All Their Assets Are
Property of the Estate and Subject to Administration by the Trustee.
70. The allegations and exhibits in paragraphs 1 through 69 above are incorporated
herein.
71. Pursuant to 28 U.S.C. Sec. 2201 and 2202, the Trustee seeks a declaratory judgment
that Debtor owns all or a substantial portion of the ownership interests in the following Business
Entities, including their assets and real property (including, without limitation, the real property
described above)8:
 SRM Molecular, Inc.

 SRM Petroleum Products, Inc.
 SRM Terminal, LLC
 MMAF, LLC
 MMAF Investment Holdings, Inc. a/k/a MMAF Holdings, Inc.,
a/k/a M.M.A.F. Holdings, Inc.
 MMAF & JIMIN INVESTMENT, LLC
 Le Jardin Events a/k/a Mona Lisa Events and Banquet, LLC
8
Hereinafter referred to collectively with all other ownership interests identified in paragraph 71 as the “Ownership
Interests.”
 Selinsky Palms Apartments, LLC

 Tidwell/Parkway Ventures, LLC
 510 West Tidwell, LLC
 Tidwell/Parkway Property Holdings, LP d/b/a Four Star Capital
 Laeeq Health Systems, LLC
 Doctors Hospital 1997, L.P. d/b/a United Memorial Medical Center
 Laeeq MOB, LP d/b/a MMJA Ventures, LLC
 Laeeq MOB Management, LLC
 Laeeq 511 Interests, LLC
 Tidwell MOB Management, LLC
 Tidwell MOB, LP.
72. Moreover, the Trustee seeks a declaratory judgment that Debtor’s Family Members
and Debtor’s Associates either own no interest in the Business Entities or own a percentage
exclusive from that which Debtor owns, subject to proof that consideration was actually given for
such interests and that to the extent consideration was given that it was funds of those parties and
not funds of Debtor and/or his interest in the Business Entities or otherwise property of the
bankruptcy estate.
73. The Trustee also seeks a declaratory judgment that Debtor’s interests in the
Business Entities are property of Debtor’s Chapter 7 bankruptcy estate and subject to
administration by the Trustee.
74. The Trustee is entitled to such a declaratory judgment pursuant to the following
four theories.
i. Quasi-Estoppel
herein.
76. Quasi-Estoppel prevents “a party from asserting, to another’s disadvantage, a right
inconsistent with a position previously taken.” Lopez v. Munoz, Hockema & Reed, L.L.P., 22
S.W.3d 857, 864 (Tex. 2000). “The doctrine applies when it would be unconscionable to allow a

person to maintain a position inconsistent with one to which he acquiesced, or from which he
accepted a benefit.” Id.
77. Debtor, both before and after the Petition Date, repeatedly represented to third-
parties that he had ownership interests in the Business Entities and Real Property. Such conduct
puzzled the Trustee. Why would a debtor who genuinely fears that his Fifth Amendment rights are
at risk fail and refuse to disclose to the Court his assets, yet proceed to disclose his assets on no
less than three separate occasions to lenders after the Petition Date? Exhibit 1, at 13–35.9 The
Trustee has come to one conclusion—Debtor is engaged in an ongoing scheme to hide his assets
and grow his personal wealth, while relying on Debtor’s Family Members and Debtor’s Associates
to accomplish this scheme during the pendency of the Bankruptcy Case.
78. This conclusion is buttressed by the personal financial statement provided by
Debtor and signed by Debtor post-petition related to an asset purchase agreement (“Asset
Purchase”) in a Chapter 11 bankruptcy involving Humble Surgical Hospital, LLC (“Humble
Surgical Bankruptcy”).10 As part of the Asset Purchase, Debtor sent a signed, personal financial
statement to the debtors and Chapter 11 trustee in the Humble Surgical Bankruptcy. Exhibit 1, at
19-22. The result was a sale order approved by Judge Lynn Hughes of the United States District
Court for the Southern District of Texas. Exhibit 2, at 6–30. In fact, the same counsel who
represents Debtor in the above-captioned bankruptcy case, represented Debtor in the Asset
Purchase. Exhibit 2, at 29-30.
79. Given such conduct, as well as Debtor’s choice to destroy estate property rather
than surrendering it to the Trustee when under Court Order, Exhibit 3, the Trustee believes Debtor
will either deny his ownership in the Business Entities or point to those who nominally hold the
9
All of the exhibits referenced herein are included with the Appendix attached to and filed with the Complaint.
10
In re Humble Surgical Hosp., LLC, No. 17-31078-HW-11 (S.D. Tex. June 30, 2017) (Hughes, J.).
Business Entities as the true owners. Quasi-estoppel precludes Debtor both from denying such
ownership and from pointing to other parties as the true owners. Debtor benefited from his
assertions in these personal financial statements—as evident from the facts herein—and it would
be unconscionable for Debtor to not be estopped from asserting legal arguments directly contrary
to his admitted ownership. To do so would allow Debtor to continue avoiding both his obligations
under the Bankruptcy Code and his creditors. Given the financial benefits Debtor received from
his representations of ownership, Texas law estops Debtor from denying ownership in the Business
Entities or pointing to others as owning his interests. In re Liao, 553 B.R. 584, 607 (Bankr. S.D.
Tex. 2016) (citing Davidson v. Davidson, 947 F.2d 1294, 1297 (5th Cir. 1991) (internal citations
omitted).
80. An identification of facts which support the application of quasi-estoppel as it
relates to certain of the Ownership Interests and Real Property, and other assets, follows below.
These facts are only partial and the Trustee anticipates more will be revealed as discovery
progresses.
81. SRM Entities: Through signed financial statements, Debtor repeatedly listed his
ownership in the SRM Entities to obtain financing from third-party lenders:11
Date of Financial
12/12/2014 2/17/2015 6/20/2015 9/17/2015 8/15/2017 9/1/2018
Statement
Listed Ownership in 60% 60% unspecified 30% 70% 70%
SRM Terminal LLC ownership
Recipient/Lender Greenberg Lowry Nazario American Dean Third Coast
Finance Donkey Trujillo (for First Maddox Bank
Company Farm LP Keller National
Williams) Bank
11
Although these financial statements list the social security number and birth date of Ghouse, based on Trustee’s
review of signature cards related to bank accounts for which Debtor has authority, Trustee contends Debtor signed
these financial statements. Before the Court, Debtor identified his own signature, and the same signature is on these
financial statements indicating that Debtor—not Ghouse—signed these statements. Exhibit 5; Exhibit 6, at 1–3.
Debtor did list his own social security number on the financial statement dated June 20, 2015. Additionally, the
name listed on the December 12, 2014 financial statement was “Syed R. Mohiuddin” and “Syed Mohiuddin” on all
subsequent statements. Finally, Debtor sent all of the financial statements referenced herein to the relevant parties
from his email address: srm1124@gmail.com.
82. Based apparently on Debtor’s representations in the December 2014 financial
statement (“December 2014 Statement”), Exhibit 1, at 4–6, Greenberg Finance Company agreed
to loan $1.82 million to SRM Terminal. Exhibit 4.
83. MMAF Entities: Through signed financial statements, Debtor repeatedly listed
his ownership in the MMAF Entities and the real property associated with them to obtain financing
from third-party lenders.
Date of Financial
12/12/2014 2/17/2015 6/20/2015 9/17/2015
Statement
Listed Ownership in 100% 100% 100% 100%
5622 Havenwoods
Recipient/Lender Greenberg Lowry Nazario American
Finance Donkey Trujillo (for First
Company Farm LP Keller National
Williams) Bank
84. In loan negotiations in May 2015 with an entity named Lowry Donkey Farm LP,
Debtor stated to lender’s counsel, Kevin Kerr in an email: “MMAF HOLDINGS is owned by my
family, [sic] those are first intials [sic] of my children and i am the president of this entity.” Exhibit
7, at 1. Mona testified that Debtors and her children’s names are Mariya, Amaan and F. Exhibit
8. On the Petition Date, Mariya, Amaan and F were all between the ages of 14 and 23. Exhibit
8, 8:7–10:25.
85. Citgo Entity: Through signed financial statements, Debtor repeatedly listed his
ownership in the MMAF Entities and the real property associated with them to obtain financing
from third-party lenders. As of the Petition Date, Debtor owns at least a 35% interest in this entity.
Date of Financial Statement 12/12/2014 2/17/2015 6/20/2015

Listed Ownership in Citgo
Gas Station 35% 35% 100%
Greenberg Nazario Trujillo
Recipient/Lender Finance Lowry Donkey (for Keller
Company Farm LP Williams)

86. Debtor owns a 35% interest in the Citgo Entity. Exhibit 9, at 36. Debtor confirmed
his ownership percentage interest in email correspondence with Wang and profit distributions with
Wang that align with that same percentage. Exhibit 10.
87. Apartment Entity: Through a signed financial statement, Debtor identified his
ownership in the Apartment Entity as 65% in order to obtain financing from a third-party lender
in the August 2017. Exhibit 1, at 19–22.
88. Doctors Hospital Entities: Debtor asserted the following ownership stakes in the
Doctors Hospital Entities, which align with the percentage of ownership the MMAF Entities have
in the Doctors Hospital Entities, i.e. 55% (see infra paragraph 98):
Date of Financial Statement 8/15/2017 9/1/2018

Listed Ownership in Tidwell
Parkway Property Holdings,
L.P. 55% 55%
Listed Ownership in Laeeq
Health Systems, LLC 55% 15%
Listed Ownership in Doctors
Hospital 1997, L.P. 60%
Recipient/Lender Dean Maddox Third Coast Bank
89. MOB Entities: Through a signed financial statement, Debtor identified his
ownership in the Apartment Entity as 55% in order to obtain financing from a third-party lender
in the August 2017. Exhibit 1, at 19–22.
90. Clinic Entities: Through a signed financial statement in August of 2017, Debtor
identified his ownership in the Apartment Entity as 60%. Exhibit 1, at 19–22. Through a signed
financial statement in September 2018, Debtor appears to identify his ownership in the Clinic
Entities as 100%. Exhibit 1, at 28–29. Debtor completed both of these financial statements in an
effort to obtain and benefit from third-party financing.

91. Based on the foregoing and without limitation, Trustee asks the Court find Debtor
is the owner of all or a substantial portion of the Business Entities and their assets and real property.
ii. De Facto Ownership/ Equitable Ownership
herein.
93. Section 541(a)(1) defintes “property of the estate” as including “all legal or
equitable interests of the debtor in property.” 11 U.S.C. § 541(a)(1). Ownership rights in property
do not depend solely on formalities of title. A person may have an interest in property, and may
even be considered the de facto owner, although someone else has title. In re IFS Fin. Corp., 417
B.R. 419, 435 (Bankr. S.D. Tex. 2009) (J. Isgur) (citing Cohen v. Ulz (In re Ulz), 388 B.R. 865,
868 (Bankr. N.D. Ill 2008)). The true owner of property is measured by possession and control
rather than bare legal title. Southmark Corp. v. Grosz (In re Southmark Corp., 49 F.3d 1111, 1116-
17 (5th Cir. 1995). Where the debtor has exercised de facto ownership over assets, “mere circuitry
of arrangement will not save” such assets from being determined to be assets of the estate. Dean
v. Davis, 242 U.S. 438, 443 (1917).
94. Additionally, a debtor owns an equitable interest in property when the debtor uses
his funds to obtain assets, treats the assets as his own, and has the use and enjoyment of the assets.
FDIC v. Sullivan, 204 B.R. 919, 939 (Bankr. N.D. Tex. 1995) (internal citations omitted).
Similarly, control over property held in the name of another and transfers from that property to a
debtor’s family members or close associates also demonstrates equitable ownership. Id.
95. Here, Debtor has exercised de facto ownership and equitable ownership over the
Business Entities, their assets, and real property. For example, Debtor has utilized the Real
Property as collateral when obtaining financing and loans for his own personal benefit and profit.

96. Additionally, both before and after the Petition Date, Debtor exercised possession
and complete control over the numerous bank accounts for the Business Entities and had
“unfettered discretion” in deciding which of his creditors to pay and from which accounts to pay
them. In re IFS Fin. Corp., 669 F.3d 255, 263 (5th Cir. 2012) (citing Southmark v. Grosz (In re
Southmark), 49 F.3d 1111, 1116–17 (5th Cir. 1995)). Debtor has signature authority over
numerous accounts related to the Business Entities12 and regularly moved money among these
accounts absent oversight. Exhibit 6. Debtor would frequently write checks from bank accounts
related to the Doctors Hospital Entities for clearly personal and unrelated expenses, depending, in
the words of Ghouse, on “whichever account ha[d] funds available at the moment . . . .” Exhibit
11. As highlighted below, this partial listing of clearly personal and self-serving transactions
indicates Debtor enjoys the benefit from and treats as his own the Business Entities and their assets.
97. SRM Entities
 Transfers from SRM Entities for Debtor’s Personal Benefit:
o Between May 5, 2015 and November 27, 2015, at least $19,226.64

($9,613.32 prepetition and $7,209.99 post-petition) to MMAF Entities
for debt service on either 5622 Havenwoods or 5623 Havenwoods.
Exhibit 12.
o At least $1,889.30 pre-petition in slip and other fees to South Shore

Harbor Marina for Debtor’s boat. Exhibit 17.
 Transfers from SRM Entities for Debtor’s Personal Businesses:
o At least $141,889.77 for the purchase of the Event Entity and for the
purchase of the Bamwood Properties. Exhibit 13.
o At least $20,633.01 ($14,384.76 pre-petition, $6,248.25 post-petition)

to Event Entity for debt service of the Bamwood Properties. Exhibit 16.
o At least $8,100 in post-petition in political donations. Exhibit 17.
12
This signatory authority includes all bank accounts from which the transfers in paragraphs 97-101 originated.
o At least $13,750 post-petition in connection with Debtor’s development

of the Apartment Entity. Exhibit 14.
98. MMAF Entities
 Money that is due to be paid to the MMAF Entities is routinely paid to other
Business Entities instead. For instance, Debtor would direct money that is to be
paid to MMAF Entities to be paid instead to SRM Entities. See, e.g., Exhibit
15.
 Debtor repeatedly represents that he owns the following three assets in the name
of the MMAF Entities: 1) MMAF Ownership Interests, 2) 5622 Havenwoods,
and 3) 5623 Havenwoods. Exhibit 1. Some details of how these assets benefit
Debtor and how Debtor attempts to hide his true ownership is detailed below:
1) MMAF Ownership Interests:
o As of the Petition Date, through MMAF entities, Debtor held a 55%

interest in Laeeq Health Systems, LLC and 510 W Tidwell, LLC.
Exhibit 19; Exhibit 20. Laeeq Health Systems, LLC holds a 99%
interest as the limited partner in both Doctors Hospital 1997, L.P. and
Tidwell/Parkway Property Holdings, L.P. Exhibit 22, at 24. 510 W
Tidwell, LLC holds a 1% interest as the general partner in both Doctors
Hospital 1997, L.P. and Tidwell/Parkway Property Holdings, L.P.
Exhibit 22, at 24
o Debtor directed this percentage of interest be assigned to the MMAF

Entities in the acquisition of the Doctors Hospital Entities. Exhibit 21.
o Debtor identifies himself as the General Partner in signed documents

with financial institutions for Doctors Hospital Entities. Exhibit 5.
o Debtor uses his ownership and control of Doctors Hospital Entities to

obtain money to support a profligate lifestyle, obtain loans and expand
his business ventures while in Chapter 7 bankruptcy.
2) 5622 Havenwoods:
o Before and since the Petition Date, Debtor has resided and resides at this
address.
o On August 19, 2013, Mahvish, on behalf of MMAF Holdings, Inc.,

executed an agreed order foreclosing on the real property at 5622
Havenwoods. Exhibit 23. Raheel signed the Agreed Judgment,
because he was the “legal” owner. Confusingly, Raheel remained listed
as the “legal” owner until well after the Petition Date, even though title

had vested in Debtor-controlled MMAF Holdings, Inc. on August 19,

2013. Exhibit 24.
o On December 17, 2013, Mona, on behalf of MMAF Holdings, executed

a deed of trust securing a $206,000 loan collateralized by a lien on 5622
Havenwoods. Exhibit 25.13
o Debtor subsequently wrote in a January 21, 2014 email: “My house is

under company name MMAF [sic] the loan was made to company to
pay taxes and outstanding dues [sic]. Signed by Mona and me [sic].”
Exhibit 27, at 1.
o Both before and after the Petition Date, based on representations of

ownership of the Ownership Interests and 5622 Havenwoods, Debtor
consummated numerous business and personal transactions and
obtained almost $9 million in financing from those transactions.
Exhibit 28.
o After the Petition Date, Debtor caused 5622 Havenwoods Drive to

become encumbered by a promissory note in favor of David
Greenberg’s 421 Interests, Ltd. and later caused 5622 Havenwoods to
become encumbered by a promissory note in favor of Tech Brix.
Exhibit 40.
3) 5623 Havenwoods:
o After the Petition Date, Debtor used proceeds from property of the estate
to acquire 5623 Havenwoods in the name of the MMAF Entities and on
the same day transferred 5623 Havenwoods to 5921 Interests, Ltd.
Exhibit 29.
o Thereafter, Debtor caused 5623 Havenwoods to come into the

possession, custody, or control of Tech Brix. Exhibit 30. Multiple of
Debtor’s Family Members, including Jennifer, Raheel, Mahvish and
Mariya reside or resided at 5623 Havenwoods during the Bankruptcy
Case.
99. Apartment Entity
 Transfers from Apartment Entity for Debtor’s Personal Benefit:
13
The deed of trust and promissory notes dated December 17, 2013 refer to “MMAF Holdings, Inc.,” a Texas
corporation. Exhibits 25. Debtor and Mona’s prior entity, actually named M.M.A.F. Holdings, forfeited its Texas
corporate charter in 2007. MMAF Holdings is a similarly named Delaware entity controlled by Debtor. On
September 3, 2015, Debtor’s associate Erwin Wilbanks filed a document correcting the December 2013 deed of trust
and promissory note and substituting the Delaware entity named MMAF Holdings. Exhibit 26. The correction
document indicates that the original December 17, 2013 promissory note had been lost or destroyed. Id.
o At least $7,500 post-petition to James Q. Pope, Debtor’s bankruptcy

attorney in the Bankruptcy Case. Exhibit 32.
o At least $27,325.79 post-petition to the Event Entity, at least $20,600 of

which was for taxes associated with the Bamwood Properties. Exhibit
16.
o At least $30,000 post-petition to “Capricorn Travel.” Exhibit 17.
 Transfers from Apartment Entity for Debtor’s Personal Businesses:
o At least $218,500 post-petition to 421 Interests, Ltd. in connection with

assignment of the note previously held by Texas Funding Corporation
and secured by 5622 Havenwoods. Exhibit 39.
o At least $186,047.34 post-petition from Apartment Entity to Doctors

Hospital Entities to cover expenses such as payroll. Exhibit 37.
o At least $24,830 post-petition from Apartment Entity to Citgo Entity.

Exhibit 37.
100. Doctors Hospital Entities
 Transfers from Doctors Hospital Entities for Debtor’s Personal Benefit:
o At least $395,500 to Nathan J. Mays, Debtor’s criminal attorney, $310,000

of which was transferred post-petition. Exhibit 38.
o At least one medical procedure. Debtor arranged for Michael Longust, the
note holder on the Event Entity property, to receive a hernia surgery in
exchange for forgiveness of Debtor’s indebtedness. Exhibit 35, 42:5–43:3.
o At least $6,429.89 to Klein ISD for 5622 Havenwoods’ property taxes.

Exhibit 17.
o At least $5,723.09 to Klein ISD for 5623 Havenwoods’ property taxes.

Exhibit 17.
o At least $10,586.70 post-petition in slip and other fees to South Shore

Harbor Marina for Debtor’s boat. Exhibit 17
o At least $10,134 post-petition to “My Galveston Getaway.” Exhibit 17.
o At least $33,419.17 post-petition to “Capricorn Travel.” Exhibit 17.
o At least $74,000 post-petition to “M Dream Homes Inc.” Exhibit 17.
o At least $4,319.18 post-petition to “i host poker Houston.” Exhibit 17.

 Transfers from Doctors Hospital Entities for Debtor’s Personal Businesses:
o At least $381,244.34 post-petition to Event Entity from February 3, 2016

until June 6,2018. Exhibit 16.
o At least $38,384.58 post-petition to Michael Longust, in connection with

the purchase of the Bamwood Properties. Exhibit 42.
o At least $109,666 post-petition to Citgo Entity. Exhibit 41.
o At least $114,200 post-petition to and related to the Apartment Entity,

$45,000 of which was for commissions owed to third-parties. Exhibit 18.
o At least $72,236.70 post-petition to Mona Lisa Churrascaria Brazilian

Steakhouse, LLC (“Mona Lisa Churrascaria”), a failed restaurant venture,
which was nominally held by Mona and Raheel. Exhibit 43.
o At least $13,500 post-petition to Cobra Shell, LLC, an entity concerning a

gas station which is nominally held by Ghouse (“Cobra Shell”). Exhibit 44.
101. MOB Entities
 Transfers from MOB Entities for Debtor’s Personal Benefit:
o At least $2,500 post-petition from MOB Entities to Nathan J. Mays,

Debtor’s criminal attorney. Exhibit 38.
o At least $3,500 post-petition for legal fees for Debtor’s father-in-law.

Exhibit 51.
 Transfers from MOB Entities for Debtor’s Personal Businesses:
o At least $354,630.97 post-petition for tax liens on the Apartment Entity

land. Exhibit 18.
o At least $75,000 post-petition for purchasing an ownership in interest in

the Apartment Entity. Exhibit 18.
o At least $34,518 post-petition from MOB Entities to the Citgo Entity.

Exhibit 12.
o At least $2,000 post-petition from MOB Entities to Cobra Shell.

Exhibit 44.

102. Based on the foregoing and without limitation, Trustee asks the Court find Debtor
is the de facto owner of and/or equitable owner of all or a substantial portion of the Business
Entities and their assets and real property.
iii. Alter Ego/Reverse-Veil Piercing
herein.
104. Business Entities (except for the Citgo Entity) are an alter ego of Debtor because
(1) he organized and operated each of them as a “mere tool or business conduit” of himself and (2)
there is such unity between Debtor and the each of the Business Entities that “the separateness” of
each has ceased and failing to find an alter ego relationship would result in injustice. Richard
Nugent & CAO, Inc. v. Estate of Ellickson, 543 S.W.3d 243, 266 (Tex. App.—Houston [14th Dist.]
2018, no pet.).
105. The Fifth Circuit has recognized the following as indicia of an alter ego
relationship: (1) the degree to which corporate formalities have been followed and corporate and
individual property have been kept separately; (2) the amount of financial interest, ownership, and
control the individual maintains over the corporation; and (3) whether the corporation has been
used for personal purposes. Bollore S.A. v. Import Warehouse, Inc., 448 F.3d 317, 325 (5th Cir.
2006. Specific evidence of an alter ego relationship includes: (1) payment of alleged corporate
debts with personal checks or other commingling of funds; (2) representations by the individual
that he or she would financially back the corporation; (3) diversion of company profits for personal
use; (4) inadequate capitalization of the corporation; and (5) other inadequate separation of
corporate and personal assets. In re Schooler, No. 12–32312, 2013 WL 176139, at *4 (Bankr.
S.D. Tex. 2013) (Isgur, J.).

106. The Business Entities did not and do not follow corporate formalities. The Business
Entities did not and do not: (i) keep books and records, (ii) hold annual meetings, (iii) have
financial controls, (iv) abide by conflicted transaction provisions of their own company agreements
and (v) Debtor often acted beyond the authority of the Business Entities’ company agreements to
serve his own interests. Exhibit 46.
107. As detailed above, Debtor regularly commingled funds and diverted funds of the
Business Entities for personal use. There was and is no separation between the Business Entities’
assets and Debtors. In other instances, Debtor used personal funds or funds from other Business
Entities to pay the debt service, tax obligations and real estate transaction costs for other Business
Entities.
108. Debtor’s control over the Business Entities is demonstrated by his own, signed
personal financial statements, the superior authority he has in the Business Entities, Exhibit 46,
and his unfettered access to Business Entities’ bank accounts. Exhibit 6.
109. In multiple instances, Debtor served as a personal guarantor on loans taken by SRM
Entities, Doctors Hospital Entities, and the Event Entity—at least one of these guarantees occurred
while Debtor was in Chapter 7. Exhibit 45.
110. Debtor regularly undercapitalized the Business Entities to maximize the cash flow
at his disposal for personal gain. Exhibit 50.
111. As such, an alter ego finding is necessary to prevent injustice. Trustee asks the
Court to find the SRM Entities, MMAF Entities, Apartment Entity, Event Entity, Doctors Hospital
Entities, MOB Entities and Clinic Entities to be alter egos of Debtor and that Debtor’s interests in
such entities, along with such entities’ assets and real property, are property of the estate. This is
necessary to prevent Debtor from continuing to perpetrate fraud, evade existing legal obligations

and circumventing one or more statutes. SSP Partners v. Gladstrong Inv. (USA) Corp., 275 S.W.3d
444, 454–55 (Tex. 2008).
iv. Sham to Perpetrate a Fraud.
herein.
113. Texas courts take a “flexible fact-specific approach” in determining what
constitutes a sham, but the quintessential scenario includes a debtor with unwanted obligations
who siphons off revenues, sells assets, or otherwise attempts to avoid paying his debts, such as by
starting up a new business. Love v. State, 972 S.W.2d 114, 120 (Tex. App.—Austin 1998, pet.
denied). Establishing “injustice or unfairness” to the Trustee and Debtor’s creditors is sufficient
to warrant application of the sham to perpetuate a fraud doctrine. Sparling v. Doyle, EP-13-CV-
00323-DCG, 2014 WL 12489990, at *7 (W.D. Tex. Oct. 23, 2014); Permian Petroleum Co. v.
Petroleos Mexicanos, 934 F.2d 635, 643 (5th Cir. 1991). Neither fraud nor intent to defraud need
be shown as a prerequisite to disregarding the corporate entity as a sham; it is sufficient if
recognizing the separate corporate existence would bring about an inequitable result. Castleberry
v. Branscum, 721 S.W.2d 270, 275 (Tex. 1986).
114. Here, in using the Business Entities, the Real Estate and the Ownership Interests as
a sham to perpetrate a fraud, Debtor engaged in constructive fraud, which has been defined as “the
breach of some legal or equitable duty which, irrespective of moral guilt, the law declares
fraudulent because of its tendency to deceive others, to violate confidence, or to injure public
interests.” Archer v. Griffith, 390 S.W.2d 735, 740 (Tex. 1964). In addition to all other facts
pleaded herein, Trustee’s extensive discovery and investigation reveals that before and after the
Petition Date, Debtor used the Business Entities as a sham to perpetrate a fraud. For example,

Debtor appears to pick whichever of the MMAF Entities would meet his needs at a given time—
to the consternation of third parties and to obscure his true assets. Exhibit 47. In other instances,
third-party financial institutions have expressed concerns regarding glaring inconsistencies in the
ownership information of company agreements. In response, Debtor either walked away from a
deal or amended the ownership information as directed by counsel for those third-party financial
institutions.
115. Debtor ran SRM Entities, MMAF Entities, Event Entity, Apartment Entity and
Doctors Hospital Entities for the benefit of himself and Debtor’s Family Members. After the
Petition Date, Debtor continued to treat the Business Entities as extensions of himself and used
property of the estate to acquire MOB Entities and Clinic Entities. Having defrauded multiple
creditors out of millions of dollars, Debtor has ample motivation to obscure his true assets in the
names of the Business Entities, Debtor’s Family Members and Debtor’s Associates.
116. Trustee possesses evidence that Debtor, Mahvish, Jennifer and Raheel have been
consistently involved in SRM Entities, MMAF Entities, Event Entity, Apartment Entity, Doctors
Hospital Entities, MOB Entities and Clinic Entities. Debtor directs the actions of Mahvish,
Jennifer and Raheel and they benefit financially from Debtor’s enterprise.
117. In light of Debtor’s conduct, Trustee asks the court to find that Debtor engaged in
a sham to perpetrate a fraud and that the Court disregard the corporate from of SRM Entities,
MMAF Entities, Event Entity, Apartment Entity, Doctors Hospital Entities, MOB Entities and
Clinic Entities and hold that their assets and real property are assets of the estate subject to
administration by the Trustee.

II. Turnover—11 U.S.C. § 542(a)
herein.
119. Pursuant to 11 U.S.C. § 542(a), an entity that is not the Trustee and that is in
possession “of property that the trustee may use, sell, or lease under [11 U.S.C. §] 363” must turn
over and account for such property to the trustee, “unless such property is of inconsequential value
or benefit to the estate.” 11 U.S.C. § 542(a).
120. To the extent the Ownership Interests, Business Entities, Real Property and their
related assets are not in the possession custody or control of the Trustee and are adjudicated as
Debtor’s and subject to the Trustee’s administration in the Bankruptcy Case, the Trustee seeks an
order for the immediate turnover and accounting of such assets to the Trustee.
III. Avoidance of Post-Petition Transfers—11 U.S.C. § 549
herein.
122. Pursuant to 11 U.S.C. § 549 the trustee may avoid a transfer of property of the
estate—that occurs after the commencement of the case.
123. To the extent any of the Ownership Interests, Business Entities, Real Property or
other assets adjudicated as property of the estate and subject to the Trustee’s administration are in
the possession of Debtor’s Family Members, Debtor’s Business Associates, Parker Transfer
Entities, or Tech Brix as a result of post-petition transfers, such transfers were made without
authority. The Trustee asks the Court to void any such transfers.

APPLICATION FOR A TEMPORARY RESTRAINING ORDER AND PRELIMINARY INJUNCTION
herein.
125. The Trustee seeks a TRO against Debtor, his agents, his assigns, Debtor’s Family
Members, Debtor’s Business Associates and any of the Business Entities (the “Enjoined Parties”)
which:
1) freezes14 both, the transfer of or voluntary imposition of liens on
(i) the above-described Real Property, and
(ii) the ownership interests in the Business Entities (the “Ownership Interests”);
2) prohibits both
(i) any transfer of any asset of any of the Business Entities in excess of $5,000
except in the ordinary course of business as allowed by the Court, and
(ii) the alteration, deletion, destruction of any document and/or electronically stored
information (as defined in the Federal Rules of Civil Procedure) or any account of
any of the Enjoined Parties, including communications concerning the Business
Entities;
3) requires Debtor to give the Trustee and his attorneys and agents continuing, real-time
access to the accounting systems and bank information for all the Business Entities in order to
allow the Trustee to monitor those accounts and ensure compliance with this restraining order and
preliminary injunction.
14
For purposes of clarity, “freezes” means that the Enjoined Parties cannot sell, trade, barter, exchange, convey,
rename, dissolve, involve in any business transaction, collateralize, involve in any loan, transfer, hide, abscond,
liquidate, damage, destroy or in any way affect the financial condition of the Real Property and Ownership Interests.
126. The Fifth Circuit utilizes the traditional four-part standard for determining whether
a bankruptcy court should issue an injunction:
1) a substantial likelihood that the movant will prevail on the merits;
2) a substantial threat that the movant will suffer irreparable injury if the injunction is not
granted;
3) a finding that the threatened injury to the movant outweighs the threatened harm an
injunction may cause the party opposing the injunction; and
4) a finding that granting the injunction will not disserve the public interest.
In re Zale Corp., 62 F.3d 746, 765 (5th Cir. 1995).
127. In the present case, the Trustee meets all four standards. As for prevailing on the
merits, the Ownership Interests, Business Entities, and Real Property, to the extent described
above, ultimately belong to Debtor and are property of the bankruptcy estate. After extensive
discovery and analysis of Rule 2004 examinations, bank accounts, and business transactions, the
Trustee marshalled evidence that Debtor owns the Ownership Interests. Indeed, even Debtor
himself claims he owns them. Exhibit 1, at 14–29.
128. Second, there is a substantial threat that the Estate will suffer irreparable injury if
the TRO is not granted. As earlier proceedings found, Debtor elected to destroy evidence instead
of produce it in response to the Trustee’s requests and the Court’s Orders. Exhibit 3. Absent the
TRO, the Trustee believes that the Defendants will act to further interfere with the Trustee’s ability
to administer the bankruptcy estate, including by destroying, or directing others to destroy,
evidence material to the administration of the estate. For example, the Trustee has recently
discovered evidence that Debtor’s Family Members, specifically Mahvish and Jennifer, both
deleted email accounts subject to discovery in this bankruptcy case within 24 hours of learning
that Debtor was being held in custody of the U.S. Marshals for contempt after the Court found
Debtor deleted information and evidence sought by the Trustee. Exhibit 49.
129. Moreover, as evidenced by the demolition of the improved structure at 5638
Selinsky Road, Houston Texas 77048 during this Bankruptcy Case, the Trustee fears further loss
of value if the TRO is not granted. Also, given the frequency of transactions orchestrated by
Debtor during the Bankruptcy Case, Trustee fears the Real Property will be transferred to third-
parties, pledged, or encumbered upon Defendants learning of this Complaint. Trustee also fears
that Debtor, who has spent thousands of dollars on foreign travel during the Bankruptcy Case and
who has multiple connections with Pakistan and India, may abscond with estate assets beyond the
reach of Court if the financial limitations sought in the TRO are not granted.
130. Trustee does not seek to inhibit the normal operations of the Doctors Hospital
Entities and the services they provide to the local community. Instead, Trustee seeks to inhibit the
abnormal activities of Debtor through the Doctors Hospital Entities that inure solely to his personal
benefit, gain, and profit and to prevent further loss to the estate.
131. Third, the balancing of the interests plainly favors the Trustee. The injunctive relief
simply preserves the status quo. All parties rights are adequately protected.
132. Finally, the public interest strongly favors the issuance of the injunction. The
Trustee seeks only to fulfill his obligations (and ensure the estate’s rights) under applicable law.
Public policy supports the TRO, so that the Trustee can administer the estate in attempt to satisfy
the claims of creditors without further interference from Debtor.
BOND
133. Given the nature of Debtor’s conduct demonstrated herein, the short time period
for which the Enjoined Parties will be restrained in light of the extensive discovery and the cost
the Trustee incurred as a result of Debtor’s conduct to date, the Trustee respectfully requests that
the Court, in its discretion, waive, or set a minimal requirement for any bond required in connection
with the issuance of the requested injunctive relief.

REQUEST FOR ATTORNEY’S FEES
134. Pursuant to 28 U.S.C. Sec. 2202, should any one of Debtor’s Family Members or
Debtor’s Associates contest the Trustee’s ownership and assert an interest in any of the Business
Entities, the Trustee seeks an award of attorney’s fees against that person. The Trustee has
significant reason to believe that any such contention would be a continuation of Debtor’s scheme
to hide his assests and pursued in bad faith.15 If any of Debtor’s Family Members or Debtor’s
Associates files a pleading with this Court stating that he or she does not assert an interest in the
Business Entities, the Trustee seeks no monetary relief against such person.
PRAYER
135. The Trustee requests (i) the entry of a declaratory judgment as set forth above; (ii)
turnover of estate property as set forth above, (iii) avoidance of post-petition transfers, and (iv)
the award of attorney’s fees and costs as set forth above; and (v) such other just relief including
the substantive consolidation of the Business Entities in evaluating the foregoing claims for relief.
Dated: April 10, 2019.
Respectfully submitted,
By:/s/ Cameron A. Secord

Bruce J. Ruzinsky
State Bar No. 17469425
Federal I.D. 5037
Matthew D. Cavenaugh
Federal I.D. 1134544
Cameron A. Secord
Email: csecord@jw.com
Gary Yevelev
15
See In re Bigler LP, No. 10-03029, 2011 WL 2420319, at * 7 (S.D. Tex. Bankr. June 9, 2011) (recognizing that 28
U.S.C. § 2202 permits a court to award attorney’s fees in “cases of bad faith, vexation, wantonness, or oppression
relating to the filing or maintenance of the action”); see also W. Heritage Ins. Co. v. Robertson, 224 F.3d 764, No.
99-10924, 2000 WL 992178, at * 3 (5th Cir. June 19, 2000) (unpublished) (holding same).

Email: gyevelev@jw.com
1401 McKinney Street, Suite 1900
Houston, Texas 77010
(713) 752-4342 (Telephone)
(713) 308-4183 (Facsimile)
Scott A. Wheatley
Email: swheatley@jw.com
777 Main Street, Suite 2100
Fort Worth, Texas 76102
(817) 334-7224 (Telephone)
(817) 870-5124 (Facsimile)
Special Counsel for Randy S. Williams,
Chapter 7 Trustee


Bankruptcy Case 15-34752 Petition

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Bankruptcy Case 15-34752 Petition

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Case 19-03434 Document 1 Filed in TXSB on 04/10/19 Page 1 of 40

IN THE UNITED STATES BANKRUPTCY COURT

PALMS APARTMENTS, LLC, §

PLAINTIFF’S VERIFIED ORIGINAL COMPLAINT AND EMERGENCY

THE EMERGENCY APPLICATION FOR TEMPORARY RESTRAINING ORDER

EMERGENCY RELIEF HAS BEEN REQUESTED. IF THE COURT CONSIDERS

REPRESENTED PARTIES SHOULD ACT THROUGH THEIR ATTORNEY.

PLAINTIFF’S VERIFIED ORIGINAL COMPLAINT AND Page 2 of 40

PARTIES AND JURISDICTION

wherever he may be found.

3. Syed Ghouse Mohiuddin a/k/a Ghouse (“Ghouse”) is an individual and brother of

wherever he may be found.

4. Mona Lisa Mohiuddin (“Mona”) is an individual and wife of Debtor residing in

5. Mariya Mohiuddin (“Mariya”) is an individual and daughter of Debtor residing in

6. Syed Amaan Mohiuddin, commonly referred to as Amaan (“Amaan”), is an

Texas 77066, or wherever he may be found.

7. S. A. M., commonly referred to as F. (“F”), is an individual and son of Debtor

PLAINTIFF’S VERIFIED ORIGINAL COMPLAINT AND Page 4 of 40

8. Jennifer Rizvi a/k/a Jennifer Sydenham (“Jennifer”) is an individual residing in

9. Raheel Khan, commonly referred to as Bunty (“Raheel”), is an individual and

Texas 77066, or wherever he may be found.

wherever she may be found.

11. Mahvish Khan (“Mahvish”) is an individual and sister-in-law of Debtor residing in

jointly and individually referred to as the “Debtor’s Family Members.”

PLAINTIFF’S VERIFIED ORIGINAL COMPLAINT AND Page 5 of 40

wherever he may be found.

14. Ravishanker Mallapuram a/k/a Ravi (“Ravi”) is an individual and business

wherever he may be found.

Texas 77584, or wherever he may be found.

PLAINTIFF’S VERIFIED ORIGINAL COMPLAINT AND Page 6 of 40

Rizwan Mohiuddin, or at 5622 Havenwoods, Houston, TX 77066, or wherever Syed Rizwan

Mohiuddin may be found.

5622 Havenwoods, Houston, TX 77066, or wherever he may be found.

77379, or wherever he may be found.

PLAINTIFF’S VERIFIED ORIGINAL COMPLAINT AND Page 7 of 40

77066, or wherever he may be found.

Havenwoods, Houston, TX 77066, or wherever she may be found. Alternatively, M.M.A.F.

service, at 5622 Havenwoods, Houston, TX 77066, or wherever he may be found. MMAF

Havenwoods, Houston, TX 77066, or wherever either of them may be found.

to accept service at 5622 Havenwoods, Houston, TX 77066, or wherever he may be found.

PLAINTIFF’S VERIFIED ORIGINAL COMPLAINT AND Page 8 of 40

Havenwoods, Houston, TX 77066, or wherever he may be found.

Havenwoods, Houston, TX 77066, or wherever he may be found.

PLAINTIFF’S VERIFIED ORIGINAL COMPLAINT AND Page 9 of 40

wherever he may be found.

Turner, at 510 W. Tidwell Road, Houston, TX 77094.

33. Tidwell/Parkway Property Holdings, LP d/b/a Four Star Capital (“TPPH”) is a

Houston, TX 77066, or wherever he may be found.,

PLAINTIFF’S VERIFIED ORIGINAL COMPLAINT AND Page 10 of 40

Houston, TX 77066, or wherever he may be found.

an officer eligible to accept service, at 5622 Havenwoods, Houston, TX 77066, or wherever he

referred to as the “MOB Entities.”

accept service, at 5622 Havenwoods, Houston, TX 77066, or wherever he may be found.

PLAINTIFF’S VERIFIED ORIGINAL COMPLAINT AND Page 11 of 40

Havenwoods, Houston, TX 77066, or wherever he may be found.

and individually referred to as the “Clinic Entities.”

to as the “Business Entities.”

Richmond Ave., Suite 440, Houston, Texas 77057.

Richmond Ave., Suite 440, Houston, Texas 77057.

PLAINTIFF’S VERIFIED ORIGINAL COMPLAINT AND Page 12 of 40

jointly and individually referred to as the “Parker Transfer Entities.”

(b)(2)(B), and (b)(2)(O).

49. Venue is proper in this district pursuant to 28 U.S.C. § 1409(a).

Bankruptcy Rule 7001.