Debtor Reply Affirmation To Aust Gregory Zipes Filed

UNITED STATES BANKRUPTCY COURT
SOUTHERN DISTRICT OF NEW YORK
Inre: Chapter 7
RAHUL DEV MANCHANDA,
Debtor
DEBTOR REPLY AFFIRMATION TO AUST GREGORY ZIPES
TO: THE HONORABLE SEAN H. LANE

UNITED STATES BANKRUPTCY JUDGE
The Debtor, Rahul Dev Manchanda, submits this Reply Affirmation to AUST Gregory Zipes as
follows:
PRELIMINARY STATEMENT
1. Similar to my reaction to AUSA Dana Walsh Kumar's Complaint to Object to Discharge, my
reaction to AUST Gregory Zipes' COMPLAINT OBJECTING TO DEBTOR'S
DISCHARGE drew a similar reaction of sickness to my stomach at the bottom-feeder level
of word manipulation, word salad, con-artistry and tongue twister deception and lies being
lobbed about by this man which truly shocks the conscience. He will also be referred to the
DOJ Office of Professional Responsibility for his behavior herein, and hopefully some
scrutiny will force this man to work on (and perhaps actually develop) some semblance of
a
professional ethics, because he is more akin to a shark then a trustee lawyer to help Debtor
navigate his way out of a thicket and quagmire of bone crushing debt.
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2. Similar to AUSA Dana Walsh Kumar, AUST Gregory Zipes relentlessly and routinely resorts
to outright lies, falsities, half-truths, defamation, slander, verbal abuse, mockery, and libel
throughout his attached (and marked up) pleadlng.
3. We will attempt to point out each and every bit of attorney and government misconduct by
AUST Gregory Zipes in this Reply Affirmation, but they are so numerous and rapid-fire, that
we may have to resort to cut and paste responses as he also tends to repeat his lies and
deception throughout his pleading, as if somehow wishing and hoping that his repeating of
his bald-faced lies will somehow make them true.
SPECIFIC RESPONSES TO AUST GREGORY ZJPES SPURIOUS ALLEGATIONS
4. First, AUST Gregory Zipes "Statement of the Case" is a completely and totally false
statement, echoing the attorney and professional misconduct of AUSA Dana Walsh Kumar,
and he will also be referred to the DOJ Office of Professional Responsibility for
investigation.
5. Yes several extensions later generously afforded to him by the court at Debtor's pain and
expense, nearly 2 years later, to p~oduce nothing but insults, ad hominems and defamation,
slander, and libel.
6. Bankruptcy Lawyer Bruce Bronson stood by his own figures, valuations, and calculations but
to date has refused to turn over my client case file, original documents, valuations, etc even
though I have subpeonaed him 3 times and cc'ed AUST Gregory Zipes since June 2023. I
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don't have the training, expertise, or knowledge to question his bankruptcy law
work/expertise of more than 20 years.
7. I have never been a bankruptcy attorney, only an immigration attorney for 22 years. At
various times prior, I have retained the services of bankruptcy lawyer Julio Portilla and/or
others. So, many previous filings were either erroneous, misguided, or incomplete Iif I even
filed them, as at some point my in-house Of Counsel Atomeys prepared and filed in addition
to Julio Portilla
8. Upon information and belief this was either accidental or filed by Julio Portilla, for what
reason I have no idea
9. We have already filed official complaints regarding Bruce Bronson's misconduct and
behavior, stemming from his alcohol abuse and addiction, anger management issues, which
we expressed to the court.
10. Our bank statement "rushed markings" are subject of course to CPA Michael Arons and
before him CPA Marc Albaum - the last tax return was rushed because although it was due
10/23, AUST Zipes wanted it within a few days in 06/23, so the etchings were rushed - we
later voluntarily amended the return in 10/23.
11. Bruce Bronson did this valuation. with his experts.
12. The accounts receivables are considered non-recoverable as they were already turned over to
a collection agency which only reaped complaints and small claims lawsuits.
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13. The New Rochelle home law office property is a mortgage, not fully owned.
14. We submitted everything to the best of our ability and speed, but were hampered by
document unavailability, slowness of the financial institutions, outright refusals unless we
were Bruce Bronson, and other obstacles within the speed demanded by AUST Gregory
Zipes.
15. Debtor did NOT object to the court ordered subpoe~ so this is a false statement by AUST
Gregory Zipes.
16. We provided everything that we had, or could get. So this is another malicious misstatement
by AUST Gregory Zipes.
17. After a few hours, it was in fact AUST Gregory Zipes who terminated the deposition even
though Debtor begged to continue and finish the process for AUSA Dana Walsh Kumar to
conclude her interrogation, so once again AUST Gregory Zipes lies herein.
18. Debtor had a medical emergency borne out by medical records provided to the court and
AUSA and AUST.
19. Debtor was still absent due to the medical emergency.
20. And a office basement which is exclusively used for law office consultations, legal work,
research, servers, files, etcJ adminimative.
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21. We still do not know what a "Homestead Exemption" is.
22. I work '?n nearly every floor of the home law office.
23. That is a false statement. Any and all recorded information, books, documents, records,
papers are kept either at the home or NYC law office, or with our CPA/Accountant Michael
Arons and previously with CPA Marc Albaum.
24. We fully comply with this.
25. There is no boasting from Debtor, instead that is AUST Gregory Zipes when he boasts on
Linkedln about being an NYU Adjunct Law Professor.
26. Yes and these files are kept/maintained at the NYC law office, home law office, and at our
CPA offices for 7 years.
27. That's a false statement - of course they are available - AUST Gregory Zipes was just simply
too lazy to make an appointment to come and inspect.
28. Now follows AUST Gregory Zipes starting to make an entire rapid-fire blitzkrieg of blatantly
false statements, one after another, so many that we can't even reproduce or comment here,
so we attach/enclose his own pleading with our demarcations denoting where he did it. aaain
and again - Rule 11 Sanctions "safe harbor'' for AUST Gregory Zipes is once against
extended to him in order to correct, recant, or be sanctioned for such serious government
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attorney misconduct - he can not just be allowed to get away with this, unscathed legally and
equitably.
29. We provided whatever we had, or could obtain within the time period given.
30. Even the banks would not release our bank statements from years ago.
31. We have already explained that either we were advised to temporarily move the money from
an illegal lien from NYC HRA, or because of IRS harassment led by AUSA Dana Walsh
Kumar, our law fum bank accounts were periodically closed without warning forcing us to
find a new bank, for many years.
32. That's a false statement. Our cash was always liquid, with no way to determine the source as
we often grossed $50-$150,000 per month during those loan disbursement years, for many
years.
33. As per our attached comments, there are a great many examples of wishful thinking by a very
dirty-minded AUST Gregory Zipes, and only a criminal can think like a criminal - we never
did anything of the sort that he negatively alleges.
34. AUST Gregory Zipes routinely uses the word "apparently" because that's a false statement
and he has no evidence or proof that this was the case - he is a liar and that's a false
statement.
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35. We deducted as business expenses whatever we could deduct, did not deduct what we could
not deduct, per out CPA Michael Arons and prior CPA Marc Albaum.
36. If they were business expenses to either the NYC (we have TVs there too) or home law office
then they are deductible.
37. We turned over/submitted whatever we had in our possession, or whatever we could obtain,
including traveling to those banks personally.
38. Bankruptcy Lawyer Bruce Bronson produced and filed our chapter 7 bankruptcy petition
100%, with minimal input from us as Debtor, as he was the expert of more than 20 years in
bankruptcy law, and we paid him $3500 to do so.
39. The Petition looked fine to me, but I am not a bankruptcy lawyer.
40. As far as my recollection, any and all wet signatures were requested by Bruce Bronson after
he filed the case with electronic signatures.
41. In terms of valuing the law firm at $100, that's what Bruce Bronson and his experts
determined, and why can't we accept his expertise, work product, calculations, as valid?
42. To be honest, I still really don't know how he arrived at that number, but when I asked him
for my client files, original documents, valuations and work product, cc'ed to AUST Gregory
Zipes since June 2023, and even subpoenaed these materials from Bruce Bronson, he ignored
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my multiple requests, all while the court and AUST Gregory Zipes watched and did nothing
to assist.
43. This was liquid capital which was our funds used for a business expense.
44. AUST Gregory Zipes keeps using the phrase "New Rochelle property" but we prefer to use
"Home Law Office."
45. These were all Bruce Bronson's calculations, valuations, numbers and work product.
46. Why (how) would we amend another bankruptcy attorney's work product with 20 years of
experience, Bruce Bronson, whom we paid $3500?
47. In terms of AUST Gregory Zipes crowing on about how on May 16, 2023 the "court
recommended us to amend the schedules" we do not recall this.
48. Why (how) would we amend another bankruptcy attorney's work product with 20 years of
experience, Bruce Bronson, whom we paid $3500 (we needed to repeat this phrase several
times in response to AUST Gregory Zipes innumerable, vacuous, and inane "helpful
comments")?
49. It's true - I generally do not scrutinize, or look at, or pay our bills as the anxiety endangers the
heart attack I had in August 2019, so my Law Office Manager and wife pays all bills,
manages the insurance policies, books, etc.
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50. At one point. in AUST Gregory Zipes number 135, and after having received milli~ns of
pages of financial documents, credit card statements, bank statements, tax returns, profits and
loss, contracts, insurance policies, and 100s more financial documents over nearly half a
decade, which he and his taxpayer funded team bas been allowed to scrutinize with a
magnifying glass for nearly 2 years, he states "Debtor's finances remain opaque," but this is
because AUST Gregory Zipes and his team are, quite frankly, stupid and obtuse - even after
receiving and reviewing all requested :financial documents, records, statements, tax returns,
AUST Gregory Zipes still calls "Debtor's :finances remain opaque." The only thing that is
"opaque" is AUST Gregory Zipes brain. The AUST's inherent stupidity should not be used
against the Debtor.
51. Contrary to AUST Gregory Zipes latest ad hominem stupid comment. there bas been plenty
of "belt-tightening."
52. In response to AUST Gregory Zipes' constant kvetching about the mistakenly prepared/filed
BMW Reaffirmation Agreement, we have already stated countless times that we already
explained, that Bruce Bronson and BMW told us to fill this out, it was never approved, and
was a "trap" set up by Bronson and BMW.
WHEREFORE, for the above referenced reasons, Debtor respectfully requests the following relief
on his Petition:
(a) on Count One of AUST Gregory Zipes' Complaint. an order approving the Debtor's discharge
pursuant to Bankruptcy Code §727(a)(3);
(b) on Count Two of AUST Gregory Zipes' Complaint, an order approving the Debtor's discharge
pursuant to Bankruptcy Code§ 727(a)(4);
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(c) on Count Three of AUST Gregory Zipes' Complaint, an order approving the Debtor's discharge
pursuant to Bankruptcy Code§ 727(a)(5); and
(d) for such other and further relief as the Court may deem just and proper.
Dated: 3/29/24
Respectfully submitted,
RAHUL DEV MANCHANDA

Pro Se Debtor
270 Victory Boulevard

New Rochelle, NY 10804
Telephone: (212) 968-8600
Email: rdm@manchanda-law.com
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WILLIAM K. HARRINGTON
United States Trustee for Region 2
U.S. Department of Justice
Office of the United States Trustee
One Bowling Green, Room 534
New York, New York 10004
Tel. (212) 510-0500
By: Greg M. Zipes, Esq.
Trial Attorney
UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF NEW YORK
----------------------------------x
Inre
Chapter7
Case No. 23-22095 (SID,)
Debtor.
---------------------------x
WILLIAM K. HARRINGTON,
as United States Trustee for Region 2,
Adv. Case No. 24 - _
Plaintiff,
-against-
Defendant.
---------------------------x
COMPLAINT OBJECTING TO DEBTOR'S DISCHARGE
PURSUANT TO 11 U.S.C. §§ 11 U.S.C. 727(a)(3), 727{a){4){A) AND 727(a)(5)
William K. Harrington, the United States Trustee for Region 2 (the "United States
Trustee," or the "Plaintiff''), by and through the undersigned attorney, objects to the discharge of
the debts ofRahul Dev Manchanda (the "Debtor" or the "Defendant") pursuant to 11 U.S.C. §§
727(a)(3), 727(a)(4)(A) and 727(a)(5) and, in support thereof, respectfully alleges as follows:
23-22095-shl .Doc 117 Filed 03/25/24 Entered 03/25/2412:45:44 Main Document
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STATEMENT OF THE CASE
By this adversary proceeding, the United States Trustee objects to the discharge of the
Debtor, pursuant to 11 U.S.C. §§ 727(a)(3), (aX4) and (a)(S). The Debtor, an attorney, is the
sole proprietor ofManchanda Law Offices, PLLC. As shown below, the Debtor has both This is a
completely and
acquired expensive assets and incurred significant debt, but when questioned and asked to totally false
sta
produce information regarding those assets and liabilities, he has concealed, falsified and failed te~nt,
echomgthe
to keep or preserve information from which his financial or business transactions might be attorney and
professional
ascertained, provided false oaths or accounts, and failed to satisfactorily explain any deficiencymisconduct of
AUSADana
of assets to meet his liabilities. Walsh Kumar, and
PARTIES
he will also be
referred to the
1. The Plaintiff, William K. Harrington, is the United States Trustee for Region 2 DOJ Office of
Professional
with offices located at One Bowling Green, Room 534, New York, NY 10004. United States Responsibility for
investigation.
Trustees are officials of the Department of Justice appointed by the Attorney General to
supervise the administration,of bankruptcy cases and trustees. See, generally, 28 U.S.C. §§ 581-
589.
2. Marianne T. O'Toole, Esq. (the "Chapter 7 Trustee") is the Chapter 7 trustee in
this case under 11 U.S.C. § 702(d).
3. Rahul Dev Manchanda is the Debtor in the above captioned case ("Manchanda"
or "Debtor").
4. According to the Petition, the Debtor lives at 270 Victory Blvd., New Rochelle,
NY 10801 (the ''New Rochelle Property").
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JURISDICTION, VENUE, AND STATUTORY PREDICATES FOR RELIEF
5. The United States Trustee possesses standing to pursue his complaint and
application under 11 U.S.C. §§ 307 and 727(c)(l).
6. This Court has jurisdiction pursuant to 28 U.S.C. §§ 157 and 1334 and the
"Standing Order of Referral of Cases to Bankruptcy Judges" of the United States District Court
for the Southern District of New York, dated July 10, 1984 (Ward, Acting CJ.). This cause of
action constitutes a core proceeding as defined by 28 U.S.C. § 157(b)(2)(J). •
7. The statutory and other predicates for the relief sought herein are 11 U.S.C.
§§ 105(a), 541, and 727, and Federal Rules of Bankruptcy Procedure ("Bankruptcy Rules")
4004(a) and 7001.
8. Venue is proper pursuant to 28 U.S.C. § 1409(a).
9. This Complaint is timely filed as the deadline for filing a complaint objecting to Yes several
extensions later,
discharge was extended through and including March 25, 2024, by an order entered on January nearly 2 years to
17, 2024 pursuant to Federal Rule of Bankruptcy Procedure 4004(b). See Bankruptcy Case No. p~uce nottiing
but insults, ad
23-22095 (SHL) (the "ECF Doc."}, ECF Doc. No. 111. hominems and
defamation,
slander and libel.
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ALLEGATIONS COMMON TO ALL COUNTS
A. Procedural History
10. On February 4, 2023 (the "Filing Date"), the Debtor commenced a bankruptcy
case by filing a voluntary petition (the "Petition"). ECF Doc. No. 1.
11. On the Filing Date, the Debtor also filed certain schedules of assets and liabilities
(the "Initial Schedules"). Id.
12. On February 16, 2023, the Debtor filed schedules of income and expenses, and on
March 8, 2023, the Debtor filed an amended version of the Initial Schedules (together, as may be
amended, supplemented, or modified, the "Schedules"). ECF Doc. Nos. 5, 13.
13. The Debtor also filed a chapter 7 statement of current monthly income and means
test calculation (Form 122A-1) (the "Means Test Form") on February 16, 2023. ECF Doc. No.
6.
14. The Debtor filed a statement of financial affairs, to which an amended version
was filed on February 25, 2023 (as may be further amended, supplemented, or modified, the
"SOFA"). ECF Doc. No. 10.
15. The Debtor testified under oath or penalty of perjury at the meeting of creditors
and equity security holders mandated by 11 U.S.C. § 341 that was held telephonically on March
9, 2023 (the "Creditors' Meeting") (relevant portions of a transcription of the Creditors' Meeting
are attached as Exhibit C hereto).
16. At a hearing held on May 16, 2023, the Court advised the Debtor that he could
further amend the Schedules or SOFA if the Debtor believed they needed amendments:
So, I do understand Mr. Manchanda's comment that he didn't prepare the Petition and
that the $100 [value of the law firm] is Mr. Bronson's number. I can understand that.
And so what I think I would suggest of Mr. Manchanda is to take a look at the
bankruptcy filing, the Petition and the schedules. Get yourself familiar with them. And
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Pg 5 of 22
if they need to be amended to reflect what you think is proper, then you should do that. Bankruptcy
And the idea is to get information and transparency. So if the number you think Mr. Lawyer Bruce
Bronson chose is incorrect, you should change that number and amend the schedules and Bronson stood
information. by his own
ECF Doc. No. 43, May 16 Tr. at 44:6-15. figures,
calculations but
17. Following the Court's statements on May 16, 2023, the Debtor has made no to date has
refused to tum
further amendments to the Schedules or SOFA. over my client
case file, original
18. By orders signed on May 25, 2023 and June 1, 2023, respectively, the Court
documents,
extended the deadline for the United States Trustee and/or the Chapter 7 Trustee to file a valuations etc
even though I
complaint objecting to the Debtor's discharge or a motion to dismiss or convert this case to have
subpeonaed him
September 8, 2023. ECF Doc. No. 44, 45. 3 times and
19. By order signed October 11, 2023, the Court further extended the deadline for the cc'ed AUST
Gregory Zlpes
United States Trustee and/or the Chapter 7 Trustee to file a complaint objecting to the Debtor's since June
2023.1 dont
discharge or a motion to dismiss or convert this case to January 9, 2024. ECF Doc. No. 76. have the
training,
20. By order signed January 17, 2024, the Court further extended the deadline for the rtise
expe or
United States Trustee and/or the Chapter 7 Trustee to file a complaint objecting to the Debtor's knowledge to
question his
discharge or a motion to dismiss or convert this case to March 25, 2024. ECF Doc. No. 111. work/expertise.
B. The Debtor's Prior Bankruptcy Filings
21. On October 4, 2011, the Debtor filed a voluntary petition prose under Chapter 7
of the Bankruptcy Code. Case No. 11-14666-smb. This case was dismissed on January 8, 2012.
No. 11-14666, ECF Doc. No. 33. I have never been a bankruptcy attorney, only an immigration attorney. At various
time~prior I have retained the services of bankruptcy lawyer Julio Portilla and/or
22. On September 3, 2ilJ?~,Jfegl?fWJR§ ~~dM~Bg ilfBNdH~S~ ~~~j,~
Bankruptcy Code. Case No. 13-12880-mg. In this case, the Debtor's oblilzations were
discharged through the Chapter 7 process on January 13, 2014. No. 13-12880, ECF Doc. No. 64.
5
Pg 6 of 22
23. Less than four months later, on April 30, 2014, the Debtor filed a third petition, Upon information
and belief this was
this time under Chapter 13 of the Bankruptcy Code. Case No. 14-11259-jlg. The Debtor's
either accidental
or filed
by Julio
petition was dismissed on January 7, 2015. No. 14-11259, ECF Doc. No. 32.
Portilla, for what
24. One year later, on January 29, 2016, the Debtor filed another Chapter 13 petitiot@Sson I have no
Idea.
Case No. 16-10222-jlg. The Debtor's petition was dismissed on January 27, 2017. No. 16-
10222, ECF Doc. No. 187.
C. The Debtor's Representation by Mr. Bronson in this Case
25. The Debtor was represented in the bankruptcy case by H. Bruce Bronson, Esq.,
Bronson Law Offices, P.C., 480 Mamaroneck Avenue, Harrison, NY 10528. ECF Doc. No. 1.
26. Approximately one month after the Filing Date, Mr. Bronson filed an application we have
to withdraw as counsel to the Debtor, citing the Debtor's "negative comments" and alleging that al~dy filed
official
the Debtor "deprecate[d his law] Finn" and "questioned [the] Finn's integrity and morality." complaints
regarding
ECF Doc. No. 18. Bronson's
misconduct and
27. The Court granted Mr. Bronson's application to withdraw as counsel, and he was behavior,
stemming from
thus discharged of his responsibilities as the Debtor's counsel by order signed April 20, 2023.
his alcohol
ECF Doc. No. 32. abuse and
addiction, anger
D. Substance of the Debtor's Petition and Schedules as Amended management
issues, which
28. The Debtor's debts are primarily consumer debts, as defined in 11 U.S.C. §
we expressed
101(8). See Petition, ECF Doc. No. 1. to the court.
29. Per the Schedules, the Debtor is a duly licensed attorney currently employed by
Manchanda Law Office PLLC. Schedule I, ECF Doc. No. 5.
30. The Debtor owns 100 percent of Manchanda Law Office PLLC (the "Manchanda
Law Finn"). See Schedule A/B, ECF Doc. No. 13; and Manchanda Law, No. 11-15837, ECF
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Pg 7 of 22
Doc. No. 27, Memorandum Endorsement and Order Denying Contempt Motions and Enjoining
Further Filings Except in Accordance with This Order, at 1 ("The debtor is a law finn, and
Manchanda is the principal attorney and the sole member.").
31. At the Debtor's initial examination pursuant to Bankruptcy Rule 2004 held on
September 20, 2023 (the "September Examination'1, the Debtor testified, "I got an A+ in
Stephen Zorn's law class. Stephen's role was a senior partner at Sullivan and Cromwell in the
tax department, and he actually asked me to do his tax return". Ex. A (relevant portions of
transcription of September Examination) at 18:6-11.
32. At the continued examination pursuant to Bankruptcy Rule 2004 held on January
25, 2024 (the "January Examination"), the Debtor further testified, "I took tax law in school, I
got an A plus, I worked with Senior Cromwell, I got an A plus, so good that he wanted me to do
his tax returns." Ex. B (relevant portions of transcription of January Examination) at 16:17-19.
33. The Debtor is generally ~amiliar with the finances of the Manchanda Law Finn.
34. The Debtor personally has marked certain personal bank statements with
notations indicating his belief that certain items on those personal bank statements were business subject of
course to CPA
expenses. See Ex. B, Jan. 2024 Transcript, at 49:9-12.
Michael Arons
35. On his SOFA, the Debtor lists "gross', business revenue during the roughly one- and before him
CPA Marc
month period of January 1, 2023 through the Filing Date in the amount of $4,500. See SOFA, Albaum-the
last tax return
Question 2. The Debtor also lists gross business revenue for the prior year, 2022, as $52,000. was rushed
because
Id. And the Debtor lists gross business revenue for 2021 as $51,999. Id.
although it was
36. The Debtor values his sole proprietorship in the Manchanda Law Finn at $100. due 10/23,
AUST Zlpoe
See E'C:P Doo. No. 13 , SQh, ND at 4 • Bruce Bronson did this valuation, with his experts. wanted it within
a few days in
06/23, so the
etchings were
rushed-we
7 later voluntarily
amended the
return in 10/23.
Pg 8 of 22
37. In the recent bankruptcy case ofManchanda Law Office PLLC, No.23-11805 These accounts
receivables are
(SHL), which the Debtor filed prose on November 13, 2023, the Debtor listed accounts
considered non-
receivable on behalf of the Manchanda Law Finn with a "Current" value of $253,217. See No!ecoverable as
they were already
23-11805, ECF Doc. No. 1 (Sch. AIB, Question 11). turned over to a
collection agency
38. On Schedule I in this case, the Debtor states that his net monthly income from which only reaped
nd
"rental property and from operating a business, profession, or farm," is $4,250. See ECF Doc. complain~s a
• small claims
No. 5, Sch. I. According to the Debtor, after including the income of"Debtor 2 or non-filing lawsuits.
spouse," his total monthly income is $7,527.53. Id.
39. The Debtor's claimed monthly net expenses are $7,535.00. See ECF Doc. No. S,
Sch. J. This figure includes two monthly car payments - one that costs the Debtor $624 each
month, and one that costs the Debtor $771 per month- and $1,200 each month for food and
housekeeping supplies. Id.
40. This results in a claimed monthly deficit of$7.47. See ECF Doc. No. S, Sch. J
(Item 23c).
41. The Debtor has scheduled total assets of $871,601, including: (i) the New This is a
mortgage, not
Rochelle Property valued at $845,265, (ii) a 2018 BMW 320i valued at $11,336, (iii) household fully owned.
goods and furnis~ings valued at $5,000, (iv) electronics valued at $2,000, (v) clothes valued at
$2,000, (vi) jewelry valued at $300, (vii) cash on hand of $5,800, and (xiii) the full ownership of
the Manchanda Law Firm valued at $100. See ECF Doc. No. 13, Sch. A/B.
42. The Debtor testified under oath or penalty of perjury at the March 9, 2023
Creditors' Meeting.
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Pg 9 of 22
43. According to the Debtor's testimony at the Creditors' Meeting, the New Rochelle
Property was purchased by the Debtor and his wife on or about July 6, 2022. See Ex. C
(Creditors' Meeting Tr.); at 8:3.
44. "Quontickbk" is listed as the secured creditor of the New Rochelle Property, and
this debt was incurred on ''2022-07." See ECF Doc. No. 1, Sch. D (Item 2.4). 1
45. The Debtor has scheduled $1,501,230 in total liabilities. See, ECF Doc. No. I,
Sch. D.
46. The Debtor has scheduled secured debt in the total amount of $835,055, including
a mortgage of$661,950 and an Internal Revenue Service claim of$122,957. Id.
47. The Debtor scheduled unsecured debt in the total amount of $666,175, including a
loan of$500,00a2 from the Small Business Administration (the "SBA") and student loans of
$145,184. See ECF Doc. No. 13, Sch. F.
E. The United States Trustee's Application Pursuant to Bankruptcy Rule 2004
48. On April 20, 2023, the United States Trustee filed an application (the "2004
Application") pursuant to Bankruptcy Rule 2004, directing the Debtor to produce certain
documents and to appear for an examination to answer any and all questions relating to the acts,
conduct or property or to the liabilities and financial condition of the Debtor, or to any matter
which may affect the administration of his bankruptcy estate, or to his right to a discharge. See
ECF Doc. No. 30.
49. Over the objection of the Debtor (ECF Doc. No. 27), the Court entered an order
granting the United States Trustee's 2004 Application on June I, 2023 (the "2004 Order"). See
ECF Doc. No. 45.
1Although the Debtor amended certain schedules, he has not amended Schedule D.
2
In his Schedules, the Debtor left blank the date he incurred this debt. See ECF Doc. No. 13, Sch. D.
9
50. Pursuant to the 2004 Order, the Debtor was required to produce certain
documents and information to the United States Trustee within 21 days from the date of entry of
the 2004 Order (i.e., no later than June 22, 2023).
51 . In a rolling production, the Debtor produced some, but not all, of the documents
We submitted
everything to the
required pursuant to the 2004 Order, on the following dates: May 30, 2023; June 24, 2023; July best of our
ability and
18, 2023; and August 6, 2023.
speed, but were
52. A chart showing the documents produced by the Debtor is attached hereto as hampered by
document
Exhibit D (the "Document Production Chart"). unavailability,
slowness of the
53. The Document Production Chart was sent to the Debtor for review and approval financial
institutions,
on August 1, 2023, over seven weeks in advance of his scheduled examination. See Exhibit E,
outright refusals
attached hereto. unless we were
Bruce Bronson,
54. Before his scheduled September Examination, the Debtor did not provide any and other
obstacles within
comments or changes to the Document Production Chart.
the speed
Debtor did NOT object 55. On December 12, 2023, over the Debtor's objection, the Court authorized the demanded by
AUST Gregory
to the court ordeted s~booena, so this is a false statement by AUST Gr~gol"',l. Zioes.
d. tl fro TD Bank, NA
umtea States to subpoena mtormation about the Dem:ot' s finances tree y m .,llpes.
Citibank, N.A., and M&T Bank. See ECF Doc. No. 93 (the "Subpoena Order'').
56. In its application for the Subpoena Order, the United States alleged that "[t] he
bank statements the Debtor has produced to date are incomplete, and the Debtor has not provided we provided
everything that
sufficient documentation relating to the $500,000 SBA loan that his law firm received or about
we had, or
the source of the funds he used to purchase his home in July 2022." See ECF Doc. No. 80 could get. So
this Is another
(Introduction). malicious
by AUST
Gregory Zipes.
Pg 11 of 22
F. The Debtor's Examination
57. At the Debtor's request, the September Examination took place via Zoom and not
in person. Present at that remote examination were counsel to the United States Trustee and an
Assistant United States Attorney who represented the SBA and the Internal Revenue Service.
58. During the September Examination, the Debtor testified under penalty of perjury.
59. The Debtor's examination began but had to be adjourned at the request of the After a few hours, it
was in fact AUST
transcriber. Ex. A, Sept 2023 Tr., at 90:23-25; 91: 1-25; and 92: 1.
Gregory Zipes who
60. At such time, counsel to the United States Trustee and the Assistant United st!S'lnated th e
deposition even
Attorney indicated that they had not completed asking the Debtor questions. Ex. A, Sept. 20lBough Debtor
begged to continue
Tr., at 89:24-90:4, and 90:9-12. and finish the
process after AUSA
61. The Debtor agreed to a continuation of his examination in-person at the
Dana Walsh Kumar
Courthouse on November 6, 2023. concluded her
interrogation, so
62. However, the Debtor did not appear at the examination on November 6, 2023.once again AUST
Debtor had a medical emergency borne out by medical records provided to the court and AUSA and AUST. •.
Gregory Zipes hes
See ECF Doc. No. 84, Nov. 7 Tr. at 3-4:8. herein.
63. The Debtor also failed to appear at a Zoom conference scheduled to consider
discovery issues ·and held on November 7, 2023. Id. Debtor was still absent due to the medical emergency.
64. The Debtor,s continued examination took place on January 26, 2024.
G. The Debtor's Use of the New Rochelle Property
65. The New Rochelle Property has three bedrooms and a kitchen. Ex. B, Jan. 2024 And a office
basement which
Tr., at 7: 1-4.
is exclusively
66. The Debtor claims a homestead exemption of $179,975 for the New Rochelle used for law
office
frV~liJt ~ u~r DUL. ~O. D, ~~n. (. We do not know what this is. consultations,
legal work,
research,
servers, files,
etc,
11 administrative.
Pg 12 of 22
67. The Debtor testified that, "[he] used [the New Rochelle Property] exclusively - I work on nearly
every floor of the
[he] would say 90 percent of the property [is used] - for meeting with clients, working on home law office.
clients' cases, doing legal research". Ex. A, Sept. 2023 Tr. at 12:17-21.
68. When Plaintiff's counsel asked the Debtor to confirm that it was his testimony
that 90 percent of the New Rochelle Property is used for business, the Debtor responded:
"Yes. Yes."
~ Sept. 2023 Tr., 14:14.
COUNT ONE
Denial of Discharge Pursuant to 11 U.S.C. § 727(a)(3)
(Failure to Maintain Books and Records)
69. The United States Trustee re-alleges and incorporates the allegations contained in
paragraphs 1 through 68.
70. Section 727(a)(3) of the Bankruptcy Code provides:
(a) The court shall grant the debtor a discharge, unless-...
(3) the debtor has concealed, destroyed, mutilated, falsified, or failed to keep
or preserve any recorded information, including books, documents, records, and
papers, from which the debtor's financial condition or business transactions might be
ascertained, unless such act or failure to act was justified under all of the
circumstances of the case.
11 U.S.C. § 727(a)(3).
71. The Debtor failed to keep or preserve recorded information, including books, That Is a false
statement. Ally
documents, records, and papers, from which the debtor's financial condition or business
and all recorded
transactions might be ascertained. Information, books,
documents,
72. To satisfy his recordkeeping obligations, the Debtor must produce records that records, papers
are kept either at
provide stakeholders with enough information "to ascertain [the Debtor's] financial condition the home or NYC
law office, or with
out CPA/
Accountant
Michael Arons and
12
previously with
CPA Marc Albaum.
Pg 13 of 22
and to track his financial dealings with substantial completeness and accuracy for a reasonable we fully comply
with this.
period past to present." In re Zarling, 628 B.R. 624,636 (Bankr. N.D. Ill. 2021).
73. Furthennore, the adequacy of a debtor's record-keeping is considered in relation
to the debtor's occupation, education, experience, and sophistication. In re Strbac, 235 B.R. 880
(B.A.P. 6th Cir. 1999).
74. The Debtor, who has boasted about receiving an A+ in tax law coursework as a No boasting,
that is AUST
law student, is a sophisticated lawyer who knows how to maintain and safeguard books and
Gregory Zipes
records, knows how to use such records, and knows the importance of maintaining such records. when he boasts
on Llnkedln
75. New York Professional Conduct Rule 1.15(d) provides that "a lawyer shall about being an
NYU Adjunct
maintain for seven years after the events that they record: the records of all deposits in and Law Professor.
withdrawals from[ ...] any other bank account that concerns or affects the lawyer's practice of
law .. .'' N.Y. R. Profl Cond. l.15(d) (2017) (emphasis added). Yes and these files are kept/maintained at the
. . NYC law office, honwJaw office, and at our CPA
76. Tots Rule specifies further that "these records shall S])Ccitically 1<lenui:y tne date,
offices for 7 years.
source and description of each item deposited, as well as the date, payee, and purpose of each
withdrawal or disbursement ..." Id
77. The Debtor is the sole proprietor of the Manchanda Law Firm.
78. For all these reasons, the standard imposed on the Debtor by 11 U.S.C. §
727(a)(3) is higher than the standard that would be imposed on an unsophisticated debtor.
79. The Debtor did not maintain his books and records in a format that a third party That's a false
statement - of
could easily review.
course they are
80. The Debtor did not maintain his law firm·•s books consistent with the New York available • AUST
Gregory Zlpes
Rules of Professional Conduct. was just simply
too lazy to make
an appointment
to come and
inspect.
13
Pg 14of 22
81 . The Debtor maintained scattered bank statements and no ledger reflecting either That's a false
his business or his personal expenditures. statement.
82. The United States Attorney subpoenaed Debtor's business and personal bank
We provided
accounts and sent copies of what was received to the Debtor and the United States Trustee. whatever we had,
or could obtain
Even the banks would 83. It.was only after the Debtor's bank records were subpoenaed that significant within the time
not release our .bank statement$. from-veal'$...aao. . . . period given.

financial activities onne Uel>tor and his business were discovered.
84. The bank statements and other financial records obtained through the subpoenas That's a false
statement.
confirm that the Debtor hid, or failed to keep records of, significant transactions.
85. The bank statements and other financial records obtained through the subpoenas
were documents that fell within the scope of the 2004 Order.
86. For example, a "Universal Withdrawal" receipt from the Manchanda Law Firm we have already
explained that
M&T account on July 6, 2022, within one year of the Filing Date, shows a $180,157.27
either we ere
withdrawal (the "$180,157.27 Withdrawal"). advised to move

the money from
87. Because the "Universal Withdrawal" came from a business account and was usechn illegal lien
from NYC HRA,
to pay for the house, the document is both a business and personal record of the Debtor. or because of the
That's a false statemen&8. Also, the "Universal Withdrawal" document reflected a material transaction of IRS led by AUSA
Dana Walsh
Our cash was always liquid, with no way to determine source as we often grossed $50-150,000 per month for years.
this Debtor. That is because the Debtor used the $180,157.27 Withdrawal for the closing costs Kumar our bank
accounts were
and/or down payment of his personal home, the New Rochelle Property. See Jan. 26 Tr. at 118·perlodlcally
closed without
119. This is wishful thinking by a very dirty-minded AUST Gregory Zipes.
warning forcing
us to find a new
89. As typified by the $180,157.27 Withdrawal, the Debtor concealed assets and
bank.
income by paying for personal expenses through business accounts. Only a criminal can think like a criminal . we
. . nev.er did.amdhino of the sort.
90. The Debtor apparently used busmess loans he obtainea trom the Uovemment to
pay for his personal home and other personal expenses. AUST Gregory Zipes uses the word w8 pparently" because
That's a false statement and he has no evidence r proof tha1
this was the case - he is a liar and That's a false statement.
14
Pg 15 of 22
91. The Debtor concealed assets and income by failing to tum over documentation That's a false
statement.
relating to the $180,157.27 Withdrawal.
92. In addition, the Debtor or his wife used the Debtor's law firm business accounts That's a false
statement.
frequently to pay for personal expenses, including:
(a) two purchases at a jeweler, Swarovski 182 (Manchanda Law Office PLLC We deducted as
Citi Account ending 3516) (Mar. 10, 2020 and Dec. 31, 2020); business
(b) purchases at wine and liquor stores (Citi Account ending 3516) (Mar. 24, expenses
~; ~~~~
(c) a purchase at athletic outfitter Adidas (Citi Account ending 3516) (June 3,
2020); deduct, did not
(d) expenses paid to doctors, emergency medical services, and urgent care centcitduct what we
(Citi Account ending 3516, Manchanda Law Office PLLC TD Account could not deduct,
ending 5143, and Manchanda Law Office, M&T Account ending 2686) ( J ~ our CPA
23, 2020, Apr. 20, 2020, Oct. 22, 2020, Oct. 26, 2020, Oct. 27, 2020, Oct. 21.1ichael Arons and
2020, Feb. 25, 2021, June 9, 2022); and . CPA M
(e) family portraits (M&T Account ending 2686) (Aug. 17, 2022). pnor arc
Albaum.
93. Further complicating matters, the Debtor claimed that certain expenses on a non-
business bank account, among others, were in fact business expenses, including the following:
(a) A payment of $19.95 to television streaming service Netflix; If they were business
(b) A payment of $352. 76 to clothing and accessories store Coach, Inc.; and expenses to either
(c) A payment of $325 to Green Village Landscaping, Inc. the NYC (we have
94. The Debtor's acts as outlined above have the effect of concealing, destroying:"8 th ere too) or
home law office then
mutilating, falsifying and/or failing to keep or preserve recorded information, including boob,y are deductible.
documents, records, and papers, from which the debtor's financial condition or business
transactions might be ascertained. That's a false statement.
95. As stated, the Debtor did not tum over bank statements showing significant We turned over/
submitted whatever
business activities, and these were instead obtained through subpoenas.
we had in our
96. In a rolling production, the Debtor produced some, but not all, of the docum~ssion, or
whatever we could
required pursuant to the 2004 Order, on the following dates: May 30, 2023; June 24, 2023; .bdjlin, including
traveling to those
18, 2023; and August 6, 2023. banks personally.
15
Pg 16 of 22
97. The Document Production Chart shows that the Debtor turned over no That's a false
• c. •
m1onnation •
m •
connection wi"th certain
• categones
• of documents requested by the Um"ted States statement.
Trustee and the United States Attorney's office, and less than complete infonnation in other
categories.
98. Such acts or failures to act are not justified under the circumstances of the case.
99. The foregoing constitutes grounds to deny the Debtor's discharge under 11 U.S.C. That's a false
statement.
§ 727(a)(3).
COUNT TWO
Denial of Discharge Pursuant to 11 U.S.C. § 727(a)(4)(A)
(FALSE OATH)
I 00. The United States Trustee re-alleges and incorporates the allegations contained in
(a) The court shall grant the debtor a discharge, unless-...
(4) the debtor knowingly and fraudulently, or in connection with the case---
(A) made a false oath or account;
11 U.S.C. § 727(a)(4).
102. The Debtor knowingly and fraudulently made several false oaths or accounts That's a false
• and •m connection
durmg • wt"th the case, most sigru • • Schedules, and SOFA. statement.
• ·r.icantly on h.is Petition,
16
Pg 17 of 22
103. The Debtor signed the Petition, Schedules, and SOFA, certifying under penalty of Bankruptcy
Lawyer Bruce
perjury that he examined these documents and that the information contained therein was true Bronson
produced and
and correct ECF Doc. Nos. 1, 5, 10, 13.
filed our
104. A. debtor's signature on a petition "has the force and effect of an oath." Cepelak chapter 7
bankruptcy
v. Sears (In re Sears), 246 B.R. 341, 347 (B.A.P. 8th Cir. 2000). petiton 100%,
with zero input
105. The Debtor testified under oath or penalty of perjury at the March 9, 2023 from us as
Creditors' Meeting. Debtor, as he
was the expert
106. It is ''well established" that statements made by a debtor at a creditors' meeting and we paid
him $3500to
constitute "oaths" for the purposes of 11 U.S.C. § 727(a)(4). In re Korte, 262 B.R. 464,471 doso.
(B.A.P. 8th Cir. 2001).
107. At the Creditors' Meeting, the Debtor acknowledged that he had reviewed the
Petition, Schedules, and SOFA. See Ex. C (Creditors' Meeting Tr.) at 5. They looked fine to me, but I am not a
bankrupt~ lawyer.
108. On September 22, 2023, the Debtor's former bankruptcy counsel, Bronson Law
Offices P.C., provided the United States Trustee's Office with a copy of the Debtor's original
signature pages to his Petition, Schedules, and SOFA. This document'is attached hereto as As far as my
recollection, any and
Exhibit F.
all wet signatures
109. As an attorney who has experience in the bankruptcy arena, the Debtor knowlttB requested by
Bruce Bronson after
he cannot simply rely on others in valuing .his law firm on his Schedules and must conduct hee filed the case with
electronic signatures.
own due diligence when reviewing the information on his Schedules and SOFA. Why not?
110. The Debtor's statement valuing the Manchanda Law Firm at $100 in his
Schedules and SOFA was made under penalties of perjury. That's what Bruce Bronson and his experts determined.
111. The Debtor testified that he did not know why the Manchanda Law Finn was
valued at $100 in his Schedules and SOFA. I still really don't know how he arrived at that number, but when I
asked him for my client files, original documents, valuations and work
product, cc'ed to AUST Gregory Zipes since June 2023, and even
subpNlnaed these mat~rials from Bruce Bronson, he ignored my
multiple requests, all while the court and AUST Gregory Zipes watched
and did nothing to assist.
Pg 18 of 22
112. ·The Debtor's failure to investigate the basis for the value of his law finn at the That's a false
statement.
very least represented a reckless indifference to the truth.
113. Statements made with "reckless indifference to the truth" can be ''regarded as That's a false
statement.
intentionally false". In re Charles, 474 B.R. 680,684 (Bankr. 8th Cir. 2012).
114. The Debtor's failure to investigate the value of his law firm is especially glaring That's a false
statement.
because the Manchanda Law Firm had significant revenue in the years prior to the Filing Date.
115. For example, in 2018, the Debtor stated in a bank account application that the That's a false
statement.
Manchanda Law Finn had annual gross revenue of $1 million and had an annual net profit of
$100,000.
116. Also, on July 6, 2022, within one year of the Filing Date, the Debtor or his wife This was liquid
capital which
made the $180,157.27 Withdrawal from the M&T BankManchanda Law Office account to pay
was our funds
for the New Rochelle Property. Home Law Office used fora
business
117. The $180,157.27 that was transferred from the Manchanda Law Office account expense.
was an asset of the Manchanda Law Firm. And used for a Home Law Office
118. By way of further example that the Manchanda Law Firm should not have been
valued at $100 as of the Filing Date without investigation by the Debtor, the Debtor was These were all
Bruce Bronson's
supporting a $771 monthly car lease payment from income from the Manchanda Law Office.
calculations,
Further, as of the Filing Date, the Debtor was supporting his mortgage payments ofthe'aluatlons,
119.
numbers and
New Rochelle Property and all his other personal expenses from income from the Manchanda Law work product.
Office.
120. The Debtor was offered numerous opportunities to amend his Schedules. Why would we amend
. . another bankruptcy
121. On May 16, 2023, the Court specifically recommended that he amend his
attorney's work product
schedules. See Doc. No. 43, May 16 Tr. at 44:6-15. we do not recall this. with 20 years of
experience, Bruce
Bronson, whom we paid
$3500?
18
Pg 19 of 22
122. The Debtor did not file any amendments relating to his law firm after the Court's Why would we
amend another
suggestion that he do so.
bankruptcy
123. As such, his valuation of the Manchanda Law Finn at $100 in the Schedules attorney's work
product with 20
without any apparent investigation, due diligence, or effort to tie this value to revenue or years of
experience,
accounts receivable (including a possible fraudulent conveyance under 11 U.S.C. § 548 for the Bruce Bronson,
whom we paid
$180,157.27 Withdrawal) constitutes a false oath. That's a false statement.
$3500?
124. For the same reasons, his statement on Schedule I, in which the Debtor lists net
monthly income from the Manchanda Law Finn in the amount of$7,527.53, constitutes a false
oath. Why would we amend another bankruptcy attorney's work product with 20 years of experience, Bruce Bronson,
whom we ~Id $3500?
125. The Debtor's net income could not be explained by the Debtor after two separate
days of examinations. Why would we amend another bankruptcy attorney's work product with 20 years of experience,
Bruce Bronson, whom we paid $3500?
126. The Debtor's net income and expenses on Schedule I are false because they do
does not include all the transfers from the Manchanda Law Finn accounts to pay the Debtor's
personal expenses, as outlined in the previous Count. These include, but are not limited to,
landscaping at the New Rochelle Property. At the home law office?
127. The Debtor's statement under oath at an examination that "I don't even look at It's true - I do not
look at or pay our
our finances ..." when referring to the Manchanda Law Finn is a false oath. Ex. A, Sept. 2023 bills as the
anxiety
Tr., at 85:20-24.
endangers the
128. "The subject matter of a false oath is 'material' and thus sufficient to bar heart attack I had
in August 2019,
discharge, if it bears a relationship to the bankrupt's business transactions or estate, or concerns so my Law Office
•
the d1scovery of assets, busmess
• dea1·mgs, or th e existence
• and d'1spos1tion
. . ofh1s
. property." Manager and
~.K,. •
wm, pays all bills,
Chalik, 784 F.2d 616,618 (11th Cir. 1984). manages the

Insurance
policies, books,
etc.
19
Pg 20 of 22
129. Following the advice of counsel is not a defense when it is ''transparently clear" Why would we
amend another
that certain material misrepresentations have been made in a debtor's papers. Zizza v. bankruptcy
attomey's work
Harrington (In re Zizza), 875 F.3d 728, 732-3 (1st Cir. 2017).
product with 20
130. In summary, based on the above facts, the Debtor's sworn statements relating to years of
Why would we experience,
amend anotherthe value of his business and other financial information rise to the level of false oaths, to wit: ('14ruce Bronson,
bankruptcy attorrieY,'s work prodµct with 20 years of.experi~{l~. Bruce Bron~n. w}lom V1e.pctid $3500? whom we paid
the Debtor made statements relating to his income and the value ot his law firm under oath; (2) $JS00?
the statements were false; (3) the Debtor knew the statements were false; (4) the Debtor made the
statements with fraudulent intent; and (5) the statements related materially to the Debtor's
bankruptcy case.
13 I. The foregoing constitutes grounds to deny the Debtor's discharge under 11 U .S.C. That's a false
statement.
§ 727(a)(4)(A).
COUNT THREE
Denial of Discharge Punuant to 11 U.S.C. § 727(a)(S)
(Failure to Explain Deficiency of Assets to Meet Liabilities)
132. The United States Trustee re-alleges and incorporates the allegations contained in
(a) The court shall grant the debtor a discharge, unless-.. .
(5) the debtor has failed to explain satisfactorily, before determination of

denial of discharge under this paragraph, any loss of assets or deficiency of assets to
meet the debtor's liabilities;
11 U.S.C. § 727(a)(5). •
134. The Debtor has claimed that he has insufficient assets to meet his liabilities.
135.
Ev~n after the; c;xienstve reviewr as outl~ij liUYi1\ ID~ Donmri finmnon ll■ lil ..
.l:CS remam This IS because
opaque. AUST Gregory Zipes and his team are stupid and obtuse - even after receiving all requested financial
documents, records, statements, tax returns, AUST Gregory Zipes still calls "Debtor's finances remain opaque:
The only thing that is "opaque" is AUST Gregory Zipes brain. The AUSrs inherent stupidity should not be used
against the Debtor. 20
23-22095-shl -Doc 117 Filed 03/25/24 Entered 03/25/2412:45:44 Main Document
Pg 21 of 22
136. However, it does appear that the Debtor seeks to discharge legitimate debts while There has been
plenty of "belt-
maintaining a lavish lifestyle without belt-tightening.
tightening. w
137. As an example of the Debtor's lavish lifestyle, on May 8, 2023, more than three
We already months after the Filing Date, the Debtor filed a reaffirmation agreement in connection with his
explained that Bruce Bronson and BMW told us to fill this out, it was never a_pproved, and was a "trap" set bY. Bronson and BMW.
BMW, promising to pay $771 a month for 27 months. ECF Doc. No. 38, with a duplicate copy
at ECF Doc. No. 39. (A copy of the Reaffirmation Agreement is attached as Exhibit G.)
138. In the Reaffirmation Agreement, the Debtor represented to the Court under oath
that he had sufficient income to pay for the BMW. We already explained that Bruce Bronson and BMW told us to fill
this out, it was never approved, and was a "trap" set by Bronson
139. IIi the Reaffirmation Agreement, the Pna11\~ecked the box next to the followmg
statement: "You can afford to make the payments on the reaffirmed debt because your monthly we already
explained that
income is greater than your monthly expenses even after you include in your expenses the
Bruce Bronson
monthly payments on all debts you are reaffirming, including this one." and BMW told
us to fill this out,
140. Similarly, the Debtor acquired the New Rochelle Property less than one year it was never
approved, and
before the Filing Date. See Ex. C, Creditors' Meeting Tr. at 8:3. was a "trap" set
by Bronson and
141. As outlined above, while claiming to have no assets, the Debtor has paid for
BMW.
landscaping and other expenses for the New Rochelle Property, all within a year prior to the
Filing Date.
142. Section 727(a)(5) contains no intent requirement, and thus "imposes strict
liability" when the debtor fails to provide a satisfactory explanation for the deficiency in assets."
In re McDonald, 29 F.4th 817, 823 (6th Cir. 2022).
143. Although intent is not required, the facts make plain that the Debtor has This is a false
•mtent1on • tior the de fl1c1ency

• ally c.1a1·1ed to prov1"de an explanat1on • • assets. The Debtor continues
m • statement.
to spend large sums notwithstanding his alleged inability to repay his creditors.
21
Pg 22 of 22
.,
144. The foregoing constitutes grounds to deny the Debtor's discharge under 11 U.S.C.
§ 727(a)(S).
WHEREFORE, the United States Trustee respectfully requests the following relief on
his complaint:
(a) on Count One of the Complaint, an order denying the Debtor's discharge pursuant to
Bankruptcy Code §727(a)(3);
(b) on Count Two of the Complaint, an order denying the Debtor's discharge pursuant to
Bankruptcy Code§ 727(aX4);
(c) on Count Three of the Complaint, an order denying the Debtor's discharge pursuant
to Bankruptcy Code § 727(a)(5); and
(d) for such other and further relief as the Court may deem just and proper.
Dated: New York, New York

March 25, 2024
UNITED STATES TRUSTEE
By: Isl Greg M. Zipes

Greg M. Zipes
Trial Attorney
Phone:212-510-0500
22
23-22095-shl Doc 117-1 Filed 03/25/24 Entered 03/25/2412:45:44 Exhibits to
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1 don't know that I can certify this.

2 MR. MANCHANDA: I'm recording this. Do
3 you want me to send you the recording?
4 THE COURT STENOGRAPHER: No. I am the
5 record.
6 MR. ZIPES: We're going to have to do
7 it again. That's the answer --
8 Q. I'll try to move on, but we may very
9 A. No, we don't.
10 Q. We're on Docket Number 449, UST 449; is
11 that right? Do you see that at the bottom,
12 Mr. Manchanda?
13 A. I see what you put on the screen, yes.
14 Q. Okay.
15 Is that your handwriting?
16 A. None of those are my handwriting.
17 Q. Do you know whose handwriting this is?
18 A. It looks like the law office manager.
19 Q. Your wife?
20 A. Who is a cosigner on the account, because
21 she's the law office manager. She has access to our
22 bank records, payi~g the bills. I told you this
23 already. I don't even look at our finances. If I
24 looked at our finances, I'd probably have --
25 Q. So you're testifying this is her
BEHMKE REPORTING AND VIDEO SERVICES, INC. 85

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Exhibit C
UNITED STATES BAmCROPTCY COURT

SOUTHERN DISTRICT OF NEW YOmt
IN RE: Chapter 7
Rahul Dev Manchanda,
Debtor . Bankruptcy 123-22095 (SBL)

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , ......................... .
March 9, 2023
10:30 a.m.
TRANSCRIPT OF TELEPHONIC 341 MEETING
APPEARANCES:
For The Debtor: H. Bruce Bronson, Baq.
Bronson Law Officea, l'C
480 Mamaroneck Ave.
Harrison, NY 10528
For the IRS and the SBA: Dana Walsh Kumar, Bsq.
Assistant o.s. Attorney
Southern District of New York
86 Chambers Street-3rd Fl.
New York, NY 10007
Chapter 7 Standing Trustee: Marianne T. O'Toole, Bsq.
Marianne T. O'Toole, LLC
22 Valley Rd.
Katonah, NY 10536
For Douglas M. Senderoff: Michael Druckman, Baq.
Lewis & Lin, LLC
77 Sands St.-6th Fl.
Brooklyn, NY 11201
1 MS. O' TOOLE: Thank you.
2 DIRECT EXAMINATION
3 BY MS. O'TOOLE:
4 Q. On your New York State driver's license, what is your --
5 the issue date?
6 A. The issue date is 08/16/2022.
7 Q. Thank you. And then on your social security card, what is

8 the difference between the printed name and the signed name?
9 A. Printed name is Rahul Dev Manchanda, and I signed it Rahul
10 Manchanda.
11 Q. Thank you. Have you ever used another name?
12 A. No.
13 Q. Have you ever used another social security number?
14 A. No.
15 Q. Did you review your petition and the subsequently filed
16 amendments before you signed them?
17 A. Yes.
18 Q. And did you provide the signature pages to your attorney?
19 A. Yes.
20 MS. O'TOOLE: Counsel, did you cause the signature

21 pages to be uploaded to the Trustee's portal?
22 MR. BRONSON: Yes , I did.
23 BY MS O'TOOLE:
24 Q. Sir, have you listed everything that you own on your

25 bankruptcy petition and the amendments?
1 A. Yes.
2 Q. Do you have any changes that you'd like to malt• to your

3 petition or schedules?
4 A. No, Ma' am.
5 Q. Is the infonnation contained in the petitions, schedules,
6 statemen~, and related documents true and correct?

7 A. Yes, Ma'am.
8 Q. Have you filed for bankruptcy before?
9 A. Yes, Ma'am.
10 Q. And when did you file for bankruptcy before?
11 A. I don't recall the first time, but I believe it was around
12 2011.
13 Q. And did you receive a discharge in bankruptcy?
14 A. I believe so, yes.
15 Q. And where was that case filed?
16 A. Southern District of New York in Manhattan.
17 Q. • Okay, all right. And do
18 MS . O' TOOLE: Mr. Bronson, had you independently
19 verified that or --
20 MR. BRONSON: I did. I'm going to look it up again.
21 I don't believe there was a discharge. There were a couple of
22 different filings, but I'm going to look that up as you're
23 doing this meeting. I'll report back to you in a few minutes.

24 MS. O' TOOLE: Okay. And tell me the last one, all
25 right, with the last date. If you'll give me -- identify what
Exhibit D
23-22095-shl Doc 117-1 Filed 03/25j
United States Truste
Rahul Dev -----t::!"' 42 ..-!nchanda, Chapter 7, Case No.: 23-22095 (SHL)
-
Productio~ f'.....iii--=..:, Response to 2004 Order Entered on June 1, 2023
Document Requ~ -..d:

1) The 2020, 2021 iJ 2022 Federal and State Tax Returns with all
completed schedu• attached-including but not limited to extensions,
..
1099's, W-21s-fo~ I )th (a) the Debtor and (b) the Manchanda Law Offi
PLLC.
2) All documents :r:- ~ting to the valuation of the Manchanda Law Office
PLLC provided in __:J-- ~ Schedules.
3) All documents s::= -c :wing the Debtor's relationship to Manchanda Law

PLLC, including a - ~ governing documents evidencing the Debtor's own
and any employme= ~ agreements, and any payments by the Manchanda I
Office PLLC to t h ~ I ~btor.
4) All documents s .M ,c
7Ving how the Debtor calculated income on Schedul
[ECF Docket No. s;;;;;; . The Debtor indicates on Schedule I that his net incc
from "rental prop~i. - y- md from operating a business, profession, or farm"
$4,250. After inclu
monthly income is
,..
_;w_: :::::::J@ lhe income of"Debtor 2 or non-filing spouse" the
=527.53. The Debtor should provide all documents i
connection with th~ ---=ia:::: -:ome amounts listed in Schedule I.
5) All documents r ~ .a..= ng to applications for credit, loans, or letters of ere

submitted by the r>c I ~
◄r to credit or financial institutions for two (2) yean
prior to the Filing I:.t t=- , as well as all documents relating to applications t
credit, loans, or Jett ~ of credit submitted by the Debtor with respect to al
outstanding credit o I an obligations existing at or after the time of the Fi
Date to the present.
6) Monthly statemen
in Schedule D, E, an-
- ~
- r all debts listed in the Schedules, including those Ii!
for the two (2) years prior to the date of filing of the
Petition.
Rahul Dev .Manchanda, Chapter 7, Case No.: 23-22095 (SHL)

Production mResJXJnse to 2004 Order Entered on June I, 2023 (Doc 45)
7) All documents reating to the purchase, maintenance, or valuation of 270 5/30/23 UST-000035- UST-000039
Victory Boulevard,. New Rochelle, New Y orlc, including any (i) appraisals, (ii)
closing documents,. (iii) receipts, and (iv) confumation(s) of mortgage and tax
payments, with the name of the payor, related to such property.
8) All documents relilting to the debt with the U.S. Small Business Administration 5/30/23 UST-000040- UST-000116
listed in the Debtor's Schedules, including any (i) appraisals, (ii) closing
documents, (iii) recepts, and (iv) confirmation(s) of payment, with the name of 6/14/23 UST-SBA-000001 to UST-SBA-000045
the payor, related to such debt.
9) All documents relating to the purchase, maintenance, or valuation of the 2018 5/30/23 UST-000117
BMW 320i listed in th.e Debtor's Schedules, including any (i) appraisals, (ii)
closing documents, (ii) receipts, and (iv) confirmation(s) of payment, with the
name of the payor, related to such property.
IO) All documents relating to the "Lease for BWMW X3 2022 $771 per month" 5/30/23 UST-000118
listed in the Debtor's Schedules, including any (i) appraisals, (ii) closing
documents, (iii) receipts, and (iv) confirmation(s) of payment, with the name of
the payor, related to sllch lease.
11) All documents renting to the purchase and/or valuation of the Rolex Oyster 5/30/23 UST-000119 - UST-000120
Perpetual Steel Yellow Gold White Roman Men's Watch listed in the Debtor's
Schedules, including 1,ut not limited to, all (i) appraisals, (ii) closing documents,
(iii) receipts, and (iv) confumation(s) of payment, with the name of the payor,
related to such property.
12) All documents relating to the Debtor's purchase and/or leasing of any real 5/30/23 UST-000121 - UST-000142
property or automobiles, individually or with another individual, a spouse, a
sibling, a child, etc., for the two (2) years prior to the Filing Date to the present,
including but not limited to, all (i) appraisals, (ii) closing documents, (iii) receipts,
and (iv) confmnation(s) of payment, with the name of the payor, related to such
real property or automobiles.
Rahul Dev Manchanda, Chapter 7, Case No.: 23-22095 (SHL)

Production in Response to 2004 Order Entered on June 1, 2023 (Doc 45)
13) All insurance policies and all documents relating to applications submitted for 5/30/23 UST-000143- UST-000187
insurance policies held by the Debtor, individually or with another individual, a
spouse, a sibling, a child, etc., for two (2) years prior to the Filing Date to the
present.
14) All documents relating to gifts or transfers made to or from the Debtor having
a value in excess of $100 .00 for the past two years and, if documents do not exist
for any such gift, a description of the item purchased and to whom such item was
presented.
15) Copies of money orders, bank checks or certified checks used to pay any bills, 5/30/23 UST-000188 - UST-000268
in the 12 months preceding the Filing Date
7/18/23 UST-000302 - UST-000663
Exhibit E
U.S. Department of Justice

Office of the United States Trustee
Southern District ofNew York
{@:JW!'~:~~.J!R!'-!l.!!~...:.l-•,~ ~lffi\~ult!lffifflffll Ill II'
New York, NY 10004-1408
Phone: (212) 510-0500
August 1, 2023
VIA EMAIL _
Rahul Dev Manchanda
270 Victory Blvd
New Rochelle, NY 10801
Re: Rahul Dev Manchanda

Case No. 23-22095-shl
Dear Mr. Manchanda,
My office is in receipt of additional documents you produced on July 18, 2023, in

response to the 2004 Order entered by Judge Lane (the "July 18 Production").
The July 18 Production has been bates stamped UST-000269 through UST-
000663. A copy of the July 18 Production with the bates stamps is attached herein.
Additionally, attached are documents we received from Jayanthi Ganapathy from
FinAccurate, which have been bates stamped UST-SBA-000001 to UST-SBA-000045.
Please review the summary of documents produced with the corresponding bates
range. If you think I have miscategorized something, or missed a document you sent,
please let me know by return letter or email.
Very truly yours,
UNITED STATES TRUSTEE
~;.::~~~~
Greg Zipes •
Trial Attorney
NilClOSillQ~
Cc: Dana Walsh Kumar, Assistant U.S. Attorney
Exhibit F
95-shL: -.OOC 117-1 Filed 03/25/24 Entered 03l25l#412:4~
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CERTIFICATE OF SERVICE
On March 29, 2024, I, Rahul Manchanda, served a copy of this Debtor
Reply Affirmation to AUST Gregory Zipes and any attached pages to
AUST Gregory Zipes, located at 1 Bowling Green, New York, New York
10004 via ECF, Electronic, and U.S. Mail.
By: Rahul Manchanda, Esq.

Manchanda Law Office PLLC
30 Wall Street, 8~ Floor
Tel: (212) 968-8600
Fax: (212) 968-8601

Debtor Reply Affirmation To Aust Gregory Zipes Filed

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UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF NEW YORK

RAHUL DEV MANCHANDA,

DEBTOR REPLY AFFIRMATION TO AUST GREGORY ZIPES

TO: THE HONORABLE SEAN H. LANE

1. Similar to my reaction to AUSA Dana Walsh Kumar's Complaint to Object to Discharge, my

reaction to AUST Gregory Zipes' COMPLAINT OBJECTING TO DEBTOR'S

DISCHARGE drew a similar reaction of sickness to my stomach at the bottom-feeder level

throughout his attached (and marked up) pleadlng.

his bald-faced lies will somehow make them true.

SPECIFIC RESPONSES TO AUST GREGORY ZJPES SPURIOUS ALLEGATIONS

slander, and libel.

work/expertise of more than 20 years.

reason I have no idea

we expressed to the court.

later voluntarily amended the return in 10/23.

11. Bruce Bronson did this valuation. with his experts.

document unavailability, slowness of the financial institutions, outright refusals unless we

by AUST Gregory Zipes.

AUSA and AUST.

19. Debtor was still absent due to the medical emergency.

research, servers, files, etcJ adminimative.

Arons and previously with CPA Marc Albaum.

24. We fully comply with this.

Linkedln about being an NYU Adjunct Law Professor.

CPA offices for 7 years.

too lazy to make an appointment to come and inspect.

find a new bank, for many years.

did anything of the sort that he negatively alleges.

then they are deductible.

including traveling to those banks personally.

bankruptcy law, and we paid him $3500 to do so.

he filed the case with electronic signatures.

"Home Law Office."

experience, Bruce Bronson, whom we paid $3500?

recommended us to amend the schedules" we do not recall this.

manages the insurance policies, books, etc.

against the Debtor.

was a "trap" set up by Bronson and BMW.

pursuant to Bankruptcy Code §727(a)(3);

pursuant to Bankruptcy Code§ 727(a)(4);

pursuant to Bankruptcy Code§ 727(a)(5); and

RAHUL DEV MANCHANDA

270 Victory Boulevard

UNITED STATES BANKRUPTCY COURT

RAHUL DEV MANCHANDA,

STATEMENT OF THE CASE

2. Marianne T. O'Toole, Esq. (the "Chapter 7 Trustee") is the Chapter 7 trustee in

this case under 11 U.S.C. § 702(d).

NY 10801 (the ''New Rochelle Property").

JURISDICTION, VENUE, AND STATUTORY PREDICATES FOR RELIEF

application under 11 U.S.C. §§ 307 and 727(c)(l).

action constitutes a core proceeding as defined by 28 U.S.C. § 157(b)(2)(J). •

4004(a) and 7001.

8. Venue is proper pursuant to 28 U.S.C. § 1409(a).

ALLEGATIONS COMMON TO ALL COUNTS

case by filing a voluntary petition (the "Petition"). ECF Doc. No. 1.

(the "Initial Schedules"). Id.

amended, supplemented, or modified, the "Schedules"). ECF Doc. Nos. 5, 13.

"SOFA"). ECF Doc. No. 10.

are attached as Exhibit C hereto).

B. The Debtor's Prior Bankruptcy Filings

10222, ECF Doc. No. 187.