UNITED STATES BANKRUPTCY COURT
DISTRICT OF SOUTH CAROLINA
/K Case No. 12-02333-DD
HART REALTY AND PROPERTY
MOTION OF KEVIN CAMPBELL, TRUSTEE TO CONDUCT
BANKRUPTCY RULE 2004 EXAMINATION OF
Kevin Campbell, the duly appointed and acting Chapter 7 Trustee for the above
Debtor (hereinafter referred to as the "Trustee"), by and through his undersigned attorney
does hereby file this Motion to Conduct Bankruptcy Rule 2004 Examination of Pamelin K.
Nettleton. In support of such Motion, the Trustee would show as follows:1.
The debtor, Hart Realty and Property Management ("Debtor"), filed a
voluntary petition under Chapter 7 of the Bankruptcy Code on April 11, 2012.
Prior to the meeting of creditors, the Trustee reviewed the Debtor's
schedules, statements and other documents filed with the court. At the
Meeting of Creditors, the Debtor testified concerning his financial affairs.
3.Through his investigation, the Trustee learned that the Debtor deposited its
clients' security deposits into its Real Estate Trust Account for safekeeping
for the benefit of its clients.
Upon information and belief, the Debtor relied on various informal and basic
prepared reports from an administrative assistant, Pamelin K. Nettleton, to
show him the purported balance of Hart Realty's various accounts.
Case 12-02333-dd Doc 32 Filed 08/22/12 Entered 08/22/12 14:36:11 Desc MainDocument Page 1 of 3