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Case 12-02333-dd

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UNITED STATES BANKRUPTCY COURT DISTRICT OF SOUTH CAROLINA ) B/K Case No. 12-02333-DD HART REALTY AND PROPERTY ) MANAGEMENT, ) Chapter 7 Debtor. MOTION OF KEVIN CAMPBELL, TRUSTEE TO CONDUCT BANKRUPTCY RULE 2004 EXAMINATION OF PAMELIN K. NETTLETON 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. 2. 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. 4. 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. IN RE:

Case 12-02333-dd

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Upon information and belief, Pamelin K. Nettleton was able to remove funds from the Real Estate Trust Account and a second Owner Proceeds Account and convert those to her own use, without the Debtor knowing that she did so.

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Based on the foregoing, the Trustee asserts that he is entitled to an order providing for an examination of Pamelin K. Nettleton pursuant to Bankruptcy Rule 2004.

WHEREFORE, the Trustee prays that this Court issue an Order directing the examination of Pamelin K. Nettleton, pursuant to the provisions of Bankruptcy Rule 2004, on September 7, 2012 at 10:00 a.m. by counsel for Kevin Campbell, Trustee at the offices of Campbell Law Firm, PA, 890 Johnnie Dodds Blvd., Mount Pleasant, SC.

Mt. Pleasant, South Carolina Dated: August 21, 2012

Respectfully submitted, CAMPBELL LAW FIRM, P.A. /s/ Suzanne Campbell Chisholm Suzanne Campbell Chisholm Attorney for the Trustee Post Office Box 684 Mt. Pleasant, SC 29465 (843) 884-6874/884-0997(fax) District Court I.D. No. 10274 scampbell campbell-law-firm.com

Case 12-02333-dd

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Filed 08/22/12 Entered 08/22/12 14:36:11 Document Page 3 of 3

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UNITED STATES BANKRUPTCY COURT DISTRICT OF SOUTH CAROLINA IN RE: ) ) B/K Case No. 12-02333-dd HART REALTY & PROPERTY MANAGEMENT,) Chapter 7 ) ) Debtor. ) CERTIFICATE OF MAILING

I, Lauren J. Schumann, Legal Assistant, Campbell Law Firm, P.A. hereby certify that on this day I mailed a true and correct copy of the following: MOTION OF KEVIN CAMPBELL, TRUSTEE TO CONDUCT BANKRUPTCY RULE 2004 EXAMINATION OF PAMELIN K. NETTLETON AND PROPOSED ORDER FOR BANKRUPTCY RULE 2004 EXAMINATION by mailing said copies by United States mail, with proper postage affixed thereto and addressed to those creditors and parties in interest as shown below. The United States Trustee's Office was served electronically with this document.

Pamelin K. Nettleton 157 Brookgate Drive Myrtle Beach, SC 29579

/s/Lauren J. Schumann Lauren J. Schumann, Legal Assistant Campbell Law Firm, PA Post Office Box 684 Mt. Pleasant, SC 29465 (843) 884-6874/ (843) 884-0997 fax Mt. Pleasant, South Carolina Dated: August 22, 2012