Gray's Dismisal MotionOrder Change Venue Denied


 





On February 24,2004, I entered the United States Bankruptcy Court House on the 11th Floor of the Tip O'Neil building in Boston, Massachusetts where I have been barred from entering by US Bankruptcy Judge Caroll J. Kenner. I went to the Courthouse today at 11:00 AM to file my motion to seek a change of venue on my Bankruptcy Case. I was greeted by the U.S. Marshall and two other law enforcement officers who were prepared for my arrival. The Marshall stated that there would be no arrest on this day. The US Marshall took my motion, passed through the barriers and filed it for me, and then asked me to leave the building. I told him that I would return in two weeks to be arrested and break the order if I was not granted my change of venue request. This is a democracy, I have rights as a citizen and I will continue to fight until those rights are recognized. Judicial corruption ruined my family's viability for generations. The corruption of Judge Kenner must end - not just for me but for all of the businessmen who seek refuge in her court and are unlawfully stripped of years of hardwork.
------------------------------------------------
UNITED STATES BANKRUPTCY COURT
DISTRICT OF MASSACHUSETTS
******************************
CHAPTER 11
CASE No. 96-10123-CJK

In re:

V&M MANAGEMENT, INC.,

DEBTOR

*****************************
ALPHONSE MOURAD

Plaintiff

vs.

STEPHEN S. GREY, TRUSTEE

Defendant
******************************

MOTION FOR CHANGE OF VENUE OF
THIS CASE TO ANOTHER STATE

Now comes Alphonse Mourad, Plaintiff, and moves the Honorable Court (Kenner, C.J.), to change the venue of the debtor's bankruptcy from this Eastern District of Massachusetts to either the states of New York, Connecticut or Rode Island on the grounds that Judge Kenner was appointed the Chief Judge of the Bankruptcy Appeals Court in April 2003 (See Exhibit "A"), thus creating a conflict of interest, in that Judge Kenner will be the residing Judge in both the Debtor's chapter 11 bankruptcy case, and will be the Judge who will be responsible to hear any appeal made in said chapter 11 bankruptcy case in the Bankruptcy Appeals Court. Judge Kenner will be forced to make an eventual ruling in the remand trial in the U.S. Bankruptcy Court (which she has continued to postpone) making it impossible for Mourad to try to get another appellate court order requiring a trial.

Furthermore, as of today, almost four years later, the United States Bankruptcy Court of Appeals ordered Judge Kenner to give Mourad a trial on his claims of malfeasance and negligence by the United States Bankruptcy Trustee, appointed by Judge Kenner to handle his bankruptcy case (see U.S. Bankruptcy Appellate Panel's 4/12/00 Judgment and Order, attached as Exhibit "B"). Judge Kenner, who had been the chief bankruptcy judge for fourteen years, has refused to grant a trial date despite Mourad's efforts (see Mourad's 9/12/01 Motion to Request A Trial, attached as Exhibit "C").

On 10/31/01, Judge Kenner submitted a Pretrial Order On Remand Motion of Alphonse Mourad To Allow Administrative Claim Late (See Exhibit "D"). In that Order, Judge Kenner ordered Mourad to file a pretrial statement on or before 2/15/02, and for the Trustee to file his pretrial statement on or before 4/12/02. Both parties satisfied Judge Kenner's order.

As of now, nearly two years have passed since both parties had satisfied Judge Kenner's pretrial order, and nearly four years have passed since the original 4/12/00 Order and Judgment of the Bankruptcy Appellate Pannell. Still, no trial date has been set by Judge Kenner.

Also, Mourad is still awaiting a response from The Committee On The Judiciary and The House of Representatives on his compliant filed against Judge Kenner, seeking an investigation and her eventual impeachment for her cover-up of the fraud and perjury committed in the V&M Bankruptcy case, by the Trustee, Stephen S. Gray and the Law Firm of Hanify and King and attorney Harold H. Murphy (See Exhibit "E").

There is a further conflict, in that Judge Kenner could potentially be called as a witness in the remand trial based on her knowledge that Harold Murphy and Hanify and King, who was V&M Management's counsel, represented Trustee Gray in a separate matter before Judge Kenner at the very same time. The record demonstrates that Harold Murphy and Hanify & King represented Stephen Gray, in his capacity as Chapter 7 Trustee, in the case of In re: Neponset River Paper Company f/k/a, Patriot Paper Corporation, Case No. 93-12482-CJK. This case was pending at the very same time as the V&M case and was before the same Bankruptcy Judge, Carol J. Kenner, who appointed Gray as the Trustee for V&M. It is reasonable to assume that Judge Kenner knew of the prior Murphy/Hanify and King representation of Gray at the same time she appointed Gray. The Patriot Paper case had been ongoing before Mourad hired Harold Murphy to represent V&M in January of 1996, and Murphy proceeded to represent Gray in the Patriot Paper case and V&M simultaneously, in the same court room, and in front of the same Judge (Carol J. Kenner), without notifying Mourad of his relationship with Gray. Further, Gray was appointed by Kenner as V&M's Trustee on 4/2/96. On 4/11/96, Murphy and Hanify & King appeared on behalf of Gray in the Patriot Paper case before Judge Kenner. Also, Trustee Gray filed two Verified Statements under oath (one on 4/2/96 and the other on 4/5/96, See attached Exhibit "F") stating he had no affiliation with the debtor or the debtor's attorney's, thus committing perjury.

Mourad also says that Judge Kenner is biased to him, in that she had barred Mourad from the U.S. Bankruptcy Court, the Clerks Office, and the U.S. Trustee's Office for life without a hearing or just cause, thus violating his first amendment right and enabling him to file motions on his behalf, being Pro Se and indigent. (See Exhibit "G").

Finally, Mourad says that Judge Kenner's delay of the remand trial to determine who is responsible to pay the IRS income taxes for the profit V&M incurred for the years 1997 and 1999, which the Trustee pocketed for himself as the owner of V&M Management, has cost Mourad approximately $400,000 owed to the IRS, including interest and penalties in excess of $150,000 (See Exhibit "H").

WHEREFORE, Mourad moves the Honorable Court (Kenner, C.J.), to change the venue of the debtor's bankruptcy from this Eastern District of Massachusetts to either the states of New York, Connecticut or Rode Island on the grounds mentioned above.

_________________________
Alphonse Mourad
125 West Street
Hyde Park, MA 02136
(617) 312-4919

February 24, 2004

UNITED STATES BANKRUPTCY COURT
DISTRICT OF MASSACHUSETTS
******************************
CASE No. 96-10123-CJK

In re:
V&M MANAGEMENT, INC.,
Debtor *****************************
ALPHONSE MOURAD
Plaintiff

vs.

STEPHEN S. GREY, TRUSTEE
Defendant
******************************

CERTIFICATE OF SERVICE

I, Alphonse Mourad, hereby certify that I have served, by first class mail, the following parties my Motion For Change of Venue, on this 24th day of February, 2004:

Paul Moore
Duane Mooris, LLP
470 Atlantic Avenue, Suite 500
Boston, MA 02210
(617) 289-9200

Eric Bradford
Office of the United States Trustee
1184 Thomas P. O'Neil, Jr. Federal Building
10 Causway Street
Boston, MA 02222-1074

Singed under the pains and penalties of perjury

_________________________
Alphonse Mourad
EXHIBIT D:

Unites States Bankruptcy Court
District of Massachusetts
.
Chapter 11
Case No. 96-10123-CJK
.
In re
.
V & M MANAGEMENT, INC.,
.
Debtor
.
PRETRIAL ORDER ON
REMANDED MOTION OF ALPHONSE MOURAD TO ALLOW ADMINISTRATIVE CLAIM LATE
.

Alphonse Mourad has filed a request for trial on the unadjudicated parts of his remanded
Motion of Alphonse Mourad to Allow Administrative Claim Late. The Court hereby orders Mr.
Mourad to file a pretrial statement on or before February 15, 2002, and the Trustee to
file his pretrial statement on or before April 12, 2002. Mr. Mourad may then file a further pretrial statement, as to his rebuttal evidence only, on or before June 4, 2002.
A party's pretrial statements shall include the following:


1. A list of the witnesses that a party intends to call;


2. With respect to each witness that a party intends to call, a brief statement from the parly as to the substance of the witness's expected testimony; and


3. A list of all exhibits that the party intends to introduce at trial, together with copies of the exhibits themselves. The documents shall be in the sequence proposed to be offered at trial and shall be numbered sequentially. Failure to file exhibits timely, or to include a document in the Pretrial Statement as an exhibit, may result in the exclusion of that document at trial. Each party is responsible for providing copies of all exhibits to opposing counsel and for having sufficient copies available at the trial for use by witnesses.


Date: 10/31/01
Carol J. Kenner
United States Bankruptcy Judge


cc: Mr. Alphonse Mourad
Paul Moore, Esq., for Stephen Gray, Creditors' Trustee
-----------------------------------------------
UNITED STATES BANKRUPTCY COURT
DISTRICT OF MASSACHUSETTS
.
In Re:
.
Chapter 11
V&M MNAGEMENT, INC.,
No. 96-10123-CK
.
Debtor
.
ALPHONSE MOURAD,
Plaintiff
.
vs
.
STEPHEN GREY, TRUSTEE
Defendants
.
PLAINTIFF'S PRETRIAL STATEMENT


Pursuant to this Court order of October 31, 2001, Plaintiff ALPHONSE MOURAD hereby submit the list of proposed witnesses, documents and exhibits.


A. PLAINTIFF'S WITNESSES
1. Custodian of Records
Verdolino and Lowery, P.C.
124 Washington Street
Foxborough, Mass 02035
Tel: (508) 543-1720
This witness is the custodian of records for the firm which conducted the accounting for
Trustee Stephen Grey during his management of V&M Management, including the payment of taxes. This witness will produce and will testify concerning the business nature of the accounting records.


2 Greg Jalbert,
Verdolino & Lowey, P.C.
124 Washington Street, Suite 101
Foxborough, MA 02035
Tel (508) 543-1720.
This witness was the accountant for V&M Management and the Trustee, Stephen Gray from 1996-1999. Mr. Jalbert was responsible for the taxes and the accounting of V&M Management. He will testify concerning the assessments, payment of taxes, and the cash flow through the trustee.


3. Frank D. Pietroski, MAI
FD Pietroski & Company
175 Derby Street, Unit #21
Hingham, MA 02043
Tel (617) 749-8830 Fax (617) 749-4920
Mr. Pietroski was hired by V&M Managment to do an appraisal of the V&M properties at the Mandela Apartments, and returned an appraisal of $11,000,000. He will testify concerning his appraisal.


4. Richard A. Cohen
Chairman, Board of Review
Boston City Hall
Assessing Department, Room 301
Boston, MA 02201
Mr.Cohen established an assessment of $10,000,000 on the V&M properties, and assessed taxes against V&M on that basis. He will testify concerning his method of determining the assessment, and the position of the City of Boston concerning the value of the property and the taxes to be levied against it.


5. Tony Crayton
Crayton Consultant Services
3 Douglas Park #313
Boston, MA 02118
Tel/Fax: (617) 427-4361
Mr. Crayton did an appraisal of the Mandela Apartments, and appraised the land alone in excess of $10,000,000. He will testify concerning his appraisal.


6. Kenneth Gurge, Esq.,
Arthur Chipouras, Esq.,
Mary Costigan, Esq.
Department of Revenue
Commonwealth of Massachusetts
100 Cambridge Street
Boston, MA
Mr. Gurge established an appraised value of the Mandela Apartments at $100,000, which figure was relied upon by the Trustee. He will testify concerning his method of arriving at the appraisal, and his interactions and relations with the Trustee. Mr. Chipouras established that V&M Management owed $4,000,000 in tax arrears despite the $100,000 appraisal, and will testify concerning how he established the tax liability. Ms. Costigan testified in prior proceedings concerning the $100,000 appraisal upon which the Trustee based his actions.


7. Marvis Knospe, Esq.
Internal Revenue Service
10 Causeway Street, Room 401
Boston, MA 02222
Mr. Knospe appeared at the Confirmation Hearing on behalf of the United States and the IRS and informed the trial court that the Trustee had agreed to pay all taxes and to satisfy all tax claims and that based upon those guarantees and representations, the IRS had no objection to the Confirmation Plan. Mr. Knopse will testify concerning conversations between himself and the Trustee, and the representations he made to the court.


8. David M. Lipton, Esq.
15 Court Square, Suite 425
Boston, MA 02108
Tel (617) 227-7666
Mr. Lipton will testify concerning a pattern of negligent conduct on the part of the Trustee involving other bankruptcy cases.


9. James P. Dillon, Jr.
Attorney At Law
1 Billings Road
N. Quincy, MA 02171
Mr. Dillon was the attorney for V&M regarding the real estate taxes. He will testify concerning his efforts to resolve the tax issue with the Commonwealth.


10. Larry Nelson
Vice President
American Capital Resource
1990 Resurgens Plaza
945 East Paces Ferry Rd.
Atlanta, Georgia 30326
Tel (404) 240-4300 Fax (404) 240-4313

Mr. Nelson will testify that he sent a letter to V&M Management and Plaintiff on January 30, 1996, stating that he was able to refinance Mandela for the amount of $9,000,000, which letter became the basis for the Plaintiff's Confirmation Plan.


11. Custodian of Records
Dept of Housing and Community Development
100 Cambridge Street, 18th Floor
Boston, MA 02202
This witness will produce and will testify as to the authenticity of records of the Department of Housing concerning the approval of the tax credits to Beacon Management rather than to Plaintiff.


12. Jane Wallis Gumble, Director
Department of Housing and Community Development
00 Cambridge Street, 18th Floor
Boston, MA 02202

Ms. Gumble approved the tax credit for the partnership of Beacon Management and the Mandela residents in 1997, and will testify concerning the reasons for granting the tax credit to Beacon, and the relationship between her office and the Trustee. She will also testify concerning the eventual capture of all the tax credits by Beacon Management.


13. Kevin Leprohon,
Joseph J. Blake and Associates, Inc.
Real Estate Appraisers and Consultants
10 East 40th Street, 26th Floor
New York, NY 10016
Tel (212) 779-0555 Fax (212) 779-0566
Mr. Lephohon appraised the Mandela Apartments on March 24, 1997 in access of $7,000,000, and will testify concerning his appraisal.


14. Custodian of Records
Beacon Residential Properties
2 Oliver Street
Boston, MA 0219
The custodian or records will produce and will testify concerning the nature of business records of Beacon Management, and in particular, those records pertaining to the acquisition of low-income housing credits from V&M Management, and the process of the acquisition of the Mandela Apartments.


15. Howard E. Cohen
Beacon Residential Properties
2 Oliver Street
Boston, MA 02109
Mr. Cohen will testify concerning the sale of the assets of V&M Management to Beacon, the transfer of the ten-year low income housing tax credit from the Trustee to Beacon, the application and approval of Beacon for the tax credit, the business relationship between the Trustee and , and the cash flow from HUD to the Trustee to Beacon.


16. Custodian of Records
Housing and Urban Development
New England Multifamily Project
Thomas P. O'Neill Office Building
10 Causeway Street, 10th Floor
Boston, MA 02222
The custodian of records will produce and will testify concerning records of HUD relating to the cash disbursements to the Trustee, the financial records submitted by the Trustee, the renewal of the HUD rent subsidy agreements with the Trustee, the approval of the sale of the property to Beacon, and the cash flow to Beacon.


17. James A. Tierney,
Director, Project Management of New England Multifamily HUD
Thomas P. O' Neill, Jr. Federal Building/Office of Housing
10 Causeway Street, 3rd Floor
Boston, MA 02222-1092
Mr. Tierney will testify concerning prior business relationships of the Trustee with HUD, the system of rent subsidies and the approval of the Trustee to operate the Mandela Apartments, the transfer of ownership to the Trustee, the low income housing tax credit system and eligibility to receive the credits, HUD's approval of the transfer of the credits to the Trustee and subsequently to Beacon.


18. Richard E. Bonz
President
Bonz & Company Incorporated
64 Broad St.
Boston, MA. 02109
(617) 478-2090
Mr. Bonz was retained by the Trustee to appraise Mandela Apartments and brought back an appraisal of $100,000 which was adopted by the Trustee. He will testify concerning the basis for his appraisal and his relationship with the Trustee.


19. Alphonse Mourad
125 West Street
Hyde Park, MA. 02163
(617) 312-4919


20. Steven Slavin, CPA
40 Grove Street
Wellesley, MA 02482
781-239-3335
Mr. Slavin did the 1995 and 1996 analysis if the V&M Management financial statements and the analysis of the personal liability of Plaintiff to V&M Management. He will testify concerning the cash flow from the company to the Plaintiff.


21. Donna Buccio
Office of the Chapter 11 Trustee
The Recovery Group
270 Congress Street
Boston, MA 02210
(617) 482-4242
Ms. Buccio prepared the monthly operating reports for J. Marshall, United States Trustee, concerning the Mandela Apartments, and will testify concerning the cash flow of the development.


22. Stephen Gray
Appointed Chapter 11 Trustee
The Recovery Group
270 Congress Street
Boston, MA 02210
(617) 482-4242


Stephen Gray was appointed as the Chapter 11 Trustee for V&M Management, Inc. from 1996-1999 by the United States Bankruptcy Court. He will testify with regard to all financial, accounting and managerial activities that took place during his tenure. In addition, Mr. Gray will provide detailed testimony with regard V&M's 1997 tax credit application.


Respectfully submitted this 14th day of February, 2002


By: _____________________________
Alphonse Mourad, pro per
125 West Street
Hyde Park, MA. 02163

EXHIBIT E:

CONGRESS OF THE UNITED STATES
House of Representatives
.
Committee On The Judiciary
2138 Rayburn House Office Building
Washington, DC 20515-6216
202-225-3951
.
December 22, 1998
.
Mr. Alphonse Mourad
125 West Street
Hyde Park, MA 02136
.
Dear Mr. Mourad:
.
Thank you for your correspondence regarding judicial misconduct. You have inquired as to the procedures of the House Judiciary Committee on investigating complaints against Federal judges.
.
Due to the limited resources of the Committee to investigate the complaints received, and to ensure fairness to all individuals involved, Congress established a procedure in 1980 to be utilized as the primary means of investigating and adjudicating judicial misconduct complaints.
.
The Judicial Councils Reform and Judicial Conduct and Disability Act of 1980, 28 U.S. C. 372(c) ("The 1980 Act") established a mechanism for the presentation of complaints against federal judges (with the exception of Justices of the United States Supreme Court, for whom no formal complaint mechanism exists other than filing a complaint with Congress). It is the considered policy of the House Judiciary Committee to defer, except in exceptional circumstances, to the complaint procedures of the 1980 Act. You should, accordingly, take all possible steps to avail yourselves of those procedures before bringing die matter to this Committee.
.
Under those procedures, a complaint alleging that a federal judge has engaged in conduct prejudicial to the effective and expeditious administration of the business of the courts may be filed with the clerk of the U.S. Court of Appeals for the circuit in which the federal judge to be complained against sits.
.
Each complaint is considered first by the Chief Judge of the circuit, who determines whether or not the complaint raises an issue that should be investigated. If the complaint is against the Chief Judge, another judge will make this determination.
.
If the complaint is directly related to the merits of a decision or procedural ruling rendered by the judge against whom the complaint is lodged, the complaint will be summarily dismissed.
.
The proper recourse to challenge the merits of a judicial ruling is by way of appeal, at the appropriate time, to a court with jurisdiction to hear such appeals. The filing of a complaint of judicial misconduct under the procedures set forth in section 372(c) is not a device for further review of judicial rulings.
.
If the Chief Judge determines that an investigation is necessary, he or she will appoint a special committee of judges for that purpose. The special committee will report to the judicial council of the circuit, which will decide what action, if any, should be taken.
.
A complaint must be filed in writing on a form that has been developed for that purpose. If you need the form, it is suggested that you call the clerk of the appropriate U.S. Court of Appeals, and the clerk can provide you with a copy of the form.
.
This letter is not meant to suggest that the filing of a complaint of judicial misconduct is appropriate in your situation. It is intended only to inform you and suggest that any complaint that is to be filed should be filed first under those procedures.
.
If a party has availed itself of the Judicial Councils Reform and Judicial Conduct and Disability Act procedures, and remains dissatisfied, they may implore a Member of the House to bring such a complaint to the attention of the Judiciary Committee.
.
Again, this letter is not meant to suggest that you file a complaint under the 1980 Act or that you contact your representative requesting that a formal complaint be filed. I hope this assists in informing you as to the procedures established by Congress and followed by the Judiciary Committee.
.
Sincerely,
.
HOWARD COBLE
Chairman
Subcommittee on Courts and Intellectual Property
HC/mg

EXHIBIT F:

OFFICE OF THE BAR COUNSEL
.
BOARD OF BAR OVERSEERS OF THE SUPREME JUDICIAL COURT 75 FEDERAL STREET BOSTON, MASSACHUSETTS 02110
617/728-8750 Fax: 617/357-1866
.
ASSISTANT BAR COUNSEI TERENCE M. TROYER ANNE S. J. KAUFMAN SUSAN STRAUSS WEISBERG ALICE L. HAGEMAN ROGER GELLER
BRUCE T. ElSENHLT CATHLEEN C. CAVELL
ELLEN M. MEAGHER ROBERT I. WARNER JANE R. RABE
YVONNE P. TOYLOY
LINDA G. BAL'ER JOHN W. MARSHALL
FIRST ASSISTANT BAR COUNSEL CONSTANCE V. VECCHIONE NANCY E. KALTMAN
July 27, 1998
Mr. Alphonse Mourad 125 West Street HydePark,MA 02136
RE: BBO File NofsV C1-97-723B (Harold B. Murphy, Esq.;> Dear Mr. Mourad:
.
I have reviewed and investigated your allegations of misconduct regarding Attorney Harold B. Murphy.
Your allegation that Attorney Murphy did not disclose to you that his firm represented Mr. Gray in other prior or pending matters cannot be substantiated with the degree and certainty of evidence necessary for successful prosecution. It does appear that trustee Gray filed two false, or at least grossly inaccurate, disclosure statements with the Bankruptcy Court. However, after exhaustive review, we have been unable to prove that either Choate, Hall and Stewart or Hanify and King had prior knowledge of, or participated in the falsity of the two filings.
In dismissing this file, we express no opinion as to any civil liability that Attorney Murphy or trustee Gray may have and the file may be reopened if any other agency finds any professional misconduct.
The matter is now concluded, and no further proceedings will be instituted by this office. This decision has been reviewed by a member of the Board of Bar Overseers, who concurs in the dismissal.
BruceT. Eisenhut Assistant Bar Counsel
RTFAImm
----------------------------------------------
UNITED STATES BANKRUPTCY COURT DISTRICT OF MASSACHUSETTS (Eastern Division)
.
In re:
Chapter 11 V & M MANAGEMENT, INC.,
Case NO.; 96-10123-CJK
Debtor.
.
AMENDED VERIFIED STATEMENT OF STEPHEN S. GRAY
In accordance with Rule 2007.1 of the Federal Rules of Bankruptcy Procedure, I, Stephen S. Sray. hereby verify and state as follows:
.
1. On April 2, 1996, this Court enccsred an order allowing my appointment ae Chapter 11 Trustee of V&M Management, Inc., the Debtor in this chapter 11 case (the "Debtor").
.
2. I have moved this Court for the entry of an order authorizing the employment of Choate, Hall 6 Stewart ("CH&S") and Paul D. Moore, P.O., of chat finn as my counsel in this matter. I am filing this Amended Verified Statement solely to disclose my connections with Mr. Moore.
.
3. I have consulted with the United Statej Trustee, counsel to the Debtor, the Examiner appointed by this Court and certain creditors of the Debtor. In addition. I have reviewed the Debtor's schedules and statement o; affairs and certain other papers filed in connection with this case. Based upon my consultations with the aforementioned parties and my review of the papers noted above, to the best of my knowledge, I do not have any connections with the Debtor, its creditors, any other party in interest, their respective attorneys and accountants,
the United State Trustee, or any person employed in the office of the united States Trustee except that:
- Paul D. Moore serves as counsel to me in my capacity as the Chapter 7 Trustee of TLX Communications, Inc. (Case No. 95-15916-JNF) and of C1M Communications, Inc. (Case No. 95-15917-JNF);
- Paul D. Moore serves as counsel to me in my capacity as the Chapter 11 Trustee of William T. Bates d/b/a New England Physical Therapy and Sports Medicine (Case No. 94-13S96-CJK;
- Paul 0. Moore serves as counsel to me in my capacity as the Chapter 7 Trustee of Fidelity Guaranty Mortgage Corparation (Case No. 92-20375-WCH);
- Paul 0. Moore serves as counsel to me in my capacity as the Chapter 7 Trustee of Northeast Building Corporation (Case No. 91-16758-WCH); and
- Paul D. Moore serves as Debtor's counsel in several matters in which The Recovery Group and roe serve as Turnaround Consultant or as Disbursing Agent.
4. 1 hereby represent that I am a disinterested person as that term is defined in Section 101(14) of the Bankruptcy Code.
Executed this 10 day of April, 1996 under the laws of the United States of America.

Stephen S. Gray
The Recovery Group
270 Congress Street
Boston, MA 02210
(617) 482-4242
-------------------------------------------------
UNITED STATES BANKRUPTCY COURT
DISTRICT OF MASSACHUSETTS
.
In RE
V & M MANAGEMENT. INC. CHAPTER 11
CASE NO. 96-101233-CJK
Debtor
.
VERIFIED STATEMENT OF STEPHEN S. GRAY
.
In accordance with Rule 2007.1 of the Federal Rules of Bankruptcy Procedure. I. Stephen S. Gray. hereby verify and state as follows:
.
1. On April 2,1996. this court entered an Order allowing my appointment as Chapter 11 Trustee of the above Debtor.
.
2. The undersigned has consulted with the United States Trustee, the Court* appointed examiner, counsel to the Debtor and certain creditors of the above Debtor, and the Debtor and reviewed the Debtor's schedules and statement of affairs and other papers filed in connection with this case. Based upon a review of these papers and discussions with the aforementioned parties, the undersigned does not have any connections with the Debtor, creditors, any party in interest, their respective attorneys, the United States Trustee or any person employed in the Office of the United States Trustee. The undersigned submits and so states that he is a "disinterested person" in this case.
Signed under penattes of perjury this 5th day of Apri 1996.
STEPHEN S. GRAY
The Recovery Group
270 Congress Street
Boston, MA 02210
617/482-4242
-------------------------------------------------
UNITED STATES BANKRUPTCY COURT
DISTRICT OF MASSACHUSETTS
.
In re Chapter 7Case No. 93-12482-CJK NEPONSET RIVER PAPER COMPANY
f/k/a PATRIOT PAPER CORPORATION,
Debtor.
.
STATEMENT OF TRUSTEE RESPECTING MOTION FOR RELIEF FROM AUTOMATIC STAY
.
Now comes Stephen S. Gray, Chapter 7 Trustee of the above-entitled Debtor (the "Trustee"), by his attorneys, and respectfully states that he has no opposition to the Motion For Relief From Automatic Stay Where Recovery Is Limited To Debtor"s Insurance Policy with respect to Frederick E. Sheerer v. Consolidated Rail Corporation. Civil Action No. 95-12682RGS, pending before the U.S. District Court for Massachusetts provided that any recovery is limited to the extent of applicable insurance coverage and no appearance or participation by Trusteed counsel in the matter shall be required.
Respectfully submitted,
Stephen S. Gray,
Chapter 7 Trustee
Certified to be a true and
correct copy of the original. attorneys,
James M. Lynch, Clerk
U.S. Bankruptcy Court
District of.Massachusetts

EXHIBIT G:

See IRS Tax Litigation on website.
www.bostonmandelascandal.com
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Gray's Dismisal Motion | Order Change Venue Denied