VIRGINIA: Before the Virginia State Bar Disciplinary Board

In the Matter of

LAURA REED WRIGHT VSB Docket No.. 17-080-107279 Attorney at Law

CONSENT TO REVOCATION ORDER On March 30, 2018, came Laura Reed Wright and presented to the Board an Affidavit

Declaring Consent to Revocation of her license to practice law in the courts of this

Commonwealth. By tendering her Consent to Revocation at a time when allegations of

Misconduct are pending, the nature of which are specifically set forth in the attached affidavit

and Certification, Respondent acknowledges that that the material facts upon which the

allegations of Misconduct are pending are true.

The Board having considered the said Affidavit Declaring Consent to Revocation, and

Bar Counsel having no objection, the Board accepts her Consent to Revocation. Accordingly, it

is ordered that the license to practice law in the courts of this Commonwealth heretofore issued

to the said Laura Reed Wright be and the same hereby is revoked, and that the name of the said

Laura Reed Wright be stricken from the Roll of Attorneys of this Commonwealth.

Entered this 2nd day of April, 2018.

Virginia State Bar Disciplinary Board

By:_______________________________________________ Sandra L. Havrilak Second Vice Chair

Sandra L. Havrilak

Digitally signed by Sandra L. Havrilak DN: cn=Sandra L. Havrilak, o, ou, email=slhavrilak@havrilaklaw.com, c=US Date: 2018.04.02 10:42:01 -04'00'

VIRGINIA:

BEFORE THE VIRGINIA STATE BAR DISCIPI.INARY BOARD

IN TI IE MATIER OFI.AURA REED WRIGHT

VSB I)ocket No. 17-080-107279

AFFIDAVIT DECLARING CONSENT TO REVOCA 1 ION

Laura Reed Wright. after being duly sworn, states as follows:

1. That Laura Reed Wright was licensed to practice law in the Commonwealth of

Virginia on 10/15/1993:

2. That I.aura Reed Wright submits this Affidavit Declaring Consent to Revocation

pursuant to Rule of Court, Part 6, Section IV, Paragraph 13-28.

3. Ihat Laura Reed Wright's consent to revocation is freely and voluntarilyrendered, that Laura Reed Wright is not being subjected to coercion or duress, and that I.aura

Reed Wright is fully aware of the implications oí consenting to the revocation of her license to

practice law in the Commonwealth of Virginia;4. Laura Reed Wright is aware that there is currently pending before the Disciplinary

Board a Certification alleging Misconduct, the docket number for which is set forth above, and

the specific nature of which is here set furth:

On September 2, 2014, Respondent and her husband filed for bankruptcy underChapter 7 of Title 11 of the United States Code in the United States Bankruptcy Court forthe Western District oí Virginia.

On February 19.2015 the case was converted from a Chapter 7 case to a Chapter13.

On September 22,2016, the Chapter 13 Trustee filed a Motion to Dismiss thecase alleging that Respondent and her husband concealed assets from the Court,perpetrated a fraud upon the Court, and suborned perjury in the form ofa materially falseaffidavit she prepared and had her aunt sign detailing the source of funds to purchasehorses that she did not disclose to the Court.

Respondent also failed to disclose in the course of her bankruptcy proceeding acozintry club membership and the purchase ofa Jeep.

Jason Shorter, Esquire was assigned as the Chapter 13 I'rustee over Respondent'sbankruptcy case.

Mr. Shorter investigated Respondent's purchase oí' the horses in the context of herbankruptcy case,

Mr. Shorter conducted an examination under oath of Respondent as debtor,pursuant to 11 lJ.S.C. App. § 2004 ("2004 Examination").

While under oath, Respondent testified that the source of the $18,000.00 used tomake purchases oi horses for her daughter Jordyn was her grandmother, Aldene Reed.

During Mr. Shorter's 2004 examination, Respondent produced a notarizedaffidavit from her aunt, Robin Reed Poff, to corroborate her version of the source of thefunds used to purchases horses (-Poff Affidavit').

On August 2,2016, Mr. Shorter conducted a 2004 examination ofMs. AldeneReed.

f~ Ms. Reed testified under oath that she did not provide the funds as Respondenthad previously testified to under oath and pursuant to the Poff Affidavit.

Respondent had already previously testified under oath that she drafted the poffAffidavit and had Ms. Poff sign it,

b. On August 22,2016, Mr. Shorter conducted a 2004 examination, under oath, ofMs. Poff,

In response to questioning about the nature and veracity oflhe Poff Affidavit, Ms.Poff refused to answer any questions on the subject and instead invoked her right againstself-incrimination pursuant to the Fifth Amendment to the United States Constitution.

On September 22,2016 Mr. Shorter filed a Motion to Dismiss with 1 rohibition onDischarge of Debts or alternatively a Motion to Convert to Chapter 7.

5. Laura Reed Wright acknowledges that the material facts upon which the

allegations o fmisconduct are predicated are true; and

6. I.aura Reed Wright submits this Affidavit and consents to the revocation of

Ihis][herl license to practice law in the Commonwealth of Virginia because she knows that if the

disciplinary proceedings based on the said alleged misconduct were brought or prosecuted to a

conclusion. she could not successfully defend them,

Executed and dated on M*v- Ž-Ø, %-0(8

ctaRJiwp&&Laura Reed WrightRespondent

COMMONWEAI.TI 1 OF VIRGINIACITY/COUNTY OF Bll(11(1 Vii ta , to wit: L (l tl r ß W Í I giltThe foregoing Affidavit Declaring Consent to Revocation was subscribed and sworn to before

me by I.aura Reed Wright on IVI Cl ÏC+1/' 2.0~ 1.0 I 0

My Commission expires: NOV 38 , 2-Dl~ì. Sf:E*%RU@Ü'-o -ò..~7'gi::.. c,aryp~~f

RECEIVED

Oct 25, 2017

VIRGINIA: VIRGINIA STATE BAR

CLERK'S OFFICE

BEFORE THE EIGHTH DISTRICT SUBCOMMITTEE OF THE VIRGINIA ST ATE BAR

IN THE MATTER OF LAURA REED WRIGHT VSB Docket No. 17-080-107279

SUBCOMMITTEE DETERMINATION (CERTIFICATION)

On September 21, 2017, a meeting in this matter was held before a duly convened Eighth

District Subcommittee consisting of Jeffrey A. Crackel, Esquire, Michael M. Waldvogel, lay

person, and Malissa L. Giles, Esquire, Chair. Pursuant to Part 6, §IV,, 13-15.B.3 of the Rules

of the Supreme Court of Virginia, the Eighth District Subcommittee of the Virginia State Bar

hereby serves upon Laura Reed Wright, ("Respondent") the following Certification:

I. ALLEGATIONS OF FACT

1. At all times relevant, Respondent was a member in good standing with the Bar of the Commonwealth of Virginia.

2. Respondent was admitted to the practice of law in the Commonwealth of Virginia in October of 1993.

3. Prior to the events that comprise this Certification, Respondent had experience in representing clients on bankruptcy matters.

4. On September 2, 2014, Respondent and her husband filed for bankruptcy under Chapter 7 of Title 11 of the United States Code in the United States Bankruptcy Court for the Western District of Virginia.

5. On February 19, 2015 the case was converted from a Chapter 7 case to a Chapter 13.

6. On September 22, 2016, the Chapter l 3 Trustee filed a Motion to Dismiss the case based upon Respondent and her husband concealing assets from the Court, for the fraud that Respondent perpetrated upon the Court, and for suborning perjury in the form of a materially false affidavit she prepared and had her aunt sign detailing the source of funds to purchase horses that she did not disclose to the Court.

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7. Respondent also failed to disclose in the course of her bankruptcy proceeding a country club membership and the purchase of a Jeep.

8. Jason Shorter, Esquire was assigned as the Chapter 13 Trustee over Respondent's bankruptcy case.

9. Mr. Shorter investigated Respondent's purchase of the horses in the context of her bankruptcy case.

10. Mr. Shorter conducted an examination under oath of Respondent as debtor, pursuant to 11 U.S.C. App.§ 2004 ("2004 Examination'').

11. While under oath, Respondent testified th.at the source of the $18,000 .00 used to make purchases of horses for her daughter Jordyn was her grandmother, Aldene Reed.

12. During Mr. Shorter' s 2004 examination; Respondent produced a notarized affidavit from her aunt, Robin Reed Poff, to corroborate her version of the source of the funds used to purchases horses ("Poff Affidavit").

13. On August 2, 2016, Mr. Shorter conducted a 2004 examination of Ms. Aldene Reed.

14. Ms. Reed testified under oath that she did not provide the funds as Respondent had previously testified to under oath and pursuant to the Poff Affidavit.

15. On August 22, 2016, Mr. Shorter conduct ed a 2004 examination, under oath, of Ms. Poff.

16. In response to questioning about the nature and veracity of the Poff Affidavit, Ms. Poff refused to answer any questions on the subject and jnstead invoked her right against self­incrimination pursuant to the Fifth Amendment to the United States Constitution.

17. Respondent had already previously testified under oath that she drafted the Poff Affidavit and had Ms. Poff sign it.

18. When Respondent drafted the Poff Affidavit, she knew its contents to be false.

19. On September 22, 2()16 Mr. Shorter filed a Motion to Dismiss with Prohibition on Discharge of Debts or alternatively a Motion to Convert to Chapter 7.

20. In the Motion to Dismiss, Mr. Shorter set out a detailed chronology of the horse transactions that Respondent made and failed to disclose in the bankruptcy.

21. The Motion to Dismiss also sets out other fraudulent activity that the Respondent engaged in, in the course of her bankruptcy case.

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22. A copy of the Motion to Dismiss is attached hereto as Exhibit A and incorporated herein by reference.

23. During the course of the investigation of this case, Respondent told the Bar's investigator an inherently unbelievable scenario in which Ms. Poff delivered to her a bag filled with $ 18,000.00 in cash.

24. The Bar submits that statement is false and that Respondent made it knowing it to be false.

25. At the time she made the false statement to the Bar, Respondent knew that her grandmother had denied being the source of the $18,000.00.

26. The Bar attempted to contact Ms. Poff at her last known address and phone number concerning the contents of the Poff Affidavit and the various statements that Respondent made to the investigator.

27. Ms. Poff refused to cooperate with the Bar, and a gentlemen answerin g a phone number associated with Ms. Poff's residence refused to speak with Bar's investigator or acknowledge knowin g Ms. Poff.

II. NATURE OF MISCONDUCT

Such conduct by Respondent constitutes misconduct in violation of the following

provisions of the Ru! es of Professional Conduct:

RULE 3.3 Candor Toward The Tribunal

(a) A lawyer shall not knowingly:

(1) make a false statement of fact or law to a tribunal;

(2) fail to disclose a fact to a tribunal when disclosure is necessary to avoid assisting a criminal or fraudulent act by the client ;

( 4) offer evidence that the lawyer knows to be false. If a lawyer has offered material evidence and comes to know of its falsity, the lawyer shall take reasonable remedial measures.

(d) A lawyer who receives information clearly establishing that a person other than a client h as perpetrated a fraud upon the tribunal in a proceeding in which the lawyer is representing a client shall promptly reveal the fraud to the tribunal.

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(e) The duties stated in paragraphs (a) and (d) continue until the conclusion <>f the proceeding, and apply even if compliance requires disclosure of information protected by RuJe 1.6.

* * * * RULE3.4 Fairness To Opposing Party And Counsel

A lawyer shall not:

(c) Falsify evidence, counsel or assist a witness to testify falsely, or offer an inducement to a witness that is prohibited by law. But a lawyer may advance, guarantee, or pay:

*

(1) reasonable expenses incurred by a witness in attending or testifying;

(2) reasonable compensation to a witness for lost earnings as a result of attending or testifying;

(3) a reasonable fee for the professional services of an expert witness.

* * *

RULE 4.4 Respect For Rights Of Third Persons

In representing a client, a lawyer shall not use means that have no purpose other than to embarrass, delay, or burden a third person, or use methods of obtaining evidence that violate the legal rights of such a person.

* * * *

RULE 8.1 Bar Admission And Disciplinary Matters

An applicant for admission to the bar, or a lawyey already admitted to the bar, in connection with a bar admission application, any certification required to be filed as a condition of maintaining or renewing a license to practice law, or in connection with a disciplinary matter, shall not:

(a) knowingly make a false statement of material fact;

(b) fail to disclose a fact necessary to correct a misapprehension known by the person to have arisen in the matter;

* * * *

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RULE8.4 Misconduct

It is professional misconduct for a lawyer to:

(a) violate or attempt to violate the Rules of Professional Conduct, knowingly assist or induce another to do so, or do so through the acts of another;

(b) commit a criminal or deliberately wrongful act that reflects adversely on the lawyer's honesty, trustworthiness or fitness to practice law;

( c) engage in conduct involving dishonesty, fraud, deceit or misrepresentation which reflects adversely on the lawyer's fitness to practice law;

* * * *

III. CERTIFICATION

Accordingly, it is the decision of the Subcommittee to certify the above matter to the

Virginia State Bar Disciplinary Board.

EIGHTH DISTRICT SUBCOMMITTEE OF THE VIRGINIA ST ATE BAR

By ;lc./di•'\

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MaHssa L. Giles Subcommittee Chair

CERTIFICATE OF SERVICE

I certify that on be.,./o~QS,Wftiailed by certified mail a true and correct copy of the foregoing Subcommittee Determination (Certification) to Laura Recd Wright, Esquire, Respondent, at 2630 Gaylord Rd, Roanoke, VA 24018, Respondent's last address of record with the Virginia State Bar.

Assistant Bar Counsel

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Case 14-71222 oocO Filed 09122116 Entered 0912211sU 53:29 Document Page 1 of 7

IN THE UNITED STATES BANKRUPTCY COURT FOR TIIE WESTERN DISTRICT OF VIRGINIA

In re: Stacey J. Wright, Laura R. Wright,

§ § §

Case N<>. 14-71222

Debtor(s) Chapter 13

Desc Main

MOTION TO DISMISS WITH PROIDBITION ON FUTURE DISCHARGE OF DEBTS OR IN THE ALTERNATIVE, TO CONVERT THE CASE TO CHAPTER 7

NOTICE OF HEARING

TAKE NOTICE: A hearing will be held 011 this Motion on the 17th day of October, 2016, at 11:00 A.M., at the U.S. Bankruptcy Court, 2nd Floor, 21~ Church Avenue, SW, Roanoke, VA 24011.

NOW COMES CHRISTOPHER T. MICALE, TRUSTEE (hereinafter "Trustee"), moving to dismiss this Case with a prohibition of future discharge of debts, and shows as follows:

). LEGAL BASIS FOR DISMISSAL

1. Section 1307(c) of Title 11 provides that a case may be dismissed by the Court for "cause"; and under § 349(a), if a court so dismisses a case, the court may aJso> upon a showing of "cause", order that dismissal of the case is subject to a prohibition upon a debtor from seeking to discharge debts dischargeable in the case dismissed in any subsequent case brought under Title 11.

II. BACKGROUNDANDINTRODUCI10N

2. Stacey J. Wright ("Stacey Wright") and Laura R. Wright ("Laura Wright") filed their petition on September 2, 2014; the case was thereafter converted to chapter 13.

3. At this time, the Debtors are in default of their chapter 13 plan payments. 4. Laura Wright is an attorney and member of the Virginia State Bar and was admitted

in 1995 to the Bar of this Court. 5. Upon infonnation and belief, Laura Wright (under the name "Laura Kathryn

Reed'~ served as counsel for debtors in.numerous cases before this Court. 6. Pursuant to the confinnation order entered in this Case, the Trustee preserved the

right to pursue claims under§§ 544, 547 and 548 of the Bankruptcy Code. 7. After confinnation the Trustee learned that Laura Wright and/or her minor daughter

(hereinafter referred to as "J.W.") acquired the show pony 11Woodland's Jack Spanow'' (hereinafter "Jack Sparrow") in Aug1.1st 2014 for the sum of $18,000, thereby raising a question Wldc;r §§ 544 and 548 ~to how a minor ~hild ~ould produ~ $18~000.

VSB EXHIBIT

A

Case 14-71222 Doc02 Filed 09/22/16 Entered 09/22/16~53:29 Document Page 2 of 7

Desc Main

8. In investigating Jack Sparrow's purchase, it was learned that the Debtors continue to Lead a lifestyle a.typical of chapter 13 debtors, which has been concealed from creditors as a result of Laura Wright's perpetration of a continuing fraud upon this Court.

A. THE $18,000 PURCHASE OF JACK SPARROW

9. . On August 14, 2014,. Laura Wright, J,W,, and three others, traveled to the State of Maryland where Jack Sparrow was purchased.

10. In her 2004 Exam, Laura Wright ttstified that her grandmother, Aldene Reed, provided the $18,000 cash used to purchase Jack Sparrow.

11. Laura Wright continued to insist throughout her 2004 Exam that Aldene Reed purchased the animal for J.W. and that Aldene Reed financially supports J.W.'s riding.

12. Laure Wright even went so far as to testify that she and her husband Stacey Wright had signed a written agreement with Aldene Reed for J.W. 's benefit.

13. However, on August 29, 2016, Aldene Reed testified that she had not provided $18,000 to the Debt<m for Jack Sparrow's purchase, nor was she supporting J.W.'s riding.

14. Laura Wright's own father- Richard Reed - further testified, as power 9f attorney for Aldene Reed, that no written agreement existed between bis mother and the Debtors.

15. Furthermore, after the 2004 Exam of Laura Wright, Laura Wright, through her attorney, provided the Trustee with an affidavit to corroborate her story.

16. The affidavit provided by Laura Wright was eJCecuted by her aunt, Robin Poff, and purports to corroborate Laura Wright's.2004 Exam testimony.

17. However, when Robin Poff was deposed regarding the allegation that Aldene Reed provided the cash, Robin Poff invoked her 5th Amendment Right under the U.S. Constitution.

18. It is mot presently kn<>wn whether Laura Wright herself drafted the affidavit for her aunt Robin Poff.

B. THE SHOW COMPETITIONS AND TRAINING EXPENSES

19. Since before this Case was filed and continuing thereafter, J.W. has ridden in numerous shows and continued to train at a high level of cost.

20. Up until recent months, all of J.W.1s riding was assooiated with the entity known as Treybrook Fann, located in Boones Mill, Virginia.

21. To date, the Trustee has detennined that J.W. <:<>mpetcd in not less than thirty (30) shows throughout Virginia and surrounding states on Jack Sparrow or other animals.

22. Costs associated with this endeavor include transportation of animals, veterinary costs, boarding and upkeep, horse shoeing, competition fees, lodging, training, etc.

23. However, as explained above, Laura Wright testified that Grandmother Aldene Reed supports J.W.':s hobby.

24. However, no such agreement was produced by Richard Reed - Laura Wright's Father - who produced documents o:n behalf of Grandmother Aldene Reed.

25. Furthermore, in Stacey Wright's own 2004 Exam, he testified that he had never signed an agreement with Grandmother Aldene Reed for the benefit of J. W.

26. To date, the Trustee has not examined the Wright Family's b°*}tatements to see if the Debtors maintained this hobby on behalf of J.W.

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27. It was asked that Stacey Wright bring his s ·unTrust Banlc statements to his 2004 Ex.am so the Trustee could review the same; however, no su:ch statements were provided.

28. Nevertheless, expenses associated with Treybrook Fann alone over nearly one (l) years' time were in excess of Thirty Thousand Dollars ($30.000).

29. The amount referenced in the foregoing paragraph does not include competition fees, lodging, insurance, veterinary fees, training costs, etc.

C. THE SHOW PONY "MEADOWBROOK NEWSFLASH"

30. In December 2013, the Wright Family acquired the show pony Meadowbrook Newsflash (hereinafter "Newsflash").

31. This animal was owned by the Wright Family until sold in Jwte 2015 for the price of$6,500.

32. In a Facebook post Treybrook Fann posted to its Facebook pa.ge congratulating the Wright Family for the purchase of Newsflash, both Stacey Wright and minor J. W. "liked" the post.

33. Jn her 2004 Exam, Laura Wright was specifically asked about the Wright Family's ownership of horses and/or ponies before and during their bankruptcy.

34. At no time during h.er 2004 Exam did Laura Wright acknowledge anyone in the Wright Family had an ownership interest in Newsflash.

35. Yet -0n or about June 19, 20 I 5, Laura Wright executed a Bill of Sale in her own name purporting to transfer Newsflash for $6,500.

36. Jn th.e Schedule B filed September 2, 2014, the Wrights did not disclose any interest in any animals.

D. THE SHOW PONY "COVENANT HALEIGH,,

37. At one time, the Wright Family owned the show pony known as Covenant Haleigh ("Haleigh"), which minor J.W. routinely competed on in 2013 and 2014.

38. Jn her 2004 Exam, Laura Wright acknowledged the Wright Family's ownership of Haleigh.

39. However, when asked when the Wright Family transferred ownership of Haleigh, Wright testified that Haleigh was sold in early 2014 for a couple thousand dollars.

40. Yet.it is undisputed by Laura Wright's own daughter that Haleigh was sold in July 2014 to the Wooley Family of Canada, owners of Meadowlands Farm.

41. On or about July 22. 2014, Haleigh was sold for the purchase price of $10,000 to Shane Wooley, in conjunction with a transaction referred to fa the next section.

42. The :sale of Haleigh is not disclosed in the original Statement of Financial Affairs file,d September 2, 2014, or the subsequently amended Statement of Financial Affairs.

E. THE SHOW PONY "STERLING SILVER"

43. At the time Haleiglil was sold (July 22, 2014), another animal, Sterling Silver ("Silver"), was likewise sold to the Wooley Family of Canada. owners of Meadowlands Fann.

44. . Laura Wright acquired Silver by contract dated March 13, 2014, for the price of $4,000.00,, which Laura Wright herself signed.

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45. Silver was sold for the price of$5,000, and as a result of the sale of both Haleigh and Silver, a wire transfer was made to Treybrook Fann resulting in net payment of $14,965.00.

46. The next day (July 23, 2014), Treybrook Fann issued payment in the amount of $14,965.00 to Laura R. Wright on Check No. 3018 drawn on the account ofTreybrook Farm at Franklin Community Bank.

4 7. Taking receipt of Check No. 3018, Laura Wright endorsed the :same and negotiated it for cash in the amount of$14,965.00 at the main branch of Franklin Community Banlc.

48. Again, the transaction pertaining to Haleigh and Silver is not disclosed in paragraph ten (10) of the original Statement of Financial Affairs filed September 2, 2014.

49. Again, the transaction pertaining to Haleigh and Silver is not disclosed in paragraph ten (10) of the amen<ied Statem.entofFinancial Affairs filed November 12, 2014.

50. At no time during her 2004 Exam did Laura Wright acknowledge ownership of Silver, and her testimony regarding the disposition of Haleigh was untruthful.

51. Upon infonnation and belief, the funds acquired from the sale of Haleigh and Siiver made up the bulk of funds used to acquire Jack Sparrow.

F. THE SHOW PONY "FOXWRE BLUE POINT"

52. Shortly before filing their petition (September 2, 2014), Laura Wright purchased the animal known as Foxlore Blue P<iint ("Blue") for $7,100.00.

53. Blue was purchased via online auction through sporthorseauctions.com, and the precise source of funds used to acquire Blue is presently unknown.

54. Blue was subsequently sold on October 8, 201 S, for the price ofS6,000.00, which Wright took possession of via two checks, Nos. 3242 and 3243, in the amounts of $5,000.00 and .$I ,000.00, respectively.

55. Although Laura Wright was asked about the Wright Family's ownership interests in ponies and/or horses, Laura Wright never acknowledged ownership of Blue.

56. Notwithstanding Laun Wright's lack of acknowledgment regarding her or minor daughter J.W.'s ownership interest i11 Blue, Laura Wright executed the bill of sale for Blue in her name "obo [J.W.], Minor."

S1. Laura Wright and Stacey Wright did not acknowledge ownership of any animals in their Schedule B filed September 2, 2014.

58. Laura Wright and Stacey Wright did not list any gifts in their o:riginal Statement of Financial Affairs filed September 2, 2014, or the amended Statement of Financial Affairs filed thereafter.

G. THE SHOW PONY KNOWN AS "CONTANGA"

59. On May 29, 2015, Laura Wright acquired the show pony Contanga "oho [J.W.], minor" for .$8,000.

60. At no time during her 2004 Exam did Laura Wright acknowledge either her own or J.W.'s ownership of .COntanga when asked.

61. Contanga was subsecruently sold by bill of sale of June 29, 20 J 5, for the purchase price ofS7,500.

62. Beca11sc Contanga was acquired post-petition, there may not be: a duty to report this purc.hase in the schedules and documents filed with the Court.

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63. However, Laura Wright's concealment of this animal during her 2004 Ex.am further demonstrates the continuing fraud b~ing perpetrated by Laura Wright.

B. THE HUNTING HILLs COUNTRY CLUB MEMBERSHIP

64. In addition to the conduct referenced already, the Debtors were members of Hunting Hills Country Club, Inc. ("Hunting Hills'') prior to and during their bianlcruptcy.

65. · The Schedule B filed September 2, 2014, does not disclose any "interest" held by the Debtors i11 Hunting Hills.

66. The Schedule G filed September 2, 2014, represented that the Debtors had no executory contracts or unexpired leases.

67. However, on September 20, 2013, the Debtors submitted an application for membership to Hunting Hills and be.came members shortly thereafter.

68. At the time of their filing on September2, 2014, their membership for the year2014 was effective.

69. Just a few weeks after the petition filing, the Debtors paid Hunting Hills for their 2015 membership in full, a cost of $3,180.00.

70. Jn the Schedule B filed September 2, 2014, the Debtors represented total liquid non-rctirement account assets on hand of less than $500.00.

71 . The Hunting Hills membership was tenninated by Stacey Wright in the month of December 20 IS.

72. In addition to membership costs, the Debtors spent more than $3,000 on golf and food after filing bankruptcy up to termination of their membel'ship (actual total: $3, I 17.15).

I. THE 1389 FIELDGATE ROAD RENTAL PROPERTY

73. Jn addition to the conduct referenced already, the Debtors continued to rent out the 1389 Fieldgate Road Property, notwithstanding their stated intent to surrender the residence.

74. When the Debtors filed their petition, they indicated they held an interest in real estate located at 1389 Fieldgate Road, Salem, VA 24153.

75. The Debtors have previously explained in other proceedings in this cause that they couldn't afford the home.

76. In the confinned chapter 13 plan, the Debtors indicated that they would surrender the JJroperty to the primary mortgage creditor.

77. However, notwithstanding their stated intent to surrender the property, the Debtors have leased the property to one (1) or more individuals during this Case.

78. Stacey Wright testified at his 2004 Exam that someone has leased the 1389 Fieldgate Road Property, but he stated he did not know any of the details regarding this property.

79. To the extent a leasehold was in effect at the time oftbc Debtors' bankruptcy filing, no such leasehold is disclosed on Schedule G.

80. Furthcnnore, to the extent a leasehold was in effect at any rime a Schedule I was filed with the Court, no income is reported to the Court &om this leasehold.

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J. THE 1993 JEEP YJ WRANGLER

Desc Main

81. After the petition filing on September 2, 2014, the Debtors acquired a 1993 Jeep Y J Wrangler automobile.

82. Stacey Wright testified that the Jeep referenced in the foregoing paragraph was acquired for the sum of $3,000.

83. ln the Schedule B filed September 2, 2014, the Debtors represented total liquid non-retirement account assets on hand of less than $500.00.

84. Coupled with the payment of the Hunting Hills membership in September 2014, the Debtors had in excess of $6,000 cash available to them in September or October 2014 compared with the Schedule B they filed with the Court.

K. THE FRANKLIN COUNTY DISTRICT COURT CASE

85. On or about April 12, 2016, Laura Wright fi lecl a warrant in detinuc in the Franklin County General District Court aJleging Jack Sparrow was being wrongfully withheld.

86. The named defendant in the Franklin County General Dislrict Court Case is Treybrook Farm Ltd.

87. Although the Franklin County General District Court Case has not been fUIJy adjudicated at this time, Laura Wright did post a $16,000 cash bond to retrieve Jack Sparrow.

88. The source of funds used to post a S 16,000 cash bond is presently unknown to the Trustee.

Ill. CONCLUSION

89. The allegations set forth in the foregoing paragraphs one (1) through eighty-eight (88) are reincorporated as if set forth in this Conclusion in their entirety.

90. Notwithstanding her knowledge of bankruptcy law, the schedules and statements of financial affairs filed by Laura Wright and her husband in th is Case contain numerous omissions of material fact.

91. Indeed, only at the urging of the United States Trustee did tlte Wrights actually amend the original Statement of Financial Affairs to disclose the transaction regarding the Wrights' draw on their Member One Federal Credit Union line of credit, which facts gave rise to the United States Trllstee's adversary complaint filed during the chapter 7 case.

92. Now, when the Chapter 13 Trustee learned of the Debtors' lifestyle as set forth above, Laura Wright continued to omit information and provided spoken testimony which appears to be completely untrue given her own family member's contradictions and/or invocations of rights not to testify.

93. The sanction prescribed under Section 349(a) has been described as "severe"; however, given Wright's membership in the legal profession and her continuing attempt to conceal infonnation to the detriment of creditors, such sanction is warnnted in this case.

94. As has been said by other courts, bankruptcy is for the honest but unfortunate debtors that sc:c:k relief; it is not for the dishonest and fortUnate debtors who attempt to manipulate the process.

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95. Accordingly, the Trustee seeks that this Case be dismissed with a prohibition that Laura WrJght and Stacey Wright may never seek discharge <>f any of their scheduled debts in any subsequ~ntly filed bankruptcy proceeding.

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WHEREFORE, THE CHAPTER 13 TRUSTEE RESPECTFULLY PM YS THIS COURT THAT: A. An order be entered dismissing the above-referenced case pursuant to§ 1307(c); B. That such order contain a prohibition under § 349(a) providing that the ~bto~ be

prohibited from seeking discharge of any of the debts they scheduled in their schedules filed in this Case in any s.ubsequent case brought under Title l 1 of the U.S. Code;

C. Jn the alternative to dismissal, that this Case be CC>nverted to chapter 7 of Title 11; and D. That the Trustee,have such other relief the Court deems necessary and proper.

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OFFICE OF THE CHAPTER 13 TRUSTEE CHRISTOPBERT.MICALE.TRUSTEE

By: / s/ Tason 1J. Sfiorter JASON B. SHORTER, ESQ. Staff Attorney for the Office of the Chapter I 3 Trustee POST OFFICE Box 1001 ROANOKE, VA 24005-100 l (540) 342-3n4 (PH) (540) 342-3062 (FAX)

CERTFICA TE OF SERVICE

The Undersigned hereby certifies that on September 22, 2016 he uploaded a itrue and exact copy .t of the foregoing Motion to the Court's Electronic Case Filing System, notice of which shall be

sent by operation of the Court's Electronic filing receipt to all parties entitled to receive notice electronically, including, Counsel for the Debtors. Other parties were served, addressed as follows, via United States Mail, First Class, postage prepaid:

Stacey J. Wright Laura R. Wright 2643 Gaylord Road SW Roanoke, VA 24018

MOTNl471222.001-001

Isl Tason ~. Sfiorter

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