ThinkTank
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Response to Debtor's Motion to Dismiss Texas Equusearchs Complaint Objecting to Dischargeability of Debt
June 26, 2013
https://docs.google.com/file/d/0B7DjeAMt_BpIZ3hVakdNWmlsUms/edit?usp=sharing
page 2 - "The bankruptcy discharge is intended for the "honest but unfortunate debtor."
Here, the Debtor is neither.
The Plaintiff's [TES] claims asserted in the Complaint against the Debtor [Casey Anthony] center on the fraudulent and material misrepresentations and omissions the Debtor made to the Plaintiff concerning the whereabouts and living status of her daughter, Caylee Marie Anthony...
... Plaintiff [TES] objects to the dischargeability of the damages suffered by the Plaintiff as a result of the Debtor's fraud pursuant 11 U.S.C. 523(a)(2)(A) and (a)(6).
page 6 - In fact, the Debtor thanked Mr. Miller and the Plaintiff [Texas EquuSearch] for assisting in the search for Caylee.
These statements later proved to be blatantly false as the Debtor knew at the time she made these statements that Caylee had actually died in the family swimming pool at the Residence on June 16, 2008.
The Debtor certainly received a direct benefit from the Plaintiff's searches for Caylee.
By not alerting the Plaintiff that Caylee was not missing and had actually died in the Swimming Pool on June 16, 2008, the Debtor was able to maintain the appearance of ignorance and innocence as to Caylee's disappearance and death. The Plaintiff's searches for Caylee allowed the Debtor to continue to portray herself as the worried mother desperately hoping that her
page 13 - daughter was still alive and would be safely returned to her family.
The Plaintiff's searches for Caylee also provided the Debtor a means to deflect attention away from her, and focus on the searches for Caylee. Therefore, the Debtor received a direct benefit from the Plaintiff's searches for Caylee.
... the Debtor, directly (and through her parents) told Mr. Miller that Caylee had
page 14 - been abducted and was still alive, and thanked him and the Plaintiff [Texas EquuSearch] for assisting in the search for Caylee. Moreover, Casey never once corrected or otherwise disagreed with these false statements and alerted the Plaintiff that Caylee was not actually missing, but in fact she had died in the Swimming Pool on June 16, 2008.
June 26, 2013
https://docs.google.com/file/d/0B7DjeAMt_BpIZ3hVakdNWmlsUms/edit?usp=sharing
page 2 - "The bankruptcy discharge is intended for the "honest but unfortunate debtor."
Here, the Debtor is neither.
The Plaintiff's [TES] claims asserted in the Complaint against the Debtor [Casey Anthony] center on the fraudulent and material misrepresentations and omissions the Debtor made to the Plaintiff concerning the whereabouts and living status of her daughter, Caylee Marie Anthony...
... Plaintiff [TES] objects to the dischargeability of the damages suffered by the Plaintiff as a result of the Debtor's fraud pursuant 11 U.S.C. 523(a)(2)(A) and (a)(6).
page 6 - In fact, the Debtor thanked Mr. Miller and the Plaintiff [Texas EquuSearch] for assisting in the search for Caylee.
These statements later proved to be blatantly false as the Debtor knew at the time she made these statements that Caylee had actually died in the family swimming pool at the Residence on June 16, 2008.
The Debtor certainly received a direct benefit from the Plaintiff's searches for Caylee.
By not alerting the Plaintiff that Caylee was not missing and had actually died in the Swimming Pool on June 16, 2008, the Debtor was able to maintain the appearance of ignorance and innocence as to Caylee's disappearance and death. The Plaintiff's searches for Caylee allowed the Debtor to continue to portray herself as the worried mother desperately hoping that her
page 13 - daughter was still alive and would be safely returned to her family.
The Plaintiff's searches for Caylee also provided the Debtor a means to deflect attention away from her, and focus on the searches for Caylee. Therefore, the Debtor received a direct benefit from the Plaintiff's searches for Caylee.
... the Debtor, directly (and through her parents) told Mr. Miller that Caylee had
page 14 - been abducted and was still alive, and thanked him and the Plaintiff [Texas EquuSearch] for assisting in the search for Caylee. Moreover, Casey never once corrected or otherwise disagreed with these false statements and alerted the Plaintiff that Caylee was not actually missing, but in fact she had died in the Swimming Pool on June 16, 2008.