After obtaining an approximately $725,000 trial judgment against a client’s former business partner, Mr. Clayton began to collect against the defendant’s real-estate holdings, and also bank accounts, even as the defendant pursued appeal.  But then, just two hours before the New Jersey Superior Court issued an Order dismissing the defendant’s appeal, the defendant responded by filing a Chapter 13 bankruptcy.  In light of the suspicious timing of the bankruptcy filing – and the fact that the debtor did not even actually qualify for a Chapter 13 in the first place – Mr. Clayton filed a motion in Bankruptcy Court to retroactively annul the automatic stay and validate the Superior Court’s dismissal Order.  Holding that the debtor had engaged in “inequitable conduct,” the Bankruptcy Court agreed, here, and retroactively lifted the stay and affirmed the validity of the Superior Court’s dismissal Order.  Next, Mr. Clayton filed a motion to convert the Chapter 13 to a straight Chapter 7 liquidation proceeding (which was granted), and subsequently opposed the debtor’s follow-up motion to convert the bankruptcy to a more complex and time-consuming  Chapter 11 proceeding (which was denied).  As a result, the bankruptcy is currently proceeding as a Chapter 7 liquidation of all of the debtor’s non-exempt assets (including approximately 20 real-estate investment properties) for the benefit of creditors such as Mr. Clayton’s client.