What is the amount you require to pay in order to close this case? The only point of further action is to generate legal fees for Mr. Gordon.

April 5 2017 Absolute power of Attorney to sell Property in Chile 
 
I had to leave the state because of the actions caused by this case, and it's participant creditors.
I will fill you in later on the circumstances of my situation, as it is particularly more difficult now for me to deal with this issue.
I have clearly found I am incompetent to deal with this case pro se.
I do not have an attorney, have not been able to find one, and am looking for one in Chile.
I have tried to pay the amount due, but Neil Gordon has never responded.
What is the amount you require to pay in order to close this case? The only point of further action is to generate legal fees for Mr. Gordon.
I believe that this case in Chile can not proceed because U.S. law requires tax returns to have been filed prior to the bankruptcy filing. 
If you proceed with this activity it will fail for several other reasons in Chile, and would only be a further waste of the estate.
 
Sincerely,
Claudio Avendano
   

 
 
On 2017-04-04 18:05, Matthews, William D. wrote:

Dear Mr. Avendaño,
 
Below is my message to you from March 3.  Attached are the documents that were attached to that message.  If you decline to cooperate with this procedure to get the properties in Chile sold, we will have no choice but to seek authority to ask our attorneys in Chile to file what is called an ancillary insolvency proceeding in Chilean court that will be connected to your bankruptcy case here in the United States.
 
 

William D. Matthews
Of Counsel
 

 

Arnall Golden Gregory LLP
171 17th Street NW, Suite 2100
Atlanta, GA 30363
p: 404.873.8670 f: 404.873.8671
william.matthews@agg.com | bio | linkedin | vcard | website

 

 

From: Matthews, William D. 
Sent: Friday, March 03, 2017 5:39 PM
To: 'claudio@metroecho.com'
Cc: Gordon, Neil C.; 'Roberto Villaseca'; Ricardo Reveco; Antonella Oberti; Jaime Puyol
Subject: Claudio Avendaño (Case No. 15-64523-PWB)

 
Dear Mr. Avendaño,
 
My name is William Matthews.  I am an attorney working for the Trustee, Neil Gordon, in your bankruptcy case. 
 
As you are aware, the Trustee has employed the firm of Carey y Cía in Chile as special counsel to assist in selling your real estate (lots) located in La Higuera.  At the firm of Carey y Cía, our main contacts are Roberto Villaseca, Ricardo Reveco, Antonella Oberti, and Jaime Puyol.  They are copied with this message.  A copy of the bankruptcy court’s order approving employment of the firm as special counsel is attached.
 
The firm of Carey y Cía has prepared the attached Power of Attorney which will enable the firm to proceed to sell the lots in Chile.  I believe that you have previously advised the Trustee that you will be willing to cooperate to execute such a document or any other documents as may be needed to allow the properties in La Higuera to be marketed and sold on behalf of your bankruptcy estate.  Please advise if you remain willing to cooperate.  If so, we will need to coordinate arrangements for your travel to the Chile consulate in Miami so that the document can be executed in the presence of consul.  Roberto Villaseca or one of his associates or assistants at Carey y Cía can coordinate with you to schedule your trip to the consulate.  We will also need to obtain authority from the bankruptcy court for the bankruptcy estate to pay for your round-trip flight to Miami, reasonable costs between the Miami airport to and from the consulate, and reasonable costs to and from your home to the Atlanta airport. 
 
Carey y Cía has also prepared a separate Power of Attorney that would mandate them to destine the proceeds to the bankruptcy estate, which needs to be signed separately.  Please let all of us know if you remain willing to execute the documents needed to sell the lots you own in Chile (as you previously advised), and Carey y Cía attorneys and assistants can begin to coordinate with you and the consulate to arrange your travel and to schedule a meeting at the consulate.
 
Thank you,

 

William D. Matthews
Of Counsel
 

             

Arnall Golden Gregory LLP
171 17th Street NW, Suite 2100
Atlanta, GA 30363
p: 404.873.8670 f: 404.873.8671
william.matthews@agg.com | bio | linkedin | vcard | website