National Judgment Recovery ("NJR") brought an action to determine that the $93,159.71 fraudulent conveyance judgment against Tyndall, as a "net winner" in the ZeekRewards pyramid scheme case, was nondischargeable under 11 U.S.C. § 523(a)(2)(A) as actual fraud.
The bankruptcy court denied a motion to dismiss two chapter 11 cases, which had employed the infamous 'Texas Two Step" to address (avoid? skirt?) liability for asbestos mass torts claims, holding that :
