Summary:

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.

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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 :

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Title 11 of the United States Code (the “Bankruptcy Code”) provides a fresh start to the “honest but unfortunate debtor.” Chapter 7 therefore permits a debtor to “discharge their outstanding debts in exchange for liquidating their nonexempt assets and distributing them to their creditors.” Dismissals in chapter 7 are governed by section 707 of the Bankruptcy Code. Section 707(a) governs all chapters of bankruptcy filings and applies when adequate “cause” is shown.