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Law Office of Barry R. Wegman

Barry R. Wegman SBN 127356
2 7506 Collett Ave
Van Nuys, California 91406
3 (818) 570-9312
Email: [email protected]
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Attorney for Plaintiff, Bob Atchison

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UNITED STATES BANKRUPTCY COURT

CENTRAL DISTRICT OF CALIFORNIA

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LOS ANGELES DIVISION

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In re:

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OMA MCCONNELL,

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Debtor.
BOB ATCHISON,

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Plaintiff,
v.

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OMA MCCONNELL also known as

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ALEXANDRA MCCONNELL,
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Defendant.

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Case No.: 2:14-bk-14501-BB

Chapter: 7
Adv No.: 2:14!ap!01420!BB
RESPONSE BY CREDITOR BOB
ATCHISON TO MOTION FOR
CONTEMPT, SANCTIONS AND
DAMAGES FOR VIOLATION OF 11
U.S.C. 362; DECLARATION OF BOB
ATCHISON
Date: November 18, 2014
Time: 2:00 P,M,
Ctrm: 1475

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TO THE HONORABLE SHERI BLUEBOND, JUDGE, DEBTOR OMA

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MCCONNELL, IN PRO SE AND TO INTERESTED PARTIES:

DECLARATION OF BOB ATCHISON

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I, Bob Atchison, declare:

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1. That I am over the age of 18 and competent to make this declaration upon my own

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personal knowledge. If called to testify to the matters stated herein below, I could do so

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competently and under oath. I am a creditor of Debtor Oma McConnell.

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2. Without going into all the pre-history, I obtained a judgment against Debtor Oma

McConnell in Texas in 2005. Essentially, she retained me and failed and refused to pay me.

All I ever got were false promises and excuses.

3. Post judgment, Debtor did everything she could to frustrate and delay recovery on

the judgment, including accusing me of perjury and forging documents. But my Texas

attorney sought enforcement through post-judgment discovery procedures. Debtor failed to

respond to any of them. The following events all took place before Debtor filed her

bankruptcy on March 5, 2012. On July 25, 2011 an Order to appear for her deposition was

issued. She did not appear. On September 12, 2011, a motion to hold her in contempt was

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filed and an order imposing sanctions was issued on October 17, 2011. When she continued

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to refuse to appear or provide any discovery, a second motion for sanctions was filed on

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January 6, 2012. That motion was granted. When she continued to frustrate our efforts, an

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Order to Show Cause was issued on January 17, 2012 for her appearance in the Texas court

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on February 17, 2012. She didnt appear. On March 5, 2012, my attorney filed a motion for

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a bench warrant to be issued against Debtor. This is the same date she filed her second

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bankruptcy, a Chapter 7 entitled In re Oma McConnell, bearing case number 2:12-bk-17945-ER.

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4. At the time my attorney filed the motion for a bench warrant in the Texas court on

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March 5, 2012, I had no knowledge that Debtor was filing her bankruptcy the same day.

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Her affidavit at page 25 of her moving papers admits she failed to appear at a judgment

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creditors examination on March 5, 2012 and this caused her to file her emergency petition

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on March 5, 2012. I know of no way in which I or my attorney could have known this from

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Texas, we are two hours ahead of California.

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5. After the motion for a bench warrant was filed, but before it was heard or a

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warrant issued, I learned of Debtors 2012 Chapter 7 bankruptcy filing. I am not an attorney

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and do not know bankruptcy laws, but I did understand that it might impact our efforts in the

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Texas court. To make sure we were not making a mistake, I spoke with my attorney, Roger

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B. Borgelt, and told him I had learned of Debtors 2012 bankruptcy filing. I was told by Mr.

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Borgelt that the warrant was going to be issued because the Debtor failed to appear at an
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Order to Show Cause set by the Texas court. The motion and the anticipated warrant did not

seek assets of the Debtor and was in response to her violation of a court order, not our

efforts of collection. Based on this advice, I thought nothing more about it; believing we

were in our rights. The motion was heard on March 26, 2012 and the Texas court issued a

bench warrant that merely required the Debtor to appear in court. A true copy of the

Warrant is attached hereto as Exhibit A and incorporated herein by reference.

6. After reviewing Debtors motion and argument, my California attorney has

advised me that Mr. Borgelts advice was incorrect. I understand that nothing we did up to

the filing of the motion was a violation, as the stay hadnt started. The filing was done

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without any knowledge of the bankruptcy. But I now know that I should have had the

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motion withdrawn. I didnt know that then, but I do now. I will contacted Mr. Borgelt and

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ask him to make sure the warrant is withdrawn. I hope to have something to show this

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Court or at least a further declaration stating that this has been accomplished by the time of

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the hearing.

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7. Nothing has been done to further my efforts to obtain recovery that havent been

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lawful. Most of the effort has been in two of Debtors bankruptcies. Just prior to her

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current bankruptcy, I had my Texas judgment domesticated in California and had scheduled

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a Debtors exam, but it did not go forward after her current filing and she has not

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demonstrated any further efforts in that direction.

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8. I understand that the penalty for violating the stay depends on the level of that

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violation. Certainly, other than obtaining the warrant, nothing further has occurred. No

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effort has been made to have Debtor arrested in California. In fact, in her blog, entitled Rob

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Moshen and his lies, she wrote about the bench warrant and its impact on her at:

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http://omahamou.com/oma/viewtopic.php?f=1&t=57&p=9318&hilit=bench+warrant#p9318

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where she wrote on August 1, 2012 at 2:28 pm:

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I left Texas today to return to Los Angeles and my name was ran

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through the computer data base not one time but twice by not only a

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representative of the US government but by the Texas law enforcement and no

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PROOF OF SERVICE OF DOCUMENT

I am over the age of 18 and not a party to this bankruptcy case or adversary proceeding. My business address is:
7506 Collett Ave., Van Nuys, CA 91406

A true and correct copy of the foregoing document entitled (specify) RESPONSE BY CREDITOR BOB ATCHISON TO
MOTION FOR CONTEMPT, SANCTIONS AND DAMAGES FOR VIOLATION OF 11 U.S.C. 362; DECLARATION OF
BOB ATCHISON will be served or was served (a) on the judge in chambers in the form and manner required by LBR
5005-2(d); and (b) in the manner stated below:

1. TO BE SERVED BY THE COURT VIA NOTICE OF ELECTRONIC FILING (NEF): Pursuant to controlling General
Orders and LBR, the foregoing document will be served by the court via NEF and hyperlink to the document. On (date)
11/6/14, I checked the CM/ECF docket for this bankruptcy case or adversary proceeding and determined that the
following persons are on the Electronic Mail Notice List to receive NEF transmission at the email addresses stated below:

Barry R Wegman
Baruch C Cohen
Wes Avery (TR)
James W Charlton
United States Trustee (LA)

brweg@sbcg lobal. net

[email protected]
Wam [email protected]
[email protected]
ustpregion16.1a.ecf@usdoj .gov

Service information continued on attached page

2. SERVED BY UNITED STATES MAIL:

On (date) 11/6/14 I served the following persons and/or entities at the last known addresses in this bankruptcy case or
adversary proceeding by placing a true and correct copy thereof in a sealed envelope in the United States mail, first class,
postage prepaid , and addressed as follows. Listing the judge here constitutes a declaration that mailing to the judge will
be completed no later than 24 hours after the document is filed .
Honorable Sheri Bluebond, Judge
United States Bankruptcy Court
255 East Temple Street, Suite 1482
Los Angeles, CA 90012

DebtorOma McConnell
145 S. Glenoaks, 305
Burbank, CA 91502

Service information continued on attached page

3. SERVED BY PERSONAL DELIVERY, OVERNIGHT MAIL. FACSIMILE TRANSMISSION OR EMAIL (state method
for each person or entity served): Pursuant to F.R.Civ.P. 5 and/or controlling LBR, on (date)
, I served
the following persons and/or entities by personal delivery, overnight mail service, or (for those who consented in writing to
such service method) , by facsimile transmission and/or email as follows. Listing the judge here constitutes a declaration
that personal delivery on, or overnight mail to, the judge will be completed no later than 24 hours after the document is
filed.

Service information continued on attached page

I declare under penalty of perjury under the laws of the United States that the f

11/7/12
Date

Barry R. Wegman
Printed Name

This form is mandatory. It has been approved for use by the United States Bankruptcy Court for the Central District of California.
June 2012

F 9013-3.1.PROOF .SERVICE

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Exhibit A

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Exhibit B

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Oma Hamou View topic - Rob Moshein and His Lies....

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http://omahamou.com/oma/viewtopic.php?f=1&t=57&p=9318&hilit=ben...

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an affidavit as has some of the women he paid for sex and or supported them...another person has provided an
affidavit saying Hamid paid him to use a room inside of his home so he could bring women over and have sex
with them....I have never received in excess of $50,000 in cash or gifts from Hamid...
Sandman
Posts: 1214
Joined: Tue Mar 11, 2008 9:02 pm
Website
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Re: Rob Moshein and His Lies....

by Oma Hamou on Wed Aug 01, 2012 2:28 pm

I left Texas today to return to Los Angeles and my name was ran through the computer data base not one time but twice by
not only a representative of the US government but by the Texas law enforcement and no mention of any civil bench
warrant for my arrest. Much to the dismay of both Bob Atchison and Rob Moshein, I was able to enjoy my short stay in
Texas FREE as a bird!
When I got back to LA I also learned someone connected to the Alexander Palace Time Machine history forum had made
new complaints about me stating amongst other things, my house was dirty. For someone to say my house is dirty they

11/6/2014 5:53 PM

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would have had to commit the crime of tresspassing by jumping over the fence to peer through the windows or entered the
house and since I know every person who has been in my house the only other deduction is the other. Patrick and his friends
as well as each of you have been warned and some of you have been warned by members of law enforcement that you are
not allowed to commit crimes against me. When the authorities came to my residence and saw the house was basically clean
just carpets needed to freshening, saw my house maids and others they told me the recent complaints made are in their
opinion are lies, just people who they believe have it in for me. The actions by the individuals who made these recent
complaints further demostrate the intent this group of individuals will go to harm me. Animal control was also called by the
same group of individuals came to my home and was concerned about 3 of my cats because they are in the late stages of
their illness and much to the dismay of the individuals who placed those calls to this agency they did not remove any of my
animals. The new complaints made asbout me demonstrate to All this group of individuals connected to the Alexander
Palace Time Machine history forum are the product of cowards, liars who do felonious acts that show an ongoing pattern of
stalking, harassment and threats to name but a few.
Oma Hamou
Posts: 3902
Joined: Sat Dec 08, 2007 9:40 pm
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Re: Rob Moshein and His Lies....

by Oma Hamou on Wed Aug 01, 2012 5:02 pm
Blake Springpasture said...
I see that Hamou is still up to her old tricks.
Old tricks? This coming from a member of the Alexander Palace Time Machine history forum who publishes lies about
police officers and others. I don't know who is using this web account, Bob, Rob or Mike Pyles or some other crazy but you
all act in unison to do the same things over and over making claims that are libelous, defamatory and false concerning me.
Your just a group of nuts.
The nitwit doesn't seem to realize that between 2005 and 2010 ALL airlines that are members of the
International Air Transport Association (including American Airlines) began putting bar codes on their boarding
passes.
The boarding pass to "prove" she was in Texas today is an old pass from years ago.
Typical.
August 1, 2012 4:53 PM
I deliberately removed everything from that boarding pass because I didn't want you to be able to stalk me as far as where I
had gone too. I assure you, when I spoke with law enforcement concerning the newest complaints made about me by you
and your ilk, I was able to produce the above boarding pass that contained the missing information I removed. This is just
one more of your outrageous and idiotic lies as I will be able to produce this boarding pass in it's origianl form in court and
prove your matter of fact statement is not only false, libelous and defamatory.
Oma Hamou
Posts: 3902
Joined: Sat Dec 08, 2007 9:40 pm
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Re: Rob Moshein and His Lies....

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