Gordon Silver Attorneys At Law Ninth Floor 3960 Howard Hughes Pkwy Las Vegas. Nevada 89169 (702) 796-5555 Case 13-20348-Ied Doc 295 Entered 04/07/14 13:57:24 Page 36 of 44 124. Incredibly, at the 341 Hearings, Dr. Scoccia also testi?ed that Debtor had been ?nanced by ?the Bank of Scoccia,? and that he had not taken monies owed in order to ?pay the troops,? 341 II Tr., Ex. B., p. 29:5?24. However, as with the millions of dollars in payments to Owie?BooBoo and Tuna Park between 2004 and 2011 as discussed above that slipped Dr. Scoccia?s mind, he apparently forgot that his remaining entities had received at least $573,000 from Debtor in 2013 alone.28 SE V. Scoccia Tr., Ex. P, pp. 8228-18, 143:2-14522, and Ex. 6. 125. Dr. Scoccia?s lapse in memory is particularly perplexing as both Dr. Scoccia and Ms. Otero have acknowledged that since at least October 2013, Ms. Otero would prepare a ?hot list or a plan list? and then Dr. Scoccia and Ms. Otero would decide what would be paid; however, Dr. Scoccia always made the ?nal determination. V. Scoccia Tr., Ex. P, pp. 125:5- 12; Otero Tr., Ex. L, pp. 94:20?23. 126. Beyond what appears to be self?dealing, Dr. Scoccia and his entities are facing signi?cant potential avoidance actions for the payments tendered not only on the eve of the bankruptcy ?ling, but potentially for the last four years. The appearance of self-dealing and substantial potential avoidance actions, coupled with Dr. Scoccia extensive history of removing anyone that challenges him, evidences that an extension of exclusivity will solely serve to hinder a consensual plan, not further it. 127. This concern is heighted by the fact that Dr. Scoccia is facing personal tax liens for his unpaid individual taxes from the last two years of over $350,000. V. Scoccia Tr., Ex. P, pp. 190:14-193:24 and Exs. 24, 25, and 26. Additionally, Dr. Scoccia is co-obligated with Debtor for payroll taxes of approximately $400,000. Q, pp. 130:10-131:17. K. Nevada State?s Expression of Concern Regarding Current Management and Operations. 128. On March 12, 2014, the Department of Health and Human Services Division of Public and Behavior Health (the ?Dept. of issued a letter to Mr. Seelig, a copy of which was provided to the County by the Dept. of HHS (the ?March l2 Letter?). Ex. X. 28 While the County issued a subpoena in January 2014 for the records of all payments made from Debtor to the Scoccia Entities in 2011 and 2012, these records still have not been produced. 32