Case 16-04035 Doc 20 Filed 03/17/17 Entered 03/17/17 11:18:40 Desc Main Document Page 1 of 4 UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA '5::r ceem In re ST. PRUL, my Bky No. 15-42460 Paul Hansmeier, Chapter 7 Debtor. Daniel M. McDermott, United States Trustee, Plaintiff ADV No. 16?04035 V. Paul Hansmeier, Defendant. DEFENDANT PAUL R. HAN BRIEF IN RESPONSE TO THE MOTION TO COMPEL Paul Hansmeier 3749 Sunbury Alcove Woodbury, MN 55125 (651) 399-1583 prhansmeier@gmail.com March 17, 2017 Case 16-04035 Doc 20 Filed 03/17/17 Entered 03/17/17 11:18:40 Desc Main Document Page 2 of 4 MEMORANDUM I Debtor Paul Hansmeier does not substantively oppose the US. Trustee?s entitlement to take discovery in this case, including by making document requests. Hansmeier?s only request is that the Court order counsel for the US. Trustee to engage in a good faith and substantive ?meet and confer,? with Hansmeier, so that Hansmeier is not forced to engage in purely duplicative document production. In his underlying bankruptcy case Hansmeier has produced an estimated thousands of pages of documents. Hansmeier ?rst produced substantial documents during his Chapter 13 case in connection. with a Rule 2004 examination. Hansmeier then produced substantial additional documents when his case was converted to Chapter 7. The Trustee?s document requests substantially overlap the document requests that Hansmeier has responded to during this case and, on information and belief, the Trustee has access to those documents. Hansmeier has attempted to engage with counsel for the Trustee to learn the Trustee?s position on what document requests do not overlap with prior document requests, so that Hansmeier may focus his production in a manner that minimizes the burden to him and, frankly, the Trustee. The Trustee has, to date, re?ised to provide a concrete indication of what he believes is outstanding. Ideally, counsel for the Trustee will reach out to Hansmeier before the hearing on his Motion to Compel so that the parties can resolve the outstanding document production issue without needless burdening the Court. Notwithstanding his certi?cation to the Court otherwise, Hansmeier does not believe that the Trustee ful?lled the spirit of the meet and confer requirement prior to bringing his motion. The last communication Hansmeier received before the Trustee?s Case 16-04035 Doc 20 Filed 03/17/17 Entered 03/17/17 11:18:40 Desc Main Document Page 3 of 4 motion was ?led is attached as an exhibit to this memorandum. Regardless, however, nothing is preventing the Trustee from engaging in a good faith meet and confer with Hansmeier now so that the parties may complete the pre?trial discovery process in a manner that is consistent with the rules. Respectfully submitted, March 17, 2017 J's/ Paul R. Hansmeier 3?13?20?7 Case 16-04035 Doc 20 M?ntePeWM/Ete?l?mellzm?o Desc Main Document Page 4 of 4 Paul Hansmeier McDermott v. Hansmeier 1 message Kreuziger, Colin (USTP) Wed, Feb 1, 2017 at 9:37 AM To: "mail@classjustice.org" Good morning Paul: Now that it appears many of the disputed claims issues have been resolved in your bankruptcy case, I would like to know if you are planning on waiving your discharge. i also note that you have been indicted so I assume you will invoke the Fifth Amendment to avoid testifying at trial in this case. That would allow the bankruptcy court to draw numerous adverse inferences against you. If you are amenable to waiving your discharge, you will need to ?le a motion for approval of the waiver with the bankruptcy court. i can provide you with recent examples it you would like. If not, we need to discuss when you will provide responses to my document production "requests. Thank you. Colin Kreuziger Special Assistant United States Attorney Trial Attorney United States Department of Justice Office of the United States Trustee Region 12 1015 US. Courthouse 300 4th St 9 Minneapolis, MN 55415 X969 hitpsu'imail 7641b9fBQO&view=pt&q= cot i n&qs=true&search= 1l2