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Clerk, U.S. Bankruptcy Court

Western District of North Carolinal Crm

Ashley Austin Edwards

United States Bankruptcy Judge

UNITED STATES BANKRUPTCY COURT

WESTERN DISTRICT OF NORTH CAROLINA

CHARLOTTE DIVISION

In re: )

) Case No.: 24-31129

RYAN LASHON FORD, )

) Chapter 7

Debtor. )

ORDER AND OPINION DENYING MOTION FOR RECUSAL

THIS MATTER is before the Court upon the Amendment [sic] Motion for Recusal of

Trustee and Bankruptcy Administrator [Do. No. 207] (the “Motion”), which was filed by Ryan

Lashon Ford (the “Debtor’”) originally on July 10, 2025,' against the Chapter 7 trustee in the

Debtor’s case, Melanie D. Johnson Raubach (the “Trustee”), and Heather Culp as the Bankruptcy

Administrator for the Western District of North Carolina (the “Bankruptcy Administrator”).* The

' The Debtor’s amended motion, which is the version considered as to the merits by the Court with regard

to this Order, was filed August 29, 2025. Its predecessor (the “Original Motion’) is docketed at No. 131.

* Debtor’s Original Motion, the Motion, and her Reply to Objection of the Trustee [Do. No. 208] (the

“Debtor’s Reply”), all three identify as the Bankruptcy Administrator and seek the recusal of Heather

Culp, who is not the Bankruptcy Administrator, but the staff attorney for the Bankruptcy Administrator,

Court conducted a hearing on the Motion on September 8, 2025 (the “Hearing”). At the Hearing,

all parties appeared on behalf of themselves. Following the Hearing, the Court took this matter

under advisement and now renders its opinion.

FACTS AND PROCEDURAL HISTORY

I. Introduction

On December 23, 2024 (the “Petition Date”), the Debtor filed for bankruptcy under Chapter

7. Voluntary Petition [Do. No 1] (the “Petition”). Generally, Chapter 7 cases are straightforward

and offer distressed debtors an opportunity to discharge debt in an organized, transparent, and

efficient legal process. This pro se case is atypical with over two hundred filings in the last ten

months. The Debtor has filed no fewer than a dozen motions: a motion to dismiss the bankruptcy

proceeding, a motion to appear remotely, a motion to bring a laptop to court, two motions to

convert the case to one under Chapter 11 of the Bankruptcy Code, two motions to declare that

certain property is tribal property and not property of the bankruptcy estate, a motion to convert

the case to one under Chapter 13 of the Bankruptcy Code, a motion to refer certain matters to

mediation, a motion to compel the Trustee to provide a settlement amount to the Debtor, a motion

for a protective order to limit discovery, and a motion to recuse the Trustee and Bankruptcy

Administrator. Most of these motions have required responses from the Trustee and the

Bankruptcy Administrator as well as replies to the Debtor’s replies. The Court denied virtually all

of these motions.

Shelley K. Abel. Relatedly, some references to specific comments or exchanges made by the Bankruptcy

Administrator in this opinion came specifically from Ms. Culp.

II. Debtor’s Assets and the May Hearing

Before filing and within two years of the Petition Date, the Debtor transferred two

properties (the “Properties”) to a limited liability company wholly owned by the Debtor. While

the Debtor disclosed an interest in the Properties in the Petition, she significantly understated their

value by an estimated 90% and did not disclose the transfers (or any others) in response to question

18 of the statement of financial affairs, which asks whether the Debtor sold, traded, or otherwise

transferred any property to anyone within the two years before the Petition Date. Despite this

omission, the Trustee learned of these transfers and filed an adversary proceeding to recover the

properties as fraudulent transfers.

With the Petition, the Debtor filed an application to proceed in forma pauperis, declaring

that she had no cash or money in her accounts, which the Court granted. The Court later learned

from the Trustee that the Debtor had at least $7,000 as of the Petition Date.

Since the beginning of this case, the Debtor has made numerous arguments that use

legalistic language and terms but do not accurately represent current law. The Debtor has been a

member of the Xi Amaru Tribal Government (also known as ARNA) (the “Tribe”) since,

according to the Debtor, “maybe 2022.” The Debtor was associated with the Tribe at the time she

transferred the Properties.3 On January 8, 2025, at a meeting of creditors, the Debtor asserted that,

following the transfer of the Properties, they belonged to the Tribe.4

At a hearing held on May 27, 2025 (the “May Hearing”), the Debtor testified to having

begun courses with the Tribe prior to the Petition Date (the “Courses”), one of which was on

3 See Ex Parte Motion for Production of Documents Only from Aboriginal Republic Of North America,

Xi-Amaru Tribal Government, Aboriginal University, And Amaru Xi-Ali D/B/A Xi Amaru Tribal

Enterprises Pursuant to Bankruptcy Rule 2004 ¶ 7 [Do. No. 148] (the “Second Ex Parte Motion”).

4 See Ex Parte Motion for Production of Documents Only from Certain Banks, Credit Unions, And

Financial Technology Companies Pursuant to Bankruptcy Rule 2004 [Do. No. 144].

‘jurisprudence’. The Bankruptcy Administrator, through independent research, learned that the

‘School of Law’ associated with the Tribe offers courses focusing on topics that include “Tribal

Business Registration,” “Business & Personal Credit,” “Law Consultation,” “Lawsuit Drafting,”

“Business Credit and Personal Credit Services,” “Patent Trademark Copyright Training,” and

“Land Trust Services,” and that homework for a course tested participants on their knowledge of

bankruptcy and insolvency, such as the difference between Chapter 11 and Chapter 13.5 The

Bankruptcy Administrator cross-examined the Debtor on the Courses at the May hearing, but the

Debtor could not recall answers to most of the questions related to the Courses or the Tribe, such

as exact costs of the Courses, their precise completion dates, or how she paid.6 Based upon (1) the

5 Second Ex Parte Motion ¶ 12.

6 At the May Hearing, the Debtor could also not recall exact details regarding (1) the monthly mortgage

payment for at least one of the Properties, (2) the tenants’ names, the name of the company her property

manager works for, (3) how long her property manager has managed the property or when she first met

her, (4) the bank holding accounts associated with the Debtor’s LLC or the Properties, (5) whether she

has ever visited a physical branch, (6) when she opened that account, (7) its current balance, (8) whether

any deposits other than rent had been made post-petition, (9) whether the May rent on the Properties had

been paid, (10) who receives statements for that account, (11) the amount of cash she received in a 2021

refinance of one of the properties or the precise date of that refinance, (12) who prepared her 2023 tax

return, (13) when she purchased a vehicle she owned or whether that purchase pre- or post-dated her

becoming active in the Tribe, (14) being asked at the creditors meeting about transferring property to the

Tribe, (15) all repairs made at a property in the last year beyond a washer and dryer, or (16) whether there

were any other Tribal holdings or assets under her control beyond the real properties and account

discussed.

This would begin a trend of the Debtor being unable to recall important details the Trustee or

Bankruptcy Administrator sought to move the Debtor’s case along. At the First July Hearing, the Debtor

could not recall (1) when a bank account closed or the reason for its closure, (2) the last time she

deposited into a different emergency fund account, (3) if she had listed any closed bank accounts on her

bankruptcy papers, (4) any details about a transfer on her bank statement, (5) the ownership or details of

multiple other bank accounts, or (6) whether she still had access to two bank accounts—all despite having

accessed some of her bank statements online for the very accounts queried about. At the Second July

Hearing, the Debtor could not recall (1) details regarding a Zelle transfer to an undisclosed account, (2)

details regarding Coinbase account activity, (3) whether she had provided statements for another account

starting from June, or (4) whether she had provided or even remembered any related documents for

another transfer, among others. At the September hearing, the Debtor could not recall (1) the exact dates

or periods when certain accounts were used or closed or whether they were closed this year or last year,

(2) any details related to other accounts for the period between February 2023 and May 2023 or for 2025,

(3) whether she had previously disclosed certain accounts, including a savings account, (4) the exact

nature or timeframe of her use of another account related to transfers, (5) the details for a transfer on

lack of answers from the Debtor and the need of complete facts and (2) a concern that the

unauthorized practice of law had or occurred was occurring, the Trustee and the Bankruptcy

Administrator sought from the Debtor documents related to the Courses (the “Discovery

Request”). At this hearing, the Debtor also revealed accounts which she had failed to disclose in

her Petition which the Court ordered the Debtor to produce.

III. June Hearings and the Reference

At a hearing held on June 23, 2025 (the “June Hearing”), the Debtor acknowledged that

she had not produced any of the documents since the May Hearing. As well, the Debtor initially

stated that she did not recall sending multiple emails to the Trustee in the following week, which

the Trustee then read into the record at the June Hearing. The Debtor subsequently acknowledged

that she had emailed and informed the Trustee that she would produce documentation at some

point. The Debtor also requested that a mediator be appointed and that a settlement amount be

provided to allow the Debtor to pay off all creditors in a lump sum. The Trustee and the Bankruptcy

Administrator informed the Debtor that that was not possible because they could not be fully aware

of who may be a rightful creditor until they received the bank records and other pertinent

information that the Debtor had failed to produce. Following the June Hearing, the Court entered

the Order from Omnibus Hearing on June 23, 2025 [Do. No. 111] (the “Omnibus Order”), which

formally ordered the Debtor to provide documents related to various bank accounts the Debtor had

not disclosed as well as documents related to the Courses.

On June 27, 2025, the Debtor filed in the District Court to have the reference of this case

to this Court withdrawn.7 In that filing, the Debtor alleged various facts such as receiving

February 14th, 2024 (6) the details regarding possibly lost documents from another account, or (7) the

details regarding a co-op system for another account, among others.

7 Notice of Motion to Withdraw a Reference of Bankruptcy Petition [Do. No. 121].

voicemails from the Trustee that did not occur. As well, many paragraphs utilized masculine

pronouns interspersed with feminine pronouns (which the Debtor uses in general), suggesting that

the pleading had been duplicated from one with a male-identifying individual. At the Second July

Hearing, when the Bankruptcy Administrator inquired about the voicemails, the Debtor stated she

“did not remember writing this.”

IV. July Hearings and the Debtor’s Original Motion

Prior to a hearing held on July 7, 2025 (the “First July Hearing”) and to provide an update

regarding the production of documents, the Trustee and the Bankruptcy Administrator filed their

First Status Report [Do. No. 125], which asserted that the Debtor had failed to provide any of the

requested documents to the Bankruptcy Administrator and failed to provide many of the requested

documents to the Trustee. The Trustee and the Bankruptcy Administrator also recommended that

the Court find the Debtor in contempt and fine her $100 a day until she complied with the Omnibus

Order. Following the First July Hearing, the Court entered the Order Finding Debtor in Civil

Contempt [Do. No. 132] (the “Contempt Order”) and found the Debtor in civil contempt. However,

the Court gave the Debtor one more chance to fully comply with the Omnibus Order before

imposing sanctions and ordered that a hearing occur on July 21, 2025 (the “Second July Hearing”),

to assess compliance with the Contempt Order.

Immediately following the First July Hearing but before the Contempt Order was entered

on July 14, 2025, the Debtor filed this Motion. The Original Motion made multiple statements of

fact that were irrefutably false. See Original Motion ¶ 4 (declaring that the information sought by

the Discovery Request “was revealed or used by the Trustee” and that “[b]y divulging estate

information she had no authority to release, the Trustee breached her duty to safeguard estate assets

and respect applicable privacy and property rights,” and that the Bankruptcy Administrator “was

aware of, or failing [sic] to prevent, this disclosure”). Upon receiving a letter from the Bankruptcy

Administrator regarding this falsity, the Debtor filed her amended motion and removed such

statements.

At the Second July Hearing, the Debtor asserted that she had complied with certain portions

of the Court Orders. When asked by the Court to provide any argument regarding the mitigation

of sanctions, the Debtor acknowledged “mistakes” but stated that she could not provide the

Courses’ documents as doing so would violate federal law. When asked what law she would

violate, the Debtor cited 11 U.S.C. § 541, 15 U.S.C. § 114, 17 U.S.C. §§ 504 and 505, 18 U.S.C.

§ 241, and the Indian Arts and Crafts Act. There is no section 114 in Title 15 of the United States

Code, and the other cited statutes are inapplicable. Following the Second July Hearing, the Court

imposed the recommended daily sanctions.

V. September Hearing

Between the Second July Hearing and the next hearing, the Debtor partially complied with

the Contempt Order as pertaining to certain, but not all, accounts, but did not comply with the

Discovery Request. At a hearing on September 8, 2025 (the “September Hearing”), the existence

of further accounts was revealed, placing the total number in the dozens. At the same hearing, the

Debtor explicitly refused to produce documentation related to the Courses. The Debtor also refused

to answer the Court’s questions about the Courses and who may be threatening her with legal

action, which she asserted is why she cannot turn over the Courses’ documentation in compliance

with the Court Orders. Given the Debtor’s refusal to comply with the prior order, following the

September Hearing, the Court raised the Debtor’s daily contempt fines to $150.

Further, the parties presented their arguments as to the Motion. When the Debtor was asked

about the false statements made in her Original Motion, the Debtor stated she “made an error when

[she] was on typing” and “misspoke.”8 At the hearing, the Court also became aware of the fact that

in 2023, the Debtor was sanctioned in state court and ordered to pay $8,000 pursuant to Rule 11

for filing a “verified pleading which contained facts and statements of law that were insufficient

to satisfy the grievances [ ] alleged” and “were not credible,”9 which she did not appeal.

DISCUSSION

I. Legal Background

A. Legal Standard for Recusal

“The court [ ] may remove a trustee [ ] for cause.” 11 U.S.C. § 324(a). Removal of a trustee

is “as serious an action as a bankruptcy judge could possibly decide” that should “not [be]

undertaken lightly,” In re Walker, 2004 Bankr. LEXIS 2187, 2004 WL 3152787 (Bankr. S.D. Fla.

Dec. 1, 2004), aff'd, Walden v. Walker, 515 F.3d 1204 (11th Cir. 2008), partly since “if a trustee

is removed, he or she is also removed from all other bankruptcy cases in which he or she is involved

unless the court rules otherwise.” In re Tres-Ark, Inc., 483 B.R. 460, 467 (Bankr. W.D. Tex. 2012)

(citing 11 U.S.C. § 324(b)).

For recusal, “[t]he standard of review is clear and convincing evidence.” In re JMW Auto

Sales, 494 B.R. 877, 890 (Bankr. S.D. Tex. 2013). “The ‘party seeking removal’ bears the burden

of proof and meets this burden by providing evidence of ‘specific facts’ warranting removal.” Dye

v. Brown (In the Matter of AFI Holding, Inc.), 530 F.3d 832, 845 (9th Cir. 2008) (quoting 3 Collier

on Bankruptcy ¶ 324.02, at 324-3 (Alan N. Resnick & Henry J. Sommer eds., 15th ed. rev. 2006)).

“As the movant, the Debtor bears the burden of establishing cause by setting forth specific facts

which support the removal of the Trustee. A conclusory contention unsupported by specific facts

8 Court Recordings of September 8, 2025 Hearing [Do. No.s 214-217] (the “September Hearing

Recordings”) (The Debtor’s statements at 44-17-44:20 and 44:45-44:50).

9 Exhibit List for September 8, 2025, Hearing, Bankruptcy Administrator Ex. 3, State Court Order re:

Def/Father’s Motion for Rule 11 Sanctions [Do. No 218].

does not constitute sufficient grounds for the removal of a trustee.” In re Alexander, 289 B.R. 711,

714 (B.A.P. 8th Cir. 1999). “[H]orrible imaginings alone cannot be allowed to carry the day.” In

re Martin, 817 F.2d 175, 181–83 (1st Cir. 1987).

The Bankruptcy Code does not define ‘cause’. However, courts have held that “cause may

include trustee incompetence, violation of the trustee’s fiduciary duties, misconduct or failure to

perform the trustee’s duties, or lack of disinterestedness or holding an interest adverse to the

estate.” Schoenmann v. United States Tr. (In re Li’s Cap. LLC), 2025 Bankr. LEXIS 902 *10-*11

(citing Dye v. Brown (In re AFI Holding, Inc.), 530 F.3d 832, 845 (9th Cir. 2008)). “[C]ause to

remove a trustee cannot be found in actions that fall within the proper scope of the trustee's

discretion.” In re Consol. Indus. Corp., 330 B.R. 712, 715 (Bankr. N.D. Ind. 2005). “Cause to

remove a trustee must be something of a substantial nature directly affecting the rights and interests

of the public. . . . Moreover, when making a removal decision, a court must consider the best

interest of the estate, not merely that of a single complaining movant.” United Tax Grp., LLC, 622

B.R. at 157 (citing In re Baker, 38 B.R. 705, 707 (D. Md. 1983)).

Lastly, a debtor “may not necessarily have standing” to have a trustee removed. In re

Bashour, 124 B.R. 52, 54 (Bankr. N.D. Ohio 1991). “Generally, removals are sought by creditors

who do not believe that the trustee is qualified or acting to protect creditors’ interests.” Id. (citing

In re El San Juan Hotel Corporation, 841 F.2d 6, 8-9 (1st Cir. 1988); In re Persky, 893 F.2d 15,

17-18 (2d Cir. 1989)).

B. Legal Duties for the Trustee and Bankruptcy Administrator

The Bankruptcy Code imposes a litany of obligations on a trustee. These include the duty

to “collect and reduce to money the property of the estate [ ] and close such estate as expeditiously

as is compatible with the best interests of parties in interest,” “be accountable for all property

received,” “ensure that the debtor shall perform his intention as specified in [§ 521(a)(2)(B)],”

“investigate the financial affairs of the debtor,” “examine proofs of claims and object to the

allowance of any claim that is improper,” “if advisable, oppose the discharge of the debtor,”

“furnish such information concerning the estate and the estate’s administration as is requested by

a party in interest,” “make a final report and file a final account of the administration of the estate.”

11 U.S.C. § 704(a)(1)-(9). Although there are limited situations where a trustee owes a debtor a

duty,10 generally, “[a] trustee’s fiduciary duties are owed to the estate and creditors, not the debtor

personally.” In re Livore, supra, 2010 Bankr. LEXIS 1653 *16-17 (citations omitted); see also In

re Perez, 30 F.3d 1209, 1214 (9th Cir. 1994) (“Counsel for the estate must keep firmly in mind

that his client is the estate and not the debtor individually.”); cf. Commodity Futures Trading

Comm’n v. Weintraub, 471 U.S. 343, 355 (1985) (“One of the painful facts of bankruptcy is that

the interests of shareholders become subordinated to the interests of creditors.”).

Although the Bankruptcy Administrator’s duties are not delineated within the Bankruptcy

Code as such, they are generally coterminous with those imposed on its equivalent outside of North

Carolina and Alabama, the U.S. Trustee.11 Thus, they are obliged to “supervise the administration

10 Wisdom v. Gugino, 649 Fed. App'x 583, 584 (9th Cir. 2016) (citing U.S. Dep't of Justice, Executive

Office for the United States Trustees, Handbook for Chapter 7 Trustees 4-2 (2012)) (“When a debtor

retains an interest in estate assets—either by properly claiming exemptions or because surplus property

will remain in the estate after all creditors have been compensated—the trustee owes a fiduciary duty to

the debtor as well.”).

11 See CTA11 Add. IX (the Eleventh Circuit’s Statement that Alabamian bankruptcy administrators’

“duties are essentially the same as those of the U.S. trustees in the Department of Justice”); U.S. Gen.

Accounting Off., Bankruptcy Administration: Justification Lacking for Continuing Two Parallel

Programs: Report to the Chairman, Permanent Subcomm. on Investigations, Comm. on Governmental

Affairs, U.S. Senate, App. III, tbl. III.1-2, at 35-36 (Sept. 1992) (outlining how bankruptcy administrators

do virtually all the activities of US Trustees, including, in Chapter 7 cases, “[r]eview[ing] petitions for

abuse, trustee operations, case status reports, fee applications, closing reports, trustee bonding” and

“[r]eceiv[ing] bank statements/reports,” in Chapter 11 cases, “[r]equir[ing] monthly financial reports, visit

debtor premises, encourage creditor committees, review disclosure statements,” in Chapter 13 cases,

“[r]equir[ing] annual budget, annual report, trustee bonding, independent CPA audit,” and, in all,

of cases. . . by reviewing. . . applications filed for compensation and reimbursement under [§ 330],

filing with the court comments with respect to such application and, if. . . appropriate, objections

to such application,” 28 U.S.C. § 586, as well as to “review all materials filed by the debtor and. . .

file with the court a statement as to whether the debtor’s case would be presumed to be an abuse

under [§ 707(b)].” 11 U.S.C. § 704(b)(1)(A). Bankruptcy Administrators also serve a more

generalist role focused on the public’s stake in the proper administration of the bankruptcy system.

See, e.g., E1 Collier on Bankruptcy B (16th 2025) (“The bankruptcy administrators were given

standing to raise, appear, and be heard on any issues under the Bankruptcy Code, and were allowed

to present to the court, on the record and with notice to the parties, any views or recommendations

regarding matters within the scope of their duties. Furthermore, the bankruptcy administrators

were empowered to initiate a review and investigation of any allegations of fraud and misconduct,

and to make appropriate referrals thereof.”); see also Lynch v. Jackson, No. 16-1358 at 120 n. 1

(4th Cir. 2017) (“The [bankruptcy administrator] acts to prevent fraud and abuse in bankruptcy

proceedings.”); and H.R. REP. 95-595, 88, 1978 U.S.C.C.A.N. 5963, 6049-50 (“[Bankruptcy

administrators] will serve as bankruptcy watch-dogs to prevent fraud, dishonesty, and

overreaching in the bankruptcy arena,” given “there is a public interest in the proper administration

of bankruptcy cases” since “[b]ankruptcy is an area where there exists a significant potential for

fraud, for self-dealing, and for diversion of funds.”).

“computerized case tracking system, download data from clerk’s office, require interest-bearing

accounts.”).

II. Analysis

A. The Debtor’s Allegations of Misconduct

The Debtor’s most prominent allegation is that the Discovery Request constitutes

misconduct because it is illegal12 or extralegal.13 At bottom, the Discovery Request does not and

cannot constitute either. First and as the Court has continuously explained to the Debtor over the

last four months, there is nothing illegal about it. That the Discovery Request is not copyright

infringement is true, not only actually, but also constitutively so. See, e.g., Bond v. Blum, 317 F.3d

385, 397 (4th Cir. 2003) (holding that disclosure of copyrighted materials in litigation is Fair Use

and non-infringing since the purpose is adjudication, not commercial exploitation); see Courtroom

Recording on Sep. 8, 2025 at 1:39:07 PM [Dkt. No. 216] (statement of the Court at 5:44–6:05)

(“[C]opyright law itself contemplates compelled production and evidentiary use; it is not a

privilege that defeats discovery. Otherwise, copyright would be unenforceable. How else could

courts come to any decisions on the matter? The same protections that Debtor claims her

noncompliance upholds would not exist if litigants adopted her view.”). Relatedly, the Debtor

alleges various violations of Rule 2004’s principle against fishing expeditions based on the

Discovery Request. However, a challenge to a Rule 2004 motion is not appropriate grounds for a

recusal motion. Rather, a party must object to the Rule 2004 motion specifically. No such objection

was filed in this case.

Second, it clearly is not extralegal. The Discovery Request is not only generally authorized

as a standard litigation tool available to all parties, including the Debtor, but it has also been

specifically authorized in this case by the Court, not only initially when it was first made, but also

currently under the Contempt Order. The Debtor’s continued assertion otherwise contravenes the

12 See, e.g., The Motion ¶¶ 5, 7, 33-34, 37, 41-44, 47, 49, 50.

13 See, e.g., The Motion ¶¶ 4, 7, 9, 34-35, 45, 47, 50-51.

Court’s rulings and the Contempt Order. Thirdly and most importantly, far from being illegal or

extralegal, the Discovery Request is statutorily required of the Trustee and Bankruptcy

Administrator, as the Court will discuss next.

B. The Debtor’s Allegations of Partiality, Conflicts of Interest, and General Bias

The Debtor also alleges that the actions of the Trustee and the Bankruptcy Administrator

display that they have interests contrary to their duties either because they are adverse to the Debtor

internally in this case or because they are motivated by improper external sources.14 For example,

the Debtor alleged at the September Hearing that both the Trustee and the Bankruptcy

Administrator were motivated by “money and prestige”15 and that their actions were “not for the

benefit of the creditors” since she was “trying to go ahead and pay my creditors,” which the

Discovery Request precluded.16 The Debtor also discloses that she has filed a complaint against

the Trustee with the North Carolina Bar (the “Bar Complaint”), which creates a conflict between

her and the Trustee.17

Setting aside the Bar Complaint for the moment, any adverseness between the Trustee and

the Bankruptcy Administrator and the Debtor here is not improper; it is legally imposed. The

Trustee’s and the Bankruptcy Administrator’s statutory duties require them to oppose the Debtor

when doing so serves the best interests of the estate, creditors, or the integrity of the bankruptcy

system. The Debtor’s interests do not supersede those of other interested parties. Neither the

Trustee nor the Bankruptcy Administrator is the Debtor’s counsel; their role can, and often must,

14 See, e.g., The Motion ¶¶ 33, 35, 37, 39, 44-46.

15 Court Hearing Recording September 8, 2025 (Debtor’s statement at 11:46-11:56).

16 Court Hearing Recording September 8, 2025 (Debtor’s statement at 4:28-5:52).

17 See The Motion, ¶ 69.

be opposing within an adversarial framework.18 Thus, as to Debtor’s assertion that there is “no

explanation” for the Discovery Request besides “prestige,” Trustee and the Bankruptcy

Administrator do not obtain ‘prestige’ but merely maintain employment by fulfilling their statutory

duties.

As to the Debtor’s statement that the Trustee’s and the Bankruptcy Administrator’s actions

preclude her “pay[ing] her creditors,” that argument is a red herring. The record reflects that the

Trustee and the Bankruptcy Administrator have consistently acted to protect creditor recoveries

by opposing certain Debtor motions due to inadequate notice or to preserve collateral necessary to

fund those recoveries. And even if the Discovery Request does not directly increase distributions,

it advances the orderly administration of the bankruptcy system, which the Trustee and the

Bankruptcy Administrator are duty-bound to promote and which ultimately benefits all parties,

including the Debtor.

1. The Debtor’s State Bar Complaint

Regarding the Bar Complaint, the Debtor is right that, at least factually, it does place her

in formal opposition to the Trustee. However, first, to reiterate, it is unclear whether conflicts

between a trustee and only the debtor, not the estate, can form a basis for recusal. Second, and

more importantly, the Bar Complaint is itself unlawful as against a trustee in the current procedural

posture.

Our Court considered this issue squarely in In re Seertech Corporation. Case No. 06-31156

[Do. No. 90] (W.D.N.C. Bankr. September 12, 2007). There, a party similarly filed a state bar

complaint against the trustee. As this Court explained there, such action violated the “automatic

18 Debtor’s assertion otherwise is all the more illogical given that the Debtor, as a landlord, is herself a

potential creditor who, if ever needing to recover from a debtor-tenant, would be dependent on a trustee

acting for her interests to receive fair treatment in bankruptcy, even if adverse to that debtor.

stay. . . . [W]hich bars outside efforts to control either the estate or its property,” as well as “the

Barton Doctrine, [whereby] a bankruptcy trustee may not be sued in another tribunal without leave

of the appointing court.” Seertech at 15-16 (first citing 11 U.S.C. § 362(a) then citing Gordon v.

Nick, 162 F.3d 1155 (4th Cir. Sept. 2, 1998), Schafler v. Field, 2001 WL 34553964 (D. Md. Aug.

15, 2001), and In re Byrd, 2007 WL 1485441 (Bankr. D. Md. May 18, 2007) (all citing Barton v.

Barbour, 104 U.S. 126, 26 L. Ed. 672 (1881))). The Bar Complaint here is no different.

Similarly, even if a conflict between a trustee and exclusively the debtor could constitute

conflict warranting recusal, the Court of course could not find the Bar Complaint to validly do so

since it would be to reward explicit contravention of law that is itself designed to help litigants

such as the Debtor. Grounds for removal cannot rest on a conflict the Debtor herself created.

C. The Debtor’s Allegations of Specific Bias

The Debtor alleges that the Trustee and the Bankruptcy Administrator have displayed

specific bias against the Tribe and herself in regard to their tribal sovereignty. She alleges this is

displayed by three facts: (1) the Bankruptcy Administrator’s statement that “[a]ll of [the Debtor's]

pleadings [being] filed, ‘all rights reserved’ [below the signature], [is] another thing that's highly

unusual” about the Debtor’s case; (2) the Bankruptcy Administrator’s statement that she could

“file a motion pursuant to Rule 2004 to subpoena the materials that” the Discovery Request seeks,

and that she had “some ideas from researching online who we should target;” and (3) the Trustee’s

and the Bankruptcy Administrator’s utilization of sovereign citizen movement cases in explaining

to the Court why the Debtor’s tribal sovereignty was not afforded the protections she claimed.

1. The Debtor’s Allegations of Specific Bias Based on Specific Comments

Made by the Bankruptcy Administrator

As to the first fact, the Bankruptcy Administrator’s use of “unusual” is descriptive, not

evaluative. “Unusual” means “noticeably different from what is generally found or experienced,”

Unusual, Merriam-Webster Online Thesaurus, https://www.merriam-

webster.com/thesaurus/unusual, and it can mark objective rarity or scarcity without implying

abnormality or criticism. Here, the Bankruptcy Administrator’s observation did just that. It is an

objective fact that, because court filings are public records and not copyrighted, a litigant stamping

every pleading “all rights reserved” is uncommon. Moreover, as discussed above, there are

multiple aspects of this case that are atypical for Chapter 7, and for bankruptcy practice generally.

And, indeed, “[t]ruth is an absolute defense to” such claims. Seertech at 18. The Bankruptcy

Administrator’s phrasing was matter-of-fact and about reality; it did not display any subjective

view of the Debtor.

As to the second fact, “target” has two definitions: “to make a target of” or “to direct or

aim.” Target, Collins English Dictionary (HarperCollins Publ’rs, online ed.),

https://www.collinsdictionary.com/us/dictionary/english/target. Only the former carries a

negative, hostile connotation; the latter is neutral and describes, in this context, focusing an inquiry

or directing lawful process. Here, as evinced by the fact that the context was regarding where to

send mail, the Bankruptcy Administrator clearly used “target” in that neutral sense, identifying the

proper recipients for the Discovery Request, rather than suggesting animus toward the Debtor or

the Tribe.

2. The Debtor’s Allegations of Specific Bias Based on Analogies Between

Tribal Sovereignty and the Sovereign Citizen Movement

As to the third fact, the Court does not believe that the Trustee’s and the Bankruptcy

Administrator’s analogies in any way served to transpose any negative connotations of the

sovereign citizen movement onto tribal sovereignty as the Debtor alleges. That is not how

analogies work in case law analysis. Analogies are, definitionally, not identity statements. Cf., e.g.,

Ohio Oil Co. v. Indiana, 177 U.S. 190, 209 (1900) (“But whilst there is an analogy between

animals ferae naturae and the moving deposits of oil and natural gas, there is not identity between

them.”). Analogies do not equate, they illustrate; they are a bridge, not a mirror.

The Trustee and the Bankruptcy Administrator were not contending that the Debtor is a

sovereign citizen. Rather, they offered examples to assist the Court in evaluating a narrow,

dispositive point of law: claims of extranational sovereignty cannot defeat the application of

generally applicable laws unless the sovereignty asserted is one that U.S. law recognizes. The

Trustee’s and the Bankruptcy Administrator’s analogies between the sovereign citizen movement

and tribal sovereignty rested solely on that limited similarity: each asserts a form of sovereignty

said to lie outside ordinary civil authority. From that shared premise, the Trustee and the

Bankruptcy Administrator drew the limited inference that such claims are legally ineffective

absent recognition by the United States and federal law.

Everyone in this case, including the Court, understands there is a mountain of difference

between tribal sovereignty and the sovereign citizen movement. Tribal sovereignty is a long-

standing doctrine grounded in the unique, pre-constitutional status of Indian tribes and the federal

government’s trust relationship; the sovereign citizen movement is a fringe, alegal posture. But all

those differences do not alter the discrete proposition for which the analogy was offered: where a

litigant invokes an extranational sovereign authority to avoid generally applicable law, federal

recognition is the gating requirement. Here, the Debtor’s assertion of tribal sovereignty rests on a

Tribe that is not recognized; accordingly, whatever its other characteristics, it does not carry the

legal consequences of recognized tribal sovereignty, such as immunity or jurisdictional

displacement.

Two things can be vastly different and yet share a single relevant feature; an analogy that

isolates and uses that feature does not import the rest. That is what happened here. The Trustee

and the Bankruptcy Administrator did not equate tribal sovereignty with the sovereign citizen

movement; they borrowed only the narrow point that unrecognized claims of sovereignty, whether

styled as “tribal” or otherwise, cannot bar the operation of ordinary law. It is standard fare in legal

reasoning to employ analogies across disparate doctrines to test a rule’s predicates and

consequences. The Trustee’s and the Bankruptcy Administrator’s use of analogy stayed well

within that tradition by illuminating the recognition prerequisite without denigrating tribal

sovereignty or collapsing it into the sovereign citizen movement.

In sum, the Court and the parties have been explicit that they respect the Debtor’s asserted

cultural identity and the importance of tribal self-determination where the law recognizes it. That

respect does not alter the legal conclusion here: because the Debtor’s claimed sovereignty depends

on a Tribe that is not recognized, it does not supply a defense to the laws at issue. The Court

therefore rejects any suggestion that the Trustee’s and the Bankruptcy Administrator’s analogies

were pejorative; they were properly confined to the recognition question and were credited only

for that limited purpose.

**********

Simply, all the Debtor’s accusations alleging cause for recusal are actions that are legally

required of the Trustee or the Bankruptcy Administrator. This cannot validly form the basis for

recusal.

CONCLUSION

The Court hopes that the above analysis clearly elucidates why the allegations against the

Trustee and the Bankruptcy Administrator do not suffice for recusal grounds since there is no

cause. Furthermore, though, the Court, conscious of its own duty of neutrality, but also aware that

the Debtor has forced its hand to weigh in on the performance of the Trustee and the Bankruptcy

Administrator, feels it necessary to state the following: the Trustee’s and the Bankruptcy

Administrator’s conduct in this case has been faultless. Despite the complexity of this case, the

Trustee and the Bankruptcy Administrator have continually performed their statutory duties such

as locating the litany of originally undisclosed bank accounts to which the Debtor transferred

money. They have waded through the thousands of pages of documents the Debtor has provided

to pinpoint information important to the case. They have both dedicated the time necessary to this

case, sometimes on the weekend, despite having a multitude of other cases. They have also

conducted themselves in court, despite any understandable frustration the Debtor had engendered,

with grace. Contrarily, the Debtor’s conduct in this case has been unsatisfactory pursuant to her

duties under the Bankruptcy Code and general legal provisions, not to mention the Contempt

Orders from this Court.

WHEREFORE IT IS ORDERED that Debtor’s Motion for recusal is DENIED.

SO ORDERED.

This Order has been signed United States Bankruptcy Court

electronically. The Judge’s

signature and Court’s seal

appear at the top of the Order.