Editing Openai/68543586-b3fc-8004-86a9-b3760b4894b0 (section)

==== Under Rule 2004, you can seek to examine: ====

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You may also request:
* Email list ownership docs
* Contracts with members
* Sales records
* Communications about unpaid commissions

==== <syntaxhighlight lang="markdown">'''UNITED STATES BANKRUPTCY COURT''' ====
'''SOUTHERN DISTRICT OF TEXAS – HOUSTON DIVISION'''

'''In re:''' DE Marketing LLC  
'''Case No.:''' 25-33305  
'''Chapter 7'''

'''MOTION FOR RULE 2004 EXAMINATION'''

Comes now [Your Name], a creditor in the above-captioned case, and respectfully requests that the Court enter an order authorizing a Rule 2004 examination of the Debtor, its principals, and affiliated entities for the purpose of investigating possible undisclosed assets, fraudulent transfers, and continued operation under successor entities including “Clickerr,” “MyInboxPro,” and “Push Platform.”

'''Background:'''
* Movant represents a group of over 3,000 independent contractors owed more than $2 million in unpaid commissions.
* Debtor issued 1099s for funds never paid.
* Debtor claimed to own a 31-million subscriber email list, now being used by a related company while claiming no assets in bankruptcy.
* Website and member data have been removed without notice.
* Movant has reason to believe assets have been improperly transferred or concealed.

'''Relief Requested:'''
Movant respectfully requests that the Court authorize examination under Rule 2004 and allow for the production of documents and deposition of:
# [Name of DE Marketing owner/operator]
# DE Marketing LLC
# [Any known new LLC or person operating Clickerr/MyInboxPro]

Dated: [Your Date]

Respectfully submitted,  
[Your Name]  
[Your contact info – mailing address/email]  
Appearing pro se as a creditor

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