Case 19-10573-KG Doc 31 Filed 05/06/19 Page 1 of 14

IN THE UNITED STATES BANKRUPTCY COURT

FOR THE DISTRICT OF DELAWARE
_____________________________________
:
In re: : Chapter 7
:
CommuniClique, Inc., : Case No. 19-10573 (KG)
:
Alleged Debtor. :
: Re: Dkt. No. 20
____________________________________ :

RESPONSE TO COURT’S SUA SPONTE MOTION TO TRANSFER CASES

Keith Hladek, Philip Lowit, Paitaridis Children Family Trust, Robert M. Pons, Erik

Sachwitz, Andrew Schwartzberg and Jaime Schwartzberg, Adam Stern and Stonehaven Capital

(collectively, the “Petitioning Creditors”), by and through undersigned counsel, file this response

(the “Response”) to the Court’s sua sponte motion to transfer (the “Motion to Transfer”) the

involuntary bankruptcy cases filed against (i) CommuniClique, Inc. (the “Company” or

“CommuniClique”), a Delaware corporation, alleged debtor in case number 19-10573 (the

“CommuniClique Action”) pending in the Bankruptcy Court for the District of Delaware (the

“Bankruptcy Court”), and (b) Andrew Brent Powers (“Mr. Powers”, together with

CommuniClique, the “Alleged Debtors”), founder and Chief Executive Officer of

CommuniClique, and alleged debtor in case number 19-10574 (the “Powers Action”, together with

the CommuniClique Action, the “Actions”) pending in the Bankruptcy Court. In support of the

Response, the Petitioning Creditors state as follows:

PRELIMINARY STATEMENT1

The Petitioning Creditors understand the Court’s concern about whether Delaware is the

proper venue for the Actions to proceed. Mr. Powers is a California resident and his company,

1 Capitalized terms not defined in the Preliminary Statement have the meanings ascribed to them in this Response.

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CommuniClique, is apparently doing business in California. But these are unusual cases. Upon a

closer examination, the only parties that truly benefit from a transfer to California are the Alleged

Debtors, who would benefit from being closer in proximity to the forum, and, ancillary, from

further delay of these proceedings – an obvious goal of the Alleged Debtors. The Court must ask

itself what is fair under the circumstances. As discussed infra, on balance, the most convenient

forum is in fact Delaware, the chosen state of incorporation for the Company, not California, and,

under the circumstances, fairness requires that the Court give very little deference to what is

convenient for the Alleged Debtors. Accordingly, the Petitioning Creditors request that the Court

keep the cases in Delaware, the Petitioning Creditors’ chosen forum.

BACKGROUND

A. The Virginia Securities Action

1. On March 16, 2018, the State Corporation Commission of the Commonwealth of

Virginia (the “Commission”) issued a Rule to Show Cause (the “Rule”) against CommuniClique

and Mr. Powers based upon allegations made by the Commission’s Division of Securities and

Retail Franchising (the “Division”) that the Alleged Debtors violated the Virginia Securities Act

(the “Act”) by making material misrepresentations to investors, thereby commencing the case

styled Commonwealth of Virginia v. CommuniClique, Inc. and Andrew Brent Powers, Case No.

SEC-2017-00051 (the “VA Securities Action”).

2. Mr. Powers and CommuniClique were represented by counsel in the Virginia

Securities Action. Counsel ultimately withdrew prior to the evidentiary hearing. According to

Mr. Powers, he and CommuniClique “chose not to contest the action.” See Blog Post titled “I

Screwed Up,” authored by A. Powers (available at https://www.andypowers.com/i-screwed-up/).

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3. A hearing on the Rule was held in the VA Securities Action on June 12, 2018 (the

“Hearing”).

4. Following the Hearing, on July 13, 2018, A. Ann Berkebile (the “Hearing

Examiner”), a hearing examiner with the Commission, issued her report (the “Report”), pursuant

to which she determined that the Alleged Debtors violated the Act by making material

misrepresentations to investors. A true and correct copy of the Report is attached hereto as Exhibit

A. The Hearing Examiner recommended, among other things, that the Alleged Debtors make

restitution to investors, including the Petitioning Creditors, in the aggregate amount of $9,890.2932

and that the Alleged Debtors be permanently enjoined from offering or selling securities in

Virginia. Ex. A, Report at pp. 5-6.

5. On August 30, 2018, the Commission entered a Judgment Order (the “Judgment

Order”) against the Alleged Debtors for violations of the Act, adopting the Hearing Examiner’s

findings and recommendations in the Report. A true and correct copy of the Judgment Order is

attached hereto as Exhibit B. See Ex. B, Judgment Order at pp. 3-4.

B. The Alleged Debtors’ California Move

6. Prior to August 2018, Mr. Powers was a long-time resident of the Commonwealth

of Virginia. It was there that he started his company, CommuniClique, and perpetrated a decade-

long fraud that resulted in entry of the Judgment Order.

7. The Hearing Examiner issued her report in July 2018. In August 2018, with the

writing on the wall, the Alleged Debtors all but emptied the CommuniClique bank accounts,

transferring funds to Mr. Powers and other associates. A true and correct summary compilation

2 The Commission ordered both CommuniClique and Mr. Powers to pay $9,890,293 in restitution to defrauded
Investors. The portion of the total restitution ordered by the Commission that relates to the Petitioning Creditors is
$2,876,281.40.

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of bank statements reflecting such transfers is attached hereto as Exhibit C. Alleged Debtors then

packed up and moved to California, where they have remained since.

C. The Assets

8. Petitioning Creditors do not yet know precisely what assets the Alleged Debtors

have and where those assets are located. Petitioning Creditors believe that CommuniClique’s

primary assets are likely cash and investments. Petitioning Creditors are not aware of any real

property (improved or otherwise) or any other tangible assets owned by the Company and situated

in California (or anywhere else).

9. Petitioning Creditors believe that Mr. Powers’ primary assets are likely cash and

investments. Petitioning Creditors do not believe that Mr. Powers’ owns real property (improved

or otherwise) in California; Mr. Powers is known to have been renting in California since he moved

there in August of 2018. See Ex. I, Rocker Compl.

D. The Employees

10. Petitioning Creditors are not aware of any current employees of CommuniClique.

11. Petitioning Creditors are aware of the following former employees of the Company

(and, as noted, Mr. Powers):

• Courtney Snell (“Ms. Snell”), former executive assistant to the Company

and Mr. Powers, resident of the State of Colorado, see Declaration of
Courtney Snell filed at Case No., 19-10573, Dkt. No. 24-4, and Case No.
19-10574, Dkt. No. 28-4;

• Kristan Hopkins (“Mr. Hopkins”), former Chief Strategy Officer, resident

of the State of Massachusetts, see Ex. G, Hopkins Compl.;

• Balarami Parvathareddy Reddy (“Mr. Ram Reddy”), former Chairman of

the Board, resident of the Commonwealth of Virginia, see a true and correcy
copy of the CommuniClique SEC Form D attached hereto as Exhibit D
(“SEC Form D”);

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• Timothy Gentry (“Mr. Gentry”), former President, resident of the

Commonwealth of Virginia, see id.; and

• Timothy Lee (“Mr. Lee”), former Chief Financial Officer, resident of the
Commonwealth of Virginia, see id.

C. The Creditors

12. Many of the creditors left in the Alleged Debtors’ wake are from Virginia and the

surrounding areas. In fact, only two of the nine Petitioning Creditors are from California, Andrew

and Jamie Schwartzberg (the “Schwartzbergs”), and they prefer Delaware as a venue. Six of the

remaining Petitioning Creditors reside on the East Coast, located in Virginia, New York, and

Pennsylvania. The final Petitioning Creditor is a resident of Australia.

13. In addition, five other known investors (the majority of which are covered by the

Judgment Order) have signed declarations (the “Non-Petitioning Creditor Investor Declarations”)

stating that they are owed substantial sums of money by the Alleged Debtors, reside on the East

Coast, and prefer that the bankruptcy cases remain in Delaware. The Non-Petitioning Creditor

Investor Declarations are attached hereto as Exs. E, Jai Gupta Declaration; F, Satya Akula

Declaration; G, Adam Reinhart; H, Seetarmayya Nagula; and I, Diwakar Nagula, respectively.

Another known creditor, Barrique Holdings, LLC, located in Washington, D.C., has also signed a

declaration (the “Barrique Declaration”) indicating its preference that the Court not transfer the

cases to California. A copy of the Barrique Declaration is attached hereto as Exhibit J.

14. The Petitioning Creditors are also aware of the following recent lawsuits (and,

where noted, judgments) against CommuniClique and/or Powers:

• Alleged Debtors were sued by the Donahue Trusts3 in the Circuit Court of
Fairfax County, Virginia (the “Donahue Complaint”), pursuant to which a

3 The “Donahue Trusts” means collectively, (i) the Jason Mark Donahue ROTH IRA 706358, a self-directed Roth
IRA for the benefit of Jason M. Donahue and his wife, Sara J. Donahue, (ii) the Jason M. Donahue Trust, an individual
Trust owned by Jason M. Donahue, and (iii) the Robert and Carole Donahue Family Trust, a trust for the benefit of

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judgment order was entered in favor of the Donahue Trusts and against the
Alleged Debtors in the amount of $4,302,816.66 (the “Donahue Judgment
Order”). True and correct copies of the Donahue Complaint and the
Donahue Judgment Order are attached hereto as Exhibits K and L.

• Alleged Debtors were sued in April by a former employee, Kristan

Hopkins (“Mr. Hopkins”) for non-payment of wages and compensation in
an amount exceeding $400,000 (the “Hopkins Complaint”). A true and
correct copy of the Hopkins Complaint is attached hereto as Exhibit M.

• CommuniClique was sued (the “Snap Inc. Complaint”) in February by its

landlord, Snap, Inc. (“Snap”). A true and correct copy of the Snap Inc.
Complaint is attached hereto as Exhibit N.

• Finally, this month, Powers was sued (along with the Company) (the
“Rocker Complaint”) by his landlord, Rosanna Rocker (“Ms. Rocker”),
for failure to pay rent for his home in Pacific Palisades, California. A true
and correct copy of the Rocker Complaint is attached hereto as Exhibit O.

15. Ms. Snell, former executive assistant of the Alleged Debtors, owed approximately

$35,000, is a resident of Colorado Springs, Colorado. See Declaration of Courtney Snell filed at

Case No., 19-10573, Dkt. No. 24-4 and Case No. 19-10574, Dkt. No. 28-4. Mr. Hopkins is a

resident of the State of Massachusetts. See Ex. M, Hopkins Compl. Snap is a Delaware

corporation doing business in the State of California. See Ex. N, Snap Compl. It is not known

where Ms. Rocker resides, but she is the owner of the California property rented by Mr. Powers

and his family. See Ex. O, Rocker Compl.

ARGUMENT

I. The Actions were properly commenced in Delaware.

16. CommuniClique is a Delaware corporation; therefore, venue in Delaware is proper

as to it. 28 U.S.C. § 1408(1).

Jason M. Donahue’s parents. See Ex. K (Donahue Compl.). The Donahues chose Virginia as their preferred forum
to litigate the issues set forth in the Donahue Complaint.

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17. Venue in Delaware is also proper as to Mr. Powers due to his “affiliate” status under

the Bankruptcy Code. Specifically, 28 U.S.C. § 1408(2) provides that a case under title 11 may

be commenced in the district court for the district “in which there is pending a case under title 11

concerning such person’s affiliate….” An “affiliate” is defined as an entity (which includes a

person) that “directly or indirectly owns, controls, or holds with power to vote, 20 percent or more

of the outstanding voting securities of the debtor….” 11 U.S.C. 101(2)(A). As of January 15,

2018, Mr. Powers owned 34.25% of the shares of CommuniClique through Empower Investments

LLC (“Empower”). A true and correct copy of the CommuniClique capitalization table as of

January 15, 2018 is attached hereto as Exhibit P. This has not been disputed. Empower is an

entity created and controlled by Mr. Powers, described by him as his “investment office.” See

https://www.andypowers.com. Accordingly, Mr. Powers, through Empower, indirectly owns,

controls and holds more than 20% of the voting securities of CommuniClique. The Petitioning

Creditors have no reason to believe that Mr. Powers, founder and CEO of CommuniClique, does

not have the power to vote those shares through Empower. As such, venue is proper in Delaware

as to Mr. Powers. See In re Innovative Communication Co., LLC, 358 B.R. 120 (Bankr. D. Del.

2006) (found venue of involuntary Chapter 11 case of individual debtor could lie in Delaware due

to individual’s “affiliate” status under the Bankruptcy Code where individual was owner, chairman

of the board, CEO and president of a Delaware company that was subject to a pending involuntary

case in Delaware).

II. The Court should refrain from transferring the Actions to California.

18. Notwithstanding proper venue, the Court “may transfer a case or proceeding under

title 11 to a district court for another district, in the interest of justice or for the convenience of the

parties. 28 U.S.C. § 1412; see also Fed. R. Bankr. P. 1014(a)(1) (If a petition is filed in the proper

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district, the court, on the timely motion of a party in interest or on its own motion, and after hearing

on notice to the petitioners, the United States trustee, and other entities as directed by the court,

may transfer the case to any other district if the court determines that the transfer is in the interest

of justice or for the convenience of the parties.”). “The decision of whether to transfer venue is

within the court’s discretion based on an individualized case-by-case analysis of convenience and

fairness.” In re Caesars Entertainment Operating Company, Inc., 2015 WL 4952559, *5 (Bankr.

D. Del. Feb. 2, 2015) quoting In re Enron Corp., 274 B.R. 327, 342 (Bankr. S.D.N.Y. 2002).

19. Pursuant to the Motion to Transfer, the Court asks why the Actions should not be

transferred to California. At first blush, it is easy to see why the Court raised this issue sua sponte.

Mr. Powers is a California resident and his company, CommuniClique, is apparently doing

business in California. But these are unusual cases. Upon a closer examination, it is not clear that

California is the preferable venue under these circumstances. Petitioning Creditors submit that it

is not, and that Delaware is the proper venue to administer these cases both from a convenience

and fairness perspective.

A. Convenience of the Parties

20. “When considering convenience of the parties for purposes of transfer of venue, .

. . courts often look to the factors set forth in the United States Court of Appeals for the Fifth

Circuit’s CORCO decision.” Id. at *6. These factors include:

(1) The proximity of creditors of every kind to the Court;

(2) The proximity of the debtor to the Court;

(3) The proximity of the witnesses necessary to the administration of the estate;

(4) The location of the assets;

(5) The economic administration of the estate; and

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(6) The necessity for ancillary administration in the event of liquidation.

Id. citing In re Commonwealth Oil Refining Co. 596 F.2d 1239, 1247 (5th Cir. 1979) (“CORCO”);

Innovative, 358 B.R. at 126; Enron, 274 B.R. at 343.

(1) Proximity of Creditors

21. The first factor, the proximity of creditors of every kind to the Court, weighs

heavily in favor of this Court retaining jurisdiction. Each of the Petitioning Creditors chose this

venue as their preferred forum. Six out of nine of the Petitioning Creditors reside on the East

Coast, one lives in Australia and the Schwartzbergs, the only West Coast residents of the

Petitioning Creditors, prefer Delaware as a venue.

22. Moreover, a number of other large-scale creditors—many of whom are judgment

creditors by virtue of the VA Securities Action—reside on the East Coast. See Exs. E-J

(Declarations of Non-Petitioning Creditors). Delaware is more convenient and is the preferred

venue for these creditors. Id. These creditors’ preference should be given substantial weight, as

they account for more than $7 million in debt on their own. Id.

23. Other known creditors of the Alleged Debtors reside in Massachusetts (Mr.

Hopkins) and Colorado (Ms. Snell). Snap, CommuniClique’s landlord, is a Delaware corporation

that operates in California.4

24. While the residences of other creditors of the Alleged Debtors are likely spread

throughout the United States (and potentially abroad), it is expected that there is a high

concentration on the East Coast, where the Alleged Debtors operated their business (and

orchestrated their fraud) for many years. Indeed, the overwhelming majority of creditors whose

residences are known by the Petitioning Creditors are located on the East Coast, as set forth herein.

4 Ms. Rocker, Mr. Powers’ landlord, may also reside in California, but it is not known.

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These creditors would be inconvenienced by a transfer to California (and, in fact, prejudiced, if

there is further dissipation of assets because of any delays associated with a venue transfer).

25. On balance, Delaware is closer in proximity for known creditors of the Alleged

Debtors than California. And, of note, no creditor has expressed a preference for these cases to

be transferred to California. Accordingly, this factor weighs strongly in favor of this Court

retaining jurisdiction.

(2) Proximity of Alleged Debtors

26. Petitioning Creditors are not aware of any current employees of the Company (other

than Mr. Powers) or of any current physical office in which the Company resides. See Ex. N, Snap

Compl. (CommuniClique is being sued by its landlord for unpaid rent and is no longer in

possession of the premises). For all intents and purposes, the Company is Mr. Powers, who resides

in California. Obviously, California is closer in proximity for the Alleged Debtors than Delaware.

While courts generally give the debtor’s choice of forum a certain level of deference, such

deference is more closely scrutinized in an involuntary case commenced by the debtor’s creditors.

Id. at *8. Under the circumstances, the Court should give very little deference to the Alleged

Debtors’ choice of forum.

27. First, the reason Mr. Powers and his Company are in California in the first place

appears to stem from circumstances created by their own misconduct. Prior to August 2018, Mr.

Powers lived in, and operated his Company out of, Virginia. Only when the Hearing Examiner

issued her Report, (i) finding that the Alleged Debtors violated the Virginia Securities Act by

making material false misrepresentations to investors, and (ii) recommending (a) that the Alleged

Debtors pay almost $10 million in restitution to the aggrieved investors, and (b) that a permanent

injunction be put in place that would prevent the Alleged Debtors from ever offering or selling

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securities in Virginia again, did the Alleged Debtors leave Virginia. And they did so abruptly, but

not first without draining the Company’s bank accounts and leaving a slew of creditors in their

wake. See Ex. C, Summary Bank Statements.

28. Second, as set forth in more detail in the Petitioning Creditors’ Motion for (I) Entry

of an Order Striking Alleged Debtors' Answers to Involuntary Petitions, and (II) Entry of the

Orders for Relief [Case No. 19-10573, Dkt. No. 24; Case No. 19-10574, Dkt. No. 28], the Alleged

Debtors seem to have learned very little from their past misdeeds. Instead, in an effort to prove

that they are capable of paying large debts as they come due, the Alleged Debtors falsified invoices

that were submitted to this Court as evidence that it should not enter the orders for relief pending

against them. Suffice it to say, the convenience of forum for the Alleged Debtors should be a low

priority to the Court.

(3) Proximity of Witnesses

29. The Company’s former employees may be witnesses necessary to the

administration of the estates. Those employees include Ms. Snell, who resides in Colorado, see

Declaration of Courtney Snell filed at Case No., 19-10573, Dkt. No. 24-4, and Case No. 19-10574,

Dkt. No. 28-4; Mr. Hopkins, who resides in Massachusetts, see Ex. M, Hopkins Compl.; Mr. Ram

Reddy, who resides in Virginia, see Ex. D, SEC Form D; Mr. Gentry, who resides in Virginia, see

id.; and Mr. Lee, who resides in Virginia, see id. But for Ms. Snell, all of CommuniClique’s former

employees that may be necessary witnesses reside on the East Coast. On balance, Delaware is

closer in proximity than California for potential known witnesses.

(4) Location of Assets

30. Petitioning Creditors do not yet know precisely what assets the Alleged Debtors

have and where those assets are located. However, Petitioning Creditors believe that the Alleged

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Debtors’ primary assets are movable (i.e., cash and investments) or intangible (i.e., intellectual

property and contracts). It is not known whether the Alleged Debtors have any tangible assets

located in California, but both CommuniClique and Mr. Powers rented space in California, so,

presumably, they do not own real property in California. The location of assets on a whole should

not tip the scales one way or the other.

(5) The Economic (and Efficient) Administration of the Estate

31. The economic and efficient administration of the estate is often cited as the most

important consideration when determining whether to transfer venues. Caesars, 2015 WL

4952559, *6; CORCO, 596 F.2d at 1247; Enron, 274 B.R. at 348. Here, there is no reason to

believe that the ability of this Court and the California court to administer the Alleged Debtors’

bankruptcy cases in a just and efficient manner is, in general, anything but equal. However, while

the Actions have not been pending for long (relatively speaking), this Court has developed a

“learning curve” based on the (unfortunate) matters that have already come before it in these cases,

gaining valuable familiarity with many of the issues that have and will likely continue to arise in

these cases. See Enron, 274 B.R. at 349. This “learning curve” contributes to judicial economy,

and should weight in favor of keeping the cases in Delaware. Id.

32. Moreover, it is in the interest of efficiency and economy that there be no delay,

which will be inevitable in the event of a transfer. Alleged Debtors’ misdeeds make it all the more

likely that any delay will be used to further deplete their estates. A trustee’s prompt appointment

is essential.

33. Further, since it appears the trustee will not be administering tangible assets in

California, neither venue is more convenient than the other for that purpose.

34. Accordingly, this factor weighs heavily in favor of keeping this case in Delaware.

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(6) Necessity for Ancillary Administration in the Event of Liquidation

35. It is not clear that this factor applies in a Chapter 7 context where a liquidation is

contemplated. Even in a Chapter 11 case, courts have discounted the importance of the sixth

CORCO factor. See CORCO, 596 F.2d at 1248 (stating that the anticipation of the failure of the

Chapter XI proceeding is an illogical basis upon which to predicate a transfer); Caesars, 2015 WL

495259, *6 fn. 7. Nevertheless, as set forth in the preceding section, since it appears the trustee

will not be administering tangible assets in California, neither venue is more convenient than the

other for that purpose. Further, all known litigation against the Alleged Debtors can be effectively

and efficiently administered through the bankruptcy claims process.

B. Interest of Justice

36. “The ‘interest of justice’ component of Section 1412 is a broad and flexible

standard which must be applied on a case-by-case basis. It contemplates a consideration of

whether transferring venue would promote the efficient administration of the bankruptcy estate,

judicial economy, timeliness, and fairness….” Id. at *7 quoting In re Patriot Coal Corp., 482 B.R.

718, 739 (Bankr. S.D.N.Y. 2012).

37. The considerations involved with the interest of justice are intertwined with the

economic and efficient administration of the estate. Enron, 274 B.R. at 349. As set forth above,

it does not appear that these cases will be more economical or efficient in one venue over the other.

However, the Petitioning Creditors submit that this Court has developed a “learning curve” in these

cases that weighs toward keeping the cases in Delaware.

38. Petitioning Creditors have selected Delaware as their chosen forum, and many other

creditors have expressed a preference for maintaining the case in Delaware. And, on balance, the

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CORCO factors tip towards keeping the cases in Delaware. The only parties that truly benefit

from a transfer to California are the Alleged Debtors, who would benefit from further delay of

these proceedings. The Court must ask itself what is fair under the circumstances. Petitioning

Creditors submit that fairness requires the Court to keep the Actions in Delaware, their chosen

forum, and, under these particular circumstances, not give deference to the convenience of the

Alleged Debtors.

CONCLUSION

39. For all the reasons set forth herein, Petitioning Creditors respectfully submit that

the Court should deny the Motion to Transfer and keep the Actions in Delaware.

Dated: May 6, 2019 VENABLE LLP

Wilmington, Delaware

/s/ Daniel A. O’Brien________________

Daniel A. O’Brien (No. 4897)
1201 N. Market Street, Suite 1400
Wilmington, Delaware 19801
Telephone: 302-298-3535
Facsimile: 302-298-3550
daobrien@venable.com

-and-

Andrew J. Currie, Esq.

Benjamin E. Horowitz, Esq.
600 Massachusetts Avenue, NW
Washington D.C. 20001
Telephone: 202-344-4586
Facsimile: 202-344-8300
ajcurrie@venable.com
behorowitz@venable.com

Counsel to the Petitioning Creditors

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