谢谢各位阅读我的前一个帖子，下面补充如下，希望多多的建议。
1）我的客户最先是filed Charpter 11 （October 13, 2014）。Court ordered the appointment of a chapter 11 trustee. Thereafter, Trustee was appointed the chapter 11 trustee for the Debtor’s bankruptcy estate
2）我同客户之间的买卖是从6月到9月/2014，是在破产保护之前。
4）问题是 By Order entered on April 30, 2015, the Court converted this case to a case under chapter 7 of the Bankruptcy Code pursuant to 11 U.S.C. § 1112(b). Following conversion of the case, Trustee has appointed the chapter 7 trustee of the Debtor’s bankruptcy estate. 就是说先是11， 然后再变成7。
5）破产公司trustee 律师说“Defendant was a supplier of various goods to the Debtor. During the ninety days prior to the Petition Date a balance existed on the Debtor’s account with Defendant.”我们只提供了电池片。
6）破产公司trustee 律师的理由是“At the time each of the Payments were made the Debtor is insolvent as the value of its assets at fair valuation was substantially less than the aggregate of its liabilities.”就是说公司已经资不抵债但是还在付款。注意，我们的买卖是发生在公司破产之前。
7）Trustee律师要我还钱（~$100K)的理由如下
a) The Payments to Defendant were of transfers of interests of the Debtor in property.
b) Upon information and belief, at the time of the Payments Defendant was a creditor of the Debtor; thus, the Payments were made to or for Defendant’s benefit. As a consequence, the Payments to Defendant were made for or on account of an antecedent debts owned by the Debtor to Defendant.
c) The transfer of the Payments to Defendant were made within 90 days of the Petition Date. 注意，这里应该是Charpter 11，而不是Charpter 7.
d) At the time of each of the Payments the Debtor was insolvent.
e) The transfer of the Payments to Defendant enabled Defendant to receive more than Defendant would have received if the Debtor’s case was a case under Chapter 7 of the Bankruptcy Code, the Payments had not been transferred, and Defendant received payment of their outstanding debts to the extent provided by the provisions of the Bankruptcy Code. 没有理由，如果是Charpter 7, 公司就不可能再从事生产而是必须关门，怎么还能向我们买东西呢？
f) Based on the foregoing, the transfer of the Payments to Defendant are avoidable pursuant to Section 547(b) of the Bankruptcy Code. 是的，不付钱我们也不会卖东西的。
g) Plaintiff is, therefore, entitled to judgment against Defendant avoiding the transfer of the Payments.
h) Section 550(a) of the Bankruptcy Code provides that to the extent a transfer is avoided under Section 547 the trustee may recovery, for the benefit of the estate, the property transferred, or if the Court so orders, the value of such property from the initial transferee of such transfer or the entity for whose benefit such transfer was made or, alternatively, any immediate or mediate transfer of such transferee.
i) The transfer of the Payments to Defendant are avoidable pursuant to Section 547 of the Bankruptcy Code.
j) Defendant is the initial transferee of the Payments
k) Accordingly, Plaintiff is entitled to a judgment against Defendant recovering the Payments for the benefit of the Debtor’s bankruptcy estate
当然最坏的情况是亏$100K加上律师费，再就是同Trustee 律师make a deal (我可以不用找律师？）或者是fight at the court with a 律师。
