BOBBY N. HARMON, CPCU, ARM
Telephone :
Email: bobby_n_harmon@yahoo.com
Website: www.the-catbird-seat.net
Defendant, Pro Se
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF HAWAII
OFFICE OF THE U.S. TRUSTEE ) CASE NO. CV05-00030 DAE KSC
)
Plaintiff, ) DEFENDANT BOBBY N. HARMON’S
) OBJECTION TO THE APPOINTMENT
vs. ) OF JAMES B. NICHOLSON AS
) SUCCESSOR TRUSTEE; MOTION
BOBBY N. HARMON, ) FOR ORDER TO DISAPPROVE THIS
) APPOINTMENT
Defendant )
) NON-HEARING MOTION
) _______________
) Trial Date: None
) Judge: Hon. Kevin S. Chang
________________________________)
DEFENDANT BOBBY N. HARMON’S OBJECTION TO PLAINTIFF’S
APPOINTMENT OF JAMES B. NICHOLSON AS
SUCCESSOR TRUSTEE; MOTION FOR ORDER TO DISAPPROVE
THIS APPOINTMENT
COMES NOW Defendant BOBBY N. HARMON and submits this OBJECTION TO PLAINTIFF’S APPOINTMENT OF JAMES B. NICHOLSON AS SUCCESSOR TRUSTEE for the following reasons:
1. On May 25, 2006, Defendant received a notice dated May 12, 2006, from the Office of the U.S. Trustee that they were appointing James B. Nicholson as successor trustee in this case. This notice was delayed in delivery as it was sent to my former address in Las Vegas, NV.
2. The Office of the U.S. Trustee did not provide to the Defendant any disclosures or biographical information regarding their successor trustee appointee, James B. Nicholson. It is well known to the Office of the U.S. Trustee that Defendant has challenged and objected to the appointment of previous trustees due to numerous and undisclosed personal, professional, political and financial connections with various entities involved in this case, including former trustee Mary Lou Woo. Also, due to the direct involvement of a number of insurance entities in this case, Defendant has previously requested that he be provided the identities of all insurance companies and brokers providing professional liability insurance and trustee bonds to any appointed trustees. This information has not yet been provided by the Office of the U.S. Trustee, James B. Nicholson, or by any other parties related to this case, including former trustee Mary Lou Woo and her attorney Steven Guttman.
3. Defendant, through his own independent research, has discovered that successor trustee appointee, James B. Nicholson, has a number of apparent conflicts-of-interest in this case which would cause him to be biased against Defendant. For example, reports state that James B. Nicholson played college football at Michigan State University and pro-football for the Kansas City Chiefs. A teammate of Mr. Nicholson was reported to be Honolulu City Councilman, Arnold Morgado, who is, or was, the president of the Association of Parents and Teachers of Kamehameha Schools, and who has been in a position to affect legislation related to issues involving that entity. Another apparent connection is a Michigan businessman and community leader named James B. Nicholson, whom I believe to be closely related to this trustee appointee of the same name. This individual is, or was, an officer for the Michigan chapter of The Nature Conservancy - a non-profit organization with substantial financial ties to Kamehameha Schools, Peter Savio, Faye Kurren (wife of Judge Barry Kurren), Guido Giacometti, Nathan Aipa, Colleen Wong, Henry Paulson, Goldman Sachs, PricewaterhouseCoopers, Ben Benson, Mark McConaghy, and other parties directly related to this case.
II. MOTION TO DISAPPROVE THE APPOINTMENT OF JAMES B. NICHOLSON AS SUCCESSOR TRUSTEE
Based upon the facts and arguments presented herein, Defendant respectfully asks that the Court DISAPPROVE the appointment of James B. Nicholson as successor trustee.
DATED: Kentucky, June 5, 2006
_____________________________
BOBBY NORRIS HARMON,
Debtor Pro Se