Little Hal Turner in big trouble in bankruptcy court.

I'll just let everyone read this and come up with their own conclusion.



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UNITED STATES BANKRUPTCY COURT

DISTRICT OF NEW JERSEY



FORMAN HOLT ELIADES & RAVIN LLC

80 Route 4 East, Suite 290

Paramus, New Jersey 07652

201-845-1000

Attorneys for Benjamin A. Stanziale, Jr.
Case No.: 10-15164 (DHS)
Chapter 7 Trustee
Judge: Hon. Donald H. Steckroth
Joseph M. Cerra (JC 0903) Chapter: 7

In re:



HAROLD C. TURNER,
Debtor.
___________________________________________
BENJAMIN A. STANZIALE, JR., Chapter 7 Trustee,

Plaintiff, Adv. Pro. No. 10-

- against -

HAROLD C. TURNER,
Defendant.





COMPLAINT OBJECTING TO DISCHARGE,
AND FOR TURNOVER AND AN ACCOUNTING

Benjamin A. Stanziale, Jr., chapter 7 trustee (“Plaintiff”) of the estate of Harold C. Turner,
Debtor (“Debtor”), by and through his attorneys, Forman Holt Eliades & Ravin LLC, by way of
complaint against Harold C. Turner (“Defendant”), sets forth as follows:
PROCEDURAL BACKGROUND
1. On February 24, 2010 (the “Filing Date”), the debtor Harold C. Turner (the ‘Debtor”)
filed a voluntary petition pursuant to Chapter 7 of Title 11 of the United States Code (the



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“Bankruptcy Code”).
2. Benjamin A. Stanziale, Jr. was appointed Chapter 7 Trustee (the “Trustee”) for the
Debtor’s estate on February 24, 2010.
JURISDICTION AND VENUE
3. This adversary proceeding is brought under Case No. 10-15164 (DHS) now pending
before this Court.
4. This Court possesses jurisdiction over the subject matter of this action pursuant to 28
U.S.C. §§157(b)(1) and 1334(b), as this action arises under, in, or is related to a case under the
Bankruptcy Code.
5. This Court further possesses jurisdiction according to the terms of the “District Court
General Order of Reference” of the United States District Court for the District of New Jersey dated
July 23, 1984, as it arises under the Debtors’ Chapter 7 bankruptcy cases pending in this Court.
6. This adversary proceeding is brought pursuant to 11 U.S.C. §§542 and 727.
7. This is a core proceeding within the meaning of 28 U.S.C. §157(b)(2)(A), (E), (J) and
(O).
8. Venue is proper under 28 U.S.C. §1409(a).
FACTUAL ALLEGATIONS
9. The Debtor, who publicly identifies publicly known as “Hal Turner,” is an internet
blogger who hosted an internet radio program on what he called the “Turner Radio Network.” Over
the years, the Debtor gained notoriety, in some circles, for his extreme right-wing political beliefs
and his support of what he called the “pro-white movement.”
10. The debtor’s petition and schedules indicate that he owes about $95,000 in unsecured
debt. He has no secured debt according to his petition and schedules. He apparently resides in a

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condominium that he shares with his wife, Phyllis Turner. He scheduled neither rent payments nor
mortgage payments.
11. He claims to live on government subsidies of about $860 per month and claims
expenses of about $960 per month.
12. His wife, Phyllis Turner, filed for bankruptcy in 2001. In her petition and schedules,
she claimed that she was the 100% owner of the condominium, which she valued at $87,400 with a
first-lien of $69,000. She exempted her equity and the property was abandoned by her trustee,
Carmen Maggio.
13. The Debtor was recently convicted on charges of making terroristic threats against
three United States Circuit Judges, having written on his blog that they “deserve to be killed.” He
has been tried on the same charges two prior occasions in the United States District Court for the
Eastern District of New York on these charges - both times to hung juries.
14. The docket of the Debtor’s criminal proceedings identifies three attorneys as his
defense counsel. Two of them are private practice attorneys; neither is scheduled as a creditor in his
bankruptcy filings. The Debtor does not indicate anywhere on his petition how he has paid his
criminal defense attorneys.
15. The Debtor frequently commented during his radio broadcasts of his overall net
worth. During a broadcast in October 2007, the Debtor stated:
My house is paid off. My cars are paid off. I’ve got $100,000 in Fidelity Mutual
Funds and another $150,000 in Commerce Capital. That totals $250,000 cash. How
many others in the movement can say that? Yet some deride me as begging for
money when I can buy and sell just about any of them.

16. The Trustee issued a Rule 2004 subpoena to the Debtor requesting that he appear for
examination and produce various documents pertaining to his assets and net worth.
17. On August 3, 2010, the date on which the Debtor was obligated to produce

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documents by 4 p.m., the Debtor’s counsel called the Trustee’s counsel to advise that the Debtor
would not produce documents on August 3, 2010 and could not appear for the Rule 2004
examination scheduled for the next day.
18. Thereafter, the Trustee filed a motion with this Court seeking to extend the deadline
to file a non-dischargeability complaint against the Debtor. The Court granted the motion, extended
the deadline to file until September 30, 2010, and provided in the Order that the Debtor must sit for
the Rule 2004 examination and produce documents no later than September 10, 2010.
19. The Debtor did not comply with the deadlines in the Court’s order.
20. On September 15, 2010, the Trustee’s counsel wrote to the Debtor requesting his
prompt compliance with the Order requiring him to make Rule 2004 disclosures and appear for a
Rule 2004 examination. This letter was copied to the Debtor’s bankruptcy attorney.
21. Neither the Debtor nor his counsel thereafter contacted the Trustee’s counsel to
arrange for compliance with the Court’s Order.
FIRST COUNT
(Objection to Discharge Pursuant to 11 U.S.C. §727(a)(3))
22. Plaintiff repeats the allegations of Paragraphs “1” through “21” as if set forth at
length here.
23. Defendant has destroyed or failed to keep or preserve any recorded information,
including books, documents, records, and papers, from which Defendant’s financial condition or
business transactions might be ascertained.
WHEREFORE, Plaintiff demands judgment against Defendant denying the Defendant’s
discharge pursuant to Section 727(a)(3) of the Bankruptcy Code; awarding to Plaintiff his costs of
suit, including reasonable attorneys’ fees; and granting to Plaintiff such other relief as this Court

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deems just and proper.
SECOND COUNT
(Objection to Discharge Pursuant to 11 U.S.C. §727(a)(4)(A))
24. Plaintiff repeats the allegations of Paragraphs “1” through “21” as if set forth at
length here.
25. Defendant failed to disclose the cash values of various assets, including Fidelity
Mutual Funds account and his Commerce Capital account.
26. Defendant signed his schedules under penalties of perjury.
27. Defendant knowingly and fraudulently, in or in connection with their case, made a
false oath or account.
WHEREFORE, Plaintiff demands judgment against Defendant denying Defendant’s
discharge pursuant to Section 727(a)(4)(A) of the Bankruptcy Code; awarding to Plaintiff his costs
of suit, including reasonable attorneys’ fees; and granting to Plaintiff such other relief as this Court
deems just and proper.
THIRD COUNT
(Objection to Discharge Pursuant to 11 U.S.C. §727(a)(4)(D))
28. Plaintiff repeats the allegations of Paragraphs “1” through “27” as if set forth at
length here.
29. The Debtor failed to turnover to Plaintiff recorded information, including books,
documents, records, and papers, relating to their property or financial affairs.
WHEREFORE, Plaintiff demands judgment against Defendant denying the Defendant’s
discharge pursuant to Section 727(a)(4)(D) of the Bankruptcy Code; awarding to Plaintiff his costs
of suit, including reasonable attorneys’ fees; and granting to Plaintiff such other relief as this Court

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deems just and proper.
FOURTH COUNT
(Objection to Discharge Pursuant to 11 U.S.C. §727(a)(5))
30. Plaintiff repeats the allegations of Paragraphs “1” through “29” as if set forth at
length here.
31. According to the Debtor’s public pronouncements, he possessed assets sufficient to
pay his creditors in full at times prior to the Filing Date.
32. Defendant has failed to explain satisfactorily any loss of assets or deficiency of assets
to meet his liabilities.
WHEREFORE, Plaintiff demands judgment against Defendant denying Defendant’s
discharge pursuant to Section 727(a)(5) of the Bankruptcy Code; awarding to Plaintiff his costs of
suit, including reasonable attorneys’ fees; and granting to Plaintiff such other relief as this Court
deems just and proper.
FIFTH COUNT
(Objection to Discharge Pursuant to 11 U.S.C. §727(a)(6))
33. Plaintiff repeats the allegations of Paragraphs “1” through “32” as if set forth at
length here.
34. The Debtor has disobeyed a lawful order of this Court to produce documents in
response to the Trustee’s Rule 2004 notice.
35. The Debtor has disobeyed a lawful order of this Court to testify pursuant to the
Trustee’s Rule 2004 and the refusal to testify was not on based on his privilege against self-
incrimination.
WHEREFORE, Plaintiff demands judgment against Defendant denying Defendant’s

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discharge pursuant to Section 727(a)(6) of the Bankruptcy Code; awarding to Plaintiff his costs of
suit, including reasonable attorneys’ fees; and granting to Plaintiff such other relief as this Court
deems just and proper.
SIXTH COUNT
(Accounting Pursuant to 11 U.S.C. §542)
36. Plaintiff repeats the allegations of Paragraphs “1” through “35” as if set forth at
length here.
37. The Debtor is in control, possession, custody or control of property which is property
of the estate.
38. Accordingly, pursuant to the provisions of Section 542(a) of the Bankruptcy Code,
the Debtor must account and turn over to the Trustee that property which is property of the estate.
WHEREFORE, Plaintiff demands judgment against the Defendant requiring him to account
and turn over to the estate, pursuant to 11 U.S.C. §542(a), property of the estate; awarding to
Plaintiff his costs of suit, including reasonable attorneys’ fees; and granting to Plaintiff such other
relief as this Court deems just and proper.
Respectfully submitted,
FORMAN HOLT ELIADES & RAVIN LLC
Attorneys for Trustee



By:_/s/ Joseph M. Cerra_______________________________
Joseph M. Cerra

Dated: September 30, 2010