Raubach v. Holt Solutions, LLC

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THIS MATTER is before the Court upon the Debtor's Response and Declaration to Order Denying Debtor's Request to Purge Contempt, Further Sanctioning Debtor, and Denying Debtor's Discharge [Doc. No.¹224; Adv. Proc. Doc. No. 57], filed on October 6, 2025 (the "First Contempt Review Motion"), Motion to Vacate or Stay Civil Contempt Proceedings, for Protective Relief, and Supporting Memorandum of Law Under Fed. R. Bankr. P. 9020 and Due Process Principles [Do. No. 242], filed on October 27, 2025, (the "Second Contempt Review Motion"), Motion to Vacate Contempt Order and For Declaratory Relief that the Court Exceeded Its Article I Authority [Doc. No. 248], filed on October 30, 2025, (the "Third Contempt Review Motion"), Motion to Vacate or Deny Contempt and Sanctions for Lack of Evidence Basis and Violation of Federal Rules of Evidence and Due Process [Doc. No. 252], filed on October 30, 2025 (the "Fourth Contempt Review Motion"), Motion for Reconsideration, Protective Relief, and Stay Pending Appeal [Doc. No. 293], filed on November 12, 2025 (the "Fifth Contempt Review Motion"), and Motion to Reconsideration, Protective Relief, and Emergency Stay Pending Appeal [Doc. No. 295], filed on November 12, 2025 (the "Sixth Contempt Review Motion," and together with the First Contempt Review Motion, the Second Contempt Review Motion, the Third Contempt Review Motion, the Fourth Contempt Review Motion, the Fifth Contempt Review Motion, the "Contempt Review Motions"), all relating to the Court's Order Finding Debtor in Civil Contempt [Doc. No. 132; Adv. Proc. Doc. No. 34], entered July 14, 2025 (the "Contempt Finding Order"), Opinion and Order Sanctioning Debtor for Failure to Comply with Omnibus Order and Contempt Order [Doc. No. 147; Adv. Proc. Doc. No. 39], entered July 29, 2025 (the "Contempt Sanctions Order"), Order

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Denying Debtor's Request to Purge Contempt, Further Sanctioning Debtor, and Denying Debtor's Discharge [Doc. No. 223; Adv. Proc. Doc. No. 56], entered October 7, 2025 (the "Contempt Further Sanctions and Discharge Order"), and Order Continuing For Final Hearing [Doc. No. 270], entered on November 4, 2025 (the "Final Contempt Order," and together with the Contempt Finding Order, the Contempt Sanctions Order, the Contempt Further Sanctions and Discharge Order, the "Contempt Orders"), as well as before the Court upon the Debtor's Motion for Reconsideration of Order Denying Motion to Shorten Notice and Asserting Procedural Disadvantage and Prejudice [Doc. No. 264], filed on November 3, 2025 (the "Notice Reconsideration Motion," and together with the Contempt Review Motions, the "Debtor's Outstanding Motions"), and related to the Court's Order Denying Motion to Shorten Notice [Doc. No. 258], entered on October 31, 2025 (the "Denying Shortened Notice Order"). For the reasons outlined below, (1) terminates the Debtor's civil contempt, (2) orders the Debtor to pay the fines she has accrued under the Contempt Orders, (3) reports to the U.S. Attorney for the Western District of North Carolina and the Mecklenburg County District Attorney various crimes, (4) denies the Debtor's Outstanding Motions, (5) denies the Debtor's discharge, (6) bars the Debtor from docketing any filings in her Chapter 7 Base Case without prior approval by the Court, and (7) denies the request for Federal Rule of Bankruptcy Procedure 9011 sanctions against the Debtor.

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I. FACTUAL AND PROCEDURAL HISTORY²

A. Introduction

1. On December 23, 2024 (the "Petition Date"), the Debtor filed her pro se, Voluntary Petition [Doc. No. 1] (the "Debtor's Petition"), for relief under Chapter 7 of Title 11 of the United States Code. The Petition Date would begin what will probably be one of the most involved individual Chapter 7 cases the Court will have.

B. Pre-Petition and Petition Date Facts

1. The Debtor's Assets

2. As recently as 2023, the Debtor owned two properties: (1) a property at 3819 Yorkford Dr, Charlotte, North Carolina, 28269 (the "Yorkford Property"), and (2) a property at 6415 Nevin Glen Drive, Charlotte, North Carolina, 28269 (the "Nevin Property," and together with the Yorkford Property, the "Properties").³As of the Petition Date, the Debtor received almost $1,800 in income from renting the Nevin Property (the "Rental Income").⁴

3. The Debtor formed Holt Solutions, LLC, a North Carolina limited liability company ("Holt Solutions") on April 20, 2022 (the "Holt Solutions Creation Date").⁵Holt

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Solutions' sole registered member, organizer, and agent is the Debtor, and its mailing and principal and registered office addresses is the same as the Yorkford Property's address.⁶which she described in official records as a tribal property.⁷The Debtor also so operates, as of the Petition Date, Holts Consulting, another North Carolina limited liability company ("Holts Consulting").⁸ A year and a day after the Holt Solutions Creation Date and around 19 months prior to the Petition Date, the Debtor conveyed to Holt Solutions first the Yorkford Property (the "Yorkford Property Conveyance")⁹and then the Nevin Property (the "Nevin Property Conveyance," and together with the Yorkford Property Conveyance, the "Conveyances"),¹⁰on April 23, 2023 (the "Conveyances Date").¹¹

4. On the Petition Date, the Debtor held almost $9,200 in bank accounts (the "Debtor's Held Funds").¹²Additionally, twenty-six bank accounts existed on the Petition Date which belonged to the Debtor either wholly individually, jointly with her dependents, or through Holt Solutions (the "Debtor's Accounts").¹³The month prior to the Petition Date, the Debtor was actively using four of the Debtor's Accounts, which were also the four accounts which held the most funds as of the Petition Date; from three of those four accounts the Debtor transferred funds five times on the Petition Date itself.¹⁴

Production Motion"), as Ex. A, pp. 6-8 (the "Holt Solutions State Registration Filing") (providing the Debtor's filing with the North Carolina Secretary of State the articles of organization forming Holt Solutions, LLC, describing it as a "Tribal LLC [that] function[s] as a multi-purpose Aboriginal Tribal Association Trust").

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2. The Tribal Entities and the Tribal Courses

5. The Debtor is and has been a member of the Xi-Amaru Tribe (the "Tribe") since at least 2022, according to the Debtor's admission to the Court. The Tribe appears to one entity within a larger amorphous group of related entities or individuals, including, in addition to the Tribe, the Aboriginal Republic of North America ("ARNA"), HAWAB DFW Region 6, Shabazz Associates, the Aboriginal Medical Association, the Aboriginal University, a 'Minister' Kojo Xi Shabazz, also known as Aboriginal Don ("Minister Kojo"), and a 'Dr.' Amaru Nama Taga Xi-Ali, also known as 'Dr.' Ali Muhammad ("Dr. Ali") (collectively and together with the Tribe, the "Tribal Entities").

6. The Tribal Entities offer various educational courses (the "Tribal Courses"), some of which are labeled 'Jurist' and appear to purport to teach about the law (the "Jurist Courses").¹⁵ The Debtor has taken various courses with the Tribe (the "Debtor's Tribal Courses") and began, around the Petition Date, one of the Jurist Courses (the "Debtor's Jurist Course"), per her submissions. Within three years prior to the Petition Date, the Debtor made nearly $4,000 in payments to various Tribal Entities (the "Tribal Payments").¹⁶

3. The Petition and the IFP Application

7. In the Debtor's Petition, the Debtor made selective and false submissions, as well as material omissions, regarding her financial matters. As to the Debtor's assets, although the Debtor's Petition did disclose (1) the Debtor's interest in the Debtor's vehicle,¹⁷(2) the Debtor's interest in Holts Consulting and the latter's existence since April 7, 2022,¹⁸and (3) an interest in

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the Properties with an asserted valuations for the Properties,¹⁹the Petition omitted any reference

(1) to creditors of the Properties or the vehicle (the "Debtor's Creditors"),²⁰as well as (2) to Holt Solutions or the Debtor's interest in Holt Solutions.²¹The Petition also denied generally the Conveyances' occurrence.²²Lastly, the Debtor's Petition claimed a "homestead exemption" and various exemptions pursuant to laws concerning foreign or federally recognized Native individuals (the "Debtor's Tribal Exemptions") for the Debtor's assets generally.²³

8. As to the Debtor's income, the Debtor's Petition asserted that the Debtor's income was around $3,000 monthly (the "Debtor's Asserted Income") for herself and for her three dependents, which omitted the Rental Income.²⁴Furthermore, the Debtor's Petition also explicitly denied the Rental Income's existence, both specifically as of the Petition Date²⁵and generally within two years of the Petition Date.²⁶The Debtor's Petition also denied specifically the Debtor's Held Funds' existence and omitted any reference to any of the Debtor's Accounts.²⁷

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9. Along with her Petition, the Debtor also filed the Application to Proceed In Forma Pauperis [Doc. No. 4] (the "IFP Application"), requesting that the Court waive the Debtor's Chapter 7 filing fee due to the Debtor's income being below the threshold, 150% of the poverty line for the debtor's household. For this calculation, the IFP Application provided similar numbers to those provided in her Petition, also omitting the Rental Income.²⁸The IFP Application did disclose one of the Debtor's Accounts with a balance of $0.00 but affirmed that that amount encompassed the Debtor's Held Funds.²⁹The Court granted the IFP Application.³⁰

C. January through May Facts

1. The January 341 Meeting, Early Filings, and the April 23 Hearing

10. On January 22, 2025, the Trustee held a 341 Meeting of Creditors (the "January

341 Meeting").³¹By then, the Trustee had learned of Holt Solutions and the Conveyances through independent research, since the Debtor's Petitions' had omitted both matters.³²At the January 341 Meeting, the Debtor made additional similar false submissions regarding the truth of the Debtor's Petition (1) generally³³and as the Debtor's Petition pertained (2) to the Debtor's assets³⁴and (3)

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the Conveyances,³⁵as well as regarding (4) the Tribal Payments.³⁶The Debtor also described Holt Solutions and Holt Consulting as operating on behalf of the Tribe to which they also owed any income received.³⁷She described Holt Solutions as managing the Properties for the Tribe³⁸and asserted that the Tribe "controls" and is responsible for the Properties³⁹on account of the Conveyances because the Tribe "owns" Holt Solutions as "tribal property" or a "tribal business."⁴⁰

11. The same day as the January 341 Meeting, the Trustee filed a Notice of Possible Dividends and Request for Notice to Creditors [text-only docket entry]. On March 3, 2025, the Debtor filed the Pro Se Reaffirmation Agreement Between Debtor and Navy Federal Limited [Doc. No. 19] (the "Reaffirmation Agreement"). The Reaffirmation Agreement provided the Debtor's Asserted Income for the Debtor's income, excluding the Rental Income.⁴¹On March 20, 2025, the

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Trustee filed the Objection to Exemptions [Doc. No. 20] (the "Exemptions Objection"), objecting to the Debtor's Tribal Exemptions as lacking basis in law.⁴²

12. Over the following month, the Debtor would move twice to end the Chapter 7 Base Case. First, on April 3, 2025, the Debtor filed the Motion to Voluntary Dismiss Case [Doc. No. 26] (the "Dismissal Motion"), asserting that the Chapter 7 Base Case was filed under the mistaken impression bankruptcy was necessary to deal with her debts, but had concluded that negotiating with her creditors outside of bankruptcy would better ensure she retains her assets.⁴³On April 22, 2025, the Debtor filed the Notice of Motion and Motion to Convert Chapter 7 Case to Chapter 11 Pursuant to 11 U.S.C. 706(a) [Doc. No. 41] (the "First Chapter 11 Conversion Motion").

13. On April 23, 2025, the Court held a hearing in this case (the "April 23 Hearing")⁴⁴ on, inter alia, the Reaffirmation Agreement, Exemptions Objection, the Dismissal Motion. The

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Debtor, the Trustee and the United States Bankruptcy Administrator for the Western District of North Carolina (the "Bankruptcy Administrator," and together with the Debtor and the Trustee, the

"Parties") appeared at the April 23 Hearing. The Court first heard the Reaffirmation Agreement at the April 23 Hearing, which the Court ultimately granted.⁴⁵

14. During consideration of the Exemptions Objection, the Debtor clarified the assertions she made at the January 341 Meeting regarding Holt Solutions, the Properties, and the Properties Conveyances vis-à-vis the Tribe. Specifically, the Debtor asserted that she stilled wholly owned the Properties,⁴⁶notwithstanding the Conveyances, because such conveyances to tribal entities were allowed and was common practice "for asset protection" by tribal individuals.⁴⁷ that something is on shortened notice, occasionally the Court will consider shortened notice," but "[n]ever really 24 hours' notice," and only "[l]ike maybe [to] truncate from the 14 days or the 21 days if there's an emergency, but that's then paired with a motion to shorten notice").

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During consideration of the Dismissal Motion, the Trustee and Bankruptcy Administrator questioned the likelihood of and the Debtor's ability to pay her creditors outside of bankruptcy. The Debtor countered that her enrollment in the Debtor's Tribal Courses would engender the necessary funds to pay the Debtor's creditors.⁴⁸The Court ultimately granted the Exemptions Objection⁴⁹and denied the Dismissal Motion.⁵⁰The Court concluded the April 23 Hearing by recommending that the Debtor obtain counsel for the Debtor's bankruptcy case.⁵¹

15. After the April 23 Hearing and prior to the next hearing, the Debtor made various other filings.⁵²Additionally, on May 1, 2025, the Trustee filed a notice to various creditors of the Debtor who were undisclosed in the Debtor's Petition (the "Debtor's Undisclosed Creditors")⁵³to which objected the Debtor on May 6, 2025.⁵⁴

do,"); id., 21:24-22:2 (the Debtor's statement that the Properties Conveyances "were for asset protection that was consistent with tribal customs and private cultural governance")..

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2. The May Hearing and Further Filings

16. On May 27, 2025, the Court held a hearing (the "May Hearing")⁵⁵on various filings by the Debtor. During the May Hearing, the Bankruptcy Administrator cross-examined the Debtor, wherein the Debtor first acknowledged the Rental Income as well as another undisclosed account of the Debtor's Accounts where the Rental Income was deposited.⁵⁶The Debtor testified she thought that even "if [her] name [was] on the account but it belongs to the Tribe, [she] d[id]not need to list [ ] or disclose it."⁵⁷When asked whether any other undisclosed accounts existed, the Debtor admitted to having another account that was opened after the Petition Date,⁵⁸but falsely stated only these two accounts of the Debtor's Accounts existed.⁵⁹

17. When asked about the Debtor's assertion of expected income from the Debtor's Tribal Courses at the April 23 Hearing, the Debtor testified that she had completed courses through the Tribe on genealogy, cosmology, and other topics.⁶⁰She testified that she began the Debtor's Jurist Course in February 2025, had paid the requisite fee, and was currently enrolled.⁶¹The Debtor could not explain how these courses would engender the income she had asserted they would.⁶² As to the Debtor's Jurist Course, the Debtor described it as covering "nationality, law" and "[t]he

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denationalization of individuals that are looking to reclaim their status"⁶³and denied that anything the Debtor learned from the Debtor's Jurist Course informed the Debtor's Petition.⁶⁴

18. The Debtor also testified that she had made no payments to the Tribe other than for Debtor's Tribal Courses and one donation of $300 the previous year.⁶⁵She further testified that she had been involved with the Tribe since "maybe 2022."⁶⁶Finally, the Debtor testified, not on cross but in her own affirmative submission, that the Tribe was willing to provide additional funds to help her repay her debts outside of a Chapter 7 case.⁶⁷

19. Although the Debtor testified to the facts just canvassed, the Debtor testified that she could not recall answers to many questions, most of which, conveniently, pertained to matters the Debtor appears to have tried to conceal from the bankruptcy proceedings, such as those relating to the Nevin Property, the Rental income,⁶⁸and others matters.⁶⁹This would begin a trend

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throughout the May and subsequent hearing of the Debtor not recalling matters apparently when doing so was convenient for the Debtor.⁷⁰

20. Due to this testimony, the Court orally directed the Debtor to provide the Trustee and Bankruptcy Administrator with certain "information" needed, including any information as to any undisclosed bank accounts (the "May Accounts Directive"), tax returns (the "May Tax Returns Directive"), leases (the "May Leases Directive"), and "any of the course information" (the "May Course Documents Directive," and together with the May Bank Directive, the May Tax Returns Directive, and the May Leases Directive, the "May Oral Directives").⁷¹The Court explained to the Debtor that the Trustee's role in the bankruptcy case obliged her to seek and review such information.⁷²

21. Following the May Hearing and prior the next hearing, the Parties made various further filings. On May 28, 2025, the Trustee initiated the Adversary Proceeding, asserting, inter alia, that the Conveyances were fraudulent and that the Properties should be brought back into the bankruptcy estate for the benefit of the Debtor's creditors.⁷³The next day, the Debtor filed an Answer to Complaint [Adv. Pro. Doc. No. 6], wherefore the Court entered the Court Memo to Individual re: Attorney Representation [Adv. Pro. Doc. No. 7] (the "Court Representation Memo"), informing the Debtor that she could not represent Holt Solutions and would need to obtain counsel to litigate the Adversary Proceeding. The Debtor also made further filings seeking to end her

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Chapter 7 Base Case or effectuate a resolution obtaining the treatment she had sought through the Debtor's Tribal Exemptions.⁷⁴On June 9, 2025, the Debtor filed the Amended Schedule J, Cover Sheet [Doc. No. 78] (the "First Amended Schedule"). The First Amended Schedule again provided as the Debtor's income the Debtor's Asserted Income which omitted the Rental Income.⁷⁵

D. June Facts

1. The June 9 Hearing and Further Filings

22. On June 9, 2025, the Court held a hearing (the "June 9 Hearing")⁷⁶on one of the Debtor's pleadings regarding the Debtor's tribal assertions. The Debtor again argued that the Properties were unrecoverable due to their tribal status from the Conveyances and that such conveyances are standard tribal practice.⁷⁷After rebuttal as to the merits of these arguments by the

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Trustee⁷⁸and the Bankruptcy Administrator,⁷⁹the Bankruptcy Administrator also informed the Court that the Debtor had done nothing to comply with the Court's May Oral Directives and specifically did not comply with the May Accounts Directive and the May Leases Directive when the Bankruptcy Administrator's offered the Debtor an opportunity to do so.⁸⁰After the Debtor replied to the merits of the Trustee's and the Bankruptcy Administrator's rebuttal,⁸¹the Court queried the Debtor as to her compliance with the May Oral Directives, the Debtor acknowledge she had not taken any actions to comply.⁸²Additionally, after discussion of the Trustee's efforts to notify the Debtor's creditors, the Court explained to the Debtor that the Trustee was obligated to send such notice and this was one reason which made the Debtor's compliance with the May Accounts Directive so important in order to progress the Debtor's case.⁸³

23. Later the same day as the June 9 Hearing, the Debtor filed the Motion for Protective Order to Limit Discovery [Doc. No. 81; Adv. Pro. Doc. No. 13] (the "First Protective Motion") in you cite case law, just as you've cited case law, you know that's not exactly your same fact pattern, but it might help guide the Court, and I think Ms. Raubach is just trying to do that, as well."). The Debtor responded that she "underst[ood] and [ ] respect[ed] what [the Court was] saying," but that the nonetheless, just the Trustee making the analogy created bias and was prejudicial. See id., at 12:19-14:8.

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both the Chapter 7 Base Case and the Adversary Proceeding. The Debtor filing the First Protective Motion in the Adversary Proceeding without counsel contravened the Court's Local Rule 2090-1, the Court Representation Memo, and the Court's explicit delineation to the Debtor of the same at the June 9 Hearing,⁸⁴as did another motion the Debtor filed the same day in the Adversary Proceeding.⁸⁵

24. On June 20, 2025, the Debtor also filed the Amended Statement of Income, Schedule J, Cover Sheet [Doc. No. 105] (the "Second Amended Schedules," and together with the First Amended Schedule, the "Amended Schedules"). The Second Amended Schedules repeated the false statement from the Debtor's Petition as to the nonexistence of the Rental Income specifically⁸⁶and as to the Debtor's Asserted Income, it again omitted the Rental Income as part of the Debtor's income.⁸⁷

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2. The June 23 Hearing, the Reference Withdrawal Motion, and Further Filings

25. On June 23, 2025, the Court held a hearing (the "June 23 Hearing")⁸⁸on various prior filings by the Debtor.⁸⁹During consideration of one such filing, the Bankruptcy Administrator informed the Court that the Debtor still had not complied with some of the directives under the May Oral Directives.⁹⁰The Trustee and Bankruptcy Administrator cross-examined the Debtor during the June 23 Hearing, wherein the Debtor again failed to recall details as to key matters, such as her compliance to date with the May Oral Directives,⁹¹the Nevin Property, and the Rental Income.⁹²

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26. The Court concluded the June 23 Hearing with an oral ruling⁹³which was reduced to written form and entered on June 23, 2025, as the Order from Omnibus Hearing on June 23, 2025 [Doc. No. 111; Adv. Proc. Doc. No. 19] (the "June Omnibus Order," together with the May Oral Directives, the "May and June Orders"). The June Omnibus Order, after first denying various filings of the Debtor's hearing at the June 23 Hearing,⁹⁴made five directives to the Debtor, specifically:

• (1) Barring the Debtor from litigating on behalf of Holt Solutions (the "June Holt Solutions Representation Directive");

• (2) Directing the Debtor to provide the Trustee and Bankruptcy Administrator with any of the Debtor's and Holt Solutions' bank account information (the "June Accounts Directive," and together with the May Account Directive, the "May and June Accounts Directives");

• (3) Directing the Debtor to provide the Trustee and Bankruptcy Administrator with any of Holt Solutions' tax returns (the "June Tax Returns Directive," and together with the May Tax Returns Directive, the "May and June Tax Returns Directives");

• (4) Directing the Debtor to provide the Trustee and Bankruptcy Administrator with any lease agreements for either of the Properties (the "June Leases Directive;" together with the May Leases Directive, the "May and June Leases Directives," which, together with the May and June Course Documents Directives, the May and June Tax Returns Directives, and the June Holt Solutions Representation Directive, the "May and June non-Tribal Directives");

• (5) Directing the Debtor to provide the Trustee and Bankruptcy Administrator with any documents for the Debtor's Tribal Courses (the "June Courses Documents Directive;"

together with the May Course Documents Directive, the "May and June Courses Documents Directives," which, together with the May and June non-Tribal Directives, the "May and June Directives").⁹⁵

The June Omnibus Order set a deadline of June 27, 2025, for the Debtor's compliance,⁹⁶directed the Trustee or the Bankruptcy Administrator to file a report on the Debtor's compliance after this

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deadline,⁹⁷and set a status hearing for the Debtor's compliance on July 7, 2025 (the "July 7 Hearing").⁹⁸

27. On June 27, 2025, the Debtor filed the Motion to Withdraw Reference [Doc. No. 121; Dist. Ct. Doc. No. 1] (the "Reference Withdrawal Motion"), which sought to withdraw her case from this Court to the District Court. The same day, the Debtor sent a cease-and-desist letter to the Trustee alleging that the Trustee had committed libel and defamation against the Debtor and the Tribe. See Notice of Receipt of Correspondence from Debtor to Trustee "Official Notice to Cease and Desist" [Doc. No. 124] (the "Cease and Desist Letter").

28. On July 3, 2025, the Trustee and the Bankruptcy Administrator filed the Joint Report (of Bankruptcy Administrator and Trustee) of Status of Debtor's Compliance with Order from Omnibus Hearing on June 23, 2025, and Request for Sanctions [Doc. No. 125; Adv. Proc. Doc. No. 29] (the "First Status Report"). The First Status Report reported that the Debtor had started to comply with the June and May Bank Accounts Directives by providing some account statements, but also reported that this (1) did not include either some or all statements for the accounts requested as well as (2) had revealed more of the Debtor's Accounts of which the Trustee and the Bankruptcy Administrator were previously unaware.⁹⁹The First Status Report also reported that the Debtor had not taken any actions to comply with the May and June Tax Returns Directives and the May and June Courses Documents Directives, and had not fully complied with the May and June Leases Directives.¹⁰⁰Thus, the First Status Report requested that the Court

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"[f]ind the Debtor in civil contempt of the [June] Omnibus Order and permit the Debtor to purge her contempt by paying … $100.00 per day beginning on July 7, 2025, until she fully complies."¹⁰¹

29. On July 7, 2025, the Debtor responded to the First Status Report. See Response to Joint Report of Status of Debtor's Compliance with Omnibus Order and Objection to Request for Sanctions [Doc. No. 127] (the "First Status Report Response"). The First Status Report Response objected to the May and June Course Documents Directives on the grounds that her compliance with the directives would violate copyright¹⁰²and the directives were irrelevant to her bankruptcy case.¹⁰³However, the First Status Report Response stated, the Debtor "intends to comply with the remaining provisions of the [June Omnibus Order] and is actively gathering the requested financial records" and "and will produce them as soon as they are collected."¹⁰⁴

E. July through August Facts

1. The July 7 Hearing

30. The Court next held the July 7 Hearing¹⁰⁵as a status conference on the Debtor's compliance with the May and June Orders. As to the First Status Report Response' assertion that

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the Debtor was trying to comply with the May and June non-Tribal Directives, the Bankruptcy Administrator rebutted on the grounds that the Debtor's explanation did not explain her outstanding noncompliance with all the May and June non-Tribal Directives. The Bankruptcy Administrator asserted that the May and June Leases Directives could be easily and quickly fully complied with by the Debtor's contacting the Nevin Property's property manager.¹⁰⁶As to the First Status Report Response' copyright and relevancy objection to the May and June Courses Documents Directives, the Bankruptcy Administrator rebutted on the grounds that the Debtor was just arguing she did not need to comply because she did not want to comply.¹⁰⁷The Trustee joined the Bankruptcy Administrator's and highlighted that the Debtor had approximately a seven week period since the May Oral Directives to comply at least with the May and June non-Tribal Directives.¹⁰⁸

31. The Debtor was cross examined by the Trustee and the Bankruptcy Administrator as to the account statement production to date, any undisclosed accounts, the Debtor's Petition, and the Tribe; the Debtor could not remember details.¹⁰⁹This testimony revealed more of the Debtor's Accounts.¹¹⁰After the cross-examination, the Trustee reminded the Debtor that she could

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easily download the overdue account statements online..¹¹¹The Bankruptcy Administrator noted that the fact that May and June Account Directives directed the Debtor to provide statements for all accounts she owned, not only those requested which the Debtor produced, challenged the Debtor's assertion she was attempting to comply with the May and June non-Tribal Directives.¹¹²

32. The Court concluded the July 7 Hearing with an oral ruling¹¹³which was reduced to written form and entered on June 23, 2025, as the Contempt Finding Order. The Contempt Finding Order found the Debtor in civil contempt for her noncompliance with the May and the June Orders,¹¹⁴but provided that the Debtor could purge this finding by complying with the May and June Orders by, specifically, providing the Trustee and Bankruptcy Administrator with:

• (1) all statements for any and all of the Debtor's or Holt Solutions' accounts generally, and specifically, but not limited to, certain statements for certain identified accounts (the "July 7 Accounts Directives," and together with the May and June Bank Account Directives, the "May, June, and July 7 Account Directives"),

• (2) the lease agreements for either of the Properties (the "July 7 Leases Directives,"

together with the May and June Leases Directives, the "May, June, and July 7 Leases Directives"), and

• (3) the documents for the Debtor's Tribal Courses (the "July 7 Courses Documents Directives;" together with the May and June Courses Documents Directives, the "May, June, and July 7 Courses Documents Directives," which, together with the May, June, and July 7 Account Directives, the May, June, and July 7 Leases Directives, the "May, June, and July 7 Orders").¹¹⁵

The Contempt Finding Order set a deadline of July 17, 2025, for the Debtor's compliance¹¹⁶and scheduled a status hearing on July 21, 2025 (the "July 21 Hearing") for determination of compliance and imposing sanctions if the Debtor failed to comply.¹¹⁷

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33. On July 10, 2025, the Debtor filed the Motion for Recusal of Trustee and Bankruptcy Administrator [Doc. No. 132] (the "Original Recusal Motion"). The Original Recusal Motion made various false allegations of fact.¹¹⁸On July 11, 2025, the Trustee and the Bankruptcy Administrator filed responses to Reference Withdrawal Motion at the District Court and¹¹⁹the Debtor replied on July 17, 2025. See Reply to Opposition [Dist. Ct. Doc. No. 17] (the "Original Reference Withdrawal Motion Response Reply"). The Original Reference Withdrawal Motion Response Reply contained various patent errors, such as alleging that the Trustee had sent the Debtor threatening voicemails (the "Voicemails Allegations")¹²⁰and utilizing masculine pronouns interspersed with feminine pronouns, which the Debtor uses in general (the "Motion Pronoun Discordance"), suggesting that the pleading had been duplicated from one with a male-identifying individual.¹²¹

34. On July 21, 2025, prior to the July 21 Hearing, the Bankruptcy Administrator and the Trustee filed a Joint Report of Status of Debtor's Compliance with Order Finding Debtor in Civil Contempt [Doc. No. 136] (the "Second Status Report"). The Second Status Report canvased

(1) that the Bankruptcy Administrator and the Trustee had found some of the Debtor's Held Funds,¹²²(2) that the Debtor had taken some actions to comply with the May, June, and July 7

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Account Directives by providing some requested statements, but not all requested statements, (3) that her production revealed more of the Debtor's Accounts, displaying further noncompliance of the general part of the May, June, and July 7 Account Directives, and (4) that the Debtor had taken no action to comply with the May, June, and July 7 Courses Documents Directives.¹²³The Second Status Report did not raise any compliance issues as to the May, June, and July 7 Leases Directives, wherefore it appears that the Debtor had fully complied with that directive prior to July 21, 2025.

2. The July 21 Hearing

35. During the July 21 Hearing,¹²⁴the Bankruptcy Administrator raised to the Court the Voicemails Allegations.¹²⁵When the Court inquired what was the basis for the allegations, the Debtor stated she could not recall writing it.¹²⁶The Court then directed the Debtor that she would need to file an amended version of the Original Reference Withdrawal Motion Response Reply.¹²⁷ Next, the Trustee addressed the Second Status Report,¹²⁸and the Bankruptcy Administrator highlighted the volume of undisclosed Debtor's Accounts.¹²⁹

36. When the Court queried the Debtor as to the various outstanding compliance issues, the Debtor repeated that she was trying her best to comply with the May, June, and July 7 Bank Account Directives¹³⁰but could not recall key details when pressed by the Court on the accounts.¹³¹

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As to the May, June, and July 7 Courses Documents Directives, the Debtor asserted she could not comply as it would violate copyright and claimed she was "under duress" to commit a crime.¹³²

37. When the Court asked the Debtor to provide any argument regarding the mitigation of sanctions, the Debtor admitted "mistakes" in her attempts to comply with the May, June, and July 7 Bank Account Directives but repeated that she could not comply with the May, June, and July 7 Courses Documents Directives because it would be illegal, citing 11 U.S.C. § 541, 15 U.S.C. § 114, 17 U.S.C. §§ 504 and 505, 18 U.S.C. § 241, and the Indian Arts and Crafts Act.¹³³The Court then engaged in the following exchange with the Debtor:

Debtor: Through the order, Your Honor, I am being pressured and coerced into turning over this stuff that does not belong to me. Again, it belongs to the tribe and not myself… And if I am being threatened with sanctions and punishment for something that isn't mine, then obviously this causes me duress, and I am being forced to make decisions under pressure, fear, and intimidation. So, I'm really caught in the middle of something that. Umm. Court: Ms. Ford. Has . . . the tribe said this to you? Because we have told you that this law you are citing is completely inapplicable. So, can you please provide a name of who you are speaking to at the tribe that is asserting any of those arguments?

Debtor: Your Honor, I cannot say any of that, but what I can say is that this would be a-a- against the law for me to do so.

Court: Who have you spoken to the tribe, in, during this process?

Debtor: That, I will not disclose.

Court: Has the tribe threatened you with a lawsuit?

Debtor: Your Honor, that I will not disclose.

Court: And you understood my prior ruling, is that correct?

Debtor: Which order?

Court: You understood why copyright -- why your arguments do not apply?

Debtor: No. I think they do apply.¹³⁴

(3) whether she had provided statements for another account starting from June, or (4) whether she had provided or even remembered any related documents for another transfer, among others).

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38. After taking the matter under advisement,¹³⁵the Court entered the Contempt Sanctions Order six days later. The Contempt Sanctions Order, after addressing the case facts¹³⁶ and law allowing the Court to sanction a party found in civil contempt,¹³⁷found:

• (1) that "the Debtor [had] either refused or otherwise failed to produce" what she was directed to produce under the May, June, and July 7 Orders;

• (2) that "the Debtor's assertions that she will be subject to legal action" for compliance with the May, June, and July 7 Courses Documents Directives were "not [ ] credible"

because no evidence as to such had been provided;

• (3) that the May, June, and July 7 Courses Documents Directives sought documents important for "the Court to regulate the practice of law and potential abuses in practice against this Debtor by third parties" given the "he length and complexity of the Debtor's pleadings," "the false factual information contained in some pleadings[,] and the inapplicable or non-existent legal authorities cited therein," which "raise questions concerning the source of this material;"

• (4) that the at least $7,000 in funds the Debtor had not disclosed in her Petition questioned the Debtor's assertions of good faith as it may constitute perjury; and

• (5) that Debtor's actions had "impeded the enforcement of the Court Orders, delayed the progress of this case, and has disrupted the Parties' ability to fulfill their fiduciary duties;"¹³⁸

Thus, the Contempt Sanctions Order found the Debtor again in contempt of the May Order, the June Omnibus Order, and the Contempt Finding Order, having not complied with their directives and acted in bad faith,¹³⁹and imposed civil contempt fine of $100 to accrue daily beginning on the day the Contempt Sanctions Order is entered (the "Contempt Fines").¹⁴⁰The Contempt Sanctions Order also (1) directed the Debtor to provide statements for specific identified accounts (the "July

21 Accounts Directives," together with the May, June, and July 7 Account Directives, the "May through July 21 Account Directives"),¹⁴¹(2) provided that the Debtor could purge the contempt findings and the Contempt Fines by complying with the May Order, the June Omnibus Order, the

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Contempt Finding Order, and Contempt Sanctions Order,¹⁴²and (3) directed the Debtor to serve by mail a copy of the Contempt Sanctions Order to "any parties that the Debtor is aware may contest the relief provided under this order, including the Debtor's asserted tribe," prior to July 31, 2025, and file a certificate of service of the same prior to August 4, 2025 (the "July 21 Mailing Order to Tribal Entities Directive," which, together with the May, June, and July 7 Courses Documents Directives, the "May through July 21 Tribal Directives").¹⁴³

3. Further July and August Filings

39. On July 29, 2025, the Bankruptcy Administrator filed a motion for production to one Tribal Entity,¹⁴⁴which the Court granted.¹⁴⁵On July 31, 2025, the Bankruptcy Administrator filed notices of intent to subpoena further Tribal Entities at various addresses.¹⁴⁶These attempts by the Bankruptcy Administrator to contact Tribal Entities appears to have been futile.

40. On August 4, 2025, the Debtor filed Motion for Continuance to Obtain Counsel and Request for Clarification on Representation Options [Doc. No. 173] and the Statement of Full Compliance with Court Orders and Request to Purge Contempt [Doc. No. 174] (the "Debtor's First Statement of Full Compliance").

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41. On August 13, 2025, the Trustee and the Bankruptcy Administrator filed the Joint Response and Request for Hearing Status Report and Response and Objection (of Bankruptcy Administrator and Trustee) to Debtor's Statement of Full Compliance with Court Orders and Request to Purge Contempt [Doc. No. 177; Adv. Proc. Doc. No. 46] (the "Third Status Report"). The Third Status Report asserted that the Debtor had done nothing to comply with the May through July 21 Tribal Directives and still had not fully complied with the May through July 21 Account Directives because there were still missing statements and the statements produced revealed more of the Debtor's Accounts.¹⁴⁷

42. On August 20, 2025, the Debtor filed the Reply Opposing Default Judgment in Adversary Proceeding and Statement of Full Compliance with Court Order [Doc. No. 179] (the

"Debtor's Second Statement of Full Compliance"). On August 29, 2025, the Debtor filed the Debtor's Statement of Full Compliance with Updated Status Report [Doc. No. 209] (the "Debtor's Third Statement of Full Compliance"). The Debtor's Second and Third Statements of Full Compliance asserted that the Debtor did not need comply with the May through July 21 Tribal Directives because the Debtor believed those directives as irrelevant or infringing copyright.¹⁴⁸On

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August 29, 2025, the Debtor also filed the Amendment [sic] Motion for Recusal of Trustee and Bankruptcy Administrator [Doc. No. 207] (the "Amended Recusal Motion"), in which she removed the false allegations in the Original Recusal Motion.

43. On September 4, 2025, the Trustee and the Bankruptcy Administrator filed the Joint Status Report and Response and Objection to Debtor's Statements of Full Compliance with Court Orders and Requests to Purge Contempt [Doc. No. 211; Adv. Proc. Doc. No. 48] (the

"Fourth Status Report"). The Fourth Status Report asserted that the Debtor had still done nothing to comply with the May through July 21 Tribal Directives and had not fully complied with the May through July 21 Account Directives, although the Debtor had narrowed her specific production requirements under the May through July 21 Account Directives.

F. September Facts

1. The September Hearing and Further Filings

44. On September 8, 2025, the Court held a hearing (the "September Hearing").¹⁴⁹By the September Hearing, the Contempt Fines totaled $4,200 based upon the Debtor's continued noncompliance with the Contempt Sanctions Order. At the September Hearing, the Debtor appeared with counsel for the Adversary Proceeding and thus had fully complied with the Obtaining Representation Directive in the Adversary Proceeding.¹⁵⁰For the status hearing as to

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the ongoing contempt, the Debtor first addressed May through July 21 Account Directives, which she asserted she was trying to comply but complained that the goalposts seemed to be moving and precluded the Debtor's full compliance.¹⁵¹When the Court directly queried the Debtor as various details about her compliance with the May through July 21 Bank Account Directives, the Debtor could not recall exact details or only offered tentative answers.¹⁵²

45. The Trustee asserted that there were still many outstanding requested account statements.¹⁵³The Bankruptcy Administrator rebutted that the moving goalposts was because of the Debtor's own actions, specifically, her noncompliance with the May through July 21 Accounts Directives as it pertained to the Debtor's Accounts generally, and her limited compliance as to only the specifically requested accounts.¹⁵⁴

46. As to the May, June, and July 7 Courses Documents Directives, the Debtor repeated that she could not comply with those directives legally.¹⁵⁵When the Court then directly queried the Debtor about discrete details about the Debtor's Tribal Courses and the Debtor's Jurist Course, the Debtor testified that she could not recall any such details, although she did not deny the through July 21 Account Directives and the May through July 21 Tribal Directives were still outstanding. It is indisputable that the Debtor's compliance with May through July 21 Account Directives was necessary for the Adversary Proceeding to progress, and probably the case that her compliance with the May through July 21 Tribal Directives was also relevant, as those matters bore highly on the Conveyances as the central issue of the Adversary Proceeding. See id. (the Trustee's statement canvassing the same).

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existence of such courses and her enrollment therein.¹⁵⁶When the Bankruptcy Administrator cross- examined the Debtor as to similar details, the result was similarly fruitless,¹⁵⁷except that the Debtor first objected to one question as violating copyright and irrelevant before being unable to recall the answer after her objection was overruled,¹⁵⁸and pled the Fifth Amendment on another question.¹⁵⁹

47. During closing, the Debtor again argued she could not comply with the Course Documents Order because they were irrelevant to bankruptcy matters and compliance would violate copyright, but that she was complying with the Directives concerning matters she deemed relevant to the bankruptcy case.¹⁶⁰The Trustee concluded by noting that sanctions did not seem to

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be working to get the Debtor to comply and would defer to the Court as to further escalation.¹⁶¹ The Bankruptcy Administrator concluded by requesting the Course increase the Contempt Fines and deny the Debtor's discharge.¹⁶²Finally, the Debtor repeated her goal to pay off her creditors and argued that the May through July 21 Tribal Directives were precluding any such progress or resolution of the case by distracting the matters.¹⁶³

48. The Court made an oral ruling as to the matters for the status hearing matters¹⁶⁴and entered in written form on October 7, 2025, as the Contempt Further Sanctions and Discharge Order. The Contempt Further Sanctions and Discharge Order found that the Debtor continued to be in civil contempt (the "September Contempt Finding") based on her noncompliance with the June Omnibus Order and the Contempt Sanctions Order.¹⁶⁵Next, the Contempt Further Sanctions and Discharge Order directed the Debtor, as a condition for her to purge September Contempt Finding, to take various action, specifically:

• (1) to provide to the Trustee and the Bankruptcy Administrator the documents for the Debtor's Tribal Courses (the "September Courses Documents Directives," together with the May, June, and July 7 Courses Documents Directives, the "May through September Courses Documents Directives");¹⁶⁶

• (2) to "[s]erve by mail the Contempt Sanctions Order to "any parties that the Debtor is aware may contest the relief provided under the [that order], including the Debtor's asserted tribe," and file a Certificate of Service of the same (the "September Mailing Order to Tribal Entities Directive," together with the July 21 Mailing Order to Tribal Entities Directive, the "July and September Mailing Order to Tribal Entities Directive,"

which, together with the May through September Courses Documents Directives, the

"May through September Tribal Directives");¹⁶⁷and documents, again, like I've stated before, um, they're not part of my bankruptcy, um, state, um, what the court is asking me to do is to break the law, and again, for, for trademark, and, um, copyright infringement, um, is definitely an overreach. Um, we're requesting those things that I, again, that I don't own, and I can't produce something that I don't own.").

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• (3) to provide specific statements for various specific accounts including those for CashApp (the "September Accounts Directives," together with the May through July

21 Account Directives, the "May through September Account Directives").¹⁶⁸ Lastly, the Contempt Further Sanctions and Discharge Order held that because of the September Contempt Finding, (1) the Court raised the Contempt Fines' daily accruing amount to $150 beginning on entry of the Contempt Further Sanctions and Discharge Order, and (2) the Court denied the Debtor's discharge, which the Court would not reconsider until the Debtor complied with the June Omnibus Order and the Contempt Sanctions Order.¹⁶⁹

49. After the Court made the oral ruling at the September Hearing, the Court heard the Recusal Motion. The Debtor proffered opening arguments reasserting prior failed arguments¹⁷⁰ and the Trustee rebutted.¹⁷¹The Bankruptcy Administrator's cross-examined the Debtor and presented evidence, which the Debtor confirmed, that the Debtor removed the false allegations from the Original Recusal Motion in the Amended Recusal Motion.¹⁷²Specifically, the Bankruptcy Administrator addressed how the changes had not been based on the Debtor's own volition but were prompted by a letter that the Bankruptcy Administrator sent to the Debtor which threatened a motion for sanctions pursuant to Federal Rule of Bankruptcy Procedure 9011(c)(1) unless,

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pursuant to the "safe harbor" provision under Federal Rule of Bankruptcy Procedure 9011(c)(2)(B), the Debtor made the changes.¹⁷³

50. The Bankruptcy Administrator asked the Debtor whether she had ever been sanctioned by a court outside of the case before this Court, which the Debtor initially responded by testifying that she could not recall.¹⁷⁴Then, the Bankruptcy Administrator presented to the Court an order from the Mecklenburg County district court entered on December 4, 2023 which ordered the Debtor to pay her ex-husband $8,000 in sanctions under N.C. Gen. Stat. § 1A-1, Rule 11 (the "State Court Sanctions Order").¹⁷⁵The State Court Sanctions Order, the Debtor confirmed, was ordered based on findings that the Debtor had, in a custody dispute between the Debtor and her ex-husband, (1) "verified a pleading which contained facts and statements of law that were insufficient to satisfy the grievances [that the Debtor] alleged," (2) "that [the Debtor's] allegations as they relate to [the Debtor's ex-husband] were not credible and were therefore, factually insufficient," and (3) were "filed for an improper purpose."¹⁷⁶

51. During closing, the Debtor argued that the State Court Sanctions Order did not impugn her credibility and she repeated her opening arguments.¹⁷⁷The Bankruptcy Administrator concluded by noting that (1) she was executing her duties including investigating the potential unauthorized practice of law, and that (2) the Recusal Motion was really just a collateral attack on

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the Court's orders.¹⁷⁸At the conclusion of the September Hearing, the Court took the Recusal Motion under advisement, which it denied on September 29, 2025.¹⁷⁹

2. Further Filings

52. On October 6, 2025, the Debtor filed the First Contempt Review Motion, which reaffirmed that she had taken the Debtor's Jurist Course.¹⁸⁰On October 10, 2025, the Trustee and the Bankruptcy Administrator filed the Fifth Joint Status Report and Response and Objection to Debtor's Response and Declaration to Order Denying Debtor's Request to Purge Contempt, Further Sanctioning Debtor, and Denying Debtor's Discharge [Doc. No. 227] (the "Fifth Status Report"). The Fifth Status Report asserted that (1) the Debtor still had done nothing to comply with the May through September Tribal Directives and had not fully complied with the May through September Account Directives because some statements were still outstanding, (2) the provided statements had revealed more of the Debtor's Accounts, and (3) the Debtor's production of the CashApp Statements (the "First CashApp Statement Production") were incomplete as it was a summary missing specifics as to the transfers.¹⁸¹

53. On October 17, 2025, the Debtor filed the Supplemental Response Providing Additional Information to Fifth Joint Status Report [Doc. No. 229] (the "Fifth Status Report Response"). The Fifth Status Report Response asserted that the Debtor was trying to comply with the May through September Account Directives and that, as it pertained to the CashApp

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statements, the Debtor had provided a full unredacted version of the Debtor's CashApp accounts on October 17, 2025 (the "Second CashApp Statement Production").¹⁸²However, the Debtor stated in Fifth Status Report Response that she would not comply with the May through September Tribal Directives.¹⁸³

G. October Facts

1. The October Hearing and the Trustee's Letter and the Debtor's Protective Motion

54. At a hearing on October 20, 2025 (the "October Hearing"),¹⁸⁴the Contempt Fines totaled $9,100. After disposing of procedural matters,¹⁸⁵the Court turned to the status hearing on the contempt matters. For opening arguments, as to the May through September Account Directives, the Debtor asserted that she had finally fully complied by providing all requested available statements in existence.¹⁸⁶As to the May through September Tribal Directives, the

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Debtor asserted that she could not comply by repeating her argument that the requested materials were copyrighted¹⁸⁷and irrelevant to her bankruptcy case because she never presented herself as a lawyer and they did not contribute to paying her creditors.¹⁸⁸

55. The Trustee asserted that the Debtor had satisfied many of the account statement requests in the May through September Account Directives by providing the Second CashApp Statement Production, but that there were still a few potentially necessary outstanding statements.¹⁸⁹Next, the Bankruptcy Administrator cross-examined the Debtor with a presentation of printouts of statements from the Debtor's accounts, which the Debtor confirmed to be accurate and which contained transfers totaling almost $4,000 to various Tribal Entities.¹⁹⁰The Bankruptcy Administrator also presented printouts of various pages from the Tribal Entities' websites.¹⁹¹

56. When the Bankruptcy Administrator asked the Debtor about one payment made to a Tribal Entity, the Debtor could remember virtually no details about the transfer or the Tribal

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Entity.¹⁹²When the Bankruptcy Administrator asked the Debtor about details about the Debtor's Jurist Course, the Debtor could not recall most details.¹⁹³When the Bankruptcy Administrator asked the Debtor about (1) her familiarity with certain Tribal Entities' online materials or individuals, (2) the source of certain arguments made by the Debtor to the North Carolina state court and to the Court during these proceedings, (3) the origin of certain practices carried out by the Debtor in her pleadings, and (4) the Tribe's and the Tribal Course's relation to Holt Consulting and Holt Solutions, the Debtor could not recall virtually any details¹⁹⁴or pled the Fifth Amendment.¹⁹⁵When the Bankruptcy Administrator further pressed the Debtor regarding the Tribal Course Documents and their format, the Debtor again testified that she could not provide

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them due to her nonpossession of the Tribal Course Documents.¹⁹⁶The result was similarly futile when the Court stated one way the Debtor could display good faith to comply with the Tribal Directives was to try obtain login credentials for the Debtor's Tribal Courses.¹⁹⁷The Debtor's

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inability to recall continued when the Debtor was asked questions about the Tribal Payments and the Tribal Entities.¹⁹⁸The Debtor continued pleading the Fifth Amendment.¹⁹⁹The Trustee cross- examined the Debtor about the fact that a preliminary comparison of the First and Second CashApp Statement Productions display that the statements "do not entirely match," and how the Debtor Debtor: I don't even remember.).

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made at least one edit to the two statements adding a confidentiality statement, to which the Debtor could not explain.²⁰⁰

57. In closing arguments, the Bankruptcy Administrator argued at to the Accounts Directives, although the Debtor had finally submitted all requested account statements, since some statements were redacted, the Debtor had not sufficiently complied with that directive.²⁰¹The Bankruptcy Administrator requested the Court sanction the Debtor pursuant to Federal Rule of Bankruptcy Procedure 9011 for continuing to assert she had complied with the prior Contempt Orders while openly acknowledging she had not complied with certain directives.²⁰²Next, the Bankruptcy Administrator argued that the Contempt Fines appeared to not be working to obtain compliance as to the May through September Tribal Directives and recommended the Court consider incarceration of the Debtor especially given the Debtor's unpersuasive and non- remembering testimony which was inconsistent with the Debtor's prior submissions to the Court.²⁰³Finally, the Bankruptcy Administrator requested the Court deny the Debtor any discharge with prejudice.²⁰⁴The Trustee joined the Bankruptcy Administrator's arguments and added that

"it's abundantly clear that compliance has not occurred" and that "that the sanctions today have not had the impact that the parties would have otherwise hoped they would have."²⁰⁵The Debtor then closed, first asserting she had done all she could to comply with the May through September Account Directives,²⁰⁶then that she could not comply with the May through September Tribal

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Directives because she did not possess the Tribal Course Documents or have the authority to provide them.²⁰⁷

58. Finally, the Court directed the Debtor to provide unredacted versions of all account statements.²⁰⁸The Court repeated that the Debtor had to comply with the September Mailing Order Directive and clarified that serving specifically HAWAB DFW, Shabazz Associates, the Tribe, Aboriginal Medical Associates (the "October Mailing Order Directive," together with the July and September Mailing Order to Tribal Entities Directive, the "July through October Mailing Order to Tribal Entities Directive").²⁰⁹As to the Course Documents Directives, the Court suggested that the Debtor show good faith attempts to comply by providing to the Trustee and the Bankruptcy Administrator the Debtor's login credentials for all Tribal Course related websites, or if the Debtor did not remember the login credentials, by resetting the login credentials and providing reset login credentials to the Trustee and the Bankruptcy Administrator (the "October Login Credentials Directive").²¹⁰The Court then indicated to the Parties that the Court no longer thought the Debtor's civil contempt sanctions were coercive and that the Court would consider next pursuing other penalties.²¹¹Finally, the Court urged the Debtor to speak to a lawyer regarding the impending possibility of criminal sanctions against the Debtor.²¹²Given the Debtor's submissions to the Court, the Court wanted to provide the Debtor an opportunity to show some good faith attempt at

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compliance,²¹³and the Court continued all outstanding matters for hearing November 3, 2025 (the

"November 3 Hearing").²¹⁴

2. The Debtor's Further Filings, the Protective Motion, the Denial of Reference Withdrawal, and the Denying Shortened Notice Order

59. On October 27, 2025, the Debtor filed the Second Contempt Review Motion and the Motion to Limit Trustee's Examination Under Rule 2004 and for Protective Order Regarding Post-Petition Personal Expenditures [Doc. No. 243] (the "Protective Motion"). The fact section of the Protective Motion acknowledged payments by the Debtor to the Tribe for coursework for the Debtor's Courses (the "Protected Motion's Payments"),²¹⁵and stated that "Trustee ha[d] indicated an intent to question or investigate these transactions to determine whether the Debtor

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'received value for services'."²¹⁶Also on October 27, 2025, the District Court denied the Debtor's Reference Withdrawal Motion.²¹⁷

60. On October 30, 2025, the Debtor filed the Third and the Fourth Contempt Review Motions which she requested be set for hearing at the November 3 Hearing.²¹⁸Because a three- day period contravened this Court's Local Rule 9013 requirement for at least fourteen days for nonmovants to review a motion before the motion is heard, the Debtor moved for the Court to allow a shortened period because "cause" existed for allowing such under Federal Rule of Bankruptcy Procedure 9006(c).²¹⁹This cause rested on (1) the constitutional and factual arguments against the Contempt Order made in the Third and the Fourth Contempt Review Motions, (2) the ongoing Fines, and (3) the possibility of imprisonment.²²⁰The next day, on October 31, 2025, the Trustee objected to shortened notice on the basis that one business day would not afford time necessary for her to review the new arguments made in the Third and the Fourth Contempt Review Motions.²²¹The Court denied shortened notice.²²²

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61. Also on October 31, 2025, the Trustee filed the Sixth Status Report on Debtor's Compliance with Orders [Doc. No. 259] (the "Sixth Status Report"). The Sixth Status Report stated that the Trustee had confirmed the discrepancies between Second CashApp Account Production and the First CashApp Account Production, namely, that transfers had been missing from the first production, many of which, "[d]isturbingly, … involve parties the Debtor has previously attempted to shield from disclosure in this case," i.e., Tribal Entities.²²³

H. November Facts

1. The November 3 Hearing, The Trustee's Letter, and the Final Contempt Order

62. At the November 3 Hearing,²²⁴the Court considered the Protective Motion²²⁵and held a status hearing on the contempt matters. By then, the Contempt Fines totaled $11,200. On the Protective Motion, the Debtor argued that the Trustee could not investigate the Protected Motion's Payments as they involved information that was "protected" and irrelevant to bankruptcy.²²⁶

63. In rebuttal, the Trustee reminded the Court that at the October Hearing, the Debtor had insisted that she did not know the Aboriginal Medical Association and Dr. Ali.²²⁷The Trustee demonstrated through independent research, she had concluded that the Dr. Ali operated under the

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Aboriginal Medical Association's name and was the direct recipient of more than $2,000 of the Tribal Payments.²²⁸Based on this conclusion, on October 23, 2025, the Trustee sent a letter to both Aboriginal Medical Association and Dr. Ali related to those transfers made to Aboriginal Medical Association within the preference period and inquiring whether the Debtor had received value for the payments (the "Trustee's Letter").²²⁹A trustee sending such a inquiries, i.e., to a transferee of a debtor inquiring about the transfer's value exchange, is part and parcel of their duties under 11 U.S. Code §§ 547-548.

64. The Trustee also noted she did not send a copy of the letter to the Debtor, which is also standard practice for such inquiries. Still, four days later, the Debtor filed her Protective Motion using the exact "value" language present in the Trustee's Letter.²³⁰When the Court asked the Debtor about the timing and language tying the Protective Motion and the Trustee's Letter, the Debtor insisted she had not been aware of the letter and that the motion was filed in response to the previous facts of the case.²³¹The Court denied the Protective Motion.²³²

65. As to the May through September Account Directives, the Trustee discussed the discrepancies between the First and the Second CashApp Account Productions and the possibility of spoilation by the Debtor.²³³Notwithstanding that issue, the Trustee stated that the Debtor now appeared to have fully complied with the May through September Account Directives, as she had finally sent to the Trustee and Bankruptcy Administrator all requested statements for all accounts

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identified as belonging to the Debtor on the Petition Date, which totaled twenty-five.²³⁴As to the May through September Courses Documents Directives, the Trustee noted how the Debtor had taken no actions to comply.²³⁵The Bankruptcy Administrator concurred with the Trustee's statements as to the Debtor's compliance with the May through September Account Directives and the possible spoilation, for which she quoted 18 U.S. Code § 1519 which criminalizes such conduct.²³⁶The Bankruptcy Administrator added that the Debtor had not fully complied with the July through October Mailing Order to Tribal Entities Directive because the Debtor's certificate of service (the "Certificate of Service") was only to one Tribal Entity, ARNA, and had used a different address than the one the Trustee and Bankruptcy Administrator had found connected to ARNA.²³⁷The Bankruptcy Administrator also noted that the Debtor had done nothing to comply with the October Login Credentials Directive.²³⁸The Bankruptcy Administrator concluded by again recommending that the Court consider referring the Debtor for criminal contempt.²³⁹

66. The Debtor first insisted she had not manipulated any of the CashApp statements and just provided the statement CashApp had sent to her and which she assumed was correct.²⁴⁰ She asserted that the Certificate of Service constituted compliance with July through October Mailing Order to Tribal Entities Directive.²⁴¹Finally, the Debtor argued that she had made a good faith effort to comply with the October Login Credentials Directive, by presenting a printout that purportedly showed:

• (1) an email sent by the Debtor's email on October 26, 2025, to HAWAB Region 6, at hawabregion6@gmail.com, stating that the Debtor was "in a bankruptcy court

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proceeding and the court has requested that [she] provide the tribal jurist course login,"

and asking if they "[c]ould provide [her] the login to give to them;"

• (2) a response to the email above received by the Debtor's email on October 29, 2025, stating that "[a]ccording [t]o our records[,] [the Debtor] never received or registered for our organization's classes or tribal course login" and "have no login information for us to provide;" and

• (3) an email identical to and sent on the same day as the email above to an entity at amaruxiali@gmail.com (collectively, the "Debtor's Emails").²⁴² When the Court asked about the Debtor's Emails and whether the HAWAB Region 6 was the entity from whom the Debtor took the Debtor's Tribal Courses, the Debtor replied she could not recall but would infer HAWAB Region 6 was not since they did not have the login credential.²⁴³As to the second of the Debtor's Emails, the Debtor asserted she received no response.²⁴⁴

67. The Bankruptcy Administrator rebutted that the Certificate of Service and Debtor's Emails did not show attempts by the Debtor to contact Shabazz Associates, who she believed provided the Debtor's Tribal Courses, or Aboriginal Medical Association, wherefore she had not complied with the July through October Mailing Order to Tribal Entities Directive or the October Login Credentials Directive.²⁴⁵The Trustee concurred with the Bankruptcy Administrator and noted that the Protective Motion reaffirmed that the Debtor did take the Tribal Courses which further indicated that the Debtor was willfully not complying with the May through September Courses Documents Directives.²⁴⁶The Debtor responded that "it's impossible for [her] to turn over something that [she] do[es]n't have," wherefore, she was "being punished for something that [she] cannot do."²⁴⁷

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68. At the end of the hearing the Court made a final oral order²⁴⁸which the Final Contempt Order rendered in written form.²⁴⁹The Final Contempt Order found that, as of the November 3 Hearing, the Debtor had not fully complied with the Accounts Directives, the Course Documents Directives, and the Mailing Order Directives.²⁵⁰The Final Contempt Order set the Debtor's Outstanding Motions as well as all outstanding contempt related matters for a final hearing on November 17, 2025 (the "November 17 Hearing").²⁵¹The Final Contempt Order directed the Debtor to, by the November 17 Hearing, complete four discrete actions, specifically:

• (1) to forward all emails she had received from CashApp to the Trustee and the Bankruptcy Administrator, whose metadata the Trustee and the Bankruptcy Administrator were to check (the "Forwarding CashApp Emails Directive," which together with the May through September Account Directives, the "non-Tribal Directive");²⁵²

• (2) to mail the Contempt Orders to (a) Shabazz Associates, (b) HAWAB DFW, (c) Xi- Amaru Tribe, also known as ARNA, (d) the Aboriginal Medical Association, and (e) Dr. Ali (the "November Mailing Order Directive," and together with the July through October Mailing Order to Tribal Entities Directive, the "Mailing Contempt Orders Directives");²⁵³

• (3) to email the same five Tribal Entities above, requesting all materials from the Debtor's Courses, and to forward those emails and all responses to the Trustee and the Bankruptcy Administrator (the "Emailing Tribal Entities and Forwarding Directive");²⁵⁴

• (4) to forward to the Trustee and the Bankruptcy Administrator any and all emails in her email account related to the Debtor's Courses (the "Forwarding All Tribal Emails Directive;" which, together with the November Mailing Order Directive and the Emailing Tribal Entities and Forwarding Directive, the "November Tribal Directives,"

which, together with the Forwarding CashApp Emails Directive, the "Final Directives," and which, together with the May through September Tribal Directives, the "Tribal Directives").²⁵⁵

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The Final Contempt Order concluded if by the November 17, 2025, the Debtor had not complied with the Final Directives, it would consider "criminal contempt, perjury, and potentially falsification of documents."²⁵⁶

69. Later the same day of the November 3 Hearing, the Debtor filed the Notice Reconsideration Motion. On November 7, 2025, the Trustee filed the Seventh Status Report, as well as responses to Third and Fourth Contempt Review Motions,²⁵⁷and the Bankruptcy Administrator filed a response to the Fourth Contempt Review Motions.²⁵⁸On November 12, 2025, the Debtor filed replies to the Trustee's responses,²⁵⁹a response to the Seventh Status Report,²⁶⁰and the Fifth and Sixth Contempt Review Motions.²⁶¹On November 14, 2025, the made, membership documentation for which the Debtor has averred she paid dues, any course information (including, but not limited to, the "Jurist" course) ranging from scheduling matters such as calendar invitations and meeting links for classes or office hours, to actual course content such as syllabi, reading lists, study materials (including links to or attachments of PDFs, slide decks, audio/video files, or zipped archives), assignments, quiz or test notifications and grading or feedback").

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Bankruptcy Administrator filed limited replies to one of Debtor's replies to the Trustee's responses and to the Debtor's response to the Seventh Status Report;²⁶²she additionally filed responses to the Fifth and Sixth Contempt Review Motions,²⁶³to which the Trustee joined.²⁶⁴

2. The November 17 Hearing

70. At the November 17 Hearing,²⁶⁵the Court heard the Debtor's Outstanding Motions and held a final status hearing on the Contempt Orders. First, the Debtor presented the Contempt Review Motions.²⁶⁶The Debtor invoked her Fifth Amendment rights at the beginning of the hearing.²⁶⁷The Debtor argued that the Contempt Orders violated her rights under First, Third, Fourth, Fifth, Ninth, and Fourteenth Amendment, as well Fed. R.s Bankr. P. 9018, 9023, and 9024, because the Contempt Orders were "overboard," sought disclosure of "expressive and social materials," constituted an "invasion of confidential and private matters," and were irrelevant to bankruptcy.²⁶⁸

71. The Bankruptcy Administrator, with joinder from the Trustee, rebutted that these arguments (1) were not timely, (2) did not accurately represent the law, and (3) failed to provide allow final hearing on all matters at the November 17 Hearing. See Order Granting Motion to Shorten Notice [Doc No. 297].

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sufficient injury justifying the relief sought of reconsideration and stay pending appeal, to which the Trustee joined.²⁶⁹The Debtor rebutted that her pro se status warranted excepting the timeliness issue and that she had shown constitutional violations and injury warranting the Debtor's requested

.²⁷⁰

72. The Court took the Debtor's Outstanding Motions under advisement and turned to the status hearing.²⁷¹The Trustee presented how the Debtor had done nothing to comply with the November Mailing Contempt Orders Directive, the Email Tribal Entities and Forward Directive, and the Forwarding All Tribal Emails Directive.²⁷²The Trustee asserted that the Debtor had complied with the Forwarding CashApp Emails Directive and that although the First CashApp Account Production's missing transfers were "[i]ncredibly odd," "nothing … looked concerning with the metadata" and it "appears to be legitimate."²⁷³

73. The Debtor responded that she had indeed just sent the CashApp statements as they were sent to her and any discrepancies were CashApp's fault, reinvoked the Fifth Amendment, and repeated her arguments that (1) the contempt proceedings violated the Eighth, Fourteenth and Ninth Amendments and this Court's Article Authority and (2) she had complied with the Contempt Orders because she done fully complied with the non-Tribal Directives and the Tribal Directives violated the First Amendment, were irrelevant to bankruptcy.²⁷⁴The Bankruptcy Administrator mentioned that the Debtor previously asserted being a member of a federally recognized tribe.²⁷⁵

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74. The Debtor challenged that she had ever asserted to belong to a federally recognized Tribe.²⁷⁶The Court then pulled up the Debtor's Response / Debtor's Reply to 277 Trustee's Objection to Motion to Vacate Contempt Order and For Declaratory Relief that the Court Exceeds its Article I Authority [Doc. No. 290] and quoted the Debtor's passage making such assertion.²⁷⁷

75. In support of her Third and Fourth Contempt Review Motions, the Debtor repeated her arguments that the Contempt Orders had violated copyright, involved matters irrelevant to bankruptcy, and sought to punish the Debtor using civil contempt, as grounds for the Court having exceeded its Article I authority, not followed evidentiary rules, and violated due process.²⁷⁸

76. As to her Notice Reconsideration Motion, the Debtor argued that the Denying Shortened Notice Order violated due process because she was facing the threat of incarceration and did not have the staff that the Trustee and the Bankruptcy Administrator have.²⁷⁹

77. The Trustee rebutted that the Notice Reconsideration Motion was not timely.²⁸⁰As to the Contempt Review Motions, the Trustee asserted that they were not timely or warranting the reconsideration relief because the Debtor could not demonstrate the threshold requirement of a meritorious argument. Instead, the Debtor moved based on her prior arguments of copyright and relevancy, which were "well plowed ground in this case."²⁸¹The Court concluded the November

17 Hearing by taking the matters under advisement.²⁸²The Court now renders its opinion.

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II. DISCUSSION

A. Civil Contempt: The Contempt Findings, the Contempt Fines, the Debtor's Impossibility Argument, and the Debtor's Outstanding Motions

1. Legal Background

78. Federal bankruptcy courts have the power (1) to find a party in civil contempt (the

"contemnor") based on a contemnor's (a) noncompliance with an order from the court (the

"underlying order") and (b) knowledge or constructive knowledge of the underlying order and their noncompliance, and well as the power (2) to implement various sanctions, ranging from monetary fines to incarceration, against the contemnor in order to coerce compliance. See Fed. R. Civ. P. 70(e) (empowering federal district courts to "hold [a] disobedient party in contempt") & Fed. R. Bankr. P. 7070 (incorporating Federal Rule of Civil Procedure 70(e) to bankruptcy courts

"in an adversary proceeding"); see also Life Techs. Corp. v. Govindaraj, 931 F.3d 259, 267 (4th Cir. 2019) (noting that federal district courts at least retain "the inherent power to order sanctions to preserve the integrity of the judicial process and to punish bad-faith conduct intended to delay or disrupt the course of litigation or to impede enforcement of a court order" (citation omitted)); Allen v. Pierce (In re Timmer), No. BAP AZ-04-1604-KMOS, 2005 WL 6960235, at *4 (B.A.P. 9th Cir. Sept. 29, 2005) (noting that both federal district courts and bankruptcy courts "have inherent power to regulate practice in cases before them" and "deal with abuses in practice under its inherent power" (citation omitted)); United States v. Ali, 874 F.3d 825, 831 (4th Cir. 2017) ("[Civil contempt requires] (1) the existence of a valid decree of which the alleged contemnor had actual or constructive knowledge; (2) that the decree was in the movant's 'favor'; (3) that the alleged contemnor by its conduct violated the terms of the decree, and had knowledge (at least constructive knowledge) of such violations; and (4) that the movant suffered harm as a result"

(citations omitted).); Beckhart v. Newrez LLC, 31 F.4th 274, 278 (4th Cir. 2022) (civil contempt,

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unlike criminal contempt, generally does not require willfulness to violate an order ((citations omitted))); Sugar v. Burnett, 130 F.4th 358, 377-78 (4th Cir. 2025) (same).

79. However, federal bankruptcy courts' civil contempt power is also limited. Civil contempt sanctions can only be compensatory or coercive, not punitive. See Buffington v. Balt. Cnty., 913 F.2d 113, 133-34 (4th Cir. 1990) (noting that civil contempt, unlike criminal contempt, requires that contemnors' sanctions " 'stand[ ] [ ] unless and until [they] perform[ ] the affirmative act required by the court's order'," (citation omitted)). Punitive sanctions may only arise from criminal contempt, which requires "criminal proceedings, including the right to jury trial." See United Mine Workers of America v. Bagwell, Syllabus, 512 U.S. 821 (1994).

80. A contemnor facing coercive civil contempt sanctions may purge the civil contempt finding and end continued sanctions by the contemnor sufficiently complying with the underlying order. The Fourth Circuit does not necessarily require compliance to be "perfect," and allows

"substantial" compliance to purge. See, e.g., United States v. Darwin Constr. Co., 873 F.2d 750, 754 (4th Cir. 1989); De Simone v. VSL Pharm., Inc., 36 F.4th 518, 530 (4th Cir. 2022) (citing id., at 754 & 755); Consolidation Coal Co. v. United Mineworkers of Am., 683 F.2d 827, 832 (4th Cir. 1982). Still, substantial compliance requires the contemnor to take "all reasonable steps … to ensure compliance" as to each part of an underlying order. See Darwin, 873 F.2d at 755-56. Thus, substantial compliance cannot exist where (1) regardless of what steps the contemnor has taken, any other available steps were not taken, or (2) regardless of what steps are still available, the contemnor appears to only have taken steps as to certain parts of an underlying order. See id.

81. However, civil contempt may end without the contemnor fully or even substantially complying in two ways. The first way is if civil contempt sanctions begin as coercive but become punitive over time. When it becomes sufficiently apparent to a court that the sanctions will not

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coerce the compliance, the court must terminate the civil contempt or convert it to criminal contempt to ensure the appropriate due process procedural requirements for criminal proceedings occur. See Soobzokov v. CBS, Quadrangle/New York Times Book Co., 642 F.2d 28, 31 (2d Cir. 1981) ("When it becomes obvious that sanctions are not going to compel compliance, they lose their remedial characteristics and take on more of the nature of punishment."); Simkin v. United States, 715 F.2d 34 (2d Cir. 1983) ("[A]t some point in what otherwise would be an indefinite period of confinement[,] due process considerations oblige a court to release a contemnor from civil contempt if the contemnor has then shown that there is no substantial likelihood that continued confinement will accomplish its coercive purpose" (citations omitted).).

82. The second way to end civil contempt in the absence of compliance is "where compliance is impossible" (the "impossibility defense"). See United States v. Rylander, 460 U.S. 752, 757 (1983); see also Shillitani v. United States, 384 U.S. 364, (1966). Although the initial burden for civil contempt is on the movant, see Ali, 874 F.3d at 832, once the movant has shown the required elements, the contemnor bears the burden of proving an impossibility defense. See id. (citations omitted). The impossibility defense is also limited in certain ways key to this case, as the Court discusses below.

2. Analysis

a. The Debtor's Outstanding Civil Contempt

i. The Debtor's Asserted Impossibility Defense

83. Throughout these proceedings, the Debtor claimed that she cannot comply with the Tribal Directives because she deems those directives violative of copyright and irrelevant to her bankruptcy case. The Debtor appears to have first argued this (1) in the First Status Report

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Response back in early July.²⁸³The Debtor continued to argued this (2) directly before the Court at the July 21 Hearing,²⁸⁴in August (3)-(5) in the Debtor's First, Second, and Third Statements of Full Compliance,²⁸⁵in September (6) directly before the Court at the September Hearing during the status hearing²⁸⁶and (7) during consideration of the Recusal Motion,²⁸⁷in October (8) in the First Contempt Review Motion,²⁸⁸(9) in the Fifth Status Report Response,²⁸⁹and (10) at the October Hearing,²⁹⁰and in November (11) at the November 17 Hearing.²⁹¹Such arguments, obviously, would not suffice as grounds for the impossibility defense.

84. Starting at the October Hearing, the Debtor raised a purportedly different argument, specifically, that she cannot comply with the Tribal Directives because she (1) does not have access to any Course Documents and (2) has no ability to obtain access to any such Course Documents to provide to the Trustee and the Bankruptcy Administrator (the "Debtor's New Argument").²⁹²If true, the Debtor's New Argument would most likely suffice for an impossibility defense. However, the Court rejects the Debtor's New Argument for five distinct reasons.

85. First, the Debtor's New Argument does not really seem to be 'new'. Rather the Debtor's assertion of her nonpossession or control of the Course Documents was her own conclusion based on her perennial copyright and relevancy arguments.²⁹³While not explicitly a

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function of her asserted copyright argument, the Debtor appears to just be reasserting that legal conclusion in an attempt to make the assertion one of fact alone.

86. Second, and more crucially, absent changed circumstances, a contemnor may not raise for the first time at the contempt proceeding stage arguments as to why they cannot comply with the underlying order. See Rylander, 460 U.S. at 757 (holding that a contemnor "may not [ ] raise[ ] for the first time in a contempt proceeding" for noncompliance with a production order

"that [they] lacked possession or control of the records at the time the order was issued, [but] could defend the contempt charge on the ground that [they] w[ere] then unable to comply because [they] lacked possession or control" (citations omitted)); see also Ali, 874 F.3d at 830 (holding that because the contemnor "did not raise her nonpossession defense at the enforcement stage" as to a request for production of documents, she "was therefore precluded from raising that defense at the contempt stage" as to the request). This is exactly what the Debtor attempted to do with the Debtor's New Argument. If some factual impossibility did exist, the Debtor was required to argue this during the Court's consideration of these contempt matters for the May or June Orders, or, at the least, prior to the Contempt Finding and Contempt Sanctions Orders, not for the first time in October.

87. Third, the Debtor's New Argument is no more than a bare assertion of impossibility, which cannot suffice under the law for impossibility defenses. Generally, impossibility based solely on the contemnor's assertion does not suffice, see Ali, 874 F.3d at 833 ("A bare assertion of nonpossession cannot satisfy this burden."), nor can asserting impossibility generally or ability to access, retrieve, or recreate them," having "no legal authority to" do so without copying copyright and exposing herself to liability, and (2) the Debtor's noncompliance with the Course Website Login Directive on the grounds that the "login credentials requested were controlled by a third-party platform,"

the Debtor "d[id] not have the passwords or administrative access," she "ha[d] attempted in good faith to recover or reset the passwords but was unsuccessful, and "[t]he platform's access is now outside my control").

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conclusorily. See South Carolina v. United States, 907 F.3d 742, 764 (4th Cir. 2018). A successful impossibility defense generally requires that the contemnor proffers specific and detailed facts underpinning their assertion of impossibility, see id., and can require the contemnor to proffer affirmative acts they took to achieve compliance not just as to some parts of order, but " 'all reasonable efforts to comply' " with the entire order. See Ali, 874 F.3d at 833. The Debtor proffers no details underpinning this new argument or explanations as to why she raises such argument so late in these contempt proceedings. The Debtor proffers nothing such as, for example, the following: (1) specific recorded attempts to obtain the Course Documents given they are linked to a class for which she paid and thus arguably is entitled to an extent, (2) clarifications how her new ground can be true and still comport with her previous submissions of facts that indicate at least in a vacuum that she possesses Course Documents,²⁹⁴or (3) explanations for why her previous defense of her noncompliance fixated on alleged issues as to the Course Documents Directives themselves warranting noncompliance if, according to the new ground, noncompliance would be inescapable even absent those issues.

88. Fourth, an asserted impossibility defense cannot suffice when rebutted by the prior conduct of the contemnor, as is the case here. Generally, the contemnor's proffer of factual impossibility must "convince the court that compliance . . . [is] actually impossible (rather than merely difficult, inconvenient, or potentially impossible)." See South Carolina, 907 F.3d at 765. Similarly, courts may reject such a proffer even if it would otherwise suffice when it is discredited by the contemnor's prior conduct. See Withrow v. Concannon, 942 F.2d 1385, 1388 (9th Cir. 1991)

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("Impossibility of perfect compliance, then, may be a defense to contempt, but it does not preclude an injunction requiring compliance . . . when a pattern of non-compliance has been shown").

89. The prior facts of this case rebut the Debtor's New Argument, not only because it is difficult to reconcile the new argument with how the Debtor defended her noncompliance prior to October, but also due to the Debtor's overall general pattern of noncompliance during these proceedings. This pattern is displayed by the Debtor's apparent selective recall of information queried at the Hearings,²⁹⁵as well as her general unwillingness to comply with really any of the Directives until particularly pressed as to a discrete part. The Debtor only complied once noncompliance became specific enough to patently constitute contempt and never before her noncompliance, while a fact, was not obvious. A contemnor's eventual and torturously obtained compliance with most directives, while indeed precluding further sanctions on the basis alone of those directives, should still be able rebut later self-serving submissions discordant with those prior facts.

90. Fifth, the Court simply does not believe the Debtor's New Argument, based on (1) the Protective Motion and (2) the Debtor's noncompliance with the Forwarding Emails Directive. First, the Protective Motion, due to its timing and language, makes it virtually impossible, on the Court's view, that the Debtor is not in contact with the Tribal Entities.

91. Second, the Court fashioned the Forwarding Emails Directive in a specifically narrowly tailored way so that the Debtor could show good faith efforts to comply. This is because, while doubtful, the Court does not completely rule out the possibility that the Debtor was enrolled in the Debtor's Jurist Course at some point but now no longer has access to any Course Documents and somehow has become cut off from all Tribal Entities. However, it is inconceivable how the

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Debtor can truthfully have no such emails to forward even if she was only minimally engaged with the Tribe as a rank-and-file paying member, which is one fact she has never repudiated. Thus, her specific noncompliance with the Forwarding Emails Directive confirms what is evinced by the facts before the Court: that as to the Tribal Directives, the Debtor can comply but chooses not to comply.

ii. Further Sanctions Coerciveness as to the Debtor's Compliance

92. Deciding whether the Debtor has complied with the Contempt Orders, which she has not, does not end the analysis. This is because where sanctions under civil contempt have not coerced compliance, further sanctions may stop being coercive and become punitive to the extent a court believes it will either (1) not effectuate compliance, or (2) it can do so only do at a cost violative of due process.²⁹⁶

93. After accruing more than $11,000 in Contempt Fines for almost half a year, the Debtor has not budged at all with regard to the Course Documents Directives and has only possibly budged with regard to one of the Tribal Directives, the First Mailing Directive. The Contempt Fines have not progressed the matters underpinning the Tribal Directives. Thus, continuing Contempt Fines now would be more punitive than coercive.

94. For this reason, the Court will terminate the ongoing daily contempt fines in the Base Case and the Adversary Proceeding. However, the Court will neither (1) purge the contempt findings given that the Debtor has not complied with the Contempt Orders and is still in contempt nor (2) vacate the accrued fines.

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95. As to the second, the Court will not vacate the accrued fines, despite the fact some courts do,²⁹⁷for two reasons. First, the Court questions whether such practice is advisable since it seems to engender delay of compliance because it makes when compliance occurs not a concern of a contemnor if they will eventually comply. Second, the Court's recognition that the Contempt Fines have become punitive is only with regard to the Tribal Directives. Indeed, this does not appear to have been the case with the non-Tribal Directives. The Contempt Fines were requisitely coercive as to the non-Tribal Directives until the Debtor came into compliance, which was sometime around the November 3 Hearing. For this reason, the Court terminates the fines as of November 3, 2025.

b. The Debtor's Outstanding Motions

96. The Outstanding Motions all generally seek reconsideration of various Court orders made during these proceedings, specifically six related to the Contempt Orders.²⁹⁸The Court will first consider the Notice Reconsideration Motion which seeks reconsideration of the Order Denying Shortened Notice.²⁹⁹

97. The Notice Reconsideration Motion argues that her Shortened Notice Motions for the Third and the Fourth Contempt Review Motions should have granted because (1) the matters were urgent due to the Court's criminal contempt threat,³⁰⁰(2) the Debtor is pro se whereas the

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Trustee and Bankruptcy Administrator have a staff and resources warrants accommodation for her,³⁰¹and (3) she had previously been able responded to a pleading in this case in a four day like she wanted here.³⁰²

98. The Court denies the Notice Reconsideration Motion. The extremely short notice period sought by the Shortened Notice Motions for the Third and the Fourth Contempt Review Motions alone warrants the ruling and precludes reconsideration. It was further warranted since by the time the Debtor filed the Shortened Notice Motions, she had been well aware of this rule through her many attempts to avoid it.³⁰³

99. The other six Outstanding Motions make various submissions, many of which duplicate arguments the Debtor has already raised and the Court has rejected. Together, they seek termination and reconsideration of the Contempt Sanctions, Findings, and Orders as it relates to the Course Documents Directives, emergency stay of the Orders, a protective order shielding the Course Documents from discovery, an award of attorney's fees, reconsideration of the discharge denial, and, finally, declarations that the Court cannot punish the Debtor, that the Debtor has complied or that her compliance is impossible, and that the Course Documents are copyrighted and irrelevant to bankruptcy.³⁰⁴

100. Four motions seek this on the Debtor's ground (1) that she cannot comply with the Course Documents Directives because she does not own or possess the Course Documents, that

(2) the Course Documents are copyrighted and irrelevant to bankruptcy, and³⁰⁵all six also assert

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(3) that the Course Documents Directives violates the Debtor's constitutional right to due process because her compliance is impossible.³⁰⁶The Stay Motions also argue that the Contempt Orders violate (4) the Debtor's her right to privacy and (5) the Court's Article I authority.³⁰⁷

101. As to the second two grounds, the Court has already rejected these arguments multiple times. As to the first ground, the Court does not believe the Debtor.³⁰⁸For the same reasons, the Court rejects the due process grounds. As to the privacy grounds, they are not timely and should have been raised earlier. Lastly, as to the Article I powers ground, the Court agrees with the Debtor completely that the Court does not have the power to seek punitive sanctions. This is exactly why, as the Court has explained multiple times to the Debtor, the Court has never considered itself executing or initiating any criminal penalties against or imprisonment of the Debtor. Thus, the Court denies all requested relief in the Outstanding Motions.³⁰⁹

B. Criminal Matters

1. Legal Background

a. Bankruptcy Courts' Powers to Refer for Criminal Prosecution, to Seek Criminal Contempt, and their Duty to Report Crimes under 18 U.S.C. § 3057

102. Notwithstanding bankruptcy courts' substantial civil contempt powers, so long as its sanctions remain coercive or compensatory,³¹⁰bankruptcy courts generally cannot execute, initiate, or formally seek criminal penalties. However, bankruptcy courts have a statutorily

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imposed duty when they "hav[e] reasonable grounds for believing that any violation under chapter 9 of this title or other laws of the United States relating to insolvent debtors … has been committed, or that an investigation should be had," to "report to the appropriate United States attorney all the facts and circumstances of the case, the names of the witnesses and the offense or offenses believed to have been committed." 18 U.S.C. § 3057. This language is neither permissive nor discretionary; it is a mandatory duty of this Court from Congress.

b. Unauthorized Practice of Law Elements in North Carolina and Bankruptcy Courts Procedure for Reporting it under 18 U.S.C § 3057

103. North Carolina law bars the practice of law by any non-licensed individual, see N.C. Gen. Stat. § 84-2.1, and criminalizes the unauthorized practice of law as a Class 1 misdemeanor. See N.C. Gen. Stat. § 84-8. North Carolina defines the "practice of law" broadly to reach "performing any legal service for someone else," and "include[es]. . . preparing or aiding in the preparation of any petitions,. . . assisting by advice, counsel, or otherwise in any legal work; and advis[ing] or giv[ing] opinion upon the legal rights of" someone else. N.C. Gen. Stat. § 84-

2.1. Section 84-7 empowers district attorneys to seek injunctions or criminal prosecution for violations of § 84-2.1. North Carolina bankruptcy courts that believe the unauthorized practice of law has occurred have a duty to report it to both the U.S. Attorney and the state district attorney pertinent to its district due to the mixed federal and state jurisdiction of such potential crimes in the bankruptcy context. See, e.g., In re Howerton, No. 04-12819, 2004 Bankr. LEXIS 2695, at *2 (Bankr. M.D.N.C. Nov. 24, 2004).

c. Criminal Perjury Elements and Perjury's Effect as to Discharge in the Fourth Circuit

104. Making a false oath or false declaration in front of a federal court is a crime punishable by fines and up to five years imprisonment. See 18 U.S.C. § 1621 (criminalizing perjury

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before a federal court generally); 18 U.S.C. § 152(2)-(3) (criminalizing perjury specifically in a bankruptcy case). Courts interpreting the latter have held such a crime has occurred when the following elements are met: (1) the existence of a bankruptcy proceeding, (2) a statement made therein that is (a) material and (b) false, and (3) the statement was made (a) under oath and (b) knowingly and fraudulently. See, e.g., Metheany v. United States, 390 F.2d 559, 561 (9th Cir.), cert. denied, 393 U.S. 824 (1968).

d. Criminal Contempt Elements and an Impossibility Defense

105. Contempt is criminally punishable conduct pursuant to 18 U.S.C. § 401(3) empowering courts "to punish by fine or imprisonment, or both, at its discretion, such contempt of its authority, and none other, as. . . [d]isobedience or resistance to its lawful writ, process, order, rule, decree, or command." The Fourth Circuit interpreting 18 U.S.C. § 401(3) has held it requires three elements that approximately mirror those for civil contempt, specifically, " '(1) a reasonably specific order; (2) violation of the order; and (3) the willful intent to violate the order'." United States v. Mahbobeh Shariati, 694 F. App'x 893, 894-95 (4th Cir. 2017) (citation omitted) (per curiam)). The Fourth Circuit has also held that criminal contempt under 18 U.S.C. § 401(3), unlike civil contempt, requires that the contemnor "willfully violated a decree that was clear and left no uncertainty in the minds of those that heard it." United States v. Westbrooks, 780 F.3d 593, 595 (4th Cir. 2015) (internal quotation marks omitted).

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2. Analysis

a. The Criminal Allegations against the Tribal Entities

106. Sufficient evidence exists for a reasonable belief that the Tribe has or is committing unauthorized practice of law. This conclusion is evinced through pieces of evidence displaying the Tribe's activities generally as well as various actions taken by the Debtor in this case.

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i. Evidence that the Tribal Entities Have Committed Unauthorized Practice of Law Independent of this Case 311, 312

107. Shabazz Associates offers a 'Tribal Jurist Course Certification' through Aboriginal University taught by Minister Shabazz.³¹³Individuals can obtain this 'Certification' upon enrollment in and completion of one of four proffered 'semesters' for the course.³¹⁴This course

311 The Court notes that the Bankruptcy Administrator uncovered this information through her own independent research. The Court notes this, first, to acknowledge the Bankruptcy Administrator's hard and diligent work as to these matters. The Court also notes this because, although the Bankruptcy Administrator presented this evidence at the October Hearing, she was unable admit most of it through the Debtor's testimony. See Exhibit List [Doc. No. 232]. Nevertheless, the Court does not think covering the evidence here contravenes evidence rules preventing admittance there and are binding on the Court, for two reasons. The first reason is that this evidence's availability online suggests it qualifies for judicial notice as the Fourth Circuit has recognized for at least some websites. See, e.g., Hall v. Virginia, 385 F.3d 421, 424 n.3 (4th Cir. 2004); United States v. Garcia, 855 F.3d 615, 621-22 (4th Cir. 2017). Additionally, it being available specifically on Internet Archive further bolsters that judicial notice of the evidence is allowed. See Under a Foot Plant Co. v. Exterior Design, Inc., No. 6:14-cv-01371-AA, 2015 U.S. Dist. LEXIS 37596, 2015 WL 1401697, at *4 (D. Md. Mar. 25, 2015) ("District courts have routinely taken judicial notice of content from The Internet Archive."); Pinder v. 4716 Inc., 494 F. Supp. 3d 618, 625 (D. Ariz. 2020) ("Archived websites may sometimes be afforded judicial notice.").

Second, courts considering reporting under 18 U.S.C. § 3057 have recognized doing so does not necessitate following all evidence rules since a court finding it must report a crime under 18 U.S.C. § 3057 is not the same as a court finding that the crime did indeed occur. See Frankoff v. Norman, No. 14-11- 00152-CV, 2012 Tex. App. LEXIS 5045, at *12-15 (Tex. App. June 26, 2012) ("The Referral does not constitute conclusive proof. . . . [A] referral [18 U.S.C. § 3057] is not evidence of a crime, but is based on the referree's conclusion that there are grounds supporting a reasonable belief that a crime was committed. Id. § 3057(a). As such, it may be based on information that is not admissible evidence to be investigated by the United States Attorney. See In re Coral Petroleum, Inc., 249 B.R. 721, 725 (Bankr. S.D. Tex. 2000) (noting referral to United States Attorney was for investigation of potential criminal conduct). It is not proof of the allegations contained within it. See id.; see also In re Guttierez, 248 B.R. 287, 290 n.3 (Bankr. W.D. Tex. 2000) (noting bankruptcy court may not adjudicate criminal matters relating to concealment of assets belonging to bankruptcy estate but may refer matter for criminal investigation)."); United States v. Hubbard,

650 F.2d 293, 323 (D.C. Cir. 1980) (stating that "[o]f course, copies of the documents can be made available by the court to appropriate law enforcement authorities," regardless "as to what is admissible evidence and what is not" (citations omitted)).

312 The Court reproduces all language from sources in this section as they appear (and without any "sic"

notations), except for omissions, punctuation additions, and stem and some capitalization changes.

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costs $1,000.³¹⁵Shabazz describes the course's "[p]urpose" as "to Certify Aboriginal Jurists who can become law professionals in our Indigenous Jurisdiction and protect Indigenous Nationals of ARNA who are also US Nationals from adverse actions from adverse legal fictions posing as governmental structure."³¹⁶The topics covered in the course include:

• "Taxes, Debt and Currency," which purports to teach enrollees "how to live a tax Exempt for Life Operation (all Sales Taxes) via Indigenous Exemption, Ecclesiastical Automatic Exemption, or Itemized Deduction on 1040, How to properly engage form 56, How to Fillout Form i-9 as a Native, How to Use forms w-8 Ben W-9 and W-4 properly, How to engage Property Tax Exemption using Ecclesiastical entities and or Itemized deductions on 1040's," as well as

"Understanding debt and what it actually is and what it is used for and the impacted;"

• "Lawsuits and Keys to Winning," which purports to teach enrollees "to be comfortable going to court and working with nationals and non-nationals on cases and the property way of dealing with issues and winning in court;"

• "Contract Law," which purports to teach enrollees how "to understand how contracts work and the impact of them on Aboriginal people" and "[h]ow to properly engage in contract without jeopardizing the status of the aboriginal;" and

• "Business Operations as Tribal Jurist and Running Tribal Law Firm Successfully,"

which purports to teach enrollees how "to put[ ] it all together. . . to understand how to organize yourself and run your law firm to serve aboriginals."³¹⁷ HAWAB ARNA describes this course as enabling enrollees to:

• "Assist with Tax Matters, dealing with fraudulent claims by ALL Tax Entities making unlawful claims on Indigenous Peoples, Removing PERMANENTLY Fraudulent Child Support Claims;"³¹⁸

• "Removing Fraudulent Mortgage Issues and Fraudulent Debt Claims from the most successful system of removing erroneous debt claims, the identity theft Identity Fraud Procedure;"³¹⁹

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• Assist with Lawsuit issues . . . : all types in Indigenous Jurisdiction and foreign venues. The multiple levels of labor offered guarantee the Aboriginal Jurist will have a service that is high demand."³²⁰

108. Shabazz Associate's website also contains a webpage titled "Debt, Tax, Student, OTHER DEBT Discharge Intake." Although the Google Form for this is no longer accepting responses,³²¹this webpage also provides links to purchase from Shabazz 'Debt Donation Removal' for $1,500³²²and '7 Year Statute Of Limitations Donation' for $500 which is marketed with a picture stating "Debt Relief Just Ahead."³²³

109. Aboriginal University, which claims to be ARNA's first accredited educational institute and the certifying arm for all Aboriginal Jurists,³²⁴offers, through its 'School of Law', courses on topics such as "Tribal Business Registration," "Business & Personal Credit," "Law Consultation," "Lawsuit Drafting," "Business Credit and Personal Credit Services," and "Land Trust Services."³²⁵Level 2 of the Jurist program features 'homework' that quizzes enrollees on topics such as "Insolvency," "liability," being a "debtor," "Creditor[s]," "liquidation,"

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"competency," the Supremacy Clause, "real defense," "fraud," "Bankruptcy," the Bankruptcy Clause, the UCC, differences between "chapter 13 & Chapter 7 discharge," "arrears," a "habeas corpus action," Chapter 7's effect on child support, and remedies for child support orders.³²⁶Level 3 of the program offers training on "International Law-Patent Trademark Copyright Training."³²⁷

110. HAWAB ARNA also offers 'Jurist Level 1 Private Coaching," which also costs $1,000.³²⁸HAWAB ARNA describes this coaching as "Minister Kojo you will have access to us on a weekly conference call which will be recorded" and requires that "you must be enrolled as a jurist at one of the following institutions: ARNA Aboriginal Law Firm/Aboriginal University[,] Hawab University[,] Or Any Other Creditable University within ARNA."³²⁹

ii. Evidence that the Tribal Entities Have Committed Unauthorized Practice of Law from this Case

111. The Debtor actions both prior to the Petition Date and within this case appear to have been done at the advice of, for the benefit of, or in concert with the Tribal Entities. First, as to actions done prior to the Petition Date, the Debtor was a member of the Tribe as of the Holt Solutions Creation Date and Conveyances Date based on both independent evidence³³⁰and the

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Debtor's own testimony.³³¹The Debtor has also averred multiple times in this case and as late as October, 2025, to having taken a Jurist Course.³³²Lastly, the Debtor paid a total $3,930 to Tribal Entities within three years of the Petition Date—almost $2,000 in 2022, the year of the Holt Solutions Creation Date, nearly $1,200 in 2023, the year of the Conveyances Date, and almost $900 in 2024, the year of the Petition Date.³³³These facts reasonably suggest the Tribe's advancement or involvement in the creation of Holt Solutions and the Conveyances. Indeed, the fact alone that the Debtor has paid so much to the Tribe the last few years for apparently nothing in return, is suspect.

112. Moreover, further evidence ties the Tribal Entities to the creation of Holt Solutions and the Conveyances. Prior to Petition Date, the Debtor described the creation of Holt Solutions as relating to the Tribal Entities.³³⁴The Debtor has similarly described the creation of Holt Solutions and the Conveyances as relating to the Tribe throughout her various submissions during these proceedings.³³⁵The clear implication of these facts is that the Tribe directed or advised the Debtor for both the creation Holt Solutions and the Conveyances, which is all the more concerning given the deleterious effect of both on the Debtor's financial matters, the Payments she's made to the Tribe, and the lack of any value in return. This above evidence is further corroborated by (1) 3/arnaannualbudget2023.pdf) (listing the Debtor, but misspelled as "Ryan Lashaun Ford," amongst members it appears that were in good standing as to paying dues).

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how the Tribal Entities offer the very courses that comprise the Debtor's Tribal Courses,³³⁶(2) how the Debtor has continued to assert the Tribal Entities' copyright justifications as why she cannot comply with some of the directives, (3) how the Debtor has displayed confusion as to the content of her own pleadings, and (4) how the Protective Motion displays that the Debtor's actions in this case have been at the Tribal Entities' direction.

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113. The Court believes the evidence above reasonably evinces unauthorized practice of law which the Court is under a duty to report. While the evidence from the Tribe that is independent of this case may be protected by the First Amendment (but, if so, only under the relaxed standard for commercial speech), when combined with the evidence from this case, there is the appearance that the Tribe is attempting to obtain legal outcomes in the Western District of North Carolina Bankruptcy Court through the Debtor's case without needing to be admitted to the Court. Thus, the Court reports this to the U.S. Attorney for Western District of North Carolina and the Mecklenburg County District Attorney.

114. The Court believes these activities warrant investigation particularly because, to the extent individuals are paying the inordinate costs for the Tribe's 'services', it would be a scam targeting some of the most vulnerable individuals. While the Court's jurisdiction limits it to dealing with the Debtor and is unable to investigate the Tribe as a non-party (e.g., through issuances of show cause orders), prosecutors are not so constrained.

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b. The Criminal Allegations against the Debtor

i. The Criminal Contempt Allegations against the Debtor

115. The Debtor appears to have willfully not complied with the Contempt Orders as they pertain to the Tribal Entities.³³⁷Thus, pursuant to its duty under 18 U.S.C. § 3057, the Court reports this crime of criminal contempt to the Western District of North Carolina U.S. Attorney.

ii. The Perjury Allegations against the Debtor

116. It appears that the Debtor has made numerous false submissions both to this Court, the Trustee, and the District Court, since the Petition Date. According to the Court's review, the Debtor has made false submissions as to:

• (1) the Properties' valuations by approximately 90%: once, affirmatively in the Debtor's Petition;³³⁸

• (2) the Debtor's Creditors: once, by omission in the Debtor's Petition;³³⁹

• (3) the Debtor's interest in Holt Solution, two times: first, (a) by omission in the Debtor's Petition,³⁴⁰then (b) affirmatively at the January 341 Meeting;³⁴¹

• (4) the Conveyances, two times: affirmatively both (a) in the Debtor's Petition³⁴² and (b) at the January 341 Meeting;³⁴³

• (5) the Rental Income eleven times: by omission and affirmatively twice both (a)-

(c) in the Debtor's Petition³⁴⁴and (d)-(i) in the Amended Schedules,³⁴⁵by omission (j) in the Reaffirmation Agreement,³⁴⁶and (k) by omission in the IFP Application;³⁴⁷

• (6) the Debtor's Accounts, countless times: in the Debtor's Petition, in various pleadings, and in testimony before the Court;

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• (7) the Tribal Payments, twice: (a) at the January 341 Meeting³⁴⁸and (b) the May Hearing;³⁴⁹and

• (8) the Trustee and the Bankruptcy Administrator's actions, affirmatively twice: in the Original Recusal Motion and the Original Reference Withdrawal Motion Response Reply.³⁵⁰

117. Although there is only direct evidence as to its willfulness as to one of the above false submissions,³⁵¹the number of false submissions and their convenience to the Debtor's position on the matters for which the Debtor proffered them, sufficiently evinces a strong case of criminal perjury. Similarly, as to the Debtor's false submissions regarding the Debtor's Accounts, the Debtor's pattern of compelled, piecemeal disclosure aggravates those false submissions and demonstrates that those omissions were not inadvertent but willful.

118. The Debtor made all of the above submissions including the Debtor's Petition, the Debtor's Amended Schedules, and the IFP Petition under penalty of perjury.³⁵²In the Debtor's Petition, the Debtor also acknowledged being "aware that bankruptcy fraud is a serious crime and that if [her] bankruptcy forms are inaccurate or incomplete, [she] could be fined or imprisoned."³⁵³ At the January 341 Meeting, the Debtor's statements were made under oath,³⁵⁴as were generally all the Debtor's statements in her pleadings and at the various hearings before the Court.

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119. In sum, the Court believes that the facts above reasonably show that the Debtor has engaged in perjury. Thus, pursuant to its duty under 18 U.S.C. § 3057, the Court reports these crimes to the Western District of North Carolina U.S. Attorney.

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120. However, the Court would not recommend any criminal prosecution against the Debtor for these crimes of criminal contempt and perjury. The reason for this is that the Court feels that the financial costs to the Debtor from this case sufficiently punishes the Debtor.

121. These costs are not due to the civil contempt sanctions, which themselves are not insignificant, but rather the reasonable administrative costs of the Trustee so far in this case. Only considering the Trustee's expenses and fees incurred December through May of 2025, the administrative costs exceed of $43,000³⁵⁵and will most likely be at least double that by the end of these proceedings. Pursuant to 11 U.S.C. § 507, these expenses are given priority from distribution of the Debtor's assets. This case is uniquely an asset case and proceeds from the Debtor's assets will have to be liquidated, and the proceeds will go to covering these expenses and to pay the Debtor's creditors. The Court believes that this natural result of the Debtor's actions is punishment enough as an incurrence of expenses at this level is not an insignificant penalty.

C. The Trustee's and Bankruptcy Administrator's Requests

122. Lastly, the Trustee and Bankruptcy Administrator have requested other relief beyond that discussed. First, the Trustee asks the Court to issue "a final denial of the Debtor's discharge in this case."³⁵⁶Second, the Bankruptcy Administrator seeks imposition of Federal Rule

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of Bankruptcy Procedure 9011 sanctions due to the Debtor's filing of pleadings making frivolous or previously rejected arguments.³⁵⁷Third, the Bankruptcy Administrator requests a prefiling injunction barring the Debtor from filing pleadings based on (1) the dozens of pleadings filed by the Debtor lacking any basis in law or fact or misrepresenting both, (2) the Debtor continually seeking relief already denied and reasserting arguments previously rejected, (3) the Attempted Representation, as well as (4) various duplicative filings.³⁵⁸

1. The Trustee's Request for Final Denial of Discharge

123. The Court grants the Trustee's final denial of the Debtor's discharge. First, the Court's previous denial conditioned any possible discharge on the Debtor fully complying with the Contempt Orders, which, because the Court has found that the Debtor can comply but choose not to,³⁵⁹interdicts any possible discharge. Additionally, although the Court is not recommending further prosecution of the Debtor for perjury, it does not doubt it has occurred to a criminally sanctionable extent which necessarily means the Debtor is ineligible for discharge under 11 USCS § 727(a)(4)(A) and Fourth Circuit precedent. See, e.g., United States v. Sieber (In re Sieber), 489 B.R. 531, 554 (Bankr. D. Md. 2013) (setting the standard for 11 USCS § 727(a)(4)(A)'s bar of discharge due to a debtor having "made a false oath or account," as requiring that the debtor made a statement that was (1) false, (2) material to the bankruptcy case, and (3) it was done (a) under oath, (b) knowing its falseness, and (c) with fraudulent intent (citations omitted)); see also Van Robinson v. Worley, 849 F.3d 577, 583 (4th Cir. 2017) (citation omitted).

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2. The Bankruptcy Administrator's Request for Federal Rule of Bankruptcy Procedure 9011 Sanctions

124. As to the Bankruptcy Administrator's request for Rule 9011 sanctions, the Court denies it. First, the Court does not dispute Bankruptcy Administrator's assertion that the Debtor has persistently and flagrantly violated Federal Rule of Bankruptcy Procedure 9011 through her litany of pleadings and continual reassertion of meritless arguments long after the Court has explicitly rejected them. One need look no further than six Outstanding Motions canvassed above to see this.

125. Nevertheless, the Court feels itself is sufficiently to blame on this score to make Rule 9011 sanctions unwarranted as of now. The Court should have made clear to the Debtor much earlier that she could not continue to make such arguments in her filings and in court, and that doing so would justify sanctions. It did not. The Debtor, as a pro se litigant (notwithstanding the Tribe's ostensible help), should have been informed of this consequence and its contours sufficiently prior to any imposition of such sanctions. Since the Debtor was not so informed, the Court is unwilling at this juncture to sanction the Debtor pursuant to Rule 9011.

3. The Bankruptcy Administrator's Request for a Prefiling Injunctions

126. As to the Bankruptcy Administrator's request for a filing bar on the Debtor, the Court grants it. The Debtor's continued reassertion of arguments the Court has rejected as well as the Debtor's multiple duplicate filings warrant such relief. Thus, any future filings by the Debtor must be first sent to the Court before they are docketed. The Court will approve appropriate filings as not reraising arguments the Court has rejected before allowing them to be docketed.

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III. CONCLUSION

The Court concludes with the following three notes to the Parties. First, to all the Parties, the Court reiterates what it stated at first at November 3 Hearing, in the Final Contempt Order, and the November 17 Hearing, that this order finally disposes of all the contempt matters such as those relating to the Tribe and Tribal Entities, the Debtor's contempt and perjury, any alleged bias against the Debtor, etc. The Court sees absolutely no reason why it will need to hear these matters again, especially since it has heard them repeatedly over the last seven months. To the extent any Parties take any issue with this order, they can appeal it. Second, as to the Trustee and the Bankruptcy Administrator, the Court commends the work they have done throughout this case. They have had to spend an inordinate amount of time on this case, far more than is usual for a Chapter 7 case and probably more than most cases under any chapter of the Bankruptcy Code. Nevertheless, they have never failed to do what was required to find the information vital to the case which the Debtor would not or had not disclosed. This is particularly noteworthy for Bankruptcy Administrator who, unlike the Trustee, is not paid hourly, and yet still has worked on this case outside of work hours and even on the weekends. The bankruptcy system's very existence depends on individuals like the Trustee and the Bankruptcy Administrator verifying parties' submissions and litigating for the good of the system overall. They are the frontline defense against the conduct that has occurred here and the Court cannot stress enough their importance. Third, to the Debtor the Court states again, for clarity's sake, that the Court itself is not imposing any criminal penalties on the Debtor.

WHEREFORE IT IS ORDERED that

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1. The Debtor's ongoing Civil Contempt Sanctions in the Chapter 7 Base Case and the Adversary Proceeding are TERMINATED as of November 3, 2025, and the accrued sanctions of $11,200 are REDUCED to a Money Judgement;

2. The Debtor is ORDERED to pay this Money Judgement to the Court by May 30, 2026;

3. The Court will SEND this Order by both certified mail and electronic email to the U.S. Attorney for the Western District of North Carolina and the Mecklenburg County District Attorney as a formal report pursuant to 18 U.S.C. § 3057 of possible crimes;

4. The Debtor's Outstanding Motions are DENIED;

5. The Debtor's DISCHARGE is DENIED;

6. The Debtor is BARRED from filing anything in the Chapter 7 Base Case that is automatically docketed and any future such filings must first be forwarded by the Bankruptcy Court Clerk to the Court before being docketed and the Court will review such filings to decide that they are not duplicitous or completely without merit; and

7. The Bankruptcy Administrator's Request for Federal Rule of Bankruptcy Procedure 9011 Sanctions is DENIED without prejudice.

IT IS SO ORDERED.

This Order has been signed electronically. United States Bankruptcy Court The Judge's signature and Court's seal

appear at the top of this order.