David Carlebach Esq Performed a Miracle he received money that David baksht did NOT give him

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Baksht testified at the evidentiary hearing that he “rarely” needs

to take medications and painkillers. (3/4/13 Hrg. Tr. at 151:3-13). But when

faced with prior deposition testimony harmful to his interests (that Schneorson

had a 50 percent equity stake in the Debtor), Baksht tried to disavow his

testimony on the basis that he was on “strong pain killers” during his deposition.

(Mov. Ex. 15 at 67:20-21, 89:1-4, 145:8-10; Mov. Ex. 5 ¶ 10). A claim of drugaffected

testimony is one of Baksht’s recurring ploys. He again claimed to be on

“very strong medication” when he was deposed on February 26,
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The Debtor’s bankruptcy counsel has failed to file an amended affidavit as required under

Bankruptcy Rule 2016. The existing sworn statement filed under Bankruptcy Rule 2016(b)

represented that Carlebach received a retainer of $5,000 from David Baksht. (Mov. Ex. 1 ¶ 4).

Baksht testified that he did not make that payment. (2/27/13 Hrg. Tr. at 24:7-25).

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