Letantia Bussell - Page 4

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          management corporation and two other medical corporations                   
          (collectively, the three corporations) in which petitioner would            
          ostensibly own no interest.  Pursuant to petitioner’s                       
          instructions, the attorneys formed the three corporations without           
          any apparent ownership by petitioner but with the apparent                  
          ownership by third-party nominees.  Petitioner in fact owned each           
          of the three corporations.  Petitioner caused the three                     
          corporations to be formed with the express intent of defrauding             
          creditors, including respondent, by concealing her assets and               
          income during a bankruptcy that she would file in connection with           
          a scheme (bankruptcy scheme) to maximize retention of her assets.           
          This income included income derived from the dermatology                    
          practice.                                                                   
               The medical management corporation, BBL Medical Management,            
          Inc. (BBL), was incorporated in California in June 1992.  It                
          operated the dermatology practice under the name “Beverly Hills             
          Dermatology Consultants, A Medical Group”.  BBL received all of             
          the income earned in the dermatology practice, employed the                 
          dermatology practice’s medical staff, and collected moneys due to           
          the dermatology practice from insurance companies and patients.             
          BBL also paid the dermatology practice’s business expenses and              
          purchased its supplies.                                                     
               Petitioner was advised by Beaudry that BBL should be owned             
          `by a third-party nominee in order to conceal petitioner’s actual           
          ownership of BBL.  Petitioner selected Assieh Ghassemi                      




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