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On February 4, 1999, petitioner filed an opposition to
Proulx’s ex parte application. Petitioner argued that the relief
sought by Proulx in the ex parte application was improper for
various reasons but offered to place the final reward installment
then due to her from the U.S. Government into a segregated,
interest-bearing special attorney-client trust account with her
bankruptcy counsel’s firm, Robbins & Keehn (the trust account),
under the conditions that there would be no withdrawals from the
trust account without: (1) An order from the bankruptcy court;
or (2) the consent of Proulx.
On February 22, 1999, the bankruptcy court directed the U.S.
Government to make the final installment of petitioner’s reward
and further
ordered that * * * [petitioner’s bankruptcy attorney
and his firm] are hereby instructed to place the funds
from * * * [the reward] into * * * [the trust account].
These funds may not be disbursed without further order
of this court. Further, in the event that * * *
[petitioner] dismisses her Chapter 13 action, the funds
shall remain in * * * [the trust account] pending
further order of this court.
The reward was paid to petitioner by U.S. Treasury check
dated February 26, 1999. The check represented the fourth
installment of the reward due petitioner as a result of the
settlement from the whistle-blower case. The check was issued to
petitioner “c/o Charles F. Robbins Esq., Robbins & Keehn, 530 B
Street, Ste. 2400, San Diego, CA 92101”. Petitioner endorsed the
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