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Alphonse Mourad
125 West Street
Hyde Park, MA 02136

August 17, 1997
(Open Letter)

Mr. J. Christopher Marshall
United States Trustee
Thomas P. O'Neill Jr.
Federal Bldg.
10 Causeway Street
Room 1184
Boston, MA 02222

In Re:

Eric K. Bradford & V&M Management, Inc.

Ch. 11 Case No. 96-10123-CJK

Dear Mr. Marshall,

I wish to register a complaint with your office and ask that you investigate the conduct of Attorney Eric K. Bradford in connection with this case, and to take such disciplinary and corrective action, including removal of Bradford from the case, because Bradford has demonstrated unfair bias against me, has blindly rubber-stamped the position of the Chapter 11 Trustee, Stephen S. Gray, and has not been fair or neutral or undertaken to understand the true dimensions of this bankruptcy.
To begin with, Bradford has made no efforts to form an unsecured creditors committee, and their interests have been all but lost in the ocean of paper that has engulfed this case. Second, at the April 1, 1996 hearing on the Motion to Appoint a Trustee, Bradford made a totally improper reference to the misleading front page article in The Boston Globe about Mandela, myself, and the Court's decision to remove me from the Mandela development before the hearing was even held (see Exhibit "A"). This remark was highly prejudicial to me and the Debtor.
This improper reference to The Boston Globe article was not as bad as it got. Bradford made an inane argument about his own study of "logic and rhetoric," Mourad's "offense-defense" approach, and even invoked Richard Nixon's "Checkers speech" (Pg.46 of April 1, 1996 Transcript). Bradford's argument even confused the Court, not knowing whether Bradford supported the appointment of a Trustee or supported authorizing an Examiner with expanded powers as a less drastic and more appropriate remedy than the "extraordinary," last resort remedy of a Trustee. Realizing his error, Bradford apologized to Court for his improper and harmful remarks. But his apology did not correct the wrong. Bradford went on to recommend Stephen S. Gray as Trustee of the Mandela development.
Eric Bradford continued his personal vendetta against me on December 23, 1996, in a room full of witnesses, including former Senator William Owens, Thelma Barros, Bill Ferguson, the director of the Schiller Institute, and me. Bradford said ..."You took a million dollars in 1995 Al, you are a fraud, and you are using the tenants for your own personal gain and benefit ." This defamatory, biased, and unsupportable statement is a clear example of the negative and tainted picture that Bradford has painted of me.
Bradford has no proof that I took $1,000,000 from V&M Management in 1995 as he so erroneously stated. Furthermore, I have proof that I did not take $1,000,000 from V&M in 1995. In a May 9, 1997 letter from certified accountant, Steven Slavin to me, Slavin states "After having reviewed the V&M Management, Inc. federal corporate income tax return prepared by Verdolino & Lowey, for the year ended December 31, 1995, distribution to shareholders (Mourad) was only $63,831" (see Exhibit "B"). Interestingly, Verdolino & Lowey were retained by Trustee Gray and are not V&M's accountants, yet they claim that I only took $63,831 in 1995 from V&M; a total contradiction to the Court's April 1, 1996 finding that I took approximately $1,000,000 from V&M in 1995, which constituted mismanagement, thus giving the Court reason to appoint a Trustee.
With all of the evidence and Motions to Correct and clarify Judge Kenner's erroneous findings and conclusions from the April 1, 1996 order appointing a Trustee, and the fact that V&M was forced to file bankruptcy due to the denial of an injunction against a foreclosure on fraudulent and forged note, verified by a hand-writing forensics examiner (see Exhibit "C," Memorandum of Hanify & King, and Exhibit "D", May 27, 1997 Affidavit of Ronald H. Rice, certified forensics examiner), Bradford still continues to support parties (BRA, DOR, City of Boston) whom have sought control of the Mandela development for many years at the expense of my livelihood, financial stability, and reputation.
A second opinion has been obtained by certified document handwriting examiner, Joan McCann. McCann states in a July 28, 1997 letter "It is more probable than not that the two illegible witness signatures appearing on the questioned exhibit Q-1, were not authored by the same person who signed the unreadable witness signatures" (see Exhibit "E").
Bradford has not protected the interests of V&M's estate or its creditors. In addition to not organizing a creditors' committee, Bradford has kept silent the entire time the Trustee, Stephen Gray, devalued the property, and did not dispute Trustee Gray's ridiculous valuation of $100,000. Obviously, if this is the true valuation of the estate, then the estate is in far worse condition than it was before Bradford opened his mouth and made ludicrous accusations, comments, and recommendations to the Bankruptcy Court.
In a June 3, 1997 letter from certified accountant Steven Slavin to Mourad, Slavin stated that the "total Net Income for the year ended 1996 is $1,063,994" (see Exhibit "F"). This demonstrates that the property is worth far more than $100,000, and that the Trustee wants to keep every dime of the $1,063,994 for himself at the expense of the creditors. Again, Bradford has and continues to make no objection to any action the Trustee has taken since his appointment.
As a representative of the U.S. Trustee Office, Eric Bradford is responsible for, and has the power to investigate and dispute any mismanagement that the appointed Trustee commits, any fraud or other criminal activity that has been committed involving the estate prior to, and during the bankruptcy, and ultimately has a responsibility to ensure the highest possible dollar for the creditors of the estate. Bradford has failed to follow through with any of these responsibilities, and failed to protect all of the innocent parties in this case.
That Bradford supports the Plan of Reorganization filed by the Trustee, DOR, Winter Hill Federal Savings Bank, Beacon Residential Properties, and the Mandela Residents Cooperative Association, is further evidence of his non-neutral disposition. That plan will pay the unsecured creditors only 9-12 cents on the dollar. Dismissal of the case so that V&M Management, Inc. could refinance and pay all of the undisputed creditors 100% on their principal, would better serve the creditors. He also failed to consider other plans of reorganization, such as the Plan proposed by Gary Leroy and Mourad, Owens & Associates, which offers a significantly larger amount of money than the Trustee's and Beacon's Plan.
I ask the U.S. Trustee's Office to demand a dismissal of this case so that V&M could prevail in state court against L&N First Mortgage Realty Trust for the fraud, perjury and forgery they committed.
Sincerely,
__________________________
Alphonse Mourad

U. S. Department of Justice
Office of the United States Trustee
Districts of Maine, Massachusetts, New Hampshire and Rhode Island

617-565-6360

Thomas P. O'Neill, Jr.
Federal Office Building
10 Causeway Street, Room 1164
Boston, Massachusetts 02222-1043

August 26, 1997

Alphonse Mourad
125 West Street
HydePark,MA02136

Re:

V&M Management. Inc; Your Letter of August 17, 1997 Dear Mr. Mourad:
This is to confirm that I received and reviewed your letter of August 17, 1997 and have taken the matter under advisement.
Very truly yours,

J. Christopher Marshall
United States Trustee
JCM:hm

Alphonse Mourad
125 West Street
Hyde Park, MA 02136

September 17, 1997
(Open Letter)

Mr. J. Christopher Marshall

United States Trustee
Thomas P. O'Neill Jr. Federal Bldg.
10 Causeway Street
Room 1184
Boston, MA 02222

In Re:

Eric K. Bradford & V&M Management, Inc.

Ch. 11 Case No. 96-10123-CJK
Dear Mr. Marshall,

This letter supplements my August 17, 1997 complaint filed with your office, and asks that Attorney Eric K. Bradford be forced to resign from V&M's bankruptcy case, and that such disciplinary and corrective actions be further taken as you deem proper. As I have stated in my previous complaint, Bradford has demonstrated unfair bias against me, has blindly rubber-stamped the position of the Chapter 11 Trustee, Stephen S. Gray, and has not been fair or neutral or undertaken to understand the true dimensions of this bankruptcy.

V&M was forced to file bankruptcy due to the denial of an injunction against a foreclosure on fraudulent and forged note committed by L&N First Mortgage Realty Trust. Bradford was made aware of this forged note by the several motions I had filed in the bankruptcy court, that were also served to him, as well as all supporting documentation and proof. Although fraud has been committed on the Court, Bradford has and continues to remain silent in light of the unlawful circumstances he is consciously aware of. The forgery of the fraudulent and bogus March 29, 1985, 24%, $50,000 Note by L&N First Mortgage Realty Trust caused V&M to file bankruptcy, and consequently damaged V&M Management, Inc., The creditors of the estate, the Mandela Residents, several of my family members, and myself personally.

On August 7, 1997, Judge Kenner allowed my Motion to Compel L&N First Mortgage Realty Trust To Produce Original Note For Expert Handwriting Analysis (see Exhibit "A," Kenner's Order and Memorandum).

On August 26, 1997, Ronald H. Rice, expert forensic handwriting analyst, examined the (fraudulent) original March 29, 1985, 24%, $50,000 Note at L&N's attorney's office. Expert Rice opines that the note was in fact forged and the signature on the note is not mine, (see Exhibit "B," August 28, 1997 Affidavit of Ronald H. Rice).

As a result of the fraud committed by L&N, and Bradford's failure to investigate or dispute L&N's bogus claim, my family and I have suffered many losses and damages. I have lost fifteen years of my life and investment worth millions of dollars in the Mandela Apartments. My personal home is now being foreclosed on by Winter Hill Bank as a result of this bankruptcy, (see Exhibit "C"). My cousin, Tanious Chouerie, who was a creditor to V&M, and who had to file chapter 13 to protect his home from foreclosure, has recently suffered a heart attack, solely caused by stress of this case, and passed away, leaving behind three young children and a house that is now up for auction. Numerous other family members have and continue to suffer as well, in that, mortgages were taken out on their homes to finance V&M's legal battles against L&N and other various agencies. Now, they must all make their monthly mortgage payments, that V&M had previously made before the Trustee was assigned to take over V&M. If they fail to do so, their homes will be foreclosed upon as well.

Furthermore The Trustee, Steven Gray, his attorney, Paul Moore, and other various entities are seeking over $1,000,000 in administrative fees. Bradford has not disputed the administrative fees of the mentioned parties, which are excessive, and beyond the scope of reason and law. The Trustee has and continues to devalue the property, and has milked every dime of it for himself and his attorney. At one point in this bankruptcy, the Trustee made the ridiculous assertion that the 276 unit property, that was appraised for approximately $8,000,000, was only worth $100,000 and that the creditors of the estate were owed nothing. Again, Bradford did not object to this ludicrous claim. The Trustee should receive nothing for his malicious attempt to rob V&M and its creditors of their livelihood, and financial stability.

This bankruptcy case has lasted over twenty months, and is the most docketed case in the history of the Bankruptcy Court. Had Bradford done his job, it all would have been resolved over a year ago, and would have saved all parties involved months of grief and anguish.

As a result of Bradford not doing his job, I had to take it upon myself to protect the interests of V&M and the creditors. I have spent over fifteen hours working with the FBI on this case. They are extremely interested in the mismanagement of the Trustee and the fraud committed by L&N. They also wonder why Bradford kept silent in light of these circumstances, and did not attempt to contact them in order to ignite a full investigation.

As a representative of the U.S. Trustee Office, Eric Bradford is responsible for, and has the power to investigate and dispute any mismanagement that the appointed Trustee commits, any fraud or other criminal activity that has been committed involving the estate prior to, and during the bankruptcy, and ultimately has a responsibility to ensure the highest possible dollar for the creditors of the estate. Bradford has failed to follow through with any of these responsibilities, and failed to protect all of the innocent parties in this case.

Again, I respectfully ask the U.S. Trustee's Office to compel Bradford to resign and demand a dismissal of this case so that V&M could prevail in state court against L&N First Mortgage Realty Trust for the fraud, perjury and forgery they committed.

Sincerely,
__________________________
Alphonse Mourad

Please Refer to the following August 17 and September 17, 1997 letters written to United States Trustee Christopher Marshall. Please note that Mr. Marshall did absolutely nothing regarding this matter, and has deliberately covered up for Eric Bradford.

United States Bankruptcy Court
District of Massachusetts

Chapter 11 Case No. 96-10123-CJK

In re
V & M MANAGEMENT, INC.,
Debtor

ORDER ON MOTION OF ALPHONSE MOURAD TO COMPEL PRODUCTION OF ORIGINAL NOTES FOR EXPERT HANDWRITING ANALYSIS

Alphonse Mourad's Motion to Compel Production of Original Notes For Expert Handwriting Analysis, which I am treating as a motion for examination under F.R.Bankr.P. 2004, is hereby ALLOWED as follows: Judith Moriarty and Mario Nicosia, as Trustees ofL&N First Mortgage Realty Trust, shall produce the original promissory notes for analysis by Mr. Mourad's handwriting analyst at the offices of their counsel, Victor Bass and the firm ofFriedman and Atherton, but the Trustees ofL&N need not surrender possession of the notes to Mr. Mourad or the analyst. Unless the Trustees ofL&N agree otherwise in writing, the examination must be conducted in counsel's offices. The analyst may make copies of the originals in counsel's offices and analyze the copies elsewhere. The examination shall be conducted at a mutually agreed time within twenty days of this order.
Date: Aug 7 1997

Carol Kenner
United States Bankruptcy Court

cc: Mr. Alphonse Mourad
Victor Bass, Esq., for L&N First Mortgage Realty Trust Paul Moore, Esq., for Trustee

CERTIFIED HANDWRITING AND DOCUMENT EXPERTS

James P. Dillon.Jr.
Attorney At Law
1 Billings Road
No.Quincy.MA 02171
August 28, 1997

HANDWRITING EXAMINER'S REPORT

The undersigned Licensed/Approved Educator/Trainer in Forensic Handwriting Examination and court qualified/appointed Forensic Handwriting Examiner has studied and examined the follow-ing listed documents which were obtained, for comparison purposes, from the office of attorney Victor Bass. For the purpose of identification, these documents are listed and referred to as Exhibits K1. K1A. K1B. K1C. K2. K2A, K2B, K3, K3A, K3B. K4, K4A, K4B. K5, K5A, 01, Q1A. Q1B,Q1C.Q1D,Q1E,Q.1F.
K1. Ore (1) photocopy of a NOTE dated August 14,1985. Document bears one line of handprinted letters, bottom right, that read: AM
K1 A. One (1) photocopy of the second page of the NOTE bearing three lines of handprinted/handwritten letters and words. Above the typewritten name- Alphonse Mourad is the known signature of Alphonse Mourad. The true signature of M r. Mourad appears three times i n this document
K1B. One (1) Polaroid photograph of the first two original signatures authored by M r. Mourad. This photograph was secured from the original document
K1 C. One (1) Polaroid photograph of the two lines of witness initials. This photograph was secured from the original document
K2. Ore (1) photocopy of a NOTE dated December 21,1984. Document bears one line of handprinted letters, bottom right, that read: AM
K2A. One (1 ) photocopy of the second page of the NOTE bearing two lines of
handprinted/handwritten letters and words. Above the typewritten name-Alphonse Mourad is the known signature of Alphonse Mourad. The true signature of Mr. Mourad appears two times in this document
K2B. Ore (1) Polaroid photograph of the two original signatures authored by Mr. Mourad. This photograph was secured from the original document
K3. Ore (1) photocopy of a NOTE dated January 23,1986. Document bears one line of handprinted letters, bottom left, that read: AM
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K3A. One (1) photocopy of the second page of the NOTE bearing two lines of handwritten signatures. Above the typewritten name-Alphonse Mourad is the known signature of Alphonse Mourad. The true signature of M r. Mourad appears two times i n this document
K3B. Ore (1) Polaroid photograph of the two original signatures authored by Mr. Mourad. This photograph was secured from the original document
K4. One (1) photocopy of a NOTE dated March 18.1986. Document bears one line of handprinted letters, right lower column, that read: AM
K4A. One (1) photocopy of the second page of the NOTE bearing two lines of handwritten signatures. Above the typewritten name-Alphonse Mourad is the known signature of Alphonse Mourad. The true signature of M r. Mourad appears two times in this document
K4B. One (1) Polaroid photograph of the two original signatures authored by Mr. Mourad. This photograph was secured from the original document
K5. One (1) photograph of a NOTE dated May 9,1985. Document bears one line of handprinted letters, left lower corner, that read: AM
K5A. One (1) photocopy of the second page of the NOTE bearing three lines of
handwritten/handprinted words and letters. Above the typewritten name-Alphonse Mourad is the known signature of Alphonse Mourad. The true signature of Mr. Mourad appears three times in this document
Q1. Ore (1) photocopy of a NOTE dated March 29,1985. Document does not
bear any handprinted initials or any other handwritten/handprinted words, letters or numerals.
Q1A. Ore (1) photocopy of the second page of the NOTE. Document bears three lines of handwritten letters and words. Above the typewritten name-Alphonse Mourad is the handwritten words alleged ID be the signature of Alphonse Mourad. The alleged handwritten words/signature appears three times i n this document
Q1 B. One (1 ) Polaroid photograph of the first alleged signature. This photograph was secured from the original document
QIC One (1) Polaroid photograph of the two unidentified witness signatures. This photograph was secured from the original document
Q1D. One (1) Polaroid photograph of the first two alleged signatures. This photo-graph was secured from the original document
- 3 -
01 E. One (1) Polaroid photograph of the first two alleged signatures. This photo-graph was secured from the original document
0.1 F. One (1) Polaroid photograph of the third alleged signature. This photograph was secured from the original document
PART II - OPINION
Using the handwritten signatures in Exhibits K1A. K1B, K2A, K2B, K3A, K3B. K4A, K4B, K5A as the standards and as the basis for comparison, it is the opinion of this Examiner, within a reasonable degree of certainty, that:
A The handwritten signatures on the questioned document, Exhibit 0,1 A, were not written or signed by the Alphonse Mourad represented by the cited standards, Exhibits K1A, K1 B, K2A, K2B. K3A, K3B, K4A, K4B, KSA.
B. There are sufficient factors of letter stroke dissimilarity i n the handwritten signatures on the questioned document. Exhibit Q1A and the cited standards to indicate they were written/signed by two different people.
PART III - BASIS FOR OPINION This opinion is based on the following Pattern Recognition Factors:
RE: PART II, A.
The style, slant and flow of the writings in the questioned document and the Alphonse Mourad standards are not the same. Further, the individual letter stroke charac-teristics, personal writing habits and idiosyncrasies, found in the Mourad exemplars, are not present in the questioned writings/signatures.
These totally differing factors, found in the questioned writings, reflect the writing habits of an individual other than the Alphonse Mourad represented by the exemplars in Exhibits K1A, K1 B, K2A, K2B, K3A, K3B, K4A, K4B, KSA.
RE: PART II,B.
There are definitive factors of letter stroke characteristics (personal writing habits and idiosyncrasies) that are present in the questioned writings but missing in the cited standards. These are specifically noted as, but not limited to, the following.
1. The handwritten capital M's.
2. The handwritten lower case a's, d's, e's, h's, I's, n's, o's, p's, r's, s's, u's.
- 4 -
These factors, found in the questioned writings/signatures and the cited standards, reflect the unconscious writing habits of two different individuals and establish the opinion cited in Part II,
B.
if court testimony is anticipated, please inform this Examiner at least four weeks prior to trial date to assure availability and to allow sufficient time for preparation.
Sincerely.

Ronald H. Rice

Licensed Investigator (Department Of State Police - License No.: 99)
Licensed/Approved Educator/Trainer in Forensic Handwriting Examination (Commonwealth Of Massachusetts Department Of Education - License No.: 961031 C)

Court Qualified/Appointed Forensic Handwriting Examiner

RHR/mm
Enclosures:

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