Adversary Complaint — Donald Lassman, Trustee v. Bottom Line Concepts, LLC (District of Massachusetts)

Summary

An adversary complaint filed October 30, 2025, by Donald Lassman, Chapter 7 trustee of ATW Line Painting, LLC, against Bottom Line Concepts, LLC, doing business as Bottom Line Savings, in the U.S. Bankruptcy Court for the District of Massachusetts, Case 25-01153, in Case No. 23-11607-CJP. It states that an involuntary Chapter 7 petition was filed against the debtor on September 29, 2023, and that the debtor paid the defendant $22,605.60 on September 27, 2023. The trustee alleges the payment was a preferential transfer under 11 U.S.C. § 547(b) and seeks a judgment for $22,605.60 plus interest under § 550 of the Bankruptcy Code. Jonathan M. Horne of Murtha Cullina LLP signs /s/ for the trustee.

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“Adversary Complaint — Donald Lassman, Trustee v. Bottom Line Concepts, LLC (District of Massachusetts).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/1-complaint-lassman-v-bottom-line-concepts-b43422f45d/, SHA-256 ea0d4135af163415aa9952085cfba70d1ccefd01e1440d865fc082eeee0f6b7b.

Full text

Case 25-01153 Doc 1 Filed 10/30/25 Entered 10/30/25 13:27:48 Desc Main
Document Page 1 of 4

UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF MASSACHUSETTS
EASTERN DIVISION

In re:

ATW LINE PAINTING, LLC, CHAPTER 7

CASE NO. 23-11607-CJP
Debtors.

DONALD LASSMAN, CHAPTER 7 TRUSTEE OF
THE BANKRUPTCY ESTATE OF ATW LINE
PAINTING, LLC,

Plaintiff, ADV. PROC. NO. ____________

BOTTOM LINE CONCEPTS, LLC, dba BOTTOM
LINE SAVINGS,

Defendant.

ADVERSARY COMPLAINT

PARTIES

1. Donald Lassman (the “Trustee”) is the Chapter 7 of the bankruptcy estate of ATW

Line Painting, LLC (the “Debtor”), and maintains the right to bring and prosecute all actions

against the Defendant pursuant to §§ 547 and 550 of the Bankruptcy Code.

2. The Defendant, Bottom Line Concepts, LLC dba Bottom Line Savings (the

“Defendant”), is a Florida limited liability company with a principal place of business located at

3323 NE 163rd Street, Suite 302, North Miami, FL 33160, and a registered agent address of Bryn

Law Group, 2 South Biscayne Blvd, Suite 2600, Miami, FL 33131.

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JURISDICTION AND VENUE

3. The Trustee brings this adversary proceeding pursuant to Sections 547 and 550 of

the United States Bankruptcy Code, 11 U.S.C. §§ 101-1330, and Rule 7001 of the Federal Rules

of Bankruptcy Procedure.

4. This Court has jurisdiction over this adversary proceeding pursuant to 28 U.S.C. §§

157(a), 157(b)(1) and 1334(b). This adversary proceeding is a core proceeding pursuant to

28 U.S.C. § 157(b)(2)(F)

5. Venue in this District is proper pursuant to 28 U.S.C. § 1409(a) because this

proceeding arises under title 11.

GENERAL ALLEGATIONS

6. On September 29, 2023 (the “Petition Date”), an involuntary petition under Chapter

7 of the Bankruptcy Code was filed against the Debtor.

7. On October 31, 2023, an Order for Relief under Chapter 7 of the Bankruptcy Code

was entered against the Debtor.

8. On November 1, 2023, the Trustee was appointed as the Chapter 7 trustee of the

Debtor’s bankruptcy estate.

9. The Debtor’s financial records indicate that within ninety (90) days before the

Petition Date (the "Preference Period"), the Debtor made a payment to the Defendant on September

27, 2023, in the amount of $22,605.60 (the “Preference Payment”).

10. On October 8, 2025, the Trustee sent a demand (the “Demand Letter”) to the

Defendant requesting the Preference Payment either be returned, or in the alternative, that the

Defendant advise the Trustee of any defenses it claimed.

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11. Based on the Trustee’s review of the Debtor’s financial information, proofs of claim

filed against the Debtor and other documents and information available to the Trustee and his

accountants, the Trustee does not believe that the Defendant has any defenses to the avoidance and

recovery of the Preference Payment by the Trustee.

COUNT I
(Avoidance and Recovery of the Preference Payment)

12. The Trustee incorporates by reference each and every allegation set forth above as

if fully recited herein.

13. The Preference Payment constitutes a transfer of an interest of the Debtor in

property.

14. The Preference Payment was made to or for the benefit of the Defendant.

15. The Preference Payment was made for or on account of an antecedent debt owed

by the Debtor to the Defendant before such payment was made.

16. The Preference Payment was made within ninety (90) days before the Petition Date.

17. The Preference Payment was made while the Debtor was insolvent.

18. The Preference Payment enabled the Defendant to receive more than it would have

received in a case under Chapter 7 of the Bankruptcy Code if the Preference Payment had not been

made, and the Defendant received payment of such debt to the extent provided by the provisions

of the Bankruptcy Code.

19. Prior to bringing this action the Trustee conducted reasonable due diligence and

took into account the Defendant’s known or reasonably knowable affirmative defenses.

20. The Defendant was the initial transferee of the Preference Payment and the entity

for whose benefit the Preference Payment was made.

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21. The Preference Payment constitutes a preferential transfer of property within the

meaning of 11 U.S.C. § 547(b).

WHEREFORE, the Trustee respectfully requests that this Court enter judgment against

the Defendant:

a. Avoiding the Preference Payment as a preferential transfer under § 547(b) of the
Bankruptcy Code;

b. Awarding the Trustee judgment against the Defendant, under § 550 of the
Bankruptcy Code, in the amount of $22,605.60, plus statutory interest thereon;

c. Awarding the Trustee his costs and expenses incurred in prosecuting this adversary
proceeding, including without limitation, reasonable attorneys' fees and costs; and

d. Granting the Trustee such other and further relief as the Court deems just and
proper.

Respectfully submitted,

DONALD LASSMAN, TRUSTEE OF THE
BANKRUPTCY ESTATE OF ATW LINE
PAINTING, LLC,

By his attorneys,

/s/ Jonathan M. Horne
Jonathan M. Horne, Esq. BBO #673098
Murtha Cullina LLP
33 Arch Street, 12th Floor
Boston, MA 02110
617-457-4000 Telephone
617-482-3868 Facsimile
jhorne@murthalaw.com
Dated: October 30, 2025

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