Robert W. Hunt, a medical corporation

I. Facts and Summary of Pleadings

Robert W. Hunt, a medical corporation (the “Debtor”) filed a voluntary Chapter 11 petition on November 23, 2011. The case was converted to Chapter 7 on July 24, 2012. The Debtor was in the business of operating a workers’ compensation medical clinic (the “Business”). Upon Dr. Hunt’s death, his widow, Peli Popovich Hunt (“Ms. Hunt”), operated the Business only for the purpose of collecting accounts receivable from previously provided medical services.

A. Claim No. 9-1, Asserted by the Robert and Peli Hunt Revocable Trust On November 27, 2012, the Robert and Peli Hunt Revocable Trust (the “Trust”) filed Proof of Claim No. 9-1 (“Claim 9”). The Trust asserts an unsecured priority claim for “receivables estimated well in excess of $1,000,000.00.”2 The Trust asserts that Claim 9 is entitled to priority pursuant to § 507(a)(3).

B. The Trustee’s Adversary Proceeding Against Ms. Hunt, in Her Personal Capacity and In Her Capacity as Trustee of the Trust On August 2, 2012, the Trustee filed a complaint against Ms. Hunt (the “Complaint”),4 in her personal capacity and in her capacity as Trustee of the Trust. The Complaint sought injunctive relief,…