Finally, as discussed in the “Plain English Glossary of Bankruptcy Preference Terms”, the term “Transfer” is broadly defined as follows:
The term “Transfer” refers to any payment(s) made by the Debtor to the Defendant during the Applicable Period (as defined herein), including, but not limited to, any funds, property, or other value conveyed to you by check, wire transfer, debit, credit to your account, the return to you of inventory or other property, or by any other means during the Applicable Period, by the Debtor, or otherwise satisfied an obligation owed to you by the Debtor.
Requests For Admissions
1. Admit that You received each of the Transfer(s) identified by the Transfer number and the check amount listed on Exhibit “A” attached to the Complaint.
2. :•For each Transfer, admit the. Transfer was made during the Preference Period.
3. For each Transfer, admit that You had a right to receive the Transfer in satisfaction of or on account of an obligation or debt owed to You by the Debtor at the time payment was made,
4. Admit that each Transfer was for Your benefit.
5. Admit that at the time you received each Transfer You were a creditor of the Debtor.
6. Admit that each Transfer was, at the time it was made, on account of an antecedent debt owed to You by the Debtor.
7. Admit that the Debtor was insolvent at the time of each Transfer.
8. Admit that, with, respect to each Transfer, You received a greater percentage of what was owed to You (with respect to the obligation or debt underlying the Transfer) than You would have received if the Transfer had not been made and the Debtor conducted a liquidation of its business pursuant to Chapter 7 of Ti tie 11 of the United States Code.
9. Admit that, with respect to each Transfer, You did not hold a filly perfected security interest in assets of the Debtor (other than the Transfer) equal to or exceeding the amount of the Transfer that secured satisfaction of the obligation or debt on account of which the Transfer was made.
10. For each Transfer, admit that no New Value was extended to the Debtor the Transfer.
11. For each Transfer, admit that the Transfer was not intended by either You or Debtor to be the in exchange for New Value to be conveyed contemporaneously with the Transfer.
12. For each Transfer, admit that no New Value was exchanged contemporaneously subsequent to with the Transfer.
13. For each invoice or other Obligation paid by each Transfer, admit that the invoice or obligation was paid later, earlier, or in a manner otherwise inconsistent with the prior course, of business dealing between Your company and the Debtor for the period [1 year prior to the start of the preference period] through [the date of start of the preference period].
14. For each invoice or other obligation paid by each Transfer, admit that the invoice or obligation was paid later, earlier, or in a manner otherwise inconsistent with the general practices of Your industry.
15. For each invoice or other obligation paid by each Transfer, admit that the invoice or obligation was paid later, earlier, or in a manner otherwise inconsistent with the general practices of the Debtor’s industry.
16. For each invoice or obligation paid by each Transfer, admit that the invoice or obligation was not incurred by the Debtor as part of its normal business or financial affairs with You.
17. For each Transfer, admit that the Transfer was not made by the Debtor consistent with ordinary business terms.
18. If You contend that the Transfers were not made for Your benefit, admit that the Transfers were for the benefit of another creditor.
19. Admit that with respect to each of the Transfers on Exhibit A to the Complaint that each of the elements of 11 USC 547(b) other than the insolvency element is satisfied.