09/17/2026
THE BANKRUPTCY COURT LACKS JURISDICTION THREE YEARS OF PHYSICAL POSSESSION WITHOUT LEGAL AUTHORITY OR JURISDICTION
The entire jurisdictional and legal edifice constructed by the Trustee, the UST, and their counsel rests on a single foundational premise: that Noreen Connolly held a 100% ownership interest in Dapan Investments, LLC, a multi-member LLC, as of the Petition Date of July 13, 2022. Because that premise fails, as the broken chain of title clearly demonstrates, every action taken in reliance on that premise is void for want of jurisdiction, standing, or lawful authority.
THOMAS JACQUES → ANDREW WELLWERTS → NOREEN CONNOLLY
Neither required mandatory link had been established when possession was taken:
Jacques → Wellwerts: The document submitted by the trustee does not contain Noreen’s signature, contains an incomplete notary section, references requirements of an operating agreement that was never produced, and does not establish a completed transfer of Jacques’s documented 50% membership interest.
Wellwerts → Connolly: The divorce decree required additional deeds, assignments, bills of sale, and other instruments to give effect to its provisions. Those transfer documents were not produced, and Thomas Jacques was not a party to the divorce.
Jacques never legally transferred his interest to Andrew, Andrew then had nothing to transfer to Noreen. Andrew never completed the instruments required by the divorce decree, the second transfer was also incomplete. Accordingly, as of the July 13, 2022 petition date and certainly as of July 11, 2023 the documents did not establish that Noreen held a 100% ownership interest in Dapan Investments, LLC.
