IN THE UNITED STATES BANKRUPTCY COURT FOR THE
SOUTHERN DISTRICT OF TEXAS
HOUSTON DIVISION

WILLIAM WEST, CHAPTER 7 TRUSTEE AND HEA CLINIC, P.A.'S 
COMPLAINT SEEKING DENIAL OF DISCHARGE

TO THE HONORABLE WILLIAM GREENDYKE,
UNITED STATES BANKRUPTCY JUDGE:

        COME NOW, William West, Chapter 7 Trustee ("Trustee") and HEA Clinic, P.A. ("HEA") and files this Complaint Seeking Denial of Discharge of Debtor Jack Holladay ("Debtor") and in support thereof would show as follows:

I.
PARTIES

        1.    Debtor is an individual debtor who initiated this proceeding by filing a voluntary Chapter 7 petition on March 25, 2003.

        2.    William West is the duly appointed, acting Chapter 7 Trustee in this case.

        3.    HEA is a professional association with its principal place of business in Houston, Harris County, Texas.

        4.    HEA, a creditor and party in interest in this proceeding, is Debtor's sole unsecured creditor. Debtor owes HEA approximately $750,000 pursuant to a judgment entered against Debtor in favor of HEA on March 12, 2003.

II.
JURISDICTION AND VENUE

        5.    This Court has jurisdiction over this matter pursuant to 11 U.S.C. §1334 and 28 U.S.C. § 157(b)(2)(B). This matter is a core proceeding under 28 U.S.C. § 157(b)(2)(I) and (J).  Venue is proper under 28 U.S.C. § 1409(a).

        6.    This matter is properly brought as an adversary proceeding under Fed. R. Bankr. P. 7001(4) and (6).