Marlene Fearing, CEO and Officer of

Inglewood Womans Club

1343 E. Stoney Canyon Circle
Oro Valley, AZ 85737
Phone: 952-451-2204
Email: mfear5741@aol.com

IN THE UNITED STATES BANKRUPTCY

FOR THE DISTRICT OF ARIZONA
Proceedings Under Chapter 11
In Re:
Case No. 4:15-BK-04005-SHG
INGLEWOOD WOMANS CLUB
INC.
Debtor
_______________________________

)
)
)
)

MARLENE FEARING, CEO AND

OFFICER OF INGLEWOOD WOMANS
CLUB, INC. and LARGEST CREDITOR
FILES THIS ADVERSARY COMPLAINT
AND REQUEST FOR INVESTIGATION
AND ORDER FOR PROTECTION

PLEASE TAKE NOTICE that Marlene Fearing, the largest creditor, CEO and Officer of the
Inglewood Womans Club (the Club) hereby files an Adversarial Complaint Pursuant to
Bankruptcy Rule 7001 and 7003, to discharge an illegal claim achieved through theft by fraud,
deceit and collusion (Claim filed by Cunningham and Pacheco on behalf of Stoney Canyon
Homeowners Association (HOA). An investigation for theft by fraud is necessary.
1. The reorganizational plan cannot be completed by attorneys for the Club until a
determination is made by the court as to the criminal complaint alleged by largest creditor and
CEO of the Club. Can a claim achieved by a theft by fraud upon the State court be legally
presented fraudulently before a bankruptcy court for collection? This is the case with the
Pacheco claim upon the bankruptcy court for its legal fees and HOA judgment against the
Inglewood Womans Club.
2. In the Initial filing for Bankruptcy Protection under Chapter 11, it was immediately
disclosed to Snell and Willmer and the court that the Club was a victim of theft by fraud which
1

necessitated the need to file for Bankruptcy to save the last remaining asset (which was to serve
as a convalescing retreat for veterans) the house at 1343 E. Stoney Canyon Circle, Oro Valley,
AZ 85737 (Attached Statement of Marlene Fearing)
3. There was no follow up by our legal counsel, Snell and Willmer to not only object to the
outrageous fees charged by the law firm of Cunningham, Pacheco, but to ascertain the validity of
the judgment and subsequent sheriff sale. The Club was never notified of any judgment,
foreclosure or sheriff sale. The Club hired Barry Rorex to defend the HOAs claims. Instead of
defending the Club, Mr. Rorex joined Mr. Pacheco in a scheme to steal the asset that he was paid
to protect. Mr. Pacheco made no showing at the creditors meeting for obvious reasons. He didnt
want to answer any questions i.e., A. How he obtained his fraudulent and bogus judgment in the
first place with the aid of the Clubs attorney Barry Rorex? Subjecting himself to answering
such questions may have gleaned sufficient information to have his bogus claim discharged
completely. B. Why he chose to obstruct the sale on the property when he could have received
all of the $43,000 in attorney fees and HOA fees? The why is because collecting only the
$43,000 in attorney fees was not the completed intent of the bogus and fraudulent claims. The
ultimate intent was to steal the entire property valued close to $185,000. This is the kind of scam
that has been perpetrated against the Club from the very onset of the discovery of a $550,000.
bank account in its name. The HOA fees were approximately $3,000 and our supposed attorney
(Barry Rorex) indicated that we had a legal offset of $8,500 for damages due to HOA refusal to
provide services and honor the CCRs of the HOA.
4. The court must look at the entire picture as to what has transpired here.
The theft of the Clubs money was achieved in part by the organized conspiracy to rid Fearing of
all assets, even if they werent all her assets. Most of the money that Fearing used to fund the
Club (after the bank account was stolen) was money she had borrowed. The borrowed money
was used to fix the house and defend the lawsuit in California. All of the money belonging to
our veterans $550,000.00 has thus far been used to feed dishonest attorneys as was the case
in Minnesota, California, and now Arizona using the same modus operandi illegal court
proceedings to sanitize criminal activity. (Attached is Affidavit of Marlene Fearing and
attached exhibits fully explaining the background of the club).
2

5. The Club is an innocent party being victimized by those who are targeting Marlene
Fearing for her blowing the whistle on crimes being perpetrated by individuals working for the
government. The fact that these crimes took place several years ago as outlined in (The
documentary Marlenas Journal Telling it like it is in Minnesota not so nice) tells the story of
how these crimes were committed against people of color and Fearings efforts to uphold Fair
Housing laws as mandated by her Real Estate and General Contractor licenses. This is an
ongoing conspiracy with no end in sight so long as Fearing continues to breathe and blow her
whistle on corruption.
IMPORTANT FACTS: The issue here is not how the government failed, but rather how
efforts to enforce the laws were thwarted by a politician intoxicated by power and greed.
Both Minnesota Human Rights and the Department of Justice in D.C. did their due
diligence in investigating the claims of gender and racial discrimination. The Cities were
found to be guilty of both gender and racial discrimination. Cities funds were already
frozen pending prosecution by both Minnesota and the U.S. Justice Department in D.C.
Since this occurred in Minnesota, the most obvious choice of prosecutor would be by
Minnesota. The enforcement problem was this, the master puppeteer of the criminal
conduct was legal counsel for both cities (league of cities law firm, of Greene Espel of which
Andrew Luger was partner. As legal counsel, Andrew Luger knew that he was conspiring to
cover these crimes through perjury, destruction or fabrication and altering of court
documents and in general obstruction of justice. Mr. Luger was subsequently appointed to
Minnesota Assistant U. S. Attorney and then appointed as The Minnesota U. S. Attorney.
Mr. Luger chose to cover up his conduct by closing the file on both cases and cover up the
massive tort liabilities that Fearing and other victimized individuals were entitled to due to
his criminal conduct. Mr. Luger was not acting as a man of law, but rather as a criminal
who should be prosecuted for his corruption.
The vindictive and arbitrary assaults on Fearing only escalated because of her refusal to go
away silently. The lawsuits against Fearing did not end. At the time of the writing of
Marlenas Journal, Fearing still had approximately $1,000,000 in land. All of that was
taken from her in the same process as all the rest of her millions in assets through bogus
claims filed in courts without any notice or due process for Fearing. Judgments against her
were arbitrarily assessed and the remainder of the land was also taken in much the same
way using the courts in Minnesota to facilitate the thefts of her land.
Fearing was a marked woman and blackballed no matter where she went. Fearing
should have been protected by Whistle blower protection law, but the opposite took
place. Fearing was followed and had constant surveillance in every aspect of her life,
personal and business. There is only one person who had that kind of motive and
unchecked power . Mr. Minnesota who used his position for a personal vendetta to
destroy Fearing and anything and everything that was associated with her. His portrayal of
Fearing is of an unsavory, evil, vile and crazy person. However, it is Fearings contention
3

that he is merely describing himself. And since he is the power Fearing has no chance of
any fairness or equity because the well is already poisoned by Mr. Minnesota before
Fearing has any opportunity to give testimony. That was true in California, Minnesota and
now Arizona. Fearing at this point is fearful for her life as stalking and harassment has
escalated recently. There seems to be no boundaries or end to his madness and Fearing
considers him to be a very dangerous and psychotic individual. Clearly, only a madman
would do things like this? It is not possible to make this stuff up as evidence is compelling
by witnesses who observed this behavior as well as documented evidence. The deeds of Mr.
Minnesota are more fully outlined in Fearings new almost completed second documentary
which exposes all of his criminal conduct with impunity for the past 15 years.
6. The underlying related cases (explained in Affidavit of Marlene Fearing) are an important
part of what led to this bankruptcy, in an attempt by Fearing to protect the innocent party (the
Club). The intended target here is Fearing due to her blowing the whistle on criminal activity by
a very high powerful and high ranking government authority in Minnesota. The fact that he
requested that the bankruptcy trustee tag this file is added proof of his unclean hands.
To see the Truth, sometimes TITLES and POSITIONS must be set aside and the conduct of the
individual scrutinized. Fearing has been subjected to such scrutiny for 15 years, investigated and
reinvestigated in search of any wrong-doing to cast a doubt or shadow on her integrity and to no
avail. Its time now to investigate the investigator!
ACTION BY THE BANKRUPTCY COURT REQUESTED BY MARLENE FEARING
1. Call for an independent investigation of the above described matters. These are federal
crimes. (Attached letter to Trustee requesting such investigation dated July 16, 2015)
2. Vacate the questionable attorney fees of Pacheco.
3. There is compelling evidence to suggest that Mr. Minnesota also orchestrated an
embezzlement of the Clubs funds through bank withdrawals and tax fraud.
4. Issue a protection order for Fearing.
When the above is adjudicated by the Court, the Clubs attorney will file a reorganization plan.
The criminal aspect of this case must be bifurcated before any reorganization of the Club can
proceed.
Respectfully submitted,

August 5, 2015

Marlene Fearing
Creditor of Inglewood Womans Club
CEO of Inglewood Womans Club