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the bankruptcy code gives bankruptcy trustees the power to recover fraudulently transferred property this power helps ensure that creditors are treated fairly and have access to all the bankruptcy estate's property however the trustee's ability to recover fraudulent transfers can be limited depending on the status of the recipient in the case of enray video Depot the 9th circuit considered the trustee's power to recover transferred property from an initial transferee Jeffrey Arlen was the president of video Depot and controlled all the company's operations Arlen also enjoyed gambling in the late 1980s Arlen visited the Las Vegas Hilton roughly 60 times during this period Arlen gambled responsibly he used only his money or Hilton's credit line and always repaid his losses in full occasionally Arlen carried a balance but it was always lower than his credit limit unfortunately things took a turn in May of 1990. Arlen incurred a 225 thousand dollar d

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