Draycott Industrial Supply LLC · business dispute
5. Related party transaction analysis
Over the twenty-four months in dispute the operating account paid $1,466,000.00 across sixteen wires to two payees, Halbrook Logistics LLC and Wexley Freight Co. Each of the sixteen wires names the same receiving account, ····2245. Four years of records name both payees only in these wires.
Four of the sixteen wires
| Date | From | To | Amount | Cited |
|---|---|---|---|---|
| 14 Apr 2023 | Operating ····4180 | Halbrook Logistics ····2245 | $96,000.00 | |
| 9 Nov 2023 | Operating ····4180 | Wexley Freight ····2245 | $84,000.00 | |
| 28 Jun 2024 | Operating ····4180 | Halbrook Logistics ····2245 | $124,000.00 | |
| 17 Jan 2025 | Operating ····4180 | Wexley Freight ····2245 | $108,000.00 |
Two payees, one receiving account. Sixteen wires to two payees name the same account, and the records name each payee only in those wires (····4180.pdf, p. 214).
Payments to suppliers over the same period total $1,610,000.00 across 915 payments to 116 recipients. Each of the twelve largest is named in the accounts before the period in dispute begins.
8. Transfer pattern analysis
The sixteen wires run at roughly one a quarter, at amounts between $84,000.00 and $124,000.00. Each clears within four business days of a customer deposit of a similar size into the operating account.
The earliest payment to either payee is the wire of 14 April 2023, three weeks after the supply agreement at issue was signed. The largest, $124,000.00 on 28 June 2024, is the largest payment out of the operating account in its month.
12. Conclusion and recommendations
The wires set out in sections 5 and 8 are listed with the statement page each was read from, so counsel can put them to the officers who authorised them.
Recommended next steps. Subpoena the records of the receiving account ····2245, including its opening documents, which would show who holds the account both payees are paid into.
Request the invoices and bills of lading behind the sixteen wires, $1,466,000.00 in all, so each payment can be set against a shipment the company received.
Set the customer deposit that precedes each wire against the receivables ledger for the same quarter. The operating account shows each deposit and the page it prints on.
The coverage summary lists every monthly cycle of the operating account ····4180 held in the production, so the twenty-four months in dispute can be read against the statements behind them.