Trustee for Ponzi scheme debtors asserted fraudulent transfer claims, pursuant to 11 U.S.C. § 548 and 544(b), against defendant, an attorney who acted as debtors' coordinating counsel with respect to numerous lawsuits filed against debtors across the country. Defendant argued that he was essentially a conduit from debtors to local counsel, and that he should not be accountable for money he did not retain. After a trial, the bankruptcy court concluded that defendant had failed to account properly for more than $350,000 of funds that had been transferred to him by debtors, and granted trustee a judgment for that amount. The district court agreed with the bankruptcy court's conclusion that trustee had established that debtors had transferred funds to defendant during the one-year period prior to debtors' bankruptcy filing, and that debtors were insolvent at the time of those transfers. The district court rejected defendant's argument that trustee had failed to meet his burden of proving that debtors received less than reasonably equivalent value for those transfers, on the ground that trustee testified that his investigation found no evidence at all of consideration received by debtors, which placed the duty on defendant to produce evidence of value returned to debtors. As defendant's accounting practices were grossly inadequate, he failed to establish that debtors had received value in return for the transfers made to him. However, the district court ruled that the bankruptcy court had failed to credit defendant with a few transfers that were adequately tied to legal services provided to debtors, totaling approximately $37,000, and affirmed the judgment less that amount.