24 Jane Doe v, Epstein Case No. 08-CV-80893-Mraragohnson Epstein's Memorandum of Law in Opposition to Jane Doe's Injunction Motion Page 21 of 24 Smart. Inc., 381 B.R. 359, 382 (M.D. Fla. 2007) (holding that bankruptcy trustee failed to establish a fraudulent transfer claim as the trustee failed to establ