holders, and suggested that they were institutional creditors as well. See Ex. 22, ¶ 6; Ex. 27, ¶ 3. 21 . Rule 404(b) of the Federal Rules of Evidence provides that evidence of prior crimes, wrongs or acts is admissible to prove "motive, opportunity, intent, preparation, plan, knowledge, identity, or absence of mistake or accident” but not to prove a defendant’s character in order to show he acted in conformity with the charged offense. Fed.R.Evid. 404(b). 22 . See Tr. 60-61 (AUSA: "[John Gellene is] going to tell you that he didn't knowingly deceive anybody, that wasn't his intention at all”); Tr. 1087 (Counsel for Gellene to the court: "[T]he issue in this case is the defendant’s state of mind.”). 23 . See, e.g., Morganroth & Morganroth v. DeLorean, 123 F.3d 374, 379 (6th Cir.1997) (<HOLDING>); Federal Deposit Ins. Corp. v. Fidelity &
holding that evidence that defendant plaintiffs former client consistently failed to pay other lawyers was relevant to prove the element of intent to defraud holding other acts evidence that was permissible to demonstrate a plan to defraud was also admissible to establish intent knowledge and absence of mistake holding that an attorney may only undertake to represent a new client against a former client  where there is no confidential information received from the former client that is in any way relevant to representation of the current client holding that the rule 404b evidence admitted to prove intent was clearly relevant because intent was at issue in the trial holding that the statute requires actual intent to hinder delay or defraud creditors or the trustee constructive intent to defraud does not suffice