receiving a reasonably equivalent value in exchange for the transfer or obligation and the debtor was insolvent at that time or the debtor became insolvent as a result of the transfer or obligation. (b) A transfer made by a debtor is fraudulent as to a creditor whose claim arose before the transfer was made if the transfer was made to an insider for an antecedent debt, the debtor was insolvent at that time, and the insider had reasonable cause to believe that the debtor was insolvent. 2 . Mass. Gen. Laws, Ch. 109A, § 5(a) provides: (a) A transfer made or obligation incurred by a debtor is fraudulent as to a creditor, whether the creditor's claim arose before or after the transfer was made or the obligation was incurred, if the deb m Beach, Inc., 833 F.2d 1484, 1487 (11th Cir.1987) (<HOLDING>); Morgan v. Kanak (In re Kanak), 85 B.R. 483,
holding that evidence which is relevant to a pleaded issue as well as an unpleaded issue does not give opposing party adequate notice that the unpleaded issue is entering the case holding that an issue is waived when a party fails to provide adequate citation to authority holding that implied consent is not established merely one party introduced evidence relevant to an unpleaded issue and the opposing party failed to object holding a prior case was not precedent on an issue when the issue was not contested holding that issue in motion for rehearing is waived if original brief is not sufficient to acquaint the court with the issue and does not present an argument that would allow the court to decide the issue