That leaves § 1336.05. Under this provision, a transfer constitutes a constructive fraudulent transfer with respect to the Debtor’s existing creditors (such as her medical providers) if it was made — as the Transfer was — for less than reasonably equivalent value, and if the debtor was insolvent at the time of the transfer or became insolvent as a result of the transfer. A crucial issue, therefore, is which party bears the burden of proof on the insolvency issue under Ohio law. Consistent with the general rule that the plaintiff bears the burden of proof on the elements of a cause of action, many courts in this district, including this Court, have held that the trustee bears the burden of proving the debtor’s insolvency at the time of the transfer. See Canyon Sys., 343 B.R. at 647 (<HOLDING>); Kovacs v. Berger (In re Berger), 2007 WL
holding that the government bears the burden of proof with respect to the issue of whether termination for default was justified holding that the trustee bears the burden of proof with respect to the issue of insolvency under ohio law holding that the defendant bears the burden under plainerror review holding that the plaintiff bears the burden of proof for all elements of section 523a15 holding that the defendant bears the burden of proof and that such a disposition does not violate the due process clause