Re #15: If the original agreement for payment was due and payable more than 90 days before the petition
was originally filed, then the payments could be viewed as in satisfaction of an antecedent debt. The fact that the case was converted to Chapter 7 is irrelevant. The original filing date is the date from which the 90 day avoidance period runs.
Re #18: You may be able to put this matter to rest right here, by explaining that this is how you ordinarily operate your business, that your payment requests are customary in your industry, and that the transaction between yourself and the debtor was not intended to be based upon a sales commission, which was contingent on a future property lease or sale, or on the payment of money from a third party tenant or vendor.
That is, you offered to do X in exchange for Y, which is a customary agreement in your business, and the debtor paid you according to the terms of your agreement.
You could even explain that such agreements are frequently oral, rather than written.
Note that what ever you contend, the trustee will look for you to prove your position, if not now, via documentation, then at trial or summary judgment. This means you may need to hire some other persons in the industry who do the same business as you, and who will testify to the ordinary nature of your transaction.
Also, if you have other landlords
with whom you transact business similarly, and they can testify to this, then you could use those sources as witness to the ordinary nature of your business transaction. You don't need to provide sworn affidavits in your interrogatory response -- you just need to assert that it is something that you do routinely in similar transactions.
Note: I can't format your response for you. Violates website rules.
Hope this helps.