Marrama v. Citizens Bank. The bank filed a complaint to deny Marrama his Chapter 7 discharge because he transferred property within 1 year prior to filing bankruptcy, thereby invoking Section 727(a)(2)(A) of the Bankruptcy Code. During the Trial, Marrama invoked his Fifth Amendment privilege against self-incrimination to avoid testifying. The Court drew a negative inference against Marrama as a result of his refusal to testify, concluding that he defrauded creditors by making the transfers. The First Circuit affirmed the Bankruptcy Court's decision to deny Marrama his discharge.