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Full title: Adversary case 2:21-ap-01019. Complaint by Elissa Miller against ABIR COHEN TREYZON SALO, LLP, a California limited liability partnership, Boris Treyzon Esq. ($350.00 Fee Charge To Estate). Nature of Suit: (91 (Declaratory judgment)),(11 (Recovery of money/property - 542 turnover of property)),(02 (Other (e.g. other actions that would have been brought in state court if unrelated to bankruptcy))) (Andrassy, Kyra) (Entered: 01/25/2021)

Document posted on Jan 24, 2021 in the bankruptcy, 35 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

As a result of this conduct, ACTS and Treyzon have intentionally interfered4 with the Debtor's contractual relations and should be held liable for the damages resultin5 from their conduct and enjoined from any further similar conduct with the Southern 6 California Gas Leak Litigation or any of the other cases in which the Debtor is counsel.Pursuant to 11 U.S.C. § 542(a), the Trustee seeks a judgment requiring 18 ACTS and Treyzon and each of their agents and employees to turnover to the Trustee al19 copies of the Client List and any other list of clients of the Debtor and, after this turnover,20 to destroy all written and electronic copies of the Client List and any other lists of the 21 Debtor's clients that remain in their possession.For a judgment finding that ACTS and Treyzon have violated the automatic27 stay by utilizing the Client List to solicit the Debtor's clients with the intention of interferin 1 entitled in the Southern California Gas Leak Litigation and awarding the Trustee fees an2 costs, actual damages, and sanctions for the violation of the automatic stay and 3 injunctive relief; 4 On the Second Claim for Relief 5 2.Declaring that pending further Court order, the Debtor and Frantz remain 20 the counsel of record in the Southern California Gas Leak Litigation with respect to all of 21 the Gas Leak Clients and that any retainer agreements with ACTS signed by the Gas 22 James Frantz EXHIBIT "3" rom: John Shaffer ent: Saturday, January 23, 2021 4:32 PM o: 'btreyzon@actslaw.com'; 'rfinnerty@actslaw.com' c: 'Miller, Elissa D.'; 'Lei Lei Wang Ekvall'; Kenneth Chiate; Eric Winston; 'James Frantz'ubject: RE: Southern California Gas Leak Litigation lease see the following correspondence from the Chapter 7 Trustee of the Girardi Keese bankruptcy estate and Frantz aw Group: ear Mr. Treyzon, Mr. Finnerty, and all ACTS Personnel: he Frantz Law Group and Elissa D. Miller, the Chapter 7 Trustee of Girardi Keese, are writing as a follow up to our letterated January 22, 2021.

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1 SMILEY WANG-EKVALL, LLP Lei Lei Wang Ekvall, State Bar No. 163047 2 lekvall@swelawfirm.com Philip E. Strok, State Bar No. 169296 3 pstrok@swelawfirm.com Kyra E. Andrassy, State Bar No. 207959 4 kandrassy@swelawfirm.com Timothy W. Evanston, State Bar No. 319342 5 tevanston@swelawfirm.com 3200 Park Center Drive, Suite 250 6 Costa Mesa, California 92626 Telephone: 714 445-1000 7 Facsimile: 714 445-1002 8 Proposed Attorneys for Elissa D. Miller, Chapter 7 Trustee 9 UNITED STATES BANKRUPTCY COURT 10 CENTRAL DISTRICT OF CALIFORNIA 11 02 LOS ANGELES DIVISION 0 ornia 92626 ax 714 445-1 1123 I GnI RreA RDI KEESE, C Cahsaep tNero 7. 2:20-bk-21022-BR a, Calif00 • F 14 Debtor. Adv No. ____ s0 15 e1 a M45- COMPLAINT FOR: ost4 4 16 ELISSA D. MILLER, Chapter 7 Trustee for C1 7 the bankruptcy estate of Girardi Keese, (1) VIOLATION OF THE AUTOMATIC Tel 17 STAY UNDER 11 U.S.C. § 362; Plaintiff, 18 (2) TURNOVER OF PROPERTY OF THE v. ESTATE UNDER 11 U.S.C. § 542; 19 ABIR COHEN TREYZON SALO, LLP, a (3) INTENTIONAL INTERFERENCE 20 California limited liability partnership; and WITH PROSPECTIVE ECONOMIC BORIS TREYZON, an individual, ADVANTAGE; 21 Defendants. (4) INTENTIONAL INTERFERENCE 22 WITH CONTRACTUAL RELATIONS; 23 (5) DECLARATORY RELIEF; AND 24 (6) AVOIDANCE OF UNAUTHORIZED POSTPETITION TRANSFERS UNDER 11 25 U.S.C. § 549(a) 26 27

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1 Plaintiff Elissa D. Miller, solely in her capacity as the chapter 7 trustee (The 2 "Trustee") for the bankruptcy estate of Girardi Keese, alleges the following based on 3 information and belief: 4 JURISDICTION AND VENUE 5 1. The Bankruptcy Court (the "Court") has jurisdiction over this adversary 6 proceeding under 28 U.S.C. §§ 157(b)(1) and 1334 and the Trustee consents to entry of 7 a final judgment in this matter by the Bankruptcy Court. 8 2. This proceeding is a core proceeding under 28 U.S.C. § 157(b)(2)(A), (E), 9 (H), and (O). 10 3. Venue properly lies in this judicial district because this proceeding arises in11 and relates to a case pending in this district under title 11 of the United States Code as 2 0 0 ornia 92626 ax 714 445-1 1123 provide4d. for inT h2i8s Uad.Sv.eCrs. a§r y1 4p0r9o(cae)e. ding arises out of and is related to the bankruptcy a, Calif00 • F 14 case of Girardi Keese (the "Debtor"), Case No. 2:20-bk-21022-BR. s0 15 e1 M5- a 4 ost4 4 16 STATEMENT OF STANDING C1 7 Tel 17 5. The Trustee has standing to bring this action pursuant to 11 U.S.C. §§ 323,18 362, 541, and 542 and applicable California law. 19 20 PARTIES TO THE ACTION 21 6. The Trustee is the duly appointed chapter 7 trustee for the Debtor's 22 bankruptcy estate. 23 7. Defendant Abir Cohen Treyzon Salo, LLP ("ACTS"), is a California limited 24 liability partnership with its principal place of business in Encino, California. 25 8. Defendant Boris Treyzon is an attorney licensed to practice law in the Stat26 of California and on information and belief is alleged to be a partner of ACTS. 27

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1 GENERAL ALLEGATIONS 2 9. The Debtor is a plaintiff's law firm based in Los Angeles, California, which 3 specialized in representing clients in mass tort and other contingency litigation. On 4 December 18, 2020, petitioning creditors Jill O'Callahan, as successor in interest to 5 James O'Callahan, Robert M. Keese, John Abassian, Erika Saldana, Virginia Antonio, 6 and Kimberly Archie (collectively, the "Petitioning Creditors") filed an involuntary chapter 7 7 bankruptcy petition against the Debtor (the "Petition Date"). 8 10. On December 24, 2020, the Petitioning Creditors filed a Motion for 9 Appointment of Interim Trustee Pursuant to 11 U.S.C. § 303(g). The Court entered an 10 order granting the motion on January 5, 2021. On January 6, 2021, the Trustee was 11 appointed as the interim trustee. 2 0 0 ornia 92626 ax 714 445-1 1123 of Cour1t1 t.o ImOmne dJiaanteulayr Ey n1t3e,r 2a0n2 O1,r dtheer fCoor uRret leienft eurnedde ar nC hOarpdteerr D7i;r e(2c)t inTgh:e ( 1U)n Titheed CStleartek sa, Calif00 • F 14 Trustee to Immediately Appoint a Chapter 7 Trustee; (3) The Debtor to File All Schedules0 15 and Related Documentation for Chapter 7 Case within Fourteen Days of the Entry of thise1 M5- a 4 ost4 4 16 Order; and (4) Vacating February 16, 2021 Status Conference. On January 13, 2021 C1 7 Tel 17 (the "Order for Relief Date"), the Clerk of Court entered an order for relief against the 18 Debtor, and the Trustee was appointed and accepted her appointment in the Debtor's 19 case. 20 12. As of the filing of the involuntary petition against the Debtor, the Debtor wa21 counsel of record for one or more plaintiffs in a significant number of cases which were 22 undertaken on a contingency fee basis. In one of these cases, the Debtor and Frantz 23 Law Group, APLC ("Frantz") jointly represented approximately 8,200 plaintiff-victims (the24 "Gas Leak Clients") asserting claims arising out of the 2015 blowout and subsequent 25 months-long gas leak in Porter Ranch, California (“Southern California Gas Leak 26 Litigation” or "Porter Ranch Litigation"), pursuant to various agreements including (i) the 27 Porter Ranch Agreement Frantz Law Group, APLC & Girardi Keese, and (ii) the Attorney

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1 13. Prior to the Petition Date, most of the Debtor's attorneys and staff had 2 resigned or moved on from the firm, so protection of the clients' rights has and continues3 to be one of the Trustee's highest concerns. Among other things, to protect the clients' 4 rights, the Trustee and her counsel initiated discussions with a number of law firms, with 5 the goal of transferring some or all of the Debtor's pending cases to competent and 6 qualified counsel pursuant to agreements in which the Debtor's estate would retain an 7 economic benefit. 8 14. In furtherance of those discussions, the Trustee entered into Nondisclosure9 Agreements with five law firms, including ACTS, who was recommended to the Trustee 10 by some of the creditors. Defendant Boris Treyzon signed the NDA on behalf of ACTS 11 on or about January 12, 2021, agreeing to use information regarding the Debtor only to 2 0 0 ornia 92626 ax 714 445-1 1123 perform1 5d.u e dFiloiglleonwcien gin h ceor ndniseccutisosnio wnisth a AnCd TnSeg' doetiasitrioen tso atankde s ouvbejer ctht eto l idtiogcautimone nmtaattitoenrs . a, Calif00 • F 14 and the Court's approval, the Trustee determined that the Southern California Gas Leak s0 15 Litigation was at a point where it did not make sense to bring in a new counsel and, e1 M5- a 4 ost4 4 16 rather, reached an agreement with Frantz under which Frantz will continue to represent C1 7 Tel 17 the Gas Leak Clients, without the Debtor serving as co-counsel, and will share 45% of 18 any recoveries, after reimbursement of certain costs, with the Debtor's bankruptcy estate19 The possibility of an agreement with Frantz, but not the terms of the settlement, became 20 public knowledge on January 20, 2021, when Frantz and the Trustee entered into and 21 filed a stipulation to continue the hearing on Frantz's motion for relief from the automatic 22 stay with regard to the Southern California Gas Leak Litigation.1 23 ACTS' Improper Solicitations on January 22 and January 24 24 16. On or about January 22, 2021, without the knowledge or consent of the 25 Trustee or Frantz and in violation of the Rules of Professional Conduct governing the 26 ethical conduct of law in California, ACTS sent an unsolicited email and/or letter marked 27 1

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1 "Personal & Confidential" and an "Attorney/Client Communication" to the Gas Leak 2 Clients. 3 17. In the letter, ACTS acknowledges that the Debtor is their counsel and then 4 notifies them that the Debtor has been the subject of involuntary bankruptcy proceedings5 and "concerning allegations." The letter further falsely and fraudulently implies that it is 6 being sent with the blessing of this Court and/or the court in which the Southern 7 California Gas Leak Litigation is pending, telling the Gas Leak Clients that "[r]ecently, our8 firm indicated to the court that we would be assisting with many of GK's Porter Ranch 9 Gas Leak cases." The letter tells the Gas Leak Clients that ACTS can assume full 10 responsibility for the case under the same fee arrangement that they had with the Debtor11 but that in order for ACTS "to continue representing you under these terms," the clients 2 0 0 ornia 92626 ax 714 445-1 1123 mfour stht es icglnie an trse ttoa incleicr ka tgor eseigmne tnhte w reittha iAnCerT aSg arese smoeonnt .a s A pt othsesi bbloet.t o Tmh eo fl ethttee rs oinliccluitadteiosn a, lina, Calif00 • F 14 under a picture of the employees of ACTS, the solicitation states that "This letter is s0 15 intended to be attorney advertising and it should not be construed as a formation of a e1 M5- a 4 ost4 4 16 lawyer/client relationship. If you are represented by other counsel, please disregard this C1 7 Tel 17 message, and unsubscribe from our mailing list." A copy of this email is attached as 18 Exhibit "1." 19 18. When ACTS and Boris Treyzon sent this communication, they were well 20 aware that the Gas Leak Clients were represented by the Debtor and Frantz and had the21 actual intention to convert the Gas Leak Clients to clients of ACTS and to retain any 22 related contingency fees for their own benefit. The Trustee is informed that 23 approximately 100 of the Gas Leak Clients have so far clicked on the link and agreed to 24 be represented by ACTS. 25 19. The Trustee took possession of the books and records that were at the 26 Debtor's location when she was appointed. The Trustee has taken possession of the 27 offices and numerous paper files contained therein and her computer specialists are in

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1 the Trustee has not located the list of the Gas Leak Clients, much less their email 2 addresses and contact information, although the Trustee is informed that this client list 3 (the "Client List") existed as of the Petition Date. This Client List and the Debtor's 4 financial interest in the Southern California Gas Leak Litigation are property of the 5 Debtor's bankruptcy estate pursuant to 11 U.S.C. § 541(a) and subject to the provisions 6 of the automatic stay as set forth in 11 U.S.C. § 362. 7 20. The Trustee is informed that ACTS came into possession of the Client List 8 at a time when the Debtor was without funds and under significant financial pressures 9 from ACTS's judgment creditor client, secured creditors, and other former clients who ha10 not received their settlement payments. The Debtor did not receive reasonably equivalen11 value for the Client List, its interest in the Southern California Gas Leak Litigation, and 2 0 0 ornia 92626 ax 714 445-1 1123 athney AinCteTrSe/sGtsK o Af gthreee Dmeebntot r( ains adneyfi noethde br epleonwd),in agt lait itgimateio wn hmeant ttehres Dpeubrptoorr twedalsy hsauvbijnegc t to a, Calif00 • F 14 difficulty meeting its obligations as they came due and/or was insolvent or rendered s0 15 insolvent as a result. e1 M5- a 4 ost4 4 16 21. On the evening of January 22, 2021, immediately upon learning of ACTS' C1 7 Tel 17 solicitation of the Gas Leak Clients, the Trustee, on behalf of the Debtor's estate, and 18 Frantz sent ACTS a cease and desist letter by email, a copy of which is attached as 19 Exhibit "2." Counsel for Frantz followed this letter up with an email from Frantz and the 20 Trustee to three ACTS attorneys, including Boris Treyzon and two others who had 21 previously worked at the Debtor, on January 23, 2021. A copy of this email is attached 22 as Exhibit "3." 23 22. Boris Treyzon responded to the letter on January 24, 2021, at 24 approximately 8:57 p.m., denying that he or ACTS had done anything wrong while failing25 to respond to the Trustee's demand for turnover of the Client List and other assets of the26 Debtor's estate. A copy of this response is attached as Exhibit "4." 27 23. Then, a few minutes later, ACTS sent out a second email blast to the Gas

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1 click here to sign our retainer agreement." A copy of this email is attached as Exhibit "5. 2 Again, the email is silent about Frantz's representation of the Gas Leak Clients. The link3 in the emails from ACTS remain active as of the filing of this Complaint. 4 The Prepetition ACTS/GK Agreement 5 24. The Trustee is informed that prior to the Petition Date, on or about 6 November 16, 2020, ACTS and the Debtor purportedly entered into an Assumption and 7 Lien Agreement (the "ACTS/GK Agreement"). In the ACTS/GK Agreement, ACTS was 8 given the opportunity to conduct due diligence on the Debtor's pending cases and to 9 determine which ones it would assume, "subject to client consents and ethical 10 compliance." ACTS was also permitted to communicate directly with any of the Debtor's11 lawyers or staff to determine whether to employ them. In exchange for this, the Debtor 2 0 0 ornia 92626 ax 714 445-1 1123 paussrpuomrtee dfolyr ognalvye a u ppr oitms eisceo tnoo bmeic r eainmdb cuorsnetrda cctousatls r aignhdts " qinu athnetu cmas mese rAuCit TcSha drgeecisd"e idf tthoe rea, Calif00 • F 14 was a recovery to pay them. To the extent that the ACTS/GK Agreement is a valid s0 15 contract, it is executory and the Trustee intends to reject it.2 In addition, even if the e1 M5- a 4 ost4 4 16 ACTS/GK Agreement was a valid agreement, if ACTS had not properly assumed C1 7 Tel 17 representation of clients as of the Petition Date, the automatic stay would bar ACTS from18 any further act that would affect the Debtor's economic interest in the pending litigation. 19 25. The Trustee is informed that the ACTS/GK Agreement was entered into 20 under duress and is an attempt by ACTS to exert pressure on the Debtor so that ACTS 21 can collect a judgment that ACTS obtained against the Debtor for one of its clients. In or22 about April 2020, ACTS obtained a judgment for approximately $11 million against the 23 Debtor on behalf of a client. In October 2020, ACTS filed a turnover action on behalf of 24 its client, which the Trustee is informed put an immense amount of pressure on the 25 26 2 The Trustee is investigating whether the ACTS/GK Agreement and any related transfer of rights in cases27 is avoidable or void as a fraudulent transfer or voidable on other grounds such as undue influence and reserves the right to either amend the complaint to add these and other causes of action or to file a

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1 Debtor. In order to stop the turnover action and under duress and undue influence, the 2 Debtor relented to ACTS and entered into the ACTS/GK Agreement without obtaining th3 consent of its clients or Frantz before doing so. Without actually assuming representatio4 and without any Gas Leak Client agreeing to substitute in ACTS, ACTS filed notices of 5 substitution and/or notices of association in the Southern California Gas Leak Litigation 6 and has refused to withdraw them. 7 26. Treyzon is readily familiar with this bankruptcy case. On December 24, 8 2020, Treyzon submitted a declaration in support of the motion to appoint an interim 9 trustee. In his declaration he admitted that the Debtor's cases belong to the Debtor and 10 that if any attorneys were substituted in, the Debtor's estate could be damaged. Yet, tha11 is precisely what ACTS and Treyzon have been doing, and thus, each is acting willfully. 2 0 0 ornia 92626 ax 714 445-1 1123 FIRST CLAIM FOR RELIEF a, Calif00 • F 14 (Violation of the Automatic Stay) es10 15 (Against ACTS and Treyzon) M5- a 4 ost4 4 16 27. Plaintiff incorporates the allegations of paragraphs 1 through 26 as though C1 7 Tel 17 fully set forth herein. 18 28. Upon the entry of the order for relief, the automatic stay of 11 U.S.C. § 36219 went into effect, preventing parties from taking any act to possess or control an asset of 20 the estate. 21 29. The Client List and the Debtor's financial interest in the contingency fee 22 arrangement for the Southern California Gas Leak Litigation are property of the Debtor's 23 bankruptcy estate. 24 30. ACTS and Treyzon are wrongfully in possession of the Client List and, 25 without the Trustee's knowledge or consent, used it after the Petition Date to solicit the 26 Gas Leak Clients in violation of the ethical rules governing lawyers in California. The 27 solicitation email that they sent on January 22, 2021, contains hyperlinks that remain

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1 ACTS and Treyzon that the communications cease and the links be deactivated. This 2 communication is an unauthorized attempt by ACTS and Treyzon to solicit the Gas Leak3 Clients under the same fee arrangement that the Gas Leak Clients had with the Debtor 4 and to retain the fees that would otherwise be paid to the Debtor for itself. The conduct i5 also part of a continued attempt by ACTS to exert pressure against the Debtor in order t6 force the Debtor to pay the judgment that ACTS obtained against the Debtor on behalf of7 one of its clients. 8 31. On January 24, 2020, after being informed by the Trustee that she considere9 the conduct of ACTS and Treyzon to violate the automatic stay and to be tortious and 10 after the Trustee requested that ACTS and Treyzon cease and desist from their conduct,11 Treyzon responded by sending a letter by email at 8:57 p.m. disagreeing with the 2 0 0 ornia 92626 ax 714 445-1 1123 Totrhuesrte aes'ss eptos soitfi othne a Dnde brteofru'ss inegst atote c.e. a Tshee ann, da dfeewsi smt iannudte tso ltautrenr ,o AvCerT tSh ea nCdli eTnret yLzisotn a snedn t a, Calif00 • F 14 second email blast to the Gas Leak Clients containing inaccurate information about the s0 15 ACTS/GK Agreement and urging them to "Simply click here to sign our retainer e1 M5- a 4 ost4 4 16 agreement." C1 7 Tel 17 32. ACTS' and Treyzon's conduct violates the automatic stay, warranting an 18 injunction, damages to the extent that the estate lost the Gas Leak Clients as a result of 19 ACTS' and Treyzon's conduct, and the imposition of sanctions and the reimbursement to20 the estate of the fees and costs it incurs as a result of ACTS' and Treyzon's conduct. 21 22 SECOND CLAIM FOR RELIEF 23 (Intentional Interference with Prospective Economic Advantage) 24 (Against ACTS and Treyzon) 25 33. Plaintiff incorporates the allegations contained in paragraphs 1 through 26 26 as though fully set forth herein. 27 34. Pursuant to the Joint Representation Agreements, the Debtor and Frantz

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1 Joint Representation Agreements entitle the Debtor and Frantz to a contingency fee 2 based on a percentage of the recoveries each Gas Leak Client is awarded and paid in 3 the Southern California Gas Leak Litigation. ACTS and Treyzon had actual knowledge 4 that the Gas Leak Clients are represented by the Debtor and Frantz and that the Debtor 5 has an economic relationship with the Gas Leak Clients; indeed, ACTS acknowledges 6 this relationship in the email that ACTS sent to the Gas Leak Clients in which ACTS 7 states that it is aware that the Gas Leak Clients are represented by the Debtor. Further, 8 ACTS signed a nondisclosure agreement with the Trustee. 9 35. ACTS and Treyzon intended to disrupt this relationship and to convert the 10 Gas Leak Clients to their own clients, as evidenced by the text of the email and the 11 hyperlinks within that email where the Gas Leak Clients can sign a retainer agreement 2 0 0 ornia 92626 ax 714 445-1 1123 wfailtshe AlyC imTSp.li e Idn tthhaet eitm haaidl, tAhCe TbSle wssrionngg ofuf ltlyh es tCaoteudr tt htoa ta ipt pwroaas cthh eth Dee Dbetobrt'so rs'su ccclieensstso.r aTnhde a, Calif00 • F 14 Trustee is informed that a number of the Gas Leak Clients have clicked on the link in thes0 15 email and signed retainer agreements with ACTS based on the wrongful statements in e1 M5- a 4 ost4 4 16 the email. The email is causing confusion among the Gas Leak Clients and leading theC1 7 Tel 17 to incorrectly believe that their interests in the Southern California Gas Leak Litigation ar18 not presently being represented as there is no mention in the e-mail of the continued 19 involvement of Frantz as their co-counsel of record. By converting the Debtor's clients to20 its own, ACTS and Treyzon are causing the estate harm by depriving the Debtor of its 21 contractual right to fees and reimbursement of costs with respect to these clients. 22 36. As a result of this conduct, ACTS and Treyzon have intentionally interfered23 with the Debtor's prospective economic advantage and should be held liable for the 24 damages resulting from their conduct and enjoined from engaging in any further similar 25 conduct with the Southern California Gas Leak Litigation or any of the other cases in 26 which the Debtor is counsel. 27 37. In addition, because the conduct of ACTS and Treyzon is willful and

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1 2 THIRD CLAIM FOR RELIEF 3 (Intentional Interference with Contractual Relations) 4 (Against both ACTS and Treyzon) 5 38. The Trustee incorporates the allegations in paragraphs 1 through 26 as 6 though fully set forth herein. 7 39. Pursuant to the Joint Representation Agreements, the Debtor and Frantz 8 are co-counsel to the Gas Leak Clients in the Southern California Gas Leak Litigation. 9 Under the Joint Representation Agreements, the Debtor and Frantz are entitled to a 10 percentage of the recoveries that they obtain in the Southern California Gas Leak 11 Litigation. ACTS and Treyzon had actual knowledge of the Debtor's contractual 2 0 0 ornia 92626 ax 714 445-1 1123 rtheela teiomnasihl itph awt iAthC tThSe Gseanst Ltoe athke C Glieanst sL.e aInkd Celeiedn, tAs CinT wS haicchkn AoCwTleSd gsetast ethsi sth raetl aitt iiosn aswhaipr ein a, Calif00 • F 14 that the Gas Leak Clients are represented by the Debtor. Further, ACTS signed a s0 15 nondisclosure agreement with the Trustee. e1 M5- a 4 ost4 4 16 40. ACTS and Treyzon intended to disrupt this relationship and to convert the C1 7 Tel 17 Gas Leak Clients to their own clients, as evidenced by the text of the email and the 18 hyperlinks within that email where the Gas Leak Clients can sign a retainer agreement 19 with ACTS. In the email, ACTS wrongfully stated that it was the Debtor's successor and 20 falsely implied that it had the blessing of a court (either this Court or the state court in 21 which the Southern California Gas Leak Litigation is pending) to make the solicitation. 22 The Trustee is informed that a number of the Gas Leak Clients have clicked on the link i23 the email and signed retainer agreements with ACTS based on the wrongful statements 24 in the email. The email is causing confusion among the Gas Leak Clients and leading 25 them to incorrectly believe that their interests in the Southern California Gas Leak 26 Litigation are no longer being represented as there is no mention that the Frantz Firm 27 remains their counsel. By converting the Debtor's clients to its own, ACTS and Treyzon

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1 are causing the estate harm by depriving the Debtor of its contractual right to fees and 2 expenses with respect to these clients. 3 41. As a result of this conduct, ACTS and Treyzon have intentionally interfered4 with the Debtor's contractual relations and should be held liable for the damages resultin5 from their conduct and enjoined from any further similar conduct with the Southern 6 California Gas Leak Litigation or any of the other cases in which the Debtor is counsel. 7 42. In addition, because the conduct of ACTS and Treyzon is willful and 8 malicious, the Trustee seeks an award of punitive damages against them. 9 10 FOURTH CLAIM FOR RELIEF 11 (TURNOVER OF PROPERTY OF THE ESTATE) 2 0 0 ornia 92626 ax 714 445-1 1123 43. The Trustee i(nAcgoarpinosrat tbeso tthh eA aCllTeSga atinodn sT oref ypzaorang) raphs 1 through 42 as a, Calif00 • F 14 though fully set forth herein. s0 15 44. The Client List is property of the Debtor's bankruptcy estate that the Trustee1 M5- a 4 ost4 4 16 is informed is in the possession of ACTS and Treyzon. C1 7 Tel 17 45. Pursuant to 11 U.S.C. § 542(a), the Trustee seeks a judgment requiring 18 ACTS and Treyzon and each of their agents and employees to turnover to the Trustee al19 copies of the Client List and any other list of clients of the Debtor and, after this turnover,20 to destroy all written and electronic copies of the Client List and any other lists of the 21 Debtor's clients that remain in their possession. 22 FIFTH CLAIM FOR RELIEF 23 (Declaratory Relief) 24 (Against ACTS and Treyzon) 25 46. The Trustee incorporates the allegations of paragraphs 1 through 26 as 26 though fully set forth herein. 27 47. A dispute has arisen between the Trustee, on one hand, and ACTS and

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1 contractual interest in the Southern California Gas Leak Litigation that requires a judicial 2 declaration. 3 48. Accordingly, the Trustee seeks a declaration that until further Court order, 4 the Debtor and Frantz remain the counsel of record in the Southern California Gas Leak 5 Litigation with respect to all of the Gas Leak Clients and that any retainer agreements 6 with ACTS signed by the Gas Leak Clients are void as a violation of the automatic stay 7 and a violation of the California Rules of Professional Conduct. 8 9 SIXTH CLAIM FOR RELIEF 10 (Avoidance of Postpetition Transfer Under 11 U.S.C. § 549) 11 (Against ACTS and Treyzon) 2 0 0 ornia 92626 ax 714 445-1 1123 herein.4 9. The Trustee incorporates paragraphs 1 through 26 as though fully set fortha, Calif00 • F 14 50. To the extent that the foregoing conduct of ACTS and Treyzon have s0 15 resulted in any of the Gas Leak Clients signing a retainer agreement with ACTS in e1 M5- a 4 ost4 4 16 connection with the Southern California Gas Leak Litigation, each entry into a retainer C1 7 Tel 17 agreement on or after the Petition Date is an unauthorized postpetition transfer of an 18 interest of the Debtor in property (namely, its contractual financial interest in the litigation19 that was done without the permission of the Court or the authority of the Debtor and is 20 therefore avoidable as an unauthorized transfer of an interest of the Debtor in property 21 under 11 U.S.C. § 549(a). 22 23 WHEREFORE, the Trustee prays that the Court enter a judgment against ACTS 24 and Treyzon as follows: 25 On the First Claim for Relief 26 1. For a judgment finding that ACTS and Treyzon have violated the automatic27 stay by utilizing the Client List to solicit the Debtor's clients with the intention of interferin

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1 entitled in the Southern California Gas Leak Litigation and awarding the Trustee fees an2 costs, actual damages, and sanctions for the violation of the automatic stay and 3 injunctive relief; 4 On the Second Claim for Relief 5 2. For actual, compensatory, and punitive damages against ACTS and 6 Treyzon in an amount to be determined and for injunctive relief prohibiting any further 7 acts to solicit the Gas Leak Clients and any other clients of the Debtor; 8 On the Third Claim for Relief 9 3. For actual, compensatory, and punitive damages against ACTS and 10 Treyzon in an amount to be determined and for injunctive relief prohibiting any further 11 acts to solicit the Gas Leak Clients and any other clients of the Debtor; 2 0 0 ornia 92626 ax 714 445-1 1123 4. Requiring ACTSO nan tdh eT rFeoyuzortnh aCnlda iema cfho ro Rf tehleieirf agents and employees to a, Calif00 • F 14 turnover to the Trustee all paper copies of the Client List and, after this turnover, requirins0 15 ACTS and Treyzon and their agents and employees to destroy all written and electronic e1 M5- a 4 ost4 4 16 copies of the Client List and any other lists of the Debtor's clients that remain in their C1 7 Tel 17 possession or that refer to any of the Debtor's clients; 18 On the Fifth Claim for Relief 19 5. Declaring that pending further Court order, the Debtor and Frantz remain 20 the counsel of record in the Southern California Gas Leak Litigation with respect to all of 21 the Gas Leak Clients and that any retainer agreements with ACTS signed by the Gas 22 Leak Clients are void as a violation of the automatic stay. 23 On the Sixth Claim for Relief 24 6. Declaring that any retainer agreements entered into by ACTS with the Gas 25 Leak Clients on or after the Petition Date are void as unauthorized postpetition transfers 26 of an interest of the Debtor in property. 27 On All Claims for Relief

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1 8. For attorney's fees and costs as authorized by law; and 2 9. For such other and further relief as the Court may deem just and proper. 3 4 DATED: January 25, 2021 Respectfully submitted, 5 SMILEY WANG-EKVALL, LLP 6 7 By: /s/ Kyra E. Andrassy 8 KYRA E. ANDRASSY Attorneys for Elissa D. Miller, Chapter 7 9 Trustee 10 11 2 0 0 ornia 92626 ax 714 445-1 1123 a, Calif00 • F 14 s0 15 e1 M5- a 4 ost4 4 16 C1 7 Tel 17 18 19 20 21 22 23 24 25 26 27

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EXHIBIT "1"

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-------- Forwarded message --------- rom: Porter Ranch Gas Leak Litigation Update <info@actslaw.com> ate: Fri, Jan 22, 2021 at 2:42 PM ubject: Urgent update for Girardi | Keese Porter Ranch Gas Leak Litigation Clients o: > d for an important update... View this email in your browser Personal & Confidential - For Girardi | Keese clients ONLY Attorney/Client Communication Dear : We hope that this letter finds you well despite these difficult times. You are receiving this letter because you are currently a plaintiff in the Porter Ranch Gas Leak litigation and represented by Girardi | Keese (“GK”). Our firm, Abir Cohen Treyzon Salo, LLP, previously agreed to assist GK with your case and has an experienced toxic tort and environmental legal team to do so. This team is led by Robert W. Finnerty, Esq., who has over thirty years of experience in this area of the law. Please click here for more information about Mr. Finnerty and our firm. Recently, our firm indicated to the court that we would be assisting with many of GK’s Porter Ranch Gas Leak cases. Unfortunately, GK and its founding partner are facing concerning allegations and have been the subject of involuntary bankruptcy proceedings. Nevertheless, our firm stands ready to continue to represent you until your case is concluded. We can assume full responsibility for your case under the same fee arrangement you entered into with GK, which means you will not be subject to any additional attorney fees. In order for us to continue representing you under these terms, please execute a retainer agreement with our firm as soon as possible. Please click here to sign our retainer agreement.

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You will have an opportunity to ask questions and receive more information at virtual Town Hall Meetings next week. Please click here to register with us for access to our portal where you can get updates on the litigation, get information on the virtual Town Hall Meetings and also electronically send us messages with your questions. If you cannot attend the virtual Town Hall Meetings or would like to contact us before the Meetings, please feel free to call our dedicated Porter Ranch Litigation Gas Leak hotline at (818) 350-7654. Our legal team will be available to answer your questions Monday through Fridayfrom 7:00 am - 8:00 pm and Saturday and Sunday from 8:00 am -12:00 pm. We understand that other lawyers may be attempting to contact you and take over your case. We hope that you will attend our virtual Town Hall Meetings to learn more about our firm and get answers to any questions you may have. We are confident that we can achieve a terrific result for you due to our experience in environmental law and familiarity with your case. From all of us at ACTS Law Team, please stay safe and we look forward to hearing from you. This letter is intended to be attorney advertising and it should not be construed as a formation of a lawyer/client relationship. If you are represented by other counsel, please disregard this message, and unsubscribe from our mailing list. No guarantee of outcome is made. Past results are not a guarantee of future outcome. Copyright (C) 2021 Abir Cohen Treyzon Salo, LLP. All rights reserved. You are receiving this email because you opted in via our website. Abir Cohen Treyzon Salo, LLP 16001 Ventura Blvd Ste 200 Encino, CA 91436-4482

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EXHIBIT "2"

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January 22, 2021 Via Email (btreyzon@actslaw.com rfinnerty@actslaw.com) Abir Cohen Treyzon Salo, LLP c/o Boris Treyzon, Esq. & Robert W. Finnerty, Esq. 16001 Ventura Blvd., Ste. 200 Encino, CA 91436-4482 Dear Mr. Treyzon, Mr. Finnerty, and all ACTS Personnel: Pursuant to all applicable legal authorities and professional rules, the Frantz Law Group (“FLG”) and Elissa D. Miller, the Chapter 7 Trustee of Girardi Keese (the “Trustee”), hereby demand that your law firm, and any and all persons associated with your law firm, CEASE AND DESIST your unauthorized and improper solicitation of clients jointly represented by FLG and Girardi/Keese (“GK”) with knowledge that these clients are already represented by counsel, in violation of California's Rules of Professional Conduct. Moreover, your improper solicitation was done without the approval of the Trustee and is an intentional violation of the automatic stay for which you may be sanctioned pursuant to Bankruptcy Code sections 362(k) and 105. Your letter's reference to an “agreement” between your firm and GK to assist with the Porter Ranch Gas Leak Litigation is misleading and asserted in bad faith. Your letter was sent without conferring with FLG and after FLG specifically REJECTED your request to permit your firm to jointly represent FLG and GK joint clients. Moreover, any tentative agreement with GK was never consummated and efforts by you to exercise control over GK's cases were stayed by the court in Chicago and now by the automatic stay. Your unauthorized and misleading letter to FLG clients fails to disclose that you were not authorized to communicate with the clients because they are already represented by counsel and that you have not been authorized by the Trustee or the bankruptcy court to exercise control over GK's assets. In addition, it is evident that you are in possession of GK's client lists and pursuant to Bankruptcy Code section 542, the Trustee hereby demands turnover of all such data and files that you improperly obtained and retained. Please be advised that an agreement in principle has been reached between the Trustee and FLG for FLG to resume representation of the clients alone. If you do not cease to contact the clients of GK, who are also represented by FLG, the Trustee intends to seek sanctions against you. If any clients contact you, we demand that you inform them to disregard your solicitation letter. We trust no further information or a court order is required for you to immediately CEASE AND DESIST YOUR COMMUNICATION WITH GK AND FLG CLIENTS.

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Sincerely, Kenneth Chiate Elissa D. Miller Quinn Emanuel Urquhart & Sullivan, LLP c/o SulmeyerKupetz 865 South Figueroa Street, 10th Floor 333 S Grand Ave #3400 Los Angeles, CA 90017 Los Angeles, CA 90071 Counsel to Frantz Law Group Chapter 7 Trustee for the estate of Girardi Keese cc: Lei Lei Wang Ekvall K. John Shaffer Eric Winston James Frantz

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EXHIBIT "3"

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rom: John Shaffer ent: Saturday, January 23, 2021 4:32 PM o: 'btreyzon@actslaw.com'; 'rfinnerty@actslaw.com' c: 'Miller, Elissa D.'; 'Lei Lei Wang Ekvall'; Kenneth Chiate; Eric Winston; 'James Frantz'ubject: RE: Southern California Gas Leak Litigation lease see the following correspondence from the Chapter 7 Trustee of the Girardi Keese bankruptcy estate and Frantz aw Group: ear Mr. Treyzon, Mr. Finnerty, and all ACTS Personnel: he Frantz Law Group and Elissa D. Miller, the Chapter 7 Trustee of Girardi Keese, are writing as a follow up to our letterated January 22, 2021. Notwithstanding our letter, we understand that the link to your firm’s Porter Ranch ngagement letter remains active, and thus you are continuing to solicit clients in violation of the California Rules of rofessional Conduct and the Bankruptcy Code’s automatic stay. Please deactivate the link immediately and confirm at you have done so. rantz Law Group and the Trustee reserve all rights. lissa Miller James Frantz hapter 7 Trustee of Girardi Keese Frantz Law Group, APLC rom: John Shaffer ent: Friday, January 22, 2021 8:42 PM o: 'btreyzon@actslaw.com' ; 'rfinnerty@actslaw.com' c: 'Miller, Elissa D.' ; 'Lei Lei Wang Ekvall' ; Kenneth Chiate ; Eric Winston ; 'James Frantz' ubject: Southern California Gas Leak Litigation lease see the attached correspondence. . John Shaffer artner uinn Emanuel Urquhart & Sullivan, LLP 65 S. Figueroa Street, 10th Floor s Angeles, CA 90017 13-443-3667 Direct 13-443-3000 Main Office Number 13-443-3100 Fax hnshaffer@quinnemanuel.com ww.quinnemanuel.com OTICE: The information contained in this e-mail message is intended only for the personal and confidential use of the recipient(s) named above. This message ay be an attorney-client communication and/or work product and as such is privileged and confidential. If the reader of this message is not the intended cipient or agent responsible for delivering it to the intended recipient, you are hereby notified that you have received this document in error and that any view, dissemination, distribution, or copying of this message is strictly prohibited. If you have received this communication in error, please notify us immediately e-mail, and delete the original message.

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SSSuuubbbssscccrrriiibbbeee PPPaaasssttt IIIssssssuuueeesss TTTrrraaannnssslllaaatttView this email in your browser Personal & Confidential - For Girardi | Keese clients ONLY Attorney/Client Communication Dear : We are writing to you because you have filed actions in the Porter Ranch Gas Leak litigation and have previously been represented solely by the now defunct/bankrupt law firm of Girardi | Keese. Because of this, you now have important decisions to make concerning your future representation. Before the filing of the bankruptcy, on November 18, 2020, Tom Girardi of Girardi | Keese entered into an agreement with our firm, Abir Cohen Treyzon & Salo LLP. This agreement allowed us to work with Girardi | Keese on your case, as well as the cases of thousands of your neighbors in the Porter Ranch area. Of course, this is subject to your informed consent. Now with the demise of Girardi | Keese, we are reaching out to you to ensure you will continue to be well represented by offering you a choice. This message is important to your legal rights because you need to be well-informed in order to make decisions to protect these rights. Among these rights are the absolute right of any client to be represented by a capable and experienced attorney of their choosing. Attorneys should always act in the best

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chose your attorney. Attorneys should not treat your case as an “asset” of the Girardi | Keese bankruptcy or claim to have inherited it as part of their law firm “family.” You always have the absolute right to change counsel if you are not satisfied. The bankruptcy of Girardi | Keese and court proceedings in other courts do not have any effect on these rights. As before, we offer to continue your representation. Simply click here to sign our retainer agreement. If you have since retained other counsel, please disregard this message. This is why we sent our Urgent Update email on January 22, 2021. As we alerted you, other law firms have since tried to interfere with our November 18th agreement with Girardi | Keese, which remains in full force and effect. They have done so by not presenting their credentials. Instead, they are trying to persuade you to engage with them by making false and defamatory claims against our firm. Just as we stand up for the rights of others, we will not be silent in the face of these baseless accusations. Because we value the ethics of all professions, we have consulted with ethics experts and now bankruptcy counsel every step of the way. We are prepared to address any questions or concerns you may have at the Virtual Town Hall meeting tomorrow (Monday) evening at 6 pm. Please click here to register with us for access to our portal where you can get updates on the litigation. If you cannot attend Monday’s virtual Town Hall Meeting, we will make a recording available to you on our portal. You can also contact us by calling our dedicated Porter Ranch Litigation Gas Leak hotline at (818) 350-7654. We are taking these steps so that you have the opportunity to be updated on the litigation, our firm and our plans for representation, if you choose us. As always, from all of us at ACTS Law Team, please stay safe and we look forward to hearing from you.

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This letter is intended to be attorney advertising and it should not be construed as a formation of a lawyer/client relationship. If you are represented by other counsel, please disregard this message, and unsubscribe from our mailing list. No guarantee of outcome is made. Past results are not a guarantee of future outcome. Copyright (C) 2021 Abir Cohen Treyzon Salo, LLP. All rights reserved. Update Preferences | Unsubscribe

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