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Full title: Application to Employ Daphne Masin as Paraprofessional ; Notice of Opportunity to Request Hearing; Declaration of Trustee; and Declaration of Paraprofessional, with Proof of Service Filed by Trustee Elissa Miller (TR) (Miller (TR), Elissa) (Entered: 01/26/2021)

Document posted on Jan 25, 2021 in the bankruptcy, 13 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

VIA NOTICE OF ELECTRONIC FILING (“NEF”)ichard D Buckley on behalf of Interested Party L.A. Arena Funding, LLC chard.buckley@arentfox.com arie E Christiansen on behalf of Creditor KCC Class Action Services, LLC christiansen@vedderprice.com, ecfladocket@vedderprice.com,marie-christiansen-4166@ecf.pacerpro.com ennifer Witherell Crastz on behalf of Creditor Wells Fargo Vendor Financial Services, Inc. shleigh A Danker on behalf of Interested Party Courtesy NEF shleigh.danker@dinsmore.com, SDCMLFiles@DINSMORE.COM;Katrice.ortiz@dinsmore.com lifford S Davidson on behalf of Creditor California Attorney Lending II, Inc. kvall@swelawfirm.com, lgarrett@swelawfirm.com;gcruz@swelawfirm.com;jchung@swelawfirm.com ichard W Esterkin on behalf of Interested Party Courtesy NEF chard.esterkin@morganlewis.com imothy W Evanston on behalf of Interested Party Courtesy NEF vanston@swelawfirm.com, gcruz@swelawfirm.com;lgarrett@swelawfirm.com;jchung@swelawfirm.com ric D Goldberg on behalf of Creditor Stillwell Madison, LLC ric.goldberg@dlapiper.com, eric-goldberg-1103@ecf.pacerpro.com ndrew Goodman on behalf of Attorney William F Savino Goodman.AndrewR102467@notify.bestcase.com ndrew Goodman on behalf of Petitioning Creditor Kimberly Archie goodman@andyglaw.com, Goodman.AndrewR102467@notify.bestcase.com ndrew Goodman on behalf of Petitioning Creditor Robert M. Keese goodman@andyglaw.com, Goodman.AndrewR102467@notify.bestcase.com ndrew Goodman on behalf of Petitioning Creditor Virginia Antonio goodman@andyglaw.com, Goodman.AndrewR102467@notify.bestcase.com teven T Gubner on behalf of Interested Party Courtesy NEF gubner@bg.law, ecf@bg.law arshall J Hogan on behalf of Creditor California Attorney Lending II,ena@penalaw.com, penasomaecf@gmail.com;penalr72746@notify.bestcase.com ichael J Quinn on behalf of Creditor KCC Class Action Services, LLC quinn@vedderprice.com, ecfladocket@vedderprice.com,michael-quinn-2870@ecf.pacerpro.com onald N Richards on behalf of Interested Party Courtesy NEF n@ronaldrichards.com, morani@ronaldrichards.com,justin@ronaldrichards.com hilip E Strok on behalf of Interested Party Courtesy NEF strok@swelawfirm.com, gcruz@swelawfirm.com;1garrett@swelawfirm.com;jchung@swelawfirm.com nited States Trustee (LA)

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Nos., State Bar No. & Email Address lissa D. Miller emiller@sulmeyerlaw.com 33 South Grand Avenue, Suite 3400 os Angeles, California 90071-1406 elephone: 213.626.2311 acsimile: 213.629.4520 Attorney for trustee Trustee appearing without an attorney UNITED STATES BANKRUPTCY COURT CENTRAL DISTRICT OF CALIFORNIA – LOS ANGELES DIVISION In re: CASE NO.: 2:20-bk-21022-BR CHAPTER: 7 GIRARDI KEESE TRUSTEE’S NOTICE OF MOTION AND MOTION FOR: AUTHORIZATION TO EMPLOY PARAPROFESSIONALS, AND/OR AUTHORIZATION TO PAY FLAT FEE TO TAX PREPARER; NOTICE OF OPPORTUNITY TO REQUEST HEARING; DECLARATION OF TRUSTEE; AND DECLARATION OF PARAPROFESSIONAL [No hearing unless requested under LBR 9013-1(o)] Debtor(s). O PARTIES IN INTEREST: LEASE TAKE NOTICE that the duly-appointed chapter 11 trustee has filed this motion for court approval of the trustee’quest to employ a paraprofessional, and/or pay a flat fee to a tax preparer of up to $ ot to exceed $750 unless the court orders otherwise). The court may grant the motion authorizing retention of araprofessional and expenditure of estate funds without a hearing unless you file with the court and serve upon thustee and the United States trustee a written objection to the motion explaining all of the reasons for the oppositioITHIN 14 DAYS AFTER THE DATE OF SERVICE OF THIS NOTICE AND MOTION, plus 3 additional days if you wererved by mail or pursuant to F.R.Civ.P.5(b)(2)(D) or (F). If an objection is timely filed, the trustee will set the matter fearing and notify you of the date and time of the hearing. Failure to object may be deemed consent to interiuthorization of the expenses requested by the trustee.

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a. Identity of proposed paraprofessional: Daphne Masin whose rate is $65.00/hour(1) A resume is attached as Exhibit A. not more than (2) It is estimated that the fees for all work by the paraprofessional will be $ $1,500.00/week . b. The trustee contends that the paraprofessional will provide the following servicesCommencing on January 15, Assisting the Trustee in the administration of the Debtor for 20-25 hours per day (as an average) including locating financial books and records; collecting mail and reviewing for important documents and checks; assisting forensic team in locating (1) information (2) Assist with access to office space and transition of paper files to new counsel(3) Provide such additional support services as request by the Trusteec. The trustee contends that the paraprofessionals will provide the following services that are not included iparagraph (f)(1) of LBR 2016-2, and fees for these services should be paid separate and apart from thetrustee’s compensation allowed pursuant to 11 U.S.C. § 326(a): (1) (2) (3) 2. The trustee moves for an order authorizing employment of a tax preparer, as follows: a. Identity of proposed tax preparer: (i) A resume is attached as Exhibit B. b. The tax preparer has agreed to accept up to $ (not to exceed $750 unless the court orders otherwise) as payment in full for the following services. 3. The trustee moves for an order authorizing payment from property of the estate of a sum not to exceed$ (not to exceed $750 unless the court orders otherwise) to the tax preparer upocompletion of such services to the estate without a separate fee application being required. January 25, ate: 2021 /s/ Elissa D. Miller Chapter 11 trustee

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Elissa D. Miller , the duly-appointed chapter 7 trustee, have prepared the foregoing otion for authorization to employ paraprofessionals, and/or for authorization to pay a flat fee of (not to exceed $750 unless the court orders otherwise) to a tax preparer. The effective and fficient administration of this bankruptcy case dictates approval of the motion and I base that conclusion on the followingcts: ee Attached Statement of Chapter 7 Trustee and basis for retention of para-professional. declare under penalty of perjury under the laws of the United States that the foregoing is true and correct. 1/25/21 Elissa D. Miller /s/ Elissa D. Miller Date Printed Name of chapter 11 trustee Signature

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OF PARAPROFESSIONAL By this application, the Trustee seeks to retain Daphne Masin as a para-professional/field gent. As can be seen from her resume attached, Ms. Masin is well qualified to assist the Trustee in is regard. Ms. Masin commenced providing services at the request of the Trustee on January 15, 2020. hus, the Trustee requests that her employment be as of that date. Girardi Keese (the "Debtor") was once a thriving plaintiff's law firm based in Los Angeles, alifornia, practicing in the areas of personal injury, defective products, sexual abuse, toxic torts, usiness law, employment law, and aviation law. Unfortunately, and as has been exhaustively ported in the media, things have changed drastically for the Debtor and its founding partner, homas Girardi. On December 18, 2020, a number of creditors (the "Petitioning Creditors") filed an involuntary hapter 7 bankruptcy petition against the Debtor.1 On December 24, 2020, the Petitioning Creditors filed a Motion for Appointment of Interim rustee Pursuant to 11 U.S.C. § 303(g) [Docket No. 12]. The Court entered an order granting the otion on January 5, 2021 [Docket No. 45]. On January 6, 2021, the Trustee was appointed as the terim trustee [Docket No. 50]. On January 13, 2021, the Court entered an Order Directing: (1) The Clerk of Court to mediately Enter an Order for Relief under Chapter 7; (2) The United States Trustee to Immediatelyppoint a Chapter 7 Trustee; (3) The Debtor to File All Schedules and Related Documentation for hapter 7 Case within Fourteen Days of the Entry of this Order; and (4) Vacating February 16, 2021 tatus Conference [Docket No. 68]. On January 13, 2021, the Clerk of Court entered an order for lief against the Debtor [Docket No. 69], and the Trustee was appointed and accepted her ppointment in the Debtor's case [Docket No. 71]. . The Petitioning Creditors also filed an involuntary chapter 7 bankruptcy petition against Thomas V. irardi, which is currently pending as Bankruptcy Case No. 2:20-bk-21020-BR.

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am, including Masin, have worked tirelessly to secure the assets and physical premises and vestigate, review and analyze the scope and status of the Debtor's financials and cases, which are t varying litigation stages. At the time of the filing of the involuntary, the Debtor was still counsel of cord to thousands of clients. At the time of the filing of the involuntary, other than one attorney, an few staff members, the Debtor had no employees or contract employees. The Trustee has and intends to continue to utilize the services to Ms. Masin as her field gent/paraprofessional to locate the financial books and records among stacks of papers in the ccounting department; collect mail and reviewing for important documents and checks2; assisting e forensic team in locating information. In addition, Ms. Masin will assist the Trustee by oordinating access to the Debtors' offices and the transition of paper files to new counsel. Only Ms. asin and the Trustee have the keys to the offices. I am also requesting authority to utilize Ms. Masin's services for such additional support ervices as the Trustee may need from time to time. None of the services listed in Local Rule 2016-2(f)(2) will be delegated to Ms. Masin. It would be impossible to forward the mail as mail is received at the premises under too many ifferent names, some of which has nothing to do with the Debtor.

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OFP ARAPROFESSPIEORNSAOULNN DELRB R2 016-2 .Thfeo lloiwasci onmgp lete doefas loclftr hipepa triaopnr ofecsosninoencwatilit'tohshnd ese btporri,n coiftp hadebtionrs,i dedresb,t cotrrhe'eds i atnooyrt shp,ea rr otrpy a rtiinie nst earnetdsh te,ri ers peactttiovrean nedysaccounotraa nnptyes r,s on eimntp hloeof yfeoidftc heUe n itSetda ttersu stee: Thep ara-prohfaepssr seivoinsoaeulrvs eladysa p araproffeostrsh Tiero unsaitlnae neu nrelcaatsaeend ad l servaesas p ara-proffeotrsh sTeir ounsatbleu es'isnp easrstH noewra Erhdr enbwehroig as,l saTo r usitne e,unrelcaatseeds . .Thpea raprofiesns osatic orneadlai nte oqru,si etcyu hroiltdoyera r ni nsiodfte hdre e btor,a sfe oxlcleopwtsn/a .Thpea raprofiesnso satin owdna asnl o wti,t 2hy iena bresf otrhdeea toeft hfei loiftn hge pehteirteaiid onin,r eoffoircee mrp looyfte hede e btioncr o nnecwtiittohhon ef fsearlo,eri ssuaonfac nesy e cuorfti htdeye btor. n/a .Thpea raprofneesisthihooenlrnad olsrr e preasneyn tisn terest mtaott heiern itaelorlftey hse etsa tdaovrtoe efrancyl aosfcs r ediotreo qrusi ty secubryri etays oohfano n ldydi erorerisc n,td irreelcatt itoocn,os nhniepcw tiitointeirnte hsdete btoarni novre stmenftoa rnb syae nckueorrfti htdeye btofro,ar n oyot rh reera seoxnc,ea psft o ln/a/ .Thpea raprofiesns osatir oenlaaoltre i mvpel ooyfte heUe n itSetda ttersu sotraeb ea nkrujputdcgeyex ,c eapst follows: n/a ecluanrdepe ern aolfpt eyr juunryd tehrle a wosft hUen itSetda ttehsta htfe o regiotsir naugen c do rrect. 1/52/202D1a phMnaes in ate PrintedN ame

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EXHIBIT A

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(626) 827-0262; daphnemasin@dmasinconsulting.com Results-driven professional with extensive experience in operations, administration, andfinance. Managed and directed overall daily accounting functions, administered 401k pensionplan for 100 employees, and have assisted in complex software conversions. AREAS OF EXPERTISE • Finance Strategy • Tax Returns/Laws/Schedules • General Accounting • Working with Secured Lenders • Contract Analysis • Human Resources • Cash Flow Projections/Budgets • Overall Operations SPECIAL SKILLS • Administration and management of the “workout” process for insolvent businesses thatare undergoing out-of-court processes. • Expertise in forced liquidation sales and accompanying processes. • Strong face-to-face and phone communication skills – able to explain complex situationsin easy-to-understand communications; excellent at reassuring customers/clients whoare in distress over liquidation process. • Solid experience in the distribution industry; former material supplier to the constructionindustry. Calculate costs, deliveries to customers, sales invoicing, prepare AR and APaging’s, track sales commissions, prepare journal entries and update general ledger totax preparation. • Extensive knowledge of compliance requirements for federal and state taxing authorities(sales tax, payroll taxes, property taxes and code compliance). • Software expertise: Microsoft Office-excel, word, QuickBooks, Oracle-NetSuite, ADP,miscellaneous proprietary PROFESSIONAL EXPERIENCE D MASIN CONSULTING LLC., Monrovia, CA March 2018-PresentAssist Bankruptcy Trustees with Chapter 7 & 11 field work.in various industries. Preparing bankstatement analysis, review bank transfers; review and confirm Accounts Receivable-AccountsPayable-Inventory balances. On site inventory of assets. Work with auction houses whennecessary. Collaborating with Turn Around and other companies specializing in insolvency,reviewing, interpreting, and reporting on financial and due diligence work for insolventcompanies. Preparing cash flow analysis and research for preferences. Work with the debtorsto better understand this alternate insolvency process through a General Assignment for theBenefit of Creditors. Help provide solutions whether to market the business or liquidate theassets through an auction process. CREDIT MANAGEMENT ASSOCIATION, Glendale, CA 2009 – March 2018Asset Sales / Communication Manager, Adjustment Insolvency DepartmentCMA is a 100+ year-old association that offers an array of business services including: Business Collection, Industry Trade, Construction Lien, and the Adjustment Insolvency (ADJ). The main focus of the ADJ is to administer complex transactions pertaining to closing down a business (vs. filing Chapter7 or 11).

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• Prepare and review due diligence about the client company’s operation, analyzing allfinancial information, preparing cash flow projections and budgets. • Work with secured lenders of the debtors, and ultimately, find the best means tooptimize the debtor’s estate and the creditor’s money, as well as securing all remainingassets in the estate. • Liaison for auctions of client company assets (help coordinate and organize all mattersrelating to this process). • Serve as resource for all matters pertaining to the liquidation of company; includingmanaging all creditors and legal parties involved, virtually taking over the process for theclient company. MCALONEY ENTERPRISES, INC., El Monte, CA 2002-2009 Executive Vice President/Co-Owner $1.5M Architectural Hardware Company • Performed daily operations, oversaw and managed all areas of Human Resources;prepared all financial information from daily transactions through monthly financialsthrough to tax returns. • Responsible for applying and certifying the business in city, state and federal arenas formaterial procurement. • Performed site surveys for contractors. • Brought customers ideas and thoughts together through bids. • Prepared hardware schedules supported with appropriate cut sheets as needed. • Responsible for approving and signing all contracts and prepare appropriate liens. WELLS FARGO BANK, Van Nuys, CA 2001 Consultant - Project to assist in liquidating a company . • Prepared all financial analysis forecasts. • Established payment programs for the taxing authorities. MATCO UNITED, INC, Commerce, CA 1985-2001 Controller, Vice President $30M company distributing paper goods, food service and cleaning items. • Prepared and maintained all financial records including budgets, cash flows and monthlyfinancial statements. • Managed accounting, finance, and HR departments. Familiar with 401K and itsadministration. EDUCATION California State University, Northridge Bachelor of Science, Business/Accounting PROFESSIONAL CERTIFICATIONS • Certified Bankruptcy Credit Specialist • Certified Construction Credit Specialist PROFESSIONAL ASSOCIATIONS • Member of the National Association of Women in Construction (NAWIC)

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• Turn Around Management Association (TMA) • Los Angeles Bankruptcy Forum (LABF) • National Association of Credit Managers (NACM)Financial Lawyers Conference (FLC)• International Women’s Insolvency & Restructuring Confederation (IWIRC)

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PROOF OF SERVICE OF DOCUMENT am over the age of 18 and not a party to this bankruptcy case or adversary proceeding. My business address is 333 outh Grand Avenue, Suite 3400, Los Angeles, CA 90071. true and correct copy of the foregoing document entitled (specify): TRUSTEE’S NOTICE OF MOTION AND MOTION OR AUTHORIZATION TO EMPLOY PARAPROFESSIONALS; NOTICE OF OPPORTUNITY TO REQUEST EARING; DECLARATION OF TRUSTEE; AND DECLARATION OF PARAPROFESSIONAL will be served or was erved (a) on the judge in chambers in the form and manner required by LBR 5005-2(d); and (b) in the manner stated elow: .TO BE SERVED BY THE COURT VIA NOTICE OF ELECTRONIC FILING (NEF): Pursuant to controlling Generalrders and LBR, the foregoing document will be served by the court via NEF and hyperlink to the document. On (date)anuary 26, 2021 I checked the CM/ECF docket for this bankruptcy case or adversary proceeding and determined thate following persons are on the Electronic Mail Notice List to receive NEF transmission at the email addresses statedelow: Service information continued on attached pag . SERVED BY UNITED STATES MAIL: n (date) January 26, 2021 , I served the following persons and/or entities at the last known addresses in this bankruptcase or adversary proceeding by placing a true and correct copy thereof in a sealed envelope in the United States mail,rst class, postage prepaid, and addressed as follows. Listing the judge here constitutes a declaration that mailing to thedge will be completed no later than 24 hours after the document is filed. ebtor irardi Keese 126 Wilshire Blvd os Angeles, CA 90017-1904 Service information continued on attached pag .SERVED BY PERSONAL DELIVERY, OVERNIGHT MAIL, FACSIMILE TRANSMISSION OR EMAIL (state methodr each person or entity served): Pursuant to F.R.Civ.P. 5 and/or controlling LBR, on (date) , I servee following persons and/or entities by personal delivery, overnight mail service, or (for those who consented in writing tuch service method), by facsimile transmission and/or email as follows. Listing the judge here constitutes a declarationat personal delivery on, or overnight mail to, the judge will be completed no later than 24 hours after the document isled. Service information continued on attached pag declare under penalty of perjury under the laws of the United States that the foregoing is true and correct. January 26, 2021 Cheryl Caldwell /s/Cheryl Caldwell Date PrintedName Signature

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ADDITIONAL SERVICE INFORMATION (if needed): . SERVED BY THE COURT VIA NOTICE OF ELECTRONIC FILING (“NEF”)ichard D Buckley on behalf of Interested Party L.A. Arena Funding, LLC chard.buckley@arentfox.com arie E Christiansen on behalf of Creditor KCC Class Action Services, LLC christiansen@vedderprice.com, ecfladocket@vedderprice.com,marie-christiansen-4166@ecf.pacerpro.com ennifer Witherell Crastz on behalf of Creditor Wells Fargo Vendor Financial Services, Inc. rastz@hrhlaw.com shleigh A Danker on behalf of Interested Party Courtesy NEF shleigh.danker@dinsmore.com, SDCMLFiles@DINSMORE.COM;Katrice.ortiz@dinsmore.com lifford S Davidson on behalf of Creditor California Attorney Lending II, Inc. sdavidson@swlaw.com, jlanglois@swlaw.com;cliff-davidson-7586@ecf.pacerpro.com ei Lei Wang Ekvall on behalf of Interested Party Courtesy NEF kvall@swelawfirm.com, lgarrett@swelawfirm.com;gcruz@swelawfirm.com;jchung@swelawfirm.com ei Lei Wang Ekvall on behalf of Trustee Elissa Miller (TR) kvall@swelawfirm.com, lgarrett@swelawfirm.com;gcruz@swelawfirm.com;jchung@swelawfirm.com ichard W Esterkin on behalf of Interested Party Courtesy NEF chard.esterkin@morganlewis.com imothy W Evanston on behalf of Interested Party Courtesy NEF vanston@swelawfirm.com, gcruz@swelawfirm.com;lgarrett@swelawfirm.com;jchung@swelawfirm.com ric D Goldberg on behalf of Creditor Stillwell Madison, LLC ric.goldberg@dlapiper.com, eric-goldberg-1103@ecf.pacerpro.com ndrew Goodman on behalf of Attorney William F Savino goodman@andyglaw.com, Goodman.AndrewR102467@notify.bestcase.com ndrew Goodman on behalf of Petitioning Creditor Erika Saldana goodman@andyglaw.com, Goodman.AndrewR102467@notify.bestcase.com ndrew Goodman on behalf of Petitioning Creditor Jill O'Callahan goodman@andyglaw.com, Goodman.AndrewR102467@notify.bestcase.com ndrew Goodman on behalf of Petitioning Creditor John Abassian goodman@andyglaw.com, Goodman.AndrewR102467@notify.bestcase.com ndrew Goodman on behalf of Petitioning Creditor Kimberly Archie goodman@andyglaw.com, Goodman.AndrewR102467@notify.bestcase.com ndrew Goodman on behalf of Petitioning Creditor Robert M. Keese goodman@andyglaw.com, Goodman.AndrewR102467@notify.bestcase.com ndrew Goodman on behalf of Petitioning Creditor Virginia Antonio goodman@andyglaw.com, Goodman.AndrewR102467@notify.bestcase.com teven T Gubner on behalf of Interested Party Courtesy NEF gubner@bg.law, ecf@bg.law

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arshall J Hogan on behalf of Creditor California Attorney Lending II, Inc. hogan@swlaw.com, knestuk@swlaw.com azmig Izakelian on behalf of Creditor Frantz Law Group, APLC zmigizakelian@quinnemanuel.com ewis R Landau on behalf of Creditor Virage SPV 1, LLC ew@Landaunet.com ewis R Landau on behalf of Interested Party Courtesy NEF ew@Landaunet.com aniel A Lev on behalf of Interested Party Courtesy NEF lev@sulmeyerlaw.com, ccaldwell@sulmeyerlaw.com;dlev@ecf.inforuptcy.com eter J Mastan on behalf of Interested Party Courtesy NEF eter.mastan@dinsmore.com, SDCMLFiles@dinsmore.com;Katrice.ortiz@dinsmore.com dith R Matthai on behalf of Interested Party Courtesy NEF matthai@romalaw.com enneth Miller on behalf of Interested Party Courtesy NEF miller@pmcos.com, efilings@pmcos.com lissa Miller (TR) A71@ecfcbis.com, MillerTrustee@Sulmeyerlaw.com;C124@ecfcbis.com;ccaldwell@sulmeyerlaw.com ric A Mitnick on behalf of Interested Party Courtesy NEF itnickLaw@aol.com, mitnicklaw@gmail.com cott H Olson on behalf of Creditor KCC Class Action Services, LLC olson@vedderprice.com, scott-olson-2161@ecf.pacerpro.com,ecfsfdocket@vedderprice.com,nortega@vedderprice.coeonard Pena on behalf of Interested Party Robert Girardi ena@penalaw.com, penasomaecf@gmail.com;penalr72746@notify.bestcase.com ichael J Quinn on behalf of Creditor KCC Class Action Services, LLC quinn@vedderprice.com, ecfladocket@vedderprice.com,michael-quinn-2870@ecf.pacerpro.com onald N Richards on behalf of Interested Party Courtesy NEF n@ronaldrichards.com, morani@ronaldrichards.com,justin@ronaldrichards.com hilip E Strok on behalf of Interested Party Courtesy NEF strok@swelawfirm.com, gcruz@swelawfirm.com;1garrett@swelawfirm.com;jchung@swelawfirm.com nited States Trustee (LA) stpregion16.la.ecf@usdoj.gov ric D Winston on behalf of Creditor Frantz Law Group, APLC ricwinston@quinnemanuel.com hristopher K.S. Wong on behalf of Interested Party L.A. Arena Funding, LLC hristopher.wong@arentfox.com, yvonne.li@arentfox.com imothy J Yoo on behalf of Interested Party Courtesy NEF y@lnbyb.com

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