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Full title: Objection (related document(s): 123 Motion to Approve Compromise Under Rule 9019 Emergency Motion For Order: (1) Approving Compromise With Frantz Law Group, APLC Pursuant To Federal Rule Of Bankruptcy Procedure 9019; (2) Authorizing The Assignment Of The Estate's Interests In The filed by Trustee Elissa Miller (TR)) Evidentiary Objections To Declaration of Elissa Miller Filed In Support of Emergency Motion To Approve Compromise With Frantz Law Group; Assignment Of Estate's Interest and Rejection of Assumption Agreement Filed by Creditors ABIR COHEN TREYZON SALO, LLP, a California limited liability partnership, Boris Treyzon Esq (Goodman, Andrew) (Entered: 01/29/2021)

Document posted on Jan 28, 2021 in the bankruptcy, 3 pages and 0 tables.

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23 24 25 26 27 1 TO THE HONORABLE BARRY RUSSELL, UNITED STATES BANKRUPTCY 2 JUDGE, ELISSA MILLER, INTERIM CHAPTER 7 TRUSTEE, THE OFFICES OF THE 3 UNITED STATES TRUSTEE AND ALL OTHER INTERESTED PARTIES: 4 Abir Cohen Treyzon Salo, LLP and Boris Treyzon hereby submits the following 5 objections to the Declaration of Elissa Miller dated January 25, 2021 submitted in Support of 6 Emergency Motion to Approve Settlement.R. Evid 602, 801, 901 18 expedited basis because ACTS, in violation of 19 the ethical rules governing California The Trustee lacks personal 20 attorneys, has recently sent unsolicited emails knowledge of this 21 containing a number of misrepresentations to statement and the statement 22 the Debtor’s and Frantz’s joint clients in the lacks foundation and is 23 Southern California Gas Leak Litigation inadmissible hearsay and 24 seeking to convert the clients to its own, speculation.Attorneys for Defendant ABIR COHEN 11 TREYZON SALO, LLP, and BORIS TREYZON

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1 Boris Treyzon, Esq. (State Bar No.188893) 2 ABIR COHEN TREYZON SALO, LLP 16001 Ventura Blvd, 3 Los Angeles, CA 91436 Telephone: (310) 407-7888 4 E-Mail: Btreyzon@actslaw.com 5 Attorneys for Defendants Boris Treyzon And Abir Cohen Treyzon Salo, LLP 6 7 UNITED STATES BANKRUPTCY COURT 8 CENTRAL DISTRICT OF CALIFORNIA 9 LOS ANGELES DIVISION 10 In Re CASE NO. 2:20-bk-21022-BR 11 [Chapter 7] GIRARDI KEESE 12 EVIDENTIARY OBJECTIONS TO Debtor. DECLARATION OF ELISSA MILLER 13 DATED JANUARY 25, 2021 IN SUPPOR OF MOTION TO APPROVE 14 _____________________________________ SETTLEMENT _____________________________________ 15 ELISSA D. MILLER, Chapter 7 Trustee for the bankruptcy estate of Girardi Keese, 16 Plaintiff, 17 v. Date: February 2, 2021 18 Time: 10:00 a.m. ABIR COHEN TREYZON SALO, LLP, a Ctrm.: 1668 via ZoomGov 255 E. Temple 19 California limited liability partnership; and Street Los Angeles, CA 90012 BORIS TREYZON, an individual, 20 Web Address: Defendants. https://cacb.zoomgov.com/j/1614873359 21 Meeting ID: 1614873359 Password: 123456 22 Telephone: (669) 254-5252 (San Jose) (646) 828-7666 (New York) 23 24 25 26 27

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1 TO THE HONORABLE BARRY RUSSELL, UNITED STATES BANKRUPTCY 2 JUDGE, ELISSA MILLER, INTERIM CHAPTER 7 TRUSTEE, THE OFFICES OF THE 3 UNITED STATES TRUSTEE AND ALL OTHER INTERESTED PARTIES: 4 Abir Cohen Treyzon Salo, LLP and Boris Treyzon hereby submits the following 5 objections to the Declaration of Elissa Miller dated January 25, 2021 submitted in Support of 6 Emergency Motion to Approve Settlement. 7 I. Various Portions of the January 25, 2021 Miller Declaration are Inadmissibl8 Under the Federal Rules of Evidence. 9 The Court should not consider portions of the January 25, 2021 Elissa Miller Declaratio10 because portions of the Declaration are inadmissible and should be disregarded. Evidence 11 submitted to the Court on motion practice must meet all requirements for admissibility of 12 evidence as if offered at the time of trial. Beyene v. Coleman Sec. Services, Inc., 854 F.2d 1179,13 1181-82 (9th Cir. 1988). Testimonial evidence must be based on personal knowledge of the 14 witness offering the evidence. Fed. R. Evid. 602. The January 25, 2021 Miller Declaration fails15 to meet the criteria as set forth above. 16 Proffered Evidence Objection 17 1. Miller Decl., ¶ 11. Relief is necessary on an Fed. R. Evid 602, 801, 901 18 expedited basis because ACTS, in violation of 19 the ethical rules governing California The Trustee lacks personal 20 attorneys, has recently sent unsolicited emails knowledge of this 21 containing a number of misrepresentations to statement and the statement 22 the Debtor’s and Frantz’s joint clients in the lacks foundation and is 23 Southern California Gas Leak Litigation inadmissible hearsay and 24 seeking to convert the clients to its own, speculation. Moreover, 25 despite knowing that the clients are currently Ms. Miller is not 26 represented by both the Debtor and Frantz. I competent to opine as an 27 am informed and belief that approximately 50 expert in attorney ethics.

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1 families have been tricked into signing 2 retainer agreements with ACTS, and it is 3 feared that more will follow suit as a result of 4 the unethical behavior of ACTS. (21:4-11) 5 6 7 Dated: January 29, 2021 ABIR COHEN TREYZON SALO, LLP 8 9 By: _________/s/ Boris Treyzon__________ 10 Boris Treyzon, Esq. Attorneys for Defendant ABIR COHEN 11 TREYZON SALO, LLP, and BORIS TREYZON 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27

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