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Full title: Motion for Order Authorizing Chapter 7 Trustee to Operate the Business of the Debtor on a Limited Basis Pursuant to 11 U.S.C. § 721 and Maintain Current Status of Certain Trust Accounts and for Other Relief; Memorandum of Points and Authorities; Declaration of Elissa D. Miller in Support with Proof of Service Filed by Trustee Elissa Miller (TR) (Ekvall, Lei Lei) (Entered: 02/02/2021)
Document posted on Feb 1, 2021 in the bankruptcy, 16 pages and 0 tables.
Bankrupt11 Summary (Automatically Generated)
In addition to deposit and operating accounts, the Trustee has determined that th 5 Debtor maintained the following accounts at the following banks: 6 i. 24 required to effectuate the release of funds and/or payments;3 25 2 The Trustee is continuing to interview former employees and review the Debtor's 26 books and records to ascertain whether other bank accounts exist. T6 date, the Trustee has identified that the Debtor maintained accounts at a minimum of fiv7 banks.Authorizing the Trustee to delegate the authority for the release of funds in 22 the minors blocked accounts to the banks where the accounts are held and excusing the23 Trustee from posting a bond for the funds held in such minors blocked accounts, or 24 alternatively, authorizing the Trustee to sign off on the liquidation of the account upon 25 receipt of proper documentation from the beneficiary; and 26 6.Specifically, I have determined that in addition to deposit and operating24 accounts, the Debtor maintained the following accounts at the following banks: 25 i. Citizens Business Bank - blocked minor accounts, IOLTA (State Bar26 Trust Accounts) and a trust account for the benefit of four clients27 ii.
List of Tables
Document Contents1 SMILEY WANG-EKVALL, LLP Lei Lei Wang Ekvall, State Bar No. 163047 2 firstname.lastname@example.org Philip E. Strok, State Bar No. 169296 3 email@example.com Timothy W. Evanston, State Bar No. 319342 4 firstname.lastname@example.org 3200 Park Center Drive, Suite 250 5 Costa Mesa, California 92626 Telephone: (714) 445-1000 6 Facsimile: (714) 445-1002 7 Attorneys for Elissa D. Miller, Chapter 7 Trustee 8 UNITED STATES BANKRUPTCY COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 LOS ANGELES DIVISION 11 2 In re Case No. 2:20-bk-21022-BR 0 0 92626 4 445-1 1123 G IRARDI KEESE, C hapter 7 ornia ax 71 Debtor. MOTION FOR ORDER AUTHORIZING a, Calif00 • F 14 CTHHEA PBTUESRIN 7E TSRSU OSFT ETHE ET OD EOBPTEORRA OTEN A s0 15 LIMITED BASIS PURSUANT TO 11 e1 M5- U.S.C. § 721 AND MAINTAIN CURRENT a 4 ost4 4 16 STATUS OF CERTAIN TRUST C1 7 ACCOUNTS AND FOR OTHER RELIEF; el 17 MEMORANDUM OF POINTS AND T AUTHORITIES; DECLARATION OF 18 ELISSA D. MILLER IN SUPPORT 19 [No Hearing Required Pursuant to Local Bankruptcy Rule 9013-1(o)] 20 21 22 / / / 23 / / / 24 / / / 25 / / / 26 / / / 27 / / /
11 TABLE OF CONTENTS Pag 2 3 I. INTRODUCTION .................................................................................................... 4 II. FACTUAL BACKGROUND ..................................................................................... 5 A. The Debtor's Involuntary Bankruptcy Case .................................................. 6 B. The Debtor's Cases ...................................................................................... 7 C. The Bank Accounts ...................................................................................... 8 III. LIMITED OPERATING RELIEF REQUESTED ....................................................... 9 IV. MEMORANDUM OF POINTS AND AUTHORITIES ............................................... 10 V. CONCLUSION ........................................................................................................ 11 2 0 0 92626 4 445-1 1123 ornia ax 71 a, Calif00 • F 14 s0 15 e1 M5- a 4 ost4 4 16 C1 7 el 17 T 18 19 20 21 22 23 24 25 26 27
21 TABLE OF AUTHORITIES 2 Pag 3 CASES 4 In re Nakhuda, 2015 WL 873566 (B.A.P. 9th Cir. 2015) .................................................... 5 6 STATUTES 7 11 U.S.C. § 303(g) ............................................................................................................. 8 11 U.S.C. § 721 ....................................................................................................... 2, 8, 19 10 TREATISES 11 2 6 Collier on Bankruptcy ¶ 721.01 (Alan N. Resnick & Henry J. Sommer eds., 16th 0 0 92626 4 445-1 1123 ed. 2012) ................................................................................................................. ornia ax 71 a, Calif00 • F 14 s0 15 e1 M5- a 4 ost4 4 16 C1 7 el 17 T 18 19 20 21 22 23 24 25 26 27
31 TO THE HONORABLE BARRY RUSSELL, UNITED STATES BANKRUPTCY JUDGE: 2 Elissa D. Miller, the chapter 7 trustee (the "Trustee") of the bankruptcy estate of 3 Girardi Keese (the "Estate"), submits this Motion for Order Authorizing Chapter 7 Truste4 to Operate the Business of the Debtor on a Limited Basis Pursuant to 11 U.S.C. § 721 5 and Maintain Current Status of Certain Trust Accounts and for Other Relief (the 6 "Motion"). In support of the Motion, the Trustee submits the following memorandum of 7 points and authorities and the attached Declaration of Elissa D. Miller. 8 9 I. INTRODUCTION 10 Girardi Keese (the "Debtor") was once a thriving plaintiff's law firm based in Los 11 Angeles, California, practicing in the areas of personal injury, defective products, sexual 2 0 0 92626 4 445-1 1123 aasb uhsaes, btoexeicn teoxrthsa, ubsutisvineelys rse lpaowrt,e edm inp lothyem menetd liaaw, t,h ainngds a hvaiavteio cnh laanwg. e dU ndfroarstutincaaltleyl yfo, ra tnhde ornia ax 71 a, Calif00 • F 14 Debtor and its founding partner, Thomas Girardi. Recent events led to commencement s0 15 of involuntary petitions against both the Debtor and Mr. Girardi. At that time, the Debtor'e1 M5- a 4 ost4 4 16 operations were greatly diminished, with most of the attorneys and staff having resigned C1 7 el 17 or moved on from the Debtor. The Debtor, however, was and remains counsel of recordT 18 in a significant number of litigation cases which were undertaken on a contingency basis. 19 The Trustee and her counsel have worked tirelessly to investigate, review and 20 analyze the scope and status of the cases, which are at varying litigation stages. The 21 Trustee and her counsel have also interviewed a number of reputable law firms that may22 be interested in taking over some or all of the cases. This process is ongoing with the 23 ultimate goal being the orderly transition of cases to other counsel while protecting the 24 clients' interests. Among the cases are those that have settled or where settlement is 25 imminent, and those that have been reduced to judgment (collectively, the "Resolved 26 Cases"). There are also cases where clients of the Debtor have terminated or will 27 terminate their relationship with the Debtor and engaged or will engage substitute
41 By this Motion, the Trustee seeks: 2 1. Authority to operate the business of the Debtor on a limited basis for a 3 period of six months from the date the Trustee accepted her appointment on January 13,4 2021; 5 a. With respect to the Resolved Cases, the Trustee seeks authority to 6 take all reasonable steps and execute all documents necessary to issue to clients their 7 agreed-upon portion of funds remitted to the Debtor and/or Trustee related to the 8 Resolved Cases. 9 b. As to the Terminated Cases, the Trustee seeks authority to take all 10 reasonable steps and execute all documents necessary to protect the client's interest in 11 having files transitioned to the client and preserve the Estate's interest in legal fees and 2 0 0 92626 4 445-1 1123 costs to2 .w hichA tuhteh oErsittya tteo ims aeinnttiatliend S. t a te Bar IOLTA Client Trust Accounts and over 100 ornia ax 71 a, Calif00 • F 14 blocked minor accounts at the banks where the accounts are currently located provided s0 15 that the accounts are at U.S. Trustee approved depositories on the terms and conditionse1 M5- a 4 ost4 4 16 set forth herein; and C1 7 el 17 3. With respect to the approximately 100 blocked minors accounts at CitizensT 18 Business Bank ("CBB"), authorize CBB to release the funds to the minors/beneficiaries 19 without further signature required from the Debtor, via the Trustee, upon presentation of 20 appropriate identification and documentation. Alternatively, to authorize the Trustee to 21 sign off on the liquidation of the account upon receipt of proper documentation. The 22 Estate has no interest whatsoever in the funds in these accounts. 23 These actions will preserve and protect Estate assets and are consistent with an 24 orderly liquidation. Accordingly, the Trustee respectfully requests the Court grant the 25 Motion. 26 27
51 II. FACTUAL BACKGROUND 2 A. The Debtor's Involuntary Bankruptcy Case 3 The Debtor is a plaintiff's law firm based in Los Angeles, California. On Decembe4 18, 2020, petitioning creditors Jill O'Callahan, as successor in interest to James 5 O'Callahan, Robert M. Keese, John Abassian, Erika Saldana, Virginia Antonio, and 6 Kimberly Archie (collectively, the "Petitioning Creditors") filed an involuntary chapter 7 7 bankruptcy petition against the Debtor.1 A status conference on the involuntary petition 8 was scheduled for February 16, 2021. 9 On December 24, 2020, the Petitioning Creditors filed a Motion for Appointment o10 Interim Trustee Pursuant to 11 U.S.C. § 303(g) [Docket No. 12]. The Court entered an 11 order granting the motion on January 5, 2021 [Docket No. 45]. On January 6, 2021, the 2 0 0 92626 4 445-1 1123 TrusteeO wn aJsa naupaproyin 1te3d, 2a0s2 t1h,e t hinet eCroimu rttr uesntteeere [dD aonck Oetr dNeor .D 5i0re].c t ing: (1) The Clerk of Courornia ax 71 a, Calif00 • F 14 to Immediately Enter an Order for Relief under Chapter 7; (2) The United States Trustee s0 15 to Immediately Appoint a Chapter 7 Trustee; (3) The Debtor to File All Schedules and e1 M5- a 4 ost4 4 16 Related Documentation for Chapter 7 Case within Fourteen Days of the Entry of this C1 7 el 17 Order; and (4) Vacating February 16, 2021 Status Conference [Docket No. 68]. On T 18 January 13, 2021, the Clerk of Court entered an order for relief against the Debtor 19 [Docket No. 69], and the Trustee was appointed and accepted her appointment in the 20 Debtor's case [Docket No. 71]. 21 B. The Debtor's Cases 22 As of the commencement of the involuntary petition, the Debtor was counsel of 23 record in a significant number of cases which were undertaken on a contingency basis. 24 These cases are at varying stages and include the Resolved Cases. The Terminated 25 26 1 The Petitioning Creditors also filed an involuntary chapter 7 bankruptcy petition 27 against Thomas V. Girardi, which is currently pending as Bankruptcy Case No. 2:20-bk-21020-BR.
61 Cases are those cases where clients have or will terminate their relationship with the 2 Debtor and engage with substitute counsel. See Declaration of Elissa D. Miller. 3 C. The Bank Accounts 4 In addition to deposit and operating accounts, the Trustee has determined that th 5 Debtor maintained the following accounts at the following banks: 6 i. Citizens Business Bank - blocked minor accounts, IOLTA (State Bar 7 Trust Accounts) and a trust account for the benefit of four clients 8 ii. Torrey Pines Bank - minors accounts 9 iii. Wells Fargo- blocked minors accounts; and 10 iv. Citibank - a blocked settlement account.2 11 See Declaration of Elissa D. Miller. 2 0 0 92626 4 445-1 1123 III. TLhIMe ITTEruDs teOeP sEeReAksT IaNuGth RorEityL ItEoF o RpeErQatUe EthSeT bEuDs iness of the Debtor on a limited ornia ax 71 a, Calif00 • F 14 basis for a period of six months from the date the Trustee accepted her appointment on s0 15 January 13, 2021 as set forth in more detail below. e1 M5- a 4 ost4 4 16 A. The Resolved Cases C1 7 el 17 With respect to the Resolved Cases, the Trustee seeks authority to take all T 18 reasonable actions and execute all documents necessary to issue to clients their agreed19 upon portion of funds remitted to the Debtor and/or Trustee related to the Resolved 20 Cases. This authorization would include, without limitation, authority for the Trustee to: 21 (1) Accept and negotiate funds and/or payments made to the Debtor 22 and/or Trustee on behalf of a client(s); 23 (2) Negotiate and pay any liens (e.g. medical liens, attorney's liens, etc. 24 required to effectuate the release of funds and/or payments;3 25 2 The Trustee is continuing to interview former employees and review the Debtor's 26 books and records to ascertain whether other bank accounts exist. 27 3 The Trustee is not seeking authorization to pay liens against property of the Debtor's Estate, only those liens specific to the Resolved Case at issue such as medical
71 (3) Issue to a client(s) the agreed-upon portion of any funds and/or 2 payments made to the Debtor and/or Trustee on behalf of a client(s) consistent with 3 applicable agreements; 4 (4) Take any other reasonable actions and execute all documents 5 necessary to effectuate the issuance of funds and/or payments to the Debtor's client(s); 6 and 7 (5) Hold in the Estate the funds remaining after payment to the client(s) 8 which would include the Debtor's fees and costs consistent with applicable agreements. 9 B. The Terminated Cases 10 As to the Terminated Cases, the Trustee seeks authority to take all reasonable 11 actions and execute all documents necessary to protect the client's interest in having file2 0 0 92626 4 445-1 1123 twrahnicshit itohnee Ed sttoa tteh eis c elienntittl eadn.d Tphreiss earuvteh othriez aEtisotna twe'osu inldt einrecslut dine ,l ewgiathl ofeuet sli manitadt icoons,t sa utoth orityornia ax 71 a, Calif00 • F 14 for the Trustee to: s0 15 (1) Upon request, transfer files to the client(s), or new counsel upon e1 M5- a 4 ost4 4 16 appropriate proof of engagement; C1 7 el 17 (2) Execute any documents reasonably necessary to effectuate a T 18 substitution of attorney; 19 (3) Employ file clerks or IT personnel, as independent contractors, to 20 facilitate the transfer of client files to the client(s) or successor counsel;4 21 (4) Obtain appropriate insurance, including liability insurance; 22 (5) Take any other reasonable actions and execute all documents 23 necessary to effectuate the orderly transition of client files; and 24 liens and only after receiving and reviewing proper documentation as to the lien holder 25 and the amount of the lien. 26 4 As there are various lenders who assert secured claims against various assets of the Estate, the Trustee anticipates filing in the near future a motion for authority to use 27 cash collateral to fund these necessary expenses of limited operations and will identify such individuals, their hourly rates and a proposed budget in the cash collateral motion.
81 (6) Take all reasonable actions to protect and preserve the legal fees 2 and costs to which the Estate is entitled including, without limitation, the filing of notices 3 of lien for legal fees and costs. 4 C. BANK ACCOUNTS 5 The Trustee has been collecting information as to the Debtor's bank accounts. T6 date, the Trustee has identified that the Debtor maintained accounts at a minimum of fiv7 banks. The accounts include: (1) general firm accounts; (2) those labeled as client trust 8 accounts whether or not they truly are such; (3) State Bar of California IOLTA accounts; 9 (4) about 100 minors blocked accounts at Citizens Business Bank; and (5) a blocked 10 settlement account at Citibank.5 See Declaration of Elissa D. Miller. 11 With regard to the general account and those labeled "client trust" accounts, the 2 0 92626 4 445-10 1123 Trerguastrede t ois t hmeo IvOinLgT Ath oascec ofuunndtss, ttoh etr umsinteoer sa bccloocuknetds aucncdoeur nhtesr, aconndt raonl.y6 s Hetotlweemveenr,t wbliothc kedornia ax 71 a, Calif00 • F 14 accounts, the Trustee requests authority to allow those accounts to remain at the currents0 15 banks provided that such bank is an approved depository and subject to confirmation by e1 M5- a 4 ost4 4 16 the United States Trustee's Office that such bank is appropriately collateralized. The C1 7 el 17 banks where the known IOLTA accounts, the minors blocked accounts, and the T 18 settlement blocked account are held have been notified of the bankruptcy and have 19 placed a hold or freeze on the accounts. 20 With respect to minors blocked accounts, the Debtor has no interest in the funds, 21 although they are under the Debtor’s Tax ID Number. The Debtor's only obligation is to 22 sign a release upon proof that the beneficiary is 18 years old. The Trustee is requesting 23 authority to delegate that function to the bank so that the Estate has no obligation 24 whatsoever with respect to these accounts. See Declaration of Elissa D. Miller. In fact, 25 the accounts are a liability as the accounts are interest bearing, and the Debtor has to 26 5 As of this date, these are the only such accounts the Trustee has identified. 27 6 With the exception of the one trust account for the benefit of four clients at CBB.
91 report the income, notwithstanding that the income runs with the account to the minor. 2 As the Estate has no property interest in these accounts, the Trustee contends that if the3 bank takes over the authority, the Estate should not bear the obligation of having to post 4 a bond for the funds in these minors accounts. 5 With respect to the IOLTA accounts, the Trustee seeks an order authorizing the 6 Trustee to designate the Trustee as the sole signatory and directing the banks where the7 accounts are held to comply with the Trustee's change of signatory requests. The 8 Trustee will ensure that the amount of her bond is not only sufficient to cover the amount9 in her account but also the amounts in the IOLTA accounts and all other accounts 10 wherever maintained. See Declaration of Elissa D. Miller. 11 D. Additional Operating Relief 2 0 0 92626 4 445-1 1123 the DebTthoer iTnr ucsatseees awlshoe rsee ethkes Dauetbhtoorri twy atos fciloeu nnosteicl eosf roefc loiernd fsohro luelgda sl hfeee dse aenmd ict osts of ornia ax 71 a, Calif00 • F 14 necessary in her sole and absolute discretion. s0 15 e1 M5- a 4 ost4 4 16 IV. MEMORANDUM OF POINTS AND AUTHORITIES C1 7 el 17 Under 11 U.S.C. § 721, "[t]he court may authorize the trustee to operate the T 18 business of the debtor for a limited period, if such operation is in the best interest of the 19 estate and consistent with the orderly liquidation of the estate." See also In re Nakhuda,20 2015 WL 873566 at *2 (B.A.P. 9th Cir. 2015) citing 11 U.S.C. § 721 and 6 Collier on 21 Bankruptcy ¶ 721.01 (Alan N. Resnick & Henry J. Sommer eds., 16th ed. 2012). 22 Authorizing the Trustee to operate the Debtor's business on a limited basis is in 23 the best interest of the Estate and promotes orderly liquidation. See Declaration of Eliss24 D. Miller. As to the Resolved Matters, the relief requested will allow the Debtor's clients 25 to receive funds to which they are entitled without significant delay. Disbursement of 26 client funds also allows the Trustee to set aside and preserve legal fees and costs owed 27 to the Debtor. Further, empowering the Trustee to file notices of lien for legal fees and
101 client files and sign substitutions of attorney promotes the orderly transition of the 2 Terminated Cases. In short, allowing the Trustee to operate the Debtor's business on a 3 limited basis will maximize recovery to the Estate, while also encouraging orderly 4 liquidation by preventing any dissipation of Estate assets. Thus, the Trustee requests 5 that the Court grant the Motion. 6 7 V. CONCLUSION 8 For the foregoing reasons, the Trustee respectfully requests that the Court enter 9 an order: 10 1. Granting the Motion; 11 2. Authorizing the Trustee, for a period of six months from the date the 2 0 0 92626 4 445-1 1123 TDreubsttoere o anc ace lipmteitde dh ebra asipsp aosin dtmeteanilte odn in J athneu aMroy t1io3n,; 2 021, to operate the business of the ornia ax 71 a, Calif00 • F 14 3. Authorizing the IOLTA accounts, the minors blocked accounts and the s0 15 settlement blocked accounts to remain open at the current banks where the accounts are1 M5- a 4 ost4 4 16 held, subject to the conditions set forth herein; C1 7 el 17 4. Authorizing the Trustee to be the sole signatory on the IOLTA accounts, thT 18 settlement blocked accounts, and any other account where the bank requires a court 19 order to change the signatory and directing the banks to comply with the Trustee's 20 change of signatory requests; 21 5. Authorizing the Trustee to delegate the authority for the release of funds in 22 the minors blocked accounts to the banks where the accounts are held and excusing the23 Trustee from posting a bond for the funds held in such minors blocked accounts, or 24 alternatively, authorizing the Trustee to sign off on the liquidation of the account upon 25 receipt of proper documentation from the beneficiary; and 26 6. For such other relief as the Court deems just and proper. 27
111 DATED: February 2, 2021 Respectfully submitted, 2 SMILEY WANG-EKVALL, LLP 3 4 By: /s/ Lei Lei Wang Ekvall 5 LEI LEI WANG EKVALL Attorneys for Elissa D. Miller, Chapter 7 6 Trustee 7 8 9 10 11 2 0 0 92626 4 445-1 1123 ornia ax 71 a, Calif00 • F 14 s0 15 e1 M5- a 4 ost4 4 16 C1 7 el 17 T 18 19 20 21 22 23 24 25 26 27
121 DECLARATION OF ELISSA D. MILLER 2 I, Elissa D. Miller, declare as follows: 3 1. I am the duly appointed Chapter 7 Trustee in the bankruptcy case of Girard 4 Keese. I know each of the following facts to be true of my own personal knowledge, 5 except as otherwise stated and, if called as a witness, I could and would competently 6 testify with respect thereto. I am also a partner at the law firm SulmeyerKupetz. I make 7 this declaration in support of the Motion for Order Authorizing Chapter 7 Trustee to 8 Operate the Business of the Debtor on a Limited Basis Pursuant to 11 U.S.C. § 721 and 9 Maintain Current Status of Certain Trust Accounts and for Other Relief (the "Motion"). 10 Unless otherwise defined in this declaration, all terms defined in the Motion are 11 incorporated herein by this reference. 2 0 0 92626 4 445-1 1123 against2 t.he DeAbt ttohre, tthime eD tehbet oPre rteitpiorensinegn tCerde dniutomrse rcooums mpaernticeesd i nth ae sinigvnoilfuicnatnatr ya mpeotuitinotn of ornia ax 71 a, Calif00 • F 14 cases. The Debtor represented its clients on a contingency basis. s0 15 3. Currently, the Debtor's cases are at varying stages. e1 M5- a 4 ost4 4 16 4. I have been collecting information as to the Debtor's bank accounts. ToC1 7 el 17 date, I have identified that the Debtor maintained accounts at a minimum of five banks. T 18 The accounts include: (1) general firm accounts; (2) those labeled as client trust account19 whether or not they truly are such; (3) State Bar of California IOLTA accounts; (4) about 20 100 minors blocked accounts at Citizen Business Bank; and (5) a blocked settlement 21 account at Citibank. As of this date, these are the only accounts I have been able to 22 identify. 23 5. Specifically, I have determined that in addition to deposit and operating24 accounts, the Debtor maintained the following accounts at the following banks: 25 i. Citizens Business Bank - blocked minor accounts, IOLTA (State Bar26 Trust Accounts) and a trust account for the benefit of four clients27 ii. Torrey Pines Bank - minors accounts
131 iv. Citibank - a blocked settlement account. 2 6. I am currently interviewing former employees of the Debtor and am also3 reviewing the Debtor's books and records to determine whether the Debtor had other 4 accounts. 5 7. With respect to the minors blocked accounts at Citizen’s Business Bank, I6 am informed and believe that neither the Debtor nor the Estate has any interest in those 7 accounts. Rather, the Debtor was and the Estate is obligated to: (1) sign off on the 8 delivery of the funds in the account to the beneficiary when the beneficiary turns 18 and 9 (2) account for the income earned on the accounts on its tax returns, notwithstanding tha10 the interest income inures to the benefit of the beneficiary. 11 8. I will ensure that the amount of my bond is sufficient to cover the amount of2 0 0 92626 4 445-1 1123 fsuenttdlesm ine mnt yb Tlorcuksetede a accccoouunntsts, aansd w, teoll tahse tehxet eanmt oreuqnut ihreedld, tinh eI OaLmToAu natc hceoludn itns ,t hthee m inors ornia ax 71 a, Calif00 • F 14 blocked accounts. s0 15 9. In my business judgment, I believe operating the Debtor's business on ae1 M5- a 4 ost4 4 16 limited basis as set forth in the Motion is in the best interest of the Estate and promotes C1 7 el 17 orderly liquidation of the Estate's assets. T 18 I declare under penalty of perjury under the laws of the United States of America 19 that the foregoing is true and correct. 20 Executed on this 1st day of February, 2021, at Los Angeles, California. 21 22 23 Elissa D. Miller 24 25 26 27
14PROOF 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 3200 ark Center Drive, Suite 250, Costa Mesa, CA 92626. true and correct copy of the foregoing document entitled (specify): MOTION FOR ORDER AUTHORIZING CHAPTER 7 RUSTEE TO OPERATE THE BUSINESS OF THE DEBTOR ON A LIMITED BASIS PURSUANT TO 11 U.S.C. § 721 ND MAINTAIN CURRENT STATUS OF CERTAIN TRUST ACCOUNTS AND FOR OTHER RELIEF; MEMORANDUM F POINTS AND AUTHORITIES; DECLARATION OF ELISSA D. MILLER IN SUPPORT will be served or was served (an the judge in chambers in the form and manner required by LBR 5005-2(d); and (b) in the manner stated below: .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)ebruary 2, 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) February 2, 2021 , I served the following persons and/or entities at the last known addresses in thisankruptcy case or adversary proceeding by placing a true and correct copy thereof in a sealed envelope in the Unitedtates mail, first class, postage prepaid, and addressed as follows. Listing the judge here constitutes a declaration thatailing to the judge will be completed no later than 24 hours after the document is filed. he Honorable Barry Russell .S. Bankruptcy Court oybal Federal Building 55 E. Temple Street, Suite 1660 os Angeles, CA 90012 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 served thellowing persons and/or entities by personal delivery, overnight mail service, or (for those who consented in writing touch 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. February 2, 2021 Gabriela Gomez-Cruz /s/ Gabriela Gomez-Cruz Date PrintedName Signature
15ADDITIONAL SERVICE INFORMATION (if needed): . SERVED BY THE COURT VIA NOTICE OF ELECTRONIC FILING (“NEF”) Richard D Buckley email@example.com Marie E Christiansen firstname.lastname@example.org, email@example.com,firstname.lastname@example.org Jennifer Witherell Crastz email@example.com Ashleigh A Danker Ashleigh.firstname.lastname@example.org, SDCMLFiles@DINSMORE.COM;Katrice.email@example.com Clifford S Davidson firstname.lastname@example.org, email@example.com;firstname.lastname@example.org Lei Lei Wang Ekvall email@example.com, firstname.lastname@example.org;email@example.com;firstname.lastname@example.org Richard W Esterkin email@example.com Timothy W Evanston firstname.lastname@example.org, email@example.com;firstname.lastname@example.org;email@example.com Eric D Goldberg firstname.lastname@example.org, email@example.com Andrew Goodman firstname.lastname@example.org, Goodman.AndrewR102467@notify.bestcase.com Steven T Gubner email@example.com, firstname.lastname@example.org Marshall J Hogan email@example.com, firstname.lastname@example.org Razmig Izakelian email@example.com Lewis R Landau Lew@Landaunet.com Daniel A Lev firstname.lastname@example.org, email@example.com;firstname.lastname@example.org Peter J Mastan email@example.com, SDCMLFiles@dinsmore.com;Katrice.firstname.lastname@example.org Edith R Matthai email@example.com Kenneth Miller firstname.lastname@example.org, email@example.com Elissa Miller (TR) CA71@ecfcbis.com, MillerTrustee@Sulmeyerlaw.com;C124@ecfcbis.com;firstname.lastname@example.org Eric A Mitnick MitnickLaw@aol.com, email@example.com Scott H Olson firstname.lastname@example.org, scott-olson- email@example.com,firstname.lastname@example.org,email@example.com Leonard Pena firstname.lastname@example.org, email@example.com;firstname.lastname@example.org Michael J Quinn email@example.com, firstname.lastname@example.org,email@example.com Ronald N Richards firstname.lastname@example.org, email@example.com,firstname.lastname@example.org Philip E Strok email@example.com, firstname.lastname@example.org;email@example.com;firstname.lastname@example.org United States Trustee (LA) email@example.com Eric D Winston firstname.lastname@example.org Christopher K.S. Wong email@example.com, firstname.lastname@example.org Timothy J Yoo email@example.com