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Full title: Notice of motion/application for Order: (1) Extending And/Or Establishing Deadline To File Schedules And Statement Of Financial Affairs; And (2) Authorizing Chapter 7 Trustee To Prepare And File Schedules And Statement Of Financial Affairs Pursuant To Federal Bankruptcy Rule 1007(k); Memorandum Of Points And Authorities; Declaration Of Elissa D. Miller In Support with Proof of Service Filed by Trustee Elissa Miller (TR) (RE: related document(s)164 Motion to Extend Deadline to File Schedules or Provide Required Information, and/or Plan (Case Opening Documents) Motion For Order: (1) Extending And/Or Establishing Deadline To File Schedules And Statement Of Financial Affairs; And (2) Authorizing Chapter 7 Trustee To Prepare And File Schedules And Statement Of Financial Affairs Pursuant To Federal Bankruptcy Rule 1007(k); 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)). (Ekvall, Lei Lei) (Entered: 02/05/2021)

Document posted on Feb 4, 2021 in the bankruptcy, 5 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

On December 18, 2020, petitioning creditors Jill O'Callahan, as successor in interest to James O'Callahan, Robert M. Keese, John Abassian, Erika Saldana, 8 Virginia Antonio, and Kimberly Archie (collectively, the "Petitioning Creditors") filed an involuntary chapter 7 bankruptcy petition against Girardi Keese (the "Debtor").The Motion seeks authority to prepare and file the Debtor's schedules and C1 7 statement of financial affairs and for an extension of time to do so.This review process is continuing, but given the number of cases in the 18 Debtor's inventory, the state of the Debtor's record keeping, the lack of any personnel at the Debtor that is knowledgeable and familiar with the Debtor's assets, liabilities and 19 financial affairs, and the difficulty of accurately ascertaining the Debtor's assets and liabilities from the records, the task of compiling the information to prepare the Debtor's 20 schedules and statement of financial affairs will be labor intensive and time consuming. true and correct copy of the foregoing document entitled (specify): NOTICE OF MOTION FOR ORDER: (1) EXTENDING ND/OR ESTABLISHING DEADLINE TO FILE SCHEDULES AND STATEMENT OF FINANCIAL AFFAIRS; AND (2) AUTHORIZINHAPTER 7 TRUSTEE TO PREPARE AND FILE SCHEDULES AND STATEMENT OF FINANCIAL AFFAIRS PURSUANT TO EDERAL BANKRUPTCY RULE 1007(k); MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION OF ELISSA D. ILLER IN SUPPORT will be served or was served (a) on the judge in chambers in the form and manner required by LBR 5005(d); and (b) in the manner stated below: .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.

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Document Contents

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 Timothy W. Evanston, State Bar No. 319342 4 tevanston@swelawfirm.com 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 9 UNITED STATES BANKRUPTCY COURT 10 CENTRAL DISTRICT OF CALIFORNIA 11 LOS ANGELES DIVISION 2 0 0 92626 4 445-1 1123 I GnI RreA RDI KEESE, CChaasep tNero 7. 2:20-bk-21022-BR ornia ax 71 a, Calif00 • F 14 N(1O) TEIXCTEE ONDF IMNGO TAIONND /FOORR ORDER: s0 15 ESTABLISHING DEADLINE TO FILE e1 M5- SCHEDULES AND STATEMENT OF a 4 ost4 4 16 FINANCIAL AFFAIRS; AND C71 (2) AUTHORIZING CHAPTER 7 el 17 TRUSTEE TO PREPARE AND FILE T SCHEDULES AND STATEMENT OF 18 FINANCIAL AFFAIRS PURSUANT TO Debtor. FEDERAL BANKRUPTCY 19 RULE 1007(k); OPPORTUNITY TO REQUEST A HEARING 20 [No Hearing Required Pursuant to 21 Local Bankruptcy Rule 9013-1(o)] 22 23 24 25 26 27

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1 TO THE U.S. TRUSTEE AND ALL PARTIES ENTITLED TO NOTICE: 2 PLEASE TAKE NOTICE that Elissa D. Miller, the chapter 7 trustee (the "Trustee"of the bankruptcy estate of Girardi Keese (the "Estate"), has filed a Motion for Order 3 (1) Extending and/or Establishing Deadline to File Schedules and Statement of FinancialAffairs; and (2) Authorizing Chapter 7 Trustee to Prepare and File Schedules and 4 Statement of Financial Affairs Pursuant to Federal Rule of Bankruptcy Procedure 1007(k(the "Motion"). The Trustee is requesting that the Motion be granted without a hearing a5 provided in Local Bankruptcy Rule 9013-1(o) unless a party in interest timely files and serves a written opposition to the Motion and requests a hearing. The Motion is 6 summarized as follows: 7 1. On December 18, 2020, petitioning creditors Jill O'Callahan, as successor in interest to James O'Callahan, Robert M. Keese, John Abassian, Erika Saldana, 8 Virginia Antonio, and Kimberly Archie (collectively, the "Petitioning Creditors") filed an involuntary chapter 7 bankruptcy petition against Girardi Keese (the "Debtor"). On 9 December 24, 2020, the Petitioning Creditors filed a Motion for Appointment of Interim Trustee Pursuant to 11 U.S.C. § 303(g) [Docket No. 12]. The Court entered an order 10 granting the motion on January 5, 2021 [Docket No. 45]. On January 6, 2021, the Trustewas appointed as the interim trustee [Docket No. 50]. 11 02 2. On January 13, 2021, the Clerk of Court entered an order for relief against 0 ornia 92626 ax 714 445-1 1123 tarinhecceqcl uueDidpreeetebdddt oto hhrn ee[ D SrD oacechpbkeptedootuir nN ltetoom D.( ea6,n )9E tf] i/ ilnF(e" , Ot ahGr eld,i seaDtrn e cfdboo tnrHo tR raw'seini ltciihenaifgns" ) et,sh ea[eDvn enodnac tk mhdeeaet y TNasrno uad.s f 7ttaee1der] d. e wr neTatshrsyse a ooOpff prtedhoaeeincr h tOfe oredrdn aeRtinrte ydflo i erf a, Calif00 • F 14 Rwiethlieinf , 1o4r dJaaynsu aarfyte 2r 0e,n 2tr0y2 o1f, tahned O (brd) efirl efo itrs R seclhieefd, uolre Jsa annuda rsyt a2t7e,m 2e0n2t1 o. f Tfinhaen Dcieabl taofrf adiirds es10 15 neither. M5- a 4 ost4 4 16 3. The Motion seeks authority to prepare and file the Debtor's schedules and C1 7 statement of financial affairs and for an extension of time to do so. The Trustee has beeTel 17 working to sort through all of the data to gather the details of the Debtor's business and financial affairs. This review process is continuing, but given the number of cases in the 18 Debtor's inventory, the state of the Debtor's record keeping, the lack of any personnel at the Debtor that is knowledgeable and familiar with the Debtor's assets, liabilities and 19 financial affairs, and the difficulty of accurately ascertaining the Debtor's assets and liabilities from the records, the task of compiling the information to prepare the Debtor's 20 schedules and statement of financial affairs will be labor intensive and time consuming. The Trustee estimates that it will take approximately six months to complete the task 21 although her goal is to complete them sooner. 22 DEADLINE FOR FILING AND SERVING OPPOSITION PAPERS AND REQUEST FOR A HEARING: Pursuant to LBR 9013-1(o), any party who opposes the 23 Motion may request a hearing on the Motion. The deadline to file and serve a written opposition and request for hearing is 14 days after the date of service of this notice, plus24 3 additional days if you were served by mail or pursuant to F.R.Civ.P. 5(b)(2)(D) or (F). 25 If you timely file and serve a written opposition and request for a hearing, the Trustee will file and serve a notice of hearing at least 14 days in advance of the hearing. 26 If you fail to comply with this deadline: 27 (a) The Trustee will file a declaration to indicate (1) the Motion was properly served, (2) the response period elapsed, and (3) no party filed and serve

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1 a written opposition and request for a hearing within 14 days after the date of service of the notice; 2 (b) The Trustee will lodge an order that the Court may use to grant the 3 Motion; and 4 (c) The Court may treat your failure as a waiver of your right to oppose the Motion and may grant the Motion without further hearing and notice. 5 DATED: February 5, 2021 SMILEY WANG-EKVALL, LLP 6 7 By: /s/ Lei Lei Wang Ekvall 8 LEI LEI WANG EKVALL Attorneys for Elissa D. Miller, Chapter 7 9 Trustee 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

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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 3200 ark Center Drive, Suite 250, Costa Mesa, CA 92626. true and correct copy of the foregoing document entitled (specify): NOTICE OF MOTION FOR ORDER: (1) EXTENDING ND/OR ESTABLISHING DEADLINE TO FILE SCHEDULES AND STATEMENT OF FINANCIAL AFFAIRS; AND (2) AUTHORIZINHAPTER 7 TRUSTEE TO PREPARE AND FILE SCHEDULES AND STATEMENT OF FINANCIAL AFFAIRS PURSUANT TO EDERAL BANKRUPTCY RULE 1007(k); MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION OF ELISSA D. ILLER IN SUPPORT will be served or was served (a) on the judge in chambers in the form and manner required by LBR 5005(d); and (b) in the manner stated below: . TO BE SERVED BY THE COURT VIA NOTICE OF ELECTRONIC FILING (NEF): Pursuant to controlling General rders and LBR, the foregoing document will be served by the court via NEF and hyperlink to the document. On (date) ebruary 5, 2021 I checked the CM/ECF docket for this bankruptcy case or adversary proceeding and determined that e following persons are on the Electronic Mail Notice List to receive NEF transmission at the email addresses stated elow:  Service information continued on attached pag . SERVED BY UNITED STATES MAIL: n (date) February 5, 2021 , I served the following persons and/or entities at the last known addresses in this ankruptcy case or adversary proceeding by placing a true and correct copy thereof in a sealed envelope in the United tates mail, first class, postage prepaid, and addressed as follows. Listing the judge here constitutes a declaration that ailing 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 method r 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 declaration at personal delivery on, or overnight mail to, the judge will be completed no later than 24 hours after the document is led.  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 5, 2021 Gabriela Gomez-Cruz /s/ Gabriela Gomez-Cruz Date Printed Name Signature

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ADDITIONAL SERVICE INFORMATION (if needed): . SERVED BY THE COURT VIA NOTICE OF ELECTRONIC FILING (“NEF”)  Kyra E Andrassy kandrassy@swelawfirm.com, lgarrett@swelawfirm.com;gcruz@swelawfirm.com;jchung@swelawfirm.com  Rafey Balabanian , docket@edelson.com  Richard D Buckley richard.buckley@arentfox.com  Marie E Christiansen mchristiansen@vedderprice.com, ecfladocket@vedderprice.com,marie-christiansen-4166@ecf.pacerpro.com  Jennifer Witherell Crastz jcrastz@hrhlaw.com  Ashleigh A Danker Ashleigh.danker@dinsmore.com, SDCMLFiles@DINSMORE.COM;Katrice.ortiz@dinsmore.com  Clifford S Davidson csdavidson@swlaw.com, jlanglois@swlaw.com;cliff-davidson-7586@ecf.pacerpro.com  Lei Lei Wang Ekvall lekvall@swelawfirm.com, lgarrett@swelawfirm.com;gcruz@swelawfirm.com;jchung@swelawfirm.com  Richard W Esterkin richard.esterkin@morganlewis.com  Timothy W Evanston tevanston@swelawfirm.com, gcruz@swelawfirm.com;lgarrett@swelawfirm.com;jchung@swelawfirm.com  Eric D Goldberg eric.goldberg@dlapiper.com, eric-goldberg-1103@ecf.pacerpro.com  Andrew Goodman agoodman@andyglaw.com, Goodman.AndrewR102467@notify.bestcase.com  Suzanne C Grandt suzanne.grandt@calbar.ca.gov, joan.randolph@calbar.ca.gov  Steven T Gubner sgubner@bg.law, ecf@bg.law  Marshall J Hogan mhogan@swlaw.com, knestuk@swlaw.com  Razmig Izakelian razmigizakelian@quinnemanuel.com  Lewis R Landau Lew@Landaunet.com  Daniel A Lev dlev@sulmeyerlaw.com, ccaldwell@sulmeyerlaw.com;dlev@ecf.inforuptcy.com  Peter J Mastan peter.mastan@dinsmore.com, SDCMLFiles@dinsmore.com;Katrice.ortiz@dinsmore.com  Edith R Matthai ematthai@romalaw.com  Kenneth Miller kmiller@pmcos.com, efilings@pmcos.com  Elissa Miller (TR) CA71@ecfcbis.com, MillerTrustee@Sulmeyerlaw.com;C124@ecfcbis.com;ccaldwell@sulmeyerlaw.com  Eric A Mitnick MitnickLaw@aol.com, mitnicklaw@gmail.com  Scott H Olson solson@vedderprice.com, scott-olson- 2161@ecf.pacerpro.com,ecfsfdocket@vedderprice.com,nortega@vedderprice.com  Leonard Pena lpena@penalaw.com, penasomaecf@gmail.com;penalr72746@notify.bestcase.com  Michael J Quinn mquinn@vedderprice.com, ecfladocket@vedderprice.com,michael-quinn-2870@ecf.pacerpro.com  Ronald N Richards ron@ronaldrichards.com, morani@ronaldrichards.com,justin@ronaldrichards.com  Philip E Strok pstrok@swelawfirm.com, gcruz@swelawfirm.com;1garrett@swelawfirm.com;jchung@swelawfirm.com  Boris Treyzon jfinnerty@actslaw.com, sgonzales@actslaw.com  United States Trustee (LA) ustpregion16.la.ecf@usdoj.gov  Eric D Winston ericwinston@quinnemanuel.com  Christopher K.S. Wong christopher.wong@arentfox.com, yvonne.li@arentfox.com  Timothy J Yoo tjy@lnbyb.com

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