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Full title: Stipulation By Elissa Miller (TR) and Maltzman & Partners, PA, on behalf of defendant in the underlying action, enter into Stipulation Confirming Pre-Petition Agreement and Authorization of Payment of Fees and Expenses to be Disbursed to the Estate with Proof of Service Filed by Trustee Elissa Miller (TR) (Ekvall, Lei Lei) (Entered: 02/09/2021)

Document posted on Feb 8, 2021 in the bankruptcy, 11 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

Elissa D. Miller, the chapter 7 trustee of the bankruptcy estate of Girardi Keese 21 (the "Trustee"), by and through her attorneys, Hickey Law Firm, P.A. ("Hickey"), on behal22 of plaintiff in the underlying action, and Maltzman & Partners, PA ("Maltzman"), on behalf23 of defendant in the underlying action, enter into this Stipulation Confirming Pre-Petition 24 Agreement and Authorizing Payment of Fees and Expenses to be Disbursed to the 25 Estate (the "Stipulation") as follows: 26 RECITALS 27 A. On December 18, 2020 (the "Petition Date"), an involuntary chapter 7 1 of the involuntary petition, Debtor was counsel of record in a significant number of 2 matters which were undertaken on a contingency basis.3 Hickey Law Firm P.A. is authorized to disburse the proceeds of the gross settlement to 4 the client, Jane Doe, and to Hickey Law Firm, P.A. in accordance with the attached 5 redacted closing statement 6 2. Notwithstanding the November 13, 2020, letter from CAL, Hickey Law Firm 7 P.A. is authorized and directed to remit the payment due to the Debtor to Elissa D. Miller 8 Chapter 7 Trustee of the Bankruptcy Estate of Girardi Keese, to and for the benefit of the 9 Debtor’s estate, and any interest of CAL and any other purported lien holder on any such10 proceeds, does not attach to the proceeds of the settlement due to the client/plaintiff or t11 Hickey Law Firm, P.A. 2 0 0 92626 4 445-1 1123 IT IS SO STIPULATED. SERVED BY UNITED STATES MAIL: n (date) February 9, 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.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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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 IGnI RreA RDI KEESE, CChaasep tNero 7. 2:20-bk-21022-BR ornia ax 71 a, Calif00 • F 14 SPETITPITUILOANT AIOGNR CEOEMNFEINRTM AINNGD P RE-s0 15 AUTHORIZING PAYMENT OF FEES e1 M5- AND EXPENSES TO BE DISBURSED a 4 ost4 4 16 TO THE ESTATE C71 Debtor. el 17 [No Hearing Required] T 18 19 TO THE HONORABLE BARRY RUSSELL, UNITED STATES BANKRUPTCY JUDGE20 Elissa D. Miller, the chapter 7 trustee of the bankruptcy estate of Girardi Keese 21 (the "Trustee"), by and through her attorneys, Hickey Law Firm, P.A. ("Hickey"), on behal22 of plaintiff in the underlying action, and Maltzman & Partners, PA ("Maltzman"), on behalf23 of defendant in the underlying action, enter into this Stipulation Confirming Pre-Petition 24 Agreement and Authorizing Payment of Fees and Expenses to be Disbursed to the 25 Estate (the "Stipulation") as follows: 26 RECITALS 27 A. On December 18, 2020 (the "Petition Date"), an involuntary chapter 7

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1 of the involuntary petition, Debtor was counsel of record in a significant number of 2 matters which were undertaken on a contingency basis. 3 B. The petitioning creditors moved for the appointment of an interim trustee 4 which was granted by the Court by order entered January 5, 2021. The Trustee was 5 appointed as the interim chapter 7 trustee on January 6, 2021. The order for relief was 6 entered January 13, 2021 and, the same date, the Trustee was reappointed and has 7 been serving in that capacity since. 8 C. Prior to the petition date, Debtor commenced an action on behalf of its 9 client entitled Jane Doe v. Princess Cruise Lines, Ltd, Case No. 2:19-cv-09281-JFW-AF10 (the "Litigation"). In or about July 2020, the Litigation was resolved and the parties 11 entered into a Confidential General Release of All Claims, Indemnity and Hold Harmless 2 0 0 92626 4 445-1 1123 AgreemDe. nt. Plaintiff's counsel, Hickey Law Firm, P.A. ("Hickey") and the Debtor have ornia ax 71 a, Calif00 • F 14 executed a closing statement which sets out the amounts and timing for the payment of s0 15 their attorneys' fees and expenses by the Defendant. The first of two installments has e1 M5- a 4 ost4 4 16 been paid. The second installment was originally due on January 31, 2021. However, C1 7 el 17 plaintiff and defendant agreed to extend the time of payment of the second installment toT 18 and including February 15, 2021, to allow for this stipulation to be negotiated, executed 19 and approved by the Bankruptcy Court. 20 E. In a letter dated November 13, 2020, California Attorney Lending II ("CAL")21 asserted a claim to "any and all fees and other non-reimbursable expense payments due22 to the Debtors" related to the Litigation. 23 F. In light of CAL's demand, defendant is reluctant to remit the fees and costs24 provided for in the Closing Statement to the Trustee without a court order. 25 26 STIPULATION 27 In light of the foregoing, the parties stipulate as follows:

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1 1. Defendant in the underlying matter may forward payment of the last 2 installment of the gross settlement proceeds to Hickey Law Firm, P.A.’s trust account. 3 Hickey Law Firm P.A. is authorized to disburse the proceeds of the gross settlement to 4 the client, Jane Doe, and to Hickey Law Firm, P.A. in accordance with the attached 5 redacted closing statement 6 2. Notwithstanding the November 13, 2020, letter from CAL, Hickey Law Firm 7 P.A. is authorized and directed to remit the payment due to the Debtor to Elissa D. Miller 8 Chapter 7 Trustee of the Bankruptcy Estate of Girardi Keese, to and for the benefit of the 9 Debtor’s estate, and any interest of CAL and any other purported lien holder on any such10 proceeds, does not attach to the proceeds of the settlement due to the client/plaintiff or t11 Hickey Law Firm, P.A. 2 0 0 92626 4 445-1 1123 IT IS SO STIPULATED. ornia ax 71 a, Calif00 • F 14 DATED: February 9, 2021 SMILEY WANG-EKVALL, LLP s0 15 e1 M5- osta 4 44 16 By: /s/ Lei Lei Wang Ekvall C1 LEI LEI WANG EKVALL 7 el 17 Attorneys for Elissa D. Miller, Chapter 7 T Trustee 18 DATED: February ___, 2021 HICKEY LAW FIRM, P.A. 19 20 By: 21 JOHN H. HICKEY 22 23 DATED: February __, 2021 MALTZMAN & PARTNERS, PA 24 25 By: JEFFREY B. MALTZMAN 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): STIPULATION CONFIRMING PREPETITION GREEMENT AND AUTHORIZING PAYMENT OF FEES AND EXPENSES TO BE DISBURSED TO THE ESTATE ill be served or was served (a) on the judge in chambers in the form and manner required by LBR 5005-2(d); and (b) in the anner 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 9, 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 9, 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 9, 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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