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Full title: Declaration re: of Lei Lei Wang Ekvall in Support of Stipulation Confirming Pre-Petition Agreement and Authorizing Payment of Fees and Expenses to be Disbursed to the Estate with Proof of Service Filed by Trustee Elissa Miller (TR) (RE: related document(s)172 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 Estat). (Ekvall, Lei Lei) (Entered: 02/09/2021)

Document posted on Feb 8, 2021 in the bankruptcy, 5 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

In a letter dated November 13, 2020, California Attorney Lending II ("CAL")26 asserted a claim to "any and all fees and other non-reimbursable expense payments due27 to the Debtors" related to the Litigation.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.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. Kenneth Miller kmiller@pmcos.com, efilings@pmcos.com  Elissa Miller (TR) CA71@ecfcbis.com, MillerTrustee@Sulmeyerlaw.com;C124@ecfcbis.com;ccaldwell@sulmeyerlaw.com 

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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 DEKECVALALLR AINT ISOUNP OPOF RLTE IO LFE I WANG s0 15 STIPULATION CONFIRMING PRE- e1 M5- PETITION AGREEMENT AND a 4 ost4 4 16 AUTHORIZING PAYMENT OF FEES C71 Debtor. AND EXPENSES TO BE DISBURSED el 17 TO THE ESTATE T 18 [No Hearing Required] 19 20 I, Lei Lei Wang Ekvall, declare: 21 1. I am a partner with Smiley Wang-Ekvall, LLP, attorneys for Elissa D. Miller,22 Chapter 7 Trustee of the bankruptcy estate of Girardi Keese (the "Trustee"). I am 23 licensed to practice before this Court and the courts of the State of California. I know 24 each of the following facts to be true of my own personal knowledge, except as otherwis25 stated and, if called as a witness, I could and would competently testify with respect 26 thereto. I make this declaration in support of the Stipulation Confirming Pre-Petition 27 Agreement and Authorizing Payment of Fees and Expenses to be Disbursed to the

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1 Estate (the "Stipulation"). Unless otherwise defined in this declaration, all terms defined 2 in the Stipulation are incorporated herein by this reference. 3 2. According to the Court's docket, on December 18, 2020, an involuntary 4 chapter 7 bankruptcy petition was filed against Girardi Keese ("Debtor"). As of the filing 5 of the involuntary petition, Debtor was counsel of record in a significant number of 6 matters which were undertaken on a contingency basis. 7 3. The petitioning creditors moved for the appointment of an interim trustee 8 which was granted by the Court by order entered January 5, 2021. The Trustee was 9 appointed as the interim chapter 7 trustee on January 6, 2021. The order for relief was 10 entered January 13, 2021 and, the same date, the Trustee was reappointed and has 11 been serving in that capacity since. 2 0 0 92626 4 445-1 1123 action o4n. behIa alf mof aitdsv cislieedn tt heantt iptlerido rJ taon teh eD poeet ivti.o Pnr dinactees, sth Cer uDieseb tLoirn ceosm, Lmtde,n Cceads ea n ornia ax 71 a, Calif00 • F 14 No. 2:19-cv-09281-JFW-AFM (the "Litigation"). In or about July 2020, the Litigation was s0 15 resolved and the parties entered into a Confidential General Release of All Claims, e1 M5- a 4 ost4 4 16 Indemnity and Hold Harmless Agreement. C1 7 el 17 5. According to Plaintiff's counsel, Hickey Law Firm, P.A. ("Hickey"), pre-T 18 petition, the Debtor executed a closing statement which sets out the amounts and timing 19 for the payment of their attorneys' fees and expenses by the Defendant. A copy of the 20 redacted closing statement provided to me by Hickey is attached to the Stipulation. The 21 first of two installments has been paid. The second installment was originally due on 22 January 31, 2021. However, plaintiff and defendant agreed to extend the time of 23 payment of the second installment to and including February 15, 2021, to allow for the 24 Stipulation to be negotiated, executed and approved by the Bankruptcy Court. 25 6. In a letter dated November 13, 2020, California Attorney Lending II ("CAL")26 asserted a claim to "any and all fees and other non-reimbursable expense payments due27 to the Debtors" related to the Litigation.

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1 7. In light of the Debtor's bankruptcy and CAL's demand, the defendant is 2 reluctant to remit the fees and costs provided for in the Closing Statement to the Trustee3 without a court order. 4 I declare under penalty of perjury under the laws of the United States of America 5 that the foregoing is true and correct to the best of my knowledge. 6 Executed on this 9th day of February, 2021, at Costa Mesa, California. 7 /s/ Lei Lei Wang Ekvall 8 LEI LEI WANG EKVALL 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

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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): DECLARATION OF LEI LEI WANG EKVALL IN UPPORT OF STIPULATION CONFIRMING PREPETITION AGREEMENT AND AUTHORIZING PAYMENT OF FEES AND XPENSES TO BE DISBURSED TO THE ESTATE will be served or was served (a) on the judge in chambers in the form and anner 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 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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