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Full title: Application to Employ Menchaca & Company as Accountant with proof of service Filed by Trustee Elissa Miller (TR) (Miller (TR), Elissa) (Entered: 03/04/2021)

Document posted on Mar 3, 2021 in the bankruptcy, 26 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

Upon preliminary review Menchaca believes this engagement will enta14 providing accounting services to the estate, in particular, to perform a tax analysis of proceed15 received by the Trustee, to prepare necessary federal and state tax returns, resolve any tax issue16 that may arise, and providing other accounting services as may be required by the Trustee for th17 benefit of the estate.The applicant requests the employment of MENCHACA & COMPANY LLP, Certifie26 Public Accountants & Business Consultants (the "Company" or “MCO”), effective as of Marc27 2, 2021 to render accounting services to the estate, in particular, to perform a tax analysis 28 proceeds received by the Trustee, to prepare necessary federal and state income tax returns, tHACA & COMPANY LLP Exhibit 1 SUMMARY OF STAFF AND BILLING RATES FROM JUNE 1, 2017 THROUGH CURRENT TYPICAL ITEMS OF EXPENSE EXHIBIT “B” MENCHACA & COMPANY LLP FIRM PROFILE Menchaca & Company LLP is a firm of certified public accountants servicing clients throughout the Los Angeles metropolitan areas as well as other locations within California and the United States.His experience also includes tax structuring of complex business transactions, form of ownership determinations, corporate and partnership reorganizations and restructurings, dischargeability of taxes in bankruptcy and dealing with tax issues related to Chapter 7 and Chapter 11 bankruptcy filings.He is a member of the National Association of Bankruptcy Trustees, American Bankruptcy Institute, Los Angeles Bankruptcy Forum, Association of Insolvency and Restructuring

List of Tables

Document Contents

333 South Grand Avenue, Suite 3400 2 Los Angeles, California 90071 Telephone: (213) 626-2311 3 Facsimile: (213) 629-4520 4 Email: emiller@sulmeyerlaw.com 5 Chapter 7 Trustee 6 7 8 UNITED STATES BANKRUPTCY COURT 9 CENTRAL DISTRICT OF CALIFORNIA, LOS ANGELES DIVISION 10 11 In re: ) ) Case No. 2:20-bk-21022 BR 12 ) ) Chapter 7 13 GIRARDI KEESE, ) ) APPLICATION BY CHAPTER 7 14 ) TRUSTEE TO EMPLOY MENCHACA ) COMPANY LLP AS ACCOUNTANT; 15 ) AND STATEMENT OF ) DISINTERESTEDNESS 16 Debtor. ) ) [11 U.S.C § 327(a), Fed. R. Bank. P. 2014 17 ) and Loc. Bankr. R. 2014-1(b)(1)] ) 18 ) DATE: None Required ) TIME: None Required 19 ) PLACE: Courtroom “1668” ) 255 E. Temple St. 20 ) Los Angeles, CA 90012 21 22 TO THE HONORABLE BARRY RUSSELL, UNITED STATES BANKRUPTC 23 JUDGE, AND OTHER INTERESTED PARTIES: 24 Elissa D. Miller (hereinafter “Applicant”) applies to the above-captioned court for a25 order authorizing the employment of MENCHACA & COMPANY LLP, Certified Publi26 Accountants & Business Consultants (the "MCO" or "Menchaca"), to render accounting service27 to the bankruptcy estate of Girardi Keese (the “Debtor”), effective March 2, 2021, an28 respectfully represents: HACA & COMPANY LLP

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2 acting Trustee in the above-captioned bankruptcy proceeding. 3 2. In order to faithfully discharge her duties, the Applicant requires the assistanc4 and expertise of an accountant capable of rendering accounting services to the estate. 5 3. The Notice of the Application to Employ Accountant was served on the creditor6 of the estate on March 4, 2021. A copy of the notice is attached hereto as Exhibit “A” an7 incorporated herein by this reference. 8 4. Applicant has discussed with MENCHACA & COMPANY LLP, Certified Publi9 Accountants and Business Consultants (hereinafter “Menchaca” or "MCO"), its availability t10 render accounting services to the estate, and its proposed employment by the Trustee. Menchac11 has agreed to render services to the estate on the terms and conditions set forth in thi12 Application. 13 5. Upon preliminary review Menchaca believes this engagement will enta14 providing accounting services to the estate, in particular, to perform a tax analysis of proceed15 received by the Trustee, to prepare necessary federal and state tax returns, resolve any tax issue16 that may arise, and providing other accounting services as may be required by the Trustee for th17 benefit of the estate. 18 6. Menchaca’s services may include: 19 (a) Review of Debtor’s prior year income tax returns, bankruptcy petition an20 schedules and documents related to the liquidation of the estate’s assets and the transaction21 attendant thereto. 22 (b) Review and tax analysis of transactions, including capital gains calculation23 consideration of tax attributes inherited from the Debtor and other considerations of the estate’24 liquidated assets, to determine the appropriate (and most beneficial to the estate) tax treatment. 25 (c) Preparation of federal and state income tax returns to reflect the transactions 26 the estate. 27 (d) Communication with taxing authorities on behalf of the estate. 28 (e) Obtain the required tax clearance from the Internal Revenue Service for th

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2 (f) Perform any other financial analysis, investigation, general accounting service3 and address any other tax matters which may be required by the Trustee to properly administ4 the estate and maintain tax compliance. 5 7. These services entail sufficient complexities of accounting and tax issues, t6 warrant the employment of Menchaca pursuant to this Employment Application in lieu 7 utilizing the procedure set forth in Local Bankruptcy Rule 2016-2(d). 8 8. A schedule of Menchaca’s hourly rates and resume is attached hereto as Exhib9 “B” and incorporated herein by reference. Applicant is informed and believes that Menchaca’10 hourly rates are reasonable in light of current hourly rates charged by other accountants. 11 9. Menchaca understands and agrees to accept employment on grounds that its fee12 may be awarded only by application and approval by this Court after notice and a hearin13 pursuant to §330 of the Bankruptcy Code. 14 10. Menchaca is familiar with the Bankruptcy Code, the Bankruptcy rules, the Loc15 Bankruptcy Rules, and the Guidelines of the United States Trustee and will comply with them. 16 11. Menchaca has not received nor was paid a retainer from the Debtor, the estate, 17 principal of the estate, or any third party. Menchaca may only be compensated as approved b18 this Court after notice and a hearing pursuant to §330 of the Bankruptcy Code. 19 12. The court has power to authorize employment of Menchaca pursuant to 11 U.S. 20 section 327 (a); which states, in pertinent part: 21 [T]he trustee, with the court’s approval, may employ one or more . . . accountants . . . or other professional persons, that do not hold or 22 represent interest adverse to the estate, and that are disinterested persons, to represent or assist the trustee in carrying the trustee’s 23 duties under this title. 13. Applicant has attempted to determine whether Menchaca has an interest advers24 to that of the estate with regard to the matters upon which it is to engage. Attached hereto an25 made part hereof is the declaration of John J. Menchaca, which supports Applicant’s conclusio26 that no such adverse interest exists and that Menchaca is a “disinterested person” as that term i27 defined in the Bankruptcy Code. 28

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2 not have any connections with the Debtor, any insider information of the Debtor, or any relate3 entities of the Debtor or principals of the Debtor. Menchaca has not received a retainer from th4 Debtor, the estate, principal of the estate, or any third party. 5 6 WHEREFORE, Applicant respectfully requests that she be authorized to emplo7 MENCHACA & COMPANY LLP, Certified Public Accountants & Business Consultants as h8 accountant to render services as described in the foregoing Application, effective as of March 9 2021, with compensation to be paid as an administrative expense in such amounts as this Cou10 may hereinafter determine and allow. 11 12 13 DATED: March 3, 2021 /s/ Elissa D. Miller 14 Elissa D. Miller Chapter 7 Trustee 15 16 17 18 19 20 21 22 23 24 25 26 27 28

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Nos., State Bar No. & Email Address MENCHACA & COMPANY LLP 835 Wilshire Boulevard, Suite 300 Los Angeles, California 90017 Telephone: (213) 683-3317 Facsimile: (213) 683-1883 jmenchaca@menchacacpa.com Proposed Accountants for Elissa D. Miller, Chapter 7 Trustee for the Bankruptcy Estate of Girardi Keese Attorney for: UNITED STATES BANKRUPTCY COURT CENTRAL DISTRICT OF CALIFORNIA - LOS ANGELES DIVISION In re: CASE NO.: 2:20-bk-21022 BR CHAPTER: 7 GIRARDI KEESE, STATEMENT OF DISINTERESTEDNESS FOR EMPLOYMENT OF PROFESSIONAL PERSON UNDER FRBP 2014 (File with Application for Employment) [No Hearing Required] Debtor(s). . Name, address and telephone number of the professional (Professional) submitting this Statement: MENCHACA & COMPANY LLP 835 Wilshire Boulevard, Suite 300 Los Angeles, California 90017 Telephone: (213) 683-3317 . The services to be rendered by the Professional in this case are (specify): Please see attached list of services to be rendered. . The terms and source of the proposed compensation and reimbursement of the Professional are (specify): Menchaca understands and agrees to accept employment on grounds that its fees may be awarded only by application and approval by this Court after notice and a hearing pursuant to 11 U.S.C. §330 of the Bankruptcy Code

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(specify): Menchaca has not received nor was paid a retainer from the Debtor, the estate, a principal of the estate, or any third party. . The investigation of disinterestednessmade by the Professional prior to submitting this Statement consisted of(specify): Conflicts check with major secured and unsecured creditors, owners, officers and /or directors and other professionals retained in the case. . The following is a complete description of all of the Professional’s connections with the Debtor, principals of theDebtor, insiders, the Debtor’s creditors, any other party or parties in interest, and their respective attorneys andaccountants, the United States trustee, or any person employed in the office of the United States trustee (specify,attaching extra pages as necessary): NONE . The Professional is not a creditor, an equity security holder or an insider of the Debtor, except as follows (specify,attaching extra pages as necessary): NONE . The Professional is not and was not, within 2 years before the date of the filing of the petition, a director, officer oremployee of the Debtor. . The Professional does not have an interest materially adverse to the interest of the estate or of any class of creditorsor equity security holders, by reason of any direct or indirect relationship to, connection with, or interest in, the Debtoror for any other reason, except as follows (specify, attaching extra pages as necessary): NONE 0. Name, address and telephone number of the person signing this Statement on behalf of the Professional and therelationship of such person to the Professional (specify): John J. Menchaca, Managing Partner 835 Wilshire Boulevard, Suite 300 Los Angeles, California 90017 Telephone: (213) 683-3317

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Girardi Keese Case No. 2:20-bk-21022 BR The services to be rendered by the Professional in this case are: 1. Review of Debtor’s prior year income tax returns, bankruptcy petition and schedules and documents related to the liquidation of the estate’s assets and the transactions attendant thereto. 2. Review and tax analysis of transactions, including capital gains calculations, consideration of tax attributes inherited from the Debtor and other considerations of the estate’s liquidated assets, to determine the appropriate (and most beneficial to the estate) tax treatment. 3. Preparation of federal and state income tax returns to reflect the transactions of the estate. 4. Communication with taxing authorities on behalf of the estate. 5. Obtain the required tax clearance from the Internal Revenue Service for the estate’s income tax returns; and 6. Perform any other financial analysis, investigation, general accounting services and address any other tax matters which may be required by the Trustee to properly administer the estate and maintain tax compliance.

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EXHIBIT “A”

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835 Wilshire Boulevard, Suite 300 2 Los Angeles, California 90017 Telephone: (213) 683-3317 3 Facsimile: (213) 683-1883 jmenchaca@menchacacpa.com 4 Proposed Accountant for the Bankruptcy Estate of Girardi Keese 5 6 UNITED STATES BANKRUPTCY COURT 7 CENTRAL DISTRICT OF CALIFORNIA, LOS ANGELES DIVISION 8 9 In re: ) ) 10 ) Case No. 2:20-bk-21022 BR ) 11 GIRARDI KEESE, ) Chapter 7 ) 12 ) NOTICE OF APPLICATION BY ) CHAPTER 7 TRUSTEE TO EMPLO 13 ) ACCOUNTANT [11 U.S.C § 327(a), F ) R. Bank. P. 2014 and Loc. Bankr. R. 14 Debtor. ) 2014-1(b)(2)] ) 15 ) ) 16 ) ) DATE: None Required 17 ) TIME: None Required ) PLACE: Courtroom “1668” 18 ) 255 E. Temple St. ) Los Angeles, CA 90012 19 ) 20 TO THE HONORABLE BARRY RUSSELL, UNITED STATES BANKRUPTC 21 JUDGE, AND OTHER INTERESTED PARTIES: 22 PLEASE TAKE NOTICE that Elissa D. Miller the duly appointed Chapter 7 Trustee (th23 “Trustee” or “Applicant”), will file an application to employ accountants (the “Application”24 with the United States Bankruptcy Court. 25 The applicant requests the employment of MENCHACA & COMPANY LLP, Certifie26 Public Accountants & Business Consultants (the "Company" or “MCO”), effective as of Marc27 2, 2021 to render accounting services to the estate, in particular, to perform a tax analysis 28 proceeds received by the Trustee, to prepare necessary federal and state income tax returns, tHACA & COMPANY LLP

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Exhibit 1

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SUMMARY OF STAFF AND BILLING RATES FROM JUNE 1, 2017 THROUGH CURRENT TYPICAL ITEMS OF EXPENSE Travel costs, including local parking and mileage – as incurred Copy costs - .20 cents each – as incurred Extraordinary mailing costs (over $1.00 per item) – as incurred Overnight courier service fees – as incurred Direct telephone charges – as incurred Direct telex, telefax and similar charges, .10 cents a page plus telephone charges – as incurred Printing – as incurred Filing fees – as incurred PERSONNEL RATES Staff R eference Position Rate John J. Menchaca JJM Managing Partner 480 Edward A. Alvarado EAE Value & Litigation 375 Consultant Toshihiro A. Okubo TAO Manager 325 Robert P. Coats RPC Senior 295 Scott M. McLean SMM Senior 295 Natalie F. Beltran NFB Senior 240 Imelda Gaeta IG Paraprofessional 200 Note: Staff time may be billed at less than standard rates depending upon the nature of the work being performed.

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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 businesddress is 333 South Grand Avenue, Suite 3400, Los Angeles, CA 90071-1406. true and correct copy of the foregoing document entitled (specify): NOTICE OF TRUSTEE'S PPLICATION TO EMPLOY ACCOUNTANT will be served or was served (a) on the judge in hambers 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 ontrolling General Orders and LBR, the foregoing document will be served by the court via NEF andyperlink to the document. On (date) March 4, 2021, I checked the CM/ECF docket for this ankruptcy case or adversary proceeding and determined that the following persons are on the lectronic Mail Notice List to receive NEF transmission at the email addresses stated below: yra E Andrassy kandrassy@swelawfirm.com, arrett@swelawfirm.com;gcruz@swelawfirm.com;jchung@swelawfirm.com afey Balabanian , docket@edelson.com ichelle Balady mb@bedfordlg.com, leo@bedfordlg.com ri S Blumenfeld Ori@MarguliesFaithLaw.com, elen@MarguliesFaithLaw.com;Angela@MarguliesFaithLaw.com;Vicky@MarguliesFaithLaw.com andor Theodore Boxer tedb@tedboxer.com ichard D Buckley richard.buckley@arentfox.com arie E Christiansen mchristiansen@vedderprice.com, ecfladocket@vedderprice.com,marie-hristiansen-4166@ecf.pacerpro.com ennifer Witherell Crastz jcrastz@hrhlaw.com shleigh A Danker Ashleigh.danker@dinsmore.com, DCMLFiles@DINSMORE.COM;Katrice.ortiz@dinsmore.com lifford S Davidson csdavidson@swlaw.com, jlanglois@swlaw.com;cliff-davidson-586@ecf.pacerpro.com ei Lei Wang Ekvall lekvall@swelawfirm.com, arrett@swelawfirm.com;gcruz@swelawfirm.com;jchung@swelawfirm.com ichard W Esterkin richard.esterkin@morganlewis.com imothy W Evanston tevanston@swelawfirm.com, cruz@swelawfirm.com;lgarrett@swelawfirm.com;jchung@swelawfirm.com eremy Faith Jeremy@MarguliesFaithlaw.com, elen@MarguliesFaithlaw.com;Angela@MarguliesFaithlaw.com;Vicky@MarguliesFaithlaw.com ames J Finsten , jimfinsten@hotmail.com lan W Forsley alan.forsley@flpllp.com, awf@fkllawfirm.com,awf@fl-wyers.net,addy.flores@flpllp.com,laura.rucker@flpllp.com ric D Goldberg eric.goldberg@dlapiper.com, eric-goldberg-1103@ecf.pacerpro.com ndrew Goodman agoodman@andyglaw.com, Goodman.AndrewR102467@notify.bestcase.com uzanne C Grandt suzanne.grandt@calbar.ca.gov, joan.randolph@calbar.ca.gov teven T Gubner sgubner@bg.law, ecf@bg.law arshall J Hogan mhogan@swlaw.com, knestuk@swlaw.com azmig Izakelian razmigizakelian@quinnemanuel.com ewis R Landau Lew@Landaunet.com

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aniel A Lev dlev@sulmeyerlaw.com, ccaldwell@sulmeyerlaw.com;dlev@ecf.inforuptcy.com raig G Margulies Craig@MarguliesFaithlaw.com, icky@MarguliesFaithlaw.com;Helen@MarguliesFaithlaw.com;Angela@MarguliesFaithlaw.com eter J Mastan peter.mastan@dinsmore.com, DCMLFiles@dinsmore.com;Katrice.ortiz@dinsmore.com dith R Matthai ematthai@romalaw.com enneth Miller kmiller@pmcos.com, efilings@pmcos.com lissa Miller (TR) CA71@ecfcbis.com, illerTrustee@Sulmeyerlaw.com;C124@ecfcbis.com;ccaldwell@sulmeyerlaw.com ric A Mitnick MitnickLaw@aol.com, mitnicklaw@gmail.com cott H Olson solson@vedderprice.com, scott-olson- 161@ecf.pacerpro.com,ecfsfdocket@vedderprice.com,nortega@vedderprice.com eonard Pena lpena@penalaw.com, penasomaecf@gmail.com;penalr72746@notify.bestcase.coichael J Quinn mquinn@vedderprice.com, ecfladocket@vedderprice.com,michael-quinn-870@ecf.pacerpro.com onald N Richards ron@ronaldrichards.com, orani@ronaldrichards.com,justin@ronaldrichards.com evin C Ronk Kevin@portilloronk.com, Attorneys@portilloronk.com illiam F Saavino wsavino@woodsoviatt.com, lherald@woodsoviatt.com hilip E Strok pstrok@swelawfirm.com, cruz@swelawfirm.com;1garrett@swelawfirm.com;jchung@swelawfirm.com oris Treyzon jfinnerty@actslaw.com, sgonzales@actslaw.com nited States Trustee (LA) ustpregion16.la.ecf@usdoj.gov ric D Winston ericwinston@quinnemanuel.com hristopher K.S. Wong christopher.wong@arentfox.com, yvonne.li@arentfox.com imothy J Yoo tjy@lnbyb.com  Service information continued on attached pag . SERVED BY UNITED STATES MAIL: n (date) March 4, 2021, I served the following persons and/or entities at the last known addresses iis bankruptcy case or adversary proceeding by placing a true and correct copy thereof in a sealed nvelope in the United States mail, first class, postage prepaid, and addressed as follows. Listing thedge here constitutes a declaration that mailing to the judge will be completed no later than 24 hoursfter the document is filed.  Service information continued on attached pag . SERVED BY PERSONAL DELIVERY, OVERNIGHT MAIL, FACSIMILE TRANSMISSION OR MAIL (state method for each person or entity served): Pursuant to F.R.Civ.P. 5 and/or controlling BR, on (date) , I served the following persons and/or entities by personal elivery, overnight mail service, or (for those who consented in writing to such service method), by csimile transmission and/or email as follows. Listing the judge here constitutes a declaration that ersonal delivery on, or overnight mail to, the judge will be completed no later than 24 hours after theocument is filed. Service information continued on attached page.

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declare under penalty of perjury under the laws of the United States that the foregoing is true and orrect. March 4, 2021 Lupe V. Cortez /s/ Lupe Cortez Date Printed Name Signature

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S c/o BK Servicing, LLC 1 Ventura Boulevard, Suite 200 PO Box 131265 no, CA 91436-4482 Roseville, MN 55113-0011 tz Law Group, APLC Southern California Gas Company Century Park East 555 West 5th Street Los Angeles, CA 90013-1011 Angeles, CA 90067-2905 s Fargo Vendor Financial Services, Inc. Erika Saldana emar, Rousso & Heald, LLP 1757 Riverside Drive 0 Ventura Blvd., 12th Floor Glendale, CA 91201-2856 no, CA 91436-2802 'Callahan John Abassian Club View Drive 6403 Van Nuys Boulevard Angeles, CA 90024-5305 Van Nuys, CA 91401-1437 berly Archie Robert M. Keese 0 Ventura Boulevard 22982 Rosemont Court 307 Murrieta, CA 92562-3075 man Oaks, CA 91403-3841 inia Antonio Boris Treyzon Esq 3 Via Navarra 16001 Ventura Blvd., Suite 200 a Linda, CA 92886-3065 Encino, CA 91436-4482 Robert Girardi rdi Keese 402 South Marengo Ave. Wilshire Blvd Suite B Angeles, CA 90017-1904 Pasadena, CA 91101-3113 Legal Support, Inc. ortillo Ronk Legal Team Fay Pugh Corsa Avenue 1163 Daniels Drive 207 Los Angeles, CA 90035-1101 tlake Village, CA 91362-4059 inic Lombardo Andrew Goodman E. Pomona Boulevard 30700 Russell Ranch Road A Suite 250 terey Park, CA 91755-7210 Westlake Village, CA 91362-9507 ord Law Group, APC DK Global, Inc. Century Park East 420 Missouri Ct

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West 187th Street 3700 State Street, Suite 350 ena, CA 90248-4123 Santa Barbara, CA 93105-3100 att Consulting US Legal Support resta Verde Dr 16825 Northchase Dr Suite 900 ing Hills Estates, CA 90274-5455 Houston, TX 77060-6004 my Y. Hsu Express Network LLC 4 Pacific Promenade 1605 W Olympic Blvd #800 423 Los Angeles CA 90015-4685 a Vista, CA 90094-4006 Media, Inc. Chet Thompson 0 Shadow Rock Ln 26080 Shadow Rock L ncia, CA 91381-0630

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EXHIBIT “B”

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MENCHACA & COMPANY LLP FIRM PROFILE Menchaca & Company LLP is a firm of certified public accountants servicing clients throughout the Los Angeles metropolitan areas as well as other locations within California and the United States. Commercial experience includes primarily mid-sized companies with sales volume in the $5 million to $100 million range as well as partnerships, joint ventures and other business oriented operations. In addition to accounting and tax preparation services, the firm provides services in all areas of business and financial consulting and tax planning. Menchaca & Company LLP has a large segment of its practice concentrated in specialized areas of receiverships, investigative accounting, bankruptcy and litigation support. Menchaca & Company LLP has been appointed as professional accountants for Trustees and receivers and to assist in reorganizations, liquidations, tax research, planning, consultation and preparation, investigation accounting and other bankruptcy matters for numerous cases. John J. Menchaca, Managing Partner of the firm, serves as a Panel Trustee on the Central District of California Interim Panel of U.S. Bankruptcy Trustees.

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MENCHACA & COMPANY LLP PERSONNEL JOHN J. MENCHACA-CPA, MS TAXATION, CIRA (MANAGING PARTNER / CHAPTER 7 TRUSTEE / CHAPTER 11 TRUSTEE) Mr. Menchaca has over 25 years of experience in public accounting. He has significant tax consulting and tax compliance experience in corporate, partnership, Limited Liability Company, Limited Liability Partnership and individual taxation, at both the federal and state levels. Mr. Menchaca’s corporate tax experience includes closely held corporations, publicly traded multi-state corporate consolidations and S corporations. His experience also includes tax structuring of complex business transactions, form of ownership determinations, corporate and partnership reorganizations and restructurings, dischargeability of taxes in bankruptcy and dealing with tax issues related to Chapter 7 and Chapter 11 bankruptcy filings. He has also been successfully involved with Internal Revenue and Franchise Tax Board protest and audit defense. Mr. Menchaca is also a Chapter 7 Panel Trustee for the Central District of California. Prior to forming his own firm, Mr. Menchaca was a Principal with Vasquez & Company LLP for six years. Mr. Menchaca was also with the international accounting firm of Ernst & Young LLP for 14 years. While with Ernst & Young LLP, Mr. Menchaca provided financial, accounting and tax services to middle market privately held and publicly traded companies with revenues of up to $250 million. Mr. Menchaca serves on the USC / Kenneth Leventhal School of Accounting Board of Advisors. He is a member of the National Association of Bankruptcy Trustees, American Bankruptcy Institute, Los Angeles Bankruptcy Forum, Association of Insolvency and Restructuring Advisors, American Institute of Certified Public Accountants and the California Society of Certified Public Accountants.

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Mr. Menchaca graduated with a Bachelors of Science in Business Administration with an emphasis in Accounting from the University of Southern California and received a Masters of Science in Taxation from Golden Gate University. EDWARD A. ALVARADO – AVA, CFE – (VALUATION & LITIGATION CONSULTANT) Edward A. Alvarado is the owner of the Valuation and Litigation Support Services firm of Alvarado Consulting, Inc. Mr. Alvarado has over fifteen years of litigation and consulting experience providing damage analysis involving economic, accounting and financial issues in a variety of cases including fraud, unfair business competition, patent, copyright and trademark infringement, breach of contract, accounting and attorney malpractice, antitrust and construction. TOSHIHIRO A. OKUBO – CPA – (MANAGER) Mr. Okubo graduated from California State University, Los Angeles with a Bachelor of Science in Business Administration in September, 1992 and graduated from University of Southern California with a Master of Business Taxation in May, 1998. Mr. Okubo has financial and tax consulting experience with both local and big four accounting firms. ROBERT P. COATS – (SENIOR ACCOUNTANT) Mr. Coats hold a Bachelor of Science Degree in Accounting from California State University, Los Angeles. Mr. Coats has 20 years of tax preparation experience for individuals and corporations and 14 years of experience preparing Chapter 7 and Chapter 11 bankruptcy estate tax returns. He is familiar with all areas of bankruptcy tax and accounting issues. Mr. Coats has tax experience with both local and big four accounting firms. SCOTT M. MCLEAN – (SENIOR ACCOUNTANT) Mr. McLean graduated from California State Polytechnic University, Pomona with a Bachelor of Science in Accounting/Business Administration with an emphasis in Taxation. Mr. Mc Lean is familiar with all areas of bankruptcy tax and has experience in providing a full range of accounting services, including all aspects of Taxation.

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NATALIE F. BELTRAN - CPA - (SENIOR ACCOUNTANT) Ms. Beltran graduated with a Bachelor of Science Degree in Commerce, Major in Accounting from University of Santo Tomas, Manila, Philippines. Ms. Beltran is a licensed Certified Public Accountant in the State of California and the Philippines. Ms. Beltran has experience in providing a full range of accounting services, including all aspects of Taxation. IMELDA GAETA – (PARAPROFESSIONAL) Ms. Gaeta has worked as a Bankruptcy Trustee Administrator since 1997. Ms Gaeta has completed course work at Pasadena Community College and is the Secretary of the Trustee Administrators' Group (TAG).

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SUMMARY OF STAFF AND BILLING RATES FROM JUNE 1, 2017 THROUGH CURRENT TYPICAL ITEMS OF EXPENSE Travel costs, including local parking and mileage – as incurred Copy costs - .20 cents each – as incurred Extraordinary mailing costs (over $1.00 per item) – as incurred Overnight courier service fees – as incurred Direct telephone charges – as incurred Direct telex, telefax and similar charges, .10 cents a page plus telephone charges – as incurred Printing – as incurred Filing fees – as incurred PERSONNEL RATES Staff R eference Position Rate John J. Menchaca JJM Managing Partner 480 Edward A. Alvarado EAE Value & Litigation 375 Consultant Toshihiro A. Okubo TAO Manager 325 Robert P. Coats RPC Senior 295 Scott M. McLean SMM Senior 295 Natalie F. Beltran NFB Senior 240 Imelda Gaeta IG Paraprofessional 200 Note: Staff time may be billed at less than standard rates depending upon the nature of the work being performed.

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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 333 outh Grand Avenue, Suite 3400, Los Angeles, CA 90071-1406. true and correct copy of the foregoing document entitled (specify): APPLICATION BY CHAPTER 7 TRUSTEE TO EMPLOY ENCHACA & COMPANY LLP AS ACCOUNTANT; AND STATEMENT OF DISINTERESTEDNESS will be served or was erved (a) on 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 General Orders nd LBR, the foregoing document will be served by the court via NEF and hyperlink to the document. n March 4, 2021, I checked the CM/ECF docket for this bankruptcy case or adversary proceeding and determined that the llowing persons are on the Electronic Mail Notice List to receive NEF transmission at the email addresses stated below: yra E Andrassy kandrassy@swelawfirm.com, lgarrett@swelawfirm.com;gcruz@swelawfirm.com;jchung@swelawfirm.com afey Balabanian , docket@edelson.com ichelle Balady mb@bedfordlg.com, leo@bedfordlg.com ri S Blumenfeld Ori@MarguliesFaithLaw.com, elen@MarguliesFaithLaw.com;Angela@MarguliesFaithLaw.com;Vicky@MarguliesFaithLaw.com andor Theodore Boxer tedb@tedboxer.com ichard D Buckley richard.buckley@arentfox.com arie E Christiansen mchristiansen@vedderprice.com, ecfladocket@vedderprice.com,marie-christiansen-166@ecf.pacerpro.com ennifer Witherell Crastz jcrastz@hrhlaw.com shleigh A Danker Ashleigh.danker@dinsmore.com, SDCMLFiles@DINSMORE.COM;Katrice.ortiz@dinsmore.com lifford S Davidson csdavidson@swlaw.com, jlanglois@swlaw.com;cliff-davidson-7586@ecf.pacerpro.com ei Lei Wang Ekvall lekvall@swelawfirm.com, lgarrett@swelawfirm.com;gcruz@swelawfirm.com;jchung@swelawfirm.com ichard W Esterkin richard.esterkin@morganlewis.com imothy W Evanston tevanston@swelawfirm.com, cruz@swelawfirm.com;lgarrett@swelawfirm.com;jchung@swelawfirm.com eremy Faith Jeremy@MarguliesFaithlaw.com, elen@MarguliesFaithlaw.com;Angela@MarguliesFaithlaw.com;Vicky@MarguliesFaithlaw.com ames J Finsten , jimfinsten@hotmail.com lan W Forsley alan.forsley@flpllp.com, awf@fkllawfirm.com,awf@fl-wyers.net,addy.flores@flpllp.com,laura.rucker@flpllp.com ric D Goldberg eric.goldberg@dlapiper.com, eric-goldberg-1103@ecf.pacerpro.com ndrew Goodman agoodman@andyglaw.com, Goodman.AndrewR102467@notify.bestcase.com uzanne C Grandt suzanne.grandt@calbar.ca.gov, joan.randolph@calbar.ca.gov teven T Gubner sgubner@bg.law, ecf@bg.law arshall J Hogan mhogan@swlaw.com, knestuk@swlaw.com azmig Izakelian razmigizakelian@quinnemanuel.com ewis R Landau Lew@Landaunet.com aniel A Lev dlev@sulmeyerlaw.com, ccaldwell@sulmeyerlaw.com;dlev@ecf.inforuptcy.com raig G Margulies Craig@MarguliesFaithlaw.com, icky@MarguliesFaithlaw.com;Helen@MarguliesFaithlaw.com;Angela@MarguliesFaithlaw.com eter J Mastan peter.mastan@dinsmore.com, SDCMLFiles@dinsmore.com;Katrice.ortiz@dinsmore.com dith R Matthai ematthai@romalaw.com enneth Miller kmiller@pmcos.com, efilings@pmcos.com lissa Miller (TR) CA71@ecfcbis.com, MillerTrustee@Sulmeyerlaw.com;C124@ecfcbis.com;ccaldwell@sulmeyerlaw.com ric A Mitnick MitnickLaw@aol.com, mitnicklaw@gmail.com cott H Olson solson@vedderprice.com, scott-olson- 161@ecf.pacerpro.com,ecfsfdocket@vedderprice.com,nortega@vedderprice.com eonard Pena lpena@penalaw.com, penasomaecf@gmail.com;penalr72746@notify.bestcase.com ichael J Quinn mquinn@vedderprice.com, ecfladocket@vedderprice.com,michael-quinn-2870@ecf.pacerpro.com onald N Richards ron@ronaldrichards.com, morani@ronaldrichards.com,justin@ronaldrichards.com evin C Ronk Kevin@portilloronk.com, Attorneys@portilloronk.com illiam F Saavino wsavino@woodsoviatt.com, lherald@woodsoviatt.com hilip E Strok pstrok@swelawfirm.com, gcruz@swelawfirm.com;1garrett@swelawfirm.com;jchung@swelawfirm.com

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oris Treyzon jfinnerty@actslaw.com, sgonzales@actslaw.com nited States Trustee (LA) ustpregion16.la.ecf@usdoj.gov ric D Winston ericwinston@quinnemanuel.com hristopher K.S. Wong christopher.wong@arentfox.com, yvonne.li@arentfox.com imothy J Yoo tjy@lnbyb.com  Service information continued on attached pag . SERVED BY UNITED STATES MAIL: n (date) , I served the following persons and/or entities at the last known addresses in this bankruptcy ase or adversary proceeding by placing a true and correct copy thereof in a sealed envelope in the United States mail, rst class, postage prepaid, and addressed as follows. Listing the judge here constitutes a declaration that mailing to the dge will be completed no later than 24 hours after the document is filed.  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. March 4, 2021 Lupe V. Cortez /s/ Lupe Cortez Date Printed Name Signature

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