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Full title: Declaration re: of Philip E. Strok in Support of Stipulation for Rejection of Contingent Fee Agreement with Proof of Service Filed by Trustee Elissa Miller (TR) (RE: related document(s)271 Stipulation By Elissa Miller (TR) and Mullen & Henzell L.L.P. and Shane Horton, by and through his mother Yvonne Horton, by and through their attorneys for Rejection of Contingent Fee Agreement with Proof of Service). (Strok, Philip) (Entered: 03/18/2021)

Document posted on Mar 17, 2021 in the bankruptcy, 5 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

On March 2, 2021, my office, on behalf of the Trustee, filed a Motion for 20 Order Authorizing and Approving the Transition, Assignment, and Lien Agreement and 21 the Assignment of the Estate's Interests in Certain of the Debtor's Cases to Aitken Aitken22 Cohn Free and Clear of Liens, Claims and Interests Pursuant to 11 U.S.C. § 363In the 24 Motion, the Trustee proposes to assign and transfer a number of the Debtor's pending 25 cases to Aitken Aitken Cohn ("AAC"), subject to certain conditions. Given that Horton is 4 unwilling to provide consent, the Trustee has agreed to exclude M&H and Horton from 5 the Motion, the AAC agreement and their provisions subject to a reservation of rights, 6 claims and interests. SERVED BY UNITED STATES MAIL: n (date) March 18, 2021 , I served the following persons and/or entities at the last known addresses in this bankruptcase 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.P. 5 and/or controlling LBR, on (date) ________ , I served the llowing persons and/or entities by personal delivery, overnight mail service, or (for those who consented in writing to uch 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 I GnI RreA RDI KEESE, CChaasep tNero 7. 2:20-bk-21022-BR ornia ax 71 a, Calif00 • F 14 DSUECPPLAORRAT TOIOF NS TOIPF UPLHAILTIIPO NE. FSOTRR OK INs0 15 REJECTION OF CONTINGENT FEE e1 M5- AGREEMENT a 4 ost4 4 16 C71 el 17 [No Hearing Required] T 18 Debtor. 19 20 21 22 I, Philip E. Strok, declare: 23 1. I am a partner with Smiley Wang-Ekvall, LLP, attorneys for Elissa D. Miller,24 Chapter 7 Trustee of the bankruptcy estate of Girardi Keese (the "Trustee"). I am 25 licensed to practice before this Court and the courts of the State of California. I know 26 each of the following facts to be true of my own personal knowledge, except as otherwis27 stated and, if called as a witness, I could and would competently testify with respect

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1 Fee Agreement (the "Stipulation"). Unless otherwise defined in this declaration, all term2 defined in the Stipulation are incorporated herein by this reference. 3 2. According to the Court's docket, on December 18, 2020 (the "Petition 4 Date"), an involuntary chapter 7 bankruptcy petition ("Petition") was filed against Girardi 5 Keese ("Debtor"). As of the filing of the Petition, the Debtor was counsel of record in a 6 significant number of 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 of the bankruptcy estate of Girardi Keese (the 10 "Estate") on January 6, 2021. The order for relief was entered January 13, 2021 and, th11 same date, the Trustee was reappointed and has been serving in that capacity since. 2 0 0 92626 4 445-1 1123 Mullen 4&. HortIo anm L .aLd.Pv.i s(e"Md &thHa"t) p, raionrd tYo vthoen npee tHitoiornto dna (t"eH, oinrt oJnu"n)e e oxfe 2c0u1te5d, tah eC oDnetbintgoer,n t ornia ax 71 a, Calif00 • F 14 Fee Agreement (the "Agreement") which described the legal services to be provided to s0 15 Horton and the terms of the retention. Pursuant to the Agreement, the Debtor was to e1 M5- a 4 ost4 4 16 serve as lead trial counsel. A claim for damages was filed in the United States District C1 7 el 17 Court for the Central District of California on behalf of Horton (the "Litigation"). The T 18 Litigation is currently pending. 19 5. On March 2, 2021, my office, on behalf of the Trustee, filed a Motion for 20 Order Authorizing and Approving the Transition, Assignment, and Lien Agreement and 21 the Assignment of the Estate's Interests in Certain of the Debtor's Cases to Aitken Aitken22 Cohn Free and Clear of Liens, Claims and Interests Pursuant to 11 U.S.C. § 363 [Docket23 No. 229] (the "Motion"). The Motion is scheduled for hearing on March 23, 2021. In the 24 Motion, the Trustee proposes to assign and transfer a number of the Debtor's pending 25 cases to Aitken Aitken Cohn ("AAC"), subject to certain conditions. Each proposed 26 assignment is subject to the client's consent. 27 6. On March 9, 2021, counsel for Horton and M&H filed a Limited Opposition

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1 Assignment of the Estate's Interests in Certain of the Debtor's Cases, etc. [Docket 2 No. 251]. M&H and Horton object to the Motion to the extent the Trustee intends for the 3 Agreement to be included in the proposed assignment to AAC. Given that Horton is 4 unwilling to provide consent, the Trustee has agreed to exclude M&H and Horton from 5 the Motion, the AAC agreement and their provisions subject to a reservation of rights, 6 claims and interests. 7 7. By order of the Court entered March 10, 2021, the deadline to assume or8 reject executory contracts or unexpired leases of residential real property or of personal 9 property of the Debtor was extended to and including September 9, 2021. 10 I declare under penalty of perjury under the laws of the United States of America 11 that the foregoing is true and correct to the best of my knowledge. 2 0 0 92626 4 445-1 1123 Executed on this 18th day of March, 2021, at Costa Mesa, California. ornia ax 71 a, Calif00 • F 14 PHILIP E. STROK 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 PHILIP E. STROK IN SUPPORT OF TIPULATION FOR REJECTION OF CONTINGENT FEE AGREEMENT will be served or was served (a) on the judge in chamber 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 rders and LBR, the foregoing document will be served by the court via NEF and hyperlink to the document. On (date) arch 18, 2021 I checked the CM/ECF docket for this bankruptcy case or adversary proceeding and determined that thllowing persons are on the Electronic Mail Notice List to receive NEF transmission at the email addresses stated below:  Service information continued on attached pag . SERVED BY UNITED STATES MAIL: n (date) March 18, 2021 , I served the following persons and/or entities at the last known addresses in this bankruptcase 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. he Honorable Barry Russell William C. Beall .S. Bankruptcy Court Beall & Burkhardt APC oybal Federal Building 1114 State Street 55 E. Temple Street, Suite 1660 La Arcada Building, Suite 200 os Angeles, CA 90012 Santa Barbara, CA 93101  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 served the llowing persons and/or entities by personal delivery, overnight mail service, or (for those who consented in writing to uch 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 18, 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  Michelle Balady mb@bedfordlg.com, leo@bedfordlg.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  James J Finsten , jimfinsten@hotmail.com  Alan W Forsley alan.forsley@flpllp.com, awf@fkllawfirm.com,awf@fl-lawyers.net,addy.flores@flpllp.com,laura.rucker@flpllp.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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