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Full title: Motion to Use Cash Collateral - Chapter 7 Trustee's Second Motion for Order Approving Stipulations for Use of Cash Collateral and Authorizing Use of Cash Collateral Pursuant To 11 U.S.C. § 363 and Federal Rule Of Bankruptcy Procedure 4001(b) AND (d); Memorandum of Points and Authorities, Declarations of Elissa D. Miller and Philip E. Strok in Support with Proof of Service Filed by Trustee Elissa Miller (TR) (Strok, Philip) (Entered: 03/30/2021)

Document posted on Mar 29, 2021 in the bankruptcy, 75 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

If the Trustee has 6 no authority to use cash collateral, the Trustee will be unable to preserve the Estate's 7 most critical assets, the Debtor's interests in its attorneys' fees and costs.Without continuing access to funds, the Trustee is unable to fund a 25 2 On February 10, 2021, the Trustee filed a second Motion for Order Authorizing Chapter 7 Trustee 26 to Operate the Business of the Debtor on a Limited Basis Pursuant to 11 U.S.C. § 721 Pursuant to Cash Collateral Stipulation and Budget and to Retain and Pay Debtor's Former Employees as Independent 27 Contractors in Accordance Therewith [Docket No. 180].However, in no M 5‐ osta  4 44 16 event will the Trustee exceed the authorization as set forth in the Stipulations; C 1 7 el   T 17 (2) As adequate protection for use of its cash collateral, the alleged secured18 creditor will receive a postpetition replacement lien for its asserted secured claim against19 the Debtor's assets with the same validity, priority, scope and extent as any lien(s) held 20 by the alleged secured creditor as of the involuntary petition date solely to the extent that21 the use of cash collateral results in the diminution of the alleged secured creditor's 22 prepetition lien; 23 (3)The replacement lien shall not encumber or otherwise attach to any causes2 of action under chapter 5 of the Bankruptcy Code or any proceeds of such causes of 3 action; 4 (5) All rights and arguments of the Trustee, on behalf of the Estate, to5 challenge or dispute the validity, priority, scope or extent of the security interests asserte6 by the alleged secured creditor, including without limitation, in the Debtor's postpetition 7 receipts and cash, or that the use of cash collateral has resulted in the diminution of the 8 value of the alleged secured creditor's prepetition liens, are preserved.All rights and arguments of the Trustee, on behalf of the Estate, to 24 challenge or dispute (a) the validity, priority, scope or extent of the security interests 25 asserted by any alleged secured creditor including, without limitation, in the Debtor's 26 post-petition receipts and cash, or (b) that the use of cash collateral has resulted in the 27 diminution of the value of the alleged secured creditor's prepetition lien(s), are preserved, 28 1 and any alleged secured creditor's right to oppose any such request by the Trustee is 2 preserved; 3 14.

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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 UNITED STATES BANKRUPTCY COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 LOS ANGELES DIVISION 11 In re Case No. 2:20-bk-21022-BR 2 0 12 0 92626  4 445‐1 13 GIRARDI KEESE, Chapter 7 alifornia  •  Fax 71 14 Debtor. CMHOATPIOTNE RF O7 RT ROURSDTEERE A'SP SPERCOOVNINDG a, C 00   STIPULATIONS FOR USE OF CASH es 10 15 COLLATERAL AND AUTHORIZING USE osta M 4 445‐ 16 OTOF 1C1A USH.S .CCO. L§ L3A6T3 EARNADL F PEUDRESRUAALN T C 1 7 el   RULE OF BANKRUPTCY PROCEDURE T 17 4001(b) AND (d); MEMORANDUM OF POINTS AND AUTHORITIES, 18 DECLARATIONS OF ELISSA D. MILLER AND PHILIP E. STROK IN SUPPORT 19 [Application for Order Setting Hearing 20 on Shortened Notice Concurrently Filed] 21 Date: To be set 22 Time: To be set Ctrm.: 1668 via ZoomGov 23 255 E. Temple Street Los Angeles, CA 90012 24 Web Address: https://cacb.zoomgov.com 25 Meeting ID: To be set Password: To be set 26 Telephone: To be set 27

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1 TABLE OF CONTENTS Pag 2 3 I.  INTRODUCTION .................................................................................................... 4 II.  FACTUAL BACKGROUND ..................................................................................... 5 A.  The Debtor's Involuntary Bankruptcy Case .................................................. 6 B.  The Debtor's Primary Assets ........................................................................ 7 C.  State of the Debtor's Office .......................................................................... 8 D.  The Trustee's Prior Motion for Order Approving Stipulations for Use of Cash Collateral and Authorizing Use of Cash Collateral .......................... 9 E.  The Estate's Current Cash Position ............................................................. 10 F.  The Cash Collateral Stipulations .................................................................. 11 G.  Federal Rule of Bankruptcy Procedure 4001(b) Disclosures ........................ 2  0 12 0 92626  4 445‐1 13 H.  Alleged Secured Creditors ......................................................................... 1alifornia  •  Fax 71 14 III.  MEMORANDUM OF POINTS AND AUTHORITIES ............................................. 1a, C 00   A.  The Court Should Approve the Stipulations with CAL II, Stillwell, es 10 15 Virage, and Nano ....................................................................................... 1M 5‐ osta  4 44 16 B.  The Court Should Authorize the Use of Cash Collateral Because the C 1 7 el   Alleged Secured Creditors are Adequately Protected ................................ 1T 17 C.  Cause Exists to Grant the Motion on an Interim Basis ............................... 118 IV.  CONCLUSION ...................................................................................................... 119 20 21 22 23 24 25 26 27

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1 TABLE OF AUTHORITIES 2 Pag 3 CASES  4 Fed. Nat'l Mortg. Ass'n v. Dacon Bolingbrook Assoc. L.P., 5 153 B.R. 204, 214 (N.D. Ill. 1993) ......................................................................... 1 6 In re Constable Plaza Assoc., 125 B.R. 98, 105 (Bankr. S.D.N.Y. 1991) ............................................................. 1 7 Leasing Partners, LP v. ProAlert, LLC (In re ProAlert, LLC), 8 314 B.R. 436, 441 (B.A.P. 9th Cir. 2004) .............................................................. 1 9 Stein v. U.S. Farmers Home Admin. (In re Stein), 19 B.R. 458 (Bankr. E.D. Pa. 1982) ...................................................................... 110 United Sav. Ass'n of Texas v. Timbers of Inwood Forest Assoc., Ltd., 11 484 U.S. 365, 370 (1988) ...................................................................................... 12  0 12 0 92626  4 445‐1 13 STATUTES  alifornia  •  Fax 71 14 11 U.S.C. § 303(g) ............................................................................................................. a, C 00   es 10 15 11 U.S.C. § 362(c)(2) ....................................................................................................... 1M 5‐ osta  4 44 16 11 U.S.C. § 363 ..................................................................................................... 2, 17, 2C 1 7 el   T 17 11 U.S.C. § 363(c) ........................................................................................................... 118 11 U.S.C. § 363(c)(2)(A) .................................................................................................. 119 11 U.S.C. § 363(e) ........................................................................................................... 120 11 U.S.C. § 506(c) ........................................................................................................... 121 11 U.S.C. § 721 ................................................................................................................. 22 Federal Rule of Bankruptcy Procedure 4001 ................................................................... 123 Federal Rule of Bankruptcy Procedure 4001(b) ...................................................... passi24 Federal Rule of Bankruptcy Procedure 4001(b)(2) .......................................................... 125 Federal Rule of Bankruptcy Procedure 4001(d) ...................................................... passi26 27 RULES 

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1 TO THE HONORABLE BARRY RUSSELL, UNITED STATES BANKRUPTCY JUDGE 2 Elissa D. Miller, the chapter 7 trustee for the bankruptcy estate of Girardi Keese 3 (the "Estate"), submits this Chapter 7 Trustee's Second Motion for Order Approving 4 Stipulations for Use of Cash Collateral and Authorizing Use of Cash Collateral Pursuant 5 to 11 U.S.C. § 363 and Federal Rule of Bankruptcy Procedure 4001(b) and (d) (the 6 "Motion"). In support of the Motion, the Trustee submits the following memorandum of 7 points and authorities and the attached declarations of Elissa D. Miller and Philip E. 8 Strok. 9 10 I. INTRODUCTION 11 When the Trustee was first appointed, operations at Girardi Keese (the "Debtor") 2  0 12 had essentially stopped. The Debtor's primary assets continue to be its interests in its 0 92626  4 445‐1 13 attorneys' fees and costs in its contingency cases. However, because the Debtor's alifornia  •  Fax 71 14 existing cash was minimal and because its attorneys and employees either resigned or a, C 00   es 10 15 left the firm, the Debtor was not in a position as of the petition date to realize the value ofM 5‐ osta  4 44 16 its interests in its fees and costs. Since her appointment, the Trustee has been working C 1 7 el   T 17 to protect the interests of the Debtor's clients and preserve and maximize the value of th18 Estate's interests by transitioning the cases to other qualified counsel or, where the 19 Debtor's involvement has been terminated by the client, taking all appropriate steps to 20 preserve, protect and collect on the Estate's entitlement to fees and costs. Transitioning 21 these cases and protecting the Estate's interests requires uninterrupted access to the 22 Debtor's case files, cost ledgers, and other crucial information. 23 On February 10, 2021, the Trustee filed her first Motion for Order Approving 24 Stipulations for Use of Cash Collateral and Authorizing Use of Cash Collateral Pursuant 25 to 11 U.S.C. § 363 and Federal Rule of Bankruptcy Procedure 4001(b) [Docket No. 179] 26 (the "First Cash Collateral Motion"). As noted in the First Cash Collateral Motion, the 27 Debtor's disorganization and byzantine storage platforms have made preservation of the

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1 Fortunately, the support of the Debtor's former employees has greatly assisted the 2 Trustee's efforts in locating files, cost ledgers, and other critical information necessary to3 protect the clients and preserve the value of the Estate. 4 Since the First Cash Collateral Motion was filed, the Estate's cash position has 5 improved dramatically. Use of cash collateral under the First Cash Collateral Motion wa6 imperative to achieve this result. Importantly, the Trustee is expected to come in under 7 budget for the period covered by the First Cash Collateral Motion. 8 By the Motion, the Trustee again seeks authorization to use cash collateral on a 9 pared-down subsistence basis to preserve and enhance the value of the Estate in 10 accordance with the updated 90-Day Budget (the "Budget") attached hereto as Exhibit 11 "1" which covers the period from April 1, 2021 through June 30, 2021 (the "Cash 2 0 12 Collateral Period"). Under the Budget, expenditures will not exceed 115% of the 0 92626  4 445‐1 13 aggregate "High" expenditures set forth in the Budget, i.e., a 15% variance. Since the alifornia  •  Fax 71 14 First Cash Collateral Motion, the Trustee has continued discussions with the consensual a, C 00   es 10 15 lenders alleging to hold secured claims. Recently, the Trustee has entered into cash M 5‐ osta  4 44 16 collateral stipulations with California Attorney Lending II ("CAL II"), Stillwell Madison, LLC 1 7 el   T 17 ("Stillwell"), Virage SPV 1, LLC ("Virage"), and Nano Banc ("Nano"). As set forth in the 18 respective stipulations attached hereto as Exhibits "2," "3," "4," and "5," these parties will19 receive replacement liens in the cash collateral with the same validity, priority, scope or 20 extent against the Debtor's assets as of the petition date, and solely to the extent that th21 use of cash collateral results in diminution of value. Thus, because these parties have 22 consented, the Trustee is authorized to cash collateral. As to the other alleged 23 lienholders that have not expressly consented, the use of cash collateral should be 24 authorized because their interests will be adequately protected. 25 The use of cash collateral is crucial for the Estate. If the Trustee lacks access to 26 cash collateral, she will be unable to transition the Debtor's cases to other law firms to 27 maximize the Estate's value while protecting the clients. Further, if the Trustee's access

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1 Trustee will be highly burdened in recovering fees and costs. The Trustee may even be 2 unable to establish quantum meruit claims in its cases where the Debtor was terminated 3 and/or replaced. Thus, the Trustee's use of cash collateral will protect the interests of 4 secured creditors because the collateral (the attorneys' fees and costs) will be preserved5 and likely enhanced if the Trustee successfully transitions the cases. If the Trustee has 6 no authority to use cash collateral, the Trustee will be unable to preserve the Estate's 7 most critical assets, the Debtor's interests in its attorneys' fees and costs. In short, the 8 secured creditors will be adequately protected because use of cash collateral will 9 preserve and likely enhance the Estate. 10 For these reasons, the Court should approve the cash collateral stipulations and 11 enter an interim order authorizing the Trustee to use cash collateral in accordance with 2 0 12 the Budget through the final hearing on the Motion, and then with a final order until June 0 92626  4 445‐1 13 30, 2021. alifornia  •  Fax 71 14 a, C 00   es 10 15 II. FACTUAL BACKGROUND M 5‐ osta  4 44 16 A. The Debtor's Involuntary Bankruptcy Case C 1 7 el   T 17 The Debtor is a plaintiff's law firm based in Los Angeles, California. On Decembe18 18, 2020, petitioning creditors Jill O'Callahan, as successor in interest to James 19 O'Callahan, Robert M. Keese, John Abassian, Erika Saldana, Virginia Antonio, and 20 Kimberly Archie (collectively, the "Petitioning Creditors") filed an involuntary chapter 7 21 bankruptcy petition against the Debtor.1 Prior to the involuntary petition, the Debtor 22 practiced in the areas of personal injury, defective products, sexual abuse, toxic torts, 23 business law, employment law, and aviation law. 24 On December 24, 2020, the Petitioning Creditors filed a Motion for Appointment o25 Interim Trustee Pursuant to 11 U.S.C. § 303(g) [Docket No. 12]. The Court entered an 26 27 1 The Petitioning Creditors also filed an involuntary chapter 7 bankruptcy petition against Thomas V. Girardi, which is currently pending as Bankruptcy Case No. 2:20-bk-21020-BR.

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1 order granting the motion on January 5, 2021 [Docket No. 45]. On January 6, 2021, the 2 Trustee was appointed as the interim trustee [Docket No. 50]. 3 On January 13, 2021, the Court entered an Order Directing: (1) The Clerk of Cour4 to Immediately Enter an Order for Relief under Chapter 7; (2) The United States Trustee 5 to Immediately Appoint a Chapter 7 Trustee; (3) The Debtor to File All Schedules and 6 Related Documentation for Chapter 7 Case within Fourteen Days of the Entry of this 7 Order; and (4) Vacating February 16, 2021 Status Conference [Docket No. 68]. On 8 January 13, 2021, the Clerk of Court entered an order for relief against the Debtor 9 [Docket No. 69], and the Trustee was appointed and accepted her appointment in the 10 Debtor's case [Docket No. 71]. 11 B. The Debtor's Primary Assets 2 0 12 At the time the involuntary petition was filed against the Debtor, the Debtor's affair0 92626  4 445‐1 13 were in dire straits. Pre-petition, the Debtor was counsel of record in a significant numbealifornia  •  Fax 71 14 of cases which were undertaken on a contingency basis. Unfortunately, prior to the a, C 00   es 10 15 involuntary petition date, nearly all of the Debtor's employees and attorneys had resigneM 5‐ osta  4 44 16 and moved on. These cases are at varying litigation stages, with some cases currently C 1 7 el   T 17 pending and other cases where the client has terminated its relationship with the Debtor. 18 Without staff and attorneys, the Trustee is left with the challenge of establishing the 19 Estate's rights to fees and costs and collecting on such fees and costs from the Debtor's 20 contingency cases. The Debtor's fees and costs in its plethora of cases likely constitute 21 the most significant assets in the Estate. However, protecting and preserving the 22 Debtor's and clients' interests in these cases requires a support team that needs to be 23 paid and the payment of other necessary expenses. 24 C. State of the Debtor's Office 25 The Trustee continues to regularly visit the Debtor's offices. As stated in the First26 Cash Collateral Motion, the Debtor's offices are difficult to navigate, disorganized, and 27 hold a large volume of documents. The Debtor's case files and data are generally store

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1 paper files, (2) some files are stored a proprietary electronic system of the Debtor, and 2 (3) other files are stored electronically in a program called iManage. This is in addition to3 client cost information located on the Debtor's Sage Accounting System. In order to4 access this information, the Debtor must continue to pay for internet services for the 5 Debtor, as well as pay for the maintenance of the virtual "cloud" server. Preservation of6 this electronic information also requires the services of a specialized computer7 consultant. See Declaration of Elissa D. Miller. 8 The Trustee's attempts to navigate the Debtor's internal systems have been 9 supported by certain of the Debtor's former employees.2 Because the Debtor's 10 bankruptcy case is in its early stages, the Debtor's former employees have significantly 11 more organizational and operational knowledge of the Debtor than the Trustee. For 2 0 12 instance, some of the employees working with the Trustee know where to find certain 0 92626  4 445‐1 13 physical files or know where the information is stored electronically. These employees alifornia  •  Fax 71 14 are also generally familiar with the Debtor's electronic databases. As such, the Trustee a, C 00   es 10 15 requires the assistance of former employees of the Debtor to help navigate the Debtor's M 5‐ osta  4 44 16 electronic and physical storage systems, keep track of the Debtor's pending cases to C 1 7 el   T 17 protect the Estate and clients, and locate additional assets. Physical files as well as 18 electronic information are still located at the Debtor's office and the Trustee requires 19 uninterrupted utilities to access such information. In addition, to protect the Estate from 20 liability while the Debtor's office is being accessed, the Trustee requires insurance. 21 Accordingly, the Trustee has included the estimated costs of utilities and insurance in th22 Budget. See Declaration of Elissa D. Miller. 23 The Trustee continues to diligently work to identify assets of the Debtor and this 24 process is ongoing. Without continuing access to funds, the Trustee is unable to fund a 25 2 On February 10, 2021, the Trustee filed a second Motion for Order Authorizing Chapter 7 Trustee 26 to Operate the Business of the Debtor on a Limited Basis Pursuant to 11 U.S.C. § 721 Pursuant to Cash Collateral Stipulation and Budget and to Retain and Pay Debtor's Former Employees as Independent 27 Contractors in Accordance Therewith [Docket No. 180]. On February 16, 2021, the Court entered an ordegranting the motion and authorizing the Trustee to retain and pay certain of the Debtor's employees through July 13, 2021. See Docket No. 194.

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1 proper investigation of the Debtor's affairs to preserve and maximize the value of the 2 Estate. Accordingly, immediate use of cash collateral is critical to both preservation and 3 enhancement of the Estate, as well as protection of the Debtor's clients. 4 D. The Trustee's Prior Motion for Order Approving Stipulations for Use o 5 Cash Collateral and Authorizing Use of Cash Collateral 6 On February 10, 2021 the Trustee filed her First Cash Collateral Motion. The 7 Court held a hearing on the First Cash Collateral Motion on February 16, 2021. On 8 February 16, 2021, the Court entered an order granting the motion on an interim basis. 9 See Docket No. 193. On March 2, 2021, the Court held a final hearing on the First Cash10 Collateral Motion. On March 11, 2021, the Court entered an order granting the motion o11 a final basis. See Docket No. 257. Currently, the Trustee's authority to use cash 2 0 12 collateral expires on March 31, 2021. 0 92626  4 445‐1 13 In connection with the First Cash Collateral Motion, the Trustee previously alifornia  •  Fax 71 14 submitted a 90-day budget to use cash collateral. To date, the Trustee is in full a, C 00   es 10 15 compliance with the previous 90-day budget and she believes she will come in under M 5‐ osta  4 44 16 budget for the period covered. See Declaration of Elissa D. Miller. C 1 7 el   T 17 E. The Estate's Current Cash Position 18 Since the filing of the First Cash Collateral Motion, the Trustee has been able to19 successfully recover assets for the benefit of the Estate. Excluding funds held by the 20 Trustee in her Client Trust Account (a portion of which belong to the Estate) and blocked21 funds in a IOLTA Account located at East West Bank, the Trustee is currently holding 22 non-client funds of approximately $3.8 million. However, because these funds are 23 encumbered, the Trustee is unable to use this sum to fund her Court-approved limited 24 operations and expenditures. Accordingly, continued authority to use cash collateral is 25 necessary to preserve and maximize the value of the assets of the Estate. See 26 Declaration of Elissa D. Miller. 27

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1 F. The Cash Collateral Stipulations 2 The Trustee's need for use of cash collateral is critical and ongoing. Since the 3 Court granted the First Cash Collateral Motion, the Trustee and her counsel have 4 continued to engage in discussions with certain consensual lenders alleging to hold 5 secured claims against the Estate and have obtained their consent to use cash collateral 6 On March 29, 2021, the Trustee and CAL II entered into a Second Stipulation for 7 Use of Cash Collateral and Adequate Protection (the "Second CAL II Stipulation"). See 8 the Second CAL II Stipulation, Exhibit "2." 9 On March 26, 2021, the Trustee and Stillwell entered into a Stipulation between 10 the Trustee and Stillwell Madison, LLC For Use of Cash Collateral and Adequate 11 Protection (the "Stillwell Stipulation"). See the Stillwell Stipulation, Exhibit "3." 2 0 12 On March 26, 2021, the Trustee and Virage entered into a Second Stipulation for 0 92626  4 445‐1 13 Use of Cash Collateral and Adequate Protection (the "Second Virage Stipulation"). See alifornia  •  Fax 71 14 the Second Virage Stipulation, Exhibit "4." a, C 00   es 10 15 On March 26, 2021, the Trustee and Nano entered into a Stipulation Between the M 5‐ osta  4 44 16 Trustee and Nano Banc for Use of Cash Collateral and Adequate Protection (the "Nano C 1 7 el   T 17 Stipulation") (the Second CAL II Stipulation, the Stillwell Stipulation, the Virage 18 Stipulation, and the Nano Stipulation are collectively referred to as the "Stipulations"). 19 See the Nano Stipulation, Exhibit "5." 20 In accordance with the proposed Budget, the Trustee will use the cash collateral t21 pay the fees for a computer consultant, the Trustee's field agent, a former attorney of the22 Debtor, and other employees of the Debtor, including an accounts payable manager, IT 23 manager, mass torts data manager and file clerk. The Trustee will also use the cash 24 collateral to pay the insurance premiums3, internet service for the office, utilities for the 25 office (power, water, and gas), as well as for "cloud" services for the Debtor's electronic 26 27 3 In the First Cash Collateral Motion, the Trustee included a line item for the bond premium in the budget. As reflected in the current Budget, the bond premium has been paid and no further funds to pay abond premium are required at this time. See Budget, Ex. "1."

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1 files. The Trustee's Budget allows for total expenditures ranging from $141,100 to 2 $226,650 for the Cash Collateral Period, with an allowed 15% variance from the "High" 3 end of the budget as provided in the Stipulations. See Budget, Ex. "1." In sum, the 4 Budget provides the Trustee with the resources she needs to transition the Debtor's 5 cases, protect and preserve the Estate's interests in the Debtor's existing and terminated6 cases, and protect the Debtor's clients. 7 G. Federal Rule of Bankruptcy Procedure 4001(b) Disclosures 8 As required by Federal Rule of Bankruptcy Procedure 4001(b), the following are9 the material provisions of the Stipulations: 10 (1) The Trustee is authorized to use cash collateral in accordance with the11 Budget for the Cash Collateral Period. The Trustee's expenditures will not exceed 115%2 0 12 of the aggregate "High" expenditures in the Budget (i.e. a 15% variance). The Trustee 0 92626  4 445‐1 13 has utilized names for positions in the Budget and may utilize different people other thanalifornia  •  Fax 71 14 the ones indicated. For economy, the Trustee may increase the hourly rate of one or a, C 00   es 10 15 more people included in the Budget and eliminate the use of others. However, in no M 5‐ osta  4 44 16 event will the Trustee exceed the authorization as set forth in the Stipulations; C 1 7 el   T 17 (2) As adequate protection for use of its cash collateral, the alleged secured18 creditor will receive a postpetition replacement lien for its asserted secured claim against19 the Debtor's assets with the same validity, priority, scope and extent as any lien(s) held 20 by the alleged secured creditor as of the involuntary petition date solely to the extent that21 the use of cash collateral results in the diminution of the alleged secured creditor's 22 prepetition lien; 23 (3) The alleged secured creditor is not required to file any financing statement,24 notice, lien or other similar instrument in any jurisdiction, or take any other action to 25 perfect its replacement lien, and the replacement lien is automatically perfected upon 26 approval of the Stipulations; 27

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1 (4) The replacement lien shall not encumber or otherwise attach to any causes2 of action under chapter 5 of the Bankruptcy Code or any proceeds of such causes of 3 action; 4 (5) All rights and arguments of the Trustee, on behalf of the Estate, to5 challenge or dispute the validity, priority, scope or extent of the security interests asserte6 by the alleged secured creditor, including without limitation, in the Debtor's postpetition 7 receipts and cash, or that the use of cash collateral has resulted in the diminution of the 8 value of the alleged secured creditor's prepetition liens, are preserved. 9 (6) Neither the Trustee nor the Estate are waiving any rights under 11 U.S.C. 10 § 506(c); 11 (7) Upon reasonable request and subject to appropriate confidentiality2 0 12 provisions, the Trustee will provide her Form 2 Cash Receipts and Disbursements 0 92626  4 445‐1 13 Record; and alifornia  •  Fax 71 14 (8) The Trustee is authorized to use cash collateral until June 30, 2021 unlessa, C 00   es 10 15 extended with the alleged secured creditor's consent or Bankruptcy Court order; M 5‐ osta  4 44 16 (9) The Trustee's authorization to use cash collateral of the alleged securedC 1 7 el   T 17 creditor automatically expires if the Trustee files any document or pleading challenging 18 the validity, priority, scope or extent of the alleged secured creditor's prepetition liens; 19 and 20 (10) The Trustee reserves the right to seek an order from the Bankruptcy Court21 extending the Stipulations and/or authorizing the Trustee's further use of cash collateral. 22 Attached hereto as Exhibit "6" is the Trustee's Statement Regarding Cash 23 Collateral or Debtor in Possession Financing [FRBP 4001; LBR 4001-2]. Attached heret24 as Exhibit "7" is the Trustee's proposed interim order granting this Motion. 25 H. Alleged Secured Creditors 26 Upon her appointment, the Trustee ran a UCC search with the California Secretar27 of State. While the Trustee is not waiving any arguments to contest the validity, priority,

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1 a security interest in the cash collateral or are a secured creditor. A summary of these 2 parties is listed below, with a more complete disclosure attached hereto as Exhibit "8." 3 Because the Debtor's case is in its early stages, this information represents the Trustee'4 best knowledge at this time. 5 File Number File Date Alleged Lienholder Filing Claim 6 California Attorney 117275806299 07/06/2011 -- 7 Lending II 8 167506300179 01/26/2016 Ikon Financial Services4 -- 9 167506300290 01/26/2016 Ikon Financial Services -- 10 167519369916 04/11/2016 Stillwell Madison, LLC -- 11 177587629032 05/30/2017 Ikon Financial Services -- 2 00 12 177601785042 08/18/2017 Virage SPV 1, LLC5 -- 92626  4 445‐1 13 177614819640 11/06/2017 Virage SPV 1, LLC -- alifornia  •  Fax 71 14 187635620856 03/01/2018 Virage SPV 1, LLC -- a, C 00   Mes 5‐10 15 187666662169 08/31/2018 Nano Banc -- osta  4 44 16 C 1 California Attorney 7 el   197746713843 11/14/2019 -- T 17 Lending II 18 Jamie, Joseph, & U200027063225 10/6/2020 $11,491,232.876 19 Kathleen Ruigomez 20 California Attorney U200033578428 11/2/2020 $6,254,014.57 21 Lending II 22 23 4 Ikon Financial Services only purports to hold a security interest in certain equipment of the Debtor. 24 5 The Trustee believes but has not yet confirmed that this UCC Financing Statement was filed on 25 behalf of Virage SPV 1, LLC. 26 6 The Trustee reserves all rights to contest or seek to avoid any judgment lien filed during the preference period. On March 26, 2021, Jamie, Joseph & Kathleen Ruigomez each filed proofs of claim in 27 the amount of $11,747,245.95 and asserting an ORAP lien on all of the Debtor's personal property assets. The Trustee is currently in the process of reviewing their proofs of claim. See Proofs of Claim 23-1, 24-1, and 25-1.

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1 KCC Class Action U200037891132 12/17/2020 $7,504,109.59 2 Services, LLC 3 4 III. MEMORANDUM OF POINTS AND AUTHORITIES 5 A. The Court Should Approve the Stipulations with CAL II, Stillwell, 6 Virage, and Nano 7 Section 363(c)(2) of the Bankruptcy Code provides that "[t]he trustee may not use8 sell, or lease cash collateral under paragraph (1) of this subsection unless – (A) each 9 entity that has an interest in such cash collateral consents." See 11 U.S.C. § 10 363(c)(2)(A). 11 Here, CAL II, Stillwell, Virage and Nano have all consented to the use of cash 2 0 12 0 92626  4 445‐1 13 collateral on an interim basis from April 1, 2021 through and including June 30, 2021. alifornia  •  Fax 71 14 Scoenes Eenxt. f"r2o,m" E Cx.A "L3 ,I"I, ESxt.il l"w4e,"l la, nVdir aEgxe. ," 5a.n"d TNhaunso, ,b tehcea Tursues ttehee iTsr uasutteheo rhizaesd o tbot auisnee dc ash a, C 00   es 10 15 M 5‐ collateral under 11 U.S.C. § 362(c)(2). Moreover, as discussed below, the Trustee is osta  4 44 16 C 71 further authorized to use cash collateral because any other alleged secured creditors of el   T 17 the Debtor will be adequately protected. 18 B. The Court Should Authorize the Use of Cash Collateral Because the19 Alleged Secured Creditors are Adequately Protected 20 A bankruptcy court may authorize a trustee's use of cash collateral without the 21 consent of a secured creditor provided the secured creditor's interest in such cash 22 collateral is adequately protected. See 11 U.S.C. §§ 363(c), (e). "However, the 23 protection afforded to secured creditors is not absolute." Sec. Leasing Partners, LP v. 24 ProAlert, LLC (In re ProAlert, LLC), 314 B.R. 436, 441 (B.A.P. 9th Cir. 2004). Rather, as25 articulated by the United States Supreme Court, a secured creditor is entitled to adequat26 protection only from the decline in value of its collateral package post-petition. See 27 United Sav. Ass'n of Texas v. Timbers of Inwood Forest Assoc., Ltd., 484 U.S. 365, 370

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1 Multiple courts have authorized the use of cash collateral to either enhance or 2 preserve the value of a debtor's estate. See Stein v. U.S. Farmers Home Admin. (In re 3 Stein), 19 B.R. 458, 460 (Bankr. E.D. Pa. 1982) (finding that the use of cash collateral 4 was necessary to operate the debtor's business in turn enhancing the debtor's estate); 5 Fed. Nat'l Mortg. Ass'n v. Dacon Bolingbrook Assoc. L.P., 153 B.R. 204, 214 (N.D. Ill. 6 1993) (finding that "the required adequate protection of Rents is satisfied to the extent th 7 Debtor reinvests the Rents in the operation and maintenance of the property because th8 value of the secured creditor's interest in its collateral will thereby be increased."); In re 9 Constable Plaza Assoc., 125 B.R. 98, 105 (Bankr. S.D.N.Y. 1991) (finding adequate 10 protection is present in part because rent would be used for maintaining office building, 11 which would "preserve or enhance the value of the building" and "protect the 2 0 12 collateral…"). 0 92626  4 445‐1 13 The Trustee's use of cash collateral will preserve and enhance the value of the alifornia  •  Fax 71 14 Estate, providing the secured creditors with adequate protection. In fact, since the filing a, C 00   es 10 15 of the First Cash Collateral Motion, the Trustee has used the cash collateral to preserve M 5‐ osta  4 44 16 and enhance the Estate's value. Consequently, the Estate now has funds totaling C 1 7 el   T 17 approximately $3.8 million. Continued use of cash collateral may further enhance this 18 value. As noted earlier, the Estate's primary assets are the Debtor's interests in its 19 attorneys' fees and costs from its contingency cases. In order to preserve the value of 20 these assets, the Trustee has been negotiating with different law firms to represent the 21 Debtor's clients, with the goal of transferring these cases so that the clients have 22 representation and so that the Estate can receive the Debtor's attorneys' fees and costs 23 in an amount that is fixed and certain, which would be a vast improvement from what 24 would otherwise be undefined quantum meruit claims, if any. The proper transitioning of25 these cases requires the use of cash collateral. 26 To realize the value of the Debtor's interests in its attorneys' fees and costs, the 27 Trustee needs cash to fund the transition of the Debtor's cases. Specifically, the Trustee

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1 house the Debtor's case files and needs uninterrupted utilities at the Debtor's offices. 2 The Trustee also needs the assistance of professionals, para-professionals and former 3 employees to preserve these case files by helping locate case lists, files and cost ledger4 (or help find the documents necessary to prepare the cost ledgers). Without these basic5 and necessary expenditures, the Trustee will not have access to the Debtor's case files 6 and may not be able to effectively transition the Debtor's cases or ascertain the Debtor's 7 fees and costs. If transitions fail to occur, the Trustee may not be able to collect any fee8 and costs for the Estate. As noted earlier, the Trustee's goal is to obtain a recovery for 9 the Estate that exceeds the quantum meruit value of the Debtor's interest in its fees. At 10 minimum, access to cash collateral will preserve the Estate's value by preserving the 11 Debtor's records that support its quantum meruit and cost claims. This preservation of 2 0 12 value of the Debtor's quantum meruit and cost claims adequately protects the secured 0 92626  4 445‐1 13 creditors. alifornia  •  Fax 71 14 The use of cash collateral will likely enhance the secured creditors' collateral. Tha, C 00   es 10 15 Court recently approved a compromise between the Trustee with Frantz Law Group, M 5‐ osta  4 44 16 APLC with respect to the "Southern California Gas Leak Litigation." Through this C 1 7 el   T 17 compromise, the Trustee was able to obtain a recovery for the Estate significantly higher18 than any quantum meruit claim. Since the First Cash Collateral Motion, the Court has 19 also approved the Transition, Assignment and Lien Agreement and the assignment of th20 Estate's interests in certain of the Debtor's cases to Aitken Aitken Cohn ("Aitken"). Agai21 through the agreement with Aitken, the Trustee will obtain a recovery substantially highe22 than any quantum meruit claim. With access to cash collateral, the Trustee will have the23 ability to enter into similar compromises and agreements that may again enhance the 24 value of the Estate. As made clear in the Budget, the Trustee is seeking funding only for25 what is absolutely necessary and is not requesting any funds for her professionals' fees 26 at this time. The budget is simple and is designed to allow the Trustee to both preserve 27 and enhance the value of the alleged secured creditors' collateral. Because the use of

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1 collateral, the secured creditors are adequately protected. Thus, the Court should 2 authorize the Trustee to use cash collateral. 3 C. Cause Exists to Grant the Motion on an Interim Basis 4 A court may not approve the use of cash collateral, on a final basis, on less than5 14 days after service of the motion. See FRBP 4001(b)(2). Nonetheless, the court may 6 approve the interim use of cash collateral to the extent necessary "to avoid immediate 7 and irreparable harm to the estate pending a final hearing." Id. 8 Ample cause exists to grant the Motion on an interim basis. The Trustee seeks 9 authorization to use cash collateral from April 1, 2021 through and including June 30, 10 2021. The cash collateral will be used to pay essential costs necessary to preserving th11 Estate and will very likely lead to enhancement of the Estate's value. Indeed, the Truste2 0 12 is currently holding approximately $3.8 million on behalf of the Estate for the benefit of 0 92626  4 445‐1 13 creditors, made possible in part by the Trustee's prior authorization to use cash collateralalifornia  •  Fax 71 14 This figure will rise as the Trustee continues to work to enhance the property of the a, C 00   es 10 15 Estate, efforts that are funded by the cash collateral. M 5‐ osta  4 44 16 C 1 7 el   T 17 IV. CONCLUSION 18 For the foregoing reasons, the Trustee requests that the Court enter an order: 19 1. Granting the Motion; 20 2. Authorizing the Trustee's interim use of cash collateral pursuant to FRBP21 4001(b) and (d) in accordance with the Budget attached hereto as Exhibit "1" plus a 15%22 variance; 23 3. Approving the Second CAL II Stipulation attached hereto as Exhibit "2";24 4. Approving the Stillwell Stipulation attached hereto as Exhibit "3";25 5. Approving the Second Virage Stipulation attached hereto as Exhibit "4";26 6. Approving the Nano Stipulation attached hereto as Exhibit "5";27 7. Providing all alleged secured creditors with the adequate protection and

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1 8. Granting such other and further relief as the Court deems just and proper. 2 3 DATED: March 30, 2021 Respectfully submitted, 4 SMILEY WANG-EKVALL, LLP 5 6 By: 7 PHILIP E. STROK Attorneys for Elissa D. Miller, Chapter 7 8 Trustee 9 10 11 2 0 12 0 92626  4 445‐1 13 alifornia  •  Fax 71 14 a, C 00   es 10 15 M 5‐ osta  4 44 16 C 1 7 el   T 17 18 19 20 21 22 23 24 25 26 27

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1 DECLARATION OF ELISSA D. MILLER 2 I, Elissa D. Miller, declare as follows: 3 1. I am the duly appointed Chapter 7 Trustee for the bankruptcy estate of 4 Girardi Keese. I am also a partner at SulmeyerKupetz, a professional corporation. I 5 know each of the following facts to be true of my own personal knowledge, except as 6 otherwise stated and, if called as a witness, I could and would competently testify with 7 respect thereto. I make this declaration in support of the Chapter 7 Trustee's Second 8 Motion for Order Approving Stipulations for Use of Cash Collateral and Authorizing Use 9 of Cash Collateral Pursuant to 11 U.S.C. § 363 and Federal Rule of Bankruptcy 10 Procedure 4001(b) and (d) (the "Motion"). Unless otherwise defined in this declaration, 11 all terms defined in the Motion are incorporated herein by this reference. 2 0 12 2. On January 13, 2021, I accepted by appointment as the Chapter 7 Trustee0 92626  4 445‐1 13 for the bankruptcy estate of Girardi Keese. alifornia  •  Fax 71 14 3. Since my appointment and the filing of the First Cash Collateral Motion, Ia, C 00   es 10 15 have continued to regularly visit the Debtor's offices. Unfortunately, the Debtor's offices M 5‐ osta  4 44 16 are not intuitively set up, are difficult to navigate and are disorganized. In addition, C 1 7 el   T 17 because the Debtor used its offices as storage, the offices house a large number of 18 documents that are haphazardly stored. 19 4. The Debtor stored its case files and data in different ways. The Debtor20 stores some of its case files in physical paper files, and other files related to the mass tor21 cases are stored in a proprietary electronic system of the Debtor. The Debtor also stores22 certain files in an electronic system called iManage©, which is separate from the Debtor'23 proprietary electronic system. Some files are maintained on paper and also stored 24 electronically on one or the other of the databases. Financial information related to the 25 cases (e.g., cost ledgers) is located on the Sage Accounting System. 26 5. In order to have continued access to the Debtor's electronic information, th27 Debtor needs to have internet access, as the access points to this electronic information

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1 are located at the Debtor's offices. In addition, I must pay for the maintenance of the 2 virtual "cloud" server to preserve the Debtor's files and information. 3 6. As the Debtor is without insurance, I also have had to obtain liability and4 contents insurance for the Debtor's case. 5 7. The Debtor's former employees have extensive knowledge about the 6 Debtor's operations and have been instrumental in helping me learn about how the 7 Debtor conducted its business prepetition. I continue to rely on the Debtor's former 8 employees when operational and organization issues arise, so that any issues can be 9 resolved more expeditiously. 10 8. Specifically, some of the Debtor's former employees know where to locate11 certain physical files or know where the file is saved electronically and in which database2 0 12 These employees have continued to help me find certain files, cost ledgers, and other 0 92626  4 445‐1 13 records more efficiently. In addition, these employees have also helped me keep track oalifornia  •  Fax 71 14 the Debtor's pending cases to protect the Estate and the Debtor's clients, as well as a, C 00   es 10 15 locate additional assets of the Debtor. M 5‐ osta  4 44 16 9. Currently, the Debtor's physical files remain at the Debtor's offices, alongC 1 7 el   T 17 with the Debtor's electronic information. While I need internet service to access some of18 the information, I also need uninterrupted access to utilities like power, water, and gas, 19 for continued access. Because the Debtor's office has to be accessed for this 20 information, insurance for the premises is also needed to protect the Estate from any 21 liability while the Debtor's offices are accessed. 22 10. I previously submitted a 90-day budget in connection with the First Cash23 Collateral Motion. I have fully complied with the previous budget and believe I will come 24 in under the budget for the period covered by the First Cash Collateral Motion. 25 11. I have, with the assistance of my professionals, developed the current26 Budget, which includes the costs detailed above, to pay for the resources I need to 27 maximize and preserve value for the Estate, as well as protect the Debtor's clients. A

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1 work on the case, I learn more about the capabilities of the Debtor's former employees 2 who are assisting me. When I prepared the Budget, I utilized names and/or titles for 3 certain line items in the Budget. Ultimately, I may utilize persons other than the ones 4 indicated in the Budget. For economy, I may use one person for more than one function 5 and increase the hourly rate accordingly. I also may eliminate the use of others. 6 However, in no event will I exceed the total amount as set forth in the Budget plus the 7 15% variance. 8 12. I am continuing to work to identify assets of the Debtor, and this process is9 ongoing. Since the filing of the First Cash Collateral Motion, I have successfully 10 recovered assets for the benefit of the Estate. I am currently holding non-client funds of 11 approximately $3.8 million. This figure does not include the funds I hold in the Client 2 00 12 Trust Account (a portion of which belong to the Estate) and blocked funds in a State Bar 92626 4 445-1 13 IOLTA Account located at East West Bank. Nonetheless, because the non-client funds alifornia • Fax 71 14 are encumbered, I cannot use this sum to fund the Court-approved limited operations ana, C00 es10 15 expenditures. M5- osta 4 44 16 I declare under penalty of perjury under the laws of the United States of America C71 el T 17 that the foregoing is true and correct. 18 Executed on this ____ day of March, 2021, at ___________________, California. 19 20 Elissa D. Miller 21 22 23 24 25 26 27

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1 DECLARATION OF PHILIP E. STROK 2 I, Philip E. Strok, declare as follows: 3 1. I am a partner with Smiley Wang-Ekvall, LLP, attorneys of record for Elissa 4 D. Miller, Chapter 7 Trustee. I am licensed to practice before this Court and the courts o5 the State of California. I know each of the following facts to be true of my own personal6 knowledge, except as otherwise stated and, if called as a witness, I could and would7 competently testify with respect thereto. I make this declaration in support of the Chapte8 7 Trustee's Second Motion for Order Approving Stipulations for Use of Cash Collateral9 and Authorizing Use of Cash Collateral Pursuant to 11 U.S.C. § 363 and Federal Rule of10 Bankruptcy Procedure 4001(b) and (d) (the "Motion"). Unless otherwise defined in this11 declaration, all terms defined in the Motion are incorporated herein by this reference. 2 0 12 2. Upon the Trustee's appointment, my office ran a UCC search with the0 92626  4 445‐1 13 California Secretary of State. After my office conducted the UCC search, I prepared a alifornia  •  Fax 71 14 summary of the search results. A true and correct copy of the chart I prepared, which a, C 00   es 10 15 accurately summarizes the results of the UCC search, is attached hereto as Exhibit "8." M 5‐ osta  4 44 16 3. Since the First Cash Collateral Motion, I have continued to engage inC 1 7 el   T 17 discussions with counsel for CAL II, Stillwell, Virage and Nano regarding their alleged 18 interests in cash collateral. 19 4. As of a result of these discussions, the Trustee has entered into stipulation20 to use cash collateral with CAL II, Stillwell, Virage and Nano. 21 5. On March 29, 2021, the Trustee and CAL II entered into the Second CAL II22 Stipulation. A true and correct copy of the CAL II Stipulation is attached hereto as Exhibi23 "2." 24 6. On March 26, 2021, the Trustee and Stillwell entered into the Stillwell25 Stipulation. A true and correct copy of the Stillwell Stipulation is attached hereto as 26 Exhibit "3." 27

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1 7. On March 26, 2021, the Trustee and Virage entered into the Second Virag 2 Stipulation. A true and correct copy of the Second Virage Stipulation is attached hereto 3 as Exhibit "4." 4 8. On March 26, 2021, the Trustee and Nano entered into the Nano 5 Stipulation. A true and correct copy of the Nano Stipulation is attached hereto as Exhibit6 "5." 7 9. FRBP 4001(d) and Local Bankruptcy Rule 4001-2 require that the Motion8 be accompanied with a Statement Regarding Cash Collateral or Debtor in Possession 9 Financing and a proposed form of order. A true and correct copy of the Statement 10 Regarding Cash Collateral or Debtor in Possession Financing is attached hereto as 11 Exhibit "6," and a true and copy of the proposed order is attached hereto as Exhibit "7." 2 0 12 I declare under penalty of perjury under the laws of the United States of America 0 92626  4 445‐1 13 that the foregoing is true and correct to the best of my knowledge. alifornia  •  Fax 71 14 Executed on this 30th day of March, 2021, at Costa Mesa, California. a, C 00   es 10 15 M 5‐ osta  4 44 16 C 1 7 el   Philip E. Strok T 17 18 19 20 21 22 23 24 25 26 27

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EXHIBIT "1"

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Chapter 7 Bankruptcy Estate of Girardi Keese 90‐Day Budget April 2021 through June 2021 Estimated Amounts Name Description Low High iDiscovery Solutions 1 Computer consultant for trustee $23,000 $33,000D Masin Consulting LLC Trustee's field agent 17,500 25,000 Kenny Rodriguez Former GK attorney 12,500 25,000 Norina Rouillard Former GK A/P manager 9,000 11,250 Sammy Suh Former GK IT manager 7,500 12,000 Arlan Solonga Former GK data clerk for proprietary system 12,500 17,500Josemaria Ibarra Former GK file clerk 10,000 13,000 Trustee Insurance Group General liability and car insurance 1,200 1,600Trustee Insurance Group Property insurance for building 0 17,500Inernational Sureties Bond premium 0 0 Crown Castle Internet service for office 10,000 15,000 Mimecast Cloud services 1,000 2,000 LADWP/So Cal Gas Power/water/gas for office 7,500 12,500 Insight Software license 800 1,200 Insight  Software (VM) license renewal 5,100 5,100 Microsoft Software license renewal 16,000 20,000 TBD Unknown/miscellaneous expenses 7,500 15,000      Totals $141,100 $226,650 1  Although iDiscovery Solutions was included in the previous budget with a low of $45,000 and a high of $60,000, no payments have been made to it.

25

EXHIBIT "2"

26

27

28

29

30

31

32

33

34

EXHIBIT "3"

35

36

37

38

39

40

41

42

43

EXHIBIT "4"

44

45

46

47

48

49

50

51

EXHIBIT "5"

52

53

54

55

56

57

58

59

EXHIBIT "6"

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MILEY WANG-EKVALL, LLP hilip E. Strok, State Bar No. 169296 strok@swelawfirm.com imothy W. Evanston, State Bar No. 319342 evanston@swelawfirm.com 200 Park Center Drive, Suite 250 osta Mesa, California 92626 elephone: 714 445-1000 acsimile: 714 445-1002 Individual appearing without attorney Attorney for: Elissa D. Miller, Chapter 7 Trustee UNITED STATES BANKRUPTCY COURT CENTRAL DISTRICT OF CALIFORNIA- L O S A N G E L E S D I V I SIONDIVISIONn re: CASE NO.: 2:20-bk-21022-BR IRARDI KEESE CHAPTER: 7 STATEMENT REGARDING CASH COLLATERAL OR DEBTOR IN POSSESSION FINANCING [FRBP 4001; LBR 4001-2] DATE: TIME: COURTROOM: 1668 ADDRESS: 255 E. Temple Street Debtor(s). Los Angeles, CA 90012 ecured party(ies):California Attorney Lending II; Stillwell Madison, LLC; Virage SPV 1, LLC; Nano Banc; Jaime, Joseph and Kathleen Ruigomez; KCC Class Action Services, LLChe Debtorhas requested the approval ofeither (1) a motion for use of cash collateral, or postpetition financing, or both, (2) through a separately-filed motion, a stipulation providing for the use of cash collateral, or postpetition financing, or th. The proposed form of order on the motion or the stipulation contains the following provisions or findings of fact: Page Line No. Disclosures Tracking FRBP 4001(c)(1)(B)(i)through (xi)and (d)(1)(B)No.: (if applicable) (i): “[A] grant of priority or a lien on property of the estate under § 364(c) or (d)”(ii): “[T]he providing of adequate protection or priority for a claim that arose before the commencement of the case, including the granting of a lien on property of the estate 3 11to secure the claim, or the use of property of the estate or credit obtained under § 364 to make cash payments on account of the claim” Cross-collateralization, i.e.,clauses that secure prepetition debt by postpetition assets in which thesecured party would not otherwise have a security interest by virtue of its prepetition security agreement or applicable lawRoll-up, i.e.,provisions deeming prepetition debt to be postpetition debt or usingpostpetition loans from a prepetition secured partyto pay part or all of that secured party’s prepetition debt, other than as provided in § 552(b)This form is mandatory. It has been approved for use bythe United States Bankruptcy Court for the Central District of California.

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on cash collateral as of the petition date (iii): “[A] determination of the validity, enforceability, priority, or amount of a claim that arose before the commencement of the case, or of any lien securing the claim”(iv): “[A]waiver or modification of Code provisions or applicable rules relating to the automatic stay” Automatic relief from the automatic stay upon occurrence of certain events. (v): “[A] waiver or modification of any entity’s authority or right to file a plan, seek an extension of time in which the debtor has the exclusive right to file a plan, request the use of cash collateral under § 363(c), or request authority to obtain credit under § 364”(vi): “[T]he establishment of deadlines for filing a plan of reorganization, for approval of a disclosure statement, for a hearing on confirmation, or for entry of a confirmation order” (vii): “[A] waiver or modification of the applicability ofnonbankruptcy law relating to the perfection of a lien on property of the estate, or on the foreclosure or other 3 17enforcement of the lien” (viii): “[A] release, waiver, or limitation on any claim or other cause of action belonging to the estate or the trustee, including any modification of the statute of limitations or other deadline to commence an action” (ix): “[T]he indemnification of any entity” (x): “[A] release, waiver, or limitation of any right under § 506(c)”The granting of any lien on any claim or cause of action arising under §506(c)(xi): “The granting of any lien on any claim or cause of action arising under §§ 544, 545, 547, 548,549, 553(b), 723(a), or 724(a)” Page Line No. Additional Disclosures Required by LBR 4001-2 No.: (if applicable) With respect to a professional fee carve out, disparate treatment for professionals retained by a creditors’ committee from thatprovided for the professionals retained by the debtor Pay downprepetition principal owed to a creditor Findings of fact on matters extraneous to the approval process/30/2021 Philip E . S t r o k /s/ Ph il i p E . S t r o k ate Printed Name Signature This form is mandatory. It has been approved for use bythe United States Bankruptcy Court for the Central District of California.

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am over the age of 18 and not a party to this bankruptcy case or adversary proceeding. My business address is: true and correct copy ofthe foregoing document entitled:STATEMENTREGARDING CASH COLLATERAL OR EBTOR IN POSSESSION FINANCING[FRBP 4001; LBR 4001-2]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 controlling General rders and LBR, the foregoing document will be served by the court via NEF and hyperlink to the document. On (date),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: Service information continued on attached page . 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 becompletedno later than 24 hours after the document is filed. Service information continued on attached page . 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 touch 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 completedno later than 24 hours after the document is led. Service information continued on attached page declare under penalty of perjury under the laws of the United States that the foregoing is true and correct. Date Printed Name Signature This form is mandatory. It has been approved for use bythe United States Bankruptcy Court for the Central District of California.

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EXHIBIT "7"

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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 UNITED STATES BANKRUPTCY COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 LOS ANGELES DIVISION 11 MILEY WANG‐EKVALL, LLP  3200 Park Center Drive, Suite 250 Costa Mesa, California 92626 el  714 445‐1000  •  Fax 714 445‐1002 1111123456 IGnI RreA RDI KEESE, Debtor. CC[GSAOACPEUPOhaFRRasC PTALCOepHORLN tAPNeAOONTSOroTRIDV HN7.SE II 2N GMZERC:IGD2 ONAOC0 ]TGLSLH -IbI LNT AOPUkAITUP-NPS2TETRU E1FERESL0 OROIR2AUMRAF2 TA7 - LOIOCB NO TRARARTRNDN SDUTSEDHEO SFR RT O1 E1RE U 'US.SS .EC . S T 17 § 363 AND FEDERAL RULE OF BANKRUPTCY PROCEDURE 4001(b) 18 AND (d) 19 Date: To be set Time: To be set 20 Ctrm.: 1668 via ZoomGov 255 E. Temple Street 21 Los Angeles, CA 90012 22 Web Address: https://cacb.zoomgov.com Meeting ID: To be set 23 Password: To be set Telephone: To be set 24 25 26 27 28

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1 On _____________, at __:__ a.m./p.m., the above-captioned Court held a hearing 2 on the Chapter 7 Trustee's Second Motion for Order Approving Stipulations for Use of 3 Cash Collateral and Authorizing Use of Cash Collateral Pursuant to 11 U.S.C. § 363 and 4 Federal Rule of Bankruptcy Procedure 4001(b) and (d) (the "Motion")1 filed by Elissa D. 5 Miller, in her capacity as Chapter 7 Trustee for the bankruptcy estate (the "Estate") of 6 Girardi Keese. Appearances were as noted on the Court's record. Having considered 7 the Motion and the pleadings, declarations, and exhibits filed in support thereof and 8 opposition thereto, and the statements and arguments of counsel on the record at the 9 hearing on the Motion, finding that notice and service of the Motion were proper and that 10 no further notice be given, and finding good cause for the relief requested in the Motion, 11 IT IS HEREBY ORDERED that: MILEY WANG‐EKVALL, LLP  3200 Park Center Drive, Suite 250 Costa Mesa, California 92626 el  714 445‐1000  •  Fax 714 445‐1002  1111123456 aopnp arno vi123ne...td e roimn aTTTbnhhha eeesini sSMSte;et orilictlmwioo nenbdl ali sSsC iGtsAip;LR u AIlaIN tSiTotinEp uDalt atoatnico hnae nad ti nttaotec thrhiemed M btoao sttiihsoe;n Maso tEioxnh iabsit E"_x_h"ib isit a"_p_p"r oisv ed S T 17 4. The Second Virage Stipulation attached to the Motion as Exhibit "__" is 18 approved on an interim basis; 19 5. The Nano Stipulation attached to the Motion as Exhibit "__" is approved on 20 an interim basis; 21 6. CAL II, Stillwell, Virage, Nano, and any other alleged secured creditor of the 22 Debtor and/or the Estate shall be considered a "secured creditor" as that term is used in 23 this Order and shall be entitled to the protections provided to such secured creditor; 24 7. The Trustee, on behalf of the Estate, is authorized to use cash collateral on 25 an interim basis from April 1, 2021 through and including June 30, 2021 (the "Cash 26 Collateral Period") in accordance with the Budget attached to the Motion as Exhibit "__," 27 28 1 Capitalized terms not defined herein shall have the meanings ascribed to them in the Motion.

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1 with expenditures during the Cash Collateral Period not to exceed 115% of the aggregate 2 "High" expenditures set forth in the Budget, i.e., a 15% variance; 3 8. The Trustee has utilized names for positions in the Budget and may utilize 4 different people other than the ones indicated, and may increase the hourly rate of one or 5 more people included in the Budget and eliminate the use of others, however, in no event 6 will the Trustee exceed the authorization as set forth in this Order. 7 9. The Trustee is authorized to pay the W-9 employees identified in the 8 Budget and such other W-9 employees as the Trustee requires to perform the services 9 contemplated in the Budget, so long as the total amount paid does not exceed the 10 authorization as set forth in this Order. 11 10. As adequate protection for the use of cash collateral in accordance with the MILEY WANG‐EKVALL, LLP  3200 Park Center Drive, Suite 250 Costa Mesa, California 92626 el  714 445‐1000  •  Fax 714 445‐1002  1111123456 Bas2dcis0umos2dpei0gner,eut etttah,ido nea nds np e oyeec fxta uitttlhreileoeendng tv eacdadlsala u tsiaeemen, c (oyssuf o) lrit leehaednegly ( acs atir)onle le hsdtgtehi tetleodhd r ee bss xyDhet eaecthnulblet rt ro eteahrdcl'als eect giartvehesedesd ia e tuso tpsser'e ocsw su opitrt-fehr pecd etpa htcesietrhtie iost dicnoaio tnmrolel arelpi et alevansrac( asloeild) fmr; i Detyese,nu cptl etrlsiimeo inrnbi t efyaor, r1 i8ts, S T 17 11. Any alleged secured creditor shall not be required to file any financing 18 statement, notice, lien, or other similar instrument in any jurisdiction, or take any other 19 action in order to perfect its replacement lien created hereunder because the 20 replacement lien is automatically perfected upon entry of this Order; 21 12. No replacement lien shall encumber or otherwise attach to any causes of 22 action under chapter 5 of the Bankruptcy Code or any proceeds of such causes of action; 23 13. All rights and arguments of the Trustee, on behalf of the Estate, to 24 challenge or dispute (a) the validity, priority, scope or extent of the security interests 25 asserted by any alleged secured creditor including, without limitation, in the Debtor's 26 post-petition receipts and cash, or (b) that the use of cash collateral has resulted in the 27 diminution of the value of the alleged secured creditor's prepetition lien(s), are preserved, 28

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1 and any alleged secured creditor's right to oppose any such request by the Trustee is 2 preserved; 3 14. Neither the Trustee nor the Estate are waiving any rights they may have4 under Bankruptcy Code Section 506(c) and any alleged secured creditor is not waiving 5 any of its rights or arguments to contest or dispute any such rights; 6 15. Upon reasonable request by any alleged secured creditor and subject to7 appropriate confidentiality provisions as determined by the Trustee, the Trustee will 8 provide her Form 2 Cash Receipts and Disbursements Record to the alleged secured 9 creditor; 10 16. The authorization to use cash collateral of any alleged secured creditor11 expires on June 30, 2021 unless extended with such alleged secured creditor's consent MILEY WANG‐EKVALL, LLP  3200 Park Center Drive, Suite 250 Costa Mesa, California 92626 el  714 445‐1000  •  Fax 714 445‐1002 1111123456 ocfSialrte islBslhw aa ecnnlok1ly,lr7 l uVad.ptoiertcacruagyTm le Chd eaeounn urctidrn oto gNnor sartphdenleeenoa rt'C; sd o aifan sCsghs A ceCLhrot aeIlIlldl,ae Stnleitegrilanilnwls gP;e letlh,r eiVo idvraa sglihdeai,t lyla ,an pudrt ioNomraitnayot,i c staocl oltyhp eee xToprri ureesx titefe etnh'ste o uTfs rCeu AsotLfe eII , S T 17 18. The Trustee reserves the right to seek an order from the Court authorizing18 the Trustee's further use of cash collateral upon notice of such request and any alleged 19 secured creditor reserves the right to oppose any such request; and 20 19. There shall be a final hearing on the Motion on ______, at __:__ a.m./p.m. 21 ### 22 23 24 25 26 27 28

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EXHIBIT " " 8

69

Listings: State Lien Search (Active
Table 1 on page 70. Back to List of Tables
File Type File Number File Date Expiration
Date
Debtor Secured Party Lien Summary and
Collateral
Claim Amount (from
filing)
Comments
Original 117275806299 07/06/2011 07/06/2021 GIRARDI KEESE
1126 WILSHIRE
BLVD.
LOS ANGELES CA
90017
CALIFORNIA
ATTORNEY
LENDING II, INC.
6400 MAIN STREET,
SUITE 120
WILLIAMSVILLE NY
14221
ACTIVE (All Assets and proceeds)
CAL Original filing which was limited
to interest in certain cases.
GIRARDI THOMAS
V.
100 LOS ALTOS
DRIVE
PASADENA CA
91105
AMENDMENT 1172814762 08/18/2011 Restated Collateral Description
AMENDMENT 1373755925 08/28/2013 GIRARDI KEESE Expanded Collateral Description to a
assets includingproceeds
ll
CONTINUATION 1675306737 06/10/2016 GIRARDI KEESE
AMENDMENT 1775969950 07/19/2017 CAL Amendment to Add Thomas V.
Girard
Original 167506300179 01/26/2016 01/26/2021 GIRARDI & KEESE IKON FINANCIAL ACTIVE (specified Equipment 1126 WILSHIRE SVCS only) BLVD 1738 BASS RD LOS ANGELES CA MACON GA 31210- 90017-1904 1043 Original 167506300290 01/26/2016 01/26/2021 GIRARDI & KEESE IKON FINANCIAL ACTIVE (specified Equipment 1126 WILSHIRE SVCS only) BLVD 1738 BASS RD LOS ANGELES CA MACON GA 31210- 90017-1904 1043 Original 167519369916 04/11/2016 04/11/2021 GIRARDI KEESE STILLWELL ACTIVE (Cases set forth in 1126 WILSHIRE MADISON, LLC Exhibit B-1 of Stillwell's BOULEVARD PO BOX 832 Agreement with Debtor) BEVERLY HILLS CA CAREFREE AZ 90017 85377 Original 177587629032 05/30/2017 05/30/2022 GIRARDI & KEESE IKON FINANCIAL ACTIVE (specified Equipment 1126 WILSHIRE SVCS only) BLVD 1738 BASS RD

70

Table 1 on page 71. Back to List of Tables
None None None None None None
Original 177601785042 08/18/2017 08/18/2022 GIRARDI & KEESE
1126 WILSHIRE
BLVD
LOS ANGELES CA
90017
CORPORATION
SERVICE
COMPANY, AS
REPRESENTATIVE
P.O. BOX 2576
UCCSPREP@CSCIN
FO.COM
SPRINGFIELD IL
62708
ACTIVE - Any Eligible Case (as
defined in the Loan Agreement)
The Trustee believes but has not yet
confirmed that this UCC Financing
Statement was filed on behalf of
Virage SPV 1, LLC.
None None None None None None
Original 177614819640 11/06/2017 11/06/2022 GIRARDI & KEESE
1126 WILSHIRE
BLVD
LOS ANGELES CA
90017
CORPORATION
SERVICE
COMPANY, AS
REPRESENTATIVE
P.O. BOX 2576
UCCSPREP@CSCIN
FO.COM
SPRINGFIELD IL
62708
ACTIVE - Any Eligible Case (as
defined in the Loan Agreement)
Counsel for Virage SPV 1, LLC has
confirmed that this UCC Financing
Statement was filed on behalf of
Virage SPV 1, LLC.
None None None None None None
Original 187635620856 03/01/2018 03/01/2023 GIRARDI & KEESE
1126 WILSHIRE
BLVD
LOS ANGELES CA
90017
CORPORATION
SERVICE
COMPANY, AS
REPRESENTATIVE
P.O. BOX 2576
UCCSPREP@CSCIN
FO.COM
SPRINGFIELD IL
ACTIVE - Any Eligible Case or
Eligible Collateral Case (as
defined in the Loan Agreement)
Counsel for Virage SPV 1, LLC has
confirmed that this UCC Financing
Statement was filed on behalf of
Virage SPV 1, LLC.
AMENDMENT 1977226167 07/10/2019 62708
AMENDMENT 1977234000 07/16/2019
None None None None None None
Original 187666662169 08/31/2018 08/31/2023 GIRARDI & KEESE NANO BANC ACTIVE (All Assets and proceeds)
1126 WILSHIRE 25220 HANCOCK
BOULEVARD AVENUE, STE. 140
LOS ANGELES CA MURRIETA CA 92562
90017
None None None None None None
None None None None None None
Original 197746713843 11/14/2019 11/14/2024 GIRARDI & KEESE
1126 WILSHIRE
BLVD
LOS ANGELES CA
90017-1904
CT CORPORATION
SYSTEM, AS
REPRESENTATIVE
330 N. BRAND BLVD
SUITE 700
GLENDALE, CA
91203
ACTIVE (All Assets and proceeds) California Attorney Lending II has
confirmed that this UCC Financing
Statement was filed on its behalf.
None None None None None None

71

Table 1 on page 72. Back to List of Tables
Judgment Lien U200027063225 10/6/2020 GIRARDI | KEESE
1126 WILSHIRE
BLVD
LOS ANGELES CA
90017-1904
JAMIE, JOSEPH &
KATHLEEN
RUIGOMEZ
16001 VENTURA
BLVD.
SUITE 200
ENCINO CA91436
ACTIVE (Judgment Lien on
Personal Property)
$ 11,491,232.87
GIRARDI THOMAS
V.
100 LOS ALTOS
DRIVE
PASADENA CA
91105
None None None None None None
Judgment Lien U200033578428 11/2/2020 GIRARDI & KEESE
1126 WILSHIRE
BLVD.
LOS ANGELES CA
90017
CALIFORNIA
ATTORNEY
LENDING II, INC.
6400 MAIN STREET,
SUITE 120
WILLIAMSVILLE NY
14221
ACTIVE (Judgment Lien on
Personal Property)
$ 6,254,014.57
GIRARDI THOMAS
V.
100 LOS ALTOS
DRIVE
PASADENA CA
None None None None None None
Judgment Lien U200037891132 12/17/2020 GIRARDI KEESE
1126 WILSHIRE
BLVD
LOS ANGELES CA
90017
KCC CLASS ACTION
SERVICES, LLC
222 N. PACIFIC
COAST HIGHWAY
THIRD FLOOR
EL SEGUNDO, CA
90245
ACTIVE (Judgment Lien on
Personal Property)
$ 7,504,109.59
THOMAS V.
GIRARDI
100 LOS ALTOS
DRIVE
PASADENA, CA

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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): CHAPTER 7 TRUSTEE'S SECOND MOTION FOR ORDER PPROVING STIPULATIONS FOR USE OF CASH COLLATERAL AND AUTHORIZING USE OF CASH COLLATERAL URSUANT TO 11 U.S.C. § 363 AND FEDERAL RULE OF BANKRUPTCY PROCEDURE 4001(b) AND (d);MEMORANDUM OF OINTS AND AUTHORITIES, DECLARATIONS OF ELISSA D. MILLER AND PHILIP E. STROK IN SUPPORT will be served or as served (a) on the judge in chambers in the form and manner required by LBR 5005-2(d); and (b) in the manner stated elow: .TO BE SERVED BY THE COURT VIA NOTICE OF ELECTRONIC FILING (NEF): Pursuant to controlling Generalrders and LBR, the foregoing document will be served by the court via NEF and hyperlink to the document. On (date)arch 30, 2021 I checked the CM/ECF docket for this bankruptcy case or adversary proceeding and determined thate following persons are on the Electronic Mail Notice List to receive NEF transmission at the email addresses statedelow: Service information continued on attached pag . SERVED BY UNITED STATES MAIL: n (date) March 30, 2021, I served the following persons and/or entities at the last known addresses in thisankruptcy case or adversary proceeding by placing a true and correct copy thereof in a sealed envelope in the Unitedtates mail, first class, postage prepaid, and addressed as follows. Listing the judge here constitutes a declaration thatailing to the judge will be completed no later than 24 hours after the document is filed. he Honorable Barry Russell IKON Financial Svcs .S. Bankruptcy Court 1738 Bass Rd. oybal Federal Building Macon, GA 31210-1043 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 methodr each person or entity served): Pursuant to F.R.Civ.P. 5 and/or controlling LBR, on (date) March 30, 2021, I served thllowing persons and/or entities by personal delivery, overnight mail service, or (for those who consented in writing touch service method), by facsimile transmission and/or email as follows. Listing the judge here constitutes a declarationat personal delivery on, or overnight mail to, the judge will be completed no later than 24 hours after the document isled. IA E-Mail 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 30,2021 Gabriela Gomez-Cruz /s/ Gabriela Gomez-Cruz Date PrintedName Signature

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. 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  •William C Beall will@beallandburkhardt.com, carissa@beallandburkhardt.com •Ori S Blumenfeld Ori@MarguliesFaithLaw.com, Helen@MarguliesFaithLaw.com;Angela@MarguliesFaithLaw.com;Vicky@MarguliesFaithLaw.com •Sandor Theodore Boxer tedb@tedboxer.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 •Jeremy Faith Jeremy@MarguliesFaithlaw.com, Helen@MarguliesFaithlaw.com;Angela@MarguliesFaithlaw.com;Vicky@MarguliesFaithlaw.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 •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  •Sheryl K Ith sith@cookseylaw.com, sith@ecf.courtdrive.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 •Craig G Margulies Craig@MarguliesFaithlaw.com, Vicky@MarguliesFaithlaw.com;Helen@MarguliesFaithlaw.com;Angela@MarguliesFaithlaw.com •Peter J Mastan peter.mastan@dinsmore.com, SDCMLFiles@dinsmore.com;Katrice.ortiz@dinsmore.com •Edith R. Matthai ematthai@romalaw.com, lrobie@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 •Kevin C Ronk Kevin@portilloronk.com, Attorneys@portilloronk.com •William F Saavino wsavino@woodsoviatt.com, lherald@woodsoviatt.com •Kenneth John Shaffer johnshaffer@quinnemanuel.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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.SERVED BY PERSONAL DELIVERY, OVERNIGHT MAIL, FACSIMILE TRANSMISSION OR EMAILia E-mail: ndrew W Zepeda Rafey Balabanian Nano Banc ames J Finsten Edelson PC 25220 Hancock Ave., Suite 140 urie, Zepeda, Schmalz, Hogan & Martin 123 Townsend St Ste 100 Murrieta, CA 92562 875 Century Park E Ste 2100 San Francisco, CA 94107 epadilla@nanobanc.com os Angeles, CA 90067 rbalabanian@edelson.com pdonaldson@nanobanc.com zepeda@lurie-zepeda.com insten@lurie-zepeda.com bir Cohen Treyzon Salo, LLP Law Finance Group, LLC LFG Special Investor Group, LLC /o: Boris Treyzon 591 Redwood Hwy Finance Group Fund II 6001 Ventura Boulevard, Suite 200 Suite 1200 200 South Virginia St., 8th Floor ncino, CA 91436 Mill Valley, CA 94941 Reno, NV 89501 treyzon@actslaw.com info@lawfinance.com info@lawfinance.com orporation Service Company, As Jeffrey M. Schwartz, Esq.  CT Corporation System, as epresentative Much Shelist, P.C.  Representative .O.Box 2576 CT Lien Solutions 191 North Wacker Drive, Suite 1800  pringfield, IL 62708 330 N. Brand Blvd., Suite 700 01 Adlai Stevenson Dr. Chicago, IL 60606  Glendale, CA 91203 pringfield, IL 62703 Telephone: (312) 521‐2626  UCCSPREP@CSCINFO.com CCSPREP@CSCINFO.com jschwartz@muchlaw.com  Attorneys for Nano Bank 

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