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Full title: Motion for Order Authorizing the Transition and Assignment of the Estate's Interests in the Paramount Litigation Free and Clear of Liens, Claims and Interests Pursuant to 11 U.S.C. Section 363; Memorandum of Points and Authorities; Declaration of Elissa D. Miller in Support with Proof of Service Filed by Trustee Elissa Miller (TR) (Ekvall, Lei Lei) (Entered: 04/30/2021)

Document posted on Apr 29, 2021 in the bankruptcy, 26 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

The assignment to Thomassian, including without limitation the Thomassian 23 Allocation, shall be free and clear of all liens, claims, encumbrances, and other interests 24 pursuant to Bankruptcy Code section 363(f), including but not limited to (i) any purported25 liens, assignments, encumbrances, or other purported transfers to litigation funders or 26 other creditors of the Debtor, and (ii) any purported assignments or transfers (or 27 agreements to a substitution of counsel or notice of association or appearance) by the 1 Any liens, claims, encumbrances, or other interests of the Debtor’s creditors or 2 other entities that may assert an interest in the Debtor’s right to attorneys’ fees or other 3 compensation relating to the Clients shall attach only to the Estate Allocation, to the 4 same extent, priority, and validity (if any) that such liens, claims, encumbrances, or other5 interests had prior to consummation of the Agreement, and subject to any claims or 6 defenses the Trustee or the Estate may have. “Costs” mean all reasonable costs incurred by the Debtor or Thomassian relating to the representation of the Clients in the Paramount Litigation, including (i) filing fees and other court costs, (ii) expert witness fees and expenses, (iii) client costs, (iv) discovery-related expenses, including reporter costs, transcript costs, and costs relating to document production and storage, (v) marketing expenses, (vi) steering committee contributions, and (vii) all costs and expenses of case management and accounting.Any liens, claims, encumbrances, or other interests of the Debtor’s creditors or other entities that may assert an interest in the Debtor’s right to attorneys’ fees or other compensation relating to the Clients shall attach only to the Estate Allocation, to the same extent, priority, and validity (if any) that such liens, claims, encumbrances, or other interests had prior to consummation of this Agreement, and subject to any claims or defenses the Trustee or the Estate may have. Neither Thomassian nor the Trustee shall make any voluntary assignment, voluntary referral, or other voluntary transfer that would cause fees that would otherwise be Fees to be paid to any other counsel, entity, or person, unless such assignment, referral, or other transfer (i) by Thomassian is solely out of the Thomassian Allocation, or (ii) by the Trustee (and with Bankruptcy Court approval) is solely out of the Estate Allocation. validity (if any) that such liens, claims, encumbrances, or other interests had prior to consummation of this Agreement, and subject to any claims or defenses the Trustee or the Estate may have; such claims, liens encumbrances, or other interests shall not attach to the Thomassian Allocation, (iv) Thomassian is assuming no liabilities of the Estate, the Debtor, or any partners, members,attorneys, insiders, affiliates, or employees thereof, whether under contract, tort, or otherwise,(v) the Federal Rule of Evidence 502(d) prot

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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 MTHOET ITORNA FNOSRIT IOORND AENRD A AUSTSHIOGRNIMZIENNGT s0 15 OF THE ESTATE'S INTERESTS IN THE e1 M5- PARAMOUNT LITIGATION FREE AND a 4 ost4 4 16 CLEAR OF LIENS, CLAIMS AND C71 INTERESTS PURSUANT TO 11 U.S.C. el 17 § 363; MEMORANDUM OF POINTS AND T AUTHORITIES; DECLARATION OF 18 ELISSA D. MILLER IN SUPPORT Debtor. 19 [No Hearing Required Pursuant to Local Bankruptcy Rule 9013-1(o)] 20 21 22 TO THE HONORABLE BARRY RUSSELL, UNITED STATES BANKRUPTCY JUDGE: 23 Elissa D. Miller, the chapter 7 trustee for the bankruptcy estate of Girardi Keese 24 (the "Trustee"), submits this Motion for Order Authorizing the Transition and Assignment 25 of the Estate's Interests in the Paramount Litigation Free and Clear of Liens, Claims and 26 Interests Pursuant to 11 U.S.C. § 363 (the "Motion"). In support of the Motion, the 27 Trustee submits the following memorandum of points and authorities and the attached

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1 I. INTRODUCTION 2 Prior to the involuntary petition, Girardi Keese (the "Debtor") was a prominent 3 plaintiff's law firm representing clients in the areas of personal injury, defective products, 4 sexual abuse, toxic torts, business law, employment law, and aviation law. Since her 5 appointment, the Trustee and her counsel have diligently worked to analyze the Debtor's6 pending cases. To protect the Debtor's clients, the Trustee and her counsel have 7 engaged in discussions with various law firms to discuss the possibility of transferring 8 some or all of the Debtor's pending cases to qualified and experienced counsel. 9 Pre-petition, the Debtor represented approximately 137 plaintiffs (the "Clients") in 10 an action involving alleged personal injury and property damage arising from toxic 11 emissions in Paramount, California (the "Paramount Litigation"). The Paramount 2 0 0 92626 4 445-1 1123 Lbeitifgoareti oan s ies ttclelomsee ntot craesno bluet imone mbuotr itahleizreed a aren da dthdeit iConliaeln ttass pkasi dth. a At fnteere da ptop rboea cchoimngp lae ted ornia ax 71 a, Calif00 • F 14 couple of law firms regarding transition of the Paramount Litigation, the Trustee has s0 15 entered into an agreement with The Law Offices of Antony Thomassian ("Thomassian"), e1 M5- a 4 ost4 4 16 who will be collaborating with The Law Offices of Tim D. Wright ("Wright") (Thomassian C1 7 el 17 and Wright are hereinafter collectively referred to as "Thomassian"). Thomassian is T 18 already familiar with the Paramount Litigation. Among other things, Wright referred 19 approximately 1/3 of the Clients to the Debtor. Thomassian is experienced in personal 20 injury lawsuits and has the requisite expertise and resources to represent the Clients in 21 the Paramount Litigation. 22 The proposed assignment, which is subject to each Client's consent, is in the best23 interest of the Estate and the Clients are assured of being represented by competent 24 counsel. Additionally, the Estate will collect 66.7% of any contingency fees earned, plus 25 costs, in the Paramount Litigation, which is a good outcome for the Estate. For these 26 reasons, the Motion should be granted. 27

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1 II. BACKGROUND 2 A. The Debtor's Bankruptcy Case 3 The Debtor was a well-respected plaintiff's law firm based in Los Angeles, 4 California. On December 18, 2020, petitioning creditors Jill O'Callahan, as successor in 5 interest to James O'Callahan, Robert M. Keese, John Abassian, Erika Saldana, Virginia 6 Antonio, and Kimberly Archie (collectively, the "Petitioning Creditors") filed an involuntary7 chapter 7 bankruptcy petition against the Debtor.1 On December 24, 2020, the 8 Petitioning Creditors filed a Motion for Appointment of Interim Trustee Pursuant to 9 11 U.S.C. § 303(g) [Docket No. 12]. The Court entered an order granting the motion on 10 January 5, 2021 [Docket No. 45]. On January 6, 2021, the Trustee was appointed as th11 interim trustee [Docket No. 50]. 2 0 0 92626 4 445-1 1123 to ImmOedni aJtaenlyu aErnyt e1r3 a, n2 0O2r1d,e trh feo rC Roeurlite ef nutnedreedr Canh aOprtdeer r7 D; (i2re) cTtihneg :U (n1i)t eTdh eS tCatleersk T orfu Cstoeuer ornia ax 71 a, Calif00 • F 14 to Immediately Appoint a Chapter 7 Trustee; (3) The Debtor to File All Schedules and s0 15 Related Documentation for Chapter 7 Case within Fourteen Days of the Entry of this e1 M5- a 4 ost4 4 16 Order; and (4) Vacating February 16, 2021 Status Conference [Docket No. 68]. On C1 7 el 17 January 13, 2021, the Clerk of Court entered an order for relief against the Debtor T 18 [Docket No. 69], and the Trustee was appointed and accepted her appointment in the 19 Debtor's case [Docket No. 71]. 20 B. The Debtor's Pending Cases 21 As of the filing of the involuntary petition against the Debtor, the Debtor was 22 counsel of record in a significant number of cases which were undertaken on a 23 contingency fee basis. Since her appointment, the protection of the clients' rights has 24 been one of the Trustee's highest concerns. As a result, the Trustee and her counsel 25 26 1 The Petitioning Creditors also filed an involuntary chapter 7 bankruptcy petition 27 against Thomas V. Girardi, which is currently pending as Bankruptcy Case No. 2:20-bk-21020-BR.

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1 have initiated discussions with a number of law firms, with the goal of transferring some 2 or all of the Debtor's pending cases to counsel. See Declaration of Elissa D. Miller. 3 C. The Transition Agreement 4 The Debtor was counsel of record for approximately 137 plaintiffs in the 5 Paramount Litigation. The Debtor is not able to continue to perform as counsel for the 6 clients and Thomassian wishes to substitute in as counsel for the Clients, subject to eac 7 Client's written consent. The Debtor's claim to fees and costs in the Paramount Litigatio8 is an asset of value. Accordingly, the Trustee and Thomassian entered into a transition 9 agreement, whereby the Trustee agreed to transfer the Estate's interest in 137 cases in 10 the Paramount Litigation to Thomassian (the "Agreement"). The salient terms of the 11 Agreement are as follows: 2 0 0 92626 4 445-1 1123 All fees1 .th at mAalylo bcea trieocne iovfe dF ebeys T homassian or the Debtor on account of the ornia ax 71 a, Calif00 • F 14 representation of the Clients in the Paramount Litigation, net of any common benefit s0 15 assessments ("Fees"), shall be allocated as follows: e1 M5- a 4 ost4 4 16 (a) To the Trustee for the benefit of the Estate, 66.7% of the Fees after C1 7 el 17 deducting costs (the “Estate Allocation”); T 18 (b) To Thomassian, 33.3% of the Fees after deducting Costs (the 19 "Thomassian Allocation"). Any Referral Fees due on cases which have been 20 referred to the Debtor and are transferred to Thomassian pursuant to the 21 Agreement shall be deducted from the Thomassian Allocation. Thomassian 22 agrees to assume the representation of the Clients under the same fee structure 23 as that which was agreed to in writing between the Clients and the Debtor. 24 (c) It is understood and acknowledged that the Debtor has advanced or25 otherwise incurred costs in the Paramount Litigation, some of which may be claim26 in the Bankruptcy Case, and reimbursement for such costs will be made to the 27 Estate as part of the Estate Allocation.

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1 2. Payment Of Allocated Fees 2 All Fees shall be initially payable to a trust fund administered by Thomassian. 3 Within 30 days of receipt, Thomassian shall calculate the Thomassian Allocation and the 4 Estate Allocation and notify the Trustee of the proposed allocation. If the Trustee does 5 not object to the proposed allocation within 14 days after such notice, Thomassian shall 6 distribute the Fees in accordance with the proposed allocation. If the Trustee does 7 object, Thomassian shall reserve such amount as would be necessary to satisfy the 8 Trustee’s objection, if sustained, and may distribute the remainder. The Trustee and 9 Thomassian agree to attempt to resolve any dispute promptly, which resolution shall be 10 subject to approval under Bankruptcy Rule 9019. If the parties cannot resolve their 11 dispute within 30 days, the matter will be submitted to the Bankruptcy Court. 2 0 0 92626 4 445-1 1123 Thoma3s.s ian aCnodm thme oEns tDaetef esnhsaell Bseepnaerfaitte Clyl ariemta in 100% of any common ornia ax 71 a, Calif00 • F 14 defense/benefit fund claim owing to them, and each shall be separately responsible for as0 15 costs, expenses, and other charges associated with their respective claims. e1 M5- a 4 ost4 4 16 4. Assignment Of All Other Rights / Free And Clear Assignment. C1 7 el 17 Subject to the fee sharing agreement set forth above, all of the Debtor’s and the T 18 Estate’s interests in the Paramount Litigation shall be assigned to Thomassian "as-is", 19 "where-is", and without representation or warranty of any kind by the Trustee including, 20 without limitation, any representation or warranty as to the Clients or the continued 21 representation of the Clients by Thomassian. 22 The assignment to Thomassian, including without limitation the Thomassian 23 Allocation, shall be free and clear of all liens, claims, encumbrances, and other interests 24 pursuant to Bankruptcy Code section 363(f), including but not limited to (i) any purported25 liens, assignments, encumbrances, or other purported transfers to litigation funders or 26 other creditors of the Debtor, and (ii) any purported assignments or transfers (or 27 agreements to a substitution of counsel or notice of association or appearance) by the

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1 Any liens, claims, encumbrances, or other interests of the Debtor’s creditors or 2 other entities that may assert an interest in the Debtor’s right to attorneys’ fees or other 3 compensation relating to the Clients shall attach only to the Estate Allocation, to the 4 same extent, priority, and validity (if any) that such liens, claims, encumbrances, or other5 interests had prior to consummation of the Agreement, and subject to any claims or 6 defenses the Trustee or the Estate may have. The Thomassian Allocation shall be free 7 and clear of such liens, claims, encumbrances, or other interests. For the avoidance of 8 doubt, Thomassian is assuming no liabilities of the Estate, the Debtor, or any current or 9 former partners, members, attorneys, insiders, affiliates, or employees thereof, whether 10 under contract, tort, or otherwise. 11 5. Withdrawal And Substitution Of Debtor As Counsel and Lien in 2 0 0 92626 4 445-1 1123 The Trustee aFnadv Tohr oomf athsesi aEns tsahtael l take all steps reasonably necessary to cause ornia ax 71 a, Calif00 • F 14 the Debtor to be substituted out and Thomassian to be substituted in as counsel for the s0 15 Clients in the Paramount Litigation. The Trustee shall coordinate with Thomassian to e1 M5- a 4 ost4 4 16 provide for the smooth transition of the cases and to notify the Clients that their cases wilC1 7 el 17 be handled solely by Thomassian. Thomassian agrees and the Clients shall T 18 acknowledge and agree that the Estate has a lien in the Paramount Litigation for the 19 Estate Allocation and Costs advanced or otherwise incurred by the Debtor. The lien will 20 attach to any recovery the Clients may obtain in the Paramount Litigation, whether by 21 arbitration award, judgment, settlement, or otherwise. The Trustee, on behalf of the 22 Debtor and the Estate, is hereby authorized to take all steps deemed necessary by the 23 Trustee to protect and preserve the lien. 24 Immediately upon execution of the Agreement, the Trustee consents to 25 Thomassian communicating to the Clients the existence and/or terms of the Agreement, 26 provided that prior to Bankruptcy Court approval of the Agreement, any such 27 communication note that the Agreement is subject to such approval.

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1 6. Bankruptcy Court Approval 2 The terms of the Agreement, and the effectiveness thereof, are subject to Court 3 approval. 4 A copy of the Agreement is attached hereto as Exhibit "1." 5 6 III. MEMORANDUM OF POINTS AND AUTHORITIES 7 A. The Court Can Authorize the Assignment Under 11 U.S.C. § 363(b) 8 Section 363(b) of the Bankruptcy Code empowers a trustee to "use, sell or 9 lease…other than in the ordinary course of business, property of the estate…" A 10 transaction outside the ordinary course of business is appropriate when proposed in goo11 faith and supported by a sound or valid business justification. In consideration of a 2 0 0 92626 4 445-1 1123 ptrraonpsoascetido ntr aisn sina cthtieo nb etos tu isnete orer sstesl lo pf rtohpee ertsyt aotfe t hbea seesdta oten, tchoeu fratsc tlso oakn da th wishtoertyh eorf tthhee ornia ax 71 a, Calif00 • F 14 case. In re America West Airlines, 166 B.R. 908, 912 (Bankr. D. Ariz.1994) (citing In re s0 15 Lionel Corp., 722 F.2d 1063, 1071 (2d Cir. 1983)). This requires examination of the e1 M5- a 4 ost4 4 16 "business justification" for the proposed transaction. In re 240 North Brand Partners, C1 7 el 17 Ltd., 200 B.R. 653, 659 (B.A.P. 9th Cir. 1996); In re Ernst Home Center, Inc., 209 B.R. T 18 974 (Bankr. W.D. Wash. 1997). A trustee's business judgment is subject to great judicial19 deference. See In re Lahijiani, 325 B.R. 282, 289 (B.A.P. 9th Cir. 2005); see also In re 20 MF Global, Inc., 535 B.R. 596, 605 (Bankr. S.D.N.Y. 2015); GBL Holding Co., Inc. v. 21 Blackburn/Travis/Cole, Ltd., 331 B.R. 251, 255 (N.D. Tex. 2005); In re Psychrometric 22 Systems, Inc., 367 B.R. 670, 674 (Bankr. D. Colo. 2007). 23 The proposed assignment is in the best interests of the Estate and has been 24 proposed in good faith. Under the Agreement, the Estate will realize 66.7% of any 25 contingency fees earned plus costs on terms that are fair to the Estate. Finally, the 26 Agreement is the product of the Trustee's arms-length negotiations with Thomassian. 27 Thomassian is already familiar with the Paramount Litigation. Thomassian was willing to

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1 satisfactory to the Trustee. There is a valid business justification for the Agreement, and2 the Agreement is in the best interests of the Estate. See Declaration of Elissa D. Miller. 3 For these reasons, the Court should authorize the assignment under the Agreement 4 under 11 U.S.C. § 363(b). 5 B. The Court May Authorize the Assignment of the Estate's Interests in 6 the Paramount Litigation Free and Clear of Any Liens and Interests 7 Under 11 U.S.C. § 363(f) 8 As noted earlier, the Agreement provides that any creditors of the Debtor that ma9 hold an interest in the Debtor's future recovered attorneys' fees may only assert such 10 interests against the Estate Allocation. These claims are unique to the Debtor. Simply 11 put, creditors can only assert their claims and interests against the Debtor, not against 2 0 0 92626 4 445-1 1123 Tinhteormesatsss aiarne oorn ltyh ea gTahionmst athssei aEns tAaltleo cAaltloiocna.t i oTnos m, tahkee T crluesatre eth aset ethkess Ce ocurertd aitpoprsro' pvaolt eton tial ornia ax 71 a, Calif00 • F 14 authorize the assignment contemplated in the Agreement to be free and clear of any s0 15 liens, claims and interests under 11 U.S.C. § 363(f). e1 M5- a 4 ost4 4 16 The Court can authorize the assignment of the Estate's interests in the ParamounC1 7 el 17 Litigation free and clear of any liens, claims and interests under 11 U.S.C. § 363(f). T 18 Section 363(f) provides the following: 19 (f) The trustee may sell property under subsection (b) or (c) of this section free and clear of any interest in such property of an entity other than the 20 estate, only if— 21 (1) applicable nonbankruptcy law permits sale of such property free and clear of such interest; 22 (2) such entity consents; 23 (3) such interest is a lien and the price at which such property is to 24 be sold is greater than the aggregate value of all liens on such property; 25 (4) such interest is in bona fide dispute; or 26 (5) such entity could be compelled, in a legal or equitable 27 proceeding, to accept a money satisfaction of such interest

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1 Because 11 U.S.C. § 363(f) is written in the disjunctive, the Court may authorize 2 the assignment free and clear of any interests if any of the conditions are met. 3 The Court can authorize assignment of the Estate's interests in the Paramount 4 Litigation free and clear of any liens, claims and interests under 11 U.S.C. § 363(f)(5). 5 Section 363(f)(5) "requires that there be, or that there be the possibility of, some 6 proceeding, either at law or at equity, in which the nondebtor could be forced to accept 7 money in satisfaction of its interest." Clear Channel Outdoor, Inc. v. Knupfer (In re PW, 8 LLC), 391 B.R. 25, 45 (B.A.P. 9th Cir. 2008). The California Commercial Code provides 9 for a proceeding where the nondebtor could be forced to accept money satisfaction of its10 interest. Under California Commercial Code § 9610(a), "[a]fter default, a secured party 11 may sell…or otherwise dispose of any or all the collateral in its present condition or 2 0 0 92626 4 445-1 1123 fCoollomwminegrc aianly C coodmem §e 9rc6i1a0ll(ya r)e. a Fsuornthaebrle, "p[are] psaercautrioend opra rptryo scheaslsl ianpgp."l y S…eteh eC caalifsohr npirao ceedsornia ax 71 a, Calif00 • F 14 of disposition under Section 9610... [to] the satisfaction of obligations secured by the s0 15 security interest…[and] the satisfaction of obligations secured by any subordinate e1 M5- a 4 ost4 4 16 security interest…" See California Commercial Code § 9615(a). Here, because any C1 7 el 17 party that potentially holds a security interest in the Estate's fees from the Paramount T 18 Litigation can be compelled to accept a money satisfaction under California Commercial 19 Code §§ 9610(a) and 9615(a), 11 U.S.C. § 363(f)(5) applies. Thus, the Court may 20 authorize the assignment contemplated in the Agreement free and clear of any liens, 21 claims and interests under 11 U.S.C. § 363(f)(5). 22 The Agreement is reasonable and in the best interest of the Debtor's creditors. 23 Pursuant to the Agreement, the Estate will receive 66.7% of the fees recovered for the 24 Clients in the Paramount Litigation and all of its costs. This result greatly benefits the 25 Estate and will likely yield a recovery for the Estate that is greater than what the Estate 26 would recover litigating a quantum meruit claim. 27 The Agreement is also in the best interest of the Debtor's clients. While the

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1 the Clients with the opportunity to continue with reputable and experienced counsel 2 through the proposed representation. Moreover, the Clients will be represented by 3 counsel who is already familiar with the Paramount Litigation. Ultimately, if the Clients 4 opt for the proposed representation, they will be represented by counsel that is already 5 knowledgeable about the case and is experienced and qualified. Thus, the Agreement i6 in the best interests of the clients. 7 C. Waiver of 14-Day Stay Set Forth in FRBP 6004(h) is Appropriate 8 FRBP 6004(h) provides that "[a]n order authorizing the use, sale, or lease of 9 property other than cash collateral is stayed until the expiration of 14 days after entry of 10 the order, unless the court orders otherwise." Given the involuntary petition commenced11 against the Debtor, it is in the best interests of the Clients to resolve any uncertainty they2 0 0 92626 4 445-1 1123 monagyo hinagv,e r ecsoonlcveinrgn inagn yw choon ifsu sreiopnr easse qnutiincgk ltyh aesm p. o Bsesicbaleu sise itnh eth Pe abreasmt oinutnetr eLsitti goaf ttihoen is ornia ax 71 a, Calif00 • F 14 clients. Waiver of the stay under FRBP 6004(h) will further preserve the amount of fees s0 15 the Estate can expect to collect pursuant to the Agreement. For these reasons, waiver oe1 M5- a 4 ost4 4 16 the FRBP 6004(h) stay is appropriate. C1 7 el 17 T 18 IV. CONCLUSION 19 Accordingly, the Trustee respectfully requests that the Court enter an order 20 providing for the following relief: 21 1. Granting the Motion; 22 2. Authorizing the Trustee to enter into the Agreement; 23 3. Approving the terms of the Agreement, a copy of which is attached hereto 24 as Exhibit "1"; 25 4. Authorizing the Trustee to execute any documents or take any actions 26 reasonably necessary to effectuate the terms of the Agreement; 27 5. Approving the transaction as contemplated in the Agreement pursuant to

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1 6. Authorizing and ordering the assignment and transfer of any rights or 2 payment to property as contemplated in the Agreement to be free and clear of all claims,3 liens, encumbrances, or other interests against the Debtor pursuant to 11 U.S.C. § 363(f4 7. Authorizing and ordering that any asserted claims, liens, encumbrances, or5 other interests against the Debtor will attach only to the Estate Allocation and not to the 6 Thomassian Allocation; 7 8. Finding that Thomassian is not assuming any liabilities of the Estate, the 8 Debtor, or any partners, members, attorneys, insiders, affiliates, or employees thereof, 9 whether under contract, tort, or otherwise; 10 9. Finding that the Federal Rule of Evidence 502(d) protections for attorney-11 client privilege and work-product set forth in the Agreement apply; 2 0 0 92626 4 445-1 1123 1110.. FAourt hsourcizhi nogt htehre rwelaieivf ears o tfh teh eC o1u4r-td maya py edreioedm u jnudset ra FnRd BnPec 6e0s0s4a(rhy.) ; and ornia ax 71 a, Calif00 • F 14 s0 15 DATED: April 30, 2021 Respectfully submitted, e1 a M45- ost4 4 16 SMILEY WANG-EKVALL, LLP C1 7 el 17 T 18 By: /s/ Lei Lei Wang Ekvall 19 LEI LEI WANG EKVALL Attorneys for Elissa D. Miller, Chapter 7 20 Trustee 21 22 23 24 25 26 27

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1 DECLARATION OF ELISSA D. MILLER 2 3 I, Elissa D. Miller, declare as follows: 4 1. I am the duly appointed Chapter 7 Trustee in the bankruptcy case of Girard 5 Keese. I am also a partner at the law firm SulmeyerKupetz, a Professional Corporation. 6 I know each of the following facts to be true of my own personal knowledge, except as 7 otherwise stated and, if called as a witness, I could and would competently testify with 8 respect thereto. I make this declaration in support of the Motion for Order Authorizing th 9 Assignment of the Estate's Interests in the Paramount Litigation Free and Clear of Liens,10 Claims and Interests Pursuant to 11 U.S.C. § 363 (the "Motion"). Unless otherwise 11 defined in this declaration, all terms defined in the Motion are incorporated herein by this2 0 0 92626 4 445-1 1123 referen2c.e . The Debtor was counsel of record in a significant number of pending casesornia ax 71 a, Calif00 • F 14 when the Petitioning Creditors commenced the involuntary petition against the Debtor. s0 15 The Debtor undertook these cases on a contingency fee basis. e1 M5- a 4 ost4 4 16 3. Since my appointment, one of my highest priorities was ensuring that the C1 7 el 17 rights of the Debtor's current clients in pending matters were protected. In order to T 18 protect these clients' rights, I immediately began to interview law firms—with the 19 assistance of my counsel—to explore the possibility of transferring the Debtor's pending 20 cases. The goal of my discussions with these law firms was to ultimately transfer some 21 or all of the pending cases to protect the clients' rights. 22 4. At the time of my appointment, the Debtor was counsel of record for 23 approximately 137 plaintiffs in the Paramount Litigation. 24 5. Recently, I entered into the Transition Agreement on behalf of the Estate 25 whereby I agreed to transfer the Estate's interest in the Paramount Litigation to 26 Thomassian, who will be collaborating with Wright. A true and correct copy of the 27 Agreement is attached hereto as Exhibit "1."

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1 6. The Paramount Litigation is close to resolution but there are additional 2 tasks that need to be completed before a settlement can be memorialized and the Client3 paid. After approaching a couple of law firms regarding transition of the Paramount 4 Litigation, I entered into the Agreement with Thomassian and Wright. I am informed that 5 Thomassian and Wright are already familiar with the Paramount Litigation. Among other6 things, Wright referred approximately 1/3 of the Clients to the Debtor. Thomassian and 7 Wright are experienced in personal injury lawsuits and have the requisite expertise and 8 resources to represent the Clients in the Paramount Litigation. 9 7. The Agreement is the product of my arms-length negotiations with 10 Thomassian and Wright and will allow the Estate to transfer the Paramount Litigation so 11 that it can be completed, while allowing the Estate to collect 66.7% of the recovered 2 0 0 92626 4 445-1 1123 attorne8y.s ' feesIn, pmluys o iptsin cioons tas.n d based on my business judgment, the Agreement is in thornia ax 71 a, Calif00 • F 14 best interest of the Estate, because it is reasonable and will likely yield a recovery for thes0 15 Estate that is greater than what the Estate would recover litigating a quantum meruit e1 M5- a 4 ost4 4 16 claim. C1 7 el 17 9. In sum, I believe there is valid business justification for the Agreement, as T 18 the Agreement will result in the best outcome for the Estate and the Debtor's clients. 19 I declare under penalty of perjury under the laws of the United States of America 20 that the foregoing is true and correct. 21 Executed on this 30th day of April, 2021, at __L_o_s_ A_n_g_e_le_s_______, California. 22 23 ELISSA D. MILLER 24 25 26 27

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EXHIBIT "1"

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TRANSITION AGREEMENT This Settlement Agreement (“Agreement”) is entered into by and between Elissa D. Miller (“Trustee”), solely in her capacity as trustee of the estate (“Estate”) of Girardi Keese (“Debtor”), the chapter 7 debtor in case number 2:20-bk-21022-BR (“Bankruptcy Case”) pending in the U.S. Bankruptcy Court for the Central District of California (“Bankruptcy Court”), on the one hand, and Law Offices of Antony Thomassian ("Thomassian") and The Law Offices of Tim D. Wright (“Wright”), on the other hand. The Trustee, Thomassian and Wright may hereinafter be referred to individually as a “Party” and collectively as the “Parties.” RECITALS WHEREAS, an involuntary chapter 7 bankruptcy petition was filed against the Debtor on December 18, 2020 (“Petition Date”), commencing the Bankruptcy Case [Docket No. 1]; WHEREAS, on January 5, 2021, the Bankruptcy Court ordered the appointment of an interim trustee [Docket No. 45]. The Trustee was appointed as interim trustee and accepted her appointment on January 6, 2021 [Docket No. 46]; WHEREAS, on January 13, 2021, the Bankruptcy Court entered an “Order Directing: (1) The Clerk of Court to Immediately Enter an Order for Relief under Chapter 7; (2) The United States Trustee to Immediately Appoint a Chapter 7 Trustee; (3) The Debtor to File All Schedules and Related Documentation for Chapter 7 Case within Fourteen Days of the Entry of this Order; and (4) Vacating February 16, 2021 Status Conference” [Docket No. 68]. On January 13, 2021, the Clerk of Court entered an order for relief against the Debtor [Docket No. 69], and the Trustee was appointed and accepted her appointment [Docket No. 70]; WHEREAS, prior to the Petition Date, the Debtor was counsel of record for approximately 137 plaintiffs ("Clients") in an action involving alleged personal injury and property damage arising from toxic emissions in Paramount, California (the "Paramount Litigation"). WHEREAS, the Debtor is not able to continue to perform as counsel for the Clients; WHEREAS, Thomassian wishes to substitute in as counsel for the Clients with Wright's collaboration. Thomassian and Wright are already familiar with the Paramount Litigation (Thomassian and Wright are hereinafter collectively referred to as "Thomassian"). The transition of the Clients to Thomassian is subject to each Client's consent. WHEREAS, following good faith, arm’s length negotiations, and to avoid the expense, delay, and risks of litigation, and to ensure continuous representation and a smooth transition for the Clients, the Parties desire to transfer the Debtor's files relating to the Paramount Litigation to Thomassian, pursuant to the terms and conditions as hereinafter set forth, and pursuant to Bankruptcy Code section 363;

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NOW, THEREFORE, in consideration of the mutual terms and covenants to be performed by each of the Parties hereto, and subject to approval of this Agreement by the Bankruptcy Court, the Parties hereby agree as follows: TERMS AND CONDITIONS 1. Definitions. In addition to the definitions in the Recitals or otherwise in this Agreement, the following definitions shall apply: “Clients” mean the Clients of the Debtor in the Paramount Litigation which are to be transferred to Thomassian, subject to the Clients' express consent. For the avoidance of doubt and except as set forth above, Clients shall not include any client that retains Thomassian after the Petition Date and that was not a client of the Debtor in the Paramount Litigation (i.e., totally new clients). “Costs” mean all reasonable costs incurred by the Debtor or Thomassian relating to the representation of the Clients in the Paramount Litigation, including (i) filing fees and other court costs, (ii) expert witness fees and expenses, (iii) client costs, (iv) discovery-related expenses, including reporter costs, transcript costs, and costs relating to document production and storage, (v) marketing expenses, (vi) steering committee contributions, and (vii) all costs and expenses of case management and accounting. All such costs are subject to documentation, which documentation shall be provided to the Trustee or Thomassian. No interest shall accrue or be payable on account of Costs. “Fees” mean all fees that may be received by Thomassian or the Debtor on account of the representation of the Clients in the Paramount Litigation, net of any common benefit assessments. Thomassian agrees to assume the representation of the Clients under the same fee structure as that which was agreed to in writing between the Clients and the Debtor. “Referral Fees” mean referral fees owing to third parties pursuant to enforceable and documented referral fee arrangements that were entered into prior to the Petition Date and disclosed in writing to both the Debtor and Thomassian. For the avoidance of doubt, Referral Fees shall not include any bonuses, salaries, draws, distributions, or other compensation or obligations paid or owing to current or former partners, members, attorneys, insiders, affiliates, or employees of the Debtor. 2. Allocation of Fees. a. All Fees shall be allocated as follows: To the Trustee for the benefit of the Estate, 66.7% of the Fees after deducting Costs (the “Estate Allocation”); and

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To Thomassian, 33.3% of the Fees after deducting Costs (the “Thomassian Allocation”). Any Referral Fees due on cases which have been referred to the Debtor and are transferred to Thomassian pursuant to this Agreement shall be deducted from the Thomassian Allocation, which Thomassian shall be authorized to negotiate. b. It is understood and acknowledged that the Debtor has advanced or otherwise incurred Costs in the Paramount Litigation, some of which may be claims in the Bankruptcy Case, and reimbursement for such Costs will be made to the Estate as part of the Estate Allocation. 3. Payment Of Allocated Fees. All Fees shall be initially payable to a trust fund administered by Thomassian. Within 30 days of receipt, Thomassian shall calculate the Thomassian Allocation and the Estate Allocation and notify the Trustee of the proposed allocation. If the Trustee does not object to the proposed allocation within 14 days after such notice, Thomassian shall distribute the Fees in accordance with the proposed allocation. If the Trustee does object, Thomassian shall reserve such amount as would be necessary to satisfy the Trustee’s objection, if sustained, and may distribute the remainder. The Parties agree to attempt to resolve any dispute promptly, which resolution shall be subject to approval under Bankruptcy Rule 9019. If the Parties cannot resolve their dispute within 30 days, the matter will be submitted to the Bankruptcy Court. 4. Distribution of Net Settlement Proceeds. After payment of the Estate Allocation, the Thomassian Allocation, and all Costs, Thomassian shall distribute to each Client his or her share of the settlement proceeds. 5. Common Defense Benefit Claim. Thomassian and the Estate shall separately retain 100% of any common defense/benefit fund claim owing to them, and each shall be separately responsible for all costs, expenses, and other charges associated with their respective claims. 6. Assignment Of All Other Rights / Free And Clear Assignment. Subject to the fee sharing agreement set forth above and Section 11 below, all of the Debtor’s and the Estate’s interests in the Paramount Litigation shall be assigned to Thomassian "as-is", "where-is", and without representation or warranty of any kind by the Trustee including, without limitation, any representation or warranty as to the Clients or the continued representation of the Clients by Thomassian. The assignment to Thomassian, including without limitation the Thomassian Allocation, shall be free and clear of all liens, claims, encumbrances, and other interests pursuant to Bankruptcy Code section 363(f), including but not limited to (i) any purported liens, assignments, encumbrances, or other purported transfers to litigation funders or other creditors of the Debtor,

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and (ii) any purported assignments or transfers (or agreements to a substitution of counsel or notice of association or appearance) by the Debtor. Any liens, claims, encumbrances, or other interests of the Debtor’s creditors or other entities that may assert an interest in the Debtor’s right to attorneys’ fees or other compensation relating to the Clients shall attach only to the Estate Allocation, to the same extent, priority, and validity (if any) that such liens, claims, encumbrances, or other interests had prior to consummation of this Agreement, and subject to any claims or defenses the Trustee or the Estate may have. The Thomassian Allocation shall be free and clear of such liens, claims, encumbrances, or other interests. For the avoidance of doubt, Thomassian is assuming no liabilities of the Estate, the Debtor, or any current or former partners, members, attorneys, insiders, affiliates, or employees thereof, whether under contract, tort, or otherwise. 7. Withdrawal And Substitution Of Debtor As Counsel and Lien in Favor of the Estate. The Trustee and Thomassian shall take all steps reasonably necessary to cause the Debtor to be substituted out and Thomassian to be substituted in as counsel for the Clients in the Paramount Litigation. The Trustee shall coordinate with Thomassian to provide for the smooth transition of the cases and to notify the Clients that their cases will be handled solely by Thomassian. Thomassian agrees and the Clients shall acknowledge and agree that the Estate has a lien in the Paramount Litigation for the Estate Allocation and Costs advanced or otherwise incurred by the Debtor. The lien will attach to any recovery the Clients may obtain in the Paramount Litigation, whether by arbitration award, judgment, settlement, or otherwise. The Trustee, on behalf of the Debtor and the Estate, is hereby authorized to take all steps deemed necessary by the Trustee to protect and preserve the lien. Immediately upon execution of this Agreement, the Trustee consents to Thomassian communicating to the Clients the existence and/or terms of this Agreement, provided that prior to Bankruptcy Court approval of this Agreement, any such communication note that the Agreement is subject to such approval. 8. Cooperation. The Parties shall cooperate in good faith to effectuate the terms of this Agreement, including (i) effectuating the transfer of all client and case files to Thomassian, (ii) filing of withdrawals and/or substitutions or disassociations of counsel, and (iii) preparing, executing or filing any documents necessary to acknowledge the Estate's lien as set forth in Section 6 of this Agreement. The Trustee and her counsel shall promptly direct all communications relating to the Paramount Litigation to Thomassian. Pursuant to Federal Rule of Evidence 502(d), the order approving this Agreement shall provide that no communications between the Trustee, Thomassian, and their counsel shall constitute a waiver of the Clients’ attorney-client privilege, attorney-client confidentiality of communications, or attorney work product relating to the Paramount Litigation.

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9. Notices. Any notices required hereunder shall be provided in writing by overnight delivery or email to the following: Trustee: Elissa D. Miller c/o SulmeyerKupetz 333 S Grand Ave #3400 Los Angeles, CA 90071 emiller@sulmeyerlaw.com with copies to: Lei Lei Wang Ekvall Philip E. Strok Smiley Wang-Ekvall, LLP 3200 Park Center Drive, Suite 250 Costa Mesa, CA 92626 lekvall@swelawfirm.com pstrok@swelawfirm.com Thomassian: Antony Thomassian Law Offices of Antony Thomassian 7120 Hayvenhurst Avenue, Suite 400 Van Nuys, CA 91406 Tonythomassian@gmail.com Wright: Tim D. Wright The Law Offices of Tim D. Wright 1112 W. Burbank Boulevard, Suite 302 Burbank, CA 91506 timw@timwrightlaw.com 10. Entire Agreement. This Agreement constitutes the final and entire agreement between the Parties hereto pertaining to the subject matter hereof and supersedes all prior and contemporaneous negotiations, discussions, agreements, and understandings of the Parties, whether oral or written, with respect to such subject matter.

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11. Binding on Successors. This Agreement shall be binding upon and inure to the benefit of the successors, assigns, heirs, executors, administrators, etc. of each of the Parties, including but not limited to any successor trustee and the Debtor after the case is dismissed or closed. 12. No Assignments or Delegation of Rights. Neither Party hereto has assigned or delegated any rights to any other party or person any of the rights or interests related to any claim which may be subject to the terms of this Agreement. Neither Thomassian nor the Trustee shall make any voluntary assignment, voluntary referral, or other voluntary transfer that would cause fees that would otherwise be Fees to be paid to any other counsel, entity, or person, unless such assignment, referral, or other transfer (i) by Thomassian is solely out of the Thomassian Allocation, or (ii) by the Trustee (and with Bankruptcy Court approval) is solely out of the Estate Allocation. Any such assignment or other transfer shall be subject to the reasonable consent of the other Party. 13. Jurisdiction and Venue. Any action to enforce this Agreement must be brought in the Bankruptcy Court. The Parties each hereby waive their right to trial by jury, if any, in connection with any such legal action. The Parties consent to entry of a final judgment or order by the Bankruptcy Court as a core matter. 14. Modification. This Agreement may be modified only by a writing executed by the Party to this Agreement against whom enforcement of such modification is sought. 15. Further Assurances. The Parties shall take all further acts and sign all further documents necessary or convenient to effectuate the purpose of this Agreement. Subject to the Bankruptcy Court’s approval, the order approving this Agreement shall relieve the Trustee of the obligation of signing amendments and/or substitutions for individual Clients (unless such signature is required by another court or governmental authority with relevant jurisdiction). 16. Signature and Execution. A signed copy of this Agreement shall have the same force and effect as the original. This Agreement may be executed in counterparts, each of which is deemed to be an original, but such counterparts together shall constitute one and the same instrument.

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17. Severability. In the event that any court determines that any provision of this Agreement is unenforceable, the provision at issue shall be enforced to the maximum extent permitted by law, and all other provisions shall remain in full effect. 18. Full Authority to Sign Agreement. Any individual signing on behalf of any Party hereto expressly represents and warrants to each other Party that he or she has full authority to do so and to bind such Party hereto and, in the case of the Trustee, to bind the Estate, subject only to approval of the Bankruptcy Court. 19. No Penalty for Drafting Agreement. No provisions of this Agreement shall be interpreted for or against any Party because that Party or its legal representative drafted this Agreement. 20. Parties to Bear Own Costs. Each party shall be responsible for the payment of its own costs, attorneys’ fees, and all other expenses in connection with negotiation, preparation, execution, and approval of this Agreement. Notwithstanding the foregoing, if arbitration or other legal action is necessary to enforce the terms of this Agreement, the Party declared to be the prevailing party in such arbitration or proceedings shall be entitled to its reasonable attorneys’ fees and costs incurred in enforcing this Agreement. 21. Recitals Acknowledged. The Recitals are true and correct to the best of the Parties’ knowledge, and hereby adopted by the Parties. 22. Bankruptcy Court Approval. The terms of this Agreement, and the effectiveness thereof, are subject to the approval of the Bankruptcy Court, after the Parties’ compliance with the notice and hearing requirements of the Bankruptcy Code, the Federal Rules of Bankruptcy Procedure, and the Local Bankruptcy Rules. Within five days of execution of this Agreement, the Trustee will file a motion seeking Bankruptcy Court approval of this Agreement. The Trustee shall request that the order approving this Agreement shall be effective and enforceable immediately upon entry. The form and substance of the order approving this Agreement shall include determinations by the Bankruptcy Court that (i) the Trustee has authority to enter into this Agreement and to consummate the transactions contemplated hereby, (ii) the assignment and transfer of any rights to payment or other property is free and clear of all claims, liens, encumbrances, and other interests against the Debtor, (iii) any asserted claims, liens, encumbrances, or other interests against the Debtor or its property shall attach only to the Estate Allocation, to the same extent, priority, and

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validity (if any) that such liens, claims, encumbrances, or other interests had prior to consummation of this Agreement, and subject to any claims or defenses the Trustee or the Estate may have; such claims, liens encumbrances, or other interests shall not attach to the Thomassian Allocation, (iv) Thomassian is assuming no liabilities of the Estate, the Debtor, or any partners, members,attorneys, insiders, affiliates, or employees thereof, whether under contract, tort, or otherwise,(v) the Federal Rule of Evidence 502(d) protections for attorney-client privilege and work-productset forth in Section 7 above apply, and (vi) subject to the Bankruptcy Court’s approval, the Trusteeis relieved of the obligation of signing amendments and/or substitutions for individual Clients,unless such signature is required by another court or governmental authority with relevantjurisdiction. 23. Mutual Release. a. Release of the Trustee and the Estate. Except as for the obligations and benefits set forth by and for the Parties in the Settlement Agreement (including without limitation the Thomassian Allocation), Thomassian hereby releases and forever discharges the Estate, the Trustee, and the Trustee’s attorneys and agents, each in their capacity(ies) as such (collectively, the “Trustee Released Parties”) from and against any and all claims (including, without limitation, all complaints, causes of action, lawsuits, charges, debts, liens, contracts, agreements, promises, liabilities, judgments, demands, damages, losses, emotional distress, rights, benefits, obligations, attorneys’ fees, costs, and expenses), of any kind, nature or type, whether known or unknown, liquidated or unliquidated, matured or unmatured, that Thomassian has or may have against any, some, or all of the Trustee Released Parties in connection with, arising out of or related to the Paramount Litigation. For the avoidance of doubt, the Trustee Released Parties shall include the Estate (including any released claim Thomassian may have against the Estate), but shall not include the revested Debtor (if any) or any of the Debtor’s current or former attorneys, employees, members, partners, insiders, or affiliates. b. Release by the Trustee and the Estate. Except as for the obligations and benefits set forth by and for the Parties in the Settlement Agreement (including the Estate Allocation), the Trustee on behalf of the Estate (collectively, the “Trustee Releasors”) hereby releases and forever discharges Thomassian and its attorneys and agents (the “Thomassian Released Parties”) from and against any and all claims (including, without limitation, all complaints, causes of action, lawsuits, charges, debts, liens, contracts, agreements, promises, liabilities, judgments, demands, damages, losses, emotional distress, rights, benefits, obligations, attorneys’ fees, costs and expenses), of any kind, nature or type, whether known or unknown, liquidated or unliquidated, matured or unmatured, that the Trustee Releasors have or may have against the Thomassian Released Parties in connection with, arising out of or related to the Paramount Litigation.

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c. Unknown Claims. The Parties acknowledge and assume the risk that subsequent to the execution of the Settlement Agreement, he, she, or it may discover facts or law, or may incur, suffer, or discover losses, damages, or injuries that are unknown and unanticipated at the time the Settlement Agreement was executed or became effective, which if known at such time may have materially affected his, her, or its decision to give the release contained herein. d. Section 1542 Waiver. The Trustee on behalf of the Estate, and Thomassian waive any and all rights they might otherwise possess under California Civil Code section 1542 and similar provisions of law existing in any other jurisdiction. California Civil Code Section 1542 provides as follows: A general release does not extend to claims which the creditor or releasing party does not know or suspect to exist in his or her favor at the time of executing the release and that, if known by him or her, would have materially affected his or her settlement with the debtor. IN WITNESS WHEREOF, the Parties hereto hereby execute this Settlement Agreement as of the date of final signature below. Dated: April _3_0_, 2021 Elissa D. Miller, Chapter 7 Trustee By:__________________________________ Elissa D. Miller, solely in her capacity as Chapter 7 Trustee of the Estate Dated: April ___, 2021 Law Offices of Antony Thomassian By: _________________________________ Antony Thomassian Dated: April _2_9_, 2021 The Law Offices of Tim D. Wright By: _________________________________ Tim D. Wright

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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): MOTION FOR ORDER AUTHORIZING THE RANSITION AND ASSIGNMENT OF THE ESTATE'S INTERESTS IN THE PARAMOUNT LITIGATION FREE AND LEAR OF LIENS, CLAIMS AND INTERESTS PURSUANT TO 11 U.S.C. § 363; MEMORANDUM OF POINTS AND UTHORITIES; DECLARATION OF ELISSA D. MILLER IN SUPPORT 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) pril 30, 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:  Service information continued on attached pag . SERVED BY UNITED STATES MAIL: n (date) April 30, 2021 , 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. he Honorable Barry Russell .S. Bankruptcy Court oybal Federal Building 55 E. Temple Street, Suite 1660 os Angeles, CA 90012  Service information continued on attached pag . SERVED BY PERSONAL DELIVERY, OVERNIGHT MAIL, FACSIMILE TRANSMISSION OR EMAIL (state method r each person or entity served): Pursuant to F.R.Civ.P. 5 and/or controlling LBR, on (date) ________ , I 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. April 30, 2021 Gabriela Gomez-Cruz /s/ Gabriela Gomez-Cruz Date Printed Name Signature

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1. 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     rbalabanian@edelson.comdocket@edelson.com  Michelle Balady     mb@bedfordlg.comleo@bedfordlg.com   William C Beall     will@beallandburkhardt.comcarissa@beallandburkhardt.com  Ori S Blumenfeld     Ori@MarguliesFaithLaw.com,  Helen@MarguliesFaithLaw.com;Angela@MarguliesFaithLaw.com;Vicky@MarguliesFaithLaw.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.comeric‐goldberg‐1103@ecf.pacerpro.com  Andrew Goodman     agoodman@andyglaw.comGoodman.AndrewR102467@notify.bestcase.com  Suzanne C Grandt     suzanne.grandt@calbar.ca.govjoan.randolph@calbar.ca.gov  Steven T Gubner     sgubner@bg.lawecf@bg.law   Marshall J Hogan     mhogan@swlaw.comknestuk@swlaw.com  Sheryl K Ith     sith@cookseylaw.comsith@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  Elizabeth A Lombard     elombard@zwickerpc.combknotices@zwickerpc.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.comlrobie@romalaw.com  Kenneth Miller     kmiller@pmcos.comefilings@pmcos.com  Elissa Miller (TR)     CA71@ecfcbis.com, MillerTrustee@Sulmeyerlaw.com;C124@ecfcbis.com;ccaldwell@sulmeyerlaw.com  Eric A Mitnick     MitnickLaw@aol.commitnicklaw@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  David M Reeder     david@reederlaw.comsecretary@reederlaw.com  Ronald N Richards     ron@ronaldrichards.commorani@ronaldrichards.com  Kevin C Ronk     Kevin@portilloronk.comAttorneys@portilloronk.com  William F Savino     wsavino@woodsoviatt.comlherald@woodsoviatt.com  Kenneth John Shaffer     johnshaffer@quinnemanuel.com   Richard M Steingard     , awong@steingardlaw.com   Philip E Strok     pstrok@swelawfirm.com, gcruz@swelawfirm.com;1garrett@swelawfirm.com;jchung@swelawfirm.com  Boris Treyzon     jfinnerty@actslaw.comsgonzales@actslaw.com  United States Trustee (LA)     ustpregion16.la.ecf@usdoj.gov  Eric D Winston     ericwinston@quinnemanuel.com   Christopher K.S. Wong     christopher.wong@arentfox.comyvonne.li@arentfox.com  Timothy J Yoo     tjy@lnbyb.com 

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