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Full title: Stipulation By Elissa Miller (TR) and Gabriel and Maria Abikzer by and through their attorneys to Authorize the Release of Disputed Costs to Clients with Proof of Service Filed by Trustee Elissa Miller (TR) (Ekvall, Lei Lei) (Entered: 05/12/2021)

Document posted on May 11, 2021 in the bankruptcy, 6 pages and 0 tables.

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el 17 E. Pursuant to the Disbursement Stipulation, the Clients and the Trustee T 18 agreed that $229,663.00 of the first installment would be reserved and held in trust by th19 Trustee pending resolution of a dispute between the Clients and the Debtor regarding th20 reimbursement of certain costs and advances (the "Disputed Costs").The Trustee is authorized to remit the Disputed Costs totaling $229,663.007 to the Clients, in care of Rafey Balabanian, Edelson PC, 150 California Street, 18th Floor, 8 San Francisco, California 94111.The Trustee is authorized to remit the Disputed Costs totaling $229,663.007 to the Clients, in care of Rafey Balabanian, Edelson PC, 150 California Street, 18th Floor, 8 San Francisco, California 94111. true and correct copy of the foregoing document entitled (specify): STIPULATION AUTHORIZING THE RELEASE OF ISPUTED COSTS TO CLIENTS will be served or was served (a) on the judge in chambers in the form and manner required bBR 5005-2(d); and (b) in the manner stated below: .TOP. 5 and/or controlling LBR, on (date) _____ , I served the llowing persons and/or entities by personal delivery, overnight mail service, or (for those who consented in writing to uch service method), by facsimile transmission and/or email as follows.

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1 SMILEY WANG-EKVALL, LLP Lei Lei Wang Ekvall, State Bar No. 163047 2 lekvall@swelawfirm.com Philip E. Strok, State Bar No. 169296 3 pstrok@swelawfirm.com Timothy W. Evanston, State Bar No. 319342 4 tevanston@swelawfirm.com 3200 Park Center Drive, Suite 250 5 Costa Mesa, California 92626 Telephone: 714 445-1000 6 Facsimile: 714 445-1002 7 Attorneys for Elissa D. Miller, Chapter 7 Trustee 8 9 UNITED STATES BANKRUPTCY COURT 10 CENTRAL DISTRICT OF CALIFORNIA 11 LOS ANGELES DIVISION 2 0 0 92626 4 445-1 1123 I GnI RreA RDI KEESE, CChaasep tNero 7. 2:20-bk-21022-BR ornia ax 71 a, Calif00 • F 14 SRTEILPEUALSAET IOOFN D AISUPTUHTOERDIZ CINOGS TTSH ET O s0 15 Debtor. CLIENTS e1 M5- a 4 ost4 4 16 [No Hearing Required] C71 el 17 T 18 TO THE HONORABLE BARRY RUSSELL, UNITED STATES BANKRUPTCY JUDGE19 Elissa D. Miller, the chapter 7 trustee of the bankruptcy estate of Girardi Keese 20 (the "Trustee"), by and through her attorneys, and Gabriel and Maria Abikzer (the 21 "Clients"), through their attorneys, enter into this Stipulation Authorizing the Release of 22 Disputed Costs to Clients (the "Stipulation") as follows: 23 24 RECITALS 25 A. On December 18, 2020 (the "Petition Date"), an involuntary chapter 7 26 bankruptcy petition ("Petition") was filed against Girardi Keese ("Debtor"). As of the filing27 of the involuntary petition, Debtor was counsel of record in a significant number of

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1 B. The petitioning creditors moved for the appointment of an interim trustee 2 which was granted by the Court by order entered January 5, 2021. The Trustee was 3 appointed as the interim chapter 7 trustee on January 6, 2021. The order for relief was 4 entered January 13, 2021 and, the same date, the Trustee was reappointed and has 5 been serving in that capacity since. 6 C. On May 18, 2018, the Debtor commenced an action in the Los Angeles 7 County Superior Court, Case No. BC706830, on behalf of the Clients against the City of 8 Los Angeles and Jeffrey Joel (the "Superior Court Case"). The Superior Court Case wa9 subsequently settled in favor of the Clients for $23,000,000.00 (the "Settlement Amount"10 The Settlement Amount is being paid in two installments, with the first installment alread11 having been paid and the second installment due in July of 2021. 2 0 0 92626 4 445-1 1123 AuthoriDzi.n g SeOtntle Jmaneunat rPya 1y,m 2e0n2t1 t,o t hCeli eTnrut astnede Paanydm theen tC olife Enxtsp eennsteerse dto i nthtoe aE sSttaipteu lation ornia ax 71 a, Calif00 • F 14 [Docket No. 116] (the "Distribution Stipulation"), which set forth the allocation of the s0 15 installment payments between the Clients and the Debtor. The Distribution Stipulation e1 M5- a 4 ost4 4 16 was approved by order entered January 26, 2021 [Docket No. 124]. C1 7 el 17 E. Pursuant to the Disbursement Stipulation, the Clients and the Trustee T 18 agreed that $229,663.00 of the first installment would be reserved and held in trust by th19 Trustee pending resolution of a dispute between the Clients and the Debtor regarding th20 reimbursement of certain costs and advances (the "Disputed Costs"). The controversy 21 over the Disputed Costs involves certain loans that were secured by the Debtor from 22 Signal Funding to fund the litigation (the "Litigation Loan"). The Debtor and the Clients 23 agreed to share the obligation equally, including interest charges. 24 F. The Clients have since repaid the Litigation Loan in full, and the Disputed 25 Costs represent the Debtor's share of its obligation on the Litigation Loan. 26 27

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1 STIPULATION 2 In light of the foregoing, the parties stipulate as follows: 3 1. The Trustee, on behalf of the Debtor's estate, and the Clients, through their4 attorneys of record, confirm that the Clients are entitled to the distribution of the Disputed 5 Costs; and 6 2. The Trustee is authorized to remit the Disputed Costs totaling $229,663.007 to the Clients, in care of Rafey Balabanian, Edelson PC, 150 California Street, 18th Floor, 8 San Francisco, California 94111. 9 IT IS SO STIPULATED. 10 11 2 0 0 92626 4 445-1 1123 DATED: May __1_1, 2021 CELhIaSpSteAr D7 .T MruIsLtLeEeR o,f sthoele lEy sitna thee r capacity as ornia ax 71 sa, Calif000 • F 1145 D ATED: May ___, 2021 EDELSON PC e1 M5- a 4 ost4 4 16 By: C1 el 7 17 RAFEY S. BALABANIAN T Attorneys for Gabriel and Maria Abikzer 18 19 20 21 22 23 24 25 26 27

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1 STIPULATION 2 In light of the foregoing, the parties stipulate as follows: 3 1. The Trustee, on behalf of the Debtor's estate, and the Clients, through their4 attorneys of record, confirm that the Clients are entitled to the distribution of the Disputed 5 Costs; and 6 2. The Trustee is authorized to remit the Disputed Costs totaling $229,663.007 to the Clients, in care of Rafey Balabanian, Edelson PC, 150 California Street, 18th Floor, 8 San Francisco, California 94111. 9 IT IS SO STIPULATED. 10 11 2 0 0 92626 4 445-1 1123 DATED: May ___, 2021 CELhIaSpSteAr D7 .T MruIsLtLeEeR o,f sthoele lEys itna thee r capacity as ornia ax 71 sa, Calif000 • F 1145 D ATED: May (cid:2)_(cid:2)_(cid:1)_, 2021 EDELSON PC e1 M5- a 4 ost4 4 16 By: C1 el 7 17 RAFEY S. BALABANIAN T Attorneys for Gabriel and Maria Abikzer 18 19 20 21 22 23 24 25 26 27

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PROOF OF SERVICE OF DOCUMENT am over the age of 18 and not a party to this bankruptcy case or adversary proceeding. My business address is 3200 ark Center Drive, Suite 250, Costa Mesa, CA 92626. true and correct copy of the foregoing document entitled (specify): STIPULATION AUTHORIZING THE RELEASE OF ISPUTED COSTS TO CLIENTS will be served or was served (a) on the judge in chambers in the form and manner required bBR 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 Generalrders and LBR, the foregoing document will be served by the court via NEF and hyperlink to the document. On (date)ay 12, 2021 I checked the CM/ECF docket for this bankruptcy case or adversary proceeding and determined that thellowing 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) May 12, 2021, I served the following persons and/or entities at the last known addresses in this bankruptcyase 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 thedge will be completed no later than 24 hours after the document is filed. The Honorable Barry Russell U.S. Bankruptcy Court Roybal Federal Building 255 E. Temple Street, Suite 1660 Los 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. May 12, 2021 Gabriela Gomez-Cruz /s/ Gabriela Gomez-Cruz Date PrintedName Signature

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ADDITIONAL SERVICE INFORMATION (if needed): . SERVED BY THE COURT VIA NOTICE OF ELECTRONIC FILING (“NEF”) yra E Andrassy kandrassy@swelawfirm.com, lgarrett@swelawfirm.com;gcruz@swelawfirm.com;jchung@swelawfirm.com afey Balabanian rbalabanian@edelson.com, docket@edelson.com ichelle Balady mb@bedfordlg.com, leo@bedfordlg.com illiam C Beall will@beallandburkhardt.com, carissa@beallandburkhardt.com ri S Blumenfeld Ori@MarguliesFaithLaw.com, elen@MarguliesFaithLaw.com;Angela@MarguliesFaithLaw.com;Vicky@MarguliesFaithLaw.com ichard D Buckley richard.buckley@arentfox.com arie E Christiansen mchristiansen@vedderprice.com, ecfladocket@vedderprice.com,marie-christiansen-166@ecf.pacerpro.com ennifer Witherell Crastz jcrastz@hrhlaw.com shleigh A Danker Ashleigh.danker@dinsmore.com, SDCMLFiles@DINSMORE.COM;Katrice.ortiz@dinsmore.com lifford S Davidson csdavidson@swlaw.com, jlanglois@swlaw.com;cliff-davidson-7586@ecf.pacerpro.com ei Lei Wang Ekvall lekvall@swelawfirm.com, lgarrett@swelawfirm.com;gcruz@swelawfirm.com;jchung@swelawfirm.com ichard W Esterkin richard.esterkin@morganlewis.com imothy W Evanston tevanston@swelawfirm.com, gcruz@swelawfirm.com;lgarrett@swelawfirm.com;jchung@swelawfirm.com eremy Faith Jeremy@MarguliesFaithlaw.com, elen@MarguliesFaithlaw.com;Angela@MarguliesFaithlaw.com;Vicky@MarguliesFaithlaw.com ames J Finsten , jimfinsten@hotmail.com lan W Forsley alan.forsley@flpllp.com, awf@fkllawfirm.com,awf@fl-lawyers.net,addy.flores@flpllp.com ric D Goldberg eric.goldberg@dlapiper.com, eric-goldberg-1103@ecf.pacerpro.com ndrew Goodman agoodman@andyglaw.com, Goodman.AndrewR102467@notify.bestcase.com uzanne C Grandt suzanne.grandt@calbar.ca.gov, joan.randolph@calbar.ca.gov teven T Gubner sgubner@bg.law, ecf@bg.law arshall J Hogan mhogan@swlaw.com, knestuk@swlaw.com heryl K Ith sith@cookseylaw.com, sith@ecf.courtdrive.com azmig Izakelian razmigizakelian@quinnemanuel.com ewis R Landau Lew@Landaunet.com aniel A Lev dlev@sulmeyerlaw.com, ccaldwell@sulmeyerlaw.com;dlev@ecf.inforuptcy.com lizabeth A Lombard elombard@zwickerpc.com, bknotices@zwickerpc.com raig G Margulies Craig@MarguliesFaithlaw.com, icky@MarguliesFaithlaw.com;Helen@MarguliesFaithlaw.com;Angela@MarguliesFaithlaw.com eter J Mastan peter.mastan@dinsmore.com, SDCMLFiles@dinsmore.com;Katrice.ortiz@dinsmore.com dith R. Matthai ematthai@romalaw.com, lrobie@romalaw.com enneth Miller kmiller@pmcos.com, efilings@pmcos.com lissa Miller (TR) CA71@ecfcbis.com, MillerTrustee@Sulmeyerlaw.com;C124@ecfcbis.com;ccaldwell@sulmeyerlaw.com ric A Mitnick MitnickLaw@aol.com, mitnicklaw@gmail.com cott H Olson solson@vedderprice.com, scott-olson- 161@ecf.pacerpro.com,ecfsfdocket@vedderprice.com,nortega@vedderprice.com eonard Pena lpena@penalaw.com, penasomaecf@gmail.com;penalr72746@notify.bestcase.com ichael J Quinn mquinn@vedderprice.com, ecfladocket@vedderprice.com,michael-quinn-2870@ecf.pacerpro.com avid M Reeder david@reederlaw.com, secretary@reederlaw.com onald N Richards ron@ronaldrichards.com, morani@ronaldrichards.com evin C Ronk Kevin@portilloronk.com, Attorneys@portilloronk.com illiam F Savino wsavino@woodsoviatt.com, lherald@woodsoviatt.com enneth John Shaffer johnshaffer@quinnemanuel.com ichard M Steingard , awong@steingardlaw.com hilip E Strok pstrok@swelawfirm.com, gcruz@swelawfirm.com;1garrett@swelawfirm.com;jchung@swelawfirm.com oris Treyzon jfinnerty@actslaw.com, sgonzales@actslaw.com United States Trustee (LA) ustpregion16.la.ecf@usdoj.gov ric D Winston ericwinston@quinnemanuel.com hristopher K.S. Wong christopher.wong@arentfox.com, yvonne.li@arentfox.com imothy J Yoo tjy@lnbyb.com

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