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Full title: Response to (related document(s): 12 Emergency motion Emergency Motion For Appointment Of Interim Trustee Pursuant to 11 USC 303(g); Memorandum of Points And Authorities; Declarations of Paul Cody and Boris Treyzon, Esq. filed Separately With Proof of Service. LBR 9075-1(b) filed by Petitioning Creditor Jill O'Callahan, Petitioning Creditor Robert M. Keese, Petitioning Creditor John Abassian, Petitioning Creditor Erika Saldana, Petitioning Creditor Virginia Antonio, Petitioning Creditor Kimberly Archie) Filed by Creditor Frantz Law Group, APLC (Winston, Eric) (Entered: 01/04/2021)

Document posted on Jan 3, 2021 in the bankruptcy, 7 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

Paul Cody (the “Cody Declaration”) of litigation funder California Attorne15 Lending II (“CAL II”), and (ii) attorney Boris Treyzon (the “Treyzon Declaration”) of Abir Cohe16 Treyzon Salo, LLP (“Treyzon Firm”).9 The Treyzon Declaration also fails to mention that in the Southern California Gas Lea10 Litigation, GK already had co-counsel for the 8,000 clients – Frantz – and that for years Frantz ha11 been doing the work needed to protect the interests of the clients.One, that Frantz, consistent with it27 ethical obligations under California law, may advise its existing clients in the Southern California Ga 1 order and the commencement of this involuntary case, that the clients have the option to terminat2 their relationships with GK, and that they also have the option to choose to proceed only with Frant3 or with other counsel associated with Frantz in the matter.Two, that Frantz, also consistent wit 4 California law, may confer with any Southern California Gas Litigation clients who wish to terminat5 their engagements with GK.rastz@hrhlaw.com ichard W Esterkin on behalf of Interested Party Courtesy NEF chard.esterkin@morganlewis.com ric D Goldberg on behalf of Creditor Stillwell Madison, LLC ric.goldberg@dlapiper.com, eric-goldberg-1103@ecf.pacerpro.com ndrew Goodman on behalf of Petitioning Creditor Erika Saldana goodman@andyglaw.com

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Document Contents

1 QUINN EMANUEL URQUHART & SULLIVAN, LLP Kenneth Chiate (Cal. Bar No. 39554) 2 kenchiate@quinnemanuel.com K. John Shaffer (Cal. Bar No. 153729) 3 johnshaffer@quinnemanuel.com Eric Winston (Cal. Bar No. 202407) 4 ericwinston@quinnemanuel.com Razmig Izakelian (Cal. Bar No. 292137) 5 razmigizakelian@quinnemanuel.com 865 South Figueroa Street, 10th Floor 6 Los Angeles, California 90017-2543 Telephone: (213) 443-3000 7 Facsimile: (213) 443-3100 8 Attorneys for Frantz Law Group, APLC 9 UNITED STATES BANKRUPTCY COURT 10 CENTRAL DISTRICT OF CALIFORNIA 11 LOS ANGELES DIVISION 12 In re Chapter 7 13 GIRARDI KEESE, dba, THOMAS VINCENT Case No. 2:20-bk-21022-BR 14 GIRARDI LIMITED RESPONSE AND NON- 15 Debtor. OPPOSITION TO MOTION OF PETITIONING CREDITORS FOR 16 APPOINTMENT OF INTERIM TRUSTEE PURSUANT TO 11 U.S.C. § 303(g) 17 Hearing Date: January 5, 2021 Time: 2:00 p.m. 18 Location: Courtroom 1575 255 E. Temple Street 19 Los Angeles, CA. 90012 20 21 22 23 24 25 26 27

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1 Frantz Law Group, APLC (“Frantz”) is both a creditor of Girardi Keese (“GK”) and co2 counsel with GK in representing over 8,000 victims asserting claims arising out of the 2015 blowo3 and subsequent months-long gas leak in Porter Ranch, California (the “Southern California Gas Lea 4 Litigation”). Frantz files this limited response to the Motion of Petitioning Creditors for Appointme5 of Interim Trustee Pursuant to 11 U.S.C. § 303(g) (the “Interim Trustee Motion”), filed on Decembe6 24, 2020, by Robert M. Keese, Jill O’Callahan (as successor in interest to James O’Callahan), Erik 7 Saldana, Virginia Antonio, and Kimberly Archie (collectively, the “Petitioning Creditors”) [ECF N8 12]. 9 RESPONSE 10 Frantz does not oppose the appointment of an interim trustee pursuant to 11 U.S.C. § 303(g11 Indeed, an interim trustee likely is necessary to provide stability given what appears to be a12 abandonment by GK of its obligations as counsel in the Southern California Gas Leak Litigatio13 However, Frantz is concerned with certain statements made in the Interim Trustee Motion and in th14 declarations from (i) Paul Cody (the “Cody Declaration”) of litigation funder California Attorne15 Lending II (“CAL II”), and (ii) attorney Boris Treyzon (the “Treyzon Declaration”) of Abir Cohe16 Treyzon Salo, LLP (“Treyzon Firm”). It is surprising that a purportedly secured litigation funder an17 a law firm that should have no involvement in the Southern California Gas Leak Litigation hav18 submitted declarations in support of the Interim Trustee Motion and specifically mention the Souther19 California Gas Leak Litigation. 20 According to the Cody Declaration, CAL II is a litigation funder that purportedly lent mone21 to GK and claims a security interest in substantially all of GK’s assets. Among the assets listed in th22 Cody Declaration are GK’s interests in the Southern California Gas Leak Litigation. Indeed, the Cod23 Declaration identifies the litigation as one in which GK represents over 8,000 clients and is “owe24 significant sums.” Cody Declaration ¶ 32. What the Cody Declaration and the Interim Truste25 Motion do not mention is that GK is co-counsel with Frantz in the Southern California Gas Lea26 Litigation, and that GK has failed to comply with its obligations in that litigation. Moreover, G27 never disclosed to Frantz (and never obtained the consent of Frantz or any of the 8,000 clients) th

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1 The Cody Declaration also discloses that prior to the Petition Date, CAL II, GK and Treyzo 2 Firm entered into an agreement for the transfer of responsibility for certain cases from GK to th 3 Treyzon Firm. Cody Declaration ¶ 38. The Treyzon Declaration indicates the agreement was entere4 into in October 2020. Treyzon Declaration ¶ 4. The Treyzon Declaration further indicates that th 5 Treyzon Firm has already hired several associates and staff from GK, and it is clear that the Treyzo 6 Firm is angling to take over GK’s cases. See Treyzon Declaration ¶ 9. The Treyzon Declaratio7 further states – without any support – that if other attorneys are substituted in (instead of the Treyzo 8 Firm), GK’s bankruptcy estate somehow purportedly will be damaged. See id. 9 The Treyzon Declaration also fails to mention that in the Southern California Gas Lea10 Litigation, GK already had co-counsel for the 8,000 clients – Frantz – and that for years Frantz ha11 been doing the work needed to protect the interests of the clients. The Treyzon Declaration also fail12 to disclose that the Treyzon Firm has already (improperly) filed notices of association in the Souther13 California Gas Leak Litigation. Frantz is aware of at least 12 notices of association filed in Decembe14 2020. Neither GK nor the Treyzon Firm mentioned, much less sought the consent of, Frantz or (to th15 best of Frantz’s knowledge) the respective clients before these notices of association were filed. G16 cannot simply associate in whatever counsel it desires in the Southern California Gas Leak Litigatio17 its co-counsel has been Frantz, and Frantz did not (and does not) consent to such associations. Frant18 believes that these improper notices have created confusion for clients in the Southern California Ga19 Leak Litigation. 20 Frantz and undersigned counsel have already contacted Treyzon regarding the imprope21 notices of association and sought confirmation from Mr. Treyzon that the Treyzon Firm woul22 withdraw the associations. As of the date of this response, the Treyzon Firm has not responded. 23 On December 31, 2020, Frantz filed its Motion for Relief from the Automatic Stay Under 124 U.S.C. § 362 (the “Stay Relief Motion”), requesting confirmation that the automatic stay under 125 U.S.C. § 362(a) does not apply, or if the automatic stay is applicable, that relief from the automati26 stay be granted pursuant to 11 U.S.C. § 362(d), for two matters. One, that Frantz, consistent with it27 ethical obligations under California law, may advise its existing clients in the Southern California Ga

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1 order and the commencement of this involuntary case, that the clients have the option to terminat2 their relationships with GK, and that they also have the option to choose to proceed only with Frant3 or with other counsel associated with Frantz in the matter. Two, that Frantz, also consistent wit 4 California law, may confer with any Southern California Gas Litigation clients who wish to terminat5 their engagements with GK. 6 This Court has set a hearing on the Stay Relief Motion for January 26, 2021. To the extent th7 this Court grants the Interim Trustee Motion, Frantz looks forward to discussing the Stay Relie 8 Motion with the interim trustee. But, regardless of whether an interim trustee is appointed, at least fo9 the Southern California Gas Leak Litigation, this Court should have a complete record. 10 11 DATED: January 4, 2021 Respectfully submitted, 12 QUINN EMANUEL URQUHART & SULLIVAN, LL 13 By: /s/ Eric Winston Kenneth Chiate 14 John Shaffer Eric Winston 15 Razmig Izakelian 16 Attorneys for Frantz Law Group, APLC 17 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: 65 S. Figueroa Street, 10th Floor, Los Angeles, CA 90017 true and correct copy of the foregoing document entitled: Limited Response and Non-Opposition to Motion of Petitioninreditors for Appointment of Interim Trustee Pursuant to 11 U.S.C. § 303(g) ill be served or was served (a) on the judge in chambers in the form and manner required by LBR 5005-2(d); and (b) in e 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 January , 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 page . SERVED BY UNITED STATES MAIL: n January 4, 2021, I served the following persons and/or entities at the last known addresses in this bankruptcy case ordversary proceeding by placing a true and correct copy thereof in a sealed envelope in the United States mail, first classostage prepaid, and addressed as follows. Listing the judge here constitutes a declaration that mailing to the judge will e completed no later than 24 hours after the document is filed. homas Girardi, 1126 Wilshire Boulevard Los Angeles, CA 90017 irardi Keese, 1126 Wilshire Boulevard Los Angeles, CA 90017 eonard Pena, Esq., PENA & SOMA, APC, 402 S. Marengo Avenue, Suite B, Pasadena, CA 91101 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 servede following persons and/or entities by personal delivery, overnight mail service, or (for those who consented in writing tuch service method), by facsimile transmission and/or email as follows. Listing the judge here constitutes a declaration at personal delivery on, or overnight mail to, the judge will be completed no later than 24 hours after the document is led. Service information continued on attached page declare under penalty of perjury under the laws of the United States that the foregoing is true and correct. 1/4/2021 Razmig Izakelian /s/ Razmig Izakelian Date Printed Name Signature

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. TO BE SERVED BY THE COURT VIA NOTICE OF ELECTRONIC FILING (NEF): ennifer Witherell Crastz on behalf of Creditor Wells Fargo Vendor Financial Services, Inc. rastz@hrhlaw.com ichard W Esterkin on behalf of Interested Party Courtesy NEF chard.esterkin@morganlewis.com ric D Goldberg on behalf of Creditor Stillwell Madison, LLC ric.goldberg@dlapiper.com, eric-goldberg-1103@ecf.pacerpro.com ndrew Goodman on behalf of Petitioning Creditor Erika Saldana goodman@andyglaw.com ndrew Goodman on behalf of Petitioning Creditor Jill O'Callahan goodman@andyglaw.com ndrew Goodman on behalf of Petitioning Creditor John Abassian goodman@andyglaw.com ndrew Goodman on behalf of Petitioning Creditor Kimberly Archie goodman@andyglaw.com ndrew Goodman on behalf of Petitioning Creditor Robert M. Keese goodman@andyglaw.com ndrew Goodman on behalf of Petitioning Creditor Virginia Antonio goodman@andyglaw.com teven T Gubner on behalf of Interested Party Courtesy NEF gubner@bg.law, ecf@bg.law arshall J Hogan on behalf of Creditor California Attorney Lending II, Inc. hogan@swlaw.com, knestuk@swlaw.com ewis R Landau on behalf of Interested Party Courtesy NEF ew@Landaunet.com dith R Matthai on behalf of Interested Party Courtesy NEF matthai@romalaw.com cott H Olson on behalf of Creditor KCC Class Action Services, LLC olson@vedderprice.com, scott-olson- 161@ecf.pacerpro.com,ecfsfdocket@vedderprice.com,nortega@vedderprice.com onald N Richards on behalf of Interested Party Courtesy NEF n@ronaldrichards.com, morani@ronaldrichards.com,justin@ronaldrichards.com

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nited States Trustee (LA) stpregion16.la.ecf@usdoj.gov ric D Winston on behalf of Creditor Frantz Law Group, APLC ricwinston@quinnemanuel.com imothy J Yoo on behalf of Interested Party Courtesy NEF y@lnbyb.com

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