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Full title: Reply to (related document(s): 333 Opposition filed by Interested Party Erika Girardi) Reply to Opposition of Erika Girardi to Chapter 7 Trustee's Application to Employ the Law Offices of Ronald Richards & Associates, A.P.C., as Special Litigation Counsel with Proof of Service Filed by Trustee Elissa Miller (TR) (Ekvall, Lei Lei) (Entered: 06/01/2021)

Document posted on May 31, 2021 in the bankruptcy, 45 pages and 0 tables.

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: 1668 255 E. Temple Street 19 Los Angeles, California 90012 20 21 22 TO THE HONORABLE BARRY RUSSELL, UNITED STATES BANKRUPTCY JUDGE: 23 Elissa D. Miller, the chapter 7 trustee (the "Trustee") for the bankruptcy estate (th24 "Estate") of Girardi Keese (the "Debtor"), submits this reply to the Opposition [Docket No25 333] filed by Erika Girardi ("Erika") to the Chapter 7 Trustee's Application to Employ the 26 Law Offices of Ronald Richards & Associates, A.P.C., as Special Litigation Counsel 27The 26 Order also stated that "[c]ounsel for Plaintiffs also reaffirmed that Plaintiffs would not be 27 proceeding on any fraudulent transfer claims, including but not limited to the 6th Cause o 1 Action in the First Amended Complaint, and that fraudulent transfer claims belong to the 2 bankruptcy estate of Girardi Keese."Here, Erika has not filed a proof of claim, or highlighted any pecuniary interests that C 1 7 el   T 17 would be adversely affected by an order granting the Trustee's application to employ the18 Richards Firm.The Fraudulent Transfer Claims Will Only Be Pursued by the Trustee C 1 7 el   T 17 and Do Not Create an Actual Conflict or an Adverse Interest 18 Erika argues at length that because the Richards Firm represents the Plaintiffs 19 (who previously asserted fraudulent transfer claims), there is an actual conflict because 20 fraudulent transfer claims belong to the Estate.The voluntary dismissal of the Debtor shall have no effect on the Plaintiffs' 9 right to enforce any alleged claim they purport to hold against the Debtor by filing a proof 10 of claim in the Debtor's bankruptcy case or the rights of the Trustee to dispute or object to P 11 any such claim filed; and L 2 MILEY WANG-EKVALL, L 3200 Park Center Drive, Suite 250 Costa Mesa, California 92626

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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 In re Case No. 2:20-bk-21022-BR 2  00 12 92626  4 445‐1 13 G IRARDI KEESE, C hapter 7 alifornia  •  Fax 71 14 Debtor. RGEIRPALRYD TI OT OO PCPHOASPITTEIORN 7 O TFR UERSTIKEAE 'S a, C 00   APPLICATION TO EMPLOY THE LAW es 10 15 OFFICES OF RONALD RICHARDS & osta M 4 445‐ 16 ALISTSIGOACTIAIOTNE SC,O AU.PN.SCE.,L A S SPECIAL C 1 7 el   T 17 Date: June 8, 2021 Time: 10:00 a.m. 18 Ctrm.: 1668 255 E. Temple Street 19 Los Angeles, California 90012 20 21 22 TO THE HONORABLE BARRY RUSSELL, UNITED STATES BANKRUPTCY JUDGE: 23 Elissa D. Miller, the chapter 7 trustee (the "Trustee") for the bankruptcy estate (th24 "Estate") of Girardi Keese (the "Debtor"), submits this reply to the Opposition [Docket No25 333] filed by Erika Girardi ("Erika") to the Chapter 7 Trustee's Application to Employ the 26 Law Offices of Ronald Richards & Associates, A.P.C., as Special Litigation Counsel 27 [Docket No. 318] (the "Application").

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1 I. INTRODUCTION 2 The Court should overrule the Opposition and grant the Trustee's Application to 3 employ the Law Offices of Ronald Richards & Associates, A.P.C. (the "Richards Firm"), 4 as special litigation counsel. The Application is non-controversial and straightforward; th 5 Trustee seeks to employ the Richards Firm to investigate and pursue possible fraudulent6 transfer claims against Erika. The Trustee's application is fully transparent and makes 7 clear that the Richards Firm represents certain creditors of the Debtor. 8 Preliminarily, the Opposition is fatally defective and should not even be considere9 as Erika does not have standing to oppose the Application. She makes no attempt to 10 explain why she should be heard on the Application. For this reason alone, the 11 Opposition should be overruled. 2  00 12 As to the Application itself, Erika asserts two bases for its denial. Both fail. First, 92626  4 445‐1 13 the creditors represented by the Richards Firm are not pursuing fraudulent transfer alifornia  •  Fax 71 14 claims that belong to the Estate. More specifically, the Trustee and the creditors a, C 00   es 10 15 represented by the Richards Firm have agreed that only the Estate will pursue fraudulenM 5‐ osta  4 44 16 transfer claims. This agreement, stated on the record and recognized by this Court's C 1 7 el   T 17 order, eliminates any actual conflict of interest. Second, the Trustee seeks to employ th18 Richards Firm as special litigation counsel under section 327(e). Employing the Richard19 Firm under section 327(e) limits the inquiry as to whether the Richards Firm holds an 20 adverse interest. Erika's disregard for the limitation in section 327(e)—namely, her failur21 to argue how a possible claim objection presents an interest adverse to the Estate in an 22 unrelated potential fraudulent transfer action—warrants denial. There is no actual 23 conflict, and the Richards Firm does not hold an adverse interest with respect to the 24 matter for which they are employed. 25 Erika's request for a "gag order" is also not properly before the Court. Moreover, i26 is irrelevant to the Application and should be summarily overruled. Accordingly, the Cou27 should grant the Application.

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1 II. BACKGROUND 2 A. The Sheldon Litigation 3 On December 9, 2020, the Law Offices of Philip R. Sheldon, APC, filed a 4 complaint against Thomas V. Girardi, the Debtor, and DOES 1-100 in the Los Angeles 5 Superior Court, commencing case number 20STCV47160 (the "Sheldon Litigation"). On 6 December 16, 2020, the Law Offices of Philip R. Sheldon, APC, Philip R. Sheldon, Law 7 of Robert P. Finn, and Robert P. Finn (collectively, the "Plaintiffs") filed a first amended 8 complaint (the "First Amended Complaint") in the Sheldon Litigation. In the First 9 Amended Complaint, the Plaintiffs assert a cause of action to recover fraudulent 10 transfers. 11 On January 29, 2021, the Richards Firm filed a Notice of Association of Counsel 2  00 12 on behalf of the Plaintiffs. As disclosed in the Trustee's Application, the Richards Firm is92626  4 445‐1 13 currently counsel for the Plaintiffs who claim to be creditors of the Estate. alifornia  •  Fax 71 14 B. The Removal and Remand of the Sheldon Litigation a, C 00   es 10 15 On March 5, 2021, David Lira filed a notice of removal to remove the Sheldon M 5‐ osta  4 44 16 Litigation to this Court. Subsequently, the Sheldon Litigation was assigned adversary C 1 7 el   T 17 case number 2:21-ap-01039-BR. On March 9, 2021, the Court entered an order setting 18 status conference and ordering the parties to show cause why the Court should not 19 abstain and remand the Sheldon Litigation. The Court also set a status conference on 20 the notice of removal for May 11, 2021. 21 On March 25, 2021, the Trustee entered into a Stipulation for Voluntary Dismissal22 of Debtor Pursuant to Federal Rule of Civil Procedure 41(a) [Docket No. 15] (the 23 "Stipulation"). See Stipulation, Ex. "1."1 Under the Stipulation, the Trustee and the 24 Plaintiffs agreed to a dismissal of the Debtor without prejudice. The parties further 25 stipulated that the dismissal of the Debtor would have no effect on the Plaintiffs' right to 26 27 1 Pursuant to Federal Rule of Evidence 201, the Trustee requests that the Court take judicial notice of the Stipulation, attached as Ex. "1," the Order attached as Ex. "2," the Statement attached as Ex. "3," and the Remand Order attached as Ex. "5."

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1 enforce any alleged claim they purport to hold against the Debtor by filing a proof of clai2 in the Debtor's case. The parties also agreed that the dismissal would not affect the 3 Trustee's rights to dispute or object to any such claim. On March 26, 2021, the Court 4 entered an order approving the Stipulation [Docket No. 16]. See Order, Ex. "2." 5 On April 16, 2021, the Plaintiffs filed a Motion for Remand [Docket No. 20] (the 6 "Remand Motion") in response to Lira's notice of removal. A hearing on the Remand 7 Motion was scheduled for May 11, 2021. In response to the Remand Motion, the Truste8 filed the Chapter 7 Trustee's Statement of Non-Opposition to Plaintiffs' Motion for 9 Remand (the "Statement") [Docket No. 26] on April 27, 2021. In the Statement, the 10 Trustee informed the Court that based on the Plaintiffs' agreement "that they would not 11 pursue the fraudulent transfer claims," the Trustee did not oppose the Remand Motion. 2  00 12 See Statement, Ex. "3." 92626  4 445‐1 13 At the hearing on the Remand Motion, counsel for the Plaintiffs confirmed that thealifornia  •  Fax 71 14 fraudulent transfer claims asserted by the Plaintiffs in the Sheldon Litigation belonged to a, C 00   es 10 15 the Estate in the following exchange: M 5‐ osta  4 44 16 Mr. Evanston [Trustee's Counsel]: …Our only request is that Plaintiffs' C 1 7 el   counsel confirm on the record that the fraudulent transfer claims will be T 17 pursued by the estate. 18 Mr. Richards: That's correct, your Honor. We are not pursuing any of the fraudulent transfer claims. Those are just going to be pursued by the 19 estate only. 20 See Transcript of May 11, 2021 Remand Motion Hearing at 12:17-23, Ex. "4." Following21 this exchange, counsel for the Plaintiffs twice confirmed that the Plaintiffs would not 22 pursue the fraudulent transfer claims. See id. at 13:12-14 ("We're not going to pursue th23 fraudulent conveyance claims that are pled in the complaint. Those belong to the 24 estate…") and id. at 13:21-22 ("We're not pursuing the fraudulent conveyance claims."). 25 On May 13, 2021, the Court entered an order granting the Remand Motion. The 26 Order also stated that "[c]ounsel for Plaintiffs also reaffirmed that Plaintiffs would not be 27 proceeding on any fraudulent transfer claims, including but not limited to the 6th Cause o

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1 Action in the First Amended Complaint, and that fraudulent transfer claims belong to the 2 bankruptcy estate of Girardi Keese." See Remand Order, Ex. "5." 3 4 III. MEMORANDUM OF POINTS AND AUTHORITIES 5 Section 327(c) provides that "a person is not disqualified for employment under 6 this section solely because of such person's employment by or representation of a 7 creditor, unless there is an objection by another creditor or the United States trustee, in 8 which case the court shall disapprove such employment if there is an actual conflict of 9 interest." See 11 U.S.C. § 327(c). Although Section 327(c) "applies generally to all 10 employment under § 327…clearly the 'actual conflict of interest' that it references must b11 analyzed in the narrower context of § 327(e)." See In re Polaroid Corp, 424 B.R. at 453 2  00 12 citing Stoumbos, 988 F.2d at 964. "'[A] conflict of interest is actual and warrants 92626  4 445‐1 13 disqualification under § 327(c) if there is active competition between two interests, in alifornia  •  Fax 71 14 which one interest can only be served at the expense of the other.'" In re Hummer a, C 00   es 10 15 Transportation, Inc., 2013 WL 8013588 (Bankr. E.D. Cal. September 12, 2013) citing M 5‐ osta  4 44 16 Johnson v. Richter, Miller & Finn (In re Johnson), 312 B.R. 810, 822 (E.D. Va. 2004). C 1 7 el   T 17 Under Section 327(e), subject to court approval, a trustee may employ: 18 [F]or a specified special purpose, other than to represent the trustee in conducting the case, an attorney that has 19 represented the debtor, if in the best interest of the estate, and if such attorney does not represent or hold any interest 20 adverse to the debtor or the estate with respect to the matter on which such attorney is to be employed. 21 22 See 11 U.S.C. § 327(e) (emphasis added). 23 Courts have held that the "where the trustee seeks to appoint counsel only as 24 'special counsel' for a specific matter, there need only be no conflict between the trustee 25 and counsel's creditor client with respect to the specific matter itself. Stoumbos v. 26 Kilimnik (In re Am. Alloy Metals), 988 F.2d 949, 964 (9th Cir. 1993) (emphasis added). 27 "Section 327(e) has a narrower focus than § 327(a), and imposes fewer restrictions on

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1 2010). Courts have "defined what it means to hold an adverse interest as follows: (1) to2 possess or assert any economic interest that would tend to lessen the value of the 3 bankrupt estate or that would create either an actual or potential dispute in which the 4 estate is a rival claimant; or (2) to possess a predisposition under circumstances that 5 render such a bias against the estate." See Tevis v. Wilke, Fleury, Hoffelt, Gould & 6 Birney, LLP (In re Tevis), 347 B.R. 679, 688 (B.A.P. 9th Cir. 2006). 7 A. Erika Has No Standing to Object to the Application 8 Erika does not have standing to object to the application. "A party's standing in a 9 bankruptcy case is governed by the 'person aggrieved' standard. A 'person aggrieved' is10 one whose pecuniary interests are directly and adversely affected." Sheen v. Diamond 11 (In re Am. Comput. & Dig. Components, Inc.), 2005 WL 6960172 (B.A.P. 9th Cir. May 122  00 12 2005); see also In re Autosport Int'l, Inc., 2013 WL 3199826 at *3-4 (Bankr. C.D. Cal. 92626  4 445‐1 13 June 24, 2013) (determining that opposition documents to motion could not be alifornia  •  Fax 71 14 considered because the party lacked standing). a, C 00   es 10 15 Erika has not made any showing of how she is a person aggrieved with standing. M 5‐ osta  4 44 16 Here, Erika has not filed a proof of claim, or highlighted any pecuniary interests that C 1 7 el   T 17 would be adversely affected by an order granting the Trustee's application to employ the18 Richards Firm. Moreover, Erika cannot establish standing simply because she might be 19 a defendant in a fraudulent transfer action. Courts have routinely held that status as a 20 defendant in a fraudulent transfer case does not confer standing. See, e.g. Abbott v. Daf21 (In re Abbott), 183 B.R. 198 (B.A.P. 9th Cir. 1995) (holding that the debtor's wife did not 22 have standing as a potential defendant to appeal the order reopening case so that truste23 could pursue fraudulent transfer claims against her); Wigley v. Wigley (In re Wigley), 88624 F.3d 681, 685 (8th Cir. 2018) (holding that debtor's wife did not have standing to appeal 25 bankruptcy court's order granting the creditor relief from stay to prosecute fraudulent 26 transfer action against her). 27 The Ninth Circuit's decision in Fondiller v. Robertson (In re Fondiller), 707 F.2d

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1 special litigation counsel to investigate and pursue fraudulent transfer claims against a 2 debtor and his wife, a non-debtor. The bankruptcy court approved the employment of 3 special litigation counsel, and the BAP affirmed. Subsequently, the wife appealed the 4 order, and the Ninth Circuit affirmed the BAP. In its holding, the Ninth Circuit noted that 5 the wife's only "demonstrable interest" was as a "potential party defendant in an 6 adversary proceeding[.]" Id. at 443. Thus, because the "order did not diminish her 7 property, increase her burdens, or detrimentally affect her rights," the wife lacked 8 standing to appeal the order. Similarly, an order granting the application to employ the 9 Richards firm has no direct impact on Erika. The order itself does not diminish her 10 property, increase any burdens, or detrimentally affect any rights. Indeed, Erika raises 11 none of these arguments in her opposition. 2  00 12 In sum, Erika, as a mere potential defendant, does not have standing to oppose 92626  4 445‐1 13 the Application. The Court can disregard the opposition on this basis alone. alifornia  •  Fax 71 14 Nonetheless, as set forth below, Erika's opposition also fails on the merits and provides a, C 00   es 10 15 no grounds to deny the Application. M 5‐ osta  4 44 16 B. The Fraudulent Transfer Claims Will Only Be Pursued by the Trustee C 1 7 el   T 17 and Do Not Create an Actual Conflict or an Adverse Interest 18 Erika argues at length that because the Richards Firm represents the Plaintiffs 19 (who previously asserted fraudulent transfer claims), there is an actual conflict because 20 fraudulent transfer claims belong to the Estate. It is true that fraudulent transfer claims 21 belong to the Estate. However, there is no actual conflict here. The Plaintiffs have 22 agreed that the fraudulent transfer claims belong to the Estate and will only be pursued 23 by the Estate. The Trustee acknowledged this agreement with the Plaintiffs in her 24 Statement to the Remand Motion filed with the Court. See Statement, Ex. "3." 25 Subsequently, counsel for the Plaintiffs repeatedly stated on the record at the hearing on26 the Remand Motion that the Plaintiffs would not pursue the fraudulent transfer claims. 27 See Transcript, Ex. "4." In fact, the Court recognized the Plaintiffs' statements in its orde

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1 agreed not to pursue the fraudulent transfer claims, there will be no overlap between the 2 Estate and the Plaintiffs. Simply put, there is no actual conflict.2 Similarly, the Plaintiffs' 3 agreement not to pursue the fraudulent transfer claims also means that the Richards Fir4 does not represent a party that holds an adverse interest. In sum, there is no basis to 5 deny the Application because of the fraudulent transfer claims. 6 C. The Potential Claim Objection Does Not Constitute an Actual Conflict 7 or An Adverse Interest 8 There is no actual conflict nor interest adverse to the Estate concerning the 9 Trustee's potential claim objection to the Plaintiffs' claim. Erika contends that the Truste10 may be required to object to the Plaintiffs' claim on the basis that the Plaintiffs' claim is 11 based on money allegedly owed pursuant to a purported oral fee-splitting agreement, 2  00 12 which Erika contends is impermissible under California law. See Opposition at 9:4-6. 92626  4 445‐1 13 Erika's assertions are based on a misapplication of the standard in section 327(e) by alifornia  •  Fax 71 14 disregarding its limiting language. a, C 00   es 10 15 Section 327(e) provides that proposed counsel cannot represent an adverse M 5‐ osta  4 44 16 interest "with respect to the matter on which such attorney is to be employed." See 11 C 1 7 el   T 17 U.S.C. § 327(e). As made clear in the Application, the Richards Firm's employment is 18 limited to investigating and pursuing fraudulent transfer claims on behalf of the Estate. 19 As to this limited purpose, the interests of the Estate and the Plaintiffs are squarely 20 aligned—both parties are interested in maximizing recovery. In searching for a conflict, 21 Erika looks beyond the narrow confines of the scope of the Richards Firm's employment 22 and misapplies the standard under section 327(e) by expanding its express limitations. 23 Erika fails to explain how a potential claim objection, which would not be handled by the 24 Richards Firm, as it is outside the scope of the Richards Firm's employment, conflicts 25 26 2 Erika's contention that the Trustee has failed to make the requisite disclosures in her application to employ the Richards Firm concerning the fraudulent transfer claims and potential claim objection is a red 27 herring. At the time the Trustee filed her Application, the Plaintiffs had already agreed that the fraudulent transfers claims belonged to the Estate. Moreover, as discussed in more detail later, the potential claim objection is a distinct issue and is not within the limited scope of the Richards Firm's employment.

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1 with recovery of fraudulent transfers or how these issues are even connected. The 2 Richards Firm's representation of the Plaintiffs is completely unrelated to its duties as 3 special litigation counsel, and does not preclude its employment as special litigation 4 counsel. There is no actual conflict or adverse interest. 5 The Bankruptcy Appellate Panel from the Ninth Circuit has rejected the line of 6 arguments Erika raises. In Fondiller v. Robertson (In re Fondiller), 15 B.R. 890 (B.A.P. 7 9th Cir. 1981) (aff'd on other grounds), the chapter 7 trustee sought to employ a firm as 8 special litigation to pursue fraudulent transfer claims against the debtor and his wife, a 9 non-debtor. The debtor and his wife objected to the trustee's employment of the firm 10 because the firm was currently representing certain creditors. The B.A.P. did not find 11 these arguments persuasive. In affirming the bankruptcy court's order authorizing 2  00 12 employment of the firm, the B.A.P. noted that section 327(e) does not require special 92626  4 445‐1 13 litigation counsel to cease its current representation of certain creditors. Here, the alifornia  •  Fax 71 14 Richards Firm's representation of the Plaintiffs is not adverse, nor does it create an actua, C 00   es 10 15 conflict with respect to Richards Firm's limited scope of employment (investigating and M 5‐ osta  4 44 16 pursuing fraudulent transfer claims against Erika and any of her related entitles). C 1 7 el   T 17 Because the Richards Firm is representing the Trustee in a limited capacity, there is no 18 issue with the Richards Firm's representation of other creditors. 19 Further, if Erika's arguments are accepted, they would render section 327(c) 20 superfluous. It is not unusual for a trustee to retain special litigation counsel that also 21 represents a creditor. Indeed, it is expressly permitted by the Bankruptcy Code and Erik22 acknowledges that in Thomas Girardi's individual case, she did not oppose the trustee's 23 application to employ special litigation counsel that represents certain creditors. See 24 Opposition at 1:17. However, Erika's contention that a potential objection to a proof of 25 claim precludes employment of special litigation counsel means that any time counsel 26 represents a creditor, proposed counsel could never be retained by a trustee. If this wer27 true, then section 327(c)'s language that provides that "a person is not disqualified for

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1 meaningless. On this point, Erika provides no case law or legal authority for a position 2 that contravenes section 327(c). In short, Erika's position is unsupported, in 3 contravention of the Bankruptcy Code and should be rejected. 4 D. The Request for a Gag Order is Improper 5 Erika's request that the Court issue a "gag order" limiting the speech of Mr. 6 Richards is improperly raised. This request is completely irrelevant to the standard for 7 employment set forth in the Application. Moreover, the issue is not currently before the 8 Court, and should not be raised in an opposition for the first time. "Courts in this and 9 other districts have concluded that a request for affirmative relief is not proper when 10 raised for the first time in an opposition." Smith v. Premiere Valet Services, Inc., 2020 11 WL 7034346 at *14 (C.D. Cal. August 4, 2020) (citing decisions where courts have 2  00 12 rejected affirmative requests for relief first raised in oppositions). Thus, because the 92626  4 445‐1 13 issue is not before the Court and is irrelevant, the Court need not consider it and should alifornia  •  Fax 71 14 deny the request. a, C 00   es 10 15 M 5‐ osta  4 44 16 IV. CONCLUSION C 1 7 el   T 17 For the foregoing reasons, the Trustee requests that the Court overrule the 18 Opposition and enter an order granting the Application. 19 20 DATED: June 1, 2021 Respectfully submitted, 21 SMILEY WANG-EKVALL, LLP 22 23 By: /s/ Lei Lei Wang Ekvall 24 LEI LEI WANG EKVALL Attorneys for Elissa D. Miller, Chapter 7 25 Trustee 26 27

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EXHIBIT "1"

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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 Miller, Chapter 7 Trustee 8 UNITED STATES BANKRUPTCY COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 LOS ANGELES DIVISION P 11 In re Case No. 2:20-bk-21022-BR L 2 MILEY WANG-EKVALL, L 3200 Park Center Drive, Suite 250 Costa Mesa, California 92626 Tel 714 445-1000 • Fax 714 445-100 111111234567 GLAPOCRAPHOaFIRWlCFIBiLfAoI, EIC ROPraRnED FiCSTSaFIH a IPKSOClEi.Eof FEoLFlEe rDSIRnS N POiOOaENrN ,BoFp, ,p Era PoarRnifHne eTi tInsioL ndsPrIdsPii.ovih v FinRdiipdaIDuN.;ul a eSNacalb,noHl; ;t dr oEaLp r LAo. DrWaOt ioNn, ; CASDTP[NOTRdhISovIa OP MF pHNCUEtIeeoSELDra.SD A Er72AiUTR :n2LIRgAO1 EOL-RNa F4eR pF 1q-UDO0(uaLE1Ri)0rEB e3V TdO9OO]-F BLR CRU PI NVUTIRLA SRUYA NT S 18 Plaintiffs, 19 v. 20 THOMAS V. GIRARDI, an individual; GIRARDI KEESE; a California law firm; 21 ERIKA GIRARDI a/k/a/ ERIKA JAYNE, an individual; EJ GLOBAL, LLC, a California 22 limited liability company; 1126 WILSHIRE PARTNERSHIP, a California general 23 partnership; GIRARDI FINANCIAL, INC., a Nevada corporation; DAVID LIRA, an 24 individual; ROBERT FINNERTY, an individual; and DOES 1-100, inclusive, 25 Defendants. 26 27 28

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1 TO THE HONORABLE BARRY RUSSELL, UNITED STATES BANKRUPTCY JUDGE: 2 Elissa D. Miller, the chapter 7 trustee (the "Trustee") for the bankruptcy estate of 3 Girardi Keese (the "Debtor"), and the Law Offices of Philip R. Sheldon, APC, Philip R. 4 Sheldon, Law Offices of Robert P. Finn, and Robert P. Finn (collectively, the "Plaintiffs"), 5 by and through their respective counsel, hereby stipulate as follows: 6 RECITALS 7 A. On December 9, 2020, the Law Offices of Philip R. Sheldon, APC, filed a 8 complaint against Thomas V. Girardi, the Debtor, and DOES 1-100, in the Los Angeles 9 Superior Court, commencing Case No. 20STCV47160 (the "State Court Action"). 10 B. On December 16, 2020, the Plaintiffs filed a First Amended Complaint P 11 against Thomas V. Girardi, the Debtor, as well as Erika Girardi, EJ Global, LLC, 1126 L 2 MILEY WANG-EKVALL, L 3200 Park Center Drive, Suite 250 Costa Mesa, California 92626 Tel 714 445-1000 • Fax 714 445-100 111111234567 WiAcCnhnrtieaeltsodprhenittiesioroerCtr ,s t7 .Poa a banJlardsatno nmKOk efeirinrmlusse phD bdOtie cepa'ryCc,ln y eGap miAlneilravtrbaichoterihaodlrui nnie 1nF, 8 ta(Raicn,g rooa2aylbn0 liencec2hcsri0atttai ,lvtMp ,hp etIe.eenl y KrtcD,i t .7eit,eoh eDbbnesatia eon"nv,Prg ki.Jd erc ou TtrLihpethiinrtodicas niAyt, oi s nbacragansam sdsCJse eiRrli laed aoOndagb,i'yat CeoE,ir nartrtsh silkFl"teaa) i Th n PfSainhleeneoatd,rmli dtt aiyaoaas.nnn s si a inG nu,g vciVr ocaielrrugdsniisn,t aiianr y S 18 which is currently pending as Bankruptcy Case No. 2:20-bk-21020-BR. 19 D. On March 5, 2021, Defendant David Lira filed a Notice of Removal, 20 removing the State Court Action to this Court and commencing adversary case 2:21-ap-21 1039-BR (the "Adversary Case"). 22 E. On March 9, 2021, the Court entered an order setting a status conference 23 and ordering the parties to show cause why the Court should not abstain and remand the 24 State Court Action. 25 F. A status conference is currently scheduled for May 11, 2021. 26 G. The Trustee and the Plaintiffs have agreed to a dismissal of the Debtor 27 without prejudice. 28

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1 STIPULATION 2 In light of the foregoing recitals, the Trustee and the Plaintiffs stipulate to the 3 following: 4 1. The Debtor is dismissed from the Adversary Case and the State Court5 Action without prejudice; 6 2. The voluntary dismissal of the Debtor shall have no effect on the Plaintiffs'7 right to enforce any alleged claim they purport to hold against the Debtor by filing a proof 8 of claim in the Debtor's bankruptcy case or the rights of the Trustee to dispute or object to 9 any such claim filed; and 10 3. The Trustee/Debtor’s estate and the Plaintiffs shall bear their own fees and P 11 costs. L 2 MILEY WANG-EKVALL, L3200 Park Center Drive, Suite 250 Costa Mesa, California 92626 Tel 714 445-1000 • Fax 714 445-100 111111234567 DATED: March 25, 2021 SBMy: ILLEEYI WLEA/Is NW/G LA-eENi KGLVe EiA WKLVLa,An LgLL LEP k vall S Attorneys for Elissa Miller, Chapter 7 Trustee 18 19 DATED: March 24, 2021 SPERTUS, LANDES & UMHOFER, LLP 20 21 22 By: JAMES SPERTUS 23 Attorneys for Plaintiffs Law Offices of Philip R. Sheldon, APC; Philip R. Sheldon; Law Offices 24 of Robert P. Finn; and Robert P. Finn 25 26 27 28

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PROOF OF SERVICE OF DOCUMENT I am over the age of 18 and not a party to this bankruptcy case or adversary proceeding. My business address is 3200 Park Center Drive, Suite 250, Costa Mesa, CA 92626. A true and correct copy of the foregoing document entitled (specify): STIPULATION FOR VOLUNTARY DISMISSAL OF DEBTOR PURSUANT TO FEDERAL RULE OF CIVIL PROCEDURE 41(a) will 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 the manner stated below: 1.TO BE SERVED BY THE COURT VIA NOTICE OF ELECTRONIC FILING (NEF): Pursuant to controlling GeneralOrders and LBR, the foregoing document will be served by the court via NEF and hyperlink to the document. On (date)March 25, 2021 I checked the CM/ECF docket for this bankruptcy case or adversary proceeding and determined that thefollowing persons are on the Electronic Mail Notice List to receive NEF transmission at the email addresses stated below:  Lei Lei Wang Ekvall lekvall@swelawfirm.com, lgarrett@swelawfirm.com;gcruz@swelawfirm.com;jchung@swelawfirm.com Edith R. Matthai ematthai@romalaw.com, lrobie@romalaw.com Elissa Miller (TR) CA71@ecfcbis.com, MillerTrustee@Sulmeyerlaw.com;C124@ecfcbis.com;ccaldwell@sulmeyerlaw.com Ronald N Richards ron@ronaldrichards.com, morani@ronaldrichards.com United States Trustee (LA) ustpregion16.la.ecf@usdoj.gov Timothy J Yoo tjy@lnbyb.com Service information continued on attached page. 2. SERVED BY UNITED STATES MAIL: On (date) March 25, 2021 , I served the following persons and/or entities at the last known addresses in this bankruptcycase or adversary proceeding by placing a true and correct copy thereof in a sealed envelope in the United States mail,first class, postage prepaid, and addressed as follows. Listing the judge here constitutes a declaration that mailing to thejudge will be completed no later than 24 hours after the document is filed. The Honorable Barry Russell James W Spertus U.S. Bankruptcy Court Spertus Landes & Umhoffer LLP Roybal Federal Building 1990 South Bundy Dr Ste 705 255 E. Temple Street, Suite 1660 Los Angeles, CA 90025 Los Angeles, CA 90012 Service information continued on attached page. 3.SERVED BY PERSONAL DELIVERY, OVERNIGHT MAIL, FACSIMILE TRANSMISSION OR EMAIL (state methodfor each person or entity served): Pursuant to F.R.Civ.P. 5 and/or controlling LBR, on (date) , I servedthe following persons and/or entities by personal delivery, overnight mail service, or (for those who consented in writing tosuch service method), by facsimile transmission and/or email as follows. Listing the judge here constitutes a declarationthat personal delivery on, or overnight mail to, the judge will be completed no later than 24 hours after the document isfiled. Service information continued on attached page. I declare under penalty of perjury under the laws of the United States that the foregoing is true and correct. March 25, 2021 Gabriela Gomez-Cruz /s/ Gabriela Gomez-Cruz Date PrintedName Signature This form is mandatory. It has been approved for use by the United States Bankruptcy Court for the Central District of California.

15

EXHIBIT "2"

16

1 SMILEY WANG-EKVALL, LLP Lei Lei Wang Ekvall, State Bar No. 163047 2 lekvall@swelawfirm.com FILED & ENTERED Philip E. Strok, State Bar No. 169296 3 pstrok@swelawfirm.com Timothy W. Evanston, State Bar No. 319342 MAR 26 2021 4 tevanston@swelawfirm.com 3200 Park Center Drive, Suite 250 5 Costa Mesa, California 92626 CLERK U.S. BANKRUPTCY COURT Telephone: 714 445-1000 Central District of California 6 Facsimile: 714 445-1002 BY f o r t i e r DEPUTY CLERK7 Attorneys for Elissa Miller, Chapter 7 Trustee 8 UNITED STATES BANKRUPTCY COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 LOS ANGELES DIVISION P 11 In re Case No. 2:20-bk-21022-BR L 2 MILEY WANG-EKVALL, L 3200 Park Center Drive, Suite 250 Costa Mesa, California 92626 Tel 714 445-1000 • Fax 714 445-100 111111234567 GLAPOCRAPHaOIFRWlCFIiBLfAIo,E IC ORPraRnED FSiCTSaFIH a PIKSOClEiE.fo FEoLFlEer DSRInS NP OiOOEaNrN ,BoFp, ,p Era PaornRiHnfee Ti tInisoL nPdsrIdsPii.ovi hv FniRdiipdIaDuN.;ul ae SNaaclbHn,ol;; t d roEaLp r LAo. DrWaOt ioNn, ; CAOFDR[NOdhEURovaRBLD pHNE TEVtee oOROOar.R Fr2L7Ai :nUPPC2gNU1PI V-TRRRaIALSeOpq R-UVP0uYAI1RNi 0rNDOeG3TIdC9S S]T-EM BTODRIIS PUF SUREALEDLA E4 TOR1I(OAFa LN) S 18 Plaintiffs, 19 v. 20 THOMAS V. GIRARDI, an individual; GIRARDI KEESE; a California law firm; 21 ERIKA GIRARDI a/k/a/ ERIKA JAYNE, an individual; EJ GLOBAL, LLC, a California 22 limited liability company; 1126 WILSHIRE PARTNERSHIP, a California general 23 partnership; GIRARDI FINANCIAL, INC., a Nevada corporation; DAVID LIRA, an 24 individual; ROBERT FINNERTY, an individual; and DOES 1-100, inclusive, 25 Defendants. 26 27 28

17

1 The Court having reviewed the Stipulation for Voluntary Dismissal of Debtor 2 Pursuant to Federal Rule of Civil Procedure 41(a) (the "Stipulation")1, which was filed as 3 docket number 15, and good cause appearing, 4 IT IS HEREBY ORDERED AS FOLLOWS: 5 1. The Stipulation is approved; 6 2. The Debtor is dismissed from the Adversary Case and the State Court 7 Action without prejudice; 8 3. The voluntary dismissal of the Debtor shall have no effect on the Plaintiffs' 9 right to enforce any alleged claim they purport to hold against the Debtor by filing a proof 10 of claim in the Debtor's bankruptcy case or the rights of the Trustee to dispute or object to P 11 any such claim filed; and L 2 MILEY WANG-EKVALL, L 3200 Park Center Drive, Suite 250 Costa Mesa, California 92626 Tel 714 445-1000 • Fax 714 445-100 111111234567 c osts. 4 . The Trustee/Debtor’s estate and #th#e# Plaintiffs shall bear their own fees and S 18 19 20 21 22 23 Date: March 26, 2021 24 25 26 27 1 Capitalized terms not defined herein shall have the meanings ascribed to them in the 28 Stipulation.

18

EXHIBIT "3"

19

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, the Chapter 7 Trustee for the bankruptcy estate of Girardi 8 Keese 9 UNITED STATES BANKRUPTCY COURT 10 CENTRAL DISTRICT OF CALIFORNIA P 11 LOS ANGELES DIVISION L 2 MILEY WANG-EKVALL, L 3200 Park Center Drive, Suite 250 Costa Mesa, California 92626 Tel 714 445-1000 • Fax 714 445-100 111111234567 IGLAPOnAPHFI RrWCFIeLAI , IC ROPaED FCSSFIH a IKOClEiEfFEoLE rDSRnS OiOOaEN ,BFp , Er PoaRfHneT IsiL nsPIdPi.oi v FnRidaIDN.ul eSNcaboHl,;t r oEaLpr LAo. DrWaOt ioNn, ; CCACOMDdHhaaFOvats AeTN epN:PI tOONeoTNrN.oE 72.-M R OF :22a OP:712y RP- 0T1aO -R1RpbS,-UkE 02-ISMT210T1I02AO03E1NN29E D2- 'BTS- BRO SR PT LAATIENMTEIFNFTS ' S California sole proprietorship; and Time: 2:00 P.m. 18 ROBERT P. FINN, an individual, Ctrm.: 1668 via ZoomGov 255 E. Temple Street 19 Plaintiffs, Los Angeles, CA 90012 20 v. Web Address: https://cacb.zoomgov.com Meeting ID: 161 713 6367 21 THOMAS V. GIRARDI, an individual; Password: 123456 GIRARDI & KEESE, a California law firm; Telephone: (669) 254-5252 (San Jose)22 ERIKA GIRARDI a/k/a ERIKA JAYNE, an (646) 828-7666 (New York)individual; EJ GLOBAL, LLC, a California 23 limited liability company; 1126 WILSHIRE PARTNERSHIP, a California general 24 partnership; GIRARDI FINANCIAL, INC., a Nevada corporation; DAVID LIRA, an 25 individual; ROBERT FINNERTY; an individual; and DOES 1-100, inclusive, 26 Defendants. 27 28

20

1 TO THE HONORABLE BARRY RUSSELL, UNITED STATES BANKRUPTCY JUDGE: 2 Elissa D. Miller, the chapter 7 trustee (the "Trustee") for the bankruptcy estate of 3 Girardi Keese (the "Estate"), submits this statement of non-opposition to the Motion for 4 Remand (the "Motion") [Docket No. 20] filed by the Law Offices of Philip R. Sheldon, 5 APC, Philip R. Sheldon, Law Offices of Robert P. Finn, and Robert P. Finn (collectively, 6 the "Plaintiffs"). 7 On March 25, 2021, the Trustee and Plaintiffs entered into a Stipulation for 8 Voluntary Dismissal of Debtor Pursuant to Federal Rule of Civil Procedure 41(a) [Docket 9 No. 15] (the "Stipulation"). Pursuant to the Stipulation, the Plaintiffs agreed to dismiss 10 Girardi Keese as a defendant from the action without prejudice. On March 26, 2021, the P 11 Court entered an order approving the Stipulation. L 2 MILEY WANG-EKVALL, L 3200 Park Center Drive, Suite 250 Costa Mesa, California 92626 Tel 714 445-1000 • Fax 714 445-100 111111234567 FoBMfrao atsthuieoidsdnu, T.olt eh hn nee tt hPsterilaxa Ptnihnsl atfciefianfrsut i cfsaflesag' ir moeafegs adr bec teethiolmaontne tginnh t et toahy n etwhd oe orp ueEelpdsrra tenatsiotveete .np tcAuaortfsimtoeunpre ,lt ahtthhienee tT ifTsrruar ufsuostdret ueferle aei nundfdtoo uterrmlase nnenstdo ft etrt haro enpc slpPafoeilmasre.isn .tt ih ffes S 18 DATED: April 27, 2021 Respectfully submitted, 19 SMILEY WANG-EKVALL, LLP 20 21 By: /s/ Timothy W. Evanston 22 TIMOTHY W. EVANSTON Attorneys for Elissa D. Miller, the Chapter 7 23 Trustee for the bankruptcy estate of Girardi Keese 24 25 26 27 28

21

PROOF OF SERVICE OF DOCUMENT I am over the age of 18 and not a party to this bankruptcy case or adversary proceeding. My business address is: 3200 Park Center Drive, Suite 250, Costa Mesa, CA 92626 A true and correct copy of the foregoing document entitled (specify): Chapter 7 Trustee's Statement of Non-Opposition to Plaintiffs' Motion for Remand will 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 the manner stated below: 1. TO BE SERVED BY THE COURT VIA NOTICE OF ELECTRONIC FILING (NEF): Pursuant to controlling GeneralOrders and LBR, the foregoing document will be served by the court via NEF and hyperlink to the document. On (date)4/27/2021, I checked the CM/ECF docket for this bankruptcy case or adversary proceeding and determined that thefollowing persons are on the Electronic Mail Notice List to receive NEF transmission at the email addresses stated below:  Lei Lei Wang Ekvall lekvall@swelawfirm.com, lgarrett@swelawfirm.com;gcruz@swelawfirm.com;jchung@swelawfirm.com Edith R. Matthai ematthai@romalaw.com, lrobie@romalaw.com Elissa Miller (TR) CA71@ecfcbis.com, MillerTrustee@Sulmeyerlaw.com;C124@ecfcbis.com;ccaldwell@sulmeyerlaw.com Ronald N Richards ron@ronaldrichards.com, morani@ronaldrichards.com United States Trustee (LA) ustpregion16.la.ecf@usdoj.gov Timothy J Yoo tjy@lnbyb.com  Service information continued on attached page 2. SERVED BY UNITED STATES MAIL: On (date) 4/27/2021, I served the following persons and/or entities at the last known addresses in this bankruptcy case oradversary proceeding by placing a true and correct copy thereof in a sealed envelope in the United States mail, first class,postage prepaid, and addressed as follows. Listing the judge here constitutes a declaration that mailing to the judge willbe 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 page 3. SERVED BY PERSONAL DELIVERY, OVERNIGHT MAIL, FACSIMILE TRANSMISSION OR EMAIL (state methodfor each person or entity served): Pursuant to F.R.Civ.P. 5 and/or controlling LBR, on (date) ______________, I servedthe following persons and/or entities by personal delivery, overnight mail service, or (for those who consented in writing tosuch service method), by facsimile transmission and/or email as follows. Listing the judge here constitutes a declarationthat personal delivery on, or overnight mail to, the judge will be completed no later than 24 hours after the document isfiled. Service information continued on attached page I declare under penalty of perjury under the laws of the United States that the foregoing is true and correct. 4/27/2021 Lynnette Garrett /s/ Lynnette Garrett Date Printed Name Signature This form is mandatory. It has been approved for use by the United States Bankruptcy Court for the Central District of California.

22

EXHIBIT "4"

23

1 UNITED STATES BANKRUPTCY COURT 2 CENTRAL DISTRICT OF CALIFORNIA 3 --oOo-- 4 In Re: ) Case No. 2:20-bk-21022-BR ) 5 GIRARDI KEESE, ) Chapter 7 ) 6 Debtor. ) Los Angeles, California ) Tuesday, May 11, 2021 7 ) 2:00 p.m. LAW OFFICES OF PHILIP R. ) 8 SHELDON, et al., ) Adv. No. 2:21-ap-01039-BR ) 9 Plaintiffs, ) ) 10 v. ) ) 11 GIRARDI, et al., ) ) 12 Defendants. ) ______________________________) 13 14 HEARING RE NOTICE OF REMOVAL 15 HEARING RE MOTION FOR REMAND 16 TRANSCRIPT OF TELEPHONIC PROCEEDINGS BEFORE THE HONORABLE BARRY RUSSELL 17 UNITED STATES BANKRUPTCY JUDGE 18 APPEARANCES: 19 For the Plaintiffs: RONALD RICHARDS, ESQ. 20 Law Offices of Ronald Richards & Associates, APC 21 Post Office Box 11480 Beverly Hills, California 22 90213 (310) 556-1001 23 24 Proceedings recorded by electronic sound recording; 25 transcript produced by transcription service.

24

ii 1 APPEARANCES: (Cont'd.) 2 For Defendant Lira: KYLE KVETON, ESQ. Robie & Matthai 3 350 South Grand Avenue Suite 3950 4 Los Angeles, California 90071 5 For Elissa Miller: TIM EVANSTON, ESQ. Smiley, Wang-Ekvall, LLP 6 3200 Park Center Drive Suite 250 7 Costa Mesa, California 92626 (714) 445-1000 8 Court Recorder: Wanda Toliver 9 United States Bankruptcy Court Edward R. Roybal Federal 10 Building 255 East Temple Street 11 Los Angeles, California 90012 12 Transcriber: Jordan Keilty Echo Reporting, Inc. 13 2160 Fletcher Parkway Suite 209 14 El Cajon, California 92020 (858) 453-7590 15 16 17 18 19 20 21 22 23 24 25

25

1 1 LOS ANGELES, CALIFORNIA TUESDAY, MAY 11, 2021 2:00 P.M. 2 --oOo-- 3 (Call to order of the Court.) 4 THE CLERK: Number three and four, Girardi Keese. 5 Please state your name for the record. 6 MR. KVETON (telephonic): Good afternoon, your 7 Honor. On behalf of Defendant David Lira, Kyle Kveton, K-V- 8 E-T-O-N. 9 THE COURT: All right. 10 MR. RICHARDS (telephonic): Good afternoon, your 11 Honor. Ronald Richards on behalf of Plaintiffs. 12 THE COURT: Okay. You want -- it's your motion to 13 remand this, right? 14 MR. RICHARDS: Yes, your Honor. 15 THE COURT: Okay. And do you wish to -- I've read 16 -- by the way, I've read all your -- all your papers. Do17 you wish to -- and you sort of -- you had the last word as18 far as the papers. I know what the argument -- why don't I19 hear from the other side. Then you can reply. How's that? 20 MR. RICHARDS: Great. 21 THE COURT: One thing, Mr. -- how do you pronounce 22 -- is it -- 23 MR. KVETON: It's pronounced Kveton, your Honor. 24 THE COURT: That's right. Got you. Kveton, okay. 25 Mr. Kveton, what I -- what I -- what I don't understand is

26

2 1 -- I mean, I understand what's going on, but my strong 2 inclination is to remand this for a couple of reasons. 3 Number one, I -- why would -- two things. One is, 4 again, I have no -- just so you understand, I have no -- I5 have no opinion on the merits of this, but I know what the6 issues are. Why -- why -- what you're saying essentially 7 that ultimately -- and, again, I don't know if you're 8 correct or not, but the other side said maybe it's true, 9 maybe it isn't. Basically you're saying, well, ultimately,10 that if they -- if they do get a judgment against you, as I11 understand, the allegation is that -- that you'll receive12 basically moneys that the -- that the firm improperly 13 diverted funds, and part of your salary payment you got was14 part of the funds. I mean, I'm saying it in very simplistic15 terms, but that's more or less what they're alleging, right? 16 MR. KVETON: That's one of their allegations, yes, 17 your Honor. 18 THE COURT: Yeah, one of them, but the -- that's 19 -- and -- and then you're saying that, well, even if -- 20 you're saying obviously that you can do it, but assuming 21 that -- that you get a judgment, you're saying, well, the22 estate would have top indemnify me anyway. 23 Is that the essence of really what your argument 24 is, why I should hear it? 25 MR. KVETON: Only -- it's only part, your Honor.

27

3 1 You've correctly articulated one of our arguments, but I 2 think the Court is -- did not look at and did not address 3 the one that I think is the problem here with moving us 4 anywhere as -- 5 THE COURT: Well, I looked at everything. I may 6 not have said it right now, but I have. I'm trying to 7 summarize best I could. 8 MR. KVETON: Sure. 9 THE COURT: So why else would you -- 10 MR. KVETON: I understand. 11 THE COURT: -- think that -- 12 MR. KVETON: And no offense intended to the Court. 13 THE COURT: -- I should hear this? 14 MR. KVETON: It's -- the simple answer I think can 15 be found in one other place, in paragraph 59 of the first16 amended complaint -- 17 THE COURT: All right. 18 MR. KVETON: -- where the Plaintiffs admit that 19 the amount of money that they are owed cannot be ascertained20 without a full accounting from the Girardi Defendant, that21 is, with the two estates in bankruptcy here, because 22 everything -- assuming they have a right to any payment 23 whatsoever, that right starts with did the Girardi Firm and24 Tom Girardi have money, control money, and not disburse it. 25 They can't even tell us how much they are owed unless and

28

4 1 until that preliminary foundational fact is determined. 2 That's got to happen in this Court. And any defenses to 3 their entitlement, for example, a lack of contract, a lack4 of standing on the part of Mr. Sheldon who did not identify5 this claim in bankruptcy years ago, et cetera, all have to6 be determined preliminarily, and those are identical 7 defenses that the Trustee is going to have to raise to the8 proof of claim file by the Sheldon and Finn Plaintiffs here. 9 If we go to State Court, we're going to end up 10 with another -- another judicial officer or tribunal making11 the very same precondition foundational fact determinations12 this Court has to make as to the two Girardi estate 13 Defendants, whether they're a party to this case or not. 14 You don't get to Dave Lira until you first get to Girardi15 and Girardi Keese, who got the money. Until that happens,16 you can't get to Mr. Lira, regardless of Plaintiffs' theory. 17 Plaintiffs admit that. That -- that is a core -- a core 18 fundamental precept in their complaint. You must get an 19 accounting of the Girardi Defendants first and how much the20 Plaintiffs are owed in the first instance before you can 21 figure out whether there was transfer that was fraudulent, a22 conversion or abuse of any elder. And, therefore, we should23 not be litigating this case in two separate forums because24 you have to -- this Court has to make those determinations25 as to the key Defendants, where the tentacles all emanate

29

5 1 from, that is, Girardi and Girardi Keese. 2 THE COURT: Okay. Thank you. All right. And 3 thank you for adding that. I did read that, but -- okay. 4 Mr. Richards? 5 MR. RICHARDS: Yeah, that -- that's incorrect, 6 your Honor, because the accounting we can get through 7 discovery. There -- we don't need to sue somebody to ge4t8 accounting. And, second of all, the claims against Lira are9 independent tort claims. He doesn't get indemnity for any10 tortious conduct under Labor Code 2802, and the Girardi 11 Keese Defendant's not a part of this action anymore, and 12 we're not pursuing any of the state claims. There's no 13 claim objection process. If there's a -- if there's an 14 omitted claim from Sheldon's bankruptcy filing, the State15 Court will apply the Code, and they'll win on a motion for16 judgment on the pleadings or demur. I mean, it happens all17 the time in State Court. They argue -- they use the word18 "judicial estoppel" even though that's not technically 19 correct. That's what every State Court practitioner does,20 and say, "Oh, it's not on the bankruptcy form. So they're21 barred." So we just want to proceed against -- that's how22 we resolve the case with the Trustee. We just want to 23 proceed against the non-Debtor parties, and I don't think24 this Court needs to be the bookkeeper for the Girardi Keese25 estate. We can get that information from either the

30

6 1 Defendant directly through discovery or by discovery against2 the -- 3 THE COURT: Well, as -- 4 MR. RICHARDS: -- Trustee. 5 THE COURT: -- I understand it, you have to show, 6 I gather -- and, again, thank you. You've been a little 7 more explicit. I was trying to cut through, and I didn't do8 a very good job in cutting through the issues. But I guess9 they have to show, and it -- it would be, I guess, the way I10 -- just reviewing the transcripts of what happened in 11 Chicago -- I haven't had the trials here, but just taking12 you -- the -- which of the -- what I'm trying to figure out13 is -- I think I know the answer -- as far as the -- but 14 essentially you're saying that these would be -- I use that15 as an example, the $2,000,000 that apparently is missing 16 from the aircraft, the crash in Indonesia I think it was. 17 Is that part of this? 18 MR. RICHARDS: No. 19 THE COURT: Okay. Well, that's where I wanted to 20 make sure. 21 MR. RICHARDS: We have written fee agreements with 22 all these clients. I know the complaint says oral, but on23 some allegations -- 24 THE COURT: I wanted to make it clear for me at 25 this point exactly which -- because the essence of it is

31

7 1 that the firm improperly got the money and then -- then --2 and then these -- these salary, whatever you call it, paid3 to -- with Lira were part of that. Is that in essence what4 this is about? 5 MR. RICHARDS: Yes, and also -- 6 THE COURT: Yeah. So my question is which -- 7 which of those -- 8 MR. RICHARDS: -- these were direct checks. 9 THE COURT: -- lawsuits were the ones that were 10 part of that -- the improper action by the firm, by the 11 Debtor? 12 MR. RICHARDS: Well, these were other lawsuits, 13 your Honor, not just the Chicago lawsuit. 14 THE COURT: Okay. Well, that's where I went off. 15 MR. RICHARDS: And may players -- yeah, there's 16 many -- I was on the phone for those contempt hearings. 17 There's many joint client agreements for Girardi and Keese18 and the Plaintiffs, like many other lawyers in Southern 19 California, have joint fee agreements with the clients. 20 THE COURT: Right. 21 MR. RICHARDS: Girardi was the lawyer, and the 22 Plaintiffs were the lawyer. And so Girardi got the fees but23 never turned them over to the -- 24 THE COURT: Right. 25 MR. RICHARDS: -- Plaintiff and paid Lira.

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8 1 THE COURT: Right. So all -- so all you need to 2 show, again, I'm -- I wanted to get it straight. I -- as 3 far as the particular fees that are involved, that all you4 have to show -- and you obviously as the Plaintiff is that 5 -- that the moneys were paid to Girardi Keese, right? 6 That's basically what you have to show, right? 7 MR. RICHARDS: That's correct. Also, there were 8 direct statements by Lira we've alleged in the complaint, 9 and there was direct conduct. Lira's not some outsider. 10 He's been a signer on the trust account, and he's Girardi's11 son-in-law. He's not like somebody out of left field here. 12 I mean, he's a principal lieutenant in the Girardi 13 organization. He's a higher up for sure. 14 THE COURT: Okay. So -- and so again, so what -- 15 what my question to you is -- is what -- what determination16 that the -- the State Court would make because that -- 17 that's fairly -- would not possibly be inconsistent with 18 anything I would do, namely, what was owed, you know. 19 MR. RICHARDS: The State Court and you don't even 20 come into close contact on this one. 21 THE COURT: All right. Mr. Kveton, what about 22 that? I don't think that -- I don't have to make a full 23 determination, do I? 24 MR. KVETON: Well, you have to make -- first of 25 all, leaving aside from the inaccuracies from that

33

9 1 recitation of Mr. Richards, which I'll just categorically 2 say he's wrong on the characterizations to Lira and his 3 conduct -- 4 THE COURT: Okay. And, again, I -- 5 MR. KVETON: -- but the bottom line is -- 6 THE COURT: -- figured you would disagree. 7 MR. KVETON: -- they don't get a dime. They don't 8 get a dime. They don't get a dime unless and until they can9 prove, (a), there was a valid fee split or fee agreement 10 with Girardi Keese. Lira was not a party to any of those11 alleged contracts. Not even Mr. Richards can say that with12 a straight face. 13 Secondly, they have to prove the amount given the 14 settlement they are owed from the Girardi Firm, that is, how15 much money went to the Girardi Firm and how much should have16 gone to them. 17 Our -- our status, according to the complaint is 18 that the recipient of funds that should have been given to19 the -- Mr. Sheldon and Mr. Finn, not that we were the 20 recipient and had some obligation on the initial funds to21 disburse but that we got money that should have gone to 22 them. Until they can prove and get a determination as to23 (a) entitlement and (b) amount, the amount and extent any24 liability that might ever be asserted against Mr. Lira is25 purely speculative, which is the foundational fact that has

34

10 1 to be determine is is the Sheldon and Finn firms entitled to2 money in the first place. That is a decision you're going3 to have to make in any event separately on the proofs of 4 claim and should not be made by a State Court where you have5 competing -- two competing judges doing the same 6 determination. And how a judge might apply the doctrines of7 judicial estoppel or any other if you fail to disclose it in8 your bankruptcy filing theory, should be done in one court. 9 Quite frankly, it should be done by you. 10 THE COURT: Of course, the problem with that is -- 11 I'm very familiar with judicial estoppel, with that area. 12 The only problem is in this case, this was an involuntary13 case, and there's the -- the -- that doesn't work, you know,14 when you're dealing with involuntary. It worked quite well15 -- but, anyway, let me hear very briefly, Mr. Richards -- 16 MR. KVETON: That was Sheldon filing, your Honor. 17 The filing we're talking about failing to disclose was 18 Sheldon's, not the Girardi involuntary -- 19 THE COURT: Okay. Okay. All right. Thank you. 20 All right. Mr. -- 21 MR. KVETON: Just for clarification. Thank you, 22 your Honor. 23 THE COURT: -- Richards? 24 MR. RICHARDS: We haven't filed any claims. We 25 may never file claims in this case depending on the outcome

35

11 1 of the money trail to Lira. We don't have to lay out -- we2 don't have to prove that Lira received an exact amount to 3 allege a claim against him. I mean, he's trying to create4 this mix where there's -- where -- this is just a complaint5 against a non-Debtor that -- that -- it's all conjecture 6 that you're even going to have to adjudicate a claim. That7 assumes there won't be a resolution with Mr. Spertus who's8 representing the Plaintiffs and the Trustee. I mean, that9 just isn't -- 10 THE COURT: Okay. I'm going to grant the motion 11 to remand. I tend to agree with you. I'm not as worried12 about the possibility that the State Court judge might make13 a ruling inconsistent. And also, what I'm certainly not 14 ever going to want to do is deal with Mr. Lira's conduct. 15 That -- that -- and if he does, if the -- I don't have any -16 - again, I have no opinion how this is all going to play 17 out. I'm not particularly worried about the State Court 18 making any -- any determination that may conflict with my19 views. 20 And, in any case, either -- one of two things is 21 going to happen. Again, I'm repeating myself ad nauseam. 22 Either Mr. Lira's going to win or he's going to lose, and if23 he -- if he -- if he wins, then it's a moot -- everything24 you were talking about is really a moot point. And if he25 loses, then he can turn around and he can file his claim for

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12 1 indemnification and then we'll go to that. And, again, I 2 have, again, no -- no opinion whatsoever on that. 3 So I think the better part of valor in this case 4 is let it all play out in the State Court. So I will -- if5 you'll -- Mr. Richards, if you'll prepare an order remanding6 that -- that complaint to the State Court, and that -- I 7 don't think -- that doesn't leave anything for me to do, is8 it not? 9 MR. RICHARDS: Your Honor? 10 MR. KVETON: That's correct. 11 MR. EVANSTON (telephonic): Your Honor, I'm sorry. 12 This is Tim Evanston for the Chapter 7 Trustee, Elissa 13 Miller. 14 THE COURT: I'm sorry I -- I saw you there, but I 15 wasn't sure if you wanted to speak. I'm assume you agree16 with what the -- what I've just done? 17 MR. EVANSTON: We do. We have no opposition. Our 18 only request is that Plaintiffs' counsel confirm on the 19 record that the fraudulent transfer claims will be pursued20 by the estate. 21 MR. RICHARDS: That's correct, your Honor. We are 22 not pursuing any of the fraudulent transfer claims. Those23 are just going to be pursued by the estate only. We are not24 -- even though the complaint had been in there, we made an25 agreement before the -- before the non-opposition by the

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13 1 Trustee. They raised that issue, and we filed a stip with2 them that we would not pursue the fraudulent conveyance of3 claims at all. So try to remember that this may come up in4 a future hearing, so when they raise that -- 5 THE COURT: Well, this is -- 6 MR. KVETON: May I ask one clarification, your 7 Honor? 8 THE COURT: Sure. Sure. 9 MR. KVETON: Pardon me for directing this to 10 counsel, but will we get a similar representation with the11 State Court on remand? 12 MR. RICHARDS: We're not going to pursue the 13 fraudulent conveyance claims that are pled in the complaint. 14 Those belong to the estate, and I'll -- I mean, I'm -- I'll15 send you a copy of the stipulation I made with the Trustee's16 counsel. 17 THE COURT: Well, and I assume they're not 18 suicidal. I assume the same statement will be made to the19 State Court, right? And that's -- that's a rhetorical 20 question, but it's a fair one, right? 21 MR. RICHARDS: That's correct. We're not pursuing 22 the fraudulent conveyance claims. 23 THE COURT: Yeah, I -- okay. That's certainly a 24 fair -- it's a fair question. Anyway, this whole case is a25 fascinating case and no doubt will be -- who knows what

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14 1 other things will come up, but this particular one, I think2 this one does belong in -- in the State Court. And so thank3 you, Gentlemen. Thank you very much, and if you'll prepare4 that order, I will sign that, and that concludes this 5 hearing. Thank you very much. 6 ALL: Thank you, your Honor. 7 THE COURT: You're welcome. 8 (Proceedings concluded.) 9 10 11 I certify that the foregoing is a correct 12 transcript from the electronic sound recording of the 13 proceedings in the above-entitled matter. 14 15 /s/Jordan Keilty 5/11/2021 Transcriber Dates 16 17 FEDERALLY CERTIFIED TRANSCRIPT AUTHENTICATED BY: 18 19 /s/L.L. Francisco L.L. Francisco, President 20 Echo Reporting, Inc. 21 22 23 24 25

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EXHIBIT "5"

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SPERTUS, LANDES & UMHOFER, LLP 1 James W. Spertus (SBN 159825) Ezra D. Landes (SBN 253052) 2 1990 South Bundy Dr., Suite 705 Los Angeles, California 90025 FILED & ENTERED 3 Tel.: (310) 826-4700 Fax: (310) 826-4711 4 jim@spertuslaw.com MAY 13 2021 ezra@spertuslaw.com 5 THE LAW OFFICES OF CLERK U.S. BANKRUPTCY COURT 6 RONALD RICHARDS & ASSOCIATES, A.P.C. CBeYn f t or ra t li e D r i s t r i cDtE oPf UCTaYli fCorLnEiaRKRonald Richards (SBN 176246) 7 Morani Stelmach (SBN 296670) P.O. Box 11480 8 Beverly Hills, CA 90213 Tel.: (310) 556-1001 9 Fax: (310) 277-3325 ron@ronaldrichards.com 10 morani@ronaldrichards.com LP 4711 11 Attorneys for Plaintiffs L 6- Spertus, Landes & Umhofer, 1990SBD.,S705 OUTH UNDY R UITE LA.CA90025 OS NGELES T310-826-4700;F310-82ELEPHONE ACSIMILE 1111123456 IGnI RrFeA:O RRD TI HKEE ECSEEN,T RUDANeLb IDtToEIrS.D T RSTICATT OESF BCAANLIKFROURCHCAPNHAToDInACASV.E Y,P.B L NT NaCOErOOOrSRy..U: : AR 7 2R2 Nu::T2s2Gs0 1e-E-lbalLkp E--20S11 0D023I29V--IBBSRRIO N 17 LAW OFFICES OF PHILIP R. SHELDON, APC, a California professional corporation, ORDER GRANTING PLAINTIFFS’ 18 PHILIP R. SHELDON, an individual, LAW MOTION FOR REMAND OFFICES OF ROBERT P. FINN, a California 19 sole proprietorship, and ROBERT P. FINN, an DATE: May 11, 2021 individual, TIME: 2:00 p.m. 20 Plaintiffs, CTRM: by zoomgov.com MEETING ID: 161 713 6367 21 v. PASSWORD: 123456 22 THOMAS V. GIRARDI, an individual; GIRARDI & KEESE, a California law firm; 23 ERIKA GIRARDI a/k/a ERIKA JAYNE, an individual, EJ GLOBAL, LLC, a California 24 limited liability company, 1126 WILSHIRE PARTNERSHIP, a California general 25 partnership, GIRARDI FINANCIAL, INC., a Nevada corporation, DAVID LIRA, an 26 individual, ROBERT FINNERTY, an individual, and DOES 1-100, inclusive, 27 Defendants. 28

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1 The Court, having considered Plaintiffs Law Offices of Philip R. Sheldon, Philip R. 2 Sheldon, Law Offices of Robert P. Finn, and Robert P. Finn’s (collectively, “Plaintiffs”) 3 motion for an order remanding to state court the action entitled Law Offices of Philip R. 4 Sheldon, et al. v. Girardi, et al., Los Angeles Superior Court Case No. 20STCV47160 (the 5 “Removed Action”), any opposition regarding the same, for the reasons stated on the record 6 and for good cause appearing, hereby orders that Plaintiffs’ Motion is GRANTED. 7 Counsel for Plaintiff also reaffirmed that Plaintiffs would not be proceeding on any 8 fraudulent transfer claims, including but not limited to the 6th Cause of Action in the First 9 Amended Complaint, and that fraudulent transfer claims belong to the bankruptcy estate of 10 Girardi Keese. LP 4711 11 The Removed Action is hereby REMANDED to the Superior Court of the State of L 6- Spertus, Landes & Umhofer, 1990SBD.,S705 OUTH UNDY R UITE LA.CA90025 OS NGELES T310-826-4700;F310-82ELEPHONE ACSIMILE 1111123456 C # #a#li foIrTn iIaS, CSoOu nOtyR oDfE LRosE ADn. geles forthwith. 17 18 19 20 21 22 23 24 Da te: May 13, 2021 25 26 27 28 1

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1 All parties hereby agree to the foregoing order. 2 Dated: May 12, 2021 SMILEY WANG-EKVALL 3 4 /s Tim Evanston 5 ___________________________ Tim Evanston 6 Attorney for the Trustee 7 8 Dated: May 12, 2021 SPERTUS, LANDES & UMHOFER LLP 9 10 /s Ezra Landes LP 4711 11 ___________________________ Spertus, Landes & Umhofer, L1990SBD.,S705 OUTH UNDY R UITE LA.CA90025 OS NGELES T310-826-4700;F310-826-ELEPHONE ACSIMILE 1111123456 D ated: M ay 12, 2021 EAR/sz OtKtroaByr ILnlEeea yKn& dfv eoMesrt oAPnlTa TinHtifAfsI 17 ___________________________ 18 Kyle Kveton Attorney for Defendant David Lira 19 20 21 22 23 24 25 26 27 28 2

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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): REPLY TO OPPOSITION OF ERIKA GIRARDI TO HAPTER 7 TRUSTEE'S APPLICATION TO EMPLOY THE LAW OFFICES OF RONALD RICHARDS & ASSOCIATES, .P.C., AS SPECIAL LITIGATION COUNSEL will be served or was served (a) on the judge in chambers in the form and anner 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) une 1, 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) June 1, 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. 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. June 1, 2021 Gabriela Gomez-Cruz /s/ Gabriela Gomez-Cruz Date Printed Name Signature

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ADDITIONAL SERVICE INFORMATION (if needed): . SERVED BY THE COURT VIA NOTICE OF ELECTRONIC FILING (“NEF”) 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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