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Full title: Motion for Order Authorizing the Transition and Assignment of the Estate's Interests in the NFL Concussion Litigation to Goldberg Persky White P.C. Free and Clear of Liens, Claims and Interests Pursuant to 11 U.S.C. Secton 363; Memorandum of Points and Authorities; Declaration of Elissa D. Miller in Support with Proof of Service Filed by Trustee Elissa Miller (TR) (Ekvall, Lei Lei) (Entered: 06/09/2021)

Document posted on Jun 8, 2021 in the bankruptcy, 25 pages and 0 tables.

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WHEREAS, Trustee has been informed that Debtor has an obligation to Virage SPV1, LLC by Loan Agreement dated as of November 1, 2017, that GPW and RB have entered into an Amendment to said Loan Agreement and that said Amendment does not modify Debtor’s rights and obligations thereunder, if any, and that Trustee reserves all rights to dispute any claims, rights, or interests asserted by Virage SPV1, LLC, against the Debtor, the Debtor’s estate, or their assets, including but not limited to the scope, priority, extent and validity of any security interests that may be asserted by Virage SPV1, LLC. The assignment to GPW, including without limitation the GPW Allocation, shall be free and clear of all liens, claims, encumbrances, and other interests pursuant to Bankruptcy Code section 363(f), including but not limited to (i) any purported liens, assignments, encumbrances, or other purported transfers to litigation funders or other creditors of the Debtor, (ii) any purported assignments or transfers (or agreements to a substitution of counsel or notice of association or appearance) by the Debtor, and (iii) claims for contribution.Any liens, claims, encumbrances, or other interests of the Debtor’s creditors or other entities that may assert an interest in the Debtor’s right to attorneys’ fees or other compensation relating to the Clients shall attach only to the Estate Allocation, to the same extent, priority, and validity (if any) that such liens, claims, encumbrances, or other interests had prior to consummation of this Agreement, and subject to any claims or defenses the Trustee or the Estate may have.Neither GPW nor the Trustee shall make any voluntary assignment, voluntary referral, or other voluntary transfer that would cause fees that would otherwise be Joint Rep. Fees to be paid to any other counsel, entity, or person, unless such assignment, referral, or other transfer (i) by GPW is solely out of the GPW Allocation, or (ii) by the Trustee (and with Bankruptcy Court approval) is solely out of the Estate Allocation.The form and substance of the order approving this Agreement shall be reasonably acceptable to GPW, and shall include determinations by the Bankruptcy Court that (i) the Trustee has authority to enter into this Agreement and to consummate the transactions contemplated hereby, (ii) the assignment and transfer of any rights to payment or other property is free and clear of all claims, liens, encumbrances, rights of the Trustee to contribution or indemnity and other interests against the Debtor, (iii) any asserted claims, liens, encumbrances, or other interests against the Debtor or its property shall attach only to the Estate Allocation, to the same extent, priority, and validity (if any) that such liens, claims, encumbrances, or other interests had prior to consummation of this Agreement, and subject to any claims or defenses the Trustee or the Estate may have; such claims, liens encumbrances, or other interests shall not attach t

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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 IGnI RreA RDI KEESE, CChaasep tNero 7. 2:20-bk-21022-BR ornia ax 71 a, Calif00 • F 14 MTHOET ITORNA FNOSRIT IOORND AENRD A AUSTSHIOGRNIMZIENNGT s0 15 OF THE ESTATE'S INTERESTS IN THE e1 M5- NFL CONCUSSION LITIGATION TO a 4 ost4 4 16 GOLDBERG PERSKY WHITE P.C. FREE C71 AND CLEAR OF LIENS, CLAIMS AND el 17 INTERESTS PURSUANT TO 11 U.S.C. T § 363; MEMORANDUM OF POINTS AND 18 AUTHORITIES; DECLARATION OF Debtor. ELISSA D. MILLER IN SUPPORT 19 [No Hearing Required Pursuant to 20 Local Bankruptcy Rule 9013-1(o)] 21 22 TO THE HONORABLE BARRY RUSSELL, UNITED STATES BANKRUPTCY JUDGE: 23 Elissa D. Miller, the chapter 7 trustee for the bankruptcy estate of Girardi Keese 24 (the "Trustee"), submits this Motion for Order Authorizing the Transition and Assignment 25 of the Estate's Interests in the NFL Concussion Litigation to Goldberg Persky White P.C. 26 Free and Clear of Liens, Claims and Interests Pursuant to 11 U.S.C. § 363 (the "Motion")27 In support of the Motion, the Trustee submits the following memorandum of points and

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1 I. INTRODUCTION 2 Prior to the involuntary petition, Girardi Keese (the "Debtor") was a prominent3 plaintiff's law firm representing clients in the areas of personal injury, defective products, 4 sexual abuse, toxic torts, business law, employment law, and aviation law. Since her 5 appointment, the Trustee and her counsel have diligently worked to analyze the Debtor's6 pending cases. To protect the Debtor's clients, the Trustee and her counsel have 7 engaged in discussions with reputable law firms to discuss the possibility of transferring 8 some or all of the Debtor's pending cases to qualified and experienced counsel. 9 Pre-petition, the Debtor and Goldberg Persky White P.C. ("GPW") represented 10 approximately 100 former NFL players ("Joint Clients") claiming to have suffered 11 concussion injuries from repeated blows to the head ("NFL Concussion Litigation"). 2 0 0 92626 4 445-1 1123 GhaPvWe ehnatse raegdr einetdo taon c aognrteineumee tnot rteop trreasnesnitti othne a Jnodi nats Csilgienn tthse a Ends ttahtee 'sT riunsteterees at nind tGheP NWF L ornia ax 71 a, Calif00 • F 14 Concussion Litigation to GPW. The proposed assignment, which is subject to each s0 15 Client's consent, is in the best interest of the Estate and the Joint Clients are assured of e1 M5- a 4 ost4 4 16 being represented by competent counsel who is already familiar with their cases. C1 7 el 17 Additionally, the Estate will collect 25% of any contingency fees earned in the NFL T 18 Concussion Litigation, which is a good outcome for the Estate. For these reasons, the 19 Motion should be granted. 20 21 II. BACKGROUND 22 A. The Debtor's Bankruptcy Case 23 The Debtor was a well-respected plaintiff's law firm based in Los Angeles,24 California. On December 18, 2020, petitioning creditors Jill O'Callahan, as successor in 25 interest to James O'Callahan, Robert M. Keese, John Abassian, Erika Saldana, Virginia 26 Antonio, and Kimberly Archie (collectively, the "Petitioning Creditors") filed an involuntary27

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1 chapter 7 bankruptcy petition against the Debtor.1 On December 24, 2020, the 2 Petitioning Creditors filed a Motion for Appointment of Interim Trustee Pursuant to 3 11 U.S.C. § 303(g) [Docket No. 12]. The Court entered an order granting the motion on 4 January 5, 2021 [Docket No. 45]. On January 6, 2021, the Trustee was appointed as th5 interim trustee [Docket No. 50]. 6 On January 13, 2021, the Court entered an Order Directing: (1) The Clerk of Cour7 to Immediately Enter an Order for Relief under Chapter 7; (2) The United States Trustee 8 to Immediately Appoint a Chapter 7 Trustee; (3) The Debtor to File All Schedules and 9 Related Documentation for Chapter 7 Case within Fourteen Days of the Entry of this 10 Order; and (4) Vacating February 16, 2021 Status Conference [Docket No. 68]. On 11 January 13, 2021, the Clerk of Court entered an order for relief against the Debtor 2 0 0 92626 4 445-1 1123 [DDeobctkoer'ts N coa.s 6e9 []D, oacnkde tth Neo T. r7u1s]t.e e w as appointed and accepted her appointment in the ornia ax 71 a, Calif00 • F 14 B. The Debtor's Pending Cases s0 15 As of the filing of the involuntary petition against the Debtor, the Debtor was e1 M5- a 4 ost4 4 16 counsel of record in a significant number of cases which were undertaken on a C1 7 el 17 contingency fee basis. Since her appointment, the protection of the clients' rights has T 18 been one of the Trustee's highest concerns. As a result, the Trustee and her counsel 19 have initiated discussions with a number of law firms, with the goal of transferring some 20 or all of the Debtor's pending cases to counsel. See Declaration of Elissa D. Miller. 21 C. The GPW Transition Agreement 22 The Debtor and GPW were counsel of record for the Joint Clients in the NFL 23 Concussion Litigation. The Debtor is not able to continue to perform as counsel for the 24 clients and GPW wishes to continue as counsel for some the Joint Clients. The Debtor's25 claim to fees and costs in the NFL Concussion Litigation is an asset of value. 26 1 The Petitioning Creditors also filed an involuntary chapter 7 bankruptcy petition 27 against Thomas V. Girardi, which is currently pending as Bankruptcy Case No. 2:20-bk-21020-BR.

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1 Accordingly, the Trustee and GPW entered into a transition agreement, whereby the 2 Trustee agreed to transfer the Estate's interest in NFL Concussion Litigation to GPW (th3 "Agreement"). The salient terms of the Agreement are as follows: 4 1. Allocation of Fees 5 All fees that may be received by GPW or the Debtor on account of the 6 representation of the Joint Clients in the NFL Concussion Litigation, net of any common 7 benefit assessments ("Fees"), shall be allocated as follows: 8 (a) To the Trustee for the benefit of the Estate, 25% of the Fees (the 9 “Estate Allocation”); 10 (b) To GPW, 75% of the Fees (the "GPW Allocation"). Any Referral 11 Fees due on cases which have been referred to the Debtor and are transferred to 2 0 0 92626 4 445-1 1123 GwhPiWch pGuPrsWua snhta tlol bthei sa uAtghroereizmeedn tto s nheagllo btiea tdee. ducted from the GPW Allocation, ornia ax 71 a, Calif00 • F 14 2. Payment Of Allocated Fees s0 15 All Fees shall be initially payable to a trust fund administered by GPW. Within 30e1 M5- a 4 ost4 4 16 days of receipt, GPW shall calculate the GPW Allocation and the Estate Allocation and C1 7 el 17 notify the Trustee of the proposed allocation. If the Trustee does not object to the T 18 proposed allocation within 14 days after such notice, GPW shall distribute the Fees in 19 accordance with the proposed allocation. If the Trustee does object, GPW shall reserve 20 such amount as would be necessary to satisfy the Trustee’s objection, if sustained, and 21 may distribute the remainder. The Trustee and GPW agree to attempt to resolve any 22 dispute promptly, which resolution shall be subject to approval under Bankruptcy 23 Rule 9019. If the parties cannot resolve their dispute within 30 days, the matter will be 24 submitted to the Bankruptcy Court. 25 3. Common Defense Benefit Claim 26 GPW and the Estate shall separately retain 100% of any common defense/benefit27 fund claim owing to them, and each shall be separately responsible for all costs,

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1 4. Assignment Of All Other Rights / Free And Clear Assignment. 2 Subject to the fee sharing agreement set forth above, all of the Debtor’s and the 3 Estate’s interests in the NFL Concussion Litigation shall be assigned to GPW "as-is", 4 "where-is", and without representation or warranty of any kind by the Trustee including, 5 without limitation, any representation or warranty as to the Joint Clients or the continued 6 representation of the Joint Clients by GPW. 7 The assignment to GPW, including without limitation the GPW Allocation, shall be8 free and clear of all liens, claims, encumbrances, and other interests pursuant to 9 Bankruptcy Code section 363(f), including but not limited to (i) any purported liens, 10 assignments, encumbrances, or other purported transfers to litigation funders or other 11 creditors of the Debtor, and (ii) any purported assignments or transfers (or agreements t2 0 0 92626 4 445-1 1123 a substAitnuyti oline nosf ,c colauinmsse,l eonr cnuomticber aonf caesss,o ocri aottiohne ro irn taeprepsetasr aonf cthee) bDye tbhteo rD’se cbrteodr.it ors or ornia ax 71 a, Calif00 • F 14 other entities that may assert an interest in the Debtor’s right to attorneys’ fees or other s0 15 compensation relating to the Joint Clients shall attach only to the Estate Allocation, to the1 M5- a 4 ost4 4 16 same extent, priority, and validity (if any) that such liens, claims, encumbrances, or otherC1 7 el 17 interests had prior to consummation of the Agreement, and subject to any claims or T 18 defenses the Trustee or the Estate may have. The GPW Allocation shall be free and 19 clear of such liens, claims, encumbrances, or other interests. For the avoidance of doub20 GPW is assuming no liabilities of the Estate, the Debtor, or any current or former 21 partners, members, attorneys, insiders, affiliates, or employees thereof, whether under 22 contract, tort, or otherwise. 23 5. Withdrawal And Substitution Of Debtor As Counsel and Lien in 24 Favor of the Estate 25 The Trustee shall take all steps reasonably necessary to cause the Debtor to 26 withdraw as counsel in the NFL Concussion Litigation. The Trustee shall coordinate with27 GPW to provide for the smooth transition of the cases and to notify the Joint Clients that

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1 acknowledge and agree that the Estate has a lien in the NFL Concussion Litigation for 2 the Estate Allocation. The lien will attach to any recovery the Joint Clients may obtain in 3 the NFL Concussion Litigation, whether by arbitration award, judgment, settlement, or 4 otherwise. The Trustee, on behalf of the Debtor and the Estate, is hereby authorized to 5 take all steps deemed necessary by the Trustee to protect and preserve the lien. 6 Immediately upon execution of the Agreement, the Trustee consents to GPW 7 communicating to the Joint Clients the existence and/or terms of the Agreement, 8 provided that prior to Bankruptcy Court approval of the Agreement, any such 9 communication note that the Agreement is subject to such approval. 10 6. Bankruptcy Court Approval 11 The terms of the Agreement, and the effectiveness thereof, are subject to Court 2 0 0 92626 4 445-1 1123 approvAal .c opy of the Agreement is attached hereto as Exhibit "1." ornia ax 71 a, Calif00 • F 14 s0 15 III. MEMORANDUM OF POINTS AND AUTHORITIES e1 M5- a 4 ost4 4 16 A. The Court Can Authorize the Assignment Under 11 U.S.C. § 363(b) C1 7 el 17 Section 363(b) of the Bankruptcy Code empowers a trustee to "use, sell or T 18 lease…other than in the ordinary course of business, property of the estate…" A 19 transaction outside the ordinary course of business is appropriate when proposed in goo20 faith and supported by a sound or valid business justification. In consideration of a 21 proposed transaction to use or sell property of the estate, courts look at whether the 22 transaction is in the best interests of the estate based on the facts and history of the 23 case. In re America West Airlines, 166 B.R. 908, 912 (Bankr. D. Ariz.1994) (citing In re 24 Lionel Corp., 722 F.2d 1063, 1071 (2d Cir. 1983)). This requires examination of the 25 "business justification" for the proposed transaction. In re 240 North Brand Partners, 26 Ltd., 200 B.R. 653, 659 (B.A.P. 9th Cir. 1996); In re Ernst Home Center, Inc., 209 B.R. 27 974 (Bankr. W.D. Wash. 1997). A trustee's business judgment is subject to great judicial

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1 MF Global, Inc., 535 B.R. 596, 605 (Bankr. S.D.N.Y. 2015); GBL Holding Co., Inc. v. 2 Blackburn/Travis/Cole, Ltd., 331 B.R. 251, 255 (N.D. Tex. 2005); In re Psychrometric 3 Systems, Inc., 367 B.R. 670, 674 (Bankr. D. Colo. 2007). 4 The proposed assignment is in the best interests of the Estate and has been 5 proposed in good faith. Under the Agreement, the Estate will realize 25% of any 6 contingency fees earned plus costs on terms that are fair to the Estate. Finally, the 7 Agreement is the product of the Trustee's arms-length negotiations with GPW. GPW wa8 willing to continue the prosecution of the NFL Concussion Litigation for the Joint Clients 9 on terms that were satisfactory to the Trustee. There is a valid business justification for 10 the Agreement, and the Agreement is in the best interests of the Estate. See Declaratio11 of Elissa D. Miller. For these reasons, the Court should authorize the assignment under 2 0 0 92626 4 445-1 1123 the AgrBe.e menTt huen dCeoru 1r1t MU.aSy. CA.u §t h3o6r3iz(be) .t h e Assignment of the Estate's Interests in ornia ax 71 a, Calif00 • F 14 the NFL Concussion Litigation Free and Clear of Any Liens and s0 15 Interests Under 11 U.S.C. § 363(f) e1 M5- a 4 ost4 4 16 As noted earlier, the Agreement provides that any creditors of the Debtor that maC1 7 el 17 hold an interest in the Debtor's future recovered attorneys' fees may only assert such T 18 interests against the Estate Allocation. These claims are unique to the Debtor. Simply 19 put, creditors can only assert their claims and interests against the Debtor, not against 20 GPW or the GPW Allocation. To make clear that these creditors' potential interests are 21 only against the Estate Allocations, the Trustee seeks Court approval to authorize the 22 assignment contemplated in the Agreement to be free and clear of any liens, claims and 23 interests under 11 U.S.C. § 363(f). 24 The Court can authorize the assignment of the Estate's interests in the NFL 25 Concussion Litigation free and clear of any liens, claims and interests under 11 U.S.C. 26 § 363(f). Section 363(f) provides the following: 27 (f) The trustee may sell property under subsection (b) or (c) of this section free and clear of any interest in such property of an entity other than the

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1 (1) applicable nonbankruptcy law permits sale of such property free and clear of such interest; 2 (2) such entity consents; 3 (3) such interest is a lien and the price at which such property is to 4 be sold is greater than the aggregate value of all liens on such property; 5 (4) such interest is in bona fide dispute; or 6 (5) such entity could be compelled, in a legal or equitable 7 proceeding, to accept a money satisfaction of such interest 8 Because 11 U.S.C. § 363(f) is written in the disjunctive, the Court may authorize 9 the assignment free and clear of any interests if any of the conditions are met. 10 The Court can authorize assignment of the Estate's interests in the NFL 11 2 Concussion Litigation free and clear of any liens, claims and interests under 11 U.S.C. 0 0 92626 4 445-1 1123 § 363(f)(5). Section 363(f)(5) "requires that there be, or that there be the possibility of, ornia ax 71 some proceeding, either at law or at equity, in which the nondebtor could be forced to a, Calif00 • F 14 accept money in satisfaction of its interest." Clear Channel Outdoor, Inc. v. Knupfer (In rs0 15 e1 M5- PW, LLC), 391 B.R. 25, 45 (B.A.P. 9th Cir. 2008). The California Commercial Code a 4 ost4 4 16 C71 provides for a proceeding where the nondebtor could be forced to accept money el 17 T satisfaction of its interest. Under California Commercial Code § 9610(a), "[a]fter default, 18 a secured party may sell…or otherwise dispose of any or all the collateral in its present 19 condition or following any commercially reasonable preparation or processing." See 20 California Commercial Code § 9610(a). Further, "[a] secured party shall apply…the cash21 proceeds of disposition under Section 9610... [to] the satisfaction of obligations secured 22 by the security interest…[and] the satisfaction of obligations secured by any subordinate 23 security interest…" See California Commercial Code § 9615(a). Here, because any 24 party that potentially holds a security interest in the Estate's fees from the NFL 25 Concussion Litigation can be compelled to accept a money satisfaction under California 26 Commercial Code §§ 9610(a) and 9615(a), 11 U.S.C. § 363(f)(5) applies. Thus, the 27

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1 Court may authorize the assignment contemplated in the Agreement free and clear of 2 any liens, claims and interests under 11 U.S.C. § 363(f)(5). 3 The Agreement is reasonable and in the best interest of the Debtor's creditors. 4 Pursuant to the Agreement, the Estate will receive 25% of the fees recovered for the 5 Clients in the NFL Concussion Litigation and all of its costs. This result greatly benefits 6 the Estate and will likely yield a recovery for the Estate that is greater than what the 7 Estate would recover litigating a quantum meruit claim. 8 The Agreement is also in the best interest of the Debtor's clients. While the 9 decision to choose and retain counsel rests with the Joint Clients, the Agreement will 10 provide the Joint Clients with the opportunity to continue with reputable and experienced 11 counsel through the proposed representation. Moreover, the Joint Clients will be 2 0 0 92626 4 445-1 1123 represeCn.t ed bWy acoivuenrs oefl w14h-oD iasy a Slretaayd yS featm Fioliartrh w iinth F tRheBirP N 6F0L0 4C(ohn) cisu sAsipopnr oLiptirgiaattieo n. ornia ax 71 a, Calif00 • F 14 FRBP 6004(h) provides that "[a]n order authorizing the use, sale, or lease of s0 15 property other than cash collateral is stayed until the expiration of 14 days after entry of e1 M5- a 4 ost4 4 16 the order, unless the court orders otherwise." Given the involuntary petition commencedC1 7 el 17 against the Debtor, it is in the best interests of the Joint Clients to resolve any uncertaintT 18 they may have concerning who is representing them. Because the NFL Concussion 19 Litigation is ongoing, resolving any confusion as quickly as possible is in the best interest20 of the clients. Waiver of the stay under FRBP 6004(h) will further preserve the amount o21 fees the Estate can expect to collect pursuant to the Agreement. For these reasons, 22 waiver of the FRBP 6004(h) stay is appropriate. 23 24 IV. CONCLUSION 25 Accordingly, the Trustee respectfully requests that the Court enter an order 26 providing for the following relief: 27 1. Granting the Motion;

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1 3. Approving the terms of the Agreement, a copy of which is attached hereto 2 as Exhibit "1"; 3 4. Authorizing the Trustee to execute any documents or take any actions 4 reasonably necessary to effectuate the terms of the Agreement; 5 5. Approving the transaction as contemplated in the Agreement pursuant to 6 11 U.S.C. § 363(b); 7 6. Authorizing and ordering the assignment and transfer of any rights or 8 payment to property as contemplated in the Agreement to be free and clear of all claims,9 liens, encumbrances, or other interests against the Debtor pursuant to 11 U.S.C. § 363(f10 7. Authorizing and ordering that any asserted claims, liens, encumbrances, or11 other interests against the Debtor will attach only to the Estate Allocation and not to the 2 0 0 92626 4 445-1 1123 GPW A8l.lo catioFnin; d ing that GPW is not assuming any liabilities of the Estate, the Debtor, ornia ax 71 a, Calif00 • F 14 or any partners, members, attorneys, insiders, affiliates, or employees thereof, whether s0 15 under contract, tort, or otherwise; e1 M5- a 4 ost4 4 16 9. Finding that the Federal Rule of Evidence 502(d) protections for attorney-C1 7 el 17 client privilege and work-product set forth in the Agreement apply; T 18 10. Authorizing the waiver of the 14-day period under FRBP 6004(h); and 19 11. For such other relief as the Court may deem just and necessary. 20 21 DATED: June 9, 2021 Respectfully submitted, 22 SMILEY WANG-EKVALL, LLP 23 24 By: /s/ Lei Lei Wang Ekvall 25 LEI LEI WANG EKVALL Attorneys for Elissa D. Miller, Chapter 7 26 Trustee 27

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1 DECLARATION OF ELISSA D. MILLER 2 3 I, Elissa D. Miller, declare as follows: 4 1. I am the duly appointed Chapter 7 Trustee in the bankruptcy case of Girard 5 Keese. I am also a partner at the law firm SulmeyerKupetz, a Professional Corporation. 6 I know each of the following facts to be true of my own personal knowledge, except as 7 otherwise stated and, if called as a witness, I could and would competently testify with 8 respect thereto. I make this declaration in support of the Motion for Order Authorizing th 9 Transition and Assignment of the Estate's Interests in the NFL Concussion Litigation to 10 Goldberg Persky White P.C. Free and Clear of Liens, Claims and Interests Pursuant to 11 11 U.S.C. § 363 (the "Motion"). Unless otherwise defined in this declaration, all terms 2 0 0 92626 4 445-1 1123 defined2 .in theT Mhoet iDoenb atorer winacso rcpoourantseedl ohfe rreecino rbdy inth ais sriegfneirfeicnacnet. number of pending casesornia ax 71 a, Calif00 • F 14 when the Petitioning Creditors commenced the involuntary petition against the Debtor. s0 15 The Debtor undertook these cases on a contingency fee basis. e1 M5- a 4 ost4 4 16 3. Since my appointment, one of my highest priorities was ensuring that the C1 7 el 17 rights of the Debtor's current clients in pending matters were protected. In order to T 18 protect these clients' rights, I immediately began to interview law firms—with the 19 assistance of my counsel—to explore the possibility of transferring the Debtor's pending 20 cases. The goal of my discussions with these law firms was to ultimately transfer some 21 or all of the pending cases to protect the clients' rights. 22 4. At the time of my appointment, the Debtor and Goldberg Persky White P.C. 23 ("GPW") represented approximately 100 former NFL players ("Joint Clients") claiming to 24 have suffered concussion injuries from repeated blows to the head ("NFL Concussion 25 Litigation"). GPW has agreed to continue to represent the Joint Clients, and GPW and I 26 have entered into an agreement to transition and assign the Estate's interest in the NFL 27 Concussion Litigation to GPW. A true and correct copy of the Agreement is attached

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1 5. I believe the proposed assignment is in the best interests of the Estate. 2 The Agreement has been proposed in good faith. Under the Agreement, the Estate will 3 realize 25% of any contingency fees earned plus costs on terms that are fair to the 4 Estate. The Agreement is the product of arms-length negotiations with GPW. GPW was5 willing to continue the prosecution of the NFL Concussion Litigation for the Joint Clients 6 on satisfactory terms. 7 6. In my opinion and based on my business judgment, there is valid 8 justification for the Agreement. The Agreement is in the best interest of the Estate as th 9 Agreement will result in the best outcome for the Estate and the Debtor's clients. 10 I declare under penalty of perjury under the laws of the United States of America 11 that the foregoing is true and correct. 2 0 0 92626 4 445-1 1123 Executed on this __9_ t_h_ day of June, 2021, at Los Angeles, California. ornia ax 71 a, Calif00 • F 14 ELISSA D. MILLER es10 15 M5- a 4 ost4 4 16 C1 7 el 17 T 18 19 20 21 22 23 24 25 26 27

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EXHIBIT "1"

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TRANSITION AGREEMENT This Transition Agreement (“Agreement”) is entered into by and between Elissa D. Miller (“Trustee”), solely in her capacity as trustee of the estate (“Estate”) of Girardi Keese (“Debtor”), the chapter 7 debtor in case number 2:20-bk-21022-BR (“Bankruptcy Case”) pending in the U.S. Bankruptcy Court for the Central District of California (“Bankruptcy Court”), on the one hand, and Goldberg Persky White P.C. (“GPW”), on the other hand. The Trustee and GPW may hereinafter be referred to individually as a “Party” and collectively as the “Parties.” RECITALS WHEREAS, prior to December 18, 2020 (“Petition Date”), the Debtor and GPW jointly represented approximately 100 former NFL players claiming to have suffered concussion injuries from repeated blows to the head (“NFL Concussion Litigation”); WHEREAS, an involuntary chapter 7 bankruptcy petition was filed against the Debtor on the Petition Date, commencing the Bankruptcy Case [Docket No. 1]; WHEREAS, on January 5, 2021, the Bankruptcy Court ordered the appointment of an interim trustee [Docket No. 45]. The Trustee was appointed as interim trustee and accepted her appointment on January 6, 2020 [Docket No. 46]; WHEREAS, on January 13, 2021, the Bankruptcy Court entered an “Order Directing: (1) The Clerk of Court to Immediately Enter an Order for Relief under Chapter 7; (2) The United States Trustee to Immediately Appoint a Chapter 7 Trustee; (3) The Debtor to File All Schedules and Related Documentation for Chapter 7 Case within Fourteen Days of the Entry of this Order; and (4) Vacating February 16, 2021 Status Conference” [Docket No. 68]. On January 13, 2021, the Clerk of Court entered an order for relief against the Debtor [Docket No. 69], and the Trustee was appointed and accepted her appointment [Docket No. 70]; WHEREAS, GPW claims that it advanced costs on behalf of the Joint NFL Concussion Clients and that the Debtor failed to advance its proportionate share. As a result, GPW claims the Debtor owes GPW the sum of $1,963,885.52, pursuant to the December 19, 2012 agreement between GPW, Russomanno & Borrello (hereafter “RB”) and Debtor, which amount has not been paid and by which the agreement has been breached by Debtor. WHEREAS, Trustee has been informed that Debtor has an obligation to Virage SPV1, LLC by Loan Agreement dated as of November 1, 2017, that GPW and RB have entered into an Amendment to said Loan Agreement and that said Amendment does not modify Debtor’s rights and obligations thereunder, if any, and that Trustee reserves all rights to dispute any claims, rights, or interests asserted by Virage SPV1, LLC, against the Debtor, the Debtor’s estate, or their assets, including but not limited to the scope, priority, extent and validity of any security interests that may be asserted by Virage SPV1, LLC. WHEREAS, following good faith, arm’s length negotiations, and to avoid the expense, delay, and risks of litigation, and to ensure continuous representation and a smooth transition for

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the clients in the NFL Concussion Litigation, the Parties desire to resolve the disputes between and among them, subject to the terms and conditions as hereinafter set forth, and pursuant to Bankruptcy Code section 363 and Federal Rule of Bankruptcy Procedure 9019; NOW, THEREFORE, in consideration of the mutual terms and covenants to be performed by each of the Parties hereto, and subject to approval of this Agreement by the Bankruptcy Court, the Parties hereby agree as follows: TERMS AND CONDITIONS 1. Definitions. In addition to the definitions in the Recitals or otherwise in this Agreement, the following definitions shall apply: “Clients” mean 100 joint clients of the Debtor and GPW in the NFL Concussion Litigation, including any of such clients that the Debtor purported to assign or otherwise transfer to (or agree to a substitution of counsel or notice of association or appearance by) any other law firm. For the avoidance of doubt, Clients shall not include any client that retains GPW after the Petition Date and that was not as of the Petition Date a client of the Debtor or GPW in the NFL Concussion Litigation (i.e., totally new clients). “Joint Rep. Fees” mean all fees that may be received by GPW or the Trustee on account of the representation of the Clients in the NFL Concussion Litigation, net of any common benefit assessments. “Referral Fees” mean referral fees owing to third parties pursuant to enforceable and documented referral fee arrangements that were entered into prior to the Petition Date and disclosed in writing to both the Debtor and GPW. For the avoidance of doubt, Referral Fees shall not include any bonuses, salaries, draws, distributions, or other compensation or obligations paid or owing to current or former partners, members, attorneys, insiders, affiliates, or employees of the Debtor. 2. Allocation of Joint Rep. Fees. a. Except for the Referral Fees referred to in subparagraph (c) below, all Joint Rep. Fees shall be allocated as follows: To the Trustee for the benefit of the Estate, 25% of the Joint Rep. Fees (the “Estate Allocation”); and To GPW, 75% of the Joint Rep. Fees (the “GPW Allocation”). b. Referral Fees due on cases which have been referred to the Debtor and are transferred to GPW pursuant to this Agreement shall be deducted from the GPW Allocation and GPW, which GPW shall be authorized to negotiate.

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c. All other fee allocations between Debtor and GPW and RB are voided and shall be merged into this Section 2. 3. Payment Of Allocated Fees. All Joint Rep. Fees shall be initially payable to a trust fund administered by GPW. Within 30 days of receipt, GPW shall calculate the GPW Allocation and the Estate Allocation and notify the Trustee of the proposed allocation. If the Trustee does not object to the proposed allocation within 14 days after such notice, GPW shall distribute the Joint Rep. Fees in accordance with the proposed allocation. If the Trustee does object, GPW shall reserve such amount as would be necessary to satisfy the Trustee’s objection, if sustained, and may distribute the remainder. The Parties agree to attempt to resolve any dispute promptly, which resolution shall be subject to approval under Bankruptcy Rule 9019. If the Parties cannot resolve their dispute within 30 days, the matter will be submitted to the Bankruptcy Court. 4. Common Defense Benefit Claim. GPW and the Estate shall separately retain 100% of any common defense/benefit fund claim owing to them, and each shall be separately responsible for all costs, expenses, and other charges associated with their respective claims. 5. Assignment Of All Other Rights / Free And Clear Assignment. Subject to the fee sharing agreement set forth above and Section 11 below, all of the Debtor’s and the Estate’s interests in the NFL Concussion Litigation shall be assigned to GPW "as-is", "where-is", and without representation or warranty of any kind by the Trustee including, without limitation, any representation or warranty as to the Clients or the continued representation of the Clients by GPW. The assignment to GPW, including without limitation the GPW Allocation, shall be free and clear of all liens, claims, encumbrances, and other interests pursuant to Bankruptcy Code section 363(f), including but not limited to (i) any purported liens, assignments, encumbrances, or other purported transfers to litigation funders or other creditors of the Debtor, (ii) any purported assignments or transfers (or agreements to a substitution of counsel or notice of association or appearance) by the Debtor, and (iii) claims for contribution. Any liens, claims, encumbrances, or other interests of the Debtor’s creditors or other entities that may assert an interest in the Debtor’s right to attorneys’ fees or other compensation relating to the Clients shall attach only to the Estate Allocation, to the same extent, priority, and validity (if any) that such liens, claims, encumbrances, or other interests had prior to consummation of this Agreement, and subject to any claims or defenses the Trustee or the Estate may have. The GPW Allocation shall be free and clear of such liens, claims, encumbrances, or other interests. For the avoidance of doubt, GPW is assuming no liabilities of the Estate, the Debtor, or any current or former partners, members, attorneys, insiders, affiliates, or employees thereof, whether under contract, tort, or otherwise.

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6. Withdrawal And Substitution Of Debtor As Counsel and Lien in Favor of the Estate. The Trustee shall take all steps reasonably necessary to cause the Debtor to promptly withdraw as counsel in the NFL Concussion Litigation. The Trustee shall coordinate with GPW to provide for the smooth transition of the cases and to notify the Clients that their cases will be handled solely by GPW. GPW agrees and the Clients shall acknowledge and agree that the Estate has a lien in the NFL Concussion Litigation for the Estate Allocation. The lien will attach to any recovery the Clients may obtain in the NFL Concussion Litigation, whether by arbitration award, judgment, settlement, or otherwise. The Trustee, on behalf of the Debtor and the Estate, is hereby authorized to take all steps deemed necessary by the Trustee to protect and preserve the lien. Immediately upon execution of this Agreement, the Trustee consents to GPW communicating to the Clients the existence and/or terms of this Agreement, provided that prior to Bankruptcy Court approval of this Agreement, any such communication note that the Agreement is subject to such approval. 7. Cooperation. The Parties shall cooperate in good faith to effectuate the terms of this Agreement, including (i) effectuating the transfer of all client and case files to GPW, (ii) filing of withdrawals and/or substitutions or disassociations of counsel, and (iii) preparing, executing or filing any documents necessary to acknowledge the Estate's lien as set forth in Section 6 of this Agreement. The Trustee and her counsel shall promptly direct all communications relating to the NFL Concussion Litigation to GPW. Pursuant to Federal Rule of Evidence 502(d), the order approving this Agreement shall provide that no communications between the Trustee, GPW, and their counsel shall constitute a waiver of the Clients’ attorney-client privilege, attorney-client confidentiality of communications, or attorney work product relating to the NFL Concussion Litigation. 8. Notices. Any notices required hereunder shall be provided in writing by overnight delivery or email to the following: Trustee: Elissa D. Miller c/o SulmeyerKupetz 333 S Grand Ave #3400 Los Angeles, CA 90071 emiller@sulmeyerlaw.com

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with copies to: Lei Lei Wang Ekvall Philip E. Strok Smiley Wang-Ekvall, LLP 3200 Park Center Drive, Suite 250 Costa Mesa, CA 92626 lekvall@swelawfirm.com pstrok@swelawfirm.com GPW: Bruce Mattock Goldberg Persky White P.C. 11 Stanwix Street, Suite 1800 Pittsburgh, PA 15222 Email: bmattock@gpwlaw.com Attention: Jason Luckasevic at jluckasevic@gpwlaw.com with copies to: ___________________________ ___________________________ ___________________________ ___________________________ 9. Entire Agreement. This Agreement constitutes the final and entire agreement between the Parties heretopertaining to the subject matter hereof and supersedes all prior and contemporaneous negotiations, discussions, agreements, and understandings of the Parties, whether oral or written, with respect to such subject matter. 10. Binding on Successors. This Agreement shall be binding upon and inure to the benefit of the successors, assigns,heirs, executors, administrators, etc. of each of the Parties, including but not limited to any successor trustee and the Debtor after the case is dismissed or closed. 11. No Assignments or Delegation of Rights. Neither Party hereto has assigned or delegated any rights to any other party or person anyof the rights or interests related to any claim which may be subject to the terms of this Agreement. Neither GPW nor the Trustee shall make any voluntary assignment, voluntary referral, or other voluntary transfer that would cause fees that would otherwise be Joint Rep. Fees to be paid to any other counsel, entity, or person, unless such assignment, referral, or other transfer (i) by GPW is solely out of the GPW Allocation, or (ii) by the Trustee (and with Bankruptcy Court approval) is

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solely out of the Estate Allocation. Any such assignment or other transfer shall be subject to the reasonable consent of the other Party. 12. Jurisdiction and Venue. Any action to enforce this Agreement must be brought in the Bankruptcy Court. TheParties each hereby waive their right to trial by jury, if any, in connection with any such legal action. The Parties consent to entry of a final judgment or order by the Bankruptcy Court as a core matter. 13. Modification. This Agreement may be modified only by a writing executed by the Party to this Agreementagainst whom enforcement of such modification is sought. 14. Further Assurances. The Parties shall take all further acts and sign all further documents necessary orconvenient to effectuate the purpose of this Agreement. Subject to the Bankruptcy Court’s approval, the order approving this Agreement shall relieve the Trustee of the obligation of signing amendments and/or substitutions for individual Clients (unless such signature is required by another court or governmental authority with relevant jurisdiction). 15. Signature and Execution. A signed copy of this Agreement shall have the same force and effect as the original. ThisAgreement may be executed in counterparts, each of which is deemed to be an original, but such counterparts together shall constitute one and the same instrument. 16. Severability. In the event that any court determines that any provision of this Agreement isunenforceable, the provision at issue shall be enforced to the maximum extent permitted by law, and all other provisions shall remain in full effect. 17. Full Authority to Sign Agreement. Any individual signing on behalf of any Party hereto expressly represents and warrants toeach other Party that he or she has full authority to do so and to bind such Party hereto and, in the case of the Trustee, to bind the Estate, subject only to approval of the Bankruptcy Court. 18. No Penalty for Drafting Agreement. No provisions of this Agreement shall be interpreted for or against any Party because thatParty or its legal representative drafted this Agreement.

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19. Parties to Bear Own Costs. Each party shall be responsible for the payment of its own costs, attorneys’ fees, and allother expenses in connection with negotiation, preparation, execution, and approval of this Agreement. Notwithstanding the foregoing, if arbitration or other legal action is necessary to enforce the terms of this Agreement, the Party declared to be the prevailing party in such arbitration or proceedings shall be entitled to its reasonable attorneys’ fees and costs incurred in enforcing this Agreement. 20. Recitals Acknowledged. The Recitals are true and correct to the best of the Parties’ knowledge, and hereby adoptedby the Parties. 21. Bankruptcy Court Approval. The terms of this Agreement, and the effectiveness thereof, are subject to the approval ofthe Bankruptcy Court, after the Parties’ compliance with the notice and hearing requirements of the Bankruptcy Code, the Federal Rules of Bankruptcy Procedure, and the Local Bankruptcy Rules. Within five days of execution of this Agreement, the Trustee will file a motion seeking Bankruptcy Court approval of this Agreement. The Trustee shall request (i) a hearing on an emergency basis or shortened time, and (ii) that the order approving this Agreement shall be effective and enforceable immediately upon entry. The form and substance of the order approving this Agreement shall be reasonably acceptable to GPW, and shall include determinations by the Bankruptcy Court that (i) the Trustee has authority to enter into this Agreement and to consummate the transactions contemplated hereby, (ii) the assignment and transfer of any rights to payment or other property is free and clear of all claims, liens, encumbrances, rights of the Trustee to contribution or indemnity and other interests against the Debtor, (iii) any asserted claims, liens, encumbrances, or other interests against the Debtor or its property shall attach only to the Estate Allocation, to the same extent, priority, and validity (if any) that such liens, claims, encumbrances, or other interests had prior to consummation of this Agreement, and subject to any claims or defenses the Trustee or the Estate may have; such claims, liens encumbrances, or other interests shall not attach to the GPW Allocation, (iv) GPW is assuming no liabilities of the Estate, the Debtor, or any partners, members, attorneys, insiders, affiliates, or employees thereof, whether under contract, tort, or otherwise, (v) the Federal Rule of Evidence 502(d) protections for attorney-client privilege and work-productset forth in Section 7 above apply, (vi) subject to the Bankruptcy Court’s approval, the Trustee isrelieved of the obligation of signing amendments and/or substitutions for individual Clients, unlesssuch signature is required by another court or governmental authority with relevant jurisdiction,(vii) the December 19, 2012 agreement shall be deemed voided and have no effect and that all ofDebtor’s rights therein are assigned to GPW, (viii) Debtor’s obligation by Loan Agreement withVirage SPV1, LCC dated November 1, 2017 is not modified by the within Order, and (ix) theprovisions of the Loan Agreement and/or Modification as to the identity of GPW and RB will notbe disclosed or publicized without further order of Court.

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22. Mutual Release. a. Release of the Trustee and the Estate. Except as for the obligations and benefits set forth by and for the Parties in the Agreement (including without limitation the GPW Allocation), GPW and RB hereby releases and forever discharges the Estate, the Trustee, and the Trustee’s attorneys and agents, each in their capacity(ies) as such (collectively, the “Trustee Released Parties”) from and against any and all claims (including, without limitation, all complaints, causes of action, lawsuits, charges, debts, liens, contracts, agreements, promises, liabilities, judgments, demands, damages, losses, emotional distress, rights, benefits, obligations, claims for contribution or indemnity, attorneys’ fees, costs, and expenses), of any kind, nature or type, whether known or unknown, liquidated or unliquidated, matured or unmatured, that GPW has or may have against any, some, or all of the Trustee Released Parties in connection with, arising out of or related to the NFL Concussion Litigation, or any other thing or matter. For the avoidance of doubt, the Trustee Released Parties shall include the Estate (including any released claim GPW may have against the Estate), but shall not include the revested Debtor (if any) or any of the Debtor’s current or former attorneys, employees, members, partners, insiders, or affiliates. b. Release by the Trustee and the Estate. Except as for the obligations and benefits set forth by and for the Parties in the Agreement (including the Estate Allocation), the Trustee on behalf of the Estate (collectively, the “Trustee Releasors”) hereby releases and forever discharges GPW and RB and their respective attorneys and agents (the “GPW and RB Released Parties”) from and against any and all claims (including, without limitation, all complaints, causes of action, lawsuits, charges, debts, liens, contracts, agreements, promises, claims for contribution or indemnity, liabilities, judgments, demands, damages, losses, emotional distress, rights, benefits, obligations, attorneys’ fees, costs and expenses), of any kind, nature or type, whether known or unknown, liquidated or unliquidated, matured or unmatured, that the Trustee Releasors have or may have against the GPW and RB Released Parties in connection with, arising out of or related to the NFL Concussion Litigation, or other litigation thing or matter. c. Unknown Claims. The Parties each acknowledge and assume the risk that subsequent to the execution of the Settlement Agreement, he, she, or it may discover facts or law, or may incur, suffer, or discover losses, damages, or injuries that are unknown and unanticipated at the time the Settlement Agreement was executed or became effective, which if known at such time may have materially affected his, her, or its decision to give the release contained herein.

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d. Section 1542 Waiver. The Trustee on behalf of the Estate, and GPW waive any and all rights they might otherwise possess under California Civil Code section 1542 and similar provisions of law existing in any other jurisdiction. California Civil Code Section 1542 provides as follows: A general release does not extend to claims which the creditor or releasing party does not know or suspect to exist in his or her favor at the time of executing the release and that, if known by him or her, would have materially affected his or her settlement with the debtor. IN WITNESS WHEREOF, the Parties hereto hereby execute this Settlement Agreement as of the date of final signature below. Dated: June __1__, 2021 _________________________________ Elissa D. Miller, solely in her capacity as Chapter 7 Trustee of the Estate Dated: June ____, 2021 GOLDBERG PERSKY WHITE P.C. By:_______________________________ Bruce Mattock

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d. Section 1542 Waiver. The Trustee on behalf of the Estate, and GPW waive any and all rights they might otherwise possess under California Civil Code section 1542 and similar provisions of law existing in any other jurisdiction. California Civil Code Section 1542 provides as follows: A general release does not extend to claims which the creditor or releasing party does not know or suspect to exist in his or her favor at the time of executing the release and that, if known by him or her, would have materially affected his or her settlement with the debtor. IN WITNESS WHEREOF, the Parties hereto hereby execute this Settlement Agreement as of the date of final signature below. Dated: June , 2021 Elissa D. Miller, solely in her capacity as Chapter 7 Trustee of the Estate .5 , Dated: June 2021 GOLDBERG PERSKY WHITE P.C. By: c "Mattoc 2869726.1 9

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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 Penter Drive, Suite 250, Costa Mesa, CA 92626. true and correct copy of the foregoing document entitled (specify): MOTION FOR ORDER AUTHORIZING THE TRANSITIOND ASSIGNMENT OF THE ESTATE'S INTERESTS IN THE NFL CONCUSSION LITIGATION TO GOLDBERG PERSKY HITE P.C. FREE AND CLEAR OF LIENS, CLAIMS AND INTERESTS PURSUANT TO 11 U.S.C. § 363; MEMORANDUM OOINTS AND AUTHORITIES; DECLARATION OF ELISSA D. MILLER IN SUPPORT ( will be served or was served (a) on thedge in chambers in the form and manner required by LBR 5005-2(d); and (b) in the manner stated below: .TO BE SERVED BY THE COURT VIA NOTICE OF ELECTRONIC FILING (NEF): Pursuant to controlling Generalrders and LBR, the foregoing document will be served by the court via NEF and hyperlink to the document. On (date)une 9, 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) June 9, 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 methodr each person or entity served): Pursuant to F.R.Civ.P. 5 and/or controlling LBR, on (date) _______ , I served thellowing persons and/or entities by personal delivery, overnight mail service, or (for those who consented in writing touch service method), by facsimile transmission and/or email as follows. Listing the judge here constitutes a declarationat personal delivery on, or overnight mail to, the judge will be completed no later than 24 hours after the document isled. 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 9, 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.comichelle Balady mb@bedfordlg.com, leo@bedfordlg.com illiam C Beall will@beallandburkhardt.com, carissa@beallandburkhardt.comri S Blumenfeld Ori@MarguliesFaithLaw.com, elen@MarguliesFaithLaw.com;Angela@MarguliesFaithLaw.com;Vicky@MarguliesFaithLaw.comichard 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.comlifford S Davidson csdavidson@swlaw.com, jlanglois@swlaw.com;cliff-davidson-7586@ecf.pacerpro.comei Lei Wang Ekvall lekvall@swelawfirm.com, lgarrett@swelawfirm.com;gcruz@swelawfirm.com;jchung@swelawfirm.comichard W Esterkin richard.esterkin@morganlewis.com imothy W Evanston tevanston@swelawfirm.com, gcruz@swelawfirm.com;lgarrett@swelawfirm.com;jchung@swelawfirm.comeremy Faith Jeremy@MarguliesFaithlaw.com, elen@MarguliesFaithlaw.com;Angela@MarguliesFaithlaw.com;Vicky@MarguliesFaithlaw.comames J Finsten , jimfinsten@hotmail.com lan W Forsley alan.forsley@flpllp.com, awf@fkllawfirm.com,awf@fl-lawyers.net,addy.flores@flpllp.comric D Goldberg eric.goldberg@dlapiper.com, eric-goldberg-1103@ecf.pacerpro.comndrew Goodman agoodman@andyglaw.com, Goodman.AndrewR102467@notify.bestcase.comuzanne C Grandt suzanne.grandt@calbar.ca.gov, joan.randolph@calbar.ca.govteven 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.comazmig Izakelian razmigizakelian@quinnemanuel.com ewis R Landau Lew@Landaunet.com aniel A Lev dlev@sulmeyerlaw.com, ccaldwell@sulmeyerlaw.com;dlev@ecf.inforuptcy.comlizabeth A Lombard elombard@zwickerpc.com, bknotices@zwickerpc.comraig G Margulies Craig@MarguliesFaithlaw.com, icky@MarguliesFaithlaw.com;Helen@MarguliesFaithlaw.com;Angela@MarguliesFaithlaw.cometer J Mastan peter.mastan@dinsmore.com, SDCMLFiles@dinsmore.com;Katrice.ortiz@dinsmore.comdith R. Matthai ematthai@romalaw.com, lrobie@romalaw.comenneth Miller kmiller@pmcos.com, efilings@pmcos.com lissa Miller (TR) CA71@ecfcbis.com, MillerTrustee@Sulmeyerlaw.com;C124@ecfcbis.com;ccaldwell@sulmeyerlaw.comric 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.comeonard Pena lpena@penalaw.com, penasomaecf@gmail.com;penalr72746@notify.bestcase.comichael J Quinn mquinn@vedderprice.com, ecfladocket@vedderprice.com,michael-quinn-2870@ecf.pacerpro.comavid M Reeder david@reederlaw.com, secretary@reederlaw.comonald N Richards ron@ronaldrichards.com, morani@ronaldrichards.comevin C Ronk Kevin@portilloronk.com, Attorneys@portilloronk.comilliam F Savino wsavino@woodsoviatt.com, lherald@woodsoviatt.comenneth 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.comoris Treyzon jfinnerty@actslaw.com, sgonzales@actslaw.comUnited States Trustee (LA) ustpregion16.la.ecf@usdoj.govric D Winston ericwinston@quinnemanuel.com hristopher K.S. Wong christopher.wong@arentfox.com, yvonne.li@arentfox.comimothy J Yoo tjy@lnbyb.com

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