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Full title: Ex parte application Trustee's Ex Parte Motion to File Under Seal Pursuant to LBR 5003-2(c) and Court Manual Section 2.8(b) as to the Trustee's Motion for Order Authorizing the Transition and Assignment of the Estate's Interests in the Mesh Litigation to Nadrich & Cohen LLP and The Oshman Firm, LLC, Free and Clear of Liens, Claims and Interests Pursuant to 11 U.S.C. Section 363; Memorandum of Points and Authorities and Declarations of Elissa D. Miller and Jeffrey Nadich in Support with Proof of Service Filed by Trustee Elissa Miller (TR) (Ekvall, Lei Lei) (Entered: 06/17/2021)

Document posted on Jun 16, 2021 in the bankruptcy, 40 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

AND JEFFREY NADICH IN SUPPORT 22 23 TO THE HONORABLE BARRY RUSSELL, UNITED STATES BANKRUPTCY JUDGE: 24 Elissa D. Miller, the chapter 7 trustee for the bankruptcy estate of Girardi Keese 25 (the "Trustee"), files this ex parte motion ("Ex Parte Motion") for an order authorizing the 26 Trustee to file under seal pursuant to Local Bankruptcy Rule ("LBR") 5003-2(c) and Cour27 Manual section 2.8(b), the Motion for Order Authorizing the Transition and Assignment o 1 Firm, LLC, Free and Clear of Liens, Claims and Interests Pursuant to 11 U.S.C. § 363 2 (the "Motion").The Debtor's claim to fees and costs in the Mesh Litigation is an asset of value19 Accordingly, the Trustee and N&O entered into a transition agreement, whereby the 20 Trustee agreed to transfer the Estate's interest in its 30 clients in the J&J Litigation and 21 its 22 clients in the BSC Litigation to N&O (the "Agreement").It is understood and acknowledged that the Debtor has advanced or 10 otherwise incurred costs in the Mesh Litigation, some of which may be claims in P 11 the Bankruptcy Case, and reimbursement for such costs will be made to the L 2 MILEY WANG-EKVALL, L 3200 Park Center Drive, Suite 250 Costa Mesa, California 92626 1000 • The assignment to N&O, including without limitation the N&O Allocation, shall be 8 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 P 11 creditors of the Debtor, and (ii) any purported assignments or transfers (or agreements to L 2 MILEY WANG-EKVALL, L 3200 Park Center Drive, Suite 250 Costa Mesa, California 92626 1000 • COHEN LLP AND THE OSHMAN FIRM, 19 LLC, FREE AND CLEAR OF LIENS, CLAIMS AND INTERESTS PURSUANT 20 TO 11 U.S.C. § 363 21 22 The Court, having reviewed and considered the Trustee's Ex Parte Motion to File 23 Under Seal Pursuant to LBR 5003-2(c) and Court Manual Section 2.8(b) as to the 24 Trustee's Motion for Order Authorizing the Transition and Assignment of the Estate's 25 Interests in the Mesh Litigation to Nadrich & Cohen LLP and The Oshman Firm, LLC, 26 Free and Clear of Liens, Claims and Interests Pursuant to 11 U.S.C. § 363 (the "Ex Parte 27 Motion"), and finding good cause appearing therefor, 28

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1 SMILEY WANG-EKVALL, LLP Lei Lei Wang Ekvall, State Bar No. 163047 2 lekvall@swelawfirm.com Philip E. Strok, State Bar No. 169296 3 pstrok@swelawfirm.com Timothy W. Evanston, State Bar No. 319342 4 tevanston@swelawfirm.com 3200 Park Center Drive, Suite 250 5 Costa Mesa, California 92626 Telephone: 714 445-1000 6 Facsimile: 714 445-1002 7 Attorneys for Elissa D. Miller, Chapter 7 Trustee 8 9 UNITED STATES BANKRUPTCY COURT 10 CENTRAL DISTRICT OF CALIFORNIA 11 LOS ANGELES DIVISION 2 0 0 92626 4 445-1 1123 I GnI RreA RDI KEESE, CChaasep tNero 7. 2:20-bk-21022-BR ornia ax 71 a, Calif00 • F 14 TFIRLUES UTNEDEE'SR E SXE PAALR PTUER MSOUATINOTN T TOO s0 15 LBR 5003-2(c) AND COURT MANUAL e1 M5- SECTION 2.8(b) AS TO THE TRUSTEE'S a 4 ost4 4 16 MOTION FOR ORDER AUTHORIZING C71 THE TRANSITION AND ASSIGNMENT el 17 OF THE ESTATE'S INTERESTS IN THE T MESH LITIGATION TO NADRICH & 18 COHEN LLP AND THE OSHMAN FIRM, Debtor. LLC, FREE AND CLEAR OF LIENS, 19 CLAIMS AND INTERESTS PURSUANT TO 11 U.S.C. § 363; MEMORANDUM OF 20 POINTS AND AUTHORITIES AND DECLARATIONS OF ELISSA D. MILLER 21 AND JEFFREY NADICH IN SUPPORT 22 23 TO THE HONORABLE BARRY RUSSELL, UNITED STATES BANKRUPTCY JUDGE: 24 Elissa D. Miller, the chapter 7 trustee for the bankruptcy estate of Girardi Keese 25 (the "Trustee"), files this ex parte motion ("Ex Parte Motion") for an order authorizing the 26 Trustee to file under seal pursuant to Local Bankruptcy Rule ("LBR") 5003-2(c) and Cour27 Manual section 2.8(b), the Motion for Order Authorizing the Transition and Assignment o

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1 Firm, LLC, Free and Clear of Liens, Claims and Interests Pursuant to 11 U.S.C. § 363 2 (the "Motion"). In support of the Ex Parte Motion, the Trustee submits the following 3 memorandum of points and authorities and the attached Declarations of Elissa D. Miller 4 and Jeffrey Nadich. 5 6 I. INTRODUCTION 7 Pre-petition, the Debtor represented approximately 30 plaintiffs against Johnson 8 Johnson, et al. ("J&J Litigation"), and approximately 22 plaintiffs against Boston Scientifi 9 Corporation ("BSC Litigation") in connection with claims for personal injury from the use 10 of pelvic mesh products. The J&J Litigation and the BSC Litigation are sometimes 11 collectively referred to as the "Mesh Litigation." Nadrich & Cohen LLP ("Nadrich") and 2 0 0 92626 4 445-1 1123 TLihtieg aOtisohnm, aannd F wirmish, LtoL Csu (b"Ostsithumtea inn" a) sa rceo cuunrsreeln ftolyr rtheep rDeseebntotirn'sg colitehnetrs p (ltahien ti"fCfsl ieinn tths"e) .M esornia ax 71 a, Calif00 • F 14 The Trustee has entered into an agreement with Nadrich and Oshman (sometimes0 15 collectively referred to as "N&O") to transition and assign the Mesh Litigation to N&O. e1 M5- a 4 ost4 4 16 This Ex Parte Motion seeks authority to file the Motion and the Agreement, which is C1 7 el 17 attached to the Motion as Exhibit "1," under seal to protect certain information regarding T 18 the fee arrangement between the parties, as the disclosure could weaken N&O's litigatio19 strategy and give the defense in the Mesh Litigation an advantage in developing its own 20 strategy, to the detriment of the Estate and the Clients. A redacted version of the Motion21 along with a proposed order are attached to this Ex Parte Motion as Exhibits "1" and "2."22 23 II. BACKGROUND 24 A. The Debtor's Bankruptcy Case 25 The Debtor was a well-respected plaintiff's law firm based in Los Angeles, 26 California. On December 18, 2020, petitioning creditors Jill O'Callahan, as successor in 27 interest to James O'Callahan, Robert M. Keese, John Abassian, Erika Saldana, Virginia

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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 N&O Transition Agreement s0 15 The Debtor was counsel of record for approximately 52 plaintiffs in the Mesh e1 M5- a 4 ost4 4 16 Litigation. The Debtor is not able to continue to perform as counsel for the clients and C1 7 el 17 N&O wishes to substitute in as counsel for those clients, subject to each client's written T 18 consent. The Debtor's claim to fees and costs in the Mesh Litigation is an asset of value19 Accordingly, the Trustee and N&O entered into a transition agreement, whereby the 20 Trustee agreed to transfer the Estate's interest in its 30 clients in the J&J Litigation and 21 its 22 clients in the BSC Litigation to N&O (the "Agreement"). 22 This Ex Parte Motion seeks to file the Motion under seal so as to not disclose the 23 amount and proportion of the fees each party will receive pursuant to the Agreement. 24 N&O believes that, in their experience, there are many factors considered by opposing 25 counsel that guide them on how to litigate the case and against whom they will focus thei26 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 emphasis. N&O believes that if opposing counsel learns of the fee division agreed to 2 between the Trustee and N&O, opposing counsel will be motivated to focus on the cases3 being transitioned here. The disclosure of the fee structure could weaken N&O's 4 litigation strategy and motivate the defense in the Mesh Litigation to use the information 5 to the detriment of the Clients and, ultimately, the Estate. See Declaration of Jeffrey 6 Nadrich attached hereto. 7 8 III. MEMORANDUM OF POINTS AND AUTHORITIES 9 A. Legal Standards for Filing Pleadings Under Seal 10 LBR 5003-2(c) provides: 11 (1) Filing Under Seal. Subject to 11 U.S.C. § 107, a 2 document may not be filed under seal without a prior written 0 0 92626 4 445-1 1123 osmerudpseatr r baoetfe tp hmreeo scteioonuntr etr.de qItfou a et hsfiteliinn jgug d sugunecd hien rr etshleieea fml aisan ndren aqe urp esrosetpte ofdos,re tahd ionr dtheer ornia ax 71 Court Manual. a, Calif00 • F 14 (2) Disclosure of Sealed Documents. No sealed or s0 15 confidential record of the court maintained by the clerk will be e1 M5- disclosed except upon written order of the court. A party a 4 ost4 4 16 seeking disclosure of sealed or confidential court records C71 must file and serve a motion pursuant to LBR 9013-1(d) or (o). el 17 The motion must state with particularity the need for specific T information in such records. 18 The Court Manual at section 2.8(b) provides: 19 Filing Documents Under Seal [LBR 5003-2(c)]. No 20 documents may be presented to the court for filing under seal unless and until the court has granted a motion authorizing 21 the filing of such documents under seal. All motions for authority to file documents under seal must be filed 22 electronically, if the filer is an attorney. 23 (1) The motion should include as exhibits, or in a separate appendix also filed electronically, the documents that the 24 movant seeks to file under seal with the confidential portions redacted; provided, however, that, if the documents 25 are voluminous, the motion may be accompanied by a declaration under penalty of perjury to this effect and a 26 schedule of the documents that movant seeks to file under seal. 27 (2) The motion must describe the nature of the information

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1 confidential information itself) and explain why the information should not be publicly disclosed. 2 (3) If and when the court grants the motion for authority to file 3 documents under seal, unredacted versions of the documents, together with an entered copy of the order 4 authorizing the sealed filing, should be presented for filing under seal in the manner directed by the court in its order 5 authorizing the filing under seal. Additional information regarding the process of filing a document under seal is 6 available by calling Case Initiation, as listed in Court Manual Appendix A, at the division where the case is pending. [Bold 7 emphasis in original.] 8 B. Portions of the Motion, the Trustee's Declaration, and the Agreement 9 Setting forth the Terms of the Assignment Should be Filed Under Seal10 This Ex Parte Motion complies with LBR 5003-2(c)(1) and Section 2.8 of the Cour11 Manual. A redacted version of the Motion and a proposed order are attached as 2 0 0 92626 4 445-1 1123 Ethxaht ibthites T"1ru" satnede "a2s.s" e Trths isis Ecxo nPfaidreten tMiaol taionnd aelxspol adienssc wribhey st hthee in nfoartumraet ioofn t hseh oinuflodr mnoatt iboen ornia ax 71 a, Calif00 • F 14 publicly disclosed. The request to file the Motion under seal is made because the s0 15 Agreement between the Trustee and N&O describes the financial arrangement between e1 M5- a 4 ost4 4 16 the parties. The redacted information is limited and only includes the specific financial C1 7 el 17 terms described in the agreement. N&O believes that disclosure of the information couldT 18 give defense in the Mesh Litigation a litigation advantage to the detriment of the Clients 19 and the Estate. 20 21 IV. CONCLUSION 22 Accordingly, the Trustee respectfully requests that the Court enter an order 23 providing for the following relief: 24 1. Granting this Ex Parte Motion; 25 2. Authorizing the Trustee to file the Motion and attached Agreement under 26 seal, with the Motion and Agreement filed in redacted form on ECF in the form attached 27 as Exhibit "1";

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1 3. For such other relief as the Court may deem just and necessary. 2 3 DATED: June 15, 2021 Respectfully submitted, 4 SMILEY WANG-EKVALL, LLP 5 6 By: /s/ Lei Lei Wang Ekvall 7 LEI LEI WANG EKVALL Attorneys for Elissa D. Miller, Chapter 7 8 Trustee 9 10 11 2 0 0 92626 4 445-1 1123 ornia ax 71 a, Calif00 • F 14 s0 15 e1 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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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 Mesh Litigation to Nadrich & 10 Cohen LLP and The Oshman Firm, LLC, Free and Clear of Liens, Claims and Interests 11 Pursuant to 11 U.S.C. § 363 (the "Motion"). Unless otherwise defined in this declaration,2 0 0 92626 4 445-1 1123 all term2s. definTehde i nD tehbet oMr owtiaosn caoruen isneclo orpf oreractoerdd hfoerr eaipnp broyx tihmisa treelfye r5e2n cpela. intiffs in the ornia ax 71 a, Calif00 • F 14 Mesh Litigation. I recently entered into the Transition Agreement on behalf of the Estate s0 15 whereby I agreed to transfer the Estate's interest in the Mesh Litigation to N&O. e1 M5- a 4 ost4 4 16 3. I am informed that it is in the best interest of the Estate to file the Motion C1 7 el 17 under seal to protect certain information regarding the fee arrangement between the T 18 parties, as the disclosure could weaken N&O's litigation strategy and give the defense in 19 the Mesh Litigation an advantage in developing its own strategy, to the detriment of the 20 Estate and the Clients. A redacted version of the Motion along with a proposed order ar21 attached to this Ex Parte Motion as Exhibits "1" and "2." 22 I declare under penalty of perjury under the laws of the United States of America 23 that the foregoing is true and correct. 24 Executed on this __1_7_t_h day of June, 2021, at Los Angeles, California. 25 26 ELISSA D. MILLER 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 D. Miller, Chapter 7 Trustee 8 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 1000 • Fax 714 445Tel 714 445--100 111111234567 I G nI RreA RDI KEESE, C C MTOMCLCLHahOLFOECsaAE SHTTep, IH EITHM tFONeN RERSLrNo A I E7L.E TA FN 2ELSINOG:SP T2ADRIA 0ATAN -TITIObNNDOIEkORDT N-C'N2SED TL1A R EITHE0NNREO2EATDS 2 AREON T-ABU RSASOSRTE DHFPS HSRM UILOTGIARICSRENNSH NIMIZ UN FS&IEA NI,TR N NGHMTT E , S TO 11 U.S.C. § 363; MEMORANDUM OF 18 POINTS AND AUTHORITIES; Debtor. DECLARATION OF ELISSA D. MILLER 19 IN SUPPORT 20 [No Hearing Required Pursuant to 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 Mesh Litigation to Nadrich & Cohen LLP and The Oshman 26 Firm, LLC, Free and Clear of Liens, Claims and Interests Pursuant to 11 U.S.C. § 363 27 (the "Motion"). In support of the Motion, the Trustee submits the following memorandum 28 of points and authorities and the attached Declaration of Elissa D. Miller.

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1 I. INTRODUCTION 2 Prior to the involuntary petition, Girardi Keese (the "Debtor") was a prominent 3 plaintiff's law firm representing clients in the areas of personal injury, defective products, 4 sexual abuse, toxic torts, business law, employment law, and aviation law. Since her 5 appointment, the Trustee and her counsel have diligently worked to analyze the Debtor's 6 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 represented approximately 30 plaintiffs against Johnson & 10 Johnson, et al. ("J&J Litigation"), and approximately 22 plaintiffs against Boston Scientific P 11 Corporation ("BSC Litigation") in connection with claims for personal injury from the use L 2 MILEY WANG-EKVALL, L 3200 Park Center Drive, Suite 250 Costa Mesa, California 92626 1000 • Fax 714 445Tel 714 445--100 111111234567 ocTLsoufiht libpelgese aOctlatvtisioniNvchnte aimm,ald yalae r enrinscexd hhfFp e wpiearrrmrrinseioedhd,d n L OuttcooLces Ctsh astu om.s( b " tatTOshhnhteesi teh (uM"s mJtMoee&am esiJnnshe " hL ta)Li i mstLaiitg iriectgeaiogsa t cuaitcouintoonirosnlr lenaee. l.nnc "fTd tto lihyv Nrt e rhartohleeyduep rBgr irecDheShfoseeC eub&r rntLt e o ttiCidhtrni' egsogtoa h pco telaiaitoenhssnn e tL" tra2NsL 0rp P&e( ltay Oh(sei"eno"Na) tm "irabfCsfedrs,li tri nNieiimcngnah ettd"hss)r"e i)ca .Mhn deh sahs S 18 been involved in handling and settling over 1,000 mass tort cases. He and his teams 19 have already settled 250 of his own firm’s mesh cases, including against manufacturers 20 such as Covidien, Boston Scientific, Ethicon (Johnson & Johnson), Coloplast, Cook 21 Medical, Caldera, Bard, American Medical Systems and others. 22 Oshman has been involved in the Mesh Litigation since 2010, having filed over 23 500 cases against Johnson & Johnson, C.R. Bard, Boston Scientific, American Medical 24 Systems and Boston Scientific. He currently has an inventory of approximately 120 25 remaining cases with Johnson & Johnson pending in the Superior Court of New Jersey, 26 the jurisdiction where the Debtor's cases are pending. The balance of his cases against 27 the other four listed manufacturers have all settled. Oshman has attended upward of 100 28

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1 depositions, primarily in the J&J Litigation, and has handled approximately a dozen cases 2 designated as bellwethers, for core discovery and trial. 3 The proposed assignment, which is subject to each Client's consent, is in the best 4 interest of the Estate, and the Clients are assured of continued representation. 5 Additionally, the Estate will collect earned in the J&J 6 Litigation, and in the BSC Litigation, plus costs, which is a good outcome for the 7 Estate. For these reasons, the Motion should be granted. 8 9 II. BACKGROUND 10 A. The Debtor's Bankruptcy Case P 11 The Debtor was a well-respected plaintiff's law firm based in Los Angeles, L 2 MILEY WANG-EKVALL, L 3200 Park Center Drive, Suite 250 Costa Mesa, California 92626 1000 • Fax 714 445Tel 714 445--100 111111234567 CiAcP1nh1neatea ttlUioirpfteoin.toSesrinonrt. iC,int7a oa.g . bn §J CadOa 3n rmnKe0k eid3rDmusi(tegpbo Oc)terc es['ryCDm lyf iapo lbeAlecledakrtric het aih1aot i8MnnNe,, oo a(2Rc.tg0 ioo1oa2lb2nli0ene] ,.fcs r optt ti Tr vetM hhAetie.eltp yi K opD,C neoteohieinnbuesgttr emot" c,Pre e.rJ1eneno tt dtiehO tioirtnonoef n rAdIDsni nb ateJgeanci rsl Celio smOmriraed 'bTCndeer,iaru tr Eol gsl2rartrsi4eahk",enaa) 2 tn fPiSi0n,le ua2gadrl0 ssdt ,h aua steannhu naemcint,c ovteVotosii orlsugnoni nrot aiiannr y S 18 January 5, 2021 [Docket No. 45]. On January 6, 2021, the Trustee was appointed as the 19 interim trustee [Docket No. 50]. 20 On January 13, 2021, the Court entered an Order Directing: (1) The Clerk of Court 21 to Immediately Enter an Order for Relief under Chapter 7; (2) The United States Trustee 22 to Immediately Appoint a Chapter 7 Trustee; (3) The Debtor to File All Schedules and 23 Related Documentation for Chapter 7 Case within Fourteen Days of the Entry of this 24 Order; and (4) Vacating February 16, 2021 Status Conference [Docket No. 68]. On 25 January 13, 2021, the Clerk of Court entered an order for relief against the Debtor 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-28 21020-BR.

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1 [Docket No. 69], and the Trustee was appointed and accepted her appointment in the 2 Debtor's case [Docket No. 71]. 3 B. The Debtor's Pending Cases 4 As of the filing of the involuntary petition against the Debtor, the Debtor was 5 counsel of record in a significant number of cases which were undertaken on a 6 contingency fee basis. Since her appointment, the protection of the clients' rights has 7 been one of the Trustee's highest concerns. As a result, the Trustee and her counsel 8 have initiated discussions with a number of law firms, with the goal of transferring some 9 or all of the Debtor's pending cases to counsel. See Declaration of Elissa D. Miller. 10 C. The N&O Transition Agreement P 11 The Debtor was counsel of record for approximately 52 plaintiffs in the Mesh L 2 MILEY WANG-EKVALL, L 3200 Park Center Drive, Suite 250 Costa Mesa, California 92626 1000 • Fax 714 445Tel 714 445--100 111111234567 LNcATitosirc&tu inc2gOssoa2te ret wdniceoiiltns in.ea hg. ng Tel ytrThsse,h eettihneo dD e tDsteh ouTebe brbtt uorBstasotrSi'nttrseuC s iectsf ee lL aan rii itnnomtighd ta ae atNsot biE o& clfesneoO t eutat oosnet e sncaN'esotne& ln dirnfOteo itcnder o(u rttiseehhntso etstotos " iie naAnp gcettihrtlrrsiaeefe one 3nMrsm0tmsite e,ic o sanlsinhseut " nbaL)c.tjgio set iru Tgceinntahe s ttemtoieho sleene afn aoJiltsicr&e, htanwJh nt che L tlei aeiectrsirnlgemisetabe'snstyti to owsotnhf fr a eitavthn taneedldn u e. S 18 Agreement are as follows: 19 1. Allocation of Fees 20 All fees that may be received by N&O or the Debtor on account of the 21 representation of the Clients in the Mesh Litigation, net of any common benefit 22 assessments ("Fees"), shall be allocated as follows: 23 (a) In the J&J Litigation: 24 (i) To the Trustee for the benefit of the Estate, 25 (the “J&J Estate Allocation”); and 26 (ii) To N&O, (the "J&J N&O 27 Allocation"). 28

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1 (b) In the BSC Litigation: 2 (i) To the Trustee for the benefit of the Estate, 3 (the “BSC Estate Allocation”); and 4 (ii) To N&O, (the "BSC 5 N&O Allocation"). 6 The J&J Estate Allocation and the BSC Estate Allocation are sometimes 7 collectively referred to as the "Estate Allocation" and the J&J N&O Allocation and 8 the BSC N&O Allocation are sometimes referred to as the N&O Allocation. 9 (c) It is understood and acknowledged that the Debtor has advanced or 10 otherwise incurred costs in the Mesh Litigation, some of which may be claims in P 11 the Bankruptcy Case, and reimbursement for such costs will be made to the L 2 MILEY WANG-EKVALL, L 3200 Park Center Drive, Suite 250 Costa Mesa, California 92626 1000 • Fax 714 445Tel 714 445--100 111111234567 dnpaoroytipsfyo o sthfEAe erdslel t TFcaaereltleuoiep s2castt,a.e s sNte ihpo &aoanOlfr l t wPt bhosaietehfhy atiipmhnnllrei teo1ci anEpa4lot sllcyd stOu aaeplftydaae sA ty ea Aaal lllltbfoolhtolecceecraa a tNsttotieuoi& odacnOn h.Ft. r AneuIfoesl ltottsh iccf euae nTt, idorNu na&s datOemn edsi nhd tiahoslteele sdrE einssdottr atbi btoyeub NtAjee&l lctoOhtc et.ao tF Witoehnieet hs ai nnin d3 0 S 18 accordance with the proposed allocation. If the Trustee does object, N&O shall reserve 19 such amount as would be necessary to satisfy the Trustee’s objection, if sustained, and 20 may distribute the remainder. The Parties agree to attempt to resolve any dispute 21 promptly, which resolution shall be subject to approval under Bankruptcy Rule 9019. If 22 the Parties cannot resolve their dispute within 30 days, the matter will be submitted to the 23 Bankruptcy Court. 24 3. Common Defense Benefit Claim 25 N&O and the Estate shall separately retain 100% of any common defense/benefit 26 fund claim owing to them, and each shall be separately responsible for all costs, 27 expenses, and other charges associated with their respective claims. 28

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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 Mesh Litigation shall be assigned to N&O "as-is", "where-is", and 4 without representation or warranty of any kind by the Trustee including, without limitation, 5 any representation or warranty as to the Clients or the continued representation of the 6 Clients by N&O. 7 The assignment to N&O, including without limitation the N&O Allocation, shall be 8 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 P 11 creditors of the Debtor, and (ii) any purported assignments or transfers (or agreements to L 2 MILEY WANG-EKVALL, L 3200 Park Center Drive, Suite 250 Costa Mesa, California 92626 1000 • Fax 714 445Tel 714 445--100 111111234567 aocsinoa ttshmmeuerbpeer e sseetAntnixstsntut iaehtytiitnae oilotdisne,n tppno hrrrsfaeii ,ooc tlca rromi ltttauiyonani, mg ycsa oestanon,lsd osets huvrne eamcnr tluoiC mdamtilinaciteby etini rno( aotitnfsne f acrsoaeenhfs ssyatsth,)o l lieot ncha ri A atatothtgtat ieohscre unheDec rooe mhinrbn elttlaiyeoenp rrnttep’,oss esa ,trt anhiscgrde laaho nsEitfm ucttsohebsta e)j,ae t ebetDctnyo te A ctrtbonuhllto emeoacy rnbDa’ssyr’tea icfocbnerlntaeceo,eid srmt.s iot o,so rt orh osorer t ooh treh re r S 18 defenses the Trustee or the Estate may have. The N&O Allocation shall be free and 19 clear of such liens, claims, encumbrances, or other interests. For the avoidance of doubt, 20 N&O is assuming no liabilities of the Estate, the Debtor, or any current or former partners, 21 members, attorneys, insiders, affiliates, or employees thereof, whether under contract, 22 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 promptly withdraw as counsel in the Mesh Litigation. The Trustee shall coordinate with 27 N&O to provide for the smooth transition of the cases and to notify the Clients that their 28 cases will be handled solely by N&O. N&O agrees and the Clients shall acknowledge

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1 and agree that the Estate has a lien in the Mesh Litigation for the Estate Allocation. The 2 lien will attach to any recovery the Clients may obtain in the Mesh Litigation, whether by 3 arbitration award, judgment, settlement, or otherwise. The Trustee, on behalf of the 4 Debtor and the Estate, is hereby authorized to take all steps deemed necessary by the 5 Trustee to protect and preserve the lien. 6 Immediately upon execution of the Agreement, the Trustee consents to N&O 7 communicating to the Clients the existence and/or terms of the Agreement, provided that 8 prior to Bankruptcy Court approval of the Agreement, any such communication note that 9 the Agreement is subject to such approval. 10 6. Bankruptcy Court Approval P 11 The terms of the Agreement, and the effectiveness thereof, are subject to Court L 2 MILEY WANG-EKVALL, L 3200 Park Center Drive, Suite 250 Costa Mesa, California 92626 1000 • Fax 714 445Tel 714 445--100 111111234567 aIIpI. provA MASal e.E.c coMtipoOynT Ro 3hAf 6etNh3 CDe(bo UA)u Mgorrft e OtCheFeam nPBe nOAatnuI NiksthrT uaoSptrt taiAczcyeNh CDethdo Ae dh UeAe TreseHmstoiOpg oaRnwsmIT eEeIrExsnhS ta i bU tirntu "ds1et.e"r e1 1to U "u.Ss.eC, .s §e l3l o6r3 (b) S 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 good 20 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 28 deference. See In re Lahijiani, 325 B.R. 282, 289 (B.A.P. 9th Cir. 2005); see also In re

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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 6 in the J&J Litigation and earned in the 7 BSC Litigation, plus costs, on terms that are fair to the Estate. Finally, the Agreement is 8 the product of the Trustee's arms-length negotiations with N&O. N&O is already 9 representing other plaintiffs in the Mesh Litigation and is familiar with the litigation. N&O 10 was willing to undertake the prosecution of the Mesh Litigation for the Clients on terms P 11 that were satisfactory to the Trustee. There is a valid business justification for the L 2 MILEY WANG-EKVALL, L 3200 Park Center Drive, Suite 250 Costa Mesa, California 92626 1000 • Fax 714 445Tel 714 445--100 111111234567 AEAglgisrreesaeem mDBee.. nnMtt, i ulalenTt1nrdh1d.he e ertUF h M 1oC.eS1ero A. stCuUhhgre..r tS§seL M.ee iC3t mair6.ge y3e§aa n( Ats3fit)oou 6 insnt3h s (iFnbo, r )trth.eih ze ee e Ca btnhoeduesr t CAti nslsethseaoirrgue nolsdtmf s aA eounnft hytth o oLerfii z eEtehns esttha Eeate nsa.d ts aS sItnieegte'nse m DrIeneestcnetlstar u erUansntdtisode neri n rtoh fe S 18 As noted earlier, the Agreement provides that any creditors of the Debtor that may 19 hold an interest in the Debtor's future recovered attorneys' fees may only assert such 20 interests against the Estate Allocation. These claims are unique to the Debtor. Simply 21 put, creditors can only assert their claims and interests against the Debtor, not against 22 N&O or the N&O Allocation. To make clear that these creditors' potential interests are 23 only against the Estate Allocations, the Trustee seeks Court approval to authorize the 24 assignment contemplated in the Agreement to be free and clear of any liens, claims and 25 interests under 11 U.S.C. § 363(f). 26 The Court can authorize the assignment of the Estate's interests in the Mesh 27 Litigation free and clear of any liens, claims and interests under 11 U.S.C. § 363(f). 28 Section 363(f) provides the following:

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1 (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 2 estate, only if— 3 (1) applicable nonbankruptcy law permits sale of such property free and clear of such interest; 4 (2) such entity consents; 5 (3) such interest is a lien and the price at which such property is to 6 be sold is greater than the aggregate value of all liens on such property; 7 (4) such interest is in bona fide dispute; or 8 (5) such entity could be compelled, in a legal or equitable 9 proceeding, to accept a money satisfaction of such interest 10 Because 11 U.S.C. § 363(f) is written in the disjunctive, the Court may authorize P 11 the assignment free and clear of any interests if any of the conditions are met. L 2 MILEY WANG-EKVALL, L 3200 Park Center Drive, Suite 250 Costa Mesa, California 92626 1000 • Fax 714 445Tel 714 445--100 111111234567 f3esBra6ie.tRht3eise.( affr2)a n(5ac5Tdt,t)h i l4oc"ae5nlrwe e C a(oq Boorfu r.uoiiA trarsfet .t aPs icnen .at tqyh9enu atr lheiiatet y sutCnh,tt .shiei"rn,o .r cerC2wil za0blheei0emia c8,arh s)o s .C ts rah hiTntgehadhn ann emitnno Cteetnhenlade rOtleer ifeobsuo ftttrb sodtneh roiu a ecotn h orCEde,u eso Ilpntrdma oc 1tbm.se1 esv' es Ui.fbr oKci.inSlriinactt.eyuelC rpCdoe.f fose§t,ot dr ss3 e(a o6iI ncnmp3c rt(reeohfe) pvep( Pi5t rd Mo)mWe.c eso ,eSs nLfehoeeLd rcyLCi tna iiito)gn i,gn , 3 a 9ti1o n S 18 proceeding where the nondebtor could be forced to accept money satisfaction of its 19 interest. Under California Commercial Code § 9610(a), "[a]fter default, a secured party 20 may sell…or otherwise dispose of any or all the collateral in its present condition or 21 following any commercially reasonable preparation or processing." See California 22 Commercial Code § 9610(a). Further, "[a] secured party shall apply…the cash proceeds 23 of disposition under Section 9610... [to] the satisfaction of obligations secured by the 24 security interest…[and] the satisfaction of obligations secured by any subordinate 25 security interest…" See California Commercial Code § 9615(a). Here, because any 26 party that potentially holds a security interest in the Estate's fees from the Mesh Litigation 27 can be compelled to accept a money satisfaction under California Commercial Code 28 §§ 9610(a) and 9615(a), 11 U.S.C. § 363(f)(5) applies. Thus, the Court may authorize

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1 the assignment contemplated in the Agreement free and clear of any liens, claims and 2 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 J&J Litigation fees and 5 BSC Litigation fees and all of its costs. This result greatly benefits the Estate 6 and will likely yield a recovery for the Estate that is greater than what the Estate would 7 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 Clients, the Agreement will provide 10 the Clients with the opportunity to continue with reputable and experienced counsel P 11 through the proposed representation. Moreover, the Clients will be represented by L 2 MILEY WANG-EKVALL, L 3200 Park Center Drive, Suite 250 Costa Mesa, California 92626 1000 • Fax 714 445Tel 714 445--100 111111234567 cb pthoereous pnto esirndrettCFeyel Rr .wro ,e BhtushPontes lier6 Wso s0t fhaas0 atl ihr4tvnehe(e ahe crcd) a c loypisoe frhfun oa1 rtcvms4to i.do-i lDlleriaadsatree y twrrh saSai tloth tai ts "hyt[ hase Se]trnaw eM ytoies erFeddso. eh"ur r nt LGhatii tuliii vgnttheha oneFtir RoteizhnBxien.pP g iiTrn a6thvht0ouieo0lsu n4u,n (tsohtheaf)e ,r 1 i yssA4 ap gAdlereapet,iy etpoisomrr on alee pfcntaerotis rami eset menoin tfer tynh coeef d S 18 against the Debtor, it is in the best interests of the Clients to resolve any uncertainty they 19 may have concerning who is representing them. Because the Mesh Litigation is ongoing, 20 resolving any confusion as quickly as possible is in the best interest of the clients. 21 Waiver of the stay under FRBP 6004(h) will further preserve the amount of fees the 22 Estate can expect to collect pursuant to the Agreement. For these reasons, waiver of the 23 FRBP 6004(h) stay is appropriate. 24 25 IV. CONCLUSION 26 Accordingly, the Trustee respectfully requests that the Court enter an order 27 providing for the following relief: 28 1. Granting the Motion;

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1 2. Authorizing the Trustee to enter into the Agreement; 2 3. Approving the terms of the Agreement, a copy of which is attached hereto 3 as Exhibit "1"; 4 4. Authorizing the Trustee to execute any documents or take any actions 5 reasonably necessary to effectuate the terms of the Agreement; 6 5. Approving the transaction as contemplated in the Agreement pursuant to 7 11 U.S.C. § 363(b); 8 6. Authorizing and ordering the assignment and transfer of any rights or 9 payment to property as contemplated in the Agreement to be free and clear of all claims, 10 liens, encumbrances, or other interests against the Debtor pursuant to 11 U.S.C. § 363(f); P 11 7. Authorizing and ordering that any asserted claims, liens, encumbrances, or L 2 MILEY WANG-EKVALL, L 3200 Park Center Drive, Suite 250 Costa Mesa, California 92626 1000 • Fax 714 445Tel 714 445--100 111111234567 oNautnn&hydOe epr r aA inc89rltotlo..en ncretearrsastit,co sFFmtn ,iia ;nnet go ddmariitnnib,n ggeos rrtttshh ot,haa tahett tte NthDor&ewren ObiFset eeoyisd;sr e,nw rionailtlsl aaiRdstuetsalruecsm h,o aifon fEngfill vyiaai dnttoeey sn tl,hic aoeebr Ei 5lei0tsmi2etap(std leoo) yfAp etlrhleooestce aEtchtstieiotoarnnet esoa, fn f,to dhwr e nha oeDtttto ehtroben treto hyre,- or S 18 client privilege and work-product set forth in the Agreement apply; 19 10. Authorizing the waiver of the 14-day period under FRBP 6004(h); and 20 11. For such other relief as the Court may deem just and necessary. 21 22 DATED: May ___, 2021 Respectfully submitted, 23 SMILEY WANG-EKVALL, LLP 24 25 By: 26 LEI LEI WANG EKVALL Attorneys for Elissa D. Miller, Chapter 7 27 Trustee 28

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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 Girardi 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 the 9 Transition and Assignment of the Estate's Interests in the Mesh Litigation to Nadrich & 10 Cohen LLP and The Oshman Firm, LLC, Free and Clear of Liens, Claims and Interests P 11 Pursuant to 11 U.S.C. § 363 (the "Motion"). Unless otherwise defined in this declaration, L 2 MILEY WANG-EKVALL, L 3200 Park Center Drive, Suite 250 Costa Mesa, California 92626 1000 • Fax 714 445Tel 714 445--100 111111234567 arpaciaglrslo sshtteietessrstc ma.ot 2 n sftT. hc thdheeeee so f egiDfn Socmeelaibidnyelt c nooicnetfros ' tsmmu'h nrceyyisgu dMeahrrilptso-estpctno,io uot I ei snncimsx ltiamipeomrlnnoeeetsr nsied nt w, iica tnohiott ehneprpl e eytpo hn oobredfases isnmtgeeigba dyl ina m lhih wttyiaeog trf hotieiernefmi rntstser sta br w pvnwyire seaitorfhweseri irs ttplrio aierrn weosugft le ewfttiirhcrmaemtesena s dDcte-ee.wen l. ybsI it nuthtor r oairtnh'rnsdges ep ftereh rtna osdt oitnhmgee S 18 or all of the pending cases to protect the clients' rights. 19 3. The Debtor was counsel of record for approximately 52 plaintiffs in the 20 Mesh Litigation. I recently entered into the Transition Agreement on behalf of the Estate 21 whereby I agreed to transfer the Estate's interest in the Mesh Litigation to N&O. A true 22 and correct copy of the Agreement is attached hereto as Exhibit "1." 23 4. I am informed that N&O is already representing other plaintiffs in the Mesh 24 Litigation and is familiar with the litigation and has the requisite expertise and resources 25 essential to prosecute the Mesh Litigation. 26 5. In my opinion and based on my business judgment, the Agreement is in 27 the best interest of the Estate, because it is reasonable and will likely yield a recovery for 28

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1 the Estate that is greater than what the Estate would recover litigating a quantum meruit 2 claim. 3 6. The Agreement is the product of the Trustee's arms-length negotiations with 4 N&O. 5 7. In sum, I believe there is valid business justification for the Agreement, as 6 the Agreement will result in the best outcome for the Estate and the Debtor's clients. 7 I declare under penalty of perjury under the laws of the United States of America 8 that the foregoing is true and correct. June 9 Executed on this __1_s_t_ day of Mxxaxyx, 2021, at Los Angeles, California. 10 P 11 MILEY WANG-EKVALL, LL 3200 Park Center Drive, Suite 250 Costa Mesa, California 92626 1000 • Fax 714 445Tel 714 445--1002 111111234567 ELISSA D. MILLER S 18 19 20 21 22 23 24 25 26 27 28

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EXHIBIT "1"

25

26

27

28

29

30

31

32

33

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EXHIBIT "2"

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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 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 I G nI RreA RDI KEESE, C OPPCTOTCROAUOhaRRasAR RDUDTepNTSEREH tNeEUSRRTEro IA M T7MGA.T NI 2ORUORAT:TU2TANN T0IHSN UOA-OTObTANN EkIRLL N-DETB2I GZSO '1RASIE 0 NT SFC2M5GRIS20LTOU I-0ETIGBOT3SH RNIU-NTO2E MNE (N 2cDEE. )8F' NESA(ORbT NER) O SDXA EF S A L S THE ESTATE'S INTERESTS IN THE 18 MESH LITIGATION TO NADRICH & Debtor. COHEN LLP AND THE OSHMAN FIRM, 19 LLC, FREE AND CLEAR OF LIENS, CLAIMS AND INTERESTS PURSUANT 20 TO 11 U.S.C. § 363 21 22 The Court, having reviewed and considered the Trustee's Ex Parte Motion to File 23 Under Seal Pursuant to LBR 5003-2(c) and Court Manual Section 2.8(b) as to the 24 Trustee's Motion for Order Authorizing the Transition and Assignment of the Estate's 25 Interests in the Mesh Litigation to Nadrich & Cohen LLP and The Oshman Firm, LLC, 26 Free and Clear of Liens, Claims and Interests Pursuant to 11 U.S.C. § 363 (the "Ex Parte 27 Motion"), and finding good cause appearing therefor, 28 IT IS ORDERED that:

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1 1. The Ex Parte Motion is granted; 2 2. The Trustee is authorized to file the unredacted version of the Motion for 3 Order Authorizing the Transition and Assignment of the Estate's Interests in the Mesh 4 Litigation to Nadrich & Cohen LLP and The Oshman Firm, LLC, Free and Clear of Liens, 5 Claims and Interests Pursuant to 11 U.S.C. § 363 (the "Motion") under seal, with the filing 6 date reflected in the Court's docket, pursuant to Local Bankruptcy Rule 5003-2(c), and 7 such documents shall remain under seal until further order of this Court: 8 3. The Trustee is authorized to partially redact versions of the Motion and the 9 attached Agreement. 10 ### P 11 L 2 MILEY WANG-EKVALL, L 3200 Park Center Drive, Suite 250 Costa Mesa, California 92626 Tel 714 445-1000 • Fax 714 445-100 111111234567S 18 19 20 21 22 23 24 25 26 27 28

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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): TRUSTEE'S EX PARTE MOTION TO FILE UNDER SEALURSUANT TO LBR 5003-2(c) AND COURT MANUAL SECTION 2.8(b) AS TO THE TRUSTEE'S MOTION FOR ORDER UTHORIZING THE TRANSITION AND ASSIGNMENT OF THE ESTATE'S INTERESTS IN THE MESH LITIGATION TO ADRICH & COHEN LLP AND THE OSHMAN FIRM, LLC, FREE AND CLEAR OF LIENS, CLAIMS AND INTERESTS URSUANT TO 11 U.S.C. § 363; MEMORANDUM OF POINTS AND AUTHORITIES AND DECLARATIONS OF ELISSA D. ILLER AND JEFFREY NADICH IN SUPPORT 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 17, 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 17, 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 17, 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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