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Full title: Motion For Order Authorizing Chapter 7 Trustee To: (A) Operate The Business Of The Debtor On A Limited Basis Pursuant To 11 U.S.C. § 721; and (B) Maintain Current Status Of Any Newly Discovered Trust Accounts Memorandum Of Points And Authorities; Declaration Of Elissa D. Miller In Support with Proof of Service Filed by Trustee Elissa Miller (TR) (Strok, Philip) (Entered: 06/18/2021)

Document posted on Jun 17, 2021 in the bankruptcy, 27 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

The Trustee previously determined that, in addition to deposit and operating18 accounts, the Debtor maintained accounts at the following banks2: 19 (1) Citizens Business Bank – blocked minor accounts, IOLTA (State Bar Trust20 Accounts) and a trust account for the benefit of four clients; 21 (2) Torrey Pines Bank – blocked minors accounts; and 22 (3) Citibank – a blocked settlement account.Fax 71 14 liability and contents insurance so that the Trustee and her team can access Building 2, a, C 00   es 10 15 the servers, and the internet to: (1) transition files, physical and electronic, to successor M 5‐ osta  4 44 16 counsel, co-counsel, and/or clients; (2) access information to prepare and file the C 1 7 el   T 17 bankruptcy schedules and statement of financial affairs; and (3) preserve and access 18 information and files in order to protect and/or monetize the Estate's rights to costs and 19 fees owing to the Debtor for services rendered and costs advanced pre-petition; 20 (2) Authority to retain and pay certain former employees of the Debtor, as21 independent contractors on an hourly basis, to assist the Trustee with the limited 22 operations described in this Motion; and 23 (3) Authority to pay such other necessary costs to assist with the Trustee's24 limited operations described in this Motion and to vacate Building 2 when it becomes 25 necessary.The Trustee seeks authority to pay former employees and other operating 27 expenses from unencumbered funds in the Estate or pursuant to Court order authorizing 1 D.Should the Trustee's investigation reveal any newly discovered IOLTA, minors8 blocked, settlement blocked or other trust bank accounts beyond the Existing Trust 9 Accounts, the Trustee requests authority to allow such accounts to remain at the current 10 banks provided that such bank is an approved depository and subject to confirmation by 11 the United States Trustee's Office that such bank is appropriately collateralized.The Trustee is also still continuing to 23 transition the Debtor's cases, and it appears that there are additional cases in which the 24 Trustee can assert a right to legal fees and costs.

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Document Contents

1 SMILEY WANG-EKVALL, LLP Lei Lei Wang Ekvall, State Bar No. 163047 2 lekvall@swelawfirm.com Philip E. Strok, State Bar No. 169296 3 pstrok@swelawfirm.com Timothy W. Evanston, State Bar No. 319342 4 tevanston@swelawfirm.com 3200 Park Center Drive, Suite 250 5 Costa Mesa, California 92626 Telephone: 714 445-1000 6 Facsimile: 714 445-1002 7 Attorneys for Elissa D. Miller, Chapter 7 Trustee 8 UNITED STATES BANKRUPTCY COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 LOS ANGELES DIVISION 11 In re Case No. 2:20-bk-21022-BR 2  00 12 92626  4 445‐1 13 G IRARDI KEESE, C hapter 7 alifornia  •  Fax 71 14 Debtor. MCHOATPIOTNE RF O7 RT ROURSDTEERE A TUOT: HORIZING a, C 00   es 10 15 (A) OPERATE THE BUSINESS OF THE osta M 4 445‐ 16 DPUEBRTSOUARN OTN T AO L1I1M UIT.SED.C .B §A 7S2IS1 ; AND C 1 7 el   T 17 (B) MAINTAIN CURRENT STATUS OF ANY NEWLY DISCOVERED TRUST 18 ACCOUNTS 19 MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION OF 20 ELISSA D. MILLER IN SUPPORT 21 [No hearing required pursuant to Local Bankruptcy Rule 9013-1(o)] 22 23 24 25 26 27

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1 TABLE OF CONTENTS Pag 2 3 I. INTRODUCTION .................................................................................................... 4 II. FACTUAL BACKGROUND ..................................................................................... 5 A. The Debtor's Bankruptcy Case ..................................................................... 6 B. The Debtor's Cases ...................................................................................... 7 C. The Debtor's Bank Accounts ........................................................................ 8 E. The Debtor's Record System ....................................................................... 9 F. The Trustee's Prior Operating Motions and Second Cash CollateralMotion .......................................................................................................... 10 III. LIMITED OPERATING RELIEF REQUESTED ....................................................... 11 A. The Requested Relief Regarding the Resolved Cases ................................ 2 00 12 92626  4 445‐1 13 B. The Requested Relief Regarding the Terminated Cases ............................. alifornia  •  Fax 71 14 C. AOdpdeirtaiotnioanl sR ..e..q..u..e..s..t.e..d.. .R..e..l.i.e..f. .R...e..g.a..r..d..in..g.. .t.h..e.. .T...r.u..s..te..e..'.s.. .L..i.m...it.e..d........................ a, C 00   es 10 15 D. The Requested Relief Regarding the Debtor's Legal Fees and Costs ....... 1M 5‐ osta  4 44 16 IV. LIMITED TRUST ACCOUNT MAINTENANCE RELIEF REQUESTED ................ 1C 1 7 el   T 17 V. MEMORANDUM OF POINTS AND AUTHORITIES ............................................. 118 VI. CONCLUSION ...................................................................................................... 119 20 21 22 23 24 25 26 27

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1 TABLE OF AUTHORITIES 2 Pag 3 CASES  4 In re Nakhuda, 5 2015 WL 873566 (B.A.P. 9th Cir. 2015) ................................................................ 16 7 STATUTES  8 11 U.S.C. § 303(g) ............................................................................................................. 9 11 U.S.C. § 363 ................................................................................................................. 10 11 U.S.C. § 721 ....................................................................................................... 2, 6, 111 2 00 12 RULES  92626  4 445‐1 13 Fed. R. Bankr. P. 1007(k) .................................................................................................. alifornia  •  Fax 71 14 Fed. R. Bankr. P. 4001(b) .................................................................................................. a, C 00   es 10 15 M 5‐ osta  4 44 16 TREATISES  C 1 7 el   T 17 6 Collier on Bankruptcy ¶ 721.01 (Alan N. Resnick & Henry J. Sommer eds., 16th ed. 2012) ............................................................................................................... 118 19 20 21 22 23 24 25 26 27

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1 TO THE HONORABLE BARRY RUSSELL, UNITED STATES BANKRUPTCY JUDGE: 2 Elissa D. Miller, the chapter 7 trustee (the "Trustee") for the bankruptcy estate (th3 "Estate") of Girardi Keese (the "Debtor"), submits this Motion for Order Authorizing 4 Chapter 7 Trustee to: (A) Operate the Business of the Debtor on a Limited Basis 5 Pursuant to 11 U.S.C. § 721; and (B) Maintain Current Status of any Newly Discovered 6 Trust Accounts (the "Motion"). In support of the Motion, the Trustee submits the followin7 memorandum of points and authorities and the attached declaration of Elissa D. Miller. 8 9 I. INTRODUCTION 10 The Court should grant the Motion as the requested relief is necessary, narrowly11 tailored and in the best interest of the Estate, its creditors and the Debtor's clients. The 2 00 12 Trustee has made extraordinary progress since the Trustee's prior motions requesting 92626  4 445‐1 13 authority to operate the business of the Debtor on a limited basis were granted. With alifornia  •  Fax 71 14 authority to operate, the Trustee has been able to successfully transition a significant a, C 00   es 10 15 number of the Debtor's cases, resulting in the protection of both clients and the Debtor's M 5‐ osta  4 44 16 interests in its legal fees and costs. Similarly, the Trustee has safeguarded the Debtor's C 1 7 el   T 17 rights to attorneys' fees and costs in certain of the Debtor's former cases by filing notices18 of lien. In addition, the Trustee has disbursed funds owed to clients as certain cases are19 resolved. In short, operation of the Debtor's business on a limited basis has allowed the 20 Trustee to enhance the value of the Estate and ensure that clients remain protected. 21 The Court previously authorized the Trustee to operate the Debtor on a limited 22 basis through July 13, 2021. That date is fast approaching, and more work remains to b23 done. The Trustee is not seeking to expand her authority but, rather, to continue the 24 authority previously granted by the Court and recognized as essential to administer the 25 Estate. The continuation of the Trustee's authority is critical and any interruption to the 26 Trustee's limited authority to operate will upend the Trustee's progress and prejudice 27 interested parties. Authority to operate on a limited basis will enable the Trustee to

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1 the Trustee's progress in administering the Estate. For these reasons, the Motion shoul2 be granted. 3 4 II. FACTUAL BACKGROUND 5 A. The Debtor's Bankruptcy Case 6 The Debtor was once a thriving law firm based in Los Angeles, California. On 7 December 18, 2020 (the "Petition Date"), petitioning creditors Jill O'Callahan, as 8 successor in interest to James O'Callahan, Robert M. Keese, John Abassian, Erika 9 Saldana, Virginia Antonio, and Kimberly Archie (collectively, the "Petitioning Creditors") 10 filed an involuntary chapter 7 bankruptcy petition against the Debtor.1 Prior to the 11 Petition Date, the Debtor practiced in the areas of personal injury, defective products, 2 00 12 sexual abuse, toxic torts, business law, employment law, and aviation law. 92626  4 445‐1 13 On December 24, 2020, the Petitioning Creditors filed a Motion for Appointment oalifornia  •  Fax 71 14 Interim Trustee Pursuant to 11 U.S.C. § 303(g) [Docket No. 12]. The Court entered an a, C 00   es 10 15 order granting the motion on January 5, 2021 [Docket No. 45]. On January 6, 2021, the M 5‐ osta  4 44 16 Trustee was appointed as the interim trustee [Docket No. 50]. C 1 7 el   T 17 On January 13, 2021, the Court entered an Order Directing: (1) The Clerk of Cour18 to Immediately Enter an Order for Relief under Chapter 7; (2) The United States Trustee 19 to Immediately Appoint a Chapter 7 Trustee; (3) The Debtor to File All Schedules and 20 Related Documentation for Chapter 7 Case within Fourteen Days of the Entry of this 21 Order; and (4) Vacating February 16, 2021 Status Conference [Docket No. 68]. On 22 January 13, 2021, the Clerk of Court entered an order for relief against the Debtor 23 [Docket No. 69], and the Trustee was appointed and accepted her appointment in the 24 Debtor's case [Docket No. 71]. 25 26 27 1 The Petitioning Creditors also filed an involuntary chapter 7 bankruptcy petition against Thomas Girardi, which is currently pending as Bankruptcy Case No. 2:20-bk-21020-BR (the "Thomas Girardi Bankruptcy Case").

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1 On February 5, 2021, the Trustee filed her Motion for Order (1) Extending and/or 2 Establishing Deadline to File Schedules and Statement of Financial Affairs; and (2) 3 Authorizing Chapter 7 Trustee to Prepare and File Schedules and Statement of Financial 4 Affairs Pursuant to Federal Rule of Bankruptcy Procedure 1007(k) [Docket No. 164] (the 5 "Schedules Motion"). On February 24, 2021, the Court entered an order granting the 6 Schedules Motion [Docket No. 220]. The Trustee's current deadline to file the schedules7 and statement of financial affairs on behalf of the Debtor is August 24, 2021. 8 B. The Debtor's Cases 9 As of the Petition Date, the Debtor was counsel of record in a significant number 10 cases which were undertaken on a contingency basis. These cases were at varying 11 stages. Among the cases are those that have settled or where settlement is imminent, 2 00 12 and those that have been reduced to judgment (collectively, the "Resolved Cases"). 92626  4 445‐1 13 There are also cases where clients of the Debtor have terminated or will terminate their alifornia  •  Fax 71 14 relationship and have engaged or will engage substitute counsel (collectively, the a, C 00   es 10 15 "Terminated Cases"). M 5‐ osta  4 44 16 C. The Debtor's Bank Accounts C 1 7 el   T 17 The Trustee previously determined that, in addition to deposit and operating18 accounts, the Debtor maintained accounts at the following banks2: 19 (1) Citizens Business Bank – blocked minor accounts, IOLTA (State Bar Trust20 Accounts) and a trust account for the benefit of four clients; 21 (2) Torrey Pines Bank – blocked minors accounts; and 22 (3) Citibank – a blocked settlement account. 23 These IOLTA, blocked and other trust accounts are collectively referred to as the24 "Existing Trust Accounts." The Trustee continues to investigate whether other bank 25 accounts exist. See Declaration of Elissa D. Miller. 26 2 The Debtor also maintained small IOLTA accounts at Nano Bank, Wells Fargo Bank and U.S. 27 Bank. Each of those accounts were closed, either by the bank upon learning of the case or at the request of the Trustee because the bank would not change the signatory. The funds are separately identified and have been placed in a segregated account under the Trustee's control.

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1 D. The Debtor's Law Offices 2 For over 20 years, the Debtor operated out of two buildings located in Los 3 Angeles, California. One building is located at 1122 Wilshire Boulevard, Los Angeles, 4 California ("Building 1"), and the other is located at 1126 Wilshire Boulevard, Los 5 Angeles, California ("Building 2"). The buildings are linked through hallways allowing for 6 interior access between the buildings, even though the buildings are separately owned b7 non-Debtor parties. 8 The Estate continued to occupy both Building 1 and Building 2 post-bankruptcy. 9 Each of the buildings housed attorneys and staff and included storage and other space t10 support the Debtor's practice. Building 1 was recently sold and the Trustee has vacated 11 the premises, disposed of over 7 truckfuls of waste, and moved the majority of its 2 00 12 remaining contents to Building 2. Building 2 is currently listed for sale and provides only 92626  4 445‐1 13 a temporary storage solution for the Trustee. alifornia  •  Fax 71 14 E. The Debtor's Record System a, C 00   es 10 15 Prior to the Petition Date, the Debtor stored and maintained its case files inM 5‐ osta  4 44 16 physical and electronic record systems. However, the electronic files may not be a C 1 7 el   T 17 duplicate of the physical files, and vice versa. The digital records were stored on two 18 different programs depending on the type of case. For mass tort litigation cases, the 19 Debtor stored its records and files in a proprietary electronic program. For all other case20 and general office files, the Debtor stored its records and files in an electronic program 21 called iManage. Finally, cost ledgers and other related records were maintained in 22 another program called Sage Accounting Software. The Trustee has relied on former 23 employees of the Debtor in order to navigate the Debtor's complicated file and record 24 system more efficiently. See Declaration of Elissa D. Miller. 25 F. The Trustee's Prior Operating Motions and Second Cash Collateral26 Motion 27 On February 2, 2021, the Trustee filed a Motion for Order Authorizing Chapter 7

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1 § 721 and Maintain Current Status of Certain Trust Accounts and for Other Relief [Docke 2 No. 156] (the "First Operating Motion"). On March 2, 2021, the Court entered an order3 granting the First Operating Motion [Docket No. 235], authorizing the Trustee operate th4 business of the Debtor for a period of six months starting from the date of the Trustee's5 appointment on January 13, 2021. Thus, the Trustee has authority to operate the6 business of the Debtor through July 13, 2021. The order, a copy of which is attached as 7 Exhibit "1," also granted certain relief related to the Existing Trust Accounts. 8 On February 10, 2021, the Trustee filed a Motion for Order Authorizing Chapter 7 9 Trustee to Operate the Business of the Debtor on a Limited Basis Pursuant to 11 U.S.C. 10 § 721 Pursuant to Cash Collateral Stipulation and Budget and to Retain and Pay Debtor'11 Former Employees as Independent Contractors in Accordance Therewith [Docket No. 2 00 12 180] (the "Second Operating Motion"). The Trustee filed the Second Operating Motion92626  4 445‐1 13 concurrently with an Application for Order Setting Hearing on Shortened Notice. Onalifornia  •  Fax 71 14 February 16, 2021, the Court entered an order granting the Second Operating Motiona, C 00   es 10 15 through July 13, 2021 [Docket No. 194]. A copy of the order granting the SecondM 5‐ osta  4 44 16 Operating Motion is attached as Exhibit "2." C 1 7 el   T 17 On March 30, 2021, the Trustee filed the Chapter 7 Trustee's Second Motion for 18 Order Approving Stipulations for Use of Cash Collateral and Authorizing Use of Cash 19 Collateral Pursuant to 11 U.S.C. § 363 and Federal Rule of Bankruptcy Procedure 20 4001(b) ("Second Cash Collateral Motion") [Docket No. 287]. On April 14, 2021, the 21 Court entered an interim order granting the Second Cash Collateral Motion [Docket No. 22 307]. On May 7, 2021, the Court entered a final order granting the Second Cash 23 Collateral Motion [Docket No. 329]. Currently, the Trustee has authority to use cash 24 collateral through and including June 30, 2021. The Trustee anticipates filing in the near25 future a third motion for authority to use cash collateral to fund the necessary expenses 26 of the Debtor's limited operations. 27

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1 III. LIMITED OPERATING RELIEF REQUESTED 2 As noted above, the Court has entered orders authorizing the Trustee to operate3 the business of the Debtor on a limited basis through July 13, 2021. The Trustee seeks 4 authority to continue operating the business of the Debtor on a limited basis for an 5 additional six months – through January 13, 2022 - without prejudice to the Trustee's 6 right to request additional or continuing authority to operate. The Trustee is seeking 7 authority to operate the business of the Debtor consistent with the scope previously 8 granted by the Court as detailed below. 9 A. The Requested Relief Regarding the Resolved Cases 10 With respect to the Resolved Cases, the Trustee seeks authority to take all11 reasonable actions and execute all documents necessary to issue to clients their agreed2 00 12 upon portion of funds remitted to the Debtor and/or Trustee related to the Resolved 92626  4 445‐1 13 Cases. This authorization would include, without limitation, authority for the Trustee to alifornia  •  Fax 71 14 continue to: a, C 00   es 10 15 (1) Accept and negotiate funds and/or payments made to the Debtor and/orM 5‐ osta  4 44 16 Trustee on behalf of a client(s); C 1 7 el   T 17 (2) Negotiate and pay any liens (e.g. medical liens, attorney's liens, etc.)18 required to effectuate the release of funds and/or payments;3 19 (3) Issue to a client(s) the agreed-upon portion of any funds and/or payments20 made to the Debtor and/or Trustee on behalf of a client(s) consistent with applicable 21 agreements; 22 (4) In the Trustee's sole discretion and upon the Trustee's confirmation of23 proper amounts, issue to co-counsel and/or referral attorneys the agreed-upon portion of24 attorney fees and costs consistent with applicable agreements; 25 26 27 3 The Trustee is not seeking authorization to pay liens against property of the Debtor's Estate, only those liens specific to the Resolved Cases at issue such as medical liens and only after receiving and reviewing proper documentation as to the lien holder and the amount of the lien.

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1 (5) Take any other reasonable actions and execute all documents necessary t2 effectuate the issuance of funds and/or payments to the Debtor's client(s); and 3 (6) Hold in the Estate the funds remaining after payment to the client(s), co-4 counsel and/or referral attorneys which would include the Debtor's fees and costs 5 consistent with applicable agreements. 6 B. The Requested Relief Regarding the Terminated Cases 7 With respect to the Terminated Cases, the Trustee seeks authority to take all8 reasonable actions and execute all documents necessary to protect the client's interest i9 having files transitioned to the client and preserve the Estate's interest in legal fees and 10 costs to which the Estate is entitled. This authorization would include, without limitation, 11 authority for the Trustee to continue to: 2 00 12 (1) Upon request, transfer files to the client(s), or new counsel upon92626  4 445‐1 13 appropriate proof of engagement; alifornia  •  Fax 71 14 (2) Execute any documents reasonably necessary to effectuate a substitutiona, C 00   es 10 15 of attorney or disassociation of counsel; M 5‐ osta  4 44 16 (3) Employ file clerks or IT personnel, as independent contractors, to facilitateC 1 7 el   T 17 the transfer of client files to the client(s) or successor counsel; 18 (4) Maintain appropriate insurance, including liability insurance;19 (5) Take any other reasonable actions and execute all documents necessary t20 effectuate the orderly transition of client files; and 21 (6) Take all reasonable actions to protect and preserve the legal fees and cost22 to which the Estate is entitled including, without limitation, the filing of notices of lien for 23 legal fees and costs. 24 C. Additional Requested Relief Regarding the Trustee's Limited25 Operations 26 As detailed above, the Debtor stored its files physically (in Building 1 and Building27 2) and also electronically. Since the Court's prior authorization to retain and employ

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1 relied on their knowledge of the Debtor's record and file system in order to locate files 2 more expeditiously. The former employees' assistance has had a positive impact on the 3 Trustee's administration of the Estate, as their involvement has made it easier to navigat4 the Debtor's operations and finances, and has helped the Trustee transition case files of 5 former clients for their protection. Moreover, these former employees have been 6 invaluable to the Trustee's efforts to vacate Building 1 and relocate to Building 2. The 7 Trustee also anticipates that she will need to vacate Building 2 in the near future. 8 In order to continue to access records, the Trustee needs to be able to pay those 9 costs associated with operating Building 2. The Trustee also needs to be able to pay 10 insurance and bond fees so that the former employees can safely access Building 2 (an11 consequently access the books and records), and to limit any exposure to the Estate. 2 00 12 More specifically, the Trustee seeks: 92626  4 445‐1 13 (1) Authority to pay the utilities, internet, and other necessary systems andalifornia  •  Fax 71 14 liability and contents insurance so that the Trustee and her team can access Building 2, a, C 00   es 10 15 the servers, and the internet to: (1) transition files, physical and electronic, to successor M 5‐ osta  4 44 16 counsel, co-counsel, and/or clients; (2) access information to prepare and file the C 1 7 el   T 17 bankruptcy schedules and statement of financial affairs; and (3) preserve and access 18 information and files in order to protect and/or monetize the Estate's rights to costs and 19 fees owing to the Debtor for services rendered and costs advanced pre-petition; 20 (2) Authority to retain and pay certain former employees of the Debtor, as21 independent contractors on an hourly basis, to assist the Trustee with the limited 22 operations described in this Motion; and 23 (3) Authority to pay such other necessary costs to assist with the Trustee's24 limited operations described in this Motion and to vacate Building 2 when it becomes 25 necessary. 26 The Trustee seeks authority to pay former employees and other operating 27 expenses from unencumbered funds in the Estate or pursuant to Court order authorizing

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1 D. The Requested Relief Regarding the Debtor's Legal Fees and Costs 2 As requested in the First Operating Motion, the Trustee also seeks authority to file3 notices of lien for legal fees and costs of the Debtor in cases where the Debtor was 4 counsel of record should she deem it necessary in her sole and absolute discretion. 5 6 IV. LIMITED TRUST ACCOUNT MAINTENANCE RELIEF REQUESTED 7 Should the Trustee's investigation reveal any newly discovered IOLTA, minors8 blocked, settlement blocked or other trust bank accounts beyond the Existing Trust 9 Accounts, the Trustee requests authority to allow such accounts to remain at the current 10 banks provided that such bank is an approved depository and subject to confirmation by 11 the United States Trustee's Office that such bank is appropriately collateralized. 2 00 12 With respect to any newly discovered minors blocked accounts, the Debtor has n92626  4 445‐1 13 interest in the funds, although they are under the Debtor's Tax ID Number. The Debtor'salifornia  •  Fax 71 14 only obligation is to sign a release upon proof that the beneficiary is 18 years old. The a, C 00   es 10 15 Trustee is requesting authority to delegate that function to the bank so that the Estate haM 5‐ osta  4 44 16 no obligation whatsoever with respect to these accounts. See Declaration of Elissa D. C 1 7 el   T 17 Miller. In fact, the accounts are a liability because they are interest bearing, and the 18 Debtor has to report the income, notwithstanding the income runs with the account to the19 minor. As the Estate has no property interest in these accounts, the Trustee contends 20 that if the bank takes over the authority, the Estate should not bear the obligation of 21 having to post a bond for the funds in these minors accounts. 22 With respect to any newly discovered IOLTA, settlement blocked and/or other trus23 bank accounts, the Trustee seeks an order authorizing the Trustee to designate the 24 Trustee as the sole signatory and directing the banks where the accounts are held to 25 comply with the Trustee's change of signatory requests. The Trustee will ensure that the26 amount of her bond is not only sufficient to cover the amounts in her account but also th27 amounts in the IOLTA accounts and all other accounts wherever maintained. See

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1 V. MEMORANDUM OF POINTS AND AUTHORITIES 2 Under 11 U.S.C. § 721, "[t]he court may authorize the trustee to operate the3 business of the debtor for a limited period, if such operation is in the best interest of the 4 estate and consistent with the orderly liquidation of the estate." See also In re Nakhuda,5 2015 WL 873566 at *2 (B.A.P. 9th Cir. 2015) citing 11 U.S.C. § 721 and 6 Collier on 6 Bankruptcy ¶ 721.01 (Alan N. Resnick & Henry J. Sommer eds., 16th ed. 2012). 7 Authorizing the Trustee to operate the business of the Debtor on a limited basis is8 in the best interest of the Estate and promotes an orderly liquidation. See Declaration of 9 Elissa D. Miller. The relief requested as to the Resolved Cases will allow the Debtor's 10 clients to continue to receive funds to which they are entitled without significant delay. 11 Moreover, disbursement of client funds will allow the Trustee to preserve and set aside 2 00 12 legal fees and costs owed to the Debtor. The Trustee's request for continued authority t92626  4 445‐1 13 file notices of lien in certain of the Debtor's cases similarly preserves the Debtor's legal alifornia  •  Fax 71 14 fees and costs. With respect to the relief requested regarding the Terminated Cases, tha, C 00   es 10 15 Trustee's continued authority to transition client files and sign substitutions of attorney noM 5‐ osta  4 44 16 only promotes the orderly transition of the Terminated Cases—it also protects the C 1 7 el   T 17 Debtor's former clients. 18 The Trustee's requests are not extraordinary and have been previously granted b19 the Court. The Trustee is not seeking authority to do anything that the Court has not 20 previously approved. Moreover, the Trustee's requests are necessary. The Trustee is 21 currently in the process of preparing the Debtor's schedules and statement of financial 22 affairs, which are due on August 24, 2021. The Trustee is also still continuing to 23 transition the Debtor's cases, and it appears that there are additional cases in which the 24 Trustee can assert a right to legal fees and costs. If the Trustee is not authorized to 25 operate the business of the Debtor for the limited purposes described herein, the Truste26 will be unable to successfully transition cases over to new counsel, prejudicing clients. 27 The Trustee may also be unable to complete the schedules and statement of financial

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1 legal fees and costs by losing access to case files and cost ledgers. By operating the 2 Debtor, the Trustee has made significant strides in preserving the Estate. The Motion 3 only serves to continue this progress. In sum, continued operation of the Debtor's 4 business is necessary for the Trustee to continue to maximize value of the Estate, 5 administer the Estate, and protect the Debtor's former clients. 6 7 VI. CONCLUSION 8 For the foregoing reasons, the Trustee respectfully requests that the Court enter9 an order: 10 1. Granting the Motion; 11 2. Authorizing the Trustee to operate the business of the Debtor on a limited2 00 12 basis as detailed in the Motion for a period of six months from July 13, 2021 - through 92626  4 445‐1 13 January 13, 2022 - without prejudice to the Trustee's right to request additional or alifornia  •  Fax 71 14 continuing authority to operate; a, C 00   es 10 15 3. Authorizing any newly discovered IOLTA, minors blocked, settlementM 5‐ osta  4 44 16 blocked and/or other trust bank accounts to remain open at the current banks where the C 1 7 el   T 17 accounts are held, subject to the conditions set forth herein; 18 4. Authorizing the Trustee to be the sole signatory on any newly discovered19 IOLTA, settlement blocked and/or other trust bank accounts, and any other account 20 where the bank requires a Court order to change the signatory and directing the banks t21 comply with the Trustee's change of signatory requests; 22 5. Authorizing the Trustee to delegate the authority for the release of funds in23 any newly discovered minors blocked accounts to the banks where the accounts are hel24 and excusing the Trustee from posting a bond for the funds held in such minors blocked 25 accounts, or alternatively, authorizing the Trustee to sign off on the liquidation of the 26 account upon receipt of proper documentation from the beneficiary; and 27

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1 6. For such other relief as the Court deems just and proper. 2 3 DATED: June 18, 2021 Respectfully submitted, 4 SMILEY WANG-EKVALL, LLP 5 6 By: 7 PHILIP E. STROK Attorneys for Elissa D. Miller, Chapter 7 8 Trustee 9 10 11 2 00 12 92626  4 445‐1 13 alifornia  •  Fax 71 14 a, C 00   es 10 15 M 5‐ osta  4 44 16 C 1 7 el   T 17 18 19 20 21 22 23 24 25 26 27

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1 DECLARATION OF ELISSA D. MILLER 2 I, Elissa D. Miller, declare as follows: 3 1. I am the duly appointed chapter 7 trustee for the bankruptcy estate of 4 Girardi Keese. I am also a partner at the law firm SulmeyerKupetz, a Professional 5 Corporation. I know each of the following facts to be true of my own personal knowledge6 except as otherwise stated and, if called as a witness, I could and would competently 7 testify with respect thereto. I make this declaration in support of the Motion for Order 8 Authorizing Chapter 7 Trustee To: (A) Operate the Business of the Debtor on a Limited 9 Basis Pursuant to 11 U.S.C. § 721; and (B) Maintain Current Status of Any Newly 10 Discovered Trust Accounts (the "Motion"). Unless otherwise defined in this declaration, 11 all terms defined in the Motion are incorporated herein by this reference. 2  00 12 2. As of the Petition Date, the Debtor was counsel of record in a significant 92626  4 445‐1 13 number of cases which were undertaken on a contingency basis. These cases were at alifornia  •  Fax 71 14 varying stages. I previously caused the First Operating Motion to be filed so that I could a, C 00   es 10 15 deal with these cases and with various bank accounts [Docket No. 156]. On March 2, M 5‐ osta  4 44 16 2021, the Court entered an order granting the First Operating Motion. A true and correctC 1 7 el   T 17 copy of the order granting the First Operating Motion is attached as Exhibit "1." 18 3. When I first visited the Debtor's offices, I learned that the Debtor maintaine19 its case files physically and electronically. I am informed that the electronic files may not20 be a duplicate of the physical files and vice versa. Regarding the digital records, they 21 were maintained on two different programs depending on the type of cases. The Debtor 22 used a proprietary electronic program for its mass tort litigation cases. However, for all 23 other cases and general office files, the Debtor stored these records in an electronic 24 program known as iManage. The Debtor's cost ledgers and other related records were 25 maintained in another program called Sage Accounting Software. 26 4. Because the Debtor's records were stored in a complicated fashion and 27 were not easy to locate, I determined that it would be more economical and efficient for

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1 Debtor's data and file maintenance processes. Accordingly, I caused the Second 2 Operating Motion to be filed so that I could retain and pay certain of the Debtor's former 3 employees, as well as pay the utilities and insurance so that these files and records coul4 remain accessible [Docket No. 180]. On February 16, 2021, the Court entered an order 5 granting the Second Operating Motion. A true and correct copy of the order granting the 6 Second Operating Motion is attached as Exhibit "2." 7 5. Since the order was entered granting the Second Operating Motion, I have 8 continued to rely on certain former employees of the Debtor, who have helped me and 9 my field agent more efficiently navigate the Debtor's complicated file and record system. 10 6. I have been collecting information as to the Debtor's bank accounts. To 11 date, I have identified that the Debtor maintained accounts at a minimum of five banks. 2  00 12 The accounts include: (1) general firm accounts; (2) those labeled as client trust account92626  4 445‐1 13 whether or not they truly are such; (3) State Bar of California IOLTA accounts; (4) about alifornia  •  Fax 71 14 100 minors blocked accounts at Citizen Business Bank; and (5) a blocked settlement a, C 00   es 10 15 account at Citibank. As of this date, these are the only accounts I have been able to M 5‐ osta  4 44 16 identify. C 1 7 el   T 17 7. Specifically, I have determined that in addition to deposit and operating 18 accounts, the Debtor maintained the following accounts at the following banks: 19 i. Citizens Business Bank – blocked minor accounts, IOLTA 20 (State Bar Trust Accounts) and a trust account for the benefit 21 of four clients; 22 ii. Torrey Pines Bank – minors accounts; and 23 iii. Citibank – a blocked settlement account. 24 8. I have also determined that the Debtor maintained small IOLTA accounts a25 Nano Bank, Wells Fargo Bank and U.S. Bank. These bank accounts have since been 26 closed, either by the bank after learning of the Debtor's case or at my request because 27 the bank would not change the signatory. The funds from these accounts are separately

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1 9. My investigation as to whether other bank accounts exist is ongoing. 2 10. If I later discover any minors blocked accounts, I am informed and believe 3 that neither the Debtor nor the Estate has any interest in these accounts. Rather, the 4 Debtor was and the Estate is obligated to (1) sign off on the delivery of the funds in the 5 account to the beneficiary when the beneficiary turns 18 and (2) account for the income 6 earned on the accounts on its tax returns, notwithstanding that the interest income inure7 to the benefit of the beneficiary. 8 11. Regarding any newly discovered IOLTA, settlement blocked, and/or other 9 trust bank accounts, I will ensure that the amount of my bond is sufficient to cover the 10 amounts in these accounts. 11 12. In my business judgment and for the reasons set forth in the Motion, I 2 00 12 believe operating the Debtor's business on a limited basis as set forth in the Motion is in 92626 4 445-1 13 the best interest of the Estate and promotes orderly liquidation of the Estate's assets. alifornia • Fax 71 14 I declare under penalty of perjury under the laws of the United States of America a, C00 es10 15 that the foregoing is true and correct. M5- osta 4 44 16 Executed on this _1_6_t_h day of June, 2021, at Los Angeles, California. C71 el T 17 18 Elissa D. Miller 19 20 21 22 23 24 25 26 27

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EXHIBIT "1"

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1 SMILEY WANG-EKVALL, LLP Lei Lei Wang Ekvall, State Bar No. 163047 2 lekvall@swelawfirm.com FILED & ENTERED Philip E. Strok, State Bar No. 169296 3 pstrok@swelawfirm.com Timothy W. Evanston, State Bar No. 319342 MAR 02 2021 4 tevanston@swelawfirm.com 3200 Park Center Drive, Suite 250 5 Costa Mesa, California 92626 CLERK U.S. BANKRUPTCY COURT Telephone: 714 445-1000 Central District of California 6 Facsimile: 714 445-1002 BY t o l i v e r DEPUTY CLERK7 Attorneys for Elissa D. Miller, Chapter 7 Trustee 8 UNITED STATES BANKRUPTCY COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 LOS ANGELES DIVISION 11 MILEY WANG-EKVALL, LLP 3200 Park Center Drive, Suite 250 Costa Mesa, California 92626 el 714 445-1000 • Fax 714 445-1002 1111123456 IGnI RreA RDI KEESE, Debtor. CCOOTBLUSIRTahU.RRMSsaAUSDD.IepCTTSIEE NtNEUe.TRR Er§DoES S 7GA.E 7 OB S2U2R T:AF 12TAOO S 0HCANF -IOOESbN TTkR PIRDPHN-TE2I UEGZMA1RR I 0ANDIAMNS2IGETNO2 UTBE -TCATBRT ATIHNRUOOHIAT NSNRE P TT C FOT OUOEN R1RR A1R 7 E NT S T 17 ACCOUNTS AND FOR OTHER RELIEF 18 [No Hearing Requested Pursuant to Local Bankruptcy Rule 9013-1(o)] 19 20 21 On February 2, 2021, Elissa D. Miller, the Chapter 7 Trustee for the bankruptcy 22 estate of Girardi Keese, filed and served the Motion for Order Authorizing Chapter 7 23 Trustee to Operate the Business of the Debtor on a Limited Basis Pursuant to 11 U.S.C. 24 § 721 and Maintain Current Status of Certain Trust Accounts and for Other Relief [Docket25 No. 156] (the "Motion"), and notice of the Motion [Docket No. 157] (the "Notice"). No 26 opposition to or request for hearing on the Notice or the Motion was filed or served. 27 Having reviewed the Notice and the Motion and the papers filed in support thereof, 28 service being proper, and good cause appearing therefrom:

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1 IT IS ORDERED that: 2 1. The Motion is granted; 3 2. The Trustee is authorized, for a period of six months from the date the 4 Trustee accepted her appointment on January 13, 2021, to operate the business of the 5 Debtor on a limited basis as detailed in the Motion, including, but not limited to, issuing 6 checks to clients, co-counsel, and/or referral attorneys, upon the Trustee's confirmation of 7 proper amounts; 8 3. The IOLTA accounts, the minors blocked accounts and the settlement 9 blocked accounts are authorized to remain open at the current banks where the accounts 10 are held, subject to the conditions set forth in the Motion; 11 4. The Trustee is authorized to be the sole signatory on the IOLTA accounts, MILEY WANG-EKVALL, LLP 3200 Park Center Drive, Suite 250 Costa Mesa, California 92626 el 714 445-1000 • Fax 714 445-1002 1111123456 tccinhoh etuah rnseteg's etm 5to leo.irn mdfo eserirsgn tntTbo ablh octleocoh kcraTyeknr edurge dseaqt ceauthceceoec siuo stssn uia;gtn suant stnath,odt oo a tr rnhiyzde ea adbn nadtyon t kohdstee hw leebhgra eanartkceesc t othshuheena atal lcwu ccthohoemourrnepitt lystyh faweor riebt ht ahh nteehk ledr er ,eT letqhrauuessi rebtee asoen f'ts khf usis na drse S T 17 authorized to release the funds without the Trustee's signature subject to the banks' 18 receipt of proper documentation from the beneficiary, and the Trustee is excused from 19 posting a bond for the funds held in such minors blocked accounts; or alternatively, the 20 Trustee is authorized to sign off on the liquidation of the account upon receipt of proper 21 documentation from the beneficiary. 22 ### 23 Date: March 2, 2021 24 25 26 27 28

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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 FILED & ENTERED Philip E. Strok, State Bar No. 169296 3 pstrok@swelawfirm.com Timothy W. Evanston, State Bar No. 319342 FEB 16 2021 4 tevanston@swelawfirm.com 3200 Park Center Drive, Suite 250 5 Costa Mesa, California 92626 CLERK U.S. BANKRUPTCY COURT Telephone: 714 445-1000 Central District of California 6 Facsimile: 714 445-1002 BY f o r t i e r DEPUTY CLERK7 Attorneys for Elissa D. Miller, Chapter 7 Trustee 8 UNITED STATES BANKRUPTCY COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 LOS ANGELES DIVISION 11 P 2 In re Case No. 2:20-bk-21022-BR MILEY WANG-EKVALL, LL 3200 Park Center Drive, Suite 250 Costa Mesa, California 92626 el 714 445-1000 • Fax 714 445-100 1111123456 GIRARDI KEESE, Debtor. COOTBLUCIRhU.ORRMSaUSDDL.IpCTSILEENtEe.TARR Er§DET S 7GAE 7EB SU2R RTA 1TAOAO SHPNLF IOSOU TTS PRIRPHTNESIUIEGZPRURI UNDAMASLEGTNOUABE TATCTT TINTHIOOOHOTANRNE PT C FOTAOAOENN S1RR DHA1 7 S T 17 BUDGET AND TO RETAIN AND PAY DEBTOR'S FORMER EMPLOYEES AS 18 INDEPENDENT CONTRACTORS IN ACCORDANCE THEREWITH 19 20 Date: February 16, 2021 Time: 2:00 p.m. 21 Ctrm.: 1668 via ZoomGov 255 E. Temple Street 22 Los Angeles, CA 90012 23 Web Address: https://cacb.zoomgov.com/j/1604415586 24 Meeting ID: 1604415586 Password: 123456 25 Telephone: (669) 254-5252 (San Jose) (646) 828-7666 (New York) 26 27 28

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1 On February 16, 2021, at 2:00 p.m., the above-captioned Court held a hearing on 2 the Motion for Order Authorizing Chapter 7 Trustee to Operate the Business of the 3 Debtor on a Limited Basis Pursuant to 11 U.S.C. § 721 Pursuant To Cash Collateral 4 Stipulation And Budget And To Retain And Pay Debtor's Former Employees As 5 Independent Contractors In Accordance Therewith (the "Motion")1 [Docket No. 180] filed 6 by Elissa D. Miller, the Chapter 7 Trustee (the "Trustee") for the bankruptcy estate (the 7 "Estate") of Girardi Keese. Appearances were as noted on the Court's record. Having 8 considered the Motion and the pleadings, declarations, and exhibits filed in support 9 thereof and opposition thereto, and the statements and arguments of counsel on the 10 record at the hearing on the Motion, finding that notice and service of the Motion were 11 proper and that no further notice be given, and finding good cause for the relief requested P 2 MILEY WANG-EKVALL, LL 3200 Park Center Drive, Suite 250 Costa Mesa, California 92626 el 714 445-1000 • Fax 714 445-100 1111123456 imn othneth MsI12T o..fr toIiSom nH ,tTT hE hheRee dE MTaBtroeYut s itOohteneRe iD Tsis rEGu aRsRutEetAhDeNo atrThiczEaceDted: ;p pteudrs huearn at ptop o1i1n tUm.eSn.Ct o. n§ J7a2n1u, aforyr a1 3p,e 2ri0o2d1 o, ft os ixS T 17 operate the business of the Debtor on a limited basis as detailed in the Motion without 18 prejudice to the Trustee's right to request an extension from the Court; 19 3. The Trustee is authorized to retain and pay on a weekly basis the W-920 employees identified in the Motion and such other W-9 employees as the Trustee 21 22 23 24 25 26 27 1 Capitalized terms not otherwise defined herein shall have the meanings ascribed to them in the 28 Motion.

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1 requires to perform the services contemplated by the Motion, so long as the total amount 2 paid is within the amount projected in the Budget plus any Court-authorized variance; and 3 4 4.The Trustee is authorized to pay insurance, utilities, bond fees and other 5 necessary costs as set forth in the Motion and in accordance with the Budget plus any 6 Court-authorized variance. 7 ### 8 9 10 11 P 2 MILEY WANG-EKVALL, LL 3200 Park Center Drive, Suite 250 Costa Mesa, California 92626 el 714 445-1000 • Fax 714 445-100 1111123456 S T 17 18 19 20 21 22 23 Date: February 16, 2021 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): MOTION FOR ORDER AUTHORIZING CHAPTER 7 RUSTEE TO: (A) OPERATE THE BUSINESS OF THE DEBTOR ON A LIMITED BASIS PURSUANT TO 11 U.S.C. § 721; ND (B) MAINTAIN CURRENT STATUS OF ANY NEWLY DISCOVERED TRUST ACCOUNTS MEMORANDUM OF POINTND AUTHORITIES; DECLARATION OF ELISSA D. MILLER IN SUPPORT will be served or was served (a) on the judge in hambers 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 18, 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 18, 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 18, 2021 Gabriela Gomez-Cruz /s/ Gabriela Gomez-Cruz Date PrintedName Signature

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

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