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Full title: Declaration re: of Philip E. Strok in Support of Stipulation Authorizing Payment of Client's Settlement Funds and Fees to be Disbursed to the Estate with Proof of Service Filed by Trustee Elissa Miller (TR) (RE: related document(s)418 Stipulation By Elissa Miller (TR) and R. Bradley by and Through Their Attorneys to Authorize Payment of Client's Settlement Funds and Fees to be Disbursed by the Estate with Proof of Service). (Strok, Philip) (Entered: 06/22/2021)

Document posted on Jun 21, 2021 in the bankruptcy, 5 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

I am informed that, post-petition, the Client signed a settlement agreement 9 which provides for a gross settlement amount (the "Settlement Amount") in exchange for10 releases and a dismissal of the Client's claims against the Defendant with prejudice.The Trustee is not the Client's counsel, 20 has never appeared in the Case, and therefore, is unable to file the notice of dismissal, a21 copy of which is attached to the Stipulation as Exhibit “1.” 22 7. Robinson Calcagnie, Inc. ("RC"), as counsel of record for a number of othe23 plaintiffs in the JCCP, has agreed to associate in the Case solely for the purpose of filing24 the notice of dismissal, as an accommodation to the Trustee, on the condition that the 25 Client acknowledges that no attorney-client relationship is established between RC and 26 the Client as a result of RC’s association and filing of the notice of dismissal. SERVED BY UNITED STATES MAIL: n (date) June 22, 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.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.

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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 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 DSUECPPLAORRAT TOIOF NS TOIPF UPLHAILTIIPO NE. STROK INs0 15 AUTHORIZING PAYMENT OF CLIENT'S e1 M5- SETTLEMENT FUNDS AND FEES TO a 4 ost4 4 16 BE DISBURSED TO THE ESTATE C71 Debtor. el 17 [No Hearing Required] T 18 19 20 21 I, Philip E. Strok, declare: 22 1. I am a partner with Smiley Wang-Ekvall, LLP, attorneys for Elissa D. Miller,23 Chapter 7 Trustee of the bankruptcy estate of Girardi Keese (the "Trustee"). I am 24 licensed to practice before this Court and the courts of the State of California. I know 25 each of the following facts to be true of my own personal knowledge, except as otherwis26 stated and, if called as a witness, I could and would competently testify with respect 27 thereto. I make this declaration in support of the Stipulation Authorizing Payment of

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1 Unless otherwise defined in this declaration, all terms defined in the Stipulation are 2 incorporated herein by this reference. 3 2. I am informed that, pre-petition, the Debtor, which was retained by the 4 Client pursuant to a contingency fee retainer, commenced an action on the Client's behal5 in the Los Angeles County Superior Court against Janssen Pharmaceuticals, Inc., Case 6 No. BC 576110 (the "Case"), which is included in Risperdal and Invega Judicial Counsel 7 Coordinated Proceeding, JCCP 4775 (the "JCCP"). 8 3. I am informed that, post-petition, the Client signed a settlement agreement 9 which provides for a gross settlement amount (the "Settlement Amount") in exchange for10 releases and a dismissal of the Client's claims against the Defendant with prejudice. 11 4. The Trustee recently received funds from the Defendant, after $1,000.00 2 0 0 92626 4 445-1 1123 was wi5th. held Atoc pcoaryd cinogm tmo othne f usnigdn ecods rtest.a iner agreement between the Debtor and the ornia ax 71 a, Calif00 • F 14 Client, the agreed-upon contingency fee is 40% of the total Settlement Amount. In s0 15 addition, according to the books and records of the Debtor, the Debtor agreed to waive e1 M5- a 4 ost4 4 16 costs. The Trustee is prepared to issue the balance of the Settlement Amount, net of thC1 7 el 17 common fund costs and the 40% fee, to the Client. T 18 6. A notice of dismissal with prejudice is required to be filed in the Case now 19 that the Settlement Amount has been issued. The Trustee is not the Client's counsel, 20 has never appeared in the Case, and therefore, is unable to file the notice of dismissal, a21 copy of which is attached to the Stipulation as Exhibit “1.” 22 7. Robinson Calcagnie, Inc. ("RC"), as counsel of record for a number of othe23 plaintiffs in the JCCP, has agreed to associate in the Case solely for the purpose of filing24 the notice of dismissal, as an accommodation to the Trustee, on the condition that the 25 Client acknowledges that no attorney-client relationship is established between RC and 26 the Client as a result of RC’s association and filing of the notice of dismissal. 27

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1 I declare under penalty of perjury under the laws of the United States of America 2 that the foregoing is true and correct to the best of my knowledge. 3 Executed on this 22nd day of June, 2021, at Costa Mesa, California. 4 /s/ Philip E. Strok 5 PHILIP E. STROK 6 7 8 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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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): DECLARATION OF PHILIP E. STROK IN SUPPORT OF TIPULATION AUTHORIZING PAYMENT OF CLIENT'S SETTLEMENT FUNDS AND FEES TO BE DISBURSED TO THE STATE) will be served or was served (a) on the judge in chambers in the form and manner required by LBR 5005-2(d); and (b 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 22, 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 22, 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 22, 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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