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Full title: Stipulation By Erika Girardi and Elissa D. Miller, Chapter 7 Trustee Filed by Interested Party Erika Girardi (Attachments: # 1 Proposed Order to Extend Briefing Schedule on Motion for Reconsideration # 2 Proof of Service) (Borges, Evan) (Entered: 06/28/2021)

Document posted on Jun 27, 2021 in the bankruptcy, 3 pages and 0 tables.

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Facsimile: (310) 277-3325 5 Attorneys for Elissa D. Miller, Chapter 7 Trustee 6 EVAN C. BORGES, State Bar No. 128706 EBorges@GGTrialLaw.com 7 GREENBERG GROSS LLP 650 Town Center Drive, Suite 1700 8 Costa Mesa, California 92626 Granting Chapter 7 Trustee’s Application to Employ the Law Offices of Ronald Richards & 3 Associates, A.P.C. as Special Litigation Counsel (the “Stipulation”) is entered into by and betwee 4 Elissa D. Miller, chapter 7 trustee (“Trustee”) for bankruptcy debtor Girardi Keese, and party-in-5 interest Erika Girardi (“Ms. Girardi”), by and through their attorneys of record herein, based on 6 the following facts: 7 A. On June 24, 2021, Ms. Girardi filed her Notice of Motion and Motion for 8 Reconsideration of Order Granting Chapter 7 Trustee’s Application to Employ the Law Offices of 9 Ronald Richards & Associates, A.P.C. as Special Litigation Counsel [Dkt.B. On June 25, 2021, this Court issued its Order on “Notice of Motion and Motion fo12 Reconsideration of Order Granting Chapter 7 Trustee’s Application to Employ the Law Offices of13Ronald Richards & Associates, A.P.C. as Special Litigation Counsel” [Dkt. 438], ordering any 14 opposition to the Motion be filed on or before 4:00 p.m. on Friday, July 2, 2021, and any reply to 15 any opposition be filed on or before 4:00 p.m. on Friday, July 9, 2021.

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1 RONALD N. RICHARDS, State Bar No. 176246 ron@ronaldrichards.com 2 LAW OFFICES OF RONALD RICHARDS & ASSOCIATES, A.P.C. P.O. Box 11480 3 Beverly Hills, California 90213 Telephone: (310) 556-1001 4 Facsimile: (310) 277-3325 5 Attorneys for Elissa D. Miller, Chapter 7 Trustee 6 EVAN C. BORGES, State Bar No. 128706 EBorges@GGTrialLaw.com 7 GREENBERG GROSS LLP 650 Town Center Drive, Suite 1700 8 Costa Mesa, California 92626 Telephone: (949) 383-2800 9 Facsimile: (949) 383-2801 10 Attorneys for Party-in-Interest Erika Girardi 11 UNITED STATES BANKRUPTCY COURT 12 CENTRAL DISTRICT OF CALIFORNIA, LOS ANGELES DIVISION 13 In re Case No. 2:20-bk-21022-BR 14 GIRARDI KEESE, Chapter 7 15 Debtor. STIPULATION [AND [PROPOSED] ORDE TO EXTEND BRIEFING SCHEDULE ON 16 MOTION FOR RECONSIDERATION OF ORDER GRANTING CHAPTER 7 17 TRUSTEE’S APPLICATION TO EMPLOY THE LAW OFFICES OF RONALD 18 RICHARDS & ASSOCIATES, A.P.C. AS SPECIAL LITIGATION COUNSEL 19 [Related to ECF Nos. 437 and 438] 20 21 Judge: Hon. Barry Russell 22 23 24 25 26 27

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1 This Stipulation to Extend Briefing Schedule on Motion for Reconsideration of Order 2 Granting Chapter 7 Trustee’s Application to Employ the Law Offices of Ronald Richards & 3 Associates, A.P.C. as Special Litigation Counsel (the “Stipulation”) is entered into by and betwee 4 Elissa D. Miller, chapter 7 trustee (“Trustee”) for bankruptcy debtor Girardi Keese, and party-in-5 interest Erika Girardi (“Ms. Girardi”), by and through their attorneys of record herein, based on 6 the following facts: 7 A. On June 24, 2021, Ms. Girardi filed her Notice of Motion and Motion for 8 Reconsideration of Order Granting Chapter 7 Trustee’s Application to Employ the Law Offices of 9 Ronald Richards & Associates, A.P.C. as Special Litigation Counsel [Dkt. 437] (the “Motion”); 10 and 11 B. On June 25, 2021, this Court issued its Order on “Notice of Motion and Motion fo12 Reconsideration of Order Granting Chapter 7 Trustee’s Application to Employ the Law Offices of13 Ronald Richards & Associates, A.P.C. as Special Litigation Counsel” [Dkt. 438], ordering any 14 opposition to the Motion be filed on or before 4:00 p.m. on Friday, July 2, 2021, and any reply to 15 any opposition be filed on or before 4:00 p.m. on Friday, July 9, 2021. 16 NOW, THEREFORE, following discussions between counsel, the Trustee and Ms. Girardi17 stipulate and agree to entry of an order extending the current briefing schedule for 14 days, as 18 follows: 19 1. The deadline for any opposition to the Motion shall be extended from Friday, July 20 2, 2021, to on or before 4:00 p.m. on Friday, July 16, 2021; 21 2. The deadline for any reply to any opposition to the Motion shall be extended from 22 Friday, July 9, 2021, to on or before 4:00 p.m. on Friday, July 23, 2021; 23 3. No further pleadings will be allowed; and 24 4. The Court will determine whether to set the matter for hearing after reviewing any 25 opposition and/or reply. 26 27

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1 Respectfully submitted, 2 DATED: June_2_8, 2021 LAW OFFICES OF RONALD RICHARDS & ASSOCIATES, A.P.C. 3 4 5 By: Ronald N. Richards 6 Special Litigation Counsel to Elissa D. Miller, Chapter 7 Trustee 7 8 DATED: June 28, 2021 GREENBERG GROSS LLP 9 10 11 By: Evan C. Borges 12 Attorneys for Party-in-Interest Erika Girardi 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27

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