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Full title: Declaration re: Redacted- Declaration Of Jason Luckasevic In Support Of: Omnibus Reply In Support Of Trustee's: (A) Motion For Order Authorizing the Transition and Assignment Of The Estate's Interests In The NFL Concussion Litigation to Goldberg Persky White P.C. Free and Clear of Liens, Claims and Interests Pursuant to 11 U.S.C. § 363; and (B) 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. § 363 with Proof of Service Filed by Trustee Elissa Miller (TR) (RE: related document(s)389 Motion for Order Authorizing the Transition and Assignment of the Estate's Interests in the NFL Concussion Litigation to Goldberg Persky White P.C. Free and Clear of Liens, Claims and Interests Pursuant to 11 U.S.C. Secton 363; Memorandum of Poi, 428 Motion (REDACTED) 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. Se). (Strok, Philip) (Entered: 08/03/2021)

Document posted on Aug 2, 2021 in the bankruptcy, 8 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

As of the time of bankruptcy filing, Debtor was in material breach of its4 obligation to pay costs under the Letter of Agreement and as of that date GPW paid over5 $1.9 million in costs throughout the NFL Concussion Litigation.Currently, players need assistance in simpl22 evaluating their past medical history, scheduling evaluations, submitting claims and later 23 defending their claim throughout the claims process.Based on my direct involvement with the first former NFL player cases, 27 familiarity with the Settlement and ongoing work for current GPW clients, I am well 28 qualified to be approved to receive assignment of the representation of the Debtor client PROOF OF SERVICE OF DOCUMENT am over the age of 18 and not a party to this bankruptcy case or adversary proceeding. true and correct copy of the foregoing document entitled (specify): DECLARATION OF JASON LUCKASEVIC IN UPPORT OF OMNIBUS REPLY IN SUPPORT OF TRUSTEE'S: (A) MOTION FOR ORDER AUTHORIZING THE RANSITION AND ASSIGNMENT OF THE ESTATE'S INTERESTS IN THE NFL CONCUSSION LITIGATION TO OLDBERG PERSKY WHITE P.C.FREE AND CLEAR OF LIENS, CLAIMS AND INTERESTS PURSUANT TO 11 .S.C. § 363; AND (B) MOTION FOR ORDER AUTHORIZING THE TRANSITION AND ASSIGNMENT OF THE STATE'S INTERESTS IN THE MESH LITIGATION TO NADRICH & COHEN LLP AND THE OSHMAN FIRM, LLC, REE AND CLEAR OF LIENS, CLAIMS AND INTERESTS PURSUANT TO 11 U.S.C. § 363 will be served or was erved (a) on the judge in chambers in the form and manner required by LBR 5005-2(d); and (b) in the manner stated elow: .TO

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1 SMILEY WANG-EKVALL, LLP Philip E. Strok, State Bar No. 169296 2 pstrok@swelawfirm.com Kyra E. Andrassy, State Bar No. 207959 3 kandrassy@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 – LOS ANGELES DIVISION 10 In re Case No. 2:20-bk-21022-BR 11 GIRARDI KEESE, Chapter 7 2  00 12 92626  4 445‐1 13 Debtor. DLUECCKLAARSAEVTIICO NIN O SFU JPAPSOORNT OF alifornia  •  Fax 71 14 OTRMUNSIBTUEES' SR:E PLY IN SUPPORT OF a, C 00   es 10 15 (A) MOTION FOR ORDER osta M 4 445‐ 16 AASUSTIHGONRMIZEINNTG O TFH ETH TER AESNTSAITTIOE'NS AND C 1 7 el   INTERESTS IN THE NFL CONCUSSION T 17 LITIGATION TO GOLDBERG PERSKY WHITE P.C. FREE AND CLEAR OF 18 LIENS, CLAIMS AND INTERESTS PURSUANT TO 11 U.S.C. § 363; AND 19 (B) MOTION FOR ORDER 20 AUTHORIZING THE TRANSITION AND ASSIGNMENT OF THE ESTATE'S 21 INTERESTS IN THE MESH LITIGATION TO NADRICH & COHEN LLP AND THE 22 OSHMAN FIRM, LLC, FREE AND CLEAR OF LIENS, CLAIMS AND 23 INTERESTS PURSUANT TO 11 U.S.C. § 363 24 Date: August 10, 2021 25 Time: 2:00 p.m. Ctrm.: 1668 26 255 E. Temple Street Los Angeles, California 90012 27 28

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1 DECLARATION OF JASON LUCKASEVIC 2 I, Jason Luckasevic, declare as follows: 3 1. I am an attorney at law duly licensed to practice in Pennsylvania, Arizona, 4 Michigan, and the Supreme Court of the United States. I am also a shareholder and 5 member of the advisory committee with Goldberg Pesky White P.C. I know each of the 6 following facts to be true of my own personal knowledge, except as otherwise stated and7 if called as a witness, I could and would competently testify with respect thereto. I make 8 this declaration in support of the Trustee's Omnibus Reply in Support of Trustee's: (A) 9 Motion for Order Authorizing the Transition and Assignment of the Estate's Interests in 10 the NFL Concussion Litigation to Goldberg Persky White P.C. Free and Clear of Liens, 11 Claims and Interests Pursuant to 11 U.S.C. § 363; and (B) Motion for Order Authorizing 2 00 12 the Transition and Assignment of the Estate's Interests in the Mesh Litigation to Nadrich 92626  4 445‐1 13 & Cohen LLP and The Oshman Firm, LLC, Free and Clear of Liens, Claims and Interestalifornia  •  Fax 71 14 Pursuant to 11 U.S.C. § 363 (the "Reply"). Unless otherwise defined in this declaration, a, C 00   es 10 15 all terms defined in the Reply are incorporated herein by this reference. M 5‐ Costa  14 44 16 2. I was the first lawyer to sue the National Football League (the “NFL”), 7 el   T 17 representing former players who suffered concussion injuries. In 2011, I commenced th18 NFL Concussion Litigation and have been extensively involved in the NFL Concussion 19 Litigation to this day. Pre-petition, the Debtor represented approximately 100 NFL 20 players in the NFL Concussion Litigation and in these cases GPW was named as co- 21 counsel of record. 22 3. The Debtor and GPW entered into a Letter of Agreement regarding the 23 prosecution of former NFL cases and the attorney fee sharing arrangements on or about24 December 26, 2012. Another firm, Russomano & Borrello, was also a party to the Letter25 of Agreement. A true and correct copy of the Letter of Agreement is attached to the 26 Reply as Exhibit "1." 27 4. The Letter of Agreement provided: fees to be shared depending mainly on28 the origination of the specific case, the Debtor to receive either of

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1 the attorneys' fees recovered after the payment of any referral fees, and that the Debtor 2 would be responsible for general litigation costs. 3 5. As of the time of bankruptcy filing, Debtor was in material breach of its4 obligation to pay costs under the Letter of Agreement and as of that date GPW paid over5 $1.9 million in costs throughout the NFL Concussion Litigation. 6 6. During the course of the NFL Concussion Litigation, the Court entered an 7 Order modifying all of the fee agreements for counsel for plaintiffs. Pursuant to the 8 Court's ruling, plaintiffs' counsel are only entitled to receive of all recoveries for their9 attorneys' fees, irrespective of what they were entitled to receive under their agreements10 with their clients. In addition, plaintiffs' counsel are also required to divert of any 11 amount they recover for their attorneys' fees to a common benefit fund. Thus, plaintiffs' 2 00 12 counsel will essentially receive only of any sum recovered. It remains to be ruled 92626  4 445‐1 13 upon who will ultimately receive the set-aside for the common benefit fund. alifornia  •  Fax 71 14 7. The Debtor entered into a loan agreement with Virage during the NFL a, C 00   es 10 15 Concussion Litigation. Under the loan agreement, Thomas Girardi agreed to guarantee M 5‐ osta  4 44 16 the Debtor's obligations. C 1 7 el   T 17 8. The NFL entered into a global settlement of the Concussion Litigation in 18 January 2017, but the settlement did not resolve all issues with respect to the player's 19 claims. Instead, a complex global protocol governs the settlement in the NFL 20 Concussion Litigation (the "Global Protocol"). Further, the settlement put in place a two- 21 party claim system wherein the NFL was one party having its own legal representation, 22 and each former NFL player was the other party, with independent legal representation. 23 9. Under the Global Protocol, a multi-factor formula is applied to calculate the 24 threshold amount of a player's claim. The formula looks at whether the player was alive 25 at a certain date. From this date, the player then has 65 years going forward to file a 26 claim for compensation for brain injury should he be diagnosed with one of the qualifying27 diagnoses from an approved physician. In addition, the formula also requires the player 28 to have played a certain number of seasons compared to the player's age, and consider

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1 the player's degree of injury. Once this information is compiled, it is input into the formul2 to calculate the amount of the player's claim. 3 10. Players are not automatically entitled to the claim amount determined unde4 the formula. In order for players to eventually receive any settlement proceeds, the 5 players must file an initial statement of claim after completion of a lengthy, complicated 6 test battery with two settlement-approved physicians. One evaluation in and off itself by 7 the neuropsychologist includes a six hours test battery. Should their evaluation result in 8 an approved qualifying diagnosis, then they must submit a claim to the claims 9 administrator, Brown Greer ("BG"). This process is filled with complications throughout 10 that requires navigating a 126 page settlement agreement and 374 Frequently Asked 11 Questions found on www.nflconcussionsettlement.com. It should be noted that only 2  00 12 1,300 former players out of a class of over 20,000 former players have received a 92626  4 445‐1 13 monetary award from this settlement claims process to date. alifornia  •  Fax 71 14 11. The claims administrator BG then performs an initial review of the claim a, C 00   es 10 15 after it is submitted. Based on the initial review, BG may either reject the claim, request M 5‐ osta  4 44 16 additional information from the claimant, or cite other issues. The NFL is entitled to C 1 7 el   T 17 appeal, and does often appeal, the determinations made by BG. In addition, BG is 18 entitled to assign review of the claim sua sponte to a panel of experts that are selected b19 the NFL. 20 12. Given the complicated process in submitting claims, much work remains fo21 plaintiffs' counsel under the Global Protocol. Currently, players need assistance in simpl22 evaluating their past medical history, scheduling evaluations, submitting claims and later 23 defending their claim throughout the claims process. 24 13. To date, our efforts have caused over 70 of the GPW law firm’s 400 plus 25 clients receiving a monetary award. 26 14. Based on my direct involvement with the first former NFL player cases, 27 familiarity with the Settlement and ongoing work for current GPW clients, I am well 28 qualified to be approved to receive assignment of the representation of the Debtor client

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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 JASON LUCKASEVIC IN UPPORT OF OMNIBUS REPLY IN SUPPORT OF TRUSTEE'S: (A) MOTION FOR ORDER AUTHORIZING THE RANSITION AND ASSIGNMENT OF THE ESTATE'S INTERESTS IN THE NFL CONCUSSION LITIGATION TO OLDBERG PERSKY WHITE P.C. FREE AND CLEAR OF LIENS, CLAIMS AND INTERESTS PURSUANT TO 11 .S.C. § 363; AND (B) MOTION FOR ORDER AUTHORIZING THE TRANSITION AND ASSIGNMENT OF THE STATE'S INTERESTS IN THE MESH LITIGATION TO NADRICH & COHEN LLP AND THE OSHMAN FIRM, LLC, REE AND CLEAR OF LIENS, CLAIMS AND INTERESTS PURSUANT TO 11 U.S.C. § 363 will be served or was erved (a) on the judge in chambers in the form and manner required by LBR 5005-2(d); and (b) in the manner stated elow: .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)August 3, 2021 I checked the CM/ECF docket for this bankruptcy case or adversary proceeding and determined that thllowing 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) ________ , I served the following persons and/or entities at the last known addresses in this bankruptcy caser adversary proceeding by placing a true and correct copy thereof in a sealed envelope in the United States mail, firstlass, postage prepaid, and addressed as follows. Listing the judge here constitutes a declaration that mailing to the judgill be completed no later than 24 hours after the document is filed. 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 followingersons and/or entities by personal delivery, overnight mail service, or (for those who consented in writing to such ervice method), by facsimile transmission and/or email as follows. Listing the judge here constitutes a declaration that ersonal delivery on, or overnight mail to, the judge will be completed no later than 24 hours after the document is filed. 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. August 3, 2021 Gabriela Gomez-Cruz /s/ Gabriela Gomez-Cruz Date PrintedName Signature

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O BE SERVED BY THE COURT VIA NOTICE OF ELECTRONIC FILING (NEF):  Kyra E Andrassy kandrassy@swelawfirm.com, lgarrett@swelawfirm.com;gcruz@swelawfirm.com;jchung@swelawfirm.com  Rafey Balabanian rbalabanian@edelson.com, docket@edelson.com  Michelle Balady mb@bedfordlg.com, leo@bedfordlg.com  Ori S Blumenfeld ori@marguliesfaithlaw.com, Helen@MarguliesFaithLaw.com;Angela@MarguliesFaithLaw.com;Vicky@MarguliesFaithLaw.com  Evan C Borges eborges@ggtriallaw.com, cwinsten@ggtriallaw.com  Richard D Buckley richard.buckley@arentfox.com  Marie E Christiansen mchristiansen@vedderprice.com, ecfladocket@vedderprice.com,marie-christiansen-4166@ecf.pacerpro.com  Jennifer Witherell Crastz jcrastz@hrhlaw.com  Ashleigh A Danker Ashleigh.danker@dinsmore.com, SDCMLFiles@DINSMORE.COM;Katrice.ortiz@dinsmore.com  Clifford S Davidson csdavidson@swlaw.com, jlanglois@swlaw.com;cliff-davidson-7586@ecf.pacerpro.com  Lei Lei Wang Ekvall lekvall@swelawfirm.com, lgarrett@swelawfirm.com;gcruz@swelawfirm.com;jchung@swelawfirm.com  Richard W Esterkin richard.esterkin@morganlewis.com  Timothy W Evanston tevanston@swelawfirm.com, gcruz@swelawfirm.com;lgarrett@swelawfirm.com;jchung@swelawfirm.com  Jeremy Faith Jeremy@MarguliesFaithlaw.com, Helen@MarguliesFaithlaw.com;Angela@MarguliesFaithlaw.com;Vicky@MarguliesFaithlaw.com  James J Finsten , jimfinsten@hotmail.com  Alan W Forsley alan.forsley@flpllp.com, awf@fkllawfirm.com,awf@fl-lawyers.net,addy.flores@flpllp.com  Eric D Goldberg eric.goldberg@dlapiper.com, eric-goldberg-1103@ecf.pacerpro.com  Andrew Goodman agoodman@andyglaw.com, Goodman.AndrewR102467@notify.bestcase.com  Suzanne C Grandt suzanne.grandt@calbar.ca.gov, joan.randolph@calbar.ca.gov  Steven T Gubner sgubner@bg.law, ecf@bg.law  Marshall J Hogan mhogan@swlaw.com, knestuk@swlaw.com  Sheryl K Ith sith@cookseylaw.com, sith@ecf.courtdrive.com  Razmig Izakelian razmigizakelian@quinnemanuel.com  Lillian Jordan ENOTICES@DONLINRECANO.COM, RMAPA@DONLINRECANO.COM  Lewis R Landau Lew@Landaunet.com  Daniel A Lev dlev@sulmeyerlaw.com, ccaldwell@sulmeyerlaw.com;dlev@ecf.inforuptcy.com  Elizabeth A Lombard elombard@zwickerpc.com, bknotices@zwickerpc.com  Craig G Margulies Craig@MarguliesFaithlaw.com, Vicky@MarguliesFaithlaw.com;Helen@MarguliesFaithlaw.com;Angela@MarguliesFaithlaw.com  Ron Maroko ron.maroko@usdoj.gov  Peter J Mastan peter.mastan@dinsmore.com, SDCMLFiles@dinsmore.com;Katrice.ortiz@dinsmore.com  Edith R. Matthai ematthai@romalaw.com, lrobie@romalaw.com  Kenneth Miller kmiller@pmcos.com, efilings@pmcos.com  Elissa Miller (TR) CA71@ecfcbis.com, MillerTrustee@Sulmeyerlaw.com;C124@ecfcbis.com;ccaldwell@sulmeyerlaw.com  Eric A Mitnick MitnickLaw@aol.com, mitnicklaw@gmail.com  Scott H Olson solson@vedderprice.com, scott-olson- 2161@ecf.pacerpro.com,ecfsfdocket@vedderprice.com,nortega@vedderprice.com  Carmela Pagay ctp@lnbyb.com  Leonard Pena lpena@penalaw.com, penasomaecf@gmail.com;penalr72746@notify.bestcase.com  Michael J Quinn mquinn@vedderprice.com, ecfladocket@vedderprice.com,michael-quinn-2870@ecf.pacerpro.com  David M Reeder david@reederlaw.com, secretary@reederlaw.com  Ronald N Richards ron@ronaldrichards.com, morani@ronaldrichards.com  Kevin C Ronk Kevin@portilloronk.com, Attorneys@portilloronk.com  Frank X Ruggier frank@ruggierlaw.com, enotice@pricelawgroup.com

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 William F Savino wsavino@woodsoviatt.com, lherald@woodsoviatt.com  Kenneth John Shaffer johnshaffer@quinnemanuel.com  Richard M Steingard , awong@steingardlaw.com  Philip E Strok pstrok@swelawfirm.com, gcruz@swelawfirm.com;1garrett@swelawfirm.com;jchung@swelawfirm.com  Boris Treyzon bt@treyzon.com, sgonzales@actslaw.com  United States Trustee (LA) ustpregion16.la.ecf@usdoj.gov  Eric D Winston ericwinston@quinnemanuel.com  Christopher K.S. Wong christopher.wong@arentfox.com, yvonne.li@arentfox.com  Timothy J Yoo tjy@lnbyb.com

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