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Full title: Declaration re: of Kyra E. Andrassy in Support of Stipulation Authorizing Payment of Client's Settlement Funds and Fees and Expenses to be Disbursed to the Estate with Proof of Service Filed by Trustee Elissa Miller (TR) (RE: related document(s)604 Stipulation By Elissa Miller (TR) and Benjamin Langfur, and Mary Alexander & Associates, P.C. to Authorize Payment of Client's Settlement Funds and Fees and Expenses to be Disbursed to the Estate with Proof of Service). (Andrassy, Kyra) (Entered: 08/17/2021)

Document posted on Aug 16, 2021 in the bankruptcy, 5 pages and 0 tables.

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I am informed that the retention agreement between the Debtor and the 10 Client provided that the Debtor would receive a percentage of the total recovery from its 11 representation of the Client, plus costs.el 17 based on the Client's settlement amount relative to the settlement amounts to be T 18 received by other plaintiffs represented by the Debtor, and the Debtor's contingency fee, 19 the Client would have been entitled to receive the balance. The amount of the Second Payment, even if paid 100% to the Client, 26 without the deduction of any apportioned costs to the Estate and the contingency fee to 27 the Estate, would still be less than the total amount that the Client would have received 28 1 had the Client received the net balance due to the Client from the First Payment 2 combined with the net balance due to Client from the Second Payment. true and correct copy of the foregoing document entitled (specify): DECLARATION OF KYRA E. ANDRASSY IN UPPORT OF STIPULATION AUTHORIZING PAYMENT OF CLIENT'S SETTLEMENT FUNDS AND FEES AND XPENSES TO BE DISBURSED TO THE ESTATE will be served or was served (a) on the judge in chambers in the fornd manner required by LBR 5005-2(d); and (b) in the manner stated below: .P. 5 and/or controlling LBR, on (date) , I served the following ersons and/or entities by personal delivery, overnight mail service, or (for those who consented in writing to such servicethod), by facsimile transmission and/or email as follows.

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Document Contents

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 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 s0 15 DECLARATION OF KYRA E. e1 M5- ANDRASSY IN SUPPORT OF a 4 ost4 4 16 STIPULATION AUTHORIZING C71 PAYMENT OF CLIENT'S SETTLEMENT el 17 FUNDS AND FEES AND EXPENSES TO T BE DISBURSED TO THE ESTATE 18 Debtor. [No Hearing Required] 19 20 21 22 23 I, Kyra E. Andrassy, declare: 24 1. I am a partner with Smiley Wang-Ekvall, LLP, attorneys for Elissa D. Miller,25 Chapter 7 Trustee of the bankruptcy estate of Girardi Keese (the "Trustee"). I am 26 licensed to practice before this Court and the courts of the State of California. I know 27 each of the following facts to be true of my own personal knowledge, except as otherwis28 stated and, if called as a witness, I could and would competently testify with respect

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1 thereto. I make this declaration in support of the Stipulation Authorizing Payment of 2 Client's Settlement Funds and Fees and Expenses to Be Disbursed to the Estate (the 3 "Stipulation") . Unless otherwise defined in this declaration, all terms defined in the 4 Stipulation are incorporated herein by this reference. 5 2. I am informed that prior to the petition date, the Debtor was retained by the 6 Client and commenced an action against various defendants in connection with a fire at 7 building known Ghost Ship (the "Litigation"). The Litigation was recently resolved 8 pursuant to a confidential settlement agreement (the "Settlement"). 9 3. I am informed that the retention agreement between the Debtor and the 10 Client provided that the Debtor would receive a percentage of the total recovery from its 11 representation of the Client, plus costs. 2 0 0 92626 4 445-1 1123 of the S4e. ttlemIe anmt ( "inFfiorsrmt Peady tmhaetn, ti"n). O Tchtoabt epra 2y0m2e0n, tt hwea sD teob btoer dreiscbeuivrseedd a a pcacyomrdeinngt atos tphaer ornia ax 71 a, Calif00 • F 14 terms of the retention agreement (i.e., first to costs, then the contingency fee, with the s0 15 balance to the Client). The Trustee believes that the Debtor, however, failed to remit ane1 M5- a 4 ost4 4 16 portion of the First Payment to the Client. After deducting costs, allocated to the Client C1 7 el 17 based on the Client's settlement amount relative to the settlement amounts to be T 18 received by other plaintiffs represented by the Debtor, and the Debtor's contingency fee, 19 the Client would have been entitled to receive the balance. 20 5. I am informed that Alexander is currently holding an additional payment on 21 account of the Settlement ("Second Payment"). 22 6. In order to avoid any reluctance on the part of Alexander to remit the 23 Second Payment to the Trustee, the parties have entered into the Stipulation regarding 24 the disbursement of the Second Payment. 25 7. The amount of the Second Payment, even if paid 100% to the Client, 26 without the deduction of any apportioned costs to the Estate and the contingency fee to 27 the Estate, would still be less than the total amount that the Client would have received 28

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1 had the Client received the net balance due to the Client from the First Payment 2 combined with the net balance due to Client from the Second Payment. 3 I declare under penalty of perjury under the laws of the United States of America 4 that the foregoing is true and correct to the best of my knowledge. 5 Executed on this 17th day of August, 2021, at Costa Mesa, California. 6 /s/ Kyra E. Andrassy 7 KYRA E. ANDRASSY 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 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): DECLARATION OF KYRA E. ANDRASSY IN UPPORT OF STIPULATION AUTHORIZING PAYMENT OF CLIENT'S SETTLEMENT FUNDS AND FEES AND XPENSES TO BE DISBURSED TO THE ESTATE will be served or was served (a) on the judge in chambers in the fornd 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 General rders and LBR, the foregoing document will be served by the court via NEF and hyperlink to the document. On (date) ugust 17, 2021 I checked the CM/ECF docket for this bankruptcy case or adversary proceeding and determined that e following persons are on the Electronic Mail Notice List to receive NEF transmission at the email addresses stated elow:  Service information continued on attached pag . SERVED BY UNITED STATES MAIL: n (date)) August 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. he Honorable Barry Russell .S. Bankruptcy Court oybal Federal Building 55 E. Temple Street, Suite 1660 os Angeles, CA 900125  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 following ersons and/or entities by personal delivery, overnight mail service, or (for those who consented in writing to such servicethod), by facsimile transmission and/or email as follows. Listing the judge here constitutes a declaration that personal elivery 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 17, 2021 Gabriela Gomez-Cruz /s/ Gabriela Gomez-Cruz Date Printed Name 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  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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