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Full title: Declaration re: of Lei Lei Wang Ekvall in Support of Stipulation to Extend Deadline to Respond to Notice of Motion and Motion for Relief from the Automatic Stay Filed by Frantz Law Group, APLC with Proof of Service Filed by Trustee Elissa Miller (TR) (RE: related document(s)60 Stipulation By Elissa Miller (TR) and Franz Law Group, APLC by and Through their Attorneys to Extend Deadline to Respond to Notice of Motion and Motion for Relief of Stay with Proof of Service). (Ekvall, Lei Lei) (Entered: 01/12/2021)

Document posted on Jan 11, 2021 in the bankruptcy, 4 pages and 0 tables.

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Lei Lei Wang Ekvall LEI LEI WANG EKVALL 25 26 27 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 LEI LEI WANG EKVALL IN UPPORT OF STIPULATION TO EXTEND DEADLINE TO RESPOND TO NOTICE OF MOTION AND MOTION FOR ELIEF FROM THE AUTOMATIC STAY FILED BY FRANTZ LAW GROUP, APLC will be served or was served (a) on e judge in chambers in the form and manner required by LBR 5005-2(d); and (b) in the manner stated below: .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) January 12, 2021 , I served the following persons and/or entities at the last known addresses in this bankruptcase 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 servee following persons and/or entities by personal delivery, overnight mail service, or (for those who consented in writing tuch 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 Proposed 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 DEKECVALALLR AINT ISOUNP OPOF RLTE IO LFE I WANG s0 15 STIPULATION TO EXTEND DEADLINE e1 M5- TO RESPOND TO NOTICE OF MOTION a 4 ost4 4 16 AND MOTION FOR RELIEF FROM THE C71 Alleged Debtor. AUTOMATIC STAY FILED BY FRANTZ el 17 LAW GROUP, APLC T 18 DATE: January 26, 2021 TIME: 10:00 a.m. 19 CTRM: 1668 20 21 I, Lei Lei Wang Ekvall, declare: 22 1. I am a partner with Smiley Wang-Ekvall, LLP, proposed attorneys for 23 Elissa D. Miller, Chapter 7 Trustee of the bankruptcy estate of Girardi Keese (the 24 "Trustee"). I am licensed to practice before this Court and the courts of the State of 25 California. I know each of the following facts to be true of my own personal knowledge, 26 except as otherwise stated and, if called as a witness, I could and would competently 27 testify with respect thereto. I make this declaration in support of the Stipulation to Exten

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1 "Stipulation") . Unless otherwise defined in this declaration, all terms defined in the 2 Stipulation are incorporated herein by this reference. 3 2. According to the Court's docket, on December 18, 2020, an involuntary 4 chapter 7 bankruptcy petition was filed against Girardi Keese ("Debtor"). As of the filing 5 of the involuntary petition, Debtor was counsel of record in a significant number of 6 matters which were undertaken on a contingency basis. 7 3. The petitioning creditors moved for the appointment of an interim trustee 8 which was granted by the Court by order entered January 5, 2021. The Trustee was 9 appointed as the interim chapter 7 trustee on January 6, 2021. 10 4. On December 30, 2020, Frantz filed a Notice of Motion and Motion for 11 Relief From the Automatic Stay [Docket No. 31] (the "Motion"). The Motion is scheduled2 0 0 92626 4 445-1 1123 fJoarn hueaaryri n1g2 ,o 2n0 J2a1n. uary 26, 2021, at 10:00 a.m. The deadline to respond to the Motion is ornia ax 71 a, Calif00 • F 14 5. The Trustee was only recently appointed on January 6, 2021, and has not s0 15 had sufficient time to fully evaluate the Debtor's business or the relief sought by Frantz. e1 M5- a 4 ost4 4 16 Accordingly, I requested and Frantz agreed to extend the deadline to respond to the C1 7 el 17 Motion for seven days to afford the Trustee additional time to properly evaluate the T 18 Debtor's affairs and determine the best course of action going forward. The Stipulation 19 filed concurrently herewith reflects the parties' agreement. 20 I declare under penalty of perjury under the laws of the United States of America 21 that the foregoing is true and correct to the best of my knowledge. 22 Executed on this 11th day of January, 2021, at Costa Mesa, California. 23 24 /s/ Lei Lei Wang Ekvall LEI LEI WANG EKVALL 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 LEI LEI WANG EKVALL IN UPPORT OF STIPULATION TO EXTEND DEADLINE TO RESPOND TO NOTICE OF MOTION AND MOTION FOR ELIEF FROM THE AUTOMATIC STAY FILED BY FRANTZ LAW GROUP, APLC will be served or was served (a) on e judge in chambers 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 General rders and LBR, the foregoing document will be served by the court via NEF and hyperlink to the document. On (date) anuary 12, 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) January 12, 2021 , I served the following persons and/or entities at the last known addresses in this bankruptcase 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 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 servee following persons and/or entities by personal delivery, overnight mail service, or (for those who consented in writing tuch 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. January 12, 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”)  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  Eric D Goldberg eric.goldberg@dlapiper.com, eric-goldberg-1103@ecf.pacerpro.com  Andrew Goodman agoodman@andyglaw.com, Goodman.AndrewR102467@notify.bestcase.com  Steven T Gubner sgubner@bg.law, ecf@bg.law  Marshall J Hogan mhogan@swlaw.com, knestuk@swlaw.com  Razmig Izakelian razmigizakelian@quinnemanuel.com  Lewis R Landau Lew@Landaunet.com  Peter J Mastan peter.mastan@dinsmore.com, SDCMLFiles@dinsmore.com;Katrice.ortiz@dinsmore.com  Edith R Matthai ematthai@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  Michael J Quinn mquinn@vedderprice.com, ecfladocket@vedderprice.com,michael-quinn-2870@ecf.pacerpro.com  Ronald N Richards ron@ronaldrichards.com, morani@ronaldrichards.com,justin@ronaldrichards.com  Philip E Strok pstrok@swelawfirm.com, gcruz@swelawfirm.com;1garrett@swelawfirm.com;jchung@swelawfirm.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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