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Full title: Declaration Of: Tony Lopez in Support of Debtors' Third, Fourth, and Fifth Omnibus Objections to Claims (Incorrect Priority Claims) Filed by GABRIELLE A. HAMM on behalf of GUMP'S BY MAIL, INC., GUMP'S CORP., GUMP'S HOLDINGS, LLC (Related document(s)646 Objection to Claim filed by Debtor GUMP'S HOLDINGS, LLC, Jnt Admin Debtor GUMP'S CORP., Jnt Admin Debtor GUMP'S BY MAIL, INC., 647 Objection to Claim filed by Debtor GUMP'S HOLDINGS, LLC, Jnt Admin Debtor GUMP'S CORP., Jnt Admin Debtor GUMP'S BY MAIL, INC., 648 Objection to Claim filed by Debtor GUMP'S HOLDINGS, LLC, Jnt Admin Debtor GUMP'S CORP., Jnt Admin Debtor GUMP'S BY MAIL, INC.) (HAMM, GABRIELLE) (Entered: 04/29/2021)

Document posted on Apr 28, 2021 in the bankruptcy, 3 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

Since approximately 2012, I have served as the Chief Financial Officer and Chi 5 Operating Officer of Gump’s Holdings, LLC, a Nevada LLC (“Holdings”), Gump’s Corp., 6 California corporation (“Retail”), and Gump’s By Mail, Inc., a Delaware corporation (“Direct,7 or collectively with Holdings and Retail, the “Debtors”), debtors and debtors-in-possession in th8 above-captioned jointly administered Chapter 11 cases (the “Chapter 11 Cases”).(the “Fourth Omnibus Objection”); and (3) Debtors’ Fift28 Omnibus Objection to Claims (Gump’s Holdings, LLC Claims Asserting Incorrect Priority) (th 1 2 Objection, the “Omnibus Objections”).Debtors have carefully reviewed the claims that are the subject of the Omnibu 4 Objections and determined that they are not properly classified as priority claims under Sectio5 507(a) of the Bankruptcy Code, but should be classified as general unsecured claims.The claims listed on Exhibit 1 of the Fourth Omnibus Objection are custome14 claims for store credits, gift card balances, or for goods not delivered in which the transaction wa15 for an outright purchase that Debtors did not fulfill, rather than an incomplete transaction, or wher16 the claim does not contain any documentation or other evidence indicating that a deposit was mad17 13. The claims listed on Exhibit 1 of the Fifth Omnibus Objection are not claims 18 individuals for deposits of money in connection with the purchase, lease, or rental of property, 19 the purchase of services, for the personal, family, or household use of such claimants, and in som20 cases, are not even claims of individuals.

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Document Contents

1 WILLIAM M. NOALL 2 Nevada Bar No. 3549 E-mail: wnoall@gtg.legal 3 GABRIELLE A. HAMM Nevada Bar No. 11588 4 E-mail: ghamm@gtg.legal 5 MARK M. WEISENMILLER Nevada Bar No. 12128 6 E-mail: mweisenmiller@gtg.legal 7251 Amigo St., Suite 210 7 Las Vegas, Nevada 89119 Telephone (725) 777-3000 8 Facsimile (725) 777-3112 9 Attorneys for Debtors 10 UNITED STATES BANKRUPTCY COURT 11 FOR THE DISTRICT OF NEVADA 12 In re: Case No.: BK-S-18-14683-mkn Chapter 11 13 GUMP’S HOLDINGS, LLC Jointly administered with: 14 Affects this Debtor. No. BK-S-18-14684-mkn (In re Gump’s Corp.) 15 No. BK-S-18-14685-mkn (In re Gump’s By Affects all Debtors. Mail, Inc.) 16 17 Affects Gump’s Corp. 18 Date: June 3, 2021 Affects Gump’s By Mail, Inc. Time: 9:30 a.m. 19 20 DECLARATION OF TONY LOPEZ IN SUPPORT OF DEBTORS’ THIRD, FOURTH, AND FIFTH OMNIBUS OBJECTIONS TO CLAIMS (INCORRECT PRIORITY CLAIMS21 22 I, Tony Lopez, hereby declare under penalty of perjury under the laws of the United State23 of America as follows: 24 1. I am more than 21 years old, mentally competent, and I have never been convicte25 of a felony or of any crime involving moral turpitude. 26 2. I am a Certified Public Accountant licensed in California and a Certified Frau27 Examiner. I hold a B.A. degree in accounting from California State University, Long Beach an28 an M.B.A. from Pepperdine University.

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1 2 Angeles-based business advisory firm that provides accounting and strategic transaction service3 financial advisory services, and risk and compliance services. 4 4. Since approximately 2012, I have served as the Chief Financial Officer and Chi 5 Operating Officer of Gump’s Holdings, LLC, a Nevada LLC (“Holdings”), Gump’s Corp., 6 California corporation (“Retail”), and Gump’s By Mail, Inc., a Delaware corporation (“Direct,7 or collectively with Holdings and Retail, the “Debtors”), debtors and debtors-in-possession in th8 above-captioned jointly administered Chapter 11 cases (the “Chapter 11 Cases”). 9 5. I have served in such capacity since September of 2012 as a consultant, and fro10 July 8, 2013 to present, pursuant to a Consulting Agreement with my limited liability partnershi11 Assurance Partners, LLP. 12 6. In my capacity as the Debtors’ CFO/COO, I am responsible for, among oth13 things, overseeing the Debtors’ accounting, treasury, tax, credit, and audit matters, along with the14 operations. In this capacity, I have extensive knowledge of, and experience with, the event15 leading up to the commencement of the Chapter 11 Cases, the business and financial affairs of th16 Debtors, the Debtors’ pre-petition efforts to market the Debtors’ business, and the Debtor17 operations during the Chapter 11 Cases. Debtors continue to operate their businesses and manag18 their affairs as debtors-in-possession pursuant to Sections 1107(a) and 1108 of the Bankruptc19 Code. No trustee or examiner has been appointed in the Chapter 11 Cases. 20 7. Except as otherwise indicated, all facts set forth in this Declaration are based upo21 my personal knowledge of the Debtors’ operations and finances, information learned from m22 review of relevant documents, and information supplied to me by the Debtors’ advisors. If calle23 upon to testify, I could and would testify competently to the facts set forth in this Declaration. 24 8. I submit this Declaration in support of: (1) Debtors’ Third Omnibus Objection t25 Claims (Gump’s By Mail, Inc. Claims Asserting Incorrect Priority) (the “Third Omnibu26 Objection”); (2) Debtors’ Fourth Omnibus Objection to Claims (Gump’s Holdings, LLC Claim27 Asserting Incorrect Priority) (the “Fourth Omnibus Objection”); and (3) Debtors’ Fift28 Omnibus Objection to Claims (Gump’s Holdings, LLC Claims Asserting Incorrect Priority) (th

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1 2 Objection, the “Omnibus Objections”). 3 9. Debtors have carefully reviewed the claims that are the subject of the Omnibu 4 Objections and determined that they are not properly classified as priority claims under Sectio5 507(a) of the Bankruptcy Code, but should be classified as general unsecured claims. 6 10. In the Third Omnibus Objection, Debtors object to claims against Direct by vendor7 asserting priority under Section 507(a)(4) of the Bankruptcy Code. Neither of the vendors liste8 on Exhibit 1 to the Third Omnibus Objection were employees of any of the Debtors or independe9 contractors for the sale of goods or services, and the claims do not seek payment for wage10 salaries, commissions, vacation, severance, or sick leave pay. 11 11. In the Fourth and Fifth Omnibus Objections, Debtors object to claims whic12 improperly assert priority under Section 507(a)(7) of the Bankruptcy Code. 13 12. The claims listed on Exhibit 1 of the Fourth Omnibus Objection are custome14 claims for store credits, gift card balances, or for goods not delivered in which the transaction wa15 for an outright purchase that Debtors did not fulfill, rather than an incomplete transaction, or wher16 the claim does not contain any documentation or other evidence indicating that a deposit was mad17 13. The claims listed on Exhibit 1 of the Fifth Omnibus Objection are not claims 18 individuals for deposits of money in connection with the purchase, lease, or rental of property, 19 the purchase of services, for the personal, family, or household use of such claimants, and in som20 cases, are not even claims of individuals. Instead, they are claims of Debtors’ vendors an21 suppliers. 22 Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the foregoing is tru23 and correct to best of my knowledge and belief. 24 DATED April 29, 2021. 25 /s/ Tony Lopez TONY LOPEZ 26 27 28 4838-1365-6807, v. 1

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