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Full title: Declaration of Jeffrey B. Ellman in Support of the Ex Parte Application of the Debtor for an Order Authorizing It to Retain and Employ Jones Day as Counsel as of the Petition Date (RE: related document(s)[16] Application to Employ filed by Debtor DBMP LLC) filed by Garland S. Cassada on behalf of DBMP LLC. (Cassada, Garland)

Document posted on Oct 26, 2021 in the bankruptcy, 16 pages and 0 tables.

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America Merrill Lynch International DAC) is a former co-client with current client Deutsche Bank AG New York in a matter closed in 2020; • Affiliate company Banc of America Strategic Investments Corporation is a minority joint venture partner in current client General Electric Co. is: (both opened 2021) are new clients; (a) a current client; (b) a former • GE Global Operations France SAS, GE co-client with affiliate company Energy Parts, Inc., General Electrik and former co-client GE Medical LLC a/k/a GE Lighting, a co-client with affiliate company Savant Company (all opened 2020) are and former co-client GE Energy new clients; Financial Services, Inc. in a matter closed in 2019; • Affiliate company Employers Reassurance Corporation is a member of new clientFrance S.A.S., Baker Hughes, • Affiliate companies GE Medical Systems A GE Company, GE Medical Information Technologies, Inc., GE Systems Information Aviation, GE Japan Corporation, GE Technologies, Inc., GE Medical Systems Trade & Development (a/k/a Alstom Hydro France) and GE Renewable Management S.A.S. are current clients; • Affiliate company GE Capital Corporation and affiliated entity General Electric Pension Trust are co-clients in a current group representation of General Motors term lenders; • Affiliate company GE

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UNITED STATES BANKRUPTCY COURT WESTERN DISTRICT OF NORTH CAROLINA CHARLOTTE DIVISION In re Chapter 11 DBMP LLC,1 Case No. 20-30080 (JCW) Debtor. DECLARATION OF JEFFREY B. ELLMAN IN SUPPORT OF THE EX PARTE APPLICATION OF THE DEBTOR FOR AN ORDER AUTHORIZING IT TO RETAIN AND EMPLOY JONES DAY AS COUNSEL AS OF THE PETITION DATE Pursuant to Rule 2014(a) of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”), Jeffrey B. Ellman declares: 1. I am a partner with the law firm of Jones Day and am duly authorized to make this declaration on behalf of Jones Day. I make this declaration to supplement disclosures set forth in: (a) the Ex Parte Application of the Debtor for an Order Authorizing It to Retain and Employ Jones Day as Counsel as of the Petition Date [Dkt. 16] (the “Application”); (b) the Declaration of Gregory M. Gordon in support of the Application (the “Gordon Declaration”), which was attached to the Application as Exhibit C; 2 and (c) the prior supplemental declaration of Mr. Gregory M. Gordon filed on February 8, 2021 [Dkt. 657] (the “First Supplemental Declaration” and, together with the Gordon Declaration, the “Declarations”). The facts set forth in this declaration are personally known to me or have 1 The last four digits of the Debtor’s taxpayer identification number are 8817. The Debtor’s address is 20 Moores Road, Malvern, Pennsylvania 19355. 2 In addition, a supplemental declaration of Mr. Gregory M. Gordon in support of the Application was filed on February 21, 2020 [Dkt. 166] at the request of the Bankruptcy Administrator for the Western District of North Carolina (the “Bankruptcy Administrator”) to clarify that Jones Day would waive any claim for fees and expenses in excess of DBMP LLC’s prepetition retainer, if any, that were incurred prior to the Petition Date.

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been collected for me under my direction and, if called as a witness, I could and would testify thereto. 2. On January 23, 2020, the above-captioned debtor and debtor in possession (the “Debtor”) filed the Application and the Gordon Declaration with the Court. By the Application, the Debtor sought authority to retain and employ Jones Day as counsel in this chapter 11 case (the “Chapter 11 Case”). On January 24, 2020, the Court entered an ex parte order [Dkt. 34] authorizing the retention of Jones Day as the Debtor’s counsel in the Chapter 11 Case as of the Petition Date. On March 17, 2020, the Court entered an amended order [Dkt. 201] authorizing the retention of Jones Day as the Debtor’s counsel in the Chapter 11 Case as of the Petition Date. 3. In connection with the Application, to check and clear potential conflicts of interest in the Chapter 11 Case, Jones Day researched its client database (the “Initial Conflicts Search”) to determine whether it had any relationships with the individuals or institutions set forth on Schedule 1 to the Gordon Declaration. A similar process was conducted in connection with the First Supplemental Declaration (the “First Supplemental Conflicts Search” and, together with the Initial Conflicts Search, the “Prior Conflict Searches”) with respect to the parties set forth in Schedule 1 to the First Supplemental Declaration (together with the parties set forth on Schedule 1 to the Gordon Declaration, the “Interested Parties”). 4. In the Declarations, Mr. Gordon disclosed that although Jones Day represented or currently represents certain of the Interested Parties included in the Prior Conflicts Search, those representations were or are in matters unrelated to the Chapter 11 Case, and Jones Day did not represent any entity or individual in a matter in which such entity or individual is adverse to the Debtor.

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Second Supplemental Disclosure 5. In the Declarations, Mr. Gordon stated that Jones Day would, in accordance with Bankruptcy Rule 2014(a), supplement the information contained in those declarations with respect to, among other things, new relationships not set forth therein. 6. Jones Day now has further updated the examination of its relationships with interested parties in the Chapter 11 Case. In connection therewith, Jones Day researched its client database for the past two years (the “Second Supplemental Conflicts Search”) to determine whether: (a) since the completion of the First Supplemental Conflicts Search, Jones Day has ceased providing client services to any entities (or their affiliates) previously disclosed as clients of Jones Day in the Declarations; (b) any information relating to Jones Day’s relationship with any of the Interested Parties, or their affiliates, was inadvertently omitted from the Declarations; (c) since the completion of the First Supplemental Conflicts Search, Jones Day has undertaken to provide client services to any of the Interested Parties that were not clients of Jones Day at the time of the Declarations; and (d) any entities not identified as Interested Parties, because such entities (i) were unknown to Jones Day at the time of the Declarations or (ii) have taken on a role in matters relating to the Chapter 11 Case since the date of the Declarations, are current or former clients of Jones Day. 7. A list of the additional entities included in the Second Supplemental Conflicts Search (collectively, the “Additional Parties”) is set forth on Schedule 1 attached hereto. Disinterestedness 8. To the extent that the Second Supplemental Conflict Search indicated that (a) the Declarations required updating or (b) Jones Day has been or currently is employed by any of the Additional Parties in matters unrelated to the Chapter 11 Case, the identities of those

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entities and the nature of, or change in, Jones Day’s relationship to them, as of July 26, 2021, are set forth on Schedule 2 attached hereto (“Schedule 2”). 9. To the best of my knowledge, information and belief, Jones Day represents no interest adverse to the Debtor, its estate, its creditors or the Bankruptcy Administrator, and Jones Day does not represent any other party with an actual or potential interest in the Chapter 11 Case or such party’s respective attorneys or accountants, except as set forth in Schedule 2 and in the Declarations. 10. I believe that Jones Day continues to be a “disinterested person,” as defined in section 101(14) of title 11 of the United States Code (the “Bankruptcy Code”) and required by section 327 of the Bankruptcy Code. The Debtor, however, is a complex entity with numerous creditors and other relationships, and I am unable to state with certainty whether every client representation or other connection has been disclosed. In this regard, if Jones Day discovers additional information that requires disclosure, it will file an additional supplemental disclosure with the Court. Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the foregoing is true and correct to the best of my information, knowledge and belief. Dated: October 27, 2021 /s/ Jeffrey B. Ellman Jeffrey B. Ellman

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SCHEDULE 1 Additional Parties as of July 26, 2021

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Debtor’s Retained Professionals Donlin, Recano and Company, Inc. Debtor’s Significant Ordinary Course Professionals, Consultants and Service Providers Hunter & Cole Kean Miller LLP Professionals to the Future Claimants’ Representative Alexander Ricks PLLC Other Interested Parties United States Bankruptcy Rule 2002 Appearances Bailey Cowan Heckaman PLLC Bevan and Associates LPA, Inc. Brayton Purcell LLP Flint Law Firm, LLC Francisco Galaviz Keller, Fishback and Jackson LLP Motley Rice LLC Nass Cancelliere Nemeroff Law Firm, PC Rebecca S. Vinocur, P.A Reynolds Frizzell LLP Simmons Hanly Conroy The Lanier Law Firm Thornton Law Firm, LLP Wallace & Graham, P.A. Waters & Kraus, LLP

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SCHEDULE 2 SECOND SUPPLEMENTAL DISCLOSURE IN RE DBMP LLC SCHEDULE OF INTERESTED PARTIES AS OF JULY 26, 2021 THAT CURRENTLY EMPLOY OR HAVE FORMERLY EMPLOYED JONES DAY IN MATTERS UNRELATED TO THE DEBTORS OR THEIR CHAPTER 11 CASE RELATIONSHIP INTERESTED PARTY TO THE CLIENTS AND THEIR AFFILIATES DEBTORS NEW PARTIES IN INTEREST1 Donlin, Recano and Company, Inc. Debtor’s Retained • Affiliated entity AST Trust Company Professional (Canada) is a current client. UPDATES TO PRIOR DISCLOSURE 3M Company Significant Co-Defendant • Affiliate company 3M France is now a in Asbestos Related former client (closed 2020). PRIOR DISCLOSURE: Litigation • 3M Company and affiliate company 3M Purification are former clients (both closed 2018); and • Affiliate companies 3M France and 3M Media Company LLC are current clients. A. O. Smith Corporation Significant Co-Defendant • A. O. Smith Corporation is a new client in Asbestos-Related (opened 2021). PRIOR DISCLOSURE: Litigation • A. O. Smith Corporation is a former client (closed 2018). 1 The parties listed herein are parties in interest (or affiliated entities) who are current clients of Jones Day or were clients of Jones Day within the last two years. The names of current clients of Jones Day appear in bold and italics. The disclosure of stockholder interests or other affiliate relationships among potentially related entities reflects only information known to Jones Day through its conflict reporting system. Jones Day has not performed independent research to identify all stockholder interests or other affiliate relationships with respect to interested parties. Moreover, Jones Day has not disclosed representations of trade associations and similar industry or special interest organizations in which interested parties are members.

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RELATIONSHIP INTERESTED PARTY TO THE CLIENTS AND THEIR AFFILIATES DEBTORS Bank of America, N.A. Depository and • Affiliate company Bank of America Disbursement Bank Merrill Lynch International DAC is now PRIOR DISCLOSURE: known as current client Bank of America • Bank of America, N.A. and Europe DAC (opened 2020); affiliate companies Bank of • Affiliate company Merrill Lynch Kingdom America Securities Europe of Saudi Arabia Company is a new client S.A., Bank of America Merrill (opened 2021); and Lynch International DAC – Milan Branch, Merrill Lynch • Affiliate company Merrill Lynch, Pierce, International, , Bank of Fenner & Smith is now a former client America, N.A. London and (closed 2020). Bank of America Business • See also entry below for Metropolitan Life Credit are current clients; Insurance Company (a/k/a MetLife) • Parent company Bank of regarding related disclosure. America Corporation is: (a) a current client; (b) the employer of an individual who is a former client (closed 2019); and (c) a co-client in a current joint representation with affiliate company and current client Merrill Lynch Bank & Trust (Cayman) Limited and certain of its affiliate companies; • Affiliate company Bank of America Merrill Lynch International Designated Activity Company is a former co-client with current client Natixis in a joint representation closed in 2020; • Affiliate company Bank of America Merrill Lynch International Limited (n/k/a current client Bank of America Merrill Lynch International DAC) is a former co-client with current client Deutsche Bank AG New York in a matter closed in 2020; • Affiliate company Banc of America Strategic Investments Corporation is a minority joint venture partner in current client Visible Alpha LLC;

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RELATIONSHIP INTERESTED PARTY TO THE CLIENTS AND THEIR AFFILIATES DEBTORS • Affiliate company Bank of America Merrill Lynch is: (a) a member, with current client Goldman Sachs International, of a former group representation of lenders closed in 2018; and (b) the indemnitor for and former employer of an individual who is a former client (closed 2020); • Affiliate company Merrill Lynch, Pierce, Fenner & Smith Incorporated is: (a) a current client; and (b) a former co-client with current client Deutsche Bank AG New York in a matter closed in 2019; and • Affiliate companies Bank of America Merrill Lynch International (closed 2018); Merrill Lynch Capital Corporation (closed 2019); Merrill Lynch International, London Branch, Merrill Lynch Kingdom of Saudi Arabia Company and Merrill Lynch Bank & Trust (Cayman) Limited (all closed 2020) are former clients.

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RELATIONSHIP INTERESTED PARTY TO THE CLIENTS AND THEIR AFFILIATES DEBTORS Bestwall LLC Bankruptcy Rule 2002 • Affiliate companies Koch Financial Assets Appearance III, LLC, Koch-Glitsch Italia S.r.l., Koch PRIOR DISCLOSURE: Real Estate Investments, Koch Strategic Co-Defendant in • Bestwall LLC is a current client; Platforms, Koch Technology Solutions, Asbestos-Related LLC, Koch Technology Solutions UK • Ultimate parent company Koch Litigation Limited and Koch Treasury (all opened Industries, Inc. is: (a) a current 2021); and Koch Agronomic Services, client in matters unrelated to Koch Chemical Technology Group S.L. Bestwall or its chapter 11 case; and Koch Chemicals Technology Group (b) the owner of current client Italia S.r.l. (all opened 2020) are new Infor, Inc.; and (c) a former clients; and equity holder of former client Truck-Lite Co. LLC • Affiliate companies Bittware, Inc., Infor, (closed 2020); Inc., Koch Shipping Pte Ltd. and Flint Hills Resources, L.P. (all closed 2021); • Affiliate company Georgia- Koch Fertilizer LLC, Guardian Industries Pacific LLC is a current client in and Invista International S.a.r.l. several matters with ultimate (all closed 2020); and Koch Metals parent company Koch Trading Limited (closed 2019) are now Industries, Inc. unrelated to former clients. Bestwall or its chapter 11 case; • Affiliate companies Bittware, Inc., Guardian Industries, Guardian Europe Sàrl, Guardian Flachglas GmbH, Koch Biological Solutions LLC, Koch Fertilizer LLC, Koch Disruptive Technologies, Koch Minerals LLC, Koch Shipping Pte. Ltd., Koch Equity Development, Koch Companies Public Sector LLC, SRG Global, Inc., Molex Incorporated n/k/a Molex, LLC, Molex Elektronik GmbH, Invista International S.a.r.l., DSS Optical Solutions and Flint Hills Resources, L.P. are current clients in matters unrelated to Bestwall or its chapter 11 case; and

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RELATIONSHIP INTERESTED PARTY TO THE CLIENTS AND THEIR AFFILIATES DEBTORS • Affiliate companies Koch AG & Energy Solutions, LLC, Koch Supply & Trading LLC, Molex Zetronic S.R.L., KCTG Japan Holdings Limited, Koch-Glitsch Italia S.R.L. and Molex Japan Co., Ltd. n/k/a Molex Japan LLC (all closed 2019); and Koch Biological Solutions and Koch Supply & Trading L.P. (both closed 2020) are former clients. CBS Corporation Significant Co-Defendant • CBS Corporation and Network Ten Pty in Asbestos-Related Limited (both closed 2021); and affiliate PRIOR DISCLOSURE: Litigation companies CBS International • CBS Corporation and affiliate (Netherlands) B.V. and CBS UK companies CBS International (both closed 2020) are now former clients. (Netherlands) B.V., CBS UK • See also entry below for Westinghouse and Network Ten Pty Limited Electric Corporation regarding related are current clients; and disclosure. • Affiliate company CBS Studios International GmbH is a former client (closed 2018).

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RELATIONSHIP INTERESTED PARTY TO THE CLIENTS AND THEIR AFFILIATES DEBTORS General Electric Co. Significant Co-Defendant • Affiliate companies GE Energy Power in Asbestos-Related Conversion UK Limited and GE Power PRIOR DISCLOSURE: Litigation Conversion Naval Systems, Inc. • General Electric Co. is: (both opened 2021) are new clients; (a) a current client; (b) a former • GE Global Operations France SAS, GE co-client with affiliate company Energy Parts, Inc., General Electrik and former co-client GE Medical Ticaret Ve Servis AS, GE Energy Systems Italia S.p.a. in a matter Products France SNC and Consumer closed in 2020; and (c) a former Lighting (U.S.) LLC a/k/a GE Lighting, a co-client with affiliate company Savant Company (all opened 2020) are and former co-client GE Energy new clients; Financial Services, Inc. in a matter closed in 2019; • Affiliate company Employers Reassurance Corporation is a member of new client Ad • Affiliate companies GE Hoc Group of NGL Energy Bondholders Transportation Parts LLC, (opened 2021); General Electric International, • The group representation of General Inc., GE Energy Products Motors term lenders in which affiliate Finance SNC, GE Lighting company GE Capital Corporation and LLC, GE Grid Solutions LLC, affiliated entity General Electric Pension GE Power Services Belgium, Trust were members was closed in 2020; S.A., GE Japan Corporation, GE Medical Systems Trade & • Nihon Medi-Physics Co., Ltd., of which Development (Shanghai) Co., affiliate company GE Healthcare is a co-Ltd., GE Power, GE Grid owner, is now a former client Australia Pty Ltd., GE IS&T (closed 2020); S.A.S., GE Energy Power Conversion Technology, Ltd., • Aver, Inc., an entity in which affiliate company GE Ventures Ltd. is an investor, GE-Hitachi Nuclear Energy is now a former client (closed 2021); and Americas LLC, GE Wind France S.A.S., Baker Hughes, • Affiliate companies GE Medical Systems A GE Company, GE Medical Information Technologies, Inc., GE Systems Information Aviation, GE Japan Corporation, GE Technologies, Inc., GE Medical Systems Trade & Development Healthcare Limited, GE Water (Shanghai) Co., Ltd., GE Grid Australia & Process Technologies, ABB Pty Ltd. and GE IS&T S.A.S. Industrial Solutions (France) (all closed 2021); GE Energy Connections, S.A.S. (f/k/a GE Power Controls GE-Hitachi Nuclear Energy Americas, France), ABB Electrification LLC, GE Power Services Belgium S.A. Solutions SLU (f/k/a GE Power and GE Healthcare Limited Controls Iberica), ABB (all closed 2020); and General Electric Industrial Solutions (Klodzko) Energy UK Limited (closed 2019) are now SP Z.o.o. (f/k/a GE Power former clients. Controls Polska SP Z.o.o.), GE Energy Power Conversion • See also entries below for J.P. Morgan France S.A.S., GE Energy Chase and Metropolitan Life Insurance Connections, GE SCF S.C.A., Company (a/k/a MetLife) regarding related GE Aviation, GE Hydro France disclosure.

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RELATIONSHIP INTERESTED PARTY TO THE CLIENTS AND THEIR AFFILIATES DEBTORS (a/k/a Alstom Hydro France) and GE Renewable Management S.A.S. are current clients; • Affiliate company GE Capital Corporation and affiliated entity General Electric Pension Trust are co-clients in a current group representation of General Motors term lenders; • Affiliate company GE Healthcare is one of the owners of current client Nihon Medi- Physics Co., Ltd.; • Affiliate company GE Ventures Ltd. is an investor in current client Aver, Inc.; • Affiliate company GE Japan GK (n/k/a SMFL Capital Co., Ltd.) is a former client with current client Sumitomo Mitsui Banking Corporation in a matter closed in 2019; and • Affiliate companies GE Water & Process Technologies México, and GE Oil & Gas (both closed 2018); GE Oil & Gas Australia Pty Ltd., GE Capital Aviation Services, GE Electric Energy UK Limited, GE Capital Europe Ltd., Healthcare Financial Solutions LLC and GE Water & Process Technologies France (all closed 2019); and GE Digital LLC, GE Eoliennes SN and GE Energy Management (all closed 2020) are former clients.

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RELATIONSHIP INTERESTED PARTY TO THE CLIENTS AND THEIR AFFILIATES DEBTORS J.P. Morgan Chase Depository and • Parent company JPMorgan Chase & Co. Disbursement Bank is: (a) a member of a joint defense group PRIOR DISCLOSURE: representation of KWA underwriters • Affiliate company JPMorgan opened in 2020; and (b) a stockholder of Trust Company of Delaware is a Nine Point Energy Holdings, Inc., the current client; parent company of new client Nine Point Energy, LLC (opened 2021); and • Parent company JPMorgan Chase & Co. is: (a) a current • Affiliated entity JPMorgan Chase client; (b) a member of current Retirement Plan Brigade is a member of client Ad Hoc Intelsat Jackson new client Ad Hoc Group of NGL Energy Unsecured Noteholders Group; Bondholders (opened 2021). (c) a co-client in a current matter • See also entry above for Bank of America, with current client The Bank of N.A. and entry below for Metropolitan Life Nova Scotia; and (d) the Insurance Company (a/k/a MetLife) employer and indemnitor of an regarding related disclosure. individual who is a current client (opened 2020); • Affiliate company JPMorgan Securities LLC is: (a) a current client; (b) a co-client in a current matter with current client Citigroup, Inc.; (c) a former co-client with current client Bank of America Corporation in a matter closed in 2020; and (d) a former co-client with current client Deutsche Bank AG New York in a matter closed in 2019; • Affiliate company JPMorgan Securities Plc is: (a) a current client; (b) a former co-client with current client UniCredit Bank AG in a matter closed in 2019; and (c) a former co-client with current client Intesa SanPaolo in a matter closed in 2019; • Affiliate company Highbridge Capital Management LLC was a member of former client Ad Hoc Group of Savers LLC Term Loan Lenders (closed 2019);

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RELATIONSHIP INTERESTED PARTY TO THE CLIENTS AND THEIR AFFILIATES DEBTORS • Affiliated entities and current clients JPMorgan Chase Retirement Plan Brigade and JPMorgan Chase Retirement Plan Brigade Bank Loan; and JPMorgan Funds – Multi- Manager Alternatives Fund and JPMorgan Trust III – JPMorgan Multi-Manager Alternatives Fund are former co-clients in a group representation of Hexion noteholders closed in 2019; • Affiliated entity JPMorgan Chase Retirement Plan Brigade is: (a) a co-client in one current and one former group representation of iHeart Communications, Inc. former lenders and noteholders (closed 2020); and (b) a former co-client in a group representation of Bon-Ton second lien noteholders closed in 2019; • Affiliated entity JPMorgan Chase Retirement Plan Brigade Bank Loan is: (a) a co-client in a current group representation of iHeart Communications, Inc. former lenders and noteholders; (b) a former co-client with affiliated entity JPMorgan Chase Retirement Plan and current client Brigade Capital Management, L.P. in a matter closed in 2018; and (c) a former co-client in a group representation of Preferred Proppants term lenders closed in 2019; and

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RELATIONSHIP INTERESTED PARTY TO THE CLIENTS AND THEIR AFFILIATES DEBTORS • Affiliate companies JPMorgan Grupo Financiero, S.A. de C.V., JPMorgan Chase, National Association, JPMorgan Business Credit Corporation, and JPMorgan (all closed 2018); and JPMorgan LLC (closed 2019) are former clients. Metropolitan Life Insurance Significant Co-Defendant • Affiliated entity Metropolitan Life Company (a/k/a MetLife) in Asbestos-Related Insurance Company Separate Account Litigation No. 558 is a member of new client Ad Hoc PRIOR DISCLOSURE: Group of NGL Energy Bondholders • Parent company Bank of (opened 2021). America Corporation is: • See also entries above for Bank of (a) a current client; and America, N.A. and J.P. Morgan Chase (b) a former co-client with regarding related disclosure. affiliate company MetLife Investment Advisors LLC in a matter closed in 2018. Union Carbide Corporation Significant Co-Defendant • Affiliate companies Dow Química in Asbestos-Related Méxicana, S.A. de C.V. and The Dow PRIOR DISCLOSURE: Litigation Chemical Company are new clients • Union Carbide Corporation and (opened in 2020). affiliate companies Dow Corning Corporation and Dow AgroSciences LLC are current clients; and • Affiliate company The Dow Chemical Company is: (a) a current client; and (b) a co- owner in a joint venture of current client Sadara Chemical Company. Westinghouse Electric Corporation Significant Co-Defendant • Parent company CBS Corporation is now a in Asbestos-Related former client (closed 2021). PRIOR DISCLOSURE: Litigation • See also entry above for CBS Corporation • Parent company CBS regarding related disclosure. Corporation is a current client. NAI-1520234053

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