CIS International Holdings (N.A.) Corporation — Entry #210: Motion for 2004 Examination Filed by Creditor Tokyo Century (USA) Inc
Case: CIS International Holdings (N.A.) Corporation cacb · 2:25-bk-18374
filed September 22, 2025
What this document is
Docket entry #210 · filed July 16, 2026
Motion for 2004 Examination Filed by Creditor Tokyo Century (USA) Inc. (Gill, Angela)
Who is involved
- CIS International Holdings (N.A.) Corporation
- David M Goodrich (TR)
- United States Trustee (LA)
Why we have it
We follow this case because it names a company we track, although that company is not a party:
- Core Scientific: its name “Core Scientific, Inc.” appears in a filing in this case.
…Representative Matters In re Core Scientific, Inc. (U.S. Bankruptcy Court for the Southern…
A free copy from the RECAP archive of federal court filings (mirrored at the Internet Archive), retrieved October 28, 2026. Federal court filings are public records.
Document text
28 page(s), 57,768 characters, converted from the PDF's text layer · plain text.
Full text
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1 ANGELA N. GILL –SBN 260928
HEMAR, ROUSSO & HEALD, LLP
2 15910 Ventura Boulevard, 12th Floor
Encino, California 91436
3 Telephone: (818) 501-3800
Facsimile: (818) 501-2985
4 agill@hrhlaw.com
5 Attorneys for Creditor and Party in Interest,
TOKYO CENTURY (USA) INC.
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UNITED STATES BANKRUPTCY COURT
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CENTRAL DISTRICT OF CALIFORNIA, LOS ANGELES DIVISION
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11 IN RE: ) CASE NO. 2:25-bk-18374-BR
)
12 CIS INTERNATIONAL HOLDINGS ) CHAPTER 7
(N.A.) CORPORATION, )
13 ) MOTION FOR EXAMINATION UNDER
) RULE 2004; DECLARATION OF
14 Debtor. ) ANGELA N. GILL AND TITO
) CABRERA IN SUPPORT THEREOF
15 )
) [No Hearing Set Pursuant to
16 ) Local Bankruptcy Rule 2004-1; 9013-1(p)]
)
17 ) Proposed Examination Date:
) Date: July 30, 2026
18 ) Time: 11:00 a.m.
) Location: Hemar Rousso & Heald
19 ) 15910 Ventura Blvd., 12th Fl.
) Encino, California 91436
20 )
)
21 ___________________________________
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TO THE HONORABLE BARRY RUSSELL UNITED STATES BANKRUPTCY JUDGE, THE
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UNITED STATES TRUSTEE, CHAPTER 7 TRUSTEE, DEBTOR AND ALL PARTIES IN
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INTEREST:
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PLEASE TAKE NOTICE that pursuant to Federal Rule of Bankruptcy Procedure 2004
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and Local Bankruptcy Rule 2004-1, TOKYO CENTURY (USA) INC. (“Movant”) moves the
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Court for an order authorizing the examination of CIS INTERNATIONAL HOLDINGS (N.A.)
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29 MOTION FOR RULE 2004 EXAMINATION
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1 CORPORATION through CHARITHA SAMARASINGHE, President and Authorized
2 Representative of CIS INTERNATIONAL HOLDINGS (N.A.) CORPORATION (hereinafter
3 referred to as “Debtor”). The Motion for Examination Under Rule 2004 (“Motion”) is based upon
4 the following facts and circumstances:
5 1. Movant is a creditor and party in interest in the above-captioned Chapter 7
6 bankruptcy case of Debtor (“Bankruptcy Case”). The Bankruptcy Case was commenced by
7 Debtor’s voluntary Chapter11 petition, filed September 22, 2025 (“Petition Date”).
8 2. On October 22, 2025, the Bankruptcy Case was converted to Chapter 7. (Dkt. 80).
9 3. On November 17, 2025, Movant timely filed a proof of claim in the amount of
10 $65,096.08. The claim is secured by two (2) vehicles specifically described as:
11 a. 2021 Isuzu NPR-HD, VIN 54DC4W1D8MS209725
12 b. 2021 Isuzue NPR-HD, VIN 54DC4W1D7MS209733
13 (Attached hereto and incorporated by reference is a true and correct copy of the filed proof of
14 claim as Exhibit “1”).
15 4. On January 6, 2026, Movant filed an Amended Motion for Relief from the
16 Automatic Stay to enforce its rights under applicable non-bankruptcy law to repossess both
17 vehicles due to Debtor’s failure to provide adequate protection and proof of insurance for the
18 vehicles. (Dkt. 163).
19 5. The Court granted Movant’s request and entered two Orders Granting Motion for
20 Relief from the Automatic Stay (the “Orders”) on February 4, 2026. (Dkt. Nos. 181, 182).
21 6. Specifically, the Orders terminated the stay as to Debtor and the Debtor’s
22 bankruptcy estate and permitted Movant to enforce its remedies to repossess or obtain possession
23 and dispose of the vehicles in accordance with applicable non-bankruptcy law. (Dkt. Nos. 181,
24 182).
25 7. After obtaining the Order, Movant was able to repossess the 2021 Isuzu NPR-HD,
26 VIN 54DC4W1D8MS209725.
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1 8. Despite many attempts to do so, Movant has not been able to repossess the 2021
2 Isuzu NPR-HD VIN 54DC4W1D7MS209733 (hereinafter “Isuzu 9733”).
3 9. Movant’s agents have made attempts to retrieve and repossess the Isuzu 9733 at the
4 following addresses at the following dates, without success:
5 a. On or around March 22, 2026 agents went to 4501 Air Park Road., Rhinelander,
6 WI 54501 but were not able to locate the Isuzu 9733.
7 b. On or around April 22, 2026, agents went to 1405 W. 178th St., Gardena, CA 90248
8 but were unable to locate the Isuzu 9733.
9 c. On or about May 24, 2026, agents went to 2389 Air Park Rd., Rhinelander, WI
10 54501 but were unable to locate the Isuzu 9733.
11 10. At this time, Movant needs to conduct the Debtor's 2004 examination in order to
12 investigate and determine where the Isuzu 9733 is located, and how to retrieve it.
13 11. The examination cannot proceed under F.R.B.P. Rules 7030 and 9014 because
14 there is pending no adversary proceeding or contested matter wherein the merits of the matters
15 referred to hereinabove may be scrutinized. Discovery may not proceed in the State Court
16 Litigation because of the strictures of 11 U.S.C. § 362.
17 12. Pursuant to LBR 2004-1(a), Movant’s counsel has communicated with Debtor's
18 counsel, Byron Moldo and Chase Stone at Ervin, Cohen and Jessup regarding a mutually
19 agreeable date to conduct the examination.
20 13. Over the course of communication between June 3, 2026 and July 15, 2026,
21 including telephone conversations on July 8, 2026 and July 15, 2026, Movant’s counsel was
22 informed by Debtor’s counsel Byron Moldo that he was not able to obtain a response from
23 Debtor’s principal regarding either the location of the vehicle or availability for a 2004 exam.
24 WHEREFORE, the Movant prays that an Order be entered under F.R.B.P. Rule 2004
25 authorizing the examination of CHARITHA SAMARASINGHE, President and Authorized
26 Representative of CIS INTERNATIONAL HOLDINGS (N.A.) CORPORATION, on any topic
27 subject to inquiry pursuant to that rule, at the law offices of Hemar, Rousso and Heald, LLP,
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1 located at 15910 Ventura Blvd., 12th Floor, Encino, CA 91436, beginning on July 30, 2026, at
2 11:00 a.m., in person, and thereafter to be continued from day to day, weekends and holidays
3 excepted, as necessary to complete the examination.
4 DATED: July 16, 2026 HEMAR, ROUSSO & HEALD, LLP
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/s/ Angela N. Gill
6 BY: _______________________________
ANGELA N. GILL
7 Attorneys for Creditor/Movant
TOKYO CENTURY (USA) INC.
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DECLARATION OF TITO CABRERA
1
2 I, TITO CABRERA, declare as follows:
3 1. I am employed by Isuzu Finance of America Inc. /Tokyo Century (USA) Inc.
4 (“Movant”) as the Vice President of Operations. I am a custodian of the books, records and files
5 of the Movant, as those records pertain to loans or extensions of credit by Movant to CIS
6 INTERNATIONAL HOLDINGS (N.A.) CORPORATION (hereinafter, “Debtor”). I have
7 personally worked on said records, and as to the facts contained herein, I know them to be true of
8 my own personal knowledge or I have gained knowledge of them from the records of Movant
9 which are prepared and maintained in the ordinary course of its business, at or near the time of the
10 acts or occurrences depicted or represented by such records. If called upon as a witness, I could
11 and would competently testify to the fact contained herein, as I have personal knowledge thereof.
12 2. On November 17, 2025, Movant timely filed a proof of claim in the amount of
13 $65,096.08. The claim is secured by two (2) vehicles specifically described as:
14 a. 2021 Isuzu NPR-HD, VIN 54DC4W1D8MS209725
15 b. 2021 Isuzue NPR-HD, VIN 54DC4W1D7MS209733
16 (Attached hereto and incorporated by reference is a true and correct copy of the filed proof of
17 claim as Exhibit “1”).
18 3. On January 6, 2026, Movant filed an Amended Motion for Relief from the Automatic
19 Stay to enforce its rights under applicable nonbankruptcy law to repossess both vehicles due to
20 Debtor’s failure to provide adequate protection and proof of insurance for the vehicles. (Dkt. 163).
21 4. The Court granted Movant’s request and entered two Orders Granting Motion for
22 Relief from the Automatic Stay (the “Orders”) on February 4, 2026. (Dkt. Nos. 181, 182).
23 5. Specifically, the Orders terminated the stay as to Debtor and the Debtor’s bankruptcy
24 estate and permitted Movant to enforce its remedies to repossess or obtain possession and dispose
25 of the vehicles in accordance with applicable nonbankruptcy law. (Dkt. Nos. 181, 182).
26 After obtaining the Order, Movant was able to repossess the 2021 Isuzu NPR-HD, VIN
27 54DC4W1D8MS209725.
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1 DECLARATION OF ANGELA N. GILL
2 I, ANGELA N. GILL, declare as follows:
3 I am an attorney licensed to practice law in all of the courts in the State of California. I am an
4 attorney at the law firm of Hemar, Rousso & Heald, LLP, attorneys of record for Tokyo Century
5 (USA) Inc. (“Movant”) and I am not a party to this action. I make this declaration based upon my
6 personal knowledge of this case and as a custodian of records of the legal file as it relates to
7 Movant’s claims against CIS INTERNATIONAL HOLDINGS (N.A.) Corporation (“Debtor”).
8 1. On November 17, 2025, Movant timely filed a proof of claim in the amount of $65,096.08.
9 The claim is secured by two (2) vehicles specifically described as:
10 a. 2021 Isuzu NPR-HD, VIN 54DC4W1D8MS209725
11 b. 2021 Isuzu NPR-HD, VIN 54DC4W1D7MS209733
12 (Attached hereto and incorporated by reference is a true and correct copy of the filed proof of
13 claim as Exhibit “1”).
14 2. On January 6, 2026, Movant filed an Amended Motion for Relief from the Automatic Stay
15 to enforce its rights under applicable nonbankruptcy law to repossess both vehicles due to
16 Debtor’s failure to provide adequate protection and proof of insurance for the vehicles. (Dkt. 163).
17 3. The Court granted Movant’s request and entered two Orders Granting Motion for Relief
18 from the Automatic Stay (the “Orders”) on February 4, 2026. (Dkt. Nos. 181, 182).
19 4. Specifically, the Orders terminated the stay as to Debtor and the Debtor’s bankruptcy estate
20 and permitted Movant to enforce its remedies to repossess or obtain possession and dispose of the
21 vehicles in accordance with applicable nonbankruptcy law. (Dkt. Nos. 181, 182).
22 5. Movant needs to conduct the Debtor's 2004 examination in order to investigate and
23 determine where the 2021 Isuzu NPR-HD identified by VIN 54DC4W1D7MS209733 is located
24 and how to retrieve it.
25 6. The examination cannot proceed under F.R.B.P. Rules 7030 and 9014
26 because there is pending no adversary proceeding or contested matter wherein the merits of the
27 matters referred to hereinabove may be scrutinized. Discovery may not proceed in the State Court
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1 Litigation because of the strictures of 11 U.S.C. § 362.
2 7. Pursuant to LBR 2004-1, I have communicated with Debtor’s counsel, Byron Moldo and
3 Chase Stone of Ervin, Cohen and Jessup regarding a mutually agreeable date to conduct the
4 examination.
5 8. I communicated with Debtor’s counsel Byron Moldo telephonically on July 8, 2026,
6 and on July 15, 2026.
7 9. I have also been in communication with Debtor’s counsel Chase Stone and Byron Moldo
8 via email between June 3, 2026, and July 14, 2026.
9 10. I was informed by Debtor’s counsel Byron Moldo that he was not able to obtain a response
10 from Debtor’s principal regarding either the location of the vehicle or availability for a 2004 exam.
11 11. Since the parties were not able to agree upon a date and time to conduct the examination, I
12 am requesting that the examination be conducted on July 30, 2026, at 11:00 a.m. at the law firm of
13 Hemar, Rousso and Heald, located at 15910 Ventura Blvd., 12th Floor, Encino, CA 91436, to be
14 conducted in person.
15 I declare under the penalty of perjury under the laws of the United States of America that
16 the foregoing is true and correct. Executed on July 16, 2026, at Encino, California.
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18 /s/ Angela N. Gill
ANGELA N. GILL
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EXHIBIT 1
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Fill in this information to identify the case:
Debtor 1 CIS International Holdings Corporation
__________________________________________________________________
Debtor 2 ________________________________________________________________
(Spouse, if filing)
__________
United States Bankruptcy Court for the: Central District of of __________
California
District
Case number 2:25-bk-18374-BR
___________________________________________
Official Form 410
Proof of Claim
Read the instructions before filling out this form. This form is for making a claim for payment in a bankruptcy case. Do not use this form to
make a request for payment of an administrative expense. Make such a request according to 11 U.S.C. § 503.
Filers must leave out or redact information that is entitled to privacy on this form or on any attached documents. Attach redacted copies of any
documents that support the claim, such as promissory notes, purchase orders, invoices, itemized statements of running accounts, contracts, judgments,
mortgages, and security agreements. Do not send original documents; they may be destroyed after scanning. If the documents are not available,
explain in an attachment.
A person who files a fraudulent claim could be fined up to $500,000, imprisoned for up to 5 years, or both. 18 U.S.C. §§ 152, 157, and 3571.
Fill in all the information about the claim as of the date the case was filed. That date is on the notice of bankruptcy (Form 309) that you received.
Part 1: Identify the Claim
1. Who is the current
creditor?
Tokyo Century (USA) Inc.
___________________________________________________________________________________________________________
Name of the current creditor (the person or entity to be paid for this claim)
Other names the creditor used with the debtor Isuzu Finance of America, Inc.
________________________________________________________________________
2. Has this claim been ✔ No
acquired from
someone else? Yes. From whom? ______________________________________________________________________________________________________
3. Where should notices Where should notices to the creditor be sent? Where should payments to the creditor be sent? (if
and payments to the different)
creditor be sent?
c/o Dressler Peters LLC
_____________________________________________________ _____________________________________________________
Federal Rule of Name Name
Bankruptcy Procedure
(FRBP) 2002(g) 101 W. Grand Ave., Ste. 404
______________________________________________________ ______________________________________________________
Number Street Number Street
Chicago IL 60654
______________________________________________________ ______________________________________________________
City State ZIP Code City State ZIP Code
Contact phone (312) 602-7360
________________________ Contact phone ________________________
Contact email ddressler@dresslerpeters.com
________________________ Contact email ________________________
Uniform claim identifier (if you use one):
__ __ __ __ __ __ __ __ __ __ __ __ __ __ __ __ __ __ __ __ __ __ __ __
4. Does this claim amend ✔ No
one already filed?
Yes. Claim number on court claims registry (if known) ________ Filed on ________________________
MM / DD / YYYY
5. Do you know if anyone ✔ No
else has filed a proof Yes. Who made the earlier filing? _____________________________
of claim for this claim?
Official Form 410 Proof of Claim page 1
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Part 2: Give Information About the Claim as of the Date the Case Was Filed
6. Do you have any number ✔ No
you use to identify the Yes. Last 4 digits of the debtor’s account or any number you use to identify the debtor: ____ ____ ____ ____
debtor?
7. How much is the claim? 65,096.08 Does this amount include interest or other charges?
$_____________________________.
No
✔ Yes. Attach statement itemizing interest, fees, expenses, or other
charges required by Bankruptcy Rule 3001(c)(2)(A).
8. What is the basis of the Examples: Goods sold, money loaned, lease, services performed, personal injury or wrongful death, or credit card.
claim?
Attach redacted copies of any documents supporting the claim required by Bankruptcy Rule 3001(c).
Limit disclosing information that is entitled to privacy, such as health care information.
Secured Promissory Notes
______________________________________________________________________________
9. Is all or part of the claim No
secured? ✔ Yes. The claim is secured by a lien on property.
Nature of property:
Real estate. If the claim is secured by the debtor’s principal residence, file a Mortgage Proof of Claim
Attachment (Official Form 410-A) with this Proof of Claim.
Motor vehicle
✔ Other. Describe:
2021 Isuzu NPR-HD, 2021 Isuzu NPR-HDG
_____________________________________________________________
Basis for perfection: Certificates of Title
_____________________________________________________________
Attach redacted copies of documents, if any, that show evidence of perfection of a security interest (for
example, a mortgage, lien, certificate of title, financing statement, or other document that shows the lien has
been filed or recorded.)
Value of property: 51,100.00
$__________________
Amount of the claim that is secured: 51,100.00
$__________________
13,996.08 (The sum of the secured and unsecured
Amount of the claim that is unsecured: $__________________
amounts should match the amount in line 7.)
Amount necessary to cure any default as of the date of the petition: $____________________
Annual Interest Rate (when case was filed)_______%
Fixed
Variable
10. Is this claim based on a ✔ No
lease?
Yes. Amount necessary to cure any default as of the date of the petition. $____________________
11. Is this claim subject to a ✔ No
right of setoff?
Yes. Identify the property: ___________________________________________________________________
Official Form 410 Proof of Claim page 2
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12. Is all or part of the claim ✔ No
entitled to priority under
11 U.S.C. § 507(a)? Yes. Check one: Amount entitled to priority
A claim may be partly Domestic support obligations (including alimony and child support) under
priority and partly 11 U.S.C. § 507(a)(1)(A) or (a)(1)(B). $____________________
nonpriority. For example,
in some categories, the Up to $* of deposits toward purchase, lease, or rental of property or services for
law limits the amount personal, family, or household use. 11 U.S.C. § 507(a)(7). $____________________
entitled to priority.
Wages, salaries, or commissions (up to $1,*) earned within 180 days before the
bankruptcy petition is filed or the debtor’s business ends, whichever is earlier. $____________________
11 U.S.C. § 507(a)(4).
Taxes or penalties owed to governmental units. 11 U.S.C. § 507(a)(8). $____________________
Contributions to an employee benefit plan. 11 U.S.C. § 507(a)(5). $____________________
Other. Specify subsection of 11 U.S.C. § 507(a)(__) that applies. $____________________
* Amounts are subject to adjustment on 4/01/ and every 3 years after that for cases begun on or after the date of adjustment.
Part 3: Sign Below
The person completing Check the appropriate box:
this proof of claim must
sign and date it. I am the creditor.
FRBP 9011(b). ✔ I am the creditor’s attorney or authorized agent.
If you file this claim I am the trustee, or the debtor, or their authorized agent. Bankruptcy Rule 3004.
electronically, FRBP
5005(a)() authorizes courts
I am a guarantor, surety, endorser, or other codebtor. Bankruptcy Rule 3005.
to establish local rules
specifying what a signature
is. I understand that an authorized signature on this Proof of Claim serves as an acknowledgment that when calculating the
amount of the claim, the creditor gave the debtor credit for any payments received toward the debt.
A person who files a
fraudulent claim could be I have examined the information in this Proof of Claim and have a reasonable belief that the information is true
fined up to $500,000, and correct.
imprisoned for up to 5
years, or both.
18 U.S.C. §§ 152, 157, and I declare under penalty of perjury that the foregoing is true and correct.
3571.
Executed on date 11/17/2025
_________________
MM / DD / YYYY
/s/ Dennis A. Dressler
________________________________________________________________________
Signature
Print the name of the person who is completing and signing this claim:
Name Dennis A. Dressler
_______________________________________________________________________________________________
First name Middle name Last name
Title Attorney
_______________________________________________________________________________________________
Company Dressler Peters, LLC
_______________________________________________________________________________________________
Identify the corporate servicer as the company if the authorized agent is a servicer.
Address 101 W. Grand Ave., Ste. 404
_______________________________________________________________________________________________
Number Street
Chicago IL 60654
_______________________________________________________________________________________________
City State ZIP Code
Contact phone (312) 602-7360
_____________________________ Email ddressler@dresslerpeters.com
____________________________________
Official Form 410 Proof of Claim page 3
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PURCHASE OF LOAN CONTRACT
This Purchase of Loan Contract (this “Purchase Contract”) is executed pursuant to the Master Loan and
Sale and Assignment Agreement dated as of May 16, 2007 (the “Agreement”), by and between ISUZU
FINANCE OF AMERICA, INC., as Assignor, and TOKYO CENTURY (USA) INC., as Assignee.
This Purchase Contract is dated, and the assignment described below is effective, as of the date set forth
below and hereby expressly incorporates the terms and conditions of the Agreement.
1. Dealer Isuzu Truck Of La Crosse
2. Obligor (Borrower) CIS International Holdings (N.A.) Corp.
3. Guarantor
4. Date of (Loan) Contract 5/16/2022
5. Contract Documents (See Schedule A)
6. Total Invoice Cost (Amount Financed) $58,457.50
7. Payments to be due under Purchase Contract
(a) Term 60
(b) Amount of each payment $1,123.09
(c) Balloon Payment $1,123.09
8. Consideration (6) $58,457.50
9. Acquisition Fee to Assignee (TCUSA) $250.00
10. Referral Fee $700.00
11. Dealer Markup $2,240.70
12. Purchase Amount (8-9+10+11) $61,148.20
Date of Execution: May 24, 2022
ASSIGNOR: ISUZU FINANCE OF AMERICA, INC.
By: ___________________________________________
Name: ___________________________________________
Title: ___________________________________________
ASSIGNEE: TOKYO CENTURY (USA) INC.
By: ___________________________________________
Name: ___________________________________________
Title: ___________________________________
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PURCHASE OF LOAN CONTRACT
This Purchase of Loan Contract (this “Purchase Contract”) is executed pursuant to the Master Loan and
Sale and Assignment Agreement dated as of May 16, 2007 (the “Agreement”), by and between ISUZU
FINANCE OF AMERICA, INC., as Assignor, and TOKYO CENTURY (USA) INC., as Assignee.
This Purchase Contract is dated, and the assignment described below is effective, as of the date set forth
below and hereby expressly incorporates the terms and conditions of the Agreement.
1. Dealer Isuzu Truck Of La Crosse
2. Obligor (Borrower) CIS International Holdings (N.A.) Corp.
3. Guarantor
4. Date of (Loan) Contract 12/27/2022
5. Contract Documents (See Schedule A)
6. Total Invoice Cost (Amount Financed) $61,325.28
7. Payments to be due under Purchase Contract
(a) Term 60
(b) Amount of each payment $1,207.74
(c) Balloon Payment $1,207.74
8. Consideration (6) $61,325.28
9. Acquisition Fee to Assignee (TCUSA) $250.00
10. Referral Fee $700.00
11. Dealer Markup $2,387.28
12. Purchase Amount (8-9+10+11) $64,162.56
Date of Execution: December 30, 2022
ASSIGNOR: ISUZU FINANCE OF AMERICA, INC.
By: ___________________________________________
Name: ___________________________________________
Title: ___________________________________________
ASSIGNEE: TOKYO CENTURY (USA) INC.
By: ___________________________________________
Name: ___________________________________________
Title: ___________________________________
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Case 2:25-bk-18374-BR Doc 210 Filed 07/16/26 Entered 07/16/26 12:20:04 Desc
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PROOF OF SERVICE OF DOCUMENT
1
I am over the age of 18 and not a party to this bankruptcy case or adversary proceeding. My business
2 address is: 15910 Ventura Blvd., 12th Floor, Encino, California 91436
3 A true and correct copy of the foregoing document described as MOTION FOR EXAMINATION UNDER
RULE 2004; DECLARATION OF ANGELA N. GILL AND TITO CABRERA IN SUPPORT THEREOF will
4 be served or was served (a) on the judge in chambers in the form and manner required by LBR 5005-2(d);
and (b) in the manner indicated below:
5
I. TO BE SERVED BY THE COURT VIA NOTICE OF ELECTRONIC FILING (“NEF”) – Pursuant to
6 controlling General Order(s) and Local Bankruptcy Rule(s) (“LBR”), the foregoing document will be served
by the court via NEF and hyperlink to the document. On July 16, 2026, I checked the CM/ECF docket for
7 this bankruptcy case or adversary proceeding and determined that the following person(s) are on the
Electronic Mail Notice List to receive NEF transmission at the email address(es) indicated below:
8
9
Service information continued on attached page
10
II. SERVED BY U.S. MAIL (indicate method for each person or entity served):
11 On July 16, 2026, I served the following person(s) and/or entity(ies) at the last known address(es) in this
bankruptcy case or adversary proceeding by placing a true and correct copy thereof in a sealed envelope
12 in the United States Mail, first class, postage prepaid, and/or with an overnight mail service addressed as
follows. Listing the judge here constitutes a declaration that mailing to the judge will be completed no later
13 than 24 hours after the document is filed.
14
Service information continued on attached page
15
III. SERVED BY PERSONAL DELIVERY (indicate method for each person or entity served): Pursuant to
16 F.R.Civ.P. 5 and/or controlling LBR, on July 16, 2026, I served the following person(s) and/or entity(ies) by
personal delivery, or (for those who consented in writing to such service method), by facsimile transmission
17 and/or email as follows. Listing the judge here constitutes a declaration that personal delivery on the judge
will be completed no later than 24 hours after the document is filed.
18
Judge’s Copy
19 Hon. Barry Russell
United States Bankruptcy Court
20 255 E. Temple Street, Suite 1660
Los Angeles, CA 90012
21
Service information continued on attached page
22
I declare under penalty of perjury under the laws of the United States of America that the foregoing is true
23 and correct.
24
July 16, 2026 Sanaz Adnani /s/ Sanaz Adnani
25 Date Type Name Signature
26
27
28
9
29 MOTION FOR RULE 2004 EXAMINATION
30
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1 NOTICE OF ELECTRONIC FILING (NEF):
2 • Ismail Amin iamin@talglaw.com, pgilmore@talglaw.com; kvescera@talglaw.com;
shalberstadt@talglaw.com; cstark@talglaw.com; ckim@talglaw.com;
3 eavakian@talglaw.com; knarh@talglaw.com; kmeade@talglaw.com;
kanderson@talglaw.com
4 • Christopher Beyer cab@replevin.com, ecf@writofseizure.com
• Michael D Breslauer mbreslauer@swsslaw.com, sdurazo@swsslaw.com
5 • Steve Burnell Steve.Burnell@gmlaw.com, sburnell@ecf.courtdrive.com;
sburnell@ecf.inforuptcy.com;patricia.dillamar@gmlaw.com;CourtMail@gmlaw.com
6 • Richard P Cook richard@capefeardebtrelief.com
• Caroline Djang cdjang@buchalter.com,
7 docket@buchalter.com;lverstegen@buchalter.com
• Dennis A Dressler ddressler@dresslerpeters.com
8 • James R Felton jfelton@gblawllp.com,
ystotland@gblawllp.com;msingleman@gblawllp.com
9 • David M Goodrich (TR) dgoodrich@go2.law,
c143@ecfcbis.com;dgoodrich11@ecf.axosfs.com;lrobles@go2.law
10 • Michael Jones michael.jones4@usdoj.gov
• Raffi Khatchadourian raffi@hemar-rousso.com
11 • Ron Maroko ron.maroko@usdoj.gov
• Byron Z Moldo bmoldo@ecjlaw.com,
12 aantonio@ecjlaw.com,dperez@ecjlaw.com,scarson@ecjlaw.com
• Christopher S Murphy bk-cmurphy@oag.texas.gov
13 • Scott Olson solson@seyfarth.com, chidocket@seyfarth.com
• Kurt Ramlo RamloLegal@gmail.com, kr@ecf.courtdrive.com;ramlo@recap.email
14 • Patrick J Schurr patrick.schurr@solidcounsel.com
• Amitkumar Sharma amit.sharma@aisinfo.com
15 • Chase Aleksander Stone cstone@ecjlaw.com, aantonio@ecjlaw.com,
dperez@ecjlaw.com, scarson@ecjlaw.com, elivermore@ecjlaw.com
16 • United States Trustee (LA) ustpregion16.la.ecf@usdoj.gov
• Cranston J Williams cwilliams3@socalgas.com
17 • Jennifer C Wong bknotice@mccarthyholthus.com, jwong@ecf.courtdrive.com
18 SERVICE LIST BY U.S. MAIL:
19 CIS International Holdings (N.A.) Corporation
Attn: President, Charitha Samarasinghe
20 1405 W. 178th Street
Gardena, CA 90248
21
Lauren T Attard
22 Baker & Hostetler LLP
1900 Avenue of the Stars, Suite 2700
23 Los Angeles, CA 90067
24 Ervin Cohen & Jessup LLP
Attn: Byron Z. Moldo
25 9401 Wilshire Blvd., 12th Floor
Beverly Hills, CA 90212
26
Panthers Capital LLC
27 Benjamin Isaacov, CEO & President
9 W Broad St, Suite 320
28 Stamford, CT 06902
10
29 MOTION FOR RULE 2004 EXAMINATION
30