Case 2:25-bk-18374-BR Doc 210 Filed 07/16/26 Entered 07/16/26 12:20:04 Desc Main Document Page 1 of 28 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. 6 7 8 UNITED STATES BANKRUPTCY COURT 9 CENTRAL DISTRICT OF CALIFORNIA, LOS ANGELES DIVISION 10 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 ___________________________________ 22 TO THE HONORABLE BARRY RUSSELL UNITED STATES BANKRUPTCY JUDGE, THE 23 UNITED STATES TRUSTEE, CHAPTER 7 TRUSTEE, DEBTOR AND ALL PARTIES IN 24 INTEREST: 25 PLEASE TAKE NOTICE that pursuant to Federal Rule of Bankruptcy Procedure 2004 26 and Local Bankruptcy Rule 2004-1, TOKYO CENTURY (USA) INC. (“Movant”) moves the 27 Court for an order authorizing the examination of CIS INTERNATIONAL HOLDINGS (N.A.) 28 1 29 MOTION FOR RULE 2004 EXAMINATION 30 Case 2:25-bk-18374-BR Doc 210 Filed 07/16/26 Entered 07/16/26 12:20:04 Desc Main Document Page 2 of 28 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. 27 28 2 29 MOTION FOR RULE 2004 EXAMINATION 30 Case 2:25-bk-18374-BR Doc 210 Filed 07/16/26 Entered 07/16/26 12:20:04 Desc Main Document Page 3 of 28 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, 28 3 29 MOTION FOR RULE 2004 EXAMINATION 30 Case 2:25-bk-18374-BR Doc 210 Filed 07/16/26 Entered 07/16/26 12:20:04 Desc Main Document Page 4 of 28 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 5 /s/ Angela N. Gill 6 BY: _______________________________ ANGELA N. GILL 7 Attorneys for Creditor/Movant TOKYO CENTURY (USA) INC. 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 4 29 MOTION FOR RULE 2004 EXAMINATION 30 Case 2:25-bk-18374-BR Doc 210 Filed 07/16/26 Entered 07/16/26 12:20:04 Desc Main Document Page 5 of 28 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. 28 5 29 MOTION FOR RULE 2004 EXAMINATION 30 Case 2:25-bk-18374-BR Doc 210 Filed 07/16/26 Entered 07/16/26 12:20:04 Desc Main Document Page 6 of 28 Case 2:25-bk-18374-BR Doc 210 Filed 07/16/26 Entered 07/16/26 12:20:04 Desc Main Document Page 7 of 28 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 28 7 29 MOTION FOR RULE 2004 EXAMINATION 30 Case 2:25-bk-18374-BR Doc 210 Filed 07/16/26 Entered 07/16/26 12:20:04 Desc Main Document Page 8 of 28 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. 17 18 /s/ Angela N. Gill ANGELA N. GILL 19 20 21 22 23 24 25 26 27 28 8 29 MOTION FOR RULE 2004 EXAMINATION 30 Case 2:25-bk-18374-BR Doc 210 Filed 07/16/26 Entered 07/16/26 12:20:04 Desc Main Document Page 9 of 28 EXHIBIT 1 Case Case 2:25-bk-18374-BR 2:25-bk-18374-BR Doc Claim210 11-1 Filed Filed 07/16/26 11/17/25 Entered Desc Main 07/16/26 Document 12:20:04 Page Desc1 Main Documentof 3 Page 10 of 28 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 Case Case 2:25-bk-18374-BR 2:25-bk-18374-BR Doc Claim210 11-1 Filed Filed 07/16/26 11/17/25 Entered Desc Main 07/16/26 Document 12:20:04 Page Desc2 Main Documentof 3 Page 11 of 28 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 Case Case 2:25-bk-18374-BR 2:25-bk-18374-BR Doc Claim210 11-1 Filed Filed 07/16/26 11/17/25 Entered Desc Main 07/16/26 Document 12:20:04 Page Desc3 Main Documentof 3 Page 12 of 28 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 Case Case2:25-bk-18374-BR 2:25-bk-18374-BR Doc Claim 21011-1 Filed Part 2 07/16/26 Filed 11/17/25 Entered Desc 07/16/26 Exhibit 12:20:04Page Desc 1 Main Document of 14 Page 13 of 28 Case Case2:25-bk-18374-BR 2:25-bk-18374-BR Doc Claim 21011-1 Filed Part 2 07/16/26 Filed 11/17/25 Entered Desc 07/16/26 Exhibit 12:20:04Page Desc 2 Main Document of 14 Page 14 of 28 Case Case2:25-bk-18374-BR 2:25-bk-18374-BR Doc Claim 21011-1 Filed Part 2 07/16/26 Filed 11/17/25 Entered Desc 07/16/26 Exhibit 12:20:04Page Desc 3 Main Document of 14 Page 15 of 28 Case Case2:25-bk-18374-BR 2:25-bk-18374-BR Doc Claim 21011-1 Filed Part 2 07/16/26 Filed 11/17/25 Entered Desc 07/16/26 Exhibit 12:20:04Page Desc 4 Main Document of 14 Page 16 of 28 Case Case2:25-bk-18374-BR 2:25-bk-18374-BR Doc Claim 21011-1 Filed Part 2 07/16/26 Filed 11/17/25 Entered Desc 07/16/26 Exhibit 12:20:04Page Desc 5 Main Document of 14 Page 17 of 28 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: ___________________________________ Case Case2:25-bk-18374-BR 2:25-bk-18374-BR Doc Claim 21011-1 Filed Part 2 07/16/26 Filed 11/17/25 Entered Desc 07/16/26 Exhibit 12:20:04Page Desc 6 Main Document of 14 Page 18 of 28 Case Case2:25-bk-18374-BR 2:25-bk-18374-BR Doc Claim 21011-1 Filed Part 2 07/16/26 Filed 11/17/25 Entered Desc 07/16/26 Exhibit 12:20:04Page Desc 7 Main Document of 14 Page 19 of 28 Case Case2:25-bk-18374-BR 2:25-bk-18374-BR Doc Claim 21011-1 Filed Part 2 07/16/26 Filed 11/17/25 Entered Desc 07/16/26 Exhibit 12:20:04Page Desc 8 Main Document of 14 Page 20 of 28 Case Case2:25-bk-18374-BR 2:25-bk-18374-BR Doc Claim 21011-1 Filed Part 2 07/16/26 Filed 11/17/25 Entered Desc 07/16/26 Exhibit 12:20:04Page Desc 9 Main Document of 14 Page 21 of 28 Case Case2:25-bk-18374-BR 2:25-bk-18374-BR Doc Claim 210 11-1Filed Part 2 07/16/26 Filed 11/17/25 Entered Desc 07/16/26 Exhibit 12:20:04 Page Desc 10 Main Document of 14 Page 22 of 28 Case Case2:25-bk-18374-BR 2:25-bk-18374-BR Doc Claim 210 11-1Filed Part 2 07/16/26 Filed 11/17/25 Entered Desc 07/16/26 Exhibit 12:20:04 Page Desc 11 Main Document of 14 Page 23 of 28 Case Case2:25-bk-18374-BR 2:25-bk-18374-BR Doc Claim 210 11-1Filed Part 2 07/16/26 Filed 11/17/25 Entered Desc 07/16/26 Exhibit 12:20:04 Page Desc 12 Main Document of 14 Page 24 of 28 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: ___________________________________ Case Case2:25-bk-18374-BR 2:25-bk-18374-BR Doc Claim 210 11-1Filed Part 2 07/16/26 Filed 11/17/25 Entered Desc 07/16/26 Exhibit 12:20:04 Page Desc 13 Main Document of 14 Page 25 of 28 Case Case2:25-bk-18374-BR 2:25-bk-18374-BR Doc Claim 210 11-1Filed Part 2 07/16/26 Filed 11/17/25 Entered Desc 07/16/26 Exhibit 12:20:04 Page Desc 14 Main Document of 14 Page 26 of 28 Case 2:25-bk-18374-BR Doc 210 Filed 07/16/26 Entered 07/16/26 12:20:04 Desc Main Document Page 27 of 28 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 Case 2:25-bk-18374-BR Doc 210 Filed 07/16/26 Entered 07/16/26 12:20:04 Desc Main Document Page 28 of 28 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