CIS International Holdings (N.A.) Corporation — Entry #214: Application Filed by Debtor CIS International Holdings (N.A.) Corporation (Malmed, Shantal)
Case: CIS International Holdings (N.A.) Corporation cacb · 2:25-bk-18374
filed September 22, 2025
What this document is
Docket entry #214 · filed October 27, 2026
Application Filed by Debtor CIS International Holdings (N.A.) Corporation (Malmed, Shantal)
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
84 page(s), 234,000 characters, converted from the PDF's text layer · plain text.
Full text
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1 Byron Z. Moldo (CA SBN 109652)
bmoldo@ecjlaw.com
2 Chase A. Stone (CA SBN 335228)
cstone@ecjlaw.com
3 Shantal Malmed (CA SBN 351496)
smalmed@ecjlaw.com
4 ERVIN COHEN & JESSUP LLP
9401 Wilshire Boulevard, Twelfth Floor
5 Beverly Hills, California 90212-2974
Telephone: (310) 273-6333
6 Facsimile: (310) 859-2325
7 Attorneys for CIS International Holdings (N.A.)
Corporation, dba E Tropical Fish, Former Chapter
8 11 Debtor and Debtor-in-Possession
9 UNITED STATES BANKRUPTCY COURT
10 CENTRAL DISTRICT OF CALIFORNIA, LOS ANGELES DIVISION
11 In re: Case No. 2:25-bk-18374-BR
12 CIS International Holdings (N.A.) Chapter 7
Corporation,
13 Hon. Barry Russell
Debtor.
14 FIRST AND FINAL APPLICATION FOR
COMPENSATION AND REIMBURSEMENT
15 OF FEES AND EXPENSES INCURRED
BETWEEN SEPTEMBER 22, 2025 AND
16 OCTOBER 23, 2026 BY ERVIN COHEN &
JESSUP LLP AS GENERAL BANKRUPTCY
17 COUNSEL TO CHAPTER 11 DEBTOR AND
DEBTOR-IN-POSSESSION;
18 DECLARATION OF BYRON Z. MOLDO IN
SUPPORT THEREOF
19
[No hearing required pursuant to LBR 9013-1(o)]
20
21 TO THE HONORABLE BARRY RUSSELL, UNITED STATES BANKRUPTCY
22 JUDGE, THE OFFICE OF THE UNITED STATES TRUSTEE, AND ALL PARTIES IN
23 INTEREST:
24 Ervin Cohen & Jessup LLP (“ECJ”), general bankruptcy counsel to CIS International
25 Holdings (N.A.) Corporation, dba E Tropical Fish, the former chapter 11 debtor and debtor-in-
26 possession (the “Debtor”), hereby submits its First and Final Application for Compensation and
27 Reimbursement of Expenses by Ervin Cohen & Jessup LLP as General Bankruptcy Counsel to
28 Chapter 11 Debtor and Debtor-in-Possession (the “Application”) for services rendered and
18899.1:12550439.1
FIRST AND FINAL APPLICATION FOR PAYMENT OF FEES AND/OR EXPENSES BY ERVIN COHEN &
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1 expenses incurred during the period of September 22, 2025 through October 23, 2026 (the “Subject
2 Period”). ECJ respectfully requests that the Court grant this Application and allow, on a final basis,
3 compensation of $167,091.50 in fees and $1,665.74 in expenses incurred during the Subject Period,
4 for a total of $168,757.24, which constitutes all of the compensation ECJ seeks in this case.
5 (i) Name of Applicant: Ervin Cohen & Jessup LLP
6 (ii) Type of services rendered: General bankruptcy counsel to the Debtor.
7 (iii) Date of filing of petition under Chapter 11: September 22, 2025 [Dkt. No. 1].
8 (iv) Date of entry of Order Approving Applicant’s Employment: December 3, 2025
9 [Dkt. No. 132], approving the application to employ ECJ, effective as of September 22, 2025.
10 (v) Date of entry of Order Converting Case to Chapter 7: October 22, 2025 [Dkt.
11 No. 80].
12 (vi) Date of filing of last Fee Application: This is ECJ’s first and final fee application.
13 (vii) Total fees and costs allowed or paid to Applicant to date: $0.00 allowed;
14 $36,588.50 in fees paid from ECJ’s pre-petition retainer, of which $26,051.00 was applied to
15 fees for the Subject Period and is subject to approval by this Application, and $10,537.50 was
16 applied to fees for pre-petition services.
17 (a) Retainer received: $50,000
18 (b) Retainer remaining as of the date of this Application: $13,411.50.
19 (c) Total amount requested in all prior applications: $0.00.
20 (d) Total amount actually paid pursuant to prior approved applications: $0.00.
21 (e) Total amount due but unpaid pursuant to prior approved applications: $0.00.
22 (f) Total amount allowed but reserved pending final fee application: $0.00.
23 (viii) Amount requested in this Application: $167,091.50 in fees and $1,665.74 in
24 expenses, for a total of $168,757.24.
25 (ix) Net amount requested to be paid: $127,629.00 in fees and $1,665.74 in expenses,
26 for a total of $129,294.74, after crediting the $26,051.00 already applied from ECJ’s retainer
27 to fees for the Subject Period and applying the remaining $13,411.50 retainer balance.
28 ///
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1 1. Nature of ECJ’s Representation
2 ECJ served as general bankruptcy counsel to the Debtor in its chapter 11 case from the
3 Petition Date (defined below) until the case was converted to chapter 7 on October 22, 2025. After
4 conversion, ECJ continued to represent the Debtor in connection with its duties as a chapter 7 debtor,
5 including preparation of the final report required by Federal Rule of Bankruptcy Procedure 1019(5),
6 attendance at the meeting of creditors under 11 U.S.C. § 341(a), and cooperation with the chapter 7
7 trustee, David M. Goodrich (the “Trustee”).
8 2. Employment of ECJ
9 On October 13, 2025, the Debtor filed its Application of Debtor and Debtor-in-Possession
10 for Authority to Employ Ervin Cohen & Jessup LLP as General Bankruptcy Counsel, Effective
11 September 22, 2025 [Dkt. No. 40], together with a notice of opportunity to request a hearing under
12 LBR 9013-1(o) [Dkt. No. 41]. No party requested a hearing [Dkt. No. 125]. On December 3, 2025,
13 the Court entered its Order Approving Application to Employ Ervin Cohen & Jessup LLP as General
14 Bankruptcy Counsel [Dkt. No. 132], approving the application. The application sought ECJ’s
15 employment effective as of September 22, 2025. A copy of the employment order is attached hereto
16 as Exhibit “2.”
17 3. Period Covered by This First and Final Application
18 This Application is made pursuant to 11 U.S.C. §§ 329 and 330, Federal Rule of Bankruptcy
19 Procedure 2016, and LBR 2016-1, and covers the period from September 22, 2025 through October
20 23, 2026. ECJ has not filed any prior fee application in this case.
21 4. Events That Led to the Filing of the Petition
22 The Debtor operated from its facility at 1405 W. 178th Street in Gardena, California, where
23 it imported and distributed tropical fish and aquatic products to retail customers, including Petco
24 Animal Supplies Stores, Inc. (“Petco”). In the months before the petition was filed, the Debtor
25 came under mounting pressure from its secured and merchant cash advance lenders. Panthers
26 Capital LLC (“Panthers”), which claimed to hold a security interest in the Debtor’s accounts
27 receivable as assignee of Quick Funding, sued the Debtor and sought entry of default, and asserted
28 rights to the payments Petco owed the Debtor. Other lenders, including Settle Funding, LLC
3
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1 (“Settle”) and Newtek Bank, N.A. (“Newtek”), also asserted UCC-1 liens on the Debtor’s assets.
2 At the same time, the Debtor faced threats of disconnection of its utility service, a potential unlawful
3 detainer proceeding, and a state court receivership affecting its landlord, Lionsrock Investments
4 LLC. Facing a liquidity crisis and the loss of access to its principal source of cash, the Debtor filed
5 a voluntary petition under chapter 11 of the Bankruptcy Code on September 22, 2025 (the “Petition
6 Date”) [Dkt. No. 1] to preserve its business and its accounts receivable for the benefit of its creditors.
7 5. The Chapter 11 Case
8 a. Compliance With U.S. Trustee Requirements and Filing of Schedules
9 Immediately after the Petition Date, ECJ assisted the Debtor in meeting its obligations as a
10 debtor-in-possession, including preparing and submitting the Office of the United States Trustee’s
11 seven-day package and required forms, opening a debtor-in-possession account, closing pre-petition
12 bank accounts, and providing proof of insurance. ECJ prepared the Debtor’s principals for, and
13 attended, the initial debtor interview and the § 341(a) meeting of creditors held on October 6, 2025.
14 ECJ also prepared and filed the Debtor’s Schedules and related documents on October 6, 2025 [Dkt.
15 No. 16], obtained an order extending the deadline to file the remaining schedules and statements
16 [Dkt. Nos. 17, 21], and filed Schedule A/B and the Statement of Financial Affairs on October 20,
17 2025 [Dkt. No. 65], after the Court denied the Debtor’s second request for an extension [Dkt. Nos.
18 51, 52].
19 b. Stipulation With Petco for Turnover of Funds
20 Petco was holding funds owed to the Debtor that were essential to the Debtor’s continued
21 operations. ECJ promptly made demand on Petco under 11 U.S.C. § 542, and thereafter, negotiated
22 a stipulation for turnover of those funds, then filed the stipulation on October 3, 2025 [Dkt. No. 15].
23 The Court approved the stipulation on October 7, 2025 [Dkt. No. 22]. Notably, after conversion to
24 Chapter 7, Panthers moved for reconsideration of the Order approving the stipulation [Dkt. No.
25 100]. Petco opposed the motion, supported by a declaration from ECJ attorney Chase Stone [Dkt.
26 No. 128], and Settle, Newtek, and the Trustee also opposed it [Dkt. Nos. 129–131]. The Court
27 denied the motion for reconsideration on December 24, 2025 [Dkt. No. 156].
28 / / /
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1 c. Emergency First Day Motions
2 On October 10, 2025, ECJ filed six emergency motions on the Debtor’s behalf: (i) a motion
3 for order limiting notice [Dkt. No. 31]; (ii) a motion to pay pre-petition priority wages [Dkt. No.
4 32]; (iii) a motion to provide adequate assurance of future payment to utility companies under 11
5 U.S.C. § 366 [Dkt. No. 33]; (iv) a motion to pay pre-petition claims of critical vendors [Dkt. No.
6 34]; (v) a motion for authority to use cash collateral [Dkt. No. 35]; and (vi) a motion for permission
7 to file a memorandum exceeding 35 pages [Dkt. No. 36]. The motions were supported by the
8 omnibus declaration of the Debtor’s principal, Charitha Samarasinghe [Dkt. No. 37], and a statement
9 regarding cash collateral [Dkt. No. 38].
10 Before and after filing the motions, ECJ worked with the Debtor’s accountant to prepare a
11 13-week budget and negotiated with Panthers, Settle, Newtek, and other secured lenders for consent
12 to the Debtor’s use of cash collateral, including a limited request to use cash collateral to pay priority
13 wages. Panthers filed a notice of non-consent [Dkt. No. 30], and the U.S. Trustee, Settle, Panthers,
14 and Southern California Gas Company filed oppositions [Dkt. Nos. 55–58, 64]. ECJ filed an
15 omnibus reply on October 20, 2025 [Dkt. No. 61] and argued the motions at the hearing on October
16 21, 2025. The Court denied each of the emergency motions by orders entered October 22, 2025
17 [Dkt. Nos. 73-78].
18 6. Conversion to Chapter 7
19 Without authority to use cash collateral, the Debtor could not continue operating. In the
20 days after the hearing, ECJ assisted the Debtor in identifying potential sources of debtor-in-
21 possession financing and other alternatives with the Debtor’s principals, prospective lenders, and
22 secured creditors in an effort to keep the business operating. Following the hearing, on October 22,
23 2025, the Court entered its Order Converting Case to Chapter 7 [Dkt. No. 80]. The Trustee was
24 appointed as interim chapter 7 trustee on October 23, 2025 [Dkt. No. 81].
25 7. ECJ’s Post-Conversion Services
26 After conversion, the Debtor remained subject to its duties under 11 U.S.C. § 521 and
27 Federal Rule of Bankruptcy Procedure 1019. ECJ prepared and filed the Final Report of Debtor as
28 Debtor in Possession Upon Conversion of Chapter 11 Case to Chapter 7 Case Pursuant to
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1 Bankruptcy Rule 1019(5) on November 18, 2025 [Dkt. No. 116]. Moreover, ECJ prepared the
2 Debtor’s principals for, and attended, the post-conversion § 341(a) meeting of creditors, which
3 commenced on November 19, 2025, was continued to December 11, 2025 and January 5, 2026, and
4 concluded on January 5, 2026. Throughout this period, ECJ responded to the Trustee’s requests for
5 documents and information about the Debtor’s assets, bank accounts, receivables, liens, and
6 transactions with related entities.
7 ECJ also communicated with the Trustee regarding his emergency motion to abandon real
8 property [Dkt. Nos. 91, 120], his motion to reject the Debtor’s unexpired nonresidential lease [Dkt.
9 Nos. 106, 155], and potential claims against Panthers, and it assisted in defending the Petco turnover
10 order against Panthers’ motion for reconsideration. The Trustee filed a Notice of Assets on
11 December 4, 2025 [Dkt. No. 133], and the deadline for filing proofs of claim was March 9, 2026.
12 8. Available Funds on Hand
13 Based on information provided by the Trustee, as of October 26, 2026, the estate holds
14 approximately $711,194.13 in cash. In addition, ECJ holds $13,411.50 of the Debtor’s pre-petition
15 retainer in its client trust account.
16 9. Estimated Amount of Other Accrued Administrative Expenses
17 ECJ is informed that the estate has incurred, and will continue to incur, chapter 7
18 administrative expenses including the Trustee’s compensation under 11 U.S.C. § 326 and the fees
19 and costs of the Trustee’s general bankruptcy counsel, Greenspoon Marder LLP [Dkt. No. 201], and
20 special litigation counsel, Richard P. Cook, PLLC [Dkt. No. 206]. Post-petition obligations incurred
21 during the chapter 11 case are listed in the Debtor’s Rule 1019(5) final report [Dkt. No. 116]. ECJ
22 is not aware of any other chapter 11 professional that has sought allowance of fees.
23 10. Prior Fee Applications and Payments to Applicant
24 ECJ has not filed any prior fee applications in this case. Prepetition, ECJ received a retainer
25 of $50,000 from the Debtor. ECJ has applied $36,588.50 of the retainer as follows: (i) $10,537.50
26 for pre-petition services rendered between September 8 and September 21, 2025; (ii) $25,986.00 for
27 services rendered between September 22 and September 30, 2025; and (iii) $65.00 for services
28 rendered on February 12, 2026. ECJ does not seek allowance of its fees for pre-petition services in
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1 this Application. The remaining $13,411.50 is held in ECJ’s client trust account. ECJ has received
2 no other payments in this case. To the extent the Court determines that ECJ’s post-petition
3 application of the retainer required prior authorization, ECJ requests that the Court approve those
4 applications through this Application.
5 11. Summary of Compensation Requested
6 ECJ respectfully requests that the Court grant this First and Final Application and allow, on
7 a final basis, compensation in the amount of $167,091.50 in fees and $1,665.74 in expenses incurred
8 during the Subject Period, for a total of $168,757.24, which constitutes all of the compensation ECJ
9 seeks in this case. After crediting the $26,051.00 already applied from the retainer to fees for the
10 Subject Period and applying the remaining $13,411.50 retainer balance, ECJ requests payment of
11 the unpaid balance of $127,629.00 in fees and $1,665.74 in expenses, for a total of $129,294.74.
12 Of the fees requested, $114,768.00 was incurred during the chapter 11 case (September 22,
13 2025 through October 22, 2025), and $52,323.50 was incurred after conversion (October 23, 2025
14 through October 23, 2026). Of the expenses requested, $1,355.69 was incurred during the chapter
15 11 case and $310.05 was incurred after conversion. ECJ professionals expended a total of 234.5
16 hours during the Subject Period, at a blended hourly rate of approximately $712.55:
17 Total Fees Incurred By ECJ For Services For The Subject Period:
(By Professional)
18
PROFESSIONAL HOURS RATE FEES
19 Byron Z. Moldo (Partner) 43.0 $1,075.00 $46,225.00
20 Byron Z. Moldo (Partner) 1.0 $1,150.00 $1,150.00
Jared Slater (Partner) 3.6 $655.00 $2,358.00
21
Chase A. Stone (Senior Associate) 148.1 $650.00 $96,265.00
22
Danielle R. Gabai (Associate) 16.3 $550.00 $8,965.00
23 Dylan Allen (Associate) 6.2 $535.00 $3,317.00
24 Tanner F. Hosfield (Associate) 2.4 $515.00 $1,236.00
Shantal Malmed (Associate) 13.9 $545.00 $7,575.50
25
Totals: 234.5 $167,091.50
26
ECJ’s expenses consist of the following categories. ECJ does not charge for secretarial or
27
word-processing time, local telephone calls, or incoming facsimiles:
28
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1 Total Expenses Incurred By ECJ For The Subject Period:
2 CODE DESCRIPTION AMOUNT
E101 Copying $924.79
3
E106 Online Research $140.91
4 E107 Delivery Services/Messenger $324.90
5 E108 Postage $275.14
6 Totals: $1,665.74
7 12. Summary of Exhibits Attached in Support of Services Rendered
8 Attached hereto are the following exhibits in support of this Application:
9 EXHIBIT DESCRIPTION
Detailed billing records of the time spent by each professional for
10 “1”
applicant, including a breakdown by activity code.
11 A copy of the Order Approving Application to Employ Ervin Cohen & Jessup
“2” LLP as General Bankruptcy Counsel
12 “3” Firm Biographies/Curriculum Vitae
13 13. Narrative of Services
14 Detailed billing records for the Subject Period are attached hereto as Exhibit “1.” ECJ’s
15 services are summarized below by activity code.
16
Total Fees Incurred By ECJ For Services For The Subject Period:
17 (By Activity Code)
18 CODE DESCRIPTION HOURS FEES
B110 Case Administration 52.6 $36,227.50
19
B120 Asset Analysis and Recovery 21.2 $19,390.00
20 B130 Asset Disposition 5.2 $3,422.50
21 B140 Relief from Stay/Adequate Protection 1.5 $975.00
Proceedings
22 B150 Meetings of and Communications with 21.2 $14,460.00
Creditors
23
B160 Fee/Employment Applications 33.3 $20,470.50
24 B170 Fee/Employment Objections 0.2 $130.00
25 B185 Assumption/Rejection of Leases and 1.5 $975.00
Contracts
26
B190 Other Contested Matters 9.5 $6,276.00
27 B210 Business Operations 8.0 $6,822.50
28 B230 Financing/Cash Collateral 62.7 $45,397.50
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1 B240 Tax Issues 3.6 $3,275.00
2 B310 Claims Administration and Objections 1.0 $777.50
B320 Plan and Disclosure Statement 0.7 $497.50
3
B410 General Bankruptcy Advice/Opinions 2.9 $1,885.00
4 B420 Restructurings 9.4 $6,110.00
5 Totals: 234.5 $167,091.50
6
7 Case Administration – B110: 52.6 hours; $36,227.50. ECJ prepared and filed the Debtor’s
8 chapter 11 petition, creditor matrix, and list of twenty largest creditors; prepared and submitted the U.S.
9 Trustee’s seven-day package and USTLA forms and addressed the Debtor’s insurance, debtor-in-
10 possession account, and pre-petition bank account requirements; prepared and filed the Debtor’s
11 schedules and statements and the ex parte motions to extend the deadline to file them; prepared the
12 motions to limit notice and to file a memorandum exceeding 35 pages; and monitored the docket and
13 addressed filing deficiencies. After conversion, ECJ prepared and filed the Rule 1019(5) final report,
14 responded to the Trustee’s general requests for documents and information, and drafted amendments
15 to the schedules. ECJ also communicated regularly with the Debtor’s principals, its accountant, and
16 counsel for interested parties regarding the status of the case. In September and October 2026, ECJ
17 communicated with the Trustee’s counsel, counsel for Tokyo Century, and other parties in interest
18 regarding a requested Rule 2004 examination, the location of estate assets and vehicle collateral, and
19 the retention of separate counsel by the Debtor’s principal.
20 Asset Analysis and Recovery – B120: 21.2 hours; $19,390.00. ECJ investigated the Debtor’s
21 assets, including the receivables held by Petco and the Debtor’s potential claims against Panthers;
22 prepared the demand on Petco and the stipulation for turnover of funds, coordinated the filing of the
23 stipulation, and served the order approving it on Panthers; investigated Panthers’ asserted security
24 interest and its assignment from Quick Funding; reviewed the Debtor’s insurance policies, tax returns,
25 and inter-company transactions with related entities; and conferred with the Debtor’s accountant and
26 principals, and later the Trustee, regarding estate assets, real property transactions, and potential claims
27 against Panthers. After conversion, ECJ analyzed the recordation dates and priority of the UCC-1 liens
28 against the Debtor’s assets and provided the Trustee with information and documents regarding the
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1 Debtor’s bank accounts, its receivables from Petco, and Panthers’ accounts receivable statements.
2 Asset Disposition – B130: 5.2 hours; $3,422.50. ECJ addressed the disposition of certain
3 shipping containers; reviewed the Trustee’s motion to abandon real property, Newtek’s limited
4 opposition, and Panthers’ joinder, and communicated with the Trustee and the Debtor’s principals
5 regarding the motion and the continued hearing; reviewed the Trustee’s notice of assets; and, following
6 the conclusion of the § 341(a) meeting, followed up with the Trustee regarding vehicles and pre-petition
7 liens.
8 Relief from Stay/Adequate Protection Proceedings – B140: 1.5 hours; $975.00. ECJ reviewed
9 correspondence from the Debtor’s litigation counsel regarding the scope of the automatic stay as to the
10 Debtor’s principal, communicated with litigation counsel regarding extending the stay to related
11 entities, and advised the Debtor’s principal regarding relief from stay.
12 Meetings of and Communications with Creditors – B150: 21.2 hours; $14,460.00. ECJ
13 communicated with Ford Motor Credit Company LLC regarding the automatic stay; negotiated with
14 Petco’s counsel regarding the § 542 demand and turnover stipulation; prepared for and attended the
15 initial debtor interview and the October 6, 2025 § 341(a) meeting; communicated with Settle, Panthers,
16 Newtek, DB Group America, Golden State Water, and counsel for the Small Business Administration
17 regarding cash collateral, critical vendor payments, and their respective claims and liens; after
18 conversion, conferred with the Trustee in preparation for the chapter 7 § 341(a) meeting, prepared the
19 Debtor’s principals for and attended the meeting, and followed up on the documents requested at the
20 meeting; and conferred with the Trustee regarding creditor inquiries and with Petco’s counsel regarding
21 the facts supporting Mr. Stone’s declaration.
22 Fee/Employment Applications – B160: 33.3 hours; $20,470.50. ECJ prepared the application
23 to employ ECJ and the related notice, declaration of non-opposition, and lodged order [Dkt. Nos. 40,
24 41, 125, 126]; prepared applications to employ Dominic LoBuglio as the Debtor’s accountant and BPM
25 LLP as special accountant, including the required disclosures and statements of disinterestedness;
26 prepared ECJ’s fee statements for September and October 2025; and began preparation of this
27 Application.
28 ///
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1 ECJ began preparing this Application in November 2025, when it reviewed the applicable
2 Local Bankruptcy Rules, began drafting the Application and supporting declaration, and analyzed
3 ECJ’s eligibility for compensation under 11 U.S.C. §§ 327 and 330. ECJ resumed work on the
4 Application in September 2026. Between September and October 2026, ECJ reviewed its billing
5 records for the Subject Period, drafted and revised the Application, coordinated with its billing
6 department to generate updated billing statements and exhibits, reviewed the docket, conferred with
7 the Trustee’s counsel regarding the funds held by the estate, and reviewed the Local Bankruptcy Rules
8 governing notice of the Application.
9 Fee/Employment Objections – B170: 0.2 hours; $130.00. ECJ reviewed and edited its
10 employment application to confirm the required disclosures and proposed order language.
11 Assumption/Rejection of Leases and Contracts – B185: 1.5 hours; $975.00. ECJ conferred
12 with the Debtor’s litigation counsel regarding the Panthers litigation, UCC-1 issues, and the resolution
13 of a three-party agreement, and, after conversion, reviewed the lodged order on the Trustee’s motion
14 to reject the Debtor’s lease.
15 Other Contested Matters – B190: 9.5 hours; $6,276.00. ECJ reviewed the status of the state
16 court litigation pending against the Debtor; prepared, filed, and served notices of the bankruptcy stay
17 in the state court and workers’ compensation proceedings pending against the Debtor; conferred with
18 the Debtor’s litigation counsel and the Trustee regarding the Panthers litigation, including removal and
19 jurisdictional issues; reviewed Panthers’ reply in support of its motion for reconsideration and
20 communicated with Petco’s counsel regarding Panthers’ asserted security interest; and addressed
21 personal guaranty litigation filed against the Debtor’s principal and a motion to be relieved as counsel
22 in related litigation.
23 Business Operations – B210: 8.0 hours; $6,822.50. ECJ prepared the emergency motion to
24 provide adequate assurance of future payment to utility companies under 11 U.S.C. § 366, including
25 the list of utility providers and proposed deposits; advised the Debtor regarding its continued
26 operations, including proof of insurance, accounting issues with Petco, payments to related entities, and
27 Southern California Gas Company’s objection; and, following the October 21, 2025 hearing, negotiated
28 with the Debtor’s principals and secured creditors regarding the possibility of continued operations.
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1 Financing/Cash Collateral – B230: 62.7 hours; $45,397.50. ECJ worked with the Debtor’s
2 accountant to prepare the budget, cash forecast, and projections; prepared the emergency motions for
3 use of cash collateral, payment of critical vendors, and payment of pre-petition priority wages, together
4 with the supporting omnibus declaration, proposed orders, and notice of the emergency hearing, and
5 coordinated their filing and service; negotiated with Panthers, Settle, Newtek, and Woodmere for
6 consent to the use of cash collateral, including a limited request to use cash collateral to pay priority
7 wages; explored debtor-in-possession financing; analyzed the oppositions and prepared the omnibus
8 reply; and prepared for and argued the motions at the October 21, 2025 hearing.
9 Tax Issues – B240: 3.6 hours; $3,275.00. ECJ advised the Debtor and its accountant regarding
10 sales tax returns, the Debtor’s sales and use tax and workers’ compensation accounts, the payment of
11 its tax obligations, and the preparation of the Debtor’s 2024 tax return, and forwarded an Employment
12 Development Department inquiry to the Trustee.
13 Claims Administration and Objections – B310: 1.0 hours; $777.50. ECJ reviewed Ford Motor
14 Credit Company’s claims and supporting documents, communicated with the Trustee regarding liens,
15 and reviewed proofs of claim filed in the chapter 7 case, including duplicate claims filed by one creditor
16 and a claim filed by the Debtor’s principal.
17 Plan and Disclosure Statement – B320: 0.7 hours; $497.50. ECJ reviewed the Court’s order
18 setting the initial status conference and related deadlines [Dkt. No. 3] and corrected the creditor matrix
19 to cure the 72-hour deficiency [Dkt. No. 2].
20 General Bankruptcy Advice/Opinions – B410: 2.9 hours; $1,885.00. ECJ advised the Debtor’s
21 principals regarding their options following the October 21, 2025 hearing, including debtor-in-
22 possession financing and conversion, and responded to the principals’ inquiries regarding documents
23 and related litigation.
24 Restructurings – B420: 9.4 hours; $6,110.00. Following conversion, ECJ coordinated the
25 transition to chapter 7, including compiling and delivering documentation to the Trustee regarding the
26 Debtor’s UCC filings and related entities; conferred with the Trustee and the Debtor’s principals
27 regarding next steps; analyzed the effect of the automatic stay on related litigation against non-debtors;
28 and communicated with the Debtor’s principals, their counsel, Settle, Altbanc, and the Trustee
12
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1 regarding proposed financing, a possible assignment transaction, the structuring of a new operating
2 entity, a letter of intent, and possible asset sale scenarios.
3 14. ECJ's Fees Are Entitled to Administrative Expense Priority
4 Compensation and reimbursement awarded under 11 U.S.C. § 330(a) is an administrative
5 expense under 11 U.S.C. § 503(b)(2) and is entitled to priority under 11 U.S.C. § 507(a)(2). Because
6 this case was converted, ECJ acknowledges that its allowed fees and expenses incurred during the
7 chapter 11 case are payable in accordance with 11 U.S.C. § 726(b).
8 15. Employment and Post-Conversion Compensation
9 ECJ was employed under 11 U.S.C. § 327(a) and is eligible for compensation under 11
10 U.S.C. § 330. On October 13, 2025, while the case was pending under chapter 11, the Debtor
11 applied for entry of an order under 11 U.S.C. § 327(a) authorizing the Debtor to employ ECJ as
12 general bankruptcy counsel, effective as of September 22, 2025 [Dkt. No. 40]. The application
13 stated that ECJ would seek approval of its compensation and reimbursement of its expenses under
14 11 U.S.C. §§ 330 and 331. No opposition was filed. On December 3, 2025, after the case was
15 converted to chapter 7 on October 22, 2025, the Court entered its Order Approving Application to
16 Employ Ervin Cohen & Jessup LLP as General Bankruptcy Counsel [Dkt. No. 132]. The order
17 recites the conversion, approves the application, and orders that “ECJ’s compensation as general
18 bankruptcy counsel is subject to 11 U.S.C. § 330.”
19 The Supreme Court’s decision in Lamie v. United States Trustee, 540 U.S. 526 (2004) does
20 not bar the requested award. In Lamie, counsel had been employed under § 327(a) to represent the
21 chapter 11 debtor-in-possession, and the Court held that conversion to chapter 7 terminated the
22 debtor’s status as debtor-in-possession and, with it, counsel’s employment under § 327. Id. at 531–
23 32. In Lamie, no order authorized counsel’s employment after conversion, so counsel could not be
24 compensated from the estate for post-conversion services. Id. at 538-39. Here, by contrast, the only
25 order authorizing ECJ’s employment was entered on December 3, 2025, approximately six weeks
26 after conversion. The Court entered that order in the chapter 7 case, with the conversion expressly
27 noted, and ordered that ECJ’s compensation “as general bankruptcy counsel is subject to 11 U.S.C.
28 § 330.” ECJ is therefore a “professional person employed under section 327” within the meaning
13
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1 of § 330(a)(1).
2 Even apart from the employment order, Lamie recognizes that a debtor’s former counsel
3 may be compensated from a chapter 7 estate when employed by the trustee with court approval. Id.
4 at 538-39; 11 U.S.C. § 327(e). Moreover, in applying Lamie, bankruptcy courts in this jurisdiction
5 have approved a trustee’s employment of former debtor-in-possession counsel under § 327(e) for
6 the special purpose of providing transition services the trustee had requested, and awarded
7 compensation under § 330(a)(1) for those services on a retroactive basis. See In re Johnson, 397
8 B.R. 486, 492 (Bankr. E.D. Cal. 2008). The Johnson court found the exceptional circumstances
9 required in this circuit for retroactive compensation were, namely, a satisfactory explanation for the
10 absence of prior approval and services that significantly benefited the estate. See id. (citing Okamoto
11 v. THC Fin. Corp. (In re THC Fin. Corp.), 837 F.2d 389, 392 (9th Cir. 1988); Law Offices of Ivan
12 W. Halperin v. Occidental Fin. Grp., Inc. (In re Occidental Fin. Grp., Inc.), 40 F.3d 1059, 1062 (9th
13 Cir. 1994)).
14 Here, ECJ’s post-conversion services, totaling $52,323.50 in fees and $310.05 in expenses,
15 were of the same kind as in Johnson, following Lamie: they were rendered so that the Debtor could
16 fulfill its obligations under 11 U.S.C. § 521 and Rule 1019(5), and they directly (and significantly)
17 assisted the Trustee in identifying and administering estate assets, including by cooperating with the
18 Trustee’s requests for documents and information. As such, ECJ requests that the Court allow these
19 amounts. To the extent the Court determines that any portion of ECJ’s post-conversion fees and
20 expenses is not payable from the estate, ECJ requests that the order so provide without prejudice to
21 ECJ’s right to seek payment from the Debtor or other non-estate sources.
22 16. ECJ’s Services Were Necessary
23 ECJ's services were necessary to assist the Debtor throughout both the chapter 11 and chapter
24 7 phases of the case. Upon the Petition Date, the Debtor required counsel to comply with U.S.
25 Trustee requirements, timely prepare and file schedules and statements, obtain turnover of funds
26 held by Petco, and seek authority to use cash collateral and pay critical vendors and employees.
27 Following conversion, the Debtor required counsel to prepare the Rule 1019(5) final report, prepare
28 for and attend the § 341(a) meeting of creditors, and respond to the Trustee's requests for
14
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1 information. ECJ staffed the matter efficiently, with the majority of the work performed by an
2 associate at a lower billing rate under the supervision of a senior partner.
3 17. ECJ’s Services Benefitted the Estate
4 ECJ's services provided a tangible benefit to the estate. ECJ obtained an order compelling
5 turnover of funds held by Petco and successfully opposed Panthers' subsequent motion for
6 reconsideration. ECJ further maintained the Debtor's compliance with its reporting and disclosure
7 obligations, allowing the Debtor to pursue a reorganization while that remained a viable path. After
8 conversion, ECJ cooperated with the chapter 7 trustee by furnishing the Debtor's records and
9 information regarding its assets, liens, and transactions, which aided the Trustee's administration of
10 the estate and resulted in the filing of a Notice of Assets [Dkt. No. 133].
11 18. No Sharing of Compensation
12 ECJ has not shared, and has not agreed to share, any compensation received or to be received
13 in this case with any person other than the partners and employees of ECJ, in accordance with 11
14 U.S.C. § 504 and Federal Rule of Bankruptcy Procedure 2016(a).
15 19. Factors Affecting the Award of Compensation
16 In determining reasonable compensation, the Court considers the nature, extent, and value
17 of the services rendered, including the time spent, the rates charged, whether the services were
18 necessary or beneficial at the time they were performed, whether they were completed within a
19 reasonable amount of time commensurate with the complexity and importance of the issues
20 presented, and whether the requested compensation is comparable to that charged by similarly
21 skilled practitioners in non-bankruptcy matters. 11 U.S.C. § 330(a)(3). Each of these factors
22 supports the requested award.
23 Overall, this case required ECJ to prepare and file a chapter 11 petition on an emergency
24 basis, obtain turnover of funds held by Petco, and prepare and prosecute six contested emergency
25 motions during the first month of the case, despite opposition from the United States Trustee and
26 multiple secured creditors. The services rendered were necessary and beneficial to the estate when
27 performed and were completed efficiently and effectively in light of the issues presented. ECJ's
28 hourly rates are its standard rates for bankruptcy and non-bankruptcy matters and are comparable to
15
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1 those charged by practitioners of similar skill, experience, and reputation in the Los Angeles legal
2 market. Biographies of the ECJ professionals who rendered services in this case are attached as
3 Exhibit “3.”
4 PRAYER
5 WHEREFORE, ECJ submits that the fees and expenses incurred are reasonable and
6 necessary given the nature and complexity of the case, and prays for the Court to enter an Order:
7 1. Approving, on a final basis, fees to ECJ in the amount of $167,091.50 and expenses
8 of $1,665.74 incurred during the Subject Period;
9 2. Approving ECJ’s prior application of $26,051.00 of its retainer to its fees for the
10 Subject Period, and authorizing ECJ to apply the remaining retainer balance of $13,411.50 to its
11 allowed fees;
12 3. Authorizing and directing the Trustee to pay ECJ the unpaid balance of $127,629.00
13 in fees and $1,665.74 in expenses, as an allowed administrative expense, in accordance with 11
14 U.S.C. § 726(b);
15 4. Approving ECJ’s total fees and costs in this case, on a final basis, in the amounts of
16 $167,091.50 in fees and $1,665.74 in costs;
17 5. Approving the form and manner of notice of this Application and the hearing thereon;
18 and
19 6. Granting such other and further relief as may be deemed just and proper.
20
21 DATED: October 27, 2026 ERVIN COHEN & JESSUP LLP
22
By: /s/ Shantal Malmed
23
Shantal Malmed
24 Attorneys for CIS International Holdings (N.A.)
Corporation, dba E Tropical Fish, Former Chapter
25 11 Debtor and Debtor-in-Possession
26
27
28
16
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1 DECLARATION OF BYRON Z. MOLDO
2 I, Byron Z. Moldo, declare as follows:
3 1. I am a partner at Ervin Cohen & Jessup LLP (“ECJ”), and I am one of the attorneys
4 of record for CIS International Holdings (N.A.) Corporation, dba E Tropical Fish, the former chapter
5 11 debtor and debtor-in-possession (the “Debtor”), in the above-captioned bankruptcy case. I have
6 personal knowledge of the facts set forth herein, except those stated on information and belief, and
7 as to those matters I believe them to be true. If called as a witness, I could and would testify
8 competently thereto.
9 2. I submit this declaration in support of the First and Final Application for
10 Compensation and Reimbursement of Expenses by Ervin Cohen & Jessup LLP as General
11 Bankruptcy Counsel to Chapter 11 Debtor and Debtor-in-Possession (the “Application”).
12 Capitalized terms not defined herein have the meanings given in the Application.
13 3. ECJ’s billing records attached hereto as Exhibit “1” accurately reflect the services
14 rendered and expenses incurred by ECJ during the Subject Period of September 22, 2025 through
15 October 23, 2026. I have reviewed the billing records and they are true and correct to the best of
16 my knowledge.
17 4. The fees and expenses requested in this Application are reasonable and necessary in
18 light of the complexity of this case and the services rendered.
19 5. The hourly rates charged by ECJ professionals during the Subject Period represent
20 ECJ’s standard rates for bankruptcy and non-bankruptcy matters.
21 6. Before the Petition Date, ECJ received a retainer of $50,000.00 from the Debtor.
22 ECJ has applied $36,588.50 of the retainer to its fees as described in the Application, and the
23 remaining $13,411.50 is held in ECJ’s client trust account. ECJ has received no other payments in
24 this case.
25 7. ECJ has not shared, and has not agreed to share, any compensation received or to be
26 received in this case with any person other than the partners and employees of ECJ.
27 ///
28 ///
17
FIRST AND FINAL APPLICATION FOR PAYMENT OF FEES AND/OR EXPENSES BY ERVIN COHEN &
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1 8. A true and correct copy of the Court’s order approving ECJ’s employment [Dkt. No.
2 132] is attached hereto as Exhibit “2,” and true and correct copies of the biographies of the ECJ
3 professionals who rendered services in this case are attached hereto as Exhibit “3.”
4 I declare under penalty of perjury under the laws of the United States of America that the
5 foregoing is true and correct to the best of my knowledge.
6 Executed on this October 27, 2026, at Beverly Hills, California.
7
8 /s/ Byron Z. Moldo
Byron Z. Moldo
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
18
FIRST AND FINAL APPLICATION FOR PAYMENT OF FEES AND/OR EXPENSES BY ERVIN COHEN &
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EXHIBIT “1”
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Ervin Cohen & Jessup LLP
In re CIS International Holdings (N.A.) Corporation, Case No. 2:25-bk-18374-BR
Detailed Time Records — September 22, 2025 through October 23, 2026
Date Timekeeper Code Description Hours Rate Amount
09/22/2025 Moldo, B110 Coordinate commencement of chapter 11 1.3 $1,075.00 $1,397.50
Byron Z.
09/22/2025 Moldo, B120 Review documents re Quick Funding and relationship to Panthers 0.4 $1,075.00 $430.00
Byron Z. Capital
09/22/2025 Stone, B110 Prepare/draft petition; prepare/draft 20 largest creditors; send info 1.6 $650.00 $1,040.00
Chase A. to client re confirmation; prepare Schedules.
09/22/2025 Stone, B110 Review/draft petition; review service list; email to client re 1.6 $650.00 $1,040.00
Chase A. signature/verification; review petition; review tax
returns/accounting re determination of assets/liabilities; teleconf.
w/ B. Moldo re same.
09/22/2025 Stone, B110 Teleconf. w/ client re timing of petition; review/coordinate filing of 0.5 $650.00 $325.00
Chase A. matrix; send BestCase file to A. Antonio to coordinate and
review/revise notice; prepare Top 20 creditors matrix for review.
09/22/2025 Stone, B110 Finalize petition; finalize service list; corespondence w/ A. Antonio 1.4 $650.00 $910.00
Chase A. re approving/uploading petition; teleconf. w/ client re update;
review/email Edison re disconnect; call to Edison re same;
review/send response to clietn re update about disconnectoin
following imposition fo automatic stay.
09/23/2025 Stone, B320 Teleconf. re notice to Ford Motors re stay; follow-up email to 0.3 $650.00 $195.00
Chase A. client re confirming collection efforts by Ford ceasing.
09/23/2025 Stone, B150 Teleconf. w/ Z. Bohlender re Petco/542 demand; teleconf. w/ client 0.6 $650.00 $390.00
Chase A. re status of 542 and next steps re vendor motion.
09/23/2025 Stone, B320 Review/revise issues re creditor matrix; note 72-hour deadline to 0.2 $650.00 $130.00
Chase A. fix matrix.
09/24/2025 Moldo, B320 Review 9/24/25 order re plan, disclosure, etc. 0.1 $1,075.00 $107.50
Byron Z.
09/24/2025 Moldo, B230 Telephone call to LoBuglio re preparation of budget for cash 0.5 $1,075.00 $537.50
Byron Z. collateral
09/24/2025 Moldo, B120 Review financial information 1.0 $1,075.00 $1,075.00
Byron Z.
09/24/2025 Moldo, B230 Telephone call to client, LoBuglio re preparation of budget and 0.5 $1,075.00 $537.50
Byron Z. projections
09/24/2025 Moldo, B120 Prepare letter to Fletcher re turnover of funds by Petco 0.2 $1,075.00 $215.00
Byron Z.
09/24/2025 Moldo, B190 Review status of pending state court lawsuits 0.3 $1,075.00 $322.50
Byron Z.
09/24/2025 Stone, B110 Teleconf. w/ OUST counsel re petition. 0.2 $650.00 $130.00
Chase A.
09/24/2025 Stone, B320 Review/forward (for calendaring) status conf. order re plan 0.1 $650.00 $65.00
Chase A. deadlines (Judge Russell).
09/24/2025 Stone, B230 Prepare/continue drafting first day motions; review accounting 1.3 $650.00 $845.00
Chase A. information re budget.
09/24/2025 Stone, B230 Conf. w/ CIS client re next steps; balance sheets; P&L w/ proposed 0.7 $650.00 $455.00
Chase A. accountant for Estate (analysis for preparation of cash collateral
motion).
09/24/2025 Stone, B230 Prepare/continue drafting motion first day motions. 1.2 $650.00 $780.00
Chase A.
09/24/2025 Stone, B230 Prepare/continue drafting first day motions; review service list. 1.2 $650.00 $780.00
Chase A.
Exhibit 1 – Page 2
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Date Timekeeper Code Description Hours Rate Amount
09/25/2025 Moldo, B110 Prepare letter to client re closure of pre-petition bank accounts 0.2 $1,075.00 $215.00
Byron Z.
09/25/2025 Stone, B110 Email/review response from U.S. Trustee Ron Maroko re: denial of 0.2 $650.00 $130.00
Chase A. week extension request to submit 7-day package (Week of Rosh
Hashanah).
09/25/2025 Moldo, B110 Review notice of chapter 11 case 0.1 $1,075.00 $107.50
Byron Z.
09/25/2025 Moldo, B120 Telephone call to Fletcher re Petco turnover of property 0.3 $1,075.00 $322.50
Byron Z.
09/25/2025 Moldo, B150 Prepare letter to client re IDI and DIP requirements 0.2 $1,075.00 $215.00
Byron Z.
09/25/2025 Moldo, B120 Investigate Panthers security interest and assignment from Quick 0.5 $1,075.00 $537.50
Byron Z. Funding
09/25/2025 Stone, B230 Teleconf. w/ Petco counsel A. Fletcher 0.3 $650.00 $195.00
Chase A.
09/25/2025 Stone, B230 Analyze UCC-1 filings; review priority argument re Petco; update 1.4 $650.00 $910.00
Chase A. cash collateral and critical vendor motion re same; prepare
proposed order re cash collateral.
09/25/2025 Stone, B150 Review response from A. Fletcher re 542 demand; analyze. 0.2 $650.00 $130.00
Chase A. Forward inquiry.
09/25/2025 Stone, B230 Prepare/continue drafting first day motions; draft analysis; 0.6 $650.00 $390.00
Chase A. review/prepare factual background section.
09/26/2025 Stone, B210 Inquiry/request for proof of insurance from client for OUST; 0.2 $650.00 $130.00
Chase A. respond re same.
09/26/2025 Stone, B110 Review correspondence; teleconf. w/ Bank of CBC to forward to 0.1 $650.00 $65.00
Chase A. client re setting up DIP account.
09/26/2025 Stone, B150 Review email correspondence from A. Fletcher/respond re meeting 0.2 $650.00 $130.00
Chase A. and set up call.
09/26/2025 Stone, B150 Teleconf. w/ A. Fletcher re status of stipulation; order and 0.8 $650.00 $520.00
Chase A. discussion of next steps re Petco; follow-up re same.
09/26/2025 Stone, B110 Review/analyze insurance policies; teleconf. w/ client re updating 0.9 $650.00 $585.00
Chase A. insurance and renewing for UST; review/analyze inquiries from
client; update information to include for UST; send email to R.
Maroko.
09/29/2025 Moldo, B120 Review client letter and supporting documents re possible assets 0.2 $1,075.00 $215.00
Byron Z.
09/29/2025 Moldo, B110 Discussions with client re preparation of 7 day package 1.0 $1,075.00 $1,075.00
Byron Z.
09/29/2025 Moldo, B230 Telephone call to LoBuglio re case status and cash collateral 0.3 $1,075.00 $322.50
Byron Z.
09/29/2025 Moldo, B120 Review liability insurance policy 0.3 $1,075.00 $322.50
Byron Z.
09/29/2025 Moldo, B230 Telephone call to Aron re payment of rent 0.2 $1,075.00 $215.00
Byron Z.
09/29/2025 Moldo, B110 Prepare 7 day package 0.6 $1,075.00 $645.00
Byron Z.
09/29/2025 Moldo, B310 Review Ford Motor Credit claims and supporting documents 0.3 $1,075.00 $322.50
Byron Z.
09/29/2025 Moldo, B110 Prepare statement of major issues for UST 7 day package 0.3 $1,075.00 $322.50
Byron Z.
Exhibit 1 – Page 3
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Date Timekeeper Code Description Hours Rate Amount
09/29/2025 Stone, B110 Review correspondence from client re CIS asset information; 0.6 $650.00 $390.00
Chase A. review policies sent from client re automobile and worker's
compensation. Send information re seven-day package (reminder);
send further information re general list of required insurance
policies. Provide further detail/explanation re same and request
immediate assistance.
09/29/2025 Stone, B110 Review USTLA Form 12; send to client for signature; 0.2 $650.00 $130.00
Chase A. prepare/finalize and send.
09/29/2025 Stone, B230 Review/respond to email re inquiries from S. Samarasinghe; conf. 0.2 $650.00 $130.00
Chase A. re next steps (critical vendors).
09/29/2025 Stone, B150 Respond to email from A. Fletcher re stipulation/legal issues. 0.1 $650.00 $65.00
Chase A.
09/29/2025 Stone, B110 Review USTLA Form 8; prepare to finalize/send to client for 0.2 $650.00 $130.00
Chase A. signature and submit.
09/29/2025 Stone, B110 Review USTLA Form 5.3 prepare to finalize/send to client for 0.2 $650.00 $130.00
Chase A. signature and submit.
09/29/2025 Stone, B110 Review USTLA Form 5.2; prepare to finalize/send to client for 0.2 $650.00 $130.00
Chase A. signature and submit.
09/29/2025 Stone, B110 Review USTLA Form 5.1; prepare to finalize/send to client for 0.3 $650.00 $195.00
Chase A. signature and submit.
09/29/2025 Stone, B110 Review USTLA Form 5; prepare to finalize/send to client for 0.3 $650.00 $195.00
Chase A. signature and submit.
09/29/2025 Stone, B110 Review USTLA Form 4; prepare to finalize/send to client for 0.1 $650.00 $65.00
Chase A. signature and submit.
09/29/2025 Stone, B110 Review USTLA Form 3; review/organize attachments; prepare to 0.5 $650.00 $325.00
Chase A. finalize/send to client for signature and submit.
09/29/2025 Stone, B110 Draft client communication summarizing UST seven-day package 0.5 $650.00 $325.00
Chase A. contents and next steps.
09/29/2025 Stone, B110 Prepare and revise Seven Day package w/ client (call/email 0.9 $650.00 $585.00
Chase A. exchange to confirm disclosures and financials; incorporate client
edits).
09/29/2025 Stone, B110 Finalize UST seven-day package (review checklist, confirm 0.8 $650.00 $520.00
Chase A. completeness, formatting).
09/30/2025 Hosfield, B190 Conference with C. Stone regarding action items; review email 0.4 $515.00 $206.00
Tanner F. correspondence from B. Moldo and related documents regarding
notice of stay.
09/30/2025 Moldo, B230 Telephone call to LoBuglio re case status and budget 0.3 $1,075.00 $322.50
Byron Z.
09/30/2025 Moldo, B150 Telephone call from Golden State Water re outstanding balance and 0.2 $1,075.00 $215.00
Byron Z. establishment of new accounts
09/30/2025 Moldo, B190 Review status of pending state court litigation 0.5 $1,075.00 $537.50
Byron Z.
09/30/2025 Moldo, B120 Prepare stipulation for turnover of funds by Petco 0.4 $1,075.00 $430.00
Byron Z.
09/30/2025 Moldo, B230 Analyze financial reports and projections (.4); telephone call to 0.6 $1,075.00 $645.00
Byron Z. LoBuglio re same (.2)
09/30/2025 Stone, B150 Draft/prepare CIS/Petco 542 stipulation; teleconf. w/ client re 0.9 $650.00 $585.00
Chase A. status of funding; send email to A. Fletcher (Petco counsel) and
attach proposed stipulation.
10/01/2025 Hosfield, B190 Conference with B. Moldo regarding notices of stay; review case 1.1 $515.00 $566.50
Tanner F. dockets and judicial directories; prepare notice of stay and
strategize via emails with B. Moldo; further revise notice of stay.
Exhibit 1 – Page 4
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Date Timekeeper Code Description Hours Rate Amount
10/01/2025 Moldo, B230 Telephone call to client re preparation of forecast and budget 1.0 $1,075.00 $1,075.00
Byron Z.
10/01/2025 Moldo, B120 Telephone call to Fletcher re turnover of funds by Petco 0.2 $1,075.00 $215.00
Byron Z.
10/01/2025 Moldo, B120 Telephone call to Bohlender, Luccarelli, Stone re Panthers Capital 1.0 $1,075.00 $1,075.00
Byron Z. and claims
10/01/2025 Stone, B230 Teleconf. w/ D. LoBuglio accountant re balance sheet/P&L; review 1.1 $650.00 $715.00
Chase A. next steps w/ client.
10/01/2025 Stone, B185 Teleconf. w/ Z. Bohlender and CT counsel re litigation w/ 1.2 $650.00 $780.00
Chase A. Panthers; review UCC-1 issues; review next steps re usury and
discuss resolving three-party agreement.
10/01/2025 Stone, B150 Review/respond to Draft Stipulation - Urgent (Petco/A. Fletcher) 0.2 $650.00 $130.00
Chase A. and coordination; assign correct matter once identified.
10/02/2025 Stone, B150 Email/follow-up to Petco re stipulation. 0.1 $650.00 $65.00
Chase A.
10/02/2025 Stone, B120 Review updated stipulation drafts; coordinate with A. Fletcher, G. 0.3 $650.00 $195.00
Chase A. Insana, and S. Gaenzel; forward to Sam/Varuni for approval.
10/03/2025 Moldo, B240 Prepare letter to client re submission of sales tax returns 0.2 $1,075.00 $215.00
Byron Z.
10/03/2025 Moldo, B230 Telephone call to van Pohlot re DIP financing 0.3 $1,075.00 $322.50
Byron Z.
10/03/2025 Moldo, B240 Telephone call to LoBuglio re sales tax issues 0.4 $1,075.00 $430.00
Byron Z.
10/03/2025 Hosfield, B190 Review email and notice of Chapter 11 filing; prepare as exhibit to 0.5 $515.00 $257.50
Tanner F. notice of stay; strategize with B. Moldo regarding notices; review
service list; oversee filing and service of notice of stay.
10/03/2025 Stone, B120 Prepare/review stipulation and vendor list updates; coordinate with 1.6 $650.00 $1,040.00
Chase A. Debbie on ECF filing and service; confer with Sam/Varuni on
vendor additions
10/03/2025 Stone, B240 Address sales/use tax account and workers' comp coordination 0.6 $650.00 $390.00
Chase A. (combining entities) with D. LoBuglio; outline response plan.
10/06/2025 Hosfield, B190 Correspondence via emails with B. Moldo and C. Stone regarding 0.4 $515.00 $206.00
Tanner F. filed notice of stay; review rejection notice and oversee re-
submitting of notice of stay; email correspondence regarding same.
10/06/2025 Stone, B150 Review IDI date/time; review 341(a) date/time; provide 1.1 $650.00 $715.00
Chase A. instructions and request meeting w/ clients re preparation of the
same.
10/06/2025 Moldo, B110 Prepare schedules 1.2 $1,075.00 $1,290.00
Byron Z.
10/06/2025 Stone, B110 Review/update schedules; teleconf. w/ clerk; review/revise motion 0.9 $650.00 $585.00
Chase A. re emergency/ex parte relief (extend time to file schedules); obtain
signature from debtor principal.
10/06/2025 Stone, B150 Prepare for 341(a) meeitng; teleconf. w/ client re preparation; send 0.6 $650.00 $390.00
Chase A. email to R. Maroko re driver's license for C. Samarsinghe.
10/06/2025 Stone, B190 Review email and inquiry Jaime Mendoza Gonzalez v. CIS 0.1 $650.00 $65.00
Chase A. (notice).
10/06/2025 Stone, B150 Teleconf.: IDI and 341(a) meeting of creditors. 1.5 $650.00 $975.00
Chase A.
10/06/2025 Stone, B110 Prepare/review/organize schedules to file w/ Court re cure 2.2 $650.00 $1,430.00
Chase A. deadline: Schedule E, F, G, H, and statement of related cases.
Review w/ CIS principal and send to A. Antonio to finalize.
10/06/2025 Stone, B230 Review/draft motion re critical vendors; review/draft motion re 0.5 $650.00 $325.00
Chase A. cash collateral; instructions to D. Allen re same.
Exhibit 1 – Page 5
Case 2:25-bk-18374-BR Doc 214 Filed 10/27/26 Entered 10/27/26 16:15:01 Desc
Main Document Page 24 of 84
Date Timekeeper Code Description Hours Rate Amount
10/06/2025 Allen, B110 Drafted motion to extend 1.0 $535.00 $535.00
Dylan
10/07/2025 Gabai, B110 Conf. with Chase Stone re case background. 0.4 $550.00 $220.00
Danielle R.
10/07/2025 Gabai, B160 Prepare application to employ ECJ. 1.2 $550.00 $660.00
Danielle R.
10/07/2025 Moldo, B190 Review client letter re pending worker's comp cases and status of 0.2 $1,075.00 $215.00
Byron Z. cases
10/07/2025 Stone, B110 Conf. w/ support staff re uploading lodged order (conf. w/ clerk's 0.2 $650.00 $130.00
Chase A. office); approve/instruct office to upload proposed order extending
time to file schedules.
10/07/2025 Stone, B110 Finalize proposed order extending time; address "Notice to Filer" 0.4 $650.00 $260.00
Chase A. deficiency;submit and confirm entry; circulate order and summary
to team/client.
10/07/2025 Stone, B110 Respond to client inquiries re status of funds and filing timeline; 0.3 $650.00 $195.00
Chase A. set expectations on next deadlines.
10/07/2025 Stone, B190 Coordinate with B. Moldo and Z. Bohlender on AWP/common- 0.1 $650.00 $65.00
Chase A. interest and litigation exposure.
10/07/2025 Stone, B190 Confirm Notice of Stay mailing in Gonzalez and approach on 0.2 $650.00 $130.00
Chase A. workers' comp coordination (22STCV35612/03622).
10/07/2025 Stone, B230 Status call with D. LoBuglio re cash forecast, payroll status, Petco 0.5 $650.00 $325.00
Chase A. turnover mechanics; identify action items.
10/07/2025 Stone, B110 Address Notice of Deficiency re filing fees/creditor add; 0.2 $650.00 $130.00
Chase A. coordinate corrective filings and docket checks with A. Antonio/D.
Perez.
10/07/2025 Stone, B160 Review ECJ employment application draft; comments/edits; 0.3 $650.00 $195.00
Chase A. coordinate with D. Gabai on CPA employment approach.
10/08/2025 Gabai, B160 Further prepare employment application re ECJ; prepare proposed 3.3 $550.00 $1,815.00
Danielle R. order granting application
10/08/2025 Gabai, B160 Prepare application to employ DOMINIC LOBUGLIO as CPA for 1.3 $550.00 $715.00
Danielle R. the Estate.
10/08/2025 Allen, B230 Emergency Motion and order for Cash Collateral drafting 1.0 $535.00 $535.00
Dylan
10/08/2025 Stone, B230 Review email re payroll from client/timing; email wire instructions 0.2 $650.00 $130.00
Chase A. to A. Fletcher.
10/08/2025 Moldo, B230 Telephone call to client re updated projections and budget for cash 1.0 $1,075.00 $1,075.00
Byron Z. collateral motion
10/08/2025 Stone, B210 Teleconf. w/ D. LoBuglio, B. Moldo, client re Petco; 1.1 $650.00 $715.00
Chase A. accounting/balance.
10/08/2025 Stone, B120 Review order re stipulation (request/POS); provide instructions to 0.2 $650.00 $130.00
Chase A. A. Antonio to serve on Panthers Capital LLC in order to obtain
cash.
10/08/2025 Stone, B230 Outline terms/edits for cash collateral/critical vendor order; 0.3 $650.00 $195.00
Chase A. circulate to D. LoBuglio; confirm service list.
10/08/2025 Allen, B230 Emergency motion to pay critical vendors and order drafting 1.0 $535.00 $535.00
Dylan
10/09/2025 Gabai, B160 Further prepare employment application to employ CPA and 1.3 $550.00 $715.00
Danielle R. review LBR re service of same.
10/09/2025 Moldo, B230 Prepare motion for use of cash collateral 1.4 $1,075.00 $1,505.00
Byron Z.
10/09/2025 Moldo, B160 Prepare application to employ ECJ; proposed order 1.0 $1,075.00 $1,075.00
Byron Z.
Exhibit 1 – Page 6
Case 2:25-bk-18374-BR Doc 214 Filed 10/27/26 Entered 10/27/26 16:15:01 Desc
Main Document Page 25 of 84
Date Timekeeper Code Description Hours Rate Amount
10/09/2025 Stone, B230 Draft cash collateral motion and proposed order; build 13-week 2.8 $650.00 $1,820.00
Chase A. budget and reduced notice provisions; incorporate lender consent
language; circulate to team.
10/09/2025 Stone, B230 Draft critical vendors emergency motion and budget schedule; 1.1 $650.00 $715.00
Chase A. necessity showing; coordinate with emergency funding list.
10/09/2025 Stone, B210 Draft utilities motion (adequate assurance) and reduced notice 0.7 $650.00 $455.00
Chase A. papers; prepare notice captions and hearing settings.
10/09/2025 Stone, B230 Prepetition wages analysis and motion; calculate pro rata wages 0.4 $650.00 $260.00
Chase A. within statutory caps; align with cash forecast.
10/09/2025 Stone, B230 Lender consent outreach (Newtek, Woodmere, Settle): transmit 0.3 $650.00 $195.00
Chase A. budget/order; confirm consent positions; note edits.
10/09/2025 Stone, B230 Review/approve emergency first day motions service list; 0.2 $650.00 $130.00
Chase A. coordinate overnight mail and service logistics with staff.
10/09/2025 Stone, B170 Review/edit ECJ employment application; confirm disclosures and 0.2 $650.00 $130.00
Chase A. proposed order language with D. Gabai.
10/09/2025 Stone, B160 Review tax accountant employment application draft; align 0.1 $650.00 $65.00
Chase A. scope/comp and Rule 2014 disclosures.
10/09/2025 Stone, B230 Budget iterations and urgent payments coordination; reconcile "DB 0.3 $650.00 $195.00
Chase A. Logistics" removal and emergency payments with critical vendors
schedule.
10/10/2025 Gabai, B230 Review and revise emergency motions re cash collateral, compile 0.9 $550.00 $495.00
Danielle R. exhibits and prepare proposed orders re same.
10/10/2025 Gabai, B230 Review and revise emergency motion re critical vendors, compile 1.1 $550.00 $605.00
Danielle R. exhibits, prepare proposed order re same.
10/10/2025 Gabai, B230 Review and revise emergency motion re prepetition wages, 1.1 $550.00 $605.00
Danielle R. compile exhibits, prepare proposed order re same.
10/10/2025 Gabai, B210 Review and revise emergency motion re adequate assurance, 1.2 $550.00 $660.00
Danielle R. compile exhibits, prepare proposed order re same.
10/10/2025 Gabai, B110 Review and revise emergency motion re limitation of notice, 1.2 $550.00 $660.00
Danielle R. prepare exhibits thereto, prepare proposed order re same.
10/10/2025 Gabai, B110 Review and revise emergency motion re exceeding 35-page limit, 0.8 $550.00 $440.00
Danielle R. and prepare proposed order re same.
10/10/2025 Gabai, B230 Review and revise omnibus declaration in support of emergency 0.7 $550.00 $385.00
Danielle R. motions and compile exhibits thereto.
10/10/2025 Gabai, B230 Oversee filling of emergency motions. 0.6 $550.00 $330.00
Danielle R.
10/10/2025 Allen, B230 Prepared first day motions 1.5 $535.00 $802.50
Dylan
10/10/2025 Moldo, B160 Prepare application to employ LoBuglio as accountant 0.5 $1,075.00 $537.50
Byron Z.
10/10/2025 Moldo, B230 Review Panthers non-consent to use of cash collateral 0.2 $1,075.00 $215.00
Byron Z.
10/10/2025 Moldo, B110 Prepare motions to limit notice and file lengthy brief; orders 1.0 $1,075.00 $1,075.00
Byron Z.
10/10/2025 Moldo, B230 Prepare motion to pay critical vendors 1.0 $1,075.00 $1,075.00
Byron Z.
10/10/2025 Moldo, B230 Prepare motion to pay prepetition wages 1.0 $1,075.00 $1,075.00
Byron Z.
10/10/2025 Moldo, B120 Prepare letter to Cappello re possible claims 0.2 $1,075.00 $215.00
Byron Z.
10/10/2025 Moldo, B120 Prepare letter to Cappello re claims of debtor 0.2 $1,075.00 $215.00
Byron Z.
Exhibit 1 – Page 7
Case 2:25-bk-18374-BR Doc 214 Filed 10/27/26 Entered 10/27/26 16:15:01 Desc
Main Document Page 26 of 84
Date Timekeeper Code Description Hours Rate Amount
10/10/2025 Stone, B230 Draft/finalize cash collateral motion and proposed interim order; 2.3 $650.00 $1,495.00
Chase A. finalize 13-week budget; add Panthers non‑consent
language; coordinate notice/hearing date.
10/10/2025 Stone, B110 Draft limiting notice motion and 35-page excess memorandum; 0.9 $650.00 $585.00
Chase A. align notice procedures and captions.
10/10/2025 Stone, B210 Draft utilities motion (adequate assurance), coordinate initial utility 0.7 $650.00 $455.00
Chase A. list and deposits.
10/10/2025 Stone, B230 Draft prepetition priority wages motion; verify caps and payroll 0.6 $650.00 $390.00
Chase A. data; finalize exhibit of employees/amounts
10/10/2025 Stone, B230 Filing/ECF logistics: review service list; coordinate large overnight 0.4 $650.00 $260.00
Chase A. mailing and service; verify ECF confirmations; address
Statement/Declaration docketing.
10/10/2025 Stone, B230 Lender consent outreach and follow‑up 0.3 $650.00 $195.00
Chase A. (Newtek/Woodmere/Panthers): transmit budget/order;
negotiate/record positions; update team.
10/10/2025 Stone, B160 Review/edit ECJ and tax accountant employment papers; confirm 0.2 $650.00 $130.00
Chase A. Rule 2014 disclosures and proposed orders.
10/10/2025 Stone, B230 Budget/payment triage with client (removed DB Logistics; align 0.1 $650.00 $65.00
Chase A. emergency payments with critical vendor list).
10/13/2025 Gabai, B160 Finalize employment applications re ECJ and Dominic LoBuglio. 0.6 $550.00 $330.00
Danielle R.
10/13/2025 Moldo, B240 Review LoBuglio letter and respond re 2024 tax return 0.2 $1,075.00 $215.00
Byron Z.
10/13/2025 Moldo, B240 Review client letter and respond re BPM and preparation of tax 0.2 $1,075.00 $215.00
Byron Z. returns
10/13/2025 Moldo, B120 Review documents re relationship with various entities 0.3 $1,075.00 $322.50
Byron Z.
10/13/2025 Stone, B230 Review correspondence from V. Samarasinghe re CIS invoices; set 0.1 $650.00 $65.00
Chase A. up call w/ B. Chia from Settle re cash collateral.
10/13/2025 Moldo, B230 Telephone call to LoBuglio re financing issues, assets, tax issues 0.5 $1,075.00 $537.50
Byron Z.
10/13/2025 Moldo, B150 Telephone call from Altman re debt to DB Group and review 0.3 $1,075.00 $322.50
Byron Z. supporting documents
10/13/2025 Stone, B230 Email/respond to Settle bankruptcy counsel re hearing/next steps. 0.2 $650.00 $130.00
Chase A.
10/13/2025 Stone, B240 Teleconf. w/ D. LoBuglio re assessment of tax issues; discussino of 0.6 $650.00 $390.00
Chase A. next steps re payment of obligations.
10/13/2025 Stone, B230 Teleconf. w/ S. Samarasinghe; teleconf. w/ banker re WI; review 1.6 $650.00 $1,040.00
Chase A. outcome of events re cash collateral; email re analysis of approach
to settle cash collateral issues.
10/14/2025 Gabai, B160 Correspond with Chase Stone re application to employ CPA. 0.2 $550.00 $110.00
Danielle R.
10/14/2025 Moldo, B150 Review correspondence re DB Group America re good in transit 0.2 $1,075.00 $215.00
Byron Z.
10/14/2025 Moldo, B120 Review various documents re tax return and related entities 0.4 $1,075.00 $430.00
Byron Z.
10/14/2025 Moldo, B120 Telephone call to LoBuglio re estate assets 0.6 $1,075.00 $645.00
Byron Z.
10/14/2025 Stone, B230 Review email instructions from S. Fortier re notice; 1.5 $650.00 $975.00
Chase A. review/draft/revise notice of emergency hearings; email to and
from chambers re status of notice/public instructions; teleconf. w/
S. Samarasinghe re POS/email address/contact information;
forward/organize POS w/ A. Antonio and D. Perez.
Exhibit 1 – Page 8
Case 2:25-bk-18374-BR Doc 214 Filed 10/27/26 Entered 10/27/26 16:15:01 Desc
Main Document Page 27 of 84
Date Timekeeper Code Description Hours Rate Amount
10/14/2025 Stone, B150 Teleconf./follow-up w/ Settle re cash collateral. 0.5 $650.00 $325.00
Chase A.
10/14/2025 Stone, B150 Email to R. Altman re DB critical vendors motion. 0.1 $650.00 $65.00
Chase A.
10/14/2025 Moldo, B240 Discussions re preparation of 2024 tax return 1.2 $1,075.00 $1,290.00
Byron Z.
10/14/2025 Moldo, B230 Telephone call to Hatch, Bohlender re possible DIP financing 0.5 $1,075.00 $537.50
Byron Z.
10/14/2025 Stone, B230 Email to R. Soref re Panthers Capital; follow-up re BPM. 0.2 $650.00 $130.00
Chase A.
10/14/2025 Stone, B230 Teleconf. w/ R. Soref re Panthers. 0.3 $650.00 $195.00
Chase A.
10/14/2025 Stone, B110 Review CM/ECF notices and conform caption/notice after filings; 0.1 $650.00 $65.00
Chase A. verify hearing set entries and docket updates.
10/14/2025 Stone, B230 Finalize and circulate service/notice to additional creditors/contacts 0.1 $650.00 $65.00
Chase A. not already in POS; confirm fax/Email service list updates with
staff.
10/14/2025 Stone, B150 Review/approve "Request for Emergency Consent to Use Cash 0.3 $650.00 $195.00
Chase A. Collateral" language and send to stakeholders (emails with Randye
Soref/Lucas Rocklin around 12:59 PM).
10/14/2025 Stone, B230 Coordinate courtesy copies with Express Network/courtesy copy 0.1 $650.00 $65.00
Chase A. delivery instructions for Judge Russell (emails 9:22-9:25 AM).
10/14/2025 Stone, B230 Draft/revise Notice of Emergency First Day Motions per S. Fortier; 1.3 $650.00 $845.00
Chase A. coordinate with chambers re public instructions/status; review
CM/ECF notices (appearance/hearing set) and conform
caption/notice; finalize service list and coordinate POS with A.
Antonio/D. Perez; circulate finalized notice to creditor contacts.
10/15/2025 Allen, B110 Drafted motion and order to extend 1.0 $535.00 $535.00
Dylan
10/15/2025 Moldo, B120 Discussion with client and accountant re assets, liabilities, inter- 3.0 $1,075.00 $3,225.00
Byron Z. company transactions
10/15/2025 Stone, B230 Conference with management (V. and S. Samarasinghe) and B. 0.9 $650.00 $585.00
Chase A. Moldo re MOR timing, payroll needs, and limited budget; review
September and 9/22/25 Balance Sheet and P&L reports and related
emails; outline action items and follow up with team on
schedules/extension filing.
10/15/2025 Stone, B110 Teleconf. re meeting wtih V. Samarasinghe (MOR request for 0.2 $650.00 $130.00
Chase A. extension, review schedules, etc.).
10/15/2025 Stone, B230 Email/request for postpetition payroll amount. 0.1 $650.00 $65.00
Chase A.
10/15/2025 Stone, B110 Prepare/review/revise proposed order and motion re second request 0.6 $650.00 $390.00
Chase A. for extension to deadline to file schedules.
10/15/2025 Moldo, B110 Prepare 2nd ex parte application to extend time to submit 0.2 $1,075.00 $215.00
Byron Z. schedules
10/15/2025 Stone, B230 Review postpetition wage request; draft email to Settle and 0.2 $650.00 $130.00
Chase A. Panthers; send to B. Moldo for review.
10/15/2025 Stone, B230 Review/analyze discuss next steps re cash collateral. 0.1 $650.00 $65.00
Chase A.
10/15/2025 Stone, B230 Pre-meeting preparation; review September and 9/22/25 Balance 0.4 $650.00 $260.00
Chase A. Sheet and P&L and "Limited Budget" correspondence; outline
MOR/schedules status and payroll questions (for 10 a.m. CIS call).
Exhibit 1 – Page 9
Case 2:25-bk-18374-BR Doc 214 Filed 10/27/26 Entered 10/27/26 16:15:01 Desc
Main Document Page 28 of 84
Date Timekeeper Code Description Hours Rate Amount
10/15/2025 Stone, B230 Review payroll figures from V. Samarasinghe; draft and circulate 0.3 $650.00 $195.00
Chase A. limited cash collateral/priority wages request and outreach to
Panthers/UST; coordinate with second extension filing.
10/15/2025 Stone, B230 Call with UST re objection and MOR deadline/status and 0.2 $650.00 $130.00
Chase A. extension; confirm filing plan and information requirements.
10/16/2025 Moldo, B230 Negotiations with secured creditors re use of cash collateral 1.2 $1,075.00 $1,290.00
Byron Z.
10/16/2025 Stone, B230 Teleconf. w/ S. Samarasinghe; forward Panthers' response re use of 0.6 $650.00 $390.00
Chase A. cash collateral to Settle and request further response; review Z.
Bohlender email re next steps.
10/16/2025 Stone, B110 Review NEF notices re appearance and courtesy NEF; confirm 0.2 $650.00 $130.00
Chase A. service matrix and file/route to team; note MOR deadline in task
list.
10/16/2025 Stone, B230 Draft/refine cash-collateral limited wages request and circulate 0.2 $650.00 $130.00
Chase A. follow-ups; coordinate responses and next-step assignments.
10/16/2025 Stone, B110 Review/respond to "Request for Second Extension" and 0.1 $650.00 $65.00
Chase A. payroll/cash collateral emails; confirm next-step assignments.
10/16/2025 Stone, B230 Draft and circulate follow-up on limited cash-collateral use for 0.2 $650.00 $130.00
Chase A. priority wages; coordinate with management and counsel on
proposed terms; track counterparty response and next steps.
10/16/2025 Stone, B150 Send follow-up re limited use of cash collateral for priority wages; 0.2 $650.00 $130.00
Chase A. confirm counterparty receipt and next step timing.
10/17/2025 Stone, B160 Review email from L. Vesely re employment application materials; 0.2 $650.00 $130.00
Chase A. respond re same w/ statement of disinterestedness.
10/17/2025 Moldo, B120 Discussions re claims against Panthers 0.6 $1,075.00 $645.00
Byron Z.
10/17/2025 Moldo, B230 Review UST opposition to critical vendor motion and request for 0.2 $1,075.00 $215.00
Byron Z. continuance
10/17/2025 Moldo, B230 Review Settle limited objection to use of cash collateral 0.1 $1,075.00 $107.50
Byron Z.
10/17/2025 Moldo, B210 Review Panthers opposition to critical vendor motion 0.2 $1,075.00 $215.00
Byron Z.
10/17/2025 Moldo, B120 Telephone call from LoBuglio re T3 Aquatics and related entities 0.3 $1,075.00 $322.50
Byron Z.
10/17/2025 Moldo, B230 Review and analyze opposition to emergency motions 1.2 $1,075.00 $1,290.00
Byron Z.
10/17/2025 Stone, B230 Review and analyze objection and supporting declaration regarding 0.7 $650.00 $455.00
Chase A. limited use of cash collateral/critical vendor relief; outline response
strategy and evidentiary needs; coordinate with team on draft
assignments and timing.
10/17/2025 Stone, B160 Coordinate accountant's employment application materials; 0.3 $650.00 $195.00
Chase A. prepare/confirm disinterestedness and connections disclosures;
correspond with D. LoBuglio, L. Vesely, and team regarding
required exhibits and next filing steps.
10/17/2025 Stone, B230 Review and analyze objection affecting use of cash 0.3 $650.00 $195.00
Chase A. collateral/critical vendor relief; outline response strategy and
evidentiary needs; circulate summary and coordinate next steps.
10/17/2025 Stone, B230 Substantive review and analysis of opposition and declarations 1.7 $650.00 $1,105.00
Chase A. regarding cash collateral/critical vendor relief; develop response
strategy, identify evidentiary gaps, and assign drafting tasks; confer
with counsel and client; prepare summary to team.
Exhibit 1 – Page 10
Case 2:25-bk-18374-BR Doc 214 Filed 10/27/26 Entered 10/27/26 16:15:01 Desc
Main Document Page 29 of 84
Date Timekeeper Code Description Hours Rate Amount
10/17/2025 Stone, B110 Process CM/ECF notices; update docket and case file; calendar 0.3 $650.00 $195.00
Chase A. briefing/hearing deadlines; route filings and instructions to D.
Perez/A. Antonio.
10/17/2025 Stone, B230 Teleconference re employment application and DIP account status; 0.3 $650.00 $195.00
Chase A. confirm disinterestedness materials, connections list, and next
filing steps.
10/20/2025 Slater, Jared B160 Meeting with C. Stone regarding background of case and 0.3 $655.00 $196.50
employment application assignment
10/20/2025 Gabai, B230 Review and revise Debtor's obnibus reply re oppositions to 0.4 $550.00 $220.00
Danielle R. emergency motions.
10/20/2025 Moldo, B210 Telephone call from client re payments to related entities 0.2 $1,075.00 $215.00
Byron Z.
10/20/2025 Moldo, B230 Prepare reply to opposition to motion to use cash collateral and pay 1.0 $1,075.00 $1,075.00
Byron Z. critical vendors
10/20/2025 Moldo, B120 Telephone call to LoBuglio re balance sheet and other financial 0.4 $1,075.00 $430.00
Byron Z. issues
10/20/2025 Moldo, B210 Review So Cal Gas objection to motion re utilities 0.2 $1,075.00 $215.00
Byron Z.
10/20/2025 Stone, B230 Review UST objection; review Panther opposition/objection re 3.2 $650.00 $2,080.00
Chase A. prepetition vendors/cash collateral; review SoCalGas; review
budget and conf. w/ S. Samarasinghe; review timing re 2:00 p.m.
deadline; instruct D. Perez/A. Antonio to prepare for filing that
afternoon.
10/20/2025 Stone, B230 Prepare omnibus reply to UST; Settle; Panther; and SoCalGas; 1.3 $650.00 $845.00
Chase A. draft reply; draft declaration; teleconf. w/ S. Samarasinghe.
10/20/2025 Stone, B110 Review Debtor's tax returns (2023, 2022), prior balance sheet, 0.8 $650.00 $520.00
Chase A. revised balance sheet, and P&L statements; analyze financial data
for Schedule A/B preparation.
10/20/2025 Stone, B110 Obtain and review copies of Debtor's licensing documentation and 0.3 $650.00 $195.00
Chase A. depreciation/amortization schedules.
10/20/2025 Stone, B110 Teleconference with C. Samarasinghe and V. Samarasinghe 0.5 $650.00 $325.00
Chase A. regarding financial disclosures and schedules; discuss outstanding
information needs.
10/20/2025 Stone, B110 Prepare and draft Schedule A/B based on review of financial 1.3 $650.00 $845.00
Chase A. documents, tax returns, and balance sheets; coordinate asset
classifications and valuations.
10/20/2025 Stone, B230 Revise critical vendors motion; incorporate financial data and 0.9 $650.00 $585.00
Chase A. adjustments based on client discussions.
10/20/2025 Stone, B110 Finalize and approve e-file Schedule A/B; prepare email 0.9 $650.00 $585.00
Chase A. correspondence regarding hearing preparation for morning
proceedings; confirm filing and next steps.
10/21/2025 Slater, Jared B160 Review response from BPM LLP regarding employment 0.2 $655.00 $131.00
application information
10/21/2025 Slater, Jared B160 Prepare Notice of Application and Application of Debtor and 1.4 $655.00 $917.00
Debtor-In-Possession For Authority to Employ BPM LLP As
Special Accountant for the Estate and Statement of Disinterest
10/21/2025 Slater, Jared B160 E-mail to BPM LLP requesting information to prepare employment 0.4 $655.00 $262.00
application on company's behalf
10/21/2025 Slater, Jared B160 E-mail to Brightpoint Law requesting information to prepare 0.3 $655.00 $196.50
employment application on company's behalf
10/21/2025 Moldo, B210 Review LoBuglio letter and financial information re operations 0.3 $1,075.00 $322.50
Byron Z.
Exhibit 1 – Page 11
Case 2:25-bk-18374-BR Doc 214 Filed 10/27/26 Entered 10/27/26 16:15:01 Desc
Main Document Page 30 of 84
Date Timekeeper Code Description Hours Rate Amount
10/21/2025 Moldo, B210 Telephone call to client re court ruling and continued operations 0.5 $1,075.00 $537.50
Byron Z.
10/21/2025 Stone, B230 Prepare for hearing on emergency motions; organize exhibits and 1.2 $650.00 $780.00
Chase A. supporting documents; compile materials for court binders.
10/21/2025 Stone, B410 Conf. w/ S. Samarasinghe re following hearing next steps; 2.1 $650.00 $1,365.00
Chase A. teleconf. w/ DIP financer; teleconf. w/ B. Moldo; teleconf. w/ Z.
Bohlender; review additional information from S. Samarasinghe re
next steps/Ch. 7.
10/21/2025 Moldo, B210 Review proposed orders denying emergency motions 0.2 $1,075.00 $215.00
Byron Z.
10/21/2025 Stone, B230 Teleconf. w/ Z. Bohlender; email/correspondence w/ S. 0.8 $650.00 $520.00
Chase A. Samarasinghe re DIP financing; review prior email/correspondence
re same.
10/21/2025 Stone, B230 Print and assemble court binders for emergency motions hearing; 0.8 $650.00 $520.00
Chase A. prepare copies for review with client.
10/21/2025 Stone, B230 Appear at hearing before Judge Russell on emergency motions; 2.4 $650.00 $1,560.00
Chase A. present argument; respond to court's questions; confer with client
and opposing counsel.
10/21/2025 Stone, B410 Post-hearing teleconf. with S. Samarasinghe regarding anticipated 0.5 $650.00 $325.00
Chase A. issues for next steps re conversion to chapter 7.
10/21/2025 Stone, B230 Review/teleconf. w/ team re strategy and legal advice to CIS; 0.9 $650.00 $585.00
Chase A. discussion w/ S. Samarasinghe re funding; teleconf. w/ Altbank;
schedule/call w/ Settle counsel.
10/22/2025 Slater, Jared B160 Meeting with C. Stone to discuss employment application for BPM 0.3 $655.00 $196.50
10/22/2025 Slater, Jared B160 Revise employment application for BPM 0.3 $655.00 $196.50
10/22/2025 Slater, Jared B160 E-mails to and review responses from BPM regarding draft 0.2 $655.00 $131.00
employment application
10/22/2025 Moldo, B210 Conference Olson re court hearing and possible continued 1.0 $1,075.00 $1,075.00
Byron Z. operations
10/22/2025 Moldo, B150 Prepare letter to Amin re Newtek Bank 0.2 $1,075.00 $215.00
Byron Z.
10/22/2025 Moldo, B120 Telephone call to Cappello, Bohlender, Luccarelli re claims against 0.4 $1,075.00 $430.00
Byron Z. Panthers
10/22/2025 Moldo, B210 Negotiations with client and secured creditors re continued 1.5 $1,075.00 $1,612.50
Byron Z. operations
10/22/2025 Stone, B150 Teleconference with S. Olson regarding CIS posture, next 0.5 $650.00 $325.00
Chase A. steps/considerations, and coordination with Polsinelli/Z.
Bohlender; define action items and timelines.
10/22/2025 Stone, B110 Review and analyze bankruptcy court notices and orders; confirm 0.8 $650.00 $520.00
Chase A. status and next steps; circulate to client; teleconf. w/ S.
Samarasinghe.
10/22/2025 Stone, B110 Prepare and send status updates on CIS re client inquiry; 0.5 $650.00 $325.00
Chase A. coordinate scheduling with team for follow-up discussions re
Polsenelli/Z. Bohlender.
10/22/2025 Stone, B150 Review Newtek UCC correspondence; assess implications for CIS 0.4 $650.00 $260.00
Chase A. matter; respond with requested information and next steps.
10/22/2025 Stone, B420 Email correspondence with co-counsel and client team re CIS 0.6 $650.00 $390.00
Chase A. strategy; DFPI issues; Altbanc/Settle follow up; compile and
forward background materials; outline next steps/items.
10/22/2025 Stone, B160 Meeting with J. Slater re employment/retention applications in CIS 0.5 $650.00 $325.00
Chase A. (scope, disclosures, proposed terms, filing timeline);
outline/drafting and required exhibits.
Exhibit 1 – Page 12
Case 2:25-bk-18374-BR Doc 214 Filed 10/27/26 Entered 10/27/26 16:15:01 Desc
Main Document Page 31 of 84
Date Timekeeper Code Description Hours Rate Amount
10/22/2025 Stone, B150 Email/correspondence and analysis of Panthers priority in context 0.7 $650.00 $455.00
Chase A. of Settle UCC; discussion w/ S. Samarasinghe re next steps;
teleconf. w/ S. Samarasinghe.
10/23/2025 Moldo, B120 Telephone call from Goodrich re case status 0.5 $1,075.00 $537.50
Byron Z.
10/23/2025 Moldo, B150 Telephone call to Amin, Stark re Newtek loan 0.5 $1,075.00 $537.50
Byron Z.
10/23/2025 Stone, B420 Teleconf./email w/ Z. Bohlender re Settle and 0.6 $650.00 $390.00
Chase A. forwarding/communication w/ Seyfarth and Altbanc to facilitate
possible assignment; teleconf. re same.
10/23/2025 Stone, B420 Email/correspondence re Z. Bohlender, Panther timeline; circulate 1.4 $650.00 $910.00
Chase A. notice of Lodgment re conversion to Chapter 7; reivwe/coordinate
correspondence and answer questions re S. Samarsinghe.
10/23/2025 Stone, B420 Review inquiries re D. Goodrich and next steps; setup 0.6 $650.00 $390.00
Chase A. call/email/correspondence w/ D. Goodrich and S. Samarasinghe.
10/24/2025 Slater, Jared B160 E-mail to Z. Bohlender regarding Brightpoint law employment 0.1 $655.00 $65.50
application
10/24/2025 Stone, B110 Review/respond to email from CT counsel re Chapter 7 0.2 $650.00 $130.00
Chase A. appointment.
10/24/2025 Stone, B120 Review UCC recordation dates; review lien stack summary re Z. 0.9 $650.00 $585.00
Chase A. Bohlender; draft/summarize email to D. Goodrich re cash
collateral.
10/24/2025 Stone, B190 Review/analyze email from P. Luccarelli re CT case. 0.1 $650.00 $65.00
Chase A.
10/24/2025 Stone, B420 Compile documentation for Chapter 7 trustee D. Goodrich; 0.6 $650.00 $390.00
Chase A. organize and prepare; review add'l information re UCC filings, and
related entity documentation; send materials to trustee (L. Robles).
10/24/2025 Stone, B420 Additional legal analysis re related litigation (as to automatic stay 0.5 $650.00 $325.00
Chase A. over non-debtors/individual principals); procedural options/veil
piercing; strategic implications.
10/27/2025 Stone, B420 Teleconf./emails w/ D. Goodrich re information/summary and 0.6 $650.00 $390.00
Chase A. provide additional updates at request of S. Samarasinghe.
10/27/2025 Stone, B110 Respond to inquiries re S. Samarasinghe Ch. 7. 0.2 $650.00 $130.00
Chase A.
10/27/2025 Stone, B420 Teleconf. w/ D. Goodrich, S. Samarsinghe re next steps and answer 0.5 $650.00 $325.00
Chase A. inquiries re same.
10/27/2025 Stone, B240 Email/forward inquiry from S. Montgomery re EDD to D. 0.2 $650.00 $130.00
Chase A. Goodrich; respond re same.
10/27/2025 Stone, B420 Review and analyze Chapter 7 bankruptcy filing for CIS; prepare 0.4 $650.00 $260.00
Chase A. extensive summary and documentation for J. Wyche; follow-
up/coordinate with B. Kowieski.
10/27/2025 Stone, B420 Address AltBanc financing issues; correspondence with Z. 0.3 $650.00 $195.00
Chase A. Bohlender regarding banking matters and alternative financing
options; draft/send email and further responses to trustee inquiries.
10/29/2025 Slater, Jared B160 E-mail to BPM to follow up on CV request 0.1 $655.00 $65.50
10/29/2025 Stone, B420 Teleconf. w/ Z. Bohlender re Ch. 7 trustee; structuring newco; 1.1 $650.00 $715.00
Chase A. Settle/Alltbanc discussions, etc.
10/30/2025 Stone, B110 Email to Banc of Commerce; review email from Z. Bohlender re 0.3 $650.00 $195.00
Chase A. updates (cash); review/respond to inquiry from S. Samarasinghe re
container.
Exhibit 1 – Page 13
Case 2:25-bk-18374-BR Doc 214 Filed 10/27/26 Entered 10/27/26 16:15:01 Desc
Main Document Page 32 of 84
Date Timekeeper Code Description Hours Rate Amount
10/30/2025 Stone, B420 Review/analyze progress updates/extensive communication w/ S. 0.6 $650.00 $390.00
Chase A. Samarsinghe and Z. Bohlender; follow-up correspondence to J.
Wyche; discussion re asset sales v. disposition to Lionsrock and
possible scenarios/outcomes.
10/30/2025 Stone, B130 Teleconf. w/ S. Samarsinghe re DB containers; additional issue re 0.2 $650.00 $130.00
Chase A. D. Goodrich.
10/31/2025 Stone, B120 Teleconf. w/ Commerce Bank re CIS bank accounts; review email 0.6 $650.00 $390.00
Chase A. from Z. Bohlender; forward info to J. Wyche re same.
10/31/2025 Stone, B420 Teleconf. w/ Z. Bohlender; next steps; forward inquriy at request 0.5 $650.00 $325.00
Chase A. of CIS to D. Goodrich re same; email to J. Wyche re same.
10/31/2025 Stone, B420 Review information and summary of Letter of Intent to Trustee; 0.3 $650.00 $195.00
Chase A. correspondence with Z. Bohlender.
10/31/2025 Stone, B420 Further email/correspondence and extensive coordination w/ S. 0.6 $650.00 $390.00
Chase A. Samarsinghe and Z. Bohlender w/ D. Goodrich re update (notice to
abandon); follow-up teleconf/ w. S. Samrasinghe re same and
discussion/analysis of next steps.
11/02/2025 Stone, B420 Review/email from Z. Bohlender re motion to abandon; forward to 0.2 $650.00 $130.00
Chase A. B. Moldo.
11/03/2025 Moldo, B130 Review NewTek limited opposition to trustee motion to abandon 0.1 $1,075.00 $107.50
Byron Z.
11/03/2025 Stone, B150 Confer with D. Goodrich new CIS issues; analyze questions and 0.5 $650.00 $325.00
Chase A. provide recommendations; circulate follow up
11/03/2025 Stone, B130 Review/forward joinder filed by Panthers to NewTek opposition to 0.2 $650.00 $130.00
Chase A. abandonment.
11/04/2025 Stone, B110 Teleconf. w/ S. Samarsinghe; review/forward order to continue 0.9 $650.00 $585.00
Chase A. hearing; send email to D. Goodrich; provide further
instruction/email to S. Samarasinghe/V. Samarasinghe; send ACH
instructions to D. Goodrich.
11/05/2025 Stone, B120 Review email re V. Samarasinghe (pending AR from Petco); 0.3 $650.00 $195.00
Chase A. prepare subsequent response re clarification; note for further
inquiry to D. Goodrich.
11/06/2025 Stone, B130 Review/send documents to Z. Bohlender re Panthers objection; 0.3 $650.00 $195.00
Chase A. review email/follow-up request for information from S.
Samarsinghe.
11/07/2025 Stone, B130 Draft correspondence to V. Samarasinghe and S. Samarasinghe re 1.2 $650.00 $780.00
Chase A. notice of continued hearing on motion to abandon; review motion
to abandon; review add'l issues re Wisconsin and Live Aquaria
acquisitions.
11/10/2025 Stone, B150 Review/forward email to D. Goodrich re creditor inquiry. 0.2 $650.00 $130.00
Chase A.
11/10/2025 Stone, B110 Review status report prepared by D. Goodrich; review email from 0.4 $650.00 $260.00
Chase A. H. Basri re claim (Director of CV Sematik Perkasa); review
subsequent inquiry from D. LoBuglio.
11/11/2025 Stone, B110 Review/reply to S. Samarasinghe; email to D. Goodrich re status 0.2 $650.00 $130.00
Chase A. report.
11/11/2025 Stone, B160 Prepare fee application through Oct. 22; review LBRs; prepare 0.8 $650.00 $520.00
Chase A. declaration re same; send email/analysis to B. Moldo.
11/11/2025 Stone, B150 Teleconf. w/ A. Fletcher; review documents; send request/email to 1.1 $650.00 $715.00
Chase A. A. Antonio and D. Perez; review prior communications re
settlement agreement; update re B. Moldo; send analysis to A.
Fletcher.
11/11/2025 Stone, B160 Review iManage documents re employment applications; access 0.5 $650.00 $325.00
Chase A. PACER/CM/ECF for case filings; research declaration re non-
opposition procedures and forms.
Exhibit 1 – Page 14
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Main Document Page 33 of 84
Date Timekeeper Code Description Hours Rate Amount
11/11/2025 Stone, B110 Forward 341(a) meeting info to S. Samarasinghe and review B. 0.3 $650.00 $195.00
Chase A. Moldo emails re CIS/DFPI. Confirm declaration re non-opposition
procedures and access PACER for case filings.
11/12/2025 Stone, B110 Review/email/correspondence w/ S. Samarasinghe re scheduling. 0.2 $650.00 $130.00
Chase A.
11/12/2025 Stone, B130 Teleconf. re status of abandonment; review email/follow-up from 1.9 $650.00 $1,235.00
Chase A. D. Goodrich; provide further analysis/send email to D. Goodrich re
response; forward additional info to S. Samarasinghe; respond to
V. Samarasinghe inquiry re same.
11/12/2025 Stone, B120 Review/respond to inquiries re D. Goodrich; review add'l email 1.2 $650.00 $780.00
Chase A. correspondence from S. Samarasinghe; forward add'l
documentation; review additional invoices from Petco.
11/13/2025 Stone, B120 Review/send docs to D. Goodrich; provide further information; 1.1 $650.00 $715.00
Chase A. teleconf. re B. Moldo; review Panthers A/R statements.
11/13/2025 Stone, B120 Cont. re request providing/send further correspondence to D. 1.8 $650.00 $1,170.00
Chase A. Goodrich; review/analyze; teleconf re same; further analysis re
asset schedule; follow-up email to P. Luccarelli re status of stay.
11/13/2025 Stone, B150 Email correspondence to I. Amin and C. Stark re NewTek. 0.2 $650.00 $130.00
Chase A.
11/14/2025 Stone, B140 Review court filings re transcript/notice of deficiency; 0.5 $650.00 $325.00
Chase A. correspondence with D. Goodrich; email to P. Luccarelli re
extending bankruptcy stay to related entities; forward materials re
next steps.
11/14/2025 Stone, B150 Review/respond to emails from P. Luccarelli re bankruptcy stay. 0.2 $650.00 $130.00
Chase A.
11/16/2025 Stone, B150 Review email from B. Kowiecki; save/note for further 0.2 $650.00 $130.00
Chase A. updates/follow-up re abandonment.
11/17/2025 Moldo, B120 Review documents re Wisconsin property 0.3 $1,075.00 $322.50
Byron Z.
11/17/2025 Moldo, B120 Conference Goodrich, client re real property transactions 0.5 $1,075.00 $537.50
Byron Z.
11/17/2025 Stone, B110 Review email from V. Samarsinghe re employee backpay; forward 0.2 $650.00 $130.00
Chase A. to B. Moldo re inquiry.
11/17/2025 Stone, B150 Email/respond to V. Samarsinghe re 341(a). 0.2 $650.00 $130.00
Chase A.
11/17/2025 Stone, B150 Send/draft follow-up email for 341(a) meeting; review prior notes 0.3 $650.00 $195.00
Chase A. from 341(a) w/ UST.
11/17/2025 Stone, B110 Prepare/finalize form 1019. 1.3 $650.00 $845.00
Chase A.
11/17/2025 Stone, B110 Teleconf. w/ B. Moldo; prepare Form 9019; organize/review 0.5 $650.00 $325.00
Chase A. documents for 341(a) meeting of creditors.
11/17/2025 Stone, B110 Teleconf. w/ S. Samarasinghe; review documents; send email to D. 1.2 $650.00 $780.00
Chase A. Goodrich to confirm; send email to B. Moldo re same.
11/17/2025 Stone, B150 Teleconf. w/ D. Goodrich re preparation of 341(a). 0.5 $650.00 $325.00
Chase A.
11/17/2025 Stone, B110 Email/send documents re D. Goodrich; provide add'l analysis. 0.3 $650.00 $195.00
Chase A.
11/17/2025 Stone, B110 Further email/review correspondence and forward documents to D. 0.2 $650.00 $130.00
Chase A. Goodrich re same.
11/18/2025 Stone, B150 Review 341(a) email/update from D. Goodrich; review DIP 0.4 $650.00 $260.00
Chase A. account statement from V. Samarasinghe; forward to D. Goodirch.
Exhibit 1 – Page 15
Case 2:25-bk-18374-BR Doc 214 Filed 10/27/26 Entered 10/27/26 16:15:01 Desc
Main Document Page 34 of 84
Date Timekeeper Code Description Hours Rate Amount
11/18/2025 Stone, B110 Continue preparation Form 1019; email/forward attachments to D. 1.2 $650.00 $780.00
Chase A. Goodrich re closing statements; inquire re S. Samarasinghe re
same.
11/18/2025 Stone, B110 Review/finalize Form 1019; forward request to D. Goodrich re 0.5 $650.00 $325.00
Chase A. acount statements.
11/18/2025 Stone, B110 Email/review revise CIS and send email to D. Goodrich; request 0.2 $650.00 $130.00
Chase A. Docusgin from V. Samarasinghe and S. Samarasinghe.
11/19/2025 Stone, B150 Email/review preparation for 341(a); summarize list of 0.3 $650.00 $195.00
Chase A. items/follow-up w/ S. Samarasinghe; teleconf. re same.
11/19/2025 Stone, B150 Teleconf. w/ S. Samarsinghe. 0.7 $650.00 $455.00
Chase A.
11/19/2025 Stone, B150 341(a) 2.2 $650.00 $1,430.00
Chase A.
11/19/2025 Stone, B150 Review list of notes; prepare/itemize list of documents to send to 0.3 $650.00 $195.00
Chase A. D. Goodrich.
11/20/2025 Stone, B150 Review notes from 341(a); set up hearing folder re uploading files 0.9 $650.00 $585.00
Chase A. for V. Samarasinghe and S. Samarasinghe; email to D. Goodrich re
articles; teleconf. w/ B. Moldo re same; follow up re employee
request/letter issue.
11/20/2025 Stone, B150 Teleconf. w/ counsel for SBA re priority; forward inquiry to S. 0.6 $650.00 $390.00
Chase A. Samarsinghe.
11/21/2025 Allen, B160 Reviewed the file re preparing the fee app 0.7 $535.00 $374.50
Dylan
11/21/2025 Stone, B190 Teleconf. w/ P. Lucarelli; follow-up email to D. Goodrich re Ct 1.2 $650.00 $780.00
Chase A. litigation; analyze legal authorities in aid of jurisdiction analysis.
11/22/2025 Stone, B190 Review correspondence freom P. Luccarelli; review 0.2 $650.00 $130.00
Chase A. correspondence from A. Fletcher re same.; review response from
D. Goodrich re complaint/timing of call.
11/24/2025 Stone, B160 Review/revise stipulation; review proposed order; lodge CIS order 1.2 $650.00 $780.00
Chase A. re employment; send documents re template to B. Moldo for
review; approve/upload notice of lodgment and declaration of non
opposition.
11/25/2025 Stone, B150 Continue drafting CIS fee application re 327 compensation; email 1.2 $650.00 $780.00
Chase A. to A. Fletcher re facts of declaration.
11/25/2025 Stone, B190 Review email from A. Fletcher re Panthers security interest; 0.2 $650.00 $130.00
Chase A. respond re same; prepare/draft response.
11/26/2025 Stone, B140 Review correspondence from P. Lucarrelli re S. Samarasinghe; 0.3 $650.00 $195.00
Chase A. review subsequent email from S. Samarasinghe
11/27/2025 Stone, B310 Review proof of claim re submission of Willy Hartano (twice 0.2 $650.00 $130.00
Chase A. submitted); to analyze whether erroneous/separate claims for
preparation of amended schedules as of Petition Date.
12/01/2025 Stone, B190 Teleconf. w/ D. Goodrich and P. Lucarelli. 0.8 $650.00 $520.00
Chase A.
12/01/2025 Stone, B110 Review email correspondence from V. Samarsinghe; review notes 0.5 $650.00 $325.00
Chase A. re 341(a) and continue revising/review amendments to schedules.
12/02/2025 Stone, B160 Review docket re order of employment. 0.2 $650.00 $130.00
Chase A.
12/03/2025 Stone, B410 Email to CIS principal re documents and lawsuit inquiries; 0.3 $650.00 $195.00
Chase A. answer/referral to counsel re same; prepare response/send via
email.
12/04/2025 Stone, B190 Review/respond to email to S. Samarasinghe re PG lawsuit. 0.2 $650.00 $130.00
Chase A.
Exhibit 1 – Page 16
Case 2:25-bk-18374-BR Doc 214 Filed 10/27/26 Entered 10/27/26 16:15:01 Desc
Main Document Page 35 of 84
Date Timekeeper Code Description Hours Rate Amount
12/04/2025 Stone, B130 Review notice of assets re D. Goodrich. 0.2 $650.00 $130.00
Chase A.
12/04/2025 Stone, B150 Review files uploaded by S. Samarasinghe; send 0.3 $650.00 $195.00
Chase A. response/reminder re request from D. Goodrich to share prior to
341(a); organize.
12/04/2025 Stone, B160 Prepare/review and draft first fee statement (Sept. 2025). 0.2 $650.00 $130.00
Chase A.
12/04/2025 Stone, B160 Prepare/review second fee statement (October 2025). 0.2 $650.00 $130.00
Chase A.
12/05/2025 Stone, B190 Review/respond to email from P. Lucarelli re removal issues/next 0.3 $650.00 $195.00
Chase A. steps.
12/05/2025 Stone, B190 Teleconf. w/ B. Moldo; teleconf. w/ Z. Bohlender; review email re 0.5 $650.00 $325.00
Chase A. Z. Bohlender about adversary.
12/08/2025 Stone, B110 Email/reply to D. Goodrich; review files from CIS debtor re same; 0.3 $650.00 $195.00
Chase A. review email and set up call re group.
12/08/2025 Stone, B110 Teleconf. w/ B. Moldo; email to D. Goodrich. 0.2 $650.00 $130.00
Chase A.
12/09/2025 Stone, B190 Email/reply to P. Lucarelli re removal. 0.2 $650.00 $130.00
Chase A.
12/09/2025 Stone, B110 Teleconf. w/ D. Goodrich; email to S. Samarasinghe; email to A. 1.6 $650.00 $1,040.00
Chase A. Antonio/D. Perez re continuance; teleconf. w/ P. Lucarrelli; email
to group of interested professionals.
12/09/2025 Stone, B190 Review pleading re reply to opposition re Panthers. 0.5 $650.00 $325.00
Chase A.
12/09/2025 Stone, B110 Teleconf. w/ P. Luccarelli; continue amendment of schedules; 1.2 $650.00 $780.00
Chase A. email to B. Moldo re status/forward; email to group re
attorneys/contingency claims.
12/10/2025 Stone, B110 Follow-up w/ Z. Bohlender. 0.1 $650.00 $65.00
Chase A.
12/11/2025 Stone, B190 Review correspondence from S. Samarasinghe re personal 0.1 $650.00 $65.00
Chase A. guaranty case.
12/11/2025 Stone, B110 Review email from A. Antonio re documents sent from V. 0.1 $650.00 $65.00
Chase A. Samarsinghe.
12/11/2025 Stone, B160 Teleconf. w/ L. Ponce. 0.0 $0.00 $0.00
Chase A.
12/12/2025 Stone, B190 Review summons re personal guaranty lawsuit against S. 0.4 $650.00 $260.00
Chase A. Samarasinghe; send email to S. Samarasinghe re reply to lawsuit
issues; review/email and follow-up; provide response re personal
representation; review subsequent email from Z. Bohlender.
12/12/2025 Moldo, B120 Telephone call to Bohlender, Stone re proposed action against 0.5 $1,075.00 $537.50
Byron Z. Panthers
12/12/2025 Stone, B110 Teleconf. w/ Z. Bohlender; follow-up w/ B. Moldo. 0.8 $650.00 $520.00
Chase A.
12/16/2025 Stone, B190 Email/follow-up to J. Atabak re email/schedule. 0.1 $650.00 $65.00
Chase A.
12/16/2025 Stone, B185 Review notice of lodgment re motion to abandon lease; review 0.3 $650.00 $195.00
Chase A. notice of lodgment re denial of motion to reconsider; email to A.
Fletcher re follow-up.
12/16/2025 Stone, B190 Review email from P. Lucarelli; review/respond to email from A. 0.1 $650.00 $65.00
Chase A. Fletcher.
12/18/2025 Stone, B110 Review/respond to email from D. Goodrich; forward attachments. 0.3 $650.00 $195.00
Chase A.
Exhibit 1 – Page 17
Case 2:25-bk-18374-BR Doc 214 Filed 10/27/26 Entered 10/27/26 16:15:01 Desc
Main Document Page 36 of 84
Date Timekeeper Code Description Hours Rate Amount
12/18/2025 Moldo, B120 Telephone call to Atabek re claims against Panthers 0.5 $1,075.00 $537.50
Byron Z.
12/18/2025 Stone, B190 Teleconf. w/ J. Atabek; email to V. Samarsinghe and S. 0.8 $650.00 $520.00
Chase A. Samarasinghe; follow-up w/ D. Goodrich; review motion to be
relieved as counsel; review follow-up emails from P. Lucarelli and
Z. Bohlender.
12/22/2025 Stone, B110 Email to D. Goodrich; email to S./V. Samarasinghe; teleconf. w/ B. 0.5 $650.00 $325.00
Chase A. Moldo re same.
12/23/2025 Stone, B140 Review/notify S. Samarasinghe re relief from stay; forward 0.5 $650.00 $325.00
Chase A. correspondence to D. Goodrich; review subsequent follow-up
email from V. Samarasinghe re DIP account; review subsequent
response re smae.
12/23/2025 Stone, B150 Draft/respond to email re payments to CIS employees explaining 0.3 $650.00 $195.00
Chase A. issues re payment from CIS and prior requests.
12/24/2025 Stone, B110 Review entry of two orders re NEF. 0.2 $650.00 $130.00
Chase A.
12/29/2025 Stone, B310 Review correspondence from B. Moldo re proof of claim. 0.1 $650.00 $65.00
Chase A.
12/30/2025 Stone, B310 Review email from B. Moldo re proof of claim; download proof of 0.2 $650.00 $130.00
Chase A. claim re S. Samarasinghe.
12/30/2025 Stone, B110 Draft/review amended schedules. 0.7 $650.00 $455.00
Chase A.
01/05/2026 Stone, B110 Review calendar; email to D. Goodrich; email to S. Samarasinghe; 0.1 $650.00 $65.00
Chase A. teleconf. w/ B. Moldo.
01/05/2026 Stone, B110 Email to D. Goodrich; email to S. Samarsinghe; review/send 0.2 $650.00 $130.00
Chase A. follow-up re same.
01/05/2026 Stone, B130 341(a) meeting of creditors - concluded; summarize/follow-up w/ 0.8 $650.00 $520.00
Chase A. B. Moldo re next steps; add/edit list of documents.
01/05/2026 Stone, B110 Review/draft/send correspondence; send further 0.2 $650.00 $130.00
Chase A. information/correspondence to S. Samarasinghe re same.
01/06/2026 Stone, B110 Review/respond to request from D. Goodrich re files; send follow- 0.5 $650.00 $325.00
Chase A. up email to S. Samarasinghe/V. Samarasinghe re request.
01/07/2026 Stone, B140 Email/response to S. Samarasinghe re lift stay. 0.2 $650.00 $130.00
Chase A.
01/12/2026 Stone, B110 Email to J. Atabek; email/follow-up w/ Debtor; email/follow-up to 0.2 $650.00 $130.00
Chase A. D. Goodrich.
01/13/2026 Stone, B130 Email to D. Goodrich; response re Izusu; send email to B. Moldo 0.3 $650.00 $195.00
Chase A. re prepetition liens.
01/14/2026 Stone, B310 Review communication w/ D. Goodrich re liens, further discussion 0.2 $650.00 $130.00
Chase A. w/ B. Moldo to confirm insight.
01/20/2026 Stone, B110 Review email from V. Samarsinghe; send to D. Goodrich re 0.3 $650.00 $195.00
Chase A. update.
01/21/2026 Stone, B110 Review D. Goodrich reply; send further response to V. 0.3 $650.00 $195.00
Chase A. Samarsinghe; conf. w/ B. Moldo/D.LoBuglio re same.
02/12/2026 Stone, B110 Email/review/respond re Chapter 7 filing. 0.1 $650.00 $65.00
Chase A.
09/08/2026 Stone, B110 Emails to and from B. Moldo re CIS International Holdings 0.2 $650.00 $130.00
Chase A. bankruptcy inquiry.
09/22/2026 Stone, B110 Teleconf. w/ S. Malmed re CIS International re fee application. 0.2 $650.00 $130.00
Chase A.
09/23/2026 Malmed, B160 Conference with C. Stone re case and fee app. 0.1 $545.00 $54.50
Shantal
Exhibit 1 – Page 18
Case 2:25-bk-18374-BR Doc 214 Filed 10/27/26 Entered 10/27/26 16:15:01 Desc
Main Document Page 37 of 84
Date Timekeeper Code Description Hours Rate Amount
09/23/2026 Malmed, B160 Draft fee app. 2.1 $545.00 $1,144.50
Shantal
09/24/2026 Malmed, B160 Revise fee app. 0.3 $545.00 $163.50
Shantal
09/25/2026 Malmed, B160 Finalize fee app and correspond with C. Stone re same. 2.9 $545.00 $1,580.50
Shantal
09/28/2026 Stone, B110 Emails to and from R. Williamson and S. Samarasinghe re call re 0.3 $650.00 $195.00
Chase A. engaging Newtek Bank and D. Goodrich.
09/28/2026 Stone, B110 Emails to and from S. Malmed re review of fee application. 0.2 $650.00 $130.00
Chase A.
09/28/2026 Malmed, B160 Correspond with C. Stone re fee app. 0.1 $545.00 $54.50
Shantal
09/29/2026 Stone, B110 Emails to and from R. Williamson re Chase / Richard request for 0.3 $650.00 $195.00
Chase A. call Re: Introducing Attorney for LionsRock - Re. CIS re Chapter 7
to Chapter 11 conversion and trustee counsel contact information
for release of held funds.
09/30/2026 Stone, B110 Emails to and from A. Gill re CIS International / Tokyo Century 0.2 $650.00 $130.00
Chase A. Rule 2004 exam scheduling and meet and confer conference under
LBR 7026-1(c).
10/02/2026 Stone, B110 Meet and confer w/ Angela Gill re Tokyo Century; next steps/email 0.5 $650.00 $325.00
Chase A. w/ R. Williamson to assist w/ vehicle collateral, and
cooperation/location of estate assets.
10/05/2026 Stone, B110 Correspond w/ S. Burnell (Greenspoon Marder) and R. Williamson 0.3 $650.00 $195.00
Chase A. re CIS International, including introducing counsel for Mr.
Samarsinghe to debtor's counsel and concerns of debtor's principal.
10/05/2026 Malmed, B160 Correspond with C. Stone re fee app. 0.1 $545.00 $54.50
Shantal
10/06/2026 Stone, B110 Emails to and from A. Gill re Tokyo Century. 0.2 $650.00 $130.00
Chase A.
10/06/2026 Malmed, B160 Conference with C. Stone re fee app. 0.1 $545.00 $54.50
Shantal
10/07/2026 Stone, B110 Emails to and from S. Samarasinghe regarding withdrawal of claim 0.2 $650.00 $130.00
Chase A. in Central District of California bankruptcy matter and execution
of amended settlement agreement.
10/13/2026 Malmed, B160 Conference with C. Stone re fee app. 0.3 $545.00 $163.50
Shantal
10/13/2026 Malmed, B160 Revise fee app; correspond with B. Moldo re same. 2.4 $545.00 $1,308.00
Shantal
10/14/2026 Moldo, B160 Prepare ECJ final fee application 1.0 $1,150.00 $1,150.00
Byron Z.
10/14/2026 Malmed, B160 Review B. Moldo's redline changes to fee app and correspond with 0.4 $545.00 $218.00
Shantal B. Moldo re same.
10/14/2026 Malmed, B160 Revise fee app. 1.8 $545.00 $981.00
Shantal
10/14/2026 Malmed, B160 Correspond with L. Ponce and B. Moldo re revised invoice 0.3 $545.00 $163.50
Shantal reflecting new time entries re revising fee app.
10/14/2026 Malmed, B160 Correspond with S. Burnell re value of estate funds re preparation 0.2 $545.00 $109.00
Shantal of first and final fee app.
10/14/2026 Malmed, B160 Review docket re revising fee app. 0.2 $545.00 $109.00
Shantal
10/14/2026 Malmed, B160 Review local rules re 9013-1(o) and negative notice; correspond 0.2 $545.00 $109.00
Shantal with B. Moldo re same.
Exhibit 1 – Page 19
Case 2:25-bk-18374-BR Doc 214 Filed 10/27/26 Entered 10/27/26 16:15:01 Desc
Main Document Page 38 of 84
Date Timekeeper Code Description Hours Rate Amount
10/15/2026 Malmed, B160 Revise fee app; correspond with B. Moldo re same. 1.7 $545.00 $926.50
Shantal
10/15/2026 Malmed, B160 Correspond with S. Carson re revising exhibits to fee app. 0.2 $545.00 $109.00
Shantal
10/15/2026 Malmed, B160 Review new billing statement re correspondence with L. Ponce re 0.5 $545.00 $272.50
Shantal revising fee app.
Total Fees 234.5 $167,091.50
Summary of Fees by Activity Code
Code Description Hours Fees
B110 Case Administration 52.6 $36,227.50
B120 Asset Analysis and Recovery 21.2 $19,390.00
B130 Asset Disposition 5.2 $3,422.50
B140 Relief from Stay/Adequate Protection Proceedings 1.5 $975.00
B150 Meetings of and Communications with Creditors 21.2 $14,460.00
B160 Fee/Employment Applications 33.3 $20,470.50
B170 Fee/Employment Objections 0.2 $130.00
B185 Assumption/Rejection of Leases and Contracts 1.5 $975.00
B190 Other Contested Matters 9.5 $6,276.00
B210 Business Operations 8.0 $6,822.50
B230 Financing/Cash Collateral 62.7 $45,397.50
B240 Tax Issues 3.6 $3,275.00
B310 Claims Administration and Objections 1.0 $777.50
B320 Plan and Disclosure Statement 0.7 $497.50
B410 General Bankruptcy Advice/Opinions 2.9 $1,885.00
B420 Restructurings 9.4 $6,110.00
Total 234.5 $167,091.50
Summary of Fees by Timekeeper
Timekeeper Hours Rate Fees
Moldo, Byron Z. 43.0 $1,075.00 $46,225.00
Moldo, Byron Z. 1.0 $1,150.00 $1,150.00
Slater, Jared 3.6 $655.00 $2,358.00
Stone, Chase A. 148.1 $650.00 $96,265.00
Gabai, Danielle R. 16.3 $550.00 $8,965.00
Allen, Dylan 6.2 $535.00 $3,317.00
Hosfield, Tanner F. 2.4 $515.00 $1,236.00
Malmed, Shantal 13.9 $545.00 $7,575.50
Total 234.5 $167,091.50
Exhibit 1 – Page 20
Case 2:25-bk-18374-BR Doc 214 Filed 10/27/26 Entered 10/27/26 16:15:01 Desc
Main Document Page 39 of 84
Ervin Cohen & Jessup LLP
In re CIS International Holdings (N.A.) Corporation, Case No. 2:25-bk-18374-BR
Itemized Expenses — September 22, 2025 through October 23, 2026
Date Code Description Vendor Amount
10/01/2025 E106 Online Research West Publishing Corporation $35.11
10/03/2025 E108 Postage Expense $2.06
10/06/2025 E101 Outside Document Reproduction Services Craig Sommerstein $250.43
10/07/2025 E106 Online Research PACER Service Center $0.20
10/08/2025 E108 Postage Expense $0.74
10/10/2025 E101 Outside Document Reproduction Services Craig Sommerstein $674.36
10/14/2025 E108 Postage Expense $99.54
10/15/2025 E107 Messenger/Attorney Services Legal Support Network, LLC $79.50
10/15/2025 E107 Messenger/Attorney Services Legal Support Network, LLC $75.00
10/15/2025 E107 Messenger/Attorney Services Legal Support Network, LLC $138.75
10/31/2025 E107 Messenger/Attorney Services First Legal Buyer Inc. $18.70
10/31/2025 E107 Messenger/Attorney Services First Legal Buyer Inc. $12.95
11/19/2025 E108 Postage Expense $172.80
01/06/2026 E106 Online Research PACER Service Center $105.60
Total Expenses $1,665.74
Summary of Expenses by Category
Code Description Amount
E101 Copying $924.79
E106 Online Research $140.91
E107 Delivery Services/Messenger $324.90
E108 Postage $275.14
Total $1,665.74
Total Fees and Expenses $168,757.24
Exhibit 1 – Page 21
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Main Document Page 40 of 84
EXHIBIT “2”
Case 2:25-bk-18374-BR Doc 132
214 Filed 12/03/25
10/27/26 Entered 12/03/25
10/27/26 14:52:18
16:15:01 Desc
Main
MainDocument
Document PagePage41 of 2
84
1 Byron Z. Moldo (SBN 109652)
bmoldo@ecjlaw.com
2 Chase Stone (SBN 335228)
cstone@ecjlaw.com FILED & ENTERED
3 ERVIN COHEN & JESSUP LLP
9401 Wilshire Boulevard, Twelfth Floor
4 Beverly Hills, California 90212-2974 DEC 03 2025
Telephone: (310) 273-6333
5 Facsimile: (310) 859-2325 CLERK U.S. BANKRUPTCY COURT
Central District of CaliShowing the first 150,000 of 234,000 characters. Full text.