Case 2:25-bk-18374-BR Doc 214 Filed 10/27/26 Entered 10/27/26 16:15:01 Desc Main Document Page 1 of 84 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 & JESSUP LLP Case 2:25-bk-18374-BR Doc 214 Filed 10/27/26 Entered 10/27/26 16:15:01 Desc Main Document Page 2 of 84 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 /// 2 FIRST AND FINAL APPLICATION FOR PAYMENT OF FEES AND/OR EXPENSES BY ERVIN COHEN & JESSUP LLP Case 2:25-bk-18374-BR Doc 214 Filed 10/27/26 Entered 10/27/26 16:15:01 Desc Main Document Page 3 of 84 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 FIRST AND FINAL APPLICATION FOR PAYMENT OF FEES AND/OR EXPENSES BY ERVIN COHEN & JESSUP LLP Case 2:25-bk-18374-BR Doc 214 Filed 10/27/26 Entered 10/27/26 16:15:01 Desc Main Document Page 4 of 84 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 / / / 4 FIRST AND FINAL APPLICATION FOR PAYMENT OF FEES AND/OR EXPENSES BY ERVIN COHEN & JESSUP LLP Case 2:25-bk-18374-BR Doc 214 Filed 10/27/26 Entered 10/27/26 16:15:01 Desc Main Document Page 5 of 84 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 5 FIRST AND FINAL APPLICATION FOR PAYMENT OF FEES AND/OR EXPENSES BY ERVIN COHEN & JESSUP LLP Case 2:25-bk-18374-BR Doc 214 Filed 10/27/26 Entered 10/27/26 16:15:01 Desc Main Document Page 6 of 84 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 6 FIRST AND FINAL APPLICATION FOR PAYMENT OF FEES AND/OR EXPENSES BY ERVIN COHEN & JESSUP LLP Case 2:25-bk-18374-BR Doc 214 Filed 10/27/26 Entered 10/27/26 16:15:01 Desc Main Document Page 7 of 84 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 7 FIRST AND FINAL APPLICATION FOR PAYMENT OF FEES AND/OR EXPENSES BY ERVIN COHEN & JESSUP LLP Case 2:25-bk-18374-BR Doc 214 Filed 10/27/26 Entered 10/27/26 16:15:01 Desc Main Document Page 8 of 84 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 8 FIRST AND FINAL APPLICATION FOR PAYMENT OF FEES AND/OR EXPENSES BY ERVIN COHEN & JESSUP LLP Case 2:25-bk-18374-BR Doc 214 Filed 10/27/26 Entered 10/27/26 16:15:01 Desc Main Document Page 9 of 84 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 9 FIRST AND FINAL APPLICATION FOR PAYMENT OF FEES AND/OR EXPENSES BY ERVIN COHEN & JESSUP LLP Case 2:25-bk-18374-BR Doc 214 Filed 10/27/26 Entered 10/27/26 16:15:01 Desc Main Document Page 10 of 84 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 /// 10 FIRST AND FINAL APPLICATION FOR PAYMENT OF FEES AND/OR EXPENSES BY ERVIN COHEN & JESSUP LLP Case 2:25-bk-18374-BR Doc 214 Filed 10/27/26 Entered 10/27/26 16:15:01 Desc Main Document Page 11 of 84 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. 11 FIRST AND FINAL APPLICATION FOR PAYMENT OF FEES AND/OR EXPENSES BY ERVIN COHEN & JESSUP LLP Case 2:25-bk-18374-BR Doc 214 Filed 10/27/26 Entered 10/27/26 16:15:01 Desc Main Document Page 12 of 84 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 FIRST AND FINAL APPLICATION FOR PAYMENT OF FEES AND/OR EXPENSES BY ERVIN COHEN & JESSUP LLP Case 2:25-bk-18374-BR Doc 214 Filed 10/27/26 Entered 10/27/26 16:15:01 Desc Main Document Page 13 of 84 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 FIRST AND FINAL APPLICATION FOR PAYMENT OF FEES AND/OR EXPENSES BY ERVIN COHEN & JESSUP LLP Case 2:25-bk-18374-BR Doc 214 Filed 10/27/26 Entered 10/27/26 16:15:01 Desc Main Document Page 14 of 84 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 FIRST AND FINAL APPLICATION FOR PAYMENT OF FEES AND/OR EXPENSES BY ERVIN COHEN & JESSUP LLP Case 2:25-bk-18374-BR Doc 214 Filed 10/27/26 Entered 10/27/26 16:15:01 Desc Main Document Page 15 of 84 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 FIRST AND FINAL APPLICATION FOR PAYMENT OF FEES AND/OR EXPENSES BY ERVIN COHEN & JESSUP LLP Case 2:25-bk-18374-BR Doc 214 Filed 10/27/26 Entered 10/27/26 16:15:01 Desc Main Document Page 16 of 84 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 FIRST AND FINAL APPLICATION FOR PAYMENT OF FEES AND/OR EXPENSES BY ERVIN COHEN & JESSUP LLP Case 2:25-bk-18374-BR Doc 214 Filed 10/27/26 Entered 10/27/26 16:15:01 Desc Main Document Page 17 of 84 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 & JESSUP LLP Case 2:25-bk-18374-BR Doc 214 Filed 10/27/26 Entered 10/27/26 16:15:01 Desc Main Document Page 18 of 84 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 & JESSUP LLP Case 2:25-bk-18374-BR Doc 214 Filed 10/27/26 Entered 10/27/26 16:15:01 Desc Main Document Page 19 of 84 EXHIBIT “1” Case 2:25-bk-18374-BR Doc 214 Filed 10/27/26 Entered 10/27/26 16:15:01 Desc Main Document Page 20 of 84 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 Case 2:25-bk-18374-BR Doc 214 Filed 10/27/26 Entered 10/27/26 16:15:01 Desc Main Document Page 21 of 84 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 Case 2:25-bk-18374-BR Doc 214 Filed 10/27/26 Entered 10/27/26 16:15:01 Desc Main Document Page 22 of 84 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 Case 2:25-bk-18374-BR Doc 214 Filed 10/27/26 Entered 10/27/26 16:15:01 Desc Main Document Page 23 of 84 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 Case 2:25-bk-18374-BR Doc 214 Filed 10/27/26 Entered 10/27/26 16:15:01 Desc 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 Case 2:25-bk-18374-BR Doc 214 Filed 10/27/26 Entered 10/27/26 16:15:01 Desc 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 California BY toliver DEPUTY CLERK 6 Proposed Attorneys for Former Debtor and Debtor in Possession CIS International Holdings 7 (N.A.) Corporation dba E Tropical Fish 8 9 UNITED STATES BANKRUPTCY COURT 10 CENTRAL DISTRICT OF CALIFORNIA, LOS ANGELES DIVISION 11 12 In re Case No. 2:25-18374-BR 13 CIS International Holdings (N.A.) Corporation Chapter 7 dba E Tropical Fish, 14 ORDER APPROVING APPLICATION TO Debtor. EMPLOY ERVIN COHEN & JESSUP LLP 15 AS GENERAL BANKRUPTCY COUNSEL 16 Hon. Barry Russell 17 [No Hearing Requested] 18 19 On October 13, 2025, CIS International Holdings (N.A.) Corporation dba E Tropical Fish 20 (“CIS” or “Debtor”) filed the Notice of Application and Application of Debtor and Debtor-in- 21 Possession for Authority to Employ Ervin Cohen & Jessup LLP as General Bankruptcy Counsel; 22 and Statement of Disinterestedness (the “Application”) [Docket No. 41]. 23 Pursuant to Local Bankruptcy Rule 9013-1(o)(1)(A)(ii), any opposition or request for 24 hearing was due within fourteen (14) days of filing. On October 22, 2025, this case was converted 25 to Chapter 7 [Docket No. 80]. No opposition to the Application was filed or served. For good 26 cause appearing, it is ORDERED that: 27 The Court, having reviewed the Application, and for good cause, it is hereby 28 1. ORDERED that the Application to employ Ervin Cohen & Jessup LLP (“ECJ”) as 18899.1:11671023.1 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 PagePage42 of 2 84 1 Debtor’s Chapter 11 general bankruptcy counsel is approved, and it is further 2 2. ORDERED that ECJ’s compensation as general bankruptcy counsel is subject to 11 3 U.S.C. § 330. 4 5 ### 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Date: December 3, 2025 25 26 27 28 18899.1:11671023.1 2 Case 2:25-bk-18374-BR Doc 214 Filed 10/27/26 Entered 10/27/26 16:15:01 Desc Main Document Page 43 of 84 EXHIBIT “3” Case 2:25-bk-18374-BR 8/25/26, 11:44 AM Doc 214 Filed 10/27/26 Byron Z. Moldo: Entered Ervin Cohen 10/27/26 16:15:01 & Jessup LLP Desc Main Document Page 44 of 84 Cookie Main Main Settings Content Menu Byron Z. Moldo Partner bmoldo@ecjlaw.com Direct 310.281.6354 Byron Z. Moldo is a Partner and Chair of Receivership, Education Bankruptcy, and Creditors' Rights Services. J.D., Southwestern Law School Born and raised in Los Angeles, Byron’s entire legal career has B.A., University of California, specialized in bankruptcy, receivership, assignments for the Los Angeles benefit of creditors and all aspects of insolvency. He regularly serves as a Receiver in state and federal court cases, as assignee Practice Areas for the benefit of creditors and as a fiduciary in other court- Litigation and Alternative supervised matters. In addition, a substantial portion of his work Dispute Resolution consists of serving as general or special counsel to receivers, Receivership, Bankruptcy, bankruptcy trustees and other fiduciaries. He also represents and Creditors’ Rights Services https://www.ecjlaw.com/professionals-byron-z-moldo#Overview 1/7 Case 2:25-bk-18374-BR 8/25/26, 11:44 AM Doc 214 Filed 10/27/26 Byron Z. Moldo: Entered Ervin Cohen 10/27/26 16:15:01 & Jessup LLP Desc Main Document Page 45 of 84 creditors’ committees and secured creditors, and has been Admissions appointed as a Disbursing Agent, Chapter 11 Plan Confirmation Agent and to serve in other fiduciary capacities. California Byron previously served as a Chapter 7 and 11 Bankruptcy Trustee in the Central District of California for approximately ten years. He also serves as a mediator for the Bankruptcy Mediation Program of the Central District of California, and the United States District Court for the Central District of California. He regularly speaks at, and writes materials for continuing legal education seminars related to bankruptcy and receivership. He is admitted to practice in all state and federal courts in California. Throughout his career Byron has volunteered substantial time by working with children in local sports, and participating in events sponsored by Crossroads School and Windward School where his children attended. Byron’s passions include wine, food and travel. PAST EMPLOYMENT Moldo Davidson Fraioli Seror & Sestanovich LLP, Los Angeles, California, Partner Honors & Recognitions 500 Leading Global Bankruptcy & Restructuring Lawyers, Lawdragon, 2025, 2026 Legal ‘Visionary’, L.A. Times, Business of Law, 2022 Best Lawyers in America, Recognized since 2008 https://www.ecjlaw.com/professionals-byron-z-moldo#Overview 2/7 Case 2:25-bk-18374-BR 8/25/26, 11:44 AM Doc 214 Filed 10/27/26 Byron Z. Moldo: Entered Ervin Cohen 10/27/26 16:15:01 & Jessup LLP Desc Main Document Page 46 of 84 Super Lawyers: Southern California Super Lawyers, 2009-2026 Community & Professional GGI Geneva Group International, Global Chairperson, Debt Collection, Restructuring and Insolvency Practice Group National Association of Federal Equity Receivers (NAFER), Full Member; Chairperson-Membership Committee California Bankruptcy Forum, Los Angeles/Orange County Chapter California Receiver’s Forum State Bar of California, Business Law Section, Legislation Subcommittee, Chair State Bar of California, Business Law Section, Insolvency Law Committee Los Angeles Bankruptcy Forum Beverly Hills Bar Association Westwood Bar Association, Former President Southern California Bankruptcy Inns of Court, Founding Member Client Alerts 35 Ervin Cohen & Jessup Attorneys Named As 2027 "Best Lawyers In America" Best Lawyers, 08.20.2026 https://www.ecjlaw.com/professionals-byron-z-moldo#Overview 3/7 Case 2:25-bk-18374-BR 8/25/26, 11:44 AM Doc 214 Filed 10/27/26 Byron Z. Moldo: Entered Ervin Cohen 10/27/26 16:15:01 & Jessup LLP Desc Main Document Page 47 of 84 Byron Moldo Joins Andy Serbe on Legal Lens to Discuss Retail Bankruptcies ION Analytics, 08.27.2025 34 Ervin Cohen & Jessup Attorneys Named "Best Lawyers In America" 08.21.2025 Two Ervin Cohen & Jessup Partners Named 'Leading Global Bankruptcy Lawyers' 07.07.2025 Partner Byron Moldo Quoted In The Los Angeles Times Los Angeles Times, 07.07.2022 Partner Byron Moldo Quoted in the Guardian on the Mega- Mansion "The One" 03.04.2022 Partner Byron Moldo Quoted In The Los Angeles Times Los Angeles Times, 03.01.2022 Byron Moldo Featured By MoneyGeek Discussing Paying Off Debt in Collections MoneyGeek, 03.2021 Partner Byron Moldo Discusses the Financial Fallout of the Pandemic in the LA Business Journal's Bankruptcy Roundtable Los Angeles Business Journal, 07.29.2020 ECJ Partner Byron Moldo Quoted In The Southern California Record Southern California Record , 04.15.2020 Two Ervin Cohen & Jessup Partners Selected to Geneva Group International Leadership 11.14.2018 ECJ's Byron Moldo Weighs In on Bankruptcy of Large Beverly Hills Media Company https://www.ecjlaw.com/professionals-byron-z-moldo#Overview 4/7 Case 2:25-bk-18374-BR 8/25/26, 11:44 AM Doc 214 Filed 10/27/26 Byron Z. Moldo: Entered Ervin Cohen 10/27/26 16:15:01 & Jessup LLP Desc Main Document Page 48 of 84 08.06.2015 Blog Posts Coronavirus Advice for Creditors ECJ Blogs, 03.23.2020 Publications Subchapter V of the US Bankruptcy Code GGI Global Alliance’s Debt Collection, Restructuring & Insolvency News, 06.12.2020 Substantive Consolidation, its Application, and the Authority 10.11.2019 When Breaking Up Is Hard, Call A Partition Referee 05.24.2016 Relativity Bankruptcy Auction: Speed Is an Issue Contributing Member, Variety, 08.2015 An Interview: Judge Dean Pregerson Receivership News, Summer 2015 Speaking Engagements Raising the White Flag: Why Consider Abandoning Bankruptcy to an Alternative Choice California Bankruptcy Forum, Webinar, 05.14.2021 GGI Debt Collection, Restructuring & Insolvency Webinar Geneva Group International, Live Webcast, 12.01.2020 "Ask the Receiver" CRF Loyola VIII Symposium, Renaissance Hotel, Newport Beach, 01.24.2020 https://www.ecjlaw.com/professionals-byron-z-moldo#Overview 5/7 Case 2:25-bk-18374-BR 8/25/26, 11:44 AM Doc 214 Filed 10/27/26 Byron Z. Moldo: Entered Ervin Cohen 10/27/26 16:15:01 & Jessup LLP Desc Main Document Page 49 of 84 Can That Be Included Too? Expanding the Scope of the Receivership. National Association of Federal Equity Receivers, Scottsdale, AZ, 10.18.2019 Substantive Consolidation GGI’s Best Practices & Marketing Professionals Conference, Wichita, Kansas, 09.19.2019 Practice Tips and Issues at the Intersection of Litigation and Bankruptcy/Receivership Matters GGI Pan-American Regional Conference, Houston, TX, 06.2019 Health & Safety Receiverships: Legal Breakthroughs and Lessons from the Trenches California Receivers Forum, Costa Mesa, CA, 06.2019 Money, Money, Money: Tax, Insurance, Expenses and Reporting National Association of Federal Equity Receivers, Washington, D.C., 10.13.2016 Locating and Recovering Hidden or Concealed Assets PFAC Conference, Indian Wells, CA, 06.2016 Sales Free and Clear for Business and Realty – Does it Matter What Type of Property? Loyola VI Receivership Symposium, Irvine, CA, Jan. 2015 Growing Your Real Estate Brokerage Business By Expanding Into New Markets CCIM (Certified Commercial Investment Member), Los Angeles, CA, 05.2013 Real Estate Receiverships CEB, Los Angeles, CA, 09.2012 Byron Moldo Named Leading Bankruptcy Lawyer 06.20.2024 https://www.ecjlaw.com/professionals-byron-z-moldo#Overview 6/7 Case 2:25-bk-18374-BR 8/25/26, 11:44 AM Doc 214 Filed 10/27/26 Byron Z. Moldo: Entered Ervin Cohen 10/27/26 16:15:01 & Jessup LLP Desc Main Document Page 50 of 84 Fifteen Ervin Cohen and Jessup Attorneys Named to 2024 Super Lawyers Lists 01.15.2024 Ten Ervin Cohen & Jessup Attorney Named "Best Lawyers In America" And Two Named "Ones To Watch" 09.01.2023 Eighteen Ervin Cohen & Jessup Attorneys Recognized in 2024 Edition of Best Lawyers in America & Best Lawyers: Ones To Watch 08.18.2023 ECJ Partners Randall Leff and Byron Moldo Named "Legal Visionaries" by the Los Angeles Times 07.06.2022 Partner Byron Moldo Named a Global Chairperson with Geneva Group International 09.30.2021 Ervin Cohen & Jessup Named Receiverships Law Firm of the Year 06.09.2015 https://www.ecjlaw.com/professionals-byron-z-moldo#Overview 7/7 Case 2:25-bk-18374-BR 10/15/26, 1:56 PM Doc 214 Filed 10/27/26 Jared Slater: Entered Ervin Cohen & 10/27/26 16:15:01 Jessup LLP Desc Main Document Page 51 of 84 Cookie Main Main Settings Content Menu Jared W. Slater Partner jslater@ecjlaw.com Direct 310. 281.6330 Jared W. Slater is a Partner in ECJ's Litigation and Employment Education Departments. J.D., University of Southern California, Gould School of Jared's practice focuses on defending labor and employment Law actions, including claims for wage and hour violations, B.A., University of California, harassment, and discrimination both in the individual and class Los Angeles, Psychology action arenas. He also devotes a significant portion of his practice to defending professionals whose former clients bring Practice Areas claims against them. Litigation and Alternative Dispute Resolution Employment https://www.ecjlaw.com/professionals-jared-w-slater 1/15 Case 2:25-bk-18374-BR 10/15/26, 1:56 PM Doc 214 Filed 10/27/26 Jared Slater: Entered Ervin Cohen & 10/27/26 16:15:01 Jessup LLP Desc Main Document Page 52 of 84 Prior to joining ECJ, Jared obtained complete defense verdicts at Admissions trial and favorable results on dispositive motions and in mediations. In doing so, his clients have lauded him for his California personal approach to each of their cases. Jared has also gained substantial trial experience defending legal malpractice, employment and personal injury actions. Honors & Recognitions Super Lawyers: Southern California Rising Stars, 2025 JD Supra Readers' Choice Top Author, 2025, 2026 Best Lawyers: Ones to Watch, Recognized since 2026 Leaders of Influence: Labor & Employment Attorneys, Los Angeles Business Journal, 2025 Client Alerts Three Ervin Cohen & Jessup Partners Top Lawdragon’s 2027 “Leading Corporate Employment Lawyers” List Lawdragon, 10.14.2026 Two Ervin Cohen & Jessup Partners Named to Los Angeles Business Journal’s 2026 Leading Employment Attorneys List Los Angeles Business Journal, 09.15.2026 Jared Slater quoted in Bloomberg Law's Daily Labor Report - Google’s Spirit Air AI Data Bid Reveals Worker Protection Void Bloomberg Law - Daily Labor Report, 09.15.2026 35 Ervin Cohen & Jessup Attorneys Named As 2027 "Best Lawyers In America" Best Lawyers, 08.20.2026 https://www.ecjlaw.com/professionals-jared-w-slater 2/15 Case 2:25-bk-18374-BR 10/15/26, 1:56 PM Doc 214 Filed 10/27/26 Jared Slater: Entered Ervin Cohen & 10/27/26 16:15:01 Jessup LLP Desc Main Document Page 53 of 84 Jared Slater Discusses the Strategic Calculus Behind Harassment Settlements Variety, 02.12.2026 Jared Slater quoted in Law360 '4 Tips For Employers When Layoffs Can't Be Avoided' Law360, 11.07.2025 Two Ervin Cohen & Jessup Partners Named Top Employment Attorneys By Los Angeles Business Journal 09.09.2025 34 Ervin Cohen & Jessup Attorneys Named "Best Lawyers In America" 08.21.2025 Jared Slater quoted in Law360 'New Jersey Litigation Highlights For The 1st Half Of 2025' Law360, 08.08.2025 Client Alert: ECJ’s Employment Department Launches Employer Audit Compliance Service 03.25.2025 Jared Slater quoted in Modern Healthcare 'How healthcare systems are navigating Trump's anti-DEI push' Modern Healthcare, 03.25.2025 Jared Slater Authored an Article in the Daily Journal Titled “Planes, Trains, and Automobiles in the Modern Arbitration World." Daily Journal, 02.26.2024 Blog Posts One Motion, One Chance: A Second Motion to Compel Arbitration May Be Deemed a “Renewed Motion” | By: Jared W. Slater https://www.ecjlaw.com/professionals-jared-w-slater 3/15 Case 2:25-bk-18374-BR 10/15/26, 1:56 PM Doc 214 Filed 10/27/26 Jared Slater: Entered Ervin Cohen & 10/27/26 16:15:01 Jessup LLP Desc Main Document Page 54 of 84 Employment Law Reporter, 10.15.2026 Ninth Circuit Permits EFAA Election After Arbitration Has Commenced | By: Jared W. Slater The Staff Report, 09.23.2026 An Arbitration Clause Specific to an Employment Agreement Might Not Apply to Common Employment Claims | By Jared W. Slater Employment Law Reporter, 09.21.2026 EFAA Uncertainty Does Not Excuse a Delayed Motion to Compel Arbitration | By: Jared W. Slater The Staff Report, 09.16.2026 Signed the Same Day, Read Together: The Mutuality Problem Hiding in Onboarding Documents | By: Jared W. Slater The Staff Report, 09.01.2026 In re Orr and New State Law Mandate a New Approach for Enforcing Arbitration Agreements | By Jared W. Slater The Staff Report, 08.13.2026 Client Alert: ICE Expands the List of I-9 Errors That Carry Immediate Fines | By: Jared W. Slater The Staff Report, 08.11.2026 Sexual Orientation Harassment Can Trigger Federal Arbitration Exemption | By: Jared W. Slater The Staff Report, 08.05.2026 Ninth Circuit Confirms Employment-Specific Arbitration Language Survives Cook | By: Jared W. Slater The Staff Report, 07.28.2026 California Broadens the FAA’s Transportation-Worker Exemption for Delivery Drivers | By: Jared W. Slater Employment Law Reporter, 07.23.2026 https://www.ecjlaw.com/professionals-jared-w-slater 4/15 Case 2:25-bk-18374-BR 10/15/26, 1:56 PM Doc 214 Filed 10/27/26 Jared Slater: Entered Ervin Cohen & 10/27/26 16:15:01 Jessup LLP Desc Main Document Page 55 of 84 Governor Newsom Signs Executive Order Regarding Growing AI Trend in Employment | By: Jared W. Slater The Staff Report, 06.17.2026 Whose Agreement Is It Anyway? Court of Appeal Rejects Employer’s Attempt to Invoke Staffing Agency Arbitration Provisions By: Jared W. Slater The Staff Report, 05.26.2026 “All” Means All: The Court of Appeal’s Latest Warning on Overbroad Arbitration Agreements | By: Jared W. Slater The Staff Report, 05.11.2026 Inconsistencies Among Contemporaneous Arbitration Agreements May Not Be Fatal to Enforcement | By Jared W. Slater Employment Law Reporter, 04.30.2026 Ninth Circuit Upholds Arbitration Delegation Clause Despite Contrary Severability Language | By: Jared W. Slater The Staff Report, 04.08.2026 From Cook to Ayala‑Ventura: Drawing the Line on “Infinite” Arbitration Clauses | By: Jared W. Slater Employment Law Reporter, 03.26.2026 Employers Use Arbitration Awards to Preclude Private Attorneys General Act Claims | By: Jared W. Slater The Staff Report, 03.10.2026 Tiny Fonts, Narrow Holding: California Clarifies When Fine Print Matters | By: Jared W. Slater Employment Law Reporter, 02.25.2026 California Court Upholds Federal Arbitration Act Election in Employment Arbitration Agreements | By: Jared W. Slater The Staff Report, 02.17.2026 The Risk of Boilerplate PAGA Waivers in Employment Arbitration Agreements | By: Jared W. Slater The Staff Report, 02.11.2026 https://www.ecjlaw.com/professionals-jared-w-slater 5/15 Case 2:25-bk-18374-BR 10/15/26, 1:56 PM Doc 214 Filed 10/27/26 Jared Slater: Entered Ervin Cohen & 10/27/26 16:15:01 Jessup LLP Desc Main Document Page 56 of 84 Employment Arbitration Agreement Rollout During Class Action Backfires in Federal Court Case | By: Jared W. Slater Employment Law Reporter, 02.02.2026 Why Collateral Terms in Your Non-Disclosure Agreement May - or May Not - Tank Your Arbitration Policy | By: Jared W. Slater Employment Law Reporter, 01.29.2026 PAGA Standing Remains a Matter for the Courts Even After Arbitration | By: Jared W. Slater The Staff Report, 01.22.2026 Understanding the Broad Reach of the EFAA in California | By: Jared W. Slater Employment Law Reporter, 01.20.2026 Playing the Long Game: How an Employer's Litigation Strategy Waived the Right to Arbitration | By: Jared W. Slater The Staff Report, 01.15.2026 Warning: Your Sister Company Might Be Your Joint Employer Liability Partner | By: Jared W. Slater The Staff Report, 12.18.2025 SB 446 and California’s New Thirty-Day Data Breach Countdown | By: Jared W. Slater The Staff Report, 12.09.2025 New Enforcement Law Requires Review of Tip Handling | By: Jared W. Slater The Staff Report, 11.25.2025 New Law Increases Employer Exposure to FEHA Litigation | By: Jared W. Slater The Staff Report, 11.19.2025 The High Price of Delay: California's SB 261 and the Triple Penalty | By: Jared W. Slater, Esq. The Staff Report, 11.06.2025 https://www.ecjlaw.com/professionals-jared-w-slater 6/15 Case 2:25-bk-18374-BR 10/15/26, 1:56 PM Doc 214 Filed 10/27/26 Jared Slater: Entered Ervin Cohen & 10/27/26 16:15:01 Jessup LLP Desc Main Document Page 57 of 84 The “Net Effect” Rule That Can Sink Arbitration Agreements | By: Jared W. Slater Employment Law Reporter, 10.28.2025 The Hidden Cost of Fine Print: A Warning to Employers Drafting Arbitration Agreements | By: Jared W. Slater The Staff Report, 10.22.2025 Another Crucial Win for Employers re: Untimely Arbitration Fee Payments | By: Jared W. Slater Employment Law Reporter, 10.16.2025 Client Alert: California's Civil Rights Council Approves New Regulations On AI In Employment | By: Jared W. Slater Legal Bites, The Staff Report, 09.22.2025 Employers May Now Obtain Equitable Relief for Untimely Arbitration Payments | By: Jared W. Slater Employment Law Reporter, The Staff Report, 08.20.2025 California Appellate Courts Split on “Headless” PAGA Standing: CRST Expedited Permits Broad Claims, While Leeper Awaits Review | By: Jared W. Slater The Staff Report, 08.05.2025 A New Era for Workplace Surveillance? | By: Jared W. Slater Employment Law Reporter, 07.29.2025 Assembly Bill 1018: A Bill for Employers to Keep an (A)Eye On | By: Jared W. Slater The Staff Report, 07.22.2025 Surprise! Misleading Statements and Time Pressure May Render an Employer’s Arbitration Agreement Unenforceable | By: Jared W. Slater The Staff Report, 07.15.2025 Contemporaneous Onboarding Documents May Invalidate An Employer’s “Squeaky Clean” Arbitration Agreement | By: Jared W. Slater https://www.ecjlaw.com/professionals-jared-w-slater 7/15 Case 2:25-bk-18374-BR 10/15/26, 1:56 PM Doc 214 Filed 10/27/26 Jared Slater: Entered Ervin Cohen & 10/27/26 16:15:01 Jessup LLP Desc Main Document Page 58 of 84 The Staff Report, 07.08.2025 Employers Beware: Lessons from Sanders v. Superior Court of Los Angeles County | By: Tanner Hosfield and Jared W. Slater The Staff Report, 06.10.2025 The Importance of Having an Up-To-Date Employment Arbitration Agreement | By: Jared W. Slater Legal Bites, The Staff Report, 05.13.2025 To Sever or Not to Sever, That is the Question For Courts Reviewing Employment Arbitration Agreements for Enforceability | By: Jared W. Slater The Staff Report, 04.08.2025 Another Day, Another Dispute Between Appellate Courts Over Employment Arbitrations | By: Jared W. Slater The Staff Report, 04.01.2025 The Importance of Compliance Audits Under the Amended Private Attorneys General Act | By: Jared W. Slater The Staff Report, 03.19.2025 An Attorney’s Inadvertence, Mistake, or Excusable Neglect Is Not Sufficient to Overcome The Bright-Line Rule for Arbitration Fee Payments | By: Jared W. Slater The Staff Report, 03.18.2025 Sexual Harassment Claims Preclude Arbitration Even if the Federal Arbitration Act is Not Explicitly Invoked in an Arbitration Agreement | By: Jared W. Slater Legal Bites, The Staff Report, 03.11.2025 Court of Appeal Harmonizes Enforcement of Abritration Agreements with Arbitrator's Authorty | By: Jared W. Slater The Staff Report, 03.06.2025 Arbitration Fee Payment Statute Does Not Apply To Post-Dispute Arbitration Agreements | By: Jared W. Slater The Staff Report, 02.26.2025 https://www.ecjlaw.com/professionals-jared-w-slater 8/15 Case 2:25-bk-18374-BR 10/15/26, 1:56 PM Doc 214 Filed 10/27/26 Jared Slater: Entered Ervin Cohen & 10/27/26 16:15:01 Jessup LLP Desc Main Document Page 59 of 84 Every PAGA Action Has An Individual Component Which May Be Subject To Arbitration | By: Jared W. Slater Legal Bites, The Staff Report, 02.19.2025 Equitable Estoppel Can Be Invoked By a Non-Signatory Joint Employer to Compel Arbitration | By: Jared W. Slater The Staff Report, 02.11.2025 Los Angeles and San Diego Counties Enact Fair Chance Ordinances for Unincorporated Areas | By: Jared W. Slater The Staff Report, 01.02.2025 Single Sexual Harassment Claim Eliminates Arbitration of All Employment-Related Claims in the Same Case | By: Jared W. Slater The Staff Report, 12.30.2024 Stricter Controls Over Wage Statement Penalty Awards Are a Gift For Some | By: Jared W. Slater The Staff Report, 12.27.2024 “Prejudice” No Longer an Element to Determine Waiver of Right to Compel Arbitration | By: Jared W. Slater The Staff Report, 12.19.2024 Entertainment Vendors Must Certify Safety Training for Employees By: Jared W. Slater The Staff Report, 12.05.2024 California Employers Prohibited from Mandatory Religious or Political Meetings | By: Jared W. Slater The Staff Report, 12.04.2024 Severing Unconscionable Terms in Employment Arbitration Agreements | By: Jared W. Slater The Staff Report, 08.27.2024 Overbroad Employment Arbitration Agreements Will Not Be Enforced in California | By: Jared W. Slater The Staff Report, 08.13.2024 https://www.ecjlaw.com/professionals-jared-w-slater 9/15 Case 2:25-bk-18374-BR 10/15/26, 1:56 PM Doc 214 Filed 10/27/26 Jared Slater: Entered Ervin Cohen & 10/27/26 16:15:01 Jessup LLP Desc Main Document Page 60 of 84 The Battle for Supremacy: Federal Arbitration Act v. California Arbitration Act | By: Jared W. Slater The Staff Report, Legal Bites, 07.30.2024 Another Blow to E-Signed Arbitration Agreements in California By: Jared W. Slater The Staff Report, Legal Bites, 07.23.2024 Workplace Violence Prevention Plans and Trainings Must be Implemented by July 1 | By: Jared Slater The Staff Report, 06.26.2024 Employer Alert: Workplace Violence Prevention Plans for California Employers Must be Established by July 1, 2024 Legal Bites, The Staff Report, 05.02.2024 Previous Arbitration Agreements Are Potentially Unenforceable Against Re-Hired Employees Legal Bites, The Staff Report, 04.25.2024 When Does a “Dispute” Arise Under the Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act? The Staff Report, 02.27.2024 California Court of Appeals Reinforces Strict Limits on Arbitration Fee Payment Deadline The Staff Report, 02.20.2024 Trial Courts Do Not Have Authority to Dismiss PAGA Claims for Lack of Manageability The Staff Report, 02.13.2024 Happy Valentine’s Day! A Reminder that Employers Must Notify Employees of Void Non-Compete Clauses and Agreements by February 14, 2024 The Staff Report, 02.05.2024 California Expands Protections for Employee Conduct The Staff Report, 11.28.2023 https://www.ecjlaw.com/professionals-jared-w-slater 10/15 Case 2:25-bk-18374-BR 10/15/26, 1:56 PM Doc 214 Filed 10/27/26 Jared Slater: Entered Ervin Cohen & 10/27/26 16:15:01 Jessup LLP Desc Main Document Page 61 of 84 Appealing A Petition to Compel Arbitration Ruling No Longer Automatically Stays Superior Court Proceedings The Staff Report, 11.27.2023 California Enacts Additional Restrictions on Employer Noncompete Agreements Legal Bites, The Staff Report, 11.07.2023 California Increases Paid Sick Leave for Employees The Staff Report, 10.23.2023 ­California Opens its Doors to Commerce by Voiding Out-Of-State Non-Compete Agreements Legal Bites, The Staff Report, 10.04.2023 California Supreme Court Rules that PAGA Claims May Be Pursued in Court Despite Arbitration Agreement The Staff Report, 08.01.2023 California Court of Appeals Holds that Joint Employers Must Sign Arbitration Agreement The Staff Report, 04.24.2023 Court Rules Outside Salesperson Exemption Turns on Employer Control The Staff Report, 04.04.2023 California Court of Appeals Rules that Proposition 22 is Constitutional…Mostly…For Now The Staff Report, 03.15.2023 NLRB Declares Confidentiality and Non-Disparagement Provisions in Severance Agreements Unlawful Legal Bites, The Staff Report, 02.24.2023 Arbitration Agreements Can Be A Condition of Employment Once Again Legal Bites, The Staff Report, 02.17.2023 https://www.ecjlaw.com/professionals-jared-w-slater 11/15 Case 2:25-bk-18374-BR 10/15/26, 1:56 PM Doc 214 Filed 10/27/26 Jared Slater: Entered Ervin Cohen & 10/27/26 16:15:01 Jessup LLP Desc Main Document Page 62 of 84 California Will Create a Pilot Program Recognizing Businesses That Create Safe and Welcoming Environments Legal Bites, The Staff Report, 12.12.2022 Employers Beware: SB 1044 Creates a Right to Refuse to Work in Emergency Conditions Legal Bites, The Staff Report, 12.07.2022 When Substantial Compliance Is Not Enough: A Cautionary Ruling For Employment Arbitration Actions Legal Bites, The Staff Report, 11.22.2022 California Court of Appeals Provides Guidance on Wage Order Seating Requirements The Staff Report, 08.31.2022 Update: Challenge to California’s Arbitration Agreement Law Marches On Legal Bites, The Staff Report, 08.29.2022 Another Minimum Wage Increase? There’s a Referendum for That The Staff Report, 08.22.2022 United States Supreme Court Overrules Ban on PAGA Arbitrations Legal Bites, The Staff Report, 06.21.2022 California’s Supreme Court Declares Meal and Rest Period Premiums are “Wages” The Staff Report, Legal Bites, 06.01.2022 Supreme Court Hears Oral Argument on Arbitrability of California's Private Attorneys’ General Act Under Federal Arbitration Act The Staff Report, 04.01.2022 Supreme Court Upholds Vaccine Mandate for Medicare and Medicaid-Certified Providers and Suppliers The Staff Report, 01.20.2022 https://www.ecjlaw.com/professionals-jared-w-slater 12/15 Case 2:25-bk-18374-BR 10/15/26, 1:56 PM Doc 214 Filed 10/27/26 Jared Slater: Entered Ervin Cohen & 10/27/26 16:15:01 Jessup LLP Desc Main Document Page 63 of 84 United States Supreme Court Imposes Stay on OSHA Vaccine Mandate The Staff Report, 01.13.2022 Los Angeles County Tightens Mask Mandates for Employers The Staff Report, 01.07.2022 Mandatory Arbitration Agreements in California: Down, But Possibly Not Out The Staff Report, 12.27.2021 Recent Private Attorneys General Act Reform Efforts The Staff Report, 12.22.2021 New Private Attorneys General Act Developments The Staff Report, 12.15.2021 Following COVID-19 Related Guidance Just Became Easier for Employers The Staff Report, 12.14.2021 Senate Bill 762: Another Tall Hurdle for Employers Seeking Arbitration The Staff Report, 12.13.2021 Changes To Statutory Covid-19 Exposure Notice and Reporting Requirements Legal Bites, 11.18.2021 SB 639: The Hidden Cost of Phasing Out Certificate Programs for Workers With Disabilities The Staff Report, Legal Bites, 11.15.2021 New Law Enhances Labor Commissioner’s Ability to Lien Employer Real Property The Staff Report, 11.11.2021 Mandatory Arbitration Agreements are Unenforceable in California, Again The Staff Report, 09.17.2021 https://www.ecjlaw.com/professionals-jared-w-slater 13/15 Case 2:25-bk-18374-BR 10/15/26, 1:56 PM Doc 214 Filed 10/27/26 Jared Slater: Entered Ervin Cohen & 10/27/26 16:15:01 Jessup LLP Desc Main Document Page 64 of 84 Publications Daily Journal - "Planes, Trains, and Automobiles in the Modern Arbitration World." | By: Jared Slater Daily Journal, 03.07.2024 State of Employment Arbitrations: 2023 Edition | By: Jared W. Slater Employment Law Reporter, 12.05.2023 California’s Supreme Court Declares Meal and Rest Period Premiums are “Wages” Employment Law Reporter, Ervin Cohen & Jessup LLP, 06.01.2022 United States Supreme Court Imposes Stay on OSHA Vaccine Mandate: What Does it Mean for Restaurants? Modern Restaurant Management, 01.14.2022 California’s Independent Contractor Statute is Not Preempted by Federal Law Employment Law Reporter, Ervin Cohen & Jessup LLP, 12.07.2021 Meal and Rest Break Claims for California Drivers Engaged in Interstate Commerce Remain Preempted by Federal Law Employment Law Reporter, Ervin Cohen & Jessup LLP, 12.03.2021 Changes To Statutory Covid-19 Exposure Notice and Reporting Requirements Employment Law Reporter, Ervin Cohen & Jessup LLP, 11.18.2021 California Supreme Court Declines to Reverse Restriction on Criminal Background Checks Employment Law Reporter, Ervin Cohen & Jessup LLP, 10.05.2021 California Supreme Court Issues Retroactive Decision on Calculating Meal and Rest Break Premium Pay Employment Law Reporter, Ervin Cohen & Jessup LLP, 07.19.2021 https://www.ecjlaw.com/professionals-jared-w-slater 14/15 Case 2:25-bk-18374-BR 10/15/26, 1:56 PM Doc 214 Filed 10/27/26 Jared Slater: Entered Ervin Cohen & 10/27/26 16:15:01 Jessup LLP Desc Main Document Page 65 of 84 Proposed Legislation Likely to Create Problems for California Employers Employment Law Reporter, Ervin Cohen & Jessup LLP, 06.10.2021 California Supreme Court Signals the End for Rounding Meal Break Time Employment Law Reporter, Ervin Cohen & Jessup LLP, 05.10.2021 What Employers Need to Know About the $15.00 Federal Contractor Minimum Wage Employment Law Reporter, Ervin Cohen & Jessup LLP, 04.30.2021 Can Dr. Jekyll Sign for Mr. Hyde?: Examining The Rights of Individuals Suffering From Dissociative Identity Disorder In Civil Contexts 24 S. Cal. Rev. L. & Soc. Just. 239, 2015 Speaking Engagements 2025 New Laws Seminar Hybrid: In person & Zoom, 01.22.2025 Understanding Employment Contracts UCLA Radiology Fellows Career Symposium, 10.09.2021 https://www.ecjlaw.com/professionals-jared-w-slater 15/15 Case 2:25-bk-18374-BR 10/15/26, 1:57 PM Doc 214 Filed 10/27/26 Chase A. Stone: Entered Ervin Cohen 10/27/26 16:15:01 & Jessup LLP Desc Main Document Page 66 of 84 Cookie Main Main Settings Content Menu Chase A. Stone Senior Associate cstone@ecjlaw.com Direct 310.281.6369 Chase A. Stone is a Senior Associate in the Receivership, Education Bankruptcy, and Creditors' Rights Department at Ervin LL.M, UCLA School of Law, Cohen & Jessup LLP in Beverly Hills, California. Business Bankruptcy J.D., UC Davis School of His practice covers all aspects of insolvency, including Law bankruptcy, receiverships, out-of-court workouts, and M.S., University of assignments for the benefit of creditors (ABCs). He advises Michigan clients across industries such as retail and real estate, as well B.A., Oberlin College, with Honors https://www.ecjlaw.com/professionals-chase-a-stone 1/4 Case 2:25-bk-18374-BR 10/15/26, 1:57 PM Doc 214 Filed 10/27/26 Chase A. Stone: Entered Ervin Cohen 10/27/26 16:15:01 & Jessup LLP Desc Main Document Page 67 of 84 as mid-sized businesses, individuals, and court-appointed Practice Areas fiduciaries throughout Southern California. Receivership, Bankruptcy, Chase serves as a partition referee, appointed by California and Creditors’ Rights Services courts to sell real property owned by tenants in common. He also represents court-appointed receivers and other fiduciaries in partition actions and receivership proceedings, Admissions including equity, Health and Safety Code, and rents and California profits receiverships. His work involves shareholder and U.S. District Court partnership disputes, fraud or mismanagement cases, U.S. District Court, Central corporate insolvency, and managing distressed real estate District of California portfolios. U.S. District Court, Eastern District of California Chase has extensive experience representing secured and unsecured creditors in bankruptcy proceedings, including U.S. District Court, Northern District of California individual Chapter 11 debtors, claim recovery, post- judgment collections, lease assumption and assignment U.S. District Court, disputes, and adversary litigation such as Southern District of California nondischargeability and preference actions. Chase is Co-Chair of the California Lawyers Association’s Insolvency Law Committee. Prior to joining ECJ, Chase served as a judicial law clerk for the Honorable Ronald A. Clifford III and the Honorable Victoria S. Kaufman in the U.S. Bankruptcy Court for the Central District of California. In re Core Scientific, Inc. (U.S. Bankruptcy Court for the Southern District of Texas) (Case No. 22-90341) – Represented claimants with over $22 million in combined claims to successfully resolving dispute with the debtor regarding calculation of claims. https://www.ecjlaw.com/professionals-chase-a-stone 2/4 Case 2:25-bk-18374-BR 10/15/26, 1:57 PM Doc 214 Filed 10/27/26 Chase A. Stone: Entered Ervin Cohen 10/27/26 16:15:01 & Jessup LLP Desc Main Document Page 68 of 84 Celsius Network LLC, et al. (U.S. Bankruptcy Court for the Southern District of New York) (Case No. 22-10964) – Obtained favorable outcome under section 503(b)(3)(D) for award of substantial contribution over objections, including from the Office of the United States Trustee, and assisted in negotiations of plan support agreement. U.S. Bankruptcy Court for the Central District of California – Successfully negotiated settlement on behalf of individual Chapter 11 debtor, reducing prepetition judgment of $18 million by nearly half and resolving longstanding dispute in favor of the debtor. U.S. Bankruptcy Court for the Northern District of California/Santa Clara Superior Court – Assisted in representation of court-appointed receiver in claims brought against receiver personally by bankruptcy trustee, reducing liability to $0. Honors & Recognitions Super Lawyers: Southern California Rising Stars, 2025, 2026 Best Lawyers: Ones to Watch, Recognized since 2026 Community & Professional California Lawyers Association, Insolvency Law Committee Co-Chair 2026-2027 https://www.ecjlaw.com/professionals-chase-a-stone 3/4 Case 2:25-bk-18374-BR 10/15/26, 1:57 PM Doc 214 Filed 10/27/26 Chase A. Stone: Entered Ervin Cohen 10/27/26 16:15:01 & Jessup LLP Desc Main Document Page 69 of 84 Official Liaison of the Insolvency Law Committee/Business Law Section to the California Commission on Uniform State Laws (CCUSL) (Model ABC Act) Los Angeles Bankruptcy Forum California Lawyers Association, Business Law Section, Insolvency Law Committee Member 2024 - 2027 Client Alerts 35 Ervin Cohen & Jessup Attorneys Named As 2027 "Best Lawyers In America" Best Lawyers, 08.20.2026 Chase A. Stone Explores Quasi-Judicial Immunity for State Court Receivers California Lawyers Association, 05.19.2026 34 Ervin Cohen & Jessup Attorneys Named "Best Lawyers In America" 08.21.2025 Publications In re Serta Simmons Bedding, 125 F.4th 555 (5th Cir. 2024) | Case Summary & Author’s Comment By: Chase A. Stone California Lawyers Assocation, 04.15.2025 JJD-HOV Elk Grove, LLC v. Jo-Ann Stores, LLC | Case Summary By: Chase A. Stone California Lawyers Association, 02.18.2025 https://www.ecjlaw.com/professionals-chase-a-stone 4/4 Case 2:25-bk-18374-BR 10/15/26, 1:57 PM Doc 214 Filed 10/27/26 Danielle Gabai: Entered Ervin Cohen 10/27/26 16:15:01 & Jessup LLP Desc Main Document Page 70 of 84 Cookie Main Main Settings Content Menu Danielle R. Gabai Associate dgabai@ecjlaw.com Direct 310.281.6359 Danielle is an Associate in the Receivership, Bankruptcy, and Education Creditors' Rights Department. Her experience includes J.D., USC Gould School of representing receivers in state court, as well as trustees, Law individual and corporate creditors, debtors, and transferees B.A., Business in bankruptcy proceedings under Chapters 7 and 11 Administration With a (including Subchapter V) of the Bankruptcy Code. Danielle Specialization in Finance, IDC Interdisciplinary also has experience in Assignments for the Benefit of Center Creditors. https://www.ecjlaw.com/professionals-113 1/2 Case 2:25-bk-18374-BR 10/15/26, 1:57 PM Doc 214 Filed 10/27/26 Danielle Gabai: Entered Ervin Cohen 10/27/26 16:15:01 & Jessup LLP Desc Main Document Page 71 of 84 Danielle earned her Juris Doctor from the University of Practice Areas Southern California Gould School of Law in 2021, where she also obtained a Business Law Certificate. During law school, Receivership, Bankruptcy, and Creditors’ Rights she served as President of the Jewish Law Student Services Association and Outreach Chair of the Healthcare Law Society. She holds a Bachelor of Arts in Business Administration with a specialization in Finance from IDC Interdisciplinary Center in Herzliya, Israel. Honors & Recognitions Best Lawyers: Ones to Watch, Recognized since 2026 Client Alerts 35 Ervin Cohen & Jessup Attorneys Named As 2027 "Best Lawyers In America" Best Lawyers, 08.20.2026 34 Ervin Cohen & Jessup Attorneys Named "Best Lawyers In America" 08.21.2025 https://www.ecjlaw.com/professionals-113 2/2 Case 2:25-bk-18374-BR 8/25/26, 11:44 AM Doc 214 Filed 10/27/26 Shantal Malmed: Entered Ervin Cohen 10/27/26 16:15:01 & Jessup LLP Desc Main Document Page 72 of 84 Cookie Main Main Settings Content Menu Shantal Malmed Associate smalmed@ecjlaw.com Direct 310.281.6314 Shantal Malmed is an Associate in ECJ’s Receivership, Education Bankruptcy, and Creditors’ Rights Services Department. Her J.D., University of practice focuses on complex insolvency and fiduciary Southern California, matters, including receiverships, bankruptcy litigation, and Gould School of Law asset recovery. Shantal brings experience representing B.A., University of trustees in Chapter 7 and Chapter 11 proceedings, handling California, Los Angeles adversary actions, settlements, and court-approved asset sales in the real estate, finance, healthcare, aviation, food and restaurants, wholesale distribution, retail, ecommerce, https://www.ecjlaw.com/professionals-130 1/3 Case 2:25-bk-18374-BR 8/25/26, 11:44 AM Doc 214 Filed 10/27/26 Shantal Malmed: Entered Ervin Cohen 10/27/26 16:15:01 & Jessup LLP Desc Main Document Page 73 of 84 and energy industries. Notably, Shantal represented a Practice Areas chapter 11 trustee for a large hospital in successfully obtaining $1 million in voluminous preference action Receivership, Bankruptcy, and Creditors’ Rights lawsuits. Shantal also represented a chapter 7 trustee for an Services insolvent aviation company in the sale of property that created a completely solvent estate. Shantal currently serves as Vice Chair of the Beverly Hills Bar Association, Bankruptcy Section. She earned her Juris Doctor from the University of Southern California Gould School of Law and holds a Bachelor of Arts, summa cum laude, from UCLA. During law school, she served as Treasurer of the Jewish Law Student Association and Academic Chair of the Women’s Law Society. Honors & Recognitions TMA SoCal Chapter, Member, Present Los Angeles Bankruptcy Forum, Member, 2023-Present Community & Professional Beverly Hills Bar Association, Bankruptcy Section - Vice Chair, May 2024 – Present - Secretary, May 2023 – May 2024 https://www.ecjlaw.com/professionals-130 2/3 Case 2:25-bk-18374-BR 8/25/26, 11:44 AM Doc 214 Filed 10/27/26 Shantal Malmed: Entered Ervin Cohen 10/27/26 16:15:01 & Jessup LLP Desc Main Document Page 74 of 84 Blog Posts Senate Passes Bill to Permanently Raise Subchapter V Debt Ceiling – What It Means for Small Businesses | By: Shantal Malmed 08.19.2026 Speaking Engagements Bridging Careers & Culture: Insights from Tech, Law, Media and Beyond | Panelist University of Southern California, 11.13.2024 https://www.ecjlaw.com/professionals-130 3/3 Case 2:25-bk-18374-BR Doc 214 Filed 10/27/26 Entered 10/27/26 16:15:01 Desc Main Document Page 75 of 84 Dylan Allen Associate dallen@ecjlaw.com Direct 310.281.6356 Dylan is an Associate in the Receivership, Bankruptcy, and Creditors’ Rights Education Department. He represents receivers in state court, as well as trustees, J.D., University of Minnesota Law individual and corporate creditors, debtors, and transferees in bankruptcy School proceedings under Chapters 7 and 11 of the Bankruptcy Code. B.S., University of Southern California During law school, Dylan gained experience through the University of Minnesota Law School’s Bankruptcy Clinic, where he represented clients in Practice Areas personal bankruptcy proceedings. Before law school, he worked in the Receivership, Bankruptcy, and financial services industry, where he negotiated financial partnerships and Creditors’ Rights Services supported commercial lending and underwriting initiatives. Dylan earned his J.D. from the University of Minnesota Law School, where he was a member of the Jewish Law Student Association. He received his B.A. in Law, History, and Culture from the University of Southern California. Beach Cities, 841 Apollo St., Suite 450, El Segundo, CA 90245 | T 310.545.0010 | www.ecjlaw.com Case 2:25-bk-18374-BR Doc 214 Filed 10/27/26 Entered 10/27/26 16:15:01 Desc Main Document Page 76 of 84 Tanner Hosfield Associate thosfield@ecjlaw.com Direct 310.281.6315 Tanner is an Associate in ECJ's Litigation and Employment Departments. His Education practice focuses on defending labor and employment actions, including both J.D., University of California, Los individual and class action cases. Tanner represents employers in a wide Angeles range of employment matters, including claims for harassment, B.S., University of California, discrimination, retaliation, wrongful termination, and wage and hour Davis, Biology disputes. He also assists with the development of employee handbooks, policies, and procedures. Tanner began his legal career with an AmLaw 200 law firm specializing in labor and employment defense. Tanner also has experience representing employees at a plaintiff’s side employment firm while in law school, which provided him unique insights that assist his strategic approach for defending employers. During his time in law school, he also served as a Managing Editor for the UCLA Law Review. Blog Posts The Workplace Know Your Rights Act Adds a New Notice Requirement and Creates an Emergency Contact Option Related to Arrests and Detentions During Work Hours | By: Tanner Hosfield The Staff Report, 12.04.2025 California’s 2025 Expansion of Employee Leave Rights: What Employers Need to Know About AB 406 and SB 590 | By: Tanner Hosfield The Staff Report, 12.02.2025 California’s SB 513: Expanded Personnel File Requirements Create New Obligations for Employers | By: Tanner Hosfield The Staff Report, 12.01.2025 Beach Cities, 841 Apollo St., Suite 450, El Segundo, CA 90245 | T 310.545.0010 | www.ecjlaw.com Case 2:25-bk-18374-BR Doc 214 Filed 10/27/26 Entered 10/27/26 16:15:01 Desc Main Document Page 77 of 84 Tanner Hosfield California Supreme Court Defines “Reasonable Effort” That is Required for a Good-Faith Defense to a Claim for Unpaid Wages | By: Tanner Hosfield Employment Law Reporter, 11.20.2025 Reminder: New Notice Required Regarding Expansion of Accommodations and Leave Requirements for Victims | By: Tanner Hosfield The Staff Report, 09.24.2025 Employers Beware: Lessons from Sanders v. Superior Court of Los Angeles County | By: Tanner Hosfield and Jared W. Slater The Staff Report, 06.10.2025 California Court of Appeal Decision in Rose v. Hobby Lobby: No Recovery of Costs Against Nonparticipating State Agency | By: Tanner Hosfield Employment Law Reporter, 06.03.2025 California Court Narrows “Death Knell” Appeal Rule: Key Takeaways for Employers | By: Tanner Hosfield Employment Law ReporterThe Staff Report, 05.28.2025 California Court of Appeal Rejects "Headless" PAGA Claims in Williams v. Alacrity Solutions Group | By: Tanner Hosfield The Staff Report, 05.20.2025 Good News for Employers: Court Upholds Prospective Meal Break Waivers for Short Shifts | By: Tanner Hosfield Legal BitesThe Staff Report, 05.06.2025 More PAGA Updates: LWDA Publishes FAQ; AB 1034 Extends Exemption for Construction Employees under CBA | By: Tanner Hosfield The Staff Report, 01.22.2025 New Law Prohibits Discrimination on the Basis of Possessing a Driver's License | By: Tanner Hosfield The Staff Report, 12.17.2024 New Law Mandates That Employees Can No Longer Be Required to Use Vacation Before Receiving Paid Family Leave Benefits | By: Tanner Hosfield The Staff Report, 12.12.2024 Changes to PAGA Create Opportunities for Employers to Minimize Penalties | By: Tanner Hosfield Employment Law Reporter, 08.20.2024 Beach Cities, 841 Apollo St., Suite 450, El Segundo, CA 90245 | T 310.545.0010 | www.ecjlaw.com Case 2:25-bk-18374-BR Doc 214 Filed 10/27/26 Entered 10/27/26 16:15:01 Desc Main Document Page 78 of 84 PROOF OF SERVICE OF DOCUMENT I am over the age of 18 and not a party to this bankruptcy case or adversary proceeding. My business address is: ERVIN COHEN & JESSUP LLP 9401 Wilshire Boulevard, Twelfth Floor Beverly Hills, California 90212-2974 A true and correct copy of the foregoing document entitled (specify): FIRST AND FINAL APPLICATION FOR COMPENSATION AND REIMBURSEMENT OF FEES AND EXPENSES INCURRED BETWEEN SEPTEMBER 22, 2025 AND OCTOBER 23, 2026 BY ERVIN COHEN & JESSUP LLP AS GENERAL BANKRUPTCY COUNSEL TO CHAPTER 11 DEBTOR AND DEBTOR-IN-POSSESSION; DECLARATION OF BYRON Z. MOLDO IN SUPPORT THEREOF will be served or was served (a) on the judge in chambers in the form and manner required by LBR 5005-2(d); and (b) in the manner stated below: 1. TO BE SERVED BY THE COURT VIA NOTICE OF ELECTRONIC FILING (NEF): Pursuant to controlling General Orders and LBR, the foregoing document will be served by the court via NEF and hyperlink to the document. On (date) October 27, 2026, I checked the CM/ECF docket for this bankruptcy case or adversary proceeding and determined that the following persons are on the Electronic Mail Notice List to receive NEF transmission at the email addresses stated below: Ismail Amin on behalf of Creditor Newtek Bank, N.A. iamin@talglaw.com, pgilmore@talglaw.com; kvescera@talglaw.com; shalberstadt@talglaw.com; cstark@talglaw.com; ckim@talglaw.com; eavakian@talglaw.com; knarh@talglaw.com; kmeade@talglaw.com; kanderson@talglaw.com Christopher Beyer on behalf of Creditor North Star Leasing, a Division of Peoples Bank cab@replevin.com, ecf@writofseizure.com Michael D Breslauer on behalf of Interested Party Courtesy NEF mbreslauer@swsslaw.com, sdurazo@swsslaw.com Steve Burnell on behalf of Trustee David M Goodrich (TR) Steve.Burnell@gmlaw.com, sburnell@ecf.courtdrive.com;sburnell@ecf.inforuptcy.com;patricia.dillamar@gmlaw.com;courtmail@gmlaw.c om Richard P Cook on behalf of Attorney Richard P Cook richard@capefeardebtrelief.com Caroline Djang on behalf of Defendant CIS International Distributors Inc. cdjang@buchalter.com, docket@buchalter.com;lverstegen@buchalter.com Caroline Djang on behalf of Defendant Lionsrock Investments LLC cdjang@buchalter.com, docket@buchalter.com;lverstegen@buchalter.com Caroline Djang on behalf of Defendant Lionsrock Wisconsin LLC cdjang@buchalter.com, docket@buchalter.com;lverstegen@buchalter.com This form is mandatory. It has been approved for use by the United States Bankruptcy Court for the Central District of California. June 2012 F 9013-3.1.PROOF.SERVICE Case 2:25-bk-18374-BR Doc 214 Filed 10/27/26 Entered 10/27/26 16:15:01 Desc Main Document Page 79 of 84 Caroline Djang on behalf of Defendant Live Aquaria Holdings Corp. cdjang@buchalter.com, docket@buchalter.com;lverstegen@buchalter.com Caroline Djang on behalf of Defendant Siam Tropical Fish Ltd. cdjang@buchalter.com, docket@buchalter.com;lverstegen@buchalter.com Caroline Djang on behalf of Defendant T3 Aquatics cdjang@buchalter.com, docket@buchalter.com;lverstegen@buchalter.com Caroline Djang on behalf of Defendant Tropical Quarium Fish (FIJI) Ltd cdjang@buchalter.com, docket@buchalter.com;lverstegen@buchalter.com Caroline Djang on behalf of Defendant Charitha I. Samarasinghe cdjang@buchalter.com, docket@buchalter.com;lverstegen@buchalter.com Caroline Djang on behalf of Interested Party CIS International Distributors Inc. cdjang@buchalter.com, docket@buchalter.com;lverstegen@buchalter.com Caroline Djang on behalf of Interested Party Charitha I. Samarasinghe cdjang@buchalter.com, docket@buchalter.com;lverstegen@buchalter.com Caroline Djang on behalf of Interested Party Lionsrock Investments LLC cdjang@buchalter.com, docket@buchalter.com;lverstegen@buchalter.com Caroline Djang on behalf of Interested Party Lionsrock Wisconsin LLC cdjang@buchalter.com, docket@buchalter.com;lverstegen@buchalter.com Caroline Djang on behalf of Interested Party Live Aquaria Holdings Corp. cdjang@buchalter.com, docket@buchalter.com;lverstegen@buchalter.com Caroline Djang on behalf of Interested Party Siam Tropical Fish Ltd. cdjang@buchalter.com, docket@buchalter.com;lverstegen@buchalter.com Caroline Djang on behalf of Interested Party T3 Aquatics cdjang@buchalter.com, docket@buchalter.com;lverstegen@buchalter.com Caroline Djang on behalf of Interested Party Tropical Aquarium Fish (FIJI) Ltd cdjang@buchalter.com, docket@buchalter.com;lverstegen@buchalter.com Caroline Djang on behalf of Plaintiff CIS International Distributors Inc. cdjang@buchalter.com, docket@buchalter.com;lverstegen@buchalter.com Caroline Djang on behalf of Plaintiff Charitha I. Samarasinghe cdjang@buchalter.com, docket@buchalter.com;lverstegen@buchalter.com Caroline Djang on behalf of Plaintiff Lionsrock Investments LLC cdjang@buchalter.com, docket@buchalter.com;lverstegen@buchalter.com This form is mandatory. It has been approved for use by the United States Bankruptcy Court for the Central District of California. June 2012 F 9013-3.1.PROOF.SERVICE Case 2:25-bk-18374-BR Doc 214 Filed 10/27/26 Entered 10/27/26 16:15:01 Desc Main Document Page 80 of 84 Caroline Djang on behalf of Plaintiff Lionsrock Wisconsin LLC cdjang@buchalter.com, docket@buchalter.com;lverstegen@buchalter.com Caroline Djang on behalf of Plaintiff Live Aquaria Holdings Corp. cdjang@buchalter.com, docket@buchalter.com;lverstegen@buchalter.com Caroline Djang on behalf of Plaintiff Siam Tropical Fish Ltd. cdjang@buchalter.com, docket@buchalter.com;lverstegen@buchalter.com Caroline Djang on behalf of Plaintiff T3 Aquatics cdjang@buchalter.com, docket@buchalter.com;lverstegen@buchalter.com Caroline Djang on behalf of Plaintiff Tropical Aquarium Fish (FIJI) Ltd cdjang@buchalter.com, docket@buchalter.com;lverstegen@buchalter.com Dennis A Dressler on behalf of Creditor Tokyo Century (USA) Inc. ddressler@dresslerpeters.com James R Felton on behalf of Creditor Signature Staff Resources, LLC jfelton@gblawllp.com, ystotland@gblawllp.com;msingleman@gblawllp.com Angela Gill on behalf of Creditor Tokyo Century (USA) Inc. agill@hrhlaw.com, caseview.ecf@usdoj.gov;usacac.tax@usdoj.gov David M Goodrich (TR) dgoodrich@go2.law, c143@ecfcbis.com;dgoodrich11@ecf.axosfs.com;lrobles@go2.law Michael Jones on behalf of U.S. Trustee United States Trustee (LA) michael.jones4@usdoj.gov Raffi Khatchadourian on behalf of Creditor Tokyo Century (USA) Inc. raffi@hemar-rousso.com Raffi Khatchadourian on behalf of Interested Party Courtesy NEF raffi@hemar-rousso.com Ron Maroko on behalf of U.S. Trustee United States Trustee (LA) ron.maroko@usdoj.gov Byron Z Moldo on behalf of Debtor CIS International Holdings (N.A.) Corporation bmoldo@ecjlaw.com, aantonio@ecjlaw.com,dperez@ecjlaw.com,scarson@ecjlaw.com Christopher S Murphy on behalf of Creditor Texas Comptroller of Public Accounts, Revenue Accounting Division bk-cmurphy@oag.texas.gov This form is mandatory. It has been approved for use by the United States Bankruptcy Court for the Central District of California. June 2012 F 9013-3.1.PROOF.SERVICE Case 2:25-bk-18374-BR Doc 214 Filed 10/27/26 Entered 10/27/26 16:15:01 Desc Main Document Page 81 of 84 Scott Olson on behalf of Creditor Settle Funding, LLC solson@seyfarth.com, chidocket@seyfarth.com Kurt Ramlo on behalf of Interested Party Courtesy NEF RamloLegal@gmail.com, kr@ecf.courtdrive.com;ramlo@recap.email Kurt Ramlo on behalf of Plaintiff Panthers Capital LLC RamloLegal@gmail.com, kr@ecf.courtdrive.com;ramlo@recap.email Patrick J Schurr on behalf of Creditor Signature Staff Resources, LLC patrick.schurr@solidcounsel.com Amitkumar Sharma on behalf of Creditor Ford Motor Credit Company LLC, c/o AIS Portfolio Services, LLC amit.sharma@aisinfo.com Chase Aleksander Stone on behalf of Debtor CIS International Holdings (N.A.) Corporation cstone@ecjlaw.com, aantonio@ecjlaw.com,dperez@ecjlaw.com,scarson@ecjlaw.com United States Trustee (LA) ustpregion16.la.ecf@usdoj.gov Cranston J Williams on behalf of Creditor Southern California Gas Company cwilliams3@socalgas.com Jennifer C Wong on behalf of Creditor Ford Motor Credit Company LLC bknotice@mccarthyholthus.com, jwong@ecf.courtdrive.com Jennifer C Wong on behalf of Interested Party Courtesy NEF bknotice@mccarthyholthus.com, jwong@ecf.courtdrive.com Service information continued on attached page 2. SERVED BY UNITED STATES MAIL: On (date) October 27, 2026, I served the following persons and/or entities at the last known addresses in this bankruptcy case or adversary proceeding by placing a true and correct copy thereof in a sealed envelope in the United States mail, first class, postage prepaid, and addressed as follows. Listing the judge here constitutes a declaration that mailing to the judge will be completed no later than 24 hours after the document is filed. [PLEASE SEE SERVICE LIST ATTACHED] Service information continued on attached page 3. SERVED BY PERSONAL DELIVERY, OVERNIGHT MAIL, FACSIMILE TRANSMISSION OR EMAIL (state method for each person or entity served): Pursuant to F.R.Civ.P. 5 and/or controlling LBR, on (date) October 27, 2026, I served the following persons and/or entities by personal delivery, overnight mail service, or (for those who consented in writing to such service method), by facsimile transmission and/or email as follows. Listing the judge here constitutes a declaration This form is mandatory. It has been approved for use by the United States Bankruptcy Court for the Central District of California. June 2012 F 9013-3.1.PROOF.SERVICE Case 2:25-bk-18374-BR Doc 214 Filed 10/27/26 Entered 10/27/26 16:15:01 Desc Main Document Page 82 of 84 that personal delivery on, or overnight mail to, the judge will be completed no later than 24 hours after the document is filed. Honorable Barry Russell United States Bankruptcy Court Central District of California Edward R. Roybal Federal Building and Courthouse 255 E. Temple Street, Suite 1660 / Courtroom 1668 Los Angeles, CA 90012 Service information continued on attached page I declare under penalty of perjury under the laws of the United States that the foregoing is true and correct. October 27, 2026 Sydney Carson /s/ Sydney Carson Date Printed Name Signature This form is mandatory. It has been approved for use by the United States Bankruptcy Court for the Central District of California. June 2012 F 9013-3.1.PROOF.SERVICE Case 2:25-bk-18374-BR Doc 214 Filed 10/27/26 Entered 10/27/26 16:15:01 Desc Main Document Page 83 of 84 In re CIS International Holdings (N.A.) Corporation, Debtor. Case No 2:25-bk-13874-BR United States Bankruptcy Court, Central District of California, Los Angeles Division SERVICE LIST DEBTOR UNITED STATES TRUSTEE CIS International Holdings (N.A.) Office of the United States Trustee Corporation dba eTropical Fish 915 Wilshire Blvd #1850 1405 W. 178th Street Los Angeles, CA 90017 Gardena, CA 90248 20 LARGEST CREDITORS American Packaging Capital, Inc. California Employee Develop. Dept. PO Box 77077 PO Box 826218 Minneapolis, MN 55480-7777 Sacramento, CA 94230-6218 CV Sematik Perkasa Indonesia D.B. Group America, Ltd. JL Setiawarg a 2351 US Route 130 2I3BB RT 002, RW 004 Jatiranggon Dayton, NJ 08810 Jatisampurna, Kota Bekasi INDONESIA Fleet Global Logistics Ford Motor Credit 19 Srinakarin Rd. (4th Floor) Bangna, Bangnha PO Box 537901 Nuea Livonia, MI 48153-7901 Bangkok, THAILAND 10260 Guangzhou Quick Production Co. A20 of Room Launch Funding Group LLC 1001 No. 621 1250 E. Hallandale Beach Bl. #505 Tianhe Rd., Tianhe District Hallandale, FL 33009 Guang Zhou, Guangzhou, CHINA Lincoln Benefit Life Company Newtek Bank, N.A. P.O. Box 4322 1111 Brickell Ave Suite 135 Carol Stream, IL 60197 Miami, FL 33131 North Star Leasing Division Shorr Packaging of Peoples Bank Los Angeles Branch P.O. Box 4505 1100 Eliwanda Ave Burlington, VT 05406-4505 Ontario, CA 91760-8658 Signature Staff Resources LLC Southern California Edison Company 1460 TL Townsend Dr. # 104 P.O. Box 300 Rockwall, TX 75032 Rosemead, CA 91770 Teknowledge Shared Services Ltd. U.S. Small Business Administration 27/6A Park Lane Office of General Counsel Rajagiriya, SRI LANKA 312 No. Spring Street, 5th Floor Los Angeles, CA 90012 18899.1:11675073.1 Case 2:25-bk-18374-BR Doc 214 Filed 10/27/26 Entered 10/27/26 16:15:01 Desc Main Document Page 84 of 84 UPS Victory Packaging Executive Financial Enterprises 3550 E. Francis Street, Suite 200 PO Box 894820 Ontario, CA 91761 Los Angeles, CA 90189-4820 Western Overnight LLC 16 Corporate Woods Blvd., Ste. 1 Albany, NY 12211 18899.1:11675073.1