michael gerard fletcher (state bar no. 070849) frandzel … · 2021. 1. 11. · michael gerard...

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4045014.3 | 078410-0061 1 Case No. 5:18-cv-02104-SJO-PLA

NOTICE OF FIFTH APPLICATION AND FIFTH APPLICATION FOR ORDER APPROVING AND AUTHORIZING PAYMENT OF RECEIVER’S AND RECEIVER’S COUNSEL’S FEES AND EXPENSES, ETC.

Michael Gerard Fletcher (State Bar No. 070849) [email protected] Craig A. Welin (State Bar No. 138418) [email protected] Hal D. Goldflam (State Bar No. 179689) [email protected] FRANDZEL ROBINS BLOOM & CSATO, L.C. 1000 Wilshire Boulevard, Nineteenth Floor Los Angeles, California 90017-2427 Telephone: (323) 852-1000 Facsimile: (323) 651-2577

Attorneys for Receiver ROBB EVANS AND ASSOCIATES LLC

UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

WESTERN DIVISION

FEDERAL TRADE COMMISSION,

Plaintiff,

v.

JASON CARDIFF, etc., et al.,

Defendants.

Case No. 5:18-cv-02104-DMG-PLA

NOTICE OF FIFTH APPLICATION AND FIFTH APPLICATION FOR ORDER APPROVING AND AUTHORIZING PAYMENT OF RECEIVER’S AND RECEIVER’S COUNSEL’S FEES AND EXPENSES FOR THE PERIOD FROM JULY 1, 2020 THROUGH OCTOBER 31, 2020; MEMORANDUM OF POINTS AND AUTHORITIES

[Fifth Fee Application; Local Rule 66-7(f)]

Date: February 5, 2021 Time: 9:30 a.m. Place: Courtroom 8C, 350 West 1st St. Judge: Hon. Dolly M. Gee

Case 5:18-cv-02104-DMG-PLA Document 537 Filed 01/08/21 of 17 Page ID#:30526

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4045014.3 | 078410-0061 2 Case No. 5:18-cv-02104-SJO-PLA


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TO: THE HONORABLE DOLLY M. GEE, UNITED STATES DISTRICT

JUDGE, THE PARTIES TO THIS ACTION, AND TO ALL KNOWN

CREDITORS AND OTHER PARTIES IN INTEREST:

PLEASE TAKE NOTICE that on February 5, 2021, at 9:30 a.m., or as soon

thereafter as the parties may be heard in Courtroom 8C of the above-entitled court

located at 350 West 1st Street, 8th Floor, Los Angeles, California 90012, Robb

Evans & Associates LLC, as Receiver of Redwood Scientific Technologies, Inc.

(California), Redwood Scientific Technologies, Inc. (Nevada), Redwood Scientific

Technologies, Inc. (Delaware), Identify, LLC, Advance Men’s Institute Prolongz

LLC, Run Away Productions, LLC, Carols Place Limited Partnership, and each of

their subsidiaries, affiliates, successors, and assigns, and of assets of Jason Cardiff

and Eunjung Cardiff (collectively, the “Receivership Defendants”), and as Receiver

of as Receiver of VPL Medical, Inc., will and hereby does apply to the Court for an

order approving the payment of the fees and expenses of the Receiver, the

Receiver’s staff, and the Receiver’s outside counsel, Frandzel Robins Bloom &

Csato, L.C., for the period from July 1, 2020 through October 31, 2020 (“Fifth

Reporting Period”). During the Fifth Reporting Period (a) the fees and costs of the

Receiver and its staff totaled $160,032.79 (consisting of $156,166.20 in fees and

$3,866.59 in costs), and (b) the fees and costs of FRBC totaled $348,969.76

(consisting of $344,648.50 in fees and $4,321.26 in costs), for a total of

$509,002.55.

PLEASE TAKE FURTHER NOTICE that this Application is made pursuant

to Local Rule 66-7(f) and in accordance with the Court’s preliminary injunctions

issued in this action, namely Preliminary Injunction with Asset Freeze, Receiver,

and Other Equitable Relief against Jason Cardiff and Eunjung Cardiff [Doc. No. 59,

filed on November 8, 2018], which requires the Receiver to file with the Court and

serve on the parties periodic requests for the payment of reasonable compensation

for the Receiver’s and the Receiver’s hired personnel, including counsel to the


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4045014.3 | 078410-0061 3 Case No. 5:18-cv-02104-SJO-PLA


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Receiver, and for actual out-of-pocket expenses incurred by them.

Further, to the extent L.R. 7-3 applies to this Application, please see the

discussion in the concurrently filed Declaration of Michael Gerard Fletcher

regarding the Receiver’s compliance with this local rule.

This Application is based upon this Notice and the attached Memorandum of

Points and Authorities; the concurrently filed Declarations of Brick Kane and

Michael Gerard Fletcher and Exhibits thereto; upon the pleadings, records and files

of this case of which the Receiver requests the Court take judicial notice, and upon

all other further pleadings, oral and documentary evidence and argument of counsel

as may be presented by the Receiver at or before the time of the hearing on this

Application.

PLEASE TAKE FURTHER NOTICE that a copy of this Application and

supporting declarations and exhibits are posted on the Receiver’s website at

https://www.robbevans.com/find-a-case/redwood-scientific-technologies-inc-et-al/

where they may be reviewed in their entirety. This Application, the attached

Memorandum of Points and Authorities, and the concurrently filed declarations and

exhibits are being served on all parties herein. While a copy of this Application and

the attached Memorandum of Points and Authorities is being served on all known

creditors and interested parties (see attached Creditors Service List), these third-

parties may obtain copies of the supporting declarations and exhibits by accessing

the Receiver’s website or by sending a written request to: Robb Evans & Associates

LLC, 11450 Sheldon Street, Sun Valley, California 91352-1121; Telephone (818)

768-8100; Facsimile: (818) 768-8802.


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Dated: January 8, 2021 FRANDZEL ROBINS BLOOM & CSATO, L.C.MICHAEL GERARD FLETCHER CRAIG A. WELIN HAL D. GOLDFLAM

By: /s/ Michael Gerard Fletcher

MICHAEL GERARD FLETCHER Attorneys for Receiver ROBB EVANS & ASSOCIATES LLC


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4045014.3 | 078410-0061 5 Case No. 5:18-cv-02104-SJO-PLA


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MEMORANDUM OF POINTS AND AUTHORITIES

I. CHRONOLOGICAL FACTS THROUGH OCTOBER 31, 2020

1. On October 10, 2018, the Federal Trade Commission (“FTC”) initiated

this action alleging violations of the Federal Trade Commission Act, 15 U.S.C. §

45(a), among other alleged violations of federal laws and regulations.

2. On October 10, 2018, the Court issued its Ex Parte Temporary

Restraining Order with Asset Freeze, Appointment of a Temporary Receiver, and

Other Equitable Relief, and Order to Show Cause Why a Preliminary Injunction

Should Not Issue (“Temporary Restraining Order”), whereby the Court appointed

Robb Evans & Associates LLC (“REA”) the Temporary Receiver of the

Receivership Entities and of the assets of Jason Cardiff and Eunjung Cardiff as more

particularized therein. [Doc. No. 1.]

3. On October 24, 2018, the Court entered its Preliminary Injunction with

Asset Freeze, Receiver, and Other Equitable Relief Against Redwood Scientific

Technologies, Inc. (CA), etc. Appointment of a Receiver, and Other Equitable

Relief, whereby the Court ordered that Robb Evans & Associates LLC shall

continue to serve as the Receiver of the Receivership Entities with full powers of an

equity receiver. [Doc. No. 46.]

4. On October 24, 2018, the Court entered its Order Extending Temporary

Restraining Order and Granting Continuance of Preliminary Injunction Hearing for

Defendant Danielle Cadiz. [Doc. No. 47.]



Defendants Jason Cardiff and Eunjung Cardiff and Ordering them to Return Assets.

[Doc. No. 48.]

6. On November 1, 2018, the Receiver filed its Report of Activities for

the period from October 10, 2018 through October 31, 2018 (“First Report of

Activities”). [Doc. No. 52; see also Doc. 53 Notice of Errata – whereby a readable


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4045014.3 | 078410-0061 6 Case No. 5:18-cv-02104-SJO-PLA


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copy of page 9 of the First Report of Activities was filed.]

7. On November 7, 2018, the Court entered its Stipulated Preliminary

Injunction as to Defendant Danielle Cadiz, whereby the Court ordered that Robb

Evans & Associates LLC shall continue to serve as the Receiver of the Receivership

Entities with full powers of an equity receiver [Doc. No. 55.]

8. On November 8, 2018, the Court entered its Preliminary Injunction

with Asset Freeze, Receiver, and Other Equitable Relief Against Jason Cardiff and

Eunjung Cardiff (“Preliminary Injunction”), whereby the Court ordered that Robb


Entities and of the Assets of Defendants Jason Cardiff and Eunjung Cardiff, as more

particularized therein, with full powers of an equity receiver. [Doc. No. 59.]

9. Pursuant to Section XXII of the Preliminary Injunction, the Court

ordered that:

“the Receiver and all personnel hired by the Receiver as

herein authorized, including counsel to the Receiver and

accountants, are entitled to reasonable compensation for

the performance of duties pursuant to this Order and for

the cost of actual out-of-pocket expenses incurred by

them, from the assets now held by, or in the possession or

control of, or which may be received by the Receivership

Defendants. The Receiver shall file with the Court and

serve on the parties periodic requests for the payment of

such reasonable compensation, with the first such request

filed no more than sixty (60) days after the date of this

Order.”

10. On September 27, 2019, the Court entered an Order Approving and

Authorizing Payment of the Receiver’s and Its Counsel’s Fees and Expenses for the

Period from Inception of the Receivership Estate through November 30, 2018


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4045014.3 | 078410-0061 7 Case No. 5:18-cv-02104-SJO-PLA


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(“First Fee Application”). [Doc. 223.]

11. On September 27, 2019, the Court entered its Order Approving and


Period from December 1, 2018 through June 30, 2019 (“Second Fee Application”).

[Doc. 224.]

12. On March 10, 2020, the Court entered its Order Approving Settlement

Between Receiver and Third-Party Inter/Media Time Buying Corporation. [Doc.

306.]

13. March 10, 2020, the entered its Order Authorizing the Receiver to Sell,

Subject to the Court’s Final Confirmation, Defendants Cardiffs’ Residence Located

at 700 West 25th Street, Upland, California. [Doc. 306, 309 (formal order).]

14. On March 10, 2020, the Court entered its Order Approving and


Period from July 1, 2019 through September 30, 2019 (“Third Fee Application”).

[Doc. 307.]

15. On June 24, 2020, the Court entered its Temporary Restraining Order

With Asset Freeze and Other Equitable Relief and Order to Show Cause Why A

Preliminary Injunction Should Not Issue Under Seal and In Camera temporarily

appointing the Receiver over VPL Medical, Inc., which the Court extended for the

duration of this case by entering its Preliminary Injunction with Asset Freeze and

Receiver on July 7, 2020 [Doc. 389], giving the Receiver the powers of an equity

receiver as to VPL (collectively, the “VPL Preliminary Injunction”).

15. On June 29, 2020, the Receiver filed the Report of Receiver’s

Immediate Access to the Premises of VPL Medical, Inc (“Initial VPL Report”).

[Doc. 365.]

16. On July 6, 2020, the Receiver file its Supplemental Report Regarding

VPL Medical, Inc., Jason Cardiff, and Materially Altered Bank Account Statements

(“Supplemental VPL Report”). [Doc. 380.]


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4045014.3 | 078410-0061 8 Case No. 5:18-cv-02104-SJO-PLA


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17. On August 31, 2020, the Receiver filed the Declaration of Brick Kane

including the Receiver’s Report of VPL Medical, Inc. Conducting Operations Going

Forward dated August 18, 2020, attached as Exhibit 1 to the Declaration (“August

18, 2020 VPL Report”). (Filed under seal [Doc. 472] pursuant to the Court’s Order

entered on August 29, 2020 [Doc. 470]). In addition to the ongoing operational

expenses in the VPL Cash Flow Projections included with the August 18, 2020 VPL

Report is a weekly reserve for the Receiver’s fees and costs, including the

Receiver’s counsel. The parties stipulated to the Court approving the August 18,

2020 VPL Report, including the Cash Flow Projections, and for the Court to instruct

the Receiver to conduct VPL operations going forward in accordance therewith

[Doc. 467-1]. On August 29, 2020, the Court entered its Order approving the

August 18, 2020 Report including the VPL Cash Flow Projections, and instructed

the Receiver to conduct VPL Operations going forward in accordance with the VPL

Cash Flow Projections. [Doc. 470.]

18. On October 1, 2020, the Receiver filed its VPL Operating Report.

[Doc. 503] pursuant to the Court’s September 9, 2020, Order [Doc. 486] directing

the Receiver to “provide updates on VPL’s business, operations, income/expenses,

and earnings projections”, among other things, every 60 days (“October 1, 2020

VPL Report”).

19. On October 13, 2020, the Court entered its Order Re Receiver’s Fourth

Application for Fees and Expenses granting the Receiver’s Fourth Fee Application

and authorizing payment of the Receiver’s and its counsel’s fees and expenses the

Fourth Fee Period (October 1, 2019 through June 30, 2020) (“Fourth Fee

Application). [Doc. 514.]

20. By July 16, 2020, the Receiver filed a total of six Affidavits of Non-

Compliance with the TRO and Preliminary Injunction (October 23, 2018 [Doc.

206], July 2, 2019 [Doc. 144], August 22, 2019 [Docs. 200, 201], January 29, 2020

[Doc. 273], April 30, 2020 [Doc. 331], and July 16, 2020 [Doc. 442]).


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II. THE RECEIVER’S AND RECEIVER’S COUNSEL’S FEES,

EXPENSES, AND ACTIVITIES DURING THE FIFTH REPORTING

PERIOD

During the Fifth Reporting Period (July 1, 2020 through October 31, 2020),

the fees and costs of the Receiver, the Receiver’s deputies, and staff totaled

$160,032.79, consisting of $156,166.20 in fees and $3,866.59 in costs. The legal

fees and costs of the Receiver’s counsel, Frandzel Robins Bloom & Csato, L.C.

(“FRBC”), which the Receiver hired pursuant to the authority given to the Receiver

in the Court’s Temporary Restraining Order at § XVI.G., and the Preliminary

Injunction at § XVI.G., totaled 348,969.76, consisting of $344,648.50 in fees and

$4,321.26 in costs. Accordingly, the total of receivership fees and expenses

incurred during the Fifth Reporting Period which the Receiver seeks an order

authorizing payment is $509,002.55. (See Declaration of Brick Kane.)

The activities undertaken by the Receiver, the Receiver’s duties, and staff

during the Fifth Reporting Period are summarized the accompanying Declaration of

Brick Kane and are further detailed in the Receiver’s monthly billing summaries

reflecting the services rendered and time spent by the Receiver. (See Declaration of

Brick Kane and Exh. 2.) The activities described in the First Report of Activities, in

my declarations submitted in support of the Receiver’s Second Fee Application,

Third Fee Application, and Fourth Fee Application, the Initial VPL Report, the

Supplemental VPL Report, the August 31, 2020 VPL Report, and the October 1,

2020 VPL Report generally have continued during the Fifth Reporting Period in the

context of the Receiver’s efforts to identify, obtain, safeguard and preserve assets of

the receivership estate and otherwise to perform its duties and responsibilities under

the authority granted by the Temporary Restraining Order and Preliminary

Injunction, and the VPL Preliminary Injunction, generally have continued during the

Fifth Reporting Period in the context of the Receiver’s efforts to identify, obtain,

safeguard and preserve assets of the receivership estate and otherwise to perform its


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4045014.3 | 078410-0061 10 Case No. 5:18-cv-02104-SJO-PLA


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duties and responsibilities under the authority granted by the Temporary Restraining

Order, Preliminary Injunction, and VPL Preliminary Injunction. FRBC assisted the

Receiver during the Fifth Reporting Period in the manner summarized in the

concurrently filed Declaration of Michael Gerard Fletcher and FRBC’s activities are

further detailed in FRBC’s monthly billing summaries reflecting the services

rendered. (See Declaration of Michael Gerard Fletcher and Exh. 4.)

The Receiver respectfully submits that in light of the work performed during

the Fifth Reporting Period, the fees and costs of the Receiver and its professionals

are reasonable and should be approved and authorized for payment in their entirety.

III. CONCLUSION

Based on the foregoing and the concurrently filed Declarations of Brick Kane

and Michael Gerard Fletcher (and exhibits thereto), the Receiver respectfully

requests that the Court grant the Application and that it issue an order deeming that,

in light of the work performed during the Fifth Reporting Period, the fees and costs

of the Receiver and its professionals are reasonable and should be approved and

authorized for payment in their entirety.

Dated: January 8, 2021 FRANDZEL ROBINS BLOOM & CSATO, L.C.MICHAEL GERARD FLETCHER CRAIG A. WELIN HAL D. GOLDFLAM

By: /s/ Michael Gerard Fletcher

MICHAEL GERARD FLETCHER Attorneys for Receiver ROBB EVANS & ASSOCIATES LLC


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4062768.1 | 078410-0061 1 Case No. 5:18-cv-02104-SJO-PLA

DECLARATIONS OF BRICK KANE AND MICHAEL GERARD FLETCHER IN SUPPORT OF APPLICATION FOR ORDER APPROVING AND AUTHORIZING PAYMENT OF RECEIVER’S AND RECEIVER’S COUNSEL’S FEES, ETC.

Michael Gerard Fletcher (State Bar No. 070849) [email protected] Craig A. Welin (State Bar No. 138418) [email protected] Hal D. Goldflam (State Bar No. 179689) [email protected] FRANDZEL ROBINS BLOOM & CSATO, L.C. 1000 Wilshire Boulevard, Nineteenth Floor Los Angeles, California 90017-2427 Telephone: (323) 852-1000 Facsimile: (323) 651-2577

Attorneys for Receiver ROBB EVANS AND ASSOCIATES LLC

UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

WESTERN DIVISION

FEDERAL TRADE COMMISSION,

Plaintiff,

v.

JASON CARDIFF, etc., et al.,

Defendants.

Case No. 5:18-cv-02104-DMG-PLA

DECLARATIONS OF BRICK KANE AND MICHAEL GERARD FLETCHER IN SUPPORT OF APPLICATION FOR ORDER APPROVING AND AUTHORIZING PAYMENT OF RECEIVER’S AND RECEIVER’S COUNSEL’S FEES AND EXPENSES FOR THE PERIOD FROM JULY 1, 2020 THROUGH OCTOBER 31, 2020

[Fifth Fee Application; Local Rule 66-7(f)]

Date: February 5, 2021 Time: 9:30 a.m. Place: Courtroom 8C, 350 West 1st St. Judge: Hon. Dolly M. Gee

Case 5:18-cv-02104-DMG-PLA Document 537-1 Filed 01/08/21 Page 1 of 403 Page ID#:30543

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DECLARATION OF BRICK KANE

I, Brick Kane, declare as follows:

1. I am the President & Chief Operating Officer of Robb Evans &

Associates LLC (“REA”), initially the Temporary Receiver and subsequently the

Receiver in this matter. I have personal knowledge of the matters set forth in this

declaration and, if I were called upon to testify as to those matters, I could and

would competently testify thereto based upon my personal knowledge.

2. I am one of the individuals with REA that has primary responsibility

for the day-to-day supervision and management of the receivership estate in this

case since REA first began to act as the Temporary Receiver on October 10, 2018,

pursuant the its Ex Parte Temporary Restraining Order with Asset Freeze,

Appointment of a Temporary Receiver, and Other Equitable Relief, and Order to

Show Cause Why a Preliminary Injunction Should Not Issue (“Temporary

Restraining Order”).

3. On October 24, 2018, the Court entered its Preliminary Injunction with

Asset Freeze, Receiver, and Other Equitable Relief Against Redwood Scientific

Technologies, Inc. (CA), etc. Appointment of a Receiver, and Other Equitable

Relief, whereby the Court ordered that Robb Evans & Associates LLC shall

continue to serve as the Receiver of the Receivership Entities with full powers of an

equity receiver. [Doc. No. 46.]



Defendant Danielle Cadiz. [Doc. No. 47.]



Defendants Jason Cardiff and Eunjung Cardiff and Ordering them to Return Assets.

[Doc. No. 48.]

6. On November 1, 2018, the Receiver filed its Report of Activities for


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the period from October 10, 2018 through October 31, 2018 (“First Report of

Activities”). [Doc. No. 52; see also Doc. 53 Notice of Errata – whereby a readable

copy of page 9 of the First Report of Activities was filed.]

6. On November 7, 2018, the Court entered its Stipulated Preliminary

Injunction as to Defendant Danielle Cadiz, whereby the Court ordered that Robb


Entities with full powers of an equity receiver [Doc. No. 55.]

7. On November 8, 2018, the Court entered its Preliminary Injunction

with Asset Freeze, Receiver, and Other Equitable Relief Against Jason Cardiff and

Eunjung Cardiff (“Preliminary Injunction”), whereby the Court ordered that Robb


Entities and of the Assets of Defendants Jason Cardiff and Eunjung Cardiff, as more

particularized therein, with full powers of an equity receiver. [Doc. No. 59.]



Period from Inception of the Receivership Estate Through November 30, 2018.

[Doc. 223.]



Period from Inception of the Receivership Estate through November 30, 2018

(“First Fee Application”). [Doc. 223.]

10. On September 27, 2019, the Court entered its Order Approving and


Period from December 1, 2018 through June 30, 2019 (“Second Fee Application”).

[Doc. 224.]

11. On March 10, 2020, the Court entered its Order Approving Settlement

Between Receiver and Third-Party Inter/Media Time Buying Corporation

(“Inter/Media”). [Doc. 306.]


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12. March 10, 2020, the entered its Order Authorizing the Receiver to Sell,

Subject to the Court’s Final Confirmation, Defendants Cardiffs’ Residence Located

at 700 West 25th Street, Upland, California. [Doc. 306, 309 (formal order).]

13. On March 10, 2020, the Court entered its Order Approving and


Period from July 1, 2019 through September 30, 2019 (“Third Fee Application”).

[Doc. 307.]

14. On June 24, 2020, the Court entered its Temporary Restraining Order

With Asset Freeze and Other Equitable Relief and Order to Show Cause Why A

Preliminary Injunction Should Not Issue Under Seal and In Camera temporarily

appointing the Receiver over VPL Medical, Inc., which the Court extended for the

duration of this case by entering its Preliminary Injunction with Asset Freeze and

Receiver on July 7, 2020 [Doc. 389], giving the Receiver the powers of an equity

receiver as to VPL (collectively, the “VPL Preliminary Injunction”).

15. On June 29, 2020, the Receiver filed the Report of Receiver’s

Immediate Access to the Premises of VPL Medical, Inc (“Initial VPL Report”).

[Doc. 365.]

16. On July 6, 2020, the Receiver file its Supplemental Report Regarding

VPL Medical, Inc., Jason Cardiff, and Materially Altered Bank Account Statements

(“Supplemental VPL Report”). [Doc. 380.]

17. On August 31, 2020, the Receiver filed the Declaration of Brick Kane

including the Receiver’s Report of VPL Medical, Inc. Conducting Operations Going

Forward dated August 18, 2020, attached as Exhibit 1 to the Declaration (“August

18, 2020 VPL Report”). (Filed under seal [Doc. 472] pursuant to the Court’s Order

entered on August 29, 2020 [Doc. 470]). In addition to the ongoing operational

expenses in the VPL Cash Flow Projections included with the August 18, 2020 VPL

Report is a weekly reserve for the Receiver’s fees and costs, including the

Receiver’s counsel. The parties stipulated to the Court approving the August 18,


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2020 VPL Report, including the Cash Flow Projections, and for the Court to instruct

the Receiver to conduct VPL operations going forward in accordance therewith

[Doc. 467-1]. On August 29, 2020, the Court entered its Order approving the

August 18, 2020 Report including the VPL Cash Flow Projections, and instructed

the Receiver to conduct VPL Operations going forward in accordance with the VPL

Cash Flow Projections. [Doc. 470.]

18. On October 1, 2020, the Receiver filed its VPL Operating Report.

[Doc. 503] pursuant to the Court’s September 9, 2020, Order [Doc. 486] directing

the Receiver to “provide updates on VPL’s business, operations, income/expenses,

and earnings projections”, among other things, every 60 days (“October 1, 2020

VPL Report”).

19. On October 13, 2020, the Court entered its Order Re Receiver’s Fourth

Application for Fees and Expenses granting the Receiver’s Fourth Fee Application

and authorizing payment of the Receiver’s and its counsel’s fees and expenses the

Fourth Fee Period (October 1, 2019 through June 30, 2020) (“Fourth Fee

Application). [Doc. 514.]

20. By July 16, 2020, the Receiver filed a total of six Affidavits of Non-

Compliance with the TRO and Preliminary Injunction (October 23, 2018 [Doc.

206], July 2, 2019 [Doc. 144], August 22, 2019 [Docs. 200, 201], January 29, 2020

[Doc. 273], April 30, 2020 [Doc. 331], and July 16, 2020 [Doc. 442]).

Fees, Expenses, and Activities During the Fifth Reporting Period

21. During the Fifth Reporting Period (July 1, 2020 through October 31,

2020), the fees and costs of the Receiver, the Receiver’s deputies, and staff totaled

$160,032.79, consisting of $156,166.20 in fees and $3,866.59 in costs. The legal

fees and costs of the Receiver’s counsel, Frandzel Robins Bloom & Csato, L.C.

(“FRBC”), which the Receiver hired pursuant to the authority given to the Receiver

in the Court’s Temporary Restraining Order at § XVI.G., and the Preliminary

Injunction at § XVI.G., totaled 348,969.76, consisting of $344,648.50 in fees and


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$4,321.26 in costs. Accordingly, the total of receivership fees and expenses

incurred during the Fifth Reporting Period which the Receiver seeks an order

authorizing payment is $509,002.55.

22. The Receiver’s fees and costs for which approval is requested are

identified in the summary which the Receiver’s office has prepared and titled as

“Receivership Administrative Expense Report by Month and Fund Balance From

Inception (October 10, 2018) to October 31, 2020,” a true and correct copy of which

I attach hereto as Exhibit 1. The fees are further detailed Exhibit 2 hereto.

Specifically, Exhibit 2 is comprised of monthly billing summaries reflecting the

services rendered and time spent by REA’s members, accountants, staff, and support

staff during the Fifth Reporting Period (with the work descriptions redacted where

appropriate to preserve information protected from disclosure by the attorney-client

privilege or otherwise to protect the Receiver and the receivership estate from

inappropriate disclosures).

23. I am familiar with the methods and procedures used to create, record,

and maintain the Receiver’s billing records. The billing records attached hereto as

Exhibit 2 are prepared from computerized time records prepared contemporaneously

with the services rendered by each professional billing time to this matter. These

computerized records are prepared in the ordinary course of business by the

Receiver’s professionals who have a business duty to accurately record their time

spent and services rendered on the matters on which they perform work. The time

records are transferred into a computerized billing program which generates

monthly invoices. In my experience, the Receiver’s methods and procedures for

recording and accounting for time and services have proven to be reliable and

accurate.

24. The activities described in the First Report of Activities, in my

declarations submitted in support of the Receiver’s Second Fee Application, Third

Fee Application, and Fourth Fee Application, the Initial VPL Report, the


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Supplemental VPL Report, the August 31, 2020 VPL Report, and the October 1,

2020 VPL Report generally have continued during the Fifth Reporting Period in the

context of the Receiver’s efforts to identify, obtain, safeguard and preserve assets of

the receivership estate and otherwise to perform its duties and responsibilities under

the authority granted by the Temporary Restraining Order and Preliminary

Injunction, and the VPL Preliminary Injunction. Moreover, while the services

rendered and time spent by REA’s members, accountants, staff, and support staff

during the Fifth Reporting Period are summarized in the Receiver’s billing

summaries (Exhibit 2), such services included, without limitation: (a) regularly

communicating with the Receiver’s counsel on various legal and fact issues related

to the Receiver’s administration of the receivership estate, including asset

identification and recovery issues; (b) regularly communicating with the FTC’s

counsel regarding receivership assets, including asset identification and preservation

issues; (c) preparing the Receiver’s sixth affidavit of non-compliance; (d) evaluating

the Receiver’s duties and obligations under the VPL Preliminary Injunction; (e)

regularly visiting VPL’s production, including in connection with VPL’s principals,

Bobbi Bedi and Jason Cardiff working on getting the production machines

operational; (f) engaging in extensive discussions and exchange of information with

Messrs. Bedi and Cardiff, the attorneys for VPL and Messrs. Bedi and Cardiff, and

third parties, regarding VPL manufacturing issues; (g) preparing the VPL cash flow

projections and continuously working on VPL cash flow issues; (h) negotiating

salaries and job descriptions for Messrs. Bedi and Cardiff; (i) regularly participating

in discussions with the parties and their counsel regarding VPL operational issues;

(j) conducting regular meetings with VPL’s principals re VPL operational issues; (k)

monitoring of the status of the instant litigation including review of motions and

other documents filed by the parties, and working with the Receiver’s counsel in

connection therewith; (l) handling of various VPL related issues, including sales tax

issues, vendor payment requests and payments, updating cash flow projections,


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payroll, and working with the Receiver’s counsel re employment agreement terms

for line workers; (m) preparing the Receiver’s reports filed with the Court; (n)

working on multiple matters relating to the Cardiffs’ residence.

21. During the Fifth Reporting Period, FRBC performed certain work for

the Receiver. That work is summarized in the accompanying Declaration of

Michael Gerard Fletcher and evidenced by FRBC’s invoices to the Receiver

(Exhibit 4 thereto), which I have reviewed and approved for payment subject to the

Court granting this Application.

22. I believe that in light of the work performed during the Fifth Reporting

Period, the fees and costs of the Receiver and FRBC are reasonable and should be

approved and authorized for payment in their entirety.

23. In connection with the Application, the Receiver will comply with the

notice requirements of Local Rule 66-7(f) concerning applications for approval of a

receiver’s administrative fees and expenses by serving a copy of the Notice of

Application and Application, the supporting Memorandum of Points and

Authorities, and the declarations and all exhibits on the parties to this action, and by

serving a copy of the Notice of Application and Application and the supporting

Memorandum of Points and Authorities on known creditors who are identified on

the Proof of Service attached to the Notice of Application and Application. In

addition, the Receiver will provide an entire copy of the Application, including the

declarations, to anyone who requests a copy of the Application in writing directed to

Robb Evans & Associates LLC, 11450 Sheldon Street, Sun Valley, California

91352-1121. The Receiver also will post a copy of the entire Application and

supporting declarations on the Receiver’s website for this case at

https://www.robbevans.com/find-a-case/redwood-scientific-technologies-inc-et-al/.


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DECLARATION OF MICHAEL GERARD FLETCHER

I, Michael Gerard Fletcher, declare as follows:

1. I am an attorney at law duly admitted to practice before the courts of

the State of California, the federal courts of the State of California, including the

United States District Court for the Central District of California, and the Ninth

Circuit Court of Appeals, and am a shareholder of Frandzel Robins Bloom & Csato,

L.C. (“FRBC”), attorneys for the Receiver in this matter, Robb Evans & Associates

LLC.

2. I am one of the attorneys primarily responsible for the representation of

the Receiver in this case in addition to Craig A. Welin, who also is a shareholder of

FRBC.

3. During the period of July 1, 2020 through October 31, 2020 (“Fifth

Reporting Period”), FRBC incurred $348,969.76, consisting of $344,648.50 in fees

and $4,321.26 in costs.

4. I attach hereto as Exhibit 3 a table that summarizes the hours worked

by each attorney and paralegal during the Fifth Reporting Period, and their

respective hourly billing rates. This table also shows the percentage of the total fees

incurred by each timekeeper. As the table indicates, the work I performed during

the Fourth Reporting period accounts for nearly 56% of all of the fees.

5. I attach hereto as Exhibit 4 the billing records for FRBC reflecting the

services rendered, time spent and costs incurred by FRBC pertaining to this matter

during the Fifth Reporting Period, with the work descriptions redacted where

appropriate to preserve information protected from disclosure by the attorney-client

privilege and/or attorney work product doctrine or otherwise to protect the Receiver

and the receivership estate from inappropriate disclosures (and FRBC and I

otherwise preserve the attorney-client privilege regarding our communications with

the Receiver as well as documents and information protected from disclosure under

the attorney work product doctrine). These billing summaries are organized in the


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following manner: (a) by the following ABA Uniform Task-Based Management

System Bankruptcy Code Tasks (which are most applicable to billings conducted in

a federal receivership matter) – e.g., Case Administration, Asset Analysis and

Recovery, Meetings of and Communications with Creditors, Litigation, Asset

Analysis and Recovery, and Asset Disposition; and (b) by each attorney and

paralegal under each of the referenced task codes. In addition, at the end of all

timekeeper entries under each task code is a table that includes the hours worked by

each attorney and paralegal.

6. I am familiar with the methods and procedures used to create, record

and maintain billing records for FRBC’s clients. The billing records attached hereto

as Exhibit 4 are prepared from computerized time records prepared

contemporaneously with the services rendered by each attorney and paralegal billing

time to this matter. These computerized records are prepared in the ordinary course

of business by the attorneys and paralegals employed by FRBC who have a business

duty to accurately record their time spent and services rendered on the matters on

which they perform work. The time records are transferred into a computerized

billing program which generates monthly invoices under the supervision of the

firm’s accounting department. Based upon my experience with FRBC, I believe the

firm’s methods and procedures for recording and accounting for time and services

for its clients is reliable and accurate.

7. While the legal services rendered by FRBC during the Fifth Reporting

Period, either at the direction of the Receiver or responsible attorneys with this firm,

are contained in the specific work entries in Exhibit 4, such services included,

without limitation: (a) regularly communicating with and advising the Receiver on

various legal issues related to the Receiver’s administration of the receivership

estate; (b) assisting the Receiver with legal issues as needed; (c) regularly

communicating with the FTC’s counsel and the Cardiffs’ counsel related to various

receivership administration issues; (d) continuing conducting initial legal work


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related to the Court appointing the Receiver as temporary receiver of VPL,

including legal review of VPL’s operations, pursuant to terms of the Court’s

temporary restraining order issued June 24, 2020; (e) attending the July 7, 2020

hearing on the OSC why the Court should enter an order for a preliminary injunction

re VPL; (f) reviewing the VPL Preliminary Injunction; (g) analyzing Jason Cardiff’s

and VPL’s ex parte application (and supporting declarations) to remove the

Receiver or to direct the receiver to continue VPL’s operations, etc., preparing the

Receiver’s opposition and supporting declaration, reviewing the FTC’s opposition

and supporting declarations, reviewing the applicants’ reply, and reviewing the

order denying the application; (h) preparing the Receiver’s sixth affidavit of non-

compliance; (i) reviewing documents and evidence filed by the parties regarding the

FTC’s motion for contempt sanctions against the Cardiffs, attending the July 24,

2020 hearing, and reviewing the Court’s order provisionally granting the FTC’s

motion in part; (j) analyzing third-party Inter/Media Time Buying Corporation’s

motion to compel the Receiver to cure mortgage arrearages for the Cardiffs’

residence and supporting declarations, preparing the Receiver’s opposition,

including supporting declarations and evidence, reviewing the oppositions of the

FTC, the Cardiffs, and third-party True Pharmastrip to the motion, reviewing the

reply, and reviewing the order denying the motion; (k) reviewing VPL’s application

for stay pending appeal, preparing the declarations in support of the Receiver’s

opposition to the application, reviewing the FTC’s opposition and supporting

evidence as well as applicants’ reply and Court’s order denying the application; (l)

assisting the Receiver on legal and other issues related to the VPL operational

issues, including assisting in extensive negotiations on operating expenses and cash

flow issues, including salaries for Bobbi Bedi and Jason Cardiff, negotiating the

joint stipulation as to VPL operations and preparing the ex parte application to file

same under seal, including preparing the Declaration of Brick Kane, and otherwise

assisting the Receiver on multiple matters needed to set up the operation of VPL to


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operate profitably and legally in compliance with the Court’s August 29, 2020 Order

instructing the Receiver to conduct VPL operations going forward in accordance

with the VPL Cash Flow Projections; (m) preparing VPL employee contracts; (n)

preparing and issuing subpoenas to VPL, Bobbi Bedi and related third-parties in

connection with the Receiver’s efforts to identify, obtain, safeguard and preserve

assets of the receivership estate, reviewing responses and objections to the

subpoenas, and conferring with counsel re attempts to informally resolve discovery

dispute; (o) preparing the Receiver’s Fourth Fee Application, including analyzing

Defendants’ opposition and third-party Inter/Media’s opposition, preparing the

Receiver’s reply memorandum, and reviewing the Court’s order granting

application; (p) reviewing the various motions filed by the parties (e.g., cross-

summary judgment motions) and resulting orders issued by the Court as they relate

to the administration of the receivership estate, including communicating with the

Receiver about the motions and orders; (q) assisting the Receiver on legal issues in

connection with its report on VPL operations filed on October 1, 2020, including

analysis of Defendants response; (r) analyzing the Cardiffs’ Motion for Jason

Cardiff’s Salary and Living Expenses and supporting declarations, reviewing the

FTC’s opposition and supporting evidence, and preparation the Receiver’s

opposition and supporting declarations, (s) assisting the Receiver on issues related to

the Receiver’s plan to discontinue efforts to sell the Cardiffs’ residence.

8. I believe that in light of the work FRBC performed during the Fifth

Reporting Period, FRBC’s fees and costs are reasonable and should be approved and

authorized for payment in their entirety.

9. It is FRBC’s understanding that in light of the Court’s requirement

under the Temporary Restraining Order and Preliminary Injunction that the Receiver

shall file with the Court and serve on the parties periodic requests for payment of the

Receiver’s and its professionals’ reasonable compensation, that the Receiver was

not required to comply with L.R. 7-3 before bringing the instant Application.


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Further, it is our understanding that L.R. 7-3 does not apply to the Application in the

first instance since the Receiver represents the Court’s agent, and there is no

“opposing counsel” as that term is used in L.R. 7-3. Nonetheless, on December 9,

2020, my partner, Hal D. Goldflam, communicated in writing with counsel of record

for Plaintiff Federal Trade Commission, Defendant Danielle Cardiz, and Defendants

Jason Cardiff and Eunjung Cardiff regarding the Receiver’s intent to bring the

instant Application, and that the Receiver would file it after December 16, 2020.

Mr. Goldflam also provided all counsel with (a) a copy of the “Receivership

Administrative Expense Report by Month and Fund Balance From Inception

(October 10, 2018) to October 31, 2020” and (b) copies of the Receiver’s and

FRBC’s respective redacted invoices for the Fifth Reporting Period. I attach hereto

collectively as Exhibit 5 true and correct copies of the December 9, 2020 written

communications, excluding copies of the invoices and report.

10. On December 14, 2020, Stephen Cochell, counsel for the Cardiffs and

VPL Medical, Inc., called me asking the Receiver to delay filing the Fifth Fee

Application until after the end of December, 2020, because he needed additional

time to review the Receiver’s and FRBC’s invoices for the Fifth Reporting Period.

He memorialized his request in an e-mail to me and Mr. Goldflam, and on

December 21, 2020, Mr. Goldflam confirmed in an e-mail that the Receiver would

not file the Fifth Fee Application until January 7, 2020 at the earliest. I attach hereto

as Exhibit 6 a true and correct copy of these e-mails, except I have caused the

amount of the weekly reserve in the stipulated VPL Cash Flow Projection for the

Receiver’s fees and costs, including the Receiver’s counsel, to be redacted since the

Cash Flow Projection was filed under seal.


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11

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13

14

15

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17

18

19

20

21

22

23

24

25

26

27

28

4062768.1 | 078410-0061 15 Case No. 5:18-cv-02104-SJO-PLA


FRA

ND

ZEL

RO

BIN

S B

LOO

M &

CSA

TO, L

.C.

100

0 W

ILSH

IRE

BO

ULE

VA

RD, N

INE

TE

EN

TH

FLO

OR

LOS

AN

GE

LES,

CA

LIFO

RN

IA 9

00

17-2

427

(323

) 8

52-1

00

0

11. Despite Mr. Cochell’s request that the Receiver delay filing the Fifth

Fee Application, as of January 7, 2021, he never notified us whether VPL and/or the

Cardiffs have any intention to oppose the Fifth Fee Application. In addition, neither

the FTC nor Ms. Cardiz has notified us that it or she intends to oppose the Fifth Fee

Application.

I declare under penalty of perjury under the laws of the United States of

America that the foregoing is true and correct and that this declaration was executed

on January 8, 2021, at Los Angeles County, California.

/s/ Michael Gerard Fletcher ___________

MICHAEL GERARD FLETCHER


EXHIBIT 1 19


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Pag

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25


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Pag

e 7

of 7

26


michael gerard fletcher (state bar no. 070849) frandzel … · 2021. 1. 11. · michael gerard...

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