Electronic 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 y FILED by Superior Court of California, County of Los Angeles on 07/20/2020 03:53 PM Sherri R. Carter, Executive Officer/Clerk of Court, by A. Miro,Deputy Clerk W. Dan Lee (SBN289526) [Email: dlee @metallawgroup.com] M.E.T.A.L. LAW GROUP, LLP 725 S. Figueroa Street, Suite 3065 Los Angeles, California 90017 Tel: (323) 289-2260 | Fax: (323) 289-2261 Attorneys for Plaintiff KOREAN WESTERN PRESBYTERIAN CHURCH OF LOS ANGELES, a California nonprofit religious corporation SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES, CENTRAL DISTRICT KOREAN WESTERN PRESBYTERIAN CHURCH OF LOS ANGELES, a California nonprofit religious corporation, Plaintiff, VS. JONG SUK CHOI aka OLAF J. CHOI, an individual, THE WESTERN PRESBYTERY OF THE HAPDOING IN USA, a California nonprofit retigious corporation; LA OPEN DOOR PRESBYTERIAN CHURCH, a California nonprofit religious corporation; and HUN SUNG PARK, an individual; and DOES 1-25, inclusive, Defendants. CASE NO. 19STCV40062 {Related to 19STCV36339) [For All Purposes Assigned to the Hon. Monica Bachner in Dept. 71] REPLY IN RESPONSE TO DEFENDANTS’ OPPOSITION TO PLAINTIFF’S MOTION FOR LEAVE TO FILE FIRST AMENDED VERIFIED | COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF; DECLARATION OF W. DAN LEE Hearing Date: July 28, 2020 Time: 10:30 a.m. Dept: 71 Action Filed: November 6, 2019 RES ID: 693865294014 TO THE HONORABLE COURT; ALL PARTIES AND THEIR RESPECTIVE ATTORNEYS OF RECORD: J REPLY IN RESPONSE TO DEFENDANTS’ OPPOSITION TO PLAINTIFF'S MOTION FOR LEAVE TO AMEND; DECLARATION OF W. DAN LEE 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Plaintiff Korean Western Presbyterian Church (“KWPC” or “Plaintiff”), a California nonprofit religious corporation, by its undersigned counsel, submits its Reply in response to the Oppositions separately filed by Defendants LA Open Door Presbyterian Church and Hun Sung Park (collectively, “Park Faction’), on the one hand, and Defendants Jong Suk Choi aka Olaf J. Choi and The Western Presbytery of Hapdong in USA (collectively, the ““Chei Faction”), on the other hand, as follows: IL Procedural History On October 10, 2019, certain former officers and/or directors of KWPC filed a lawsuit against the Park Faction and the Choi Faction, captioned as Koo Bong Lee, et al. v. Nathanael Yun, et al. (LASC 19STCV36339 - Lead Case), alleging, among others, fraud, conspiracy and breach of fiduciary duty. On November 6, 2019, Plaintiff filed this lawsuit against the Park Faction and the Choi Faction, which is related to the Lead Case before this Court (collectively, the “State Court Action’®). (See the accompanied Declaration of W. Dan Lee, Esq. (“Lee Decl.”),{ 2.) On November 15, 2019, the Court in Department 85 (Hon. James C. Chalfant, presiding) issued a temporary restraining order against Defendants Choi, Hapdong, and LAOD. On January 16, 2020, an order of preliminary injunction was issued against said defendants, which remains in full force and effect. (Lee Decl., | 3.) On February 14, 2020, a voluntary chapter 11 petition was filed on behalf of KWPC. Thereafter, this lawsuit was stayed due to bankruptcy. On April 24, 2020, the Bankruptcy Court entered an order modifying the automatic stay to allow the parties to the State Court Action to proceed with the State Court Action to final judgments or orders regarding the dispute between the Ko Faction and the Choi Faction. (BK Doc 147, attached as Exhibit “A” to Lee Decl, { 4 and incorporated herein by reference.) Further, the Bankruptcy Court ordered to appoint a chapter 11 trustee. On or about April 27, 2020, Jason Rund (the “Trustee”) was appointed as the chapter 11 trustee. (BK Doc 144, attached as Exhibit “B™ to Lee Decl., { 5 and incorporated herein by reference.) Following the lift of the automatic stay in part above, the Trustee and KWPC entered into a stipulation re: State Action, a copy of which (BK Doc 181) attached as Exhibit “C” to Lee Decl., § 6 and incorporated herein by reference. On June 17,2020, the Bankruptcy Court approved the foregoing stipulation. (BK Doc 184, attached as Exhibit “D" to Lee Decl., § 7 and incorporated herein by 2 REPLY IN RESPONSE TO DEFENDANTS’ OPPOSITION TO PLAINTIFF'S MOTION FOR LEAVE TO AMEND; DECLARATION OF W. DAN LEE 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 reference.) II. Plaintiff Is No Longer In Possession, Control, And/or Management Of Its Property The Park Faction argues that the (Proposed) First Amended Verified Complaint is prejudicial since it is intended to evict the Park Faction from the leased premises. This argument has no merits since the Bankruptcy Court appointed the Trustee on April 24, 2020. The commencement of a bankruptcy case creates an estate. {11 U.S.C. § 541(a).) Generally, the estate is comprised of all legal or equitable interests of the debtor in property as of the commencement of the case. (11 U.S.C. § 541(a)(1).) Initially, pursuant to § 1107 of the Bankruptcy Code, KWPC was a “debtor in possession” and generally had all of the rights and powers, and was required to perform most of the functions and duties, of a chapter 11 trustee. On April 24, 2020, the Bankruptcy Court entered an order granting the Choi Faction’s request for appointment of a chapter 11 trustee. On or about April 27, 2020, Jason Rund accepted appointment as the chapter 11 trustee. Upon the appointment of the Trustee, the Debtor was no longer a debtor in possession, no longer had authority to act on behalf of the estate, and no longer had authority to exercise control over property of the estate. (See BK Doc 181, Stipulation, qq C-H; Lee Decl, { 8.) Therefore, KWPC has no authority or power over the lease between KWPC and LA Open Door Presbyterian Church (“LAOD”). Rather, on June 29, 2020, the Judgment Creditor Evangelical Christian Credit Union filed its proof of claim against the Debtor (KWPC) in the amount of $3,408,428.40, based on the judgment entered against Defendant LAOD, to the extent that the Park Faction and the Choi Faction are in collusion to avoid the judgment against LAOD and to take over KWPC'’s property as alleged in the State Action. (BK Claim 5, attached as Exhibit “E” to Lee Decl., 9.) Accordingly, it would be prejudicial to KWPC if this motion is denied. III. The Choi Faction’s “Disqualification” Argument Is Premature The Choi Faction argues that since attorney for KWPC in the State Action, Won Kee Lee aka W. Dan Lee (“Lee”) is in conflict with Nathanael Yun, he should be first disqualified. (Opp. at pp. 5-6.) This issue was already raised by Nathanael Yun when he, by his attorney(s), filed a complaint against Lee in the State Bar of California, which was closed as of May 7, 2020. (Lee Decl., § 10.) 3 REPLY IN RESPONSE TO DEFENDANTS’ OPPOSITION TO PLAINTIFF'S MOTION FOR LEAVE TO AMEND; DECLARATION OF W. DAN LEE 10 11 12 13 14 15 17 18 19 20 21 22 23 24 25 26 27 28 IV. The Amended Complaint Seeks This Court’s Order To Determine Which Faction Represents KWPC A motion for leave to amend is liberally granted. This motion is timely in compliance with Code Civ. Proc., § 576. The (proposed) amended complaint for declaratory and injunctive relief omits all other claims pled in the original complaint and asks this Court to determine which faction represents KWPC. In order to expedite this determination, Plaintiff already filed and noticed a motion for an order to fix a hearing date pursuant to California Corporations Code section 9418, which is currently set for November 2, 2020 before this Court. V. Conclusion For the reasons stated above, this motion should be granted. Further, Plaintiff asks the court to name (a) Joo Mo Ko, Bong Kyu Kim, and Myun Chul Ra as (additional) plaintiffs and (b) Chang Rok Kim as an additional defendant. Plaintiff(s) will file the First Amended Verified Complaint within ten (10) days from this Court’s order. Date: July 20, 2020 Respectfully submitted, M.E.T.A.L. LAW GROUP, LLP W. Dan Lee Plaintiff KOREAN WESTERN PRESBYTERIAN CHURCH OF LOS ANGELES, a California nonprofit religious corporation 4 REPLY IN RESPONSE TO DEFENDANTS’ OPPOSITION TO PLAINTIFF'S MOTION FOR LEAVE TO AMEND; DECLARATION OF W. DAN LEE 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 DECLARATION OF W. DAN LEE I, W. Dan Lee, declare under oath as follows: I: I'am an attorney licensed to practice in all courts in the state of California. I am attorney of record for Plaintiff Korean Western Presbyterian Church of Los Angeles (“Plaintiff”) in the above- captioned matter. I know all of the facts set forth herein of my own personal knowledge and, if called as a witness, could and would competently testify hereto. 2. On October 10, 2019, certain former offices and/or directors of KWPC filed a lawsuit against the Park Faction and the Choi Faction captioned as Koo Bong Lee, et al. v. Nathanael Yun, et al. (LASC 19STCV36339 - Lead Case), alleging, among others, fraud, conspiracy and breach of fiduciary duty. On November 6, 2019, Plaintiff filed this lawsuit against the Park Faction and the Choi Faction, which is related to the Lead Case before this Court (collectively, the “State Court Action”). 3. On November 15, 2019, the Court in Department 85 (Hon. James C. Chalfant, presiding) issued a temporary restraining order against Defendants Choi, Hapdong, and LAOD. On January 16, 2020, the Honorable Chalfant issued an order of preliminary injunction against said defendants, which remains in full force and effect. 4. On February 14, 2020, a voluntary chapter 11 petition was filed on behalf of KWPC. Thereafter, this lawsuit was stayed due to bankruptcy. On April 24, 2020, the Bankruptcy Court entered an order modifying the automatic stay to allow the parties to the State Court Action to proceed with the State Court Action to final judgments or orders regarding the dispute between the Ko Faction and the Choi Faction. (BK Doc 147, attached hereto as Exhibit “A” and incorporated herein by reference.) Further, the Bankruptcy Court ordered to appoint a chapter 11 trustee. 3 On or about April 27, 2020, Jason Rund (the “Trustee”) was appointed as the chapter 11 trustee. {BK Doc 144, attached hereto as Exhibit “B” and incorporated herein by reference.) 6. Following the lift of the automatic stay in part above, the Trustee and KWPC entered into a stipulation re: State Action, a copy of which (BK Doc 181) attached hereto as Exhibit “C” and incorporated herein by reference. 7h On June 17, 2020, the Bankruptcy Court approved the foregoing stipulation. (BK Doc 184, attached hereto as Exhibit “D” and incorporated herein by reference. --- 3 ----- - REPLY IN RESPONSE TO DEFENDANTS’ OPPOSITION TO PLAINTIFF'S MOTION FOR LEAVE TO AMEND; DECLARATION OF W. DAN LEE 10 1 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 8. On April 24, 2020, the Bankruptcy Court entered an order granting the Choi Faction’s request for appointment of a chapter 11 trustee. On or about April 27, 2020, Jason Rund accepted appointment as the chapter 11 trustee. Upon the appointment of the Trustee, the Debtor was no longer a debtor in possession, no longer had authority to act on behalf of the estate, and no longer had authority to exercise control over property of the estate. (See BK Doc 181, Stipulation, fl C-H.) g. On June 29, 2020, the Judgment Creditor Evangelical Christian Credit Union filed its proof of claim against the Debtor (KWPC) in the amount of $3,408,428.40, based on the judgment entered against Defendant LAOD, to the extent that the Park Faction and the Choi Faction are in collusion to avoid the judgment against LAOD and to take over KWPC'’s property as alleged in the State Action. (BK Claim $, attached hereto as Exhibit “E” and incorporated herein by reference. 10. In mid-April 2020, Nathanael Yun filed a complaint against Lee in the State Bar of California, alleging conflict of interest in this matter. I submitted my written response thereto. Thereafter, the case was closed as of May 7, 2020. (Attached hereto as Exhibit “F” and incorporated herein by reference is a true copy of the closure letter dated May 7, 2020, from the State Bar of California.) I declare under penalty of perjury under the laws of California that the foregoing is true and correct, except as to matters herein stated to be on information and/or belief. This declaration was executed on July 20, 2020, at Los Angeles, California. Lar W. Dan Lee 6 REPLY IN RESPONSE TO DEFENDANTS’ OPPOSITION TO PLAINTIFF'S MOTION FOR LEAVE TO AMEND; DECLARATION OF W. DAN LEE 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Exhibit “A” Order Granting Motion For Order Stating Automatic Stay Applies In State Court Proceeding (BK Doc 147_Entered 04/28/2020) V REPLY IN RESPONSE TO DEFENDANTS’ OPPOSITION TO PLAINTIFF'S MOTION FOR LEAVE TO AMEND; DECLARATION OF W. DAN LEE Case [£:20-bk-11675-NB Doc 147 Filed 04/28/20 Entered 04/28/20 10:21:58 Desc Main Document Page 1 of 3 1 [| TIMOTHY J. YOO (SBN 155531) MONICA Y. KIM (SBN 180139) 2 LEVENE, NEALE, BENDER, YOO & BRILL L.L.P. FILED & ENTERED 3 10250 Constellation Boulevard, Suite 1700 Los Angeles, California 90067 4 || Telephone: (310) 229-1234 APR 28 2020 Facsimile: (310) 229-1244 5 || Email: TTY@LNBYB.COM, MYK@LNBYB.COM & ERCIE Cif RIETEr EOI Central District of California 6 Attorneys for Nathanael Yun and Jong Suk Choi en = 7 UNITED STATES BANKRUPIEFERCGHMWADE BY COURT 8 CENTRAL DISTRICT OF CALIFORNIA LOS ANGELES DIVISION 9 In re: Case No. 2:20-BK-11675-NB 10 KOREAN WESTERN PRESBYTERIAN Chapter 11 IT {| CHURCH OF LOS ANGELES, 12 ORDER GRANTING MOTION FOR Debtor and Debtor in ORDER STATING AUTOMATIC STAY 13 Possession. APPLIES IN STATE COURT PROCEEDING 14 Hearings: 15 Date: March 31, 2020 Time: 1:00 p.m. 16 Place: Courtroom 1545 17 Date: April 21, 2020 Time: 2:00 p.m. 18 Place: Courtroom 1545 19 20 21 22 23 24 25 26 27 28 Case hh RR W N No oe ~~ O N 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 P:20-bk-11675-NB Doc 147 Filed 04/28/20 Entered 04/28/20 10:21:58 Desc Main Document Page 2 of 3 Hearings were held on March 31, 2020 at 1:00 p.m. and April 21, 2020 at 2:00 p.m. (collectively, “Hearings™) before the Honorable Neil. W. Bason, United States Bankruptcy Judge, in his Courtroom 1545, located at 255 E. Temple St., Los Angeles, CA, to consider the motion (“Motion” or “Stay Motion”) filed by the Ko Faction on behalf of the above-referenced Chapter 11 debtor, Korean Western Presbyterian Church of Los Angeles, debtor herein (“Debtor or “Church”), for order stating that the automatic stay applies in the state court action (“State Court Action”) which was commenced for the Debtor, entitled Korean Western Presbyterian Church of Los Angeles v. Jong Suk Choi, et al, pending in the Los Angeles County Superior Court (Case No. 19STCV40062). All appearances made in connection with the Motion at all of the Hearings are set forth on the record of the Court. Upon consideration of the Stay Motion and all papers and evidence filed in support of the Stay Motion, the opposition to the Stay Motion filed by Nathanael Yun and Jong Suk Choi aka Olaf Choi (“Movants or “Chei Faction”) and all papers and evidence filed in support of the opposition, the Debtor’s reply to the opposition to the Stay Motion and all papers and evidenced filed in support of the reply, all other pleadings and documents filed in this bankruptcy case, and argument of counsel at the Hearings; the Court having found that adequate notices of the Stay Motion and the Hearings were given under all applicable provisions of the Bankruptcy Code, Bankruptcy Rules and Local Bankruptcy Rules; and for the all of the reasons stated on the record at the Hearings and in the Court’s “Memoradum Decision (4) That The Automatic Stay Covers State Court Lawsuit But (B) Determining That “Cause” Exists To Modify The Stay So That Such Litigation May Proceed” (“Memorandum Decision”, filed April 21, 2020, as docket 124), and for good cause appearing therefor, IT IS HEREBY ORDERED THAT: A The Stay Motion (dkt. 71) is hereby granted and the Court finds that the automatic stay applies to the State Court Action, provided, however, pursuant to a separate order of the Court (“Stay Relief Order”, dkt. 131) entered with respect to motion filed by Movants for relief from the automatic stay (dkt. 79), the Court has granted relief from the automatic stay to allow UY Case wn RB W N No 0 0 1 ON 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2:20-bk-116/5-NB Doc 147 Filed 04/28/20 Entered 04/28/20 10:21:58 Desc Main Document Page 3 of 3 the parties to proceed with the State Court Action pursuant to the terms of the Stay Relief Order. “IT IS SO ORDERED.” Neil W. Bason United States Bankruptcy Judge [Date: April 28, 2020 10 11 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Exhibit “B” Order Approving Appointment of Chapter 11 Trustee (BK Doc 144 _Entered 04/27/2020) 8 REPLY IN RESPONSE TO DEFENDANTS’ OPPOSITION TO PLAINTIFF'S MOTION FOR LEAVE TO AMEND; DECLARATION OF W. DAN LEE Casg 0 oo NN o O ; A W O N a N O O N N N N N N N N =o wo 2 2 wo @ = o m e h o w m k wm h m h © =~ OO N h Aa WwW O N = O W O N M O R W N a o 2:20-bk-116/5-NB Doc 144 Filed 04/27/20 Entered 04/27/20 10:35:05 Desc Main Document Page2of5 PETER C. ANDERSON UNITED STATES TRUSTEE Jill M. Sturtevant Assistant United States Trustee Dare Law, SBN 155714 Trial Attorney Office of the United States Trustee 915 Wilshire Blvd, Suite 1850 Los Angeles, CA 90017 Tel: (213) 894-4925 Fax: (213) 894-2603 Email; dare law@usdoj.gov UNITED STATES BANKRUPTCY COURT CENTRAL DISTRICT OF CALIFORNIA LOS ANGELES DIVISION In re Case No. 2:20-bk-11675-NB KOREAN WESTERN PRESBYTERIAN Chapter 11 CHURCH OF LOS ANGELES ORDER APPROVING APPOINTMENT OF CHAPTER 11 TRUSTEE Debtor, The Court having considered the United States Trustee's Application For Order Approving Appointment Of Trustee And Fixing Bond (“Application”), and for good cause appearing, IT IS HEREBY ORDERED that the Application is granted. IT IS FURTHER ORDERED that the appointment of the Jason Rund as chapter 11 trustee by the United States Trustee is approved. HHH Case 2:20-bk-116/5-NB Doc 144 Filed 04/27/20 Entered 04/27/20 10:35:05 Desc Main Document Page 3of5 PROOF OF SERVICE OF DOCUMENT | am over the age of 18 and not a party to this bankruptcy case or adversary proceeding. My business address is: 915 Wilshire Blvd, Suite 1850 Los Angeles, CA 90017 A true and correct copy of the foregoing document entitled: NOTICE OF LODGMENT OF ORDER IN BANKRUPTCY CASE 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) 04/27/2020 , | 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: See Attached Service information continued on attached page 2. SERVED BY UNITED STATES MAIL: On (date) __ 04/27/2020 , | 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. See 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) , | 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 that personal delivery on, or overnight mall to, the judge will be completed no later than 24 hours after the document is filed. The Honorable NEIL BASON United States Bankruptcy Judge 255 E. Temple Street, 9th Floor Mailroom Los Angeles, CA 90012 [J service information continued on attached page | declare under penalty of perjury under the laws of the United States that the foregoing is true and correct. 04/27/2020 Dare Law /s/ Dare Law 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. December 2012 Page 2 F 9021-1.2.BK.NOTICE.LODGMENT Lase 2:2U0-bk-116/5-NB Doc 144 Filed 04/27/20 Entered 04/27/20 10:35:05 Desc Main Document Page 4 of 5 Served by United States Postal Service Debtor Korean Western Presbyterian Church of Los Angeles 1218S. Fairfax Avenue Los Angeles, CA 90019 Attorney for Debtor Dan W Lee 725 S Figueroa St Ste 3065 Los Angeles, CA 90017 Served by NEF Monica Y Kim Attorney for the Choi Faction myk@Inbrb.com, myk@ecf.inforuptcy.com Dare Law Attorney for US Trustee dare.law@usdoj.gov Won Lee Attorney for Debtor dlee@metallawgroup.com Victor A Sahn Attorney for Debtor vsahn@sulmeyerlaw.com pdillamar@sulmeyerlaw.com pdillamar@ecf.inforuptcy.com vsahn@ecf.inforuptcy.com cblair@sulmeyerlaw.com cblair@ecf.inforuptcy.com dlee@metallawgroup.com dlee@ecf.inforuptcy.com Alan G Tippie Attorney for Debtor atippie@sulmeyerlaw.com atippie@ecf.courtdrive.com; pdillamar@sulmeyerlaw.com United States Trustee (LA} ustpregionl6.la.ecf@usdoj.gov Michael A Wallin Attorney for Creditor mwallin@wallinrussell.com Steven Werth Attorney for Debtor swerth@ecf.inforuptcy.com Case 2:20-bk-116/5-NB Doc 144 Filed 04/27/20 Entered 04/27/20 10:35:05 Desc Main Document Page 5 of 5 Timothy | Yoo Attorney for Choi Faction tjy@Inbyb.com case 2:2U0-bK-116/5-NB Doc 144 Filed 04/27/20 Entered 04/27/20 10:35:05 Desc Main Document Page 1 of5 Attorney or Party Name, Address, Telephone & FAX Nos., State Bar No. & FOR COURT USE ONLY Email Address Peter C. Anderson United States Trustee Jill M. Sturtevant, Assisant United States Trustee Dare Law, SBN 155714, Trial Attorney Office of the United States Trustee 915 Wilshire Blvd, Suite 1850 Los Angeles, CA 90017 Tel: 213-894-4925 Fax: 213-894-2603 email: dare law@usdoj.gov Individual appearing without an attorney X Attorney for: United States Trustee UNITED STATES BANKRUPTCY COURT CENTRAL DISTRICT OF CALIFORNIA - LOS ANGELES DIVISION In re: CASE NO.: 2:20-bk-11675-NB KOREAN WESTERN PRESBYTERIAN CHURCH OF LOS CHAPTER: 11 ANGELES NOTICE OF LODGMENT OF ORDER IN BANKRUPTCY CASE RE: (title of motion"): ORDER APPROVING APPOINTMENT OF CHAPTER 11 TRUSTEE Debtor(s) PLEASE TAKE NOTE that the order titled ORDER APPROVING APPOINTMENT OF CHAPTER 11 TRUSTEE was lodged on (date) __ 04/27/2020 and is attached. This order relates to the motion which is docket number 142 . ! Please abbreviate if title cannot fit into text field. This form is mandatory. It has been approved for use by the United States Bankruptcy Court for the Central District of California December 2012 Page 1 F 9021-1.2.BK.NOTICE.LODGMENT 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Exhibit “C” Stipulation Between Trustee And Debtor Re: Pending State Court Action (BK Doc 181_Entered 06/15/2020) 9 REPLY IN RESPONSE TO DEFENDANTS’ OPPOSITION TO PLAINTIFF'S MOTION FOR LEAVE TO AMEND; DECLARATION OF W. DAN LEE “ope 2:20-DK-116/5-NB Doc 181 Filed 06/15/20 Entered 06/15/20 16:05:53 Desc Main Document Page 1 of 6 BRAD D. KRASNOFF (State Bar No. 125065) bkrasnoff@DanningGill.com JOHN N. TEDFORD, IV (State Bar No. 205537) Jtedford@DanningGill.com DANNING, GILL, ISRAEL & KRASNOFF, LLP 1901 Avenue of the Stars, Suite 450 Los Angeles, California 90067-6006 Telephone: (310) 277-0077 Facsimile: (310) 277-5735 Attorneys for Jason Rund, Chapter 11 Trustee UNITED STATES BANKRUPTCY COURT CENTRAL DISTRICT OF CALIFORNIA LOS ANGELES DIVISION Inre Case No. 2:20-bk-11675-NB KOREAN WESTERN PRESBYTERIAN Chapter 11 CHURCH OF LOS ANGELES, STIPULATION BETWEEN TRUSTEE Debtor. AND DEBTOR RE PENDING STATE COURT ACTION [No hearing required) Jason Rund. chapter 11 trustee (the “Trustee™) for the estate of Korean Western Presbyterian Church (the Debtor”). and the putative Debtor, by and through its bankruptcy and state court counsel of record, request that the Court approve the within stipulation of the parties: STIPULATION A, Prior to November 2019, a dispute arose between a group of persons generally referred to as the "Ko Faction™ and a group of persons generally referred to as the “Choi Faction” regarding which group was legally authorized to control the Debtor. B. In November 2019, a complaint was filed on behalf of the Debtor, against four defendants, in the Los Angeles Superior Court. The case is Korean Western Presbyterian Church of Los Angeles v. Choi. Case No, 19STCV0062 (the “State Court Action”). The defendants in the 1590309 1 26950 ] Cape 2:20-bk-11675-NB Doc 181 Filed 06/15/20 Entered 06/15/20 16:05:53 Desc 1 12 13 14 16 17 18 19 =] J - = J J Main Document Page 2 of 6 State Court Action are (1) Jong Suk Choi aka Olaf J. Choi, (2) The Western Presbytery of the Hapdong in USA, (3) LA Open Door Presbyterian Church, and (4) Hun Sung Park. C. On February 14, 2020 (the “Petition Date”), a voluntary chapter 11 petition was filed on behalf of the Debtor. The petition and other case initiating docurnents were signed by Rev. Joo Mo Ko. There is a dispute as to whether Rev. Ko has authority to act on behalf of the Debtor. D. The commencement of a bankruptcy case creates an estate. 11 U.S.C. § 541(a). Generally, the estate is comprised of all legal or equitable interests of the debtor in property as of the commencement of the case. 11 U.S.C. § 541(a)(1). Therefore, to the extent that claims made in the State Court Action constituted interests of the Debtor in property, they became property of the Debtor’s estate. E. Initially, pursuant to § 1107 of the Bankruptcy Code, the Debtor was a “debtor in possession” and generally had all of the rights and powers, and was required to perform most of the functions and duties, of a chapter 11 trustee. F. On April 24, 2020, a motion was filed in the State Court Action on behalf of the Debtor, seeking leave to file a first amended complaint (the “Motion for Leave to Amend™). The proposed First Amended Complaint for Declaratory and Injunctive Relief omits certain claims for money damages that were asserted in the original complaint. A hearing on the Motion for Leave to Amend is scheduled for July 28, 2020. G. Also on April 24, 2020, the Bankruptcy Court entered an order modifying the automatic stay to allow the parties to the State Court Action to proceed with the State Court Action to final judgments or orders, provided. however, that the automatic stay remains in place to prevent collection of any monetary judgment out of the bankruptcy estate or disposition of estate property, absent further order of the Bankruptcy Court. H. Also on April 24, 2020, the Bankruptcy Court entered an order granting certain parties’ request for appointment of a chapter 1 trustee. On or about April 27, 2020, Jason Rund accepted appointment as the chapter 11 trustee. Upon the appointment of the Trustee, the Debtor was no longer a debtor in possession, no longer had authority to act on behalf of the estate, and no tonger had authority to exercise control over property of the estate. 1590509 | 26950 2 Cape 2:20-bk-116/5-NB Doc 181 Filed 06/15/20 Entered 06/15/20 16:05:53 Desc Main Document Page 3 of 6 L At least at present, the Trustee intends to remain neutral with respect to the dispute between the “Ko Faction” and the “Choi Faction” over control of the Debtor and its property. At the same time, the Trustee does not object to the State Court Action going forward so the dispute between the factions can be resolved. WHEREFORE, THE PARTIES STIPULATE AND AGREE AS FOLLOWS: 1. Nothing in this stipulation. or the Bankruptcy Court's order approving this stipulation, should be interpreted by any party or court to mean that the Bankruptcy Court or the Trustee has determined that the Ko Faction is authorized to act on behalf of the Debtor. The fact that this stipulation refers to the “Debtor” having done or being authorized to do something does not mean that the Bankruptcy Court and/or the Trustee agrees that the “Ko Faction” has authority to act on behalf of the Debtor. Z Similarly, no adverse inferences should be made by any party or court reviewing this stipulation or the Bankruptcy Court's order. Nothing in this stipulation, or the Bankruptcy Court's order approving this stipulation. should be interpreted by any party or court to mean that the Bankruptcy Court or the Trustee has determined that the Choi Faction is authorized to act on behalf of the Debtor. Until he says otherwise, the Trustee is neutral. 3. On its own behalf, and not on behalf of the Trustee or the estate, the Debtor may continue to prosecute the State Court Action. The Debtor shall not make any representation to the state court that the Debtor or its counsel is acting on behalf of, or represents, the Trustee and/or the estate. 4. The Debtor shall not make any representation to the state court that the Trustee favors the position advanced by the Debtor in the State Court Action, or agrees that the state court should rule in favor of the plaintiff. i Ht i HH i 1390509 | 26950 3 Case 2:20-bK-116/5-NB Doc 181 Filed 06/15/20 Entered 06/15/20 16:05:53 Desc such claims. DATED: June | 22020 DATED: June ™020 : DATED: June ti. 2020 3 } 1390509 1 2495¢ Main Document Page 4 of 6 3 The Trustee docs not take any position with respect to the Debtor's Motion for Leave to Amend. However, to the extent the Motion for Leave to Amend secks authority to file an amended complaint that omits claims for money damages, the Trustee consents to the omission of DANNING, GILL, ISRAEL & KRASNOFF, LLP By NY 4. LS JON N. TEDFORD, IV Attdrfieys for Jason Rund, Chapter i] Trustee METAL LAW GROUP, LLP W. DAN LEE State Court Attorneys for Korean Westem Presbyterian Church of Los Angeles SULMEYERKUPETZ, A Professional Corporation By: TR = coe VICTOR A. SAHN Bankruptcy Attorneys for Korean Western Presbyterian Church of Los Angeles Case 2:2U-Dk-116/5-NB Doc 181 Hiled 06/15/20 Entered 06/15/20 16:05:53 Desc Main Document Page 5 of 6 PROOF OF SERVICE OF DOCUMENT | am over the age of 18 and not a party to this bankruptcy case or adversary proceeding. My business address is 1901 Avenue of the Stars, Suite 450, Los Angeles, CA 90067-6006. A true and correct copy of the foregoing document entitled (specify): STIPULATION BETWEEN TRUSTEE AND DEBTOR RE PENDING STATE COURT ACTION 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) June 15, 2020 | 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: & Service information continued on attached page. 2. SERVED BY UNITED STATES MAIL: On (date) » | 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. O 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) , | 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 that personal delivery on, or overnight mail to, the judge will be completed no later than 24 hours after the document is filed. 0 Service information continued on attached page. | declare under penalty of perjury under the laws of the United States that the foregoing is true and correct. June 15, 2020 Patricia Morris /s/ Patricia Morris Date Printed Name Signature 15845311 26950 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 Lase 2:20-bk-116/5-NB Doc 181 Hed 06/15/20 Entered 06/15/20 16:05:53 Desc Main Document Page 6 of 6 ADDITIONAL SERVICE INFORMATION (if needed): 1. SERVED BY THE COURT VIA NOTICE OF ELECTRONIC FILING (“NEF”) Monica Y Kim myk@Inbrb.com, myk@ecf.inforuptcy.com Brad Krasnoff bkrasnoff@DanningGill.com, danninggill@gmail.com;bkrasnoff@ecf.inforuptcy.com Dare Law dare.law@usdoj.gov Won Lee dlee@metallawgroup.com Jason M Rund (TR) trustee@srlawyers.com, jrund@ecf.axosfs.com Victor A Sahn vsahn@sulmeyerlaw com, pdillamar@sulmeyerlaw.com;pdillamar@ecf.inforuptcy.com;vsahn@ecf.inforuptcy.com;cblair@sulmeyerlaw.co m;cblair@ecf.inforuptcy.com;dlee@metallawgroup.com;dlee@ecf inforuptcy. om John N Tedford jtedford@DanningGill.com, danninggill@gmail .com;jtedford@ecf.inforuptcy.com Alan G Tippie atippie@sulmeyerlaw.com, atippie@ecf.courtdrive.com;pdillamar@sulmeyerlaw.com United States Trustee (LA) ustpregion!6.la.ecf@usdoj.gov Michael A Wallin mwallin@wallinrussell.com Steven Werth swerth@sulmeyerlaw.com, cblair@sulmeyerlaw.com;mviramontes@sulmeyerlaw.com;swerth@ecf.inforuptcy.com Timothy J Yoo tjy@Inbyb.com Aaron E de Leest adeleest@DanningGill.com, danninggill@gmail.com;adeleest@ecf.inforuptcy.com 1594531.1 26950 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 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Exhibit “D” Order Approving Stipulation Between Trustee and Debtor Re: Pending State Court Action (BK Doc 184_Entered 06/17/2020) 10 REPLY IN RESPONSE TO DEFENDANTS’ OPPOSITION TO PLAINTIFF'S MOTION FOR LEAVE TO AMEND; DECLARATION OF W. DAN LEE Ca co ~~ N W BA W N oo 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 je 2:20-bk-11675-NB Doc 184 Filed 06/17/20 Entered 06/17/20 10:32:43 Desc Main Document Page 1 of 2 BRAD D. KRASNOFF (State Bar No. 125065) bikrasnoff@DanningGill. com JOHN N. TEDFORD, IV (State Bar No. 205537) Jjtedford@DanningGill.com FILED & ENTERED DANNING, GILL, ISRAEL & KRASNOFF, LLP 1901 Avenue of the Stars, Suite 450 Los Angeles, California 90067-6006 JUN 172020 Telephone: (310) 277-0077 Facsimile: (310) 277-5735 CLERK U.S. BANKRUPTCY COURT Central District of California EY sumlin DEPUTY CLERK Attorneys for Jason Rund, Chapter 11 Trustee CHANGES MADE BY COURT UNITED STATES BANKRUPTCY COURT CENTRAL DISTRICT OF CALIFORNIA LOS ANGELES DIVISION Inre Case No. 2:20-bk-11675-NB KOREAN WESTERN PRESBYTERIAN Chapter 11 CHURCH OF LOS ANGELES, ORDER APPROVING STIPULATION Debtor. BETWEEN TRUSTEE AND DEBTOR RE PENDING STATE COURT ACTION [No hearing required] The Court having considered the Stipulation Between Trustee and Debtor Re Pending State Court Action (the “Stipulation”) (docket no. 181) between Jason Rund, chapter 11 trustee (the “Trustee™) for the estate of Korean Western Presbyterian Church (the “Debtor”), and the putative Debtor, for good cause appearing, it is ORDERED THAT: 1. The Stipulation is approved. 2, Nothing in the Stipulation, or this order, should be interpreted by any party or court to mean that this Court or the Trustee has determined that the persons referred to in this bankruptcy case as the “Ko Faction” are, or are not, authorized to act on behalf of the Debtor. Accordingly, the fact that the Stipulation and this order refers to the “Debtor” having done or being authorized to do 1594038.1 26950 1 Caf wm Rk W N No 0 = ) Oh 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 je 2:20-bk-11675-NB Doc 184 Filed 06/17/20 Entered 06/17/20 10:32:43 Desc Main Document Page 2 of 2 something does not mean that this Court or the Trustee has determined that the “Ko Faction” has authority to act on behalf of the Debtor. 3. Similarly, nothing in the Stipulation, or this order, should be interpreted by any party or court to mean that this Court or the Trustee has determined that the persons referred to in this bankruptcy case as the “Choi Faction” are, or are not, authorized to act on behalf of the Debtor. 4. On its own behalf, and not on behalf of the Trustee or the estate, the Debtor may continue to prosecute the Korean Western Presbyterian Church of Los Angeles v. Choi, Case No. 19STCV0062 (the “State Court Action”). 5. The Debtor shall not make any representation to the state court that the Debtor or its counsel is acting on behalf of, or represents, the Trustee and/or the estate. 6. The Debtor also shall not make any representation to the state court that the Trustee or the Court favors the position advanced by the Debtor in the State Court Action, or agrees that the state court should rule in favor of the plaintiff. HHH No by Wore Neil W. Bason United States Bankruptcy Judge Date: June 17, 2020 1594038.1 26950 2 10 1 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Exhibit “E” Proof of Claim Filed by Judgement-Creditor Evangelical Christian Credit Union (BK Claim 5_Filed 06/29/2020) 11 REPLY IN RESPONSE TO DEFENDANTS’ OPPOSITION TO PLAINTIFF'S MOTION FOR LEAVE TO AMEND; DECLARATION OF W. DAN LEE Case 2:20-bk-11675-NB Claim 5 Filed 06/29/20 Desc Main Document Page 1 of 3 Fill in this information to identify the case: Deblor 1 Korean Western Presbyterian Church Debtor 2 {Spouse, if filing) United Slates Bankruptcy Cour for the: Central District of California Case number 2.20-bk-11675-NB Official Form 410 Proof of Claim 416 Read the Instructions before filling out this form. This form Is for making a claim for payment In a bankruptcy case. Do not use this form to make a request for payment of an administrative expense. Make such a request according to 11 U.S.C. § 503, Filers must leave out or redact information that is entitled to privacy on this form or on any attached documents. Attach redacted copies of any documents that support the claim, such as promissory notes. purchase orders, invoices, itemized statements of running accounts, contracts, judgments, mortgages, and security agreements. Do not send original documents; they may be destroyed after scanning. If the documents are not available, explain in an allachment. A person who files a fraudulent claim could be fined up to $500,000, imprisoned for up to 5 years, or both. 18 U.S.C. §§ 152. 157, and 3571 Fill In all the Information about the claim as of the date the case was filed. That date is on the notice of bankruptcy (Form 309) that you received. Identify the Claim ln “HE ISHING EXEnt Evangelical Christian Credit Union creditor? : - ~ Name of the current craditor (the person or entily to be paid for this claim) Other names the creditor used with the debtor 2 Has this claim been od No acquired from a someone else? Yes. From whom? 3 Where should notices Where should notices to the creditor be sent? Where should payments to the creditor be sent? (if and payments to the different) creditor be sent? . c/o Wallin & Russell LLP Federal Rule of Name Name Bankruptcy Procedure : . (FRBP) 2002(g) 28000 Towne Centre Drive, Suite 130 Number Street © Number Street - Foothill Ranch CA 92610 Cily State 2IP Code City State ZIP Code Contact phone 949-652-2200 Contact phone Contact ema Mwallin@wallinrussell.com Contact email Uniform claim identifier for electronic payments in chapter 13 {il you use one): 4. Does this claim amend [ No one already filed? QJ Yes. Claim number on court claims registry (if known) Filed on MM oD YY¥ 5. Do you know ifanyone [ No else has filed a proof ¥ e the earlier filing? of claim for this claim? | Yes. Who mad SET Rings Official Form 410 Proof of Claim page 1 Case 2:20-bk-11675-NB Claim 5 Filed 06/29/20 Desc Main Document Page 2 of 3 Give Information About the Claim as of the Date the Case Was Filed 6. Do you have any number & No you ues toidentifythe [J ves. Last 4 digits of the debtor's account or any number you use to identify the debtor: ebtor 7. How much is the claim? $ 3,408,428.40 . poes this amount include interest or other charges? OQ No od Yes. Attach statement itemizing interest, fees, expenses, or other charges required by Bankruptcy Rule 3001({c)(2)(A). 8. What is the basis of the ~~ Examples: Goods sold, money loaned, lease, services performed, personal injury or wrongful death. or credit card. claim? Attach redacted copies of any documents supporting the claim required by Bankruptcy Rule 3001{c). Limit disclosing information that is entitled to privacy, such as health care information. Judgment entered in Los Angeles Counly Superior Court Case No. BC497940 (see Addendum for furlher details). 9. Is all or part of the claim [74] No secured? (J Yes. The claim is secured by a lien on property. Nature of property: 0 Real estate. If the claim is secured by the debtor's principal residence, file a Mortgage Proof of Ciaim Attachment (Official Form 410-A) with this Proof of Claim. OQ Motor vehicle {1 other. Describe: Basis for perfection: Attach redacted copies of documents, if any, that show evidence of perfection of a security interest (for example, a mortgage, lien, certificate of title, financing statement. or other document that shows the lien has been filed or recorded.) Value of property: Amount of the claim that is secured: § Amount of the claim that is unsecured: 5 {The sum of the secured and unsecured amounts should match the amount in line 7.) Amount necessary to cure any default as of the date of the petition: 3 Annual Interest Rate (when case was filed) % U Fixed OQ Variable 10. Is this claim basedona {ff no lease? Q ves. Amount necessary to cure any default as of the date of the petition. $ 11. is this claim subjecttoa (J No right of setoff? Q Yes, Identify the property: Official Form 410 Proof of Claim page 2 Case 2:20-bk-116/5-NB Clam 5 Filed 06/29/20 Desc Main Document 12. Is all or part of the claim entitled to priority under #1 U.S.C. § 507(a)? A claim may be partly priority and partly nonpriority. For example, in some categories, the law limits the amount entitled to priority. Sign Below Page 3 of 3 a No U Yes. Check all that apply: Amount entitled to priority 0 Domestic support obligations (including alimony and child support) under 11 U.S.C. § 507{a)(1}(A) or (a)(1)(B). § 0 Upto $2,850° of deposits toward purchase, lease, or rental of property or services for personal, family, or household use. 11 U.S.C. § 507(a)(7). $ a Wages. salaries, or commissions (up to $12,850*) eamed within 180 days before the bankruplcy petition is filed or the debtor's business ends, whichever is earlier. $ 11 U.S.C. § 507(a)4). 0) Taxes or penalties owed to governmental units. 11 U.S.C. § 507(a)8) $$ QO contributions to an employee benefit plan. 11 U.S.C. § 507(a)(5). $ QJ Other, Specify subsection of 11 U.S.C. § 507(a)(__) that applies. $ * Amounts are subject to adjustment on 4/01/19 and every 3 years afler that for cases begun on or after the date of adjustment The person completing this proof of claim must sign and date it. FRBP 9011(b). If you file this claim electronically, FRBP 5005(a){2) authorizes courts to establish local rules specifying what a signature is A person who files a fraudulent claim could be fined up to $500,000, imprisoned forup to 5 years, or both. 18 U.S.C. §§ 152, 157, and 3571. Official Form 410 Check the appropriate box: | am the creditor. | am the creditors attorney or authorized agent. I'am the trustee, or the debtor, or their authorized agent. Bankruptcy Rule 3004 I'am a guarantor, surety, endorser, or other codebtor. Bankruptcy Ruie 3005 D U O O E I understand that an authorized signature on this Proof of Claim serves as an acknowledgment that when calculating the amount of the claim, the creditor gave the debtor credit for any payments received toward the debt | have examined the information in this Proof of Clairn and have a reasonable belief that the information is true and correct. | declare under penalty of perjury that the foregoing Is true and correct Executed on date 06/29/2020 MM | DD Shuang Print the name of the person who is completing and signing this claim: Yyyy Name Susan B Rushing First name Middle name Last name Title = _ SVP Chief Risk Officer Company Evangelical Christian Credit Union ) ) . ldenufy the corporale servicer as the company if the authorized agent 's a servicer Address 955 West Imperial Highway, Suite 100 L Number Streat Brea CA 92821 City . Stale ZIP Code oo N Contact phone 949-652-2202 Email mwallin@wallinrussell.com Proof of Claim page 3 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Exhibit “F”’ The State Bar of California’s Closure Letter (dated 05/07/2020) Re: Case Number 20-0-03840 Complainant: Nathanael Yun Against Won Kee Lee (aka Dan Lee) 12 REPLY IN RESPONSE TO DEFENDANTS’ OPPOSITION TO PLAINTIFF'S MOTION FOR LEAVE TO AMEND; DECLARATION OF W. DAN LEE - tt kc) The State Bar OFFICE OF CHIEF TRIAL COUNSEL '__ | of California 845 5. Figueroa Street, Los Angeles, CA 90017 213-765-1217 hugo.gonzalez@calbar.ca.gov May 7, 2020 PERSONAL AND CONFIDENTIAL DELIVERED VIA MY STATE BAR PROFILE Won Kee Lee {aka Dan Lee) METAL Law Group LLP 725 S Figueroa St Ste 3065 Los Angeles CA 90017-5430 Re: Case Number: 20-0-03840 Complainant: Nathanael Yun Dear Won Kee Lee: This letter is sent to you based upon information that you are not currently represented by counsel in this matter. If this is incorrect, please advise me within five days so that future communications may be directed to your counsel. The State Bar has completed the investigation of the allegations of professional misconduct reported by Nathanael Yun and determined that this matter does not warrant further action. Therefore, the matter is closed. The decision to close this matter is without prejudice to further proceedings as appropriate pursuant to rule 2603 of the Rules of Procedure of the State Bar of California. Thank you for your cooperation in this matter. Sincerely, Aa Hugo Gonzalez Investigator San Francisco Office Los Angeles Office 180 Howard Street 845 S. Figueroa Street San Francisco, CA 94105 www, calbar.ca.gov Los Angeles, CA 80017 10 1 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 PROOF OF SERVICE STATE OF CALIFORNIA, COUNTY OF LOS ANGELES I am over the age of eighteen years and not a party to the within action; my business address is 725 S. Figueroa Street, Suite 3065, Los Angeles, California 90017. On July 20, 2020, I served the following document(s) described as REPLY IN RESPONSE TO DEFENDANTS’ OPPOSITION TO PLAINTIFF'S MOTION FOR LEAVE TO FILE FIRST AMENDED VERIFIED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF on the interested parties in this action by placing true copies thereof enclosed in sealed envelopes addressed as follows: C. James Sohn, Esq. Steven C. Kim, Esq. | [Email: sohnesq@ amatl.com] [Email; stevenchim@'sbeglobal.net] 11900 Shasta Circle 3701 Wilshire Blvd., Suite 1040 Cerritos, CA 90703 Los Angeles, CA 90010, Esq. Attorney for Defendants Jong Suk Choi aka Olaf | Attorney for Defendants Jong Suk Choi aka Olaf J. Choi; The Western Presbytery of the Hapdong | J. Choi; The Western Presbytery of the Hapdong in USA in USA Paul A. de Lorimier, Esq. David S. Kim, Esq. [Email: pdelorimicr@mbglaw com] [Email: davidkimesg@ sbeglobal.net] James Wright, Esq. Todd A. Fuson, Esq. [Email: jwright @mbglaw.com] [Email: 1oddlusone ds blaw firm.com] 3250 Wilshire Blvd., #603 DAVID S. KIM & ASSOCIATES Los Angeles, CA 90010 3731 Wilshire Boulevard, Suite 910 Attorney for Defendants LA Open Door Los Angeles, California 90010 Presbyterian Church; Hun Sung Park Attorneys for Plaintiffs Koo Bong Lee, et al (Lead 19STCV36339) John N. Tedford, IV, Esq. Victor A. Sahn, Esq. [Email: jtedtord@ DanningGill.com] [Email: vsahn@ sulimey erlaw com] DANNING, GILL, ISRAEL & KRASNOFF, Steven F. Werth, Esq. LLP [Email: swerth@ sulmey erlaw.com] 1901 Avenue of the Stars, Suite 450 SulmeyerKupetz Los Angeles, California 90067-6006 333 South Grand Avenue, Suite 3400 Attorneys for Jason Rund, Chapter 11 Trustee Los Angeles, California 9007 1 For Debtor Korean Western Presbyterian Church | Attorneys for Debtor Korean Western in Bankruptcy Case (2:20-bk-11675) Presbyterian Church in Bankruptcy Case (2:20- bk-11675) x BY ELECTRONIC MAIL: Pursuant to Emergency Rules Related to COVID-19, rule 12 (electronic service), I caused such document(s) to be delivered by transmitting via electronic mail a true copy to the email addresses set forth below on this date before 5:00 p.m. [x] BY DESIGNATED ELECTRONIC FILING SERVICE: Pursuant to section 1010.6 of the Code of Civil Procedure and rule 2.253(b) of the California Rules of Court, I caused such document(s) to be electronically filed with the Superior Court of Los Angeles via One Legal, e-filing service provider designated by said court on this date before 5:00 p.m. 13 REPLY IN RESPONSE TO DEFENDANTS’ OPPOSITION TO PLAINTIFF'S MOTION FOR LEAVE TO AMEND; DECLARATION OF W. DAN LEE 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 I declare under penalty of perjury under the laws of California that the foregoing is true and correct. Executed on July 20, 2020 at Los Angeles, California. (dA W. Dan Lee 14 REPLY IN RESPONSE TO DEFENDANTS’ OPPOSITION TO PLAINTIFF'S MOTION FOR LEAVE TO AMEND; DECLARATION OF W. DAN LEE
