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Steven Jay Katzman, State Bar No. 132755 skatzman@bmkattorneys.com Anne Uyeda, State Bar No. 235306 auyeda@bmkattorneys.com Anthony Bisconti, State Bar No. 269230 tbisconti@bmkattorneys.com BIENERT, MILLER & KATZMAN, PLC 903 Calle Amanecer, Suite 350 San Clemente, California 92673 Telephone: (949) 369-3700/Facsimile: (949) 369-3701 Attorneys for Retired Employees of the City of San Bernardino Jenifer Aragon, Michael Billdt, Michael Eckley, Walt Goggin, Wayne Harp, Frank Mankin, Denis Moon, Scott Paterson, and Robert Simmons
CASE NO. 6:12-bk-28006 MJ CHAPTER 9 VERIFIED STATEMENT PURSUANT TO FEDERAL RULE OF BANKRUPTCY PROCEDURE 2019
BIENERT MILLER & KATZMAN, PLC (BMK), appearing as counsel for retired employees of the City of San Bernardino Jenifer Aragon, Michael Billdt, Michael Eckley, Walt Goggin, Wayne Harp, Frank Mankin, Denis Moon, Scott Paterson, and Robert Simmons (collectively, the Retirees), parties in interest in the bankruptcy case of the City of San Bernardino (the Bankruptcy Case), file this verified statement pursuant to Federal Rule of Bankruptcy Procedure 2019 (the Rule 2019 Statement) and state as follows: 1. BMK has been requested and has agreed to represent the Retirees in the Bankruptcy Case .
Case 6:12-bk-28006-MJ
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2.
The Retirees consist of former long-standing employees in supervisory positions with the
City of San Bernardinos (the City) police, fire, and public safety departments. 3. The Retirees have agreed to represent their common interests and the interests of other
retired employees of the City in relation to the assertion and preservation of the retirement rights and obligations common to other retirees, owed by the City to the retirees, as potentially affected by the Bankruptcy Case or City action during the pendency of the Bankruptcy Case. 4. The Retirees have vested interests due to their status as retired employees of the City. The
amounts of the Retirees respective claims have yet to be determined. 5. The names and contact addresses for the Retirees are listed below. The address listed for
the Retirees is BMKs address because BMK and the Retirees believe that the Retirees addresses are confidential and protected by law. Jenifer Aragon c/o Bienert, Miller & Katzman, PLC 903 Calle Amanecer, Suite 350 San Clemente, California 92673 Michael Billdt c/o Bienert, Miller & Katzman, PLC 903 Calle Amanecer, Suite 350 San Clemente, California 92673 Michael Eckley c/o Bienert, Miller & Katzman, PLC 903 Calle Amanecer, Suite 350 San Clemente, California 92673 Walt Goggin c/o Bienert, Miller & Katzman, PLC 903 Calle Amanecer, Suite 350 San Clemente, California 92673 Wayne Harp c/o Bienert, Miller & Katzman, PLC 903 Calle Amanecer, Suite 350 San Clemente, California 92673 Frank Mankin c/o Bienert, Miller & Katzman, PLC 903 Calle Amanecer, Suite 350 San Clemente, California 92673 2
VERIFIED STATEMENT PURSUANT TO FEDERAL RULE OF BANKRUPTCY PROCEDURE 2019
Case 6:12-bk-28006-MJ
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Denis Moon c/o Bienert, Miller & Katzman, PLC 903 Calle Amanecer, Suite 350 San Clemente, California 92673 Scott Paterson c/o Bienert, Miller & Katzman, PLC 903 Calle Amanecer, Suite 350 San Clemente, California 92673 Robert Simmons c/o Bienert, Miller & Katzman, PLC 903 Calle Amanecer, Suite 350 San Clemente, California 92673 6. In addition to the Retirees, BMK will also represent other similarly situated retired
employees of the City to the extent necessary to effectuate the objectives of the retention, and will supplement and/or amend this Rule 2019 Statement to reflect such modifications no later than thirty (30) days after such changes occur. I, Steven Jay Katzman, certify under penalty of perjury of the laws of the United States of America that the foregoing Rule 2019 Statement is true and correct to the best of my knowledge and belief. Executed on August 15, 2012, at San Clemente, California. /s/ Steven Jay Katzman /s/ Steven Jay Katzman
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VERIFIED STATEMENT PURSUANT TO FEDERAL RULE OF BANKRUPTCY PROCEDURE 2019
Case 6:12-bk-28006-MJ
Doc 78-1 Filed 08/15/12 Entered 08/15/12 12:35:00 Affidavit Proof of Service Page 1 of 2
CHAPTER 9 Debtor(s).
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F 9013-3.1.PROOF.SERVICE
Case 6:12-bk-28006-MJ
Doc 78-1 Filed 08/15/12 Entered 08/15/12 12:35:00 Affidavit Proof of Service Page 2 of 2
CHAPTER 9 Debtor(s).
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2. SERVED BY UNITED STATES MAIL: On August 15, 2012, I served the following persons and/or entities at the last known addresses in this bankruptcy case or adversary proceeding by placing a true and correct copy thereof in a sealed envelope in the United States mail, first class, postage prepaid, and addressed as follows. Listing the judge here constitutes a declaration that mailing to the judge will be completed no later than 24 hours after the document is filed. William P. Smith (U.S. Mail) Nathan F. Coco Miles W. Hughes McDermott Will & Emery LLP 227 West Monroe Street Chicago, IL 60606
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 August 15, 2012, I served the following persons and/or entities by personal delivery, overnight mail service, or (for those who consented in writing to such service method), by facsimile transmission and/or email as follows. Listing the judge here constitutes a declaration that personal delivery on, or overnight mail to, the judge will be completed no later than 24 hours after the document is filed. Honorable Meredith A. Jury (Overnight Delivery) U.S. Bankruptcy Court 3420 Twelfth Street, Suite 325 Riverside, CA 92501-3819 Service information continued on attached page I declare under penalty of perjury under the laws of the United States that the foregoing is true and correct.
Coleen Grogan
Printed Name
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