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Case 8:10-bk-24771-RK Doc 127 Filed 01/12/11 Entered 01/12/11 13:08:49 Desc
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MARC J. WINTHROP- State Bar No. 63218

KAVITAGUPTA-StateBarNo.l38505
kgupta@winthropcouchot.com
WINTHROP COUCHOT
PROFESSIONAL CORPORATION
660 Newport Center Drive, Suite 400
Newport Beach, CA 92660
Telephone: (949) 720-4100
Facsimile: (949) 720-4111
General Insolvency Counsel for
8 Debtor and Debtor-in-Possession
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UNITED STATES BANKRUPTCY COURT
CENTRAL DISTRICT OF CALIFORNIA
SANTA ANA DIVISION
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In re:
CRYSTAL CATHEDRAL MINISTRIES,
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a California nonprofit corporation,
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Debtor and
Debtor-in-Possession.
Case No. 8:10-bk-24771-RK
Chapter II Proceeding
DEBTOR'S NOTICE OF MOTION AND
MOTION FOR ORDER EXTENDING THE
DEBTOR'S PLAN EXCLUSIVITY PERIODS;
MEMORANDUM OF POINTS AND
AUTHORITIES; IN
SUPPORT THEREOF
[11 US.C 1121]
DATE:
TIME:
PLACE:
February 8, 2011
2:30p.m.
Courtroom 5D
411 W. Fourth Street
Santa Ana, C:A 9270 I
MAINDOCS-11-1566 70-v l-CI) sta I _pian_ Exclusivity_ Motion. DOC
1 TO THE HONORABLE ROBERT KWAN, UNITED STATES BANKRUPTCY
2 JUDGE, THE OFFICE OF THE UNITED STATES TRUSTEE, AND ALL OTHER
3 PARTIES-IN-INTEREST:
4 Crystal Cathedral Ministries, a California nonprofit corporation, the debtor and debtor-in-
5 possession herein ("Debtor") hereby moves ("Motion") the Court, pursuant to the provisions of
6 Section 1121 of the United States Bankruptcy Code ("Bankruptcy Code"), for an order granting
7 the following relief:
8 1. Extending, through and including May 16, 2011, the Debtor's exclusive period to
9 file a plan of reorganization ("Plan");
10 2. Extending, through and including July 16, 2011, the Debtor's exclusive period to
11 solicit acceptances to such a Plan;
12 3. Providing that such order is without prejudice to the Debtor's right to seek further
13 extensions of the applicable exclusivity periods provided by Section 1121 of the Bankruptcy
14 Code; and
15 4. Granting to the Debtor such other and further relief as is just and proper under the
16 circumstances of this case.
1 7 This Motion is made on the basis of the within points and authorities, the Declaration of
18 Gywn Myers attached hereto, and on such other evidence as the Court elects to consider prior to
19 or at the hearing on this matter.
20 IF YOU DO NOT OPPOSE THE MOTION DESCRIBED ABOVE, YOU NEED
21 TAKE NO FURTHER ACTION. HOWEVER, IF YOU OBJECT TO THE MOTION,
22 PURSUANT TO LOCAL BANKRUPTCY RULE 9013-1(F), YOU MUST FILE AND
23 SERVE A WRITTEN OBJECTION AT LEAST 14 DAYS BEFORE THE HEARING.
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DATED: January 12,2011 WINTHROP COUCHOT
By: Is/ Marc J Winthrop
Marc J. Winthrop
Ka vita Gupta
General Insolvency Counsel for the Debtor
and Debtor-in-Possession
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MAINDOCS-1115 G670-v l-C1ystal_ Pl;m _ Exc:usivity _Motion. DOC
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4 A.
MEMORANDUM OF POINTS AND AUTHORITIES
I.
STATEMENT OF FACTS
The Debtor.
5 The Reverend Dr. Robert H. Schuller and his wife, Arvella, founded the Debtor's
6 predecessor in 1955. At that time, it consisted of a single church, known as Garden Grove
7 Community Church, which held its services in space rented from the Orange Drive-In Theatre.
8 The church moved to its current location in Garden Grove, California in 1961, occupying a new
9 sanctuary designed by architect Philip Johnson.
I 0 The Debtor produces The Hour of Power, which is shown throughout the world and is
II North America's longest running televised church service. The Debtor's message of"possibility
12 thinking" is also supported through its many facets, including, inter alia: (I) the delivery of
13 messages of hope each Sunday by Pastors Sheila Schuller Coleman and Dante Gebel. Dr.
14 Schuller, who is 84, is the featured speaker once per month; (2) providing meals for the homeless
15 every Monday; (3) conducting weekly youth groups; and (4) hosting a number of weekly self-help
16 programs. The Debtor also operates a school and cemetery on its campus. The Debtor has
17 approximately 250 full-time and part-time employees who support its many facets.
1 8 R. Events Precipitating The Debtor's Financial Difficulties and Efforts to
19 Reorganize.
20 Over the last few years, the Debtor's leadership has gone through several changes as the
21 ministry has endeavored to transition from its founders to the next generation who will carry the
22 mission of the ministry forward. Robert A. Schuller became Senior Pastor in 2006. He ultimately
23 resigned and Dr. Sheila Schuller Coleman became the Senior Pastor in July of 2009. The period
24 of unsettled leadership caused some in the congregation and viewing audience to leave the
25 ministry, resulting in reduced revenue for an organization that exists primarily on donations.
26 However, the greatest impact on the Debtor's revenues came from the severe downturn in the
27 national economy, which has had a drastic impact on donations to the Debtor and to charitable
28 giving in general. Donations were down approximately 24% in 2009 alone.
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.MAIN DOCS-# 1566 70-vl-Crysta 1_ Plan_ Exclusivity_ MO!ionDOC
Since Dr. Coleman has taken over as Senior Pastor, she has focused her efforts on restoring
2 confidence and enthusiasm in the ministry. Tt is too early to gauge the results of her efforts but
3 early indicators appear to be favorable. Even though the Debtor cut expenses, the decline in
4 donations and other revenue was so severe that the benefits of these reductions could nul be
5 recognized quickly enough and the Debtor's level of debt, both secured and unsecured, increased.
6 Ultimately, the Debtor decided to address the growing amount of debt by convening a general
7 meeting of creditors under the auspices of Credit Managers Association of California. The meeting
8 was well attended and resulted in a voluntary 90-day moratorium on debt collection activities,
9 which was almost universally observed. Due to the need to have reliable financial information on
10 which to base an out of court repayment plan, the Unofficial Creditors Committee ("Unofficial
II Committee") granted the Debtor a conditional 90-day extension of the moratorium. Negotiations
12 were well underway between the Debtor and Unofficial Committee when certain creditors sought
13 and obtained writs of attachment and a number of other lawsuits were filed against the Debtor.
14 Unfortunately, the negotiations between the Debtor and the Unofficial Committee stalled due to
15 concern over the cash flow projections and financial reports. Given these circumstances, the
16 Unofficial Committee decided to allow the moratorium to expire on October 9, 2010 and made a
17 demand for payment. Cumulatively, these circumstances then forced the Debtor to file the present
18 Chapter II proceeding on October 18, 2010 (""Petition Date") in order to obtain a breathing spell
19 within which to address the claims of all creditors on a fair, equitable and uniform basis.
20 C. The Committee.
21 The Office of the United States Trustee ("UST") appointed the Official Committee of
22 Unsecured Creditors ("Committee") pursuant to Section 1102(a)(l) of the Bankruptcy Code on
23 October 27, 20 I 0. The Committee subsequently employed the law firm of Ringstad & Sanders,
24 LLP as its counsel.
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MAINDOCS-# 1566 70-v l-Cryslal_ Plan_ Exclusivity __Motion. DOC
D. Post-Petition Operation/Progress Towards Reorganization.
2 As of this writing, the Debtor's case was filed almost three months ago. However, due in
3 part to the Debtor's financial condition, the seasonality of revenue,
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and the complexity of dealing
4 with various internal and external operational issues, this case has still not stabilized to the point
5 that the Debtor has the financial information required to produce a feasible plan.
6 Notwithstanding, since the Petition Date, the Debtor has continued to identifY ways to improve its
7 c<llih flow and to lower its costs. To that end, the Debtor is, inter alia, evaluating its contracts and
8 services, negotiating with landlords to reduce administrative rent pa}ments, and has declined to
9 renew certain contracts that were unprofitable.
I 0 The Debtor has also engaged, on a regular basis, with the Committee, UST amlto a lesser
11 extent, its secured creditors to resolve outstanding issues, including cash collateral issues.
12 Specifically, on November 15,2010, the Court granted the Debtor's motion to use cash collateral
13 on a final basis. The Debtor has also provided both the Committee and the UST with all material
14 or relevant information that they have requested. Finally, the Debtor has complied with the
15 obligations imposed upon it by the Bankruptcy Code, this Court's orders and the UST
16 requirements.
17 This case has received extensive coverage in the press, which has primarily focnsed on
18 insider compensation. At present, the Committee and the UST have collectively filed four
19 objections to Notices of Setting/Increasing Insider Compensation (collectively, "Contested
20 Notices"). The Debtor has agreed with the Committee and UST to the appointment of an
21 examiner for the limited purpose of assisting in the resolution of insider compensation issues,
22 including the Contested Notices and any future notices that may be filed.
23 In summary, notwithstanding the complexity of this case and the fact that the Debtor filed
24 its petition only approximately three months ago, the Debtor has made significant progress in its
25 case. The Debtor believes that extending the exclusivity periods from February 17, 2011 and
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Specifically, the results for the year-end holiday season (which is the most profitable) will not be available until such
time as the exclusivity periods expire.
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MAINDOCS-# 1566 7 0-vl-Crystal -Plan _ E"clusi\ity _Motion DOC
April 17, 20 II through and including Y!ay 16, 2011 and July 16, 20 II will enable the Debtor to
2 resolve many of the foregoing issues and to file a confinnable plan of reorganization.
3 II.
4 THIS COURT HAS AUTHORITY TO EXTEND THE EXCLUSIVE
5 PERIODS FOR FILING AND SOLICITING ACCEPT Al'I.Cli:S TO A PLAN
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A. "Cause" Exists to Extend the Exclusivity Periods.
Pursuant to Section 1121 (b) of the Bankruptcy Code, a Chapter 11 debtor has the
exclusive right to file a plan of reorganization during the first 120 days following the filing date
of a Chapter 11 bankruptcy petition and to thereafter solicit acceptances to any plan so filed for a
period of an additional 60 days.
Section 112l(b) of the Bankruptcy Code provides:
Except as otherwise provided in this section, only the debtor may file a plan until
after 120 days after the date of the order for relief under this chapter.
11 U.S.C. 112l(b).
No other party-in-interest may file a plan of reorganization unless: (i) a trustee has been
appointed, (ii) the debtor has not filed a plan within 120 days after the date of the order of relief,
or (iii) the debtor has not filed a plan that has been accepted before 180 days after the date of the
order for relief by each class of claims or interests that is impaired by the plan. See II U.S.C.
112l(c). However, Bankruptcy Code Section 112l(d) empowers the Court to reduce or extend
the 120-day and 180-day periods for "cause."
Section 1121 (d) of the Bankruptcy Code provides in peninent part:
On request of a party in interest made within the respective periods specified in
subsections (b) and (c) of this section and after notice and a hearing, the court
may for cause reduce or increase the 120-day period or the 180-day period
referred to in this section.
II U.S.C. 1121.
The Bankruptcy Code does not define "cause" as used in Section 1121 (d) so the decision
of whether or not to grant a request to extend or shorten the exclusivity periods lies within the
sound discretion ofthe bankruptcy judge. See, e.g, Official Comm. of Unsecured Creditors v.
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MAINDOCS-# 15 66 70-v 1-Cryslal_ Plan_ Exclusivity_ Motion.DOC
Henry Mayo Newhall Mem '/How (In re Henry Mayo Newhall Mem '/Hasp.), 282 B.R. 444, 453
2 (R.A.P. 9th Cir. 2002); In re Adelphia !:nmmc'ns Corp, 352 B.R. 578,590 (Bankr. S.IJ N.Y.
3 2006). The "cause" standard referred to in Section 1121 has been recognized as a general
4 standard that allows the bankruptcy court "maximwn flexibility to suit various types of
5 reorganization proceedings." In rePublic Serv. Co. of New Hampshire, 88 B.R. 521, 534 (Rankr.
6 D.N.H. 1988).
7 The primary consideration for a bankruptcy court in determining whether to modify a
8 debtor's exclusivity is whether "adjustment of exclusivity will facilitate moving the case forward
9 towards a fair and equitable resolution." In re Henry Mayo Newhall Mem 'I Hasp., 282 B.R. at
10 453; see also In re Dow Corning Corp., 208 B.R. 661,670 (Bankr. E.D. Mich. 1997); In re
II Adelphia Commc 'ns, 352 B.R. at 590. Further, the legislative history for Section 1121 dictates
12 that granting an extension of exclusivity "should be based on a showing of some promise of
13 probable success." Senate Report No. 95-989, 95th Cong., 2d Sess. 118 (1978); see also In re
14 Landmark Park Plaza Ltd. P'ship, 167 B.R. 752,756 (Bankr. D. Conn. 1994) (requiring "a
15 showing of some promise of probable success"); In re Montgomery Court Apartments ofingham
16 County, Ltd, 126 B.R. 537,539 (Bankr. S.D. Ohio 1991) ("[A] debtor seeking an extension
17 should make a showing 'of some probable success' in formulating a plan."); In re Grossinger 's
18 Assocs., 116 R.R. 34, :lfi (Rankr. S.D.N.Y. 1990) (requiring "probable success in formulating a
19 plan of reorganization").
20 Other criteria that courts consider in determining if"cause" exists include: (1) the number
21 of extensions that have been requested; (2) whether the case is complicated; (3) the time period
22 the case has been pending, relative to its size and complexity; ( 4) whether the debtor is
23 proceeding in good faith; ( 5) whether the debtor is paying current expenses; ( 6) whether the
24 debtor has shown a reasonable prospect for filing a viable plan; (7) whether the debtor is making
25 satisfactory progress negotiating with key creditors; (8) whether the debtor is seeking an
26 extension of exclusivity to pressure creditors; and (9) whether the debtor is depriving the official
27 committee of unsecured creditors of material or relevant information. See In re Dow Corning,
28 208 B.R. at 661; In re Express One Int'l, Inc., 194 B.R. 98, 100 (Bankr. E.D. Tex. 1996). Courts
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MAINOOCS-# 1566 70-v 1-Cl)'s:al_ Plan _ Motion.DOC
1 have also recognized that the diligence of management and the proper administration of the case
2 are factors supporting an extension of the exclusivity periods. See Tn re United Press in/ 'I,
3 60 B.R. 265 (Bankr. D.D.C. 1986).
4 In tlris case, "cause" exists to grant the Debtor's request for an extension of the
5 exclusivity periods. Such request satisfies the general principles established by the courts as
6 guideposts in ascertaining what constitutes "cause" within the meaning of Section 1121 (d). As
7 set forth above, this is the Debtor's first request for an extension. Further, the Debtor's case was
8 filed only three months ago and has proven to be quite complicated. The Debtor has provided
9 the Committee with all material or relevant information that it has requested and it is not seeking
10 this extension to pressure creditors. In fact, the Debtor has been proceeding in good faith,
11 having worked with the Committee to resolve any outstanding issues, including cash collateral
12 issues. Ultimately, extension of the exclusivity periods as requested herein will significantly
13 facilitate the proposal of a confirmable Plan- a truly fair and equitable resolution to this case.
14 B. The Debtor Has Properly Administered Its Case.
15 Courts have recognized that the diligence of management and the proper administration of
16 the case are yet additional factors in supporting an extension of the exclusivity periods. See, In re
17 United Press Int'l, 60 B.R. at 265, In re Trainer's, Inc., 17 B.R. 246, 247 (Bankr. E.D. Pa. 1982).
18 Since the Petition Date, the Debtor has properly administered its Chapter II case. The
19 Debtor has complied with the obligations imposed upon it by the Bankruptcy Code and this
20 Court's orders. Also, the Debtor has filed the necessary schedules and reports required by the
21 UST. The Debtor's administration of its case supports granting the relief requested herein.
22 III.
23 CONCLUSION
24 Based upon the foregoing, the Debtor respectfully requests that the Court enter an order
25 granting the following relief:
26 1. Extending, through and including May 16,2011, the Debtor's exclusive period to
27 file a Plan;
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MAINDOCS-111566 70-v 1-Crystal_ Plan_ Exclus:vity _Motion .DOC
2. Extending, through and including July 16, 2011, the Debtor's exclusive period to
2 solicit acceptances to such a Plan;
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3. Providing that such Order is without prejudice to the Debtor's right to seek further
4 extensions of the applicable exclusivity periods provided by Section 1121 of the Bankruptcy
5 Code; and
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4. Granting to the Debtor such other and further relief as is just and proper under the
7 circumstances of this case.
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DATED: January 12,2011 WINTHROP COUCHOT
By: Is/ Marc J Winthrop
Marc J. Winthrop
Kavita Gupta
General Insolvency Counsel for the Debtor
and Debtor-in-Possession
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MAINDOCS-# 1566 70-v I-Crys1al_ Plan_ Ex:clusivily _ Motion.DOC
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DECLARATION OF GWYN MYERS
I, Gwyn Myers, declare as follows:
1. I am the Chief Restructuring Officer of Crystal Cathedral Ministries, a California
nonprofit corporation, the debtor and debtor-in-possession herein ("Debtor"),
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and am responsible
for overseeing the day-to-day operations and financial performance of the Debtor. Consequently, T
have been involved in supervising all aspects of the Debtor's financial and business affairs since
April2010.
2. The facts stated herein are within my personal knowledge, and if called upon to
testify to such facts I could and would testify competently thereto.
3. The Reverend Dr. Robert H. Schuller and his wife, Arvella, founded the Debtor's
predecessor in 1955. At that time, it consisted of a single church, known as Garden Grove
Community Church, which held its services in space rented from the Orange Drive-In Theatre.
The church moved to its current location in Garden Grove, California in 1961, occupying a new
sanctuary designed by architect Philip Johnson.
4. The Debtor produces The Hour of Power, which is shown throughout the world
and is North America's longest running televised church service. The Debtor's message of
"possibility thinking" is also supported through its many facets, including, inter alia: (I) the
delivery of messages of hope each Sunday hy Pastors Sheila Schuller Coleman and Dante Gebel.
Dr. Schuller, who is 84, is the featured speaker once per month; (2) providing meals for the
homeless every Monday; (3) conducting weekly youth groups; and (4) hosting a number of weekly
self-help programs. The Debtor also operates a school and cemetery on its campus. The Debtor
has approximately 250 full-time and part-time employees who support its many facets.
5. Over the last few years, the Debtor's leadership has gone through several changes
24 as the ministry has endeavored to transition from its founders to the next generation who will
25 carry the mission of the ministry forward. Robert A. Schuller became Senior Pastor in 2006. He
26 ultimately resigned and Dr. Sheila Schuller Coleman became the Senior Pastor in July of 2009.
27 The period of unsettled leadership caused some in the congregation and viewing audience to leave
28
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Capitalized terms used herein but not othenvise defined shall have the meaning set forth in the Motion.
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MAINDOCS-# 156670-v 1-Crysml_ Plan_ Exc:usivity _Motion. DOC
the ministry, resulting in reduced revenue for an organization that exists primarily on donations.
2 However, the greatest impact on the Debtor's revenues came from the severe downturn in the
3 national economy, which has had a drastic impact on donations to the Debtor and to charitable
4 giving in general. Donations were down approximately 24% in 2009 alone.
5 6. Since Dr. Coleman has taken over as Senior Pastor, she has focused her efforts on
6 restoring confidence and enthusiasm in the ministry. It is too early to gauge the results of her
7 efforts but early indicators appear to be favorable. Even though the Debtor cut expenses, the
8 decline in donations and other revenue was so severe that the benefits of these reductions could
9 not be recognized quickly enough and the Debtor's level of debt, both secured and unsecured,
10 increased. Ultimately, the Debtor decided to address the growing amount of debt by convening a
II general meeting of creditors under the auspices of Credit Managers Association of California. The
12 meeting was well attended and resulted in a voluntary 90-day moratorium on debt collection
13 activities, which was almost universally observed. Due to the need to have reliable financial
14 information on which to base an out of court repayment plan, the Cnofficial Creditors Committee
15 ("Unoftlcial Committee") granted the Debtor a conditional90-day extension of the moratorium.
16 Negotiations were well underway between the Debtor and Unofficial Committee when certain
17 creditors sought and obtained writs of attachment and a number of other lawsuits were filed
18 against the Debtor. Unfortunately, the negotiations between the Debtor and the Unoftlcial
19 Committee stalled due to concern over the cash flow projections and financial reports. Given
20 these circwnstances, the Unofficial Committee decided to allow the moratorium to expire on
21 October 9, 2010 and made a demand for payment. Cumulatively, these circumstances then forced
22 the Debtor to file the present Chapter II proceeding on October 18, 2010 ("Petition Date") in
23 order to obtain a breathing spell within which to address the claims of all creditors on a fair,
24 equitable and uniform basis.
25 7. The Office of the United States Trustee ("UST") appointed the Official Committee
26 of Unsecured Creditors ("Committee") pursuant to Section 11 02(a)(l) of the Bankruptcy Code on
27 October 27,2010. The Committee subsequently employed the law firm of Ringstad & Sanders,
28 LLP as its counsel.
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MA TNOOCS-# 15 6670-v !-Crystal_ Plan_ Exclusivity_ Motion. DOC
8. As of this writing, the Debtor's case was filed almost three months ago. However.
2 due in part, to the Debtor's financial condition, the seasonality of revenue,
1
and the complexity of
3 dealing with various internal and external operational issues, this case has still not stabilized to the
4 point that the Debtor has the financial infom1ation required to produce a feasible plan.
5 Notwithstanding, since the Petition Date, the Debtor has continued to identifY ways to improve its
6 cash flow and to lower its costs. To that end, the Debtor is, inter alia, evaluating its contracts and
7 services, negotiating with landlords to reduce administrative rent payments, and has declined to
8 renew certain contracts that were unprofitable.
9
9. The Debtor has also engaged, on a regular basis, with the Committee, UST and to a
10 lesser extent, its secured creditors to resolve outstanding issues, including cash collateral issues.
11 Specifically, on November 15, 2010, the Court granted the Debtor's motion to use cash collateral
12 on a tina! basis. "!be Debtor has also provided both the Committee and the UST with all material
13 or relevant information that they have requested. Finally, the Debtor has complied with the
14 obligations imposed upon it by the Bankruptcy Code, this Court's orders and the UST
15 requirements.
16
10. This case has received extensive coverage in the press, which has primarily focused
17 on insider compensation. At present, the Committee and the UST have collectively filed four
18 objections to Notices of Setting/Increasing Insider Compensation (collectively, "Contested
19 Notices"). The Debtor has agreed with the Committee and UST to the appointment of an
20 examiner for the limited purpose of assisting in the resolution of insider compensation iss Lies,
21 including the Contested Notices and any future notices that may be filed.
22
II. In summary, notwithstanding the complexity of this case and the fact that the
23 Debtor filed its petition only approximately three months ago, the Debtor has made significant
24 progress in its case. This is the Debtor's first request for an extension. I believe that extending
25 the exclusivity periods from February 17,2011 and April17, 2011 through and including May 16,
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Specifically, the results for the year-end holiday season (which is the most profitable) will not be available until such
time as the exclusivity periods expire.
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MAJNDOCS-# 156670-v l..Ctystal_ Plan_ Ly_ Motion.DOC
01/11/2011 TU3 20! 3.3 FAX 71H7143l5
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20 II and July 16, 2011 will enable the Debtor to resolve many of the foregoing issues and to file
a confirmable plan of reorganization.
I declare under penalty of perjury under the laws of the Uncted States of America and the
State of California that the foregoing is true and correct.
Executed thi> i.L. of January 2011, at Garden Grove, California.
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NOTE: When using this form to indicate service of a proposed order, DO NOT list any person or entity in Category 1.
Proposed orders do not generate an NEF because only orders that have been entered are placed on the CM/ECF docket
PROOF OF SERVICE OF DOCUMENT
I am over the age of 18 and not a party to this bankruptcy case or adversary proceeding. My business
address is: 660 Newport Center Drive, 4'" Fl., Newport Beach, CA 92660.
A true ond correct copy of the foregoing document described as: DEBTOR'S :'<OTICE OF MOTION AND MOTION
FOR ORDER EXTENDING THE flFATOR 'S PI AN EXCLUSIVITY PERIODS; MEMORANDUM OF POINTS
AND AUTHORITIES; DECLARATION IN SUPPORT THEREOF will be served or was served (a) on the judge
in chambers in the form and manner required by LBR 5005-2(d); and (b) in the manner indicated below:
I. TO BE SERVED BY THE COURT VIA NOTICE OF ELECTRONIC FILING !"NEF"l- Pursuant to
controlling General Order(s) and Local Bankruptcy Rule(s) ("LBR"), the foregoing document will be served
by the court via NEF and hyperlink to the document. On January 12. 2011, I checked the CM/ECF docket
for this bankruptcy case or adversary proceeding and determined that the following person(s) are on the
Electronic Mail Notice List to receive NEF transmission at the email address(es) indicated below:
Service information continued on attached page
II. SERVED BY U.S. MAIL OR OVERNIGHT MAIL( indicate method for each person or entity served):
On January 12, 2011, I served the following person(s) and/or entity(ies) at the last known address(es) 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/or with an overnight mail service 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.
15 Service information continued on attached page
16 Ill. SERVED BY PERSONAL DELIVERY, FACSIMILE TRANSMISSION OR EMAIL flnd1cate method for
each person or entity served): Pursuant to F.R.Civ.P. 5 and/or controlling LBR, on ,
17 2011 I served the following person(s) and/or entity(ies) by personal delivery, or (for those who consented in
writing to such service method), by facsimile transmission and/or email as follows. Listing the judge here
18 constitutes a declaration that personal delivery on the judge will be completed no later than 24 hours after
the document is filed.
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D Service information continued on attached page
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I declare under penalty of perjury under the laws of the United States of
and correct.
oregoing is true
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January 12, 2011 Susan Connor
Date Type Name
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M A NDOCS-# 1566 70-v !-Crystal_ Pla11_ Exclusi vitL Motion.DOC
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NEFSERVICE
Frank Cadigan frank.cadigan@usdoj.gov
Mark R Campbell mcampbell@markcampbelllaw.com
Bernard R Given bgiven@frandzel.com,
cfiling@frandzel.com;shom@frandzel.com;bgiven@frandzel.com
Marshall F Goldberg mgoldberg@glassgoldberg.com
Kavita Gupta kgupta@winthropcouchot.com
Edward S Kim ekim@hemar-rousso.com
Sleven B Lever sblever@leverlaw.com
MichaelS Mitchell mike@demarcomitchell.com
John D Monte montelaw@eatihlink.net
SueY Park spark@callahan-law.com
Todd C. Ringstad becky@ringstadlaw.com
Chri,lupher 0 Rivas crivas@reedsmith.com
Nanette D Sanders becky@ringstadlaw.com
Ramesh Singh c1aims@recoverycorp.com
Edward J Tredinnick etredinnick@greeneradovsky.com
United States Trustee (SA) ustpregionl6.sa.ecf@usdoj.gov
Andrew F Whalnall awhatnall@daca4.com
Marc J Winthrop mwinthrop@winthropcouchot.com, pj@winthropcouchot.com
Arnold H Wuhrman Wuhrman@serenitylls.com
Crystal Cathedral Ministries
AUn: Gwyn Myers. CRO
13280 Chapman Ave.
Garden Grove_ CA 9 2 8 4 0 ~ 4 4 1 4
NJ-:F
Proposed Committee Counsel
Nanette D. Sanders. Esq.
Ringstad & Sanders LLP
2030 Main Strcel. Suik 1200
Irvine, C/\ 92614
r&M Bank of Long Beach
c/o Lawrence C. Meyerson, Esq
578 Washington Blvd .. #867
Morino Del Rcy. CA 90292
Gipson Hoffman & Pancione
Attn: Robert E. Gipson, Esq.
I')() I I\ venue of the Stars #II 00
Los Angeles, CA 90067-6002
SERVICE VIA FIRST CLASS MAIL
(Unless NEF indicated)
'IEP
United Stales Trustee's Office
Alln: Frank Cadigan, Esq.
411 West fourth Sl., #9041
Santa Ana, CA 9270 t
Credit Managers Association
Attn: Charles Klaus
40 Ea<>l Verdugo Ave.
Burbank, CA 91502
NEFJ0/21/10
Dr. Robert H. Schuller
c/o Mark R. Campbell, Esq.
Mark Campbell Law
300 S. Harbor Blvd., #700
Anaheim. CA 92805
-15-
CCM
SpecialNoticc, Secured
LimitNioticeOrderEntd I0/2lll0
Document No. 153!J50
F&M Bank of Long Beach
c/o Michael Leight, Esq.
6700 Pacific Coast llwy, if-237
Long Beach, CA 90803
Judy A. <.)uan, Esq.
Gardner & Quan Inc.
5000 Birch St., #4400
Newport Beach. CA 9660
NEF 10127110
PNCEF, LLC.
c/o Marshall P. Goldberg, Esq.
Glass & Goldberg
21700 Oxnard St., #430
Woodland II ills, CA 91367-3665
MAI\I"DOCS-#1%670-vl-Crystal Plan Exclusivih_Motion_DOC
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I employ. Inc.
c/o Callahan & Blaine. APLC
Stephen F._ Ria me, Esq
Sue Y. Park, Esq.
3 HuLton Centre Dr., 9th Fl.
Santa Ana. C'A 92707
NEF 11/1/10
NEF 11/11/10
Prandzel, Robins Bloom & CsatG, LC
Bernard R. Given. 11
6500 Wilshire Blvd., 1 i
11
Pl.
Los Angeles, CJ\ lJ004S
11/10/10 CrLMamw.l
Christina Wilcox:
2480 fairview Way
Costa Mesa, CA 92626
RSN11/16/10
Morgan Stanley Bank, NA
c/o Reed Smith LLP
Christopher 0. Rivas. Esq.
355 S. Grand Ave., #2900
l.os Angeles, CA 90071-15 J 4
l\Ef 12/6/2010 Nlif 1219/10
Steven B. Lever, Esq.
Catellus Pinancc 1. LLC
Attn: Managing Member
201 Mission St., #340
San Francisco. CA 94105
EdwardS. Kim, Esq.
Hemar, Rousso & lleald, LLP
Catellus Finance I, LLC
Attn: Ass;ct Management
125tll E. Imperial Highway, #550
Norwalk, CA 90650
-16-
NEF 11/10/10
Edward J. Tredinnick, Esq.
Greene Radovsky Maloney Shmc &
llennigh LLP
Pour Embarcadero Center, #400
San Francisco, CA 94111
RSN 11/16/10
Morgan Stanley Hank, NA
c/o Reed Smith LLP
Mark D. Silverschotz, Esq.
599 Lexington Ave.
New York, NY 10022
1/6/11 RSN
Marilyn M. Pcoples-Hugghins
c/o DcMarco-Mitchell, PLLC
1255 West 15
1
h St., 481 0
Plano, TX 75075
MAl NDOCS-111 5 66 70-v 1-Crystnl_ Plan_ Exclusivity_ Motion.DOC

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Case 8:10-bk-24771-RK Doc 127 Filed 01/12/11 Entered 01/12/11 13:08:49 Desc

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