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UNITED STATES BANKRUPTCY COURT
CENTRAL DISTRICT OF CALIFORNIA
SANTA ANA DIVISION

In re:

CRYSTAL CATHEDRAL MINISTRIES,
a California nonprofit corporation,


Debtor and
Debtor in Possession.
Case No. 8:10-bk-24771-RK

Chapter 11 Proceeding

DEBTORS EMERGENCY MOTION FOR
ORDER AUTHORIZING PAYMENT AND
HONORING OF PREPETITION PAYROLL
OBLIGATIONS; MEMORANDUM OF
POINTS AND AUTHORITIES

[DECLARATION OF FRED W. SOUTHARD
IN SUPPORT THEREOF FILED
CONCURRENTLY HEREWITH]

DATE: October 20, 2010
TIME: 3:00 p.m.
PLACE: Courtroom 5D
411 W. Fourth Street
Santa Ana, CA 92701


MARC J. WINTHROP State Bar No. 63218
mwinthrop@winthropcouchot.com
KAVITA GUPTA State Bar No. 138505
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

[Proposed] General Insolvency Counsel for
Debtor and Debtor-in-Possession

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Crystal Cathedral Ministries, a California nonprofit corporation, the debtor and debtor-in-
2 possession herein ("Debtor"), hereby moves ("Motion"), on an emergencv basis, for an order
3 granting the following relief:
4 A. Authorizing payment of prepetition employee wage and salary obligations
5 owed by the Oebtor up to the priority limit in Section 507(a) of the United States
6 Bankruptcy Code;
7 B. Authorizing the Debtor to pay: (I) $159,411 fur the reimbursement of
8 ordinary course prepetition employment business expenses in accordance with company
9 policy, and (2) the payment of benefit obligations including 40l(k) plan employer
10 contributions, worker's compensation, medical, dental, life insurance, disability insurance,
II and miscellaneous other benefits incurred and payable in the ordinary course;
12 C. Authorizing the Debtor to honor all prepetition vacation pay, sick leave,
13 holiday pay, jury duty pay, and other paid leave claims in the ordinary course;
14 D. Authorizing the Debtor to take all actions reasonable and necessary to
15 comply with its obligations to its existing payroll service company;
16 E. Authorizing the Debtor to retain its prepetition payroll account(s) for 30
17 days and directing the bank or other financial institution not or otherwise impair the
18 Debtor's ability to deposit funds into and to withdraw funds from said account(s); and
19 F. Such additional relief as the Court deems just and proper.
20 This Motion is made on the basis of the concurrently filed Declaration of Fred W.
21 Southard (the "Declaration"), the within memorandum of points and authorities, and on such
22 other evidence as may be presented to the Court prior to or at the hearing on this Motion.
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DATED: October 19, 2010
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WINTHROP COUCHOT
PROFESSIONAL CORPORATION
By: /s/ MarcJ. Winthrop
Marc J. Winthrop
Kavita Gupta
[Proposed] General Insolvency Counsel for the
Debtor and Debtor-in-Possession
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I.
2 THE NEED FOR EMERGENCY RELIEF
3 The Debtor must retain the support of its employees in order to preserve and maintain its
4 ongoing business operations. and to meet the needs of its congregation. To retain this support. the
5 Debtor must timely pay approximately $159,411 for all prepetition payroll and wage related
6 obligations owed to this constituency.
7 Payroll for employees is due on October 21, 2010 and October 28, 2010
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for salary and
8 other obligations earned prior to the filing of this case. To meet these payroll obligations, payroll
9 needs to be funded on October 21, 2010. As a result, the need for judicial relief is immediate. The
10 Debtor believes that employees will leave if they are not paid, which will cause immediate and
11 irreparable damage to the Debtor's business. In contrast, ifthe Debtor can promptly obtain the
12 relief sought herein, its business value will be preserved for the benefit of all creditors.
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A.
STATEMENT OF FACTS
The Debtor.
16 The Reverend Dr. Robert H. Schuller and his wife, Arvella, founded the Debtor in 1955.
17 At that time, it consisted of a single church, known as Garden Grove Community Church, which
18 held its services in space rented from the Orange Drive-In Theatre. The church moved to its
19 current location in Garden Grove, California in 1961, occupying a new sanctuary designed by
20 architect Richard Neutra. The campus has grov.'!l to include buildings designed by noted architects
21 such as Philip Johnson and Richard Meier.
22 The Debtor produces The Hour of Power, which is shown throughout the world and is
23 North America's longest running televised church service. Its message of"possibility thinking" is
24 also supported through its many facets, including, inter alia: (1) Pastors Sheila Schuller Coleman
25 and Dante Gebel delivery of messages of hope each Sunday. Dr. Schuller, who is 84, is the
26 featured speaker once per month; (2) providing meals for the homeless every Monday;
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The Debtor has two separate pay period tor its employees.
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(3) conducting weekly youth groups; and (4) hosting a number of weekly self-help programs. The
2 Debtor has approximately 190 full-time and part-time employees who support its many facets.
3 D. Events Precipitating Chapter 11 Filing.
4 Over the last few years, the Debtor's leadership has gone through several changes as the
5 ministry has endeavored to transition from its founders to the next generation who will carry the
6 mission of the ministry forward. Robert A. Schuller became Senior Pastor in 2006. lie ultimately
7 resigned and Dr. Sheila Schuller Coleman became the Senior Pastor in July of2009. The period
8 of unsettled leadership caused some in the congregation and viewing audience to leave the
9 ministry, resulting in reduced revenue for an organization that exists primarily on donations.
10 However, the greatest impact on the Debtor's revenues came from the severe downturn in the
11 national economy, which has had a drastic impact on donations to the Debtor and to charitable
12 giving in general. Donations were down approximately 24% in 2009 alone.
13 Since Dr. Coleman has taken over as Senior Pastor, she has managed to restore confidence
14 and enthusiasm in the ministry, which has halted the decline and produced a gradual increase in
15 both attendees and viewers. Even though the Debtor drastically cut expenses, the decline in
16 donations and other revenue was so severe that the benefits of these reductions could nut be
17 recognized quickly enongh and the Debtor's level of debt, both secured and unsecured, increased.
18 Ultimately, the Debtor decided to address the growing amount of debt by convening a general
19 meeting of creditors under the auspices of Credit Managers Association of Califomia. The meeting
20 was well attended and resulted in a voluntary 90-day moratorium on debt collection activities,
21 which was almost universally observed. Due to the need to have reliable financial information on
22 which to base an out of court repayment plan, the Unofficial Creditors Committee ("Committee")
23 granted the Debtor a 90 day extension of the moratorinm. Negotiations were well underway
24 between the Debtor and Committee when creditors sought and obtained writs of attachment and a
25 number of other lawsuits were filed against the Debtor. The negotiations between the Debtor and
26 the Committee stalled due to concern over the cash flow projections and financial reports. Given
27 these circumstances, the Committee decided to allow the moratorium to expire on October 9, 2010
28 and made a demand for payment. Cumulatively, these circumstances then forced the Debtor to file
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the present Chapter II proceeding on October 18. 2010 in order to obtain a breathing spell within
2 which to address the claims of all creditors on a fair, equitable and uniform basis.
3 The Debtor has worked very hard to reduce overhead and expenses and to identify and
4 evaluate opportunities to improve profitability. In particular, it has worked diligently to develop a
5 repayment plan for its creditors. The Debtor will continue these efforts during this Chapter II
6 case, including its ongoing negotiations with the Committee with the view towards promptly filing
7 a plan of reorganization and the pursuit of a speedy exit from Chapter II.
& c. The Debtor's li'inancial Performance.
9 The following is a summary of the Debtor's financial performance over the last
I 0 three years:
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6/30/2010
Revenue $25,264,954
Net Income (Loss) ($3,050,642)
D. The Debtor's Debt Structure.
6/30/2009 6/30/2008
$18,896,238 $26,686,756
(S6,590,436) ($7,179,726)
15 As of the petition date, Farmers & Merchants Bank of Long Beach asserts a secured claim
16 in the approximate amount of $36 million, which is purportedly secured by a lien pursuant to a
17 deed of trust recorded against the Debtor's real property. Other creditors, including, inter alia, Out
I& of Court Committee of Unsecured Creditors, Grant & BCG, Morgan Stanley, GE Capital Public
19 Finance, Inc., and National City Commercial Capital Corporation, collectively assert secured
20 claims in the aggregate approximate amount of $12 million against certain real property,
21 certificates of deposit, and equipment, among other assets, of the Debtor.
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E. The Relief Sought in this Motion.
23 The Debtor seeks Court authority to pay approximately $159,411, consisting of its
24 prepetition wage related obligations and honor its employee related prepetition benefits to
25 employees that are still employed by the Debtor. These obligations include prepetition pa)Toll,
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The Debtor is in the process of investigating the extent, validity, priority and perfection of the security interests of
these creditors. Accordingly, the D ~ b t o r n:st:rves all rights with respect thereto, and nothing contained herein or filing
in connection with this Motion should be construed as an admission with respect to the extent, validity, priority and
perfection of any creditor's security interest.
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wages, salaries, federal, state and local payroll taxes, deductions and withholdings, payroll
2 deductions relating to various benefits, reimbursement of business expenses, and miscellaneous
3 other claims asserted by current employees (including, without limitation, worker's compensation,
4 medical, dental, life insurance, and disability insurance). These benefits include vacation pay, sick
5 leave, holiday pay, jury duty pay, and other paid leave. These payments will not render
6 the estate administratively insolvent. Attached as Exhibit "1" to the Declaration is a list ofthc
7 Debtor's employees and the payroll due for each employee for the applicable pre-petition period.
8 The Debtor seeks authority to pay these pre-petition wages and salaries, which is summarized as
9 follows:
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TYPE OF EMPLOYEE
The Hour of Power &
Bathgate Ranch
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Hourly
Salary
Church
Hourly
Salary
PRE-PETITION
PERIOD
I 0/11 /I 0-10/24/10
I 0/15/10-1 0/28/l 0
10/4110-10/17/10
10/8/l 0-10/21 II 0
PAYMENT
DUE DATE
10/28/10
10/21/10
10/21/10
AMOUNT
$55,302
$15,795
$35,350
$52,964
The total amount of unpaid pre-petition employee wages and employee benefits due from
the Debtor to all of its employees, including insiders to whom no payments will be made until
further authorization is obtained, are less than $11,725 for each employee. To the extent any such
amount is in excess of$11,725 for au employee, the Debtor will pay a maximum amount of
$11,725 to such employee pursuant to an order granting this Motion.
The prepetition compensation amounts include compensation to insiders in this case,
but no payments will be made to insiders until such compensation is authorized to be paid
pursuant to the U.S. Trustee Guidelines.
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The Debtor has designated its employees into the following three categories depending on the facet of the ministry
theypetfonn services for: (I) The Hour ofPower; (2)the Bathgate Ranch: and (3) the church. The Hour of Power's
employees provide services in connection with the Debtor's telt:vi:st:d church st:rvice. The employees of Bathgate
Ranch perform services in connection with the weddings that are being held at the Bathgate Ranch. The church's
employees include ministers, musicians and other support staff for members of the congregation.
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I III.
2 GOOD CAUSE EXISTS FOR HEARING THIS
3 MOTION ON AN EMERGENCY BASIS
4 Procedural authorization for this emergency Motion is found in Rule 9006
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of the Federal
5 Rules of Bankruptcy Procedure, and in T.ocal Bankruptcy Rule 9075-1.
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The need for the Debtor to
6 pay prepetition claims of its employees is essential because the Debtor's business is dependent
7 upon its labor. If these employees are not paid, they will cease working and seek employment
8 elsewhere. Any such disruption would have a devastating effect upon the Debtor's business and
9 the Debtor's creditors. If the Debtor obtains the relief sought herein, its business operation will
I 0 continue in the ordinary course, customer needs will be met, and the overall value of the Debtor's
II business enterprise will be preserved for the Debtor's creditors. Accordingly, the Debtor submits
12 that emergency relief is both necessary and appropriate.
13 IV.
14 THE DEBTOR SHOULD BE AUTHORIZED
15 TOPAYPRE-PETITIONPAYROLL
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A. The Court May Authorize Payment of Prepetition Payroll and Honoring of
Benefits.
Bankmptcy Code Section 507(a)(4) gives priority status to allowed unsecured claims for
wages, salaries, or commissions, including vacation, severance, and sick leave pay earned by an
individual within 180 days of the petition date, up to $11,725 per individual. Specifically,
Sections 507(a)(4) and (5) provide in pertinent part:
(a) The following expenses and claims have priority in the following order:
(4) Fourth, allowed unsecured claims, but only to the extent of$11,725 for each
individual or corporation, as the case may be, earned within 180 days before the
date of the filing of the petition or the date of the cessation of the debtor's
business, whichever occurs first, for--
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Bankruptcy Rule 9006(c) provides, in pt:rlint:nt part: "wht:n an ar.;t is required or allowed to be done at or within a
specified time by these rules or be a notice given thereunder or by order of the court, the court for cause shown may in
its discretion with or without motion or notice order the period reduced."
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Rule 9075-l(a) and (b) of the Local Bankruptcy Rules for the Central District of California provides for hearings on
an emergency basis or, alternatively, on notice shorter than would otherwise be required under the Local Bankruptcy
Rules.
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(A) wages, salaries, or commissions, including vacation, severance, and sick
leave pay earned by an individual;
(5) Fifth, allowed unsecured claims for contributions to an employee bendit
plan-
( A) arising from services rendered within 180 days before the date of the filing
of the petition for the date of the cessation of the debtor's business, whichever
occurs !Irs!, but only
(B) for each such plan, to the extent of-
(i) the number of employees covered by each such plan multiplied by $11,725;
less
(ii) the aggregate amount paid to such employees under paragraph (4) of this
subsection, plus the aggregate amount paid by the estate on behalf of such
employees to any other employee benefit plan.
10 II U.S.C. 507(a)(4)and(5).
11 Courts have consistently authorized the payment of prepetition priority wages and other
12 debt in !he absence of a plan of reorganization, where such payments create "the greatest likelihood
13 of payment of creditors in full or at least proportionately." See Matter of Columbia Gas, 171 B.R.
14 189, 191-92 (Bankr. D. Del. 1994); In re Lehigh & New England Ry. Co., 657 F. 2d 570, 581 (3d
15 Cir. 1981); Ionosphere Club, 98 B.R. 174, 178-179 (Bankr. S.D.N.Y. 1989); In re Structurlite
16 Plastics Com., (Structurlite I) 86 Bankr. 922, 932 (Bankr. S.D. Ohio 1988), citing In re Chateaugay
17 QQm., 80 Bankr. 279,287 (S.D.N.Y 1987); see also In re Adams Apple. Inc., 829 F.2d 1484 (9th
18 Cir. 1987).
19 Courts have also authorized Chapter II debtors to honor prepetition employee benefits.
20 See Matter of Canton Casting, Inc., 103 B.R. 874, 875-876 (Bankr. N.D. Ohio 1989) (authorizing
21 payment ofprepetition vacation benefits); Inre Busy Beaver Bldg. Centers. Inc., 19 F.3d 833, 853
22 (3d Cir. 1994) ("!he bankmptcy court entered numerous interim orders ... aulhorizing ... the
23 payment of pre-petition wages and employee benefits ... "); lnre Chateaugay Com., 80 B.R. at 281
24 ("Judge Lifland, upon application of LTV, issued an order authorizing and empowering LTV to
25 continue payment of pre-petition wages and salaries, employee reimbursement expenses, and
26 benefits.").
27 As set forth above, Section 507(a)(4) affords priority status to unsecured claims for wages,
28 salaries or commissions, including vacation, severance, and sick leave pay earned by an individual
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within 180 days before the filing of a bankruptcy petition to the extent of$11, 725 for each such
2 individuaL For a number of reasons, the Bankruptcy Code affords special treatment to certain
J pre-petition claims of employees. Wages arc priority claims, and thus must be paid in full in order
4 to confirm a plan. The ability to ensure that the employees receive their unpaid prepetition salary
5 and do not miss a paycheck is critical to preserve the going concern value of the Debtor's business
6 and maximize value in this case. Compared with a typical claim in bankruptcy, wages represent a
7 large part of an employee's wealth. In addition, unlike an ordinary trade creditor, the typical
8 employee does not have other sources of income and, thus, cannot diversify the risk of the
9 employer's default. Therefore, this Court has authority to allow the Debtor to pay certain
I 0 prepetition claims.
II In the within case, ample cause exists justifying payment of the prepetition period wages.
12 Specifically, as evidenced by the Declaration, the maximization of the value of the Debtor is
13 contingent upon the continued operation of the Debtor's business. Since the loss of any employee
14 at this critical juncture could materially damage the Debtor's business operations, and
15 consequently the value of its overall business enterprise, compelling grounds exist for the entry of
16 an order authorizing the Debtor to pay and/or honor the prepetition employee wages and
1 7 compensation in the amounts established by the Declaration.
18 Consequently, it is critical that the Debtor continues, in the ordinary course, those personnel
19 policies that were in effect prior to the petition date. If the checks issued by a payroll service in
20 payment of any of the compensation or other employee obligations are dishonored, or if such
21 obligations are not timely paid postpetition, the employees may suffer extreme personal hardship
22 and may be unable to pay their daily living expenses. A loss of employee morale and goodwill at
23 this crucial juncture would undermine the Debtor's stability, and undoubtedly would have a
24 negative effect on the Debtor, its congregation, the value of its assets and business, and its ability to
25 achieve its objectives in Chapter 11. As noted by the court in In re Egualnet Communications
26 Com., 258 B.R. 368 (Bankr. S.D. Tex. 2000), "the need to pay [pre-petition employee wage claims]
27 in an ordinary course of business time frame is simple common sense. Employees are more likely
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to stay in place and to refrain from actions which could be detrimental to the case and/or the estate
2 iftheir pay and benefits remain intact and uninterrupted." Id. at 370.
3 Nothing in this Motion nor any payments made by the Debtor pursuant to this Motion,
4 shall be deemed an assumption or rejection of any employee benefit plan, employment agreement,
5 other program or contract, or otherwise aflect the Debtor's rights under Section 365 of the
6 Bankruptcy Code to assume or reject any executory contract between the Debtor and any
7 employee ur any payroll service.
8 Therefore, the Debtor believes that, unless the Court allows the payments requested herein
9 to its employees, the disruption to the Debtor's employees and business practices would
I 0 substantially jeopardize the Debtor's ability to reorganize its affairs.
11 B. All ofthe Cash Payments in Question Represent Payment of Priority Claims.
12 All of the payments in question constitute priority claims pursuant to Sections 507(a)(4)
13 and (a)(5) of the Bankruptcy Code, and are therefore more likely to be paid in any event. The
14 Debtor is unable to determine whether all vacation, severance and sick leave pay earned by
15 employees within 180 days of the petition date or whether contributions to employee benefit plans
16 arise from services rendered within 180 days of the petition date. However, none of the payroll
1 7 checks will exceed this limit.
18 Since all priority payments must be made eventually before general unsecured claims can
19 be paid, courts often permit payment of pre-petition wages so that the debtor-in-possession may
20 maintain an effective workforce, especially where the amount of the payment is relatively small
21 and where it appears that the wages being paid would ultimately quality as priority claims. In re
22 Quality Interiors, 127 B.R. 391, 396 (Bankr. N.D. Ohio 1991), citing 11 U.S.C. 507. The Debtor
23 believes that all of the subject prepetition wages, as well as claims for vacation and sick leave
24 benefits and other related benefits, constitute priority claims pursuant to the provisions of
25 Sections 507(a)(4) and (a)(S), which will be paid by the Debtor's estate in any event.
26 Consequently, there is ample authority and legal justification for authorizing the Debtor to honor
27 its wage and benefit commitments to current employees to the extent that they constitute
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pre petition obligations, as they are relatively small amounts and likely within priority limits in any
2 event.
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4 NOTICE OF THE MOTION IS ADEQUATE
5 The Debtor has served a copy of this Motion on its secured creditors, the unsecured
6 creditors holding the 20 largest claims against the Debtor, and the Office of the United States
7 Trustee. The Debtor respectfully submits that such notice is appropriate and comports with the
8 requirements ofthe Federal Rules of Bankruptcy Procedure and the Local Bankruptcy Rules. See,
9 Fed. R. Bankr. P. 2002, Fed. R. Bankr. P. 9006(c), and Local Bankruptcy Rule 9075-l(a).
10 VI.
II CONCLUSION
12 Based on the foregoing, the Debtor respectfully requests that the Court grant the relief
13 requested herein, and such other and further relief as the Court may deem just and proper.
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DATED: October 19,2010 WINTHROP COUCHOT
PROFESSIONAL CORPORATION
By:. _ __,_,/s.,_/ "'M-"a""r"'c W=ir"'rt"'hr"-'o"'p'--------
Marc J. Winthrop
Kavita Gupta
[Proposed] General Insolvency Cow1sel for the
Debtor and Debtor-in-Possession
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NOTE. When using this form to indicate service of a proposed order, DO NOT list any person or entity m 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., 4th Fl., Newport Beach, CA 92660.
A true and correct copy of the foregoing document described as: NOTICE TO CREDITORS AND
PARTIES IN INTEREST OF HEARING ON "FIRST DAY MOTIONS" 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")- 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 October 19, 2010, 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:
Frank Cadigan frank.cadigan@usdoj .gov
United States Trustee (SA) ustpregionl6.sa.ecf@usdoj.gov
Marc J Winthrop mwinthrop@winthropcouchot.com, pj@wintlrropcouchot.com
D Service information continued on attached page
II. SERVED BY U.S. MAIL OR OVERNIGHT MAIL( indicate method for each person or entity served):
On October 19. 2010 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 completed no later
than 24 hours after the document 1s filed.
18] Service information continued on attached page
Ill. SERVED BY PERSONAL DELIVERY. FACSIMILE TRANSMISSION OR EMAIL (indicate method for
each person or entity served): Pursuant to F.R.Civ.P. 5 and/or controlling LBR,
- 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
constitutes a declaration that personal delivery on the judge will be completed no later than 24 hours after
the document is filed.
D Service information continued on attached page
I declare under penalty of perjury under the laws of the United States of America that th oregoing is true
and correct.
October 19, 2010 Viann Corbin
Date Type Name
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C1ystal CatheJral Ministries
Atln: Fred Southard. CFO
13280 Chapman Ave.
Garden Grove. CA 92840-4414
Out of Court Committee
Nanette D. Sanders, Esq
Rmgstad & Sanders LLP
2030 Main Slreel, Suite 1200
Irvine, Ci\ 92614
F&M 11ank of Long Beach
9 r/o Lawrcm:e C. Meyerson,
57R Hlvd., #R67
10 Marina Del Rey, CA 90292
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20 LARCEST
PNCEF. LIE
Attn: Marshilll f. Goldberg. Esq.
21700 Oxnard SL, #430
Woodland I !ills. CA 91367-3665
Promotional Media
Attn: Denise Rodourinkoch
727 N. Main St.
Orange, C/\ 9286&
lnfocision Management Corp.
Attn: Corp<1rate Officer
325 Springsldc Dr.
Akron. OH 44333
\1cdia Services Agency
Alln: John Cas0ria
P 0. Box 11901
Santa Ana. CA 92711
SERVICE VIA OVERNIGHT DELIVERY
Lnited States Trustee's Office
Att11: Frank Cadigan. Csq
4 I I West fourth St, #9041
Santa Am, CA 9270 I
Credit Managers Association
Attn: Charles Klaus
40 East Verdugo Ave.
Burbank, CA 91502
20 LARGEST
lJaystar 1 elevision Network
Att11: Corporate Officer
3901 Highway 121
Bedford, TX 76021
Gipson Hornnan & Pancione
Atln: Robe1 t E. Gipson
1901 AvenueofthcStars#IIOO
Los Angeles, CA 90067-6002
Lutzkcr & Lutzkcr. LLP
1\lln: Arnie Lulzker
1233

Street NW
Suite 703
Washington, DC 20036
Classis or California- Canyon Lake
Attn: Corporate 011icer
12765 Oaks Avenue
Chino. CA 91710
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CCM
20Largest, Secured, SpeciaiNoticc
Document No. 153450
F&M Bank of l.ong Beach
c/o Michael Leight, Esq.
6700 Pacific Coast Hwy, #237
Long Beach, CA 90803
20 LARCEST
KMYQ
Tribune Television NW
Attn: Corpomte Officer
Filt 30697/P.O. nux 60000
San Francisco, CA 941 tiO
WKRC-TV
Newport Television LLC
Attn: Corporate Offieer
P.O. BllX 841646
Dallas. TX 752K4-164fi
A-I Bui I ding Maintenance, Inc.
Attn: Alan Bennett
PO. Box 80507
Rancho Santa Margarita, CA 92688-0507
Advanlage Mailing Inc.
Attn: Corpomtc Officer
1600 N. Kraemer Blvd.
CA 92806
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FGS-CA Inc.
KMSP World Markding Im:.
Attlr Angela Attn: Corporate Ollicer Attn: Rick Payne
5401 Jurupa Slreel
4614 Collection Center Dr. 14407 Alondra Blvd.
2
Ontario, CA 91761 Chicago.IL 60693 La Mirada, CA 90638
3
Lloyd Daniel Corporati(ln WKc1-1v
Thomas Nelson Publishe1
4 Alln: Chad Scalf Attn: Corporale Officer Attn: Corporale Officer
1600 S. Fedeml 1-Iwy P 0. Box 919060 2576 Momentum PI
5
Pompano Beach. FL 33062 Orlando. CA 32891-9060 Chicago. II 60689-0001
6
KWUN-TV
Scripps I Ioward Broad
7 Alln: Cl)fpflrate Otlicer dba KNXV
P.O. Box 677)46
Attr1: Corporate Officer
8
Dallas. TX 75267-7H6 P.O. Hox 116n3
Atlanta. GA 30368
9
10
1 1
UTILITY UTILITY UTILITY
12
AT&T City or Garden Grove
13 Altn: Corp01ate Oftlcer Attn: Corporate Otliccr Edison Company
Payment Center
P.O Box 3070 /\ltn: Corporate Officer
14
Sacramento, CA 95887-0001 Garden Grove. CA 92842-3070 1241 S. Grand Avenue
Santa Ana. CA 92705
15
AT & T Mobility
16 Attn: Corporate OHicer Garden Grove Disposal The Gas Company
P.O. Box (d63 Alln: Corporate Officer ALtn: Corporate Officer
17
Carol Stream, lL 60197-6463 P.O. Box 78829 P.O. Box C
Phoenix. AZ 85062-8829 Monterey Park, CA 9 J 756
18
AT & T Teleconference
19
Alln: Corporate Offtcer Waste Management ofOC Cox Communication
P.O. Box 28-10 Attn: Corporate OHicer
Attn: Corporate Orficer
20
Omaha, :.JE 68103-2840 P.O. Box 78251 P.O. Box 53280
Phoenix. AZ 85062-8251 Phoenix, AZ 85072-3280
21
22
City of Orange
Attn: Corporate omecr Tclcpacilic Communications Vcrizon Wireless
P.O. Box 30146 J\Un: Corporate Officer Attn: Corporate Officer
23
Los Angeles. CA 90030-0146 P.O. Box 526015 P .0. Box 9622
Sacmmcnto. CA 95852-6015 Mission Hills, CA 91346-9622
24
25
CR & R Incorporated
Attll" Corporate Officer
P.O. Box 206
26
Stanton, C/\ 90680
27
28
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