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009589.0024\4654282.2 DEC. OF SUSAN L. UECKER IN SUPP. OF 

RECEIVER’S AND MONITOR’S MOTION FOR 

ORDER AUTH. EMPLOY. OF PROFESSIONALS 

3:17-CV-00223-RS

Wendel, Rosen, Black & Dean LLP 

1111 Broadway, 24t h Floor 

Oakland, California 94607-4036 

Elizabeth Berke-Dreyfuss (Bar No. 114651) 

WENDEL, ROSEN, BLACK & DEAN LLP 

1111 Broadway, 24th Floor 

Oakland, California 94607-4036 

Telephone: (510) 834-6600 

Fax: (510) 834-1928 

Email: edreyfuss@wendel.com 

Proposed Attorneys for Susan L. Uecker, 

Receiver and Monitor 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

SECURITIES AND EXCHANGE 

COMMISSION, 

Plaintiff, 

vs. 

SAN FRANCISCO REGIONAL CENTER, LLC; 

THOMAS M. HENDERSON; CALIFORNIA 

GOLD MEDAL, L.P.; CALL SOCKET, L.P.; 

CALL SOCKET II, L.P.; CALLSOCKET III, 

L.P.; COMPREHENSIVE CARE OF 

OAKLAND, L.P.; NA3PL, L.P.; WEST 

OAKLAND PLAZA, L.P.; CALLSOCKET, 

LLC; CALLSOCKET II, LLC; CALLSOCKET 

III, LLC; COMPREHENSIVE CARE OF 

CALIFORNIA, LLC; IMMEDIA, LLC; and 

NORTH AMERICA 3PL, LLC,

Defendants, 

-andCALLSOCKET HOLDING COMPANY, LLC; 

CALLSOCKET III HOLDING COMPANY, 

LLC; BERKELEY HEALTHCARE 

DYNAMICS, LLC; CENTRAL CALIFORNIA 

FARMS, LLC; and JL GATEWAY, LLC, 

Relief Defendants. 

 Case No. 3:17-CV-00223-RS 

DECLARATION OF SUSAN L. UECKER 

IN SUPPORT OF RECEIVER’S AND 

MONITOR’S ADMINISTRATIVE 

MOTION FOR ORDER AUTHORIZING 

EMPLOYMENT OF PROFESSIONALS 

Case 3:17-cv-00223-RS Document 103-2 Filed 04/06/17 Page 1 of 5
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009589.0024\4654282.2 DEC. OF SUSAN L. UECKER IN SUPP. OF 

RECEIVER’S AND MONITOR’S MOTION FOR 

ORDER AUTH. EMPLOY. OF PROFESSIONALS 

2 3:17-CV-00223-RS

Wendel, Rosen, Black & Dean LLP 

1111 Broadway, 24t h Floor 

Oakland, California 94607-4036 

I, Susan L. Uecker, declare: 

1. I am the duly appointed the duly appointed receiver and monitor (the “Receiver” 

and “Monitor”) for Defendants San Francisco Regional Center, LLC; California Gold Medal, L.P.; 

CallSocket, L.P.; CallSocket II, L.P.; CallSocket III L.P.; NA3PL, L.P.; West Oakland Plaza, L.P.; 

CallSocket, LLC; CallSocket II, LLC; CallSocket III, LLC; Immedia, LLC; and Relief Defendants 

CallSocket Holding Company, LLC; CallSocket Holding III Holding Company, LLC; Central 

California Farms, LLC; and JL Gateway, LLC (collectively the “Receivership Entities”), and 

monitor Defendants’ Comprehensive Care of California, LLC; Comprehensive Care of Oakland, 

L.P. and North America 3PL, LLC, and relief Defendants Berkeley Health Care Dynamics, LLC 

(“Monitor Entities”) pursuant to the Court’s Order Appointing Receiver and Monitor entered 

herein on March 29, 2017 (“Appointing Order”)(Docket No. 100). The following facts are true of 

my own personal knowledge and if called as a witness, I would and could competently testify 

thereto, except as to those matters that are alleged upon information and belief, and as to those 

matters, I believe them to be true. I make this declaration in support of my Administrative Motion 

for Order Authorizing Employment of Professionals. 

2. I respectfully request that the Court enter an Order authorizing me and to employ 

and compensate: (1) Uecker & Associates, Inc. to provide project management, bookkeeping, 

reporting and staffing (“Uecker & Associates”); (2) the firm of Wendel, Rosen, Black & Dean 

LLP (“Wendel, Rosen”), as my general receivership counsel; (3) the firm of Baker Dondelson 

(“Baker Donelson”), as my EB-5 immigration counsel;(4) Akawie & LaPietra, Professional 

Corporation (“Akawie & LaPietra”) as my leasing counsel; and (5) Bachecki, Crom & Co., LLP 

(“Bachecki Crom”) CPAs, as my forensic accounting and tax preparation professionals 

(collectively, “Professionals”). Under the terms of the Appointing Order, I am authorized to 

engage the same Professionals as I employ as Receiver. I am requesting the Court authorize and 

Case 3:17-cv-00223-RS Document 103-2 Filed 04/06/17 Page 2 of 5
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009589.0024\4654282.2 DEC. OF SUSAN L. UECKER IN SUPP. OF 

RECEIVER’S AND MONITOR’S MOTION FOR 

ORDER AUTH. EMPLOY. OF PROFESSIONALS 

3 3:17-CV-00223-RS

Wendel, Rosen, Black & Dean LLP 

1111 Broadway, 24t h Floor 

Oakland, California 94607-4036 

approve the engagements and compensation of each of the Professional in accordance with the 

terms presented in the Motion. 

3. In my capacity as both the Receiver and Monitor, I seek to employ Uecker & 

Associates to perform certain in-house staffing services that permit me to fulfil my duties and 

responsibilities as both the Receiver and Monitor. The Associate/Project Manager works under 

my direction on all aspects of the case, such as asset analysis, asset disposition, business 

operations, case administration, claims work, investor communications, preparing reports. The 

Accounting Staff prepares daily, weekly and monthly accounting reports for all projects, works 

with the outside accountant and tax professionals on information for tax work and forensic 

accounting. General Staff provides miscellaneous services such as sending notices and reports and 

website updates. The hourly rates for the proposed engagement of Uecker & Associates are as 

follows: 

Associate/Project Manager Hourly Rate $200.00 

Accounting Hourly Rate $100.00 

General Staff Hourly Rate $ 50.00 

4. Uecker & Associates charges its costs as actual costs. Uecker & Associates will 

seek compensation in compliance with the terms of the Appointment Order and agrees to bill its 

fees and costs in this case in accordance with the Billing Instructions for Receivers in Civil 

Actions Commenced by the U.S. Securities and Exchange Commission, and upon application and 

approval by the Court. 

/ / / 

/ / / 

/ / / 

Case 3:17-cv-00223-RS Document 103-2 Filed 04/06/17 Page 3 of 5
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009589.0024\4654282.2 DEC. OF SUSAN L. UECKER IN SUPP. OF 

RECEIVER’S AND MONITOR’S MOTION FOR 

ORDER AUTH. EMPLOY. OF PROFESSIONALS 

4 3:17-CV-00223-RS

Wendel, Rosen, Black & Dean LLP 

1111 Broadway, 24t h Floor 

Oakland, California 94607-4036 

5. Pursuant to the terms of the Appointment Order, in my capacity as Receiver and 

Monitor, I seek to engage and compensate Wendel Rosen to represent me in this matter as general 

receivership counsel. Wendel Rosen represented me in the State Court Action.1

6. Pursuant to the terms of the Appointment Order, in my capacity as Receiver, I seek 

to engage and compensate Akawie & LaPietra, specifically, Gregory S. Nerland, as my counsel to 

deal with issues related to leases involved with the Receivership Assets. Mr. Nerland represented 

me in the State Court Action for leasing matters for the purpose of bringing unlawful detainer 

matters. 

7. Pursuant to the terms of the Appointment Order, in my capacity as Receiver and 

Monitor, I seek to engage and compensate Baker Donelson as EB-5 immigration counsel. While 

Baker Donelson is a full service law firm, I am retaining Baker Donelson solely with respect to its 

immigration practice. Baker Donelson’s Immigration Practice is nationally recognized for its 

specialty in the EB-5 program and investors. Specifically, I seek to retain Robert C. Divine, a 

shareholder of Baker Donelson. Baker Donelson represented me in the State Court Action as my 

EB-5 immigration counsel. 

8. Pursuant to the terms of the Appointment Order, in my capacity as Receiver and 

Monitor, I seek to employ and compensate Bachecki Crom to prepare and file tax returns; to 

prepare tax projections and perform tax analysis; to analyze the tax impact of potential 

transactions; to testify as to accounting and financial issues; to prepare a forensic accounting of the 

transfers among the various received entities and monitored entities; and to consult with me and 

my counsel as to those matters. Bachecki Crom represented me in the State Court Action as my 

tax accountant. 

 

1

 Young v. Henderson, Case No. RG15778891, pending before the Alameda County Superior 

Court (“State Court Action”). 

Case 3:17-cv-00223-RS Document 103-2 Filed 04/06/17 Page 4 of 5
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009589.0024\4654282.2 DEC. OF SUSAN L. UECKER IN SUPP. OF 

RECEIVER’S AND MONITOR’S MOTION FOR 

ORDER AUTH. EMPLOY. OF PROFESSIONALS 

5 3:17-CV-00223-RS

Wendel, Rosen, Black & Dean LLP 

1111 Broadway, 24t h Floor 

Oakland, California 94607-4036 

I declare under penalty of perjury that the foregoing is true and correct and that this 

declaration was executed on the 5th day of April, 2017 at San Francisco, California. 

/s/ Susan L. Uecker 

 Susan L. Uecker 

Case 3:17-cv-00223-RS Document 103-2 Filed 04/06/17 Page 5 of 5