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009589.0024\4654358.2 DEC. OF ELIZABETH BERKE-DREYFUSS 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 ELIZABETH 

BERKE-DREYFUSS IN SUPPORT OF 

RECEIVER’S AND MONITOR’S 

ADMINISTRATIVE MOTION FOR 

ORDER AUTHORIZING EMPLOYMENT 

OF PROFESSIONALS 

Case 3:17-cv-00223-RS Document 103-7 Filed 04/06/17 Page 1 of 4
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009589.0024\4654358.2 DEC. OF ELIZABETH BERKE-DREYFUSS 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, Elizabeth Berke-Dreyfuss, declare: 

1. I am an attorney licensed to practice law by the State of California, admitted to 

practice before this Court, and am a partner with the law firm of Wendel, Rosen, Black & Dean 

LLP (“Wendel Rosen”), the proposed counsel of record for Susan L. Uecker, the Receiver and 

Monitor herein. The following facts are true of my own personal knowledge and if called upon to 

do so, I would and could testify there, except as to those matters that are alleged upon information 

and belief, and as to those matters, I believe them to be true. 

2. The Wendel Rosen attorneys to provide substantive legal work on the matter are 

admitted to practice before the State Bar of California, the State Courts and District Courts and are 

experienced receivership and insolvency, litigation attorneys and real estate transactional counsel. 

Wendel Rosen represented the Receiver in the State Court Action.1

 Wendel Rosen has performed 

a conflict check and Wendel Rosen and its attorneys are not an attorney for or associated with or 

employed for any party to this action, except that Wendel Rosen represented the Receiver in a 

representative capacity in other matters that are unrelated to this action, and as previously stated, 

represented the Receiver in the State Court Action as the Receiver for the CallSocket Entities. 

3. I am a partner with over 32 years’ experience in representing trustees and receivers 

in a broad range of bankruptcy and insolvency matters for businesses and individuals. I have 

substantial experience in Chapter 7, Chapter 11 cases and receivership cases, including avoidance 

actions (preferences and fraudulent transfers) and was the attorney who represented the Receiver 

in the State Court Action. 

4. Tracy Green, also one of the firm’s partners, with over 32 years’ experience in the 

insolvency related practice, has represented trustees and creditors in avoidance actions (fraudulent 

conveyances, preferences, and equitable subordination). 

5. C. Gregg Ankenman, another of the firm’s partners, specializes in real estate and 

business transactional work, including commercial real estate leases, sales, exchanges, and 

 

1

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

Court (“State Court Action”). 

Case 3:17-cv-00223-RS Document 103-7 Filed 04/06/17 Page 2 of 4
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009589.0024\4654358.2 DEC. OF ELIZABETH BERKE-DREYFUSS 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 

financing. Mr. Ankenman handled each of the CallSocket Entity real estate sales in the State 

Court Action. 

6. Thiele Robin Dunaway, another of the firm’s partners, is a litigator with 30 years’ 

experience litigating disputes involving various business contract, commercial loan documents, 

deeds of trust, and title to real property. A particular focus of her practice is on appellate work in 

both state and federal courts. Ms. Dunaway handled each of the appeals and writs of mandate 

filed by the CallSocket Entities in the State Court Action. 

7. Jason Horst and Katherine Kao are each commercial business litigators with 11 and 

7 years’ experience respectively. 

8. The hourly rates for each of the Wendel Rosen attorneys are as follows: 

Attorney Practice Hourly Rate 

Elizabeth Berke-Dreyfuss 

Partner 

Receivership, 

Insolvency, Litigation 

$520 

Tracy Green 

Partner 

Receivership, 

Insolvency, Litigation 

$520 

C. Gregg Ankenman 

Partner 

Real Estate Leasing 

and Sales 

$550 

Thiele R. Dunaway 

Partner 

Litigation $500 

Jason Horst 

Associate 

Litigation $395 

Katherine Kao 

Associate 

Litigation $375 

9. Wendel Rosen also employs paralegals that range in hourly rates from $135 to 

$275, depending on experience. Wendel Rosen’s fees typically adjust annually on January 1. 

Wendel Rosen charges its costs as actual costs. Wendel Rosen 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. 

10. I expect to serve as lead counsel, and will provide legal advice relating to the 

administration of the instant receivership, including in connection with all necessary discovery and 

Case 3:17-cv-00223-RS Document 103-7 Filed 04/06/17 Page 3 of 4
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009589.0024\4654358.2 DEC. OF ELIZABETH BERKE-DREYFUSS 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 

Receivership Asset recovery efforts and the Monitor Reports, prepare all pleadings to be filed 

with the Court, and will coordinate all necessary legal services. To the extent that additional 

services are necessary, Mses. Green and Dunaway will assist me. After the Receiver has 

formulated the Recovery Plan, and litigation has commenced, I will be supported in the litigation 

by Mses. Green, Dunaway, Kao and Mr. Horst. All lower level discovery and litigation will be 

handled by associates. Mr. Ankenman will work exclusively on sales of real property should the 

need arrive. Wendel Rosen will ensure that there is no duplication of services. The biographies of 

Mses. Berke-Dreyfuss, Green, Dunaway, Kao and Messrs. Horst and Ackenman are attached 

hereto as Exhibits A, B, C, D, E and F.

11. Pursuant to Local Rule 7-11(a), filed concurrently herewith is the Stipulation As To 

Receiver’s And Monitor’s Administrative Motion For Order Authorizing Employment Of 

Professionals (“Stipulation”). Attached hereto as Exhibit G is a true and correct copy of an email 

that I sent to all counsel appearing in this matter for each of the defendants and the SEC. All 

counsel with the exception of two have signed the Stipulation. Patrick Freeman of Valle Makoff 

LLP, counsel for San Francisco Regional Center, LLC; California Gold Medal, L.P.; NA3PL, 

L.P.; West Oakland Plaza, L.P.; Immedia, LLC, did not oppose the motion, but could not sign the 

Stipulation under the terms of Paragraphs 7 and 8 of the Appointment Order, which provided that 

the Receiver assumed control over the received Defendants and Relief Defendants and dismissed 

the agents of those entities. Attached hereto as Exhibit H is a true and correct copy of Mr. 

Freeman’s email to me. Mr. Gilbert Serota of Arnold & Porter Kaye Scholer LLP, counsel for 

defendant Thomas Henderson did not respond to my email as of the date of this declaration. 

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

declaration was executed on the 6th day of April, 2017 at Oakland, California. 

/s/ Elizabeth Berke-Dreyfuss Elizabeth Berke-Dreyfuss 

Case 3:17-cv-00223-RS Document 103-7 Filed 04/06/17 Page 4 of 4