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009589.0024\4648850.1 DECLARATION OF JAY D. CROM IN SUPPORT 

OF RECEIVER’S AND MONITOR’S MOTION 

FOR ORDER AUTHORIZING EMPLOYMENT 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 JAY D. CROM IN 

SUPPORT OF RECEIVER’S AND 

MONITOR’S ADMINISTRATIVE 

MOTION FOR ORDER AUTHORIZING 

EMPLOYMENT OF PROFESSIONALS

Case 3:17-cv-00223-RS Document 103-5 Filed 04/06/17 Page 1 of 2
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009589.0024\4648850.1 DECLARATION OF JAY D. CROM IN SUPPORT 

OF RECEIVER’S AND MONITOR’S MOTION 

FOR ORDER AUTHORIZING EMPLOYMENT OF 

PROFESSIONALS 

2 3:17-CV-00223-RS

Wendel, Rosen, Black & Dean LLP 

1111 Broadway, 24t h Floor 

Oakland, California 94607-4036 

I, Jay D. Crom, declare: 

1. I am a certified public accountant in the State of California, and am a partner in the 

firm of Bachecki, Crom & Co., LLP, Certified Public Accountants. The following facts are true of 

my own personal knowledge, and if called upon to do so, 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 Susan L. Uecker, 

Receiver’s and Monitor’s Motion for Order Authorizing Employment of Professionals. 

2. I have held a license as certified public accountant for over thirty-four (34) years. I 

also hold a certificate from the Association of Insolvency and Reorganization Advisors as a 

certified insolvency and reorganization advisor. I also hold a certificate as a Certified Fraud 

Examiner. Attached hereto as Exhibit A is a true and correct copy of my curriculum vitae. 

3. The accounting firm has extensive experience in providing financial investigation, 

tax preparation, insolvency and forensic accounting and financial advisory services. 

4. The normal billing rates for Bachecki Crom are as follows: 

Partners $380 - $525 / hour 

Senior Accountant $270 - $360 / hour 

Junior Accountant $165 - $260 / hour 

5. To the best of my knowledge, information and belief, Bachecki, Crom & Co., LLP, 

has no connection, except as set forth herein, with any of the parties or interested persons in the 

within receivership case, except Bachecki, Crom & Co. represented the Receiver as receiver for 

the CallSocket Entities in the State Court Action. 

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

executed the same in South San Francisco, California on April 3, 2017. 

 

/s/ Jay D. Crom 

 Jay D. Crom 

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