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Case 14-32819-JKO

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UNITED STATES BANKRUPTCY COURT


SOUTHERN DISTRICT OF FLORIDA
FT. LAUDERDALE DIVISION
www.flsb.uscourts.gov

In re:

Case No.: 14-32819-JKO


(Jointly Administered)

US CAPITAL/FASHION MALL, LLC, et al.,


Chapter 7
Debtors.
_______________________________________/
NOTICE OF FILING AFFIDAVITS
IN SUPPORT OF DUANE MORRISS RESPONSE TO
ORDER DIRECTING DUANE MORRIS TO SUBMIT PAPERS
DUANE MORRIS LLP, by and through undersigned counsel and in support of Duane
Morriss Response to Order Directing Duane Morris to Submit Papers [ECF #246], files the
following Affidavits:
1.

Second Affidavit of Kevin E. Vance, attached hereto as Exhibit A;

2.

Second Affidavit of Rebecca L. Guillou, attached hereto as Exhibit B; and

3.

Affidavit of Connie Graver, attached hereto as Exhibit C.

Dated: February 13, 2015.

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Case No.: 14-32819-JKO

Respectfully submitted,
We hereby certify that we are admitted to the Bar of the United States
District Court for the Southern District of Florida and are in compliance
with the additional qualifications to practice in this court set forth in
Local Rule 2090-1(A).

STEARNS WEAVER MILLER WEISSLER


ALHADEFF & SITTERSON, P.A.
Counsel for Duane Morris, LLP
Museum Tower, Suite 2200
150 West Flagler Street
Miami, Florida 33130
Telephone: (305) 789-3200
Facsimile:
(305) 789-3395
By:

/s/ Drew M. Dillworth


DREW M. DILLWORTH
Florida Bar No. 167835
ddillworth@stearnsweaver.com
DAVID C. POLLACK
Florida Bar No. 362972
dpollack@stearnsweaver.com

CERTIFICATE OF SERVICE
I CERTIFY that on February 13, 2015, I electronically filed the foregoing document with
the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served
this day by transmission of Notices of Electronic Filing generated by CM/ECF to those parties
registered to receive electronic notices of filing in this case, as indicated on the attached Service
List.
By:

/s/ Drew M. Dillworth


DREW M. DILLWORTH

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Case No.: 14-32819-JKO

SERVICE LIST
Electronic Mail Notice List
The following is the list of parties who are currently on the list to receive email notice/service for
this case, and should have been served by Notice of Electronic Filing generated by the Courts
CM/ECF system:

Joaquin J Alemany
joaquin.alemany@hklaw.com
jose.casal@hklaw.com

Valerie Barton Barnhart


vbarnhart@kelleykronenberg.com
jgardella@kelleykronenberg.com
sosber@kelleykronenberg.com

Becket and Lee LLP


notices@becket-lee.com

Richard E Berman
reb@bermankean.com
deannel@bermankean.com

Timothy R Bow
tbow@mrthlaw.com
jgarey@mrthlaw.com
ycandia@mrthlaw.com
mrthbkc@gmail.com
ecfnotices@mrthlaw.com

Daniel DeSouza
ddesouza@desouzalaw.com

Drew M Dillworth
ddillworth@stearnsweaver.com
mfernandez@stearnsweaver.com
bank@stearnsweaver.com
rross@stearnsweaver.com
dillworthcdp@ecf.epiqsystems.com
cgraver@stearnsweaver.com

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Case No.: 14-32819-JKO

Jeffrey R Eisensmith
je@eisensmithlaw.com

Michael J Friedman
mfriedman@vlplaw.com

John C Hanson
jhanson@barthet.com

Jason Z. Jones
jjones@joneslawpa.com

Mark A Levy
mark.levy@brinkleymorgan.com
sandra.gonzalez@brinkleymorgan.com
brinkleymorganecf@gmail.com

Nicole L Levy
nllevy@duanemorris.com
LRTaseff@duanemorris.com
dperez@duanemorris.com
YArnavatParga@duanemorris.com
shmarder@duanemorris.com
DiMassa@duanemorris.com
LJKotler@duanemorris.com

Charles H Lichtman
clichtman@bergersingerman.com
lwebster@bergersingerman.com
efile@bergersingerman.com

Brett D Lieberman
blieberman@messana-law.com
thurley@messana-law.com
emair@messana-law.com
nbarrus@messana-law.com
tmessana@messana-law.com
tmessana@bellsouth.net

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Case No.: 14-32819-JKO

Jerry M Markowitz
jmarkowitz@mrthlaw.com
rrubio@mrthlaw.com
mrthbkc@gmail.com
gruiz@mrthlaw.com
ycandia@mrthlaw.com

Thomas M. Messana
tmessana@messana-law.com
emair@messana-law.com
blieberman@messana-law.com
thurley@messana-law.com
tmessana@bellsouth.net
nbarrus@messana-law.com
ekates@bakerlaw.com
jmooremaley@messana-law.com
tzeichman@messana-law.com

Glenn D Moses
gmoses@gjb-law.com
gjbecf@gjb-law.com
chopkins@gjb-law.com
vlambdin@gjb-law.com

Office of the US Trustee


USTPRegion21.MM.ECF@usdoj.gov

Chad S Paiva
chad.paiva@gmlaw.com
katrina.bankert@gmlaw.com

Alan J. Perlman
aperlman@ralaw.com
mhannau@ralaw.com

Grace E. Robson
grobson@mrthlaw.com
jgarey@mrthlaw.com
mrthbkc@gmail.com
sramirez@mrthlaw.com
5

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Case No.: 14-32819-JKO

Michael E Rothenberg
michael.rothenberg@hklaw.com
joaquin.alemany@hklaw.com

Michael L Schuster
mschuster@gjb-law.com
gjbecf@gjb-law.com
mchang@gjb-law.com
scomer@gjb-law.com

Steven J. Solomon
steven.solomon@gray-robinson.com
lnegron@gray-robinson.com
lauren.rome@gray-robinson.com
Amador.Ruiz-Baliu@gray-robinson.com

Kevin E. Vance
kevance@duanemorris.com
cmackey@duanemorris.com
pnmendoza@duanemorris.com

Kenneth A Welt
fl10@ecfcbis.com
pacerfilings@gmail.com
kaw@trustesolutions.net
court@trusteeservices.biz

#4039477 v1

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EXHIBIT A

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COMPOSITE EXHIBIT 1

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EXHIBIT B

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SECOND AFFIDAVIT OF REBECCA L. GUILLOU


Rebecca L. Guillou, being duly sworn, deposes and says:

1.

I am a paralegal in the trial department in the Miami office of Duane Monis LLP.

I make this affdavit on personal knowledge. If called as a witness I would competently testify to
the facts set forth herein.

2.

In my first aff,rdavit f,rled January 22,2015 IDE 192-51,I stated:

I did not use E-orders to upload any stipulation or proposed


directly

agreed order

to the Judge. I filed everything with Pacer, and all counsel of

record were served by email via ECF.

3.
I

That assertion was true to the best of my knowledge, information, and belief when

signed my affidavit on January 20,

2015. I had no reason to doubt the accuracy of my

statement until the moment during the January 27 hearing when the Judge read, from an EOrders Transaction Repoft, that the Amended Agreed Order on Ganglu's motion for relief from
the automatic stay had been uploaded to E-orders at 14:56:40 on November 3,2014. Even then,

I did not believe that I was the person who had uploaded the Amended Agreed Order.

4.

have been a litigation paralegal since 1994.

have extensive experience

electronically filing documents in the United States District Courl for the Southern District of
Florida and in Florida state courts.

5.

On Thursday, October 30, 2014, Dawn Perez, another litigation paralegal in

Duane Morris's Miami offrce, told me that she would be out the next day (Halloween) to spend

time with her daughter, and would also be out the following Monday and Tuesday, November
and

4.

As is our practice when one of us plans to be absent from the office, Ms. Perez and I

discussed which

of her matters I might have to cover for her. She mentioned (among other

cases) Mapuche and its related bankruptcy cases, and she said

if there were filings, I could log on

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to the bankruptcy court's CM/ECF system via PACER, but that the log-on system and password
were different than the District Court's. She gave me Kevin Vance's log-in credentials.

6.

On Monday, November 3, 2014, Ms. Rodriguez-Taseff asked me to file

the

Stipulation on Motion for Relief from the Automatic Stay and its Exhibit A, an Agreed Order.

Using Mr. Vance's password and for the first time in my career,

accessed the Bankruptcy

Court's CM/ECF system. It looked somewhat different than the District Court's system, as Ms.
Perez had told me

it would. I was confident that my years of experience on the District Coutl's

CM/ECF site would enable me to figure out how to f,rle the documents.
navigating around the system, but when

signed off,

I had some issues

was equally conf,rdent that

successfully accomplished what Ms. Rodriguez-Taseff had asked me to do

had

- file the Stipulation

and the Agreed Order.

7.

A little while later, the Trustee's

counsel communicated some changes to the

Agreed Order, and the lawyers agreed to the form of an Amended Agreed Order. In an email at

2:41 PM onNovember 3, 2014, the Trustee's counsel asked me to file it, and by reply email at
2:49 PM,I wrote,

"l will file the Amended

that contains those two emails is Exhibit

8.

Agreed Order, shoftly." A copy of the email thread

I to this affidavit.

In my first affidavit, I reported (at paragraph 2)that onNovember 3, I had filed

the Stipulation, on the Bankruptcy Court's CM/ECF system twice -- first without the Agreed
Order and then with the Agreed Order.

I further reported (at paragraph 4) that later that same

afternoon, I filed a Certificate of Service with the Stipulation, the original Agreed Order, and the
Amended Agreed Order. I did not notify Mr. Vance that I was going to use his filing credentials

to file the Stipulation, the Agreed Order, or the Amended Agreed Order, and I did not

advise

him, after the fact, that I had done so. I realize that I should have advised him of the filing before
2

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I made it. In the future, before I make any electronic filing, I will obtain specific permission to
make the filing from the individual whose credentials I have been authorized to use.

9.

When

signed my first Affidavit,

did not remember that between filing

the

Stipulation and Agreed Order IDE 38, 38-1] and later filing the Certificate of Service IDE 39], I
had accessed the CM/ECF system in order to

file the Amended Agreed Order. My first affidavit

did not mention that filing because I simply did not recall it.

10.

My belief that all the documents I filed on the CM/ECF system on November

were filed in the electronic docket and emailed to all counsel by the system is reflected in how I
reported my time for that day:
111312014: numerous revisions to stipulation on motion for relief from teh

[sic] automatic stay; draft and finalize agreed order; draft and finalize
amended agreed order; file nd serve all pleudings; draft and finalize
certificate of service;
(Emphasis added). My November 3 time entry, taken from a Duane Morris print-out (with one
phrase, unrelated to

11.

filing, redacted) is Exhibit 2 to this affidavit.

On January 28,2015, the day after the hearing, Michael Silverman,

Moris's General Counsel,

asked me

Duane

to attend a meeting in one of the conference rooms in

Duane Morris's Miami office to try to figure out how someone had uploaded the Amended
Agreed Order to E-orders the aftemoon of November

3. David Pollack and Connie Graver were

also at the meeting. Mr. Silverman showed me reports that Duane Morris's I.S. department had

run that showed that

was the only person to access the Amended Agreed Order on the firm's

document management system on November 3 and also the only person to have connected to the

Bankruptcy Court's CM/ECF system that day. That is when I realized that I must have uploaded
the Amended Agreed Order, even though

I did not then, and still do not now,

SO

remember doing

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Mr. Silverman asked me to show him, Mr. Pollack, and Ms. Graver how to

use

the Bankruptcy Courl's CM/ECF system to file a document. Ms. Graver, who Mr. Silverman

told me is an expert on that system, had connected to

it on the Fitm's computer

system and

displayed the main page on a large screen in the conference room. Ms. Graver asked me to show

her how

I filed the Stipulation. I had difficulty maneuvering through

the screens and menu

me. 'With her help, I

was able to get to the

choices, most of which did not look familiar to

correct screen. Once there I knew, from my experience e-filing in District Cout1, how to attach a
PDF of the document and file it.

13.

Ms. Graver then asked me to show her how I filed the Amended Agreed Order. I

told her I did not remember. She then asked me try to figure it out. I found
"Order Upload" and clicked on

it.

a menu

option called

With Ms. Graver's help I was able to click through to the end

of the process, that is, to the screen that would permit me to file an order.

14.

The task

was assigned November 3 was to file the stipulation and the agreed

order, and later the amended agreed order. No one told me to send the original or amended order

to the judge for signature without copying the lawyers on the service list or to upload the
Amended Agreed Order to E-orders, and I did not intend to do so. Every document I file on the

District Couft's CM/ECF system is served on all counsel on the service list. I had no reason to
believe that was not also the case on the Bankruptcy Coutl's system. In District Court, when an

order is submitted to the court for signature,

it is emailed to the Judge's chambers in Word

format and copied to all counsel. I had no idea that in the Bankruptcy Court, such an order is
uploaded,

in PDF format, to the CM/ECF system, which

does not send email notice

to all

counsel.

15.

I now understand that I did not use the Bankruptcy Couft's system correctly. It
4

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I did not intend to do anything

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other than follow my instructions to file the

stipulation, agreed order, and amended agreed otder, and until my meeting with Mr. Silverman

on January 28,

believed

I had accomplished

that and only that. Because of my unfortunate

filing experience on this Court's CN,I/ECF system, I wanted to leam how to use the system
properly. I took and completed the online training on February l0 and received my certihcate of
completion on February 1 1. It is attached as Exhibit 3.

16.

Mr. Silverman has instructed that until further notice, any bankruptcy filings for

personnel in our Miami office are to be handled by an experienced bankruptcy paralegal in our
Boca Raton or Philadelphia office.

ro

tTt

-(''.

Rebecca L. Guillou

STATE OF FLORIDA

)
)ss

COUNTY OF MIAMI-DADE

The foregoing instrument


by Rebecca L. Guillou who is

trris

f6#r

to

me

Commission Number and Expiration

blic, State of Florida

DAWT PEREZ

Name

1{olary Prbllc Strte


of Florida
My Comm. Etpirss sap
20, 201 5
Commlsslon # EE r00603
Sonded

l{atlont f{otary A5sn.

#4033235 v3

{';aY

of Jamy, 2015,
C_____J produced

Notary Public

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EXHIBIT

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Guillou, Rebecca

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rom:

ient:

Guillou, Rebecca L
Monday. November 03,2014 2:49 PM

To:

'Moses, Glenn'; Schuster, Michael

Cc:

Rodriguez-Tasefl, Lida; Day, Allison


RE: Agreed Order on Motion for Relief from Autotnatic Stay.DOCX

Subject:

Hello. Thank you for clarifying. I will file the Amended

AgroecJ Order,

shortly

From : Moses, G len n Ima ilto gmose$loib-law.com I


Sent: Monday, November 03, 2014 2:41 PM
Tor Guillou, Rebecca L; Schuster, Michael
Ccr Rodrlguez-Taseff, Lida; Day, Allison
Subjech RE: Agreed Order on Motion for Relief from Automatfc Stay,DOCX
:

Hi Rebecca: The cases are being administratively consolidated, so tllere will be jLrst one caption (orrce the consolidation
order is entered), lfurther revisecl ihe proposed order (attachecJ)to refle ct that the stay rclief notion ws filed in just
Mapuche), but wll technically apply to all 3 debtors (r,'rlrich yciu worrld prol:aLlly v'ranI anyway).
I

would f ile, however, the amended exhibit in the case t was initially file d in.

(Sorry for any confusion)

-rom: Guillou, Rebecca L


[mailto:RLGuillou@duanernorris.com]
Jent: Monday, November 03/ 2014 2:16 PM
To: Moses, Glenn; Schuster, Michael
Cc: Rodriguez-Taseff, Lida; Day, Allison
RE: Agreed Order on Motion for Relief from Automatic Stay.DOCX

Sutrject:

Prior to rny filingthe ABreed Order, can you please clarify a fcw things for tne, fhs tnornng we were told by Mchael
to use the Mapuche case caption for rhe AgreerJ Order (Case No.: 14-32827) is this no lorrger correct? Anr lto file the
amendeclexhibit A in both the US Capital Fashion Mall, LLC case (14-32819)and also in the Mapuche case?

ro m

M o se

s,

G le n

I rn a ilt o : g nLo-s-qs @g

j-laW*Co-m

Sent: Monday, November 03, 2014 2:02

PM

To: Guillou, Rebecca L; Schuster, Michael


Cc: Rodriguez-Taseff, Lida; Day, Allison
Subject: RE: Agreed Order on Motion for Relief from Automatic Stay.DOCX
Plc'ase see the revisecl proposetl orcler in redline and

clean. Please subnrit the clean version as the amended exhibt A to

the stip, Ihanks.

From: Guillou, Rebecca L Imalto:RLGuillou@duanemorris,com]


Sent: Monday, November 03t 20L4 12:47 PM
To: Schuster, Michael; Moses, Glenn
Cc: Rodriguez-Taseff, Lda

Subjech Agreed Order on Motion for Relef from Automatic


iichael,

Stay.DOCX

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lreceivedyourvoicemail,PleaseseeattachedtheAgreedOrderinWord. lhavealreadyuploadedtheAgreedOrder,
with Pacer, so we will need to submit a revised Agreed Order.

Rcbccca Gulllou
Paralegal
Duane Morris l.LP
200 South tsiscayne Boulevard, Suit
3400
tvlami. FL 33131-23'18

i::.)r

lIiJ,$ irii.ili{)il

P: +1 305 960 2327


F: +1 305 397 1872

,jL{jl. [)(:tr(i lri(i:fi$. l)h)!,;j vlsii htlp://Www.DUangl,S-SSn

r)llli'r r:,!i(rii

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EXHIBIT

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Case 14-32819-JKO

r1./3/2O1.4 4536

REBECCA L. GUILLOU

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1,O2O.OO NUMEROUS REVISIONS TO STIPULATION ON MOTION FOR


RELIEF FROM TEH AUTOMATIC STAY; DRAFT AND

FINALIZE AGREED ORDER; DRAFT AND FINALIZE

AMENDED AGREED ORDER; FILE AND SERVE ALL


PLEADINGS; DRAFT AND FINALIZE CERTIFICATE OF SERVICE;

REDACTED

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EXHIBIT 3

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CMIE,CF Online Trainin


cerffies thut

Rebecca
h

GuxXu

as s ucces sfully completed

CMECF for Attorneys


und is hereby awarded this
C ertiftc ut e

CMECF T,*;*,^aTuo,

of

C o mp leto

02nu2015
Date

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EXHIBIT C

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AFFIDAVIT OF CONNIE GRAVER


Connie Graver, being duly sworn, deposes and says:
1.

I am a senior paralegal in the Bankruptcy Department at the law firm of Stearns

Weaver Miller Weissler Alhadeff & Sitterson, P.A. I make this affidavit on personal knowledge.
If called as a witness, I would competently testify to the facts set forth herein.
2.

I have completed training for the Courts Case Management/Electronic Case Files

System (ECF). I also was a participant in the Courts pilot program for agent filings. I have
routinely filed documents electronically through ECF since the Court first implemented ECF in
2005. I am fully familiar with and knowledgeable about the electronic filing of documents and
submission of orders in this Court, as well as in other bankruptcy courts and district courts.
3.

On January 28, 2015, David Pollack, a litigation partner at my firm, asked me to

attend a meeting at Duane Morris LLP later that day to assist in the investigation of certain of its
electronic filings and representations made about them in Duane Morriss Response to this
Courts Order to Show Cause [ECF #107]. Before the meeting, I reviewed the filings at issue
and noted the following errors:

The Stipulation for Relief From the Automatic Stay was filed twice, once as a
separate document without an attachment [ECF #38], and then again with the
attachment, a proposed Agreed Order [ECF #38-1]. The Court prefers that
exhibits be filed with the main document unless they are voluminous. The
Stipulation should have been filed one time, with the exhibit attached.

A Certificate of Service [ECF #39] was filed with the Stipulation, the proposed
Agreed Order, and proposed Amended Agreed Order. Pursuant to Local Rule
9004-1(D), documents filed with the court shall not have as an attachment any
document already filed in the case or proceeding.

I also noted that the proposed Amended Agreed Order, which was not served by ECF when it
was uploaded, was subsequently served by ECF when attached to the Certificate of Service [DE
39].

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At the beginning of the meeting on January 28, I met with Michael Silverman of

Duane Morris and David Pollack. I explained to them the process for electronic filings in this
Court, including the filing of a stipulation and the uploading of an order. I also demonstrated
how to query the status of an uploaded order.
5.

Mr. Silverman then asked Rebecca Guillou, a paralegal at Duane Morris, to join

us. Ms. Guillou told us that the documents she filed in this case on November 3, 2014 were the
first documents she had ever electronically filed in bankruptcy court. She also told us that
because she had previously filed documents electronically in district court, she thought she could
maneuver her way through this Courts ECF system.
6.

As the meeting continued, I discovered that Ms. Guillou had limited knowledge of

bankruptcy, did not understand how to correctly file through ECF in this Court, and did not
understand language commonly used in bankruptcy filings in this Court. For example, Ms.
Guillou did not know the meaning of an E-Order. When I explained that an E-Order is an
order uploaded in ECF that goes only to the judge for signing, she said that in her experience,
such orders are submitted to the judge via email, not filed on the ECF system. She added that
she believed that anything she did on an ECF system would be disseminated to all counsel of
record electronically.
7.

In my experience, uncontested orders are submitted to different courts in different

ways. For example, in this Court a party uploads a non-competing proposed order via ECF
under an event called Order Upload. In the District Court for the Southern District of Florida,
a party submits proposed orders to the judge by e-mail. For all divisions of the Bankruptcy
Court for the Middle District of Florida (except for Judge Funk in Jacksonville), a party submits
a proposed order via a link (https://pacer.flmb.uscourtslgov/orders/login.asp). For Judge Funk, a

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party submits an Order though ECF under an event entitled Proposed Order Judge Funk
Only.
8.

At Mr. Silvermans request, I conducted a mock electronic filing with Ms.

Guillou to try to determine how she filed the Stipulation and submitted the Amended Order. I
accessed this Courts ECF system on the computer in the conference room and displayed its
main page, pictured below, on a large screen that had been set up in the conference room.

I asked Ms. Guillou how she had filed documents electronically in Bankruptcy Court. She told
me that the main page screen did not look familiar and she did not remember what she did on the
site to file the documents. I suggested that she click on Bankruptcy in the blue banner at the
top of the screen. She did so, and the following screen, called Bankruptcy Events, opened.

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I asked Ms. Guillou how she had filed the Stipulation. She said she might have

clicked on Other. She proceeded to click Other and saw no Stipulation option on the
drop-down menu.

She returned to the Bankruptcy Events screen and clicked on

Motions/Applications. Its drop-down menu had a Stipulation option, which she clicked.
She knew how to attach her pdf document and to complete the filing (although we did not file
anything during the exercise).
10.

I then asked Ms. Guillou to show me how she had submitted the Amended

Agreed Order. She told me she did not remember. I asked her to try to figure it out. She said
she might pick Order Upload on the Bankruptcy Events menu, and asked whether that is an EOrder.

I said yes, and she clicked on it, opening the Order Upload for Bankruptcy screen

pictured below.

Case 14-32819-JKO

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Page 34 of 37

Ms. Guillou chose Upload Single and clicked on it, which opened the Single Order Upload
screen pictured below.

Ms. Guillou said she did not know what to do next. I prompted her to type in the case number in
the case number box. She did so, and got the Single Order Upload screen, with the full case
number, pictured below.

Case 14-32819-JKO

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Ms. Guillou said that the screen looked unfamiliar. I prompted her to type 38 as the related
document number; ECF # 38 is the Stipulation. Ms. Guillou typed in 38, and the drop-down
menu pictured below appeared.

11.

Ms. Guillou told me that the screen looked a little familiar, but that she did not

understand the choices and did not know which one she chose. She guessed wrong, and then
asked me to tell her. I told her she had selected the Order on Pleadings (No Hearing Required)
option. It did not refresh her recollection. I then asked whether she had received a confirmation
from ECF after she uploaded the order. She said she had gotten an email but had not saved or
printed it because she thought it was the typical notification that the Order, like the Stipulation,
had been sent electronically to all parties.
12.

Next I asked Ms. Guillou whether she could do an Order Query. She said she did

not know how, so I showed her. First, I opened the Reports screen pictured below.

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Then I clicked on the Order Query option, which opened the screen, pictured below, that
shows the status of orders that had been uploaded.

In particular, I pointed out the order next to the number 38 in the Related Doc # column. Ms
Guillou said it was now obvious to her that she had uploaded the Amended Agreed Order. She
also said that she did not realize it, intended to file it in the case docket like she had filed the
original Agreed Order, and believed she had done so.

Case 14-32819-JKO

13.

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Page 37 of 37

Ms. Guillou was gracious and cooperative throughout our discussion and filing

exercise, seemed to want

to help

answer the questions surrounding the uploading

of

the

Amended Agreed Order, and appeared sincerely apologetic about the error she made.

Connie Graver

STATE OF FLORIDA

couNTY oF MIAMI-DADE )

) ss:

BEFORE ME personally appeared Connie Graver, who is p-e.{qqgally*kqqy-ry !q e or


as identification and attests that the foregoing instrument was
who produced
acknowledged

bdayofFebruary,2015andistrueandcorrecttothebestof

her knowledge and belief. Affrant took an oath.


(Seal)

&

Notary Public, State

l[av. ta l-

I".'"ut
Printed Name of Notary Public

MARIE GRACE MASVIDAL

,,ii'iliiTi,;,'Jffi li:11
uommission

Florida

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