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I. Background

Complete background information is set forth in the Memorandum of Decision (1) Denying Motion for Leave to Amend and (2) Denying Motion to Dismiss (the “Memorandum”).3 Information in the Memorandum is restated herein only to the extent necessary to address the

1 Doc. No. 80. 2 Unless otherwise indicated, all “Civil Rule” references are to the Federal Rules of Civil Procedure, Rules 1–86; all “Bankruptcy Rule” references are to the Federal Rules of Bankruptcy Procedure, Rules 1001–9037; all “Evidence Rule” references are to the Federal Rules of Evidence, Rules 101–1103; all “LBR” references are to the Local Bankruptcy Rules of the United States Bankruptcy Court for the Central District of California, Rules 1001-1–9075-1; and all statutory references are to the Bankruptcy Code, 11 U.S.C. §§ 101–1532. 3 Doc. No. 63. arguments presented in the Motion for Reconsideration, and familiarity with the Memorandum is assumed. On August 11, 2022, the Los Angeles Superior Court (the “State Court”) entered a default judgment in favor of Plaintiff and against Defendant in the amount of $325,617.89 (the “State Court Judgment”).4 The State Court Judgment arose from Defendant’s…