________________________________________

Lynn L. Tavenner, Esquire (VSB No. 30083)

Paula S. Beran, Esquire (VSB No. 34679)

David N. Tabakin, Esquire (VSB No. 82709)

Tavenner & Beran

20 North 8

th Street

Richmond, Virginia 23219

Telephone: (804) 783-8300

Telecopier: (804) 783-1078

Counsel for Lynn Lewis Tavenner, Chapter 7 Trustee

UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

Richmond Division

In re: THE LAW OFFICES OF WHITE & 

ASSOCIATES, PLLC, Case No.

Debtor 15-36223-KRH

LYNN L. TAVENNER, TRUSTEE, Chapter

Plaintiff 7

Adv. Proc No.

MARK F. WHITE,

NNIKA E. WHITE,

Defendants

VERIFIED COMPLAINT FOR INJUNCTIVE RELIEF, DAMAGES ASSOCIATED 

WITH THE WILLFUL VIOLATION OF THE AUTOMATIC STAY, AND TO THE 

EXTENT NECESSARY, RELIEF FROM THE AUTOMATIC STAY

Lynn L. Tavenner, the Chapter 7 Trustee (the “Trustee”) for the bankruptcy estate (the 

“Corporate Estate”) of The Law Offices of White and Associates, PLLC (the “Corporate Debtor”

and/or the “PLLC”), by undersigned counsel, for her complaint (the “Complaint”) against Mark 

F. White and Nnika E. White (the “Individual Debtors” and/or “Defendants”), alleges as follows:

NATURE OF THE ACTION

The Trustee, pursuant to 11 U.S.C. §§ 105, 362, 542 and Rules 7001 and 7065 of the 

Federal Rules of Bankruptcy Procedure (the “Rules”) brings this action seeking entry of an 

Order: (A) to the extent necessary, granting the Trustee relief from the automatic stay such that 

she might bring this Complaint and obtain the relief requested herein; (B) enjoining the 

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Defendants from using and/or disposing any and all corporate property, including but not limited 

to: hard drives, any storage media, desktop computers, laptop computers, servers, computer 

related equipment, server related equipment, televisions, monitors, safes and/or safe deposit 

boxes, records of cash receipts, client files both hard copy and electronic, bank statements and 

records, invoices, records of accounts receivable, all electronic data in any form located on the 

premises of the Corporate Debtor or in any off site backup location or storage facility, and any 

other materials, information, or records, both tangible and intangible related to the operation of 

the Corporate Debtor’s business affairs and/or containing information pertaining to the Corporate 

Debtor (collectively the “Corporate Property”); (C) enjoining the Defendants from discarding or 

concealing any information contained in the Corporate Property; (D) compelling the Defendants

to turnover to the Trustee the Corporate Property; (E) awarding the Trustee damages associated 

with the Defendants’ willful violation of the automatic stay. The Trustee has filed simultaneously 

herewith a Motion For Ex Parte Relief/Temporary Restraining Order (the “Ex Parte Motion”) to 

(A) obtain possession of the Corporate Property; and (B) to protect and preserve said Corporate 

Property on an ex parte basis due to the easily disposable nature of the items sought and history 

of the Defendants’ actions.

JURISDICTION

1. This Court has jurisdiction over this adversary proceeding pursuant to 28 U.S.C. 

§§ 157 and 1334.

2. Venue lies properly in this Court pursuant to 28 U.S.C. § 1409.

3. This matter is a core proceeding pursuant to 28 U.S.C. § 157.

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THE PARTIES

4. The Plaintiff is Lynn A. Tavenner, the Chapter 7 Trustee of the Corporate 

Debtor’s Estate who was appointed as interim Trustee on December 4, 2015, and continues to 

serve.

5. On information and belief, defendant Mark F. White is an individual, currently 

residing at 4600 Jennway Loop, Moseley, VA 23120.

6. On Information and belief, defendant Nnika E. White is an individual, currently 

residing at 4600 Jennway Loop, Moseley, VA 23120.

Background

7. On or about September November 19, 2014, the Individual Debtors commenced a 

case by filing a voluntary petition for relief under chapter 13 of Title 11 of the United States 

Code (the “Bankruptcy Code”), case number 14-36232-KRH (the “Individual Case”).

8. On December 11, 2014, the Individual Debtors filed their first Chapter 13 Plan of 

reorganization (the “First Plan”).

9. On January 14, 2015, the chapter 13 trustee filed her objection to the First Plan 

(the “First Plan Objection”), alleging that the First Plan was not filed in good faith, which 

hearing was set for January 21, 2015.

10. At the January 21, 2015, hearing on the First Plan Objection, the same was 

continued to February 18, 2015.

11. At the February 18, 2015, hearing on the First Plan Objection, the same was 

continued to March 18, 2015.

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12. At the March 18, 2015 hearing, the First Plan Objection was sustained, and an 

order denying confirmation was entered.

13. On April 7, 2015, the Individual Debtors filed a second Chapter 13 Plan of 

reorganization (the “Second Plan”).

14. On May 6, 2015, a secured creditor of the Individual Debtors filed its objection to 

the Second Plan (the “Secured Creditor Objection to the Second Plan”).

15. Also on May 6, 2015, the Office of the United States Trustee (the “UST”), filed 

its limited objection the Second Plan (the “UST Limited Objection to the Second Plan”), 

expressing concerns as to the accuracy of the Individual Debtors’ schedules.

16. At the May 13, 2015 hearing on both the Secured Creditor Objection to the 

Second Plan and the UST Limited Objection to the Second Plan, the same were continued to 

June 10, 2015.

17. On June 9, 2015, the Individual Debtors filed a third Chapter 13 Plan of 

reorganization (the “Third Plan”).

18. The Third Plan resulted in the cancellation of the June 10, 2015 hearing, as the 

Secured Creditor Objection to the Second Plan and the UST Limited Objection to the Second 

Plan were now moot.

19. On June 15, 2015, Nnika E. White (“White”), filed a motion in her capacity as 

legal counsel requesting that she substitute herself as attorney of record for the Individual 

Debtors (the “White Motion”).

20. The White Motion was granted by entry of an Order on July 8, 2015, and the 

Individual Case proceeded with only White as counsel of record.

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21. On July 17, 2015, the UST filed its objection to the Third Plan (the “UST 

Objection to the Third Plan”), the same being set for a hearing on July 22, 2015.

22. The July 22, 2015 hearing on the UST’s Objection to the Third Plan was 

continued to September 2, 2015.

23. The September 2, 2015 hearing on the UST’s Objection to the Third Plan was 

continued a second time to October 14, 2015.

24. On October 13, 2015, White filed the Individual Debtors fourth Chapter 13 Plan 

of reorganization (the “Fourth Plan”).

25. The October 14, 2015 hearing on the UST’s Objection to the Third Plan was 

heard. Neither the Individual Debtors nor White appeared (or any other counsel on their behalf). 

At the conclusion of the hearing, the Court, sua sponte, ordered White to show cause why she 

should not be sanctioned for violations of the Bankruptcy Code and Bankruptcy Rules.

26. The Order to Show Cause was entered on October 20, 2015, and set for a hearing 

on November 4, 2015.

27. Also on October 20, 2015, the chapter 13 trustee filed her motion to convert the 

Individual Debtors’ case from a case under chapter 13 to one under chapter 7 of the Bankruptcy 

Code (the “Motion to Convert”).

28. On October 29, 2015, White filed the Individual Debtors fifth Chapter 13 Plan of 

reorganization (the “Fifth Plan”).

29. On November 4, 2015, a hearing was held on the Order to Show Cause and the 

Motion to the Convert, at the conclusion of which the Court took the matters under advisement.

30. On November 5, 2015, the Court entered an order granting the Motion to Convert.

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31. On November 5, 2015, Bruce H. Matson was appointed Chapter 7 trustee of the 

Individual Case (the “Individual Trustee”).

32. Among the assets of the Individual Debtors’ estate is 100 percent ownership of 

the PLLC.

33. The Individual Trustee, on December 2, 2015, moved this Court for the authority 

to initiate a voluntary chapter 7 proceeding for the PLLC (the “Authority Motion”).

34. The Individual Trustee also filed a motion to expedite (the “Motion to Expedite”) 

the hearing for the Authority Motion, which hearing was set for December 3, 2015 at 2:00 PM.

35. At the hearing convened on December 3, 2015, the Motion to Expedite was 

granted, and the Court heard the Authority Motion.

36. On information and belief, during the course of the December 3, 2015 hearing, 

White did testify under the penalty of perjury that she had not removed any of the Corporate 

Property from the PLLC other than pictures of her children.

37. At the conclusion of the hearing, the Court granted the Individual Trustee the 

authority sought in the Authority Motion.

38. At 4:47 PM on December 3, 2015, the Individual Trustee filed a voluntary 

petition for relief pursuant to Chapter 7 of the Bankruptcy Code (the “Corporate Case”).

39. Lynn L. Tavenner thereafter was appointed interim Trustee of the Corporate Case, 

and she continues to serve in that capacity.

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FACTS

40. On the morning of December 4, 2015, the Trustee , with counsel, appeared at the 

offices of the Corporate Debtor, located at 9101 Midlothian Turnpike, Suite 800, N. Chesterfield, 

VA 23235 (the “Corporate Offices”).

41. The Trustee was met at the Corporate Offices by a locksmith and forensic 

computer professional, both of whom are ready, willing, and able to testify. 

42. The locksmith had arrived before the Trustee, and related to the Trustee that a 

woman matching a description of White had exited the Corporate Offices and approached him to 

inquire about his presence in the parking lot. 

43. Upon learning that the locksmith was waiting for the Trustee, White reentered the 

Corporate Offices.

44. The locksmith heard the sound of equipment being moved and witnessed White 

and a person matching the description of the PLLC’s intern separately exit the property carrying 

items from the Corporate Offices. 

45. A male matching the description of White’s spouse, the other Individual Debtor, 

was seen leaving the rear of the Corporate Offices carrying items from the Corporate Offices.

46. Immediately upon entering the Corporate Offices, the Trustee found at the 

receptionist station a computer resting on top of a desk with its hard drive missing, no monitor, 

no papers, pencils, pens, or any other supplies one would expect in the front office of a law firm.

47. The Trustee proceeded to move from room to room within the Corporate Offices 

and was met with similar scenes: computers were either missing or left on the floor with parts 

displaced and in some instances hard drives removed; desks were emptied of all supplies; one 

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office server was missing; at least one office safe had been removed; certain physical client files 

had been removed from the Corporate Offices; televisions had been removed from the walls, in 

essence, someone had raided the Corporate Offices and removed any Corporate Property of 

value. 

48. White’s personal office was completely devoid of any Corporate Property that 

one could reasonably assume had been used in the exercise of the corporate business.

49. Certain pictures of the Corporate Offices taken on December 4, 2015, in 

conjunction with the Trustee’s examination of the Corporate Offices are attached hereto as 

Exhibit A.

50. Following consultation with the UST, the Trustee contacted two former 

employees of the Corporate Debtor, both of whom are ready, willing, and able to testify. The 

former employees came to the Corporate Offices to assist the Trustee in securing and preserving 

assets of the Corporate Debtor’s estate.

51. With the assistance of these former employees, the Trustee was able to move from 

room to room within the Corporate Offices, looking for the client files, and other of the 

Corporate Debtor’s property, and ascertaining that many items had been removed.

52. The Trustee found a bin used in conjunction with a paper shredder that looked as 

though it had recently been emptied. 

53. Within another bin used in conjunction with a paper shredder, the Trustee found a 

redwell containing significant information related to a case of a client of the Corporate Debtor 

that had recently been converted from a case under Chapter 13 to a case under Chapter 7 for bad 

faith. The Trustee secured the file.

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54. During the course of the day, the Trustee, her agents, and/or clients who had 

arrived at the Corporate Offices witnessed White approach in a vehicle several times, and 

quickly drive away.

55. Upon information and belief, White met on December 4, 2015, with a client of the 

Corporate Debtor at a location other than the Corporate Offices, and gave him his client file (or 

at least a portion of the same).

56. Upon information and belief, White met another bankruptcy attorney on 

December 4, 2015, at a location other than the Corporate Offices, and gave her a client file (or at 

least a portion of the same).

57. The Trustee learned, from the UST, a review of the Corporate Debtors’ docket,

and documents in the Corporate Offices, that the Corporate Debtor had several bank accounts at 

Wells Fargo Bank, N.A.

58. After securing the premises and documenting the state of the Corporate Offices, 

the Trustee promptly visited a branch of Wells Fargo Bank, N.A.

59. The Trustee was shown bank records for each of the Corporate Debtor’s accounts. 

Each account had been drained of all funds and closed on December 2, 2015.

60. Upon information and belief, White, after the filing of the Authority Motion, with 

the actual knowledge and notice that the Individual Trustee sought to file the Corporate Case, 

proceeded directly to a Wells Fargo Bank, N.A. branch and emptied the Corporate Debtor’s bank 

accounts.

61. Upon information and belief, one or both of the Individual Debtors left the 

hearing on the Authority Motion, having heard this Court’s ruling on said motion with actual 

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knowledge that the Individual Trustee would promptly file the Corporate Case, and went to the 

Corporate Offices where they willfully and maliciously systematically attempted to cover their 

tracks by removing the entirety of the Corporate Property. 

62. On December 4, 2015, the Trustee filed an Application to Employ Tavenner & 

Beran as Trustee’s Counsel in the Corporate Case (the “Corporate Debtor Trustee Employment 

Application”).

63. On December 4, 2015, the Trustee, with the help of the former employees, 

modified the voice mail message of the Corporate Debtor’s telephone line to direct all client 

inquiries to the law firm of Tavenner and Beran, PLC.

64. Upon information and belief, White contacted former employees of the Corporate 

Debtor during the weekend of December 5 and 6, 2015, seeking passwords to email accounts.

65. Upon information and belief, during the weekend of December 5 and 6, 2015, 

White forwarded the Corporate Debtor’s telephone line to a cell phone and/or another phone 

over which she maintains control.

66. Upon information and belief, during the weekend of December 5 and 6, 2015, 

White caused the webpage of the Corporate Debtor to direct all client inquiries to a cell phone. 

See Exhibit B, attached hereto.

67. Upon information and belief, White sent information related to clients of the 

Corporate Debtor to one or more attorneys on December 7, 2015.

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Causes of Action

COUNT I

(Relief from the Automatic Stay)

68. The Trustee incorporates the facts asserted in paragraphs 1 through 67.

69. The Individual Debtors are debtors under Chapter 7 of the Bankruptcy Code

having pending before this Court the Individual Case.

70. As such, the automatic stay of 11 U.S.C. § 362 may be in effect.

71. Pursuant to § 362(d)(1), the Trustee believes cause exists to allow the Trustee to 

bring this Complaint against the Individual Debtors to demand the relief sought herein.

COUNT II

(Injunctive Relief)

72. The Trustee incorporates the facts asserted in paragraphs 1 through 71.

73. The Corporate Property, including, but not limited to, the computers, televisions, 

servers, and hard drives: (a) are property that the Trustee may use, sell, or lease under the 

Bankruptcy Code; and/or, (b) contain recorded information relating to the Corporate Debtor’s 

property and/or financial affairs.

74. Injunctive relief: (a) compelling the Defendants to turn over the Corporate 

Property, including, but not limited to, the computers, servers, hard drives, and any and all 

electronic data either belonging to the Corporate Debtor and/or containing information pertaining 

to the Corporate Debtor; and (b) enjoining the Defendants from using, disposing or otherwise 

altering the Corporate Property, including, but not limited to, the computers, servers, hard drives, 

and any and all electronic data or physical files belonging to and/or containing information about 

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the Corporate Debtor is necessary and/or appropriate to carry out the provisions of the 

Bankruptcy Code.

75. The Trustee is likely to succeed on the merits of this Complaint.

76. No harm will be caused to the Defendants in granting the injunctive relief sought. 

77. The harm suffered by the Corporate Debtor (and to creditors) if the injunction is 

not granted is great.

78. The public interest is best served by preventing the Defendants from using, 

disposing, and/or concealing assets that could either (a) belong to the Corporate Debtor’s estate

and/or (b) contain information related to the Corporate Debtor’s property and/or financial affairs.

COUNT III

(Willful Violation of the Automatic Stay)

79. The Trustee incorporates the facts asserted in paragraphs 1 through 78.

80. The Corporate Property, including, but not limited to, the computer, servers, hard 

drives, electronic data, and physical files, as well as any recorded information contained on them, 

are assets of the Corporate Debtor’s estate.

81. Corporate Property, including, but not limited to, the computer, servers, hard 

drives, electronic data, and physical files contain recorded information relating to the Corporate 

Debtor’s property and/or financial affairs.

82. White, having been present at the December 3, 2015 hearing, is certainly aware of 

the Corporate Debtor’s bankruptcy case.

83. The Individual Debtors have willfully exercised control over property of the 

Corporate Debtor’s estate.

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84. Despite their awareness of the existence of the Corporate Debtor’s pending 

bankruptcy case and despite White having testified under oath that she had not removed any 

Corporate Property other than pictures of her children, the Defendants intentionally raided the 

Corporate Offices and removed valuable Corporate Property in willful violation of the automatic 

stay of § 362.

85. The Corporate Debtor has been damaged by the Individual Debtors control over 

property of the bankruptcy estate.

WHEREFORE, the Trustee respectfully requests that the Court enter an order: 

(a) Granting the Trustee, to the extent necessary, relief from the automatic stay in the 

Individual Case pursuant to section 362(d)(1);

(b) Compelling the Individual Debtors to turn over the Corporate Property, including, 

but not limited to, the computers, servers, hard drives, and any and all electronic 

data and physical files either belonging to the Corporate Debtor and/or containing 

recorded information pertaining to the Corporate Debtor’s property and/or 

financial affairs pursuant to sections 542(a) and (e) of the Bankruptcy Code,

(c) Enjoining the Individual Debtors from using, disposing and/or otherwise altering 

the Corporate Property, including the computers, servers, hard drives, and any and 

all electronic data and physical files either belonging to the Corporate Debtor 

and/or containing recorded information pertaining to the Corporate Debtor’s 

property and/or financial affairs pursuant to section 105 of the Bankruptcy Code 

and Rule 7065; 

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(d) Awarding the Trustee, on behalf of the bankruptcy estate, damages associated 

with the Defendants’ willful violation of the automatic stay; and, 

(e) Granting such other relief as is just and appropriate under the circumstances.

LYNN L. TAVENNER, TRUSTEE

Dated: December 7, 2015

By: /s/ Paula S. Beran

Paula S. Beran

Lynn L. Tavenner, Esquire (VSB No. 30083)

Paula S. Beran, Esquire (VSB No. 34679)

David N. Tabakin, Esquire (VSB No. 82709)

Tavenner & Beran

20 North 8th Street

Richmond, Virginia 23219

Telephone: (804) 783-8300

Telecopier: (804) 783-0178

Counsel for Lynn L. Tavenner, Trustee

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UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

Richmond Division

In re: THE LAW OFFICES OF WHITE & 

ASSOCIATES, PLLC, Case No.

Debtor, 15-36223-KRH

LYNN L. TAVENNER, TRUSTEE, Chapter

Plaintiff 7

Adv. Proc No.

MARK F. WHITE,

NNIKA E. WHITE,

Defendants

Verification of Lynn L. Tavenner

I, Lynn L. Tavenner, Plaintiff in the above styled case have reviewed the Complaint. The 

allegations in said Complaint of which I have personal knowledge I believe to be true. Those 

allegations in said Complaint of which I do not have personal knowledge I believe to be true 

based on specific information, documents, and/or both.

I verify under penalty of perjury under the laws of the United States of America and the 

Commonwealth of Virginia that the foregoing is true and correct.

Dated: December 7, 2015

/s/ Lynn L. Tavenner

Lynn L. Tavenner, Esquire (VSB No. 30083)

Paula S. Beran, Esquire (VSB No. 34679)

David N. Tabakin, Esquire (VSB No. 82709)

Tavenner & Beran

20 North 8th Street

Richmond, Virginia 23219

Telephone: (804) 783-8300

Telecopier: (804) 783-0178

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Exhibit A

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12/7/2015 The Law Office of White & Associates ­ Home

http://www.whitelawva.com/ 1/2

Home

The Law Office Of White

& Associates

The Law Firm you can Trust

HOME

Law Office of White and Associates is no longer open

for business.

Any questions regarding open cases please contact

Nnika White at 804­274­9002.

The information on this website should NOT be considered legal advice and

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The information on this website is for informational purposes only. Nothing on

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This information is not intended to create, and receipt of it does not constitute,

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become a client of the firm.

This website is not intended to be a source for legal advice, and you should not

rely on any information provided in this website as such. Readers should not

Exhibit B

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12/7/2015 The Law Office of White & Associates ­ Home

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relationship, and should always seek the advice of competent counsel.  White

and Associates may provide links to third party websites as a convenience.

The inclusion of any link does not imply endorsement by White and

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Except as expressly provided herein, White and Associates PC does not grant

you any express or implied rights to the information or content provided on this

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Home

9101 Midlothian Turnpike Suite 800 Richmond, VA 23235 Phone (804) 377­9431 Fax 804­377­9434

Exhibit B

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