Robert M. Marino, Esq. VSB #26076 

Redmon Peyton & Braswell, LLP 

510 King Street, Suite 301 

Alexandria, VA 22314 

703-684-2000 

703-684-5109 (fax) 

rmmarino@rpb-law.com

Counsel for Blue Ridge Arsenal, Inc. 

IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE EASTERN DISTRICT OF VIRGINIA 

Alexandria Division 

 

 ) 

In re: ) Case No. 18-10472-KHK 

Blue Ridge Arsenal, Inc., ) Chapter 11 

 Debtor. ) 

 ) 

NOTICE OF DEBTOR’S APPLICATION TO EMPLOY SPECIAL COUNSEL 

PLEASE TAKE NOTICE that Blue Ridge Arsenal, Inc. (“Debtor”), the Debtor and 

Debtor-In-Possession herein, by counsel, pursuant to 11 U.S.C. §327 and Federal Rule of 

Bankruptcy Procedure 2014, has filed papers (specifically that certain Application to Employ 

Special Counsel (the “Application”)) requesting the entry of an Order authorizing the 

employment of Robert S. Naftal, Esq. and the law firm of Robert S. Naftal, P.C. (“Proposed 

Special Counsel”) as special counsel for the purpose of performing special legal services for the 

Debtor, nunc pro tunc to March 1, 2018. Specifically, Proposed Special Counsel will assist in 

any efforts by the Debtor to sell its assets or obtain new investor financing, including the review 

of any and all offers and the preparation and/or review of all documents necessary to 

memorialize and complete any such transaction(s). A copy of the Application, with Verified 

Statement and a proposed Order, is attached to this Notice. 

Your rights may be affected. You should read these papers carefully and discuss 

them with your attorney, if you have one in this bankruptcy case. (If you do not have an 

attorney, you may wish to consult one.) 

If you do not wish the court to grant the relief sought in the Application, or if you want 

the court to consider your views on the Application, then on or before April 6, 2018 (the 

“Response Deadline”), which is fourteen days after the date of service of this Notice and the 

Application, you or your attorney must: 

 File with the Court, at the following address, Clerk of Court, United States 

Bankruptcy Court for the Eastern District of Virginia, Alexandria Division, 

200 South Washington Street, Alexandria, Virginia 22314, a written response 

and request for hearing, as required by Local Rule 2014-1. Unless a written 

response and request for hearing is filed and served by the Response 

Deadline, the Court may deem any opposition waived, treat the 

Application as conceded, and issue an order granting the requested relief 

without further notice or hearing. If you mail your response to the Court for 

filing, you must mail it early enough so the court will receive it on or before 

the date noted above. 

 You must also mail a copy to the persons listed below: 

Robert M. Marino, Esq. 

Redmon Peyton & Braswell LLP 

510 King Street, Suite 301 

Alexandria, Virginia 22314 

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The Office of the United States Trustee, Region 4 

115 South Union Street 

Suite 210 

Alexandria, VA 22314 

If you or your attorney do not take any of the foregoing steps by the Response Deadline, 

the court may decide that you do not oppose the relief sought in the Application and may enter 

an order granting that relief. 

Dated: March 23, 2018 Respectfully Submitted, 

/s/ Robert M. Marino 

Robert M. Marino, Esq. VSB#26076 

REDMON, PEYTON & BRASWELL, LLP 

510 King Street, Suite 301 

Alexandria, VA 22314 

Phone: 703-684-2000 

Fax: 703-684-5109 

Email: rmmarino@rpb-law.com

Counsel for Blue Ridge Arsenal, Inc. 

CERTIFICATE OF SERVICE 

I hereby certify that I have this 23rd day of March, 2018, caused a copy of this Notice to 

be served electronically through the electronic case filing system to all persons entering their 

appearance and requesting notice in this case and by first class mail, postage prepaid, to the 

creditors and parties in interest who are set forth on the attached service list..

/s/Robert M. Marino 

Robert M. Marino 

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