_________________________________ 

Bruce H. Matson (Va. Bar No. 22874) 

LeClairRyan, A Professional Corporation 

919 East Main Street, 24th Floor 

Richmond, Virginia 23219 

(804) 343-4090 

Trustee 

UNITED STATES BANKRUPTCY COURT 

EASTERN DISTRICT OF VIRIGNIA 

Richmond Division 

) 

In re: ) Chapter 7 

) 

TERESA S. CAMDEN, ) Case No. 16-31606 

) 

Debtor. ) 

) 

TRUSTEE’S APPLICATION FOR 

EMPLOYMENT OF ATTORNEYS (SANDS ANDERSON PC) 

Bruce Matson, Trustee (the “Trustee”), by counsel that pursuant to 11 U.S.C. § 327 and 

Rule 2014 of the Rules of the Bankruptcy Procedure, hereby requests this Court authorize the 

employment of Sands Anderson PC to represent the Trustee and the estate in the above-styled 

case (the “Case”) and in support thereof, states as follows: 

Background

1. The Debtor filed for relief in the above-captioned Bankruptcy Court (the 

“Court”) pursuant to Chapter 7 of 11 U.S.C. § 101 et seq. (the “Bankruptcy Code”). 

2. The Trustee was appointed interim trustee in the Case and continues to serve in 

that capacity. 

Basis for Relief

3. The Trustee requires the assistance of legal counsel to provide advice and other 

services concerning the investigation and, if any, the prosecution of litigation to pursue recovery 

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of claims and/or other assets owed to the estate, including bank accounts, tax refunds, equipment 

and other tangible personal property and real estate and transfers and claimed exemptions 

relating to real estate. The engagement will be directed primarily at these matters, however, the 

scope of the engagement, if approved, will include any other matters for which the Trustee 

believes legal representation is needed and all matters the Trustee may assign to counsel 

proposed to be employed by this Application. 

Attorneys to be Engaged

4. Due to the experience and expertise of its attorneys in bankruptcy, creditors’ 

rights, litigation and other matters similar to the issues presented in this Case, the Trustee seeks 

to employ the law firm of Sands Anderson PC. The proximity of the attorneys at Sands 

Anderson PC to the Trustee will permit a more efficient delivery of legal services and prompt 

communication with the Trustee, which should result in an economy of expenses to the estate 

and a corresponding increase in recovery for the estate. 

5. The Trustee proposes to compensation Sands Anderson PC for tis services in 

accordance with Sands Anderson PC’s normal billing practice, which is to record and bill the 

time of Sands Anderson PC’s professionals at the firm’s regular hourly rates for its partners, 

associates and paralegals for its legal services. Generally, for Trustee matters in Virginia the 

range of Sands Anderson PC’s hourly rates are between $285.00 and $385.00 per hour for 

counsel/partners, $235.00 to $250.00 for associates and $150.00 for paralegals. Sands Anderson 

PC’s rates are reviewed, and when deemed appropriate, adjusted annually. Sands Anderson PC 

will utilize paralegals from time to time where the tasks required can be accomplished by a 

paralegal with a corresponding reduction in the applicable hourly rate. The Trustee will also 

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reimburse Sands Anderson PC for its out-of-pocket expenses incurred in connection with the 

engagement proposed herein. 

6. Subject to approval by the Court, this Application shall constitute the Trustee’s 

agreement to employ and compensation Sands Anderson PC. The Trustee has advised Sands 

Anderson PC that its compensation will be in accordance with 11 U.S.C. § 330, in compliance 

with Rule 2016 of the Federal Rules of Bankruptcy Procedure (and any applicable Local Rules), 

and subject to the approval of this Court. 

Legal Authority

7. The Bankruptcy Code authorizes trustees to employ professionals to assist the 

trustee in completing the trustee’s duties in a case such as this one. Specifically, 327(a) of the 

Bankruptcy Code provides, in pertinent part, as follows: 

Except as otherwise provided in this section, the trustee, 

with the court’s approval, may employ one or more 

attorneys, accountants, appraisers, auctioneers, or other 

professional personal, that do not hold or represent an 

interest adverse to the estate, and that the disinterested 

persons, to represent or assist the trustee in carrying out the 

trustee’s duties under this title. 

11 U.S.C. § 327(a). In addition, Section 327(d) of the Bankruptcy Code provides: 

The court may authorize the trustee to act as attorney or 

accountant for the estate if such authorization is in the best 

interest of the estate. 

11 U.S.C. § 327(d). Accordingly, the Trustee asserts that the relief requested is supported by 

applicable law and is in the best interest of the estate. 

8. Except as described herein, the Trustee believes that Sands Anderson PC does not 

have any connections with the Debtor, creditors, or any other party in interest or their respective 

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attorneys and accountants that would prevent Sands Anderson PC from being a “disinterested 

person” within the meaning of § 101(14) of the Bankruptcy Code. Filed contemporaneously 

herewith as Exhibit A hereto is the Attorney’s Disclosure Statement attesting to the status, 

condition and/or exceptions to any of these connections. 

Notice

9. Notice of this Application has been given to the parties listed on the attached 

Certificate of Service. The Trustee submits that no other or further notice is required. 

WHEREFORE, Bruce H. Matson, Trustee, by counsel, hereby requests that this Court to 

(i) approve the employment of Sands Anderson PC by entering the proposed Order Authorizing 

Employment of Attorneys (Sands Anderson PC), a copy of which is attached hereto as Exhibit B, 

and (ii) grant such other relief concerning this Application as may be appropriate. 

BRUCE H. MATSON, TRUSTEE 

/s/ Bruce H. Matson_________________ 

Trustee 

Bruce H. Matson (Va. Bar No. 22874) 

LeClairRyan, A Professional Corporation 

919 East Main Street, 24th Floor 

Richmond, Virginia 23219 

(804) 343-4090 

Trustee 

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CERTIFICATE OF SERVICE 

I hereby certify that on the 16th day of June, 2016, a true and correct copy of this 

Trustee’s Application For Employment of Attorneys (Sands Anderson PC) was sent by first-class 

mail, postage prepaid, and/or electronic delivery to all parties receiving electronic notification 

and to: 

Robert Van Arsdale 

Office of the U.S. Trustee 

701 East Broad Street – Suite 4304 

Richmond, Virginia 23219 

Assistant U.S. Trustee 

Sharon C. Stuart, Esquire 

Stuart Law Firm, LLC 

2222 Monument Avenue 

Richmond, Virginia 23220 

Counsel for Debtor 

/s/ Bruce H. Matson_________________ 

Trustee 

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UNITED STATES BANKRUPTCY COURT 

EASTERN DISTRICT OF VIRIGNIA 

Richmond Division 

) 

In re: ) Chapter 7 

) 

TERESA S. CAMDEN, ) Case No. 16-31606 

) 

Debtor. ) 

) 

ATTORNEY'S DISCLOSURE STATEMENT

COMMONWEALTH OF VIRGINIA: 

CITY OF RICHMOND: 

This day, C. Thomas Ebel, personally appeared before me, the undersigned Notary 

Public, in my jurisdiction aforesaid, and being first duly sworn, stated as follows: 

1. I am an attorney at law duly licensed to practice in Virginia and admitted to 

practice in the above-captioned court. 

2. I am an officer with the law firm of Sands Anderson PC, which maintains offices 

at 1111 East Main Street, Richmond, Virginia, as well as in Fredericksburg, McLean and 

Christiansburg, Virginia, and Raleigh, North Carolina. The Trustee in the above-captioned case 

(the "Case") has requested that Sands Anderson PC represent the Trustee in connection with 

certain matters in the Case. 

3. Except as provided in paragraph 4 below, to the best of my knowledge, neither I 

nor any other member of the firm of Sands Anderson PC has or represents any interest adverse to 

the captioned Debtor or the estate; nor do I or any member of Sands Anderson PC have any 

connection with the Debtor or the estate; nor am I aware of any connection or relationship with 

any party in the Case, including the Office of the United States Trustee, or their respective 

professionals that would prevent Sands Anderson PC from not being a "disinterested person" in 

the Case within the meaning of § 101(14) of the United States Bankruptcy Code. 

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EXHIBIT B 

_________________________________ 

Bruce H. Matson (Va. Bar No. 22874) 

LeClairRyan, A Professional Corporation 

919 East Main Street, 24th Floor 

Richmond, Virginia 23219 

(804) 343-4090 

Trustee 

UNITED STATES BANKRUPTCY COURT 

EASTERN DISTRICT OF VIRIGNIA 

Richmond Division 

) 

In re: ) Chapter 7 

) 

TERESA S. CAMDEN, ) Case No. 16-31606 

) 

Debtor. ) 

) 

ORDER APPROVING TRUSTEE’S EMPLOYMENT OF ATTORNEYS 

This matter came before the Court upon the Trustee’s Application for Employment of 

Attorneys (Sands Anderson PC) (the “Application”). After proper notice and due consideration, 

it is hereby ORDERED as follows: 

1. The Trustee’s employment of Sands Anderson PC in accordance with the terms of 

the Application to serve as attorneys to the Trustee should be and hereby is approved. 

2. Subject to approval of the Court, the employment approved by this Order shall be 

compensated as provided in the Application and in accordance with 11 U.S.C. § 330. 

Upon entry of this Order, the Clerk is directed to forward copies to all parties on the 

Service List attached hereto. 

ENTERED: _________________________________________ 

UNITED STATES BANKRUTPCY JUDGE 

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I ASK FOR THIS: 

_______________________________________ 

Bruce H. Matson (Va. Bar No. 22874) 

LeClair Ryan, A Professional Corporation 

919 East Main Street, 24th Floor 

Richmond, Virginia 23219 

(804) 343-4090 

Trustee 

SEEN AND NO OBJECTION: 

_______________________________________ 

Robert Van Arsdale 

Office of the U.S. Trustee 

701 East Broad Street, Suite 4304 

Richmond, Virginia 23219 

(804) 771-2310 

Assistant U.S. Trustee 

CERTIFICATE OF ENDORSEMENT 

I hereby certify that the foregoing Order Approving Trustee’s Employment of Attorneys 

has been endorsed by all necessary parties. 

Trustee 

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SERVICE LIST 

Robert Van Arsdale 

Office of the U.S. Trustee 

701 East Broad Street – Suite 4304 

Richmond, Virginia 23219 

Assistant U.S. Trustee 

Sharon C. Stuart, Esquire 

Stuart Law Firm, LLC 

2222 Monument Avenue 

Richmond, Virginia 23220 

Counsel for Debtor 

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