Robert S. Westermann (VSB No. 43294)

Franklin R. Cragle, III (VSB No. 78398)

HIRSCHLER FLEISCHER, P.C.

The Edgeworth Building

2100 East Cary Street

Post Office Box 500

Richmond, Virginia 23218-0500

Telephone: 804.771.9500

Facsimile: 804.644.0957

E-Mail: rwestermann@hirschlerlaw.com

fcragle@hirschlerlaw.com

Counsel for BMST, Inc. and Mark Beltrami

IN THE UNITED STATES BANKRUPTCY COURT

FOR THE EASTERN DISTRICT OF VIRGINIA

RICHMOND DIVISION

)

In re: )

)

DIGITAL INK, INC., and ) Case No. 18-30056-KLP

CHRISTOPHER DAVID McGINNIS, )

) Chapter 7

Debtors. )

)

)

HARRY SHAIA, JR., TRUSTEE, )

)

Plaintiff, )

v. ) Adv. Pro. No. 18-03098-KLP

)

BMST, INC., et al., )

)

Defendants. )

)

NOTICE OF MOTION AND HEARING

PLEASE TAKE NOTICE THAT on November 2, 2018, BMST, Inc. and Mark Beltrami 

(together, the “BMST Defendants”), by their undersigned counsel, filed with the Court their 

Motion to Dismiss Complaint to Avoid Transfers, Impress Successor Liability, and Obtain an 

Order of Substantive Consolidation (the “Motion”). A true and complete copy of the Motion has 

been filed with the Bankruptcy Court simultaneously with this Notice and may be obtained for a 

fee via PACER at http://www.vaeb.uscourts.gov, or by written request to Franklin R. Cragle, III,

Esquire, Hirschler Fleischer, P.C., Post Office Box 500, Richmond, Virginia 23218-0500, or by

sending such written request to fcragle@hf-law.com.

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Your rights may be affected. You should read the Motion carefully and discuss it 

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

wish to consult one.)

PLEASE TAKE FURTHER NOTICE THAT if you do not want the Court to grant the 

relief sought in the Motion, or if you want the Court to consider your views on the Motion, then 

you or your attorney must, on or before November 21, 2018:

1. File with the Court at the address shown below a written response to the Motion 

pursuant to Local Bankruptcy Rule 9013-1. You must mail or otherwise file it early enough so the 

Court will receive it on or before the due date identified therein.

Clerk of the Court

United States Bankruptcy Court

701 E. Broad Street, Suite 4000

Richmond, Virginia 23219

2. You must also serve your written response on the following counsel for BMST 

Defendants at the address shown below. You must serve the written response early enough so that 

such counsel will receive it on or before the due date identified herein.

Franklin R. Cragle, III, Esquire

Hirschler Fleischer, P.C.

The Edgeworth Building

2100 East Cary Street

Post Office Box 500

Richmond, Virginia 23218-0500

fcragle@hf-law.com

Attend a hearing on the Motion before the Court on November 28, 2018, at 9:30 a.m. 

(prevailing Eastern Time), at United States Bankruptcy Court, 701 East Broad Street, Room 

5100, Richmond, Virginia.

If you or your attorney do not take these steps, the Court may decide that you do not 

oppose the relief sought in the Motion and may enter an order granting the relief requested in the 

Motion.

Dated: November 2, 2018 Respectfully submitted

BMST, INC. and MARK BELTRAMI

 /s/ Franklin R. Cragle, III

 Counsel

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Robert S. Westermann (VSB No. 43294)

Franklin R. Cragle, III (VSB No. 78398)

HIRSCHLER FLEISCHER, P.C.

The Edgeworth Building

2100 East Cary Street

Post Office Box 500

Richmond, Virginia 23218-0500

Telephone: 804.771.9500

Facsimile: 804.644.0957

E-Mail: rwestermann@hirschlerlaw.com

fcragle@hirschlerlaw.com

Counsel for BMST, Inc. and Mark Beltrami

CERTIFICATE OF SERVICE

I hereby certify that on November 2, 2018, a true and complete copy of the foregoing 

Notice was filed and served electronically using the Court’s ECF System and was also sent by email and first class mail, postage prepaid, as follows:

Kimberly A. Taylor, Esq.

William A. Broscious, Esq.

Kepley Broscious & Biggs, PLC

2211 Pump Road

Richmond, Virginia 23233

(ktaylor@kbbplc.com)

 Counsel for Harry Shaia, Jr., Trustee

Robert A. Canfield, Esq.

Canfield Wells & Kruck, LLP

4124 E. Parham Road

Henrico, Virginia 23228

(bob@cwkllp.com)

 Counsel for Christopher McGinnis

 /s/ Franklin R. Cragle, III

 Counsel

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