William A. Broscious, VSB #27436 

Kimberly A. Taylor, VSB #29823 

KEPLEY BROSCIOUS & BIGGS, PLC 

2211 Pump Road 

Richmond, VA 23233 

(804) 741-0400 x202 

(804) 741-6175 (Facsimile) 

 Counsel for the Trustee 

IN THE UNITED STATES BANKRUPTCY COURT 

 FOR THE EASTERN DISTRICT OF VIRGINIA 

 Richmond Division 

In re: 

 

DIGITAL INK, INC., and 

CHRISTOPHER DAVID McGINNIS, 

 Case No. 18-30056 KLP 

Chapter 7 

 

 Debtors. (Jointly Administered) 

ORDER AUTHORIZING TRUSTEE TO CONDUCT 

BANKRUPTCY RULE 2004 EXAMINATION 

Upon the motion of Harry Shaia, Jr., Trustee in the bankruptcy case of 

MGT Construction Management, Inc., for an order pursuant to Section 105(a) 

of title 11 of the United States Code, Rule 2004 of the Federal Rules of 

Bankruptcy Procedure and Rule 2004-1 of the Local Rules of this Court, 

authorizing discovery of Mary Heaton the Court finds that: (a) it has 

jurisdiction to consider the motion pursuant to 28 U.S.C. §§ 157 and 1334; (b) 

this is a core proceeding pursuant to 28 U.S.C. § 157(b); (c) venue is proper 

before this Court pursuant to 28 U.S.C. §§ 1408 and 1409; (d) proper and 

adequate notice of the motion and the hearing thereon has been given and no 

other or further notice is necessary; (e) there have been no objections to the 

motion; and (f) upon the record herein, and after due deliberation thereon, good 

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and sufficient cause exists for the granting of the relief as set forth herein; 

therefore, it is hereby ORDERED that: 

1. The motion and the relief requested therein is GRANTED; 

 2. The Trustee is authorized to examine Ms. Heaton to the fullest 

extent permitted by Rules 2004 and 9016 of the Bankruptcy Rules concerning 

the financial affairs and operations of the Debtors and whether any claims or 

causes of action may exist against BSMT, Inc. or any other persons or entities; 

 3. The Trustee is authorized and empowered to take all actions 

necessary to implement the relief granted herein, including but not limited to 

issuing and serving subpoenas for production of documents and for 

examination of witnesses; 

 4. This Order is without prejudice to the Trustee’s right to apply to 

the Court for further discovery of Ms. Heaton or any other person; 

 5. The requirement under Rule 9013-1(G) to file a memorandum of 

law in connection with the Motion is waived; and 

 6. This Order shall be effective immediately upon entry. 

Done in Richmond, Virginia ______________________________________ 

 UNITED STATES BANKUPTCY JUDGE 

Dated: _________________, 2018 

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I ASK FOR THIS: 

 

/s/ Kimberly A. Taylor 

William A. Broscious, VSB #27436 

Kimberly Ann Taylor, VSB #29823 

Counsel for the Trustee 

Kepley Broscious & Biggs, PLC 

2211 Pump Road 

Richmond, VA 23233 

Phone: (757) 636-9826 

Fax: (804) 741-6175 

ktaylor@kbbplc.com 

CERTIFICATION OF ENDORSEMENT 

UNDER LOCAL BANKRUPTCY RULE 9022-1(C) 

I hereby certify that the foregoing proposed Order has been endorsed by 

or served upon all necessary parties. 

/s/ Kimberly A. Taylor 

Counsel 

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SERVICE LIST: 

Counsel to the Trustee: William A. Broscious, Esquire 

Kepley Broscious & Biggs, PLC 

2211 Pump Road 

Richmond, Virginia 23233 

Office of the U.S. Trustee: Robert B. Van Arsdale, Esquire 

Shannon Pecoraro, Esquire 

OFFICE OF THE U. S. TRUSTEE 

701 East Broad Street - Suite 4304 

Richmond, Virginia 23219 

 

Debtor: c/o Christopher David McGinnis 

 P.O. Box 191 

Petersburg, Virginia 23804 

copy to: Hunter R. Wells, Esquire 

 Canfield, Baer & Kruck LLP 

 4124 E. Parham Road 

 Richmond, Virginia 23228 

 

Mary Heaton: Mary Heaton 

 c/o BMST, Inc. 

1961 Puddledock Road 

Petersburg, Virginia 23803 

 

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