IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE EASTERN DISTRICT OF VIRGINIA 

(Alexandria Division) 

In re: * 

 

WW Contractors Inc., * Case No: 18-12095-BFK 

 Debtor. * Chapter 11 

 

* * * * * * * * * * * * 

LIMITED OBJECTION TO DEBTOR’S MOTION TO DISMISS CASE

 

 Meridian Law, LLC, former counsel to debtor and debtor-in-possession in the abovecaptioned case (the “Debtor”), hereby files this Limited Objection to Debtor’s Motion to Dismiss 

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

THE CHAPTER 11 CASE 

1. On June 12, 2018, the Debtor filed a voluntary petition for relief under Chapter 11 

of the United States Code in the United States Bankruptcy Court for the District of Maryland, 

Case No. 18-17927. On June 14, 2018, the Bankruptcy Case was transferred to the United States 

Bankruptcy Court for the Eastern District of Virginia and was assigned Case No. 18-12095 (the 

“Bankruptcy Case”). 

2. Pursuant to an order entered on August 15, 2018, Meridian was approved as counsel 

to the Debtor, effective as of the Petition Date. 

3. On or about November 1, 2018, the Debtor notified Meridian that the Debtor was 

replacing Meridian with Whiteford, Taylor & Preston, LLP as bankruptcy counsel. 

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4. On November 16, 2018, the Debtor filed the Motion, wherein the Debtor is seeking 

dismissal of the Bankruptcy Case.

LIMITED OBJECITON 

5. Meridian does not object to the dismissal of the Bankruptcy Case. It does, 

however, object to the dismissal of the case without the entry of an order containing provisions 

regarding fees and expenses incurred by professionals retained in this Bankruptcy Case. (In 

addition to Meridian, the accounting firm of Rosen, Sapperstein & Friedlander, LLC was 

approved on August 15, 2018 as accountant to the Debtor, effective as of the Petition Date.) 

Meridian further objects to the dismissal of the Bankruptcy Case to the extent that the contemplated 

dismissal of the case is not conditioned on payment of duly approved fees and expenses of the 

Debtor’s professionals. 

CONCLUSION

WHEREFORE, Meridian Law, LLC respectfully requests that this Honorable Court (a) 

condition the dismissal of the instant Bankruptcy Case on the entry of an order (i) setting forth 

provisions regarding fees and expenses incurred by professionals retained in this case; and (ii) 

directing the payment of duly approved fees and expenses of the Debtor’s professionals; and (b) 

grant such other and further relief as the Court deems just and proper. 

Respectfully submitted, 

/s/ Aryeh E. Stein 

Aryeh E. Stein, VA Bar No. 45895 

Meridian Law, LLC 

600 Reisterstown Road, Suite 700 

Baltimore, MD 21208 

(443) 326-6011 

astein@meridianlawfirm.com 

 Former Counsel for Debtor 

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CERTIFICATE OF SERVICE

 I hereby certify that on this 4th day of December, 2018, a copy of the foregoing Limited 

Objection to Debtor’s Motion to Dismiss Case were served electronically to the following parties 

on the Court’s CM/ECF notice list: 

Derek C Abbott - dabbott@mnat.com 

Robert K. Coulter - robert.coulter@usdoj.gov, USAVAE.ALX.ECF.BANK@usdoj.gov 

Richard Ashford DuBose - dubo@gebsmith.com 

John P. Fitzgerald, III - ustpregion04.ax.ecf@usdoj.gov 

Jack Frankel - jack.i.frankel@usdoj.gov, USTPRegion04.ax.ecf@usdoj.gov 

David William Gaffey - dgaffey@wtplaw.com, rodom@wtplaw.com 

Sara A. John - sara_john@eppspc.com 

Dinh H Ngo - bankruptcyva@mwc-law.com, bankruptcyva@ecf.inforuptcy.com 

John M. Stern - John.Stern@oag.texas.gov, bk-mbecker@oag.texas.gov 

Jennifer Ellen Wuebker - jwuebker@wtplaw.com, rodom@wtplaw.com 

/s/ Aryeh E. Stein 

 Aryeh E. Stein 

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