Erika L. Morabito (VSB No. 44369) 

Brittany J. Nelson (VSB No. 81734) 

QUINN EMANUEL URQUHART & SULLIVAN LLP 

1300 I Street, N.W., Suite 900 

Washington, DC 20005 

(202) 538-8334 (telephone) 

Special Counsel to the Chapter 7 Trustee

10750-00003/13230948.2 

UNITED STATES BANKRUPTCY COURT 

EASTERN DISTRICT OF VIRGINIA 

RICHMOND DIVISION 

In re: 

LeClairRyan PLLC, 

 Debtor1

Case No.: 19-34574-KRH 

Chapter 7 

NOTICE OF FILING UNDER SEAL OF 

PROPOSED FAO SETTLEMENTS 

PLEASE TAKE NOTICE THAT Lynn L. Tavenner, not individually but solely in her 

capacity as the Chapter 7 trustee (in such capacity, the “Chapter 7 Trustee” and/or the “Trustee”) 

of the bankruptcy estate (the “Estate”) of LeClairRyan PLLC (“LeClairRyan” and/or 

the “Debtor”), in the above-referenced Chapter 7 case (the “Case”), filed under seal with the 

United States Bankruptcy Court for the Eastern District of Virginia (the “Court”), pursuant to the 

Order Approving Procedures and Permitting Trustee to Prosecute and Compromise FAO Actions

[ECF No. 533], and as thereafter modified by Court Orders, ECF Nos. 929 and 982 (collectively, 

the “FAO Procedures Order”),2

 a Sixth Notice of Proposed FAO Settlements [ECF No. 1081] 

(the “Sixth Notice of Proposed Settlements”) describing proposed settlements with the following 

individuals: 

Matthew Bauer

Michael Conway

Bryan P. Couch 

Michael Giunta

Jay S. Gregory

Charles Erik Gustafson

Andrew Neil Hartzell 

Gretchen Jackson 

Powell Leitch 

James Messenger

Nancy M. Reimer

1

 The principal address of the Debtor as of the petition date was 4405 Cox Road, Glen Allen, Virginia 23060, and the 

last four digits of the Debtor’s federal tax identification number are 2451. 

2

 Terms not otherwise defined shall have the meanings ascribed to them in the FAO Procedures Order. 

Case 19-34574-KRH Doc 1253 Filed 03/16/22 Entered 03/16/22 00:02:29 Desc Main

Document Page 1 of 3
10750-00003/13230948.2 2 

Wayne Roth 

Robin Teskin 

Patrick Voke 

All of the above referenced individuals have requested that the both the terms of the 

Proposed FAO Settlement and the settlement agreements be subject to a protective order as 

permitted under the FAO Procedures Order. Accordingly, as indicated above, the Sixth Notice of 

Proposed Settlements was filed under seal. See ECF No. 1081. 

This notice is being provided to publicly announce the filing of the Sixth Notice of 

Proposed Settlements and the procedures outlined therein. If an Interested Party (as defined in the 

FAO Procedures Order) desires to object to the Trustee proceeding with final consummation of 

any said settlement, then within fifteen (15) days of the service of this Notice, he/she/it must file 

with the Court, at the address shown below, a written response with supporting memorandum 

pursuant to Local Bankruptcy Rule 9013-1 and the FAO Procedures Order; and send or otherwise 

file it early enough so the Court will receive it on or before fifteen (15) days from the date of 

service of this Notice. 

Clerk of the Court 

United States Bankruptcy Court 

701 E. Broad Street, Suite 4000 

Richmond, VA 23219 

Any of the Interested Parties must also serve a copy on: 

Paula S. Beran, Esq. 

Tavenner & Beran, PLC 

20 North Eighth Street, 

2nd Floor 

Richmond, VA 23219 

Erika L. Morabito, Esq. 

Brittany J. Nelson, Esq. 

Quinn Emanuel Urquhart & 

Sullivan LLP 

1300 I Street NW, Suite 900 

Washington, DC 20005 

Shannon F. Pecoraro, Esq. 

Office of the United States Trustee 

701 East Broad, 

Suite 4304 

Richmond, VA 23219 

If these steps are not taken, any opposition is deemed waived, and the Trustee may 

consummate the Proposed FAO Settlements without further notice or hearing. 

Dated: March 15, 2022 Respectfully submitted, 

/s/ Brittany J. Nelson 

Special Counsel to Lynn L. Tavenner, Esq., the 

Chapter 7 Trustee of Estate of LeClairRyan PLLC 

Case 19-34574-KRH Doc 1253 Filed 03/16/22 Entered 03/16/22 00:02:29 Desc Main

Document Page 2 of 3
10750-00003/13230948.2 3 

LOCAL BANKRUPTCY RULE 2002-1 CERTIFICATE OF SERVICE 

I certify that on this 15th day of March, 2022, a true copy of the foregoing Notice was 

served on (i) the Office of the United States Trustee, (ii) the 20 largest unsecured creditors as listed 

on the Debtor’s schedules, and (iii) any other party who has made a written request to Paula S. 

Beran, Esquire and filed on the Court’s CM/ECF system. 

 /s/ Brittany J. Nelson 

Case 19-34574-KRH Doc 1253 Filed 03/16/22 Entered 03/16/22 00:02:29 Desc Main

Document Page 3 of 3