IN THE UNITED STATES BANKRUPTCY COURT

FOR THE EASTERN DISTRICT OF VIRGINIA 

(Richmond Division) 

In re: 

LECLAIRRYAN PLLC, 

Debtor. 

Chapter 7 

Case No. 19-34574 (KRH) 

Lynn L. Tavenner, as Chapter 7 Trustee, 

Plaintiff, 

vs. 

ULX Partners, LLC and UnitedLex Corporation

Defendants. 

 Adv. Pro. 20-03142 (KRH) 

NOTICE OF MOTION AND HEARING THERON IF NECESSARY 

PLEASE TAKE NOTICE that Defendants ULX Partners, LLC, ULX Manager, LLC, 

and UnitedLex Corporation (collectively, “Defendants”), by counsel, have filed a Motion to Seal 

Settlement Agreement and Related Documents, Information, and Hearings (the “Motion”) 

[Docket No. 207 in Case No. 20-03142 and Docket No. 1325 in Case No. 19-34574]. 

PLEASE TAKE FURTHER NOTICE that your rights may be affected. You should 

read the Motion carefully and discuss it with your attorney if you have one in this Chapter 7 

Case. (If you do not have an attorney, you may wish to consult one). 

PLEASE TAKE FURTHER NOTICE that on September 4, 2019, the Court entered the 

Order Establishing Certain Notice, Case Management and Administrative Procedures [ECF. No. 38] 

(the “Case Management Order”), which approved the Notice, Case Management, and Administrative 

Procedures attached as Exhibit 1 to the Case Management Order (the “Case Management 

Procedures”). The Case Management Procedures, among other things, prescribe the manner in which 

Objection must be filed and served and set forth when certain hearings will be conducted. A copy of 

the Case Management Order may be obtained, free of charge, by written request to 

mckeet@gtlaw.com, or, for a fee, at http://ecf.vaeb.uscourts.gov. 

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

requested in the Motion, or if you want the Court to consider your views on the Motion, on or before

May 23, 2022 (the “Objection Deadline”), you or your attorney must: 

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File with the Court, either electronically or at the address shown below, a written 

response to the Motion pursuant to Rule 9013-1(H) of the Local Rules of the United 

States Bankruptcy Court for the Eastern District of Virginia and the Case Management 

Procedures. If you mail your written response to the Court for filing at the address of 

the clerk below, you must mail it early enough so the Court will receive it on or before 

the Objection Deadline. 

If a response is not properly and timely filed and served, the Court may deem any 

opposition waived, treat the Motion as conceded and enter an appropriate order 

granting the requested relief without further notice or hearing. 

Clerk of the Court 

United States Bankruptcy Court 

701 East Broad Street, Suite 4000 

Richmond, VA 23219 

In accordance with the Case Management Procedures, you must also serve a copy of 

your written Objection on the Core Parties, the 2002 List Parties and any Affected 

Entity so that the Objection is received on or before the Objection Deadline.

PLEASE TAKE FURTHER NOTICE that the Court will entertain the Motion on May 

25, 2022, at 11:00 a.m. (or such time thereafter as the matter may be heard). In connection with 

the same, the undersigned will appear before The Honorable Kevin R. Huennekens, United States 

Bankruptcy Judge. Due to the COVID−19 public health emergency, no in-person hearings are 

being held. This hearing will take place remotely through Zoom on the date and time scheduled 

herein. To appear at the hearing, you must use the following Zoom registration link: 

https://www.zoomgov.com/meeting/register/vJItfuivqTwsG0w7NNm3z511H7Q0KnjY2W8

Listen-only conference line[s]: 

Dial: 1-866-590-5055 

Access Code: 4377075 

Security Code: 52522 

Dated: May 11, 2022 Respectfully submitted, 

/s/ David G. Barger 

David G. Barger (VSB No. 21652) 

Thomas J. McKee, Jr. (VSB No. 68427) 

Greenberg Traurig, LLP 

1750 Tysons Boulevard, Suite 1000 

McLean, Virginia 22102 

Telephone: (703) 749-1300 

Facsimile: (703) 749-1301 

Email: bargerd@gtlaw.com 

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 mckeet@gtlaw.com 

and 

J. Gregory Milmoe (admitted pro hac vice) 

Greenberg Traurig, LLP 

One International Place, Suite 2000 

Boston, MA 02110 

Telephone: (617) 310-6064 

Email: milmoeg@gtlaw.com 

Counsel ULX Partners, LLC, ULX 

Manager, LLC, 

and UnitedLex Corporation 

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CERTIFICATE OF SERVICE 

I HEREBY CERTIFY that on this 11th day of May, 2022, a true and correct copy of the 

foregoing document was served via first class mail and/or electronic mail upon: (i) all parties and 

counsel requesting service via the Court’s ECF system, (ii) the Office of the United States 

Trustee, (iii) Special Counsel to Lynn L. Tavenner, Chapter 7 Trustee, (iv) the 20 largest 

unsecured creditors as listed on the Debtor’s schedules, and (v) the Service List as defined by the 

governing Case Management Order and filed by counsel to the Chapter 7 Trustee. 

/s/ David G. Barger 

David G. Barger (VSB No. 21652) 

Greenberg Traurig, LLP 

1750 Tysons Boulevard, Suite 1000 

McLean, Virginia 22102 

Telephone: (703) 749-1300 

Facsimile: (703) 749-1301 

Email: bargerd@gtlaw.com 

Counsel to ULX Partners, LLC, ULX 

Manager, LLC, 

and UnitedLex Corporation

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