Paula S. Beran, Esquire (Va. Bar No. 34679)

Tavenner & Beran, PLC 

20 North Eighth Street, Second Floor

Richmond, Virginia 23219

Telephone: (804) 783-8300

Telecopy: (804) 783-0178

Counsel for Lynn L. Tavenner, Chapter 7 Trustee

UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

Richmond Division

In re: Case No. 19-34574-KRH

LeClairRyan, PLLC,1

Debtor Chapter 7

PROPOSED AGENDA FOR HEARING ON

JULY 14, 2022, AT 2:00 P.M. (PREVAILING EASTERN TIME)

Set forth below are the matters scheduled to be heard before the Honorable Kevin R. 

Huennekens on July 14, 2022, beginning at 2:00 p.m. The omnibus hearing shall be conducted 

both in-person and by Zoom for Government. Persons wishing to appear at the omnibus hearing 

may participate by either, at their option, appearing in person at Judge Huennekens’ Courtroom, 

701 E. Broad St., Courtroom 5000, Richmond, Virginia, or registering in advance at: 

https://www.zoomgov.com/meeting/register/vJIsc-urrjwpHOBgSn1kb7R9zkkCffWLZUc 

Persons who wish to attend, but not participate at, the omnibus hearing may dial-in to the Court’s 

listen-only conference line:

Dial: 1-866-590-5055; Access Code: 4377075; Security Code: 71422 

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.

Case 19-34574-KRH Doc 1484 Filed 07/12/22 Entered 07/12/22 17:46:20 Desc Main

Document Page 1 of 8
2 

I. MATTERS OF THE TRUSTEE AND/OR THE ESTATE

1. Motion to Approve Compromise under FRBP 9019 (Iron Mountain) filed by Paula S. 

Beran of Tavenner & Beran, PLC on behalf of Lynn L. Tavenner. [ECF No. 1424] 

Related documents:

1. Notice of Motion and Notice of Hearing (Re: related document(s)[1424] Motion to 

Approve filed by Lynn L. Tavenner) filed by Paula S. Beran of Tavenner & Beran, 

PLC on behalf of Lynn L. Tavenner. Hearing scheduled for 7/14/2022 at 02:00 PM at 

Judge Huennekens' Courtroom, 701 E. Broad St., Rm. 5000, Richmond, Virginia. 

Response Deadline: July 7, 2022 

Responses Filed: None 

Status: The Trustee will request that the Court grant the Motion as filed.

II. MATTERS OF THIRD PARTIES

2. Application for Administrative Expenses – Application for Order Allowing and Directing 

Payment of Administrative Expense Claim (Related Document(s)1307 Order on Motion to 

Set Last Day to File Administrative Claims) filed by Neil E. McCullagh of Spotts Fain PC 

on behalf of Park Towers Office Investment, LLC, Park Towers Investment, LLC. 

(McCullagh, Neil) [ECF No. 1350] 

Related documents:

a. Notice of Motion and Notice of Hearing – Notice of Application for Order Allowing 

Administrative Expense Claim and Notice of Hearing (Re: related document(s)1350 

Application for Administrative Expenses filed by Park Towers Investment, LLC, Park 

Towers Office Investment, LLC) filed by Neil E. McCullagh of Spotts Fain PC on 

behalf of Park Towers Investment, LLC, Park Towers Office Investment, LLC. Hearing 

scheduled for 6/28/2022 at 11:00 AM at Judge Huennekens’ Courtroom, 701 E. Broad 

St., Rm. 5000, Richmond, Virginia. (McCullagh, Neil) [ECF No. 1351] 

b. Statement - STIPULATION BETWEEN LYNN L. TAVENNER, AS TRUSTEE, 

PARK TOWERS INVESTMENT, LLC, AND PARK TOWERS OFFICE 

INVESTMENT, LLC AND PROPOSED STIPULATED ORDER (Re: related 

document(s)1350 Application for Administrative Expenses filed by Park Towers 

Case 19-34574-KRH Doc 1484 Filed 07/12/22 Entered 07/12/22 17:46:20 Desc Main

Document Page 2 of 8
3

Investment, LLC, Park Towers Office Investment, LLC) filed by Paula S. Beran of 

Tavenner & Beran, PLC on behalf of Lynn L. Tavenner. (Beran, Paula) [ECF. No. 

1427]

Response Deadline: June 21, 2022

Responses Filed: None

Status:

The Court has entered Stipulation Between Lynn L. Tavenner, as 

Trustee, Park Towers Investment, LLC and Park Towers Office 

Investment, LLC and Stipulated Order (Re: related 

document(s)1427 Statement filed by Lynn L. Tavenner) [ECF. 

No. 1462] and, as such, the matter may be removed from the 

Court’s docket.

3. Application for Administrative Expenses – Application of Ponte Gadea Washington, LLC 

for Allowance and Payment of Administrative Expense Claim filed by Thomas John 

McKee Jr. of Greenberg Traurig on behalf of Ponte Gadea Washington, LLC. 

(Attachments: # 1 Exhibit(s) A # 2 Exhibit(s) B) (McKee, Thomas)

Related documents:

a. Notice of Motion and Notice of Hearing (Re: related document(s)1356 Application for 

Administrative Expenses filed by Ponte Gadea Washington, LLC) filed by Thomas 

John McKee Jr. of Greenberg Traurig on behalf of Ponte Gadea Washington, LLC. 

Hearing scheduled for 6/28/2022 at 11:00 AM at Judge Huennekens’ Courtroom, 701 

E. Broad St., Rm. 5000, Richmond, Virginia. (McKee, Thomas)

b. Hearing held and continued; Appearance(s): Paula Beran for Trustee; Thomas Mckee 

for ULX Partners, LLC (Re: related document(s)1356 Application for Administrative 

Expenses filed by Ponte Gadea Washington, LLC) Hearing scheduled for 7/14/2022 at 

02:00 PM at Judge Huennekens' Courtroom, 701 E. Broad St., Rm. 5000, Richmond, 

Virginia. (Gary, Lisa) Modified on 7/1/2022 to correct hearing time to 2:00 PM (Gary, 

Lisa). [ECF No. 1446]

Response Deadline: June 21, 2022

Responses Filed: None

Case 19-34574-KRH Doc 1484 Filed 07/12/22 Entered 07/12/22 17:46:20 Desc Main

Document Page 3 of 8
4

Status:

The Movant and the Trustee have agreed on the form of a 

stipulation and proposed stipulated order [ECF No. 1483], which 

proposed stipulated order will be tendered to this Court. As such, 

this matter may be removed from the Court’s docket.

4. Application for Administrative Expenses and Order Allowing Chapter 11 Administrative 

Expense Claim for Post-Petition Rent (Related Document(s)1307 Order on Motion to Set 

Last Day to File Administrative Claims) filed by Richard E. Lear of Holland & Knight 

LLP on behalf of CARLYLE OVERLOOK OWNER LLC. (Lear, Richard) [ECF No. 

1358]

Related documents:

a. Notice of Motion and Notice of Hearing (Re: related document(s)1358 Application for 

Administrative Expenses filed by CARLYLE OVERLOOK OWNER LLC) filed by 

Richard E. Lear of Holland & Knight LLP on behalf of CARLYLE OVERLOOK 

OWNER LLC. Hearing scheduled for 6/28/2022 at 11:00 AM at Judge Huennekens’

Courtroom, 701 E. Broad St., Rm. 5000, Richmond, Virginia. (Lear, Richard) [ECF 

No. 1359]

b. Hearing held and continued; Appearance(s): Paula Beran for Trustee (Re: related 

document(s)1358 Application for Administrative Expenses filed by CARLYLE 

OVERLOOK OWNER LLC) Hearing scheduled for 7/14/2022 at 02:00 PM at Judge 

Huennekens' Courtroom, 701 E. Broad St., Rm. 5000, Richmond, Virginia. (Gary, 

Lisa) Modified on 7/1/2022 to correct hearing time to 2:00 PM (Gary, Lisa) [ECF No. 

1447]

Response Deadline: June 21, 2022

Responses Filed: None

Status:

The Movant and the Trustee have agreed on the form of a 

stipulation and proposed stipulated order [ECF No. 1466], which 

proposed stipulated order will be tendered to this Court for entry. 

As such, this matter may be removed from the Court’s docket.

5. Application for Administrative Expenses filed by Lori D. Thompson of Spilman, Thomas 

Battle PLLC on behalf of Lori D. Thompson. (Attachments: # 1 Exhibit(s) A) (Thompson, 

Lori) [ECF No. 1360]

Case 19-34574-KRH Doc 1484 Filed 07/12/22 Entered 07/12/22 17:46:20 Desc Main

Document Page 4 of 8
5

Related documents:

a. Notice of Motion and Notice of Hearing (Re: related document(s)1360 Application for 

Administrative Expenses filed by Lori D. Thompson) filed by Lori D. Thompson of 

Spilman, Thomas Battle PLLC on behalf of Lori D. Thompson. Hearing scheduled for 

6/28/2022 at 11:00 AM at Judge Huennekens’ Courtroom, 701 E. Broad St., Rm. 5000, 

Richmond, Virginia. (Thompson, Lori) [ECF No. 1361]

b. Hearing held and continued; Appearance(s): Paula Beran for Trustee (Re: related 

document(s)1360 Application for Administrative Expenses filed by Lori D. Thompson) 

Hearing scheduled for 7/14/2022 at 02:00 PM at Judge Huennekens' Courtroom, 701 

E. Broad St., Rm. 5000, Richmond, Virginia. (Gary, Lisa) Modified on 7/1/2022 to 

correct hearing time to 2:00 PM (Gary, Lisa) [ECF No. 1447]

Response Deadline: June 21, 2022

Responses Filed:

Response to (Re: related document(s)1360 Application for 

Administrative Expenses filed by Lori D. Thompson) filed by 

Paula S. Beran of Tavenner & Beran, PLC on behalf of Lynn L. 

Tavenner. (Beran, Paula) [ECF No. 1420]

Status:

The Movant and the Trustee are in active discussions to resolve 

any and all matters related to this bankruptcy estate. Therefore, 

the Trustee respectfully requests that this matter be continued 

until August 25, 2022 at 1:00 P.M. The Movant consents to such 

a continuance. 

6. Motion to Seal Settlement Agreement and Related Documents, Information, and Hearings 

filed by David G. Barger of Greenberg Traurig, LLP on behalf of ULX Partners, LLC, 

ULX Manager, LLC, and UnitedLex Corporation [ECF No. 1325 and ECF No. 207 in Adv. 

Pro. No. 20-03142]

Related Documents:

a. Notice of Hearing (Re: related document(s)1325 Motion to Restrict Public 

Access to Sensitive Case Information filed by UnitedLex Corporation, ULX 

Partners, LLC) filed by David G. Barger of Greenberg Traurig, LLP on behalf 

of ULX Partners, LLC, UnitedLex Corporation. Hearing scheduled for 

5/25/2022 at 11:00 AM at Judge Huennekens' Courtroom, 701 E. Broad St., 

Rm. 5000, Richmond, Virginia. (Barger, David) [ECF No. 1326]

Case 19-34574-KRH Doc 1484 Filed 07/12/22 Entered 07/12/22 17:46:20 Desc Main

Document Page 5 of 8
6

b. Hearing held and continued; (related document(s): 1325 Motion to Restrict 

Public Access to Sensitive Case Information filed by ULX Partners, LLC, 

UnitedLex Corporation) Appearances: David G. Barger, J. Gregory Milmoe for 

ULX Partners, LLC;Paula Beran for Trustee; Erika Morabito, Special Counsel, 

for Trustee; Kathryn Montgomery for Office of the US Trustee. Hearing 

scheduled for 05/26/2022 at 12:00 PM at Judge Huennekens' Courtroom, 701 

E. Broad St., Rm. 5000, Richmond, Virginia. (LisaGary) [ECF No. 1340]

c. Order Continuing Hearing (Re: related document(s)1325 Motion to Restrict 

Public Access to Sensitive Case Information filed by UnitedLex Corporation, 

ULX Partners, LLC) Hearing scheduled for 5/26/2022 at 12:00 PM at Judge 

Huennekens' Courtroom, 701 E. Broad St., Rm. 5000, Richmond, Virginia. 

[ECF No. 1341]

d. Hearing held and continued; matters to be sealed and/or filed under seal pending 

final determination at June 8, 2022 hearing as more fully set out in court. 

(related document(s): 1325 Motion to Restrict Public Access to Sensitive Case 

Information filed by ULX Partners, LLC, UnitedLex Corporation) 

Appearances:David G. Barger for ULX Partners, LLC; Paula Beran for Trustee; 

Erika Morabito, Special Counsel, for Trustee; Kathryn Montgomery for Office 

of the US Trustee; Hearing scheduled for 06/08/2022 at 01:00 PM at Judge 

Huennekens' Courtroom, 701 E. Broad St., Rm. 5000, Richmond, Virginia. 

(LisaGary) [ECF No. 1347]

e. Order to Seal Omnibus Settlement Agreement and Related Documents, 

Information, and Hearings (Related Doc 1325) [ECF. No. 1382]

f. Hearing held and continued; (related document(s): 1326 Notice of Hearing filed 

by ULX Partners, LLC, UnitedLex Corporation) Appearances: Dave Grable 

and Erika Morabito, Special Counsel, for Trustee; Paula Beran for Trustee; 

Kathryn Montgomery for Office of the US Trustee;, Susan Poll Klaessy for 

Foley & Lardner LLP; David G. Barger for ULX Partners, LLC; Erin 

Rosenberg for CVC Advisers. Hearing scheduled for 06/28/2022 at 11:00 AM 

at Judge Huennekens' Courtroom, 701 E. Broad St., Rm. 5000, Richmond, 

Virginia. (LisaGary) [ECF No. 1401]

g. Hearing held and continued; Appearance(s): Paula Beran for Trustee; Thomas 

Mckee, David Barger for ULX Partners, LLC; Kathryn Montgomery for Office 

of the U.S. Trustee (Re: related document(s)1325 Motion to Restrict Public 

Access to Sensitive Case Information filed by UnitedLex Corporation, ULX 

Partners, LLC) Hearing scheduled for 7/14/2022 at 02:00 PM at Judge 

Huennekens' Courtroom, 701 E. Broad St., Rm. 5000, Richmond, Virginia. 

(Gary, Lisa) Modified on 7/1/2022 to correct hearing time to 2:00 PM (Gary, 

Lisa) [ECF No. 1442]

Case 19-34574-KRH Doc 1484 Filed 07/12/22 Entered 07/12/22 17:46:20 Desc Main

Document Page 6 of 8
7

h. Supplemental Sealed Motion/Application (Related Document(s)1325 Motion 

to Restrict Public Access to Sensitive Case Information filed by UnitedLex 

Corporation, ULX Partners, LLC) filed by David G. Barger of Greenberg 

Traurig, LLP on behalf of ULX Partners, LLC, UnitedLex Corporation. 

(Attachments: # 1 Exhibit(s) Exhibit 1 # 2 Exhibit(s) Attachment 1 # 3 

Exhibit(s) Attachment 2 # 4 Exhibit(s) Attachment 3 # 5 Exhibit(s) Attachment 

4 # 6 Exhibit(s) Attachment 5 # 7 Exhibit(s) Attachment 6 # 8 Exhibit(s) 

Attachment 7 # 9 Exhibit(s) Attachment 8 # 10 Exhibit(s) Attachment 9) 

(Barger, David) [ECF No. 1479 and ECF No. 269 in Adv. Pro. No. 20-03142]

Response Deadline: May 23,2022

Responses Filed:

Objection to ULX Partners, LLC, United Lex Corporation and 

ULX Managers, LLC's Motion to Seal Settlement Agreement and 

Related Documents, Information, and Hearings (Re: related 

document(s)1325 Motion to Restrict Public Access to Sensitive 

Case Information filed by UnitedLex Corporation, ULX Partners, 

LLC) filed by Kathryn R. Montgomery of Office of the United 

States Trustee on behalf of John P. Fitzgerald, III. (Montgomery, 

Kathryn) [ECF No. 1332]

Status:

Pursuant to the Settlement Agreement addressed in the Motion,

notwithstanding the entry of any confidentiality order, information 

as may be required to comply with the duties of the Trustee shall 

not be confidential. Accordingly, the Trustee will address the 

same with counsel for the Movant in attempt to resolve such 

issues in advance of the hearing. To the extent no resolution is 

reached, the same will be presented to the Court. In addition, the 

Trustee understands the Objection filed by John P. Fitzgerald, III 

at ECF 1332 remains unresolved and the hearing will go forward.

III. REPORTS

7. Case Status and Report pursuant to Local Rule 2015-(a)-(1)(A)

Case 19-34574-KRH Doc 1484 Filed 07/12/22 Entered 07/12/22 17:46:20 Desc Main

Document Page 7 of 8
8 

Respectfully submitted,

LYNN L. TAVENNER, CHAPTER 7 TRUSTEE

Dated: July 12, 2022

Richmond, Virginia 

By: /s/ Paula S. Beran

Paula S. Beran, Esquire (VSB No. 34679) 

PBeran@TB-LawFirm.com 

Tavenner & Beran, PLC 

20 North 8th Street

Richmond, Virginia 23219 

Telephone: (804) 783-8300 

Telecopier: (804) 783-0178 

Counsel for Lynn L. Tavenner, Chapter 7 Trustee

CERTIFICATE OF SERVICE

Pursuant to the Local Rules of this Court and applicable orders, I certify that on this 12th

day of July, 2022, a true copy of the foregoing Agenda was sent electronically to all parties 

receiving ECF notices in this Case. 

/s/ Paula S. Beran 

Counsel for Lynn L. Tavenner, Chapter 7 Trustee

Case 19-34574-KRH Doc 1484 Filed 07/12/22 Entered 07/12/22 17:46:20 Desc Main

Document Page 8 of 8