J. Scott Sexton (VSB No. 29284) 

Andrew M. Bowman (VSB No. 86754) 

GENTRY LOCKE 

P.O. Box 40013 

Roanoke, Virginia 24022 

Telephone: 540.983.9300 

Fax: 540.983.9400 

Email: sexton@gentrylocke.com 

bowman@gentrylocke.com

William A. Broscious (VSB No. 27436) 

William A. Broscious, Esq., PLC 

P.O. Box 71180 

Henrico, Virginia 23255 

Telephone: 804.533.2734 

Email: wbroscious@brosciouslaw.com 

Counsel for the Former Attorney 

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29646/1/10037619v2

UNITED STATES BANKRUPTCY COURT 

EASTERN DISTRICT OF VIRGINIA 

Richmond Division 

In re: 

 

 LeClairRyan, PLLC, 

 Debtor. 

Case No.: 19-34574-KRH 

Chapter 7 

LECLAIRRYAN FORMER ATTORNEY’S MOTION TO SEAL 

A LeClairRyan, PLLC former attorney (the “Former Attorney”), by counsel, pursuant to 

Rule 9018 of the Federal Rules of Bankruptcy Procedure, hereby files this Motion to Seal and/or 

redact certain portions of his Objection to the Trustee’s Second Motion to Modify Procedures 

Regarding the Prosecution and/or Settlement of Actions Involving Former Attorneys and Certain 

Others (the “Objection”) and the exhibits thereto. In support of this Motion, the Former Attorney 

states as follows: 

1. On August 4, 2021, the Trustee informed this Former Attorney that she would seek 

to add him as a defendant in the ULX Adversary proceeding. The Trustee provided this information 

voluntarily, without any condition of confidentiality. 

2. The Trustee has now taken the position that this Former Attorney’s identity is 

“Confidential” under the terms of this Court’s FAO Order (ECF No. 533) insofar as he is a target 

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in the ULX Adversary Proceeding. See Tavenner v. ULX Partners, LLC and UnitedLex Corp. 

(“ULX Adversary Proceeding”), Adv. Proc. No. 20-03142, ECF No. 68, ¶ 4. 

3. In doing so, the Trustee has placed the Former Attorney in a situation where he 

cannot freely object to the Trustee’s Second FAO Procedures Motion without revealing his 

identity. 

4. The Trustee has expressly stated that once her motion is granted, she will unseal 

the proposed amended complaint in the ULX Adversary Proceeding and reveal this Former 

Attorney’s identity. See ULX Adversary Proceeding, ECF No. 68, ¶ 4 (“To the extent the Court 

grants the Motions, any potential concern about confidentiality will be moot, and the Trustee’s 

redacted Motion for Leave to Amend and proposed amended complaint can (and should) be 

unsealed and filed on the public docket as soon as possible.”).

5. This is fundamentally unfair because (1) the Court’s FAO Order granted every 

other former attorney (even ULX) the right to confidentially engage in mediation before having 

their name publicized in an adversary proceeding, (2) the Trustee violated the Court’s FAO Order 

by filing an amended complaint in the ULX Adversary Proceeding, and (3) the Trustee seeks to 

specifically deprive this Former Attorney of that right through the proposed changes to the FOA 

Order. 

6. Accordingly, the Former Attorney seeks entry of an order authorizing him to file 

under seal certain portions of his Objection and the exhibits thereto, and that his name not be 

mentioned at the August 19, 2021 Omnibus Hearing. 

7. Before sealing this Former Attorney’s Objection, the Court must: (1) give public 

notice of this sealing request and allow for interested parties to object; (2) consider less drastic 

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alternatives; and (3) provide specific reasons and factual findings in support of its decision. See 

Ashcraft v. Conoco, Inc., 218 F.3d 282, 288 (4th Cir. 2000). 

8. Accompanying this Motion, the Former Attorney has filed a public notice on the 

docket concerning his sealing request. 

9. This Former Attorney has narrowly redacted his Objection and exhibits thereto to 

remove only that information which would reveal his identity or discuss the content of the parties 

pre-mediation scheduling communications, as required by First Modified FAO Order. See ECF 

No. 929, ¶ 4. 

10. To the extent the Court adopts the rationale set forth in Paragraph 5, supra, it would 

provide specific reasons and factual findings supporting its sealing decision. 

11. The Former Attorney has made no prior request for the relief sought in this Motion. 

12. A copy of the proposed Order granting this Motion to Seal is attached hereto as 

Exhibit A. 

WHEREFORE, the Former Attorney, by counsel, respectfully requests the Court grant his 

Motion to Seal, authorize the filing of a redacted Objection and exhibit on the public docket, 

maintain the unredacted Objection and exhibits under seal, reference him as the “Former Attorney” 

at the August 19, 2021 Omnibus Hearing, and for such other relief as is just and proper. 

Respectfully submitted this 16th day of August, 2021. 

 FORMER ATTORNEY 

 /s/ Andrew M. Bowman 

J. Scott Sexton (VSB No. 29284) 

Andrew M. Bowman (VSB No. 86754) 

GENTRY LOCKE 

P.O. Box 40013 

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Roanoke, Virginia 24022 

Telephone: 540.983.9300 

Fax: 540.983.9400 

Email: sexton@gentrylocke.com 

 bowman@gentrylocke.com 

William A. Broscious (VSB No. 27436) 

William A. Broscious, Esq., PLC 

P.O. Box 71180 

Henrico, Virginia 23255 

Telephone: 804.533.2734 

Email: wbroscious@brosciouslaw.com 

Counsel for the Former Attorney 

 

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CERTIFICATE OF SERVICE

 I hereby certify that on this 16th day of August, 2021, I electronically filed the foregoing 

with the Clerk using the CM/ECF system which will send notification of such filing to all 

counsel of record. 

 /s/ Andrew M. Bowman 

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