EXHIBIT A 

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SETTLEMENT AGREEMENT

THIS SETTLEMENT AGREEMENT (the “Agreement”) is made this 19th day of 

November, 2021, by and between Lynn L. Tavenner in her capacity as the Chapter 7 Trustee (the

“Trustee”) of the bankruptcy case (the “Bankruptcy Case”) of LeClairRyan PLLC on behalf of 

the bankruptcy estate (the “Estate”) of LeClairRyan PLLC, which was formerly known as LeClair 

Ryan, P.C. (collectively, “LeClairRyan”), and Elizabeth Acee, Richard Bowerman, Paul 

Burleigh, John Cahill, Mark Dombroff, Niclas Ferland, Janice Grubin, Erik Gustafson, Chris 

Lange, Jason Medley, Lori Thompson, Karol Corbin Walker, Andrew Zappia, Joseph F. 

Lagrotteria, Bryan Couch, Jeffrey Alitz, Thomas Butler, Kevin Kenneally, David Freinberg, 

Michael Hern, Gary LeClair, Lisa Murphy, Stephen Romine, Katja H. Hill, Vernon E. Inge, Jr.,

and John Reilly (collectively, the “Defendants”), and Columbia Casualty Company 

(“Columbia”). The Trustee, the Defendants, and Columbia may be referred to hereinafter

collectively as the “Parties.”

RECITALS

WHEREAS, on September 3, 2019 (the “Petition Date”), LeClairRyan filed for relief 

under Chapter 11 of Title 11 of the United States Code, 11 U.S.C. §§ 101-l532 (the “Bankruptcy

Code”) in the United States Bankruptcy Court for the Eastern District of Virginia, Richmond 

Division (the “Bankruptcy Court”). Pursuant to §§ 1007 and 1108 of the Bankruptcy Code, 

LeClairRyan operated as a debtor-in-possession;

WHEREAS, per agreement between LeClairRyan, the United States Trustee, and ABL 

Alliance, LLP, LeClairRyan’s Bankruptcy Case was converted to a case under Chapter 7 of the 

Bankruptcy Code on October 4, 2019 (the “Conversion Date”);

WHEREAS, upon conversion, Lynn L. Tavenner was appointed interim trustee, and no 

trustee having been elected at the meeting of creditors, she continues to serve as trustee;

WHEREAS, LeClairRyan’s Bankruptcy Case is presently pending in the Bankruptcy

Court;

WHEREAS, the Trustee has alleged civil and statutory claims against the Defendants

including, without limitation, Management Wrongful Acts

1

or Interrelated Wrongful Acts, 

including statutory or common law breach of fiduciary duty, trade secrets, statutory and common 

law conspiracy, or unlawful distribution in violation of Va. Code Ann. §§ 13.1-653, 13.1-690, and 

13.1–692 (the “Covered Claims”) and additional claims under Chapter 5 of the Bankruptcy Code, 

under Virginia Code §55.1-400 or Va. Code §13.1-1035, or other similar state law claims, 

including but not limited to claims for unjust enrichment, conversion, and/or unlawful distributions 

received directly or indirectly to or for the benefit of any Defendant and/or Insured Person (as 

hereafter defined) (collectively, the “Non-Covered Claims”). The Trustee has demanded, 

asserted, and/or filed adversary proceedings in the Bankruptcy Court (“Demands”) against certain

1 Capitalized terms not otherwise defined herein shall have the meanings ascribed to them in the 

Columbia Policy.

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Defendants with respect to the Covered Claims and Non-Covered Claims, including Adversary 

Proceeding Nos. 21-03069, 21-03070, 21-03071, 21-03078, 21-03079, 21-03080, 21-03081, 21-

03082, 21-03083, 21-03084, 21-03085, 21-03086, 21-03087, 21-03088, 21-03089, 21-03090, 21-

03091, 21-03092, and 20-03142 (collectively, the “Adversary Proceedings”); 

WHEREAS, Columbia and the Defendants assert that the Defendants are “Insured 

Persons” under Management Liability Policy Number 596749072 (the “Columbia Policy”) issued 

to LeClairRyan by Columbia;

WHEREAS, the Trustee, Defendants, and Columbia participated in an informal settlement 

conference on November 16, 2021 (the “Settlement Conference”);

WHEREAS, after extensive negotiations, through their respective counsel, the Trustee, the 

Defendants, and Columbia seek to fully and finally resolve the Covered Claims on the terms set 

forth herein without admission of liability; and 

WHEREAS, the Trustee, the Defendants, and Columbia have negotiated and reached this 

Agreement in good faith.

THE AGREEMENT

NOW, THEREFORE, in consideration of the mutual releases set forth herein and the 

payment of certain sums provided herein by Columbia to the Trustee and the Defendants, which 

the Trustee, the Defendants and Columbia agree is good and valuable consideration for the various 

covenants and understandings set forth in this Agreement, it is hereby agreed by the Parties as 

follows:

1. Court Approval. Upon execution of this Agreement, the Trustee shall file a 

motion in form and substance reasonably acceptable to the Defendants and Columbia seeking 

Bankruptcy Court approval of this Agreement pursuant to the Order Approving Procedures and

Permitting Trustee to Prosecute and Compromise FAO Action [Docket No. 533] (the “FAO

Order”) and Rule 9019 of the Federal Rules of Bankruptcy Procedure (the “9019 Motion”). The 

Defendants and Columbia agree to reasonably cooperate with the Trustee in obtaining approval of 

this Agreement. The 9019 Motion will relate solely to Covered Claims. To the extent any 

resolution is reached between the Trustee and any individual Defendant as to Non-Covered 

Claims, such resolution will be subject to a separate approval process provided by the FAO Order 

and will occur on a defendant-by-defendant basis. The Trustee shall file the 9019 Motion no later 

than November 19, 2021, and request a hearing on or before November 30, 2021.

2. Settlement Payment. Columbia shall pay $9,475,000 (nine million four hundred 

seventy-five thousand dollars) to Lynn L. Tavenner, Trustee of the Estate of LeClairRyan (the 

“Payment”), in full satisfaction of the Covered Claims. Said Payment shall be made after the 

Effective Date (as hereafter defined), but no later than January 28, 2022. If, however, the 9019 

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Order (as hereafter defined) is not entered on or before January 18, 2022, then the Payment will 

be made no later than ten (10) calendar days after entry of the 9019 Order.2 

3. Payment of Claim Expenses. Columbia shall not pay more than $525,000 (five 

hundred twenty-five thousand dollars) in total Claim Expenses, as that term is defined in the 

Columbia Policy (the “Claim Expenses Payments”). All Claim Expenses shall be approved and 

paid by Columbia in accordance with the Columbia Policy, and Columbia agrees to use good faith 

in reviewing the invoices submitted to determine if they constitute covered Claim Expenses. Prior 

to the payment of any Claim Expenses, Columbia shall submit supporting documentation to the 

Trustee for review and consultation, and, within seven (7) business days, the Trustee may review 

such documentation and consult with Columbia regarding the Claim Expenses; provided, however, 

that the Trustee shall not have consent or veto rights with respect to payment of any Claim 

Expenses. Columbia has the sole discretion to determine approved Claim Expenses and pay the 

Claim Expenses pursuant to and in accordance with this Agreement and the Columbia Policy. The 

Parties reserve all rights to object to any of the Claim Expenses that are not paid in accordance 

with the Columbia Policy and/or this Agreement. To the extent that the Claim Expenses of 

Defendants represented by Fox Rothschild LLP, the Zemanian Law Group, Cole Schotz P.C., 

Wolff & Orenstein, LLC (but solely with respect to fees and costs specific to Thomas Butler), 

McGuire Woods, and Venable are less than $525,000, Columbia shall distribute the remainder to 

the law firms representing the Defendants not identified previously in this sentence on a pro rata 

basis based on the invoices submitted and approved by Columbia on account of work on Covered 

Claims. The Claim Expenses Payments shall only be made simultaneously with or after the 

Payment to the Trustee as set forth in paragraph 2 above. In no event shall Columbia be required 

to pay more than $525,000 for amounts under this paragraph. 

4. Effectiveness. This Agreement shall be effective only upon entry of a final and 

non-appealable order (the “9019 Order”) by the Bankruptcy Court approving the terms and 

conditions of the Agreement as set forth in the 9019 Motion (the “Effective Date”). The proposed 

9019 Order submitted with the 9019 Motion shall include language authorizing Columbia to make 

the Payment and the Claim Expenses Payments from the limit of liability of the Columbia Policy, 

and shall state that the Payment and Claim Expenses Payments will exhaust the entire aggregate 

limit of liability under the Columbia Policy. The proposed 9019 Order shall further state that after 

making the Payment and Claim Expenses Payments, Columbia has no further obligations under 

the Columbia Policy. 

5. Release by Trustee of Defendants and Other Insured Persons. In exchange for 

the consideration reflected in this Agreement and upon receipt of the Payment, the Trustee, on

behalf of herself, the Estate, and LeClairRyan, except as otherwise set forth in this Agreement, and 

solely as to Covered Claims, hereby releases and forever discharges (a) the Defendants, (b) each 

of the Defendants’ family members, relatives, agents, officers, consultants, insurers, employees, 

2

 The Payment shall be sent via ACH transfer pursuant to the wire instructions to be

provided separately by counsel for the Trustee to counsel for Columbia. The Trustee must provide 

Columbia with wire instructions, a W-9 for payee, and verbal confirmation of wire instructions on 

or before December 15, 2021. 

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attorneys, accountants, financial advisors, and representatives of any kind, and heirs (collectively, 

the “Defendants’ Released Affiliates”), and (c) other Insured Persons3(collectively with the 

Defendants and the Defendants’ Released Affiliates, the “Releasees”) from each and every right, 

claim, debt, cause of action, demand, suit for damages, liability, legal fee, act or right of action of 

any nature whatsoever, whether asserted or unasserted, known or unknown, that LeClairRyan, the 

Estate, and/or the Trustee has made, could have made, and/or is able to make against any of the 

Releasees for all Covered Claims, as those claims are defined above, regardless of whether or not 

said Covered Claims exceed the coverage or benefits under the Columbia Policy. Nothing in this 

Agreement shall be deemed a waiver, release or discharge by the Trustee of any claims, rights, or 

actions that the Trustee, on behalf of the Estate, or the Defendants may have against any other 

former attorney, advisor, consultant, agent, employee, director, owner, member or officer of 

LeClairRyan who is not an Insured Person.

For the avoidance of doubt, nothing in this Agreement shall be deemed a waiver, release

or discharge by the Trustee of the Defendants or the Defendants’ Released Affiliates, in part or in 

whole, as to Non-Covered Claims. Further, Defendants’ Released Affiliates shall not include any 

defendant named in any other pending action brought by the Trustee or any of those defendants’ 

family members, relatives, agents, officers, consultants, insurers, employees, attorneys, 

accountants, financial advisors, and representatives of any kind, and heirs, including but not 

limited to ULX Partners, LLC, ULX Manager LLC, UnitedLex Corporation, CVC Capital 

Partners, Daniel Reed, Nicholas Hinton, and/or P. Douglas Benson.

6. Release by Defendants of Trustee. In exchange for the consideration reflected in 

this Agreement and upon the Trustee’s receipt of the Payment, the Defendants and Insured Persons

hereby release and forever discharge (i) the Trustee, (ii) the Estate, and (iii) any agents, officers, 

consultants, employees, attorneys, accountants, financial advisors, and representatives of any kind 

of the Estate and/or the Trustee (collectively, the “Trustee’s Released Affiliates”), from each and 

every right, claim, debt, cause of action, demand, suit for damages, liability, legal fee, act or right 

of action of any nature whatsoever, whether asserted or unasserted, known or unknown, that the 

Defendants made, could have made, and/or are able to make against the Trustee, the Estate, and/or 

the Trustee’s Released Affiliates for relying on Management Wrongful Acts, and for asserting, 

pursuing, settling, and/or releasing any of the Covered Claims.

Notwithstanding anything in this Agreement to the contrary (or to the extent not otherwise 

released by the Trustee or the Defendants in a separate agreement), to the extent the Trustee has 

asserted, is pursuing, or may assert or pursue a Non-Covered Claim against any Defendant or 

Insured Person, nothing in this Agreement shall preclude or act as a bar against such Defendant or 

Insured Person from asserting, solely in response to such Non-Covered Claim, any applicable 

counterclaim, third-party claim, defense, setoff right or affirmative defense to the Non-Covered 

Claim. Further, nothing in this Agreement shall be deemed a release of any such third-party claim, 

setoff right or affirmative defense to the Non-Covered Claim. In addition, nothing in this 

3 For sake of clarity, this definition of “Insured Persons” includes Janice Bowen, Everette 

Allen, Jennifer Mistal, Charles Osthimer, Patricia Peden, Thomas Regan, Robert Reklaitis, Josh 

Rosenfeld, Jeffrey O’Hara, and George Whitley, but is without prejudice to whether this person 

constitutes an “Insured Person” as defined in the Columbia Policy.

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Agreement shall be deemed a waiver of any timely filed proof of claim or claim under 11 U.S.C. 

§ 502(h) by any Defendant or a waiver of any objections to said proof of claim or claim under 11 

U.S.C. § 502(h) that has or may be raised by the Trustee.

7. Defendants’ Covenant Not to Sue Defendants. The Defendants hereby covenant 

and agree that they will not assert any claims against any of the other Defendants (as defined 

herein) arising out or related to the Covered Claims or Non-Covered Claims.

8. Release by Trustee and Defendants of Columbia. In exchange for the 

consideration reflected in this Agreement and upon the Trustee’s receipt of the Payment (and as to 

Defendants only, upon receipt of the Claim Expense Payments in accordance with paragraph 3 

above), the Trustee and Defendants hereby discharge and release Columbia and its respective 

affiliates, parents, subsidiaries, predecessors, successors, agents, officers, directors, employees, 

attorneys, reinsurers, representatives and agents, heirs, beneficiaries, and assigns and any person 

acting on its behalf from any and all claims, actions, causes of action, rights or obligations, whether 

known or unknown, whether contingent or liquidated, of every kind, nature and description that 

they now have or may have arising out of, related to, based upon, by reason of, or in any way 

involving any and all claims for coverage or insurance benefits that were made or could have been 

made under the Columbia Policy, including any claim for misrepresentation, fraud, indemnity, 

contribution, breach of contract, breach of duty, negligence, “bad faith,” violation of statute or 

regulation, unfair claims handling, attorneys’ fees, or damages of any kind whatsoever arising out 

of or relating to the Columbia Policy or any request for coverage or benefits under the Columbia 

Policy. The Trustee and Defendants acknowledge that, when the Payment and Claim Expenses 

Payments are made, the entire aggregate limit of liability of the Columbia Policy is exhausted and 

Columbia has no further obligations under the Columbia Policy. 

9. Contribution Bar. The Parties agree that the proposed 9019 Order shall include 

findings that the releases contained in the 9019 Order and this Agreement were given in good faith 

as defined in Virginia Code Section 8.01-35.1, and the Defendants shall be entitled to all of the 

applicable protections of Virginia Code Section 8.01-35.1 (the “Contribution Bar”). The Parties 

further agree that this Agreement is conditioned upon the good faith finding as defined in Virginia 

Code Section 8.01-35.1. Furthermore, the Trustee will use reasonable efforts in seeking to obtain 

Bankruptcy Court approval of the following provisions in the 9019 Order, although such approval 

is not a condition to this Agreement:

The Trustee has demonstrated that the releases, bar order, and protections 

contemplated by the Settlement Agreement are proper in scope and are either 

consensual or apply only to claims or causes of action that are either: (i) property 

of the Estate; or (ii) derivative of a right assertable by, or belonging to, the Debtor 

or Trustee. 

Upon the receipt of the Payment, all persons and entities are enjoined and barred 

from commencing or continuing any and all past, present or future claims and from 

asserting any and all allegations of liability or damages, of whatever kind, nature 

or description, direct or indirect, in law, equity or arbitration, absolute or 

contingent, in tort, contract, statutory liability or otherwise, whether or not based 

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on strict liability, negligence, gross negligence, fraud, breach of fiduciary duty or 

otherwise (including attorneys’ fees, costs or disbursements), against the 

Defendants and other Insured Persons, and their successors, advisors, attorneys, and 

insurers, including but not limited to Columbia, solely in their capacity as such 

(collectively, the “Contribution Releasees”) based on the Covered Claims.

To the extent that any person (“Petitioner”) commences any action against any of 

the Contribution Releasees either (a) asserting a claim that is based on the Covered 

Claims and where the alleged injury to such person arises from that person’s alleged 

liability to the Debtor or (b) seeking contribution or indemnity for any liability or 

expenses incurred in connection with a Covered Claim, and if such action or claim 

is not barred by a court pursuant to this Order, neither this Order nor the Settlement 

Agreement shall bar claims by the Contribution Releasee against (x) such 

Petitioner, (y) any person who is or was controlled by, controlling, or under 

common control with the Petitioner, whose assets or estate are or were controlled, 

represented, or administered by the Petitioner, or as to whose claims the Petitioner 

has succeeded, and (z) any person that participated with any of the preceding 

persons described in items (a) and (b) of this paragraph in connection with the 

assertion of the Claim brought against the Releasee(s). 

Notwithstanding anything contained in this Agreement, the injunction and bar order 

set forth above are limited in purpose, scope, and effect and is not a third-party 

“bankruptcy discharge.” It is not a release of direct third-party claims, except to the 

extent such claims were property of the Estate and derivative of the Debtor’s right 

or (i) asserted against Contribution Releasees by any person based on theories of 

joint and several liability; or (ii) for set-off, indemnity, contribution, or 

apportionment of liability under Virginia Code Section 8.01-35.1 or other 

applicable law. 

10. Dismissal. Within ten (10) calendar days of receipt of Payment, the Trustee shall 

file all necessary pleadings to effectuate the dismissal with prejudice of Covered Claims in each 

of the Adversary Proceedings in accordance with this Agreement.

11. Predecessors, Successors, and Assigns. All persons or business entities granting

releases hereby include any predecessor in interest or successor in interest of the respective grantor.

All persons or business entities released hereby include any predecessor in liability or successor

in liability for the released liability.

12. Understanding and Counsel. The Parties represent and warrant that (i) they have

read and understand the terms of this Agreement, (ii) they have been (or had the opportunity to be)

represented by counsel with respect to this Agreement and all matters covered by and relating to

it, (iii) they have entered into this Agreement for reasons of their own and not based upon

representations of any other party hereto, and (iv) they have full authority and right (provided, 

however, the Trustee’s authority is subject to the approval referenced in paragraph 1 herein) to 

grant the releases expressed in this Agreement and to bind the parties in all respects to this 

Agreement.

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13. Legal Fees and Costs. Except as otherwise set forth in this Agreement, each of 

the Parties shall pay its own respective costs and attorneys' fees incurred or to be incurred with 

respect to the Demands, Covered Claims, and Non-Covered Claims, including but not limited to 

those incurred in connection with this Agreement, settlement conferences, mediation, and/or 

attendance at any hearing in connection with this Bankruptcy Case or any related adversary 

proceedings. 

14. Entire Agreement. This Agreement constitutes the entire agreement with respect 

to the subject matter addressed in this Agreement and supersedes any prior written and/or verbal 

agreements between the Parties.

15. Amendments. This Agreement may not be orally modified. This Agreement may

only be modified in a writing signed by all of the Parties.

16. Headings. All headings and captions in this Agreement are for convenience only

and shall not be interpreted to enlarge or restrict the provisions of the Agreement.

17. Construction. As used in this Agreement, the plural shall include the singular, and 

the singular shall include the plural, unless the context or intent indicates to the contrary. "Person" 

shall include natural persons, corporations, partnerships, and/or any other entity, which by law is 

treated as or has the rights of a natural person.

18. Waiver and Modification. The failure of the Parties to insist, in any one or more

instances, upon the strict performance of any of the covenants of this Agreement, or to exercise

any option contained in this Agreement, shall not be construed as a waiver, or a relinquishment for 

the future of such covenant or option, but the same shall continue and remain in full force and 

effect. Further, nothing in this Agreement shall be deemed to be a release of the Trustee, 

Defendants, and/or Columbia for their breach of any terms and conditions of this Agreement. 

19. Jurisdiction. By this Agreement, each of the Parties submits to the jurisdiction of

the Bankruptcy Court for any action to enforce or interpret this Agreement.

20. Counterparts and Electronic Signatures. This Agreement may be executed in

counterparts and all such counterparts when so executed shall together constitute the final

Agreement as if all of the Parties had signed one document. This Agreement may be executed by

facsimile or PDF copy and each signature thereto shall be and constitute an original signature,

again as if all Parties had executed a single original document.

21. Survival. In the event any provision of this Agreement should be held to be void, 

voidable, unlawful, or for any reason unenforceable, the remaining portions hereto shall remain in 

full force and effect.

22. Further Necessary Actions. To the extent that any document is required to be

executed by any Party to effectuate the purposes of this Agreement, the Party will execute and

deliver such document or documents to the requesting Party.

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23. Actions to Enforce. Should any action be brought by one of the Parties to enforce

any provision of this Agreement, the non-prevailing party to such action shall reimburse the

prevailing party for all reasonable attorneys' fees and court costs and other expenses incurred by

the prevailing party in said action to enforce.

24. Applicable Law. This Agreement shall be construed and interpreted in accordance

with the laws of the Commonwealth of Virginia. This Agreement shall not be construed against

any of the Parties, but shall be given a reasonable interpretation.

25. No Admission of Liability. Each of the Parties understands and acknowledges 

that this Agreement constitutes a compromise and settlement of the Covered Claims as described 

in this Agreement. No action taken by any of the Parties hereto, either previously or in connection

with this Agreement, shall be deemed or construed to be an admission of the truth or falsity of any 

Covered Claims, Non-Covered Claims, or other potential claims or an acknowledgment or 

admission by any Party of any fault, wrongdoing or liability by such Party and/or any of its 

affiliates, employees, agents or representatives, and the Agreement will not be offered or used for 

any of these purposes.

[THIS PAGE IS INTENTIONALLY LEFT BLANK. SIGNATURE PAGES TO 

FOLLOW]

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The Parties hereby knowingly and voluntarily enter into this Agreement as of the date set forth 

below.

LYNN L. TAVENNER, in her capacity as trustee of the Estate of LeClairRyan PLLC

____________________________________ Date: _________________________

Lynn L. Tavenner

COLUMBIA CASUALTY COMPANY

____________________________________ Date: _________________________

By:

Name:

Its: 

ELIZABETH ACEE

___________________________________

RICHARD BOWERMAN

___________________________________

PAUL BURLEIGH

___________________________________

JOHN CAHILL

___________________________________

MARK DOMBROFF

__________________________________

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NICLAS FERLAND

___________________________________

JANICE GRUBIN

___________________________________

ERIK GUSTAFSON

___________________________________

CHRIS LANGE

___________________________________

JASON MEDLEY

___________________________________

LORI THOMPSON

___________________________________

KAROL CORBIN WALKER

___________________________________

ANDREW ZAPPIA

___________________________________

JOSEPH F. LAGROTTERIA

___________________________________

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BRYAN COUCH

___________________________________

JEFFREY ALITZ

___________________________________

THOMAS BUTLER

___________________________________

KEVIN KENNEALLY

___________________________________

DAVID FREINBERG

___________________________________

MICHAEL HERN

___________________________________

GARY LECLAIR

___________________________________

LISA MURPHY

___________________________________

STEPHEN ROMINE

___________________________________

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KATJA H. HILL

___________________________________

VERNON E. INGE, JR.

___________________________________

JOHN REILLY

___________________________________

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