Erika L. Morabito (VA Bar No. 44369) 

Brittany J. Nelson (VA Bar No. 81734) 

QUINN EMANUEL URQUHART & SULLIVAN, LLP 

1300 I Street, NW, Suite 900 

Washington, DC 20005 

Telephone: (202) 538-8334 

Special Counsel to the Chapter 7 Trustee

UNITED STATES BANKRUPTCY COURT 

EASTERN DISTRICT OF VIRGINIA 

RICHMOND DIVISION 

In re: 

LeClairRyan PLLC, 

 Debtor.1

Case No. 19-34574-KRH 

Chapter 7 

COVER SHEET FOR FIRST INTERIM APPLICATION OF QUINN EMANUEL 

URQUHART & SULLIVAN, LLP AS SPECIAL COUNSEL TO THE TRUSTEE, FOR 

ALLOWANCE OF COMPENSATION AND REIMBURSEMENT OF EXPENSES 

INCURRED 

General Information 

Name of applicant: Quinn Emanuel Urquhart & Sullivan, LLP 

Authorized to provide professional 

services to: Lynn L. Tavenner, Chapter 7 Trustee 

Date of bankruptcy filing: September 3, 2019 

Date of retention order: July 1, 2021 

First Interim Period 

Period for which compensation and 

reimbursement sought: May 18, 2021 – July 31, 2021 

Type of fee statement or application: Interim Application 

Total hours billed: 65.40 

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.

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2 

 Total hourly fees requested: $83,743.802

 Blended hourly rate (all timekeepers): $1,280.49

 Total contingent fees requested: $805,350.00

 Total expenses requested: $27,946.94

2 This amount reflects a ten (10) percent discount off of Quinn’s standard hourly rates, as stated in the Retention 

Application (defined below) and per entry of the Retention Order (defined below). 

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UNITED STATES BANKRUPTCY COURT 

EASTERN DISTRICT OF VIRGINIA 

RICHMOND DIVISION 

In re: 

LeClairRyan PLLC, 

 Debtor.1

Case No. 19-34574-KRH 

Chapter 7 

FIRST INTERIM APPLICATION OF QUINN EMANUEL URQUHART & SULLIVAN, 

LLP AS SPECIAL COUNSEL TO THE TRUSTEE, FOR ALLOWANCE OF 

COMPENSATION AND REIMBURSEMENT OF EXPENSES INCURRED 

Quinn Emanuel Urquhart & Sullivan, LLP (“Quinn”), special counsel to Lynn L. Tavenner, 

and 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”), respectfully represents: 

I. INTRODUCTION

1. Quinn hereby submits this first interim application (the “Application”) for interim 

allowance of compensation for professional services rendered and actual and necessary expenses 

incurred by Quinn as special counsel to the Trustee for certain professional services in the period 

May 18, 2021 through July 31, 2021 (the “First Interim Period”) pursuant to sections 330 and 331 

of chapter 11 of title 11 of the United States Code (the “Bankruptcy Code”), the Federal Rules of 

Bankruptcy Procedure (the “Bankruptcy Rules”) and Rule 2016-1 of the United States 

Bankruptcy Court for the Eastern District of Virginia Local Bankruptcy Rules (the “Local Rules”). 

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. 

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10750-00001/12913641.8 2 

II. BACKGROUND 

2. On September 3, 2019 (the “Petition Date”), the Debtor filed for relief under 

chapter 11 of the Bankruptcy Code. Pursuant to §§ 1107 and 1108 of the Bankruptcy Code, the 

Debtor was operating its business as a debtor-in-possession. 

3. On September 12, 2019, the United States Trustee filed its Motion to Convert Case 

to Chapter 7 (the “Motion to Convert”) and notice thereof [ECF No. 61]. At a hearing on 

September 26, 2019, the Court denied the Motion to Convert. However, per agreement between 

the Debtor, the United States Trustee, and ABL Alliance, LLP (the “Lender”) as stated in the 

Order on Motion to Convert Case to Chapter 7, the Case was converted to a case under Chapter 7 

of the Bankruptcy Code on October 4, 2019 [ECF No. 140]. 

4. On June 7, 2021, the Trustee filed Trustee’s Application to Retain and Employ 

Quinn Emanuel Urquhart & Sullivan, LLP as Special Counsel [ECF No. 908] (the “Retention 

Application”). On June 28, 2021, the Court entered its Order Authorizing the Retention and 

Employment of Quinn Emanuel Urquhart & Sullivan, LLP as Special Counsel [ECF No. 939] (the 

“Retention Order”), retroactive to May 18, 2021. 

5. Pursuant to the Retention Application and Retention Order, the Estate will 

compensate Quinn during the Investigative Phase (as defined in the Retention Application and 

Retention Order) on an hourly basis (the “Administrative Fees”). During the Litigation Phase (as 

defined in the Retention Application and Retention Order), the Estate will compensate Quinn, 

subject to the professional responsibility and other rules governing its practice, based on the total 

recoveries on claims or causes of action or the net value to the Estate of any release of claims 

against the Estate (the “Recoveries”). Quinn shall receive thirty percent (35%) of the recoveries 

(the “Contingent Fees”). 

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10750-00001/12913641.8 3 

III. JURISDICTION, VENUE, AND PREDICATES FOR RELIEF

6. This Court has jurisdiction over this Application pursuant to 28 U.S.C. §§ 157 and 

1334. This is a core proceeding within the meaning of 28 U.S.C. § 157(b)(2). Venue in this district 

is proper pursuant to 28 U.S.C. §§ 1408 and 1409. 

7. The predicates for the relief requested in this Application are sections 330, and 331 

of the Bankruptcy Code, Bankruptcy Rule 2016, and Local Rule 2016-1. 

IV. RELIEF REQUESTED 

8. By this Application, Quinn respectfully requests that the Court enter an order (a) for 

interim allowance of reasonable compensation for certain of the actual, reasonable, and necessary 

professional services that it has rendered as special counsel to the Trustee in this Case for the 

Administrative Fees during the First Interim Period in the amount of $83,743.80 (the “Interim 

Administrative Fees”), (b) for reimbursement of actual, reasonable and necessary expenses 

incurred in representing the Trustee during the First Interim Period in the amount of $27,946.94, 

and (c) for payment of $805,350 for Contingent Fees.2

9. A summary schedule of compensation by timekeeper during the First Interim 

Period is attached hereto as Exhibit B. A summary schedule of hours and fees covered during the 

First Interim Period, categorized by project code is attached hereto as Exhibit C. A summary 

schedule of the expense reimbursements requested by category is attached hereto as Exhibit D. A 

2 As will be described more fully in the forthcoming (a) the Second Notice of Proposed FAO Settlements filed under 

seal, (b) the Notice of Filing Under Seal of Proposed FAO Settlements. and (c) future notices of settlement and/or 

Bankruptcy Rule 9019 motions that may be filed in connection with future settlements requiring court approval, the 

Estate will receive certain settlement payments after the date hereof. For the sake of clarity, in this Application, Quinn 

seeks payment of Contingent Fees only after the relevant settlements have been approved and the Estate has received 

the relevant settlement payments. In addition, with respect to future recoveries, Quinn reserves the right to apply 

for the payment of additional Contingent Fees for work that was performed during the First Interim Period. 

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10750-00001/12913641.8 4 

chart containing information related to the recoveries related to FAO Actions is attached hereto as 

Exhibit E.

3

V. BASIS FOR RELIEF REQUESTED 

10. In addition to the contingency work for which Quinn is not seeking payment at this 

time, during the First Interim Period, Quinn provided the following services to, and as requested 

by, the Trustee: (i) investigation of potential claims, including but not limited to, Chapter 5 claims, 

fraudulent transfers, excessive compensation, breaches of fiduciary duty, and/or unjust 

enrichment; (ii) made recommendations to the Trustee that included, among other things, proposed 

next steps as it relates to the prosecution of some or all of the claims; and (iii) settlement of certain 

claims. 

11. In performing the services detailed in this Application, Quinn has endeavored to 

ensure that its professionals comply with the applicable provisions of the Bankruptcy Code, the 

Bankruptcy Rules, the Local Rules, and any other applicable procedures or orders of the Court. 

12. Quinn has not made any prior request for payment of professional fees earned and 

expenses incurred during the First Interim Period. Except as provided in the Retention 

Application and Retention Order, Quinn has not received any payments on account of such fees or 

expenses. 

13. In accordance with Bankruptcy Rule 2016 and Local Rule 2016-1, a detailed 

chronological itemization of the services rendered by each professional and paraprofessional, 

calculated by tenths of an hour and categorized in accordance with the appropriate project code 

3 Pursuant to the Order Approving Procedures and Permitting Trustee to Prosecute and Compromise FAO Actions 

[ECF No. 533] (the “Procedures Order”), Exhibit E will be filed separately under seal using the sealed document 

docketing event in the ECF system pursuant to CM/ECF Policy 6. See Procedures Order ¶ 4.

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10750-00001/12913641.8 5 

and a detailed chronological itemization of the expenses incurred by Quinn during the First Interim 

Period are attached hereto as Exhibit F. 

14. Quinn has endeavored to represent the Trustee in the most expeditious and 

economical manner possible. Tasks have been assigned to attorneys and paralegals at Quinn so 

that the work has been performed by those most familiar with the particular matter or task and, 

where attorney involvement was required, by the lowest hourly rate professional appropriate for a 

particular matter. Moreover, Quinn has endeavored to coordinate with other professionals involved 

in this Case so as to minimize any duplication of effort and to minimize attorneys’ fees and 

expenses. Quinn believes it has been successful in this regard. 

15. No agreement or understanding exists between Quinn and any other person for the 

sharing of compensation received or to be received for services rendered in connection with this 

Case. 

VI. NOTICE 

16. Notice of this Application has been provided to all necessary parties in accordance 

with the Case Management Procedures and the Compensation Procedures. Quinn submits that no 

other or further notice need be provided. 

17. No previous application for the relief sought in this Application has been made to 

this or any other court. 

18. Quinn has reviewed the requirements of the Local Rules and certifies that this 

Application complies with the applicable provisions of the Bankruptcy Code, Bankruptcy Rules, 

and Local Rules. 

WHEREFORE, Quinn hereby respectfully requests that this Court enter an order, 

substantially in the form attached hereto as Exhibit A, (i) approving this Application; (ii) awarding 

Quinn, on an interim basis, Interim Administrative Fees in the amount of $83,743.80 and 

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reimbursement of actual, reasonable, and necessary expenses incurred by Quinn during the First 

Interim Period in the amount of $27,946.94; (iv) awarding Quinn, on an interim basis, Contingent 

Fees in the amount of $805,350; (v) authorizing the Trustee to pay Quinn the amount of Interim 

Administrative Fees and Contingent Fees approved by the Court, when the Trustee deems such 

funds are available; and (vi) granting such other relief as the Court deems proper and just. 

Dated: September 2, 2021 Respectfully submitted, 

/s/ Erika L. Morabito 

Erika L. Morabito (VSB No. 44369) 

Brittany J. Nelson (VSB No. 81734) 

QUINN EMANUEL URQUHART 

 & SULLIVAN, LLP 

1300 I Street, NW, Suite 900 

Washington, DC 20005 

(202) 538-8000 (telephone) 

(202) 538-8100 (facsimile) 

erikamorabito@quinnemanuel.com 

Special Counsel to Lynn L. Tavenner, the Chapter 7 

Trustee of the Estate of LeClairRyan PLLC

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CERTIFICATE OF SERVICE 

I hereby certify that on the 2nd day of September 2021, a true copy of the foregoing 

Application was served via first-class and/or electronic mail to Kenneth N. Whitehurst, III, 

Assistant United States Trustee, and all parties receiving ECF notices. Notification of the filing 

of the Application and amounts sought therein will be served on (a) the Debtor’s 20 Largest 

Unsecured Creditors; (b) all known secured creditors from the Debtor’s Official Form 106D; 

(c) the Core Parties and 2002 List as defined in the Case Management Order; and (d) all parties 

requesting service of pleadings in this Case (as indicated on Schedule A attached to the Court filed 

copy of said notice). 

/s/ Erika L. Morabito 

Special Counsel to the Chapter 7 Trustee 

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