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

AUGUST 19, 2021, AT 11:00 A.M. (PREVAILING EASTERN TIME)

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

Huennekens, United States Bankruptcy Judge, in Room 5000, United States Courthouse, 701 East 

Broad Street, Richmond, Virginia 23219, on August 19, 2021, beginning at 11:00 a.m. via Zoom:

Zoom registration link:

https://www.zoomgov.com/meeting/register/vJItcuyurT4uGUza77r1a7XmQbZhJCVxE1M

Listen-only conference line:

Dial: 1-866-590-5055

Access Code: 4377075

Security Code: 81921

I. MATTERS IN THE MAIN CASE

1. Motion for Relief from Stay Re: Insurance Policy filed by Rebecca L. Saitta of Wiley Rein 

LLP on behalf of Columbia Casualty Company. (Attachments: # 1 Exhibit(s) A 

# 2 Proposed Order) (Saitta, Rebecca) [ECF No. 857]

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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Related documents: 

a. Notice of Motion and Notice of Hearing (Re: related document(s)857 Motion for 

Relief from Stay filed by Columbia Casualty Company) filed by Rebecca L. Saitta 

of Wiley Rein LLP on behalf of Columbia Casualty Company. Hearing scheduled 

for 6/24/2021 at 11:00 AM at Judge Huennekens' Courtroom, 701 E. Broad St., 

Rm. 5000, Richmond, Virginia. (Attachments: # 1 Exhibit(s) A)(Saitta, Rebecca) 

[ECF No. 859]

b. Hearing held; final hearing set; Declaration of Lynn Tavenner #924 Admitted. 

Appearance(s): Paula Beran for Trustee; Rebecca Saitta for Columbia Casualty 

Company (Re: related document(s)857 Motion for Relief from Stay filed by 

Columbia Casualty Company) Hearing scheduled for 7/22/2021 at 01:00 PM at 

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

(Gary, Lisa) [ECF No. 927]

c. Exhibit (Re: related document(s)857 Motion for Relief from Stay filed by 

Columbia Casualty Company) filed by Rebecca L. Saitta of Wiley Rein LLP on 

behalf of Columbia Casualty Company. (Saitta, Rebecca) [ECF No. 951]

d. Hearing held and continued; Declaration of Lynn Tavenner 949 Admitted. 

Appearance(s): Paula Beran for Trustee; Rebecca Saitta for Columbia Casualty 

Company (Re: related document(s)857 Motion for Relief from Stay filed by 

Columbia Casualty Company) Hearing scheduled for 8/19/2021 at 11:00 AM at 

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

(Gary, Lisa) [ECF No. 954]

e. Stipulation Granting Relief From Automatic Stay By Columbia Casualty Company 

and Between Trustee (Re: related document(s)857 Motion for Relief from Stay 

filed by Columbia Casualty Company) filed by Rebecca L. Saitta of Wiley Rein 

LLP on behalf of Columbia Casualty Company. (Attachments: # 1 Exhibit(s) 

A)(Saitta, Rebecca) [ECF No. 965] 

Response Deadline: June 17, 2021

Responses Filed:

Objection to - TRUSTEES ANSWER AND LIMITED 

OBJECTION TO THE MOTION FOR RELIEF FROM THE 

AUTOMATIC STAY (Re: related document(s)857 Motion for 

Relief from Stay filed by Columbia Casualty Company) filed by 

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

Tavenner. (Beran, Paula) [ECF No. 921]

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Status:

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

order (as found at ECF No. 965) that allows the Motion to be 

granted under modified terms. 

2. Motion to Approve - TRUSTEES SECOND MOTION TO MODIFY PROCEDURES 

REGARDING THE PROSECUTION AND/OR SETTLEMENT OF ACTIONS INVOLVING 

FORMER ATTORNEYS AND CERTAIN OTHERS AND MEMORANDUM IN SUPPORT 

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

Tavenner. (Beran, Paula) [ECF No. 962]

Related documents:

a. Motion to Approve (Trustee's Motion for an Order Establishing Procedures 

Regarding the Prosecution of Actions Involving Former Attorneys and Certain 

Others and Memorandum in Support Thereof) filed by Paula S. Beran of Tavenner 

& Beran, PLC on behalf of Lynn L. Tavenner. (Beran, Paula) [ECF No. 457]

b. Notice of Motion and Notice of Hearing (Re: related document(s)962 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 8/19/2021 at 11:00 AM 

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

(Beran, Paula) [ECF No. 963]

Response Deadline: August 16, 2021

Responses Filed:

Objection to Trustee's Second Motion to Modify Procedures 

Regarding the Prosecution and/or Settlement of Actions Involving 

Former Attorneys and Certain Others (Re: related 

document(s)962 Motion to Approve filed by Lynn L. Tavenner) 

filed by Paul A. Driscoll of Zemanian Law Group on behalf of 

Lisa M. Murphy. (Attachments: # 1Exhibit(s) Letter electing 

mediation # 2 Exhibit(s) E-mail acknowledging mediation 

election) (Driscoll, Paul) [ECF No. 967]

Filed on behalf of former attorney - Objection to (Re: related 

document(s)962 Motion to Approve filed by Lynn L. Tavenner) 

filed by Andrew M. Bowman of Gentry Locke on behalf of 

Former Attorney. (Attachments: # 1 Exhibit(s) A (Redacted) 

# 2 Exhibit(s) B (Redacted) # 3Exhibit(s) C (Redacted) 

# 4 Exhibit(s) D (Redacted)) (Bowman, Andrew) [ECF No. 968]

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Filed on behalf of former attorney - Motion to File Document(s) 

Under Seal (Related Document(s)968 Objection to 

Motion/Application filed by Former Attorney) filed by Andrew 

M. Bowman of Gentry Locke on behalf of Former Attorney. 

(Attachments: # 1 Exhibit(s) A) (Bowman, Andrew) [ECF No. 

969]

Filed on behalf of former attorney - Notice of Motion and Notice 

of Hearing (Re: related document(s)969 Motion to File 

Documents(s) Under Seal filed by Former Attorney) filed by 

Andrew M. Bowman of Gentry Locke on behalf of Former 

Attorney. Hearing scheduled for 8/19/2021 at 11:00 AM at Judge 

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

Virginia. (Bowman, Andrew) [ECF No. 970]

Filed on behalf of former attorney - Sealed Objection (Related 

Document(s)968 Objection to Motion/Application filed by 

Former Attorney) filed by Andrew M. Bowman of Gentry Locke 

on behalf of Former Attorney. (Attachments: # 1 Exhibit(s) A 

# 2 Exhibit(s) B # 3 Exhibit(s) C # 4Exhibit(s) D) (Bowman, 

Andrew) [ECF No. 971]

Status:

The Trustee will request that this Court invoke an express

provision of the FAO Order and authorize the modification of 

certain discrete aspects of the FAO Actions Procedures (all as 

defined in the Second Motion To Modify Procedures). 

3. Motion to Authorize Disclosure of Certain Settlement Materials filed by Erika L. 

Morabito of Quinn Emanuel on behalf of Lynn L. Tavenner. (Morabito, Erika) [ECF No. 

944] and Adversary Proceeding No. 20-03142 (ULX Partners, LLC, UnitedLex 

Corporation) [ECF No. 55] 

Related documents: 

a. Notice of Motion (Re: related document(s)944 Motion to Authorize filed by Lynn 

L. Tavenner) filed by Erika L. Morabito of Quinn Emanuel on behalf of Lynn L. 

Tavenner. (Morabito, Erika) [ECF No. 945] [ECF No. 56] 

b. Hearing held and continued; Declaration of Lynn Tavenner 949 Admitted. 

Appearance(s): ): Erika Morabito for Trustee; Thomas McKee for ULX Partners, 

LLC (Re: related document(s)944 Motion to Authorize filed by Lynn L. 

Tavenner) Hearing scheduled for 8/19/2021 at 11:00 AM at Judge Huennekens' 

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Courtroom, 701 E. Broad St., Rm. 5000, Richmond, Virginia. (Gary, Lisa) [ECF 

No. 953]

Response Deadline: July 19, 2021 

Responses Filed: None 

Status: The Trustee will request that the Court enter an Order granting 

the Motion as modified.

II. MATTERS IN ADVERSARY PROCEEDINGS 

4. Adversary Proceeding No. 20-03142 (ULX Partners, LLC, UnitedLex Corporation) –

Motion to File Document(s) Under Seal (Re: related document(s)66 Motion to Amend 

filed by Lynn L. Tavenner, as Chapter 7 Trustee) filed by Erika L. Morabito of Quinn 

Emanuel on behalf of Lynn L. Tavenner, as Chapter 7 Trustee. (Attachments: 

# 1 Exhibit(s)) (Morabito, Erika) [ECF No. 68]

Related documents:

a. Motion to Amend Complaint and to Modify Pretrial Scheduling Order (Re: 

related document(s)1 Complaint filed by Lynn L. Tavenner, as Chapter 7 Trustee) 

filed by Erika L. Morabito of Quinn Emanuel on behalf of Lynn L. Tavenner, as 

Chapter 7 Trustee. (Attachments: # 1 Exhibit(s)) (Morabito, Erika) [ECF No. 66]

b. Notice of Motion and Notice of Hearing (Re: related document(s)68 Motion to 

File Documents(s) Under Seal filed by Lynn L. Tavenner, as Chapter 7 Trustee) 

filed by Erika L. Morabito of Quinn Emanuel on behalf of Lynn L. Tavenner, as 

Chapter 7 Trustee. Hearing scheduled for 8/19/2021 at 11:00 AM at Judge 

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

(Morabito, Erika) [ECF No. 69]

c. Sealed Motion/Application (Related Document(s)66 Motion to Amend filed by 

Lynn L. Tavenner, as Chapter 7 Trustee, 68 Motion to File Documents(s) Under 

Seal filed by Lynn L. Tavenner, as Chapter 7 Trustee) filed by Erika L. Morabito 

of Quinn Emanuel on behalf of Lynn L. Tavenner, as Chapter 7 Trustee. 

(Attachments: # 1 Exhibit(s)) (Morabito, Erika) [ECF No. 70]

d. Sealed Motion/Application(Re: related document(s)70 Sealed Document filed by 

Lynn L. Tavenner, as Chapter 7 Trustee, 73 Motion to Amend filed by Lynn L. 

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Tavenner, as Chapter 7 Trustee) filed by Erika L. Morabito of Quinn Emanuel on 

behalf of Lynn L. Tavenner, as Chapter 7 Trustee. (Attachments: # 1 Exhibit(s)) 

(Morabito, Erika) [ECF No. 74]

Response Deadline: August 16, 2021

Responses Filed: None

Status:

The Trustee will ask the Court to enter an Order authorizing her 

to file under seal certain portions of the Motion for Leave to 

Amend Complaint and to Modify Pretrial Scheduling Order, as 

well as to file under seal in its entirety the proposed amended 

complaint.

5. Adversary Proceeding No. 20-03142 (ULX Partners, LLC, UnitedLex Corporation) –

Motion to Amend Complaint and to Modify Pretrial Scheduling Order (Re: related 

document(s)1 Complaint filed by Lynn L. Tavenner, as Chapter 7 Trustee) filed by Erika 

L. Morabito of Quinn Emanuel on behalf of Lynn L. Tavenner, as Chapter 7 Trustee. 

(Attachments: # 1 Exhibit(s)) (Morabito, Erika) [ECF No. 66]

Related documents:

a. Notice of Motion and Notice of Hearing (Re: related document(s)66 Motion to 

Amend filed by Lynn L. Tavenner, as Chapter 7 Trustee) filed by Erika L. 

Morabito of Quinn Emanuel on behalf of Lynn L. Tavenner, as Chapter 7 Trustee. 

Hearing scheduled for 8/19/2021 at 11:00 AM at Judge Huennekens' Courtroom, 

701 E. Broad St., Rm. 5000, Richmond, Virginia. (Morabito, Erika) [ECF No. 67]

b. Sealed Motion/Application (Related Document(s)66 Motion to Amend filed by 

Lynn L. Tavenner, as Chapter 7 Trustee, 68 Motion to File Documents(s) Under 

Seal filed by Lynn L. Tavenner, as Chapter 7 Trustee) filed by Erika L. Morabito 

of Quinn Emanuel on behalf of Lynn L. Tavenner, as Chapter 7 Trustee. 

(Attachments: # 1 Exhibit(s)) (Morabito, Erika) [ECF No. 70]

c. Corrected Motion to Amend Complaint and to Modify Pretrial Scheduling 

Order (Re: related document(s)66 Motion to Amend filed by Lynn L. Tavenner, as 

Chapter 7 Trustee) filed by Erika L. Morabito of Quinn Emanuel on behalf of Lynn 

L. Tavenner, as Chapter 7 Trustee. (Attachments: # 1 Exhibit(s)) (Morabito, Erika) 

[ECF No. 73]

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e. Sealed Motion/Application(Re: related document(s)70 Sealed Document filed by 

Lynn L. Tavenner, as Chapter 7 Trustee, 73 Motion to Amend filed by Lynn L. 

Tavenner, as Chapter 7 Trustee) filed by Erika L. Morabito of Quinn Emanuel on 

behalf of Lynn L. Tavenner, as Chapter 7 Trustee. (Attachments: # 1 Exhibit(s)) 

(Morabito, Erika) [ECF No. 74]

Response Deadline: August 16, 2021

Responses Filed:

Objection to (Re: related document(s)66 Motion to Amend filed 

by Lynn L. Tavenner, as Chapter 7 Trustee) filed by Thomas John 

McKee Jr. of Greenberg Traurig on behalf of ULX Partners, LLC, 

UnitedLex Corporation. (McKee, Thomas) [EF No. 75]

Motion to File Document(s) Under Seal (Re: related 

document(s)75 Objection to Motion/Application filed by ULX 

Partners, LLC, UnitedLex Corporation) filed by Thomas John 

McKee Jr. of Greenberg Traurig on behalf of ULX Partners, LLC, 

UnitedLex Corporation. (Attachments: # 1 Proposed Order) 

(McKee, Thomas) [ECF No. 76]

Notice of Hearing (Re: related document(s)76 Motion to File 

Documents(s) Under Seal filed by ULX Partners, LLC, 

UnitedLex Corporation) filed by Thomas John McKee Jr. of 

Greenberg Traurig on behalf of ULX Partners, LLC, UnitedLex 

Corporation. Hearing scheduled for 8/19/2021 at 11:00 AM at 

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

Richmond, Virginia. (McKee, Thomas) [ECF No. 77]

Sealed Objection (Re: related document(s)75 Objection to 

Motion/Application filed by ULX Partners, LLC, UnitedLex 

Corporation) filed by Thomas John McKee Jr. of Greenberg 

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

(McKee, Thomas) [ECF No. 78]

Status:

The Trustee will ask the Court to grant the Motion to Amend 

Complaint and to Modify Pretrial Scheduling Order and enter an 

Order (i) granting the Trustee leave to file an amended complaint 

and (ii) amend the Second Pretrial Order as appropriate. 

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IV. REPORTS

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

Respectfully submitted,

LYNN L. TAVENNER, CHAPTER 7 TRUSTEE

Dated: August 17, 2021

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 17th

day of August 2021, 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

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