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

Tavenner & Beran, PLC 

20 North Eighth Street, Second Floor

Richmond, Virginia 23219

Telephone: (804) 783-8300

Facsimile: (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.

LeClairRyan, PLLC,1 19-34574-KRH

Debtor Chapter

7

MOTION TO EXPEDITE HEARING 

AND MEMORANDUM IN SUPPORT THERETO 

Lynn L. Tavenner, Trustee, not individually, but solely in her capacity as the Chapter 7 

trustee (in such capacity, 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”) 

hereby moves, by counsel, (the “Expedited Hearing Motion”) the Court for the entry of an order 

pursuant to Local Bankruptcy Rule 9013-1(N) granting an expedited hearing on her Trustee’s 

Application to Retain and Employ Cozen O'Connor as Special Counsel (the “Cozen O’Connor 

Employment Application”) and Trustee’s Supplement to Application to Retain and Employ 

Quinn Emanuel Urquhart & Sullivan, LLP as Special Counsel (the “Quinn Emanuel 

Supplemental Employment Application,” together with the Cozen O’Connor Employment 

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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Application, the “Applications”)2 In support of this Expedited Hearing Motion, the Trustee 

respectfully represents as follows: 

JURISDICTION

1. The United States Bankruptcy Court for the Eastern District of Virginia (the 

“Court”) has jurisdiction over this matter pursuant to 28 U.S.C. §§ 157 and 1334 and the Standing 

Order of Reference from the United States District Court for the Eastern District of Virginia, dated 

August 15, 1984. 

2. This is a core proceeding pursuant to 28 U.S.C. § 157(b)(2). 

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

BACKGROUND FOR REQUESTED RELIEF

4. As the Trustee has represented to the Court on several occasions, the Trustee 

previously determined that she needed the advice and guidance of experienced legal counsel to 

carry out her duties under the Bankruptcy Code, specifically to investigate and pursue certain 

litigation claims. The Trustee believed (and continues to believe) that these potential litigation 

claims may be of substantial value but required the assistance of counsel to assist in her 

investigation, evaluation, and, if necessary, pursuit of such claims. 

5. Accordingly, on January 30, 2020, the Trustee filed an application to employ the 

law firm of Foley & Lardner LLP (“Foley”) as special counsel to investigate and pursue potential 

claims, which the Court approved on February 10, 2020, retroactive to January 30, 2020 [ECF 

Nos. 300, 342]. Beginning January 30, 2020, Ms. Erika L. Morabito, on behalf of Foley, served 

2 Capitalized terms not otherwise defined shall have the meanings given them in the Applications. 

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as the lead special counsel to the Trustee. In addition, Ms. Brittany J. Nelson, also on behalf of 

Foley, represented the Trustee.

6. On May 18, 2021, Ms. Morabito and Ms. Nelson joined Quinn Emanuel Urquhart 

& Sullivan, LLP (“Quinn Emanuel”). After being informed of Ms. Morabito and Ms. Nelson’s 

relocation from Foley to Quinn Emanuel, the Trustee conducted due diligence with respect to the 

Estate’s ongoing special litigation needs and, in the exercise of her business judgment and 

consistent with her duties, selected, subject to Court approval, Quinn Emanuel to represent her as 

special counsel going forward in this Case on the vast majority of unresolved matters based on its 

considerable experience in insolvency, bankruptcy, and litigation matters, as well as its 

considerable experience in internal investigations. As such, on June 7, 2021, the Trustee filed

Trustee’s Application to Retain and EmployQuinn Emanuel Urquhart & Sullivan, LLP as Special 

Counsel [ECF No. 908] (the “Quinn 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. 937] (the “Quinn Retention Order”), retroactive to

May 18, 2021.

7. To date, in connection with the Trustee’s retention and assistance of special 

counsel, the Estate has recovered in excess of $19,000,000.00.

8. In addition, with the significant assistance of Quinn Emanuel, after mediating for 

more than two and a half months, litigating for over a year and half, and engaging in hard fought, 

arms-length negotiations with multiple parties, aided in large part by a substantial amount of hours 

(more than 100) expended by the judicial mediator (the “Judicial Mediator”) in this Case (who 

happens to be the Chief Bankruptcy Judge in this District), the Trustee, all of the defendants in two 

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separate adversary proceedings, and certain insurers reached a global, comprehensive $21,000,000 

agreement (the “Judicially Mediated Global Settlement”), that is a fair and reasonable 

compromise of the claims and causes of action asserted by the Trustee in those two separate 

adversary proceedings. The Judicially Mediated Global Settlement was the result of a mediator’s 

proposal that was to either be accepted or rejected in total. The Trustee in the exercise of her 

business judgment determined that acceptance was in the best interest of the Estate because, among 

other things, this settlement avoids lengthy, complex, and expensive litigation of a myriad disputed 

issues among these parties, and provides for a significant amount of money that likely could 

provide for a meaningful distribution to unsecured creditors. 

9. As such, the Trustee sought this Court’s approval of the Judicially Mediated Global 

Settlement by filing Trustee’s Motion and Memorandum of Law for Entry of an Order (I) 

Approving (A) Judicially Mediated Settlement and (B) Compensation to Counsel Including an 

Improvident Payment under Section 328(a); and (II) Granting Related Relief [ECF No. 1328] (the 

“Judicially Mediated Settlement Motion”).

10. Prior to the filing of the Judicially Mediated Settlement Motion, upon hearing of 

the salient terms relayed by the parties in open Court, the Office of the United States Trustee (the 

“UST” and/or the “Program”) expressed concerns to the Trustee with respect to the Judicially 

Mediated Settlement, which the Trustee immediately tried to address, to no avail. Ultimately, the 

UST propounded discovery upon the Trustee [ECF 1335]. Finding herself in the precarious 

position at odds with the UST(a position she has never experienced in her (a) 25 years of serving 

as a Chapter 7 Trustee and (b) over 30 years as a member of this Court’s bankruptcy community), 

the Trustee sought and received assistance from the Judicial Mediator in an effort to address the 

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UST’ s issues. Through this process the Trustee addressed certain concerns articulated by the UST, 

provided all of the information that had been requested by the UST, answered all questions posed 

by UST, and learned that no additional documents or other information was needed from the 

Trustee. At the conclusion of such process, the Trustee understood that, while the UST would have 

preferred a different structure for the settlement embodied in the Judicially Mediated Settlement 

Motion, it recognized the unique circumstances that resulted in the same. Nevertheless, the UST 

persisted with its objection [ECF Nos. 1333 and 1370] (the “US Trustee Objection”). 

11. At the hearing on the Judicially Mediated Settlement Motion on June 8, 2022, after 

(a) receiving and reviewing extensive evidence from the Trustee and (b) hearing respective 

arguments of counsel, this Court took the matter under advisement. On June 28, 2022, this Court 

approved the Judicially Mediated Global Settlement by entering Order Granting Motion and 

Memorandum of Law for Entry of an Order (I) Approving (A) Judicially Mediated Settlement and 

(B) Compensation to Counsel Including an Improvident Payment Under Section 328(a); and (II) 

Granting Related Relief [ECF No. 1453], and issuing an accompanying Memorandum Opinion

[ECF No. 1452] (collectively, the “Judicially Mediated Settlement Ruling”).

12. Upon receipt of the Judicially Mediated Settlement Ruling, recognizing that the 

Estate was now poised to receive additional substantial sums and in a position to significantly 

reduce expenses, the Trustee focused upon estate administrative items and a path forward to 

address claims including but not limited to the most immediate potential administrative claims of 

Iron Mountain. The Trustee also reached out to the Acting Assistant United States Trustee for 

Region 4 to thank him for his professionalism and that of his Richmond office in connection with 

a difficult task that she understood the UST program believed was in the best interest of the 

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bankruptcy system. Upon receipt of a very kind response, acknowledging the great result for the 

Estate, the Trustee progressed forward with the belief that the UST was satisfied with the Judicially 

Mediated Settlement Ruling and the added benefit that the UST believed its program had 

contributed to the process. 

13. As a result, the Trustee was surprised when the UST appealed the Judicially 

Mediated Settlement Ruling by filing a Notice of Appeal on the docket in this Case at ECF No. 

1480 on July 11, 2022, thereby initiating Civil Action No. 3:22cv 4943 (the “Judicially Mediated 

Global Settlement Appeal”). 

14. The Trustee immediately recognized and was concerned (and now creditors have 

expressed similar concerns) about the negative impact on the Estate and potential distributions to 

creditors resulting from the UST’s Judicially Mediated Global Settlement Appeal. As such, the 

Trustee has attempted on numerous occasions to explain the concerns with supporting facts to the 

UST with the hope that, once recognizing the significance of the potential impact compared with 

little, if any, upside benefit to its program, the UST would reconsider its path forward. To date, the 

UST has not appeared interested in receiving any such information about the impact on case 

administration. And it has not altered its path forward. Thus, the Trustee has no alternative but to 

expend the Estate’s resources to defend the Judicially Mediated Global Settlement Appeal. After 

all, it involves a $21,000,000 settlement that all parties in interest who have verbalized an opinion 

maintain is, at a minimum, a great result for the Estate and which the Trustee maintains will likely 

yield sufficient funds to make a meaningful distribution to general unsecured creditors. 

3 The Applications incorrectly note this appeal with the case number Civil Action No. 3:22cv328

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15. On July 14, 2022, in a bench ruling (the “Oral Seal Ruling”), this Court indicated 

that it would grant as modified a Motion to Seal Settlement Agreement and Related Documents, 

Information, and Hearings [ECF. No. 1325] and Supplement to Their Previously-Filed Motion to 

Seal Settlement Agreement and Related Documents, Information, and Hearings [ECF No. 1479] 

filed by the ULX Partners, LLC, UnitedLex Corporation, and ULX Manager, LLC. In connection 

with the same, this Court indicated that it would write an opinion for the benefit of the District 

Court if any party intended to appeal. Without providing this Court the opportunity to write that 

opinion, before entry of any order by this Court, and with no professional courtesy notice to the 

Trustee, the UST filed a premature notice of appeal of the Court’s Oral Seal Ruling, thereby 

initiating Civil Action No. 3:22cv515 (the “Premature Seal Appeal”). As such, the Trustee also 

will have to expend additional resources to ensure that the Estate is protected in connection with 

the Premature Seal Appeal. 

16. Pursuant to the Quinn Retention Order as found in the engagement letter attached 

to the Quinn Retention Application, 

In the event that the result of any Claim at the trial level is appealed, QEU&S would 

be pleased to represent the Trustee in such appeal on mutually agreeable terms, 

subject to Court approval, if the Trustee believes it would be in the best interest of 

the Estate. We understand the Trustee will make such determination depending on 

the facts and circumstances of each Claim, including the amount involved and cost 

of such appeal.

Accordingly, Quinn Emanuel is not retained to represent the Estate in connection with any 

appeal. 

17. After (a) conducting extensive due diligence including but not limited to research 

on numerous court dockets of billing rates and potential hours to be exerted on known appeals, 

(b) communicating with five law firms about rates and estimated costs, and (c) considering that a 

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component of the Judicially Mediated Global Settlement addresses a fee to Quinn Emanuel, the 

Trustee determined in the exercise of her business judgement that it was in the Estate’s best interest 

to retain the firm of Cozen O’Connor to assist the Estate in the Judicially Mediated Global 

Settlement Appeal as well as to also utilize Cozen O’Connor in connection with other appellate 

and related matters, including the Premature Seal Appeal, should the Trustee in the exercise of her 

business judgment determine it is in the best interest of the Estate. And notwithstanding the 

proposed retention of Cozen O’Connor, the Trustee also seeks authority to utilize Quinn Emanuel 

in connection with nuances related to the impacts of the UST appeals on the two pending 

Adversary Proceedings, Numbers 20-03142 and 21-03095-KRH, as well as to provide information 

and support to Cozen O’Connor as requested by the Trustee given Quinn Emanuel’s extensive 

knowledge of the facts and law that likely will be part of the Judicially Mediated Global Settlement 

Appeal (the “Supplemental Representation”). 

REQUESTED RELIEF

18. Contemporaneously herewith, the Trustee has filed the Applications, seeking to 

separately employ both Cozen O’Connor and Quinn Emanuel in connection with the afore 

mentioned appellate matters for the specific purposes identified in each. Notwithstanding 

exhaustive efforts to prevent and eliminate the need for even the hiring of appellate counsel, as 

well as efforts to eliminate the need for an expedited hearing, the Trustee’s efforts appear to have 

fallen into a deep abyss, and the UST has persisted on its own path. For example, other than a 

response today to the Trustee’s request for the UST to endorse the proposed employment orders 

contained in the Applications, the Trustee has had no communication with the UST on this case 

for a week notwithstanding the Trustee repeated request in a sincere, heartfelt email dated July 26, 

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2022 to have discussions with the Program. To date, there has been no response from the Program

to said email --not even an acknowledgement of receipt. 

19. Irrespective of the same, the Trustee persists forward. Imminently, the Estate is 

faced with numerous deadlines in connection with appellate matters, which occur as early as 

August 8, 2022. And these deadlines are merely multiplying by virtue of the actions of the 

Program. For example, on August 1, 2022, the UST filed in the District Court a Motion to 

Consolidate Appeals, ECF No. 3 in 3:22cv 494 (the “Consolidation Motion”) with 8 lawyers 

listed on the pleading as representing the UST in these appeals. The Consolidation Motion 

indicates in a footnote that “Opposing counsel declined to consent to this motion to consolidate, 

asserting that it is premature at this time.” The Trustee was never provided a copy of any said 

motion before its filing. In response to an email from the UST indicating that it intended to file a 

motion to consolidate and asking for the Trustee’s position on the same without providing any 

supporting information, the Trustee requested that the UST defer the filing of any motion until 

said time as this Court had issued its memorandum opinion for the Premature Seal Appeal and the 

Program had identified its issues on appeal. The Trustee further indicated, after the same had 

been completed, she would discuss the consolidation issue with her professionals to ensure that 

she based any decision on all available information and, with the same, made a decision in her 

business judgement as to what was in the best interest of the Estate. Until the filing of the 

Consolidation Motion, the Trustee did not know that the UST had chosen not to honor her request

to defer. And now the Trustee faces yet another deadline, which deadline pursuant to Fed. R. 

Bankr. Pro. 8013 would be August 8, 2022 or pursuant to the District Court’s Local Civil Rule 7 

would be August 15, 2022. So, it is important that the Estate immediately retain appellate counsel 

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to address these items and provide information and advice to the Trustee such that she can make 

informed decisions as to what she believes in the exercise of her business judgment is in the best 

interest of the Estate. 

20. Also, as this Court is aware, certain documents have been sealed and/or redacted 

wherein the Trustee’s counsel is permitted to access the sealed and unredacted documents. 

However, there is no similar provision for proposed counsel. And even more importantly, this 

Court’s Judicially Mediated Settlement Ruling has been redacted and, absent further order of this 

Court, Cozen O’Connor is not permitted to review the unredacted Judicially Mediated Settlement 

Ruling. The Cozen O’Connor Employment Application requests authorization to immediately 

share all relevant unredacted materials with Cozen O’Connor. 

21. Finally, pleadings being filed by the UST in the District Court wrongly suggest on 

their face that the proceeding is against Lynn Tavenner personally. The Trustee is hopeful that the 

same is merely an oversight rather than an attempt to convert what is already an extremely 

precarious position for the Trustee to a cataclysmic unauthorized personal attack. The issue 

nonetheless needs to be addressed immediately. 

LEGAL AUTHORITY

22. Local Rule 9013-1(N) contemplates the relief requested herein. Pursuant to Local 

Rule 9013-1(N), the Certification for Expedited Hearing is attached hereto as Exhibit A. 

23. For the reasons stated herein and in the Applications, the Trustee submits that the 

requisite cause has been shown and, as such, respectfully requests that this Court conduct a hearing 

on the Applications on or before August 4, 2022, which in and of itself only provides the Trustee 

one business day and a weekend (which weekend the Trustee had originally intended to spend with 

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her family celebrating her son’s 17th birthday that is on August 8) to (a) have appellate counsel 

begin review of a plethora of information, (b) coordinate with various counsel, and (c) make 

informed decisions in the exercise of her business judgement on matters having upcoming 

deadlines as early as August 8, 2022. 

NOTICE

24. Copies of this Expedited Hearing Motion and notice thereof will be provided on 

August 3, 2022 to (a) the Office of the United States Trustee, (b) the Debtor’s 20 Largest 

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

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

requesting service of pleadings in this Case. 

WHEREFORE, the Trustee respectfully requests that the Court enter an order substantially 

in the form attached hereto as Exhibit B: (a) permitting the Trustee to present the Applications on 

on an expedited basis and (b) granting such other and further relief, as the Court may deem proper.

Dated: August 3, 2022 

Richmond, Virginia

LYNN L. TAVENNER, TRUSTEE

By:/s/ Paula S. Beran

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

Tavenner & Beran, PLC 

20 North 8th Street

Richmond, Virginia 23219 

Telephone: (804) 783-8300 

Facsimile: (804) 783-0178 

Counsel for Lynn L. Tavenner, Trustee

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CERTIFICATE OF SERVICE

Pursuant to the Local Rules and/or orders of this Court, I certify that on this 3rd day of 

August 2022, a true copy of the foregoing Motion was sent electronically and/or by first-class 

mail to: (a) the Office of the United States Trustee; (b) the Debtor’s 20 Largest Unsecured 

Creditors; (c) all known secured creditors from the Debtor’s Official Form 106D; (d) the Core 

Parties and 2002 List as defined in the Case Management Order; and (e) all parties requesting 

service of pleadings in this Case. 

/s/ Paula S. Beran 

Counsel for the Trustee 

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1 

UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

Richmond Division 

In re: Case No.

LeClairRyan, PLLC, 19-34574-KRH

Debtor Chapter

7

CERTIFICATION FOR EXPEDITED HEARING

Lynn L. Tavenner, Trustee, not individually, but solely in her capacity as the Chapter 7 

trustee (in such capacity, 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”) 

Lynn L. Tavenner, Chapter 7 Trustee (the “Trustee”), has filed (a) a request for an expedited 

hearing (the “Expedited Hearing Motion”) and (b) Applications (as defined in the Expedited 

Hearing Motion). In support thereof, as required by Local Rule 9013-1(N), I, Paula S. Beran, 

hereby swear under penalty of perjury the following: 

1. I am a member of the Bar of this Court; 

2. I have carefully examined the matter and have concluded that there is a true need 

for an emergency hearing;

3. I have not created the emergency through any lack of due diligence; and 

4. I am unable to resolve the matter without a hearing.

/s/ Paula S. Beran 

Paula S. Beran, Esquire

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

Tavenner & Beran, PLC 

20 North Eighth Street, Second Floor

Richmond, Virginia 23219

Telephone: (804) 783-8300

Facsimile: (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.

LeClairRyan, PLLC,1 19-34574-KRH

Debtor Chapter

7

ORDER GRANTING EXPEDITED HEARING ON THE TRUSTEE’S MOTION

TO EXPEDITE HEARING ON THE TRUSTEE’S APPLICATIONS TO RETAIN 

APPELLATE COUNSEL AND MEMORANDUM IN SUPPORT THERETO

This matter came before the Court upon the motion of Lynn L. Tavenner, Chapter 7 trustee 

(the “Trustee”) of the above-captioned bankruptcy case, requesting an expedited hearing and 

shortened response period (the “Expedited Hearing Motion”) on the Applications (as defined in 

the Expedited Hearing Motion), and it appearing that a certification under Local Rule 9013-1(N) 

was attached to the Expedited Hearing Motion and it further appearing good cause exists for 

granting an expedited hearing, it is hereby: 

ADJUDGED, ORDERED, AND DECREED as follows:

1. The Expedited Hearing Motion is hereby GRANTED. 

2. Capitalized terms not otherwise defined herein shall have the meanings given to 

them in the Expedited Hearing Motion. 

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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3. The Court shall hear the Applications on August ____2022 at ____ __.m. 

(prevailing Eastern Time) at the U.S. Bankruptcy Court, 701 East Broad Street, Room 5000, 

Richmond, Virginia 23219. 

4. Upon entry, the Clerk shall serve (by electronic delivery) a copy of this Order on 

counsel for the Trustee. 

ENTERED:

UNITED STATES BANKRUPTCY JUDGE

I ask for this: 

/s/ 

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

Tavenner & Beran, PLC 

20 North 8th Street

Richmond, Virginia 23219 

Telephone: (804) 783-8300 

Facsimile: (804) 783-0178 

Counsel for Lynn L. Tavenner, Trustee 

Local Rule 9022-1 Certification

I hereby certify that, pursuant to Local Rule 9022-1, the foregoing proposed Order has 

either been served upon and/or endorsed by all necessary parties. 

 

Counsel 

Service List for Entered Order

Kathryn R. Montgomery, Esquire 

Shannon F. Pecoraro, Esquire 

Office of the United States Trustee

701 East Broad Street, Room 4304 

Richmond, Virginia 23219 

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Paula S. Beran, Esquire

Tavenner & Beran, PLC

20 North Eighth Street, Second Floor

Richmond, VA 23219

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