Erika L. Morabito (VSB No. 44369) 

Brittany J. Nelson (VSB No. 81734) 

QUINN EMANUEL URQUHART & SULLIVAN LLP 

1300 I Street, N.W., Suite 900 

Washington, DC 20005 

Telephone: (202) 538-8334 

Email: erikamorabito@quinnemanuel.com 

 brittanynelson@quinnemanuel.com 

Special Counsel to Lynn L. Tavenner, Chapter 7 Trustee

UNITED STATES BANKRUPTCY COURT 

EASTERN DISTRICT OF VIRGINIA 

(Richmond Division)

In re: 

LeClairRyan PLLC, 

 Debtor. 

______________________________________ 

Lynn L. Tavenner, as Chapter 7 Trustee, 

 Plaintiff, 

v. 

ULX Partners, LLC, UnitedLex Corporation, 

and ULX Manager, LLC, 

 Defendants. 

Chapter 7 

Case No. 19-34574 (KRH) 

Adv. Proc. No. 20-03142 (KRH) 

NOTICE OF MOTION AND HEARING THEREON 

PLEASE TAKE NOTICE that Lynn L. Tavenner, Trustee (the “Trustee”), and not 

individually but solely in her capacity as the Chapter 7 trustee of the bankruptcy estate of 

LeClairRyan PLLC, in the above-captioned Chapter 7 case (the “Case”), by counsel, has filed the 

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 (the “Motion”). A copy of the Motion is being filed 

under seal pending the Court’s ruling on the ULX Partners, LLC’s, UnitedLex Corporation’s, and 

ULX Manager, LLC’s Motion to Seal Settlement Agreement and Related Documents, Information, 

and Hearings [Dkt No. 207] (the “Seal Motion”), scheduled to be heard on May 25, 2022 at 11:00 

am. Thereafter, the Motion will be served as provided in any Order addressing the Seal Motion. 

Furthermore, a copy of the Motion may be received by any Person (as defined by Section 101(41) 

of the Bankruptcy Code) holding a claim against the Estate evidenced by (i) a proof of claim, 

which claim is not otherwise subject to dispute pursuant to the Bankruptcy Code and/or the 

Bankruptcy Rules and/or (ii) an order of the Bankruptcy Court, only upon written receipt by Paula 

Case 19-34574-KRH Doc 1329 Filed 05/18/22 Entered 05/18/22 17:29:43 Desc Main

Document Page 1 of 4
 2 

S. Beran, Esquire at pberan@tb-lawfirm.com of a commitment of any Person to keep such Motion 

confidential. 

PLEASE TAKE FURTHER NOTICE that your rights may be affected. You should read 

the Motion carefully and discuss it with your attorney if you have one in this Case. (If you do not 

have an attorney, you may wish to consult one). 

PLEASE TAKE FURTHER NOTICE that on September 4, 2019, the Court entered the 

Order Establishing Certain Notice, Case Management and Administrative Procedures [ECF. No. 

38] (the “Case Management Order”), which approved the Notice, Case Management, and 

Administrative Procedures attached as Exhibit 1 to the Case Management Order (the “Case

Management Procedures”). The Case Management Procedures, among other things, prescribe 

the manner in which Objections must be filed and served and set forth when certain hearings will 

be conducted. A copy of the Case Management Order may be obtained, free of charge, by written 

to request to pberan@tb-lawfirm.com or, for a fee, at https://ecf.vaeb.uscourts.gov. 

PLEASE TAKE FURTHER NOTICE if you do not want the Court to grant the relief 

requested in the Motion, or if you want the Court to consider your views on the Motion, then, by 

June 1, 2022 (the “Objection Deadline”), you or your attorney must: 

File with the Court, either electronically or at the address shown below, a written response 

to the Motion pursuant to Rule 9013-1(H) of the Local Rules of the United States 

Bankruptcy Court for the Eastern District of Virginia and the Case Management 

Procedures. If you mail your written response to the Court for filing, you must mail it early 

enough so the Court will receive it on or before the Objection Deadline. 

If a response is not properly and timely filed and served, the Court may deem any 

opposition waived, treat the Motion as conceded and enter the appropriate order 

granting the requested relief without further notice or hearing. 

Clerk of the Court 

United States Bankruptcy Court 

701 East Broad Street, Suite 4000 

Richmond, VA 23219 

In accordance with the Case Management Procedures, you must also serve a copy of your 

written Objection on the Core Parties, the 2002 List Parties and any Affected Entity so that 

the Objection is received on or before the Objection Deadline. 

PLEASE TAKE FURTHER NOTICE THAT the Court will entertain the Motion at a 

hearing on June 8, 2022, at 1:00 p.m. (or such time thereafter as the matter may be heard). In 

connection with the same, the undersigned will appear before The Honorable Kevin R. 

Huennekens, United States Bankruptcy Judge. This hearing will take place remotely through 

Zoom on the date and time scheduled herein. 

Case 19-34574-KRH Doc 1329 Filed 05/18/22 Entered 05/18/22 17:29:43 Desc Main

Document Page 2 of 4
 3 

Zoom registration link: 

https://www.zoomgov.com/meeting/register/vJItc--rrz4jHfonPb6c3FARuCippfQvj4g

Listen-only conference line: 

 Dial: 1-866-590-5055 

 Access Code: 4377075 

 Security Code: 6822 

PLEASE TAKE FURTHER NOTICE THAT you should consult the Case Management 

Procedures before filing any written response. 

PLEASE GOVERN YOURSELVES ACCORDINGLY. 

Dated: May 18, 2022 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, N.W., Suite 900 

Washington, DC 20005 

(202) 538-8334 (telephone) 

erikamorabito@quinnemanuel.com 

brittanynelson@quinnemanuel.com 

Special Counsel to Lynn L. Tavenner, the Chapter 7 

Trustee of the Estate of LeClairRyan PLLC 

Case 19-34574-KRH Doc 1329 Filed 05/18/22 Entered 05/18/22 17:29:43 Desc Main

Document Page 3 of 4
CERTIFICATE OF SERVICE 

I HEREBY CERTIFY that on this 18th day of May, 2022, a true and correct copy of the 

foregoing document was served via first class mail and/or electronic mail upon: (i) all parties and 

counsel requesting service via the Court’s ECF system, (ii) the Office of the United States 

Trustee, (iii) the Defendants, (iv) the 20 largest unsecured creditors as listed on the Debtor’s 

schedules, (v) the Service List as defined by the governing Case Management, (f) Foley & 

Lardner; and (g) all Persons identified in paragraph 4 of the FAO Procedures Order. 

/s/ Erika L. Morabito 

Erika L. Morabito 

Special Counsel to Lynn L. Tavenner, the Chapter 7 

Trustee of the Estate of LeClairRyan PLLC 

Case 19-34574-KRH Doc 1329 Filed 05/18/22 Entered 05/18/22 17:29:43 Desc Main

Document Page 4 of 4