4848-6176-4826 

UNITED STATES BANKRUPTCY COURT 

EASTERN DISTRICT OF VIRGINIA 

Richmond Division 

In re: 

 LeClairRyan PLLC, 

 Debtor 

Case No.: 19-34574-KRH 

Chapter 7 

STIPULATION BY LYNN L. TAVENNER, AS TRUSTEE, REFLECTING 

AGREED EXTENSIONS OF TIME WITH DESIGNATED FAO PARTIES 

Lynn L. Tavenner, not individually, but solely in her capacity as the duly appointed 

Chapter 7 trustee (the “Trustee”) of the bankruptcy estate of LeClairRyan PLLC (the “Debtor”) 

in the above-referenced Chapter 7 case (the “Bankruptcy Case”), and the parties listed in 

Exhibit A attached hereto (collectively, the “FAO Parties”) hereby stipulate (the “Stipulation”) 

as follows: 

BACKGROUND 

1. On September 3, 2019, the Debtor filed a voluntary petition under Chapter 11 of 

Title 11 of the United States Code (the “Bankruptcy Code”) in the United States Bankruptcy 

Court for the Eastern District of Virginia, Richmond Division (the “Bankruptcy Court”). 

2. On October 4, 2019, the Debtor’s Bankruptcy Case was converted to a case under 

Chapter 7 of the Bankruptcy Code. 

3. Upon conversion, Lynn L. Tavenner was appointed interim trustee and, as no 

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

4. On June 15, 2020, the Bankruptcy Court entered its Order Approving Procedures 

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

Order”). 

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5. The procedures approved by the FAO Order authorize the Trustee to send demand 

letters (the “FAO Demands”) to former attorneys and others, including the FAO Parties. The 

FAO Order further requires that any recipient of such a demand letter may elect to participate in 

pre-complaint mediation (the “Pre-Complaint Mediation Election”), and that such election must 

be made within 14 days of the date of the demand letter. 

6. The FAO Order also states that within 60 days after the date of the Pre-Complaint 

Mediation Election, the parties must have commenced the mediation process by (a) selecting a 

mutually agreeable mediator, (b) having executed a mediation agreement, and (c) having 

scheduled a date for mediation (the “Mediation Commencement Deadline”). That Mediation 

Commencement Deadline falls on or around February 3, 2021 for several of the FAO Parties. 

7. Given that the parties identified in Exhibit A have entered into settlement 

discussions with the Trustee, including executing confidentiality agreements, the Trustee 

believes that a 45-day extension of the Mediation Commencement Deadline would be beneficial 

for the parties to continue negotiating a consensual resolution to the Trustee’s FAO Demands. 

8. Notwithstanding the progress made between the Trustee and the FAO Parties with 

respect to the FAO Demands, given intervening holidays, issues related to the COVID-19 

pandemic, and work schedules, additional time is needed to determine if there can be a 

consensual resolution without the assistance of a mediator. 

9. The Trustee and the FAO Parties believe that the 45-day extension of the 

Mediation Commencement Deadline is warranted under the unique circumstances surrounding 

these FAO Demands. 

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10. The Trustee believes that there could be similar basis for extending additional 

Mediation Commencement Deadlines and, as such, also respectfully submits a process to 

accomplish the same. 

STIPULATION 

11. With respect to the FAO Parties, the Mediation Commencement Deadline is 

extended by 45 days from the current Mediation Commencement Deadline. Without further 

order of this Bankruptcy Court, the Mediation Commencement Deadline may be extended for 

additional parties by the Trustee’s filing of supplemental Exhibits A to this Stipulation, listing 

additional individuals and relevant extended dates. 

12. Except as expressly stated herein, the terms of the FAO Order are not affected by 

this Stipulation. 

IT IS SO ORDERED 

Date: ________________________ ___________________________________ 

 Richmond, Virginia Honorable Kevin R. Huennekens 

 United States Bankruptcy Judge 

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I ask for this: 

/s/ Brittany J. Nelson 

Erika L. Morabito (VSB No. 44369) 

Brittany J. Nelson (VSB No. 81734) 

Jack G. Haake (VSB No. 87590) 

FOLEY & LARDNER LLP 

3000 K Street, NW, Suite 600 

Washington, DC 20007-5109 

(202) 672-5300 (telephone) 

(202) 672-5399 (facsimile) 

bnelson@foley.com 

Counsel to Lynn L. Tavenner, Esq., 

Chapter 7 Trustee of Estate of LeClairRyan PLLC 

CERTIFICATION OF ENDORSEMENT, 

UNDER LOCAL BANKRUPTCY RULE 9022-1(C) 

 Pursuant to Local Bankruptcy Rule 9022-1(C), I hereby certify that the foregoing 

proposed order has been endorsed by or served upon all necessary parties. 

/s/ Brittany J. Nelson 

Brittany J. Nelson 

Service List 

Lynn L. Tavenner, Chapter 7 Trustee S. Allan Adelman 

Tavenner & Beran, PLC 128 Tanner Point Drive 

20 North 8th Street, 2nd Floor Stevensville, MD 21666 

Richmond, VA 23219 

Timothy Adelman Philip Bonoli 

404 Queens Court 2101 Basswood Court 

Stevensville, MD 21666 Westlake Village, CA 91361 

Corey R. Weber Pete Zemanian 

Brutzkus Gubner Zemanian Law Group 

c/o Philip Bonoli c/o Neal Brodsky 

21650 Oxnard St., Suite 500 223 E. City Hall Ave., Suite 201 

Woodland Hills, CA 91367 Norfolk, VA 23510 

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David Dean Michael Conway 

Cole Schotz P.C. 5 Thorne Place 

c/o Andrew Cole Bridgeport, CT 06605 

500 Delaware Avenue, Suite 1410 

Wilmington, DE 19801 

Bernard Gehlhar John P. Hutchins 

2613 Isabelle Avenue 2115 Howell Mill Road NW 

San Mateo, CA 94403 Atlanta, GA 30318 

Robert McWhorter Clint Morse 

2313 Beckett Drive Brooks Pierce 

El Dorado Hills, CA 95762 c/o Clinton Morse 

2000 Renaissance Plaza 

 230 North Elm Street 

 Greensboro, NC 27401 

John Pirko Bruin Richardson 

12207 Cabin Creek Drive 523 Sleepy Hollow Road 

Hanover, VA 23069 Richmond, VA 23229 

Ronald Sheff 

5902 Roland Avenue 

Baltimore, MD 21210

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EXHIBIT A 

FAO Parties 

FAO Party Current Mediation 

Commencement Deadline 

Stipulated Mediation 

Commencement Deadline 

S. Allan Adelman February 3, 2021 March 22, 2021 

Timothy Adelman February 3, 2021 March 22, 2021 

Philip Bonoli February 3, 2021 March 22, 2021 

Neal Brodsky February 3, 2021 March 22, 2021 

Andrew Cole February 3, 2021 March 22, 2021 

Michael Conway February 3, 2021 March 22, 2021 

Bernhard Gehlhar February 3, 2021 March 22, 2021 

John Hutchins February 3, 2021 March 22, 2021 

Robert McWhorter February 3, 2021 March 22, 2021 

Clinton Morse February 3, 2021 March 22, 2021 

John Pirko February 3, 2021 March 22, 2021 

Bruin Richardson February 3, 2021 March 22, 2021 

Ronald Sheff February 3, 2021 March 22, 2021 

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