10750-00003/13102630.2

UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

RICHMOND DIVISION

In re:

LeClairRyan PLLC,

Debtor1

Case No.: 19-34574-KRH

Chapter 7 

NOTICE OF FILING UNDER SEAL OF

PROPOSED FAO SETTLEMENTS

PLEASE TAKE NOTICE THAT Lynn L. Tavenner, 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”), filed under seal with the 

United States Bankruptcy Court for the Eastern District of Virginia (the “Court”), pursuant to the 

Order Approving Procedures and Permitting Trustee to Prosecute and Compromise FAO Actions

[ECF No. 533], and as thereafter modified by Court Orders, ECF Nos. 929 and 982 (collectively, 

the “FAO Procedures Order”),2a Fourth Notice of Proposed FAO Settlements [ECF No. 1145]

(the “Fourth Notice of Proposed Settlements”) describing proposed settlements with the 

following individuals: 

Everette G. Allen, III

Steven W. Blaine

Shanna Boughton

Mary Elizabeth Davis

Stephen M. Faraci, Sr.

David C. Freinberg

Linda B. Georgiadis

Grant S. Grayson

Michael Hern

Katja H. Hill

Vernon E. Inge, Jr.

Joseph Lagrotteria

Gary D. LeClair

Susan Childers North

William Oberdorf

Charles E. Osthimer, III

David W. Phillips

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.

2 Terms not otherwise defined shall have the meanings ascribed to them in the FAO Procedures Order.

Case 19-34574-KRH Doc 1146 Filed 12/15/21 Entered 12/15/21 20:01:14 Desc Main

Document Page 1 of 3
10750-00003/13102630.2 2

Thomas C. Regan

John P. Reilly

Robert Reklaitis

John C. Selbach

D. Shane Smith

Tate Tischner

Robert Wonneberger

All of the above referenced individuals have requested that the both the terms of the 

Proposed FAO Settlement and the settlement agreements be subject to a protective order as 

permitted under the FAO Procedures Order. Accordingly, as indicated above, the Fourth Notice of 

Proposed Settlements was filed under seal. See ECF No. 1145.

This notice is being provided to publicly announce the filing of the Fourth Notice of 

Proposed Settlements and the procedures outlined therein. If an Interested Party (as defined in the 

FAO Procedures Order) desires to object to the Trustee proceeding with final consummation of 

any said settlement, then within fifteen (15) days of the service of this Notice, he/she/it must file 

with the Court, at the address shown below, a written response with supporting memorandum 

pursuant to Local Bankruptcy Rule 9013-1 and the FAO Procedures Order; and send or otherwise 

file it early enough so the Court will receive it on or before fifteen (15) days from the date of 

service of this Notice.

Clerk of the Court

United States Bankruptcy Court

701 E. Broad Street, Suite 4000

Richmond, VA 23219

Any of the Interested Parties must also serve a copy on:

Paula S. Beran, Esq.

Tavenner & Beran, PLC

20 North Eighth Street, 

2nd Floor

Richmond, VA 23219

Erika L. Morabito, Esq.

Brittany J. Nelson, Esq.

Quinn Emanuel Urquhart & 

Sullivan LLP

1300 I Street NW, Suite 900

Washington, DC 20005

Shannon F. Pecoraro, Esq.

Office of the United States Trustee

701 East Broad, 

Suite 4304

Richmond, VA 23219

If these steps are not taken, any opposition is deemed waived, and the Trustee may 

consummate the Proposed FAO Settlements without further notice or hearing.

Dated: December 15, 2021 Respectfully submitted,

/s/ Brittany J. Nelson

Special Counsel to Lynn L. Tavenner, Esq., the 

Chapter 7 Trustee of Estate of LeClairRyan PLLC

Case 19-34574-KRH Doc 1146 Filed 12/15/21 Entered 12/15/21 20:01:14 Desc Main

Document Page 2 of 3
10750-00003/13102630.2 3

LOCAL BANKRUPTCY RULE 2002-1 CERTIFICATE OF SERVICE

I certify that on this 15t

h

day of December, 2022, a true copy of the foregoing Notice was 

served on (i) the Office of the United States Trustee, (ii) the 20 largest unsecured creditors as listed 

on the Debtor’s schedules, and (iii) any other party who has made a written request to Paula S.

Beran, Esquire and filed on the Court’s CM/ECF system.

 /s/ Brittany J. Nelson

Case 19-34574-KRH Doc 1146 Filed 12/15/21 Entered 12/15/21 20:01:14 Desc Main

Document Page 3 of 3