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.

LeClairRyan, PLLC,1 19-34574-KRH

Debtor Chapter 7

NOTICE OF MOTION AND HEARING THEREON IF NECESSARY

PLEASE TAKE NOTICE Lynn L. Tavenner, Trustee, and not individually but solely in 

her capacity as the Chapter 7 trustee of the bankruptcy estate of LeClairRyan PLLC, in the abovereferenced Chapter 7 case (the “Case”), by counsel, filed the following: TRUSTEE’S MOTION 

FOR AN ORDER APPROVING (I) THE TRUSTEE’S RELIANCE ON DEBTOR’S LIST 

OF EQUITY SECURITY HOLDERS AND (II) PROCEDURES FOR OBTAINING 

COPIES OF FILED TAX RETURNS AND MEMORANDUM IN SUPPORT 

THEREOF (the “Motion”). A Copy of the Motion is being served herewith. 

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

read the Motion carefully and discuss them with your attorney if you have one in this chapter 

7 Case. (If you do not have an attorney, you may wish to consult one).

PLEASE TAKE FURTHER NOTICE 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, on or 

before three days from the November 16, 2021 Omnibus Hearing (the “Objection Deadline”), 

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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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 an 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 on 

November 16, 2021, at 11:00 a.m. (or such time thereafter as the matter may be heard). REMOTE 

HEARING INFORMATION: Due to the COVID−19 public health emergency, no in-person 

hearings are being held. This hearing will take place remotely through Zoom. To appear at 

the hearing, you must use the following Zoom registration link:

Zoom registration link:

https://www.zoomgov.com/meeting/register/vJIscuGuqDMsHxLhZ703LYSct-3M4BRjYtI

Listen-only conference line:

Dial: 1-866-590-5055

Access Code: 4377075

Security Code: 111621

PLEASE NOTE: You MUST submit the Zoom Request Form no later than two (2) business days 

prior to this hearing. Any documentary evidence the parties wish to present at the hearing must be 

filed with the Court in advance of the hearing.

PLEASE TAKE FURTHER NOTICE THAT you should consult the Case Management 

Procedures before filing any written response.

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PLEASE GOVERN YOURSELVES ACCORDINGLY.

Respectfully submitted,

LYNN L. TAVENNER, CHAPTER 7 TRUSTEE

Dated: November 02, 2021

Richmond, Virginia

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

Telecopier: (804) 783-0178

Counsel for Lynn L. Tavenner, Chapter 7 Trustee

CERTIFICATE OF SERVICE

Pursuant to the Local Rules of this Court, I certify that on or before the 2nd day of

November 2021, a true copy of the foregoing Notice and Motion were 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; (e) individuals listed on 

the ESH list and (f) all parties requesting service of pleadings in this Case (as indicated on the 

Schedule A attached to the Court filed copy of this Notice).

/s/ Paula S. Beran

Counsel for Lynn L. Tavenner, Chapter 7 Trustee

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