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 EXPEDITED HEARING REQUEST

PLEASE TAKE NOTICE that 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”) has filed the Motion for Approval of Compromise and Settlement and 

Memorandum of Law (the “Motion”). The Trustee has also filed the Motion to Expedite Hearing 

on Trustee’s Motion (the “Motion to Expedite”). Copies of the Motion and the Motion to Expedite 

are being served herewith. 

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

read the Motion and Motion to Expedite 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. 

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

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

on or before November 29, 2022, at 1:00 p.m. (the “Objection Deadline”), you or your attorney

must file and serve an objection consistent with the Case Management Order. 

PLEASE TAKE FURTHER NOTICE THAT the Court will entertain the Motion to 

Expedite, and if granted, the Motion, on November 29, 2022, at 1:00 p.m. (or such time thereafter 

as the matter may be heard). In accordance with Richmond General Order 22-2, unless ordered 

otherwise, the hearing will be conducted both in person and via Zoom with a listen-only line 

available: 

Zoom registration link: 

https://www.zoomgov.com/meeting/register/vJIsduytrjIoGS5CTVaDRfaeEmN2lblLzM0 

Listen-only conference line: 

Dial: 1-866-590-5055 

Access Code: 4377075 

Security Code: 112922 

PLEASE TAKE FURTHER NOTICE THAT any party desiring to object the Motion to 

Expedite and/or the Motion or otherwise be heard with respect to the same shall also appear and 

be heard at such time. 

PLEASE GOVERN YOURSELVES ACCORDINGLY.

Respectfully submitted,

LYNN L. TAVENNER, CHAPTER 7 TRUSTEE

Dated: November 27, 2022

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

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CERTIFICATE OF SERVICE

Pursuant to the Local Rules of this Court, I certify that on this 27th day of November 2022, 

a true copy of the foregoing Notice 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 (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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