Kathryn R. Montgomery, Esq., AUST (Va. Bar No. 42380)

Shannon Pecoraro, Esq. (Va. Bar No. 46864)

Jason B. Shorter, Esq. (Va. Bar No. 80989)

Office of the United States Trustee

701 East Broad Street - Suite 4304

Richmond, VA 23219

Telephone (804) 771-2310

Facsimile (804) 771-2330

UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

RICHMOND DIVISION

In re

LeClairRyan, PLLC, 

 Debtor. 

Case No.: 19-34574-KRH

Chapter 7

Lynn Tavenner, Chapter 7 Trustee,

 Plaintiff,

v. 

ULX Partners, LLC, et al.,

 Defendants.

 Adv. Proc.: 20-03142-KRH

Lynn Tavenner, Chapter 7 Trustee,

 Plaintiff,

v. 

CVC Capital Partners, et al.,

 Defendants.

 Adv. Proc.: 21-03095-KRH

THE UNITED STATES TRUSTEE’S STATEMENT OF THE ISSUES AND 

DESIGNATION OF ITEMS TO BE INCLUDED IN THE RECORD ON APPEAL 

 John P. Fitzgerald, III, Acting United States Trustee for Region Four, which includes the 

Case 19-34574-KRH Doc 1523 Filed 07/25/22 Entered 07/25/22 12:30:12 Desc Main

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Eastern District of Virginia, pursuant to Rule 8009 of the Federal Rules of Bankruptcy Procedure, 

files this Statement of the Issues and Designation of Items to be Included in the Record on Appeal. 

See Notice of Appeal, Dkt. No. 1480.

STATEMENT OF THE ISSUES

1. Whether the bankruptcy court erred in approving a $3.15 million additional 

payment to the estate’s special litigation counsel.

2. Whether the bankruptcy court erred when it held that the additional $3.15 million 

payment to the estate’s special litigation counsel could be approved under Federal Rule of 

Bankruptcy Procedure 9019 regarding settlements, and that 11 U.S.C. § 328 does not apply. 

3. Whether the bankruptcy court erred when it approved the $3.15 million additional 

payment to the estate’s special litigation counsel because the record does not support a finding 

that the requirements of 11 U.S.C. § 328 were met.

4. Whether the bankruptcy court erred when it found that the standard for approving 

settlement agreements under Federal Rule of Bankruptcy Procedure 9019 was met as to the 

$3.15 million additional payment to the estate’s special litigation counsel.

5. Whether the bankruptcy court erred when it found that the $3.15 million payment 

to the estate’s special litigation counsel could not be severed from a settlement agreement 

resolving litigation brought by the estate.

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ITEMS TO BE INCLUDED IN THE RECORD ON APPEAL

In re LeClairRyan, PLLC, Case 19-34574 

Docket No. Description

Docket Sheet

1 Chapter 11 voluntary petition non-individual

3 Declaration (Declaration of Lori D. Thompson, Esq. in Support of Chapter 11 

Petition and First Day Motions) 

9 Motion to File Document(s) Under Seal (Motion of LeClairRyan PLLC 

Pursuant to Sections 105 and 107 of the Bankruptcy Code and Bankruptcy Rule 

9018 for Entry of an Order Authorizing LeClairRyan PLLC to File Under Seal 

Exhibit B to the Motion to LeClairRyan PLLC for Entry of Interim and Final 

Orders Approving Settlement Procedures and Compromising Accounts 

Receivable and Related Relief)

10 Sealed Exhibit 

14 Declaration (Declaration of Guy A. Davis in Support of Motion of LeClairRyan 

PLLC for Entry of Interim and Final Orders Authorizing the Debtor to Use Cash 

Collateral and Granting Adequate Protection and Related Relief)

42 Order Authorizing LeClairRyan PLLC to File Under Seal Exhibit B to the 

Motion of LeClairRyan PLLC for Entry of Interim and Final Orders Approving 

Settlement Procedures and Compromising Accounts Receivable and Related 

Relief

PLEASE NOTE: These designations include documents filed under seal by 

Order of the bankruptcy court. Pursuant to Rule 8009(f) of the Federal 

Rules of Bankruptcy Procedure, the clerk of the bankruptcy court shall not 

transmit any materials filed under seal to the district court until such time 

as the district court enters an order allowing such transmission. The United 

States Trustee will be filing a motion in the district court requesting such 

an order.

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Docket No. Description

45 Transcript of Hearing Held 9/3/2019

61 Motion to Convert Case to Chapter 7

82 Motion for Joinder of Michele Craddock in Motion of United States Trustee to 

Convert Case to Chapter 7

90 Motion for Joinder of Motion to Convert

99 Statement in Support of Motion of United States Trustee to Convert Case to 

Chapter 7

101 Response to (Response of LeClairRyan PLLC to Motion of United States 

Trustee to Convert Case to Chapter 7)

103 Declaration (Supplemental Declaration of Guy A. Davis in Support of the 

Application of LeClairRyan PLLC for Entry of an Order Authorizing the 

Employment and Retention of Protiviti Inc. as Financial Advisor for 

LeClairRyan PLLC Effective as of the Petition Date)

104 Declaration (Supplemental Declaration of Tyler P. Brown in Support of the 

Application of LeClairRyan PLLC for Entry of an Order Authorizing the 

Employment and Retention of Hunton Andrews Kurth LLP as Counsel for 

LeClairRyan PLLC Effective as of the Petition Date)

110 Declaration of John McCauley (Re: related document(s)13 Motion to Approve 

Use of Cash Collateral filed by LeClairRyan PLLC, 41 Order 

Continuing/Rescheduling/Setting Hearing)

128 Transcript of Hearing Held 9/26/2019

134 Order Denying Motion to Convert

140 Order Granting Motion to Convert Case to Chapter 7

142 Trustee’s Application to Employ Tavenner & Beran PLC

152 Order Granting Application to Employ Tavenner & Beran PLC

154 Supplemental Order on Conversion

175 Appointment of Interim Trustee

208 Non-Individual’s Schedules and or Statements, Lists

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Docket No. Description

209 Non-Individual Schedules and/or Statements, Lists

211 Non-Individual’s Schedules and or Statements, Lists regarding Statement of 

Financial Affairs

263 Transcript of Hearing Held 11/21/2019

330 Trustee’s Application to Employ Foley & Lardner

342 Order Approving Trustee’s Application to Employ Foley & Lardner, LLP

345 Motion for procedures re avoidance actions

349 Notice of Appearance filed by Erika L. Morabito of Foley & Lardner, LLP

385 Ordre Granting Motion for Procedures re Avoidance Actions

435 Declaration of Lynn L. Tavenner, Chapter 7 Trustee, in support of matters set 

for hearing on April 30, 2020

448 First Interim Application for Compensation for Tavenner & Beran PLC 

450 Application for Compensation for Lynn L. Tavenner

451 First Interim Application for Compensation for Foley & Lardner, LLP

457 Trustee’s Motion to Approve Motion for and Order Establishing Procedures 

Regarding the Prosecution of Actions Involving Former Attorneys and Certain 

Others and Memorandum in Support Thereof

515 Exhibit A - Proposed List of Mediators

516 Amended Exhibit A - Proposed List of Mediators

517 Exhibit B - Settlement Agreement

518 Declaration of Lynn L. Tavenner, Trustee

533 Order Establishing Procedures Regarding the Prosecution of Actions Involving 

Former Attorneys

538 Declaration of Lynn L. Tavenner, Trustee

555 Motion for 2004 Examination

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Docket No. Description

595 Order Granting Motion for 2004 Examination

562 Order Granting First Interim Application for Compensation for Tavenner & 

Beran PLC

587 Order Granting First Interim Application for Compensation for Foley & 

Lardner, LLP

604 Declaration of Lynn L. Tavenner, Trustee

622 Second Interim Application for Compensation for Tavenner & Beran PLC

623 Application for Compensation (Application for Compensation of Professional 

Accountant)

625 Second Interim Application for Compensation for Foley & Lardner, LLP

637 Declaration of Lynn L. Tavenner, Trustee

653 Transcript of Hearing Held 4/30/2020

654 Transcript of Hearing Held 6/25/2020

655 Transcript of Hearing Held 8/27/2020

657 Order Granting Second Interim Application for Compensation for Foley & 

Lardner, LLP

666 Adversary Case 20-03142 Complaint Against ULX Partners, LLC, UnitedLex 

Corporation,

669 Declaration of Lynn L. Tavenner, Trustee

670 Exhibit A (Re: related document(s)669 Declaration filed by Lynn L. Tavenner) 

671 Exhibit B - Part 1 of 2 (Re: related document(s)669 Declaration filed by Lynn 

L. Tavenner)

672 Exhibit B - Part 2 of 2 (Re: related document(s)669 Declaration filed by Lynn 

L. Tavenner)

689 Transcript of Hearing Held 10/30/2020

713 Declaration of Lynn L. Tavenner, Trustee

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Docket No. Description

721 Transcript of Hearing Held 12/17/2020

733 Third Interim Application for Compensation for Tavenner & Beran PLC

736 Third Interim Application for Compensation for Foley & Lardner, LLP

737 Transcript filed Re: Hearing Held 10/4/2019

739 Transcript filed Re: Hearing Held 10/24/2019

743 Transcript filed Re: Hearing Held 12/19/2019

752 Declaration of Lynn L. Tavenner, Trustee

757 Transcript of Hearing Held 10/29/2020

758 Transcript of Hearing Held 1/28/2021

769 Order Granting Application for Compensation for Tavenner & Beran, PLC

770 Order Granting Second Interim Application for Compensation for Tavenner & 

Beran PLC

779 Order Granting Third Interim Application for Compensation for Foley & 

Lardner, LLP

786 Declaration of Lynn L. Tavenner, Trustee

795 Declaration of Lynn L. Tavenner, Trustee

803 Transcript of Hearing Held 3/25/2021

811 Sealed Notice (Attachments: # 1 Exhibit A to Notice # 2 Exhibit 1 to Ex. A # 3 

Exhibit 2 to Ex. A # 4 Exhibit 3 to Ex. A # 5 Exhibit 4 to Ex. A # 6 Exhibit 5 to 

Ex. A # 7 Exhibit 6 to Ex. A # 8 Exhibit 7 to Ex. A # 9 Exhibit 8 to Ex. A # 10 

Exhibit 9 to Ex. A # 11 Exhibit 10 to Ex. A # 12 Exhibit 11 to Ex. A # 13 Exhibit 

12 to Ex. A # 14 Exhibit 13 to Ex. A # 15 Exhibit 14 to Ex. A # 16 Exhibit 15 

to Ex. A # 17 Exhibit 16 to Ex. A # 18 Exhibit 17 to Ex. A # 19 Exhibit 18 to 

Ex. A # 20 Exhibit 19 to Ex. A # 21 Exhibit 20 to Ex. A # 22 Exhibit 21 to Ex. 

A # 23 Exhibit 22 to Ex. A # 24 Exhibit 23 to Ex. A # 25 Exhibit 24 to Ex. A # 

26 Exhibit 25 to Ex. A # 27 Exhibit 26 to Ex. A # 28 Exhibit 27 to Ex. A # 29 

Exhibit 28 to Ex. A # 30 Exhibit 29 to Ex. A # 31 Exhibit 30 to Ex. A # 32 

Exhibit 31 to Ex. A # 33 Exhibit 32 to Ex. A # 34 Exhibit 33 to Ex. A # 35 

Exhibit 34 to Ex. A # 36 Exhibit 35 to Ex. A # 37 Exhibit 36 to Ex. A # 38 

Exhibit 37 to Ex. A)

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Docket No. Description

830 Sealed Exhibit

835 Declaration of Lynn L. Tavenner, Trustee

838 Objection to Consummation of Proposed FAO Settlements

845 Fourth Interim Application for Compensation for Foley & Lardner, LLP

846 Sealed Exhibit to Fourth Interim Application for Compensation for Foley & 

Lardner, LLP

847 Fourth Interim Application for Compensation for Tavenner & Beran PLC

852 Trustee’s Motion to Modify Procedures Regarding the Prosecution of Actions 

Involving Former Attorneys and Certain Others and Memorandum in Support 

Thereof

854 Motion to File Document(s) Under Seal - Motion For Authority To Limit Access 

To Settlement Agrement Filed Under Seal And To Seal Hearing On Approval 

Of Said Settlement, If Necessary

857 Motion for Relief from Stay Re: Insurance Policy

860 Transcript of Hearing Held 4/27/2021

891 Omnibus Objection to Trustee’s Motion to Modify Procedures Regarding the 

Prosecution of Actions Involving Former Attorneys and Certain Others and 

Memorandum in Support Thereof filed by ULX Partners, LLC, UnitedLex 

Corporation

893 Declaration of Lynn L. Tavenner, Trustee

894 Trustee’s Response to Omnibus Objection filed by ULX Partners, LLC, 

UnitedLex Corporation (ECF 891)

906 Transcript of Hearing Held 5/27/2021

908 Trustee’s Application to Employ Quinn Emanuel Urquhart & Sullivan, LLP as 

Special Counsel to Chapter 7 Trustee

911 Order Granting Fourth Interim Application for Compensation for Tavenner & 

Beran PLC

921 Objection to Trustees Answer And Limited Objection To The Motion For Relief 

From The Automatic Stay

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Docket No. Description

922 Limited Response to Limited Response and Reservation of Rights

924 Declaration of Lynn L. Tavenner, Trustee

929 Order Granting Trustee’s Motion to Modify Procedures Regarding the 

Prosecution of Actions Involving Former Attorneys and Certain Others (ECF 

852)

931 Order Granting Fourth Interim Application for Compensation for Foley & 

Lardner, LLP

932 Order Granting Motion for Authority to Limit Access to Settlement Agreement 

Filed Under Seal and to Seal Hearing on Approval of Related Settlement

937 Order Granting Trustee’s Application to Employ Quinn Emanuel Urquhart & 

Sullivan, LLP as Special Counsel to Chapter 7 Trustee

940 Transcript of Hearing Held 6/24/2021

944 Motion to Authorize Disclosure of Certain Settlement Materials

949 Declaration of Lynn L. Tavenner, Trustee

950 Amended Exhibit A to Declaration filed by Lynn L. Tavenner

951 Exhibit Re: Motion for Relief from Stay filed by Columbia Casualty Company

957 Transcript to Hearing Held 7/22/2021

962 Trustee’s Second Motion to Modify Procedures Regarding the Prosecution of 

Actions Involving Former Attorneys and Certain Others and Memorandum in 

Support Thereof

965 Stipulation Granting Relief From Automatic Stay By Columbia Casualty 

Company

969 Motion to File Documents Under Seal

971 Sealed Objection (Attachments: # 1 Exhibit(s) A # 2 Exhibit(s) B # 3 Exhibit(s) 

C # 4 Exhibit(s) D) 

973 Declaration of Lynn L. Tavenner, Trustee

974 Exhibit A to Declaration of Lynn L. Tavenner, Trustee

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Docket No. Description

975 Exhibit B to Declaration of Lynn L. Tavenner, Trustee

976 Schedule A to Trustee’s Second Motion to Modify Procedures Regarding the 

Prosecution of Actions Involving Former Attorneys and Certain Others and 

Memorandum in Support Thereof

980 Consent Order Granting Motion for Relief from Stay and Establishing 

Procedures for Access to Proceeds of Insurance Policy

982 Order Modifying Order governing Procedures Regarding the Prosecution of 

Actions Involving Former Attorneys and Certain Others

983 Order Granting Motion to Allow Disclosure of Settlement Materials and to 

Establish Procedures for the Preservation of Privilege

984 Transcript of Hearing Held 8/19/2021

992 First Interim Application for Compensation for Quinn Emanuel

993 Sealed Exhibit to First Interim Application for Compensation for Quinn 

Emanuel

1032 Fifth Application for Compensation for Tavenner & Beran PLC

1042 Adversary case 21-03095. Complaint against CVC Capital Partners, Daniel 

Reed, Nicholas Hinton, Josh Rosenfeld, P. Douglas Benson 

1052 Declaration of Lynn L. Tavenner, Trustee

1059 Transcript of Hearing Held 9/23/2021

1064 Order Granting Fifth Application for Compensation for Tavenner & Beran PLC

1069 Sealed Notice (Attachments: # 1 Exhibit(s) Exhibit A # 2 Exhibit 1 (to Exhibit 

A) # 3 Ex 2 to Ex A # 4 Ex 3 to Ex A # 5 Ex 4 to Ex A # 6 Ex 5 to Ex A # 7 Ex 

6 to Ex A # 8 Ex 7 to Ex A # 9 Ex 8 to Ex A # 10 Ex 9 to Ex A # 11 Ex 10 to 

Ex A # 12 Ex 11 to Ex A # 13 Ex 12 to Ex A # 14 Ex 13 to Ex A # 15 Ex 14 to 

Ex A # 16 Ex 15 to Ex A # 17 Ex 16 to Ex A # 18 Ex 17 to Ex A # 19 Ex 18 to 

Ex A # 20 Ex. 19 to Ex A # 21 Ex 20 to Ex A # 22 Ex 21 to Ex A # 23 Ex 22 to 

Ex A # 24 Ex 23 to Ex A # 25 Ex 24 to Ex A # 26 Ex 25 to Ex A # 27 Ex 26 to 

Ex A # 28 Ex 27 to Ex A # 29 Ex 28 to Ex A # 30 Ex 29 to Ex A # 31 Ex 30 to 

Ex A # 32 Ex 31 to Ex A # 33 Ex 32 to Ex A # 34 Ex 33 to Ex A # 35 Ex 34 to 

Ex A # 36 Ex 35 to Ex A # 37 Ex 36 to Ex A # 38 Ex 37 to Ex A # 39 Ex 38 to 

Ex A # 40 Ex 39 to Ex A # 41 Ex 40 to Ex A # 42 Ex 41 to Ex A # 43 Ex 42 to 

Ex A # 44 Ex 43 to Ex A # 45 Ex 44 to Ex A # 46 Ex 45 to Ex A # 47 Ex 46 to 

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Docket No. Description

Ex A)

1070 Statement Second Notice of Filing Under Seal of Proposed FAO Settlements 

1074 Trustee’s Supplemental Application to Employ Quinn Emanuel Urquhart & 

Sullivan, LLP as Special Counsel to Chapter 7 Trustee

1075 Order Granting First Interim Application for Compensation for Quinn Emanuel

1079 Declaration of Lynn L. Tavenner, Trustee

1081 Sealed Notice

1082 Statement Third Notice of Filing Under Seal of Proposed FAO Settlements

1085 Order Granting Trustee’s Supplemental Application to Employ Quinn Emanuel 

Urquhart & Sullivan, LLP as Special Counsel to Chapter 7 Trustee (ECF 1074)

1097 Declaration of Lynn L. Tavenner, Trustee

1098 Exhibit A to Declaration of Lynn L. Tavenner, Trustee

1099 Exhibits B & C to Declaration of Lynn L. Tavenner, Trustee

1103 Motion to Approve Compromise and Settlement and Memorandum of Law

1109 Memorandum of Law In Support of Trustee's Motion for Approval of 

Compromise and Settlement

1112 Declaration of Lynn L. Tavenner, Trustee

1118 Transcript of Hearing Held 11/29/2021

1120 Second Interim Application for Compensation for Quinn Emanuel

1121 Sealed Exhibit to Second Interim Application for Compensation for Quinn 

Emanuel

1122 Sixth Interim Application for Compensation for Tavenner & Beran PLC

1133 Order Granting Motion to Approve Settlement

1145 Sealed Notice (Attachments: # 1 Exhibit 1 # 2 Exhibit 2 # 3 Exhibit 3 # 4 Exhibit 

4 # 5 Exhibit 5 # 6 Exhibit 6 # 7 Exhibit 7 # 8 Exhibit 8 # 9 Exhibit 9 # 10 

Exhibit 10 # 11 Exhibit 11 # 12 Exhibit 12 # 13 Exhibit 13 # 14 Exhibit 14 # 15 

Exhibit 15 # 16 Exhibit 16 # 17 Exhibit 17 # 18 Exhibit 18 # 19 Exhibit 19 # 20 

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Docket No. Description

Exhibit 20 # 21 Exhibit 21 # 22 Exhibit 22 # 23 Exhibit 23 # 24 Exhibit 24)

1146 Statement Fourth Notice of Filing Under Seal of Proposed FAO Settlements

1159 Declaration of Lynn L. Tavenner, Trustee

1168 Order Granting Second Interim Application for Compensation for Quinn 

Emanuel

1169 Sealed Notice

1170 Statement Fifth Notice of Filing Under Seal of Proposed FAO Settlements

1178 Order Granting Sixth Interim Application for Compensation for Tavenner & 

Beran PLC

1203 Transcript of Hearing Held 1/27/2022

1206 Transcript of Hearing Held 12/21/2021

1219 Declaration of Lynn L. Tavenner, Trustee

1242 Seventh Interim Application for Compensation for Tavenner & Beran PLC

1245 Third Interim Application for Compensation for Quinn Emanuel

1249 Supplemental Third Interim Application for Compensation for Quinn Emanuel

1252 Sealed Notice (Attachments: # 1 Exhibit(s) 1 # 2 Exhibit(s) 2 # 3 Exhibit(s) 3 # 

4 Exhibit(s) 4 # 5 Exhibit(s) 5 # 6 Exhibit(s) 6 # 7 Exhibit(s) 7 # 8 Exhibit(s) 8 

# 9 Exhibit(s) 9 # 10 Exhibit(s) 10 # 11 Exhibit(s) 11 # 12 Exhibit(s) 12 # 13 

Exhibit(s) 13 # 14 Exhibit(s) 14)

1253 Statement Notice of Filing Under Seal of Certain Settlements

1267 Sealed Exhibit to Third Interim Application for Compensation for Quinn 

Emanuel

1269 Declaration of Lynn L. Tavenner, Trustee

1279 Transcript of Hearing Held 3/29/2022

1282 Order Granting Third Interim Application for Compensation for Quinn Emanuel

1288 Order Granting Seventh Interim Application for Compensation for Tavenner & 

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Docket No. Description

Beran PLC

1325 Motion to Restrict Public Access to Sensitive Case Information—Motion to Seal 

Settlement Agreement and Related Documents, Information and Hearings

1326 Notice of Hearing on Motion to Restrict Public Access to Sensitive Case 

Information

1328 Sealed Motion to Approve 9019

1329 Notice of Motion and Notice of Hearing on Sealed Motion to Approve 9019

1332 United States Trustee’s Objection to ULX Partners, LLC, UnitedLex 

Corporation and ULX Managers, LLC’s Motion to Seal Settlement Agreement 

and Related Documents, Information and Hearings 

1333 United States Trustee’s Objection to Trustee’s Motion and Memorandum of 

Law for Entry of an Order(I) Approving (A) Judicially Mediated Settlement and 

(B) Compensation to Counsel Including Improvident Payment under Section 

328(a) and (II) Granting Related Relief Filed Under Seal at Docket Number 211

1335 United States Trustee’s Motion for a Status Hearing and Scheduling Order

1336 United States Trustee’s Motion to Expediate Hearing

1339 Trustee’s Objection to United States Trustee’s Motion for a Status Hearing and 

Scheduling Order

1341 Order Continuing Hearing on Motion to Restrict Public Access to Sensitive Case 

Information—Motion to Seal Settlement Agreement and Related Documents, 

Information and Hearings (ECF 1325)

1363 Motion to File Documents Under Seal by Foley & Lardner, LLP

1365 Trustee’s Sealed Answer to Motion to File Documents Under Seal by Foley & 

Lardner, LLP

1370 United States Trustee’s Sealed Objection

1372 United States Trustee’s Motion to File Documents Under Seal and Reservation 

of Rights

1373 United States Trustee’s Motion to Expedite

1374 Sealed Certification/Declaration/Statement to Sealed Motion to Approve 9019

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Docket No. Description

1375 Motion to Expedite filed by Foley & Lardner, LLP

1380 Sealed Declaration with Exhibits 1-14 filed by Trustee

1382 Interim Order to Seal Omnibus Settlement Agreement and Related Documents

1386 Sealed Answer filed by Chapter 7 Trustee

1387 Supplemental Sealed Declaration filed by Chapter 7 Trustee

1388 Sealed Exhibit filed by Chapter 7 Trustee

1393 Eighth Interim Application for Compensation for Tavenner & Beran PLC

1396 Amended Sealed Exhibit filed by Chapter 7 Trustee (Settlement Agreement 

execution copy)

1397 Sealed Supplemental Declaration of Geoffrey S. Goodman

1402 Transcript of Hearing Held 6/8/2022

1433 Declaration of Lynn L. Tavenner, Trustee

1450 Sealed Memorandum Opinion

1452 Unsealed and Redacted Memorandum Opinion

1453 Order Approving Settlement 

1454 Motion for Approval of Agreement Re-docketed to file unsealed version with 

redactions

1455 Transcript of Hearing Held 6/28/2022

1460 Order Granting Eighth Interim Application for Compensation for Tavenner & 

Beran PLC

1479 Supplemental Sealed Motion to Restrict Public Access to Sensitive Case 

Information—Motion to Seal Settlement Agreement and Related Documents, 

Information and Hearings with Exhibits 1-10 (ECF 1325)

1480 Notice of Appeal

1485 Declaration of Lynn L. Tavenner, Trustee

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Docket No. Description

1486 Sealed Declaration in support of Supplemental Sealed Motion to Restrict Public 

Access to Sensitive Case Information—Motion to Seal Settlement Agreement 

and Related Documents, Information and Hearings with Exhibits 1-10 (ECF 

1325)

1495 Transcript of Hearing Held 7/14/2022

1499 Fourth Interim Application for Compensation for Quinn Emanuel

1501 Corrected Exhibit A to Fourth Interim Application for Compensation for Quinn 

Emanuel

1502 Sealed Exhibit to Fourth Interim Application for Compensation for Quinn 

Emanuel

1503 Sealed Notice 

1504 Statement Notice of Filing Under Seal of Proposed FAO Settlements

1505 Notice of Appeal

Tavenner v. ULX Partners, LLC, et al., Adv. Pro. 20-03142

Dkt. No. Description

Docket Sheet

1 Complaint against ULX Partners, LLC, UnitedLex Corporation filed by Lynn 

L. Tavenner, as Chapter 7 Trustee. (Attachments: # 1 Exhibit 1 # 2 Exhibit 2 

# 3 Exhibit 3 # 4 Exhibit 4 # 5 Exhibit 5 # 6 Exhibit 6 # 7 Exhibit 7 # 8 Exhibit 

8 # 9 Exhibit 9 # 10 Exhibit 10 # 11 Exhibit 11 # 12 Exhibit 12 # 13 Exhibit 13 

# 14 Exhibit 14 # 15 Exhibit 15 # 16 Exhibit 16 # 17 Exhibit 17 # 18 Exhibit 

18 # 19 Exhibit 19 # 20 Exhibit 20 # 21 Exhibit 21 # 22 Exhibit 22 

# 23 Exhibit 23 # 24 Exhibit 24 # 25 Exhibit 25 # 26 Exhibit 26 # 27 Exhibit 

27 # 28 Exhibit 28)

2 Motion to Authorize Motion to Otherwise File Complaint (Re: related 

document1 Complaint filed by Lynn L. Tavenner, as Chapter 7 Trustee) filed 

by Erika L. Morabito of Foley & Lardner on behalf of Lynn L. Tavenner, as 

Chapter 7 Trustee. (Attachments: # 1 Ex. A (Part 1 of 1) # 2 Ex. A (Part 2 of 2) 

# 3 Proposed Order)

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Dkt. No. Description

3 Order Granting Motion to Otherwise File Complaint (Related Doc # 2)

4 Corrected Complaint against ULX Partners, LLC, UnitedLex Corporation (Re: 

related document(s)1 Complaint filed by Lynn L. Tavenner, as Chapter 7 

Trustee) filed by Erika L. Morabito of Foley & Lardner on behalf of Lynn L. 

Tavenner, as Chapter 7 Trustee. (Attachments: # 1 Exhibit 1 # 2 Exhibit 2 

# 3 Exhibit 3 # 4 Exhibit 4 # 5 Exhibit 5 # 6 Exhibit 6 # 7 Exhibit 7 # 8 Exhibit 

8 # 9 Exhibit 9 # 10 Exhibit 10 # 11 Exhibit 11 # 12 Exhibit 12 # 13 Exhibit 13 

# 14 Exhibit 14 # 15 Exhibit 15 # 16 Exhibit 16 # 17 Exhibit 17 # 18 Exhibit 

18 # 19 Exhibit 19 # 20 Exhibit 20 # 21 Exhibit 21 # 22 Exhibit 22 

# 23 Exhibit 23 # 24 Exhibit 24 # 25 Exhibit 25 # 26 Exhibit 26 # 27 Exhibit 

27 # 28 Exhibit 28) 

6 Summons and Notice of Pre-Trial Conference. Summons Issued to ULX 

Partners, LLC Answer Due 12/7/2020; UnitedLex Corporation Answer Due 

12/7/2020 (Re: related document(s)4 Amended Complaint filed by Lynn L. 

Tavenner, as Chapter 7 Trustee)

7 Stipulation By ULX Partners, LLC, UnitedLex Corporation and Between Lynn 

L. Tavenner as Chapter 7 Trustee filed by Thomas John McKee Jr. of 

Greenberg Traurig on behalf of ULX Partners, LLC, UnitedLex Corporation. 

9 Pre-Trial Order; (Re: related document(s)4 Amended Complaint filed by Lynn 

L. Tavenner, as Chapter 7 Trustee) Trial set for 9/14/2021 - 9/24/2021 at 10:00 

AM at Judge Huennekens' Courtroom, 701 E. Broad St., Rm. 5000, Richmond, 

Virginia.

11 Transcript of Hearing Held 12/17/2020

13 Motion for Withdrawal of Reference and Memorandum in Support 

Thereof filed by Thomas John McKee Jr. of Greenberg Traurig on behalf of 

ULX Partners, LLC, UnitedLex Corporation. (Attachments: # 1 Proposed 

Order)

15 Designation of Record Regarding Withdrawal of Reference (Re: related 

document(s)13 Motion for Withdrawal of Reference (fee) filed by ULX 

Partners, LLC, UnitedLex Corporation) filed by Thomas John McKee Jr. of 

Greenberg Traurig on behalf of ULX Partners, LLC, UnitedLex Corporation. 

16 Notice of Motion (Re: related document(s)13 Motion for Withdrawal of 

Reference (fee) filed by ULX Partners, LLC, UnitedLex Corporation) filed by 

Thomas John McKee Jr. of Greenberg Traurig on behalf of ULX Partners, 

LLC, UnitedLex Corporation.

17 Defendant's Motion to Dismiss Adversary Proceeding /Partially Dismiss the 

Complaint filed by Thomas John McKee Jr. of Greenberg Traurig on behalf of 

ULX Partners, LLC, UnitedLex Corporation. (Attachments: # 1 Proposed 

Order) 

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Dkt. No. Description

18 Memorandum of Law in Support (Re: related document(s)17 Motion to 

Dismiss Adversary Proceeding filed by ULX Partners, LLC, UnitedLex 

Corporation) filed by Thomas John McKee Jr. of Greenberg Traurig on behalf 

of ULX Partners, LLC, UnitedLex Corporation. (Attachments: # 1 Exhibit(s) 

Exhibit A # 2 Exhibit(s) Exhibit B # 3 Exhibit(s) Exhibit C)

19 Objection to (Plaintiff's Opposition to Defendants' Motion to Withdraw the 

Reference) (Re: related document(s)13 Motion for Withdrawal of Reference 

(fee) filed by ULX Partners, LLC, UnitedLex Corporation) filed by Erika L. 

Morabito of Foley & Lardner on behalf of Lynn L. Tavenner, as Chapter 7 

Trustee. 

20 Designation of Record Regarding Withdrawal of Reference (Re: related 

document(s)13 Motion for Withdrawal of Reference (fee) filed by ULX 

Partners, LLC, UnitedLex Corporation) filed by Erika L. Morabito of Foley & 

Lardner on behalf of Lynn L. Tavenner, as Chapter 7 Trustee. Document(s) 

due by 1/25/2021. 

21 Reply to Trustee's Objection to Defendants' Motion to Withdraw the 

Reference (Re: related document(s)13 Motion for Withdrawal of Reference 

(fee) filed by ULX Partners, LLC, UnitedLex Corporation) filed by Thomas 

John McKee Jr. of Greenberg Traurig on behalf of ULX Partners, LLC, 

UnitedLex Corporation. 

22 Supplemental Statement of the Record (Re: related document(s)13 Motion for 

Withdrawal of Reference (fee) filed by ULX Partners, LLC, UnitedLex 

Corporation, 15 Designation of Record Regarding Withdrawal of Reference 

filed by ULX Partners, LLC, UnitedLex Corporation, 19 Objection to 

Motion/Application filed by Lynn L. Tavenner, as Chapter 7 Trustee, 21 Reply 

to Motion/Application filed by ULX Partners, LLC, UnitedLex Corporation) 

filed by Thomas John McKee Jr. of Greenberg Traurig on behalf of ULX 

Partners, LLC, UnitedLex Corporation. 

23 Transmittal of Withdrawal of Reference to the U. S. District Court (Re: related 

document(s)13 Motion for Withdrawal of Reference (fee) filed by ULX 

Partners, LLC, UnitedLex Corporation) 

24 Notification of Civil Action Number 3:21-cv-00077. (Re: related 

document(s)23 Transmittal of Withdrawal of Reference to the U. S. District 

Court) 

25 Objection to (Plaintiffs Opposition to Defendants Motion to Partially Dismiss 

the Complaint) (Re: related document(s)17 Motion to Dismiss Adversary 

Proceeding filed by ULX Partners, LLC, UnitedLex Corporation) filed by 

Erika L. Morabito of Foley & Lardner on behalf of Lynn L. Tavenner, as 

Chapter 7 Trustee.

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26 Reply to Trustee's Opposition to Defendants' Motion to Partially Dismiss the 

Complaint (Re: related document(s)17 Motion to Dismiss Adversary 

Proceeding filed by ULX Partners, LLC, UnitedLex Corporation) filed by 

Thomas John McKee Jr. of Greenberg Traurig on behalf of ULX Partners, 

LLC, UnitedLex Corporation. 

27 Notice of Hearing (Re: related document(s)17 Motion to Dismiss Adversary 

Proceeding filed by ULX Partners, LLC, UnitedLex Corporation) filed by 

Thomas John McKee Jr. of Greenberg Traurig on behalf of ULX Partners, 

LLC, UnitedLex Corporation. Hearing scheduled for 3/25/2021 at 11:00 AM 

at Judge Huennekens' Courtroom, 701 E. Broad St., Rm. 5000, Richmond, 

Virginia. 

28 Certificate of Service of Discovery Documents (Certificate of Service of 

Plaintiffs Responses to Defendant ULX Partners, LLCs First Set of 

Interrogatories) filed by Erika L. Morabito of Foley & Lardner on behalf of 

Lynn L. Tavenner, as Chapter 7 Trustee. 

29 Stipulation by Lynn L. Tavenner, as Trustee, Reflecting Agreed Protective 

Order with Defendants By Lynn L. Tavenner, as Chapter 7 Trustee and 

Between ULX Partners, LLC and UnitedLex Corporation filed by Brittany 

Jane Nelson of Foley & Lardner LLP on behalf of Lynn L. Tavenner, as 

Chapter 7 Trustee. 

30 Order Continuing Hearing (Re: related document(s)17 Motion to Dismiss 

Adversary Proceeding filed by ULX Partners, LLC, UnitedLex 

Corporation, 25 Objection to Motion/Application filed by Lynn L. Tavenner, 

as Chapter 7 Trustee, 26 Reply to Motion/Application filed by ULX Partners, 

LLC, UnitedLex Corporation) Hearing scheduled for 4/27/2021 at 01:00 PM at 

Judge Huennekens' Courtroom, 701 E. Broad St., Rm. 5000, Richmond, 

Virginia. 

32 Proposed Findings of Fact and Conclusions of Law (Re: related 

document(s)13 Motion for Withdrawal of Reference (fee) filed by ULX 

Partners, LLC, UnitedLex Corporation, 19 Objection to Motion/Application 

filed by Lynn L. Tavenner, as Chapter 7 Trustee, 21 Reply to 

Motion/Application filed by ULX Partners, LLC, UnitedLex Corporation) 

35 Objection (Re: related document(s)32 Order Directing) filed by Thomas John 

McKee Jr. of Greenberg Traurig on behalf of ULX Partners, LLC, UnitedLex 

Corporation. (Attachments: # 1 Exhibit(s) A # 2 Exhibit(s) B # 3 Exhibit(s) C 

# 4 Exhibit(s) D # 5 Exhibit(s) E # 6 Exhibit(s) F # 7 Exhibit(s) G 

# 8 Exhibit(s) H)

36 Certificate of Service of Subpoena (McGladrey /RSM) filed by Brittany Jane 

Nelson of Foley & Lardner LLP on behalf of Lynn L. Tavenner, as Chapter 7 

Trustee. 

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37 Certificate of Service of Subpoena (Wells Fargo) filed by Brittany Jane Nelson 

of Foley & Lardner LLP on behalf of Lynn L. Tavenner, as Chapter 7 Trustee. 

38 Certificate of Service of Subpoena (Elliot Davis, LLC) filed by Brittany Jane 

Nelson of Foley & Lardner LLP on behalf of Lynn L. Tavenner, as Chapter 7 

Trustee. 

39 Certificate of Service of Subpoena (SB2 Consultants LLC) filed by Brittany 

Jane Nelson of Foley & Lardner LLP on behalf of Lynn L. Tavenner, as 

Chapter 7 Trustee. 

40 Certificate of Service of Subpoena (Bruce Green) filed by Brittany Jane 

Nelson of Foley & Lardner LLP on behalf of Lynn L. Tavenner, as Chapter 7 

Trustee. 

41 Order Setting Status Conference (Re: related document(s)17 Motion to 

Dismiss Adversary Proceeding filed by ULX Partners, LLC, UnitedLex 

Corporation) Hearing scheduled for 4/27/2021 at 01:00 PM at Judge 

Huennekens' Courtroom, 701 E. Broad St., Rm. 5000, Richmond, Virginia. 

43 Statement (Trustees Response to Defendants Objection to the Bankruptcy 

Courts Proposed Findings of Fact and Conclusion of Law) (Re: related 

document(s)35 Objection filed by ULX Partners, LLC, UnitedLex 

Corporation) filed by Erika L. Morabito of Foley & Lardner on behalf of Lynn 

L. Tavenner, as Chapter 7 Trustee.

44 Transmittal of the Report and Recommendation to the U. S. District Court (Re: 

related document(s)32 Proposed Findings of Fact and Conclusions of 

Law, 35 Objection to Proposed Findings of Fact and Conclusions of 

Law, 43 Statement/ Trustee's Response to Objection to the Bankruptcy Court's 

Proposed Findings of Fact and Conclusion of Law. 

45 Statement - Designation of Record with Respect to Defendants' Objection to 

the Bankruptcy Court's Proposed Findings of Fact and Conclusions of Law 

Regarding Defendants' Motion to Withdraw the Reference (Re: related 

document(s)32 Order Directing, 35 Objection filed by ULX Partners, LLC, 

UnitedLex Corporation, 43 Statement filed by Lynn L. Tavenner, as Chapter 7 

Trustee) filed by David G. Barger of Greenberg Traurig, LLP on behalf of 

ULX Partners, LLC, UnitedLex Corporation.

46 Supplemental Transmittal of of the Report and Recommendation to the U. S. 

District Court (Re: related document(s)13 Motion for Withdrawal of Reference 

(fee) filed by ULX Partners, LLC, UnitedLex Corporation) 45 Designation of 

Record with Respect to Defendants' Objection to the Bankruptcy Court's 

Proposed Findings of Fact and Conclusions of Law Regarding Defendants' 

Motion to Withdraw the Reference 

47 Stipulation and Order Lynn L. Tavenner, as Trustee, Reflecting Agreed 

Protective Order with Defendants. (Re: related document(s)29 Stipulation filed 

by Lynn L. Tavenner, as Chapter 7 Trustee) 

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49 Pre-Trial Order; (Re: related document(s)4 Amended Complaint filed by Lynn 

L. Tavenner, as Chapter 7 Trustee) Trial set for 10/25/2021 at 10:00 AM 

Through 11/5/2021 at 10:00 AM at Judge Huennekens' Courtroom, 701 E. 

Broad St., Rm. 5000, Richmond, Virginia. (Bullock, Nathaniel)

50 Order Setting Hearing (Re: related document(s)17 Motion to Dismiss 

Adversary Proceeding filed by ULX Partners, LLC, UnitedLex Corporation) 

Hearing scheduled for 6/24/2021 at 11:00 AM at Judge Huennekens' 

Courtroom, 701 E. Broad St., Rm. 5000, Richmond, Virginia. 

53 Transcript of Hearing Held 6/24/2021.

55 Motion to Authorize Disclosure of Certain Settlement Materials filed by Erika 

L. Morabito of Quinn Emanuel on behalf of Lynn L. Tavenner, as Chapter 7 

Trustee. 

56 Notice of Motion (Re: related document(s)55 Motion to Authorize filed by 

Lynn L. Tavenner, as Chapter 7 Trustee) filed by Erika L. Morabito of Quinn 

Emanuel on behalf of Lynn L. Tavenner, as Chapter 7 Trustee. 

57 Memorandum Opinion (Re: related document(s)17 Motion to Dismiss 

Adversary Proceeding filed by ULX Partners, LLC, UnitedLex 

Corporation, 25 Objection to Motion/Application filed by Lynn L. Tavenner, 

as Chapter 7 Trustee, 26 Reply to Motion/Application filed by ULX Partners, 

LLC, UnitedLex Corporation) 

58 Order Granting in part, Denying in part Motion to Dismiss Adversary 

Proceeding (Related Doc # 17) 

59 Amended Exhibit A (Re: related document(s)55 Motion to Authorize filed by 

Lynn L. Tavenner, as Chapter 7 Trustee) filed by Erika L. Morabito of Quinn 

Emanuel on behalf of Lynn L. Tavenner, as Chapter 7 Trustee. 

63 Transcript or Hearing Held 7/22/2021

64 Stipulation and [Proposed] Order Regarding Answer/Response Deadline By

ULX Partners, LLC, UnitedLex Corporation and Between ULX Partners, 

LLC, UnitedLex Corporation, and Lynn L. Tavenner, as Chapter 7 Trustee 

filed by Thomas John McKee Jr. of Greenberg Traurig on behalf of ULX 

Partners, LLC, UnitedLex Corporation.

66 Motion to Amend Complaint and to Modify Pretrial Scheduling Order (Re: 

related document(s)1 Complaint filed by Lynn L. Tavenner, as Chapter 7 

Trustee) filed by Erika L. Morabito of Quinn Emanuel on behalf of Lynn L. 

Tavenner, as Chapter 7 Trustee. (Attachments: # 1 Exhibit(s))

67 Notice of Motion and Notice of Hearing (Re: related document(s)66 Motion to 

Amend filed by Lynn L. Tavenner, as Chapter 7 Trustee) filed by Erika L. 

Morabito of Quinn Emanuel on behalf of Lynn L. Tavenner, as Chapter 7 

Trustee. Hearing scheduled for 8/19/2021 at 11:00 AM at Judge Huennekens' 

Courtroom, 701 E. Broad St., Rm. 5000, Richmond, Virginia. 

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68 Motion to File Document(s) Under Seal (Re: related document(s)66 Motion to 

Amend filed by Lynn L. Tavenner, as Chapter 7 Trustee) filed by Erika L. 

Morabito of Quinn Emanuel on behalf of Lynn L. Tavenner, as Chapter 7 

Trustee. (Attachments: # 1 Exhibit(s)) 

69 Notice of Motion and Notice of Hearing (Re: related document(s)68 Motion to 

File Documents(s) Under Seal filed by Lynn L. Tavenner, as Chapter 7 

Trustee) filed by Erika L. Morabito of Quinn Emanuel on behalf of Lynn L. 

Tavenner, as Chapter 7 Trustee. Hearing scheduled for 8/19/2021 at 11:00 AM 

at Judge Huennekens' Courtroom, 701 E. Broad St., Rm. 5000, Richmond, 

Virginia. 

70 Sealed Motion/Application (Related Document(s)66 Motion to Amend filed by 

Lynn L. Tavenner, as Chapter 7 Trustee, 68 Motion to File Documents(s) 

Under Seal filed by Lynn L. Tavenner, as Chapter 7 Trustee) filed by Erika L. 

Morabito of Quinn Emanuel on behalf of Lynn L. Tavenner, as Chapter 7 

Trustee. (Attachments: # 1 Exhibit(s)).

71 Agreed Stipulation and Order Regarding Answer/Response Deadline Between 

ULX Partners, LLC, UnitedLex Corporation, and Lynn L. Tavenner, as 

Chapter 7 Trustee (Re: related document(s)64 Stipulation filed by ULX 

Partners, LLC, UnitedLex Corporation).

73 Corrected Motion to Amend Complaint and to Modify Pretrial Scheduling 

Order (Re: related document(s)66 Motion to Amend filed by Lynn L. 

Tavenner, as Chapter 7 Trustee) filed by Erika L. Morabito of Quinn Emanuel 

on behalf of Lynn L. Tavenner, as Chapter 7 Trustee. (Attachments: 

# 1 Exhibit(s)).

74 Sealed Motion/Application(Re: related document(s)70 Sealed Document filed 

by Lynn L. Tavenner, as Chapter 7 Trustee, 73 Motion to Amend filed by 

Lynn L. Tavenner, as Chapter 7 Trustee) filed by Erika L. Morabito of Quinn 

Emanuel on behalf of Lynn L. Tavenner, as Chapter 7 Trustee. (Attachments: 

# 1 Exhibit(s)).

75 Objection to (Re: related document(s)66 Motion to Amend filed by Lynn L. 

Tavenner, as Chapter 7 Trustee) filed by Thomas John McKee Jr. of 

Greenberg Traurig on behalf of ULX Partners, LLC, UnitedLex Corporation.

76 Motion to File Document(s) Under Seal (Re: related document(s)75 Objection 

to Motion/Application filed by ULX Partners, LLC, UnitedLex Corporation) 

filed by Thomas John McKee Jr. of Greenberg Traurig on behalf of ULX 

Partners, LLC, UnitedLex Corporation. (Attachments: # 1 Proposed Order).

77 Notice of Hearing (Re: related document(s)76 Motion to File Documents(s) 

Under Seal filed by ULX Partners, LLC, UnitedLex Corporation) filed by 

Thomas John McKee Jr. of Greenberg Traurig on behalf of ULX Partners, 

LLC, UnitedLex Corporation. Hearing scheduled for 8/19/2021 at 11:00 AM 

at Judge Huennekens' Courtroom, 701 E. Broad St., Rm. 5000, Richmond, 

Virginia. 

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78 Sealed Objection(Re: related document(s)75 Objection to Motion/Application 

filed by ULX Partners, LLC, UnitedLex Corporation) filed by Thomas John 

McKee Jr. of Greenberg Traurig on behalf of ULX Partners, LLC, UnitedLex 

Corporation. 

82 Order Granting Motion to File Document(s) Under Seal (Related Doc # 68).

84 Order Granting Motion to Allow Disclosure of Settlement Materials and to 

Establish Procedures for the Preservation of Privilege. (Related Doc # 55).

85 Order Granting Motion to for Leave to Amend Complaint and to Modify PreTrial Scheduling Order. (Related Doc # 73).

86 Amended Complaint against ULX Manager LLC, Gary LeClair, ULX 

Partners, LLC, UnitedLex Corporation (Re: related document(s)1 Complaint 

filed by Lynn L. Tavenner, as Chapter 7 Trustee) filed by Erika L. Morabito of 

Quinn Emanuel on behalf of Lynn L. Tavenner, as Chapter 7 Trustee. 

(Attachments: # 1 Exhibit 1 # 2 Exhibit 2 # 3 Exhibit 3 # 4 Exhibit 4 

# 5 Exhibit 5).

87 Motion to Dismiss Adversary Proceeding / Partially Dismiss the First 

Amended Complaint (Re: related document(s)86 Amended Complaint filed by 

Lynn L. Tavenner, as Chapter 7 Trustee) filed by Thomas John McKee Jr. of 

Greenberg Traurig on behalf of ULX Manager LLC, ULX Partners, LLC, 

UnitedLex Corporation. (Attachments: # 1 Proposed Order).

88 Memorandum of Law in Support (Re: related document(s)87 Motion to 

Dismiss Adversary Proceeding filed by ULX Partners, LLC, UnitedLex 

Corporation, ULX Manager LLC) filed by Thomas John McKee Jr. of 

Greenberg Traurig on behalf of ULX Manager LLC, ULX Partners, LLC, 

UnitedLex Corporation. (Attachments: # 1 Exhibit(s) A # 2 Exhibit(s) B 

# 3 Exhibit(s) C # 4 Exhibit(s) D # 5 Exhibit(s) E)(McKee, Thomas)

89 Answer to Complaint (Related Doc #86) filed by Thomas John McKee Jr. of 

Greenberg Traurig on behalf of ULX Manager LLC, ULX Partners, LLC, 

UnitedLex Corporation.

90 Summons and Notice of Pre-Trial Conference. Summons Issued to Gary 

LeClair Answer Due 9/27/2021; ULX Manager LLC Answer Due 9/27/2021; 

ULX Partners, LLC Answer Due 9/27/2021; UnitedLex Corporation Answer 

Due 9/27/2021 (Re: related document(s)86 Amended Complaint filed by Lynn 

L. Tavenner, as Chapter 7 Trustee) Pre-Trial Conference set for 9/8/2021 at 

01:00 PM at Judge Huennekens' Courtroom, 701 E. Broad St., Rm. 5000, 

Richmond, Virginia.

91 Order Scheduling Pre-Trial Conference (Re: related document(s)86 Amended 

Complaint filed by Lynn L. Tavenner, as Chapter 7 Trustee) Pre-Trial 

Conference scheduled for 9/8/2021 at 01:00 PM at Judge Huennekens' 

Courtroom, 701 E. Broad St., Rm. 5000, Richmond, Virginia.

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92 Transcript of Hearing Held 8/19/2021.

93 Supplemental Order (Re: related document(s)82 Order on Motion to File 

Document(s) Under Seal).

99 Transcript of Hearing Held 9/8/2021.

100 Third Stipulation and Amended Pre-Trial Order; (Re: related 

document(s)49 Pre-Trial Order, 86 Amended Complaint filed by Lynn L. 

Tavenner, as Chapter 7 Trustee) Trial set for 4/18/2022 at 10:00 AM Through 

4/29/2022 at Judge Huennekens' Courtroom, 701 E. Broad St., Rm. 5000, 

Richmond, Virginia. Hearing on Motion to Dismiss set for 10/19, 2021 at 

11:00 AM at Judge Huennekens' Courtroom, 701 E. Broad St., Rm. 5000, 

Richmond, Virginia.

104 Motion to Dismiss Pleading (Re: related document(s)86 Amended Complaint 

filed by Lynn L. Tavenner, as Chapter 7 Trustee) filed by Andrew M. Bowman 

of Gentry Locke on behalf of Gary LeClair.

105 Memorandum of Points and Authorities in Support of Gary D. LeClair's 

Motion to Dismiss (Re: related document(s)104 Motion to Dismiss Pleading 

filed by Gary LeClair) filed by Andrew M. Bowman of Gentry Locke on 

behalf of Gary LeClair. (Attachments: # 1 Exhibit(s) 1 # 2 2 # 3 Exhibit(s) 3 

# 4 4 # 5 Exhibit(s) 5 # 6 Exhibit(s) 6 # 7 Exhibit(s) 7 # 8 Exhibit(s) 8 

# 9 Exhibit(s) 9).

106 Omnibus Opposition Brief to the Motions to Dismiss the First Amended 

Complaint Filed by ULX Partners, LLC, ULX Manager, UnitedLex Corp., and 

Gary LeClair (Re: related document(s)87 Motion to Dismiss Adversary 

Proceeding filed by ULX Partners, LLC, UnitedLex Corporation, ULX 

Manager LLC, 104 Motion to Dismiss Pleading filed by Gary LeClair) filed by 

Erika L. Morabito of Quinn Emanuel on behalf of Lynn L. Tavenner, as 

Chapter 7 Trustee. (Attachments: # 1 Exhibit 1).

108 Defendant's Reply to Trustee's Opposition Brief (Re: related 

document(s)104 Motion to Dismiss Pleading filed by Gary LeClair) filed by 

Andrew M. Bowman of Gentry Locke on behalf of Gary LeClair. 

(Attachments: # 1 Exhibit(s) 1).

109 Reply to Trustee's Omnibus Opposition Brief (Re: related 

document(s)87 Motion to Dismiss Adversary Proceeding filed by ULX 

Partners, LLC, UnitedLex Corporation, ULX Manager LLC) filed by Thomas 

John McKee Jr. of Greenberg Traurig on behalf of ULX Manager LLC, ULX 

Partners, LLC, UnitedLex Corporation.

111 Motion to Amend (Re: related document(s)47 Stipulation and Order, 84 Order 

on Motion to Authorize) filed by Andrew M. Bowman of Gentry Locke on 

behalf of Gary LeClair. (Attachments: # 1 Proposed Order Exhibit 1 

# 2 Proposed Order Exhibit 2).

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112 Transcript of Hearing Held 10/19/2021

114 Memorandum Opinion (Re: related document(s)87 Motion to Dismiss 

Adversary Proceeding filed by ULX Partners, LLC, UnitedLex Corporation, 

ULX Manager LLC, 104 Motion to Dismiss Pleading filed by Gary 

LeClair, 106 Opposition Brief filed by Lynn L. Tavenner, as Chapter 7 

Trustee, 108 Reply to Motion/Application filed by Gary LeClair, 109 Reply to 

Motion/Application filed by ULX Partners, LLC, UnitedLex Corporation, 

ULX Manager LLC).

115 Order Denying Motion to Dismiss Adversary Proceeding (Related Doc # 87), 

Denying Motion to Dismiss Pleading (Related Doc # 104).

117 Answer to Complaint (Related Doc #86), Counterclaim against Lynn L. 

Tavenner, as Chapter 7 Trustee filed by Andrew M. Bowman of Gentry Locke 

on behalf of Gary LeClair. 

118 Answer to Complaint (Related Doc #86) filed by Thomas John McKee Jr. of 

Greenberg Traurig on behalf of ULX Manager LLC, ULX Partners, LLC, 

UnitedLex Corporation. 

119 Motion to Approve Compromise under FRBP 9019 filed by Erika L. Morabito 

of Quinn Emanuel on behalf of Lynn L. Tavenner, as Chapter 7 Trustee. 

(Attachments: # 1 Exhibit(s)).

120 Notice of Motion and Notice of Hearing (Re: related document(s)119 Motion 

to Approve filed by Lynn L. Tavenner, as Chapter 7 Trustee, Lynn L. 

Tavenner, as Chapter 7 Trustee) filed by Erika L. Morabito of Quinn Emanuel 

on behalf of Lynn L. Tavenner, as Chapter 7 Trustee. Hearing scheduled for 

11/29/2021 at 01:00 PM at Judge Huennekens' Courtroom, 701 E. Broad St., 

Rm. 5000, Richmond, Virginia. 

121 Order Granting Motion to Approve Settlement (Related Doc # 119).

127 Order Setting Hearing (Re: related document(s)100 Pre-Trial Order) Hearing 

scheduled for 1/14/2022 at 02:00 PM at Judge Huennekens' Courtroom, 701 E. 

Broad St., Rm. 5000, Richmond, Virginia. 

129 Order Concerning Deposition (Re: related document(s)127 Order 

Continuing/Rescheduling/Setting Hearing).

130 Joint Stipulation for Dismissal of Defendant Gary LeClair By Lynn L. 

Tavenner, as Chapter 7 Trustee and Between filed by Brittany Jane Nelson of 

Quinn Emanuel on behalf of Lynn L. Tavenner, as Chapter 7 Trustee.

131 Transcript of Hearing Held 1/14/2022.

133 Motion for Summary Judgment filed by Thomas John McKee Jr. of Greenberg 

Traurig on behalf of ULX Manager LLC, ULX Partners, LLC, UnitedLex 

Corporation. 

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134 Notice of Hearing (Re: related document(s)133 Motion for Summary 

Judgment filed by ULX Partners, LLC, UnitedLex Corporation, ULX Manager 

LLC) filed by Thomas John McKee Jr. of Greenberg Traurig on behalf of 

ULX Manager LLC, ULX Partners, LLC, UnitedLex Corporation. Hearing 

scheduled for 2/17/2022 at 11:00 AM at Judge Huennekens' Courtroom, 701 

E. Broad St., Rm. 5000, Richmond, Virginia. 

135 Motion to File Document(s) Under Seal (Re: related document(s)133 Motion 

for Summary Judgment filed by ULX Partners, LLC, UnitedLex Corporation, 

ULX Manager LLC) filed by Thomas John McKee Jr. of Greenberg Traurig 

on behalf of ULX Manager LLC, ULX Partners, LLC, UnitedLex Corporation. 

(Attachments: # 1 Proposed Order).

136 Notice of Hearing (Re: related document(s)135 Motion to File Documents(s) 

Under Seal filed by ULX Partners, LLC, UnitedLex Corporation, ULX 

Manager LLC) filed by Thomas John McKee Jr. of Greenberg Traurig on 

behalf of ULX Manager LLC, ULX Partners, LLC, UnitedLex Corporation. 

Hearing scheduled for 2/17/2022 at 11:00 AM at Judge Huennekens' 

Courtroom, 701 E. Broad St., Rm. 5000, Richmond, Virginia. 

137 Sealed Motion/Application(Re: related document(s)133 Motion for Summary 

Judgment filed by ULX Partners, LLC, UnitedLex Corporation, ULX Manager 

LLC) filed by Thomas John McKee Jr. of Greenberg Traurig on behalf of 

ULX Manager LLC, ULX Partners, LLC, UnitedLex Corporation. 

(Attachments: # 1 Statement of Undisputed Material Facts # 2 Deposition Tabs 

# 3 Exhibit(s) 1 # 4 Exhibit(s) 2 # 5 Exhibit(s) 3 # 6 Exhibit(s) 4 # 7 Exhibit(s) 

5 # 8 Exhibit(s) 6 # 9 Exhibit(s) 7 # 10 Exhibit(s) 8 # 11 Exhibit(s) 9 

# 12 Exhibit(s) 10 # 13 Exhibit(s) 11 # 14 Exhibit(s) 12 # 15 Exhibit(s) 13 

# 16 Exhibit(s) 14 # 17 Exhibit(s) 15 # 18 Exhibit(s) 16 # 19 Exhibit(s) 17 

# 20 Exhibit(s) 18 # 21 Exhibit(s) 19 # 22 Exhibit(s) 20 # 23 Exhibit(s) 21 

# 24 Exhibit(s) 22 # 25 Exhibit(s) 23 # 26 Exhibit(s) 24 # 27 Exhibit(s) 25 

# 28 Exhibit(s) 26 # 29 Exhibit(s) 27 # 30 Exhibit(s) 28 # 31 Exhibit(s) 29 

# 32 Exhibit(s) 30 # 33 Exhibit(s) 31 # 34 Exhibit(s) 32 # 35 Exhibit(s) 33 

# 36 Exhibit(s) 34 # 37 Exhibit(s) 35 # 38 Exhibit(s) 36 # 39 Exhibit(s) 37 

# 40 Exhibit(s) 38 # 41 Exhibit(s) 39 # 42 Exhibit(s) 40 # 43 Exhibit(s) 41 

# 44 Exhibit(s) 42 # 45 Exhibit(s) 43 # 46 Exhibit(s) 44 # 47 Exhibit(s) 45 

# 48 Exhibit(s) 46 # 49 Exhibit(s) 47 # 50 Exhibit(s) 48 # 51 Exhibit(s) 49 

# 52 Exhibit(s) 50 # 53 Exhibit(s) 51 # 54 Exhibit(s) 52 # 55 Exhibit(s) 53 

# 56 Exhibit(s) 54 # 57 Exhibit(s) 55 # 58 Exhibit(s) 56 # 59 Exhibit(s) 57 

# 60 Exhibit(s) 58 # 61 Exhibit(s) 59 # 62 Exhibit(s) 60)

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138 Amended Notice of Hearing (Re: related document(s)133 Motion for 

Summary Judgment filed by ULX Partners, LLC, UnitedLex Corporation, 

ULX Manager LLC) filed by Thomas John McKee Jr. of Greenberg Traurig 

on behalf of ULX Manager LLC, ULX Partners, LLC, UnitedLex Corporation. 

Hearing scheduled for 2/17/2022 at 01:00 PM at Judge Huennekens' 

Courtroom, 701 E. Broad St., Rm. 5000, Richmond, Virginia. 

139 Amended Notice of Hearing (Re: related document(s)135 Motion to File 

Documents(s) Under Seal filed by ULX Partners, LLC, UnitedLex 

Corporation, ULX Manager LLC) filed by Thomas John McKee Jr. of 

Greenberg Traurig on behalf of ULX Manager LLC, ULX Partners, LLC, 

UnitedLex Corporation. Hearing scheduled for 2/17/2022 at 01:00 PM at 

Judge Huennekens' Courtroom, 701 E. Broad St., Rm. 5000, Richmond, 

Virginia. 

140 Order Setting Hearing (Re: related document(s)100 Pre-Trial Order) Hearing 

scheduled for 2/4/2022 at 10:00 AM at Judge Huennekens' Courtroom, 701 E. 

Broad St., Rm. 5000, Richmond, Virginia. 

142 Order Appointing Honorable Frank J. Santoro as Judicial Mediator 

144 Fourth Stipulation and Amended Pre-Trial Order; (Re: related 

document(s)100 Pre-Trial Order) Trial set for 4/18/2022 through 4/29/2022 at 

10:00 AM at Judge Huennekens', 701 E. Broad St., Rm. 5000, Richmond, 

Virginia. A hearing on any dispositive Motions including summary judgment 

motions shall be held on March 15, 2022 at 11:00 a.m. at Judge Huennekens', 

701 E. Broad St., Rm. 5000, Richmond, Virginia A hearing on the motion to 

amend shall be March 8, 2022 at 11:00 a.m. at Judge Huennekens', 701 E. 

Broad St., Rm. 5000, Richmond, Virginia

145 Transcript of Hearing Held 2/4/2022.

147 Motion to Amend First Amended Complaint (Re: related 

document(s)86 Amended Complaint filed by Lynn L. Tavenner, as Chapter 7 

Trustee, Lynn L. Tavenner, as Chapter 7 Trustee) filed by Erika L. Morabito 

of Quinn Emanuel on behalf of Lynn L. Tavenner, as Chapter 7 Trustee. 

(Attachments: # 1 Exhibit A).

148 Notice of Hearing (Re: related document(s)147 Motion to Amend filed by 

Lynn L. Tavenner, as Chapter 7 Trustee, Lynn L. Tavenner, as Chapter 7 

Trustee) filed by Erika L. Morabito of Quinn Emanuel on behalf of Lynn L. 

Tavenner, as Chapter 7 Trustee. Hearing scheduled for 3/8/2022 at 11:00 AM 

at Judge Huennekens' Courtroom, 701 E. Broad St., Rm. 5000, Richmond, 

Virginia. 

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149 Sealed Motion/Application(Re: related document(s)147 Motion to Amend 

filed by Lynn L. Tavenner, as Chapter 7 Trustee, Lynn L. Tavenner, as 

Chapter 7 Trustee) filed by Erika L. Morabito of Quinn Emanuel on behalf of 

Lynn L. Tavenner, as Chapter 7 Trustee. (Attachments: # 1 Exhibit A) 

150 Sealed Answer/Response/Reply(Re: related document(s)137 Sealed Document 

filed by ULX Partners, LLC, UnitedLex Corporation, ULX Manager LLC) 

filed by Erika L. Morabito of Quinn Emanuel on behalf of Lynn L. Tavenner, 

as Chapter 7 Trustee. 

152 Corrected Sealed Answer/Response/Reply(Re: related document(s)137 Sealed 

Document filed by ULX Partners, LLC, UnitedLex Corporation, ULX 

Manager LLC, 150 Sealed Document filed by Lynn L. Tavenner, as Chapter 7 

Trustee, Lynn L. Tavenner, as Chapter 7 Trustee) filed by Erika L. Morabito 

of Quinn Emanuel on behalf of Lynn L. Tavenner, as Chapter 7 Trustee. 

153 Sealed Exhibit(Re: related document(s)152 Sealed Document filed by Lynn L. 

Tavenner, as Chapter 7 Trustee, Lynn L. Tavenner, as Chapter 7 Trustee) filed 

by Erika L. Morabito of Quinn Emanuel on behalf of Lynn L. Tavenner, as 

Chapter 7 Trustee.

154 Motion to File Document(s) Under Seal (Re: related document(s)150 Sealed 

Document filed by Lynn L. Tavenner, as Chapter 7 Trustee, Lynn L. 

Tavenner, as Chapter 7 Trustee, 152 Sealed Document filed by Lynn L. 

Tavenner, as Chapter 7 Trustee, Lynn L. Tavenner, as Chapter 7 

Trustee, 153 Sealed Document filed by Lynn L. Tavenner, as Chapter 7 

Trustee, Lynn L. Tavenner, as Chapter 7 Trustee) filed by Erika L. Morabito 

of Quinn Emanuel on behalf of Lynn L. Tavenner, as Chapter 7 Trustee. 

155 Notice of Hearing (Re: related document(s)154 Motion to File Documents(s) 

Under Seal filed by Lynn L. Tavenner, as Chapter 7 Trustee, Lynn L. 

Tavenner, as Chapter 7 Trustee) filed by Erika L. Morabito of Quinn Emanuel 

on behalf of Lynn L. Tavenner, as Chapter 7 Trustee. Hearing scheduled for 

3/15/2022 at 11:00 AM at Judge Huennekens' Courtroom, 701 E. Broad St., 

Rm. 5000, Richmond, Virginia. 

156 Sealed Answer/Response/Reply(Re: related document(s)133 Motion for 

Summary Judgment filed by ULX Partners, LLC, UnitedLex Corporation, 

ULX Manager LLC) filed by Thomas John McKee Jr. of Greenberg Traurig 

on behalf of ULX Manager LLC, ULX Partners, LLC, UnitedLex Corporation. 

(Attachments: # 1 Exhibit(s) A # 2 Exhibit(s) B # 3 Exhibit(s) C # 4 Exhibit(s) 

D # 5 Exhibit(s) E # 6 Exhibit(s) F # 7 Exhibit(s) G # 8 Exhibit(s) H 

# 9 Exhibit(s) I # 10 Exhibit(s) J # 11 Exhibit(s) K # 12 Exhibit(s) L 

# 13 Exhibit(s) M).

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157 Motion to File Document(s) Under Seal (Re: related document(s)156 Sealed 

Document filed by ULX Partners, LLC, UnitedLex Corporation, ULX 

Manager LLC) filed by Thomas John McKee Jr. of Greenberg Traurig on 

behalf of ULX Manager LLC, ULX Partners, LLC, UnitedLex Corporation. 

(Attachments: # 1 Proposed Order).

158 Notice of Hearing (Re: related document(s)157 Motion to File Documents(s) 

Under Seal filed by ULX Partners, LLC, UnitedLex Corporation, ULX 

Manager LLC) filed by Thomas John McKee Jr. of Greenberg Traurig on 

behalf of ULX Manager LLC, ULX Partners, LLC, UnitedLex Corporation. 

Hearing scheduled for 3/15/2022 at 11:00 AM at Judge Huennekens' 

Courtroom, 701 E. Broad St., Rm. 5000, Richmond, Virginia. 

159 Notice of Motion and Notice of Hearing (Re: related document(s)147 Motion 

to Amend filed by Lynn L. Tavenner, as Chapter 7 Trustee, Lynn L. Tavenner, 

as Chapter 7 Trustee) filed by Erika L. Morabito of Quinn Emanuel on behalf 

of Lynn L. Tavenner, as Chapter 7 Trustee. Hearing scheduled for 3/8/2022 at 

11:00 AM at Judge Huennekens' Courtroom, 701 E. Broad St., Rm. 5000, 

Richmond, Virginia. 

160 Motion to File Document(s) Under Seal (Re: related document(s)147 Motion 

to Amend filed by Lynn L. Tavenner, as Chapter 7 Trustee, Lynn L. Tavenner, 

as Chapter 7 Trustee) filed by Erika L. Morabito of Quinn Emanuel on behalf 

of Lynn L. Tavenner, as Chapter 7 Trustee. (Attachments: # 1 Exhibit A 

# 2 Exhibit B).

161 Notice of Motion and Notice of Hearing (Re: related document(s)160 Motion 

to File Documents(s) Under Seal filed by Lynn L. Tavenner, as Chapter 7 

Trustee, Lynn L. Tavenner, as Chapter 7 Trustee) filed by Erika L. Morabito 

of Quinn Emanuel on behalf of Lynn L. Tavenner, as Chapter 7 Trustee. 

Hearing scheduled for 3/8/2022 at 11:00 AM at Judge Huennekens' 

Courtroom, 701 E. Broad St., Rm. 5000, Richmond, Virginia. 

162 Mediation Order (Re: related document(s)142 Order Appointing).

166 Transcript of Hearing Held 2/17/2022.

168 Response to (Re: related document(s)147 Motion to Amend filed by Lynn L. 

Tavenner, as Chapter 7 Trustee, Lynn L. Tavenner, as Chapter 7 Trustee) filed 

by Thomas John McKee Jr. of Greenberg Traurig on behalf of ULX Manager 

LLC, ULX Partners, LLC, UnitedLex Corporation. (Attachments: 

# 1 Exhibit(s) A # 2 Exhibit(s) B # 3 Exhibit(s) C # 4 Exhibit(s) D 

# 5 Exhibit(s) E # 6 Exhibit(s) F # 7 Exhibit(s) G # 8 Exhibit(s) H 

# 9 Exhibit(s) I # 10 Exhibit(s) J # 11 Exhibit(s) K # 12 Exhibit(s) L 

# 13 Exhibit(s) M).

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169 Sealed Answer/Response/Reply(Re: related document(s)147 Motion to Amend 

filed by Lynn L. Tavenner, as Chapter 7 Trustee, Lynn L. Tavenner, as 

Chapter 7 Trustee) filed by Thomas John McKee Jr. of Greenberg Traurig on 

behalf of ULX Manager LLC, ULX Partners, LLC, UnitedLex Corporation. 

(Attachments: # 1 Exhibit(s) A # 2 Exhibit(s) B # 3 Exhibit(s) C # 4 Exhibit(s) 

D # 5 Exhibit(s) E # 6 Exhibit(s) F # 7 Exhibit(s) G # 8 Exhibit(s) H 

# 9 Exhibit(s) I # 10 Exhibit(s) J # 11 Exhibit(s) K # 12 Exhibit(s) L 

# 13 Exhibit(s) M).

170 Motion to File Document(s) Under Seal (Re: related document(s)169 Sealed 

Document filed by ULX Partners, LLC, UnitedLex Corporation, ULX 

Manager LLC) filed by Thomas John McKee Jr. of Greenberg Traurig on 

behalf of ULX Manager LLC, ULX Partners, LLC, UnitedLex Corporation. 

(Attachments: # 1 Proposed Order).

171 Notice of Hearing (Re: related document(s)170 Motion to File Documents(s) 

Under Seal filed by ULX Partners, LLC, UnitedLex Corporation, ULX 

Manager LLC) filed by Thomas John McKee Jr. of Greenberg Traurig on 

behalf of ULX Manager LLC, ULX Partners, LLC, UnitedLex Corporation. 

Hearing scheduled for 3/8/2022 at 11:00 AM at Judge Huennekens' 

Courtroom, 701 E. Broad St., Rm. 5000, Richmond, Virginia. 

172 Sealed Exhibit(Re: related document(s)152 Sealed Document filed by Lynn L. 

Tavenner, as Chapter 7 Trustee, Lynn L. Tavenner, as Chapter 7 

Trustee, 153 Sealed Document filed by Lynn L. Tavenner, as Chapter 7 

Trustee, Lynn L. Tavenner, as Chapter 7 Trustee) filed by Brittany Jane 

Nelson of Quinn Emanuel on behalf of Lynn L. Tavenner, as Chapter 7 

Trustee. (Attachments: # 1 Transcript Exhibits # 2 Exhibit(s) 1-6 # 3 Exhibit(s) 

7-17 # 4 Exhibit(s) 18-34 # 5 Exhibit(s) 35-38 # 6 Exhibit(s) 39-40 

# 7 Exhibit(s) 41 - Part 1 # 8 Exhibit(s) 41 - Part 2 # 9 Exhibit(s) 42-45 

# 10 Exhibit(s) 46-47 # 11 Exhibit(s) 48-50 # 12 Exhibit(s) 51 - Part 1 

# 13 Exhibit(s) 51 - Part 2 # 14 Exhibit(s) 51 - Part 3 # 15 Exhibit(s) 51 - Part 

4 # 16 Exhibit(s) 52-56 # 17 Exhibit(s) 57-63 # 18 Exhibit(s) 64-70 

# 19 Exhibit(s) 71 - Part 1 # 20 Exhibit(s) 71 - Part 2 # 21 Exhibit(s) 71 - Part 

3 # 22 Exhibit(s) 71 - Part 4 # 23 Exhibit(s) 72-77 # 24 Exhibit(s) 78-86 

# 25 Exhibit(s) 87-99 # 26 Exhibit(s) 100-103 # 27 Exhibit(s) 104 

# 28 Exhibit(s) 105-107 # 29 Exhibit(s) 108 # 30 Exhibit(s) 109-111 

# 31 Exhibit(s) 112-119 # 32 Exhibit(s) 120-123 # 33 Exhibit(s) 124-130 

# 34 Exhibit(s) 131-133 # 35 Exhibit(s) 134-137 # 36 Exhibit(s) 138 

# 37 Exhibit(s) 139 - Part 1 # 38 Exhibit(s) 139 - Part 2 # 39 Exhibit(s) 139 -

Part 3 # 40 Exhibit(s) 140)

173 Sealed Answer/Response/Reply(Re: related document(s)147 Motion to Amend 

filed by Lynn L. Tavenner, as Chapter 7 Trustee, Lynn L. Tavenner, as 

Chapter 7 Trustee) filed by Erika L. Morabito of Quinn Emanuel on behalf of 

Lynn L. Tavenner, as Chapter 7 Trustee. 

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174 Reply to Motion to Amend First Amended Complaint (Re: related 

document(s)173 Sealed Document filed by Lynn L. Tavenner, as Chapter 7 

Trustee, Lynn L. Tavenner, as Chapter 7 Trustee) filed by Erika L. Morabito 

of Quinn Emanuel on behalf of Lynn L. Tavenner, as Chapter 7 Trustee. 

(Attachments: # 1 Exhibit 1 # 2 Exhibit 2 # 3 Exhibit 3 # 4 Exhibit 4 

# 5 Exhibit 5 # 6 Exhibit 6 # 7 Tab A # 8 Tab C).

175 Sealed Exhibit(Re: related document(s)168 Response to Motion/Application 

filed by ULX Partners, LLC, UnitedLex Corporation, ULX Manager LLC) 

filed by Erika L. Morabito of Quinn Emanuel on behalf of Lynn L. Tavenner, 

as Chapter 7 Trustee.

176 Statement - Proposed Agenda for March 8, 2022 Hearing filed by Paula S. 

Beran of Tavenner & Beran, PLC on behalf of Lynn L. Tavenner, as Chapter 7 

Trustee. 

177 Order Directing Defendants to Produce Insurance-Related Information. (Re: 

related document(s)142 Order Appointing, 162 Order Directing)

178 Order Directing the Exchange of Information Between the Defendants, 

Nicholas Hinton, Daniel Reed, The Insurance Companies and the Chapter 7 

Trustee. (Re: related document(s)142 Order Appointing, 162 Order Directing).

182 Supplemental Order Appointing Mediator (Re: related document(s)142 Order 

Appointing).

183 Fifth Amended Pre-Trial Order; (Re: related document(s)4 Amended 

Complaint filed by Lynn L. Tavenner, as Chapter 7 Trustee, Lynn L. 

Tavenner, as Chapter 7 Trustee, 144 Pre-Trial Order) Trial set for 5/16/2022 

through 5/27, 2022 at 10:00 AM at Judge Huennekens' Courtroom, 701 E. 

Broad St., Rm. 5000, Richmond, Virginia.

184 Order Continuing Hearings (Re: related document(s)147 Motion to Amend 

filed by Lynn L. Tavenner, as Chapter 7 Trustee, Lynn L. Tavenner, as 

Chapter 7 Trustee, 160 Motion to File Documents(s) Under Seal filed by Lynn 

L. Tavenner, as Chapter 7 Trustee, Lynn L. Tavenner, as Chapter 7 

Trustee, 170 Motion to File Documents(s) Under Seal filed by ULX Partners, 

LLC, UnitedLex Corporation, ULX Manager LLC) Hearing scheduled for 

4/19/2022 at 11:00 AM at Judge Huennekens' Courtroom, 701 E. Broad St., 

Rm. 5000, Richmond, Virginia.(Re: related document(s) 133 Motion for 

Summary Judgment filed by Thomas John McKee Jr. of Greenberg 

Traurig, 135 Motion to File Document(s) Under Seal filed by Thomas 

McKee, 154 Motion to File Document(s) Under Seal filed by Erika 

Morabito, 157 Motion to File Document(s) Under Seal filed by Thomas 

Mckee) Hearing scheduled for 4/28/2022 at 11:00 AM at Judge Huennekens' 

Courtroom, 701 E. Broad St., Rm. 5000, Richmond, Virginia.

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189 Statement regarding Notice of Filed Declarations filed by Thomas John 

McKee Jr. of Greenberg Traurig on behalf of ULX Manager LLC, ULX 

Partners, LLC, UnitedLex Corporation. 

190 Sixth Amended Pre-Trial Order; (Re: related document(s)183 Pre-Trial Order) 

Trial set for 5/16/2022 through 5/27, 2022 at 10:00 AM at Judge Huennekens' 

Courtroom, 701 E. Broad St., Rm. 5000, Richmond, Virginia. (Bullock, 

Nathaniel) (Bullock, Nathaniel). Related document(s) 4 Amended Complaint 

filed by Counter-Defendant Lynn L. Tavenner, as Chapter 7 Trustee, Plaintiff 

Lynn L. Tavenner, as Chapter 7 Trustee. Modified on 3/24/2022 to add related 

document to docket entry.

193 Transcript of Hearing Held 3/8/2022.

195 Mediation Order Regarding Confidentiality (Re: related document(s)142 Order 

Appointing, 162 Order Directing) (Ramirez-Lowe, Suzan)

200 Transcript of Hearing Held 4/19/2022.

201 Consent Motion to Continue April 28th Hearing and to Stay Remaining 

Deadlines in the Court's Sixth Stipulation and Amended Pre-Trial Order (Re: 

related document(s)190 Pre-Trial Order) filed by Thomas John McKee Jr. of 

Greenberg Traurig on behalf of ULX Manager LLC, ULX Partners, LLC, 

UnitedLex Corporation. (Attachments: # 1 Exhibit(s) A - Proposed Order).

202 Consent Order Granting Motion to Continue April 28th Hearing and to Stay 

Remaining Deadlines in the Court's Sixth Stipulation and Amended Pre-Trial 

Order (Related Doc # 201) Hearing scheduled for 5/25/2022 at 11:00 AM at 

Judge Huennekens' Courtroom, 701 E. Broad St., Rm. 5000, Richmond, 

Virginia. 

207 Motion to Restrict Public Access to Sensitive Case Information - Motion to 

Seal Settlement Agreement and Related Documents, Information, and 

Hearings [Redacted document attached](Re: related 

document(s)200 Transcript filed) filed by David G. Barger of Greenberg 

Traurig, LLP on behalf of ULX Manager LLC, ULX Partners, LLC, 

UnitedLex Corporation. (Attachments: # 1 Exhibit(s) A - Proposed Order 

# 2 Exhibit(s) B - Redacted Transcript).

208 Notice of Hearing (Re: related document(s)207 Motion to Restrict Public 

Access to Sensitive Case Information filed by ULX Partners, LLC, UnitedLex 

Corporation, ULX Manager LLC) filed by David G. Barger of Greenberg 

Traurig, LLP on behalf of ULX Manager LLC, ULX Partners, LLC, 

UnitedLex Corporation. Hearing scheduled for 5/25/2022 at 11:00 AM at 

Judge Huennekens' Courtroom, 701 E. Broad St., Rm. 5000, Richmond, 

Virginia.

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210 Unopposed Bridge Order Restricting Public Access (Re: related 

document(s)200 Transcript filed, 207 Motion to Restrict Public Access to 

Sensitive Case Information filed by ULX Partners, LLC, UnitedLex 

Corporation, ULX Manager LLC).

211 Sealed Motion/Application(Re: related document(s)207 Motion to Restrict 

Public Access to Sensitive Case Information filed by ULX Partners, LLC, 

UnitedLex Corporation, ULX Manager LLC) filed by Erika L. Morabito of 

Quinn Emanuel on behalf of Lynn L. Tavenner, as Chapter 7 Trustee. 

(Attachments: # 1 Exhibit A # 2 Exhibit B # 3 Exhibit C # 4 Exhibit D).

212 Notice of Motion and Notice of Hearing (Re: related document(s)211 Sealed 

Document filed by Lynn L. Tavenner, as Chapter 7 Trustee, Lynn L. 

Tavenner, as Chapter 7 Trustee) filed by Erika L. Morabito of Quinn Emanuel 

on behalf of Lynn L. Tavenner, as Chapter 7 Trustee. Hearing scheduled for 

6/8/2022 at 1:00 PM at Judge Huennekens' Courtroom, 701 E. Broad St., Rm. 

5000, Richmond, Virginia. (Morabito, Erika) Modified on 5/19/2022 to correct 

hearing time to 1:00 PM .

215 Objection to Motion to Seal Settlement Agreement and Related Documents, 

Information, and Hearings (Re: related document(s)207 Motion to Restrict 

Public Access to Sensitive Case Information filed by ULX Partners, LLC, 

UnitedLex Corporation, ULX Manager LLC) filed by Kathryn R. Montgomery 

of Office of the United States Trustee on behalf of John P. Fitzgerald III. 

216 Objection to Trustee's Motion for Sealed Document (Re: related 

document(s)211 Sealed Document filed by Lynn L. Tavenner, as Chapter 7 

Trustee, Lynn L. Tavenner, as Chapter 7 Trustee) filed by Kathryn R. 

Montgomery of Office of the United States Trustee on behalf of John P. 

Fitzgerald III. 

217 Motion for Status Hearing and A Scheduling Order, Notice of Motion and 

Notice of Hearing (Re: related document(s)211 Sealed Document filed by 

Lynn L. Tavenner, as Chapter 7 Trustee, Lynn L. Tavenner, as Chapter 7 

Trustee) Hearing scheduled for 5/25/2022 at 11:00 AM at Judge Huennekens' 

Courtroom, 701 E. Broad St., Rm. 5000, Richmond, Virginia. Filed by 

Kathryn R. Montgomery of Office of the United States Trustee on behalf of 

John P. Fitzgerald III.

218 Motion to Expedite Hearing with Proposed Order and Notice of Hearing (Re: 

related document(s)217 Motion for Status Hearing filed by John P. Fitzgerald, 

Notice of Motion and Notice of Hearing) filed by Kathryn R. Montgomery of 

Office of the United States Trustee on behalf of John P. Fitzgerald III. Hearing 

scheduled for 5/25/2022 at 11:00 AM at Judge Huennekens' Courtroom, 701 

E. Broad St., Rm. 5000, Richmond, Virginia.

219 Objection to (Re: related document(s)217 Motion for Status Hearing filed by 

John P. Fitzgerald) filed by Erika L. Morabito of Quinn Emanuel on behalf of 

Lynn L. Tavenner, as Chapter 7 Trustee. 

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224 Order Continuing Hearing (Re: related document(s)147 Motion to Amend 

filed by Lynn L. Tavenner, as Chapter 7 Trustee, Lynn L. Tavenner, as 

Chapter 7 Trustee, 160 Motion to File Documents(s) Under Seal filed by Lynn 

L. Tavenner, as Chapter 7 Trustee, Lynn L. Tavenner, as Chapter 7 

Trustee, 170 Motion to File Documents(s) Under Seal filed by ULX Partners, 

LLC, UnitedLex Corporation, ULX Manager LLC, 207 Motion to Restrict 

Public Access to Sensitive Case Information filed by ULX Partners, LLC, 

UnitedLex Corporation, ULX Manager LLC) Hearing scheduled for 5/26/2022 

at 12:00 PM at Judge Huennekens' Courtroom, 701 E. Broad St., Rm. 5000, 

Richmond, Virginia. 

233 Order Continuing Hearing (Re: related document(s)217 Motion for Status 

Hearing filed by John P. Fitzgerald, Notice of Motion and Notice of Hearing) 

Hearing scheduled for 6/1/2022 at 01:00 PM at Judge Huennekens' Courtroom, 

701 E. Broad St., Rm. 5000, Richmond, Virginia. 

234 Transcript of Hearing Held 5/25/2022.

235 Transcript of Hearing Held 5/25/2022.

236 Transcript of Hearing Held 5/26/2022.

237 Statement - NOTICE OF CANCELLATION OF HEARING SCHEDULED 

FOR JUNE 1, 2022 at 1:00 P.M. (Re: related document(s)233 Order 

Continuing/Rescheduling/Setting Hearing) filed by Paula S. Beran of 

Tavenner & Beran, PLC on behalf of Lynn L. Tavenner, as Chapter 7 Trustee.

238 Motion to File Document(s) Under Seal (Foley & Lardner LLPs Motion 

Requesting Authorization to Seal Its Limited Objection to the Trustees 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) filed by Susan Poll Klaessy of Foley & Lardner LLP on behalf of Foley 

& Lardner LLP. 

239 Notice of Motion and Hearing Thereon (Re: related document(s)238 Motion to 

File Documents(s) Under Seal filed by Foley & Lardner LLP) filed by Susan 

Poll Klaessy of Foley & Lardner LLP on behalf of Foley & Lardner LLP. 

240 Sealed Answer/Response/Reply(Re: related document(s)238 Motion to File 

Documents(s) Under Seal filed by Foley & Lardner LLP) filed by Susan Poll 

Klaessy of Foley & Lardner LLP on behalf of Foley & Lardner LLP. 

241 Corrected Notice of Hearing (Redocketed to including Hearing 

Information) (Re: related document(s)238 Motion to File Documents(s) Under 

Seal filed by Foley & Lardner LLP, 239 Notice of Motion filed by Foley & 

Lardner LLP) filed by Susan Poll Klaessy of Foley & Lardner LLP on behalf 

of Foley & Lardner LLP. Hearing scheduled for 6/8/2022 at 01:00 PM at 

Judge Huennekens' Courtroom, 701 E. Broad St., Rm. 5000, Richmond, 

Virginia. 

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243 Sealed Objection (Related Document(s)211 Sealed Document filed by Lynn L. 

Tavenner, as Chapter 7 Trustee, Lynn L. Tavenner, as Chapter 7 Trustee) filed 

by Kathryn R. Montgomery of Office of the United States Trustee on behalf of 

John P. Fitzgerald III. 

244 Statement (Notice of Objection and Hearing set for 6/8/2022 at 1:00 p.m. (Re: 

related document(s)243 Sealed Document filed by John P. Fitzgerald) filed by 

Kathryn R. Montgomery of Office of the United States Trustee on behalf of 

John P. Fitzgerald III. 

245 Motion to File Document(s) Under Seal and Reservation of Rights, with 

Notice of Motion, and with Notice of Hearing, (Related 

Document(s)211 Sealed Document filed by Lynn L. Tavenner, as Chapter 7 

Trustee, Lynn L. Tavenner, as Chapter 7 Trustee, 243 Sealed Document filed 

by John P. Fitzgerald, 244 Statement filed by John P. Fitzgerald) filed by 

Kathryn R. Montgomery of Office of the United States Trustee on behalf of 

John P. Fitzgerald III. Hearing scheduled for 6/8/2022 at 01:00 PM at Judge 

Huennekens' Courtroom, 701 E. Broad St., Rm. 5000, Richmond, Virginia. 

246 Motion to Expedite Hearing with Notice and Proposed Order, and with Notice 

of Hearing, (Related Document(s)245 Motion to File Documents(s) Under 

Seal filed by John P. Fitzgerald) filed by Kathryn R. Montgomery of Office of 

the United States Trustee on behalf of John P. Fitzgerald III. Hearing 

scheduled for 6/8/2022 at 01:00 PM at Judge Huennekens' Courtroom, 701 E. 

Broad St., Rm. 5000, Richmond, Virginia.

247 Motion to Expedite Hearing (Re: related document(s)238 Motion to File 

Documents(s) Under Seal filed by Foley & Lardner LLP) filed by Susan Poll 

Klaessy of Foley & Lardner LLP on behalf of Foley & Lardner LLP. 

248 Notice of Motion and Notice of Hearing (Re: related document(s)247 Motion 

to Expedite Hearing filed by Foley & Lardner LLP) filed by Susan Poll 

Klaessy of Foley & Lardner LLP on behalf of Foley & Lardner LLP. Hearing 

scheduled for 6/8/2022 at 01:00 PM at Judge Huennekens' Courtroom, 701 E. 

Broad St., Rm. 5000, Richmond, Virginia. 

249 Sealed Certification/Declaration/Statement(Re: related document(s)211 Sealed 

Document filed by Lynn L. Tavenner, as Chapter 7 Trustee, Lynn L. 

Tavenner, as Chapter 7 Trustee) filed by Erika L. Morabito of Quinn Emanuel 

on behalf of Lynn L. Tavenner, as Chapter 7 Trustee. (Attachments: 

# 1 Exhibit 1 # 2 Exhibit 2 # 3 Exhibit 3 # 4 Exhibit 4 # 5 Exhibit 5 # 6 Exhibit 

6 # 7 Exhibit 7 # 8 Exhibit 8 # 9 Exhibit 9 # 10 Exhibit 10 # 11 Exhibit 11 

# 12 Exhibit 12 # 13 Exhibit 13 # 14 Exhibit 14)

250 Order to Seal Omnibus Settlement Agreement and Related Documents, 

Information, and Hearings (Related Doc 207) (Bray, Lynessa).

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252 Sealed Answer/Response/Reply(Re: related document(s) 211 Sealed 

Document filed by Lynn L. Tavenner, as Chapter 7 Trustee, Lynn L. 

Tavenner, as Chapter 7 Trustee) filed by Erika L. Morabito of Quinn Emanuel 

on behalf of Lynn L. Tavenner, as Chapter 7 Trustee. 

253 Sealed Notice(Re: related document(s)211 Sealed Document filed by Lynn L. 

Tavenner, as Chapter 7 Trustee, Lynn L. Tavenner, as Chapter 7 Trustee) filed 

by David G. Barger of Greenberg Traurig, LLP on behalf of ULX Manager 

LLC, ULX Partners, LLC, UnitedLex Corporation. 

254 Amended Sealed Exhibit(Re: related document(s)211 Sealed Document filed 

by Lynn L. Tavenner, as Chapter 7 Trustee, Lynn L. Tavenner, as Chapter 7 

Trustee) filed by Erika L. Morabito of Quinn Emanuel on behalf of Lynn L. 

Tavenner, as Chapter 7 Trustee. 

259 Transcript of Hearing Held 6/8/2022.

265 Motion for Approval of Agreement Re-docketed to file unsealed version with 

redactions (Re: related document(s)211 Sealed Document filed by Lynn L. 

Tavenner, as Chapter 7 Trustee, Lynn L. Tavenner, as Chapter 7 Trustee) filed 

by Erika L. Morabito of Quinn Emanuel on behalf of Lynn L. Tavenner, as 

Chapter 7 Trustee. 

266 Statement April 19, 2022 Transcript - Re-docketed to file unsealed version 

with redactions (Re: related document(s)200 Transcript filed) filed by Erika L. 

Morabito of Quinn Emanuel on behalf of Lynn L. Tavenner, as Chapter 7 

Trustee. 

267 Exhibit A - Re-docketed to file unsealed version with redactions (Re: related 

document(s)147 Motion to Amend filed by Lynn L. Tavenner, as Chapter 7 

Trustee, Lynn L. Tavenner, as Chapter 7 Trustee) filed by Erika L. Morabito 

of Quinn Emanuel on behalf of Lynn L. Tavenner, as Chapter 7 Trustee.

269 Supplemental Sealed Motion/Application(Re: related document(s)207 Motion 

to Restrict Public Access to Sensitive Case Information filed by ULX Partners, 

LLC, UnitedLex Corporation, ULX Manager LLC) filed by David G. Barger 

of Greenberg Traurig, LLP on behalf of ULX Manager LLC, ULX Partners, 

LLC, UnitedLex Corporation. (Attachments: # 1 Exhibit(s) 1 # 2 Exhibit(s) 

Attachment 1 # 3 Exhibit(s) Attachment 2 # 4 Exhibit(s) Attachment 3 

# 5 Exhibit(s) Attachment 4 # 6 Exhibit(s) Attachment 5 # 7 Exhibit(s) 

Attachment 6 # 8 Exhibit(s) Attachment 7 # 9 Exhibit(s) Attachment 8 

# 10 Exhibit(s) Attachment 9).

270 Sealed Certification/Declaration/Statement(Re: related 

document(s)207 Motion to Restrict Public Access to Sensitive Case 

Information filed by ULX Partners, LLC, UnitedLex Corporation, ULX 

Manager LLC, 269 Sealed Document filed by ULX Partners, LLC, UnitedLex 

Corporation, ULX Manager LLC) filed by David G. Barger of Greenberg 

Traurig, LLP on behalf of ULX Manager LLC, ULX Partners, LLC, 

UnitedLex Corporation. 

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Dkt. No. Description

272 Transcript of Hearing Held 7/14/2022.

273 Notice of Appeal Re: Oral Ruling on July 14, 2022, of U.S. Bankruptcy Court 

EDVA Granting Motion to Seal Settlement Agreement & Related Documents, 

Information and Hearings [Order Not Entered on Docket] filed by Kathryn R. 

Montgomery of Office of the United States Trustee on behalf of John P. 

Fitzgerald III. Appellant Designation due by 8/2/2022.

274 Exhibit 1 (Transcript of Open Court Hearing on July 14, 2022)

275 Sealed Exhibit (Related Document(s)273 Notice of Appeal filed by John P. 

Fitzgerald)

Tavenner v. CVC Capital Partners, LLC, 21-03095

Dkt. No. Description

Docket Sheet

1 Complaint against CVC Capital Partners, Daniel Reed, Nicholas Hinton, Josh 

Rosenfeld, P. Douglas Benson filed by Lynn L. Tavenner, as Chapter 7 

Trustee. 

4 Summons and notice issued to P. Douglas Benson ; CVC Capital Partners ; 

Nicholas Hinton ; Daniel Reed ; Josh Rosenfeld (Re: related 

document(s)1 Complaint filed by Lynn L. Tavenner, as Chapter 7 Trustee).

7 Motion to Dismiss Adversary Proceeding as to Daniel Reed (Re: related 

document(s)1 Complaint filed by Lynn L. Tavenner, as Chapter 7 Trustee) 

filed by Thomas John McKee Jr. of Greenberg Traurig on behalf of Daniel 

Reed. (Attachments: # 1 Proposed Order).

8 Memorandum in Support of Daniel Reed's Motion to Dismiss (Re: related 

document(s)7 Motion to Dismiss Adversary Proceeding filed by Daniel Reed) 

filed by Thomas John McKee Jr. of Greenberg Traurig on behalf of Daniel 

Reed. (Attachments: # 1 Exhibit(s) A # 2 Exhibit(s) B # 3 Exhibit(s) C 

# 4 Exhibit(s) D).

9 Motion to Dismiss Adversary Proceeding as to Nicholas Hinton (Re: related 

document(s)1 Complaint filed by Lynn L. Tavenner, as Chapter 7 Trustee) 

filed by Thomas John McKee Jr. of Greenberg Traurig on behalf of Nicholas 

Hinton. (Attachments: # 1 Proposed Order).

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10 Memorandum in Support of Nicholas Hinton's Motion to Dismiss (Re: related 

document(s)9 Motion to Dismiss Adversary Proceeding filed by Nicholas 

Hinton) filed by Thomas John McKee Jr. of Greenberg Traurig on behalf of 

Nicholas Hinton. 

11 Inquiry/General Checksheet Issued to Thomas J. McKee, Jr. regarding Motion, 

Notice of Hearing; Notice of Motion/Hearing omitted.. (Re: related 

document(s)7 Motion to Dismiss Adversary Proceeding filed by Daniel Reed).

12 Inquiry/General Checksheet Issued to Thomas J. McKee, Jr. regarding Motion, 

Notice of Hearing; Notice of Motion/Hearing omitted.. (Re: related 

document(s)9 Motion to Dismiss Adversary Proceeding filed by Nicholas 

Hinton).

13 Notice of Motion (Re: related document(s)7 Motion to Dismiss Adversary 

Proceeding filed by Daniel Reed) filed by Thomas John McKee Jr. of 

Greenberg Traurig on behalf of Daniel Reed. 

14 Notice of Motion (Re: related document(s)9 Motion to Dismiss Adversary 

Proceeding filed by Nicholas Hinton) filed by Thomas John McKee Jr. of 

Greenberg Traurig on behalf of Nicholas Hinton. 

17 Trustee's Response to (Re: related document(s)7 Motion to Dismiss Adversary 

Proceeding filed by Daniel Reed, 9 Motion to Dismiss Adversary Proceeding 

filed by Nicholas Hinton) filed by Brittany Jane Nelson of Quinn Emanuel on 

behalf of Lynn L. Tavenner, as Chapter 7 Trustee. (Attachments: # 1 Exhibit A 

# 2 Exhibit B).

18 Stipulation of Extension to Respond to Complaint By Lynn L. Tavenner, as 

Chapter 7 Trustee and Between filed by Brittany Jane Nelson of Quinn 

Emanuel on behalf of Lynn L. Tavenner, as Chapter 7 Trustee. 

19 Defendant's Motion for Withdrawal of Reference and Memorandum of Law in 

Support Thereof filed by Michael E. Hastings of Woods Rogers PLC on behalf 

of CVC Capital Partners. 

21 Defendant's Motion for Jury Demand [Defendant CVC Advisers (India) 

Private Limited] filed by Michael E. Hastings of Woods Rogers PLC on behalf 

of CVC Capital Partners. 

22 Defendant's Motion to Dismiss Adversary Proceeding [CVC Advisers (India) 

Private Limited filed by Michael E. Hastings of Woods Rogers PLC on behalf 

of CVC Capital Partners. 

23 Defendant's Motion to Dismiss Adversary Proceeding Memorandum of Law In 

Support of (Re: related document(s)22 Motion to Dismiss Adversary 

Proceeding filed by CVC Capital Partners) filed by Michael E. Hastings of 

Woods Rogers PLC on behalf of CVC Capital Partners. 

24 Defendant's Exhibit Designation of the Record (Re: related 

document(s)19 Motion for Withdrawal of Reference (fee) filed by CVC 

Capital Partners) filed by Michael E. Hastings of Woods Rogers PLC on 

behalf of CVC Capital Partners. 

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25 Defendant's Notice of Motion by CVC Advisers (India) Private Limited (Re: 

related document(s)19 Motion for Withdrawal of Reference (fee) filed by CVC 

Capital Partners, 21 Jury Demand filed by CVC Capital Partners, 22 Motion to 

Dismiss Adversary Proceeding filed by CVC Capital Partners, 23 Motion to 

Dismiss Adversary Proceeding filed by CVC Capital Partners) filed by 

Michael E. Hastings of Woods Rogers PLC on behalf of CVC Capital 

Partners. 

26 Defendant's Corporate Ownership Statementby CVC Advisers (India) Private 

Limited filed by Michael E. Hastings of Woods Rogers PLC on behalf of CVC 

Capital Partners. 

27 Reply to the Trustee's Response to Motions to Dismiss Filed by Nicholas 

Hinton and Daniel Reed (Re: related document(s)17 Response to 

Motion/Application filed by Lynn L. Tavenner, as Chapter 7 Trustee) filed by 

Thomas John McKee Jr. of Greenberg Traurig on behalf of Nicholas Hinton, 

Daniel Reed.

30 Defendant's Memorandum of Law in Support of Defendant CVC's Motion to 

Dismiss the Complaint (Re: related document(s)22 Motion to Dismiss 

Adversary Proceeding filed by CVC Capital Partners) filed by Michael E. 

Hastings of Woods Rogers PLC on behalf of CVC Capital Partners.

31 Defendant's Designation of Record Regarding Withdrawal of Reference (Re: 

related document(s)19 Motion for Withdrawal of Reference (fee) filed by CVC 

Capital Partners) filed by Michael E. Hastings of Woods Rogers PLC on 

behalf of CVC Capital Partners. Document(s) due by 12/27/2021.

32 Proposed Stipulation and Order Among CVC Advisers (India) Private Limited 

and Lynn L Tavenner, as Chapter 7 Trustee By CVC Capital Partners and 

Between Lynn L. Tavenner, as Chapter 7 Trustee (Re: related 

document(s)19 Motion for Withdrawal of Reference (fee) filed by CVC 

Capital Partners, 21 Jury Demand filed by CVC Capital Partners, 22 Motion to 

Dismiss Adversary Proceeding filed by CVC Capital Partners) filed by 

Michael E. Hastings of Woods Rogers PLC on behalf of CVC Capital 

Partners.

33 Stipulation and Order (Re: related document(s)32 Stipulation filed by CVC 

Capital Partners).

36 Defendant's Motion to Dismiss Adversary Proceeding as to P. Douglas 

Benson (Re: related document(s)1 Complaint filed by Lynn L. Tavenner, as 

Chapter 7 Trustee) filed by Georgina C Shepard of Arnall Golden Gregory 

LLP on behalf of P. Douglas Benson. (Attachments: # 1 Proposed Order).

37 Memorandum in Support of P. Douglas Benson's Motion to Dismiss (Re: 

related document(s)36 Motion to Dismiss Adversary Proceeding filed by P. 

Douglas Benson) filed by Georgina C Shepard of Arnall Golden Gregory LLP 

on behalf of P. Douglas Benson. 

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38 Notice of Motion (Re: related document(s)36 Motion to Dismiss Adversary 

Proceeding filed by P. Douglas Benson) filed by Georgina C Shepard of Arnall 

Golden Gregory LLP on behalf of P. Douglas Benson. 

39 Motion to Dismiss Adversary Proceeding as to Josh Rosenfeld (Re: related 

document(s)1 Complaint filed by Lynn L. Tavenner, as Chapter 7 Trustee) 

filed by Georgina C Shepard of Arnall Golden Gregory LLP on behalf of Josh 

Rosenfeld. (Attachments: # 1 Proposed Order)

40 Memorandum in Support of Josh Rosenfeld's Motion to Dismiss (Re: related 

document(s)39 Motion to Dismiss Adversary Proceeding filed by Josh 

Rosenfeld) filed by Georgina C Shepard of Arnall Golden Gregory LLP on 

behalf of Josh Rosenfeld. 

41 Notice of Motion (Re: related document(s)39 Motion to Dismiss Adversary 

Proceeding filed by Josh Rosenfeld) filed by Georgina C Shepard of Arnall 

Golden Gregory LLP on behalf of Josh Rosenfeld.

42 Joint Stipulation for Partial Dismissal By Lynn L. Tavenner, as Chapter 7 

Trustee and Between filed by Brittany Jane Nelson of Quinn Emanuel on 

behalf of Lynn L. Tavenner, as Chapter 7 Trustee. 

43 Opposition Brief (Re: related document(s)19 Motion for Withdrawal of 

Reference (fee) filed by CVC Capital Partners) filed by Erika L. Morabito of 

Quinn Emanuel on behalf of Lynn L. Tavenner, as Chapter 7 Trustee. 

(Attachments: # 1 Exhibit 1 # 2 Exhibit 2).

44 Stipulation and Order By CVC Capital Partners and Between Lynn L. 

Tavenner, as Chapter 7 Trustee (Re: related document(s)19 Motion for 

Withdrawal of Reference (fee) filed by CVC Capital Partners) filed by 

Michael E. Hastings of Woods Rogers PLC on behalf of CVC Capital 

Partners. 

45 Defendant's Brief in Further Support of Motion to Withdraw the 

Reference (Re: related document(s)19 Motion for Withdrawal of Reference 

(fee) filed by CVC Capital Partners) filed by Michael E. Hastings of Woods 

Rogers PLC on behalf of CVC Capital Partners. 

46 Transmittal of Withdrawal of Reference to the U. S. District Court (Re: related 

document(s)19 Motion for Withdrawal of Reference (fee) filed by CVC 

Capital Partners).

49 Stipulation FOR EXTENSION OF TIME TO RESPOND TO DEFENDANTS' 

MOTIONS TO DISMISS By Lynn L. Tavenner, as Chapter 7 Trustee and 

Between (Re: related document(s)36 Motion to Dismiss Adversary Proceeding 

filed by P. Douglas Benson, 39 Motion to Dismiss Adversary Proceeding filed 

by Josh Rosenfeld) filed by Brittany Jane Nelson of Quinn Emanuel on behalf 

of Lynn L. Tavenner, as Chapter 7 Trustee. 

50 Order of District Court Referring Motion to Withdraw to Bankruptcy Judge 

(Re: related document(s)19 Motion for Withdrawal of Reference (fee) filed by 

CVC Capital Partners).

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51 Proposed Findings of Fact and Conclusions of Law (Re: related 

document(s)19 Motion for Withdrawal of Reference (fee) filed by CVC 

Capital Partners, 43 Opposition Brief filed by Lynn L. Tavenner, as Chapter 7 

Trustee, 45 Brief filed by CVC Capital Partners).

53 Proposed Stipulation and Order Among CVC Advisers (India) Private Limited 

and Lynn L Tavenner, as Chapter 7 Trustee By CVC Capital Partners and 

Between Lynn L. Tavenner, as Chapter 7 Trustee (Re: related 

document(s)19 Motion for Withdrawal of Reference (fee) filed by CVC 

Capital Partners, 23 Motion to Dismiss Adversary Proceeding filed by CVC 

Capital Partners) filed by Michael E. Hastings of Woods Rogers PLC on 

behalf of CVC Capital Partners. 

54 Stipulation and Order (Re: related document(s)19 Motion for Withdrawal of 

Reference (fee) filed by CVC Capital Partners, 23 Motion to Dismiss 

Adversary Proceeding filed by CVC Capital Partners, 53 Stipulation filed by 

CVC Capital Partners)

56 Sealed Motion/Application filed by Erika L. Morabito of Quinn Emanuel on 

behalf of Lynn L. Tavenner, as Chapter 7 Trustee. (Attachments: # 1 Exhibit A 

# 2 Exhibit B # 3 Exhibit C # 4 Exhibit D).

57 Notice of Hearing (Re: related document(s)56 Sealed Document filed by Lynn 

L. Tavenner, as Chapter 7 Trustee) filed by Erika L. Morabito of Quinn 

Emanuel on behalf of Lynn L. Tavenner, as Chapter 7 Trustee. Hearing 

scheduled for 6/8/2022 at 01:00 PM at Judge Huennekens' Courtroom, 701 E. 

Broad St., Rm. 5000, Richmond, Virginia. 

59 Notice of Hearing (Re: related document(s)56 Sealed Document filed by Lynn 

L. Tavenner, as Chapter 7 Trustee, 57 Notice of Hearing filed by Lynn L. 

Tavenner, as Chapter 7 Trustee, 58 Notice of Deficient Filing Issued) filed by 

Erika L. Morabito of Quinn Emanuel on behalf of Lynn L. Tavenner, as 

Chapter 7 Trustee. Hearing scheduled for 6/8/2022 at 01:00 PM at Judge 

Huennekens' Courtroom, 701 E. Broad St., Rm. 5000, Richmond, Virginia.

61 Objection to Motion to Sealed Document (Re: related document(s)56 Sealed 

Document filed by Lynn L. Tavenner, as Chapter 7 Trustee) filed by Kathryn 

R. Montgomery of Office of the United States Trustee on behalf of John P. 

Fitzgerald III.

62 Objection to Trustee's Motion for Order Approving Judicially Mediated 

Settlement and Compensation to Counsel, and Sealed Document (Re: related 

document(s)56 Sealed Document filed by Lynn L. Tavenner, as Chapter 7 

Trustee) filed by Kathryn R. Montgomery of Office of the United States 

Trustee on behalf of John P. Fitzgerald III. 

63 Motion for Status Hearing and A Scheduling Order, Notice of Motion and 

Notice of Hearing (Re: related document(s)56 Sealed Document filed by Lynn 

L. Tavenner, as Chapter 7 Trustee) Hearing scheduled for 5/25/2022 at 11:00 

AM at Judge Huennekens' Courtroom, 701 E. Broad St., Rm. 5000, Richmond, 

Virginia. Filed by Kathryn R. Montgomery of Office of the United States 

Trustee on behalf of John P. Fitzgerald III

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64 Motion to Expedite Hearing with Proposed Order and Notice of Hearing (Re: 

related document(s)63 Motion for Status Hearing filed by John P. Fitzgerald, 

Notice of Motion and Notice of Hearing) filed by Kathryn R. Montgomery of 

Office of the United States Trustee on behalf of John P. Fitzgerald III. Hearing 

scheduled for 5/25/2022 at 11:00 AM at Judge Huennekens' Courtroom, 701 

E. Broad St., Rm. 5000, Richmond, Virginia. 

65 Objection to (Re: related document(s)63 Motion for Status Hearing filed by 

John P. Fitzgerald) filed by Erika L. Morabito of Quinn Emanuel on behalf of 

Lynn L. Tavenner, as Chapter 7 Trustee. 

69 Sealed Objection (Related Document(s)56 Sealed Document filed by Lynn L. 

Tavenner, as Chapter 7 Trustee) filed by Kathryn R. Montgomery of Office of 

the United States Trustee on behalf of John P. Fitzgerald III. 

70 Statement (Notice of Objection and Hearing set for 6/8/2022 at 1:00 

p.m.). (Re: related document(s)69 Sealed Document filed by John P. 

Fitzgerald) filed by Kathryn R. Montgomery of Office of the United States 

Trustee on behalf of John P. Fitzgerald III. 

71 Motion to File Document(s) Under Seal and Reservation of Rights, with 

Notice of Motion, and with Notice of Hearing, (Related Document(s)56 Sealed 

Document filed by Lynn L. Tavenner, as Chapter 7 Trustee, 69 Sealed 

Document filed by John P. Fitzgerald, 70 Statement filed by John P. 

Fitzgerald) filed by Kathryn R. Montgomery of Office of the United States 

Trustee on behalf of John P. Fitzgerald III. Hearing scheduled for 6/8/2022 at 

01:00 PM at Judge Huennekens' Courtroom, 701 E. Broad St., Rm. 5000, 

Richmond, Virginia. 

72 Motion to Expedite Hearing with Notice and Proposed Order, and with Notice 

of Hearing, (Related Document(s)71 Motion to File Documents(s) Under Seal 

filed by John P. Fitzgerald) filed by Kathryn R. Montgomery of Office of the 

United States Trustee on behalf of John P. Fitzgerald III. Hearing scheduled 

for 6/8/2022 at 01:00 PM at Judge Huennekens' Courtroom, 701 E. Broad St., 

Rm. 5000, Richmond, Virginia. 

73 Sealed Certification/Declaration/Statement(Re: related document(s)56 Sealed 

Document filed by Lynn L. Tavenner, as Chapter 7 Trustee) filed by Erika L. 

Morabito of Quinn Emanuel on behalf of Lynn L. Tavenner, as Chapter 7 

Trustee. (Attachments: # 1 Exhibit 1 # 2 Exhibit 2 # 3 Exhibit 3 # 4 Exhibit 4 

# 5 Exhibit 5 # 6 Exhibit 6 # 7 Exhibit 7 # 8 Exhibit 8 # 9 Exhibit 9 

# 10 Exhibit 10 # 11 Exhibit 11 # 12 Exhibit 12 # 13 Exhibit 13 # 14 Exhibit 

14).

75 Order to Seal Omnibus Settlement Agreement and Related Documents, 

Information, and Hearings.

77 Sealed Answer/Response/Reply(Re: related document(s)56 Sealed Document 

filed by Lynn L. Tavenner, as Chapter 7 Trustee) filed by Erika L. Morabito of 

Quinn Emanuel on behalf of Lynn L. Tavenner, as Chapter 7 Trustee. 

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78 Amended Sealed Exhibit(Re: related document(s)56 Sealed Document filed by 

Lynn L. Tavenner, as Chapter 7 Trustee) filed by Erika L. Morabito of Quinn 

Emanuel on behalf of Lynn L. Tavenner, as Chapter 7 Trustee. 

81 Proposed Stipulation and Order By CVC Capital Partners and Between 

Chapter 7 Trustee (Re: related document(s)19 Motion for Withdrawal of 

Reference (fee) filed by CVC Capital Partners) filed by Michael E. Hastings of 

Woods Rogers PLC on behalf of CVC Capital Partners. 

82 Stipulation and Order (Re: related document(s)19 Motion for Withdrawal of 

Reference (fee) filed by CVC Capital Partners). 

83 Notice of Appeal Re: Oral Ruling on July 14, 2022, of U.S. Bankruptcy Court 

EDVA Granting Motion to Seal Settlement Agreement & Related Documents, 

Information and Hearings [Order Not Entered on Docket] filed by Kathryn R. 

Montgomery of Office of the United States Trustee on behalf of John P. 

Fitzgerald III

84 Exhibit 1 (Transcript of Open Court Hearing on July 14, 2022) (Re: related 

document(s)83 Notice of Appeal filed by John P. Fitzgerald) 

85 Sealed Exhibit (Related Document(s)83 Notice of Appeal filed by John P. 

Fitzgerald) filed by Kathryn R. Montgomery of Office of the United States 

Trustee on behalf of John P. Fitzgerald III 

Respectfully Submitted,

Dated: July 25, 2022 John P. Fitzgerald, III 

 Acting United States Trustee, Region Four 

 By: /s/ Kathryn R. Montgomery 

 Kathryn R. Montgomery (Va. Bar No. 42380) 

 Shannon Pecoraro (Va. Bar No. 46864) 

 Jason B. Shorter (Va. Bar No. 80929) 

 Department of Justice

Office of the United States Trustee

 701 East Broad Street, Suite 4303 

 Richmond, Virginia 23219 

 (804) 771-2310 

 kathryn.montgomery@usdoj.gov 

 shannon.pecoraro@usdoj.gov 

jason.b.shorter@usdoj.gov 

 

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CERTIFICATE OF SERVICE

 I HEREBY CERTIFY that on this 25th day of July, 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 Appellee by counsel, (iii) all other 

interested parties by counsel or registered agent as set forth above, (iv) the 20 largest unsecured 

creditors as listed on the Debtor’s schedules, (v) the Service List as defined by the governing Case 

Management Order, and (vi) all Persons identified in paragraph 4 of the FAO Procedures Order 

(ECF 533), as modified by the Order Modifying Settlement Procedures for FAO Actions (ECF 

929). 

By: /s/ Kathryn R. Montgomery 

 Kathryn R. Montgomery, Esq., AUST 

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