William A. Broscious. (Va. Bar No. 27436)

KEPLEY BROSCIOUS & BIGGS, PLC 

2211 Pump Road 

Richmond, Virginia 23233 

(804) 741-0400 x202 

 Counsel to Roy M. Terry, Jr., Trustee 

UNITED STATES BANKRUPTCY COURT 

EASTERN DISTRICT OF VIRGINIA 

Richmond Division 

In re: ) Chapter 7 

) 

CELLCON GROUP, INC., ) Case No. 17-36015-KLP 

) 

Debtor. ) 

NOTICE OF HEARING ON TRUSTEE’S MOTION FOR ORDER 

AUTHORIZING BANKRUPTCY RULE 2004 EXAMINATIONS 

PLEASE TAKE NOTICE that on August 21, 2018, Roy M. Terry, Jr., Trustee (the 

“Trustee”), in the Chapter 7 bankruptcy case of CellCon Group, Inc. (the “Debtor”), filed the 

attached motion (the “Rule 2004 Motion”) for an order authorizing and directing discovery by 

the Trustee of certain third parties identified in the Rule 2004 Motion (the “Rule 2004 Order”): 

Your rights may be affected. You should read the Rule 2004 Motion carefully and 

discuss it with your attorney if you have one in this Bankruptcy Case. (If you do not have 

an attorney, you may wish to consult one.) 

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If you do not want the Court to grant the relief sought in the Rule 2004 Motion, or if you 

want the Court to consider your views on the Rule 2004 Motion, then you or your attorney must: 

1. File with the Court, either electronically or at the address shown below, a written 

objection or other response pursuant to Local Bankruptcy Rule 2004-1(B). If you mail your 

objection or response to the Court for filing, you must mail it early enough so the Court will 

receive it on or before August 28, 2018 (seven business days following service date per Local 

Rule 2004-1(B)). 

 William C. Redden, Clerk, 

United States Bankruptcy Court 

 701 East Main Street, Suite 4000 

 Richmond, Virginia 23219-1888 

2. You must also deliver a copy to: 

William A. Broscious, Esquire 

Kepley Broscious & Biggs, PLC 

2211 Pump Road 

Richmond, Virginia 23233 

Robert B. Van Arsdale, Esquire 

Shannon Pecoraro, Esquire 

Office of the U. S. Trustee 

701 East Broad Street - Suite 4304 

Richmond, Virginia 23219 

 

If you or your attorney do not take these steps, the Trustee will submit the Rule 2004 

Order to the Court and the Court may deem any opposition waived, treat the Rule 2004 Motion 

as conceded, and enter the Rule 2004 Order or such other order granting the relief requested 

without further notice or hearing. 

3. Attend a hearing to be scheduled at a later date and time, if necessary. In the 

event of a timely filed objection or other response to the Rule 2004 Motion, the Trustee will 

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obtain a hearing date before the Court and a notice of such hearing shall be filed and served in 

accordance with applicable law and rules.

Dated: Richmond, Virginia 

 August 21, 2018 

ROY M. TERRY, JR., TRUSTEE 

 

 

 By: /s/ William A. Broscious 

 Counsel 

William A. Broscious, Esquire (VSB #27436) 

KEPLEY BROSCIOUS & BIGGS, PLC 

2211 Pump Road 

Richmond, Virginia 23233 

Tel: 804.741.0400 x202 

wbroscious@kbbplc.com

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CERTIFICATE OF SERVICE 

I hereby certify that on August 21, 2018, a true and correct copy of the foregoing was 

served on all persons receiving electronic notice in these cases, and on each of the following by 

the first-class mail:

Office of the U.S. Trustee: Robert B. Van Arsdale, Esquire 

Shannon Pecoraro, Esquire 

OFFICE OF THE U. S. TRUSTEE 

701 East Broad Street - Suite 4304 

Richmond, Virginia 23219 

 

Debtor: CellCon Group, Inc. 

 8401 Patterson Ave. 

 Suite 205 

 Henrico, Virginia 23229-6430 

Counsel for the Debtor: Jeanne E. Hovenden, Esquire 

 Jeanne E. Hovenden, P.L.L.C. 

 9830 Lori Road 

 P.O. Box 1839 

 Chesterfield, Virginia 23832 

 

Rule 2004 Parties: Jimmy Lee and River City Recovery, LLC 

2500 Austin Ave. 

Richmond, Virginia 23223

 Andy Duke and Duke Management Services, Inc. 

3420 Pump Road #215 

Henrico, Virginia 23233 

 

/s/ William A. Broscious 

Counsel

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