HUNTON ANDREWS KURTH LLP

Riverfront Plaza, East Tower

951 East Byrd Street

Richmond, Virginia 23219

Telephone: (804) 788-8200

Facsimile: (804) 788-8218

Tyler P. Brown (VSB No. 28072)

Jason W. Harbour (VSB No. 68220)

Proposed Counsel to the Debtor

and Debtor in Possession

IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE EASTERN DISTRICT OF VIRGINIA 

RICHMOND DIVISION

In re:

LECLAIRRYAN PLLC,

Debtor.1

Chapter 11

Case No. 19-34574 (KRH)

OMNIBUS MOTION FOR ENTRY OF AN ORDER 

AUTHORIZING LECLAIRRYAN PLLC TO (I) REJECT 

UNEXPIRED LEASES AND (II) ABANDON CERTAIN

PROPERTY IN CONJUNCTION WITH SUCH REJECTION

Bankruptcy Rule 6006 Notice to Unexpired Lease Counter-Parties

Pursuant to Bankruptcy Rule 6006, parties receiving this Motion should locate their 

respective names and leases listed on Exhibit 1 to the attached Proposed Order.

LeClairRyan PLLC, the above-captioned debtor and debtor-in-possession 

(“LeClairRyan” or the “Debtor”), by its undersigned counsel, hereby moves (the “Motion”) the 

Court for entry of an order in substantially the form annexed hereto as Exhibit A (the “Proposed 

Order”), pursuant to sections 105(a), 365(a) and 554(a) of Title 11 of the United States Code, 11 

U.S.C. §§ 101-1532 (as amended, the “Bankruptcy Code”) and Rule 6006 of the Federal Rules 

of Bankruptcy Procedure (the “Bankruptcy Rules”), authorizing the Debtor to (i) reject certain 

 

1 The last four digits of the Debtor’s federal tax identification number are 2451. 

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unexpired leases for non-residential real property listed on Exhibit 1 to the Proposed Order 

(collectively, the “Leases”) effective as of the dates listed in Exhibit 1, and (ii) abandon certain 

personal property and fixtures (collectively, the “Personal Property”) at the premises under the 

Leases. In support of this Motion, the Debtor relies on the Declaration of Lori D. Thompson, 

Esq. in support of Chapter 11 Petition and First Day Motions (the “Thompson Declaration”). In 

further support of this Motion, the Debtor submits as follows:

I. Jurisdiction, Venue and Predicates for Relief

1. The Court has jurisdiction over this matter pursuant to 28 U.S.C. §§ 157 and 28 

U.S.C. § 1334(b). Venue is proper pursuant to 28 U.S.C. §§ 1408 and 1409. This matter is a 

core proceeding within the meaning of 28 U.S.C. §157 (b)(2).

2. The predicates for the relief sought herein are sections 105(a), 365(a) and 554(a) 

of the Bankruptcy Code and Bankruptcy Rule 6006.

II. Background

A. Chapter 11 Cases

3. On the date hereof (the “Petition Date”), the Debtor filed with the Court its 

voluntary petition for relief under chapter 11 of the Bankruptcy Code, commencing the abovecaptioned chapter 11 case (the “Chapter 11 Case”). 

4. The Debtor continues to operate its businesses and manage its property as a 

debtor-in-possession pursuant to sections 1107(a) and 1108 of the Bankruptcy Code. 

5. No creditors’ committee has been appointed in this Chapter 11 Case. No trustee 

or examiner has been appointed.

6. A full description of the Debtor’s business operations, corporate structures, capital 

structures, and reasons for commencing this case is set forth in full in the Thompson Declaration, 

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which was filed contemporaneously with this Motion and which is incorporated herein by 

reference. Additional facts in support of the specific relief sought herein are set forth below.

B. Facts in Support of the Motion

7. The Debtor formerly conducted the practice of law in leased premises in various 

cities in the United States. Each of the Leases the Debtor seeks to reject by this Motion are for 

the leased premises the Debtor no longer is using to practice law. 

8. Prior to the Petition Date, the Debtor began a process for shutting down its 

operations in all of its leased locations. None of the lawyers who practiced with the firm

currently are occupying any of the leased premises. All vacated the offices prior to the Petition 

Date. In addition, the remaining non-lawyer employees of the firm, who continue to work on 

billing and collection matters and the collection and transfer of client files, are now working 

either remotely or from an office leased by a non-debtor entity, as described below.

9. Prior to the Petition Date, the rights and obligations of the firm with respect to 

certain leased premises were transferred to third parties. Specifically, the Debtor worked with 

lawyers who were leaving the firm to have their new firms take over the lease obligations for 

their office locations while working for the Debtor. These include the leased premises associated 

with the Leases for office space in New Haven, Connecticut and Glen Allen, Virginia. Out of an 

abundance of caution, the Debtor is seeking to reject the Leases for those locations as well to the 

extent the Debtor has any remaining rights under those Leases. 

10. Except for eight locations, as of the Petition Date, the Debtor no longer has

Personal Property located within any of the offices covered by the Leases that the Debtor

believes would be beneficial for the Debtor to remove to retain or sell. For the remaining 

Leases, the Debtor still has limited Personal Property that may have value and some client files

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that the firm intends to catalogue and transfer to the appropriate place in consultation with those 

clients. The Debtor, therefore, seeks to reject most of the Leases as of the Petition Date, with the 

remaining eight locations to be rejected effective as of later dates in September 2019, as set forth 

on Exhibit 1 to the Proposed Order.

11. The Debtor intends to conduct its wind-down out of office space leased by ULX 

Partners, LLC (“ULXP”), which is providing administrative support services to assist the 

Debtor’s remaining employees to effectuate the wind-down. Any attorneys who are continuing 

to transfer client matters also are working remotely to do so. Accordingly, the Leases no longer 

provide any benefit to the Debtor’s estate, but impose significant burdens in the form of rent and 

related obligations. 

12. In addition to rejecting the Leases, the Debtor also has determined to abandon any

Personal Property located in the premises covered by the Leases, as of the effective dates of the 

rejections. The Debtor has determined, in the exercise of its good faith business judgment, that 

the Personal Property that the Debtor will leave in the premises has little or no value to its estate

and may impose significant burdens were the Debtor required to remove it. Any Personal 

Property of value has been removed from the premises associated with the Leases to be rejected

as of the Petition Date or will be removed by the dates of the proposed rejection set forth on 

Exhibit 1 to the Proposed Order. 

13. For the avoidance of doubt, the Debtor submits that Personal Property that it seeks 

to abandon herein shall not include client files or technology that holds client data (collectively, 

the “Client Files”) that may be located at the leased premises. The Debtor is taking, and will 

continue to take, appropriate and necessary steps to protect such Client Files and store them 

centrally or return them to the applicable clients as appropriate. 

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III. Relief Requested

14. By this Motion, the Debtor respectfully requests the entry of the Proposed Order 

authorizing the Debtor to (i) reject the Leases listed on Exhibit 1 annexed to the Proposed Order 

effective as of the dates identified in Exhibit 1, and (ii) abandon the Personal Property at the 

premises under the Leases.

IV. Basis for the Relief Requested

A. Rejection of the Leases is Appropriate

15. Section 365(a) of the Bankruptcy Code provides that a debtor-in-possession 

“subject to the court’s approval, may assume or reject any executory contract or unexpired lease 

of the debtor.” 11 U.S.C. § 365(a). “This provision allows a trustee to relieve the bankruptcy 

estate of burdensome agreements which have not been completely performed.” Stewart Title 

Guaranty Co. v. Old Republic Nat’l Title Ins. Co., 83 F.3d 735, 741 (5th Cir. 1996) (citing In re 

Murexco Petroleum, Inc., 15 F.3d 60, 62 (5th Cir. 1994)). 

16. When analyzing a debtor’s decision to reject an executory contract or an 

unexpired lease, courts typically apply a business judgment standard to determine whether to 

approve the proposed rejection. See Nat’l Labor Relations Bd. v. Bildisco & Bildisco (In re

Bildisco), 465 U.S. 513, 523 (1984) (recognizing the “business judgment” standard as the 

traditional test applied to authorize the rejection of executory contracts); Orion Pictures Corp. v. 

Showtime Networks, Inc. (In re Orion Pictures Corp.), 4 F.3d 1095, 1098-99 (2d Cir. 1993); In 

re Federated Dept. Stores, Inc., 131 B.R. 808, 811 (S.D. Ohio 1991) (“Courts traditionally have 

applied the business judgment standard in determining whether to authorize the rejection of 

executory contracts and unexpired leases.”). Rejection of an executory contract or an unexpired 

lease is appropriate where such rejection would benefit the estate. See Orion Pictures Corp., 4 

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F.3d at 2098-99; Sharon Steel Corp. v. National Fuel Gas Distrib. Corp. (In re Sharon Steel 

Corp.), 872 F.2d 36, 40 (3d Cir. 1989); In re HQ Global Holdings, 290 B.R. 507, 511 (Bankr. D. 

Del. 2003); In re Stable News Assoc., Inc., 41 B.R. 594, 596 (Bankr. S.D.N.Y. 1984). 

17. Upon a finding that the debtor has exercised its sound business judgment in 

determining that the assumption or rejection of an agreement is in the best interests of the debtor, 

its creditors and all parties-in-interest, the court should approve the assumption or rejection under 

section 365(a) of the Bankruptcy Code. See, e.g., In re Circuit City Stores, Inc., No. 08-35653, 

2010 Bankr. LEXIS 1713, at *12 (Bankr. E.D. Va. June 9, 2010); Bildisco, 462 U.S. at 523; 

Sharon Steel Corp., 872 F.2d at 39-40; Westbury Real Estate Ventures, Inc. v. Bradlees, Inc. (In 

re Bradlees Stores, Inc.), 194 B.R. 555, 558 n.1 (Bankr. S.D.N.Y. 1996); Summit Land Co. v. 

Allen (In re Summit Land Co.), 13 B.R. 310, 315 (Bankr. D. Utah 1981) (holding that absent 

extraordinary circumstances, court approval of a debtor’s decision to assume or reject an 

executory contract “should be granted as a matter of course”).

18. An integral component of the Debtor’s efforts to maximize value for its estate and 

stakeholders consists of eliminating unnecessary costs and burdensome contracts. The Debtor

has determined, in its good faith business judgment, that the rejection of the Leases is in the best 

interests of its creditors, stakeholders, and estate as there is little benefit and substantial burdens 

to the Debtor related to the Rejected Contracts.

B. Rejection of the Leases Should Be Effective as of the Dates Identified in 

Exhibit 1 Annexed to the Proposed Order

19. The Debtor also respectfully submits that it is appropriate for the Court to order 

that the effective date of rejection of each of the Leases should be the date identified in Exhibit 1 

to the Proposed Order for such Lease, including on the Petition Date for certain of the Leases. 

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20. While section 365 of the Bankruptcy Code does not specifically address the 

Court’s authority to order rejection to be effective immediately, many courts have held that 

bankruptcy courts may, in their discretion, authorize rejection retroactive to a date prior to entry 

of the order authorizing the rejection where the balance of equities weighs in favor of retroactive 

rejection. See, e.g., In re At Home Corp., 392 F.3d 1064, 1065-66 (9th Cir. 2004) (affirming 

bankruptcy court’s approval of retroactive rejection), cert. denied sub nom. Pacific Shores Dev., 

LLC v. At Home Corp., 546 U.S. 814 (2005); In re Thinking Machines Corp., 67 F.3d 1021, 1028 

(1st. Cir. 1995) (holding that “bankruptcy courts may enter retroactive orders of approval, and 

should do so when the balance of equities preponderates in favor of such remediation”); In re 

Chi-Chi’s, Inc., 305 B.R. 396, 399 (Bankr. D. Del. 2004) (holding that when principals of equity 

dictate, a bankruptcy court may approve rejection of nonresidential lease pursuant to section 

365(a) retroactive to the motion filing date); In re CCI Wireless, LLC, 297 B.R. 133, 140 (D. 

Colo. 2003) (holding that “because section 365 does not, as a matter of law, prohibit selection of 

a retroactive date for rejection, the bankruptcy court has authority under section 365(d)(3) to set 

the effective date of rejection at least as early as the filing date of the motion to reject”); In re 

Jamesway Corp., 179 B.R. 33, 36-37 (S.D.N.Y. 1995) (holding that section 365 does not include 

“restrictions as to the manner in which the court can approve rejection”).

21. Here, the balance of the equities favors rejection as requested herein. Without the 

requested relief, the Debtor may be forced to incur unnecessary administrative expenses for the 

Leases that provide little or no tangible benefit to the Debtor’s estate. 

22. The counterparties to the Leases will not be unduly prejudiced if the rejection is 

deemed effective as of the date identified in Exhibit 1 for such Lease because they will receive 

timely notice of this Motion, and, thus, have sufficient opportunity to act accordingly. In fact, 

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the landlords may benefit from such rejection the Debtor expects to have vacated the premises 

under each Lease on or before the rejection date identified in Exhibit 1 for such Lease, thereby 

allowing the landlords to relet the premises. See, e.g., In re Amber’s Stores, Inc., 193 B.R. 819, 

827 (Bankr. N.D. Tex. 1996) (holding that lease at issue should be deemed rejected as of the 

petition date due to equities of case where debtor turned over keys and vacated premises 

prepetition and served motion to reject the lease as soon as possible); In re Federated Dep’t 

Stores, Inc., 131 B.R. 808, 814 (S.D. Ohio 1991) (affirming lower court’s approval of debtor’s 

rejection of real property lease where debtor had closed its retail store and vacated the premises).

23. Courts in this district and others have permitted retroactive rejection when the 

non-debtor party to an executory contract or unexpired lease is given definitive notice of the 

debtor’s intent to reject. See, e.g., In re Morris, Schneider, Wittstadt Va., PLLC, Case No. 15-

33370 (KLP) (Bankr. E.D. Va. July 31, 2015); In re Workflow Mgmt., Inc., No. 10-74617 (SCS) 

(Bankr. E.D. Va. Oct. 29, 2010); In re MMR Holdings, Inc., No. 10-32658 (DOT) (Bankr. E.D. 

Va. June 4, 2010); In re Circuit City Stores, Inc., No. 08-35653 (KRH) (Bankr. E.D. Va. Nov. 

10, 2008); see also In re Visteon Corp., No. 09-11786 (CSS) (Bankr. D. Del. June 23, 2009) 

(authorizing the rejection of leases retroactive to the petition date); In re Sun-Times Media Grp., 

Inc., No. 09-11092 (CSS) (Bankr. D. Del. Apr. 28, 2009) (same); In re Leiner Health Prods., 

Inc., No. 08-10446 (KJC) (Bankr. D. Del. Apr. 7, 2008) (authorizing the rejection of leases 

retroactive to the date the motion was filed); In re Am. Home Mortg. Holdings, Inc., No. 07-

11047 (CSS) (Bankr. D. Del. Sept. 20, 2007) (authorizing the rejection of leases and granting 

retroactive relief requested); In re Loewen Grp. Int’l, Inc., No. 99-1244 (PJW) (Bankr. D. 

Del.Oct. 26, 2000) (authorizing the rejection of leases retroactive to the date the motion was 

filed).

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24. Accordingly, the Debtor submits that it is both fair and equitable for the Court to 

order that the rejection of the Leases be effective as of the dates listed in Exhibit 1 to the 

Proposed Order. 

C. Abandonment of Certain Personal Property

25. Section 554(a) of the Bankruptcy Code provides that “[a]fter notice and a hearing, 

the trustee may abandon any property of the estate that is burdensome to the estate or that is of 

inconsequential value and benefit to the estate.” See 11 U.S.C. § 554(a). Courts generally give 

great deference to a debtor’s decision to abandon property. See, e.g., In re Vel Rey Props., Inc., 

174 B.R. 859, 867 (Bankr. D.D.C. 1994) (“Clearly, the court should give deference to the 

trustee’s judgment in such matters.”). Unless certain property is harmful to the public, once a 

debtor has shown that it is burdensome or of inconsequential value to the estate, a court should 

approve abandonment. Id.

26. The Debtor submits that any Personal Property that remains on the leased 

premises will be of inconsequential value or burdensome to the Debtor’s estates to remove. The 

Debtor believes that the costs of retrieving, marketing and reselling the Personal Property far 

outweigh any recovery the Debtor could hope to attain for the Personal Property, assuming any 

recovery could be had at all. Accordingly, the Debtor has determined that the abandonment of 

the Personal Property left in any leased premises as of the rejection date is in the best interests of 

the Debtor’s estate.

V. Notice

27. The Debtor has served notice of this Motion on (a) the U.S. Trustee; (b) counsel 

to ABL Alliance, LLLP; (c) ULX Partners, LLC; (d) those creditors holding the 20 largest 

unsecured claims against the Debtor’s bankruptcy estate; and (e) each of the landlords under the 

Leases.

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VI. No Prior Request

28. No prior request for the relief requested herein has been made to this or any other 

court.

WHEREFORE, the Debtor respectfully requests that the Court grant the Debtor

the relief requested herein and such other and further relief as the Court deems just and proper.

DATED: September 3, 2019

Respectfully submitted,

/s/ Tyler P. Brown

Tyler P. Brown (VSB No. 28072)

Jason W. Harbour (VSB No. 68220)

HUNTON ANDREWS KURTH LLP

Riverfront Plaza, East Tower

951 East Byrd Street

Richmond, Virginia 23219

Telephone: (804) 788-8200

Facsimile: (804) 788-8218

Email: tpbrown@HuntonAK.com

jharbour@HuntonAK.com

Proposed Counsel to the Debtor 

and Debtor in Possession

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EXHIBIT A

PROPOSED ORDER

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HUNTON ANDREWS KURTH LLP

Riverfront Plaza, East Tower

951 East Byrd Street

Richmond, Virginia 23219

Telephone: (804) 788-8200

Facsimile: (804) 788-8218

Tyler P. Brown (VSB No. 28072)

Jason W. Harbour (VSB No. 68220)

Proposed Counsel to the Debtor

and Debtor in Possession

IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE EASTERN DISTRICT OF VIRGINIA 

RICHMOND DIVISION

In re:

LECLAIRRYAN PLLC,

Debtor.1

Chapter 11

Case No. 19-[ ] (___)

ORDER AUTHORIZING LECLAIRRYAN PLLC

TO (I) REJECT UNEXPIRED LEASES AND (II) ABANDON CERTAIN

PROPERTY IN CONJUNCTION WITH SUCH REJECTION

Upon the motion (the “Motion”)2of LeClairRyan PLLC, the above-captioned debtor and 

debtor-in-possession (“LeClairRyan” or the “Debtor”) for entry of an order, pursuant to sections 

105(a), 365(a) and 554(a) of the Bankruptcy Code and Rule 6006 of the Bankruptcy Rules for 

entry of an order authorizing the Debtor to (i) reject the unexpired leases for non-residential real 

property (collectively, the “Leases”) listed on Exhibit 1 annexed hereto effective as of the dates 

listed in Exhibit 1, and (ii) abandon personal property and fixtures at the premises (collectively, 

the “Personal Property”) under the Leases; the Court finds that: (a) it has jurisdiction to consider 

the Motion and the relief requested therein pursuant to 28 U.S.C. §§ 157 and 1334; (b) this is a 

 

1 The last four digits of the Debtor’s federal tax identification number are 2451. 

2

 Unless otherwise defined herein, each capitalized term shall have the meaning ascribed to it in the Motion.

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core proceeding pursuant to 28 U.S.C. § 157(b); (c) venue is proper before this court pursuant to 

28 U.S.C. §§ 1408 and 1409; (d) the relief requested in the Motion is in the best interests of the 

Debtor, its estates and creditors; (e) the Debtor has exercised its business judgment in 

determining to reject the Leases and abandon the Personal Property; (f) the Personal Property is 

of inconsequential value or would be burdensome to the Debtor’s estate to remove; (g) proper 

and adequate notice of the Motion and the hearing thereon has been given and no other or further 

notice is necessary; and (h) upon the record herein, and after due deliberation thereon, good and 

sufficient cause exists for the granting of the relief as set forth herein. Therefore,

IT IS HEREBY ORDERED THAT:

1. The Motion is GRANTED.

2. The Debtor hereby is authorized to reject the Leases, which rejection shall be 

deemed effective as of the date identified in Exhibit 1 annexed hereto for such Lease.

3. The Debtor hereby is authorized in its discretion to abandon the Personal 

Property, if any, on the premises under the Leases as of the rejection dates set forth on Exhibit 1; 

provided, however, the Debtor is not abandoning client files or technology that holds client data 

(collectively, the “Client Files”) that the may be located at the premises under the Leases. 

4. Any counterparty to a Lease to the extent it elects to file a rejection damages 

claim, if any, relating to the rejection of a Lease, shall file such claim by the claims bar date 

established in the Debtor’s chapter 11 case.

5. Nothing herein shall prejudice the right of the Debtor to object to the allowance or 

classification of any claim for damages arising from the rejection of the Lease.

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6. Notwithstanding any Bankruptcy Rule or Local Bankruptcy Rule that might 

otherwise delay the effectiveness of this Order, the terms and conditions of this Order shall be 

immediately effective and enforceable upon its entry.

7. This Court retains jurisdiction with respect to all matters arising from or related to 

the implementation of this Order.

8. The requirement under Local Bankruptcy Rule 9013-1(G) to file a memorandum 

of law in connection with the Motion is hereby waived. 

9. The Debtor is authorized and empowered to take all actions necessary to 

implement the relief requested in this Order.

______________, 2019

UNITED STATES BANKRUPTCY JUDGE

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WE ASK FOR THIS:

/s/ Tyler P. Brown

Tyler P. Brown (VSB No. 28072)

Jason W. Harbour (VSB No. 68220)

HUNTON ANDREWS KURTH LLP

Riverfront Plaza, East Tower 

951 East Byrd Street

Richmond, VA 23219

Tel: (804) 788-8200

Fax: (804) 788-8218

Email: tpbrown@HuntonAK.com

jharbour@HuntonAK.com

Proposed Counsel to the Debtor

and Debtor in Possession

CERTIFICATION OF ENDORSEMENT

UNDER LOCAL BANKRUPTCY RULE 9022-1(C)

I hereby certify that the foregoing proposed order has been endorsed by or served 

upon all necessary parties.

/s/ Tyler P. Brown

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EXHIBIT 1

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Landlord Lease Location Lease Term Rejection Date

1. Landlord:

11th & Cochran, LC

c/o Hunter E. Craig Co.

P.O. Box 5509

Charlottesville, Virginia 22905

123 E. Main Street 

Charlottesville, Virginia 22902

March 31, 2020 Petition Date

2. Landlord:

Baltic Providence, LLC

2180 Mendon Road, Suite 11

Cumberland, Rhode Island 02864

400 Westminster Street

Providence, Rhode Island 02903

December 31, 2019 Petition Date

3. Landlord:

BPP Connecticut Avenue LLC

c/o Transwestern,

815 Connecticut Avenue N.W., Suite 300

Washington, D.C. 20006

Attn: Property Manager

Copy To:

BPP Connecticut Avenue, LLC

c/o Equity Office Management, L.L.C.

222 South Riverside Plaza, Suite 2000

Chicago, Illinois 60606

Attn: Managing Counsel and Lease Admin

815 Connecticut Avenue, NW

Washington, D.C. 20006

December 31, 2024 Petition Date

4. Landlord:

Carlyle Overlook Owner, LLC

c/o Principal Real Estate Investors, LLC

711 High Street,

Des Moines, Iowa 50392-1370

Attn: Shawn Leisinger & Shannon G. Holz

Copy To:

The Holmberg Law Offices, P.C.

4118 Leonard Drive, Suite 200

Fairfax, Virginia 22030

Attn: Eric B. Holmberg, Esq.

2318 Mill Road 

Alexandria, Virginia 22314

October 31, 2027 September 5, 2019

5. Landlord:

Dominion Tower Financial Associates, LLC

999 Waterside Drive, Suite 2300

Norfolk, Virginia 23510

Dominion Tower

999 Waterside Drive

Norfolk, Virginia 23510

May 31, 2021 Petition Date

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Landlord Lease Location Lease Term Rejection Date

6. Landlord:

EYP Realty, LLC

c/o Brookfield Properties Management LLC

725 S. Figueroa Street, Suite 1850

Los Angeles, California 90017

Attn: General Manager

Copy To:

Brookfield Properties Management LLC

601 S. Figueroa Street, Suite 2200

Los Angeles, California 90017

Attn: VP, Regional Counsel

725 S. Figueroa Street

Los Angeles, California 90017

December 31, 2022 Petition Date

7. Landlord:

Faison-Roanoke Office Limited Partnership, 

et al., 

c/o Faison & Associates, LLC

121 West Trade Street, 27th Floor

Charlotte, North Carolina 28202

Copy To:

Stephen W. Lemon, Esq.

Martin Hopkins and Lemon, PC

P.O. Box 13366

Roanoke, Virginia 24033

1800 Wells Fargo Tower

Roanoke, Virginia 24006

December 31, 2020 Petition Date

8. Landlord:

Ford Motor Land Development Corporation

3300 Town Center Drive, Suite 1100

Dearborn, Michigan 48126

Attn: Sales and Leasing Department 

290 Town Center Drive

Dearborn, Michigan 48126

March 31, 2022 Petition Date

9. Landlord:

Hines Sacramento Wells Fargo Center LP

c/o Property Manager

400 Capitol Mall, Suite 670

Sacramento, California 95814

400 Capital Mall

Sacramento, California 95814

October 31, 2023 September 5, 2019

10. Landlord:

Latham & Watkins LLP

12636 High Bluff Drive

San Diego, California 92130

Attn: Chief Real Estate & Facilities Officer

Copy To:

Latham & Watkins LLP

885 Third Avenue,

New York, New York 10022

885 Third Avenue

New York, New York 10022

June 23, 2021 September 5, 2019

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Landlord Lease Location Lease Term Rejection Date

11. Landlord:

LSOP 3C III, LLC

c/o Cushman & Wakefield of MD, Inc.

500 East Pratt Street, Suite 500

Baltimore, Maryland 21202

180 Admiral Cochran Drive

Annapolis, Maryland 21401

March 31, 2026 Petition Date

12. Landlord:

MA-60 State Associates, L.L.C.

c/o Oxford Properties Group

125 Summer Street

Boston, Massachusetts 02110

Attn: Director of Legal

Copy To:

Nutter, McLennen & Fish, LLP

Seaport West

155 Seaport Boulevard

Boston, Massachusetts 02210

Attn: Timothy M. Smith, Esq.

60 State Street

Boston, Massachusetts 02109

December 31, 2028 Petition Date

13. Landlord:

Matrix One Riverfront Plaza, LLC

c/o Matric Realty, Inc.

CN 4000

Cranbury, New Jersey 08512

Attn: Joseph S. Taylor

Copy To:

Drinker Biddle Reath LLP

500 Campus Drive

Florham Park, New Jersey 07932

Attn: Michael E. Rothpletz, Jr., Esq.

1037 Raymond Blvd.

Newark, New Jersey 07102

November 30, 2021 September 20, 2019

14. Landlord:

New Boston Long Wharf, LLC

c/o New Boston Fund, Inc.

75 State Street, Suite 1410

Boston, Massachusetts 02109-1803

Copy To:

Rappaport, Aserkoff & Gelles

75 State Street, Suite 1410

Boston, Massachusetts 02109-1803

New Boston Management Services, Inc.

60 State Street, Suite 1500

Boston, Massachusetts 02109-1803

New Boston Management Services, Inc.

545 Long Wharf Drive

New Haven, Connecticut 06511

December 31, 2021 Petition Date

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Landlord Lease Location Lease Term Rejection Date

175 Capital Boulevard, Suite 200

Rocky Hill, Connecticut 06067

CB Richard Ellis – New England Partners, LP

33 Arch Street, 28th Floor

Boston, Massachusetts 02210

Attn: Property Management Accounting

15. Landlord:

Parmenter 919 Main Street, LP, LLLP

c/o Parmenter Realty Partners

919 East Main Street, Suite 100

Richmond, Virginia 23219

Attn: Property Manager

Copy To:

Parmenter 919 Main Street, LP, LLLP

c/o Parmenter Realty Partners

3399 Peachtree Road, NE, Suite 0150

Atlanta, Georgia 30326

Attn: Asset Manager

Parmenter 919 Main Street, LP, LLLP

c/o Parmenter Realty Partners

701 Brickell Avenue, Suite 2020

Miami, Florida 33131

Attn: Andrew Weiss

SunTrust Center

919 East Main Street

Richmond, Virginia 23219 

January 31, 2026 September 20, 2019

16. Landlord:

Post Oak Realty Investment Partners, LP

13355 Noel Road, 22nd Floor

Dallas, Texas 75240

Attn: President

Copy To:

TPMC Realty Corporation

1233 West Loop South, Suite 1230

Houston, Texas 77027

Attn: Steven M. Seltzer

Park Towers Investment, LLC

c/o Regent Properties

12100 Wilshire Boulevard, Suite 1750

Los Angeles, California 90025

Attention: Eric Fleiss

1233 West Loop South

Houston, Texas 77027

October 31, 2020 Petition Date

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Landlord Lease Location Lease Term Rejection Date

17. Landlord:

Quest Workspaces 515 N. Flagler LLC

515 N. Flagler Drive

West Palm Beach, Florida 33401

515 N. Flagler Drive

West Palm Beach, Florida 

33401

September 30, 2019 Petition Date

18. Landlord:

Regional Headquarters, Inc.

4201 Dominion Blvd., Suite 300

Glen Allen, Virginia 23060

4201 Dominion Blvd.

Glen Allen, Virginia 23060

July 31, 2021 Petition Date

19. Landlord:

Regus Management Group, LLC

P.O. Box 842456

Dallas, Texas 72584

Copy To:

Philadelphia.onelibertyplace@regus.com

Regus PLC

26 Boulevard Royal

L-2449 Luxembourg

Luxembourg

1650 Market Street, Suite 3800

Philadelphia, Pennsylvania 

19103 

October 31, 2019 September 5, 2019

20. Landlord:

Regus Management Group, LLC

P.O. Box 842456

Dallas, Texas 72584

Copy To:

Chicago.westjackson@regus.com

Regus PLC

26 Boulevard Royal

L-2449 Luxembourg

Luxembourg

111 West Jackson Blvd.

Chicago, Illinois 60604 

January 31, 2020 Petition Date

21. Landlord:

Regus Management Group, LLC

P.O. Box 842456

Dallas, Texas 72584

Copy To:

Dallas.leepark@regus.com

3333 Lee Parkway

Dallas, Texas 75219 

October 31, 2019 Petition Date

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6

Landlord Lease Location Lease Term Rejection Date

Zulema.gonzalez@iwgplc.com

Regus PLC

26 Boulevard Royal

L-2449 Luxembourg

Luxembourg

22. Landlord:

STRS Ohio,

275 Broad Street,

Columbus, Ohio 43215-3771

Attn: Director of Real Estate

44 Montgomery Street

San Francisco, California 94104

September 30, 2005 September 15, 2019

23. Landlord:

Talcott II Gold, LLC

One Financial Plaza

Hartford, Connecticut 06103

755 Main Street

Hartford, Connecticut 06103

August 31, 2022 September 5, 2019

045890.0000005 EMF_US 76040097v8

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