____________________________________

Erika L. Morabito (VSB No. 44369)

Brittany J. Nelson (VSB No. 81734)

QUINN EMANUEL URQUHART & SULLIVAN LLP

1300 I Street, N.W., Suite 900

Washington, DC 20005

(202) 538-8334 (telephone)

Email: erikamorabito@quinnemanuel.com

brittanynelson@quinnemanuel.com

Special Counsel to Lynn L. Tavenner, Chapter 7 Trustee

UNITED STATES BANKRUPTCY COURT

FOR THE EASTERN DISTRICT OF VIRGINIA

(Richmond Division)

In re:

LeClairRyan, PLLC,1

Debtor.

Case No. 19-34574-KRG

Chapter 7

Lynn L. Tavenner, as Chapter 7 Trustee,

Plaintiff,

v.

ULX Partners, LLC, UnitedLex Corporation, 

and ULX Manager LLC,

Defendants.

Adv. Proc. No. 20-03142 (KRH)

Lynn L. Tavenner, as Chapter 7 Trustee,

Plaintiff,

v.

CVC Capital Partners, Daniel Reed, Nicholas

Hinton, Josh Rosenfeld, P. Douglas Benson,

 Defendants.

 Adv. Proc. No. 21-03095 (KRH)

RESERVATION OF RIGHTS REGARDING THE MOTION OF THE UNITED STATES 

TRUSTEE FOR A STATUS CONFERENCE AND SCHEDULING ORDER

Lynn L. Tavenner, Trustee, not individually, but solely in her capacity as the Chapter 7 

trustee (in such capacity, the “Trustee”) of the bankruptcy estate of LeClairRyan PLLC in the 

1 The principal address of the Debtor as of the Petition Date was 4405 Cox Road, Glen Allen, Virginia 23060, and the 

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

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above-referenced Chapter 7 case, by counsel, hereby submits this reservation of rights (the 

“Reservation”) in respect to the Motion of the United States Trustee for A Status Conference and 

Scheduling Order [Dkt No. 1335]

2

(the “Motion”). In support of the Reservation, the Trustee 

respectfully states as follows:

1. On May 23, 2022 (less than 48 hours ago), the United States Trustee filed a very 

short objection to the Trustee’s 9019 Motion (as hereafter defined) [Dkt No. 1333].

2. Then, less than twenty-four (24) hours ago, on May 24, 2022, the Office of the 

United States Trustee (the “United States Trustee”) filed the Motion. The Motion seek a status 

conference and scheduling order related to discovery that the United States Trustee also recently 

served upon the Chapter 7 Trustee on May 23, 2002 (less than 48 hours ago) relating to the Trustee’s 

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 [Dkt No. 1328] (the “9019 Motion”). 

3. Concurrently with the filing of the Motion, the United States Trustee also filed a 

Motion to Expedite Hearing on the Motion of the United States Trustee for a Status Conference and 

Scheduling Order [Dkt No. 1336] (the “Motion to Expedite”). The Motion to Expedite sought a 

hearing (the “Hearing”) on the Motion and the Motion to Expedite on less than 24 hours’ notice. 

4. Prior to the above filings by the United States Trustee, and subsequently thereafter, 

the Trustee has been engaged in discussions with the United States Trustee in a continuing effort to 

better understand and address any concerns of the United States Trustee with respect to the relief 

sought in the 9019 Motion. Indeed, rather than engage in protracted and costly litigation, within 

2

 All docket cites herein are to the pleadings filed in the Main Bankruptcy Case, Case No 19-3457.

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hours after the Motion was filed, counsel for the Trustee reached out to counsel for the United States 

Trustee with a proposal that she believed would resolve the issues raised in the Motion. 

5. To that end, the two parties are scheduled to speak prior to the Hearing on the 

morning of May 25, 2022. The Trustee remains optimistic that the two parties can agree on an 

appropriate path forward such that it can be presented to the Court at the Hearing for consideration.

6. To the extent that the parties are unable to reach a resolution that is satisfactory to 

both parties, the Trustee reserves all rights regarding the Motion and the Motion to Expedite, 

including, but not limited to, the right to present oral arguments at the Hearing regarding the 

Motion and the Motion to Expedite and/or to supplement this Reservation, as appropriate. 

DATED: May 25, 2022 Respectfully submitted,

/s/ Erika L. Morabito

Erika L. Morabito (VSB No. 44369)

Brittany J. Nelson (VSB No. 81734)

QUINN EMANUEL URQUHART & SULLIVAN 

1300 I Street, N.W., Suite 900

Washington, DC 20005

(202) 538-8334 (telephone)

Email: erikamorabito@quinnemanuel.com

brittanynelson@quinnemanuel.com

Special Counsel to Lynn L. Tavenner, Chapter 7 

Trustee

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CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 25th day of May, 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 Defendants, (iii) the 20 largest

unsecured creditors as listed on the Debtor’s schedules, (iv) the Service List as defined by the

governing Case Management Order, (v) Foley & Lardner, (vi) all Persons identified in paragraph

4 of the FAO Procedures Order, and (vii) counsel for the Chapter 7 Trustee

/s/ Erika L. Morabito

Erika L. Morabito

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