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) 

Henry P. (Toby) Long, III (VSB No. 75134) 

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) 

PROPOSED AGENDA FOR HEARING 

ON SEPTEMBER 26, 2019, AT 2:00 P.M. (PREVAILING EASTERN TIME) 

I. ADJOURNED MATTERS 

1. “Cash Management” – Motion of LeClairRyan PLLC for Entry of an Order 

(I) Authorizing the Debtor to Maintain Existing Bank Accounts and Business 

Forms and Continue to Use Existing Cash Management System and (II) 

Waiving the Requirements of Section 345(b) of the Bankruptcy Code

[ECF No. 7] 

Related Documents: 

(a) Interim Order (I) Authorizing Debtor to Maintain Existing Bank 

Accounts and Business Forms and Continue to Use Existing Cash 

Management System and (II) Waiving the Requirements of Section 

345(b) of the Bankruptcy Code [ECF No. 40] 

Response Deadline: September 19, 2019.

Responses: None at the time of this filing. 

 

1

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

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Status: This matter is adjourned to the hearing scheduled before this Court on 

October 24, 2019, at 1:00 p.m. (prevailing Eastern Time), and the response 

deadline is continued to October 17, 2019. 

2. “Receivables Motion” – Motion of LeClairRyan PLLC for Entry of Interim 

and Final Orders Approving Settlement Procedures for Compromising 

Accounts Receivable and Related Relief [ECF No. 8] 

Related Documents: 

(a) Sealed Exhibit [ECF No. 10] 

(b) 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 for Compromising 

Accounts Receivable and Related Relief [ECF No. 42] 

(c) Interim Order Approving Settlement Procedures for Compromising 

Accounts Receivable and Related Relief, and Scheduling a Final 

Hearing [ECF No. 51] 

Response Deadline: September 19, 2019.

Responses: None at the time of this filing. 

Status: This matter is adjourned to the hearing scheduled before this Court on 

October 24, 2019, at 1:00 p.m. (prevailing Eastern Time), and the response 

deadline is continued to October 17, 2019. 

3. “Wages Motion” – Motion of LeClairRyan PLLC for Entry of Interim and 

Final Orders (I) Authorizing Debtor to Pay Prepetition Wages and Salaries; 

and (II) Directing Applicable Financial Institutions to Honor and Process 

Related Checks and Transfers [ECF No. 11] 

Related Documents: 

(a) Interim Order (I) Authorizing LeClairRyan PLLC to Pay 

Prepetition Wages and Salaries; (II) Directing Applicable 

Financial Institutions to Honor and Process Related Checks and 

Transfers; and (III) Granting Related Relief [ECF No. 43] 

Response Deadline: September 19, 2019.

Responses: None at the time of this filing. 

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Status: This matter is adjourned to the hearing scheduled before this Court on 

October 24, 2019, at 1:00 p.m. (prevailing Eastern Time), and the response 

deadline is continued to October 17, 2019. 

4. “Assumption Motion” – Omnibus Motion of LeClairRyan PLLC for Entry of 

Interim and Final Orders Authorizing the Debtor to Assume Certain 

Executory Contracts [ECF No. 12] 

Related Documents: 

(a) Interim Order Authorizing LeClairRyan PLLC to Assume Certain 

Executory Contracts [ECF No. 52] 

Response Deadline: September 19, 2019.

Responses: 

(b) Objection of Super-Server, LLC to Motion by Debtor to Assume 

Executory Contracts [ECF No. 88] 

Status: This matter is adjourned to the hearing scheduled before this Court on 

October 24, 2019 at 1:00 p.m. (prevailing Eastern Time), and the response 

deadline is continued to October 17, 2019. 

II. UNCONTESTED MATTERS 

5. “First Lease Rejection Motion” – 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 [ECF No. 18] 

Related Documents: 

(a) Notice of Revised Proposed Orders [ECF No. 102] 

Response Deadline: September 19, 2019.

Responses: None at the time of this filing. 

Status: This matter is going forward. The Debtor will submit a proposed 

order to reflect informal comments received. 

6. “Second Lease Rejection Motion” – Second 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 [ECF No. 69] 

Related Documents: None at the time of this filing. 

Response Deadline: September 23, 2019.

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Responses: None at the time of this filing. 

Status: This matter is going forward. 

7. “Hunton Retention Application” – 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 [ECF No. 66] 

Related Documents: 

(a) Supplemental Declaraction 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 LeClairyRyan PLLC Effective as of the 

Petition Date [ECF No. 104] 

(b) Notice of Revised Proposed Orders [ECF No. 102] 

Response Deadline: September 23, 2019. 

Responses: None at the time of this filing. 

Status: This matter is going forward. The Debtor will submit a proposed 

order to reflect informal comments received. 

8. “Protiviti Retention Application” – Application of LeClairRyan PLLC for 

Entry of an Order Authorizing the Employment and Retention of Protiviti Inc. 

and Financial Advisor for LeClairRyan PLLC Effective as of the Petition Date

[ECF No. 67] 

Related Documents: 

(a) Supplemental Declaraction 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. and 

Financial Advisor for LeClairRyan PLLC Effective as of the 

Petition Date [ECF No. 103] 

(b) Notice of Revised Proposed Orders [ECF No. 102] 

Response Deadline: September 23, 2019. 

Responses: None at the time of this filing. 

Status: This matter is going forward. The Debtor will submit a proposed 

order to reflect informal comments received. 

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9. “ALCS Appointment Motion” – Motion of LeClairRyan PLLC for Entry of 

an Order Appointing American Legal Claim Services, LLC as Claims, 

Noticing, and Balloting Agent [ECF No. 68] 

Related Documents:

(a) Notice of Revised Proposed Orders [ECF No. 102] 

Response Deadline: September 23, 2019.

Responses: None at the time of this filing. 

Status: This matter is going forward. The Debtor will submit a proposed 

order to reflect informal comments received. 

III. CONTESTED MATTERS 

10. “Client File Disposition Motion” – Motion of LeClairRyan PLLC for 

Approval of Client File Disposition Procedures [ECF No. 70] 

Related Documents: 

(a) Notice of Revised Proposed Orders [ECF No. 102] 

Response Deadline: September 23, 2019.

Responses: 

(b) Objection of Super-Server, LLC to Motion by Debtor for Approval 

of Client File Disposition Procedures [ECF No. 95] 

(c) iManage, LLC’s Limited Objection to Motion of LeClairRyan 

PLLC for Approval of Client File Disposition Procedures

[ECF No. 97] 

Status: This matter is going forward. The Debtor will submit a proposed 

order to reflect informal comments received. 

11. “Expense Motion” – Motion for Entry of an Order Authorizing and Directing 

Payment of Client Expense Reimbursements [ECF No. 71] 

Related Documents:

(a) Notice of Revised Proposed Orders [ECF No. 102] 

Response Deadline: September 23, 2019. 

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Responses: 

(a) Limited Objection of ABL Alliance, LLLP to Motion for Entry of 

an Order Authorizing and Directing Payment of Client Expense 

Reimbursements [ECF No. 100] 

Status: This matter is going forward. The Debtor will submit a proposed 

order to reflect informal comments received. 

12. “Cash Collateral” – 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 [ECF No. 13] 

Related Documents: 

(a) 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 [ECF No. 14] 

(b) Interim Order Authorizing LeClairRyan PLLC to Use Cash 

Collateral, Granting Adequate Protection and Related Relief, and 

Scheduling and Final Hearing [ECF No. 41] 

Response Deadline: September 19, 2019.

Responses: 

(c) Objection of Super-Server, LLC to Motion to Use Cash Collateral

[ECF No. 89] 

(d) iManage, LLC’s Joinder with Objection of Super-Server LLC to 

Debtor’s Motion to Use Cash Collateral [ECF No. 98] 

Status: This matter is going forward. 

13. “Convert to Chapter 7” – United States Trustee Motion to Convert Case to 

Chapter 7 [ECF No. 61] 

Related Documents: 

(a) Joinder of Michele Craddock in the United States Trustee Motion 

to Convert Case to Chapter 7 [ECF No. 82] 

(b) Joinder of Super-Server, LLC in Motion to Convert Case Filed by 

U.S. Trustee [ECF No. 90] 

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(c) Statement of ABL Alliance, LLLP in Support of Motion of United 

States Trustee to Convert Case to Chapter 7 [ECF No. 99] 

Response Deadline: September 23, 2019.

Responses: 

(d) Response of LeClairRyan PLLC to United States Trustee Motion to 

Convert Case to Chapter 7 [ECF No. 101] 

Status: This matter is going forward. 

DATED: September 24, 2019 

/s/ Henry P. (Toby) Long, III 

Tyler P. Brown (VSB No. 28072) 

Jason W. Harbour (VSB No. 68220) 

Henry P. (Toby) Long, III (VSB No. 75134) 

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 

hlong@HuntonAK.com 

Proposed Counsel to the Debtor 

and Debtor in Possession 

045890.0000006 EMF_US 76570312v4 

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