Michael E. Hastings, Esq. (VSB No. 36090) 

Woods Rogers PLC 

10 S. Jefferson Street, Suite 1800 

Roanoke, Virginia 24011 

Phone: (540) 983-7568 

Fax: (540) 983-7711 

mhastings@woodsrogers.com

Counsel for Rodney K. Adams, John T. Jessee, 

Paul C. Kuhnel, and Andrew K. Clark 1

UNITED STATES BANKRUPTCY COURT 

EASTERN DISTRICT OF VIRGINIA 

Richmond Division

In re: Case No. 

LeClairRyan PLLC, 19-34574-KRH 

Debtor. Chapter 7 

NOTICE OF MOTION AND HEARING THEREON IF NECESSARY 

PLEASE TAKE NOTICE that Rodney K. Adams, John T. Jessee, Paul C. Kuhnel, and Andrew 

K. Clark (collectively, the “Joiners”), by counsel, filed the following: RODNEY K. ADAMS, 

JOHN T. JESSEE, PAUL C. KUHNEL, AND ANDREW K. CLARK’S JOINDER TO 

GARY D. LECLAIR’S MOTION TO AMEND DEBTOR’S EQUITY SECURITY 

HOLDERS LIST PURSUANT TO BANKRUPTCY RULE 1009(A) (the “Joinder”)[ECF No. 

1237].

PLEASE TAKE FURTHER NOTICE that your rights may be affected. You should 

read the Joinder carefully and discuss it with your attorney if you have one in this chapter 7 

Case. (If you do not have an attorney, you may wish to consult one). 

PLEASE TAKE FURTHER NOTICE that on September 4, 2019, the Court entered the 

Order Establishing Certain Notice, Case Management and Administrative Procedures [ECF. No. 

38] (the “Case Management Order”), which approved the Notice, Case Management, and 

Administrative Procedures attached as Exhibit 1 to the Case Management Order (the “Case 

Management Procedures”). The Case Management Procedures, among other things, prescribe 

the manner in which Objection must be filed and served and set forth when certain hearings will 

be conducted. A copy of the Case Management Order may be obtained, free of charge, by written 

request to pberan@tb-lawfirm.com, or, for a fee, at http://ecf.vaeb.uscourts.gov. 

PLEASE TAKE FURTHER NOTICE if you do not want the Court to grant the relief 

requested in the Joinder, or if you want the Court to consider your views on the Joinder, on or 

before March 22, 2022 (the “Objection Deadline”), you or your attorney must: 

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

to the Joinder pursuant to Rule 9013-1(H) of the Local Rules of the United States 

Bankruptcy Court for the Eastern District of Virginia and the Case Management 

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Procedures. If you mail your written response to the Court for filing, you must mail it early 

enough so the Court will receive it on or before the Objection Deadline. 

If a response is not properly and timely filed and served, the Court may deem any 

opposition waived, treat the Joinder as conceded and enter an appropriate order 

granting the requested relief without further notice or hearing.

Clerk of the Court 

United States Bankruptcy Court 

701 East Broad Street, Suite 4000 

Richmond, VA 23219 

In accordance with the Case Management Procedures, you must also serve a copy of your 

written Objection on the Core Parties, the 2002 List Parties and any Affected Entity so that 

the Objection is received on or before the Objection Deadline. 

PLEASE TAKE FURTHER NOTICE THAT the Court will entertain the Joinder on 

March 29, 2022 at 11:00 a.m. (or such time thereafter as the matter may be heard. REMOTE 

HEARING INFORMATION: Due to the COVID-19 public health emergency, no in-person 

hearing are being held. This hearing will take place remotely through Zoom. To appear at 

the hearing, you must use the following Zoom registration link:

https://www.zoomgov.com/meeting/register/vJItd-GvqDkvH4cmJbXkjNKZZrN-Pfd4nbg 

Listen-only conference line: 

Dial 1-866-590-5055 

Access Code: 4377075 

Security Code: 32922 

PLEASE NOTE: You MUST submit the Zoom Request Form no later than two (2) business days 

prior to this hearing. Any documentary evidence presented at the hearing must be filed with the 

Court in advance of the hearing. PLEASE GOVERN YOURSELVES ACCORDINGLY.

Dated: March 7, 2022 Respectfully submitted, 

RODNEY K. ADAMS, JOHN T. JESSEE, 

PAUL C. KUHNEL, AND ANDREW K. CLARK 

By: /s/ Michael E. Hastings

Of Counsel 

Case 19-34574-KRH Doc 1238 Filed 03/07/22 Entered 03/07/22 15:18:18 Desc Main

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Michael E. Hastings, Esq. (VSB No. 36090) 

Woods Rogers PLC 

10 S. Jefferson Street, Suite 1800 

Roanoke, Virginia 24011 

Phone: (540) 983-7568 

Fax: (540) 983-7711 

mhastings@woodsrogers.com

 

Counsel for the Joiners 

CERTIFICATE OF SERVICE 

I hereby certify that on March 7, 2022, a true and correct copy of the foregoing document 

was filed with the Court through the CM/ECF system which will send notification of such filing 

to all counsel of record. 

 /s/ Michael E. Hastings

Case 19-34574-KRH Doc 1238 Filed 03/07/22 Entered 03/07/22 15:18:18 Desc Main

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