Paula S. Beran, Esquire (Va. Bar No. 34679)

Tavenner & Beran, PLC 

20 North Eighth Street, Second Floor

Richmond, Virginia 23219

Telephone: (804) 783-8300

Telecopy: (804) 783-0178

Counsel for Lynn L. Tavenner, Chapter 7 Trustee

UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

Richmond Division

In re: Case No.

LeClairRyan, PLLC,1 19-34574-KRH

Debtor Chapter 7

TRUSTEE’S MOTION FOR AN ORDER AUTHORIZING

THE EXECUTION OF NOTICES OF PROPOSED ADJUSTMENTS

AND MEMORANDUM IN SUPPORT THEREOF

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

7 trustee (in such capacity, the “Chapter 7 Trustee” and/or the “Trustee”) of the bankruptcy 

estate (the “Estate”) of LeClairRyan PLLC (“LeClairRyan” and/or the “Debtor”) hereby by and 

through her undersigned counsel, pursuant to §§ 105 and 363(b) of the United States Code, 11 

U.S.C. §§ 101—1532 (as hereafter amended, the “Bankruptcy Code”), and Rule 6004 of the 

Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules,” and each individually a 

“Bankruptcy Rule”) moves for the entry of an order authorizing the execution and delivery of (1) 

IRS Forms 5701, Notices of Proposed Adjustments (“Forms 5701”) as further described herein 

and attached hereto as Exhibit A and (2) all other documents necessary to conclude a certain audit 

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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conducted by the Internal Revenue Service (together with the Forms 5701, the “Audit Forms”) 

and,in support thereof, respectfully represents as follows:

JURISDICTION

1. The United States Bankruptcy Court for the Eastern District of Virginia (the 

“Court”) has jurisdiction over this matter pursuant to 28 U.S.C. §§ 157 and 1334 and the Standing 

Order of Reference from the United States District Court for the Eastern District of Virginia, dated 

August 15, 1984.

2. This is a core proceeding pursuant to 28 U.S.C. § 157(b)(2).

3. Venue is proper pursuant to 28 U.S.C. §§ 1408 and 1409.

BACKGROUND

4. On September 3, 2019 (the “Petition Date”), the Debtor filed for relief under 

Chapter 11 of Title 11 of the United States Code, 11 U.S.C. §§ 101-1532 (the “Bankruptcy 

Code”). Pursuant to §§ 1007 and 1108 of the Bankruptcy Code, the Debtor operated as a debtorin-possession.

5. Per agreement between the Debtor, the United States Trustee, and ABL Alliance, 

LLLP (the “Lender”), the Debtor’s bankruptcy case was converted to a case (the “Case”) under 

Chapter 7 of the Bankruptcy Code on October 4, 2019 (the “Conversion Date”).

6. Upon conversion, Lynn L. Tavenner was appointed interim trustee, and no trustee 

having been elected at the meeting of creditors, she continues to serve as trustee.

7. Upon conversion, the Trustee became custodian of the Debtor’s books and records 

and asserted control over all made available to her as of the Conversion Date. In addition, the 

Trustee filed her Motion for Immediate Authority to Operate Certain Aspects of Debtor’s Business 

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for a Limited Period and to Shorten Notice Thereof, and Memorandum in Support Thereof (the 

“Operation Motion”), ECF No. 144, and pursuant to numerous Orders of this Court, the Trustee 

has been provided authority to operate certain aspects of the Debtor’s business for a limited period 

of time (the “721 Operations”).

Pre-Petition Corporate Conversion

8. Prior to March 2018, the Debtor operated as a Virginia professional corporation. 

Thereafter, upon the Debtor’s filing of Articles of Conversion, the State Corporation Commission

of Virginia issued a Certificate of Entity Conversion, effective March 4, 2018 (the “Corporate

Transition”).

9. The Corporate Transition prompted the filing of a federal tax return with the 

Internal Revenue Service (“IRS”) for the portion of the calendar tax year that pre-dated the 

Corporate Transition for the period ending March 4, 2018 (the “2018 Short Year Return”).

10. Upon information and belief, prior to the Petition Date, the IRS had advised the 

Debtor of its intent to audit the Debtor’s 2018 Short Year Return (the “2018 IRS Audit”) yet the 

Trustee was neither informed of nor provided information about the 2018 IRS Audit by any 

representative of the Debtor. Shortly after the Conversion Date, the IRS contacted the Trustee to 

begin work in earnest on the 2018 IRS Audit. The Trustee, directly and through her professionals, 

of course cooperated with the IRS in connection with said audit. 

11. The Trustee, with the assistance of her professionals and wind-down team, 

attempted to locate all information requested by the IRS in conjunction with the 2018 IRS Audit. 

The Trustee provided certain information to the IRS. Unfortunately, notwithstanding an extensive 

amount of diligence, the Trustee was unable to locate in the Debtor’s books and records a majority 

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of the information that the IRS maintained was necessary to support aspects of the 2018 Short 

Year Return. As a result, the Trustee contacted, directly and through her professionals, former 

officers and directors of the Debtor, as well as the Debtor’s former accountant who had assisted in 

the preparation of the 2018 Short Year Return, to obtain insight as to the basis for 

information/amounts contained in the 2018 Short Year Return. Based upon those communications 

with the former officers and directors, as well as the Debtor’s former accountant who had assisted 

in the preparation of the 2018 Short Year Return, the Trustee understood there was a substantial 

amount of back up to support the figures used on the return, including those relating to adjustments

for and/or devaluation of accounts receivable, and the same should have been contained within the 

Debtor’s books and records. Once again, notwithstanding an extensive amount of additional 

diligence, the Trustee, with the assistance of her professionals and wind-down team, was unable 

to locate in the Debtor’s books and records a majority of the information that the IRS maintained 

was necessary to support aspects of the 2018 Short Year Return. Based upon communications with 

former officers and directors, the Trustee also understood that the supporting documentation could 

be explained by, and likely located through, a certain former employee of the Debtor and/or ULXP. 

The Trustee contacted, directly and through her wind-down team, said individual who, albeit 

extremely professional and desired to assist, could neither explain nor point to documents to 

support the extensive adjustment for and/or devaluation of accounts receivable contained in the 

2018 Short Year Return. As a result, the Trustee was unable to provide to the IRS the complete 

documentation it maintained was required to support aspects of the Debtor’s 2018 Short Year 

Return.

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12. In connection with finalizing the 2018 IRS Audit, the IRS has requested that the 

Trustee execute the Forms 5701. And based on discussions with the Estate’s accountant, the 

Trustee, in the exercise of her business judgment, maintains that it is in the best interest of the 

Estate to execute the Forms 5701 and otherwise facilitate the conclusion of the 2018 IRS Audit. 

RELIEF REQUESTED

13. By this Motion (the “Motion”), pursuant to §§ 105 and 363(b) of the United States 

Code, the Trustee seeks the entry of an order that would authorize and approve the Trustee’s 

(and/or her approved professional’s) execution of the Audit Forms. 

14. The relief sought in this Motion is authorized by §§ 105 and 363 of the Bankruptcy 

Code and provides the Trustee with the authority to comply with such IRS actions, which will 

positively impact the amount of the IRS proofs of claims in this Case. Specifically, without the 

execution of the Audit Forms, the Trustee understands that the IRS will completely disallow 

certain items in the 2018 Short Year Return, which could result in millions of additional dollars in 

priority claims to the detriment of other creditors and the Estate. Therefore, this relief is in the 

best interest of the Estate and its creditors.

15. The Trustee hereby requests the entry of an order pursuant to §§ 105 and 363(b) 

of the Bankruptcy Code authorizing the Trustee, directly and/or through her professionals, to 

execute the Audit Forms such that the 2018 IRS Audit can be concluded in the manner that is 

most favorable to the Estate based on the current facts and circumstances. Of course, if any 

additional information becomes available to the Trustee, she will forward the same forthwith to 

the appropriate IRS agent/auditor. 

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LEGAL AUTHORITY

16. Section 363(b) of the Bankruptcy Code provides that a trustee “after notice and a 

hearing, may use, sell or lease, other than in the ordinary course of business, property of the estate.” 

11 U.S.C. § 363(b)(1). 

17. To approve a use, sale, or lease of property other than in the ordinary course of 

business, the court must find “some articulated business justification.” See, e.g., In re Martin 

(Myers v. Martin), 91 F.3d 389, 395 (3d Cir. 1996) (citing Fulton State Bank v. Schipper (In re 

Schipper), 933 F.2d 513, 515 (7th Cir. 1991)); Comm. of Equity SEC Holders v. Lionel Corp. (In 

re Lionel Corp), 722 F.2d 1063, 1070 (2d Cir. 1983); WBQ P’ship v. Virginia (In re WBQ P’ship),

189 B.R. 97, 102 (Bankr. E.D. Va. 1995).

18. While, arguably the execution and delivery of the Audit Forms is in the ordinary

course of the Trustee’s 721 Operations and/or within her purview as a fiduciary, the Trustee 

believes it appropriate to seek independent Court authority for said actions. The Trustee 

respectfully submits that the execution and delivery of the Audit Forms is supported by sound 

business justification. The Trustee maintains that the same will assist in the preservation of the 

value of the Estate’s assets for creditors by reducing the amount of priority claim that ultimately 

could result from the 2018 IRS Audit and eliminating costly claim litigation to which the Trustee, 

notwithstanding an extreme amount of diligence, has been unable to locate documentation to 

support certain amounts asserted on the Debtor’s 2018 Short Year Return. Moreover, given the 

efforts of the Trustee and her professionals and agents to date with respect to the same, the Trustee 

believes that based upon the information currently available, the proposed course of action will 

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result in ultimate savings to the Estate when contrasted with the prospect of the additional liability 

that will be claimed by the IRS without such executed Audit Forms.

19. Also, pursuant to § 105 of the Bankruptcy Code, the Court has expansive equitable 

powers to fashion any order or decree which is in the interest of preserving or protecting the value 

of a debtor’s assets. See, e.g., In re Chinichian, 784 F.2d 1440, 1443 (9th Cir. 1986), which is 

promoted by the authority requested in this Motion.

NOTICE

20. Notice of this Motion has been provided by U.S. Mail, postage prepaid, email, or 

by ECF notice to (a) the Office of the United States Trustee; (b) the Debtor’s 20 Largest Unsecured 

Creditors; (c) all known secured creditors from the Debtor’s Official Form 106D; (d) the Core 

Parties and 2002 List as defined in the Case Management Order; and (e) all parties requesting 

service of pleadings in this Case (as indicated on the Schedule A attached to the Court filed copy 

of said Motion). The Trustee submits that no other or further notice need be given.

NO PRIOR RELIEF

21. No prior request for the relief sought herein has been made to this Court or any 

other court.

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WHEREFORE, the Trustee respectfully requests that the Court (a) enter an Order, 

substantially in the form attached hereto as Exhibit B (a) approving the Motion and authorizing 

the Trustee and/or her professionals to execute and delivery the Audit Forms; and (b) granting 

such other and further relief as the Court may deem proper.

Respectfully submitted,

LYNN L. TAVENNER, CHAPTER 7 TRUSTEE

Dated: June 10, 2021

Richmond, Virginia

By: /s/ Paula S. Beran

Paula S. Beran, Esquire (VSB No. 34679)

PBeran@TB-LawFirm.com

Tavenner & Beran, PLC

20 North 8th Street

Richmond, Virginia 23219

Telephone: (804) 783-8300

Telecopier: (804) 783-0178

Counsel for Lynn L. Tavenner, Chapter 7 Trustee

CERTIFICATE OF SERVICE

I certify that on this 10th day of June 2021, a true copy of the foregoing Motion was sent 

electronically to: (a) the Office of the United States Trustee; (b) the Debtor’s 20 Largest Unsecured 

Creditors; (c) all known secured creditors from the Debtor’s Official Form 106D; (d) the Core 

Parties and 2002 List as defined in the Case Management Order; and (e) all parties requesting 

service of pleadings in this Case (as indicated on the Schedule A attached to the Court filed copy 

of said Motion).

/s/ Paula S. Beran

Paula S. Beran, Esquire

Counsel for Lynn L. Tavenner, Chapter 7 Trustee

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Form 5701 

(April 2019) 

Name of taxpayer 

LECLAIRRY AN PLLC 

Name and title of person to whom delivered 

Strickland, Barry CPA 

Entity for this proposed adjustment 

LECLAIRRYAN PLLC 

Department of the Treasury - Internal Revenue Se1Vice 

Notice of Proposed Adjustment 

Issue Number 

1 

Date 

Response Due 

Based on the information we now have available and our discussions with you, we believe the proposed adjustment listed below should be 

included in the revenue agent's report. However, if you have additional information that would alter or reverse this proposal, please 

furnish this information as soon as possible. 

Years 

201803 

Amount Account or return line 

$207,538.00 /IRS Form 1120/Line 26/0ther Deductions 

SAIN Number UIL Code 

526-22 00274.01-00 

Reasons for Proposed Adjustment (If the explanation cl the adjustmert Wilf be tonger than the space provided belON, the entire explanation stoufd tegin on Form 886-A (Explanation of ffems.). 

Taxpayer's / Representative's Action: 

D Agreed D Agreed in Part D Disagreed 

Taxpayer's / Representative's Signature 

D Have additional information; will submit by: 

If Disagreed in Part or in Full - Check here for consideration of Fast Track Settlement 

D Taxpayer D IRS 

Team Manager 

Date 

Cat. No. 42770J www.irs.gov Form 5701 (Rev. 4-2019) 

Part 1 - Taxpayer's File Copy 

14J 

EXHIBIT A

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Form 886-A I

Department of the Treasury - Internal Revenue Service 

(May 2017) Explanation of Items 

Name of taxpayer I

Tax Identification Number (last 4 digits) 

LECLAIRRY AN PLLC 2451 

Item Being Adjusted: Other Deductions - Meals and Entertanrment 

SAIN Number: 526-22 

Amount per Return 

Amount per Exam 

Adjustment 

ISSUE: 

201803 

$ 25,042,018 

24,834,480 

$ 207,538 

Whether the taxpayer was allowed to deduct entertainment expenses? 

FACTS: 

Schedule number or exhibit 

Form 5701 No. 001 

Year/Period ended 

201803 

LeClairRyan, A Professional Corp. and Subsidiaries (LCR), filed a final tax return on 201803 before 

converting to a partnership. The 201803 return was examined. Upon review of the G L accounts and tax 

returns, it was discovered that LCR had fully deducted GL accounts 91100 Potential Client EntertainmentEntertainment for $4,000 and 91530 Legal Network Involvement-Entertainment for $203,538. There was 

no M-3 adjustment made for these accounts. The examiner determined that the accounts were not 

deductible under the changes to IRC 27 4 made by the Tax Cuts and Jobs Act and therefore an adjustment 

was required. 

LCR is in bankruptcy proceedings. The examiner has worked with the Trustee and the Court Appointed 

Accountant who was the Power of Attorney as authorized by the Trustee. 

LAW: 

Catalog Number2081 OW Page 1 www.irs.gov Form 886-A (Rev. 5-2017) 

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Form 886-A I

Department of the Treasury - Internal Revenue Service Schedule number or exhibit 

(May 2017) Explanation of Items Form 5701 No. 001 

Name of taxpayer I Tax Identification Number (last 4 digits) Year/Period ended 

LECLAIRRY AN PLLC 2451 201803 

Internal Revenue Code Section (IRC) 274 provides a disallowance of certain entertainment, etc., expenses. 

(a) Entertainment, amusement, or recreation, or qualified transportation fringes.

(1) In general. No deduction otherwise allowable under this chapter [IRC Sections 1 et seq.] shall be allowed

for any item-

(A) Activity. With respect to an activity which is of a type generally considered to constitute entertainment,

amusement, or recreation, or 

(B) Facility. With respect to a facility used in connection with an activity referred to in subparagraph (A). 

TAXPAYER'S POSITION: 

The Trustee has indicated that they agree with the proposed adjustment. 

GOVERNMENT'S POSITION: 

It is the government's position that the above adjustment should be made under IRC Section 274 in order 

to correctly reflect taxable income. 

Catalog Number2081 OW Page 2 www.irs.gov Form 886-A (Rev. 5-2017) 

[ 14)

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O

Form 5701 

(April 2019) 

Name of taxpayer 

LECLAIRRYAN PLLC 

Name and title of person to whom delivered 

Strickland, Barry CPA 

Entity for this proposed adjustment 

LECLAIRRYAN PLLC 

Department of the Treasury- Internal Revenue Service 

Notice of Proposed Adjustment 

Issue Number 

2 

Date 

Response Due 

Based on the information we now have available and our discussions with you, we believe the proposed adjustment listed below should be 

included in the revenue agent's report. However, if you have additional information that would alter or reverse this proposal, please 

furnish this information as soon as possible. 

Years 

201803 

Amount Account or return line 

$12,768,766.00 /IRS Form 1120/Line 26/Other Deductions 

SAIN Number UIL Code 

515 00166.02-00 

Reasons for Proposed Adjustment �f ti>, exptanatk,n cl the adjustmert will be lcv,gerthan the space provided bekJN, the entire exptanauon should begin on Form 886-A (Explanation of llems). 

Issue: NR adjustment to FMV 

Item Being Adjusted: Other Deductions - NR adjustment to FMV 

See Attached Form 886-A for details. 

Taxpayer's / Representative's Action: 

D Agreed D Agreed in Part D Disagreed 

Taxpayer's/ Representative's Signature 

D Have additional information; will submit by: 

If Disagreed in Part or in Full - Check here for consideration of Fast Track Settlement 

D Taxpayer D IRS 

Team Manager 

Date 

Cat. No. 42770J 

Part 1 - Taxpayer's File Copy 

www.irs.gov Form 5701 (Rev. 4-2019) 

[ '4]

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Form 886-A I

Department of the Treasury - Internal Revenue Service 

(May 2017) Explanation of Items 

Name of taxpayer I Tax Identification Number (last 4 digits) 

LECLAIRRY AN PLLC 2451 

Item Being Adjusted: Other Deductions - A/R adjustment to FMV 

SAIN Number: 515.01 

Amount per Return 

Amount per Exam 

Adjustment 

ISSUE: 

$ 

$ 

201803 

20,666,097 

7,897,331 

12,768,766 

Whether LeClairRyan met the requirements to write-down accounts receivable? 

FACTS: 

Schedule number or exhibit 

Form 5701 No. 002 

Year/Period ended 

201803 

LeClairRyan, a Professional Corporation (LCR) converted to a Professional Limited Liability Company during 

2018. The 201803 tax return for LeClairRyan, A Professional Coporation was examined. At the time of 

examination, the company had declared bankruptcy and was under the control of a Trustee. The court appointed 

accountant was granted Power of Attorney by the Trustee. The examiner worked with the accountant. 

LCR wrote down the accounts receivable account on the 201803 return. The write-down was noted as 

FMV Write-down to Accounts Receivable in the amount of$20,666,097. The POA and Trustee worked 

with the tax preparer and former employees of LCR and were unable to get support for the calculation of 

the FMV write-down. LCR was able to provide support showing that $7,297,301 was subsequently written 

off as uncollectible by the successor PLLC. The examiner and manager deemed this to be adequate support 

for that portion of the write down for A/R. Due to lack of substantiation, the examiner proposed an 

adjustment of $12,768,766 for the remaining amount of the FMV write-down. 

LAW: 

Catalog Number2081 OW Page 1 www.irs.gov Form 886-A (Rev. 5-2017) 

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Form 886-A I

Department of the Treasury - Internal Revenue Service Schedule number or exhibit 

(lvlay 201 7J Explanation of Items Form 5701 No. 002 

Name of taxpayer I

Tax Identification Number (last 4 digits) Year/Period ended 

LECLAIRRY AN PLLC 2451 201803 

Under IRC Section 336(a), generally except as otherwise provided in this section or section 337, gain or loss 

shall be recognized to a liquidating corporation on the distribution of property in complete liquidation as if 

such property were sold to the distributee at its fair market value. 

Under IRC Section 515 generally: 

(1) Wholly worthless debts

There shall be allowed as a deduction any debt which becomes worthless within the taxable year. 

(2) Partially worthless debts

When satisfied that a debt is recoverable only in part, the Secretary may allow such debt, in an amount not 

in excess of the part charged off within the taxable year, as a deduction. 

TAXPAYER'S POSITION: 

The Trustee has indicated that they are in agreement with the proposed adjustment. 

GOVERNMENT'S POSITION: 

It is the government's position that the above adjustments should be made under IRC Sections 336 and 515 

in order to correctly reflect taxable income. 

Catalog Number2081 OW Page 2 www.irs.gov Form 886-A (Rev. 5-2017) 

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EXHIBIT B

Paula S. Beran, Esquire (Va. Bar No. 34679)

Tavenner & Beran, PLC 

20 North Eighth Street, Second Floor

Richmond, Virginia 23219

Telephone: (804) 783-8300

Telecopy: (804) 783-0178

Counsel for Lynn L. Tavenner, Chapter 7 Trustee

UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

Richmond Division

In re: Case No.

LeClairRyan, PLLC,1 19-34574-KRH

Debtor Chapter 7

ORDER AUTHORIZING THE EXECUTION OF NOTICES OF PROPOSED 

ADJUSTMENTS AND MEMORANDUM IN SUPPORT THEREOF

This matter coming before the Court on the Trustee’s Motion for an Order Authorizing the 

Execution of Notices of Proposed Adjustments and Memorandum In Support Thereof (the “Motion”)2

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

trustee (in such capacity, the “Chapter 7 Trustee” and/or the “Trustee”) of the bankruptcy estate (the 

“Estate”) of LeClairRyan PLLC (“LeClairRyan” and/or the “Debtor”) seeking, inter alia, (a) 

authorization for and approval of the execution of IRS Forms 5701, Notices of Proposed Adjustments 

(“Forms 5701”), as well all other documents necessary to facilitate the conclusion of a certain audit 

conducted by the Internal Revenue Service (together with the Forms 5701, the “Audit Forms”); and 

(b) other and further relief as the Court may deem proper; and upon consideration of the Motion, the 

Court having reviewed the Motion and having heard the statements of counsel in support of the relief 

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.

2 Capitalized terms not otherwise defined herein have the meanings given to them in the Motion.

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requested in the Motion at a hearing before the Court (the “Hearing”); the Court finding that (a) the 

Court has jurisdiction over this matter pursuant to 28 U.S.C. §§ 157 and 1334; (b) this is a core 

proceeding pursuant to 28 U.S.C. § 157(b)(2); (c) venue is proper before this Court pursuant to 28 

U.S.C. §§ 1408 and 1409; and (d) notice of the Motion (and service of the proposed order) was 

sufficient under the circumstances; and the Court having determined that the legal and factual bases 

set forth in the Motion and at the Hearing establish just cause for the relief herein granted.

NOW, THEREFORE, it is ORDERED, that:

1. The Motion is GRANTED.

2. The Trustee, directly and/or through her professionals, is authorized to execute and 

deliver, as appropriate, any and all Audit Forms. 

3. This Court retains jurisdiction to (a) enforce and implement the terms and provisions 

of the Audit Forms and (b) interpret, implement, and enforce the provisions of this Order.

4. As permitted by Bankruptcy Rule 6004(h), notwithstanding Bankruptcy Rule 7062, 

this Order shall be effective and enforceable immediately upon entry.

5. Upon entry, the Clerk shall forthwith provide a copy of this Order to counsel for the 

Trustee, who shall serve (by electronic delivery, first class mail, postage prepaid or overnight delivery) 

copies of this Order on: the Office of the United States Trustee.

ENTERED:

UNITED STATES BANKRUPTCY JUDGE

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I ask for this:

/s/

Paula S. Beran, Esquire (VSB No. 34679)

PBeran@TB-LawFirm.com

Tavenner & Beran, PLC

20 North 8th Street, Second Floor

Richmond, Virginia 23219

Telephone: (804) 783-8300

Facsimile: (804) 783-0178

Counsel for Lynn L. Tavenner, Chapter 7 Trustee

Seen and No Objection

/s/ 

Shannon F. Pecoraro, Esquire

Office of the U.S. Trustee

701 East Broad Street, Suite 4304

Richmond, VA 23219

Trial Attorney

CERTIFICATION

I hereby certify that, pursuant to Local Rule 9022-1, the foregoing proposed Order has either 

been endorsed by and/or served upon all necessary parties.

Counsel

Service List for Entered Order

Paula S. Beran, Esquire

Tavenner & Beran, PLC

20 North 8th Street, Second Floor

Richmond, Virginia 23219

Shannon F. Pecoraro, Esquire

Department of Justice

Office of the United States Trustee

701 East Broad Street, Suite 4304

Richmond, Virginia 23219

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