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. 19-34574-KRH

LeClairRyan, PLLC,1

Debtor Chapter 7

PROPOSED AGENDA FOR HEARING ON

OCTOBER 19, 2021, AT 11:00 A.M. (PREVAILING EASTERN TIME)

Set forth below are the matters scheduled to be heard before the Honorable Kevin R. 

Huennekens, United States Bankruptcy Judge, in Room 5000, United States Courthouse, 701 East 

Broad Street, Richmond, Virginia 23219, on October 19, 2021, beginning at 11:00 a.m. via Zoom:

Zoom registration link:

https://www.zoomgov.com/meeting/register/vJIsf-6qrzovHiJ1W7B-eUJQ9KiLth0YamQ

Listen-only conference line:

Dial: 1-866-590-5055

Access Code: 4377075

Security Code: 101921

I. MATTERS IN ADVERSARY PROCEEDING NO. 20-03142 (UNITEDLEX

CORPORATION et al). 

1. Adversary Proceeding No. 20-03142 (UnitedLex Corporation et al) – Motion to Dismiss 

Adversary Proceeding / Partially Dismiss the First Amended Complaint (Re: related 

document(s)86 Amended Complaint filed by Lynn L. Tavenner, as Chapter 7 Trustee) 

filed by Thomas John McKee Jr. of Greenberg Traurig on behalf of ULX Manager LLC, 

ULX Partners, LLC, UnitedLex Corporation. (Attachments: # 1 Proposed Order) 

(McKee, Thomas) [ECF No. 87]

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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2

Related documents: 

a. Amended Complaint against ULX Manager LLC, Gary LeClair, ULX Partners, 

LLC, UnitedLex Corporation (Re: related document(s)1 Complaint filed by Lynn 

L. Tavenner, as Chapter 7 Trustee) filed by Erika L. Morabito of Quinn Emanuel 

on behalf of Lynn L. Tavenner, as Chapter 7 Trustee. (Attachments: # 1 Exhibit 1 

# 2Exhibit 2 # 3 Exhibit 3 # 4 Exhibit 4 # 5 Exhibit 5) (Morabito, Erika) [ECF 

No. 86]

b. Reply to Trustee's Omnibus Opposition Brief (Re: related document(s)[87] 

Motion to Dismiss Adversary Proceeding filed by ULX Partners, LLC, UnitedLex 

Corporation, ULX Manager LLC) filed by Thomas John McKee Jr. of Greenberg

Traurig on behalf of ULX Manager LLC, ULX Partners, LLC, UnitedLex 

Corporation. (McKee, Thomas) [ECF No. 109]

Response Deadline: October 12, 2021

Responses Filed: Omnibus Opposition Brief to the Motions to Dismiss the First 

Amended Complaint Filed by ULX Partners, LLC, ULX 

Manager, UnitedLex Corp., and Gary LeClair(Re: related 

document(s)87 Motion to Dismiss Adversary Proceeding filed 

by ULX Partners, LLC, UnitedLex Corporation, ULX 

Manager LLC, 104 Motion to Dismiss Pleading filed by Gary 

LeClair) filed by Erika L. Morabito of Quinn Emanuel on 

behalf of Lynn L. Tavenner, as Chapter 7 Trustee. 

(Attachments: # 1 Exhibit 1) (Morabito, Erika) [ECF No 105]

Status: The Trustee will request that the Court deny the Defendants’

Motion to Dismiss.

2. Adversary Proceeding No. 20-03142 (UnitedLex Corporation et al) – Motion to Dismiss 

Pleading (Re: related document(s)86 Amended Complaint filed by Lynn L. Tavenner, as 

Chapter 7 Trustee) filed by Andrew M. Bowman of Gentry Locke on behalf of Gary 

LeClair. (Bowman, Andrew) [ECF No. 104]

Related documents: 

a. Amended Complaint against ULX Manager LLC, Gary LeClair, ULX Partners, 

LLC, UnitedLex Corporation (Re: related document(s)1 Complaint filed by Lynn 

L. Tavenner, as Chapter 7 Trustee) filed by Erika L. Morabito of Quinn Emanuel 

on behalf of Lynn L. Tavenner, as Chapter 7 Trustee. (Attachments: # 1 Exhibit 1 

# 2Exhibit 2 # 3 Exhibit 3 # 4 Exhibit 4 # 5 Exhibit 5) (Morabito, Erika) [ECF 

No. 86]

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b. Defendant's Reply to Trustee's Opposition Brief (Re: related document(s)[104] 

Motion to Dismiss Pleading filed by Gary LeClair) filed by Andrew M. Bowman 

of Gentry Locke on behalf of Gary LeClair. (Attachments: # (1) Exhibit(s) 1) 

(Bowman, Andrew) [ECF No. 108]

Response Deadline: October 12, 2021

Responses Filed: Omnibus Opposition Brief to the Motions to Dismiss the First 

Amended Complaint Filed by ULX Partners, LLC, ULX 

Manager, UnitedLex Corp., and Gary LeClair(Re: related 

document(s)87 Motion to Dismiss Adversary Proceeding filed 

by ULX Partners, LLC, UnitedLex Corporation, ULX 

Manager LLC, 104 Motion to Dismiss Pleading filed by Gary 

LeClair) filed by Erika L. Morabito of Quinn Emanuel on 

behalf of Lynn L. Tavenner, as Chapter 7 Trustee. 

(Attachments: # 1 Exhibit 1) (Morabito, Erika) [ECF No 105]

Status: The Trustee will request that the Court deny the Defendant’s 

Motion to Dismiss.

II. MATTERS IN OTHER ADVERSARY PROCEEDINGS 

3. Adversary Proceeding No. 21-03069 (Bowerman) – Motion to Consolidate Lead Case 20-

cv-03142 with 21-cv-03069 filed by Diana Lyn Curtis McGraw of Fox Rothschild LLP on 

behalf of Richard W. Bowerman. (Attachments: # 1 Proposed Order) (McGraw, Diana 

Lyn) [ECF No. 5]

Related documents: 

a. Motion to Expedite Hearing (Related Document(s)5 Motion to Consolidate filed 

by Richard W. Bowerman) filed by Diana Lyn Curtis McGraw of Fox Rothschild 

LLP on behalf of Richard W. Bowerman. (McGraw, Diana Lyn) [ECF No. 6]

b. Notice of Hearing (Re: related document(s)5 Motion to Consolidate filed by 

Richard W. Bowerman, 6 Motion to Expedite Hearing filed by Richard W. 

Bowerman) filed by Diana Lyn Curtis McGraw of Fox Rothschild LLP on behalf 

of Richard W. Bowerman. Hearing scheduled for 10/19/2021 at 11:00 AM at 

Judge Huennekens' Courtroom, 701 E. Broad St., Rm. 5000, Richmond, Virginia. 

(McGraw, Diana Lyn) [ECF No. 7]

c. Adversary case 21-03069. Complaint against Richard W. Bowerman filed by 

Lynn L. Tavenner, as Chapter 7 Trustee. Nature of Suit: (13 (Recovery of 

money/property - 548 fraudulent transfer)), (02 (Other (e.g., other actions that 

would have been brought in state court if unrelated to bankruptcy))) Associated 

Bankruptcy Case Number: 3:19-bk-34574 (Nelson, Brittany) ECF No. 1]

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d. Adversary Proceeding No. 20-03142 (UnitedLex Corporation et. al.) – Amended 

Complaint against ULX Manager LLC, Gary LeClair, ULX Partners, LLC, 

UnitedLex Corporation (Re: related document(s)1 Complaint filed by Lynn L. 

Tavenner, as Chapter 7 Trustee) filed by Erika L. Morabito of Quinn Emanuel on 

behalf of Lynn L. Tavenner, as Chapter 7 Trustee. (Attachments: # 1 Exhibit 1 

# 2Exhibit 2 # 3 Exhibit 3 # 4 Exhibit 4 # 5 Exhibit 5) (Morabito, Erika) [ECF 

No. 86]

Response Deadline:

The Movant unilaterally set a response deadline for 11:00 am on 

October 18, 2021. The Trustee maintains that the Movant has 

misapplied a local rule of this Court, which provides “A hearing 

may not be set by a party on less than 14 days’ notice unless the 

Court grants a motion requesting an expedited hearing pursuant 

to paragraph (N) of this Local Bankruptcy Rule. If a hearing is set 

on an expedited basis, the opposing party may file a response, 

with a supporting memorandum, not later than 1 day before the 

date of the hearing or as otherwise directed by the Court.” This 

Court has not yet granted the request for an expedited hearing. 

Nonetheless, the Trustee, through counsel, is working on a 

response which she intends to file on October18, 2021. 

Responses Filed: None as of the filing of this agenda, but the Trustee intends on 

filing a response. 

Status: The Trustee will request that the Court deny the Motion.

4. Adversary Proceeding No. 21-03070 (Lange) - Motion to Consolidate Lead Case 20-cv03142 with 21-cv-03070 filed by Diana Lyn Curtis McGraw of Fox Rothschild LLP on 

behalf of Christopher J. Lange. (Attachments: # 1 Proposed Order) (McGraw, Diana Lyn)

[ECF No. 5]

Related documents: 

a. Motion to Expedite Hearing (Related Document(s)5 Motion to Consolidate filed 

by Christopher J. Lange) filed by Diana Lyn Curtis McGraw of Fox Rothschild 

LLP on behalf of Christopher J. Lange. (McGraw, Diana Lyn) [ECF No. 6]

b. Notice of Hearing (Re: related document(s)5 Motion to Consolidate filed by 

Christopher J. Lange, 6 Motion to Expedite Hearing filed by Christopher J. 

Lange) filed by Diana Lyn Curtis McGraw of Fox Rothschild LLP on behalf of 

Christopher J. Lange. Hearing scheduled for 10/19/2021 at 11:00 AM at Judge 

Huennekens' Courtroom, 701 E. Broad St., Rm. 5000, Richmond, Virginia. 

(McGraw, Diana Lyn) [ECF No. 7]

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c. Adversary case 21-03070. Complaint against Christopher J. Lange filed by Lynn 

L. Tavenner, as Chapter 7 Trustee. Nature of Suit: (13 (Recovery of 

money/property - 548 fraudulent transfer)), (02 (Other (e.g., other actions that 

would have been brought in state court if unrelated to bankruptcy))) Associated 

Bankruptcy Case Number: 3:19-bk-34574 (Nelson, Brittany) [ECF No. 1]

d. Adversary Proceeding No. 20-03142 (ULX Partners, LLC, UnitedLex 

Corporation) – Amended Complaint against ULX Manager LLC, Gary LeClair, 

ULX Partners, LLC, UnitedLex Corporation (Re: related document(s)1 Complaint 

filed by Lynn L. Tavenner, as Chapter 7 Trustee) filed by Erika L. Morabito of 

Quinn Emanuel on behalf of Lynn L. Tavenner, as Chapter 7 Trustee. 

(Attachments: # 1 Exhibit 1 # 2Exhibit 2 # 3 Exhibit 3 # 4 Exhibit 4 # 5 Exhibit 5) 

(Morabito, Erika) [ECF No. 86]

Response Deadline:

The Movant unilaterally set a response deadline for 11:00 am on 

October 18, 2021. The Trustee maintains that the Movant has 

misapplied a local rule of this Court, which provides “A hearing 

may not be set by a party on less than 14 days’ notice unless the 

Court grants a motion requesting an expedited hearing pursuant 

to paragraph (N) of this Local Bankruptcy Rule. If a hearing is set 

on an expedited basis, the opposing party may file a response, 

with a supporting memorandum, not later than 1 day before the 

date of the hearing or as otherwise directed by the Court.” This 

Court has not yet granted the request for an expedited hearing. 

Nonetheless, the Trustee, through counsel, is working on a 

response which she intends to file on October18, 2021.

Responses Filed: None as of the filing of this agenda, but the Trustee intends on 

filing a response. 

Status: The Trustee will request that the Court deny the Motion.

5. Adversary Proceeding No. 21-03071(Zappia) – Motion to Consolidate Lead Case 20-cv03142 with 21-cv-03071 filed by Diana Lyn Curtis McGraw of Fox Rothschild LLP on 

behalf of Andrew Zappia. (Attachments: # 1Proposed Order) (McGraw, Diana Lyn) [ECF 

No. 5]

Related documents: 

a. Motion to Expedite Hearing (Related Document(s)5 Motion to Consolidate filed 

by Andrew Zappia) filed by Diana Lyn Curtis McGraw of Fox Rothschild LLP on 

behalf of Andrew Zappia. (McGraw, Diana Lyn) [ECF No. 6]

b. Notice of Hearing (Re: related document(s)5 Motion to Consolidate filed by 

Andrew Zappia, 6 Motion to Expedite Hearing filed by Andrew Zappia) filed by 

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Diana Lyn Curtis McGraw of Fox Rothschild LLP on behalf of Andrew Zappia. 

Hearing scheduled for 10/19/2021 at 11:00 AM at Judge Huennekens' Courtroom, 

701 E. Broad St., Rm. 5000, Richmond, Virginia. (McGraw, Diana Lyn) [ECF 

No. 7]

c. Adversary case 21-03071. Complaint against Andrew Zappia filed by Lynn L. 

Tavenner, as Chapter 7 Trustee. Nature of Suit: (13 (Recovery of money/property 

- 548 fraudulent transfer)), (02 (Other (e.g., other actions that would have been 

brought in state court if unrelated to bankruptcy))) Associated Bankruptcy Case 

Number: 3:19-bk-34574 (Nelson, Brittany) [ECF No. 1]

d. Adversary Proceeding No. 20-03142 (ULX Partners, LLC, UnitedLex 

Corporation) – Amended Complaint against ULX Manager LLC, Gary LeClair, 

ULX Partners, LLC, UnitedLex Corporation (Re: related document(s)1 Complaint 

filed by Lynn L. Tavenner, as Chapter 7 Trustee) filed by Erika L. Morabito of 

Quinn Emanuel on behalf of Lynn L. Tavenner, as Chapter 7 Trustee. 

(Attachments: # 1 Exhibit 1 # 2Exhibit 2 # 3 Exhibit 3 # 4 Exhibit 4 # 5 Exhibit 5) 

(Morabito, Erika) [ECF No. 86]

Response Deadline:

The Movant unilaterally set a response deadline for 11:00 am on 

October 18, 2021. The Trustee maintains that the Movant has 

misapplied a local rule of this Court, which provides “A hearing 

may not be set by a party on less than 14 days’ notice unless the 

Court grants a motion requesting an expedited hearing pursuant 

to paragraph (N) of this Local Bankruptcy Rule. If a hearing is set 

on an expedited basis, the opposing party may file a response, 

with a supporting memorandum, not later than 1 day before the 

date of the hearing or as otherwise directed by the Court.” This 

Court has not yet granted the request for an expedited hearing. 

Nonetheless, the Trustee, through counsel, is working on a 

response which she intends to file on October18, 2021.

Responses Filed: None as of the filing of this agenda, but the Trustee intends on 

filing a response. 

Status: The Trustee will request that the Court deny the Motion.

6. Adversary Proceeding No. 21-03078 (Burleigh) – Motion to Consolidate Lead Case 20-

cv-03142 with 21-cv-03078 filed by Diana Lyn Curtis McGraw of Fox Rothschild LLP on 

behalf of Paul Burleigh. (Attachments: # 1Proposed Order) (McGraw, Diana Lyn) [ECF 

No. 5]

Related documents: 

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a. Motion to Expedite Hearing (Related Document(s)5 Motion to Consolidate filed 

by Paul Burleigh) filed by Diana Lyn Curtis McGraw of Fox Rothschild LLP on 

behalf of Paul Burleigh. (McGraw, Diana Lyn) [ECF No. 6]

b. Notice of Hearing (Re: related document(s)5 Motion to Consolidate filed by Paul 

Burleigh, 6 Motion to Expedite Hearing filed by Paul Burleigh) filed by Diana 

Lyn Curtis McGraw of Fox Rothschild LLP on behalf of Paul Burleigh. Hearing 

scheduled for 10/19/2021 at 11:00 AM at Judge Huennekens' Courtroom, 701 E. 

Broad St., Rm. 5000, Richmond, Virginia. (McGraw, Diana Lyn) [ECF No. 7]

c. Adversary case 21-03078. Complaint against Paul Burleigh filed by Lynn L. 

Tavenner, as Chapter 7 Trustee. Nature of Suit: (13 (Recovery of money/property 

- 548 fraudulent transfer)), (02 (Other (e.g., other actions that would have been 

brought in state court if unrelated to bankruptcy))) Associated Bankruptcy Case 

Number: 3:19-bk-34574 (Nelson, Brittany) [ECF No. 1]

d. Adversary Proceeding No. 20-03142 (ULX Partners, LLC, UnitedLex 

Corporation) – Amended Complaint against ULX Manager LLC, Gary LeClair, 

ULX Partners, LLC, UnitedLex Corporation (Re: related document(s)1 Complaint 

filed by Lynn L. Tavenner, as Chapter 7 Trustee) filed by Erika L. Morabito of 

Quinn Emanuel on behalf of Lynn L. Tavenner, as Chapter 7 Trustee. 

(Attachments: # 1 Exhibit 1 # 2Exhibit 2 # 3 Exhibit 3 # 4 Exhibit 4 # 5 Exhibit 5) 

(Morabito, Erika) [ECF No. 86]

Response Deadline:

The Movant unilaterally set a response deadline for 11:00 am on 

October 18, 2021. The Trustee maintains that the Movant has 

misapplied a local rule of this Court, which provides “A hearing 

may not be set by a party on less than 14 days’ notice unless the 

Court grants a motion requesting an expedited hearing pursuant 

to paragraph (N) of this Local Bankruptcy Rule. If a hearing is set 

on an expedited basis, the opposing party may file a response, 

with a supporting memorandum, not later than 1 day before the 

date of the hearing or as otherwise directed by the Court.” This 

Court has not yet granted the request for an expedited hearing. 

Nonetheless, the Trustee, through counsel, is working on a 

response which she intends to file on October18, 2021.

Responses Filed: None as of the filing of this agenda, but the Trustee intends on 

filing a response. 

Status: The Trustee will request that the Court deny the Motion.

7. Adversary Proceeding No. 21-03079 (Cahill, Jr.) – Motion to Consolidate Lead Case 20-

cv-03142 with 21-cv-03079 filed by Diana Lyn Curtis McGraw of Fox Rothschild LLP on 

behalf of John H. Cahill, Jr.. (Attachments: # 1 Proposed Order) (McGraw, Diana Lyn)

[ECF No. 5]

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Related documents: 

a. Motion to Expedite Hearing (Related Document(s)5 Motion to Consolidate filed 

by John H. Cahill, Jr.) filed by Diana Lyn Curtis McGraw of Fox Rothschild LLP 

on behalf of John H. Cahill, Jr.. (McGraw, Diana Lyn) [ECF No. 6]

b. Notice of Hearing (Re: related document(s)5 Motion to Consolidate filed by John 

H. Cahill, Jr., 6 Motion to Expedite Hearing filed by John H. Cahill, Jr.) filed by 

Diana Lyn Curtis McGraw of Fox Rothschild LLP on behalf of John H. Cahill, 

Jr.. Hearing scheduled for 10/19/2021 at 11:00 AM at Judge Huennekens' 

Courtroom, 701 E. Broad St., Rm. 5000, Richmond, Virginia. (McGraw, Diana 

Lyn) [ECF No. 7]

c. Adversary case 21-03079. Complaint against John H. Cahill, Jr. filed by Lynn L. 

Tavenner, as Chapter 7 Trustee. Nature of Suit: (13 (Recovery of money/property 

- 548 fraudulent transfer)), (02 (Other (e.g., other actions that would have been 

brought in state court if unrelated to bankruptcy))) Associated Bankruptcy Case 

Number: 3:19-bk-34574 (Nelson, Brittany) [ECF No. 1]

d. Adversary Proceeding No. 20-03142 (ULX Partners, LLC, UnitedLex 

Corporation) – Amended Complaint against ULX Manager LLC, Gary LeClair, 

ULX Partners, LLC, UnitedLex Corporation (Re: related document(s)1 Complaint 

filed by Lynn L. Tavenner, as Chapter 7 Trustee) filed by Erika L. Morabito of 

Quinn Emanuel on behalf of Lynn L. Tavenner, as Chapter 7 Trustee. 

(Attachments: # 1 Exhibit 1 # 2Exhibit 2 # 3 Exhibit 3 # 4 Exhibit 4 # 5 Exhibit 5) 

(Morabito, Erika) [ECF No. 86]

Response Deadline:

The Movant unilaterally set a response deadline for 11:00 am on 

October 18, 2021. The Trustee maintains that the Movant has 

misapplied a local rule of this Court, which provides “A hearing 

may not be set by a party on less than 14 days’ notice unless the 

Court grants a motion requesting an expedited hearing pursuant 

to paragraph (N) of this Local Bankruptcy Rule. If a hearing is set 

on an expedited basis, the opposing party may file a response, 

with a supporting memorandum, not later than 1 day before the 

date of the hearing or as otherwise directed by the Court.” This 

Court has not yet granted the request for an expedited hearing. 

Nonetheless, the Trustee, through counsel, is working on a 

response which she intends to file on October18, 2021.

Responses Filed: None as of the filing of this agenda, but the Trustee intends on 

filing a response. 

Status: The Trustee will request that the Court deny the Motion.

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8. Adversary Proceeding No. 21-03080 (Walker) – Motion to Consolidate Lead Case 20-cv03142 with 21-cv-03080 filed by Diana Lyn Curtis McGraw of Fox Rothschild LLP on 

behalf of Karol Corbin Walker. (Attachments: # 1 Proposed Order) (McGraw, Diana Lyn)

[ECF No. 5]

Related documents: 

a. Motion to Expedite Hearing (Related Document(s)5 Motion to Consolidate filed 

by Karol Corbin Walker) filed by Diana Lyn Curtis McGraw of Fox Rothschild 

LLP on behalf of Karol Corbin Walker. (McGraw, Diana Lyn) [ECF No. 6]

b. Notice of Hearing (Re: related document(s)5 Motion to Consolidate filed by 

Karol Corbin Walker, 6 Motion to Expedite Hearing filed by Karol Corbin 

Walker) filed by Diana Lyn Curtis McGraw of Fox Rothschild LLP on behalf of 

Karol Corbin Walker. Hearing scheduled for 10/19/2021 at 11:00 AM at Judge 

Huennekens' Courtroom, 701 E. Broad St., Rm. 5000, Richmond, Virginia. 

(McGraw, Diana Lyn) [ECF No. 7]

c. Adversary case 21-03080. Complaint against Karol Corbin Walker filed by Lynn 

L. Tavenner, as Chapter 7 Trustee. Nature of Suit: (13 (Recovery of 

money/property - 548 fraudulent transfer)), (02 (Other (e.g., other actions that 

would have been brought in state court if unrelated to bankruptcy))) Associated 

Bankruptcy Case Number: 3:19-bk-34574 (Nelson, Brittany) [ECF No. 1]

d. Adversary Proceeding No. 20-03142 (ULX Partners, LLC, UnitedLex 

Corporation) – Amended Complaint against ULX Manager LLC, Gary LeClair, 

ULX Partners, LLC, UnitedLex Corporation (Re: related document(s)1 Complaint 

filed by Lynn L. Tavenner, as Chapter 7 Trustee) filed by Erika L. Morabito of 

Quinn Emanuel on behalf of Lynn L. Tavenner, as Chapter 7 Trustee. 

(Attachments: # 1 Exhibit 1 # 2Exhibit 2 # 3 Exhibit 3 # 4 Exhibit 4 # 5 Exhibit 5) 

(Morabito, Erika) [ECF No. 86]

Response Deadline:

The Movant unilaterally set a response deadline for 11:00 am on 

October 18, 2021. The Trustee maintains that the Movant has 

misapplied a local rule of this Court, which provides “A hearing 

may not be set by a party on less than 14 days’ notice unless the 

Court grants a motion requesting an expedited hearing pursuant 

to paragraph (N) of this Local Bankruptcy Rule. If a hearing is set 

on an expedited basis, the opposing party may file a response, 

with a supporting memorandum, not later than 1 day before the 

date of the hearing or as otherwise directed by the Court.” This 

Court has not yet granted the request for an expedited hearing. 

Nonetheless, the Trustee, through counsel, is working on a 

response which she intends to file on October18, 2021.

Responses Filed: None as of the filing of this agenda, but the Trustee intends on 

filing a response. 

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Status: The Trustee will request that the Court deny the Motion.

9. Adversary Proceeding No. 21-03081 (Dombroff) – Motion to Consolidate Lead Case 20-

cv-03142 with 21-cv-03081 filed by Diana Lyn Curtis McGraw of Fox Rothschild LLP on 

behalf of Mark Dombroff. (Attachments: # 1Proposed Order) (McGraw, Diana Lyn) [ECF 

No. 5]

Related documents: 

a. Motion to Expedite Hearing (Related Document(s)5 Motion to Consolidate filed 

by Mark Dombroff) filed by Diana Lyn Curtis McGraw of Fox Rothschild LLP 

on behalf of Mark Dombroff. (McGraw, Diana Lyn) [ECF No. 6]

b. Notice of Hearing (Re: related document(s)5 Motion to Consolidate filed by Mark 

Dombroff, 6 Motion to Expedite Hearing filed by Mark Dombroff) filed by Diana 

Lyn Curtis McGraw of Fox Rothschild LLP on behalf of Mark Dombroff. 

Hearing scheduled for 10/19/2021 at 11:00 AM at Judge Huennekens' Courtroom, 

701 E. Broad St., Rm. 5000, Richmond, Virginia. (McGraw, Diana Lyn) [ECF 

No. 7]

c. Adversary case 21-03081. Complaint against Mark Dombroff filed by Lynn L. 

Tavenner, as Chapter 7 Trustee. Nature of Suit: (13 (Recovery of money/property 

- 548 fraudulent transfer)), (02 (Other (e.g., other actions that would have been 

brought in state court if unrelated to bankruptcy))) Associated Bankruptcy Case 

Number: 3:19-bk-34574 (Nelson, Brittany) [ECF No. 1]

d. Adversary Proceeding No. 20-03142 (ULX Partners, LLC, UnitedLex 

Corporation) – Amended Complaint against ULX Manager LLC, Gary LeClair, 

ULX Partners, LLC, UnitedLex Corporation (Re: related document(s)1 Complaint 

filed by Lynn L. Tavenner, as Chapter 7 Trustee) filed by Erika L. Morabito of 

Quinn Emanuel on behalf of Lynn L. Tavenner, as Chapter 7 Trustee. 

(Attachments: # 1 Exhibit 1 # 2Exhibit 2 # 3 Exhibit 3 # 4 Exhibit 4 # 5 Exhibit 5) 

(Morabito, Erika) [ECF No. 86]

Response Deadline:

The Movant unilaterally set a response deadline for 11:00 am on 

October 18, 2021. The Trustee maintains that the Movant has 

misapplied a local rule of this Court, which provides “A hearing 

may not be set by a party on less than 14 days’ notice unless the 

Court grants a motion requesting an expedited hearing pursuant 

to paragraph (N) of this Local Bankruptcy Rule. If a hearing is set 

on an expedited basis, the opposing party may file a response, 

with a supporting memorandum, not later than 1 day before the 

date of the hearing or as otherwise directed by the Court.” This 

Court has not yet granted the request for an expedited hearing. 

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11

Nonetheless, the Trustee, through counsel, is working on a 

response which she intends to file on October18, 2021.

Responses Filed: None as of the filing of this agenda, but the Trustee intends on 

filing a response. 

Status: The Trustee will request that the Court deny the Motion.

10. Adversary Proceeding No. 21-03082 (Ferland) – Motion to Consolidate Lead Case 20-

03142 with 21-cv-03082 filed by Diana Lyn Curtis McGraw of Fox Rothschild LLP on 

behalf of Niclas Ferland. (Attachments: # 1Proposed Order) (McGraw, Diana Lyn) [ECF 

No. 5]

Related documents: 

a. Motion to Expedite Hearing (Related Document(s)5 Motion to Consolidate filed 

by Niclas Ferland) filed by Diana Lyn Curtis McGraw of Fox Rothschild LLP on 

behalf of Niclas Ferland. (McGraw, Diana Lyn) [ECF No. 6]

b. Notice of Hearing (Re: related document(s)5 Motion to Consolidate filed by 

Niclas Ferland, 6 Motion to Expedite Hearing filed by Niclas Ferland) filed by 

Diana Lyn Curtis McGraw of Fox Rothschild LLP on behalf of Niclas Ferland. 

Hearing scheduled for 10/19/2021 at 11:00 AM at Judge Huennekens' Courtroom, 

701 E. Broad St., Rm. 5000, Richmond, Virginia. (McGraw, Diana Lyn) [ECF 

No.7]

c. Adversary case 21-03082. Complaint against Niclas Ferland filed by Lynn L. 

Tavenner, as Chapter 7 Trustee. Nature of Suit: (13 (Recovery of money/property 

- 548 fraudulent transfer)), (02 (Other (e.g., other actions that would have been 

brought in state court if unrelated to bankruptcy))) Associated Bankruptcy Case 

Number: 3:19-bk-34574 (Nelson, Brittany) [ECF No. 1]

d. Adversary Proceeding No. 20-03142 (ULX Partners, LLC, UnitedLex 

Corporation) – Amended Complaint against ULX Manager LLC, Gary LeClair, 

ULX Partners, LLC, UnitedLex Corporation (Re: related document(s)1 Complaint 

filed by Lynn L. Tavenner, as Chapter 7 Trustee) filed by Erika L. Morabito of 

Quinn Emanuel on behalf of Lynn L. Tavenner, as Chapter 7 Trustee. 

(Attachments: # 1 Exhibit 1 # 2Exhibit 2 # 3 Exhibit 3 # 4 Exhibit 4 # 5 Exhibit 5) 

(Morabito, Erika) [ECF No. 86]

Response Deadline:

The Movant unilaterally set a response deadline for 11:00 am on 

October 18, 2021. The Trustee maintains that the Movant has 

misapplied a local rule of this Court, which provides “A hearing 

may not be set by a party on less than 14 days’ notice unless the 

Court grants a motion requesting an expedited hearing pursuant 

to paragraph (N) of this Local Bankruptcy Rule. If a hearing is set 

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12

on an expedited basis, the opposing party may file a response, 

with a supporting memorandum, not later than 1 day before the 

date of the hearing or as otherwise directed by the Court.” This 

Court has not yet granted the request for an expedited hearing. 

Nonetheless, the Trustee, through counsel, is working on a 

response which she intends to file on October18, 2021.

Responses Filed: None as of the filing of this agenda, but the Trustee intends on 

filing a response. 

Status: The Trustee will request that the Court deny the Motion.

11. Adversary Proceeding No. 21-03083 (Grubin) – Motion to Consolidate Lead Case 20-cv03142 with 21-cv-03083 filed by Diana Lyn Curtis McGraw of Fox Rothschild LLP on 

behalf of Janice Grubin. (Attachments: # 1Proposed Order) (McGraw, Diana Lyn) [ECF 

No. 5]

Related documents: 

a. Motion to Expedite Hearing (Related Document(s)5 Motion to Consolidate filed 

by Janice Grubin) filed by Diana Lyn Curtis McGraw of Fox Rothschild LLP on 

behalf of Janice Grubin. (McGraw, Diana Lyn) [ECF No. 6]

b. Notice of Hearing (Re: related document(s)5 Motion to Consolidate filed by 

Janice Grubin, 6 Motion to Expedite Hearing filed by Janice Grubin) filed by 

Diana Lyn Curtis McGraw of Fox Rothschild LLP on behalf of Janice Grubin. 

Hearing scheduled for 10/19/2021 at 11:00 AM at Judge Huennekens' Courtroom, 

701 E. Broad St., Rm. 5000, Richmond, Virginia. (McGraw, Diana Lyn) [ECF 

No. 7]

c. Adversary case 21-03083. Complaint against Janice Grubin filed by Lynn L. 

Tavenner, as Chapter 7 Trustee. Nature of Suit: (13 (Recovery of money/property 

- 548 fraudulent transfer)), (02 (Other (e.g., other actions that would have been 

brought in state court if unrelated to bankruptcy))) Associated Bankruptcy Case 

Number: 3:19-bk-34574 (Nelson, Brittany) [ECF No. 1]

d. Adversary Proceeding No. 20-03142 (ULX Partners, LLC, UnitedLex 

Corporation) – Amended Complaint against ULX Manager LLC, Gary LeClair, 

ULX Partners, LLC, UnitedLex Corporation (Re: related document(s)1 Complaint 

filed by Lynn L. Tavenner, as Chapter 7 Trustee) filed by Erika L. Morabito of 

Quinn Emanuel on behalf of Lynn L. Tavenner, as Chapter 7 Trustee. 

(Attachments: # 1 Exhibit 1 # 2Exhibit 2 # 3 Exhibit 3 # 4 Exhibit 4 # 5 Exhibit 5) 

(Morabito, Erika) [ECF No. 86]

Response Deadline: The Movant unilaterally set a response deadline for 11:00 am on 

October 18, 2021. The Trustee maintains that the Movant has 

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13

misapplied a local rule of this Court, which provides “A hearing 

may not be set by a party on less than 14 days’ notice unless the 

Court grants a motion requesting an expedited hearing pursuant 

to paragraph (N) of this Local Bankruptcy Rule. If a hearing is set 

on an expedited basis, the opposing party may file a response, 

with a supporting memorandum, not later than 1 day before the 

date of the hearing or as otherwise directed by the Court.” This 

Court has not yet granted the request for an expedited hearing. 

Nonetheless, the Trustee, through counsel, is working on a 

response which she intends to file on October18, 2021.

Responses Filed: None as of the filing of this agenda, but the Trustee intends on 

filing a response. 

Status: The Trustee will request that the Court deny the Motion.

12. Adversary Proceeding No. 21-03087 (Thompson) – Motion to Consolidate Lead Case 20-

cv-03142 with 21-cv-03087 filed by Diana Lyn Curtis McGraw of Fox Rothschild LLP on 

behalf of Lori Thompson. (Attachments: # 1Proposed Order) (McGraw, Diana Lyn) [ECF 

No. 5]

Related documents: 

a. Motion to Expedite Hearing (Related Document(s)5 Motion to Consolidate filed 

by Lori Thompson) filed by Diana Lyn Curtis McGraw of Fox Rothschild LLP on 

behalf of Lori Thompson. (McGraw, Diana Lyn) [ECF No. 6]

b. Notice of Hearing (Re: related document(s)5 Motion to Consolidate filed by Lori 

Thompson, 6 Motion to Expedite Hearing filed by Lori Thompson) filed by Diana 

Lyn Curtis McGraw of Fox Rothschild LLP on behalf of Lori Thompson. Hearing 

scheduled for 10/19/2021 at 11:00 AM at Judge Huennekens' Courtroom, 701 E. 

Broad St., Rm. 5000, Richmond, Virginia. (McGraw, Diana Lyn) [ECF No. 7]

c. Adversary case 21-03087. Complaint against Lori Thompson filed by Lynn L. 

Tavenner, as Chapter 7 Trustee. Nature of Suit: (13 (Recovery of money/property 

- 548 fraudulent transfer)), (02 (Other (e.g., other actions that would have been 

brought in state court if unrelated to bankruptcy))) Associated Bankruptcy Case 

Number: 3:19-bk-34574 (Nelson, Brittany) [ECF No. 1]

d. Adversary Proceeding No. 20-03142 (ULX Partners, LLC, UnitedLex 

Corporation) – Amended Complaint against ULX Manager LLC, Gary LeClair, 

ULX Partners, LLC, UnitedLex Corporation (Re: related document(s)1 Complaint 

filed by Lynn L. Tavenner, as Chapter 7 Trustee) filed by Erika L. Morabito of 

Quinn Emanuel on behalf of Lynn L. Tavenner, as Chapter 7 Trustee. 

(Attachments: # 1 Exhibit 1 # 2Exhibit 2 # 3 Exhibit 3 # 4 Exhibit 4 # 5 Exhibit 5) 

(Morabito, Erika) [ECF No. 86]

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14

Response Deadline:

The Movant unilaterally set a response deadline for 11:00 am on 

October 18, 2021. The Trustee maintains that the Movant has 

misapplied a local rule of this Court, which provides “A hearing 

may not be set by a party on less than 14 days’ notice unless the 

Court grants a motion requesting an expedited hearing pursuant 

to paragraph (N) of this Local Bankruptcy Rule. If a hearing is set 

on an expedited basis, the opposing party may file a response, 

with a supporting memorandum, not later than 1 day before the 

date of the hearing or as otherwise directed by the Court.” This 

Court has not yet granted the request for an expedited hearing. 

Nonetheless, the Trustee, through counsel, is working on a 

response which she intends to file on October18, 2021.

Responses Filed: None as of the filing of this agenda, but the Trustee intends on 

filing a response. 

Status: The Trustee will request that the Court deny the Motion.

13. Adversary Proceeding No. 21-03089 (Gustafson) – Motion to Consolidate Lead Case 20-

cv-03142 with 21-cv-03089 filed by Diana Lyn Curtis McGraw of Fox Rothschild LLP on 

behalf of Charles Erik Gustafson. (Attachments: # 1 Proposed Order) (McGraw, Diana 

Lyn) [ECF No. 5]

Related documents: 

a. Motion to Expedite Hearing (Related Document(s)5 Motion to Consolidate filed 

by Charles Erik Gustafson) filed by Diana Lyn Curtis McGraw of Fox Rothschild 

LLP on behalf of Charles Erik Gustafson. (McGraw, Diana Lyn) [ECF No. 6]

b. Notice of Hearing (Re: related document(s)5 Motion to Consolidate filed by 

Charles Erik Gustafson, 6 Motion to Expedite Hearing filed by Charles Erik 

Gustafson) filed by Diana Lyn Curtis McGraw of Fox Rothschild LLP on behalf 

of Charles Erik Gustafson. Hearing scheduled for 10/19/2021 at 11:00 AM at 

Judge Huennekens' Courtroom, 701 E. Broad St., Rm. 5000, Richmond, Virginia. 

(McGraw, Diana Lyn) [ECF No. 7]

c. Adversary case 21-03089. Complaint against Charles Erik Gustafson filed by 

Lynn L. Tavenner, as Chapter 7 Trustee. Nature of Suit: (13 (Recovery of 

money/property - 548 fraudulent transfer)), (02 (Other (e.g., other actions that 

would have been brought in state court if unrelated to bankruptcy))) Associated 

Bankruptcy Case Number: 3:19-bk-34574 (Nelson, Brittany) [ECF No. 1]

d. Adversary Proceeding No. 20-03142 (ULX Partners, LLC, UnitedLex 

Corporation) – Amended Complaint against ULX Manager LLC, Gary LeClair, 

ULX Partners, LLC, UnitedLex Corporation (Re: related document(s)1 Complaint 

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15

filed by Lynn L. Tavenner, as Chapter 7 Trustee) filed by Erika L. Morabito of 

Quinn Emanuel on behalf of Lynn L. Tavenner, as Chapter 7 Trustee. 

(Attachments: # 1 Exhibit 1 # 2Exhibit 2 # 3 Exhibit 3 # 4 Exhibit 4 # 5 Exhibit 5) 

(Morabito, Erika) [ECF No. 86]

Response Deadline:

The Movant unilaterally set a response deadline for 11:00 am on 

October 18, 2021. The Trustee maintains that the Movant has 

misapplied a local rule of this Court, which provides “A hearing 

may not be set by a party on less than 14 days’ notice unless the 

Court grants a motion requesting an expedited hearing pursuant 

to paragraph (N) of this Local Bankruptcy Rule. If a hearing is set 

on an expedited basis, the opposing party may file a response, 

with a supporting memorandum, not later than 1 day before the 

date of the hearing or as otherwise directed by the Court.” This 

Court has not yet granted the request for an expedited hearing. 

Nonetheless, the Trustee, through counsel, is working on a 

response which she intends to file on October18, 2021.

Responses Filed: None as of the filing of this agenda, but the Trustee intends on 

filing a response. 

Status: The Trustee will request that the Court deny the Motion.

14. Adversary Proceeding No. 21-03090 (Medley) – Motion to Consolidate Lead Case 20-cv03142 with 21-cv-03090 filed by Diana Lyn Curtis McGraw of Fox Rothschild LLP on 

behalf of Jason Medley. (Attachments: # 1Proposed Order) (McGraw, Diana Lyn) [ECF 

No. 5]

Related documents: 

a. Motion to Expedite Hearing (Related Document(s)5 Motion to Consolidate filed 

by Jason Medley) filed by Diana Lyn Curtis McGraw of Fox Rothschild LLP on 

behalf of Jason Medley. (McGraw, Diana Lyn) [ECF No. 6]

b. Notice of Hearing (Re: related document(s)5 Motion to Consolidate filed by Jason 

Medley, 6 Motion to Expedite Hearing filed by Jason Medley) filed by Diana Lyn 

Curtis McGraw of Fox Rothschild LLP on behalf of Jason Medley. Hearing 

scheduled for 10/19/2021 at 11:00 AM at Judge Huennekens' Courtroom, 701 E. 

Broad St., Rm. 5000, Richmond, Virginia. (McGraw, Diana Lyn) [ECF No. 7]

c. Adversary case 21-03090. Complaint against Jason Medley filed by Lynn L. 

Tavenner, as Chapter 7 Trustee. Nature of Suit: (13 (Recovery of money/property 

- 548 fraudulent transfer)), (02 (Other (e.g., other actions that would have been 

brought in state court if unrelated to bankruptcy))) Associated Bankruptcy Case 

Number: 3:19-bk-34574 (Nelson, Brittany) [ECF No. 1]

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16

d. Adversary Proceeding No. 20-03142 (ULX Partners, LLC, UnitedLex 

Corporation) – Amended Complaint against ULX Manager LLC, Gary LeClair, 

ULX Partners, LLC, UnitedLex Corporation (Re: related document(s)1 Complaint 

filed by Lynn L. Tavenner, as Chapter 7 Trustee) filed by Erika L. Morabito of 

Quinn Emanuel on behalf of Lynn L. Tavenner, as Chapter 7 Trustee. 

(Attachments: # 1 Exhibit 1 # 2Exhibit 2 # 3 Exhibit 3 # 4 Exhibit 4 # 5 Exhibit 5) 

(Morabito, Erika) [ECF No. 86]

Response Deadline:

The Movant unilaterally set a response deadline for 11:00 am on 

October 18, 2021. The Trustee maintains that the Movant has 

misapplied a local rule of this Court, which provides “A hearing 

may not be set by a party on less than 14 days’ notice unless the 

Court grants a motion requesting an expedited hearing pursuant 

to paragraph (N) of this Local Bankruptcy Rule. If a hearing is set 

on an expedited basis, the opposing party may file a response, 

with a supporting memorandum, not later than 1 day before the 

date of the hearing or as otherwise directed by the Court.” This 

Court has not yet granted the request for an expedited hearing. 

Nonetheless, the Trustee, through counsel, is working on a 

response which she intends to file on October18, 2021.

Responses Filed: None as of the filing of this agenda, but the Trustee intends on 

filing a response. 

Status: The Trustee will request that the Court deny the Motion.

15. Adversary Proceeding No. 21-03091 (Acee) – Motion to Consolidate Lead Case 20-cv03142 with 21-03091 filed by Diana Lyn Curtis McGraw of Fox Rothschild LLP on behalf 

of Elizabeth Acee. (Attachments: # 1Proposed Order) (McGraw, Diana Lyn) [ECF No. 5]

Related documents: 

a. Motion to Expedite Hearing - Motion to Consolidate Adversary Proceedings for 

Purposes of Joint Administration and for Related Relief (Related 

Document(s)5 Motion to Consolidate filed by Elizabeth Acee) filed by Diana Lyn 

Curtis McGraw of Fox Rothschild LLP on behalf of Elizabeth Acee. (McGraw, 

Diana Lyn) [ECF No. 6]

b. Notice of Hearing (Re: related document(s)5 Motion to Consolidate filed by 

Elizabeth Acee, 6 Motion to Expedite Hearing filed by Elizabeth Acee) filed by 

Diana Lyn Curtis McGraw of Fox Rothschild LLP on behalf of Elizabeth Acee. 

Hearing scheduled for 10/19/2021 at 11:00 AM at Judge Huennekens' Courtroom, 

701 E. Broad St., Rm. 5000, Richmond, Virginia. (McGraw, Diana Lyn) [ECF 

No. 7]

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17

c. Adversary case 21-03091. Complaint against Elizabeth Acee filed by Lynn L. 

Tavenner, as Chapter 7 Trustee. Nature of Suit: (13 (Recovery of money/property 

- 548 fraudulent transfer)), (02 (Other (e.g., other actions that would have been 

brought in state court if unrelated to bankruptcy))) Associated Bankruptcy Case 

Number: 3:19-bk-34574 (Nelson, Brittany) [ECF No. 1]

d. Adversary Proceeding No. 20-03142 (ULX Partners, LLC, UnitedLex 

Corporation) – Amended Complaint against ULX Manager LLC, Gary LeClair, 

ULX Partners, LLC, UnitedLex Corporation (Re: related document(s)1 Complaint 

filed by Lynn L. Tavenner, as Chapter 7 Trustee) filed by Erika L. Morabito of 

Quinn Emanuel on behalf of Lynn L. Tavenner, as Chapter 7 Trustee. 

(Attachments: # 1 Exhibit 1 # 2Exhibit 2 # 3 Exhibit 3 # 4 Exhibit 4 # 5 Exhibit 5) 

(Morabito, Erika) [ECF No. 86]

Response Deadline:

The Movant unilaterally set a response deadline for 11:00 am on 

October 18, 2021. The Trustee maintains that the Movant has 

misapplied a local rule of this Court, which provides “A hearing 

may not be set by a party on less than 14 days’ notice unless the 

Court grants a motion requesting an expedited hearing pursuant 

to paragraph (N) of this Local Bankruptcy Rule. If a hearing is set 

on an expedited basis, the opposing party may file a response, 

with a supporting memorandum, not later than 1 day before the 

date of the hearing or as otherwise directed by the Court.” This 

Court has not yet granted the request for an expedited hearing. 

Nonetheless, the Trustee, through counsel, is working on a 

response which she intends to file on October18, 2021.

Responses Filed: None as of the filing of this agenda, but the Trustee intends on 

filing a response. 

Status: The Trustee will request that the Court deny the Motion.

III. REPORTS

16. Case Status and Report pursuant to Local Rule 2015-(a)-(1)(A)

Respectfully submitted,

LYNN L. TAVENNER, CHAPTER 7 TRUSTEE

Dated: October 17, 2021

Richmond, Virginia

By: /s/ Paula S. Beran

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

PBeran@TB-LawFirm.com

Tavenner & Beran, PLC

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18

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

Pursuant to the Local Rules of this Court and applicable orders, I certify that on this 17th

day of October 2021, a true copy of the foregoing Agenda was sent electronically to all parties 

receiving ECF notices in this Case.

/s/ Paula S. Beran

Counsel for Lynn L. Tavenner, Chapter 7 Trustee

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