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

Tavenner & Beran, PLC 

20 North Eighth Street, Second Floor

Richmond, Virginia 23219

Telephone: (804) 783-8300

 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

WITNESS LIST AND RELATED DECLARATION

In accordance with Richmond General Order 22-2, 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 (the “Estate”) of LeClairRyan PLLC (“LeClairRyan” and/or the 

“Debtor”), in the above-referenced Chapter 7 case (the “Case”) hereby files, by counsel, a 

witness list and related declaration. 

WITNESS LIST

In support of the relief requested in the items designated on the Proposed Hearing 

Agenda [ECF No. 1594], the Trustee submits the following list: 

1. Lynn L. Tavenner, Chapter 7 trustee 

DECLARATION OF LYNN L. TAVENNER, TRUSTEE

I, Lynn L. Tavenner, Trustee, not individually but solely in my 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”), in the above1 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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referenced Chapter 7 case (the “Case”), pursuant to 28 U.S.C. § 1746, hereby declare as follows 

under penalty of perjury to the best of my knowledge, information, and belief:

1. I am the duly appointed Chapter 7 Trustee in the LeClairRyan Case. 

2. I submit this declaration in support of the (1) Ninth Application for Compensation 

for Tavenner Beran, PLC as Counsel to the Chapter 7 Trustee/Estate, [ECF No. 1583]; (2) Sixth 

Application for Compensation for CR3 Partners, LLC as Financial Advisor to the Chapter 7 

Trustee/Estate, [ECF No. 1584]; (3) Seventh Application for Compensation for Barry Strickland 

& Company as Accountant, [ECF No. 1586]; (4) Final Application for Compensation for Cozen 

O'Connor as Special Counsel to the Chapter 7 Trustee/Estate , [ECF No. 1585]; (5) Fifth 

Application for Compensation for Quinn Emanuel Urquhart & Sullivan, LLP as Special Counsel 

to the Trustee, [ECF No. 1582] (collectively, the “Applications” and each an “Application”); 

and (6) Case Status and Report pursuant to Local Rule 2015-(a)-(1)(A).

3. The statements in this Declaration are, except where specifically noted, based on 

my personal knowledge on information that I have obtained in connection with my role as the 

Trustee. If I were called upon to testify, I could and would competently testify to the facts set forth 

herein on that basis.

4. The Bankruptcy Code sets forth legal standards for the Court to award my 

professionals reasonable compensation for actual, necessary services rendered by such attorneys 

and paraprofessionals employed by such firms based on the nature, extent, and value of the services 

rendered, time spent on such services, and the cost of comparable services other than in a 

bankruptcy case. I understand that the Court may award reimbursement for actual, necessary 

expenses that benefit the Estate. I regularly review the invoices of Estate professionals and require 

modifications when I believe in the exercise of my business judgment adjustments are warranted 

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and in the best interest of the Estate. I have reviewed the Applications in the context of interim 

applications. I believe that the fees requested satisfy the loadstar factors enumerated in Johnson v. 

Georgia Highway Express, Inc., 488 F.2d 714 (5th Cir. 1974) as adopted by the Fourth Circuit in 

Barber v. Kimbrells, Inc., 577 F.2d 216, 226 (4th Cir.), cert. denied, 439 U.S. 934 (1978), and in 

Anderson v. Morris, 658 F.2d 246, 249 (4th Cir. 1981) The rates charged by my professionals are 

comparable to, if not less than, fees charged by other firms retained in similar capacities in 

comparable Chapter 7 cases, or, in all requisite instances, elevation above the rates in the 

Richmond Division is warranted by both the factors enumerated in 11 U.S.C. § 330 and the 

Johnson loadstar factors. I anticipate certain adjustments to future fee applications to address items 

in one or more of these interim Applications. And, in the exercise of my business judgment, I 

maintain that the amounts should be approved on an interim basis as being in the best interest of 

the Estate. 

5. To the best of my knowledge, information, and belief, I declare under penalty of 

perjury that the foregoing is true and correct. 

LYNN L. TAVENNER, CHAPTER 7 TRUSTEE

Dated: September 27, 2022

 Richmond, Virginia 

By: /s/ Lynn L. Tavenner

 Lynn L. Tavenner, Chapter 7 Trustee 

Respectfully submitted,

LYNN L. TAVENNER, CHAPTER 7 TRUSTEE

Dated: September 27, 2022

 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 

Counsel for Lynn L. Tavenner, Chapter 7 Trustee

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CERTIFICATE OF SERVICE

I certify that on this 27th day of September 2022, a true copy of the foregoing Witness 

List and Related Declaration was sent electronically to:

Shannon F. Pecoraro, Esquire (Va. Bar No. 46864)

Department of Justice

Office of the United States Trustee

701 East Broad Street, Suite 4304 

Richmond, Virginia 23219

And all other parties receiving CM/ECF notices in this Case.

/s/ Paula S. Beran 

Paula S. Beran, Esquire 

Counsel for Lynn L. Tavenner, Chapter 7 Trustee

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