1 

David G. Barger (VSB No. 21652) 

Thomas J. McKee, Jr. (VSB No. 68427) 

J. Gregory Milmoe (admitted pro hac vice) 

Greenberg Traurig, LLP 

1750 Tysons Boulevard, Suite 1000 

McLean, Virginia 22102 

Telephone: (703) 749-1300 

Fax: (703) 749-1301 

Email: mckeet@gtlaw.com 

Counsel to ULX Partners, LLC and UnitedLex Corporation 

IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE EASTERN DISTRICT OF VIRGINIA 

(Richmond Division) 

In re: 

LECLAIRRYAN PLLC, 

Debtor. 

Chapter 7 

Case No. 19-34574 (KRH) 

Lynn L. Tavenner, as Chapter 7 Trustee, 

 Plaintiff, 

vs. 

ULX Partners, LLC and UnitedLex Corporation 

 Defendants. 

 Adv. Pro. 20-03142 (KRH) 

DEFENDANTS’ OBJECTION TO TRUSTEE’S MOTION FOR LEAVE TO AMEND 

COMPLAINT AND TO MODIFY PRETRIAL SCHEDULING ORDER

 ULX Partners, LLC (“ULXP”) and UnitedLex Corporation (“UnitedLex” and together 

with ULXP, the “Defendants”), by and through their undersigned counsel, submit this objection (the 

“Objection”) to the Motion for Leave to Amend Complaint and to Modify Pretrial Scheduling Order

[ECF No. 66] (as modified by that Corrected Motion for Leave to Amend Complaint and to Modify 

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Pretrial Scheduling Order [ECF No. 73], the “Motion to Amend”)1

 filed by Lynn L. Tavenner, solely 

in her capacity as Chapter 7 Trustee (the “Trustee”) of the bankruptcy estate of LeClairRyan PLLC 

(“LeClairRyan” or the “Debtor”). In support of this Objection, the Defendants respectfully state as 

follows: 

PRELIMINARY STATEMENT

 On numerous occasions, counsel for the Trustee has expressed to the Court an earnest desire 

to administer the Debtor’s estate and prosecute the claims lodged against the Defendants as 

expeditiously and economically as possible. Now, only a couple months shy of when the trial for this 

Adversary Proceeding was to begin, the Trustee’s position has suddenly changed as she moves for 

leave to amend the Complaint to not only add defendants to the proceeding, but also to add new claims 

against the Defendants – primarily on the alleged basis that she developed evidence warranting such 

amendments. Yet other than vague conclusory assertions and generalities, the Trustee does not 

identify the new evidence she relies upon to justify an amendment, or, more importantly, when such 

evidence was discovered. Indeed, a review of the allegations in the Amended Complaint confirms 

that the amendment is not warranted because the new claims against the Defendants are not premised 

upon recently discovered evidence. Rather, the Trustee has had the relevant documents and 

information purportedly underlying the “new” claims against the Defendants in her possession since 

well before she filed the original Complaint in October 2020. 

In addition to being unjustified, the Trustee’s proposed amendment will prejudice Defendants. 

While the Court’s recent ruling on Defendants’ Motion to Dismiss eviscerated the bulk of the 

Trustee’s theories and claims in this case, the Trustee’s proposed amendment improperly seeks 

1

 Capitalized terms used but not otherwise defined herein shall have the meanings ascribed to such 

terms as set forth in the Motion to Amend.

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– all in an obvious and 

desperate effort to artificially support a sensational claim of damages following such ruling. 

Amendments are futile, however, and should not be permitted. 

Moreover, amending the complaint at this stage of the litigation will also significantly increase the 

costs of discovery. Not only will new discovery be required in the form of additional document 

custodians, years of emails, experts, and witnesses, but the Defendants will also likely need to 

reexamine many of the hundreds of thousands of pages of documents already exchanged in discovery 

with an eye towards the Trustee’s new claims and allegations. In many respects, the Trustee is asking 

that the parties begin anew. 

 In the event the Court grants the Motion to Amend notwithstanding the foregoing, the threemonth postponement of the trial date will not be sufficient. As the Trustee noted, the parties are “only 

partially through document discovery, and depositions have not yet commenced” (Motion to Amend, 

¶ 2). With the proposed addition of new defendants and numerous claims asserted against them, 

based on the pace of the discovery process thus far and anticipated future motions practice, a longer 

extension than that which the Trustee proposes is appropriate. Furthermore, if the trial is to be 

rescheduled, the Defendants request the opportunity to confer with the Trustee (and counsel for any 

added defendant) on new trial dates.2

2

 Prior to filing the Motion to Amend, the Trustee’s counsel did not confer with Defendants about 

the length of the potential continuance of the trial or her proposed dates in January/February 2022. 

Lead trial counsel for the Defendants has a conflicting trial in state court in California that is 

currently scheduled to begin on January 23, 2022, and last three to four weeks. Defendants would 

be unduly prejudiced should lead trial counsel not be able to represent the Defendants during the 

trial due to a scheduling conflict. 

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RELEVANT BACKGROUND

1. On October 26, 2020, the Trustee commenced the above-captioned adversary 

proceeding (the “Adversary Proceeding”) by filing a fourteen-count complaint (as corrected by that 

October 28, 2020 filing, the “Complaint”) [ECF No. 4] against the Defendants. 

2. On December 17, 2020, the Court entered an order (the “Pretrial Order”) [ECF No. 

9] fixing the trial date as well as pre-trial deadlines pertaining to statutory disclosures, discovery, 

dispositive motions and exhibit filings. 

3. On January 11, 2021, the Defendants filed a motion (the “Motion to Dismiss”) [ECF 

No. 17] seeking to dismiss ten of the fourteen counts of the Complaint. 

4. Since December 2020, Defendants and the Trustee have been engaged in written 

discovery, including exchanging interrogatory responses as well as exchanging and reviewing 

hundreds of thousands of pages of documents in various productions. 

5. On May 25, 2021,3

 the Court approved the Stipulated Protective Order Regarding the 

Disclosure and Use of Confidential Information (the “Protective Order”) [ECF No. 47] governing 

the parties’ use and disclosure of confidential information provided during the discovery process. 

6. On June 4, 2021, the Court entered an order (the “Second Pretrial Order”) [ECF No. 

49], modifying the trial date set forth in the Pretrial Order, with the new trial dates scheduled as 

October 25, 2021 through November 5, 2021. 

7. On June 24, 2021, the Court conducted a hearing on the Motion to Dismiss. 

8. On July 20, 2021, the Court issued its Memorandum Opinion (the “Motion to Dismiss 

Opinion” [ECF No. 57] and related order [ECF No. 58], granting in part and denying in part the 

3

 The order was signed on May 21, 2021 but entered on the docket on May 25, 2021. 

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Motion to Dismiss. With respect to the Trustee’s conspiracy counts in particular, the Court dismissed 

the bulk of the Trustee’s bases for such counts, holding: 

Entering into a joint venture, converting the business from a professional corporation to a 

professional limited liability company, terminating the firm’s deferred compensation and 

supplemental retirement plans, and making misleading or false statements to third-party 

professional consultants are not themselves unlawful acts, nor does the Trustee allege any 

unlawful means through which these acts were accomplished. Furthermore, in Virginia, a 

fraudulent conveyance cannot be the predicate act for a conspiracy claim. 

Motion to Dismiss Opinion, p.19. 

9. Rather, in the Motion to Dismiss Opinion, the Court held that only two allegations 

gave rise to a potential conspiracy claim: (i) an alleged conspiracy between Defendants and LCR’s 

board members and officers to breach directors/officers’ breach of fiduciary duty through the 

misappropriation of client funds, and (ii) the unauthorized practice of law by Defendants. See Motion 

to Dismiss Opinion, p.20. 

10. On August 5, 2021, the Trustee filed the Motion to Amend. The proposed amended 

complaint (the “Amended Complaint”) was attached as Exhibit A to the Motion to Amend and filed 

under seal. 

OBJECTION

A. The Trustee’s Unexplained and Unwarranted Delay in Filing the Motion to Amend 

Warrants Denial of Leave to Amend the Complaint 

11. As noted by the Supreme Court in Krupski v. Costa Crociere S.p.A., 560 U.S. 538 

(2010), “a court may consider a movant’s ‘undue delay’ or ‘dilatory motive’ in deciding whether 

to grant leave to amend under Rule 15(a).” Id.at 553. The Trustee’s reasons for seeking to amend 

the complaint at this late time, and after substantial delay, are circumspect and not clearly 

articulated in the motion beyond general and vague assertions. Accordingly, the Motion to Amend 

should be denied. 

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12. It has been approximately 10 months since the Trustee filed the original Complaint. 

Since that time, the parties have engaged in written discovery and various document productions 

beginning in February and March of 2021. Even prior to that time, however, the Trustee and her 

special counsel engaged in pre-complaint discovery, allegedly reviewing millions of pages of the 

Debtor’s own records and emails, conducting Rule 2004 exams of two of UnitedLex’s principals, 

and making demands for records from various third parties. Nevertheless, in her Motion to Amend, 

the Trustee asserts, without specifics, that since filing the Complaint in October 2020 her 

“investigation has uncovered compelling evidence that supports adding ULX 

Manager, and new claims against the existing defendants.” (Motion ¶10). Further, she argues that 

she brought the Motion to Amend “as promptly as she could have” (Motion to Amend, ¶ 17), 

prefacing such statement with an explanation that she “has been investigating a legion of targets . 

. . and has mediated and settled with dozens of parties.” (Id.). 

13. The Trustee’s activities with respect to mediating and settling other matters do not 

justify the delayed filing of the Motion to Amend in this case. The additional defendants the 

Trustee seeks to add have always been part of the narrative of the proceeding, even if not 

specifically identified in the Complaint. In fact, in the Trustee’s February 2021 responses to 

ULXP’s interrogatories, the Trustee identified as an alleged co-conspirator of the 

Defendants. Nevertheless, the Trustee opted to wait another seven months before moving to 

amend the Complaint to add . Further, it should be noted that it is the Trustee that 

opted to initiate this suit solely against the UnitedLex and ULXP back in October 2020 rather than 

wait for additional investigation with respect to other potential defendants. Thus, the potential 

prejudice she complains of in her Motion to Amend in the form of possible duplicate proceedings 

is solely the result of her own strategic choices. 

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assert new theories are not reviewed favorably when the facts and the theory have been known to the 

party seeking amendment since the inception of the cause of action.”) (quoting Acri v. International 

Ass’n of Machinsts, 781 F.2d 1393, 1398 (9th Cir. 1986); State Distributors, Inc. v. Glenmore 

Distilleries Co., 738 F.2d 405, 416 (10th Cir. 1984) (“Where the party seeking amendment knows or 

should have known of the facts upon which the proposed amendment is based but fails to include 

them in the original complaint, the motion to amend is subject to denial.”) (internal citations omitted). 

15. Moreover, with respect to the claims the Trustee seeks to allege against 

, the Trustee had access to evidence allegedly in support of such claims (or at least certain 

of them) since prior to the filing of the Complaint. For example, in the Trustee’s responses to the 

interrogatories propounded by the Defendants, which, again, the Trustee provided in February of 

this year, the Trustee identifies numerous communications between and the

Defendants or otherwise between and LeClairRyan employees regarding the joint 

venture. Further, many of the email communications that the Trustee cites throughout her 

complaint are emails that she has had in her possession since her appointment as they contain LCR 

employees as parties to the communications. 

16. Finally, and particularly in light of the fact that the Amended Complaint is based 

upon purported evidence known by the Trustee for some time, Defendants are prejudiced by the 

Trustee’s calculated decision to wait to file the Motion to Amend until after it had the benefit of 

the Court’s ruling on the Motion to Dismiss. As noted in Meisner v. Zymogenetics, Inc., 2016 U.S. 

Dist. LEXIS 125378 (D.S.C. 2016) where a plaintiff brought a motion to amend well into the 

litigation based on facts known to him at the time a case was originally removed to federal court, 

the court said: 

To allow the Plaintiff to amend its Complaint at this stage of the proceedings, after 

the Magistrate Judge has issued a formal recommendation regarding the disposition 

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of a dispositive motion, would not only prejudice the Defendants, who have 

expended the time and expense of fully briefing a motion to dismiss; it would 

encourage dilatory practices on the part of plaintiffs in delaying motions for leave 

to amend until after they have the benefit of a Magistrate Judge’s opinion. 

Id. at *19 (emphasis added). 

17. The Trustee has not stated a valid basis for her delay in filing the Motion to Amend. 

This unjustified delay coupled with the mentioned prejudice and the futility of the proposed Amended 

Complaint, as discussed below, supports denial of the Trustee’s request for leave. Cf. Island Creek 

Coal Co. v. Lake Shore, Inc., 832 F.2d 274 (4th Cir. 1987) (reversing a bankruptcy court’s denial 

of a motion to amend a complaint where, among other things, the motion was brought to state a 

separate ground for recovery the facts of which were allegedly discovered 3 months prior to the 

filing of the motion to amend.). 

B. The Motion to Amend Should be Denied as the Portions of the Proposed Amendment 

Would be Futile6

18. The Fourth Circuit has stated that leave to amend under Rule 15(a) should be denied 

when an amendment would be futile. See Laber v. Harvey, 438 F.3d 404, 426 (4th Cir. 2006). A 

proposed amendment is considered futile if it cannot withstand a motion to dismiss. See Perkins 

v. United States, 55 F.3d 910, 917 (4th Cir. 1995); Parker v. Berryhill, No. 4:17CV143, 2018 WL 

6 The Defendants reserve the right to raise these and additional arguments, including without 

limitation those in the realm of futility, through a potential Motion to Dismiss the Amended 

Complaint should the Court grant the Trustee leave to amend and the Defendants determine such 

filing to be appropriate. Additionally, it should be noted that the Trustee’s attempt to add ULX 

Manager, LLC as a defendant in this case violates the Court’s FAO Procedures Order, as 

amended [Bankruptcy Case Docket No. 533]. More specifically, the Trustee never served a 

demand letter upon ULX Manager, LLC, nor did it give ULX Manager, LLC an opportunity to 

mediate. Although ULX Manager, which is represented by Greenberg Traurig, would have 

rejected such demand and elected not to mediate at this stage, the Trustee’s decision to seek to 

add ULX Manager, LLC is yet another example of the Trustee litigating by her own set of rules 

and repeatedly requesting that the Court modify its procedures accordingly. 

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Entering into a joint venture, converting the business from a professional corporation to a 

professional limited liability company . . . and making misleading or false statements to thirdparty professional consultants are not themselves unlawful acts” on which a conspiracy claim 

can rest, nor can “a fraudulent conveyance . . . be the predicate act for a conspiracy claim. 

(Id.). 

23.

 

24. In the event the Court decides to grant the Motion to Amend, the ULX Entities 

respectfully request that the Court strike those portions of the Amended Complaint 

(ii) The Amended Complaint Cannot Be Based Upon Conclusory Allegations 

25. As noted in SD3, LLC v. Black & Decker (U.S.) Inc., 801 F.3d 412 (4th Cir. 2015), 

courts “accept as true all well-pled facts in the complaint and construe them in the light most favorable 

to [the pleading party].” Id. at 422 (internal citation omitted). Courts “do not, however, accept as 

true a legal conclusion couched as a factual allegation . . . [n]or do [courts] accept unwarranted 

inferences, unreasonable conclusions, or arguments.” Id. (internal quotations and citations omitted). 

Additionally, courts “can further put aside any naked assertions devoid of further factual 

enhancement.” Id. Portions of the Trustee’s proposed Amended Complaint fail to satisfy the 

foregoing. 

26.

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27. Similarly, the Trustee offers nothing but “naked assertions devoid of further factual 

enhancement” with respect to its inflammatory claims of by 

Defendants. See e.g., Amended Complaint, 

 

28. Conclusory allegations like those above are not a proper basis to state a claim and

the Amended Complaint is therefore futile in this respect. 

C. The Motion to Amend Should be Denied to the Extent it Ignores the Terms of the 

Protective Order 

29. The Defendants object to the Motion to Amend to the extent it ignores the 

protections provided under the terms of the Court’s Protective Order regarding discovery in this 

case. As noted by the Trustee in the Motion to Amend, counsel for the Trustee provided a draft of 

the amended complaint to counsel for the Defendants. Although the Amended Complaint does 

not attach emails as exhibits, the Trustee repeatedly quotes emails that were produced by 

Defendants in discovery and were designated as “Confidential” in accordance with the procedure 

set forth in the Protective Order. Pursuant to the terms of the Protective Order, such “Confidential” 

materials cannot be disclosed except to limited classes of persons/entities. [Docket No. 47, ¶11]. 

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30. In the event a party objects to the designation of a “Confidential” designation, the 

Protective Order requires that the objecting party serve a written objection stating the grounds for 

the objection, after which time the designating party shall have ten business days to consider and 

withdraw a designation. Id. at ¶10. If the designating party does not withdraw the designation, 

then the objecting party may move the Court for an order removing the designation. Id. The 

Protective Order states, however, that “[u]ntil the Court rules on the challenge, all parties shall 

continue to afford the material in question the level of protection to which it is entitled as 

designated.” Id. 

31. The Trustee has not abided by the foregoing terms of the Protective Order as she 

has failed to serve Defendants with a written objection to any such “Confidential” designation. 

Accordingly, Defendants request that in the event the Court grants the Trustee leave to amend, that 

the Trustee be required to redact information previously designated as Confidential until such time 

as the Trustee has abided by the terms and procedures set forth in the Protective Order. 

D. If the Court Agrees to Extend the Trial Date and Pre-Trial Deadlines, A Period Greater 

Than Three Months Will Be Needed 

32. In the event the Court grants the Motion to Amend, the Trustee requests a “modest 

extension [of three months] to the pretrial schedule and trial date”. (Motion to Amend, ¶ 24). 

While the Defendants eagerly await their day in court so that they may be able to present evidence 

that will contradict many of the loaded and baseless allegations asserted by the Trustee in the 

Complaint (and Amended Complaint, as applicable), as the Trustee noted herself, the addition of 

new parties and new claims will warrant significant additional discovery and a re-review of certain 

previous discovery. The Trustee has added new paragraphs of allegations in the Amended 

Complaint, has added new parties, and has added new counts against those parties. 

Additionally, a three month continuance will not suffice in light of anticipated motions practice, 

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delays in discovery, and the fact that no depositions have been taken. Further, as noted above, 

Defendants’ lead counsel has a three to four week trial scheduled to begin in California state court 

on January 23, 2022. Accordingly, and without prejudice to the views that may be expressed on 

this issue by , Defendants respectfully request that trial be continued from its current 

October date. 

33. Before setting a new trial date, however, the Defendants respectfully request that 

the Trustee be asked to confirm whether she intends to seek leave to add any additional defendants 

to the litigation. In her interrogatory responses, the Trustee identified 

. To date, however, the Trustee has 

only sought to add to this litigation. Yet in light of the Trustee identifying 

 back in February 2020, and the Trustee’s recently filed “Consent 

Order Granting Relief from the Automatic Stay and Establishing Procedures for Access to 

Proceeds of Insurance Policy” [Bankruptcy Case Docket No. 965] in which the Trustee confirms 

that she has sent written demand letters to certain of the Debtor’s former attorneys and that she has 

agreed to the advancement of certain insurance proceeds to such former attorneys in defense of the 

Trustee’s claims, the Defendants query whether, several months from now, the Trustee will seek 

leave again to further amend the Amended Complaint (should the Court permit it) to add 

 as defendants in this action. Defendants reserve all rights with respect to 

this issue.

34. Alternatively, in the event the Court does not grant the Trustee leave to amend the 

complaint, Defendants nevertheless request a continuance of the trial date. UnitedLex and ULXP 

have not yet filed an Answer in this case, depositions have not yet occurred, and the Trustee has 

indicated that she will soon be producing additional documents to Defendants as noted at the July 

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2021 omnibus hearing. Under the current Pre-Trial Scheduling Order, however, the parties are 

required to designate experts no later than August 26, 2021, dispositive motions are due September 

20, 2021, and discovery is due to close on October 4, 2021. Accordingly, the Defendants 

respectfully request that in the event the parties are to proceed with the original Complaint, that 

the Court continue the current October trial date and that the Pre-Trial Scheduling Order be 

adjusted accordingly. 

35. Defendants are prepared to confer with the Trustee’s counsel, and 

counsel if appropriate, with respect to an appropriate new proposed trial date and Pre-Trial Order. 

CONCLUSION 

WHEREFORE, the Defendants respectfully request that the Court deny the Motion to 

Amend, proceed to continue the trial in this matter, and modify the Pre-Trial Scheduling Order 

accordingly. Should the Court decide to grant the Motion to Amend, however, the Defendants 

respectfully request that the Court direct the Trustee to (i) strike those portions of the Amended 

Complaint that 

 and (ii) redact the parts of the 

Amended Complaint that quote or otherwise summarize communications provided by the 

Defendants in discovery that were designated as “Confidential”. In addition, should the Court 

decide to grant the Trustee’s request for an extension of the deadlines and trial date set forth in the 

Pretrial Order and Second Pretrial Order, respectively, the Defendants request that the parties be 

given an opportunity to confer on an adjusted schedule to provide to the Court. 

Dated: August 16, 2021 /s/ Thomas J. McKee, Jr. 

David G. Barger (VSB No. 21652) 

Thomas J. McKee, Jr. (VSB No. 68427) 

Greenberg Traurig, LLP 

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1750 Tysons Boulevard, Suite 1000 

McLean, Virginia 22102 

Telephone: (703) 749-1300 

Facsimile: (703) 749-1301 

Email: bargerd@gtlaw.com 

 mckeet@gtlaw.com 

and 

J. Gregory Milmoe (admitted pro hac vice) 

Greenberg Traurig, LLP 

One International Place, Suite 2000 

Boston, MA 02110 

Telephone: (617) 310-6064 

Email: milmoeg@gtlaw.com 

Counsel to ULX Partners, LLC 

and UnitedLex Corporation 

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CERTIFICATE OF SERVICE

 I hereby certify that on this 16th day of August, 2021, I caused a true and correct copy of 

Defendants’ Objection to Trustee’s Motion for Leave to Amend Complaint and to Modify Pretrial 

Scheduling Order to be served on Ms. Lynn L. Tavenner, as the Chapter 7 Trustee of LeClairRyan 

PLLC, c/o Quinn Emanuel Urquhart & Sullivan LLP, as the Trustee’s special litigation counsel, 

via electronic mail to: Erika L. Morabito (erikamorabito@quinnemanuel.com) and Brittany J. 

Nelson (brittanynelson@quinnemanuel.com). An unredacted copy has also been emailed to Ms. 

Morabito and Ms. Quinn. 

/s/ Thomas J. McKee, Jr. 

Thomas J. McKee, Jr. (VSB No. 68427) 

Greenberg Traurig, LLP 

1750 Tysons Boulevard, Suite 1000 

McLean, Virginia 22102 

Telephone: (703) 749-1300 

Facsimile: (703) 749-1301 

Email: mckeet@gtlaw.com 

Counsel to ULX Partners, LLC 

and UnitedLex Corporation

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