Erika L. Morabito (VA Bar No. 44369)

Brittany J. Nelson (VA Bar No. 81734) 

QUINN EMANUEL URQUHART & SULLIVAN, LLP

1300 I Street, NW, Suite 900

Washington, DC 20005

Telephone: (202) 538-8334

Special Counsel to the Chapter 7 Trustee

UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

RICHMOND DIVISION

In re:

LeClairRyan PLLC,

Debtor.1

Case No. 19-34574-KRH

Chapter 7

COVER SHEET FOR FIFTH INTERIM APPLICATION OF QUINN EMANUEL 

URQUHART & SULLIVAN, LLP AS SPECIAL COUNSEL TO THE TRUSTEE, FOR 

ALLOWANCE OF COMPENSATION AND REIMBURSEMENT OF EXPENSES 

INCURRED

General Information

Name of applicant: Quinn Emanuel Urquhart & Sullivan, LLP

Authorized to provide professional

services to: Lynn L. Tavenner, Chapter 7 Trustee

Date of bankruptcy filing: September 3, 2019

Date of retention order: July 1, 2021

Fifth Interim Period

Period for which compensation and

reimbursement sought: July 1, 2022 – August 31, 2022

Type of fee statement or application: Interim Application

Total hours billed: 87.90

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

 Total hourly fees requested: $112,747.602

 Blended hourly rate (all timekeepers): $1,282.68

 Total contingent fees requested: $14,000.00

 Total expenses requested: $476.89

2 This amount reflects a ten (10) percent discount off of Quinn’s standard hourly rates, as stated in the Retention

Application (defined below) and per entry of the Retention Order (defined below). 

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UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

RICHMOND DIVISION

In re:

LeClairRyan PLLC,

Debtor.1

Case No. 19-34574-KRH

Chapter 7

FIFTH INTERIM APPLICATION OF QUINN EMANUEL URQUHART & SULLIVAN, 

LLP AS SPECIAL COUNSEL TO THE TRUSTEE, FOR ALLOWANCE OF 

COMPENSATION AND REIMBURSEMENT OF EXPENSES INCURRED

Quinn Emanuel Urquhart & Sullivan, LLP (“Quinn”),special counsel to Lynn L. Tavenner,

and not individuallybut 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”), in the above-referenced Chapter 7 

case (the “Case”), respectfully represents:

I. INTRODUCTION

1. Quinn hereby submits this Fifth Interim Application (the “Application”) for 

interim allowance of compensation for professional services rendered and actual and necessary

expenses incurred by Quinn as special counsel to the Trustee for certain professional services in

the period July 1, 2022 through August 31, 2022 (the “Fifth Interim Period”) pursuant to sections

330 and 331 of chapter 11 of title 11 of the United States Code (the “Bankruptcy Code”),the 

Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”) and Rule 2016-1 of the United 

States Bankruptcy Court for the Eastern District of Virginia Local Bankruptcy Rules (the “Local

Rules”).

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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II. BACKGROUND 

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

chapter 11 of the Bankruptcy Code. Pursuant to §§ 1107 and 1108 of the Bankruptcy Code, the

Debtor was operating its business as a debtor-in-possession.

3. On September 12, 2019, the United States Trustee filed its Motion to Convert Case

to Chapter 7 (the “Motion to Convert”) and notice thereof [ECF No. 61]. At a hearing on

September 26, 2019, the Court denied the Motion to Convert. However, per agreement between

the Debtor, the United States Trustee, and ABL Alliance, LLP (the “Lender”) as stated in the

Order on Motion to Convert Case to Chapter 7, the Case was converted to a case under Chapter 7

of the Bankruptcy Code on October 4, 2019 [ECF No. 140].

4. On June 7, 2021, the Trustee filed Trustee’s Application to Retain and Employ

Quinn Emanuel Urquhart & Sullivan, LLP as Special Counsel [ECF No. 908] (the “Retention 

Application”). On June 28, 2021, the Court entered its Order Authorizing the Retention and

Employment of Quinn Emanuel Urquhart & Sullivan, LLP as Special Counsel [ECF No. 939] (the 

“Retention Order”), retroactive to May 18, 2021.

5. On August 2, 2022, the Trustee filed Trustee’s Supplemental Application to Retain 

and Employ Quinn Emanuel Urquhart & Sullivan, LLP as Special Counsel [ECF No. 1533] (the 

“Supplemental Application”). On September 2, 2022, the Court entered its Order Clarifying the 

Order Authorizing the Retention and Employment of Quinn Emanual Urquhart & Sullivan, LLP 

as Special Counsel [ECF No. 1568] (the “Supplemental Retention Order”), retroactive to July 

11, 2022. 

6. Pursuant to the Retention Application, the Retention Order, the Supplemental 

Retention Application, and the Supplemental Retention Order, the Estate will compensate Quinn

for administrative tasks on an hourly basis (the “Administrative Fees”). In addition, during the

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Litigation Phase (as defined in the Retention Application and Retention Order), the Estate will 

compensate Quinn, subject to the professional responsibility and other rules governing its practice, 

based on the total recoveries on claims or causes of action or the net value to the Estate of any

release of claims against the Estate (the “Recoveries”). Quinn shall receive thirty-five percent 

(35%) of the recoveries (the “Contingent Fees”). 

III. JURISDICTION, VENUE, AND PREDICATES FOR RELIEF

7. This Court has jurisdiction over this Application pursuant to 28 U.S.C. §§ 157 and

1334. This is a core proceeding within the meaning of 28 U.S.C. § 157(b)(2). Venue in this district

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

8. The predicates for the relief requested in this Application are sections 330, and 331

of the Bankruptcy Code, Bankruptcy Rule 2016, and Local Rule 2016-1.

IV. RELIEF REQUESTED 

9. By this Application, Quinn respectfully requests that the Court enter an order (a) for

interim allowance of reasonable compensation for certain of the actual, reasonable, and necessary

professional services that it has rendered as special counsel to the Trustee in this Case for the

Administrative Fees during the Fifth Interim Period in the amount of $112,747.60 (the “Interim 

Administrative Fees”)2; (b) for reimbursement of actual, reasonable and necessary expenses 

incurred in representing the Trustee during the Fifth Interim Period in the amount of $476.89; and 

(c) for payment of $14,000.00 for Contingent Fees.3

2

 This amount does not include numerous voluntary write-offs and other professional discounts totaling more than 

$31,000 provided by Quinn to the Trustee.

3 As will be described more fully in the forthcoming (a) the Eighth Notice of Proposed FAO Settlement s filed under 

seal, (b) the Notice of Filing Under Seal of Proposed FAO Settlements, and (c) future notices of settlement and/or

Bankruptcy Rule 9019 motions that may be filed in connection with future settlements requiring court approval, the

Estate may receive certain settlement payments after the date hereof. For the sake of clarity, in this Application, 

Quinn seeks payment of Contingent Fees only after the relevant settlements have been approved and the Estate has

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10. A summary schedule of compensation by timekeeper during the Fifth Interim

Period is attached hereto as Exhibit B. A summary schedule of hours and fees covered during the 

Fifth Interim Period, categorized by project code is attached hereto as Exhibit C.

4 A summary 

schedule of the expense reimbursements requested by category is attached hereto as Exhibit D. A 

chart containing information related to the recoveries related to FAO Actions is attached hereto as

Exhibit E.

5

V. BASIS FOR RELIEF REQUESTED

11. In addition to the contingency work for which Quinn is not seeking payment at

this time, during the Fifth Interim Period, Quinn provided the following non-exclusive services to,

and as requested by, the Trustee: (i) work related to protecting and preserving value for the 

Estate while the Trustee conducted extensive due diligence on what was in the Estate’s best 

interest to address the Judicially Mediated Global Settlement Appeal (as defined in the 

Supplemental Retention Order); (ii) attended Court hearings, including providing status reports 

to the Court; (iii) resolution of potential claims, including but not limited to, Chapter 5 claims,

fraudulent transfers, excessive compensation, breaches of fiduciary duty, and/or unjust

enrichment; (iv) made recommendations to the Trustee that included, among other things,

proposednext steps as it relates to the prosecution of some or all of the claims; and (v) settlement

(and related work thereto) of certain claims.

received the relevant settlement payments. In addition, with respect to future recoveries, Quinn reserves the right 

to apply for the payment of additional Contingent Fees for work that was performed during the Fifth Interim Period.

5 Pursuant to the Order Approving Procedures and Permitting Trustee to Prosecute and Compromise FAO Actions

[ECF No. 533] (the “Procedures Order”), Exhibit E will be filed separately under seal using the sealed document

docketing event in the ECF system pursuant to CM/ECF Policy 6. See Procedures Order ¶ 4.

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12. In performing the services detailed in this Application, Quinn has endeavored to

ensure that its professionals comply with the applicable provisions of the Bankruptcy Code, the

Bankruptcy Rules, the Local Rules, and any other applicable procedures or orders of the Court.

13. Quinn has not made any prior request for payment of professional fees earned and

expenses incurred and/or paid during the Fifth Interim Period. Except as provided in the Retention 

Application, the Retention Order, the Supplemental Retention Application, and the Supplemental 

Retention Order, Quinn has not received any payments on account of such fees or expenses.

14. In accordance with Bankruptcy Rule 2016 and Local Rule 2016-1, a detailed

chronological itemization of the services rendered by each professional and paraprofessional,

calculated by tenths of an hour and categorized in accordance with the appropriate project code

and a detailed chronological itemization of the expenses incurred by Quinn during the Fifth Interim

Period are attached hereto as Exhibit F.

15. Quinn has endeavored to represent the Trustee in the most expeditious and

economical manner possible. Tasks have been assigned to attorneys and paralegals at Quinn so

that the work has been performed by those most familiar with the particular matter or task and,

where attorney involvement was required, by the lowest hourly rate professional appropriate for a

particularmatter. Moreover, Quinn has endeavored to coordinate with other professionalsinvolved

in this Case so as to minimize any duplication of effort and to minimize attorneys’ fees and

expenses. Quinn believes it has been successful in this regard.

16. No agreement or understanding exists between Quinn and any other person for the

sharing of compensation received or to be received for services rendered in connection with this

Case.

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VI. NOTICE 

17. Notice of this Application has been provided to all necessary parties in accordance

with the Case Management Procedures and the Compensation Procedures. Quinn submits that no

other or further notice need be provided.

18. No previous application for the relief sought in this Application has been made to

this or any other court.

19. Quinn has reviewed the requirements of the Local Rules and certifies that this

Application complies with the applicable provisions of the Bankruptcy Code, Bankruptcy Rules,

and Local Rules.

WHEREFORE, Quinn hereby respectfully requests that this Court enter an order,

substantially in the form attached hereto as Exhibit A, (i) approving this Application; (ii) awarding 

Quinn, on an interim basis, Interim Administrative Fees in the amount of $112,747.60 and 

reimbursement of actual, reasonable, and necessary expenses incurred by Quinn during the Fifth

Interim Period in the amount of $476.89; (iv) awarding Quinn, on an interim basis, Contingent

Fees in the amount of $14,000.00; (v) authorizing the Trustee to pay Quinn the amount of Interim 

Administrative Fees and Contingent Fees approved by the Court, when the Trustee deems such 

funds are available; and (vi) granting such other relief as theCourt deems proper and just.

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Dated: September 7, 2022 Respectfully submitted,

/s/Erika L Morabito

Erika L. Morabito (VSB No. 44369)

Brittany J. Nelson (VSB No. 81734)

QUINN EMANUEL URQUHART

& SULLIVAN, LLP

1300 I Street, NW, Suite 900

Washington, DC 20005

(202) 538-8000 (telephone)

(202) 538-8100 (facsimile)

erikamorabito@quinnemanuel.com

Special Counsel to Lynn L. Tavenner, the Chapter 7

Trustee of the Estate of LeClairRyan PLLC

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CERTIFICATE OF SERVICE

I hereby certify that on the 7

th day of September 2022, I will cause a true copy of the 

foregoing Application to be served via first-class and/or electronic mail to Kathyrn Montgomery 

and/or Shannon F. Pecoraro, Esquire, Trial Attorney for the Office of the United States Trustee, 

and all parties receiving ECF notices. Notification of the filing of the Application and amounts 

sought therein will be served on (a) the Debtor’s 20 Largest Unsecured Creditors; (b) all known 

secured creditors from the Debtor’s Official Form 106D; (c) the Core Parties and 2002 List as 

defined in the Case Management Order; and (d) all parties requesting service of pleadings in this 

Case (as indicated on the Schedule A attached to the Court filed copy of said Application).

/s/ Erika L. Morabito

Special Counsel to the Chapter 7 Trustee

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