______________________________________

Kathryn R. Montgomery, AUST (VSB No. 42380)

Shannon Pecoraro, Esq. (VSB No. 46864)

Jason B. Shorter, Esq. (VSB No. 80929)

Office of the United States Trustee

701 East Broad Street, Suite 4304

Richmond, VA 23219

Telephone: (804) 771-2310

Facsimile: (704) 771-2330

IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE EASTERN DISTRICT OF VIRGINIA

Richmond Division

In re:

LECLAIRRYAN PLLC, 

Debtor.

________________

Lynn L. Tavenner, as Chapter 7 Trustee, 

 

 Plaintiff, 

v. 

ULX Partners, LLC, UnitedLex Corporation, 

and ULX Managers, LLC

 Defendants.

________________

Lynn L. Tavenner, as Chapter 7 Trustee, 

 

 Plaintiff, 

v. 

CVC Capital Partners, Daniel Reed, Nicholas 

Hinton, Josh Rosenfeld, P. Douglas Benson

 

Defendants.

Chapter 7

 Case No. 19-34574 (KRH)

 Adv. Proc. Nos. 20-03142 (KRH) 

 and 

 

 21-03095 (KRH).

NOTICE OF OBJECTION AND HEARING THEREON

PLEASE TAKE NOTICE THAT the United States Trustee has filed with the Court a

Supplemental Objection (the “Objection”) to the Chapter 7 Trustee’s Chapter 7 Trustee’s 

Sealed Motion (Main Dkt. 1328 and Dkt. 211 and Reed Dkt. 56) (collectively, the “9019 

Case 20-03142-KRH Doc 244 Filed 06/03/22 Entered 06/03/22 16:48:52 Desc Main

Document Page 1 of 3
2

Motion”).

1 The United States Trustee’s Objection is being filed under seal pending the Court’s 

ruling on the ULX Partners, LLC’s, UnitedLex Corporation’s, and ULX Manager, LLC’s 

Motion to Seal Settlement Agreement and Related Documents, Information and Hearings (Main

Dkt. 1325 and Dkt. 207) (the “Seal Motion”), originally heard on May 25, 2022, and continued 

until June 8, 2022 at 1 p.m. Thereafter, the Objection will be served as provided in any Order 

addressing the Seal Motion. 

Furthermore, a copy of the Objection may be received by any Person (as defined by

Section 101(41) of the Bankruptcy Code) holding a claim against the Estate evidenced by 

(i) a proof of claim, which claim is not otherwise subject to dispute pursuant to the 

Bankruptcy Code and/or the Bankruptcy Rules and/or (ii) an order of the Bankruptcy

Court, only upon written receipt by Paula S. Beran, Esquire at pberan@tb-lawfirm.com of

a commitment of any Person to keep such Motion confidential

Your rights may be affected. You should read these papers carefully and discuss them 

with your attorney, if you have one in this bankruptcy case. (If you do not have an attorney, you 

may wish to consult one.)

PLEASE TAKE FURTHER NOTICE that on September 4, 2019, the Court entered the 

Order Establishing Certain Notice, Case Management and Administrative Procedures [ECF No. 

38 in the main case] (the “Case Management Order”), which approved the Notice, Case 

Management, and Administrative Procedures attached as Exhibit 1 to the Case Management Order 

(the “Case Management Procedures”). The Case Management Procedures, among other things, 

prescribe the way Objections must be filed and served and set forth when certain hearings will be 

conducted. A copy of the Case Management Order may be obtained, free of charge, by written 

request to mckeet@gtlaw.com, or, for a fee, at http://ecf.vaeb.uscourts.gov.

(X) A hearing to consider the 9019 Motion and any objection thereto is 

scheduled for June 8, 2022, at 1:00 p.m., prevailing Eastern Time, before the 

Honorable Judge Kevin R. Huennekens. 

REMOTE HEARING INFORMATION: Due to the COVID−19 public health emergency, no 

in-person hearings are being held. This hearing will take place remotely through Zoom on the date 

and time scheduled herein. 

To appear at the hearing, you must use the following Zoom registration link: 

https://www.zoomgov.com/meeting/register/vJItc--rrz4jHfonPb6c3FARuCippfQvj4g

Listen-only conference line: 

Dial: 1-866-590-5055 

Access Code: 4377075 

Security Code: 6822

1 “Main Dkt.” refers to the docket in the main Bankruptcy Case. “Dkt.” refers to the docket in the United Lex 

Adversary Proceeding, while “Reed Dkt.” refers to the docket in the Reed Adversary Proceeding.

Case 20-03142-KRH Doc 244 Filed 06/03/22 Entered 06/03/22 16:48:52 Desc Main

Document Page 2 of 3
3

Respectfully Submitted,

Dated: June 3, 2022 JOHN P. FITZGERALD, III

Acting United States Trustee Region 4

By: /s/Kathryn R. Montgomery

Kathryn R. Montgomery (VSB 42380)

Assistant United States Trustee

Office of the United States Trustee

701 E. Broad St., Ste. 4304 

Richmond, VA 23219

Ph: (804) 771-2310

Fax: (804) 771-2330

Kathryn.Montgomery@usdoj.gov

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 3rd day of June, 2022, a true and correct copy of the 

foregoing document was served via first class mail and/or electronic mail upon: (i) all parties and 

counsel requesting service via the Court’s ECF system, (ii) the Defendants, (iii) the 20 largest 

unsecured creditors as listed on the Debtor’s schedules, (iv) the Service List as defined by the 

governing Case Management Order, (v) Foley & Lardner, (vi) all Persons identified in paragraph 

4 of the FAO Procedures Order, and (vii) counsel for the Chapter 7 Trustee. 

By: /s/ Kathryn R. Montgomery

Kathryn R. Montgomery, Esq. 

Case 20-03142-KRH Doc 244 Filed 06/03/22 Entered 06/03/22 16:48:52 Desc Main

Document Page 3 of 3