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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, 

vs. 

ULX Partners, LLC, UnitedLex 

Corporation, and ULX Manager, LLC 

 Defendants. 

Chapter 7 

Case No. 19-34574 (KRH) 

 Adv. Proc. No. 20-03142-KRH 

DEFENDANTS’ MOTION TO FILE PARTIALLY REDACTED OPPOSITION TO 

TRUSTEE’S MOTION TO AMEND

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

ULX Manager, LLC (“ULXM”) (collectively, the “ULX Entities” or “Defendants”), by and through 

their undersigned counsel, pursuant to Rule 9018 of the Federal Rules of Bankruptcy Procedure, 

hereby files this Motion to File Partially Redacted Opposition (the “Motion to Redact”), with respect 

to Defendants’ Opposition to the Trustee’s Motion to Amend the First Amended Complaint [Docket 

No. 169] (the “Opposition”). Defendants state the following in support of their Motion to Partially 

Redact. 

1. On February 11, 2022, the Trustee filed her Motion for Leave to Amend the First 

Amended Complaint [Docket No. 147] (the “Motion to Amend”), along with her Motion to File 

Document Under Seal [Docket No. 149] (the “Motion to Seal”), through which the Trustee seeks 

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leave to file a redacted version of her Motion to Amend and to file her proposed Second Amended 

Complaint under seal until the Court rules upon such motion. The Trustee provided Defendants with 

an unredacted version of the Motion to Amend and the proposed Second Amended Complaint. 

2. Without conceding whether the information the Trustee seeks to redact and/or seal is 

proper and reserving all rights with respect thereto, and in the event the Court grants the Trustee’s 

Motion to Seal, the Defendants seek to file their Opposition to the Trustee’s Motion to Amend in 

partially redacted form pending the Court’s ruling on the Trustee’s Motion to Seal so as not to 

prematurely disclose any information that the Court may order sealed, and because the Defendants’ 

Opposition includes reference to information, both in the opposition itself and in attached exhibits, 

that contain information that has been identified as, or derived from, confidential information. 

Accordingly, Defendants seek entry of a Proposed Order, attached hereto, authorizing the same. 

WHEREFORE, Defendants respectfully request that the Court grant this Motion to Partially 

Redact and allow the partially redacted filing of their Opposition to the Trustee’s Motion to Amend 

on the public docket until such further Order of this Court, and for such other relief as is just and 

proper. 

Dated: March 1, 2022 /s/ Thomas J. McKee, Jr. 

David G. Barger (VSB No. 21652) 

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: bargerd@gtlaw.com 

 mckeet@gtlaw.com 

and 

J. Gregory Milmoe (admitted pro hac vice) 

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Greenberg Traurig, LLP 

One International Place, Suite 2000 

Boston, MA 02110 

Telephone: (617) 310-6064 

Email: milmoeg@gtlaw.com 

Counsel to the ULX Entities

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CERTIFICATE OF SERVICE

 I hereby certify that on this 1st day of March, 2022, I caused a true and correct copy of the 

foregoing 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). 

/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 the ULX Entities

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