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, UnitedLex Corp., and ULX Manager, LLC 

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 

AMENDED NOTICE OF MOTION AND HEARING 

PLEASE TAKE NOTICE that ULX Partners, LLC (“ULXP”), UnitedLex Corporation 

(“UnitedLex”), and ULX Manager, LLC (“ULXM”) (collectively, the “Defendants”), have filed 

a Motion for Summary Judgment [Docket No. 133] (the “Motion”) in the above-captioned 

adversary proceeding, which was filed and served upon you on January 28, 2022. 

PLEASE TAKE FURTHER NOTICE that a copy of the Motion may be obtained for a 

fee at https://ecf.vaeb.uscourts.gov. 

PLEASE TAKE FURTHER NOTICE that your rights may be affected. You should 

read the Motion carefully and discuss it with your attorney, if you have one. (If you do not 

have an attorney, you may wish to consult one.)

Case 20-03142-KRH Doc 138 Filed 02/01/22 Entered 02/01/22 15:22:52 Desc Main

Document Page 1 of 4
PLEASE TAKE FURTHER NOTICE that if you do not want the Court to grant the relief 

requested in the Motion, or if you want the Court to consider your views on the Motion, then on 

or before February 11, 2022 (the “Objection Deadline”), you or your attorney must: 

 File with Court, either electronically or at the address shown below, a written 

response pursuant to 9013-1(H) of the Local Rules of the United States Bankruptcy 

Court for the Eastern District of Virginia. If you mail your written response to the 

Court for filing, you must mail it early enough so the Court will receive it on or 

before the Objection Deadline: 

 Clerk of the Court 

 United States Bankruptcy Court 

 701 East Broad Street 

 Suite 4000 

 Richmond, VA 23219 

 You must also serve a copy of your written response on the undersigned counsel so 

that it is received on or before the Objection Deadline. 

PLEASE TAKE FURTHER NOTICE that the Court will entertain the Motion at the 

upcoming omnibus hearing on February 17, 2021, at 1:00 p.m. (or such time thereafter as the 

matter may be heard. In connection with the same, the undersigned will appear before The 

Honorable Kevin R. Huennekens, United States Bankruptcy Judge. 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: 

Zoom registration link: 

https://www.zoomgov.com/meeting/register/vJIsfu6gpzMrHRBE47YWERHgxP8vk2BVTdI 

Listen-only conference line: 

Dial: 1-866-590-5055 

Access Code: 4377075 

Security Code: 21722 

If you or your attorney do not take these steps, including the filing and serving of a written 

response within the time period and in the manner set forth above, the Court may deem any 

opposition waived, treat the Motion as conceded, decide that you do not oppose the relief sought 

in the Motion and issue an order granting the relief requested without further notice or hearing. 

Dated: February 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 

Case 20-03142-KRH Doc 138 Filed 02/01/22 Entered 02/01/22 15:22:52 Desc Main

Document Page 2 of 4
McLean, Virginia 22102 

Telephone: (703) 749-1300 

Facsimile: (703) 749-1301 

Email: bargerd@gtlaw.com 

 mckeet@gtlaw.com 

Counsel to ULX Partners, LLC, UnitedLex 

Corporation, and ULX Manager, LLC 

 

Case 20-03142-KRH Doc 138 Filed 02/01/22 Entered 02/01/22 15:22:52 Desc Main

Document Page 3 of 4
CERTIFICATE OF SERVICE

 I hereby certify that on this 1st day of February 2022, I served a true and correct copy of 

the foregoing Notice of Motion and Hearing via the Court’s CM/ECF filing system upon all 

counsel of record. 

 

/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, UnitedLex 

Corporation, and ULX Manager, LLC

Case 20-03142-KRH Doc 138 Filed 02/01/22 Entered 02/01/22 15:22:52 Desc Main

Document Page 4 of 4