IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE EASTERN DISTRICT OF VIRGINIA 

(Richmond Division) 

Chapter 7 

Case No. 19-34574 (KRH) 

Adv. Proc. No. 20-03142 (KRH) 

AGREED STIPULATION AND ORDER 

The Parties, plaintiff Lynn L. Tavenner, as Chapter 7 Trustee (the “Plaintiff”) and 

defendants ULX Partners, LLC and UnitedLex Corporation (collectively, the “Defendants”), 

by their respective counsel, and subject to approval by the Court, stipulate and agree to the 

following: 

1. On July 20, 2021, this Court entered an Order [Docket No. 58] requiring the 

Defendants to file their Answer(s) to the original Complaint [Docket No. 4] (the “Original 

Complaint”) in this matter no later than August 10, 2021 (the “Answer Order”). 

2. On July 22, 2021, counsel for the Plaintiff informed the Defendants and this 

Court that the Plaintiff intends to file a Motion for Leave to File an Amended Complaint in this 

In re: 

LeClairRyan PLLC, 

Debtor. 

________________________________ 

Lynn L. Tavenner, as Chapter 7 Trustee, 

Plaintiff, 

v. 

ULX Partners, LLC and UnitedLex 

Corporation, 

Defendants. 

Case 20-03142-KRH Doc 64 Filed 07/30/21 Entered 07/30/21 17:40:31 Desc Main

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matter (the “Anticipated Motion for Leave”) in order for such motion to be heard by this 

Court at the next Omnibus Hearing of August 19, 2021. 

3. In light of the Anticipated Motion for Leave, the Parties agree, subject to the 

Court’s approval, that the Defendants’ deadline to file their answer(s) to the Original Complaint 

as set forth in the Answer Order is vacated and that the following shall instead apply: 

i. In the event the Plaintiff opts against filing the Anticipated Motion for Leave, 

then the Plaintiff shall file a Notice of Answer Deadline with the Court 

indicating that Defendants will file their answer(s) to the Original Complaint no 

later than August 24, 2021. 

ii. In the event the Plaintiff files the Anticipated Motion for Leave and the Court 

denies such Motion, leaving the Original Complaint as the operative complaint 

in this matter, then Defendants shall file their answer(s) to the Original 

Complaint no later than fourteen (14) calendar days after entry of the Court’s 

Order denying the Anticipated Motion for Leave. 

iii. In the event the Plaintiff files the Anticipated Motion for Leave and the Court 

grants such Motion permitting the filing of an Amended Complaint, or if 

Defendants and/or their counsel consent in writing to the relief requested in the 

Anticipated Motion on or before August 5, 2021 (the “Written Consent”), then 

Defendants shall file (i) their answer(s) to the Amended Complaint or (ii) any 

other response to the Amended Complaint as permitted by the Bankruptcy 

Code, any rule, statute, or as otherwise authorized by the Bankruptcy Court, no 

later than twenty-one (21) calendar days after either the entry of the Court’s 

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Order granting the Anticipated Motion for Leave or the Written Consent, or by 

such other time as may be ordered by the Court. 

Dated: July 30, 2021 

Respectfully submitted, 

_/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) 

Greenberg Traurig, LLP 

One International Place, Suite 2000 

Boston, MA 02110 

Telephone: (617) 310-6064 

Email: milmoeg@gtlaw.com 

Counsel to Defendants

_/s/ Erika L. Morabito__________________ 

Erika L. Morabito (VSB No. 44369) 

Brittany J. Nelson (VSB No. 81734) 

QUINN EMANUEL URQUHART & 

SULLIVAN LLP 

1300 I Street, N.W., Suite 900 

Washington, DC 20005 

Telephone: (202) 538-8334 

Email: erikamorabito@quinnemanuel.com 

 brittanynelson@quinnemanuel.com 

Special Counsel to Plaintiff

SO ORDERED, this _____ day of ____________, 2021: 

____________________________________ 

THE HONORABLE KEVIN R. HUENNEKENS 

UNITED STATES BANKRUPTCY JUDGE 

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LOCAL BANKRUPTCY RULE 9022-1(C) CERTIFICATION 

 I hereby certify that the foregoing has either been endorsed by or served upon all 

necessary parties. 

_/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 Defendants 

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