IN THE UNITED STATES BANKRUPTCY COURT

FOR THE EASTERN DISTRICT OF VIRGINIA

Norfolk Division

In re: Jacqueline Michelle Lennon, )

)

CAROLYN L. CAMARDO, ) Case No.: 13-74773-FJS

) Chapter: 7

Plaintiff, )

v. ) Adversary Proceeding No. 15-07108-FJS

)

JACQUELINE MICHELLE LENNON, )

)

Defendant. )

)

MOTION TO WITHDRAW

COMES NOW Kristi L. Johnson (“Movant”), and, pursuant to Local Bankruptcy Rule 

2090-1(G), moves for an order to withdraw as counsel for Jacqueline M. Lennon (“Debtor”) in the 

above-captioned action. In support of this motion, Movant states as follows:

1. For reasons Movant cannot disclose by virtue of the attorney-client privilege that 

exists between Debtor and Movant, Movant is unable to further represent Debtor. In addition, 

Debtor, who never paid any fees associated with representation, has repeatedly and consistently

failed or refused to communicate or cooperate with Movant concerning matters critical to this case

for several months, resulting in an “impasse in necessary communication and cooperation between 

counsel and client that precludes effective representation on a continuing basis.” NGM Ins. Co. v. 

Secured Title & Abstract, Inc., No. 3:07CV536, 2008 U.S. Dist. LEXIS 33478, at *4, 2008 WL 

1826032, at *1 (E.D. Va. Apr. 23, 2008).

2. As this adversarial proceeding is in its beginning stages and no trial date has been 

set, this withdrawal can be effected without material prejudice to Debtor.

Case 15-07108-FJS Doc 7 Filed 12/23/15 Entered 12/23/15 20:07:03 Desc Main

 Document Page 1 of 3
2

3. Debtor has received notice of counsel’s intention to seek withdrawal of 

representation, and has been provided with notice as to this Motion, and any hearing thereon, in 

accordance with Local Bankruptcy Rule 9013-1 and any other applicable rules of this Court.

Though notice was provided, for the first time, more than nine months prior to filing this Motion,

Debtor has never expressed any objection to Movant’s intention to seek withdrawal from 

representation.

WHEREFORE, for the foregoing reasons, Movant respectfully requests that this 

Honorable Court enter an Order granting this Motion to Withdraw as counsel for Debtor, 

withdrawing Counsel’s appearance for Debtor in the above-captioned underlying and adversarial 

proceedings, and granting such other and further relief the Court deems appropriate. 

Dated: December 23, 2015 Respectfully submitted,

By: /s/ Kristi L. Johson

Kristi L. Johnson, VSB No. 77776

5055 Seminary Road, #938 

Alexandria, VA 22311 

Phone: (757) 593-1980

Counsel for Debtor

Case 15-07108-FJS Doc 7 Filed 12/23/15 Entered 12/23/15 20:07:03 Desc Main

 Document Page 2 of 3
3

CERTIFICATE OF SERVICE

I hereby certify that on this 23rd day of December, 2015, a true and accurate copy of the 

foregoing Motion to Withdraw, together with a copy of the Notice of Electronic filing associated 

herewith, was served by email, U.S. first class mail, and certified mail, postage prepaid, on:

Jacqueline M. Lennon

404 S. Rosemont Road

Virginia Beach, VA 23452

jalennon@portfoliorecovery.com

wintersgammy@gmail.com

 /s/ Kristi L. Johnson

Kristi L. Johnson, VSB No. 77776

5055 Seminary Road, #938 

Alexandria, VA 22311 

Phone: (757) 593-1980

Counsel for Debtor

Case 15-07108-FJS Doc 7 Filed 12/23/15 Entered 12/23/15 20:07:03 Desc Main

 Document Page 3 of 3