Amanda Erin DeBerry (VSB #83805)

Boleman Law Firm, P.C.

2104 W. Laburnum Avenue, Suite 201

P.O. Box 11588

Richmond, Virginia 23230-1588

Telephone (804) 358-9900

Counsel for Debtor

UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

RICHMOND DIVISION

In re: Unique Quanetta Greene Case No. 18-31824-KRH

Debtor Chapter 13

Debtor’s Address: 2422 Barton Avenue, Apt. A

 Richmond, Virginia 23222

Last Four Digits of Debtor’s SSN: xxx-xx-5452

 

NOTICE OF MOTION TO WITHDRAW AS COUNSEL AND NOTICE OF HEARING

Counsel for the Debtor, Unique Quanetta Greene, has filed a Motion to Withdraw 

as Counsel, asking that the Court permit the Boleman Law Firm, P.C., and its lawyers to 

withdraw as counsel of record in this Chapter 13 case. 

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

them with your attorney, if you have one.

NOTICE IS HEREBY GIVEN that a hearing thereon will be held on the 

above-referenced Motion at the United States Bankruptcy Court, in the Honorable 

Kevin R. Huennekens’s Courtroom, 701 E. Broad Street, Room 5000, Richmond, 

VA 23219-3515, on September 19, 2018, at 11:30 a.m.

If you want to be heard on this matter, then no later than three (3) days prior to 

the date of the hearing, you or your attorney must: 

1. File with the court, at the address below, a written response pursuant to 

Local Rule 9013-1(H). If you mail your response to the Court for filing, you 

must mail it early enough so that the Court will receive it on or before the 

date stated above.

Clerk of Court

 United States Bankruptcy Court

 701 East Broad Street, Suite 4000

 Richmond, VA 23219

2. You must also send a copy to:

Boleman Law Firm, P.C.

2104 Laburnum Ave., Suite 201

P.O. Box 11588

Richmond, VA 23230-1588

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If you or your attorney do not take these steps, the Court may decide that you do 

not oppose the relief sought in the Motion and may enter an Order granting that relief.

Dated: September 12, 2018

Respectfully Submitted,

BOLEMAN LAW FIRM, P.C.

By: /s/ Amanda Erin DeBerry

Amanda Erin DeBerry (VSB #83805)

Boleman Law Firm, P.C.

2104 W. Laburnum Avenue, Suite 201

P.O. Box 11588

Richmond, Virginia 23230-1588

Telephone (804) 358-9900

Counsel for Debtor

CERTIFICATE OF SERVICE

I certify that on September 12, 2018 I have transmitted a true copy of the 

foregoing document electronically through the Court’s CM/ECF system or by mail to the 

Debtor, Chapter 13 trustee, the United States trustee if other than by the electronic 

means provided for at Local Bankruptcy Rule 2002-1, and to all creditors and parties in 

interest on the mailing matrix attached hereto.

By: /s/ Amanda Erin DeBerry

 Counsel for Debtor

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UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

RICHMOND DIVISION

In re: Unique Quanetta Greene Case No. 18-31824-KRH

Debtor Chapter 13

MOTION TO WITHDRAW AS COUNSEL

Boleman Law Firm, P.C., (“Boleman”) hereby respectfully requests that the Court 

allow Boleman and each of its respective lawyers to withdraw as counsel of record for

Unique Quanetta Greene (the “Debtor”) based upon the following reasons: 

1. Debtor filed this case on April 5, 2018. 

2. Counsel has not been able to main communication with the Debtor, 

despite repeated attempts via phone, electronic mail, and regular first-class mail, and 

despite previous admonishments to Debtor of the importance of maintaining 

communications with counsel. 

3. Counsel believes continued representation of the Debtor under the 

circumstances would be in violation of the Rules of Professional Conduct, i.e., Rule 

1.2(c) and (d), Rule 1.3(a) and (b), Rule 1.4 (a), (b), and (c), and Rule 3.3(a).

4. Further, counsel believes Rule 1.16(a) and (b) require termination of the 

representation and requires that counsel seek leave to withdrawal.

WHEREFORE Boleman Law Firm, P.C., and its respective lawyers request that 

this Honorable Court enter an Order permitting the withdrawal as counsel of record and 

grant any further relief that the Court deems to be just and proper under the 

circumstances.

Amanda Erin DeBerry (VSB #83805)

Boleman Law Firm, P.C.

2104 W. Laburnum Avenue, Suite 201

P.O. Box 11588

Richmond, Virginia 23230-1588

Telephone (804) 358-9900

Counsel for Debtor

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Respectfully Submitted,

BOLEMAN LAW FIRM, P.C.

By: /s/ Amanda Erin DeBerry Amanda Erin DeBerry (VSB #83805)

Boleman Law Firm, P.C.

2104 W. Laburnum Avenue, Suite 201

P.O. Box 11588

Richmond, Virginia 23230-1588

Telephone (804) 358-9900

Counsel for Debtor

CERTIFICATE OF SERVICE

I certify that on September 12, 2018 I have transmitted a true copy of the 

foregoing document electronically through the Court’s CM/ECF system or by mail to the 

Debtor, Chapter 13 trustee, the United States trustee if other than by the electronic 

means provided for at Local Bankruptcy Rule 2002-1, and to all creditors and parties in 

interest on the mailing matrix attached hereto.

By: /s/ Amanda Erin DeBerry

 Counsel for Debtor

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American Credit Acceptance

961 E. Main Street, 2nd Floor

Spartanburg, SC 29302

Andover Place Apartments

2852 Fairfield Ave #B

Richmond, VA 23223

CALL Federal Credit Union

4605 Commerce Road

P.O. Box 26603

Richmond, VA 23261

Check City

Attn: Bankruptcy

2729 W. Broad Street, Suite B

Richmond, VA 23220

Cornerstone Acceptance

3741 S. Nova Rd

Port Orange, FL 32129

Genesis Properties, Inc.

Attn: Bankruptcy Dept

101 West Commerce Road, 2nd fl

Richmond, VA 23224

Great Richmond Rentals

2000 West Club Lane

Richmond, VA 23226

Henrico Federal Credit Union

8611 Dixon Powers Drive

Richmond, VA 23228

John Trexlar

2800 Buford Rd # 201

Richmond, VA 23235

Lafayette, Ayers & Whitlock

10160 Staples Mill Rd

Ste 105

Glen Allen, VA 23060

M&M Automotive

5414 Hull Street

Richmond, VA 23234

Peoples Advantage Credit Union

Re: Bankruptcy

P.O. Box 3180

Petersburg, VA 23805-3180

Rent-A-Wreck

8410 W Broad St

Henrico, VA 23294

River Trace FCU

6011 Staples Mill Rd

Henrico, VA 23228

Westlake Financial Services

Re: Bankruptcy

P.O. Box 76809

Los Angeles, CA 90076-0809

Yvonne Greene

2422 Barton Ave., Apt. A

Richmond, VA 23222

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