Charles H Krumbein, (VSB NO 01234)

Krumbein & Associates, PLLC

1650 Willow Lawn Drive Ste 201

Richmond, Va 23230

804 673 4358

charlesh@krumbein.com

IN THE UNITED STATES BANKRUPTCY COURT

FOR THE EASTERN DISTRICT OF VIRGINIA

RICHMOND DIVISION

IN RE CASE NO 17-34078 KRH

POTOMAC PILE DRIVE LLC

DEBTOR

PETER BARRETT, TRUSTEE

Plaintiff ADV Pro- 19-03079 KRH

V

Robin McCormack,

Shoreline Service & Design LLC

Brad Martin

Potomac Pile Driver LLC

APD3 LLC and

Jacob Lillard 

Defendants

NOTICE OF MOTION TO WITHDRAW REPRESENTATION

PLEASE TAKE NOTICE THAT the following document was filed with 

the Court: Motion TO WITHDRAW REPRESENTATION.

Your rights may be affected. You should read these papers 

carefully and discuss them with your attorney, if you have one 

in this bankruptcy case. (If you do not have an attorney, you 

may wish to consult one.) If you do not want the Court to grant 

the relief sought in the Motion, or if you want the Court to 

consider your views on the Motion, then on or before April 15, 

2020, you or your attorney must:

Case 19-03079-KRH Doc 59 Filed 04/01/20 Entered 04/01/20 12:25:50 Desc Main

Document Page 1 of 6
1. File with the Court, at the address shown below, a written 

response pursuant to Local Bankruptcy 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 before the 

deadline shown above. Mail your objection or comments to:

(1) Clerk of the Court

United States Bankruptcy Court

701 East Broad Street

Richmond, VA 23219

YOU MUST ALSO:

2. Mail a copy to:

Charles H Krumbein, Esq.

Krumbein & Associates, PLLC

1650 Willow Lawn Dr STE 201

Richmond, Va 23230

3. Attend a hearing on April 15,2020 at 12:00PM at 701 East 

Broad Street, Courtroom 5000, Richmond, VA 23219. You must 

attend the hearing in addition to filing a written objection to 

the Motion. If you fail to file timely a written response or 

attend the hearing, the Court may consider any objection

you may have waived and award the relief requested.

Date: April 1, 2020

/S/ Charles H Krumbein

Charles H Krumbein, (VSB NO 01234)

Krumbein & Associates, PLLC

1650 Willow Lawn Drive Ste 201

Richmond, Va 23230

804 673 4358

charlesh@krumbein.com

Certificate of Service

This day the undersigned certifies that a true copy of this 

Motion to Withdraw Representation was sent by CM/ECF and 

delivered to the Movant Peter Barrett and Jeremy Williams.

February 28, 2020, and Robin McCormack and Shoreline Service & 

Design LLC.

/S/ Charles H Krumbein

Charles H Krumbein, Esq. 

Case 19-03079-KRH Doc 59 Filed 04/01/20 Entered 04/01/20 12:25:50 Desc Main

Document Page 2 of 6
By first class US Mail 

Robin McCormack, and 

Shoreline Services and Design, LLC.

214 Marshall Ave

Colonial Beach Va 22443

Case 19-03079-KRH Doc 59 Filed 04/01/20 Entered 04/01/20 12:25:50 Desc Main

Document Page 3 of 6
Charles H Krumbein, (VSB NO 01234)

Krumbein & Associates, PLLC

1650 Willow Lawn Drive Ste 201

Richmond, Va 23230

804 673 4358

charlesh@krumbein.com

IN THE UNITED STATES BANKRUPTCY COURT

FOR THE EASTERN DISTRICT OF VIRGINIA

RICHMOND DIVISION

IN RE CASE NO 17-34078 KRH

POTOMAC PILE DRIVE LLC

DEBTOR

PETER BARRETT, TRUSTEE

Plaintiff ADV Pro- 19-03079 KRH

V

Robin McCormack,

Shoreline Service & Design LLC

Brad Martin

Potomac Pile Driver LLC

APD3 LLC and

Jacob Lillard 

Defendants

Motion to Withdraw Representation

This day comes Charles H Krumbein, Counsel of record for Robin 

McCormack and her corporation Shoreline Service & Design LLC and 

moves this court to allow said counsel to withdraw his 

representation of these parties. 

Counsel and his clients have irreconcilable differences and to 

the conduct of this representation such that Counsel is unable 

to complete his responsibilities.

Accordingly ,Counsel preys that this court allow Counsel be 

allow to withdraw as representative of these parties in this 

matter before the court.

Date: April 1, 2020

Case 19-03079-KRH Doc 59 Filed 04/01/20 Entered 04/01/20 12:25:50 Desc Main

Document Page 4 of 6
/S/ Charles H Krumbein

Charles H Krumbein, (VSB NO 01234)

Krumbein & Associates, PLLC

1650 Willow Lawn Drive Ste 201

Richmond, Va 23230

804 673 4358

charlesh@krumbein.com

Certificate of Service

This day the undersigned certifies that a true copy of this 

Motion to Withdraw Representation was sent by CM/ECF and 

delivered to the Movant Peter Barrett and Jeremy Williams.

February 28, 2020 and Robin McCormack and Shoreline Service & 

Design LLC.

/S/ Charles H Krumbein

Charles H Krumbein, Esq. 

Served By US Mail 

Robin McCormack, and 

Shoreline Services and Design, LLC.

214 Marshall Ave

Colonial Beach Va 22443

Case 19-03079-KRH Doc 59 Filed 04/01/20 Entered 04/01/20 12:25:50 Desc Main

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Case 19-03079-KRH Doc 59 Filed 04/01/20 Entered 04/01/20 12:25:50 Desc Main

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