UNITED STATES BANKRUPTCY COURT

FOR THE EASTERN DISTRICT OF VIRGINIA

Alexandria Division

____________________________________

]

In re: ]

]

SURESH VENKAT DOKI, ] Case No. 19-11503-KHK

] (Chapter 11)

Debtor ]

____________________________________]

MOTION FOR LEAVE TO WITHDRAW AS DEBTOR’S COUNSEL

TO THE HONORABLE KLINETTE H. KINDRED, BANKRUPTCY JUDGE:

COMES NOW the Law Offices of Jeffrey M. Sherman (“Attorneys”), currently counsel of 

record for Suresh Venkat Doki (“Debtor”), and as its Motion for Leave to Withdraw as Debtor’s

Counsel (“Motion”), respectfully represents as follows:

1. The Attorneys filed their application for approval of their retention as Debtor’s

counsel on June 2, 2019 (Docket No. 24). An order approving the retention was recently entered

by the Court.

2. Pursuant to LBR 2090-1(G), counsel of record may not withdraw their appearance 

except “for cause, on order of the Court after reasonable notice to the party on whose behalf the 

attorney has appeared....”

3. The Attorneys wish to withdraw from the representation of the Debtor, and have 

their appearance on his behalf stricken from the record of this case, for cause: (a) the working 

relationship between the Debtor and the Attorneys has deteriorated to the point where it is 

unmanageable, and has compromised the ability of the Attorneys to further render independent 

advice to the Debtor; and (b) other matters exist as to which full disclosure is barred by the 

attorney-client privilege.

4. The Debtor has indicated his consent to this withdrawal, and has also been advised, 

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by electronic communication on this date, that (a) he may proceed in this action, and in any other 

action related or associated with the parties or issues in this case, on a pro se basis, or (b) may seek 

to engage and retain substitute counsel for this case or any other related or associated proceedings, 

and as to such substitute counsel, the Attorneys would provide briefings and information on the 

known background and current state of this case, current issues, current procedural posture, and 

applicable deadlines, at no cost to the Debtor. 

5. The disappointing deterioration of the working relationship with the Debtor has left 

the Attorneys with no choice but to seek to withdraw, and thus, by this Motion, they seek leave to 

withdraw and to have their appearance on behalf of the Debtor stricken from this case.

6. The Attorneys reserve the right to seek compensation for services rendered and 

expenses incurred in the course of the representation of the Debtor herein, through the date of the 

withdrawal and striking of their appearance.

WHEREFORE, the Attorneys respectfully requests that the Court:

1. Grant this Motion;

2. Allow the Attorneys leave to withdraw from the further representation of the Debtor;

3. Striking the appearance of the Attorneys as counsel for the Debtor from the record of 

this case; and

4. Granting the Attorneys such other and further relief as is just and proper.

Dated: July 1, 2019 Respectfully submitted,

/S/ Jeffrey M. Sherman

Jeffrey M. Sherman, VSB 22424

LAW OFFICES OF JEFFREY M. SHERMAN

1600 N. Oak Street, #1826

Arlington, VA 22209

(703) 855-7394 (tel)

jeffreymsherman@gmail.com

Former Attorneys for the Debtor

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4

CERTIFICATE OF SERVICE

I hereby certify that a copy of the foregoing was served on July 1, 2019, by first class mail, postage 

prepaid, and, where available, by electronic transmission, upon the following:

Mary Joanne Dowd

Arent Fox LLP 

1717 K St., NW, 

Washington, DC 20006 

mary.dowd@arentfox.com 

Jack Frankel

Office of the U.S. Trustee 

1725 Duke Street, Suite 650 

Alexandria, VA 22314 

jack.i.frankel@usdoj.go

Suresh Venkat Doki

1013 Founders Ridge Lane 

Mc Lean, VA 22102 

FAIRFAX-VA 

/S/ Jeffrey M. Sherman

Jeffrey M. Sherman

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