Motion to Withdraw as Baron Counsel due to Fulfillment of Agreement

 
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OTION TO WITHDRAW – PAGE 1 OF 3 
Alan L. Busch 
Christopher M. Albert 
Busch, Ruotolo & Simpson, LLP 
100 Crescent Court, Suite 250 
Dallas, Texas 75201 
Telephone: (214) 855-2880 
Facsimile: (214) 855-2871 
E-mail: busch@buschllp.com 
E-mail: albert@buschllp.com 
Attorneys for Jeffrey Baron, Alleged Debtor
 
UNITED STATES BANKRUPTCY COURT 
NORTHERN DISTRICT OF TEXAS 
DALLAS DIVISION 
IN RE: 
§ 
 § 
JEFFREY BARON, 
§ 
Bankr. No. 12-37921-SGJ 
 § 
Alleged Debtor. 
§ 
 
 
 
MOTION TO WITHDRAW 
COME NOW Busch, Ruotolo & Simpson, LLP, Alan L. Busch, and Christopher M. 
Albert  (collectively "Counsel"), counsel of record for Jeffrey Baron, the Alleged Debtor in the 
above-styled case, who file this their Motion to Withdraw as counsel of record, and in support 
thereof, would show unto this Court s follows: 
1.   Counsel agreed to serve as counsel to the Alleged Debtor in his involuntary 
bankruptcy case on January 24, 2013.  Counsel was officially retained to serve as counsel for 
the Alleged Debtor when, on January 28, 2013, the Alleged Debtor signed the client 
agreement between himself and counsel, a true and correct copy of which is attached hereto 
as Exhibit “A”. 
2.  The client agreement identifies and limits the scope of Counsel’s engagement, 
and provides that Counsel would defend the Alleged Debtor in the involuntary proceeding 
above.  It expressly provides that Counsel’s responsibility to represent the Alleged Debtor is 
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OTION TO WITHDRAW – PAGE 2 OF 3 
limited to that which is identified in the agreement, that Counsel is not required to represent 
the Debtor in any bankruptcy proceeding following or resulting from the involuntary case, 
and that in the absence of a separate agreement to do so, Counsel is not required to undertake 
any representation of the debtor in bankruptcy beyond that of the involuntary.  The client 
agreement also states: 
Legal Representation by Busch Ruotolo & Simpson, LLP of Jeffrey Baron 
to defend the Client against an involuntary bankruptcy petition in the 
related adversary proceeding styled In re Jeffrey Baron, now pending before 
the United States Bankruptcy Court for the Northern District of Texas, 
Dallas Division, Case No. 12-37921-SGJ, but not representation of the 
Debtor in the event an order for relief is entered under 11 U.S.C. Section 
362. 
 
 
3.  On June 26, 2013, this Court entered its Findings and Conclusions concerning 
the trial of the involuntary bankruptcy case, and entered an Order for Relief [see Docket Nos. 
239 and 240], thus ending and terminating Counsel’s agreed engagement. 
4.  Inasmuch as the engagement between Counsel and the Alleged Debtor has 
ended by its terms, and inasmuch as Counsel did not agree to represent Mr. Baron in 
bankruptcy (nor did he agree for Counsel to serve in that capacity), withdrawal is probably 
unnecessary.  Nonetheless, in an abundance of propriety and clarity, Counsel seeks official 
leave to withdraw as counsel for Mr. Baron this cause for the reasons stated. 
WHEREFORE, PREMISES CONSIDERED, Counsel of record for Jeffrey Baron, 
respectfully pray that on final hearing hereof, this Court enter an order granting Counsel leave to 
withdraw as counsel of record in this cause, and granting such other and further relief to which 
Counsel may be justly entitled. 
 
 
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OTION TO WITHDRAW – PAGE 3 OF 3 
 
Respectfully submitted, 
Busch, Ruotolo & Simpson, L.L.P. 
 
 
By:  /s/ Alan L. Busch   
  Alan L. Busch 
State Bar No. 19408830 
Christopher M. Albert 
State Bar No. 24008550 
 
 
 
 
CERTIFICATE OF SERVICE 
 
  I hereby certify that on June 28, 2013, a true and correct copy of the foregoing document was 
sent by email to Jeffrey Baron; Lisa Lambert, Counsel for the United States Trustee; Gerrit 
Pronske, Counsel for the Petitioning Creditors, and upon all persons requesting notices via the 
ECF system. 
 
 
 
 
  /s/ Alan L. Busch   
  Alan L. Busch 
 
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