Amended Motion to Withdraw as Counsel of Record for Panthera Training, LLC — In re Panthera Enterprises, LLC, No. 2:19-bk-00787

Summary

An Amended Motion to Withdraw as Counsel of Record for Panthera Training, LLC, Doc 452, filed August 16, 2024, in In re Panthera Enterprises, LLC, Case No. 2:19-bk-00787, Chapter 7, in the U.S. Bankruptcy Court for the Northern District of West Virginia. Julia A. Chincheck, Zachary J. Rosencrance, Michael R. Proctor and the law firm of Bowles Rice LLP state that Bowles Rice was retained on October 8, 2019, that the retention agreement reserved the right to withdraw if timely payments were not made, and that no payments have been received for unpaid legal fees. A written certification attached as Exhibit A states that, as of August 9, 2024, Bowles Rice LLP had been unable to make direct contact with Panthera Training, LLC. It carries the signature text /s/ Zachary J. Rosencrance.

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Full text

17046489.1
IN THE UNITED STATES BANKRUPTCY COURT
FOR THE NORTHERN DISTRICT OF WEST VIRGINIA

In re:

PANTHERA ENTERPRISES, LLC,

Case No. 2:19-bk-00787

Chapter 7

Debtor.

AMENDED MOTION TO WITHDRAW AS COUNSEL
OF RECORD FOR PANTHERA TRAINING, LLC

COMES NOW, Julia A. Chincheck, Zachary J. Rosencrance, and Michael R.
Proctor, and the law firm of Bowles Rice LLP, attorneys for Panthera Training, LLC (“Panthera”)
in the above-referenced bankruptcy case, and moves this Honorable Court pursuant to Rule 1.16
(Declining or Terminating Representation) of the West Virginia Rules of Professional Conduct
and pursuant to Local Rule 2091-1(b)(2)(a)-(h) (Attorneys – Withdrawals) of the United States
Bankruptcy Court for the Northern District of West Virginia Local Rules, all notification
requirements have been met.
1.
The law firm of Bowles Rice was retained by Panthera on October 8, 2019,
to represent it in connection with the bankruptcy case of Panthera Enterprises, LLC.  According to
the retention agreement, Bowles Rice reserved the right to withdraw its representation if timely
payments were not made.
2.
Bowles Rice has contacted Panthera on numerous occasions via telephone
and email to collect monies due for unpaid legal fees.  Panthera indicated that they would be
sending payment to Bowles Rice.  As of this filing, no payments have been received.
No. 2:19-bk-00787    Doc 452    Filed 08/16/24    Entered 08/16/24 16:18:41    Page 1 of 5

2
17046489.1
3.
Panthera is aware of Bowles Rice LLP’s intention to withdraw from this
bankruptcy proceeding.
4.
Here, based upon good cause shown, counsel seek and order from this Court
relieving Julia A. Chincheck, Zachary J. Rosencrance, and Michael R. Proctor, and the law firm
of Bowles Rice LLP of their obligation to serve as counsel for Panthera in the above-referenced
bankruptcy case.
5.
Counsel have served Panthera a copy of this Motion.
6.
Panthera’s last known mailing address and telephone number is as follows:
Panthera Training, LLC
c/o Robert Starer
Post Office Box 981
Old Fields, West Virginia 26845
Telephone: 304-530-5555
7.
Pursuant to Local Rule 2091, all notification requirements have been met.
See, Written Certification attached hereto as Exhibit A.
WHEREFORE, the undersigned counsel prays for an Order from this Honorable
Court granting Julia A. Chincheck, Zachary J. Rosencrance, and Michael R. Proctor, and the law
firm of Bowles Rice LLP, leave to withdraw as counsel for Panthera Training, LLC in the above-

No. 2:19-bk-00787    Doc 452    Filed 08/16/24    Entered 08/16/24 16:18:41    Page 2 of 5

3
17046489.1
referenced bankruptcy proceeding, and for such other relief as this Honorable Court deems just
and proper.
PANTHERA TRAINING, LLC

By Counsel

/s/ Zachary J. Rosencrance

Zachary J. Rosencrance (WVSB #13040)
Michael J. Proctor (WVSB #9122)
BOWLES RICE LLP
600 Quarrier Street, Post Office Box 1386
Charleston, West Virginia 25325-1386
Telephone:  (304) 347-1100
Facsimile:   (304) 343-3058
E-mail:       zrosencrance@bowlesrice.com
E-mail:       mproctor@bowlesrice.com

No. 2:19-bk-00787    Doc 452    Filed 08/16/24    Entered 08/16/24 16:18:41    Page 3 of 5

EXHIBIT A

IN THE UNITED STATES BANKRUPTCY COURT
FOR THE NORTHERN DISTRICT OF WEST VIRGINIA

In re:

PANTHERA ENTERPRISES, LLC,

Case No. 2:19-bk-00787

Chapter 7

Debtor.

WRITTEN CERTIFICATION

1.
Pursuant to Local Rule 2091-1(b)(2)(a)-(h), Bowles Rice LLP has made all
required noticed thereunder via email correspondence sent to Douglas Kahle c/o Panthera
Training, LLC.
2.
Additionally, Bowles Rice LLP has advised Panthera Training that the
effective date of Bowles Rice LLP’s withdrawal begins upon entry of an order granting the Motion
to Withdraw as Counsel.
3.
Bowles Rice LLP attempted to follow up via telephone to confirm receipt
of the email correspondence; however, as of August 9, 2024 Bowles Rice LLP has been unable to
make direct contact with Panthera Training, LLC.
PANTHERA TRAINING, LLC

By Counsel

/s/ Zachary J. Rosencrance

Zachary J. Rosencrance (WVSB #13040)
Michael J. Proctor (WVSB #9122)
BOWLES RICE LLP
600 Quarrier Street, Post Office Box 1386
Charleston, West Virginia 25325-1386
Telephone:  (304) 347-1100
Facsimile:   (304) 343-3058
E-mail:       zrosencrance@bowlesrice.com
E-mail:       mproctor@bowlesrice.com
16310841.1
No. 2:19-bk-00787    Doc 452    Filed 08/16/24    Entered 08/16/24 16:18:41    Page 4 of 5

17046489.1
IN THE UNITED STATES BANKRUPTCY COURT
FOR THE NORTHERN DISTRICT OF WEST VIRGINIA

In re:

PANTHERA ENTERPRISES, LLC,

Case No. 2:19-bk-00787

Chapter 7

Debtor.

CERTIFICATE OF SERVICE

I, Zachary J. Rosencrance, do hereby certify that a true and correct copy of the
Amended Motion to Withdraw as Counsel of Record for Panthera Training, LLC and
proposed Order Granting Amended Motion to Withdraw as Counsel of Record for Panthera
Training, LLC have been served on all parties registered to receive notices by the Court’s ECF
System in this case, on this the 16th day of August, 2024.
The undersigned, counsel of record for Panthera Training, LLC, does hereby further
certify on this 16th day of August, 2024, that a true copy of the foregoing Amended Motion to
Withdraw as Counsel of Record for Panthera Training, LLC and proposed Order Granting
Amended Motion to Withdraw as Counsel of Record for Panthera Training, LLC was served
upon Panthera Training, LLC, at the following address:
Panthera Training, LLC
c/o Robert Starer
Post Office Box 981
Old Fields, West Virginia 26845
/s/ Zachary J. Rosencrance

Zachary J. Rosencrance (WVSB #13040)

No. 2:19-bk-00787    Doc 452    Filed 08/16/24    Entered 08/16/24 16:18:41    Page 5 of 5

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