Harmon
Debtor, Pro Se
UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF HAWAII
In re | Case No. 99-04339
| (Chapter 7)
et al. |
dba | DEBTOR’S
ORBITS HAWAII, | OPPOSITION TO MOTION TO
| WITHDRAW AS ATTORNEYS;
Debtors. | EXHIBITS A - J;
| CERTIFICATE OF SERVICE
|
| DATE: February 22, 2001
| TIME: 9:30 a.m.
| JUDGE: Honorable Lloyd King
____________________________________|
DEBTOR HARMON’S OPPOSITION TO MOTION TO WITHDRAW AS ATTORNEYS FOR DEBTOR
COMES NOW Debtor HARMON and submits this written Opposition to Motion to Withdraw as Attorneys for Debtor. Debtor interposes this opposition for the following reasons:1.I do not concur with BRADLEY R. TAMM’s statement that I have been insistent on a course of action that is inappropriate, or that this has led to irreconcilable differences between the client and counsel. I have simply asked for information which I believe is material to this case and to which I may be entitled. To provide evidence of this, copies of correspondence between Mr. Tamm and myself are attached as EXHIBITS A - J.
2. I have requested information regarding two primary issues of concern that have not yet been fully answered. The first issue is my belief that TORKILDSON, KATZ, FONSECA, JAFFE, MOORE & HETHERINGTON, a Law Corporation, may have had a conflict of interest and/or made material misrepresentations during the settlement negotiations in this case. TORKILDSON, KATZ were defendants in CIVIL NO. 99-00304 DAE, and were also the Attorneys for P&C INSURANCE COMPANY; HENRY H. PETERS, RICHARD S.H. WONG, LOKELANI LINDSEY, GERARD JERVIS AND OSWALD STENDER, TRUSTEES OF BISHOP ESTATE; NATHAN AIPA; LOUANNE KAM; RODNEY PARK; WILLIAM S. RICHARDSON; GILBERT TAM; and PETER LOWE, and had indicated they were acting on behalf of FEDERAL INSURANCE COMPANY, another named defendant in CIVIL NO. 99-00304 DAE, in related lawsuits. The second issue discussed with Mr. Tamm concerned the W-2 Tax Form, or Form 1099, which I have not yet received. During the settlement negotiations, it was stated by Mr. Tamm that the entire settlement amount would be characterized as Wage Income. As wage income, my understanding is that the employer must provide a W-2 Form, and indicate the amount of Social Security and other taxes withheld and/or paid. This tax form is needed for the preparation and filing of my Year 2000 income tax, and for filing for Social Security Benefits, which I am currently preparing to do.
3. The timing of this Motion is inappropriate and results in undue hardship to the client. I have had to relocate to Kentucky in order to care for my ailing mother and to attempt to find a new home, having lost our home in Hawaii due to the bankruptcy settlement. I have not requested that Mr. Tamm file any legal motions or take other legal action. I believe that it would result in undue hardship and expense for me to seek, retain and provide documentation to a new attorney at this time merely to obtain documents regarding the bankruptcy proceedings in which Mr. Tamm participated as my attorney.
DATED: January 31, 2001
_____________________________
BOBBY NORRIS HARMON,
Debtor Pro Se
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