MOTION to Withdraw as Attorney by Zeljka Bozanic for / by Andre Lorquet — Andre Lorquet (Dkt. 56)

Summary

A Motion to Withdraw as Counsel of Record filed by Zeljka Bozanic, Esq. for defendant Andre Lorquet in United States of America v. Andre Lorquet, No. 22-cr-20326-KMM, in the U.S. District Court for the Southern District of Florida. The motion states that Mr. Lorquet was indicted on July 22, 2022, pleaded guilty before Magistrate Judge Louis on January 24, 2023, and has since asked counsel to file a motion to withdraw his plea. It states that his reasons include challenging the effectiveness of assistance of counsel and alleging duress, and that counsel believes the Rules of Professional Responsibility prohibit continuing the representation. The motion asks the Court to appoint counsel for Mr. Lorquet, and states that AUSA Jonathan Bailyn takes no position under Local Rule 88.9. Its certificate of service is dated March 13, 2023.

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                              UNITED STATES DISTRICT COURT
                              SOUTHERN DISTRICT OF FLORIDA

                                   CASE NO.: 22-cr-20326-KMM

UNITED STATES OF AMERICA
         Plaintiff,
vs.

ANDRE LORQUET,
         Defendant.
                                           /


                   MOTION TO WITHDRAW AS COUNSEL OF RECORD

       COMES NOW, Zeljka Bozanic, Esq. and hereby moves to withdraw as counsel of record

for the defendant, Andre Lorquet. As grounds in support thereof the defense would state the

following:

       1. On July 22, 2022, Mr. Lorquet was indicted and charged with four counts of Wire

             Fraud, four counts of Money Laundering and one count of Aggravated Identity Theft.

       2. On November 17, 2022, the undersigned filed a Notice of Appearance in this case.

       3. On January 24, 2023, Mr. Lorquet plead guilty before Magistrate Judge Louis.

       4. Since taking the plea, Mr. Lorquet has asked the undersigned to file a motion to

             withdraw his plea.

       5. Some of the reasons for Mr. Lorquet’s request to withdraw the plea are challenging

             the effectiveness of assistance of counsel he has received and allege duress. Mr.

             Lorquet states that he believed that he was signing bond paperwork for his release,

             when he in fact signed a plea agreement.

       6. The undersigned believes that there is a conflict of interest and that the Rules of

             Professional Responsibility prohibit her from continuing this representation.




                                                  1
       7. The undersigned has filed a Motion to Withdraw Plea on behalf of Mr. Lorquet in a

           separate filing.

       8. The undersigned respectfully requests that the Court grant this motion to Withdraw

           and appoint counsel for Mr. Lorquet who could effectively represent him in his

           Motion to Withdraw Plea and in the case.

       9. Pursuant to Local Rule 88.9, undersigned counsel contacted AUSA Jonathan Bailyn,

           who takes no position on this motion.

       WHEREFORE, the undersigned respectfully requests this motion be granted.

                                 CERTIFICATE OF SERVICE

       I HEREBY certify that on March 13, 2023, undersigned counsel electronically filed

foregoing document with the Clerk of Courts using CM/ECF which will send notification of such

filing to all counsel of record, and notification was sent to the Defendant via U.S. Postal Service.

                                              Respectfully submitted,

                                              BOZANIC LAW, P.A.
                                              2847 Hollywood Blvd.
                                              Hollywood, FL 33020
                                              Telephone:    954.920.9750
                                              Facsimile:    954.400.0335
                                              E-Mail: Zeljka@bozaniclaw.com

                                                    /s/Zeljka Bozanic
                                              By:_________________________________
                                                    Zeljka Bozanic
                                                    Florida Bar No. 23707




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