MOTION to Withdraw as Attorney by Henry P. Bell for / by Andre Lorquet — Andre Lorquet (Dkt. 83)

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Case 1:22-cr-20326-KMM Document 83 Entered on FLSD Docket 09/06/2023 Page 1 of 2




                         UNITED STATES DISTRICT COURT
                         SOUTHERN DISTRICT OF FLORIDA

                             CASE NO. 22-20326-CR-KMM

  UNITED STATES OF AMERICA,
        Plaintiff,
  v.

  ANDRE LORQUET

        Defendant.
  _____________________________/
             MOTION TO WITHDRAW AS COUNSEL TO DEFENDANT

        Undersigned counsel moves to withdraw as counsel to the defendant Andre

  Lorquet.

        Because of irreconcilable differences, undersigned counsel moves to withdraw

  as Mr. Lorquet’s attorney in this matter. The comments to Rule 4-1.2 of the Florida

  Bar state the following: “[a] lawyer and a client may disagree about the means to be

  used to accomplish the client’s objectives. The lawyer should consult with the client

  and seek a mutually acceptable resolution of the disagreement. If such efforts are

  unavailing and the lawyer has a fundamental disagreement with the client, the

  lawyer may withdraw from the representation.”

        Here, the undersigned lawyer and client have a fundamental disagreement.

  As a result, the undersigned lawyer seeks to withdraw from representing the client,

  in this case Mer. Lorquet. To protect the client’s confidences and attorney client

  privilege, the undersigned is not disclosing the communications and disagreements


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Case 1:22-cr-20326-KMM Document 83 Entered on FLSD Docket 09/06/2023 Page 2 of 2




  between counsel and Mr. Lorquet. Nevertheless, they are fundamental and

  therefore the undersigned finds that withdrawal is necessary.

        Wherefore, Henry P. Bell and Bell Rosquete Reyes Esteban, PLLC

  respectfully request that the Court enter an order permitting their withdrawal as

  counsel and discharging them from further responsibility in representing Mr.

  Lorquet.



                            CERTIFICATE OF SERVICE

        I HEREBY CERTIFY that, on August 6, 2023, a true and correct copy of the

  foregoing has been furnished electronically via CMCEF to all counsel of record.

                                  Respectfully submitted,

                                  BELL ROSQUETE REYES ESTEBAN, PLLC
                                  Henry P. Bell
                                  Fla. Bar No. 090689
                                  999 Ponce De Leon Blvd.
                                  Suite 810
                                  Coral Gables, Florida 33134
                                  Telephone: (305) 570-1610
                                  Facsimile: (305) 570-1599
                                  Email:       hbell@bresq.com
                                  Counsel to Andre Lorquet

                                  By: ____s/Henry P. Bell_____
                                        Henry P. Bel

  CC: Andre Lorquet – FDC Miami




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