Motion for Leave to Withdraw — USA v. Smith (N.D. Ill.)

Record facts

U.S. District Court for the Northern District of Illinois · No. 1:20-cr-00922 · Doc. 27 · 2021-07-09 · Docket on CourtListener

Full text

IN THE UNITED STATES DISTRICT COURT 
FOR THE NORTHERN DISTRICT OF ILLINOIS 
EASTERN DIVISION 
 
UNITED STATES OF AMERICA,             ) 
                        Plaintiff,                                ) 
                                                                      ) 
                 v.                                                  )                 No. 20 CR 922 
                                                                      )                  Judge Manish S. Shah 
CARLOS SMITH,             
                      ) 
                       Defendant.                             ) 
 
MOTION FOR LEAVE TO WITHDRAW  
 
Now comes KENT R. CARLSON court appointed attorney of record for Defendant 
CARLOS SMITH and respectfully moves this  Honorable Court for leave to withdraw his 
appearance as counsel for CARLOS SMITH. In support hereof, the following is asserted: 
 
1. That CARLOS SMITH is charged with wire fraud and bank fraud in violation of 18 
U.S.C. 1014, 1343, 1957. 
2. That on March 14, 2021, counsel was appointed to represent CARLOS SMITH. 
3. That there have developed irreconcilable differences between counsel and CARLOS 
SMITH, such that there has been a complete and total break-down of the attorney client 
relationship, such that counsel does not believe he can provide effective assistance of counsel to 
CARLOS SMITH. 
4. Specifically CARLOS SMITH has advised counsel that he no longer wants counsel to 
represent him “fire yourself, let me get a new lawyer” as he believes counsel is not acting in his 
best interests and CARLOS SMITH believes counsel will not act in his best interests ”a new 
lawyer I can trust and understands me better”.  
5. That due to the aforementioned counsel does not believe he can effectively continue to 
represent CARLOS SMITH. 
Case: 1:20-cr-00922 Document #: 27 Filed: 07/09/21 Page 1 of 3 PageID #:75

6. That requiring CARLOS SMITH to proceed in this cause with current counsel would 
deny CARLOS SMITH, his valuable constitutional rights to the effective assistance of counsel, 
to a fair and just trial and due process of law. 
For all the above and foregoing reasons, KENT R. CARLSON court appointed attorney 
of record for CARLOS SMITH prays this Honorable Court grant him leave to withdraw as 
attorney for Defendant CARLOS SMITH and for the appointment of new counsel. 
 
Respectfully submitted, 
 
s/Kent R. Carlson 
KENT R. CARLSON & ASSOCIATES P.C. 
53 W. Jackson Blvd. - Suite 1544 
Chicago, Il. 60604 
(312) 663-9601 
kentrcarlson@sbcglobal.net 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Case: 1:20-cr-00922 Document #: 27 Filed: 07/09/21 Page 2 of 3 PageID #:76

CERTIFICATE OF SERVICE 
 
 
The undersigned, hereby certifies that the following document: 
 
MOTION TO WITHDRAW 
 
 
Was served on July 8, 2021, in accordance with Fed. R. Crim. P. 49, Local Rule 5.5 and the 
General Order on Electric Case Filing (ECF), pursuant to the District Court’s system as to ECF 
filers. 
 
 
s/Kent R. Carlson 
KENT R. CARLSON & ASSOCIATES P.C. 
53 W. Jackson Blvd. - Suite 1544 
Chicago, Il. 60604 
(312) 663-9601 
kentrcarlson@sbcglobal.net 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Case: 1:20-cr-00922 Document #: 27 Filed: 07/09/21 Page 3 of 3 PageID #:77

File and source

File

gov.uscourts.ilnd.394355.27.0.pdf

Size

82,442 bytes

SHA-256

a53026049937f861e794d8f42da06551f0b97dcce3dfbf921896bf746c3af377

Our copy

gov.uscourts.ilnd.394355.27.0.pdf

Original

PACER (login required)