Motion to Withdraw as Attorney, Zeljka Bozanic — USA v. Casseus (M.D. Fla.)

Summary

Filed 03/19/24, in Case No. 23-cr-00009-TPB in the U.S. District Court for the Middle District of Florida, this is a motion by attorney Zeljka Bozanic to withdraw as counsel for Denis Casseus. It recites that he was indicted on January 25, 2023 on bank fraud, false statement to a lending institution and illegal monetary transaction charges, pleaded guilty to counts one, two and five, and on October 20, 2023 received 24 months' imprisonment followed by 36 months of supervised release. Bozanic filed his Amendment 821 motion on February 9, 2024, and Assistant Public Defender Laura Ferro later appeared for sentence reduction purposes. After the Federal Defender's Office preferred she withdraw, Casseus himself instructed Bozanic on March 18 and 19, 2024 to file the motion.

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UNITED STATES DISTRICT COURT 
MIDDLE DISTRICT OF FLORIDA  
 
CASE NO.: 23-cr-00009-TPB 
 
UNITED STATES OF AMERICA            
                      Plaintiff, 
vs. 
 
DENIS CASSEUS, 
 
           Defendant. 
                                                                      / 
 
MOTION TO WITHDRAW  
The undersigned, Zeljka Bozanic, files this Motion to Withdraw as Counsel of record, 
and as grounds states the following: 
1. 
On January 25, 2023, Mr. Casseus was charged by Indictment with two counts 
of Bank Fraud in violation of 18 U.S.C. § 1344, two counts of False Statement to Lending 
Institution in violation of 18 U.S.C. § 1014, and one count of Illegal Monetary Transaction 
in violation of 18 U.S.C. § 1957.  
2. 
On February 10, 2023, the undersigned entered a notice of appearance.   
3. 
 On May 26, 2023, Mr. Casseus pled guilty to count one, count two and count 
five of the Indictment. 
4. 
On October 20, 2023, Mr. Casseus was sentenced to 24 months’ imprisonment, 
to be followed by 36 months of supervised release. Mr. Cassesus was allowed to surrender 
to Bureau of Prisons by December 21, 2024.  
5. 
On February 9, 2024, at the request of Mr. Casseus, the undersigned filed a 
Motion for Retroactive Application of Sentencing Guidelines pursuant to Amendment 821 
[DE 64].  
6. 
On February 15, 2024, the Court appointed Federal Public Defender for 

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purposed of the “Pro Se Motion” titled “Motion for Compassionate Release” [DE 62], 
which was apparently not filed by Mr. Casseus.  
7. 
On March 7, 2024, Assistant Public Defender Laura Ferro filed a Notice of 
Appearance for Sentence Reduction Motion Purposes only [DE 71]. 
8. 
On March 12, 2024, Assistant Public Defender Laura Ferro filed a Motion for 
Clarification [DE 73].  
9. 
The undersigned did not think there was a reason to file a motion for 
clarification, but informed Ms. Ferro that I was amendable to representing Mr. Casseus for 
the limited purposes of the 821 Amendment Motion I filed.  
10. On March 13, 2024, after Mr. Casseus contacted the undersigned, the 
undersigned reached out to Ms. Ferro asking her to amend her motion, as Mr. Casseus felt 
it would be easier for the Federal Defender’s Office to represent him on both motions.  
11. On March 14, 2024, Ms. Ferro responded stating that her office would prefer 
that the undersigned file a motion to withdraw.  
12. Between March 18 and March 19, 2024, the undersigned was directly instructed 
by Mr. Casseus himself for the undersigned to file a Motion to Withdraw.  
WHEREFORE, Zeljka Bozanic respectfully request that this Court enter an Order 
allowing the undersigned to withdraw from this matter and release the undersigned from any 
further responsibility in this case.  
CERTIFICATE OF SERVICE 
I HEREBY certify that on March 19, 2024, 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 via mail to Denis Casseus. 

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Respectfully submitted, 
 
BOZANIC LAW, P.A. 
17100 Royal Palm Blvd. 
Suite 1 
Weston, FL 33326 
Telephone: 
954.920.9750 
Facsimile: 
954.400.0335 
E-Mail: Zeljka@bozaniclaw.com 
 
 
By:_____/s/Zeljka Bozanic___________ 
 
 
 
 
 
 
 
Zeljka Bozanic 
 
 
 
 
 
 
 
Florida Bar No.  23707

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