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Home Court filings United States v. Felicia Jackson Stanley Motion to Withdraw

Court filing

Motion to Withdraw

Record facts

CourtU.S. District Court for the Northern District of Florida
Filed2024-01-16

U.S. District Court for the Northern District of Florida · No. 4:22-cr-00032-MW-MAF · Doc. 87 · 2024-01-16 · Docket on CourtListener

Summary

A Motion to Withdraw filed January 16, 2024 by Federal Public Defender Joseph F. DeBelder in United States v. Felicia Jackson-Stanley, No. 4:22-cr-00032-MW-MAF, in the U.S. District Court for the Northern District of Florida, Doc. 87. The motion asks the Court to allow the Office of the Federal Public Defender to withdraw from representing the defendant on her Guidelines amendment motion under 18 U.S.C. § 3582(c)(2), ECF No. 84. It states that the Court appointed the office to assess relief under the 2023 Amendments to the Sentencing Guidelines and ordered a memorandum by January 17, 2024 (ECF No. 85). Counsel states he reviewed the case and sent the defendant an analysis, and believes the office is precluded from filing the memorandum under Rule 4-1.7 and Rule 4-3.1 of the Rules Regulating the Florida Bar. The filing includes a certificate of service.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Full text

UNITED STATES DISTRICT COURT  
NORTHERN DISTRICT OF FLORIDA 
TALLAHASSEE DIVISION 
 
UNITED STATES OF AMERICA,  
 
 
 
 
 
 
 
 
 
 
Case No. 4:22CR32-MW  
vs. 
 
 
 
 
 
 
  
  
FELICIA JACKSON-STANLEY,  
Defendant. 
_________________________________/ 
 
 
MOTION TO WITHDRAW 
 
Undersigned counsel moves this Court to allow the Office of the Federal 
Public Defender, Northern District of Florida, to withdraw from any further 
representation of the Defendant, FELICIA JACKSON-STANLEY, related to her 
Guidelines amendment motion pursuant to 18 U.S.C. § 3582(c)(2), ECF No. 84. In 
support of this motion, counsel states: 
1. This Court appointed the Federal Public Defender’s Office to assist Ms. 
Jackson-Stanley in determining whether she is entitled to relief under the 
2023 Amendments to the Sentencing Guidelines. Further, the Court 
ordered counsel to file a memorandum addressing the issue on or before 
Wednesday, January 17, 2024. ECF No. 85. 
2. Undersigned counsel has reviewed Defendant=s case. Further, 
undersigned counsel has sent a letter to Ms. Jackson-Stanley and provided 
Case 4:22-cr-00032-MW-MAF     Document 87     Filed 01/16/24     Page 1 of 3

her with an analysis of whether she might be eligible for a reduction in 
sentence based on the 2023 Guidelines Amendments.   
3. Undersigned counsel believes that the Federal Public Defender’s Office is 
precluded from filing the ordered memorandum pursuant to the Rules of 
Professional Conduct for the Florida Bar. See, Rule 4-1.7 and Rule 4-3.1, 
Rules Regulating the Florida Bar.   
WHEREFORE, the Federal Public Defender hereby requests that this Court 
allow the Office of the Federal Public Defender to withdraw from any further 
representation of the Defendant, FELICIA JACKSON-STANLEY, related to her 
Guidelines amendment motion pursuant to 18 U.S.C. § 3582(c)(2), ECF No. 84. 
 
                                          Respectfully submitted, 
JOSEPH F. DEBELDER 
FEDERAL PUBLIC DEFENDER 
 
/s/ Joseph F. DeBelder                               
JOSEPH F. DEBELDER 
Federal Public Defender 
Florida Bar No. 193800 
227 N. Bronough Street 
Suite 4200 
Tallahassee, FL 32301 
Joseph_DeBelder@fd.org 
(850) 942-8818 
 
 
 
 
Case 4:22-cr-00032-MW-MAF     Document 87     Filed 01/16/24     Page 2 of 3

CERTIFICATE OF SERVICE 
I HEREBY CERTIFY that a copy of the foregoing has been furnished by 
electronic delivery to Robert Davies, Assistant United States Attorney, on January 
16, 2024. 
 
 
 
 
 
Joseph F. DeBelder 
 
 
 
 
 
JOSEPH F. DEBELDER 
 
 
Case 4:22-cr-00032-MW-MAF     Document 87     Filed 01/16/24     Page 3 of 3

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