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Home Court filings USA v. Harun (GASD 89545) Motion to Withdraw as Attorney of Record

Court filing

Motion to Withdraw as Attorney of Record

Record facts

CourtU.S. District Court for the Southern District of Georgia
Filed2023-07-07

U.S. District Court for the Southern District of Georgia · No. 3:23-cr-00003-DHB-BKE · Doc. 10 · 2023-07-07 · Docket on CourtListener

Summary

A motion by defense counsel Mohammed S. Luwemba and Teri L. Thompson to withdraw as attorneys of record in United States v. Gladys Harun, filed July 7, 2023 as Document 10 in No. 3:23-cr-00003-DHB-BKE in the U.S. District Court for the Southern District of Georgia. The motion states that the defendant was charged in a seven-count Indictment under 18 USC § 1623, 18 USC § 1343 and 18 USC §1957, and that counsel was retained on February 9, 2023. It states that on April 27, 2023 the defendant entered a guilty plea to Count One of an Information under a written plea agreement. Counsel states the client is terminating his services and refusing to pay as agreed, that he provided the Initial Pre-Sentence Report, and that withdrawal will not delay sentencing. The four-page filing ends with a certificate of service on the government.

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

IN THE UNITED STATES DISTRICT COURT 
FOR THE SOUTHERN DISTRICT OF GEORGIA 
DUBLIN DIVISION 
 
UNITED STATES OF AMERICA : 
 
 
 
 
 
 
: Case No. 3:22-CR-09 
V. 
 
 
 
 
 
:  
 
 
 
 
 
 
: 
GLADYS HARUN, 
 
 
: 
 
DEFENDANT. 
 
 
: 
 
 
 
 
 
 
: 
 
 
MOTION TO WITHDRAW AS ATTORNEY OF RECORD 
 
 
COMES NOW, undersigned counsel, and hereby files their Motion to 
Withdraw as Attorneys of Record in the above-captioned matter.  In support thereof, 
counsel states the following: 
(1) 
Gladys Harun is charged in a seven-count Indictment with the following 
offenses: False Declaration, in violation of 18 USC § 1623, Wire Fraud, in violation 
of 18 USC § 1343 (two counts), and Money Laundering Transaction over $10,000, 
in violation of 18 USC §1957 (four counts).    
 
 
 
 
 
 
 (2) 
On February 9, 2023, undersigned counsel was retained to represent Ms. 
Harun to represent her in the above-referenced Indictment.   
 
Case 3:23-cr-00003-DHB-BKE     Document 10     Filed 07/07/23     Page 1 of 4

(3) 
On April 27, 2023, Ms. Harun entered a guilty plea to Count One of an 
Information pursuant to a written plea agreement.   
(4) 
Undersigned counsel was informed by Ms. Harun that she is terminating his 
services, and that she is refusing to pay him as contractually agreed. 
(5) 
Counsel cannot zealously and effectively represent Ms. Harun due to her 
decision to terminate his services and her refusal to pay him as agreed.   
(6) 
 
Counsel provided the Initial Pre-Sentence Report to Ms. Harun and has 
advised her in writing of all applicable deadlines to file objections thereto. 
(7) 
 
This request for withdrawal will not delay the sentencing hearing or otherwise 
interrupt the orderly operation of the Court or be manifestly unfair to Ms. Harun.  
 
WHEREFORE, counsel respectfully requests an Order permitting him to 
withdraw from this matter. 
 
Respectfully submitted this 6th day of July 2023. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Case 3:23-cr-00003-DHB-BKE     Document 10     Filed 07/07/23     Page 2 of 4

LUWEMBA LAW 
 
 
 
/s/ Mohammed S. Luwemba 
2296 Henderson Mill Road, Ste. 304  
Mohammed S. Luwemba 
Atlanta, Georgia 30345  
 
 
Georgia Bar No. 680308 
Office: 404-522-1400 
Email: luwemba@luwembalaw.net  
 
TERI THOMPSON, LLC 
 
 
/s/Teri L. Thompson 
2330 Scenic Highway 
 
 
 
Teri L. Thompson  
Snellville, Georgia 30078 
 
 
Georgia Bar No. 443999 
Office: 770-674-2890 
 
 
 
 
Email: terithompson17@gmail.com 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Case 3:23-cr-00003-DHB-BKE     Document 10     Filed 07/07/23     Page 3 of 4

IN THE UNITED STATES DISTRICT COURT 
FOR THE SOUTHERN DISTRICT OF GEORGIA 
DUBLIN DIVISION 
 
UNITED STATES OF AMERICA : 
 
 
 
 
 
 
: Case No. 3:22-CR-09 
V. 
 
 
 
 
 
:  
 
 
 
 
 
 
: 
GLADYS HARUN, 
 
 
: 
 
DEFENDANT. 
 
 
: 
 
 
 
 
 
 
: 
 
CERTIFICATE OF SERVICE 
 
I hereby certify that I have this day served a copy of the foregoing Motion to 
Withdraw upon opposing counsel using the CM/ECF system which will send email 
notification of such filing to the opposing counsel of record: 
Mr. Louis Alexander Hamner, Esq. 
Assistant United States Attorney 
22 Barnard Street, Suite 300 
Savannah, GA 31401 
 
 
Respectfully submitted,   
 
 
LUWEMBA LAW 
 
 
 
/s/ Mohammed S. Luwemba 
2296 Henderson Mill Road, Ste. 304  
Mohammed S. Luwemba 
Atlanta, Georgia 30345  
 
 
Georgia Bar No. 680308 
Office: 404-522-1400 
Email: luwemba@luwembalaw.net  
 
TERI THOMPSON, LLC 
 
 
/s/Teri L. Thompson 
2330 Scenic Highway 
 
 
 
Teri L. Thompson  
Snellville, Georgia 30078 
 
 
Georgia Bar No. 443999 
Office: 770-674-2890 
 
 
 
 
Email: terithompson17@gmail.com 
 
Case 3:23-cr-00003-DHB-BKE     Document 10     Filed 07/07/23     Page 4 of 4

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