MOTION for Russell J. Feldman to Withdraw as Attorney . Document filed by Rafael Martinez — USA v. Martinez (Dkt. 79)

Record facts

U.S. District Court for the Southern District of New York · No. 1:22-cr-00251-LJL · Doc. 79 · 2023-07-06 · Docket on CourtListener

Summary

A motion and declaration by Russell J. Feldman for leave to withdraw as attorney of record for defendant Rafael Martinez in United States v. Martinez, No. 1:22-cr-00251-LJL, in the U.S. District Court for the Southern District of New York, filed July 6, 2023 as Doc. 79. The motion is brought under Local Civil Rule 1.4 and Local Criminal Rule 1.2 and declared under 28 U.S.C. § 1746. It states that Feldman will no longer be associated with Morvillo Abramowitz Grand Iason & Anello P.C. as of July 6, 2023, and that the firm and Willkie Farr & Gallagher LLP will continue to represent the defendant. It asserts that the withdrawal will not prejudice any party, that no retaining or charging lien is asserted, and asks that he be removed from the ECF service list. The two-page filing references a proposed order attached as Exhibit A.

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Full text

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 
 
UNITED STATES OF AMERICA 
 
 
 
                          
 
                  v. 
 
RAFAEL MARTINEZ, 
 
                          Defendant. 
  
 
 
 
 
      
 
22 Cr. 251 (LJL)  
 
 
MOTION AND DECLARATION PURSUANT TO LOCAL CIVIL RULE 1.4  
AND LOCAL CRIMINAL RULE 1.2  
FOR LEAVE TO WITHDRAW AS ATTORNEY OF RECORD 
 
I, Russell J. Feldman, an attorney of record for Defendant Rafael Martinez 
hereby move the Court pursuant to Local Civil Rule 1.4 and Local Criminal Rule 1.2 of the Local 
Rules of the United States District Courts for the Southern and Eastern Districts of New York for 
an order, substantially in the form attached hereto as Exhibit A, granting me leave to withdraw 
as attorney of record in this action.  In support thereof, and pursuant to 28 U.S.C. § 1746, I 
declare as follows: 
1. 
Effective as of the close of business on July 6, 2023, I will no longer be associated 
with Morvillo Abramowitz Grand Iason & Anello P.C. (“Morvillo Abramowitz”), which firm 
represents Rafael Martinez in this action. 
2. 
Morvillo Abramowitz, including Elkan Abramowitz and Telemachus P. Kasulis, 
will continue to represent the aforementioned party in this action.  Mr. Abramowitz and Mr. 
Kasulis are fully familiar with the litigation and proceedings to date. Mr. Martinez will also 
continue to be represented by Willkie Farr & Gallagher LLP, including Michael Schachter and 
Randall Jackson, who are fully familiar with the litigation and proceedings to date.  
Case 1:22-cr-00251-LJL     Document 79     Filed 07/06/23     Page 1 of 2

2 
 
3. 
Because the Motion herein will not result in a change of the law firms 
representing Mr. Martinez, I respectfully submit that my withdrawal as counsel of record will not 
affect this action in any way, will not alter the posture of the case, and will not prejudice any 
party.   
4. 
I am not asserting a retaining or charging lien. 
5. 
For the foregoing reasons, I hereby request that I be removed as counsel of record 
from the Electronic Case Filing (“ECF”) system, and that no further documents, notices, or other 
pleadings in this action be served upon me. 
6. 
The filing of this Motion electronically using the Court’s ECF system constitutes 
good and proper service on all parties and their registered attorneys of record.  A copy of this 
Motion and Exhibit A shall also be provided to Rafael Martinez. 
7. 
I declare under penalty of perjury that the foregoing is true and correct. 
Dated: July 6, 2023 
 
New York, New York 
 
MORVILLO ABRAMOWITZ GRAND                  
IASON & ANELLO P.C. 
 
By:   
s/ Russell J. Feldman                       d 
    Russell J. Feldman  
 
565 Fifth Avenue 
New York, New York 10017 
(212) 856-9600 (phone) 
(212) 856-9494 (fax) 
rfeldman@maglaw.com 
 
Case 1:22-cr-00251-LJL     Document 79     Filed 07/06/23     Page 2 of 2

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