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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF RHODE ISLAND
UNITED STATES OF AMERICA
:
:
v.
:
No. 20-CR-074-MSM
:
DAVID STAVELEY,
:
a/k/a Kurt Sanborn,
:
Defendant.
:
MOTION FOR LEAVE TO WITHDRAW AS COUNSEL
Attorney Mark L. Josephs respectfully submits this Motion for Leave to Withdraw as
Counsel for Defendant David Staveley. Undersigned counsel has represented Mr. Staveley in
this matter as defense counsel after being admitted pro hac vice for purposes of this
representation.
Mr. Josephs requests that he be allowed to withdraw for two reasons. First, Mr. Josephs
will be closing his solo Massachusetts practice by the end of January 2021 because he has
accepted an offer to serve as in-house counsel in a private company. Second, Mr. Staveley has
not paid, and cannot pay, for Mr. Josephs’s services. Mr. Josephs has been in touch with the
Federal Defender’s office about Mr. Staveley, as he will require an Assistant Federal Defender or
a CJA attorney.
For the foregoing reasons, undersigned counsel respectfully requests that this Motion for
Leave be granted, and undersigned counsel be permitted to withdraw his appearance in this
action. The affidavit and certification required by Local Rule Gen 206 are attached.
Respectfully submitted,
Dated: January 6, 2021
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/s/ Mark L. Josephs
Mark L. Josephs
MA Bar No. 568454
Law Office of Mark L. Josephs LLC
100 Cambridge Street, 14th Floor
Boston, MA 02114
(202) 904-4736
mark.josephs@markljosephslaw.com
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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF RHODE ISLAND
UNITED STATES OF AMERICA
:
:
v.
:
No. 20-CR-074-MSM
:
DAVID STAVELEY,
:
a/k/a Kurt Sanborn,
:
Defendant.
:
AFFIDAVIT IN SUPPORT OF MOTION FOR LEAVE TO WITHDRAW AS COUNSEL
1.
My name is Mark Josephs. I am 55 years old, and I am defense counsel to
Defendant David Staveley in this action.
2.
I am admitted to the Massachusetts, Illinois, and District of Columbia Bars. My
Massachusetts Bar Number is 568454.
3.
Mr. Staveley is not in the military service of the United States as defined in the
Servicemembers Civil Relief Act of 2003 (50 U.S.C. §§ 3901-4043), as amended.
Signed this 6th day of January, under the pains and penalties of perjury.
/s/ Mark L. Josephs
Mark L. Josephs
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4
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF RHODE ISLAND
UNITED STATES OF AMERICA
:
:
v.
:
No. 20-CR-074-MSM
:
DAVID STAVELEY,
:
a/k/a Kurt Sanborn,
:
Defendant.
:
CERTIFICATION OF MARK JOSEPHS IN SUPPORT OF
MOTION FOR LEAVE TO WITHDRAW AS COUNSEL
1.
I, Mark Josephs, hereby certify that I notified my client, Defendant David
Staveley, in person at the Wyatt Detention Facility on January 6, 2021, of my intent to file a
Motion to withdraw as counsel.
2.
I made him aware that he could object to this Motion and that substitution of
counsel will not be considered as grounds for delaying the trial or any other matter scheduled in
this case.
Respectfully submitted,
/s/ Mark L. Josephs
Mark L. Josephs
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5
CERTIFICATE OF SERVICE
I hereby certify that this document filed through the ECF system will be sent
electronically to the registered participants as identified on the Notice of Electronic Filing (NEF),
and paper copies will be sent to anyone indicated as a non-registered participant on January 6,
2021.
/s/ Mark L. Josephs
Mark L. Josephs
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