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Court filing — No. 3:24-cr-00142 (Dkt. 67, D.N.D.)

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         Case 3:24-cr-00142-PDW            Document 67       Filed 02/20/26     Page 1 of 2




                                UNITED STATES DISTRICT COURT
                                 DISTRICT OF NORTH DAKOTA


   UNITED STATES OF AMERICA,                                       Case No. 3:24-CR-142

                              Plaintiff,
                                                           MOTION TO WITHDRAW AS
   vs.                                                            COUNSEL

   ROSS SYLVESTER ELENDU,

                              Defendant.


         Erich M. Grant, Attorney for the Defendant, moves the Court for its order allowing him to

withdraw as counsel for the Defendant, Ross Sylvester Elendu, based upon the following cause:

   1. There has been a complete and irretrievable breakdown of the attorney-client relationship

         whereby effective representation is no longer possible.

   2. The Defendant has demanded that the undersigned withdraw as his counsel.

   3. Reasonable efforts have been made to resolve these issues but to no avail.

   4. The defendant has been convicted by a jury and is in detention pending sentencing on April

         2, 2026, at 1:30 PM. Sufficient time remains for the defendant to retain new counsel in

         advance of his sentencing hearing. He would not be prejudiced by withdrawal.

         Based upon the forgoing reasons, Counsel for the Defendant respectfully moves to withdraw

as counsel for the Defendant.

Dated this 20th day of February, 2026.                 MCGEE, HANKLA, & BACKES, P.C.
                                               BY:    /s/ Erich M. Grant
                                                      Erich M. Grant (ND ID# 07593)
                                                      E-mail: egrant@mcgeelaw.com
                                                      2400 E. Burdick Expwy., Ste. 100
                                                      PO Box 998
                                                      Minot, North Dakota 58702-0998
                                                      (701) 852-2544
                                               Attorney for the Defendant

                                                   1
       Case 3:24-cr-00142-PDW            Document 67      Filed 02/20/26     Page 2 of 2




                                CERTIFICATE OF SERVICE

       Erich M. Grant, counsel for the Defendant, hereby certifies that the foregoing document was

served upon the following:

       By Certified Mail:                           By Electronic Filing:

       Ross Elendu #2025004029                      Matthew Greenley
       Sherburne County Jail                        Assistant U.S. Attorney
       13880 Business Ctr Dr., NW, Suite 200        matthew.greenley@usdoj.gov
       Elk River, MN 55330


Dated this 20th day of February, 2026.              MCGEE, HANKLA, & BACKES, P.C.


                                             BY:    /s/ Erich M. Grant
                                                    Erich M. Grant (ND ID# 07593)
                                                    E-mail: egrant@mcgeelaw.com
                                                    2400 E. Burdick Expwy., Ste. 100
                                                    PO Box 998
                                                    Minot, North Dakota 58702-0998
                                                    (701) 852-2544
                                             Attorney for the Defendant




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