Motion to Withdraw as Counsel — No. 1:24-cr-00323 (Dkt. 44, D.D.C.)
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Motion to withdraw as counsel in the U.S. District Court for the District of Columbia, United States v. Jose Biaou, case 1:24-cr-00323, Document 44, filed December 31, 2025. Maia Livengood of Quinn Emanuel Urquhart and Sullivan, LLP asks leave under Local Rule 44.5 to withdraw, citing irreconcilable differences between the firm and Biaou. The motion states that co-counsel Ubong Akpan of the Office of the Federal Public Defender for the District of Columbia will continue to represent Biaou without disruption.
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“Motion to Withdraw as Counsel — No. 1:24-cr-00323 (Dkt. 44, D.D.C.).”
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Case 1:24-cr-00323-CRC Document 44 Filed 12/31/25 Page 1 of 2
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
UNITED STATES OF AMERICA,
v. Case No.: 1:24-cr-00323-CRC
JOSE BIAOU,
Defendant.
MOTION TO WITHDRAW AS COUNSEL
Attorney Maia Livengood respectfully moves this Court for leave to withdraw as counsel
for Defendant Jose Biaou pursuant to Local Rule 44.5. In support of the Motion, Ms. Livengood
states as follows:
1. Ms. Livengood of Quinn Emanuel Urquhart and Sullivan, LLP (“Quinn Emanuel”) is
counsel of record for Defendant in the above-captioned matter, along with co-counsel
Ubong Akpan from the Office of the Federal Public Defender for the District of Columbia.
2. Irreconcilable differences have arisen between Quinn Emanuel and Mr. Biaou.
3. Withdrawal at this stage will not unduly prejudice Mr. Biaou or delay these proceedings.
Mr. Biaou will continue to be ably represented by co-counsel Ubong Akpan of the Office
of the Federal Public Defender for the District of Columbia, whose representation of Mr.
Biaou predates Quinn Emanuel’s involvement in this matter.
4. Ms. Akpan is fully familiar with the pretrial motions filed on Mr. Biaou’s behalf, the
discovery produced in this case, and Mr. Biaou’s defenses. The continuity of Ms. Akpan’s
representation ensures that Mr. Biaou will suffer no disruption or gap in counsel.
5. Quinn Emanuel has informed Mr. Biaou of its intent to withdraw and will serve a copy of
the Motion on Mr. Biaou as required by Local Rule 44.5(d).
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Case 1:24-cr-00323-CRC Document 44 Filed 12/31/25 Page 2 of 2
WHEREFORE, Maia Livengood respectfully requests that this Court grant leave to
withdraw as counsel of record for Defendant.
Dated: December 31, 2025
/s/ Maia Livengood
Maia Livengood (DC Bar No. 1724598)
QUINN EMANUEL URQUHART &
SULLIVAN, LLP
1300 I Street NW, Suite 900
Washington, District of Columbia 20005-3314
(202) 538-8000
maialivengood@quinnemanuel.com
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