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Motion to Withdraw as Counsel — No. 2:22-cr-00993 (Dkt. 152, D.S.C.)

Summary

A Motion to Withdraw as Counsel, Entry Number 152 filed February 12, 2025 in the District of South Carolina, Charleston Division (Case 2:22-cr-00993-RMG), United States v. Jonathan Ramaci. It is filed by Jerry N. Theos and E. Gordon Hay, VI of the Theos Law Firm, LLC and Joseph P. Griffith, Jr. of the Joe Griffith Law Firm, LLC, who ask to be relieved as counsel. Their grounds are that the defendant cannot make financial arrangements to retain them, their engagement ran only through judgment in the district court and has ended, post-conviction or appeal grounds may require them to testify as witnesses, and he now wishes to use the Public Defender. The motion states that the defendant and the government consent.

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Cite this document

“Motion to Withdraw as Counsel — No. 2:22-cr-00993 (Dkt. 152, D.S.C.).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/motion-to-withdraw-as-counsel-no-2-22-cr-00993-dkt-152-d-s-c-f245c01894/, SHA-256 e5c8b4983fa205ced894c128a1349f9a6eeb5e213d7e5b090f8c49caf3cf9894.

Full text

     2:22-cr-00993-RMG         Date Filed 02/12/25       Entry Number 152         Page 1 of 2




                     THE DISTRICT COURT OF THE UNITED STATES
                           DISTRICT OF SOUTH CAROLINA
                               CHARLESTON DIVISION

UNITED STATES OF AMERICA,                     )
                                              )      CASE NUMBER: 2:22-cr-00993-RMG
                       Plaintiff,             )
v.                                            )   MOTION TO WITHDRAW AS COUNSEL
                                              )
JONATHAN RAMACI,                              )
                                              )
                       Defendant.             )



        The undersigned counsel for Defendant hereby moves this Honorable Court for an order

relieving Jerry N. Theos and E. Gordon Hay, VI of the Theos Law Firm, LLC, and Joseph P.

Griffith, Jr. of the Joe Griffith Law Firm, LLC, as counsel for the Defendant.

        This motion is being made based upon the following grounds: (1) The Defendant is not

capable of making the financial arrangements to retain the representation of the undersigned

attorneys; (2) The undersigned attorneys’ engagement with the Defendant was effective only

through judgment at the district court, and that engagement has now terminated; (3) One or more

of the grounds Defendant may raise post-conviction and/or on appeal may require the undersigned

counsel to serve as witnesses, thereby precluding the undersigned counsel’s continued

representation, including the instant appeal; and, (4) The Defendant now wishes to engage the legal

services of the Public Defender.

        The undersigned counsel has provided written notice of their intent to withdraw as counsel

to Defendant and Counsel for the Government. Defendant and the Government consent to the

requested relief.
   2:22-cr-00993-RMG   Date Filed 02/12/25    Entry Number 152         Page 2 of 2




                            By:    Respectfully submitted,

                                   /s/ Jerry N. Theos
                                   Jerry N. Theos, Esq. (Fed. I.D. 4055)
                                   E. Gordon Hay, VI, Esq., (Fed.ID 13490)
                                   Theos Law Firm, LLC
                                   11 State Street
                                   Charleston, SC 29401
                                   jerry@theoslaw.com
                                   gordon@theoslaw.com
                                   (843) 577-7046

                                   &

                                   /s/ Joseph P. Griffith, Jr.
                                   Joseph P. Griffith, Esquire (Fed I.D. 2473)
                                   Joe Griffith Law Firm, LLC
                                   946 Johnnie Dodds Blvd.
                                   Mt. Pleasant, S.C. 29464
                                   843.225.5563 (tel)
                                   joegriffithjr@hotmail.com
                                   ATTORNEYS FOR DEFENDANT
February 12, 2025
Charleston, SC


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