First Lyle Russell, now Ellen Denise... (Funky numbering is true to the original document.)
Motion to Withdraw as Counsel
Now comes Ellen Dennis, attorney for Defendant, Peter Hendrickson, and files this Motion to
Withdraw as Counsel.
Ellen Dennis says as follows:
1. Concurrence in this motion has been sought and granted. Defendant, Peter Hendrickson, concurred in the motion by e-mail on July 12, 2009. Assistant United States Attorney, Michael Leibson, concurred in the motion on July 13, 2009. Co-counsel, Lyle D. Russell, has also concurred in the motion.
1. Ellen Dennis is one of the attorneys of record for Defendant, Peter Hendrickson. The other attorney of record, Lyle D. Russell, has also filed a motion for withdrawal.
2. There has been a breakdown in the attorney/client relationship between Ellen Dennis and Peter Hendrickson. The breakdown is sufficiently significant to damage the defense, possibly depriving Defendant of his right to a fair trial and the effective assistance of counsel.
3. Inasmuch as trial is scheduled for October 20, 2009, there should be sufficient time for Defendant Hendrickson to retain new counsel to represent him.
Wherefore, for the reasons stated above, Ellen Dennis, asks the court to permit her to withdraw as counsel for Peter Hendrickson.
Respectfully submitted,
/s/Ellen Dennis (P-24400)
Law Office of Ellen Dennis
Attorney for Defendant Hendrickson
101 S. Ann Arbor St., Ste. 203A
Saline, Michigan 48176
734 944-5819
Brief in Support of Motion to Withdraw as Counsel
Ellen Dennis filed an appearance in this case November 14, 2008, the date of arraignment. Since that date she has represented Defendant Hendrickson, first as his sole counsel, and from March, 2009, as co-counsel with Lyle D. Russell, Jr. Together with co-counsel, she has reviewed the discovery and filed motions on Defendant Hendrickson’s behalf, several of which were taken under advisement by the court. She has also appeared in court for argument on the motions.
There has been recent deterioration in the attorney/client relationship between Defendant
Hendrickson and Ellen Dennis caused by issues that have not been satisfactorily resolved. At this point the breakdown in the attorney/client relationship between Defendant Hendrickson and Ellen Dennis is significant enough that there is a danger that Defendant Hendrickson’s defense might be adversely impacted, and it is in Defendant Hendrickson’s best interest to permit Ellen Dennis to withdraw from his representation.
Co-counsel, Lyle D. Russell, Jr., has likewise moved for withdrawal, but since trial is not
scheduled until October 20, 2009, Defendant Hendrickson should have sufficient time to retain new counsel, and his right to a fair trial should not be compromised by the withdrawal of Ellen Dennis.
Wherefore, for the reasons stated above, Ellen Dennis, asks the court to permit her to withdraw as counsel for Peter Hendrickson.
Respectfully submitted,
/s/Ellen Dennis (P-24400)
Law Office of Ellen Dennis
Attorney for Defendant Hendrickson
101 S. Ann Arbor St., Ste. 203A
Saline, Michigan 48176
734 944-5819
Dated: July 13, 2009
Demo.