Free Motion to Withdraw as Attorney - District Court of Delaware - Delaware

Case 1 :07-cr-00109-SLR Document 8 Filed 07/20/2007 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT if
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, :
Plaintiff. FILED UNDER SEAL
v. Mag. Docket No. ;§__
JAMES GORDON,
Defendant.
DEFENDANT’S SEALED, UNOPPOSED MOTION TO WITHDRAW CURRENT
QOUN SEL AND TO APPOINT NEW COUNSEL
Edson A. Bostic, Federal Public Defender for the District of Delaware, hereby moves this
Court for an Order withdrawing the Office of the Federal Public Defender for the District of
- Delaware as counsel for James Gordon, and appointing Christopher Koyste, a member of the
Criminal Justice Act Panel, to continue his representation.
In support thereof, Mr. Bostic avers as follows:
l. On or about April 27, 2005, Mr. Gordon was arrested and charged, pursuant to a
complaint and warrant with distribution of Oxycodone, in violation of 2l U.S.C. § 841 (a)(l) and
(b)(1)(C)-
2. The matter is still pending at the magisterial level, and the Defendant has been
cooperating since his arrest.
3. Mr. Koyste has resigned from the Office of the Federal Public Defender and the matter
then reassigned to Federal Public Defender, Edson A. Bostic.
4. Since that time, both Mr. Koystel and Mr. Gordon have informed Counsel that Mr.
1 Mr. Koyste has since been named to the Criminal Justice Panel.

Case 1:07-cr-00109-SLR Document 8 Filed 07/20/2007 Page 2 of 3
Gordon desires to have Mr. Koyste continue as counsel in this matter. The basis for this stems
from the close and longstanding attomey-client relationship that has developed between Mr.
Koyste and l\/Ir. Gordon.
5. In the interest of justice and to foster the continuity of this attorney-client relationship,
Counsel is requesting that the Office of the Federal Public Defender be removed from this matter
and Mr. Koyste be appointed as court appointed counsel for Mr. Gordon, pursuant to the
Criminal Justice Act.
6. The withdrawal of the Office of the Federal Public Defender and appointment of Mr.
Koyste as Counsel for defendant should not result in any substantial delay in the disposition of
this matter.
7. Counsel has discussed the filing of the instant motion with the government, Assistant
United States Attorney David Hall, and the government does not oppose the motion.
WHEREFORE, for the above stated reasons, it is respectfully requested that this Court
enter an Order withdrawing the Office of the Federal Public Defender for the District of
Delaware as Mr. Gordon’s Counsel, and appointing Christopher Koyste, a member of the
Criminal Justice Act Panel to continue Mr. Gordon’s representation.
Federal Public Defender
Attorney for James Gordon
Office of the Federal Public Defender
District of Delaware
704 King Street, Suite 110
Wilmington, Delaware 19801
Dated: July 20, 2007

Case 1:07-cr-00109-SLR Document 8 Filed 07/20/2007 Page 3 of 3
CERTIFICATE OF SERVICE
The undersigned attorney for Defendant James Gordon hereby certifies that on
July 20, 2007, two (2) copies of the attached Motion were placed in a box in the United States
District Court of the District of Delaware addressed to the following person(s):
DAVID HALL, ESQUIRE
Assistant U.S. Attorney
The Nemours Building
1007 Orange Street, Suite 700
P.O. Box 2046
Wilmington, DE 19899-2046
via First Class Mail to:
CHRISTOPHER S. KOYSTE
800 N. KING STREET, SUITE 302
WILMINGTON, DE 19801
Y / I i rl I I- _-`
/ X . — ‘ — . ._.
EDSON A. BOSTIC
Federal Public Defender
Attorney for James Gordon
Office of the Federal Public Defender
District of Delaware
704 King Street, Suite 110
Wilmington, Delaware 19801
Dated: July 20, 2007