Free Motion for Miscellaneous Motion regarding Reduction of Sentence re Crack Cocaine Offense 18:3582 - District Court of Connecticut - Connecticut

Case 3:00-cr-00069-AHN

Document 319

Filed 08/21/2008

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT ------------------------------------------------------x : UNITED STATES OF AMERICA : : v. : : CLINTON COX : : ------------------------------------------------------x

Case No. 3:00CR00069(AHN)

August 21, 2008

MOTION TO WITHDRAW Undersigned counsel, Sarah A. L. Merriam, respectfully requests leave to withdraw as counsel for Mr. Cox in connection with his request for a reduction in sentence under 18 U.S.C. § 3582(c)(2). In support of this motion, counsel states: (1) Undersigned counsel appeared on behalf of Mr. Cox on May 21, 2008, in connection with his motion for reduction of sentence under § 3582(c)(2) and the recent amendments to the Sentencing Guidelines for offenses involving crack cocaine. (2) Undersigned counsel filed an appearance only after receiving written authorization from the defendant to appear on his behalf in connection with this matter. The purpose of undersigned's appearance was solely to pursue a reduction in sentence under § 3582. (3) Mr. Cox continues to make pro se submissions to this Court regarding both his request for a reduction in sentence under § 3582 and other matters. (4) Mr. Cox has previously sent a letter to the Court expressing his dissatisfaction with the undersigned's representation, a copy of which he sent to the undersigned. (5) There has been a complete breakdown of the relationship between the defendant and the undersigned. There are very substantial and irreconcilable differences between Mr. Cox and

Case 3:00-cr-00069-AHN

Document 319

Filed 08/21/2008

Page 2 of 2

the undersigned counsel which cannot be resolved. Accordingly, undersigned counsel seeks leave to withdraw. (6) Undersigned counsel has sent a copy of this motion to Mr. Cox and has informed him of the need to file a pro se appearance with the Court. Undersigned counsel has also sent Mr. Cox a copy of the docket sheet in his case; an appearance form; a copy of the Local Rules of Criminal Procedure; and a copy of the Second Circuit's instructions on appealing criminal cases. Respectfully submitted, The Defendant, Clinton Cox Thomas G. Dennis Federal Defender

Dated: August 21, 2008

__________/s/______________________ Sarah A. L. Merriam Assistant Federal Defender 265 Church Street, Suite 702 New Haven, CT 06510 Bar No. ct25379 Phone: 203-498-4200 Fax: 203-498-4207 Email: [email protected]

CERTIFICATE OF SERVICE I HEREBY CERTIFY that on August 21, 2008, a copy of the foregoing motion was filed electronically and served by mail on anyone unable to accept electronic filing. Notice of this filing will be sent to all parties by operation of the Court's electronic filing system or by mail to anyone unable to accept electronic filing as indicated on the Notice of Electronic Filing. Parties may access this filing through the Court's CM/ECF System. /s/ Sarah A. L. Merriam -2-