1. Mr. Francis has advised undersigned counsel that he has retained new trial counsel for this case. Current counsel does not know who Mr. Francis’s new trial counsel is. (Decl. of Robert E. Barnes,
2. A substantial strategic difference of opinion precludes counsel from competently discharging the tasks necessary to protect his former client’s rights – in breach of the client’s contractual obligation but within his Constitutional entitlement – rendering it impossible to carry out the duties of counsel to effectively represent the defendant in this proceeding, justifying the substitution of counsel.
Joe Francis cans The Bobs
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Joe Francis cans The Bobs
http://www.cheatingfrenzy.com/francis61-2.pdf
Demo.