COMES NOW, Annette Marie Bosworth, in response to her attorney Brandon Taliaferros

Motion to Withdrawal As Counsel for Defendant.

I request that Taliaferros motion be denied for the following reasons:


1. Taliaferro has failed to state a specic claim. Under Rule 1.16(b)(5) of the South Dakota
Rules of Professional Conduct, a lawyer may withdraw from representing a client if the
client fails substantially to fulll an obligation to the lawyer regarding the lawyers
services and has been given reasonable warning that the lawyer will withdraw unless the
obligation is fullled. Taliaferros Motion fails to cite any specic example.
2. Further, I do not believe I have failed substantially to fulll an obligation to the lawyer
regarding Taliaferros services.
3. Because Taliaferros Motion to Withdraw contains no facts or specic allegations, I am
unable to respond properly. However, statements made in informal written
correspondence with Mr. Taliaferro indicate baseless legal arguments.
4. For example, in an August 3rd letter, Taliaferro claims to have led his Motion to
Withdraw because I failed to pay a retainer due on July 25th. Mr. Taliaferro led his
Motion on July 16th, nine days before the retainer was due. See Exhibit A.
5. Taliaferros Withdrawal violates Rule 1.16.(b)(1) which states a lawyer can withdraw if
withdrawal can be accomplished without material adverse effect on the interests of the
client.
6. As an example, Taliaferros intentionally vague Motion to the Withdraw had a
predictable, immediate, material adverse effect on my criminal case by creating
speculations in the media about what obligation I had allegedly not fullled to Taliaferro.
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STATE OF SOUTH DAKOTA,

Plaintiff

vs.

ANNETTE MARIE BOSWORTH,

Defendant.
Crim 14-305

RESPONSE TO
MOTION TO WITHDRAWAL AS
COUNSEL FOR DEFENDANT
STATE OF SOUTH DAKOTA

COUNTY OF HUGHES
IN CIRCUIT COURT

SIXTH JUDICIAL COURT
Taliaferros vague Motion to Withdraw incited media speculation that I was unable or
unwilling to pay Mr. Taliaferro or that I had acted as an out of control client. See
Exhibits B, C & D. Neither insinuation is true and both materially damaged my ability to
nd replacement counsel and created a false, negative public impression of me.
7. Because Taliaferros Motion to Withdraw has no stated factual basis, because it
damages my reputation and ability to nd replacement counsel, and because it will delay
proceedings in my criminal trial, I ask that Talliaferros Motion be denied.


Dated this 4th of August, 2014.
__________________________

Annette Bosworth, MD
Defendant
MEANINGFUL MEDICINE
5000 S Minnesota Ave #100
Sioux Falls, SD 57108
(605) 371-6899
dr.bosworth@meaningfulmedicine.org


CERTIFICATE OF SERVICE
The undersigned hereby certies that he served a copy of this legal document upon the ofce of
the prosecuting attorney, on the date shown below:
Robert Mayor
Deputy Attorney General
Ofce of the Attorney General
George S. Mickelson Building
1302 East Highway 14, Suite 1
Pierre, South Dakota 57501-8501

Dated this 4th of August, 2014.
_________________________________________


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