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.
OF 1 3
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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8/4/14, 2:47 PM Annette Bosworth attorney attempts to exit the circus. Taliaferro les to withdraw from case. | South Dakota War College
Page 1 of 8 http://dakotawarcollege.com/annette-bosworth-attorney-attempts-to-exit-the-circus-taliaferro-les-to-withdraw-from-case/
Annette Bosworth apparently is less interested in staying out of jail than she is in being in the
public eye. And the attorney whom she hired to keep her out of jail is not satised that Boz has
that same goal in mind:
Just days after representing Annette Bosworth in court and releasing a statement
distancing Bosworth from former spokesman Lee Stranahan, Brandon Taliaferro is
withdrawing as Bosworths attorney.
Taliaferro says Bosworth hasnt fullled her obligations to him as her attorney.
Read it all here.
If you read the rest of the article, it sounds as if she was warned about something, and she didnt
heed her attorneys warning.
This doesnt surprise me. Id had a chance to speak with Mr. Taliaferro, and he seemed like some-
one focused on doing his job. From the release he sent out earlier in the week, he was focused on
cutting through the BS, and doing what he was hired to do defend Annette Bosworth from the
charges led against her.
2014 ELECTIONS
ANNETTE BOSWORTH ATTORNEY
ATTEMPTS TO EXIT THE CIRCUS.
TALIAFERRO FILES TO WITHDRAW FROM
CASE.
JULY 18, 2014 | SDSEN_2014 | 29 COMMENTS
South Dakota War College
8/4/14, 2:47 PM Annette Bosworth attorney attempts to exit the circus. Taliaferro les to withdraw from case. | South Dakota War College
Page 2 of 8 http://dakotawarcollege.com/annette-bosworth-attorney-attempts-to-exit-the-circus-taliaferro-les-to-withdraw-from-case/
He issued a statement designed to remove his client from the circus she was attending with her
Spokes-porn-guy, Lee Stranahan. But just when it seemed she was free, she rushed right back into
the big top.
I dont think Ive ever seen anyone so hell bent as Annette Bosworth to go down in ames.
Personally, I dont think this case should have ever gone to trial. In a normal world, why would
anyone waste the resources of the court in this manner? I dont know the minds of the prosecu-
tors, but given its a white collar petition matter, I suspect that this whole thing could have been
pled down to a misdemeanor, and gone away with a ne.
Instead, Annette is hell bent to ride the aming stallion into the sunset.
By which I mean shes going to be convicted of a felony, stripped of her license to be a physician,
and could end up spending some time in the iron-bar hotel.
And the circus continues to linger in town, far past when anyone wants to attend.
29 THOUGHTS ON ANNETTE BOSWORTH ATTORNEY ATTEMPTS TO EXIT THE CIRCUS.
TALIAFERRO FILES TO WITHDRAW FROM CASE.
JULY 18, 2014 AT 6:59 PM
Obviously this lawyer is simply a pawn of Marty Jackley and Mike Rounds. Oh. And Leder-
man. And Arends. Obviously.
JULY 19, 2014 AT 12:06 AM
I thought it was Ravnsborgs job (since he is the lawyer) to recruit the lawyers, lol, all of
these conspiracies and plants are a bit amusing though.
Facebook Facebook 9 Twitter Twitter 11
Anonymous
Anonymous
8/4/14, 2:47 PM Bosworth attorney withdraws from case
Page 1 of 3 http://www.argusleader.com/story/davidmontgomery/2014/07/18/bosworth-attorney-withdraws/12857389/
POLITICAL SMOKEOUT
Bosworth attorney withdraws from case
David Montgomery, dmontgomery@argusleader.com 5:27 p.m. CDT July 18, 2014
Just days after representing Annette Bosworth in court and releasing a statement
(/story/davidmontgomery/2014/07/15/bosworth-stranahan/12674341/) distancing Bosworth from former
spokesman Lee Stranahan, Brandon Taliaferro is withdrawing as Bosworth's attorney.
Taliaferro says Bosworth hasn't fulfilled her obligations to him as her attorney.
In his motion, he asks the judge to let him withdraw because of Rule 1.16(b)(5)
(http://www.sdbar.org/rules/rules.shtm) of the South Dakota Bar Association's Rules of Professional Conduct.
That rule says attorneys can stop representing someone if "the client fails substantially to fulfill an obligation to
the lawyer regarding the lawyer's services and has been given reasonable warning that the lawyer will withdraw unless the obligation is fulfilled."
The motion, filed Thursday at the Hughes County Clerk of Courts, doesn't go into detail about what obligation Bosworth didn't fulfill.
The judge has yet to rule on Taliaferro's request to withdraw.
Taliaferro was not Bosworth's first attorney. She was initially represented by Sioux Falls attorney Jeff Beck.
Taliaferro was a notable pick for her attorney because he has clashed with Attorney General Marty Jackley before. He was investigated by Jackley's
Division of Criminal Investigation for alleged witness tampering, charges that were later thrown out. Jackley's office is now prosecuting Bosworth for
alleged felony election law violations.
Read or Share this story: http://argusne.ws/1mYgCoB
(Photo: Elisha Page - Argus Leader)
8/4/14, 2:49 PM Madville Times
Page 1 of 6 http://madvilletimes.com/2014/07/candidate-for-bosworths-next-attorney-accused-child-rapist-jansen/
COMMENTS FEED POSTS FEED
From Madison ! Spear"sh: real liberal media for #e great sta$ of Sou# Dakota
J UL
31
2 0 1 4
Posted by caheidelberger
I can think like Chad and Annette. It makes me ill, but I can do it.
Annette Bosworth may have just found her next attorney. After betraying
Joel Arends and monkey-wrenching Brandon Taliaferro's best efforts
to defend her, the former fake Senate candidate, petition fraudster, and
drama queen may be the least appealing legal client since Ted Klaudt.
But Attorney General Marty Jackley, U.S. Attorney Brendan Johnson,
and Hughes County States Attorney Wendy Kloeppner may have just
delivered the indefensible doctor a defense attorney: Christopher Robert
Jansen. The Selby attorney served a term as Walworth County states
attorney from 2009 to 2012, then resigned a few weeks early to enter
private practice after voters turned him out in favor of James Hare. And
Tuesday, Jackley, Johnson, and Kloeppner had him arrested for three
counts of first-degree rape. The three alleged victims are under the age of
13.
One would think that no reasonable client would want to pick Jansen for
counsel right now. "Innocent until proven guilty" doesn't stop defendants
from minimizing their exposure to possible bad press. But in
the "writhing snakepit of treachery and mind games" of Team Bosworth,
no press is bad press. In Bosworth and husband Chad Haber's reading of
Chad's bible, The 48 Laws of Power, the client no attorney wants and the
attorney no client wants are the perfect unpredictable, attention-getting,
water-stirring, misdirecting match.
Jansen would also be the next poster boy for Chad Haber's hashtag
exploitation of child rape victims. As the centerpiece of his quixotic but
devious bid for the Libertarian nomination for attorney general, Haber is
charging that Attorney General Jackley has a "big pedophilia problem" in
his failure to prosecute child rapist Richard Mette as vigorously as he
should have. Haber needs to stop the Attorney General's new prosecution
of child rape from puncturing Haber's political narrative. Haber thus
needs to bring Jansen into his wife's camp and pump him for
information with which Haber could spin Jansen's prosecution into
persecution. He needs to make Jansen's story just another aspect
of corruption in South Dakota, just like Jackley's prosecution of Haber's
wife.
Expect Bosworth to announce Jansen as her attorney, and expect Haber
to launch a new hashtag any day.
* * *
Even if The 48 Laws of Power can be read as a bastard's
handbook, he wrote it to demystify the dirty tricks of the
executives he encountered during a dispiriting period as a
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SoDakLiberty
Republican meet and greet with Rounds
in Aberdeen today: This evening there is
a Meet & Greet in Aberdeen celebrating
the opening of the Brown County
Republican Volunteer Center. Here are the
details from the events invitation: When:
Monday, August 4 Wh
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Full steam ahead on the indoor pool at
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Lookout Mountai n, Spear"sh, SD Lookout Mountai n, Spear"sh, SD
Candidate for Bosworths Next Attorney:
Accused Child Rapist Jansen
8/4/14, 2:49 PM Madville Times
Page 2 of 6 http://madvilletimes.com/2014/07/candidate-for-bosworths-next-attorney-accused-child-rapist-jansen/
Hollywood screenwriter. "I felt like a child exposing what the
parents are up to and laughing at it," he says. "Opening the
curtain and letting people see the Wizard of Oz."
....Greene claims that most of the emails he receives are from
readers who used his first book to understand and outwit
manipulative people, but surely he has inadvertently created a few
scoundrels himself? "There are people on the borderline and
maybe the book helps them to move into that sociopathic realm
so then I feel bad," he concedes, "but mainly it's positive" [Dorian
Lynskey, "Robert Greene on His 48 Laws of Power: 'I'm Not Evil
I'm a Realist'," The Guardian, 2012.12.93].
* * *
Update 15:17 CDT: OopsJansen might have trouble representing
Bosworth from the Hughes County Jail. At Jansen's first hearing in
Pierre this afternoon, Jansen did not seek and the judge did not set bail.
State's attorney Kloeppner says the state believes Jansen is a danger to
the community and to himself.
Tweet Tweet 2 0
POSTED BY CAHEIDELBERGER | TAGGED AS: ANNETTE BOSWORTH, CHAD HABER,
CHRISTOPHER ROBERT JANSEN, CRIME, POLITICS
24 Responses to Candidate for Bosworths Next Attorney:
Accused Child Rapist Jansen
mike from iowa
2014. 07. 31 AT 15: 45
This could get uglier in a hurry. On a side note-the alternate universe(PP)
mentioned John Thune's efforts to make union financial dealings transparent.
Roger Cornelius
2014. 07. 31 AT 15: 57
mike,
The headline in the RCJ was "Thune to Fight Union Corruption", it appeared the
same day that South Dakota Democrats were fighting Republican legislature for
transparency over the GOED/EB-5 scandal.
mike from iowa
2014. 07. 31 AT 16: 00
Thanks Roger. I just happened to see this at PP's blog while I checked out his
coverage of Jansen's arrest.
JeniW
2014. 07. 31 AT 16: 03
Safest place for him to be because there might be someone(s) who would do him
harm, plus providing room and board?
There are people who do not take too kindly of people who are, or have been
accused of, sexually abusing children.
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2014.08.02
Constant Conservative
Breaking a Few Friday Targets: Racism is
alive and well, in Cuba. That would
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