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Case 2:16-cr-00046-GMN-PAL Document 653 Filed 08/26/16 Page 1 of 4

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DRUMMOND LAW FIRM


Craig W. Drummond, Esq.
Nevada Bar No. 11109
810 S. Casino Center Blvd., Suite 101
Las Vegas, NV 89101
T: (702) 366-9966
F: (702) 508-9440
Craig@DrummondFirm.com
Attorney for Defendant

DRUMMOND LAW FIRM


810 S. CASINO CENTER BLVD., SUITE 101
LAS VEGAS, NEVADA 89101
DRUMMONDFIRM.COM

UNITED STATES DISTRICT COURT


DISTRICT OF NEVADA

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UNITED STATES OF AMERICA,

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Plaintiff,

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vs.

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O. SCOTT DREXLER,
Defendant.

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Case No.:2:16-cr-00046-GMN-PAL

MOTION TO WITHDRAW AS
COUNSEL OF RECORD

COMES NOW Defendant, O. SCOTT DREXLER, by and through his attorney of record,

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CRAIG W. DRUMMOND, ESQ., and hereby requests for the appointment of new CJA defense

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counsel in this matter. This request is made base on the following facts and legal points and

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authorities as outlined herein.


Given that Mr. Drexler remains in Federal custody in Pahrump, Nevada pending trial this

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is a request that this matter be heard on an expedited basis.

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//

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Case 2:16-cr-00046-GMN-PAL Document 653 Filed 08/26/16 Page 2 of 4

DECLARATION

I, CRAIG W. DRUMMOND, ESQ., in accordance with NRS 53.045 and under penalty of perjury

make the following declaration:

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DRUMMOND LAW FIRM
810 S. CASINO CENTER BLVD., SUITE 101
LAS VEGAS, NEVADA 89101
DRUMMONDFIRM.COM

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1.

That Craig W. Drummond, Esq. is a duly qualified, practicing and licensed attorney

in the State of Nevada and State of Missouri and am the CJA counsel appointed to defendant
Defendant O. Scott Drexler.
2.

That a breakdown of the attorney-client relationship has deteriorated between

counsel and Defendant such that counsel can no longer effectively represent the Defendant
in both pre-trial activities and at trial.
3.

That both the Defendant, and counsel, are together requesting that new CJA counsel

be appointed in this matter.


4.

That further details of this request can be outlined at a closed hearing.

5.

That as a result of the aforementioned facts, CRAIG W. DRUMMOND, ESQ.,

desires for the Court to issue an Order allowing counsel to withdraw as attorney of record
in this matter.
DATED this 26th day of August 2016.

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By:

/ / SIGNED / /_________
CRAIG W. DRUMMOND, ESQ.
Nevada Bar No. 11109
Attorney for Defendant

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Case 2:16-cr-00046-GMN-PAL Document 653 Filed 08/26/16 Page 3 of 4

MEMORANDUM OF POINTS AND AUTHORITIES

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In this matter it is clear that there are irreconcilable differences that warrant withdrawal

because the attorney-client relationship has deteriorated between counsel and Defendant such that

counsel can no longer effectively represent Defendant.

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DRUMMOND LAW FIRM
810 S. CASINO CENTER BLVD., SUITE 101
LAS VEGAS, NEVADA 89101
DRUMMONDFIRM.COM

STATEMENT OF FACTS

This request complies with Nevada Rule of Professional Conduct 1.16 because

[w]ithdrawal can be accomplished without material adverse effect on the interests of the client.

Local Rule 10-6(b) requires leave of court and that notice of this request be served on both the

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Defendant and on opposing counsel.

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CONCLUSION

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WHEREFORE, both the Defendant, and counsel, are together requesting that new CJA
counsel be appointed in this matter.

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DATED this 26th day of August, 2016.

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Respectfully Submitted,
DRUMMOND LAW FIRM

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/ / SIGNED / /
.
Craig W. Drummond, Esq.
Nevada Bar No. 11109
810 S. Casino Center Blvd., Suite 101
Las Vegas, NV 89101
T: (702) 366-9966
F: (702) 508-9440
Craig@DrummondFirm.com
Attorney for Defendant Drexler

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Case 2:16-cr-00046-GMN-PAL Document 653 Filed 08/26/16 Page 4 of 4

CERTIFICATE OF SERVICE

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I HEREBY CERTIFY that on the 26th day of August, 2016, the undersigned served the
foregoing MOTION TO WITHDRAW AS COUNSEL OF RECORD on all counsel herein by
causing a true copy thereof to be filed with the Clerk of Court using the CM/ECF system, which
was served via electronic transmission by the Clerk of Court pursuant to local order.

DRUMMOND LAW FIRM


810 S. CASINO CENTER BLVD., SUITE 101
LAS VEGAS, NEVADA 89101
DRUMMONDFIRM.COM

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/ / SIGNED / /
.
An Employee of DRUMMOND LAW FIRM

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