UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF INDIANA

HAMMOND DIVISION

UNITED STATES OF AMERICA

Plaintiff,

v. CASE NUMBER: 2:14-CR-63

GEORGE GASICH

Defendant.

MOTION TO WITHDRAW 

The undersigned, as attorney for the Defendant, George Gasich, moves to 

withdraw as counsel for the Defendant George Gasich, and in support shows:

1. On March 11, 2015, the undersigned counsel entered his appearance as standby counsel. [DE 42].

2. Between March 11, 2015 and October 20, 2015, the undersigned counsel had 

no communication with Defendant George Gasich despite efforts by the 

undersigned counsel. 

3. On October 20, 2015 before a scheduled status conference before this Court, 

Defendant George Gasich began consulting with the undersigned counsel in 

his capacity as stand-by counsel.

4. On October 21, 2015, Defendant George Gasich appeared before the Court 

and stated his intention to plead guilty to Count 2 of the Indictment without 

the benefit of a plea agreement. Prior to the change of plea hearing, the Court

ordered, at the Defendant’s request, that the undersigned counsel become the 

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attorney for Defendant. The Defendant then proceeded to plead guilty to 

Count 2 of the Indictment without the benefit of a plea agreement. [DE 92].

5. The undersigned counsel and Defendant George Gasich have experienced a 

complete breakdown in the attorney-client relationship. Specifically, 

Defendant George Gasich does not want to accept the undersigned counsel’s 

representation and has been unwilling to communicate in a manner sufficient 

to allow the undersigned counsel to effectively represent Defendant Gasich.

The undersigned now believes that Defendant George Gasich lacks 

confidence in the representation of the undersigned to the extent that the 

attorney-client relationship is irretrievably broken. The breakdown of that 

relationship has resulted in an unwillingness on the part of Defendant Gasich 

to communicate with the undersigned counsel regarding the status or future 

of this case.

6. Defendant George Gasich has represented to the undersigned counsel that he 

has no objection to this motion. However, Defendant George Gasich failed to 

specify to the undersigned counsel whether he wishes to proceed pro se or be 

appointed substitute CJA counsel.

7. Defendant George Gasich’s response to the First Draft of the Presentence 

Investigation Report is due no later than February 4, 2016. [DE 114].

8. Defendant George Gasich’s sentencing hearing is scheduled for March 25, 

2016 at 10:30 a.m. [117].

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9. The undersigned counsel will be in Portland, Oregon from February 1-

February 4, 2016 attending a meeting of Federal Defenders sponsored by the 

Administrative Office of the United States Courts. If the Court schedules a 

hearing pursuant to this motion, the undersigned counsel can make himself 

available to participate by telephone or have another lawyer from the Federal 

Defender’s Office appear for the undersigned counsel at the hearing.

WHEREFORE the undersigned, as counsel for Defendant George Gasich, moves 

to withdraw as counsel for the Defendant.

Dated: January 21, 2016

Respectfully submitted,

Northern District of Indiana

Federal Community Defenders, Inc.

By: s/ Jerome T. Flynn 

Jerome T. Flynn

31 East Sibley Street

Hammond, IN 46320

Phone: (219) 937-8020

Fax: (219) 937-8021

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CERTIFICATE OF SERVICE

I hereby certify that, on January 21, 2016 , I electronically filed the foregoing 

with the Clerk of the Court using the CM/ECF system which sent notification of such 

filing to the following:

Randall M. Stewart – AUSA

Randall.Stewart@usdoj.gov

Nathaniel L Whalen - AUSA 

nathaniel.whalen@usdoj.gov

Mark A. Psimos

psimoslaw@airbaud.net

s/ Jerome T. Flynn

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