Response to Withdrawal (Including Exhibits)

5/21/2018 Response to Withdrawal (Including Exhibits)

1/8

COMES NOW, Annette Marie Bosworth, in response to her attorney Brandon TaliaferrosMotion to Withdrawal As Counsel for Defendant.

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

1. Taliaferro has failed to state a specific 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 fulfill an obligation to the lawyer regarding the lawyers

services and has been given reasonable warning that the lawyer will withdraw unless the

obligation is fulfilled. Taliaferros Motion fails to cite any specific example.

2. Further, I do not believe I have failed substantially to fulfill an obligation to the lawyerregarding Taliaferros services.

3. Because Taliaferros Motion to Withdraw contains no facts or specific 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 filed his Motion to

Withdraw because I failed to pay a retainer due on July 25th. Mr. Taliaferro filed 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 fulfilled to Taliaferro.

OF1 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


2/8

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

find 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 find 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 #100Sioux Falls, SD 57108

(605) 371-6899

[email protected]

CERTIFICATE OF SERVICE

The undersigned hereby certifies that he served a copy of this legal document upon the office of

the prosecuting attorney, on the date shown below:

Robert Mayor

Deputy Attorney General

Office 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.

_________________________________________

OF2 3


3/8

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4/8

8/4/14Annette Bosworth attorney attempts to exit the circus. Taliaferro files to withdraw from case. | South Dakota War College

Phttp://dakotawarcollege.com/annette-bosworth-attorney-attempts-to-exit-the-circus-taliaferro-files-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 satisfied that Boz has

that same goal in mind:

Just days after representingAnnette 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 fulfilled 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 didn

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 o

cutting through the BS, and doing what he was hired to do defend Annette Bosworth from the

charges filed 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
http://dakotawarcollege.com/annette-bosworth-attorney-attempts-to-exit-the-circus-taliaferro-files-to-withdraw-from-case/http://dakotawarcollege.com/author/sdsen_2014/http://dakotawarcollege.com/annette-bosworth-attorney-attempts-to-exit-the-circus-taliaferro-files-to-withdraw-from-case/#commentshttp://dakotawarcollege.com/category/2014-elections/http://dakotawarcollege.com/http://dakotawarcollege.com/http://dakotawarcollege.com/annette-bosworth-attorney-attempts-to-exit-the-circus-taliaferro-files-to-withdraw-from-case/#commentshttp://dakotawarcollege.com/author/sdsen_2014/http://dakotawarcollege.com/annette-bosworth-attorney-attempts-to-exit-the-circus-taliaferro-files-to-withdraw-from-case/http://dakotawarcollege.com/category/2014-elections/http://www.argusleader.com/story/davidmontgomery/2014/07/18/bosworth-attorney-withdraws/12857389/http://www.argusleader.com/story/davidmontgomery/2014/07/15/bosworth-stranahan/12674341/


5/8

8/4/14Annette Bosworth attorney attempts to exit the circus. Taliaferro files to withdraw from case. | South Dakota War College

Phttp://dakotawarcollege.com/annette-bosworth-attorney-attempts-to-exit-the-circus-taliaferro-files-to-withdraw-from-case/

He issued a statement designed to remove his client from the circusshe was attending with her

Spokes-porn-guy, Lee Stranahan. But just when it seemed she was free, she rushed right back in

the big top.

I dont think Ive ever seen anyone so hell bent as Annette Bosworth to go down in flames.

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 bee

pled down to a misdemeanor, and gone away with a fine.

Instead, Annette is hell bent to ride the flaming stallion into the sunset.

By which I mean shes going to be convicted of a felony, stripped of her license to be a physicianand 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 Twitter

Anonymous

Anonymous
http://dakotawarcollege.com/annette-bosworth-attorney-attempts-to-exit-the-circus-taliaferro-files-to-withdraw-from-case/#comment-609842http://dakotawarcollege.com/annette-bosworth-attorney-attempts-to-exit-the-circus-taliaferro-files-to-withdraw-from-case/#comment-609796http://instagram.com/p/qfK0UBwG7Y/http://www.democraticunderground.com/10021311425http://dakotawarcollege.com/taliaferro-stranahan-relieved-of-spokesman-duties/


6/8

8/4/14Bosworth attorney withdraws from case

Phttp://www.argusleader.com/story/davidmontgomery/2014/07/18/bosworth-attorney-withdraws/12857389/

POLITICAL SMOKEOUT

Bosworth attorney withdraws from case

David Montgomery, [email protected] 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 Con

That rule says attorneys can stop representing someone if "the client fails substantially to fulfill an obliga

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

Division of Criminal Investigation for alleged witness tampering, charges that were later thrown out. Jackley's office is now prosecuting Bosworth fo

alleged felony election law violations.

Read or Share this story: http://argusne.ws/1mYgCoB

(Photo: Elisha Page - Argus Leader)
http://www.sdbar.org/rules/rules.shtmhttp://www.sdbar.org/rules/rules.shtmhttp://www.argusleader.com/story/davidmontgomery/2014/07/15/bosworth-stranahan/12674341/http://www.argusleader.com/blog/davidmontgomery/


7/8

8/4/14Madville Times

Phttp://madvilletimes.com/2014/07/candidate-for-bosworths-next-attorney-accused-child-rapist-jansen/

COMMENTS POSTS FEED

From Madison !Spear"sh: real liberal media for #e great sta$of Sou#Dakota

J UL

312 0 1 4

Posted by caheidelberger

Ican think like Chad and Annette. It makes me ill,but I can do it.

Annette Bosworth may have just found her next attorney. Afterbetraying

Joel Arendsand monkey-wrenching Brandon Taliaferro's best efforts

to defend her, the former fake Senate candidate, petition fraudster, and

drama queenmay 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 mayhave just

delivered the indefensibledoctor a defense attorney: Christopher RobertJansen. The Selby attorney served a term as Walworth County states

attorney from 2009 to 2012, then resigned a few weeks earlyto enter

private practice after voters turned him out in favor of James Hare. And

Tuesday, Jackley, Johnson, and Kloeppnerhad him arrested for three

counts of first-degree rape. The three alleged victims are under the age of

13.

Onewould think that no reasonable client would want to pick Jansen for

counsel right now. "Innocent until proven guilty" doesn't stop defendants

fromminimizing 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, The48 Laws of Power, the client no attorneywants 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

exploitationof 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 Metteas 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 Powercan 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

recent commentsrecent comments

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Candidate for Bosworths Next Attorney:Accused Child Rapist Jansen
https://www.facebook.com/pages/Chad-Haber-for-South-Dakota-Attorney-General/246255215585552?sk=infohttp://madvilletimes.com/2014/08/aclu-writes-letter-miller-school-board-boots-gideon-bibles/#comment-349440http://madvilletimes.com/2014/07/contacthttp://madvilletimes.com/2014/08/aclu-writes-letter-miller-school-board-boots-gideon-bibles/#comment-349441http://cgt411.tech.purdue.edu/covey/48_laws_of_power.htmhttp://cgt411.tech.purdue.edu/covey/48_laws_of_power.htmhttp://cgt411.tech.purdue.edu/covey/48_laws_of_power.htmhttp://www.theguardian.com/books/2012/dec/03/robert-greene-48-laws-of-powerhttp://www.theguardian.com/books/2012/dec/03/robert-greene-48-laws-of-powerhttp://www.keloland.com/newsdetail.cfm/fmr-states-attorney-facing-child-rape-charges/?id=167591http://www.mobridgetribune.com/?s=jansen+rape&search=Searchhttps://www.facebook.com/MyersforGovernorhttp://www.mobridgetribune.com/?p=3735https://www.facebook.com/MyersforGovernorhttp://thejansenlawoffice.com/aboutus.htmlhttp://thejansenlawoffice.com/aboutus.htmlhttps://www.facebook.com/MyersforGovernorhttps://www.facebook.com/MyersforGovernorhttps://www.facebook.com/MyersforGovernorhttps://www.facebook.com/MyersforGovernorhttps://www.facebook.com/MyersforGovernorhttp://madvilletimes.com/2014/02/bosworth-gambling-with-base-connect-whos-scamming-whom/http://madvilletimes.com/2014/06/bosworth-should-read-indictment-charges-include-signatures-before-after-philippines/http://madvilletimes.com/2014/08/aclu-writes-letter-miller-school-board-boots-gideon-bibles/#comment-349447http://way2gosd.com/http://madvilletimes.com/2014/06/bosworth-blames-arends-campaigner-davis-refutes-stranahan-makes-bank/http://www.argusleader.com/story/davidmontgomery/2014/07/18/bosworth-attorney-withdraws/12857389/http://www.argusleader.com/story/davidmontgomery/2014/07/18/bosworth-attorney-withdraws/12857389/http://madvilletimes.com/2014/06/bosworth-blames-arends-campaigner-davis-refutes-stranahan-makes-bank/http://way2gosd.com/http://madvilletimes.com/2014/07/candidate-for-bosworths-next-attorney-accused-child-rapist-jansen/http://way2gosd.com/http://madvilletimes.com/http://madvilletimes.com/http://madvilletimes.com/http://madvilletimes.com/http://madvilletimes.com/http://madvilletimes.com/about/http://madvilletimes.com/contact/http://madvilletimes.com/contact/http://madvilletimes.com/policies/http://madvilletimes.com/projects/http://madvilletimes.com/feed/rss/http://madvilletimes.com/comments/feed/http://madvilletimes.com/2014/07/candidate-for-bosworths-next-attorney-accused-child-rapist-jansen/http://madvilletimes.com/http://madvilletimes.com/projects/http://madvilletimes.com/policies/http://madvilletimes.com/contact/http://madvilletimes.com/about/http://madvilletimes.com/http://npntestfeed.blogspot.com/2014/08/nbpnpn-poll-rounds-holds-13-point-lead.htmlhttp://npntestfeed.blogspot.com/http://www.southdacola.com/blog/2014/08/full-steam-ahead-on-the-indoor-pool-at-spellerberg/http://www.southdacola.com/bloghttp://sodakliberty.com/2014/08/04/republican-meet-and-greet-with-rounds-in-aberdeen-today/http://sodakliberty.com/http://madvilletimes.com/2014/07/policies/advertising/http://madvilletimes.com/2014/07/contacthttp://madvilletimes.com/2014/07/contacthttps://www.facebook.com/MyersforGovernorhttp://way2gosd.com/http://madvilletimes.com/2014/08/aclu-writes-letter-miller-school-board-boots-gideon-bibles/#comment-349440http://madvilletimes.com/2014/08/aclu-writes-letter-miller-school-board-boots-gideon-bibles/#comment-349441http://madvilletimes.com/2014/08/aclu-writes-letter-miller-school-board-boots-gideon-bibles/#comment-349442http://madvilletimes.com/2014/08/aclu-writes-letter-miller-school-board-boots-gideon-bibles/#comment-349443http://madvilletimes.com/2014/08/20-questions-chad-haber-says-hell-talk-scandals-on-facebook/#comment-349444http://madvilletimes.com/2014/08/aclu-writes-letter-miller-school-board-boots-gideon-bibles/#comment-349445http://madvilletimes.com/2014/08/aclu-writes-letter-miller-school-board-boots-gideon-bibles/#comment-349446http://madvilletimes.com/2014/08/aclu-writes-letter-miller-school-board-boots-gideon-bibles/#comment-349447http://madvilletimes.com/2014/08/nbp-weiland-trails-rounds-by-13-needs-31000-pressler-dems/#comment-349448http://madvilletimes.com/2014/08/aclu-writes-letter-miller-school-board-boots-gideon-bibles/#comment-349449http://madvilletimes.com/2014/01/taliaferro-schwab-case-shows-the-ugly-politics-of-south-dakota-foster-care/http://madvilletimes.com/2014/07/powers-follows-leaders-finds-bogus-bosworth-signatures-says-spokesman-peddled-porn/https://www.facebook.com/pages/Chad-Haber-for-South-Dakota-Attorney-General/246255215585552?sk=infohttps://twitter.com/MetteScandal/followershttp://cgt411.tech.purdue.edu/covey/48_laws_of_power.htmhttp://www.theguardian.com/books/2012/dec/03/robert-greene-48-laws-of-powerhttp://www.keloland.com/newsdetail.cfm/fmr-states-attorney-facing-child-rape-charges/?id=167591http://www.mobridgetribune.com/?s=jansen+rape&search=Searchhttp://dakotawarcollege.com/selby-man-arrested-on-rape-charges/http://www.mobridgetribune.com/?p=3735http://www.mobridgetribune.com/?p=3352http://thejansenlawoffice.com/aboutus.htmlhttp://rapidcityjournal.com/news/local/top-stories/klaudt-guilty-of-raping-foster-daughters/article_4db736ee-8f9c-5bb3-b6bc-790fe8e227c1.htmlhttp://madvilletimes.com/2014/04/worst-campaign-video-of-2014-annette-bosworth/http://madvilletimes.com/2014/06/bosworth-should-read-indictment-charges-include-signatures-before-after-philippines/http://madvilletimes.com/2014/02/bosworth-gambling-with-base-connect-whos-scamming-whom/http://www.argusleader.com/story/davidmontgomery/2014/07/18/bosworth-attorney-withdraws/12857389/http://madvilletimes.com/2014/06/bosworth-blames-arends-campaigner-davis-refutes-stranahan-makes-bank/http://madvilletimes.com/http://madvilletimes.com/feed/rss/http://madvilletimes.com/comments/feed/


8/8

8/4/14Madville Times

Phttp://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" [DorianLynskey, "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 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 iowa2014 . 07 . 31 A T 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 Cornelius2014 . 07 . 31 A T 15 :57

mike,The headline in the RCJ was "Thune to Fight Union Corruption", it appeared thesame day that South Dakota Democrats were fighting Republican legislature fortransparency over the GOED/EB-5 scandal.

mike from iowa2014 . 07 . 31 A T 16 :00

Thanks Roger. I just happened to see this at PP's blog while I checked out hiscoverage of Jansen's arrest.

JeniW2014 . 07 . 31 A T 16 :03

Safest place for him to be because there might be someone(s) who would do himharm, plus providing room and board?

There are people who do not take too kindly of people who are, or have beenaccused of, sexually abusing children.

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