“Pentiuk, Couvreur & Kobiljak, P.C. and Kerry L Morgan are counsel for Defendant, OATH KEEPERS, only, in this matter… That Defendant, Oath Keepers, has not communicated or responded to counsel after counsel reached out several times and there has been a breakdown of communication… That Defendant, Oath Keepers, has not paid its legal fees and costs due and Owing to Pentiuk, Couvreur & Kobiljak, P.C. and have not provided information to the undersigned, if and when, the legal fees and costs will be paid… Counsel also requested Oath Keepers obtain substitute counsel in avoidance Of this Motion, but have received no such substitution… On November 1, 2021 Defendant, Oath Keepers, was advised that the motion herein would be filed with this Court on November 10, 2021 and withdrawing from this matter if no substitution Of counsel was received… On November 10, 2021, Pentiuk, Couvreur & Kobiljak did not hear from Defendant, Oath Keepers, nor receive a substitution of counsel, necessitating the filing of this motion.”

“WHEREFORE, Pentiuk, Couvreur & Kobiljak, P.C. and Kerry L. Morgan respectfully request this Honorable Court grant the following relief: 1. Grant the motion to withdraw as counsel for Defendant, Oath Keepers, Only; and 2. Order Defendant Oath Keepers to retain new counsel and an Appearance of new counsel be filed within thirty (30) days of the filing of an Order” says Pentiuk, Couvreur & Kobiljak’s motion to withdraw from defending the Oath Keepers as an entity in Congressman Bennie Thompson’s lawsuit against them.