Joel A Brodsky's motion to withdraw from Savio vs Drew Peterson wrongful death suit (filed December 17.

2012):

Now comes attorney, Joel A. Brodsky, the attorney for Drew Peterson in the instant case, and moves this Court to grant him leave to withdraw as the attorney for Drew Peterson in this cause. In support of this motion the Defendant states: 1. A Defendant in the instant case, Drew Peterson, is also a Defendant in the first degree murder case of People v. Drew Peterson, 09 CF 1040, in which he is charged with the murder of Kathleen Savio, his third wife (hereinafter the Savio murder case). Defendant Peterson has been convicted in that case and posttrial motions are pending. 2. In addition Drew Peterson is also the only suspect in the disappearance and, according to the Illinois State Police, the presumed murder, of his fourth wife Stacy Peterson, (hereinafterthe Stacy Peterson investigation). 3. Until October of this year, in addition to being the attorney for Drew Peterson in the instant case, Joel Brodsky was also lead counsel for Drew Peterson in the Savio murder case as well as the Stacy Peterson investigation. Mr. Brodsky withdrew as Mr. Petersons attorney in the Savio murder case, and the Stacy Peterson investigation, on October 30, 2012. 4. Thereafter, on December 13, 2012, Attorney Steve Greenberg, the current attorney for Defendant Drew Peterson in the Savio murder case, filed a Memorandum in Support of Ineffective Assistance of Counsel Argument (hereinafter the Memo), in the post-trial motion proceedings in the Savio murder case. 5. In the aforesaid Memo, which is thirty (30) pages in length, Attorney Greenberg, acting as the authorized attorney and agent for Drew Peterson, neglected to address at least twenty (20) important post-trial issues such as the use of hearsay at the trial, the use of hearsay previously found to be unreliable, keeping a jury venire for 2 years in violation of the jury statute, violation of the right to speeding trial, the introduction of irrelevant prior-misconduct and botched 2004 investigation evidence, the allowance of improperly disclosed and irrelevant hit man evidence, the barring of evidence of prior perjury by Kathleen Savio, the improper introduction of prior-consistent statement evidence, prosecutorial mistakes and misconduct, etc. Instead Greenberg incredibly focuses the entire thirty (30) pages of the Memo on Joel Brodsky. 6. Attorney Geenberg is acting not out of a desire to act in the best interest of his client, but is acting in such a manner in the post-trial proceedings because Greenberg suffers from a severe mental illness known as pathological narcissism (DSMIV-TR 301.81) 1. Because of this mental illness Attorney Greenberg has irrationally fixated on Joel Brodsky because, among other things, Greenberg resents the attention paid to Mr. Brodsky by the press during the trial of the Savio murder case, as Greenbergs mental illness leads him to believe that only he, and he alone, is entitled to, and worthy of, the attention of, and praise of, others. 2. Further, Attorney Greenberg, because of his pathological narcissism, also developed a hatred and resentment of Joel Brodsky which is causing him to ignore the best interest of his client and to become irrationally tixated and obsessed with Joel Brodsky because, among other things, Mr. Brodsky, (A) prevented Mr. Greenberg from appearing on a daily cable TV segment during the trial known as Greenberg v. Karas on TruTvs In Session program because it was [Diagnostic and Statistical Manual of Mental Disorders

301.81 2 DSM 301. describes two of the nine attributes of pathological narcissism as (1) a person who requires excessive admiration who is (2) often envious of others. (Also, see Exhibit A)] giving away defense strategy, (which also interfered with Greenbergs personal intimate relationship with Beth Karas, the TruTv reporter in this segment which he developed during the trial to get more attention for himself, (B) prevented Greenberg from traveling to New York during the trial to appear on the Piers Morgan T\/ program to talk about the defense strategy, (C) criticized Mr. Greenberg for spending a great deal of time in the press room at the Courthouse during the trial, even when witnesses for the prosecution were on the stand, instead of preparing for his cross-examinations and arguments (E), publically disclosed that Mr. Greenberg was unprepared for the crossexamination of witnesses and making of objections during the trial. 7. Because he is not acting in the best interest of his client Drew Peterson and because Attorney Greenbergs mental illnesses causes him to be irrationally obsessed with Mr. Brodsky, Mr. Greenberg has falsely convinced Drew Peterson that the quickest and easiest way to obtain a reversal of his conviction in the Savio murder case is to make blatantly false and ill considered allegations of misconduct against Mr. Brodsky. 8. Drew Peterson, because he is facing the likelihood of having to spend the rest of his life in prison, is, like a man grasping straws, knowingly accepting and agreeing to make false allegations against l\/lr. Brodsky based on Greenbergs ill conceived advice and counsel. 9. As an example ofjust one (1) of these false allegations revolves around the defense calling Harry Smith to testify at the Savio murder trial. Greenberg is asserting that it was Mr. A Brodskys decision to call Mr. Smith against the vehement advise of himself and others. However, the truth is that Attorney Greenberg agreed that Mr. Smith should be called as a witness for the defense on three (3) separate occasions in the day prior to Mr. Smith being called. Because his mental illness requires him to believe that he can never be wrong, Mr. Greenberg ignores orforgets that there were two (2) independent witnesses, both attorneys, who were present and who heard and saw Mr. Greenberg agree that Nlr. Harry Smith should be called by the Peterson defense, and who will testify under oath to that fact.3 10. Further, because his illness causes him to need to publically promote himself as infallible and special, regardless of the consequences to his client, Attorney Greenberg has entered into an agreement with reporter Stacy St. Clair of the Chicago Tribune, whereby he leaked sealed and privileged information to her for her news stories on the Peterson case, and she in exchange promoted Greenberg in her articles in a manner which placated his pathological narcissism, (and turned herself and the Chicago Tribune effectively into Greenbergs public relations agent). This - agreement between Stacy St. Clair and Attorney Greenberg goes back to Greenbergs representation of Brian Dugan in the Nacarrico murder case in DuPage County.4 11. However, in what is the final straw that requires Mr. Brodskys withdrawal in the instant case, due to his pathological fixation on Mr. Brodsky, Attorney Steve Greenberg has committed what is probably the single biggest legal mistake in the history of jurisprudence. In the December 13, 2012 Memo in the Savio murder case Attorney Steve Greenberg quoted directly December 13, 2012 Memo in the Savio murder case Attorney Steve Greenberg quoted directly from a November 24, 2012, letter that Mr. Brodsky sent to Drew Peterson that concerned

privileged matters. By doing this Greenberg has most assuredly waived the attorney-client privilege regarding the contents and subject matter of that letter, which is extremely sensitive on a matter still being investigated by the Will County States Attorneys office, and which may lead to the unearthing of Greenbergs illness also causes him to forgets that when Smith was called it was he, Greenberg, who went out into the hallway to get Mr. Smith and it was he who escorted Mr. _Smith into the Courtroom. It is public record that a copy of Judge Whites 2010 hearsay hearing decision in the Savio murder case, which he sealed by court order, was leaked to Stacy St. Clair of the Chicago Tribune (and no other reporter), very shortly after Attorney Greenberg joined the Peterson defense team. A reading of her published articles clearly show a promotion of Attorney Greenberg. The leak of the hearsay hearing decision was clearly prejudicial to Drew Peterson. St. Clair also had access that no other reporter had to sealed discovery documents in the Dugan case. Evidence against Peterson. 12. Therefore, because of this unfathomable error by Attorney Steve Greenberg, Petersons current attorney, Joel Brodsky fully and reasonably expects to be called as a witness against Mr. Peterson (and another person) either before the grand july and/or in a future prosecution against Drew Peterson (and another person). 13. Therefore, because of this major and unbelievable legal misstep by Attorney Steve Greenberg, Mr. Brodsky will be a witness against Drew Peterson, and therefore he cannot remain as Petersons attorney in this case. 14. Joel Brodsky has sent a substitution of attorneys to Drew Peterson to sign so that he could withdraw without the necessity for the bringing of this motion. However, Mr. Peterson has refused to sign and return this document, (most probably again on the ill conceived advice of Steve Greenberg), thereby requiring the bringing of this motion.