# I N T HE UNITED STATES DISTRICT COURT FOR "I'HE SOUTHERN DISTRICT OF NEW YORK
IN RE JPMORGAN CHASE & CO. DERIVATIVE LITIGATION

Case No. 1:23-cv-03903-JSR

DERIVATIVE ACTION

# DEFENDANT JAMES E. STALEY'S NOTICE OF MOTION TO DISMISS THE AMENDED STOCKTIOI R DERIVATIVE COMPLAINT
Pursuant to Rules 12(IX6) and 23 1 (1) of the Federal Rules of Civil Procedure, Defendant James E. Staley hereby respectfully requests that the Court dismiss all claims in the Complaint filed by Plaintiffs on behalf of Nominal Defendant JPMorgan Chase & Co. The reasons supporting Mr. Staley's motion are set forth in the corresponding Memorandum of Law.

In accordance with the Court's Case Management Plan, ECF No. 16, this response to Plaintiffs' Complaint is filed by July 6, 2023. Per the same order, Plaintiffs' response to this motion is due by July 20, 2023; and Defendants' reply briefs, if any, are due by July 29, 2023.

Date: July 6, 2023 Respectfully submitted,

/s/ John McNichols

Brendan V. Jr.

John McNichols

Zachary

S hen L. Wohlgemuth

& CONNOLLY LLP 680 Maine Avenue SW

Washington, DC 20024

Tel: (202) 434-5252

Fax: (202) 434-5029

jmcnichols@wc.com

Counsel for Defendant James Edward Staley