IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK¶
GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS,¶
Plaintiff,¶
v.¶
JPMORGAN CHASE BANK, N.A.¶
Defendant/Third-Party Plaintiff.¶
JPMORGAN CHASE BANK, N.A.¶
Third-Party Plaintiff,¶
v.¶
JAMES EDWARD STALEY¶
Third-Party Defendant.¶
Case Number. I :22-cv-10904-JSR¶
THIRD-PARTY DEFENDANT JAMES STALEY’S NOTICE OF MOTION TO DISMISS JPMORGAN’S THIRD-PARTY COMPLAINT¶
Pursuant to Rule 12(bX6) of the Federal Rules of Civil Procedure, Third-Party Defendant James Staley hereby respectfully requests that the Court dismiss all claims in the Third-Party Complaint filed by Defendant JPMorgan Chase Bank, N.A. The reasons supporting Mr. Staley’s motion are set forth in the corresponding Memorandum of Law.¶
Complying with this Court’s minute order dated April 18, 2023, this response to JPMorgan’s Complaint is filed by April 24, 2023. Pursuant to the same minute order, JPMorgan’s response to this motion is due by May 8, 2023, Mr. Staley’s reply is due by May 15, 2023, and the Court will hold a hearing at 3:00 p.m. on May 19, 2023, in Courtroom 14B.¶
Date: April 24, 2023 Respectfully submitted,¶
/ /Brendan V. r. Brendan V. Jr. Zachary K. St hen L. Wohlgemuth & CONNOLLY LLP 680 Maine Avenue SW Washington, DC 20024 Tel: (202) 434-5252 Fax: (202) 434-5029 zwarren@wc.com¶
Counsel for Third-Party Defendant James Edward Staley¶