# 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,

v.

JAMES EDWARD STALEY

Third-Party Defendant.

Case Number: 1:22-cv-10904-JSR

# JAMES EDWARD STALEY'S MOTION FOR LEAVE TO WITHDRAW JONATHAN DUNN AS COUNSEL OF RECORD
Pursuant to Rule 1.4 of the Local Rules of the United States District Courts for the Southern and Eastern Districts of New York, Third-Party Defendant, James Staley, by and through undersigned counsel, respectfully submits this Motion for Leave to Withdraw Jonathan Dunn as Counsel of Record. In support, Third-Party Defendant states as follows:

- I. On May 24, 2023, the Court entered an Order [Docket No. 164] granting admission pro hac vice to Jonathan Dunn as counsel for Third-Party Defendant in the abovecaptioned litigation.
- 2. Third-Party Defendant now moves for leave to withdraw Mr. Dunn's appearance in this action because of Mr. Dunn's forthcoming departure from & Connolly LLP on September 1, 2023.

3. Withdrawal is sought with notice to and consent from Third-Party Defendant. Third-Party Defendant remains represented in this action by legal counsel from Connolly, including but not limited to undersigned counsel.

4. Granting this motion will not cause any undue delay in these proceedings or prejudice any party.

For good cause shown, Third-Party Defendant James Staley respectfully requests that the Court grant this motion and enter an order permitting the withdrawal of Jonathan Dunn as counsel of record and removing him from the list of attorneys receiving electronic notices of filings and proceedings in this action.

Dated: August 31, 2023 Respectfully submitted,

By: /s/ Jonathan Dunn

Brendan V. Jr. John M. McNichols Zachary K. Eden Schiffmann Jonathan Dunn & CONNOLLY LLP 680 Maine Avenue SW Washington, DC 20024 Tel: (202) 434-5252 Fax: (202) 434-5029 bsullivan@wc.com

Ste hen L. Wohlgemuth & CONNOLLY LLP 650 Fifth Avenue, Suite 1500 New York, NY 10019 Tel: (202) 434-5390 Fax: (202) 434-5029 swohlgemuth®wc.com Counsel for Third-Party Defendant James Edward Staley