State of California et al v. Trump et al

Filing 127

MOTION to Withdraw as Attorney filed by John Bellinger, III, Richard Bernstein, Peter Keisler, Carter Phillips, Christopher Shays, Stanley Twardy, Christine Todd Whitman. Responses due by 5/22/2019. Replies due by 5/29/2019. (Attachments: # 1 Proposed Order)(Dollan, Matthew) (Filed on 5/8/2019)

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Richard Mancino (pro hac vice)
[e-mail]
Shaimaa M. Hussein (p1-0 hac vice)
[e-mail]
Matthew Dollan (pro hoc vice)
[e-mail]
WILLME FARR & GALLAGHER LLP
787 Seventh Avenue
New York, NY 10019
Telephone: [phone]
Facsimile: [phone]

Richard D. Bernstein (pro hac vice pending)
1875 K Street, N.W.
Washington, D.C. 20006-1238
Telephone: [phone]
rbernsteinlaw @ gmail .com
Counselfor Amici Curiae christopher Sliays, christine Todd Whitman, Peter Keisler, Carter
Phillips, John Bellinger III, Stanley Twcirdy, and Richard Bel7zstein

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
OAKLAND DIVISION

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STATE Of CALIFORNIA, et al.,

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David W. Evans
HAIGHT BROWN & BONESTEEL
Three Embarcadero Center, Suite 200
San Francisco, CA 94111
Telephone: [phone]
Facsimile: [phone]
devans @hbb]aw.com

Plaintiffs,
V.

DONALD J. TRUMP, in his official capacity as
President of the United States of America, et al.,

Defendants.

MATTHEW DOLLAN’S NOTICE OF
MOTION AND MOTION TO
WITHDRAW AS COUNSEL FOR AMICI
CURIAE CHRISTOPHER SHAYS,
CHRISTINE TODD WHITMAN, PETER
KEISLER, CARTER PHILLIPS, JOHN
BELLINGER III, STANLEY TWARDY,
AND RICHARD BERNSTEIN;
PROPOSED ORDER GRANTING
MOTION TO WITHDRAW

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Case No. 4:19-CV-00872-HSG

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SIERRA CLUB and SOUTHERN BORDER
COMMUNITIES COALITION,

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Pta intkffs,
v.

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DONALD J, TRUMP President of the United
States, in his official capacity, et al,,

Case No. 4:19-CV-00892-HSG

Defendants.

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NOTICE OF MOTION
PLEASE TAKE NOTICE that Matthew Dollan, of Wilikie Farr & Gallagher LLP, 787 Seventh

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Avenue, New York, NY 10019, shall and hereby does respectfully seek leave of this Court, pursuant
to LOCAL R. 11-5(a) and in compliance with CAL. R. PROF. CONDUCT 3-700, to withdraw as counsel
for arnici curiae Christopher Shays, Christine Todd Whitman, Peter Keisler, Carter Phillips, John
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Bellinger III, Stanley Twardy, and Richard Bernstein.

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MOTION TO WiTHDRAW AS COUNSEL FOR AMICI CURIAE

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Pursuant to LOCAL R. 11-5, Matthew Dollan (“Movant”) hereby notifies the parties and the
Court of his intent to withdraw as counsel pro liar i’ice for antici curiae Christopher Shays, Christine

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Todd Whitman, Peter Keisler, Carter Phillips, John Bellinger III, Stanley Twardy, and Richard
Bernstein. Movant offers the following grounds for this notice and motion:

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1. This Court granted Movant leave to appear pro hac rice in this action pursuant to its May 2,
2019, Order.
2. Movant has represented amid curiae as part of his employment at Willkie farr Gallagher LLP.
As of May 9,2019, Movant will no longer be employed as an attorney at Wilikie Farr Gallagher LLP.

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3. Wilikie Farr Gallagher LLP attorneys Richard Mancino and Shaimaa Hussein, and attorney
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Richard Bernstein, also represent amici curiae and will continue to do so.
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Movant’s withdrawal will not cause any prejudice or delay in this case. All parties have counsel

actively representing them, and none will require any additional time to review or acclimate to the
absence of Movant as counsel pro hoc itce.
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5. Given the insubstantial nature of this Motion, as well as the substantial burden to all parties in
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travelling and attending a hearing on this Motion, Movant respectfully requests that the Court waive
oral argument.

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THEREFORE, Movant Matthew Dollan respectfully requests that this Court waive oral

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argument on this Motion, grant him leave to withdraw as counsel pro hoc vice in the above-captioned
matter, and enter an order stating that Movant has so withdrawn.

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Dated: May 8, 2019

Respectfully submitted,

David W. Evans
HAIGHT BROWN & BONESTEEL
Three Embarcadero Center, Suite 200
San Francisco, CA 94111
Telephone: [phone]
Facsimile: (415) 5467505

/s/ Matthew Do1la,z
Matthew Dollan (pro hoc vice)
WIELKIE FARR & GALLAGHER LLP
787 Seventh Ave
New York, NY 10019
Telephone: [phone]
Facsimile: [phone]

Richard Mancino (pro hac vice)
Shaimaa M. Hussein (pro hoc vice)
WILLME FARR & GALLAGHER EL?
787 Seventh Ave
New York, NY 10019
Telephone: [phone]
Facsimile: [phone]

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Richard D. Bernstein (pro hoc vice pending)
1875 K Street, N.W.
Washington, D.C. 20006-1238
Telephone: [phone]
Cotcnsel for Ainici Curiae Christopher Shavs, Christine Todd Whitman, Peter Keisler, Carter Phillips,
John Be/linger III, Stcniley Two rdv, and Richard Bel7Istein

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CERTIFICATE OF SERVICE
I hereby certify that on May 8, 2019, I caused the foregoing document to be filed via the
U.S. District Court for the Northern District of California’s CM/ECF system, which I understand
caused service on all registered parties.

/s/ Matthew Dotian
Matthew Dollan
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