State of California et al v. Trump et al

Filing 148

MOTION to Withdraw as Attorney (Zachary Kolodin) filed by 58 Religious Organizations. Responses due by 5/29/2019. Replies due by 6/5/2019. (Attachments: # 1 Proposed Order)(Kolodin, Zachary) (Filed on 5/15/2019) Modified on 5/16/2019 (cpS, COURT STAFF).

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PATTERSON BELKNAP WEBB & TYLER LLP

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Steven A. Zalesin (pro hac vice)
Adeel A. Mangi (pro hac vice)
Zachary Kolodin (pro hac vice)
Amir Badat (pro hac vice)
1133 Avenue of the Americas
New York, NY 10036-6710
Tel: [phone]
Fax: [phone]

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LAFAYETTE & KUMAGAI LLP
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Gary T. Lafayette (SBN 088666)
Brian H. Chun (SBN 215417)
1300 Clay Street, Suite 810
Oakland, CA 94612
Tel: [phone]
Fax: [phone]

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Attorneys for Amici Curiae 58 Religious Organizations

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
OAKLAND DIVISION

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SIERRA CLUB and SOUTHERN BORDER
COMMUNITIES COALITION, et al.,

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Plaintiffs,

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

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Defendants.
STATE OF CALIFORNIA, et al.,

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

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

Case No. 4:19-cv-00872-HSG
ZACHARY KOLODIN’S NOTICE OF
MOTION AND MOTION TO
WITHDRAW AS COUNSEL FOR
AMICI CURIAE 58 RELIGIOUS
ORGANIZATIONS; PROPOSED
ORDER GRANTING MOTION TO
WITHDRAW

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ZACHARY KOLODIN’S NOTICE OF MOTION AND MOTION TO WITHDRAW AS COUNSEL FOR AMICI CURIAE 58
RELIGIOUS ORGANIZATIONS; PROPOSED ORDER GRANTING MOTION TO WITHDRAW; 19-cv-00872, 19-cv-00892

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NOTICE OF MOTION
PLEASE TAKE NOTICE that Zachary Kolodin, of Patterson Belknap Webb & Tyler LLP,
1133 Avenue of the Americas, New York, NY 10036-6710, respectfully seeks leave of the Court, as

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required by LOCAL R. 11-5(a) and CAL. R. PROF. CONDUCT 3-700, to withdraw as counsel for amici
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curiae 58 Religious Organizations.

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MOTION TO WITHDRAW AS COUNSEL FOR AMICI CURIAE

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Zachary Kolodin hereby notifies the parties and the Court of his intent to withdraw as

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counsel pro hac vice for amici curiae 58 Religious Organizations. For each of the following

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reasons, the relief requested herein is just and proper:
1.

In a May 9, 2019, the Court granted Mr. Kolodin leave to appear pro hac vice in State

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of California, et al. v. Trump, 4:19-cv-872-HSG (Dkt. 133);
2.

In a May 14, 2019 Order, the Court granted Mr. Kolodin leave to appear pro hac vice

in Sierra Club, et al., v. Trump, 4:19-cv-892-HSG (Dkt. 126);
3.

Mr. Kolodin has represented amici curiae as part of his employment at Patterson

Belknap Webb & Tyler LLP. As of May 17, 2019, Mr. Kolodin will no longer be employed in that
capacity;
4.

Patterson Belknap Webb & Tyler LLP attorneys Steven A. Zalesin, Adeel A. Mangi,

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and Amir Badat, and attorneys Gary Lafayette and Brian Chun of Lafayette and Kumagai LLP, also
represent amici curiae and will continue to do so.
5.

Mr. Kolodin’ s withdrawal will not cause any prejudice or delay. All parties have

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counsel actively representing them, and none will require any additional to review or acclimate to

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the absence of Mr. Kolodin as counsel pro hac vice.

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-2ZACHARY KOLODIN’S NOTICE OF MOTION AND MOTION TO WITHDRAW AS COUNSEL FOR AMICI CURIAE 58
RELIGIOUS ORGANIZATIONS; PROPOSED ORDER GRANTING MOTION TO WITHDRAW; 19-cv-00872, 19-cv-00892

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6.

Given the routine nature of this motion, as well as the substantial burden to all parties

in travelling and attending a hearing, Mr. Kolodin respectfully requests that the Court waive oral
argument.

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THEREFORE, Zachary Kolodin respectfully requests that the Court waive oral argument,
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grant him leave to withdraw as counsel pro hac vice in the above-captioned matter, and enter an

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order so stating.

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Dated:

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New York, New York
May 15, 2019
Respectfully submitted,
By: /s/ Zachary Kolodin___
Steven A. Zalesin (pro hac vice)
Adeel A. Mangi (pro hac vice)
Zachary Kolodin (pro hac vice)
Amir Badat (pro hac vice)
PATTERSON BELKNAP WEBB & TYLER LLP
1133 Avenue of the Americas
New York, New York 10036-6710
Tel: [phone]
Fax: [phone]
[e-mail]
[e-mail]
[e-mail]
[e-mail]

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By: /s/ Gary T. Lafayette
Gary T. Lafayette
Brian H. Chun
LAFAYETTE & KUMAGAI LLP
1300 Clay Street, Suite 810
Oakland, CA 94612
Tel: [phone]
Fax: [phone]
[e-mail]

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Counsel for Amici Curiae Religious Organizations

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_

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-3ZACHARY KOLODIN’S NOTICE OF MOTION AND MOTION TO WITHDRAW AS COUNSEL FOR AMICI CURIAE 58
RELIGIOUS ORGANIZATIONS; PROPOSED ORDER GRANTING MOTION TO WITHDRAW; 19-cv-00872, 19-cv-00892

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CERTIFICATE OF SERVICE
I hereby certify that on May 15, 2019, I caused the foregoing to be electronically filed with
the Clerk of the Court using the CM/ECF system, which sent notification of such filing to all

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registered attorneys of record.
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/s/ Zachary Kolodin
Zachary Kolodin
Attorney for Amici Curiae 58 Religious Organizations

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-4ZACHARY KOLODIN’S NOTICE OF MOTION AND MOTION TO WITHDRAW AS COUNSEL FOR AMICI CURIAE 58
RELIGIOUS ORGANIZATIONS; PROPOSED ORDER GRANTING MOTION TO WITHDRAW; 19-cv-00872, 19-cv-00892