State of California et al v. Trump et al

Filing 213

MOTION to Withdraw as Attorney Brittany M. Jones filed by Commonwealth of Virginia. Responses due by 10/4/2019. Replies due by 10/11/2019. (Attachments: # 1 Proposed Order)(Jones, Brittany) (Filed on 9/20/2019)

MARK R. HERRING
Attorney General
MICHELLE S. KALLEN
Deputy Attorney General
BRITTANY M. JONES
Attorney
202 North Ninth Street
Richmond, VA 21239
[phone]
[e-mail]
[e-mail]

Attorneys for Commonwealth of Virginia
IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF CALIFORNIA
OAKLAND DIVISION

STATE OF CALIFORNIA, et al.,

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

Plaintiffs,

NOTICE OF MOTION AND MOTION
TO WITHDRAW AS COUNSEL FOR
PLAINTIFF STATE

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

NOTICE OF MOTION
PLEASE TAKE NOTICE that Brittany M. Jones of the Office of the Attorney
General of Virginia, 202 North Ninth Street, Richmond, Virginia 23219, 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 Plaintiff
Commonwealth of Virginia.

1

MOTION TO WITHDRAW AS COUNSEL
Pursuant to Local R. 11-5, Brittany M. Jones (Movant) hereby notifies the
parties and the Court of her intent to withdraw as counsel pro hac vice for Plaintiff
Commonwealth of Virginia. Movant offers the following grounds for this notice and
motion:
1.

This Court granted Movant leave to appear pro hac vice in this action

pursuant to its February 22, 2019 Order.
2.

Movant has represented the Commonwealth of Virginia as part of her

employment at the Office of the Attorney General. As of September 20, 2019,
Movant will no longer be employed as an attorney for the Office.
3.

Michelle S. Kallen, Deputy Solicitor General, also represents the

Commonwealth and continues to do so.
4.

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 hac

vice.
5.

Given the insubstantial nature of this Motion, as well as the

substantial burden to all parties in traveling and attending a hearing on this
Motion, Movant respectfully requests that the Court waive oral argument.
6.

THEREFORE, Movant Brittany M. Jones respectfully requests that

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Movant has so withdrawn.

2

Dated: September 19, 2019

Respectfully Submitted,

Michelle S. Kallen
Deputy Attorney General
Office of the Attorney General
202 North Ninth Street
Richmond, VA 21239
Tel. [phone]
Fax [phone]

BRITTANY M. JONES
Attorney
202 North Ninth Street
Richmond, VA 21239
[phone]
[e-mail]

/s/ Brittany M. Jones

3

CERTIFICATE OF SERVICE
The undersigned hereby certifies that on September 19, 2019, I electronically
filed a true copy of the foregoing with the Clerk of the Court using the CM/ECF
system, which will send a notification of such filing (NEF) to counsel of record.
Opposing counsel will be sent a copy by first-class, postage prepaid mail:
U.S. Department of Justice
Civil Division
P.O. Box 883
Washington, DC 20044
_/s/ Brittany M. Jones __
Brittany M. Jones

4