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)

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MARK R. HERRING Attorney General MICHELLE S. KALLEN Deputy Attorney General BRITTANY M. JONES Attorney 202 North Ninth Street Richmond, VA 21239 (804) 786-2071 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. (804) 786-2071 Fax (804) 371-0200 BRITTANY M. JONES Attorney 202 North Ninth Street Richmond, VA 21239 (804) 786-2071 /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

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