Court records
- Format
- Set
- Court Records
- Text
- Searchable
Text as released
Machine-read from the scan. Names, dates and numbers can be misread — check anything you rely on against the original page.
Case 1:23-cv-03903-JSR Document 28 Filed 07/06/23 Page 1 of 1
IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
Master Case No. 1:23-cv-03903-JSR
IN RE JPMORGAN CHASE & CO.
DERIVATIVE LITIGATION
DERIVATIVE ACTION
DEFENDANT JAMES E. STALEY’S NOTICE OF MOTION TO
DISMISS THE AMENDED STOCKHOLDER DERIVATIVE COMPLAINT
Pursuant to Rules 12(b)(6) and 23.1(b) of the Federal Rules of Civil Procedure, Defendant
James E. Staley hereby respectfully requests that the Court dismiss all claims in the Complaint
filed by Plaintiffs on behalf of Nominal Defendant JPMorgan Chase & Co. The reasons supporting
Mr. Staley’s motion are set forth in the corresponding Memorandum of Law.
In accordance with the Court’s Case Management Plan, ECF No. 16, this response to
Plaintiffs’ Complaint is filed by July 6, 2023. Per the same order, Plaintiffs’ response to this
motion is due by July 20, 2023; and Defendants’ reply briefs, if any, are due by July 29, 2023.
Date: July 6, 2023 Respectfully submitted,
/s/ John McNichols
Brendan V. Sullivan Jr.
John McNichols
Zachary K. Warren
Stephen L. Wohlgemuth
WILLIAMS & CONNOLLY LLP
680 Maine Avenue SW
Washington, DC 20024
Tel: (202) 434-5252
Fax: (202) 434-5029
[…]