Motion To Withdraw As Counsel

Date: 2023-01-31

Summary

A Motion to Withdraw as Counsel filed January 31, 2023 as Doc: 67 in Blue Flame Medical LLC v. Chain Bridge Bank, N.A., No. 21-2218 (L) and No. 21-2219, in the United States Court of Appeals for the Fourth Circuit, on appeal from 1:20-cv-00658-LMB-IDD. Under Local Rule 46(c), Kathleen Foley asks to withdraw her appearance as counsel for Plaintiff-Appellant Blue Flame Medical LLC because she will no longer be affiliated with Goldstein & Russell, P.C. The motion states that Blue Flame will continue to be represented by Eric F. Citron of that firm and that JPMorgan Chase Bank and Chain Bridge Bank consent. The filing includes a certificate of compliance and a certificate of service.

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Full text

USCA4 Appeal: 21-2218 Doc: 67 Filed: 01/31/2023 Pg: 1 of 4

IN THE UNITED STATES COURT OF APPEALS
FOR THE FOURTH CIRCUIT

Blue Flame Medical LLC,
Plaintiff-Appellant,
v.
Chain Bridge Bank, N.A.,
Defendant and Third-Party Plaintiff-Appellee, No. 21-2218 (L)
John J. Brough; David M. Evinger, (1:20-cv-00658-LMB-IDD)
Defendants-Appellees,
v.
JPMorgan Chase Bank, N.A.,
Third-Party Defendant.

Blue Flame Medical LLC,
Plaintiff,
v.
Chain Bridge Bank, N.A.,
Defendant and Third-Party Plaintiff-Appellee,
No. 21-2219
John J. Brough; David M. Evinger, (1:20-cv-00658-LMB-IDD)
Defendants,
v.
JPMorgan Chase Bank, N.A.,
Third-Party Defendant-Appellant.

MOTION TO WITHDRAW AS COUNSEL

Pursuant to Local Rule 46(c), Kathleen Foley respectfully requests that the

Court withdraw her appearance as counsel for Plaintiff-Appellant Blue Flame Med-

ical LLC in these matters, as Ms. Foley will no longer be affiliated with the law firm
USCA4 Appeal: 21-2218 Doc: 67 Filed: 01/31/2023 Pg: 2 of 4

Goldstein & Russell, P.C. Plaintiff-Appellant will continue to be represented by

Eric F. Citron of Goldstein & Russell, P.C.

Undersigned counsel has informed counsel for Appellant JPMorgan Chase

Bank and Appellee Chain Bridge Bank, in accordance with Local Rule 27(a). Both

parties consent to the relief sought in this motion.

January 31, 2023 Respectfully submitted,
/s/ Kathleen Foley
Eric F. Citron
Kathleen Foley
GOLDSTEIN & RUSSELL, P.C.
7475 Wisconsin Avenue, Suite 850
Bethesda, MD 20814
(202) 362-0636
Counsel for Plaintiff-Appellant
Blue Flame Medical LLC

2
USCA4 Appeal: 21-2218 Doc: 67 Filed: 01/31/2023 Pg: 3 of 4

CERTIFICATE OF COMPLIANCE

In accordance with Fed. R. App. P. 32(g)(1), the undersigned certifies that this

motion complies with the type-volume limit of Fed. R. App. P. 27(d)(2) because this

motion contains 93 words, excluding the parts of the motion exempted by Fed.

R. App. P. 32(f).

This motion complies with the typeface requirements of Fed. R. App.

P. 32(a)(5) and the type style requirements of Fed. R. App. P 32(a)(6) because this

document has been prepared in a proportionally spaced typeface using Microsoft

Word 2016, Times New Roman, 14-pt font.

/s/ Kathleen Foley
January 31, 2023
USCA4 Appeal: 21-2218 Doc: 67 Filed: 01/31/2023 Pg: 4 of 4

CERTIFICATE OF SERVICE

I hereby certify that I electronically filed the foregoing with the Clerk of the

Court for the United States Court of Appeals for the Fourth Circuit by using the

appellate CM/ECF system on January 31, 2023. All participants in the case are reg-

istered CM/ECF users and service will be accomplished by the appellate CM/ECF

system.

/s/ Kathleen Foley
January 31, 2023

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