Case 1:19-cr-00725-JPO Document 57 Filed 12/24/19 Page 1 of 1

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF NEW YORK
——————————————————X
UNITED STATES OF AMERICA,
NOTICE OF MOTION
TO WITHDRAW AS COUNSEL
Plaintiff,
—v.—
19-CR-725 (JPO)
LEV PARNAS, et al.,

Defendants.
——————————————————X

PLEASE TAKE NOTICE THAT pursuant to Local Rule 1.4, it is hereby requested that the

appearance of Edward B. MacMahon, Jr., be withdrawn as counsel for Defendant Lev Parnas in

this matter, for the reasons set forth in the accompanying Affirmation of Counsel. Mr. Parnas will

continue to be represented by Joseph A. Bondy, Esq., as indicated on the Court’s docket.

The undersigned counsel respectfully requests this Honorable Court enter an Order granting the

motion to withdraw.

Dated: December 24, 2019

Respectfully submitted:

/s/ Edward B. MacMahon, Jr.

Co-Counsel of Record for Lev Parnas
EDWARD B. MACMAHON, JR., PLC
P.O. Box 25
107 East Washington Street
Middleburg, Virginia 20118
Telephone: 540-687-3902
Fax: 540-687-6366
 Case 1:19-cr-00725-JPO Document 57-1 Filed 12/24/19 Page 1 of 2

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF NEW YORK
——————————————————X
UNITED STATES OF AMERICA,

AFFIRMATION OF
Plaintiff, EDWARD B. MACMAHON, JR.

—v.— 19-CR-725 (JPO)

LEV PARNAS,

Defendant.
——————————————————X

Edward B. MacMahon, Jr., Esq., an attorney duly licensed to practice law in New York

and before this Court, hereby affirms that the following facts are true:

1. I am a private practitioner, with offices located in Washington, DC and

Middleburg, Virginia. I appeared as counsel to Mr. Parnas during his original bail setting in

Alexandria, Virginia, and thereafter at Mr. Parnas’ initial appearance in this jurisdiction on

October 23, 2019, and a second conference, on December 2, 2019.

2. Discovery is yet to be completed, no pre-trial motions have been filed, and a trial

date is yet to be set by the Court.

3. In this action, I am joined by New York-based criminal defense attorney Joseph A.

Bondy as co-counsel. Since I entered my appearance, Mr. Parnas’ apparent ability to fund his

defense has diminished. It thus would constitute a significant hardship for Mr. Parnas to continue

being represented by two attorneys in this matter.

4. I have discussed this matter fully with Mr. Parnas, who, given my location out of

district and his circumstances, consents to my filing the instant request to withdraw from his

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criminal matter. I have also discussed this matter with Mr. Bondy, who is prepared to assume all

aspects of Mr. Parnas’ defense.

5. I will remain available to the Court, to the extent it may require my appearance or

response to any matters before it, and also to Mr. Parnas, to ensure orderly transfer of my files

and any other information required to protect Mr. Parnas’ rights.

6. Thank you for consideration of this request.

Dated: December 24, 2019

/s/ Edward B. MacMahon, Jr.,

Co-Counsel of Record to Lev Parnas
EDWARD B. MACMAHON, JR., PLC
P.O. Box 25
107 East Washington Street
Middleburg, Virginia 20118
Telephone: 540-687-3902
Fax: 540-687-6366

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