vs.

UNITED STATES DISTRICT COURT

EASTERN DISTRCT OF NEV/ YORK
X
IINITED STATES OF AMERICA, Cr. No. 14-00248 (PKC)
STIPULATION AND ORDER OF
SUBSTITITION OF COUNSEL
MICHAEL GRIMM,
Defendant.
STIPULATION AND ORDER OF SUBSTITION OF COUNSEL
IT IS HEREBY STIPULATED AND AGREED, by and between the undersigned
counsel and pursuant to Local Rule 1.4, that the law firm of Marcus Neiman & Rashbaum LLP
hereby is substituted in place of the law firm of Kase & Druker as counsel of record for
defendant Michael Grimm in the above-captioned case. A declaration in support of this
stipulation and order for substitution of counsel is attached hereto pursuant to Local Rule 1.4.
PLEASE TAKE NOTICE that all pleadings, notices of hearing, and other filings in this
matter should be served upon the undersigned incoming counsel.
X
Dated: July 17,2014
KASE & DRUKER
By: By:
Elizabeth S. Kase
esk@kaseanddruker.com
1325 Franklin Avenue, Suite 225
Garden City, NY I1530
Tel: 516-746-4300
Fax 516-742-941,5
NEI & RASHBAUM
Daniel Rashbaum (DR-4037)
drashbaum@mnrlawfirm. com
2 S. Biscayne Blvd., Suite 1750
Miami, Fl. 33131
Tel:305400-4261
Fax: 866-780-8355
Incomng Counsel
r
Mn Grimm
Outgoing Counselfr Mr. Grimm
SO ORDERED
The Honorable Pamela K. Chen
United States District Judge
July
_,2014
Case 1:14-cr-00248-PKC-RML Document 19 Filed 07/17/14 Page 1 of 1 PageID #: 80
VS.
IINITED STATES DISTRICT COURT
EASTERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA, Cr. No. 14-248 (PKC)
MICHAEL GRIMM,
Defendant.
----x
DECLARATION OF DANIEL RASHBAUM IN SUPPORT OF STIPULATION AND
ORDER OF SUBSTITION OF COUNSEL
Pursuant to 28 U.S.C.

1746, DANIEL LAWRENCE RASHBAUM, hereby declares as
follows:
1. I am an attorney admitted to practice before the courts of the State of New York
and the United States District Court for the Eastern District of New York. I am a partner at the
law firm of Marcus Neiman & Rashbaum LLP.
2. I respectfully submit this declaration pursuant to Local Rule 1.4 of the United
States District Court of Eastem District of New York, in support of the stipulation and order
substituting Marcus Neiman & Rashbaum LLP for Kase & Druker as counsel of record for
defendant Michael Grimm.
3. Mr. Grimm has requested that Marcus Neiman & Rashbaum represent him in this
action and has consented to the withdrawal of Kase & Druker. The Government does not object
to the proposed substitution of counsel.
4. The Indictment in this case was unsealed on April 28, 2014, less than three
months ago. The Court has entered orders excluding, for Speedy Trial purposes, the time period
from April 28 to July 21. A trial date has not yet been set in this matter.
Case 1:14-cr-00248-PKC-RML Document 19-1 Filed 07/17/14 Page 1 of 2 PageID #: 81
5. There is a status conference scheduled at 11:00 a.m. on July 21,2014. Mr.
Grimm respectfully requests that his proposed new counsel, Marcus Neiman & Rashbaum LLP,
be substituted in as counsel prior to that conference, so that it can represent him there.
6. Because this case is still in its incipient stages, the requested substitution of
counsel will not unnecessarily delay this action, and undersigned counsel respectfully requests
that the Court approve the Stipulation and Order of Substitution submitted in connection with
this declaration.
7. I declare under penalty of perjury that the foregoing is true and correct.
Dated: Miami, Florida,
July 17,2014
Lawrence Rashbaum, Esq.
2
Case 1:14-cr-00248-PKC-RML Document 19-1 Filed 07/17/14 Page 2 of 2 PageID #: 82