UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK L&H, INC. Case No. 1:24-cv-06425-LTS Plaintiff, -against- CHIJET MOTOR COMPANY, INC., and EQUINITI TRUST COMPANY, LLC, fi/k/a AMERICAN STOCK TRANSFER & TRUST COMPANY, LLC, Defendants.

MOTION TO TEMPORARILY STAY PROCEEDINGS AND FOR LEAVE TO WITHDRAW AS COUNSEL Pursuant to Local Civil Rule 1.4, Cooley LLP, Counsel for Defendants Chiyet Motor Company, Inc. (“Chiyet”) and Equiniti Trust Company, LLC, f/k/a American Stock Transfer & Trust Company LLC (“Equiniti,” and with Chijet, “Defendants”’), and the individual attorneys from Cooley LLP who have appeared herein (collectively, ““Cooley”), hereby move for leave to withdraw as counsel and for a temporary stay of proceedings pending Defendants’ engagement of new legal representation. As set forth in the accompanying Declaration of Aric H. Wu, dated March 24, 2025, Defendants have terminated their engagement of Cooley for this matter and instructed Cooley to cease any further work in the matter aside from this motion. See Wu Decl. 93. Per Rule 1.16(b)(3) of the New York Rules of Professional Conduct, “a lawyer shall withdraw from the representation of a client when . . . [t]he lawyer is discharged.” N.Y. Comp. Codes R. & Regs. tit. 22 § 1200.1.16(b)(3); see also In re Weiner,

, at *4 (Bankr. S.D.N.Y. June 21, 2019) (“It is undisputed that the Debtor terminated the services of the Firm and that the Firm accepted that discharge. . .. The Court cannot and will not compel the Firm to represent the Debtor.”).

To afford Chijet and Equiniti adequate time to secure new legal representation, Cooley requests that the action be temporarily stayed for at least thirty (30) days. The only upcoming deadline in the case is March 27, 2025, for Equiniti’s reply in further support of its motion to dismiss Plaintiff’s claims against it. ECF No. 44. This motion is being made at Defendants’ request and with Defendants’ consent. For all

the reasons herein, Cooley and Defendants respectfully request that the Court: a. grant Cooley leave to withdraw as counsel for Chijet and Equiniti; b. temporarily stay the action and all pending deadlines in the action by at least thirty (30) days to afford Chijet and Equiniti adequate time to secure new legal representation; and c. grant such other and further relief as this Court deems just and proper.

Dated: New York, New York Respectfully submitted, March 24, 2025 COOLEY LLP The foregoing requests are granted. Cooley is By: /s/ Aric H. Wu hereby granted leave to withdraw as counsel Aric H. Wu for Chijet and Equiniti. Cooley is directed to serve a copy of this order on Chijet and 55 Hudson Yards Equiniti by April 7, 2025, and file prompt New York, NY 10001 proof of such service that identifies the Tel: (212) 479-6000 relevant service addresses and contact [email protected] persons for those entities. This action, and all pending deadlines in the action, are hereby William K. Pao (pro hac vice) stayed until May 16, 2025. Chijet and Jonathan B. Waxman (pro hac vice) Equiniti are hereby directed to appear by new Wells Fargo Center, South Tower counsel on or before that date. DE 47 355 South Grand Avenue, Suite 900 resolved. Los Angeles, CA 90071 SO ORDERED. Tel: (213) 561-3250 [email protected] 4/02/2025 [email protected] /s/ Laura Taylor Swain, Chief USDJ UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK L&H, INC. Case No. 1:24-cv-06425-LTS Plaintiff,

-against- CHIJET MOTOR COMPANY, INC., and EQUINITI TRUST COMPANY, LLC, f/k/a AMERICAN STOCK TRANSFER & TRUST COMPANY, LLC, Defendants. DECLARATION OF SERVICE Y ELECTRONIC MAIL Pursuant to

, I, Aric H. Wu, declare as follows: 1. I am not a party to this action, am over 1 years of age, and am a partner at the law firm Cooley LLP, 55 Hudson Yards, New York, New York 10001. 2. On March 24, 2025, I served true and correct copies of the: a. Motion to Temporarily Stay Proceedings and for Leave to Withdraw as Counsel; and b. Declaration of Aric H. Wu in Support of Motion to Temporarily Stay Proceedings and for Leave to Withdraw as Counsel, on the following: Counsel for Plaintiff Rory G. Greebel [email protected] Philip . Langer [email protected]

Defendant Chijet Motor Company, INC. [email protected] Defendant Equiniti Trust Company, LLC [email protected] [email protected]

3. I made such service by causing true and correct copies of the aforementioned documents to be attached to electronic mails and sending the electronic mails to the above mentioned electronic mail addresses. I affirm this 24th day of March, 2025, under penalties of perjury under the laws of New York, which may include a fine or imprisonment, that the foregoing is true, and I understand that this document may be filed in an action or proceeding in a court of law. Dated: March 24, 2025 New York, New York /s/ Aric H. Wu Aric H. Wu