Considerate Commerce Inc v. ISP Electronics LLC

CourtDistrict Court, N.D. Texas
DecidedSeptember 5, 2025
Docket3:23-cv-02140
StatusUnknown

This text of Considerate Commerce Inc v. ISP Electronics LLC (Considerate Commerce Inc v. ISP Electronics LLC) is published on Counsel Stack Legal Research, covering District Court, N.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Considerate Commerce Inc v. ISP Electronics LLC, (N.D. Tex. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF TEXAS DALLAS DIVISION CONSIDERATE COMMERCE INC., § § Plaintiff, § § § V. § No. 3:23-cv-2140-E-BN § ISP ELECTRONICS LLC, ISP TEK § SERVICES LLC, and CAPTIVE § TRADE CORPORATION, § § Defendants. § MEMORANDUM OPINION AND ORDER GRANTING OPPOSED MOTION TO WITHDRAW AS COUNSEL Kristi Motley, and the law firm of Nace & Motley, LLP has filed a Motion to Withdraw as Counsel for Plaintiff Considerate Commerce Inc. and Third-Party Defendants Mahmood Osorio and Melody Osorio (collectively the “Considerate Parties”). See Dkt. No. 224. Ms. Motley requests that the Court allow her to withdraw as counsel of record for the Considerate Parties. She explains that “Attorney Dave Wishnew of the law firm Crawford, Wishnew & Lang, PLLC has recently filed a Notice of Appearance and Designation of Lead Counsel” in this case; that the Considerate Parties “desire Mr. Wishnew to remain as [their] lead counsel”; and that “withdrawal is necessary to effectuate the client’s choice of counsel.” Dkt. No. 224 at 3. Ms. Motley adds that the Considerate Parties have consented to her withdrawal and that it “is not sought for delay, but so that justice may be done.” Id. Defendant/Counter-Plaintiff ISPTek Services, LLC and Defendant ISP Electronics, LLC (collectively, “Defendants”) oppose the request and assert that Defendants have genuine concerns about the potential for Ms. Motley’s withdrawal to disrupt and delay these proceedings resulting in prejudice to Defendants. These concerns were communicated to Ms. Motley and the Considerate Parties’ new counsel prior to the Motion to Withdraw being filed, but none of these concerns were addressed in Ms. Motley’s motion nor in correspondence beforehand by either Ms. Motley or the Considerate Parties’ new counsel. Indeed, the Motion to Withdraw fails to address any of Defendants’ concerns and fails to even argue, much less show, that good cause exists for Ms. Motley’s withdrawal. Good cause does not exist for Ms. Motley’s withdrawal 1) in light of the Considerate Parties’ efforts to cast blame on Ms. Motley for all of their actions and inactions in this case, as well as 2) at this late stage of the case. First, the Considerate Parties have recently sought to use Ms. Motley as an excuse for the Considerate Parties’ actions and inactions in this case and are attempting to use such as a basis to relitigate this entire case. See Considerate Parties’ Objection to Report and Recommendation of the United States Magistrate Judge, Motion for Reconsideration of Motion to File Late Response, Objection to Findings, Conclusions, and Recommendation of the United States Magistrate Judge. While these motions have recently been resolved, the Considerate Parties’ arguments in the motions shed light on their new litigation strategy – blaming all unfavorable rulings and/or litigation positions on their prior counsel. With several motions pending where discovery sanctions may be awarded, such positions necessitate Ms. Motley’s continued presence in the case. Her absence would make it more difficult for Defendants to refute these allegations of attorney misconduct and Ms. Motley should be required to respond to those assertions, rather than allowing the Considerate Parties to “try the empty chair” for each of their failed arguments. Second, this case has been pending for nearly two years during which over two hundred filings have been made, over ten thousand documents have been produced, and the only remaining deadlines— aside from briefing this motion—relate to pretrial and trial. As has already been demonstrated through their filings, the Considerate Parties’ new counsel cannot replicate Ms. Motley’s institutional knowledge of this case at this stage in the litigation. Going forward, it is inevitable that Ms. Motley will, and must, remain involved in this case if for nothing but the practical purpose of continuing to educate the Considerate Parties’ new counsel of the goings-on in this case throughout its two-year history and avoiding the argument of lack of knowledge by new counsel with respect to prior actions/positions. Ms. Motley’s formal withdraw would only cause further delays, excuses, and complexities that will primarily prejudice Defendants. Moreover, Defendants still have several motions pending that seek the recovery of their attorneys’ fees from the Considerate Parties and/or their counsel. Defendants are concerned that the Considerate Parties and their new counsel will attempt to disclaim liability by blaming any attorneys’ fee award and/or sanction on the actions of Ms. Motley, thereby risking Defendants’ ability to recover should Ms. Motley be dismissed. In fact, this concern has already been confirmed. As evidenced by the Considerate Parties’ most recent filings, the Considerate Parties’ new strategy is blaming all unfavorable outcomes on Ms. Motley. It is not unreasonable to assume they would do the same should attorneys’ fees or sanctions be awarded against them. Ms. Motley’s complete absence would invite an attractive scapegoat, regardless of the merit or lack thereof to such an allegation. At the very least, Ms. Motley’s continued presence in this case would allow her, and perhaps require her, to respond to the allegations that were levied against her and are likely to arise again as this case proceeds. Dkt. No. 233 at 4-6 (cleaned up). “Attorneys normally are expected to work through the completion of a case.” F.T.C. v. Intellipay, Inc., 828 F. Supp. 33, 33 (S.D. Tex. 1993). And so, an attorney of record may not withdraw as counsel of record until certain requirements are satisfied. The question of whether these requirements have been met such that withdrawal is warranted is “entrusted to the sound discretion of the [trial] court.” In re Wynn, 889 F.2d 644, 646 (5th Cir. 1989) (cleaned up). The first withdrawal requirement is that attorneys may only withdraw “upon leave of the court and a showing of good cause and reasonable notice to the client.” Id.; accord N.D. TEX. L. CIV. R. 83.12(a) (requiring that “an attorney desiring to withdraw in any case must file a motion to withdraw”). The withdrawing attorney bears the burden of proving the existence of good cause for withdrawal. See Intellipay, 828 F. Supp. at 34 (“The record must generally reflect an appropriate basis for granting leave [to withdraw]; unsubstantiated claims are insufficient.”). “A court’s determination whether an attorney has good cause to withdraw

depends on the facts and circumstances of the particular case.” Edwards v. Oliver, No. 3:17-cv-1208-M-BT, 2022 WL 4820147, at *1 (N.D. Tex. Sept. 30, 2022). “Whether good cause exists for an attorney to withdraw is a question of federal law.” Id. at *2 (cleaned up). That question may be answered “by referring to the standards for withdrawal articulated in national ethics canons and in the ethics rules adopted by the court.” Id. (cleaned up). And, at least through Local Civil Rule 83.8(e), the United States District Court for the Northern District of Texas “has adopted the Texas

Disciplinary Rules of Professional Conduct.” Id. “If a district court is not persuaded that good cause for withdrawal exists, it has substantial latitude to deny an attorney’s motion to withdraw. This is especially true where … an attorney seeks to withdraw over his client’s objection.” White v. BAC Home Loans Servicing, LP, No. 3:09-cv-2484-G, 2010 WL 2473833, at *1 (N.D. Tex. June 15, 2010) (cleaned up).

Good cause exists for Ms. Motley to withdraw as counsel because, as the Considerate Parties persuasively assert in their reply, “there are irreconcilable conflicts between Ms. Motley and the Considerate Parties and her continued representation would violate the ethical obligations of an attorney” because the Considerate Parties discharged Ms. Motley. Dkt. No. 236 at 2, 7.

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Related

Federal Trade Commission v. Intellipay, Inc.
828 F. Supp. 33 (S.D. Texas, 1993)
Baker v. Peake (In Re Fernandez)
478 F. App'x 138 (Fifth Circuit, 2012)
Honda Power Equipment Manufacturing, Inc. v. Woodhouse
219 F.R.D. 2 (District of Columbia, 2003)
Wynn v. Eriksson (In re Wynn)
889 F.2d 644 (Fifth Circuit, 1989)

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Bluebook (online)
Considerate Commerce Inc v. ISP Electronics LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/considerate-commerce-inc-v-isp-electronics-llc-txnd-2025.