Delgado v. Donald J. Trump For President, Inc.

District Court, S.D. New York·Decided March 10, 2023·No. 1:19-cv-11764·Unknown

Opinion

USDC SDNY DOCUMENT UNITED STATES DISTRICT COURT ELECTRONICALLY FILED SOUTHERN DISTRICT OF NEW YORK DOC #: Fo DATE FILED: 3/10/2023 ARLENE DELGADO, Plaintiff, 19-CV-11764 (AT) (KHP) -against- OPINION AND ORDER DONALD J. TRUMP FOR PRESIDENT, INC., ON MOTION TO WITHDRAW TRUMP FOR AMERICA, INC., SEAN SPICER, individually, REINCE PRIEBUS, individually, STEPHEN BANNON, individually, Defendants. wunn--------- == + ----- -----------X KATHARINE H. PARKER, UNITED STATES MAGISTRATE JUDGE: Before the Court is a motion by the Derek Smith Law Group, PLLC and Daniel Kirschbaum, counsel of record for Plaintiff Arlene Delgado, to withdraw as counsel. (ECF No. 124.) For the reasons stated below, the motion is GRANTED. BACKGROUND Arlene Delgado (“Plaintiff”) initiated this action on December 23, 2019 against Trump for America, Inc., Donald J. Trump for President, Inc. and certain individuals who worked for the campaign. Her claims include breach of contract, employment discrimination, retaliation, and tortious interference with prospective economic advantage. Since the action’s inception, Plaintiff was represented by the Derek Smith Law Group, PLLC (the “Firm”). Initially, Abraham Melamed (“Mr. Melamed”) served as lead counsel, but in September 2022, Mr. Melamed left the Firm and Daniel Kirschbaum (“Mr. Kirschbaum”) replaced him as lead counsel for Plaintiff. On January 12, 2023, the Court held a settlement conference, which was not successful. On January 27, 2023, another lawyer at the Firm, lan Bryson (“Mr. Bryson”), applied for Pro Hac Vice admission, but then immediately withdrew his application. On January 30, 2023, Mr.

Kirschbaum moved on behalf of the Firm to withdraw as counsel, citing an “irreparable breakdown in attorney-client relations” between Plaintiff and the Firm. (ECF Nos. 124, 125.) Plaintiff opposed the motion, and Defendants took no position. (ECF Nos. 129, 132.) At the

time the motion was filed, document discovery was largely complete, and dates had been set for party depositions. No other depositions had occurred or were scheduled, and no expert discovery had been taken. The deadline for all discovery was March 31, 2023. On February 7, 2023, the Court held an ex parte conference with Plaintiff and Mr. Kirschbaum to learn more about their positions on the motion.1 (ECF No. 134.) The Court then issued a 60-day stay of deadlines and directed Plaintiff and Mr. Kirschbaum to submit in camera

affidavits providing further detail regarding their positions on the motion. (ECF No. 137.) The letters from Mr. Kirschbaum and Plaintiff confirm a breakdown in their relationship and reveal the development of distrust and acrimony between Plaintiff and her lawyers. Mr. Kirschbaum’s letter also states that the Firm will not seek any lien for fees on any settlement that Plaintiff may recover, but it does intend to seek reimbursement of the expenses it has laid

out in this litigation for this Court’s filing fee, process server’s charges, the cost of ordering a court reporter’s transcript, and the fee for Mr. Bryson’s Pro Hac Vice application, and that it reserves the right to apply for and recover its fees in the event Plaintiff prevails at a trial. Mr. Kirshbaum does not request any retaining lien. Plaintiff’s letters contest that she was the cause of any relationship breakdown, and suggest that a motivating factor behind the relationship strain is that the Firm assumed this

1 Documents concerning motions to withdraw as counsel are “routinely” filed under seal or in camera to preserve the confidentiality of the attorney-client relationship between a party and its counsel. Team Obsolete Ltd. v. A.H.R.M.A. Ltd., 464 F.Supp.2d 164, 165 (E.D.N.Y.2006); see also Committee Note to Local Civil Rule 1.4. case would settle quickly, and it is not interested in taking the case to trial. Plaintiff also stated that she has already paid a substantial amount in attorney’s fees to the Firm, and if the Firm is permitted to seek additional fees, this would further prejudice her ability to obtain new

counsel. ANALYSIS Withdrawal of counsel is governed by Local Civil Rule 1.4, which states: An attorney who has appeared as attorney of record for a party . . . may not withdraw from a case without leave of the court granted by order. Such an order may be granted only upon a showing by affidavit or otherwise of satisfactory reasons for withdrawal or displacement and the posture of the case, including its position, if any, on the calendar, and whether or not the attorney is asserting a retaining or charging lien.

S. & E.D.N.Y.R. 1.4. The decision to grant or deny a motion to withdraw is within the district court’s discretion. In making the determination, the Court should consider (i) the reasons for withdrawal, and (ii) the impact of the withdrawal on the timing of the proceeding. Karimian v. Time Equities, Inc., 2011 WL 1900092, at *2 (S.D.N.Y. May 11, 2011) (citing S. & E.D.N.Y.R. 1.4). I consider both factors below, and also address the issue of any claim to attorney’s fees and costs that the Firm may make. 1. Reasons for Withdrawal Mr. Kirschbaum states that his Firm’s reason for seeking to withdraw is that an irreparable breakdown has occurred in the attorney-client relationship. It is well established that this is a sufficient reason for withdrawal, even where the client opposes the motion or disputes a relationship breakdown. Id. (collecting cases). Although Plaintiff opposes the withdrawal, she does not contest that the attorney-client relationship has broken down, and her submissions confirm a lack of confidence in Mr. Kirschbaum and the Firm. The Court need not determine the “source of the strain” on the

relationship or assign any blame in deciding the motion to withdraw; the strained relationship alone is “sufficient grounds” for withdrawal. Diarama Trading Co. v. J. Walter Thompson U.S.A., Inc., 2005 WL 1963945, at *1 (S.D.N.Y. Aug. 15, 2005). Based on the in camera submissions, the Court finds that the attorney-client relationship has indeed broken down here sufficient to warrant granting the motion to withdraw. Importantly, in making this determination, the Court does not ascribe blame to either Plaintiff or her counsel for the breakdown. Thus, this decision

should not be cited for any purpose in connection with the ongoing litigation and in no way impacts merits issues in the case. Plaintiff suggests that a motivating factor for the withdrawal is that the Firm wanted this case to settle, and after the unsuccessful January 2023 settlement conference, it lost interest in the case and sought to withdraw on that basis. A dispute regarding settlement strategy is

generally not a sufficient reason to permit withdrawal. Joffe v. Javerbaum Wurgaft Hicks Kahn Wikstrom & Sinins, P.C., 827 F. App'x 35, 38 (2d Cir. 2020). However, Plaintiff has not shown that a disagreement over settlement strategy was the sole, or even a predominant, motivating factor here. See id. (affirming the decision to grant a motion to withdraw where the district court acknowledged there was a dispute between plaintiff and his counsel regarding settlement, but did not find that this dispute was the only, or even the predominant, reason for

withdrawal). Rather, there are various reasons unrelated to settlement strategy for the breakdown in the relationship that are sufficient for allowing the withdrawal. See Diarama Trading Co. v. J. Walter Thompson U.S.A., Inc., 2005 WL 1963945, at *2 (S.D.N.Y. Aug. 15, 2005) (finding that an ongoing dispute between plaintiff and counsel regarding legal fees “may not, by itself, constitute a sufficient reason” for withdrawal, but that counsel nevertheless showed a

“‘satisfactory’ reason for withdrawal: its irreconcilable differences with Plaintiff”). Plaintiff also argues that if Mr. Kirschbaum is permitted to withdraw, another attorney from the Firm should be required to represent her.

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Delgado v. Donald J. Trump For President, Inc., (S.D.N.Y. 2023).

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