UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

FORT LAUDERDALE DIVISION

BRANDON THOMPSON 

 Plaintiff,

v. Case No. 20-cv-60885-PMH

FORT LAUDERDALE LAW 

GROUP SOUTH, PLLC, 

Defendant.

 / 

UNOPPOSED MOTION TO WITHDRAW AS COUNSEL FOR DEFENDANT 

Defendant, FORT LAUDERDALE LAW GROUP SOUTH, PLLC (“Defendant”) and 

counsel for the Defendant, Jesse I. Unruh, Esq., pursuant to Southern District of Florida Local 

Rule 11.1(d)(3), move this Honorable Court to remove Jesse I. Unruh, Esq. and Spire Law, LLC

as counsel of record, and in support thereof state: 

1. On April 1, 2021, this Court issued an order Approving Settlement Agreement and 

Dismissing Case with Prejudice. See ECF No. 70. The Court retained jurisdiction to enforce the 

terms of the agreement for twenty-eight (28) months from April 1, 2021. 

2. Following Plaintiff’s assertion that Defendant had failed fulfill its settlement obligations, 

Plaintiff’s counsel contacted the undersigned to determine if Defendant would retain Spire Law to 

defend the asserted breach issue. The undersigned indicated that Defendant had not retained the 

form to handle that issue and did not anticipate that occurring. 

3. Through clerical oversight, the undersigned’s office did not denote that the case had 

returned to an active status for which the undersigned remained as counsel of record for Defendant.

4. On March 8, 2023, Plaintiff filed its Motion to Enforce Settlement, for Sanctions and 

Case 0:20-cv-60885-PMH Document 80 Entered on FLSD Docket 08/21/2023 Page 1 of 4
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Attorneys’ Fees and Costs Against Defendant. See ECF No. 71.

5. On March 27, 2023, this Court entered an Order requiring Defendant to respond to 

Plaintiff’s Motion on or before March 30, 2023. See ECF No. 73.

6. On March 28, 2023, counsel for Defendant forwarded the Order to Defendant and 

Defendant confirmed they did not want the undersigned to represent them in the enforcement 

matter.

7. On or about April 12, 2023, the undersigned notified counsel for Plaintiff that Defendant 

had not retained Spire Law to represent it in the enforcement proceedings and indicated that 

Plaintiff’s counsel was free to contact the Defendant directly.

8. On July 26, 2023, this Court granted Plaintiff’s Second Motion to Enforce Settlement, For 

Sanctions and Attorneys’ Fees and Costs Against Defendant, FORT LAUDERDALE LAW 

GROUP SOUTH, PLLC (“Defendant”). See ECF No. 77.

9. Plaintiff’s counsel courteously indicated to Spire Law that the undersigned was still 

counsel of record and expected at the hearing relating to the above motion. 

10. The Court set an in-person show cause hearing for August 21, 2023 which was continued 

until September 6, 2023.

11. Consistent with the wishes of the Defendant, the undersigned seeks to be relieved of all 

further responsibilities regarding this matter.

12. Rule 4-1.16(b) of the Rules Regulating the Florida Bar allows withdrawal if:

1) Withdrawal can be accomplished without material adverse effects on the interests 

of the client;

2) The client insists upon taking action that the lawyer considers repugnant, 

imprudent, or with which the lawyer has a fundamental disagreement; 

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3) The client fails substantially to fulfill an obligation to the lawyer regarding the 

lawyer’s services and has been given reasonable warning that the lawyer will 

withdraw unless the obligation is fulfilled;

4) The representation will result in an unreasonable financial burden on the lawyer or 

has been rendered unreasonably difficult by the client; or 

5) Other good cause for withdrawal exists. 

13. Courts have the discretion to allow counsel to permissively withdraw from representation. 

14. Good cause exists here. Defendant’s counsel represented Defendant up to and including 

the dismissal of this action on April 1, 2021. On or around the time of receipt of Plaintiff’s Motion 

to Enforce Settlement, For Sanctions and Attorneys’ Fees and Costs Against Defendant, the 

undersigned advised Plaintiff’s counsel that Defendant had not retained the undersigned regarding 

any enforcement proceedings and further directed Plaintiff’s counsel to contact Defendant directly. 

15. Accordingly, the undersigned respectfully requests to facilitate future communications 

with Defendant, the following contact information has been provided as such: 

Fort Lauderdale Law Group South, PLLC 

c/o Chris Patterson, Esquire 

1250 S. Pine Island Road, Suite 250 

Plantation, Florida 33324 

Phone: (954) 306-8420

Fax: (954) 306-8430

Email: chrispatterson@LawFLLG.com 

WHEREFORE, Defendant, FORT LAUDERDALE LAW GROUP SOUTH, PLLC, and the 

undersigned respectfully request that Jesse I. Unruh, Esq. and Spire Law, LLC be removed as 

counsel of record and be excused from attendance from the Show Cause Hearing set for September 

6, 2023. 

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LOCAL RULE 7.1(a)(3) CERTIFICATE

Counsel for Defendant has conferred with counsel for Plaintiff who has no objection to the 

relief requested.

Dated this 21st day of August, 2023. 

Respectfully submitted,

SPIRE LAW, LLC

2572 W. State Road 426, Suite 2088 

Oviedo, Florida 32765 

By: /s/Jesse I. Unruh 

Jesse I. Unruh, Esq. 

 Florida Bar No. 93121 

jesse@spirelawfirm.com

marcela@spirelawfirm.com

filings@spirelawfirm.com

CERTIFICATE OF SERVICE

I hereby Certify that on this 21st day of August, 2023, the foregoing was electronically 

filed with the Court by CM/ECF portal, which will send a notice of electronic filing to: Noah E. 

Storch, Esquire, at noah@floridaovertimelawyer.com, at 10368 West State Road 84, Suite 103, 

Davie, FL 33324 and a copy sent via U.S. Mail and electronic mail to:

Chris Patterson, Esquire 

1250 S. Pine Island Road, Suite 250 

Plantation, Florida 33324 

Email: chrispatterson@LawFLLG.com 

 /s/ Jesse I. Unruh 

 Attorney 

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