UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

SCOTT WALLIS, individually and 

as the sole beneficiary of USA Baby Inc.'s 

assets by Bankruptcy Court order, 

Case No. 12-5285 

Plaintiff, 

v. 

ALAN LEVINE, et al., Honorable Joan B. Gottschall 

Defendants. 

DEFENDANT CARDSERVICE INTERNATIONAL, LLC'S MEMORANDUM IN 

OPPOSITION TO PLAINTIFF'S MOTION TO DISQUALIFY 

THE LAW FIRMS OF MILLER, SHAKMAN AND BEEM, AND 

FOX ROTHSCHILD LLP, PURSUANT TO LR83.50 AND IRPC 1.18 

Defendant, Cardservice International, LLC ("CSI", incorrectly referred to in the 

Amended Complaint as "Card Services International, Inc."), by and through its undersigned 

counsel, Miller, Shakman & Beem LLP ("MSB") and Fox Rothschild LLP ("Fox"), respectfully 

submits this memorandum in opposition to the Motion of Plaintiff, Scott Wallis ("Wallis"), to 

Disqualify the Law Firms of Miller, Shakman and Beem, and Fox Rothschild LLP, Pursuant to 

LR83.50 and IRPC 1.18 (the "Motion to Disquailfy"). 

I. FACTUAL AND PROCEDURAL BACKGROUND 

A. Wallis' Amended Complaint and CSI's Motion to Dismiss 

Wallis' Amended Complaint runs to 92 pages and 657 paragraphs and names as 

defendants over 160 individuals, law firms, businesses, judges, state and federal government 

officials, and state and federal government entities, as well as several hundred Doe defendants. 

It accuses defendants of myirad violations of the bankruptcy automatic stay, racketeeirng, and 

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civil rights violations. CSI appears as a defendant because of its alleged tangential involvement 

in the Amended Complaint's allegation that certain franchisees continued using trademarks after 

franchise agreements had been terminated, rendering such use of the trademarks unauthorized. 

On August 14, 2012, CSI filed a motion to dismiss the Amended Complaint and 

accompanying memorandum in support (collectively, "CSI' s Motion to Dismiss") [ECF Nos. 19, 

21]. CSI's Motion to Dismiss details the reasons that the Court should dismiss CSI as a 

defendant in this case; namely, that Wallis' claims against CSI are barred by res judicata and/or 

fail to state claim upon which relief can be granted. On September 4, 2012, the Court set a 

briefing schedule for CSI's Motion to Dismiss, as well as the numerous other motions to dismiss 

filed by defendants in this case [ECF No. 120]. The schedule provides that Wallis is to respond 

to CSI' s Motion to Dismiss by November 11, 2012, that CSI shall reply by November 26, 2012, 

and that a status and motion heairng will be held on December 11, 2012. 

B. Wallis' Motion to Disqualify 

Apparently in response to CSI' s Motion to Dismiss Wallis' firvolous claims, Wallis filed 

his Motion to Disqualify on September 4, 2012 [ECF No. 122]. Wallis' Motion to Disqualify 

states that on November 17, 2008, Wallis filed a lawsuit styled "Scott Wallis v. Alan Levine et 

al., Case No. 08 CV 6579" (referred to herein as "Case No. 08-cv-6579"). See Motion to 

Disqualify at (1[ 2. Wallis further alleges that "[p]rior to July 28-29, 2009" he contacted MSB 

seeking legal representation in Case No. 08-cv-6579 and that "on July 28-29, 2009," he spoke by 

telephone with Edward Feldman ("Feldman"), a partner at MSB. Id. at IR 3-4. Wallis states that 

he and Feldman spoke for 15-20 minutes, duirng which conversation Wallis descirbed Case No. 

08-cv-6579 "in detail" and alleges that, at some undisclosed time, Feldman reviewed the 

complaint from Case No. 08-cv-6579. Id. at (1[ 4. Wallis contends that he considered the 

conversation to be privileged and has not waived any conlfict or interest or consented to CSI's 

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representation by MSB. Id. Finally, Wallis makes the assertion that "[a]t all times relevant, said 

communications were used and communicated by Feldman and [MSB] against Wallis in 

litigation." Id. Outside of his broad and conclusory statements, Wallis has offered no evidence 

of any such purported conduct. 

As for Fox, Wallis admits that he "does not know the extent of . . . conversations or the 

confidential information that was disclosed by Feldman to Fox" but goes on to assert that "Fox 

gained knowledge from Feldman that is directly adverse to Wallis who was a prospective client 

of Feldman and [MSB]." Id. at (1[ 17. Wallis' Motion to Disqualify requests that both MSB and 

Fox be disqualified and that CSI' s Motion to Dismiss be stricken. Id. at (1[ 23. 

B. Wallis' Prior Lawsuits Relevant to the Motion to Disqualify 

1. Case No. 08-cv-6579 

Case No. 08-cv-6579, discussed above, is the lawsuit that Wallis alleges he discussed 

with Feldman. As in this case, Wallis' complaint in Case No. 08-cv-6579 was a sprawling 

document that named dozens of defendants and spanned more than 200 pages, alleging Wallis' 

stock RICO violations and a litany of other claims, all styled as a purported shareholder 

derivative suit. CSI was not a defendant in Case No. 08-cv-6579, which was eventually 

dismissed by the Honorable Elaine E. Bucklo. 

In a submission in Case No. 08-cv-6579, Wallis offered a different account of his 

purported conversation with Feldman, while in the process of questioning the impartiality of 

Judge Bucklo. On August 4, 2009, Wallis filed a "Motion for Equitable Relief' after his 

complaint had been dismissed and stated: 

On July 28, 2009, Wallis contacted the law firm of Miller, Shakman and Beem, LLP 

("Shakman") in pursuit of legal representation for this case. Wallis' phone call was 

returned by Eddie Feldman ("Feldman") on July 28, 2009. Wallis, in his conversation 

with Feldman, learned that Shakman only represented law firms and attonreys as 

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defendants. Furthermore, Feldman stated that it was the long held and established 

practice of Shakman to not represent plaintiffs against law firms and/or attorneys. Wallis 

also learned this was the firm where Judge Bucklo practiced law as an attonrey in 

Chicago. Needless to say, Wallis, in learning these facts, has serious concerns about the 

ability of Judge Bucklo to act impartially in this case, especially given her legal training 

at Shakman. 

See Motion for Equitable Relief at (1[ 26, Case No. 08-cv-6579, Dkt. No. 119, attached hereto as 

Exhibit "A". 

2. Case No. 10-cv-5497 (District Court Appeal of Case No. 10-a-1212) 

A second prior lawsuit discussed in the Motion to Disqualify is Case No. 10-cv-5497, in 

which Wallis states he "notified" MSB of the alleged conlfict. Case No. 10-cv-5497 represented 

an appeal before the distirct court of a bankruptcy adversary proceeding, Case No. 10-a-1212. 

On February 3, 2011, Wallis filed, in Case No. 10-cv-5497, a document styled "Joint Reply Biref 

and Appendix in Support of Appellants' Joint Opening Brief and in Opposition to Appellees' 

Briefs Appellants Scott Wallis and Ron Eriksen. " Wallis' claimed "notification" was a passing 

reference to his alleged conversation with Feldman in a footnote in which Wallis purported to 

object to CSI' s even referencing Case No. 08-cv-6579 (presumably because of the alleged 

conlfict stemming from Judge Bucklo's past association with MSB), and made vague and 

unsubstantiated allegations of CSI passing information to unnamed "other Appellees." The 

footnote reads: 

Appellants [i.e., Wallis] object to the introduction of said case [i.e., Case No. 08-cv-6579] 

introduced into Case Nos. 10 AP 1212 & 10 CV 5497 by Defendants. On July 29, 2009, 

Wallis contacted the law firm of Miller, Shakman & Beem, LLP ("Shakman") to discuss 

representation in Case No. 08 CV 6579. Wallis discussed said case with Shakman, via 

attorney Eddie Feldman ("Feldman"), on the belief that Shakman would represent Wallis. 

Shakman, after reviewing said case, decided that it would not represent Wallis. Pursuant 

to lIlinois Rules of Professional Conduct ("IRPC"), specifically IRPC Rules 1.18, 1.9 & 

1.10, Shakman is a conlficted counsel. Furthermore, Wallis believes that Shakman has 

discussed information he disclosed related to said case with other Appellees. Information 

related to Case No. 08 CV 6579, introduced by Shakman, or Appellees, in Case Nos. 10 

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AP 1212 & 10 CV 6579, should be stircken, due to said conflict and the passing of 

information by Shakman to other Appellees. 

Although his conversation with Feldman allegedly took place in July 2009, Wallis never 

moved to disqualify MSB or Fox from representing CSI in Case No. 10-cv-5497 or Case No. 10- 

a-1212.1 

C. Feldman Does Not Recall The Alleged Conversation 

With Wallis or Any AllegedlyDisclosed Confidential Information 

Feldman has no recollection of Wallis contacting him on or about July 29, 2009, or at any 

other time regarding Case No. 08-cv-6579. See Affidavit of Edward W. Feldman, Esquire atl 3, 

attached hereto as Exhibit "B". Feldman does not recognize Wallis' name. Id. Feldman found 

nothing relating to Wallis or Case No. 08-cv-6579 in his emails from the time peirod of July 29, 

2009. Id. atl 4. Feldman's calendar from July 2009 also contained no references to any contact 

with Wallis or anyone else regarding Case No. 08-cv-6579. Id. at 1 5. In fact, Feldman located 

no documents or other records at MSB pertaining to Wallis or Case No. 08-cv-6579, and found 

nothing to suggest that he ever spoke with Wallis or anyone else regarding that matter. Id. atl 6. 

Feldman reviewed the docket on PACER for Case No. 08-cv-6579, which was wholly unfamiliar 

to Feldman. Id. at 1 7. Indeed, the docket did not refresh any recollection on Feldman's part 

pertaining to any contact with Wallis or anyone else regarding that matter. Id. 

Assuming that Wallis contacted Feldman in July 2009, Feldman has no recollection, 

notes or other documents relfecting any information regarding Case No. 10-cv-5497 or any other 

1 As discussed in CSI's Motion to Dismiss, Wallis filed yet another lawsuit against CSI, which lawsuit 

forms the basis for CSI' s res judicata argument in this case. On November 10, 2010, Wallis filed a 

complaint in the United States District Court for the Northern District of lIlinois against CSI and The 

Travelers Indemnity Company ("Case No. 10-cv-07250"). MSB and Fox represented CSI from the 

inception of Case No. 10-cv-07250 through its dismissal as to CSI, yet Wallis never moved to disqualify 

MSB and/or Fox in that case either. It is only now, atfer being faced with another motion to dismiss 

Wallis' repetitious and frivolous claims, that Wallis raises this purported issue. 

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matter involving Wallis. Id. at (1[ 8. Indeed, Feldman has no recollection of Wallis or anyone 

asking him to represent them in Case No. 08-cv-6579. Id. at (1[ 10. Of course, Wallis never 

retained MSB or Feldman to represent Wallis in Case No. 08-cv-6579. Id. at (1[ 11.2 

II. ARGUMENT 

Disqualification of a party's chosen counsel "is a drastic measure which courts should 

hesitate to impose except when absolutely necessary [because a] disqualification of counsel, 

while protecting the attonrey-client relationship, also serves to destroy a relationship by 

depirving a party of representation of their own choosing." Freeman v. Chicago Musical 

Instrument Co., 689 F.2d 715, 721-722 (7th Cir. 1982). As this Court noted in its September 11, 

2012 order setting a birefing schedule on the Motion to Disqualify (which order at the same time 

denied two additional motions to disqualify filed by Wallis, calling one of them frivolous), 

motions for disqualification "should be viewed with extreme caution for they can be misused as 

techniques of harassment." Freeman, 689 F.2d at 722. "Accordingly, the burden is on the moving 

party to show the facts warranting disqualification." Van Jackson v. Check 'NT Go of Ill., Inc., 

114 F. Supp. 2d 731, 732 (N.D. Ill. 2000). As this Court noted, "[t]here must be solid evidence 

of conflict; the court will not grant a motion for disqualification 'where the mere appearance of 

impropriety is far from clear. " See September 11, 2012 Order [ECF No. 144] (quoting 

Freeman, 689 F.2d at 723). 

2 Wi• th the exception of (i) Feldman contacting his partner, Marc Beem, on February 7 and 8, 2011 

regarding the footnote discussed above in Case No. 10-cv-5497 and the facts in his affidavit and (ii) a 

conversation with counsel from Fox in December 2010 regarding procedures in the Northenr District of 

lIlinois regarding another suit that Wallis commenced against CSI, Feldman had no contact with any of 

the parties or their counsel regarding these proceedings. Id. atl 9. 

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ABA Model Rules of Professional Conduct Rule 1.18 ("Rule 1.18")3pertains to the 

disqualification of counsel due to alleged "prospective client" relationships. It provides: 

(a) A person who consults with a lawyer about the possibility of forming a client-lawyer 

relationship with respect to a matter is a prospective client. 

(b) Even when no client-lawyer relationship ensues, a lawyer who has learned 

information from a prospective client shall not use or reveal that information, except as 

Rule 1.9 would permit with respect to information of a former client. 

(c) A lawyer subject to paragraph (b) shall not represent a client with interests materially 

adverse to those of a prospective client in the same or a substantially related matter if the 

lawyer received information from the prospective client that could be significantly 

harmful to that person in the matter, except as provided in paragraph (d). If a lawyer is 

disqualified from representation under this paragraph, no lawyer in a firm with which that 

lawyer is associated may knowingly undertake or continue representation in such a 

matter, except as provided in paragraph (d). 

The first question under this Rule is whether a prospective client relationship existed at 

all. See Cascades Branding Innovation, LLC v. Walgreen Co., 2012 WL 1570774, at *6 (N.D. 

Ill. May 3, 2012). If so, courts consider "whether a substantial relationship exists between a 

client and an attorney," and have applied the following three-prong test: 

a three-level inquiry [should] be undertaken . . . First, the tiral judge must make a factual 

reconstruction of the scope of the prior legal representation. Second, it must be 

determined whether it is reasonable to infer that the confidential information allegedly 

given would have been given to a lawyer representing a client in those matters. Third, it 

must be determined whether that information is relevant to the issues raised in the 

litigation pending against the former client. 

Id. at *6 (quoting LaSalle Nat'l Bank v. County of Lake, 703 F.2d 252, 255-256 (7th Cir. 1983) 

and applying three-pronged test to prospective-client scenario). 

CSI discusses these factors below, but highlights here that the defining characteristic of 

Wallis' recounting of his alleged conversation with Feldman is its complete lack of detail 

3 See Locla Civil Rule 83.50 ("Applicable disciplinary rules are the Model Rules adopted by the 

American Bar Association."). Wallis cites to rules of professional conduct from lIlinois, where MSB is 

located, and Pennsylvania, where Fox is located. These state rules are modeled after the ABA Model 

Rule and similar if not identical to the rules in a number of other jurisdictions. 

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regarding what was actually discussed; there is no "solid evidence of conflict. " Instead, Wallis 

makes a series of conclusory and unsubstantiated assertions. In the Motion to Disqualify, Wallis 

states he "descirbed [Case No. 08-cv-6579] in detail," but does not say what comprised this 

description, much less that it involved any confidential information. See Motion to Disqualify at 

(1[ 4. In the affidavit Wallis submitted with the Motion to Disqualify, Wallis is equally vague, 

merely stating that he "disclosed confidential information pertaining to Case No. 08 CV 6579." 

See Exhibit B to Motion to Disqualify at (1[ 5. These bald assertions, with no detail or 

corroborating evidence, wholly fail to carry Wallis' burden. 

1. No Prospective Client Relationship 

Was Formed Between Wallis and MSB. 

Wallis does not proffer enough evidence to carry his burden in establishing that a 

prospective client relationship was even formed, much less that it requires disqualification. 

Wallis' vague, conclusory accounting of this telephone conversation, coupled with Feldman's 

affidavit stating that he recalls no details of such a conversation or even that it occurred, are 

insufficient to demonstrate that Wallis "consult[ed] with [Feldman] about the possibility of 

forming a client-lawyer relationship with respect to a matter " See Rule 1.18. 

2. If A Prospective Client Relationship 

Was Formed, Its Scope Was Extremely Limited. 

To the extent this prong applies to prospective (as opposed to former) clients, it clearly 

counsels against disqualification in this case. Wallis alleges a 15 to 20 minute phone call and 

fails to identify at any level of detail what was discussed. The conversation was so 

inconsequential that Feldman does not recall it occurirng. Given the scope of this alleged 

communication, the burden placed on Wallis is especially heavy in demonstrating that it should 

have any bearing on this case, a burden he totally fails to meet. 

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3. Wallis Provides No Basis To 

Reasonably Infer That Confidential Information Was Disclosed. 

The Cascades Branding court next asked whether "it is reasonable to infer that the 

confidential information allegedly given would have been given to a lawyer representing a client 

in those matters," and in answering this question provides an excellent contrast to this case. In 

Cascades Branding, the court discussed a series of emails in which details about the plaintiff s 

patent portfolio were passed to a lawyer who then declined to represent the plaintiff and ended 

up representing defendant in the case where disqualification was sought. The court noted that 

the emails were "illuminating as to [plaintiff s] core litigation, licensing, reasonable royalty and 

business model strategies," and also relfected additional communications beyond the emails. 

2012 WL 1570774 at *9. As corroboration for the substantive nature of these communications, 

the court noted that the counsel involved could recall details regarding plaintiff off the top of his 

head. Id. Conversely, where, as here, the purpotred prospective client fails set out in detail the 

information allegedly disclosed, disqualification is not proper. See Conn v. U.S. Steel Corp., 

2009 WL 260955, at *6 (N.D. Ind. Feb. 2, 2009) (denying motion to disqualify under Indiana's 

Rule 1.18 where plaintiff failed to identify the confidential information that was allegedly 

disclosed). 

Needless to say, there is nothing in this case approaching the level of detailed disclosures 

at issue in Cascade Branding. In his submission in this case, Wallis provides no details regarding 

the alleged disclosures. The only potential clue as to what was actually discussed comes in 

Wallis' submission in Case No. 08-cv-6579 in which Wallis questioned the impartiality of Judge 

Bucklo. That discussion, provided before Wallis had any reason to seek disqualification, gives 

no indication that any confidential information passed between Wallis and Feldman. At most it 

implies that he and Feldman discussed the fact that some of the defendants in Case No. 08-cv9 

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6579 were law firms, information that could be gleaned from an inspection of the publicly 

available complaint and docket. 

4. Wallis Provides No Basis To Find 

That Information Relevant To This Matter Was Disclosed. 

The third factor considered by the Cascades Branding court was whether the disclosed 

information "is relevant to the issues raised in the litigation pending against the former client." 

This prong essentially asks the key question posed by Rule 1.18 whether the information 

received from the prospective client could be "substantially harmful" to the prospective client in 

the matter where disqualification is sought. See Cascades Branding, 2012 WL 1570774 at *9. 

In this case, Wallis has not made this showing, because, again, Wallis has not identified 

any information that was allegedly disclosed. This failure of proof is fatal to his Motion to 

Disqualify. The New Jersey Supreme Court recently defined "significantly harmful" information 

as used in its Rule of Professional Conduct 1.18, which is similar to Illinois' Rule 1.18, and held: 

DI order for information to be deemed "significantly harmful" within the context of 

RPC 1.18, disclosure of that information cannot be simply detrimental in general to the 

former prospective client, but the harm suffered must be prejudicial in fact to the former 

prospective client within the confines of the specific matter in which disqualification is 

sought, a determination that is exquisitely fact-sensitive and specific. 

0 Builders & Assoc. Inc. v. Yuna Corp., 19 A.3d 966, 976 (N.J. 2011). In that case, the court 

denied a motion to disqualify because the alleged prospective client failed to meet the "burden of 

production and persuasion in the request to disqualify" by "vaguely claim[ing] only that 

information 'concerning pending litigation and business matters' had been disclosed" and 

making "bald and unsubstantiated assertions. " Id.; see also State ex rel. Thompson v. Dueker, 

346 S.W.3d 390, 396 (Mo. App. E.D. 2011) (applying similar Missouri rule and finding "specific 

evidence of the nature and substance of the information is required in Rule 4-1.18 proceedings 

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to establish that it is 'significantly harmful;' speculative or hypothetical claims of harm are not 

enough.") (emphasis added). 

For all of the reasons discussed above, Wallis has not provided any evidence, much less 

"specific evidence of the nature and substance," of the information he purportedly disclosed to 

Feldman that could conceivably be "substantially harmful" to his interests in this case. His 

assertion that "Nit all times relevant, said communications were used and communicated by 

Feldman and [MSB] against Wallis in litigation" is, like the rest of his allegations, conclusory, 

unsubstantiated and inadequate to carry his burden. The lack of harm is further evidenced by 

Wallis' failure to seek disqualification of MSB in at least two prior lawsuits in which MSB 

represented CSI after Wallis' alleged conversation with Feldman. The Motion to Disqualify was 

proffered for no other reason than to harass CSI and in a thinly veiled attempt to avoid the 

dismissal of yet another frivolous lawsuit. 

5. Wallis Provides No Basis to Disqualify Fox 

As discussed above, Wallis' threadbare account of his conversation with Feldman cannot 

carry his burden in seeking the disfavored relief of attorney disqualification under any 

circumstances. Regarding Fox, Rule 1.18 applies to "a lawyer who has had discussions with a 

prospective client" and provides that, if a conlfict of interest is found, "no lawyer in a firm with 

which that lawyer is associated may" continue to be adverse to the prospective client. Wallis 

cites no authoirty to hold that the communication of a prospective client with one law firm 

should be imputed to another law firm, and his admission that he does not know whether 

Feldman passed to Fox any information he allegedly learned (albeit followed by the naked and 

contradictory assertion that he did pass such information) does not support any such imputation. 

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CSI believes that the Motion to Disqualify has no merit as to MSB or Fox, but should the 

Court disagree as to MSB, CSI respectfully submits that there is no basis whatsoever to 

disqualify Fox. 

III. RELIEF REQUESTED 

Accordingly, CSI respectfully requests that the Court deny Wallis' Motion to Disqualify. 

Respectfully submitted, 

s/ Melissa B. Pryor 

Marc O. Beem, Esquire 

Melissa B. Pryor, Esquire 

MILLER SHAKMAN & BEEM LLP 

180 North LaSalle Street, Suite 3600 

Chicago, IL 60601 

Tel. 312-263-3700/Fax 312-263-3270 

mbeem@millershakman.com 

mpryor@millershakman.com 

Joshua Horn, Esquire (admitted pro hac vice) 

Kenneth H. Leichter, Esquire (admitted pro hac vice) 

FOX ROTHSCHILD LLP 

2000 Market Street, 20thFloor 

Philadelphia, PA 19103-3222 

Tel. 215-299-2000/Fax 215-299-2150 

jhom@foxrothschild.com 

kleichter@foxrothschild.com 

Attonreys for Defendant 

Cardservice Intenrational, LLC 

Dated: October 5, 2012 

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UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

SCOTT WALLIS, individually and 

as the sole beneficiary of USA Baby Inc.'s 

assets by Bankruptcy Court order, 

Case No. 12-5285 

Plaintiff, 

v. 

ALAN LEVINE, et al., Honorable Joan B. Gottschall 

Defendants. 

CERTIFICATE OF SERVICES 

The undersigned attorney, upon oath, hereby creativities that a copy of the foregoing 

memorandum of defendant, Cardservice International, Inc., in opposition to Plaintiff s Motion to 

Disqualify the Law Firms of Miller, Shakman and Beem, and Fox Rothschild LLP, Pursuant to 

LR83.50 and IRPC 1.18, was served upon the party listed below via U.S. Mail, postage prepaid, 

on the 5th day of October, 2012: 

Scott Wallis 

2534 Emily Lane 

Elgin, IL 60124 

Pro se plaintiff 

s/ Kenneth H. Leichter 

Case: 1:12-cv-05285 Document #: 170 Filed: 10/05/12 Page 13 of 13 PageID #:821