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IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF TEXAS 

DALLAS DIVISION 

LE-VEL BRANDS, LLC 

Plaintiff, 

v. 

NATHASA ROBERSON, 

Defendant. 

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No. 3:22-CV-01366 

PLAINTIFF’S MOTION FOR STATUS CONFERENCE 

AND TO EXTEND TEMPORARY RESTRAINING ORDER 

Plaintiff Le-Vel Brands, LLC filed this case against Defendant Natasha Roberson to 

enforce a non-solicitation agreement. Presented with overwhelming evidence that Roberson was 

breaching her agreement, the state court entered a temporary restraining order (“TRO”) 

enforcing the agreement and preserving the status quo. The state court set a June 30 temporary 

injunction hearing. In a signed Rule 11 agreement, the parties agreed “to file an agreed motion 

resetting the temporary injunction hearing and extending the TRO.” See Ex. 1. 

Roberson then removed the case to this Court, meaning the case “simply comes into the 

federal system in the same condition in which it left the state system.” Matter of Meyerland, 960 

F.2d 512, 520 (5th Cir. 1992). Just three days after agreeing to extend the TRO, Roberson

changed course, and now opposes any extension. Le-Vel therefore respectfully requests that the 

Court set a status conference and extend the TRO, which would otherwise expire on June 30. 

I. FACTUAL BACKGROUND

Plaintiff Le-Vel Brands is a direct-sales company that sells health-and-wellness products. 

Doc. 1-6, p. 12. Le-Vel markets its products exclusively through independent distributors called 

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“promoters.” Id. Before someone can become a promoter, he or she must agree to Le-Vel’s 

“Promoter Agreement,” which includes a two-year non-solicitation provision. Id. 

Defendant Natasha Roberson is a former high-ranking promoter who agreed to the 

Promoter Agreement. Id. at p. 13. On June 16, 2022, after compiling overwhelming evidence that 

Roberson was raiding Le-Vel’s salesforce and causing irreparable harm, Le-Vel filed its Original 

Petition, Verified Application for Temporary Restraining Order and Temporary Injunction, and 

Motion for Expedited Discovery in Dallas County, Texas. Doc. 1-6, p. 1. The state court held a 

hearing (in which both sides were represented by counsel), granted the TRO, and set the 

temporary injunction hearing for June 30, 2022. Doc. 1-10. 

On June 20, under Texas Rule of Civil Procedure 11, the parties agreed “to file an agreed 

motion resetting the temporary injunction hearing and extending the TRO.” See Ex. 1. On June 

23, Roberson removed the case to this Court. Doc. 1. In a telephone conference on June 24, 

Roberson’s counsel indicated Roberson is now opposed to extending the TRO. 

II. ARGUMENTS AND AUTHORITY 

1. Le-Vel request a status conference. 

Le-Vel respectfully request a status conference. In particular, Le-Vel requests an 

opportunity to confer with the Court about scheduling the preliminary injunction hearing, 

discovery, and related briefing, along with any interim relief that may be necessary. See Leaf 

Trading Cards, LLC v. Upper Deck Co., No. 3:17-CV-03200-N, 2017 WL 9534099, at *1 (N.D. 

Tex. Dec. 11, 2017) (ordering the parties “to confer regarding expedited discovery and a briefing 

schedule for presenting the application for preliminary injunction on the papers.”); FED. R. CIV.

P. 16 (purposes of a pretrial conference include “expediting disposition of the action [and] 

establishing early and continuing control”). Roberson is unopposed to this request. 

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2. The Court should extend the TRO. 

Absent further agreement or order, the current TRO will expire on June 30. Doc. 1-10. 

Federal Rule of Civil Procedure 65(b)(2) authorizes the Court to extend the TRO for an 

additional 14 days (that is, until July 14, 2022) for good cause, or longer if the “adverse party 

consents.” In the state-court Rule 11 agreement, before Roberson changed course, “the parties 

agree[d] to file an agreed motion resetting the temporary injunction hearing and extending the 

TRO” (Ex. 1)—although Roberson now opposes any extension. 

Separately, there is good cause to continue preserving the status quo. “Courts have found 

good cause to extend TROs, for example, where the court needed time to fully consider the 

various arguments and motions of the parties; where the moving party needed additional time to 

prepare and present its preliminary injunction, despite diligent efforts; and where the moving 

party was continuing to attempt to serve the defendants and obtain more information about the 

case.” Sec. & Exch. Comm’n v. AriseBank, No. 3:18-CV-186-M, 2018 WL 10419828, at *1 

(N.D. Tex. Mar. 9, 2018) (internal quotation omitted). Here, the TRO simply requires Roberson 

to honor her contract for a short period while the Court develops a plan for the preliminary 

injunction hearing. Preserving the status quo would prevent Roberson from further breaching her 

non-solicitation agreement, which is “the epitome of irreparable harm” and why “enforcement of 

valid noncompete covenants by injunction is the rule rather than the exception in Texas courts.” 

Providence Title Co. v. Truly Title, Inc., 547 F. Supp. 3d 585, 604 (E.D. Tex. 2021). 

III. CONCLUSION 

Le-Vel respectfully requests that the Court enter the attached order setting a status 

conference and extending the temporary restraining order. 

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Respectfully submitted, 

/s/ Parker Graham 

Parker Graham 

 Bar No. 24087612 

 pgraham@ccsb.com 

Brent Rubin 

 Bar No. 24086834 

 brubin@ccsb.com 

Jordan Brownlow 

 Bar No. 24120729 

 jbrownlow@ccsb.com 

CARRINGTON, COLEMAN, SLOMAN

& BLUMENTHAL, L.L.P. 

901 Main Street, Suite 5500 

Dallas, Texas 75202 

Phone: (214) 855-3000 

Fax: (214) 855-1333 

Attorneys for Plaintiff 

CERTIFICATE OF CONFERENCE 

I certify that I conferred with Defendant’s counsel as follows: Starting on June 17, 2022, 

Defendant’s counsel and I conferred about an agreement to reset the temporary injunction 

hearing and extend the TRO. On June 22, Defendant’s counsel sent me a signed copy of the Rule 

11 agreement, a true and correct copy of which is attached as Ex. 1. After Defendant removed 

the case, I conferred with Defendant’s counsel by email on June 23 and 24 about the relief 

requested in this motion. In a June 24, 2022 telephone call, Defendant’s counsel said he was 

opposed to any extension of the TRO, but unopposed to the status conference. 

 

/s/ Parker Graham 

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