1 

IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF TEXAS

FORT WORTH DIVISION

JENNIFER VANDERSTOK, et al.,

Plaintiffs, 

and

BLACKHAWK MANUFACTURING GROUP,

INC.; DEFENSE DISTRIBUTED; and SECOND

AMENDMENT FOUNDATION, INC.,

Intervenor-Plaintiffs, 

v. 

MERRICK GARLAND, in his official 

capacity as Attorney General of the United States;

et al., 

Defendants.

Civil Action No. 4:22-cv-00691-O 

UNOPPOSED MOTION TO WITHDRAW AS COUNSEL 

 Pursuant to Local Rule 83.12.(a), undersigned counsel, Erin M. Erhardt, hereby

respectfully moves to withdraw her appearance for the Plaintiffs in this matter. Ms. Erhardt has

accepted a new position, and her employment with Mountain States Legal Foundation ends May

19, 2023. Plaintiffs will continue to be represented by Brian A. Abbas, who has already noticed

his appearance in this case. This withdrawal will not cause delay or prejudice to any party. 

Case 4:22-cv-00691-O Document 219 Filed 05/19/23 Page 1 of 4 PageID 4681
2 

DATED: May 19, 2023. 

R. Brent Cooper (TX Bar No. 04783250)

Benjamin D. Passey (TX Bar No. 24125681) 

COOPER & SCULLY, P.C. 

900 Jackson Street, Suite 100 

Dallas, Texas 75202 

Tele: (214) 712-9500 

Fax: (214) 712-9540 

brent.cooper@cooperscully.com 

ben.passey@cooperscully.com 

Cody J. Wisniewski* (CO Bar No. 50415) 

FIREARMS POLICY COALITION

5550 Painted Mirage Road, Suite 320 

Las Vegas, NV 89149 

Tele: (916) 378-5785 

Fax: (916) 476-2392 

cwi@fpchq.org

/s/ Erin M. Erhardt

Erin M. Erhardt* (CO Bar No. 49360) 

Brian A. Abbas* (AZ Bar No. 031866) 

MOUNTAIN STATES LEGAL FOUNDATION

2596 S. Lewis Way

Lakewood, CO 80227 

Tele: (303) 292-2021 

Fax: (877) 349-7074 

eerhardt@mslegal.org 

babbas@mslegal.org 

*Admitted pro hac vice 

Attorneys for Plaintiffs

Case 4:22-cv-00691-O Document 219 Filed 05/19/23 Page 2 of 4 PageID 4682
3 

CERTIFICATE OF SERVICE

I hereby certify that, on May 19, 2023, I electronically submitted the foregoing document 

with the clerk of court for the U.S. District Court, Northern District of Texas, using the electronic 

case filing system of the court. I hereby certify that I have served all parties electronically or by 

another manner authorized by the Federal Rule of Civil Procedure 5(b)(2). 

 /s/ Erin M. Erhardt 

 Erin M. Erhardt 

CERTIFICATE OF CONFERENCE

I certify that on May 19, 2023, counsel for Plaintiffs conferred with co-counsel for 

Plaintiffs and counsel for Defendants, and both indicated they do not oppose this motion. 

/s/ Erin M. Erhardt 

 Erin M. Erhardt 

Case 4:22-cv-00691-O Document 219 Filed 05/19/23 Page 3 of 4 PageID 4683
1 

IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF TEXAS

FORT WORTH DIVISION

JENNIFER VANDERSTOK, et al.,

Plaintiffs, 

v. 

MERRICK GARLAND, in his official 

capacity as Attorney General of the United States;

et al., 

Defendants. 

Civil Action No. 4:22-cv-00691-O 

[PROPOSED] ORDER

 Upon consideration of the unopposed motion to withdraw appearance as counsel for 

Plaintiffs filed by Erin M. Erhardt, it is hereby 

ORDERED that the motion is GRANTED. 

SO ORDERED.

Dated: 

 REED O’CONNOR

United States District Judge 

Case 4:22-cv-00691-O Document 219 Filed 05/19/23 Page 4 of 4 PageID 4684