On January 13, 2022 a
Motion-Secondary
was filed
involving a dispute between
Beddow, Brooke,
and
Bayside Dental,
Boeke, Brad,
Boeke, Carolyn,
for EMPLOYMENT
in the District Court of Dallas County.
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FILED
2/23/2024 1:52 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Martin Reyes DEPUTY
CAUSE NO. DC-22-00478
BROOKE BEDDOW § IN THE DISTRICT COURT OF
§
Plaintiffs, §
§
v. § DALLAS COUNTY, TEXAS
§
BAYSIDE DENTAL & BRAD BOEKE §
§
Defendants. § 191st JUDICIAL DISTRICT
RESPONSE TO MOTION TO WITHDRAW
Plaintiff, BROOKE BEDDOW (hereinafter “Beddow”) files this her Response to
Defendants counsel’s Motion to Withdraw, and in support thereof would respectfully show this
Court as follows:
1. On January 13, 2022, Plaintiff Beddow filed this case against Defendants Bayside
Dental and Brad Boeke.
2. Initially, Carla Rankin served as counsel for Defendants.
3. On December 29, 2022, Rankin filed a motion to substitute counsel with attorney
John Frick. Ms. Rankin conferred with Plaintiff’s counsel regarding the motion to substitute
counsel.
4. On January 9, 2023, this Court granted Plaintiff’s motion to substitute, and Mr.
Frick served as counsel for Defendants.
5. The parties have conducted discovery, and discussed settlement.
6. As will be raised, the parties came to an agreed upon and enforceable settlement
agreement, with sufficient and substantial terms on or around July 13, 2023. Since then,
Defendants have been largely unresponsive to repeated follow-ups by counsel for Plaintiff.
RESPONSE TO MOTION TO WITHDRAW 1
7. On November 14, 2023, Mr. Frick filed a Motion to Withdraw.
8. Mr. Frick did not conference with Plaintiff and notably, there is no substitution of
counsel offered.
9. This case is set for Jury Trial on April 1, 2024 and the hearing on Mr. Frick’s motion
for withdrawal for March 20, 2024 at 10:00 a.m.
10. Plaintiff oppose/object to Mr. Frick’s Motion to Withdraw as Counsel to the extent
that there is no substitution of counsel and/or it would delay the trial.
11. Rule 10 requires a showing of good cause for withdrawal, but it also permits the
Court to “impose further conditions upon granting leave to withdraw.”
12. While Plaintiff is sympathetic to Mr. Frick’s situation, Plaintiff’s case must proceed
to trial efficiently and with active counsel.
13. Defendant Bayside Dental is a professional limited liability company. If Mr.
Frick’s withdrawal was granted, Bayside dental would be unrepresented. "Legal entities, such
as.... a limited liability company, generally may appear in a district or county court only through a
licensed attorney." Sherman v. Boston, 486 S.W.3d 88, 95-96 (Tex. App. – Houston [14th Dist.]
2016, pet. denied).
WHEREFORE, PREMISES CONSIDERED, Beddow respectfully requests that this Court
only permit Mr. Frick’s Motion to Withdraw as counsel for Defendants once another attorney has
been obtained on this matter, and grant her such other and further relief to which they may be
entitled.
RESPONSE TO MOTION TO WITHDRAW 2
DATED: February 23, 2024
Respectfully submitted,
By:_/s/Ditty S. Bhatti ____________
Vincent J. Bhatti
State Bar No. 24055169
Ditty S. Bhatti
State Bar No. 24062803
5700 Tennyson Parkway,
Suite 300
Plano, Texas 75024
(214) 253-2533 (Telephone)
(214) 279-0033 (Facsimile)
Vincent.bhatti@bhattilawfirm.com
Ditty.bhatti@bhattilawfirm.com
Attorneys for Plaintiff
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the above Response to Defendant’s counsel’s
Motion to Withdraw has been sent by electronic filing and email to counsel for Brad
Boeke/Bayside Dental, Mr. John M. Frick, 2600 Dallas Parkway, Suite 380, Frisco, TX 75034 on
this 23rd day of February, 2024.
/s/Vincent J. Bhatti_________
Vincent J. Bhatti
RESPONSE TO MOTION TO WITHDRAW 3
Automated Certificate of eService
This automated certificate of service was created by the efiling system.
The filer served this document via email generated by the efiling system
on the date and to the persons listed below. The rules governing
certificates of service have not changed. Filers must still provide a
certificate of service that complies with all applicable rules.
Ditty Bhatti
Bar No. 24062803
ditty.bhatti@bhattilawfirm.com
Envelope ID: 84846601
Filing Code Description: Response
Filing Description: TO MOTION TO WITHDRAW
Status as of 2/24/2024 6:26 AM CST
Associated Case Party: BROOKE BEDDOW
Name BarNumber Email TimestampSubmitted Status
VINCENT JBHATTI vincent.bhatti@bhattilawfirm.com 2/23/2024 1:52:18 PM SENT
Associated Case Party: BAYSIDE DENTAL
Name BarNumber Email TimestampSubmitted Status
Carla S.Rankin carla@rankinlawgroup.net 2/23/2024 1:52:18 PM SENT
Chasten West admin@rankinlawgroup.net 2/23/2024 1:52:18 PM SENT
Chandra Rodriguez crodriguez@reiddennis.com 2/23/2024 1:52:18 PM SENT
John Frick jfrick@reiddennis.com 2/23/2024 1:52:18 PM SENT
Associated Case Party: BRAD BOEKE
Name BarNumber Email TimestampSubmitted Status
Chandra Rodriguez crodriguez@reiddennis.com 2/23/2024 1:52:18 PM SENT
John Frick jfrick@reiddennis.com 2/23/2024 1:52:18 PM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Carolyn Boeke cgboeke@gmail.com 2/23/2024 1:52:18 PM SENT
Document Filed Date
February 23, 2024
Case Filing Date
January 13, 2022
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FILED 2/23/2024 1:52 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Martin Reyes DEPUTY CAUSE NO. DC-22-00478 BROOKE BEDDOW § IN THE DISTRICT COURT OF § Plaintiffs, § § v. § DALLAS COUNTY, TEXAS § BAYSIDE DENTAL & BRAD BOEKE § § Defendants. § 191st JUDICIAL DISTRICT RESPONSE TO MOTION TO WITHDRAW Plaintiff, BROOKE BEDDOW (hereinafter “Beddow”) files this her Response to Defendants counsel’s Motion to Withdraw, and in support thereof would respectfully show this Court as follows: 1. On January 13, 2022, Plaintiff Beddow filed this case against Defendants Bayside Dental and Brad Boeke. 2. Initially, Carla Rankin served as counsel for Defendants. 3. On December 29, 2022, Rankin filed a motion to substitute counsel with attorney John Frick. Ms. Rankin conferred with Plaintiff’s counsel regarding the motion to substitute counsel. 4. On January 9, 2023, this Court granted Plaintiff’s motion to substitute, and Mr. Frick served as counsel for Defendants. 5. The parties have conducted discovery, and discussed settlement. 6. As will be raised, the parties came to an agreed upon and enforceable settlement agreement, with sufficient and substantial terms on or around July 13, 2023. Since then, Defendants have been largely unresponsive to repeated follow-ups by counsel for Plaintiff. RESPONSE TO MOTION TO WITHDRAW 1 7. On November 14, 2023, Mr. Frick filed a Motion to Withdraw. 8. Mr. Frick did not conference with Plaintiff and notably, there is no substitution of counsel offered. 9. This case is set for Jury Trial on April 1, 2024 and the hearing on Mr. Frick’s motion for withdrawal for March 20, 2024 at 10:00 a.m. 10. Plaintiff oppose/object to Mr. Frick’s Motion to Withdraw as Counsel to the extent that there is no substitution of counsel and/or it would delay the trial. 11. Rule 10 requires a showing of good cause for withdrawal, but it also permits the Court to “impose further conditions upon granting leave to withdraw.” 12. While Plaintiff is sympathetic to Mr. Frick’s situation, Plaintiff’s case must proceed to trial efficiently and with active counsel. 13. Defendant Bayside Dental is a professional limited liability company. If Mr. Frick’s withdrawal was granted, Bayside dental would be unrepresented. "Legal entities, such as.... a limited liability company, generally may appear in a district or county court only through a licensed attorney." Sherman v. Boston, 486 S.W.3d 88, 95-96 (Tex. App. – Houston [14th Dist.] 2016, pet. denied). WHEREFORE, PREMISES CONSIDERED, Beddow respectfully requests that this Court only permit Mr. Frick’s Motion to Withdraw as counsel for Defendants once another attorney has been obtained on this matter, and grant her such other and further relief to which they may be entitled. RESPONSE TO MOTION TO WITHDRAW 2 DATED: February 23, 2024 Respectfully submitted, By:_/s/Ditty S. Bhatti ____________ Vincent J. Bhatti State Bar No. 24055169 Ditty S. Bhatti State Bar No. 24062803 5700 Tennyson Parkway, Suite 300 Plano, Texas 75024 (214) 253-2533 (Telephone) (214) 279-0033 (Facsimile) Vincent.bhatti@bhattilawfirm.com Ditty.bhatti@bhattilawfirm.com Attorneys for Plaintiff CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the above Response to Defendant’s counsel’s Motion to Withdraw has been sent by electronic filing and email to counsel for Brad Boeke/Bayside Dental, Mr. John M. Frick, 2600 Dallas Parkway, Suite 380, Frisco, TX 75034 on this 23rd day of February, 2024. /s/Vincent J. Bhatti_________ Vincent J. Bhatti RESPONSE TO MOTION TO WITHDRAW 3 Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules. Ditty Bhatti Bar No. 24062803 ditty.bhatti@bhattilawfirm.com Envelope ID: 84846601 Filing Code Description: Response Filing Description: TO MOTION TO WITHDRAW Status as of 2/24/2024 6:26 AM CST Associated Case Party: BROOKE BEDDOW Name BarNumber Email TimestampSubmitted Status VINCENT JBHATTI vincent.bhatti@bhattilawfirm.com 2/23/2024 1:52:18 PM SENT Associated Case Party: BAYSIDE DENTAL Name BarNumber Email TimestampSubmitted Status Carla S.Rankin carla@rankinlawgroup.net 2/23/2024 1:52:18 PM SENT Chasten West admin@rankinlawgroup.net 2/23/2024 1:52:18 PM SENT Chandra Rodriguez crodriguez@reiddennis.com 2/23/2024 1:52:18 PM SENT John Frick jfrick@reiddennis.com 2/23/2024 1:52:18 PM SENT Associated Case Party: BRAD BOEKE Name BarNumber Email TimestampSubmitted Status Chandra Rodriguez crodriguez@reiddennis.com 2/23/2024 1:52:18 PM SENT John Frick jfrick@reiddennis.com 2/23/2024 1:52:18 PM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status Carolyn Boeke cgboeke@gmail.com 2/23/2024 1:52:18 PM SENT