Christiansen v. Spectrum Pharmaceuticals, Inc.
- Valerie Caproni
- 1:22-cv-10292
- U.S. District Court · Southern District of New York
- 7
In Christiansen v. Spectrum Pharmaceuticals, Judge Caproni granted counsel’s withdrawal motion, giving Christiansen three options after a new lead plaintiff is appointed.
Steven B. Christiansen and Kaplan Fox & Kilsheimer LLP, including attorneys Robert N. Kaplan, Jeffrey P. Campisi, and Brandon Fox. Christiansen must address his representation after a new lead plaintiff is appointed.
What happened
Christiansen v. Spectrum Pharmaceuticals, Inc. involved Steven B. Christiansen’s opposition to Kaplan Fox & Kilsheimer LLP’s request to withdraw as his lawyers. The opinion concerns the attorney-client relationship, not the merits of the investors’ securities case.
Christiansen argued that his lawyer, Jeffrey P. Campisi, had failed to pursue his requests about settlement and that finding new counsel would be difficult. He also argued that Kaplan Fox’s expected fee lien would discourage other firms from representing him. Kaplan Fox argued that Christiansen’s filing showed the relationship had broken down and made continued representation unreasonably difficult.
Judge Valerie Caproni granted the motion to withdraw. She ordered the Clerk to end the appearances of Robert N. Kaplan, Jeffrey P. Campisi, and Brandon Fox, and said Jennifer Ligansky had never appeared. Within 30 days after a new lead plaintiff is appointed, Christiansen must obtain new counsel, file a notice that he will represent himself, or withdraw as a named plaintiff.
The detailed version
- Christiansen v. Spectrum Pharmaceuticals, Inc. · No. 1:22-cv-10292
- Valerie Caproni
- Aug. 26, 2025
Background
Steven B. Christiansen, a former court-appointed lead plaintiff and a member of the proposed investor class, opposed Kaplan Fox & Kilsheimer LLP’s motion to withdraw as his counsel. The submission states that Kaplan Fox attorneys Robert N. Kaplan, Jeffrey P. Campisi, and Brandon Fox sought withdrawal; it also references Jennifer Ligansky, who the Court said had never appeared in the case.
Christiansen argued that Campisi had not followed his requests to contact defense counsel about a possible settlement and that Christiansen’s filing with the Court was necessary to communicate his concerns. He also argued that Kaplan Fox’s anticipated charging lien for fees would make it difficult or impossible to find another law firm. A charging lien is a lawyer’s claimed right to seek payment from a recovery in the case.
Kaplan Fox argued that Christiansen’s filing demonstrated that the attorney-client relationship had deteriorated and that continued representation had become unreasonably difficult. The Court considered standards under New York Rule of Professional Conduct 1.16, which addresses when a lawyer may withdraw. The Court also noted Campisi’s representation that Kaplan Fox was not asserting a retaining or charging lien, and found Christiansen’s argument about the anticipated lien unfounded.
Ruling
Judge Valerie Caproni granted the motion to withdraw. The Clerk was directed to terminate the open motion at Docket 145 and to terminate the appearances of Kaplan, Campisi, and Fox. The Court stated that Ligansky never appeared in the case.
No later than 30 days after the Court appoints a new lead plaintiff, Christiansen must do one of three things: secure new counsel, file a Notice of Pro Se Appearance stating that he will represent himself, or withdraw as a named plaintiff. The Court directed the Clerk to mail Christiansen a copy of the Order.
Effect of the Decision
This order resolves the lawyers’ withdrawal request. The opinion does not decide the underlying securities claims or state whether Christiansen or the proposed class will prevail on those claims.
Read the full 7-page opinion on CourtListener, the free public archive maintained by the Free Law Project.