Weatherford International, LLC et al v. Ameen

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF TEXAS
HOUSTON DIVISION
WEATHERFORD
INTERNATIONAL, LLC, et al.,
Plaintiffs,
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v. 	CIVIL ACTION NO. 4:23-cv-2420
SAYAMIK NAJAF MOHAMMED
AMEEN,
Defendant.
MEMORANDUM AND ORDER
Pending before the Court is Defendant Sayamik Najaf Mohammed
Ameen’s (“Ameen”) Motion for Leave to File Motion to Withdraw Counsel (ECF
No. 229), Opposed Motion for Evidentiary Hearing (ECF No. 236), and Opposed
Motion for Leave to File Sur-Reply (ECF No. 239).1 	Based on a review of the
motions, arguments, and relevant law, the Court DENIES the Motion for
Leave to File Motion to Withdraw Counsel (ECF No. 229), DENIES the Motion
for Evidentiary Hearing (ECF No. 236), and DENIES AS MOOT the Motion
for Leave to File Sur-Reply (ECF No. 239).
1 On October 11, 2024, this case was referred to the Undersigned for all purposes
pursuant to 28 U.S.C. § 636(b)(1)(A) and (B) and Federal Rule of Civil Procedure (“Rule”) 72.
(ECF No. 59).
United States District Court
Southern District of Texas
ENTERED
December 23, 2025
Nathan Ochsner, Clerk
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I. 	Background
Plaintiffs Weatherford International, LLC and Weatherford U.S., LP’s
(collectively, 	“Weatherford”) 	filed 	suit 	against 	Ameen 	on 	June 	30, 	2023,
asserting claims of (1) breach of contract; (2) violation of the Federal Defend
Trade Secrets Act (“DTSA”), 18 U.S.C. § 1836 et seq.; (3) violation of the Texas
Uniform Trade Secrets Act (“TUTSA”), Texas Civil Practice & Remedies Code
Annotated § 134A.001, et seq.; and (4) breach of fiduciary duty. (ECF No. 1).
On February 27, 2025, the Court recommended Weatherford’s Motion for
Summary Judgment be granted as to its breach of contract claim and denied
as to its DTSA and TUTSA trade secret claims. 	(ECF No. 90). 	The Court
further recommended Ameen’s Rule 12 Motion be denied. 	(See id.). 	Ameen
filed 	a 	Motion 	for 	Reconsideration 	and 	Objections 	to 	the 	Court’s
recommendation. (ECF No. 91). On March 25, 2025, the District Judge denied
Ameen’s motion and adopted the Court’s recommendation. (ECF No. 96).
However, on March 17, 2025, Ameen filed a Counterclaim, Answer,
Declaratory Judgment, and Injunction (“Original Counterclaims”). 	(ECF No.
93). 	Weatherford filed Motions to Strike and to Dismiss Ameen’s Original
Counterclaims (ECF No. 101, 153). 	On August 1, 2025, Ameen filed his First
Amended 	Counterclaims 	(“Amended 	Counterclaims”). 	(ECF 	No. 	179).
Weatherford then filed a Motion to Strike Ameen’s Amended Counterclaims
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(ECF No. 185). 	After discovery misconduct on Ameen’s part, Weatherford
moved for, and the Court granted, sanctions against Ameen and his counsel.
(ECF Nos. 161, 180). 	Ameen filed motions to reconsider, strike, clarify, and
amend the Court’s Order imposing Sanctions (ECF Nos. 180, 192–193, 202–
203).
On October 7, 2025, the Court recommended Weatherford’s Motions to
Strike and to Dismiss the Original Counterclaims be denied as moot (ECF Nos.
101, 153), and Motion to Strike the Amended Counterclaims be granted (ECF
No. 185). (ECF No. 214). 	The Court then denied the remainder of Ameen’s
motions challenging the Court’s Order imposing sanctions (ECF Nos. 192–193,
202–203). (ECF No. 214).
Weatherford then moved for, inter alia, entry of the parties’ stipulated
protective order (ECF No. 199), and a protective order barring Ameen from
additional filings and for a pretrial conference to resolve pending issues (ECF
No. 208). Ameen moved for relief from the District Judge’s Order adopting the
Court’s recommendation (ECF No. 103), and for leave to file a sur-reply
regarding Weatherford’s Motion to Strike Ameen’s Amended Counterclaims
(ECF No. 209).
On October 16, 2025, the Court recommended that Ameen’s Motion for
Relief from Judgment and to Partially Vacate Order (ECF No. 103) be denied.
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(ECF No. 221). 	The Court also granted Weatherford’s motion for entry of the
parties’ stipulated protective order (ECF No. 199), granted Weatherford’s
motion to the extent it requested a protective order barring Ameen from future
filings and denied the motion to the extent it requested a pretrial conference
(ECF No. 208). 	(Id.). 	Finally, the Court denied as moot Ameen’s motion for
leave to file a sur-reply (ECF No. 209). 	(Id.). 	Ameen filed objections to the
Court’s October 7 and 16 rulings. (ECF No. 225).
On October 31, 2025, Ameen himself filed the instant motion for leave to
file a motion to withdraw his counsel, Debra Jennings, Goodwille Pierre, and
Jazmyne Betters. 	(ECF No. 229).2 On November 17, Ameen filed the instant
opposed motion for an evidentiary hearing to address his pending objections to
the Court’s prior recommendations and orders. 	(ECF No. 236). 	Weatherford
filed a response (ECF No. 238), and Ameen filed the instant motion to file a
sur-reply (ECF No. 239).
II. 	Discussion
A. 	Motion for Leave to File Motion to Withdraw Counsel
Because the Motion for Leave to File Motion to Withdraw Counsel (ECF
No. 229) was filed by Ameen himself and not counsel, the Court shall deny and
2 On November 6, 2025, the Court granted a Motion for Leave to Withdraw as Counsel
of Record (ECF No. 218) by The Pierre Firm, PLLC, J. Goodwille Pierre, and Jazmyne
Betters. (ECF No. 232).
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strike the motion. 	Plaintiff does not have a constitutional right to hybrid
representation. 	Because Plaintiff is currently represented by counsel in the
district court, he is not entitled to file a pro se motion on his own behalf. 	See
Wolf v. City of Port Arthur, No. 1:20-cv-465, 2023 WL 5321075, at *1–2 (E.D.
Tex. Aug. 17, 2023) (striking from the record all filings made by client in her
pro se capacity, as those motions were not properly before the court because it
could not entertain hybrid representation from a represented party).
The Motion for Leave to File Motion to Withdraw Counsel is thus denied
and stricken. (ECF No. 229)
B. 	Motion for Evidentiary Hearing
Ameen’s motion requests an evidentiary hearing to address his pending
objections (ECF No. 225) to the Court’s prior recommendations and orders.
(ECF No. 236). Ameen particularly takes issue with the Court’s order imposing
sanctions (ECF No. 180) and its order denying Ameen’s various challenges to
the sanctions order (ECF No. 214). (ECF No. 236 at 1).3
The Court finds that the motion violates the Court’s protective order
entered on October 16, 2025. 	(ECF No. 221). 	Under the protective order, the
Court ordered that “(1) Ameen is restricted from filing further motions without
3 Ameen’s motion for a hearing noticeably seeks to address the Court’s sanctions
“[b]ecause the imposition of over $40,000 in sanctions and a finding of unethical conduct
turned on disputed issues of fact[.]” (ECF No. 236 at 4). Ameen wishes to resolve these issues
“before ruling on [his] objections (Doc. 225).” (Id.).
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leave of Court and (2) any motion that repeats prior arguments will be
stricken.” (Id. at 16–18). Ameen’s motion, however, violates the order because
it was filed without seeking leave of Court and it repeats prior arguments
challenging the Court’s sanctions. (See ECF Nos. 167, 192–193, 202–203). The
Court 	has 	already 	addressed 	and 	rejected 	Ameen’s 	arguments 	in 	its
Memorandum, Recommendation, and Orders from October 7 and 16. (See ECF
No. 214 at 14–19; ECF No. 221 at 11–18). Additionally, the Court already held
an evidentiary hearing on July 25, 2025 regarding Weatherford’s motion for
sanctions. 	(ECF No. 171). 	As such, the Motion for Evidentiary Hearing is
denied and stricken. (ECF No. 236)
C. Motion for Leave to File Sur-Reply
Ameen moves for leave to file a sur-reply in opposition to Weatherford’s
response (ECF No. 238) to Ameen’s motion for an evidentiary hearing (ECF
No. 	236) 	“because 	Weatherford’s 	Response 	raises 	new 	arguments 	and
misrepresentations that were not addressed in Ameen’s original Motion (Dkt.
No. 236).” (ECF No. 239 at 1–2).
“Neither the Federal Rules nor the Local Rules provide for the right to
file a surreply.” 	BHL Boresight, Inc. v. Geo-Steering Sols., Inc., 2017 WL
3634215 at *2 (S.D. Tex. Aug. 24, 2017). 	Indeed, “[s]urreplies, and any other
filing that serves the purpose or has the effect of a surreply, are highly
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disfavored, as they usually are a strategic effort by the nonmovant to have the
last word on a matter.” 	Weaver v. Celebration Station Props., Inc., 2015 WL
1932030 at *3 (S.D. Tex. Apr. 28, 2015) (quoting Lacher v. West, 147 F. Supp.
2d 538, 539 (N.D. Tex. 2001)).
Where a sur-reply is permitted, it “is limited to addressing only new
arguments raised for the first time by the opposing party in their reply briefing
and not included in the original motion.” 	Branch v. CEMEX, Inc., 2012 WL
2357280 at *9 (S.D. Tex. June 20, 2012) (quoting Marbury Law Grp., PLLC v.
Carl, 729 F. Supp. 2d 78, 83 (D.C. 2010)). 	“It is not an abuse of discretion for
a court to deny a party leave to file a surreply when that party seeks only to
respond to arguments—even new ones—relating to an issue the party already
addressed in its response.” Austin v. Kroger Tex. L.P., 2016 WL 1322248 at *2
(N.D. Tex. Apr. 5, 2016). 	Moreover, “[s]uch a request [for surreply] must also
be accompanied by a detailed recital of the necessity of the proposed surreply—
something 	more 	than 	a 	conclusory 	assertion 	that 	[parties] 	raise 	new
arguments in their Replies.” BHL Boresight, 2017 WL 3634215 at *3.
Sur-replies “are highly disfavored” by courts; indeed, they are “limited to
addressing only new arguments raised for the first time by the opposing party
in their reply briefing and not included in the original motion.” BHL Boresight,
2017 WL 3634215 at *3; Branch, 2012 WL 2357280 at *9.
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Ameen fails to meet the exacting standard advanced by sister courts.
Ameen’s Motion for Sur-reply merely recycles previous theories disputing the
basis for sanctions and objecting to the Court’s prior rulings. 	Ameen fails
plainly to provide a “detailed recital of the necessity of the proposed surreply.”
BHL Boresight, 2017 WL 3634215 at *3. 	Further, the Court has already
addressed 	and 	rejected 	Ameen’s 	arguments 	against 	sanctions 	in 	its
Memorandum, Recommendation, and Orders from October 7 and 16. 	Cuellar
v. Rodriquez, No. 23-cv-237, 2023 WL 6135685, at *1 (W.D. Tex. Sept. 19, 2023)
(denying defendant’s motion for leave to file sur-reply where court found
neither 	defendant’s 	motion 	nor 	the 	proposed 	sur-reply 	identified 	new
arguments purportedly made in the plaintiff's reply brief, and the proposed
sur-reply appeared “to be little more than a restatement of prior arguments
and submitting various case law in support”). 	Indeed, in the October 7
Memorandum, 	Recommendation, 	and 	Order, 	the 	Court 	already 	denied
Ameen’s multiple motions challenging the Court’s sanctions order. 	(See ECF
No. 214 at 14–20). 	Additionally, because the Court has already considered
Ameen’s request for an evidentiary hearing to address his objections, and the
Court denies the aforementioned Motion for Evidentiary Hearing through this
order, see supra Part II.B, a sur-reply is of no effect here. The Court therefore
denies Ameen’s request to file a sur-reply as moot. (ECF No. 239).
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III. 	Conclusion
Based on the foregoing, the Court DENIES the Motion for Leave to
File Motion to Withdraw Counsel (ECF No. 229), DENIES the Motion for
Evidentiary Hearing (ECF No. 236), and DENIES AS MOOT the Motion for
Leave to File Sur-Reply (ECF No. 239).
The Clerk shall send copies of this Memorandum and Recommendation
to the respective parties who have fourteen days from the receipt thereof to file
written objections thereto pursuant to Federal Rule of Civil Procedure 72(b)
and General Order 2002-13. Failure to file written objections within the time
period mentioned shall bar an aggrieved party from attacking the factual
findings and legal conclusions on appeal.
SIGNED in Houston, Texas on December 23, 2025.
______________________________
Richard W. Bennett
United States Magistrate Judge
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