Shapell Socal Rental Properties (Shapell) works in the area of owning and managing commercial real estate. (CFI) owns a chain of retail stores that sells women's clothing. The fact that one party failed to pay rent and pushed the envelope due to COVID closures did not change the obligation of professionalism between legal teams. Chico's FAS, Inc., found on appeal that attorneys have both an ethical and statutory duty to notify opposing counsel of an intent to seek a default. In quite a scolding for defense counsel, the court in Shapell Socal Rental Properties, LLC v.