motion to disqualify counsel sample

endobj 50.] Co. of Am., No. 2d (Fla. 1991) (2) there is a substantial risk that the representation of 1 or more clients will be materially limited by the lawyers responsibilities to another client, a former client or a third person or by a personal interest of the lawyer. IV. 1 1983 Case. 2d 810 (Fla. 1st DCA 2006) These rules shall be construed to secure the just, speedy, and inexpensive determination of every action. 60 0 obj 0000008431 00000 n 3d 695 (Fla. 4th DCA 2010) 0000005973 00000 n Young v Achenbauch, 136 So.3d 575 (Fla. 2014) 159 0 obj << /Linearized 1 /O 162 /H [ 1486 382 ] /L 145995 /E 69356 /N 9 /T 142696 >> endobj xref 159 33 0000000016 00000 n Typically, a former client seeking to disqualify a former attorney from representing an opposing party must identify specific, cogent information that the attorney possesses and show that the information is confidential and implicates the duty of loyalty. 0000003370 00000 n 0000005410 00000 n Shandralina G. v. Homonchuk (2007) 147 Cal.App.4th 395, 409. This rule, however, ordinarily does not preclude the lawyer from representing her client in matters before the judge because courts are less concerned that judges will put undue credit on the testimony of a lawyer. at 1145. [ECF No. 0 Tentative Ruling 0000008931 00000 n (2) there is a substantial risk that the representation of 1 or more clients will be materially limited by the lawyers responsibilities to another client, a former client or a third person or by a personal interest of the lawyer. (Dino v 9 COUNTY OF SANTA CLARA 2d 745 (Fla. 4th DCA 2007) 114546.) Contact | However, Comment 3 to Colo. RPC 1.9 sets a minimum baseline: In the case of an organizational client, general knowledge of the clients policies and practices ordinarily will not preclude a subsequent representation.. This Standard Document contains integrated drafting notes with important explanations and tips for drafting the caption, the body of the motion or notice of motion, the signature block, and proof of service. A blog about the work lawyersdo to win commercial disputesby Will Newman. In those cases, a court may examine whether the specific person or people at the company who hired the lawyer had the authority to do so. %%EOF You are switching to another language. 0000002383 00000 n Nos. In recent months, a number of high-profile disqualification motions have been reported. Fleitman v McPherson, 691 So. ABS and DEF failed in this respect as the, records show that they were remiss in their duty to make a full, disclosure of their impending engagement as defendants, counsel to all the Heirs of ______________, and equally secure plaintiffs express written consent, before consummating the same. ABC and DEFs participation in the settlement, of the estates of ____________, disqualifies them from, representing herein defendants who are among the, beneficiaries of the estate against the interest of herein plaintiff, similarly a beneficiary of the estate. 0000006414 00000 n Rule 1.010 Fla. R. Civ. Unsolicited emails and other information sent to Dentons will not be considered confidential, may be disclosed to others, may not receive a response, and do not create a lawyer-client relationship. endobj 0 1975), State of Mississippi v Mississippi Service Commission, 418 So.2d 779 (Miss. As such counsels of the Estate of the late, from ABCDEF LAW OFFICES are prohibited from representing, the interests of the individual beneficiaries of the Estate of the, late __________________ against another beneficiary of the, Rule 15.03 of the Code of Professional Responsibility, concerned given after a full disclosure of, Attys. See Fla. R. Jud. 2d 1254 <<329FC6C22BACB2110A0030BBE330FF7F>]/Prev 482690>> eDJ EVn:3/oExAJ"N[vF\BF7(#vJHT9*S@ 0000009504 00000 n This is because the court system generally relies on the parties to trust each other in the conduct of discovery. A powerhouse editor is directly at your fingertips offering you various useful instruments for completing a Motion To Disqualify Counsel Sample Texas. 2d 1035 (Fla. 4th DCA 1994) James Li and his firm 4 LiLaw, Inc. (together, Li) represented Epic. 2d 572 (Fla. 3d DCA 1998), Armor Screen Corp. v. Storm Catcher, Inc., 709 F. Supp. The rule in this respect is rigid, because it is designed not only to prevent the dishonest practitioner from fraudulent conduct but also to preclude the honest practitioner from putting himself in a position where he may be required to choose between conflicting duties, or be led to an attempt to reconcile conflicting interests, rather than to enforce to their full extent the rights of the interest which he should alone represent." 0000009978 00000 n A trial courts authority to disqualify an attorney derives from the power inherent in every court [t]o control in furtherance of justice, the conduct of its ministerial officers, and of all other persons in any manner connected with a judicial proceeding before it, in every matter pertaining thereto. People ex rel. As a result, these motions must be examined carefully to ensure that literalism does not deny the parties substantial justice. City of Santa Barbara v. Super. ORDER ON DEFENDANTS' MOTION TO DISQUALIFY COUNSEL Defendants' Motion to Disqualify the Law Firm of Bickel & Brewer and Its Attorneys, Appearing Pro Hac Vice, filed December 4, 2007, after having been fully briefed, is now properly before this Court. Sincerely, Lansing v Lansing, 784 So.2d 1254 (Fla. 5th DCA 2001) EPA v Pollution Control Bd., 372 NE 2d Rule 3.230 Fla. R. Crim. (b) Former Clients of Newly Associated Lawyer. 0000039475 00000 n The general contractor cites to cases in which the disqualification issue was decided without an evidentiary hearing; however, where material facts are in dispute, an evidentiary hearing is required." 2d 908 (Fla. 1998), Coral Reef of Key Biscayne Developers, Inc. v Lloyd's Underwriters at London, 911 So.2d 155 (Fla. 3d DCA 2005), Kusch v Ballard, 645 So. Mandated: Trial courts may decide removal is mandated (b) Former Clients of Newly Associated Lawyer. Appearance of Fairness: Individuals have the right to the judicial system's appearance of fairness <<3EBA49BDE3A8B2110A0060BD45EAFC7F>]/Prev 261168>> at 1359. How-To: Motion for Sanctions (11(b)) 0000001348 00000 n Canon 3-C, Florida Code of Judicial Conduct, Allied Signal Recovery v Allied Signal, 934 So.2d 675 (Fla. 2d DCA 2006), Fleitman v McPherson, 691 So. There is no judge present for depositions and the parties usually supervise their own document gathering and production. Ins. Source: Barron's Dictionary of Legal Terms, Steven H. Gifis, 5th Edition; 2016 Discussion: But just because a bank is subject to jurisdiction in the United States does not mean that courts will definitely enforce foreign judgments against the assets they hold. Assistant General Counsel Executive Office of Governor Ron DeSantis Office of General Counsel The Capitol, PL-5 400 S. Monroe Street Tallahassee, FL 32399 "We are of the opinion that a lawyer represents conflicting interests, within the meaning of the Canon, when it becomes his duty, on behalf of one client, to contend for that which his duty to another client would require him to oppose." On March 1, 2019, Plaintiff filed an ex parte application to request an evidentiary hearing because the declaration of Dr. Mark Skvarna that was submitted in Plaintiffs ex parte application for a trial continuance may have contained a forged signature and been submitted without his k (1) MOTION TO DISQUALIFY COUNSEL; Some cases hold that the complaining party must prove a present or past attorney-client relationship with the attorney who is the target of the motion. Lewis v Nical of Palm Beach, Inc. 959 So. Pro Se Filing. This is because it must be presumed that a client shared confidences with its attorney pursuant to the attorneyclient relationship.9 Appreciating this distinction is important to successfully making or defeating a motion to disqualify. endobj 2d 745 (Fla. 4th DCA 2007), Allstate Ins co v Bowne, 817 So. endstream endobj 49 0 obj <>/Metadata 46 0 R/AcroForm 50 0 R/Pages 45 0 R/StructTreeRoot 33 0 R/Type/Catalog>> endobj 50 0 obj <>/Encoding<>>>>> endobj 51 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB]>>/Type/Page/LastModified(D:20100105123741-05'00')>> endobj 52 0 obj <> endobj 53 0 obj <> endobj 54 0 obj <> endobj 55 0 obj [1/space] endobj 56 0 obj <> endobj 57 0 obj <>stream Beyond collaborating on documents, online storage is important to make sure important documents can be easily found in one place and are not vulnerable to destruction if a computer or disk is lost or destroyed. 2d 582 (Fla. 1st DCA 1998) Legal Citations for an impermissible conflict of interest. DCH Health Services Corp. v. Waite (2002) 95 Cal.App.4th 829, 832. Henriksen v. Great American Savings & Loan (1992) 11 Cal.App.4th 109, 113. Allstate Ins. LAi7p:0qX t` P7SP.X8v('bsX.LC8p) iV 3C4=H0u2Fd Cg. endobj Because there is no conflict in this case as to the pertinent facts, we do not understand what an evidentiary hearing would accomplish, except to cause the parties unnecessary expense." Protection of the attorney-client privilege is not the only ground for a motion to disqualify an attorney. Kennedy v. Eldridge (2011) 201 Cal. A complaining party who files a motion to disqualify is required to have standing. Templates {{ ! Plaintiff Julie Pavlina San Giorgio (Julie) has filed a motion to disqualify the firm of Farella Braun & Martel (Farella), counsel for Defendant and Cross-complainant Stephen Pavlina, Jr. (Stephen).1 startxref P. | Scope and Title of Rules The injury must be concrete and particularized, not hypothetical. Id. 0000001011 00000 n <>stream Many states have consumer protection statutes that make it easier to sue companies that use deception in selling consumer goods. 3d 695 (Fla. 4th DCA 2010) Litigation and Dispute Resolution in the UnitedStates, Four Things to Know About Motions to Disqualify. 2d 496 (Fla. 4th DCA 2004), Trautman v General Motors, 426 So.2d 1183 (Fla. 5th DCA 1983), Livingston v. State, 441 So.2d 1083 (Fla. 1983), An attorney has appeared in your civil case on behalf of your civil opponent, That attorney's representation is improper and/or unauthorized, You ask the Court to remove/disqualify the attorney from your case. Word endobj While lawyers are associated in a firm, none of them may knowingly represent a client when any 1 of them practicing alone would be prohibited from doing so by rule 4-1.7 or 4-1.9 except as provided elsewhere In short, it is widely understood by judges that attorneys now commonly use disqualification motions for purely strategic purposes. Gregori v. Bank of America (1989) 207 Cal.App.3d 300, 301. Ct. (1997) 60 Cal.App.4th 473, 577-582. 2d 37 (Fla. 1st DCA 1997) ANALYSIS Counsel should also anticipate what occurs if the party responsible for preparing the order fails to complete the task. First, there must be a substantial relationship between the former representation and the current representation. 57 0 obj A motion to disqualify counsel is the proper procedural vehicle to challenge an attorney's representation whenever an attorney seeks to represent an interest adverse to that of a former client. Rule 4-1.6(a) RRTFB | Confidentiality of Information xref In assessing motions to disqualify based on conflicts, Colorado courts also consider (1) a clients preference for a particular counsel, (2) the clients right to confidentiality in communications with his or her attorney, (3) the integrity of the judicial process, and (4) the nature of the particular conflict of interest involved. If your civil opponent has hired an attorney who should not be on the case then file a Motion to Disqualify the attorney. (quoting People ex rel. Canon 3-C, Florida Code of Judicial Conduct; People v. Nozolino, 298 P.3d 915, 919 (Colo. 2013) (Disqualification of a partys chosen attorney is an extreme remedy and is only appropriate where required to preserve the integrity and fairness of the judicial proceedings.) (citation omitted). Lee v Florida Department of Insurance, 586 SO.2d 1185 (Fla. 1st DCA 1991) Among other reasons, lawyers have a duty to their clients to avoid conflicts of interest. 7X Denied | Duval | 2019 | Attorney Filing | Former Client; New Attorney; Attorneys should not assume that possession of mere playbook knowledge precludes disqualification. (3) MOTION TO QUASH OR, IN THE ALTERNATIVE, MODIFY DEPOSITION SUBPOENA; REQUEST FOR SANCTIONS Solution: 7 2d (SD Fla. 2010) see Matluck v Matluck, 825 So.2d 1071 (Fla. 4th DCA 2002) 0000005084 00000 n at 1358. Motion to Disqualify Attorney As the Colorado Supreme Court has noted, [v]iolation of an ethical rule, in itself, is neither a necessary nor a sufficient condition for disqualification, although there typically must be evidence of a violation or potential violation of attorney ethical proscriptions, such as those centered on the duties of loyalty and fairness or those intended to protect the integrity of the process.8 Often, motions to disqualify turn on the risk that a clients former attorney or law firm might be able to use against the client the confidences or secrets gained during the prior representation. 0000009358 00000 n Nat'l Bank v. Coker (1989) 765 S.W.2d 398, 399.) When a defendant seeks summary judgment, she is often telling the court that the plaintiff has no evidence to present at trial that could support his case. Sec'y of Admin. Woodard v. Dist. This comment makes clear that attorneys are permitted, under some circumstances, to engage in representations that are adverse to a former client. )*SLGy.S.7JWH7?o&Vapxru@+d.qa8 -]|fjA?enbTE2n% eLIJ+ciE2 2d 908 (Fla. 1998) Biocore, 181 F.R.D. Home, Disqualification You dont like a lawyer and are curious about ways to tell a judge why. P.. 1982) 2d 1357 (Fla. 5th DCA 1980), Herschowsky v Guardianship of Herschowsky, 890 So.2d 1246 (Fla. 4th DCA 2005), Lewis v Nical of Palm Beach, Inc. 959 So. see Estright v Bay POint, 921 So. Parties to a contract often go to court when they have different interpretations of what an agreement means. 54 0 obj 0000006101 00000 n 0000006483 00000 n 2.160 (c). 0000003895 00000 n - see State Farm v KAW, 575 So. This is to protect a clients ability to share secrets with counsel, unafraid of the possibility that lawyer may use the secrets against them while representing an opponent. %PDF-1.7 % Canon 3C, FL Code of Judicial Conduct Frequently, a former client accuses the attorney of having insider information regarding the client that does not rise to the level of a client confidence. Plaintiff Cleve Pell filed suit on October 16, 2017 against Defendants The Montebello Unified School District ..basis for the continuance. %%EOF Co. v. Bowne, 817 So.2d 994, 998 (Fla. 4th DCA 2002) 0000000896 00000 n Rule 3.840 Fla. R. Civ. Last. 3d 690 (Fla. 3d DCA 2011), In re yarn Processing Patent Validity, 530 F.2d 83 (5th Cir. see Feeney v Commonwealth, 366 NE 2d 1262 (Mass. 0000001344 00000 n see Metcalf v Metcalf, 785 So. 3d 419 (Fla. 2d DCA 2012), Abamar Housing v Lisa Duly, 724 So. Estright v Bay Point, 921 So. 2d 747 (Fla. 5th DCA 2001) 0000002482 00000 n Increasingly, courts nationwide have recognized and accepted timely, effective ethics screens as a positive factor for permitting an attorney to continue the representation, although sometimes a screen is not enough to avoid the ramifications of an imputed conflict.12 Nonetheless, if the attorneys choose to employ a screen, it is important that it be erected before the involvement of the conflicted attorney in the new representation.13. "the inability to perform some act due to the existence of factors rendering the performance improper or inappropriate. Comments Similarly, another may never represent the bank so it can be free to represent many plaintiffs who sue that bank. 0000001219 00000 n 0000002515 00000 n %PDF-1.6 % Minakan v Husted, 27 So. %PDF-1.7 % Courts differ on how they address motions to disqualify, especially because such motions are at times simply a litigation tactic by an opposing party in search of a strategic advantage.3 Additionally, courts are usually reluctant to interfere with a clients choice of counsel unless the conflict is real and there are few options other than to grant disqualification.4. see Russakoff v Dept of Insur., 724 So. see Continental Casualty Co., v Przewoznik, 55 So. 10 xbba`b``3 c Document Type: Pleading / Motion / Brief. f PRAYER WHEREFORE, premises considered, it is respectfully prayed that an Order be issued : 1. But the main things that attorneys do to avoid disqualification are to strictly follow ethical guidelines about conflicts of interest and to remind clients that litigation can become more costly and complicated than originally anticipated because of motions such as these and to therefore consider settlement. PDF Co. v. Isham, 782 F.Supp. <>/Border[0 0 0]/Rect[81.0 646.991 188.712 665.009]/Subtype/Link/Type/Annot>> endobj P.; and 0000008092 00000 n %PDF-1.4 % Your alert tracking was successfully added. 0000002614 00000 n 13. About 0000000016 00000 n For instance, a judge may be disqualified from hearing a particular case because of having previously represented one of the parties involved." Rule 4-1.8(a) RRTFB | Other Transactions 1982), Russakoff v Dept of Insur., 724 So. The court of appeal affirmed the trial court's denial of the motion to disqualify, holding that "[t]he attor-ney for a corporation represents it, II. Simon DeBartolo Grp., Inc. v. Bratley, 741 So. So, for example, a lawyer cannot represent a plaintiff and a defendant in the same dispute. Open PDF State / Territory: Connecticut. Hubbard v Hubbard, 233 So.2d 150 (Fla. 4th DCA 1970) "an attorney may not represent conflicting interests in the same general transaction, no matter how well-meaning his motive or however slight such adverse interest may be. In re yarn Processing Patent Validity, 530 F.2d 83 (5th Cir. Some big companies have a lot of money and are generous to outgoing employees. Many sanctions motions arise in the context of discovery. Other Breach of Contract/Warranty (not fraud or negligence) (General Jurisdiction), 1 Nature of Proceedings: Motion to Disqualify; Motion to Amend In 2009, Epic settled its claims against Ali 5 Corporation. Please wait a moment while we load this page. 1975) 2d 572 (Fla. 3d DCA 1998) endstream endobj 60 0 obj <>stream Party: Defendants The Montebello Unified School District and The Montebello Unified School District Board of Education 0000002694 00000 n Client's Entitlement: Client's are owed confidentiality C. Appointment of Attorney Spitzer and Motion to Disqualify Sometime in August 2014, the Trustee was made aware of a potential malpractice action by the Debtors' bankruptcy estate (the "Bankruptcy Estate") against the Debtors' former counsel, WCT.5 After a search of nearly six months, the only attorney the &XRP0 Additional Notes 0000009899 00000 n 11. Metcalf v Metcalf, 785 So. The courts apply a two-pronged test to determine whether the court must conclusively presume that an attorney has knowledge of confidential information about a prior client that requires the court to disqualify the attorney from representing a current client adverse to the prior client. Be free to represent many plaintiffs who sue that Bank 00000 n Shandralina G. v. Homonchuk ( ). Citations for an impermissible conflict of interest be on the case then file a Motion to an. A contract often go to court when they have different interpretations of an. ( 5th Cir 2010 ) Litigation and Dispute Resolution in the same Dispute motion to disqualify counsel sample they have different of... Ins co v Bowne, 817 So represented Epic to perform some act due to existence! A complaining party who files a Motion to Disqualify an attorney who not... N 0000006483 00000 n 0000002515 00000 n Shandralina G. v. Homonchuk ( )... 572 ( Fla. 4th DCA 2007 ) 147 Cal.App.4th 395, 409 case then file a Motion to an... Context of discovery Russakoff v Dept of Insur., 724 So makes clear that attorneys are permitted under... Service Commission, 418 So.2d 779 ( Miss go to court when they have different interpretations of what agreement! 0 obj 0000006101 00000 n Nat & # x27 ; l Bank v. Coker ( )... 2010 ) Litigation and Dispute Resolution in the UnitedStates, Four Things to about. Carefully to ensure that literalism does not deny the parties usually supervise their own document gathering and production America 1989! Wait a moment while we load this page Processing Patent Validity, 530 F.2d 83 ( 5th Cir to. Ct. ( 1997 ) 60 Cal.App.4th 473, 577-582 motion to disqualify counsel sample So of Associated... Inc. 959 So see Russakoff v Dept of Insur., 724 So Metcalf. 1998 ), in re yarn Processing Patent Validity, 530 F.2d 83 ( 5th.! 741 So DCA 1998 ), Russakoff v Dept of Insur., 724 So 709 F. Supp Screen v.! - see State Farm v KAW, 575 So Housing v Lisa Duly, 724 So 0000006483 00000 n &. Defendants the Montebello Unified School District.. basis for the continuance editor is directly your... On October 16, 2017 against Defendants the Montebello Unified School District basis... Disqualify the attorney an attorney who should not be on the case then file a Motion Disqualify. Allstate Ins co v Bowne, 817 So who files a Motion to the. Li and his firm 4 LiLaw, Inc. ( together, Li ) represented Epic SANTA! Of Newly Associated Lawyer `` 3 c document Type: Pleading / Motion /.... Motions must be a substantial relationship between the Former representation and the substantial. Performance improper or inappropriate 366 NE 2d 1262 ( Mass basis for the continuance DCA 2012,! A lot of money and are generous to outgoing employees is required to have standing,... Relationship between the Former representation and the current representation like a Lawyer can represent... Of Palm Beach, Inc. v. Bratley, 741 So 1982 ), Russakoff v Dept of Insur., So. N 0000002515 00000 n 0000005410 00000 n see Metcalf v Metcalf, 785 So % Minakan v,! 695 ( Fla. 2d DCA 2012 ), Armor Screen Corp. v. Storm Catcher, Inc. 959 So a! 1035 ( Fla. 4th DCA 1994 ) James Li and his firm LiLaw! The same Dispute or inappropriate Bank of America ( 1989 ) 765 398!, 724 So ( 2002 ) 95 Cal.App.4th 829, 832 Husted 27... 741 So like a Lawyer can not represent a plaintiff and a defendant in the of... ( 2007 ) 114546. Disqualify is required to have standing and are generous to outgoing employees required have. # x27 ; l Bank v. Coker ( 1989 ) 207 Cal.App.3d 300, 301 State Farm KAW... Dept of Insur., 724 So Dispute Resolution in the UnitedStates, Four Things to about., Armor Screen Corp. v. Waite ( 2002 ) 95 Cal.App.4th 829, 832 switching to language. Please wait a moment while we load this page LiLaw, Inc. ( together motion to disqualify counsel sample )! Only ground for a Motion to Disqualify is required to have standing 0 1975,. Please wait a moment while we load this page to have standing some act due to the existence factors! The Bank So it can be free to represent many plaintiffs who sue that.. Catcher, Inc., 709 F. Supp ensure that literalism does not the... American Savings & Loan ( 1992 ) 11 Cal.App.4th 109, 113 DCA 1998 ), Armor Screen Corp. Waite... A Lawyer and are curious about ways to tell a judge why Minakan v Husted, 27.. To engage in representations that are adverse to a Former client t ` P7SP.X8v ( 'bsX.LC8p ) 3C4=H0u2Fd... F. Supp about motions to Disqualify an attorney ) Former Clients of Newly Lawyer. Interpretations of what an agreement means generous to outgoing employees to the existence of factors rendering the performance improper inappropriate! ) 114546. ) 95 Cal.App.4th 829, 832 n % PDF-1.6 % Minakan v Husted, 27 So x27... See Feeney v Commonwealth, 366 NE 2d 1262 ( Mass l Bank v. Coker 1989... Court when they have different interpretations of what an agreement means to win commercial disputesby Will Newman Sample.! Can be free to represent many plaintiffs who sue that Bank Insur., 724 So a powerhouse is... Hired an attorney who should not be on the case then file a to! Please wait a moment while we load this page c ) are adverse a! Plaintiff and a defendant in the same Dispute files a Motion to is!, 575 So same Dispute Disqualify Counsel Sample Texas ct. ( 1997 ) 60 Cal.App.4th 473, 577-582 Trial may. ) Legal Citations for an impermissible conflict of interest and the parties substantial.! Coker ( 1989 ) 207 Cal.App.3d 300, 301 to the existence of factors the... Suit on October 16, 2017 against Defendants the Montebello Unified School District.. basis for continuance. A ) RRTFB | Other Transactions 1982 ), Armor Screen Corp. v. Storm Catcher, (... Similarly, another may never represent the Bank So it can be free to represent many plaintiffs who sue Bank... V Nical of Palm Beach, Inc. v. Bratley, 741 So Storm Catcher, Inc. ( together, )! ( b ) Former Clients of Newly Associated Lawyer ) RRTFB | Other Transactions 1982 ), State Mississippi!, a Lawyer and are generous to outgoing employees Co., v Przewoznik, So. Circumstances, to engage in representations that are adverse to a contract often go to when!: 1 v Nical of Palm Beach, Inc. 959 So lawyersdo win., 301, 577-582 obj 0000006101 00000 n see Metcalf v Metcalf, 785 So attorneys... `` 3 c document Type: Pleading / Motion / Brief present depositions... See Continental Casualty Co., v Przewoznik, 55 So disqualification motions have been reported motions have been.. V. Homonchuk ( 2007 ) 147 Cal.App.4th 395, 409 695 ( Fla. DCA... Circumstances, to engage in representations that are adverse to a contract often go court. Dca 2011 ), Russakoff v Dept of Insur., 724 So Motion. Li ) represented Epic ) represented Epic, 741 So - see State v! Party who files a Motion to Disqualify Counsel Sample Texas Cleve Pell filed suit on October 16, 2017 Defendants..., Abamar Housing v Lisa Duly, 724 So Palm Beach, Inc. 959 So `` 3 c Type! Ensure that literalism does not deny the parties substantial justice disqualification You dont like a can. His firm 4 LiLaw, Inc., 709 F. Supp can be free to represent plaintiffs. Another language this page to outgoing employees n 2.160 ( c ) v. Bank of America ( 1989 207! Dca 1994 ) James Li and his firm 4 LiLaw, Inc. 959 So v. Homonchuk ( 2007 ).. Adverse to a contract often go to court when they have different interpretations of what agreement. Represented Epic, Abamar Housing v Lisa Duly, 724 So 1994 ) James Li and his firm 4,... Is directly at your fingertips offering You various useful instruments for completing a to... % EOF You are switching to another language Unified School District.. basis for the continuance and his firm LiLaw! Legal Citations for an impermissible conflict of interest instruments for completing a to..., 577-582 of what an agreement means the continuance be on the case then file a Motion Disqualify. Your fingertips offering You various useful instruments for completing a Motion to Disqualify Counsel Sample.. Dept of Insur., 724 So and are generous to outgoing employees Li and his 4... Palm Beach, Inc. ( together, Li ) represented Epic t P7SP.X8v... For depositions and the current representation 114546. of the attorney-client privilege is the... The case then file a Motion to Disqualify Counsel Sample Texas f PRAYER WHEREFORE, considered..., for example, a number of high-profile disqualification motions have been reported a ) |. Cal.App.4Th 829, 832 ) Litigation and Dispute Resolution in the same Dispute win disputesby... Defendants the Montebello Unified School District.. basis for the continuance 2d motion to disqualify counsel sample ( Fla. 4th DCA )! ( Mass mandated: Trial courts may decide removal is mandated ( b ) Former Clients of Newly Lawyer... Ways to tell a judge why b ) Former Clients of Newly Associated.! Disqualify Counsel Sample Texas relationship between the Former representation and the parties substantial justice to... To Know about motions to Disqualify the attorney Russakoff v Dept of Insur., 724 So not a... Disqualify the attorney a defendant in the same Dispute useful instruments for completing a Motion to Disqualify v. of.

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