Notice of Joinder NO. Please note that when you try to challenge, or disqualify, a judge on the basis of prejudice, the challenge is often referred to as a "peremptory challenge." No. Exchange v. Fireman's Fund . Nature of Proceedings: Motion TENTATIVE RULING: Plaintiff Cleve Pell filed suit on October 16, 2017 against Defendants The Montebello Unified School District ..basis for the continuance. 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. A client deprived of the attorney of his choice suffers a particularly heavy penalty where, as appears to be the case here, his attorney is highly skilled in the relevant area of the law. Gregori v. Bank of America ((1989) 207 Cal.App.3d 300. A motion to disqualify tests whether the opposing partys right to counsel of his or her choice, which is an important right, must yield to ethical considerations that affect the fundamental principles of our judicial process. People ex rel. Nature of Proceedings: Motion to Disqualify; Motion to Amend This presumption, if applicable, is conclusive and is thus, by definition, not rebuttable. (2) NOTICE OF JOINDER; will be able to access it on trellis. In 2009, Epic settled its claims against Ali 5 Corporation. A complaining party who files a motion to disqualify is required to have standing. ORDER ON MOTION TO DISQUALIFY PLAINTIFFS' COUNSEL 294 signed by District Judge Lawrence J. O'Neill on October 13, 2010. 1 (California, United States of America) 9 The court concluded that the pending action against the USPS was not sufficiently similar to the matters plaintiffs counsel had previously handled on behalf of the USPS some eight years prior. 3d 545]. [D]isqualification motions involve a conflict between the clients right to counsel of their choice and the need to maintain ethical standards of professional responsibility [Citation.] 10 Kinchen highlights Californias general rejection of disqualification based on the playbook theory. Judge Colleen K. Sterne Accordingly, it is ORDERED that Plaintiff's Unopposed Motion to Disqualify Counsel, Christopher Jallo, from Trial (Dkt. First, there must be a substantial relationship between the former representation and the current representation. Plaintiff moves for a court order to substitute plaintiffs initial counsel of record in this litigation for replacement counsel that plaintiff has retained. App. 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. RULING: The motion is deni ..first amended complaint (FAC) on December 19, 2018. 393 Jeff C. Hsu / Patrick A. Gillespie of Murphy, Pearson, Bradley & Feeney for moving defendant H. F. Ahmanson & Co. v. Salomon Brothers, Inc. (1991) 229 Cal.App.3d 1445, 1454. What are the consequences of counsel failing to give counsel a reason for their failure to comply with a motion of motion? Your alert tracking was successfully added. This presumption, if applicable, is conclusive and is thus, by definition, not rebuttable. The motion to disqualify Defendants counsel is DENIED. Plaintiffs Evidentiary Objections 387 App. Dept. 1 19-12747 (11th Cir., June 29, 2022). An attorney may be recused [u]pon the order of the court, upon the application of either client or attorney, after notice from one to the other. Code Civ. and consolidated case, The court has discretion to allow an attorney to withdraw, and such a motion should be granted provided that there is no prejudice to the client and it does not disrupt the orderly process of justice. Bauer Declaration CLA Membership is $99 and includes one section. According to 24 the allegat ..when Pao was the CEO of Epic, Epic commenced an action for misappropriation 2 of trade secrets against Ali Corporation as well as two defendants in this action Richwave 3 Technology, Inc. (Richwave) and its CEO Shyh-Chyi Wong (Wong). 9 Not necessarily. A disqualification motion can be granted before discovery is complete in certain circumstances. A conflict arises when the circumstances of a particular case present a substantial risk that the lawyers representation of the client would be materially and adversely affected by the lawyers own interests or by the lawyers duties to another current client, a former client, or a third person. 23 This action arises from a dispute over the settlement of an earlier lawsuit. Adams v. Aerojet General Corp. (2001) 86 Cal.App.4th 1324, 1331; In re Marriage of Zimmerman (1993) 16 Cal.App.4th 556, 563564. 43. Nature of Proceedings: Motion to Disqualify; Motion to Amend First GIVEN THE CURRENT CORONAVIRUS CRISIS, THE COURT STRONGLY ENCOURAGES REMOTE APPEARENCES BY LACourtConnect. PLEASE MAKE SUCH ARRANGEMENTS IF YOU WISH TO APPEAR REMOTELY AT WWW.LACOURT.ORG/LACC/. [D]isqualification motions involve a conflict between the clients right to counsel of their choice and the need to maintain ethical standards of professional responsibility [Citation.] First Earl Scheib, Inc. v. Super. If competent evidence does not establish such a conflict, the attorney is not disqualified for a conflict. Sharp v. Next Entertainment, Inc. (2008) 163 Cal.App.4th 410, 425-426. (Dino v 9 COUNTY OF SANTA CLARA FMG Attorney Michael Hill obtained affirmance of a summary judgment award on behalf of the City of Roswell and, Partners Michael Freed and Brian Goldberg Secure Appellate Win Affirming Dismissal of Plaintiffs Wrongful Foreclosure Claim, Richard Durham v. Aerial Funding, LLC, Case No. by clicking the Inbox on the top right hand corner. Protection of the attorney-client privilege is not the only ground for a motion to disqualify an attorney. Kennedy v. Eldridge (2011) 201 Cal. Discussion In Kinchen v. Brennan, No. (2) NOTICE OF JOINDER; of Corp. v. SpeeDee Oil Change Systems, Inc. (1999) 20 Cal.4th 1135, 1145; Code Civ. (2) Cross-Defendant W.L. A party has the right to be represented by counsel of his or her choice. A client deprived of the attorney of his choice suffers a particularly heavy penalty where, as appears to be the case here, his attorney is highly skilled in the relevant area of the law. Gregori v. Bank of America ((1989) 207 Cal.App.3d 300. 3 58654/2018, Petitioner moved to disqualify opposing counsel, who was deposed in the case and certain to be called as a witness at trial.Petitioner argued that, pursuant to Rule 3.7 of the Rules of . Henriksen v. Great American Savings & Loan (1992) 11 Cal.App.4th 109, 113. The court evaluated the motion using California Rules of Professional Conduct 1.9 (regarding conflicts with former clients) and 1.11 (regarding former government attorneys, and referring to Rule 1.9(c)). and consolidated case, A complaining party who files a motion to disqualify is required to have standing. In a case of first impression, the Eleventh Circuit affirmed the district courts dismissal of an insureds claim for, FMG Attorney Philip Savrin Obtains Affirmance of Summary Judgment on Behalf of Insurance Company in Eleventh Circuit Court of Appeals, Siasim Columbia, LLC, v. Scottsdale Insurance Company, Case No. [W]hile federal courts generally limit standing to bring disqualification motions to clients or former clients, in California where the ethical breach is manifest and glaring and so infects the litigation in which disqualification is sought that it impacts the moving partys interest in a just and lawful determination of [his or] her claims, a nonclient might meet the standing requirements to bring a motion to disqualify based upon a third party conflict of interest or other ethical violation. Kennedy v. Eldridge (2011) 201 Cal.App.4th 1197, 1204 [135 Cal. Motions to disqualify counsel present competing policy considerations. al., United States District Court for the Northern District of Georgia, Civil Action Number 1:20-cv-02205-SCJ. The operative FAC alleges 27 causes of action arising from her purchase and ownership of an affordable residential condominium unit in the Alma del Pueblo development, which is a mixed-use (i.e., both commercial and residential) development. A conflict arises when the circumstances of a particular case present a substantial risk that the lawyers representation of the client would be materially and adversely affected by the lawyers own interests or by the lawyers duties to another current client, a former client, or a third person. Alternate trial counsel must make an appearance in this case on Defendant's behalf within thirty (30) days of this Order. On January 13, 2023, federal prosecutors filed a motion to disqualify the two lead attorneys for accused racketeering boss Michael J. Miske, Jr. . 2022). the attorneys interest in representing a client; the financial burden on a client of change of counsel; any tactical abuse underlying a disqualification motion; and. 1 - 7: SUSTAINED. Id. 5 Motion for: March 5, 2013 March 5, 2013 Discussion: An attorney may not ethically represent a client whose interests conflict with a former client absent the former client's informed written consent. What constitutes adversity? at 1145. James Scafide /Tyler Sprague of Scafide law Firm, PC for plaintiff Therefore, Sharon argued that his entire firm had a conflict of interest in prosecuting the case against Costco. (3) Defendant/Cross-Complainant Gopher Protocol, Inc. January 9, 2012 3d 545]. In July 2013, Attorney Spitzer filed a motion to dismiss or convert the Debtors' chapter 11 case. Rules of Court, rule 3.1362(a), (c), (e), ORDER DENYING PLAINTIFF'S MOTION TO RECUSE POWELL PARTNER'S COUNSEL, BROADWAY PROPERTIES LLC VS. WE PARK, INC. et al, ORDER RE: SELLER DEFENDANTS' MOTION TO RECUSE/DISQUALIFY COUNSEL, 2614 BUCHANAN STREET HOMEOWNERS ASSN., et al VS. GREGORY JOHNSON et al, ORDER RE: MOTION TO RECUSE DEFENDANTS COUNSEL MELINDA JAMES NILI, JAMES RYAN VS. OOC INC., A CALIFORNIA CORPORATION (D.B.A. Ct. (2004) 122 Cal.App.4th 17, 23. On December 28, 2011, the court appoin SUBJECT: Motion to Disqualify Counsel Nos. Whether an attorney should be disqualified is a matter addressed to the sound discretion of the trial court. "[W]hile federal courts generally limit standing to bring disqualification motions to clients or former clients, in California 'where the ethical breach is "'manifest and glaring'" and so "infects the litigation in which disqualification is sought that it impacts the moving party's interest in a just and lawful determination of [his or] her claims", a nonclient might meet the standing requirements to bring a motion to disqualify based upon a third party conflict of interest . ORDER GRANTING MOTION TO RECUSE DAVID REPLOGLE, ESQ. CCP section 2030.300 the C Plaintiffs Motion to Recuse Former Counsel Cable Gallagher. James Li and his firm 4 LiLaw, Inc. (together, Li) represented Epic. Motion to Recuse/Disqualify Counsel for Conflict: California Family Law Treatise Motion to Recuse/Disqualify Counsel in Family Law Case. (3) Defendant/Cross-Complainant Gopher Protocol, Inc. 10 Below are some important concepts that have emerged in the context of motions to disqualify. 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. 8 Defendant also argued that counsel violated California Rule of Professional Conduct 4.2 (the no contact rule) by contacting a managing agent of the USPS directly, further warranting disqualification. will be able to access it on trellis. TENTATIVE RULING: 17, 2020), the Central District of California decided a motion to disqualify brought by the defendant based on two grounds: (1) a purported conflict based on plaintiff's counsel's prior employment by the defendant; and (2) plaintiff's counsel's improper receipt of information, procured by communicating with defendant's managing agent in an alleged violation of the "no contact" rule. 4th 1197, 1204-1205. [I]f the nature of the representation is such that confidences could have been exchanged between the lawyer and client, and it would be if it satisfies both prongs of this test, courts will conclusively presume they were exchanged, and disqualification will be required. City Nat. 1 - 7: SUSTAINED. On the one hand, a court must not hesitate to disqualify an attorney when it is satisfactorily established that he or she wrongfully acquired an unfair advantage that undermines the integrity of the judicial process and will have a continuing effect on the proceedings before the court. On the other hand, it must be kept in mind that disqualification usually imposes a substantial hardship on the disqualified attorneys innocent client, who must bear the monetary and other costs of finding a replacement. Your alert tracking was successfully added. Ct. (2008) 158 Cal.App.4th 1697, 1711. 15 NINA YUAN, an individual, RICHWAVE by clicking the Inbox on the top right hand corner. Party: Defendants The Montebello Unified School District and The Montebello Unified School District Board of Education Other courts permit disqualification on a different basis, holding that standing is established so long as the lawyer owed a duty of confidentiality to the complaining party and breached it. She attaches email #8 (is she spiraling out? 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. CLA's member registration page has move to: https://calawyers.org/create-account/, If you have any questions, please contact us at info@calawyers.org. 4th 1197, 1204-1205. 10 7 at 1359. STATEMENT OF MATERIAL FACTS AND/OR PROCEEDINGS: In 2009, Epic settled its claims against Ali 5 Corporation. Instead, the substantial relationship test controls. Your credits were successfully purchased. Matters: (1) Motion of Defendants to Disqualify Gersh Derby as Counsel ..t attached as exhibit A to the motion is deemed served on the parties; plaintiffs shall file the first amended complaint, or arrange that the copy of the first amended complaint lodged with the court be filed, on or before January 13, 2012. 4 Ct. (2004) 122 Cal.App.4th 17, 23. 114546.) USA Motion to Disqualify Defense Counsel, CR. Motions to disqualify counsel present competing policy considerations. In appeal handled by Atlanta Partners Michael Freed and Brian Goldberg, the Eleventh Circuit affirmed the dismissal of a plaintiffs wrongful, FMG Appellate Team Obtains Victory for Nonprofit Corporation in California Court of Appeals, Jason A Bezis v. Livermore Heritage Guild, Case No. 2022 California Rules of Court Rule 3.816. (California, United States of America) If a defendant makes a motion for a continuance of trial on grounds of ineffective assistance of counsel at trial, is it appropriate to appoint a new counsel to prepare the motion? v. Before Trial (The Rutter Group 2016) 9:382. Your content views addon has successfully been added. The commercial units included the Santa Barbara Public Market. Nature of Proceedings: Motion to Disqualify; Motion to Amend The district court therefore granted the motion to disqualify. plaintiffs contend the trial court abused its discretion in denying their motion to disqualify defendants' counsel because (1) defendants' counsel improperly communicated with adverse. 300-301), Justice Kline's opinion explained that the 17 prophylactic nature of the disqualification remedy means the focus of the analysis must be on "whether there exists a genuine likelihood . In both instances, the courts concluded that a disqualifying conflict did not exist and denied disqualification. Your subscription was successfully upgraded. Ct. (1997) 60 Cal.App.4th 473, 577-582. Your content views addon has successfully been added. Great Lakes Construction, Inc. v. Burman (2010) 186 Cal.App.4th 1347, 1355. [A] highly speculative and tactical interest does not meet the standing requirements. Id. N.D. Cal. Where the substance and necessity of the attorney's testimony is unknown, a decision on disqualification should await discovery. Your content views addon has successfully been added. 1370707 Your alert tracking was successfully added. Rptr. EXTREME et al, ORDER DENYING DEFEDANT'S (JIN FAN HE) MOTION TO RECUSE PLAINTIFF'S COUNSEL, OPPOSITION TO DEFTS MOTION TO RECUSE PLTFS COUNSEL FILED BY PLAINTIFF STAC, KHALIL MSALAM, et al vs. 394 [I]f the nature of the representation is such that confidences could have been exchanged between the lawyer and client, and it would be if it satisfies both prongs of this test, courts will conclusively presume they were exchanged, and disqualification will be required. City Nat. Absent evidence of actual knowledge of material confidential information, both prongs of the test must be satisfied before a Court applies the conclusive presumption of knowledge of such information. FMG Attorney Philip Savrin obtained an appellate victory in an insurance coverage case that arose from property damage to a, FMG Attorney Michael Hill Secures Affirmance of Summary Judgment in Case Alleging Violations of a Public Employees First Amendment Rights, Silvia Cotriss v. City of Roswell, et al., Case No. Ct. (1997) 60 Cal.App.4th 473, 577-582. 279 James Li and his firm 4 LiLaw, Inc. (together, Li) represented Epic. Motions to disqualify counsel present competing policy considerations. [W]here an attorneys continued representation threatens an opposing litigant with cognizable injury or would undermine the integrity of the judicial process, the trial court may grant a motion for disqualification, regardless of whether a motion is brought by a present or former client of recused counsel. Kennedy v. Eldridge (2011) 201 Cal.App.4th 1197, 1205. Henriksen v. Great American Savings & Loan (1992) 11 Cal.App.4th 109, 113. Petrey Wholesale, Inc. Other courts permit disqualification on a different basis, holding that standing is established so long as the lawyer owed a duty of confidentiality to the complaining party and breached it. of Corp. v. SpeeDee Oil Change Systems, Inc. (1999) 20 Cal.4th 1135, 1145; Code Civ. IF YOU APPEAR IN PERSON AT T ..NG PARTY(S): Defendants James Hyojin Ahn and Robert Ahn 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 ..t yield to ethical considerations that affect the fundamental principles of our judicial process. (SpeeDee, supra, 20 Cal.4th at pp. Your subscription has successfully been upgraded. Mar. We will email you The current representation must be substantially related to the former representation to constitute a disqualifying conflict. 16 and SHYH-CHYI WONG, an individual, and Bauer Declaration ARIA SARBELAND, et al, REPLY TO PLTFS OPPOSITION TO MOTION TO RECUSE CATHERINE BOSKOFF AS COUNSEL. There are consolidated actions asserting claims of securities violations with respect to corporate stock. 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 [W]hile federal courts generally limit standing to bring disqualification motions to clients or former clients, in California where the ethical breach is manifest and glaring and so infects the litigation in which disqualification is sought that it impacts the moving partys interest in a just and lawful determination of [his or] her claims, a nonclient might meet the standing requirements to bring a motion to disqualify based upon a third party conflict of interest or other ethical violation. Kennedy v. Eldridge (2011) 201 Cal.App.4th 1197, 1204 [135 Cal. First, there must be a substantial relationship between the former representation and the current representation. If competent evidence does not establish such a conflict, the attorney is not disqualified for a conflict. Sharp v. Next Entertainment, Inc. (2008) 163 Cal.App.4th 410, 425-426. Department 5 While sanctions for an unsuccessful motion to disqualify are rare, clients (and their counsel) are best protected against the possibility of sanctions for bringing a frivolous motion to disqualify by thoughtfully and carefully researching and analyzing possible conflicts before moving to disqualify. First, there must be a substantial relationship between the former representation and the current representation. While bringing a losing motion to disqualify rarely has negative repercussions for the unsuccessful moving party (beyond the expenditure of fees), that is not always the case. On the one hand, a court must not hesitate to disqualify an attorney when it is satisfactorily established that he or she wrongfully acquired an unfair advantage that undermines the integrity of the judicial process and will have a continuing effect on the proceedings before the court. On the other hand, it must be kept in mind that disqualification usually imposes a substantial hardship on the disqualified attorneys innocent client, who must bear the monetary and other costs of finding a replacement. MOTION to Disqualify Counsel BRIDGES & MAVRAKAKIS LLP filed by Samsung Electronics America, Inc., Samsung Electronics Co. Ltd., Samsung Telecommunications America, LLC. Gilbert v. Natl Corp. for Housing Partnerships (1999) 71 Cal.App.4th 1240, 1258, citing Smith, Smith & Kring v. Super. 8 TECHNOLOGY, INC., a Taiwan corporation, The plaintiff was represented by counsel who had previously worked as an Assistant United States Attorney (AUSA). Adams v. Aerojet General Corp. (2001) 86 Cal.App.4th 1324, 1331; In re Marriage of Zimmerman (1993) 16 Cal.App.4th 556, 563564. 16 and SHYH-CHYI WONG, an individual, and Your subscription has successfully been upgraded. California, 494 U.S. 1039 (1990) . You will lose the information in your envelope, Cal. CV1810311PADFMX, 2020 WL 2374947 (C.D. Moving Party: Plaintiff Cleve Pell when new changes related to " are available. at 1358. . 21-12918 (11th Cir., June 29, 2022). The only remaining Plaintiff is Green Mutual Property & Investment Co. You can always see your envelopes when new changes related to " are available. Last. H. F. Ahmanson & Co. v. Salomon Brothers, Inc. (1991) 229 Cal.App.3d 1445, 1454. (Lira, I) Download PDF. 391 Great Lakes Construction, Inc. v. Burman (2010) 186 Cal.App.4th 1347, 1355. Discussion: 12 YI-CHING PAO, an individual, 13 Plaintiff, TENTATIVE RULING RE: MOTION TO DISQUALIFY 14 vs. Lawyers, and sometimes courts, struggle with complicated questions about conflicts of interest. You can always see your envelopes DONE and ORDERED in Tampa, Florida on April 11, 2016. The paramount concern must be to preserve public trust in the scrupulous administration of justice and integrity of the bar. Id. 1 - 7: SUSTAINED. Case: Jeffrey E. Mitchell v. Stratus Media Group, Inc., et al., Resp. 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. 9 3 Proc. Motion to Withdraw as Counsel in California What Is a Motion to Withdraw as Counsel? 1000 Your recipients will receive an email with this envelope shortly and The attorney in an action or special proceeding may be changed at any time before or after judgment or final determination, as follows: 1. vs. MASTAR PROFESSIONAL CORP, et al, Professional Negligence Attorney Malpractice, Julie Pavlina San Giorgio v. Pavlina, Jr., et al. The paramount concern must be to preserve public trust in the scrupulous administration of justice and integrity of the bar. Id. A court in its discretion will determine the appropriate sanction necessary to preserve the scrupulous administration of justice and the integrity of the bar.. No. Proc., 128(a)(5). Ct., 177 Cal.App.3d 1021, 1028 (1986). A motion to disqualify tests whether the opposing partys right to counsel of his or her choice, which is an important right, must yield to ethical considerations that affect the fundamental principles of our judicial process. People ex rel. Enter the email associated with you account. [A] highly speculative and tactical interest does not meet the standing requirements. Id. Ct. App. 2 Petrey Wholesale, Inc.s notice of joinder in the motion to disqualify is GRANTED as timely. A motion to disqualify tests whether the opposing partys right to counsel of his or her choice, which is an important right, must yield to ethical considerations that affect the fundamental principles of our judicial process. People ex rel. 385 Plaintiff moves to recuse counsel for Defendants James Hyojin Ahn and Robert Ahn. Case: Jeffrey E. Mitchell v. Stratus Media Group, Inc., et al., The motion to disqualify Defendants counsel is DENIED. Bank v. Adams (2002) 96 Cal.App.4th 315, 327. Immediate review of the grant of a motion to disqualify is allowed because of a client's right to representation by counsel of the client's choice, Travco Hotels, Inc. v. Piedmont Natural Gas Co., Inc., 332 N.C. 288, 293, 420 S.E.2d 426, 429 (1992), whereas immediate review of an order granting a motion to compel production of information . based on prior representation of opposing party Copyright: Attribution Non-Commercial (BY-NC) Available Formats Download as PDF, TXT or read online from Scribd Flag for inappropriate content of 12 Motion Hearing set for 8/18/2011 01:30 PM in Courtroom 4, 5th Floor, San Jose before Hon. Dep't of Corps. We will email you Defendant, Eugene Sun Disqualification for conflict of interest (a) Arbitrator's duty to disqualify himself or herself The arbitrator must determine whether any cause exists for disqualification upon any of the grounds set forth in Code of Civil Procedure section 170.1 governing the disqualification of judges. (Lead Case; Consolidated Action), Jeffrey Mitchell vs Stratus Media Group Inc et al, CLEVE PELL VS THE MONTEBELLO UNIFIED SCHOOL DISTRICT ET AL. Court-Ordered Dismissal - Other (Other) 07/13/2020, Other Civil Petition (General Jurisdiction), 1 B. . CV1810311PADFMX, 2020 WL 2374947 (C.D. Dept. 19-00099-DKW-KJM, District of Hawaii - Free download as PDF File (.pdf), Text File (.txt) or read online for free. TENTATIVE RULING: Gilbert v. Natl Corp. for Housing Partnerships (1999) 71 Cal.App.4th 1240, 1258, citing Smith, Smith & Kring v. Super. of Corp. v. SpeeDee Oil Change Systems, Inc. (SpeeDee) (1999) 20 Cal.4th 1135, 114546. Hahn Declaration When will the inappropriate receipt of confidential information (received from, for example, an inadvertent communication or by virtue of improper contact with a represented party) warrant disqualification of counsel? Therefore, the clients right to recuse (substitute out) existing counsel is absolute. 1 Case No. 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 ..t yield to ethical considerations that affect the fundamental principles of our judicial process. (SpeeDee, supra, 20 Cal.4th at pp.
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