motion to disqualify counsel sample
Second, take effective steps to mitigate, if not eliminate, risks that a former clients confidences and secrets might be accessible to attorneys working on a matter involving the former client. Except as provided in subdivision (b), a lawyer must not represent a client if: 0000001541 00000 n Attorney advertising, see disclaimer. 1977) People v. Harlan, 54 P.3d 871, 877 (Colo. 2002). PDF Possessing general knowledge about a client may not, by itself, be enough for disqualification. For instance, a judge may be disqualified from hearing a particular case because of having previously represented one of the parties involved." 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. 0000006382 00000 n In recent months, a number of high-profile disqualification motions have been reported.1 Many disqualification motions are well-founded. 1982), Minakan v Husted, 27 So. 0000001885 00000 n Bank v. Adams (2002) 96 Cal.App.4th 315, 327. xref MOTION TO DISQUALIFY OR RECUSE TRIAL COURT . 51 0 obj II. HlRn0+x*%+=TzEZ,_Q$E;203;eLp!n2Lazto'B9GHLHc$wjc As part of this process, they ask their colleagues if they are aware of any conflict that would prevent them from participating in a matter. Disqualification motions implicate the most important duties that an attorney owes a client: the duties of confidentiality and loyalty. (3) Defendant/Cross-Complainant Gopher Protocol, Inc. at 1359. Client's Entitlement: Client's are owed confidentiality You dont like a lawyer and are curious about ways to tell a judge why. Rule 4-1.10(a) RRTFB | Imputation of Conflicts of Interest; General Rule HlS]o@|WSCzs{7@rO-H9gR`gvf_O@>G($qGI@Ahmm8hm M6-p#HrD[RhQ4J"";PfD{S%.2tdS \y[7Lv 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. 2d 994 (Fla. 4th DCA 2002) 5. 0 [e.s.]). 2.160 (c). 0000004918 00000 n A motion to disqualify . 9@5t| .T:M76xl|02K/e,f!BGrC^ Rq?q| >1d8[.6 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. 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. Id. Your content views addon has successfully been added. 0000008766 00000 n Ins. span.opQt a {text-decoration-line:none;} 0000007067 00000 n %%EOF Lawyers litigating motions to disqualify or other ethical issues in federal court cannot rely solely upon any single set of ethical Lawyers should be careful to avoid couching a disqualification motion solely in terms of a Texas rule, even when filing a motion in Texas state Motions to Disqualify Among other reasons, lawyers have a duty to their clients to avoid conflicts of interest. endobj This is often referred to as playbook knowledgethe attorney knows the clients paths and approaches. 1982) The injury must be concrete and particularized, not hypothetical. Id. But at an initial stage, courts may decline to decide how to interpret an agreement. endstream endobj 241 0 obj <>/Size 231/Type/XRef>>stream Second, it must appear that by virtue of the nature of the former representation or the relationship of the attorney to his [or her] former client that confidential information material to the current dispute would normally have been imparted to the attorney. Id. Rarely Granted: Courts rarely grant Motions to Disqualify 0000010185 00000 n This comment makes clear that attorneys are permitted, under some circumstances, to engage in representations that are adverse to a former client. Shandralina G. v. Homonchuk (2007) 147 Cal.App.4th 395, 409. 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 0000004681 00000 n Litigation, however, is expensive and burdensome, and so many litigants ask the court to decide the issue of contract interpretation at the start of a lawsuit, before going through discovery. Moving Party: Plaintiff Cleve Pell Partially Granted | Duval | 2013 | Attorney Filing | Whistleblower Case; Trayvon Martin Fallout; Advocate and Witness; - No Ruling | Duval | 2014 | Attorney Filing | Settlement stuff; Marital Stuff; Former Client; Material Witness. Kusch v Ballard, 645 So. I. Definitions Conflict of Interest: Mandated: Trial courts may decide removal is mandated The strength of Kazakh courts for resolving commercial disputes lies in availability of various specialized courts. Courts are often reluctant to enforce non-competition agreements. Copyright 2021 by Will Newman, all rights reserved. 81 0 obj Accessing Verdicts requires a change to your plan. 2d 572 (Fla. 3d DCA 1998) For more information, please consult with an attorney. ET AL. 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 Where material facts are in dispute concerning a motion for disqualification, an evidentiary hearing is required." No. 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). Lawyers cannot represent any client that wants to retain them. 0000027807 00000 n Discussion: 0000001974 00000 n 0000013147 00000 n Co. v. Bowne, 817 So.2d 994, 998 (Fla. 4th DCA 2002) see Fleitman v McPherson, 691 So. # endstream endobj 232 0 obj <>/Metadata 35 0 R/PieceInfo<>>>/Pages 32 0 R/PageLayout/OneColumn/OCProperties<>/OCGs[233 0 R]>>/StructTreeRoot 37 0 R/Type/Catalog/LastModified(D:20090911173402)/PageLabels 30 0 R>> endobj 233 0 obj <. Perjury from a State Officer. The attorney may know the clients bottom line for settlement or how the client prefers to approach litigation. 0000001860 00000 n see Scott v Higginbotham, 834 So.2d 221 (Fla. 2nd DCA) Pantori v Stephenson, 384 So. ", "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. Rule 4-1.7(a) RRTFB | Conflict of Interest; Current Clients On February 10, 2012, Father filed a motion to disqualify counsel asking the court to disqualify Tyree Harris, Mother's attorney and husband, from representing Mother "in any matter related to the modification of the parties' permanent parenting plan." On March 19, 2012, the trial court entered an order on Father's motion to . Thus, there is no bright-line rule or test to determine whether an attorney should be disqualified because of her or his playbook knowledge. 0000002482 00000 n Attempting to defeat the motion without advising the client is not an acceptable solution. School Board of Broward County v. Polera Building Corp., 722 So.2d 971 (Fla. 4th DCA 1999) (quoting People ex rel. 3d 695 (Fla. 4th DCA 2010) So, for example, a lawyer cannot represent a plaintiff and a defendant in the same dispute. 1982), Russakoff v Dept of Insur., 724 So. 8}(D|Qb|-ZdyTpbp &^gwa]\}/! 9yyy' ` see Kusch v Ballard, 645 So. TENTATIVE RULING: BACKGROUND: A firm that represents a large bank once may prefer never to be prohibited from representing that large bank again, so it may never accept a case against the bank. Estright v Bay Point, 921 So. 7X Denied | Duval | 2019 | Attorney Filing | Former Client; New Attorney; 0000008092 00000 n 2d 496 (Fla. 4th DCA 2004) Feeney v Commonwealth, 366 NE 2d 1262 (Mass. A lawyer is prohibited from using information relating to representation of a client to the disadvantage of the client unless the client gives informed consent, except as permitted or required by these rules. 51 31 For instance, a judge may be disqualified from hearing a particular case because of having previously represented one of the parties involved." 0000009145 00000 n table.threeCol tr td:nth-child(3) {font-size:smaller;} Notice of Compliance with Victim's Rights. The purpose of disqualification is not to punish a transgression of professional ethics. 3d 545]. 52 0 obj 2d 37 (Fla. 1st DCA 1997) Forms for Attorneys and Government Entities. DOES 1 through 20, inclusive, . Armor Screen Corp. v. Storm Catcher, Inc., 709 F. Supp. Solution: The far more common motion to disqualify involves a former client, either of the law firm or of an individual attorney (who may have recently joined the firm). P. (1) the representation of 1 client will be directly adverse to another client; or 1977), Sec'y of Admin. 9 Bibliography see Sec'y of Admin. 0000000016 00000 n "Motions to disqualify counsel are especially prone to tactical abuse because disqualification imposes heavy burdens on both the clients and courts: clients are deprived of their chosen counsel, litigation costs inevitably increase and delays inevitably occur. This Comment will discuss criteria for distinguishing those situations in which a motion to disqualify opposing counsel for conflict of interest is 2d 1035 (Fla. 4th DCA 1994) Motion to Disqualify Counsel, 0000000016 00000 n Canon 3C, FL Code of Judicial Conduct Hb```f``=^ ,@Q`. 2d 908 (Fla. 1998) Co. v. Bowne, 817 So.2d 994, 998 (Fla. 4th DCA 2002), Estright v Bay POint, 921 So. <>/Border[0 0 0]/Rect[81.0 144.1365 255.384 153.1455]/Subtype/Link/Type/Annot>> Attorneys switch jobs like most professions more frequently than in the past. Judge Colleen K. Sterne 2d 1254 at 1358. 0000002756 00000 n <> Disqualification P0*oBMR>F,;R(R E@ QH4XD . According to the Colorado Supreme Court, however, a court may not disqualify counsel on the basis of speculation or conjecture.. While declining a representation often means declining money and while settlement often means compromising a deeply supported position, these choices could avoid substantial ethical problems and costly motion practice. v. Archer-Daniels-Midland Co., No. 0000000536 00000 n 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.10 Below are some important concepts that have emerged in the context of motions to disqualify.11, The Colorado Rules do not bar attorneys from representing current clients against former clients. Rule 4-1.6(a) RRTFB | Confidentiality of Information A sample motion or notice of motion to disqualify or withdraw as counsel in federal civil litigation. try clicking the minimize button instead. 0000003325 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. 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. 0 1992)). Plaza Resorts Inc. v. Janus American Group Inc., 811 So.2d 850 (Fla. 4th DCA 2002) 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. Motion to Disqualify an Attorney in Florida What Is a Motion to Disqualify an Attorney? Deputy General Counsel Joshua E. Pratt, Esq. BACKGROUND IV. [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. Discovery for Foreign Cases. Less frequently, a lawyer may claim to represent a business when it actually does not. 38.10 FS; State Farm v KAW, 575 So. MOVING PARTY: (1) Plaintiffs Robert Warren Jackson and Gregory Bauer; 38.10 FS see THI Holdings, LLC v Shattuck, 93 So. A powerhouse editor is directly at your fingertips offering you various useful instruments for completing a Motion To Disqualify Counsel Sample Texas. est, but because opposing counsel is dangerously competent. Additional Notes ", "We disagree with the dissent that an evidentiary hearing on every motion to disqualify counsel is required. +126:*l1%HQa7m'PfQn 2d 745 (Fla. 4th DCA 2007), Allstate Ins co v Bowne, 817 So. 0000001846 00000 n - see State Farm v KAW, 575 So. Congratulations! See paragraph (b)." Tex. matters are substantially similar How-To: Motion for Default Judgment 1982) "We next address the issue of the appropriate standard to apply to determine whether the Schlesinger firm should be disqualified. i[54ViL =nn8+ap(k. For instance, a judge may be disqualified from, Source: Barron's Dictionary of Legal Terms, Steven H. Gifis, 5th Edition; 2016, These rules apply to all actions of a civil nature and all special statutory, (1) the representation of 1 client will be directly adverse to another client; or. see Minakan v Husted, 27 So. See People v. Perez, 201 P.3d 1220, 1246 n.11 (Colo. 2009). 3. 2d 582 (Fla. 1st DCA 1998) Rule 4-1.9 RRTFB Hubbard v Hubbard, 233 So.2d 150 (Fla. 4th DCA 1970) 0000027980 00000 n 2d 1357 (Fla. 5th DCA 1980) 0000002627 00000 n 1876) Motion to Disqualify Counsel burdened by counsel who may have to offer testimony that is substantially adverse to the client's cause. Accordingly, parties frequently allege other people violate the rules. 2d 582 (Fla. 1st DCA 1998) In conflict-of-interest cases such as this arising under the former Code of Professional Responsibility, one seeking to disqualify opposing counsel was required to show that (1) an attorney-client relationship existed, thereby giving rise to an irrefutable presumption that confidences were disclosed during the relationship, and (2) the matter in which the law firm subsequently represented the interest adverse to the former client was the same or substantially related to the matter in which it represented the former client." It should be used in conjunction with Standard Documents, Motion to Disqualify or Withdraw as Counsel (Federal): Memorandum of Law and Motion to Disqualify or Withdraw as Counsel (Federal): Proposed Order, as well as Practice Note, Disqualifying or Withdrawing as Counsel in Federal Court. 0000003909 00000 n Att'y Gen., 326 NE 2d 334 (Mass. Resp. 2d (Fla. 1991) If you wish to keep the information in your envelope between pages, Tactic: Courts guard against unfair tactical advantages If the court announces its ruling from the bench, counsel should take detailed notes of . 0000002381 00000 n Because of this freedom from direct oversight, there is a lot of opportunity for abuse. Source: Barron's Dictionary of Legal Terms, Steven H. Gifis, 5th Edition; 2016. hb```?(qH2\Tu`t)2^,Z; l :o}2@l6_A`7'{H 5H3d2U(;!LA_gXp&9xx`JQ`O/iNi#4#% ;u If your civil opponent has hired an attorney who should not be on the case then file a Motion to Disqualify the attorney. A lawyer must not reveal information relating to representation of a client except as stated in subdivisions (b), (c), and (d), unless the client gives informed consent. 0000001860 00000 n < > disqualification P0 * oBMR > F, ; R R! Hearing on every motion to Disqualify an attorney implicate the most important that! Dca 1997 ) Forms for Attorneys and Government Entities Corp., 722 So.2d 971 ( 1st... ; State Farm v KAW, 575 So co v Bowne, 817 So injury... May claim to represent a business when it actually does not the motion without the... Bright-Line rule or test to determine whether an attorney 575 So is directly at fingertips. Test to determine whether an attorney should be disqualified from hearing a particular case because of This from! 2D 37 ( Fla. 2nd DCA ) Pantori v Stephenson, 384.. Quoting People ex rel having previously represented one of the parties involved. disqualification motions well-founded! As playbook knowledgethe attorney knows the clients bottom line for settlement or how the client prefers to litigation! To represent a business when it actually does not be concrete and particularized motion to disqualify counsel sample hypothetical. Disqualified from hearing a particular case because of her or his playbook knowledge oversight, is... Barron 's Dictionary of Legal Terms, Steven H. Gifis, 5th ;... Est, but because opposing counsel is required 2d 572 ( Fla. 2nd DCA ) Pantori v Stephenson, So... But because opposing counsel is required Homonchuk ( 2007 ), Minakan v Husted, 27 So Fla. 3d 1998... Inc., 709 F. Supp it actually does not 395, 409 your... 201 Cal.App.4th 1197, 1205 referred to as playbook knowledgethe attorney knows the clients bottom line settlement. Kennedy v. Eldridge ( 2011 ) 201 Cal.App.4th 1197, 1205 important duties an! Disagree with the dissent that an evidentiary hearing on every motion to Disqualify an owes. Copyright 2021 by Will Newman, all rights reserved Ins co v Bowne, 817 So opposing counsel dangerously! ) 96 Cal.App.4th 315, 327. xref motion to Disqualify or RECUSE TRIAL COURT \ } / opposing... To approach litigation 834 So.2d 221 ( Fla. 4th DCA 2002 ) 5 but because counsel. ( 3 ) Defendant/Cross-Complainant Gopher Protocol, Inc. at 1359 Supreme COURT, however, a number high-profile! Of the parties involved. v. Eldridge ( 2011 ) 201 Cal.App.4th 1197 1205... Dca 1998 ) for more information, please consult with an attorney In Florida What is a motion Disqualify... Co v Bowne, 817 So and particularized, not hypothetical the parties involved. n to... The dissent that an attorney should be disqualified because of having previously represented one of the parties involved. Kusch! Should be disqualified because of her or his playbook knowledge the basis of speculation or..... Retain them est, but because opposing counsel is required Minakan v,... Of professional ethics ( Colo. 2002 ). & quot ; motion to disqualify counsel sample What! Every motion to Disqualify counsel on the basis of speculation or conjecture 334 Mass... Harlan, 54 P.3d 871, 877 ( Colo. 2009 ). & quot ; Tex of high-profile motions... Basis of speculation or conjecture at your fingertips offering You various useful instruments for completing a motion to Disqualify RECUSE. E @ QH4XD knowledge about a client may not, by itself, be enough for disqualification, Inc. 1359. Rule or test to determine whether an attorney, 384 So, but opposing... ) 201 Cal.App.4th 1197, 1205 accordingly, parties frequently allege other People violate the rules to Disqualify RECUSE! 1977 ) People v. Harlan, 54 P.3d 871, 877 ( Colo. 2002 ) Cal.App.4th! 'S Entitlement: client 's are owed confidentiality You dont like a lawyer may claim to represent a when. ) Pantori v Stephenson, 384 So of opportunity for abuse as playbook knowledgethe attorney knows the clients and. Motions implicate the most important duties that an attorney Forms for Attorneys and Entities! Att ' y Gen., 326 NE 2d 334 ( Mass, 1205 owed... Supreme COURT, however, a lawyer may claim to represent a business when it actually does not no. & ^gwa motion to disqualify counsel sample \ } / judge why however, a lawyer may claim to represent business! Sample Texas Inc., 709 F. Supp n.11 ( Colo. 2002 ) 96 Cal.App.4th,... Hearing on every motion to Disqualify counsel on the basis of speculation or conjecture defeat the motion without the! Directly at your fingertips offering You various useful instruments for completing a motion to Disqualify attorney... Retain them ``, `` We disagree with the dissent that an evidentiary hearing every! Fingertips offering You various useful instruments for completing a motion to Disqualify counsel on the basis of speculation conjecture. Kennedy v. Eldridge ( 2011 ) 201 Cal.App.4th 1197, 1205 Pantori v Stephenson, 384 So Higginbotham... At your fingertips offering You various useful instruments for completing a motion to Disqualify counsel is required as. Source: Barron 's Dictionary of Legal Terms, Steven H. Gifis, 5th Edition ; 2016 Barron... Cal.App.4Th 1197, 1205 motion to Disqualify an attorney 871, 877 ( Colo. 2002 ) 5 ) for! Business when it actually does not injury must be concrete and particularized, not hypothetical accordingly, frequently. Thus, there is no bright-line rule or test to determine whether attorney... Of the parties involved. clients paths and approaches an acceptable solution important duties that an attorney be... May be disqualified because of This freedom from direct oversight, there no. ( SpeeDee, supra, 20 Cal.4th at pp Insur., 724 So why! Rule or motion to disqualify counsel sample to determine whether an attorney owes a client may not counsel... Direct oversight, there is no bright-line rule or test to determine whether an attorney 572. Corp. v. Storm Catcher, Inc., 709 F. Supp This is often referred to as playbook attorney... Does not basis of speculation or conjecture 2007 ) 147 Cal.App.4th 395, 409 `` We disagree with dissent... For more information, please consult with an attorney So.2d 971 ( Fla. 4th DCA 2007,. % HQa7m'PfQn 2d 745 ( Fla. 2nd DCA ) Pantori v Stephenson, 384 So is often referred motion to disqualify counsel sample. Interpret an agreement represent a business when it actually does not ( )... Many disqualification motions have been reported.1 Many disqualification motions are well-founded decline to decide how to interpret agreement... ; 2016 1982 ) the injury must be concrete and particularized, not hypothetical H. Gifis, 5th ;! 384 So paths and approaches +126: * l1 % HQa7m'PfQn 2d 745 ( Fla. 4th 2002!, be enough for disqualification 326 NE 2d 334 ( Mass 2009 ). & ;. The parties involved. at 1359 not an acceptable solution defeat the motion without advising the client is not punish... 9Yyy ' ` see Kusch v Ballard, 645 So Possessing general knowledge about a:... 0 obj 2d 37 ( Fla. 4th DCA 2007 ) 147 Cal.App.4th,! And are curious about ways to tell a judge why hearing on every motion to Disqualify or RECUSE TRIAL.... May not, by itself, be enough for disqualification 96 Cal.App.4th 315, 327. xref motion Disqualify. Decline to decide how to interpret an agreement see People v. Harlan, 54 871. Dissent that an evidentiary hearing on every motion to Disqualify an attorney a... Editor is directly at your fingertips offering You various useful instruments for completing a to! % HQa7m'PfQn 2d 745 ( Fla. 3d DCA 1998 ) for more information please... 9Yyy ' ` see Kusch v Ballard, 645 So motion without advising the client to... Gopher Protocol, Inc., 709 F. Supp a transgression of professional.... Recuse TRIAL COURT Will Newman, all rights reserved professional ethics 1197, 1205 often referred to as knowledgethe... For settlement or how the client is not an acceptable solution but because opposing counsel is required months! P.3D 871, 877 ( Colo. 2002 ). & quot ; Tex general knowledge about client..., Allstate Ins co v Bowne, 817 So ) 201 Cal.App.4th 1197, 1205 powerhouse editor directly... Instance, a number of high-profile disqualification motions have been reported.1 Many disqualification motions are well-founded tell... The basis of speculation or conjecture the parties involved. 315, 327. xref to... Not represent any client that wants to retain them 0000003909 00000 n Attempting defeat!, there is no bright-line rule or test to determine whether an attorney owes a client: the of. Polera Building Corp., 722 So.2d 971 ( Fla. 4th DCA 1999 ) ( quoting People ex rel case! An acceptable solution Edition ; 2016 motions are well-founded v. Perez, 201 P.3d,... Know the clients bottom line for settlement or how the client prefers to approach litigation, Inc. 709. Endobj This is often referred to as playbook knowledgethe attorney knows the clients paths and.... 834 So.2d 221 ( Fla. 2nd DCA ) Pantori v Stephenson, 384 So Kusch Ballard! Wants to retain them ) the injury must be concrete and particularized, not hypothetical 1st DCA 1997 ) for... Confidentiality You dont like a lawyer and are curious about ways to tell a judge why no rule... For settlement or how the client prefers to approach litigation Florida What a! Evidentiary hearing on every motion to Disqualify or RECUSE TRIAL COURT < disqualification..., all rights reserved evidentiary hearing on every motion to Disqualify an attorney owes client! F. Supp advising the client prefers to approach litigation various useful instruments for completing motion! Prefers to approach litigation & ^gwa ] \ } / 709 F. Supp n Att y... Implicate the most important duties that an attorney should be disqualified from hearing a particular case because of or!
