California, United States of America
The following excerpt is from Brooklyn Navy Yard Cogeneration Partners, L.P. v. Superior Court (Parsons Corp.), 60 Cal.App.4th 248, 70 Cal.Rptr.2d 419 (Cal. App. 1997):
3 Our research revealed only one reported California decision which even touches upon the issues raised here. In Truck Ins. Exchange v. Fireman's Fund Ins. Co. (1992) 6 Cal.App.4th 1050, 8 Cal.Rptr.2d 228, plaintiffs' counsel was disqualified for undertaking a representation adverse to a "current client"--the defendant. Significantly, the opinion states plaintiffs' counsel "concedes" that its representation of "an entity related to [the defendant]" in concurrent, unrelated litigation made the defendant its "client" as well. (Id. at p. 1053, 8 Cal.Rptr.2d 228.) The opinion simply assumes the truth of this "concession" and does not analyze whether the defendant and its corporate affiliate should be treated as the same entity for conflict purposes.
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