California, United States of America
The following excerpt is from GREAT LAKES Constr. INC. v. BURMAN, 114 Cal.Rptr.3d 301, 186 Cal.App.4th 1347 (Cal. App. 2010):
Our reading of Colyer v. Smith, supra, 50 F.Supp.2d 966, recognizes a minority view inasmuch as it permits a non-client to move to disqualify opposing counsel. But the non-client must meet stringent standing requirements, that is, harm arising from a legally cognizable interest which is concrete and particularized, not hypothetical. ( Id. at pp. 971973.)
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