MERCADO v. SUPERIORCOURTOFORANGECOUNTY
Nonparty may bring motion to disqualify attorney, rather than file an independent action to protect movant's substantive rights as former client, where attorney was disqualified in previous action involving movant, and new action in which ex client was not named as a party but could have been added later by Doe amendment was an obvious attempt at evading prior disqualification order. Where prior disqualification order had become final, and grounds for motion to disqualify in new action involving same adverse party were identical, doctrine of collateral estoppel precluded attorney from opposing disqualification in new action.
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