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p0436 If an attorney representing a party in litigation previously represented an adverse party, the court should determine whether the prior representation was direct and personal and if so should disqualify the attorney if there is a connection between the two successive representations; however, if the court finds that the attorney was not in a direct, personal relationship with the former client, it should not disqualify the attorney unless it determines that the attorney's position during the first representation made it likely that confidential information relevant to the current representation was acquired.CitationJESSEN v HARTFORD (Substantial Relationship) 111 CA4 698 [See: R of PC 3310; Flatt v Superior Court 9 C4 275, T/AT 2/95; Ahmanson v Salomon 229 CA3 1445]
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