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P1185 The fact that an attorney was disqualified on the ground of conflict in a previous action, in which he filed a cross complaint against a former client alleging that the former client tortiously conspired with a non-party, resulted in issue preclusion (i.e., collateral estoppel) justifying the same attorney's disqualification in a subsequent action based on the same allegation and naming as a defendant the person who had been named as the non-party coconspirator in the cross complaint he filed in the previous action.CitationMACHADO v SUPERIOR COURT (Disqualification Standing) 148 CA4 875 [See: Lucido v Superior Court 51 C3 335]
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