Substantial Relations Test for Prior Representation

Court disqualified counsel under Rule of Professional Conduct 1.9, applying the “substantial relation” test to former counsel’s representation of the current adversary party.  Temkin Estate, 3 Fid.Rep.3d 37, 3 Fid.Rep.3d 261 (O.C. Bucks 2012) (Opinion by Gilamn, J.), appeal quashed, 2614 EDA 2012 (Pa. Super. 8/23/2013) (non-precedential; disqualified attorney did not have standing to appeal).

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