Elliott v. Elliott

CourtDistrict Court, E.D. California
DecidedNovember 17, 2021
Docket1:21-cv-00897
StatusUnknown

This text of Elliott v. Elliott (Elliott v. Elliott) is published on Counsel Stack Legal Research, covering District Court, E.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Elliott v. Elliott, (E.D. Cal. 2021).

Opinion

Case 1:21-cv-00897-SAB Document 36 Filed 11/17/21 Page 1 of 45

8 UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10

11 AARON A. ELLIOTT, Case No. 1:21-cv-00897-SAB

12 Plaintiff, ORDER DENYING PLAINTIFF’S MOTION TO DISQUALIFY COUNSEL 13 v. (ECF Nos. 30, 33, 34) 14 FRANK T. ELLIOTT, III, et al.,

15 Defendants.

17 I.

18 INTRODUCTION

19 Currently pending before the Court is Plaintiff Aaron A. Elliot’s (“Plaintiff”) motion to

20 disqualify Quall Cardot, LLP (“Quall”), as counsel for Defendants Frank T. Elliott, III (“Tokkie”

21 or “Trustee”), Wileman Bros. & Elliott Inc. (“WBE”), and Brian Johnson (“Johnson”). The 1

22 Court, having reviewed the motion, opposition, and reply papers, the declarations and exhibits

23 attached thereto, as well as the Court’s file, shall deny the motion for the reasons explained

24 herein.

25 / / /

26 / / / 27 1 For ease of reference to the docket and filings in this action, while the parties utilize the terms petition, petitioner, and respondents, the Court shall refer to the parties as Plaintiff and Defendants, and the operative petition as the first 28 amended complaint.

1 Case 1:21-cv-00897-SAB Document 36 Filed 11/17/21 Page 2 of 45

1 II.

2 BACKGROUND

3 On March 26, 2021, Plaintiff instituted this action by filing a petition for accounting and

4 other claims, in the Superior Court of California, County of Tulare. (ECF No. 1 at 8.) The

5 petition brought claims for: (1) Petition for Accounting: (2) Petition to Remove Trustee; (3)

6 Petition for Surcharge; (4) Return of Trust Property and Damages; (5) Aiding and Abetting

7 Fiduciary Breaches and for Return of Wrongful Withholding of Trust Property; (6) Violation of

8 the Perishable Agricultural Commodities Act of 1930 (“PACA”), and the California Food and

9 Agriculture Code; and (7) Conversion. (Id.) On June 4, 2021, Defendants removed this action to

10 this Court, the United States District Court for the Eastern District of California. (ECF No. 1.)

11 Plaintiff’s sole federal claim in the originally filed complaint was an alleged violation of

12 the PACA. (ECF No. 1 at 8-29.) On June 14, 2021, Defendants filed a motion to dismiss, along

13 with an answer and counterclaim. (ECF Nos. 6, 7.) The counterclaim proffers jurisdiction based

14 on the PACA claim. (ECF No. 7.) On June 18, 2021, Plaintiff filed a first amended complaint

15 which retained all the same claims as the original complaint except for the PACA claim. (ECF

16 No. 9.) On June 28, 2021, Plaintiff filed a motion to remand based on the absence of the PACA

17 claim. (ECF No. 10.) On July 9, 2021, Defendants filed an answer to the first amended

18 complaint, and on July 14, 2021, Plaintiff/Counter-Defendant filed an answer to the

19 counterclaim. (ECF Nos. 17, 18.) On July 23, 2021, the case was reassigned to the undersigned 20 pursuant to the parties’ consent. (ECF No. 22.) On August 25, 2021, the Court denied

21 Defendants’ motion to dismiss as moot and withdrew the motion to remand pursuant to the

22 notice of withdrawal. (ECF No. 25.) On October 1, 2021, the scheduling order issued in this

23 action. (ECF No. 29.)

24 On October 6, 2021, Plaintiff filed the motion to disqualify counsel that is presently

25 before the Court, setting the hearing for November 10, 2021. (ECF No. 30.) On October 27,

26 2021, Defendants filed an opposition to the motion. (ECF No. 33.) On November 3, 2021, 27 Plaintiff filed a reply brief. (ECF No. 34.) On November 8, 2021, finding the matter suitable for

28 decision without oral argument pursuant to Local Rule 230(g), the Court vacated the November

2 Case 1:21-cv-00897-SAB Document 36 Filed 11/17/21 Page 3 of 45

1 10, 2021 hearing on this motion. (ECF No. 35.)

2 III.

3 LEGAL STANDARD

4 Motions to disqualify counsel are decided under state law. In re Cnty. of L.A., 223 F.3d

5 990, 995 (9th Cir. 2000); Hitachi, Ltd v. Tatung Co., 419 F.Supp.2d 1158, 1160 (N.D. Cal.

6 2006). The local rules for this district direct the Court to apply the rules and law of professional

7 conduct of California. See Local Rule 180(e) (“[T]he standards of professional conduct required

8 of members of the State Bar of California and contained in the State Bar Act, the Rules of

9 Professional Conduct of the State Bar of California, and court decisions applicable thereto . . .

10 are hereby adopted as standards of professional conduct in this Court.”); Rodriguez v. W. Publ’g

11 Corp., 563 F.3d 948, 967 (9th Cir. 2009) (“By virtue of the district court’s local rules, California

12 law controls whether an ethical violation occurred.”).

13 The decision to grant a motion to disqualify counsel due to a conflict of interest is within

14 the trial court’s discretion. Lennar Mare Island, LLC v. Steadfast Ins. Co., 105 F. Supp. 3d 1100,

15 1108 (E.D. Cal. 2015). “Under California law the starting point for deciding a motion to

16 disqualify counsel is the recognition of interests implicated by a motion.” Hitachi, 419

17 F.Supp.2d at 1160. Disqualification motions involve such considerations as a client’s right to

18 chosen counsel, an attorney’s interest in representing a client, and the financial burden on a client

19 to replace disqualified counsel. Id. at 1161 (citing People ex rel. Department of Corporations v. 20 SpeeDee Oil Change Systems, Inc., 20 Cal.4th 1135, 1145 (1999); Lennar Mare Island, 105 F.

21 Supp. 3d at 1108 (stating court must weigh same factors, as well as “any tactical abuse

22 underlying a disqualification proceeding against the fundamental principle that the fair resolution

23 of disputes within our adversary system requires vigorous representation of parties by

24 independent counsel unencumbered by conflicts of interest.”) (quoting In re Lee G., 1

25 Cal.App.4th 17, 26 (1991)).

26 “Disqualification is a blunt tool meant to encourage wide berth of ethical grey areas, its

27 ruthlessness warranted only after a clear showing of conflict.” Lennar Mare Island, 105 F. Supp.

28 3d at 1107. Because “disqualification is a drastic measure, it is generally disfavored and should

3 Case 1:21-cv-00897-SAB Document 36 Filed 11/17/21 Page 4 of 45

1 only be imposed when absolutely necessary.” Id. (quoting Concat LP v. Unilever, PLC, 350

2 F.Supp.2d 796, 814 (N.D. Cal.2004). “On the other hand, particularly when a party alleges a

3 conflict between two of a firm’s current clients, ‘the paramount concern must be the preservation

4 of public trust both in the scrupulous administration of justice and in the integrity of the bar.

5 Consequently, the recognizably important right to choose one’s counsel must yield to the ethical

6 considerations that embody the moral principles of our judicial process.’ ” Id. at 1108 (quoting

7 State Farm Mut. Auto. Ins. Co. v. Fed. Ins. Co., 72 Cal.App.4th 1422, 1428 (1999)).

8 California law distinguishes two types of conflict: a successive conflict of interest

9 involves a conflict of interests between a current client and a former client, whereas a concurrent

10 conflict places the interests of two current clients at odds. Lennar Mare Island, 105 F. Supp. 3d

11 at 1108 (citations omitted). Where successive, the primary concern is that of confidentiality. Id.

12 Where concurrent, the primary concern is the attorney’s duty, and the client’s legitimate

13 expectation, of loyalty. Id.

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