Lavenson v. Loomis

7 Pa. D. & C.4th 188, 1990 Pa. Dist. & Cnty. Dec. LEXIS 193
CourtPennsylvania Court of Common Pleas, Montgomery County
DecidedAugust 8, 1990
Docketno. 89-17523
StatusPublished

This text of 7 Pa. D. & C.4th 188 (Lavenson v. Loomis) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Montgomery County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Lavenson v. Loomis, 7 Pa. D. & C.4th 188, 1990 Pa. Dist. & Cnty. Dec. LEXIS 193 (Pa. Super. Ct. 1990).

Opinion

LAWRENCE, J.,

Plaintiff, Jay Lavenson, appeals from this court’s order of June 19, 1990 granting defendants’ petition to disqualify plaintiff’s attorney from further representation of plaintiff in this action.1

BACKGROUND

On October 17, 1989 Jay Lavenson filed suit against Aviation Insurance Center Inc., James Loomis and The Loomis Companies, Ltd. for breach of an employment contract, tortious interference with that contract and non-payment of commissions while plaintiff was employed as president of AIC from 1985 to 1988. Throughout this period, Loomis and his wife were the sole shareholders of AIC. Loomis was the president and the chairman of [190]*190the board of The Loomis Companies, and he and his wife were the sole shareholders of that company.

On November 13, 1989, defendants filed the within petition to disqualify plaintiff’s counsel, Arthur Wolk, which was granted.

DISCUSSION

A trial court is authorized to disqualify an attorney where there has been a breach of the Rules of Professional Conduct. See Slater v. Rimar Inc., 462 Pa. 138, 338 A.2d 584 (1975). Defendants claim that two fundamental rules of ethical conduct have been violated by plaintiff’s attorney. First, they contend that plaintiff’s attorney has run afoul of Pennsylvania Rule of Professional Conduct 1.6, which charges an attorney with the ethical obligation to preserve confidential client information. Subsection (d). of this rule provides that this duty outlasts the termination of the lawyer’s employment.

Second, defendants assert that plaintiff’s attorney is in violation of rule 1.9, which sets forth an attorney’s required conduct with regard to his or her conflict of interest with former clients:

“A lawyer who has formerly represented a client in a matter shall not thereafter:

“(a) represent another person in the same or a substantially related matter in which that person’s interests are materially adverse to the interests of the former client unless the former client consents after a full disclosure of the circumstances and consultation.”

Disqualification of an attorney on the ground of conflict of interest is thus justified if a court finds (1) the existence of a prior attorney-client relationship between the party seeking disqualification and the attorney in question, and (2) the matters involved in the current action are substantially related to the [191]*191subject matter of the former representation. North Penn Hospital v. Hughes Foulkrod Construction Co., 22 D.&C. 3d 652 (1981).

Disqualification is essential in the present case. Defendants are Wolk’s former clients, and the present litigation bears a substantial relationship to the prior representation.

A significant part of plaintiff’s lawsuit and defendants’ petition to disqualify centers on a program kriown as the Helicopter Association Insurance, program. The program itself was to evolve from a formal written agreement between Helicopters Association International, an organization of helicopter owners and operators, and AIC, an insurance agency. Under this agreement, AIC was to find favorable insurance coverage for HAI members who received helicopter training and who properly maintained their helicopters.

The groundwork for the HAI program was laid from 1985 to 1987, when extensive negotiations between the principals of both AIC and HAI took place and an agreement between them was finalized. The instant petition arises out of Arthur Wolk’s involvement in effectuating this agreement. There is no dispute that Wolk was involved in the HAI agreement. Wolk contends, however, that his involvement was solely limited to representing Jay Lavenson personally2 and that he did not represent the defendants. Conversely, the defendants assert that although they never formally retained Wolk to represent them with regard to HAI and despite no fee ever having been paid to Wolk as a result of his [192]*192work, he was their counsel in connection with the HAI/AIC agreement.

The existence of an attorney-client relationship does not depend on either an explicit agreement or the payment of a fee. E.F. Hutton & Co. v. Brown, 305 F.Supp. 371 (S.D. Texas, 1969); Hendershot v. Hendershot, 28 D.&C. 3d 239 (1982). The existence of an attorney-client relationship may be implied from the conduct of the parties. E.F. Hutton & Co., supra. The existence of the attorney-client relationship can also be found when it is not unreasonable for the client to have understood that he or she was represented by a particular attorney. Id. Whether an attorney-client relationship existed depends on the client’s belief that he is consulting a lawyer in that capacity and his manifested intention to seek professional advice. Westinghouse Electric v. Kerr-McGee Corp., 480 F.2d 1311 (7th Cir. 1978). Even an implied professional relationship can result in a finding of a conflict of interest. Id.

The nature of Wolk’s participation in the HAI program is delineated by the deposition testimony of Wolk, Lavenson, Loomis and the documentary evidence of record related to the HAI/AIC transaction. James Loomis testified at his deposition that he believed Wolk represented AIC, himself and The Loomis Companies in connection with the HAI program. (Loomis deposition at 20, 24, 29, 51.) He stated that Wolk not only participated in the negotiation of the HAI/AIC agreement, he was also involved in the drafting phase. (Loomis deposition at 57.)

An initial draft of the HAI/AIC agreement was sent to Wolk and placed into his law office word processor. (Lavenson deposition at 58-9.) Wolk made substantial changes to this draft. (Lavenson [193]*193deposition at 63-4; 200144-200154.)3 After this, Wolk had ongoing involvement in the drafting of the document. For instance, Wolk’s letter of August 13, 1986, addressed to Lavenson as president of AIC, stated that he was forwarding to Lavenson as president of AIG a draft of the AIC/HAI agreement. (Wolk deposition at 20-1; 200174.) He attached a draft of the HAI agreement which he acknowledged was in his own handwriting. (Wolk deposition at 22; 200206-200220.) Additionally, in a November 4, 1986 letter from Wolk to Loomis, Lavenson and Peter Meshin, AIC Director of Operations, Wolk ¿nclosed a copy of another revised HAI agreement for their review and thanked them “for the opportunity to participate in drafting this document.” (Wolk deposition at 33, 35; 200140.)

In a November 10, 1986 letter to James Loomis and Jay Lavenson, Wolk stated that he was enclosing still another revised HAI agreement to “include the changes Jim requested.” (Wolk deposition at 33; 200138.)

Most significantly, a review of the first page of any of these drafts indicates that the agreement,was at all times between HAI and AIC, not Jay Laven-son. Lavenson was not a party to the HAI/AIC agreement. Any legal representation Wolk provided to Lavenson was done in Lavenson’s capacity as president of AIC.

The record is clear that during the HAI/AIC negotiations, the only attorney on the AIC side was Wolk.

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Cite This Page — Counsel Stack

Bluebook (online)
7 Pa. D. & C.4th 188, 1990 Pa. Dist. & Cnty. Dec. LEXIS 193, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lavenson-v-loomis-pactcomplmontgo-1990.