The following excerpt is from Smith v. Cook, Case No.: 17-cv-00961-AJB-WVG (S.D. Cal. 2018):
With these principles in mind, a litigant may bring a motion to disqualify an attorney if he or she has standing, which is "implicit in disqualification motions." Great Lakes, 186 Cal. App. 4th at 1356. Generally, standing requires that the plaintiff be able to assert an injury, that is, an invasion of a legally protected interest. See Angelucci v. Century Supper Club, 41 Cal. 4th 160, 175 (2007). Moreover, in most circumstances, before the disqualification of an attorney is proper, the complaining party must have or must have had an attorney-client relationship with that attorney. See Strasbourger Pearson Tulcin Wolff Inc. v. Wiz Tech., Inc., 69 Cal. App. 4th 1399, 1404 (1999).
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