HomeMy WebLinkAbout02-13-89 (2)
BARBARA McK. MUMMA AND
LISA M. MORGAN, individually
and as executrixes of the
ESTATE OF ROBERT M. MUMMA,
Deceased,
: IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - EQUITY
Plaintiffs
V
ROBERT M. MUMMA, II,
Defendant
NO. 66 EQUITY 1988
BARBARA McK. MUMMA AND
LISA M. MORGAN, individually
and as executrixes of the
ESTATE OF ROBERT M. MUMMA,
Deceased,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
ORPHANS' COURT DIVISION
Plaintiffs
.
.
V
.
.
ROBERT M. MUMMA, II,
BARBARA M. McCLURE, AND
LINDA M. ROTH,
Defendants
NO. 21-86-398
IN RE: DEFENDANT ROBERT M. MUMMA. II'S MOTIONS TO DISQUALIFY
MORGAN. LEWIS Ii BOCltIUS FROM LEGAL REPRESENTATION
OF THE ESTATE OF ROBERT M. MUMMA. DECEASED
BEFORE SHEELY. P.J.
ORDER OF COURT
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AND NOW, this
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day of February, 1989,
defendant's motion to disqualify the law firm of Morgan, Lewis &
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Bockius from legal representation of the Estate of Robert M.
Mumma, deceased, is DENIED.
By the Court,
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Thomas M. Kittredge, Esquire
John F. Stillmun, III, Esquire
William F. Martson, Esquire
For the Plaintiffs
John B. Fowler, III, Esquire
Jon A. Baughman, Esquire
Anthony Vale, Esquire
For the Defendants
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BARBARA McK. MUMMA AND
LISA M. MORGAN, individually
and as executrixes of the
ESTATE OF ROBERT M. MUMMA,
Deceased,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - EQUITY
Plaintiffs
V
ROBERT M. MUMMA, II,
Defendant
NO. 66 EQUITY 1988
BARBARA McK. MUMMA AND
LISA M. MORGAN, individually
and as executrixes of the
ESTATE OF ROBERT M. MUMMA,
Deceased,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: ORPHANS' COURT DIVISION
Plaintiffs
V
ROBERT M. MUMMA, II,
BARBARA M. McCLURE, AND
LINDA M. ROTH,
Defendants
NO. 21-86-398
:
IN RE: DEFENDANT ROBERT M. MUMMA, II'S MOTIONS TO DISQUALIFY
MORGAN. LEWIS & BOCKIUS FROM LEGAL REPRESENTATION
OF THE ESTATE OF ROBERT M. MUMMA, DECEASED
BEFORE SHEELY, P.J.
OPINION AND ORDER OF COURT
On January 25, 1989, a hearing was held before this
court concerning Robert M. Mumma, II's (Mr. Mumma) motion to
disqualify Morgan, Lewis & Bockius (Morgan, Lewis) as counsel for
plaintiffs in both of the above-captioned actions. What follows
is this court's findings of facts, discussion, and conclusions of
law.
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FINDINGS OF FACTS
1. Robert M. Mumma, II, is a defendant in both of the
above actions.
2. The decedant, Robert M. Mumma, died testate on
April 12, 1986.
3. On June 5, 1986, letters testamentary for the
Estate of Robert M. Mumma were granted to Barbara McK. Mumma and
Lisa M. Morgan as executrixes under instruments dated May 19,
1982 and October 12, 1984.
4. Morgan, Lewis represents the plaintiff executrixes,
Barbara McK. Mumma and Lisa M. Morgan in both of the above
actions and have been legal counsel to the estate since the death
of the decedant.
5. At a meeting with Arthur Klein of Morgan, Lewis in
Mayor June, 1986, at which all members of the immediate family
were present, Mr. Klein explained in detail the provisions of the
will and discussed with the family various suggestions and
options to pursue regarding the administration of the estate.
6. Mr. Klein of Morgan, Lewis attended this meeting as
legal counsel for the estate; however, he did not specifically
state that he only represented the estate.
7. During the meeting, Mr. Klein discussed with all
present the possibility of the children disclaiming their
interest under the will in favor of their children in order to
gain some tax benefit by avoiding ndoublen taxation.
8. On August 21, 1986, Mr. Mumma met with Mr. Klein in
order to discuss his own personal estate planning needs.
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NO. 1526 CIVIL 1988
9. As a result of that meeting, Mr. Mumma retained the
legal services of Morgan, Lewis for his own estate planning
needs.
10. Mr. Klein began working on Mr. Mumma's estate
planning needs, however, by letter dated September 5, 1986,
Morgan, Lewis through Mr. Klein, informed Mr. Mumma that Morgan,
Lewis represents the Mumma Estate by stating:
One matter we discussed which I did not
note in the memorandum is that if you or any
of your companies were to become involved in
negotiations with your father's Estate to buy
the operating company (or anything else for
that matter), Morgan, Lewis & Bockius would
represent the Estate and your would obtain
other counsel. I know that Lisa and your
mother are satisfied with that understanding
and you indicated that you were also.
Defendant's Exhibit No.1.
11. Mr. Mumma understood that Morgan, Lewis was only
representing him concerning his "estate planning and related
matters." Mr. Mumma understood that he would need separate legal
counsel if he or any of his companies were to enter negotiations
with the Estate to purchase the operating company (pennsy Supply,
Inc.) or to purchase anything else for that matter from the
Estate.
12. Mr. Mumma provided Mr. Klein with documentation of
his financial assets and liabilities in order to facilitate his
estate planning.
13. These statements and documentations of Mr. Mumma's
financial status were returned to Mr. Mumma.
14. Mr. Mumma has substantial and extensive experience
with attorney-client relationships as he has retained at least
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NO. 1526 CIVIL 1988
twelve different attorneys to represent him concerning personal
as well as business matters.
15. In early January, 1987, Mr. Mumma and Mr. Klein
had a discussion concerning Mr. Mumma disclaiming his interest
under his father's will in favor of his children.
16. Mr. Mumma authorized Mr. Klein to draft a
disclaimer of his interest for his review.
17. Mr. Klein informed Mr. Mumma by letter, dated
January 6, 1987, that for the disclaimer to be effective, it must
be filed with the Clerk of the Orphans' Court Division of
Cumberland County.
(Defendant's Exhibit No.7).
18. Mr. Mumma executed the qualified disclaimer of his
interest on January 6, 1987, (Plaintiff's Exhibit No.1) and said
disclaimer was filed with the Court of Common Pleas of Cumberland
County, Orphans' Court Division on January 12, 1987, in Book 115
at Page 20 with the knowledge and authorization of Mr. Mumma.
(See, Plaintiff's Exhibit No.1 and No.2).
19. On March 26, 1987, Morgan, Lewis received a
retainer in the amount of $20,000 from Mr. Mumma. The $20,000
was drawn from the corporate account of Kimbob, Inc.
(Defendant's Exhibit No.8).
20. In November, 1986, Morgan, Lewis counseled the
executrixes on the advisability of liquidating two family
companies prior to the end of 1986. The two companies were Kim
Company and Pennsylvania Supply Company.
21. Mr. Mumma was vice-president of both companies in
November, 1986, and as such, was their senior officer.
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NO. 1526 CIVIL 1988
22. The shareholders of Kim Company were as follows:
Pennsylvania Supply Company (7,241 shares), Mr. Mumma (334
shares), Mrs. McClure (333 shares), Mrs. Roth (333 shares), Mrs.
Morgan (333 shares), and Mrs. Mumma (106 shares).
23. The shareholders of Pennsylvania Supply Company
were as follows: the decedent (700 shares), Mr. Mumma (3
shares), Mrs. McClure (3 shares), Mrs. Roth (3 shares), and Mrs.
Morgan (3 shares).
24. Both Kim Co. and Pennsylvania Supply Company held
substantial real estate although they were non-operating.
25. In November, 1986, Morgan, Lewis met with the
shareholders of the two above named companies to discuss the
possible liquidation of the companies.
26. Present at the meeting in addition to all the
shareholders, were Mr. Klein and Mr. Hadley, the family
accountant.
27. At the meeting Mr. Mumma raised questions
concerning the possibility to liquidating the companies while
maintaining their corporate shell or identity for possible future
use.
28. All family members/shareholders were concerned
with the answer to the above questions although Mr. Klein could
not answer the questions without conducting some legal research.
29. After conducting legal research concerning Mr.
Mumma's various questions, Mr. Klein sent Mr. Mumma a letter
dated November 11, 1986, with a blind carbon copy going to, among
others, the executrixes of the estate. The letter contained
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NO. 1526 CIVIL 1988
answers to Mr. Mumma's questions regarding the feasibility and
mechanics of the liquidation of the corporations as proposed by
Mr. Mumma. (Defendant's Exhibit NO.2).
30. Mr. Klein's associate, Martha E. Manning, sent Mr.
Mumma a letter dated December 3, 1986, at Executrix Morgan's
request in which Section 1103 of the Pennsylvania Business
Corporation Law relating to the dissolution of corporations was
relayed to Mr. Mumma.
31. In December, 1986, William Skinner, an associate
in the corporate department of Morgan, Lewis, met in Harrisburg
with the executrixes and Mr. Mumma to review a draft of a
tenants-in-common agreement which concerned the handling of the
liquidated assets of Kim Company and Pennsylvania Supply Company.
32. Mr. Skinner appeared at this meeting as legal
counsel for the estate, however, he did not mention that Morgan,
Lewis was not acting as legal counsel of the shareholders.
33. After the meeting was under way, Mr. Klein
participated in this meeting via telephone from Philadelphia to
answer questions concerning the proposed agreement and certain
changes were suggested by Mr. Mumma.
34. The changes suggested included the right of first
refusal provision, which would give any shareholder (who would
become a tenant-in-common) the right to buy the interest of any
other shareholder who wanted to sell his or her interest. The
other suggested change pertained to the ability of the tenant-in-
common to pledge their interest, to grant gifts, etc.
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NO. 1526 CIVIL 1988
35. Morgan, Lewis sent all shareholders including Mr.
Mumma a revised copy of the tenant-in-common agreement under
cover of letter dated March 11, 1987 (Defendant's Exhibit No.4).
36. In December, 1986, Mr. Mumma executed a power of
attorney to enable the liquidation of the corporations to proceed
while he was in Colorado during the month of January, 1987.
37. During the Spring of 1987, Morgan, Lewis met with
the tenants-in-common at the Estate's request to discuss drafts
of tenants-in-common agreements as well as the management
agreements for the jointly-held properties.
38. During a February or March, 1987 meeting with some
of the tenants-in-common present, Mr. Mumma signed two unattached
signature pages for the draft agreements. These pages were later
attached to the final agreements of the tenants-in-common.
39. In July, 1987, the executrixes called a meeting at
Mrs. McClure's home which was attended by all of the tenants-in-
common. The meeting was called to discuss the sale of some
property in Lemoyne, pennsylvania owned by the tenants-in-common.
40. Mr. Mumma opposed this sale. However, he agreed
to sign a power of attorney to permit the sale only upon
obtaining the agreement of all the shareholders of Nine Ninety-
Nine, Inc. (999) that he would have right of first refusal to buy
Pennsy Supply, Inc.
41. No representative of Morgan, Lewis was present at
this above meeting.
42. After the meeting, Executrix Morgan consulted with
Mr. Klein who advised against the granting of the right of first
refusal to Mr. Mumma.
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NO. 1526 CIVIL 1988
43. Morgan, Lewis continued to represent Mr. Mumma
with regard to his personal estate planning needs until August
14, 1987, at which time Mr. Mumma advised Mr. Klein that he would
seek other representation. (Defendant's Exhibit NO.9).
44. Morgan. Lewis. by letter dated August 14, 1987,
returned $6,100 from the $20,000 retained on Mr. Mumma's account
after deducting charges for work performed on his personal estate
planning matters as well as the disclaimer matter. (Defendant's
Exhibit No.9).
45. Mr. Mumma was not charged for any consultation,
legal research or work performed by Morgan, Lewis concerning the
tenants-in-common agreements or any other matter of the Mumma
Estate. (Plaintiff's Exhibit No.3).
46. On December 27, 1988, a complaint for declaratory
judgment and relief was filed by the above plaintiffs at 21-86-
398 of the Cumberland County Court of Common Pleas, Orphans'
Court Division.
47. The complaint generally seeks declaratory judgment
under 42 Pa. C.S.A. S7533 and 20 Pa. C.S.A. S711 that Article
Thirteenth of decedent's will does not bar plaintiffs from
selling shares of Nine Ninety-Nine, Inc. (999) and Hummelstown
Quarries, Inc. (Humme1stown) owned by the estate to a publicly
traded overseas entity.
48. Morgan, Lewis represents the plaintiffs in this
current matter before the Orphans' Court.
49. On December 27. 1988. Executrixes Barbara McK.
Mumma and Lisa M. Morgan petitioned this court for the Estate of
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NO. 1526 CIVIL 1988
Robert M. Mumma, deceased, for declaratory judgment under 42 Pa.
C.S.A. ~7533 and for other relief under 20 Pa. C.S.A. Subch. 33C
[sic] and p133.
50. The petition generally seeks a confirmation of the
petitioners' authority to sell 999 and Hummelstown and certain
other related real estate owned by the estate and Mumma family
members and for an order under 20 Pa. C.S.A. Subch. 33C [sic]
~7133 that the estate may submit any issues nonselling
shareholder raises in connection with the sale of his/her
interest in 999 and Hummelstown to voluntary judicial arbitration
in the Court of Common Pleas of Cumberland or Dauphin County.
51. Morgan, Lewis represents the petitioners in this
matter.
52. On December 27, 1988, a complaint in equity and
declaratory judgment at No. 66 Equity 1988 was brought by the
above plaintiffs against the defendants in the Cumberland County
Court of Common Pleas.
53. The complaint generally seeks a declaratory
judgment declaring that the right of first refusal asserted by
Mumma with respect to Pennsy Supply, Inc., is invalid and that
the Mumma Realty Associates power of attorney executed by Mumma,
is valid and enforceable and entitles plaintiffs to act as
attorney in fact to execute in Mumma's name the deeds and other
documents necessary to complete the sale of Mumma Realty
Associates I and Mumma Realty Associates II properties to a
proposed buyer; and finally declare that the MRA I and MRA II
agreements are valid, enforceable and binding on Robert M. Mumma,
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NO. 1526 CIVIL 1988
II and enter an order requiring Mr. Mumma to specifically perform
his duties and obligations under the MRA I and MRA II agreements.
54. Morgan, Lewis represents the plaintiffs in this
equity matter.
55. On December 29, 1988, Robert M. Frey, Esquire was
appointed by this court as Guardian Ad Litem for the minor
persons interested in the estate of Robert M. Mumma, deceased,
with authorization to represent said minor persons in all matters
related to the sale of 999 and Hummelstown and the actions for
declaratory judgment and other relief pertaining thereto to
actions now pending before this court and in any further
proceedings in the Court of Common Pleas of Cumberland or Dauphin
County, Pennsylvania.
56. Mr. Mumma does not dispute he intends his
qualified disclaimer to be effective, nor does he claim that it
is now invalid.
DISCUSSION
Mr. Mumma's motion to disqualify Morgan, Lewis as legal
counsel for the plaintiff in the pending litigation draws our
attention to the Rules of Professional Conduct (Rules) as adopted
by the Pennsylvania Supreme Court. The Rules became effective on
April 1, 1988 and, as such, superseded the former Code of
Professional Responsibility (Code).
Defendant's motion is based on the argument that
Morgan, Lewis represented Mr. Mumma in prior matters which were
substantially related to the pending Orphans' Court and Equity
matter. In essence, Mr. Mumma alleges that a conflict of
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NO. 1526 CIVIL 1988
interest exists in Morgan, Lewis' continued representation of the
plaintiffs. Mr. Mumma points to Rule 1.9 as his authority for
his motion. Rule 1.9 reads as follows:
Conflict of Interest: Former Client
A lawyer who has formerly represented a
client shall not thereafter:
(a) represent another person in the
same or 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; or
(b) use information relating to the
representation to the disadvantage of the
former client except as Rule 1.6 would
permit with respect to a client or when
the information has become generally
known.
Rule 1.9, Rules of Professional Conduct, 42 Pa. C.S.A. (Purdon
Supp. 1988).
In considering a motion for disqualification of a
party's legal counsel, courts are reluctant to grant such a
serious remedy because when presented with such a serious
request, courts must be careful "to preserve a balance. delicate
though it may be. between an individual's right to his own freely
chosen counsel and the need to maintain the highest ethical
standards of professional responsibility." Slater v. Rimar.
~. 462 Fa. 138, 338 A.2d 584, 590 (1975). Because motions for
disqualification are at times interposed for tactical reasons,
courts must approach such motions with caution as a client whose
attorney is disqualified incurs a loss of time and money in being
compelled to retain new counsel who in turn have to become
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NO. 1526 CIVIL 1988
familiar with the prior comprehensive investigation which is the
core of modern complex litigation. The client, moreover, may
lose the benefit of its long-time counsel's specialized knowledge
of its operations. See,~, Government of India v. Cook
Industries, Inc., 569 F.2d 737 (2nd Cir. 1978)1 Ries v. MTD
Products, Inc., 14 D.&C.3d 566 (1980).
pennsylvania's appellate courts have not directly
addressed conflicts of interest issues under the newly adopted
Rules. However, the comment to the Rules explains that Rule 1.9
merely incorporates the basic elements of Canons 4 (client
confidentiality), 5 (loyalty to client), and 9 (appearance of
impropriety) contained in the former Code. Thus, the Rules
hopefully provide clearer guidance to both the bench and bar when
faced with questions of conflict of interest with a former client
than was provided by the Code.
Under Rule 1.9 the test for disqualification focuses on
the analysis of whether the subject matter of the representation
of the former client and the present client are "substantially
related." In raising a conflict of interest challenge, the
burden is on the moving party to establish a violation of Rule
1.9. See, Pa. Power & Liqht v. Gulf Oil Corp., 74 D.&C.2d 431
(1975)1 INA Underwriters Ins. v. Nalibotsky, 594 F.Supp. 1199
(E.D. Pa. 1984).
A court in addressing the "substantial relationship"
issue must answer the following questions:
1. Did the lawyer have an attorney-client
relationship with the former client?
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NO. 1526 CIVIL 1988
2. What was the nature and scope of the
prior representation at issue?
3. What is the nature of the present lawsuit
against the former client?
See, INA, supra, Nemours Foundation v. Gilbane, Aetna, Federal
Ins., 632 F.Supp. 418 (D. Del. 1986).
Under the present facts, there is no dispute that an
attorney-client relationship existed between Morgan, Lewis and
Mr. Mumma. Thus, the thrust of our analysis moves onto the
nature and scope of that prior representation. Mr. Mumma argues
that Morgan, Lewis represented him not only in his own personal
estate planning needs and disclaimer needs, but so, too, did
Morgan, Lewis represent him with regard to the negotiations and
liquidations of Kim Company and Pennsylvania Supply Company and
the formation of the related tenancy-in-common. We do not
believe that the facts of this case, nor the applicable law in
regards to this matter, adequately supports Mr. Mumma's argument.
In reaching this conclusion, our attention is first
drawn to the letter, dated September 5, 1986, in which Mr. Klein
clearly states to Mr. Mumma the terms of Morgan, Lewis'
representation.
(Defendant's Exhibit No.1). In that letter,
Mr. Klein clearly stated that he was employed by Mr. Mumma solely
for estate planning purposes and disclaimer purposes under Mr.
Mumma's father's will. Moreover, Mr. Mumma was given express
notice that Morgan, Lewis would not act as Mr. Mumma's attorney
if Mr. Mumma entered into negotiations with the Estate for the
purchase of any Estate assets. Thus, Mr. Mumma had express
notice that Morgan, Lewis' duty of loyalty and representation
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NO. 1526 CIVIL 1988
attached to their representation of the Estate and that no
attorney-client relationship could exist with Mr. Mumma if he
sought to purchase Estate assets.
On further review of the facts, it is clear to this
court that Morgan, Lewis' attorney-client relationship with Mr.
Mumma did not expand beyond the understanding of the above-noted
September 5, 1986 letter. (Defendant's Exhibit No.1). Although
there were meetings (both in Harrisburg and in Philadelphia) in
which Morgan, Lewis participated, those meetings were attended at
all times by the executrixes of the Estate and Morgan, Lewis as
legal counsel for the Estate. Even the correspondence that Mr.
Mumma received following some of these meetings advised him that
Morgan, Lewis was writing at the request of the Estate with
regard to questions concerning the dissolution of some
corporations in which Mr. Mumma was a shareholder. (See
Defendant's Exhibit No.3). We do note, however, that at some of
these meetings Mr. Mumma, upon reviewing drafts of documents, had
certain questions and suggestions. Because Morgan, Lewis
undertook some legal research to answer these questions and
suggestions, Mr. Mumma now argues that Morgan, Lewis was acting
as his attorney when in fact these legal answers were mutually
beneficial to the Estate. Moreover, we take special note that
Mr. Mumma was not charged for such legal research. (See,
Plaintiff's Exhibit No.3).
In addressing a motion for disqualification, the Court
of Common Pleas of Lehigh County in Pennsylvania Power & Liqht
succinctly summarized the law of Pennsylvania regarding the
existence of an attorney-client relationship:
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NO. 1526 CIVIL 1988
Although the relationship of attorney and
client may be implied from the conduct of the
parties, such conduct must evidence an offer
or request by the client for legal services
and an acceptance of the offer by the
attorney. It is clear that an attorney-
client relationship exists only with the
consent of both parties. [S]uch relationship
is "personal. reciprocal, and confidential"
and" lilt must be entered into freely, fairly
and advisedly by the attorney and client."
Such relationship may "not be forced upon one
party without the consent of the other."
Pennsylvania Power & Liqht, 74 D.&C.2d at 437 (1975) (Citations
omitted). Moreover, "Pennsylvania courts have often stressed the
consensual nature of the attorney-client relationship." Connelly
v. Wolf, Block, Schorr & Solis-Cohen, 463 F.Supp. 914, 919 (E.D.
Pa. 1978).
Thus. the mere fact that Mr. Mumma relied on the
Estate's legal research and received some answers to questions
from Morgan, Lewis attorneys (as authorized by the Estate}, is
insufficient, in and of itself, to expand the basic attorney-
client relationship beyond the original scope of legal
representation as noted in the September 5, 1986 letter.
Indeed, Mr. Mumma's arguments concerning his expanded legal
representation by Morgan, Lewis are no more than unilateral
"assumptions" or "understandings" which do not overcome the very
clear and precise definition of their relationship from the very
start.
Mr. Mumma argues, however, that because he reviewed
certain documents prepared by Morgan, Lewis for the Estate,
Morgan, Lewis had expanded their legal representation of Mr.
Mumma. We do not agree. In stainton v. Tarantino. 637 F.Supp.
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NO. 1526 CIVIL 1988
1051 (E.D. Pa. 1986), the court found that an attorney-client
relationship did not arise between the attorney and his partners
in a real estate partnership even though the attorney had drafted
documents for real estate transactions from which the other
partners derived a benefit. The court stated that:
Although [the attorney] prepared some of the
legal documents in the real estate
transactions in question, he was performing
such work for himself and for the
partnership. He was not performing personal
legal services in connection with these real
estate deals for the [partners], although as
his partners in the transactions they
benefited from [the attorney's] work.
Stainton, 637 F.Supp. at 1066.
Similarly, in Pennsylvania Power & Liqht, the court
stressed that the mere reliance upon legal work performed for
another person that happened to also benefit the party seeking
disqualification, is not sufficient to establish an attorney-
client relationship. Id., at 437-438. Mr. Mumma's role, like
that in Pennsylvania Power & Liqht, was limited to reviewing and
commenting upon documents prepared for the Estate by Morgan,
Lewis. Moreover, there was no evidence that Mr. Mumma paid any
fees to Morgan, Lewis for work in connection with the
liquidations, and more importantly any "advice" he may have
received was provided to him (as well as to the other
shareholders) as a service by the Estate in an effort to persuade
him to participate voluntarily in these transactions. Finally,
we note the most telling observation is that during this hearing
held on January 25, 1989, Mr. Mumma testified repeatedly that he
knew Morgan, Lewis was the attorney for the Estate.
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NO. 1526 CIVIL 1988
In summary, then, it is clear that Mr. Mumma has failed
to carry the burden of persuasion to establish that the existence
of an attorney-client relationship extended beyond that of legal
counsel for estate planning purposes and disclaimer purposes, to
that of legal counsel representing his interests in the company
liquidations and tenancies-in-common issues.
Moving on, our next question to answer is "what is the
nature of the present lawsuit against the former client?" As
stated in our findings of fact, the Orphans' Court matter and the
Equity matter basically concerns a dispute over the sale of
certain Estate assets. More specifically, the Orphans' Court
matter focuses on two issues: 1) the interpretation of the
decedent's will, and 2) the offering of appraisal rights to Mr.
Mumma. At this point we find it necessary to note that although
Mr. Mumma seems to find some dissatisfaction with Morgan, Lewis'
implementation of the qualified disclaimer under his father's
will, Mr. Mumma does not seek to void its effect or intent.
Therefore, we find the disclaimer is not at issue or in dispute
in either of these pending matters. Thus, the issue of the
disclaimer is not "substantially related" to the issues raised in
either of the present proceedings. Consequently, Morgan, Lewis'
prior representation of Mr. Mumma with regard to the disclaimer
is not a basis for disqualification of Morgan, Lewis.
Moving on, we find that the thrust of the pending
proceedings focuses on will interpretation issues which are
clearly unrelated to Morgan, Lewis' prior representation of Mr.
Mumma. The other thrust of these proceedings focus on proposed
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NO. 1526 CIVIL 1988
corporate restructuring and the propriety of offering appraisal
rights to Mr. Mumma. These matters, then, are subjects which we
find unrelated to Morgan, Lewis' prior representation of Mr.
Mumma.
The remaining inquiry under the "substantial
relationships" test is whether during the course of his
representation, Mr. Mumma may have disclosed confidential
information to Morgan, Lewis that is now relevant to the issues
in the present lawsuits. INA Underwriters, supra. We also note,
as the court did in Realco Services, Inc. v. Holt, 479 F.Supp.
867 (E.D. Pa. 1979), that:
If a client in a prior representation might
have imparted confidential information to his
lawyer in dealing with particular issues, and
if issues arise in the second suit which
would permit the use of such confidences
aqainst the original client, the substantial
relationship test is met, and
disqualification is required.
Id., 479 F.Supp. at 871.
(Original emphasis).
In this case, though, we will not "allow [our]
imagination to run free with a view to hypothesizing conceivable
but unlikely situations in which confidential information 'might'
have been disclosed" which is relevant to the pending suits. INA
Underwriters supra. Mr. Mumma's attorney-client relationship
with Morgan, Lewis and their legal representation of Mr. Mumma's
personal estate planning and disclaimer under this father's will,
conceivably included the intimation of confidential financial
information. However, we do not believe that that type of
information is now relevant to the present lawsuits or will even
become an issue. Thus, the size of Mr. Mumma's personal assets
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NO. 1526 CIVIL 1988
assets and the size of the tax benefits be stood to gain under
the disclosure are not relevant to the present lawsuits, and
therefore do not provide a basis for disqualification under Rule
1.9 or the applicable case1aw.
CONCLUSIONS OF LAW
1. The subject matter of the pending lawsuits are not
substantially related to any prior legal representation Morgan,
Lewis provided Mr. Mumma:
2. Any confidential information Morgan, Lewis acquired
during their prior legal representation of Mr. Mumma is not now
relevant to the pending lawsuits:
3. Morgan, Lewis have not violated Rule 1.9 of the
Rules of Professional Conduct in their current representation of
the Estate of Robert M. Mumma, deceased.
In accordance with these findings of facts, discussion,
and conclusions of law, we order:
ORDER OF COURT
AND NOW, this
I J t;A.,
day of February, 1989,
defendant's motion to disqualify the law firm of Morgan, Lewis &
Bockius from legal representation of the Estate of Robert M.
Mumma, deceased, is DENIED.
By the Court,
/s/ Harold E. Sheely
P.J.
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NO. 1526 CIVIL 1988
Thomas M. Kittredge, Esquire
John F. Stillmun, III, Esquire
William F. Martson, Esquire
For the Plaintiffs
John B. Fowler, III, Esquire
Jon A. Baughman, Esquire
Anthony Vale, Esquire
For the Defendants
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