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In Re Cendant Corp. Securities Litigation

Citations: 124 F. Supp. 2d 235; 2000 U.S. Dist. LEXIS 19628; 2000 WL 1824443Docket: CV 98-1664(WHW)

Court: District Court, D. New Jersey; December 11, 2000; Federal District Court

Narrative Opinion Summary

In a complex securities litigation, Ernst & Young (E. Y) sought a declaratory judgment to allow attorney Theodore Wells to represent them despite his firm's representation of a key witness, Amy Lipton, who opposed the dual representation. The court faced the primary legal issue of potential conflict of interest under New Jersey Rules of Professional Conduct. Cendant Corporation and Ms. Lipton argued that Mr. Wells' firm's representation of both parties violated ethical rules, including Rules 1.7(a), 1.7(b), and 1.7(c), citing the direct adversity of interests and the appearance of impropriety. Despite E. Y's assertion of ethical safeguards, the court found that the proposed ethical screen was insufficient to mitigate the conflict. The court ruled that Ms. Lipton's anticipated testimony against E. Y established a direct conflict, necessitating her consent for dual representation, which she withheld. Consequently, the court denied E. Y's motion, concluding that Mr. Wells' representation would breach professional conduct standards, emphasizing the need to uphold public confidence in the legal profession. E. Y was required to seek alternative legal counsel, ensuring compliance with ethical rules. The court's decision highlighted the precedence of ethical obligations over a client's preference for specific legal representation.

Legal Issues Addressed

Appearance of Impropriety and Ethical Screens

Application: The court found that the proposed ethical screen was inadequate to dispel the appearance of impropriety under Rule 1.7(c), emphasizing that public confidence in the legal profession must be maintained.

Reasoning: Cendant contends that Paul Weiss' dual representation of Ms. Lipton and E. Y creates an appearance of impropriety due to the potential for conflicting interests, which undermines public confidence in the legal profession.

Conflict of Interest under New Jersey Rules of Professional Conduct

Application: The court addressed the issue of dual representation, finding that Ms. Lipton's testimony against E. Y. created a direct conflict of interest, thereby violating Rules 1.7(a) and 1.7(b) due to the lack of her consent for dual representation.

Reasoning: Ultimately, the court concludes that Paul Weiss's representation of E. Y would violate both Rule 1.7(a) and Rule 1.7(b) due to the material limitations imposed on the attorneys’ ability to represent their clients effectively.

Declaratory Judgment Act and Justiciable Controversy

Application: The court considered E. Y's motion as presenting a justiciable issue under the Declaratory Judgment Act, despite arguments that it raised a nonjusticiable issue, concluding that a real controversy existed based on established facts.

Reasoning: Nonetheless, the Court will consider the motion as presenting a justiciable issue.

Disqualification Standard for Legal Representation

Application: The court determined that disqualification of Mr. Wells was necessary to prevent potential breaches of loyalty and confidentiality, emphasizing that a client’s right to counsel is subordinate to maintaining professional standards.

Reasoning: The court emphasizes that disqualification of Mr. Wells is necessary to uphold professional conduct rules, despite potential impacts on attorney mobility.