Bill Freivogel has been busy indeed spotting interesting updates!Presented with our thanks are several of his April highlights:

• Chaowai 101 AOA LLC v. 101 A of A LLC, 2026 NY Slip Op 31493(U) (N.Y. S. Ct. N.Y. County April 9, 2026).
  • “Very complicated LLC ownership case. Law Firm started representing an LLC that owned a NYC building. Resulting from a number of disagreements, Law Firm wound up not representing the LLC/owner, but representing a prospective new member of the LLC/owner. LLC/owner moved for Law Firm to turn over its files relating to this matter and to disqualify Law Firm from representing the new LLC member”
  • “In this Order the justice ordered Law Firm to turn over certain of its files, but not others, and ordered Law Firm not disqualified from representing the new LLC member.”
• In re Arbit, 2026 WL 1078065 (Fed. Cir. April 21, 2026).
  • “Individuals A, B, and C are ‘named inventors’ of the patent in question (‘the Patent’). C filed this case against A and B ‘for correction of inventorship,’ to establish C as the sole inventor of the Patent. Evidently, A and B would like to sell their interest in the Patent to Lincoln Diagnostics (‘Lincoln’).”
  • “Lincoln is paying A and B’s legal fees for this case. When C learned of Lincoln’s role, C moved to disqualify the law firm (‘Law Firm’) for A and B. C did not claim he was a former client of Law Firm.
  • “The magistrate judge granted the motion to disqualify, and the district judge affirmed. In this Order the Federal Circuit denied A and B’s petition for mandamus (affirmed the district court). The court discussed primarily N.J. Rule 1.8(f)(2), which deals with abuses from litigants’ accepting compensation from non-parties. [Our note: No one raised or discussed standing. We get how these payment arrangements can be abused, but nowhere has C shown how this arrangement threatens the fair administration of justice, or how he is otherwise prejudiced.]”
• N.L. v. J.D, 2026 NBKB 77 (CanLII) (Ct. K.B. N.B. April 20, 2026).
  • “Mother and Father are litigating an issue relating to their child. Lawyer, at Firm 1, represented Mother for several months. Lawyer then moved to Firm 2, which represents Father.”
  • “Mother moved to disqualify Firm 2. In this Decision the court denied the motion. Before Lawyer’s move, Firm 2 began erecting a screen between Lawyer and the lawyers representing Father including instructing personnel on their contacts with each other, maintaining locked files and so forth, all in compliance with New Brunswick Rule 3.4-20.
• Boyd v. H&R Accounts, Inc., No. 25-12834 (E.D. Mich. April 17, 2026).
  • “Plaintiff, represented by Lawyer, is suing a debt collection agency (‘H&R’) for violating debt collection laws. H&R moved to disqualify Lawyer because Lawyer had previously represented debt collection agencies affiliated with H&R in matters substantially related to this one.”
  • “In this thoughtful and comprehensive opinion the court granted the motion to disqualify. Lawyer had never represented ‘directly’ H&R or its corporate parent. However H&R has been a member of a closely related collection of agencies, a several of which Lawyer has represented in a number of cases.”
  • “The issues in those cases were largely similar to the issues here. A number of corporate officials have overlapped with various of these agencies, including the ‘Chief Compliance Officer,’ with whom Lawyer has worked closely. In short, ‘the Court finds that no amount of effective and careful lawyering can obviate the concerns raised in this case.’”
• Pan-Oceanic Eng’g Co., Inc. v. Grange Mut. Ins., 2026 IL App (1st) 250511-U (Ill. App. April 14, 2026).
  • “Illinois prohibits casualty insurers from insuring punitive damages in many situations. In this case an insured went to trial in a vehicle accident case facing claims of compensatory and punitive damages. One of several issues was whether the insurer’s retained ‘panel counsel’ (‘Lawyer’) had a conflict of interest.”
  • “In this opinion the appellate court described the ways Lawyer did have a conflict. Lawyer had previously alerted the insured of the advisability of hiring independent counsel, but the insured agreed to allow Lawyer to proceed for insured.”
  • “The court held, given the conflict, the insurer must pay Lawyer an hourly rate greater than that of panel counsel. We are not giving you the full picture, given the limitations of this site. The court’s discussion is totally about Illinois insurance law and seems of limited use elsewhere.”