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Hodge v. UFRA-Sexton, LP
Georgia Supreme Court
758 S.E.2d 314 (2014)
UFRA-Sexton, LP (UFRA) managed an apartment complex where Monica Williams was murdered. Williams’s sister Belinda Hodge (plaintiff) hired attorney Craig Brookes to bring a wrongful-death suit against UFRA. Brookes’s paralegal Kristi Bussey was deeply involved in every aspect of the case. UFRA’s insurance company retained the firm Insley & Race, LLC (Insley) (defendant). Insley later hired Bussey as a paralegal. Neither Bussey nor Insley knew that there was a conflict of interest until a few months had passed. Bussey told her supervisors about the conflict as soon as she realized there was one, and Insley immediately put extensive screening measures into place. Insley told Brookes about the conflict months afterwards, and Brookes filed a motion to disqualify Insley. In response, Insley and Bussey filed affidavits affirming that Insley had installed extensive screening measures that would remain in place and that Bussey had not and would not work on the case or disclose any of Hodge’s confidential information. The trial court denied the motion, and Brookes appealed. The court of appeals affirmed the denial, and the Georgia Supreme Court granted certiorari.
Rule of Law
Holding and Reasoning (Hunstein, J.)
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