1 SCOTT D.

WOLFE
2029 Morley Street
2 Simi Valley, CA 93065
3
818-581-1111
4
Defendant in Pro Per
5

9 SUPERIOR COURT OF CALIFORNIA COUNTY OF LOS ANGELES

10

11
Scott D. Wolfe, ) Case No. 21CHCV00382
12 )
) NOTICE OF MOTION AND MOTION;
13 Plaintiff, ) MEMORANDUM OF POINTS AND
) AUTHORITIES; AND DECLARATION OF
14 vs. ) SCOTT D. WOLFE IN SUPPORT OF
) MOTION TO DISQUALIFY DEFENDANTS
15
Justin R. Wolfe, The Estate of Bruce P. Wolfe )) COUNSEL RANDOLPH M. SHARON, ESQ.
16 ) FOR EGREGIOUS CONFLICT OF
Justin R. Wolfe (Trustee), Haley Ashley, And ) INTEREST, VIOLATIONS OF ATTORNEY-
17 ) CLIENT PRIVILEGES, AND SANCTIONS.
all John & Jane Does 1-100 )
18 ) Hearing Date: 11/10/2021
TIME: 8:30 AM
19 Defendant's
DEPT: F49
20 Date action filed: 1/14/2021
Trial Date: None
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RESERVATION ID 040224225557
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23
TO: EACH PARTY:
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PLEASE TAKE NOTICE, AND YOU ARE HEREBY NOTIFIED that on November 10,
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2021, at 8:30 a.m. or as soon thereafter as the matter may be heard, in Department F49 may be heard,
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27 in Department F49 of the above-entitled Court, located at 9425 Penfield Avenue, Chatsworth,

28 California 91311, the Plaintiff Scott D. Wolfe will, and hereby does move for an order to compelling
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MOTION TO DISQUALIFY DEFENDANTS COUNSEL RANDOLPH M. SHARON, ESQ

 1 defendant Justin R. Wolfe's counsel Randolph M. Sharron to be immediately removed from this

2 litigation and a restraining order put in place to prevent Randolph M. Sharron, Esq. from disclosing
3
any and all information, work product, etc. in this case or information pertaining to the Plaintiff Scott
4
D. Wolfe. Plaintiff also requests that this honorable Court turn this matter over to the California Bar
5
Association for further actions.
6

7 Plaintiff, Scott D. Wolfe, will also move the Court for an order that Randolph M. Sharon,

8 Esq., pay the moving party the sum of $5,000.00 as a reasonable cost to hire a new attorney to
9
unwind Randolph M. Sharon, Esq. as his counsel, financial power of attorney, medical power of
10
attorney, etc.
11
This motion is made on the grounds that Randolph M. Sharon, Esq. has violated the Faith and
12

13 Trust that is the hallmark of the client-lawyer relationship. The motion will be based upon this notice,

14 the attached Memorandum of Points and Authorities in support, the declaration of Scott D. Wolfe,
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and the attached exhibits.
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17
Date: October 5, 2021
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19

20 By: ___________________________
Scott D. Wolfe
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Defendant, In Pro Per
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MOTION TO DISQUALIFY DEFENDANTS COUNSEL RANDOLPH M. SHARON, ESQ

 1 MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT FOR ORDER

2 COMPELLING RANDOLPH M. SHARON, ESQ. TO BE REMOVED AS DEFENDANT(S)

3
COUNSEL AND FOR MONETARY SANCTIONS
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5
I.
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7 PRELIMINARY STATEMENT

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Scott D. Wolfe, Plaintiff, ("Moving Party") hereby submits their memorandum of points and
9

10 authorities in support of this motion seeking an order to immediately remove Justin R. Wolfe,

11 ("defendant") counsel Randolph M. Sharon, Esq. from this case, place an immediate restraining order
12
preventing Randolph M. Sharon, Esq. from discussing, disclosing any and all information, work
13
product, etc. in this case or information any and all information pertaining to the Plaintiff Scott D.
14
Wolfe. Plaintiff also requests that this honorable Court turn this matter over to the California Bar
15

16 Association for further actions. Plaintiff Scott D. Wolfe is also asking for sanctions against Randolph

17 M. Sharon, Esq. There are enormous expenses the Plaintiff Scott D. Wolfe will incur to unwind
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Randolph M. Sharon, Esq. as his counsel, financial power of attorney, medical power of attorney, etc.
19
Through the attached exhibits A through D, the Court is presented with documents supporting
20
this motion, that Randolph M. Sharon, Esq. was fully aware that he should not have been
21

22 representing the defendant(s) in this matter. As Randolph M. Sharon, Esq. has a preexisting

23 relationship with Plaintiff Scott D. Wolfe that would violate the California Rules of Professional
24 Conduct, including but not limited to attorney-client privilege and conflict of interest.
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MOTION TO DISQUALIFY DEFENDANTS COUNSEL RANDOLPH M. SHARON, ESQ

 1 II.

2 MEMORANDUM OF POINTS AND AUTHORITIES

3
1. Randolph M. Sharon, Esq. violated The California State Bar Rules of Professional
4
Conduct Rule 3-100 "Confidential Information of a Client (A) A member shall not reveal
5
information protected from disclosure by Business and Professions Code section 6068, subdivision
6

7 (e)(1) without the informed consent of the client... Plaintiff Scott D. Wolfe has never given Randolph

8 M. Sharon consent to represent the defendants in this matter.

9
Randolph M. Sharon, Esq. shared office space with my father, Bruce P. Wolfe, Esq. He had
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an agreement of time for space in the Law Center building that my father owned located at 14120
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Victory Blvd. Van Nuys, CA 91401. During the multiple years he shared office space with my father,
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13 he was part of my legal team that involved personal and business transactions requiring legal

14 guidance. Randolph M. Sharon, Esq. had full access to all client files in my father's Law Center
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building, including all closed files as they were stored on the same property. Please refer to Exhibit
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A: the cover page and the table of contents of Plaintiff Scott D. Wolfe's Declaration of Trust, where it
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is printed on the letterhead of Randolph M. Sharon. This shows the Court the first of many exhibits
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19 that Randolph M. Sharon, Esq. has intentionally violated multiple sections of The California State

20 Bar Rules of Professional Conduct. EVEN AFTER CHANGING OFFICE LOCATIONS, Randolph
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M. Sharon, Esq. continued to have unfettered access to the Law Center Building.
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Randolph M. Sharon, Esq. was the brother-in-law of Plaintiff and Defendants father Bruce P.
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Wolfe, making him the Uncle of both Plaintiff and Defendant. With the family relationship, intimate
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25 legal representation, and full access to all Plaintiff Scott D. Wolfe's legal files, Randolph M. Sharon,

26 Esq., is and has used this information to the Defendants advantage from the beginning of his
27 representation of Justin R. Wolfe and the Estate of Bruce P. Wolfe in this matter.
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MOTION TO DISQUALIFY DEFENDANTS COUNSEL RANDOLPH M. SHARON, ESQ

 1 Randolph M. Sharon, Esq. discussed with Plaintiff Scott D. Wolfe on several occasions as his

2 counsel the investments that were comingled with his father Bruce P. Wolfe and assured Plaintiff
3
Scott D. Wolfe that he knows his father made arrangements if something happened to him that he
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would receive his portion of the investments and never to worry about it. This conversation was
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specifically discussed on or about September / October of 2000 when Randolph M. Sharon, Esq. was
6

7 putting the Trust together for Plaintiff Scott D. Wolfe. Randolph M. Sharon, Esq. having firsthand

8 knowledge of the monies that are now in question leaves the only conclusion that Randolph M.
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Sharon, Esq. violated The California State Bar Rules of Professional Conduct Rule 5-220
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Suppression of Evidence, "A member shall not suppress any evidence that the member or the
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member's client has a legal obligation to reveal or to produce." All the documentation that was in
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13 possession of Plaintiff's father, Bruce P. Wolfe, prior to his death has vanished. Defendant Justin R.

14 Wolfe refused entry of Plaintiff Scott D. Wolfe into their fathers home prior to and after his death
15
(See Exhibit D) could have only been advised directly or indirectly by his counsel to modify or
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dispose of any documentation, wills, trusts, etc. that spelled out Plaintiff Scott D. Wolfe comingled
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investments with his father.
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19 This action is further solidified by Randolph M. Sharon's refusal to turn over any requested

20 documents in Set One or Set Two of the request for documents. A motion to produce the documents
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has been set for November 15, 2021, at the Los Angeles County Court (Chatsworth Court) located
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9425 Penfield Avenue, Chatsworth, California 91311, in department F49. Randolph M. Sharon, Esq.
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has a duty of confidentiality. The California State Bar Rules of Professional Conduct Paragraph
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25 (A) of Rule 3-100 relates to a member's obligations under Business and Professions Code section

26 6068, subdivision (e)(1), which provides it is a duty of a member: "To maintain inviolate the
27 confidence, and at every peril to himself or herself to preserve the secrets, of his or her client." A
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MOTION TO DISQUALIFY DEFENDANTS COUNSEL RANDOLPH M. SHARON, ESQ

 1 member's duty to preserve the confidentiality of client information involves public policies of

2 paramount importance. (In Re Jordan (1974) 12 Cal.3d 575, 580 [116 Cal. Rptr. 371].) Preserving
3
the confidentiality of client information contributes to the Trust that is the hallmark of the client-
4
lawyer relationship. The responsibility of Trust extends beyond an attorney repeating information
5
disclosed by a client to using the information disclosed against the client when he represents a
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7 different party against the original client. This is precisely why the California State Bar created Rules

8 of Professional Conduct.
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2. Randolph M. Sharron, Esq. has violated The California State Bar Rules of
10
Professional Conduct Rule 1.7 (a) "A lawyer shall not, without informed written consent* from each
11
client and compliance with paragraph (d), represent a client if the representation is directly adverse to
12

13 another client in the same or a separate matter." The California State Bar Rules of Professional

14 Conduct Rule 1.7 (c) 'A lawyer shall not represent a client without written* disclosure of the
15
relationship to the client and compliance with paragraph (d) where: (1) the lawyer has, or knows* that
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another lawyer in the lawyer's firm* has, a legal, business, financial, professional, or personal
17
relationship with or responsibility to a party or witness in the same matter. Within The California
18

19 State Bar Rules of Professional Conduct Rule 1.7 Comments (2) states, "Paragraphs (a) and (b)

20 apply to all types of legal representations, including the concurrent representation of multiple parties
21
in litigation or in a single transaction or in some other common enterprise or legal relationship."
22
Exhibit B; The Will And Testament of (Plaintiff) Scott D. Wolfe on page 4 (Tenth) states, "I
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nominate Randolph M. Sharon, to serve as my Executor." Randolph M. Sharon, Esq. cannot state he
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25 was not aware of this arrangement as he was the attorney that constructed and wrote Plaintiff Scott D.

26 Wolfe's will; page one is printed on the letterhead of Randolph M. Sharon, Esq. and was witnessed by
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MOTION TO DISQUALIFY DEFENDANTS COUNSEL RANDOLPH M. SHARON, ESQ

 1 Randolph M. Sharon, Esq. spouse Helayne B. Sharon, who works with Mr. Sharon to present as she

2 has signed every proof of service Mr. Sharon has produced in this matter.
3
In the case of Flatt v. Superior Court (1994) 9 Cal.4th 275 [36 Cal.Rptr.2d 537] states, "A
4
lawyer may not act as an advocate in one matter against a person the lawyer represents in some other
5
matter, even when the matters are wholly unrelated." This case clearly explains that Randolph M.
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7 Sharon, Esq. cannot represent Defendant Justin R. Wolfe or the estate of Bruce P. Wolfe in this

8 matter.
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3. Randolph M. Sharron, Esq. has violated The California State Bar Rules of
10
Professional Conduct Rule 3-310 (B) (3) "The member has or had a legal, business, financial,
11
professional, or personal relationship with another person or entity the member knows or reasonably
12

13 should know would be affected substantially by resolution of the matter."

14 Exhibit C; The Uniform Statutory Form Power of Attorney of (Plaintiff) Scott D. Wolfe on
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page 3 it states, "Randolph M. Sharon shall act as my agent under this power of attorney." Randolph
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M. Sharon, Esq. cannot state he was not aware of this arrangement as he was the attorney that
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constructed and wrote Plaintiff Scott D. Wolfe's will; page one is printed on the letterhead of
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19 Randolph M. Sharon, Esq. and Mr. Sharon was also the Notary Public (Commission #1209016) of

20 exhibit C, the Uniform Statutory Form Power of Attorney of (Plaintiff) Scott D. Wolfe. The court
21
case of State Farm Mutual Automobile Insurance Company v. Federal Insurance Company (1999)
22
72 Cal.App.4th 1422 [86 Cal.Rptr.2d 20], the Court held that paragraph (C)(3) of predecessor rule 3-
23
310 was violated when a lawyer, retained by an insurer to defend one suit, and while that suit was
24

25 still pending, filed a direct action against the same insurer in an unrelated action without securing the

26 insurer's consent. Notwithstanding State Farm, paragraph (a) does not apply with respect to the
27 relationship between an insurer and a lawyer when, in each matter, the insurer's interest is only as an
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MOTION TO DISQUALIFY DEFENDANTS COUNSEL RANDOLPH M. SHARON, ESQ

 1 indemnity provider and not as a direct party to the action. "Even where there is no direct adversity, a

2 conflict of interest requiring informed written consent under paragraph (b) exists if there is a
3
significant risk that a lawyer's ability to consider, recommend or carry out an appropriate course of
4
action for the client will be materially limited as a result of the lawyer's other responsibilities,
5
interests, or relationships, whether legal, business, financial, professional, or personal."
6

7 Randolph M. Sharon, Esq. has violated The California State Bar Rules of Professional

8 Conduct Rule 3-310 (C) (2), (C) (3), and (E). The California State Bar Rules of Professional
9
Conduct Rule 3-310 (C) states, "A member shall not, without the informed written consent of each
10
client:" (Mr. Sharon has never been granted written consent from Plaintiff). The California State Bar
11
Rules of Professional Conduct Rule 3-310 (C) (2) and (3) state, "Accept or continue representation
12

13 of more than one client in a matter in which the interests of the clients actually conflict; or Represent

14 a client in a matter and at the same time in a separate matter accept as a client a person or entity
15
whose interest in the first matter is adverse to the client in the first matter." As stated in Exhibit B
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and C, Randolph M. Sharon, Esq. continues to represent the interest of Plaintiff Scott D. Wolfe, and
17
there is no question that a conflict exists that prevents him from representing the defendants in this
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19 matter.

20 The California State Bar Rules of Professional Conduct Rule 3-310 (D) states, "A member
21
shall not, without the informed written consent of the client or former client, accept employment
22
adverse to the client or former client where, by reason of the representation of the client or former
23
client, the member has obtained confidential information material to the employment." Randolph M.
24

25 Sharon has received confidential material related to Plaintiff Scott D. Wolfe. Within the discussion of

26 The California State Bar Rules of Professional Conduct Rule 3-310 Discussion states, "While
27 paragraph (B) deals with the issues of adequate disclosure to the present client or clients of the
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MOTION TO DISQUALIFY DEFENDANTS COUNSEL RANDOLPH M. SHARON, ESQ

 1 member's present or past relationships to other parties or witnesses or present interest in the subject

2 matter of the representation, paragraph (E) is intended to protect the confidences of another present or
3
former client. These two paragraphs are to apply as complementary provisions."
4
Due to the type of relationship, Client, Entrustment of Financial and Medical Decisions, the
5
Plaintiff Scott D. Wolfe has entrusted in Randolph M. Sharon, Esq. excludes Randolph M. Sharon,
6

7 Esq. from representing the Defendants in this matter. "There are some matters in which the conflicts

8 are such that even informed written consent may not suffice to permit representation." (See Woods v.
9
Superior Court (1983) 149 Cal.App.3d 931 [197 Cal. Rptr. 185]; Klemm v. Superior Court (1977)
10
75 Cal.App.3d 893 [142 Cal.Rptr. 509]; Ishmael v. Millington (1966) 241 Cal.App.2d 520 [50 Cal.
11
Rptr. 592].)
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MOTION TO DISQUALIFY DEFENDANTS COUNSEL RANDOLPH M. SHARON, ESQ

 1 III

2 POINTS OF AUTHORITY
3
California Business and Professions Code
4
A. Bus & Prof Code § 6068 (2017) (e) (1) "To maintain inviolate the confidence, and at every
5
peril to himself or herself to preserve the secrets, of his or her client."
6

7 The California State Bar Rules of Professional Conduct

8 A. The California State Bar Rules of Professional Conduct Rule 3-100 "Confidential
9
Information of a Client (A) "A member shall not reveal information protected from
10
disclosure by Business and Professions Code section 6068, subdivision (e)(1) without the
11
informed consent of the client, …."
12

13 B. The California State Bar Rules of Professional Conduct Rule 5-220 Suppression of

14 Evidence, "A member shall not suppress any evidence that the member or the member's client
15
has a legal obligation to reveal or to produce."
16
C. The California State Bar Rules of Professional Conduct Rule 1.7 (a) "A lawyer shall not,
17
without informed written consent* from each client and compliance with paragraph (d),
18

19 represent a client if the representation is directly adverse to another client in the same or a

20 separate matter."
21
D. The California State Bar Rules of Professional Conduct Rule 1.7 (c) 'A lawyer shall not
22
represent a client without written* disclosure of the relationship to the client and compliance
23
with paragraph (d) where: (1) the lawyer has, or knows* that another lawyer in the lawyer's
24

25 firm* has, a legal, business, financial, professional, or personal relationship with or

26 responsibility to a party or witness in the same matter.

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MOTION TO DISQUALIFY DEFENDANTS COUNSEL RANDOLPH M. SHARON, ESQ

 1 E. The California State Bar Rules of Professional Conduct Rule 1.7 Comments (2) states,

2 "Paragraphs (a) and (b) apply to all types of legal representations, including the concurrent
3
representation of multiple parties in litigation or in a single transaction or in some other
4
common enterprise or legal relationship.
5

6 F. The California State Bar Rules of Professional Conduct Rule 3-310 (B) (3) "The member
7
has or had a legal, business, financial, professional, or personal relationship with another
8
person or entity the member knows or reasonably should know would be affected
9
substantially by resolution of the matter."
10

11 G. The California State Bar Rules of Professional Conduct Rule 3-310 (C) states, "A member
12
shall not, without the informed written consent of each client:"
13

14 H. The California State Bar Rules of Professional Conduct Rule 3-310 (C) (2) and (3) state,

15 "Accept or continue representation of more than one client in a matter in which the interests
16
of the clients actually conflict; or Represent a client in a matter and at the same time in a
17
separate matter accept as a client a person or entity whose interest in the first matter is adverse
18
to the client in the first matter."
19

20 I. The California State Bar Rules of Professional Conduct Rule 3-310 (D) states, "A member

21 shall not, without the informed written consent of the client or former client, accept
22
employment adverse to the client or former client where, by reason of the representation of
23
the client or former client, the member has obtained confidential information material to the
24
employment."
25

26 J. The California State Bar Rules of Professional Conduct Rule 3-310 Discussion states,

27 "While paragraph (B) deals with the issues of adequate disclosure to the present client or
28
clients of the member's present or past relationships to other parties or witnesses or present
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MOTION TO DISQUALIFY DEFENDANTS COUNSEL RANDOLPH M. SHARON, ESQ

 1 interest in the subject matter of the representation, paragraph (E) is intended to protect the

2 confidences of another present or former client. These two paragraphs are to apply as
3
complementary provisions.
4
Case Law
5
A. (Woods v. Superior Court (1983) 149 Cal.App.3d 931 [197 Cal. Rptr. 185] "There are some
6

7 matters in which the conflicts are such that even informed written consent may not suffice to

8 permit representation.
9
B. Klemm v. Superior Court (1977) 75 Cal.App.3d 893 [142 Cal.Rptr. 509] "There are some
10
matters in which the conflicts are such that even informed written consent may not suffice to
11
permit representation."
12

13 C. Ishmael v. Millington (1966) 241 Cal.App.2d 520 [50 Cal. Rptr. 592].) "There are some

14 matters in which the conflicts are such that even informed written consent may not suffice to
15
permit representation.
16
D. Re Jordan (1974) 12 Cal.3d 575, 580 [116 Cal.Rptr. 371]. "Preserving the confidentiality of
17
client information contributes to the Trust that is the hallmark of the client-lawyer
18

19 relationship. The responsibility of Trust extends, beyond an attorney repeating information

20 disclosed by a client to using the information disclosed against the client when he represents a
21
different party against the original client."
22
E. Flatt v. Superior Court (1994) 9 Cal.4th 275 [36 Cal.Rptr.2d 537] states, "A lawyer may
23
not act as an advocate in one matter against a person the lawyer represents in some other
24

25 matter, even when the matters are wholly unrelated."

26 F. In State Farm Mutual Automobile Insurance Company v. Federal Insurance Company

27 (1999) 72 Cal.App.4th 1422 [86 Cal.Rptr.2d 20], "the Court held that paragraph (C)(3) of
28

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MOTION TO DISQUALIFY DEFENDANTS COUNSEL RANDOLPH M. SHARON, ESQ

 1 predecessor rule 3-310 was violated when a lawyer, retained by an insurer to defend one suit,

2 and while that suit was still pending, filed a direct action against the same insurer in an
3
unrelated action without securing the insurer's consent. Notwithstanding State Farm,
4
paragraph (a) does not apply with respect to the relationship between an insurer and a lawyer
5
when, in each matter, the insurer's interest is only as an indemnity provider and not as a direct
6

7 party to the action. "Even where there is no direct adversity, a conflict of interest requiring

8 informed written consent under paragraph (b) exists if there is a significant risk that a lawyer's
9
ability to consider, recommend or carry out an appropriate course of action for the client will
10
be materially limited as a result of the lawyer's other responsibilities, interests, or
11
relationships, whether legal, business, financial, professional, or personal."
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MOTION TO DISQUALIFY DEFENDANTS COUNSEL RANDOLPH M. SHARON, ESQ

 1 IV.

2 CONCLUSION
3
The relationship the Plaintiff Scott D. Wolfe shares with the Defendants counsel Randolph M.
4
Sharon, Esq. is extremely intimate and personal as Plaintiff has entrusted Mr. Sharon to make
5
financial and life and death decisions on his behalf if he became incapacitated or unable to make
6

7 these types of decisions. "There are some matters in which the conflicts are such that even informed

8 written consent may not suffice to permit representation." (See Woods v. Superior Court (1983) 149
9
Cal.App.3d 931 [197 Cal. Rptr. 185]; Klemm v. Superior Court (1977) 75 Cal.App.3d 893 [142
10
Cal.Rptr. 509]; Ishmael v. Millington (1966) 241 Cal.App.2d 520 [50 Cal. Rptr. 592].)
11

12

13

14 Date: October 5, 2021

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16
By: _______________________________
17 Scott D. Wolfe
Defendant, In Pro Per
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MOTION TO DISQUALIFY DEFENDANTS COUNSEL RANDOLPH M. SHARON, ESQ

 1 DECLARATION OF SCOTT D. WOLFE IN SUPPORT FOR ORDER COMPELLING

2 RESPONSES TO DISCOVERY REQUEST AND MONETARY SANCTIONS

3

4
I, Scott D. Wolfe, declare:
5

6 1. I am the defendant in the above-entitled action.

7
2. On October 5, 2021, I served my Randolph M. Sharon, Esq., Justin R. Wolfe, The Estate of
8

9
Bruce P. Wolfe, Justin R. Wolfe (Trustee), Haley Ashley with a notice of motion and motion;

10 memorandum of points and authorities; and declaration of Scott D. Wolfe in support of the

11 motion to remove defendants counsel Randolph M. Sharon, Esq. for egregious conflict of
12
interest, violations of attorney-client privileges and sanctions.
13
3. The statements made in this motion are true and accurate.
14

15 4. The Exhibits in this motion are genuine and accurate, as some have my signature from the

16 date the original document was created.

17
5. I ask that the court award sanctions of $5,00.00. I based my request for the imposition of a
18
sanction on the basis that to attain new counsel and create a new Trust, Will, Financial Power
19
of Attorney, and Medical Power of Attorney will cost $5,000.00.
20

21 I declare under penalty of perjury under the law of California that the foregoing is true and

22 correct.
23
Date: October 5, 2021
24
By:__________________________
25 Scott D. Wolfe
Defendant, In Pro Per
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MOTION TO DISQUALIFY DEFENDANTS COUNSEL RANDOLPH M. SHARON, ESQ