In re Lee
United States Bankruptcy Court for the Central District of California
94 B.R. 172 (1989)
The Lees (debtors), sole shareholders of their company Seoul Corporation (Seoul) (debtor), filed separate Chapter 11 cases — Seoul's reorganization followed by the Lees' own personal case — with overlapping creditors and joint liability on many shared debts; both the Lees and Seoul sought representation by the same law firm, which filed parallel applications for appointment as counsel in both cases while intentionally withholding the related nature of the two filings and affirming in each application that it had no connection to any other interested party besides the debtor. The bankruptcy court discovered the parallel, undisclosed applications and issued an order to show cause why the firm shouldn't be disqualified from representing both parties.
Whether a law firm may represent debtors in related but separate bankruptcy cases involving overlapping creditors and joint liability, particularly where the firm concealed the parallel nature of its representation from the court.