Phinney v. Phinney
The Third District reversed a non-final order disqualifying an incapacitated husband's sister (who served both as his guardian and as his limited-appearance counsel) from all phases of a dissolution proceeding because she was a necessary fact witness. The court held that Rule Regulating the Florida Bar 4-3.7 by its text applies only to acting as an advocate 'at a trial,' so a blanket disqualification covering all proceedings was an abuse of discretion; counsel may still appear in pretrial and posttrial matters.
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