Kennedy v. Eldridge (2011) 201 Cal.App.4th 1197, involved a custody dispute in which the paternal grandfather (an attorney) sought to represent the father (i.e., the attorney's son). (Kennedy, supra, 201 Cal.App.4th at p. 1200.) The trial court granted the mother's motion to disqualify the paternal grandfather, even though neither he nor his wife (also an attorney) had ever represented the mother. (Id. at pp. 1201-1202.) The appellate court held that "an amalgamation of interrelated factors" supported the trial court's exercise of discretion. (Id. at p. 1205.) The first factor was the potential misuse of the mother's confidential information, which the paternal grandparents "may have acquired" during the course of representing the mother's father in a divorce proceeding. (Id. at pp. 1205-1206.) The close relationship between the mother and her father caused the court to treat the two individuals as "a single unity for purposes of determining whether an ethical conflict exists." (Id. at p. 1208.) Kennedy applied the "substantial relationship" test from successive representation doctrine, and concluded "the trial court could reasonably find there was a significant danger that--as a result of its prior involvement in her father's divorce case--the paternal grandparents' firm acquired relevant confidential information about the mother to which it otherwise would not have had access." (Id. at p. 1207.) Kennedy noted that the "successive representation model" does not require proof of the receipt of confidential information because such transfer of confidences is presumed. (Id. at p. 1208.) Other factors supporting the court's ruling included the possibility that the paternal grandfather would need to testify in the custody dispute (id. at p. 1209), as well as the "strong appearance of impropriety" caused by the "multiple and interconnected family entanglements" between the parties and proposed counsel (id. at p. 1211).