In Mink v. Maccabee (2004) 121 Cal.App.4th 835, an attorney (Maccabee) sued another attorney (Mink) for a referral fee (by way of a cross-complaint) and, to be sure, for quantum meruit, but the trial court threw the case out on demurrer because the client hadn't given consent to the division of fees until several months after the case referred had been completed. Moreover, the underlying case had indeed been quite profitable for the attorney to whom it had been referred, generating for him about $ 400,000 in compensation. (Mink, supra, 121 Cal.App.4th at p. 837, fn. 1.) The basis of the demurrer was the "belated acknowledgement and consent" of the client, and the first part of the opinion's published analysis -- the part dealing with belated acknowledgements -- was devoted solely to rule 2-200. (Id. at p. 837.) The last three paragraphs of the published analysis approved the quantum meruit claim by simply noting that the Supreme Court had said (in Huskinson & Brown v. Wolf (2004) 32 Cal.4th 453) that even if a lawyer could not, because of a total absence of consent, recover a fee-splitting arrangement as a matter of contract, the lawyer could still bring a claim in quantum meruit. (Mink, supra, 121 Cal.App.4th at pp. 838-839.) Against that point, the defendant had claimed on demurrer that the quantum meruit claim was nothing but a "'subterfuge to recover a prohibited referral fee,'" but that argument could not avail on demurrer, where the trial court is not allowed to make "any factual findings at all, including 'implicit' ones.'" (Id. at p. 839.)