In People ex rel. Dept. of Corporations v. SpeeDee Oil Change Systems, Inc. (1999) 20 Cal. 4th 1135, the California Supreme Court held that an attorney who was "of counsel" to a law firm should be deemed to have the same status as a member of the firm for purposes of vicarious disqualification in applying rule 3-310. That case does not assist our inquiry here, for two reasons. First, SpeeDee Oil was a case of simultaneous, not successive, representation. Second, the plaintiff made a convincing evidentiary showing that the attorney whose firm was sought to be disqualified had actually obtained material information pertaining to the suit. (20 Cal. 4th at p. 1139.)