Guardian Storage Centers, LLC v. Simpson (2026) G064847; filed 3/24/26. ![[Files/CaseFiles/G064847.PDF]] [Opinion PDF](https://www.courts.ca.gov/opinions/archive/G064847.PDF) ## Rule excerpts Unauthorized disclosure of privileged material; extending the State Fund rule. Disqualification was remanded for reconsideration. > When a lawyer receives material that the lawyer knows or reasonably should know is attorney-client privileged or subject to the work product doctrine, and it is reasonably apparent the material was impermissibly taken from the privilege holder without authorization, the lawyer receiving such material should refrain from examining the material any more than is essential to ascertain if it is privileged or subject to the work product doctrine, and shall immediately notify the privilege holder that they possesses the material. The parties may then seek to resolve any resulting disagreement through the courts. — Guardian Storage Centers, LLC v. Simpson (2026), slip op., p. 21.