In Brown v. Kelton,  2011 Ark. 93 (Mar. 3, 2011),  the Supreme Court of Arkansas affirmed an order disqualifying a staff attorney employed by Farmers Insurance Exchange (“FIE”) from representing two defendants who were insured by an insurance company that was reinsured by FIE. The two defendants were sued following an automobile accident.   The defense attorney representing the defendants filed a motion for substitution of counsel, seeking to substitute in Stephen Brown, an attorney employed by FIE. Both defendants consented to the substitution.   The claimant’s counsel filed a motion to disqualify Brown. The circuit court found that Brown’s representation of the two defendants would have constituted the unauthorized practice of law by FIE pursuant to Ark. Code Ann. § 16

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