p0057 REVIEW GRANTED Collaboration on a few matters is not sufficient to make two lawyers a firm or to establish that they are associates, so an agreement between them to split fees without the client's express consent is unenforceable; if a fee sharing agreement is unenforceable because it was made without the express consent of the client, the lawyers are not entitled to quantum meruit recovery from each other for the value of services rendered.

CHAMBERS v KAY (Fee Splitting) 88 CA4 903 [See: CA R/PC 2-200; CCP 337, 339; Weeks v Baker & McKenzie 63 CA4 1128, T/AT 6/98; Sims v Charness 86 CA4 884; Scolinos v Kolts 37 CA4 635, T/AT 10/95]