Plaintiffs sued after defendants, whose counsel plaintiffs sought to disqualify, allegedly breached their fiduciary duty to China Buddhist Association (CBA) by removing plaintiffs and other board members from CBA's bank accounts and failing to provide account statements to plaintiffs upon their request.

Manhattan Supreme Court Justice Lyle Frank had to determine whether law firm Bill Zou & Associates, as a previous attorney for CBA, should be disqualified as counsel for defendant Wang.