The following excerpt is from U.S. v. Seguame, 50 F.3d 18 (9th Cir. 1995):
We reject this theory. The fact that an attorney had "personal adversity" arising from flaws in his legal representation does not reveal that he is "beset with conflicting interests prejudicial" to his client, nor does it place the lawyer "in an adversarial relationship" with the client. United States v. Mouzin, 785 F.2d 682, 699 (9th Cir.), cert. denied, 479 U.S. 985 (1986); United States v. Jimenez, 928 F.2d 356, 362 (10th Cir.) (finding no actual conflict of interest arising from the possibility that an attorney would be held in criminal contempt for improper dissemination of grand jury materials), cert. denied, 502 U.S. 854 (1991); United States v. Logan, 998 F.2d 1025, 1029 (D.C.Cir.) (rejecting the argument that repeated confrontations between trial counsel and the court, resulting in a finding of contempt, created a conflict of interest), cert. denied, 114 S.Ct. 569 (1993).
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