California, United States of America
The following excerpt is from Uhl v. Municipal Court, 112 Cal.Rptr. 478, 37 Cal.App.3d 526 (Cal. App. 1974):
Furthermore, the mere fact that the conflict exists as to defendants in different proceedings is not a sufficiently significant distinction. Separate and distinct proceedings can pose the same problems of constitutional and ethical conflicts of interest. This fact was recognized in People v. Peters, 7 Cal.App.3d 154, 86 Cal.Rptr. 521, where private counsel was appointed to represent two defendants based on the public defender's statement that representations would create a conflict on the basis of a previously assigned case (at 160).
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