The following excerpt is from Amiel v. U.S., 209 F.3d 195 (2nd Cir. 1999):
Appellant's submissions tend sufficiently to show that she could have minimized her culpability by testifying and submitting certain evidence not presented at trial and that trial counsel chose not to pursue this strategy due in part to his fealty to appellant's mother. Appellant has thus alleged the occurrence of a type of lapse in representation that is an "inherent danger[]" whenever an attorney represents one party, but is paid by another. Wood v. Georgia, 450 U.S. 261, 268-69 (1981) ("One risk [when a defendant is represented by a lawyer paid for by a third-party who operates a criminal enterprise] is that the lawyer will prevent his client from obtaining leniency by preventing the client from offering testimony against [the third party] or from taking other actions contrary to [the third party's] interest.").
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