The following excerpt is from Heinke v. Cnty. of Tehama Sheriff's Dep't, No. CIV. S-12-2433 LKK/KJN (E.D. Cal. 2014):
19. But see, Rickley v. County of Los Angeles, 654 F.3d 950, 953 (9th Cir. 2011) (noting possible conflict of interest where trial counsel is also a percipient witness).
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