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The propriety of one attorney representing several clients whose conduct is under investigation by a grand jury has been explored only superficially by the courts and the American Bar Association's Code of Professional Responsibility. Prosecutors nonetheless have often moved to disqualify counsel representing multiple clients in recent years, basing their motions both on the client's interest in loyal and competent representation and on the government's interest in the unimpeded progress of the grand jury investigation. Professor Tague discusses the factors that counsel should consider in deciding whether to undertake multiple representation at the grand jury stage, including strategy, ethics, and the doctrinal grounds for disqualification. He concludes that, while the motion to disqualify should rarely be granted, multiple representation is a risky venture that should rarely be undertaken.

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17 Am. Crim. L. Rev. 301-339 (1980)