California, United States of America
The following excerpt is from People v. Tibbs, F070831 (Cal. App. 2016):
Another example of a conflict of interest arose in People v. Almanza (2015) 233 Cal.App.4th 990, 1002. The appellate court found a conflict of interest existed when the prosecutor threatened, before trial, to prosecute both the defense investigator and defense counsel because the defense investigator was apparently not licensed. "Any trial counsel in a criminal case who is worried that the prosecutor is scrutinizing his or her actions for possible criminal investigation and prosecution has a conflict with the interest of representing the client zealously - he or she does not want to antagonize the prosecutor." (Ibid.)
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