What is the duty of loyalty of an attorney who seeks to represent clients who are adversaries?

We also discussed the duty of loyalty that applies where an attorney seeks to represent clients who are adversaries: "Where the duty of loyalty applies, it requires a per se, or automatic disqualification, in all but a few instances. (Flatt v. Superior Court, supra, 9 Cal.4th at p. 284.) 'The reason for [the per se] rule is evident, even (or perhaps especially) to the nonattorney. A client who learns that his or her lawyer is also representing a litigation adversary, even with respect to a matter wholly unrelated to this

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one for which counsel was retained, cannot long be expected to sustain the level of confidence and trust in counsel that is one of the foundations of the professional relationship. All legal technicalities aside, few if any clients would be willing to suffer the prospect of their attorney continuing to represent them under such circumstances. As one commentator on modern legal ethics has put it: "Something seems radically out of place if a lawyer sues one of the lawyer's own present clients in behalf of another client. Even if the representations have nothing to do with each other, so that no confidential information is apparently jeopardized, the client who is sued can obviously claim that the lawyer's sense of loyalty is askew." [Citation.] It is for that reason, and not out of concerns rooted in the obligation of client confidentiality, that courts and ethical codes alike prohibit an attorney from simultaneously representing two client adversaries, even where the substance of the representations are unrelated.' (Flatt v. Superior Court, supra, 9 Cal.4th at p. 285, fn. omitted.)" (Metro-Goldwyn-Mayer, supra, 36 Cal.App.4th at p. 1840, fn. omitted.)