The following excerpt is from U.S. v. Iorizzo, 786 F.2d 52 (2nd Cir. 1986):
Thus, once the defendant establishes that there was an actual conflict, he need not prove prejudice, but simply that a "lapse in representation," Cuyler v. Sullivan, 446 U.S. 335, 349, 100 S.Ct. 1708, 1718-19, 64 L.Ed.2d 333 (1980), resulted from the conflict.
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