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PEOPLE v. HOVAN

2713, 2557/13.

146 A.D.3d 498 (2017)

2017 NY Slip Op 00131

46 N.Y.S.3d 523

THE PEOPLE OF THE STATE OF NEW YORK, Respondent, v. RICHARD HOVAN, Appellant.

Appellate Division of the Supreme Court of New York, First Department.

Decided January 10, 2017.

Defendant made a valid waiver of his right to conflict-free representation. Any conflict created by defendant's retained attorney's involvement in defendant's inappropriate contact with a witness in this case did not rise to the level of a nonwaivable conflict, such as where the attorney is accused of crimes relating to the underlying charges against the client (see e.g. United States v Perez, 325 F.3d 115...

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