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Court of Appeals — Simultaneous Representation: People v. Tyrone Prescott

New York State Court of Appeals Simultaneous Representation Appellate Counsel People v. Tyrone Prescott No. 80 Memorandum Background: The defendant alleged he was denied effective assistance of counsel due to an unwaived actual conflict of interest occasioned by his appellate counsel’s representation of defendant’s co-defendant at a prior sentencing hearing. The appellate division found that the simultaneous representation was legally inconsequential ...