The Corporate Counsel Section of the New York State Bar Association's newsletter, "NYSBA Inside", recently published an article written by our partners, Shari Brandt and James Walker, discussing a bench decision in United States v. Nicholas that addressed Upjohn warnings in the context of concurrent representations. Shari and Jim wrote a more in-depth companion memorandum after Judge Carney issued a formal decision and order in the Nicholas case titled Issuing a Proper Upjohn Warning Will Not Cure Multiple Representation Conflicts.