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that one client's story benefits another client, such as a client who will testify that he or she complained to a defendant that children were in danger but nothing was done.

Another advantage of representing multiple clients, as opposed to each having separate counsel or each filing their own separate lawsuit, is sharing costs. Many costs can be shared, such as court filing fees, deposition costs, and travel expenses, while some costs, such as individual psychological evaluations or other costs associated with proving individual damages and losses, are not shared.

Likewise, the prosecution of the case will be more efficient and more consistent if it is not run by a group of attorneys each with his or her own client and his or her own strategy.

It's also possible that clients who the Firm has decided not to represent will hire attorneys who might lack our Firm's skill and sophistication, and who could take actions that adversely affect your case, the law, and future prospects for recovery.

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## OUR REASONS AGAINST REPRESENTING MULTIPLE CLIENTS

Our greatest concern in representing multiple clients is that a conflict of interest could develop between or among our clients. It is impossible to anticipate every potential conflict. The biggest risk in multiple client cases is that the defendant might lack the assets or insurance coverage to pay all claims in full. If we collect all of that money for one client, then we may have deprived our other clients of any chance of being fairly compensated by that defendant.

It is also possible that a defendant will insist on a common settlement fund which means that it will pay a fixed amount to settle all cases. The challenge in that situation is dividing the settlement fund among multiple clients. We could not represent any one client against the interests of any other client. It would be necessary, therefore, to refer all of our clients to separate attorneys to resolve the issue concerning the distribution of the common fund.

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## OUR REASONS AGAINST REPRESENTING MULTIPLE CLIENTS (cont.)

On the other hand, defendants and their insurance companies often insist on a common settlement fund because they want to resolve all of their risk at the same time. In turn, they are often willing to pay more to resolve all of their risk than if they are only settling some of the claims.

It is also possible that one client will reveal information that is damaging to another client. In this situation, we may no longer be able to represent either client and each client may need to seek separate attorneys.

Finally, you lose some measure of confidentiality when you join forces with another party. Thus, if there is a meeting of several clients to discuss joint strategy, no one can prevent one client from revealing what was said at the meeting. Even an agreement to keep the content of the meeting confidential is difficult to enforce. (Individual attorney-client communications, however, always remain strictly confidential.)

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