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fiduciary duties to both the insured and the insurer. 39Likewise, however, the insurer’sposition relative to coverage may require that it surrender control of the litigation andsatisfy its obligations under the policy of insurance by paying for counsel of themanufacturer’s own choosing.In some circumstances, this potential for a conflict, orthe appearance of one, makes it advisable to make full disclosure to the manufacturerand obtain its consent to the representation.39 Nandorf, 479 N.E.2d at 991.28

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