Task: Text Completion
Input (English): counsel is necessary to warrant the “drastic step of disqualification of counsel.” Id. at 602-03 (citations omitted) (quoting Shaffer v. Farm Fresh, Inc., 966 F.2d 142, 145-46 (4th Cir.1992), and citing Aetna Cas. & Surety Co. v. United States, 570 F.2d 1197, 1200-01 (4th Cir.1978), and Richmond Hilton Assocs. v. City of Richmond, 690 F.2d 1086, 1089-90 (4th Cir.1982)). The Court notes that “the lawyer’s duty of loyalty long has precluded the representation of conflicting interests.” Chauffeurs, Teamsters & Helpers, Local No. 391 v. Terry, 494 U.S. 558, 586, 110 S.Ct. 1339, 108 L.Ed.2d 519 (1990); see also Dyntel Corp. v. Ebner, 120 F.3d 488, 492 (4th Cir.1997) (“[UJnder Virginia law it is clear that a lawyer owes his or her client a fiduciary duty.”); Tessier, 731 F.Supp. at 733 (<HOLDING>). This duty of loyalty is reflected in Rules 
 Holding statements: (A) holding that the substantial relationship test also concerns the duty of loyalty to a former client (B) holding that an attorney who breaches a fiduciary duty to a client forfeits his right to compensation without any requirement that the client prove actual harm (C) holding an attorney is an agent of the client and therefore cannot conspire with the client (D) recognizing that an attorney has a duty of loyalty to his client (E) holding that erisas duty of loyalty creates a duty to disclose certain information to beneficiaries
Output (English): (D)