Task: Text Completion
Input (English): duty of loyalty. Only the second subparagraph of that Rule specifically deals with confidentiality. The Second Circuit made clear in In re “Agent Orange” Prod. Liability Litig., 800 F.2d 14 (2d Cir.1986), that “an attorney owes a duty of loyalty to his client” and that “[tjhese obligations do not necessarily end when the attorney-client relationship ends.” Id. at 17. See also Arifi v. de Transport du Cocher, Inc., 290 F.Supp.2d 344, 348 (E.D.N.Y.2003) (“The duty of loyalty that runs from an attorney to a client does not necessarily end when the formal attorney-client relationship ends because the attorney owes a ‘duty of continuing loyalty’ to his former client.” (internal citations omitted)); Schwed v. General Electric Co., 990 F.Sup t’l Inc.), 222 B.R. 401, 408 (Bankr.D.Conn.1998) (<HOLDING>); Kassis v. Teacher’s Ins. and Annuity Assoc., 
 Holding statements: (A) recognizing that an attorney has a duty of loyalty to his client (B) holding that attorneys should be disqualified where the substantial relationship test is met in order to assure that the confidentiality of the attorneyclient relationship and the loyalty between attorney and client are preserved (C) holding that the substantial relationship test also concerns the duty of loyalty to a former client (D) holding that the substantial relationship test embodies a broader concept than the rule of confidentiality  that of continuing fidelity to a former client  a duty of loyalty (E) holding that an attorney may only undertake to represent a new client against a former client  where there is no confidential information received from the former client that is in any way relevant to representation of the current client
Output (English): (D)