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80a instruction may be inadequate to mitigate these risks given the nature of the allegations involved. Importantly, a joint trial is also likely to require disqualification of at least one of Maxwell’s attorneys from participating as an advocate on her behalf. The perjury counts likely implicate the performance and credibility of her lawyers in the civil action—two of whom represent her in this case. The New York Rules of Professional Conduct generally forbid a lawyer from representing a client in a proceeding in which the lawyer is likely also to be a witness. N.Y. R. Prof’l Conduct § 3.7(a). Maxwell’s counsel in the civil action and the deposition may be important fact witnesses on the perjury counts. Even if counsel were not required to testify, trying all counts together could force Maxwell to choose between having her counsel testify on her behalf on the perjury charges and having them assist her in defending the Mann Act charges. The Second Circuit has recognized that witness testimony offered by a party’s attorney presents serious risks to the fairness of a trial. See Murray v. Metro. Life Ins. Co., 583 F.3d 173, 178 (2d Cir. 2009). The lawyer might appear to vouch for their own credibility, jurors might perceive the lawyer as dis- torting the truth to benefit their client, and blurred lines between argument and evidence might confuse the jury. Id. Disqualification of counsel also implicates Maxwell’s Sixth Amendment right to be represented by the counsel of her choice. See, e.g., United States v. Kincade, No. 15-cr-00071 (JAD) (GWF), 2016 WL 6154901, at *6 (D. Nev. Oct. 21, 2016). The prejudice to Maxwell is especially pronounced because the attorneys who represented her in the civil case have worked with her for years and are particularly familiar with the facts surrounding the criminal prosecution. See United DOJ-OGR-00000143