government bears a heavy burden of establishing that disqualification is justified.’ ” United States v. Gearhart, 576 F.3d 459, 464 (7th Cir.2009) (quoting United States v. Diozzi, 807 F.2d 10, 12 (1st Cir.1986)); United States v. Washington, 797 F.2d 1461, 1465 (9th Cir.1986) (“In seeking to disqualify a defendant’s chosen counsel, the government bears a heavy burden of establishing that concerns about the integrity of the judicial process justify the disqualification.”); see also Owen v. Wangerin, 985 F.2d 312, 317 (7th Cir.1993) (“Attorney disqualification is ‘a drastic measure which courts should hesitate to impose except when absolutely necessary.’ ”) (quoting Schiessle v. Stephens, 717 F.2d 417, 419-20 (7th Cir.1983)); Evans v. Artek Systems Corp., 715 F.2d 788, 794 (2d Cir.1983) (<HOLDING>). In evaluating a request for defense counsel’s
recognizing that the party seeking attorney fees bears the burden of proving entitlement to those fees holding that the government bears the burden of proving voluntary consent under the totality of the circumstances holding that the moving party for summary judgment bears the initial burden of demonstrating the absence of a genuine issue of material fact for trial holding that the moving party bears a heavy burden of proving the facts required for disqualification holding that the defendant bears the burden of proving outside contact with the jury