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The tripartite relationship between insured, insurer and the attorney hired to represent the insured by the insurer is confusing and a recent decision by the Michigan Supreme Court does little to clarify the overall situation. The Court ruled in Atlanta International Insurance Co v Bell that the attorney may be held accountable to the insurer, but this decision runs counter to numerous previous decisions involving the same issues. Furthermore, the Model Code and Model Rules do not resolve these issues for which specific guidelines are needed.