In Jeffry v. Pounds (1977) 67 Cal. App. 3d 6, a law firm breached its professional duties to its client and was discharged by the client. The law firm then sought to recover its fees. The reviewing court held that though the breach of professional duties precludes an attorney's recovery of fees, the client must pay the reasonable value of the attorney's services performed until discharge. ( Id. at pp. 9, 12.) In Jeffry v. Pounds, the court held counsel's breach of rules of professional conduct prohibiting an attorney from representing conflicting interests except with written consent of all parties did not prohibit quantum meruit recovery, limited to the value of services rendered before the date of the violation. (Jeffry, 67 Cal. App. 3d at p. 12.) Despite violation of ethical duties to a client, the appellate courts have "allowed partial fee recovery or acknowledged that some fees could be recovered by the attorney: (1) where there was no objection by the client (Clark v. Millsap (1926) 197 Cal. 765, 242 P. 918); (2) for services rendered before the ethical breach (Jeffry v. Pounds (1977) 67 Cal. App. 3d 6, 136 Cal. Rptr. 373); or (3) on an unjust enrichment theory where the client's recovery was a direct result of the attorney's services (Estate of Falco (1987) 188 Cal. App. 3d 1004, 233 Cal. Rptr. 807)." (Cal Pak Delivery, Inc. v. United Parcel Service, Inc., supra, 52 Cal. App. 4th at p. 16.)