Can an attorney be held liable for conspiring with his client to commit actual fraud or for intentional infliction of emotional distress?

Nevertheless, the exceptions set forth in Civil Code section 1714.10, subdivision (c) are consistent with common law. "An attorney may be held liable for conspiring with his or her client to commit actual fraud or for the intentional infliction of emotional distress. [Citations.] But plaintiffs can state a viable claim only if the attorneys' actions went beyond their role as attorneys acting on behalf of [their clients]." ( Panoutsopoulos v. Chambliss (2007) 157 Cal.App.4th 297, 306, 68 Cal.Rptr.3d 647.)