Can an attorney who serves as a business agent to a client assert attorney-client privilege?

¹ See, e.g. , United States v. Rowe , 96 F.3d 1294, 1297 (9th Cir. 1996) (noting "[w]here the attorney was asked for business (as opposed to legal) counsel, no privilege attached," but "fact-finding which pertains to legal advice counts as professional legal services " (citations omitted)); United States v. Huberts , 637 F.2d 630, 640 (9th Cir. 1980) ("Generally, an attorney who serves as a business agent to a client may not assert the attorney-client privilege, because no confidential relationship attaches."); see also Harris v. United States , 413 F.2d 316, 320 (9th Cir. 1969) (applying "the general rule that ministerial or clerical services performed by an attorney are not within the privilege").