Can attorney-client privilege apply to communications between attorneys and clients made for the purpose of giving legal advice?

MultiRegion, United States of America

The following excerpt is from Weiner v. Ocwen Fin. Corp., No. 2:14-cv-2597 MCE DB (E.D. Cal. 2017):

"The attorney-client privilege protects confidential communications between attorneys and clients, which are made for the purpose of giving legal advice." United States v. Richey, 632 F.3d 559, 566 (9th Cir. 2011) (internal citations omitted). "[T]here is general agreement that the protection of the privilege applies only if the primary or predominate purpose of the attorney-client consultations is to seek legal advice or assistance." United States v. Salyer, 853 F.Supp.2d 1014, 1018 (E.D. Cal. 2012); see also In re County of Erie, 473 F.3d 413, 420-21 (2d Cir. 2007) ("We consider whether the predominant purpose of the communication is to render or solicit legal advice . . . . The predominant purpose of a communication cannot be ascertained by quantification or classification of one passage or another; it should be assessed dynamically and in light of the advice being sought or rendered, as well as the relationship between advice that can be rendered only by consulting the legal authorities and advice that can be given by a non-

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