How has attorney-client privilege been interpreted in the context of a crime-fraud claim?
The following excerpt is from U.S. v. Bauer, 132 F.3d 504 (9th Cir. 1997):
At the outset, it is important to recognize that the attorney-client privilege is a two-way street: "The attorney-client privilege protects confidential disclosures made by a client to an attorney in order to obtain legal advice, ... as well as an attorney's advice in response to such disclosures." United States v. Chen, 99 F.3d 1495, 1501 (9th Cir.1996) (emphasis added) (quotation omitted) (addressing a claim concerning the crime-fraud exception to the attorney-client privilege), cert. denied, --- U.S. ----, 117
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