When will a subpoena be served for attorney fees?

We also disagree that allowing service of the subpoena is certain to chill the attorney-client relationship or so greatly disrupt and distract the attorney that his assistance will be ineffective. These same reasons we also found in Osterhoudt were insufficient to justify a preliminary showing of need or relevance in the pre-indictment context. Accord Doe, 781 F.2d at 243. That the Sixth Amendment right to counsel has attached in the post-indictment context does not render these risks any more certain. The fee information remains beyond the bounds of the attorney-client privilege. Consequently, the probability is plain that compelling disclosure of this information would not inhibit the free flow of confidential communications made in the course of legal representation. ⁷ If compliance, for whatever reason, would necessitate disclosure of confidential information or revelation of the defense's strategy, or if the timing of the subpoena is disruptive of counsel's preparation or is harassing, a continuance or motion to quash can be sought. Id. at 250; see, e.g., In re Grand Jury Matters, 751 F.2d at 18-19; Klein, 776 F.2d at 633 n. 3. But as this court said in United States v. Freeman, "merely requiring defendant's lawyer to testify alone does not constitute a material interference with his function as an advocate...." 519 F.2d 67, 68 (9th Cir.1975).