9th Cir.;
15-50450
The court of appeals vacated a district court order granting a motion to compel production of attorney-client documents and remanded the action for further proceedings. The court held that, after a district court determined that the government had made a prima facie showing of the crime-fraud exception to attorney-client privilege, the district court was required to undertake in camera examination of the documents subpoenaed by the government to determine whether the documents sought reflected communications or work product made in furtherance of a contemplated or ongoing crime-fraud.
