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In Re Sealed Case, No. 96-3085 (D.C. Cir.) (107 F.3d 46) (March 4, 1997) (Judge A. Raymond Randolph)

The Court emphasized that two conditions must be met before the crime fraud exception can be invoked:, namely the client must have made or received the otherwise privileged communication with the intent to further an unlawful act and the client must have carried out the crime. If both conditions are ...

 

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