The U.S. Court of Appeals for the Third Circuit has given its OK under the crime-fraud exception to attorney-client privilege to a trial court’s in camera interview of a lawyer about advice provided to an ex-client as well as its subsequent decision that it meets the exception so that a grand jury could hear the testimony.
In deciding to apply the exception, the appeals court in In re Grand Jury Subpoena extended the standard governing a court’s review of documents to interviews of attorneys conducted in chambers.
