United States v. Charles E. Rowe, Individually Rowe and Associates, a Professional Corporation
Court of Appeals for the Ninth Circuit
1Opinion of the Court
KOZINSKI, Circuit Judge.
After learning of possible irregularities in attorney W. Lee McElravy’s handling of client funds, the senior partner at his San Diego law firm, Charles E. Rowe, asked two young associates to investigate McElravy’s conduct. Rowe also wrote to the State Bar, asking it to “take appropriate action” against McElravy. A grand jury investigating McElravy later subpoenaed the associates; the government hoped to question them about their conversations with Rowe. Appellants argued that the conversations were protected by the attorney-client privilege.
The attorney-client…
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