United States v. Graf

TALLMAN, Circuit Judge:

Once again we examine the complex relationship between corporate employees and corporate counsel — a delicate issue that can become particularly problematic when the latter are called to testify in opposition to the former during a criminal trial against the corporation’s former officers. Defendant-Appellant James L. Graf was a founder of, and ostensible consultant to, Employers Mutual LLC (“Employers Mutual”), a Nevada corporation that purported to provide health care benefits coverage to more than 20,000 plan members. In reality, the company was part of an elaborate…