In Re Richard Roe, Inc., and John Doe, Inc. United States of America v. Richard Roe, Inc., Richard Roe, John Doe, Inc., and John Doe

WINTER, Circuit Judge:

This appeal concerns the scope of the so-called “crime-fraud” exception to the attorney-client privilege and attorney work product immunity (collectively “the privileges”). Appellant corporations John Doe, Inc. and Richard Roe, Inc. 1 asserted the privileges with respect to four grand jury subpoenas seeking documents and testimony from the corporations and from attorneys who jointly represented the firms at one time. The government subsequently moved to compel production, arguing that the matters sought fell within the crime-fraud exception to the privileges. Based on an…