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In re Sealed Case

United States Court of Appeals for the District of Columbia Circuit
107 F.3d 46 (1997)


In sealed proceedings, the United States government (plaintiff) convened a grand jury in an investigation of election law violations. The grand jury subpoenaed two documents from an unnamed company (defendant). First, the grand jury sought an August 1994 memorandum from the company's vice president to its president. The memorandum documented a June 1994 meeting at which the vice president and the company's general counsel discussed campaign-finance laws. The government alleged that, in August 1994, the vice president violated those laws. The company withheld the memorandum, claiming attorney-client privilege. Second, the grand jury sought a file memorandum from the company’s general counsel, written sometime after November 1995, relating to the company’s actions to correct the vice president’s August 1994 conduct. The company withheld this under the attorney work-product doctrine. The district court examined the documents in camera. Without deciding if either the attorney-client privilege or the work-product doctrine applied, the court applied the crime-fraud exception to both, and ordered the company to produce the documents. When the company refused to do so, the court cited the company for contempt. The company appealed the citation to the United States Court of Appeals for the District of Columbia Circuit.

Rule of Law


Holding and Reasoning (Randolph, J.)

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