United States v. Zolin

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• holding that party asserting crime-fraud exception to attorney-client privilege must make thresh- old showing to trigger in camera review
• observing that use of the term \may\ counsels a \very relaxed test\ and, because only the judge is afforded such access, properly so
• stating that, in context of determining the applicability of the crime-fraud exception to an assertion of the attorney-client privilege, “the decision whether to engage in in camera review rests in the sound discretion of the district court.”
• permitting in camera review of materials to establish applicability of crime-fraud exception to attorney-client privilege
• permitting in camera review of materials to establish applicability of crime-fraud exception to attorney-client privilege
• requiring a threshold showing to be made before the court could perform in camera review to determine whether the crime-fraud exception to the privilege applies

Source: CourtListener parenthetical corpus (CC0).