RYMER, Circuit Judge:
We must decide whether communications between an attorney and client can be "in furtherance of" criminal activity, as they must be to fall within the crime-fraud exception to the attorney-client privilege, even if the attorney is unaware of the crimes and takes no affirmative step that actually furthers them.
Corporation appeals the district court's order requiring its two former corporate counsel, Mary Roe and John Doe, to appear before...
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