United States Third Circuit

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In Re: Grand Jury Subpoena, 12-1237

The district court's order enforcing the grand jury subpoena to compel the former attorney for the target of the investigation to testify is affirmed, where: 1) the standard announced in United States v. Zolin, 491 U.S. 554, 572 (1989), applies to determine whether to conduct an in camera examination of a witness; and 2) the district court did not abuse its discretion in applying this standard, in determining procedures for the examination, or in ultimately finding that the crime-fraud exception applies.

Appellate Information

  • Decided 02/12/2014
  • Published 02/12/2014




  • United States Third Circuit


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