United States Third Circuit

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

Judges

• FISHER

Court

• United States Third Circuit

Counsel