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ney-client privilege applied where alleged wrongdoing included "perjured testimony, document destruction, and similar misconduct"); United States v. Myers, 593 F.3d 338, 347 n.14 (4th Cir. 2010) (noting that exception applied where litigant "defrauded" public defender by submitting false invoices). Pe
6/2015 Page 14 of 51 a governmental attorney-client privilege applicable in criminal proceedings inquiring into the actions of public officials."). The Eighth Circuit did not purport to espouse a broad-ranging rule that defeated existing, well-defined privileges such as the work product doctrine. This is importan
ney-client privilege applied where alleged wrongdoing included "perjured testimony, document destruction, and similar misconduct"); United States v. Myers, 593 F.3d 338, 347 n.14 (4th Cir. 2010) (noting that exception applied where litigant "defrauded" public defender by submitting false invoices). Pe
6/2015 Page 14 of 51 a governmental attorney-client privilege applicable in criminal proceedings inquiring into the actions of public officials."). The Eighth Circuit did not purport to espouse a broad-ranging rule that defeated existing, well-defined privileges such as the work product doctrine. This is importan
ney-client privilege applied where alleged wrongdoing included "perjured testimony, document destruction, and similar misconduct"); United States v. Myers, 593 F.3d 338, 347 n.I4 (4th Cir. 2010) (noting that exception applied where litigant "defrauded" public defender by submitting false invoices). Pe
6/2015 Page 14 of 51 a governmental attorney-client privilege applicable in criminal proceedings inquiring into the actions of public officials."). The Eighth Circuit did not purport to espouse a broad-ranging rule that defeated existing, well-defined privileges such as the work product doctrine. This is importan
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