Seibel v. Eighth Jud. Dist. Ct.

Summary

The Nevada Supreme Court denied extraordinary writ relief challenging disclosure of attorney-client communications under the crime-fraud exception. It adopted a two-part test requiring proof that the client was engaged in or planning a criminal or fraudulent scheme when seeking legal advice and that the communications were sufficiently related to and made in furtherance of the scheme. The court held that the district court properly ordered in camera review and did not abuse its discretion in ordering disclosure of the documents.