Seibel v. Eighth Jud. Dist. Ct.

Summary

The Nevada Supreme Court denied extraordinary writ relief from an order compelling disclosure of attorney-client communications under the crime-fraud exception. It adopted a two-part test requiring proof that the client was pursuing a criminal or fraudulent scheme when legal advice was sought 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, after review, properly ordered disclosure of the documents.