California, United States of America
The following excerpt is from People v. Clark, 268 Cal.Rptr. 399, 50 Cal.3d 583, 789 P.2d 127 (Cal. 1990):
30 Defendant seeks to rely on his right against self-incrimination as an independent basis for exclusion of his statements. Since there was no state involvement or compulsion in eliciting his statements, no violation of his privilege against self-incrimination occurred. (Colorado v. Connelly (1986) 479 U.S. 157, 164, 107 S.Ct. 515, 520, 93 L.Ed.2d 473.)
31 In Nowell v. Superior Court (1963) 223 Cal.App.2d 652, 657, 36 Cal.Rptr. 21, the court again, quoting from Abbott, states the exception in broad, alternative language relating to communications " 'having to do with the client's contemplated criminal acts, or in aid or furtherance thereof ...' " but once again the communications in issue were asserted to be ones in which the client sought legal advice that would further his criminal purpose.
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