Does attorney-client privilege protect communications between attorney and client which further crime or fraud?

The attorney-client privilege does not protect communications between an attorney and client which further a crime or fraud; this exception applies even where the attorney is unaware that his advice may further an illegal purpose. United States v. Hodge & Zweig, 548 F.2d 1347, 1354 (9th Cir.1977). The government has the burden of making a prima facie showing that the communications were in furtherance of an intended or present illegality, id., and that there is some relationship between the communications and the illegality. See In re Sealed Case, 754 F.2d 395, 399 (D.C.Cir.1985). Obstruction of justice is an offense serious enough to defeat the privilege. Id. at 401.