The following excerpt is from U.S. v. Olano, 62 F.3d 1180 (9th Cir. 1995):
"Under the attorney-client privilege, confidential communications made by a client to an attorney to obtain legal services are protected from disclosure." Clarke v. American Commerce Nat. Bank, 974 F.2d 127, 129 (9th Cir.1992). Because the privilege "has the effect of withholding relevant information from the factfinder, it is applied only when necessary to achieve its limited purpose of encouraging full and frank disclosure by the client to his or her attorney." Id. Not all attorney-client communications are protected from discovery:
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