This case balances a criminal defendant's right to counsel and right to confidentiality with the government's potential need for information when the defendant abuses the attorney-client relationship. Three points are worth noting: (1) in this as in other recent cases, counsel's ignorance of a client's intended wrongs does not mean the crime-fraud exception does not apply since this exception is governed by the client's intention; (2) although this was a criminal case, it seems likely that the court would have taken the same approach to a civil case; and (3) although this court found that the government had not substantiated its demand for access to the entire file, it may well be that the government's burden in such circumstances is not difficult to meet.