Pellicano recorded many other persons with whom he discussed wiretapping. This evidence would support a good faith belief by a reasonable person that the Pellicano-Christensen recordings might contain similar discussions about wiretapping, especially in the context of Christensen’s representation of Kerkorian and the large sums of money Christensen’s firm had paid Pellicano. The affidavit also recounted testimony from former PIA employees that “confirmed the widespread use of wiretapping in Pellicano’s investigations.” We conclude that the government made the requisite “minimal showing” that the Pellicano-Christensen recordings might contain evidence showing the crime-fraud exception applied to any privileged communications within them. Cf. Grand Jury Subpoena 92-1(SJ), 31 F.3d at 830 (<HOLDING>). Jp. Zolin’s second step Under Zolin’s second
holding that the government met zolins first step in case involving illegal exports where affidavit based on testimony of two former employees  as well as on telephone records invoices and other documentary evidence established that a corporation used an export license to disguise illegal exports and sought its counsels legal assistance in furtherance of the scheme holding that where the court records in the present case and the records in a previous conviction reflected the same name and date of birth as well as a signature and the defendant did not object that he was not the same person as had been previously convicted the evidence was sufficient to support his conviction holding that no action may be maintained on an illegal agreement holding that the court of appeals erred in declining to consider whether the arrest was illegal and whether the consent was tainted by the potentially illegal police activity holding that the admission of evidence obtained as a result of an illegal search and seizure is subject to a harmlesserror analysis