or employees or associates against an accusation of wrongful conduct.” Rule 1.6(b)(5), MRPC. Although Walen concedes the implications of Rule 1.6(b)(5), he contends — without any legal support — that his claim for ineffective assistance of counsel was not an accusation of wrongful conduct. Although no Minnesota case is directly on point, many other jurisdictions have concluded that ineffective assistance-of-counsel claims, or similar postconvietion claims, necessarily waive the attorney-client privilege as to all communications relevant to that issue. Tasby v. United States, 504 F.2d 332, 336 (8th Cir.1974) (stating that “[w]hen a client calls into public question the competence of his attorney, the privilege is waived”); Laughner v. United States, 373 F.2d 326, 327 (5th Cir.1967) (<HOLDING>); In re Gray, 123 Cal.App.3d 614, 176 Cal.Rptr.
holding no ineffective assistance of appellate counsel claim for failure to raise as basis for appeal of conviction ineffective assistance of trial counsel where basis for the latter claim was inadequate recognizing a constitutional claim for ineffective assistance of counsel holding that a claim for ineffective assistance of counsel waives attorneyclient privilege holding that production of documents without a claim of privilege waives the right to later claim that privilege holding that an invocation of the advice of counsel defense waives the attorneyclient privilege