that the “attorney-client privilege is a two-way street”). The purpose of the attorney-client privilege is to “encourage full and frank communication between attorneys and their clients and thereby promote broader public interests in the observance of law and administration of justice.” Upjohn Co. v. United States, 449 U.S. 383, 389, 101 S.Ct. 677, 66 L.Ed.2d 584 (1981). Clients must be able to consult their lawyers candidly, and the lawyers in turn must be able to provide candid legal advice. Chen, 99 F.3d at 1499-1501. A communication from the attorney to the client that does not contain legal advice may be protected if it “directly or indirectly reveal[s] communications of a confidential nature by the client to the attorney.” In re Fischel, 557 F.2d 209, 212 (9th Cir.1977) (<HOLDING>). Further, a communication from the attorney to
holding that the information is not protected by attorneyclient privilege holding that failure to timely assert attorneyclient privilege constitutes waiver holding attorneyclient privilege protects disclosure of communications but does not protect client from disclosure of underlying facts holding that a claim for ineffective assistance of counsel waives attorneyclient privilege holding that attorneyclient privilege did not protect attorneys summaries of clients business transactions