In Upjohn Co. v. United States, 449 U.S. 383, 101 S. Ct. 677, 66 L. Ed. 2d 584 (1981) the United States Supreme Court held that an attorney's investigation of potential wrongdoing by his corporate client's employees was protected by the attorney-client privilege. The Court held that government prosecutors could seek information from the same sources that corporate counsel had interviewed but could not obtain information directly from counsel. Id. at 396.