The attorney-client privilege in Illinois is already narrow in the corporate context based upon Illinois courts’ application of the control group test pursuant to the decision in Consolidation Coal Co. v. Bucyrus-Erie Co., 89 Ill. 2d 103, 118-19 (1982).But the privilege may be narrowed even more should the 1st District Illinois Appellate Court decide in MacDonald v. Wagenmaker, 1-23-0089, that the crime-fraud exception “may extend to potential torts that involve deliberate misrepresentations, including defamation …