Silva

Edward Silva, Silva Harvesting Inc. (collectively “Silva”), Edward O.C. Ord, Inc. and Ord & Norman appeal the district court’s denial of their motion to quash a grand jury subpoena duces tecum directed at allegedly privileged records of Charles Baffin, Silva’s tax accountant. Silva also attempts to obtain review of the district court’s ruling through a petition for an extraordinary writ under the All Writs Act, 28 U.S.C. § 1651 . We dismiss the appeal for lack of subject matter jurisdiction and deny the petition.

I

Baffin has been Silva’s tax accountant for several years. In mid-1992, Baffin became *205 aware that an agent of the Internal Revenue Service (“IRS”), Elizabeth Davis, was investigating a large number of cash payments received by Silva. Baffin recommended to Silva that Silva retain attorney Edward O.C. Ord in connection with the investigation, which Silva did in April 1992. Shortly thereafter, Ord retained Baffin to aid him in representing Silva in the investigation. Baffin testified that all actions he took after Ord was retained were at Ord’s direction. The district court found that Baffin was Ord’s agent at all times relevant to these proceedings.

In July 1992,…