To answer your questions:"Doesn't the SSLCertificate parameter for each VH say which cert to use?Yes, but how does Apache know which VH to get the cert from until it has used a cert to decrypt the SSL? It just used the first cert in this case. IP Bases will get you around this. I said chicken - egg because Apache needs to read a header to know what VH to use but it can't read the header until it picks a vhost and uses the cert to decrypt the message.
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