context: We therefore endeavor to set forth the procedures to be used in reviewing a claim concerning the crime-fraud exception and the type of evidence permissible for a threshold factual showing in future cases. The proponent of the exception may, in appropriate circumstances, request an in camera review of the privileged information to allow the court to make a determination regarding the applicability of the exception.
citation_a.signal: see also
citation_a.parenthetical: where concerns for secrecy are weak, in camera proceeding may not be justified
citation_a.sentence: Id., 570-71; see also In re John Doe, Inc., supra, 13 F.3d 636 (where concerns for secrecy are weak, in camera proceeding may not be justified). We have permitted an in camera review in other contexts and conclude that, in certain circum stances, it may be an appropriate means of examining the allegedly privileged material without abrogating the privilege itself.
citation_b.signal: see
citation_b.parenthetical: concluding that neither Federal Rules of Evidence nor federal common law prohibits party opposing privilege on crime-fraud grounds from relying on in camera review of communications
citation_b.sentence: See United States v. Zolin, supra, 491 U.S. 568-69 (concluding that neither Federal Rules of Evidence nor federal common law prohibits party opposing privilege on crime-fraud grounds from relying on in camera review of communications). We recognize that encouraging an in camera review in all cases is ill-advised due to the fact that “[t]oo much judicial inquiry into the claim of privilege would force disclosure of the thing the privilege was meant to protect . . . .” (Internal quotation marks omitted.)