Can a court conduct an in camera review of privileged communications to determine whether they fall within the crime-fraud exception?

The court in its discretion may conduct an in camera review of privileged communications to resolve whether they fall within the crime-fraud exception. However, only nonprivileged relevant evidence lawfully obtained is used to determine whether to conduct an in camera review. See United States v. Zolin, 491 U.S. 554, 574, 109 S.Ct. 2619, 2632, 105 L.Ed.2d 469 (1989). The party seeking disclosure must establish facts "to support a good faith belief by a reasonable person" that the exception applies. Id. at 572, 109 S.Ct. at 2631. The evidence does not have to be "independent" of the contested communication. Id. at 574, 109 S.Ct. at 2632. The same evidence used to determine whether to conduct an in camera review may also provide the basis for finding that the crime-fraud exception applies.