The following excerpt is from United States v. Al-Farekh, 956 F.3d 99 (2nd Cir. 2020):
18 Cf. In re The City of New York , 607 F.3d 923, 94849 (2d Cir. 2010) (providing guidance to district courts on how to handle especially sensitive materials to analyze a claim for law enforcement privilege) (citing In re Grand Jury Subpoenas Dated March 19, 2002 and August 2, 2002, 318 F.3d 379, 386 (2d Cir. 2003) (describing the presentation of documents for in camera review as a "practice both long-standing and routine in cases involving claims of privilege" and citing illustrative cases); United States v. Wolfson, 55 F.3d 58, 6061 (2d Cir. 1995) (noting, in the criminal context, that "the prescribed procedure for resolving [a] dispute [as to whether certain confidential documents are subject to discovery] is to provide the documents to the district court for in camera review" and that "[t]he district court normally returns such documents to the party that submitted them in camera ")).
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