In U.S v. Kaplan, 2003 WL 22880914 (SDNY 2003) federal agents executed a search warrant at the attorney-defendant's law office and removed boxes of legal files. The defendant moved for appointment of a special master to review the documents and the Government countered that their "iron wall" prosecutor would be sufficient. In addressing the issue, the court wrote "certainly this Opinion should be counted among those disapproving the Government's use of an ethical wall team to 'protect' the attorney-client and work-product privileges or to determine whether the crime-fraud exception applies..." The Court also noted that in camera review of documents is unnecessary where independent evidence provides probable cause to believe that attorney communications took place in furtherance of a crime or fraud.