has abandoned its reasoning in Billman or adopted the restrictive reading of these forfeiture provisions favored in other jurisdictions. To the contrary, the Fourth Circuit recently invoked a similarly broad interpretation of § 853 in United States v. McHan. See 345 F.3d 262 (applying 853(c)'s relation-back principle to § 853(p) substitute property in order "to effectuate its remedial purpose (3d Cir.2000) (collecting cases); In re John Doe, Inc., 13 F.3d 633, 636 (2d Cir.1994) ("[W]here an in camera submission is the only way to resolve an issue without compromising a legitimate need to preserve the secrecy of the grand jury, it is an appropriate procedure.”) (citing In re John Doe Corp., 675 F.2d 482, 490 (2d Cir.1982)). But see In re Taylor, 567 F.2d 1183, 1188 (2d Cir.1977) (<HOLDING>). 35 . The Fourth Circuit held in United States
recognizing the importance of grand jury secrecy holding that governments weak interest in preserving grand jury secrecy did not warrant in camera submission where party seeking access to submission would learn of submission contents as soon as he was called as a grand jury witness holding that right was available in grand jury proceedings holding the presence of counsel for a witness did not violate grand jury secrecy holding that where government does not intend to disclose grand jury materials in camera proceedings are appropriate to protect govern ments interest in secrecy