Abstract
The federal grand jury is a place and a process of secrecy. This secrecy protects innocent individuals from disclosure of the fact that they may be under investigation. It protects witnesses from being pressured or threatened by potential defendants. It protects the government's interest in being able to conduct undercover investigations. As the case law has developed, however, secrecy has become an end unto itself, with the result that entirely legitimate efforts to use or discover matters that have occurred before the
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