The Battle Between Grand Jury Subpoenas and Civil Protective Orders: The Circuit Splits Persist

In a battle between a federal grand jury subpoena and a civil protective order, which one would prevail? It may come as a surprise, but the answer may depend on the federal circuit in which the dispute is pending. John Fatino discusses the different rules employed by the federal courts of appeals in assessing the relationship between civil protective orders and grand jury subpoenas.

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