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proceeding such as in Subpoena Duces Tecum-relied upon the Protective Order to indefinitely keep the relevant materials hidden. In this case, where the Protective Order is limited by its terms to only the pretrial stages of the civil litigation, no confidential business information appears to be at issue, and counse
k rendering that opinion in even further conflict with the well-reasoned decisions of numerous other Circuits. In particular, the Fourth, Ninth, and Eleventh Circuits have each adopted a per se rule favoring enforcement of a grand jury subpoena even where a protective order exists. See In re Grand Jury Subpoena,
proceeding such as in Subpoena Duces Tecwn—relied upon the Protective Order to indefinitely keep the relevant materials hidden. In this case, where the Protective Order is limited by its terms to only the pretrial stages of the civil litigation, no confidential business information appears to be at issue, and counse
k rendering that opinion in even further conflict with the well-reasoned decisions of numerous other Circuits. In particular, the Fourth, Ninth, and Eleventh Circuits have each adopted a per se rule favoring enforcement of a grand jury subpoena even where a protective order exists. See In re Grand Jury Subpoena,
proceeding such as in Subpoena Duces Tecwn—relied upon the Protective Order to indefinitely keep the relevant materials hidden. In this case, where the Protective Order is limited by its terms to only the pretrial stages of the civil litigation, no confidential business information appears to be at issue, and counse
k rendering that opinion in even further conflict with the well-reasoned decisions of numerous other Circuits. In particular, the Fourth, Ninth, and Eleventh Circuits have each adopted a per se rule favoring enforcement of a grand jury subpoena even where a protective order exists. See In re Grand Jury Subpoena,
proceeding such as in Subpoena Duces Tecwn—relied upon the Protective Order to indefinitely keep the relevant materials hidden. In this case, where the Protective Order is limited by its terms to only the pretrial stages of the civil litigation, no confidential business information appears to be at issue, and counse
k rendering that opinion in even further conflict with the well-reasoned decisions of numerous other Circuits. In particular, the Fourth, Ninth, and Eleventh Circuits have each adopted a per se rule favoring enforcement of a grand jury subpoena even where a protective order exists. See In re Grand Jury Subpoena,
Entities connected to both the Protective Order and Eleventh Circuits

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PERSONBranzburg v. Hayes
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