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EFTA00600054
ccurring before the grand jury" encompasses what has occurred, what is occurring and what is likely to occur before the grand jury, In re Motions of Dow Jones & Co 142 F.3d 496 (D. C. Cir. 1998), but it does not cover prosecutors' strategies, recommendations, In re Sealed Case No. 99-3091 (Qffice of Independent Co
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