Are there any cases where a defendant waived privilege before a grand jury?

California, United States of America

The following excerpt is from Brown v. Superior Court, 180 Cal.App.3d 701, 226 Cal.Rptr. 10 (Cal. App. 1986):

Defendants' federal cases are similarly unhelpful. Stevens v. Marks (1965) 383 U.S. 234, 86 S.Ct. 788, 15 L.Ed.2d 724, held that a potential criminal defendant who waived immunity when he first appeared without counsel before a grand jury could effectively withdraw the waiver when he subsequently appeared with counsel. That does not control whether the defendants here waived the privilege for the purpose of these civil proceedings by their untimely objection.

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