The following excerpt is from Kiefaber, In re, 774 F.2d 969 (9th Cir. 1985):
Quashing grand jury subpoenas is not the appropriate sanction for all instances of prosecutorial misconduct in the grand jury context. See In re Antitrust Grand Jury Investigation, 714 F.2d 347 (4th Cir.1983). This remedy interferes with the grand jury process in such a fundamental way that it must be reserved for cases where the powers of the grand jury have been flagrantly abused. See United States v. Dionisio, 410 U.S. at 16-18, 93 S.Ct. at 772-73 (courts should not intervene in grand jury process absent compelling reason). The government's conduct in this case was egregious enough, and the effectiveness of alternative sanctions questionable enough, that we cannot conclude that the district court abused its discretion when it chose that remedy. Accordingly, the district court's order is AFFIRMED.
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