The following excerpt is from Wheeler v. U.S., 640 F.2d 1116 (9th Cir. 1981):
In the present case the court issued a protective order not before or during the trial but rather after the trial had ended. The Government has cited no case in which a court has taken steps to protect a witness once the trial has been completed and we have been unable to find even one such case. Because this is a post-trial order, it cannot promote "the orderly and expeditious progress of a trial." Bitter v. United States, 389 U.S. at 16, 88 S.Ct. at 7. It could, however, promote the more general purpose of protecting the administration of justice from "abuses, oppression and injustice." Id. at 16, 88 S.Ct. at 7. By protecting the witness after the trial, the court is encouraging that witness, and other potential witnesses, to come forward and provide information helpful to the implementation of justice.
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