In Re Grand Jury Proceedings, Appeal of Carol Hill

This appeal presents three questions: whether, under the circumstances before us, the Government must show need and relevance before a Grand Jury subpoena can be enforced against Carol Hill, a paralegal; whether the district court should have held an evidentiary hearing on Hill’s motion for disclosure of electronic surveillance; and whether Hill’s right to confrontation was violated when the district court considered in camera an ex parte affidavit before ruling on her motions.

Facts

Carol Hill was subpoenaed to testify before, and to provide fingerprints, handwriting exemplars and a photograph…