In what circumstances will a federal grand jury be able to be used in civil litigation?

Blair v. United States, 250 U.S. 273, 282, 39 S.Ct. 468, 471, 63 L.Ed. 979 (1919). Investigation for civil enforcement is relatively limited. In fact, frustration over limitations on civil discovery may have prompted the government to convene the grand jury here. To grant the government an absolute right of access to grand jury materials for civil use might irresistibly encourage use of the grand jury as a tool of civil discovery. It would also severely limit court review of any such abuse.