The following excerpt is from Bacon v. United States, 449 F.2d 933 (9th Cir. 1971):
The term "criminal proceeding," absent a clear context, is ambiguous. Among the courts that have wrestled with its meaning in various contexts, there is a division of opinion as to whether grand jury investigations are included. See cases collected in United States v. Thompson, 2 Cir., 1963, 319 F.2d 665, 668.
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