What is the current state of the law on keeping documents from a grand jury secret?

Federal Rule of Criminal Procedure 6(e)(6) provides, "[r]ecords, orders, and subpoenas relating to grand-jury proceedings must be kept under seal to the extent and as long as necessary to prevent the unauthorized disclosure of a matter occurring before a grand jury." Rule 6(e) secrecy extends beyond grand jury transcripts and includes summaries and discussions of grand jury proceedings. See United States v. Index Newspapers LLC, 766 F.3d 1072, 1091 (9th Cir. 2014). But only a limited set of circumstances can deny the public's access to criminal

Page 2