Although people can quarrel about the significance or reliability of Independent Counsel Kenneth Starr's investigative findings, no one can deny that his investigation produced new law. We now know that the attorney-client privilege survives the death of the client,1 that government lawyers may not rely on that privilege to shield communications from their "client" relating to criminal misconduct,2 and that there is no "protective function privilege" (at least not yet),3 While bringing some clarity to certain areas, the Independent Counsel's investigation also highlighted the confused state of the law relating to Rule 6(e)'s grand jury secrecy provisions.4
Grand Jury Secrecy: Plugging the Leaks in an Empty Bucket,
Am. Crim. L. Rev.
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