GRAND JURY PROCEEDINGS, 1:21-gj-00048

Petitioner Giorgi Rtskhiladze sought access to his grand jury transcript from the Special Counsel (Mueller) investigation to support a civil defamation/Privacy Act suit; the civil case was dismissed and is on appeal.
Court granted in-person review of the transcript but expressly did not authorize further disclosure; later it allowed limited note-taking under conditions: counsel custody and destruction after filing a sealed declaration.
Petitioner filed a Rule 60(b) motion in the civil case attaching a declaration derived from notes taken during the transcript review; the government moved to seal that filing and the presiding judge sealed it.
The D.D.C. court clarified that prior orders did not authorize public disclosure of material obtained during the transcript review and petitioner sought clarification and further relief from this Court.
Petitioner then moved to unseal Rule 60 materials and to obtain an unrestricted copy of his grand jury transcript; the government opposed, citing grand-jury secrecy interests and ongoing related investigations.
The Court denied the request for an unrestricted transcript copy and for public disclosure, but granted nunc pro tunc authorization for disclosure of grand-jury material only in sealed filings in the related civil case (and authorized the government to make similar sealed disclosures to respond).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Entitlement to a copy of his grand jury transcript	Rtskhiladze: witness entitlement means no particularized-need standard for his own transcript	DOJ: no automatic right to a transcript copy; secrecy and ongoing investigations justify denial	Denied — no unrestricted copy; prior in-person access suffices; court declines to expand law to automatic copies
Standard for transcript production	Rtskhiladze: relies on In re Grand Jury to avoid particularized-need showing	DOJ: In re Grand Jury did not decide entitlement to copies; court must balance interests	Court: In re Grand Jury inapplicable to grant of copies; petitioner failed to show need to alter precedent
Public disclosure of grand-jury materials in Rule 60(b) filing	Rtskhiladze: public interest/sunlight favors disclosure of materials used in civil filing	DOJ: prior court orders and Rule 6(e) prohibit redisclosure; sealing appropriate	Denied — public disclosure not authorized; petitioner gave no basis to modify disclosure conditions
Use of grand-jury materials in sealed filings / government response	Rtskhiladze: sought clarification and relief after sealing of his Rule 60 filing	DOJ: sought sealing and asked this Court to confirm disclosure limits; requested ability to respond under seal	Granted nunc pro tunc — both petitioner and government may disclose excerpts obtained from the review only in sealed filings in the related civil case

In re Grand Jury, 490 F.3d 978 (D.C. Cir. 2007) (addressing witness access to grand-jury materials but not resolving entitlement to copies)
United States v. John Doe, Inc. I, 481 U.S. 102 (1987) (noting witnesses are not automatically entitled to copies of their grand-jury testimony due to secrecy and intimidation concerns)