Counsel may, however, wait outside of the grand jury room; and, at any and all times during questioning, a witness may leave the room to consult with his attorney.

Notwithstanding that unindicted grand jury witnesses do not have a right to have counsel present in the grand jury room,

Likewise, it Is clearly established under federal case law that there is no right to counsel before the grand jury.

—tests as: their demeanor while on the stand; any interest they might have in the outcome of the case; any bias or prejudice for or against either party; their opportunity to observe; any reason to remember or forget; the inherent probability of their testimony; its consistency or lack of consistency; and its corroboration or lack of corroboration with other credible evidence. The …

Similarly, such documents must be admitted when necessary "to ensure a `fair and impartial understanding'of the admitted portion. "

Furthermore, the Court finds that, as in the case of non-immunized witnesses who are allowed to speak with counsel outside the Grand Jury room at all times, so as to protect their Fifth Amendment privilege against self-incrimination, a "reasonable and workable accommodation of the traditional investigatory role of the grand jury" and the needs of the immunized witness …

[BOOK] Grand jury practice

[BOOK] Moore's federal practice

[BOOK] Federal Grand Jury Practice and Procedure