Roe v. United States

recognizing that “[f]ee information may be sought as evidence of unexplained wealth which may have been derived from criminal activity” | government not required to make preliminary showing of need prior to enforcement of grand jury subpoena served on attorney whose client is the unindicted target of grand jury investigation | government not required to make preliminary showing of need prior to enforcement of grand jury subpoena served on attorney whose client is the unindicted target of grand jury investigation | prior to indictment, adversary proceeding not initiated against grand jury target; Sixth Amendment right to counsel therefore did not attach and so did not prevent service of grand jury subpoena on target’s attorney | rejecting requirement to show in both pre- and post-indictment contexts | discussing an unpublished Fourth Circuit opinion addressing Harvey | “[i]n order to establish improper prejudgment of a case, it must appear to ‘a disinterested observer ... that [the agency] has in some measure adjudged the facts as well as the law of a particular case in advance of hearing it’” (citations omitted) | discussing an unpublished Fourth Circuit opinion addressing Harvey