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Each time you go before a grand jury as a target or a subject or a person of interest ? or anyone else other than a plain old witness ? you put yourself in legal jeopardy. And now Rove will have done that five times. So today is not a good day for him no matter what his lawyers eventually decide to say about it.
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The court almost had to take up this issue again. It was clear in 2003 when it said that you could not limit this procedure unless certain exceptions were in place. Congress then enacted a law without those restrictions and now the court will have to decide whether the justification for the Congressional action is constitutional or not. It should be a very close case, almost certainly a five-four ruling.