In re Grand Jury Subpoenas, No. 10-15758, slip op. at 19638 (9th Cir. Dec. 7, 2010) (Noonan, J.) (holding that feds could get law firms' copies of documents they got from overseas in private antitrust litigation against makers of flat-panel liquid crystal displays).
By a chance of litigation, the documents have been moved from outside the grasp of the grand jury to within its grasp. No authority forbids the government from closing its grip on what lies within the jurisdiction of the grand jury.