The D.C. Circuit, citing Branzburg v. Hayes, has declined to recognize the existence of qualified First Amendment in the grand jury context. In re Grand Jury Subpoena Miller, 397 F.3d 964 (D.C. Cir. 2005), opinion superseded by 438 F.3d 1141 (D.C. Cir. 2006). However, the press, like other citizens, may still seek protection from the court where harassment or bad faith can be established. See, e.g., In re Special Counsel Investigation, 332 F. Supp. 2d 26 (D.D.C. 2004); In re Grand Jury 95-1, 59 F. Supp. 2d 1, 8 (D.D.C.