It's only a 6(e) violation for a Government attorney or someone associated with one (including their investigators and agents) to disclose matters occurring before the grand jury. Witnesses before the grand jury and their attorneys are not under a secrecy rule. Transcripts of grand jury proceedings are not available to witness' lawyers before the investigation is over and an Indictment has been returned by the grand jury.

However, lawyers always debrief their clients after they testify and take notes as to what the client remembers being asked and remembers answering, and hope their clients are not mistaken or forgetting something. Defense lawyers are not allowed inside the federal grand jury room. They sit outside, and the clients are allowed to come out and talk to them during questioning if they have a question based on something the prosecutor has asked them. Lawyers can advise their client regarding the question, but they are not in the room to actually hear it. The client can come out as many times as is necessary.

When a client is in the grand jury room answering questions for several hours, it is doubtful they will remember every question asked and exactly how they answered, particularly if the prosecutor asks the same question numerous different ways.

So if you see that someone reviewed a grand jury transcript, first make sure the reporter got that right. And then realize it probably came from someone who is currently or formerly on Fitzgerald's team or was on Fitzgerald's team. If the article says the source "was familiar with" the witness' testimony or even that he or she "reviewed the testimony", they are probably talking about an oral recollection the witness gave his or her lawyers after testifying - and then the leak is probably from the witness's side.

But again, there is no grand jury secrecy rule for witnesses. Rove, Libby, Russert, etc, can all say what they remember being asked and remember answering. There is a total grand jury secrecy rule for anyone associated with the prosecutor --including lawyers, agents, court reporters, court personnel. etc.

I have only seen one article in which the reporter said someone reviewed the grand jury testimony and I immediately speculated it was a lawyer or agent now or formerly on Fitzgerald's team who was trying to help Rove because I assumed they meant they saw a transcript. If the reporter meant the source only reviewed debriefings of the testimony, then it's probably not Fitzgerald's team that's responsible. Here's the quote:

Sources who have reviewed some of the testimony before the grand jury say there is significant evidence that reporters were in some cases alerting officials about Plame's identity and relationship to Wilson -- not the other way around.