Steps for counsel to follow in the investigative state of grand jury proceedings include ascertaining the scope of the investigation and the client's role in the matter under investigation. The client should be interviewed exhaustively, and all other witnesses should be interviewed and debriefing memoranda prepared. The multiple representation of witnesses before a grand jury should be carefully weighed by counsel to ensure that such representation does not jeopardize the interests of any of the clients represented. When a corporation is the central target of an investigation, corporation counsel may find it wise to represent all employees called as witnesses. A joint defense where witnesses have separate counsel will offer the advantages of cooperation between witnesses' counsel while avoiding some of the disadvantages of multiple representation. In responding to grand jury process, counsel should challenge overzealous government activity at an early stage so as to confine the government to more reasonable limits later. The counsel must decide whether to advise the witness to use the fifth amendment privilege and whether to seek immunity from subsequent prosecution in exchange for testimony. The witness should be thoroughly prepared for the grand jury appearance. In appropriate cases, counsel can request the prosecutor to present all exculpatory evidence in his/her possession to the grand jury. The defense counsel should also consider requesting that the prosecutor submit instructions on matters of law to the grand jury. Ninety-eight footnotes are provided.