United States v. Kirschner, 823 F. Supp. 2d 665, was a federal criminal case in Michigan. The defendant had previously been indicted by a grand jury under three counts of receipt of child pornography under 18 U.S.C. § 2252A(a)(2)(A). The government sought to use a grand jury subpoena post-indictment to acquire additional evidence: the contents of an encrypted file from the defendant's hard drive.