NRS 172.241 affords the target of a grand jury investigation the opportunity to testify before them unless, after holding “a closed hearing on the matter,” the district court determines that adequate cause exists to withhold target notice. NRS 172.241(3) specifies that “[t]he district attorney may apply to the court for a determination that adequate cause exists to withhold notice, if the district attorney.... [d]etermines” that the target poses a flight risk, cannot be located or, as relevant here, “that the notice may endanger the life or property of other persons.” Accordingly, NRS 172.241’s procedure for withholding notice is met if the State presents sufficient evidence to the district court, through written application and/or at oral argument, should the court require it, to allow the court to conclude by written order that that adequate cause to withhold notice of the grand jury proceedings exists.
Valiente, Michael S., "Summary of State v. Beaudion, 131 Nev. Adv. Op. No. 48 (Jul. 2, 2015)" (2015). Nevada Supreme Court Summaries. 890.