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IN RE GRAND JURY SUBPOENA

No. 11-20750.

696 F.3d 428 (2012)

In re GRAND JURY SUBPOENA.

United States Court of Appeals, Fifth Circuit.

September 21, 2012.

Attorney(s) appearing for the Case

Frank Phillip Cihlar , Sr. Counsel, Gregory Victor Davis , Samuel Robert Lyons , Alexander Patrick Robbins (argued), Tax Div., App. Sec., Jonathan Richard Marx , U.S. Dept. of Justice, Washington, DC, for Plaintiff-Appellant.

Larry A. Campagna , Chamberlain, Hrdlicka, White, Williams & Aughtry, Houston, TX, George Blay Abney (argued), Chamberlain, Hrdlicka, White, Williams & Aughtry, Atlanta, GA, for Defendant-Appellee.

Before DAVIS, DENNIS and HAYNES, Circuit Judges.

DENNIS, Circuit Judge:

This appeal arises from a grand-jury investigation in which the target of the investigation (the "witness") was subpoenaed to produce any records of foreign bank accounts he was required to keep under Treasury Department regulations governing offshore banking. The witness informed the government that he would not comply with the subpoena, citing his Fifth Amendment privilege against self-incrimination, and the government moved to compel the...

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