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U.S. v. UNDER SEAL

No. 13-4267.

737 F.3d 330 (2013)

UNITED STATES of America, Plaintiff-Appellee, v. UNDER SEAL, Defendant-Appellant.

United States Court of Appeals, Fourth Circuit.

Decided: December 13, 2013.

Attorney(s) appearing for the Case

ARGUED: Caroline Rule , Kostelanetz & Fink, LLP, New York, NY, for Appellant. Elissa Hart-Mahan , United States Department of Justice, Washington, D.C. for Appellee. ON BRIEF: Robert Steven Fink , Juliet Leah Fink , Kostelanetz & Fink, LLP, New York, New York; David G. Barger , Greenberg Traurig, LLP, McLean, VA, for Appellant. Neil H. MacBride , United States Attorney, Office of the United States Attorney, Alexandria, VA; Kathryn Keneally , Assistant Attorney General, Frank P. Cihlar , Chief, Criminal Appeals & Tax Enforcement Policy Section, Gregory Victor Davis , Tax Division, United States Department of Justice, Washington, D.C. for Appellee.

Affirmed by published opinion. Judge AGEE wrote the opinion, in which Judge KING and Judge Gregory joined.

AGEE, Circuit Judge:

John and Jane Doe (the "Does") appeal the district court's order holding them in civil contempt for refusing to comply with grand jury subpoenas. The Does contend that the district court erred in finding that the required records doctrine overrode their Fifth Amendment privilege against self-incrimination and required production of certain foreign bank records. For the reasons that follow, we affirm the judgment of the district court.

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