The following excerpt is from U.S. v. Brown, 918 F.2d 82 (9th Cir. 1990):
Our decision in United States v. Rendahl, 746 F.2d 553 (9th Cir.1984), does not dictate a different result. In that case, we held that the defendants could raise their fifth amendment claims in the contempt proceeding when they did not have the opportunity to properly raise such a defense
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