The following excerpt is from U.S. v. Zielezinski, 740 F.2d 727 (9th Cir. 1984):
3 The reference to Fifth Amendment violations in Calandra was limited to improprieties in the evidence-gathering process. See Lawn v. United States, 355 U.S. 339, 78 S.Ct. 311, 2 L.Ed.2d 321 (1958). It does not speak to Fifth Amendment violations before the grand jury itself.
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