The following excerpt is from United States v. Kourani, 19-4292-cr (2nd Cir. 2021):
[22] Compare Rothgery v. Gillespie Cnty., Tex., 554 U.S. 191, 213 (2008) ("[A] criminal defendant's initial appearance before a judicial officer, where he learns the charge against him and his liberty is subject to restriction, marks the start of adversary judicial proceedings that trigger attachment of the Sixth Amendment right to counsel."), with United States v. Medunjanin, 752 F.3d 576, 585 (2d Cir. 2014) (describing the Fifth Amendment right to counsel, which is meant "to insure that the right against compulsory self-incrimination [i]s protected" (internal quotation marks omitted)).
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