The following excerpt is from Grand Jury Proceedings, In re, 600 F.2d 215 (9th Cir. 1979):
Appellant argues that his due process rights were violated in that he was denied the right to be represented by his retained attorney and to have his attorney file briefs and offer oral argument before the district court and that the district court relied on Ex parte and In camera submissions made without notice to him. This court recognizes the necessity of due process protections in contempt proceedings. See, e. g., United States v. Alter, 482 F.2d 1016 (9th Cir. 1973). On the record, however, we believe appellant's due process
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