The following excerpt is from U.S. v. Salerno, 937 F.2d 797 (2nd Cir. 1991):
We are cognizant of the reliability concerns that have led courts to exclude grand jury testimony from use by the prosecution at trial. See, e.g., United States v. Thevis, 665 F.2d 616, 629 (5th Cir. Unit B),
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