The following excerpt is from United States v. Cimino, No. 15-657 (2nd Cir. 2016):
When a witness at a criminal trial asserts her Fifth Amendment privilege, the district court must "undertake a particularized inquiry to determine whether the assertion was founded on a reasonable fear of prosecution as to each of the posed questions." United States v. Zappola, 646 F.2d 48, 53 (2d Cir. 1981). The district court conducted such a particularized analysis by allowing defense counsel to pose questions to the confidential informant outside the presence of the jury. The district court did not err in
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