Article: The Hyde amendment and prosecutorial investigation: the promise of protection for criminal defendants.

INTRODUCTION

Kermit Bunn appeared before a federal grand jury in response to a subpoena requiring him to certify the authenticity of corporate documents. (1) He refused to take the oath on the grounds that the prosecutor was not licensed to practice in that state. After this refusal, Bunn added, "I have legal paperwork on all of you [grand jurors]. You need to go get legal counsel." The court reporter recorded these comments, and the district court charged Bunn with contempt for threatening the grand jury. The court issued an order to show cause based on the transcript of the grand jury proceedings and the foreman's testimony that the grand jury members perceived ...

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