The following excerpt is from Harris v. U.S., 758 F.2d 456 (9th Cir. 1985):
Furthermore, such summonses do not violate the Fifth Amendment, since the documents in question belong to the recordkeeper and production will not compel the opponent of the summons to be a witness against himself. Fisher v. United States, 425 U.S. 391, 397, 96 S.Ct. 1569, 1574, 48
Page 458
2. Use of Summonses For Criminal Investigation
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