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ishes "some extraordinary circumstance or compelling need." Martindell, 594 F.2d at 296. After concluding that reliance on the protective order was unreasonable,36 Chief Judge McMahon found that the "Government [ ] persuasively demonstrated extraordinary circumstances," citing "significant 36 See, e.g., hit'!
he defendant] of the Fifth Amendment privilege barred use of his confession at trial"); United States v. Mitchell, 966 F.2d 92, 100 (2d Cir. 1992) ("Inculpatory statements are not involuntary when they result from a desire to cooperate, or from a defendant's ignorance of, or inattention to, his right to rem
ishes "some extraordinary circumstance or compelling need." Martindell, 594 F.2d at 296. After concluding that reliance on the protective order was unreasonable,36 Chief Judge McMahon found that the "Government [ ] persuasively demonstrated extraordinary circumstances," citing "significant 36 See, e.g., hit'!
he defendant] of the Fifth Amendment privilege barred use of his confession at trial"); United States v. Mitchell, 966 F.2d 92, 100 (2d Cir. 1992) ("Inculpatory statements are not involuntary when they result from a desire to cooperate, or from a defendant's ignorance of, or inattention to, his right to rem
ishes "some extraordinary circumstance or compelling need." Martindell, 594 F.2d at 296. After concluding that reliance on the protective order was unreasonable,36 Chief Judge McMahon found that the "Government [ ] persuasively demonstrated extraordinary circumstances," citing "significant '6 See, e.g., Intl E
he defendant] of the Fifth Amendment privilege barred use of his confession at trial"); United States v. Mitchell, 966 F.2d 92, 100 (2d Cir. 1992) ("Inculpatory statements are not involuntary when they result from a desire to cooperate, or from a defendant's ignorance of, or inattention to, his right to rem
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