In Doyle v. Hofstader, 257 N.Y. 244, 265-66, 177 N.E. 489, 497 (1931) Doyle was subpoenaed to a legislative committee investigating various New York City departments because "there had been preliminary testimony from the lips of other witnesses that fees of extraordinary magnitude had been paid for his services at the Board of Standards and Appeals during a period of years." Id. at 249, 177 N.E. at 490. Doyle refused to answer questions concerning whether he had divided these fees with anyone else, in furtherance of a concerted plan of bribery and corruption, and whether he had paid any part of them as a bribe to any public officer. Id.