...150 (1972) require the Government to disclose to defendants certain evidence that will aid their defense. Brady requires disclosure of exculpatory evidence. Under Giglio, the Government has a duty to produce “not only exculpatory material, but also information that could be used to impeach a key government witness.” United States...

...150 (1972) require the Government to disclose to defendants certain evidence that will aid their defense. Brady requires disclosure of exculpatory evidence. Under Giglio, the Government has a duty to produce “not only exculpatory material, but also information that could be used to impeach a key government witness.” United States...

...150, 154 (1972)). The government’s attempt to evade the NPA flies in the face of these time-honored, and honorable, principles. Rather than stand behind the promises it made in the NPA, the government tries to escape them by arguing that Ms. Maxwell has no standing to enforce them...

...150, 154-55 (1972))). The standard for relevance is “very low,” United States v. White, 692 F.3d 235, 246 (2d Cir. 2012) (explaining that Rule 401 prescribes a “very low standard”), and the definition of relevance is “very broad,” United States v. Certified Envil. Servs., Inc., 753 F.3d...

...150, 154-55 (1972); In re Sealed Case No. 99-3096 (Brady Obligations), 185 F.3d 887, 892 (D.C. Cir. 1999). Moreover, the defense is already in possession of witness statements that one or both of the defendants in this indictment may have conducted rounds or inmate counts on...

...150, 154-55 (1972), goes to the heart of Brady and Giglio. See Napue v. People of State of Illinois, 360 U.S. 264, 269 (1959) (“The jury's estimate of the truthfulness and reliability of a given witness may well be determinative of guilt or innocence.”). DOJ-OGR-00003984

...150, 154-55 (1972))).? Lastly, Ms. Maxwell has a constitutional right to compulsory process, U.S. Const. amend. VI, which includes the ability to compel production of relevant documents. See Nixon, 418 U.S. at 711. B. The materials requested are relevant. The standard for relevance is “very low,” United...

...150 (1972), and 18 U.S.C. § 3500, and that it will be prepared to make all necessary disclosures at the appropriate time to minimize any delay at trial. Moreover, although the government is not obligated to obtain information not presently in its possession, it may be improper for the...

...150, 154-55 (1972) 20.0... cceccecceccucscesensscccceescuseaseaeeas 15 In ve Sealed Case No, 99-3096 (Brady Obligations), 185 F.3d 887, 892 (D.C. Cir. 1999)........ i5 United States v. Armstrong, 517 U.S. 456, 462 (1996) oo... ccc cecccseveseusceccseeceveesenseeersesess 8 United States v. Ashley, 905 F. Supp. 1146, 1168...

...150 (1972), requires disclosure of any materials that might be used to impeach key witnesses “in sufficient time that the defendant will have a reasonable opportunity to act upon the information efficaciously.” United States v. Rodriguez, 496 F.3d 221, 226 (2d Cir. 2007). In this District, the time which...

...150 (1972). The Government has yet to respond. DOJ-OGR-00001808

...150 (1972) and its progeny, consistent with the common practice and law within this Circuit. As indicated in a prior letter, the Government intends to produce all such materials to the defense well in advance of trial.' Specifically, although the parties have not yet conferred regarding a schedule for disclosure...