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P. 16(a)(1)(E). Evidence is material under Rule 16 if it "could be used to counter the government's case or to bolster a defense." United States v. Stevens, 985 F.2d 1175, 1180 (2d Cir. 1993). "The materiality standard [of Rule 16] normally is not a heavy burden; rather, evidence is material as long as
Page: EFTA00023330 →ence that tends to exculpate the accused, but also evidence that is useful to impeach the credibility of a government witness," id., also known as "Giglio material," as well as any statements of witnesses "which are contradictory or inconsistent with the government's theory of the case." United States
Page: EFTA00023330 →P. 16(a)(1)(E). Evidence is material under Rule 16 if it "could be used to counter the government's case or to bolster a defense." United States v. Stevens, 985 F.2d 1175, 1180 (2d Cir. 1993). "The materiality standard [of Rule 16] normally is not a heavy burden; rather, evidence is material as long as
ence that tends to exculpate the accused, but also evidence that is useful to impeach the credibility of a government witness," id., also known as "Giglio material," as well as any statements of witnesses "which are contradictory or inconsistent with the government's theory of the case." United States
ep't of Homeland Sec., 325 F. Supp. 3d 447 (S.D.N.Y. 2018) 27 Dept of Interior v. Klamath Water Users Protective Ass'n, 532 U.S. 1 (2001) 26, 27 Giglio v. United States, 405 U.S. 150 (1972) In re Sealed Case, 121 F.3d 729 (D.C. Cir. 1997) passim 26 In re Terrorist Bombings of U.S. Embassies in E.
Page: EFTA00027309 →United States v. Southland Corp., 760 F.2d 1366 (2d Cir. 1985) 15 United States v. Stein, 424 F. Supp. 2d 720 (S.D.N.Y. 2006) 21 United States v. Stevens, 985 F.2d 1175 (2d Cir. 1993) 9, 12 United States v. Thomas, 116 F.3d 606 (2d Cir. 1997) 12 United States v. Undenvood, No. 04 Cr. 424 (RWS), 200
Page: EFTA00027311 →t of Homeland Sec., 325 F. Supp. 3d 447 (S.D.N.Y. 2018) 27 Dep't of Interior v. Klamath Water Users Protective Ass 'it, 532 U.S. 1 (2001) 26, 27 Giglio v. United States, 405 U.S. 150 (1972) In re Sealed Case, 121 F.3d 729 (D.C. Cir. 1997) passim 26 In re Terrorist Bombings of U.S. Embassies in E.
Page: EFTA00031265 →United States v. Southland Corp., 760 F.2d 1366 (2d Cir. 1985) 15 United States v. Stein, 424 F. Supp. 2d 720 (S.D.N.Y. 2006) 21 United States v. Stevens, 985 F.2d 1175 (2d Cir. 1993) 9, 12 United States v. Thomas, 116 F.3d 606 (2d Cir. 1997) 12 United States v. Underwood, No. 04 Cr. 424 (RWS), 200
Page: EFTA00031267 →Entities connected to both Stevens and Giglio

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Brady
PERSON
Department of Justice
ORGANIZATION
Prince Andrew
PERSONFBI
ORGANIZATION
Scarlett Johansson
PERSONCollins
PERSON
George W. Bush
PERSONLeon Black
PERSONthe Southern District
LOCATION
Julie K. Brown
PERSONEmmy Taylor
PERSON
Michael Cohen
PERSON
Supreme Court
ORGANIZATION
Southern District of New York
ORGANIZATION
Marc Rich
PERSON
Virginia Giuffre
PERSON
Bradley Edwards
PERSON