April 2, 1999

xxxxxxxx, Esquire

Assistant United States Attorney

555 4th Street, N.W.

Washington, D.C. 20001

RE: United States v. xxxxxxxxxxxx

Case No. xx-445

Dear Mr. xxxxxxx:

Pursuant to our conversation I am requesting that you provide me with any Giglio information that you have on the co-defendants Mr. xxxxxx and Mr. xxxxxxx and any other witnesses that may be testifying against Mr. xxxxxxxx Additionally, I am requesting any evidence that is known to the government or can be discovered by the government that would be discoverable Brady material. I would also note for you that I am making a specific request under Kyles v. Whitley, 115 S.Ct. 1555 (1995), imposing upon law enforcement and the prosecutor a "Duty to Learn" favorable information relating to the defendant.

To that end I would request that all officers and investigative agencies concerned with this case make certain that I am apprized, in writing, of any information or any evidence that has come to light that might me viewed in anyway as "favorable" to Mr. xxxxxxxx. This includes information that is favorable to the defendant on the issues of suppression, guilt, and\or punishment from both a substantive perspective and as impeachment information and material tending to discredit the government's witnesses.

I am requesting not only any notes, documents, or physical evidence that might contain discoverable evidence, but also that you memorialize and provide me with any such information that has not yet been reduced to writing. This request continues until and throughout the trial should one occur. Please supply any new information as you become aware of it .

This request includes but is not limited to:

1. Prior inconsistent statements of witnesses

2. Prior convictions of witnesses

3. Any and all records and information revealing prior misconduct or bad acts attributed to any witness

4. Any and all consideration or promises of consideration given to or on behalf of the witness. By "consideration", defendant refers to absolutely anything of value or use, including but not limited to criminal, civil or tax immunity grants, assistance or favorable treatment or recommendations with respect to any criminal, civil, immigration, tax court, court of claims, administrative or other legal disputes with the government or any other parties, payment of money or fees, witness fees and special witness fees, provisions of food, clothing, shelter, transportation or other like benefits, placement in a "witness protection program", and anything else which could arguably reveal an interest or bias in the witness in favor of the government or against the defense or act as an inducement to testify or to color testimony.

5. Plea agreements

6. Any evidence of any drug use on the part of any witness

7. Any and all prosecutions, investigations, or potential prosecutions pending or which could be brought against the witness, and any criminal, civil, immigration, tax court, court of claims, administrative, or other pending potential legal disputes or transactions.

8. The existence and identification of each occasion on which the witness has testified before any court, grand jury, or other tribunal or body or otherwise narrated in relation to the Defendant, the investigation, or the facts of the case.

9. The existence and identification of each occasion on which each witness who is an informer, accomplice, co-conspirator, or expert has testified before any court, grand jury, or other tribunal or body.

If the government disputes its legal obligation to disclose or produce anything requested herein, please so advise so that the matters can be timely litigated.

Please feel free to contact me regarding this request. Thank you for your attention in this matter.

Best wishes and regards.

Yours Very Truly,

Maria Jankowski Assistant Federal Public Defender