MOTION FOR PRODUCTION OF IMPEACHABLE CONVICTIONS

OF PROSECUTION WITNESSES

The Defendant, *, by and through the undersigned counsel, moves this Court for an order requiring the government to produce a reasonable time before trial evidence of all impeachable convictions of witnesses called by the government, to include certified copies of judgments of convictions and sentences.

MEMORANDUM OF LAW

This motion is based upon the following authorities: Lewis v. United States, 408 F.2d 303 (D.C.Ct.App. 1979); Brady v. Maryland, 393 U.S. 83, 83 S.Ct. 1194, 10 L.Ed.2d 215 (1963); United States v. Augurs, 427 U.S. 97, 96 S.Ct. 2392, 49 L.Ed.2d 342 (1976); Williams v. Dutton, 400 F.2d 797 (5th Cir. 1968), cert.denied, 393 U.S. 1105 (1969), and authorities cited in these opinions.

DATED this___ day of October. 1995.

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