IN THE UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF KENTUCKY

COVINGTON

UNITED STATES OF AMERICA, : CRIMINAL NO. 90-59 (2)

(Judge William O. Bertelsman)

Plaintiff, :

-VS- :

xxxxxxxxxxxxxx, et al., :

Defendants. :

MOTION OF DEFENDANT xxxxxxxxxxxx FOR DISCLOSURE

OF PROMISES, ETC. TO GOVERNMENT WITNESSES

Now comes Defendant, xxxxxxxx, by and through counsel, and moves the Court for an Order requiring the Government to disclose to him whether any person or persons the Government intends to call as a witness were promised any reward or other inducement in exchange for obtaining their testimony.

Respectfully submitted,

________________________________________

THOMAS W. MILLER

Attorney for Defendant

309 Vine Street, Suite 440

Cincinnati, Ohio 45202

Telephone (513) 241-3050

MEMORANDUM

Counsel respectfully represents that in the preparing for trial of the instant case, it is necessary to determine whether any person or persons the Government intends to call at trial were promised any reward or other inducement in exchange for obtaining their testimony. Further, counsel respectfully represents that the information sought is material to the question of whether or not the testimony is to be believed by the trier of fact.

________________________________________

THOMAS W. MILLER

Attorney for Defendant

309 Vine Street, Suite 440

Cincinnati, Ohio 45202

Telephone (513) 241-3050

CERTIFICATE OF SERVICE

I hereby certify that a copy of the foregoing was hand delivered to the office of the Assistant U.S. Attorney, U.S. Post Office and Court House, Covington, Kentucky, on this _____day of August, 1990.

________________________________________

THOMAS W. MILLER Attorney for Defendant