__________________ DISTRICT OF TEXAS
										
__________________  DIVISION

UNITED STATES OF AMERICA	                 §
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_______________________________               §

MOTION TO PRODUCE ARRANGEMENTS MADE OR EXTENDED
TO GOVERNMENT WITNESSES AND BRIEF IN SUPPORT THEREOF

TO THE HONORABLE ///, JUDGE, UNITED STATES DISTRICT COURT FOR THE /// DISTRICT OF TEXAS, /// DIVISION:

	COMES NOW ///, Defendant in the above styled and numbered cause and respectfully moves the Court for an order directing the United States Attorney to reveal any arrangements, promises or benefits made or extended to any Government witnesses and for cause would show the Court as follows:
I.
MOTION
	The Defendant moves the Court to enter an order directing the United States Attorney to prepare and provide to the Defendant and his attorney a memorandum setting out in detail the extent and scope of all offers of immunity, promises of leniency, threats of prosecution, promises of assistance, benefits, payments in cash or in kind which have been or will be extended to any person who may be called as a witness by the Government or who has provided any information to the Government or cooperated with the Government in any way in regard to this case.  The Defendant requests that the foregoing be produced at least two weeks prior to trial. 
II.

BRIEF
	A Defendant is constitutionally entitled to be informed of and to display to a jury at trial any such promises of immunity or leniency, threats of prosecution, promises of assistance or any benefits extended to any Government witness in order to secure his testimony.  The withholding of such evidence constitutes a denial to the Defendant of his constitutionally protected rights to due process and fundamental fairness.  Giglio v. United States, 405 U.S. 150, 92 S.Ct.763, 31 L.Ed.2d 104 (1972); Brady v. Maryland, 373 U.S. 83 (1963).  Such evidence is not only exculpatory in the sense that it is a legitimate ground for impeachment of any witness that the Government may call against the Defendant, Williams v. Dutton, 400 F.2d 797 (5th Cir. 1968), but also is discoverable by the Defendant in order to show the witnesses’ bias or prejudice in testifying at trial.  Davis v. Alaska, 415 U.S. 308, 94 S.Ct. 1105, 39 L.Ed.2d 347 (1974).
	WHEREFORE, PREMISES CONSIDERED, the Defendant respectfully pray that this motion be in all things GRANTED.
							Respectfully Submitted,

							___________________________________
							Name
							State Bar No. 
							Address
							City, State, Zip
							Telephone
							Attorney for Defendant
							
CERTIFICATE OF SERVICE

	This is to certify that a true and correct copy of the foregoing Motion to Produce Arrangements Made or Extended to Government Witnesses and Brief in Support Thereof has been delivered to the Assistant United States Attorney at ________________________________, this ____ day of _________________________, 20____.

							__________________________________
							Attorney for Defendant

	

__________________ DISTRICT OF TEXAS
										
__________________  DIVISION

UNITED STATES OF AMERICA	                 §
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ORDER

	CAME ON TO BE CONSIDERED the Motion To Produce Arrangements Made or Extended to Government Witnesses of Defendant ///.  Having considered the motion and argument of counsel, it is hereby:
	(GRANTED, and the Government is ordered to provide to defense counsel, in writing, the extent and scope of all offers of immunity, promises of leniency, threats of prosecution, promises of assistance, benefits or payments which have been or will be extended to any person who may be called as a witness by the Government or who has provided any information to the Government or cooperated with the Government in any way in regard to this case, on or before ____________________, 20_____.)
	(DENIED, to which the Defendant duly excepts.) 
	It is so ORDERED.
	SIGNED on ____________________, 20_____.

							_____________________________________
							UNITED STATES DISTRICT JUDGE