LeFlore v Robinson Reply Brief on Rehearing for Defendants-Appellees

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January 1, 1971

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LeFlore v Robinson Reply Brief on Rehearing for Defendants-Appellees preview

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Date is approximate.

Impact area
- Economic Justice
Topic
- Economic Justice
Collection
- Brief Collection
Taxonomy
Identifier
- b8400f0b-bb9a-ee11-be36-6045bdeb8873

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Legal Department General, Lani Guinier Correspondence. Correspondence from Lani Guinier to Walter McGowan Re: United States v. Jordan, 1983. 7bbb7c29-e592-ee11-be37-6045bdeb8873. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/1dd0acc7-732c-4ce7-be78-8f40f13cad8c/correspondence-from-lani-guinier-to-walter-mcgowan-re-united-states-v-jordan. Accessed August 19, 2025.

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June 23, 1983

Mr. Walter McGowan
Gray, Seay & Langford
P. O. Box 239
Tuskegee, Afabama 36083

RE: U Jo rdan

Dear WaLter:

Pursuant to your request, i have enclosed my pre-
liminary draft of a Motion for disclosure of
impeaching information. fn addition, I have enclosed
citation references to recent or oft-cited cases
construing Brady v. Maryland,'373 U.S. 83 (1963).
Time constraints limit,ed my search to the U. S. Supremc
Court and to the Fifth and Eleventh Circuits. I hope
boLh materials prove to be he1pful.

At this writing, the Lega1 Defense Fund has not yet
determined whether it will- be possibLe to assist. you
in a formal capacity. In lieu of a final dete::mination
on this matter, I will- rer:rain avai-labIe for advice,
discussionr or questions.

I enjoyed our conversatio;r of this afternoon. If I may
be of further assistance, please do not hesitate to
contact me.

Best of luckl

AYA/ r

Or t nl r i lt u l i t t rt s u rt tl rtl uct i ltLt' !,r {i, 5, i tr ro r rt r: ltt.r p u t' }x,st s

The NAACP LEGAL 0EFENSE & EDUCATIONAL FUND rs not part ol the National Assocration lor the Advancernert ol Colorcd Peoplc alll,,)ugh rr

was founded by it a nd shares its comm itment lo equal rights. LDF has had for over 25 years a sepa rate Board, pr og ram, stal l, o,fic0 anc budget.

An thony
Law Stu

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te rn



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The defendant respectfully moves this court for entry of

an order directing the state to investigate and disclose all

of the following within the possession, custody, controlr oI

the existence of which is known or by the exercise of due

diligence could become knovrn to the state

I. Any and al1 consiclerations or promises of consideration

given to or made on behalf of state witnesses. By "consideration",

defendant refers to absolutely anything of value or use, including

but not limited to irnmunity grants, witness fees, special witness

fees:r. transportation assistance, assistance to members of witness'

family or associates of witness, assistance or favorable treatment

with respect to any criminal, civilr oI administrative dispute

with .the state or the United States, and anything else which could

arguably create an interest or bias in the witness in favor of

al" s.tate- or against the defense or acts as an inducement to

testify or .to color testimony;

2. Any. and alI prosecutions, investigations or possible

prosecutions pending or which could be brought against the witness

and any probd.tionary, parole or deferred. prosecution status of

the witn.ess..;

3. 'Any .and alI records and information showing prior

mis,conduct:or bad acts committed by the witness.

' ' 4. Apy and all personnel files for the vritness.



BRAD, v. r,lARyLAND,Q^ u.s. 83 (1963).

I. U.S. Supreme Court:

408 u. s.
427 ,
405 'it

386 ,
360 ',
455 ,
455 '!t

454 '|r

44L 'i,

442 '|,

447 r'

786
97
1s0
66
254
2L9
24L
909
236
504
268

rr. Fifth circuit

319 ts.2d 80
656 " 1203
660 " 1076
661 " 42
66L " 448
66L " 1068
664 " 1025
665 " 641
668 " 859
674 " 479
52L " 702' 699 " 260
699 " 709
69r " 711
692 " 356
697 " 605
652 " 558

III. Eleventh Circuit

690 F.2d 1337

IV. Other Circuits
3d)
2d.)
4rh)

(D. c.. )
(3d)
( 2d)

22L F.2d 763
. 326 " 135
' 33r " 842

363 " 287
327 " L'7 4
324 " 8r4

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LeFlore v Robinson Reply Brief on Rehearing for Defendants-Appellees

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