. Having reviewed Pacheco’s submissions, the Court concludes that the evidence Rivera presents either works against- or fails to substantiate Rivera’s claim that the prosecution promised Pacheco that he would be released on low bail, or guaranteed immunity from prosecution. At most, Rivera has established through Pacheco’s state court docket sheets that Pacheco was in fact released on substantially reduced bail within a week of testifying at Rivera’s trial. But the fact that Pacheco ultimately received consideration does not establish by clear and convincing evidence that the prosecution had struck a deal with Pacheco before Pacheco testified, or that Pacheco’s release was other than the “consideration” for which Pacheco had hoped. Cf. Shabazz v. Artuz, 336 F.3d 154, 165 (2nd Cir.2003) (<HOLDING>) (footnote omitted); see also Bell v. Bell, 512
holding that prosecutions duty to present all material evidence to the jury was not fulfilled when it became known the government failed to disclose an alleged promise of leniency made to its key witness in return for his testimony holding that promises made by the prosecution to a witness in exchange for that witness testimony relate directly to the credibility of the witness holding that the fact that a prosecutor afforded favorable treatment to a government witness standing alone does not establish the existence of an underlying promise of leniency in exchange for testimony holding prosecutions failure to disclose promise of leniency to witness provided in exchange for that witnesss testimony violated due process holding that  201 does not sweep so broadly as to prevent prosecutors from offering leniency to an individual in exchange for truthful testimony