Coker make a collateral estoppel argument because, as explained earlier, that doctrine does not apply in criminal cases. She says that it would have been useful to impeach Walsh, but the record shows that her counsel used a copy of Walsh’s plea agreement to impeach Walsh at the sentencing hearing, and that Walsh freely admitted to cooperating with the government in order to get a lower sentence. This cross-examination rendered any undisclosed stipulation irrelevant and immaterial. United States v. Soto-Beniquez, 356 F.3d 1, 40 (1st Cir.2003) (no Brady violation when details of plea agreement were not disclosed because cross-examination showed that witness was receiving favorable treatment from government in return for testimony); United States v. Jones, 160 F.3d 473, 479 (8th Cir.1998) (<HOLDING>). 3. Calculation of Loss Amount The PSR stated
holding that the disclosure of proper rebuttal witness was not required holding witnesss prior consistent statement admissible where defense counsel implied in his opening statement that witness should not be believed because of the favorable consideration he received from the government in his plea bargaining agreement 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 that disclosure of plea agreement would not have led to different result because crossexamination showed that witness was receiving favorable treatment from the government holding that the prosecutors statement about a witnesss truthfulness was proper because the evidence showed that the witness complied with the plea agreement not that he told the truth simply because he entered into the plea agreement