case did not satisfy this standard. Because the credibility of a witness who testifies to substantive facts is a material issue at trial, evidence impeaching the witness’s credibility cannot be deemed “immaterial.” United States v. White, 972 F.2d 16, 20 (2d Cir.1992). Nevertheless, such evidence is not necessarily material to the jury’s verdict when it is cumulative of other impeachment evidence known to the jury. See id. at 21; see also United States v. Avellino, 136 F.3d 249, 258 (2d Cir.1998). That is the case here. Insofar as the newly discovered evidence revealed that Shapovalov had engaged in fraudulent activity beyond what he acknowledged at trial, the criminal conduct was sufficiently similar to be cumulative. See, e.g., United States v. Orena, 32 F.3d 704, 717 (2d Cir.1994) (<HOLDING>). To the extent the new evidence also indicated
holding that witnesss undisclosed criminal activity did not warrant new trial where jury heard evidence of other similar crimes holding in a criminal context that the probative value of evidence of other crimes is not substantially outweighed by danger of unfair prejudice where the court will give a limiting jury charge holding evidence of other crimes inadmissible when identity is not at issue holding that new evidence impeaching credibility of governments key witness was cumulative of other evidence of witness criminal activity holding trial court did not abuse its discretion in admitting highly probative and relevant evidence of other crimes