the damning nature of her testimony. The information about the threats against Pletcher was essential to explain why she might testify against Simmons even if he was not in fact guilty. 2. Cobaugh’s Firearms Forms Cobaugh’s misrepresentation of her criminal history in attempting to purchase a handgun, and the prosecution’s assistance in helping her to avoid liability for that misrepresentation, were also highly relevant to Simmons’s case. First, Cobaugh made a misstatement under penalty of perjury, a fact that itself could have been used to impeach her testimony. The D.C. Circuit has described such prior perjurious statements as an “infirmity ... that is almost unique in its detrimental effect on a witness’ credibility.” United States v. Cuffie, 80 F.3d 514, 517-18 (D.C.Cir.1996) (<HOLDING>). Additionally, exposing Detective Rok’s and
holding proponent of a motion for continuance should state what specific discovery is material and show why it is material holding that disclosure during discovery of certain kinds of information including privileged material trade secrets attorney work product or material involving a confidential informant could constitute a material injury of an irreparable nature holding that any error in excluding impeachment evidence about witnesss drug use in general was harmless when witness was heavily impeached in other ways holding that it is proper to refer to evidence of prior acts of misconduct in the closing arguments on the issue of credibility but it is improper to argue about misdeeds for any purpose other than impeachment because the acts were submitted for impeachment purposes only holding that undisclosed evidence of witnesss prior perjury was material despite availability of other types of impeachment material