Title: Gov Disclosure of Giglio Material, 15 Oct 12

Release Date: 2014-03-20

Text: Joint Base Myer-Henderson HallFort Myer, Virginia 22211UNITED STATES OF AMERICA V. Prosecution Disclosure ofGiglio MaterialManning, Bradley E. PF C, U.S. Army, HHC, U.S. Army Garrison, 15 October 2012On 22 June 2012, the United States submitted its initial Witness List in the abovereferenced court?martial. See Appellate Exhibit (AE) CLXII. On I4 August 2012 and 4September 2012, the United States submitted its Witness Lists regarding Article 13, UniformCode of Military Justice (UCMJ). See Appellate Exhibit Beginning in July 2012,the United States began requesting any impeachment materials for witnesses not being offeredpurely for authentication purposes. The United States requested that the departments, agencies,organizations, and military commands, to which the government witnesses are employed orassigned, conduct a thorough and comprehensive search of their own records for impeachmentmaterial and disclose any responsive records. See enclosed sample Giglio request; see alsoGiglio v. United States, 405 U.S. 150 (1972).As of 15 October 2012, the United States has reviewed its own ?les and records receivedin response to its requests. ln addition to prior disclosures, the United States discloses thefollowing and makes available for inspection all discoverable material:1. CDR Youssef Aboul-Enein. The prosecution did not ?nd any such material relating to thiswitness.2. SFC Paul Adkins. In addition to disclosure(s) already provided, any material relating to thiswitness is available for inspection with the prosecution.3. - The prosecution will coordinate with the particular department, agency,organization, or military command for any impeachment material. Should any impeachmentmaterial be found, the prosecution immediately will make such material available for inspection.4. The prosecution will coordinate with the particular department, agency,organization, or military command for any impeachment material. Should any impeachmentmaterial be found, the prosecution immediately will make such material available for inspection.5. SPC Mag Amiatu. The prosecution will coordinate with the particular department, agency,organization, or military command for any impeachment material. Should any impeachmentmaterial be found, the prosecution immediately will make such material available for inspection.6. SPC Kga Amos. The prosecution will coordinate with the particular department, agency,organization, or military command for any impeachment material. Should any impeachmentmaterial be found, the prosecution immediately will make such material available for inspection. 9APPELLATE PAGE REFERENCED:oi: PAGES 1FOR OFFICIAL USE BUT FOR OFFICIAL USE BUT UNCLASSIFIED7. . Any material relating to this witness is available for inspection with theprosecution.8. Mr. Peter Artale. Any material relating to this witness is available for inspection with theprosecution.9. SPC Eric Baker. The prosecution did not ?nd any such material relating to this witness.l0. The prosecution did not ?nd any such material relating to thiswitness.l. WOI Kyle Balonek. The prosecution did not ?nd any such material relating to this witness.12. The prosecution did not ?nd any such material relating to thiswitness.13. Mr. Joseph Benthal. The prosecution will coordinate with the particular department, agency,organization, or military command for any impeachment material. Should any impeachmentmaterial be found, the prosecution immediately Will make such material available for inspection.14. SA Troy Bettencourt. The prosecution did not ?nd any such material relating to thiswitness.15. SSG Peter Bigelow. Any material relating to this witness is available for inspection with theprosecution.16. Mr. Wyatt Bora. The prosecution did not ?nd any such material relating to this witness.l7. The prosecution did not ?nd any such material relating to this witness.I8. Mr. Steve Buchanan. The prosecution did not ?nd any such material relating to this witness.19. BG (Ret.) Robert Carr. The prosecution did not ?nd any such material relating to thiswitness.20. Mr. Sean Chamberlin. The prosecution did not ?nd any such material relating to thiswitness.21. CPT Thomas Cherepko. The prosecution did not ?nd any such material relating to thiswitness.22. SA Charles Clapper. The prosecution did not ?nd any such material relating to this witness.23. The prosecution will coordinate with the particular department,agency, organization, or military command for any impeachment material. Should anyimpeachment material be found, the prosecution immediately will make such material availablefor inspection.2FOR OFFICIAL USE BUT UNCLASSIFIEDFOR OFFICIAL USE BUT UNCLASSIFIED24. The prosecution will coordinate with the particular department,agency, organization, or military command for any impeachment material. Should anyimpeachment material be found, the prosecution immediately will make such material availablefor inspection.25. SGT Lorena Cooley. The prosecution did not ?nd any such material relating to this witness.26. Ms. Elizabeth Dibble. The prosecution did not ?nd any such material relating to thiswitness.27. Mr. Vann Van Diepen. The prosecution did not ?nd any such material relating to thiswitness.28. Mr. Jim Downey. The prosecution will coordinate with the particular department, agency,organization, or military command for any impeachment material. Should any impeachmentmaterial be found, the prosecution immediately will make such material available for inspection.29. The prosecution did not ?nd any such material relating to this witness.30. SA Antonio Edwards. The prosecution did not ?nd any such material relating to thiswitness.3 I. SA Kirk Ellis. The prosecution did not ?nd any such material relating to this witness.32. Mr. John eeley. The prosecution did not ?nd any such material relating to this witness.33. The prosecution will coordinate with the particular department, agency,organization, or military command for any impeachment material. Should any impeachmentmaterial be found, the prosecution immediately will make such material available for inspection.34. CPT Matthew Freeburg. Any material relating to this witness is available for inspectionwith the prosecution.35. CPT Casey Fulton. The prosecution did not ?nd any such material relating to this witness.36. Mr. James Fung. The prosecution did not ?nd any such material relating to this witness.37. Ms. Shelia Glenn. The prosecution did not ?nd any such material relating to this witness.38. The prosecution did not ?nd any such material relating to this witness.39. SA Toni Graham. The prosecution did not ?nd any such material relating to this witness.40. Mr. Jacob Grant. The prosecution did not ?nd any such material relating to this witness.4l. The prosecution did not ?nd any such material relating to this witness.42. VADM Robert Harward. The prosecution did not ?nd any such material relating to thiswitness.3FOR OFFICIAL USE BUT UNCLASSIFIED FOR OFFICIAL USE BUT UNCLASSIFIED43. Mr. Patrick Hoeffel. The prosecution will coordinate with the particular department,agency, organization, or military command for any impeachment material. Should anyimpeachment material be found, the prosecution immediately will make such material availablefor inspection.44. Mr. Matthew Hosburgh. The prosecution will coordinate with the particular department,agency, organization, or military command for any impeachment material. Should anyimpeachment material be found, the prosecution immediately will make such material availablefor inspection.45. LT (US Navy) Thomas Hoskins. The prosecution did not ?nd any such material relating tothis witness.46. The prosecution will coordinate with the particular department, agency,organization, or military command for any impeachment material. Should any impeachmentmaterial be found, the prosecution immediately will make such material available for inspection.47. The prosecution did not ?nd any such material relating to this witness.48. The prosecution will coordinate with the particular department, agency,organization, or military command for any impeachment material. Should any impeachmentmaterial be found, the prosecution immediately will make such material available for inspection.49. Ms. Elisa K. (Rubin) Ivory. The prosecution did not ?nd any such material relating to thiswitness.50. Mr. Albert J. anek. The prosecution did not ?nd any such material relating to this witness.Mr. Glen Johnson. The prosecution did not ?nd any such material relating to this witness.52. SA Mark Johnson. The prosecution did not ?nd any such material relating to this witness.53. AMB Patrick F. Kennedy. The prosecution did not ?nd any such material relating to thiswitness.54. The prosecution did not ?nd any such material relating to this witness.55. Mr. John Kirchoffer. The prosecution did not ?nd any such material relating to this witness.56. AMB Michael Kozak. The prosecution did not ?nd any such material relating to thiswitness.57. Mr. Adrian Lamo. In addition to discIosure(s) already provided, any material relating to thiswitness is available for inspection with the prosecution.58. CW5 Jon Larue. The prosecution did not ?nd any such material relating to this witness.59. Mr. Danny J. Lewis. The prosecution did not ?nd any such material relating to this witness.4FOR OFFICIAL USE BUT UNCLASSIFIEDFOR OFFICIAL USE BUT UNCLASSIFIED60. CPT Steven Lim. Any material relating to this witness is available for inspection with theprosecution.61. ?The prosecution did not find any such material relating to thiswitness.62. SGT Chad Madaras. The prosecution did not ?nd any such material relating to this witness.63. Mr. Brian Madrid. The prosecution will coordinate with the particular department, agency,organization, or military command for any impeachment material. Should any impeachmentmaterial be found, the prosecution immediately will make such material available for inspection.64. Ms. Tamara Mairena. The prosecution did not ?nd any such material relating to thiswitness.65. SA Mark Mander. Any material relating to this witness is available for inspection with theprosecution.66. SGT Aleiandro Marin. The prosecution did not ?nd any such material relating to thiswitness.67. The prosecution did not ?nd any such material relating to this witness.68. Mr. James McCarl. The prosecution did not ?nd any such material relating to this witness.69. Mr. Vince McCarron. The prosecution did not ?nd any such material relating to thiswitness.70. The prosecution did not ?nd any such material relating to this witness.71. Mr. James McManus. The prosecution did not ?nd any such material relating to thiswitness.72. COL David Miller. The prosecution did not ?nd any such material relating to this witness.73. Mr. Jason Milliman. The prosecution will coordinate with the particular department,agency, organization, or military command for any impeachment material. Should anyimpeachment material be found, the prosecution immediately will make such material availablefor inspection.74. Mr. James Moore. The prosecution did not ?nd any such material relating to this witness.75. Mr. Ken Moser. The prosecution did not ?nd any such material relating to this witness.76. Mr. Jeffery Motes. The prosecution did not ?nd any such material relating to this witness.77. Mr. Troy Moul. The prosecution did not ?nd any such material relating to this witness.78. Mr. Kin Moy. The prosecution did not ?nd any such material relating to this witness.5FOR OFFICIAL USE BUT UNCLASSIFIEDFOR OFFICIAL USE BUT UNCLASSIFIED79. The prosecution will coordinate with the particular department,agency, organization, or military command for any impeachment material. Should anyimpeachment material be found, the prosecution immediately will make such material availablefor inspection.80. Mr. Nicholas Murphy. Any material relating to this witness is available for inspection withthe prosecution.81. Lt Col (R) Martin Nehring. The prosecution did not ?nd any such material relating to thiswitness.82. The prosecution will coordinate with the particular department,agency, organization, or military command for any impeachment material. Should anyimpeachment material be found, the prosecution immediately will make such material availablefor inspection.83. SGT Daniel Padgett. The prosecution did not find any such material relating to this witness.84. AMB David Pearce. The prosecution did not ?nd any such material relating to this witness.85. Mr. H. Dean Pittman. The prosecution did not find any such material relating to thiswitness.86. Lt Col Robert Pope. The prosecution did not find any such material relating to this witness.87. The prosecution did not find any such material relating to this witness.88. SA Calder Robertson. The prosecution did not find any such material relating to thiswitness.89. LTC Rodney Roberts. The prosecution did not find any such material relating to thiswitness.90. The prosecution will coordinate with the particular department,agency, organization, or military command for any impeachment material. Should anyimpeachment material be found, the prosecution immediately will make such material availablefor inspection.91. SA Ronald Rock. The prosecution did not find any such material relating to this witness.92. CW4 Armond Rouillard. The prosecution did not find any such material relating to thiswitness.93. SGT David Sadtler. Any material relating to this witness is available for inspection with theprosecution.94. Mr. Doug Schasteen. The prosecution will coordinate with the particular department,agency, organization, or military command for any impeachment material. Should any6FOR OFFICIAL USE BUT UNCLASSIFIEDFOR OFFICIAL USE BUT UNCLASSIFIEDimpeachment material be found, the prosecution immediately will make such material availablefor inspection.95. Ms. Jacqueline Scott. The prosecution did not ?nd any such material relating to thiswitness.96. AMB Stephen Seche. The prosecution did not find any such material relating to thiswitness.97. SAC David Shaver. The prosecution did not find any such material relating to this witness.98. Ms. Jihrleah Showman. The prosecution will coordinate with the particular department,agency, organization, or military command for any impeachment material. Should anyimpeachment material be found, the prosecution immediately will make such material availablefor inspection.99. SA Thomas Smith. The prosecution did not ?nd any such material relating to this witness.100. SA Mitchell Song. The prosecution will coordinate with the particular department, agency,organization, or military command for any impeachment material. Should any impeachmentmaterial be found, the prosecution immediately will make such material available for inspection.l0l. Any material relating to this witness is available for inspection with theprosecution.102. 1 The prosecution did not ?nd any such material relating to thiswitness.I03. The prosecution did not ?nd any such material relating to this witness.104. Ms. Strobl. The prosecution will coordinate with the particular department,agency, organization, or military command for any impeachment material. Should anyimpeachment material be found, the prosecution immediately will make such material availablefor inspection.I05. Ms. Susan Swart. The prosecution did not ?nd any such material relating to this witness.106. Ms. Tasha Thian. The prosecution did not ?nd any such material relating to this witness.107. SSG Robert Thomas, Ill. The prosecution did not ?nd any such material relating to thiswitness.108. Mr. Louis Travieso. The prosecution will coordinate with the particular department,agency, organization, or military command for any impeachment material. Should anyimpeachment material be found, the prosecution immediately will make such material availablefor inspection.7FOR OFFICIAL USE BUT UNCLASSIFIEDFOR OFFICIAL USE BUT UNCLASSIFIEDI09. The prosecution did not ?nd any such material relating to thiswitness.I 10. Ms. Shari Villarosa. The prosecution did not ?nd any such material relating to thiswitness.1 1 1. Any material relating to this witness is available for inspection withthe prosecution.I I2. Mr. Greg Weaver. The prosecution did not ?nd any such material relating to this witness.13. Ms. Florinda White. The prosecution will coordinate with the particular department,agency, organization, or military command for any impeachment material. Should anyimpeachment material be found, the prosecution immediately will make such material availablefor inspection.1 14. SA John Wilbur. The prosecution did not find any such material relating to this witness.ll5. SA Alfred Williamson. The prosecution did not ?nd any such material relating to thiswitness.I 16. Mr. Charlie Wisecarver. The prosecution did not ?nd any such material relating to thiswitness.1 17. Mr. Alex Withers. The prosecution did not ?nd any such material relating to this witness.118. RDML David Woods. The prosecution did not ?nd any such material relating to thiswitness.19. AMB Don Yamamoto. The prosecution did not ?nd any such material relating to thiswitness.120. SA Garon Young. Any material relating to this witness is available for inspection with theprosecution.12]. Mr. Joseph Yun. The prosecution did not ?nd any such material relating to this witness.Article 13 Witnesses:122. CWO4 James Averhart. Any material relating to this witness is available for inspectionwith the prosecution.123. CWO2 Denise Barnes. The prosecution did not ?nd any such material relating to this-witness.124. Craig Blenis. The prosecution did not ?nd any such material relating to this witness.8FOR OFFICIAL USE BUT UNCLASSIFIEDFOR OFFICIAL BUT UNCLASSIFIED125. CPT Joseph Casamatta. The prosecution did not ?nd any such material relating to thiswitness.126. Col (R) Daniel Choike. The prosecution did not ?nd any such material relating to thiswitness.127. Jonathan Cline. The prosecution did not ?nd any such material relating to thiswitness.128. COL Carl Coffman. The prosecution did not ?nd any such material relating to this witness.129. William Fuller. The prosecution did not ?nd any such material relating to thiswitness.130. CWO5 Abel Galaviz. The prosecution did not ?nd any such material relating to thiswitness.131. SSG Ryan Jordan. The prosecution did not ?nd any such material relating to this witness.132. Brian Papakie. The prosecution did not ?nd any such material relating to thiswitness.133. CAPT (R) Jonathan Richardson. The prosecution did not ?nd any such material relating tothis witness.134. LTC Robert Russell. The prosecution did not ?nd any such material relating to thiswitness.135. Mr. Joshua Tankersly. The prosecution did not ?nd any such material relating to thiswitness.136. GMI Terrance Webb. The prosecution did not ?nd any such material relating to thiswitness.137. LCDR Eve Weber. The prosecution did not ?nd any such material relating to this witness.138. 1SG Bruce Williams. The prosecution did not ?nd any such material relating to thiswitness.139. Mai Timothy Zelek. Any material relating to this witness is available for inspection withthe prosecution.The United States acknowledges its continuing obligation to make available additionalimpeachment information if it is discovered.9FOR OFFICIAL USE BUT UNCLASSIFIEDFOR OFFICIAL USE BUT UNCLASSIFIEDThe United States will request impeachment material for its Article 10 witnesses andmake any responsive material available for inspection.J. HCIETER WHYTECPT, AAssistant Trial CounselEnclosureI certify that I served or caused to be served a true copy of the above on Mr. DavidCoombs, Civilian Defense Counsel via electronic mail, on 15 October 2012.J. Hg: ER WHYTECPT, AAssistant Trial Counsel10FOR OFFICIAL USE BUT UNCLASSIFIED

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