The following excerpt is from Willhoite v. Vasquez, 921 F.2d 247 (9th Cir. 1990):
My respected colleagues describe this case as involving a simple failure to disclose part of the plea agreement. I see it as more than that: It involves a pernicious scheme without any redeeming features, a scheme that can only spawn unnecessary post-trial motions and appeals when its presence in a case becomes known to the defense. The scheme violates both the letter and spirit of Giglio v. United States, 405 U.S. 150, 92 S.Ct. 763, 31 L.Ed.2d 104 (1972)(A prosecutor must disclose to the defense any inducements to a witness to testify.).
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