The following excerpt is from Giakoumelos v. Coughlin, 88 F.3d 56 (2nd Cir. 1996):
It is true that in a criminal case, on facts similar to this, the government would probably be put to the choice of disclosure of an informant's testimony or dropping the case. See United States v. Saa, 859 F.2d 1067, 1073 (2d Cir.1988), cert. denied, 489 U.S. 1089, 109 S.Ct. 1555, 103 L.Ed.2d 858 (1989) (In a criminal trial "[t]he defendant is generally able to establish a right to disclosure [of an informant's identity and testimony] where the informant is a key witness or participant in the crime charged, someone
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