Motion for Disclosure of Substance of Promises or Plea Bargains — USA v. Okojie (Dkt. 37, S.D. Ga.)

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Filed September 15, 2022 as Document 37 in Case CR422-0084 (S.D. Ga., Savannah Division), this is Defendant Bernard Okojie's Motion for Substance of Promises or Plea Bargains Between Witnesses and Government. It asks the Court to order disclosure of any statements or discussions with witnesses, confidential informants or unindicted co-defendants indicating leniency, compensation, an assurance not to prosecute, or any other benefit in exchange for cooperation or testimony. It also asks for known probations, paroles and uncharged conduct bearing on a witness's motive. The motion argues such evidence is discoverable under the Due Process Clause, citing Giglio v. U.S. and Brady v. Maryland, and is signed by counsel John J. Ossick, Jr.

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IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF GEORGIA
SAVANNAH DIVISION
UNITED STATES OF AMERICA           )
       )
v.
       )
 CASE NUMBER: CR422-0084
       )
BERNARD OKOJIE, 
       )
Defendant 
       )
       )
DEFENDANT BERNARD OKOJIE’S       
MOTION FOR SUBSTANCE OF PROMISES
OR PLEA BARGAINS BETWEEN
WITNESSES AND GOVERNMENT
COMES NOW, BERNARD OKOJIE, Defendant in the above-styled action, by
and through his undersigned counsel of record, and moves the Court for the substance of
any and all statements or discussions had with any of the witnesses, confidential
informants, or unindicted co-defendants herein or with any such person’s counsel
indicating a promise or a suggestion of  leniency, compensation, assurance not to
prosecute, agreement to proceed on only certain counts of an indictment, representations
with respect to yet uncharged misconduct, or any benefit accruing to said individuals
whatsoever in exchange for their cooperation, assistance or testimony at the trial herein,
as well as any probations, paroles, pending charges or other offenses known to the
government which have not been charged, as same relate to a government witness’
motive for testifying on their behalf.
The evidence of any such representations by the government or which the
government will make at any future time is discoverable pursuant to the Due Process
Clause of the Fifth and Fourteenth Amendments to the Constitution, and the withholding 
Case 4:22-cr-00084-LGW-BWC     Document 37     Filed 09/15/22     Page 1 of 3

of any such evidence constitutes a denial to the Defendant herein of his Constitutionally
protected rights to due process and fundamental fairness in the criminal proceedings not
brought against them.  Giglio v. U.S., 405 U.S. 150 (1972); Brady v. Maryland, 373 U.S.
83 (1963).
Respectfully submitted, this 15th day of September, 2022.          
s/John J. Ossick, Jr. 
Georgia Bar Number 555150
JOHN J. OSSICK, JR., P.C.
Post Office Box 1087
Kingsland, Georgia 31548
Telephone:  912-729-5864 
E-mail: ossick@tds.net
Case 4:22-cr-00084-LGW-BWC     Document 37     Filed 09/15/22     Page 2 of 3

IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF GEORGIA
SAVANNAH DIVISION
UNITED STATES OF AMERICA           )
       )
v.
       )
 CASE NUMBER: CR422-0084
       )
BERNARD OKOJIE, 
       )
Defendant 
       )
       )
CERTIFICATE OF SERVICE
This is to certify that I have this day served all parties in this case in accordance
with the directives from the Court Notice of Electronic Filing (“NEF”), which was
generated as a result of electronic filing.
This 15th day of September, 2022.        
s/John J. Ossick, Jr. 
Georgia Bar Number 555150
JOHN J. OSSICK, JR., P.C.
Post Office Box 1087
Kingsland, Georgia 31548
Telephone:  912-729-5864 
E-mail: ossick@tds.net
Case 4:22-cr-00084-LGW-BWC     Document 37     Filed 09/15/22     Page 3 of 3

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