What is the test for disclosure of evidence in civil cases?

MultiRegion, United States of America

The following excerpt is from U.S. v. Gonzalez, 110 F.3d 936 (2nd Cir. 1997):

Defendants argue that the government violated its disclosure obligations both under the Jencks Act, 18 U.S.C. 3500 et seq. (requiring disclosure of statements of a government witness), and Brady v. Maryland, 373 U.S. 83, 83 S.Ct. 1194, 10 L.Ed.2d 215 (1963) (requiring disclosure of exculpatory evidence), in the following manner.

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