Whether a federal agent's assurance to Haitian-citizen witnesses constituted a 'promise or offer' under Brady-Giglio-Napue

QUESTIONS PRESENTED FOR REVIEW 1. Whether a federal agent’s assurance that U.S. Immigration and Customs Enforcement, Homeland Security Investigations would “look into what we can do” for the government’s Haitian-citizen witnesses after the trial, made for the express purpose of securing their testimony, was a “promise or offer’ within the purview of Brady v. Maryland, 373 U.S. 83 (1963), Giglio v. United States, 405 U.S. 150 (1972), and Napue v. Illinois, 360 U.S. 264 (1959). 2. Whether, as the First, Second, Third, Fifth, and D.C. Circuits hold, the Constitutional prohibition against the prosecutorial use of false testimony encompasses testimony that is technically true but substantially misleading; or whether, as Eleventh and Sixth Circuits have held, Due Process is not violated unless the testimony is “literally” and “indisputably” false. i INTERESTED PARTIES AND RELATED PROECEDINGS There are no