Did the timing and method of the Government's disclosure violate Todd's Fifth Amendment right to a fair trial

QUESTION PRESENTED FOR REVIEW Despite a specific discovery request and repeated follow-up, for years the Government suppressed footage from a digital video surveillance system later found to show alleged co-conspirator Antonio Jackson appearing to direct the subject drug deal on his own. Days before trial, the Government produced multiple hours and camera angles of footage from the system. But the timing and method of the Government’s disclosure prevented Todd from finding and using the exculpatory portion in time to cross-examine Jackson. Todd had no reason to: the Government did not identify Jackson before he testified, and Jackson and Todd had never seen, heard of, or spoken to one another. The question presented for review is: Did the timing and method of the Government’s disclosure violate Todd’s Fifth Amendment to right to a fair trial, by preventing Todd from finding and using the exculpatory footage in sufficient time to cross-examine Jackson and ascertain the truth about his conduct, thus prejudicing Todd and undermining confidence in the verdict against him? i LIST OF ALL THE PARTIES Petitioner, and defendant below, is Eric Todd. Respondent is the , United States of America.