Evidence of witness' subsequent admission that she was under the influence of narcotics while testifying that she was not a drug user is not new evidence sufficient to revisit the conviction, since the disclosures do not rise to the level of addressing basic competency to testify, and would at most be in for impeachment.
Government concealment of witness' mental state would not rise to the level of a Brady claim.
No abuse of discretion in refusal to grant downward variance from sentencing guidelines.
Concur in J:
The disclosures about the witness are new evidence, but aren't material.