Withheld evidence can resurface through the opposing side’s own documents.

Evidence

This prompted Mary Ryan to submit an affidavit asserting that “counsel for the defendant were fully aware of the Yankee” report during discovery. Neil Jacobs, she said, had known of the report as early as November 1984, and had received a copy she’d sent to him by messenger two months before trial. Ryan asserted that she had forty-one documents—letters, memos, telephone logs, and receipts from messengers—attesting to the truth of her statement. — , Harr Jonathan - A Civil Action, 3109

Categorization

• ADDENDUM: Feeds the Woburn litigation thread directly: the Yankees report and Ryan’s concealment are the same discovery-abuse arc traced elsewhere.