Cover letter citing cases and stating they do not consider impeachment or refreshing material as case-in-chief material.
This document is a page from a court transcript (Case 1:20-cr-00330-PAE, likely US v. Ghislaine Maxwell) filed on August 10, 2022. Defense attorney Mr. Everdell argues to the Judge that a photograph of a witness's house was not disclosed earlier because it was intended solely as impeachment material to contradict the witness's testimony, rather than evidence for the case-in-chief. The Judge and Mr. Everdell discuss Rule 16 discovery obligations, with the Judge noting that prosecutor Mr. Rohrbach likely agrees with the procedural distinction.
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