{
  "document_metadata": {
    "page_number": "4",
    "document_number": "518",
    "date": "November 30, 2021",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 518 Filed 11/30/21 Page 4 of 8\nThe Honorable Alison J. Nathan\nNovember 30, 2021\nPage 4\nMs. Maxwell does not have disclose any \"books, papers, documents, data, photographs, tangible objects, buildings or places, or copies or portions of any of these items\" she does not intend to use in her \"case-in-chief.\"\nThe government is doubly wrong to say that impeachment evidence is limited to inconsistent statements. Ms. Maxwell can impeach a prosecution witness's testimony with any admissible exhibit. The decision in United States v. Hatfield makes this clear.\nIn Hatfield, the government sought a Rule 16(b)(1)(A) order compelling the defendant to disclose six categories of evidence:\n(1) the Tactical Armor Products, Inc. computers and servers, as described in the testimony of Rex Harris on June 3, 2008; (2) all computers of DHB Industries, Inc., as described in the testimony of Rex Harris on June 3, 2008; (3) all computers personally used by and/or issued to David H. Brooks; (4) all Toshiba laptops issued by DHB to Dawn Schlegel; (5) the stationery books obtained by David Brooks from the \"Joon\" stationary store; and (6) the binder prepared by Caroline Pang containing 2003 Monthly Point Blank Body Armor (\"PBBA\") inventory reports.\nUnited States v. Hatfield, No. 06-CR-0550, 2009 WL 10673619, at *2 (E.D.N.Y. Apr. 22, 2009).\nThe district court refused the government's request, as should this Court. As Judge Seybert explained:\nBecause [the defendant] will not be using these items to support his case in chief, [he] is not required to disclose the items under Rule 16. . . .\nThe Court rejects the Government's argument that [the defendant] is required to turn over the above documents pursuant to Rule 16 because [the defendant] may use the items to impeach Government witnesses. Rule 16 mandates disclosure of any documents and tangible objects that the defendant will use in his case-in-chief, and not items which the defendant will use to impeach witnesses.\nHatfield, 2009 WL 10673619, at *1-2 (citing Medearis & Moore) (full citations omitted). See also United States v. Cerro, 775 F.2d 908, 915 (7th Cir. 1985) (\"Pretrial discovery of federal criminal defendants is regulated in detail by Rules 12.1, 12.2, and 16 of the Federal Rules of Criminal Procedure.\")\nDOJ-OGR-00008197",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 518 Filed 11/30/21 Page 4 of 8",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "The Honorable Alison J. Nathan\nNovember 30, 2021\nPage 4",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Ms. Maxwell does not have disclose any \"books, papers, documents, data, photographs, tangible objects, buildings or places, or copies or portions of any of these items\" she does not intend to use in her \"case-in-chief.\"\nThe government is doubly wrong to say that impeachment evidence is limited to inconsistent statements. Ms. Maxwell can impeach a prosecution witness's testimony with any admissible exhibit. The decision in United States v. Hatfield makes this clear.\nIn Hatfield, the government sought a Rule 16(b)(1)(A) order compelling the defendant to disclose six categories of evidence:\n(1) the Tactical Armor Products, Inc. computers and servers, as described in the testimony of Rex Harris on June 3, 2008; (2) all computers of DHB Industries, Inc., as described in the testimony of Rex Harris on June 3, 2008; (3) all computers personally used by and/or issued to David H. Brooks; (4) all Toshiba laptops issued by DHB to Dawn Schlegel; (5) the stationery books obtained by David Brooks from the \"Joon\" stationary store; and (6) the binder prepared by Caroline Pang containing 2003 Monthly Point Blank Body Armor (\"PBBA\") inventory reports.\nUnited States v. Hatfield, No. 06-CR-0550, 2009 WL 10673619, at *2 (E.D.N.Y. Apr. 22, 2009).\nThe district court refused the government's request, as should this Court. As Judge Seybert explained:\nBecause [the defendant] will not be using these items to support his case in chief, [he] is not required to disclose the items under Rule 16. . . .\nThe Court rejects the Government's argument that [the defendant] is required to turn over the above documents pursuant to Rule 16 because [the defendant] may use the items to impeach Government witnesses. Rule 16 mandates disclosure of any documents and tangible objects that the defendant will use in his case-in-chief, and not items which the defendant will use to impeach witnesses.\nHatfield, 2009 WL 10673619, at *1-2 (citing Medearis & Moore) (full citations omitted). See also United States v. Cerro, 775 F.2d 908, 915 (7th Cir. 1985) (\"Pretrial discovery of federal criminal defendants is regulated in detail by Rules 12.1, 12.2, and 16 of the Federal Rules of Criminal Procedure.\")",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00008197",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ms. Maxwell",
      "Rex Harris",
      "David H. Brooks",
      "Dawn Schlegel",
      "Caroline Pang",
      "Judge Seybert",
      "Medearis & Moore"
    ],
    "organizations": [
      "Tactical Armor Products, Inc.",
      "DHB Industries, Inc.",
      "DHB",
      "Joon",
      "Point Blank Body Armor"
    ],
    "locations": [
      "E.D.N.Y."
    ],
    "dates": [
      "November 30, 2021",
      "June 3, 2008",
      "April 22, 2009",
      "2003"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 518",
      "06-CR-0550",
      "2009 WL 10673619",
      "775 F.2d 908",
      "DOJ-OGR-00008197"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case, with a formal tone and legal language. There are no visible redactions or damage to the document."
}