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Case 1:20-cr-00330-PAE Document518_ Filed 11/30/21 Page4of8 The Honorable Alison J. Nathan November 30, 2021 Page 4 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.” The 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. In Hatfield, the government sought a Rule 16(b)(1)(A) order compelling the defendant to disclose six categories of evidence: (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. United States v. Hatfield, No. 06-CR-0550, 2009 WL 10673619, at *2 (E.D.N.Y. Apr. 22, 2009). The district court refused the government’s request, as should this Court. As Judge Seybert explained: Because [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.... The 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. Hatfield, 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 DOJ-OGR-00008197