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Case 1:20-cr-00330-PAE Document518 Filed 11/30/21 Page7of8 The Honorable Alison J. Nathan November 30, 2021 Page 7 Finally, Rule 613, invoked by the government, has nothing to do with this issue. That rule addresses extrinsic evidence of prior inconsistent statements. The photograph Ms. Maxwell offered into evidence is not a prior inconsistent statement. rer Ms. Maxwell had no obligation (and has no obligation going forward) to disclose to the government any evidence (e.g., books, papers, documents, data, photographs, tangible objects, buildings or places) she does not intend to use during her “case-in-chief.” Fed. R. Crim. P. 16(b)(1)(A). Requiring such disclosure would violate the Fifth and Sixth Amendments. U.S. Const. amends. V, VI. This Court should reject the government’s contrary argument. DOJ-OGR-00008200