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Discovery of material used for impeachment

Posted: Fri Nov 09, 2012 8:29 pm
by SemperLegal
I think I might be overthinking this, since the supplements all seem to make a much smaller deal of the matter than I am, but:

The FRCP's on discovery exempt information " the use would be solely for impeachment" a few times. What is included:

A) I have a photograph of my client, the Plaintiff in a slip-and-fall, playing soccer on a "hurt knee" three days after the incident.
B) The same photograph, but I represent the client
C) Evidence that a witness that I intend to call is a pathological liar.
D) Evidence that a witness that I expect them to call is a pathological liar.

I know, my examples might not be perfect, and some might have Rule 11 implications, etc. but for the sake of my poor hypo drafting skills, assume that the only issue is scope of discovery.