What is the scope of a defendant's rebuttal in a criminal case?

Defendant acknowledges that "[t]he scope of rebuttal evidence is generally within the trial courts discretion." "The order of proof rests largely in the sound discretion of the trial court, and the fact that the evidence in question might have tended to support the prosecutions case-in-chief does not make it improper rebuttal. [Citations.] It is improper for the prosecution to deliberately withhold evidence that is appropriately part of its case-in-chief, in order to offer it after the defense rests its case and thus perhaps surprise the defense or unduly magnify the importance of the evidence. Nevertheless, when the evidence in question meets the requirements for impeachment it may be admitted on rebuttal to meet the evidence on a point the defense has put into dispute." ( People v. Coffman and Marlow , supra , 34 Cal.4th at p. 68, 17 Cal.Rptr.3d 710, 96 P.3d 30 ; see People v. Mayfield (1997) 14 Cal.4th 668, 762, 60 Cal.Rptr.2d 1, 928 P.2d 485 ["The trial court did not

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abuse its discretion when it permitted the prosecution to use [an out-of-court] statement in rebuttal, even though it was known to the prosecution before trial and could have been used during the prosecutions case-in-chief."].) " As with all relevant evidence, ... the trial court retains discretion to admit or exclude evidence offered for impeachment. [Citations.] A trial courts exercise of discretion in admitting or excluding evidence is reviewable for abuse [citation] and will not be disturbed except on a showing the trial court exercised its discretion in an arbitrary, capricious, or patently absurd manner that resulted in a manifest miscarriage of justice. [Citation.]" ( People v. Brown (2003) 31 Cal.4th 518, 534, 3 Cal.Rptr.3d 145, 73 P.3d 1137.)