California, United States of America
The following excerpt is from People v. Danielson, D066317 (Cal. App. 2016):
emphasizing the importance of certain evidence by introducing it at the end of the trial; and (3) to avoid 'unfair surprise' to the defendant from confrontation with crucial evidence late in the trial." (People v. Young (2005) 34 Cal.4th 1149, 1199.)
" '[R]ebuttal testimony . . . may be proper when it is offered as impeachment to meet evidence on a point put in dispute, i.e., specific statements of fact to which the defense has testified.' " (People v. Senior (1992) 3 Cal.App.4th 765, 778 (Senior).) In Senior, the appellate court upheld the admission of rebuttal testimony where the defendant's "answers on direct examination put in issue whether he had ever used force or threats." The Senior court concluded it "was proper to impeach his categorical, blanket denials of threats with evidence of a threat made the same day he denied having threatened the victim with bashing her head and hurting her." (Ibid.)
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