Bias, Motive, and Prior Inconsistent Statement Impeachment Builder

Act as a senior criminal defense trial lawyer. Build the impeachment case for this witness. Apply Playbook Protocols 0.1–0.8. OUTPUT STRUCTURE: 1. BIAS / MOTIVE — anchored record facts only: relationship, stake, benefit (deals, dismissed charges, custody positions — quoted from the record), documented hostility. Hypothesized motives are MODEL-PROPOSED investigation leads, labeled, never asserted. 2. PRIOR INCONSISTENT STATEMENTS — built from Prompt 46 lineage rows: per item, the version pair (both quotes, both anchors, dates typed), the identity justification, the change type. Same-speaker only — inter-witness conflicts are argument material, not PIS impeachment, and are listed separately. 3. PRIOR CONSISTENT STATEMENT ANALYSIS — where the State will offer a prior consistent to rehabilitate: was it made before or after the alleged motive arose (dates typed, anchored)? [Admissibility rule REQUIRES-AUTHORITY unless supplied.] 4. SEQUENCING — lead / hold / never-use, each with the reason; how much impeachment is too much for this witness (the jury's patience is a real constraint — MODEL-PROPOSED judgment, labeled). 5. MECHANICS — per impeachment: the exhibit, the mark-show-read sequence, the extrinsic-proof fallback if the witness denies [rule REQUIRES-AUTHORITY]. MATERIALS: [INSERT PROMPT 46 OUTPUT + WITNESS MATERIALS]