mirror-epstein-docs/results/IMAGES004/DOJ-OGR-00011644.json

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    "page_number": "23",
    "document_number": "739",
    "date": "08/10/22",
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  "full_text": "Case 1:20-cr-00330-PAE Document 739 Filed 08/10/22 Page 23 of 43 23 LBNAMAXTps and the extraction of metadata as his expert testimony, Mr. Flatley's views on those questions should be available through the 3500 material and through his other expert testimony, so there's really no need for any sort of further identification by the government of anything before Mr. Kelso should be able to let us know his views on those questions. MS. MENNINGER: Your Honor, the 3500 material doesn't say Mr. Flatley is going to describe the extraction of user data this way. He's talked about the fact that he has observed the user data, but he hasn't talked about the methods that he's used it. It's not that type of 3500 material from the government. So I don't agree that we could tell from what they have provided thus far exactly what Mr. Flatley's testimony is going to be. And frankly, they said Mr. Flatley was largely a fact witness as well. So if I'm understanding now that they're intending to offer something along the lines Mr. Kelso is, they didn't provide sufficient notice for Mr. Flatley's expertise in that area either. THE COURT: Well, I have to go back and look at the notice. But are you using Flatley as an expert? MR. ROHRBACH: We think Mr. Flatley is primarily a fact witness, but the line between a fact witness in a setting like this and someone testifying on the basis of their expertise is not well settled, and so we've given expert notice SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00011644",
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      "content": "Case 1:20-cr-00330-PAE Document 739 Filed 08/10/22 Page 23 of 43 23 LBNAMAXTps",
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      "content": "and the extraction of metadata as his expert testimony, Mr. Flatley's views on those questions should be available through the 3500 material and through his other expert testimony, so there's really no need for any sort of further identification by the government of anything before Mr. Kelso should be able to let us know his views on those questions.",
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      "content": "MS. MENNINGER: Your Honor, the 3500 material doesn't say Mr. Flatley is going to describe the extraction of user data this way. He's talked about the fact that he has observed the user data, but he hasn't talked about the methods that he's used it. It's not that type of 3500 material from the government. So I don't agree that we could tell from what they have provided thus far exactly what Mr. Flatley's testimony is going to be. And frankly, they said Mr. Flatley was largely a fact witness as well. So if I'm understanding now that they're intending to offer something along the lines Mr. Kelso is, they didn't provide sufficient notice for Mr. Flatley's expertise in that area either.",
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    {
      "type": "printed",
      "content": "THE COURT: Well, I have to go back and look at the notice. But are you using Flatley as an expert?",
      "position": "middle"
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    {
      "type": "printed",
      "content": "MR. ROHRBACH: We think Mr. Flatley is primarily a fact witness, but the line between a fact witness in a setting like this and someone testifying on the basis of their expertise is not well settled, and so we've given expert notice",
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      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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      "content": "DOJ-OGR-00011644",
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  "entities": {
    "people": [
      "Mr. Flatley",
      "Mr. Kelso",
      "MS. MENNINGER",
      "MR. ROHRBACH"
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      "SOUTHERN DISTRICT REPORTERS, P.C.",
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    "dates": [
      "08/10/22"
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      "1:20-cr-00330-PAE",
      "739",
      "DOJ-OGR-00011644"
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