mirror-epstein-docs/results/IMAGES003/DOJ-OGR-00008067.json

{
  "document_metadata": {
    "page_number": "26 of 28",
    "document_number": "507",
    "date": "11/24/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 507 Filed 11/24/21 Page 26 of 28\n\nAccordingly, the Court should preclude expert testimony from Kelso and Lopez unless and until the defense provides supplemental expert notice forthwith.12 If the defense does so, the Government should have an opportunity at that time to litigate its admissibility. And if the defense does not do so, those witnesses should be limited to purely factual testimony. See Lebedev, 932 F.3d at 50 (affirming a limiting instruction clarifying that the witness was not providing an expert opinion).\n\nB. Forensic Document Specialists\n\nFinally, the defendant has identified two forensic document specialists who she may call as expert witnesses. Gerald LaPorte is a \"Forensic Chemist and Document Dating Specialist,\" and Jennifer Naso is a \"Forensic Document Examiner.\" (Ex. A at 13-14). Regarding their expert opinions, the defendant writes:\n\nDefendant anticipates the receipt of documents produced by the government and documents received pursuant to defense subpoena included but not limited to journal pages by witness [Minor Victim-2]. These documents may require analysis regarding the dates of creation, completeness, alteration and manipulation. When these documents are disclosed, Defendant will seek to have them analyzed and present testimony on the analysis as needed.\n\n(Id. at 13-14).\n\nThis notice also does not provide the experts' \"opinions\" or \"the bases and reasons for those opinions.\" Fed. R. Crim. P. 16(b)(1)(C). It does not even identify the set of documents\n\n12 Similarly, absent additional expert notice, Kelso and Lopez should be required to limit their testimony to facts in the record. Experts—but not other witnesses—may rely on facts or data that are not admissible, and may disclose them to the jury in certain circumstances. See Fed. R. Evid. 703, 705.\n\n24\n\nDOJ-OGR-00008067",
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      "content": "Case 1:20-cr-00330-PAE Document 507 Filed 11/24/21 Page 26 of 28",
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    {
      "type": "printed",
      "content": "Accordingly, the Court should preclude expert testimony from Kelso and Lopez unless and until the defense provides supplemental expert notice forthwith.12 If the defense does so, the Government should have an opportunity at that time to litigate its admissibility. And if the defense does not do so, those witnesses should be limited to purely factual testimony. See Lebedev, 932 F.3d at 50 (affirming a limiting instruction clarifying that the witness was not providing an expert opinion).",
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    {
      "type": "printed",
      "content": "B. Forensic Document Specialists",
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    {
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      "content": "Finally, the defendant has identified two forensic document specialists who she may call as expert witnesses. Gerald LaPorte is a \"Forensic Chemist and Document Dating Specialist,\" and Jennifer Naso is a \"Forensic Document Examiner.\" (Ex. A at 13-14). Regarding their expert opinions, the defendant writes:\n\nDefendant anticipates the receipt of documents produced by the government and documents received pursuant to defense subpoena included but not limited to journal pages by witness [Minor Victim-2]. These documents may require analysis regarding the dates of creation, completeness, alteration and manipulation. When these documents are disclosed, Defendant will seek to have them analyzed and present testimony on the analysis as needed.\n\n(Id. at 13-14).\n\nThis notice also does not provide the experts' \"opinions\" or \"the bases and reasons for those opinions.\" Fed. R. Crim. P. 16(b)(1)(C). It does not even identify the set of documents",
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    {
      "type": "printed",
      "content": "12 Similarly, absent additional expert notice, Kelso and Lopez should be required to limit their testimony to facts in the record. Experts—but not other witnesses—may rely on facts or data that are not admissible, and may disclose them to the jury in certain circumstances. See Fed. R. Evid. 703, 705.",
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    {
      "type": "printed",
      "content": "24",
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    {
      "type": "printed",
      "content": "DOJ-OGR-00008067",
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  "entities": {
    "people": [
      "Kelso",
      "Lopez",
      "Gerald LaPorte",
      "Jennifer Naso",
      "Minor Victim-2"
    ],
    "organizations": [],
    "locations": [],
    "dates": [
      "11/24/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 507",
      "DOJ-OGR-00008067"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is mostly printed, with no handwritten content or stamps visible. The document is well-formatted and legible."
}