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be N Ww ws Oo OY ~] oO WO a oO = be N Ww = Hs Oo a OY a ~] a oO a Ke) 20 21 22 23 24 25 Caédast: 2@2OrOCRMBRPAGN Demuiremtase Aiéelin/on271 Patppbléfdie@3 11 L9OL5berl death. We will not be eliciting expert medical testimony or opinion from this witness, he will be simply testifying to what he observed with respect to the victim's physical condition during the 10 intervening years between the shooting and the death and that's important evidence, it's evidence that will then be consistent with things that medical experts to be qualified as experts will be called to testify about, but those experts did not observe these injuries during the 10 intervening years. They also did not observe Mr. Jones prior to the shooting. For instance, they wouldn't be able to tell you whether he was in a wheelchair before the shooting or after the shooting. They wouldn't be able to tell you if he developed those bedsores before the shooting or after the shooting. It is Mr. Vega's observations that will allow the jury to connect those dots. Given how important causation is in this case, we think it is important that the jury understand those injuries. THE COURT: Will medical records, that will be introduced, describe the bedsores? MR. HOBSON: They will describe the bedsores at the time of the autopsy which was in November of 2010. THE COURT: What is the connection between bedsores and cause of death? Infection? MR. HOBSON: Your Honor, essentially what I expect the SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00011126