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Case 1:20-cr-00330-PAE Document507_ Filed 11/24/21 Page4of28 Crim. P. 16(b)(1)(C). As the 1993 amendments to Rule 16 note, the Rule is meant to “minimize surprise that often results from unexpected expert testimony, reduce the need for continuances, and to provide the opponent with a fair opportunity to test the merit of the expert’s testimony through focused cross-examination.” /d. 1993 Amend. Accordingly, the Rule requires the defense to provide (1) “notice of the expert’s qualifications which in turn will permit the requesting party to determine whether in fact the witness is an expert within the definition of Federal Rule of Evidence 702;” (2) a “summary of the expected testimony,” which “permit[s] more complete pretrial preparation by the requesting party;” and (3) “a summary of the bases of the expert’s opinion.” Jd. The content of the expert notice must actually “summarize the experts’ opinions.” United States v. Ulbricht, 858 F.3d 71, 115 (2d Cir. 2017), abrogated on other grounds by Carpenter v. United States, 138 S. Ct. 2206 (2018). “Merely identifying the general topics about which the expert will testify is insufficient; rather, the summary must reveal the expert’s actual opinions.” United States v. Valle, No. 12 Cr. 847 (PGG), 2013 WL 440687, at *5 (S.D.N.Y. Feb. 2, 2013); see Ulbricht, 858 F.3d at 115 (calling “plainly inadequate” a disclosure that “listed general and in some cases extremely broad topics on which the experts might opine”). The notice then must describe the bases and reasons for those opinions. “[A] general description of possible bases does not meet the requirements of Rule 16(b)(1)(C).” United States v. Tuzman, 2017 WL 6527261, at *10 (S.D.N.Y. Dec. 18, 2017) (internal quotation marks omitted). “Merely asserting that [an expert] will provide [an] opinion based on some unspecified method ... based on data from unspecified sources, does not suffice.” United States v. Ulbricht, No. 14 DOJ-OGR-00008045