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Case 1:20-cr-00330-PAE Document507 - Filed 11/24/21 Page 24 of 28 experts, however, and before any testimony by the forensic document specialists, the defense must say more about these witnesses’ opinions and the bases for them. The Government is not able to take a position on the reliability or relevance of those opinions from the face of the expert notice. Given the proximity to trial, any additional delay to provide sufficient notice should be closely scrutinized by the Court, and entirely precluded if notice is not provided forthwith. A. Robert Kelso and John Lopez The defendant anticipates calling Robert Kelso, a computer forensics specialist, to testify about: (Ex. A at 12-13). the user data associated with certain devices seized and searched by the government’s team in this case, documents and photographs extracted from certain of those devices, and the metadata associated with certain documents and photographs. He may also testify generally about computer forensic principles associated with the creation of documents, storage and retrieval of digital documents and photographs, including the limits to the information that can be gleaned from the metadata. Mr. Kelso may testify in rebuttal to any testimony offered by the government through Stephen Flatley. As trial preparation proceeds, the defense will update the topics for Mr. Kelso if any arise. Similarly, the defendant anticipates John Lopez, a financial investigator, to testify about: (Id. at 13). his review of certain financial records provided by the government in discovery. Specifically, Mr. Lopez will discuss various transfers of funds that are reflected in the financial records and explain the information contained in the financial records regarding those transfers. To the extent Kelso and Lopez are expected to summarize evidence otherwise in the record, that testimony is not expert testimony, and therefore its admission is not precluded by Rule 702. 22 DOJ-OGR-00008065