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Case 1:20-cr-00330-PAE Document507 Filed 11/24/21 Page 28 of 28 an order will likely permit the Government to interpose a Daubert challenge now. Absent rapid supplemental notice along these lines, the Court should preclude the forensic document specialists. CONCLUSION For the reasons set forth above, the Government respectfully requests that the Court preclude the testimony of Dr. Ryan Hall and Bennett Gershman; preclude any expert testimony (as opposed to fact testimony) by Robert Kelso or John Lopez; and preclude any testimony at all from the forensic document specialists, unless and until the defendant provides supplemental expert notice, which the Court should order the defense to provide forthwith. Dated: November 15, 2021 New York, New York Respectfully submitted, DAMIAN WILLIAMS United States Attorney for the Southern District of New York By: /s/ Maurene Comey Alison Moe Lara Pomerantz Andrew Rohrbach Assistant United States Attorneys 26 DOJ-OGR-00008069