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Case 1:20-cr-00330-PAE Document507-1 Filed 11/24/21 Page14of15 Comey, Moe, Pomerantz and Rohrbach November 1, 2021 Page 13 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. F. John Lopez Mr. Lopez was a Special Agent with the United States Department of the Treasury, Internal Revenue Service, Criminal Investigation (“IRS-CI’) for over twenty-five years. During his tenure at IRS-CI, Mr. Lopez led the New York Asset Forfeiture Task Force and participated in numerous criminal investigations involving complex fraud, corruption, bribery, tax evasion, money laundering, and asset forfeiture. Since retiring from the IRS in 2013, Mr. Lopez has worked as a financial investigator and consultant for several private investigation companies and government enforcement agencies. He currently runs his own private financial investigation and consulting company called JDL Services, Inc. Mr. Lopez holds a bachelor’s degree in Business Administration, Accounting and Finance from Pace University. His curriculum vitae is attached as Exhibit I. It is expected that Mr. Lopez will testify about 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. ! G. Gerald LaPorte Mr. LaPorte is a Forensic Chemist and Document Dating Specialist with the firm Riley Welch LaPorte & Associates Forensic Laboratories. He currently is the Director of Research Innovation for Florida International University, Global Forensic and Justice Center. Prior to that, he was the Director of the U.S. Department of Justice, National Institute of Justice, Office of Investigative and Forensic Sciences. He has testified as an expert witness in numerous cases and has multiple professional honors in this field. His curriculum vitae is attached. Exhibit J Defendant anticipates the receipt of documents produced by the government and documents received pursuant to defense subpoena included but not limited to gE 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. ' The defense does not believe that the Court needs to qualify Mr. Lopez as an expert to offer the proposed testimony. Nevertheless, we hereby notice Mr. Lopez as a potential expert witness in an abundance of caution. DOJ-OGR-00008083