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    Supplemental Notice of Intent To Use Expert Witnesses at Trial

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    Aiola Virella García
    This document provides supplemental information about expert witnesses that the United States intends to call at trial. It lists updated prior testimony details for six experts: a forensic pathologist, forensic chemist, forensic odontologist, ShotSpotter analyst, FBI cell analysis expert, and digital forensic analyst. For most experts, it provides additional past trial or deposition testimony from the last 4 years. For one expert, it notes they have not previously testified as an expert.

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    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd

    Supplemental Notice of Intent To Use Expert Witnesses at Trial

    Uploaded by

    Aiola Virella García
    4K views7 pages
    This document provides supplemental information about expert witnesses that the United States intends to call at trial. It lists updated prior testimony details for six experts: a forensic pathologist, forensic chemist, forensic odontologist, ShotSpotter analyst, FBI cell analysis expert, and digital forensic analyst. For most experts, it provides additional past trial or deposition testimony from the last 4 years. For one expert, it notes they have not previously testified as an expert.

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    Federales caso Verdejo.

    Original Title

    15919000085

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    This document provides supplemental information about expert witnesses that the United States intends to call at trial. It lists updated prior testimony details for six experts: a forensic pathologist, forensic chemist, forensic odontologist, ShotSpotter analyst, FBI cell analysis expert, and digital forensic analyst. For most experts, it provides additional past trial or deposition testimony from the last 4 years. For one expert, it notes they have not previously testified as an expert.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    4K views7 pages

    Supplemental Notice of Intent To Use Expert Witnesses at Trial

    Uploaded by

    Aiola Virella García
    This document provides supplemental information about expert witnesses that the United States intends to call at trial. It lists updated prior testimony details for six experts: a forensic pathologist, forensic chemist, forensic odontologist, ShotSpotter analyst, FBI cell analysis expert, and digital forensic analyst. For most experts, it provides additional past trial or deposition testimony from the last 4 years. For one expert, it notes they have not previously testified as an expert.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    of 7

    Case 3:21-cr-00161-PAD Document 275 Filed 03/27/23 Page 1 of 7

    UNITED STATES DISTRICT COURT FOR THE


    DISTRICT OF PUERTO RICO

    UNITED STATES OF AMERICA

    CRIMINAL NO. 21-161-PAD


    v.

    [1] FELIX VERDEJO-SANCHEZ,


    Defendant.

    SUPPLEMENTAL NOTICE OF INTENT TO USE EXPERT WITNESSES AT TRIAL

    TO THE HONORABLE COURT:

    The United States hereby supplements the information provided in its notice at docket

    number 225 on each of the following experts:

    1. Rosa Rodríguez Castillo, MD, Forensic Pathologist, Puerto Rico Institute of Forensic

    Sciences

    The government has produced to the defense a report, signed by Dr. Rodríguez Castillo,

    that contains all the opinions and the bases and reasons for them. Dr. Rodríguez Castillo has not

    authored publications in the previous 10 years. She has testified as an expert at trial or deposition

    in the following cases in the past 4 years:

    2023:

    ICF-2022-05903 – Superior Court of Carolina, Puerto Rico

    1
    Case 3:21-cr-00161-PAD Document 275 Filed 03/27/23 Page 2 of 7

    2022:

    PAT-0007-22 / PAT-0008-22 / PAT-0009-22 / PAT-0010-22- Superior Court of Carolina,


    Puerto Rico

    PAT-5943-18 / PAT-5999-18 – Superior Court of Caguas, Puerto Rico

    ICF-2022-05968 (1) / ICF-2022-05968 (3) – Superior Court of Arecibo, Puerto Rico

    2021

    PAT-1320-14 / PAT-1321-14 / PAT-1322-14 – Superior Court of Aibonito, Puerto Rico

    PAT-0972-21 – Superior Court of Ponce, Puerto Rico

    PAT-5862-18- Superior Court of Ponce, Puerto Rico

    PAT-3951-20 – Superior Court of Aguadilla, Puerto Rico

    PAT-1989-20 – Superior Court of Caguas, Puerto Rico

    2020

    PAT-0560-14 – Superior Court of Aibonito, Puerto Rico

    PAT-0123-16 – Superior Court of Fajardo, Puerto Rico

    2019

    PAT-5811-16 / PAT-5812-16- Superior Court of Arecibo, Puerto Rico

    PAT-1242-18 – Superior Court of Guayama, Puerto Rico

    PAT-1198-16 – Superior Court of Fajardo, Puerto Rico

    PAT-1843-19- Superior Court of Mayaguez, Puerto Rico

    PAT-2543-17 / PAT-2544-17 - Superior Court of San Juan, Puerto Rico

    PAT-5117-18- Superior Court of Aibonito, Puerto Rico

    2
    Case 3:21-cr-00161-PAD Document 275 Filed 03/27/23 Page 3 of 7

    2. Luz A. Silva Torres, Forensic Chemist, Puerto Rico Institute of Forensic Sciences

    The government has produced to the defense a report, signed by Ms. Silva Torres, that

    contains all the opinions and the bases and reasons for them. Ms. Silva Torres has authored or

    co-authored the following publications in the past 10 years:

    Simultaneous Determination of Xylazine, Free Morphine, Codeine, 6-Acetylmorphine,

    Cocaine and Benzoylecgonine in Postmortem Blood by UPLC-MS-MS, Journal of

    Analytical Toxicology (2012)

    Toxicity and Apoptosis Related Effects of Benzimidazo [3,2-a] Quinolinium Salts upon

    Human Lymphoma Cells, The Open Medicinal Chemistry Journal (2017)

    Xyalzine as a Drug of Abuse and its Effects on the Generation of Reactive Species and

    DNA Damage on Human Umbilical Vein Endothelial Cells, Journal of Toxicology (2014)

    Toxic Effects of Xylazine on Endothelial Cells in Combination with Cocaine and 6-

    Monoacetylmorphine, Toxicology in Vitro (2014)

    Xylazine and its Speedball Combination: Induction of Apoptosis by Intrinsic and Extrinsic

    Pathway in Human Umbilical Vein Endothelial Cells, Journal of Substance Abuse and

    Alcoholism (2014)

    3
    Case 3:21-cr-00161-PAD Document 275 Filed 03/27/23 Page 4 of 7

    Ms. Silva Torres has testified as an expert at trial or deposition in the following

    cases in the past 4 years:

    Pueblo v. Luis Lopez Mercado- Superior Court of Aguadilla, Puerto Rico (2022)

    Pueblo v. Daneliz Lozada Fernandez, Superior Court of Bayamón (2022)

    Pueblo v. Iam Luis Rodriguez Ayala, Superior Court of Caguas (2021)

    Pueblo v. José A. Colón Santiago, Superior Court of Ponce, Puerto Rico (2021)

    Pueblo v. Paul A. Izquierdo Aleman, Superior Court of Caguas, Puerto Rico (2021)

    EVI2020G0008 - Superior Court of Caguas, Puerto Rico

    3. Xiomara Rivera, DMD, Forensic Odontologist

    The government has produced to the defense a report, signed by Ms. Rivera, that contains

    all the opinions and the bases and reasons for them. Ms. Rivera has not authored publications in

    the previous 10 years. Ms. Rivera testified as an expert in trials or depositions in the following

    cases in the past 4 years: United States of America v. Jorge L. Rodríguez-Santos (2019); Pueblo

    Vs. Alejandro Castillo Torres (2018)

    4. Paul Greene, Forensic Services, ShotSpotter

    Mr. Greene has not authored publications in the previous 10 years. His prior expert

    testimony in the past 4 years was disclosed at docket number 225-1. Since that filing, Mr. Greene

    has also provided expert testimony in the following cases:

    • People v Otis Wyatt - Alameda County, California (2022)

    • People v John Harris- Alameda County, California (2023)

    4
    Case 3:21-cr-00161-PAD Document 275 Filed 03/27/23 Page 5 of 7

    • Commonwealth v Tony Evans and Lorenzo Jones – Boston, Massachusetts (2023)

    • People v Michael Ortiz-San Diego, California (2023)

    • Fernando Sevilla, Willie Samuels- Alameda County, California (2023)

    5. Mathew J. Wilde, Special Agent, FBI Cellular Analysis Survey Team,

    Mr. Wilde has not authored publications in the previous 10 years. His prior expert

    testimony in the past 4 years was disclosed at docket number 225-1.

    6. Joseph Soeka, Digital Investigative Analyst, United States Department of Justice

    Mr. Soeka has not authored publications in the previous 10 years. He has not testified as

    an expert at trial or by deposition in the previous 4 years.

    5
    Case 3:21-cr-00161-PAD Document 275 Filed 03/27/23 Page 6 of 7

    WHEREFORE, the United States respectfully requests from the Honorable Court to take

    notice of the above-stated information for any action deemed just and proper.

    RESPECTFULLY SUBMITTED.

    In San Juan, Puerto Rico, this 27th day of March, 2023.

    W. Stephen Muldrow
    United States Attorney

    s/ Jeanette Collazo
    Jeanette Collazo
    Assistant U.S. Attorney
    U.S.D.C./PR Bar 226803
    Torre Chardon, Suite 1201
    350 Carlos Chardon Avenue
    San Juan, PR 00918
    (787) 766-5656
    [email protected]

    s/ Jonathan Gottfried
    Jonathan Gottfried, U.S.D.C.-PR G02510
    Assistant United States Attorney
    Torre Chardon, Suite 1201
    350 Chardon Street
    San Juan, PR 00918

    6
    Case 3:21-cr-00161-PAD Document 275 Filed 03/27/23 Page 7 of 7

    CERTIFICATE OF SERVICE

    I hereby certify that on this 27th day of March, 2023, I electronically filed the foregoing

    with the Clerk of Court using the CM/ECF system, which will send notification of such filing to

    all CM/ECF participants.

    s/ Jonathan Gottfried
    Assistant United States Attorney

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