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`Case 2:18-cr-00422-SMB Document 1081 Filed 10/27/20 Page 1 of 21
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF ARIZONA
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`United States of America,
`
`
`Plaintiff,
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`v.
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`Michael Lacey, et al.,
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`Defendants.
`
`
`
`No. CR-18-00422-001-PHX-SMB
`
`ORDER
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`
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`Pending before the Court is Defendants’ Motion in Limine to Preclude Expert
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`Testimony (Doc. 928.) to which the Government has responded. (Doc. 958.) The
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`Government has also filed the United States’ Motion to Preclude Defendants’ Noticed
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`Experts. (Doc. 905.) Defendants’ filed a response (Doc. 956.) and requested oral
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`argument. The motions are related and so the Court enters a ruling on both motions in
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`limine here. The Court has determined that oral argument is unnecessary to decide these
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`motions. L.R. Civ. 7.2(f).
`
`I.
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`BACKGROUND
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`Defendants are former officers, executives, and employees of Backpage.com, a
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`classified advertisement website. On July 25, 2018, a federal grand jury returned a 100-
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`count Superseding Indictment against Defendants alleging their commission of numerous
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`criminal acts—conspiracy, violations of the Travel Act, and money laundering—in the
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`Case 2:18-cr-00422-SMB Document 1081 Filed 10/27/20 Page 2 of 21
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`operation of Backpage.com (“Backpage”). “The SI contains a lengthy summary of the
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`alleged facts.” Lacey, 423 F.Supp.3d at 753. Within its 92 pages, it alleges Defendants
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`“were aware that the overwhelming majority of the website’s ‘adult’ and ‘escort’ ads were
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`actually ads for prostitution and took a variety of steps to intentionally facilitate that illegal
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`activity.” (SI ¶ 34; see also id. ¶¶ 9-11.) It also alleges Defendants strategized to increase
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`the number of prostitution ads on Backpage.com and evade detection by moderating the
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`website and sanitizing the postings. (Id. ¶¶ 10-11, 13, 35-70, 72-73, 75, 77-96, 98-104, 108,
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`110, 112, 116-26, 128-30, 132-34, 136, 139, 143, 145, 148.) It further alleges these
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`strategies were created to “conceal the true nature of the ads on the website,” (Id. ¶ 11.),
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`identify prostitutes currently advertising on rival websites and offer them free ads on
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`Backpage.com in an attempt to secure future business (Id. ¶¶ 35-44.), engage with The
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`Erotic Review to create reciprocal links, and enter into formal business arrangements with
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`known prostitutes for repeat business. (Id. ¶¶ 45-67.)
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`The Government has disclosed ten experts to testify about sex trafficking and child sex
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`trafficking. The proposed testimony was described as follows in the Government’s
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`disclosure (Doc. 422.):
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`1. Christina Decouflé (Human Trafficking)
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`Detective Decouflé will provide testimony at trial about how human trafficking,
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`with a focus on sex trafficking occurs, and how it occurs through online media, such as
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`social networking websites, applications, and the internet in general. Detective Decouflé
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`has been a law enforcement officer with the Phoenix Police Department since 2000. In
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`2005, she became a detective in the Vice Enforcement Unit. In 2013, Detective Decouflé
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`became a member of the Federal Bureau of Investigation, Human Trafficking Task Force,
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`Phoenix Division. The Ninth Circuit has affirmed the expert testimony of Detective
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`Decouflé in the area of human trafficking and this court should permit Detective Decouflé
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`to testify as to her expert opinions here. See United States v. Brooks, 610 F.3d 1186, 1195-
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`96 (9th Cir. 2010).
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`Detective Decouflé will describe how sex trafficking and prosecution industries
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`Case 2:18-cr-00422-SMB Document 1081 Filed 10/27/20 Page 3 of 21
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`have changed with
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`the advent of
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`the
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`internet,
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`including websites such as
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`www.craigslist.com, www.backpage.com, and others. Detective Decouflé will describe
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`how law enforcement conducts human trafficking investigations; with a focus on how
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`investigations shifted from craigslist.com to backpage.com. She will testify about her
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`knowledge of The Erotic Review (TER), it’s owner David Elms, and TER’s connection to
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`websites such as craigslist.com and backpage.com. Detective Decouflé will describe how
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`she posted advertisements on online websites like craigslist.com and backpage.com
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`advertising herself (undercover) as seller of commercial sex. She will compare and contrast
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`how different prostitution websites (including craigslist and backpage) operated and how
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`they responded to law enforcement. She will also testify about descriptors and definitions
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`of terms often used in sex trafficking and the prostitution industry, such as “trick,” “John,”
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`“pimp,” “the game,” “dates,” “choosing up,” as examples. Lastly, Detective Decouflé will
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`discuss the relationship between sex traffickers and pimps and their victims. She will
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`describe the methods and process traffickers and pimps utilize to entice, coerce, or control
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`their victims.
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`The bases and reasons for the opinions summarized above centers around Detective
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`Decouflé’s extensive experience conducting sex trafficking investigation. Detective
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`Decouflé has an extensive experience interviewing prostitutes, pimps, and individuals who
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`solicit commercial sex and has herself has engaged in numerous investigations requiring
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`knowledge of the methods that sex traffickers and pimps utilize, whether through online
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`media or through face-to-face contact, to recruit women into prostitution. Detective
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`Decouflé has interviewed hundreds of victims and survivors, which enables her to
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`understand the particular language and methods utilized in the prostitution industry.
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`2. Dominique E. Roe-Sepowitz, M.S.W., Ph.D. (Sex Trafficking)
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`Dr. Roe-Sepowitz is expected to testify as a fact witness in this matter, regarding
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`her interactions with Backpage, the National Center of Missing and Exploited Children
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`(NCMEC), human sex trafficking prevention and outreach groups in relation to Backpage
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`related prostitution advertising, as well as Backpage related interactions with state and
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`Case 2:18-cr-00422-SMB Document 1081 Filed 10/27/20 Page 4 of 21
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`federal law enforcement. In an abundance of caution, however, the government provides
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`notice identifying Dr. Roe-Sepowitz as a potential “expert” in the area of human
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`trafficking, specifically, sex trafficking.
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`Dr. Roe-Sepowitz is an Associate Professor in the School of Social Work at Arizona
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`State University. She is the director of the Office of Sex Trafficking Intervention Research
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`at Arizona State University. Dr. Roe-Sepowitz’s area of specialty and expertise is in human
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`sex trafficking with juveniles and adults, with an aim on prevention and awareness,
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`intervention and treatment.
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`Dr. Roe-Sepowitz can testify about her research in the area of human sex trafficking.
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`Specifically and recently, Dr. Roe-Sepowitz participated in (1) a six year analysis of sex
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`trafficking of minors: exploring characteristics and sex trafficking patterns; (2) a Las Vegas
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`based study on how violence is often tied to teen sex trafficking; and (3) a Hawaii based
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`study exploring online sex buyers in Hawaii. Dr. Roe-Sepowitz has also researched the
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`impact the Super Bowl had on sex trafficking. Dr. Roe-Sepowitz’s research can be found
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`at https://socialwork.asu.edu/stir/research. While the government intends for Dr. Roe-
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`Sepowitz to testify as a fact witness at trial, her education, training, and experience, could
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`lead one to believe that she is an expert in the area of human sex trafficking.
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`3. Sharon W. Cooper, M.D. (Sex Trafficking)
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`Dr. Cooper will testify about (1) how a victim can fall into the world of sex
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`trafficking, through the grooming process, force, or abduction, etc. and why certain victims
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`may be targeted; (2) the harmful, lasting impact sex trafficking can have on its victims,
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`primarily child victims; (3) the relationship and loyalty a child sex trafficking victim may
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`have and show towards her trafficker; (4) common ways a sex trafficker can use force,
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`fraud, and coercion to maintain control over his victims; (5) reasons why child sex
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`trafficking is cited as the most underreported form of child abuse; and (6) the role Backpage
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`played in the victimization of her patients and clients.
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`Dr. Cooper is a developmental and forensic pediatrician who evaluates and treats
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`children who have been victims of all forms of abuse, with a primary area of expertise in
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`Case 2:18-cr-00422-SMB Document 1081 Filed 10/27/20 Page 5 of 21
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`sexual exploitation. She is a member of the Board of Directors for the National Center for
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`Missing and Exploited Children and a retired Colonel with the United States Armed Forces.
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`Dr. Cooper has testified before the United States Congress, the Russian Parliament, the
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`Italian Senate and the European Commission on child sexual exploitation. She has also
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`testified as an expert medical witness in over two dozen federal trials. Dr. Cooper is
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`familiar with how victims were trafficked on Backpage and her opinions will be based on
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`her education, training, and her clinical and forensic experiences treating victims of sex
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`trafficking.
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`4. James Hardie
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`Supervisory Special Agent James E. Hardie will testify about (1) terminology
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`commonly used the sex trafficking, such as pimp, “bottom bitch,” MOB (money over
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`bitches), “date,” “roses” (money), “the game”, etc.: (2) common dynamics between sex
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`traffickers and their victims and how a trafficker may use drugs, force, fraud, and coercion
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`to maintain control over their victims; (3) how human trafficking takes place in our
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`communities from a law enforcement prospective; and (4) the role of the internet and
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`Backpage played in his knowledge and understanding of human trafficking and how
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`Backpage became part of the law enforcement investigations for human trafficking over
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`the years.
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`Supervisory Special Agent Hardie began investigating sex trafficking cases
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`involving both minor and adult victims in 2008, which has resulted in his experience in
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`interviewing hundreds of victims and witnesses and two dozen pimps or traffickers. From
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`2008 – 2013, Agent Hardie served as the coordinator of the FBI’s Violent Crimes Against
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`Children Task Force in Ohio. From 2013 – 2015, he served as the FBI’s representative to
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`the National Center for Missing and Exploited Children (NCMEC), where he coordinated
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`sex trafficking reporting between NCMEC and the FBI child exploitation task forces. Since
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`2011, Supervisory Special Agent Hardie has presented or provided instruction at
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`conferences and seminars, internationally and domestically, in the area of sex trafficking.
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`Supervisory Special Agent Hardie’s opinions are based on his training and
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`Case 2:18-cr-00422-SMB Document 1081 Filed 10/27/20 Page 6 of 21
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`experience in the area of human trafficking.
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`5. Derek Stigerts
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`Investigator Stigerts will testify about (1) how sex trafficking occurs; (2) common
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`terminology used by individuals involved in sex trafficking; (3) the role of the internet and
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`technology in human trafficking; (4) methods of recruitment, manipulation, and control by
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`a trafficker with his victims; and (5) the role the internet and Backpage has played in human
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`trafficking.
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`Investigator Stigerts has been involved in the investigation of human trafficking
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`offenses for over a decade. Investigator Stigerts has interviewed over 300 females involved
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`in prostitution, including 80 juvenile victims, as well as over 30 suspected pimps or
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`traffickers. He has presented at instructional courses presented by NCMEC and the FBI.
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`Investigator Stigerts’ opinions are based on his training and experience in the area of
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`human sex trafficking.
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`6. Shannon Wolf, Ph.D., LPC-S
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`Dr. Wolf will testify about the connection between trauma bonds and personal
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`identity in victims of sex trafficking and how to understand them, including ways to interact
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`with child sex trafficking victims to avoid secondary trauma, and the role Backpage has
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`played in causing trauma victims trafficked through its website. Dr. Wolf is a licensed
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`professional counselor with supervisory status and a Professor of Psychology and
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`Counseling at B.H. Carroll Theological Institute. Dr. Wolf’s provides counseling and
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`therapy to victims of sex trafficking and her current research focus is on child sex
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`trafficking.
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`7. Staca Shehan, Executive Director Case Analysis Division, NCMEC
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`Ms. Shehan is a fact witness as she met on several occasions with Backpage
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`Defendants. Ms. Shehan is the Executive Director of the Case Analysis Division at the
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`National Center for Missing and Exploited Children (NCMEC). As a result of her
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`employment, Ms. Shehan’s testimony will cover topics that could be perceived as expert
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`testimony. In an abundance of caution, the government provides notice identifying Ms.
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`Shehan as a potential “expert” in the area of human trafficking, sex trafficking, and child
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`exploitation.
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`Specifically, Ms. Shehan will testify to the creation of a dedicated Child Sex
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`Trafficking Team at NCMEC to respond to the increased need for technical assistance and
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`analysis in cases involving child sex trafficking. These unique resources include analysis
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`of potential suspect names or aliases, unique tattoos, link analysis about child sex
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`trafficking victims/potential victims, telephone numbers, addresses and/or link analysis
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`about child sex trafficking victims/potential victims, telephone numbers, addresses and/or
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`online postings.
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`The government reserves the right to question the expert regarding other matters
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`that may be raised during cross-examination by Defendants, based upon testimony
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`provided by defense experts (if any), or other witnesses and evidence introduced by
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`Defendants. This disclosure of the government’s notice of expert witnesses also serves as
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`the government’s request for notice of rebuttal or expert testimony by Defendants, pursuant
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`to Rule 16 of the Federal Rules of Criminal Procedure.
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`8. Donna Gavin
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`From July 2009 to October 2016, Lieutenant Detective Donna Gavin served as a
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`Sergeant Detective/Commander of the Boston Police Department’s Human Trafficking
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`Unit. She later served, from May 2016 to April 2019, as the Lieutenant Detective for the
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`Boston Police Department’s Crimes Against Children and Human Trafficking Units. She
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`has extensive experience investigating prostitution, human trafficking and child sex
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`trafficking crimes involving victims who were advertised on Backpage. On August 13,
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`2015, Lieutenant Detective Gavin provided a declaration in the Northern District of Illinois
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`that described Backpage’s role in the Boston-area sex trade. Lieutenant Detective Gavin is
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`expected to testify consistent with her August 13, 2015 declaration, and will provide
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`additional relevant details about Backpage’s operations in the Boston area. She is also
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`expected to testify that, in her professional experience as a law enforcement officer for over
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`30 years, the “adult” section of Backpage not only contained ads for illegal activity,
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`including prostitution, solicitation and trafficking, but it was also the primary source for
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`such ads and was well known for that purpose in the sex trafficking industry in Boston,
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`Massachusetts, until the site was shut down in 2018. Further, Lieutenant Detective Gavin
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`is expected to testify that Backpage “adult” section provided a vehicle and anonymity for
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`its users who exploited and trafficked young women and girls, that it provided no legitimate
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`service and that nearly all the cases the Boston Police Department’s Human Trafficking
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`Unit found associated with Backpage involved pimp-controlled prostitution.
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`While the government does not believe that Lieutenant Detective Gavin’s testimony
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`will involve any opinion testimony, it provides this information out of an abundance of
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`caution and in the event that any of any her testimony is deemed to constitute expert opinion
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`testimony. Lieutenant Detective Gavin’s opinions are based on her training and experience
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`in the areas of human trafficking, crimes against children and sexual assault.
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`7. Thomas Adam Umporowicz, Jr.
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`Detective-Sergeant Thomas Adam Umporowicz Jr. is the Detective-Sergeant in
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`charge of the Seattle Police Department’s Vice/High Risk Victims Unit, a position that he
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`has held since 2014. He has also served as the Human Trafficking Task Force Sergeant for
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`the Seattle Police Department. He has more than 30 years of law enforcement experience,
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`and has trained other law enforcement agencies in the United States in the areas of human
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`trafficking and internet crimes against children.
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`On August 14, 2015, Detective-Sergeant Umporowicz provided a declaration that
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`was filed in the Northern District of Illinois. The declaration described Backpage as the
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`primary website in the Seattle, Washington area for those looking to solicit a prostitute,
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`post prostitution ads or traffic prostitutes and minors. In the declaration, Detective-Sergeant
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`Umporowicz opined that in his professional experience:
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`[T]he adult section of Backpage.com not only contains ads for illegal
`activity, including prostitution, solicitation and trafficking, but it is a primary
`source for such ads and is well known for that purpose in the sex trafficking
`industry in the city of Seattle and State of Washington. But the way
`Backpage.com operates and the anonymity it provides its users makes it more
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`difficult for us to identify and arrest and prosecute these offenders. It is the
`Seattle Police Department Vice/High Risk Victims Unit position that
`removing the adult section of Backpage.com would greatly assist to disrupt
`these sex traffickers’ easy means of communication and connection for these
`illegal activities and therefore would reduce demand for, and access to, the
`sex trafficking industry within the city of Seattle and the State of
`Washington. This would be useful in protecting the women and children who
`are victimized by those numerous individuals who use Backpage.com for
`these unlawful purposes. In our experience,
`the adult section of
`Backpage.com seems to serve no legal purpose.
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`Detective-Sergeant Umprowicz is expected to testify consistent with his declaration,
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`and is expected to provide other pertinent details and observations about Backpage’s
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`operations in the Seattle area through Backpage’s closure in 2018. He is also expected to
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`testify about the evolution of prostitution and human trafficking in the Seattle area from
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`the pre-internet era through the rise of Backpage to the post-Backpage era. He will explain
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`how the ease-of-use, convenience and relative anonymity of using Backpage (both as a
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`“john” and as a prostitute or pimp) increased the demand for prostitution services and the
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`supply of persons who were advertised as prostitutes. He is expected to testify that
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`Backpage established a near-monopoly on online prostitution advertising in the Seattle
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`area. He will also explain how, following Backpage’s shutdown, the sex trade has partly
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`reverted to street-level prostitution (in hotel lobbies, casinos and on the streets), which has
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`reduced demand and supply and seriously disrupted the sex trade in the Seattle area. He
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`will also explain that Backpage was continually put on notice by law enforcement of its
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`facilitation of prostitution through the issuance of search warrants and subpoenas across
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`the country.
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`Detective-Sergeant Umprowicz’s opinions are based on his training and experience
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`in the areas of law enforcement, prostitution, and human and child sex trafficking.
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`10. Robert Spectre
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`In April 2019, Spectre authored the report “Beyond Backpage, Buying and Selling
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`Sex in The United States One Year Later.” The report summarizes the immediate online
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`disruption following April 2018 when Backpage was seized and the Stop Enabling Sex
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`Case 2:18-cr-00422-SMB Document 1081 Filed 10/27/20 Page 10 of 21
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`Traffickers Act (SESTA) and Fight Online Sex Trafficking Act (FOSTA) were signed into
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`law. Spectre’s analysis concluded that since the events in April 2018 (including Backpage’s
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`shut down), the demand for purchasing sex online has been reduced drastically.
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`Spectre’s background includes tracking online sex trafficking beginning in 2014,
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`when he was contacted by Polaris (https://polarisproject.org/human-trafficking/facts)
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`through his company twilio.org, a start-up company that developed text (short code)
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`technology. That technology is utilized by many different businesses, but was also used to
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`reach victims of sex trafficking. Since Twilio, Spectre has worked with the Cook County
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`Sherriff’s Office and the New York Police Department to develop deterrence platforms
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`focused on combating sex trafficking.
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`In 2017, Spectre, while working with the NYPD’s Human Trafficking Unit,
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`developed a demand deterrence platform that focused on the demand side of human
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`trafficking. The platform would capture phone numbers of “johns” who responded to decoy
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`ads posted by NYPD on Backpage. When a decoy ad was posted, approximately 150
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`responses would be captured in a two hour-time frame. Since Backpage was seized,
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`responses have dropped to 20-30 per day, spread among approximately 12 different
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`websites. Spectre’s additional qualifications will be provided separately to Defendants.
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`Defendants noticed 6 experts and 4 general categories where they anticipate expert
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`testimony but have not yet retained anyone.
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`Defendants’ expert witness are as follows (Docs. 500, 538.):
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`1. Bates Butler: The Defendants anticipate presenting expert testimony on
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`informant/cooperating witness testimony and sentencing. Mr. Butler is anticipated to
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`testify about the prosecution’s use of such witnesses, defense proffers, cooperation
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`agreements and the interpretation and application of such agreements, preparation of
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`informant cooperating witness testimony by the prosecution, plea agreements and
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`sentencing recommendations and expectations. Mr. Butler’s opinions will be based on his
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`experience as a former acting United States attorney in the District of Arizona, assistant
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`Case 2:18-cr-00422-SMB Document 1081 Filed 10/27/20 Page 11 of 21
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`United States Attorney, defense lawyer, seminars he has presented and attended, and his
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`over four decades of practicing criminal law.
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`2. Roman Weil: The Defendants anticipate presenting expert testimony on the
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`following topics: (1) the functions that a Chief Financial Officer (“CFO”) performs in a
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`corporate setting, including what is and is not required of a CFO in assessing allegations
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`that a company or one of its subsidiaries has engaged in unlawful conduct; and (2) the loan
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`covenants that are typically included in a seller-financed sale. Professor Weil’s opinions
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`will be based on his education, extensive experience teaching and writing about corporate
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`governance and accounting matters, and service on professional boards.
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`3. Alexandra Levy: The Defendants anticipate presenting expert testimony on the
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`effect of imposing liability on Backpage for advertisements placed by third parties; the
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`utility of online commercial advertisements to law enforcement in identifying and rescuing
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`victims of sex trafficking; sex trafficking and/or prostitution; causation or lack thereof; the
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`practices of Backpage, Craigslist, Facebook, Google, and other Internet providers as such
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`practices pertain to these issues, and rebuttal testimony of various plaintiff’s experts
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`including but not limited to Professor Roe-Sepowitz.
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`Dr. Levy’s anticipated testimony will be based on her quantitative and qualitative
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`research, training, academic and outside teaching, practical experience, prior testimony,
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`authorship of books, articles, and other academic or literary papers published in her field
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`of expertise, discussions with other experts and persons responsible for editing and
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`moderation at some of the subject internet providers, review of the books, articles, studies,
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`and seminars on these topics, and other related experience.
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`4. Dr. Alexandra Lutnick: The Defendants anticipate presenting expert testimony on
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`the effect of Imposing liability on Backpage for advertisements placed by third parties; the
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`utility of online commercial advertisements to law enforcement in identifying and rescuing
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`victims of sex trafficking; sex trafficking and/or prostitution; causation or lack thereof; the
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`practices of Backpage, Craigslist, Facebook, Google, and other Internet providers as such
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`Case 2:18-cr-00422-SMB Document 1081 Filed 10/27/20 Page 12 of 21
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`practices pertain to these issues, and rebuttal testimony of various plaintiff’s experts
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`including but not limited to Professor Roe-Sepowitz.
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`The bases of Dr. Lutnick’s anticipated testimony is her quantitative and qualitative
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`research, training, academic and outside teaching, practical experience, prior testimony,
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`authorship of books, articles, and other academic or literary papers published in her field
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`of expertise, discussions with other experts and persons responsible for editing and
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`moderation at some of the subject internet providers, review of the books, articles, studies,
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`and seminars on these topics, and other related experience.
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`5. Dr. Kimberly Mehlman-Orozco: The Defendants anticipate presenting expert
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`testimony on the effect of imposing liability on Backpage for advertisements placed by
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`third parties; the utility of online commercial advertisements to law enforcement in
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`identifying and rescuing victims of sex trafficking; sex trafficking and/or prostitution;
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`causation or lack thereof; the practices of Backpage, Craigslist, Facebook, Google, and
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`other Internet providers as such practices pertain to these issues, and rebuttal testimony of
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`various plaintiff’s experts including but not limited to Professor Roe-Sepowitz.
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`Dr. Mehlman-Orozco’s anticipated testimony will be based on her quantitative and
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`qualitative research, training, academic and outside teaching, practical experience, prior
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`testimony, authorship of books, articles, and other academic or literary papers published in
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`their field of expertise, discussions with other experts and persons responsible for editing
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`and moderation at some of the subject internet providers, review of the books, articles,
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`studies, and seminars on these topics, and other related experience.
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`6. William Norman: The Defendants anticipate presenting expert testimony on the
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`lawful formation of and lawful uses of offshore trusts.
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`Professor Norman’s opinions will be based on his education, training, academic
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`teaching, practical experience, scholarship, presentations, and other related experience.
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`7. The Defendants anticipate presenting expert testimony on law enforcement officers’
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`investigation and prosecution of sex crimes, including but not limited to prostitution, child
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`Case 2:18-cr-00422-SMB Document 1081 Filed 10/27/20 Page 13 of 21
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`prostitution, and other related crimes; how the assistance of Internet site owners and
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`employees render and impede assistance in these investigations, the terminology used in
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`the sex industry by legal escorts, strippers, fetishists, and illegal prostitution. The expert(s)
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`in this field have not yet been retained, but may include former and/or current FBI agents
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`and state law enforcement officers who worked with Backpage and publicly and privately
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`commended Backpage on its cooperation. The correspondence, with the names, agencies
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`and contact information, relating to this cooperation is in the possession of the government,
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`and has not yet been fully disclosed, notwithstanding the government’s Rule 16 and Brady
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`obligations.
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`8. The Defendants anticipate presenting expert testimony on editing and moderating
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`Internet sites by the owners and employees of the sites, the challenges and expense
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`involved in editing and moderating, the evolving standards of editing and moderating in
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`the Internet provider community from 2004 to the present, the editing and moderating
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`practices of Backpage, Craigslist, Facebook, Google, and other Internet providers and the
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`reasonableness of Backpage practices, the state and federal regulating standards relating to
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`editing and moderating practices, impeachment of the government’s experts and other
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`related topics. The expert(s) in this field have not yet been retained, but his/her/their
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`anticipated testimony will be based on said experts’ training, academic teaching, practical
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`experience, authorship of books, articles, and other academic or literary papers published,
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`discussions with other experts and persons responsible for editing and moderation at many
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`of the internet providers in the United States, review of the books, articles, studies, and
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`seminars on these topics, impeachment of the government’s experts, and other related
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`experience.
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`9. The Defendants anticipate presenting expert testimony on the marketing
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`aggregation strategies and techniques used by newspapers both for print and online
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`publications to boost readership and to generate advertising revenue. The expert(s) in this
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`field have not yet been retained, but his/her/their anticipated testimony will be based on
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`said experts’ training, academic teaching, practical experience, authorship of books,
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`Case 2:18-cr-00422-SMB Document 1081 Filed 10/27/20 Page 14 of 21
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`articles, and other academic or literary papers published, discussions with other experts
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`and persons responsible for marketing and aggregation strategies and techniques at some
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`of the subject Internet providers, review of the books, articles, studies, and seminars on
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`these topics, impeachment of the government’s experts, and other related experience.
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`10. The Defendants anticipate presenting expert testimony on the lawful formation of
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`and lawful uses of offshore trusts as a mater of United States and European Union law. The
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`expert(s) in this field have not yet been retained, but his/her/their anticipated testimony will
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`be based on said experts’ training, academic teaching, practical experience, authorship of
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`books, articles, and other