Subject: RE: Letter to the Court -- Today



Date: Tue, 02 Nov 2021 23:07:21 +0000



Attachments: 2021-11-02_Letter_re_defense_experts_and_Daubert_hearing_[to_defense].docx; Def._Expert_Notice_[proposed_redactions].pdf

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Chris,

On the other issue, scheduling the Daubert/412 hearing, attached is a draft letter, along with our proposed redactions to your expert notice. Please feel free to insert your position, which we ask that you do by 9:00.

## Thanks,



That's fine for us. Thanks for drafting.



Hey Chris,

The Government’s trial estimate also hasn’t changed, so in light of your email, attached is a draft short letter saying as much. We’re happy to file if this works for you.

On the timing of the 412/Daubert hearing, we’re preparing a draft letter which we’ll send you shortly.

Thanks,



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As you know, we have to report to the Court about two things today: (1) whether there has been any change to the anticipated length of trial, and (2) when the parties are free for the Rule 412/Daubert hearing. As to the first, the defense does not think we should modify the current 6-week estimate. Although the Court’s rulings on the motions in limine provided some helpful guidance, we can’t say at this point that it meaningfully impacted our estimate of the length of trial (assuming the government still believes its case-in-chief will be 3-4 weeks).

As to the second, we are free for the Rule 412/Daubert hearing on Nov. 9 or 10, but have a preference for Nov. 10. Please advise what the government’s preference is.

I believe the Court requested that we give our preference about the date of the Rule 412/Daubert hearing in a joint letter to the Court filed on ECF. I think we could include our positions on the trial length in that letter as well. Please let me know if you will draft the letter or if you would like the defense to draft it.

Thanks,

Chris

Christian R Everdell

COHEN & GRESSER LLP



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