Miles Guo Court Documents · Doc 322
Response in Support of Motion by USA as to Miles Guo’s Motion to Exclude Testimony of Defendant’s Expert Witnesses / (中文) 322-1 Exhibit A (Dragon Supp. Disclosure) / (中文)
摘要
Government's Supplemental Motion · Exclude/Limit Defense Expert Testimony
This 36-page filing, dated May 3, 2024 from the Assistant U.S. Attorneys (Micah F. Fergenson, Ryan B. Finkel, Justin Horton, Juliana N. Murray under Damian Williams), is the government's supplemental motion to exclude or limit the testimony of the defendant's expert witnesses in United States v. Miles Guo, S3 23 Cr. 118 (AT).
Three Defense Experts Targeted
The supplemental motion challenges:
- Raymond Dragon (valuation expert);
- Paul Doran (CCP expert);
- Thomas Bishop (accounting expert).
Exhibit A — Dragon Supplemental Disclosure
The motion attaches Exhibit A (case-doc-322-1): the supplemental disclosure of Raymond Dragon. The government argues that even the supplemental disclosure does not cure the defects identified in the First Daubert Order (ECF No. 305) regarding Dragon's methods.
Daubert Framework
The motion proceeds under Federal Rule of Evidence 702 and Daubert v. Merrell Dow Pharmaceuticals — requiring expert testimony to be:
- Based on sufficient facts or data;
- The product of reliable principles and methods;
- Reliably applied to the facts of the case.