ROBERT E. BLACKBURN, District Judge.
At the status conference on January 30, 2015, the court and counsel discussed, inter alia, some of the issues anticipated to be raised by at least some of the defendants concerning the existing and anticipated discovery and opinions relating to the government's disclosed and anticipated expert witnesses.
1. That the government may disclose additional experts and provide corresponding expert reports and summaries by
2. That to resolve pretrial issues implicating Fed. R. Evid. 702, 703, or 704, the following procedural protocol shall be used:
a. That for the government,
1. a complete statement of each expert opinion to be expressed and the bases and reasons therefor;
2. the data or other information considered by the witness in forming each expert opinion;
3. any exhibits to be used as a summary of or support for each expert opinion;
4. the qualifications of the witness, including a list of all publications authored by the witness within the preceding ten years, stated in a curriculum vitae ("c.v.");
5. the compensation to be paid the expert for the study and testimony; and
6. a listing of any other cases in which the witness has testified as an expert at trial or by deposition within the preceding four years;
b. That all motions raising issues under Fed. R. Evid. 702, 703, or 704, as codified and construed, shall be filed by
c. That for each putative expert witness with respect to whom a defendant objects for any reason, that defendant shall provide the following:
1. whether the defendant contends that the testimony of the expert is unnecessary or irrelevant; and if so, why;
2. whether the defendant objects to the qualifications of the witness; and if so, why (stated in detail); and
3. whether the defendant objects to any opinion to be offered by the expert; and if so:
a. which opinion; and
b. the specific basis for any objection stated and presented in terms of Fed. R. Evid. 401 and/or 702(a), (b), (c), or (d), 703, or 704, i.e., whether the objection impugns the relevancy of the opinion, the qualifications of the expert, the sufficiency of the facts and data used in support of the opinion, the principles and methods on which the expert relied in support of the opinion, how the expert has applied the principles and methods reliably to the facts of the case relevant to the opinion, or the facts or data used in forming an opinion on the subject; and
d. That for each putative expert witness whose necessity, qualifications, or opinions are opposed by a defendant, the government shall provide in response to the motion the following:
1. a c.v. for the expert;
2. a statement of each opinion to be offered by the expert that is opposed by the defendant; and
3. the relevance and bases for each allegedly objectionable statement to be offered by the expert, including
a. the facts or data on which the expert relied in support of the opinion made the focus and subject of objection;
b. the principles and methods on which the expert relied in support of the opinion made the focus and subject of objection; and
c. how the expert has applied the principles and methods reliably to the facts of the case relevant to the opinion made the focus and subject of objection; and
3. That based on any motion, its corresponding response, and any corresponding reply, the court may
a. rule on the papers;
b. require additional briefing;
c. schedule an evidentiary hearing; or
d. schedule oral argument.