IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF GEORGIA

ATLANTA DIVISION

UNITED STATES OF AMERICA )

)

v. ) 1:95-CR-479-05-FMH

)

xxxxxxxxxxxxxxx)

______________________________)

MOTION FOR DISCLOSURE OF EXPERT TESTIMONY

COMES NOW xxxxxxxxxxxxxx, by and through undersigned counsel, and hereby requests that the government disclose to undersigned counsel a written summary of any and all testimony the government intends to introduce at trial pursuant to Rules 702, 703, or 705 of the Federal Rules of Evidence (Expert Testimony).

Rule 16 of the Federal Rules of Criminal Procedure has been amended, effective December 1, 1993. Pursuant to that amendment, Rule 16(a)(1)(E) was added, which reads as follows:

(E) Expert Witnesses. At the defendant's request, the government shall disclose to the defendant a written summary of testimony the government intends to use under Rules 702, 703, or 705 of the Federal Rules of Evidence during its case-in-chief at trial. This summary must describe the witnesses' opinions, the bases and the reasons therefor, and the witnesses' qualifications.

WHEREFORE, the Defendant requests that the government disclose a written summary of the testimony the government intends to use at trial pursuant to Rules 702, 703, or 705 of the Federal Rules of Evidence. This written summary should include, but not be limited to, a description of the opinions of any purported experts (including medical personnel and law enforcement officers), the bases and reasons for such opinions, and the qualifications of any such experts.

DATED: 19 July 2000.

Respectfully submitted,

_______________________________

V. NATASHA PERDEW (571970)

ATTORNEY FOR

Federal Defender Program, Inc.

Suite 3512

101 Marietta Tower

Atlanta, Georgia 30303

(404) 688-7530

CERTIFICATE OF SERVICE

This is to certify that I have this day served a copy of the foregoing Motion for Disclosure of Expert Testimony upon:

STEPHANIE GABAY-SMITH, ESQUIRE

Assistant United States Attorney

400 Richard B. Russell Bldg.

75 Spring Street, S.W.

Atlanta, GA 30303

by by hand delivering a copy of same.

DATED: 19 July 2000.

___________________________

V. NATASHA PERDEW (571970)

ATTORNEY FOR

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