Notice of Intent to Use Expert Witness Evidence by USA as to Eric Dean Sheppard — USA v. Sheppard (Dkt. 65, S.D. Fla.)

Record facts

U.S. District Court for the Southern District of Florida · No. 1:22-cr-20290-BB · Doc. 65 · 2023-08-31 · Docket on CourtListener

Full text

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
 
CASE NO. 22-CR-20290-BLOOM(s) 
 
         
 
 
UNITED STATES OF AMERICA, 
 
v.    
 
ERIC DEAN SHEPPARD, 
 
 
 
Defendant. 
                                                                    / 
UNITED STATES’ NOTICE OF INTENT 
TO UTLIZE EXPERT TESTIMONY 
 
COMES NOW, the United States of America, through the undersigned Assistant United 
States Attorney, and files this Notice of Intent to Utilize Expert Testimony.  Pursuant to Rule 16(B) 
of the Federal Rules of Criminal Procedure, the government provides notice of its intent to call the 
following expert witness in its case-in-chief at trial as set forth by Rules 702, 703, and 705 of the 
Federal Rules of Evidence. 
The expert witness’s qualifications are described in his curriculum vitae, which will be 
provided to defense counsel separately via email.  The witness, Mr. Philip Palmer, is a revenue 
agent and lead employment tax specialist with the Internal Revenue Service.  The following is a 
summary of the expert witness’s expected testimony: 
 Mr. Palmer is expected to testify about the difference between what are referred to as W-
2 employees and IRS Form 1099 workers, or independent contractors.  Mr. Palmer is expected to 
testify about employer’s tax withholding obligations with respect to W-2 employees, as compared 
to Form 1099 workers.  Mr. Palmer is expected to testify about the cost to employers of W-2 
employees as compared to Form 1099 workers.  Mr. Palmer is expected to testify about the IRS 
Case 1:22-cr-20290-BB   Document 65   Entered on FLSD Docket 08/31/2023   Page 1 of 2

forms that employers are required to file with the IRS on a quarterly and annual basis in order to 
report employee wages and tax and other withholdings, such as IRS Form 940 and IRS Form 941. 
 
              
 
 
 
Respectfully submitted, 
 
MARKENZY LAPOINTE 
UNITED STATES ATTORNEY 
 
                        
 
   BY: s/Aimee Jimenez                    
                                     
 
 
AIMEE C. JIMENEZ 
Court No. A5500795 
Assistant United States Attorney 
99 N.E. 4th Street, 6th Floor 
Miami, Florida 33132 
Tel: (305) 961-9028 
      Fax: (305) 530-7976 
      Email:  Aimee.Jimenez@usdoj.gov 
 
 
 
 
CERTIFICATE OF SERVICE 
 
I CERTIFY that on August 31, 2023, I electronically filed the foregoing document  
with the Clerk of the Court using CM/ECF.     
 
                         
 
 
 
By:  s/Aimee Jimenez_______                 
 
 
 
Aimee C. Jimenez 
 
 
 
Assistant U.S. Attorney 
 
 
Case 1:22-cr-20290-BB   Document 65   Entered on FLSD Docket 08/31/2023   Page 2 of 2

File and source

File

gov.uscourts.flsd.615773.65.0.pdf

Size

107,380 bytes

SHA-256

47a82aea119d55133fbfef40a328ccb9880398158b03ba4bbd3ca4725e6dbf09

Our copy

gov.uscourts.flsd.615773.65.0.pdf

Original

PACER (login required)