Notice of Intent to Use Amended Expert Witness Disclosure Evidence by Eric Dean Sheppard — USA v. Sheppard (Dkt. 94, S.D. Fla.)

Summary

Defendant's Amended Notice of Intent to Utilize Expert Testimony, Document 94, filed September 19, 2023, in United States of America v. Eric Dean Sheppard, No. 1:22-cr-20290-BB, U.S. District Court for the Southern District of Florida. It states that the defendant may call Scott Bouchner of Berkowitz Pollack Brant Advisors, a partner and director-in-charge of forensic accounting and business valuation services, as an expert witness at trial. At this juncture, Mr. Bouchner is expected to testify about the cash flows of certain of the defendant's companies and that money is fungible. The notice states that Mr. Bouchner is relying on bank and credit card documents and QuickBooks records produced by the Government. The signature block names Jayne C. Weintraub.

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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FORIDA 
 
CASE No. 22-20290-CR-BLOOM/OTAZO-REYES 
 
UNITED STATES OF AMERICA 
 
 
Plaintiff,  
v.  
 
ERIC DEAN SHEPPARD, 
 
 
Defendant. 
____________________________________/ 
 
DEFENDANT’S AMENDED NOTICE 
OF INTENT TO UTILIZE EXPERT TESTIMONY 
 
Defendant, Eric Dean Sheppard, hereby files this Amended Notice of Intent to Utilize 
Expert Witness Testimony. Pursuant to Rule 16(B) of the Federal Rules of Criminal Procedure, 
Defendant provides this amended notice that Defendant may call the following expert witness in 
his case at trial. 
The qualifications of the expert witness, Scott Bouchner of Berkowitz Pollack Brant 
Advisors (“BPBA”), are described in his CV, which was provided to counsel for the government 
via email. Mr. Bouchner is a partner at BPBA and the director-in-charge of forensic accounting 
and business valuation services. His practice areas include bankruptcy, insolvency, litigation 
support, expert witness testimony, forensic accounting investigations, due diligence investigations, 
and more. 
At this juncture, Mr. Bouchner is expected to testify: (1) about the cash flows of certain of 
Defendant’s companies, including source of funding and use of funds; (2) that the proceeds from 
the loans at issue were applied to pay workers and other business expenses; (3) that Defendant’s 
Case 1:22-cr-20290-BB   Document 94   Entered on FLSD Docket 09/19/2023   Page 1 of 2

2 
 
accounts were funded with sufficient funds outside of the government loans to cover personal 
expenses; and (4) that money is fungible. 
Mr. Bouchner’s testimony will draw upon his expertise and experience. With respect to 
financial documents, to date Mr. Bouchner is relying on bank and credit card documents produced 
by the Government, QuickBooks records for Mr. Sheppard’s companies produced by the 
Government, and other similar QuickBooks business records that Defendant will produce. 
 
Dated: September 19, 2023.  
 
 
Respectfully submitted,  
NELSON MULLINS  
One Biscayne Tower, 21st Floor  
2 S. Biscayne Boulevard  
Miami, FL 33131  
Telephone: 305.373.9400  
Facsimile: 305.995.6449 
By: /s/ Jayne C. Weintraub 
Jayne C. Weintraub 
Florida Bar No. 320382 
Christopher Cavallo 
Florida Bar No. 0092305 
Jonathan Etra  
Florida Bar No. 686905 
 
 
CERTIFICATE OF SERVICE 
 
I HEREBY CERTIFY that on September 19, 2023, a copy of the foregoing was 
electronically filed using the Court’s CM/ECF system and electronic notice was provided to the 
Office of the United States Attorney.  
By: /s/ Jayne C. Weintraub 
Jayne C. Weintraub 
Case 1:22-cr-20290-BB   Document 94   Entered on FLSD Docket 09/19/2023   Page 2 of 2

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