Notice of Intent to Use Additional Expert Testimony Evidence by Eric Dean Sheppard — USA v. Sheppard (Dkt. 173, S.D. Fla.)

Summary

Eric Dean Sheppard filed this Notice of Intent to Utilize Additional Expert Witness Testimony on January 7, 2024 (Document 173, Case No. 22-20290-CR-BLOOM/OTAZO-REYES, Southern District of Florida) under Rule 16 of the Federal Rules of Criminal Procedure. It names John E. Jorgensen, President, CEO and Founding Partner of The Sylint Group, Inc., a digital data forensics firm, as an expert the defense may call at trial. Jorgensen is expected to testify that the November 12, 2020 email admitted as Defendant's Exhibit M-19 was sent by Heimdal Barrios to Eric Sheppard at 11:13 a.m., that its Word attachment "eric.docm" is a macro-formatted document, and that the attachment was last modified at 11:12 a.m. that day by user Barrios.Heimdal. The notice is signed for Nelson Mullins by Christopher Cavallo.

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Case 1:22-cr-20290-BB Document 173 Entered on FLSD Docket 01/07/2024 Page 1 of 3
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 NOTICE
OF INTENT TO UTILIZE ADDITIONAL EXPERT TESTIMONY
Defendant, Eric Dean Sheppard, hereby files this Notice of Intent to Utilize Additional
Expert Witness Testimony. Pursuant to Rule 16(B) of the Federal Rules of Criminal Procedure,
Defendant provides this notice that Defendant may call the following expert witness in his case at
trial.
The qualifications of the expert witness, John E. Jorgensen of The Sylint Group, Inc.
(“Sylint”), are described in his CV, which is attached to this Notice as Exhibit A.
Mr. Jorgensen is President, CEO, and Founding Partner of Sylint. Sylint provides
consulting and professional services for Cyber Security, Industrial Counter-Espionage, Counter
Cyber Warfare, eDiscovery, Signal Analysis, and Digital Data Forensic Investigations, nationally
and internationally. This includes computer systems and digital data forensic analysis, and
evidentiary data recovery and collection.
Case 1:22-cr-20290-BB Document 173 Entered on FLSD Docket 01/07/2024 Page 2 of 3
Opinions
Mr. Jorgensen will testify:
1. The November 12, 2020 email (“Barrios Email”) admitted as Defendant’s Exhibit M-
19 at trial was sent by Heimdal Barrios (heimdal.barrios@suntrust.com) to Eric
Sheppard (eric.sheppard10@gmail.com) on November 12, 2020 at 11:13 a.m. eastern
time.
2. The Barrios Email contains a Microsoft Word document attachment entitled
“eric.docm” (“Barrios Attachment”).
3. A “docm” file is a macro-formatted Microsoft Word document, typically used by
financial entities for form documents.
4. The Barrios Attachment was last modified on November 12, 2020 at 11:12 a.m. eastern
time by user Barrios.Heimdal.
Basis for Opinions
Mr. Jorgensen’s opinions and anticipated testimony are based on facts and data reasonably
relied upon by forensic computer experts. Mr. Jorgensen’s testimony will draw upon his expertise
and experience, which is reasonably relied upon by forensic computer experts.
Mr. Jorgensen’s opinions and anticipated testimony are also based on his review of the
native Barrios Email (.msg format), which contains the native Barrios Attachment (.docm format).
Mr. Jorgensen received this document from defense counsel. Defendant is producing the native
Barrios Email to the Government contemporaneous with the filing of this Notice.
John E. Jorgensen
Phe Sylint
Case 1:22-cr-20290-BB Document 173 Entered on FLSD Docket 01/07/2024 Page 3 of 3
Dated: January 7, 2024. 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/ Christopher Cavallo
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 January 7, 2024, 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/ Christopher Cavallo
Christopher Cavallo


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