Notice of Expert Testimony — United States v. Andrews (Dkt. 56, E.D. Wash.)

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A notice filed June 13, 2025 as ECF No. 56 in United States v. Michael Andrews, No. 2:24-cr-00139-MKD-1, in the U.S. District Court for the Eastern District of Washington, by Nathan Poston of the Federal Defenders of Eastern Washington and Idaho. Under Federal Rule of Procedure 16(b)(1)(C), the defense gives notice that Mr. Andrews intends to use expert testimony from Dr. Jennifer Stankus on traumatic injuries, including blunt and penetrating trauma, as they relate to the allegations in the case. The notice describes Dr. Stankus as a board-certified emergency room doctor and clinical faculty at the Madigan Emergency Medicine Residency Training Program, with experience as a law enforcement officer and in the Naval Reserves. It lists as exhibits a report of Dr. Stankus dated 6/6/25, a CV and a list of cases involving testimony.

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Case 2:24-cr-00139-MKD      ECF No. 56   filed 06/13/25   PageID.264   Page 1 of 4


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     Nathan Poston
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     Federal Defenders of Eastern Washington and Idaho
 3   601 West Riverside Ave., Suite 900
     Spokane, Washington 99201
 4   (509) 624-7606

 5   Attorneys for the Defendant
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                      UNITED STATES DISTRICT COURT
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                     EASTERN DISTRICT OF WASHINGTON
 8                      The Honorable MARY K. DIMKE

 9   United States of America,                     No. 2:24-cr-00139-MKD-1
10                                                 Notice of Expert Testimony
                    Plaintiff,
11       v.

12   Michael Andrews,
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                    Defendant.
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     Case 2:24-cr-00139-MKD       ECF No. 56     filed 06/13/25    PageID.265     Page 2 of 4


 1         Mr. Andrews submits the following notice pursuant to Federal Rule of Procedure
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     16(b)(1)(C).
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           This notice conveys Mr. Andrews intent to use expert testimony from Dr. Jennifer
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     Stankus on the subjects of traumatic injuries o to blunt and penetrating trauma, blunt
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     force injuries, and traumatic injuries as they relate to the allegations made in this case.
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 7         Dr. Stankus’s expertise is derived from her experience as a board-certified

 8   emergency room doctor with extensive experience in injury assessment, trauma care,
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     military trauma, and pathophysiology. That experience is supplemented by her
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     experience as clinical faculty at the Madigan Emergency Medicine Residency Training
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     Program where she teaches US Army Physicians that are training to become emergency
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     physicians. In addition to her background as a physician, she also has experience as law
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14   enforcement officer and enlisted service member of the Naval Reserves. This experience

15   supplements her work both experience and common knowledge it relates to firearms.
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           Defense Counsel intends to examine Dr. Stankus about bases and reasons
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     supporting her opinions as well as the full extent of her background.
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           Defense Counsel has attached the following as exhibits
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           - Report of Dr. Stankus dated 6/6/25
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21         - CV of Dr. Stankus

22         - List of cases involving testimony
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           If the Government believes this notice is insufficient, Defense Counsel requests the
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     Case 2:24-cr-00139-MKD        ECF No. 56     filed 06/13/25   PageID.266    Page 3 of 4


 1    Government contact it and seek to resolve any issues prior to trial or litigation.
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               Mr. Andrews reserves the right to supplement this notice as necessary prior to
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      trial.
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     Dated: June 13, 2025
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 7                                               Respectfully Submitted,

 8                                               S/Nathan Poston
                                                 Attorneys for Mr. Andrews
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                                                 Federal Defenders of
10                                               Eastern Washington and Idaho
                                                 601 West Riverside Ave., Suite 900
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                                                 (509) 624-7606
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                                                 Email: nathan_poston@fd.org
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     Case 2:24-cr-00139-MKD      ECF No. 56     filed 06/13/25    PageID.267     Page 4 of 4


 1                              CERTIFICATE OF SERVICE
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          I hereby certify that on June 13, 2025, I electronically filed the foregoing with the
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     Clerk of the Court using the CM/ECF System which will send notification of such
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     filing to the following: Michael Ellis, Assistant United States Attorney.
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                                               S/Nathan Poston
 6                                             Attorneys for Mr. Andrews
                                               Federal Defenders of
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                                               Eastern Washington and Idaho
 8                                             601 West Riverside Ave., Suite 900
                                               Spokane, Washington 99201
 9                                             (509) 624-7606
                                               (509) 747-3539
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                                               Email: nathan_poston@fd.org
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