Notice of Intent to Offer Expert Testimony — United States v. Victoria Madigan, No. 25-CR-39 (D. Wyo.)

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The Government's Notice of Intent to Offer Expert Testimony, Document 23 in Criminal No. 25-CR-39-SWS (Case 1:25-cr-00039-SWS), filed May 5, 2025, in the U.S. District Court for the District of Wyoming, in United States v. Victoria Madigan. The notice names Amanda Allard, Housing Programs Director of the Cheyenne Housing Authority, and says her curriculum vitae is attached as Exhibit 1. It states that Ms. Allard is expected to testify about Section 8 housing and the Housing Choice Voucher program, and that application materials were received from Victoria Madigan and her household and relied on for the eligibility decision. It further states that accurate income and asset information would have reduced or ended the assistance payments. Christyne M. Martens signed for the United States Attorney.

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        Case 1:25-cr-00039-SWS            Document 23        Filed 05/05/25    Page 1 of 5




Christyne M. Martens WSB #7-5044
Assistant United States Attorney
District of Wyoming
P.O. Box 22211
Casper, WY 82602
307-261-5434
christyne.martens@usdoj.gov

                        IN THE UNITED STATES DISTRICT COURT

                             FOR THE DISTRICT OF WYOMING

 UNITED STATES OF AMERICA,

                         Plaintiff,
         v.
                                                             Criminal No. 25-CR-39-SWS
 VICTORIA MADIGAN,

                         Defendant.


      GOVERNMENT’S NOTICE OF INTENT TO OFFER EXPERT TESTIMONY


        The United States of America hereby submits its notice of intent to offer expert testimony.

Fed. R. Crim. P. 16(a)(1)(G). The United States reserves the right to further supplement this notice.

        To avoid surprise or confusion to this Court or the Defendant, the United States is giving

courtesy notice of its intent to introduce the below-identified testimony. In providing such notice,

the United States does not concede that this anticipated testimony is in fact expert testimony

subject to Federal Rule of Evidence 702. The United States merely provides this notice out of an

abundance of caution.

    Amanda Allard
    Housing Programs Director
    Cheyenne Housing Authority

        Qualifications: Amanda Allard is the Housing Programs Director with the Cheyenne

Housing Authority. Her curriculum vitae, setting forth her relevant education and experience is

attached as Exhibit 1. In the last ten years, Ms. Allard has not authored any publications. She has

not testified as an expert witness in the last four years.
       Case 1:25-cr-00039-SWS           Document 23        Filed 05/05/25      Page 2 of 5




       Summary of Testimony: Ms. Allard is expected to testify regarding her role as Housing

Department Director for the Cheyenne Housing Authority. In this role, she is responsible for the

Cheyenne Housing Authority’s administration of housing programs, especially Section 8 housing

and the Housing Choice Voucher program. Through her education, training, and experience, she

has developed expertise in the area of public housing assistance and administration and the

operations of the Cheyenne Housing Authority. She is expected to offer testimony based on this

specialized knowledge that will assist the trier of fact in understanding the evidence presented.

       She may explain that Section 8 housing derives its name from Section 8 of the United

States Housing Act of 1937, 42 U.S.C. § 1437f, which provides that the Secretary of HUD may

enter “annual contributions contracts” with public housing agencies (PHAs), through which the

PHAs obtain federal funding to enable low-income families to enter the housing market and rent

existing dwelling units from private landlords. The Cheyenne Housing Authority is a PHA.

       The purpose of Section 8 housing assistance is “to assist the several States and their

political subdivisions to remedy the unsafe and unsanitary housing conditions and the acute

shortage of decent, safe, and sanitary dwellings for families of lower income.” 42 U.S.C. § 1437.

Under the program, qualifying tenants pay a portion of their income to a private landlord, and in

order to meet market-level rents, the PHA makes additional “assistance payments” to the landlord

with the federal funds it receives from HUD.

       To participate in the Section 8 program, would-be recipients must apply to the local PHA,

here the Cheyenne Housing Authority, which determines eligibility based on a number of financial

and family-status factors. If an applicant is selected to participate in the Section 8 program, the

local PHA issues the family a voucher. Once a PHA issues a voucher, the recipient may use it to

pay the rent for any apartment he or she chooses so long as the landlord participates in the Section

8 program and complies with the program requirements.

                                                 2
       Case 1:25-cr-00039-SWS           Document 23        Filed 05/05/25       Page 3 of 5




       Once a landlord agrees to rent to a Section 8 tenant, the two parties enter into a proposed

lease agreement for a specified total rent to owner. The parties then present the proposed lease

agreement to the PHA for approval. Once the PHA approves the lease: (1) the lease agreement

provisions become binding on both the landlord and tenant, and (2) the PHA and the landlord enter

into a separate Housing Assistance Payments Contract (“HAP Contract”), a standard and uniform

contract promulgated by HUD. The HAP Contract establishes the total rent to the owner, the

tenant's portion of the rent, and the amount that the PHA is responsible for.

       The application forms used by the Cheyenne Housing Authority explain the Section 8

Housing Choice Voucher Program and the promises the applicants are making to the federal

government and the Cheyenne Housing Authority by submitting the application. These forms

request a variety of information about family and financial status, which is information necessary

to determining eligibility. Among other things, to receive this housing assistance, applicants must

identify everyone in their household and all income for the household and supply supporting

documentation.

       Ms. Allard, along with other witnesses from the Cheyenne Housing Authority, will explain

how the Cheyenne Housing Authority interacts with applicants to ensure understanding of the

program and its requirements; how it reviews and relies on application materials submitted by

applicants; and how it determines eligibility for the Section 8 Housing Choice Voucher Program.

       Ms. Allard, along with other witnesses from the Cheyenne Housing Authority, will testify

that application materials were received from Victoria Madigan and her household and that the

Cheyenne Housing Authority relied on those application materials when determining the eligibility

of the Madigan household for assistance under the Section 8 Housing Choice Voucher Program.

Ms. Allard, along with other witnesses from the Cheyenne Housing Authority, will testify that had

Victoria Madigan and her household supplied accurate information regarding income and assets,

                                                 3
       Case 1:25-cr-00039-SWS            Document 23          Filed 05/05/25    Page 4 of 5




the housing assistance payments (vouchers) for her and her household would have been reduced

or terminated.

                                              Approved:        /s/ Amanda Allard
                                                               Amanda Allard


       The United States asserts that this notice and the reports which have been provided to the

Defendant, as well as the other information provided in discovery, satisfy the requirements of Rule

16(a)(1)(G). If, after viewing this notice and the attachment, the Defendant requests further

information or has concerns under Rule 16, the United States requests the Defendant advise as to

what further information is necessary to prepare for trial.

       In addition to the areas set forth above, the government reserves the right to elicit testimony

regarding other matters that may be raised during cross-examination, based on the testimony

elicited from the Defendant’s experts, if any, or other witnesses, or the evidence introduced by the

Defendant. To the extent the Court allows the Defendant the same right, we reserve the right to

elicit any additional testimony that this expert is qualified to provide should the need arise based

on further developments in preparing for and during the trial.

       The United States reserves the right to supplement its notice of expert witness testimony

pursuant to the continuing duty to disclose pursuant to Rule 16(a), Federal Rules of Criminal

Procedure. Investigations in criminal cases are ongoing and additional evidence may be discovered

which may require additional expert witness testimony.

       DATED this 5th day of May, 2025.

                                               STEPHANIE I. SPRECHER
                                               Acting United States Attorney


                                        By:    /s/ Christyne M. Martens
                                               CHRISTYNE M. MARTENS
                                               Assistant United States Attorney

                                                  4
       Case 1:25-cr-00039-SWS         Document 23       Filed 05/05/25     Page 5 of 5




                               CERTIFICATE OF SERVICE

       I hereby certify that on this 5th day of May, 2025, the foregoing Government’s Notice of

Intent to Offer Expert Testimony was electronically filed and consequently served on defense

counsel.


                                             /s/ Vickie L. Smith
                                             UNITED STATES ATTORNEY’S OFFICE




                                              5


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