Government's Notice of Expert Witness Testimony — United States v. Raquan Williams (Document 27)

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Government's Notice of Expert Witness Testimony in United States v. Raquan Williams, Case No. 4:24-CR-37, in the United States District Court for the Southern District of Georgia, Savannah Division, Document 27, filed May 30, 2024. The United States gives notice that it expects an ATF Special Agent to testify as an expert that the object referenced in the Indictment is a firearm under 18 U.S.C. § 921(a)(3) and that it moved in interstate and foreign commerce, citing a Taurus G2C .40 caliber pistol manufactured in Brazil. The notice says the opinions rest on firearm markings, reference materials and training and experience, and that the agent has no publications in the last 10 years. It includes a memorandum of law on expert testimony and a certificate of service.

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“Government's Notice of Expert Witness Testimony — United States v. Raquan Williams (Document 27).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-no-4-24-cr-00037-dkt-27-0e8b0e1654/, SHA-256 4f58944f9c2c87eb5223e86524e8534edd0627f82a0f000fbf965ba0aa2c17d3.

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Case 4:24-cr-00037-RSB-CLR Document 27 Filed 05/30/24 Page 1 of 5

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF GEORGIA
SAVANNAH DIVISION

UNITED STATES OF AMERICA )
) CASE NO: 4:24-CR-37
)
v. )
)
RAQUAN WILLIAMS )

GOVERNMENT’S NOTICE OF EXPERT WITNESS TESTIMONY
Now comes the United States of America, by and through Jill E. Steinberg,

United States Attorney for the Southern District of Georgia, and shows as follows:

Pursuant to Rule 16(a)(1)(G), the government provides notice to the defense of

the following expert witness expected to testify at the trial of the above-referenced

case:

EXPERT

Rebekah Parker, ATF Special Agent

Special Agent Parker, based upon her training and experience is qualified to

opine on various issues with respect to this case. Based upon her training and

experience, relying upon various industry related publications and a photographic

review of the objects, Special Agent Parker is qualified to opine on the following: that

the object referenced in the Indictment is a firearm as it is defined in 18 U.S.C. §

921(a)(3). Moreover, Special Agent Parker is qualified to opine that the firearm at

issue moved in interstate and foreign commerce prior to its recovery in this matter.
Case 4:24-cr-00037-RSB-CLR Document 27 Filed 05/30/24 Page 2 of 5

The Government hereby gives notice of its intention to call Special Agent Parker at

trial to render these opinions.

I. INTERSTATE AND FOREIGN NEXUS (FIREARM)

Rebekah Parker is a Special Agent in the Savannah Field Office of the Bureau

of Alcohol, Tobacco, Firearms and Explosives. She will testify to facts and identifying

data regarding the firearm recovered in this case, including movement in interstate

and foreign commerce. Specifically, SA Parker will testify that the Taurus, Model:

G2C, .40 caliber pistol is a firearm within the definition of 18 U.S.C. § 921(a)(3) and

was manufactured outside the State of Georgia, specifically, in Brazil. As such,

traveled in interstate commerce prior to recovery in this case.

SA Parker bases her opinions upon the firearms markings, which include but

are not limited to the serial numbers, names of the manufacturers, models, calibers,

and importers (if applicable). She also consulted and relied upon reference materials

(further detailed in discovery), research, and her own training and experience. The

government has provided a copy of his signed report and his curriculum vitae to

counsel in discovery.

II. PUBLICATIONS AUTHORED BY EXPERT IN LAST 10 YEARS

Special Agent Parker has not authored any publications in the last 10 years.

III. ALL CASES WHERE EXPERT TESTIFIED AT TRIAL OR BY
DEPOSITION IN THE LAST 4 YEARS

In the last four years, Special Agent Parker has not testified at trial.

IV. EXPERT WITNESS SIGNED APPROVAL
Case 4:24-cr-00037-RSB-CLR Document 27 Filed 05/30/24 Page 3 of 5

Special Agent Parker issued a report detailing her opinions, a curriculum

vitae, and a list of reference materials upon which she relied. Said report is signed

by her obviating the need for her to sign this disclosure. See Fed. R. Crim. P.

16(a)(1)(G)(v).

V. Memorandum of Law and Citations to Authority

The Federal Rules of Evidence provide for the admission of expert testimony

when “scientific, technical, or other specialized knowledge will help the trier of fact”

Fed. R. Evid. 702. Pursuant to Rule 702, a witness, “qualified as an expert by

knowledge, skill, experience, training, or education may testify . . . in the form of an

opinion or otherwise.” Id.

Expert testimony is admissible if it is both relevant and reliable, Daubert v.

Merrell Dow Pharms., Inc., 509 U.S. 579 (1993)1, and where it is “the kind that

enlightens and informs lay persons without expertise in a specialized field.” United

States v. Burchfield, 719 F.2d 356, 357–58 (11th Cir. 1983). To ensure these elements

are present, the trial judge serves as a “gatekeeper.” United States v. Majors, 196

F.3d 1206, 1215 (11th Cir. 1999) (citing Daubert, 509 U.S. at 2796-97). “‘[F]ederal

district courts . . . perform [this] important gatekeeping function by screening the

reliability of all expert testimony, but they have substantial discretion in deciding

1 In Kumho Tire Co. v. Carmichael, 526 U.S. 137 (1999), the Supreme Court confirmed

that Daubert’s gatekeeping obligation extends to beyond scientific experts to all of the
expert matters described in Rule 702. Kumho Tire Co., 526 U.S. at 149; United States
v. Paul, 175 F.3d 906, 910 (11th Cir. 1999) (holding that the trial judge is required to
inquire into the areas of relevance and reliability whether the expert testimony is
“scientific” or otherwise).
Case 4:24-cr-00037-RSB-CLR Document 27 Filed 05/30/24 Page 4 of 5

how to test an expert’s reliability and whether the expert’s relevant testimony is

reliable.’” Majors, 196 F.3d at 1215 (quoting Forklifts of St. Louis, Inc. v. Komatsu

Forklift, USA, Inc., 178 F.3d 1030, 1034 (8th Cir. 1999) (citing Kumho Tire Co., 526

U.S. at 146–147). 2

WHEREFORE, the government requests that the Court permit Special AW to

testify to the foregoing information as an expert in his field, subject to the government

laying the proper evidentiary foundation at trial.

Respectfully submitted,

JILL E. STEINBERG
UNITED STATES ATTORNEY

/s/ L. Alexander Hamner
L. Alexander Hamner
Assistant United States Attorney
Indiana Bar No. 31996-41

Post Office Box 8970
Savannah, GA 31412
Telephone No: 912-652-4422

2 A district court’s decision to admit or exclude expert testimony under Rule 702 is

reviewed for abuse of discretion. GE v. Joiner, 522 U.S. 136 (1997); United States v.
Gilliard, 133 F.3d 809, 812 (11th Cir. 1998).
Case 4:24-cr-00037-RSB-CLR Document 27 Filed 05/30/24 Page 5 of 5

CERTIFICATE OF SERVICE

This is to certify that I have on this day served all the parties in this case in

accordance with the notice of electronic filing (“NEF”) which was generated as a result

of electronic filing in this Court.

This 30th day of May 2024.

JILL E. STEINBERG
UNITED STATES ATTORNEY

/s/ L. Alexander Hamner
L. Alexander Hamner
Assistant United States Attorney
Indiana Bar No. 31996-41

Post Office Box 8970
Savannah, GA 31412
Telephone No: 912-652-4422

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