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k probative value. E.g., United States v. Bari, 750 F.2d 1169, 1179 (2d Cir. 1984) (finding that more than 10 years is too remote); United States v. Glover, 588 F.2d 876, 878 (2d Cir. 1978) (per curiam) (12 years too remote); United States v. Dupree, 833 F. Supp. 2d 255, 264 (E.D.N.Y. 2011), vacated an
will testify but actually "summarize the experts' opinions about those topics" and "describe the bases for the experts' opinions." United States v. Ulbricht, 858 F.3d 71, 115 (2d Cir. 2017) (emphasis added); United States v. Valle, No. 12-CR-847 (PGG), 2013 WL 440687, at *5 (S.D.N.Y. Feb. 2, 2013) ("Mer
s."). If the Defense's disclosure of an expert witness does not satisfy Rule 16, the Court has "broad discretion" to fashion an appropriate remedy. Ulbricht, 858 F.3d at 115. That discretion is guided by factors including "why disclosure was not made, the extent of the prejudice, if any, to the opposing
k probative value. E.g., United States v. Bari, 750 F.2d 1169, 1179 (2d Cir. 1984) (finding that more than 10 years is too remote); United States v. Glover, 588 F.2d 876, 878 (2d Cir. 1978) (per curiam) (12 years too remote); United States v. Dupree, 833 F. Supp. 2d 255, 264 (E.D.N.Y. 2011), vacated an
will testify but actually "summarize the experts' opinions about those topics" and "describe the bases for the experts' opinions." United States v. Ulbricht, 858 F.3d 71, 115 (2d Cir. 2017) (emphasis added); United States v. Valle, No. 12-CR-847 (PGG), 2013 WL 440687, at *5 (S.D.N.Y. Feb. 2, 2013) ("Mer
s."). If the Defense's disclosure of an expert witness does not satisfy Rule 16, the Court has "broad discretion" to fashion an appropriate remedy. Ulbricht, 858 F.3d at 115. That discretion is guided by factors including "why disclosure was not made, the extent of the prejudice, if any, to the opposing
k probative value. E.g., United States v. Bari, 750 F.2d 1169, 1179 (2d Cir. 1984) (finding that more than 10 years is too remote); United States v. Glover, 588 F.2d 876, 878 (2d Cir. 1978) (per curiam) (12 years too remote); United States v. Dupree, 833 F. Supp. 2d 255, 264 (E.D.N.Y. 2011), vacated an
will testify but actually "summarize the experts' opinions about those topics" and "describe the bases for the experts' opinions." United States v. Ulbricht, 858 F.3d 71, 115 (2d Cir. 2017) (emphasis added); United States v. Valle, No. 12-CR-847 (PGG), 2013 WL 440687, at *5 (S.D.N.Y. Feb. 2, 2013) ("Mer
s."). If the Defense's disclosure of an expert witness does not satisfy Rule 16, the Court has "broad discretion" to fashion an appropriate remedy. Ulbricht, 858 F.3d at 115. That discretion is guided by factors including "why disclosure was not made, the extent of the prejudice, if any, to the opposing
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