The USVI's Memorandum In Support Of Excluding Expert Testimony From JP Morgan (Part 1) (9/3/24)

The Epstein Chronicles

The case number 1:22-cv-10904-JSR involves a memorandum filed by the Government of the United States Virgin Islands (USVI) to exclude expert opinions provided by Kimberly Mehlman-Orozco, Joseph Fonseca, and Carlyn Irwin. Here's a summary of the key points from the memorandum:OverviewThe USVI government filed a motion to exclude the testimony and opinions of three experts retained by the defendants. The motion argues that the expert opinions should not be admitted due to issues related to their relevance, reliability, and qualifications under Federal Rule of Evidence 702 and the standards set forth in Daubert v. Merrell Dow Pharmaceuticals, Inc.Arguments for Exclusion

1. Kimberly Mehlman-Orozco:
   • Lack of Relevance and Fit: The USVI government argues that Mehlman-Orozco's opinions are not relevant to the facts of the case. Her testimony focuses on human trafficking but does not directly connect to the specific issues at hand in this litigation.
   • Methodological Flaws: The memorandum contends that Mehlman-Orozco's methods lack the scientific rigor required for expert testimony, questioning the reliability of her conclusions.
2. Joseph Fonseca:
   • Qualifications and Relevance: Fonseca is challenged on the basis of his qualifications, with the USVI government arguing that his expertise is not directly applicable to the matters of the case. His opinions are also argued to be speculative and lacking a sufficient factual basis.
   • Methodological Issues: Similar to Mehlman-Orozco, the USVI government asserts that Fonseca's methodologies are unreliable and do not meet the standards for admissible expert testimony.
3. Carlyn Irwin:
   • Lack of Expertise: The memorandum questions Irwin’s qualifications, stating that her experience and background do not sufficiently establish her as an expert in the specific issues being litigated.
   • Speculative Opinions: Irwin's opinions are claimed to be speculative and not grounded in a reliable methodology, making them inappropriate for consideration by the court.

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source:
gov.uscourts.nysd.591653.289.0_2.pdf (courtlistener.com)
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