Page 1 IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
UNITED STATES OF AMERICA
v.
DONALD J. TRUMP,
Defendant.
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*
*
*
*
*
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CRIMINAL NO. 23-cr-257 (TSC)
GOVERNMENT’S SUMMARY OF ANTICIPATED EXPERT TESTIMONY
The Government has provided its Notice of Expert Witnesses to the defendant. Pursuant to
the Pretrial Order, ECF No. 39 ¶ 7, the Government now submits to the Court “a brief description
of each [expert] witness’ area of expertise and expected testimony.” As explained below, the
Government may call up to three expert witnesses to testify in this case.
Expert Expert 1 has knowledge, skill, experience, training, and education beyond the ordinary lay
person regarding the interpretation and visual representation of geographic location data. The
Government expects that Expert 1 will testify about his/her use of ArcGIS (Geographic
Information Systems) software to create a map of the Google location history data produced in
response to a search warrant. Specifically, Expert 1 plotted the location history data for Google
accounts and devices associated with individuals who moved, on January 6, 2021, from an area at
or near the Ellipse to an area encompassing the United States Capitol building. His/her testimony
will describe and explain the resulting graphical representations of that data, and it will aid the jury
in understanding the movements of individuals toward the Capitol area during and after the
defendant’s speech at the Ellipse.
Expert Expert 2 has knowledge, skill, experience, training, and education beyond the ordinary layPage 2 person regarding the analysis of location data and location history data, including Google location
history data, to determine the approximate location at which a device with Google location history
activated was used at a particular time or range of times. The Government expects that Expert will testify about: the process of determining device location; the collection and use of location
history data by Google, LLC; and location history data produced in response to a search warrant
and included in the graphical representation prepared by Expert 1. His/her testimony will aid the
jury in understanding the movements of individuals toward the Capitol area during and after the
defendant’s speech at the Ellipse.
Expert Expert 3 has knowledge, skill, experience, training, and education beyond the ordinary lay
person regarding the analysis of cellular phone data, including the use of Twitter and other
applications on cell phones. The Government expects that Expert 3 will testify that he/she: (1)
extracted and processed data from the White House cell phones used by the defendant and one
other individual (Individual 1); (2) reviewed and analyzed data on the defendant’s phone and on
Individual 1’s phone, including analyzing images found on the phones and websites visited; (3)
determined the usage of these phones throughout the post-election period, including on and around
January 6, 2021; and (4) specifically identified the periods of time during which the defendant’s
phone was unlocked and the Twitter application was open on January 6.
Respectfully submitted,
JACK SMITH
Special Counsel
By:
-2-
/s/ Thomas P. Windom
Molly Gaston
Thomas P. WindomPage 3 Senior Assistant Special Counsels
950 Pennsylvania Avenue NW
Room B-Washington, D.C.
-3-
PDF Page 1
PlainSite Cover Page
PDF Page 2
Case 1:23-cr-00257-TSC Document 183 Filed 12/11/23 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
UNITED STATES OF AMERICA
v.
DONALD J. TRUMP,
Defendant.
*
*
*
*
*
*
*
CRIMINAL NO. 23-cr-257 (TSC)
GOVERNMENT’S SUMMARY OF ANTICIPATED EXPERT TESTIMONY
The Government has provided its Notice of Expert Witnesses to the defendant. Pursuant to
the Pretrial Order, ECF No. 39 ¶ 7, the Government now submits to the Court “a brief description
of each [expert] witness’ area of expertise and expected testimony.” As explained below, the
Government may call up to three expert witnesses to testify in this case.
Expert 1
Expert 1 has knowledge, skill, experience, training, and education beyond the ordinary lay
person regarding the interpretation and visual representation of geographic location data. The
Government expects that Expert 1 will testify about his/her use of ArcGIS (Geographic
Information Systems) software to create a map of the Google location history data produced in
response to a search warrant. Specifically, Expert 1 plotted the location history data for Google
accounts and devices associated with individuals who moved, on January 6, 2021, from an area at
or near the Ellipse to an area encompassing the United States Capitol building. His/her testimony
will describe and explain the resulting graphical representations of that data, and it will aid the jury
in understanding the movements of individuals toward the Capitol area during and after the
defendant’s speech at the Ellipse.
Expert 2
Expert 2 has knowledge, skill, experience, training, and education beyond the ordinary lay
PDF Page 3
Case 1:23-cr-00257-TSC Document 183 Filed 12/11/23 Page 2 of 3
person regarding the analysis of location data and location history data, including Google location
history data, to determine the approximate location at which a device with Google location history
activated was used at a particular time or range of times. The Government expects that Expert 2
will testify about: the process of determining device location; the collection and use of location
history data by Google, LLC; and location history data produced in response to a search warrant
and included in the graphical representation prepared by Expert 1. His/her testimony will aid the
jury in understanding the movements of individuals toward the Capitol area during and after the
defendant’s speech at the Ellipse.
Expert 3
Expert 3 has knowledge, skill, experience, training, and education beyond the ordinary lay
person regarding the analysis of cellular phone data, including the use of Twitter and other
applications on cell phones. The Government expects that Expert 3 will testify that he/she: (1)
extracted and processed data from the White House cell phones used by the defendant and one
other individual (Individual 1); (2) reviewed and analyzed data on the defendant’s phone and on
Individual 1’s phone, including analyzing images found on the phones and websites visited; (3)
determined the usage of these phones throughout the post-election period, including on and around
January 6, 2021; and (4) specifically identified the periods of time during which the defendant’s
phone was unlocked and the Twitter application was open on January 6.
Respectfully submitted,
JACK SMITH
Special Counsel
By:
-2-
/s/ Thomas P. Windom
Molly Gaston
Thomas P. Windom
PDF Page 4
Case 1:23-cr-00257-TSC Document 183 Filed 12/11/23 Page 3 of 3
Senior Assistant Special Counsels
950 Pennsylvania Avenue NW
Room B-206
Washington, D.C. 20530
-3-
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