2. This Court has indicated that it will entertain any motions made pursuant to the
decision, to preclude proposed expert testimony, simultaneous with its consideration of the trial evidence in this case. 3. For the reasons set forth in the attached memorandum of law, this witness clearly is not qualified to offer the proposed testimony offered. 4. In addition, the testimony of the witness is irrelevant to the questions before this Court, the testimony is not based upon a reliable or discernible methodology, and the testimony is otherwise unreliable. 5. In addition, the aforementioned testimony should not be admitted because
it lacks probative value, it will waste the Court’s time and it will create confusion.
WHEREFORE, based upon the foregoing reasons and based upon the facts and argument set forth in the attached memorandum of law, Plaintiffs move this Court, pursuant to Rules 104, 403, and 702 of the Federal Rules of Evidence, and pursuant to the standards set forth in
Daubert v. Merrell Dow Pharm., Inc.
, 509 U.S. 579 (1993) and its progeny, for an order precluding the testimony of the State
proposed expert Sherif Girgis. Respectfully submitted,
s/Carole M. Stanyar
s/ Dana Nessel
CAROLE M. STANYAR P34830 DANA M. NESSEL P51346 221 N. Main Street, Suite 300 645 Griswold Street, Suite 4300 Ann Arbor, MI 48103 Detroit, MI 48226 (313) 819-3953 (313) 556-2300 email@example.com firstname.lastname@example.org
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