Government (1250 Main) Expert Witness List

Case 2:16-cr-00046-GMN-PAL Document 1250 Filed 01/06/17 Page 1 of 19
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DANIEL G. BOGDEN
United States Attorney
District of Nevada
STEVEN W. MYHRE
NICHOLAS D. DICKINSON
NADIA J. AHMED
Assistant United States Attorneys
ERIN M. CREEGAN
Special Assistant United States Attorney
501 Las Vegas Blvd. South, Suite 1100
Las Vegas, Nevada 89101
(702) 388-6336
steven.myhre@usdoj.gov
nicholas.dickinson@usdoj.gov
nadia.ahmed@usdoj.gov
erin.creegan@usdoj.gov
Attorneys for the United States
UNITED STATES DISTRICT COURT

DISTRICT OF NEVADA
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UNITED STATES OF AMERICA,
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Plaintiff,
v.
ERIC J. PARKER,
O. SCOTT DREXLER,
RICKY R. LOVELIEN,
STEVEN A. STEWART,
TODD C. ENGEL, and
GREGGORY P. BURLESON,
2:16-CR-00046-GMN-PAL
GOVERNMENTS NOTICE AND
DISCLOSURES UNDER FEDERAL
RULE OF CRIMINAL PROCEDURE
16(a)(1)(G)
Defendants.
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The government certifies that the following Notice and
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CERTIFICATION:
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Disclosures set forth herein are timely made.
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The United States, by and through the undersigned, and pursuant Federal
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Rule of Criminal Procedure 16(a)(1)(G) and the Courts Order of November 22, 2016,
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(ECF No. 1017), hereby submits its Rule 16 Notice and Disclosures and informs the
defendants that the government may call all or some of the following witnesses at
trial to testify in substance as indicated herein, employing such specialized training,
education, and experience to testify in the form of an opinion, to provide technical
analysis and expertise, or to otherwise assist the trier of fact in understanding the
evidence presented at trial, all pursuant to Federal Rules of Evidence 702.
Special Agent Chad Simkins, Federal Bureau of Investigation
Background.
testify that he holds Bachelors and Masters Degrees in Accounting and is currently
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Chad Simkins, Special Agent, Federal Bureau of Investigation, will
a licensed CPA. S/A Simkins attended New Agent Training at the FBI Academy in
Quantico, Virginia, from September 2006 to January 2007 and, upon graduation,
was assigned to the Joint Terrorism Task Force in Reno, Nevada, where he served
from 2007 to 2013.
In 2009, S/A Simkins was selected to serve as a member of the FBI Special
Weapons and Tactics (SWAT) Team for the Las Vegas division.
In 2014, he
transferred to the Las Vegas division where he was ultimately assigned to the
Domestic Terrorism Squad.
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S/A Simkins is an FBI certified Firearms Instructor and Tactical Instructor.
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In August 2016, S/A Simkins was assigned to the FBI Academy in Quantico,
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Virginia, where he currently serves as a supervisor in the Firearms Training Unit
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and instructs new agents in the use and handling of firearms and firearms skills.
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In 2014, and before transferring to the FBI Academy, S/A Simkins was
assigned to the Gold Butte Investigation (the name assigned to the investigation of
the events culminating in the April 12, 2014, assault, at or near Bunkerville,
Nevada) in the Las Vegas Division. In the course of that assignment, S/A Simkins
was tasked with applying his training and experience to review and examine all
video and photographic media obtained in the course of the Gold Butte Investigation
from whatever source derived, whether it be Facebook, YouTube, or conventional
media/news sources. In connection with his examination, S/A Simkins was tasked
with identifying images of objects he determined to be firearms (as that term is
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defined by law) and identifying persons carrying, using, brandishing, or pointing

firearms in and around Toquop Wash (hereinafter the Wash) at all relevant times
on and during April 12, 2014, and at such other times and locations as are relevant
to the Superseding Indictment.
Special Agent Simkins was further tasked with physically viewing the
Toquop wash and other relevant locations in and around Bunkerville, Nevada, and
to become familiar with known landmarks in the Wash and their positions relative
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to that of Bundy supporters and federal law enforcement officers as revealed by the
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photographic evidence he reviewed. With this information, Special Agent Simkins
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obtained and derived various metrics with regard to known landmarks and the
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positions of the Bundy supporters and federal law enforcement officers, obtaining
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and deriving various metrics with regard to each. S/A Simkins was then tasked
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with creating a diagram, plotting the positions of persons carrying, using,
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brandishing, pointing firearms relative to known the positions of the law
enforcement officers and over time, establishing a timeline and summary of
movements of persons with firearms.
Summary of Anticipated Testimony.
S/A Simkins will testify that he reviewed hundreds of hours of video and
hundreds of photographs obtained from various sources during the course of the
investigation. In connection with that review, he used his investigative skills,
training, and experience, to match images captured during the events of April 12
with known images of the defendants to establish their identity and presence in or
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around the Wash at times relevant in the Superseding Indictment. He will testify
that he used his firearms training and skills to identify persons carrying, using,
brandishing, or pointing firearms, and will further describe his observations and
understanding of how the weapons were deployed as revealed by the images.
He will further testify that he compiled a number of reports and summaries
that reflect his analysis. Among those reports and summaries, is a diagram plotting
the location and position of persons with firearms (whether carrying, brandishing,
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or pointing) during two intervals of time: 1) approximately 11:57 to 12:13 during
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which time, as shown by aerial videos, ground videos and photographs taken during
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this interval; and 2) approximately 12:13 to 12:28 during which time photographic
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and video evidence reveals that Supervisory Special Agent Daniel Love was present
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at the gate speaking with Ammon Bundy. The sum and substance of his diagram
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is contained at Exhibit 1.
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He will further testify that during these two intervals of time, he tallied the
number of firearms and types, delineated as handguns and long guns, present in
the Wash and on the bridges. He compiled the results of his tally and entered them
into a spreadsheet.
contained at Exhibit 2.
The sum and substance of the results of his analysis is
He will further testify that as to each defendant, he reviewed the video and
photographic evidence obtained during the investigation and extracted the images
from the various media and, where possible, established the time when the image
was captured. By this method, S/A. Simkins was able to determine the position of
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various defendants, at various time in the wash relative to the time the BLM officers
were in their position behind the gate in the Wash. He compiled the images into a
PowerPoint presentation that serves as a summary timeline of the movement
and/or position of the defendants in the Wash. A description of his summaries has
been disclosed at GB.01875 to GB.018450.
Lastly, using video and photographic evidence adduced during the
investigation, S/A Simkins has measured and compiled various metrics relevant to
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the position of the Bundy supporters vis--vis the officers in at the gate. In accord,
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therefore, he will testify about the distances between various geographical
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landmarks in the wash and the relative positions of the Bundy supporters. These
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metrics are contained at Exhibit 2.
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Special Agent Joel P. Willis, Federal Bureau of Investigation
Special Agent Mark Seyler, Federal Bureau of Investigation
Special Agent (S/A) Joel Willis will testify that he has the following
education, training and experience: He has been employed as a Special Agent of
the FBI for approximately 13 years. He is currently assigned to the Domestic
Terrorism Squad of the Las Vegas Joint Terrorism Task Force. This task force
specializes in investigations targeting individuals and organizations who may pose
a domestic threat to the United States. S/A Willis holds a Bachelor of Science
Degree in Biology and a Masters of Science Degree in Molecular Genetics and,
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before joining the FBI, worked as a research assistant in Biology for a major
university. S/A Willis is a graduate of the FBI New Agent Training at Quantico,
Virginia and the FBIs Basic Domestic Terrorism Course. Has participated in over
one hundred investigations involving organized crime, domestic terrorism and
weapons of mass destruction.
S/A Mark Seyler will testify that has been employed as a Special Agent with
the Federal Bureau of Investigation (FBI), since October 15, 1995, having
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graduated from New Agent Training at the FBI Academy in Quantico,
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Virginia. Since that time, he has been assigned as a Case Agent on numerous
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investigations involving Acts of Terrorism, Material Support for Terrorism, Assault
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against Federal Officers, and other federal criminal violations. In the course of his
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career he has received training in the use of computers, the Internet, and social
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media, and has used this training to collect, obtain and analyze evidence of criminal
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violations. He has also used his training and experience to collect and obtain
Internet-related evidence through the use of subpoenas, search warrants, and court
orders. He has obtained and executed several federal search warrants Facebook,
Yahoo!, Microsoft (which maintains the e-mail service Hotmail), and Google, Inc.
(which maintains the email service Gmail). He has testified in Federal Court on
multiple occasions regarding this review and analysis of internet-based information
and evidence.
S/A Willis was assigned to the Gold Butte Investigation (the name assigned
to the investigation of the events culminating in the April 12, 2014, assault, at or
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near Bunkerville, Nevada) since May 2014.
S/A Seyler has been assigned to the
investigation of Ryan Payne since at least April 2014.

In the course of their investigations, S/As Willis and Seyler were tasked with
applying their training and experience to obtain process by which to obtain
information from various intent-based social media outlets, to include Facebook and
YouTube, relative to the defendants charged in the Superseding Indictment. Both
of these agents examined information obtained from these sources and analyzed
various communications and postings revealed by their examination.
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S/A Willis was assigned to the Gold Butte Investigation (the name assigned
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to the investigation of the events culminating in the April 12, 2014, assault, at or
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near Bunkerville, Nevada) since May 2014.
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investigation of Ryan Payne since at least April 2014.
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S/A Seyler has been assigned to the
Over the course of their careers, both agents have gained considerable
experience and expertise in reviewing and analyzing social media communications
and broadcasts. In the course of their investigations, S/As Willis and Seyler were
tasked with applying their training and experience to obtain process by which to
obtain information from various sources of social media to include Facebook and
YouTube relative to the defendants charged in the Superseding Indictment. Both
of these agents examined information obtained from these sources and analyzed
various communications and postings
Summary of Anticipated Testimony
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Special Agents Willis and Seyler will offer testimony that will assist the jury
to understand the Facebook posts and other activities of the defendants as related
to offenses charged.
a.
Facebook. Special Agents Willis and Seyler will testify that Facebook
allows its users to establish accounts electronically which they then use to share
written news, photographs, videos, and other information with other Facebook
users, and sometimes with the general public.
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Facebook asks users to provide basic contact and personal identifying
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information to Facebook, either during the registration process or thereafter. This
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information may include the users full name, birth date, gender, contact e-mail
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addresses, Facebook passwords, Facebook security questions and answers (for
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password retrieval), physical address (including city, state, and zip code), telephone
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numbers, screen names, websites, and other personal identifiers. Facebook also
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assigns a user identification number to each account.
Facebook users may join one or more groups or networks to connect and
interact with other users who are members of the same group or network. Facebook
assigns a group identification number to each group. A Facebook user also can
connect directly with individual Facebook users by sending each user a Friend
Request. If the recipient of a Friend Request accepts the request, then the two
users will become Friends for purposes of Facebook and can exchange
communications electronically or view information about each other electronically.
Each Facebook users account includes a list of that users Friends and a News
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Feed, which highlights information about the users Friends, such as profile
changes, upcoming events, and birthdays.
Facebook users can select different levels of privacy for the communications
and information associated with their Facebook accounts.
By adjusting these
privacy settings, a Facebook user can make information available only to himself or
herself, to particular Facebook users, or to anyone with access to the Internet,
including people who are not Facebook users. A Facebook user also can create lists
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of Facebook friends to facilitate the application of these privacy settings. Facebook
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accounts also include other account settings that users can adjust to controlfor
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example, the types of notifications they receive from Facebook.
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Facebook users can create profiles that include photographs, lists of personal
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interests, and other information. Facebook users also can post status updates
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about their whereabouts and actions, as well as links to videos, photographs,
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articles, and other items available elsewhere on the Internet. Facebook users also
can post information about upcoming events, such as social occasions, by listing
the events time, location, host, and guest list. In addition, Facebook users can
check in to particular locations or add their geographic locations to their Facebook
posts, thereby revealing their geographic locations at particular dates and times. A
particular users profile page also includes a Timeline, which is a space where the
user and his or her Friends can post messages, attachments, and links that will
typically be visible to anyone who can view the users profile.
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Facebook allows users to upload photos and videos. It also provides users the
ability to tag (i.e., label) other Facebook users in a photo or video. When a user is
tagged in a photo or video, he or she receives a notification of the tag and a link to
see the photo or video. For Facebooks purposes, the photos and videos associated
with a users account will include all photos and videos uploaded by that user that
have not been deleted, as well as all photos and videos uploaded by any user that
have that user tagged in them.
Facebook users can exchange private messages on Facebook with other users.
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These messages, which are similar to e-mail messages, are sent to the recipients
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Inbox on Facebook, which also stores copies of messages sent by the recipient, as
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well as other information. Facebook users also can post comments on the Facebook
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profiles of other users or on their own profiles; such comments are typically
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associated with a specific posting or item on the profile. In addition, Facebook has
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a Chat feature that allows users to send and receive instant messages through
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Facebook. These chat communications are stored in the chat history for the account.
Facebook also has a Video Calling feature, and although Facebook does not record
the calls themselves, it does keep records of the date of each call.
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If a Facebook user does not want to interact with another user on Facebook,
the first user can block the second user from seeing his or her account.
Facebook has a like feature that allows users to give positive feedback or
connect to particular pages. Facebook users can like Facebook posts or updates,
as well as webpages or content on third-party (i.e., non-Facebook) websites.
Facebook users also can become fans of particular Facebook pages.
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Facebook has a search function that enables its users to search Facebook for
keywords, usernames, or pages, among other things. Each Facebook account has
an activity log, which is a list of the users posts and other Facebook activities from
the inception of the account to the present. The activity log includes stories and
photos that the user has been tagged in, as well as connections made through the
account, such as liking a Facebook page or adding someone as a friend. The
activity log is visible to the user but cannot be viewed by people who visit the users
Facebook page.
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Facebook Notes is a blogging feature available to Facebook users, and it
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enables users to write and post notes or personal web logs (blogs), or to import
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their blogs from other services, such as Xanga, Live Journal, and Blogger.
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In addition to the applications described above, Facebook also provides its
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users with access to thousands of other applications on the Facebook platform.
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When a Facebook user accesses or uses one of these applications, an update about
the users access or use of that application may appear on the users profile page.
Some Facebook pages are affiliated with groups of users, rather than one
individual user.
administrator or head of the group, who can invite new members and reject or
accept requests by users to enter. Facebook can identify all users who are currently
registered to a particular group and can identify the administrator and/or creator
of the group. Facebook uses the term Group Contact Info to describe the contact
information for the groups creator and/or administrator, as well as a PDF of the
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Membership in the group is monitored and regulated by the
current status of the group profile page.

Facebook uses the term Neoprint to describe an expanded view of a given
user profile. The Neoprint for a given user can include the following information
from the users profile: profile contact information; News Feed information; status
updates; links to videos, photographs, articles, and other items; Notes; Timeline
postings; friend lists, including the friends Facebook user identification numbers;
groups and networks of which the user is a member, including the groups Facebook
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group identification numbers; future and past event postings; rejected Friend
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requests; comments; gifts; pokes; tags; and information about the users access and
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use of Facebook applications.
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Facebook also retains IP logs for a given user ID or IP address. These logs
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may contain information about the actions taken by the user ID or IP address on
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Facebook, including information about the type of action, the date and time of the
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action, and the user ID and IP address associated with the action. For example, if
a user views a Facebook profile, that users IP log would reflect the fact that the
user viewed the profile, and would show when and from what IP address the user
did so.
Facebook places small files, known as cookies or machine cookies, on
users browsers or devices. Each time a Facebook user accesses Facebook, these
cookies are sent from the users browser or device to Facebook. Facebook retains
data regarding these cookies which, among other things, can be used by Facebook
to determine which Facebook accounts were accessed from a particular browser or
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device.
Social-networking providers like Facebook typically retain additional
information about their users accounts, such as information about the length of
service (including start date), the types of service utilized, and the means and source
of any payments associated with the service (including any credit card or bank
account number). In some cases, Facebook users may communicate directly with
Facebook about issues relating to their accounts, such as technical problems, billing
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inquiries, or complaints from other users.
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Facebook typically retain records about such communications, including records of
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contacts between the user and the providers support services, as well as records of
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any actions taken by the provider or user as a result of the communications.
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b.
YouTube.
Social networking providers like
YouTube is an Internet forum that allows users to share,
search for, view and comment on video content. Users can access YouTube through
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the YouTube website or by using a special software application (app) that allows
users to access the service through a mobile device.
Anyone can watch videos on YouTube. However, a Google Account is necessary
to take advantage of Youtubes customizable features. For example, a Google Account
enables users to like videos, save their favorite videos, subscribe to video channels,
save videos to watch later, maintain a history of videos theyve watched, and flag
videos. YouTube can also personalize video recommendations based on a users video
preferences and subscriptions. All of this information is maintained by YouTube in
a users private profile.
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A Google Account is a single account that permits access to all of Googles

services, including YouTube. Subscribers obtain a Google Account by registering
with Google. During the registration process, Google asks subscribers to provide
basic personal information. Such information can include the subscribers full
name, physical address, telephone and other identifiers, alternative or recovery
email addresses, and, for paying subscribers, means and source of payment
(including any credit or bank account number). Such information may constitute
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evidence of the crimes under investigation because the information can be used to
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identify the accounts user or users.
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In order to upload a video, Google requires users to create a YouTube
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channel. In other words, without a channel, users have no public presence on
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YouTube. Although Google Accounts dont come with a YouTube channel by default,
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users with a Google Account can choose to create one. To do so, Google only requires
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the user to input the name of the channel, identify a channel category, and agree to
the Terms of Use. When a user uploads a video, Google asks for a variety of
information, including a category, title, description, tag (for keyword searches),
and location.
maintains account information and associated records about the user that posted
the video, in addition to the video itself.
Therefore, for every video that is posted on YouTube, Google
A video uploaded to YouTube is public by default. This means that anyone
can view the video by visiting YouTube. However, a user can also change the
privacy settings to permit only certain users to view a video. A user can do this by
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linking their YouTube account with Google+, a social networking service provided
by Google. The user can then select the email addresses or profiles of other Google+
users with which the video will be shared. A user can also make a video unlisted,
which means that only those with a link to the video can view it. Unlisted videos
arent visible to others who visit the channel page and generally do not show up in
Youtubes search results.
Videos and video channels on YouTube are assigned a uniform resource
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locator (URL) that directs viewers to specific video content or a particular
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channel.
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followed by a series of random alphanumeric characters. The standard URL for a
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channel generally consists of www.youtube.com/channel/ followed by the unique
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channel ID, or www.youtube.com/user/ followed by the users custom channel
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name.
The URL for a video generally consists of www.youtube.com/watch
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Google collects a variety of data on YouTube videos.
This includes
information for each time a video was watched; the comments and shares of a video;
the demographics of viewers; and the sources of traffic to the videos (i.e., the source
webpages and links that a viewer used to land on the video). Additionally, each
time a video is watched, Google states that its servers automatically record logs that
can include the page visited, the users IP address, the date and time of the visit,
cookies that uniquely identify the users browser or Google account, location data,
and other information.
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Further, Google typically retains certain transactional information about the

creation and use of each account on their systems. This information can include the
date on which the account was created, the length of service, records of log-in (i.e.,
session) times and durations, the types of service utilized, the status of the account
(including whether the account is inactive or closed), the methods used to connect
to the account (such as logging into the account via Googles website), and other log
files that reflect usage of the account. In addition, Google often has records of the
Internet Protocol address (IP address) used to register the account and the IP
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addresses associated with particular logins to the account. Because every device
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that connects to the Internet must use an IP address, IP address information can
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help to identify which computers or other devices were used to access the account.
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In addition, Google collects device-specific information (such as a users
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hardware model, operating system version, unique device identifiers, and mobile
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network information including phone number), which it may associate with a users
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Google Account. Further, information maintained by the provider can show how
and when the account was accessed or used. For example, providers typically log
the Internet Protocol (IP) addresses from which users access the account along with
the time and date. By determining the physical location associated with the logged
IP addresses, investigators can understand the chronological and geographic
context of the account access and use relating to the crime under investigation.
Additionally, information stored at the users account may further indicate the
geographic location of the account user at a particular time (e.g., location
information integrated into an image or video).
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Mary Jo Rugwell or other Designated Witness

Formerly the District Manager for Southern Nevada District Office (SNDO)
in Las Vegas. From 2008 to 2012. It is anticipated that Ms. Rugwell will testify as
a summary witness familiar with the business records of the SNDO and will testify
as what lands are designated public lands in Southern Nevada, including the Gold
Butte area. Ms. Rugwell will also review the offices dealing with Cliven Bundy
over the years leading up to the 2012 litigation. The government anticipates that
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she will provide technical and specialized testimony to explain to the jury the role
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of BLM in public lands management and technical terms such as impoundment and
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closure. A summary of her expected testimony has been disclosed in discovery at
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GB.017148 to GB.017204.
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Erich Smith
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Mr. Smiths CV is a Firearms and Toolmark expert. His CV is attached at
Exhibit 4.
evidence/images adduced during the Gold Butte investigation as indicated at
Exhibit 4. It is anticipated that Mr. Smith will apply his training and experience
and render an opinion on whether the objects depicted in the images at Exhibit 3
correspond with a known make/model/type of firearm and whether that
make/model/type of firearm is designed to expel a projectile by the action of an
explosive (18 U.S.C. 921 (a)(3)). Mr. Smith will further describe the effective range
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Mr. Smith will testify that he reviewed photographic/video
of the make and model weapons that correspond to those depicted in the
photographic evidence.
DATED this 6th day of January, 2017.
Respectfully,
DANIEL G. BOGDEN
United States Attorney
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//s//
______________________________
STEVEN W. MYHRE
NICHOLAS D. DICKINSON
NADIA J. AHMED
Assistant United States Attorneys
ERIN M. CREEGAN
Special Assistant United States Attorney
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Attorneys for the United States
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CERTIFICATE OF SERVICE
I certify that I am an employee of the United States Attorneys Office. A copy
of the foregoing GOVERNMENTS NOTICE AND DISCLOSURES UNDER
FEDERAL RULE OF CRIMINAL PROCEDURE 16(a)(1)(G) was served upon
counsel of record, via Electronic Case Filing (ECF).
DATED this 6th day of January, 2017.
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/s/ Steven W. Myhre

______________________________
STEVEN W. MYHRE
Assistant United State Attorney
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Case 2:16-cr-00046-GMN-PAL Document 1250 Filed 01/06/17 Page 1 of 19

UNITED STATES DISTRICT COURT

UNITED STATES OF AMERICA,

Disclosures set forth herein are timely made.

Case 2:16-cr-00046-GMN-PAL Document 1250 Filed 01/06/17 Page 2 of 19

trial to testify in substance as indicated herein, employing such specialized training,

education, and experience to testify in the form of an opinion, to provide technical

evidence presented at trial, all pursuant to Federal Rules of Evidence 702.

Special Agent Chad Simkins, Federal Bureau of Investigation

Chad Simkins, Special Agent, Federal Bureau of Investigation, will

S/A Simkins is an FBI certified Firearms Instructor and Tactical Instructor.

Virginia, where he currently serves as a supervisor in the Firearms Training Unit

Case 2:16-cr-00046-GMN-PAL Document 1250 Filed 01/06/17 Page 3 of 19

from whatever source derived, whether it be Facebook, YouTube, or conventional

with identifying images of objects he determined to be firearms (as that term is

defined by law) and identifying persons carrying, using, brandishing, or pointing

photographic evidence he reviewed. With this information, Special Agent Simkins

with creating a diagram, plotting the positions of persons carrying, using,

Case 2:16-cr-00046-GMN-PAL Document 1250 Filed 01/06/17 Page 4 of 19

brandishing, pointing firearms relative to known the positions of the law

enforcement officers and over time, establishing a timeline and summary of

movements of persons with firearms.

Summary of Anticipated Testimony.

investigation. In connection with that review, he used his investigative skills,

or pointing) during two intervals of time: 1) approximately 11:57 to 12:13 during

Case 2:16-cr-00046-GMN-PAL Document 1250 Filed 01/06/17 Page 5 of 19

The sum and substance of the results of his analysis is

therefore, he will testify about the distances between various geographical

metrics are contained at Exhibit 2.

Case 2:16-cr-00046-GMN-PAL Document 1250 Filed 01/06/17 Page 6 of 19

Special Agent Joel P. Willis, Federal Bureau of Investigation

Special Agent Mark Seyler, Federal Bureau of Investigation

education, training and experience: He has been employed as a Special Agent of

the FBI for approximately 13 years. He is currently assigned to the Domestic

specializes in investigations targeting individuals and organizations who may pose

Degree in Biology and a Masters of Science Degree in Molecular Genetics and,

graduated from New Agent Training at the FBI Academy in Quantico,

investigations involving Acts of Terrorism, Material Support for Terrorism, Assault

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multiple occasions regarding this review and analysis of internet-based information

near Bunkerville, Nevada) since May 2014.

S/A Seyler has been assigned to the

investigation of Ryan Payne since at least April 2014.

near Bunkerville, Nevada) since May 2014.

investigation of Ryan Payne since at least April 2014.

S/A Seyler has been assigned to the

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experience and expertise in reviewing and analyzing social media communications

YouTube relative to the defendants charged in the Superseding Indictment. Both

various communications and postings

Summary of Anticipated Testimony

Facebook asks users to provide basic contact and personal identifying

information to Facebook, either during the registration process or thereafter. This

addresses, Facebook passwords, Facebook security questions and answers (for

Case 2:16-cr-00046-GMN-PAL Document 1250 Filed 01/06/17 Page 9 of 19

assigns a user identification number to each account.

communications electronically or view information about each other electronically.

of Facebook friends to facilitate the application of these privacy settings. Facebook

example, the types of notifications they receive from Facebook.

about their whereabouts and actions, as well as links to videos, photographs,

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check in to particular locations or add their geographic locations to their Facebook

typically be visible to anyone who can view the users profile.