Notice of Expert Testimony - Page 1

IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF TEXAS 

FORT WORTH DIVISION 

UNITED STATES OF AMERICA 

 

v. Criminal No. 4:22-CR-213-P 

DAVID DEVANEY, SR. et al. 

 

NOTICE OF EXPERT TESTIMONY 

TO THE HONORABLE MARK T. PITTMAN, U.S. DISTRICT JUDGE: 

The United States of America in its Notice of Expert Testimony, and would 

respectfully show this Court as follows: 

The government expects to call HSI Agent Mike McCurdy, Johnson County 

Sherriff’s Office Deputies Curran Massey and Andrew Riggs, Burleson Police 

Department Officer Larry Sparks, and/or another qualified expert, to testify from his 

expertise on techniques and processes unique to drug trafficking. More specifically, one 

of the designated experts, or another qualified expert will testify about: 

(1) the use and utility of couriers to transport narcotics; 

(2) the street-value of methamphetamine, and other relevant illegal drugs; 

(3) the common transportation routes of methamphetamine from Mexico to and 

 throughout the United States; 

(4) the use of multiple cellular telephones including the frequent disposal of 

 such; 

(5) the use of other drug trafficking paraphernalia (e.g., digital scales, money 

 counters, baggies); 

(6) the use of coded language to disguise the fact that drug dealers are talking 

 about distributing drugs; 

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(7) common business practices between and amongst drug dealers (e.g., the 

 concept of “fronting” drugs or delivering drugs to another person on 

 consignment; the concept of “vouching” for another person in the context 

 of purchasing drugs from a source of supply; the accrual of a drug-debt for 

 a person/courier who loses drugs due to law enforcement intervention or 

 otherwise); and 

(8) the use of residences and/or other establishments (e.g. “game rooms”) to 

 conduct drug transactions between and amongst a wide and varying range 

 of drug distributors and drug customers. 

The government expects to call KeiSharra Eldridge, Angela Cassady, Carissa 

Stark-Hopenwasser, Marsha Cole, Pauline Orlando, Kiana Henderson, Phanneth Som, 

and Charity Foreman, and/or another qualified chemist(s), from the DEA South Central 

Laboratory in Dallas, Texas, to testify as to his/her opinion regarding the identification of 

narcotics seized in this case. 

 Respectfully Submitted, 

CHAD E. MEACHAM 

UNITED STATES ATTORNEY 

s/ Shawn Smith 

SHAWN SMITH

Assistant United States Attorney

State Bar of Texas No. 24033206 

801 Cherry Street, Unit #4 

Burnett Plaza, Suite 1700 

Fort Worth, TX 76102-6897 

Telephone: 817-252-5200 

Facsimile: 817-252-5455 

Email: Shawn.Smith2@usdoj.gov 

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CERTIFICATE OF SERVICE

I hereby certify that on August 29, 2022, I electronically filed the foregoing 

document with the clerk for the U.S. District Court, Northern District of Texas, using the 

electronic case filing system of the court. The electronic case filing system sent a 

ANotice of Electronic Filing@ to the attorneys of record who have consented in writing to 

accept this Notice as service of this document by electronic means. 

s/ Shawn Smith 

 SHAWN SMITH

Assistant United States Attorney 

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