BILLY J. WILLIAMS, OSB #901366 

United States Attorney 

District of Oregon 

STUART A. WEXLER 

Trial Attorney, Tax Division 

Stuart.A.Wexler@usdoj.gov 

LEE F. LANGSTON 

Trial Attorney, Tax Division 

Lee.F.Langston@usdoj.gov 

1000 SW Third Ave, Suite 600 

Portland, OR 97204-2902 

Telephone: (503) 727-1000 

Facsimile: (503) 727-1117 

Attorneys for United States of America 

UNITED STATES DISTRICT COURT 

DISTRICT OF OREGON 

PORTLAND DIVISION 

UNITED STATES OF AMERICA, Case No.: 3:15-CR-00438-JO 

 

Plaintiff,

v. 

WINSTON SHROUT, 

Defendant.

SUPPLEMENTAL NOTICE OF 

INTENT TO INTRODUCE EXPERT 

WITNESS TESTIMONY PURSUANT 

TO FEDERAL RULE OF CRIMINAL 

PROCEDURE 16(a)(1)(G) 

 The United States of America, by and through Billy J. Williams, United States Attorney 

for the District of Oregon, Stuart A. Wexler and Lee Langston, Trial Attorneys, Tax Division, 

hereby gives Supplemental Notice of Its Intent to Introduce Expert Witness Testimony Pursuant 

to Federal Rule of Criminal Procedure (16)(a)(1)(G). 

 The United States previously provided notice of its intent to offer the expert testimony of 

William C. Kerr during its case-in-chief. (Doc. 23.) As noted therein, Mr. Kerr is a former 

National Bank Examiner for the Office of the Comptroller of the Currency and is now retired and 

Case 3:15-cr-00438-JO Document 75 Filed 03/23/17 Page 1 of 4
SUPPLEMENTAL NOTICE OF INTENT TO INTRODUCE 

EXPERT WITNESS TESTIMONY 

PURSUANT TO FEDERAL RULE OF 

CRIMINAL PROCEDURE 16(a)(1)(G) - 2 

in private practice. In addition to the expert testimony previously noticed, Mr. Kerr will provide 

testimony concerning 632 additional documents found on Defendant’s computer.1

 Mr. Kerr will 

testify that his examination of the documents revealed that they are fictitious financial 

instruments without any material financial value. He will further opine that the documents were 

created solely for the purpose of perpetrating a fraud, and are designed in such a way as to 

attempt to create an aura of authenticity to the casual observer. The documents purport to draw 

on a depository account at the United States Department of Treasury for the benefit of 

Defendant. Mr. Kerr will testify that such individual accounts do not exist at the Treasury. Mr. 

Kerr’s qualifications are set forth in his curriculum vitae, attached as Exhibit A to the 

Government’s initial Notice. See Doc. 23. at Exhibit A. The Government will provide Defendant 

with a copy of Mr. Kerr’s original and supplemental opinions in advance of trial and consistent 

with District of Oregon Standing Order 2015-5(a). 

The Government’s initial Notice provided grounds for admitting Mr. Kerr’s expert 

testimony; such basis applies equally to Mr. Kerr’s supplemental material outlined above. See

Doc. 23. 

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1

 All documents reviewed by Mr. Kerr were found on Defendant’s computer and previously provided in 

discovery. 

Case 3:15-cr-00438-JO Document 75 Filed 03/23/17 Page 2 of 4
SUPPLEMENTAL NOTICE OF INTENT TO INTRODUCE 

EXPERT WITNESS TESTIMONY 

PURSUANT TO FEDERAL RULE OF 

CRIMINAL PROCEDURE 16(a)(1)(G) - 3 

 DATED this 23rd day of March, 2017. 

Respectfully submitted, 

BILLY J. WILLIAMS 

United States Attorney 

/s/ Stuart A. Wexler 

STUART A. WEXLER 

LEE F. LANGSTON 

Trial Attorneys, Tax Division 

(202) 305-3167 

Case 3:15-cr-00438-JO Document 75 Filed 03/23/17 Page 3 of 4
SUPPLEMENTAL NOTICE OF INTENT TO INTRODUCE 

EXPERT WITNESS TESTIMONY 

PURSUANT TO FEDERAL RULE OF 

CRIMINAL PROCEDURE 16(a)(1)(G) - 4 

CERTIFICATE OF SERVICE

 I HEREBY CERTIFY that on March 23, 2017, I electronically filed the foregoing with 

the Clerk of the Court using the CM/ECF system, which will send notification of such filing to 

the attorney(s) of record for the defendant. Additionally, a copy of the foregoing was emailed to 

the defendant at milieannjones@gmail.com. 

/s/ Stuart A. Wexler 

Stuart A. Wexler 

Trial Attorney, Tax Division 

Case 3:15-cr-00438-JO Document 75 Filed 03/23/17 Page 4 of 4