U.S. Department of Justice

United States Attorney

Northern District of Illinois

Michael J. Kelly

Assistant United States Attorney

Dirksen Federal Courthouse

219 South Dearborn Street, Fifth Floor

Chicago, IL 60604

Direct Line: (312) 697-4037

Fax: (312) 353-4322

E-mail: Michael.Kelly@usdoj.gov

May 6, 2021

Quinn Alexandra Michaelis

73 W. Monroe

Chicago, IL 60603

Email: qmichaelis@yahoo.com

Re: United States v. Martin Crossley, 20 CR 369

Dear Ms. Michaelis:

During the trial of the above-captioned case, the government intends to

present expert testimony as detailed below. Please consider this letter to be the

government’s formal notice pursuant to Federal Rule of Criminal Procedure 

16(a)(1)(G) of the government’s intention to call the following witness:

Special Agent Jeremy Bauer of the Federal Bureau of Investigation

The government intends to call Special Agent Jeremy Bauer to testify

regarding the historical cell site analysis he performed to determine the use and

general location of the following cellular telephone:

Phone Number User

(630) 660-0402 Martin Crossley

The government anticipates that Special Agent Bauer’s testimony will 

include statements about how cell phone towers operate. Special Agent Bauer will

testify consistent with his report, draft charts, and maps, and the historical cellular

phone data provided to defendants in discovery. The government will produce a 

draft of Special Agent Bauer’s report and accompanying materials subject to your 

agreement that this information will be used for pretrial purposes only and that 

you will not seek to rely on it at trial for cross-examination or any other purpose. 

Specifically, Special Agent Bauer will provide his opinion as to the general

areas in which the cellular telephone was located on the relevant date andtime of

the robbery as identified in the indictment as well as dates adjacent to the robbery 

date based. That testimony will rely on information furnished by a wireless phone 

Case: 1:20-cr-00369 Document #: 58-1 Filed: 05/28/21 Page 1 of 2 PageID #:377
service provider concerning which cell towers the above cellular telephone 

connected with during those times. Special Agent Bauer will also testify regarding 

which cell tower sectors were utilized for the relevant calls close in time to the 

robbery and explain that the direction of the cell tower sector utilized for any 

particular call can indicate the general location of the cell phone relative to the 

tower utilized for the call.

The data supporting Special Agent Bauer’s opinions is located in the files of

the cell phone records provided by T-Mobile and previously produced in discovery

including on September 3, 2020, and January 11, 2021. 

Finally, Special Agent Bauer has testified as an expert witness on historical

cell site analysis in federal court and state court on a number of occasions, as detailed

in Special Agent Bauer’s CV, which is included with this letter.

The government continues to evaluate whether any additional expert

witnesses will be needed for the trial and will update this disclosure if appropriate.

Finally, as requested in the government’s letter of September 3, 2020, please 

provide written summaries of any expert opinions that defendant intends offer at 

trial as required by Rule 16(b)(1)(C). 

Please contact me if you have any questions.

Very truly yours,

JOHN R. LAUSCH, JR.

United States Attorney

By: /s/ Michael J. Kelly

Michael J. Kelly

Timothy Storino

Assistant United States Attorneys

Case: 1:20-cr-00369 Document #: 58-1 Filed: 05/28/21 Page 2 of 2 PageID #:378