context: Second, her testimony about the fraud indicators helped the jury better understand the significance of the commonalities in the tax returns. Third, Calabrese's testimony was not the type of specialized testimony that needed to be admitted under Rule 702 because it was based on a summary of documents related to the case, the jury could have reviewed the documents itself and noticed the commonalities among the returns filed under Variste's EFIN, and the opinions given by Calabrese related to the summary that she prepared.
citation_a.signal: see also
citation_a.identifier: 643 F.3d 807, 841
citation_a.parenthetical: "Rule 701 does not prohibit lay witnesses from testifying based on particularized knowledge gained from their own personal experiences."
citation_a.sentence: See United States v. Hamaker, 455 F.3d 1316, 1331-32 (11th Cir.2006) (concluding a financial analyst from the Federal Bureau of Investigation gave lay testimony when he summarized thousands ' of financial documents, compared time sheets to payroll entries, and testified a fraud victim was billed for work that was performed for someone else, because “while [the agent’s] expertise and the use of computer software may have made him more efficient at reviewing [the company’s] records, his review itself was within the capacity of any reasonable lay person”); see also United States v. Hill, 643 F.3d 807, 841 (11th Cir.2011) (“Rule 701 does not prohibit lay witnesses from testifying based on particularized knowledge gained from their own personal experiences.”).
citation_b.signal: see
citation_b.identifier: 455 F.3d 1316, 1331-32
citation_b.parenthetical: concluding a financial analyst from the Federal Bureau of Investigation gave lay testimony when he summarized thousands ' of financial documents, compared time sheets to payroll entries, and testified a fraud victim was billed for work that was performed for someone else, because "while [the agent's] expertise and the use of computer software may have made him more efficient at reviewing [the company's] records, his review itself was within the capacity of any reasonable lay person"
citation_b.sentence: See United States v. Hamaker, 455 F.3d 1316, 1331-32 (11th Cir.2006) (concluding a financial analyst from the Federal Bureau of Investigation gave lay testimony when he summarized thousands ' of financial documents, compared time sheets to payroll entries, and testified a fraud victim was billed for work that was performed for someone else, because “while [the agent’s] expertise and the use of computer software may have made him more efficient at reviewing [the company’s] records, his review itself was within the capacity of any reasonable lay person”); see also United States v. Hill, 643 F.3d 807, 841 (11th Cir.2011) (“Rule 701 does not prohibit lay witnesses from testifying based on particularized knowledge gained from their own personal experiences.”).