Expert Witness Profiler

Tag: Staff

  • Correctional Healthcare Expert Not Allowed to Opine on Physical Symptoms

    Correctional Healthcare Expert Not Allowed to Opine on Physical Symptoms

    This action arises from the death of Gregory Neil Davis while he was incarcerated as a pretrial detainee at the Oklahoma County Detention Center. Plaintiff, as special administrator of the estate of Davis, alleged that numerous Jail and Medical Defendants acted with deliberate indifference to Davis’ serious medical needs in violation of the Fourteenth Amendment and were negligent under state law.

    Plaintiff filed three motions to exclude or limit the testimony of Dr. Paul M. Adler, Kathryn J. Wild, RN and Lori E. Roscoe, PhD.

    Correctional Healthcare Expert Witness

    Paul Morris Adler is a licensed medical doctor with a board certification in emergency medicine and a background in providing medical care in correctional settings.

    Discover more cases with Paul Adler as an expert witness by ordering his comprehensive Expert Witness Profile report.

    Nursing Expert Witnesses

    Kathryn Jean Wild, RN is a registered nurse and a Certified Corrections Healthcare Professional. She has decades of experience as a nurse in correctional settings. 

    Get the full story on challenges to Kathryn Wild’s expert opinions and testimony with an in-depth Challenge Study.

    Lori Elisabeth Roscoe, Ph.D., APRN is a nurse practitioner and Certified Correctional Health Professional with decades of experience in correctional healthcare, including with policy development, staff supervision, and administration.

    Want to know more about the challenges Lori Roscoe has faced? Get the full details with our Challenge Study report.

    Discussion by the Court

    A. Motion to Exclude Testimony of Adler

    Adler’s report largely consisted of factual narrative followed by his observation as to what the underlying facts show, including conclusions that there is “no evidence” or no “information or testimony” suggesting that Davis communicated his physical symptoms to anyone at the jail. These statements did not involve the application of scientific, technical, or specialized knowledge but instead expressed opinions that are “essentially factual matters as to which expert testimony is inappropriate and/or unnecessary.”

    When Adler comes closer to expressing an opinion that might be the proper subject of expert testimony, he fails to identify facts, data, standards, practices, or any other reliable principles that support his conclusions. For example, Adler opined that it is probable that symptoms began after August 9th and that an earlier medical exam would not have changed the outcome, but he did not adequately explain the basis of these opinions. Adler also speculates about what Davis knew and inappropriately weighs in on the credibility of a witness.

    Given the deficiencies in Adler’s report, the Court granted the Plaintiff’s motion to exclude the testimony.

    B. Motion to Exclude Testimony of Nurse Wild

    Plaintiff argued that Kathryn Wild offered several opinions that are outside the scope of her expertise and challenged the reliability and relevance of the other opinions.

    The Court found that Wild is qualified to offer opinions as to whether the medical staff responded appropriately and complied with applicable standards based on Davis’ clinical presentation. Additionally, although Wild is not an expert as to jail operations in general, her experience renders her qualified to offer opinions on how medical and nursing services operate in a correctional setting.

    Wild reached her opinions by reviewing medical records, deposition testimony, facility documentation and other evidence and then applying her experience in correctional health care. Further, and importantly, she identified the correctional health care standards that govern and the facts that supported her opinions.

    However, Wild’s report suffered from two deficiencies that render certain opinions unreliable or unhelpful to the jury. First, her opinion that the medical and mental health staff were not deliberately indifferent is an impermissible legal conclusion. Second, Wild’s report included factual narrative followed by conclusions that there is “no evidence” or “no documentation” that Davis verbalized or demonstrated pain or distress. These opinions did not involve the application of any specialized medical or nursing knowledge and were simply based on testimony from staff stating that Davis did not request help and the absence of any reports of pain in the medical charting.

    C. Motion to Exclude Testimony of Nurse Roscoe

    Plaintiffs have identified Lori Roscoe, Ph.D., APRN as an expert witness that will opine on standards of care and the care provided to Davis while he was detained.

    The Medical Defendants argued that she was unqualified to offer opinions as to whether the actions of a licensed professional counselor that saw Davis during his incarceration were appropriate. They also contended that her opinions regarding the scope of practice of a licensed practical nurse are unreliable.

    Although Roscoe is not a licensed professional counselor, she has experience in correctional healthcare operations and staff supervision. Her opinions are grounded in that expertise as they speak to when correctional healthcare staff should escalate care to another provider as opposed to the quality of the counseling provided by the LPC or the adequacy of the psychiatric treatment provided to Davis. The Court held that Roscoe’s experience and training are sufficient to render her qualified to opine on standards and practices for referring patients in correctional settings for additional evaluation and treatment.

    The Medical Defendants contended that Roscoe’s opinion that the LPN acted outside the scope of her practice by making diagnostic decisions, and specifically by attributing Davis’ change in condition to a mental health problem without referring him for a medical evaluation, is unreliable because she did not cite any authority to support her opinion. The Court agreed that Roscoe’s opinion that the LPN “exceeded the scope of her practice” or acted “far outside the scope of LPN practice” is not supported by sufficient facts or reliable methods and principles.

    Additionally, Roscoe’s deposition testimony indicated that the basis of her criticism of the LPN’s actions is not necessarily that she referred him to mental health, but that she did not also refer him for a medical evaluation given his symptoms.

    Although Roscoe’s explanation of the applicable standards could have been more detailed, the Court found that her opinion that the LPN’s actions deviated from accepted standards is sufficient to satisfy Rule 702‘s reliability requirements.

    Held

    • The Court granted the Plaintiff’s motion to exclude or limit the testimony of Dr. Paul Adler.
    • The Court granted in part and denied in part the Plaintiff’s motion to exclude or limit the testimony of Kathryn J. Wild, RN.
    • The Court granted in part and denied in part the Plaintiff’s motion to exclude or limit the testimony of Lori Roscoe, PhD.

    Key Takeaway

    An expert opinion “must be based on facts which enable her to express a reasonably accurate conclusion as opposed to conjecture or speculation.” The credibility of witnesses is generally not an appropriate subject for expert testimony.

    Case Details:

    Case Caption: Simms V. Board Of County Commissioners For Oklahoma County
    Docket Number: 5:23cv780
    Court Name: United States District Court, Oklahoma Western
    Order Date: February 03, 2026
  • Law Enforcement Expert Was Not Allowed to Opine on Trafficking at Hotels

    Law Enforcement Expert Was Not Allowed to Opine on Trafficking at Hotels

    This case arises under the Trafficking Victims Protection Reauthorization Act (TVPRA), which provides victims of sex trafficking a civil remedy against the perpetrators and beneficiaries of their trafficking. Plaintiff C.L.F. filed this action to recover for alleged harm she experienced from being trafficked at a Motel 6 in Wichita, Kansas, that she claims was owned and operated by the Defendants.

    On August 21, 2025, C.L.F. filed the motion sub judice, seeking to exclude as irrelevant the testimony of Defendants’ designated law-enforcement expert witness Bill Woolf.

    Law Enforcement Expert Witness

    William “Bill” Woolf has spent over 15 years of experience in law enforcement, specializing in the investigation of human trafficking, organized criminal enterprises, narcotics, and gang-related crime.

    He has conducted extensive fieldwork in identifying, investigating, and dismantling human trafficking networks, with a focus on both sex trafficking and labor trafficking operations occurring in a variety of settings, including hospitality environments.

    Woolf is the Principal and Founder of The Woolf Group, a national consulting firm providing expert guidance on human trafficking prevention, investigation, training, and public policy.

    Fortify your strategy by reviewing a Challenge Study detailing grounds for excluding Bill Woolf’s expert testimony.

    Discussion by the Court

    C.L.F. asked the Court to exclude all four opinions offered by Woolf. Namely, Woolf’s opinions that:

    (1) “There is no evidence that trafficking involving CLF was identified or interdicted by law enforcement during the relevant period;”

    (2) “Hotel staff are not trained, equipped, or authorized to investigate or intervene in suspected trafficking operations;”

    (3) “In transient lodging environments, the investigative and intervention burden for human trafficking rests with law enforcement, not hotel personnel;” and

    (4) “It is unreasonable to retroactively impose a higher duty of detection on hotel staff than the standard applied by law enforcement at the time.”

    C.L.F. claimed that “all of Woolf’s opinions are red herrings that draw the jury’s attention to topics that have no bearing on the actual issues that must be decided in this case.”

    Opinion 1

    Woolf may not tell the jury there was “no evidence that trafficking involving C.L.F. was identified or interdicted by law enforcement during the relevant period.” This is irrelevant to understanding whether hotel staff knew or should have known of sex trafficking at the Wichita Motel 6. It is also misleading. Hearing that police officers had “frequent engagement with the subject properties” and that they made no reports or arrests for sex-trafficking related crimes would lead a juror to conclude that such conduct was absent. That distracts the jury from the pertinent inquiry. Numerous arrests for sex trafficking might put hotel employees on notice, but that logic does not follow from a total absence of arrests. Law enforcement may not have arrested anyone for trafficking at the Wichita Motel 6, but that in no way precludes hotel management and staff from being aware of ongoing sex-trafficking-related activity.

    As such, the Court struck Woolf’s opinion as irrelevant and misleading.

    Opinion 2

    The Court struck Woolf’s second opinion as misleading. Investigating and/or intervening in human trafficking is not an element of the TVPRA and to suggest that Defendants’ employees were not trained or able to investigate, identify, or interdict trafficking injects elements into C.L.F.’s burden of proof that simply are not there. All that is required for C.L.F. to show is that Defendants’ employees were negligently aware of sex-trafficking-related activity on the property.

    Opinion 3

    The jury cannot hear Woolf’s third opinion. It would tell the jury that, since hotel staff lack the “access to confidential intelligence, interagency data, investigative tools, and legal mechanisms such as warrants and subpoenas” that police officers have, hotel staff are unable to “reliably assess” potential trafficking red flags.

    This would seriously undercut the jury’s factfinding role. As said, hotel staff cannot escape imputing knowledge from their own observations of sex-trafficking-related activity just because they lack military-grade investigative tools. A janitor’s inability to petition a judge for an arrest warrant has no bearing on his awareness of sex trafficking if there were observable signs of trafficking in the hotel hallways. The jury, who “is solely responsible for determining the weight and credibility of the evidence,” should assess how Defendants’ staff interpreted those signs without assessing how a police officer would react.

    Further, pointing out hotel staff’s lack of crime-prevention tools might mislead the jury to think that the TVPRA excuses liability where a defendant is unable to prevent sex trafficking. As the parties know, making that suggestion to the jury would be wholly inappropriate because “the TVPRA does not impose an affirmative duty to police and prevent sex trafficking” (nor excuse sex-trafficking liability because no duty to prevent exists). The relevant inquiry is whether hotel staff knew of trafficking, not if they prevented, or attempted to prevent, it. 

    Opinion 4

    Woolf’s fourth opinion is simply a summary of his already discussed testimony. His claim that it is “unreasonable to retroactively impose a higher duty of detection” on hotel staff than law enforcement highlights the irrelevance of his other opinions. Discussion of law enforcement’s knowledge or lack thereof regarding trafficking at the Wichita Motel 6 has no effect on that of hotel management and staff. Referring to it would only mislead the jury. Woolf’s testimony appears designed to imply that Defendants were unaware of sex trafficking because law enforcement, with all its law-enforcement techniques, was also unaware. While sensible to think that a layperson would not detect an ongoing crime if a police officer in the same situation could not, that analogy is “non-helpful” here.

    The standard is whether hotel staff knew of sex trafficking at their hotel. As explained, hotel staff are in a much different position than police officers to observe the day-to-day happenings at a hotel. The ways in which law enforcement and hotel staff acquire knowledge of sex trafficking at a hotel are completely different and to conclusively suggest to the jury that what was not observable to law enforcement was not observable to hotel staff is both untrue and unhelpful.

    Rebuttal Opinions

    Defendants pointed out that Woolf also offered rebuttal testimony to C.L.F.’s experts, and that C.L.F.’s motion did not request those rebuttal points to be excluded. C.L.F. responded that, if the Court excludes Woolf’s opinions, then it should also exclude his rebuttal opinions.

    All four opinions asserted that it would be unreasonable to find that hotel staff were aware of sex trafficking at the Wichita Motel 6 because law enforcement, with its greater resources, tools, and training, was not. As explained, such testimony would only confuse the jury.

    Rebuttal Opinion 2 responded to C.L.F.’s expert witnesses’ claims that hotel training was inadequate by pointing out that no industry standards about sex-trafficking awareness, such as the DHS Blue Campaign Hospitality Toolkit, existed until after this case’s relevant trafficking period.

    The opinion also pointed out how “assertions by [C.L.F.’s law-enforcement expert] Christi Decouflé that G6 policies actively discouraged reporting to law enforcement are not substantiated by the record.” But this is straightforward impeachment. It did not help the jury to have Woolf provide such testimony. Impeaching a witness by highlighting inconsistencies between their testimony about documents and facts contained in and relating to those documents does not require specialized knowledge, nor even a live witness; instead, that is the role of counsel.

    This Ruling Remains Good for Both the Goose and the Gander

    Woolf’s testimony could only muddle things, as he would not testify about red flags observable or known to hotel employees. Instead, he wants to advise the jury on what law enforcement would or would not have known. This would not help the jury.

    While Woolf’s testimony goes to Defendants’ actual or constructive knowledge about the trafficking, it is inappropriate as compared to other experts.

    Decouflé’s testimony here is based on Defendants’ own policies, guests’ online reviews, and what potential sex-trafficking-related facts the hotel workers, not police, saw during the relevant time. She would testify to hotel-staff knowledge based on hotel-staff observations while Woolf would compare hotel-staff knowledge and training to police-officer knowledge and training. For a jury deciding what the hotel staff knew or should have known, the former is helpful; the latter is not. Woolf’s testimony is irrelevant.

    Held

    The Court granted Plaintiff’s motion to strike or exclude the testimony of Bill Woolf.

    Key Takeaway:

    The perspective of a trained law enforcement officer experienced in identifying, investigating, and intervening in cases of human trafficking—even within hospitality settings—would not help the jury understand or determine whether G6’s management or staff knew, or should have known, that sex trafficking was occurring at the Wichita Motel 6.

    While Woolf indicated that he considered “the observable signs and behaviors that might have been available to hotel staff,” his opinions address only what law enforcement would understand and/or do in response to those observations.

    Please refer to the blog previously published about this case:

    Psychology Expert’s Opinion on Social-Media-Facilitated Sex Trafficking Admitted

    Case Details:

    Case Caption: Doe C.L.F. V. G6 Hospitality, LLC
    Docket Number: 1:23cv303
    Court Name: United States District Court, Texas Eastern
    Order Date: November 17, 2025