Tribal Solutions Group, LLC, et al. v. Joseph Valandra, et al.

          IN THE UNITED STATES DISTRICT COURT                        
        FOR THE SOUTHERN DISTRICT OF MISSISSIPPI                     
                  NORTHERN DIVISION                                  

TRIBAL SOLUTIONS GROUP, LLC, et                                           
al.,                                                                      

                  Plaintiffs,                                        

v.                                    CAUSE NO. 3:23-CV-10-CWR-LGI        

JOSEPH VALANDRA, et al.,                                                  

                 Defendants.                                         

          ORDER ON MOTION TO EXCLUDE IN PART                         

Joseph Valandra, Clayton Wooley, Jase Wilson, Michael Faloon, Ready.net, Inc., and 
Tribal Ready, Inc designated expert, Sean Sarsfield, for the purpose of producing rebuttal 
reports criticizing the expert reports produced by Richard Eichmann. Tribal Solutions Group, 
LLC, Tribal Communications, LLC, Dan C. Davis, and TC2, LLC (the “TC Parties”) moved 
the Court for an order to exclude portions of Mr. Sarsfield’s opinion and testimony that 
reference or rely on ex post methodology for calculating economic damages (i.e., rely on 
information unavailable or unknown on the date of valuation—the so-called “Book of 
Wisdom” approach). Docket No. 162. The Court held a hearing on this matter on October 20, 
2025. For the reasons discussed during the hearing and those included below, the Court 
denies the TC Parties’ motion.                                            
As discussed during the hearing, the applicability of the “Book of Wisdom” approach1 
is the subject of an open and robust debate in the field of valuation. The presence of that 

1 During the hearing, the Court noted the possible prejudicial effect referring to this method as “the Book 
of Wisdom” may have at trial. The parties are instructed to refrain from referring to this methodology in 
this manner before any jurors or prospective jurors.                      
professional disagreement indicates that this is not the type of opinion that Rule 702 was 
designed to keep out of the courtroom. Fed. R. Evid. 702 advisory committee’s note to 2000 
amendments (describing the rule as “broad enough to permit testimony that is the product 

of competing principles or methods in the same field of expertise.”). See also United States v. 
Jordan, No. 3:18-CR-67, 2023 WL 8703773 (S.D. Miss. Dec. 2, 2023) (discussing the effects of 
the most recent 2023 amendment to Rule 702). Satisfied that Sarsfield has a sufficient basis to 
support his challenged opinions, the Court finds that the TC Parties may adequately explore 
the weaknesses of Mr. Sarsfield’s analysis via cross-examination. See Jordan, 2023 WL 8703773, 
at *4 (“The merits of the expert's conclusions remain subject to attack at trial under traditional 
principles of ‘[v]igorous cross-examination, presentation of contrary evidence, and careful 

instruction on the burden of proof.’”) (quoting Daubert v. Merrell Dow Pharm., Inc., 509 U.S. 
579, 596 (1993)). The motion to exclude in part is therefore denied.      
SO ORDERED, this the 23rd day of October 2025.                       
                              s/ Carlton W. Reeves                   
                              UNITED STATES DISTRICT JUDGE