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    Govt's Discovery Letter 03082010

    Uploaded by

    DcSleuth

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    ORIGINAL SUPERIOR COURT OF THE DISTRICT OF COLUMBIA CRIMINAL DIVISION - FELONY BRANCH i 22337 UNITED STATES OF AMERICA ) CRIMINAL NOS. 2008-CF1-27068 : ) 2008-CF1-26997 Po eee tw ) 2008-CF1-26996 ) JOSEPH PRICE ) JUDGE LYNN LEIBOVITZ VICTOR ZABORSKY ) DYLAN WARD ) STATUS DATE: 3/12/10 NOTICE OF FILI ‘The government requests that the attached discovery letter (without attachments), dated March 8, 2010, be made part of the record in this case, RONALD C. MACHEN JR, United States Attorney IN L. KIRSCHNER T. PATRICK MARTIN Assistant United States Attorney 555 4th Street, N.W. Washington, DC 20530 (202) 514-7425 (GLK) (202) 514-7504 (TPM) CERTIFICATE OF SERVICE {hereby certify that l caused a copy ofthe attached discovery letter (without attachments) 19 ve served via fuesimile and e-mail and a copy (with attachments) tobe available for courier pickup oe arch 8. 2010, upon Bernard Grimm, Esq., The Army and Navy Building, 1627 1 Street, NW, Suite 1100, Washington, DC 20006, counsel for defendant Price, Thomas G. Connolly, sg, .Hartis, Aiithive & Grannis, LLP, 1200 Eighteenth Strect,N.W., 12th Floor, Washington, DC 20036-2506, aeee el for defendant Zaborsky, and David Schertler, Esq, Scherller & Onorato, LLP, 601 Pennsylvania Avenue NW, North Building, 9th Floor, Washington, DC 20004-2601, counsel for Aefendant Ward. Iiitivwy, fate Assistant United States Attorney HALLR 03/09/2010 6:09:47 AN US. Department of Justice Ronald C, Machen Jr. United States Attomey District of Columbia Judisary Center 535 Fourh St. NH. Mashingion, BC: 20830 March 8, 2010 BY FACSIMILE AND E-MAIL (LETTER. O LY) AND COURIER PICK-UP Bernie S. Grimm, Esq. Cozen O'Connor The Army and Navy Building 1627 I Street, N.W., Suite 1100 ‘Washington, DC 20006 ‘Thomas G. Connolly, Esq, Harris, Wiltshire & Grannis, LLP 1200 Bighteenth Street, N.W., 12th Floor Washington, DC 20036-2506 David Schertler, Esq. Schertler & Onorato, LLP 601 Pennsylvania Avenue NW North Building, 9th Floor Washington, D.C. 20004-2601 Re: United States v. Joseph Price Case No, 2008-CF1-27068 United States v, Victor Zaborsky ‘Case No. 2008-CF1-26997 United States v. Dylan Ward Case No. 2008-CF1-26996 Dear Counsel: ‘This is intended to summarize and supplement futher the government's Rule 16(a)(1)(E) expert diselosures in response to your complaints concerning, said disclosures, as set forth in various 1 HALLR 03/08/2010 6:09:47 AN correspondence and Defendants’ Joint Motion (9 Compel Rule 16(a)(1)(E) Disclosures:' As previously disclosed, the government may seek fo {introduce or use the following expert witnesses vr tial who will provide testimony as provided below? (1) Dr. Lois Gostinoski, Dr. Goslinoski fe a forensic pathologist, currently employed as a Deputy Medical Examiner for the District of Columbia. As you know, Dr. Goslinoski performed the autopsy on Mr. Wone: a atifgations of expert: ‘The government previously supplied you with a copy of the curriculum vitae for Dr. Goslinoski (see 2429-2432). b. ‘Summary of expected testimony, including expert-epiniont that will be rendered by the expert; The government previously supplied you with the autopsy report issued by Dr. Goslinoski, which included a summer of the expected testimony find expert opinions for this expert (see P8-18). Dr Goslinoski is expected to testify ane cyupathology and her observations and concTusions concemings here OF ats, Wone. Consistent with her report, Dr. Goslinoski is expected to testify that Ms, Wone died as a result of three remarkably clean, symmetrical, uniform stab visands to his torso, Dr. Goslinoski is expected to testify that there were no defects Inthe stab wounds (i.e.,no drag marks, abrasions o“fish-tailing”). Each wound was vnilieted at approximately the same angle, Dr. Goslinoski is expected to testify that ane found a. single petechial hemorrhage in the right sclera and the left lower Conjunctiva (white of the eye). Such a finding is consistent with some type of asphyxial event. Dr. Gostinoski is expected to testify that the stab wounds appear to teeny poen eaused by the same size knife, duc to the similariny of the three stab sa ids, Dr_ Goslinoski is also expected to testify that the knife found by the police wots bedside table next tothe bed in which Mr. Wone was lying was not the murder wweapon. Instead, in her experience, a knife blade that is four and one-half inches in Tength (e., the knife missing from defendant Ward's cutlery set) is more consistent ae es ee + We note that it has always been the governments position that where Ihe government discloses to the defense an expert report issued by the expert witness © ‘the defendant, and that feport adequately summarizes the expert's expected opinions ‘and basis and reasons for those Opinions, the government has complied with the “writen, summary” reguirements of Rule Volay(I)XE). Cf Waldron v. United States, 370 A.2d 1372, 1374 (D.C. 1977) (in upholding the soe ant's pretrial discovery ruling and afirming the conviction, sate that “the prosecution complied with Rule 16, supra, by furnishing the ‘results oF reports’ of the test performed Nothing more was required by Rule 16. ."). Indeed, athe ‘September 11, 2009 status hearing in this case, the Court agreed with this practical application of Rule 16 (see 9/11/09 Tr. 15:2-16). 2 please note that while we have largely maintained the number designations assigned the previously disclosed expert witnesses, some renumbering was necessary to correct inadvertent Frighumbering in our February 5, 2010 discovery letter. p HALLR 09/09/2010 6:09:47 Aly with the depth of the wounds to Mr. Wone’s chest. Dr- Goslinoski is also expected to testify that she observed several pre-mortem needle puncte: ‘marks to Mr. Wone’s tidy that do not appear io be the result of any medical treatment 98 intervention. Dr. Po mosk is expected to testify that none of the stab wounds ‘would have killed or cosrrandesed Mr, Wone unconscious immediately. Rather, unless incapacitated, Mr. Syone would have reacted instinctively 10 fend off physically aby attack and protect, Fiimselt, Dr. Goslinoski is expected to testify that she did pot observe any defensive wounds on Mr, Wone’s hands or forearms (i.e, no cuts, abrasions, lacerations, bruises, or similar markings of any kind indicative of @ physical struggle or of Mr. ores ving acted to defend himself from his attacker). Finally, Dr Gostinoski is, expeeted to testify that due to the significant internal bleeding resulting from the stab oie, and the presence of blood in Mir, Wone’s intestine, Mr. Wone wasalive for considerable period of time after being stabbed. c. Bases ofthe expert's opinion: The government previously supplied you with ‘he forensic repori(s) for Dx. Goslinoski, which included the basis for her expected texpert opinions (see PB-18), as well as the above summiyy of Dr. Goslinoski’s expected expert opinions and bases for those opinions, Dr. Goslinoski’s expert opinions are also based on her forensic examination ‘of Mr. Wone’s body, coupled orth her education, training, and experience inthe field of forensic examination. We also note that the entire defense tear has met with Dr. Goslinoski on at least two separate occasions for extended periods of time to discuss her autopsy report, findings, and bases for those findings in great detail (2) Mr.DougDeedriek. Mr. Deedrick jsatrace evidence examiner who formerly worked for MPD and now works as an independent contractor in the field of forensic examination, specializing in the analysis of trace evidence, As you know, Mr. Deedrick performed certain trace evidence examinations and analysis in this case. a. Qualificationsofexpert: The government previously supplied you with a copy =r the curriculum vitae for Mr, Deedrick (see P2433-2435). b. Summary of expected testimony, including expert opinion(s), that will be rendered by the expert: The government previously supplied you with the forensic reports issued by Mr. Deedrick, which included a summary of his expected testimony and expert opinions (see P 167-174, P2835-2839, 1P2967-2968, P3044). Among other things, and consistent with his reports, Mr, Deedrick would ‘estify that based on a microscopic comparison, it is his expert opinion that: the microscopic and optical properties of certain white cotton fibers found on tem 1S (the knife) are similar to the Known cotton fibers extracted from Item 16 (towel); although similar in microscopic Characteristies, the optical properties of the white cotton fibers found on Iter 13 (the knife) are slightly dissimilar to the known cotton fibers prepared from Item 17 (the HALLR 03/08/2010 6:09:47 AW vjetim’s shirt); none of the fibers found on ttem 13 (the knife) were similar to the daa otton fibers prepared from Item 17 (the vietim’'s shir) eroe™ synthetic fibers recovered from Item 34 (a shirt) were ‘microscopically like fibers prepared from Item 18 (the: ‘victim’s shorts); and the green synthetic fibers ‘recovered from Item 34 (ashirt) va ae vue onginated from Item 18 (he vietim’s shorts). In addition, consistent with fis reports, Mr. Deedrick may also be called to testify regarding the results of his wie veneopie comparison of certain head and pubic hair evidence recovered in this, erie reports supply the particulars of his opinions and bases for his opinions. c. Bases of the expert’s opinion: ‘The govemment previously supplied you with the forensic report(s) for Mr. Deedrick, which included the basis for his expected expert opinions (see P)67-174, P2835-2839, 'P2967-2968, P3044). Mr. Deedrick’s expert opinions are also based on his education, training, and experience in the field ‘of trace evidence examination and analysis. Mr. Deedrick is also engaged in some limited additional testing and analysis of certain trace svidence in this ease. If, upon completion, the government intends 19 rely on this work, we will promplly disclose any additional expert opinions and the basis for those opinions in a supplemental disclosure letter. () Mr. James Plant. James Plant is an expert in sadism and masochism (S and M) practices. As you know, Mr. Plant has viewed the § and M items collected in this case and opined Pp to the normal use and functioning of such items. a. Qualifications of expert: Mr. Plant does not have a curriculum vitae ftosociated with his status as an expert in S and M practices Rather, Mr. Plant’s expertise is based on his extensive personal and practical knowledge, experience, and training in S and M practices and the types of equipment, tools, and items used by vratviduals engaged in $ and M practices. Over the course of many 00% Mr. Plant has organized, lead, and participated in various gatherings of individuals interested in and engaged in S and M practices, including the uses of certain § and M equipment, eae and items by such individuals. These gatherings often include instructional component intended to reenforee to participants that S and M practices should be undertaken in “safe, sane, and consensual” manner, On various ‘occasions, Mr. Plant has provided instruction to individuals interested in Sand Mt practices. Mr. Plantalso frequently attends annual gatherings for those interested i) '$ and M practices and equipment, tools, and items used in $ and M practices, such as the annual gathering cau Memnational Mr. Leather and Mr. Mid-Atlantic Leather, Mr Plant has also ‘tended other S and M organizational meetings, such as “Masters and Slaves Together.” om: b. mary of expected test cluding expert opinion(s), that will be rendered by the expert: As previously diselosed, Mr. Plant is expected to testify about HALLR 03/09/2010 6.09.47 AN the intended and common use of certain S and M items by individuals engaged in S tnd M practices through reference to and consistent with the previously produced a vel list/description of S and M items recovered from 1509 Swann Street (with accompanying photographs) (sae P2974-3043). In addition, Mr. Plant may testify more generally about the nature of S and M practices, including the respective roles Of “tops and bottoms” and “masters and slaves,” as well as § and M practices cnvolving more than two individuals (c.g. threesomes, ete) Finally, Mr. Plant may ve be asked to opine on the nature and intended application of various S and M devices as seen being used by certain defendants in the photographs previously disclosed (see P195-216, P218). c. _Basesof the expert's opinion: Mr. Plant's expert opinions will be based on his extensive practical experience and instruction in S and M practices (4) Special Agent Steven Kopeck. SA Kopeck is an electronic forensics examiner with the United States Secret Service. As you know, SA Kopeck conducted forensic examinations on we cous electronic devices inthis case (c.g. desktop computers, laptop comPulerss electronic storage media). a oualfications of expert: The government previously supplied you with a copy “ofthe curriculum vitae for SA Kopeck (see P2436-2439). b. Summary of expected testimony, including expert opinion(s) that will be rendered by the expert: The government previously supplied you with the forensic repors issued by SA Kopeck, which included a summary of the expected testimony and expert opinions for SA Kopeck, as well as related documentat/0® (see PI210- D211, P1419-1471, P2464-2465). Jn summary, SA Kopeck is expected to testify as tothe methods and means that he used to recover, store, and search the electronic data contained on the various electronic devices and storage media referenced in his reports, c. _Basesofthe expert's opinion: The government previously supplied you with ‘he forcnsie report for SA Kopeck, which ineluded the basis for his expected expert opinions, as well as related documentation (see P1210-12 + P1419-1471, P2464- 365), SA Kopeck’s opinions are also based on his extensive training, and experience ait methods and means used to recover, store, and search electronic devices and storage media like those recovered in this ease. (5) Special Agent Scott Reed. SA Reed is an electronic forensics examiner with the United States Secret Service, As you know, SA Reed also conducted forensie examinations various ceatronie devices in this case (c.g. desktop computers, laptop computers, electronie storage media). a. Qualifications of expert: The government previously supplied you witha coPY HALLR 03/09/2010 6:09:47 AN of the curriculum vitae for SA Reed (see p2440-2441). b. Summary of expected tes cluding expert opinion(s), that will be rendered by theexpert: Although SA Reed did not himselfissue any forensic reports) res ease, he performed certain electronic forensics ‘examinations in this case and is imimately familiar with the recovery of the electronic data in this case by SA Kopeck as well as the methods and means SA Kopeck used to recover, store, and arreh the electronic data contained on various clectron'e devices and storage media Jn this case, as referenced in the USSS forensic reports (see P1210-1211, P1419-1471, 24642465). SA Reed is expected to testify consistent ‘with the referenced reports. cs Bases of the expert's ‘opinion: Although SA Reed did not himself issue any forensic reports in thiscase, the government previously ‘supplied you with the forensic reports related to the recovery of certain electronic data in this case, which also included the basis for SA Reed’s expected expert opinions, as ‘well as related documentation (see P1210-1211, 1419-1471). SA Reed’s opinions are also based on his extensive training and experience in the methods and means used to recover, store, and search electronic devices and storage media Tike those recovered in this case. (© Mr. Brendan Shea. Mr. Shea is 2 FBI DNA examiner. As you know, Mr. Shea conducted various DNA testing and examinations in this case a. Quilficationsofexpert: The government previously supplied you with a copy 2 he eurriculum vitae for Mr. Shea (see P1892-1897), 95 ‘well as his proficiency test summaries on CD (see P1849). b. Summary of expected testimony, including expert opinion(s)_ that will be rendered by the expert: The government previously supplied you with the FBI nai reporis issued by Mr. Shea, which included a swmuny of his expected testimony and expert opinions (see P157-164, P178-1 83, P1917-1922, P2092-2099, 2272. 2279), as well as related portions of the FBI “case file” (see generally P1845- 3428), As previously disclosed, Mr. Shea is expected 0 testify both generally about ae testing, analysis, and examination and specifically about the DNA testing, fnalysis, and examination that he conducted in this ease c. Bases of theexpert’s opinion: ‘The govemment previously supplied you with he FBI forens reports issued by Mr. Shea, which included ‘the basis for his expected expert opinions (see P157-164, P178-183, 'P1917-1922, P2092-2099, P2272-2279). Me, Shea's expert opinions are also based on his extensive ‘education, training, and experience in DNA testing, analysis, and examination (1) Ms. Leslie MeCurdy. Ms. MeCurdy is 2p FBI DNA examiner. As you know, Ms. 6 HALLR 08/09/2010 6:08:47 AN McCurdy conducted various DINA testing and examinations in this case, a. Qualifcationsofexpert! The government previously supplied you with a copy ofthe curriculum vitae for Ms. McCurdy (sex P2442-2446). b. Summary of expected testimony, including expert opinion(s) that will be rendered by the expert: The government previously supplied you with the FBI Ferensic report issued by Ms, MeCurdy, which included a summary of her expected testimony and expert opinions (see P175-177). Inaddition, Ms. McCurdy is expected to testify both generally about DNA testing, analysis, and examination ‘and specifically veat the DNA testing, analysis, and examination that she conducted in this ease g. _ Basesofthe expert’s opinion: The government previously supplied you with ‘he FBI forensic reports issued by Ms. McCurdy, which included the basis for this expert's expected expert opinions (see P175-177). Ms. MeCurdy's expos opin srslso based on her extensive education, training, and experience in DNA testing, analysis, and examination. (8) Ms. Tamyra Moretti, Ms. Moretti is an FBI DNA examiner. ‘As you know, Ms. Moretti conducted various DNA testing and examinations in this ease. a. Qualifications ofexpert: The goverment previously supplied you with a eoPy » the curriculum vitae for Ms. Moreti (sec P1898-1908), as well as her proficiency test summaries on CD (see P1849 and 2592). b. Summary of expected testimony, including expert opinion(s). that will be rendered by the expert: The government previously supplied you with the FBI forensic repor's issued by Ms. Moretti, which included a summary of her expected testimony and expert opinions (see P228-233,P1910-1916,P1927-1934, 2267-2271, 72280-2286, P2536-2547), us well as related portions of the FBI “case file” (see generally P1845-2428). As previously disclosed, Ms. Morett is. expected to testify both generally about DNA testing, analysis, and examination and specifically about the DNA testing, analysis, and examination that she conducted in this case. c. Basesof the expert's opinion: The govemment previously supplied you with the forensic reports for Ms. Moretti, which included the basis for her expected expert opinions (see P228-233, P1910-1916,P1927-1934, P2267-2271, 12280-2286, P2536- 3547), Ms, Morett’s expert opinions are also based on her extensive education, training, and experience in DNA testing, analysis, and examination. With respect to Ms. Moretti, we also note that the entire defense tear met swith her at the FBI and discussed her expert opinions and the bases for those opinions in great detail over the course of several hours. HALLR 03/08/2010 6:09:47 AN (9) Ms.Madeline Montgomery. Ms. Montgomety © © forensic chemist working at the FBI's Chemistry Unit, As youknow, she conducted some of the forensic chemistry examinations on items of evidence in this case. ‘a. Qualifications ofexpert: The government previously’ supplied you with @ copy othe curriculum vitae for Ms. Montgomery (see P1677-1681) b. Summary of expected testimony, including expert opinion(s) that will be rendered by the expert: The government previously supplied you with the forensic report for Ms. Montgomery, which included a summary ‘ofher expected testimony and expert opinions (see P165-166). As previously disclosed, Ms. Montgomery is expected to testify both generally bout forensic chemistry and specifically about the forensic chemistry examinations that she conducted in this case c. _ Basesofthe expert's opinion: ‘The government previously supplied you with ‘ye forensic reports for Ms. Montgomery, which included the basis for ber expected expert opinions (see P165-166). Ms. Montgomery's expert opinions are also based orrher extensive education, training, and experience in forensic chemistry (10) Mr, Robert Rooney. Mr, Rooney isa forensic chemist working 2 the FBI's Chemistry Unit. As you know, he conducted some of the forensic chemistry examinations on items of evidence in this case. a. Qualifications ofexpert: The government previously supplied you with a copy ‘of the curriculum vitae for Mr. Rooney (see P1693-1694) b. Summary of expected testimony, including expert opinion(s). that will be rendered by the expert: The government previously supplied you with the FBI Terensic report issued by Mr. Rooney, which included a summary of his expected testimony and expert opinions (see P186-187,P2705-2706). As previously disclosed, Ms. Rooney is expected to testify both generally about forensic chemistry and specifically about the forensic chemistry examinations that he conducted in this case. c._Bases ofthe expert's opinion: The government previously supplied you with the FBI forensic report issued by Mr. Rooney, which included the basis for his texpected expert opinions (sag P186-187). Mr. Rooney's expert opinions ie also treed on his extensive education, training, and experience in forensic chemistry (11) Mr. Jason Brewer. Mr. Brewer is a forensic chemist working at the FBI's Chemistry Unit. As you know, he conducted some of the forensic chemistry examinations on items of evidence in this case. a. Qualifications ofexpert: The government previously supplied you witha copy HALLR 09/09/2010 6:00:47 AN of the curriculum vitae for Mr. Brewer (see P1674-1676)- b. Summary of expected testimony, including expert opinion(s). that willbe rendered by the expert: The goverment previously supplied you ith the FBI forensic report issued by Mr. Brewer, which included a summery of his expected testimony and expert opinions (see P190-191, P2909-2910). Mr. Brewer's expected to testify both generally about forensic chemistry and specifically about the forensic chemistry examinations that he conducted in this case. c. Bases ofthe expert's opinion: The government previously supplied you with ‘he FBI forensic report issued by Mr. Brewer, which include the basi for his expected expert opinions (see P190-191). Mr. Brewer's expert opinions are also ‘based on his ‘extensive education, training, and experience in forensic chemistry. (12) Ms. Florine Allen. Ms. Allen is fingerprint examiner for MPD. ‘Asyouknow, Ms. ‘Allen performed some of the fingerprint examinations work in this case- a. Qualifications ofexpert: The government previously supplied you with a copy of the curriculum vitae for Ms. Allen (see P2447-2448). b, Summary of expected testimony, including expert opinion(s).that will be rendered by the expert: The government previously supplied you with the forensi¢ reports issued by Ms. Allen, which included a summary of her expected testimony and expert opinions (seg P145-149, P188-189, P1O88-90, P2548-2550, P2555, P2558, 2561-2562), as well as related portions of the MPD Fingerprint Examination Seetion’s file (see generally P2548-2582), As previously disclosed, Ms. Allen may testify generally concerning latent fingerprints, the recovery of latent prints (including fingerprints, extreme fingertip prints, and palm prints, the examination of prin, the categorization and analysis of prints, and, specifically, her examination, analysis, and findings concerning certain latent prints recovered in this case. c. Bases ofthe expert’s opinion: The goverument previously supplied you with the forensic reports issued by Ms. Allen, which include the basis for her expected texpert opinions (P145-149, P188-189, P1 088-90, P2548-2550, P2555, P2558, 12561. 3562), Ms. Allen's expert opinions are also based on her education, traning, and experience in fingerprint examination and analysis. (13) Ms, Shelly Rensink, Ms. Rensink is @ fingerprint examiner for the FBI. As you know, Ms, Rensink performed some of the fingerprint examinations work in this case a. Quulificationsofexpert: The government previously supplied you with a copy of the curriculum vitae for Ms. Rensink (see P1688-1692). HALLE 912010 6:09:47 AN b. Summary of expected testimony, including expert opinions) that wil be rendered by the expert: The govemument previously supplied you with the FBI forensic reports for Ms. Rensink, which included a summary of her expected testimony and expert opinions (see P184-185,. 1208-1209, P2732-2733, 3743-2744, 2752-2753), as well as related portions of the FBI “case file” (see generally P2732- 2809), As previously disclosed, Ms. Rensink may testify generally concerning latent fingerprints, the recovery of latent prints {including fingerprints, extreme fingertip prints, and palm prints), the examination ‘of prints, the categorization and analysis of Prints, and, specifically her examination, analysis, and findings concerting certain latent prints recovered in this case. Ms. Rensink may also testify about the integrity of latent prints over time, including the length of time that latent prints may remain fn tact on given objects and the factors that affect the length of time that latent prin's ‘will remain in tact on any given object. «Bases ofthe expert's opinion: The government previously supplied you with ‘se FBI forensic reports issued by Ms. Rensink, which included the basis for her texpected expert opinions (see P184-185, P1208-120, P2732-2753, P2738, P2743- Spud, P2747, P2752-2753, P27S9-2761, P2780). Ms. Rensink’s expert opinions are ares baged on her education, training, and experience in fingerprint examination and analysis. (14) Mr. Rory Doyle. Mr. Doyle is toxicologist for the District of Columbia, As you know, he conducted certain toxicology examinations on Mr. Wone's blood in tis case. a. Qualifications ofexpert: The government previously supplied you witha copy of the curriculum vitae for Mr. Doyle (see P2457-2463). b. Summary of expected testimony, including expert opinion(s) that will be rendered by the expert: The government previously supplied you witha toxicology’ report issued by Mr. Doyle, which included a suramary of his expected testimony and xpert opinions (see P19). Mr. Doyle is expected to testify both generally aboot Faerie toxicology and specifically about the forensic toxicological examinations that hhe conducted in this ease. «Bases ofthe expert's opinion: The government previously supplied you with « oxicology teport issued by Mr, Doyle, which include the basis for his expected expert opinions (see P19). Moreover, Mr. Doyle would base his expert opinions 00 his education, training, and experience in the field of toxicology and his interpretation of the toxicology tests performed on Mr. Wone’s blood. (15) _ Dr. Fiona Couper. Dr. Couperis a toxicologst forthe District of Columbia, Asyou know, she assisted in conducting certain toxicology examinations on Mr. Wone’s blood in this case, 10 HALLR 03/09/2010 6:09:47 AN a. Qualifications ofexpert: The government previously supplied you with a copy atthe curriculum vitae for Dr. Couper (see P2449-2456), b. Summary of expected \estimony, including expert opinion(s) tha will be rendered by the expest: The government previously supplied you with the toxicology report issued by Mr. Doyle and bearing Dr. Couper’sname. Thet report also included “ermnmary of the expected testimony and expert opinions for Dr. Couper (see P19), De Couper is expected to testify both generally about forensic toxicology and specifically about the forensic toxicological examinations that she conducted in this, case <. _ Basesofthe expert's opinion: The government previously supplied you with the toxicology report issued by Mr. Doyle and bearing Dr. Couper's mane. That report included the bass for Dr. Couper's expected expert opinions as well (see P19). Keecover, Dr. Couper would base her expert opinions on her education, training, and experience in the field of toxicology and her interpretation of the toxicology tests performed on Mr. Wone’s blood. (16) Mr. Robert P. Spalding. Mr. Spalding is blood splatter expert: a. Qualifications of expert: Upon further review, it does not appear that we previously supplied you with a copy of the curriculum vitae for this expert. ‘Accordingly, please see attached (P3070-3072). >, Summary of expected testimony, inclu ert opinion(s) rendered by the expert: The government previously supplied you with Mr. Spaulding’ s expert report, which included a summary of his expected testmouy and expert opinions (see P1167-1181, P1213-1241). As previously closed, Mr. Spalding will be called to testify in the field of blood pattern evidene® ‘We expect that Mr. Spalding will testify consistent with his report, as well as provide other expert opinions consistent with his examination of the evidence in this case (see below). c. Bases ofthe expert’s opinion: The government previously supplied you with Nir. Spaulding’s expert report, which include the basis for his expected exper opinions (sce P1167-1181, P1213-1241), Mr. Spaulding is also engaged in some limited additional testing and analysis of certain evidence in this ease. Tf, upon completion, the goverment intends to rely on this ‘work, we will prompily disclose any additional expert opinions and the basis for those opinions in a supplemental disclosure letter. (17) Dr. John Yo Dr. Yosaitis is a practicing anesthesiologist at Georgetown n HALLR 03/09/2010 6:09:47 AW Hospital in the District of Columbia. “lease see attached copy of the curriculum vitae for a, Qualifications of expert: Dr. Yosaitis (see P3073-3074). b. Summary of expected testimony including opinion(s) that willbe rendered the expert: As previously disclosed, Dr. Yosaits is expected to testify about the practice of anesthesiology, anesthetics generally, and the effects of anestheties on the aman body, Among other things, Dr. Yosaitis is expected to testify that anesthetics aarbe aumfaistered both via intravenous (IV) and via intramuscular (IM) injections. De Yosuitis will testify that certain commonly used anaesthetics, ‘like succinyolehotine, are not closely controlled in operating and emergency rooms (unl Xe hareotis) and are therefore casily accessible to those having access to said rooms. Dr Vasaitis vill testify that if administered via intramuscular injection, a dose of ucinyolcholine could render a person immobile in as little as thirty 30) sevonds Depending onthe dosage of succinyolcholine, analfected person would retain sensory pereeption and other bodily functions e.g. digestion), but would not be able fo move {he be temporarily paralyzed). Dr. Yosaitis would further testify thatthe component parts of suceynolcholine occur naturally in the body, and sueeynolehotine injected! inte rns human body quickly breaks down into its component parts and is metabolized, aking “injected” succinyolcholine impossible to detect in subsequent toxicology screens. c. Bases of the expert's opinion: Dr. Yosaitis will base his expert opinions on fis extensive educational background, training, and experience in the field of anesthesiology. (18) Dr. David Fowler. Dr. Fowler is a forensic pathologist, currently employed as the Chief Medveal Examiner forthe Office ofthe Chief Medical Examiner forthe State of Maryland. Dr. Fowler reviewed the autopsy report prepared by Dr. Goslinoski and related materials. ‘a. Qualifications ofexpert: ‘The government previously supplied you with a copy of the curriculum vitae for Dr. Fowler (see P3048-3067). b. Summary of expected testimony. including expert opinion(s) that will be rendered by the expert: Dr. Fowler is expected to testify about forensic pathology and his observations and conclusions ‘concerning the autopsy of Mr. Wone. Specifically, ‘and consistent with the autopsy report, Dr. Fowler is expected to testify that Ms. Wone died as a result of three stab wounds to his torso. Dr. Fowler is expected to testify that there were no defects in the stab wounds (i.¢., no drag marks, abrasions, oF ‘fish-taling”), Dr, Fowler is expected to testify thatthe stab wounds appear to have been caused by the same size knife, due tothe similarity of the three stab wounds. Dr. Fowler is also expected to testify that the knife found by the police on the bedside 12 HALLR 03/09/2010 6:09:47 AN table next to the bed in which Mr, Wone was lying is inconsistent with his stab table ds stead, in his experience, a knife blade that is four and one-half inches in Jength is more consistent with the depth of the wounds to Mr, Wone’s chest. Dr. Toner is also expected to testify that there are certain pre-mortem needle punclure venks to Mr, Wone’s body that are not consistent with medical treajmen’ 1 sanesvention. Dr, Fowler is expected to testify that none ofthe stab wounds would have immediately killed Mr. Wone or immediately rendered him unconseiod Rather, unless restrained orincapacitated, Mr. Wone would have reacted instinctively Titend off physically any attack and protec himself. Dr. Fowler is expected '0 testify that there do not appear to be any defensive wounds on Mr, Wone’s hands ot forearms (.e.,no cuts, abrasions, lacerations, bruises, or similar markings of any kind indicative ofa physical struggle or of Mr. Wone having acted to defend himself from his stacker), Finally, Dr. Fowler is expected to testify that due tothe significant internal bleeding resulting from the stab wounds, and the presence of blood in Mr. Wone’s intestine, Mr, Wone was alive for a period of time after being stabbed. ©. Bases of the expert’s opinion: Dr. Fowler’s expert opinions are based on his review of the autopsy report ‘and related materials, as well as his educational peckground, taining, and extensive experience in the field of forensic pathology (19) Mr. Lucas Zarwell. Mr. Zarwell isa toxicologist for the Distict of Columbia. As ‘you know, he assisted in conducting certain toxicology examinations on Mr, Wone’s blood in this case. a. Qualifications ofexpert: The government previously supplied you with a coPy ol the curriculum vitae for Mr. Zarwell (see P3068-3069) b. Summary of expected testimony, including expert opinion(s) that will be vendered by the expert: The government previously supplied you with a toxicology report issued by Mr. Doyle and bearing Dr. Couper’s name. That report also included trummary of certain expected testimony and expert opinions for Mr. Zarwel (see P19). An amended toxicology report issued by Mr. Zarwell is attached as well (See 3084), Mr, Zarwell is expected to testify both generally about forensie toxicology and specifically about the forensic toxicological examinations that he conducted in this case ¢. Bases ofthe expert's opinion: The government previously supplied you with « toxicology report issued by Mr. Doyle and bearing Dr. Couper's name. That report iaciuded the basis for Mr. Zarwell’s expected expert opinions as well (se P19) Moreover, Mr, Zarwell would base his expert opinions on his education training, and experience in the field of toxicology and bis interpretation of certain toxicology tess performed on Mr. Wone’s blood. 3 HALLR 0308/2010 6:09:47 AN (20) Ms. Maureen Walsh, Ms, Walsh isa retired MPD mobile crime lab technician. a. Qualifications of expert: Ms. Walsh does not have. a curriculum YR! 2 sociated with her stalusas an expert in the nature and processing of rime scenes iu. Walsh's expertise is based on her extensive knowledge, education, taint, and experience in processing crime scenes over the course of her 30+ year career with MD. During that time, Ms. Walsh received significant training inthe processiN of Toth nonviolent and violent erime scenes. As part of her work, she processed Poth mas of nonviolent and violent crimes scenes, including, but not limited to. saavent and nonviolent burglary scenes, as well as scenes that were the product of vorent struggles resulting in injury or death, such as shootings, stabbings, plndgeonings, ete. As art of her work, Ms. Walsh regularly observed the injte® of eerie of violent crimes. She also instructed other mobile crime lab technicians on the processing of nonviolent and violent crime scenes. b. Summary of expected testimony including opinion(s that will be rendered Ps theexpert: As crime seene evidence expert, Ms. Walsh will testify about the nature tae expt dence typically found on crime scenes that are the product of violent injuries erdeaths, including shootings, stabbings, bludgeonings, ete. Specifically, Ms Walsh fs expected to testify that based on her experience and training, the crime 2° {Tiseovered by the authorities inthis case was not consistent with that of violent stabbing erime scene (i.., lack of blood, blood splatter, blood spillage, blood trails, he undisturbed nature ofthe home, guest bedroom, and bed in which Mr. Wone wis found, the absence of any other evidence of a violent struggle or stabbing, ‘and the Absence of any other blood evidence of a violent struggle or stabbing), Ms Walsh is also expected to testify that based on her experience and training, the esime ASP “Tisvovered by the authorities inthis case was not consistent with that of an alleged Sntruder (eg, no evidence of unauthorized entry, the undisturbed nature of the home, quest bedroom, and bed in which Mr. Wone was found, no evidence that anything of aerue had been displaced or taken, despite there being various valuable items of personal property in plain sight throughout the home). Ms, Walsh is also expected to Testify that based on her experience and training, the stab wounds to Mr. Wone’s body eee onsisient with a violent struggle or, for that matter, any movement by Mi. Wone atthe time that he was stabbed. Ms. Walsh is also expected to testify that there iy no visible evidence on Mr. Wone’s body of any collateral stabbing injuries or XT Fensive wounds, consistent with what she has typically observed on stabbing cetfims over the course of her career. Finally, Ms. Walsh is also expected to testify that in her experience, knives used in violent crimes typically have blood all ovet them, ineluding on the knife blade and handle. In this case, however, the purported perder weapon discovered near Mr. Wone’s body did not appear to have blood on anything other than the knife blade itself. c. Bases of the expert's opin! Ms. Walsh's opinions are based on her 4 HALLR 08/09/2010 6:08:47 AW education, training, and extensive experience in processing nonviolent and violent ao acracones in general, and, in particular, crime scenes tha are the product of violent injuries and deaths, including shootings, stabbings, bludgeonings, In addition, Mae Walsh's opinions are based on her review of the MPD Mobile Crime Lb reports and photographs, the FBI crime scene reports and photographs, and the euiopsy photographs in this case. (21) Mr, Joseph Anderson. Mr. Andersonis aretired MPD mobile crime lab technician, a. Qualifications of expert: Mr. Anderson does not have a curriculum vitae sosociated with bis status as an expert in the nature and processing of crime scenes esther information conceming Mr. Anderson's qualifications as an expert in the nature and processing of crime scenes will be forthcoming shortly. b. Summary of expected testimony including opinion(s) that will be rendered by the expert’ As a crime scene evidence expert, Mr. Anderson will testify about the aaesearsf the evidence typically found on crime scenes that are the product of violent injuries and deaths, including shootings, stabbings, bludgeonings, ete Specifically, ree anderson is expected to testify that based on his experience and training, the erjme svene discovered by the authorities in this ease was not consistent with that of crViolent stabbing crime scene. Further information concerning Mr. Anderson’s expected expert opinions will be forthcoming shorty, c. _ Bases ofthe expert's opinion: Mr. Anderson's opinions will be based on bis Scjucation, training, and extensive experience in processing nonviolent and violent Grime scenes in general, and, in particular, crime scenes tha are the product of violent injuries and deaths, including shootings, stabbings, bludgeonings, tc. 1 addition, Ne Anderson's opinions will be based on his review of the MPD Mobile Crime Lab reports and photographs, the FBI crime scene reports and photographs, and the autopsy photographs in this case. (22) Mr. Dave Sergeant. Mr, Sergeant is a retired MPD mobile crime Jab technician. a. Qualifications of expert: Mr. Anderson does not have a curriculum vitae stssociated with his status as an expert in the nature and processing of crime scenes Me Sergeant's expertise is based on hisextensive knowledge, education, taining, and experience in processing crime scenes over the course of his 30+ year career with MPD. During that time, Mr. Sergeant received significant training in the processing tf both nonviolent and violent crime scenes, As part of his work, he processed thundveds of nonviolent and violent crimes scenes, including, but not limited to, violent and nonviolent burglary scenes, as well as scenes that were the product of Violent struggles resulting in injury or death, such as shootings, stabbings, bludgeonings, etc. As part of his work, Mr, Sergeant regularly observed the injuries 15 HALLR 05/08/2010 6:09:47 AN of victims of violent crimes. He also instructed other mobile crime Jab technicians on the processing of nonviolent and violent erime scenes. b. Summary of expected testimony including opinion(s) that will rendered by the expert: As a crime scene evidence expert, Mr. Sergeant will testify about the ature of the evidence typically found on crime scenes that are the prodvet of violent injuries and deaths, including shootings, stabbings, bludgeonings, el Specifically, Mr. Sergeant is expected to testify that based on is experience and training, the crime ware liscovered by the authorities in this case was not consistent with thal of ¢ ccsent stabbing erime scene (ie, lack of blood, blood splatter, blood spillage, blood Wai the undisturbed nature ofthe home, guest bedroom, and bed in which Mr. Wone wri ound, the absence of any other evidence ofa violent struggle orstabbing, andthe vpasnee of any other blood evidence ofa violent struggle or stabbing). Mr. Sergeant is also expected to testify that based on his experience and training, the crime see ae are by the authorities in this case was not consistent with that of an alleged sender (e.B, no evidence of unauthorized entry, the undisturbed nature of the home. guest bedroom, and bed in which Mr. Wone was found, no evidence that anything of aie had been displaced or taken, despite there being various valuable items of personal property in plain sight throughout the home). Mr, Sergeant is a0 expected tp testify that based on his experience and training, the stab wounds to Mr Wone’s body are inconsistent with a violent struggle or, for that matter, any movement byMr. Mote atthe time that he was stabbed. Mr. Sergeant is also expected to testify that there is no visible evidence on Mr. Wone’s body of any collateral stabbing injuries or defensive wounds, consistent with what he has typically observed on stabbing victims cver the course of his career. Finally, Mr. Sergeant is also expected to testify that in his experience, knives used in violent crimes typically have blood all over therm I ng on the knife blade and handle. In this case, however, the purported murder ‘weapon discovered near Mr, Wone’s body did not appear to have blood on anything other than the knife blade itself. c. _Bases of the expert's opinion: Mr. Sergeant’s opinions are based on his cucation, training, and extensive experience in processing nonviolent and violent rime scones in general, and, in particular, crime scenes that are the product of violent injuries and deaths, including shootings, stabbings, bludgeonings, ele. 1h addition, Mz. Sergeant's opinions are based on his review of the MPD Mobile Crime 1b reports and photographs, the FBI crime scene reports and photographs, and the autopsy photographs in this case. 3) Mr. Harold Deadman, Mr, Deadman isa forensic examiner for MPD. As you know, Mr. Deadman performed certain trace evidence analysis and examinations in this case. a. Qualifications of expert: Please see attached copy ofthe curriculum vitae for Mr, Deadman (see P3075-3082). 16 HALLR 03/09/2010 6:09:47 AW vb. Summary of expected testimony, including expert opinion(s) th st will be rendered by the expert: The government previously supplied you the forensi report issued by Mr. Deadman, which included a summary of his expected testimony acl expert opinions (seeP3045-3047), Mr. Deedrick would testify consistent with his report. c. Bases ofthe expert's opinion: The government previously supplied you with ‘he forensic report issued by Mr. Deedrick, which included the basis for his expected cxpert opinions (see P3045-3047). Mr. Deedrick’s expert opinions are also based on Fo education, training, and experience inthe field of forensic evidence examination, particularly trace evidence examination and analysis. (24) Ms. Maureen Bradley. Ms. Bradley is a forensic chemist working at the FBI's Chemistry Unit. As you know, she conducted some of the forensic chemistry ‘examinations on items of evidence in this case. a. Qualifications ofexpert: The government previously supplied you with a copy or ihe curriculum vitae for Ms. Bradley (see P1682-1685, P2904-2907). b. Summary of expected testimony. including expert opinion(s). that will be rendered by the expert; ‘The government previously supplied you with the forensic report issued by Ms. Bradley, which included a summary of her expected testimony find expert opinions (see P342-343, P2873-2874). As previously disclosed, Ms. Bradley is expected to testify both generally about forensic chemistry and specifically about the forensic chemistry examinations that she conducted in this case. c. _ Bases ofthe expert's opinion: The government previously supplied you with the forensic report issued by Ms. Bradley, which included the basis for het expected expert opinions (see P P342-343, P2873-2874). Ms. Bradley's expert opinions are leo based on her extensive education, training, and experience in forensic chemistry. 5) Mr. Vanessa Thai, Ms. Thai isa forensic biologist with the PBI. As you know from the FBI“case file” and your interview of Ms. Thai, she conducted various testing and examinations in this case, including certain serological examinations related to Ms. Moretti's ‘work, a. Qualifications of expert: The goverment previously provided Ms. Thai's Siatement of Qualifications as well as her proficiency test summaries on CD (See P2592). b. Summary of expected testimony, including expert opinion(s). that will be sed by the expert: The government previously supplied you with the forensic "7 HALLR 03/09/2010 6:09:47 AN reports for Ms. Thai, which included a summary of her expected testimony and expert Opinions (see P1954-1957, P1959-1961, P2308). Ms. Thai is expected to testify both generally about serological testing, analysis, and examination and specifically about the serological testing, analysis, and examination that she conducted in this case c. Bases ofthe expert's opinion: The government previously supplied you with the forensic reports for Ms. Thai, which included the basis for her expected expert opinions (see P1954-1957, P1959-1961, P2308). Ms. Thai’s expert opinions are also based on her education, training, and experience in biology and serological testing, analysis, and examination, ‘As you know, the entire defense team met with Ms, Thai at the FBI and discussed her expert opinions and the bases for those opinions in great detail over the course of several hours. (26) Mr. Jeffrey Gray. Mr. Gray is a Visual Information Specialist with the FBI's Forensies Science Support Section, Special Projects Section. In that capacity, Mr. Gray builds “to scale” three-dimensional exhibits for use at trial. 4. Qualifications of expert: Please see attached copy of the curriculum vitae for Mr. Gray (see P3083). b. Summary of expected testimony, including expert opinion(s), that will be rendered by the expert: Mr. Gray is inthe process of building a “to scale” model of the townhouse located at 1509 Swann Street, N.W., as it existed on August 2, 2006, for possible use by the government as an exhibit at trial. Should the government ‘choose to use the model at trial, the government will make the model available to you for viewing before trial, as well as invite you to ask attending FBI personnel involved in its construction any questions you have regarding it. A\ trial, Mr. Gray would testify that the model he built of 1509 Swann Street, N.W. is to seale and consistent with the actual structure as it existed on August 2, 2006, c. Bases of the expert's opinion: In order to construct the model, Mr. Gray has visited 1509 Swann Street, N.W. on multiple occasions, studied various architectural drawings and measurements of the home, took independent measurements of the home, studied crime scene photographs taken by the MPD and the FBI, studied crime scene diagrams created by the MPD and the FBI, and consulted with the current owner, Mr, Gray's construction of the model of 1509 Swann Street, N.W., will be based on his education, training, and experience in the construction of similar models. (27) Mr. Roman Karas. Mr. Karasis a toxicologist for the FBI. As you know, Mr. Karas 18 HALLR 03/09/2010 6:09:47 AN conducted certain toxicology examinations on Mr. Wone’s blood in connection with this case.? a. Qualifications of expert: The government previously supplied you with a copy of the curriculum vitae for Mr. Karas (sec P1685-1687). rendered by the expert: The government previously supplied you with the forensic report for Mr. Karas, which included a summary of his expected testimony and expert opinions (see P2594-2595, P2598-2599), as well as related portions of the FBI “case file” (see generally P2605-2702). Mr. Karas is expected to testify generally about the seience of forensic toxicology and specifically about the work he performed in this case, consistent with his report and the related documentation in the FBI “case file.” In addition, Mr. Karas is expected to testify that he is familiar with certain commonly used anaesthetics, like succinyoleholine, and is aware that suceinyolcholine can be injected into the human body. He is expected to testify that because the component parts of suceynolcholine occur naturally in the body and succynolcholine is ‘metabolized very quickly by the human body, both standard and focused toxicology sereens are unable o detect the presence of stccinyolcholine in the human body. Mr. Karas is expected to testify that if Mr. Wone had been injected with suecinyolcholine, standard and focused toxicology screens would not have detected the presence of the succinyolcholine in his blood. Accordingly, performing an such testing on Mr, Wone’s blood would not be probative in that the results would not indicate whether or not Mr. Wone had been injected with succinyolcholine. c. Bases ofthe expert's opinion: The government previously supplied you with the forensic report for Mr. Karas, which included the basis for his expected expert “opinions (see P2594-2595, P2598-2599), as well as related portions of the FBI “case file” (see generally P2605-2702). Ms. Karas” expert opinions are also based on his extensive education, training, and experience in forensic toxicology. (28) Ms. Emily Hawkins, Ms. Hawkins isa forensic biologist with the FBI As indicated in the FBI “case file,” she conducted some limited testing and examinations in this case, including certain serological examinations related to Ms. Moretti’s work. a. Qualifications of expert Although Ms. Hawkins’ serology report was > We initially identified Mr. Roman Karas as @ potential expert witness in the field of toxicology in our February 5, 2010 discovery letter, having previously disclosed his name, field of expertise, accompanying report in this case, and curriculum vitae (see February 5, 2010, discovery letter at pages 3-4). In our February 5, 2010 discovery letter, we identified Mr. Karas ‘as expert witness number “(16)” in our seminal paragraph, but subsequently overlooked him in again summarizing his expected opinions. For the sake of clarity, we have redesignated Mr. Karas as expert witness number “(23)” and will refer to him as such going forward. 19 HALLR 09/09/2010 6:09:47 At previously provided as part of the FBI “ease file,” we do not have @ copy of Ms. Fiewkins® Statement of Qualifications or her proficiency test summaries. We have requested these from the FBI and will disclose them upon receipt. b &§ £ expected testimony, including expert opinjon(s), that will be rendered by the expert: The government previously supplied you with the forensic reports for Ms. Hawkins, which included a summary of her expected testimony and Cxpert opinions (see P2306). Ms. Hawkins is expected to testify both generally about Serological testing, analysis, and examination and specifically about the serological testing, analysis, and examination that she conducted in this case. c. Bases ofthe expert's opinion: The government previously supplied you with the forensic reports for Ms. Hawkins, which included the basis for her expected expert opinions (see P2306). Ms. Hawkins’ expert opinions are also based on her education, training, and experience in biology and serological testing, analysis, and examination @9) Mr, Michael Rousseve. Mr. Rousseve is a forensic biologist with the FBI. As indicated in the FBI “case file, ” Mr. Rousseve conducted various testing and examinations in this case, including certain serological examinations related to Mr. Shea’s work. a. Qualifications ofexpert: The government previously provided Mr. Rousseve's Statement of Qualifications as well as his proficiency test ‘summaries on CD (see P1845). b. Summary of expected testimony, including expert opinion(s). that will be rendered by the expert: The government previously supplied you with the forensic reports for Mr. Rousseve, which included a summary of his expected testimony and expert opinions (see P21 16-2139). Mr. Rousseve is expected to testify both generally bout serological testing, analysis, and examination and specifically about the serological testing, analysis, and examination that he conducted in this case. c. Bases of the expert's opinion: The government previously supplied you with the forensic reports for Mr. Rousseve, which included the basis for his expected expert opinions (see P2116-2139). Mr. Rousseve's expert opinions are also based on his ‘education, training, and experience in biology and serological testing, analysis, and examination. (30) Candice Larry. Ms. Larry isa forensic biologist with the FBI. As indicated in the FBI“case file,” Ms. Larry conducted various testing and examinations in this case, including certain, serological examinations related to Mr. Shea's work. 2. Qualifications of expert: The government previously provided Ms. Larry's Statement of Qualifications as well as her proficiency test summaries on CD (see 20 HALLR 03/08/2010 6:08:47 AN P1845). b. Summary of expected testimony, including expert opinion(s). that will be rendered by the expert: The government previously supplied you with the forensic reports for Ms. Larry, which included a summary of her expected testimony and expert opinions (see P2183-2193, P2196). Ms. Lamy is expected to testify both generally st serological testing, analysis, and examination and specifically about the serological testing, analysis, and examination that she conducted in this ease c. _ Bases ofthe expert’s opinion: The government previously supplied you with the forensie reports for Ms. Larry, which included the basis for her expected expert opinions (sce P2183-2193, P2196). Ms. Thai's expert opinions ae also based on her ca mation, training, and experience in biology and serological testing, analysis, and examination, (1) Jeremy Fletcher. Mr. Fletcher is a forensie biologist with the FBI. As indicated in the FBI “case file,” Mr. Fletcher conducted various testing and examinations in this case, including, certain serological examinations related to Mr. Shea's work. a. Qualifications of expert The government previously provided Mr. Fletcher's Statement of Qualifications as well as his proficiency test summaries on CD (see P1845 and 2592). b. Summary of expected testimony, including expert-opinion(s), that will be rendered by the expert: The government previously supplied you with the forensi¢ Feporls for Mr. Fletcher, which included a summary of his expected testimony and tepert opinions (see P2194-2195). Mr. Fletcher is expected 1o testify both generally Shout serological testing, analysis, and examination and specifically about the serological testing, analysis, and examination that he conducted in this case c. Bases ofthe expert's opinion: The government previously supplied you with the forensic reports for Mr. Fletcher, which included the basis for his expected expert opinions (see P2194-2195). Mr. Fletcher's expert opinions ate also based On his cancation, training, and experience in biology and serological testing, analysis, and ‘examination. Finally, please note that as identified in the FBI “case file,” various FBIPCR/STR technicians extracted, injected, and/or amplified suspected DNA material in connection with the DNA work performed in this case by the DNA examiners (see, ¢.2., Alice L. Brown at P1952-1967). We have pot specifically identified these individuals as expert witnesses because its our position that Hey 2 Tact witnesses who simply performed standardized functions in the processing of DNA evidence at the FBI Laboratory based on the FBI Laboratory’s Quality Assurance ‘Standards, These standardized functions were performed in the normal course of processing the DNA evidence at the FBI Laboratory a and do not involve expert DNA analysis, comparison, or interpretation. Indeed, the government will ‘seek to elicit all expert opinions concerning the DNA analysis, comparison, or interpretation of the DNA evidence in this case from the two DNA examiners-Mr, Shea and Ms. Moretti. For that reason, the government does not intend to call these technicians as witnesses at trial, If however, you believe that the government is required to introduce their factual testimony at trial in advance of eliciting the expert opinions of the DNA examiners, please advise us of that immediately so that we may ask the Court to address the issue, as appropriate.* For your ease of reference, and as identified in the FBI “case file,” the following FBI technicians extracted, injected, and/or amplified suspected DNA ‘material in connection with the DNA work performed in this case: Ms. Alice Brown (sce P1845, P2592, P1962-1968, 1972-1973, P2045-2047, P2322, P2324, P2388; sce generally P1845-2428). Ms, Lori Flanagan (see P1845, P2592, P2050-2051, P2203; see generally P1845-2428). Ms, Julia Pugh (see P1845, P2592, P2140, P2310; see generally P1845-2428). Ms. Robyn Wolff (see P1845, P2592, P2143, P2204; see generally 1845-2428). Ms. Amber Carr (see P1845, P2592, P2197; see generally P1845-2428). Ms. Leah Willis (see P1845, P2592, P2317; see generally 1845-2428), * The government acknowledges that these individuals are part of the “chain-of-custody” for any items of DNA evidence that they helped process. That said, because testimony by such witnesses would be offered for the limited purpose of establishing the intermediate links in the “

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