Court Filing
EXHIBIT S-1: STATE'S SUPPLEMENTAL RESPONSE TO REQUEST FOR DISCOVERY REGARDING PENALTY PHASE EXPERTS Veena Singh Please note, additions to the expert disclosure filed on December 18, 2024, are italicized below. The State has disclosed Veena Singh, Spokane County Chief Medical Examiner and Forensic Pathologist in this Supplemental Discovery Response. It is anticipated that the State will call Dr. Singh to testify as an expert regarding the autopsies performed at Spokane County Medical Examiner's Office on November 16, 2022, on the following individuals: Ethan Chapin; Kaylee Goncalves; Xana Kernodle; and Madison Mogen. This response serves to supplement the information in the Autopsy Reports for Ethan Chapin, Kaylee Goncalves, Xana Kernodle, and Madison Mogen attached as Exhibits S-1 (a) - (d), photographs and / or video, and related reports as previously discovered to defense. The below is a summary of Dr. Singh's anticipated testimony but does not repeat all specific findings that are detailed in her reports. Based on Dr. Singh's education, training, and experience as a Chief Medical Examiner and a Forensic Pathologist, Dr. Singh will testify to performing postmortem examinations on Ethan Chapin, Kaylee Goncalves, Xana Kernodle, and Madison Mogen. It is expected Dr. Singh will testify that Kaylee Goncalves, Xana Kernodle, and Madison Mogen endured a high degree of pain and / or suffering prior to their deaths as a result of the injuries inflicted. It is expected Dr. Singh will testify Ethan Chapin also experienced a high degree of pain and / or suffering prior to his death as a result of the injuries inflicted but to a lesser degree than the other decedents. State's Exhibit exhibitsticker.com EXHIBIT S-1 Veena Singh 1 S-1 CR01-24-31665 Dr. Singh will testify regarding chain of custody, observations, examinations, evidence collected, tests performed, and cause of death. It is Dr. Singh's expert opinion that Ethan Chapin's cause of death is multiple sharp force injuries. Dr. Singh's postmortem examination showed a well-developed adult male with stab and incised wounds of the scalp, face, and neck; a stab wound of the upper chest; incised wounds of the upper extremities; stab and incised wounds of the lower extremities; associated injuries to include perforations of the jugular vein, subclavian vein, and subclavian artery. Dr. Singh will testify there was no evidence of natural disease that would have contributed to Chapin's death. Postmortem toxicology showed Chapin had a blood alcohol concentration of 0.122 g / 100 mL and an amphetamine level of 260 ng / ML. In addition, Dr. Singh will provide testimony regarding evidence that the knife used on Chapin showed indications that there was a blade guard. Dr. Singh will provide her opinion that Chapin's wounds are consistent with a single-edged knife as the source of the wounds. Dr. Singh will provide her opinion that the use of a Ka-Bar Full Size US Marine Corps Fighting Knife is consistent with the injuries observed. It is Dr. Singh's expert opinion that Kaylee Goncalves ' cause of death is multiple sharp force injuries. In addition, blunt force injuries of the head and asphyxial injuries are a significant contributor to her death. Dr. Singh's postmortem examination showed a welldeveloped adult female with stab and incised wounds of the scalp, face and neck; stab and incised wounds of the chest; and stab and incised wounds of the upper extremities. Associated injuries include punctures of the outer table of the skull; injuries to the teeth and tongue; perforations of the subclavian artery and vein; and hemorrhage into the chest cavities. Dr. Singh observed blunt force injuries including scalp laceration, bleeding EXHIBIT S-1 Veena Singh 2 around the brain, and nasal fracture, as well as scrapes on the nose and cheeks, bruising around the eyes, and patterned bruises extending across the lower face. Dr. Singh will testify that an unidentified object was pressed across Goncalves ' mouth. Dr. Singh observed petechial hemorrhages in the eyes and mouth. Dr. Singh will testify there was no evidence of natural disease that would have caused or contributed to Goncalves ' death. Postmortem toxicology showed Goncalves had a blood alcohol concentration of 0.107 g / 100 mL. Dr. Singh will provide her opinion that Goncalves ' wounds are consistent with a single-edged and / or double-edged knife being the source of the wounds. Dr. Singh will provide her opinion that the use of a Ka-Bar Full Size US Marine Corps Fighting Knife is consistent with the injuries observed. It is Dr. Singh's expert opinion that Xana Kernodle's cause of death is multiple sharp force injuries. Dr. Singh's postmortem examination showed a well-developed adult female with stab and incised wounds of the scalp, face, and neck; stab wounds of the chest and abdomen; incised puncture wounds of the back; incised wounds of the upper extremities; and incised wounds of the lower extremities. Dr. Singh also observed associated injuries including punctures of the outer table of the skull; perforations of the jugular vein, heart, lung, and pulmonary blood vessels; hemorrhage into the chest cavities; and wounds extending into the bones of the hand. Dr. Singh will testify that some of the injuries sustained are defensive injuries. In addition, Kernodle's injuries included scrapes and bruises on the face, torso, and extremities. There was no evidence that natural disease would have caused or contributed to Kernodle's death. Postmortem toxicology showed Kernodle had a blood alcohol concentration of 0.229 g / 100 mL and an amphetamine level of 12 ng / ML. Dr. Singh will provide her opinion that Kernodle's wounds are consistent EXHIBIT S-1 Veena Singh 3 with a single-edged and / or double-edged knife being the source of the wounds. In addition, the handle and / or tip of the knife could account for the appearance of serration on some of Kernodle's face wounds. Dr. Singh will opine that this serration could be caused by Kernodle fighting and / or holding / touching the knife and / or hand that is holding the knife causing the injury. Dr. Singh will provide her opinion that the use of a Ka-Bar Full Size US Marine Corps Fighting Knife is consistent with the injuries observed. It is Dr. Singh's expert opinion that Madison Mogen's cause of death is multiple sharp force injuries. Dr. Singh's postmortem examination showed a well-developed adult female with stab and incised wound of the scalp, face, and neck; stab wounds of the chest; and incised wounds of the upper extremities. Dr. Singh also observed associated injuries including wounds of the lung and liver as well as perforations of the subclavian vein, subclavian artery, and blood vessels of the chest wall. There was no evidence of natural disease that would have caused or contributed to Mogen's death. Postmortem toxicology testing showed Mogen had a blood alcohol concentration of 0.282 g / 100 mL. Dr. Singh will provide her opinion that Mogen's wounds are consistent with a single-edged knife as the source of the wounds. Dr. Singh will provide her opinion that the use of a Ka-Bar Full Size US Marine Corps Fighting Knife is consistent with the injuries observed. Dr. Singh will testify that a single large blade (single or double-edged) knife could be responsible for all wounds observed on Chapin, Goncalves, Kernodle, and Mogen. Dr. Singh's opinion / testimony will be based on her experience, education, and trainings as detailed in his curriculum vitae which is included with this response as Exhibit S-1 (e). EXHIBIT S-1 Veena Singh 4 Spokane County WASHINGTON OFFICE OF THE MEDICAL EXAMINER CHIEF MEDICAL EXAMINER VEENA D. SINGH, MD, MPH FORENSIC PATHOLOGIST DEPUTY MEDICAL EXAMINER DEPUTY MEDICAL EXAMINER SEAN RICCIARDO, MD MAKINZIE MOTT, MD FORENSIC PATHOLOGIST FORENSIC PATHOLOGIST AUTOPSY REPORT AUTOPSY NO: 221114-506 NAME OF DECEDENT: CHAPIN, ETHAN J. DATE OF BIRTH: 10/29/2002 SEX: MALE DATE PRONOUNCED / FOUND: 11/13/2022 DATE OF AUTOPSY: 11/16/2022 @ 8:00 AM LOCATION: SPOKANE COUNTY MEDICAL EXAMINER; SPOKANE, WA. RESPONSIBLE PARTY: CATHERINE MABBUTT, LATAH COUNTY CORONER PROSECTOR: VEENA D. SINGH, M.D., Μ.Ρ.Η. ASS'T PROSECTOR: KATIE SKIBITSKI / KATE SIRE / HEATHER ACRES NOTICE: THIS REPORT IS CONFIDENTIAL IN THE STATE OF WASHINGTON You are being given this report because you are named in the statute below as being authorized to have a copy of the autopsy or postmortem report, either of which may include other reports and records. These are highly confidential documents! You may not give or show any of these documents to anyone except as authorized by law. RCW 68.50.105Autopsies, postmortems-Reports and records confidential-Exceptions. (Effective January 1, 2014.) (1) Reports and records of autopsies or postmortems shall be confidential, except that the following persons may examine and obtain copies of any such report or record: The personal representative of the decedent as defined in RCW11.02.005, any family member, the attending physician or advanced registered nurse practitioner, the prosecuting attorney or law enforcement agencies having jurisdiction, public health officials, the department of labor and industries in cases in which it has an interest under RCW 68.50.103, or the secretary of the department of social and health services or his or her designee in cases being reviewed under RCW74.13.640. (2) (a) Notwithstanding the restrictions contained in this section regarding the dissemination of records and reports of autopsies or postmortems, nor the exemptions referenced under RCW42.56.240 (1), nothing in this chapter prohibits a coroner, medical examiner, or his or her designee, from publicly discussing his or her findings as to any death subject to the jurisdiction of his or her office where actions of a law enforcement officer or corrections officer have been determined to be a proximate cause of the death, except as provided in (b) of this subsection. (b) A coroner, medical examiner, or his or her designee may not publicly discuss his or her findings outside of formal court or inquest proceedings if there is a pending or active criminal or civil action, concerning a death that has commenced prior to January 1, 2014. (3) The coroner, the medical examiner, or the attending physician shall, upon request, meet with the family of the decedent to discuss the findings of the autopsy or postmortem. For purposes of this selection, the term " family " means the surviving spouse, state registered domestic partner, or any child, parent, grandparent, grandchild, brother, or sister of the decedent, or any person who was guardian of the decedent at the time of death. [2013 c 295 § 1: 2011 c 61 § 1. Prior: 2007 c 439 § 1; 2007 c 156 § 23; 1987 c 331 § 58; 1985 c 300 § 1; 1977 c 79 § 2; 1953 c 188 § 9. Formerly RCW 68.08.105] CIATION OF MEDIK OLVE NA Website: https://www.spokanecounty.org/807/Medical-Examiner 102 S. Spokane St. Spokane, Washington 99202 (509) 477-2296 FAX: (509) 455-3954 Email: medexam@spokanecounty.org State's Exhibit exhibitsticker.com 000001 S-1 (a) CR01-24-31665 AUTOPSY NO: 221114-506 DECEASED: CHAPIN, ETHAN J. Page 2 SUMMARY OF CASE FINDINGS I. Multiple sharp force injuries II. Toxicology: See separate report OPINION: Investigative reports indicate that this 20 year old male, Ethan Chapin, was found deceased at his girlfriend's shared home. Three other occupants of the home were also found deceased. Postmortem examination showed a well-developed adult male with stab and incised wounds of the scalp, face, and neck (4); a stab wound of the upper chest (1); incised wounds of the upper extremities (6); and stab and incised wounds of the lower extremities (6). Associated injuries included perforations of the jugular vein, subclavian vein, and subclavian artery. There was no evidence of natural disease that would have caused or contributed to death. Postmortem toxicology testing showed a blood alcohol concentration of 0.122 g / 100 mL and an amphetamine level of 260 ng / mL. The cause of death is multiple sharp force injuries. 12/15/2022 Veena D. Singh, M.D., M.Ρ.Η. (date signed) Forensic Pathologist VDS / skb 000002 AUTOPSY NO: 221114-506 DECEASED: CHAPIN, ETHAN J. Page 3 BACKGROUND INFORMATION: Briefly, this 20-year-old male was found deceased at his girlfriend's home. Three other occupants of the home were also found deceased. The Latah County Coroner's Office requested an autopsy to further investigate the death. INITIAL OBSERVATIONS: The body is found supine in a body bag sealed by tag number " 0773078. " The name " Ethan Chapin " and the tag number are written on a piece of blue tape affixed to the outside of the body bag. A piece of green tape bears the medicolegal case number and a notation indicating the body has been x-rayed. An identification band bearing the decedent's name, dates of birth and death, and tag number encircles the right ankle. An identification band bearing the decedent's first name and last initial encircles the left ankle. EXTERNAL EVIDENCE OF MEDICAL INTERVENTION: None. CLOTHING AND PERSONAL EFFECTS: The body is received clad in a pair of white athletic style socks. A brown paper bag is secured over each hand by means of silver duct tape. Jewelry includes a white metal pendant on a black cord around the neck and a black bracelet on the left wrist. EXTERNAL EXAMINATION: The body is that of a well-developed, well-nourished, adult lightcomplected male who weighs 228 pounds (as received), measures approximately 75 inches in length, and appears compatible with the reported age. The body has been refrigerated and is cool to the touch. Rigor mortis is receding in the muscles of the jaw and extremities. Fixed dark pink livor mortis is present over the posterior and right-sided surfaces of the body, except in areas exposed to pressure. When first viewed, blood is caked over the neck and in the left ear, and dried in smears and rivulets over the face, chest, and arms. HEAD AND NECK The scalp hair is brown, wavy, and measures up to approximately 5 inches in length over the crown. The irides appear hazel. The corneas are translucent. The sclerae are white and the conjunctivae are clear. No petechial hemorrhages are identified on the sclerae, conjunctivae, facial skin, or oral mucosa. The nose and ears are normally formed. The anterior teeth are natural and in good condition. Facial hair includes a trimmed mustache and long stubble in the beard distribution. The neck is symmetrical, without masses. The trachea is midline. THORAX AND ABDOMEN The thorax is well developed and symmetrical. The chest is slightly concave. The abdomen is flat. The surface of the back is free of lesions. The external genitalia are those of a normal adult male. The penis is circumcised. On the right shaft of the penis is an approximately 1/8 inch, bloodless area of skin erosion. EXTREMITIES The upper and lower extremities are well developed and symmetrical, without absence of digits. The fingernails are short, with smooth edges. The toenails range from short to medium length and are somewhat irregularly trimmed. 000003 AUTOPSY NO: 221114-506 DECEASED: CHAPIN, ETHAN J. Page 4 IDENTIFYING MARKS AND SCARS Scars include an approximately 1/4 inch diameter, circular, hypopigmented scar on the upper right chest. EVIDENCE OF INJURY: (NOTE: The wounds are described in an arbitrary order which does not imply sequence or severity. Wound tracks are described for a body at rest in the anatomic position.) STAB AND INCISED WOUNDS OF HEAD AND NECK (4) (1) Entrance: On the right parietal scalp, above the right ear, is an approximately 1-1 / 2 x 1/4 inch, linear stab wound oriented from 7 o'clock to 1 o'clock. The 7 o'clock end is squared and the 1 o'clock end is sharp. Discontinuous, 1/16 inch red marginal abrasion is present. An approximately 1-1 / 2 x up to 1/2 inch, triangular, abraded red contusion is present at the posterior and superior margins of the wound, widest superiorly. At the 7 o'clock end, a 1/8 inch laceration extends inferiorly from the anterior corner of the wound. Path: The hemorrhagic wound track travels along the skull, involving the scalp, subcutaneous tissue, temporalis muscle, and temporoparietal galea. Associated findings: There is moderate associated subscalpular, subgaleal, and temporalis muscle hemorrhage. There is a thin film of blood in the subdural space, overlying the left cerebral convexity. Depth and direction: The wound track travels from the decedent's back to front and downward, to a depth of approximately 7 inches. (2) Entrance: On the left parietal scalp, above and behind the left ear, is an approximately 2 x 3/16 inch, curvilinear incised wound with undermining extending anteriorly and 1/16 inch, red marginal abrasion. Path: The hemorrhagic wound track travels along the skull, involving the scalp, subcutaneous tissue, and left temporalis muscle. Associated findings: There is moderate associated subscalpular, subgaleal, and temporalis muscle hemorrhage. There is a thin film of blood in the subdural space, overlying the left cerebral convexity. Depth and direction: The wound track travels from the decedent's left to right and back to front, to a depth of approximately 1 inch. (3) Entrance: On the lateral left cheek, anterior to the left ear, is an approximately 1 x 3/16 inch, linear stab wound oriented from 12 o'clock to 6 o'clock. The 12 o'clock end is sharp and the 6 o'clock end is squared. 1/16 to 3/8 inch, dark red abrasion is present at the margins of this wound, widest inferiorly and continuous with a 1/4 inch linear abrasion extending anteriorly from the inferior end of this wound. Path: The hemorrhagic wound track involves the skin, subcutaneous tissue, and musculature of 000004 AUTOPSY NO: 221114-506 DECEASED: CHAPIN, ETHAN J. Page 5 the left cheek, passing between the mandible and zygomatic arch to enter the oral cavity. Associated findings: None. Depth and direction: The wound track travels from the decedent's left to right and downward. Depth cannot be accurately assessed due to the wound track entering the oral cavity. (4) Entrance: On the left neck is a gaping, 1-1 / 4 x 1/2 inch, linear stab wound, oriented from 10 o'clock to 4 o'clock. The 10 o'clock end is squared and the 4 o'clock end is sharp. Path: The hemorrhagic wound track involves the skin, subcutaneous tissue, superficial and deep musculature, and left internal jugular vein. Associated findings: There is abundant associated soft tissue hemorrhage. The left jugular vein is perforated. Depth and direction: The wound track travels from the decedent's front to back and downward, to a depth of approximately 1-1 / 2 inches. STAB WOUND OF TORSO (1) Entrance: On the left supraclavicular skin is a gaping, 2-1 / 2 x 1 inch, linear stab wound oriented from 9 o'clock to 3 o'clock. The 9 o'clock end is sharp and the 3 o'clock end is rounded, showing an approximately 4-1 / 4 inch, linear, incised and abraded tail extending laterally to the anterior left axilla. Path: The hemorrhagic wound track involves the skin, subcutaneous tissue, superficial and deep musculature, confluence of the left internal jugular and subclavian veins, and left subclavian artery. Associated findings: There is abundant associated soft tissue hemorrhage. Clotted blood is visible at the base of the wound. The left internal jugular and subclavian veins and left subclavian artery are perforated. Depth and direction: The wound track travels from the decedent's front to back and downward, to a depth of approximately 4 inches. INCISED WOUNDS OF UPPER EXTREMITIES (6) (1-3) Entrance: On the dorsal aspect of the right hand, at the base of the index, 4th, and 5th fingers, are superficial incised wounds measuring 1/8 inch, 1/2 inch, and 1/2 inch respectively. The wounds on the 4th and 5th fingers show irregular edges. Path: Th