Court Filing
EXHIBIT S-1 Amended Supplemental Expert Disclosure: Jennie Ayers The State has previously disclosed Jennie Ayers, Forensic Scientist III, as an expert witness in the field of forensic science. The State hereby incorporates its previous responses and attachments filed on December 18, 2024, and February 16, 2025, and is hereby supplementing those responses as follows. The purpose of processing the crime scene is to collect as much information and evidence as possible, in as pristine a condition as possible. The process involves assessing the situation and the scene; observing the condition of the scene; documentation of the scene via photography, written observation, sketches or diagrams; searching systematically for items or materials that may have evidentiary value; collecting items in a way that will preserve them and prevent alteration, contamination and tampering; and chemical or physical processing if needed to detect evidence that is not readily visible. Items may be processed for latent prints on scene or collected for future processing in the laboratory. Latent print evidence can be developed on scene by using light enhancement, powder or blood enhancing chemicals (amido black). Observed or developed prints are preserved with photography and / or tape lifting. Preserved impressions can be used for further latent print analyses. Ayers will testify about DNA. Deoxyribonucleic acid (DNA) is genetic material contained in human cells that may be utilized for human identification. DNA may be present on an item in the form of biological materials such as blood, semen, and saliva or may be left on an item when it is handled (touch DNA). Biological evidence and possible / potential DNA evidence is collected for preservation and may be sent for further EXHIBIT S-1 STATE'S EXHIBIT exhibitsticker.com Amended Supplemental Expert Disclosure: Jennie Ayers (Sealed) 1 S-1 CR01-24-31665 testing by qualified DNA analysts. Crime Scene personnel do not test or screen for DNA specifically. DNA evidence may be collected at a crime scene if there is observable biological material in the form of blood, semen, saliva, hair or other tissue present. Some biological material may not be visible but may be collected for its “ possible ” presence. “ Possible ” DNA material refers to areas or items that are likely to have DNA based on the details of the case or known activities. “ Potential ” DNA material refers to areas or items that may have DNA based on how they may have been handled (touch DNA). Biological / DNA material on a smaller item is generally collected by collecting the entire item (e.g. shirt, weapon, bottle). Visible biological / DNA material on a structural surface (e.g. floor, wall) or on a large object (e.g. furniture) is generally collected by using one or two sterile cotton swabs simultaneously. The swabs may be moistened with sterile water prior to sample collection. After swabbing the surface, the swabs are allowed to air dry in porous packaging. Any biological / DNA material on those swabs is preserved and can be used for future testing. Collection of “ possible ” and “ potential ” DNA are collected in the same method as described for visible DNA, using sterile water and sterile swabs. Trace materials like hairs or fibers may be present at a scene or on an item. These items can be collected with forceps and / or adhesive material and packaged for potential analysis. Shoe and tire impressions evidence may be observed or developed using chemical (amido black, leucocrystal violet, etc.) or physical methods (powder or light enhancement). Preservation methods include photography, casting and lifting. Items that may have evidentiary value are identified, documented and collected. EXHIBIT S-1 Amended Supplemental Expert Disclosure: Jennie Ayers (Sealed) 2 Effort is made to ensure that items are preserved as found. The type and size of packaging are determined based on the type of evidence. • Cigarette butt- paper evidence envelope • Paper note / receipt- paper evidence envelope • Computer and electronics components- paper evidence envelope or paper bag, depending on size and examination (s) to be completed. Larger items, like computer towers or monitors, that do not fit into standard evidence bags, may be identified with an evidence tag. • Nitrile type glove- paper evidence envelope • Vacuum dust container- paper evidence bag Presumptive blood tests are chemical tests that are used to distinguish possible blood stains from non-blood stains. The chemical tests that can be used are phenolphthalein or Ortho-tolidine. These tests are considered presumptive because the chemicals react to blood, which indicates the material may be blood. They are not specific for blood meaning they could react with a substance that is not blood. A small sample of a stain is collected onto a swab or filter paper, and the chemicals are applied to the sample; this leaves the source stain unaffected by chemicals. If the chemical has a color change (pink for phenolphthalein or blue / green for Ortho-tolidine) the stain is considered “ presumptively " positive for blood. The stain or item may be collected for future biological testing. If a test is inconclusive, the item / stain would likely be collected for further laboratory testing. If the test is negative, the item / stain would likely NOT be collected. Buccal cells are found on the inside of a person's cheek. A sterile cotton swab, or pair of swabs, is used to collect these cells as a reference DNA sample from a known individual. Buccal swab samples can be compared to unknown DNA samples from a crime scene or from an item of evidence. EXHIBIT S-1 Amended Supplemental Expert Disclosure: Jennie Ayers (Sealed) 3