Court Filing
EXHIBIT S-4 Amended Supplemental Expert Disclosure: Tara Martinez The State has previously disclosed Tara Martinez, Forensic Scientist III, as an expert witness in the field of forensic science, which includes, but in no way is limited to, latent prints and buccal swab collection and scene processing. The State hereby incorporates its previous response and attachments filed on December 18, 2024, and is hereby supplementing its response as follows. Martinez can be expected to testify regarding her involvement in this case, specifically when obtaining a buccal swab from Bryan Kohberger in January 2023. Martinez also collected hair samples and fingerprints from Kohberger. Further description of this can be found in Hailey Youngling's Report 21 (Bates Pages 6414-6422). Martinez will explain the process of collecting buccal swabs and the purpose of collection. 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. Martinez may discuss what latent prints are and why they are important in a forensic setting or investigation. Latent prints are impressions of friction ridge skin patterns that can be left on a surface when contact is made. The term “ latent ” refers to prints that are not visible prior to utilizing a development method; latent prints are often made up of various matrices, including sweat and oils that are colorless and require development with chemicals or powders to be seen. Prints at a crime scene may also be made from other materials that may coat the skin, like blood or dirt. Although latent means hidden, any EXHIBIT S-4 STATE'S EXHIBIT exhibitsticker.com Amended Supplemental Expert Disclosure: Tara Martinez (Sealed) 1 S-4 CR01-24-31665 prints recovered from a crime scene or from items of evidence are often referred to as latent prints. Latent print processing methods are different at a crime scene versus in the laboratory. The methods for latent print processing at a crime scene are generally limited to glue fuming, powder processing and blood reagents. Preservation methods include photography and lifting. Exemplars are intentional recordings of the friction ridge skin of an individual. These may be collected with black ink, powder / adhesive, electronic imaging, and / or other capture methods. These known exemplars can then be used for comparison against latent print evidence. Exemplars may include any / all areas of friction ridge skin from the hands or feet of an individual. Types of exemplars include fingerprints, palm prints, major case prints (tips, joints, sides of fingers), and footprints. Martinez will explain what it means for comparison results to return as inconclusive due to quality or quantity or what it means for comparison results to be excluded. Latent print comparison refers to the process of analyzing latent prints and comparing them to known exemplars in attempt to determine their source. Examiners utilize the ACE-V methodology which is a specialized version of hypothesis testing. ACE-V stands for analysis, comparison, evaluation and verification. Analysis is the assessment and documentation of friction ridge impressions to determine suitability for comparison. This assessment includes consideration of the quality and quantity of detail, orientation, anatomical source (finger, palm, etc.), type of matrix, deposition factors, complexity, substrate considerations, environmental factors, development mediums, and preservation methods. Latent prints may be of value for EXHIBIT S-4 Amended Supplemental Expert Disclosure: Tara Martinez (Sealed) 2 comparison or may be deemed to contain insufficient detail for comparison purposes. Impressions deemed " of value " are impressions that in the opinion of the examiner, contain sufficient quantity, quality, and specificity of ridge detail to warrant a comparison. Examiners also take into consideration how discriminating the location and arrangement of features within an impression are. When quantity is low, quality must be relatively high. Whereas when quality is low, quantity must be relatively high. It is not uncommon for latent print examiners to have conflicting opinions with regards to sufficiency. Latent prints are also evaluated for their suitability for database entry (AFIS, ABIS, MBIS, etc.) Comparison is the side-by-side, back and forth, examination of friction ridge detail between a latent print and a known print to determine whether the detail is in agreement or disagreement based upon features, sequences, and spatial relationships within the tolerance of clarity and distortion. Generally, latent prints are first compared against various known prints belonging to subjects associated with the evidence (victims, witnesses, and / or suspects if known). In the event that the latent prints are not identified or that there are no known prints available with which to compare, the prints may be entered into a computer database (MBIS) and compared to a large group of persons who have prints on file. Evaluation is the formulation of a conclusion based upon analysis and comparison of friction ridge impressions. Conclusions that may be reached are source identification, source exclusion or inconclusive. Source identification is the examiner's opinion that two impressions originated from the same source. The observed features are in sufficient correspondence such that the examiner would not expect to see this level of agreement in impressions that came from different sources. Nor did the examiner find features in disagreement that would lead them to conclude that the impressions are from different EXHIBIT S-4 Amended Supplemental Expert Disclosure: Tara Martinez (Sealed) 3 sources. There is no scientific basis for a predetermined number of corresponding friction ridge details be present in two impressions in order to effect a source identification. Source exclusion is an examiner's conclusion that two impressions did not originate from the same source. The observed features are in disagreement such that the examiner would not expect them to have originated from the same source. Inconclusive is an examiner's inability to reach a conclusion of source identification or exclusion. Inconclusive may be due to lack of quantity or quality of detail in the latent or known impression. Verification is the independent examination by another qualified analyst using the ACE methodology to either support or refute the conclusions of the original examiner. ISPFS requires verification of all conclusions rendered in a case (value determinations, identifications, exclusions and inconclusives). Routine verification is considered “ open ”. This means the verifier conducts independent analysis but has access to the original analyst's notes and images. Blind verification, in which the verifier has no knowledge of or access to the original analyst's conclusion, may be performed in cases of single identifications generated from a database, as a means of conflict resolution, or as an additional quality measure for complex impressions. Martinez may describe the Multi-Modal Biometric Identification System (MBIS). MBIS is the general term referring to any system that contains a database of ten-print, latent prints and palm prints. MBIS also includes software that is utilized to search available databases. Idaho is a member of the Western Identification Network and is able to search the databases of WIN central site members and the FBI. MBIS allows for searching latent prints against known fingerprint and palm print database records. The system can also be used to search latent prints against other latent prints. EXHIBIT S-4 Amended Supplemental Expert Disclosure: Tara Martinez (Sealed) 4 Martinez made several fingerprint comparisons in this case. The details of Martinez's involvement in the case can be found in multiple reports including Report 5 (Bates Pages 851-889), Report 10 (Bates Pages 899-930), Report 19 (Bates Pages 990- 995), Report 23 (Bates Pages 5906-5919), Report 24 (Bates Pages 5920-5927), Report 27 (Bates Pages 13578-13614), Report 30 (AV000308), and Report 32 (AV000308). In addition, Reports 38 (Bates Pages 15940-15947), 40 (Bates Pages 15952-15961) and 41 (Bates Pages 15923-15935) have comparison results. Martinez was present at 1122 King Rd. in Moscow, Idaho in November 2022 for the purpose of photographing the crime scene, the collection of evidence, and scene processing. This can be found in Martinez's Report 11 (Bates Pages 14921-14959). Additionally, Martinez was present at 1630 NE Valley Rd. G201 in Pullman in December 2022 for the purpose of photographing the apartment, and collecting potential evidence. Following this, Martinez accompanied other Forensic Scientists and Investigators to 1475 NE Glenn Terrell Mall, Wilson Short Hall, Room 12 in Pullman where Martinez took photographs. The explanation of these visits is outlined in Martinez's Report 25 (Bates Pages 9323-9354). EXHIBIT S-4 Amended Supplemental Expert Disclosure: Tara Martinez (Sealed) 5