Fulton County Superior Court ***EFILED ... - WordPress.com

Fulton County Superior Court ***EFILED***QW

Date: 4/7/2021 2:58 PMCathelene Robinson, Clerk

FULTON CO. BALLOT INSPECTION PLAN OVERVIEW

Petitioners Doran, Draime, Favorito, Peck, Scupin, Taylor and Terris present the following detailed Fulton Co. inspection plan is a good faith attempt to demonstrate to the court a well-conceived plan to carry out the Fulton Co. mail-in ballot inspection in a manner that is acceptable to all parties.

PLAN HIGHLIGHTS

The ballots will remain in the custody of the clerk’s office at all times

Provisions are made for the Special Master to oversee all proceedings

Three representatives of the Fulton Co. Clerk’s office can view proceedings and confirm chain of custody in the unsealing and resealing of ballot boxes

Stationary videography will cover the room to ensure that no tampering of any kind occurs during the inspection

The process will include a detailed visual mail-in ballot inspection and produce 600 D.P.I. images of those ballots consolidated on certified and sealed hard drives that can be distributed to experts for forensic inspection

Inspectors will consist of Georgia residents who will have a background check and a court approved Non-Disclosure Agreement (NDA) tendered to the Special Master and Opposing Counsel three days before the inspection

Each inspector will confirm in their NDA that they will not disclose any findings they may be aware of until such findings are presented in court

If the proposed inspection plan is approved, it can be conducted according to hours of operations of Fulton Co and completed within 5 days

Petitioner’s Counsel and employees need not be present for the inspection

The inspection will conform to the 45 person capacity assigned for the room

Inspectors will not use blue or black ink pens to record their notes on box and batch worksheets that are used for mathematical analysis

Inspection personnel will be selected from a list of Georgia residents expected to include:

o 7 poll managers o 6 hand count auditors o 10+ poll workers o 25+ audit or recount monitors o 3 monitor coordinators

Nearly all have been poll observers and most are also experienced in Fulton county.

PLAN CONTENTS:

The inspection plan includes the following artifacts to precisely define the process:

A one-page flow chart that clearly illustrates the overall flow of the inspection process

A detailed step by step plan that outlines the tasks to be performed and the team performing the tasks

A site chart of the inspection room that shows the location and purpose of all inspectors, inspection tables and supporting functions and personnel

The Curriculum Vitae (CV) of experts who may be selected to be on site

A list of all Georgia residents who may be selected as inspectors including their elections experience

FULTON CO. MAIL-IN BALLOT INSPECTION PLAN

CUSTODY VERIFICATION

1. Obtain Mail-in Box Recap Sheet w/ BoxID and ScannerID, from the World Congress Center recount (F,P)

2. Inspect sticker and tape of each box of ballots for tampering (F,P)

3. Inspect box for SOS Seal and dual signatures matching signatures for Box on Recap Sheet (F,P)

4. Photograph each ballot box with their Seal and dual signatures (P)

5. Record Box ID# (nnn) Scanner ID, #Batches, #Ballots and comments on box form (P)

6. Carefully open one ballot box per team at a time in presence of inspection team (F)

7. Review cover sheet with contents for each box and photograph sheet (F,P)

8. Record batch#, ballot count and Scanner ID (if different than Box) for each batch on the batch form (P)

9. Keep forms with box for scanning and inspection (P)

BALLOT SCANNING

10. Insert new sealed memory stick into scanner for each Box to scan (S)

11. Scan all ballots in each batch for a Box at 600 D.P.I. one batch at a time (S)

12. Remove memory stick from scanner and place in a box with container (S)

BALLOT INSPECTION

13. Remove one batch at a time from a box for inspection (P)

14. Perform visual inspection and general count verification on each ballot of each batch (P)

15. Place each batch back in box (P)

16. If box contains no suspect batches, Perform Image Consolidation Plan Central Management. (F, P)

F= Fulton, P=Plaintiffs, S=Scanners, CM=Central Management

SUSPECT INSPECTION

16. Inspect the ballots of any suspect batch in a box one batch at a time (P)

17. Inspect each ballot for creases, marking, and ballot stock of ballot batch (P)

18. Inspect, photograph and record any comments for questionable batches (P)

19. Record Suspect batch detail on Suspect tab of Batch form (P)

IMAGE CONSOLIDATION

20. Scan box and batch worksheets for each box (CM)

21. Remove memory stick from box and insert into consolidation computer (CM)

22. Copy memory stick with newly scanned ballot images to hard drive (CM)

23. Remove memory stick from scanner

RE-ESTABLISH CHAIN OF CUSTODY

24. Seal memory device in a bag and place in box (CM)

25. Ensure all batches are returned to their respective box with their coversheet (F, P)

26. Reseal each ballot box with a new inspection seal and the original Seal ID that matches the recap sheet (F)

27. Photograph each ballot box (P)

28. Ensure two people sign each box seal (F)

IMAGE DISTRIBUTION PLAN

29. Copy scanned 600 D.P.I. images from Consolidation hard drive to each Experts hard drive (CM)

30. Seal, sign and date all Expert hard drives (CM)

F= Fulton, P=Plaintiffs, S=Scanners, CM=Central Management

Ballots Secured

Scann

er

Scann

er

PurpGrn

Staging Table Staging Table

1

5 55

2 2

1

4

Please see next page for Map Legend

Red

Purp

Susp

ect

Tb

l

Central Mngmt

Completed Ballots

Grn

5

5 55

6

5

46

9

7

8

10

3

Ballots Secured

Scann

er

Scann

er

Purp Wht

Staging Table Staging Table

4

5

4

55

2

1

2

1

3

3

Purp

Roy Blu

Wht

Susp

ect Tb

l

Central Mngmt

Completed Ballots

6

5

4

5 5

6

55

6

3

12

7

8

9

11

SMSM

MAP LEGEND

= Fulton county employees (3 total)

1-2 = Scanning Team

3 = Videography Team capturing video of Ballot Inspection Process to ensure transparency and follow thru of the plan. Photography Team capturing still photos of the Ballot box before unsealing and after re

4-6 = Visual Inspection Team

7-9 = Suspect Ballot Team7-9 = Suspect Ballot Team

10-12 = Central Management Team

SMSM = Special Master

MAP LEGEND

= Fulton county employees (3 total)

2 = Scanning Team

Team capturing video of Ballot Inspection Process to ensure transparency and follow thru of the plan. Photography Team capturing still photos of the Ballot box before unsealing and after re-sealing.

6 = Visual Inspection Team

9 = Suspect Ballot Team9 = Suspect Ballot Team

12 = Central Management Team

= Special Master – Roaming position

NAME Poll M

anager

Poll W

orker

Poll W

atcher

Audit

Monito

r

Recount

Monito

r

Auditor

Coordin

ator

Attorn

ey

IT P

rofe

ss

Angela Bean

Anna Tillman

Barbara Hartman

Barry Auerbach

Ben Hendrick

Ben Parsons

Betty Cowell

Brad Grossman

Brenda Oldroyd

Bridget Thorne

Brooke Grey

Candace Serafin

Catherine Gent

Catherine Laguardia

Charles Cummings

Cherie Werginz

Cheryl Jones

Cheryl Wahlin

Christine McKinnell

Dana Forehand

David Cross

David Hancock

Debbie FisherDebbie Fisher

Dennis Powell

Edna King

Elaine Davis

Elaine Kilgore

Eric Christensen

Gabe Clavijo

Garland Favorito

Georgia Hunter-Parsons

Gordon Rolle Jr.

Hale Soucie

Harry Macdougald

James Forestal

Jan Horne

Jan Johnston

Jan Morrow Jane Lu Jim NelsonJohn Smallshaw

Judy AubeJulie AdamsKaren Hogan

Kathryn Nelson

Kenny King

Kevin Taylor

NAME Poll M

anager

Poll W

orker

Poll W

atcher

Audit

Monito

r

Recount

Monito

r

Auditor

Coordin

ator

Attorn

ey

IT P

rofe

ss

Kim Kaloyannides

Kimberly Hoechstetter

Lenny Daniel

Linda Ellis

Linda Menk

Lisa Kaminsky

Mary Kay Bacallao

Melanie Tomlinson

Michael Opitz

Michelle Millhof

Pamela Reardon

Pavel Stuchlik

Ricardo Davis

Robin Auerbach

Robin Hall

Sarah Spicher

Scott Hall

Sean Draime

Sean Kilbane

Sonia Francis-Rolle

Sue Vaughan

Susan Voyles

Ted Metz Ted Metz

Tom Bare

Tom Teagle

Tommy Amoroso

Trip Soucie

Victoria Cruz

Joel DeVisser Videography

Joseph L. Parker Suspect Expert

Thomas W. Vastrick Suspect Expert

Daniel Knutson Videography

mailto:[email protected]

Member: American Society of Questioned

Document Examiners

American Academy of Forensic Sciences - QD Section

Southeastern Association of Forensic Document Examiners

Certified: American lloard of Forensic

Document Examiners

1. Education and Training

Forensic Document Examiner

[email protected] WEBSITE - thomaswvastrick.com

EXHIBIT B CURRICULUM VITAE

Orlando, FL (Main) Office 522 S Hunt Club Blvd Suite 217

Apopka, FL 32703

Tallahassee, FL (Branch) Offic'e 1400 Village Square Blvd 113··.149

Tallahassee, FL 32317.

(407) 234-3219

Fax in U.S. (800) 216-9003

Bachelor of Science in Forensic Science from California State University at Sacramento, 1977.

Two-year, full-time, in-residence training program with the U.S. Postal Inspection Service Headquarters Crime Laboratory in Washington, DC from 1977 through 1979.

2. Experience

Full-time Forensic Document Examiner with the U.S. Postal Inspection Service Southern Region Crime Laboratory from 1980 through 1992.

Private consulting services in Forensic Document Examination since 1990.

Examinations involve handwriting, hand printing, alterations, typewriting, indented writing, counterfeiting, ink & paper analyses, burned document restoration, and mechanical impressions.

Research Manager, National Center for Forensic Science, University of Central Florida, Orlando, FL 2011 - 2015

3. Courtroom TestimonyHave testified as an expert in Forensic Document Examination over 300 times. Have testified in federal, state and local courts along with military hearings, arbitration hearings and administrative law hearings.

Have testified in Federal District Court in: Alabama, Arkansas, Florida, Georgia, Louisiana, Mississippi, North Carolina, Oklahoma, South Carolina, Tennessee, and Texas.

Have testified in the following state courts: Alabama, Arizona, Arkansas, Florida, Georgia, Kansas, Kentucky, Louisiana, Mississippi, Missouri, Oklahoma, Tennessee and Texas.

4. CertificationCertified through technical testing by the American Board of Forensic Document Examiners (ABFDE) since 1982. The ABFDE is the only certification body that is recognized by all federal government agencies employing Forensic Document Examiners along with many state and municipal law enforcement agencies. The ABFDE is also the only certification board that meets and has met published standards for required education and training with 100% compliance.

Served on the ABFDE Board of Directors 1987 to 1995.

Served as Secretary of the ABFDE Board of Directors 1991 to 1995.

CURRICULUM VITAE--JOSEPH L. PARKER – February 19th, 2021

ATLANTA FORENSIC DOCUMENT EXAMINER SERVICES, INC.

518 PINEGATE RD, PEACHTREE CITY, GA 30269

OFC/FAX (770) 631-1789; Cell/text (770) 508-4763; Email: [email protected]

Education:

Major Degree Completed

Methodist College Jan-Dec 1975 English/Psychology BA Fayetteville, NC

Central Michigan Univ. Jun 84-Dec 90 Administration MSA Satellite Campus

Fort McPherson, GA

Basic Forensic Document Examiner Training:

U. S. Army Questioned Document Examiner Program of Instruction (QDE POI) 1978-1980. This formal Army

TRADOC Course required completion of the two-year, full-time resident training to become a Forensic

Document Examiner (FDE) at the U.S. Army Criminal Investigation Laboratory (USACIL) at Fort Gordon, GA, in

1980. The training program consisted of structured reading assignments, practical exercises, written and oral

examinations, as well as on-the-job exposure to examinations relative to Questioned Document

Examination. Course instructors were U. S. Army Lab court-qualified Questioned Document Examiners.

Supplemental and continuing FDE education:

Paper Identification Seminar 1978, National Institute of Paper Chemistry, Appleton, WI

Questioned Document Course 1980, U. S. Secret Service, Washington, DC

Questioned Document Examination for Laboratory Personnel 1983

Federal Bureau of Investigation Academy, Quantico, VA

Graphic Arts Orientation Course 1983, Rochester Institute of Technology, Rochester, NY

Fundamentals of Typewriter Examination for Laboratory Personnel 1989-FBI Academy, Quantico, VA

Mead Paper and Printing Seminar 1991, Mead Corporation, Chillicothe, OH

Expert Witness and Deposition Testimony Workshop, 1991 ASQDE AGM, Lake Buena Vista, FL

Laser Printer Workshop (Estabrooks & Michaud), 1993- ASQDE Annual Meeting, Ottawa, Canada

INS Forged Travel Document Seminar (Larner), 1994-ASQDE Annual Meeting, Long Beach, CA

Typewriter Identification Workshop (Muehlberger, Crown &Tytell) 1995-SAFDE Annual Mtg, Atlanta, GA

Canon Fax Machine and Copier Workshop, 1996-SAFDE Annual Meeting, Atlanta, GA

Examining Documents Through-out the Spectrum (Richards), 1997-SAFDE Annual Meeting, Atlanta, GA

Handwriting Workshop (McKasson & Rile), 1998 ASQDE Annual Meeting, Indianapolis, IN

Rubber Stamp Examination Workshop (Lindblom), 1999 SAFDE Annual Meeting, Atlanta, GA

Typography Workshop (W. Flynn), 2000 SAFDE Annual Meeting, Atlanta, GA

Computer Printer Technology; Indentation Examination (ESDA)

Protocols; and Rubber Stamp & Seal Manufacturing Workshops, 2000 ASQDE AGM, Ottawa, Canada

Depositions and Evidence Admissibility; Validation of Assessment of Handwriting Habits; Electronic Court

Exhibits; and Handwriting and Signature Examination Workshops, 2001 ASQDE AGM, Des Moines, IA

Annual Meeting, QD Section, 2002 American Academy of Forensic Sciences (AAFS), Atlanta, GA

mailto:[email protected]

CURRICULUM VITAE -- JOSEPH L. PARKER (cont’d) February 19th, 2021

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Adobe Photoshop Workshop (G. Reis), Fort Gillem, GA 2002

ASQDE Annual Meeting & Workshops, 2002, San Diego, CA

The Lindbergh Trial and Forensic Document Examination Workshop; and Twenty-First Century Document

Examinations Workshop; ASQDE Annual Meeting 2003, Baltimore, MD

HAAS Atlas and Typewriter Classification Workshop, and Examination of Photocopies Signatures:

Distinguishing Between Line Quality and Ink Morphology Workshop; 2004 SAFDE Meeting, Atlanta, GA,

SAFDE Annual Meeting & Workshops, Atlanta, GA April 2005

ASQDE Annual Meeting & Workshops, August 2005, Montreal, Canada

SAFDE Annual Meeting & Workshops, April 2006, Atlanta, GA

SAFDE Annual Meeting & Workshops, April 2007, Atlanta, GA

ASQDE Annual Meeting & Workshops, August 2007, Boulder, CO

AAFS Annual Meeting & Workshops, February 2008, Washington, DC

SAFDE Annual Meeting and Workshop, April 2008, Peachtree City, GA

SAFDE Annual & Workshops, April 2009, Peachtree City, GA

ASQDE Annual Meeting & Workshops, August 2009, Dearborn, MI

SAFDE Annual Meeting & Workshops, April 2010, Duluth, GA

ASQDE Annual Meeting & Workshops, August 2010, Victoria, Canada


ASQDE Annual Meeting & Workshops, 2011, Philadelphia, PA

AAFS Annual Meeting & Workshops, February 2012, Atlanta, GA (served as QD Section Program Co-Chair)


ASQDE Annual Meeting & Workshops, 2012, Charleston, SC


ASQDE Annual Meeting & Workshops, August 2013, Indianapolis, IN




ASQDE Annual Meeting & Workshops, August 2016, Pensacola, FL


ASQDE Annual Meeting & Workshops, August 2017, San Diego, CA

SAFDE Annual Meeting & Workshops, April 2018, Decatur, GA

ASQDE Annual Meeting & Workshops, August 2018, Park City, UT

ASQDE Annual Meeting & Workshops, August 2019, Cary, NC

ASQDE Virtual Annual Meeting & Workshops, August 2020

AAFS Virtual Annual Meeting, February 2021

I have attended and participated in numerous additional training seminars, workshops and instructional tours

on various aspects of document examination and production related to Forensic Document Examination (FDE),

to include paper making, printing methods, ink pens, check printing, dandy-rolls, bar codes, signature and

handwriting workshops, lottery ticket printing, security documents and counterfeit materials identification.

EMPLOYMENT HISTORY

During 40+ years as a Forensic Document Examiner, I have personally examined hundreds of thousands of

documents related to more than four thousand cases; I reviewed thousands of additional examinations for

fellow examiners during military (1980-1991) and federal civil service employment (1991-2011). I presented

numerous training sessions worldwide on the subject of Forensic Document Examination to military, federal,


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state, and industry investigators and attorneys. I have also given orientation lectures on Forensic Document

Examination to students at several colleges, to civic groups, and to private investigator groups.

September 2011- Present: Forensic Document Examiner in Private Practice, Owner/Operator of

Atlanta Forensic Document Examiner Services, Inc., Peachtree City, GA

Work: Forensic Document Examiner conducting non-destructive FD Exams; providing affidavits and reports

of examination results; and rendering expert testimony of examination results in legal venues, as required.

Participate in annual proficiency testing (CTS); maintain personal ABFDE certification by meeting continuing

education requirements through research and participation in FDE professional organization workshops and

meetings. My AFDES private practice FDE lab contains all technical equipment, reference materials, and other

resources essential for nondestructive FDE Examinations, reporting, and expert testimony. I have conducted

extensive research on PDF software technology and its effects on documents.

July 1995 - September 2011 Forensic Documents Branch Chief and Forensic Document Examiner

U.S. Army Crime Laboratory, Fort Gillem (Forest Park), Georgia

Principal Duties: FD Branch Chief and FDE topic expert for DoD; Managed FD Branch operations and

supervised subordinate Forensic Document Examiners and reservist FDE; personally conducted Forensic

Document Examinations, wrote reports, provided expert testimony as required; reviewed reports of

subordinate examiners; managed FD proficiency testing, also personally completing CTS tests each year; and

maintained personal ABFDE certification. Developed, updated and provided FDE orientation training for

Department of Defense investigators and legal personnel worldwide.

Jun 94 - July 1995 Forensic Document Examiner

U.S. Army Crime Lab, Fort Gillem (Forest Park), Georgia

Principal Duties: Forensic Document Examiner - conducted FD Exams, wrote reports and provided expert

testimony as required; completed annual proficiency tests from CTS; maintained personal ABFDE certification;

supported U. S. Department of Defense units worldwide.

September 1991 - June 1994 Forensic Document Examiner

Bureau of Alcohol, Tobacco and Firearms (BATF) Crime Lab, Atlanta, GA

Principal Duties: Forensic Document Examiner-conducted FD Exams, wrote reports and provided required

expert testimony throughout the Southeastern USA; completed annual proficiency tests; and maintained

personal ABFDE certification; Personally created protocols and documentation to gain initial accreditation of

the Questioned Documents Section as part of the ASCLD-LAB accreditation of the BATF Laboratory.

1980-1991 Questioned Document Examiner-U.S. Army Crime Labs in mainland USA and Japan (1986-1990)

Principal Duties: Questioned Document Examiner (FDE)-conducted FD Exams, wrote reports and provided

expert testimony as required; supported U. S. Department of Defense units worldwide. 1980-1986 served as

Training Officer at USACIL-CONUS, directly supervised the training of Army FDE students and course updating;

assisted with training of additional FDE students at the Army and other federal and state law enforcement

agencies.

1978 - 1980 Questioned Document Student at the U.S. Army Crime Laboratory-CONUS, Fort Gordon, GA

Principal Duties: Questioned Document Student - successful completion of the Questioned Document Examiner


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Program of Instruction (POI) in June 1980

1972 – 1978 Worked as an Army CID Special Agent (Criminal Investigator), ultimately specialized in

procurement contract fraud, other white-collar crimes, and developed criminal intelligence protocols.

1970 – 1972 Training and service as an intelligence analyst for the U.S. Army in the Republic of South Viet Nam (1971 - 1972).

PROFESSIONAL MEMBERSHIPS, ACTIVITIES AND PERSONAL CERTIFICATION:

In addition to initial certification as a Forensic Document Examiner in 1980 by the U.S. Army Criminal Investigation Command Laboratory (USACIL), I successfully completed written, practical and oral testing

required to obtain certification by the American Board of Forensic Document Examiners (ABFDE) in 1991. I

have met all subsequent 5-year cycle professional development and continuing-education credit requirements (1996, 2001, 2006, 2011, and 2016) to maintain ABFDE certification. My professional activities include

membership in the American Society of Questioned Document Examiners (ASQDE); served as membership testing committee member & Chair and Editorial Review Board Member of the Journal of the ASQDE; member

of the Southeastern Association of Forensic Document Examiners (SAFDE): I have served as SAFDE Treasurer program chair, workshop chair, and site-chair); and the Questioned Document Section of the American

Academy of Forensic Sciences: AAFS – QD Section co-program chair 2012. I completed assessor training and

served as the FDE discipline assessor for several crime laboratory accreditation inspections by the American Society of Crime Laboratory Directors-Laboratory Accreditation Board (ASCLD-LAB). I completed ISO forensic

laboratory accreditation assessor training (ASCLD-LAB and FQS) and supervised development of FDE protocols to meet ISO accreditation requirements for the Forensic Document Branch at USACIL. I actively participated in

the FBI-sponsored Scientific Working Group for Questioned Documents (SWGDOC) from it’s inception as

“TWGDOC” in 1997 through 2013, when I was voted into SWGDOC membership. SWGDOC has published FDE standards on-line since 2012. I was a member of ASTM-International, which produced and published national

standards and guidelines through SWGDOC for the FDE field in the USA. ASTM-International published new FDE standards through 2012; I ended my ASTM-International membership in 2017, concurrent with the

expiration of the last FDE standard published by ASTM-International.

In 2016 I assisted members of the Forensic Document Examination (FDE) Consensus Body of the Academy

Standards Board (ASB) of the American Academy of Forensic Sciences (AAFS), an ANSI-accredited

Standards Development Organization, by personally writing the initial draft, and helping in the subsequent development of, a standard for examination of digital-source documents; I also assisted the FDE Consensus Body committee in development of the Standard for Minimum Training Requirements for Forensic Document

Students and interactions with the Law Review Committee of the ASB.

RESEARCH, PUBLICATIONS and PRESENTATIONS:

I have made numerous presentations of case-related technical information; I have voluntarily participated in

several research projects concerning FDE proficiency conducted by academic groups and my peers; I also

conducted research in various technical areas of Forensic Document Examination and made presentations of research results at FDE professional meetings. During 2019-2020 I completed all 100 test examinations for the

FBI Black Box Handwriting Examiner Decision Analysis Study. Several of these papers were also published in peer-reviewed forensic journals and law enforcement publications:

"An Update on Optical Contractors and Their Application to Questioned Document Examinations"

(Research and Author Only) 1979 American Society of Questioned Document Examiners "ESDA Product Resolution Retention" 1984 American Society of Questioned Document Examiners

"Deciphering Grease Pen Obliterations" 1986 American Society of Questioned Document Examiners

"A Limited Review of Current Check Printing Methods" 1988 American Society of Questioned

Document Examiners


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"Repeated Disguise Beats the Clone Defense" 1989 American Society of Questioned Document Examiners

"The Detection of 3M "Post-It" Note Pad Adhesive Residue on Documents" 1990 American Society of Questioned Document Examiners

"Document Examination of Counterfeit Video Tapes" (Co-author/ Presenter) 1992 American Academy of Forensic Sciences

“Identification of the Okidata Microline-92 9-Pin Dot Matrix Printer" 1993 American Society of Questioned Document Examiners

Senior Examiner Panel on Federal Laboratory Document Divisions, 1996 American Society of Questioned Document Examiners

Panel Review of Recent Daubert Hearings on Questioned Document Examination (Presenter) 1997 Southeastern Association of Forensic Document Examiners "Two Daubert Hearing Case Studies: U.S. vs. Humphery and U.S. vs. Martin" 1997 American Society of Questioned Document Examiners

"An Instance of Inkjet Printer Identification", 2001 ASQDE Annual Meeting and 2002 AAFS Questioned Document Section Annual Meeting.

“The Importance of Forensic Document Examiner Opinion Testimony”, 2003 American Society of

Questioned Document Examiners

"Why FDE Training Must Be For A Minimum of 24-Months", 2005 American Society of Questioned Document

Examiners

“Examining PDF Files and Associated Documents”, 2007 American Society of Questioned Document

Examiners and 2008 American Academy of Forensic Sciences

“PDF Technology in 2011”, 2011 American Society of Questioned Document Examiners; 2012 American

Academy of Forensic Sciences

“Copy Stand Versatility”, 2012 Southeastern Association of Forensic Document Examiners

“EDD Optimization: Recording Images Before Encapsulation”, 2015 Southeastern Association of Forensic Document Examiners

“Wheels of Justice…Grinding to a Stop” (estate case study), 2016 Southeastern Association of Forensic Document Examiners

“Metadata – Potential Support for Forensic Document Examiners”, Co-Author, 2016 American Society of

Questioned Document Examiners

“Contending with FDE Pretenders….and Residual Sensations”, 2017 Southeastern Association of Forensic Document Examiners

“Case Study #3 – Dealing with Conflicting Opinions”, Trainee Workshop, 2017 American Society of Questioned Document Examiners

“Case Study #3 – Dealing with Conflicting Opinions” from the 2017 ASQDE AGM, presented again at the 2018 technical sessions of the Southeastern Association of Forensic Document Examiners AGM

“Bias and Contextual Information in Forensic Document Examination” Workshop, Co-author/presenter, 2018 Southeastern Association of Forensic Document Examiners


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“Document Abnormalities Related to PDF Technology” 2021 American Academy of Forensic

Sciences (AAFS) oral/video presentation

LEGAL EXPERIENCE:

I have testified and provided assistance to prosecution, and to other FDE, in numerous additional Daubert hearing preparations; I assisted the Prosecution preparation of Daubert materials in June 2014 for the capital murder re-trial of State of Florida v. Jesse Lee Miller Jr.

EXPERT TESTIMONY:

I have testified as an FDE expert 171 times at various criminal and civil legal hearings, depositions, and courts for county, state, federal, USA military, and other legal hearings worldwide. Prepared expert-witness

demonstration materials and pre-trial education items for defense, prosecution, clients, and opposing attorneys, for many of these 170 cases, as well as for many hundreds of additional cases in which I

ultimately did not testify.

Expert testimonies include the following:

171. 6 October 2020, (virtual) - Sherry L. Caldwell v. Kim Garretson Hatcher Re: Estate of Anna Catherine

Perry, GA; signature simulation Garretson, Probate Court of Houston County, GA, DOCKET NO. 2018-ES-

357; Accounting Hearing; Judge Kim Willson; Attorney M. Stanley Martin,

Warner Robins, GA; Opposing counsel D. Lee Peacock, Varner & Peacock,

Warner Robins, GA.

170. 19 November 2019, Lawrence- - Russell T. Bryant v. Corina Hernandez Bryant; Superior Court of Gwinnet

ville, GA; signature County, GA; Civil Action No.16 – A-11868-10; Contempt Hearing before

Judge Warren Davis; Attorney Michael J. Anderson, Lawrenceville, GA;

Opposing counsel Judy C. King, Lawrenceville, GA.

169. 10 October 2019, Cumming, GA - Nicholas J. Swiatek v. Spencer A Smallwood; Superior Court of Forsyth

Paper, ink, hand printing, County, GA; Civil Action No. 16CV-1491-1; Damages Hearing before Judge

Indentations, machine printing Jeffrey A. Bagley; Attorney Matthew Dominick, Cumming, GA; opposing pro

se Spencer A. Smallwood

168. 25 July 2019, Fayetteville, GA - MARTI TOOLE, Individually and MAJOR TOOLE, as Personal

Paper, labels, inks, indentations Representative of the Estate of CLAYTON THOMAS TOOLE v.

HHC ST. SIMONS, INC., a Georgia Corporation d/b/a ST. SIMONS

BY-THE-SEA and UHS OF DELEWARE, INC., a Foreign Corporation,

Deposition for SUPERIOR COURT OF GLYNN COUNTY GA, CIVIL

ACTION NUMBER: CE18-00735; Attorneys Patrick Sullivan, Barnes &

Cohen, P.A., Jacksonville, FL; and Paul M. Scott; defendant Counsel Joel

S. Neckers, Denver, CO.

167. 2 October 2018, Albany, GA - Harry James v. Nickerson, et al, Dougherty County Election Commission,

Signatures, hand printing & cursive Superior State Court case No. 18D:1038; Judge Dane Perkins; Attorney W.

Earl McCall of McCall -Williams, LLC, Albany, GA; Opposing counsel

Christopher J. Hamilton, Cummings, GA.

166. 6 February 2018, Dawsonville, GA – Sweatman v. Sweatman v. Robert Wallace, Dawson County Superior Court

Signature case No. 2015-CV-381-A; Judge Jason Deal; Attorneys J. Kelsey Grodzicki

and James Craig, of Campbell & Brannon, LLC, Atlanta, GA; also Stroud

Stacy, Law office of Stroud P. Stacy, Dahlonega, GA ; Opposing counsel

Stuart Teague and Keisha Chambless of Teague & Chambless, LLLP,

Cumming, GA.

165. 20 September 2017, Atlanta, GA – Arbitration Hearing #01-17-0000-4562 case Sue Ivy Chadwick v Regions’

Signatures, Illness/Old Age Regions’ Bank, American Arbitration Association – Karen D’Amico;

Attorney Michael T. Camp, Camp Law Office, Carrollton, GA; Opposing

counsel William J. Holley, Parker Hudson Rainer & Dobbs, Atlanta, GA.


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164. 10 August 2017, Marietta, GA - Probate Court, Estate of Beatrice Robby Witherington, Estate No. :

Signatures, Simulation, Initials 16-0459, Probate Court Of Cobb County, State Of Georgia, Marietta,

GA; Attorney Kasey Libby, Atlanta, GA; Opposing counsel Charles

M. Lane, Carrollton, GA

163. 18 July 2017, Atlanta, GA - GA Lottery v. Payne & Heard Case, #2015CV265487- Fulton County

Inks, paper, hand printing Superior Court, Atlanta, GA; Attorney Albert C. Palmour, Summerville,

GA; Jack and John D. Floyd, Gadsden, AL; Opposing counsel Thomas

Lindsay, Rossville, GA

162. 14 June 2017, Birmingham, AL - AAA Arbitration Hearing re: L. Shefton Riggins and Thoracic Cardiac &

Scanned pdf documents, alterations Vascular Surgery v. Regions Bank, (Case #01-CV-2015-900632, CIRCUIT

Signatures, Initials COURT OF JEFFERSON COUNTY, AL); Attorneys Joe Alan Joseph & Ben

Coulter, Burr Forman LLP, Birmingham, AL; Opposing Attorney Samuel

Mark HILL, Hoover, AL.

161. 6 June 2017, Birmingham, AL - Deposition re: Dr. L. Shefton Riggins and Thoracic Cardiac & Vascular

Scanned pdf documents, alterations Surgery v. Regions Bank, Alabama State Court Litigation, AAA Arbitration

Signatures, Initials Matters, and Case #01-CV-2015-900632, CIRCUIT COURT OF

JEFFERSON COUNTY, AL; Attorneys Joe Alan Joseph & Ben Coulter,

Burr Forman LLP, Birmingham, AL; Opposing Attorney Samuel Mark HILL,

Hoover, AL.

160. 31 May 2017, Ludowici, GA - Probate Court Motion Hearing, Long County, GA re: Estate of Lannie

Signature-initials, simulation Wilton Burkhalter C/M No. 3072/1; Judge Bobby Harrison Smith; Attorney

John A. Donsbach, DONSBACH & KING, LLC, Augusta, GA; Opposing

Attorney Jeffrey Arnold, Arnold & Staffer, LLP, Hinesville/Ludowici, GA.

159. 28 March 2017, Birmingham, AL - Motion Hearing for the Circuit Court of Jefferson County, AL, re:

Scanned pdf documents, alterations L. Shefton Riggins Dr., et. al. v. Regions Bank, et. al., 01-CV-2015-900632.00 Judge Tamara Harris JOHNSON; Attorneys Joe Alan Joseph & Ben Coulter, Burr Forman LLP, Birmingham, AL; Opposing Attorney Samuel Mark HILL, Hoover, AL.

158. 20 December 2016, Charleston, SC - Deposition for Court of Common Pleas, County of Charleston, Signature, Hand printing, Copies State of South Carolina, re: Rutherford P. C. Smith as Special

Administrator of the Estate of Joseph John P. Serra v. Margie J. Brown, South Carolina Federal Credit Union and Wells Fargo Bank, N.A., Case No. 2014-CP-10-2951; Attorney Julius H. Hines, K & L Gates, Charleston, SC; Opposing Attorney Richard Farrier, Pierce, Herns Sloan & Wilson, Charleston, SC.

157. 30 Nov- 1 Dec 2016, Darien, GA - McIntosh County Superior Court Case #2016-V-16, McIntosh Family

Signature, Initials, Copies Chiropractic v. Amanda Skorupski; Judge Russell; Attorney C. Foster Lindberg, Ligon, Lindberg & Lanier, PC, Brunswick, GA; Opposing Attorneys Katie S. Mitchell and Scott Reddock, Mitchell & Reddock, Hinesville, GA.

156. 9 November 2016, Monroe, GA - Magistrate Court Hearing #WA16-0080, Debra Town v. Russell Down,

Signature, Judge Mike Burke, Walton County Magistrate Court, Pro Se Ms. Town,

Opposing Attorney John Nelson, Duluth, GA

155. 8 August 2016, Conyers, GA - Hearing for Cause: Debra Town v. Russell Down, Magistrate WA-16-0102,

Signature Judge Phinia Aten, Rockdale County, GA; Attorney Matthew McCord, Jonesboro, GA; Opposing Atty M. Qader A. Baig & Associates, LLC, Conyers,GA


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154. 5 August 2016, McDonough, GA - Estate of Anna Jean Diamond, Estate No. 2015-ES-371, Probate Court,

Signature, simulation Henry County, GA; Judge Kelley S. Powell; Attorney T. Kyle King,

Hodges, McEachern & King, Jonesboro, GA; Opposing Atty Emmett J. (Jerry) Arnold, IV, McDonough, GA

153. 29 June 2016, Athens, GA - AVA BROWNER v. LESLEY MOORE and SABRINA GANT, as Signature, simulation ADMINISTRATORS OF THE ESTATE OF THEODIS GANT

Civil Action NO.: SU-15-CV-0495-S, Athens-Clarke County GA State

Superior Court, Judge Lawton E. Stephens; Attorneys Timmons, Warnes &

Mercer, LLP, Athens, GA; Opposing Atty Michael Daniel

152. 29 February 2016, Seattle, WA - SOUTH EAST ENTERPRISE GROUP, LLC, et al v. John Gill;

Signatures, Paper, Printing, Inks Civil Action File No. 4:15-CV-25-CD; US Dist Court for Middle Dist

GA, Arbitration Hearing in Seattle, WA; Atty Michael D. Stacy, Atty Alex Kaufman, Kaufman & Forman, Atlanta, GA; Opposing Atty John J.E.

Markham, III-Boston, MA

151. 1 December 2015, Atlanta, GA - SOUTH EAST ENTERPRISE GROUP, LLC, et al v. John Gill; Signatures, Paper, Printing, Inks Civil Action File No. 4:15-CV-25-CD; Deposition for US Dist Court for

Middle Dist GA; Atty Richard L Robbins, Jason S. Alloy, Craig G. Kunkes, J. Matthew Brigman; Opposing Atty John J.E. Markham, III-Boston, MA

150. 2 April 2015, Jonesboro, GA - State of GA v. Tobias Leviticus Worthen (Criminal Action) Signatures, hand printing, inks Case 2014-CR-00525 -6, Clayton County Superior Court

Identified signature, hand printing ADA Atty Miguel Dominguez; Defense- Atty Ashley Palmer

149. 25 February 2015 Atlanta, GA - Eugene F. Assaf v. Gerald Bernard Stein

Signatures, hand printing 2nd Deposition for State Court of Fulton County, Atlanta, GA Identified signatures Civil Action File No. 10EV010808E

Atty Judy Aust (Goodman McGuffey Lindsey & Johnson LLP) Opposing Atty James A Rice, Jr., PC, Atlanta, GA

148. 29 October 2014, Columbus, GA - Estate of Daniel D. Greene vs. Janie M. Greene- Civil Action

Signature, Simulation, Paper, Inks, Case CV-2012-900220 Circuit Court of Russell County, AL Indented writing, Indented seals, Deposition testimony; Atty James B. McNeill Jr, Selma, AL; Computer toner printer Deposed by Atty James R. McKoon, Jr., Phenix City, AL

147. 15 August 2013, Columbus, GA - United of Omaha Life Insurance Company vs. Walter Lee

Signature, Simulation Westberry, Sr. and Tammy Brackett-Ausby

Superior Court of Muscogee County, Georgia Atty O. Wayne Spence, Columbus, GA; no opposing counsel

146. 3 April 2013, Atlanta, GA - UNITED BANK, et al v. HELME CALFEE and KAREN Signatures, computer printing, VOHMAN, et al- Civil Action No. 2011CV196613 Indentations, rubber stamps Master Hearing testimony-Fulton County Superior Court, GA Hand printing, paper, pen ink Atty Dana Diment, DIMENT CARROLL, LLP, Carrollton, GA

Deposed by Ray S. Smith III, Atlanta, GA

145. 21 March 2013, Carrollton, GA - United Bank, et al V. Helme Calfee and Karen

Signatures, Computer Printing, Vohman, et al- Civil Action No. 2011CV196613 Indentations, rubber stamps Deposition testimony-Fulton County Superior Court, GA Hand printing, paper, pen ink Atty Dana Diment, Diment Carroll, LLP, Carrollton, GA

Deposed by Ray S. Smith III, Atlanta, GA

144. 14-15 February 2013 Springfield, GA - Estate of Byron Stauffer (client Kit Yarbrough)

Signatures; ink; paper Testimony-Effington County Superior Court, Springfield, GA Identified signature; Attorney Craig S. Bonnell, Rincon, GA

Described ink flow in paper


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143. 2 August 2012, Buchanan, GA - Re: Estate of Sandra Lynnelle Harrison

Signature, handwriting Probate Court Hearing, Haralson County, GA

Atty Glen E. Stinson, Dallas, GA

142. 16 July 2012 Atlanta, GA - Eugene F. Assaf V. Gerald Bernard Stein

Signatures, hand printing Deposition for State Court of Fulton County, Atlanta, GA Identified signatures Civil Action File No. 10EV010808E

Atty Judy Aust (Goodman McGuffey Lindsey & Johnson LLP)

Opposing Atty James A Rice, Jr., PC, Atlanta, GA)

A comprehensive listing of all 171 times I have testified as an FDE expert is available upon request.