Page 2 of Reasonable Doubt

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“Where are you employed?”Focus on the questions, he told himself fiercely,not on her delectable mouth.

“The crime lab for the city of San Diego,” she replied and licked her lips as if she’d heard his thoughts.

“What is your job title, and what are your duties?”

“I’m a Criminalist III. My duties include examining, testing, and analyzing tissue samples, chemical substances, physical materials, and ballistics evidence. I interpret laboratory findings and tests, along with collecting and preserving criminal evidence. I confer with ballistics, fingerprinting, handwriting, electronics, medical, chemical, or metallurgical experts. I reconstruct crime scenes, prepare reports or presentations, and provide expert witness testimony on evidence or laboratory techniques in trials or hearings.”

“What education do you have that qualifies you to perform these duties?” He put his hand on the edge of the witness stand and came within a hairbreadth of hers. The heat from her skin reached out to his and he instantly pulled his hand away, resolving to keep his cool.

When she started, her voice was breathless, but it firmed as she spoke. “I hold a Bachelor of Science in Biochemistry and Chemistry from the University of California at San Diego and a Master of Forensic Science from George Washington University. I also continue to participate in ongoing training.”

“Approximately how many times have you testified regarding DNA profiling in court?”

“Hundreds.”

“Can you explain to the court what DNA is?”

“DNA, or the scientific term deoxyribonucleic acid, is a very long, complex molecule that is located in the nucleus of each cell in the human body.”

She continued and he had to admire the way she expertly described a complicated process for the easy comprehension of the jury.

As she continued, Jericho noted how she made eye contact with the jury and periodically him and the defense attorney.

“How does this scientific information result in DNA fingerprinting?” Jericho asked, moving closer to the jury and making eye contact with each member. He was gratified to see that they were riveted to Kate’s description and her testimony. It was imperative that she keep the explanations simple.

She smiled easily and launched into her response. “The chemical structure of everyone’s DNA is the same. The only difference between people is the order of the base pairs. There are so many millions of base pairs in each person’s DNA that every person has a different sequence.”

“And this allows you to perform DNA fingerprinting?” Jericho prompted.

“No. These patterns do not, however, give an individual ‘fingerprint,’ but they are able to determine whether two DNA samples are from the same person, related people, or nonrelated people. Scientists use a small number of sequences of DNA that are known to vary among individuals a great deal and analyze those to get a certain probability of a match.”

“Are there tests available to detect an individual’s genetic type?”

“Yes.”

“What test was used in this case?”

“Restriction fragment length polymorphism or RFLP. Scientists can analyze the genetic patterns which appear in a person’s DNA.”

“Is this test used in other fields?”

“Yes, in medical diagnostics, paternity testing, or for the identification of missing persons.”

“Can you explain briefly how the test is conducted?” When Kate finished with the brief explanation, he checked the jury again and was gratified to see they still hung on her every word.

“Are controls performed to ensure that a reliable and accurate result is obtained?”

“Yes.”

“Can you describe the safeguards and controls used to ensure the integrity of the test?”

“Procedures are in place for careful collection of samples, a documented chain of custody, and strict guidelines for handling of DNA samples in the lab.”

“Did you conduct a DNA test on the crime scene and reference samples in this case?”

“Yes.”

“What were the results of the test?”


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