MR. MANDEL: United States would call Kimberly Edwards, Your

Honor.

KIMBERLY EDWARDS, called as a witness, being first duly sworn,

testified

and said as follows:

DIRECT EXAMINATION BY MR. MANDEL:

Q. Would you state your name, please?

A. My name is Kimberly Edwards.

Q. Where are you employed?

A. I am employed by the latent fingerprint unit of the FBI.

Q. Where is that located?

A. In Quantico, Virginia.

Q. Do you have a specific title there?

A. My title is physical scientist forensic examiner.

Q. And do you specifically do fingerprint work among other things?

A. That's correct.

Q. How long have you been employed doing fingerprint work?

A. Just about four years.

Q. Can you tell us what your duties are in that regard?

A. I receive and inventory evidence, process the evidence

for presence and development of latent prints. I can then

compare those prints to the known prints of individuals.

Additionally I work with the hands and fingers of unknown

deceased in an attempt to effect their identification.

Q. How long have you been employed -- excuse me. Give us

your educational background, please?

A. I received an undergraduate degree in mathematics and

biology from the University of Virginia, Masters Degree from

University of Maryland at College Park in biological resources

and engineering.

Q. Did you also receive specific training regarding fingerprints?

A. I did. I completed a two year training program with the

latent fingerprint unit with the FBI.

Q. So we understand, although I think we do, explain to us

what a fingerprint is as it is used forensically?

A. On the palmar side of the hand and soles of your feet

there is raised portions of skin, this is known as friction

ridge skin. A fingerprint is typically what is indicated as

the friction ridge skin that is present on the end joint of

the finger, usually recorded in black ink, and rolled across a

contrasting card such as a fingerprint card.

Q. Is there a specific methodology that's used to compare fingerprints?

A. We utilize a methodology known as ACV, which stands for

Analysis, comparison, verification. The analysis portion we

look to see what identification is present in a print, the

ridge flow, pattern type, and presence of characteristics such

as the end of a ridge, dividing ridge and a dot. The

comparison portion we look at both prints to see if the same

information is present in the both prints with out an

explainable difference. In the evaluation phase we make a

determination if the two are from the same source. The last

step, the verification phase, a second qualified examiner

reviews the identification.

Q. Can you tell us what the basic factors are in the use of

fingerprints as a means of identification?

A. Fingerprints are both permanent and unique. They are

permanent in that they form prior to birth and remain

consistent throughout an individual's life barring any deep

scarring. They are unique in that the environmental and

genetic factors influence the formation of the friction ridges

and thus are unique to an individual.

Q. I believe you indicated that one of the things you

specialized in was the identification of individuals who were

deceased?

A. That's correct.

Q. Can you tell us if there are particular problems that

arise obtaining fingerprints from deceased individuals in general?

A. Well, there is a number of issues relative to the

condition of the hands or fingers of an individual based on

how long that person has been deceased, or where the body was

located.

Q. What types of problems?

A. Those factors might involve if they were in a very dry

or, dry area, then the fingers could be almost mummified. If

it is in a humid or wet area, they may decompose much faster.

If they are water logged or burned, that also can be a factor

in the condition of the fingers.

Q. Are you familiar with a technique whereby the hands of

the decedent are sometimes severed and sent in to the lab in

an effort to effect an identification?

A. Yes.

Q. Have you ever had the circumstance to work on any hands

in that situation?

A. I have.

Q. On how many occasions?

A. Approximately I would say three or four times that's occurred.

Q. In total how many such identifications does the FBI

laboratory perform in a year?

A. The laboratory receives about nine to ten sets of hands

or fingers per year.

Q. And particularly why is that technique used, what is the

purpose of that, what does it enable you to do that couldn't

other wise be done?

A. We have the necessary tools and chemicals that we can

use in order to deal with hands or fingers that may not be in

optimal condition. The ideal condition would be you could

actually take the finger and record it, but due to the factor

I mentioned earlier, sometimes it's a little bit more

difficult. And we have a number of procedures and techniques

that we can follow to aid in the recording of the friction

ridges on the skin -- that's on the fingers, excuse me.

Q. Obviously you were not working for the FBI laboratory 28

years ago?

A. No.

Q. But did you review the file that was done in terms of

the identification of Anna Mae Pictou-Aquash?

A. I did.

Q. I will ask you first of all if you can tell from your

review what took place in that case to effect an identification?

A. Yes, I was able to do that.

Q. What was that?

A. Based on the photographs that were maintained in our

files, there is an indication that the fingers were placed in

a material called Duplicast, which is a material that is

similar to epoxy where you mix two liquids and they then

solidify in a short amount of time, and that way the fingers

can be impressed into the material. The material hardens and

you are left with a cast of the friction ridges on the fingers.

Q. Then what is done after you make that cast?

A. The casts are then photographed, and each individual

finger that is represented is, that photograph is placed in a

ten print block on a fingerprint card.

(Exhibits 40-41 marked For identification.)

Q. I will ask you to look at two Exhibits I have placed ir

front of you, Exhibits number 40 and 41. First of all, can

you tell us what Exhibit No. 40 is?

A. Exhibit No. 40 is a photograph of the impressions that

were made from the hands that were submitted in this case.

And Exhibit No. 41 is the template card bearing the name Anna

Mae Pictou from our files.

Q. That Exhibit 41, was that what is referred to as the

known set of prints?

A. Known set prints, yes.

MR. MANDEL: I offer Exhibits 40 and 41 at this time.

MR. RENSCH: No objection.

THE COURT: Exhibits 40 and 41 are received. I

think this might be a good time to take our morning break. So

remember what I have told you before, members of the jury,

don't talk to each other about the case, keep an open mind

until you have heard all the evidence. Thank you, we will be

in recess for fifteen minutes.

(Recess at 10:25 until 10:45 ).

THE COURT: Re-take the stand, please.

BY MR. MANDEL:

Q. In preparation for your testimony here today did you

review the file in this matter?

A. Yes, I did.

Q. First of all, from the file review did it indicate that

an identification was made in this case?

A. Yes, it did.

Q. Are you able to see that okay on the monitor?

A. Yes.

Q. I have put what has been marked Exhibit No. 40 on the

monitor. Can you tell us what that is, and based on your

review of the file how that was prepared?

A. This is the photograph of the card that was created from

the impressions of the fingerprints of the hands that were

submitted. These are actual individual photographs of each

finger that are taken and then placed on the template card,

and the template card is photographed as a whole. Once you

have all ten fingers present, the card is then classified,

this is known as a Henry classification. Prior to when we had

computer data bases, all fingerprint cards received Henry

classifications. Those are what the numbers are up in the top

on the right side in the block where it says 19. All of that

information is derived from the pattern types and the

classification of the fingerprints on the card. This card

would have been then sent down to the technical section where

based on this classification they would have manually searched

through the fingerprint cards on file. At that time when

someone down there found one that matched the classification,

it was sent back up to the latent examiner who compared the

template card.

Q. The FBI even at that time had a lot of fingerprints on file, right?

A. That's correct.

Q. In the millions?

A. I would say tens of millions probably.

Q. How long does it take to do a comparison of that type in general?

A. In general it would depend really on how unique the

classification is. For example, the most common pattern type

is loops, so if a person has all loops, it may take a little

longer to search manually through the files. But there is

also information such as how many ridges between two areas of

the fingerprints, that kind of information can help break down

the number of files that need to be searched through. In this

case it was a female, and I believe only 20 percent of the FBI

files are of females, so that again reduces the number of

people that would need to be manually compared to.

Q. I notice on that card there is some numbers written in

the upper right-hand corner of each of the prints that is

shown there?

A. Yes, those are the indications of the ridge counts and

pattern types that are present in those fingers.

Q. When this fingerprint card was sent into the FBI lab,

was there any information that is in the lab record as to who

it might have been, who in particular to search for as possibilities?

A. Well, this card would have been created by the lab, it

would have been --

Q. Excuse me, actually when the hands were sent in to

produce the fingerprint card?

A. Based on the work sheet from the original examiner there

was a phone call on the 2nd of March from Special Agent Wood.

Q. Is this a type of record that you normally keep in these

lab files?

A. Yes. Any case that comes in the examiner works, they

keep a work sheet on what steps they have taken in that case.

Q. So at any time, for example if you are working on a case

when a call would be made in by the agent, you would make a

notation in the file reflecting that?

A. That's correct.

Q. In this case were these, were names provided as possible

comparisons that should be checked on as to who it might have been?

A. In this case there was a phone call made stating that

these could possibly be an individual by the name of Donna Sue Fiedler.

Q. Any other names other than Donna Sue Fiedler?

A. There were some aliases of that individual listed as

well. In fact, at a later time they submitted her fingerprint

card in the event we would need it for comparison purposes.

Q. Then was there a comparison done between Exhibit 40 then

and Exhibit 41?

A. Yes.

Q. Can you tell us what Exhibit 41 is again?

A. Exhibit 41 is a photograph of the fingerprint card that

was retrieved from our files based on the classification of

the fingerprint card created from the hands that were

submitted. So these are the cards from our files.

Q. At the time that the original comparison was made, was

determination made that the prints in Exhibit 40 and 41 were

from the same individual?

A. Yes, there was.

Q. Who was that individual?

A. This card bears the name Anna Mae Pictou, and it was

recorded, the fingerprint identification listed an individual

Anna Mae Aquash.

Q. That known card, was that a card that was actually made

during a processing in the Marshals office?

A. This would have been the card that was made when she was

fingerprinted at some time, yes. I would need to refer to

when exactly it was recorded.

Q. Is the date reflected on the card?

A. I have a hard time seeing it on the screen. Looks like

September 5, 1975.

Q. Were you also able to conduct your own examination and

do a comparison between the two sets of prints?

A. Yes.

Q. In your opinion was the original conclusion correct that

these were the same individual?

A. Yes.

MR. MANDEL: I have no further questions, Your Honor.

THE COURT: Cross exam.

MR. RENSCH: No questions, Your Honor.

THE COURT: Thank you, Ms. Edwards, you may step

down. Call your next witness.