-KZ tells the state in her motion that presumptive tests do not have the specificity to allow definitive identification of body fluid. Confirmatory tests are required to provide the scientific foundation for making a definitive statement as to the presence of the tested body fluid.
In the motion KZ says that there were some items that had gone through presumptive testing. She also says there were items that were not tested at all, no presumptive or confirmatory test done.
KZ says that no presumptive blood testing was performed on the bullet or fragments that were found in the garage. NO presumptive testing and NO confirmatory testing done on the bullet. SC knew it was TH's DNA on the bullet but would not say where the DNA came from. She had no idea if it was blood or spit or cells from a pap smear.
KZ says that based on BD's coerced confession, a swab was taken from the hood latch of the victim's car. She lays out how BD did not mention anything about SA touching the hood latch until asked the question by factbender. Again, no presumptive or confirmatory tests were performed on the swabs from the hood latch. (Zellner said when filing the motion she expects the testing will reveal that there is saliva on the hood latch, possibly with some microscopic fibers from a cotton swab)
KZ wants these follow up tests done: Body fluid source testing, radio carbon testing, DNA Methylation. KZ wants to test items from the RAV4 (prop bar, battery cable, interior hood release, the blinker light, the lug wrench, the blood swabs / stains). These items were never tested.
Body fluid source testing (confirmatory test): KZ will be able to use the wash from SC bullet fragment test and determine what type of cells are present. The state will be hoping the test comes back as DNA mixed with hemoglobin = blood. KZ is expecting epithelial cells or perhaps cells from a pap smear on the bullet. (This one excites me, I was positive there would be no way to determine if the bullet was planted due to SC washing the bullet.)
KZ will also perform body source testing on the hood latch swab. She mentions again that no presumptive testing was done on the hood latch, even though such tests should have helped the states case. KZ is looking to find buccal cells (nucleated / lack of keratin) as opposed to skin cells (anucleated / keratinized).
She also wants to test the RAV-4 key - body source testing again. Is it sweat, blood or saliva on the key? Would it add up to the states theory if saliva is on the key and hood latch?
She wants to test the latent ridge impressions (fingerprints) from the RAV for DNA. This is a new test. She states that not all latent prints have DNA, but as the test was not available in 2007, the answer to whose fingerprints they were has not been solved.
She wants to use Radiocarbon 14c testing to determine the age of the blood in the RAV-4. They will carbon date a single cell, or even DNA extracted from a single cell, allowing the lab worker to determine when the blood sample was taken. If the blood is fresh (SA guilty) the carbon level will have a 14c/c that matched the corresponding carbon levels from 2005. If the blood was planted from an older sample (1996 vial) the 14c/c profile of the blood sample will show an age much older than 2005.
KZ mentions in the motion (almost as an after thought) that the Carbon 14c test can also detect petroleum like products such as EDTA.
14c testing has been extensively tested and validated. C levels have steadily dropped in recent decades allowing for amazingly accurate year by year specificity when testing an unknown sample.
She even has a plan, should the samples be too contaminated for radio carbon testing. DNA methylation is her plan B. It is another age test for the blood that depends determining if the cells from the vial and the cells form the RAV have gone through the same number of 'divisions' meaning the blood is the same age, and not over 10 years older.
She wants the buccal swabs taken from SA, she will test them to see if there was any transfer of trace material when the evidence was planted.
KZ, in the motion lists everything she needs, she lists how many nano-grams of DNA should be remaining. I believe it would be very hard to switch out the swabs and somehow ensure the exact same amount of trace material / DNA is on the new swab. I am confident if the state has tried anything funny in the last 10 years, these tests will show us what it was. She lets the state know that everything will be video recorded, including when the evidence arrives at said lab.
I don't think it matters how much the state tries to **** around with the evidence. If there was any tampering back in 2005. The test will catch it, if there was any tampering since she filed the motion, the tests will catch it.
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Items included in motion that were not mentioned above:
Advanced DNA testing all around. Pelvis bone source testing, license plate, purple thong underwear, JL and AC fingerprints, scrapings of all blood stains from the car / trailer, advanced ballistic testing for bullet fragments, and finally, she wants access to the 1996 vial.
I think that is it. Hopefully they agreed to testing more than the blood swabs.
Thanks too Hypertoxicity from TTM-Reddit.