February 19, 1998

James Crist
Steinhagen and Crist
5200 Willson Road, Suite 314
Minneapolis, MN 55424
RE: Dunlap v. Chubb Life Insurance Company of America
Dear Mr. Crist,
I have reviewed multiple items related to the above styled case, including an autopsy
report, a letter addressed to a Mr. Sonneysyn from Dr. Daniel Davis, a curriculum vitae of
Daniel Davis, M.D., a case supplement of the Minneapolis Police Department related to
the aforenoted case, photographs taken during the autopsy of the decedent Anne Dunlap,
an affidavit of Sergeant David Voss, as well as scene photographs. I additionally received
a video tape which I have nofviewed at the time of the preparation of this letter.

It is my understanding that the decedent was found in the trunk of a car which was located
in a parking lot of a business. · The decedent had sustained multiple stab wounds.
The autopsy report is thorough regarding injuries, articulate, and emblematic of the good
reputation of the medical examiner's office in Minneapolis.
As I have related verbally to you, I have several observations regarding this case. First,
the stomach contents are not determinate of a time of death. Attempting to ascribe a
precise time of death based upon the appearance of stomach contents is not in keeping
with good forensic practice. An article that was written by Jaffe in the American Journal
of Forensic Medicine and Pathology details some reasons that relying upon stomach
contents to define a time of death implies a false sense of accuracy. He makes the
statement, in the abstract of the article as follows: "Generally, using stomach contents as a
guide to time of death involves an unacceptable degree of imprecision and is thus liable to
mislead the investigator and the court". (Stomach Contents and the Time of Death,
American Journal ofForensic Medicine and Pathology, 10(1):37-41, 1989.) This belief
has indeed been borne out in my experience. There is a tremendous diversity in emptying
times of stomachs among individuals, and variation within a particular individual given
certain circumstances such as stress factors. I have seen recognizable stomach contents
within the stomach days after an individual had eaten anything (while hospitalized wit~ an
endotracheal tube in place). Such cases reflect an adynamic state of the intestine due to
the tremendous stress of the underlying illness. Consequently, one may say what a person
had for a last meal, if the stomach contents are recognizable, but a precise time of death
cannot be assigned. In the present case, there is no validity to ascription of a time of death
to a thirty minute window of the afternoon, as the death could have occurred sometime
during the evening. Such factors as the size of a meal, the potential stress that the
individual experienced, and other factors all need to be taken into consideration in the
recognition of the imprecision of assigning the time of death based upon stomach contents.

 Secondly, I do not believe that the decedent was stabbed in the back of the vehicle. I have
examined numerous scenes in which people have died as a result of penetrating or
perforating injuries. The blood distribution in the car is inconsistent with arterial spurting
as would occur with a transection of a carotid artery, or any significant size arterial vessel.
Further, the small drops of what appears to be blood on the floor of a garage in the
pictures that I have examined are inconsistent, in my opinion, with arterial bleeding.
We have discussed the potential aging of blood spots. As I have related verbally to you, I
am unaware of any accepted technique for aging dried blood, in terms of how long that
blood has been on a particular surface. Such work may exist, but I have not seen it in our
literature, and am extremely skeptical regarding the ability of anyone, regardless of
technique, to be able to say within a two to twelve hour window of when blood was
deposited.

In summary, the time of death in this case, in my opinion, cannot be based upon stomach
contents. The stomach contents only indicate what the individual had for her last meal.
Additionally, it is my opinion, there is not evidence of arterial blood spurting within the
trunk of the car. Consequently, it is my opinion that the fatal stab wounds were incurred
in some location other than the trunk of the car.

If I can be of any further assistance, please let me know.
Sincerely,

/M~t;:J

5-parks Veasey, M.D.
Forensic Pathologist
Director, Autopsy Service