Case 1:18-cv-03202-DKC Document 48-20 Filed 07/22/20 Page 7 of 12 Avi T. Kamionski May 15, 2020 Page 6 of 9 EXEMPLARS OF GREGORY S. MACGILLIVARY (continued) M-6: Police Department Baltimore, Maryland Information Sheet containing the known handwriting of Detective Gregory S. MacGillivary, dated 8/22/02. Original. M-7: Police Department Baltimore, Maryland Information Sheet containing the known handwriting of Detective Gregory S. MacGillivary, dated 8/10/02. Original. M-8: Police Department Baltimore, Maryland Information Sheet containing the known handwriting of Detective Gregory S. MacGillivary, dated 7/11/02. Original. M-9: Police Department Baltimore, Maryland Information Sheet containing the known handwriting of Detective Gregory S. MacGillivary, dated 7/5/02. Original. M-10: Police Department Baltimore, Maryland Information Sheet containing the known handwriting of Detective Gregory S. MacGillivary, not dated. Original. EXAMINATION CONDUCTED: The first step in the examination of handwriting is to determine if the questioned writing contains enough complexity to make it difficult to copy. Complexity is measured by the number of changes of direction of the writing line and the intersections that occur in the signatures. The exemplars are then compared to the questioned writing to determine if they are suitable for comparison. Suitability is based upon the same type of writing, signatures to signatures, handwriting versus handwriting, and handprinting compared to handprinting although some similar characteristics can be found when comparing handwriting to handprinting and signatures. Ideally, exemplars should be written within two years of the questioned handwriting although some writing samples outside the two-year range can also assist us in making a determination. All of the handwriting characteristics are then compared between the questioned and known writing to determine if the handwriting is genuine, disguised or simulated. The handwriting was examined and compared using magnification. CONCLUSIONS: Based on our education, training and experience and on the examination of the questioned document and comparison with the known documents submitted, it is our opinion that the questioned document is not authentic and is rather a fabricated document. This opinion is based on the following: 1. Each of the two-page known “Baltimore Police Department” reports have their own unique identifying number located on the lower right-hand corner of both pages of the document. The questioned document, however, has the same identification number as an existing document. Q-1: K-4A: Report of Katherine M. Koppenhaver and Diana J. Mears Case 1:18-cv-03202-DKC Document 48-20 Filed 07/22/20 Page 8 of 12 Avi T. Kamionski May 15, 2020 Page 7 of 9 K-1A: K-2A: K-3A: Page 2 of K-4A is a blank, not yet filled out, BPD report. As such, Q-1 was created by typing onto page 2 of another copy of K-4A labeled as K-4B. 2. The signature of Sgt. Garnell Green that appears on the Questioned Document was not written by Sgt. Garnell Green and therefore is not genuine. We can reach this conclusion because the signature of Sgt. Garnell Green on Q-1 is a simulation from the document labeled K-5. There is tremor in the Q-1 signature, a lack of pressure patterns, and blunt endings. These features in a signature are all indicative of a copying process. These charts below showcase these defects in Q-1. Q-1 12/10/02 K-5 7/7/02 Additionally, Q-1 was written at a slower speed than K-5, deliberate care was given to the formation of some letters such as the “g”, “G”, and “e” as well as dark, round dots in the initials of Q-1 not present in K-5. 3. The questioned signature of Detective Mark E. Veney that appears on the Questioned Document is not a signature. It is a hand printed name. It was not written by Detective Mark E. Veney and therefore is not genuine. An example of Detective Veney’s known signature is V-5 and an example of Detective Veney’s known hand printed name is V-11. Q-1 V-5 06/02/02 Report of Katherine M. Koppenhaver and Diana J. Mears V-11 05/11/02 Case 1:18-cv-03202-DKC Document 48-20 Filed 07/22/20 Page 9 of 12 Avi T. Kamionski May 15, 2020 Page 8 of 9 The known handprinted last name of Det. Veney from (V-11) has lowercase letter, “e.” Questioned signature (Q-1) has capital “E”. The “V” in Q-1 is narrower and the right side of the “V” is taller. The final stroke of the “N” in Q-1 is diagonal and connects to the letter “Y” and then the letter “E” was added between the “N” and “Y”. Document Q-1 contains more angles in the letter forms than in V-11. Furthermore, M-8 contains the known writing of Detective Gregory S. MacGillivary found in the Baltimore Police Department (BPD) Homicide file. Detective Gregory S. MacGillivary filled out the complete form and signed his own signature on the bottom left corner. Det. MacGillivary also wrote “VENEY” on the bottom right corner. It should be noted that “VENEY” on M-8 appears to be the model that was used to create “VENEY” on Q-1. Although, M-8 was used as the model, the “VENEY” on Q-1 was not created by the same person who wrote “VENEY” on M-8. The features of each letter are different and there is evidence of tremor, lack of pressure patterns, and blunt endings, indicative of a copying process. The speed in Q-1 is slower than in M-8. Also, Q-1 is more angular than M-8. 4. Q-1 M-8 The questioned document was created from an existing document from the State’s Attorney’s Office (K-4B) as demonstrated in the attached 1½ page table. The second page of K-4B was empty with no content filled in. It is that page that was used to create the questioned document. ***SEE TABLE ATTACHED*** 5. Furthermore, the D.O.B. on the upper right corner of the questioned document is handwritten. It was written very carefully to make it appear as if it was typewritten, particularly with the number 4. Also, the 1’s has serifs. 6. On February 21, 2020 Katherine Koppenhaver and Diana J. Mears went to the Baltimore Homicide Unit and reviewed the files for 02H0131 consisting of two books. Katherine reviewed Part 1 consisting of 560 pages front and back covers included. Diana reviewed Part 2 consisting of 296 pages front and back covers included. The questioned document was not found in either book. COMMENTS: In order to establish that a questioned signature was written by a particular person, an examination with known genuine signatures must show substantial agreement in sufficient handwriting characteristics to identify the maker and eliminate the possibility of any other writer. The handwriting characteristics that are evaluated include line quality, pressure patterns, rhythm, slant, size and proportions, utilization of space and spatial alignment, initial and terminal strokes, writing speed, legibility, skill level, letter forms, types of connectors, method of construction, and pattern formations. Report of Katherine M. Koppenhaver and Diana J. Mears Case 1:18-cv-03202-DKC Document 48-20 Filed 07/22/20 Page 12 of 12 State’s Attorney’s Office Copy Compared to Questioned Document STATE’S ATTORNEY’S OFFICE QUESTIONED DOCUMENT K-4B Dated 07/03/02 or 07/05/02 3 pages not 2 separate sets Has Hole Punches (Green Arrows – 3 on left) Note: Holes do not penetrate the margin as far as K-5A above Has Trash Marks (Red Arrows) Q-1 Dated 12/10/02 Has Hole Punches (Green Arrows – 3 on left) Note: Holes in same position as K-4B and not K-4A above Has Trash Marks (Red Arrows) CASE #3502 PREPARER: DJM