Gale Green- Direct and Cross examination questions

Law mock trial witness statements

Please state and spell your name for the record

My name is Gale Green, G-A-L-E space G-R-E-E-N

What is your occupation?

I’m a forensic document examiner.

Are you qualified to be a forensic document examiner?

Yes I am, I have a master’s degree in forensics. To become a forensic document examiner I had to complete a two-year training program in an established lab. Additionally, I am certified through the American Board of Forensic Document Examiners.

What is an established questioned documents labratory?

A facility that analyzes documents for their authenticity. 

What is your occupational background?

I have 11 years of experience in forensics, particularly with a focus on forensic document examination. Eight of those years have been spent examining documents for the police department, and over the past three years, I have worked for my own consulting business. I examine forensic documents for my clients and testify in trials regularly.

Why were you hired for this examination?

The defense hired me to determine if Jamie Hayes wrote an anonymous letter to campus Security.

What was your process when examining the anonymous letter to the defendants?

First I examined the anonymous letter for identifiable characteristics then I examined the defendant's writing samples for similar and different characteristics. Lastly, I placed each of the samples under a magnifier for further examination.  

What identifiable characteristics did you notice in the anonymous letter?

I found that the anonymous letter had big letters with only a small difference between uppercase and lowercase. The pressure strokes were moderate to light and there was a slight slant to the left. The letters were not connected, and the ends of strokes pointed upwards. The cross strokes were also light. It's very unlikely that more than one person would have all these traits in their handwriting.

What did you discover when comparing the anonymous letter’s handwriting to the defendant's?

First I noticed that Jamie’s writing was lighter and had spacing patterns in certain letter combinations compared to the anonymous letter. His end strokes were less distinct and shorter, sometimes trailing off laterally or to the side rather than going upward like the anonymous letter. Also, while the anonymous letter had consistent pressure on cross strokes Jamie's were significantly lighter.

What are the chances of Jamie Hayes writing the note?

Since the differences far outweigh the similarities between the disposal examples and the handwritten note; it is my professional opinion that the note does not positively match Jamie’s writing. Thus Jamie did not write the handwritten note. 

Why do you believe that computers should not be used while examining evidence?

My mentor was a very well-respected document examiner, and it was his belief as well as mine, that computers will never be able to do the work of a trained eye. So I trust my conclusions more than I would trust any computer.

What similarities did you notice between the anonymous letter and Jamie’s writing? 

Beyond my scope

You rely solely on visual examination without using computers. Can you explain why you believe that your trained eye is superior to the technology?

I believe that the human eye can detect subtleties in handwriting that a computer might miss, such as the pressure variation in strokes or the unique flow of letters. My training and experience enhance my ability to notice these details.

How do you determine which characteristics are most significant in your analysis?

I prioritize characteristics based on their frequency and distinctiveness. For example, I focus on pressure patterns and letter connections because they are least likely to overlap between individuals.

What standards or guidelines do you follow to ensure the reliability of your conclusions?

I follow the guidelines set forth by the ABFDE (American Board of Forensic Document Examiners) and other professional organizations, which emphasize the rigorous standards set forth for analysis, documentation, and reporting in forensic document examination. 

You’ve testified as an expert in other cases, haven’t you? How many of those cases were for the prosecution/defense?

My work has been evenly divided between the prosecution and the defense. Over the past 3 years, I have testified in 15 depositions and 12 trials.

What kind of qualifications do you have in this field? 

I have 11 years of experience in forensics, particularly with a focus on forensic document examination. Before my career in forensics, I worked for 16 years as a police officer in Colorado. I examine forensic documents for my clients, and I testify in trials regularly.

Handwriting analysis is a subjective field, right?

Although certain aspects of the field are subjective I use the American Board of Forensic Document Examiners guidelines to ensure the validity of my findings. Additionally, due to my 11 years of expertise and the accepted standards I follow in the field the evidence and opinions I provided are reliable.

Can you confirm that your judgment is 100% correct?

I can’t confirm that my judgment is 100% correct but I am a respected certified fraud examiner so I can confirm that the evidence I found is trustworthy.

Can’t handwriting change depending on mood or physical condition? 

Yes, handwriting may change depending on mood or physical condition but since I was given multiple writing from the defendant, certain distinct characteristics appeared in the same 3 samples. 

There is always some margin of error or human error when determining handwriting, correct?

There is always some margin of error when determining handwriting but it is highly unlikely due to my high level of expertise and experience in forensic documentation. 

Why does your background as a police officer affect your approach compared to someone specialized in handwriting analysis?

My background as a police officer does not affect my approach to handwriting analysis.

Do you use computers for handwriting analysis?

no

Why don’t you use computers for handwriting analysis?

I have extensive knowledge in the field and I trust my trained eye more than I would trust any computer

Do you think relying on human analysis introduces bias or error into your analysis?

No it does not. Although humans can make mistakes due to my extensive experience in the field it is highly unlikely that I will make one.

Could the discrepancies in Mr. Hayes's handwriting be due to the stress of providing a sample in a police setting?

No, the differences in Mr. Hayes handwriting are unlikely due to the stress he was under. Handwriting features like spacing and end strokes are typically consist even under stress.

Why didn’t you consider that slant differences in handwriting could be due to disguise attempts, as our handwriting experts suggested?

I didn’t consider the slant differences as disguise attempts because they seemed like natural variations in Jamie’s writing, not a clear effort to alter his handwriting.

You were hired by the defense. How can we be sure your analysis is unbiased?

I follow the same procedures and standards whether I'm working for the prosecution or the defense. My conclusions are based solely on the handwriting evidence, not on the side I'm working for.

you admit that Jamie Hayes’ writing did share several characteristics with the anonymous letter, right?

Yes, there were some similarities, but I believe the discrepancies in pressure, slant, and terminal strokes outweigh those similarities.

isn't it true that you might be biased in your analysis since you were hired to support the defense's case?

I would disagree. My professional obligation is to provide an objective, unbiased analysis based on the evidence, regardless of who hires me.

Finally, what is your expert opinion of prosecution witness Dakota Kim's methodology? 

I find it hard to believe the prosecution's handwriting expert could draw reliable conclusions from just one sample. Key discrepancies, like differences in pressure and distinct spacing patterns in Jamie's handwriting, could only be identified by comparing multiple samples. Therefore, Dakota Kim’s conclusions are likely incomplete or inaccurate. 

What’s a forensic document examiner?

Forensic document examiners are like the detectives of forensic documents just as detectives collect evidence like DNA or fingerprints to identify a suspect, a forensic document examiner looks at the nuances of the document in order to determine an author.