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1 A I have, sir.

2 Q And there's been a number of studies that have been

3 published, peer reviewed, criticized and then eventually

4 rectified and published in -- in journals that you rely

5 upon.

6 A Yes.

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7 Q Your lab relies upon, other experts that are here in

8 the courtroom rely upon; correct?

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9 A Correct, and supplied you

10 Q And a secondary transfer, for instance, would be this

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11 ia
pen that I've been writing with all day.
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12 A Uh-huh.

13 Q And a secondary transfer would be -- would be that, for

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14 instance, if I've been writing with the pen all day and I
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15 give it to you and you hold it.

16 A Yes.
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17 Q You then could set the pen down and go pick up a cup;
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18 correct? And if you picked up the cup and you swabbed that
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19 cup you could find my DNA on that cup although I' v e nev er

20 touched it.

21 A It's possible, yes.

22 Q And that would be a secondary transfer, would it not?

23 A Correct.

24 Q And you would agree with me that secondary transfers, a

25 lot of times it's the items that you touch whether or not

DISTRICT COURT OF OKLAHOMA -- OFFICIAL TRANSCRIPT