Category: Investigative Resource Repository

District Attorney’s Office, Denver, CO

People’s Response to Defense Motion to Dismiss for Pre-Indictment Delay (Colorado v. Cumberbatch)

Charges for a 1994 homicide brought in 2020 only when advances in forensic capabilities led to a DNA ‘hit’ of the defendant in the Combined DNA Index System in 2018. The following claims were made by the defense: 1) statute of limitations (found to be not applicable to first-degree murder charge), 2) state’s failure to preserve evidence (addressed and rejected), 3) unavailability of witnesses and “other suspects” due to lapse of time (addressed and rejected), and 4) constitutional due process violation (rejected due to no constitutional right to a “speedy arrest”).
District Attorney’s Office, Denver, CO

People’s Motion in Limine (Colorado v. Cumberbatch)

Prosecution’s motion in limine in a 1994 Colorado murder-sexual offense case. The prosecution sought to admit several “sanitized” police contacts with the defendant in Denver in 1994. This motion in limine was an attempt to limit prejudicial elements of the police contacts.
Investigative Resource Repository

Maryland Criminal Procedure – Forensic Genetic Genealogical DNA Analysis and Search – Applicability for Deceased and Missing Individuals

The Maryland General Assembly enacted an amendment (effective October 1, 2024) to the comprehensive statute limiting the application and use of Forensic Genetic Genealogical DNA Analysis and Search (FGGS) set forth in Title 17 of the Criminal Procedure Article of the Annotated Code of Maryland, excluding steps taken using FGGS to identify unidentified human remains from coverage of Title 17. This comprehensive statute was originally enacted, and took effect, on October 1, 2021.
Investigative Resource Repository

Washington v. Miller – Case Documents

1) Affidavit of Probable Cause
2) Defendant’s Motion to Exclude Evidence
3) Defense Trial Brief and Motions in Limine
4) State’s Response to Defense Motions
Investigative Resource Repository

State’s Response to Defense Motions (Washington v. Miller)

Prosecution addresses four evidentiary issues raised in the case including: 1) relevance of jail calls made by the defendant, 2) access to firearms, 3) newspaper articles, and 4) statistical probability not necessary pertaining a to female fraction in a differential extraction.
Investigative Resource Repository

Family Tree Memo (State of Maryland v. Biagas)

An example of the completion of a family tree build-out established as part of the Forensic Genetic Genealogy investigation within a Maryland homicide case.