Ceglia v. Zuckerberg et al

Filing 197

DECLARATION signed by Larry Stewart re 192 Declaration, 196 Certificate of Service,, 189 MOTION for Sanctions Memorandum of Law in Support of Motion for Sanctions for Spoliation by Defendants filed by Paul D. Ceglia. (Attachments: # 1 Exhibit Attachment 1, # 2 Exhibit Attachment 2, # 3 Exhibit Attachment 3)(Boland, Dean)

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BIO Larry F. Stewart was born in Asheville, North Carolina. He has earned an Associate of Arts degree from Florida Technological University in Orlando, a Bachelor of Science in Forensic Science degree from the University of Central Florida, also in Orlando and a Master of Forensic Sciences degree from Antioch University in Yellow Springs, Ohio. Mr. Stewart has worked for the U.S. Government as a forensic scientist for over 25 years. During that time he has worked on many notable cases to include; the Unabomber, the John Wilkes Booth diary, numerous accused Nazi war criminals, e.g. John Demjanjuk, a.k.a. Ivan the Terrible, the reinvestigation of the Dr. Martin Luther King murder, the reinvestigation of the Kennedy assassination/CIA conspiracy theory, the Quedlinburg Treasure, the 1933 Saint-Gaudens Double Eagle gold coin, the Jon Benet Ramsey murder investigation, the 9/11 terrorist attacks, the DC Sniper investigation and the 2010 Brazilian election fraud. He has testified as an expert witness in state, federal and military courts of law, as well as testified or been deposed in foreign court systems to include; Austria, Australia, Canada, Germany, Sri Lanka, and Thailand. He has also testified at The Hague in the Netherlands and three times before the U.S. Congress. Mr. Stewart most recently held the position of Laboratory Director and Chief Forensic Scientist for the United States Secret Service. In that role, he managed up to 120 scientists, technicians, and support staff in the areas of document analysis, handwriting, fingerprints, trace evidence, audio and video analysis, photography, toolmarks, computer evidence and counterfeit analysis. In 2005, Mr. Stewart began the independent forensic consulting and investigative firm known as Stewart Forensic Consultants, LLC and its subsidiary, Global Investigative & Intelligence Services. RESUME Larry F. Stewart Occupation: Chief Forensic Scientist and President – Stewart Forensic Consultants, LLC San Luis Obispo, California Education: Associate of Arts Degree - Received June 1976 Florida Technological University Orlando, Florida Bachelor of Science in Forensic Science Degree - Received August 1979 University of Central Florida Orlando, Florida Master of Forensic Sciences Degree - Received June 1983 Antioch University Yellow Springs, Ohio Pertinent Specialized Courses: Forensic Microscopy Course - March 1978 McCrone Research Institute Chicago, Illinois Atomic Absorption Spectrophotometry - April 1979 Perkin-Elmer Corporation Gaithersburg, Maryland Gas Chromatography Course - December 1979 Virginia Polytechnic Institute and State University Gaithersburg, Maryland Advanced Gas Chromatography - March 1980 Perkin-Elmer Corporation Advanced High Pressure Liquid Chromatography Course - January 1981 Virginia Polytechnic Institute and State University Washington, DC (course location) Ink and Paper Analysis Seminar - January 1981 U.S. Air Force Office of Special Investigations Washington, DC High Pressure Liquid Chromatography/Mass Spectrometry - July 1981 U.S. Justice Department, F.B.I. Quantico, Virginia High Pressure Liquid Chromatography/Computer Operation - March 1984 Perkin-Elmer Corporation Rockville, Maryland Questioned Document Course - February 1985 U.S. Secret Service Washington, DC Fourier Transform Infrared Spectroscopy Course - June 1986 Nicolet Analytical Instruments Lanham, Maryland Scanning Electron Microscopy - September 1994 Philips Electronic Instruments Mahwah, New Jersey ASCLD/LAB Inspector Training Course – January 2000 Portland, Oregon Work Experience: December 1975 through March 1979 Laboratory Technician University of Central Florida March 1979 through September 1979 Internship Bureau of Alcohol, Tobacco and Firearms September 1979 through July 1982 Forensic Chemist Bureau of Alcohol, Tobacco and Firearms July, 1982 through June, 2005 (retired) Counterfeit Specialist Questioned Document Examiner Lead, Instrumental Analysis Section Lead, Instrumental and Computer Analysis Section Senior Document Examiner/National Expert for the United States Secret Service Chief, Questioned Document Branch Assistant Laboratory Director Laboratory Director/Chief Forensic Scientist United States Secret Service June 2005 to present Chief Forensic Scientist and President Stewart Forensic Consultants, LLC Instructor: Bureau of Alcohol, Tobacco and Firearms Rockville, Maryland United States Air Force, Office of Special Investigations Special Investigator's Course Washington, DC United States Secret Service Washington, DC Federal Law Enforcement Training Center Glynco, Georgia Drug Enforcement Agency Washington, DC International Law Enforcement Academy Budapest, Hungary Naval Criminal Investigative Service Washington, DC Rochester Institute of Technology Rochester, New York Cuesta College San Luis Obispo, California California Polytechnic University San Luis Obispo, California Guest Speaker: Montgomery College October 1980 Rockville, Maryland Antioch School of Law November 1980 and February 1981 Washington, DC Montgomery College Ink and Paper Analysis/Instrumental Techniques - February 1982 Rockville, Maryland DocSec'85 Document Security - May 1985 Washington, DC George Washington University Ink and Paper Analysis - February 1986 Washington, DC Inspector Generals Office - Health and Human Services Tri-regional Conference - January 1991 Mt. Pocono, Pennsylvania Bolling Air Force Base Joint Basic Computer Forensic Workshop - September 1993 Washington, DC Virginia Military Institute The Uses of Chemistry and Biology in the Forensic Sciences - April 1994 Lexington, Virginia UCLA Forensic Examination of Financial and Identity Documents – August 1998 American Society of Questioned Document Examiners meeting Los Angeles, California Catholic University Science Under Oath – February 2000 Washington, DC GATF Conference Security Printing, Computers and the Forensic Scientist – August 2000 Pittsburgh, PA Fraud Prevention Workshop Security Printing – October 27, 2000 U.S. Department of State Ft. Lauderdale, Florida International Association for Identification Forensic Science and Fraudulent Documents – May 2004 Sacramento, California San Luis Obispo Criminal Bar Association Getting the Most from Forensic Technology in Criminal Investigations – December 13, 2006 San Luis Obispo, California California Association of Licensed Investigators Counterfeits Are All Around Us! – February 2, 2007 Palm Springs, California California Association of Licensed Investigators Leveling The Playing Field - December 4, 2008 Pismo Beach, California Specialized Tours/Training: Crane-Weston Paper Mill Dalton, Massachusetts - July 28, 1982 Philadelphia Mint Philadelphia, Pennsylvania - July 29, 1982 Bureau of Engraving and Printing Washington, DC - July 30, 1982 Visa International San Francisco, California - January 3-6, 1984 Malco Plastics Garrison Park, Maryland - January 1985 BIS CAP International, Ink Jet Printing Conference Boston, Massachusetts - September 17-19, 1990 Achievements: Participated as a "referee" in the 1980 Crime Laboratory Proficiency Training Program Forensic Sciences Foundation, Colorado Springs, Colorado Testified in May of 1989 and 1990 before the Subcommittee on Oversight and Investigations of the Committee on Energy and Commerce, U. S. House of Representatives. These matters concerned the investigation of fraud in science. Certified by the US Secret Service as an accredited Examiner of Questioned Documents, February 1, 1991. Recipient of the Health and Human Services Inspector General's Integrity Award, 1991. Appointed Chairman of A.S.T.M. task groups (1991) concerned with developing standards for performing "Writing Ink Comparisons" and "Writing Ink Identifications." United States Delegate at the 14th European Meeting on Currency Counterfeiting, The Hague, The Netherlands, October 9-11, 1991 and the First International Conference on Fraudulent Documents, Ottawa, Canada, April 27- May 1, 1992. United States Delegate at the 6th European Conference for Police and Government Experts, London, United Kingdom, October 2-4, 1996. Presented a paper on Ink Dating, Relative and Absolute: New Approaches to Old Problems. Testified on July 22, 1999 before the House Judiciary Committee, Subcommittee on Immigration and Claims, U.S. House of Representatives. This matter concerned detection and prevention of counterfeit documents. Classified as an “Inspector” for the American Society of Crime Laboratory Directors. Elected to the Board of Directors for the American Society of Crime Laboratory Directors, September 14, 2000. Elected to the Board of Directors for the Document Security Alliance, December, 2003. Appointed as the forensic consultant for the United Nations, tasked with developing and implementing a successful forensic laboratory in Nigeria, Africa, 2007. Elected to the Board of Directors for The Academy, June, 2007. Certified Forensic Consultant, American College of Forensic Examiners Institute, October, 2007. Appointed as a forensic consultant for the US Department of State, Bureau of International Narcotics and Law Enforcement Affairs in Yerevan, Armenia, January, 2008 (ongoing assignment). Appointed as a forensic consultant for the US Department of State, Bureau of International Narcotics and Law Enforcement Affairs in Tbilisi, Georgia, May, 2008. Elected to the Board of Directors for the American Board of Forensic Examiners, February, 2009. Original Research Publications/Presentations: "Detection of Volatile Accelerants in Fire Debris. 1. A Comparative Evaluation... " Richard A. Strobel, Richard A. Tontarski, Larry F. Stewart, Philip Wineman presented at the American Academy of Forensic Sciences, New Orleans, Louisiana, February 1980, and the Mid-Atlantic Association of Forensic Scientists, combined meeting, Louisville, Kentucky, May 1980. "Artificial Aging of Documents," L.F. Stewart. Published in the Journal of Forensic Sciences, Vol. 27, No. 2, April 1982. "Ballpoint Ink Age Determination by Volatile Component Comparison," L.F. Stewart, Presented at the American Academy of Forensic Sciences meeting, Orlando, Florida, February 1982, and Mid-Atlantic Association of Forensic Scientists/Northeastem Association of Forensic Scientists joint meeting, Harrisburg, Pennsylvania, April 1982. Published in the Journal of Forensic Sciences, April 1985. "The Role of the Secret Service in Counterfeit Deterrence," L.F. Stewart. Presented at the MidAtlantic Association of Forensic Scientists meeting, Baltimore, Maryland, April 1983. "The Forensic Analysis of Printing Inks," Larry F. Stewart. Presented at the American Society of Questioned Document Examiners, Lake Tahoe, Nevada, September 1983. "Counterfeit Credit Card Deterrence," Larry F. Stewart. Presented at the American Society of Questioned Document Examiners/Canadian Society of Forensic Scientists annual meeting, Montreal, Quebec, Canada, September 1985. "Detection of Counterfeit Currency," Larry F. Stewart. Presented at the International Association of Identification conference, Arlington, Virginia, August 1987. "Identification of United States Currency Security Fibers by Fourier Transform Infrared Spectroscopy," J.E. Brown and L.F. Stewart. Presented at the Canadian Society of Forensic Scientists annual meeting, Toronto, Ontario, Canada, October, 1988. "U.S. Secret Service Ink Identification System," J.W. Hargett, J.E. Brown and L.F. Stewart. Presented at the Canadian Society of Forensic Scientists annual meeting, Toronto, Ontario, Canada, October 1988. "Use of Enlargement Ratios of Negatives and/or Printing Plates to Characterize Counterfeit Currency," L.F. Stewart, R.L. Outland and J.E. Brown. Presented at the Canadian Society of Forensic Scientists annual meeting, Toronto, Ontario, Canada, October 1988. "Current Status of Ink Age Determination," L.F. Stewart and S.L Guertin. Presented at the Ninth INTERPOL Forensic Science Symposium, INTERPOL Headquarters, Lyon, France, December 12, 1989. Published in INTERPOL International Criminal Police Review, March-April, 1991. "A.S.T.M. Standard for Writing Ink Comparisons," L.F. Stewart and J.L. Becker Presented at the Mid-Atlantic Association of Forensic Scientists 1991 meeting, Bethesda, Maryland, May 31, 1991. "Standard Guide For Test Methods For Forensic Writing Ink Comparisons," L.F. Stewart (Task Group Chairman). Published in the American Society For Testing and Materials (ASTM), Standard Designation number E-1422-91, November 1991. "Counterfeit Documents Produced by Color Copier Systems," L.F. Stewart, Presented at INTERPOL Headquarters, Lyon, France, December 11-19, 1991. "Sentence Insertions Detected Through Ink, ESDA and Line Width Analysis," S.L. Fortunato and L.F. Stewart. Published in the Journal of Forensic Sciences, November 1992. "Status of U.S.S.S. Ink Dating Program," J.W. Hargett and L.F. Stewart. Presented at the Humboldt University, Berlin, Germany, April 2, 1993. Published in Kriminalistik und Forensische Wissenschaften, No. 82, 1994. "U.S.S.S. International Ink Library and Bulletin Board System," L.F. Stewart. Presented at the Mid-Atlantic Association of Forensic Scientists meeting, Baltimore, Maryland, May 20, 1993. "Standard Guide For Test Methods For Forensic Writing Ink Identifications," L.F. Stewart (Task Group Chairman). Published in the American Society For Testing and Materials (ASTM), Standard Designation number E-1422, 1995. "The Government Response to Ink Age Determination," L.F. Stewart, J.L. Becker. Presented at the American Academy of Forensic Sciences meeting, Seattle, Washington, February 17, 1995. Published in the International Criminal Police Review - INTERPOL, Spring, 1996. “Distinguishing Between Relative Ink Age Determination and the Accelerated Aging Technique,” L.F. Stewart and S.L. Fortunato. Published in the International Journal of Forensic Document Examiners, January/March, 1996. “Forensic Examination of Financial Crimes Documents,” L.F. Stewart and J.W. Hargett. Presented at the 6th European Conference for Police and Government Document Experts, London, United Kingdom, October 2-4, 1996 and the GFS Conference, Luzerne, Switzerland, September 9-12, 1997. “Unusual Document Examination Approaches and Their Relationship to the Daubert Challenge,” L.F. Stewart. Presented at the American Board of Forensic Document Examiners meeting, Las Vegas, NV, June 23, 2002 and the American Society of Questioned Document Examiners meeting, San Diego, CA, August 14, 2002. “Forensic Science – Fake Fingerprints?,” L.F. Stewart, Published in the Forensic Expert Witness Association, Fall, 2007. "Leveling The Playing Field," L.F. Stewart. Presented at the California Association of Licensed Investigators, Central Coast meeting, Pismo Beach, California, December 4, 2008. “Crime Scene Investigation,” L.F. Stewart, on-line course developed for and published by the American College of Forensic Examiners Institute, January 2009. “Identity Theft,” L.F. Stewart, A-Z Literary Book Publisher, 2009. “Document Examination,” L.F. Stewart, A-Z Literary Book Publisher, 2009. “Forensic Science – Fake Fingerprints?,” L.F. Stewart, Published in the HG Experts Legal Experts Directory on-line publication, Spring, 2010. “Forensic Science - The Good and the Bad,” L.F. Stewart, Published in the HG Experts Legal Experts Directory on-line publication, Spring, 2010. “Forensic Science - Erroneous Handwriting Opinions,” L.F. Stewart, Published in the HG Experts Legal Experts Directory on-line publication, Spring, 2010. Professional Affiliations: American Academy of Forensic Sciences - Fellow Canadian Society of Forensic Scientists (past member) American Society of Crime Laboratory Directors Document Security Alliance (past member) Mid-Atlantic Association of Forensic Scientists (past member) California Association of Licensed Investigators Forensic Expert Witness Association American College of Forensic Examiners Institute American Chemical Society Association For Intelligence Officers Business Espionage Controls & Countermeasures Association Offices Held: Mid Atlantic Association of Forensic Scientists Secretary/Treasurer November 1981 to October 1984. American Society of Crime Laboratory Directors Board of Directors September 14, 2000 to September, 2003 Document Security Alliance Board of Directors December 2003 to November 2004 The Academy Board of Directors June, 2007 to present American Board of Forensic Examiners Board of Directors January, 2009 to December, 2009 Contact Information: Physical Address: Stewart Forensic Consultants, LLC 570 Peach Street, #30 San Luis Obispo, California 93401 Additional Office: Stewart Forensic Consultants, LLC 1629 K Street, NW Suite 300 Washington, DC 20006 Mailing Address: Stewart Forensic Consultants, LLC 793A East Foothill Boulevard, Suite 200 San Luis Obispo, California 93405 Tel/Fax: (805) 595-1333/3333, Cell: (202) 550-6233 Email: contact@stewartforensicconsultants.com Website: http://www.stewartforensicconsultants.com

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