Ceglia v. Zuckerberg et al

Filing 239

DECLARATION signed by Gus R. Lesnevich re 237 Response in Opposition to Motion,,,, filed by Mark Elliot Zuckerberg, Facebook, Inc. filed by Mark Elliot Zuckerberg, Facebook, Inc.. (Attachments: # 1 Exhibit A, # 2 Exhibit B)(Snyder, Orin)

Designation: E2291 – 03

Standard Guide for

Indentation Examinations1
This standard is issued under the fixed designation E2291; the number immediately following the designation indicates the year of
original adoption or, in the case of revision, the year of last revision. A number in parentheses indicates the year of last reapproval. A
superscript epsilon (´) indicates an editorial change since the last revision or reapproval.

1. Scope
1.1 This guide provides procedures that should be used by
forensic document examiners (Guide E444) for examinations
and comparisons involving visualization and recording of
indentations.
1.2 These procedures include evaluation of the sufficiency
of the material available for examination.
1.3 The particular methods employed in a given case will
depend upon the nature of the material available for examination.
1.4 This guide may not cover all aspects of unusual or
uncommon examinations.
1.5 This standard does not purport to address all of the
safety concerns, if any, associated with its use. It is the
responsibility of the user of this standard to establish appropriate safety and health practices and determine the applicability of regulatory requirements prior to use.

3.2.3 film, n—thin transparent plastic material that covers
the item during an examination using an EDD.
3.2.4 indentations, n—latent or visible impressions in paper
or other media.
3.2.5 indirect contact, n—two sheets of paper, one on top of
the other, with one or more intervening sheets.
3.2.6 lift, n—the product of an EDD examination; a selfadhesive plastic sheet adhering to a film that preserves the
results of an EDD examination.
3.2.7 primary indentations, n—impressions caused by the
act of writing or other dynamic actions.
3.2.8 secondary impression(s), n—fiber disturbances caused
by contact with the embossed side of indentations and not
caused by the act of writing.
3.2.9 side lighting, n—illumination from a light source that
is at a low angle of incidence, or even parallel, to the surface
of the item. Syn. oblique lighting.

2. Referenced Documents
2.1 ASTM Standards:2
E444 Guide for Scope of Work of Forensic Document
Examiners
E1732 Terminology Relating to Forensic Science
E2195 Terminology Relating to the Examination of Questioned Documents

4. Significance and Use
4.1 When sheets of paper are in direct or indirect contact
with one another, impressions on the top sheet can produce
indentations on the sheet(s) below.
4.2 This guide establishes procedures for visualizing those
indentations.
4.2.1 These procedures are essentially non-destructive;
however, pencil writing and single-strike ribbon typing can be
partially lifted from the document by EDD. Although this
effect can be minimal, adequate documentation of such items
should precede EDD.
4.3 Paper fiber disturbances caused by erasures or present in
torn paper edges may be visualized using this guide.
4.4 Electrostatic detection device (EDD) examinations may
be useful in developing other types of impressions on paper
items (for example, typewritten material, shoeprints and latent
prints).
4.5 The procedures outlined here are grounded in the
generally accepted body of knowledge and experience in the
field of forensic document examination. By following these
procedures, a forensic document examiner can reliably reach
an opinion concerning indentations.

3. Terminology
3.1 Definitions—For definitions of terms in this guide, refer
to Terminologies E1732 and E2195.
3.2 Definitions of Terms Specific to This Standard:
3.2.1 direct contact, n—two sheets of paper, one on top of
the other, with no intervening sheets.
3.2.2 electrostatic detection device (EDD), n—an instrument used to visualize paper fiber disturbances (for example,
indentations, erasures, typewritten material/lift off).
1
This guide is under the jurisdiction of ASTM Committee E30 on Forensic
Sciences and is the direct responsibility of Subcommittee E30.02 on Questioned
Documents.
Current edition approved April 10, 2003. Published June 2003. DOI: 10.1520/
E2291-03.
2
For referenced ASTM standards, visit the ASTM website, www.astm.org, or
contact ASTM Customer Service at [e-mail]. For Annual Book of ASTM
Standards volume information, refer to the standard’s Document Summary page on
the ASTM website.

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E2291 – 03
5. Interferences
5.1 Certain items submitted for examination may have
inherent limitations that can interfere with the procedures in
this guide. Limitations should be noted and recorded.
5.2 The size, shape, density or condition of an item may
make it unsuitable for the EDD portion of the procedure (for
example, some book covers, large file folders and items that
have been wet or damaged after indentations were made).
5.3 A complete examination involves the use of both the
optical and EDD portions of the procedure. All indentations
may not be revealed if the optical and EDD portions of the
procedure are not conducted.
5.4 The results of prior storage, handling, testing, or processing may interfere with these procedures. Chemical processing for latent prints generally interferes with indentation
examination results. Indentation examinations should be conducted prior to any chemical processing. Items should be
handled appropriately to avoid compromising subsequent examinations (for example, with clean cloth gloves).
5.5 Items should be handled as little as possible prior to
EDD examination to prevent contamination (for example, the
introduction of latent prints and additional indentations). Improper handling (for example, rubbing the item surface with
cloth gloves) may also impede EDD examination results.
5.6 EDD examination may yield secondary impressions as
well as primary impressions. Caution should be taken when
attempting to determine whether impressions are primary or
secondary.
5.7 In some locations (that is, areas with low humidity),
conducting an EDD examination without prior humidification
of the document may impede examination results.
5.8 Periodically check the condition of the glass beads
utilized in EDD examinations. They can deteriorate with use,
affecting the quality of the developed EDD image.
5.9 Repeated processing with EDD can result in degraded
images.
6. Equipment and Requirements
6.1 Light source(s) of sufficient intensity and appropriate
form to be used for side lighting.
6.2 Electrostatic detection device (EDD).
6.3 Imaging or other equipment for recording observations
as required.
6.4 Sufficient time and facilities to complete all applicable
procedures.
7. Procedure
7.1 All procedures shall be performed when applicable and
noted when appropriate. These procedures should be performed in the order given.
7.2 Examinations performed, relevant observations, and
results shall be documented.

7.3 View the item being examined using side lighting that is
directed at the item from various angles and directions. In some
instances, the use of side lighting in a room with subdued light
may provide better visualization of indentations.
7.3.1 Document any indentations observed.
7.3.2 If indentations are not observed, document the lack of
visible indentations.
7.4 Determine whether the item is suitable for EDD examination.
7.4.1 If the item is not suitable, discontinue examination and
report accordingly.
7.5 Each suitable item should be examined using an EDD.
7.5.1 The EDD shall be operated utilizing the instructions
provided in the operating manual, laboratory procedures, and
current technical research.
7.5.2 A control indentation shall be successfully developed
and recorded on the day of examination. This control can be
conducted prior to, or concurrently with, the EDD examination
of the item(s).
7.5.2.1 If the control indentation is not successfully visualized, the problem shall be corrected before any further indentation examinations are conducted with that instrument.
7.6 Results of the EDD examination may be preserved by
making a lift.
7.7 If no indentations are developed, the results will be
documented or preserved, or both, according to laboratory
policy.
NOTE 1—In situations where the developed results are faint or there is
background interference, or both, results may be difficult to see. In such
instances, the results should be lifted and evaluated using an appropriate
background.

7.8 Lifts shall be maintained according to laboratory policy.
7.9 Evaluate and document results of the EDD examination.
7.10 If indentations or other images are visualized, conduct
other examinations as appropriate.
8. Report
8.1 Conclusion(s), or opinion(s), or other finding(s) resulting from the procedures in this guide may be reached once
sufficient examinations have been conducted.
8.2 The bases and reasons for the conclusion(s), opinion(s),
or finding(s) should appear in the examiner’s documentation
and may also appear in the report.
8.3 Once examinations and evaluations have been completed, reports may include the following types of conclusion(s), opinion(s), or finding(s):
8.3.1 Whether indentations were observed.
8.3.2 Whether decipherable indentations were observed.
8.3.3 The text of deciphered indentations.
8.3.4 Information as to the source of indentations.
9. Keywords
9.1 electrostatic detection device (EDD); embossing; forensic science; indentations; questioned documents

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E2291 – 03
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