8.Jennifer Montgomery — Direct/Cross/Redirect/Recross
297 linesJENNIFER MONTGOMERY, duly sworn
COURT CLERK: State your name and spell your last name for the record, keep your voice up and speak into the mic.
JENNIFER MONTGOMERY: My name is Jennifer Montgomery. Last spelled is spelled M-O-N-T-G-O-M-E-R-Y.
DIRECT EXAMINATION BY MR. WEINREB:
MR. WEINREB: Good afternoon, Ms. Montgomery.
JENNIFER MONTGOMERY: Good afternoon.
MR. WEINREB: Where do you work?
JENNIFER MONTGOMERY: I'm currently employed at the state police crime lab.
MR. WEINREB: What do you do at the crime lab?
JENNIFER MONTGOMERY: I'm a Forensic Scientist 2 in the DNA unit and the crime-scene response unit.
MR. WEINREB: So you're a DNA analyst?
JENNIFER MONTGOMERY: Correct.
MR. WEINREB: How long have you worked at the crime lab?
JENNIFER MONTGOMERY: Since May of 2008.
MR. WEINREB: Where did you go to school and what degrees did you earn?
JENNIFER MONTGOMERY: I got my bachelor's of science in biology from UMass Dartmouth and my master's of science with a concentration in forensics from the University of Florida, Gainesville.
MR. WEINREB: After graduating with your master's degree in forensic science but before joining the state police lab, did you do other lab work?
JENNIFER MONTGOMERY: Yes; I have approximately eight years' experience in molecular biology and genetics labs.
MR. WEINREB: Do you have any specialized training in DNA analysis?
JENNIFER MONTGOMERY: Yes. When I first started at the crime lab, I participated in a six-month training program. This included lectures as well as required readings and written and oral exams. At the end of that training I took a competency test to determine whether or not I was able to do casework, and I passed that test and I've been a casework analyst since.
MR. WEINREB: Has there been additional testing of you over the years?
MR. WEINREB: How frequently?
JENNIFER MONTGOMERY: I'm given a proficiency test every six months.
MR. WEINREB: Have you always passed?
MR. WEINREB: In the course of your work, how many DNA samples have you analyzed?
JENNIFER MONTGOMERY: Approximately 10,000.
MR. WEINREB: Are there occasions when as a result of your analysis you have excluded a person by comparing the person's DNA to DNA found at a crime scene?
MR. WEINREB: How many times?
JENNIFER MONTGOMERY: It happens all the time.
MR. WEINREB: As part of your job, are you expected to testify in court about your examinations and the results of those examinations?
MR. WEINREB: How many times have you testified in court?
JENNIFER MONTGOMERY: Approximately 50 times.
MR. WEINREB: Your Honor, the government asks that Ms. Montgomery be qualified as a DNA expert.
MR. WATKINS: No objection.
THE COURT: Okay.
BY MR. WEINREB:
MR. WEINREB: What is DNA?
JENNIFER MONTGOMERY: DNA stands for deoxyribonucleic acid, and it's found in almost all the cells of your body. You inherit a half from your mother and half your DNA from your father, and it's responsible for, among other things, physical traits such as hair color, eye color and height.
MR. WEINREB: Is it sometimes referred to as the genetic blueprint for a person?
MR. WEINREB: Can you explain the process you used to analyze the DNA evidence in this case?
JENNIFER MONTGOMERY: Yes. I used a four-step process. The first step is called extraction, and that's when we open the cells to release the DNA. The second step is called quantitation, and that's where we take a small amount of the sample and put it into a machine which determines how much DNA we have in that sample. The third step is called amplification, and that's where we make millions and millions of copies of the DNA of interest. And the fourth step is called separation, and that's where, again, we take a small amount of the sample, put it into a machine, and it separates out the DNA by size.
MR. WEINREB: Do the processes that you just described, are they standardized processes that are followed at the state police lab?
MR. WEINREB: They're documented in protocols and procedures?
JENNIFER MONTGOMERY: Correct.
MR. WEINREB: Did you follow all of those in doing your work in this case?
JENNIFER MONTGOMERY: Yes, I did.
MR. WEINREB: What do you do to make sure your work is accurate?
JENNIFER MONTGOMERY: After I'm done with all of my testing, my file will be reviewed by a senior analyst. They'll go through the whole file and look for technical accuracy.
MR. WEINREB: Did you do DNA testing in connection with the murder of Officer Sean Collier?
JENNIFER MONTGOMERY: Yes, I did.
MR. WEINREB: Were you asked to compare Sean Collier's DNA to blood found on the outside of two white gloves?
MR. WEINREB: How did you obtain Sean Collier's DNA?
JENNIFER MONTGOMERY: I obtained a known head hair standard from the OCME, and I processed that using that same four-step process in order to determine a DNA profile for him.
MR. WEINREB: So even in our hair you can find DNA?
JENNIFER MONTGOMERY: Yes; it's in the root of the hair or a follicular tag attached to the root.
MR. WEINREB: And how did you obtain blood from the outside of the two white gloves?
JENNIFER MONTGOMERY: A swab was taken by a criminalist and then given to me to process through DNA.
MR. WEINREB: How were you able to identify it as blood from the outside of the white gloves?
JENNIFER MONTGOMERY: The criminalist will take notes and do testing to confirm that.
MR. WEINREB: Was it also given a case number and an item number?
MR. WEINREB: Do you know what the case number and item number were for the two gloves?
MR. WEINREB: What were they?
JENNIFER MONTGOMERY: The case number was 13-8140, and the two items that I tested were Item No. 12-9.1.1 and 12-9.2.1.
MR. WEINREB: So 12-9.1 is -- or 12-9 were the gloves?
JENNIFER MONTGOMERY: Correct.
MR. WEINREB: And then 12-9.1?
JENNIFER MONTGOMERY: Would be the swabs. And then the criminalist will take a portion of those swabs and put that forward for DNA, saving the other half.
MR. WEINREB: And that becomes 12-9.1.1?
JENNIFER MONTGOMERY: Correct.
MR. WEINREB: Okay. Did the test tube indicate who had prepared the sample?
MR. WEINREB: Who?
JENNIFER MONTGOMERY: Stephanie Waite.
MR. WEINREB: She's someone you work with regularly?
MR. WEINREB: In your experience is her work reliable?
MR. WEINREB: Were you able to develop a DNA profile for Sean Collier?
JENNIFER MONTGOMERY: Yes, I was.
MR. WEINREB: Were you able to develop a DNA profile for the blood from the outside of the white gloves?
JENNIFER MONTGOMERY: Yes, I was.
MR. WEINREB: Can I have Exhibit 912 for the witness, please.
MR. WEINREB: Does this diagram -- will this help you explain your testimony if you have this up?
MR. WEINREB: Okay.
MR. WEINREB: The government asks that 912 be published.
MR. WATKINS: No objection.
THE COURT: Okay.
BY MR. WEINREB:
MR. WEINREB: What does it mean to develop a DNA profile for a person or for an item like blood from the outside of gloves?
JENNIFER MONTGOMERY: We're looking at 15 specific locations as well as one location that tells us whether the sample is from a male or a female.
MR. WEINREB: Okay. Now, let me just stop you there. By "locations," do you mean locations on the gloves or --
JENNIFER MONTGOMERY: Locations on the chromosome.
MR. WEINREB: Explain what that means.
JENNIFER MONTGOMERY: So we're looking at these 15 specific locations that are highly variable from one person to the next, so it makes it useful to use for forensic identity purposes.
MR. WEINREB: Okay. Locations on their DNA?
MR. WEINREB: And you said they're highly variable from person to person?
JENNIFER MONTGOMERY: Correct.
MR. WEINREB: So everybody has those locations?
MR. WEINREB: But you don't often find the same thing at that location -- at a particular one of those locations in two different people?
JENNIFER MONTGOMERY: You can find it in two different people. But when you do all 15 locations, only identical twins have the same profile.
MR. WEINREB: What is this -- let's just focus on the three columns on the left-hand side of the page. Let's start with the first column. What's in the first column.
JENNIFER MONTGOMERY: Under "sample description," to the right of that is HHS, Sean Collier. And "HHS" stands for "head hair standard." And the item number is listed below that. And then along the left-hand side, all of the numbers and letters represent the different locations that we're looking at.
MR. WEINREB: Okay. Let me stop you right there. So it says -- just on the left-hand column, the one where everything is bold on the left, it says "sample description," then it says "item number." That refers to these two items. 10-4.1 going across is the Collier head hair sample, and then 12-9.3.1, that's one of the samples from the outside of the glove?
MR. WEINREB: All right. Now let's just -- on the left-hand column there are a bunch of numbers that have a D or a C or a T in front of them. What are those?
JENNIFER MONTGOMERY: Those are just the specific locations on the chromosome that we're looking at.
MR. WEINREB: So it's like an address?
JENNIFER MONTGOMERY: Correct.
MR. WEINREB: And then in the second column, under the name "Sean Collier" there are pairs of numbers?
MR. WEINREB: What do those represent?
JENNIFER MONTGOMERY: So the type of DNA testing that we do at the lab is called DNA STR testing. "STR" stands for short tandem repeat, and that just means we're -- it's a small section of DNA that repeats itself over and over and over. And what we do at the lab is count how many times that sequence repeats itself and assign a number. So after -- underneath the head hair standard for Sean Collier in the first column it says D8S1179.
MR. WEINREB: I'm sorry. You said the first column. You mean the first row?
JENNIFER MONTGOMERY: All the way on the left-hand column is the location --
MR. WEINREB: Yup.
JENNIFER MONTGOMERY: -- and then at that location he has 13 repeats and 14 repeats.
MR. WEINREB: Okay. Why two numbers?
JENNIFER MONTGOMERY: Because you inherit half your DNA from your mother and half from your father.
MR. WEINREB: So at each address, you actually have two different sets of repeats?
JENNIFER MONTGOMERY: Yes. They can be the same. You can get the same repeat from each parent.
MR. WEINREB: Go on.
JENNIFER MONTGOMERY: So we just do that at each of those locations. And if you go down towards the bottom, third from the bottom, there's a location that says "AMEL," and next to it is an X and a Y. And that means that this sample was obtained from a male.
MR. WEINREB: And then on the third column, "swab of red-brown stains on the exterior dorsal side of the pinky of the left glove," what are those numbers?
JENNIFER MONTGOMERY: Those -- that is the profile that I developed from that swab of red-brown stain.
MR. WEINREB: Okay. And at each address did the number of repeats in the Sean Collier sample match the number of repeats in the glove sample?
JENNIFER MONTGOMERY: Yes. The sample -- the profile that I obtained from this sample was a mixture with a major profile, and the minor profile in this mixture was insufficient for comparison so I didn't -- I wasn't able to make any comparisons to that. But I was able to make a comparison to the major profile.
MR. WEINREB: Okay. And what were the results of your comparison?
JENNIFER MONTGOMERY: The DNA profile obtained from this item indicated the presence of a mixture of DNA from more than one source. The major source of the DNA from this item has been interpreted, and this major male profile matched the DNA profile from Sean Collier.
MR. WEINREB: All right. Now let's go over to the next -- so just to summarize, the blood that you found on the outside of the gloves at that location was Sean Collier's blood?
JENNIFER MONTGOMERY: At all of the locations, yes.
MR. WEINREB: Okay. But when I say "that location," I mean that location on the glove.
MR. WEINREB: On the outside of the glove. All right. And then the next chart, you said you analyzed another sample from the outside of the gloves?
MR. WEINREB: And again, was the results of your analysis that the DNA in the blood found on the outside of the gloves at that location on the gloves was Sean Collier's blood?
JENNIFER MONTGOMERY: Yes. This was a single-source profile, meaning only one person was seen in the profile, and it was a match to the -- to Sean Collier.
MR. WEINREB: Can I have Exhibit 914 for identification, please.
MR. WATKINS: Your Honor, object. Notice.
THE COURT: Let me see you briefly.
(Discussion at sidebar and out of the hearing of the jury:)
THE COURT: Is this the keys?
MS. CLARKE: Yes.
MR. WEINREB: Your Honor, at least six months ago we sent the defense the report and an email stating that in addition to her testifying about the gloves, that this witness was going to talk about the keys. It wasn't in our initial disclosure, that's true, because we got the report later. But, in fact, we did give them the evidence many, many months ago and in an email said we were going to use it.
THE COURT: Do you have it?
MR. WEINREB: The email?
MR. CHAKRAVARTY: We could get it. We need five minutes.
MR. WATKINS: I don't think we ever got it. It's true we have the report, but the strictures of 16(a)(1)(G) are quite --
MS. CLARKE: It's not in there.
MR. WEINREB: This was the original disclosure. We did it shortly afterwards because we got the report shortly afterwards. But we did send the report with all of the information.
THE COURT: Well, given what the testimony is likely to be, I mean, is there prejudice?
MR. WATKINS: Well, your Honor, it wasn't noticed. I mean, that's the bottom line.
MS. CLARKE: It's Sean Collier's blood on the keys. And I don't know what the government's argument's going to be but they're going to try to place our client in the driver's seat leaving the scene.
THE COURT: I guess my question is: Would the -- would your approach to this witness be any different if you had received it?
MR. WATKINS: I don't know that there's a requirement for that. There is a requirement of good cause shown on the government. I don't know what the good cause would be at this point.
THE COURT: They said they could get it. You're saying you didn't get it. Those things happen. I don't know who's right on that one. But if they're right, then -- we could pause.
MR. CHAKRAVARTY: Five minutes, your Honor.
MR. WEINREB: Although we would argue -- although we have the email, I don't know if there's any need to pause for five minutes. We sent them a report saying Collier's blood was found on the keys. And the one reason for doing that was because we were notifying them this is the result that they should expect to see in evidence.
THE COURT: Have you looked at the email since this morning?
MR. CHAKRAVARTY: Not since this morning.
THE COURT: Let's take a short break and see if you can get the email.
MS. PELLEGRINI: Okay.
(In open court:)
THE COURT: We're going to take a short recess.
COURT CLERK: All rise for the jury. The Court will take a short recess.
(The Court and jury exit the courtroom and there is a recess in the proceedings at 2:52 p.m.)
COURT CLERK: All rise for the Court.
(The Court enters the courtroom at 3:26 p.m.)
(Discussion at sidebar and out of the hearing of the public:)
THE COURT: There's no jury here, but...
MR. WEINREB: So on June 30th we provided the defense with an Excel spreadsheet of all the reports and experts' names and CVs and everything else, and gave notice that the experts would testify consistently with their reports. On August 15th we provided this report, which is the report of the examination of the car keys. The defense filed a motion -- because this report was produced -- this examination was done and this report was produced after this letter was sent. So we supplemented by sending the report.
On September -- the defense meanwhile had filed a motion saying that just giving them the reports, no matter how detailed the reports were, was not sufficient and we needed to do it in a narrative fashion, and the Court agreed. So on September 2nd we provided them, in narrative fashion, an extremely detailed account of how Jennifer Montgomery does her DNA analysis. In that we did not reference the keys report, although it had already been produced, because our argument will be that the defense was already on notice that these experts would testify consistently.
We subsequently did send them -- there was yet more DNA testing done, this was the DNA testing of the hat found, and we supplemented that so that there was a -- there was the initial disclosure that the experts will testify consistent with the reports, and then there was subsequent production of reports over time along with a detailed explanation of the witnesses' [sic] methodology --
THE COURT: Where is that?
MR. WEINREB: In here. It starts here.
(Pause.)
MR. WEINREB: As with any claim, under Rule 16 the question should be did the defense have adequate notice and can they show prejudice. If there's anything they can say they would have done differently, they would have litigated this case differently, they would have done some test differently, they would have opened differently, anything if this were done in any way different.
And I can't because they have had the report, knowing that it was their client's DNA on the keys, ever since we produced the report. We notified them. And the only reason we were doing these tests and giving them these reports, as we said, way back in June, the experts are going to testify consistent with their reports, we were never asked for a single bit of follow-up discovery, anything in connection with that report although they acknowledge they've had the report since August or September of 2014.
MR. WATKINS: Yeah, there have been dozens of reports, dozens of tests, dozens of experts proposed that were potentially available in this case. This September 2nd letter is really the bible of the experts. It was hotly litigated about when the government would --
THE COURT: Did this happen before? Where's Jane? This happened before. The volume all of a sudden kicks out.
MR. WATKINS: What's that?
THE COURT: The volume kicks out. It's like the delays on the pictures.
MR. WATKINS: So the -- the fact of the matter is there's not notice there about the keys, there's not notice anywhere about the keys. The knit cap, indeed they noticed that. There was no particular reason for us to argue that there wasn't good cause once they did notice us, but they did not notice us on the keys and have not.
We -- I should note that we did file a motion to exclude DNA results. We did not argue about the keys' DNA results.
THE COURT: It wasn't Collier's DNA results you were trying to exclude.
MR. WATKINS: Well, that's correct. To the extent that the government is suggesting that the issue was somehow joined, I don't think that it was. I don't think there's any evidence of that.
THE COURT: And how would you have done things differently if you had known?
MR. WATKINS: Your Honor, I can't say how we would have done things differently. What I can say is that we noticed that it was not in here. We did not concentrate on that. We did concentrate on the many other experts that there are in this case. As the Court knows, there are very complicated and very complex on a number of different -- there is a reason the rule requires that there be notice or otherwise good cause for late notice. There's simply not good cause for this late notice at the beginning of the case.
THE COURT: Well --
MR. WATKINS: I don't think it's the determinative argument, but there's plenty of other evidence that the government has available to them.
MR. WEINREB: Your Honor, we can give notice today and put the expert -- call the expert a week from now. There's still nothing different that they're going to say next week.
MR. CHAKRAVARTY: The only reason for disclosing this report was so -- it's a Rule 16 disclosure related to the expert. It's not exculpatory --
MR. WATKINS: That doesn't do it. We received literally dozens, if not hundreds of, quote/unquote, expert reports in this case, all -- many of which the government did not use, declined to use for whatever reason. The fact that they disclosed a report that's good enough for notice is simply not adequate.
MR. WEINREB: I agree. But there's also the letters.
MR. WATKINS: But that's as broad as they get.
THE COURT: I'll let you re-call the expert next week if you want.
MR. WEINREB: Okay.
THE COURT: Okay? You have notice now. Whatever you can negotiate on the timing.
MR. WEINREB: Okay.
(In open court:)
COURT CLERK: All rise for the jury.
(The jury enters the courtroom at 3:34 p.m.)
COURT CLERK: Be seated.
THE COURT: Go ahead.
MR. WEINREB: Your Honor, we have no further questions for Jennifer Montgomery at this time subject to re-calling her at a later date.
THE COURT: All right.
MR. WEINREB: The United States calls Special Agent --
MR. WATKINS: I'm sorry. I'm going to do some cross-examination.
MR. WEINREB: Oh, I'm sorry. I thought we were going to do that at a later date but evidently we'll do it now.
THE COURT: Is Ms. Montgomery here?
JENNIFER MONTGOMERY, resumed
CROSS-EXAMINATION BY MR. WATKINS:
MR. WATKINS: Good afternoon, Ms. Montgomery.
JENNIFER MONTGOMERY: Good afternoon.
MR. WATKINS: In addition to the gloves that you tested, were you also asked to test a sweatshirt that was -- belonged to Dzhokhar Tsarnaev?
JENNIFER MONTGOMERY: Yes; I tested eight samples that were taken from the sweatshirt.
MR. WATKINS: And in preparation for that -- doing that comparison, you talked with Mr. Weinreb about developing DNA profiles. Did you also develop DNA profiles for Dzhokhar Tsarnaev and for Tamerlan Tsarnaev?
JENNIFER MONTGOMERY: Yes, I did.
MR. WATKINS: And that's in addition to the profile that was developed for Sean Collier?
JENNIFER MONTGOMERY: Correct.
MR. WATKINS: And when you did that testing of the eight separate spots on the sweatshirt of Dzhokhar Tsarnaev, were you able to develop a DNA profile from that?
JENNIFER MONTGOMERY: Yes, I was.
MR. WATKINS: You talked a little bit about single profiles versus mixtures. Was this a single profile or a mixture?
JENNIFER MONTGOMERY: They were all single-source profiles.
MR. WATKINS: And when you compared the single-source profile to those eight spots, did they match Tamerlan Tsarnaev's?
JENNIFER MONTGOMERY: No, they did not.
MR. WATKINS: Those eight spots on the sweatshirt, do you recall where on the sweatshirt you developed those from?
JENNIFER MONTGOMERY: They were swabs taken by the criminalist on various areas on the exterior of the sweatshirt including the arms, the cuffs of the sweatshirt, I believe the abdomen.
MR. WATKINS: And are you able to show the jury where on yourself those were taken from?
JENNIFER MONTGOMERY: Yes. If I can refer to my notes?
MR. WATKINS: Absolutely.
JENNIFER MONTGOMERY: Item No. 15-3.3.1, swab of red-brown saturation stain on lower exterior front and back of right sleeve near cuff, so in this area.
MR. WATKINS: Thank you.
JENNIFER MONTGOMERY: Do you want me to do all seven?
MR. WATKINS: Yes, please.
JENNIFER MONTGOMERY: 15-3.4.1 was a swab of a red-brown stain on the exterior front right sleeve near shoulder of sweatshirt, so the exterior front right. 15-3.6.1, swab of red-brown saturation stain on exterior abdomen, so in this area. 15-3.8.1, swab of red-brown saturation stain on middle portion of exterior front right sleeve of sweatshirt, so this area. 5-3.10.1, swab of red-brown saturation stain on exterior back right shoulder of sweatshirt, so back here. 15-3.9.1, swab of 5 millimeter times 3 millimeter red-brown stain on middle portion of exterior front right sleeve, so right in this area. 5-3.11.1, swab of red-brown stain on exterior lower right back of sweatshirt, back here. 15-3.2.1, swab of red-brown stain on exterior front left sleeve of sweatshirt, so here.
MR. WATKINS: You talked about finding -- doing a DNA profile on part of the abdomen. I don't think we could see that terribly clearly. Could you perhaps stand up and demonstrate to the jury what part?
JENNIFER MONTGOMERY: The abdomen would be right here.
MR. WATKINS: Thank you. And the results of that single-source profile, when you compared it to Sean Collier's blood, what was the outcome?
JENNIFER MONTGOMERY: He could not have been a source of the DNA on those items.
MR. WATKINS: And when you compared the single-source profile from those eight spots on the sweatshirt, did that match Dzhokhar Tsarnaev?
JENNIFER MONTGOMERY: Yes, it did.
MR. WATKINS: So all of the spots that were tested were from Dzhokhar Tsarnaev and no one else?
JENNIFER MONTGOMERY: Correct.
MR. WATKINS: I have nothing further, your Honor.
MR. WEINREB: Just briefly.
REDIRECT EXAMINATION BY MR. WEINREB:
MR. WEINREB: Ms. Montgomery, you say that you tested swabs that were taken from various areas on the sweatshirt?
MR. WEINREB: So a swab of a particular area, it just picks up the blood in that area, correct?
JENNIFER MONTGOMERY: Correct.
MR. WEINREB: It doesn't pick up all the blood in all the areas?
JENNIFER MONTGOMERY: No, just that specific area that the sample was taken from.
MR. WEINREB: Right. And if there was an area that wasn't swabbed, then we wouldn't know whose blood that was, correct?
JENNIFER MONTGOMERY: Correct.
MR. WEINREB: And even if there was an area that was swabbed, if the swab didn't happen to hit the entire area, cover all of it, then you wouldn't know necessarily whose blood that was, correct?
JENNIFER MONTGOMERY: Correct.
MR. WEINREB: And if somebody is swabbing areas of blood on a sweatshirt but there are, let's say, little pinpoints of blood or tiny droplets of blood elsewhere --
MR. WATKINS: I'm going to object at this point.
THE COURT: Sustained.
BY MR. WEINREB:
MR. WEINREB: Do you know whether every single droplet of blood on that sweatshirt was swabbed?
MR. WATKINS: I object.
THE COURT: You may answer that.
JENNIFER MONTGOMERY: I do not know.
BY MR. WEINREB:
MR. WEINREB: Do you know whether it is -- whether there was a request that every single droplet of blood be swabbed?
MR. WATKINS: I'm going to object.
THE COURT: Sustained.
BY MR. WEINREB:
MR. WEINREB: All you can say is that the swabs that you happened to test did not have anyone's blood besides Dzhokhar Tsarnaev's?
JENNIFER MONTGOMERY: Correct.
MR. WEINREB: No further questions.
MR. WATKINS: Just one.
RECROSS-EXAMINATION BY MR. WATKINS:
MR. WATKINS: I think on direct examination you talked about working with Stephanie Waite?
MR. WATKINS: And you worked with her for years?
MR. WATKINS: I believe you told Mr. Weinreb that she's very experienced?
MR. WATKINS: And she would be the one that would determine where to test from, correct?
JENNIFER MONTGOMERY: She's the one that samples the sweatshirt, yes.
MR. WATKINS: So do you rely on her experience to look for every single spot that was testable?
MR. WEINREB: Objection.
THE COURT: Yes, sustained.
MR. WATKINS: I have nothing further. Thank you.
THE COURT: Okay. Thank you, Ms. Montgomery. You may step down.
(The witness is excused.)
MR. WEINREB: The United States calls Special Agent Brian Corcoran.