Jamie Hall — Direct/Cross
454 linesMR. MEADORS: The State would now call Jamie Hall.
The witness, JAMIE HALL, was first duly sworn and testified as follows:
COURT CLERK: State your name for the record; spell your last name, please.
JAMIE HALL: My name is Jamie Hall, H-a-l-l.
DIRECT EXAMINATION
BY MR. MEADORS:
MR. MEADORS: Good afternoon.
JAMIE HALL: Good afternoon.
MR. MEADORS: Where do you work?
JAMIE HALL: I'm currently employed at the West Columbia Police Department as an evidence custodian.
MR. MEADORS: How long have you been there?
JAMIE HALL: Since April of 2022.
MR. MEADORS: Will you please tell the ladies and gentlemen of this jury about Jamie Hall, your background? As personal background as you want to. I'll leave that to you, but specifically your education and background that lead you to law enforcement, please.
JAMIE HALL: Yes, sir. I grew up in the Midlands area of South Carolina, and upon graduating high school I attended Clemson University and obtained my Bachelor's of Science degree in wildlife and fisheries biology. After that I spent a couple of years traveling and working some various jobs. I moved back to the area in 2013 and began looking to start a career, and ended up at SLED in 2015 as an administrative assistant in the Trace Evidence Department in the Forensic Services Laboratory. I was an administrative assistant until 2017 when I began -- became an evidence technician -- or, excuse me, a forensic technician II in the Trace Evidence Lab.
MR. MEADORS: When did you graduate Clemson?
JAMIE HALL: Sorry, in 2010.
MR. MEADORS: Okay. So, after you traveled some, you started work at SLED in what year?
JAMIE HALL: 2015.
MR. MEADORS: Okay. What was your job then?
JAMIE HALL: I was an administrative assistant.
MR. MEADORS: And what does that mean?
JAMIE HALL: For the Trace Evidence Department, that involved answering phone calls, filing documents, pretty much normal administrative duties.
MR. MEADORS: And did you further your education or your experiences while you were at SLED in that field?
JAMIE HALL: No, sir. When I became the technician in 2017, that's when I began the in-house training for that career.
MR. MEADORS: Okay. Tell us about the in-house training when you became a forensic technician.
JAMIE HALL: Yeah. So, that training involved oral and practical examinations in-house and under the supervision of an analyst in which I learned how to properly handle the evidence and process the evidence for potential GSR. I also oversaw some testimonies of some analysts to be familiar with courtroom policies as well. And I took some outside training from Hook College in Chicago as well.
MR. MEADORS: Hook College in Chicago?
JAMIE HALL: Hook, yes, sir.
MR. MEADORS: What was that training specifically?
JAMIE HALL: It was training regarding the scanning electron microscopic, which is used for GSR analysis.
MR. MEADORS: Is that -- the acronym is SEM for that?
JAMIE HALL: SEM, yes, sir.
MR. MEADORS: And when did you leave SLED?
JAMIE HALL: In March of 2022.
MR. MEADORS: And do you mind, you are working where now?
JAMIE HALL: At the West Columbia Police Department.
MR. MEADORS: West Columbia Police Department. And you are their what?
JAMIE HALL: Evidence custodian.
MR. MEADORS: Now back in June of 2021, you were a forensic technician for SLED.
JAMIE HALL: Yes, sir.
MR. MEADORS: And special agent forensic technician? How --
JAMIE HALL: No, sir. I was not necessarily an agent or considered law enforcement. I was just the forensic technician II.
MR. MEADORS: So then in June of 2021, what was your job on a day- to-day basis?
JAMIE HALL: My primary role in the Trace Evidence Department as a forensic technician was to prepare evidence for GSR analysis. That includes GSR kits, as well as inanimate objects that came in for potential GSR testing.
MR. MEADORS: And we're going to have Ms. Fletcher testify right after you, but what is a GSR kit?
JAMIE HALL: A GSR kit is an envelope that goes out to officers or investigators so that they can collect on scene from a potential suspect's hands, and it involves -- it has all the items they need: gloves so that they can make sure they're not contaminating the subject's hand; and then the little vials that contain the GSR particle lifts with the double-sided adhesive that's used to dab across their hands to pick up any potential GSR.
MR. MEADORS: So, those are kind of done in the field, if you will?
JAMIE HALL: Yes, sir.
MR. MEADORS: After a local law enforcement agency uses one of these kits, what happens to it?
JAMIE HALL: When they decided they need it analyzed, they send it to the laboratory, and then when it comes into the laboratory, I prepare it for analysis. So, that involves me making sure it's been properly sealed and initialed, handled properly, the correct kit. There are some -- a variety of kits out there. Our lab has particular kits that we accept, so I confirm that it is an acceptable kit, and I also confirm that it was collected within the allowed timeframe. On a living person, we're touching things all the time and possibly contaminating or removing the GSR, so we do have a six hour time limit on kits collected from individuals.
MR. MEADORS: So, if a kit comes in to SLED, or your possession, do you check to see if it was collected during that six hour time period?
JAMIE HALL: Yes, sir, I do.
MR. MEADORS: And how do you do that?
JAMIE HALL: We have what we call an information worksheet included in each GSR kit that the officer fills out that includes the time, or the estimated time that the shooting occurred, as well as the time that the kit was collected.
MR. MEADORS: I'm going to show you what is marked as State's 13. Can you tell if you were involved with State's 13? And if you can, how can you tell?
JAMIE HALL: Yes, sir. This has the unique SLED lab number and item number, and it also has my initials on the day that I processed it.
MR. MEADORS: 6/8/21, JEH.
JAMIE HALL: Yes.
MR. MEADORS: What's the E stand for?
JAMIE HALL: Elizabeth.
MR. MEADORS: Now, with the Court -- would you open this, please?
JAMIE HALL: Sure. Do you have some scissors?
(Break in proceedings.)
MR. MEADORS: Did you examine State's 13?
JAMIE HALL: Yes, sir. Again, it also has my date and initials from the day that I processed it.
MR. MEADORS: Your initials, again, JEH?
JAMIE HALL: Yes, sir.
MR. MEADORS: 6/8/21?
JAMIE HALL: Yes, sir.
MR. MEADORS: And when you're processing this, tell us again. What are you looking to see? Whether it's -- what's done or not? Just tell us what you --
JAMIE HALL: Okay. So, for a GSR kit I start by what -- using what we call an inventory worksheet, and on that worksheet what I'm doing is confirming the manufacturer of the kit, as well as lot number for the kit. They have lot numbers for quality control purposes to make sure they're not contaminated before they're used for collection, confirming who the kit was collected from, that six hour timeframe. And during that time I also labeled the individual particle lifts inside with the unique lab number, item number, date, and initials for control purposes.
MR. MEADORS: And I believe a sheet has been entered where a Varnadoe collected this GSR kit from the defendant. Are you aware of that?
JAMIE HALL: Are you referring to the gunshot residue analysis information sheet?
MR. MEADORS: That's exactly what I'm referring to.
JAMIE HALL: Yes, sir. That's what I would have used to confirm the six hour timeframe.
MR. MEADORS: Okay, and it's in evidence already. I'm not sure exactly what number, but do you have that copy?
JAMIE HALL: Yes, sir, I do.
MR. MEADORS: Okay, and this is already -- if you'll trust me, this has already been entered into evidence. Did you use this in examining and determining whether this was collected properly?
JAMIE HALL: Yes, sir, I did. It also has my date and initials on it.
MR. MEADORS: So, using the form shows these ladies and gentlemen what you do. How you came up and put --
JAMIE HALL: So -- yeah. There's a section here at the bottom, so we have the subject's name from whom it was collected.
MR. MEADORS: And who is that?
JAMIE HALL: This one says Richard Alexander Murdaugh, as well as the time and date the shooting occurred: 6/7/21, 10:00 p.m.
MR. MEADORS: And that's information that's gathered at the scene from somebody, right?
JAMIE HALL: Yes, sir. This particular kit says that it was filled out by collecting Officer Brian Vandore (sic). I'm sorry if I messed that up.
JAMIE HALL: That's good enough.
MR. MEADORS: Go ahead.
JAMIE HALL: And then at the bottom, the collecting officer has also signed and dated that it was collected at -- on 6/7/21 at 11:15 p.m.
MR. MEADORS: And would that 11:15 fit in the time period where you're saying, okay, I can pass this on to be analyzed?
JAMIE HALL: Yes, sir, it's an hour and 15 minutes.
MR. MEADORS: And so not taking away from what's your job at all, but one of your jobs is just to make sure that's done correctly at that point?
JAMIE HALL: Yes, sir.
MR. MEADORS: Okay, and then do you inspect the vials, if you will, to make sure --
JAMIE HALL: Yes, sir. I make sure there's nothing out of the ordinary with them. Occasionally you might would have a little crack in the vile, but I've never had anything damaged.
MR. MEADORS: So, in your opinion these were collected properly and you passed them on for analysis?
JAMIE HALL: To the best of my knowledge, yes, sir.
MR. MEADORS: Now, were there -- let me ask you this question. Local agencies that you examined items for potential evidence, in this case gunshot residue, how do they get to your -- the lab?
JAMIE HALL: Typically the officers from the local agency submit them through our evidence control department, and once they're submitted that way, that's when they're assigned their unique lab number and item numbers for each piece of evidence. And then based on the type of analysis that that agency requested, we would get notice that it needs to be processed, and so I would pick it up from evidence control and bring it upstairs to the trace lab to begin processing.
MR. MEADORS: Okay, and is all of that documented from local agency to y'all and where it goes from there?
JAMIE HALL: I can't attest to what the outside agencies do. I believe it probably varies agency to agency, but once it's been logged into our system downstairs, it is tracked throughout the laboratory for every hand that touches it.
MR. MEADORS: That's kind of what we refer to as the chain, correct?
JAMIE HALL: Yes, sir.
MR. MEADORS: Chain of evidence?
JAMIE HALL: The chain of custody.
MR. MEADORS: Chain of custody. Now, did you have some other items or potential evidence in this case that you examined?
JAMIE HALL: Yes, sir, I had several other items.
MR. MEADORS: Okay. I'm going to show you what's marked State's 418 and ask you if you can just identify this, Ms. Hall, and does it relate to your testimony?
JAMIE HALL: Well, I can no longer see my initials. But I did process items that were in Container D, and this is marked with Container D for this case number, yes, sir.
MR. MEADORS: And would you open it up then and see if you can further find your mark.
JAMIE HALL: Yes.
MR. MEADORS: With the Court's permission.
(Break in proceedings.)
MR. MEADORS: I'm going to show you what's marked 21 -- excuse me, your Lab Number 21 contained in State's 418 at this point for identification. Do you recognize that?
JAMIE HALL: Yes, sir, I recognize it as the Lab Item Number 20.
MR. MEADORS: And what is Lab Item Number 20?
JAMIE HALL: It was a brown paper bag containing one pair of green cargo shorts.
MR. MEADORS: And also contained in 418, Lab Number 21, can you tell me if you recognize that?
JAMIE HALL: Yes, sir. It's Lab Number -- or Item Number for this case 19, which was a brown paper bag containing one white t-shirt.
MR. MEADORS: Okay. Now --
MR. MEADORS: Jim.
MR. GRIFFIN: I don't have an objection to 418.
MR. MEADORS: Okay. Your Honor, I offer 418 without objection.
MR. GRIFFIN: Without objection.
JUDGE NEWMAN: They are admitted.
(SHIRT AND SHORTS MARKED AS STATE'S EXHIBIT NUMBER 418 WERE RECEIVED INTO EVIDENCE.)
MR. MEADORS: I'm going to show you what's -- for time purposes.
(Break in proceedings.)
(GSR INVENTORY MARKED AS STATE'S EXHIBIT NUMBER 422 FOR IDENTIFICATION.)
MR. MEADORS: Thank you, Your Honor. Sorry.
MR. MEADORS: I'm going to ask you, please, look at 423, 424, and 425. Do you recognize these, and do they relate to what you're talking about right now?
JAMIE HALL: Yes, sir. These are PGSR collection worksheets on clothing that I generate during my process of collecting from inanimate objects.
MR. MEADORS: Okay. Inanimate objects.
JAMIE HALL: Yes, sir.
MR. MEADORS: Okay. Now, let's start with the shirt, 423.
JAMIE HALL: Yes, sir.
MR. MEADORS: That's in evidence. Tell these folks what you did with the shirt.
JAMIE HALL: So, any time we're processing clothing or an inanimate object in the lab, we start making sure that everything has been thoroughly cleaned, and we also place down parchment paper just as an extra check and balance to make sure there's nothing contaminating the evidence. We also placed what we call a clothing link out onto the table where we are processing. It's just another one of those double sided adhesive stubs, and it's left open and exposed to the environment to make sure there's no contamination in the environment. That's how I start all of my clothing. Then I confirm that everything is adequately sealed and documented, and I open my items and lay them out on the parchment paper. I photograph items, and then I do label those items for identification later if needed. And then I will sample the clothing item closest in the areas that would be closest to the discharge of the firearm. So, in this case we're talking about a t-shirt, so I will sample the right chest and sleeve area together, and the left chest and left sleeve together. So, if you want to draw down your midline for right and left, and then we typically go down to just below the chest area.
MR. MEADORS: And is that what you do with every shirt?
JAMIE HALL: Yes, sir. If it's a long sleeved garment, I would typically use a several -- a separate particle lift for the chest area and the arms just because adhesive doesn't last quite as long.
MR. MEADORS: And if you said this I apologize. I'm tired. Why are you doing those areas?
JAMIE HALL: It's closest to the discharge of a firearm.
MR. MEADORS: Initial discharge, so that's where you test it.
JAMIE HALL: Yes, sir.
MR. MEADORS: If we're looking at the shirt, look at 418, the shirt that's contained in here. Which one is the shirt?
JAMIE HALL: 19.
MR. MEADORS: 19?
JAMIE HALL: Yes, sir.
MR. MEADORS: Before you get to doing the particle lifts, what's the first thing you do?
JAMIE HALL: I confirm what the item is and that it's properly sealed and initialed.
MR. MEADORS: Do you open it?
JAMIE HALL: After I clean I open it, yes, sir.
MR. MEADORS: And do you make observations of items when you first open it?
JAMIE HALL: Yes, sir. Anything that seems out of the ordinary for any item is documented on the worksheet in the comment section.
MR. MEADORS: And you have a comment section. That's where you put your thoughts, right?
JAMIE HALL: Yes, sir. Anything that may, again, be out of the ordinary or affect the analysis later.
MR. MEADORS: Just to go back and go down a little bit, this is the right sleeve/right chest, left sleeve/left chest, Hanes Beefy shirt, right?
MR. GRIFFIN: Your Honor, I don't have any objection to him introducing 423 into evidence. I don't know if it's in evidence yet.
MR. MEADORS: We offered it a little while ago without objection, 423, -24 and -25.
MR. GRIFFIN: I have no objection to those three exhibits going into evidence.
MR. MEADORS: I thought I said that. If I didn't, I apologize.
JUDGE NEWMAN: They're admitted.
(GSR WORKSHEET MARKED AS STATE'S EXHIBIT NUMBER 423 WAS RECEIVED INTO EVIDENCE.)
(GSR WORKSHEET MARKED AS STATE'S EXHIBIT NUMBER 424 WAS RECEIVED INTO EVIDENCE.)
(GSR WORKSHEET MARKED AS STATE'S EXHIBIT NUMBER 425 WAS RECEIVED INTO EVIDENCE.)
MR. MEADORS: Is this a Hanes Beefy shirt?
JAMIE HALL: Yes, sir, it was.
MR. MEADORS: And Item 19 was -- what are your comments underneath that?
JAMIE HALL: A small reddish brown stain observed. Shirt had an odor of laundry detergent.
MR. MEADORS: What do you mean by that, an odor of laundry detergent?
JAMIE HALL: It just smelled freshly laundered, which is not typical of the lab. Typically clothes smell slightly musky when we get it.
MR. MEADORS: And you had examined this shirt when?
JAMIE HALL: On June 8th of 2021.
MR. MEADORS: And you didn't know -- did you have any knowledge about this case whatsoever?
JAMIE HALL: I just knew that they had asked to make it a priority in the lab.
MR. MEADORS: And you attempted to collect particle lifts from that shirt.
JAMIE HALL: I did collect particle lifts from the shirt, yes, sir.
MR. MEADORS: Next, State's 425. I'm sorry we're out of order here. This is also your clothing worksheet?
JAMIE HALL: Can I see the top of that sheet? I'm sorry.
MR. MEADORS: That's all right.
JAMIE HALL: Oh, yes, sir.
MR. MEADORS: And what was this that you examined?
JAMIE HALL: This was the worksheet we generated when we collected from a seatbelt that was collected from a 2021 Chevy Suburban, South Carolina tag CZL420.
MR. MEADORS: And I think we have it marked for ID only. It's right here on top. Thank you.
MR. MEADORS: Do you recognize this? Strike that, sorry. The seatbelt, State's 100.
(Break in proceedings.)
MR. MEADORS: State's 100, can you look at this and see if you examined before, and does it relate to your testimony?
JAMIE HALL: Yes, sir. This was SLED Item Number 142, and it also has my date and initials on it as well.
MR. MEADORS: All right. What did you do with State's 100?
JAMIE HALL: At the direction of the analyst Megan Fletcher, I collected samples from various areas on the seatbelt.
MR. MEADORS: And can you tell the ladies and gentlemen of the jury, how did you determine where you were going to collect samples?
JAMIE HALL: Since this was not our typical item, I collected from areas in which Megan instructed me to collect.
MR. MEADORS: Which was where?
JAMIE HALL: We collected from the buckle, three different areas of the belt, and the latch plate.
MR. MEADORS: Can you show the jury where you collected?
JAMIE HALL: Yeah. So, this, I believe, was what we call the latch plate, sorry if I'm misspeaking on that, but -- and then the buckle was -- oh gosh -- this area here, and we did the top and bottom of it. And the three sections were just -- we measured the length for each section, did a section, rolled more out, and did the next section.
MR. MEADORS: And how were you actually doing it with the particle lifts? How were you collecting this?
JAMIE HALL: So as stated before, the particle lifts had the double-sided adhesive on it, and you just repeatedly dab that across the garment with the item that you're collecting until it loses it's adhesive abilities.
MR. MEADORS: 100 we would offer, Your Honor.
MR. GRIFFIN: No objection, Your Honor.
JUDGE NEWMAN: Admitted.
MR. MEADORS: Thank you.
(SEATBELT MARKED AS STATE'S EXHIBIT NUMBER 100 WAS RECEIVED INTO EVIDENCE.)
MR. MEADORS: In looking back on the sheet that's noted here, that's where you went through and did your inventory sheet, correct?
JAMIE HALL: Yes, sir.
MR. MEADORS: All right, and this is to document you did what you did, right?
JAMIE HALL: Yes, sir.
MR. MEADORS: Now, did you also have an occasion to examine the pants in this case that's already, I believe, in evidence?
JAMIE HALL: I did collect from some cargo shorts.
MR. MEADORS: Okay, and those were also included on what I just took down off the ELMO, but can you tell the folks where you collected, or tried to collect, lifts off the cargo shorts and why you collected in those areas?
JAMIE HALL: Yes, sir. For any type of pants or shorts, we always collect from the right groin and the left groin area. Again, that's the area that's closest to the discharge of a firearm.
MR. MEADORS: And that's standard? That's what you do?
JAMIE HALL: That is standard practice.
MR. MEADORS: Now, did you --
(Break in proceedings.)
MR. MEADORS: 419 without objection, Your Honor.
JUDGE NEWMAN: Is that correct, Mr. Griffin?
MR. GRIFFIN: Yes, Your Honor.
JUDGE NEWMAN: It's admitted.
(SHOES MARKED AS STATE'S EXHIBIT NUMBER 419 WERE RECEIVED INTO EVIDENCE.)
MR. MEADORS: Would you mind opening it up for us? Well, first of all, do you know whether or not you examined a pair of shoes in this case?
JAMIE HALL: I did, and these are the shoes, SLED Item Number 21.
MR. MEADORS: Would you please open that for the ladies and gentlemen?
(Break in proceedings.)
MR. MEADORS: Before you're cutting that, do you see JEH on here?
JAMIE HALL: Yes, I do. On 6/8/21 I signed my initials.
MR. MEADORS: What is all of that right there?
JAMIE HALL: I believe it's yard debris.
MR. MEADORS: Court's permission to dump this right here, or can I get a trash can?
JUDGE NEWMAN: Go get a trash can.
(Break in proceedings.)
MR. MEADORS: These are State's 419 in without objection. And can you show these to the jury?
JAMIE HALL: Yes, sir.
MR. MEADORS: Show the jury what you -- I -- show the jury what you --
JAMIE HALL: So with shoes, when we collect from them, we're going to collect, again, to the area that would be closest to the discharge of the firearm, so the farthest shoe. So, in this case I would do the area where the laces would typically be and the front toe. Depending on how well the adhesive continues will depend on how far back I go, but I start with the toe and then work my area down the sides.
MR. MEADORS: Is this the condition they were when you saw them on June 8, 2021?
JAMIE HALL: There was more grassy type material on them when I had them.
MR. MEADORS: Okay, and what I just dumped in the trash can, with the Court's permission, and in here, did you indicate on your comments section --
JAMIE HALL: Yes.
MR. MEADORS: -- whether or not yard debris was present?
JAMIE HALL: Yes, sir. I commented that shoes were wet with yard debris present.
MR. MEADORS: Wet with yard debris?
JAMIE HALL: Yes, sir.
MR. MEADORS: Did you on June 8th -- now, go back in your mind. When you saw these, in addition to wet and yard debris, did you make any other notes in the comments section about those shoes?
JAMIE HALL: I did not.
MR. MEADORS: Do you remember, did you see anything that looked like blood?
JAMIE HALL: I did not make any note of that, no, sir.
MR. MEADORS: With your naked eye.
JAMIE HALL: No, sir.
MR. MEADORS: Top or bottom.
JAMIE HALL: No, sir.
MR. MEADORS: Okay. Did you have any other items that you examined that were presented to you for examination either by yourself or with Megan Fletcher?
JAMIE HALL: Yes, sir.
MR. MEADORS: What was that?
JAMIE HALL: It was SLED Item Number 173, and it was -- we described it as one blue rain jacket/poncho.
MR. MEADORS: Okay, and was this the same -- now, when did you examine the poncho?
JAMIE HALL: I believe we began on October 5th of 2021.
MR. MEADORS: Okay. So, is it fair to say that the clothes, the shirt, the pants, and the shoes, were on June 8th of 2021?
JAMIE HALL: Let me check my notes. Yes, sir, that's correct, June 8th of 2021.
MR. MEADORS: And I didn't ask you this, and I apologize. When did you examine the belt, the seatbelt?
JAMIE HALL: The seatbelt was examined on September 1st of 2021.
MR. MEADORS: Okay, and, again, the specific date for the raincoat was what?
JAMIE HALL: October 5, 2021.
MR. MEADORS: And tell the ladies and gentlemen, take us to the lab now. How did you examine that garment, the rain jacket?
JAMIE HALL: This was also not our typical garment, and I believe there was some information provided from investigations, so everything that I did in this case was at the direct -- or in this particular item was at the directed -- the direct supervision of Megan Fletcher. She essentially told me where she would like for me to collect, and she documented everything on the note sheet while I physically collected the particle lifts.
MR. MEADORS: Your Honor, 420 and 427 without objection.
JUDGE NEWMAN: Is that correct?
MR. GRIFFIN: That's correct, Your Honor.
JUDGE NEWMAN: They're admitted.
(PARTICLE LIFTS MARKED AS STATE'S EXHIBIT NUMBER 420 WERE RECEIVED INTO EVIDENCE.)
(PARTICLE LIFTS MARKED AS STATE'S EXHIBIT NUMBER 427 WERE RECEIVED INTO EVIDENCE.)
MR. MEADORS: And, Your Honor, 421 are the particle lists from the rain jacket. I believe there's no objection except for the objection they made previously.
MR. GRIFFIN: No additional objection.
MR. MEADORS: No additional objection to 421.
JUDGE NEWMAN: They're admitted.
(PARTICLE LIFTS MARKED AS STATE'S EXHIBIT NUMBER 421 WERE RECEIVED INTO EVIDENCE.)
MR. MEADORS: So, let me go back in time real quick. Are these the particle lifts you took from the seatbelt, 427?
JAMIE HALL: Yes, sir. My initials are also on each individual stub.
MR. MEADORS: And that's sort of like the officer has in the scene, you're now doing the lab, taking particle lifts, correct?
JAMIE HALL: Correct.
MR. MEADORS: Okay, and particle lists from 420, lifts from -19, -20, and -21, which I think are the pants, the shirt, and the shoes, were these the particle lifts in 420 that you actually took?
JAMIE HALL: Yes, sir.
MR. MEADORS: And again in the tubes.
JAMIE HALL: Yes, sir.
MR. MEADORS: And your initials is on it.
JAMIE HALL: Yes, sir.
MR. MEADORS: Now, 421, you said it was a little different and unusual. How did you take the particle lifts on this rain jacket?
JAMIE HALL: I believe everything was in -- considered in Megan's custody while I was doing the collection, and then it was transferred directly to my custody when I carbon coded the particle lifts. That's just a process where a thin layer of carbon was added; it allows the analyst to get better images on the instrument. It doesn't do anything to add or remove GSR. It just simply adds a layer -- a very thin layer of carbon. So, it was in my custody at that time, but prior to that it was in Megan's custody.
MR. MEADORS: Okay. I'm going to show you what's marked as 226. Is this the rain jacket that you were describing?
JAMIE HALL: If I can check the bottom cuff. Yes, sir. My dates -- the date and my initials are here in the bottom cuff.
MR. MEADORS: So, you looked at this rain jacket.
JAMIE HALL: Yes, sir, I did.
MR. MEADORS: Okay, and Megan Fletcher was with you.
JAMIE HALL: Yes, sir.
MR. MEADORS: And tell the ladies and gentlemen, how did you process? Where did you attempt to get particle lifts?
JAMIE HALL: Basically the entire garment. We marked it off in different sections, again where Megan advised me to collect from, and I repeatedly dabbed the particle lift across each section until it lost adhesive.
MR. MEADORS: These particle lifts?
JAMIE HALL: Yes, sir.
MR. MEADORS: You dabbed each one of these?
JAMIE HALL: Yes, sir.
MR. MEADORS: Okay, and what are these little things on here, these tape or the --
JAMIE HALL: I'm not sure what those are.
MR. MEADORS: Okay. Now, you did the outside of this garment.
JAMIE HALL: Correct.
MR. MEADORS: Did you do anything else to it?
JAMIE HALL: We also sampled the inside of this garment as well.
MR. MEADORS: So, you actually turned it inside out and took samples from the inside.
JAMIE HALL: That's correct.
MR. MEADORS: Okay. Megan Fletcher was with you.
JAMIE HALL: Yes, sir.
MR. MEADORS: All right. What about the hood? Did you test it or take samples from the outside of the hood?
JAMIE HALL: Yes, sir, we did.
MR. MEADORS: Did you take samples from the inside of the hood?
JAMIE HALL: Yes, sir, we did.
(Break in proceedings.)
MR. MEADORS: Beg the Court's indulgence.
(Break in proceedings.)
MR. MEADORS: I'm not wearing gloves here now, but when you're examining all of these items, do you wear gloves?
JAMIE HALL: Yes, sir.
MR. MEADORS: Does Megan Fletcher, did she wear gloves?
JAMIE HALL: Yes, sir.
MR. MEADORS: Why?
JAMIE HALL: To make sure we're not contaminating it, as well as to protect ourselves from anything that may be the on the garment.
MR. MEADORS: And as far as the -- not contaminating it, don't want to put any of your -- anything of you on that garment.
JAMIE HALL: Correct. It's standard practice for us to wear a lab coat, gloves, and if it's going to be processed for DNA later, we also wear a mask.
MR. MEADORS: And is that in a controlled environment when you attempt to get these particles?
JAMIE HALL: Yes, sir.
MR. MEADORS: Thank you, Judge, that's all.
JUDGE NEWMAN: By the defense?
MR. GRIFFIN: Yes, Your Honor, thank you.
(Break in proceedings.)
CROSS-EXAMINATION
BY MR. GRIFFIN:
MR. GRIFFIN: Good afternoon, Ms. Hall.
JAMIE HALL: Good afternoon.
MR. GRIFFIN: The -- you said that if you're going to do DNA testing, you wear a mask.
JAMIE HALL: Yes, sir.
MR. GRIFFIN: Did you wear a mask?
JAMIE HALL: Yes, sir, I did.
MR. GRIFFIN: So, to your knowledge were some of the these items processed for DNA after the GSR processing?
JAMIE HALL: It was my understanding that they had the potential for DNA analysis, yes, sir.
MR. GRIFFIN: Okay. Now, let's just talk about how you go about sampling for GSR. And you talked about the shirt and you said you would do the chest and sleeve on either side. How does that work? Do you lay the shirt out on a table?
JAMIE HALL: Yes, sir. So as I stated, the table is thoroughly cleaned, and then we place down parchment paper as well, sterile parchment paper, and lay the garment out on that so that we can access all the areas.
MR. GRIFFIN: And for the shirt here, I think it's Item 19, did you just check on the two areas at the top on the chest side or --
JAMIE HALL: Yes, sir. Unless we're given information from the investigative team or from an officer who submitted it that there is potentially a reason to test somewhere else, we only test the chest and sleeve area because that's the area that would be closest to the discharge of a firearm.
MR. GRIFFIN: And that's what you're looking for is you call it gunshot residue. Is that right?
JAMIE HALL: Yes, sir. It's microscopic so you cannot see it; therefore, we're testing the areas where we would expect to find it.
MR. GRIFFIN: And you would expect to find gunshot residue on the shoulders of a person who had recently shot a gun, I would think.
JAMIE HALL: Yes, sir.
MR. GRIFFIN: That's what you're looking for.
JAMIE HALL: That's what we're trying to find out, yes.
MR. GRIFFIN: Right, and then you did some GSR testing of a seatbelt assembly and buckle and whatnot, correct?
JAMIE HALL: Correct.
MR. GRIFFIN: Okay, and you did GSR testing of this rain jacket here, right?
JAMIE HALL: Correct.
MR. GRIFFIN: And shirt, shorts, shoes. And Officer Varnadoe, I think is his name, you received a sample from him and you just checked to be sure it was all --
JAMIE HALL: I didn't physically receive it from him, but he was the collecting officer listed on the sheet, yes, sir.
MR. GRIFFIN: Okay, and so he would have taken the sample, or whoever did it would have taken it from Mr. Murdaugh. That would be Item Number 18, I believe?
JAMIE HALL: SLED Item 18, yes, sir.
MR. GRIFFIN: And those are the samples taken from Mr. Murdaugh's hands, I take it?
JAMIE HALL: Yes, sir.
MR. GRIFFIN: Okay. Now, you can get gunshot residue on you by just simply picking up a firearm, can you not?
JAMIE HALL: Those questions would be better asked of the analyst. I can only testify to factually what I did.
MR. GRIFFIN: Okay, and the analyst here is Ms. Fletcher?
JAMIE HALL: Yes, sir.
MR. GRIFFIN: Okay. Well, let me ask you to take a look at your worksheet, which is in evidence, 423. And do you have that up there?
JAMIE HALL: Yes, sir.
MR. GRIFFIN: You know, I just -- I think I would rather put it on the ELMO so we can --
MR. GRIFFIN: Do you have it your --
JAMIE HALL: I have my copy, yes, sir.
MR. GRIFFIN: Okay, great. So, that -- go to the top right there. Agent Hall, it says that this was a brand Hanes Beefy t-shirt.
JAMIE HALL: Yes, sir.
MR. GRIFFIN: And then particle lifts right sleeve, right chest, left sleeve, left chest, correct?
JAMIE HALL: Correct.
MR. GRIFFIN: And it says: Description, paper bag containing one white t-shirt. Is that right?
JAMIE HALL: That's correct.
MR. GRIFFIN: And then, Doug, if you'll down a little bit more. Okay.
MR. GRIFFIN: And then there it says comments: small reddish/brown stains observed. Shirt had odor of laundry detergent is what it says, correct?
JAMIE HALL: Correct.
MR. GRIFFIN: Do you know what those small reddish/brown stains looked like?
JAMIE HALL: They looked like small reddish/brown stains on the shirt.
MR. GRIFFIN: Were they tested?
JAMIE HALL: I have no knowledge of what was done after I handled the object.
MR. GRIFFIN: Okay. Now, below here it says: Sealed brown paper bag containing one pair of green shorts. Is that just an entry for another item?
JAMIE HALL: Yes, sir, that's Item Number 20. The sheet is designed where we can put two items on one sheet.
MR. GRIFFIN: Okay. So, when you received the shirt, Item 19, was it in its own separate bag?
JAMIE HALL: In this case it was, yes, sir. That's why I made the note that that individual item contained its own brown paper bag, while the description says brown paper bag containing.
MR. GRIFFIN: Okay, and the shorts, those are green cargo shorts, and again you lifted, it says, right groin, left groin.
JAMIE HALL: Correct.
MR. GRIFFIN: And it's just -- I mean, it's on the -- is it on the inside of the pants leg or --
JAMIE HALL: Well, it's on the outside of the garment down to, you know, a reasonable distance, depending on the type of fabric. Could depend on how much adhesive it has, depending on how large the garment is from the person. A small garment versus a 3 XL is completely different. It just depends on how far I can go down on the garment.
MR. GRIFFIN: And then -- and to do this, you would take a sticky something or another and --
JAMIE HALL: It's a double-sided adhesive on an aluminum stub within those little vials. The bottom has a holder for that. And then we just use -- we grip it by the bottom and repeatedly dab it across the garment.
MR. GRIFFIN: Until it loses its stickiness.
JAMIE HALL: Correct.
MR. GRIFFIN: And then -- do you do one vile per area or multiple vials?
JAMIE HALL: It's one vile per area listed. If for some reason I needed to use an extra vile, or an additional vile, that would have had its own listing on the worksheet.
MR. GRIFFIN: Okay, and I take it you don't know what the results of your lifting were, do you?
JAMIE HALL: No, sir, I do not.
MR. GRIFFIN: That -- it would -- you would then finish your work and send it up the chain?
JAMIE HALL: Yes, sir. All the items were either given directly to the analyst, or they're securely stored in the Trace Evidence Lab until the analyst takes possession of them.
MR. GRIFFIN: Okay, and this blue rain jacket, you said you put carbon on it or something?
JAMIE HALL: Yes, sir. It's a standard practice for anything collected from an inanimate object. We typically get a lot of debris -- sand, dirt, or fibers -- typically from clothing, and that can cause it to be a little bit more difficult on the instrument for them to get pictures of the particles. So, the carbon just allows them to get a better picture of the carbon -- I mean, I excuse me, a better picture of the particles when they do their analysis. But it does not do anything to add or remove GSR.
MR. GRIFFIN: So, you put the carbon down before you use your sticky thing.
JAMIE HALL: No, sir. That process happens after the collection. So, it goes into a small device, and there's little rubs of carbon that are rubbed against each other inside the instrument to put the layer of carbon onto it.
MR. GRIFFIN: I see. But you're not putting carbon on the garment.
JAMIE HALL: No, sir.
MR. GRIFFIN: Got it.
MR. GRIFFIN: One second, Your Honor.
(Break in proceedings.)
MR. GRIFFIN: Ms. Hall, are you involved in any way with DNA processing?
JAMIE HALL: No, sir, I'm not.
MR. GRIFFIN: Okay, and so you don't know whether any of the items were processed for DNA.
JAMIE HALL: I have no knowledge of where the items went after they left my department.
MR. GRIFFIN: Okay.
MR. GRIFFIN: Thank you so much.
JAMIE HALL: You're welcome.
JUDGE NEWMAN: Any redirect?
MR. MEADORS: No, sir. Thank you.
JUDGE NEWMAN: Thank you. You may step down.
JAMIE HALL: Thank you.
(The witness exited the stand.)
JUDGE NEWMAN: Unless you have a two minute witness, this will be it for today.
MR. WATERS: We don't, Your Honor, unfortunately.
JUDGE NEWMAN: All right, ladies and gentlemen, that will do it for this day. We'll resume at 9:30 tomorrow morning. Please do not discuss the case.
(The jury left the courtroom.)
JUDGE NEWMAN: Everyone will be seated. Mr. Harpootlian, concerning the item that you were objecting to the testing.
MR. HARPOOTLIAN: Yes, sir.
JUDGE NEWMAN: Is that the -- what exhibit number is that?
MR. HARPOOTLIAN: Just the rain jacket, Your Honor --
MR. WATERS: 226, Your Honor.
MR. HARPOOTLIAN: -- not the t-shirt, not the shorts, not the shoes.
JUDGE NEWMAN: And regarding the same, number 226, rain jacket, is the same item that Mr. Griffin cross-examined the previous witness concerning?
MR. HARPOOTLIAN: Ms. Smith?
JUDGE NEWMAN: Ms. Smith concerning?
MR. HARPOOTLIAN: Yes, he cross-examined her extensively about whether she ever -- first of all, was that the rain jacket in his hands when he came in that morning; two, had she ever seen him with that rain jacket; and three, did she -- when she looked into the closet, did she know whether it was a tarp or whether it was a rain jacket, was it the same color, she said it was the same color. That's it. And we think the prejudicial outweighs the probative.
JUDGE NEWMAN: I also recall Mr. Griffin questioning her as to whether it appeared there was a gun or different things in it?
MR. GRIFFIN: No, Your Honor. I questioned her as to the tarp. This witness, Ms. Shelley Smith, has never -- they never showed her the rain jacket. She has never identified the rain jacket, and when asked in court here's a photo of that rain jacket, she says, Your Honor, that is not what he had. And what's so prejudicial is they have introduced GSR, and they will introduce an expert tomorrow who will say it's covered with GSR, and that is extremely prejudicial. They have no evidence connecting Mr. Murdaugh to that rain jacket, and the only witness they relied upon to get a search warrant, Your Honor, says that he came in with a tarp. I questioned whether in the tarp it looked like there was a gun in the tarp. She says no. She says he went upstairs, he came down, he laid the tarp open on his mother's retirement rocking chair, and she leaves that day, and she sees the tarp laid out, and it's a tarp that looks like it goes over a car. And now they're coming in, showing her a photo of something in a closet that they seize and says it looks like a tarp. Does it look like what you saw, and she says, well, it's blue. And now they're putting in GSR on an item in a house he doesn't live in, on an item he's never had in his possession to the best of anybody's knowledge, and that's the basis for our objection, Your Honor.
JUDGE NEWMAN: Yes, Mr. --
MR. WATERS: So, Your Honor, again, if you look at the testimony in its entirety, Ms. Smith describes --
JUDGE NEWMAN: One second.
(Break in proceedings.)
JUDGE NEWMAN: Yes, sir.
MR. WATERS: She testified, of course, that Alex Murdaugh had showed up early in the morning, which was highly unusual. He was carrying what appeared to be a blue tarp balled up, and then she was shown a picture in the closet where it's balled up and says that looks like the item. Now, when it was pulled up and shown by them, she said that's not necessarily what I saw, but she did recognize the balled up item and the balled up item in the closest, which the investigator said that's how they recovered it. She did identify that picture. And then if you put the two chains of evidence together, that's what the investigator recovered that she identified. Now, certainly they can argue to the jury whether or not that's the right tarp or not, but she did say that that is consistent with what I saw all balled up, which is the only way she saw it. Again, this is also evidence that, you know, was admitted and has been extensively examined before the jury, Your Honor. So, certainly they can argue all of these points to the jury, but there's enough of a chain that's been established by the testimony for it to be submitted to the jury.
MR. HARPOOTLIAN: Your Honor, might I make a suggestion?
JUDGE NEWMAN: Yes, sir.
MR. HARPOOTLIAN: We're getting daily transcripts, perhaps overnight before they -- the prejudicial thing is the witness they're going to put up tomorrow. I would suggest perhaps you could look at that daily transcript of her testimony alone, and I don't believe, I submit, she said what he said, maybe what he wished she said, but I don't believe she said what he said. Your Honor, I think Mr. Waters is arguing this. I don't believe Mr. Waters has a dog in this.
MR. WATERS: My apologies, Your Honor.
MR. HARPOOTLIAN: It's 5:20. I just thought maybe this was a simple solution. He's going to say this is what she said; we're going to say this is what she said. I think she never said that what was in the closet is what he carried. But -- and, of course, we have a court reporter that can, I guess, not type it tonight, but perhaps give you audio of it, but it's a very simple question. It boils down to what she said about what she saw in the closet because clearly she said that when shown a picture, that's not what he walked in with. He walked in with a tarp, which he left over a chair. And, you know, other than their supposition that he somehow brought that rain jacket in, wadded it up, and threw it up in the closet, there's no evidence that there was a gun, no evidence that anything was balled up in it. They want to make a giant leap of logic if -- I mean, it's not circumstantial evidence of anything. So, I would ask the Court to perhaps look at the daily transcript -- somebody's got one right there -- and just look at her testimony. Not all of it, just her -- or even a piece of her testimony: what did she see in the closet in response to Mr. Meadors's question. Now, Mr. Meadors believes she said something and Mr. Waters believes she said something different, but the proof is in the pudding, as you say, or whatever the legal -- I would suggest strongly that maybe overnight look at it and let us know what you think.
JUDGE NEWMAN: Mr. Meadors, you had something?
MR. MEADORS: With the Court's permission?
JUDGE NEWMAN: Or Mr. Waters?
MR. MEADORS: I think -- and I guess on redirect through their investigator's transcript, I think they were asked -- I asked her if they had asked her about whether it could contain a firearm and she said, well, I don't know. But that was brought out, I think, which was directly from their investigators who asked her about it. So, that, I think, made it relevant. They certainly thought it was relevant when they were interviewing her. So, that's why we do think it's relevant, and we hope Your Honor will let us keep going tomorrow with the GSR to see if there's anything potentially in the rain jacket that has GSR evidence.
JUDGE NEWMAN: All right. Okay. We'll adjourn for this day.
(Whereupon, the case was at ease.)