IN THE COURT OF COMMON PLEAS
OF PHILADELPHIA COUNTY, PENNSYLVANIA

_____________________________________

COMMONWEALTH OF PENNSYLVANIA,
CRIMINAL DIVISION

Respondent,

v.

Nos. 1357-1358
MUMIA ABU-JAMAL,
(January Sessions, 1982)
a/k/a Wesley Cook,

Petitioner

_____________________________________

PETITIONER'S SUPPLEMENTAL OFFERS OF PROOF

Petitioner Mumia Abu-Jamal ("Jamal"), by his attorneys, respectfully submits the following supplemental offers of proof in support of the offers made on the record and denied in the course of the June 26, 1997 to July 1, 1997 remand hearing. Jamal also submits this memorandum to protest the unfairness of the proceedings and the court's rulings precluding the presentation of the defense case concerning Pamela Jenkins' testimony.

The Court's Improper Limitation on the Scope of the Remand Hearing

The Supreme Court of Pennsylvania granted Jamal's request for a remand "for the limited purpose of taking additional testimony with respect to Pamela Jenkins." (May 30, 1997 Order; emphasis added.) As Jamal explained in his Memorandum on Status and Scope of Remand Hearing, the scope of the remand hearing plainly encompassed the issues raised by Jenkins' testimony as set forth in Jamal's remand application: (1) that "in late 1981 police had pressured [Jenkins] to perjure herself and falsely identify Jamal as the shooter in this case -- despite the fact that Jenkins had not even been present at the scene" (Application, ¶ 3); (2) "that police applied improper pressure and threats to secure [Cynthia] White's testimony" (Application, ¶ 4); and (3) that "Jenkins' description of police intimidation of prostitutes fits the pattern of police/prostitution activities in Philadelphia's center city area at that time, exemplified by the testimony concerning police intimidation and manipulation of two prostitute eyewitnesses at trial, Cynthia White and Veronica Jones, and by the federal investigation of police corruption in the center city area in the early 1980's" (Application, ¶ 5). In addition, Jamal offered to present evidence that the Commonwealth has instituted a retaliatory prosecution of Jenkins in response to the Supreme Court's May 30 remand order. (Memorandum on Status and Scope of Remand, pp. 3-4.)

Despite the clear mandate of the Supreme Court's order, this court repeatedly insisted that Pamela Jenkins would be the only witness permitted to testify, and on this basis the court peremptorily quashed Jamal's numerous witness and document subpoenas:

THE COURT: What further proceedings? We are here for a limited purpose: To take the testimony of Pamela Jenkins. That's all. I am not hearing anything else, do you understand? . . . I don't care who you subpoenaed. They are quashed. I am here only for Pamela Jenkins. That's what the Supreme Court sent it down for and that's all I am hearing.

Mr. WEINGLASS: So that we are clear at the beginning: We are only to call Pamela Jenkins?

THE COURT: That's all.

Mr. WEINGLASS: And we are precluded from all the others?

THE COURT: Right.

Mr. WEINGLASS: All the subpoenas are quashed?

THE COURT: They are quashed. I don't even know what subpoenas you issued.

(Tr. 6/26/97: 7-10.) [1]

The defense called Pamela Jenkins, who confirmed the testimony presented in her verified statement:

• that in 1981 Cynthia "Lucky" White was a police informant (and was also providing her services as a prostitute for police) (id: 47, 55);

• that in late 1981 White told Jenkins she was being pressured by police in connection with this case and that White feared for her life (id: 48);

• that police pressured Jenkins to falsely identify Jamal as the shooter (despite knowing that Jenkins was not even at the scene) (id: 44, 46); and

• that police paid Jenkins to locate White, who had disappeared (id: 48-49).

Jenkins further testified that she had seen Cynthia White in Philadelphia in 1997, and that she last saw White in the company of former Philadelphia police officer Tom Ryan and Det. Richard Ryan, the same officers who Jenkins said pressured her to falsely implicate Jamal in the 1981 shooting. (Id: 50-51.)

When Jenkins' testimony was concluded, this court indicated that the parties should return to the Supreme Court. (Id: 131.) At this point, the prosecution "joined in [defense] counsels' motion that they be permitted to call additional witnesses." (Id.) Even then, the court refused to permit the defense to present any further evidence concerning Jenkins' testimony. Nonetheless, the court agreed to permit the prosecution to present evidence to respond to Jenkins' testimony. (Id: 132-34.) At this point defense counsel accurately objected "to being precluded and the prosecution is being allowed to go ahead." (Id: 134.)

From this point forward, despite the defense objections, the hearing ceased to be conducted as an adversarial proceeding. Instead, the hearing became little more than a dialog between the prosecution and the court on how best to preclude the defense from presenting evidence to corroborate Jenkins or to refute the prosecution's "rebuttal" evidence. The defense was totally precluded from presenting any witnesses other than those agreed to, or invited by, the prosecution.

On the other hand, the prosecution was given an open door to call witnesses, but declined to present any evidence pertaining to the central focus of Jenkins' testimony -- that Cynthia White was a police informant who had been pressured by police to falsely identify Jamal as the shooter. Instead, the prosecution claimed that Jenkins' testimony was incredible and thus irrelevant because a "Cynthia Williams" who was supposedly really "Cynthia White" had died in 1992 and thus Jenkins' claim of having seen White in 1997 was "perjured." (Tr. 6/30/97: 120.)

Because he was prevented from presenting evidence to corroborate Jenkins or to refute the prosecution's claims, Jamal submits the following supplemental offers of proof and verified statements to support his efforts to present evidence on these issues.

Evidence Concerning the 1992 Camden Death of "Cynthia Williams"

On Thursday, June 26, the prosecution presented supposed "self-authenticating" documents which purportedly conclusively established the death of Cynthia White in Camden, New Jersey, in 1992. This evidence, presented through Homicide Detective Raleigh Witcher, consisted of a Philadelphia police printout of Federal Bureau of Investigation ("FBI") computer data, along with a death certificate of "Cynthia Williams," aka "Mildred Saunders" in Camden, New Jersey.

Det. Witcher claimed that the FBI computer records contained fingerprint data which "matched" the fingerprint information for Cynthia White in Philadelphia police files, and that the FBI information showed that, according to New Jersey records, this person was "deceased." (Tr. 6/26/97: 143, 178.) Det. Witcher further produced a prosecution exhibit which was an amalgam of various documents, but which the prosecution falsely asserted was a "self-authenticating" document bearing the "seal from the State of New Jersey." (Id: 143.) This exhibit included a purported death certificate for "Cynthia Williams, a\k\a Mildred Saunders," with a social security number of 127-50-6809, a number also listed in Philadelphia and FBI records as one of the numbers used by Cynthia White. (Id: 145.) Det. Witcher claimed that there was a fingerprint "match and it's authenticated in the FBI report here." (Id: 178-79.) Based on this evidence, the prosecution repeatedly claimed to have "proved" that Cynthia White was dead, and the court accepted that claim.

However, on cross-examination, the defense established that the exhibits provided by Det. Witcher were not the complete and conclusive "self-authenticating" proof which the prosecution claimed. To begin with, Det. Witcher claimed that the identification of the dead Camden woman, "Cynthia Williams," and the Philadelphia witness, Cynthia White, was established through fingerprint matches. Det. Witcher explained that Cynthia White's fingerprint class numbers were included in Commonwealth Exhibit 2, the FBI computer printout and which matched White's fingerprint information in the Philadelphia identification system files. (Id: 154-55.) Yet despite this claimed fingerprint "match," the prosecution and Det. Witcher did not bring the alleged fingerprint cards from either Philadelphia or Camden to court. (Id: 154, 178.) The reason, as it later became clear, was that there was in fact no such fingerprint "match" between the Philadelphia and the New Jersey fingerprints.

Det. Witcher also was forced to concede that the FBI printout report was incomplete because additional information could have been, but was not, generated through that system. (Id: 170.) Det. Witcher further acknowledged that the FBI report was not generated based on fingerprint information. (Id: 177-78.)

Moreover, the defense was not provided with a copy of the prosecution documents until after Det. Witcher left the stand. On further review, it was clear that Commonwealth Exhibit 4 was not the "self-authenticating" record which the prosecution claimed. Instead, it was an amalgam of several incomplete pages from several documents from various sources stapled together to create the impression of an official record which never in fact existed:

• The first page of the document was a partial copy of a death certificate. This page was not copied in its entirety, and was missing an important line indicating that the key identification information was provided "by Funeral Director," not by public officials. On the back, this incomplete death certificate page bore a seal dated April 21, 1997.

• The second page of the document was an unsealed, faxed copy of a Report of Death bearing a fax line "Jan-04-00,"

• The third page of the document was an unsealed fax cover page from the Camden County Medical Examiner to "Ken Curcio, Prosecutor's Office."

Plainly the sealed certificate of death and the attached fax pages were taken from different documents, and the prosecution had simply stapled them together to create the false impression of a single "self-authenticating" sealed document.

On top of all these peculiarities with the Commonwealth's documents, Det. Witcher admitted that the prosecution team had been searching for Cynthia White since 1995. (Id: 149, 164.) Det. Witcher personally was involved in searching "records both local and out of the locale. We did not locate her." (Id: 149-51.) The detective claimed that he first became aware of the Camden death certificate on about May 30, 1997, when "someone came up with" it. (Id: 148.) Obviously, the prosecution identification team had access to the FBI database throughout their search for Cynthia White (id: 177, 7/1/97: 84), and would not have continued searching records for her if they believed the New Jersey death report was accurate and that the Camden deceased was in fact Cynthia White.

During the defense "rebuttal" case, the court and prosecution precluded the defense from presenting its own witnesses who had information that Cynthia White was alive, thus refuting the claim that White had died in Camden in 1992. The prosecution refused to provide the defense with its own files on Cynthia White or with the Camden files on the Camden death. Of course, without access to this information in its totality, the defense lacked a fair ability to test the prosecution claims. Instead, the court permitted the prosecution to spoon feed just those pages which the prosecution elected to disclose, while withholding the bulk of the documents. The court further denied the defense any ability to subpoena the necessary, withheld information. In this manner, the prosecution insisted that the defense should call certain unidentified "New Jersey" officials whom the prosecution would choose. But the prosecution would not produce the underlying files, or even identify the New Jersey officials. The defense refused to proceed on such an unfair basis, and rested.

Then, apparently aware that the purported "proof" of White's death was not conclusive or even genuine, the court and the prosecution "reopened" the hearing on July 1, 1997 to "verify" the death of Cynthia White. Once again the prosecution presented documentary evidence from the Camden County prosecutors office and claimed that the fingerprints of the black female who died in Camden "matched" the fingerprints of another black female identified as "Cynthia Drake," and reportedly also known in Camden as "Cynthia Williams" or "Mildred Saunders" or "Cynthia White" or many other names. (Commonwealth Exhibit 8; Tr. 7/1/97: 29.) [2]

Yet the documents themselves refuted the claim that this New Jersey woman was in fact the Philadelphia witness Cynthia White. The fingerprint information for the Philadelphia witness Cynthia White was demonstrably different from that of the dead New Jersey woman. Det. Witcher testified that the fingerprint identification information which "matched" the Philadelphia identification records for Cynthia White was that contained on Commonwealth Exhibit 2:

PM 11 12 CO 16 DO 08 13 PI 18

But this fingerprint information does not match the fingerprint codes of the woman who died in Camden in 1992, as reflected in the Camden prosecutor's files relied on by the Commonwealth (Comm. Exh. 8, Camden ID card):

PM 13 12 17 16 PO 18 13 CI 20

Comparing these identifiers side by side shows that fully six out of ten fingers (in bold) have entirely different fingerprint classifications, precluding any possibility of a fingerprint "match": [3]

Philadelphia: PM 11 12 CO 16 DO 08 13 PI 18
Camden: PM 13 12 17 16 PO 183 13 CI 20.
(See Tr. 7/1/97: 49-51.)

Moreover, the Camden County version of the FBI computer printout report for "Cynthia White" bears the repeated caution: "This response is not supported by fingerprint comparison." (Id: 32, 35.) The defense contended that the prosecution had manipulated the FBI computer data to delete this same warning from Commonwealth Exhibit 2 -- and this defense contention was confirmed by the Camden printout. In other words, there is no fingerprint confirmation that the person known as "Cynthia Drake" or "Cynthia White" or "Cynthia Williams" or "Mildred Saunders" in New Jersey criminal records is the same person known as "Cynthia White" in Philadelphia. [4] Hence there simply is no fingerprint confirmation or otherproof that the Camden deceased is the Cynthia White who testified in this case.

Without fingerprint identification, there is no identification, as the prosecution's own witnesses indicated. "[F]ingerprints are the one true identifier." (Id: 63.) Certainly the other information provided about the New Jersey deceased is insufficient to support an identification. There was no eyewitness identification of the body. The social security number attributed to the deceased -- 127-50-6809 -- was issued to a Hispanic woman named Migdalia Cruz, born in Puerto Rico in 1957, who is not Cynthia White. (See Milton Ver. St. (Exh. 2).) The prosecution has also refused to produce all the photographs contained in the Camden files. (Tr. 7/1/97: 22.) Moreover, the body itself has been cremated and the New Jersey files have been purged, making verification of the identification impossible. [5]

The sequence of the identification process was also suspect, as shown by the three different revisions of the death certificate contained in the Commonwealth exhibits. First, the medical examiner filled in some portions of the death certificate and identified the deceased as "Cynthia Williams." This name apparently was based on a Camden County welfare card which was found in a closet in the abandoned house where the body was discovered. (Comm. Exh. 8.) The further information on later revisions of the death certificate was provided not by Camden officials but by the Boyd Funeral Home. This information apparently came from a phone call by Detective Boyd of the Camden Police Department. Det. Boyd called a Mrs. Ruth Ray in Brooklyn, New York, and asked if she knew "Cynthia Williams." Mrs. Ray said she did not know such a person, but that she knew someone in Camden called Mildred Saunders. Later Det. Boyd called back to say that the deceased was Mildred Saunders. (See Ruth Ray Ver. St. (Exh. 3).) After this call from Det. Boyd, the Boyd Funeral Home began pressuring Mrs. Ray to send money to pay for the burial of the deceased. The Funeral Home also completed the death certificate with the information that "Cynthia Williams" was "aka Mildred Saunders."

There are many other small but telling inconsistencies on the face of the prosecution's exhibits. The Camden identification reports for "Cynthia Drake" -- the dead woman -- show that she had a surgical scar on her right arm, but not the left. The autopsy for the dead woman describes a scar on the left arm, but not the right. Commonwealth Exhibit 2 indicates that Cynthia White has a scar on her nose -- a mark not mentioned in any of the New Jersey information. These contradictions -- which come from the face of the prosecution's own exhibits -- defeat the prosecution claims to have "proved" the death of Cynthia White. Moreover, the prosecution withholds the bulk of its files on White, including its efforts to locate this witness over the past several years. These circumstances once again point to the need for full disclosure of the prosecution and police files on this case and on this witness.

Thus, despite the prosecution's claims of conclusive and "self-authenticating" proof -- which were accepted as good coin by the court (Tr. 6/30/97: 140, 7/1/97: 13, 87-88) -- the prosecution's evidence proved nothing. Because the prosecution's claims were so vulnerable, the court and prosecution cooperated to prevent the defense from presenting evidence on the issue of Cynthia White's alleged death. Jamal renews and supplements his offers of proof on this issue with the attached verified statements:

• Verified Statements of Donald Burton (Exhibit 1). Private investigator Donald Burton had been retained by the defense to search for Cynthia White beginning in December 1996. Burton located several individuals in north Philadelphia who identified a photograph of Cynthia White as "Lucky" or "Gloria" and verified that she was alive and still frequented that neighborhood. Burton also obtained information that Mildred Saunders aka Cynthia White had died in New Jersey in November 1992 but that this identification was "not verified by fingerprints." Burton investigated this information but was told by the New Jersey Bureau of Vital Statistics and local officials, including Camden County, that there was no such death report. Burton was able to locate a death report for a Mildred Saunders who died in Newark, New Jersey at age 70. Burton also located other individuals with the name Cynthia White or Mildred Saunders and similar birth dates to those used by the witness Cynthia White, but who were not in fact the witness Cynthia White. Burton's second verified statement further verifies that not all photographs contained in the Camden files were produced by the Philadelphia prosecutor in court.

• Verified Statement of Christopher Milton (Exhibit 2). Defense investigator Milton verified that social security records show that the social security number 127-50-6809 contained in the Camden, New Jersey death certificate for "Cynthia Williams aka Mildred Saunders" was actually issued to a woman named Migdalia Cruz, who was born in Puerto Rico on May 25, 1957. The social security number 127-50-6808, also used by Cynthia White, was issued to a Mildred Saunders who was born in Savannah, Georgia on May 13, 1958. There was no record of death for either of these individuals. Milton also spoke to people in Philadelphia at addresses provided by Cynthia White in Philadelphia court records and was told that she was still alive and still known as "Lucky" in 1995. Milton also located another individual named Cynthia White who lived at one of these addresses given by the witness Cynthia White in Philadelphia court files.

• Affidavit of Ruth Ray (Exhibit 3). Ruth Ray, who is listed on the Camden death certificate as the "mother" of the deceased, would testify that she is not (and never claimed to be) the mother of Mildred Saunders or Cynthia Williams. In reality, she was someone who knew a person named Mildred Saunders in Brooklyn. When Camden officials called her to inquire about a dead drug user in Camden, Ray suggested that it might be Mildred Saunders. But that suggestion is no proof of identification. On the contrary, the eagerness of Boyd Funeral Home to collect money to bury the deceased helps explain why this funeral home may have misidentified the body.

• Verified Statement of Stewart Reiser (Exhibit 4) and Testimony of Charles Grant. The defense sought to present the testimony of prosecutor Charles "Joey" Grant that he personally called prison officials and others in Massachusetts and other states in an effort to locate Cynthia White in 1995. This testimony, combined with the admissions of Det. Witcher, confirms that the prosecution team was actively looking for Cynthia White despite their access to the Camden death certificate reported in the FBI's national database. This is further corroborated by the verified statement of Stewart Reiser based on his discussions with officials at Framingham prison in Massachusetts.

Evidence Corroborating The Substance of Pamela Jenkins' Account

The court not only precluded the defense efforts to refute the claimed "death" of Cynthia White, but also prevented the defense from presenting substantive corroboration of Pamela Jenkins' testimony that Cynthia White was a police informant in 1981 and that police pressured Jenkins and White to give false testimony in this case. Jamal renews and supplements his offers of proof as follows:

• Verified Statement of Marcus Cannon (Exhibit 5). Cannon was an eyewitness present at 13th and Locust at the time of the shooting of officer Faulkner. He saw two white males, one dressed as a homeless man and another as someone who apparently was looking for a pickup. However, after the shooting these two men transformed themselves, immediately pulling weapons and approaching the scene after shots were fired. These individuals were apparently off-duty or plainclothes police officers, corroborating Thomas Ryan's statement to Pamela Jenkins that several officers were present at the scene, and consistent with the testimony of P. O. Boston. Yet any information regarding these officers or their statements has been withheld from the defense.

• Verified Statement of Jessie Milliner (Exhibit 6). Pamela Jenkins' grandmother, Jessie Milliner, would testify that Jenkins and Thomas Ryan were already having a relationship by at least the Fall of 1981, corroborating Jenkins and refuting the self-serving testimony of Ryan that they first met in 1982.

• Correspondence from Joel Goldstein (Exhibit 7). Assistant United States Attorney Joel Goldstein confirms in his July 27, 1997 letter that the prosecution has possession of prior statements of Pamela Jenkins and Thomas Ryan regarding the nature and timing of their relationship. Despite repeated defense requests, the prosecution refuses to turn over these prior statements of these two remand witnesses.

• Cynthia White Court Files. Jamal offers the following court records which show that Cynthia White was arrested six times in 1980 and 1981 by police officers Richard Herron and Joseph Gioffre, Sixth District officers who were later convicted of corruption in extorting money from central city prostitutes.

  5/29/80 MC # 8005-2895
  7/8/80 MC # 8007-0195
  6/24/80 MC # 8006-2855
  3/6/81 MC # 8103-0493
  4/6/81 MC # 8104-0062
  7/19/81 MC # 8107-1610
  

In addition, Jamal offers White's court files demonstrate that she used the alias "Lucky," as testified by Veronica Jones and Pamela Jenkins, a fact the Commonwealth has stubbornly and falsely denied. See MC # 8005-2895 (5/30/80) (alias "Lucky"); MC # 8007-0195 (alias "Lucky"); MC # 8007-0475 (alias "Lucky"). Jamal had subpoenaed these files at the 1996 remand hearing and again in 1997, but the Court quashed both subpoenas and refused to accept the documents.

• Court Records of Central City Police Corruption Convictions. Jamal offered to present the indictments and convictions of Central Division police on charges pertaining to extortion from prostitutes during the period 1981-82, including Central Division inspector Joseph DeBenedetto, Central Division officers George Woods and Raymond Emery, and Sixth District officers Richard Herron and Joseph Gioffre.

• Cynthia White Preliminary Hearing (Exhibit 8). Jamal also offers the entirety of the June 29, 1987 hearing in Com. v. White, MC # 87-06-2351, in which a prosecution witness testified that he was assaulted by White and that when he complained to a center city police officer, "the police officer knew her by her first name and said I shouldn't be messing with her." (Tr. 6/29/87: 10.)

• Kenneth Freeman Court File. The court file in Com. v. Freeman, MC #8202-2557, reflects that Central Division detective Richard Ryan (# 971), together with Central Division officer J. Forbes (#9811), arrested Kenneth Freeman on February 19, 1982, and that Freeman hid himself in his attic with a .22 calibre pistol and explosives. P. O. Forbes was one of the officers on the scene of the shooting in this case. This evident connection between Ryan and William Cook's vending stand partner, Kenneth Freeman, corroborates Pamela Jenkins' testimony that Ryan was connected to this case. However, the court quashed Jamal's subpoena for this file.

CONCLUSION

By preventing the presentation of this defense evidence, quashing the defense subpoenas, and denying the defense discovery, even as the prosecution presented unauthentic and partial documents and withheld clearly relevant evidence and information, this court has once again denied Petitioner the elementary ability to obtain a full and fair hearing on his claims. A full and fair hearing in this matter can begin only when the prosecution and police files, in their entirety, are produced for inspection by the defense. Respectfully submitted,

LEONARD I. WEINGLASS
6 West 20th St., Suite 10A
New York, New York 10010
(212) 807-8646

DANIEL R. WILLIAMS
Moore & Williams, LLP
740 Broadway Suite 500
New York, New York 10003
(212) 353-9587

JONATHAN B. PIPER
Sonnenschein, Nath & Rosenthal
8000 Sears Tower
Chicago, IL 60606
(312) 876-8000

RACHEL H. WOLKENSTEIN
67 Wall Street, Suite 2411
New York, New York 10005
(212) 406-4252

STEVEN W. HAWKINS
National Conference of Black Lawyers
918 F Street, N.W.
Washington, D.C. 20004
(202) 347-2411

DAVID RUDOVSKY, Local Counsel
Bar No. 15168
Kairys, Rudovsky, Kalman & Epstein
924 Cherry Street, Suite 500
Philadelphia, PA 19107
(215) 925-4400

Attorneys for Petitioner Mumia Abu-Jamal Dated: July 14, 1997

PROOF OF SERVICE

I hereby certify that I am this day serving the foregoing document upon the persons and in the manner indicated below which service satisfies the requirements of Pa. R. A. P. 121:

Service by United States Mail addressed as follows:

Hugh J. Burns, Jr., Esquire
(counsel for District Attorney of Philadelphia County)
Assistant District Attorney
1421 Arch Street
Philadelphia, Pa. 19102
(215) 686-5728

Dated: July 14, 1997

Jonathan B. Piper
Sonnenschein Nath & Rosenthal
8000 Sears Tower
Chicago, Illinois 60606
(312) 876-8000
(Counsel for Appellant Mumia Abu-Jamal)
(Pro Hac Vice)

Footnotes:

1. The court made clear its frustration that Jamal was being permitted a supplementary hearing at all: "Have you ever heard of a PCRA that has come back for a remand two times? Two times?" (Id.: 11.)

2. The documents reflecting the fingerprint identification information for the deceased Camden woman were listed under the name "Cynthia Drake," which did not appear on the death certificate.

3. On some of the other Camden reports the sixth identifier is listed as "08."

4. The information provided by both prosecution and defense investigators concerning their efforts to locate Cynthia White -- combined with the information provided in 1996 by defense investigators concerning their efforts to locate Veronica Jones -- demonstrate that it is common for prostitutes and drug users to use a variety of aliases and false social security numbers in their dealings with police. The widespread use of aliases demonstrates the unreliability of any identification based on data other than fingerprints -- as the Commonwealth's own witnesses testified at this remand hearing.

5. The prosecution presented no details about the specific method of fingerprint identification allegedly used by New Jersey to identify the Camden fingerprints. As a result, there is no basis on which to determine whether the New Jersey identification was based on generally-accepted scientific methods or has any reliability.

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