STATE OF SOUTH CAROLINA. COURT OF GENERAL SESSIONS COUNTY OF COLLETON FOURTEENTH JUDICIAL CIRCUIT State of South Carolina, Indieament Nos. 2022-GS-15-00592, -593, $94, and -595 MOTION FOR SANCTIONS Richard Alexander Murdaugh, Defendant Defendant Richard Alexander Murdaugh, through undersigned counsel, pursuant to Rule '5(@)(1) of the South Carolina Rules of Criminal Procedure, hereby moves the Court to prohibit the State from offering at trial any testimony regarding blood spatter from Tom Bevel, eny other principal, associate, or employee of Bevel, Gamer & Associates, LLC, or any officer of the State or other person wise opinion derives from review of Mr. Bevel's work product, asa sanction for Mr. Bevel and the State's deliberate refusal to comply with the Courts order compelling ‘production of documents related to Mr. Bevel’s opinions. Further, Mr. Murdaugh requests the ‘Court award him costs and reasonable attomey’s fees incurred in the motion practice conceming ‘Mr. Bevel. Mr. Murdaugh however ask that the Court delay considering this request for costs and ‘ees until after til I. Introduction (On June 7, 2021, Alex Murdaugh’s wife Maggie and son Paul were brutally murdered near the dog kennels at a family home on Moselle Road in Colleton County. As Me. Murdaugh has ‘noted in previous motions the State immediately decided Alex was guilty, before anyone collected, investigated, or reviewed any evidence and, unable to build a solid case against Mr. Murdaugh to present in court, instead engaged in a campaign of selective and deceptive leaks to news media to convince the public that Murdaugh is guilty before hei tried, Perhaps the most extraordinary lek ‘occurred in April 2022, when the State told FITSNews that “A shirt worn by Alex Murdaugh onthe night his wifeand son were murdered was found wo have a significant amount of high-velocity impact spatter on tom atleast one oftheir bodies” and that “he presence ofthis forensic -evidenee on his clothing ‘could have only come from one thing, “the spatter indicates that Murdaugh was piysically close to one or more of hs family members when they were shot” Manidy Maney, High-Veocity Inpact Spater Directly Tes Alex Murdaugh To Double Homicide, “Sources Say, FETSNews (Apr. 26,2022) Te any possible motive fr this ea was 0 convince the public that M: Murdaugh was guy ofthe murders before tril even befor he was formally ‘charged. This leak was an extrajudicial statement made on behalf ofthe State with the deliberate intention to prejudice the present judicial proveedings. It was als a le. ‘The leaked information was the purported opinion of Tom Bevel of Bevel, Gardner & Associates, In. (BGA) in Oklahoma, Mr. Bevel is a retired Oklahoma City police officer with no credentials in ny seientifi discipline. On the night of the murders, the South Carolina Law: Enforcement Division (SLED) collected the white cotton T-shirt Mr. Murdaugh wae wearing when he discovered Maggie and Paul's bloody bodies. SLED retained Mr. Bevel to opine tat Tshirt i stained with high-velocity blood spatter that could only come from being in proximity with them. _at the time of their murders. It did so even though the State knew on August 10, 2021—almost six weeks before firs reaching out to Mr. Bevel on September 21st—that confirmatory blood tests results were definitively negative for human blood in all areas ofthe shirt where purported spatter is present. SLED never told Mr. Bevel the shirt definitively tested negative for human blood before: Mr, Bevel produced his report. Infact, the State never told him until after defense counsel mailed -a.copy of the report directly to Mr. Bevel as an attachment to a copy of a public cour filing.However, even witheut knowing the shirt tested negative for human blood, Mr. Bevel’s init report correctly determined there was no high-velocity blood spatter on the shirt. Tt also stated that spatter was unlikely to be on the shooter at all. Only after badgering and a personal visit from SLED officials dil Mr. Bevel change his report both to say that it tums out abundant spatter is on the T-shirt afte all, and thet spatter likely would be on the person who shot Paul (although Paul’s DNA is not found on the areas ofthe shirt Mr. Bevel now says have spatter), In reaching this opposite conclusion, Mr. Bevel cited no new evidence except an in-person examination of the T-shirt—after it was destroyed for purposes of forensic testing by the unnecessary application ofan oxidizing chemical stain, and affer Mr. Bevel told the State it had ‘no evidentiary value to him, The inspection was just an excuse to pay Mr. Bevel a visit by having SLED agents act as couriers for the remnants ofthe T-shirt. Mr. Bevel admits his opinion ‘was not changed by the inspection; instead, he claims his opinion changed when he realized he ‘ould use Photoshop to alter pre-destruction photographs of the Tshirt, All this came to lightbecause SLED disclosed a copy of Mr. Bevel’ first report by mistake and because Mr. Murdaugh’s counsel requested a microscopic examination ofthe T-shirt, forcing the State to admit it had been destroyed. Based on the destruction of the Tshirt and evident bad {ith conduct surrounding the spatter analysis, Mr. Murdaugh moved to exclude it under State Cheeseboro, 346 S.C. 526, 552 8.2.24 300 (2001), and asked for an evidentiary hearing. (Mot. Exclude, Nov. 23, 2022.) Mr. Murdaugh also moved to compel production of Mr. Bevel’s case file, including communications, photographs, or other documents given to of received from him. by SLED. (Mot. Compel, Nov. 28, 2022.) The Court granted the motion to compel orally on December 9, 2022, and later in writing on December 19, 2022.WH. — Background ‘Below is a comprehensive timeline of events related to Mr. Bevel’s role in this case. The timeline naturally separates into three phases. Fitst, SLED is so frustrated by its inability to find ‘evidence to supper its initial assumption that Mr. Murdaugh is guilty that it decides to hire a blood “spatter expert to opine on Mr. Murdaugh’s T-shirt even though there is no blood on the shirt. Second, when SLED receives Mr. Bevel’s initial eport—yet another dead end in its quest to prove an innocent man's gult—it responds by getting him to reverse it, then leaks the new opinion tothe public. Third, SLED is caught in this lie by its own ineptitude, but doubles down, offering -contradictory excuses, weird at-home science fair experiments, and a regurgitation of Mr. Bevel’s report from a striv-man former SLED agent—all while openly defying the Court's order for production of relevant materials A. SLED tries but fails to find evidence against Alex Murdaugh. June 7,2021: Magaie and Paul are murdered. SLED collects Alex’s clothing. une 8, 2021: The white T-shirt Alex was wearing is tested for gunshot primer residue (GSR). Only thee particles of GSR are found, which SLED analysts believe is consistent with tevoafor fom reomily holding 4 freur ad not neosenclyindiastve of having saoualy ied & firearm. June 9, 2001: A small cutting is taken from the front hem ofthe T-shirt and tested with a presumptive test for blood in which hemoglobin catalyzes the oxidation of colorless ‘phenolphthalin no pink phenolphthalein, A presumptive test only indicates the possible presence: of blood. Many chemicals, including fabric detergent residues, can also cause the oxidative reaction, so the testis not conclusive for the presence of blood, The cutting responds positively to the presumptive test and is tested for DNA. Mr. Bevel will later concede blood and DNA on thebottom of his shirt are transfers fiom touching his family’s bodies and wiping his hands and face ‘on his shirt, and not the result of high-velocity spatter. See figure J, infra. Figure 1 June 25, 2021: SLED Issues the DIVA report forthe smal cutting ftom the bottom hem of Mr, Murdaugh’s Tshirt, It tests positive for Maggie's DNA and an unknown person. Paul is ‘excluded as a DNA cortributor. July 7, 2021: Senior Special Agent David Owen, the lead case agent, and his superior, Charles Ghent, SLED Lieutenant for the Low Country Region, bit their superior, Ryan Neil, SLED Captain forthe Low Country Region, onthe invesigtion, which isnot going wll ‘Thereafter, Cap. Neill speaks with Samu Reighle, J, another SLED Captain with leadership role in forensic services, to atk, “Questions about Alex's shir and how it was examined and blood ‘was indicated” and to express concer over the “Lack of photographs of blood stains, nd the poor quality of those that were taken,” Capt, Reighley informs Capt. Neil that SLED has no bloodstainexpert on sta Capt. Neil nots that if needed he will investigate using former SLED special agent Kenny Kinsey, now CHief Deputy atthe Orangeburg County Sheriff's Office. July 20,2021: Capt. Reighley tells Cpt. Neill that “(Crime Soene] and Serology are going to process Alex's shirt again Spray wth LCV/or something similar)” LCV is lencocrysta volt, another presumptive test for blood, in which hemoglobin catalyzes the oxidation of LCV to a purple color, Capt. Neil notes Deputy Kinsey had agreed to lok at photos ofthe Tshirt “to see {Flood Pater analysis] would be beneficial” July 21,2021: SLED tests the Fshit with LCV, The testing is conducted by Lt Kukila Wallace of SLED's crime scene forensics unit. The Tshirt is photogrephed, hung, sprayed with LLCY, photographed again, then laid out and gridded with tring. Large reas ofthe shir containing spots that immediately reacted withthe LCV are cut from the shirt and sent for DNA testing, which is conducted by SLED analyst Sarah Zapata. The DNA tests are conducted on several unlabeled sub-cuttings from each lage: cutting, [A side effect ofthis testing i that it effectively destroys the shirt. The LCV oxidizes more rapidly in the presence of catalyzing chemicals like blood or laundry detergent residue, but eventually i all oxidize, the entire shit turns purple, and all details bleed into large ditfuce splotches, SLED could have conducted the same test with luminol, which would not destroy the shirt, Had the Tshirt been purple or black, luminol would have been required. But luminol produces a luminescent reaction, which would require turning the lights off inthe room and taking photographs inthe dark, which would be slightly mor dificult han photographing puple stains on white Tshirt ina room with normal lighting. SLED chose to sve that slight amoust of effort atthe expense of destroying the evidence.“More importantly itis unclear how a color-stain test could possibly help detect blood stains on a white cotton T-shirt thathad never been washed since the murders. According to Mr. Bevel, high-velocity spater droplets have a diameter of 1 mm or less. With normal vision the unaided hhuman eye can see spots as srall as 0.1 mm. Any spatter would have been visible without taining. Regardless, turning a tiny dark red spot on a white background into atiny purple spot in no way ‘makes the spot more visible, July 25,2021: SLED issues the DNA report forthe cuttings made on July 21st. One cutting from the back of the shirt tested positive for Maggie's DNA. Paul was excluded es a DNA. contributor for that cutting. Of the cuttings from the front bottom portion ofthe shirt (which the State admits are not spatter lested, one tested positive for Paul's DNA while excluding Maggie as 8 contributor, one tested positive for Maggie's DNA while excluding Paul, and a third tested Positive for Maggie without excluding Paul. The cuttings from the upper two-thirds ofthe front ofthe shirt (which the State claims are spatter ftom shooting Paul) generally tested positive for Maggie's DNA with Pau either excluded or not considered because of his relatedness tothe other contributors. None tested postive for Paul's DNA ‘August 10, 2021: SLED takes more sub-cuttings from the larger cuttings from she Tshirt and Ms. Zapata performs HemaTrace tess to confirm the presence of human blood. HemaTrace isan immunochromatographic test that detects a reaction between dye-conjugeted antibodies and ‘form of hemoglobin foundonly in humans and higher primates. Its commonly used o onfirm the presence of human blood(or any other human tissue containing traces of blood or hemoglobin}. It is highly sensitive, able to detect as litle as four micrograms of blood in a sample. For comparison, a single grain 0 finely ground table salt weighs about 60 micrograms. Every cuting from the shirt tested negative for human blood.September 21,2021; Lt. Jeffrey Crooks of SLED's latent print department first reaches out to Me Bevel, sending an email stating, “My agency basa cae that requires BPA (blood patern analysis) analysis, and we are currently not working BPA cases. We would like to discuss potentially biting your organization to conduct the analysis” Although Deputy Kinsey, currently employed asa South Carolina law enforcement officer, had agreed to asist, no one followed up ‘with him after the LCV testing on July 25th, Instead, SLED waited two months then contacted a retired Oklahoma police officer. September 23,2021: Me. Bevel provides an estimate to SLED of $11,800 for analysis and 2 witen report ‘September 29,2021: Emily Reinhart, SLED captain for forensic administration, meet with Capt Reighly, Lt. Wallace, Lt. Schenk (the other SLED crime scene lieutenant), and Li. Hash (SLED's head of DNA testing) regarding testing of possible blood ona seat belt. Cap. Reinhart directs “If LCV is used, itis understood that no HemaTrace testing would be dane by DNA. Samples would go straight to DNA.” It appears that SLED, in response to the known but as-yet unreported negative HemaTrace results on Mr, Murdaugh’s Tshirt, has decided to avoid the possibility that the HemaTrace confirmatory test would contradict the presumptive LCV test SLED appears to want the option to say that anything that reacts with LCV—animal blood, plant material, food residue, houschold cleaners—and has any amount of DNA from Maggie or Paul— essentially, anything they ever touched—has their blood on stead of actually testing for the presence of human blood. October 12, 2021: Lt. Wallace informs Me. Bevel that SLED would like to move forward ‘with etaining Mr. Bevel in this case and asks Mr, Bevel to provide next steps. Mr. Bevel responsesthat case materials should be sent to 1007 S. Pickard St, Norman, Oklahoma, which is Mr, Bevel’s hhome address. See figure 2, ina. i Figure 2 ‘November 10,2021: SLED issues a supplemental reportto the July 25th report noting “no hhuman blood detected” for each cutting from the T-shirt. For some reason this reportis not issued until thee months after the sts were conducted. By comparison, the DNA report was issued only: four days after the larger cuttings were submitted for esting, December 15, 2021: Lt. Ghent tells Mr. Bevel that case documents will be transferred via ‘evidence.com and “In the event any physical evidence is need for your work, Lt. Kukila Wallace “will coordinate shipping this to yoJanuary 4, 2022: The evidenescom link is re-sent to Mr. Bevel and case documents transmitted to Mr. Bevel for review. The HemeTrace test resus are withheld ffom Mr, Bevel. ebruary 4, 2022 (Hriday): Mr. evel provides SLD his intial repr, dated February 3d, ‘pining that “stains on the white shir are consistent wit transfers and mot back spatter from a bullet wound” (emphasis in original). This intial report also opines that he would expect “lite to ‘no spatter on the shooter or (hisMher] clothing” resulting from the shooting of Paul and none resulting from the shooting of Mage. Me. Bevel further opines, “For there tobe litle to no back spatter on the shooter or they're [sc] clothing is certainly possible for this incident.” B. SLED and Mr. Bevel decide to fabricate evidence against Alex Murdaugh. Echrunry 7, 2022 (Monday): Agent Owen meets with Capt. Neil, Lt. Ghent, and Crime Scene personnel to discuss Mr. Bevel's report. Mer the meeting, Agent Owen asks Mr. Bevel to speak with them via Zoom the next dy. ebmuary 82022: Mr. Bevel has a Zoom conference with Agent Owen and others st SLED to discuss his report. During tis Zoom conference, Mr. Bevel asks o inspect the Phir. February 15,2022: Lt Wallace and Lt. Schenk examin the Tshirt and determine itis destroyed for purposes of further testing due to LCV oxidation. Lt Wallace takes photographs of the shirt with cell phone and sends it to Lt. Ghent. Lt. Ghent emails the photographs to Mr. Bevel, asking him “whether the shirt in this condition will still be of potential use for your ‘examination of the stains in question” and stating, “Ifyou believe so, we will make arrangements to have the shirt and the cuttings delivered to you." Mr. Bevel replies,“ would sey tat it doesn't look promising but iT testify at a trial I would prefer to say that I saw tin person to make that determination and the cuttings are probably more important than the rest ofthe shir, So yes please send them 1007 § Pickard Ave, Norman, OK 73069." As noted above, that is Bevel’s home address. See figure 2, supra 10Exbruary 16, 2022: Agent Owen emails Mr. Bevel that “Due to chain of custedy issues, 1 will hand deliver the shirt for your review,” and proposes doing so in the week of March 7th 1. uth, ‘February 17, 2022: Mr. Bevel tells Agent Owen that chain-of-custody issues do not require hhim to detiver the shirt in person in Oklahoma. SLED nonetheless decides to send both Agent ‘Owen and Lt. Wallace to Oilahoma as couriers to deliver the T-shirt even though ithas already been determined to be useless a evidence. ‘March 1. 2022: Agent Owen informs Mr, Bevel that he and Lt, Wallace will travel to Oklahoma to meet with himon March 10th ‘March 6,2022: Mr. Bevel emails Agent Owen: ‘The photos of the shirt the lab took before chemical processing, [assume there is an original format and size that is better than the one I have to work with. Before ‘coming out to OK can you check to ee if there are more photos and get them inthe original format and siz. There should also be photos taken right after applying the chemical can we get them? Please get a copy of any lab notes which should include their observations and a sketch with size measurements and locations on the shir. ‘Agent Owen responds “Yes sir. I will work on that.” Match 7.2022: Mr. Bevel again emails Agent Owen: have been working on enhancements ofthe overall photos ofthe flout ofthe shit, and see some possible tiny stains that may be spatter Withahigher a quality photo ‘we may be able to sate more than I thought we could with what {have currently received. The larger elongated stain we focused on that was easy 10 see i the photos is not what I'm looking for, it’s the tiny stains which I'm hoping the lab notes will addess and higher quality photos will show. March 9, 2022: Agent Owen and Lt. Wallace travel to Oklahoma to meet with Mr, Bevel March 10, 2022: Agent Owen and Lt. Wallace travel to Oklahoma to meet with Mr. Bevel to discuss his report. They meet at the police laboratory at 1501 W. Lindsey St, Norman,Oklahoma, Lt. Wallace forwards an email to Mr: Bevel ataching a photocopy of what appear to beer handwritten notes on the case March 1, 2022 (Friday): Agent Owen and Lt Wallace travel back to South Carona. Mr Bevel responds to, Wallace's email, stating “Got the notes ard they were helpful ina beter overall understanding ofthe scene and processing.” The nots do ro appear on the lst of materials considered for any version of Mr. Bev’ repor. ‘March 14,2022 (Monday): Mr: Bevel mils Agent Owen to tll him tht “With the large CCD format, we were abe to filer the colors ofthe shirt using Photoshop focusing on red (blood) and blue (LCV) and white ofthe shir” that now “There are over 100+ spatter stains,” and “Bottom, line I don't see any other mechanism to get so many misting stzns onto his shir other than the spatier created from the shotgun wounding” of Pa March 21,2022: Agent Owen enthusiastically replies to Mr Bevel’s March 14th email: Good afteroon Tom, ‘ast inguiring about Peer Review and repor sats. “Thank you sit, David March 22, 2022: Agent Owen receives a revised report from Mr. Bevel, opining that “100+ stains are consistent with spatter on the front of the t-shirt.” This final report also eliminates the ‘pinion that Mr. Bevel would expect “litle to no spatter on the shooter or [his/her] clothing™ resulting from the shooting of Paul, instead opining that “ue to gravity along with blood impacting these areas with suffi oree secondary spatter may also have been created raining down back, {nto the scene and potentially on the shooter” and “The shooter is certainly ina close enough range to get spatter on their clothing.” Mr. Bevel changed his previous statement, “For there to belittle to1no back spatter on the shooter or they're [sc] clothing is certainly possible for this incident,” toread “For there o be spatter on the shooter or their clothing itis certainly possible given the facts and sumstances surrounding tis incident.” ‘The items listed under “The following information was considered in this analysis” are ‘identical to those listed for his initial report except fo single addition: the viewing ofthe T-shirt at the on March 10th, There is no mention of any “RAW” image files, o any other photographs not considered when producing the initial report in February ‘When Agent Owen confirmed receipt, he asked Mr. Bevel, “is Ken Martin the only that did peer review? 1 was under the impression there would be a round table of Sto 6 colleagues.” Ken Marti isan assovate employed by Mr. Bevel’s firm March 23,2022: Agent Owen discussed the revised report with Mr. Bevel, Based on emis that day and the previous day the nature of he discussion appears tobe to cortetion of typos in the revised report. ‘March 29, 2022: Mr. Bevel provides his final report, largely identical to his previous revised report but adding the fllowing atthe end ofthe report ‘The t-shirt has been evalusted by sx (6) ecopnized Bloodstsin Patter expt all agrecing the best explanation for the stains on the shirt are spate ffom approximately the bottom third up othe top of the shit and transfers onthe botiom third down to the hem of the t-shir, All agree they cannot identify some other ‘mechanism to create the distribution and sizes ofthe questioned stain spatter ‘The identity of these “recognized Bloodstain Patter experts” is undisclosed. This addition obviously is in response to Agent Owen's request on March 22, 2022, for a “round table” of 5 agreeing withthe report. ‘he items listed under “The following information was considered in this analysis” are identical to those listed for his revised report except for one addition: a note about using forensic mannequins with dowel rods to understand “possible body positions when the deceased were 1Bshot” There is no mention of any “RAW” image files, or any other photographs not considered ‘when producing the inital reporin February. April 20, 2022: Mr. Bevel sends SLED an invoice for $10,988.75 (invoice dated April 18th). The invoice address for payment remission is 7601 Sunset Sail Ave., Edmond, Oklahoma, ‘Which is the home address of Craig Gravel, a retited Oklahoma police officer who is partner at Bevel, Gardner & Associates. See Figure 3, infra Figure 3 ‘Apt 26, 2022: SLED leaks the blood spatter “evidence” to FITSNews in a calculated _attempt to prejudice criminal proceedings against Mr. Murdaugh, C.—Caught in their lies, SLED and Mr. Bevel double down. ‘September 16,2022: SLED accidentally produces Mr. Bevel's initial report to the defense, _mislabeling it as interview notes from a November 9, 2021, interview with Kenny Hughes. ‘September 20, 2022: Defense paralegal Holli Miller discovers Mr. Bevel's mislabeled ‘initial report and notes its differences from the final report “4‘November 3,2022: after repeated requests, the State produces the ene DNA lab file in this case. Although the purpose of requesting these files was to review DNA evidence, they do also contain the HemTrac results, buried within hundreds of pages of other documents. These results re not immediately discovered by defense counsel November 4, 2022: Defense counsel request microscope-magnified photographs of the purported blood stains on Me. Murdaugh’s T-shirt, The purpose ofthis request isto obtsin expert opinion on whether the purorted blod stains were transfer stain rather than spatter. Hair and inscots can make mistsizedtanfer stains that look “morphologically very similar t impact” spatter. Eg., David rs & Theresa Geiman, Insect Artifacts Are More than Just Altered Bloodstains 8 Insects, no. 2,June 2017, at 37. However, microscopic examination can sometimes distinguish between impact spatter and transfer from tiny objects ike hairs and inset feet. At this the defense did not reaize the stains were not human blood [November 9,2022: Lead prosecutor Creighton Waters and other in the prosecution tam hhave a conference cll with Mr Bevel, in which the defense request for microscopic examination ofthe shirts discussed. ‘The call notes the shirt wes “very dark, close to back” because of LCV oxidation and therefore the requested examination would be impossible. On the call, Mr. Bevel observes that magnifying digital photographs could not substitute for microscopic examination because that would just be “blowing up pixels” and “I don't see that doing anything tat would help” identify blood spatter. Of couse later in November he claims to have done exactly that ‘when changing his opinion ffom “no blood spatter” to “lots of blood spatter” purportedly in response to Photoshop enhascements of digital photographs. Mr, Bevel also assures Mr. Waters that defense counsel's purpese in requesting an examination of the T-shirt is merely “giving us busy work to keep us busy and guessing.”November 11, 2022: Defense counsel again asks Mr. Waters for an examination of the shir Also, defense counsel first learns about the negative HemaTrace tests. In response to a Aefense motion to compel polygraph records related to Curtis Smith, a drug dealer who failed 2 polygraph examination when asked ifhe shot Maggie and Paul, SLED compared DNA taken from Curtis Smith against DNA from various items of evidence including cuttings from Mr. Mardaugh’s T-shirt. The results of the comparison withthe cutings from the T-shirt stated, “No human blood identified.” At this time, defense counsel did not know why these statements appeared on the November 2, 2022, report regarding Curtis Smith but not the earlier July 25,2021, report. Now, however, itis known that these statements reflect the HemalTrace test results, and they did not appear on the July 25, 2021, report because the tests were performed on August 10, 2022. ‘November 17, 2022: Mr. Waters finally informs defense counsel that the shirt has “tured black” and is not examinable, Defense counsel asks to view the shirt. ‘November 21, 2022: Defense counsel view the shirt at the SLED forensic laboratory. ‘November 22,2022: Defense counsel discovers the HemaTrace test results when reviewing the DNA laboratory notes while preparing a motion to exclude November 23, 2022: Mr. Murdaugh files a motion to exclude at about noon, The basis for the motion isthe destruction ofthe T-shirt. The motion includes a request for an order compelling production of all communications between Mr. Bevel and the State, At 3:30 pm, the State produces a set of communicetions with Mr. Bevel. These emails reveal to the defense that wien Bevel could not usefully examine the shir, he used Photoshop to edit the color ofthe stains on the shirt and that was his asserted basis for changing his opinion. 16November 28,2022: Ma. Murdaugh files a motion to compel Mr. Bevl's records and all communications with Mr. Bevel. The motion is styled “Motion to compel the State to produce evidence regarding aeration of photographs of evidence it destroyed” It specifically seeks all communications, including al electronic of physical documents exchanged, “regardless of mode ‘of transmission," and all Photoshop Document files related w photographs of the T-shit. The ‘motion specifically refers to fle delivered on physical media (what Mr, Bevel claims are the “RAW” format files November 29, 2022: Defense counsel emails a letter to Mr. Bevel, asking to speak with hhim about his report and enclosing the motions to exclude and compel that had been filed, including exhibits. The last two sentences of the letter read: “One quest whether you were informed that Mr. Murdaugh's T-shirt tested negative for human blood. Copies of the prosecution's serology reports are included as exhibits to the enclosed motions.” The leter was. sent at 11:29 am. EST. At4:37 pm. EST, Mr. Bevel began writing a 229-word Word document, hich he completed at 5:09 p.m. EST. The document is unsigned and not addressed to anyone. It states in fll ‘On Wednesday 11-27-2022 in the aftemoon a reporter called asking about the defense, filing « motion that I changed my BPA opinion due to pressure from the state. He was told that until adjudication is complete, I can’t talk to anyone about the case to inclide reporters ‘As to the state pressuring me, this never occurred. In my original report after looking at the processing photos and the t-shirt, which ‘was almost completely a dark color, I stated there are no bloodstans that ean be identified as coming from a firearm. My opinion would be the same today ifthe [RAW photo files had not been sent to me. RAW is an acronym for “raw image file format” which preserves all the data from the camera sensors. In non-taw format such as JPEG or TIFF less data is present due to digital processing such as compression of the data‘The original photos that were sent to me were in non-raw format and the photos did ‘ox show enough data 10 see staining that would be consistent with mist sized blood spatter. Upon getting a CD of the RAW files with much more recorded data, Photoshop was ‘used to enbance blue and datk spots on the white background of the t-shirt. This produced over 100 stains with distribution and sized that are consistent with mist sized spatter from a gunshot, ‘The reporter Mr, Bevel mentions is Avery Wilks with the Post & Courier December 1, 2022: Mr. Bevel finally receives the HemaTrace reports from SLED that show the shirt tested negative for human blood. Agent Owen writes a timeline in which he claims he first saw the HemaTrace test results on November 30, 2022, a full week after defense counsel attached them to a publicly fled mosion (timeline started at 7-45 p.m. and completed at I pam. the following dey), December 8,2022: Mr. Waters has Deputy Kinsey view the destroyed T-shirt atthe SLED forensics abortory. Mr, Waters al speaks wth SLED DNA analyst Zapata, who performed the HemaTrace tessa issue, about the HlemaTrace result Mr. Bevel, presumably at Mi, Water’ direction, responds tothe November 29th eter fom defense counsel, explaining that his response was delayed by deaths in his family and that his “policy is always to honor a reques to speak to an aiomey about an ative case” and offers 19 sake himself available for a call wit prosecutors and defense counsel, The parties agree to call on December 16th. Mr. Bevel laterasks to reschedule that cll December 21st December 9,2022 (Friday): The Court hears the motion to compel materials regarding Mr. Bevel. The Court orally grants the motion from the bench. December 12, 2022 (Monday): Mr. Bevel obtains an LCV kit for his upcoming “science fai” experiment, in which he will conduct a weekend experiment in his garage or other room in his house to prove that HemaTrace always returns a false negative when used on substances 8previously treated with LCV, despite multiple peer-reviewed articles in academic journals stating the opposite. Meanwhile, Mr. Waters has Deputy Kinsey visit the Moselle property December 13,2022: SLED analyst Zapata writes a memorandum to file, presumably a the request of Mr. Waters, positing possible explanations fora negative Hema'Trace test, Ms. Zapata attaches to her memorandum two academic articles regarding HemaTrace and LCV: Carl A. Streeting et al, A comparison of ABAcard® HemaTrace® and RSIDTM-Blood tests on dried, diluted bloodstains treated with leucocrystal violet or luminol, Australian Journal of Forensic Sciences 108 (une 2020) (inding HemaTrace tests “performed well” for bloodstains enhanced with LCY, retuming postive results for blood treated with LCV 94% of the time); Connie J Swander & Jennifer G. Sites, Evaluation for the ABAcard HemaTrace for the Forensic Identification of Human Blood, Mich. State Police Forensic Lab, (1998) (finding HemaTrace detects blood diluted with LCV) (paper submited to the Michigan Association of Forensic Science ‘Annual Meeting). December 14, 2022 (at 10:12 pm): Mr. Waters submits @ redline of Mr. Murdaugh’s proposed order on the motion to compel. A second redline is sent at 9:31 a.m. the next morning. ‘Mr. Waters’ proposed order oddly objects that Mr, Bevel was not retained by “the State,” claiming he instead was retained by “SLED,” even though SLED obviously is state agency, and implies ‘Mr. Bevel’s files therefore ae not within the contol of “the State." ‘The implicit argument is that Mr. Waters has little to no cantrol over SLED, Mr. Bevel, and their blood spatter imbroglio, Deceinber 15, 2022: Mr. Bevel obtains a bag of expired human blood from a blood bank. December 16, 2022 (Friday): Mr. Bevel obtains HemaTrace test kits. Meanwhile, Mr. ‘Waters has Deputy Kinsey meet with the pathologist who performed Maggie and Paul's autopsies.December 17, 2022 (Saturday): Mr. Bevel performs his at-home “science fair" experiment (the experiment may have begun onthe previous day), Mr. Bevel prays five cuings froma white ‘Tshirt with the expted human blood he obtained. He tests one cutng with HematTace, which tess postive, He then sprays the remaining four eutings with LCV, allows them wo dry, then tests them with HemaTrace. They tet negative, He conludes LCV always causes HemaTrace to retum 4 false negative. Mr. Bevel has produced no matral regarding this experiment beyond a brief report and @ short PowerPoint presentation containing & few low-resolution images. Beyond that, Mr Bevel has not produced any photographs, ab notes, or even anything indicating where this experiment ‘occurred. Because he has no offic o laboratory, and because he previously requested evidence to be shipped this home address, itis likely Mr. Bevel performed this weekend experiment in his home oe well, He does not even identify what portione ofthe shirt were tected with Hema. Instead, e illustrates a stain he did nor test, and shows 8 void where some cloth he did test was removed, without ever showing whether any bloodstain was present onthe tested portion ofthe cloth at all, See figure 4, na (lide from Mr. Bevel’s PowerPoint showing a “recommenced” stain for testing but then showing some other unseen portion of the shirt was actually tested), 20Mr. Bevel posits the false negatives he claims he observed may have been caused by @ -combination of diluting and the small misting stains indicative of “high velocity impact spatter,” Which according to him are “much smaller than the recommended 3mm squared” stains recommended as a minimum size for HemaTrace testing. He provides no supporting citation or documentation for is assertion thatthe “{rJecommended size of blood to test is 3mm squared,” ‘which appears to be nothing more than his own seientificaly illiterate reading of the instructional ‘insert that came with the HemalTrace test strips. The HemalTrace instructions state a sample cut from cloth or fabric should be between 3 mm? and $ mm, They do not say the stain on the cloth ‘should be a least 3 mn? (which would be a large stain). The sample cuting is soaked in2 mL of HemaTrace buffer, then one-tenth ofthat is dropped into the well onthe test card. Two Tines on the test strip means human blood is detected, which occurs if hemoglobin is present above 0.05, ug/ml. That means the 200 yl. dropped on the card only needs to contain 10 nanograms of hemoglobin to obtain a postive result, As noted in the academic articles provided by SLED’s own, aanalyst, the HemaTrace tet can detect nearly microscopic amounts of blood. Indeed, HemaTrace is more sensitive than LCV—Hema‘Trace will detect blood diluted tothe poin that it does not have a visible reaction with LCV. Swander & Stites, supra, at 4 December 18, 2022 (Sunday): Mr. Bevel wites a supplemental report regarding his at- home “science fair" experiment. Based on his purported discovery in his garage or kitchen or Wherever that HemaTrace always returns a false negative when tested on surfaces previously treated with LCV, he concludes the negative HemaTrace results for Mr. Murdaugh's T-shirt are ‘not relevant to whether blood spatter is present onhis shirt because it was treated with LCV before it was tested with HemaTrace. His opinion regarding blood spatter therefore is unchanged by the negative HematTrace tests. No reference is made to any published, peer-reviewed, academic work con the subject, because that work would contradict the results of his “science fair” experiment. December 19, 2022: The Court issues a written order memoriaizing the granting of the motion to compel. The Court orders “the State to produce tothe defense forthwith.” (1) Copies of all written or recorded communications to and from Mr. Bevel, regardless of mode of transmission, 2) Copies ofall electronic or physical documents sent to and received ftom Mr Bevel, regardless of mode of transmission. {G) All Photoshop Document files of Mr. Bevel, or of any member, employee, or agent of Bevel, Garner & Associates, LLC, related to photographs of the white T- shirt Defendant was wearing the night his wife and son were murdered. (4) A copy of the case file of Bevel asthe term is defined in the Manual of the United States Department of Justice, §-5.003 Criminal Discovery Involving Forensic Evidence and Experts. (Order, Dec. 19, 2622 (footnote omitted.) “Fothwith” means “immediately; at once; without delay.” Forthwith, Dictionary.com. A “ease file” under the definition inthe U.S. Department of Justice's manual incorporated by reference in the Court's order, is described as follows: n‘This information, which may be kept in an actual file or may be compiled by the forensic expert, normally will describe the facts or data considered by the forensic expert, include the underlying documentation of the examination or analysis perforied, and contain the material necessary for another examiner to understand the experts report. The exact material contained in acase file varies depending on the type of forensic analysis performed. It may include such items as a chain-of- ‘custody log; photographs of physical evidence; analysts’ worksheets or bench ‘notes; a scope of work; an examination plan; and data, charts and graphs that illustrate the results ofthe tests conducted Defense counsel asks Mr. Waters and Mr. Bevel to provide these materials by Friday, December 23d, December 21, 2022: Three-and-a-half hours before the scheduled call with Mr. Bevel, the State produces Mr. Bevel's supplemental report on his “science fit experiment. Mr. Waters called about one hour before the production to alert defense counsel. On the cll, Mr. Waters sounds embarrassed. He seemed unaware Mr. Bevel was performing “science fut” experiments at his home in Oklahoma to disprove the results of tests conducted in SLED's brand-new, ‘multimillion dolla forensic laboratory facilities. Defense counsel postpones the cll with Mr. Bevel. Ithas not been rescheduled December 27, 2022: Defense counsel again asks Mr. Waters and Mr. Bevel to provide materials the Court ordered them to produce immediately and without delay, stating that motion to exclude as a sanction will be filed if the materials are not produced by the close of business on December 28th. December 28, 2022: Mr. Waters responds: “We have been actively working on this issue around the holidays. We were hoping to get it uploaded before Christmas by dropbox but SLED {got a text from Mr, Bevel Friday the 23nd dal i wis woiny lo take 13 hours so ie bowel at " Gf Seanna Adsox, New SLED lab biggest chunk of $100M requested by law enforcement agencies for consruction, Post & Courier (Dec. 30,2017). 2extemal hard drive to send. am advised by SLED thatthe hard drive was in fact fedexed by Mr Bevel and is due tobe out fer delivery to SLED HQ today by 4:30pm.” December 29, 2022: The defense receives a copy of the hard drive ffom Mr. Bevel. It contains 46 GB of materials. There are no “RAW” image files. There are no Photoshop files. ‘There ae no photographs whatsoever excep for those contained in PowerPoint presentations and 4 few very low-resolution JPEG images labeled “Slide1”,“Slide2”, ee, Mr. Bevel produced no notes or analysis notes related to spatter beyond drafts of his reports and various PowerPoint presentations made for SLED. He did not produce relevant corespondence in his possession. For ‘example, he produced no correspondence regarding use of the Norman, Oklahoma, police laboratory for his meeting in March with Agent Owen and Lt, Wallace. Neither Mt, Bevel nor SLED produced any text messages—even though Mr. Waters’ email to defense counsel said Me. Bevel texted to communicat that he was having issues uploading files to SLED. December 30,2022: The Attorney Generals office produces its own communications with Mr. Bevel January 9, 2023: Mr, Waters receives a report by Deputy Kinsey that mirrors—and expressly relies on—Mr. Bevel's report. Exhibit A. Mr, Waters apparently believes the prospects for geting Mr. Bevel's opisions admitted into evidence are dubious and he thinks be ean avoid Mr. Bevel’s issues merely by having someone else read Mr. Bevel’s report and repeat it in as his own, Deputy Kinsey's report is organized around the same 12 “investigative questions” Mfr. Bevel used in his report and essentially paraphrases Mr. Bevel’s opinions on those questions with ‘one notable exception. In response to“IQ-4: Are the blood stains on Alex's white t-shirt consistent with back spatter from a gunshot," Deputy Kinsey repeats Mr, Bevel’s phrase about “100 plus™stains, then opines, “the smaller stain that are present after treatment with LCV appear to be high ‘velocity impact stains... only caused by a gunshot or speed machinery.” But then he pivots 180-degrees to conclude: “After consideration ofthe original opinion, analysis reports, and follow “up experimentation, this expert cannot render an opinion on IQ-4 above.” Deputy Kinsey is unwilling render on whether “the blood stains on Alex's white tshirt” _are spatter from a gunshot because he knows the T-shirt tested negative for human blood. January 13, 2023 (Friday before holiday one week before til): The State produces Deputy Kinsey's report to the defense. January 18, 2023: This motion i filed. TH. Legal Standard To the undersigned’s knowledge, no South Carolina prosecutor has ever before attempted to introduce irculpatory expert testimony from an out-of-state expert who—in open defiance of a court order—refused to produce the materials he relied upon informing his opinion. Therefore, there is no controlling legal standard directly on point. The leading case onthe authority ofa tial court to exclud testimony of an expert generally is Jumper x Hawkins, 348 S.C. 142, 558 SE.2d 911 (Ct. App. 2001). “The Jumper court held trial judge is required to consider and evaluate the following factors before imposing the sanction of exclusion of a witness: (1) the type of witness involved; (2) the content ofthe evidence emanating from the proffered witness; (3) the nature of the failure or reglect or refusal to furnish the witness’ name; (4) the degree of surprise tothe other party, including the prior knowledge of the name of the witness; and (5) the prejudice to the ‘opposing party.” Barnette». Adams Bros. Logging, 385 S.C. 588, 592, 586 S.E.2d S72, S74-75 (2003) (citing Jumper, 348 S.C. at 152, $58 S.E.24 at 916). ‘The Jumper court however was concemed with the exclusion of an expert who was not timely identified in the proper manner, not an identified expert who refuses to comply with the 2s‘court's orders compelling discovery. In civil cases, when a party fails to comply with a discovery ‘order, the trial court has the discretion to impose any sanction it deems just, including an order dismissing the action. Rule 37(b)(2), SCRCP; Bamerte, 355 $.C. at $93, SB6S.E.2dat 575. These sanctions can include (but are not limited to): (A) An order that the matters regarding which the order was made or any other ‘designated facts shall be taken to be established forthe purposes of the action in accordance withthe claim ofthe party obtaining the order; (B) An order refusing 10 allow the disobedient party to support or oppose designated claims or defenses, or protbiting him from introducing designated matters in evidence; (©) An order striking out pleadings or pars thereof, or staying further proceedings until the order is obeyed, or dismissing the action or proceeding or any part thereof, or rendering a judgment by default against the disobedient party; In Liew of any of the foregoing orders or in addition thereto, the court shall require the party filing to obey the order or the attorney advising him or both to pay the reasonable expenses, including attomey's fees, caused by the failure, unless the court finds thatthe failure was substantially justified or that other circumstances make an award of expenses unjust, Rule 37(6)2), SCRCP. ‘The sanction Mr. Murdaugh seeks here—an order prohibiting the disobedient party from introducing designated matters into evidence—is specifically enumerated by the civil rule and in fact isthe least harsh possible sanction enumerated. The federal criminal rule i similar: “When a party in criminal case fails to comply with a discovery order, the district court ‘may order such party to permit the discovery or inspection, grant a continuance or prohibit the party from introducing evidence not disclosed, or it may enter such other order as it deems just under the circumstances.” United States x Fernandes, 780 F.2d 1573, 1576 (11th Cit. 1986) (quoting Fed. R. Crim, P, 16(4)2)) (reversing district court denil ofa motion to exclude testimony as a sanction for failure to comply witha discovery order, holding the violation “requires tha the district court %“fashion|] the least severe, yet effective, sanction”). Rule 5 of the Soath Carolina Rules of Ctiminal Procedae has similar lnguage, though it anticipates a fale to disclose in response to a discovery request oma party, not defiance of cour order. IV. Discussion [A Mr. Bevel and the State have refused to comply with this Court’ order. Mr. Bevel andthe State have not complied with the Cour’ order. M. Bevel and the State ‘were ordered to produce (1) Copies of ll written or ecorded communications to and from Mr Bevel, regardless of made of transmission.” The Slate and Mr, Bevel have produced email correspondence, but they have not produced any text messages. On December 2h, Me. Waters told defense counsel “SLED go text fom Me, Bevel Friday the 23rd that twas going to take 13, hours [to upload certain files} so he bought an extemal harddrive to send.” That ext message has not been disclosed and, more importantly, i obviously i nt the one and only text message Me Bevel ever sent oor resived from someone at SLED. ‘Mr. Bevel and the State were ordered to produce “(2) Copies of all electronic or physical. documents sent to andre ced from Mr. Bevel, regardless of mode of transmission.” Neither Mr Bevel nor the State have produced any “RAW” image format photographs of the T-shirt. Instead, ‘Mr. Bevel produced a short memorandum stating that he received these filesand that his Photoshop ‘manipulation of them was the sole basis for changing his opinion from “there is no blood spatter” to “there isa Jot of blocd spatter.” Email correspondence suggests these photographs may have been delivered on a CD, which the motion to compel specifically refers to files delivered on physical media, and why the Cour’s order specifies documents “regardless of mode of ‘ansmission.” Yet Mr. Bevel and the State flatly refuse to produce these files. Examination of them is critical to understanding the val of his new opinion. a‘The most charitable explanation forthe refusal to produce the etic files shat Mt. Bevel ‘wants to protect his new opinion from scrutiny. The more likely explanation is that Mr. Bevel is simply lying about why he changed his opinion. Mr, Waters has represented to defense counsel that there are no undislosed “RAW” photographs, and that the only photographs Mr. Bevel was provided are the JPEG images the State has produced tothe defense. Mr, Waters word is far more credible than Mr, Bevel’, and his statement is corroborated by the facts that (1) the potion of Me. Bevel’s final report isting the evidence documents lists many photographs but it doesnot ist any Photograph not also listed as evidence considered in his initial report, (2) Me. Bevel’ final report does not list any “RAW" image files, (3) the number of photographs listed on Mr. Bevel's final report correspond with the number of photographs the State has produced—most of which were taken on July 21, 2021, with a Nikon D780 camera and produced as 6048x4024, 300dpi JPEG images with 24-bit color depth. On the other hand, Agent Owen has produced a timeline stating ‘hatte and Lt, Wallace did deliver"RAW” photographs to Mr. Bevel when they went to Oklahoma, and there are contemporaneous emails referencing photographs delivered ona CD. “Mr. Bevel and the State were ordered to produc “(3) All Photoshop Document files of Mr Bevel, or of any member, employee, or agent of Bevel, Gamer & Associates, LLC, related to photographs of the white T-shirt Defendant was wearing the night his wife and son were murdered.” He has produced no such files, only a memorandum confirming he infact does have them. Photoshop files contain a great deal of metadata, including an aut wal of alterations regarding the underlying image. See Adobe, Adobe Photoshop File Formats Specification, ‘ups? wwrmadobe.com/devnetappsfphotoshop/filformatashiml/4S0S77409_pgfld-1030196, (ov. 2019). Ifthere are no RAW image files at all, producing these files would reveal that, which may be why Mr. Bevel refused to produce them despite being specifically ordered to do so. 8Me Bevel and the Site were ordered to produce “(4 A copy ofthe case file of Bevel as the term is defined in the Manual ofthe United States Department of Justice, 95.003 Crennal Discovery Involving Forensic Evidence and Experts.” The order defines a “case fle” as “the underlying documentation of the examination or analysis performed, and contain the material necessary for another examiner to understand the expet’s report” including “a chain-of- The author, Ralph Ristenbatt, is an assistant teaching professor of forensic science in the Department of Biochemistry and Molecular Biology at The Pennsylvania State University. The SLED analyst who performed the HemaTrace tests in this ease, Sarah Zapata, received her Bachelor of Science degree in 2014 from Penn State. Prof. Ristenbatt was an instructor when Ms. Zapata was a forensic science student there, teaching courses such as “Scientific Approach to ime Scene Investigation.” Its unclear whether he taught any courses Ms. Zapata attended. 3but he, and the State, refuse to provide them even afler being ordered todo so, And as described sbove, Mr. Bevel as refised to produce much of anything fitting the definition of a “case file.” ‘The purpose behind this defiance is to insulate Me. Bevel’s opinion from seruiny, either in a Councit hearing or at tial. Significantly, it appears the ordered disclosure would show that Mr. Bevel fabricated his proffered justification for changing his opinion from exculpatory to inculpatory atthe request of SLED, and that his at-home “science fait" experiment does not mean the fac that the shirt tested negative for human blood is irrelevant to a blood stain analysis. No other failure oF refusal could weigh more heavily in favor of exclusion, Cf Curlee ». Howle, 277 S.C. 377, 382, 287 SE.24 915, 918 (1982) (“Contempt results from the willful disobedience of an order of the court Allowing Mr. Bevel to testify at tral would be prejudicial to Mr. Murdaugh ‘The final applicable factor is prejudice to Mr. Murdaugh. 348 S.C. at 152, $58 SE.24 at 916, The Court has already ruled on this factor, Mr. Murdaugh needs the requested materials to prepare his defense, which is why the Court granted the motion to compel. (Order at | (“The Court finds this information should be disclosed pursuant to Rule $, South Carolina Rules of Criminal Procedure.")) The State could have argued the defense does not need these materials in opposition ‘to the motion to compel. It didnot. It cannot now argue the defense does not need the requested ‘materials asa justification for refusing to comply withthe Court's order. ‘The State and Mr. Bevel should not be permitted to defy a Court order to sabotage @ Council hearing they know Mr, Bevel cannot survive, And in the unlikely event that Mr. Bevel could qualify as an expert witness, Mr. Murdaugh would need the requested materials to cross-examine him effectively at tral, If there are RAW image files, producing these files is necessary to understand exactly how Mr. Bevel manipulated the original images and whether his manipulation in fact supports his new opinion. Photoshop files are necessary for the same reason, as are 34‘documents regarding his “science fat” experiment, all communications with Mr. Bevel including ‘text messages (which defense counsel suspect may be more candid than emails to or from official ‘email accounts), and everything else the Court ordered Mr. Bevel to produce. This factor therefore supports exclusion 2 Exclusion of Mr Bevel is necessary to preserve the authority ofthe Court and the dignity ef the trial proceedings. “Contemptuous behavior is conduct that tends to: bring the authority and administration of ‘the law into disrespect; or, interfere with or prejudice parties or their witnesses during litigation.” ‘State v. Kenmerly, 331 3.C, 442, 450, 503 S.E.2d 214, 218 (Ct App. 1998), af'd, 337 8.C. 617, 524 $.E.2d 837 (1999). “The power of contempt exists to maintain the order and decorum of court Proceedings, to enforce the cour’s writs and order, and to punish acts tending to obstruct the due administration of justi.” 1d SLED and Mr. Bevel’s open defiance of the Cour’s order ‘compelling production certainly is contemptuous. See Rule 37(6{2)(D) (providing that in a civil ‘case, the court may trea: “asa contempt of court the failure to obey any orders" regarding discovery “except an order to submit to physical or mental examination”), Their refusal to comply with ‘the Cours order disrespects the authority of the Cour, interferes with and prej ices Mr Mardaugh during this ligation, and obstructs the due administration of justice in this case. Mr, Murdaugh does not ask the Court for a Rule to Show Cause regarding Mr. Bevel ‘(because he isin Oklahoma), but he urges the Court not to tolerate his contemptuous behavior. A. ‘court order that is not enforced invites disrespect of all other court orders. Litigation largely is a process in which a party seeks to advance its cause by asking the tribunal to order some relief, “other parties agree or oppose the request, the tribunal hears the partes’ arguments and then decides ‘whether to grant the requested relief, and the parties abide the decision or appeal to a superior ‘tribunal. If the parties are free to advance their cause by ignoring decisions they do not like, the 35process of fitgatio cannot function. Thus, iis essential that cours enforce ther ordrs “Ifa ‘party can make himself a judge ofthe validity of orders which have been issued, and by his own ‘ctf disobedience set them aie, then are the courts impotent...” Gompers» Bucks Stove d Range Co, 221 US, 418, 4501911). “As result “there could be no more important duty than to render such a decree as would serve to icte the jurisdiction and authority of courts to ‘enforce orders and to punish acts of disobedience."” Young w, U.S. ex rel, Viton et Fils $4., 481 USS. 787, 796 (1987) (quoting Gompers, 221 U.S. at 450), Mr: Murdaugh here requests the least severe sanction sufficient to vindicate the Court's authority and to enforce its order compelling production of materials relevant to Mr. Bevel's opinions: exclusion of his opinions at tril, C. Exclusion of blood spatter testimony derived from Mr. Bevel is also warranted. ‘Mr, Waters does not believe Mr. Bevel will be permitted to testify on blood spatter, which is why he is attempting to sneak Mr. Bevel’srepor in through Deputy insey asa back door. See Exhibit A. The Court should not allow this for thre reasons, First, it would in no way vindicate the authority ofthe Court o exclude Mr, Bevel from testifying to the opinions in his report just o allow someone else read Me. Bevel's report and say, “that's my opinioa too." Deputy Kinsey states that his opinion relies on parton Mr. Bevel's report ‘Mr. Bevel says his report relies on materials the Court ordered him to produce. Me. Bevel and the State have refused to comply with that order. By simple transitive logic,‘ Deputy Kinsey's report also relies on materials the State has refused to produce in defiance ofthe Court's onder. If Mr Bevel's report, so should Deputy Kinsey's report. ‘In logic, the term ‘transitive’ describes a given relation between terms such that if it exists between ‘a and "band between °b' and ',’ then it also exists between ‘a’ and ‘e."” Sirawther w Grounds, No. 2:13-CV-1357-MCE-EFB, 2015 WL. 3893570, at *8 (E.D. Cal. June 24, 2015) (Gnternal quotation marks omitted). 36Second, to the extent Deputy Kinsey ight say his report is an independent review of evidence independent of Mr Bevel’s report, no required disclosures have been made. Mr. ‘Murdaugh made a Rule 5 request on July 15, 2022, which requires the State to produce to Mr. ‘Murdaugh all “books, papers, documents, photographs, tangible objects, buildings oe places, or copies or portions thereof, which are within the possession, custody or control ofthe prosecution, ‘and which are material to the preparation ofhis defense.” Rule 5(a\(IX(C), SCRCrim?. The State hhas produced no draft reports, communications, notes, or analyses by, to, or regarding Deputy Kinsey. Deputy Kinsey's report was even produced as a scan of printed hard copy soit would not ‘even have metadata. Not one email oor from Deputy Kinsey has been produced. Such documents are encompassed by the Rule 5 request, just asthe were for Mr. Bevel. Under Rule , the deadline for such production was August 15th. Of course, many ofthese documents might not exis tall because Deputy Kinsey's report i just a paraphrase of Mr. Bevel’s report, ‘Third, Deputy Kinsey's report diverges from Mr. Bevel’s report in one key aspect: Deputy Kinsey is unwilling to say the T-shirt has any blood spatter. In response to “IQ4: Are the bloodstains on Alex's white -shirt consistent with back spatter from a gunshot?” Mr. Bevel opined that there are “100+ stains" consistent with spatter on the front of the T-shir. Deputy Kinsey ‘opines that “the smaller stains that are present after treatment with LCV appear tobe high velocity ‘Impact stains... only caused by a gunshot or high speed machinery” but then concludes: “After consideration of the original opinion, analysis reports, and follow-up experimentation, this expert ‘cannot render an opinion ox 1Q-4 above.” Deputy Kinsey is unwilling to opine the LCV-stained pattern on the consistent with blood spatter from the murders because he knows the T- shir tested negative for human blood, 37Deputy Kinsey's opinion on blood spatter—or, more accurately, his lack of an opinion — ‘therefore appears to have litle valuc tothe prosecution, But if prosceution asks him to testify, it likely will ask him to express a partial opinion about the patter of stsins on the T-shirt to create ‘the impression that they are blood spatter caused by the gunshots that killed Maggie and Paul, ‘when in fact Leputy Kinsey holds no such opinion. Deputy Kinsey lal states he “cannot render an opinion” on whether there is blood spatter on the T-shirt. Mr, Waters therefore should not be permitted to offer Deputy Kinsey's expert opinion testimony on spatter patterns on the T-shirt to lead the jury to conclusion that, in Deputy Kinsey expert opinion, cannot be drawn from the evidence? Todo so would not: the jury; it would only confuse the jury. See Rule 403, SCRE, (providing the court may exclude evidence if is probative value is substantially outweighed by a anger of confusion of the issues or misleading the jury); Rule 702, SCRE (expert opinion testimony admissible only if it would “assis the trier of fact to understand the evidence”). Where there is no blood, there can be no blood spatter D. An award of costs and fees is warranted. ‘The State's misadventure with Mr. Bevel has imposed substantial costs on Mr. Murdaugh “while he prepares his defense to unfounded murder charges, In a civil case he would be entitled 1o costs incurted including attomey's fees, Rule 37(8}#, SCRCP. He should be no less entitled to them in a ciminal case. The State's misconduct, outlined above in detail, has been egregious. Now howeveris not the time to argue over atomey’s fees, so Mr: Murdaugh asks the Court to take his request for costs under advisement until after the jury's verdict. This motion only concerns blood spatter opinion testimony. Mr. Murdaugh herein neither asks the Court to exclude testimony from Deputy Kinsey on other aspects of erime scene investigation, like the trajedory of gunshots or position of the vietims, nor concedes the admissibility of such testimony: 38V. Conclusion For the foregoing reasons, Mr, Murdsugh requests the Court t probit the State from offering testimony regarding blood spatter from Tom Bevel, any other principal, associate, or employee of Bevel, Gamer & Associates, LLC, or any officer ofthe Stale or other person whose opinion derives from review of Me. Bevel’ work product. Further, Mt. Murdaugh requests that afer tral, the Court award him costs and reasonable attoreys fes incured in motion practice regarding Mr, Bevel Respectfully eubmited, SS Richard/A. Harpootlian, SC Bar No. 2705 Phillip D. Barber, SC Bar No. 103421 RICHARD A. HARPOOTLIAN, PA. 1410 Laurel Stret (29201) Post Office Box 1090 (808) 252-4848 rah@harpootlianlaw.com pdb@harpootlianlaw.com James M. Griffin, SC Bar No, 9995 Margarst N. Fox, SC Bar No. 76228 GRIFFIN DAVIS LLC 44408 Forest Drive (29206) Post Office Box 999 (803) 744-0800, {grffinggriffindavistav.com ‘nfox@grffindavislaw.com ‘Attorneys for Richard Alexander Murdaugh January 18, 2023, ‘Columbis, South Carolina 39‘STATE OF SOUTH CAROLINA, ) IN THE COURT OF GENERAL SESSIONS ) FOURTEENTH JUDICIAL CIRCUIT conver cr corse ; Ie oh aot ne on 20510082 0595 me, | : | cexnimcart or sence Iie Ade Marg Defendant. 1, Holli Miller, paralegal to the attomey for the Defendant, Richard A. Harpootlian, PA., with offices located at 1410 Laurel Street, Columbia, South Carolina 29201, hereby certify that fon January 18, 2023, I did serve by placing in the U.S. mail, frst class postage affixed thereto (vith a courtesy copy sent electronically), the following documents to the below mentioned ‘petson: Document Motion for Sanctions Served: Creighton Waters, Esquire Office of The Attomey General Rembert C. Dennis Building ost Office Box 11549 Columbia South Carolina 29211-1549 ewaters@seag.g0¥State of South Carolina v, Richard Alexander Murdaugh Indictment Nes. 2022-GS-15-00592, 593, 594, and -595 Motion for Sanctions EXHIBIT A (Affidavit and Preliminary Expert Opinions of Dr. Kenneth Lee Kinsey, Jan 9, 2023)31-21-0061 1. My name is Dr. Kenneth Lee Kinsey am over 21) years of ag, of ound mind, dial espect qualified to epeset my expetopiagns tod sub thi Adee 2. Lam curently employed the Chief Depar of he County Sherfs Office, ta my earen le |manage al daily peraons,coodut fisal effi investigations conduct 4 1 eamed a doctorate degre (PAD) in Ctiminal Jupice in May of 2019 fom Walden ‘Univeiy. My dssenaton research “Use of Fore ad i Police Trainer tlle «quantiatve enlist dedi the paychoogial nlunces of ‘officer motivation from tose responsible fo nsrucon to police officers such a ‘Academy Instructors, Departmental Training Officers a Field Training Offices. 4, In December of 2011, ¥ cared « mase’s degree (MB) fiom Troy Univenity in Criminal Janice, received my’ bachelor's degree (8) in May bs P Parks, Recreation, and Tourism Management with an smemenenemenented tsa ct ‘Pniabnens for the Reponal Organized tine ‘experience of police polices, practices and customs) ‘eaforonment carer, “Ry Kinet La, “Us of Foe nd Pcp of Pai Diverse Decor Sees 91 bps wel 2905:‘SGJ 2021-208 31-21-0061 {6 Additionally hve gained vst experience conducting Hime scene in cought ‘my 30 year law enforcement carer, serving inthe fling capacities: cena investigator (lacie propery and violent erimes), violent crimes pvestignor (OCSO), crime sone and Iateat prints (OCSO and SLED), and asisting al : 7. Thave actively processed over 800 death senes in 10 tn aon tthe vsous law enforcement wang and ‘Adjunct Profesor at Calin Unive, whee T Tavesignions and oterC¥ related classes sace 2012. 11, My involvement inthis mater is made tthe direction ‘South Carolina Atiomey General's Office. Iwas Iavestigaive queions os were requested in the profesional asesment ofthe exter: ‘David Greene BWC recording june 7, 2021 Sled Crime Seene Iv. Summary (46 pe) 1 nterview of Alex Morduugh (438) Autopy Report for Paul Mardaugh (6 pa) Piece Ape of Pel oer ‘Autopsy Report fr Margret Mardugh Phos Foe Auopy fare Mage 8) DNA Report fue 25,2021 (18 pa) DNA Report uly 25,2021 (17 pa) (5 Pott Evidence Proceaing = (49) (G3 PhotcaEvidense Proeaing (57) 121-09074 Lab Photos of Shotgun 30) FA Report Jly 23,2021 (10 pa) Mercedes GLS Proceaing Photos (138) [Lab Photos of Vietn's Clothing (200) 2 Bvidenee (4) {dune 15,2021, 2 Jane 18,2021 2008SG) 2001-206 21-21-0064 Conmulution at MUSC w Dr. Riemer (1216722) | = (12) page Reported “Homicide lvestiguton ofPaul and Margret Mardaugh BGA (Case 2022-01 SC": asued by Tom Bevel of Bevel hrtne & Assos (03729722) sd ‘erminalimmesiate dest, l 22. Gunshot to left weit. Entrance on drs side with ext on ventral side (non-fatal. 3. Gunshot to lf thigh Entrance of wound l medial font back, downward tle to ‘gang. Gt wound is apperent onthe back of High. This wound eontans stipplng (2), no soot on ft, ‘4. Gunshot to bac ofsalpfhead Anstomica ht, Injury. Ets head and travels into upper shoulder '5. Gunshot to upper abdomen Entrance on anato na/mmediae severe bran area at downward trajectory gt sie of abdomen (Tole, {tonto back). Potential fatal but not immediate Hevere organ damage. Bit wound on lower eft side of back. This wound contains tpplil (3 In}, no soot. Similar angle to wound number 3. 2907‘8GJ 2024-286 31-21-0061 ‘Gunshot Wounds to Paul Murdaugh: Documented as (A and B). The alphabet assignment doe note sequence of wounds received. Entrance on op of eft shoal Te side of neck and proceeds ino cal ight side of hed. Upward ‘detached fom bead. No 'B. Shotgun wound to chest (buckshot). Batrunceon anda lf side of chest ner midi. ‘Stpling ie present on anatomical lef side of engine wound. Leh to right tajectoy exiing left side of chest and under. Pink past wad is presen in ext chest wound. ‘Shot spreads and continued trough let upper arm ‘Twelve (12) Tavetigative Questions ‘1Q-1: What the order ofthe shotgun wounds to Paul furdangh (sho sequence)? 10.2: Where athe shooter postoned forthe to (2) ss to Pal? 1Q1.&20phaion: ‘The shot slong the midline of Pal’ chest was the first Ypund thet he sustained. The second sd final hot waste bis lef shoulder, Into hs jaw, and tig his head First wound: {Tis shot was delivered fom sever fet away as Pl stood just sy of the approximate ‘His position was facing slighty $W tthe tine of he buckshot penetration. Aer etry (rg, angled wound), the buckabot traveled si iy across his left chest and cited under hs arm. ©, Moat ofthe shot thn entered the underside of the If arm and exited apun on the outs ofthe upper arm. Totton uprey te ominun pfeat oren 7) cit alles at continued through the windowpanes a the rer off feed room (Attachment). ‘Aa open abot cop or wed was visible a th ext pif under tela. 50 or near 90-degree blood drops on the cement phow that Paal was sil standing bot ‘moving slowly toward the door (Attachment). ‘8 Pal FW iprasonsin the Hood ropes suppofts Paul's movement towards the doe 2908SGJ 2021-296 34-21-0081 1 Blood and body fis, he conned path of location ofthe fred shoal bebind the dooe slighty ould the room's door approximately Drench ofthe setgun inside the room (Attach place the shooter vending i or ine of the feed room, wih he Second Wound: A. The second wound fo Paul occured atthe tretid of the fed room door ad ws ‘nmediately terminal (Atachoeat). 'B. This shot was unlike the frst wound in that this stl sho, commonly refered toa bids, BB C. Theo fo Pauls head entered long the top of sen at an angle upward it he brain before ent and the poston ofthe severed brain would place ahooteroutlde the door othe west sde of entry Th length ofthe shotgun would be needed fora degre of certainty, bait in unlikely ta he shooter was standing with weapon tthe tine of te second arts nso woud unos wound 3 ht angst word ape ‘Sion he ilr ans ne od ey. Mee wos wl genet et er tomede en ohare, ant wot hw) ma tay SSennon ant wounds erent) for wou a eco ot ical noes toot scotnatono he pw ass wea nsw? Cie ests the pen etd the Soph ets af eon ed Srouninonn mre sitargret nae ater eft oso: eons ge srnct ft wo et ogame ape wife ston ose ih Cray Tete of ain agnor s poet tn te ‘ra are adr ste ue ther uno naar Tar ey Spinone pyar pooner alt eth odd Dh congener wands 2900,SG) 2021-206 31-21-0061 + Gunshot wounds 1 and 4 would cause immedi lincapactation and would cease all ~ Lacking evidence that Margaret's body had been Hove or manipulated, the evidence suggests that gunshot wound 2,3, and 5 were ‘He fst sales of shots delvered to Margaret. = Theexact sequence cart be determined excopt thf three wounds were recehed i an Lptght or semt-upright postion prior to the two wd ds that were Immediately ata + There was no evidence that Margaret's body vids supine, or had Been moved or ‘manipulated (stood poo blood run) = _Therewere no projectiles located in the soll underphth the deceased that would suggest _anear 90 degrees shot downward 4143: Oplnion tls my opinion that gunshot wound 1 would have Margaret’ left sde, and trom behind. This shooter ‘wound to her abdomen, path through the left brea postion would have been prone or nearly prone feast her right hand with her shoulders and head fbw. Gunchot wound 2 would be Included inthis sequence fis nt the pojectln have been from a distance and traveling through her upper back (opposite cretion of gunshot wound} 1044: Are the blood stains on Ales whit it. with back spater rom 2 gunshot? = 100 plus stains on the front ofthe neck rea of wie tshirt (vansfers/proectd boot fan + Sten = Ethanced w/leuco Crystal Violet (LCV) and project blood over 100 fps. After consideraton the oilnalopiion analy ‘ 2910‘SGJ 2021-296 31-21-0081 ‘reports and follow-up experimentation, ths expert Hannot render an oplon on 4 above. 1:5: Are the 300¢ spettar tana on the ron of thir th rest of using the shirt to wipe the fee? + The photographs of the tshirt exibt atleast two + The fist would be the multiple smal sans nea sarment. = The ager staln at or nea the font bottom would + BWC deo depicts Alex Murdaugh wiping hi face ea, with hi hands on the Inside ofthe game. snc types of blood stale, and in fhe top neck and chest area of the the second type bood sta, {forehead with the second/bottom 1.8: option Ie sey opinion thatthe bottom stan ‘one area tothe shirt by way of wipe. Awipe ‘that alredy contains blood (BWC Wieo). Alex ‘wth the area ofthe thi that now contains the have wiped the blood from the face/forehead. The shirt the nec/ust area are dtc diferent ipl the face, 16: Wht type of bloot staining would be expected tebe on the face from checking two: decessed bodes for 8 pte or trying trol ons body ove ts back but fling to dota? ‘oth vcs recevedimmethate and terminal wouter. heartbeat (punping blood). No expectoratd ood. ‘Attempting to rllbody would produce elongated tfpe spatter tans but only low and at shoelevel 10.6: Opinion Samy pote nye fan thet wtb expat eo te fae ‘would bee transfer (swipe) pattern frm checking Hr sigs of life (ody-handace). 2911SGJ 2021-206 31-21-0061 1047: Can the poston forthe shooter for Margaret’ shoctng be Identified? ‘Margaret has (5) gunshot wounds, Gunshot wou {oper abdomen) have sinlar range, spline, ond igeneraly not cause immediate death or immobity. Gu ‘ot be 9 continuation of gunshot wound 1 (anatomical ‘cansdered not lethal in most cates not contin ‘Gunshot wound 2 could be the resus of the projectile Incapectation andthe unknown movernents of Margaret. (ef thigh) and gunshot wound or. These two wounds would wound 2 left wrt) may or may side). Gunshot 2 would ako be ofthe upward left torso wound. in the doghouse due to slack of 17: Opinion tts my option that an exact postion ofthe shooter Margaret.” The most accurate Information avaliable shooters potion ete physical location and postion tnknown movements (10-3, Kinsey 2022). 1048: How does environmental factors end pyle! baarved?| + Emdronmental factors such as (enteme) heat, physical manipulation ofa wet garment can {garment prior tothe garment beng dled. + Shape and type of stain would remaln constant ‘ould fade or darken n appearance over tine In controled condtions. 1048: Oploion ‘in my opnlon environmental factors can affect the garment the garments exposed to harsh ‘red and handle. Blood sais that are present. ‘red packaged, procesed, andar (ed) wil time exposed to the desrbed extreme cond 2912SGU 2021-206 31-21-0061 109: Would the shooter for ether vcim get blood back sppter on thelr person or dothing? + Distance of shooter (several fy) lack of blood and fue letting and ange of Paul would aly not produce back spatter on shooter for gunshbt wound (3). + Birdshot close to mue end of wespon 2). * Possty back pater on (2) shotgun was sholidered dv to shot ection, gravity, be expected shooter was doser tothe mul end of weapon, Margaret = Two gunshot wounds exhibited stppling (43 & 45) + Nebher were dose proximity to each ater. ‘+ femaining wounds were from adstance greater tha} would be expected to project blood. 108: Opinion {tis my opinion thatthe ftal shot to Pauls shoul face, and head would kahy produce enough bck spatter (2), and would be win range to contaminate ‘he shooter. This amount would produce very small roplets-immy +108 fps] of projected blood nthe direction ofthe shooter Hf shdderng the weapon and fring in 2 Parle tothe ground postion. The aly presence blood droplets andother tse zantt Ifthe shooter was not belfind the stock, but was pestloned, Closer tothe muzzle end ofthe weapon (increase Ingle ray). ‘Additonal, the ony gunshot wound on Margaret et would be suficentto produce back spoter would be GSW (}, due ta ditance, (Single projec vs. shotgun pellets). However, tlsjyound would not project blood and ‘Ussu far enough In most cases to contaminate the dhoter. 2013SGJ 202'-296 31-21-0081 10.20: Does the physical edence support strugue better Paul and the shooter gven the shot to his chest? = Stpplng on anatomical left side of chest wound. paul tsangied. 10:02 Opinion {identi no physical evdence thet would suggest or the shooter. hots rue btwn al and 1.11: Could the shooter be prone or knesing on the ant at the time ofthe shouldr- headshot? 41: Opinion . Paul's height of 58", and the sharp angle support tht Pauls left side was diping slighty, Standing r exiting the fed room athe time of the 1H. Blood due, blood volume, and body fads oo oor frame, directionality, veld areas to the ‘documented onthe SW side of shelved Items ‘evered bra would place the shoter outside ‘The length ofthe shotgun would be needed fora unlikely that the shooter was standing with &

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