IR-01-23-13799
13 July 2023
Sean Doyle
[email address]
Dear Mr Doyle
Request for information
Thank you for your Official Information Act 1982 (OIA) request of 5 May 2023, in which you ask:
‘What forms of impartiality, or bias as it is referred to by the New Zealand Police, and the
management of that bias are integrated into forensic training for the Police in New
Zealand?
What impartiality or bias related forensic training is offered to Police staff who provide
forensic services?
What resources are employed in that training?
Are copies of training materials available publicly?
If so, where might they be found?
How often is that training updated?
How is its continuing fitness-for-purpose (i.e., effectiveness, relevance and accuracy)
assessed?
What processes and procedures are in place to counter the effects of bias in the work
carried out by Police forensic staff?
How is this monitored and managed?
What reporting or audit is undertaken of these processes and procedures.’
In response to your request, I can advise that the awareness of the risks of cognitive bias (including
contextual and confirmation bias) on forensic findings is integrated into New Zealand Police forensic
training courses and standard operating procedures.
Forensic training is delivered by trainers in a variety of settings, including face to face training,
discussion groups, Court scenarios, practical scenarios, and self-directed training. There is an
emphasis on how bias can manifest using work examples, and how standard operating procedures
must be fol owed to prevent or mitigate bias. Training also includes a focus on the professional and
impartial presentation of expert evidence in Court.
Forensic training content is revised when new policy or process changes impact on training currency
or content. Fitness for purpose is managed through subject matter expert groups who have
responsibility for monitoring and updating training content and standard operating procedures for their
respective disciplines.
Forensic training comprehension is managed through knowledge tests and work competency
assessments. Compliance with standard operating procedures is also monitored through peer
review, quality control and national auditing processes.

The potential effects of bias are managed by:
•  ensuring that forensic staff are aware of the implications of cognitive bias; and
•  having standard operating procedures which include protocols for checking and peer reviewing
results.  The procedures also include protocols on how contentious results are managed to
mitigate possible bias; and
•  the requirement that expert witnesses comply with the High Court Rules 2016.

Standard operating procedures for forensic groups include quality assurance management and
auditing by line and national managers.

Attached are the fol owing Police documents that are relevant to your request:
i)  Fingerprint Officer Training Programme Module: Identification 2 Intermediate 1 (15 pages)
ii)  Fingerprint Officer Training Programme Module: Law 2 (24 pages)
iii)  New Zealand Police Fingerprint Section Standard Operating Procedure #2 – Latent
Fingerprint Examination and Identification (5 pages)
iv)  New Zealand Police Fingerprint Section Standard Operating Procedure #4 – Independent
Evaluation Review: Fingerprint Identification (5 pages)
v)  New Zealand Police Fingerprint Section Standard Operating Procedure #24 – Verification (5
pages)
vi)  Fingerprint Officer Training Programme Intermediate 1 Oral Questions: Identification 2 (2
pages).

I trust this information and material adequately addresses your request.

Yours sincerely

Warren Olsson
Detective Inspector
National Criminal Investigations Group
Police National Headquarters

Fingerprint Officer Training Programme

Module: Identification 2
Intermediate 1

Document Owner: National Fingerprint Training Officer
School of Investigations: Forensics training
The Royal New Zealand Police College
Papakowhai Road
Private Bag 50906
PORIRUA

© New Zealand Police January 2019

Copyright reserved

This document, or any portion of it, may not be reproduced or transmitted in any form or by any
means, electronic or mechanical (including photocopying, recording or by any information
storage retrieval system), without the express written permission of the New Zealand Police.

Contact for copies: Please contact the document owner if you want a copy of this manual.

New Zealand Police Fingerprint Officer Training Programme; Identification 2, March 2017

2

Module Outline

Overview
Fingerprint Officers’ main role is fingerprint identification.

As you develop your experience in examining and comparing fingerprints,
you will need be able to identify more complex prints.

To that end, this module covers three topics:

•  Topic 1: Distortion
•  Topic 2: Bias
•  Topic 3: Forgery and Fabrication.

As you read and review the information and documents, you may wish to
make a few notes in your personal learning journal.

Required
•  Ashbaugh D R, Quantitative Qualitative Friction Ridge Analysis: An
reading
introduction to basic and advanced ridgeology. Boca Raton FLA:
CRC Press, 1999. Pp 108-148.
•  Marcel S, Nixon M S, Li S Z, 2014. The Handbook of Biometric Anti-
Spoofing. Springer. Chapter 2: Forgeries of Fingerprints in Forensic
Science, by Champod C, Espinoza M.
•  Harper W W, 1937. Fingerprint Forgery – Transferred Latent
Fingerprints. Journal of Criminal Law and Criminology, Vol 28, Iss 4,
Article 7. Sourced from:
http://scholarlycommons.law.northwestern.edu/cgi/viewcontent.cgi?ar
ticle=2745&context=jclc
•  Maceo A, 2009. Qualitative Assessment of Skin Deformation: A Pilot
Study. J For Ident, 390, 59 (4).  (Located in Required Reading folder).
•  Venville N, 2010. Bias - A Review of Contextual Bias in Forensic
Science and its Potential Legal Implications. (Located in Required
Reading folder).

5

Optional reading  •  Edwards H T, 2014. Reflections on the Findings of the National
Academy of Sciences Committee on Identifying the Needs of the
Forensic Science Community. Sourced from:
https://www.justice.gov/sites/default/files/ncfs/legacy/2014/05/13/harr
y-edwards.pdf
•  Busey T A, Dror I E, 2014. Fingerprint Sourcebook.  Chapter 15,
Special Abilities and Vulnerabilities in Forensic Expertise. Sourced
from: https://www.ncjrs.gov/pdffiles1/nij/225335.pdf
•  Expert Working Group on Human Factors in Latent Print Analysis.
Latent Print Examination and Human Factors: Improving the
Practice through a Systems Approach. U.S. Department of
Commerce, National Institute of Standards and Technology, 2012.
Sourced from: http://www.nist.gov/oles/upload/latent.pdf
•  Ferriola, T J, 2002. Scientific principles in friction ridge analysis and
applying Daubert to latent fingerprint identification. Criminal Law
Bulletin. (Located in Optional Reading folder).

6

Topic 1: Distortion

Learning
The questions you need to answer for this topic include:
objectives

•  What are four factors that could result in a fingerprint lift showing
distortion?

•  What is the concept of ‘tolerance’ with reference to observable
differences between a latent print and a fingerprint sample?

•  When considering substrate distortion, what are three types of substrate
that may influence the appearance of the latent print? What features are
likely to be observed in the latent print for each type of substrate?

•  With reference to matrix distortion, what are some of the features that
may be observed in wet prints?

•  With reference to matrix distortion, what are some of the features that
may be observed with fingerprints made in blood or paint?

•  When considering development media, what are the characteristics or
features associated with each of the four development media (powder,
ninhydrin, iodine, and cyanoacrylate)?

•  What is the difference between deposition pressure and pressure
distortion?

•  What are six observable ‘red flag’ indicators of distortion in a latent
fingerprint?

Definition
According to one of Webster’s New World dictionaries, ‘to distort’ is
defined as:

“To modify so to produce an unfaithful reproduction; to change or
misrepresent; to change the usual or normal shape, form, or appearance.”

7

Distortion
With reduced quality of latents, distortion is likely to be present. As part of
our analysis process, we must be able to discern the nature of the distortion
and understand the behaviour of the ridges when they are subjected to these
distortive forces. All prints will suffer from some sort of distortion.

According to Ferriola, 2002:

“Distortion could result from a number of sources, including the matrix
(residue left behind), which comprises the print; the substrate (surface) on
which the print was left; the direction of touch; the pressure of the touch;
the reaction of the matrix with the development medium; etc. All of these
factors should be assessed during the analysis of the latent print.”
Sourced from:
http://www.clpex.com/Articles/ScientificPrinciplesbyTomFerriola.htm

Types of
The types of distortion are:
distortion
1.  Pressure.
2.  Deposition pressure.
3.  Anatomical aspects.
4.  Development:
a.  Medium.
b.  Substrate.
c.  Matrix.

Evaluation
According to Ferriola, 2002:

“During the evaluation phase of the identification process, the examiner
must consider all of the differences in appearance between the two images.
It is an accepted tenant of fingerprint science that no two prints will ever be
exactly the same in all respects.

“First, any ‘touch’ is a contact between a complex curved surface (the skin)
and, usually, a flat surface. This touch must necessarily be accompanied by
distortion of the skin. Second, the amount and type of matrix (residue left
behind) will differ. Third, the angle and pressure of the contact will change
from one touch to the next. Fourth, the size of the area of skin coming into
contact with the surface will vary.

“Any number of other factors, some subtle and some extreme, may also
8

contribute to differences in the appearance of two prints that result from
two touches by the same region of friction skin. It is not sufficient to look
only for similarities and ignore the differences, nor is it proper to look at
only some features and ignore others. The fingerprint expert must consider,
interpret and understand everything appearing in each image.”
Sourced from:
http://www.clpex.com/Articles/ScientificPrinciplesbyTomFerriola.htm

Tolerance
It is at this point that tolerance enters the equation (Ferriola, 2002). Based

on an understanding of distortion and its sources, some differences in
appearance fall within acceptable limits of tolerance. For example, it is easy
to understand and to account for the differences in appearance between a
print resulting from a light touch and a print resulting from a heavy touch.
The differences in appearance between a fully rolled inked print and a
crime scene mark are also easy to understand and easy to account for.
These differences would be said to be within tolerance. Sourced from:
http://www.clpex.com/Articles/ScientificPrinciplesbyTomFerriola.htm

Development
1.  Powders – abrasive. Collects in pores. Tends to fill in third-level detail.
media
2.  Ninhydrin – concentration of amino acids are found at the pore
openings on the ridges, therefore prints developed with ninhydrin can
appear spotty.
3.  Iodine fuming – absorbed into matrix. Non-abrasive so should show
third-level detail clearly.
4.  Cyanoacrylate – molecules polymerize with the matrix. The heat plus
humidity method leaves a ‘spaghetti like’ matrix. The vacuum leaves a
more ‘flaky’ appearance. Lighter coverage.

Deposition
Deposition pressure changes the shape of the ridges by flattening or
pressure
broadening each ridge, thereby narrowing the furrows. It describes vertical
weight placed on the ridges.

Pressure
This is different from deposition pressure. Pressure distortion describes
distortion
pressure in the lateral or horizontal plane. It is usually accompanied by
sideways sliding of friction ridges with a smeared appearance.

9

Problem
Some distortion indicators generate a need to be wary. These could be
solving
considered as ‘red flags’ for careful analysis of pressure and deposition

pressure distortions. Indicators of distortion include:

•  Ridge disturbances – sudden differences in the appearance of the matrix
or development media.
•  Lines through pattern area.
•  Misaligned ridges.
•  Extra thick ridges.
•  Hatch ridges.
•  Crossovers.
•  Angular joints.
•  Lack of harmony in distortions.
•  Substrate artefacts.

10

Topic 2: Bias

Learning
The questions you need to answer for this topic include:
objectives

•  What is the concept of bias?
•  What is cognitive bias and confirmation bias?
•  How can you self-manage to try and avoid bias?

Introduction
The concept of bias was referred to in the previous module, Identification 1.

Bias is not a fault; it results simply from the way the human mind works.
For experts, bias is an unavoidable, inherent outcome of their very expertise
and comes with the nature of our work. All information we receive
potentially introduces bias. Bias must be recognized and accommodated for
when undergoing the ACE-V process. Quite simply, bias distorts the way
we perceive and evaluate information.

Cognitive bias
This is defined as:
“The tendency to make decisions or take action in an illogical way. For
example, you might subconsciously make selective use of data, or you
might feel pressured to make a decision by more influential or more
senior colleagues.” Sourced from:
https://www.mindtools.com/pages/article/newTED_79.htm

Confirmation
Confirmation bias happens when you look for information that supports
bias
your existing beliefs, and reject data that goes against what you believe.
This can lead you to make biased decisions, because you don’t factor in all
of the relevant information. It is the tendency to look for information that
conforms to your hypothesis. Sourced from:
https://www.mindtools.com/pages/article/avoiding-psychological-bias.htm

11

How do I
All information can introduce bias, so it’s important to:
manage bias?
•  Keep an open mind.
•  Be impartial in your examination process.
•  Never assume.
•  Examine everything as if it were a blank script.
•  Not compare the known print to the latent.
•  Not be emotively swayed by the nature of the offence.
•  Never assume it is an offender’s print. Do not allow your mind to be led
to believe it should be an offender’s print.
•  Manage the verification/peer review process. Verifications should
always go ‘up’ the experience/ability ladder.

12

Topic 3: Forgery and Fabrication

Learning
The questions you need to answer for this topic include:
objectives

•  What is the difference between forgery and fabrication?
•  What are the three methods of fabrication, and what clues might be
observed in each case of the recovered fabricated latent?
•  What are two methods of forgery and what clues might be observed in
each case of the recovered forged latent?

Introduction
To help understand the differences between forged and fabricated, the
following definitions provide a good insight.

Fabricate
“Fabricate” in the sense of “manufacture” has no moral or ethical
implications, although it can be used in the sense of making things up and,
by implication, lying. A statement which is a fabrication (a lie) would not
be called forged. A “fabricated” latent print is manufactured or
misrepresented by a person, possibly involved in the investigation, in order
to enhance the case against a suspect.
Sourced from: ell.stackexchange.com/questions/78989/forgery-vs-
counterfeiting-vs-fabrication

Forge
A signature, document, or painting could be forged. That is, we could
reproduce it with the intention of having people mistake it as being
authentic. Sourced from:
ell.stackexchange.com/questions/78989/forgery-vs-counterfeiting-vs-
fabrication

“A ‘forged’ latent print is the print of an innocent person that has been
‘planted’ at a crime scene by the perpetrator (or another person) in an
attempt to hide the true offender’s identity.

“As part of your fingerprint knowledge, you will be expected to be vigilant
and observe the appearance of prints in order to detect forged or fabricated
evidence.”
Sourced from:
https://www.ncjrs.gov/App/publications/abstract.aspx?ID=202212

13

Signs of
According to Pat A Wertheim, Director of Training, Forensic Identification
fabrication
Training Seminars Ltd (see source below):

“Examiners need to be alert to the signs of fabrication in latent print
evidence submitted by others, and they need to follow procedures in their
own cases to document absolutely the authenticity of their latent prints in
order to preclude the charge of fabrication against their legitimate
evidence.”

Wertheim goes on to discuss methods of fabrication. The following text is
summarised from the source (see below).

The usual methods of fabrication are:

1.  To lift the print from a known, inked print and then label it as having
come from the crime scene. Clues – ink is a different shade of black
than fingerprint powder. Lifted inked prints are usually the fully rolled
prints, a phenomenon virtually impossible in real latent print work. Lifts
from inked prints usually include fibres and microscopic fibre marks.
2.  Mislabelling the print as having come from a crime scene when it was
actually lifted from a more benign location. Clues – the most reliable
method of detection is a close inspection of background noise. Each
type of surface leaves a trademark background noise, and frequently,
fabricators fail to take this into account. A mislabelled latent may also
reflect an orientation inconsistent with normal handling.
3.  Through the use of a staged photograph of the print. Clues – these
photographs are usually taken slightly out of focus in an attempt to hide
details which would disclose the fabrication. Or, such a photograph may
be over or under-exposed. Strange lines or shadows may be present.
The photographs may also contain stray images not expected on the
surface from which the latent purportedly came, or background noise
may not be consistent with the surface claimed.
Sourced from: www.iowaiai.org/latent-fingerprint-fabrication

14

Considerations
Kristi Mayo’s article (see source below) discusses the factors that an
examiner should look out for to alert them to fabrication:

“… a lifted print that does not match the surface from which it was
supposedly taken; a lift that has different characteristics from the other lifts
collected at the same scene; and inconsistency in lift tapes.

The article also discusses collection techniques examiners can use to avoid
any suspicion of fabrication:

“… photograph the print in place before it is lifted; include the description
of the latent print in crime scene processing notes; and using a marking,
perhaps with a ballpoint pen, on the surface near the print to be included in
a re-photograph of the print. Other techniques are to keep lifts together and
to use serial-numbered lifts.”
Sourced from:
https://www.ncjrs.gov/App/publications/abstract.aspx?ID=202212

Office practices  We cannot categorically state the true origin of latent prints unless we were
there ourselves and actually lifted the prints. It is for this reason that we do
not report on the origin of the prints, rather we say ‘labelled as’ and why we
copy the exact wording, misspellings and all.

Signs of
Forged fingerprints are rare. Clues – the ‘staged’ appearance of the prints.
forgeries
The locations of the prints might be in an unnatural or unlikely area.
Locating any forged fingerprints relies on the scene examiner developing
and lifting the planted prints.
1.  Casting materials like stamps or latex moulds can be used. Clues –
bubbles in the developed print (from air bubbles in the latex mould).
The framing effect (halo) of the stamp or mould. Examine the pores and
ridges carefully. Overall shape inconsistent with natural deposition.
2.  Transfer of latent from one surface to another. Clues – careful
observation of background noise, which will have transferred across
with the latent print.

End of module
Congratulations, you have completed the Identification 2 module. Be

prepared to answer questions on these topics.

You are now ready to begin the next training module.

15

Fingerprint Officer Training Programme

Module: Law 2

Document Owner: National Fingerprint Training Officer
School of Investigations: Forensics training.
The Royal New Zealand Police College
Papakowhai Road
Private Bag 50906
PORIRUA

© New Zealand Police

Copyright reserved

This document, or any portion of it, may not be reproduced or transmitted in any form or by any
means, electronic or mechanical (including photocopying, recording or by any information
storage retrieval system), without the express written permission of the New Zealand Police.

Contact for copies: Please contact the document owner if you want a copy of this manual.

Contents
Topic 1: Understanding your place in the court system ............................................................ 1
Expert witness purpose and role ............................................................................................................................ 1
How Court processes work .................................................................................................................................... 3
What we can and can’t say in court ....................................................................................................................... 5
Disclosure .............................................................................................................................................................. 8
Rules of Evidence and the Evidence Act ............................................................................................................... 8
Topic 2: Explaining your work and profession ........................................................................ 12
Fingerprint evidence ............................................................................................................................................ 12
Relevant Case Laws - New Zealand .................................................................................................................... 13
Relevant Case Laws – International - Daubert ..................................................................................................... 16
Errors in Fingerprints overseas – McKie and Madrid Bombing .......................................................................... 18

i
December
2015

Topic 1: Understanding your place in the court system
Expert witness purpose and role

How a case is
A case will only be considered appropriate for prosecution if the various
selected for
factors, unique to that particular case, indicate that there is both evidential
prosecution
sufficiency and pubic interest in prosecution.

The evidential sufficiency test is determined first. If that is satisfied then
the officer must proceed to consider the public interest test. The weight of
factors is not based on the number of factors; rather it is on how various
factors relate to a specific unique offender and all the circumstances
relating to that offender.

The core
An expert witness is engaged by the courts to assist the courts. While you
purpose of an
can be engaged by either prosecution or defence, your role is to maintain
Expert Witness
impartiality; you are neither ‘for’ the prosecution or the defence.

The general position in the Evidence Act 2006 is that a statement of
opinion is not admissible in a proceeding to prove the truth of what is
believed. The reason for this is that witnesses in a case give evidence as to
the matters they have experienced, not their beliefs or opinions, and that
factual evidence has to be evaluated and a decision made on the legal and
factual issues in dispute. However, from the earliest times, the courts
recognised there were technical areas outside common knowledge where a
court might benefit from the assistance of expert opinion in understanding
the matters which it had to evaluate.  The courts admit expert evidence
when the judge is satisfied that the matters which the expert evidence
addressed were outside “common knowledge” and expert opinion is
required.

Expert evidence   Expert evidence is defined under the Act in terms which reflect the

position at common law:
“The evidence of an expert based on the specialised knowledge or skill of that
expert and includes evidence given in the form of an opinion.”

New Zealand Police FPO Training Programme Intermediate 2 Law 2   page 1
December 2015

It is for the court to consider whether an expert is properly qualified to
give expert evidence and whether the evidence which they will give is
within the expert’s area of expertise. A court will rule on this if there is a
challenge to the evidence. Opinions by non-experts on technical matters
are inadmissible.

The various codes of conduct adopted by the courts in the past decade
emphasise that in giving this expert opinion, the paramount duty of an
expert is to assist the court to understand the evidence in the case.

The role of the
An expert witness has a number of conflicting duties which need to be
Expert Witness
managed and resolved correctly:

  The most important is the duty to the court and is to be treated as a
paramount and overriding duty. At its core is an obligation to assist the
court in arriving at the truth. It should be borne in mind that, it is the
court which makes the ultimate decision and the role of the expert is to
educate the court to the same level of understanding as the expert on
the particular issue in question, in this case, fingerprints.
  The expert is not an advocate for a particular party and should remain
true to his or her profession and refrain from attempting ‘to win’ the
case.
  An expert witness is to ensure that all of the relevant points of the case
are brought to the attention of the court.
  An expert has a duty to comply with the directions or orders made by
the court; these directions should be provided to the expert by the legal
practitioner conducting the matter. Directions are usually
straightforward and typically determine whether there will be a joint
conference; the timeframes for serving reports; the dates for hearing;
terms on which experts are to be briefed etc. Such directions will
normally be made by the Judge, often by consent of the parties.
  The expert has a duty to maintain his or her reputation by providing
competent advice to the court (reasoned conclusions are preferred to
bold conclusions) and refusing to put forward arguments that lack
substance or credibility in an attempt to unreasonably advance the
client’s case. It is inappropriate to allow the instructing lawyer or any
outside party to ‘filter’ the expert’s report. The lawyer may provide
advice on legal or procedural matters and may even provide advice as
to the scope of the report and its relevance to the proceedings.

New Zealand Police FPO Training Programme Intermediate 2 Law 2   page 2
December 2015

  With Joint Conferencing it is inappropriate to allow the instructing
lawyer or any outside party to interfere with the independent expert
witness process once a Joint Conference has commenced.
  Your duties to the court include confidentiality; diligence especially in
presenting the case fully and fairly; punctuality; and to quote fairly and
transparently. The duty is to be truthful as to fact, honest as to opinion
and complete as to coverage of relevant matters. Expert evidence must
be independent, objective and unbiased.

Presentation of
A Statement of Evidence is where the expert sets out his opinion and
Expert Evidence  qualifies themselves as an expert to the court. This should ideally be a

complete document without the need for further amendment. An
acknowledgement that the expert has read the ‘Code of Conduct’ and
agrees to be bound by it should be contained in the statement of evidence.

How Court processes work

Integrity
The integrity of the expert should be above reproach. You owe a duty to

the court as the court seeks to gain assistance from the expert. It is
important to have confidence in the opinions that you express. A primary
requirement is to ensure that the statement is thoroughly prepared and that
you, the expert, are familiar with all facts upon which the conclusions are
formed. Knowledge plus careful preparation is the key to providing good
testimony in court.

The general
a)  Witness gives evidence-in-chief (direct examination) then;
framework of
the trial process:  b)  Cross-examination by other parties, then

c)  Re-examination by the calling party.

New Zealand Police FPO Training Programme Intermediate 2 Law 2   page 3
December 2015

Direct
At the hearing the expert is sworn in by taking an oath on the bible or
Examination
making an affirmation. Both carry the same obligations, which is to tell the

truth.

When called to the witness box, the expert should take his notes and
documents. While we are generally ‘called’ by prosecution, we may
occasionally be called by defence. Whichever party has called you will
direct the evidence in chief, which is comprised of your statement.
At this stage, leading questions are not allowed to be asked. That is, those
questions which suggests to the witness how it is to be answered or puts
words into the mouth of the witness to be merely repeated in his or her
response.

Refreshing memory. If you need to refresh your memory while giving
evidence permission must be sought. You may refer to documents that
were made by you when your memory was ‘fresh’ (contemporaneous
requirement). Address the judge as ‘your honour/ma’arm’ or ‘sir/madam’
and ask his/hers permission to refer to your notes.

Cross
The main goal of cross examination is to investigate the truth of the
Examination
witnesses’ testimony in recognition of the adversarial nature of our trial

processes. The object is to elicit information favourable to the cross
examination team (generally defence but could be prosecution) and to cast
doubt upon the accuracy of the evidence in chief.

Cross examination is flexible and effective. You need not view the
prospect of being cross examined with alarm; however you should ensure
you know your facts thoroughly. You should express yourself as
accurately and completely as possible. Be frank and be prepared to
concede immediately anything that should be conceded. A successful cross
examination can severely weaken or destroy an expert’s testimony,
however a cross examination that reveals the accuracy of your expert
opinion, the logic of your reasoning and the soundness of your
conclusions, enhances the weight and reliability of your opinion and
therefore your standing as an expert.

New Zealand Police FPO Training Programme Intermediate 2 Law 2 page 4
December 2015

Re-examination
If after cross-examination, it appears necessary to clarify some of the

answers you have given, leave can be sought and usually obtained for ‘re-
examination’ of the matter needing clarification (as opposed to further
evidence). This is often a frustrating exercise for the expert witness
because leading questions cannot be asked during re-examination with the
consequence that the witness may not then have the opportunity to further
elaborate on a point or issue.

Once you have finished giving your testimony, you will be directed to step
down from the stand. However, you must not leave the court until you
have been given explicit permission to do so.

What we can and can’t say in court

Prepare
  Be well prepared.

  If you are going to be referring to ‘level 3 detail’ in your analysis
notes, ensure you point to or mark out some ‘level 3 detail’ in your
crimcons. These are to assist the jury; the jury needs to see the level 3
detail you refer to, rather than you simply saying it is ‘present’.

Listen carefully
  Listen to all the questions, all the time, in particular any questions from

the judge.
  Listen to a question fully and comprehend what is being asked before
you begin to answer.
  Listen carefully to the question from Counsel, especially long-winded
questions as they can be effectively no more than a statement. If in
doubt, ask for clarification or ask for the question to be repeated or
broken into parts. They may drop it altogether! Be slow and
methodical in your approach, don't appear overconfident but be
articulate in your response.
  Listen to the question and if it is not understood ask for it to be
repeated or clarified

New Zealand Police FPO Training Programme Intermediate 2 Law 2   page 5
December 2015

Answer
  Questions in cross-examination will be put in a closed form - do not
thoughtfully
agree with propositions which are poorly informed or incorrect.

  Where a concession is appropriate, make it.
  Do not back down unnecessarily. If your position can properly be
justified, then answer accordingly.
  Do not put on any kind of a “show” for judge or jury. Keep your
evidence as simple as possible.
  if you have made an error, do not try to cover it up.
   Do not become an advocate for the case of the party which instructs
you.
  Expert evidence must be objective, independent and unbiased

Verbalise
  If you use or refer to any visual aids or diagrams, these must be

verbally articulated so the stenographer can explain what you are
referring to in the transcript. For example, the transcript might read
‘witness points to lift 12’.

Know your role
  It is not for you to determine what is best for the court, so refrain from

saying you are ‘assisting the court’ or advising the judge on previous
case law.
  The court determines if you’re an Expert or not, for the purposes of
that particular trail. If you are there giving evidence it can safely be
assumed the court has accepted you as an expert in your field. So don’t
be afraid to use the terms ‘In my experience” “in my opinion”. You
are deemed an ‘expert’ through your training and experience.

Manage your
  You should remain calm and polite and if necessary be firm but not
demeanor
argumentative.

New Zealand Police FPO Training Programme Intermediate 2 Law 2   page 6
December 2015

Know about our
  Know the difference between verification and peer review! Peer
processes
review is a well defined scientific process and a process by which a

scholarly work (such as a paper or a research proposal) is checked by a
group of experts in the same field to make sure it meets the necessary
standards before it is published or accepted. It constitutes a form of
self-regulation by qualified members of a profession within the
relevant field. Peer review methods are employed to maintain
standards of quality, improve performance, and provide credibility. In
Fingerprints, peer review is the review of our case files for court by
two others, confirming we have used a recognized methodology to
arrive at a conclusion and that another person can follow that
methodology and arrive at the same conclusion. Verification is the
final step in ACE-V and involves another examiner verifying the
identification made and presented by an identifier, that is, do they
support the ID.

Understand our
  We mention belonging to a ‘society’ or professional body in our
professional
statements; firstly because we are expert witnesses and membership of
memberships

a professional body supports this and secondly, because it implies we
abide by their code of ethics. If you have a professional membership in
your statement, you must ensure you know about this organisation and
the rules it expects you to abide by.

Initiate when
  Ensure any exhibits you refer to have already been presented in court.
appropriate
If not, you may wish to prompt prosecution politely. For example:

“Sir/Madam, if I could now produce exhibit xyz, this will assist me in
demonstrating this point’.
  Do not hesitate to request that documents be shown to you that will
assist you in giving evidence.

Code of conduct
At all times the expert must abide by the High Court code of conduct for

expert witnesses and remain professional and polite.

Refer:
http://www.legislation.govt.nz/act/public/1908/0089/latest/DLM1817947.
html

New Zealand Police FPO Training Programme Intermediate 2 Law 2   page 7
December 2015

Disclosure

Rules of
The Criminal Disclosures Act 2008 came into force in 2009. Disclosure
Disclosure
under the Act occurs in a number of stages. Initial disclosure by the

prosecution must be made within 21 days of commencement of the
proceedings. This includes a summary of the facts of the alleged offence,
the penalties applying to the offence and a summary of the defendant‘s
previous convictions. Following this, the defendant can request further
disclosure, including the names of witnesses to be called, a list of exhibits,
copies of all interviews and notes on evidence. Full disclosure occurs after
the defendant has pleaded in a summary proceeding, elected trial by jury, or
made an appearance in court. The prosecution must disclose all relevant
information, together with a list of any information that the prosecution is
refusing to disclose. The defendant can, once again, request that the
prosecution make additional disclosure. Under the Act, the prosecutions
obligation to disclose is ongoing. Disclosure by the defendant is limited to
disclosure of an alibi, if one will be argued, and disclosure of any expert
witnesses that will be called.

All disclosure occurs through the OC file, which in our instances will be a
police member. He/she determines what evidence is required to be disclosed
and will undertake to do so. You must always submit your disclosure pack
to the OC file for them to deal with as appropriate. They should never be
sent directly to either prosecution or defence counsel.

Rules of Evidence and the Evidence Act

Introduction to  Evidence is determined by both the common law and the Evidence Act,
Evidence
2006. It covers a whole list of rules; the ones discussed here have some

relevance to your role as a Fingerprint Officer in court or when preparing
statements and cases for disclosure.

The Purpose of  Stated in S6 of the Act; the main objective of the Act is to “help secure the
the Act:
just determination of proceedings”. This is achieved through six objectives;

1.  providing for facts to be established by the application of logical rules
2.  providing rules of evidence that recognise the importance of rights
affirmed by the New Zealand Bill of Rights Act, 1990
New Zealand Police FPO Training Programme Intermediate 2 Law 2   page 8
December 2015

3.  promoting fairness to parties and witnesses
4.  protecting rights of confidentiality and other important interests
5.  avoiding unjustifiable expense and delay
6.  enhancing access to the law of evidence

In order to be admissible, evidence must be relevant and will only be
admitted if its probative value outweighs any unfairly prejudicial effect that
it may have on the proceeding

Relevance
Section 7(1) states the general rule that, unless otherwise provided, relevant

evidence is admissible in court proceedings. Evidence that is not relevant is
inadmissible. Relevance is defined in section 7(3) if it has a “tendency to
prove or disprove anything that is of consequence to the determination of
the proceeding”. This consists of two factors; materiality and probativenss.

Materiality asks if it is sufficiently relevant to an issue before the court and
probative is whether the evidence has the tendency to prove or disprove that
issue.

Looking at the above statement again, we break it down as follows:

“tendency to prove or disprove (probativeness) anything that is of
consequence to the determination (materiality) of the proceeding”. Both
these must be satisfied for evidence to be relevant.

There is always a cost, in terms of money, time, multiplication of issues, or
possible prejudice, of introducing any piece of evidence. The probative
value of the evidence must be weighed against these costs.

General
Although relevant, evidence may be excluded if its probative value is
Exclusion
substantially outweighed by the danger of unfair prejudice, confusion of the

issues, or misleading the jury, or by considerations of undue delay, waste of
time or needless presentation of cumulative evidence. Exclusionary rules
exist to govern this.

Section 8(1) sets out the rules of exclusion of evidence that is otherwise
relevant. These are mandatory. As a general rule, evidence MUST be
excluded if (a) its probative value is outweighed by its unfairly prejudicial
effect or (b) it will needlessly prolong the proceeding.

New Zealand Police FPO Training Programme Intermediate 2 Law 2   page 9
December 2015

1.  Unfair Prejudice – e.g. danger a jury may give more weight to it than it
deserves or be misled by evidence. An example of unfair prejudice is
with previous convictions. The Fingerprint Officer must generally avoid
mentioning or alluding to previous convictions or arrest sets of
fingerprints. Care must be taken with giving evidence around prints held
on AFIS.
2.  Photographs and Videos. – Generally admissible but may be excluded if
the judge considers they may prejudice the jury.

Hearsay rule
A hearsay statement is defined as an out-of-court statement made by a
and its
person other than the witness, tendered for proof of its content. The focus
Exceptions
however is on the purpose or use of the statement. The following exceptions

apply to this rule;
1.  ‘State of mind’ evidence – may apply to show the state of mind,
knowledge, emotion of the hearer (the witness) or the speaker (the
maker). For example a statement could be held to not be hearsay if its
use was to explain why the witness did or believed something
2.  Exclusionary rules of Hearsay - General Admissibility of hearsay
statements – A hearsay statement is admissible if it is reliable (“the
surrounding circumstances must provide reasonable assurance that the
hearsay statement is reliable”) and unavailable (“a person who is
unavailable as a witness”).
a)  There are some further statutory exceptions to hearsay statements;
i)  Admissions
ii)  Business records – this covers disclosing our documentary
evidence in court, that is, our normal everyday business
documents.

Opinion
Under S23 the general rule is that opinions are not admissible as evidence.
Evidence
The reason for this is that a witness should testify only to what a witness has

perceived. There are of course exceptions to this as follows:
1.  Non-expert opinion S24 – Allows opinion evidence if it is necessary to
enable a witness to communicate what the witness saw, heard or
otherwise perceived. For example, non-expert opinion as to a person’s
sobriety is admissible but must state the observed facts that lead to that
conclusion and cannot express an opinion on matters such as their
fitness to drive.

New Zealand Police FPO Training Programme Intermediate 2 Law 2   page 10
December 2015

2.  Expert opinion Evidence S25 – This is fingerprint testimony. The
opinion must be of an ‘expert’ and it must offer ‘substantial help’ to the
fact finder in understanding other evidence or ascertaining any fact in
the proceedings.
a)  Expert – someone with specialist knowledge and/or skills based on
training, study or experience.
b)  Substantially helpful – impose a higher threshold than the general
admissibility balance of probative v prejudicial.

Risks of
There is a higher standard of accuracy and objectivity required in assessing
Expert
the admissibility of an expert opinion. This is because the testimony of an
Opinion
expert is likely to carry more weight. “An expert witness should provide
Evidence.

independent assistance to the court by way of objective unbiased opinion to
matters within his expertise…An expert witness… should never assume the
role of advocate”. 1


1 Cresswell, J. The Ikarian Reefer 1993, 2 LILR 68, 81-82

New Zealand Police FPO Training Programme Intermediate 2 Law 2   page 11
December 2015

Topic 2: Explaining your work and profession
Fingerprint evidence

Standards for
Fingerprints have been used in courtrooms since the early 20th century, and
Identification
judges have generally regarded them as scientifically sound.

Globally there are various standards (criteria) for identification in
fingerprint examination. At present, there are two well-known standards:
1.  The empirical approach (also called “minutiae threshold” or “numerical
standard”)
2.  The holistic approaches (also called “non-numerical approach”).

New Zealand
New Zealand has adopted the holistic approach and has never required a
Standards
numerical threshold to reach a conclusion of identity. There is a fallacy held

by some in the court system that we once obeyed a 12 point rule, that is,
followed an empirical approach. (This may have come from their
knowledge of Edmond Locard’s work. Locard stated in 1918 that if 12
points were the same between two fingerprints, it would suffice as a positive
identification.)

The holistic
The holistic approach calls for an assessment by the examiner of each
approach
comparison based on its own merit (in terms of quality and quantity as

revealed by the mark and the print). The expert concludes on an
individualisation when he/she is satisfied that there is “sufficient”
correspondence (or sufficient discordance in the case of an exclusion)
between the compared images. This informed judgment is based on training,
experience, and expert knowledge.

This was successfully argued in 1973 when the International Association for
Identification, IAI, adopted a resolution rejecting an arbitrary number of
corresponding points as the required basis for identification.

Ne’urim
This standard was endorsed by the International fingerprint community in
Declaration
the 1995 Ne’urim Declaration which states, “No scientific basis exists for

requiring that a pre-determined minimum number of friction ridge features
must be present in two impressions in order to establish a positive
identification” 11 countries were represented, including New Zealand.

New Zealand Police FPO Training Programme Intermediate 2 Law 2   page 12
December 2015

Other
While we adopt the holistic approach for identification, as we follow the
standards in
Ne’urim declaration, this only forms our identification standards. Other
our work
standards in our work are set by:

  Selection (a preference for tertiary study in a related field and/or
experience)
  Training (a rigorous 5 year programme of study and exams at tertiary
level concurrent with workplace ‘on the job’ learning and assessments,
resulting in a Diploma)
  Image quality/ quantity of detail
  Proficiency testing (Collaborative Testing Services (CTS,) an overseas
independent proficiency testing service)
  Case work quality assurance and the requirement of two verifiers before
each identification is released
  Standard Operating Procedures (SOP’s)

Points to
  Bias – refer to your module and readings on bias, you may be asked
Remember:
about bias in court or whether or not you have been biased in your

examination.
  We have a tendency to offer too much in response to a question. K.I.S.S.
saying ‘yes’ is a perfectly acceptable answer, you do not need to
elaborate and explain on every point.
  Understand your training programme. Who assesses you? Who governs
it and controls it? Who reviews the training? Is it peer reviewed?

Relevant Case Laws - New Zealand

Introduction
Case law (or common law) refers to any set of rulings on law which is

guided by previous rulings. Cases that are legally similar will generally be
decided the same way, conforming with the decisions of a higher court. This
is called the rule of ‘precedent’, and ensures consistency and certainty in
how the law is applied.

There are several cases and decisions which have set precedents for
fingerprint aspects in the New Zealand courts.

New Zealand Police FPO Training Programme Intermediate 2 Law 2   page 13
December 2015

R v Mokaraka.  Peer review (verification process) regarded as hearsay evidence. However it

was conceded that scientific evidence is often the result of team work. It is
therefore conceivable that there is or should be, a ‘common law exception to
the hearsay rule’ for this type of evidence.

R v Buisson
1990 – Court of Appeal considered the admissibility and nature of
and Ratana
fingerprint evidence. The court ruled;

a)  ‘It is for trained fingerprint experts, who are able to see features not
apparent to a lay person, to determine the existence of characteristics
or points of similarity. That is not matter for the jury.” The evidence
for the jury to consider was the opinion tendered by each expert, and
in assessing its reliability they had to decide what they made of his
claim to have discovered various points of similarity and his
conclusions based upon them. The jury were entitled to reply on
what they had been told about those points of similarity if they were
satisfied with the experts reliability; and
b)  (b). A fingerprint expert is not obliged to produce and show in court
the original prints of the fingerprints, but may be required to do so if
their evidence is to be contested. It is the expert’s testimony which is
the evidence, not the prints, which could not be understood of
themselves by the jury.
c)  It was determined that there was no requirement for 12 points to be a
criterion for identification, but rather the ‘standard of proof is one of
beyond reasonable doubt rather than scientific certainty’.
“Something less than 12 points may be acceptable for safety, and in
some special cases as few as 6 points”

Queen v
– in a ‘voire dire’ the defense tried to say the FP evidence was inadmissible
Sidney Te
as its prejudicial value outweighed the probative value. Here the court
Paiho
upholds the fact that there is no requirement for there to be 12 points (as per

R v Buisson) and that the surrounding (that is, sequential fingers) and other
prints identified to the offender on the same exhibit, add value/weight to the
identification overall. In this case there were prints on a bed head from a
rape scene.

New Zealand Police FPO Training Programme Intermediate 2 Law 2   page 14
December 2015

R V Krausch
This was a ruling on the ‘value of fingerprint evidence’. This was a
(1913) –
landmark case where the judge determined that fingerprints were

established scientific facts. Fingerprints “may be regarded as established
facts. The first of these facts is that finger-markings remain absolutely
unaltered from birth to death... the second is that..the characteristics are
random, in comparing prints of two individuals you may chance to find a
close agreement as to a particular point, but the whole weight of scientific
testimony shows that even this is rare”.

The same Judge, Chapman J, reaffirmed this several years later during R v
Gunn, where he again expounded on the technique and value of fingerprint
identification and the guilty verdict was seen as a ‘vindication of the
fingerprint system’.

R V Carter
– there was a question as to ‘admissibility’ of the fingerprint evidence.
(19/12/05,
Fingerprint Experts can base opinion of identity on the ‘quality and quantity
CA155/05)
of information in the images’. The court also reiterated a finding in R v

Calder that stated that there needed to be a ‘minimum threshold of
reliability’ to be admissible (the reference being to peer review). The
essential comments here are that with regards to fingerprint evidence:
“Ordinary principals of expert evidence apply – experts must give reasons
for their conclusions”.

The courts stated that new methodologies had developed since R v Buisson,
a four-step process involving, analysis, comparison, evaluation and
verification. Evidence linking a fingerprint to a particular person is expert
evidence, and the expert must identify the steps undertaken in the process of
analysis and the major factors that influenced the expert to reach the opinion
expressed. In this instance whilst the expert explained the methodology
used, ACE-V, and the need for individual identification by an expert, he
failed to explain the major factors (other than reliance on peer review) that
led him to the view that the fingerprint could be identified as Mr. Carter’s.
(There was an absence of ‘reasons’ to justify the opinions reached.)

New Zealand Police FPO Training Programme Intermediate 2 Law 2 page 15
December 2015

Relevant Case Laws – International - Daubert

Introduction to
The opinion governs the admissibility of scientific evidence in Federal
Daubert v
court in the US. It states that the Federal rules of evidence supersede the
Merrell Dow
‘general acceptance’ tests for admissibility which came out of Frye v
Pharmaceuticals.

United States.

Daubert Opinion  Daubert opinion states that:

a)  The judge must screen scientific evidence to ensure it is relevant
and reliable
b)  The focus is on principles and methodology, not on the
conclusions they generate.
c)  The court should include the following factors:
i)  Testing and validation
ii)  Peer review
iii) Rate of error
iv)  General acceptance

Testing Daubert
Well over 40 Daubert hearings have since tested this and all fingerprint

evidence has been accepted. The first of these Daubert hearings was in US
v Byron Mitchell. In this case the defendant claimed that there was no
scientific basis for the assertion of individuality in the matching of
fingerprints. The judge upheld the admissibility of the fingerprint evidence
and rejected the challenge by defense to exclude it. Most importantly, the
court took judicial notice of two factors:

Human friction ridges are unique and permanent throughout the area of
friction ridge skin including small ridge areas.

Human friction ridge skin arrangements are unique and permanent.

New Zealand Police FPO Training Programme Intermediate 2 Law 2   page 16
December 2015

Fingerprints
The science of fingerprints meets the standards set forth in Daubert:
Science and
Daubert
  Testing. The reliability of fingerprint analysis can and has been tested

over an extended period of time. There has never been an instance in
which two different individuals have been found to possess the same
fingerprint.
  Error Rates. There is much ongoing debate about this issue. There is
no error rate for the methodology of fingerprint analysis, however
there is practitioner error. There are erroneous identifications, but
those are not the fault of the science of fingerprints. “The analogy
most often given is, No science is more precise than mathematics,
however that does not prevent the practitioner of math from saying
that two plus two equals five. That is not the fault of mathematics, but
the fault of the mathematician. The same thought applies to the science
of fingerprints.” Gary W Jones; Courtroom testimony for the
fingerprint expert, 2nd Ed.
  Peer Review. Refers to published material on fingerprints which are
open to peer review by others in the scientific community.
  Acceptability in the Relevant Scientific Community. The reliability
of fingerprint analysis has been accepted in the scientific community
for over a hundred years.

New Zealand Police FPO Training Programme Intermediate 2 Law 2   page 17
December 2015

Errors in Fingerprints overseas – McKie and Madrid
Bombing

Background to
The case of the murder of 57 year old Marion Ross in Scotland. The main
McKie
suspect was David Asbury and a number of fingerprints were recovered

throughout the investigation that were identified to him, including on a
gift tag in the victim’s home and on a tin that contained 2000 pounds
which also had the victims prints on it. However there was another print
recovered from the door frame in the victim’s house which was identified
to a police officer Shirley McKie. McKie was adamant she had never set
foot in the house. Mckie was subsequently fired, arrested and charged
with perjury. A trial ensued and four fingerprint experts concurred that the
print did indeed belong to McKie. The trial became an issue in that, if
McKie was telling the truth then the fingerprint evidence in this case, in its
entirety, would be flawed. Two fingerprint experts from the U.S. were
asked to examine the prints and both concluded that the print did not
belong to McKie. Additionally, the Scottish parliament invited overseas
experts to examine the print and 171 experts stated the two prints did not
match. The fingerprint evidence was ultimately rejected and as such
Asbury’s conviction was also overturned.

McKie Inquiry
An inquiry into the case was begun in 2008. Included in its terms of
Findings
reference was the task of finding out what went wrong and making

recommendations to avoid these shortcomings in the future. The inquiry
report was published in 2011 and the findings included:
  The marks Y7 and QI2 Ross were both misidentified by the Scottish
Criminal Record Office fingerprint examiners due to human error and
there is nothing sinister about the fact that these two errors occurred in
the same case.
  The misidentifications of Y7 and QI2 Ross expose weaknesses in the
methodology of fingerprint comparison and in particular where it
involves complex marks.
  Fingerprint examiners are presently ill-equipped to reason their
conclusions as they are accustomed to regarding their conclusions as a
matter of certainty and seldom challenged.
  There is no reason to suggest that fingerprint comparison in general is
an inherently unreliable form of evidence but practitioners and fact-
finders alike are required to give due consideration to the limits of the
discipline
New Zealand Police FPO Training Programme Intermediate 2 Law 2   page 18
December 2015

There were 86 recommendations that came out of the inquiry. Other work
from the fingerprint officers was checked for accuracy with no other
mistakes found.

Background to
Train bombing in Madrid, Spain. Interpol requested the analysis of latent
Madrid
prints from the scene. The case was assigned to a latent print supervisor
Bombing
and the Spanish police sent through electronic images. Eight images of

low resolution were submitted, with no scale. An AFIS search occurred
with a negative result. Latent prints asked for higher resolution images
with a scale. Interpol submitted more emails with the prints and 5 suspect
sets of tenprints. The latents were compared to the knowns but no ID
could be made as the tenprints were of poor resolution. One of the latent
images was searched in AFIS on 7 points; the misidentified candidate was
#4 on the list. The comparison was done using the on-screen images
against the supplied latent image. The job went to verification and the
verifier requested an original ten print set and the images was
subsequently verified using the high resolution digital copy and the
original ten prints. The unit chief did not make a thorough examination
prior to releasing the ID.

Madrid
Findings included:
Bombing
Findings –
  If the FBI had insisted on more information (e.g., an image with scale
Human Failure
for proper enlarging and an overall shot for orientation and proper

finger determination), this error may have been avoided. (Object
photographs that were available to the committee established that the
candidate's finger determination was not probable.) This comment was
not meant to mitigate the error. The error was a "human" failure and
not a methodology or technology failure.  The prescribed methodology
(Analysis, Comparison, and Evaluation–Verification or ACE-V) used
for this examination was appropriate. It was the examiners' application
of this methodology that failed.

New Zealand Police FPO Training Programme Intermediate 2 Law 2   page 19
December 2015

Madrid
  The apparent mind-set of the initial examiner after reviewing the
Bombing
results of the IAFIS search was that a match did exist; therefore, it
Findings –
Mindset
would be reasonable to assume that the other characteristics must

match as well. In the absence of a detailed analysis of the print, it can
be a short distance from finding only seven characteristics sufficient
for plotting, prior to the automated search, to the position of 12 or 13
matching characteristics once the mind-set of identification has
become dominant. This would not be an intentional misinterpretation
of the data, but it would be an incorrect interpretation nevertheless.
  Once the mind-set occurred with the initial examiner, the subsequent
examinations were tainted. Latent print examiners routinely conduct
verifications in which they know the previous examiners' results
without influencing their conclusions. However, because of:
   the inherent pressure of such a high-profile case
   the power of an IAFIS match in conjunction with the similarities
in the candidate's print, and
  the knowledge of the previous examiners' conclusions (especially
since the initial examiner was a highly respected supervisor with
many years of experience)

… it was concluded that subsequent examinations were incomplete and
inaccurate. To disagree was not an expected response.

New Zealand Police FPO Training Programme Intermediate 2 Law 2   page 20
December 2015

NEW ZEALAND POLICE FINGERPRINT SECTION

STANDARD OPERATING PROCEDURE
LATENT FINGERPRINT EXAMINATION AND IDENTIFICATION
S.O.P #: 2
Procedure category: OPERATIONAL
Effective date: 01 - 01 - 2015
Review date:  2021
Process owner
PFO Hamilton
Fingerprint Management Group (Lead -
Moderators
Manager: National Fingerprint Service
Centre)

1.0
Purpose

To provide standards for examining latent fingerprints, and making and recording
identifications of latent fingerprints.

2.0
Scope

This procedure applies to Fingerprint Assistants, Assistant Fingerprint Officers, and
qualified Fingerprint Officers undertaking latent fingerprint examination and
identification.

3.0
Rules governing New Zealand Police Fingerprint Section’s Identification

Standards

A pre-determined minimum number of friction ridge characteristics / details / features
is NOT required to be present in two impressions in order to establish a positive
identification.
Friction ridge identification is established through the agreement of friction ridge
formations, in sequence, having sufficient uniqueness to individualize.

Nothing in this standard shall be seen to override the internal policies, procedures
and quality controls of individual jurisdictions.

4.0
Key Terms

Term
Definition
ACE-V
The methodology used in examining and identifying
fingerprints; where A = Analysis; C = Comparison; E =
Evaluation; V = Verification.
Complex examination
May include, but not exclusively, identifications made
predominantly on third-level detail, distortion, multiple
impressions.
Feature
The structure and flow of friction ridges formed during
biological development and to include characteristics, ridge
edge shape and pores. A temporary or permanent influence,
eg scars, crease, wart, etc, not being a component of the
friction ridge development.
Characteristic
Galton points, bifurcation, ridge ending, dot.

Levels of detail
1 - pattern (classification), ridge flow/path; 2 - characteristics,
ridge flow/path; 3 - supporting information, edgeoscopy,

New Zealand Police Fingerprint Section Standard Operating Procedure # 2
poreoscopy, creases, scars, incipient ridges, ridge flow/path.
Friction ridge impression
Fingerprint, palmprint, or footprint.

Fingerprint
In the context of this SOP, the term 'fingerprint' equates to
'friction ridge impression' as defined.
Latent fingerprint
Generic term referring to the 'unknown' prints to also include
patent and contaminant prints.
Verification
Independent undertaking of the ACE process to determine if
you reach the same conclusion as the identifier.
Exemplar
Recorded print from known source.

5.0
Roles / Responsibilities

Role
Responsibility
Fingerprint Assistant
Analysis of latent fingerprints;
Assistant Fingerprint Officer
comparison of latent fingerprints to

known fingerprints; and evaluation of

result. Identification of latent fingerprints.

Analysis of latent fingerprints;
Fingerprint Officer
comparison of latent fingerprints to
Senior Fingerprint Officer
known fingerprints; and evaluation of
Principal Fingerprint Officer
result. Identification of latent fingerprints.
Verification of fingerprint identifications.

6.0
Procedure

Procedure
Action
Responsibility

The examiner/identifier:

In comparing two friction ridge
FPO / SFO / PFO/
6.1
impressions, use the ACE-V
methodology.
Trainee
Examine the latent fingerprint to

determine the presence or lack of
FPO / SFO /
features that may permit
PFO/Trainee
6.2 ANALYSIS
comparison; the quantity and
quality thereof; and the presence
or lack of factors that may render
a comparison complex.
Make a comparative assessment

of the configurative, sequential,
FPO / SFO /
and spatial relationships of
PFO/Trainee
6.3 COMPARISON   identifying features between the
two fingerprints.

Initiate the Comparison process

by referencing the features within
6.4
FPO / SFO /
the latent print and searching for
PFO/Trainee
them in the exemplar print.
Assess the level of agreement of
identifying features between the
6.5
FPO / SFO /
two fingerprints to establish
EVALUATION
PFO/Trainee
whether (a) there is agreement,
and (b) if the level of agreement

New Zealand Police Fingerprint Section Standard Operating Procedure # 2
constitutes a sufficient basis on
which to base an opinion of
identity.
Ensure you have located a
number of corresponding
identifying features between the
latent and exemplar prints which,
in your opinion, could not have
FPO / SFO /
6.6
originated from more than one
PFO/Trainee
source. That is, the configuration
of features is specific and unique
to the individual producing the
print.
Reach a conclusion as a result of
the ACE process, which may be
one of the following:
- Identification - the latent
fingerprint and the exemplar have
originated from the same source.
- Exclusion - the latent fingerprint
and the exemplar have NOT
6.7
FPO / SFO /
originated from the same source.

PFO/Trainee
- Inconclusive - there is insufficient
recorded detail in either fingerprint
(latent or exemplar) to come to
either of the above conclusions.
- Unsuitable – the quality or the
clarity of information contained
within the print is so low as to
render the print valueless.
Two qualified fingerprint officers
undertake the ACE process
independently to reach an
evaluation/conclusion.  The
verifiers must follow the same
process as above to determine
6.8
whether they reach the same
FPO / SFO / PFO
VERIFICATION
conclusion as the identifier. If they
reach a different conclusion, refer
to SOP # 4.
SOP # 24 guides further on the
verification process.

Once the verification process has
been completed, that is, two other
qualified experts have reached the
same conclusion as the identifier,
then an identification has been
6.9
established and the notification of
FPO / SFO / PFO
identification can be released.
(Note: This notification must NOT
be released before the verification
process is completed.)

Having completed the ACE
6.10
process and formulated a
FPO / SFO /
DOCUMENTING
hypothesis of identity, produce an
PFO/Trainee
IDENTIFICATIONS
image of the latent fingerprint (and
corresponding known exemplar),

New Zealand Police Fingerprint Section Standard Operating Procedure # 2
and mark on them corresponding
features until you have reached
the opinion of identification. These
form your working notes.
Use the latent fingerprint lift as the
reference for marking the
FPO / SFO /
6.11
identifying detail, unless a
PFO/Trainee
photograph is the method you
used to preserve the fingerprint.
Work from the latent fingerprint to
the known fingerprint.
In rare occasions where the
FPO / SFO /
6.12
quality of the latent fingerprint
PFO/Trainee
exceeds that of the known
fingerprint, this could occur
interchangeably.
Ensure you mark the correct type
and location of identifying
features.
Where a feature appears to have
been recorded differently between
two fingerprints (eg ridge ending
FPO / SFO /
6.13
on one, bifurcation on another),
PFO/Trainee
use all available information,
including other sets of known
fingerprints, to form an opinion as
to which is correct, and
appropriately mark both features.
Ensure identification
FPO / SFO /
6.14
characteristics are marked in the
PFO/Trainee
correct ridge sequence.
Endorse the image of the latent
fingerprint with the identified AFIS
FPO / SFO /
6.15
number, lift or image number,
PFO/Trainee
finger identified, date and
identifier's initials.
Complete an identification file
consisting of:
- marked images
- SOC documentation
- SOCO notes, or photographs
FPO / SFO /
6.16
- identified person's NIA Dossier
PFO/Trainee
Summary sheet
- identification cover sheet
- other relevant notes or
documents
Follow SOP # 24 for verification
FPO / SFO /
6.17
procedures.
PFO/Trainee

The verifiers:

Complete an independent
comparison and evaluation
process to determine if you reach
6.18
the same conclusion, or not, as
FPO / SFO / PFO
the identifier.
Sign the documentation, and initial
and date the image to show you

New Zealand Police Fingerprint Section Standard Operating Procedure # 2
have undertaken a verification
process.
Do not sign an identification
unless you would be prepared to
6.19
give the evidence of identity
FPO / SFO / PFO
yourself, should you be required
to do so.
If there is a disagreement about
sufficiency or identity, you may
6.20
FPO / SFO / PFO
apply the Independent Evaluation
Review SOP#4.
If an identification has been made
on Level 3 detail alone, the PFO
6.21
FPO / SFO / PFO
should refer it to the FMG for
consultation.

The identifier:

If the identification is of a Child or
Young Person (18 or under), you
must ascertain that the set of
known fingerprints used to make
FPO / SFO /
6.22
the identification is lawfully held.
PFO/Trainee/M:NFPSC
If in doubt or it is unclear, these
should be referred to your PFO,
who will seek guidance.

6.0
History of Change

SOP /
Description of SOP / Revision
Date / Staff QID
Revision No.

19/02/2015 - FMG
2
Clarified verification process and
25/9/2018 – TVM910
added additional step to 5.27. Added
SOP # 2 as reference.
3
Aligned with new SOP # 24
2/8/2019
4
Updated for SOP#4 name change
27/8/2020 - M:NFPSC

7.0
Attachments
nil

8.0
References
New Zealand Police Fingerprint Section Identification Standard: No scientific basis
exists for requiring that a pre-determined minimum number of friction ridge
characteristics / details / features must be present in two impressions in order to
establish a positive identification.
SOP # 4 Independent Evaluation Review
SOP # 24 Verification
Annexure

NEW ZEALAND POLICE FINGERPRINT SECTION

STANDARD OPERATING PROCEDURE
INDEPENDENT EVALUATION REVIEW: FINGERPRINT IDENTIFICATION
S.O.P #: 4
Procedure category: Quality Management
Effective date: 01 - 01 - 2015
Review date:  2021
Process owner
PFO Christchurch and PFO Hamilton.
Fingerprint Management Group (Lead -
Moderators
Manager: National Fingerprint  Service
Centre)

1.0
Purpose

To provide a standard procedure to be followed when the verification of a 'fingerprint
identification' cannot be confirmed between the staff conducting verification (technical
review).

2.0
Scope

This procedure applies to all operational fingerprint staff who conduct the analysis,
comparison, evaluation and verification of crime scene fingerprint evidence to known
exemplars of ink and LiveScan impressions.

3.0
Key Terms

Term
Definition
Identifier
The person who makes the identification.
Verification
The process of verifying the identification.
PFO - Principal
Officer in Charge, Crime Print Section - The Principal or
Fingerprint Officer
Acting Principal Fingerprint Officer.

4.0
Roles / Responsibilities

Role
Responsibility
Senior / Fingerprint
Informing the PFO that a fingerprint identification conflict
Officer
exists and submitting a referral to the Manager: National
Principal Fingerprint
Fingerprint Service Centre.
Officer

Manager: National
Forwarding identifications referred for independent review
Fingerprint Service
to the PFO of another Crime Print Section. Ensuring that
Centre
the site to which jobs are referred is rotated.

Manager: National Fingerprint Service Centre: Making
any enquiry, and/or taking any advice or action necessary
to satisfy himself/herself of the correct course of action to
be taken if he/she is not a qualified Fingerprint Officer
and is referred an identification as a result of the
Resolution Policy protocols following a review, or
receives a report or appeal from any member concerned
about the outcome of any Resolution Policy process.

Manager: National Fingerprint Service Centre: provides a
final decision.

New Zealand Police Fingerprint Section Standard Operating Procedure # 4

5.0
Procedure

Prerequisites

These procedures are written on the basis that national procedures within the
individual sites are adhered to. Refer to the Identification Process SOP.

Review

If at any point during the verification process there is disagreement as to the
sufficiency or validity of the identification, then the file in its entirety is to be forwarded
to the PFO.
There are two defined and separate areas for review as given below.

Scenarios

Scenario 1: Both verifiers agree with the

correctness of identification, that is, the identified

person may have made the latent impression in

question, but one verifier contends that there is

insufficient detail in the latent fingerprint to allow
any opinion of identity to be formed, and that
he/she would not personally confirm the
identification or give evidence of identity.

Scenarios 2 and 3: One verifier disagrees with

the correctness of the identification, contending

that the identified person is not the source of the
latent impression in question.

Review scenarios and resolution procedure

Procedure
Action
Responsibility

Scenario 1:

If either verifier disagrees that there is sufficient

detail present to confirm an identification, that

verifier should mark and include a copy of a

crimcon endorsed 'insufficient detail'.

Procedure
FPO / SFO / PFO
The verifier is to forward the identification to the
PFO who will then take one of the following
courses of action.

5.1
•  If the PFO, agrees with the sufficiency of
detail, the PFO signs and endorses the
paperwork accordingly including 'PFO' /
'acting PFO'. The PFO then refers the
identification to the Manager: National
Fingerprint Service Centre for delegation for
additional verification.
•  If the PFO, agrees with the sufficiency of
detail, AND one other has also agreed, the
PFO signs and endorses the paperwork
accordingly including 'PFO' / 'Acting PFO',

New Zealand Police Fingerprint Section Standard Operating Procedure # 4
and then releases the identification in
accordance with policy.
•  If two verifiers disagree with the sufficiency
of detail, they ensure the identification is
disallowed.

Scenario 2: Correctness of Identity

If either verifier does not reach the same

evaluation as the identifier.

Procedure

The verifier (or identifier) is to refer the
FPO / SFO / PFO
identification immediately to the PFO, unless the
verifier is the PFO, then Step 5.3 applies). The
verifier is to make the notation 'no match' on an
individually marked copy of a crimcon.
5.2

•  If the PFO agrees with the identification, they
refer the identification to another site.
•  if the PFO disagrees with the identification,
they ensure the identification is disallowed.
The identifier retains a right of appeal and
the PFO refers the matter to the Manager:
National Fingerprint Service Centre

Scenario 3:

If the verifier is the PFO and disagrees with the

identification.

FPO / SFO / PFO
5.3
Procedure
The PFO is to refer the identification to the
Manager: National Fingerprint Service Centre for
actioning under this procedure.

Referral for independent review

Identifications for referral to other sites are to be

directed from the Officer in Charge (PFO) of the

site where the difference of opinion has arisen.
FPO / SFO / PFO

The PFO of the site where the query has arisen
forwards the relevant job, complete with
5.4
paperwork, to the Manager: National Fingerprint
Service Centre, PNHQ.

The PFO includes a report to the Manager:
National Fingerprint Service Centre briefly listing
the circumstances of the difference of opinion.
The Manager: National Fingerprint Service

Centre forwards this file to another PFO for

review.
Manager: National
5.5

Forensic Services
The Manager: National Fingerprint Service
Centre rotates the site to which he/she sends

New Zealand Police Fingerprint Section Standard Operating Procedure # 4
files of this nature.
The PFO or Acting PFO of the reviewing site is

responsible for the identification review.
FPO / SFO / PFO

Under no circumstances are identifications for
review to be sent or received by persons other
5.6
than the PFO or Acting PFO.

Any person erroneously receiving such an
identification for review must report the matter
immediately to the PFO of his/her Section.

Duties of Principal Fingerprint Officer or Senior Fingerprint Officer Conducting
the Independent Review

Where the identification has been referred as a question of sufficiency of detail:

The appointed reviewer may not support the

original evaluation of identification. In this case
SFO / PFO
5.7
the identification is not verified and therefore not
to be allowed.

The reviewer may confirm the identification and
5.8
SFO / PFO
signs as second verifier.
The reviewer reports his/her findings to the

5.9
Manager: National Fingerprint Service Centre for
SFO / PFO
return to the originating Fingerprint Section.
Following the review, and where the identification
has been referred as a question of correct

identity:

•  If the reviewer is in agreement with the

referring PFO, the Manager: National

Fingerprint Service Centre returns the file to
Manager: National
Fingerprint Service
the referring site for appropriate action.
Centre

•  If the reviewer is in disagreement with the
5.10
referring PFO, the Manager: National
Fingerprint Service Centre takes such action
as he/she deems necessary in the
circumstances including seeking appropriate
guidance / advice.

•  The Manager: National Fingerprint Service
Centre must be advised where court requests
for jobs actioned under this Standard
Operating Procedure are received.

Appeal

New Zealand Police Fingerprint Section Standard Operating Procedure # 4
Any identifier/verifier having concerns about the

outcome of the review process has the right to

appeal or report such concerns to the Manager:
FPO / SFO / PFO
5.11
National Fingerprint Service Centre, who must
enquire into such concerns and take such action
as is appropriate to the circumstances.

6.0
History of Change

SOP / Revision No.
Description of SOP / Revision
Date / Staff QID

19/02/2015 - FMG
2
Updated to reflect SOP # 24
2/8/2019 –
M:NFPSC
3
SOP name change. Flow Chart
21/7/20 – FMG
updated and hyperlink to Flow
Chart restored.

7.0
Attachments
Independent Evaluation Review Flow Chart  <click>

8.0
References
Standard Operation Policy > Competency Standard > Identification Errors, Mistakes
and Discrepancies

Code of Conduct

Independent Evaluation Review Flow Chart  <click>

SOP # 24 Verification

SOP # 2 – Latent Fingerprint Examination

SOP # 23 Proficiency in the workplace – internal auditing

NEW ZEALAND POLICE FINGERPRINT SECTION

STANDARD OPERATING PROCEDURE
VERIFICATION
S.O.P #: 24
Procedure category: OPERATIONAL
Effective date: 15 - 07 - 2019
Review date:  2021
Process owner
Manager: National Fingerprint Service
Centre

Moderators
Fingerprint Management Group


1.0
Purpose

To provide the standard procedure for the process of verifying identifications of
prints from scenes of crime, exhibits or as a result of any other work.


2.0
Scope

This procedure applies to all qualified Fingerprint Officers.


3.0
Key Terms

Term
Definition
Verification
Independent undertaking of the ACE process to determine if
you reach the same conclusion as the identifier.
Qualified Fingerprint Officers
Fingerprint Officers / Senior Fingerprint Officers / Principal
Fingerprint Officers
Prints
Includes all palms, fingers, phalanges and feet either taken
under Section 32 of the Police Act or for elimination
purposes or volunteered or taken from deceased.
Single impression
Cases where only one print has been identified to a person.
identification
Blind Verification
A completely independent undertaking of the ACE process
by a second competent examiner who does not have
information about the first examiners conclusions. Complex
identification, the process will be semi-blind.


4.0
Roles / Responsibilities

Role
Responsibility
Fingerprint Officer (FPO)
Ensuring the process outlined in this SOP
Senior Fingerprint Officer (SFO)
is adhered to.
Principal Fingerprint Officer (PFO) ,

including the Manager: National Fingerprint

Service Centre

PFO/SFO/FPO’s
Maintaining proficiency in verification and
completing
the
verification
training
pathway.
PFO
One of the verifiers and final ‘gatekeeper’
for  all  identifications  wherever  possible.
PFO  may  delegate  other  staff  into  this
role.


5.0
Procedure

Procedure    Action
Responsibility
FPTSO
A  print  contained on  a  lift  or  image  taken  from  a  crime  AFO
scene  or  exhibit  is  evaluated  as  ‘identified’  to  a  set  of  FPO
5.1
prints  held  on  the  database,  or  otherwise  taken  under  SFO
controlled conditions.
PFO


All ‘identified’ prints must be subjected to the
FPO
5.2
verification procedures as directed under SOP #2 Latent
SFO
Fingerprint Examination
PFO

The purpose of the verification process is to undertake an  FPO
SFO
5.3
independent  ACE  process  to  determine  if  the  same  PFO
evaluation as the identifier can be reached.


There are two routes that an ‘identified’ print may follow  FPO
SFO
5.4
through the verification process and those routes are
PFO
defined as standard or complex identifications.

Standard identifications are those with high levels of
FPO
quality and quantity comparison features in both the
SFO
PFO
known and unknown prints.

Complex identification prints may include, but are not
5.5
exclusively limited to:
•  Poor quality print
•  Low quantity of features
•  Movement or distortion
•  Overlaid or multiple impressions
•  Poor contrast

•  Poor photographic focus
•  Single impression identifications
•  All scenes we have attended

These may apply to the unknown or known prints.

Identifications made on 3rd level detail alone are also to
follow SOP # 2

The determination of which verification process is
FPO
applicable to an identification is made by the ‘identifier’.   SFO
PFO

This does not, as per standard practice, preclude a
verifier from using unmarked copies of the prints to form
their own evaluation for any case they are to verify.

If a verifier in the simple pathway determines the
identification should undertake the complex pathway,
5.6
the verifier should seek guidance from the PFO.
If a verifier in the complex pathway determines the
identification should undertake the simple pathway, the
verifier shall take no action and leave the identification
in the complex pathway.

If the file contains a mix of complex and simple pathway
verifications, it must go through the complex verification
pathway, however, only the complex images need to
follow the complex process.

Standard identifications:

FPTSO
AFO
5.7
The marked copies of the working notes, crimcons (or
FPO
other) or ABIS screens, are forwarded to the first verifier  SFO
for them to follow the process as defined in SOP # 2.
PFO

If the first verifier confirms the evaluation of the
FPO
SFO
5.8
identifier then the file is to be forwarded to the second
PFO
verifier to follow the same process.

If  the  outcome  of  the  verification  process  confirms  the  FPO
SFO
5.9
original  evaluation  then  an  identification  has  been  PFO
established.


FPO
5.10
The working notes, crimcons, ABIS print outs or other,
SFO
are to be signed and dated by both verifiers to confirm
PFO

they are verifying the identification, then SOP # 2
applies.


Complex identifications:
FPO

SFO
PFO
The original identification and all working notes related

to that, and the main file is retained by the identifying
5.11
officer.
All other contents of the file that are relevant to the
identification, are to be forwarded for verification,
including unmarked copies of the known and unknown
prints, and are to be provided to both verifiers
simultaneously.

Each verifier will independently mark-up crimcons (or
FPO
other working notes), following the process as defined in  SFO
5.12
PFO
SOP # 2, in order to demonstrate the evaluation that

they reach. A semi-blind verification process is to be
undertaken.

Each verifiers will reach a conclusion as defined in SOP #  FPO
SFO
5.13
2  and  each  pass  their  working  notes,  containing  their  PFO
evaluations, back to the identifier on completion.

The  identifier  will  review  both  outcomes  of  the  FPO
SFO
5.14
verification  process  and  if  both  ‘confirm’  the  original  PFO
evaluation then an identification has been established.


The  identifier  will  collate  the  file  with  the  two  FPO
independently  semi-blind  verifications  included  and  SFO
PFO
5.15
check  for  data  accuracy  and  ID  memo  accuracy.  The
identifier  may  record  in  FIMS  the  QID’s  of  the  two
verifiers at that stage.

All  independently  marked  crimcons,  ABIS  print  outs  or  FPO
SFO
5.16
other working  notes,  are to  be  attached  to  the file  and  PFO
notification of the identification may be released, as per
SOP # 2

If the outcome of the verification process from either of  FPO
the  verifiers  under  either  the  standard  or  complex  SFO
PFO
5.17
processes does not confirm the original evaluation then
the  procedures  detailed  in  SOP  #  4,  Conflict  Resolution
applies.

6.0
History of Change

SOP /
Description of SOP / Revision
Date / Staff QID
Revision
No.


02/07/19 –
MHK981
2

16/7/2019 - FMG
3
To incorporate feedback
26/7/19 - FMG
4
To add clarification
2/8/19 – M:NFPSC
5
To incorporate FPTSO role and reflect name  19/8/20 -
change to SOP#4
M:NFPSC


7.0
Attachments


8.0
References
SOP # 2 – Latent Fingerprint Examination and Identification.
SOP # 4 – Independent Evaluation Review

Fingerprint Officer Training Programme

Intermediate 1 Oral Questions:
Identification 2

NOTE: The following sample questions serve as a guide for you only; they do not have to be asked
exactly as they are written but serves as an idea as to the type of questions that could be asked from
this module. If the trainee answers to the standard you consider appropriate for their level and
demonstrated a good understanding of the module content that is all that is required. Remember even
though these oral questions serve as a ‘gateway’ to a Knowledge test the process can also serve as
learning exercise for them as they respond to questions that could be asked in moot or real court.
Therefore it is important to provide feedback on how well they responded to / dealt with being asked
questions on certain subjects. Consider how articulate, accurate and convincing they were in their
responses.
List four factors that could result in a fingerprint lift showing distortion. See Module, Topic 1
Describe the concept of ‘tolerance’ with reference to observable differences between a latent print and
a fingerprint sample. See Module, Topic 1
When considering substrate distortion, describe three types of substrate that may influence the
appearance of the latent print. Describe the features that are likely to be observed in the latent print for
each type of substrate. See Module, Topic 1
With reference to matrix distortion, what are some of the features that may be observed in wet prints?
See Module, Topic 1
With reference to matrix distortion, what are some of the features that may be observed with
fingerprints made in blood or paint? See Module, Topic 1
When considering development media, what are the characteristics or features associated with each
of the four development media (powder, ninhydrin, iodine, and cyanoacrylate)? See Module, Topic 1
Explain the difference between deposition pressure and pressure distortion. See Module, Topic 1
List six observable ‘red flag’ indicators of distortion in a latent fingerprint. See Module, Topic 1
Describe the concept of bias. See Module, Topic 2
Describe cognitive bias and confirmation bias. See Module, Topic 2
Describe how you can self-manage to try and avoid bias. See Module, Topic 2
Fingerprint Officer Training Oral Questions / Intermediate 1 / Identification 2 / v April 2016

Describe the difference between forgery and fabrication. See Module, Topic 3
Describe the three methods of fabrication, and include a description of what clues might be observed
in each case of the recovered fabricated latent. See Module, Topic 3
Describe two methods of forgery and include a description of what clues might be observed in each
case of the recovered forged latent. See Module, Topic 3

Fingerprint Officer Training Oral Questions / Intermediate 1 / Identification 2 / v April 2016

Document Outline

Forensic documents for release.pdf