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Category: Repositories
District Attorney’s Office, Denver, CO

People’s Response to Defense Motion to Dismiss for Pre-Indictment Delay (State of Colorado v. Steven Cumberbatch)

Prosecution’s response to the defense’s motion to dismiss the case due to a pre-indictment delay in a Colorado murder-sexual offense case that occurred in 1994. The response addresses the defense’s due process arguments regarding the statute of limitations and the unavailability of witnesses and alternate suspects. The response also noted the advances in forensic techniques that occurred since the date of the incident which enabled investigators to utilize the Combined DNA Index System (CODIS).
August 2022
District Attorney’s Office, Denver, CO

People’s Motion in Limine (State of Colorado v. Steven Cumberbatch)

Prosecution’s motion in limine in the trial of a Colorado murder-sexual offense that occurred in 1994. The prosecution sought to admit “sanitized” police encounters with the defendant that occurred in Denver during the timeframe prior to the murder to limit any unfairly prejudicial details or facts.
July 2022
Legal Document Repository

Maryland Criminal Procedure – Forensic Genetic Genealogical DNA Analysis and Search – Applicability for Deceased and Missing Individuals

A comprehensive statute governing the application of Forensic Genetic Genealogical DNA Analysis and Search (FGGS) enacted by the Maryland General Assembly and set forth in Title 17 of the Criminal Procedure Article of the Annotated Code of Maryland. The original statute was enacted and went into effect on October 1, 2021. An amendment (effective October 1, 2024) to the law states that its provisions do not apply to the use of FGGS to identify unidentified human remains.
October 2021
Investigative Stage - Case

State of Maryland v. Brandon Biagas – Case Documents

These case documents pertain to the 2017 Maryland homicide case, State of Maryland v. Brandon Biagas, and collectively outline the legal basis for obtaining biological samples from the suspect, the genealogical investigative methods used, and the formal allegations supporting the criminal charges. The materials include: (1) a search warrant authorizing the collection of biological samples from the suspect for forensic testing, including samples designated for Forensic Genetic Genealogy (FGG) analysis; (2) a memorandum outlining the family tree build out process conducted during the FGG investigation; and (3) an application for a statement of charges.
November 2020
Legal Document Repository

State of Washington v. Terrence Miller – Case Documents

These case documents pertain to the 1972 Washington murder-sexual offense case, State of Washington v. Terrence Miller, and collectively outline the evidentiary disputes central to the case, the parties’ competing positions on the admissibility and reliability of historical forensic evidence, and the investigative basis for the long-delayed charges. The materials include: (1) the prosecution’s response to multiple evidentiary issues raised by the defense; (2) the defense’s trial brief and motions in limine; (3) the defense’s motion to exclude evidence; and (4) the prosecution’s charging affidavit.
October 2020