Document Fraud REPORT submitted by Bill Freeman

SUMMARY OF CONCLUSION Accounting Microscopic False Notary Photoshopping Examinations Manipulated Duplicates of the Duplicated History Introductionby 4 Experts Signatures, Stamps Same Documents SignaturesThe observational findings from the examination exhibits show that Photos Signaturesthe William Freeman signature and initials on the purported originalPromissory Notes were made by an ink jet printer. FraudThe satellite ink droplets detected in the signature and initials issufficient evidence to conclude with a high degree of scientificcertainty that the Questioned Promissory Notes are not the originalNotes because the signature and initials were not made by a pen butby an inkjet printer.Additional observational evidence that the Questioned Notes are notthe original Notes is given herein.Attachments:Exhibit 1 is my relevant Curriculum Vitae and case information.Exhibit 3 is the ASTM Standard Guide for the Examination ofDocuments Produced with Liquid Ink Jet Technology.There are hundreds of microscope and scanner files that can bedelivered on a thumb drive but too many to be printed outeconomically. 3 101

The Document Examination Accounting Microscopic False Notary Photoshopping Examinations Manipulated Duplicates of the Duplicated History Introductionby 4 Experts Signatures, Stamps Same Documents SignaturesThe following questioned documents were examined at the offices of Photos SignaturesMorgan, Lewis & Bockius LLP, 101 Park Avenue, New York City,New York 10178-0060, on September 23, 2016. The examination Fraudcommenced shortly after 10 AM and was video recorded.No attorneys were in attendance.There were two set of Loan documents presented for examinationcorresponding to two different properties.The first Loan is for the property known as 39 Side Road, LittleCompton, RI (“Side Road Loan”). The second loan is for the propertyknown as 135 Randolph Avenue, Tiverton, RI (“Randolph AvenueLoan”).The Loan documents were visually inspected, scanned with an EpsonV370 Photo Scanner, and then photographed with digitalmicroscopes.The use of very high resolution photos allows ink and toner artifactsto be clearly seen. Adobe Photoshop 2015 was used to examine thescan photos and to measure the colors of the ink in the signature andinitialsThe 39 Side Road LoanThe 39 Side Road Loan was made in March 11, 2005 in the name ofWashington Mutual Bank, FA.The documents presented were 1) An Adjustable Rate Note (“Note”) (3/11/2005) 2) A Prepayment Fee Note Addendum (“PFNA”) 4 102

3) A Mortgage (“Mort”) Accounting Microscopic False Notary Photoshopping Examinations Manipulated Duplicates of the Duplicated History Introductionby 4 Experts Signatures, Stamps Same Documents Signatures 4) An Adjustable Rate Rider (“ARR”) 5) A Second Home Rider (“SHH”) Photos Signatures 6) Assignment of Mortgage: Receiver-Chase (3/16/2013) FraudThe examination is principally concerned with the Note. The otherdocuments are used for comparison purposes.Anomalies: (1) No indentations were discerned in the signatures or initials on the documents either tactilely or under oblique lighting. (2) Exhibit A that is attached to the Side Road Mortgage consists of two pages containing the 39 Side Street property description. Visual inspection of the two pages and comparison with the other pages in the mortgage show that the two pages have been recently added to the questioned document. The pages are bright white paper and much newer appearing than the rest of the Mortgage. There are 8 staple holes. 6 at the top left of the document and two to the right of top center of the document. Only the two staple holes to the right center of the document match the rest of the pages in the mortgage. Thus the 39 Side Loan document is an “altered document” that was recently assembled. (3) The signatures on the Questioned Note and the PFNA should compare closely if they were made with the same instrument. They do not match closely in either texture or color. While the signature lines match in color, the texture and the difference in color between the two signatures can be seen with the naked eye. Neither instrument was recorded. 5 103

(4) The PFNA signature when magnified 50 times shows that the Accounting Microscopic False Notary Photoshopping Examinations Manipulated Duplicates of the Duplicated History Introductionby 4 Experts Signatures, Stamps Same Documents Signatures ink texture is mottled with various shades of magenta, cyan and yellow. The ink is not as supersaturated as is the ink in Photos Signatures the Note signature. This and the other satellite droplet artifacts are indicative of an ink jet printer. Fraud(5) The Note signature appears rich black at low magnification. The black portions of the signature are supersaturated ink. The blue black ink has coalesced into connected pools. At higher magnification, there are small pockets blue and magenta ink in the signature. When magnified sufficiently the ink texture of the signature shows what appear to be brush strokes with various shades of magenta, cyan.(6) The total ink volume in the PFNA is 217% compared with 300% in the Note signature. The maximum amount of ink is 400% corresponding to 100% in each of the four color channels.(7) The large ink tails attached to the signature are caused by the wicking of the ink along paper fibers before the ink dries.(8) Also present are small inkjet satellite droplets and tails associated with the ejection of the ink from the nozzles onto the paper.(9) Exhibit 2.1 is a high resolution scan of the initials on page 1 of the Questioned Side Road Adjustable Rate Note (“Note”). The initials are scanned at 4800 pixels per inch in RGB color mode. The stroke width is about 0.4 millimeters. The magnification is 55 times on the page. 6 104

(10) Exhibit 2.1 shows part of the Freeman initials and uses Accounting Microscopic False Notary Photoshopping Examinations Manipulated Duplicates of the Duplicated History Introductionby 4 Experts Signatures, Stamps Same Documents Signatures arrows to identify tiny droplets of ink which are defined as “satellite droplets”. Photos Signatures Satellite ink droplets are typical of an ink jet printer. An inkjet printer typically applies ink to paper by ejecting the ink Fraud through a tiny nozzle onto the paper. The ink droplets typically range in size from approximately 10 to 50 microns in diameter. The tiny satellite droplets cannot be seen except at very high resolutions and usually go unnoticed.(11) Exhibit 2.2 is microscope photo showing the satellite ink droplets about the signature. The entire signature cannot be seen because of the small focal area of the microscope at high magnification.(12) The microscope confirms the scanner evidence of satellite ink droplets.(13) Adobe Photoshop 2015 was used to examine the scanner and microscope photos and to measure the colors of the ink in the signature and initials.(14) A comparison between the signature on the Mort and the signature on the questioned Note shows that there is much more ink debris in the background of the signature on the Mort than the signature on the Note. This is consistent with the Note signature being created later.(15) There are no noticeable ink tails on the signature on the Mort unlike the signature on the Note.(16) The “R” in the signature on the Mortgage shows a down stroke followed by a smooth up stroke on the vertical part of 7 105

the “R” that is missing from the “R” in the signature on the Accounting Microscopic False Notary Photoshopping Examinations Manipulated Duplicates of the Duplicated History Introductionby 4 Experts Signatures, Stamps Same Documents Signatures Note. (17) There are multiple parallel striations in the signature on Photos Signatures the mortgage not present in the signature on the Note. (18) The inks colors in the signatures on the Note and the Fraud Mortgage are a reasonable match. However, the differences in signature form and texture are significant. The Note and the Mort were presumably created at the same time in 2005 with the same pen yet they do not agree in the foregoing observations. (19) There are many more examples in the high resolution scan and microscope phots of the tell-tale satellite ink droplets. (20) In light of the foregoing evidentiary observations, it is highly likely that the signatures on the Side Road Note and the PFNA were made by an ink jet printer.The 135 Randolph Avenue LoanThe 135 Randolph Avenue Loan, Tiverton, RI 02878 was made July12, 2005 in the name of Washington Mutual Bank, FA.The documents presented for WMBFA Loan #069434295 were 1. An Adjustable Rate Note (“Note”) (7/12/2005) 2. A Prepayment Fee Note Addendum (“PFNA”) 3. A Mortgage (“Mort”) 4. An Adjustable Rate Rider (“ARR”) 5. 1-4 Family Rider (“1-4FR”) 8 106

The examination is principally concerned with the Note. The other Accounting Microscopic False Notary Photoshopping Examinations Manipulated Duplicates of the Duplicated History Introductionby 4 Experts Signatures, Stamps Same Documents Signaturesdocuments are used for comparison purposes.Anomalies: Photos Signatures (1) There were no indentations discerned either tactilely or Fraud visually under oblique lighting for the signatures or the Riley stamp. The presence of indentations is not probative of the authenticity of a document because they can be added at any time. (2) The signature page of the Questioned Note looks newer compared to the other pages. This can be discerned with the naked eye. (3) The blue ink signature of the witness on the Note matches exactly in color the blue ink signature of Freeman. (4) Exhibit 2.3 is a high resolution microscope photo of the on page 1 of the Questioned Randolph Avenue Note. The ink color is measured in RGB color mode. The stroke width is about 0.4 millimeters. The magnification is about 55 times on the page. (5) Exhibit 2.3 shows part of the Freeman initials and uses arrows to identify tiny droplets of ink which are defined as “satellite droplets”. Satellite ink droplets are typical of an ink jet printer. An inkjet printer typically applies ink to paper by ejecting the ink through a tiny nozzle onto the paper. The ink droplets typically range in size from approximately 10 to 50 microns in diameter. The satellite droplets cannot be seen except at very high resolutions and usually go unnoticed. (6) The presence of satellite ink droplets that match the ink color of the signature or initials is probative of the use of a printer instead of a pen. If these droplets are present it is very strong 9 107

108Accounting Microscopic False Notary Photoshopping Examinations Manipulated Duplicates of the Duplicated History Introduction Fraud Photos Signatures by 4 Experts Signatures, Stamps Same Documents Signatures

EXHIBIT 1 Accounting Microscopic False Notary Photoshopping Examinations Manipulated Duplicates of the Duplicated History Introductionby 4 Experts Signatures, Stamps Same Documents Signatures James M. Kelley, Ph.D. Photos Signatures Computer Forensic Examinations Fraud 14390 Douglass Lane Saratoga, CA 95070 [email protected] (408) 402-1915Curriculum VitaeDr. James Kelley has more 30 years experience in military and commercial computersystems development. He has developed, manufactured and sold more than one hundredcomputer software, hardware and systems products.He is currently applying his computer skills to the detection of altered documents usingscanner, microscopes, sophisticated computer programs and printers. Non–destructivemethods are used.It is easy to fabricate a mortgage document that accurately recreates an original documentfrom archived digital images of the document. Mortgage loan origination files arescanned shortly after loan close and the resulting digital images are archived in an imagedatabase.1 If an accurate recreation of a promissory note is required, it can be recreatedfrom the archival digital images using graphics software and computer printers.An archival image database can be used to fabricate a complete set of loan documents.Many forensic document examiners (“FDE”) are not trained in the use of AdobePhotoshop, Illustrator, Acrobat, and other computer image processing packages. TheFDEs are “handwriting analysts” trained in comparing a questioned signature withreference signatures to identify the writer.2 This skill is useless where the source of thesignature is a digital copy made from the original document.FDEs frequently opine that if the ink is blue and looks like ballpoint pen ink that thedocument must be authentic. They are taught to distinguish ballpoint pen ink, fromroller ball, gel and fiber tip ink.3 What they do not acknowledge is that ballpoint ink canbe ordered from an ink manufacturer and applied by various other instruments such as anDamilac Machine, a plotter, a CNC machine or an inkjet printer.4 1 For example, ACS Image Solutions Inc. (“ACS”) had contracts with WashingtonMutual Inc (“WMI”) to scan mortgage documents in Juarez, Mexico until the end of2008. The scanned images were stored on FileNet per contract for access by WMI. ACSalso had contracts to destroy loan origination by shredding. 2 ASTM E2195-05. 3 ASTM standard E1422-05, Standard Guide for Test Methods for Forensic WritingInk Comparison, 2005. 109

Some FDEs mistakenly believe they can distinguish an inkjet printed signature from a Accounting Microscopic False Notary Photoshopping Examinations Manipulated Duplicates of the Duplicated History Introductionby 4 Experts Signatures, Stamps Same Documents Signaturesballpoint pen signature by the multicolored dots seen under a microscope. Ordinarily, aninkjet mixes the Cyan, Magenta, Yellow and Black inks on the paper. An intelligent Photos Signaturesforger will use premixed ink in cartridges to avoid creating the telltale dot patterncharacteristic of a forged signature.5 FraudMost loan origination documents are standard forms that were downloaded from a vendorand printed on a black ink laser printer. The forms can be easily recreated on anotherlaser printer. The new form can then be signed in blue ink by an inkjet, a Damilacmachine, or other instruments. The resulting documents will fool most people.Computer forgery has been identified in many foreclosure cases. The skill level varies.Some counterfeit documents are easily detected, others are nearly perfect. The skill levelof the technician and the client’s budget largely determines the number of tests that areperformed on a document.There is almost no risk in counterfeiting loan documents and the reward can be millionsof dollars per counterfeit.Dr. Kelley is an independent consultant. He is paid for his work, not for his opinion.Consulting opinions are by arrangement. A fee schedule is available upon request. Aretainer agreement must be signed.Relevant Experience:Dr. Kelley worked for the Speech Communication Research Laboratory assisting inresearch into speech compression and voice recognition while at the University ofCalifornia Santa Barbara.Dr. Kelley took courses in digital signal processing and passed the PhD exam in thatspecialty at the University of California, Santa Barbara. He has also used WaveletTransform processing to create a digital radio at Litton.Dr. Kelley uses computer graphics tools for the detection of anomalies in documents andsignatures that indicate that they are altered documents.Dr. Kelley has experience in the design of airborne radar and Electronic CountermeasuresSystems at the following companies: 4 Specify the color formula, viscosity and drying time. The ink manufacturer can dothe rest. 5 Spot color has been used for decades by the printing industry. 110

Raytheon Missile Systems Division Senior where he was Senior Engineer in charge of Accounting Microscopic False Notary Photoshopping Examinations Manipulated Duplicates of the Duplicated History Introductionby 4 Experts Signatures, Stamps Same Documents Signaturesthe computer program development for pulse doppler airborne phased array attack radar.The phased array system was successfully tested at Wright Patterson Air Force base. Photos SignaturesRaytheon Electronic Countermeasures Systems where he invented a digital computer Fraudcapable of collecting, sorting and processing high-density enemy radio emissions for theAdvanced Manned Strategic Aircraft, inter alia. Dr. Kelley worked directly for the chiefscientist of Raytheon.At Litton Systems, Dr. Kelley developed and tested a signal processing method thatincreased the target detection range of a wideband receiver by a factor of 4. This permitsearly detection of enemy aircraft and ground-based threats by fighter jets.Dr. Kelley also used image-processing hardware for the development of software to beused to identify shoulder-launched missiles.As an Engineering Fellow at Chips and Technologies, Dr. Kelley solved disk controllerdata separation problems and produced a line of PC disk controllers for high volumemanufacturing in Taiwan and Hong Kong.Dr. Kelley has developed and applied cryptographic methods and software for passwordprotection of computer programs and storage systems.Dr. Kelley designed, manufactured and sold a line of microprocessor in circuit emulatorsand language translators to electrical engineers and programmers for the development ofmicroprocessor based systems worldwide.Dr. Kelley has three U.S. patents and is currently active in the design of novel costeffective scalable ultra high-speed database and networking architectures.Dr. Kelley is familiar with state and federal court procedures. He has proffered testimonyand been deposed in connection with various document examinations. Computerdocument forensics is a recognized research area in academia, the Association ofComputing Machinery (“ACM”) and the IEEE.Dr. Kelley uses image-processing methods to test the authenticity of documents. Some ofthe images processing methods are mentioned in the “Scientific Examination ofQuestioned Documents” by Kelly and Lindblom (“SEQD”) and in the Forensic Standardsof the American Society of Testing Materials. The book has not been updated since 2006.Unfortunately, the ASTM forensic procedures have not kept pace with advances inscanner, computer, printer, graphics software, and compression technology. The cuttingedge in forgery research is now image processing. The Institute of Electrical andElectronic Engineers (“IEEE”) is one of the leaders in detection of image forgery. 111

For expert witnesses, it is essential that the expert report document all relevant Accounting Microscopic False Notary Photoshopping Examinations Manipulated Duplicates of the Duplicated History Introductionby 4 Experts Signatures, Stamps Same Documents Signaturesobservations and methods. The scientific method requires that all observations andmethods be reproducible by others. Unfortunately, this requirement is ignored in FDE Photos Signaturesexpert reports. FraudEducation:Stanford Executive InstitutePh.D. University of California, Santa Barbara, Electrical and Computer EngineeringM.S.E.E. University of California, Santa Barbara, Electrical EngineeringB.A. in Mathematics San Jose State UniversitySpecial:Chemistry through Organic and Physical ChemistryReactor Core design PhysicsDocument Examination Research:Visual, Ultraviolet and Infra-Red Microscope Analysis of Signatures from 100 pens.Printing electrical circuits on paper and other material using conductive ink.Coloring and Printing Signature and Initials on paper using inkjet printers.Printing Indorsement on paper with overprinting using inkjet printers.Microscopic analysis of misalignment of paper during overprinting.Identification of Laser printed forms using digital scanner and microscope.Use of Adobe Illustrator is placing and printing signatures on paper.Use of graphical techniques to identifying fabricated documents with Photoshop.Use of Adobe Illustrator to identify fabricated signatures and documentsIdentification of custom ink manufactures for inkjets.Investigation of plotters, CNC machines, 3-d printers and ink jets for simulating pens.Analysis of the various commercial machines for the pointing of signatures.Training:Image Processing, Litton Industries, San Jose, California 1994Wavelet Signal Processing Litton Industries, San Jose, California 1994Total Training for Photoshop 7, Deke McClelland, 2003Adobe Photoshop CS6 Official Training for Adobe Certified Associate Exam 2012Adobe Illustrator CS6 Video Training Course Chellius and Taylor 20121 Year training in Digital Signal Processing at University of California Santa Barbara4-years training in nuclear reactor physics at General Electric Nuclear Energy Division3-years training in digital Phased Array Radar and electronic countermeasures RaytheonMissile SystemReference Materials:Adobe Photoshop CC on Demand, Que Publishing July 2013, 602 pagesAdobe Illustrator CC on Demand, Que Publishing June 2013, 602 pagesPhotoshop CS All-In-One Desk Reference, Wiley Publishing 2004 805 pages 112

Societies: Accounting Microscopic False Notary Photoshopping Examinations Manipulated Duplicates of the Duplicated History IntroductionMember of the Association of Computing MachineryMember of the Institute of Electrical and Electronics Engineering (IEEE)Member of the Signal Processing SIG IEEEPartial List Court Cases: by 4 Experts Signatures, Stamps Same Documents SignaturesJonson, et al vs. Northwest Trustee Services, Inc., et al 12-cv-00552-RSLUS District Court, Western District of Washington atSeattleHollis and Linda Malin, et al. vs. JP Morgan Chase Bank, NA 3:11-cv-554US District Court, Eastern District of Tennessee at KnoxvilleJames B. McDonald v. Onewest Bank, FSB, et al. 2:10-cv-01952-RSLUS District Court, Western District of WashingtonJanet Reiner vs. Onewest Bank, FSB, et al. Superior Court of the 11-2-02029-8State of Washington in and for the County of ThurstonDeutsche Bank National Trust Company vs. Mitchell P. Kass 09-09002 (04) SJand Jacqueline D. Kass, Circuit Court of the Seventeenth JudicialCircuit in and for Broward County FloridaJP Morgan Chase Bank, N.A., vs. Christopher Ardern 12F000958Lake County Court of Common Pleas, OhioBank of America, NA vs. Marcia A. Wrick, et al. CV-12-775113Cuyahoga County Court of Common Pleas of Common Pleas, OhioHSBC Mortgage Services INC. vs. Joseph Iongi, et al., in the Case No. 130202716Circuit Court of the State of Oregon for the County of Multnomah.Peter J. and Joanne E. Workum vs. Washington Mutual Bank, 2:12-ap-01418-SSCDeutsche Bank National Trust Co., DLJ Mortgage Capital, et al. 2:12-bk-08554-SSCUS Bankruptcy Court for the District of ArizonaBank of America, et al., v. Cynthia Black, Circuit Court Case No. 49-2009-CA-009062 Photos Signaturesof the 9th Judicial Circuit, Osceola County, September 2013Bank of New York Mellon V. Ken Brown, et al., Case No. 1308458E2Fairwinds Credit Union V. Victor Monroy, Verbal Opinion, Seminole County, FL 9/2012Trustee Services of Carolina V. Kenneth Andresen, South Carolina, 3/2/2013 Fraud 113

Jorge and Esther Romero, verbal opinion, Florida 5/21/2013 Accounting Microscopic False Notary Photoshopping Examinations Manipulated Duplicates of the Duplicated History Introductionby 4 Experts Signatures, Stamps Same Documents SignaturesPressler & Lehman Brothers, Bank FSB Verbal 7/2013HSBC Mortgage Services INC. vs. Joseph Iongi, et al., case No. 130202716 in the CircuitCourt of the State of Oregon for the County of Multnomah. 7/2013Mark and Sheri Yeadaker v. Citi Mortgage, Inc., etc. al., California, 7/2013Nationstar Mortgage LLC vs. Maria Perdomo, et al. in the Circuit Court of the SixthJudicial district In and For Pinellas county, Florida, Case No. 20-CA-006266Bank of America V. Octavio Pina Florida Case #8:13-bk-12037-ES, 9/ 2013Donald Karleen v. Countrywide Home Loans, Hawaii, 9/2013Gary Alexander and Diane Alexander Vs. Capital One, N.A., et al. Case No. 13-2-27723-9 SEA, In the Superior Court of the State of Washington in and for the County of King.2014Bank of New York Mellon v. Diderick, Collier County, Case 12-003870-CA 9/ 2014Bausch, Superior Court of California, County of Orange, Case No. 30-2013-00651662-CU-OR-CJC, May 23, 20123.Margaret Sylvia Ordogne V. Bank of America, NA, et al, The Superior Court in andfor the County of El Dorado, Case #PC-20130276Rivera V. Deutsche Bank National Trust, Adv. No. 14-05108, Oakland, CA BankruptcyCourtIn re Nathan Topol, US Bankruptcy Court, Nevada, Ch. 7, Case No. Bk-N-10-51214for the Trustee's attorney Steven HarrisPatents & Publications:US PATENT 4,338,660 July 6, 1982 Photos Signatures Relational Break Signal Generating DeviceUS PATENT 7,957,384 B2 June 7, 2011 Multiple Virtual Local Area Network Databases in a Switch with a Relational Lookup Engine.US PATENT 8,335,780 B2 December 18, 2012 Scalable High Speed Relational Processor For databases and Networks. 114 Fraud

22.50 mm The ink is comprised primarily Accounting Microscopic False Notary Photoshopping Examinations Manipulated Duplicates of the Duplicated History Introduction of Cyan and Magenta.Ink Color: by 4 Experts Signatures, Stamps Same Documents SignaturesCyan=73% Satellite Color:Magenta=78% Cyan=23%Yellow=26% Magenta=23%Black=9% Yellow=1% Black=0% Satellite Ink Photos Signatures Droplets Fraud 94EXHIBIT 2.1 is a V370 High resolution Scan of the Initials on Page 1 of the 39 Side Road Note

Signature was made with an ink jet printer as can be seen from tiny satellite ink droplets. Pens do not spray tiny ink droplets.Exhibit 2.2 Satellite Droplets in the Freeman Signature on the 39 Side Road Note95Accounting Microscopic False Notary Photoshopping Examinations Manipulated Duplicates of the Duplicated History IntroductionFraud Photos Signatures by 4 Experts Signatures, Stamps Same Documents Signatures

Exhibit 2.3 Satellite Ink Droplets in the Randolph Note. inkjet Spray also occurs in the Initials and signature of Freeman in the 155 Randolph Note. As can be seen in the high resolution microscope photo.117Accounting Microscopic False Notary Photoshopping Examinations Manipulated Duplicates of the Duplicated History Introduction Fraud Photos Signatures by 4 Experts Signatures, Stamps Same Documents Signatures

Accounting Microscopic False Notary Photoshopping Examinations Manipulated Duplicates of the Duplicated History Introductionby 4 Experts Signatures, Stamps Same Documents Signatures Arrows point at the satellite ink Photos Signatures droplets scattered about the Freeman signature. Fraud There are many more examples in other microscope photos.EXHIBIT 2.4 Microscope Photo of the part of the Freeman Signature on the Randolph Note 118

Designation: E2389 − 05 Accounting Microscopic False Notary Photoshopping Examinations Manipulated Duplicates of the Duplicated History IntroductionStandard Guide for by 4 Experts Signatures, Stamps Same Documents SignaturesExamination of Documents Produced with Liquid Ink JetTechnology1This standard is issued under the fixed designation E2389; the number immediately following the designation indicates the year oforiginal adoption or, in the case of revision, the year of last revision. A number in parentheses indicates the year of last reapproval. Asuperscript epsilon (´) indicates an editorial change since the last revision or reapproval.1. Scope E2195 Terminology Relating to the Examination of Ques- tioned Documents 1.1 This guide provides procedures that should be used byforensic document examiners (Guide E444) for examinations E2331 Guide for Examination of Altered Documentsof documents produced with liquid inkjet technology and F221 Terminology Relating to Carbon Paper and Inkedrelated procedures. Ribbon Products and Images Made Therefrom 1.2 These procedures are applicable whether the examina- F909 Terminology Relating to Printerstion is of a questioned and known item(s) or of exclusively F1156 Terminology Relating to Product Counterfeit Protec-questioned item(s). tion Systems (Withdrawn 2001)3 1.3 These procedures include evaluation of the sufficiency F1457 Terminology Relating to Laser Printersof the material available for examination. F1857 Terminology Relating to Ink Jet Printers and Images 1.4 The particular methods employed in a given case will Made Therefromdepend upon the nature and sufficiency of the material avail-able for examination. 3. Terminology 1.5 This guide may not cover all aspects of unusual or 3.1 Definitions:uncommon examinations. 3.1.1 For definitions of terms in this guide, refer to Termi- 1.6 These methods are applicable to examinations involvingcopiers, printers, facsimile devices, and multifunction devices nologies E1732 and E2195.using ink jet technology. 3.1.2 coalescence, n—puddling or pooling of adjacent ink 1.7 This standard does not purport to address all of thesafety concerns, if any, associated with its use. It is the drops on the substrate before they can be dried or absorbedresponsibility of the user of this standard to establish appro-priate safety and health practices and determine the applica- resulting in nonuniformity of color density. F1857bility of regulatory limitations prior to use. 3.1.3 cockle, n—of paper, a defective, puckered condition of2. Referenced Documents a paper sheet as a result of non-uniform hygro-expansion 2.1 ASTM Standards:2 D1968 Terminology Relating to Paper and Paper Products which can be related to any non-uniformity in the sheet, (Withdrawn 2010)3 including mass distribution and drying stresses. D1968 E444 Guide for Scope of Work of Forensic Document 3.1.4 continuous spray, n—ink jet technology where drops Examiners are generated at a regular unbroken rate. Images are then E1732 Terminology Relating to Forensic Science generated by deflections of the ink droplets after they are charged so they are either intercepted by a catcher and not 1 This guide is under the jurisdiction of ASTM Committee E30 on Forensic permitted to impact the substrate or deflected to intercept theSciences and is the direct responsibility of Subcommittee E30.90 on Executive. substrate at specific locations. Current edition approved Dec. 1, 2005. Published January 2006. DOI: 10.1520/ 3.1.5 cracking, n—condition in which ink that has beenE2389-05. absorbed into a substrate causes the coating to shrink to a state 2 For referenced ASTM standards, visit the ASTM website, www.astm.org, orcontact ASTM Customer Service at [email protected]. For Annual Book of ASTM much smaller than the original coating dimension causing Photos SignaturesStandards volume information, refer to the standard’s Document Summary page onthe ASTM website. fractures in the image area. F1857 3 The last approved version of this historical standard is referenced on 3.1.6 crystallization, n—condition in which ink evaporateswww.astm.org. and forms crystals. F1857 3.1.7 drop on demand (DOD), n—ink jet technology where drops are generated as needed to create an image. 3.1.8 full-color copiers, n—of ink jet technology, copiers that can reproduce color originals containing gradations of color. They have a minimum of three colored inks (cyan, magenta and yellow).Copyright © ASTM International, 100 Barr Harbor Drive, PO Box C700, West Conshohocken, PA 19428-2959. United States FraudCopyright by ASTM Int'l (all rights reserved); 1 119

E2389 − 05 Accounting Microscopic False Notary Photoshopping Examinations Manipulated Duplicates of the Duplicated History Introduction3.1.9 image area, n—area on a page occupied by all the 3.2.3 circularity, n—ratio of a single ink dot height dividedprinted information. F1457 by its width with 1.0 being a perfect circle. F18573.1.10 image density, n—contrast between image and back- 3.2.4 feathering, n—ink spread over substrate causing fuzzyground as measured by densitometer. F221 edges, spidery lines and poor print quality. F18573.1.11 image, n—optical counterpart of an object produced 3.2.5 liquid ink jet device, n—device in which the ink supply is in fluid (for example, solvent or aqueous) form.by means of an image producing device. F2213.1.12 ink jet printer, n—nonimpact printer in which the 3.2.6 mottling, n—nonuniformity of image density whichcharacters are formed by projecting droplets of ink onto a follows patterns in the substrate or by non-uniform ink- by 4 Experts Signatures, Stamps Same Documents Signaturessubstrate. F909 substrate interaction. F18573.1.13 landscape mode, adj—printer output orientation in 3.2.7 satellite, n—extraneous or undesirable ink droplets.which printed lines run parallel to the direction of movement of (See also spatter, spray) F1857the paper. F1457 3.2.8 spatter, n—type of extraneous or undesirable ink droplet originating when a portion of an ink droplet strikes the3.1.14 maximum print position, n—rightmost point at which intended area and is deflected to an unintended area. F1857the printer can mark the paper. F14573.1.15 nonimpact printer, n—printer in which image forma- 3.2.9 spray, n—type of extraneous or undesirable ink dot near the printed zones which originate from the printhead.tion is not the result of mechanical impacts. Examples are F1857thermal printers, electrostatic printers, electrophotographicprinters, and inkjet printers. F909 4. Significance and Use3.1.16 offset, n—unintentional transfer of ink (as from a 4.1 The procedures outlined here are grounded in the generally accepted body of knowledge and experience in thefreshly printed substrate). F1857 field of forensic document examination. By following these procedures, a forensic document examiner can reliably reach 3.1.17 piezoelectric, n—ink jet technology where the elec- an opinion concerning whether two or more documents pro-trically stimulated deformation of a crystal causes the expul- duced with ink jet technology are from the same device,sion of the droplets from the ink chamber. whether a particular device created the document, or the determination of the make or model of a device. 3.1.18 pixelation, n—stairstepped or jagged effect resultingfrom analog to digital conversion.3.1.19 platen, n—flat plate or roller used as a support forprinting or copying a document. F1156 5. Interferences3.1.20 portrait mode, adj—printer output orientation in 5.1 Items submitted for examination may have inherent limitations that can interfere with the procedures in this guide.which print lines run perpendicular to the direction of move- Limitations should be noted and recorded.ment of the paper. F1457 5.2 Limitations can be due to the generation of the document(s), limited quantity or comparability, or condition of 3.1.21 printhead, n—printing device of an ink jet printing the items submitted for examination. Such features are takensystem. into account in this guide.3.1.22 printer output area, n—maximum area on the page to 5.3 The results of prior storage, handling, testing, or chemi- cal processing (for example, for latent prints) may interferewhich the printer will print. F1457 with the ability of the examiner to see certain characteristics. The effects can include, but are not limited to, partial destruc-3.1.23 raster output scanner, n—output peripheral, either tion of the substrate, stains, and deterioration of the ink. Whenever possible, document examinations should be con-stand alone or within a printer, that converts computer data into ducted prior to any chemical processing. Items should be handled appropriately to avoid compromising subsequent ex-a bit mapped image, which is sent to the host for storage or a aminations.printer for output. F1457 5.4 Consideration should be given to the possibility that various forms of manipulation and duplication of ink jet- 3.1.24 slit glass, n—alternate scanning surface found in produced items can be generated by computer, scanner, digital Photos Signaturessome digital photocopiers used in conjunction with an auto- camera, graphic pad or other means.matic document feeder. 5.5 Some ink supply units are interchangeable between3.1.25 smudge, n—tendency of an image to smear or streak different brands or models of machines. Some ink units are refillable and ink from suppliers other than the originalonto an adjacent area when rubbed; involves the redeposition manufacturer may be used.of abraded material. F221 5.6 Some multi-function devices utilizing toner technology can operate in either printing or copying mode, at different 3.1.26 thermal impulse, n—ink jet technology where therapid expansion of a bubble in the ink created by localizedelectrical heating expels the droplets from the ink chamber.3.2 Definitions of Terms Specific to This Standard:3.2.1 banding, n—uniform density variations or voids in agiven color which appear in the direction that the printheadtravels. F18573.2.2 bleed, n—ink feathering of one color into an adjacentcolor over time. F1857 FraudCopyright by ASTM Int'l (all rights reserved); 2 120

E2389 − 05 Accounting Microscopic False Notary Photoshopping Examinations Manipulated Duplicates of the Duplicated History Introductionresolutions and can produce both multi-color (for example, 7.8 If a known document(s) is submitted, determine whether by 4 Experts Signatures, Stamps Same Documents SignaturesCYMK) black or monochrome (for example, one color black). the known document(s) is suitable for examination, orThese various outputs from one machine have many significant comparison, or both. If it is not suitable, discontinue the Photos Signaturesdifferences among them. procedure and report accordingly. Factors that affect the suitability include clarity, detail, or condition of the document.6. Equipment and Requirements 7.9 If the original is not submitted, evaluate the quality of 6.1 Appropriate light source(s) of sufficient intensity to the best available reproduction to determine whether signifi-allow fine detail to be distinguished. cant details have been reproduced with sufficient clarity for comparison purposes and proceed to the extent possible. If the NOTE 1—Natural light, incandescent or fluorescent sources, or fiber reproduction is not of sufficient clarity for comparisonoptic lighting systems are generally used. Transmitted illumination, side purposes, discontinue these procedures and report accordingly.lighting, and vertical incident lighting may be useful in a variety ofsituations. 7.10 If a device is examined, its condition should be noted. Service records should be requested and pertinent information 6.2 Magnification sufficient to allow fine detail to be distin- noted and recorded.guished. 7.10.1 Discussion—Consultation with a qualified technician 6.3 Rulers in metric, U.S. customary units, printers’ may be advantageous or necessary.measure, and desktop publishing units. 7.11 Note the capabilities, features, and settings of any 6.4 Other apparatus as appropriate (for example, measuring variable features on each device examined. If the device hasgrids and magnetic detectors). internal memory, retain or recover any stored information. 6.5 Imaging or other equipment for recording observations 7.12 Note visible external components of the device such asas required. the platen, slit glass, collators, and cover/automatic document feeder that may contain physical evidence, obstructions, debris, 6.6 Reference materials can aid in the determination of a correction fluid, marks, or scratches.manufacturer. NOTE 2—Before taking exemplars, consideration must be given to the 6.7 Sufficient time and facilities to complete all applicable possible destruction or loss of physical evidence within the device (forprocedures. example, fragments torn from the questioned document).7. Procedures 7.13 Prepare appropriate exemplars, taking into consider- ation the features of the device and possible chemical ink 7.1 All procedures shall be performed (consistent with examinations.Toner Guide) and noted when appropriate. These proceduresneed not be performed in the order given. 7.14 Note damage to easily accessible internal components of the device such as the print head or paper transport 7.2 Examinations performed, relevant observations, and mechanism.results shall be documented. 7.15 If applicable, take additional exemplars. 7.3 At various points in these procedures, a determinationthat a particular feature is not present or that an item is lacking 7.16 If none of the exemplars are suitable for comparisonin quality or comparability may indicate that the examiner and no others are obtained, discontinue these procedures andshould discontinue or limit the procedure(s). It is at the report accordingly.discretion of the examiner to discontinue the procedure at thatpoint and report accordingly or to continue with the applicable 7.17 Examine the questioned item(s), or the questioned andprocedures to the extent possible. The reasons for such a known items.decision shall be documented. 7.17.1 Discussion—The type of substrate used in an ink jet 7.4 Determine whether the submitted questioned docu- printer may affect the appearance of the ink such as banding,ment(s) was produced with liquid ink jet technology. If not, circularity, feathering, bleed, mottling, offset, spatter or satel-discontinue examination and report accordingly. lite droplets. 7.5 Determine whether the examination is comparison of a 7.18 Examination(s) for indentations (Guide E2291) may bequestioned document(s) to a known document(s), a comparison performed for the purpose of visualizing indented writing orof exclusively questioned documents, or is another type of physical characteristics such as marks from the paper transportexamination of a questioned item(s) (e.g., to determine date mechanism.limitations or class of machine). 7.19 Various illumination techniques (color filtering, 7.6 Determine whether the questioned document(s) is suit- infrared, or ultraviolet) may be used to provide additionalable for examination, or comparison, or both. If it is not information such as security features or stains.suitable, discontinue the procedure and report accordingly.Factors that affect the suitability include clarity, detail, or 7.20 Examination(s) for alterations (Guide E2331) may becondition of the document. performed. 7.7 If no known document(s) or device(s) was submitted, go 7.21 Identification of the typestyle(s) may provide usefulto 7.9. information (for example, dating information).Copyright by ASTM Int'l (all rights reserved); 3 Fraud 121

E2389 − 05 Accounting Microscopic False Notary Photoshopping Examinations Manipulated Duplicates of the Duplicated History Introduction 7.22 Compare class characteristics (for example, paper examinations have been conducted. The number and nature of by 4 Experts Signatures, Stamps Same Documents Signaturessupply system, ink type, marks caused by mechanics, color the necessary examinations is dependent on the question atcapability). If significant unexplainable differences exist, dis- hand.continue and report accordingly. 8.2 The bases and reasons for the conclusion(s), opinion(s), NOTE 3—Some ink supply units are interchangeable among different or findings should be included in the examiner’s documenta-brands or models of machines and most units are refillable. tion and may also be included in the report. 7.23 If possible, classify the device used to produce a 8.3 Identification—When the examination reveals no sig-questioned document(s). When identifying a manufacturer of a nificant differences between two or more items and there isquestioned item(s), refer to laboratory and published industry agreement in significant individualizing characteristics, anresources. If necessary, contact the device manufacturer or identification is appropriate. There may be limitations.distributor for further information. 8.4 Elimination—If significant differences between two or 7.24 Compare individualizing characteristics such as wear more items are found at any level of the analyses, an elimina-and damage defects, misalignments, reproducible marks, tion may be appropriate. There may be limitations. There maybanding, voids, and improper or extraneous ink transfer. be similarities.Perform and note critical measurements, where needed. 8.5 Qualified Opinions—When there are limiting factors NOTE 4—Successive copying on the same machine will make marks and the examination reveals similarities or differences ofslightly out of register. Doubling or tripling of a pattern of dots or marks limited significance between two or more items, the use ofindicates, respectively, two or three generations of copies on the same qualified opinions can be appropriate. This opinion requiresmachine. Copying on more than one device may bear the distinctive marks explanation of the limiting factors.of all machines. 8.6 No Conclusion—When there are significant limiting 7.25 Evaluate similarities, differences, and limitations. De- factors, a report that no conclusion can be reached is appro-termine their significance individually and in combination. priate. This opinion requires explanation of the limiting factors. NOTE 5—Care must be taken in the evaluation of characteristics as 9. Keywordssome may be caused by factors external to the print device (for example,artifacts from or manipulation of the source computer file) or character- 9.1 facsimile devices; forensic sciences; ink jet; photocopi-istics common to a particular model of machine. ers; questioned documents 7.26 Reach a conclusion according to the criteria set forth inSection 8.8. Report 8.1 Conclusion(s), opinion(s), or findings resulting from theprocedures in this guide may be reached once sufficient BIBLIOGRAPHY Photos Signatures(1) Doherty, P., “Classification of Ink Jet Printers and Inks,” Journal of the American Society of Questioned Document Examiners, Vol 1, No. 2, December 1998, pp. 88–106. ASTM International takes no position respecting the validity of any patent rights asserted in connection with any item mentioned in this standard. Users of this standard are expressly advised that determination of the validity of any such patent rights, and the risk of infringement of such rights, are entirely their own responsibility. This standard is subject to revision at any time by the responsible technical committee and must be reviewed every five years and if not revised, either reapproved or withdrawn. Your comments are invited either for revision of this standard or for additional standards and should be addressed to ASTM International Headquarters. Your comments will receive careful consideration at a meeting of the responsible technical committee, which you may attend. If you feel that your comments have not received a fair hearing you should make your views known to the ASTM Committee on Standards, at the address shown below. This standard is copyrighted by ASTM International, 100 Barr Harbor Drive, PO Box C700, West Conshohocken, PA 19428-2959, United States. Individual reprints (single or multiple copies) of this standard may be obtained by contacting ASTM at the above address or at 610-832-9585 (phone), 610-832-9555 (fax), or [email protected] (e-mail); or through the ASTM website (www.astm.org). Permission rights to photocopy the standard may also be secured from the ASTM website (www.astm.org/ COPYRIGHT/).Copyright by ASTM Int'l (all rights reserved); 4 Fraud 122



Report of Forensic Document Examination by Accounting Microscopic False Notary Photoshopping Examinations Manipulated Duplicates of the Duplicated History Introductionby 4 Experts Signatures, Stamps Same Documents SignaturesJohn L. Sang, ordered by Mr. Brian A.Herman, Morgan, Lewis & Bockius LLPNovember 17, 2006SANG FINAL 4.PDFApp A - CV 1.PDFApp B - List of Cases 1.pdfAppendix C and D 1.PDFAppendix E & F 3.PDFRpt sign pg 11-17-16 1.pdf Photos SignaturesReport of William Freeman Loan Document Forensic Examinations Fraud 124

DIPLOMATE JOHN L. SANG FELLOW Accounting Microscopic False Notary Photoshopping Examinations Manipulated Duplicates of the Duplicated History Introductionby 4 Experts Signatures, Stamps Same Documents Signatures AMERICAN Forensic Document Examiner AMERICAN BOARD OF ACADEMY OF FORENSIC One Harbor Lane FORENSIC DOCUMENT Glen Head, New York 11545 SCIENCES EXAMINERS ______ November 17, 2016Mr. Brian A. Herman (516) 656 0443Morgan, Lewis & Bockius LLP REPORT OF FORENSIC DOCUMENT EXAMINATIONRE: William Freeman III v. JPMorgan Bank, N.A. (Civil Action 2002-0214): Analysisof Mortgage Documents. INTRODUCTIONI am a Forensic Document Examiner with a master’s degree in Forensic Science from John Jay College of CriminalJustice. I am certified by the American Board of Forensic Document Examiners and have been a document examiner forover 45 years. As an Examiner and Supervisor of the New York City Police Departments Crime Laboratory’s QuestionedDocument Section and an examiner in private practice, I have provided expert testimony in local, state and federal districtcourts in New York, New Jersey, Florida and Connecticut. I am Fellow of the American Academy of Forensic Sciences,Member, Northeastern Association of Forensic Scientists, and a Member of ASTM. I have lectured and conductedtraining at the John Jay College of Criminal Justice, the University of New Haven, CT, Brooklyn Law School and theNYC PD Crime Laboratory and its Advanced and Specialized Training program. My qualifications are set forth in detailon my CV, which is attached as Appendix A. Attached as Appendix B is a list of matters where I have providedtestimony during the period referenced. I have been retained in this matter to analyze certain signatures on certain mortgage documents provided to me by counsel for JPMorgan Chase Bank, N.A. QUESTIONED DOCUMENTSThe following Questioned Documents were submitted for forensic document examination. Photos Signatures Questioned Documents relating to 39 Side Road, Little Compton, RI, loan:Q1a pages Adjustable Rate Note bearing the date March 11, 2005, form # 32859 (11-01) which bears1-6 a black inked William R Freeman signature on page 6 of 6 and inked initials on pages 1 to 6.Q1b pages Prepayment Fee Note Addendum bearing a date of March 11, 2005, form # 32890 (04-04)1-2 which bears a black inked William R Freeman signature on page 2 of 2 and inked initials on page 1. P1 Fraud 125

William Freeman Report Accounting Microscopic False Notary Photoshopping Examinations Manipulated Duplicates of the Duplicated History IntroductionNovember 17, 2016 Questioned Documents relating to 135 Randolph Avenue, Tiverton, RI, loan:Q2a pages Adjustable Rate Note bearing the date July 12, 2005, form # 32859 (11-01) which bears a by 4 Experts Signatures, Stamps Same Documents Signatures1-6 blue inked William Freeman III signature on page 6 of 6.Q2b pages Prepayment Fee Note Addendum bearing a date of March 11, 2005, form # 32890 (04-04)1-2 which bears a blue inked William Freeman III signature on page 2 of 2. Copies of the above Questioned Documents are attached hereto as Appendix C-F. PURPOSE OF ANALYSIS I have been asked to conduct an independent examination of the documents submitted to determine, if possible, whether there were any signs of alteration by reproducing the original inked signature with an inkjet printer and printing the signature on the Questioned Document. In addition, I have been asked to review the findings of James Madison Kelley, Ph.D., as reported in his report of October 24, 2016 titled “The Forensic Report on the William R. Freeman Questioned Loan Documents,” and to comment on his analysis and results. SUMMARY OF RESULTS OF ANALYSIS A detailed examination, comparison and analyses of the disputed area of the Questioned Documents was conducted. The result of my analysis was compared to the results of Dr. Kelley. A non-destructive analysis was performed. The documents were examined microscopically using various microscopes including the Olympus MIC-D, MiScope and Nikon stereoscope together with various lighting sources and techniques. This included an examination by using fiber-optic light, oblique lighting, infrared (IR), IR Luminescence (IRL), and ultraviolet illumination. ESDA Electrostatic detection device (EDD) testing was also conducted. Digital imaging techniques were utilized, the documents were scanned and high resolution prints were made. As part of my practice, I analyze computer generated documents where the allegation of document alteration and fabrication are made including the transposing of signatures from one document to using computer graphics software such as Adobe Photoshop. Photoshop was used in the production of this report. The results of my analysis are as follows: Photos SignaturesA1 The William R. Freeman signatures on documents Q1a page 6, Q1b page 2 and Freeman initials on Q1a1-6 are all consistent with having been written in black, ballpoint pen ink. The ink has a paste-like appearance and can be seen to sit on the surface of the paper fibers. In addition, there are instances of gooping and striation patterns, both of which are attributes of ballpoint pens. Further, there are indentations corresponding with the thickness and intensity of the ink line. A ballpoint pen uses a viscous paste-like ink that adheres to the surface of the paper, Fraud often leaving blank areas in the crevasses between the paper fibers. This is not the case 2 126

William Freeman Report Accounting Microscopic False Notary Photoshopping Examinations Manipulated Duplicates of the Duplicated History Introductionby 4 Experts Signatures, Stamps Same Documents SignaturesNovember 17, 2016 Photos Signatures for the color images generated using an inkjet printer. Inkjet printers employ what is termed “process printing,” where a series of dots in combination of cyan (C), magenta Fraud (M), yellow (Y) and black (K) are disbursed onto the paper surface to create the illusion of a solid color. Microscopic examination reveals the dot pattern and is readily distinguished from actual ballpoint pen ink. No evidence of a four-color printing process (CMYK) was found which would be present had the signatures and initials been computer generated on an inkjet printer. The forms Q1a page 1 to 6 (form # 32859) and Q1b1-2 (form # 32890 (04-04) were consistent with being prepared by a toner base machine. Black toner-like particles were seen to have created the printing on the forms and those type particles were found scattered about the forms. These particles are common to find when a document is printed using a toner base machine. There is no evidence to suggest that the signatures have been tampered with by way of overwriting or retouching. Rather, they show characteristics of naturally executed initials and signatures. A2 The William Freeman III signatures on documents Q2a page 6 and Q2b page 2 both are consistent with having been written in blue, ballpoint pen ink. The ink has a paste-like appearance and can be seen to sit on the surface of the paper fibers. In addition, there are instances of gooping and striation patterns, both of which are attributes of ballpoint pens. Further, there are indentations corresponding with the thickness and intensity of the ink line. No evidence of a four-color printing process was found which would be present had the signatures been computer generated using an inkjet printer. The forms Q2a page 1 to 6 (form # 32859) and Q2b1-2 (form # 32890 (04-04) were consistent with being prepared by a toner base machine. Black toner like particles were found to have created the printing on the forms and these type of particles were found scattered about the forms. These particles are common to find when a document is printed using a toner-based machine. There is no evidence to suggest that the signatures have been tampered with by way of overwriting or retouching. Rather, they show characteristics of naturally executed initials and signatures. EXAMINATION METHODS AND RESULTS An examination, comparison and analysis was conducted of the Questioned Documents to identify alterations to the signature area of the documents and visualize them if present. In conducting the analysis, I used the following Standard Guides published by the American Society for Testing and Materials International (ASTM) which are updated by the Scientific Working Group for Forensic Document Examination (SWGDOC): E 444 - Scope of Work of Forensic Document Examiners 3 127

William Freeman Report Accounting Microscopic False Notary Photoshopping Examinations Manipulated Duplicates of the Duplicated History Introductionby 4 Experts Signatures, Stamps Same Documents SignaturesNovember 17, 2016 Photos Signatures E 2388 - Minimum Training Requirements for Forensic Document Examiners E 2331- Standard Guide for Examination of Altered Documents Fraud E1422 Test methods for Forensic Writing Ink Comparison The examination was conducted macroscopically, microscopically using various lighting techniques, such as side lighting, transmitted lighting, and other appropriate techniques such as infrared (IR), (IRL) and (UV). Some of the results were recorded using high resolution images and made part of this report to explain how I arrived at my conclusions. My examination of the William Freeman signatures and initials on Q1a, Q1b, Q2a and Q2b reflects the following: Each set of signatures and initials were written with blue or black ballpoint pen ink. The ink has a paste-like appearance that can be seen to sit on the surface of the paper fibers. There are instances of gooping and striations created by the ball of the pen during the writing process. Figure 1a is high resolution images of the four (4) signatures, two (2) of which are in black ink and (2) of which are in blue ink, and each of which is consistent with having been produced by ballpoint pen. Q1a page 6, Q1b page 2, Q2a page 6 and Q2b page 2. Figure 1b is high resolution images of seven (7) sets of initials consistent with having been written by black ballpoint pen. Q1a page 1, Q1a page 2, Q1a page 3, Q1a page 4, Q1a page 5, Q1a page 6 and Q1b page 1. Figure 1c is an enlargement of the initials on Q1b page 1, which illustrates striations that are consistent with black ballpoint pen ink and skips of ink in the writing line. Additional images are discussed below. No evidence was found of inkjet four-color printing process (CMYK), which would be present if the blue and black ink initials and signatures had been printed with an inkjet printer. Particles were found that are consistent with black toner particles. These particles were found throughout the document, and are consistent with the form documents having been printed by a toner based machine such as a laser-printer. 4 128

William Freeman Report November 17, 2016 5129Accounting Microscopic False Notary Photoshopping Examinations Manipulated Duplicates of the Duplicated History IntroductionFraud Photos Signatures by 4 Experts Signatures, Stamps Same Documents Signatures

William Freeman Report November 17, 2016 6130Accounting Microscopic False Notary Photoshopping Examinations Manipulated Duplicates of the Duplicated History IntroductionFraud Photos Signatures by 4 Experts Signatures, Stamps Same Documents Signatures

William Freeman Report November 17, 2016 7131Accounting Microscopic False Notary Photoshopping Examinations Manipulated Duplicates of the Duplicated History IntroductionFraud Photos Signatures by 4 Experts Signatures, Stamps Same Documents Signatures

William Freeman Report November 17, 2016 Figure 2a illustrations of toner particles from document 8132Accounting Microscopic False Notary Photoshopping Examinations Manipulated Duplicates of the Duplicated History IntroductionFraud Photos Signatures by 4 Experts Signatures, Stamps Same Documents Signatures

William Freeman Report Accounting Microscopic False Notary Photoshopping Examinations Manipulated Duplicates of the Duplicated History Introductionby 4 Experts Signatures, Stamps Same Documents SignaturesNovember 17, 2016 Photos Signatures Theory of Analysis of Ballpoint Pen Fraud I set forth below information concerning ballpoint pens, and additional information concerning my examination of the Questioned Documents. The ballpoint pen was introduced to the American Market in 1945 at the close of World War II. (Source 2). Ordway Hilton, Characteristics of the Ball Point Pen and Its Influence on Handwriting Identification (Source 1), explained the operation of the ballpoint pen as it “simply rolls ink onto the paper by means of a small ball bearing,” “The ball bearing is held in place at the tip of the pen by means of a housing which is crimped over the widest portion of the ball. Thus, a little less than one-half of the ball is exposed at any one time. Within the housing the ink supply is packed around the ball. With this construction the ball is free to rotate in any direction.” As it moves through the ink chamber, a thin film of ink adheres to its surface: as it rolls across the paper ink is pressed onto the paper surface.” “The ink is a viscose paste-like material, not the usual fluid writing ink of the conventional fountain pen or the old-fashioned dip pen.” “[T]he ink is pressed on the paper rather than flowed on” and once on the paper there is “a gradual penetration of the fibres, due to the sluggish flow of the viscose ink.” Figure 3 Diagram of the component parts of the Ball-Point Pen from Conway, Evidential Document p159 Figure 58 (Source 2). “By referring to the accompanying illustration, it will be seen that the ball pen is essentially a rolling printing device in which the ball impresses a line of writing onto the paper.” “The steel or sapphire ball rotates in its socket and receives its oleaginous ink supply at one point of its rotation and transfers this ink to the paper at the further point of its rotation.” Hilton further states: “Let us examine more closely the action of the ball as it rolls across the paper. After it is charged with the ink, it remains charged until it contacts the paper surface. Once discharged the ball area must again pass through the ink chamber to pick up more ink. The change in direction of the pen means a change in the direction of the rotation of the ball. If here is no ink on the particular area of the ball when it touches the paper, no ink can be deposited, and a skip or break occurs in the stroke. If there is an unduly large quantity of ink on a portion of the ball, a heavy deposit, a dark spot or blob is left.” Especially at changes of stroke direction. Hilton explains how to identify the work of a ballpoint pen: “In order to determine the ball point pen’s influence in a handwriting identification problem,” in our case to determine what mechanical device created the signature and initials, “it is necessary to be able to recognize every specimen written with this writing instrument.” 9 133

William Freeman Report Accounting Microscopic False Notary Photoshopping Examinations Manipulated Duplicates of the Duplicated History Introductionby 4 Experts Signatures, Stamps Same Documents SignaturesNovember 17, 2016 Photos Signatures Ballpoint pen ink can be identified through the application of a drop of distilled or slightly acidified water to the ink along with through microscopic study. In our case, Fraud using a solubility test would be destructive to the documents, so I have used microscopic study and other confirmatory tests. Hilton further notes that “The rolling of the ball across the paper tends to leave a small track or depression in the center of the line. Only a very hard writing surface completely eliminates it in the heavy down stroke.” This characteristic groove or depression of microscopic dimensions further distinguishes ball point pen writing from ink-jet and laser printed signatures. My examination of the signatures and initials on the Questioned Document with a low power microscope and side lighting reveals the indentation. Images of this analysis are described later in this report. 10 134

William Freeman Report Accounting Microscopic False Notary Photoshopping Examinations Manipulated Duplicates of the Duplicated History Introductionby 4 Experts Signatures, Stamps Same Documents SignaturesNovember 17, 2016 Photos Signatures Additional Characteristics of Ballpoint Pen As set forth in Scientific Examination of Questioned Documents (SEQDE) by Jan S Fraud Kelly & Brian Lindblom: “Ballpoint ink is a paste-like substance of high viscosity.” “Most ballpoint pen inks have three components: dyes, resins and volatiles.” “The work of the ballpoint pen can be recognized and distinguished from other writing instruments both by its ink and its line morphology. In lighter strokes, the transfer of the paste-like ink occurs only on the edges of the higher fibers, while in heavier strokes the pressure on the ball forms a grove or compression in the center of the stroke. Ballpoint pen inks dry rapidly once deposited on paper. Other characteristics of the ballpoint pen are derived from the ball, which controls the width and quality of the writing stroke produce.” (Source 3 at Page 148) “Ballpoint pens can be differentiated from one another by their ink color, ball sized (medium, fine, or extra fine), and defects that may be present in the writing line.” These defects include gooping (small dot-like deposit of ink, especially at points of redirection, such as in loops and connecting strokes), skipping or short gaps (Figure 13.3) and striations within the stroke (13-4) Very fine burr striations may occur at times in a pattern distinctive enough to individualize the pen.” (Source 3 at Page 149) Microscopic examination of the pen strokes on the Questioned Documents and particularly the weaker portions discloses characteristic aspects of ballpoint pen writing. The ink does not flow into the fibers but only stains the raised portions of them. See Figures 8d, 9b, 12g and 13a. The following are examples of ballpoint pen from the SEQDE: Figure 4a-b Examples of the tips of Ballpoint pens. See Scientific Examination of Questioned Documents, SEQDE, Jan S Kelly & Brian Lindblom p148 Figure 13.1 (3) 11 135

William Freeman Report Figure 5 Accounting Microscopic False Notary Photoshopping Examinations Manipulated Duplicates of the Duplicated History Introductionby 4 Experts Signatures, Stamps Same Documents SignaturesNovember 17, 2016 SEQDE p149 Figure. 13.2 Gooping “Microphotograpic enlargement” of an Skip ink line Striation/ Skip Gooping Skip Gooping Figure 6 Portion of signature written with ballpoint pen showing skips and gooping characteristic of this class of pen. See Scientific Examination of Questioned Documents, SEQD, Kelly & Lindblom at Page 150 Figure 13.3 (3)Striation/ GoopingSkip Striation Striation pattern Figure 7 Ink line morphology defects is an example of ballpoint pen writing. The ug Photos Signatures combination shown above exhibits both a striation pattern and an instance of ink gooping. See Scientific Examination of Questioned Document, SEQD, Kelly & Fraud Lindblom p150 Figure 13.4 (3) The signatures and the initials on the Questioned Documents are consistent with the examples described above. 12 136

William Freeman Report Accounting Microscopic False Notary Photoshopping Examinations Manipulated Duplicates of the Duplicated History IntroductionNovember 17, 2016Image at Figure 8a is an enlargement of the black ballpoint ink initials on Questioned Document by 4 Experts Signatures, Stamps Same Documents Signaturesend Q1a page 1.Image at Figure 8b1-2 Illustrates the results of the microscopic examination of the introductoryend stroke of the “W” at 140 times enlargement with fiber optic side lighting. It illustrates pen track depth in the introductory stroke to the W” and the change of direction of theImage at center of “W” where the upstroke culminates and down stroke begins. It shows the inkend skip in the introductory stroke of the “W” in the initial on Q1a page 1. Image 132. Figure 8c Illustrates the results of the microscopic examination of the introductoryImage at stroke of the “W” at 140 times enlargement with fiber optic side lighting. It illustratesend pen track depth in the introductory stroke to the “W” and the change of direction of the center of “W” where the upstroke culminates and down stroke begins. It shows the ink skip in the introductory stroke of the “W” in the initial on Q1a page 1. Image 132. B35C0. Figure 8d Illustrates the results of the microscopic examination of the cross stroke of the “F” at 140 times enlargement with fiber optic lighting. It illustrates the path of the black ballpoint pen line as it had rolled its ink across the paper fibers. Image 112 Microscopic examination of the area around end of the cross stroke of the “F” at 140 times enlargement with fiber optic lighting. It illustrates many toner particles around the black ballpoint ink stroke. (see pink arrows, pink box and miscellaneous toner particles)Image at Figure 8e Stereoscopic examination with fiber optic sidelighting of the upper portion ofend the “F” as the stroke of the pen turns down in the initial illustrating the slight depth of the pen track.Image at Figure 9a Illustrates an enlarged high resolution scan of the William R. Freemanend signature on questioned document Q1a page 6.Image at Figure 9b Illustrates the results of the microscopic examination of the cross stroke areaend of the “F” at 140 times enlargement with LED lighting. It illustrates the path of the black ballpoint pen ink as it had rolled across the paper fibers. Image 051 Microscopic examination of the area around end of the cross stroke of the “F” at 140 times enlargement with LED lighting. It illustrates toner particles around the black ballpoint ink stroke.Image at Figure 9c Illustrates the results of the microscopic examination of the cross stroke area Photos Signaturesend of the “F” at 140 times enlargement with infrared (IR) light at a wavelength of 760nm. Image 052. It illustrates a faint outline of the path of the black ballpoint pen ink line as it had rolled across the paper fibers. Microscopic examination of the area around end of the cross stroke of the “F” at 140 times enlargement with infrared light at a wavelength of 760nm. Image 052. It illustrates the faint image of the ink line when illuminated by IR light at 750nm, however; the black toner particles remain prominent. I have found that this is a characteristic of toner particles when examined at this wavelength of infrared light (energy).Image at Figure 9d Illustrates the results of the microscopic examination of the right end of the 13 Fraud 137

William Freeman Report Accounting Microscopic False Notary Photoshopping Examinations Manipulated Duplicates of the Duplicated History IntroductionNovember 17, 2016end cross stroke area of the “F” at 140 times enlargement with infrared light at a wavelength of 850nm. Image 053. The ballpoint ink is no longer visible; however the toner particles are still present.Image at Figure 10a illustrates an enlargement of the area of the initials on page Q1b page 1 and by 4 Experts Signatures, Stamps Same Documents Signaturesend the image area presented in Dr. Kelley’s Exhibit 2.1. The area of the “W” that is enclosed in the blue box will be used for comparison of Figures 10d through 10h.Image at Figure 10b is a copy of Dr. Kelley’s Exhibit 2.1.endImage at Figure 10c is an enlargement of the initials in the black ballpoint ink.endImage at Figure 10d is an enlargement of a portion of the initial area on Dr. Kelley’s Exhibit 2.1.endImage at Figure 10e is an enlargement of the same portion of the initial area at 40z as in Exhibitend 2.1. Striations and ink skips are also visible.Image at Figure 10f is an illustration of the bottom of the “W” image 069 140x enlarged usingend LED lighting. Particles consistent with toner particles are visible.Image at Figure 10g is an infrared image using infrared light at 760nm illustrating the inksend response to it. The toner particles are visible, however; the ink is only barely visible.Image at Figure 10h is an infrared image using infrared light at 850nm illustrating the inksend response to it. The toner particles are visible; however the ink is no longer visible. I have found that this is a good indicator that the particles are toner. The colored parallel lines are used to locate the toner particle on the corresponding images Figures 10f-g.Image at Figure 11a-g Visually explains the results of my examination and comparison of theend area on the right side of the “W” in Freeman signature Q1b page 2 outline in a red box on Figure 11a1. The signature was examined visually, microscopically using various microscopes such Olympus MIC-D, MiScope and Nikon stereoscope together with various lighting sources and techniques.Image at Figure 11a1-2 illustrates the area of the examination and comparison of a portion of the Photos Signaturesend “W” with the corresponding portion of Dr. Kelley’s report image Exhibit 2.2. (Figure 11c)Image at Figure 11b Microscopic image of a portion of the “W” of the black ballpoint inkend signature of William Freeman, at 140 times enlargement. This is a portion of the area of the “W” that was illustrated in Kelley’s Exhibit 2.2. The image clearly shows particlesImage at consistent with black toner particles.end Image Figure 11c is a copy Dr. Kelley’s Exhibit 2.2at endImage at Figure 11d illustrates the area examined outlined in a red box. See Figures 11e-g.endImage at Figure 11e-g Fig. 11e illustrates the area of microscopic examination compared withend Fig. 11f records the results of the microscopic examination with infrared light at 760nm and Fig. 11g records the results of the microscopic examination with infrared light at 850nm.g The results show that at IR 750nm the black ballpoint is barely visible while the black Fraud particles are consistent with toner particles remain at IR 850nm. The black ballpoint ink 14 138

William Freeman Report Accounting Microscopic False Notary Photoshopping Examinations Manipulated Duplicates of the Duplicated History IntroductionNovember 17, 2016 is not visible; however, black particles consistent with toner are visible.Image at Figure 12a-g Illustration of the results of the examination of the William Freeman III by 4 Experts Signatures, Stamps Same Documents Signaturesend blue ink signature on Questioned Document Q2a page 6 and the area surrounding it.Image atend Figure 12a Q2a page 6 signature.Image at end Figure 12b “Wil” 40 times magnification 134 B41Co’Image at end Figure 12c Introductory stroke into “W” has s skip. Ink rolls on top of fibers.Image at end Figure 12d illustrates Top of “I” 140 times enlargement, has a skip. Pink box contains an array of particles consistent with black toner. Some particles are in combinations ofImage at end more than one particle. Image 149 Figure 12e The brown box illustrates gooping in the top of the “F”s introductory strokeImage at end at 140 times enlarged. Pink box represents particles consistent with toner. Many others can be seen on the entire page.Image at end Figure 12f Microscopic image of the cross stroke of the “F” as it rolls across the top of the paper fibers and terminates.Image at Figure 12g Illustration of examination of blue ink line on top of paper fibers in the “m”end of William Q2a page 6 with particles consistent with black toner in the signature line below and scattered around the page. No Cyan, Magenta, Yellow & Black (CMYK) inkjet ink droplets were found. Figure 13a-b Questioned Document Q2a page 6. Microscopic examination of the blue ballpoint ink line at 140times using a fiber optic light source illustrates the blue ink line intersecting the typed “N” in Freeman consisting of toner particles. Figure 13b is a microscopic image of the intersection enlarged 140 times using infrared light at 760nm. It illustrated that this wavelength of IR light does not visualize the blue ballpoint ink yet it shows the toner particles clearly. No inkjet Cyan, Magenta, Yellow & black (K) (CMYK) ink was noted. Additional confirmatory testing for toner particles and ink can be done chemically and instrumentally. However, these tests are destructive in nature and should only be done with permission of the parties and the Court. SOURCES Photos Signatures1 Hilton, Ordway, Characteristics of the Ball Point Pen and Its Influence on Handwriting Fraud Identification. The Journal of Criminal Law, Criminology and Police Science, Vol 47, No 5 (Jan-Feb, 1957) pp 606-6132 Conway, James, Evidential Documents, (Springfield: Charles C Thomas, 1959)3 Kelly, Jan and Lindblom, Brian, , Scientific Examination of Questioned Documents, Second Edition (CRC Press, Taylor & Francis Group, 2006)4 Hilton, Ordway, Scientific Examination of Questioned Documents, Revised Ed. (New York: Elsevier/North Holland Inc., 1982 15 139

William Freeman Report Accounting Microscopic False Notary Photoshopping Examinations Manipulated Duplicates of the Duplicated History Introductionby 4 Experts Signatures, Stamps Same Documents Signatures November 17, 2016 Photos Signatures TERMS Ballpoint pen A writing instrument have as its marking tip a small, freely rotating ball Fraud bearing that rolls the ink onto the paper. The ink is typically highly viscous and non-aqueous. Roller ball pen A writing instrument in which a ball bearing is used in combination with an aqueous fluid ink to transfer the ink to the paper. CMYK These letters stand for cyan, magenta, yellow, and black, and are the four colors used in most four-color printing technologies. Using half toning, the eye can be tricked into seeing millions of colors, when just these four are combined properly. Cyan, magenta and yellow are the three primaries in this subtractive color model. Infrared (IR)- of or relating to the range of invisible radiation wavelength from about 750 nanometers, just longer than red in the visible spectrum, to 1 millimeter, on the border of the microwave region. n. infrared light or infrared part of the spectrum. American Heritage College dictionary. Infrared (IR), n—referring to radiant flux having wavelengths longer than the wavelengths of light, usually wavelengths from about 760nm to about 3 mm. ASTM Standard E284 & SWGDOC Inkjet printer A non-impact printer in which the characters are formed by projecting droplet’s of ink onto a substrate (ASTM F909) Toner A material (either a dry powder, usually mixed with a binder, or particles suspended in a liquid) that, by means of an electrical charge, is transferred in a controlled pattern into an imaging drum or belt and then to paper. Toner can be found in printers, fax machines, and copiers that utilize an electrophotographic (xerographic) process. Dry toner, n-material in a dry developer system which when deposited on substrate by the field of an electrostatic charge pattern, becomes the visible record. F1457 ASTM Dual-component development, n- mixture of dry toner and iron oxide developer that is used for developing electrostatic images in copiers. ASTM E F1424 ASTM Inkjet printer, n, nonimpact printer in which the characters are formed by projecting droplets of ink onto a substrate. ASTM F909 & SWGDOC Full-color copiers, n - ink jet technology, copiers that can reproduce color originals containing gradation of color. They have a minimum of three colored inks (cyan, magenta and yellow) (CMY) SWGDOC Satellite, n- extraneous or undesirable ink droplet. (See also spatter, spry).ASTM F1857 Spatter, n-type of extraneous or undesirable ink droplet originating when a portion of an ink droplet strikes the intended area and is deflected to an unintended area. ASTM 1857 Spray, n- type of extraneous or undesirable ink dot near the printed zone which originate from the print head. ASTM F1857Respectfully submitted,John L. Sang, MS, D-ABFDEForensic Document Examiner 16 140

William Freeman Report November 17, 2016 17 FIGURES141Accounting Microscopic False Notary Photoshopping Examinations Manipulated Duplicates of the Duplicated History IntroductionFraud Photos Signatures by 4 Experts Signatures, Stamps Same Documents Signatures

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