The Perjury Statute, RCW 9A.72.080, defines a "statement of what one does not know to be true."
Every unqualified statement of that which one does not know to be true is equivalent to a statement of that which he knows to be false.
The following are the transcripts from the Skagit County District Court Motion to Dismiss/Suppress proceedings:
The transcripts below are not finalized transcripts. They have not been reviewed, signed off and certified by the transcriptionist.
(not all are available yet)
The following exhibits were admitted or referred to in the Skagit County District Court Motion to Dismiss/Supress proceedings:
Exhibit #1 - American Board of Forensic Toxicology Code of Ethics
Exhibit #2 - Forensic Toxicology Laboratory Guidelines, 2006
Exhibit #3 - Protocol For Simulator Solutions- October 2004
Exhibit #4 - Protocol For Simulator Solutions - December 2005
Exhibit #5 - Protocol For Simulator Solutions - August 2007
Exhibit #6 - Protocol For Simulator Solutions - March 2007
Exhibit #7 - Simulator Solution Batch #7019
Exhibit #8 - Simulator Solution Batch #7020
Exhibit #9 - Simulator Solution Batch # 7021
Exhibit #10 - Simulator Solution Batch #7022
Exhibit #11 - Simulator Solution Batch #5043
Exhibit #12 - Simulator Solution Batch #5044
Exhibit #13 - Simulator Solution Batch #5046
Exhibit #14 - Two Years of Calculation Errors Statement by WSP - August 9, 2007
Exhibit #15 - Simulator Solution Batch #7019 - Revised
Exhibit #16 - Simulator Solution Batch #7020 - Revised
Exhibit #17 - Simulator Solution Batch #7021 - Revised
Exhibit #18 - Simulator Solution Batch #7022 - Revised
Exhibit #19 - Simulator Solution Batch #7002
Exhibit #20 - Simulator Solution Batch #7005
Exhibit #21 - Simulator Solution Batch #7004
Exhibit #22 - Simulator Solution Batch #7003
Exhibit #23 - QAP Correction Memo by AMG - May 4, 2007
Exhibit #24 - Simulator Solution Batch #7005 - Revised
Exhibit #25 - Simulator Solution Batch #7004 - Revised
Exhibit #26 - Simulator Solution Batch #7003 - Revised
Exhibit #27 - Simulator Solution Batch #7002 - Revised
Exhibit #28 - Simulator Solution Batch # 7001 With Miranda Certification
Exhibit #29 - State Toxicology Lab Organizational Chart
Exhibit #30 - First Anonymous Call to the Tip Line
Exhibit #31 - Formoso/Gordon Lab Investigation Memo - April 11, 2007
Exhibit #32 - Second Anonymous Call to the Tip Line
Exhibit #33 - Simulator Batch #7010 - Revised
Exhibit #34 - Three Years of Simulator Solution Batch Worksheets 2004-2007
Exhibit #35 - Simulator Batch #5017
Exhibit #36 - Simulator Batch #5036
Exhibit #37 - WSP Internal Audit - October 2004
Exhibit #38 - Correction To QAP Solution Certificates
Exhibit #39 - Ann Marie Gordon Certifications 2004-2007
Exhibit #40 - QAP Simulator Batch #6016 - Revised with Certifications and Chromatograms
Exhibit #41 - QAP Simulator Batch #6037 - Revised
Exhibit #42 - QAP Simulator Batch #7012 - Revised with Certifications and Chromatograms
Exhibit #43 - QAP Simulator Batch #7013 - Revised with Certificaitons and Chromatograms
Exhibit #44 - Simulator Batch #7015 - Revised
Exhibit #45 - QAP Simulator Batch #7019 - Revised with Certifications and Chromatograms
Exhibit #46 - Simulator Solution Batch #7023 - Revised with Certifications and Chromatograms
Exhibit #47 - Ann Lange Letter
Exhibit #48 - Routing Slip: Beckley to Logan
Exhibit #49 - Memo of Administrative Reassignment to Ann Marie Gordon
Exhibit #53 - Picture of Algorithm on the Board in the Courtroom
Department of Licensing Hearings and Rulings:
Transcript of Lance Olsen Hearing - September 10, 2007
Ruling on Watne Hearing - September 18, 2007
Documents and Materials Relevant to the Current State Toxicology Lab Perjury Issues:
Court Perjury Motion to Dismiss
Court Perjury Motion to Dismiss Exhibits 1-14
Washington State Patrol Admission of Perjury
Two Years of Incorrect Readings
Hearing Officer Ann Lange Letter of September 5, 2007
Russell Case Ruling Denying Motion to Dismiss
Ann Marie Gordon Declarations of 9/27/05, 2/3/06, 1/29/07
Protocol For Simulator Solutions - December 2005
Protocol For Simulator Solutions - March 2007
Protocol For Simulator Solutions - August 2007
Solution Batch 07002 QAP With Wrong Mean - May 2007 Correction
Solution Batch 07003 QAP With Wrong Mean - May 2007 Correction
Solution Batch 07004 QAP With Wrong Mean - May 2007 Correction
Solution Batch 07005 QAP With Wrong Mean - May 2007 Correction
Solution Batch 07019 Certification Before Preparation
Solution Batch 07020 Certification Before Preparation
Solution Batch 07021 Certification Before Preparation
Solution Batch 07022 Certification Before Preparation
American Society of Crime Laboratory Directors Guidelines
Society of Forensic Toxicology Guidelines
State v. Roche, 114 Wn. App. 424 - Malfeasance in Tox Lab
Mansour v. King County, 131 Wn. App. 255 - Subpoena Powers
Transcripts of interviews listed below are to be restricted in their use. Printing a copy of the transcript without the permission of the listed transcriptionist is prohibited.
Interview of Melissa Pemberton
The following email and communication materials are provided by FOIA from the WSP:
Memo of AMG and Formoso to Logan of Lab Investigation - April 11
FAX of Beckley, Jacobs, Logan re: 2nd Alert - July 9th
Email of Logan, Beckley, Jacobs, Hattell re: 2nd Alert
Email of Logan & Loginsky - July 24
Email of Logan, Inglis re: Russell Case Threat - July 23
Email of Moate & Logan Stating Criminal Investigation not OPS
Email of Wilke, Logan, Harruff, Others re: AMG resignation
Email of Human Resources Vacancy
Emails of Logan, Simpson, Sorenson, Jones, Beckley re: audit invitation
Email and Letters of Logan, Jones, Sorenson re: Accreditation
The following materials on Ann Marie Gordons job performance at the State Toxicology Lab are provided by FOIA:
AMG Travel Record and Requests (sorted by the year the traveling occurred)
The following AMG personnel records were provided by FOIA:
The following declarations and certifications of Ann Marie Gordon are provided by FOIA:
Simulator Solution Declarations - 1998
Simulator Solution Declarations -1999
Simulator Solution Declarations - 2000
Simulator Solution Declarations - 2001
Simulator Solution Declarations - 2002
Simulator Solution Declarations - 2003
Simulator Solution Declarations - 2004
Simulator Solution Declarations - 2005
Simulator Solution Declarations - 2006
Simulator Solution Declarations - 2007