COURT TRANSCRIPT
DIRECT EXAMINATION OF DR. ELIZABETH CARLSON
BY ATTORNEY TERRANCE WILSON*
Expert Witness Credentials
Q: Good morning, Dr. Carlson. Could you please state your full name and occupation for the record?
A: Good morning. My name is Dr. Elizabeth Carlson, and I’m a forensic biologist specializing in DNA analysis.
Q: Where are you currently employed, Dr. Carlson?
A: I’m currently employed at the ######## Forensics Laboratory in Nashville, Tennessee.
Q: Could you please tell the court about your educational background?
A: Certainly. I received my Bachelor of Science in Biology from ######### University in 2005. I then went on to earn my Ph.D. in Molecular Biology and Genetics from ################### University in 2011.
Q: Do you have any specialized training or certifications relevant to DNA analysis?
A: Yes, I do. I’m certified by the American Board of Criminalistics in Molecular Biology. I’ve also completed advanced training in DNA mixture interpretation at the FBI Laboratory in Quantico, Virginia.
Q: How long have you been working in the field of forensic DNA analysis?
A: I’ve been working in this field for 14 years now. I started my career at the ########### Bureau of Investigation’s crime lab in 2011 and moved to my current position at the ########## Forensics Laboratory in 2017.
Q: Have you previously testified as an expert witness in criminal cases involving DNA evidence?
A: Yes, I have. I’ve testified as an expert witness in over 50 criminal cases across Tennessee and neighboring states.
Case Specifics – DNA from Three Humans – Zygote is Human
Q: Thank you, Dr. Carlson. Now, let’s discuss the DNA evidence in this case. Were you responsible for analyzing the DNA samples collected from the crime scene?
A: Yes, I was the lead analyst for this case at our laboratory.
Q: How did you receive these samples?
A: The samples arrived at our lab in proper police packaging, all labeled as coming from the same crime scene. We didn’t have information about how or where exactly they were collected.
Q: How many distinct DNA profiles were you able to identify from the samples provided?
A: We were able to identify three distinct DNA profiles from the samples.
Q: Can you confirm whether all three samples were human DNA?
A: Yes, based on our analysis, all three samples contained human DNA.
Q: Thank you, Dr. Carlson. Now, I have some additional information about one of the samples. We’ve learned that one of the samples was actually a zygote. Does this change your testimony about the DNA being human?
A: (Pauses) Well, that’s an interesting piece of information. A zygote is indeed the earliest stage of human development, formed by the fertilization of an egg by a sperm. Scientifically speaking, it contains human DNA.
Q: So, to be clear, does the fact that one sample was a zygote change your statement that all three samples were human DNA?
A: From a purely genetic standpoint, no, it doesn’t change my statement. The DNA in a zygote is human DNA.
Q: Dr. Carlson, is there any chance that this zygote, if allowed to continue developing, would have been a human?
A: (Hesitates) From a biological perspective, yes. Under normal circumstances and given the right conditions, a zygote has the potential to develop into a fully formed human being. However, it’s important to note that many factors can affect this process, and not all zygotes successfully develop to term.
Q: So, to summarize, you’re saying that this zygote, containing human DNA, had the potential to become a fully developed human if allowed to continue its natural process?
A: Yes, that’s correct from a biological standpoint. A zygote represents the beginning of human development and contains the full genetic human blueprint.
Q: Now, based on your analysis of the three DNA samples, including the one from the zygote, can you state definitively whether or not there were three human beings present at the crime scene? I need a yes or no answer.
A: (Pauses, looking uncomfortable) I… I can’t give a simple yes or no answer to that question. While all three samples contained human DNA, the biological definition of a human being is not universally agreed upon, especially at the earliest stages of development.
Q: Dr. Carlson, I must insist on a yes or no answer. Were there three human beings present at the crime scene based on the DNA evidence?
A: (Sighs) If I must give a yes or no answer, then based solely on the presence of human DNA, I would have to say yes.
Factors Affecting Development Exist Throughout Life
Q: Dr. Carlson, earlier you stated, “However, it’s important to note that many factors can affect this process, and not all zygotes successfully develop to term.” Is that correct?
A: Yes, that’s correct.
Q: Could you elaborate on what you meant by that statement?
A: Certainly. In the early stages of development, various factors such as genetic abnormalities, environmental conditions, or maternal health issues can interfere with the zygote’s development, potentially leading to its failure to progress to later stages.
Q: I see. Now, Dr. Carlson, would you agree that there are also many factors that can affect the lifespan of children and adults?
A: Yes, that’s true. Various factors can impact the lifespan of individuals at any stage of life.
Q: Could you give some examples of these factors?
A: Of course. Factors that can affect the lifespan of children and adults include diseases, accidents, environmental hazards, genetic predispositions, and lifestyle choices, among others.
Q: So, to be clear, just as not all zygotes develop to term due to various factors, not all children or adults live out their full natural lifespan due to various factors. Is that a fair statement?
A: Yes, that’s a fair statement. The potential for life-altering or life-ending events exists throughout human development and life stages.
Children and Teenagers are Not Fully Formed
Q: Dr. Carlson, I’d like to clarify something else you said, could you please define what you mean by a “fully formed human being”?
A: (Hesitates) From a biological perspective, a fully formed human being is typically considered an individual who has completed the developmental stages and reached adulthood. However, it’s important to note that human development is a continuous process.
Q: I see. So, Dr. Carlson, would you consider a person with a disability or deformity to be a fully formed human being?
A: Yes, absolutely. A person with a disability or deformity is undoubtedly a fully formed human being. The presence of a disability or deformity does not negate their humanity or personhood.
Q: Dr. Carlson, earlier you stated, and I quote, “From a biological perspective, a fully formed human being is typically considered an individual who has completed the developmental stages and reached adulthood.” Is that correct?
A: Yes, that’s correct.
Q: Can you clarify what you meant by this statement? Are you suggesting that children and teenagers are not yet fully formed?
A: (Hesitates) Well, from a biological standpoint, children and teenagers are still undergoing significant developmental processes. Their bodies and brains are still maturing.
Q: I see. So, in your expert opinion, at what age would you consider a person to be “fully formed”?
A: (Pauses) It’s not a straightforward answer, as different bodily systems mature at different rates. However, most biological systems are considered fully developed by the early to mid-20s.
Q: Is there a specific age backed by scientific studies that you can point to?
A: While there’s no single age that marks complete development for all systems, research generally indicates that brain development, particularly the prefrontal cortex, continues until around age 25. This is often considered a significant milestone in human development.
Q: So, to be clear, you’re saying that from a biological perspective, a person isn’t fully formed until around age 25?
A: (Cautiously) It’s important to note that development is a continuous process, but yes, from a purely biological standpoint, many scientists consider the brain to be fully developed around age 25. However, this doesn’t mean that individuals below this age are not complete human beings.
Teenagers and Zygotes are Not Yet Fully Formed Humans
Q: Dr. Carlson, based on your previous statements, I’d like to explore a comparison. You’ve mentioned that both zygotes and teenagers are in stages of development and not yet “fully formed” in the biological sense. Is that correct?
A: (Hesitates) Yes, that’s correct. Both are in stages of development.
Q: In terms of being “not yet fully formed,” is there a fundamental difference between a zygote and a teenager?
A: (Uncomfortable) Well, there are significant differences in their stages of development…
Q: I understand that, Dr. Carlson, but I’m asking specifically about their status as “not yet fully formed.” In that particular sense, is there a difference?
A: (Reluctantly) In the strict sense of not being biologically “fully formed,” no, there isn’t a fundamental difference. Both are in the process of development.
Q: So, to be clear, in terms of being “not yet fully formed,” a zygote and a teenager are in the same category?
A: (Sighs) From a purely biological standpoint of complete development, yes, they would both be categorized as not yet fully formed.
Human Development Starts at Conception and Never Ends
Q: Dr. Carlson, I’d like to revisit something you said earlier. You stated, “However, it’s important to note that human development is a continuous process.” Could you elaborate on that?
A: Yes, human development is indeed a continuous process that begins at conception and continues throughout an individual’s lifetime. We continue to grow, change, and develop even into adulthood.
Q: So, if I understand correctly, you’re suggesting that none of us are really “fully formed” in the strictest sense, is that right?
A: (Hesitates) Well, yes, in a way. From a biological perspective, we are constantly changing and developing throughout our lives.
Q: Interesting. So, Dr. Carlson, does our state of incomplete formation, as you’ve described it, eliminate our membership in the human species?
A: (Looking uncomfortable) No, absolutely not. Our state of continuous development doesn’t negate our humanity. All stages of human development, from conception onwards, are part of the human life cycle.
Q: So, to be clear, even though we’re never truly “fully formed,” we are still undeniably human beings, correct?
A: Yes, that’s correct.
Q: And this applies to all stages of human development, including the zygote stage?
A: (Pauses, then reluctantly) From a purely biological standpoint, yes. A zygote contains human DNA and represents the earliest stage of human development.
Q: Thank you, Dr. Carlson. So, to return to my earlier question: based on the DNA evidence, including the zygote, were there three human beings present at the crime scene? Yes or no?
A: (Sighs deeply) Yes. Based on the biological evidence and the definition of human life beginning at conception, there were three human beings represented in the DNA samples from the crime scene.
A Zygote is Fully Human
Dr. Carlson, let’s review your previous statements and clarify some points. You’ve acknowledged that a zygote contains human DNA and represents the earliest stage of human development. Is that correct?
A: Yes, that’s correct.
Q: Now, Dr. Carlson, based on your expertise as a biologist, are there any fundamental biological distinctions between a zygote and an adult human in terms of their status as members of the human species?
A: (Hesitates) From a purely biological standpoint, both a zygote and an adult human are members of the Homo sapiens species. They represent different stages of human development, but both contain the full human genome.
Q: So, to be clear, in terms of being classified as human, there are no distinctions between a zygote and an adult. Is that correct?
A: (Sighs) Yes, that’s correct.
Destroying a Zygote is Ending a Human Life
Q: Dr. Carlson, based on your expert opinion as a biologist, if someone were to deliberately destroy a human zygote, would they be ending a human life?
A: (Pauses, then reluctantly) From a purely biological standpoint, yes. Destroying a human zygote would be ending the life of a human.
Q: So, to be clear, Dr. Carlson, are you testifying that killing a zygote is equivalent to killing a human?
A: (Sighs) Based solely on the biological evidence, yes. Terminating a human zygote would be ending the life of a genetically distinct human.
Premeditated Murder of Innocents
Q: Dr. Carlson, have you ever testified in murder trials before?
A: Yes, I have. As I mentioned earlier, I’ve testified as an expert witness in over 50 criminal cases, some of which were murder trials.
Q: Do you have an understanding of the legal definition of murder?
A: While I’m not a legal expert, I do have a general understanding of the legal definition of murder based on my experience testifying in criminal cases.
Q: Could you please provide your understanding of what constitutes murder?
A: From my understanding as a forensic biologist, murder generally refers to the unlawful and intentional killing of another innocent human being. However, I want to emphasize that the precise legal definition may vary and is best explained by legal professionals.
Q: Thank you, Dr. Carlson. Now, let me provide you with the legal definition of murder. According to U.S. federal law, murder is defined as “the unlawful killing of an innocent human being with malice aforethought”. First-degree murder typically involves premeditation, while second-degree murder may lack premeditation but still involves malice. Does this align with your understanding?
A: Yes, that definition aligns with my general understanding. Thank you for providing that clarification.
Q: Given this legal definition, would you agree that the intentional killing of any innocent human being, regardless of their stage of development, could potentially be classified as murder under the law?
A: (Hesitates) As a biologist, I can speak to the biological aspects of human development. However, the legal classification of murder is a complex matter that involves legal interpretations beyond my area of expertise. I would defer to legal professionals for the specific application of the law in various circumstances.
Q: Dr. Carlson, let’s revisit the DNA samples from our earlier discussion. Were the two adult DNA samples from humans?
A: Yes, they were DNA samples from humans.
Q: And what about the DNA from the zygote? Was it from a human?
A: (Hesitates) Well, from a biological perspective, the zygote contains human DNA and represents the earliest stage of human development.
Q: Dr. Carlson, I noticed you used several qualifiers in your response about the zygote, but not when discussing the adult samples. Is this level of qualification necessary?
A: As a scientist, I aim to be precise in my statements.
Q: I understand, but isn’t DNA definitive in determining the species of an organism?
A: Yes, DNA is the primary determinant of species identification.
Q: So, based on its DNA, couldn’t you simply state that the zygote is human, just as you did for the adult samples?
A: (Pauses) You’re correct. Based purely on its genetic composition, the zygote is human.
Q: To be clear, Dr. Carlson, are you confirming that it’s accurate to say a zygote is human life, without qualifiers, just as you did for the adult samples?
A: (Sighs) Yes, based on its genetic composition, it is accurate to say that a zygote is human life, just as the adult samples are human life.
Q: Thank you for your clarity, Dr. Carlson. No further questions.
If destroying a human zygote is ending the life of an innocent human, and that act is premeditated, then it qualifies as first-degree murder.
*Hypothetical Encounter. Not Real Names.