EXPERT REPORT June 12, 2018 Pertaining to the October 4, 2007 Shooting Incident of Ms, Rhoni Reuter at the 441 Elm Street, Apartment 3B, Deerfield, illinois in Lake County In the Case of People of illinois v. Marni Yang, 09 CF 926 By John Louis Larsen FBI SA Retired Larsen Forensics & Associates, Inc. 208 N. Park Boulevard Glen Ellyn, liinols 60437 DEFENDANT'S EXHIBIT 4yLarsen Forensics & Associates People of ilinals v. Marni Yang ~N Table of Contents ~ Forward: Expert Witness Disciosures..... rm Report. Administrative note to the Reader... Section 4: Items Examined. Section 2: General Background & Shooting Incident. Lake County Major Crime Task Force Photo Montage. ‘Scene Diagram - Lake County Major Crime Task.. LFA Photo Plate 1 ~ Mannequin on gridded tar Section 3: Pistol & Ammunition... Section 4: First Gunshot & Shooter & Victim's Positions... LFA Photo Montage Plate 2 ~ Cartridge in Hallway. LFA Photo Montage Plate 3, Gunshot Wound B (First Shot rN LFA Photo Montage Plate 4: Placement of Protrusion Rod in Mannequin, LFA Photo Montage Plate 5 ~ Dual Laser Experiment with Mannequin..........0.48 LFA Photo Plate 6 ~ The Sine of Bullet Hole 1 / Gunshot Wound B.. LFA Photo Plate 7 ~ ME. Protrusion Rod through Gunshot Wound B. LFA Photo Montage Plate 8 ~ Laser Mannequin Study M.E, Gunshot Wound B. LFA Photo Plate 9 - MLE. Photo of Gunshot Wound B .. LFA Photo Plate 10 (with text) Muzzle Gas Tares... LFA Photo Plate 11 - MLE. Photo with Protrusion Rod, 18 LFA Photo Plate 12~IR Photo of GSR Tan Turtleneck.... sl? LFA Photo Montage Plate 13 - Microscopic Images of Damaged Fibers........18Larsen Forensics & Associates People of ilinois v. Marni Yang Section 6: Gunshot Sequence...... ar soe 18 LFA Photo Montage Plate 14 ~ 1" Gunshot vais. ae 19 LFA Photo Montage Plate 15 ~ 2 Gunshot 19 LFA Photo Plate 16-3" Gunshot... 220 LFA Photo Montage Plate 17-4" Gunshot ...... 720) LFA Photo Plate 18 — 5" Gunshot ... 224 Section 6: Conclusion.......... oer 24 Appendix... ssLarsen Forensics & Associates, Inc. EXPERT REPORT dune 12, 2019 Pertaining to the October 4, 2007 Shooting Incident of Ms. Rhoni Reuter at the 441 Elm Street, Apartment 3B, Deerfield, Illinois in Lake County In the Case of People of Iilinols v. Marni Yang, 09 CF 926 FORWARD: EXPERT DISCLOSURES The following Curriculum Vitae material is tendered at the outset of this report. QUALIFICATION OF WITNESS |, John Louis Larsen, am a specialist in forensics investigation pertaining to crime and shooting incident scene reconstruction. As a crime and shooting incident scene Feconstructionist, | examine and evaluate evidence such as bullet holes, spent shell casings, bloodstain evidence, hair and fiber, and footwear impression evidence, as welll as Investigative case reports and medical examiner's reports to assist’ in the Teconstruction of a scene. Inspection of physical evidence and original case notes and Tough sketches and diagrams are an essential part of the reconstruction process since they provide foundational information more closely related to the incident and provide an insight into the investigators and crime scene technicians understanding of the scene These measurements and diagrams and hands-on inspection of evidentiary exhibits can assist in making determinations of bullet trajectories range of fire and shooter and victim Positions and locations. | have investigated thirty-two shooting scenes since my retirement from the FBI; (See case list in Appendix A). Forensic examination involves correlation and analysis of the information reviewed and developed in the previous paragraph in order to determine how an incident occurred. In this case we correlated and analyzed the Information in order to determine (1) the Positions of the shooters and the shooting victim at various times during the incident; (2) the sequence in which shots were fired; and (3) how shots affected the victim's movement. Generally, special experience and training is required to perform such analysis and correlation and to make such determinations. | have extensive training and experience in such matters, A copy of my curriculum vitae is attached as part of Appendix A. lam a graduate of the Federal Bureau of Investigation (FBI) Academy. On January 19, 1981 1 was sworn in as a Special Agent (SA). | was one of the founders of the FBI Evidence Response Team (ERT) Program. in coordination with members of the FB! Laboratory and other SAs associated with the development of the ERT Program, | assisted in development of the current twelve step evidences recovery guidelines and the documentation utilized in the field in the procassing of crime and shooting incident scenes. In my capacity as one of the developers of the ERT Program, | was tasked with training ERT Teams throughout the FBI and at the FBI Academy. As the Senior Team Leader and ERT Coordinator of the Chicago Division | was responsible for the documentation of crime scenes and shooting incident scenes,People of ilinols v. Mami Yang In March of 1984, | was certified as a Police Instructor through the Instructor Development Course at the FBI Academy. (See www.larsenforensicsino.com for a more detailed biographical history.) In recent years, | have been the principal forensics instructor at the ‘Suburban Law Enforcement Academy (SLEA) at College of DuPage in Glen Ellyn, Ilinols. In this capacity | have taught the Illinois Law Enforcement Standards Board 40 Hour Basic Evidence Technician Course to local law enforcement officers in Illinois and Wisconsin. | have also instructed SLEA courses in Bullet Trajectory Reconstruction (16 & 24 hr. courses), Death Investigation | (24 hr.) and Death Investigation Il (40 hr. advanced body recovery and documentation course). Authored publications in support of my qualifications are as follows: Prints from Skin: How Latent-Fingerprint Impressions are Recovered from Cadavers as Part of the Crime-Scene Search Process, Evidence Technology Magazine, Volume 6, May-June 2008, pgs. 18-22. French Fry or Indication of Bullet Perforation? Evidence Technology Magazine, Volume 7, Number 6, November ~ December 2009, pgs. 8- 9. Shooting Incident Reconstruction within a Room, Evidence Technology Magazine, Volume 8, Number 4, July-August 2040, pgs. 14-17. Grime Scene Forensic Evidence Collection Guidelines for Defense Attorneys, The Champion Magazine, Volume 35, Number 8, October 2014, pgs. 28-35. The Importance of Evidence Collection Guidelines in Developing @ Prosecutable Case, The Prosecutor (A Publication of the National District Attorneys Assoc.), Volume 45, Number 3, July/August/September 2011, pgs. 29-38: Grime Scene Forensic Evidence Collection Guidelines for Defense Attomeys (reprint of The Champion Magazine article of the same title), Indiana Defender, January 2012, pgs. 4, 17-21. Handguns: Range of Fire and Gun Powder Stippling, Evidence Technology Magazine, Volume 11, Number 1, January-February 2013, pgs. 25-28. Co-author of Forensic Photography for the Preservation of Evidence (lead author, Sandy. Weiss) (my contribution is the chapter titled: The Photographer and Mass Disaster Incident Scene) to be published by Words Matter Publishing Fall 2019, COMPENSATION TO BE PAID FOR STUDY AND TESTIMONY An hourly rate for the study was established at $300.00 per hour plus expenses. Court testimony is set at an hourly rate of $300 per hour plus expenses (food & lodging). TESTIMONY WITHIN THE LAST FOUR YEARS On January 27, 2011, the writer testified as an expert in shooting incident reconstruction pertaining to a bullet hole in a windshield before the Honorable Judge Mare R. Killam’s in Page 2 of 23People of iinois v. Mami Yang the case of State of Indiana v. Daniel Paul Foster, 53C02-1004FA-00362 (Circuit Court of Monroe County, Indiana). On September 19, 2011, the writer testified as an expert in shooting incident reconstruction before the Honorable Judge David Akemann in the case of People of Minois v. Andrzej Wojtkielewicz, 09CF2028 (Circuit Court of Kane County, Illinois). On September 19, 2012, the writer was deposed by City of Chicago Corporate Counsel in the case of Wojtkielewicz v. City of Chicago, et al., 11-C-4737, On January 23, 2013, the writer testified as an expert in crime scene reconstruction before Honorable Associate Judge John Joseph Hynes in the case of People of ilinois v. Charles Petrishe, 11CRO16 (Circuit Court of Cook County). On March 27, 2013, the writer was deposed by City of Chicago Corporate Counsel in the case of Cassandra Amold, individually as Special Administrator of the Estate of Martinez Winford, now deceased, v. City of Chicago, et al., 14 L 8374. On June 18, 2013, the writer testified as an expert in shooting incident reconstruction before Honorable Judge William T. Hart in the case of Andrzej Wojtkielewicz v. City of Chicago, et al., 11-C-4737 (U.S. District Court for the Northern District of Illinois), On August 12, 2014, the writer was deposed by City of Chicago Corporate Counsel in the case of Edwards v. City of Chicago, et al., 126 5576. On May 12, 2016, | testified as an expert in shooting incident reconstruction before United State District Court Judge Sharon Johnson Coleman in the case of Edwards v. City of Chicago, et al., 120 5676. On February 19, 2016 | testified as an expert in shooting incident reconstruction before Cook County Circuit Court Judge Thomas V. Lyons in the case of Cassandra Amold, individually as Special Administrator of the Estate of Martinez Winford, now deceased, v. Gity of Chicago, et al. 14 L 8374, On June 3, 2016, | testified to a three day search of a vehicle while in the FBI, Chicago Division in the murder of Darryl Green (06/18/1999) before Associate Judge Lawrence: Flood in the case of the People of Iifinois v. Anton Davis, 18 CR 12967 (Circuit Court of Cook County). On March 29, 2018, | testified as an expert in crime scene reconstruction before District Court Judge Tamara Russell, 1% Judicial District in the State of Colorado in the case of People of Colorado v. Michael F. Blagg, 2016 CR 7230. ‘On June 10, 2019, | testified as an expert in shooting Incident scene reconstruction before State of Wisconsin Circuit Court Judge Scott Needham, St. Croix County in the case of State of Wisconsin v. Kayle Alen Fleischauer, 18 CF 255. Page 3 of 23,People of ilinois v. Marni Yang REPORT Larsen Forensics & Associates, Ino. is referred to herein as "LFA”. On June 20, 2017 | Started a review of the case upon receiving case documents from Tammy Koelling of Words Matter Publishing, Salem, tllincis. Based upon review of my investigative experience set forth in this report and in the attached CV, and based on experiments of the described items in Section 1, | hold the opinion that the shooter in this case was approximately 5 feet 10 inches or more in height. Therefore Mami Yang, at a height of 6 feet, could not have been the shooter!. The shot sequence clarifies and establishes the height of the shooter and provides a firm foundation upon which to understand the physical elements in the scene. This report has been divided into sections to more easily break down and clarify the shooting incident of Rhoni Reyne Reuter on October 4, 2007 at approximately 7:45 AM in the morning at her home at 441 Elm St. Unit 3B, Deerfield, Illinois 60015. Administrat The main focus of my report is to determine the sequence of gunshots and range of fire with the goal of ascertaining the estimated height of the shooter. This report does not attempt to determine or theorize what type of Smm pistol was used since the State's expert Forensic Scientist Peter Striupaitis could not make a determination as to the make and model but rather suggested a myriad of manufacturers that could have created the pistol with the same characteristics as seen in the State's ballistic examination. | will not address the why or how five (5) unfired cartridge cases were recovered at the scene. The approximate height of the shooter is the objective, tte mined 1) Lake County Major Crime Task Force (LCMCTF)/Deerfield Police Department (DPD) October 4, 2007 diagram of 441 Elm Street Apt. 3B, Deerfield, Illinois Main Floor (Bates Stamped 006319); 2) LCMCTF October 4, 4007 Legend of measurements taken pertaining to recovered projectiles (hereafter referred to as "bullets"); round (hereafter referred to as unfired cartridge case); and fired casing (Bates Stamped 006320); 3) Deerfield Crossing Two Story Townhouse Floor Plan, pages 3; 4) October 4, 2007 Autopsy Report pertaining to Rhoni Reuter by Manuel R. Montez, M.D,, 9 pages, plus 5 pages of diagrams and notes (Bates Stamped 000695-698). * lnois Driver's License abstract ® Lake County Deputy Coroner Michael Reld Report on October 4. 2007, Page 1. S NIRCL Ballistic Report of Forensic Scientist Peter Striupaitis, October 10, 2004 (Bate starnp 006863- 006864), Page 4 of 23People of ilinois v. Mari Yang 5) Lake County Coroner's Office Data Sheet Narrative pertaining to Skylar Reyne Reuter-Gayle on October 4, 2007 by Deputy Coroner Michael Reid, 2 pages; 6) Lake County Autopsy Photographs & X-rays consisting of one hundred and fifty- nine photographs and five x-rays; 7) Lake County Sheriff's Office Crime Scene Photographs (digital) under case number, 7-15329, on October 4, 2007 by Evidence Technician D. Thomas #2114. (Larsen Forensics, Inc. generated contact sheet made up of thirty-one pages with six photographs per page). 8) Fired Bullet Worksheets, Northeastem Illinois Regional Crime Laboratory (NIRCL), Laboratory Case Number 07-4728, dated October 8, 2007, consisting of 19 pages. 9) August 15, 2017, Larsen Forensics placement of protrusionitrajectory rods in mannequin and Styrofoam head, thirty-seven photographs. 10)Review of the following NIRCL reports: October 6, 2007 Fingerprint Comparison Examination by Forensic Scientist Anthony R. Spadafora (Bates stamped 006861-6862; October 10, 2007 ballistic examination of fired bullets and fired cartridge casings by Forensic Scientist Peter Striupaitis (Bate stamped 006863-006864); October 10, 2007 ballistic examinations (Bates Stamped 06863-006867); October 11, 2007 fingerprint comparison examinations by Forensic Scientist, Nanoy N. Keel (Bates stamped 006868-006870); December 12 & 18, 2007 fingerprint comparison examinations by Forensic Scientist Kelly G, Lawrence (Bates stamped 006871-006874); January 7, 2007 IBIS report of analysis by Forensic Scientist Gary N. Lind (Bate stamped 006875); February 27, 2008 Ballistic comparison examination by Forensic Scientist Peter Striupaitis (bates stamped 006876-008877); February 13, 2008 DNA analysis by Forensic Scientist Sarah E. Effinger (Bates stamped 006878); February 19, 2008 DNA analysis by Forensic Scientist Michelle L. Thomas (Bates stamped 006879; February 19, 2008 DNA analysis by Forensic Scientist Sarah E. Effinger (Bates Stamped 006880-006881); February 28, 2008 DNA analysis by Forensic Scientist Michelle Thomas (Bates Stamped 006882-006883); April 3, 2008 Ballistic examination by Forensic Scientist Peter Striupaitis (Bates stamped 006884); March 18, 2008 DNA analysis by Forensic Scientist Sarah Effinger (Bates stamped 006885); March 18, 2008 DNA analysis by Forensic Scientist Michelle L. Thomas (Bates stamped 006886-006887); March 25, 2008 DNA analysis by Michelle Thomas (Bates stamped 006888) “January 24, 2008 Ballistic examination on bullet recovered outside kitchen door by Forensic Scientist Robert Berk (Bates stamped 006889-006890); December 20, 2007 SEM/GSR test results re Shawn Gayle by Forensic Scientist Mary Wong (Bates stamped 008891-006802); Page 5 of 23People of ilinois v. Mami Yang - ‘February 26, 2008 Ballistics examination result from bullet exhibits 8 ~ 13 by Forensic Scientist Robert Berk (Bates stamped 006895-006806); 14)August 9, 2017 Lana |. Nicholls volunteered to act as a model to copy on firm foam to create a mannequin of similar height and silhouette of Rhoni Reuters’ 12)March 4, 2009 LCMCTF Report of Evidence Technician Fry (Bates stamped 006858). 13)October 6, 2007 LCMCTF Report by Evidence Technician Terry Richards (Bates stamped 006801). 14)October 4, 2007 LCMCTF Investigative Report of Investigator R. Goar # (Bates stamped 006785-006788). 16)October 4, 2007 LCMCTF Autopsy Photographic Log by Evidence Technician L. Kuber (Bates stamped 006789-006792). 16)October 4, 2007 LCMCTF report pertaining to the collection of exhibits recovered by the Medical Examiner by Evidence Technician James Yanecek #1963 (Bates stamped 008764-006766).. 17)October 4, 2007 LCMCTF Investigative Report of outside videotaping of scene by R. Goar #2101 (Bates stamped 008767) 18)October 5, 2007 LCMCTF Investigative Report of processing of Reuters’ Jeep by Evidence Technician Michael Young #2118 (Bates stamped 008768). 19)October 6, 2007 LCMCTF Investigative Report detailing the recovery and copying of voice mail recording by Evidence Technician Gesar A. Flores (Bates stamped 008768). 20)October 8, 2007 LCMCTF Investigative Report of re-entry of Reuter’s apartment by Evidence Technician John Laskowski (Bates stamped 006770-006771). 21)October 4, 2007 LCMCTF Investigative Report pertaining to Photographic Log for roll of film #1 by Evidence Technician Cesar A. Flores (Bates stamped 006772- 006773). 22)October 4, 2007 LCMCTF Investigative Report by Evidence Technician John Laskowski about items recovered at the search of Reuters apartment (Bates stamped 006774), 28)October 4, 2004 LOMCTF Investigative Report pertaining to Photographic Log for rolls #1 through roll #8 by Evidence Technician Cesar A. Flores (Bates stamped 008756-006763), 24)August 15, 22, 25, 2017 Larsen Forensics laser mannequin study conducted at the ‘Suburban Law Enforcement Academy at the College of DuPage. 25)September 24, 2017 Larsen Forensios laser mannequin study conducted at Larsen Forensics Office, Glen Ellyn, llinois. 28)Novemiber 30, 2017 Omnibus Request which lead to the March 22, 2018 review of {tial exhibit in Case No, 09 CF 926, 27)April 26, 2018 | executed an Affidavit for specific evidentiary items to be tested by Larsen Forensics. 28)May 24, 2018 Larsen Forensics examination of clothing worn by Rhoni Reuter's on October 4, 2004 at Larsen Forensics, Glen Ellyn, Ilinols. 29)May 29, 2018, | obtained a standard from People's Exhibit 43, Rhoni Reuter's tan short sleeve turtleneck shirt, at Independent Forensics DNA Testing & Technologies, Lombard, Illinois, Page 6 of 23rm People of Ilinois v. Marni Yang 30)April 26, 2019, Investigator review of case for Attorney Jed Stone at Stone & Associates, 31) May 7, 2019, LFA number sequenced M.E. gunshot wounds on LFA mannequin, General Background and the Makeup of the Shooting Incident ‘On Thursday morning, October 4, 2007, Rhone Reyne Reuter was shot and killed in her kitchen at 441 Elm Street, 3B, Deerfield, Illinois 60015. The kitchen's dimensions are approximately 10 feet by 9 feet. ‘The actual area in which the shooter was active was approximately 5 feet by 5 feet, as seen in the montage of LCMCTF scene photo below. Door oFF Losey HALL, LFA LCMCTF Photo montage made up of frames 2230, 2240, 2244 & 2314, The linoleum squares are approximately 1-foot square, Reuter was 42 years old, her height was 5 fest 9 inches (69-inches) with @ weight of 135 pounds and was left handed.® She was 6 months pregnant. She appeared to be following her routine and was in the process of leaving to go to work at U.S. Foods in Rosemont, tilinois. The black shoulder bag observed above contained 4 Deorfild Grossing description of Unit 3B as a two store townhouse, See floor plan in Appendix A. 5 LOMGTF Investigative Report ~ Vietimology by Oificer Jason Baldowsky #2149 dated October 8, 2007 Gates stamp 000081). Page 7 of 23People of iltinois v. Marl Yang her gym shoes and workout gear. The Whole Foods plastic grocery bag on the floor to the right of her contained food items which were possibly her lunch, She had a set of keys in her right hand, and her purse was next to her right shoulder. 7 = Lower N “Deerfield PD. : 2007-15329 Ortonerd, 2007 a1 Elm Street Apt 3B Deerfield, IL t Main Fane c ~ Not lo Seale ‘The entry door into the kitchen is off the west kitchen wall, The kitchen entry door off the hallway is hinged to open to the inside of the kitchen and toward the south, The door's natural stopping point is the sink counter in the southwest corner of the kitchen, The shooting evidence associated with this incident consisted of a total of eight (8) fired bullets of which four were recovered from the deceased at the autopsy and three (8) were within the kitchen and threshold to the dining room. Six (6) discharged cartridge casings were recovered within the kitchen and hallway outside the kitchen door. There were five (5) unfirad 9mm Luger caliber cartridges, ‘The next photograph is of Unit B's kitchen floor simulated on a blue tarp. The kitchen floor area and evidence markings along with the mannequin are positioned Page 8 of 23,People of llinois v. Mami Yang approximately to the same scale as the crime scene, The placement of the evidence markers on the blue tarp were obtained from LCMCTF Diagrams and Measurement Legend, Crime Scene Photographs, and Photomodeler measurement data®. A Nikon D300S digital camera was used along with a Tamron SP 10-24mm wide-angle lens. See Appendix B for complete set of photographs. LFA_0013 1 Bi RE SARS LFA Photo Plate 1 — Mannequin on gridded tarp with evidence markers Section 3: Pistol & Ammunition ‘The only facts surrounding the weapon used in this incident Is that it was a &mm. semi-automatic pistol with 6 lands and grooves,” ‘The ammunition used was 8mm Speer 124-grain copper-jacketed hollow points.® Section 4: First Gunshot & Shooter & Victim's Positions ‘The shooter would have been standing in the hallway outside the front and kitchen door of Unit3B. Anyone opening the door from inside the kitchen would have likely used thelr * Photomodeler, EOS Systems, Brish Columbia 7 Northeastern Ilinols Ragional Crime Laborstory Report #2 by Forensic Solentist Petar Strupalts, Cctobsr 10, 2007 (Bates stamp 008863-006864) ® LCMCTF investigative Report ~ Evidence Technician Report of James Yanecsk, #1963, October 4, 2007 page + ‘of 3 (Bates stamp 008764), Page 9 ofPeople of illinois v. Mami Yang left hand on the door knob located on the right edge (inside). With a right opening door Reuter may have stepped back into the kitchen as the door ‘swung open. In this case Reuter’s body would have been bladed to the southwest with her right side slightly facing the door opening and the shooter. Evidence places the shooter firing the first shot by standing outside or on the threshold of Reuter's kitchen door as seen by the discharged 9mm cartridge casing outside the doorway (Evidence Item # JY003). As Reuter opens the door the shooter steps in and discharges the pistol. The range of fire has the earmarks of "contact to near contact’. Reuter is in movement as this first shot is discharged. Dr, M. Montez, M.D, labeled this wound as "B. perforating gunshot wound of chest and left shoulder:” He further goes on to describe it as "A gunshot entrance wound of the left anterior chest wall, muscle and soft tissues of the left shoulder and muscles and soft tissues of the left upper arm, before exiting,” The wound was “in the infraclavicular region, 1372" below the top of the head (or 55% inches from the floor) and 2%" left of midline.” Itis a 1%" diameter oval horizontal perforation with %4" abrasion along the medial margin. The entrance wound is cantered in a 6" x 4" blue contusion."* ® Lake County Coroner's Olfice, Autopsy Report pertaining to Rhoni Reuter on October 4, 2007, page 3. Page 10 of 23People of illinois v. Mami Yang Dr. Montez described the direction of the bullet traveled as, "front to back, right to left, and downward.” ME Photo 0715325132) BULLET EXIT HOLL LOCATION crecue0 mv aLAc) LFA Photo Montage Plate 3, Gunshot Wound B (First Shot) On August 9, 2017 | generated a firm foam mannequin with the assistance of Mrs, Lana Nicholls whose body measurement and body type resemble Reuter's, On August 15, 2017, Forensic Associate Arthur Borchers and |, utilizing the mannequin and the Medical Examiner's measurements associated with the seven gunshot wounds, placed protrusionitrajectory rods in the mannequin. See photos below (Appendix C). LFA Photo Montage Plato 4: Placement of Protrusion Rod in Mannequin Page 11 of 23,People of lilinals v. Mami Yang On August 22 and 25, 2017 Borchers and | conducted a series of laser studies dealing with the gunshot wounds at the Suburban Law Enforcement Academy (Appendix D). The room was mapped out using blue painters tape to depict the shooting incident scene, The foam mannequin with a helght of 69 inches. Mrs, Mary Beth Borchers (height 60- inches) represented a 6-foot shooter. A red-handled training pistol with mounted laser was provided to the shooter, A laser was attached to each trajectory rod to make a determination as to direction and possible height of the shooter. Different scenarios pertaining to each gunshot wound were attempted. Initial findings revealed that gunshot wounds A, C, D, E, F, and G could indeed have bean made by a 5-foot individual using a standard two-handed grip firing from extended arms from the shoulders. However gunshot wound B was the exception due to its placement and the trajectory path established by the Medical Examiner, On September 24, 2017, | conducted a comparison laser study on gunshot wound B at LFI. Using two red lasers and the mannequin along with two vertical scales, an angle finder, a NIKON D300S camera with 28-80mm lens fitted with a 77mm Variable Neutral Density filter it was ascertained that the person firing of this shot had to have been 5-feet 10-inches tall or taller. See series of photos below. A 5-foot shooter could not have created the trajectory path associated with gunshot wound B as corroborated by LFA Forensic Examiners. ‘The PowerPoint photo montage below the bottom red laser beam labeled 1 represents a 5-foot-tall shooter, The top laser beam labeled 2 represents a 6-foot 10-inch tall shooter, Laser Beam 1 below demonstrated that the pistol's muzzle height off the floor would be approximately 4 feet 6 inches for a -foot shooter if the shooter was in a “normal” standing position on a level surface using a two handed grip with arms extend from the body. This laser projection does not follow the trajectory path documented by the Medical Examiner for a 5-foot shooter. For a 5-foot shooter the bullet entering at "B" ‘would have been relatively horizontal or parallel to the floor and would have exited near ‘the top of the shoulder. As seen in laser beam #1 below, Page 12 of 23People of iinois v. Merni Yang ores) LFA Photo Montage Plate 5 - Dual Laser Experiment with Mannequin ‘The photograph of the angle finder sitting atop the laser shows the vertical angle at zero degrees 0° with a standard deviation of (45°). Laser Beam 1 is on-line (almost parallel) with the floor for both a 6-foot and/or the 5-foot 10-inch plus shooter, The horizontal estimated angle of Sin © is the same for both the 5-foot and 5-foot 10-inch plus shooter. ‘The horizontal angle was measure off the protrusion rod where it meets the body. (See below M.E. photo 17-15829(78). LFA Photo Plate 6 ~ The Sine of Bullet Hole 1 / Gunshot Wound B Page 13 of~~ People of ilinois v. Marni Yang ete) LFA Photo Plate 7 - M.E. Protrusion Rod through Gunshot Wound B Laser Beam 2 demonstrated that the pistol’s muzzle height off the floor would be approximately 6-feet for a -foot 10-inch shooter if the shooter was in a "normal" standing position on a level surface using a two-handed grip with arms extended from the body, ‘The horizontal estimated angle of impact is 34° (45°) is the same as with Laser Beam 1. The vertical estimated angle of impact is seen on the angle finder at approximately -13° (45°) for Laser Beam 2, This vertical angle corresponds to the M.E. positioning of the protrusion rod in gunshot wound B. To further support this statement | used two lasers; one from the 5-foot 10-inch shooter position and the other mounted on the protrusion rod entering the gunshot wound B. The two laser beams overlapped which coneretized the hypothesis that the 6-foot 10-inch shooter executed gunshot wound B. ‘To more clearly visualize this scenario see the photo montage below: TRAJECTORY (BULLET PATHWAY) AS DETERMINED BY THE ANGLE FINDER [ANGLE FINDER AT APPROX. VERTICAL ESTIMATED ANGLE OF IMPACT -13°(25") SHOWING LASER DOT’ SHOOTER 5-FOOT 10-INCHES IN YELLOW CIRCLE OR TALLER DETAIL OF LFI_0062 w1,0047 LFA Photo Montage Plate 8 ~ Laser Mannequin Study M.E. Gunshot Wound B Page 14 ofPeople of illinois v. Mami Yang “Range of fire (muzzle to target) for gunshot wound B was extremely "close to contact’, In making this determination several physical factors support this opinion: 1) A lead-in mark’? is observed at the entrance point of the bullet path as seen in ME photograph 07-1329 (31) below even though there's an intermediate object (Reuter's tan turtleneck short sleeve shirt), c™~ ME 07:15329(31) LFA Photo Plate 9 ~ M.E. Photo of Gunshot Wound B ‘The dashed arrows point to the lead-in mark."! 2) The 5 inch by 4 inch blue contusion area surrounding the entrance wound gives corroboration to the closeness of the muzzle blast to this area, 3) Reuter's tan shirt (bloodstained) is witness to the position of the muzzle and the direction of fire. The below image is Medical Examiner's photo 07-15329 (18), *° A lead-in mark: defined as: "A Visible, thin, elongated deposition of bullet wipe transferred to a surface a a bullet frst makes contact with thet surface..." by Luolan G, Haag, Shooting Incident Reconstruction, o™ Glossary, 2006, page 320. ble Page 18 of 23People of ilinois v. Mami Yang ‘THE MUZZLE OF THE PISTOL IS ALMOST AT A POINT OF CONTACT. ‘THE 3 SETS OF HOLES TORN IN THE FABRIC WERE CREATED BY THE GASES EXITING THE MUZZLE. | HAVE PLACED ON THE PHOTO IMAGE THE APPROXIMATE LINE OF TRAJECTORY BY OVERLAVING A YELLOW. DASH LINE/ARROW ACROSS REUTER’S LEFT CHEST AS SEEN IN THE PHOTO ABOVE, LFA Photo Plate 10 (with text) Muzzle Gas Tares 4) The Medical Examiner's placement of a yellow protrusion rod in gunshot wound B defines the direction of this gunshot. As seen below in M.E, photo 07- 15329(78). This Is the first shot fired in this incident. of LFA Photo Plate 14 - M.E, Photo with Protrusion Rod To reiterate what the Medical Examiner reported, "The direction this bullet travels are: front to back, right to left, and downward."2 ~~ = *2lbld, Autopsy Report, pg. 3 Sec. B. Page 16 of 23People of linols v. Mami Yang 8) May 24, 2018 Infrared (IR) photographic study on Reuter’s tan turtleneck short sleeve shirt and black maternity pullover dress supported the observation that the damage to the tan turtleneck was caused by a "near contact" gunshot in Which the gases tore the three-hole pattern across the top of Reuters left chest. With the largest of the tear holes being "near contact" as seen M.E. photo 07- 15329(17) gunshot wound B LFA IMG_0027 JPG IR photo below: Barra sc fUetereaat sig] LFA Photo Plate 12 ~ IR Photo of GSR Tan Turtleneck The other IR photographs were clear of any signs close contact in the form of tears and/or gunpowder particulates. See Appendix H. 8) May 24, 2018 LFA conducted a digital microscopic"? photo study of Reuter's tan turtleneck short sleeve shirt and black maternity pullover dress. ‘The fabric surrounding the bullet entrance wound caused two areas of fabric to bum as seen in photo Image 63 & 99 magnified 160x. These images support the theory that the range of fire was "close contact” because these wool fibers ware not only torn but also burnt rN '® Celestron Digital Handheld Mioroscope, Model #44302, Power 10x-160x,, Torranoa, California 90603. Page 17 of 23People of illinois v. Marni Yang BURNT AND TORN WOOL LFA Photo Montage Plate 13 - Microscopic Images of Damaged Fibers Section 5: Gunshot Sequence itis my opinion, based on placement of wound B, that when Reuter ‘opened the kitchen door she was slightly turned away from the door entrance toward her left. As the shooter Stepped into the kitchen, the shooter discharged the first shot striking Reuter in the upper left chest. Reuter’s attempt to turn away from the shooter began a counter-clockwise ovement which positioned her right side in place for the next series of gunshot wounds, ‘The second sequence of gunshot wounds were: Wounds D & G (Perforating gunshot wound to the abdomen with corresponding gunshot wound to the left forearm and recovered projectila'*); Wound E (Penetrating gunshot wound of back and abdomen); Wound F (gunshot wound to the right hip causing @ complete collapse of the hip.) This ‘shot caused Reuter to buckle allowing for Wound C'S (Penetrating gunshot wound of abdomen). ‘The fourth and final wound sequence was Wound A (Perforating gunshot wound of the head)."® This wound was to the left side of the head which could have created the bullet hole entries in the north kitchen wall in the northwest comer of the kitchen, the black garbage can, with the shooter now positioned approximately in the southwest central Section of the kitchen which and/or possibly the kitchen floor in front of the refrigerator.” \ LOMCTF Investigative Report by R. Goar #2101, Exibit No. RGO16, projectli recovered from the beck at autopsy, October 4, 2007, page 1 of 3 (Bates stamp 006785), ibid, Exhiblt No, RGO18, projectie recovered from the left wrist * Ibid, Autopsy Report, page 2 Page 18 of 23,People of ilinois v. Marni Yang On May 7, 2019 | place number sequence markers next to each M.E. Wound Marker to help the read more easily understand the sequence of event. See LEA mannequin photo series below Glossary of terms: Entry: refers to bullet hole entry Exit! refers to bullet exit hole Penetrating: bullet lodged within the body Perforating: bullet passed through the body All quotes below pertaining to M.E. gunshot wounds have been taken from Dr. M. Montez Autopsy Report of October 4, 2007. LFA Photo Montage Plato 16 ~ 2nd Gunshot 2" Gunshot creating MLE. qunshot, wounds D ("Perforating gunshot wound of abdomen :") & corresponding wound G ("Penetrating aunshot wound of left Page 19 of 23People of Iiinois v. Mami Yang ro LFA Photo Plate 16-3 Gunshot 3° Gunshot creat t wound E ("Penetratin : : 4° Gunsh LE. t wound F ("Penetrating qunshot wound a ofthe right buttock") LFA Photo Montage Plate 17 ~ 6 Gunshot _ 5 Gunshi M.E. qunshot wound ¢ ("Penetrating qunshot wound of abdomen”) Page 20 of 23,oN People of iinois v. Marni Yang 8 Gunshot creating M.E. gunshot wound A ("Perforating gunshot wound Section 6; Gonclusion 1) The shooter was between 5 fest 10 inches or taller. 2) The shooter was in @ standard shooting position, 3) The weapon used by the shooter was a semi-automatic pistol. 4) The pistol fired mm caliber ammunition. 5) The brand and type of 9mm cartridge was Speer copper jacketed hollow point as seen by the seven recovered cartridge cases and the five unfired cartridges recovered.'® 8) Rhoni Reuter appeared to be leaving for work as ssen by the way she was attired, her car and assorted key chain in her right hand, the black shoulder strapped tote bag with gym gear & gym shoes, and @ Whole Food grocery bag with lunch type items possible in her righthand, (This last item was seen on the floor near Reuters right hand.).. 7) Reuter used her left hand to open the kitchen door leading to the hallway lobby. ‘The door opened to the inside from right to left with the sink counter as the stopping point. Ibid, unired enrtidges, Page 21 of 23,People of itinols v. Marni Yang 8) Reuter was bladed to the left with her right shoulder extended towards the shooter. 9) With the door opened the shooter stepped into the kitchen threshold and fired the first shot. 10)The first shot was Medical Examiner's gunshot wound B, a perforating gunshot to the left upper chest, "infraclavicular region", and left shoulder where it exited. 14) Wound B was a "near contact” wound. 12)It Is my opinion both parties were in motion with the shooter advancing forward into the kitchen and Reuter stepping backward into the kitchen as she opened the door. This created the "near contact” wound as seen by the gas expansion tears on the tan turtleneck short sleeve shirt, 18)The LFA laser studies clearly demonstrate that Wound B was from a shooter Who is 5-feet 10-inches or great, and that generate the estimated vertical angle impact was ~13° (46°) demonstrates that the shooter was shooting down on the target (Wound B)._ Gunshot wound B could have only been generated by someone who is fect 10 inches or taller. 14)Gunshot wound B establishes the conditions needed to create the gunshot wounds noted by the Medical Examiner, This report may be subject to revision should additional information or evidence be made available, | reserve the right to use the mannequin and tarp floor layout desoribed in the report in order to illustrate and explain the statements. Respectfully Submitted By: Ge 2 op Memb Hiden John Louis Larsen Page 22 of 23,People of llinois v. Mami Yang APPENDIX ‘A, Larsen Curriculum Vitae and accompanying John Louis Larsen Law Enforcement Instructional History B. July 16, 2017 protrusion rod placement in mannequin ©. August 17, 22 & 25, 2017 LFI laser study reports and photographs on CDs: © August 17, 2017 laser study at LFA '* August 22, 2017 laser study with live exemplar person at LFA © August 25 , 2017 laser study and live fire at range D. September 24, 2017 LFI laser study report focused on gunshot wound with photographs on CD E, March 22 & 23 LFA photographic inventory of trial documents and materials associated with this case on CD F. May 17 & 24, 2018 examination of People's Exhibit 43, tan turtleneck short sleeve shirt, and People's Exhibit 42, black maternity dress, photographs on CD + May 17, 2018 LFA received and photographic documentation and chain of custodies of People's Trial Exhibits from Lake County Clerk of the Circuit Court, Department of Criminal and Traffic. Photographs of CD * May 24, 2018 detall examination of exhibits with photographic documentation both general and digital microscopic on CD + May 24, 2018 Infrared! (IR) photographic examination on CD G. July 4, 2018 LFI blue tarp kitchen floorplan photo log on CD H. May 7, 2019 LFA Mannequin sequence numbered ME. gunshot ‘wounds photographs on CD. Page 23 of 23PHOTOGRAPHED —IN THE CIRCUIT COURT OF LAKE COUNTY, ILLINOIS COUNTY DEPARTMENT, CRIMINAL DIVISION PEOPLE OF THE STATE OF ILLINOIS Respondent-Plaintiff No. 09 CF 926 ) ) ) ) v. ) ) MARNI YANG. ) ) Honorable Christopher Stride ) Judge Presiding Petitioner-Defendant AFFIDAVIT OF JOHN LOUIS LARSEN 1, John Louis Larsen, the affiant, state as follows: 1. lama Retired Special Agent of the Federal Bureau of Investigation (FBI). 1 was the Evidence Response Team (ERT) Senior Team Leader and Coordinator until my retirement. My duties as a Special Agent were in the area of violent crime matters where I specialized in the collection, documentation, analysis and reconstruction of crime and shooting incident scenes. 2, My Curriculum Vitae is attached to this affidavit as an exhibit and is offered in support of my qualifications. 3. | have been retained to conduct forensic testing in People v. Yang 09 CF 926 by the Petitioner-Defendant. 4. Ihave examined photographs taken by the Lake County Major Crime Task Force in the aforementioned case at the Lake County Circuit Clerk's Office (the "Photos"). 5. The Photos depict the use of laser and smoke at the crime scene of the shooting death of Rhoni Reuter. DEFENDANT'S EXHIBIT 456. After careful review of the Photos it is apparent to me they are crucial evidence related to the reconstruction of the shooting incident scene. 7. The Photos provide angles and data required to conduct a proper trajectory study of the crime scene, 8. Those Photos were not provided to Marni Yang or her lawyers, 9. Without these photos, the defense attorneys were hindered from conducting tests that refuted the testimony of the Medical Examiner. Accordingly, itis my opinion that the Defense was crippled in its representation of Marni Yang. In furtherance affiant sayeth not. Under penalties of perjury as provided by law pursuant to Section 1-109 of the Code of Civil Procedure, the undersigned certifies that the statements set forth in this instrument are true and correct, except as to matters therein stated to be on information and belief and as such matters the undersigned certifies as aforesaid that he/she verily believes the same to be true, fee (Signature)