The Trial
Analytical
To: Ms. Lauren Willoughby and Ms. Allison Hepola (for the prosecution)
Ms. Kaitlyn Dudley and Mr. John Cannon (for the defense)
Omnibus Analytical
45 Main Street
Notre Dame, IN 46556
From: Carroll Associates
119 Second Street, Suite 2A/B
Notre Dame, IN 46556,
Your services are requested for a lead screening test at 857 Forest Avenue in South Bend, Indiana. We will also require your services as expert witnesses for the pending trial (Cerrito v. Mount).
Ms. Willoughby from the Prosecution team and her counterpart from the Defense team (Ms. Dudley) will be responsible for the actual sample collection and for any other tasks that seem appropriate (such as preparing a map of the home to show where samples were taken). They will decide what types of sample to analyze, choose the locations to sample, and ensure that the samples are properly collected and labeled and that the chain of custody is maintained. The sampling job managers will have to have a handle on the likely sampling requirements at the site in order to efficiently use their sampling team's time and labor.
It is most important that both sampling job managers should review our standard sampling procedures (Chem 191 lab manual, lead lab) and discuss them with M. Canalas (who has a background in environmental sampling and analysis) before Oct 8th.
After obtaining the samples, the sampling team will return to lab (ETA 4:00) and prepare the samples for analysis. The preparation of most samples will take less than 15 minutes. The job managers will also assist M. Canalas in preparing appropriate quality assurance samples.
Ms. Hepola from the Prosecution team and her counterpart from the Defense team (Mr. Cannon) are responsible for maintaining the chain of custody and allocating the work of sample analysis among the analytical team members.
It is most important that they review the standard analytical procedures and calculations (Chem 191 lab manual, lead lab) and discuss them with Ms. Canalas well before Oct. 15th so that the time and labor of the analytical team members are used efficiently.
All four of the job managers should work together to convert the raw data from the ICP-AES into useful information about lead concentrations in the home. This data, in the form of a single two page report, will be distributed at the evidence discovery session on Friday Oct. 29.
The expert witnesses for the prosecution and defense will brief their respective teams regarding the strengths and weaknesses of the findings of the analysis. After this, you all will only have to testify at the trial in order to collect your hefty fees.
Sincerely yours,
Marya Lieberman,
Office Manager, Carroll Associates
119 Second Street, Suite 2A/B
Notre Dame, IN 46556
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