State of California v. Douglas S. Mouser
County of Stanislaus, Case No. 139818


The following is a public document that has been read into evidence in open court before the jury and members of the press. It is a list of my opinions regarding the case and the facts upon which they are based.


November 15, 1999

MEMORANDUM
FROM:  Brent Turvey, M.S., Knowledge Solutions, LLC, Ph# (831) 786-9238
TO: Richard Herman, Attorney, 928 12th Street, Modesto, CA  95354, Ph# (209) 529-5463
SUBJECT: State of California v. Douglas S. Mouser

The purpose of this memo is to summarize the issues that I have formed conclusions about in regards to this case, and their basis.

Victim Risk
It is my opinion that this victim, Genna Gamble, was at a high overall risk of being the victim of a violent crime. The basis for my opinion on this issue resides in the consideration of the following items:

1) The victim was diagnosed with Oppositional Defiant Disorder. She was characterized by her therapist as exhibiting behavior which included the sudden loss of temper, deliberate antagonizing of others, refusal to obey parental instruction, and impulsivity.

2) The victim was known to have a low self-image, which would make her particularly susceptible to the approaches of certain types of sex offenders (those that use a con that involves flattery or the suggestion of acceptance).

3) The victim often spent time at locations socializing with age inappropriate males, unsupervised by adults (Mall, Camelot & Funworks).

4) The victim was known to have socialized with a sex offender whose victims of choice included girls in Genna Gamble's age range, that were acquired at locations similar to the types that Genna Gamble frequented when unsupervised.

5) The victim was thought to have been likely to get into a car with someone that she knew from Camelot.

6) The victim's brother, Gerran Gamble, was known to have been dealing drugs, which he stored at their home.

Primary Scene/ Secondary Scene
It is my opinion that the location where the victim was found was very near to the location that she was attacked and killed, which would be referred to as the primary scene. The basis for my opinion on this issue resides in the consideration of the following items:

1) The nature and circumstances of the victim's purge, as discussed in item #1 of Dr. John Thornton's Crime Scene Reconstruction of this case.

2) The approach of the body to its final resting place being from the direction of the water, and not downhill from the direction of the road, as discussed in item #2 of Dr. John Thornton's Crime Scene Reconstruction of this case.

3) The Duckweed found on the victim's body as discussed in item #2 of Dr. John Thornton's Crime Scene Reconstruction of this case.

4) The "trail" of disrupted vegetation and soil between the victim's body and the bank of the water, as discussed in item #2 of Dr. John Thornton's Crime Scene Reconstruction of this case.

5) The hair of the victim, which is swept downhill towards the "trial" and the water.

6) The lack of credible, transfer evidence related to this crime from other environments or in other environments, such as biological fluids, hairs or pattern evidence.

Sexual Aspects
It is my opinion that this crime contains a number of components that, in concert, could be used to support the interpretation of a sexual motivation. It should be noted that by themselves any of these components would not necessarily be compelling. However, when combined they begin to suggest at least the significant possibility of a sexual aspect within this crime.

1) The location where the body was found is across the water from a location that is known to be frequented by people who would park their vehicles and make-out or have sex.

2) The location at and near where the body was found cannot be seen by those passing by on the main road.

3) The body was found nude at the scene, which is not entirely explained by the possibility that the removal of the victim's clothing may have been part of a precautionary act.

4) The mark on the victim's thigh which has been determined to be consistent with a mark made by underwear.

5) The absence of any significant evidence of overt anger or rage (overkill) in the injuries to the victim.

6) The absence of any evidence of a profit motivation (stolen or missing items of value) in the crime.

In my opinion, the evidence is not inconsistent with the possibility that Genna Gamble was killed during or after a sexual assault of some kind. I am further not aware of evidence that suggests radically alternate possibilities, though I am not prepared to discount them entirely.

Brent E. Turvey, MS Forensic Science
Knowledge Solutions, LLC