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Scientists' April 1, 2000 Status Report to the Court
Affidavit of Thomas W. Stafford, Jr.
Alan L. Schneider, OSB No. 68147
1437 SW Columbia Street, Suite 200
Portland, Oregon 97201
Telephone: (503) 274-8444
Facsimile: (503) 274-8445
Paula A. Barran, OSB No. 80397
BARRAN LIEBMAN LLP
E-mail: pbarran@barran.com
520 SW Yamhill Street, Suite 600
Portland, Oregon 97204-1383
Telephone: (503) 228-0500
Facsimile: (503) 274- 1212
Attorneys for Defendant
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF OREGON
ROBSON BONNICHSEN, et al.,
Plaintiffs,
v.
UNITED STATES OF AMERICA,
DEPARTMENT OF THE ARMY, et al.,
Defendants.
CV No. 96-1481 JE
AFFIDAVIT OF Thomas W. Stafford, Jr.
I, Thomas W. Stafford, Jr., being first duly sworn, do depose
and state as follows:
1. I am the founder and president of Stafford Research Laboratories,
Inc., Boulder, Colorado (hereafter "SRL"). Further
details of my professional experience and qualifications are
contained in affidavits previously filed with the Court. See
Plaintiffs' Motion for Order Granting Access to Study the Skeleton
(March 11, 1997); Plaintiffs' Reply (Motion for Immediate Response)
(August 10, 1999).
2. Munsell Soil and Plant Tissue Color Charts (also commonly
referred to as "Munsell Soil Color Charts" or "Munsell
Charts") are routinely used by geologists, archaeologists
and other scientists to describe the color of a wide variety
of objects and natural materials. These charts can be used for
any substance having color, including bones regardless of their
condition. In addition to red, yellow and brown hues, the Munsell
Charts include two charts of "Gley" colors (i.e., blue,
green and gray). Attachment 1 is a copy of three pages from
my edition of the Munsell Charts showing how those colors are
depicted. In addition to those two charts of Gley colors, there
are other Munsell Charts that can be purchased for identifying
and describing colors derived from plant materials (including
algae). They provide an even wider range of greens.
4. Attachment 2 is a copy of two pages from the Munsell website
describing the Munsell color chart system. The website address
is: munsell.com/muncheck.htm.
5. Objects such as bones that are mottled or multi-colored can
be described by giving the appropriate Color Chart reference
for each color. In such situations, the predominate color is
usually described first and then the secondary or subsidiary
colors. If any color on an object has multiple shades or hues,
such variation can be described by giving the range of the variation.
For example, a green color could be described as 5Y6/4 to 5Y6/8.
DATED this day of March, 2000. (signed)
Thomas W. Stafford, Jr.
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