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The Kennewick Man Case | Court Documents | Affidavits & Declarations

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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