Expert Witness Services
William J. Maze, Esq.

I. QUALIFICATIONS

I, William J. Maze, hereby provide this expert report based on my review of the materials provided in the above-captioned matter. My qualifications include:

• Juris Doctor, Wayne State University Law School (1996)
• Member, State Bar of Michigan (1997-Present)
• Certified in Standardized Field Sobriety Testing (NHTSA, 2005)
• Member, National College for DUI Defense (2004-Present)
• Former President, Criminal Defense Attorneys of Michigan (2014-2015)
• Qualified as expert witness in multiple Michigan district and circuit courts
• 25+ years of criminal defense practice with emphasis on DUI defense

II. MATERIALS REVIEWED

For the purpose of this report, I have reviewed the following materials:

1. Police report dated [Date]
2. Dash camera video from arresting officer's vehicle
3. Body camera footage from arresting officer
4. Datamaster DMT ticket and maintenance records
5. SFST training materials for arresting officer
6. Chemical test rights form (DI-177)

III. ANALYSIS OF SFST ADMINISTRATION

Based on my review of the video evidence and police report, I have identified several deviations from NHTSA standards in the administration of the Standardized Field Sobriety Tests:

A. Horizontal Gaze Nystagmus Test

• Improper stimulus movement speed (approximately 2 seconds instead of 4 seconds)
• Failure to check for equal pupil size and resting nystagmus
• Inadequate verification of lack of smooth pursuit

B. Walk-and-Turn Test

• Instructional stage not properly demonstrated
• Improper test surface (sloped, uneven pavement)
• Inadequate lighting conditions affecting balance assessment

IV. BREATH TEST ANALYSIS

The Datamaster DMT test result of 0.12% BAC must be evaluated in context:

• Radio Frequency Interference (RFI) test not properly conducted
• Observation period may have been compromised
• Machine maintenance records show calibration issues within 30 days of test

V. CONCLUSIONS

Based on my training, experience, and review of the materials provided, it is my expert opinion that:

1. The SFSTs were not administered in substantial compliance with NHTSA standards
2. Environmental and administrative factors may have affected test performance
3. The breath test result may not be reliable given maintenance and procedural issues
4. Reasonable doubt exists regarding the defendant's impairment at the time of driving