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Answer Brief of Appellee - Florida State University College of Law

Answer Brief of Appellee - Florida State University College of Law

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(where Hoskins’ test was performed) with the scanner at Wake<br />

Forest (where the “normal” scans were done). After finding that<br />

the scanner at Jacksonville was “only slightly” less resolute,<br />

he concluded that the findings in Jacksonville would be<br />

“somewhat less sharp by whatever amount less the resolution is”<br />

and would make adjustments. (R993).<br />

It was difficult to print images from the scanner in<br />

Jacksonville so it was necessary to take photographs <strong>of</strong> the<br />

screen instead. (R997). Based on the PET scan images and other<br />

factors, 6 Dr. Wood opined that Hoskins’ “brain is abnormal in the<br />

degree to which the front half or the frontal lobes are active<br />

... the front half <strong>of</strong> the brain is underactive with respect to<br />

the back half <strong>of</strong> the brain against normal reference groups ...”<br />

(R1000, 1010).<br />

Hoskins’ school records reflected poor aptitude in<br />

arithmetic skills and low intelligence. He was considered for<br />

“special placement in ... an educable mentally-retarded class<br />

...” (R1028).<br />

6<br />

Dr. Wood reviewed a report prepared by Dr. Rudolph Geer, a<br />

nuclear medicine physician, a report by Dr. Gary Weiss, who<br />

conducted an EEG study, and Hoskins’ school records. (R1020,<br />

1021, 1023).<br />

12

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