Although the Statistics Canada data are admissible, I do not
find them helpful. They do not distinguish between when a person committed a homicide or was charged or convicted of a homicide, and therefore cannot be compared to Totten’s data.
 Even without the Statistics Canada data, the number
of 97 is not supported by the written studies Totten authored.
Neither that number nor any number close to it is disclosed by
the six studies he claimed to have relied on. For that reason,
whether 97 young gang members in his studies were convicted
of a homicide cannot be assessed or verified.
( iv) Seventy-one males of the 97 gang members convicted of a homicide had a teardrop tattoo
 Totten claimed that, of the 97 gang members in his studies who were convicted of murder or manslaughter, 71 males
obtained a teardrop tattoo. This claim is even more troubling,
even assuming the accuracy of the figure of 97. Not a single
study lists the number of gang members who had a teardrop tattoo. Indeed, the texts of the six studies contain only a few references to tattoos and no reference at all to teardrop tattoos.
 Nonetheless, Totten testified at the Gager voir dire that
all six studies asked questions about tattoos. But the studies say
otherwise. Here is what each study says about tattoos and ques-
tions on tattoos:
— The YSB May 1999 Youth Survey does not list what ques-
tions were asked of the participants and contains no discus-
sion of tattoos.
— Appendices A and B of the Guys, Gangs and Girlfriends
Abuse study list the questions asked of each participant. The
questionnaire is detailed: 40 initial screening questions followed by in-depth interview questions. Yet the questionnaire
does not include a single question about tattoos. And the
study itself, including the various charts, does not discuss or
refer to tattoos. The absence of questions about tattoos and
references to them in the study is hardly surprising. The
purpose of the study was to explore how male youth made
sense of their abusive behaviour towards their girlfriends.
— In Understanding Serious Youth Violence, question 6 of the
interview questions asks: “Do you have any tattoos? Can
you show me? What does/do the tattoo(s) mean to you?”
Question 7 asks: “How do you communicate with gang
members . . . Probe for . . . tattoo.” The report has a section
on case studies and several of the subjects discuss their