1. STATE OF MAINE CUMBERLAND, ss.IGOR MALENKO, Plaintiff
LORI HANDRAHAN, Defendant
DISTRICT COURT
LOCATION: PORTLAND
DOCKET NO.: FM-08-51O
Name: Jacquelyn C. Campbell, PhD, RN, FAAN (Fellow of the American Academy of Nursing)
Profession: Anna D. Wolf Chair and Professor, Johns Hopkins University School of Nursing
1000 Fell St. #210, Baltimore, MD 21231
410 955-2778 (o); 410 522-6744 (h); 410 440-5594 (m)
Education:
BSN – Duke University School of Nursing
MSN – Wright State University School of Nursing
PhD – University of Rochester
Employment background: 27 years as a researcher and clinician in the area of domestic violence.
Developed Danger Assessment as a lethality and near lethality risk assessment instrument for cases of
domestic violence in 1986 with two major federally funded and five small validation studies conducted
from 1987 – 2005. More than 150 refereed publications and 7 books published on domestic violence,
domestic violence homicide and near homicide, and domestic violence risk assessment and lethality
assessment. Twenty eight years as a Professor of nursing, teaching research and family violence to
undergraduate, masters, doctoral and post doctoral students in nursing, public health and medicine as
well as conducting trainings of judges, law enforcement, prosecutors, mediators, lawyers, child custody
advocates, physicians, nurses, DV advocates and others in domestic violence homicide and domestic
violence risk assessment. Elected member of the Institute of Medicine and the American Academy of
Justice, recipient of the Vollmer Award, the American Society of Criminology Award for research
contributing to justice.
Subject matter of affidavit: Risk factors for homicide and near homicide in abusive relationships, Danger
Assessment score for Lori Handrahan and meaning of the score, validity of Danger Assessment.
Substance of Facts and Opinions and the Grounds Thereof: Defendant Lori Handrahan answered the
Danger Assessment in writing and sent it to me on 9/18/08. I subsequently scored the Danger
Assessment. Her weighted score was conservatively 22 which is well within the “extreme danger” range
(18 and above) on the Danger Assessment, the highest level of danger. If plaintiff Igor Malenko
becomes unemployed again at any time in the future (unemployment having been a frequent problem
in his past), the score on the Danger Assessment would increase to 26, even higher in the extreme
danger range. The levels of danger on the Danger Assessment have been validated using data from a

2. large national case control study of actual and attempted intimate partner homicide (see attached
published, refereed article), showing that only 8% of the cases of intimate partner homicide of women
and attempted homicide of women by intimate partners were not accurately predicted using the
weighted scoring method that I used in this case, Furthermore in only 2% of the cases of intimate
partner homicide was the extreme level of danger an overestimate of the level of danger in those cases.
In this case, it means that I can say that I can predict with a 92% level of accuracy or confidence, that Ms.
Handrahan is at extreme risk to be killed or almost killed by Mr. Malenko. Any custody judgment that
gives Mr. Malenko access to Ms. Handrahan puts her at extreme risk to be killed, almost killed or
seriously harmed by Mr. Malenko. Since approximately 17% of intimate partner homicides of women
also involve killing a child, Mila is also at risk to be killed if visitation is not supervised. Furthermore, we
have found that when women are killed or almost killed by an intimate partner, a child is present or the
first to find the body in 71% of the cases nationally. Thus, even if Mila was not directly harmed in such
an incident, there is a high probability that she would be present or find her mother. This would be a
serious trauma to the child, demonstrated to have long-term adverse physical and mental health
consequences.
As to the veracity of Ms. Handrahan’s answers to the Danger Assessment questions, most of the
responses are verifiable by others and are of known record. We have checked validity of the DA from
other abused women with official records, where such records are available, and found approximately
80-90% reliability of answers with official records.
In conclusion, in my expert opinion, based on findings from a validated assessment of danger in
domestic violence cases, I strongly recommend only supervised visitation until the child reaches majority
in the case of Malenkov vs. Handrahan (DOCKET NO.: FM-08-51O, Portland, ME) because of extreme
danger to Ms. Handrahan from Mr. Malenkov, and by extension serious danger as well as serious risk of
traumatic effects to the minor child, Mila.
Anna D. Wolf Chair and Professor
Johns Hopkins University School of Nursing
November 16, 2008