John Ferak

USA TODAY NETWORK-Wisconsin

MANITOWOC - Charred human bones. A spare key. Blood droplets scattered inside the front of Teresa Halbach's Toyota RAV4.

They are among a slew of clues that resulted in the homicide conviction of Steven Avery in the Halloween 2005 death of the 25-year-old freelance photographer.

Now, 11 years after the murder, "additional testing could once again definitively prove Mr. Avery's innocence and exonerate him for a crime he did not commit," suburban Chicago attorney Kathleen Zellner wrote in in last week's 150-plus page filing in Manitowoc County Circuit Court. Zellner is seeking a judge's permission to order new scientific evidence testing on behalf of Avery, 54, who is serving a life sentence with no possibility of parole.

"We foresee absolutely no problem getting the testing done because, if you think about it, no one who's guilty will ever allow this extensive testing to be done," Zellner said.

Zellner said her law firm — not Wisconsin taxpayers — will bear the costs for the scientific tests. She applauded now-retired Manitowoc County judge Patrick Willis for issuing an order after Avery's conviction in 2007 authorizing the physical evidence in the Halbach murder case to remain preserved indefinitely.

"The case is amazing in how much evidence there is that should be tested," Zellner told reporters.

Zellner has confirmed that all of the items she intends to submit for scientific testing still exist. That evidence remain in the custody of the Calumet County Sheriff's Department in Chilton.

"Mr. Avery's trial transcripts reveal that certain relevant evidence collected in his case was never subjected to prior DNA testing," Zellner stated. "If these items such as the blinker light, hood prop and battery cable are tested, they could conclusively demonstrate Mr. Avery's innocence by identifying the real perpetrator's DNA."

USA TODAY NETWORK-Wisconsin has dissected Zellner's court filing to determine evidence that was overlooked at the time Avery was convicted of killing Halbach. Zellner contends that the new battery of tests can be done within the next three months, if not sooner. She said the tests will reveal who killed Halbach and will show there was massive evidence planting — not only by Manitowoc County law enforcement, but also possibly by civilian searchers following Halbach's disappearance.

Here are some of the noteworthy items that Zellner wants to undergo scientific testing:

Spare Toyota key Halbach's RAV4

Found Nov. 8, 2005, during the fourth day of searching Avery's bedroom, by Manitowoc Sheriff's Sgt. Andrew Colborn, Sheriff's Lt. James Lenk and Calumet County Deputy Dan Kucharski. At Avery's trial, Sherry Culhane of the Wisconsin State Crime Lab testified she swabbed the key and developed a full DNA profile of Avery. Culhane testified she found no trace of the murder victim's DNA on her own key.

Zellner's motion: Identify the bodily fluids on the victim's spare key. "Mr. Avery wants to retest the key for any evidence of solvents or fibers that may have been used to remove the victim's DNA from the key."

Blood droplets found in Halbach's RAV4

Found on Nov. 7, 2005, at the state crime lab in Madison. All of the blood stains found in the front of the vehicle were identified as being Avery's blood.

Zellner's motion: She contends that Avery's blood was planted into the victim's RAV4 by Colborn and Lenk prior to the vehicle being moved from Josh Radandt's quarry to the adjacent Avery Salvage Yard property on Friday night, Nov. 4, 2005. Avery's lawyer wants to perform radiocarbon testing on those blood stains to definitively establish their age. At the time of Avery's 2005 arrest, Lenk knew about a vial of Avery's blood dating back to 1996 that Manitowoc County had in its custody.

Fingerprint comparisons

Eight unidentified latent fingerprints were found in various locations on the victim's vehicle. The fingerprints did not match Avery, Brendan Dassey or other relatives — and special prosecutor Ken Kratz downplayed their significance during their murder trials.

Zellner's motion: "Mr. Avery is requesting that a comparison be performed of the fingerprint standards of Officer Colborn and Lenk to any unidentified fingerprints on the victim's vehicle. If the unidentified fingerprints .... match either Officer Colborn or Officer Lenk, it would be significant evidence of their involvement in moving the victim's vehicle onto the Avery property."

Broken blinker light

Recovered from back cargo area. It came off driver's side of Halbach's vehicle. The front-end vehicle damage was downplayed by Kratz during Avery's 2007 murder trial.

Zellner's motion: Seeks DNA and trace evidence tests. "The blinker light was picked up and placed in the rear cargo area by the perpetrator or the individual who moved the car onto the Avery property. It is a reasonable assumption that this individual handled the blinker light and quite probably left his DNA on the light."

Lug wrench

Found inside Halbach's RAV4. Another item of evidence that became insignifcant during Avery's 2007 murder trial. Although the object was likely handled by Halbach's killer, it never underwent DNA testing at the state crime lab.

Zellner's motion: Seeks DNA tests to reveal who handled the lug wrench "because it appears to have been moved from its original place in the rear cargo area and therefore may have been touched by the perpetrator."

Lever to adjust driver's seat, prop bar to hold up hood, interior hood release

According to Zellner, none of these items underwent previous DNA tests.

Zellner's motion: First-ever DNA tests on driver's seat lever, prop bar for hood and interior hood release. "These previously untested items should disclose the perpetrator's DNA because the un-gloved perpetrator, of necessity, would have touched all of these items in order to operate the car, open the hood and remove the battery cable."

Battery cables

Another item not previously tested for DNA. However, Kratz argued that Avery, after raping and killing Halbach, burned her body in his fire pit and then placed her RAV4 on the edge of his family's property, disconnecting the battery cable, as part of the crime.

Zellner's motion: Check the battery cables for DNA. "Because of the effort required to remove the clamps and cables, it is extremely likely that the individual who performed these tasks would leave his DNA on them."

Hood latch

State crime lab DNA analyst Sherry Culhane testified that she discovered a full DNA profile of Avery on the hood latch. She testified the hood latch swab appeared discolored but it was not reddish-brown or consistent with blood. The swab of the hood latch occurred at the Calumet County Sheriff's Department on April 3, 2006 — six months after Avery was jailed for Halbach's murder. "The hood latch swab allegedly had 'sweat DNA' from Mr. Avery's hand. It is undisputed that there is no such thing as 'sweat DNA.'"

Zellner's motion: Conduct saliva testing and blood tests on the hood latch. "Clearly, if Mr. Avery were bleeding in the victim's car, he would have also deposited blood from his bleeding finger on the victim's hood latch; however, no presumptive blood test was done on the hood latch by the Wisconsin Department of Justice State Crime Laboratory."

Halbach's license plates

Recovered Nov. 8, 2005 from a junked station wagon located within walking distance of Avery's red trailer.

Zellner's motion: Perform new and improved DNA testing on these license plates. From her perspective, either the killer or an evidence planter could have left his DNA on the license plates. "At the time of the initial testing of the front license plate, an insufficient quantity of DNA was obtained. The rear license plate has no discernible DNA. However, with new and improved DNA testing methods, Mr. Avery may be able to obtain a full DNA profile from the license plates."

Swabs from Halbach's vehicle

In 2005, authorities used swabs to test the inside and outside of Halbach's vehicle in attempt to find DNA evidence to tie Avery to the killing.

Zellner's motion: Retest the swabs of the exterior door handle, the inside passenger-side door handle, the left battery cable, the right battery cable, interior door handle and exterior door handle.

Purple underwear

According to Zellner, a pair of purple panties were recovered from a white trailer in proximity to the Mercury station wagon where Halbach's license plates were recovered.

Zellner's motion:"Similar thong panties were recovered from the victim's residence. Mr. Avery is requesting to perform new and improved DNA testing on these panties to determine if they belonged to the victim and if they contain a male DNA profile."

Pelvic bones

One of the biggest mysteries surrounding the case is where Halbach died. Kratz argued that Halbach was chained to Avery's bedposts, raped, stabbed repeatedly, moved to Avery's garage, shot multiple times, and then set on fire in Avery's burn pit. Avery's trial lawyers Dean Strang and Jerry Buting suggest that Halbach's body was burned off-site at one of the nearby quarries. Reports show that Calumet County Sheriff's Lt. Kelly Sippel found bone and flesh in one nearby quarry on Saturday, Nov. 12. Another Calumet deputy, Joe Tenor, suspected he may have come upon human remains in one of the quarries while accompanying a team of cadaver dogs in early November 2005. "A total three out of the five dogs alerted to the area," Tenor said.

Zellner motion: Perform DNA tests on the suspected human pelvic bones recovered from the quarry property southwest of Avery salvage yard. If Zellner proves the bones belong to Halbach, the tests could shatter Kratz's murder trial theory that was used to convict Avery and Dassey of the crime.

Burnt material from Radandt's quarry

Around the time of Halbach's murder, authorities recovered what's been described as "burnt material" from Josh Radandt's deer hunting camp west of Avery's property.

Zellner's motion: Perform DNA tests to determine whether any of the burned debris confiscated from Radandt's deer camp contains evidence relevant to the murder.

Buccal swabs collected from Avery

In November 2005, Calumet County reports show, new buccal swabs were taken from Avery at the Aurora Medical Center in Two Rivers in the presence of Dr. Laura Vogel-Schwartz and registered nurse Fay Fritsch. According to trial testimony, the Manitowoc County Sheriff's Department may have also retained Avery's buccal samples, DNA and fingernail clippings related to his earlier wrongful conviction rape case.

Zellner's motion: "Mr. Avery is requesting to perform micro-trace testing of the buccal swabs to determine if there are any other materials or chemicals such as dirt on the swabs. If any material is present on the buccal swab, other than the DNA from Mr. Avery's cheek, Mr. Avery can prove that the buccal swab was used by police officers to deposit Mr. Avery's DNA on the hood latch."

Ballistics tests

Kratz argued Avery fatally shot Halbach multiple times while inside Avery's detached garage. In March 2006, Manitowoc County Sheriff's Detectives James Lenk and Dave Remiker were on hand when two previously undiscovered bullet fragments were found in the garage. Months previously, despite an extensive search by the evidence-collection team of Remiker, Colborn, Lenk and Kucharski, those bullet fragments were overlooked. At Avery's trial, Culhane testified she found Halbach's DNA on the newly discovered ammunition.

Zellner's motion: Conduct neutron activation analysis at the University of Massachusetts to compare the bullet fragment recovered from Avery's garage with the unspent .22-caliber shells that were previously seized from Avery's bedroom. "If different elements are detected, then it would refute the state's theory that (the bullet fragment from the garage) was shot by Mr. Avery with the Marlin Glenfield Model 60 .22 rifle through the skull of Ms. Halbach."

John Ferak of USA TODAY NETWORK-Wisconsin: 920-993-7115 or jferak@gannett.com; on Twitter @johnferak