(BY MR. LEONARD) If you would, step down there.

When we had the time out there, we were talking about digital manipulation, and you used pixelization and so forth.

First of all, can you just illustrate for us, sort of basic elements of a digitalized photograph?

It's extremely simple.

If these lines weren't so light, it would be perfect to explain it.

But in its most simple form, the entire screen of a digitized picture contains a series of items known as pixels, or picture elements.

Picture elements are exactly rectangular, be they square or elongated, into a rectangular form. And each one of those, although they're considerably smaller than this, represents a single pixel or picture element.

The total digital picture is made up exclusively of digital elements known as pixels.

Each one of these is assigned a value in color and density, color being, of course, the -- it's very obvious what it is; density being from something known as demin which is very thin or light or clear or white, to demax, which is dark gray, charcoal black, very dense.

Each of these elements becomes part of the overall picture.

The number of pixels determines the resolution of the overall picture. A lot of home computers will use 300 to 600, maybe as many as 800 dots or pixels per inch as its resolution.

Professional machines will go as high as 3,000 per inch or greater, so you get a far more photographic field to the end result. So for those of you who may have home computers, if you deal with -- with programs like Photo Shop or things of that nature, you know that when you look at the picture, it seems very choppy; they have things called jaggies.

Jaggies is, if you have a diagonal line that interferes and goes through the middle of a pixel, the computer has to arbitrarily decide whether it goes to this side or this side of it. And instead of getting a straight line, you end up with a slightly lightning shape or jagged line.

In ultra-high resolution situations of 3,000 lines or pixels per inch or better, you don't get the jaggies for two reasons: Number one, programs of that nature and sophistication, like computers, have programs that eliminate the jaggies and tend to smooth them out. The other situation, which is the obvious one thing I was trying to get to, is when you have many other things, they become less apparent to the eye, and you need a microscope to detect them.

Now, if you created a digitally manipulated photograph, and you wanted to hide that fact for whatever reason, is there a method you've just told us that it can -- it's -- you can discern these distinctive geometric pixel-like -- or pixels, rather, by -- under a microscope, correct?

In most cases, yes.

If you were going to digitally manipulate a photograph, and you wanted to hide that fact so that someone looking at the -- what purports to be the original negative, after the fact, can't tell that you digitally manipulated it, what could you do?

There are various steps you could do, one of which would be to throw it slightly out of focus, so that the edges would blur. There would no longer be sharp edges on the pixels.

Of course, if you'd use the maximum resolution, you could get it in the first place.

Well, by that, you mean you'd use that, what you describe as high tech, 3,000 pixels-per-inch-type machinery?

That's correct.

And then you'd throw it slightly out of focus, or you would use what's known as a dithering effect.

A dithering effect is part of a program that is included in things like Photo Shop, where they tend to average out edges or elements of each pixel, so it would disappear or be much less apparent.

Another way of dealing with it would be to create a high-resolution print and then rephotograph it on a piece of film, like 400 ASA film, or something that's very grainy, and if the grain is larger than the pixels, they'll disappear, they'll be covered up.

Just -- just go over that -- that point again. Let me make sure I understand.

You would create a high-resolution digital print using the more sophisticated machinery, so that you would have 3,000 pixels per inch, let's say.

Objection. Asked and answered. No reason to go over it again.

Overruled.

(BY MR. LEONARD) And then at that point, you would then take another photograph of that digitally created image; is that right?

That's correct.

And you would take the photograph with a -- what you said was a grainy film.

What do you mean by that?

Grain is an element of photographic film. The slower the film -- and this is a general rule -- the slower the film, 50 ASA, 32 ASA, 75, 100. Slower films have finer grain, much finer grain. What you're left with is -- let me demonstrate.

This arbitrary shape here is a piece of photographic grain, let's say. What you've got on film is a carrier, which is an acetate type of situation, variety of plastic of sorts. And what you've got is a coating on what's known as the emulsion side. And the emulsion side of the film has just a whole bunch like this.

Now, the slower the film, the finer the grain. In other words, it's less apparent. If you look at an 8 by 10 or 11 by 14 blow-up of a fine-grain print, it's very hard to see the grain.

But if you use a fast film, as you would -- say a sporting event, and you need to freeze the action, you need to be able to use a higher shutter speed, you use a faster film.

Well, the down side of the faster film is, it has much larger grain. And when you blow it up, it appears very grainy. It's as if you're looking through a screen or a mask.

Well, explain the relationship between the -- the larger grain and the pixels and to the extent, if any, that -- that might mask the underlying pixels.

Well, the nature of the grain itself, outside of being larger, also has a granular element to it. And if you are -- if you're showing a granular element over an already slightly blurred pixel area, it will mask it completely; you won't be able to detect it or see it.

Another situation is, if you were to print it nonphotographically, say in a magazine, using lithographing dots, the lithographing dots would be larger than the pixels, and they would totally mask it, as well.

Now, you can retake your seat.

Is this a good time to break?

We started at a quarter to.

Okay.

(BY MR. LEONARD) Now, when you're looking for occasions that a photograph is actually a composite or altered photograph, and you suspect that it's possible that the photograph could be digitally altered, how do you do that?

Is it sometimes extremely difficult to discern?

What do you mean by color balance?

There is a tinting that becomes apparent when -- I guess we've all seen it. I've seen it way too many times -- when you get your films back from the lab, they're either all a little bit too blue or too yellow or too pink, or something of that nature.

But, almost invariably, that color shift off of a normal neutral tone will be consistent throughout a row or series of rows, depending if they were all processed at the same time.

If a particular image has been reinserted after being manipulated from another source, there is no guarantee that that balance or that shift from what's called neutral, neutral density, ND, there could very well be a discernible color shift for the questioned photograph.

And again, that's because it was processed at a different time; is that right?

No. It could -- the final result would have been processed at the same time, but there would have been elements in the creation that created a shift in another direction that would override the general shift of the roll as it's processed.

Now, if you are creating a composite photograph, and you want to make sure that -- or attempt to make sure that you mask it -- in other words, you don't want anybody to find out that it's actually a composite; you wanted people to believe it's an original photograph or negative -- what is a -- what's a very basic thing that you have to do, keeping in mind that you're assuming that somebody's going to go back and look at the original negative, and not just the print?

And so you'd have to actually create a duplicate negative; is that right?

Objection. Leading. He didn't say that.

I wouldn't say it, anyway.

It wouldn't be a duplicate negative; it would be a copy negative that would be altered. It would not be a straight duplicate. Duplicate, using the dictionary term, means a straight copy. It would be a later generation, creation, and not actually a duplicate, per se. It would appear to be an original, but it would not be.

Okay.

Now, one more area of general testimony before we get into the subject photograph.

How do you -- can you explain -- if you need to use the board, you can do that -- how -- what's the process by which you create this copy negative?

Again, assuming that you have a composite and that you want to fool people, you want people to think that it's the -- actually the original negative?

There are a number of ways of doing this.

Again, this is hypothetical, because you'd have your choice. There would be a small menu of ways of dealing with it.

One thing you could do is, you could create the phony image that you want. Theoretically, I'd want it to be at the end of a roll, either the beginning end or the far end, one way or the other, so you don't have to match it within other elements.

And --

Well, when you say "match it within other elements," why don't you illustrate what you're talking about on the board?

Okay.

You can using a fresh -- (indicating to drawing paper).

Okay.

Standard rolls of film used to come in 20-exposure rolls and 36-exposure rolls.

We go on vacation, we buy film. We ask how many exposures. We want 24. Gives you less pictures, but it's the least expensive way to buy the film and less expensive to process. If you have a limited number of pictures you want to take of an accident, somebody hits your car, you get a smaller roll, maybe 12 exposures, something small.

That's not relevant for after this, but I thought I'd mention that.

On 35-millimeter film, the film comes in a canister, and the film is fed out of a light-safe-type of squeezing or sponge mechanism, and stretches out this way. (Indicating.) It's got something called a tongue at the end, and that's basically what you've got.

You have what invariably ends up being wasted leader at the beginning, which is light struck. That area which was outside of this in the first place is light by light. As you load it becomes useless it's called light striking. That's the technical term.

When you load it into a camera, that light-struck area usually gets stretched, so it goes over what is known as the frame aperture, and gets picked up by the pick-up reel on the far side of the camera.

You then close the back of the camera, advance it by using the cocking mechanism runoff and exposure, do it again. Usually, about the third time, you've cleared all of the light-struck area. What you're left with is the first actual frame of exposure.

Now, the easiest way to deal with a fake photograph, if you're going to use this particular type of technique, is to make it either the first or the last one. The reason that being is, if you're trying to match it to the next item, all you have to do is match it to one instead of two.

If it were to fall in the middle, between two other elements, you've got to match it to two of -- you've got to get it to register, to fit. It's got to fall in from exactly the right spot.

When you say match an element, can you explain that a little bit more?

Are you talking about lining up with the other negatives or the other frame?

Is that what you're talking about?

There are various elements: Exposure, density, color balance, and most basically, position. More than anything else, position.

If you were to use, say, two separate cameras to insert a digital frame, as opposed to the rest of it, which might be photographic frames, arbitrarily, to get it to fit, you've got to get it to fall in exactly the right spot on the film.

Between the frames, there is a spacing. On high quality cameras, that spacing should be either absolutely or very close to uniform in every single frame. On cheaper cameras, it may not advance quite as far. It might advance a little bit too far, and you won't get an even frame in between. What you'd want is, it to fall in as close to normal to where it should normally fit as if it were a legitimate frame.

You indicated space -- spacing -- sort of vertical spacing. I'll call it vertical spacing for purposes of this diagram.

There's also -- and that would be the spaces in between the two negatives or two frames?

That's correct. This would be the spacing in between.

There is also spacing or positioning of the frame with -- or the image with relation to the outer edge of the film, correct?

That is correct. The position away from the actual edge of the film itself, along the upper and lower edges of the film, are what is called sprocket holes. Those sprocket holes are the device by which the sprocket advance of the camera advances the film and pulls the next frame up and gets it to fall into the right position.

And it's -- there are, on a standard roll, standard camera, 35-millimeter camera, eight of these sprocket holes for every frame.

In motion-picture film, with half-frame film, it's four sprockets per frame.

So if you are going to try to create a false original negative, you would want to make sure that you have, for instance, the -- the false frame lined up exactly with the -- with the first of the real frames; is that right?

You'd have to -- you'd have to at least try; otherwise, it would be very easily detectable.

Now, you mentioned that you would -- there would be other things that would have to be in the register. I think you said color, exposure, things like that?

There are other -- there are other elements that you would need to match. Color balance, we've discussed.

Density is another issue, too. If you are trying to match your created frame, for want of a better term, to legitimate frames, you'd want the exposure to at least appear about the same as all those around the original, especially with an automatic exposure camera. Otherwise, the question is raised, why are the other frames off. You'd -- yours would be either too light or too dark. If yours is normal, those around it might be too light or too dark.

Okay.

You can retain your seat -- retake your seat, please.

Now, have you examined various materials in this case relating to the questioned photograph?

Yes.

Okay.

What materials have you reviewed?

I've reviewed two contact sheets, one containing the questioned frame, one that does not. I have looked at an 8-by-10 frame of the questioned frame, a print of the questioned frame. A print, an 8-by-10 print of the lower half, or approximately half of that questioned frame, and also two other frames from the two contact sheets or negative strips in question that purport to show Mr. Simpson.

Did you travel to Buffalo, New York to examine your -- what was purported to be the original negative of this photograph?

Yes, I did.

All right. Now would be a good time.

Thank you.

Ten minutes, ladies and gentlemen.

Don't talk about the case. Don't form or express any opinions.