Would you read that back, please.

Yes.

(BY MR. LAMBERT) And, in fact, Dr. Blake is one of the leading developers of the PCR techniques?

Objection. Irrelevant.

Overruled.

With regard to forensic technology yes.

This is 291.

Now, Mr. Sims, Dr. Cotton has previously put on this board some frequency results based upon her DQ Alpha and polymarker test.

You see her frequencies up there?

Yes.

Now, the Department of Justice also did a DQ Alpha test on these particular samples, didn't it?

On number 46, yes.

Your number 5, yeah?

Yes.

And what result did you get?

The DQ Alpha result was 1.1, 1.2.

That's the same result that Cellmark got?

Yes.

In addition, however, the Department of Justice did a D1S80 test which Ms. Montgomery just testified to, and the results of that test are up on the board there; see that?

Yes, I do.

Now, taking that additional test into account, that is, taking it into account, the D1S80 test in addition to the DQ Alpha test and a polymarker test, what would be the frequency of all three of those tests combined?

The range -- I'll give it as a range -- again, is one in 240,000 to one in 2.2 million.

I'd ask you then to -- if you could, step down. Make sure we get the right end here.

Steve, you can help by erasing here, right there. And we'll ask you, Mr. Sims, to put the frequency in there.

(BY MR. LAMBERT) So, Mr. Sims, taking these three test results, the two from Cellmark and the one from the Department of Justice all into account, you would expect to find those DNA patterns in only one of 240,000 to one in 2.2 million people; is that right?

Your Honor, I'm going to object to erasing data from this exhibit which is now in evidence. He can put it in beside it, but I think he just erased something from the top.

I haven't moved this in; I'm developing this exhibit as I'm going along. I'll move it in when it's done.

Okay.

I object to it being erased.

Excuse me?

I object to it being erased.

Why?

Because it changes the exhibit.

He's changing the exhibit as he goes along.

He's taking things off.

There's nothing wrong with it.

It's not an exhibit.

It's been marked.

I thought it was offered.

It hasn't been offered, Your Honor.

Okay.

Let's go down to the next item number. Item number 48. Again, this is --

Excuse me. If you want to preserve it, why don't you go up there and make an overlay and write it down on your overlay? We'll give you that opportunity right now.

I have my own notes.

I'm assuming they're going to move that in.

Well, you can -- I've used an overlay before. I would like to not deprive you of the opportunity of showing the exhibit as it existed prior to that time that this witness changed it. So if you want to do that, you may.

That's fine. We'll let them do it the way they want.

May I proceed, Your Honor?

All right.

(BY MR. LAMBERT) Going now to item number 48, again, this is an item where the Department of Justice did a DQ Alpha test?

Yes, we did DQ Alpha and D1S80 on that item.

The DQ Alpha test result on that item was what?

1.1, 1.2.

That's the same result that Cellmark got?

Yes.

And again, you did a D1S80 test which Ms. Montgomery already testified to.

Can you put in the frequency, taking that test into account?

Okay.

The frequency is the same as 47: It's 1 in 240,000 to 1 in 2.2 million.

(BY MR. LAMBERT) Okay.

Now, on item number 49, that's not an item that the Department of Justice did any tests on?

We did not do any typing.

So the frequencies on those numbers should stay the same?

That's correct.

Let's take a look at item number 50.

It appears that the results you got there are the same as 47 and 48; is that right?

That's correct.

You got the same DQ Alpha test result as Cellmark?

That's correct.

Would you please change that frequency to reflect the D1S80 numbers.

Again, this will be 1 in 240,000 to 1 in 2.2 million.

(BY MR. LAMBERT) And now, finally, on item number 42, that is finally -- 52, finally, on the Bundy list of items again, you have both DQ Alpha and D1S80 results on that item?

Yes, we did.

The DQ Alpha results are the same as Cellmark's?

Yes; it's 1.1, 1.2.

Can you put in the frequency in the top panel there for the PCR base test.

Again, it's one in 240,000 to one in 2.2 million.

And then, now dropping down to item No. 115, which is from the rear gate of Bundy, you did your own DQ Alpha test there; is that right?

Yes, we did DQ Alpha on that and also D1S80.

And your DQ Alpha test resulted in?

Type 1.1, 1.2.

And the D1S80 Ms. Montgomery testified was 24, 25, those results, the DQ Alpha results and the D1S80 results together, who could be the possible source of those test results from among Mr. Simpson, Nicole, and Ronald Goldman?

Only Mr. Simpson.

Have you calculated the frequency for those two tests, the D1S80 and the DQ Alpha?

Yes.

Would you put that in, please.

The results for those two tests would be 1 in 520 to 1 in 1,400.

Now, the reason that the numbers for item number 115 are different than, say, item number 52, is that explained by the fact that the more genetic markers that you're able to test, the more the frequency can become less common?

Yes.

Objection. Leading.

Sustained.

(BY MR. LAMBERT) What's the explanation of the difference between the 115 and, say, number 48?

Basically, the more genetic information you're getting, the more types you're looking at, then the rarer that whole profile becomes.

Let's take a look at item number 116, the rear gate. That appears to be the same as 115?

That's correct.

Would that be right? So the numbers and Mr. Simpson would be the same for that?

That's correct.

Would you please put in the numbers for us there.

Again, it's 1 in 520 to one in 1,400.

Now, finally, on this board we have item number 117 the rear gate.

From the rear gate, I see you have both a DQ Alpha and RFLP results; is that right, sir?

That's correct. We did DQ Alpha, D1S80 and we also did a nine-probe match for the rear-gate sample.

Would you explain what you mean by "nine-probe match?"

When doing RFLP, we looked at nine different loci. In other words, we produced nine different Autorads at different sides of genetic information take's all nine matched Mr. Simpson's types.

So would you put the frequency in for the RFLP calculation for this item number 117.

That last item, the item from the rear gate, because you got a nine-probe match on that item, the frequency, would you call that a rare frequency?

And the fact that you were able to get an RFLP result off of that particular evidence item, why could you get it off that, why not off of 115 or 116?

There was less DNA recovered in those stains, 115 and 116. 117 had about a little over 100 nanograms, which is sufficient for an RFLP.

And was that particular evidence item degraded or undegraded?

Do you recall what the state of degradation was?

There was only slight degradation indicated in that sample.

And is there a reason why an evidence sample that's found in one location, say on a gate as opposed to another location, say on the ground, may be more or less degraded?

Yes. It's certainly important how -- what the micro environment is where a stain occurs.

For example, if it occurs on a walkway, where there's a lot of soil and that sort of thing, one may expect to see some differences from a sample that's not in contact with as much dirt and soil, debris, that sort of thing. The collection and processing can make a difference too.

So the fact that there's more DNA on an evidence item found up on a gate, as opposed to something on the ground, is that a surprising result, from your perspective?

No.

Okay.

Why don't we take the next board. This will be number 296.

(BY MR. LAMBERT) Now, this board lists four different evidence items from the -- collected at Rockingham. The first one, number 6, is from the Rockingham driveway.

Did you do any DQ Alpha tests on that evidence item?

Yes, our laboratory test did that for DQ Alpha and D1S80.

And Ms. Montgomery testified to the D1S80 result. What are the DQ Alpha results?

1.1, 1.2.

Who would be the possible source among the three we're looking at here, be a possible source for those evidence items?

Mr. Simpson.

And could you once again put the frequency for those two tests in.

Frequency for that result would be -- the range would be one in 520 to 1 in 1,400.

Okay. I think that's the only one we have on this, chart. So let's move to the next one, which is number 293.

(BY MR. LAMBERT) Now, there's a lot of evidence items to go through on this.

The Department of Justice tested a lot of samples from the Bronco automobile?

Yes, we did.

Let's start with number 24 from the instrument panel. Did you do a DQ Alpha test on that?

Yes, we did.

And what was the result?

On number 24, which was our item number 15, the DQ Alpha type was 1.1, 1.2.

That's consistent with who?

Mr. Simpson.

And could you put the frequency in for that one test for Mr. Simpson on item number 24.

Yes, I can. This is just a DQ Alpha result, so it's one in 12, to one in 40, is the range.

And for these items here, where we just have D1S80 results 25 and 26, numbers 25 and 26, are those both consistent with Mr. Simpson as a possible source, as well?

Yes, they are.

And did you calculate what the frequency would be for those two?

Yes, I did.

Would you please do so.

For the number 25, that range would be -- check for a second.

That's where we have a type 1.1, 1.2, Also a 24, 25 result, so the range would be 1 in 520 to 1 in 1,400. Where we have just the D1S80 result of type 24, 25, that would be one in 29, to one in 48.

And then while we're here, let's take a look at item number 30 from the center console.

Did you do a DQ Alpha test on that item?

Yes, we did.

And what was the result?

That was type 1.1, 1.2.

Tallying the DNA and D1S80 results for that type, who is a possible source for that particular item?

That would be Mr. Simpson.

And what would the frequency for that item be?

Again, this is where we have the DQ Alpha and the D1S80, it would be one in 520 to one in 1400 or 1,400.

Evidence item number 31, did you do a DQ Alpha test on that?

Yes, we did.

And what results did you obtain?

That -- excuse me. The sample No. 31, which is our 18, we obtained a mixture result. The DQ Alpha indicated the type 1.1, 1.2, along with the weaker typing of 1.3, comma, 4.

And because of that mixture, who would the possible sources be of that evidence item?

The possible sources would be Mr. Simpson, and also Ronald Goldman.

And then let's drop down to -- now to number 34.

The Department of Justice do a DQ Alpha test on that item?

Yes; that was our item number 20. And we did just the DQ Alpha test on that.

The result was 1.1, 1.2.

Which is, again, consistent with who?

Mr. Simpson.

Would you put the frequency in for that item?

This is DQ Alpha only. It's one in 12 to one in 40, type 1.1, 1.2.

Let's drop down to item number 303, the center console.

Did you do a DQ Alpha test for that evidence item?

Yes, we did.

And what results did you obtain?

Yes. This was our item number 52.

We obtained a DQ Alpha result with 1.1 was present, possible 1.2 allele a 1.3 was present, and also a 4 was present on DQ Alpha.

Based upon that DQ Alpha test and D1S80 test, who would be the possible source?

Because of the D1S80, it's always 24, 25, with a weaker 18.

All three principals were potential contributors to that blood.

Evidence item 304. Could you describe your DQ alpha results on that, please.

Yes. That was DQ alpha type 1.1, with a possible 1.2. 1.3 was there, also 4. The D1S80 was 24, 25, with a weaker 18.

And again, the possible sources for those results would be?

Again, the three principals are potential sources for that mixture.

And then evidence item number 305 from the center console, what were your results on that test?

In that case, it was 1.1, possible 1.2, then a weaker 1.3 and 4.

And then on the D1S80, it was 24, 25 and weaker 18.

And possible contributors again on that would be?

Again, the three principals are possible contributors.

These items, 303, 304, and 305, all tests from the center console, were those all mixtures of more than one person's blood?

Yes, they were, stains.

And finally, did you do anything with those three evidence items as a group?

Yes. What I was able to do, because individually these samples had relatively low amounts of DNA, but they did have enough combined to make an RFLP typing feasible, I proceeded to combine all of them.

In other words, the extracted DNA, I combined all of that, did an RFLP analysis on that, and then probed it.

We have four-probe RFLP analysis on that sample.

What did that four-probe RFLP analysis tell you about the possible sources of that blood?

So the possible contributors under that RFLP test are these two individuals?

Yes, Mr. Simpson and Mr. Goldman.

Thank you.

Why don't you have a seat.

Before we leave the Bronco automobile, let me ask you about one of the other items there; that is item number 29.

Did you do a DQ alpha test on item number 29?

Yes, we did.

And what results did you get from that DQ alpha test in item number 29?

In item number 29, which I believe is a steering wheel, we got a type -- main type of 1.1, 1.2, which was consistent with Mr. Simpson, and we also detected a weaker 4 allele by itself.

And did you make any conclusion as to who among these three could possibly be excluded, based upon that test?

Well, as far as the exclusion, certainly the 1.1, 1.2 is the major type, is consistent with Mr. Simpson.

The 4 allele was identified as being present.

The 1.3 of Mr. Goldman was not seen in that particular sample.

My opinion was that this appears to be an exclusion of Mr. Goldman, but I could not be absolutely certain because of some of the technicalities of this particular case that we may not -- we, at the very low level of DNA, we were looking that, potentially, we would lose one of Mr. Goldman's alleles or one of his dots, basically, but I should point out there was no evidence of the 1.3.

So that was somewhat an ambiguous result, was it?

Yes, I would describe that as an ambiguous result, as far as that was concerned.

Okay.

Why don't we have the next board.

This is Exhibit No. 320, Your Honor.

(BY MR. LAMBERT) This board lists results of tests by the Department of Justice on the Rockingham glove. Renee Montgomery already testified to some of these test results.

Mr. Sims, it appears that a significant number of tests with were run on the glove; is that true?

Yes, they were.

Let's just then go through them, if we can.

On item number -- what you call this is your nomenclature, G1?

Yes. "G" is for Gary. So that was my stain number one.

Okay. So G1 is one of the stains on the glove?

That's correct.

And for that particular stain, did you do a DQ alpha test?

Yes, I did.

And what were your results from that test?

On that particular test, it indicated a mixture with a type 1.1, 1.3, a 4, and then also a possible 1.2 allele.

And then I see you also were able to obtain RFLP results on that particular item.

Yes. I looked at an RFLP on three of those; we did an RFLP; then a fourth one, we did an RFLP by itself.

And the possible sources of people, pursuant to your tests for this particular item, are who, sir?

And in your five-probe RFLP test results, were you able to see the bands matching both Nicole Brown and Ronald Goldman?

Yes. It was consistent with a cross -- with a mixture of DNA from Nicole Brown and Ronald Goldman on that sample.

So for that particular sample, then, you have both a five-probe RFLP test, a DQ alpha test, and a D1S80 test that are all consistent with the blood coming from Nicole Brown and Ronald Goldman?

That's correct.

Now, item area G2, could you describe your DQ alpha test results there.

Yes. That was, again, a mixture, 1.1, 1.3, 4, and then possible 1.2.

And you were also able to do an RFLP test on that?

Yes. Again, we saw that same type of person, indicating a mixture consistent with Nicole Brown and Ronald Goldman.

And the RFLP test is a test that is a powerful test for identifying people, isn't it, sir?

Yes, it is.

And if you have five-probe matches, is that a substantial match, in your opinion?

Yes.

Now, let's go to -- we've already done this one.

Let's go down to area G4.

And can you tell us what your results were there, sir?

On G4, The DQ alpha again indicated a mixture, 1.1, 1.3, 4, and then possible 1.2.

And once again, were you able to type an RFLP result on that evidence item?

Yes, I was.

And the possible sources for that item of evidence are who, sir?

Ronald Goldman and Nicole Brown.

And were you able to, at all five of those genetic markers that you probed, able to see the banding appearance for both Ronald Goldman and Nicole Brown?

Well, what was interesting especially, was that we looked at G1, G2 and G4, across one auto series of Autorads, and it was apparent that the bands that could be attributed to Ronald Goldman were fairly constant in intensity across the Autorads, whereas the bands that lined up with Nicole Brown's bands tended to fade out, going from G1, being the stronger, a little weaker for her at G2, and then weak at G4.

Did you draw any conclusion?

Yes.

What conclusion did you draw?

Well, I think given that you could see the relative contributions, it was highly significant that this was a very clear -- clearly consistent with the mixture of the two.

In other words, you could figure out which band could go to which individual.

And let's go to area G9.

You obtained some DQ alpha results there, as well?

Yes, I did.

And what were those?

Again, that was a mixture of possible -- possibly a mixture. I saw on DQ Alpha we had a type 1.3 and 4 present. There was a possibility of a 1.2 allele and a possible trace of a 1.1 allele.

And the possible contributors to this evidence item, then, that you were able to ascertain, would be who?

Well, looking at that result with the D1S80, as well as the DQ alpha, we could only say that it -- with some confidence, that it was consistent with Ronald Goldman.

Even though you had a possible 1.2 in this, you wouldn't conclude that there's another possible contributor among the three?

Yes. For example, with the possible trace 1.1, we would need a clear 1.1 and some more information on the D1S80 to attribute it to either Nicole Brown or Mr. Simpson.

And now taking evidence item G10 from the Rockingham glove, what were your results there?

On that one, again, it was a 1.3, comma 4, possible 1.2, and then a weaker 1.1 allele was detected.

On the D1S80, we've already heard, were a 24 and a weaker 25.

Yes.

So the possible sources on that particular item would be who, sir?

Ronald Goldman, and then Mr. Simpson, also.

I think we've covered all of these.

Yes.

Yeah. Don't we have the next one?

What number was that, was that last one?

The last one was 320, and this one is 297.

(BY MR. LAMBERT) Now, Mr. Sims, did you receive a pair of socks that were found in Mr. Simpson's master bedroom floor and marked Exhibit 13?

Yes.

Or evidence item 13?

Yes.

Do you recall about when you received those?

Yes. The socks were received on September 26, 1994.

And they were sent to you for what purpose, sir?

At that point in time, LAPD had detected and analyzed some of the blood stains present on them, and we were asked to do DNA typing on those blood stains.

And when you first got the socks, sir, did you examine them?

Yes, I did.

What did you observe in your initial examination?

In the initial examination of the socks, in a large -- relatively large stain had been cut out around the ankle area of one of the socks.

There was also on that same sock, a -- on the opposite side of that stain, there was an area indicated with a white arrow. Then there was also on the other sock, there was an area that had been outlined previous to my examination.

And did you then do any further examination of the socks after looking at them?

Yes. I examined the socks. First I photographed them to document what was present. And in the process of photographing those socks, and under very bright camera lights, photography lights, I noticed that there were additional stains on those socks.

At that point, then I later did some stereomicroscopic examination of the socks and determined there were a lot of very small blood stains on those socks.

And were those blood stains that you had not seen with your naked eye before you did the stereomicroscopic examination?

That's correct. These very small ones I did not see with my naked eye.

And was Dr. Blake with you when all this happened?

Yes, he was there at the time we initially examined the socks, and he was there for some of the later examinations.

And then did you do DNA tests on the socks?

Yes, we did.

Let's start with the one up at the top here, which is your number 42A-1.

Did you do a DQ alpha test on that one?

Yes.

And I should point out, that is the large stain (indicating), and LAPD had previously cut out some of that stain and submitted that to me in a tube, along with the socks themselves.

So you tested what you got in the tube from LAPD?

That's correct, for that particular stain only.

Your DQ alpha result was what?

That was type -- we typed it as type 1.1, 1.1.

And that's consistent with who?

Nicole Brown.

And were you also able to do an RFLP test on that particular evidence item?

Yes, we were able to obtain an 11 probe match on that particular item.

11 probe match. Is that a significant match?

Yes, it's very significant.

Can you please put in the frequency numbers for that 11 probe match on that particular evidence item.

And would you describe that as a rare occurrence, sir?

Yes, I would.

Okay. Now, let's take number 42A-2.

What was your DQ alpha result there?

Yes, the DQ alpha result was 1.1, 1.2.

And who's a possible source identified for those particular types?

That would be Mr. Simpson.

And did you do a calculation for the frequency of those two types, counting the D1S80, as well?

Yes, I did.

Would you please put that --

That number is 1 in 520 to 1 in 1,400.

Now, let's go to evidence item number 42A-3.

What was your result on that item, sir?

The DQ alpha type was 1.1, 1.2.

Again, who would the possible source be under the DQ alpha and D1S80 tests?

Mr. Simpson.

And on that evidence item, were you able to obtain RFLP results, as well?

Yes, we were.

And we have on the board here a nine-probe match.

Is that consistent with your recollection?

Yes, that was a nine-probe match.

Is that a significant match, sir?

Yes, it is.

Can you put the frequencies up on the board for the nine-probe match on that evidence item.

Again, this is just for six of those nine.

The numbers come out to be one in 57 billion to one in 150 billion.

Would you describe that as a rare occurrence, sir?

Yes, I would.

Now, could we go to evidence item number 42A-4.

What were your test results there?

The DQ alpha was 1.1, 1.2.

And the D1S80, we already heard from Renee Montgomery.

Who would the possible source of that be?

Mr. Simpson.

And would you put the frequency number in for that item, as well.

Yes. This would be one in 520 to one in 1,400.

Now, we're down to number 42B-1.

And would you tell us what the DQ alpha results were there.

The DQ alpha result on that case was a type 1.1, 1.1.

We also thought there might be a possible trace of a 1.2 allele.

The possible source for that, without regarding that, the 1.2, would be who, sir?

Well, again including the D1S80 results, that would be Nicole Brown.

And the possible trace of 1.2, were you able to include anyone as a possible source based upon that?

Well given -- given that I couldn't really say it was there, I wouldn't make anything on that -- out of that result, that possible trace.

And then finally, on this chart, we have item -- your item 42B-2.

What are your results on that, sir?

On 42B-2 was the same, 1.1, 1.1 DQ alpha, possible trace of the 1.2, and the D1S80 was 18, 18.

Because there was only a possible trace, you wouldn't include that in your characteristics of the possible sources for that item?

That's correct; I would look at D1S80 results, too.

So did you put frequency in for that item, just 1.1 and the 1.1 and the 18, 18 D1S80 results?

Yes, for D1 and D2.

Would they be the same?

Yes, they would be the same.

Please?

They're both one in 990 to one in 8,900.