I -- just to raise a minor point about the request for admissions, while we're having the jury come out.
These are similar to the set of request for admissions. I read in regard to the conventional serology test earlier, in a few of them -- actually more than a few, in many of them, there's in part of their response, there's a qualification as to time that we discussed in some motions earlier, your Honor.
That is: That they say in admitting this request for admission, the defense will adopt the plaintiffs' definition as communicated to the defendant at that point in time when an item was tested by an outside laboratory as opposed to the time of the collection or any other point in time. I'd prefer just to read that ones at the beginning of the request for admission or perhaps to have the Court instruct the jury that that's the point in time qualification, rather than read it in the answer to every single request for admission.
Similarly, in a few of them, they define the term "match" to be one that -- to mean cannot be excluded as a contributor as an evidence fragment. I'd just as soon read that.
The second point I'd like to raise, Your Honor, these all go to various items of evidence. Their listed by evidence item number. I'd like to put up the boards which list the evidence items numbers as I go through each session so the jury can follow along which evidence item this particular request relates to.
All these requests for admissions -- I went through them after lunch -- are cumulative as to what the three persons testified, Cotton, Montgomery and Sims. I'd like to form an objection.
I don't mind saving time. I would prefer that he read all the request for admissions and then we have the response read at one time so that it doesn't mislead the jury that we're admitting things when we have qualifiers.
I didn't understand your last sentence.
MR. P. BAKER: Okay.
In other words, if there's ten requests for admission in a row that have the same qualifier that he just read, for the request of admissions, then we read the one response instead of subtracting the qualifier and an just having it read as "admit" in front of the jury.
Okay.
To satisfy Mr. Baker's concern, you will read a qualification at the beginning. We can read all of the requests for admission and admissions at the conclusion. You may again restate the qualification that it applies to all of these admissions that were made.
Without having to read the qualifications every time, I think it will be pretty quick because the requests themselves are relatively short.
the defense will adopt the plaintiffs' definition as communicated to the defendant at that point in time when an item was tested by an outside laboratory as opposed to the time of the collection or any other point in time
I would prefer that he read all the request for admissions and then we have the response read at one time so that it doesn't mislead the jury that we're admitting things when we have qualifiers
you will read a qualification at the beginning. We can read all of the requests for admission and admissions at the conclusion. You may again restate the qualification that it applies to all of these admissions that were made