You may proceed.

Thank you, Your Honor.

Why don't you put that back up, please.

Mr. Matheson, we were talking before about this console in the Bronco that you collected blood on. I wanted to be sure, because of our technical problems, that we made this point clear.

Would you point out on this television screen here the items of evidence which you collected from this Bronco console.

There are four separate areas where I collected blood off the console: This one was marked 303; 304, which is a stain that covers this area here; 305, down in the lower right-hand corner; and then 306, which appears it could be an extension of this stain, but went ahead and collected it as a separate item.

Of these items that you collected, which were the ones that appear to you to have previously been swatched in a prior collection?

What I have marked as 303, the area up on the console lid here, and 304 on the right-hand rear side.

And could you tell from looking at them that someone had previously collected from those items?

That's correct.

When you did this collection in your laboratory in serology, who else was present?

I don't have the complete list with me. I was present; there were people that were coming and going, some of the attorneys, that type of thing.

But in addition, as far as technical-type staff, there were a Mark Taylor and Larry Ragle that were working for the defense that were observing and assisting on this.

Those were Mark Taylor and Larry Ragle were experts look working for Mr. Simpson?

Yes.

They were there watching you do this collection?

That's correct.

And the evidence items that you took off this, you then did what with them, sir, the things that you took off the Bronco console?

Well, they were collected on swatches, which is the way we collect blood samples, are allowed to dry, package up in the bindles like what you saw in one of the previous photographs from the carpeting area. You do the same thing with any small type of evidence.

The items placed in the bindle; the bindle's closed up, sealed, marked as to where it came from, the time and the initials of who did it. They're then packaged and booked into -- or placed into our property division.

Now, you mentioned when you were talking about the June 29 meeting where you made the list of all the evidence items and what you were going to do with them in the future, you mentioned the word "triage" in connection with that.

Can you explain to us what you mean by "triage?"

Well, I believe it's mainly a medical term. It has to do with doing the most important things first. Best example would be if there's a big accident where you have a number of victims, obviously not all of them can be dealt with at the same time; they go through what's called a triaging program, where they decide who is the most injured, work them first, and then go on down the line.

I used it -- There were many evidence items associated with this case.

We don't have the resources to analyze every item first, so you do a triaging system; you go through, figure out -- or make the best guess as to what you think are the most important items there that are going to yield the most important information first. Eventually, as time and resources become available, you come in and finish up the rest of the items.

And that's what you were doing that day with these evidence items in this case?

That was part of it, yes.

Now, let's talk a little bit about serology at SID.

You have been involved in serology there for some time?

Yes, since August of 1981.

And prior to joining SID, what was your educational background?

Well, I got a degree, bachelor of science degree in criminology from the California State University at Long Beach, and at the time completed the course requirements for a bachelor of arts degree in chemistry, though I never received that degree.

And since the time that you joined SID, have you been actively involved in serology work, at least since the time you went into the serology department?

Yes. Like I said, I started in June of 1978.

In August of 1981, I was transferred into the serology unit as a criminalist. At that time, I started learning the techniques that are specific to our laboratory, and worked as a criminalist within that unit doing case work: Homicide, sexual assaults, analyzing body fluids, until about May of 1989, when I was promoted to supervisor of that unit.

And for how long were you the supervisor of the serology unit?

Well, of just the serology unit, I was a supervisor for about three years. At a point approximately three, three and a half years later, one of our other supervisors resigned and I was given a couple of additional units.

Like I mentioned, at the time in June of 1994, I not only supervised serology, but our trace comparative unit, which does hairs, fibers, that type of thing, and the field unit, which is the criminalists who go out and collect evidence from the scene.

In terms of serology, what type of testing is done in the LAPD serology department?

Well, there's a number of different type of techniques. They can be broken down into two main groups that we've started calling conventional serology and then DNA analysis.

To touch real quick on the DNA, there's a couple different types of analysis there, an awful lot of initials: One of them goes by the initials PCR, one by RFLP. Our laboratory only does PCR-type of DNA analysis.

In terms of conventional serology, could you describe a little bit more what you mean by that?

Sure. Conventional serology is what I mainly worked as a criminalist, or did work as a criminalist in that area. It's the conventional or the serological type of test that's been used in a variety of different disciplines for many, many years.

The best example of conventional serology would be ABO blood typing used in hospitals a lot for transfusions. Everybody has an ABO type; they're either type A, type B, type AB or type O. You fall into one of those four categories.

That is one of the systems or genetic markers that we use in conventional serology to try and make an association or an elimination between a person and a blood stain or a semen sample.

In addition to the ABO, which has been around for decades, there are techniques that involve enzymes. Enzymes are nothing more than another chemical that's in your body similar to the ABO type, of which you have certain types that we can put into groups.

An example of that is one of the enzymes that we look at goes by the initials ESD -- it's a fairly long name; that isn't particularly important. But you are either an ESD type 1, type 2, or type 2/1; you fall into one of those groups. And you are the same type from the time you're born until you die.

Is there also a conventional serology typing called the PGM type?

Yes, there is. That's one of the other enzymes that we look at.

Okay. Is it similar to the ESD type?

It is similar in that it's an enzyme; it performs a function in your body. We can break it down either into a type 1, type 2, or type 2/1. Then you can do one additional step which breaks those three down into what are called sub types, or about ten different possibilities, rather than just three.

So all of us have one of those ten different sub types?

Yes.

Is there also an EAP type that you're familiar with?

Yes.

And what is that?

Again, it's just another enzyme that performs a function in your body, exists in a few more types. The examples being you're either type B, A, C, A, BC, A. I mean, it's a combination of letters. But each one of those designates a type, just again like in the ABO blood-type system, you have a type from --throughout your life.

And are all these conventional serology systems separate and apart from DNA testing?

They're separate, in that you're testing for the enzyme itself, or in the ABO group the antigens and the antibodies. They are different tests and you get typed. They are connected in a way, and all of them are based on your DNA.

But if a person has a particular one of these types, that doesn't necessarily mean what their DNA profile is going to be, does it?

They are independent from the DNA markers that we look at in forensic science.

Okay. Looking at these -- These four conventional types that you've described, is there any way of determining how common or uncommon a particular blood type is in the population, generally?

Yes.

And how do you do that?

Like I mentioned, you have a blood type that is yours from the time you're born till the time you die. By analyzing samples, you can find out how much of a percentage of the population has a certain type.

For example, going back to the ABO blood typing system, approximately half of the population -- a little bit less than that -- but approximately half of the population is ABO type O.

The next most common is A, then B, then AB.

Within our laboratory, we've been doing this conventional type of serology since we started the enzymes, I believe in 1977, but we've been doing the ABO a lot longer. We store the information on all of the victims and suspects that we've gotten. We do a blood sample that comes in on somebody; we record what their types are. And over the years, we've kept a chart and we know what percentage of the population in the City of Los Angeles, among victims and suspects, is a type O, type A, type B, or type AB.

And is it possible that if you know all four of these different blood types we've been talking about for a particular person or evidence sample, to determine how common or uncommon it would be in the general population to have that combination of all four types?

Yes.

And how do you go about doing that?

Well, it's something called a product rule. It's just as simple as you take the percentage of a type in one marker, like, let's say an ABO type, we know that possibly half of the people in this room would have that type; that is type O.

Then you go on to another marker and say -- let's see: We've used ESD -- excuse me -- as an example. Let's say approximately 50 percent of the population is a type 1. It's actually higher than that, but for simplicity, let's stay with that.

If we have a stain that I know is ABO type O and ESD type 1, we'd multiply 50 percent by 50 percent and come up with about 25 percent, so we'd know now that approximately 25 percent, or one out of every four people in this room, would have a combination of a type O ESD 1. And you just keep doing that with each additional marker. You get a little bit more information, it narrows down the pool of people that could have left a stain.

So if a person has an ABO type A, an ESD type 1, a PGM type 2 plus, 2 minus, and an EAP type BA, could you tell us how common in the population would be the combination of those four blood types?

By taking each of those pieces of information, determining the population or the percentage for each marker, and then multiply them together, that combination of four comes out to about .17 percent of the population. Or to put it in a little bit more understandable terms, approximately one out of about 550 to 570 people would have that complete combination of types.

So in this case, evidence on the item 49, which was one of the blood drops found at Bundy, had an ABO type A and ESD type 1, a PGM type 2 plus, 2 minus an EAF type BA, how many people out of the population could have been the person that left that blood drop there?

And if Mr. Simpson had those same four blood types, would he then be one of those, one out of 550 people who could have left that blood type?

Objection. Argumentative.

Overruled.

Thank you. I have no further questions.