📄 Direct examination of Dr. Werner Spitz (part 4) — Friday, November 8, 1996
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▲ Day 12 of 57

Direct examination of Dr. Werner Spitz (part 4)

Witness: Dr. Werner Spitz
Examiner: Edward Medvene
Called by: Defense • Date: Friday, November 8, 1996 • Utterances: 86
Dr. Spitz's direct examination concludes with a foundation dispute over a textbook photo of fingernail marks from a strangulation case, which the judge ultimately excludes. With the jury present, Dr. Spitz corrects his own earlier error about which part of Simpson's hand bore the gouges, identifies additional fingernail marks on Simpson's left hand, testifies that such marks don't necessarily leave skin under the assailant's nails, and confirms no marks are visible in a pre-recital photo of Simpson taken before 7:00 p.m. on June 12th.
1 (The following proceedings were held in open court, in the presence of the jury.)
2 THE COURT:

There's an objection pending.

3 MR. MEDVENE:

If the Court please, the picture was taken under the supervision of Dr. Spitz, and results from a strangulation case where the victim supposition would have acted in a similar way. That's our foundation, Your Honor.

4 MR. BAKER:

I don't think that's adequate foundation.

Number one, under 721 of the Evidence Code, he cannot be examined, and his supposition is pretty loose; and,

Number two, his supposition as to how somebody was struggling is exactly the same supposition he's made here today. I don't think that's appropriate foundation for either supposition.

5 THE COURT:

You may inquire.

6 MR. MEDVENE:

Do it now, sir?

7 THE COURT:

Well, yeah, before the jury comes in, so I can decide.

8 MR. MEDVENE:

Yes, sir.

9 Q:

(BY MR. MEDVENE) Dr. Spitz, with respect to the picture, could you tell us what part, if any, you had in the taking of that picture?

10 A:

Your Honor, I was the chief medical examiner. And the picture -- we had a photographer -- two photographers, actually and the photographer would take pictures of deceased people at my direction. And I would tell the photographer what I wanted photographed, how I wanted it photographed; and what he would do is focus and pull the shutter.

11 THE COURT:

Okay. Further foundation as to its relevance?

12 Q:

(BY MR. MEDVENE) And the particular victim, or the particular hand that was photographed, what was the event that encompassed the injury on the hand?

13 A:

This is a strangulation case, where an assailant had his arm around the victim and strangled her.

14 MR. MEDVENE:

That's our foundation.

15 Q:

(BY MR. MEDVENE) What does the photo intend to illustrate?

16 A:

Well, you see, this is a textbook, and it's meant to depict typical injuries for students of this discipline, and so, depicts a typical type of a fingernail mark.

17 Q:

And?

18 A:

Fingernail marks may be difficult to diagnose, especially for somebody who is learning the profession.

19 Q:

And what is the similarity, if any, between the photograph of a different person and the marks that you described on Mr. Simpson's finger?

20 A:

Well, I think there is considerable similarity.

21 Q:

If you want, we can put it back up.

22 A:

Well, I know what it shows, but I think there is considerable similarity.

Fingernail marks may have different configurations. Some fingernail marks look this way; other fingernail marks look differently. And this fingernail mark, or the fingernail marks on the picture in question, are very much like the fingernail marks in question here. They are ragged; they are jagged; they are the same similar size. I mean, everything about this is the same.

23 MR. MEDVENE:

May I approach, Your Honor?

24 THE COURT:

You may.

(BY MR. MEDVENE) I place before you -- oh, I'm sorry.

25 (Defense counsel reviews book.)
26 Q:

(BY MR. MEDVENE) I'm placing before you, your book, Medicolegal Investigation of Death, third edition, in particular page 265.

And could you tell the Court the heading and the purpose.

27 A:

The -- what do you mean by "purpose?"

28 Q:

The purpose of those photos.

29 A:

Oh. The purpose of the photos is to show fingernail marks resembling gouges, as the caption indicates, on victims' wrists, indicating a struggle had taken place. The struggle in this case was a struggle to get a hand off somebody's neck.

30 Q:

And are those the photos that we put on the board --

31 A:

Yes.

32 Q:

-- on the monitor?

Is that one of the photos?

33 A:

One the photos, yes.

34 Q:

And are you using it just for an illustrative purpose?

35 A:

That's correct.

36 MR. MEDVENE:

That's our foundation.

37 THE COURT:

Well, the foundation is, I think, still lacking as to how this witness determined that the photograph that he had his photographer make shows fingernail marks.

38 Q:

(BY MR. MEDVENE) How do you know it's a fingernail mark?

39 A:

Well, for several reasons.

First of all, it looks like fingernail marks.

Secondly, there is no other type of trauma.

Thirdly, we know how the strangulation occurred. I cannot, as I sit here, tell you whether the police found other evidence that would be corroborative or not, but there is no question in my mind. I would not have put it in the book as a typical case if it weren't a fingernail mark.

40 THE COURT:

On that basis, I think foundation is lacking.

Sustain the objection.

41 MR. MEDVENE:

All right, Your Honor.

42 THE COURT:

Bring the jury back.

43 MR. BAKER:

Your Honor, on the basis of what was just related, I would move to strike all of his opinions from the testimony relative to what are fingernail marks.

He obviously relied on what's in his book. There's inadequate foundation to show those are fingernail marks. I move to strike all of his testimony relative to his opinions concerning the cuts on Mr. Simpson's hands being fingernail marks.

44 THE COURT:

That motion is denied.

This witness is testifying as an expert. Whatever experience and basis on which he formed those opinions, subject to your cross-examination, will simply go to its weight.

45 (Jurors resume their respective seats.)
46 (The following proceedings were held in open court, in the presence of the jury.)
47 Q:

(BY MR. MEDVENE) Dr. Spitz, before the break, I inadvertently, on 2164 -- that's number 8 -- showed you a picture, and I believe I referred to it as a finger.

48 MR. BAKER:

I object, Your Honor. He did not refer to it as a finger.

49 MR. MEDVENE:

Well.

50 THE COURT:

Overruled. Just start.

51 MR. MEDVENE:

Okay.

52 Q:

(BY MR. MEDVENE) Could you tell me, did you have an opportunity, Doctor, to look at 2164 -- that's number 8 -- at the break?

53 A:

Yes.

54 Q:

And could you just -- whatever I called it, could you tell me what it is?

55 MR. BAKER:

I object. He didn't call it anything.

56 THE COURT:

Overruled.

57 DR. WERNER SPITZ:

The error was mine.

I attributed the gouges on the web side of the hand, and it is the opposite side of the hand, two gouges on the side of the little, pinky finger.

58 Q:

Okay. And?

59 A:

And they show -- you see the edge of the -- of a bone here, and under the skin, a little, white tissue area.

60 Q:

Can you see the whole hand from the picture?

61 A:

No, you cannot. That's where I made the error, because it's too close.

62 Q:

Place on the board number 2, I believe, from 715, and ask if you would please put it on the screen.

63 (Photo displayed.)
64 Q:

(BY MR. MEDVENE) This is Mr. Simpson's hand, discussed yesterday by Dr. Huizenga.

Can you tell the jury rather, the Court, if you see any marks on Mr. Simpson's hand?

65 A:

Yes, I see marks. I see little -- a row of little superficial injuries, drying injuries on the back of the left hand, in proximity of the middle knuckle, and at least one additional one there.

66 Q:

Can you please circle them on the copy in front of you and initial them.

67 (The witness complies.)
68 MR. MEDVENE:

Exhibit 2165, Your Honor.

69 Q:

(BY MR. MEDVENE) Can you give us your opinion of the cause of those marks?

70 A:

These are my view of fingernail marks, too.

71 Q:

Why? What causes you to say that?

72 A:

These are little superficial gouges. And the reason that there are many is because they're skipping; the movement caused the hand of the individual in collecting these, to skip from one to the next, to the next, to the next. And here on the other one, it didn't skip.

73 Q:

Dr. Spitz, in your opinion, would one that causes fingernail marks on another individual necessarily have that other individual's skin underneath their nails?

74 MR. BAKER:

Leading. Suggestive.

75 THE COURT:

Sustained.

76 Q:

(BY MR. MEDVENE) Do you have an opinion whether or not the person who received the fingernail -- excuse me -- do you have an opinion whether or not the person who caused the fingernail marks would necessarily have skin underneath their nails?

77 A:

No.

78 MR. BAKER:

Leading. Suggestive, as well, Your Honor.

79 Q:

(BY MR. MEDVENE) Why not?

80 A:

Well, because in the case of gouges, there's a substantial amount of skin. The skin, many times, remains suspended on the individual on whom the fingernail mark is.

It remains suspended; it does not get any blood; it dries up and falls off in a day or two.

81 MR. MEDVENE:

Would you put on the board 826, please.

82 Q:

Doctor, I show you a picture that's been previously marked. It's of Mr. Simpson somewhere prior to -- I believe the facts are somewhere prior to 7:00 p.m. on June the 12th.

I ask you to look at that picture.

If we can narrow it down or get a close-up of Mr. Simpson's hands.

83 (Photo displayed.)
84 Q:

(BY MR. MEDVENE) Do you see on Mr. Simpson's hand in this picture, taken sometime on the 12th before 7:00 p.m. at his daughter's recital, any of what you have identified as the fingernail marks?

85 A:

No, I don't see any here.

If you make it less magnified, there are no -- there are no marks here, either.

86 Q:

I have nothing further, Your Honor.

Temperature

tense

Key Quotes (4)

Werner Spitz
They are ragged; they are jagged; they are the same similar size. I mean, everything about this is the same.
Spitz asserting strong similarity between the textbook fingernail mark photo and the marks on Simpson's hand — the core of the objected-to comparison.
Werner Spitz
The error was mine. I attributed the gouges on the web side of the hand, and it is the opposite side of the hand, two gouges on the side of the little, pinky finger.
Spitz voluntarily correcting his own earlier misidentification of the wound location — notable for credibility but also an admission of error.
Werner Spitz
The skin, many times, remains suspended on the individual on whom the fingernail mark is. It remains suspended; it does not get any blood; it dries up and falls off in a day or two.
Directly addresses why the absence of victims' skin under Simpson's nails would not disprove the fingernail mark theory.
Werner Spitz
No, I don't see any here. If you make it less magnified, there are no -- there are no marks here, either.
Confirms no marks are visible in the pre-recital photo, supporting the timeline that Simpson's wounds occurred after the murders, not before.

Evidence (4)

Informal
Textbook photo from Dr. Spitz's Medicolegal Investigation of Death, 3rd edition, page 265 — fingernail gouges on wrist from a strangulation case
Foundation challenged; objection sustained; excluded
2164 (No. 8)
Close-up photo of Simpson's hand showing gouges on the side of the pinky finger
Discussed; Spitz corrects prior misidentification of which side of the hand
2165
Photo of Simpson's left hand (from exhibit 715, previously discussed by Dr. Huizenga) with Spitz's circles and initials marking fingernail marks near the middle knuckle
Marked and admitted during testimony
826
Photo of Simpson at his daughter's recital, taken sometime before 7:00 p.m. on June 12th
Discussed; Spitz confirms no fingernail marks visible

Notable Exchanges (3)

Robert BakerHiroshi Fujisaki
After the textbook photo is excluded, Baker moves to strike all of Spitz's fingernail mark testimony on the same foundation grounds. Fujisaki denies the motion, ruling the expert's experience and basis go to weight, not admissibility, subject to cross-examination.
strategic
Edward MedveneWerner Spitz
Spitz corrects his own earlier error about the location of the gouges on Simpson's hand (web side vs. pinky side), framing it as his mistake due to the photo being too close to see the full hand.
revealing
Edward MedveneWerner Spitz
Medvene elicits that the person causing fingernail marks would not necessarily have the victim's skin under their nails, because skin stays on the victim, dries, and falls off. Baker's sustained leading objection forces a rephrasing but the answer gets in.
strategic

Credibility Attacks (1)

⚔ Werner Spitz
Foundation challenge / motion to strike
Baker argued that since the textbook photo lacked adequate foundation to establish the marks were fingernail marks, Spitz's entire body of opinion testimony about fingernail marks on Simpson should be stricken. Motion denied.

Objections

6 objections (2 sustained, 3 overruled)
Proceeding 8212 • 86 utterances • Defense witness
Civil Trial
Department 103
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📂 NOV 8, 1996 📄 Direct examination of Dr. Wern
NOV 8, 1996 KRT DvH TD