📄 Cross-examination of Thomas Lange (part 2) — Thursday, October 31, 1996
Address:
C:\DEPT103\CIVIL\1996\OCT\31\CROSS-EXAMINATION-OF-THOMAS-LA.DOC
TRIAL
▲ Day 6 of 57

Cross-examination of Thomas Lange (part 2)

Witness: Det. Tom Lange
Examiner: Edward Medvene
Called by: Defense • Date: Thursday, October 31, 1996 • Utterances: 272
Robert Baker cross-examines Detective Lange on three fronts: (1) whether Lange knew about Simpson's domestic violence history before arriving at Rockingham on the night of the murders, despite his own murder follow-up report documenting exactly that; (2) whether allowing a blanket to be placed over Nicole Brown Simpson's body contaminated trace evidence at the crime scene; and (3) extensive challenges to Lange's crime scene notes, particularly his failure to document blood on the back gate despite noting other blood drops in detail. The latter half of the examination focuses on blood evidence in the closed-in area where Ron Goldman was found, with Baker pressing Lange on what the pooled blood and boot impression reveal about the struggle.
1

BY MR. BAKER:

2 Q:

Now, Detective Lange, you wrote -- co-authored a murder follow-up report, did you not?

3 A:

I believe it was part of one. I'd have to see it to see what you were referring to. There were several.

4 Q:

You remember this was Exhibit 1061 to your deposition, and you were questioned about it. That was in June of 1996.

We've got to mark it because I don't think it's been marked in this case?

5 A:

Yes.

6 Q:

And that's a report that you co-authored, correct?

7 A:

Actually, I'm the one who wrote it.

8 Q:

You did write it?

9 A:

Yes.

10 Q:

Okay. Now, you indicated that you hadn't known of any domestic violence before you went to Mr. Simpson's estate, correct?

11 A:

That's correct.

12 Q:

Okay. And you wrote on page 3, I thought -- 2. Sorry.

Tell me if I'm reading this right:

Upon arrival at the crime scene, detectives were met by Detective 3 Ron Phillips, a West Los Angeles Division homicide coordinator.

Phillips stated the victim Brown was the ex-wife of O.J. Simpson, the well-known athlete/actor.

Additionally, Phillips stated that Mr. Simpson and victim 1 had been embroiled in previous domestic violence litigation, one of them resulting in the arrest of Mr. Simpson.

Mr. Simpson resided at 360 North Rockingham Place in Brentwood, approximately two miles from the crime scene.

You then continue on: Detectives followed up to the Simpson residence for the purpose of death notification and to check on Simpson's welfare.

That's what you wrote in your murder follow-up report, is it not, sir?

13 A:

Yes, it is.

14 Q:

And so you had knowledge before you went up to Simpson's residence that, in fact, there had been a previous domestic abuse because you'd been told that by Detective Phillips, correct?

KEY QUOTE
15 A:

No, no, that's not correct.

16 Q:

Thank you very much, sir you've answered the question.

17 MR. MEDVENE:

Court please?

18 DET. TOM LANGE:

I did. I said no. And I'll gave you an explanation, if you'd like it.

19 Q:

(BY MR. BAKER) Let me ask you a couple more questions.

You then state in here that, I went up to the Simpson residence for the purpose of death notification and to check on Simpson.

There's no mention whatsoever of any welfare of the children, is there, sir?

20 A:

I don't believe in that paragraph that there is, no.

21 Q:

Now, in terms of your being at the crime scene at 875 South Bundy, it was you, was it not, who requested somebody to get a blanket to place over the body of Nicole Brown Simpson?

22 A:

Actually, I requested a sheet.

23 Q:

And you, being a veteran detective, knew that if you put something over the body, that contamination can and does occur, correct?

24 A:

Not necessarily, no.

25 Q:

Well, you wanted to make every effort, did you not, Mr. Lange, to ensure that there would be no contamination that would inhibit in any way the finding of trace evidence, such as hair and fiber, true?

26 A:

Contamination --

27 Q:

True or untrue --

28 A:

-- compromise?

29 Q:

-- true or untrue.

30 MR. MEDVENE:

If the Court please, the witness should be able to answer the question, Your Honor. It's only fair he be able to answer it.

31 THE COURT:

You may answer that question.

Read that question back to the witness.

32 (The reporter read the record as follows:)
33 DET. TOM LANGE:

Certainly.

34 Q:

(BY MR. BAKER) So you directed some officer to get a sheet, not a blanket?

A I originally said a sheet. I asked him for a sheet; that's correct.

35 Q:

They said a blanket. That was Officer Thompson -- strike that. Yeah. It was Officer Thompson?

36 A:

Yes, it was.

37 Q:

Yeah. If he said a blanket, he'd be mistaken?

38 MR. MEDVENE:

Objection. That's not what the testimony is.

39 THE COURT:

Sustained. That was not what the testimony was.

40 Q:

(BY MR. BAKER) When Officer Thompson came to you with the blanket, did you allow it to be placed over the body of Nicole Brown Simpson?

41 A:

Yes. I sent him for a sheet; he returned with a blanket. He couldn't find a clean sheet, so he returned with a clean blanket. That was his explanation to me.

42 MR. BAKER:

Move to strike as nonresponsive, Your Honor.

43 THE COURT:

It may remain.

44 Q:

(BY MR. BAKER) Did you allow the blanket to be placed over the body of Nicole Brown Simpson?

45 A:

Yes.

46 Q:

And did you understand at the time that you'd be contaminating that body with trace evidence from the blanket -- from the dryer -- where it was washed and dried? Did you understand that when you had it placed over the body?

47 A:

Not necessarily.

48 MR. MEDVENE:

Objection, Your Honor. It's one, compound, and assumes facts not in evidence.

49 THE COURT:

Assumes facts not in evidence. Sustained.

50 Q:

(BY MR. BAKER) Did you have any understanding that you could take hair and fiber from a dryer that the blanket would be dried in and move that trace evidence onto the body?

51 A:

Certainly that's always possible; however, I had another reason for doing it.

52 Q:

And that reason, in your view, overrode the possibility of contaminating the crime scene?

53 A:

Without any question.

54 Q:

All right. Now, did you, in your conversations and meetings with the plaintiffs' attorneys in this case, did you come to understand that there were any topics that you were not to discuss on the witness stand here today?

Did they tell you what they didn't want you to answer?

55 A:

No.

56 Q:

They didn't tell you there was any subject off limits?

57 A:

I wasn't aware that I could discuss anything. I thought I was here to answer questions; and no, there wasn't.

58 Q:

Okay. So you had no such discussion, correct?

59 A:

I don't recall anything like that.

60 Q:

Fair enough. Now, Mr. Lange, you were at the crime scene after you got back at about 6:45, and remained at the Bundy crime scene until when?

61 A:

I believe I was called away sometime after 12 o'clock. Sometime after noon, I believe I was called away.

62 Q:

And during that period of time, from 6:45 until sometime after noon, is when you did your processing of the crime scene and documentation of evidence, correct?

63 A:

Most of it was done during that time, yes.

64 Q:

And that would have been commencing seven hours after the bodies were found and LAPD was notified, until approximately 12 hours after the bodies were found and LAPD notified, right?

65 A:

Commencing -- I'm sorry. Seven hours after they were found?

66 Q:

Yes, sir.

67 A:

Approximately.

68 Q:

Now, when you -- strike that.

It is important, is it not, to first recognize evidence at a crime scene and then document it? You would agree with that?

69 MR. MEDVENE:

Objection, Your Honor; relevance, materiality.

70 THE COURT:

Overruled.

71 DET. TOM LANGE:

What do you mean by "recognize?"

72 Q:

(BY MR. BAKER) Determine that something is, in fact, evidence, as contrasted to something that may have no evidentiary value whatsoever.

73 A:

Generally, that's true.

74 Q:

And would you agree, sir, that one of the critical steps in processing a crime scene is to document the evidence?

75 A:

That's one of the steps.

76 Q:

And you made crime-scene notes from the crime scene on June 13, 1994, true?

77 A:

I did.

78 Q:

And you were trying to put in these notes everything of significance you observed?

79 A:

Not necessarily.

80 Q:

All right. Let me read your deposition.

Page 207, starting at line 13, through 22.

"Q. These notes were taken by you at the crime scene, correct?

"A. That's correct.

"Q. And they were taken more or less as you observed various things at the crime scene; is that correct?

"A. Yes.

"Q. Were you trying to put in these notes everything of significance that you observed?

"A. Yes."

Now, you made pretty detailed notes encompassing nine pages of attempting to put in everything you observed, correct?

Well, actually, I think there were more than nine.

81 A:

Well, nine --

82 Q:

I apologize. June 13, 1994, that's when you made, I believe, nine pages of notes.

83 A:

There were nine or ten, yes.

84 Q:

And in the nine or ten pages of notes, you documented all of the blood drops that you have testified to this morning and early afternoon, true?

85 A:

Well, when you say "documented," I wrote them down, and they weren't measured to any great degree. I noted them in the notes.

86 Q:

And you talked about the blood drops out on the driveway, north of the driver's door.

87 MR. BAKER:

Why don't you flip that on, Phil.

MR. P. BAKER: The notes or --

88 MR. BAKER:

Yeah, page 9 of his notes.

89 THE COURT:

Is that an Exhibit?

MR. P. BAKER: No, not yet.

90 MR. MEDVENE:

If the Court please, it shouldn't be displayed at this time. There's no question pending.

91 MR. BAKER:

I'll be happy -- you can put it off -- I'll be happy to lay a foundation.

92 Q:

(BY MR. BAKER) Mr. Lange, these are your notes, are they not?

93 A:

Yes, a copy.

94 Q:

Those are a copy and those are the notes we just talked about that you wrote what you observed on June 13, first nine pages, correct?

95 A:

Yes.

96 Q:

And that's in your handwriting?

97 A:

Yes, it is.

98 Q:

And that's your documentation of the crime scene when you were there on June 13?

99 A:

Correct.

100 Q:

And you tried to put in everything of significance that you observed, correct?

101 A:

Well, for the most part, yes, there are areas that I wouldn't necessarily become overly concerned with because other people are, but that's a general observation that I had, yes.

102 Q:

So that when you stated in your deposition you wanted to put down everything of significance you observed, you now believe only those areas that you thought you were concerned with, as contrasted to areas that other people might be concerned with, right?

103 A:

Not necessarily. I think you're asking for a black-or-white answer here.

104 Q:

I'm asking for a truthful one.

KEY QUOTE
105 A:

That's exactly what I'm trying to give you.

KEY QUOTE
106 Q:

Now, let's put it --

107 MR. BAKER:

What's the next number in order?

108 THE CLERK:

2107.

109 MR. BAKER:

What Is it? I'm sorry.

110 THE CLERK:

2107.

111 MR. BAKER:

Let's put up page 9, please.

112 (The instrument herein referred to as Notes of Mr. Lange was marked for identification as Defendants' Exhibit No. 2107.)
113 Q:

(BY MR. BAKER) Now, on page 9, you document two dimes, 2 pennies of the driveway north of the jeep. Do you see that?

114 A:

I do.

115 Q:

You document a blood drop straight down on the driveway, north of the driver's door of the jeep?

116 A:

Yes.

117 Q:

You documented additional blood drops on the walkway inside the rear gate --

118 A:

That is correct.

119 Q:

-- and the north side of the residence?

And then you document blood droplets observed on the north walkway between the shoe prints, right?

120 A:

Correct.

121 Q:

And those were -- blood was very important, wasn't it?

The blood drops were significant evidence, were they not?

122 A:

To me, they were significant because they appeared to me to be the blood of a suspect, yes.

123 Q:

And then you diagramed and measured the gate, true?

124 A:

That's correct.

125 Q:

And you did not indicate a single blood drop on the gate in your notes that document the crime scene of June 13, 1994; you would agree with that?

126 A:

Yes. I saw no reason to do that at that time.

KEY QUOTE
127 Q:

I see. So that's the only blood drop that you omitted in your observations of blood drops on June 13, 1994, right?

128 A:

No. There were many blood drops that weren't documented. There were many other -- there were fingerprints that weren't documented. This is not 100 percent of everything I observed, by any means.

KEY QUOTE
129 Q:

Okay. Now, on June 13, 1994, you observed some blood droplets on the back of the body of Nicole Brown Simpson, correct.

130 MR. MEDVENE:

Objection; relevance, materiality.

131 THE COURT:

Overruled.

132 DET. TOM LANGE:

I did.

133 MR. BAKER:

That exhibit number?

MR. P. BAKER: 2040.

134 Q:

(BY MR. BAKER) Now, sir, those blood drops were significant, were they not?

135 A:

To me, they were.

136 Q:

And you noted those in your notes, did you not?

137 A:

I did.

138 Q:

And they were significant because those blood drops were more likely than not to be the blood drops of the perpetrator of the crime, correct?

139 A:

No, I didn't believe so. In fact --

140 Q:

Well, you knew they weren't the blood drops of the victim?

141 A:

I believe there's a very good chance that they are, indeed, the blood drops of the victims, or a mixture. However, I wanted to know -- to clarify that, obviously.

142 Q:

And you asked or directed the coroner's office to -- to sample those blood drops, correct?

143 A:

I did.

144 MR. MEDVENE:

Objection, Your Honor. Outside the court's order.

145 THE COURT:

Excuse me?

146 MR. MEDVENE:

We object. Relevance. Outside the court's order.

147 THE COURT:

Well, to some extent, I'm going to allow cross-examination, since you made an extensive examination of this witness with regard to the blood and blood drops in the area.

148 MR. MEDVENE:

Okay. Just may we be heard, Your Honor?

149 MR. PETROCELLI:

Can we be heard on that, Your Honor?

150 THE COURT:

No.

151 Q:

(BY MR. BAKER) Now, Mr. Lange, those blood drops certainly could have been -- regardless, we'll never know that they are -- but they could have been the blood drops of the perpetrator of the crime, correct?

152 MR. MEDVENE:

Objection. Calls for speculation.

153 THE COURT:

Sustained.

154 Q:

(BY MR. BAKER) Those blood drops, you told Ratcliffe to collect and analyze, true?

155 A:

I requested that of her, yes.

156 Q:

That never occurred?

157 MR. MEDVENE:

Objection. Same objection.

158 THE COURT:

Sustained.

159 Q:

(BY MR. BAKER) To your knowledge, did it ever occur that those blood drops were analyzed?

160 MR. MEDVENE:

Same objection.

161 THE COURT:

Sustained.

162 Q:

(BY MR. BAKER) Now, you analyzed the closed-in area in some detail when you were at the crime scene on the 13th of June, did you not?

163 A:

I believe so.

164 (Counsel displays blow-up.)
165 MR. PETROCELLI:

Your Honor, for the record, there was an exhibit to Exhibit 2040, that last exhibit, that is not what 2040 is, according --

166 THE COURT:

Excuse me?

167 MR. PETROCELLI:

That is not what Exhibit 2040 is, according to --

MR. P. BAKER: 2040. I was in error. It's actually 835.

168 THE COURT:

835?

MR. P. BAKER: Yes.

169 (The instrument herein referred to as Photo of victim's back was marked for identification as Defendants' Exhibit No. 835.)
170 Q:

(BY MR. BAKER) Now, Mr. Lange, you went into the area that you described as 4 feet by 6 feet, the caged-in area, did you not?

171 A:

I went in it.

172 Q:

Yeah, after the body of Mr. Goldman had been discovered?

173 A:

I had been in there, yes.

174 Q:

And you carefully observed the evidence that was contained in that area, sir?

175 A:

I did observe evidence in that area, yes.

176 Q:

And did you observe the boot that you talked about, the left boot of Mr. Goldman?

I'm sorry. I can't make it any easier for you to see here.

177 A:

Yeah, I can see it.

178 Q:

Well, that doesn't comport with me going in there. That boot you see, I believe, was when Mr. Goldman was in there.

I did observe that after he had been -- before I went in there, yes.

179 THE COURT:

Excuse me. What is that chart, Exhibit number?

180 MR. BAKER:

What is it?

MR. P. BAKER: 1342.

181 THE COURT:

That's the big board?

MR. P. BAKER: Yes.

182 THE COURT:

Thank you.

183 (The instrument herein referred to as Photograph of blood stains from closed-in area at Bundy was marked for identification as Defendants' Exhibit No. 1342.)
184 Q:

(BY MR. BAKER) Looking at the lower right-hand photograph, there was blood that you observed in the boot of Mr. Goldman, correct? The size of the drop --

185 A:

Can I take a look at this?

186 Q:

Sure. Help yourself.

187 A:

Yes. I believe that photo was taken after Mr. Goldman was removed from that caged-in area; and I did observe that, yes.

188 Q:

Didn't that indicate to you, as a detective of some 20 years' duration, that Mr. Goldman or someone else had bled, and then Mr. Goldman had stepped into blood in the dirt, dirt or caged or closed-in area, correct?

189 A:

By looking at that, I have two interpretations of that.

190 Q:

Well, can you answer my question, sir?

191 A:

I'll try.

192 Q:

My question was: The fact that you see blood and caked dirt, indicates to you that there was bleeding, and then Mr. Goldman stepped in the dirt with blood on it during the time that he was in the closed-in area; true or untrue?

193 A:

That's certainly possible, yes.

194 Q:

And is it probable?

195 A:

Yes, it is. I would say it is.

196 Q:

If that would that be a reasonable interpretation of the dirt on the bottom of the boot; that is, that he had been bleeding in the closed-in area and then stepped in an area where he had been bleeding and blood and dirt got on the sole of his left boot, true?

197 A:

That's reasonable.

198 Q:

And indeed, did you observe sir, the blood-pattern evidence on the bars around the closed-in area, sir?

199 MR. MEDVENE:

Objection; relevance, materiality, outside the scope.

200 THE COURT:

You may answer whether you observed it or not.

This witness testified to observation of blood in the location you asked on direct.

201 DET. TOM LANGE:

I observed what might be termed pattern evidence, but also transfer evidence, things of that nature.

202 Q:

(BY MR. BAKER) Now, the blood evidence that's on the bar that goes up at 10, that is -- in other words, this again is the, if you will, the center photograph. And the red lines go to, you know, where -- right from here. So this would be the -- that would be the east side of the closed-in area, would it not?

203 A:

Yes.

204 Q:

And the -- there is -- that over there in the middle picture on the right, what would you describe that as?

Is that a blood smear or blood stain?

205 A:

This picture here?

206 Q:

Yes, sir.

207 A:

Suppose one could describe that as perhaps a swipe or some type of transfer.

208 Q:

Very well.

Don't you detectives have -- and criminalists have certain vernacular that you use to describe various types of blood evidence?

In other words, a swipe or something else, or a transfer?

Is it a swipe, in your opinion, as contrasted to a smear?

209 A:

Well, I don't necessarily differentiate between a swipe and a smear.

210 Q:

Okay.

211 A:

I suppose that could be a said subjective thing.

212 Q:

But in any event, sir, even though you don't differentiate, did that pattern, that blood evidence on the east rung of the gate or -- strike that -- fence indicate to you that it was an area where Mr. Goldman had been during the struggle?

213 A:

To me, just looking at these photos, it would indicate the probability of that, yes.

214 Q:

And then if you look at the upper right-hand photo -- and that's actually a blow-up of the middle upper photo, sir, middle upper?

215 A:

Yeah. I was just looking at the relationship here. Yeah.

216 Q:

There is a -- there's blood evidence on the lower rung of the fence, is there not, that would indicate to you that Mr. Goldman had been standing in that area for a period of time because there's blood evidence on that rung, correct?

217 A:

I don't know that. I couldn't necessarily say that he had been standing --

218 Q:

He was at least above the area where the blood is seen on that lower bar of the fence?

219 MR. MEDVENE:

If the Court please, opinions are requested that are way beyond the scope of our direct examination, Your Honor.

220 THE COURT:

Overruled.

221 Q:

(BY MR. BAKER) You would agree with that, sir?

222 A:

Possibility.

223 Q:

Probability, would you not agree?

224 A:

Well, not necessarily.

225 Q:

There's some blood that came from above that bar, did it not, sir?

226 A:

Again, it's a possibility; unless someone were lying there, reached up and grabbed the bar for some reason.

227 Q:

Is that not a drop, as contrasted to a smear? I'm talking --

228 A:

You're looking down here. You told me the bottom rung. Are you referring to something up higher?

229 Q:

No, sir; that's what I was referring to.

230 A:

Perhaps you could specifically show me and --

231 Q:

I apologize.

Is this not blood-drop evidence that came down and dropped?

And you can see from the tentacle is this not blood-drop evidence? And is this not blood-drop evidence?

232 A:

Yes, these appear to be drops, certainly.

233 Q:

Over on the right-hand photograph, that would appear to be blood that is pooled in the area, indicating that Mr. Goldman had been above that area and had been in that area for some time, correct?

234 A:

Again, it's certainly a possibility. But as soon as I say that, I imagine there's experts somewhere that could dispute that and come up with a different theory.

I'm telling you it's a possibility.

235 Q:

(BY MR. BAKER) We're here for your opinions.

236 A:

I believe I just gave it to you.

237 Q:

Is it a probability that Mr. Goldman, sir, was upright and above that area for some period of time, in order for that blood to have pooled in the area where it's indicated on the upper right-hand photograph of the exhibit in front of you?

238 A:

Yes.

239 MR. MEDVENE:

Vague and ambiguous on time. It's outside the scope and it's compound, Your Honor.

240 THE COURT:

I'm going to allow some latitude on the blood testimony. You asked on direct. I'm going to allow it. It's a reasonable cross-examination. Overruled.

241 DET. TOM LANGE:

It's certainly possible, but I can't say that that's what happened.

242 Q:

(BY MR. BAKER) Well, you would agree with me, would you not, Mr. Lange, that the blood evidence that indicated between the fence and the concrete block -- well, strike that. Let me see if I can say it so that we both understand.

This block is outside Ms.` Nicole Brown Simpson's property. The fence ends here and the block is on the other side, correct?

243 A:

Outside is north of that.

244 Q:

Correct. Correct. North. I'm sorry.

So the blood evidence that is shown in the upper right-hand photograph here, is blood evidence that would, of necessity, have pooled on the side of the fence, and then seeped north, over to that concrete walkway, correct?

245 A:

Not necessarily. Looking at this, it could have dripped down, I suppose. I mean, it's all conjecture.

246 Q:

If it dripped down, in any event, both of those cakes of blood indicate that Mr. Goldman was above that area, and was there for a period of time, to account for the amount of blood that is shown in the photograph. True or untrue?

247 A:

I couldn't say one way or the other. Again, I'll qualify that it's certainly a possibility of that occurring.

248 Q:

Now, look at the photograph on the left side, the middle left photograph.

249 A:

This photograph here?

250 Q:

Yes, sir.

251 A:

101?

252 Q:

Yes, sir.

Now, you know the difference between a shoe print and a shoe impression, do you not?

253 A:

I believe so.

254 Q:

And a shoe print is a two-dimensional impression of a shoe, true?

255 A:

That's correct.

256 Q:

And an impression would be three-dimensional; that is, the shoe would sit down into some soft material, such as loam soil that we had in the dirted area at 875 South Bundy, right?

257 A:

That's what it is, yes.

258 Q:

And you believe that that area that the hole -- there was a hole that very probably was made during the time of the murders and may contain impression evidence, true?

259 A:

No. I believe it's very possible it was made during the struggle. As far as impression evidence, I didn't see any, so I can't make that assumption.

260 Q:

But you did see the hole, correct?

261 A:

Yes.

262 Q:

How deep was it, six inches?

263 A:

I believe it was around six, eight inches, somewhere in that area.

264 Q:

How wide was it?

265 A:

I don't recall. I could speculate. Fourteen inches.

266 Q:

Let's not speculate. If you have an estimate -- you were there when the hole was presumably in the same position it's in now, because -- or in the photograph, rather, because that was taken on the 13th, right?

267 A:

Yes. This is different dimensions. It's dug out in different areas; it's down at an angle. So it varies. It could go all the way at the bottom, which I suppose is 18 inches, all the way out to two feet.

268 Q:

That obviously took some period of time to dig that impression during the struggle for `Mr. Goldman's life, true?

269 A:

No. That soil back there is fairly loose, and I would assume this could possibly happen in a matter of a few seconds.

270 Q:

I see. A few seconds, two, three. Okay.

271 THE COURT:

If this is not a convenient --

Ladies and gentlemen, tomorrow is Friday. 9 o'clock. Don't talk about the case; don't form or express any opinions.

272 THE COURT:

Witness is ordered back tomorrow.

Temperature

tense

Key Quotes (5)

Robert Baker
And so you had knowledge before you went up to Simpson's residence that, in fact, there had been a previous domestic abuse because you'd been told that by Detective Phillips, correct?
Baker uses Lange's own written report to contradict his earlier testimony that he had no knowledge of domestic violence before going to Rockingham — a foundational challenge to the justification for the warrantless entry.
Thomas Lange
Yes. I saw no reason to do that at that time.
Lange admits he did not document any blood drop on the back gate in his nine-to-ten pages of crime scene notes — the gate that later became central to the DNA evidence against Simpson. This admission is the core of Baker's evidence-handling attack.
Thomas Lange
There were many blood drops that weren't documented. There were many other -- there were fingerprints that weren't documented. This is not 100 percent of everything I observed, by any means.
Lange retreats from his deposition testimony that he tried to document everything of significance, effectively undermining his own notes as a complete record.
Robert Baker
I'm asking for a truthful one.
Baker's direct challenge to Lange's credibility after Lange pushes back on a yes/no question — a calculated moment of courtroom pressure that underscores the adversarial tone of the examination.
Thomas Lange
That's exactly what I'm trying to give you.
Lange's retort signals a witness who is composed but resistant — not crumbling under pressure, setting up a pattern of qualified answers throughout.

Evidence (5)

Deposition Exhibit 1061
Lange's co-authored murder follow-up report documenting that Detective Phillips informed him of Simpson's prior domestic violence arrest before Lange traveled to Rockingham
read into record to impeach Lange's testimony that he lacked prior knowledge of domestic violence
Defendants' Exhibit 2107
Lange's nine-to-ten pages of handwritten crime scene notes from June 13, 1994
introduced and displayed; used to show absence of any gate blood documentation
Defendants' Exhibit 835
Photograph of blood drops on the back of Nicole Brown Simpson's body
introduced after exhibit number correction from 2040; used to establish Lange directed collection of blood drops that was apparently never carried out
Defendants' Exhibit 1342
Large photograph board showing blood stains in the closed-in area at Bundy, including the fence bars, Goldman's boot, and pooled blood
displayed on blow-up board; used to elicit Lange's interpretations of Goldman's position and movement during the struggle
Informal
Blanket placed over Nicole Brown Simpson's body at Bundy crime scene
discussed as potential source of trace evidence contamination; Lange confirmed he allowed it after Officer Thompson could not find a clean sheet

Notable Exchanges (4)

Robert BakerThomas Lange
Baker reads from Lange's own murder follow-up report — which states Phillips told him about Simpson's domestic violence arrest before Lange went to Rockingham — and asks if Lange therefore had prior knowledge. Lange flatly says 'No, no, that's not correct,' insisting the report doesn't mean what Baker says it means. Baker cuts him off before he can explain.
strategic
Robert BakerThomas Lange
Baker confronts Lange with his deposition testimony that he tried to document 'everything of significance' at the crime scene, then shows that nine-to-ten pages of notes contain no mention of blood on the back gate. Lange's answer evolves from 'not necessarily' to acknowledging many things were undocumented.
revealing
Robert BakerThomas Lange
Baker presses Lange repeatedly on whether blood evidence in the closed-in area shows Goldman was upright and bleeding there for an extended time. Lange hedges with 'possibility' and 'certainly possible' while resisting 'probability' — a sustained pattern of qualified admissions under pressure.
strategic
Hiroshi FujisakiDaniel PetrocelliEdward Medvene
Petrocelli and Medvene both attempt to address the court on the blood drop questioning; Fujisaki cuts them both off with a single word: 'No.' He then overrules the objection and allows Baker's cross-examination to proceed.
procedural

Light Moments (1)

Robert Baker
Baker refers to exhibit 2040 throughout questioning about the photograph of Nicole's back, only to be corrected mid-argument by co-counsel Philip Baker and Petrocelli — the exhibit number was actually 835. Baker acknowledges the error without ceremony.

Credibility Attacks (4)

⚔ Thomas Lange
prior inconsistent statement
Baker reads Lange's June 1996 deposition testimony that he tried to document 'everything of significance' at the crime scene, then contrasts it with Lange's current qualification that he only noted things he personally found significant — undermining the completeness of the crime scene notes.
⚔ Thomas Lange
omission / selective documentation
Baker establishes that Lange's detailed notes document numerous blood drops, coins on the driveway, and even measured the gate — yet contain no mention of any blood on the gate itself, which later became critical DNA evidence.
⚔ Thomas Lange
prior inconsistent statement via own written report
Lange's own murder follow-up report documents that Detective Phillips informed him of Simpson's prior domestic violence arrest before Lange drove to Rockingham, contradicting Lange's testimony that he had no knowledge of domestic violence before arriving.
⚔ Thomas Lange
failure to follow through on investigative directive
Lange admits he directed coroner's investigator Ratcliffe to collect and analyze blood drops from Nicole Brown Simpson's back — drops that could have been perpetrator blood — but sustained objections prevent confirmation that this analysis was never performed.

Witness Demeanor

Lange is composed and resistant throughout, consistently offering qualified answers ('certainly possible,' 'not necessarily') rather than direct yes/no responses
At one point Lange interrupts Baker to insist on giving an explanation after Baker thanks him for his answer and moves on
When Baker accuses him of not giving a truthful answer, Lange responds evenly: 'That's exactly what I'm trying to give you'

Objections

11 objections (4 sustained, 6 overruled)
Proceeding 8088 • 272 utterances • Defense witness
Civil Trial
Department 103
⚖️ Start
📂 OCT 31, 1996 📄 Cross-examination of Thomas La
OCT 31, 1996 KRT DvH TD