📄 Cross-examination of Dr. Henry Lee — Friday, January 10, 1997
Address:
C:\DEPT103\CIVIL\1997\JAN\10\CROSS-EXAMINATION-OF-DR-HENRY-.DOC
TRIAL
▲ Day 39 of 57

Cross-examination of Dr. Henry Lee

Witness: Dr. Henry Lee
Examiner: Daniel Petrocelli
Called by: Defense • Date: Friday, January 10, 1997 • Utterances: 107
Baker conducts redirect of Dr. Henry Lee via videotaped deposition, focusing on three areas: clarifying Lee's criminal trial testimony about the 'wet/dry' threshold for evidence, reinforcing Lee's sock analysis (arguing the blood position on sides 1/2 matching the cutout area makes innocent transfer an implausible coincidence), and briefly touching on the shoe print envelope diagram. The session is interrupted by a contentious out-of-jury recess where plaintiff's counsel Kelly moves to bar the defense from introducing Nicole Brown Simpson's alleged drug use, drinking, and romantic life when Simpson takes the stand.
1 A:

Three hours, three and a half, two and a half. Doesn't really matter. (Videotape is halted.) (Pause.) (Videotaped deposition of Dr. Henry Lee resumes being played, with Mr. Baker examining.) REDIRECT EXAMINATION BY MR. BAKER:

2 Q:

Dr. Lee, let me go back to this drying. I want to read what was said in your transcript on August 28, 1995, because maybe it was misread to you. Page 43142 in the criminal trial transcript (During the videotaped deposition of Dr. Henry Lee, Mr. Baker read a portion of the criminal trial transcript.)

3 Q:

And is that because there is a threshold between wet and dry— strike that. And is that because the threshold between wet and dry is somewhat fuzzy.

4 A:

Wet and dry. That's not fuzzy at all.

5 Q:

Whether wet or dry, but they are in between, damp, not soaking wet. What's the definition of the wet, what kind of—you get into a semantic issue.

6 THE COURT:

Can you hold up a minute. Where are you?

MR. P. BAKER: 325.

7 MR. MEDVENE:

357.

8 MR. LEONARD:

357.

MR. P. BAKER: It's the redirect.

9 MR. MEDVENE:

Right now, 357, line 11.

10 THE COURT:

Okay. Thank you. (Mr. Baker read an answer given by Dr. Lee from a portion of the criminal trial transcript.)

11 A:

If it is not dry. Anything else I call wet. (In the videotaped deposition of Dr. Henry Lee, Mr. Baker ceased reading from the criminal trial transcript of Dr. Henry Lee.)

KEY QUOTE
12 Q:

(BY MR. BAKER) Was that your testimony back in August 28, 1995, of the criminal trial?

13 A:

Yes.

14 Q:

Now, Dr. Lee, in a laboratory procedure, the conditions are somewhat constant, are they not?

15 A:

Yes.

16 Q:

Now, Mr.—strike that. Dr. Lee, you heard Mr. Medvene ask you some questions about the sock being inside out, did you not?

17 A:

Yes.

18 Q:

And did you also determine— well, strike that. And the proposition that was proffered to you was basically if Mr. Simpson had blood on his hand or finger, and pressed side 3 of the sock that was outside—strike that—that was inside out, that that could account for the blood that you found when you examined the socks, correct?

19 A:

Correct.

20 Q:

And for that to have taken place—

21 MR. LEONARD:

363, Your Honor, line 10.

22 Q:

(BY MR. BAKER) The area cut out on the sock—on sides 1 and 2 would have—in other words, the blood on side 1 and 2 was in the exact same position as you found red balls on side 3, correct?

23 A:

Should be similar position. If press hard enough side 4 should have some blood stain, too.

KEY QUOTE
24 Q:

And so it would have to be a coincidence if Mr. Simpson put blood on side 3 when the sock was inside out in the amazing same spot that had a cut out previously by someone in the sock that you examined, correct?

KEY QUOTE
25 A:

Correct.

26 Q:

Now, Mr. Medvene talked to you about, and I don't know if I can get there with this . . . talked to you about— Where did you put that other exhibit? (Pause in tape.)

MR. P. BAKER: 366.

27 THE COURT:

Where are you going now?

MR. P. BAKER: 366. 367, line 7.

28 THE COURT:

You already read that, didn't you.

29 THE COURT:

367 from line 4 through 10 was read the first time around.

MR. P. BAKER: We didn't get to the redirect.

30 THE COURT:

Huh?

MR. P. BAKER: We haven't played any of the redirect yet.

31 THE COURT:

Oh, okay.

32 MR. BAKER:

Phil, back it up. (Pause.)

33 Q:

(BY MR. BAKER) That would— you mean you found a parallel line pattern; is that correct?

34 A:

Yes, sir.

35 Q:

And got 70 plus pairs of shoes with a parallel line sole on them subsequent— (Tape halted.)

36 MR. PETROCELLI:

That was sustained, that area.

37 THE COURT:

The second part was sustained. The Court overruled it to line 10. Line 11 is sustained. (Tape resumes playing.) (Tape halted.)

38 MR. BAKER:

Phil's future is not in the entertainment world, not in editing.

KEY QUOTE
39 THE COURT:

Not in editing.

MR. P. BAKER: Okay.

40 MR. FOSTER:

Page 368, line 11.

41 MR. LEONARD:

368, 11. (Tape resumes playing.)

42 Q:

(BY MR. BAKER) The envelope, correct?

43 A:

This is the envelope.

44 Q:

And if we look at the lower right-hand corner we see where Mr. Goldman's body is, correct?

45 A:

Correct.

46 Q:

And the envelope is directly or pretty much—

47 MR. PETROCELLI:

That was all supposed to be stricken, too, Your Honor,

48 MR. BAKER:

I didn't think this was stricken.

49

THE COURT: There was no objection to 368 -- well, strike that. 368:06 through 369:07 was sustained. Let's take a 10-minute recess. I understand you have the copy of the minute order to assist you. Okay. (Recess.) (The following proceedings were held in open court outside the presence of the jury.)

50 MR. KELLY:

Judge, one matter just before—in anticipation of Mr. Simpson taking the stand. Back in September, as a result of the defendant's motion in limine No. 3, this Court had ruled that plaintiffs could not put Mr. Simpson's character in issue, specifically forbid us to go into any allegations of purported drug use or infidelities of Mr. Simpson unless, of course, he put his character in issue. Mr. Baker in his opening statement and subsequent to that, he's given some indication that he would put Nicole Brown's Simpson character in issue even though we have not in our case thus far. He's brought up mention of in his opening statement in particular the parties, visiting with prostitutes, heavy drug users into the home, being with a lot of different men, allegations of purported drug use, excessive drinking, erratic behavior and also mention of a terminated pregnancy after separation from Mr. Simpson. We've heard no evidence of that thus far, and I suspect that he may try to put this in through Mr. Simpson's own testimony. It's my position, Judge, that first of all, these things are totally irrelevant, that there's been no evidence presented that in any way would indicate that Nicole Brown Simpson's lifestyle or character or any of that had anything to do with these murders. Secondly, Mr. Simpson alone is the only one who has testified as to any purported drug use or excessive drinking of Nicole Brown Simpson. He based that only on conversations he had had with Nicole, and clearly she's not here to defend herself with regard to that. And finally, Judge, if this is put in issue, we have a number of witnesses, and all the depositions taken to date, indicate nothing but Nicole Brown Simpson was simply a wonderful person, and we're going to be forced to bring in a parade of witnesses to testify as to what a good person she was if character is put in issue. And we think that would be an undue consumption of the Court's time and certainly misleading to the issues of fact. And all I would ask at this time is to reenforce the Court's ruling of the other day that no allegations of drug use or excessive drinking of Nicole Brown Simpson be put into issue, certainly not any of her alleged romantic interests after her separation from Mr. Simpson, and specifically the defense be barred from any testimony regarding the purported terminated pregnancy. It's just not relevant to any of the issues, Your Honor.

51 MR. BAKER:

Your Honor, this was—these issues were raised by plaintiffs. They were raised by the plaintiffs by saying that Mr. Simpson was in a jealous rage when these murders took place, and indicating to this jury that that's the cause of the rage, is that he had this thing for Nicole that he couldn't get over. This goes to the issue—the very issues amounting to their relationship. He put their relationship in issue in opening statement. It's been an issue in the whole case. And it will, I assume, continue to be an issue through final argument. Now, I'm certainly entitled to combat that issue with the testimony of my client, and I intend to do so. And had they not talked about the relationship between my client and Nicole, it wouldn't have come in ever because it wouldn't have been necessary. They have bandied that about for four months. I obviously have to defend on that issue, and intend to.

52 MR. KELLY:

Your Honor, it's not the relationship. It's the specific issues I've mentioned. You'll—it's alleged drug use or excessive drinking or her romantic interests. And, first of all, we didn't put these issues before the jury, before the Court, or at issue at all. What we put at issue was possibly the relationship, which Mr. Simpson certainly allowed to comment upon, but the—these specific things Mr. Baker mentioned in his opening occurred before the reconciliation. Even so, it has nothing to do even in terms of a non-motive, in terms of that, Your Honor, these are all '92 incidences, early '93 incidences, even before the reconciliation, so they have no bearing on the relationship or non-motive for that affect, Your Honor, and it's just—it's just not relevant to the killing. We have put nothing forward that suggests in any way it has anything to do with these killings, nor has the defense in their part of the case also, Your Honor.

53 MR. BAKER:

Drug use and drinking goes to the erratic behavior that Mr. Simpson will testify to. And that was a problem and concerned him and he talked to Juditha Brown about it. He raised that issue with Juditha Brown in all the telephone calls. The relationship—I mean we have spent basically three weeks on an incident of July 1, 1989 --

54 MR. KELLY:

January.

55 MR. BAKER:

January, I'm sorry. And to an outsider, you would think that's the incident we're here on trial on, and of course that was some five and a half years before these murders took place. That seemed to be terribly relevant. 1984 incident in the relationship seemed to be terribly relevant. And the romantic interest—they say he was extremely jealous and he was in a jealous rage. The incident that took place to her romantic interests is that he had, for example, the incident that he witnessed, I mean he didn't go into any rage, he didn't go into the house and go into a rage. These the jury's entitled to hear. They've raised them and trumpeted them throughout the country. Now it's time for Mr. Simpson to explain.

56 MR. KELLY:

Your Honor, with regard to the incidences of violence, that's a separate issue supported by P V. Zack. With regard to the specific things—as I say, they're way before the reconciliation, and the only thing I can add, if Mr. Simpson is going to testify to these things in terms of a non-motive or would be a reason for him not to have these strong feelings towards Nicole Brown Simpson or commit the murder, we should in fact be then allowed to bring in evidence of any purported drug use of his or infidelities or romantic interest he may have to show it wouldn't provide a non motive for motive for him, and the whole character issue should be front and center.

57 THE COURT:

It would be nice if you would bring these things up in a timely fashion when we have time to address these things instead of right in the middle of taking evidence on something else.

58 MR. KELLY:

Judge, I didn't know if we'd have another break. That's why.

59 THE COURT:

We had a whole day where we did nothing. Remember? Or were you in town?

60 MR. KELLY:

I was in town. The issue was raised just the other day with Mr. Tippin again, and I wanted to reenforce it.

61 THE COURT:

We sat here and did nothing all day.

62 MR. KELLY:

Excuse me?

63 THE COURT:

We did nothing except— Mr. Petrocelli came in with Levi's on.

64 MR. KELLY:

I can't be responsible for his dress code.

65 THE COURT:

Then Mr. Baker and Mr. Petrocelli came in with matters. Why do you do it now? Right in the middle when we're trying to finish other matters?

66 MR. KELLI:

I thought it was important before Mr. Simpson takes the stand and I felt it was—

67 THE COURT:

Do it in a little more timely fashion, please. I'll reserve judgment on it. Bring the jury in. Let's finish this video examination. Get it out of here.

68 THE BAILIFF:

Jury walking.

69 MR. PETROCELLI:

They were blue jeans, Your Honor, Guess jeans everyone. (Laughter.)

MR. P. BAKER: Judge, the transcript starts on 369, line 13, through to 374, line 15.

70 THE COURT:

369?

MR. P. BAKER: Line 13, through 374, line 15. That's the end of the defense, and they have a couple more questions and that's it.

71 THE COURT:

By the way, are you going to file any responsive pleadings?

72 MR. PETROCELLI:

Yes, Your Honor.

73 THE COURT:

When?

74 MR. PETROCELLI:

Monday morning, first thing. We just got them late yesterday and they're very thick and we're here in court.

75 THE COURT:

I read them.

76 MR. PETROCELLI:

You ready to rule?

77 THE COURT:

Well, what I'm trying to get at is—

78 MR. PETROCELLI:

Well—

79 THE COURT:

-- you got a whole staff of lawyers. I don't know why these things come the way they do.

80 MR. PETROCELLI:

It's a big stack of papers at the end of the day yesterday and I was working very late last night.

81 THE COURT:

I got that second paper in the morning. Didn't you get it in the morning?

82 MR. PETROCELLI:

No, we did not.

83 MR. BAKER:

I—

84 MR. PETROCELLI:

We got in the afternoon.

85 MR. BAKER:

I put it on the desk at the—at 1:30, the same time it was given to the Judge.

86 MR. PETROCELLI:

I didn't get it.

87 MR. BAKER:

Yes, it was—

88 THE COURT:

We're—

89 MR. BAKER:

I'm in court 8:30 to 4:30. If you want we can argue—

90 THE COURT:

Mr. Gelblum was not here this morning.

91 MR. GELBLUM:

I was not sitting at the beach, Your Honor. I was working very late myself.

92 MR. LEONARD:

He was looking for the fourth book.

93 MR. PETROCELLI:

Prepared to argue the rebuttal—the rebuttal case at any time, Your Honor.

94 THE COURT:

You know, Monday's a little bit late. These are not new issues.

95 MR. PETROCELLI:

Prepared to argue the Fuhrman one and the rebuttal one at—we'll just—we'll argue it orally, Your Honor.

96 THE COURT:

Okay.

97 MR. BAKER:

The rebuttal one will be—

98 MR. PETROCELLI:

The McKinney one, we have time to look at all the references that they're talking about. We can argue the law on all of them if you like.

99 THE COURT:

All right. Fine.

100 MR. BAKER:

The rebuttal one would then be helpful, if we could argue that today, Your Honor.

101 THE COURT:

Bring them in. (Jurors resumed their respective seats.)

102 MR. PETROCELLI:

1:30, Your Honor, right after lunch, first thing?

103 THE COURT:

Maybe sooner.

104 MR. PETROCELLI:

Okay.

105 THE COURT:

Okay. Play it. (Tape of deposition of Dr. Henry Lee resumes playing.)

106 (BY MR. BAKER) And we have just looked at where the location of the two bodies of the murder victims were. And then as we—let's zoom and I'll show you one other diagram so that we can hopefully get oriented relative to time and place. Let me put up first this diagram which was the prosecution's in the criminal trial and it's 593. (Criminal trial Exhibit 593 displayed on video.)
107 Q:

(BY MR. BAKER) You see the logo down here, the directional logo?

Temperature

procedural

Key Quotes (5)

Henry Lee
If it is not dry. Anything else I call wet.
Lee on redirect reclaims his simple definition of 'wet' from criminal trial — undercutting cross-examination suggestions that he was being evasive about damp/wet distinctions in evidence analysis.
Henry Lee
Should be similar position. If press hard enough side 4 should have some blood stain, too.
Lee's observation that blood transfer through a folded sock should appear on side 4 as well strengthens the defense argument that the sock blood pattern is inconsistent with innocent contact.
Baker (examining Lee)
And so it would have to be a coincidence if Mr. Simpson put blood on side 3 when the sock was inside out in the amazing same spot that had a cut out previously by someone in the sock that you examined, correct?
Baker frames the sock blood evidence as requiring an impossible coincidence to accept the prosecution/plaintiff theory — Lee confirms 'Correct.'
Baker
Phil's future is not in the entertainment world, not in editing.
Baker jokes about his son Phil's fumbling with the tape playback; Judge Fujisaki echoes 'Not in editing' — rare levity in an otherwise procedural session.
Kelly
Secondly, Mr. Simpson alone is the only one who has testified as to any purported drug use or excessive drinking of Nicole Brown Simpson. He based that only on conversations he had had with Nicole, and clearly she's not here to defend herself with regard to that.
Kelly's core argument for barring character evidence — Nicole cannot rebut Simpson's characterizations, making such testimony unfairly prejudicial.

Evidence (5)

Informal
Criminal trial transcript of Dr. Henry Lee, August 28, 1995, page 43142 — testimony about wet/dry threshold
Read aloud by Baker during deposition redirect to rehabilitate Lee's definition
Informal
The socks (sides 1, 2, 3, and 4) — blood stain positions relative to cutout area
Discussed to argue implausibility of innocent transfer theory
Informal
Envelope showing location of Goldman's body and crime scene orientation
Referenced but stricken — 368:06–369:07 sustained
Criminal trial Exhibit 593
Prosecution diagram from criminal trial showing directional logo and crime scene layout
Displayed on video at end of playing segment
Informal
Shoes with parallel line sole pattern — 70+ pairs identified
Discussed briefly; second part of question sustained

Notable Exchanges (3)

BakerPetrocelliJudge Fujisaki
Baker and Petrocelli spar over tape segments — which portions were stricken or overruled from earlier playback — with the judge tracking transcript page/line numbers in real time.
procedural
KellyBakerJudge Fujisaki
Out-of-jury motion by Kelly to bar Simpson from testifying about Nicole's alleged drug use, drinking, and romantic interests. Baker argues the jealous-rage narrative put by plaintiffs opens the door. Judge Fujisaki reserves ruling and criticizes Kelly for timing.
tense
Judge FujisakiKelly
Judge rebukes Kelly for raising the Nicole character issue mid-session: 'We had a whole day where we did nothing. Remember? Or were you in town?' Kelly cannot adequately explain the delay.
heated

Light Moments (3)

Baker / Judge Fujisaki
Baker jokes about his son Phil's tape editing fumbles: 'Phil's future is not in the entertainment world, not in editing.' Judge Fujisaki immediately echoes: 'Not in editing.'
Petrocelli
After Judge Fujisaki references Petrocelli wearing Levi's on an earlier day, Petrocelli clarifies for the record: 'They were blue jeans, Your Honor, Guess jeans everyone.' Laughter in court.
Leonard
Leonard quips about Gelblum (who was absent working late): 'He was looking for the fourth book.'

Credibility Attacks (1)

⚔ Henry Lee
Prior inconsistent statement / rehabilitation
Baker on redirect reads Lee's own criminal trial testimony (Aug 28, 1995) to show his wet/dry definition was consistent — countering Medvene's cross-examination implication that the threshold was vague or manipulated.

Witness Demeanor

(Videotape is halted.) (Pause.) (Videotaped deposition of Dr. Henry Lee resumes being played)
(Pause in tape.) — during redirect while Baker searches for exhibit
(Tape halted.) / (Tape resumes playing.) — multiple times during disputed transcript navigation
(Recess.) — 10-minute recess called by judge to resolve tape/transcript disputes
(The following proceedings were held in open court outside the presence of the jury.)
(Jurors resumed their respective seats.)

Objections

2 objections (2 sustained, 1 overruled)
Proceeding 8772 • 107 utterances • Defense witness
Civil Trial
Department 103
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📂 JAN 10, 1997 📄 Cross-examination of Dr. Henry
JAN 10, 1997 KRT DvH TD