Okay. I'm going to put up a chart that was made while Mr. Groden was on the stand which listed the various points that he made.
(BY MR. GELBLUM) Do you recall from reading the testimony that one of the points Mr. Groden made was about a blue line that he observed between the sprocket holes and the image on the photograph of Mr. Simpson walking across the end zone?
And for the record, Your Honor, I put up a different copy of that photograph that I had before. This is Exhibit 2287, the one we're looking at now. (Exhibit 2287 displayed.)
(BY MR. GELBLUM) Mr. Groden said there was no natural phenomenon in photography that could possibly cause that blue line. Did you read that testimony?
Basically, the blue line on the photograph showing Mr. Simpson is a scratch line from the rails of the Canon F1 camera. It's quite a common scratch line, as a matter of fact, and it does continue on through the remainder of that roll sporadically, and through the second roll also. And in actuality, you should many times see two little blue lines on the side there from the scratch itself as the film is wound through it one way and then pulled back the other way. So many times I can see them very, very close together, but in essence particularly the Canon F1. And I'm fairly familiar with that camera; when I was Unit Chief of the Special Photographic Unit we had 1500 of them in our inventory. So that particular one leaves those types of scratches quite commonly. However, there are other cameras that also will leave scratches very, very similar to that. They are microscopic. You basically have a very difficult time even seeing them. Normally, most photographers don't really concern themselves with it that much. But, in essence, as the film is yanked through, particularly with a motor drive, it leaves either a long line or little dash lines all the way through the film.
KEY QUOTEBy the way, Mr. Groden also said that the frame of Mr. Simpson walking through the end zone was the only frame on the entire contact sheet that had that blue line. Was that true?
No. The great majority of them have that blue line; I mean the same type of blue line, either on the bottom and the top or just one or the other. The line will actually form on either the bottom or the top right next to the sprocket holes. On some of the frames, you no longer see the bottom and it starts appearing on the top. It's kind of a random thing. The line itself will be on the entire film, but the printing of it, many times will be sporadic, and you won't see the actual blue come through in its entirety.
KEY QUOTEI'm going to show you what we showed to Mr. Groden as Exhibits 2288 and 2289. Are those enlargements that you had prepared?
Yes, sir. If I might turn these towards the jury; I assume it's Exhibit 2288. This is one of the frames that we can see the blue lines on both the top and the bottom. Right next to the sprocket hole we see two little, small blue lines. You have to realize that the blue lines -- the difference between them is possibly somewhere in the vicinity of five-hundredths of an inch apart; very, very small.
Your Honor, may I have the witness come closer to the jury so they can see the lines?
Thank you, Your Honor. See if I can get down easily. (Witness approaches jurors.)
(BY MR. GELBLUM) First of all, you want to show them the line on 2287, the photo of Mr. Simpson in the end zone?
Sure. The lines we're referring to here are right next to the sprocket holes. You can see them; they're little blue dashes, they go all along Exhibit No. 2287 on the top -- excuse me. This would be the bottom only here. They go continually along, and you just see a shade of blue right up next to the frame. We can see those same blue lines right here. Actually, this is where we got a double set.
Yes, 2288. Along the bottom here, again, we can see the double set-- the double set here, the double set here, and in this particular case we can see the ones on the top also all the way through. (Indicating.) On Exhibit No. 2289, we can see very distinctly the same type of little blue dash -- little blue scratch. And this is one of many types of scratches you'll find on film, but it's a very predominant one, as I said, on the Canon F1 camera.
Your Honor, may I? This is a camera virtually identical to the one that Mr. Scull used. It's a Canon F1. It's no longer manufactured. It's an older model, and it has a motor drive on it as used by Mr. Scull. The only difference is he used a much longer lens and also what's called a monopod to hold the camera up. In essence, what's causing the scratches in this particular case are called rails. These actually support the film. There's four of them; two of them support the face of the film and two of them keep the film in -- in the position vertically. What causes the scratches is right at the very end of the middle support rails; you see how they end right next to what's called a sprocket. This sprocket is what actually pulls the film through. There are two little roller bars on the back of the camera which, when you close it, push the film in at that particular point. And they'll leave little bitty scratches each time the motor drive pulls it on through there. When it pulls it this way, they're usually short little scratches. When you rewind -- you rewind the camera back, they're long scratches. I've got a roll of film. I'll show you how that mechanism actually works.
Would you -- Mr. Richards, you might want to come over to this location if it's okay with the judge, so more of the jurors can get a closer look.
Let's see. I'll try to demonstrate all the way around so everybody can see it. Basically, when I close the back here, right here by this little sprocket, it pushes the film in. And when the film goes through it pulls across there and leaves those tiny, little scratches. It's a fairly sharp area. It's an area right at the end of the film there. (Indicating to film.)
Do those scratches appear on additional frames besides the three we looked at; 2287, 2288 and 2289?
About 75 percent of the frames have those scratches somewhere in the vicinity there all the way throughout both rolls of film. As I said, they're quite common. As a matter of fact, some of the cameras that I have personally, including this camera, make them quite readily, the same identical types of scratches.
Yes, sir. As a matter of fact, I photographed the ones from this camera and actually drove a roll of film through here and made a small -- took out the small piece of film that has the scratch in it, which is virtually, almost impossible to see without some magnification, unless you get it just exactly right. I did make a photograph through a microscope, not the best photograph I've ever made, by the way, but a proof by a microscope that distinctly shows the scratches through there.
Okay. (The instrument herein described as a microscopic enlargement photograph of film was marked for identification as Plaintiffs' Exhibit No. 2358.)
Oh, okay. Sure. Let's -- I'll take this one, I guess. Again, the short little blue scratches here that we see that look like little dashes just above the sprocket holes are basically the same little scratches we have here along the edge of the sprocket holes made by this particular camera. Like I say, it's quite a common characteristic. You'll find it on a lot of cameras besides the Canon F1, but the -- and the F1 is noted for it because of the way one rail ends at the sprocket holes. The newer cameras, the rails are built so they don't end at this point; it's a nice smooth edge across there, so many of them won't form that type of scratch.
This is off the actual film before it's processed. This is after it's processed and printed. So when it's been printed the color turns up blue. It doesn't necessarily always turn up blue. It depends how deep that scratch is for that particular camera.
So is that -- in your opinion, is that blue line that appears on you said 75 percent of the frames on that contact sheet evidence of alteration of any kind?
No, sir. As a matter of fact, it's scratches like this that I use to tell if the film came from the same camera. When I'm looking at pieces of film, those scratches have to match where the films are cut. If they don't match where the films are cut, then I obviously have a problem in dealing with that piece of film. So I put the film together, look at it microscopically and make sure that those scratches match each other where they've been cut into pieces.
Okay. I'm just going to put an X through this No. 1 to indicate your testimony that that is not evidence of alteration. The next point that I discussed with Mr. Groden was the alignment of the frame of Mr. Simpson walking through the end zone with the adjoining frame. Did you read Mr. Groden's testimony on that subject?
Okay. And Mr. Groden testified that those were the only two frames on the entire -- both contact sheets shot by Mr. Scull that were not in alignment. Was that true?
I believe I brought a couple of enlargements along. And also, I have a contact sheet here that we might put on the Elmo to demonstrate it.
Are these marked? Yes, those are the two. Your Honor, I'm going to mark next two in order.
Write it on the back. (The instrument herein described as Enlargement was marked for identification as Plaintiffs' Exhibit No. 2359.) (The instrument herein described as Enlargement was marked for identification as Plaintiffs' Exhibit No. 2360.)
Yeah. These I had prepared just for demonstrative evidence to show the jury and the Court how -- how big these movements are and also demonstrate how they're produced. Remember, when a canister of film or cassette of film goes into a camera and the film is brought across there, the whole purpose of that film is -- in there going through this particularly with a motor drive is its ability to move across the camera. It has to have enough motion in there, it has to have enough tolerances so that the camera can let the film go through fairly easy -- fairly easy rate so it doesn't scratch it, doesn't hurt it. If it's too tight, it will jam the film up. If it's too loose, it will wobble all over the place. The picture in question here of Mr. Simpson standing there, when you look at it in relationship -- it is frame 1, when you look at in relationship to frame 2, frame 2, as we look, and I'll orientate it so Mr. Simpson's head is to my right towards frame 2, frame 2 appears to be slightly higher, and I've drawn a scratch line through the emulsion all the way across and continued it on so you can get a feel for how much distance we are actually looking at there. The distance if it is measured on the negative is less than 1/250th of an inch. Now, you say how can we see that? Well, our eyes are very perceptive to small variations, particularly on a line like that, you can see on the contact sheet, but it is a very, very small amount of movement relatively, well within the tolerances of film moving up and down within the camera. I prepared another chart of frame 1 and 2 of the second roll of film; frame 1 being a Dolphin football player -- I don't know which one; sorry -- and then another picture of Mr. Simpson on there, and you draw a line across there, you will find just about the same identical amount of distance between frame 1 and frame 2. It really happens most commonly on frame 1 and frame 2 for the simple reason when the film is first put in, it's reasonably loose, and the cassette itself is not tight. So the film has an ability to move. And if I might show it -- I don't know if it would be better to show on the Elmo or in person.
(BY MR. GELBLUM) Can you -- are the lines on 2359, 2360, are they easy to see from a distance?
I'm going to move in very closely to the rails on here so you can see the rail and the film at the same time, and I'm going to press down on the film, and you can see the amount of movement we're dealing with there, up and down.
I object to this demonstration. Number one, obviously this isn't the camera in question because that was supposedly stolen. Number two, he's demonstrating this with the camera open. When that camera is closed, there's not nearly that much play. And I think it's misleading the jury.
THE COURT: Overruled. (The following proceedings were held in open court in the presence of the jury.)
Thank you. As I said, the motion here is actually somewhat more than 1/250th of an inch, and you can see on being the top and the bottom by the way the second rail there, the one we see by the sprocket holes, the very end of it, right at that point is what causes the little scratches you saw before, but currently it's motion we're looking at here as the film is originally put in. I'll hold it up because this may be a little easier to see here. The cassette itself has a lot of freedom and latitude to move up and down as we press the motor drive, particularly if we're shooting fairly fast, that film obviously will move each time that you yank it through there. It has the capability to move it slightly up or slightly down, that positions where the frame is as it goes through there. One other sample that it asked if it was shown anywhere else is on frame 16 and 17.
Yes, this is a slightly underexposed contact sheet because it's easier to see through transmitted light.
2361. (The instrument herein described as a contact sheet was marked for identification as Plaintiffs' Exhibit No. 2361.)
What I'm going to do is pull it back just far enough so we can see 16 and 17 and then line it up with those two and show that 18, 19 and 20 line up with it. Take me just a moment to align them. It will take me a moment. I'm not sure if you can see it readily, but in -- there is a two -- is it too far away yet?
(BY MR. GELBLUM) First of all, you're talking about the numbers -- you're talking about numbers on negative strip --
Yes, and it continues through 19 and 22. When I looked at it through a magnifier, it's about the same distance on the enlargements which I made which are easier to see. In essence, it's something that's somewhat random if -- as the film goes through there, if the photographer might have put his camera upside down and the cassette shifted a little forward, and again, we're talking about 1/10th of a millimeter, which is about 1/250th of an inch, have it shifted a little bit, that frame is going to shift a little bit. It might as it gets pulled back move one more a little bit as it gets pulled through there also quite often and it happens with most cameras, you get shifting, it's most common on the first few frames but you'll find it throughout.
With the Court's permission, I'd like to pass to the jury 2359 and 2360. Those are the ones that have the line through one. You saw these, right?
No, sir. It's quite a common function of the camera, and again, it's based on the tolerances that the manufacturers make to allow the film to go through, and as I mentioned before, unless you look extremely closely, you'd never notice it. It really has little significance.
(BY MR. GELBLUM) Now, on this point, same point, Mr. Groden made another point that if the camera -- if the film was moving in the camera --
(BY MR. GELBLUM) If the film was moving in the camera, you would expect to see a shift in the scratch as well, if in fact it was a scratch, in the same proportion as the film was moving? Did you read that testimony?
Not necessarily. You have to remember that these two occurrences are happening not simultaneously, they're happening separately. Again, that's possibly easiest to show with the F1 itself, but the image is formed in the center here where the hole is. That allows -- where the shutter opens up and allows the light through. The scratch is formed off to the right here. So the image may be formed with the cassette and the film pushed up here, but when you press the button it yanks it through, as I said, and pulls it down or pulls it up. It doesn't necessarily have to coincide with the -- with the format or the frame of the image itself that's being created.
No. The film as exposed -- I guess the easiest way is to demonstrate it. The image is now wrong one. Now being exposed, and when I released the shutter it's on but no image is being exposed on bulk. I relies it now -- the scratch is being made. It's two different functions altogether.
Mr. Groden also told this jury that the frame of Mr. Simpson walking through the end zone was longer than all of the other frames on the contact sheet. Did you read that testimony?
Well, I measured when -- when I was -- when I originally examined the negatives themselves as a matter of course, that particular negative I measured and I measured it against the next closest one, which was negative number 2. Both negatives had the identical dimensions, which was 36-by-24, which is a normal -- 36 millimeters by 24 millimeters, which is a normal 35 millimeter negative. I also made the same measurements on the contact sheet, and the contact sheet is an exact one-to-one representative of the -- of the negative.
Yes. Basically the piece of paper that makes a contact sheet -- and just as easy to pull one out -- such as this is placed down on an easel. The film in this case for these contact sheets -- there's two ways of doing it. You can leave the film in the sleeves, those plastic sleeves that they come in, or you can take them out and you can lay them down one by one, place them on top of the paper, put a piece of glass on top of that and expose it with a light source. That makes the contact sheet so it's pressed one to one to the paper. So any measurements that are on the contact sheet will be the same exact measurements that are on the negative. There's no reduction or enlargement because of the way it's produced. In this particular case, the press measurements I made were with a very precise scale that measures to 1 -- basically 1/10th of a millimeter, which is the equivalent of 1/254th of an inch, or 1/250th of an inch, to round it out.
Was there any difference in size between this frame of Mr. Simpson walking through the end zone and any of the other frames on the contact sheet?
No, there wasn't a tenth of a millimeter variation. There was no variation whatsoever. It was exactly 36 millimeters.
KEY QUOTEHave you also measured -- compared the frame of Mr. Simpson walking through the end zone to another frame on the roll with a compass, as Mr. Groden said he did?
Perhaps while the jury's passing these around, do you want -- can you set up and demonstrate to the jury on the Elmo the measurements that you made.
Yes, I could, with the judge's permission. Thank you, sir. The scale that I use is a highly precise scale, as I said. It measures to about 1/10th of a millimeter, 1/250th of an inch. If you'll pardon me on this, because it is so precise and the lines are so small, it's made on glass, and I have to use magnification myself to be able to see the lines. So if you'll hold on a second.
The reason I used an underexposed contact sheet, because the portions we're interested in measuring here and viewing are not the image portions, but they're actually the edges, the dark part, and by underexposing the negative, we can actually see the detail in those much, much better. This is the scale that I'm using. Again, the lines are so thin, you really can't see them readily without some type of magnification. It's traceable back to the old National Bureau of Standards, and like I said, it has a dimension -- the smallest dimension you can read on there is 1/10th of a millimeter. What I will try to do is -- if we can get the other one on, there we go -- blow it up so you can actually see the scale on the -- on the images themselves show no differences. Would you do me a favor and go on up there and see when it's clear. I can't see when it's clearest.
This is just a double loupe I use for examination. It allows me to see the image much, much clearer. It has two magnifiers. I believe it -- this is a 5 X magnifier in the glass and it has another loupe for the right eye, 10 X, so I can see the lines to place them exactly on the edge of the photographs. This is what I usually use for most of my examinations, as a matter of fact. The first one we're going to look at, a picture of Mr. Simpson, I'll place the zero line right on the right portion, and if you look at the monitor, it should read exactly 3.6.
There it is. And I think you can observe, if you can see it, it falls right on the 6, 3.6, not 3.61 or 3.59, but 3.6, right on the button.
Before you move on, sir, you say 3, the numbers at the top of the scale, 01, 02, 03, what are those?
Thank you. And did you do the same kinds of measurements with other frames on the contact sheet?
I randomly went through and measured probably 15 more frames -- 10 to 15 more frames on this contact, and then I also measured the ones on the second roll, and all of them measured exactly 36 millimeters.
Now, Mr. Groden said that he made a photocopy at a Kinko's or some such place and made his measurements on that. Is that an accurate way to make a measurement for any legitimate photographic expert?
Well, in the area of photogrammetry or making measurements from photographs, one cardinal rule, you never use a photocopy, and the simple reason for it, as most document examiners know in that field, is most photocopiers do not reproduce exactly what you think they may produce. In other words, most photocopiers will slightly enlarge or slightly reduce in one direction or both directions, depending on the photocopier, and I'd say 90-plus percent of them will do this. You never know how much it's going to expand. It does not do it many times linearly even, so that the expansion may vary across a page. I brought a little chart that -- basically it's just a graph I pulled out of my desk drawer, and ran it through my photo machine before I came here and taped it together to show you how much off my particular one is that I have in my office. But virtually it works with almost any photo machine.
KEY QUOTEIn this particular case, my photo machine -- photocopier is off in both directions significantly.
Overruled. (The instrument herein referred to as Document depicting squares was marked for identification as Plaintiffs' Exhibit No. 2362.)
Mr. Gelblum, if you can tell Mr. Foster -- if Mr. Foster will show the upper left-hand corner fairly close to see the area to see that fairly lined up. I don't know if you can see the red. You can pick it up, Mr. Foster, to show . . .
One is overlaid right on top of the other one. A red one in combination with the black one.
The original is red it's Mylar based graph you can buy in most art stores. Again, I use it as a demonstrative sample to show you why you can't do it from photocopies, why you can't make measurements. Now go to the lower -- excuse me -- lower right-hand corner. As we go down, you're going to see the squares come apart.
Yeah, ran it through my photocopy machine, aligning the left-hand corner. You can see how much difference there is by the time you get down to the lower right. If you're enlarging two photographs the same way, two square photographs the same way, and then enlarging them beyond enlargements factor of the photo copier, the one on the left-hand side, which would be your upper left-hand corner which we just saw, would be one size, and the one to the right would be another size. It would have -- in this particular case it would have elongated, and when you make measurements, they wouldn't match.
Let's cross out the light as evidence of alteration, then. (Indicating to handwritten chart.) Next point I talked about with Mr. Groden was, he suggested there was some sort of a false edge underneath the frame of Mr. Simpson walking through the end zone.
Steve, do you have the slide there, Mr. Groden's slide? Put up 2282, 3, just to remind the jury what we're talking about. Enlarge that (indicating to Elmo). Move it up please, Steve. (Mr. Foster adjusts exhibit on Elmo.)
(BY MR. GELBLUM) Did you read Mr. Groden's testimony about what he called a false edge on the photograph down here?
Mr. Groden said there was no natural situation in photography that would give you that false edge by itself. Is that true?
No. This is really -- I was a little confused initially by it because I couldn't quite understand what was being said because it is such a common thing and it's just such a natural thing that most first-year photo students immediately would know what it was.
It's basically the first frame, which is called -- particularly on Fuji film, is called frame 0. There's also a frame 00 that's before frame number 1. And if I might use the camera again to help demonstrate. When you load your film into a camera, any camera such as this -- let's see if it's going to load back up here. We load the camera up when the cassette comes out, when you take it out of the box and out of the container, you have a little -- the leader. This is the leader of the film and the leader is already exposed, as you can see. What you do is place it onto the other end by the sprocket so the take up reel can pull it on through, as we've demonstrated a couple times. I just fired it the first time there. Normally, when you would load it in, the next step would be to close the back of the camera and then fire a couple more times until the 1 shows on the top of your camera. I think most people have experience doing this. Well, what you don't realize is just before that film is in there now, still hasn't been exposed, it hasn't been exposed to the light. So if you don't have a cap over the front of the camera or you don't put your hand over it, which is my habit of doing it, when you fire it like that, actually two exposures are being made, they're not anything you're planning, but they are being made nonetheless, and most people have experienced when they get a roll of film back, many times the first one is a picture of their feet, the floor or the ceiling, that's the first one, and it's usually frame 0, and the first thing you do is throw it away. Well, in this particular case, what has happened is frame 0 came up, and it's actually a picture of the football field at the stadium there, and when it was taken, it was clicked off with a pair of scissors. And I did -- again, if Mr. Foster would assist.
I did a little drawing and ran a roll through showing frame 0 and 00 and clipped it off in the same -- approximate same manner, just to illustrate to you what has happened here, and then made a demonstrative chart to actually show you the football field.
Put first on top, then the negatives. I'd like to show them at the same time.
-- 63, and the roll of negatives as 2364. (The instrument herein described as a computer-generated graphic was marked for identification as Plaintiffs' Exhibit No. 2363.) (The instrument herein described as a roll of negatives was marked for identification as Plaintiffs Exhibit No. 2364.)
The computer-generated graphic here is something I made up on my computer very quickly. I want to make sure I'm out of the way here. This illustrates what would be frame 1, and the frame 0 where it was cut off, because, again, this was unwanted film. It was underexposed. It wasn't meant to be taken. It was just cut off, and it wasn't done too awful neatly, it's just a pair of scissors and clipped right off at this point. If you put on the negatives just below it, just push that up a little bit, and put them on below it, and then is it on back light, back light. This is a roll that I took -- back it off, if you would, just a little bit, please. Little more. Little more. Little more. Little more. There we go. (Indicating to Elmo screen.) Okay. This -- the leader -- the whole seven inches of film here is called the leader, basically. And on here, we have just a portion of the first picture, because this portion has been exposed. I pulled it out to put it into the sprocket and the take-up reel. The next shot, which is frame 00, is this shot (indicating). And I just literally shot it in the hotel room, just to put a picture on there that you could see. And then the next one is frame 0, which was in the same hotel room, just so you could see. Then I clipped it off, just leaving a little slice left on it, exactly like is on the photograph of Mr. Simpson. And then this would be the equivalent -- this next frame here of Mr. Simpson's photograph here. In essence, what it is, is, when it was processed, it was just cut off. In examining it very closely, I found it is a picture of the field. When Mr. Scull loads -- loaded his camera -- when you normally load an F 1, you do not load it in a turn like the picture of Mr. Simpson is taken in, horizontal. You load it -- I mean, in a vertical. You load it in a horizontal manner. Again, if you you're not paying attention, the wrong lens, you have no lens covers for -- most of them do not -- you're just loading it as you saw me load it there. Before he loaded it --
Your Honor, I object. This calls for speculation at this point. He has no idea what Scull did.
Marked next in order as 2365? (The instrument herein referred to as demonstrative chart was marked for identification as Plaintiffs' Exhibit No. 2365.)
2365. -- is, I have -- I had just the bottom portion underexposed again, so that we could see the actual portion in question at the bottom here. And if you turn it horizontal, like the film would have been loaded through, we can see white lines, diminishing as they go up the frame. These are the white lines of the field while standing at the end zone. And, as a matter of fact, if you look very, very closely at the third line here, you can actually see a little red at the top white, and then a little blue, and the 20-yard line at that stadium, as can be illustrated. I think we have a picture of that. Do we have the enlarged contact sheet?
Your Honor, we may have to pass this around to make it easier to see than on the contact.
We'll mark 2366, the enlarged contact sheet of the roll that has the picture of Mr. Simpson walking through the end zone. (The instrument herein referred to as Enlarged contact sheet of the roll that has the picture of Mr. Simpson walking through the end zone, was marked for identification as Plaintiffs' Exhibit No. 2366.)
(Continuing.) If we compare it with the exact contact sheet, we can see, if we go to frame such as -- just select one kind of here at random frame 12, we can see the lines, the white lines diminishing or into the background, the same way we can see these white lines. Of course, this is a much bigger blow-up. There is a much bigger enlargement. The lines of diminishing off into the background, as they are here in this case, the camera was pointed down, so all we see is ground. In this case, the camera was pointed slightly off.
2365 is the enlargement of the frame in question, and the 2366 is the enlarged contact sheet.
In addition, if we looked at 2366, the contact sheet, at frame 25, we can see the blue, red, and white lines, as that can just be seen on the third line from the bottom going up. You can just barely see the colors in it.
I don't have an objection. I didn't understand why, when they're talking about the two exhibits -- I'm trying to take notes.
2365 is the enlargement we're about to put on the Elmo of the bottom half of the frame in question of Mr. Simpson walking through the end zone. 2366 is the contact sheet.
(BY MR. GELBLUM) Can you tell the jury what you're pointing out with the red, white, and blue lines?
Yes. You have to tune it in. On the orientation it was taken, this would be the line (indicating). This would be the closest line to the photographer, the second one. And this is the third one here (indicating). That's probably the 20-yard line. Then it goes on -- on up until you no longer see it in there. It probably would be best to pass this one along, too, so you can see how the lines do diminish as you go.
Before you pass them, let me ask a couple more questions about them. Mr. Groden said that it was ridiculous to say that what you're saying is true, because among other reasons, there would be a vanishing point you would see in those lines. Did you read that testimony?
No, it is not. If the photographer is at the end of the field; the lines are parallel to his plane. In other words, they're parallel to the plane of the field. It's very similar to, if we look up at the lights, or if you happen to be looking up in this direction, in which you can see in the jury, if you look at different lines of the light, as we look down, they get shorter and shorter and shorter. And you can see it much better, like, out in the hallway. As we look down, each one of the horizontal lines will tend to compress or diminish, the farther it gets away.
Yes, I did. In fact, I actually brought one because Mr. Groden suggested that a railroad track --
I'm sorry. Yes, next in order. (The instrument herein referred to as Artist's drawing of a railroad track was marked for identification as Plaintiffs' Exhibit No. 2367.)
Would you put that up, please, the right-hand side -- the other side. Move it over --
Can you sharpen that up just a little bit? This is just an artist's drawing of a railroad track. And he is correct in saying that the lines here on the railroad tracks themselves, along with the wires above, all go to a vanishing point. What this means is, any lines that are parallel in a picture, will go to some -- some vanishing point -- actually, one of three vanishing points that are in a picture -- most artists and most photographers are well aware of it -- however, one -- one vanishing point can be infinity. It usually is when you have parallel lines that are parallel with the film plane. In this case, he was talking about the railroad tracks. What I am talking about is the ties in between them. And if you look at the ties, each one of these ties stay parallel with each other as they get smaller and smaller and smaller, and closer and closer together, as they go away from us, or as they're viewed away from us. The same way the lines in the field do here, and really the same way the lines do in the field here. (Indicating.)
Okay. Now, finally, on this -- before we pass that around, Mr. Groden also said that this couldn't be lines on the field, because the lines went past the edge of the horizontal edge there. Is that right?
No. On figure 2365, we can see the edge of the frame here. (Indicating.) And this is the edge of the frame. (Indicating.) We can also see where the corner is the same as the corner of the frame above it, which has Mr. Simpson in it. And the corner down here (indicating), it's just a clipped-off edge of the frame. Also, the distance between these frames -- and if I might have the one showing the full one of Mr. Simpson we had initially. No, that's with the 26. I'm sorry. First and second frame.
-- at the distance -- this isn't the best. There's another one that shows this particular frame at the bottom.
2368. (The instrument herein referred to as Enlargement was marked for identification as Plaintiffs' Exhibit No. 2368.)
Yes. It is 2368. You can see the distance between frame 0, down here, and frame 18 is illustrated at the bottom of the print. And it's the same identical distance as it is between frame 1 of Mr. Simpson and frame 2 up above. Again, this vertical position is not normally how a camera's held when it is loaded. It is held in this direction, horizontally. And again, this is a photograph of the field that was useless to the photographer, and it was just cut off when he put them -- inserted them into the -- into his sleeves for storage.
Why don't we pass around 2365 and 2366, then. Again which line on 2365, you see the red, white, and blue on the 20-yard line?
You have to turn it the way it should be naturally done. It would be the third one up from the bottom. We have 1, 2, 3, as we're going from bottom to top.
The next point on the chart that Mr. Groden made is that he said he saw a retouching mark in the left pants leg. Did you read that testimony?
Steve, could you put on the monitor, please, 2282, number 68. This was Mr. Groden's exhibit, to remind the jury what we're talking about here. (Exhibit 2282 displayed.)
(BY MR. GELBLUM) He said there was a discontinuity in the grain pattern in the lower leg. Did you examine the negative and the contact sheet and the prints of this photograph in that area?
The grain pattern is consistent throughout. The shade is different, but the grain pattern is consistent throughout.
Now, Mr. Groden said he saw the retouching mark in print -- what he called a retouching mark on a print, not on the negative. If you, as a photographic expert, see some kind of a mark or something that looks strange on a print, would you assume immediately that that is some evidence of alteration?
Well, no. If I'm examining a photograph and I see a mark that I do not understand what it is, I do not automatically attribute it to falsification or alteration or changing it. It's just a mark I don't understand, and it has to go through two more procedures. One, I have to find out what it is. And when I find out what it is from, it is a natural mark that would be placed on there either through the processing or through the -- caused by the camera or perhaps some defect in the film, which happens really quite often, I would attribute it to that, and continue on. If I found it was some indication of alteration, then I would label it as such. If I did not know either way, that's the way I would have to label it, as I don't know either way, because I contribute it to something.
Can anomalies appear on prints because of the printing process, as opposed to -- and would not show up on the negative?
Yes; it happens all the time. As a matter of fact, in many of the prints that I have brought here today, there's a thing called neutron rings that you can see quite readily. They drive people who do printing crazy. But if they are small neutron rings, and you don't know what it is, and you've never been exposed to it before, you really don't understand what it is, you could very easily take that anomaly for a retouch mark.
If you see an anomaly on a print, would you want to look at the negative to see where it came from, or if it just came from the print?
Most definitely I would want a second print made, to make sure it wasn't of the print itself. If the second print doesn't have the anomaly, obviously, it was from the first print. And then secondly, I would like, if that shows the same basic -- if I got two prints showing the same mark, that is obviously coming from the negative, and I would want to examine it.
So do you see anything in the lower leg that, to you, is evidence of alteration of the left leg?
No. I looked at that particular pants leg, as I mentioned, with low magnification, high magnification, all the way to 60 power, under a microscope. I could find no suggestion, no indication whatsoever of retouch marks or alterations.
During your 25 of years of experience examining photographs, did you come to learn what retouching marks look like?
Now, Steve, can you put up the next one, which is 2282-7, number 7 again, Mr. Groden's exhibit.
(BY MR. GELBLUM) Mr. Groden testified that there was a -- what he called a linear tone, a change across the right leg. Did you review that testimony?
No, I do not. And, in essence, I examined it; I can find no significant linear tone, a change. What I mean by "significant" is, you do have tone, a change throughout there, as you can see. You have light areas and dark areas in the shadow areas of the pants, and partially where they're highlighted as they're folding back and forth. That's a tone change. But there is nothing inconsistent with that pants leg blowing in the breeze as a man is walking along. There is nothing in there that suggests that it would be a retouch mark or anything of that nature. It appears to be a highlight at the top of a fold, or what appears -- what I understand to be the mark that he has -- he is suggesting.
Let me show you 2287, which is the full-frame enlargements of the negative -- of the contact sheet of Mr. Simpson walking through the end zone. Can you show the jury, are there any tonal changes on the leg, other than the one Mr. Groden's talking about?
Not that I can -- well there's tonal changes throughout the entire leg. As I said, at each fold of the leg, the tone changes from light to dark, from shadow to highlight area. As it goes, continues on down from, you know, at the very lower portion of the leg, it was like a little snakey structure here of just the cloth rippling as you're walking along. And again, that's perfectly natural.
(BY MR. GELBLUM) Mr. Groden also said, as reflected on the chart I have in front of the jury there, that he saw a problem, because the frame of Mr. Simpson walking through the end zone had an overall reddish tint, and the other frames on the contact sheet had an overall cyan, or bluish-green tint. Did you read that testimony?
No, not in this particular case. And I don't have the contact sheet. I think the jury might be passing it around. That's quite common. Things reflect color, and there's a lot of color in these pictures. As a matter of fact, the blue monitor shining here reflects blue, or projects blue on the black cardboard underneath it. So the black cardboard takes on a blue tint to it. Mr. Simpson is surrounded by red, so some of that red diffused light is showing on, particularly white, or white shadow areas or dark shadow areas. It will show up on both. The reason that it's nowhere else as almost every other photograph in that frame, is the shadow areas are green or cyan, which is -- actually, cyan is a combination of blue and green -- is because they're standing -- most of the uniforms on there are cyan, and he's standing on green grass for most of them, so that those colors are being reflected into the white areas. And that's what you're seeing. Again, this is another tremendous problem, many times, for people who print color film, because they can't get those out very easily, without shifting the rest of the colors. They can't make white pure white without shifting the rest of the colors to get rid of those natural reflections. That, you'll find, is quite natural, for Mr. Simpson's shirt to be reflected red in there, since he's surrounded by red. He's standing on red. And the other people in all of the other frames are standing on a green turf, which is reflecting back to them.
There's two basic types of reflection: Diffused and spectral. Spectral reflection is like a mirror angle of incident equals angle of reflection. You shine a light in, it hits a mirror; whatever angle it is, it is the same angle it comes off the mirror. Diffused angle is lights that strike it, diffuses some all directions: Soft clothing, soft materials. Nonreflective materials diffuse light. They reflect light, but they don't reflect it in a specific direction. And if you have something close to it, it will -- it will reflect that light into that object, which will tint it.
Yes. Okay, ladies and gentlemen, 8:30 tomorrow. Don't talk about the case. Don't form or express any opinions. Don't read anything or watch anything about this. (The instrument herein referred to as Photograph showing item #102 was marked for identification as Defendant's Exhibit No. 1310.) (The instrument herein referred to as contact sheet was marked for identification as Defendant's Exhibit No. 1388.) (The instrument herein referred to as Photograph of Mr. Simpson was marked for identification as Plaintiffs' Exhibit No. 1830.) (At 4:30 P.M., an adjournment was taken until Wednesday, January 15, 1997, at 8:30 A.M.)
Basically, the blue line on the photograph showing Mr. Simpson is a scratch line from the rails of the Canon F1 camera. It's quite a common scratch line, as a matter of fact... when I was Unit Chief of the Special Photographic Unit we had 1500 of them in our inventory.
No. The great majority of them have that blue line; I mean the same type of blue line, either on the bottom and the top or just one or the other.
In the area of photogrammetry or making measurements from photographs, one cardinal rule, you never use a photocopy... most photocopiers will slightly enlarge or slightly reduce in one direction or both directions, depending on the photocopier.
No, there wasn't a tenth of a millimeter variation. There was no variation whatsoever. It was exactly 36 millimeters.
I looked at that particular pants leg... with low magnification, high magnification, all the way to 60 power, under a microscope. I could find no suggestion, no indication whatsoever of retouch marks or alterations.