📄 Redirect examination of Robert Groden — Monday, January 6, 1997
Address:
C:\DEPT103\CIVIL\1997\JAN\6\REDIRECT-EXAMINATION-OF-ROBERT.DOC
TRIAL
▲ Day 36 of 57

Redirect examination of Robert Groden

Witness: Robert Groden
Examiner: Dan Leonard
Called by: Defense • Date: Monday, January 6, 1997 • Utterances: 210
Defense attorney Leonard uses redirect to rehabilitate Robert Groden after a damaging cross-examination, walking the jury through the personal circumstances behind Gelblum's attacks on Groden's background — a military discharge after being beaten by an anti-Semitic sergeant, strokes caused by a fall on ice, dropping out of high school for financial reasons, and selling a story to the Globe. Groden then returns to his photographic analysis of the film frames, demonstrating via sprocket hole measurements and scratch-line geometry why frame 1-1 is out of register, and methodically dismantling Gelblum's 'football field lines' theory with five separate reasons why that interpretation is a photographic impossibility.
1 A:

Good morning.

2 Q:

Before we get into some of the substance here I want to go through, based on some of Mr. Gelblum's questions in cross-examination, some of your background again. Mr. Gelblum asked you on cross-examination about your experience in the military and particularly the reason for and the basis for your leaving the military. Do you remember that?

3 A:

Yes.

4 Q:

Can you tell the jury -- can you explain to the jury why you left the military?

5 A:

A sergeant in my company was drunk and beat me up and to keep it under the rug, they gave me a discharge because of an existing sinus problem that I had that they weren't able to deal with. That was the excuse, but the real reason was, in fact, I had been beaten up by the sergeant.

6 Q:

Why did this sergeant beat you up, sir?

7 MR. GELBLUM:

Objection, speculation, relevance.

8 MR. LEONARD:

Your Honor --

9 THE COURT:

Overruled. You opened it.

10 A:

The sergeant was anti-Semitic and I'm Jewish.

KEY QUOTE
11 Q:

(BY MR. LEONARD) Now, do you think that the fact that you were beaten up -- by the way, how old were you, sir?

12 A:

18.

13 Q:

Do you think the fact that you were beaten up when you were 18 years old by an anti-Semitic sergeant has anything to do with your ability to observe the phenomena that you observed and also to explain them to the jury?

14 A:

No, not at all.

15 Q:

Mr. Gelblum asked you about strokes that you had had. How did you happen to have strokes, can you explain that to the jury?

16 A:

About two years ago I was walking in a parking lot and slipped on a patch of ice and hit my head, which precipitated a series of strokes.

17 Q:

And from time to time have you some memory problems as a result of that; is that right?

18 A:

That's correct.

19 Q:

Do you think that has affected your ability whatsoever to analyze the photograph and to explain your analysis to the jury?

20 A:

Not at all.

21 Q:

Now, Mr. Gelblum got into some extent your experience with the House Assassination Committee. Do you remember that?

22 A:

Yes.

23 Q:

I asked you in some detail what your role was, correct, do you remember that?

24 A:

Yes.

25 Q:

And in particular he was asking you if you had done any actual analysis of photographs on behalf of, or in conjunction with your work with the Kennedys, do you remember those questions?

26 A:

Yes.

27 Q:

Now, in fact, did you do a photo analysis?

28 A:

Yes.

29 Q:

At some point, there was a panel of photographic experts, correct?

30 A:

Yes.

31 Q:

Okay. And you were working in conjunction -- you weren't a member of the panel, you were working in conjunction with the panel; is that correct?

32 A:

That's correct.

33 Q:

And was there -- did there come a time when a proficiency test was undertaken of the panel and that you participated in that? In other words, a test to determine the proficiency of the experts and also yourself in analyzing and determining whether the photographs are fake or real?

34 A:

Yes.

35 Q:

Okay. Describe just in very general terms that proficiency test that was done?

36 A:

A few members of the photo panel were assigned to create four sets of photographs, genuine photographs that look genuine, genuine photographs that appear to be fake, fake photographs that appear genuine, and fake photographs that were obviously fake. And the set of all four of those were placed as a package, they were numbered and packaged, and a written test was given to the entire photo panel and myself to determine the ability to detect phonies and to detect fake phonies, in fact.

37 Q:

How did you do on that test?

38 A:

I got 100 percent.

39 Q:

Did anyone else get 100 percent?

40 A:

No, none of them did.

41 Q:

Mr. Gelblum asked you if you had dropped out of high school. Did you drop out of high school, sir?

42 A:

Yes.

43 Q:

Why was that?

44 A:

We didn't have very much money and my going to school and remaining there was a strain on my mother. My mother and father had just separated and it was my sister, myself and my mother, and it was a real financial drain on her.

45 Q:

When you dropped out of high school is that when you went into the military?

46 A:

That's correct.

47 Q:

By the way, you have a high school degree, don't you?

48 A:

Yes.

49 Q:

How did you get that?

50 A:

When I was in the army I took the general equivalency diploma, GED test and passed it with flying colors, and also got a year's college credit the same way.

51 Q:

Does the fact that you had to drop out of high school, you think that affects your ability to do the analysis you did here and to explain your results to the jury; you think that affects it at all, sir?

52 A:

No.

53 Q:

Mr. Gelblum asked you about a situation where you had contributed to a story to the Globe newspaper. Do you remember that?

54 A:

Yes.

55 Q:

Now, Mr. Gelblum, in his questioning, was trying to suggest that you were --

56 MR. GELBLUM:

Objection, Your Honor.

57 THE COURT:

Sustained.

58 Q:

(BY MR. LEONARD) Explain to the jury, No. 1, what that -- what the story was, in general terms, and whether or not it was your purpose to sell photographs as opposed to the story itself, sir?

59 A:

When I was a staff photographic consultant to the House Assassinations Committee I had made the discovery that the autopsy photographs of President Kennedy, at least some of them, were questionable as to their authenticity based on physical anomalies within the photograph itself, and my knowledge of the statements of Dallas doctors who had worked on President Kennedy in the lifesaving efforts on November 22nd of '63, and also of medical personnel who had worked on the -- on the president after that time and in Bethesda Naval Hospital. The photographs did not show what was described by every one of the doctors. I had gone to the Chief Counsel of the House Committee which was Professor Blakey and suggested, very strongly, perhaps it would be a good idea to show those questionable photographs to the Dallas doctors to determine their authenticity. For two solid years Professor Blakey refused to do it. When the committee broke up and didn't exist anymore I was very disturbed by the fact that this had not been resolved, so I took copies of autopsy photographs and went to the Dallas doctors and other witnesses who dealt with the body, including Dealey Plaza witnesses, and I showed them the photographs, and every single one of them without exception said that the photographs were indeed fake, and I then knew that I was correct. And I felt that the public needed to know this, I thought it was a major issue, and an issue of the Kennedy assassination.

60 Q:

Now, was -- was the Globe, the Globe newspaper your first choice of a medium to get this out to the public, sir?

61 A:

No.

62 Q:

Did you -- had you attempted to go to other publications to try to get this story out to people?

63 A:

Yes.

64 Q:

Were your efforts unsuccessful?

65 A:

They were unsuccessful, yes.

66 Q:

Did you prepare a documentary on this issue of the autopsy photographs?

67 A:

Yes, a videotape documentary.

68 Q:

Now, Mr. Gelblum also asked you about the backyard photograph of Oswald; do you remember that?

69 A:

Yes.

70 Q:

Okay. You did an analysis of that photograph?

71 A:

Yes.

72 Q:

And you came to the opinion that the photograph was fake; is that right?

73 A:

That's correct.

74 Q:

Now, there was -- there were some people in the committee that agreed and some that disagreed with regard to that; is that true, sir?

75 A:

That is correct.

76 Q:

Subsequent to your analysis -- by the way, there are others who agreed with you in that respect; is that correct?

77 A:

Yes, within the committee. Also photographic experts for the Royal Canadian Mounted Police and Scotland Yard have also agreed.

78 Q:

Now, when you were on cross-examination today, you were shown some photographs of the court to show Mr. Simpson wearing particular shoes and particular clothing. When was the first time you've ever seen those photographs?

79 A:

Right here in this courtroom a few minutes ago.

80 Q:

Mr. Gelblum asked you if we had spoken about the photographs. Did we speak about the photographs?

81 A:

We did.

82 Q:

When was our discussion with regard to the photographs, sir?

83 A:

I believe he asked me if I had seen them, and I had not.

84 Q:

Was it your understanding, sir, that those photographs have just been miraculously discovered since you testified here last?

85 MR. GELBLUM:

Objection, argumentative.

86 MR. LEONARD:

Withdrawn.

87 Q:

(BY MR. LEONARD) Is it your understanding, sir, that those photographs have just arisen for the first time since you testified here?

88 MR. GELBLUM:

Objection.

89 A:

That's correct.

90 MR. GELBLUM:

His understanding is irrelevant. Move that his answer be stricken.

91 THE COURT:

Overruled. State of mind of this witness.

92 Q:

(BY MR. LEONARD) Do you have any idea, sir, whether those photographs are authentic or not?

93 A:

None at all.

94 Q:

Do you have any idea who created the photograph, when the photograph was taken, whether or not the photograph was sold to a tabloid or anything like that, sir?

95 A:

None at all.

96 Q:

Now, you said to this jury that seeing those photographs for a short period of time, just glimpsing them does not change your opinion about your analysis of this photograph. Tell the jury why, sir.

97 A:

The anomalies, the problems that I found within that photograph are still there. Existence of other photographs that have not been verified, which I haven't had a chance to examine, don't change the fact that the problems of that photograph are there, they certainly are, and 100 more pictures are not going to change that.

KEY QUOTE
98 Q:

Now, let's get -- let's talk a little bit about a couple of other points that Mr. Gelblum raised on cross-examination about the photograph itself.

99 MR. LEONARD:

I'd like to put up the first image, please. I don't believe this has been marked. Has it? Oh, it has.

MR. P. BAKER: This is 1835. (Exhibit 1835 displayed.)

100 MR. LEONARD:

Zoom in on the right upper corner.

101 Q:

(BY MR. LEONARD) First of all, I'd like to --

102 MR. LEONARD:

Pull back, Mr. Baker, if you will. (Elmo adjusted.)

103 MR. LEONARD:

Can you give me the number again.

MR. P. BAKER: 1835.

104 Q:

(BY MR. LEONARD) What does 1835 represent, sir?

105 A:

Its a blowup of the frame we've been referring to as 1-1, contact sheet 1, frame No. 1.

106 Q:

Is there also a portion of the -- very small portion of the bottom edge or the side edge depending on how you look at it, of 1.2?

107 A:

That's correct. Right at the very top which is almost off the frame here.

108 Q:

Okay. Now --

109 A:

Yes.

110 MR. LEONARD:

If we can focus in. (Elmo adjusted.)

111 Q:

(BY MR. LEONARD) All right. Now, you see the vertical line -- and actually there appears to be two lines; there's one vertical line that runs -- it appears to run across from 1-1, to 1-2; do you see that, sir?

112 A:

Yes.

113 Q:

Now, Mr. Gelblum suggested in his questioning --

114 MR. GELBLUM:

Objection, Your Honor, mischaracterizes my question.

115 THE COURT:

Sustained.

116 Q:

(BY MR. LEONARD) Have you had a chance to -- you've had a chance to look at this image, have you not, sir?

117 A:

Yes.

118 Q:

Okay. First of all, is there anything about this image that supports your opinion that this first, that 1.1 is -- is out of register? That is, that 1.1 is not aligned with 1.2?

119 A:

Yes, definitely.

120 Q:

Can you demonstrate that to us. You can step down with the Court's permission.

121 MR. LEONARD:

Can the witness step down?

122 THE COURT:

Yes.

123 MR. LEONARD:

Thank you.

124 A:

It's extremely obvious here without -- without even measuring it, though I guess we could measure it if we want to, that the difference between -- the space between the scratch itself and the edge of frame 1-1 is much closer than it is on 1-2. 1-2 is, I'd say, probably twice as far away from the scratch, indicating even better than a straight edge that it's out of alignment.

125 Q:

Okay. Now, of course, that assumes that that scratch is straight, correct?

126 A:

Yes.

127 Q:

Okay. Now, if this is -- if this is supposed to be a mechanical scratch from a camera, okay, would you assume that it would be straight?

128 A:

Yes.

129 Q:

Okay.

130 MR. LEONARD:

If you can pull the photograph back, please, all the way back, please.

131 Q:

(BY MR. LEONARD) Now, utilizing this same image, sir, is there another way that you can demonstrate the fact that this negative or this frame is out of line, out of register?

132 A:

Yes. It's kind of difficult here because you can't see the sprocket holes, but by measuring the sprocket holes to the edge of the frame the picture is measurably closer to the sprocket holes on the right side as we view it than it is on the left.

133 MR. LEONARD:

If you can focus in on the --

134 A:

There we go. Now you can see it.

135 Q:

(BY MR. LEONARD) Now, if you point out the outline of the sprocket hole, sir, in particular the left edge of the sprocket hole.

136 A:

Can we try to focus a little more. Great. Okay. This is the left edge of the sprocket hole here and this is the edge of the frame.

137 Q:

Okay. Now, can you go down to the left-hand corner. Now --

138 A:

Okay.

139 Q:

Directing your attention to the edge of the sprocket hole there.

140 A:

It's right here. Right here. (Indicating.)

141 Q:

And the edge of the frame?

142 A:

Right here. (Indicating.)

143 Q:

Now, the distance between the -- that distance is larger than the distance on the right-hand side, that is the same measurement that is from the edge of the sprocket hole to the edge of the frame; is that right?

144 A:

That is correct.

145 Q:

Okay.

146 MR. LEONARD:

You can pull back. (Indicating to Elmo.)

147 Q:

Now, you were asked questions about whether or not the negative could be out of line or out of register by virtue or as a result of some play or movement in the film; is that correct? Do you remember that?

148 A:

Yes, I remember that.

149 Q:

And you expressed an opinion that it wouldn't be possible for it to be that out of line; is that correct?

150 A:

That's correct.

151 Q:

Again, I want you to assume now that for purposes of my question that, in fact, the line along the right-hand side between the sprocket hole and the edge of the film is a mechanical scratch from the camera. Are you with me?

152 A:

Yes.

153 Q:

Okay. Does -- Would you expect the -- if there was movement in the film would you expect that line, that scratch to be straight, sir?

154 A:

Yes. You'd expect it to run -- well, the length of the film.

155 Q:

Okay. If there was movement, if there was play in the film and the film was jiggling, would you expect that line to be straight or would you expect that there would be indicia of the movement within the scratch, sir?

156 A:

If the film were shifting from a -- running horizontally, it's shifting top to bottom, would you expect the scratch to be diagonal by the degree that the frames would be out, and that's not the case.

157 Q:

In other words, what we have here is --

158 MR. LEONARD:

If you can focus in on the right-hand side of the image, please.

159 Q:

(BY MR. LEONARD) You see the -- what appears to be a blue lining there, sir?

160 A:

Yes.

161 Q:

What you're saying is that if the camera was moving you'd expect to see a shift in the line; is that correct?

162 A:

That's correct. In order for the -- in order for the frame to have been off because of film movement, you would expect that that line would be diagonal in the same direction as the shift of the frame.

163 Q:

So if it was shifting to the right you'd expect some shifting in the line; is that correct?

164 A:

That's correct.

165 Q:

Do you see any there, sir?

166 A:

No.

167 Q:

Now, if -- let's assume that that is a scratch from the camera in question, all right, the camera that was actually used to take whatever image was there before. If you were going to create a copy negative, a composite negative, and you wanted to hide your tracks would you use the same camera, sir?

168 A:

Well, you'd have to if you expected that it would be investigated, yes.

169 Q:

Why?

170 A:

Well, scratches from a camera could be I guess compared to fingerprints; they should be unique or unique to some degree to each camera. In other words, if there's a manufacturing flaw in one particular camera, a burr, for instance, that could cause a scratch and you wouldn't expect to find that on every camera.

171 Q:

So you -- and so what would be the purpose again for using the same camera, sir?

172 A:

Again, and we saw this happen in the investigation of the backyard photographs of Lee Harvey Oswald, scratches were determined to be linked to that particular camera. And in this particular case, if indeed these are scratches, that could be linked to that camera, you would want to have those scratches on the -- on the film.

173 Q:

Now, assuming that you're making a copy, composite negative, and you want to cover your tracks, what do you do with the camera once you -- what would you do with the camera once you created the copy negative?

174 A:

You get rid of it.

175 Q:

What did Scull say happened to the camera in this case in his deposition, sir?

176 A:

He claimed it was stolen.

KEY QUOTE
177 Q:

Okay. You didn't have a chance to look at the original camera, did you?

178 A:

No.

179 Q:

Okay.

180 MR. LEONARD:

You can put up the -- take that down. Yeah.

MR. P. BAKER: No. 3 of 2282.

181 Q:

(BY MR. LEONARD) Now, can you tell us what this depicts, sir?

182 A:

This is frame 1-1 from the contact sheet showing the edge of the film against the edge of the contact sheet itself.

183 Q:

Okay.

184 A:

And --

185 Q:

I'm sorry. Go ahead.

186 A:

I would just say it has one horizontal line and several vertical lines.

187 Q:

Now, you were asked on -- on cross-examination if that could be actually a photographic image on -- on what would be I guess 00, and in particular the photographic image of the football field. Can you explain to the jury how that is impossible, sir?

188 A:

Well, for several reasons.

189 Q:

If you need to focus why don't you direct Mr. Baker's attention.

190 A:

Okay. Mr. Baker, if you could just kind of come in and make this as large as possible, side to side, I'd appreciate it.

MR. P. BAKER: That's as high as it goes.

191 MR. LEONARD:

Just focus in. That's the highest focus. All right. Okay. That's fine.

192 A:

Can I come down?

193 Q:

Sure.

194 A:

Upon the suggestion of Mr. Gelblum that this might be the football field, I have spent a little more time checking this out because it sounds so ridiculous and I found out that in fact it could not be that. No. 1, if this is the edge of an incoming frame line as he's suggesting, how is it that the so-called lines of the football field extend beyond the edge of the frame where no light could possibly hit. No. 1.

KEY QUOTE
195 Q:

Okay.

196 A:

No. 2, these lines are random.

197 Q:

What do you mean by that, sir?

198 A:

They are not an equal distance from each other.

199 Q:

What do you know about a football field that makes that point relevant, sir?

200 A:

Well, how would you know how far the ball had traveled if you didn't have an accurate measurement between the lines. They would have to be an equal distance from each other. They'd have to have a vanishing point. If these were parallel lines and if the photographer were shooting away, either on purpose or by accident, there would be a vanishing point which is --

201 MR. LEONARD:

Why don't you -- let's put -- we can illustrate that. Why don't you put up -- with the Court's permission, I can put up the drawing pad.

202 THE COURT:

All right.

203 MR. LEONARD:

Thank you.

204 Q:

(BY MR. LEONARD) There's a marker.

205 A:

There's one right there.

206 Q:

Okay.

207 A:

No matter what the focal lengths of the lens is, whether it's a wide angle lens like a 28 or 35 millimeter or a normal lens like a 50 to 85 millimeter or a wide angle lens -- I'm sorry, a telephoto lens like a 500, 1500, something of that nature, I end up with something called a vanishing point. That's something used in art as well as photography, and that is at some point away from the lens you're going to have a point where parallel lines run together. If you stand on a railroad track and look towards the distance they tend to run together, and the point where they disappear and become one line is call the vanishing point. If the camera lens is here and aiming this way, and there are lines on a football field they would appear like this, and depending on the focal length of the lens they would still all run together. These are absolutely parallel. So that's another problem with it. The third problem is that they are far too sharp and they're too narrow. Lines on the football field would be much wider than this. The other problem is that these are blue and lines on the football field would be white. There's probably other problems too, but I think the major problem is that this image falls outside of where the frame line would be. That's a photographic impossibility.

208 Q:

You can resume the stand.

209 A:

Thank you.

210 Q:

Is there anything, sir, that has been discussed on your cross-examination including the photographs that you were shown for the first time that changes your opinion at all with regard to this photograph?

Temperature

tense

Key Quotes (5)

Witness
The sergeant was anti-Semitic and I'm Jewish.
Direct rebuttal to Gelblum's insinuation that Groden's military discharge reflected poorly on his character or competence.
Witness
I got 100 percent.
Groden claims he outperformed every credentialed expert on the House Assassinations Committee proficiency test for detecting fake photographs — the single strongest credential boost on redirect.
Witness
He claimed it was stolen.
Groden ties the disappearance of Scull's camera to the pattern of covering tracks after creating a composite negative, a pointed implication of fabrication.
Witness
Upon the suggestion of Mr. Gelblum that this might be the football field, I have spent a little more time checking this out because it sounds so ridiculous and I found out that in fact it could not be that.
Groden dismisses Gelblum's cross-examination theory with visible contempt and then backs it up with five technical arguments.
Witness
The anomalies, the problems that I found within that photograph are still there. Existence of other photographs that have not been verified, which I haven't had a chance to examine, don't change the fact that the problems of that photograph are there, they certainly are, and 100 more pictures are not going to change that.
Groden holds his opinion steady despite being shown new photographs of Simpson wearing the Bruno Magli shoes for the first time during cross.

Evidence (3)

Exhibit 1835
Blowup of contact sheet frame 1-1 (and partial edge of frame 1-2), used to demonstrate the out-of-register alignment via scratch-line and sprocket-hole measurements
displayed, demonstrated in person by witness
Exhibit 2282, No. 3
Frame 1-1 from the contact sheet showing the edge of the film against the edge of the contact sheet, containing the disputed horizontal and vertical lines
displayed, witness stepped down to demonstrate against 'football field' theory
Informal
Photographs of OJ Simpson wearing particular shoes and clothing, shown to Groden for the first time during cross-examination moments before redirect
discussed, witness states he had never seen them before entering the courtroom that day

Notable Exchanges (3)

LeonardGrodenGelblum
Leonard methodically rehabilitates every attack Gelblum made on Groden's background — the military discharge, strokes, GED, and Globe story — with Groden providing sympathetic context for each. Gelblum objects when Leonard begins to characterize his own questions, drawing two sustained objections.
strategic
GrodenLeonard
Groden steps down from the stand twice to demonstrate in person using the Elmo projector: first showing via sprocket-hole distances and scratch geometry that frame 1-1 is out of register, then drawing a vanishing-point diagram to show why the disputed lines cannot be football field yard markers.
technical
LeonardGroden
Leonard walks Groden through the chain of logic connecting the camera scratch to the missing camera: scratches are like fingerprints unique to a camera, so a forger using the same camera would need to get rid of it afterward — and Scull claimed his camera was stolen.
revealing

Light Moments (1)

Witness
Groden describes the football field theory as 'sounds so ridiculous' before dismantling it with five technical arguments, drawing a vanishing-point diagram and explaining railroad tracks converging in the distance.

Credibility Attacks (2)

⚔ Robert Groden
prior bad acts / background impeachment
Gelblum on cross had attacked Groden's military discharge, history of strokes, failure to complete high school, and decision to sell Kennedy autopsy photographs to the Globe tabloid. Leonard rehabilitates each on redirect by eliciting sympathetic explanations: anti-Semitic assault, accidental fall on ice, family poverty, and inability to get mainstream publications to run the story.
⚔ Robert Groden
bias / lack of qualifications
Gelblum questioned whether Groden had actually performed independent photo analysis for the House Assassinations Committee (vs. merely working alongside the panel). Leonard rehabilitates by establishing Groden participated in the panel's proficiency test and scored 100 percent — the only participant to do so.

Witness Demeanor

(Witness steps down from the stand to use the Elmo projector, twice)
(Witness draws a vanishing-point diagram on a drawing pad in open court)
(Indicating.) — multiple times while pointing to sprocket holes and frame edges on projected image

Objections

5 objections (2 sustained, 2 overruled)
Proceeding 8746 • 210 utterances • Defense witness
Civil Trial
Department 103
⚖️ Start
📂 JAN 6, 1997 📄 Redirect examination of Robert
JAN 6, 1997 KRT DvH TD