📄 Cross-examination of Andrea Mazzola (morning, part 4) — Tuesday, April 25, 1995
Address:
C:\DEPT103\CRIMINAL\1995\APR\25\CROSS-EXAMINATION-OF-ANDREA-MA.DOC
TRIAL
▲ Day 61 of 167

Cross-examination of Andrea Mazzola (morning, part 4)

Witness: Andrea Mazzola
Examiner: Peter Neufeld
Called by: Prosecution • Date: Tuesday, April 25, 1995 • Utterances: 693
Defense attorney Peter Neufeld continued his methodical cross-examination of LAPD criminalist Andrea Mazzola, focusing on failures in crime scene photography (no rulers or directional arrows in evidence photos), the detectives' control over which evidence was collected, and the absence of confirmatory blood tests on collected samples. Most damaging was Neufeld pinning Mazzola to three contradictory versions of who collected blood drops at Rockingham: in August 1994 she testified she collected all of them, last Thursday she testified Fung alone collected items 4, 5, and 6, and today she testified they both did — with no notes, documents, or conversations to explain the shift.
1 THE COURT:

All right. Miss Mazzola, have you had enough time to look at that?

2 MS. MAZZOLA:

Yes, I have.

3 THE COURT:

All right. Do you need a magnifying class or anything like that?

4 MS. MAZZOLA:

No.

5 THE COURT:

All right. Proceed.

6 MR. NEUFELD:

Have you had an opportunity to look at the photograph of the Bronco?

7 MS. MAZZOLA:

Yes.

8 MR. NEUFELD:

And that is a photograph of the Bronco at the print shed, ma'am?

9 MS. MAZZOLA:

Yes, it is.

10 MR. NEUFELD:

And that is the way it appeared on June 14th?

11 MS. MAZZOLA:

Yes.

12 MR. NEUFELD:

And, ma'am, now that you've had a chance to look at that photograph of the Bronco, I now ask you once again--actually--

13 (Brief pause.)
14 MR. NEUFELD:

Having looked at that photograph and now also once again looking at 1097, can you see that on the monitor?

15 MS. MAZZOLA:

Yes.

16 MR. NEUFELD:

Would you agree, ma'am, that if the--have you seen that long enough?

17 MS. MAZZOLA:

Yes.

18 MR. NEUFELD:

Okay. Now, would you agree that in order to see the specks that are in the upper of the two circles--see the two circles, one on top of each other?

19 MS. MAZZOLA:

Yes.

20 MR. NEUFELD:

--that in order to see those two specks, the door would have to be in the open position?

21 MR. GOLDBERG:

Calls for opinion, conclusion, no foundation.

22 THE COURT:

Sustained. Rephrase the question. Foundation.

23 MR. NEUFELD:

One moment.

24 MR. NEUFELD:

When you went out to the scene on the 14th, you systematically examined the Bronco exterior; did you not?

25 MR. GOLDBERG:

Vague as to systematically.

26 THE COURT:

Overruled. As to scene, do you mean the print shed?

27 MR. NEUFELD:

At the print shed.

28 MR. NEUFELD:

Right?

29 MS. MAZZOLA:

Yes.

30 MR. NEUFELD:

In fact, that's what your vehicle search inspection list requires you to do, to make a systematic examination of the exterior of the car; isn't that right?

31 MS. MAZZOLA:

Yes, it does.

32 MR. NEUFELD:

And you did that with Dennis Fung?

33 MS. MAZZOLA:

Correct.

34 MR. NEUFELD:

And you examined the door of the car, correct?

35 MS. MAZZOLA:

Yes.

36 MR. NEUFELD:

And you examined it both in the closed position and the open position, correct?

37 MS. MAZZOLA:

Yes.

38 MR. NEUFELD:

And based on--now, what you examined that day, in the open position and closed position of the door and having looked at these photographs, would you agree that in order to see the specks in the upper circle, that the door would have to be in the open position?

39 MR. GOLDBERG:

Still calls for conclusion, no foundation.

40 THE COURT:

Overruled.

41 MS. MAZZOLA:

It's hard to say. I'm not sure how far the bottom of the Bronco flares out from the pictures. I can't say if it would have to be open or closed.

42 MR. NEUFELD:

Ma'am, in the pictures that you have in front of you, doesn't the door of the Bronco come down flush with the outer edge of that sill in the pictures that you have?

43 MS. MAZZOLA:

I'm not sure if it's flush or not. There's a bottom strip that could be out a little further. In the picture, it's a little hard to tell.

44 MR. NEUFELD:

One moment.

45 (Discussion held off the record between Defense counsel.)
46 MR. NEUFELD:

By the way, Miss Mazzola--to the--to the best of your recollection, ma'am, you didn't even see the specks in that upper circle on the 14th, did you?

47 MS. MAZZOLA:

To the best of my recollection, I did not.

KEY QUOTE
48 MR. NEUFELD:

And you did not see the speck in the lower circle, did you?

49 MS. MAZZOLA:

No.

50 MR. NEUFELD:

And you did not see the smear or grayish or--I am sorry--discoloration indicated in the third circle, did you?

51 MS. MAZZOLA:

No.

52 MR. NEUFELD:

You didn't see any of those on the 14th, did you?

53 MS. MAZZOLA:

To the best of my recollection, I did not.

KEY QUOTE
54 MR. NEUFELD:

Right. Miss Mazzola, you didn't see them on the morning of the 13th either, did you?

55 MS. MAZZOLA:

I wasn't--

56 MR. GOLDBERG:

Assumes a fact that she looked.

57 THE COURT:

Overruled.

58 MS. MAZZOLA:

On the 13th, I don't believe I was looking that carefully.

59 MR. NEUFELD:

Miss Mazzola, you were shown the car on the 13th by the detectives, didn't you? Weren't you?

60 MS. MAZZOLA:

Yes.

61 MR. NEUFELD:

And you walked over with the detectives and Dennis Fung to examine the Bronco, didn't you?

62 MS. MAZZOLA:

Yes.

63 MR. NEUFELD:

And in fact, I think you said that you personally even swatched the stain on the handle of the Bronco, didn't you?

64 MS. MAZZOLA:

Yes.

65 MR. NEUFELD:

And that stain was pointed out to you by Detective Fuhrman, wasn't it?

66 MS. MAZZOLA:

I'm not sure which one pointed it out.

67 MR. NEUFELD:

Well, you were there when Detective Fuhrman pointed it out to--oh, I'm sorry. Withdrawn. You were at the Bronco with Dennis Fung and the detectives when one of the detectives pointed out a small speck near the handle on the driver's door; isn't that correct?

68 MS. MAZZOLA:

That's correct.

69 MR. NEUFELD:

And at that point in time, when that speck was pointed out to you and Dennis Fung, no other speck was pointed out to you and Dennis Fung on the exterior of the car; isn't that correct?

70 MS. MAZZOLA:

I don't remember. I just remember the one on the driver's handle.

71 MR. NEUFELD:

Well, with respect to your independent recollection, Miss Mazzola, as it stands today, is it fair to say that you have no independent recollection of any detective showing you any other speck or stain on that car other than the speck next to the driver's handle?

72 MS. MAZZOLA:

That I can recall, no.

73 MR. NEUFELD:

That's what I'm asking you. Your independent recollection, from what you can recall.

74 MS. MAZZOLA:

My independent recollection, no.

75 MR. NEUFELD:

Thank you. By the way, Miss Mazzola, when you do a phenolphthalein test, have you been taught that there are confirmatory tests that you can do back at the laboratory?

76 MS. MAZZOLA:

That is why we collect the positive stains.

77 MR. NEUFELD:

And the reason--I'm sorry. And the confirmatory tests that can be done back at the laboratory would tell you whether or not it was in fact blood as opposed to some other substance which created a false positive; isn't that correct?

78 MS. MAZZOLA:

I am not in the serology section. I--I don't know.

79 MR. NEUFELD:

Well, I'm not asking you for what tests is done. I'm asking you whether or not you were told that there are tests that are done back at the serology laboratory to confirm whether or not an item which you suspected might be blood was in fact blood as opposed to something else?

80 MS. MAZZOLA:

It's possible, yes.

81 MR. NEUFELD:

And there are also confirmatory tests that you've been taught about which can tell you whether something is human blood as opposed to some animal blood; isn't that right?

82 MS. MAZZOLA:

I have heard of those tests, yes.

83 MR. NEUFELD:

And as you sit here today, ma'am, referring to those specks that you collected which are item 20 on the passenger door--

84 MS. MAZZOLA:

Yes.

85 MR. NEUFELD:

--to your knowledge, has there ever been any confirmatory test done to determine whether or not that speck on the door was human blood?

86 MR. GOLDBERG:

I think misstates a fact not in evidence.

87 THE COURT:

Sustained. It's a vague question. Which--you're referring to item 20 in photograph number--Defendant's 1113, correct?

88 MR. NEUFELD:

Yes, I am.

89 THE COURT:

All right. Do you understand the question, Miss Mazzola?

90 MS. MAZZOLA:

Item 20, the three specks on the passenger door. Is that what he's referring to?

91 THE COURT:

Right.

92 MR. NEUFELD:

What I'm asking you is, with respect to the specks on the door, okay, item 20--

93 THE COURT:

Right. Passenger--Excuse me, counsel. You keep on saying specks and Mr. Harris put up another photograph. We're talking about 1113, passenger door specks, 20, correct?

94 MR. NEUFELD:

Yes.

95 THE COURT:

All right. Proceed.

96 MR. NEUFELD:

With respect to those two specks that you see in the picture to the left of the no. 20, to your knowledge, has there ever been a confirmatory test to determine whether or not those specks are human blood?

97 MR. GOLDBERG:

Calls for hearsay, irrelevant.

98 THE COURT:

Overruled. Do you know if they were tested?

99 MS. MAZZOLA:

I do not know if they were tested.

KEY QUOTE
100 MR. NEUFELD:

When the detectives showed you the speck the morning of the 13th on the driver's door, not no. 20, but the speck on the driver's door, that was right after Dennis Fung and the detectives had this discussion; is that correct?

101 MS. MAZZOLA:

Yes.

102 MR. NEUFELD:

And was Dennis Fung with you when the detectives pointed out the speck on the driver's door?

103 MR. GOLDBERG:

Assumes facts not in evidence, detectives.

104 THE COURT:

Overruled.

105 MS. MAZZOLA:

Yes.

106 MR. NEUFELD:

Now, at both Rockingham and Bundy, did the detectives tell you which items to collect?

107 MS. MAZZOLA:

They showed us different items and between talking with Mr. Fung, they all decided which ones should be collected as evidence.

108 MR. NEUFELD:

Dennis Fung and the detectives decided?

109 MS. MAZZOLA:

Correct.

110 MR. NEUFELD:

One second, your Honor.

111 (Brief pause.)
112 THE COURT:

Take your time.

113 MR. NEUFELD:

I'm sorry. What?

114 THE COURT:

Take your time.

115 (Brief pause.)
116 MR. NEUFELD:

During your training at the SID mini academy, did you receive handouts from time to time on how to conduct crime scene investigations?

117 MS. MAZZOLA:

We received various handouts, yes.

118 MR. NEUFELD:

Okay. Ask this be marked next in order.

119 THE COURT:

1115? Defense 1115.

120 (Deft's 1115 for id = handout)
121 MR. NEUFELD:

I'll show you what's been marked as Defendant's 1115, ask you to take a look at it. Read it to yourself.

122 (Witness complies.)
123 MR. NEUFELD:

Ma'am, was that handout--I'm sorry. Was that document one of the handouts that you were given at the LAPD?

124 MS. MAZZOLA:

I honestly can't remember if it was or not.

125 MR. NEUFELD:

You're saying it doesn't refresh your recollection whether it was?

126 MS. MAZZOLA:

No. No.

127 MR. NEUFELD:

In your presence, did Dennis Fung outside the presence of the detectives ever independently go out and look for evidence?

128 MS. MAZZOLA:

Not in my presence I don't think.

129 MR. NEUFELD:

When you arrived at Bundy that day, did the detectives make you wait until they removed both bodies?

130 MS. MAZZOLA:

I waited back on the sidewalk. Mr. Fung did not.

131 MR. NEUFELD:

Well, did you wait back on the sidewalk because the detectives had asked you to wait?

132 MS. MAZZOLA:

No.

133 MR. NEUFELD:

Well, had the detectives asked you to wait before you began your own work until the bodies had been both removed?

134 MS. MAZZOLA:

They did not ask me personally, no.

135 MR. NEUFELD:

Well, did they ask Dennis Fung in your presence?

136 MS. MAZZOLA:

No.

137 MR. NEUFELD:

Well, had you been taught, Miss Mazzola, that when you first get to a crime scene, you are to make a quick search for perishable evidence? Is that something you've been taught at SID?

138 MS. MAZZOLA:

Yes.

139 MR. NEUFELD:

And as you stood there when you arrived, you saw that the Coroners were in the process of moving bodies; were you not?

140 MS. MAZZOLA:

Yes.

141 MR. NEUFELD:

Did you when you first arrived go forward then into the crime scene to conduct a quick search for perishable evidence?

142 MS. MAZZOLA:

I did not personally, no.

143 MR. NEUFELD:

And why is it that you didn't do that, Miss Mazzola?

144 MS. MAZZOLA:

Because Mr. Fung was up in the area.

145 MR. NEUFELD:

Well, did you actually--from where you were standing on the sidewalk, you could observe Mr. Fung, couldn't you?

146 MS. MAZZOLA:

For the most part, yes.

147 MR. NEUFELD:

And when you saw Mr. Fung go into the area, he was carrying the brown paper bag which had the glove in it, didn't he?

148 MS. MAZZOLA:

I don't believe he had it the first time he went up.

149 MR. NEUFELD:

All right. The first time he went up, did you see Dennis Fung making a--making an examination for perishable or easily movable evidence?

150 MS. MAZZOLA:

I don't remember seeing him.

151 MR. NEUFELD:

You don't remember seeing him do that, do you?

152 MS. MAZZOLA:

No. I don't remember seeing him.

153 MR. NEUFELD:

Well, you don't remember seeing him at all?

154 MS. MAZZOLA:

I saw him up in the scene. I don't remember exactly what he was doing.

155 MR. NEUFELD:

Well, where in the scene was he when you saw him?

156 THE COURT:

At what point, counsel?

157 MR. NEUFELD:

When you were standing out on the sidewalk and they were moving the bodies, what did you see or where did you see Dennis Fung standing?

158 MS. MAZZOLA:

Up in the area where they were removing the bodies.

159 MR. NEUFELD:

Was he on the sidewalk or was he on the steps?

160 MS. MAZZOLA:

I can't remember.

161 MR. NEUFELD:

And do you have any idea what he was doing when he was in there?

162 MS. MAZZOLA:

No.

163 MR. NEUFELD:

Well, now that you've done that examination, okay, of that crime scene that day, you do know that he wasn't removing perishable or other small items near the bodies; is that correct?

164 MR. GOLDBERG:

No foundation, personal knowledge.

165 THE COURT:

Overruled. Do you understand the question?

166 MS. MAZZOLA:

I believe so.

167 THE COURT:

All right. Go ahead and answer.

168 MS. MAZZOLA:

I do not believe that he was removing any perishable items at that time.

169 MR. NEUFELD:

Nor was he removing any small items that were in close proximity to the bodies, was he?

170 MS. MAZZOLA:

No. He did not appear to be, no.

171 MR. NEUFELD:

Did you say to Dennis Fung before he walked into the crime scene that, "We should quickly look for perishable and other small items since they're removing the bodies"?

172 MS. MAZZOLA:

No.

173 MR. NEUFELD:

Did Dennis Fung say something to that effect in your presence to the detectives?

174 MS. MAZZOLA:

In my presence? I do not believe so, no.

175 MR. NEUFELD:

And you would agree that trace evidence can be transferred carelessly when bodies are moved?

176 MS. MAZZOLA:

It is possible, yes.

177 MR. NEUFELD:

Well, you were taught that, weren't you?

178 MS. MAZZOLA:

Yes.

179 MR. NEUFELD:

In your presence, did you ever hear Dennis Fung, your supervisor, tell the detectives not to move the bodies until he first made an inspection of the scene for perishable or other small items?

180 MR. GOLDBERG:

Irrelevant.

181 THE COURT:

Overruled.

182 MS. MAZZOLA:

In my presence, no.

183 MR. NEUFELD:

Now, at 7:00 A.M., you said when--that's when you arrived. A little bit after 7:00 A.M., you arrived at Rockingham with Dennis Fung?

184 MS. MAZZOLA:

If I may check my notes.

185 MR. NEUFELD:

Sure. You don't have an independent recollection as to what time you arrived?

186 MS. MAZZOLA:

Not independent recollection, no.

187 MR. NEUFELD:

Okay.

188 MS. MAZZOLA:

It was approximately around 7:00 A.M., yes.

189 MR. NEUFELD:

And you said that you overheard the discussion that Dennis Fung had with the detectives at that time; is that right?

190 MS. MAZZOLA:

Bits and pieces, yes.

191 MR. NEUFELD:

All right. And the detectives showed you around the grounds before you began collecting any stains; isn't that correct?

192 MS. MAZZOLA:

Yes.

193 MR. NEUFELD:

And at that point, the detectives told you which items to collect; isn't that right?

194 MS. MAZZOLA:

They pointed out items that they were interested in.

195 MR. NEUFELD:

well, when they pointed out items that they were interested in, they were telling you that the items that they were interested in were the items that you and Dennis Fung should collect; isn't that right?

196 MS. MAZZOLA:

Those and others if we found any, yes.

197 MR. NEUFELD:

Well, did you find other items out there in the driveway of Mr. Simpson's house other than what was pointed out to you by the detectives?

198 MS. MAZZOLA:

In the driveway, no.

KEY QUOTE
199 MR. NEUFELD:

And so as to the items in the driveway, the detectives told you which items to collect?

200 MS. MAZZOLA:

Yes.

201 MR. NEUFELD:

But you didn't even bother collecting any of the stains until 8:15; isn't that right?

202 MR. GOLDBERG:

Well, it's vague as to didn't bother. That's argumentative.

203 THE COURT:

Sustained.

204 MR. NEUFELD:

Sorry. You didn't collect any of the stains until at least 8:15; is that right?

205 MS. MAZZOLA:

May I check the time?

206 MR. NEUFELD:

Sure.

207 (Brief pause.)
208 MS. MAZZOLA:

The stain on the Bronco was collected approximately 8:15.

209 MR. NEUFELD:

Okay. And that was the first stain to be collected?

210 MS. MAZZOLA:

Yes, it was.

211 MR. NEUFELD:

And the stains in the driveway were collected after that, right?

212 MS. MAZZOLA:

Yes.

213 MR. NEUFELD:

Okay. Miss Mazzola, did you at any time after the discussion was over between Dennis Fung and the detectives say to the detectives, "Wait. We should go to Bundy first and examine that scene before they move the bodies"?

214 MS. MAZZOLA:

I did not, no.

215 MR. NEUFELD:

Did Dennis Fung say something to that effect in your presence to the detectives?

216 MS. MAZZOLA:

Not in my presence, no.

217 MR. NEUFELD:

Now, what about--and that conversation would be around 7:30 in the morning; is that right?

218 MS. MAZZOLA:

Maybe a little before.

219 MR. NEUFELD:

A little before 7:30. Maybe 7:20?

220 MS. MAZZOLA:

Somewhere between the time we arrived and we started collecting.

221 MR. NEUFELD:

Okay. So you didn't say anything to the detectives about the necessity of going to Bundy before they moved the bodies at 7:20 or 7:30 in the morning; is that right?

222 MR. GOLDBERG:

Asked and answered, argumentative.

223 THE COURT:

Sustained. Rephrase the question or move on.

224 MR. NEUFELD:

All right. Well, let's see. What about 8:00 A.M.? 8:00 A.M., you still hadn't collected the first stain. You knew at that point in time that there were bodies at Bundy that would have to be moved; did you not?

225 MR. GOLDBERG:

Argumentative, compound.

226 THE COURT:

Calls for speculation too.

227 MR. NEUFELD:

Well, had you been told prior to 8:00 A.M. that there were bodies in connection with this homicide case at Bundy?

228 MR. GOLDBERG:

Calls for hearsay.

229 THE COURT:

Overruled.

230 MS. MAZZOLA:

I knew that there were bodies at Bundy.

231 MR. NEUFELD:

And you knew from your experience and training that the Coroner's office would be there to move those bodies; did you not?

232 MS. MAZZOLA:

I did not--

233 MR. GOLDBERG:

Vague as to time.

234 THE COURT:

Overruled.

235 MS. MAZZOLA:

I did not know if the Coroners would be there or not.

236 MR. NEUFELD:

Well, you knew that at some point in time, the Coroners would come to the scene to remove the two victims; did you not?

237 MS. MAZZOLA:

At some point, yes.

238 MR. NEUFELD:

All right. Did you ask the detectives whether or not the bodies had been removed yet at 8:00 A.M. in the morning before you started collecting stains at Rockingham?

239 MS. MAZZOLA:

No.

240 MR. NEUFELD:

Did Mr. Fung ask the detectives that in your presence?

241 MS. MAZZOLA:

Not in my presence.

242 MR. NEUFELD:

Now, after you collected the drop on the Bronco, it was still--it was not until 9:00 o'clock that you began picking up the other drops in the driveway; is that right?

243 MS. MAZZOLA:

May I check the notes?

244 MR. NEUFELD:

Please do.

245 (Brief pause.)
246 MS. MAZZOLA:

Yes. Approximately 9:00 A.M.

247 MR. NEUFELD:

Okay. So at this point, you had already been at the scene, ma'am, an hour and a half approximately; is that right?

248 MS. MAZZOLA:

Not quite an hour and a half.

249 MR. NEUFELD:

And you knew that bodies--there were two bodies of two victims at the Bundy location, correct?

250 MS. MAZZOLA:

Yes. There were two victims at Bundy.

251 MR. NEUFELD:

And you knew that just from your experience, that at some point in time, Coroners would have to move those two bodies, correct?

252 MS. MAZZOLA:

Yes, they would have to remove them.

253 MR. NEUFELD:

And you had also been taught, had you not, Miss Mazzola, in terms of crime scene evidence collection methods that it is preferable to examine the crime scene before bodies are removed for small items of perishable items? Had you been taught that?

254 MR. GOLDBERG:

Compound; small and perishable.

255 THE COURT:

Haven't we gone through this already?

256 MR. NEUFELD:

We have. I'm just trying to--

257 THE COURT:

We have. We have. Let's proceed.

258 MR. NEUFELD:

Okay. Now, at both Rockingham and Bundy, photographs were taken of the various bloodstains; is that right?

259 MS. MAZZOLA:

That's correct.

260 MR. NEUFELD:

And for many of those photographs, were the photo cards set up by Dennis Fung?

261 MS. MAZZOLA:

Yes.

262 MR. NEUFELD:

And in the photographs that were set up by Dennis Fung--

263 MR. NEUFELD:

One moment.

264 (Brief pause.)
265 MR. NEUFELD:

--he did not place a ruler in the scene, did he?

266 MS. MAZZOLA:

I don't remember if he did or not.

267 (Brief pause.)
268 MR. NEUFELD:

Your Honor, with the--

269 THE COURT:

Mr. Neufeld, which board is this?

270 MR. NEUFELD:

I'm sorry. What?

271 THE COURT:

Which board is this?

272 MR. NEUFELD:

Oh, it's People's 120.

273 THE COURT:

Thank you.

274 MR. NEUFELD:

All right. With the Court's permission, may the witness step down?

275 THE COURT:

Yes. What happened to our pointer there? Ah, there we go.

276 MR. NEUFELD:

Ma'am, in your training at SID, were you taught that when you take a photograph of a bloodstain or other item of evidence, that you should use a ruler in the photograph? Is that something you were taught?

277 MS. MAZZOLA:

No.

278 MR. NEUFELD:

Well, did you receive a handout which described how photographs should be taken at crime scenes?

279 MR. GOLDBERG:

It's vague as to photographs.

280 THE COURT:

Overruled.

281 MS. MAZZOLA:

I believe we did, yes.

282 MR. NEUFELD:

All right.

283 (Brief pause.)
284 (Discussion held off the record between Defense counsel.)
285 MR. NEUFELD:

Okay. Ask this be marked for identification next in order.

286 THE COURT:

1116.

287 (Deft's 1116 for id = handout)
288 MR. NEUFELD:

116--

289 THE COURT:

1116, one six.

290 MR. NEUFELD:

Thank you.

291 MR. NEUFELD:

Show you what has been marked--

292 MR. GOLDBERG:

Peter, may I see that?

293 MR. NEUFELD:

Oh, sorry.

294 (Brief pause.)
295 MR. NEUFELD:

Show you what has been marked as Defendant's 1116, ask you to take a look at those two pages. Miss Mazzola, is 1116, Defense 1116, the handout that you received on forensic photography?

296 MS. MAZZOLA:

I don't know if it's the exact handout that we received.

297 MR. NEUFELD:

Could be?

298 MS. MAZZOLA:

It's possible.

299 MR. GOLDBERG:

Well, it calls for speculation. Motion to strike.

300 THE COURT:

Overruled.

301 MR. NEUFELD:

You said it could be?

302 MS. MAZZOLA:

Could be, could not be.

303 MR. NEUFELD:

Well, you say you recall receiving a handout on forensic photography; did you not?

304 MS. MAZZOLA:

Yes.

305 MR. NEUFELD:

were you taught at the SID, Miss Mazzola, that acceptable crime scene photography should tell a story by itself absent of any written or oral narration? Were you taught that concept?

306 MS. MAZZOLA:

Something like that, yes.

307 MR. NEUFELD:

And were you taught, Miss Mazzola, at SID that the photographs should have some scale in it so a person who's looking at the photograph will know how big the object is?

308 MR. GOLDBERG:

It's vague as to what type of photograph.

309 THE COURT:

Overruled.

310 MR. NEUFELD:

Were you taught that?

311 MS. MAZZOLA:

I don't remember if we were or not.

312 MR. NEUFELD:

Well, Miss Mazzola, let me--just for a second, look at what is here in this picture, photograph b on Prosecution's exhibit 120. Do you see it?

313 MS. MAZZOLA:

Yes.

314 MR. NEUFELD:

And do you see a red stain in the picture?

315 MS. MAZZOLA:

Yes.

316 MR. NEUFELD:

And would you agree, ma'am, that if there was no ruler in that picture, you would have--a viewer would have no idea how large that stain is? Would you agree?

317 MS. MAZZOLA:

Yes.

318 MR. NEUFELD:

and isn't it true that because of that fact, you were taught at SID that it is important to put some kind of scale or ruler in a photograph so when someone looks at the photograph, they will have an idea as to how large the stain is?

319 MS. MAZZOLA:

That is possibility, to have a ruler in the scene.

320 MR. NEUFELD:

I'm not asking you whether it's a possibility, ma'am. I'm asking you whether or not your instructors at the Los Angeles Police Department Scientific Investigation Division taught you that for forensic photography, that you should put or instruct the photographer to put a ruler in the picture when you take a picture of a bloodstain so that anyone else who is looking at it will know how big the stain is.

321 MS. MAZZOLA:

I don't believe they told us that. Forensic photographers know how to photograph evidence. It's up to them.

322 MR. NEUFELD:

Miss Mazzola, isn't the job of the criminalist to instruct and direct the forensic photographer at the scene? Isn't that one of your responsibilities?

323 MS. MAZZOLA:

It is the supervising Criminalist's responsibility.

324 MR. NEUFELD:

Fine. So it's Dennis Fung's responsibility, is that what you're saying, to instruct the forensic photographer how to take the pictures at the scene?

325 THE COURT:

Excuse me, counsel. If you would, she was mid answer when you started asking the next question. Allow her--

326 MR. NEUFELD:

I apologize, your Honor.

327 THE COURT:

--to finish--thank you.

328 MS. MAZZOLA:

Would you please repeat it?

329 MR. NEUFELD:

So would it be fair to say that it was Dennis Fung's responsibility as the senior criminalist at the scene to instruct the forensic photographers on how to take the pictures of various items of evidence?

330 MS. MAZZOLA:

Not as to how, but which items he wanted photographed.

331 MR. NEUFELD:

Isn't it--weren't you instructed, Miss Mazzola, to make sure there was comprehensive coverage of each item of evidence at the crime scene?

332 MS. MAZZOLA:

Yes.

333 MR. NEUFELD:

And weren't you instructed, ma'am, to make sure that the forensic photographer takes close-up shots as well as distant shots of each item of evidence?

334 MS. MAZZOLA:

Photographers are trained to--

335 MR. NEUFELD:

I--I'm sorry.

336 MS. MAZZOLA:

Go ahead.

337 MR. NEUFELD:

I asked whether you were instructed to make sure that that happens, you being a criminalist.

338 MS. MAZZOLA:

We were given information on the way the forensic photographers photograph crime scenes.

339 MR. NEUFELD:

And who brings the numbers that are put down to identify different items for the photographer to take pictures of?

340 MS. MAZZOLA:

We do.

341 MR. NEUFELD:

That's your job, the criminalist, right?

342 MS. MAZZOLA:

Right.

343 MR. NEUFELD:

You set the item numbers down?

344 MS. MAZZOLA:

Correct.

345 MR. NEUFELD:

And if you want the photographer--by the way, were you working with one photographer at Rockingham in the morning of July--of June 13th?

346 MS. MAZZOLA:

I believe we were. I can not be absolutely--

347 MR. NEUFELD:

It was the same photographer who at least shot the different stains in the driveway with you; isn't that right?

348 MS. MAZZOLA:

Yes.

349 MR. NEUFELD:

And it was Dennis Fung's job to instruct that photographer what he wanted in the photograph, wasn't it?

350 MR. GOLDBERG:

This has been asked and answered.

351 THE COURT:

Sustained.

352 MS. MAZZOLA:

Yes.

353 THE COURT:

Excuse me. Excuse me. Sustained.

354 MR. NEUFELD:

I didn't reask the question.

355 THE COURT:

I understand that. I'm just advising the witness if I sustain the objection--

356 MS. MAZZOLA:

I'm sorry.

357 THE COURT:

Thank you.

358 MR. NEUFELD:

And you said I believe--

359 THE COURT:

Excuse me. Excuse me. Mr. Neufeld, is there a reason we--are you still questioning as to this--

360 MR. NEUFELD:

Now I'm going to question about the board.

361 THE COURT:

All right.

362 MR. NEUFELD:

Okay. And I believe you said on direct examination that Dennis Fung was not with you when you collected item 7 and item 8 at Rockingham; isn't that right?

363 MS. MAZZOLA:

That's correct.

364 MR. NEUFELD:

And he was with you when items 4, 5 and 6 were collected; isn't that right?

365 MS. MAZZOLA:

Yes.

366 MR. NEUFELD:

And item 4 is shown--I'm sorry--in photograph a, correct?

367 MS. MAZZOLA:

Yes.

368 MR. NEUFELD:

And item 5 and 6 is shown in photograph c, correct?

369 MS. MAZZOLA:

Correct.

370 MR. NEUFELD:

Now, in items 5 and 6, is there a ruler in the photograph?

371 MS. MAZZOLA:

No.

372 MR. NEUFELD:

Did Dennis Fung instruct the photographer to place a ruler in the photograph?

373 MR. GOLDBERG:

Calls for speculation.

374 MR. NEUFELD:

In your presence.

375 MR. NEUFELD:

I'm sorry, your Honor. Is there a ruling on--

376 THE COURT:

No. You rephrased the question. I assume you withdrew it and rephrased it.

377 MR. NEUFELD:

No. I rephrased it for the--okay.

378 MS. MAZZOLA:

In my presence, no.

379 MR. NEUFELD:

And you were present when the photographs were taken?

380 MS. MAZZOLA:

For the most part, yes.

381 MR. NEUFELD:

And I think you said, ma'am--oh, let me ask you this. Were you also taught that when taking pictures of bloodstains, it may be important to know whether or not the bloodstain had some direction? Correct?

382 MS. MAZZOLA:

Yes.

383 MR. NEUFELD:

And to know whether it has some direction, one would want to know whether the direction is north, south, east or west, correct?

384 MS. MAZZOLA:

Correct.

385 MR. NEUFELD:

And for that purpose, ma'am, weren't you trained at the SID that when taking photographs of--of bloodstains, that somebody should at least put into the photograph an arrow pointing north? Weren't you taught that?

386 THE COURT:

Excuse me. Counsel--excuse me. Counsel, she's the probationary trainee. Mr. Fung was in charge and there was a photographer taking these pictures. So this is interesting, but not tremendously relevant to this witness.

387 MR. NEUFELD:

Well, did--there's only one photograph here that has an arrow and a northerly direction on it; isn't that right?

388 MS. MAZZOLA:

There appears to be, yes.

389 MR. NEUFELD:

And that's for item 7, correct?

390 MS. MAZZOLA:

Correct.

391 MR. NEUFELD:

And item 7, Dennis Fung wasn't with you when you collected it, correct?

392 MS. MAZZOLA:

Correct.

393 MR. NEUFELD:

In fact, the person that was with you when you collected item 7 was a--one of the most senior supervisors in the whole SID, correct?

394 MS. MAZZOLA:

Correct.

395 MR. NEUFELD:

And what's his name?

396 MS. MAZZOLA:

Mr. Steve Johnson.

397 MR. NEUFELD:

And did Mr. Johnson direct that the "N" in the arrow be placed in the photograph?

398 MS. MAZZOLA:

I do not remember.

399 MR. NEUFELD:

Well, did you direct that it be placed in the photograph?

400 MS. MAZZOLA:

No.

401 MR. GOLDBERG:

Your Honor--

402 MR. NEUFELD:

You may sit down. (The witness complies.)

403 MR. NEUFELD:

Would you agree, ma'am, that in terms of the drops that were collected, 4, 5, 6, 7 and 8, that for those drops that do not have a ruler in the picture, there is no record of the size of those drops?

404 MS. MAZZOLA:

That is correct.

405 MR. NEUFELD:

And would you agree, ma'am, that for the drops at Bundy, there is no ruler in any of those photographs?

406 MS. MAZZOLA:

I believe that is so.

407 MR. NEUFELD:

You believe it's so, that there is no ruler in any of those photographs?

408 MS. MAZZOLA:

That is correct.

409 MR. NEUFELD:

And so would you also agree that there is no record for the size of any of these bloodstains at Bundy--of the drops on the walkway?

410 MS. MAZZOLA:

That is correct.

411 MR. NEUFELD:

And would you also agree that all blood drops are not the same size?

412 MS. MAZZOLA:

That is definitely correct.

413 MR. NEUFELD:

And as you sit here today 10 months later, do you have an independent recollection of the size of each bloodstain at Rockingham and Bundy?

414 MS. MAZZOLA:

No.

415 MR. NEUFELD:

And at any time while you were at Rockingham and Bundy, did Dennis Fung instruct you to note the size of each of the bloodstains in writing on the field notes?

416 MR. GOLDBERG:

Your Honor, this is irrelevant and under 352, I object.

417 THE COURT:

Overruled.

418 MS. MAZZOLA:

No, he did not.

419 MR. NEUFELD:

Well, would you agree, ma'am, that the size of the bloodstain is an indication of how much blood is present?

420 MS. MAZZOLA:

That is not necessarily so.

421 MR. NEUFELD:

I said is one indication of how much blood is present.

422 MS. MAZZOLA:

It could be one indication, yes.

423 MR. NEUFELD:

All right. And would you agree, ma'am, that how much blood is present would indicate how much DNA one would expect to isolate from a bloodstain?

424 MS. MAZZOLA:

I am not a serologist. I do not know.

425 MR. NEUFELD:

Have you at any point in your instruction been told that the larger the bloodstain, the more DNA one would expect to get from the bloodstain? Has that been taught to you?

426 MR. GOLDBERG:

Irrelevant.

427 THE COURT:

Sustained. She's already testified to that issue, counsel.

428 (Brief pause.)
429 MR. NEUFELD:

One moment.

430 (Brief pause.)
431 (Discussion held off the record between Defense counsel.)
432 MR. NEUFELD:

Miss Mazzola, did you personally do the phenolphtalein test on the speck next to the driver's handle?

433 MS. MAZZOLA:

Yes.

434 MR. NEUFELD:

And did you do that at the direction of Dennis Fung?

435 MS. MAZZOLA:

Yes.

436 MR. NEUFELD:

And after you did the phenolphtalein test and it came up magenta, pink, you collected that swatch, correct?

437 MS. MAZZOLA:

Correct.

438 MR. NEUFELD:

And to your knowledge, to this day, Miss Mazzola, has any confirmatory test ever been done to make sure that that speck was human blood?

439 MR. GOLDBERG:

Asked and answered, hearsay.

440 THE COURT:

Overruled. Overruled. Do you know if any confirmatory test was done on that?

441 MS. MAZZOLA:

I do not know.

442 THE COURT:

Proceed.

443 MR. NEUFELD:

Now, back at Rockingham in the morning of June 13th, isn't it a fact that you personally and exclusively collected every drop of blood that was seen at Rockingham?

444 MS. MAZZOLA:

Mr. Fung assisted on a few of the drops.

445 MR. NEUFELD:

When you say that Dennis Fung assisted on a few of the drops, what do you mean by that?

446 MS. MAZZOLA:

That he also took some swatches.

447 MR. NEUFELD:

And on which items did he--do you now say that he also took some swatches?

448 MR. GOLDBERG:

Your Honor, this has been asked and answered, this whole thing.

449 THE COURT:

Rephrase the question.

450 MR. NEUFELD:

You say this morning that Dennis Fung assisted you on some of the stains?

451 MS. MAZZOLA:

Correct.

452 MR. NEUFELD:

And you say what you mean by assisting you, that he took some of the swatches?

453 MS. MAZZOLA:

Correct.

454 MR. NEUFELD:

Do you mean that for some items, you took some swatches and he took some swatches?

455 MS. MAZZOLA:

Correct.

456 MR. NEUFELD:

so on each of the items, you personally took swatches?

457 MS. MAZZOLA:

Correct.

458 MR. NEUFELD:

But at least as to some, he also took some swatches; is that correct?

459 MS. MAZZOLA:

Correct.

460 MR. NEUFELD:

Ma'am, when you testified on direct examination or on cross-examination last Thursday, didn't you say that with respect to items 4, 5 and 6, that Dennis Fung alone was the collector of those items and not you? Wasn't that your testimony just this last Thursday?

461 MS. MAZZOLA:

I don't remember if it was or not.

462 MR. NEUFELD:

May we just have one moment, your Honor?

463 THE COURT:

Certainly.

464 (Discussion held off the record between Defense counsel.)
465 MR. NEUFELD:

Miss Mazzola, you testified on August 23rd, 1994--didn't you testify that you alone collected all the drops of blood at the Rockingham location?

466 MR. GOLDBERG:

Could I have the page and line citation?

467 THE COURT:

Counsel?

468 MR. NEUFELD:

Page 698. Could we put up a slide, slide 8?

469 (Brief pause.)
470 MR. GOLDBERG:

I'll object. This has been asked and answered.

471 MR. NEUFELD:

A different context, your Honor.

472 MR. GOLDBERG:

Same exact words.

473 THE COURT:

I'm sorry. 698? What line, counsel?

474 MR. NEUFELD:

Line 21.

475 (Brief pause.)
476 THE COURT:

Objection sustained.

477 MR. NEUFELD:

Well, Miss Mazzola, when you testified on August--I'm sorry--when you testified on August 23rd, 1994, do you recall me asking you which items you collected at Rockingham? Do you recall me asking that question?

478 THE COURT:

The objection was sustained, counsel.

479 MR. NEUFELD:

This is a different quote I'm getting at, your Honor. It's a different portion of the transcript.

480 THE COURT:

All right. Proceed.

481 MR. NEUFELD:

It's page 700, line 6 to line 18.

482 MR. GOLDBERG:

Line which?

483 MR. NEUFELD:

Line 6 to line 18.

484 (Brief pause.)
485 THE COURT:

Proceed.

486 MS. MAZZOLA:

Would you please restate the question?

487 MR. NEUFELD:

Miss Mazzola, when you testified on August 23rd, 1995, were you asked by me which items you personally collected at the Rockingham scene that morning?

488 MS. MAZZOLA:

I--excuse me. I don't remember the exact question. It might have been something like that.

489 MR. NEUFELD:

Well, were you asked to distinguish those items that you collected personally as opposed to those items that you collectively collected with Dennis Fung?

490 MR. GOLDBERG:

Well, I would ask for page and line cite.

491 THE COURT:

700 starting at 6.

492 MR. NEUFELD:

Were you asked that?

493 MS. MAZZOLA:

I believe so. I'm not a hundred percent sure.

494 MR. NEUFELD:

and isn't it a fact, ma'am, that when you were asked which items you collected at Rockingham, that you understood that question to mean those items that you personally collected as opposed to those items which you collected with Dennis Fung; isn't that correct?

495 THE COURT:

I'm going to sustain the objection. That's not the way this question is phrased, counsel.

496 MR. NEUFELD:

All right. Well, let me ask you this. Were you asked these questions and did you give these answers in sworn testimony on August 23rd, 1995?

497 MR. NEUFELD:

Referring to page 700, line 6 to line 18. Do you have it?

498 MR. GOLDBERG:

Yes. I would object for the record, that this is not inconsistent.

499 THE COURT:

Overruled.

500 MR. NEUFELD:

Ask it be marked. What's next in order, your Honor?

501 THE COURT:

No. It's in the record already, counsel.

502 MR. GOLDBERG:

Your Honor, I would object to this procedure. If we could--

503 THE COURT:

Overruled. You can read it.

504 MR. GOLDBERG:

What?

505 THE COURT:

Read it, counsel. Proceed.

506 MR. NEUFELD:

Thank you.

507 MR. NEUFELD:

Were you asked these questions by me on August 23rd, did you give these answers? "Question: And after you removed that stain on the Bronco, you then began to collect the stains leading up the driveway toward the front door of Mr. Simpson's house?"

508 THE COURT:

Wait. Take it down. It's not inconsistent. It doesn't say all the stains. It says stains. Take it down. Proceed.

509 MR. NEUFELD:

Miss Mazzola, when you were asked about the stains that were collected on Rockingham on August 23rd, did you ever testify that Dennis Fung collected even a single stain?

510 MS. MAZZOLA:

I don't remember if I did.

511 MR. NEUFELD:

Did you testify that Dennis Fung even assisted in collecting a single stain?

512 MR. GOLDBERG:

Wait a minute. It's irrelevant what she was asked.

513 THE COURT:

Sustained.

514 MR. NEUFELD:

Was it your understanding when you were asked questions about the collecting of stains at Rockingham, Miss Mazzola, that the questions were being asked of what you personally collected as opposed to what you collectively collected with criminalist Fung?

515 MR. GOLDBERG:

Overbroad. Irrelevant.

516 THE COURT:

Sustained. I'm going to sustain the Court's own objection under 352. Now, this is too confusing given the state of this particular transcript. It's not clear. The question was not clearly asked. Proceed.

517 MR. NEUFELD:

One moment, your Honor.

518 (Discussion held off the record between Defense counsel.)
519 MR. NEUFELD:

Miss Mazzola, a few moments ago, you testified that you and Dennis Fung together each swatched portions of stains 4, 5 and six; is that correct?

520 MR. GOLDBERG:

This has been asked and answered. Under 352, I object.

521 THE COURT:

Overruled.

522 MS. MAZZOLA:

He assisted on some of them. I'm not exactly sure which exact stains.

523 MR. NEUFELD:

Miss Mazzola, five minutes ago, didn't you say with some degree of certainty that it was items 4, 5 and 6 that Dennis Fung and you did together?

524 MR. GOLDBERG:

Compound and misstates the evidence.

525 THE COURT:

Overruled.

526 MS. MAZZOLA:

We were both there working. I am not sure exactly if he took swatches from every stain that I did or if he took swatches from one.

527 MR. NEUFELD:

I'm not asking you about every stain, Miss Mazzola. I'm simply asking you whether or not you testified before these ladies and gentlemen of the jury just five minutes ago that Dennis Fung and you together each did swatches for stains 4, 5 and 6. Was that your testimony, ma'am?

528 MS. MAZZOLA:

I'm not sure I said 4, 5 and 6 or portions of.

529 MR. NEUFELD:

Portions of 4, 5 and 6?

530 MS. MAZZOLA:

One or two.

531 (Discussion held off the record between Defense counsel.)
532 MR. NEUFELD:

So you're now saying, Miss Mazzola, that you're not sure which of items 4, 5 and 6 that you both together swatched some of the blood from? Is that your current testimony?

533 MR. GOLDBERG:

Unintelligible.

534 THE COURT:

That's vague.

535 MR. NEUFELD:

Well, did you not say just a few minutes ago to this jury, Miss Mazzola, that both you and Dennis Fung together each swatched portions of the stain for items 4, 5 and 6?

536 MS. MAZZOLA:

I'm not sure if I said that both of us took swatches from 4, 5 and 6 or it could have been one or two. I don't remember.

537 MR. NEUFELD:

But at least it's your recollection that both you and Dennis Fung took swatches from at least one of those three items; is that correct?

538 MS. MAZZOLA:

That is correct.

539 MR. NEUFELD:

All right. When you testified just this last Thursday before the same jury at this trial, Miss Mazzola, were you asked these questions, did you give these answers?

540 MR. NEUFELD:

Referring to page 23851 beginning at line 4.

541 THE COURT:

3. Proceed.

542 MR. GOLDBERG:

May I have a moment, your Honor?

543 THE COURT:

Certainly.

544 (Brief pause.)
545 MR. GOLDBERG:

It's fine.

546 MR. NEUFELD:

Were you asked these questions and did you give these answers? "Question: Miss Mazzola, you said a moment ago that you testified this morning on direct examination that it is now your recollection that Mr. Fung and not you collected the drops, items number 4, 5 and 6; is that correct? "Answer: That's correct." Did you give that answer to that question last Thursday?

547 MS. MAZZOLA:

If you have it, I guess I did.

548 MR. NEUFELD:

You don't recall?

549 MR. GOLDBERG:

Well, motion to strike the witness' answer.

550 THE COURT:

Overruled.

551 MR. NEUFELD:

Would you prefer to actually read it yourself, ma'am?

552 MS. MAZZOLA:

No. That's--that's fine.

553 MR. NEUFELD:

Huh?

554 MS. MAZZOLA:

I'll take your word for it.

555 MR. GOLDBERG:

Well, I would make a motion to strike the comment--

556 MR. NEUFELD:

Miss Mazzola--

557 THE COURT:

Overruled. Excuse me, counsel. When other counsel is making an objection, would you at least allow them to finish?

558 MR. NEUFELD:

Certainly.

559 THE COURT:

Proceed.

560 MR. NEUFELD:

So, Miss Mazzola, on Thursday, you testified that you were not involved in the collection of 4, 5 and 6 and that Dennis Fung collected that; is that correct?

561 MR. GOLDBERG:

Misstates the testimony.

562 THE COURT:

Overruled.

563 MR. NEUFELD:

Is that correct?

564 MS. MAZZOLA:

At the time, I thought that Mr. Fung alone had, yes.

KEY QUOTE
565 MR. NEUFELD:

That was as recently as last Thursday?

566 MS. MAZZOLA:

Yes.

567 MR. NEUFELD:

And now today, you have a different recollection of what transpired back on June 13th, 1994? Is that your testimony, ma'am?

568 MS. MAZZOLA:

Yes.

569 MR. NEUFELD:

And when you testified on August 23rd, 1994, at that point, it was your recollection, was it not, that you had personally collected all the blood drops at Rockingham; is that correct?

570 MR. GOLDBERG:

I object to that.

571 THE COURT:

Sustained.

572 MR. NEUFELD:

Have you looked at any notes to refresh your recollection between Thursday and today that led you to change your mind from Thursday to today's testimony with respect to who collected what on items 4, 5 and 6?

573 MS. MAZZOLA:

Notes, no.

574 MR. NEUFELD:

Have you looked at any videotapes to refresh your recollection so that you would change your memory as to who collected what portions of 4, 5 and 6?

575 MS. MAZZOLA:

Videos, no.

576 MR. NEUFELD:

Have you looked at any documents to refresh your recollection that you didn't have available to you last Thursday so you could have a different memory as to who collected what with respect to items 4, 5 and 6?

577 MS. MAZZOLA:

Documents, no.

578 MR. NEUFELD:

Did you have a conversation with any members of the Prosecution staff between last Thursday and today with regard to who collected items 4, 5 and 6?

579 MS. MAZZOLA:

No.

580 MR. NEUFELD:

Did you have a conversation with Dennis Fung between Thursday and today as to who collected items 4, 5 and 6?

581 MS. MAZZOLA:

No.

582 MR. NEUFELD:

But you now say that it's your recollec--that your recollection has changed your memory of what your involvement was with regard to items 4, 5 and 6 from just this last Thursday to today; is that correct?

583 MS. MAZZOLA:

Yes.

584 MR. NEUFELD:

And, ma'am, it would be fair to say--I think you said it earlier--that you never wrote down in your notes which of you collected which items; is that right?

585 MS. MAZZOLA:

That is correct.

586 MR. NEUFELD:

And so the only way you can recall or testify as to who collected which items is strictly from your independent recollection; isn't that correct?

587 MS. MAZZOLA:

That is correct.

588 MR. NEUFELD:

Has your memory of who collected which items been aided by the prep sessions that you had with the Prosecutors in this case?

589 MS. MAZZOLA:

No.

590 MR. NEUFELD:

Did the Prosecutors ever tell you that it was important that you give some credit to Dennis Fung for his involvement in this case?

591 MS. MAZZOLA:

No.

592 MR. NEUFELD:

Did they ever tell you that it was important for you to enhance Dennis Fung's involvement in the collection of bloodstain evidence?

593 MS. MAZZOLA:

No.

594 MR. NEUFELD:

In fact, your supervisor, Dennis Fung, didn't even supervise you with respect to the collection of every stain, did he?

595 MS. MAZZOLA:

Of every stain, no.

596 MR. NEUFELD:

He was off collecting other evidence when you collected some of the stains in this case, didn't he?

597 MS. MAZZOLA:

Yes.

598 MR. NEUFELD:

When you collected a stain on a wire the afternoon of June 13th--excuse me--your supervisor was not there to observe you, was he?

599 MS. MAZZOLA:

That's correct.

600 MR. NEUFELD:

And when you collected items 7 and 8, Dennis Fung was not there to observe you, was he?

601 MS. MAZZOLA:

That is correct.

602 MR. NEUFELD:

Now, I want to show you an evidence board prepared by the Prosecution.

603 (Brief pause.)
604 (Discussion held off the record between the Deputy District Attorney and Defense counsel.)
605 MR. NEUFELD:

Can we have a sidebar briefly, your Honor?

606 THE COURT:

Proceed.

607 MR. NEUFELD:

Items have been removed--

608 THE COURT:

Proceed. We'll take it up at noon.

609 (Brief pause.)
610 MR. NEUFELD:

Now, at Bundy, ma'am, as opposed to Rockingham, isn't it true that you collected every single drop of blood at Bundy with the sole exception being the stains from the two bloody shoeprints?

611 MS. MAZZOLA:

Exclusively, no.

612 MR. NEUFELD:

Well, ma'am, were you aware of the fact that when you were--on August 23rd, when you were asked about who--which drops you collected, did you understand the question to be directed at what you personally collected as opposed to what you collected in conjunction with Dennis Fung?

613 MS. MAZZOLA:

I do not recall if I knew that it was me personally versus us as a team.

614 MR. NEUFELD:

Your Honor, I would ask the Court's permission to now read the--page 700 to the witness for that limited purpose.

615 (Brief pause.)
616 THE COURT:

I'll sustain the same objection because of the manner in which this transcript reads, counsel. It's not a clear question that was put to the witness. Proceed.

617 MR. NEUFELD:

When you testified on August 23rd, referring to page 735--

618 MR. GOLDBERG:

I would object. This was asked and answered too.

619 MR. NEUFELD:

I haven't even asked this question and I haven't read this portion of the transcript on cross-examination.

620 MR. GOLDBERG:

I'm sorry. That may have been on direct. Sorry, counsel.

621 THE COURT:

Which line, counsel? 735, what line?

622 MR. NEUFELD:

One second, your Honor. Beginning--actually beginning at 734, line 27 and ending on page 736, line 1.

623 MR. GOLDBERG:

Starting on--starting on which line?

624 MR. NEUFELD:

734, line 27.

625 THE COURT:

Proceed.

626 MR. NEUFELD:

You testified on August 23rd, 1994--were you asked these questions and did you give these answers? "Question: And which--I'm sorry. At Bundy again. At Bundy again, were there certain bloodstains that you collected and other bloodstains that were collected by Mr. Fung? "Answer: Yes. "Question: And which bloodstains were collected by Mr. Fung? "Answer: I believe he collected the red stains that were near the shoeprints that were made on the walkway. "Question: Would you please look at your notes and tell me which numbers those are? "Question: And when you say that, you say he collected the actual foot--shoeprints or he collected alleged drops that were near the shoeprints? "Answer: He if I remember correctly took swatches of the red stains that were constituting the footprint itself. "Question: Can you tell us which ones those were, please? "Answer: Property items 55 and 56. "Question: And that is it? "Answer: Yes. "Question: All other bloodstains at the Bundy crime scene were collected by you, ma'am? "Answer: Yes. "And while he collected 55 and 56, were you collecting some of your bloodstains? "Answer: Yes." Were you asked those questions and did you give those answers under oath on August 23rd, 1994?

627 MS. MAZZOLA:

Yes.

628 MR. NEUFELD:

And on August 23rd, 1994, ma'am, would you agree that the events of June 13th were fresher in your mind than they are now 10 months later?

629 MS. MAZZOLA:

Not necessarily fresher.

630 MR. NEUFELD:

Well, would you agree, ma'am, that your memory of an event that happened two months previously is stronger than your memory of an event that happened 10 months previously?

631 MR. GOLDBERG:

Well, that question is irrelevant.

632 THE COURT:

Overruled.

633 MS. MAZZOLA:

I had not thought of the events of June 13th since we had gotten done with the property reports up until the time I walked into this courtroom for the griffin hearing.

634 MR. NEUFELD:

Miss Mazzola, would you agree that your memory of an event that happened two months prior to your testifying is fresher than it is when you've had 10 months gone by?

635 MS. MAZZOLA:

Not necessarily.

636 MR. NEUFELD:

Okay. Well, Miss Mazzola, June 13th, you collected these items; is that right?

637 MS. MAZZOLA:

Yes.

638 MR. NEUFELD:

You didn't do a single other crime scene between June 13th and the date you testified on August 23rd, did you?

639 MS. MAZZOLA:

I don't remember if I did or not.

640 MR. NEUFELD:

Well, Miss Mazzola, are there any other notes that would refresh your recollection as to whether you did?

641 MS. MAZZOLA:

I don't know.

642 MR. NEUFELD:

Well, as you sit here today, ma'am, do you have an independent recollection of doing a single other crime scene between June 13th and August 23rd?

643 MS. MAZZOLA:

Independent recollection, no.

644 MR. NEUFELD:

And, Miss Mazzola, when you did this crime scene with Dennis Fung on June 13th, it was an important crime scene to you; was it not?

645 MS. MAZZOLA:

Every crime scene is important.

646 MR. NEUFELD:

Well, Miss Mazzola, you said when you were told to come to Court in this case, rather than being told it was the Simpson case, you were simply told by someone it was "The case," correct?

647 MS. MAZZOLA:

Those were her words, not mine.

648 MR. NEUFELD:

I understand that, Miss Mazzola. But is that what you were told?

649 MS. MAZZOLA:

That's what I was told, yes.

650 MR. NEUFELD:

Now, when this person said to you, "It is the case," didn't you know that what she meant was the case of the--of Mr. Simpson here? Didn't you know that?

651 MS. MAZZOLA:

I had an idea.

652 MR. NEUFELD:

Miss Mazzola, were you aware that just the previous day, August 22nd, your partner in this crime scene collection, Dennis Fung, was testifying in this courtroom before a national television audience? Were you aware of that?

653 MR. GOLDBERG:

That's been asked and answered. I also object to counsel's tone.

654 THE COURT:

Sustained. We've gone through this once before.

655 MR. NEUFELD:

That was in a different context, your Honor.

656 THE COURT:

Same testimony. We've heard it.

657 MR. NEUFELD:

And, Miss Mazzola, you were relying exclusively on your memory, on your independent recollection when you testified on August 23rd, correct?

658 MS. MAZZOLA:

That and Mr. Matheson's notes.

659 MR. NEUFELD:

Well, Mr. Matheson's notes were the original notes that you and Dennis Fung took on June 13th; isn't that correct?

660 MS. MAZZOLA:

I don't know if they were the originals or not.

661 MR. NEUFELD:

Well, the notes that--well, were they copies of the notes that you and Dennis Fung took then on June 13th?

662 MS. MAZZOLA:

They could have been copies, yes.

663 MR. NEUFELD:

Or originals?

664 MS. MAZZOLA:

That's true.

665 MR. NEUFELD:

And what those notes were the sum total of all the notes that you and Dennis Fung took on June 13th at Bundy and Rockingham; isn't that correct?

666 MS. MAZZOLA:

That's correct.

667 MR. NEUFELD:

And that would constitute the field notes and the crime scene inspection list that this jury has already seen; isn't that correct?

668 MS. MAZZOLA:

That's correct.

669 MR. NEUFELD:

And there are no other notes, are there, that were prepared by you that you've used to refresh your recollection today?

670 MS. MAZZOLA:

No.

671 MR. NEUFELD:

And there were no other notes other than those notes that you relied upon to refresh your recollection when you testified on August 23rd; isn't that correct?

672 MS. MAZZOLA:

That's correct.

673 MR. NEUFELD:

And when you testified on August 23rd, ma'am, isn't it a fact that there was no way--there is no note saying which items you personally collected and which items Dennis Fung personally collected?

674 MS. MAZZOLA:

That's correct.

675 MR. NEUFELD:

And so between August 23rd and today, ma'am, it's not as if you've had additional notes to look at which will help you to remember which items Dennis Fung collected as opposed to which items you collected; isn't that right?

676 MR. GOLDBERG:

Argumentative.

677 THE COURT:

Sustained as phrased.

678 MR. NEUFELD:

Well, Miss Mazzola, are there any other notes other than your field notes that you got from Mr. Matheson that day that indicate which items you collected and which items Dennis Fung collected?

679 MS. MAZZOLA:

Notes, no.

680 MR. NEUFELD:

And there are no notes, ma'am, or reports that were prepared by you that you looked at on August 23rd which indicated which items you collected and which items Dennis Fung collected, correct?

681 MR. GOLDBERG:

Badgering the witness in terms of testimony.

682 THE COURT:

We're there. All right.

683 MR. NEUFELD:

Can I just ask two more questions and I'll finish this area?

684 THE COURT:

Two more. Slower though. However, the Court reporter is about to go on us.

685 MR. NEUFELD:

So both today and on August 23rd, you're relying exclusively on your independent recollection as opposed to any documentary evidence to recall which items you collected and which items Dennis Fung collected, correct?

686 MS. MAZZOLA:

Memory and photographs.

687 MR. NEUFELD:

Are you--do you--have you seen a single photograph showing Dennis Fung collecting items 4, 5 or 6?

688 MS. MAZZOLA:

At the Griffen hearing, I did not have a chance to look at the photographs before.

689 MR. NEUFELD:

Ma'am, I'm simply asking you this, please. Have you seen a single photograph between June 13th and this morning or this afternoon that shows Dennis Fung collecting items 4, 5 or 6?

690 MS. MAZZOLA:

No.

691 THE COURT:

All right. Thank you, counsel. All right. Ladies and gentlemen, we are going to take our recess for the morning session. Please remember all of my admonitions to you; do not discuss the case amongst yourselves, form any opinions about the case, allow anybody to communicate with you or conduct any deliberations until the matter has been submitted to you. Counsel, I'm going to direct you to confer about that one exhibit that Mr. Neufeld was interested in.

692 MR. GOLDBERG:

Yes. We will resolve that.

693 THE COURT:

If there's any problem, let me know at 1:30. All right. We'll stand in recess. All right. Miss Mazzola, 1:30.

Temperature

tense

Key Quotes (5)

Andrea Mazzola
Yes. At the time, I thought that Mr. Fung alone had, yes.
Mazzola confirms that as recently as the prior Thursday she believed Fung alone collected items 4, 5, and 6 — directly contradicting her testimony today that they collected together, with no explanation for the change.
Andrea Mazzola
Notes, no... Videos, no... Documents, no... No.
Mazzola serially denies reviewing any notes, videos, documents, or having any conversations with prosecutors or Fung between Thursday and today — making her changed testimony about items 4, 5, and 6 inexplicable.
Andrea Mazzola
In the driveway, no.
Concedes that all items collected in Simpson's driveway were items the detectives pointed out — establishing detective control over evidence collection.
Andrea Mazzola
I do not know if they were tested.
Mazzola admits she does not know whether confirmatory tests were ever done on the blood specks on the passenger door (item 20) or the driver's handle speck, leaving in doubt whether they were human blood at all.
Andrea Mazzola
To the best of my recollection, I did not.
Admits she did not see the blood specks circled in the Bronco photograph when she examined the Bronco on June 14th — raising questions about when and how those specks appeared.

Evidence (8)

Defendant's 1097
Photograph of the Bronco at the print shed on June 14th
Shown to witness; used to question whether blood specks were visible with door open or closed
Defendant's 1113
Photograph of passenger door specks (item 20)
Referenced to establish no confirmatory test was ever done on those specks
People's 120
Photo board of blood drop evidence at Rockingham
Used to demonstrate that photographs of items 4, 5, 6 lacked rulers and directional arrows
Defendant's 1115
Handout from LAPD SID mini academy on crime scene investigation procedures
Introduced; witness could not confirm whether it was the actual handout she received
Defendant's 1116
Two-page handout on forensic photography
Introduced; witness acknowledged receiving some such handout but could not confirm this specific one
Items 4, 5, 6, 7, 8
Blood drops collected in Simpson's Rockingham driveway on June 13th
Central to impeachment — who collected which items disputed across three different testimony sessions
+ 2 more

Notable Exchanges (4)

Peter NeufeldAndrea Mazzola
Neufeld methodically walked Mazzola through three contradictory sworn accounts of who collected items 4, 5, and 6: her August 1994 grand jury testimony (she collected all drops herself), last Thursday's trial testimony (Fung alone collected 4, 5, 6), and today's testimony (both did it together). She admitted no notes, documents, videos, or conversations changed between Thursday and today.
devastating
Peter NeufeldAndrea Mazzola
Neufeld established that at Bundy, neither Mazzola nor Fung asked the detectives to delay moving the bodies so they could first search for perishable trace evidence — despite being trained to do exactly that. Mazzola confirmed she stood on the sidewalk and did not go in.
revealing
Peter NeufeldAndrea Mazzola
Neufeld pressed on the absence of rulers or north-direction arrows in blood drop photographs. The only photo with a north arrow was item 7 — the one collected when SID senior supervisor Steve Johnson was present rather than Fung.
strategic
Lance A. ItoPeter Neufeld
Ito intervened to note that Mazzola was a probationary trainee and that photography responsibilities lay with Fung, limiting the relevance of some photography questions directed to her. He also sua sponte excluded an August 1994 transcript passage as too ambiguous to be clearly inconsistent.
procedural

Credibility Attacks (3)

⚔ Andrea Mazzola
Prior inconsistent statements across multiple proceedings
Neufeld confronted Mazzola with three inconsistent sworn accounts of who collected blood drops 4, 5, and 6 at Rockingham: (1) August 1994 testimony she collected all drops herself; (2) last Thursday she said Fung alone collected 4, 5, 6; (3) today she says they both did. She had no explanation — no new notes, documents, or conversations — for how her memory changed between Thursday and Monday.
⚔ Andrea Mazzola
Training vs. practice contradiction
Neufeld showed that Mazzola was trained to search for perishable evidence immediately upon arriving at a crime scene, to instruct photographers to include rulers and directional arrows, and to exercise independent judgment — but did none of these things at Bundy or Rockingham.
⚔ Dennis Fung (through Mazzola)
Omission and supervisory failure
Through Mazzola's testimony, Neufeld established that Fung never independently searched for evidence without detective guidance, never instructed photographers to include rulers, never asked detectives to delay moving bodies, and was absent when Mazzola collected several items unsupervised.

Witness Demeanor

(Brief pause.) — multiple times while witness reviewed notes
(Witness complies.) — when asked to read exhibit 1115
Witness asked Neufeld to repeat questions multiple times, suggesting stress or evasion under sustained pressure

Objections

28 objections (9 sustained, 17 overruled)
Proceeding 5801 • 693 utterances • Prosecution witness
Criminal Trial
Department 103
⚖️ Start
📂 APR 25, 1995 📄 Cross-examination of Andrea Ma
APR 25, 1995 KRT DvH TD