Cross-examination of Andrea Mazzola (part 2)

📄 Cross-examination of Andrea Mazzola (part 2) — Wednesday, April 26, 1995

Address:

C:\DEPT103\CRIMINAL\1995\APR\26\CROSS-EXAMINATION-OF-ANDREA-MA.DOC

TRIAL

▲ Day 62 of 167

◀ Jury readmission Sidebar: phenolphtalein test admissibility ▶

Witness: Andrea Mazzola
Examiner: Peter Neufeld
Called by: Prosecution • Date: Wednesday, April 26, 1995 • Utterances: 252

Defense attorney Peter Neufeld cross-examined criminalist Andrea Mazzola on her collection of evidence at Bundy and Rockingham on June 13, 1994. The central focus was the rear gate at Bundy — Mazzola claimed not to remember seeing the gate despite having walked through it, and Neufeld directly accused prosecutors of coaching her to deny seeing it as a way to explain why blood found on the gate three weeks later was never collected that day. Neufeld also challenged her on an uncollected piece of paper near Nicole Brown Simpson's body, inconsistent notes about departure times, and her collection of item no. 11 at Rockingham without Fung present.

# 1 MR. NEUFELD:

Thank you.

# 2 MR. NEUFELD:

Miss Mazzola, you testified that a criminalist must use his or her discretion in deciding which items to collect?

# 3 MS. MAZZOLA:

Correct.

# 4 MR. NEUFELD:

And I believe you testified that a criminalist can't simply pick up every little bit of paper at a crime scene; is that correct?

# 5 MS. MAZZOLA:

Correct.

# 6 MR. NEUFELD:

And I believe it was your position that if you do that, you're simply adding a lot of garbage. Is that what you said, ma'am?

# 7 MS. MAZZOLA:

Something to that effect.

# 8 MR. NEUFELD:

Now--

# 9 (Brief pause.)

# 10 MR. NEUFELD:

I'm going to show the witness item--exhibit 1080, 1 0 8 0.

# 11 MR. NEUFELD:

Now, Miss Mazzola, you see the piece of paper on the tile in between the person who is pointing and the white envelope?

# 12 MS. MAZZOLA:

On the tile?

# 13 MR. NEUFELD:

Did you see a piece of paper on the ground?

# 14 MS. MAZZOLA:

There appears to be something on the tile, on the walkway.

# 15 MR. NEUFELD:

Well, it's an object other than the tile itself; is that correct?

# 16 THE COURT:

Excuse me, Mr. Neufeld. You need to let Miss Mazzola finish answering.

# 17 MR. NEUFELD:

Sorry, your Honor. Sorry, Miss Mazzola.

# 18 MS. MAZZOLA:

It appears to be something other than the tile.

# 19 MR. NEUFELD:

And I would like you to take a look at the photo itself. You may see a better resolution, Miss Mazzola.

# 20 MS. MAZZOLA:

Okay.

# 21 MR. NEUFELD:

Would you agree that it appears to be a piece of paper that's on the--sitting on the tile?

# 22 MS. MAZZOLA:

Yes.

# 23 MR. NEUFELD:

And, Miss Mazzola, that piece of paper was not collected by you on June 13th, was it?

# 24 MS. MAZZOLA:

No, I did not see-- remember seeing the paper on June 13th.

# 25 MR. NEUFELD:

And you never saw Dennis Fung collect that piece of paper, did you?

# 26 MS. MAZZOLA:

No.

# 27 MR. NEUFELD:

Had you seen that piece of paper, you would have certainly collected it, wouldn't you?

# 28 MS. MAZZOLA:

I would have looked at it to find out what it was.

# 29 MR. NEUFELD:

Well, wouldn't you be concerned as a criminalist that that piece of paper found so close to the body of Nicole Brown Simpson could have a fingerprint belonging to the assailant?

# 30 MS. MAZZOLA:

Yes, it's possible.

# 31 MR. NEUFELD:

And that if the assailant was bleeding at this point in time, that that piece of paper might have a drop of blood that belonged to the assailant, correct?

# 32 MS. MAZZOLA:

It's a possibility.

# 33 MR. NEUFELD:

That piece of paper might even have writing on it which would give some indication as to either the identity or the motive of whomever or however many people that were involved in this case were the assailants?

# 34 MR. GOLDBERG:

Calls for speculation.

# 35 THE COURT:

Sustained.

# 36 MR. NEUFELD:

In other words, Miss Mazzola, that piece of paper found so close to the body of Nicole Brown Simpson could have been a very relevant piece of evidence?

# 37 MR. GOLDBERG:

Calls for speculation.

# 38 THE COURT:

Sustained, but the jury can draw their own conclusion given the proximity.

KEY QUOTE

# 39 MR. NEUFELD:

Now, Miss Mazzola, calling your attention now to the drops of blood there on the walkway at Bundy, you collected five drops of blood, is that correct, five bloodstains on that walkway?

# 40 MS. MAZZOLA:

Let me check and make sure exactly how many.

# 41 MR. NEUFELD:

Please do.

# 42 (Brief pause.)

# 43 MR. NEUFELD:

Now, Miss Mazzola, the reason that you collected those drops is because you had been told by the detectives that these drops might perhaps come from the person who was the assailant as a possibility. Weren't you told that?

# 44 MS. MAZZOLA:

That was a possibility, yes.

# 45 MR. NEUFELD:

And the detectives I believe walked you and Dennis Fung along that walkway pointing out the different blood drops or bloodstains to you; did they not?

# 46 MS. MAZZOLA:

I went up to a certain point on the walkway. They were pointing out the drops, yes.

# 47 MR. NEUFELD:

And when you say they were pointing out the drops, they were pointing out the stains; isn't that right?

# 48 MS. MAZZOLA:

Correct.

# 49 MR. NEUFELD:

And now that you have seen Detective Lange and Vannatter and you know what they look like, were--excuse me. The detectives who took you on this walk-through, were either of them either Detective Lange or Vannatter?

# 50 MS. MAZZOLA:

I can't remember which ones were there that day.

# 51 MR. NEUFELD:

How many different detectives took you on that walk-through approximately?

# 52 MS. MAZZOLA:

I wasn't counting detectives. I don't know.

# 53 MR. NEUFELD:

All right. Well, was it more than two?

# 54 MS. MAZZOLA:

It was more than one.

# 55 MR. NEUFELD:

All right. And they were both speaking and pointing out different items to you and Dennis Fung?

# 56 MS. MAZZOLA:

They were talking to Mr. Fung, yes.

# 57 MR. NEUFELD:

And you could hear what they were saying?

# 58 MS. MAZZOLA:

Certain portions, yes.

# 59 MR. NEUFELD:

And you collected every stain that you saw along this walkway; did you not?

# 60 MS. MAZZOLA:

The stains were in the trail, yes.

# 61 MR. NEUFELD:

Okay. And could you step down for one second, please.

# 62 MS. MAZZOLA:

Sure.

# 63 (The witness complies.)

# 64 THE COURT:

Do you have the long pointer there? Mr. Neufeld.

# 65 MR. NEUFELD:

Okay. Miss Mazzola, you said you collected every stain that was along that walkway, correct?

# 66 MS. MAZZOLA:

Correct.

# 67 MR. NEUFELD:

And you didn't simply say, "Hmm, I will only collect representative stains," Did you?

# 68 MS. MAZZOLA:

On this, no.

# 69 MR. NEUFELD:

You made a decision with Dennis Fung that you would collect each and every stain along that way, correct?

# 70 MS. MAZZOLA:

I was told to pick up every stain.

KEY QUOTE

# 71 MR. NEUFELD:

By Dennis Fung?

# 72 MS. MAZZOLA:

Yes.

# 73 MR. NEUFELD:

And he told you that even before you started picking up the stains, didn't he?

# 74 MS. MAZZOLA:

Yes.

# 75 MR. NEUFELD:

Now, item no. 50--by the way, isn't it true that you would collect items of evidence in sequence?

# 76 MS. MAZZOLA:

As much as possible, yes.

# 77 MR. NEUFELD:

So the photo id numbers that you use such as 112 for item 47 was collected before photo id no. 113 which corresponds to item 48; isn't that right? That was your practice?

# 78 MS. MAZZOLA:

For the most part.

# 79 MR. NEUFELD:

Well, was that your practice to do that?

# 80 MR. GOLDBERG:

It's asked and answered.

# 81 THE COURT:

Overruled.

# 82 MS. MAZZOLA:

On this occasion, we started working on the trail, the walkway, because we wanted to get those stains up first.

# 83 MR. NEUFELD:

Okay. Well, did you pick up the stains on the walkway before you picked up the perishables and loose items of evidence such as the hat and the glove and the keys?

# 84 MS. MAZZOLA:

No. They were recovered first and then we went onto the walkway.

# 85 MR. NEUFELD:

Okay. So first you picked up the items, the perishable items and then you started collecting the stains; is that right?

# 86 MR. GOLDBERG:

Objection to perishable.

# 87 THE COURT:

Sustained. Assumes facts not in evidence.

# 88 MR. NEUFELD:

First you started collecting the nonstain evidence and then you went on to collect stains; is that correct?

# 89 MS. MAZZOLA:

Correct.

# 90 MR. NEUFELD:

And when you got to that walkway and you started collecting them, did you collect item 47 first on the walkway?

# 91 MS. MAZZOLA:

Yes.

# 92 MR. NEUFELD:

And then you collected item 48, correct?

# 93 MS. MAZZOLA:

Correct.

# 94 MR. NEUFELD:

And then you collected item 49; is that right? Could you please point out to the jury where items 47, 48 and 49 are?

# 95 MS. MAZZOLA:

47, right here, 48 and 49 (Indicating).

# 96 MR. NEUFELD:

Can you see that there?

# 97 MR. NEUFELD:

All right. And then--did you then go on to pick up item 50?

# 98 MS. MAZZOLA:

Yes.

# 99 MR. NEUFELD:

And could you please point out where item 50 is?

# 100 MS. MAZZOLA:

(Indicating).

# 101 MR. NEUFELD:

And would you agree, ma'am, that item 50 is located simply a few feet from the back gate along that walkway?

# 102 MS. MAZZOLA:

On the diagram, it appears to be close to the back gate.

# 103 MR. NEUFELD:

All right. And in fact, ma'am, to get--then at some point, did you pick up item 52 after you picked up item 50?

# 104 MS. MAZZOLA:

Yes.

# 105 MR. NEUFELD:

And to get to item 52, you had to walk through the back gate, didn't you?

# 106 MS. MAZZOLA:

I just kept on going. There was no gate barring my way.

# 107 MR. NEUFELD:

Well, Miss Mazzola, are you saying that there was no gate at the Bundy walkway on June 13th, 1994? Is that your testimony?

# 108 MS. MAZZOLA:

I do not recall seeing a gate on that morning.

# 109 MR. NEUFELD:

Well, Miss Mazzola, if other witnesses had testified that they were absolutely certain that there was a gate present at the rear of that walkway on June 13th, would that affect your testimony today as to whether or not there was a gate there on June 13th?

# 110 MR. GOLDBERG:

It's an improper hypothetical.

# 111 THE COURT:

Sustained.

# 112 MR. NEUFELD:

Do you have any reason to believe, Miss Mazzola, that there wasn't a gate there on June 13th when you collected the evidence?

# 113 MR. GOLDBERG:

Argumentative. Assumes facts not in evidence.

# 114 THE COURT:

Sustained. Miss Mazzola, have you been back to the scene since at Bundy?

# 115 MS. MAZZOLA:

Yes, I have.

# 116 THE COURT:

Have you seen the gate back there?

# 117 MS. MAZZOLA:

I have seen the gate since, yes.

# 118 THE COURT:

Proceed.

# 119 MR. NEUFELD:

Thank you, your Honor.

# 120 MR. NEUFELD:

When you were at the SID mini academy, Miss Mazzola, did they teach you how to look for evidence?

# 121 MS. MAZZOLA:

Yes.

# 122 MR. NEUFELD:

In fact, when you were at Rockingham that morning, Miss Mazzola, you and Dennis Fung looked all along the driveway systematically for every possible red stain along the way, didn't you?

# 123 MS. MAZZOLA:

Yes.

# 124 MR. NEUFELD:

And you've been taught to do that at the SID mini academy, haven't you?

# 125 MS. MAZZOLA:

Yes.

# 126 MR. NEUFELD:

And likewise, Miss Mazzola, at Bundy as you proceeded along that walkway in that line, you were looking for as many red stains as could be there, correct?

# 127 MS. MAZZOLA:

In that trail, yes.

# 128 MR. NEUFELD:

And when you say "That trail," You mean all the way from where 47 is--and could you point to 47, please?

# 129 MS. MAZZOLA:

(Indicating).

# 130 MR. NEUFELD:

And now could you point to 52?

# 131 MS. MAZZOLA:

(Indicating).

# 132 MR. NEUFELD:

And all along that line connecting those two dots from 47 to 52, you were looking systematically all along that way for any red stains; isn't that correct?

# 133 MS. MAZZOLA:

The area had already been searched for red stains. I was following the trail that I was told to pick up.

# 134 MR. NEUFELD:

Miss Mazzola, a moment ago, I asked you whether or not you had been taught to systematically examine the trail or walkway for any and all red stains.

# 135 MS. MAZZOLA:

Yes.

# 136 MR. NEUFELD:

I believe you answered yes; is that correct?

# 137 MS. MAZZOLA:

That's correct.

# 138 MR. NEUFELD:

And when you were at the Bundy location that day, ma'am, were you also systematically examining that walkway from item 47 to item 52 for the presence of red stains?

# 139 MR. GOLDBERG:

It's vague as to whether you is collective or individual.

# 140 THE COURT:

Overruled.

# 141 MR. NEUFELD:

Were you doing that?

# 142 MS. MAZZOLA:

It had already been searched for red stains before I started collecting them.

# 143 MR. NEUFELD:

Yes. And the person who searched for red stains before you started collecting it was you and Dennis Fung; isn't that correct?

# 144 MS. MAZZOLA:

Myself up to a certain point with Mr. Fung and the detective and Mr. Fung continued on out the back.

# 145 MR. NEUFELD:

Miss Mazzola, who told you to pick up item 52?

# 146 MS. MAZZOLA:

Mr. Fung.

# 147 MR. NEUFELD:

He told you that there was a bloodstain outside the rear gate, correct?

# 148 MS. MAZZOLA:

He told me there was a bloodstain on the driveway.

# 149 MR. NEUFELD:

Have you been taught, Miss Mazzola, at the SID mini academy to independently look for evidence when you're at a crime scene?

# 150 MS. MAZZOLA:

To a certain extent, yes.

# 151 MR. NEUFELD:

Have you been taught, Miss Mazzola, to keep your eyes open as you walk through a crime scene to see if there's any relevant evidence?

# 152 MS. MAZZOLA:

Yes.

# 153 MR. NEUFELD:

And, Miss Mazzola, did you keep your eyes open when you left item 50 and headed through the rear gate to item 52?

# 154 MS. MAZZOLA:

My eyes were open when I went out the back of the driveway.

# 155 MR. NEUFELD:

Okay. And when you walked out that back, you didn't see any red stains on the rear gate, did you?

# 156 MR. GOLDBERG:

Assumes facts not in evidence, that she saw the gate.

# 157 THE COURT:

Overruled.

# 158 MS. MAZZOLA:

I honestly don't remember seeing a gate there.

KEY QUOTE

# 159 MR. NEUFELD:

Well, Miss Mazzola, now that you--you say you've been back to that location, correct?

# 160 MS. MAZZOLA:

Correct.

# 161 MR. NEUFELD:

And you know the gate is there?

# 162 MS. MAZZOLA:

Correct.

# 163 MR. NEUFELD:

And you know from speaking to other people about this case that the gate was there in fact on the 13th, don't you?

# 164 MS. MAZZOLA:

Yes, it was there on the 13th.

# 165 MR. NEUFELD:

And so once again I ask you, when you were walking from item 50 to item 52 with your eyes open, did you notice any bloodstains on the gate?

# 166 MS. MAZZOLA:

I did not notice a gate.

# 167 MR. NEUFELD:

Did you notice any bloodstains there, Miss Mazzola?

# 168 MR. GOLDBERG:

This is badgering. Asked and answered.

# 169 THE COURT:

Sustained. She's answered she didn't see the gate. If she didn't see the gate, she couldn't see anything that wasn't on it or was on it.

# 170 MR. NEUFELD:

Thank you. You may return to your seat.

# 171 (The witness complies.)

# 172 MR. NEUFELD:

Miss Mazzola, when you were prepped to testify in this case by the Prosecutors, were you told that there was an issue in this case, that is the fact that blood drops, alleged blood drops were not recovered from the gate on June 13th, but were recovered from the gate three weeks later? Were you told that?

# 173 MS. MAZZOLA:

I remember hearing something about that.

# 174 MR. NEUFELD:

During the prep sessions?

# 175 MS. MAZZOLA:

I can't recall if it was during the prep sessions or not.

# 176 MR. NEUFELD:

And were you told during those prep sessions, Miss Mazzola, that one way to deal with that particular problem would be to say that you never even saw the gate when you were there?

KEY QUOTE

# 177 MS. MAZZOLA:

No.

# 178 MR. NEUFELD:

Did you come up with that idea on your own, ma'am?

KEY QUOTE

# 179 MR. GOLDBERG:

Your Honor, that's argumentative.

# 180 THE COURT:

Sustained.

# 181 MR. NEUFELD:

When you went back to Rockingham for the second time, Miss Mazzola, did you make any contemporaneous note to indicate the time that you arrived back at Rockingham?

# 182 MS. MAZZOLA:

I don't believe we did.

# 183 MR. NEUFELD:

Now, do you know what time you left Bundy?

# 184 MS. MAZZOLA:

The approximate time, yes.

# 185 MR. NEUFELD:

And how do you know the approximate time?

# 186 MS. MAZZOLA:

Because it was written down while we were in the truck going back to Rockingham.

# 187 MR. NEUFELD:

And where did you write that down?

# 188 MS. MAZZOLA:

I believe it was in the notes.

# 189 MR. NEUFELD:

Which note?

# 190 MS. MAZZOLA:

Let me check.

# 191 (Brief pause.)

# 192 MR. NEUFELD:

May I approach the witness to see what notes she is referring to?

# 193 THE COURT:

Certainly. Mr. Goldberg.

# 194 MS. MAZZOLA:

I have it written down here (Indicating).

# 195 MR. NEUFELD:

Well, when you say you "Have it written down here," That's not an original entry that was made contemporaneous to the--to the making out of these field notes on the 13th, is it?

# 196 MS. MAZZOLA:

Doesn't appear to be.

# 197 MR. NEUFELD:

Okay. Do you have any contemporaneous note that you made to indicate what time you left Bundy?

# 198 MS. MAZZOLA:

There doesn't appear to be.

# 199 MR. NEUFELD:

And a moment ago, ma'am, when you simply--when you testified that you wrote down the time you had left Bundy while you and Dennis Fung were in the van on the way back to Rockingham, is that something that you had just made up?

# 200 MR. GOLDBERG:

Misstates the testimony.

# 201 THE COURT:

Overruled.

# 202 MS. MAZZOLA:

I believe we had written down the time.

# 203 MR. NEUFELD:

Well, what was your basis when you testified a moment ago that you wrote down the time you left Bundy in the van while you and Dennis Fung were on your way back to Rockingham?

# 204 MS. MAZZOLA:

That I knew the approximate time that we had left Bundy.

# 205 MR. NEUFELD:

But did you have an independent recollection of actually writing it down while you were in the van in transit?

# 206 MS. MAZZOLA:

I can't remember if I recall if it was in fact when we were in the van, if we had just left or if we were sitting in the truck getting ready to leave or what.

# 207 MR. NEUFELD:

But you said you have independent recollection--I'm sorry.

# 208 THE COURT:

Counsel.

# 209 MR. NEUFELD:

I'm sorry. Please.

# 210 MS. MAZZOLA:

No. Go ahead.

# 211 MR. NEUFELD:

A moment ago, you testified that you did have a recollection that either while you were sitting in the van or while the van was in transit, that you actually wrote down an entry as to the time that you had left Bundy? Wasn't that what you just testified to a little while ago?

# 212 MS. MAZZOLA:

Correct.

# 213 MR. NEUFELD:

And my question to you is, ma'am, when you testified to that a little while ago, did you simply make that up?

# 214 MS. MAZZOLA:

No. I thought we had.

# 215 MR. NEUFELD:

Then what was your basis for believing that you had done that?

# 216 MS. MAZZOLA:

That I knew the approximate time we had left.

# 217 MR. NEUFELD:

Well, and what was the source of your information as to the approximate time that you left?

# 218 MS. MAZZOLA:

The time I had in my notes.

# 219 MR. NEUFELD:

But the time you just put in your note is not a note that you made on June 13th, is it?

# 220 MS. MAZZOLA:

It appears not to be.

# 221 THE COURT:

All right. Now we've gone through this twice now.

# 222 MR. NEUFELD:

As best you can recall at this time, Miss Mazzola, what time did you leave Bundy?

# 223 MS. MAZZOLA:

Approximately 3:15 or so.

# 224 MR. NEUFELD:

Yet, would you agree, Miss Mazzola, that you have no independent basis for estimating that time?

# 225 MR. GOLDBERG:

Asked and answered.

# 226 THE COURT:

Sustained.

# 227 MR. NEUFELD:

Now, when you first got back to Rockingham, Miss Mazzola, the first place you inspected was the exterior south side of Mr. Simpson's residence; is that correct?

# 228 MS. MAZZOLA:

That is correct.

# 229 MR. NEUFELD:

And while you were down inspecting and examining that location of Mr. Simpson's property, you noticed a red mark on a wire hanging down; did you not?

# 230 MS. MAZZOLA:

It was brought to my attention that there was a red mark on a wire back there.

# 231 MR. NEUFELD:

And who was it that brought that to your attention?

# 232 MS. MAZZOLA:

I can't remember if it was Mr. Fung or a detective.

# 233 MR. NEUFELD:

And after it was brought to your attention, did you then return to the front of the house to go get your stain collection kit?

# 234 MS. MAZZOLA:

Yes.

# 235 MR. NEUFELD:

And then once you got the stain collection kit, you alone went back to the side of the house to collect that stain; is that right?

# 236 MS. MAZZOLA:

Correct.

# 237 MR. NEUFELD:

And that reddish discoloration that you collected on that wire, that became item no. 11; did it not?

# 238 MS. MAZZOLA:

Yes.

# 239 MR. NEUFELD:

And you collected that item no. 11 without Dennis Fung even being present to observe; isn't that correct?

# 240 MS. MAZZOLA:

That's correct.

# 241 MR. NEUFELD:

And just like the other stains that you collected that day, you swatched the reddish area; did you not?

# 242 MS. MAZZOLA:

I swatched the area that came up pheno positive. I had trouble seeing exactly the red mark itself.

# 243 MR. NEUFELD:

Miss Mazzola, you saw a reddish discoloration on the wire?

# 244 MS. MAZZOLA:

It was pointed out to me, but I still couldn't quite make it out.

# 245 MR. NEUFELD:

You're saying that you couldn't make out that it was a reddish stain on the wire before you collected it? Is that your testimony?

# 246 MS. MAZZOLA:

The wire was dirty and we did a pheno test on it--

# 247 MR. NEUFELD:

Miss Mazzola, I'm asking--

# 248 THE COURT:

Wait.

# 249 MR. NEUFELD:

May I have a sidebar, your Honor?

# 250 THE COURT:

Yes, you may.

# 251 MR. NEUFELD:

Thank you.

# 252 THE COURT:

With the Court reporter.

Temperature

tense

Key Quotes (5)

Peter Neufeld

Were you told during those prep sessions, Miss Mazzola, that one way to deal with that particular problem would be to say that you never even saw the gate when you were there?

Direct accusation that prosecutors coached Mazzola to claim she didn't see the rear gate — the most explosive moment of the examination, implicating witness preparation as cover-up.

Andrea Mazzola

I honestly don't remember seeing a gate there.

Mazzola's denial of seeing the rear gate, despite later acknowledging the gate was there on June 13th and that she walked through it — the central credibility problem Neufeld was constructing.

Lance A. Ito

Sustained, but the jury can draw their own conclusion given the proximity.

Judge sustains objection on speculation about the uncollected paper but pointedly reminds the jury they can infer its significance — unusual judicial commentary benefiting the defense.

Andrea Mazzola

I was told to pick up every stain.

Mazzola attributes the collection protocol to Fung's instructions rather than her own professional judgment, undercutting her earlier testimony about criminalist discretion.

Peter Neufeld

Did you come up with that idea on your own, ma'am?

Follow-up to the coaching accusation — rhetorically devastating even though sustained, implying the only two explanations are coaching or deliberate fabrication.

Evidence (5)

Exhibit 1080

Photograph showing an unidentified piece of paper on the tile walkway near Nicole Brown Simpson's body

Introduced by Neufeld to challenge what was and wasn't collected at the scene

Items 47, 48, 49, 50, 52

Blood drops collected along the Bundy walkway on June 13, 1994

Discussed to establish collection sequence and proximity to rear gate

Item 11

Reddish discoloration swatched from a wire on the south side exterior of Rockingham

Discussed to establish Mazzola collected it alone without Fung present, raising chain of custody concerns

Informal

Blood found on the rear Bundy gate collected three weeks after the murders, not on June 13th

Referenced as the underlying problem Neufeld argued Mazzola was coached to explain away

Informal

Mazzola's field notes — purportedly showing departure time from Bundy

Challenged as not a contemporaneous entry made on June 13th

Notable Exchanges (4)

Peter Neufeld•Andrea Mazzola

Neufeld pressed Mazzola on why she could not recall seeing the rear gate despite acknowledging she walked through it and that it was there. After Mazzola repeatedly said she didn't remember the gate, Neufeld accused the prosecution of coaching her to use that claim as cover for the missing gate blood.

devastating

Peter Neufeld•Andrea Mazzola

Mazzola initially testified she wrote down the Bundy departure time in the van en route to Rockingham, but when pressed could not produce a contemporaneous note and appeared to acknowledge the note was not made on June 13th. Neufeld asked bluntly whether she had 'simply made that up.'

revealing

Peter Neufeld•Andrea Mazzola

Neufeld used exhibit 1080 to show a piece of paper lying on the walkway near the body that was never collected, contrasting it with Mazzola's earlier testimony that criminalists must use discretion and avoid collecting 'garbage.' Neufeld suggested the paper could have held a fingerprint, blood, or writing identifying the assailant.

strategic

Lance A. Ito•Andrea Mazzola

The judge himself intervened to ask Mazzola whether she had been back to Bundy and seen the gate, establishing for the record that she now knows the gate exists — undercutting her repeated claim of not remembering it on June 13th.

revealing

Credibility Attacks (4)

⚔ Andrea Mazzola

Implied prosecutorial coaching

Neufeld directly asked whether prosecutors told Mazzola during prep sessions to say she never saw the rear gate as a way to explain why gate blood collected three weeks later was never collected on June 13th.

⚔ Andrea Mazzola

Prior inconsistent statement / fabrication

Mazzola testified she wrote down the Bundy departure time in the van, but could not produce a contemporaneous note and ultimately acknowledged the note she showed was not made on June 13th. Neufeld asked directly whether she had 'made that up.'

⚔ Andrea Mazzola

Failure to independently observe evidence

Mazzola admitted she was directed by Fung to collect every stain and was directed by Fung to collect item 52 outside the rear gate; she did not independently notice the gate or any stains on it despite training to keep her eyes open at crime scenes.

⚔ Andrea Mazzola

Chain of custody / unsupervised collection

Mazzola acknowledged she collected item no. 11 (reddish stain on wire at Rockingham) entirely alone, without Fung present to observe — inconsistent with proper evidence handling protocols.

Witness Demeanor

(Brief pause.) — multiple instances when Mazzola checked notes before answering

(The witness complies.) — steps down and returns to demonstrate diagram

Mazzola begins to give rambling, equivocating answers under sustained pressure on the gate issue

Objections

12 objections (8 sustained, 4 overruled)

Proceeding 5809 • 252 utterances • Prosecution witness

Criminal Trial

Department 103