📄 Sidebar: phenolphtalein test admissibility — Wednesday, April 26, 1995
Address:
C:\DEPT103\CRIMINAL\1995\APR\26\SIDEBAR-PHENOLPHTALEIN-TEST-AD.DOC
TRIAL
▲ Day 62 of 167

Sidebar: phenolphtalein test admissibility

Date: Wednesday, April 26, 1995 • Utterances: 35
Defense attorney Neufeld complained that LAPD criminalist Andrea Mazzola spontaneously volunteered testimony about a phenolphtalein (presumptive blood) test on 'item 11' (a wire) — evidence the court had previously ruled inadmissible unless explicitly asked about. After a brief discussion clarifying that DOJ's test on the same wire came back negative while Mazzola claimed a positive, Judge Ito dismissed the dispute as 'a huge mountain out of a molehill' and ordered the jury to disregard the positive phenolphtalein result.
1 (The following proceedings were held at the bench:)
2 THE COURT:

We're at the sidebar. I think I made a mistake by putting this mat here because you guys will feel welcome to stand there and feel comfortable. Mr. Neufeld, the appropriate way to deal with a nonresponsive question--nonresponsive answer to your question is to ask the Court to strike the question and answer and admonish the jury, not to cut the witness off. You have a very bad habit of cutting witnesses off, especially this witness. I have admonished you a number of times. I don't want to have to do it in front of the jury, impose sanctions, but if I have to, I will.

3 MR. NEUFELD:

What I'm concerned with, your Honor, is, this witness volunteered information that she had--

4 THE COURT:

Keep your voice down.

5 MR. NEUFELD:

This witness volunteered information the Court had already ruled was inadmissible in this case; namely, that they did a pheno type test on that wire. That had been the ruling of the Court. The People knew about that ruling. I'm sure they must have informed the witness not to bring it up--

6 THE COURT:

Keep your voice down.

7 MR. NEUFELD:

Sorry.

8 MR. GOLDBERG:

Excuse me, your Honor.

9 MR. NEUFELD:

--bring it up unless it was explicitly inquired as to in questioning. I did not ask any question at all that caused her to start testifying to the phenolphtalein test results on that wire. I simply asked her about color and collection and she all of a sudden on her own volunteered that business about the phenolphtalein test, which is improper.

10 THE COURT:

Hold on. What's the status of the--was there any subsequent testing done on item 11?

11 MR. GOLDBERG:

No. But there were swatches of--oh, yes, there was subsequent testing. I'm sorry. There was.

12 THE COURT:

Item 11's been tested?

13 MR. GOLDBERG:

It was tested I think at the DOJ for a presumptive test for blood.

14 MR. NEUFELD:

That's actually not correct, okay. There's never been a confirmatory test on it, which I think is the Court's question, by anybody doing DNA testing or any confirmatory test. So therefore--

15 THE COURT:

What test has been done on it?

16 MR. GOLDBERG:

I think it was a phenolphtalein test. Let me go check.

17 MR. NEUFELD:

I'm worried about this because it should not have been told to the jury. And frankly, Mr. Goldberg had a duty to advise the witness that those phenolphtalein tests were inadmissible unless they were explicitly gone into.

18 THE COURT:

Miss Clark.

19 MS. CLARK:

Yes, your Honor. On the wire, the only thing that's happened, Andrea Mazzola did a presumptive phenolphtalein. DOJ did a different presumptive. There was insufficient sample to do anything further. They came up with a negative on the stain, but came up with a positive on the substrate control so that you have basically nothing on the wire.

20 MR. NEUFELD:

In other words, even more important--because in fact what happened is that DOJ did not get a positive phenolphtalein test on the evidence. Miss Mazzola claims she did. So that's it. So it should have never been alluded to.

KEY QUOTE
21 THE COURT:

This is a huge mountain out of a molehill.

KEY QUOTE
22 MR. NEUFELD:

I'm asking your Honor to order it stricken and order the jury to disregard those answers and those questions.

23 THE COURT:

All right. Let's proceed.

24 MR. GOLDBERG:

Can I be heard on that?

25 THE COURT:

Mr. Goldberg, you want to be heard?

26 (Discussion held off the record between the Deputy District Attorneys.)
27 THE COURT:

Mr. Goldberg.

28 MR. GOLDBERG:

Well, the problem is that he's--is the Court striking it or not?

29 THE COURT:

I'm inclined to.

30 MR. GOLDBERG:

Okay. the problem is, he's dancing around and around and around this issue and there's no way that she can explain what she did with that type of phenolphtalein test. My understanding of it is, from her testimony in addition to what I've been told before, that you can't see anything on that wire, that they--or she couldn't at least. maybe Mr. Fung did. I think Mr. Fung did. But she phenoed it and she got a test. She's collecting almost at random from the area where she got positive tests.

31 THE COURT:

Okay. All right. Then I'm going to tell them to disregard the report that there was a positive phenolphtalein result.

32 MR. GOLDBERG:

But they can consider what she--

33 THE COURT:

the questions about collecting it.

34 MR. GOLDBERG:

I do not understand why he's even getting into that.

35 MS. CLARK:

That's fair.

Temperature

tense

Key Quotes (4)

Lance A. Ito
This is a huge mountain out of a molehill.
Judge Ito's dismissive framing of Neufeld's motion undercuts the defense's urgency and signals his general temperament toward the dispute.
Peter Neufeld
Even more important--because in fact what happened is that DOJ did not get a positive phenolphtalein test on the evidence. Miss Mazzola claims she did. So that's it. So it should have never been alluded to.
Neufeld reveals a conflict between Mazzola's claimed positive result and DOJ's negative — a direct credibility issue with the LAPD criminalist.
Marcia Clark
They came up with a negative on the stain, but came up with a positive on the substrate control so that you have basically nothing on the wire.
Clark concedes the wire testing yielded no meaningful result, neutralizing the significance of Mazzola's volunteer testimony.
Peter Neufeld
Mr. Goldberg had a duty to advise the witness that those phenolphtalein tests were inadmissible unless they were explicitly gone into.
Neufeld places responsibility on the prosecution for the witness's non-responsive answer, implying coaching failure.

Evidence (1)

Informal
Item 11 — a wire subjected to phenolphtalein (presumptive blood) testing by both LAPD criminalist Mazzola and DOJ; conflicting results between the two labs
discussed, testimony ordered stricken

Notable Exchanges (3)

Peter NeufeldLance A. Ito
Ito opens the sidebar by admonishing Neufeld for his habit of cutting off witnesses, warning sanctions are possible, before Neufeld pivots to the actual complaint about inadmissible testimony.
tense
Peter NeufeldMarcia ClarkHank Goldberg
All three attorneys piece together what testing was actually done on the wire — Goldberg initially uncertain, Clark ultimately clarifying DOJ got a negative on the stain — revealing the prosecution's own evidence undercuts Mazzola's claimed positive.
strategic
Hank GoldbergLance A. Ito
Goldberg pushes back on the strike, arguing Mazzola's collection methodology context should remain in evidence; Ito agrees the jury can consider the collection testimony but must disregard the positive phenolphtalein result.
procedural

Credibility Attacks (1)

⚔ Andrea Mazzola
prior inconsistent result / contradicting lab finding
Neufeld highlights that Mazzola claimed a positive phenolphtalein result on the wire while DOJ testing of the same item came back negative, raising doubt about her lab work.

Objections

1 objections (1 sustained, 0 overruled)
Proceeding 5810 • 35 utterances
Criminal Trial
Department 103
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