📄 Direct examination of Dr. Henry Lee (part 4) — Wednesday, August 23, 1995
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▲ Day 141 of 167

Direct examination of Dr. Henry Lee (part 4)

Witness: Dr. Henry Lee
Examiner: Barry Scheck
Called by: Defense • Date: Wednesday, August 23, 1995 • Utterances: 208
Defense forensic expert Dr. Henry Lee testified about changes between sequential photographs of an envelope from the crime scene, pointing out a blood drop that appeared in later photos that was not present in the original, and trace material that disappeared. He then walked through a board from his own forensic textbook laying out the proper steps of crime scene examination — recognition, preservation, documentation, collection, identification, comparison, individualization, and reconstruction — connecting each step to alleged failures in the LAPD's evidence handling. The session closed with the beginning of his analysis of the Rockingham socks and their improper collection.
1 (Deft's 1349 for id = board)
2 MR. SCHECK:

And, Dr. Lee, could you please explain what these three pictures show?

3 DR. LEE:

These three picture depicts the same envelope, show the three pictures were taken different point of time. The first picture, second picture were provide to me by attorney Shapiro. Those picture depicts here appear to be taken by LAPD photographer. The third one is a picture which I took February 18, 1995 at Albany Medical Center (Indicating).

4 MR. SCHECK:

Now, Dr. Lee, would the picture in the middle represent the envelope as shown in the photograph in what we have been calling position no. 1?

5 DR. LEE:

Yes.

6 MR. SCHECK:

So that is the photograph, the first photograph in time that we know of of that envelope?

7 DR. LEE:

Yes.

8 MR. SCHECK:

And the one to the left is position no. 2?

9 DR. LEE:

Yes.

10 MR. SCHECK:

And the one to the right are the pictures taken--picture taken at Albany Medical Center?

11 DR. LEE:

Yes.

12 MR. SCHECK:

Okay. Now, could you describe to us some of the differences on these pictures between these envelopes?

13 DR. LEE:

The center envelope is this envelope which the first record, the first documentation which I can see. On the envelope near the top region, large amount of trace material. Hair and fiber-like trace appear to be in this area. The one I just show you previously, here some soil trace material already caked in this area. The photograph which I received subsequently, those trace material was found to be absent. It's gone. It's no longer on this surface. The leaf, for example, here, it's absent from this location. The leaves underneath this envelope are absent from this location. This piece of material appear to be absent from this location (Indicating). In addition, I notice some other changes. The most clear one is here. I see a blood drop in this location absent. No blood drop.

14 MR. SCHECK:

Could you circle that blood drop, please, that you have indicated is in the envelope on position no. 2 that is not in position no. 1?

15 (The witness complies.)
16 MR. SCHECK:

Now, Dr. Lee, when you were discussing before the parallel line imprint pattern--

17 DR. LEE:

Yes.

18 MR. SCHECK:

--that we began with yesterday, is that visible in the position no. 1 photograph?

19 DR. LEE:

Yes.

20 MR. SCHECK:

Is the Bruno Magli imprint visible in the position no. 1 photograph?

21 DR. LEE:

Yes.

22 MR. SCHECK:

Are the imprint patterns that were consistent with fingers visible on the original photographs?

23 MR. GOLDBERG:

Misstates the testimony.

24 THE COURT:

Overruled.

25 DR. LEE:

It's appear in this location and this location still remain on the surface (Indicating).

26 MR. SCHECK:

So in other words, those patterns which you indicated before had to be made when blood was wet or in the original photograph of position no. 1?

27 DR. LEE:

That's correct.

28 MR. SCHECK:

So when those were made, the blood was wet at that time?

29 DR. LEE:

Yes.

30 MR. SCHECK:

And to your understanding, is that before anybody came and touched that envelope and processed that scene?

31 DR. LEE:

This appears--

32 MR. GOLDBERG:

Calls for lack of personal knowledge, speculation, conjecture.

33 THE COURT:

Sustained.

34 MR. SCHECK:

Well, have you kept track of the testimony to some degree of the various witnesses in this case?

35 MR. GOLDBERG:

Well, vague.

36 DR. LEE:

No.

37 MR. SCHECK:

Is it your understanding from the testimony in this case, Dr. Lee, that the crime scene had been processed--

38 THE COURT:

Sustained. It's leading. He's also said he didn't follow the testimony.

39 MR. SCHECK:

All right. We'll leave that. In terms of the bloodstain that you've circled, are there any other stains on the envelope in position no. 1 that weren't there in position--position no. 2 that weren't there in position no. 1?

40 DR. LEE:

There are some stains. However, very difficult to make a comparison due to this again is three-dimensional setting, we look at two-dimensional picture. I can tell this clearly, this one wasn't there. There are some subtle one, minor one which I'm not going to testify.

41 MR. SCHECK:

Now, in conclusion, Dr. Lee, from this envelope, can you determine from bloodstain pattern that imprint impressions that you've described were made on it in wet blood in the course of the struggle?

42 MR. GOLDBERG:

Calls for conclusion, speculation, conjecture.

43 THE COURT:

Overruled.

44 MR. GOLDBERG:

No foundation.

45 DR. LEE:

Assume those are footwear, part of footwear imprint, which indicative these two have to be deposit when envelope was on the ground. Assume those material--

46 MR. GOLDBERG:

At this time, I'm going to object. He's just making a series of assumptions.

47 THE COURT:

Sustained. Next question.

48 MR. SCHECK:

Based on the assumption that the trace evidence and bloodstains as reflected in the envelope on position no. 1 were deposited there during the course of the homicides in this case, what does the pattern indicate?

49 MR. GOLDBERG:

Speculation, conjecture, no foundation.

50 THE COURT:

Overruled.

51 DR. LEE:

Which indicative with movement and consistent with struggle.

52 MR. SCHECK:

All right. And you're talking about the Bruno Magli imprint?

53 DR. LEE:

Yes.

54 MR. SCHECK:

The parallel line imprint?

55 DR. LEE:

Yes.

56 MR. SCHECK:

The imprints you've described as being consistent with fingers making contact with the envelope?

57 MR. GOLDBERG:

Misstates the testimony.

58 THE COURT:

Sustained.

59 MR. SCHECK:

The imprints on the envelope that you described in 1347 and 1348--

60 MR. GOLDBERG:

At this point, counsel is just testifying.

61 THE COURT:

No, he's not. He's asking a question. Proceed.

62 MR. SCHECK:

1347 and 1348?

63 DR. LEE:

Yes.

64 MR. SCHECK:

And those are all on position no. 1?

65 DR. LEE:

Yes.

66 MR. SCHECK:

Okay. Any other bloodstain patterns of interest in this board?

67 DR. LEE:

This particular drop (Indicating) which appeared to be grouped when I examine this envelope at February 18, 19, which correlate to this drop which was original absent from.

68 MR. SCHECK:

And are you aware that conventional serology was done on that drop?

69 MR. GOLDBERG:

No personal knowledge.

70 THE COURT:

Sustained.

71 MR. SCHECK:

Okay. Your Honor, in terms of timing--

72 THE COURT:

2:30.

73 MR. SCHECK:

2:30?

74 THE COURT:

2:30.

75 MR. SCHECK:

Would ask that this board be marked Defendant's next in order.

76 THE COURT:

1349?

77 THE CLERK:

50.

78 THE COURT:

I'm sorry. 1350.

79 (Deft's 1350 for id = board)
80 MR. SCHECK:

Now, Dr. Lee, does this board reflect something that appears in one of the books you've written?

81 DR. LEE:

Yes.

82 MR. SCHECK:

And what is it?

83 DR. LEE:

This is steps for forensic examination, the logic sequence when we get to crime scene or examine piece of physical evidence. That's the required step of process.

84 MR. SCHECK:

And I ask you to review these steps very briefly and connect it to what was available to you in the course of your investigation in this case and what wasn't.

85 DR. LEE:

The first step of any crime scene is recognition.

86 THE COURT:

All right. Mr. Scheck, let me ask you a question just logistically. Given the nature of this chart, is there any reason we can't have Dr. Lee back on the witness stand and with the chart turned the other way?

87 MR. SCHECK:

No, there isn't--

88 THE COURT:

So it doesn't block my view.

89 MR. SCHECK:

Okay.

90 THE COURT:

All right. Dr. Lee, why don't you pull the microphone close to you, please. Thank you. Mr. Scheck.

91 MR. SCHECK:

You were discussing the recognition stage and what that means.

92 DR. LEE:

First step of any forensic examination of the crime scene of physical evidence have to go through a step called recognition. You have to see it, recognize it before we can do anything. If any potential evidence you did not see it or imprint evidence on certain object, you did not recognize, subsequent step become obsolete since did not recognize, then we did not go through identification examination. So recognition is very crucial for any crime scene investigation, for any examination of physical evidence. Once we recognize the particular item, have particular importance or potential of value relate to a case, then we go through the next step. The next step is a composition of a lot of sub steps.

93 MR. GOLDBERG:

At this point, this is a narrative, your Honor.

94 THE COURT:

All right. Why don't you ask him category by category, Mr. Scheck.

95 MR. SCHECK:

Yes. First, with respect to recognition, when you're saying that's the most important step, for example, you discussed briefly yesterday how one can go about identifying latent footprints. Do you recall that?

96 DR. LEE:

Yes.

97 MR. SCHECK:

All right. Now, just as an example, if one does not carefully examine a scene to find latent footprints, would that be what you would call a failure of recognition?

98 DR. LEE:

Yes.

99 MR. SCHECK:

And are failures of recognition--withdrawn. And evidence that is not recognized--all right. Let's--I'm mindful of the time. Let's move on to the next step, preservation, documentation and collection. What do you mean by that?

100 DR. LEE:

This is a group activity. Have to be performed right after recognition to document the original shape by variety of methods, notes, diagram, photograph, videotaping, description prior to the collection. Also have to at the same time preserve the scientific integrity and the legal integrity of this potential evidence after it recognized.

101 MR. SCHECK:

So would videotaping a crime scene be a method in terms of preservation and documentation?

102 DR. LEE:

Yes.

103 MR. SCHECK:

And would keeping accurate notes with respect to what was collected, when it was collected and who collected it be the kind of thing that you mean by documentation and collection?

104 DR. LEE:

Yes.

105 MR. GOLDBERG:

At this point, your Honor, this is cumulative, irrelevant.

106 MR. SCHECK:

I'm trying to move through it.

107 THE COURT:

Proceed.

108 MR. SCHECK:

Would--what is chain of custody, Dr. Lee?

109 MR. GOLDBERG:

Cumulative under 352.

110 THE COURT:

Overruled.

111 MR. GOLDBERG:

Also, calls for legal conclusion.

112 THE COURT:

Overruled.

113 DR. LEE:

To a scientist, a forensic scientist, chain of custody means start of initial step. We have to keep a record of this, any transaction of this piece of evidence.

114 MR. SCHECK:

All right. Would, for example, counting the number of swatches used to collect the bloodstain be an example of activities in this preservation, documentation and collection area?

115 MR. GOLDBERG:

Unintelligible and argumentative.

116 THE COURT:

Overruled.

117 DR. LEE:

Yes.

118 THE COURT:

We did go through this with a variety of witnesses, Mr. Ragle.

119 MR. SCHECK:

I'm moving quickly.

120 MR. SCHECK:

What do you mean by identification?

121 DR. LEE:

Once the sample collected, submit to the laboratory, first we go through identification step, try to use methodological pattern, physical characters and simple chemical tests to identify a certain piece of material and the nature of such piece of evidence.

122 MR. SCHECK:

And if the preservation, documentation and collection is not done correctly, does that undermine your ability to do identification?

123 DR. LEE:

Yes.

124 MR. SCHECK:

And if the preservation, documentation, collection stage evidence is contaminated, does that undermine you to do identification?

125 DR. LEE:

Maybe.

126 MR. SCHECK:

What is "Comparison"?

127 DR. LEE:

Comparison, once you identify a particular object, for example, a hair, and we'll have known and questioned hair to compare. With a blood sample, known and questioned, soil sample, any type of sample, you need the known and question to make a comparison. Can compare biological property, physical property, microscopic characteristics and physical characteristic, try to see can we make a match.

128 MR. SCHECK:

What is "Individualization"?

129 DR. LEE:

Whether or not you can trace to the source origin. For example, simple example, a fingerprint. If you match all the ridge characteristics from a known fingerprint card to a latent fingerprint from a scene, then you say you individualize it now.

130 MR. SCHECK:

Now, what is meant by the term "Class characteristics"?

131 DR. LEE:

A large group of physical evidence at the current stage, there are limitation. We cannot reach a stage called individualization. We can only compare class characteristics, but not individual characteristics.

132 MR. SCHECK:

Would hair and fiber be an example of this?

133 DR. LEE:

Hair if just microscopic comparison, that's consistent. Not as an individualization. Cannot use as a positive identification of an individual.

134 MR. SCHECK:

That's what you would call just "Class characteristic comparison"?

135 DR. LEE:

It's little bit more than class, little lower than individualization.

136 MR. SCHECK:

Now, what is meant by "Reconstruction"?

137 DR. LEE:

Reconstruction is, after we go through all the step, now we start putting together what the significance of this piece of physical evidence fitting in the case like putting the puzzles together. Can we put the puzzle together and make some sense or we cannot put the puzzle together, make any sense.

138 MR. SCHECK:

Now, Dr. Lee, if the recognition stage and the preservation of documentation and collection stage is not performed correctly, what does that do to the ability to do reconstruction?

139 MR. GOLDBERG:

Asked and answered.

140 THE COURT:

Overruled.

141 DR. LEE:

This is the foundation. If you turn this chart upside down, if the foundation--we don't have a foundation, you take the building block away, whatever reconstruction becomes speculation.

142 MR. SCHECK:

So if evidence is contaminated or compromised in the recognition, preservation, documentation and collection phase, that makes it--undermines ability to do reconstruction?

143 DR. LEE:

Yes.

144 THE COURT:

All right. Let's move on.

145 MR. SCHECK:

That's it. Is it 2:30?

146 THE COURT:

2:30.

147 MR. SCHECK:

Your Honor, can I have a minute to get a board that's behind the door?

148 (Brief pause.)
149 MR. SCHECK:

Ask this be marked 1351.

150 THE COURT:

What is it?

151 MR. SCHECK:

It's entitled, "Trace material found on--physical evidence at Bundy, soil sample from item--from Bundy item 114."

152 (Deft's 1351 for id = board)
153 MR. SCHECK:

Dr. Lee, could you please describe to us what is depicted by the photographs on this board?

154 DR. LEE:

This board consists of four pictures. Shows a sample numbered 114, soil sample front, northwest of gate.

155 MR. SCHECK:

Says here "Soil exemplar." What does that mean?

156 DR. LEE:

My definition is control sample of the soil.

157 MR. SCHECK:

And when you say "A control sample of the soil," what would that mean in forensics?

158 DR. LEE:

It's an exemplar of soil collected from the scene.

159 MR. SCHECK:

In other words, to determine--

160 MR. GOLDBERG:

Leading.

161 THE COURT:

Sustained.

162 MR. SCHECK:

All right. Please continue with respect to the photographs here.

163 THE COURT:

Sustained.

164 MR. SCHECK:

All right. What is depicted in the central photograph indicating "Soil sample examined"?

165 DR. LEE:

On March 4th, 1995, while exam this sample, I put a piece of paper, clean paper, remove the soil debris from this envelope. That shows an overall view of those soil samples in this plastic bag.

166 MR. SCHECK:

What do the two pictures on the far right represent?

167 DR. LEE:

This two photograph are photomicrograph, taking the pictures through a microscope, which shows besides the soil, there are large amount of a trace material present in the soil, the soil sample.

168 MR. SCHECK:

And when you say "Trace material," what are you referring to?

169 DR. LEE:

I see dry vegetation, wood fragment, hairs, paint chip-like material, more hairs, fibers, a large amount of material in this envelope.

170 MR. SCHECK:

And when a soil exemplar is taken, is the purpose of that to take it from an area where there is no activity to get a sense of what is generally in the soil? Is that the idea behind it?

171 MR. GOLDBERG:

Well, calls for speculation.

172 THE COURT:

Overruled.

173 DR. LEE:

Generally, soil exemplar, we're taking at the location which we think has activities.

174 MR. SCHECK:

Okay. So in other words--and what is the purpose of taking such an exemplar?

175 DR. LEE:

For example, subsequently, you found the shoes, suspect's shoes, you can compare the soil, or you have hairs, you can compare the hair was original present in the soil or subsequently deposit on the surface.

176 MR. SCHECK:

I would like to now turn to a discussion of the socks, and I'd ask that this board be marked Defendant's next in order.

177 THE COURT:

All right. Mr. Scheck, which--

178 MR. SCHECK:

1352 I believe.

179 THE COURT:

All right.

180 (Deft's 1352 for id = board)
181 MR. SCHECK:

This first board marked 1352 entitled, "History of socks, item 13, June 13th, 1994 at Rockingham," briefly, Dr. Lee, what is this?

182 MR. GOLDBERG:

I don't think there's going to be any foundation for personal knowledge.

183 THE COURT:

Overruled.

184 MR. GOLDBERG:

He wasn't there.

185 DR. LEE:

This board consists three picture. This three picture was supplied to me by attorney Shapiro.

186 THE COURT:

Next question.

187 MR. SCHECK:

All right. Picture no. 1 is a--represents what in terms of the bedroom?

188 DR. LEE:

Depicts an overall view, shows this corner of the bedroom and a rug on the carpet, the bed and appear to be--in the center of this picture appear to be pair of socks (Indicating).

189 MR. SCHECK:

Direct your attention to the picture on the upper right-hand corner.

190 DR. LEE:

This picture is taken appear to be a different point of time. We see some changes in the picture. However, this pair of socks appear to be in the middle of this rug (Indicating).

191 THE COURT:

Isn't this redundant of Mr. Ford's testimony?

192 MR. SCHECK:

No, no. We're going in a different direction, your Honor.

193 THE COURT:

All right.

194 MR. SCHECK:

May I call your attention to close-up of two socks?

195 DR. LEE:

Yes.

196 MR. SCHECK:

And what does that appear to be in relation to the picture above it?

197 DR. LEE:

This appear to be a close-up showing this pair of same socks.

198 MR. SCHECK:

Uh-huh. Now, is there anything about the way those socks are lying on the carpet that is of interest in terms of subsequent analysis?

199 DR. LEE:

Yes.

200 MR. SCHECK:

What is it?

201 DR. LEE:

This two socks is clearly in two different location, not on top each other. This two socks both have a similarity. The top appear to be folding downward. These two socks, both side, the tip, the toe area cannot be seen whether or not due to this photograph, two-dimensional representation or in reality was tucked in, which I don't know. One sock appear to be crunched in a three-dimensional setting. The other one also, it's not flat. It's also crunched in certain fashion. These two socks, I can not determine just by looking at them inside out or outside in (Indicating).

202 MR. SCHECK:

In terms of the proper practices for collection of these socks, what should be done?

203 DR. LEE:

If I do it, I can not say about any other people. These two socks--

204 MR. GOLDBERG:

Not responsive.

205 THE COURT:

Overruled.

206 DR. LEE:

These two socks should be put in two separate bags. However, before I even pick it up, should noted the condition, dry, wet, moist or damp. In addition, should definite indicates inside out or outside in, the toe stuck inside or not or exposed, the top, whether or not in fact fall down works or not. A physical description and any obvious trace material or stain should be noted.

KEY QUOTE
207 MR. SCHECK:

Your Honor, we have two minutes and I have another board that will take longer. So I would suggest this would be a time.

208 THE COURT:

All right. Ladies and gentlemen, let's take our mid-afternoon break at this point. Please remember all my admonitions to you. And we'll stand in recess for 15 minutes. All right. Dr. Lee, you can step down.

Temperature

tense

Key Quotes (4)

Dr. Henry Lee
I see a blood drop in this location absent. No blood drop.
Lee identifies a blood drop visible in the position no. 2 envelope photograph that was not present in the original position no. 1 photograph, suggesting the evidence was disturbed or contaminated after the crime scene was documented.
Dr. Henry Lee
If you turn this chart upside down, if the foundation--we don't have a foundation, you take the building block away, whatever reconstruction becomes speculation.
Lee's central argument framing the entire defense case: if the recognition and collection stages were botched, all forensic reconstruction by the prosecution is meaningless.
Dr. Henry Lee
Those trace material was found to be absent. It's gone. It's no longer on this surface.
Lee documents that trace evidence — hairs, fibers, a leaf, soil — visible in early crime scene photographs had vanished by the time he examined the envelope, implying the scene was disturbed.
Dr. Henry Lee
These two socks should be put in two separate bags. However, before I even pick it up, should noted the condition, dry, wet, moist or damp. In addition, should definite indicates inside out or outside in.
Lee outlines what proper collection of the Rockingham socks would have required, implicitly criticizing how LAPD actually collected them.

Evidence (5)

Defendant's 1349
Board with three photographs of the envelope taken at different points in time: position no. 1 (LAPD photographer), position no. 2 (LAPD photographer), and Dr. Lee's own photograph taken February 18, 1995 at Albany Medical Center
Marked, displayed, and discussed; Lee circled missing blood drop
Defendant's 1350
Board depicting the steps of forensic examination from Dr. Lee's own published textbook: recognition, preservation, documentation, collection, identification, comparison, individualization, reconstruction
Marked and discussed as framework for criticizing LAPD evidence handling
Defendant's 1351
Board titled 'Trace material found on physical evidence at Bundy, soil sample from Bundy item 114' — four photographs including photomicrographs showing hairs, fibers, dry vegetation, wood fragments, and paint chips in the soil exemplar
Marked and discussed
Defendant's 1352
Board titled 'History of socks, item 13, June 13th, 1994 at Rockingham' — three photographs showing the socks as found in the bedroom on the carpet
Marked; discussion begun at end of session, cut off by recess
Defendant's 1347 and 1348
Previously marked exhibits depicting imprint patterns on the envelope including Bruno Magli shoe imprint, parallel line imprint, and finger-consistent impressions
Referenced in connection with position no. 1 envelope photograph

Notable Exchanges (3)

Barry ScheckDr. Henry LeeHank GoldbergJudge Ito
Lee testified that patterns on the envelope had to be made while blood was wet, and Scheck tried to establish this predated any police processing — Goldberg sustained an objection on personal knowledge before Lee could answer, cutting off the inference the defense was building.
strategic
Barry ScheckDr. Henry Lee
Using his own forensic textbook chart as scaffolding, Lee systematically walked through each step of proper forensic examination, allowing Scheck to connect every stage to an implied LAPD failure without needing to make the accusation directly.
methodical
Judge ItoBarry Scheck
Ito asked whether the board showing the socks was redundant of earlier witness Dennis Ford's testimony; Scheck assured him it was going in a different direction.
procedural

Light Moments (2)

Judge Ito
Judge Ito interrupted Lee's testimony mid-setup to ask whether the chart could be turned the other way so it didn't block his view — a purely logistical interjection in the middle of dramatic expert testimony.
Ito / Scheck
Running exchange about the 2:30 break time: Scheck asked 'Is it 2:30?' and Ito replied simply '2:30.'

Witness Demeanor

(The witness complies.) — circling the blood drop on the board as directed by Scheck

Objections

19 objections (5 sustained, 14 overruled)
Proceeding 7430 • 208 utterances • Defense witness
Criminal Trial
Department 103
⚖️ Start
📂 AUG 23, 1995 📄 Direct examination of Dr. Henr
AUG 23, 1995 KRT DvH TD