📄 Cross-examination of Dr. Henry Lee (afternoon, part 1) — Monday, August 28, 1995
Address:
C:\DEPT103\CRIMINAL\1995\AUG\28\CROSS-EXAMINATION-OF-DR-HENRY-.DOC
TRIAL
▲ Day 143 of 167

Cross-examination of Dr. Henry Lee (afternoon, part 1)

Witness: Dr. Henry Lee
Examiner: Hank Goldberg
Called by: Defense • Date: Monday, August 28, 1995 • Utterances: 483
Goldberg cross-examines defense forensic expert Dr. Henry Lee, methodically extracting concessions that undermine the defense's evidence-handling critique. Using a series of hypotheticals about bumbling police officers, Goldberg gets Lee to acknowledge that even imperfectly collected evidence can yield meaningful forensic results, and then turns Lee's own 'four-way linkage' theory against the defense by showing how it connects Simpson to both crime scenes. The examination also covers sock packaging, DNA interpretation, blood spatter, and a detailed walk-through of the Bundy crime scene photographs.
1 THE COURT:

All right. Thank you, ladies and gentlemen. The record should reflect that we have been rejoined by all the members of our jury. Dr. Henry Lee is still on the witness stand under going cross-examination by Mr. Goldberg. And Mr. Goldberg, you may continue.

2 MR. GOLDBERG:

Now, Dr. Lee, you distinguished in your testimony between the manner of transfer as opposed to the mode of transfer; is that correct?

3 DR. LEE:

Yes, sir.

4 MR. GOLDBERG:

And the mode of transfer would be the exact mechanism, in other words, was it a hand, was it a gloved hand, was it an object, what is it exactly that caused that blood transfer; is that correct?

5 DR. LEE:

That's correct.

6 MR. GOLDBERG:

Now, with respect to that issue, the mode of transfer, were you able to render any opinion regarding the mode of transfer onto the socks?

7 DR. LEE:

There are numerous possibilities. I cannot tell you which one is definitively one method.

8 MR. GOLDBERG:

So would it be fair to say that on that this is an area where you were unable to render an opinion on that question, mode of transfer?

9 DR. LEE:

Yes, sir.

10 MR. GOLDBERG:

Now, you were asked a little bit about trace analysis on direct examination and you said that it fell in the area of hair examination somewhere in between class characteristics and individualization; is that correct?

11 DR. LEE:

Yes.

12 MR. GOLDBERG:

And did you explain this--excuse me. Do you agree with the following statement: "While it is difficult to make absolute individualizations in these areas, the trace analyst can make identifications with a high degree of certainly and can often establish partial individuality of a specimen with confidence based on experience and analytical results"?

13 DR. LEE:

I would say eighty to ninety percent that statement correct. They forgot one thing. Depends on samples. Not all the sample you can reach that degree of certainty. Some of the sample, yes, you can. Other sample maybe only can do a class characteristic identification.

14 MR. GOLDBERG:

Sir, have you ever publicly stated the comment that I just made in any public forum, whether it is published or oral?

15 DR. LEE:

Maybe in certain context. I try to tell the investigator how important trace evidence is in solving crime or to disassociate a person from a crime. Trace evidence have particular value. Don't overlook trace evidence. Although trace evidence we cannot approach positive identification, two extreme. One, called individualization; one called identification. A lot of physical evidence fall in between; degree, different degree. Fingerprint, that is a possible identification. A hair we cannot reach to that, say, just from this person, no other person.

16 (Discussion held off the record between the Deputy District Attorneys.)
17 MR. GOLDBERG:

Well, let me ask you this, doctor. Maybe I can just approach counsel for a moment.

18 (Discussion held off the record between Deputy District Attorney and Defense counsel.)
19 MR. GOLDBERG:

Sorry, your Honor. I just need to look at my index for a second.

20 (Brief pause.)
21 MR. GOLDBERG:

I will come back to it later.

22 (Brief pause.)
23 MR. GOLDBERG:

Let me just ask you this, Dr. Lee--

24 DR. LEE:

Yes.

25 MR. GOLDBERG:

--with respect to trace analysis, would it be your position that in some cases regarding hair comparisons that identifications can be made with a high degree of certainty and can often establish partial individuality of a specimen with confidence?

26 DR. LEE:

Yes, sir.

27 MR. GOLDBERG:

Okay. And there were certain items that you looked at where you packaged some hair and trace evidence in bindles in this case; is that right?

28 DR. LEE:

Yes, sir.

29 MR. GOLDBERG:

And one was the envelope and one was Ron Goldman's boots, and the other one was the soil sample; is that correct?

30 DR. LEE:

No.

31 MR. GOLDBERG:

That you were--

32 DR. LEE:

Actually 21 bindles.

33 MR. GOLDBERG:

Well, that you testified to on direct examination?

34 DR. LEE:

I testify on direct, yes, only three, but in reality when I examine I found 21 separate bindles of trace evidence.

35 MR. GOLDBERG:

I'm sorry, I was asking about the testimony. Now, with respect to these three items, Dr. Lee, did you do any comparisons yourself on any of the hair and trace evidence in those bindles?

36 DR. LEE:

No, I did not.

37 MR. GOLDBERG:

Okay. And is there any forensic significance to finding the materials that you found in those three items?

38 DR. LEE:

Unless examined, maybe some significance.

39 MR. GOLDBERG:

Well, sir, is it common to find stray hair and trace materials when you are analyzing a particular piece of evidence for hair and trace?

40 DR. LEE:

Yes.

41 MR. GOLDBERG:

And is there anything unusual about that?

42 DR. LEE:

Just shows the presence of trace and of course what type of trace becomes significant. Whether or not can link a person or disassociate a person now become significant. If you found trace, that is uncommon. If you give me time, I go to jewelry box, I can probably find hundreds of hairs, all different fibers.

43 MR. GOLDBERG:

And we might be able to find some hairs and fibers--we would be able to find some hairs and fibers in the jury box that don't belong to any of the jurors in this case?

44 DR. LEE:

If you give me time I will found a lot of hairs and fibers, maybe nothing to do with the jury panel.

45 MR. GOLDBERG:

Even though this jury panel has been sitting in this jury box for quite sometime?

46 DR. LEE:

Sure. Maybe I can find your hair there, too.

47 MR. GOLDBERG:

Okay. So there wouldn't be anything unusual about being able to find hairs and fibers at a crime scene that don't belong to the suspects and the victim; is that true?

48 DR. LEE:

Yes, that's correct.

49 MR. GOLDBERG:

Now, you were asked a little bit about the generalities of crime scene identification and the Defense used a chart that was Defense 1350, if we could just take a look at that.

50 (Brief pause.)
51 MR. GOLDBERG:

Now, sir, this chart was intended in order to represent the basic steps in terms of categories of forensic examination from crime scene forward; is that correct?

52 DR. LEE:

That's correct.

53 MR. GOLDBERG:

And I just want to make sure that I'm understanding exactly how to interpret the chart correctly. Let's say that we have a situation, doctor, where the biological evidence at a crime scene, let's say it is blood, is stepped in by a Defendant and it is deposited on the sole of his shoes and then he takes it to some other location.

54 MR. SCHECK:

Objection to the form of this hypothetical.

55 THE COURT:

Overruled.

56 MR. GOLDBERG:

Okay. Now, in that hypothetical scenario that I have given you has the collection, in effect, been done by the suspect himself instead of by a police officer?

57 DR. LEE:

The collection actually involve two force. You start with recognition. If say an individual step in the blood, walk on the surface, you deposit some evidence on that walking--say walkway surface. Not--it is not by Defendant himself. The detective or the criminalist at the scene have to see it to recognize it, try to enhance it and then collect it. If you forget about that you create a big problem for future reconstruction. The second half you are correct, the shoe itself become a valuable piece of evidence. Unless you find the shoe you can't really do a side-by-side comparison.

58 MR. GOLDBERG:

Okay. And in that kind of a hypothetical situation where you had found the shoe like that, say, you would still be able to test that shoe for conventional testing and for DNA testing; is that correct?

59 DR. LEE:

Yeah. The shoe again, the testing involve quite a bit now. Not only serological analysis, you have to--the most valuable is a pattern comparison, side-by-side the shoe and the footprint. You will have compare not only look at general characteristic, also look at the wear, cut, pattern, so-called individual characteristics. Grouping just one part of it, whether or not you can link to certain source of a blood, just like hair, soil, whether or not you are link to the--back to the scene, so the whole process is involved in recognition, preservation, documentation, collection, everything.

60 MR. GOLDBERG:

Okay. And you would agree that--that--let me ask another question. Let's change the hypothetical a little bit.

61 DR. LEE:

Yes, sir.

62 MR. GOLDBERG:

And let's say that instead of a suspect at the crime scene we have a brand new police officer at his first crime scene.

63 DR. LEE:

Uh-huh.

64 MR. GOLDBERG:

And he accidentally steps in some blood.

65 DR. LEE:

Yes.

66 MR. GOLDBERG:

And he is a little panicked and he is nervous about doing that, obviously, and he--but he immediately takes his shoe off, Dr. Lee.

67 DR. LEE:

Okay.

68 MR. GOLDBERG:

And he brings it to you.

69 DR. LEE:

Yes.

70 MR. GOLDBERG:

You would still be able to analyze the blood on that shoe, wouldn't you?

71 MR. SCHECK:

Your Honor, I haven't heard--no foundation.

72 THE COURT:

Overruled.

73 DR. LEE:

If the shoe bring to me, yes, I will be able to identify whether or not that is blood. If in fact blood, human blood or not. If it is human blood, of course just like you indicate that additional serological grouping type A, type B, type O, DNA typing try to see whose blood. Equally important I have to look at a scene whether or not have same type of shoeprint.

74 MR. GOLDBERG:

So there is a variety of testing that you could do even in the hypothetical that I gave you?

75 DR. LEE:

All start with recognition.

76 MR. GOLDBERG:

Yeah.

77 DR. LEE:

You have to see it first.

78 MR. GOLDBERG:

Okay. And in my particular hypothetical, though, doctor, the police officer obviously didn't recognize the blood at the time that he stepped in it, right?

79 DR. LEE:

Yes.

80 MR. GOLDBERG:

And he didn't accurately document it or--or photograph it; is that correct?

81 DR. LEE:

Yes.

82 MR. SCHECK:

Your Honor, I object to this on foundational grounds and 352 grounds.

83 THE COURT:

Overruled.

84 MR. GOLDBERG:

And would you agree, doctor, that a police officer dabbing his foot in blood is--and then using his shoe for analysis wouldn't be the recommended collection technique?

85 DR. LEE:

I'm lost.

86 MR. GOLDBERG:

Okay. Well, you go out and lecture police officers?

87 DR. LEE:

Yes, sir.

88 MR. GOLDBERG:

Let's say a police officer raises his hand, he is in the audience. "Dr. Lee, if I don't have any swatches or I don't have any bindles to scrape off the blood, can I just dab my foot in it and submit my shoe for analysis?"

89 MR. SCHECK:

Objection, assumes facts not in evidence, no foundation.

90 THE COURT:

Overruled.

91 MR. GOLDBERG:

Would you tell the officer, "Well, I don't recommend that"?

92 DR. LEE:

I probably tell don't dab, just give me your shoes and don't do it next time.

KEY QUOTE
93 MR. GOLDBERG:

Okay. All right. So even though we have a big mistake in terms of recognition, in terms of preservation, documentation, collection, identification, we can still do comparison, we can still do individualization; is that correct, in my hypothetical?

94 DR. LEE:

You going to be on shaky ground because unless we recognize everything where we can do partial reconstruction.

95 MR. GOLDBERG:

We probably can't do reconstruction?

96 DR. LEE:

Cannot do a complete reconstruction.

97 MR. GOLDBERG:

If I may approach for a second.

98 MR. GOLDBERG:

So in my hypothetical we are probably going to--

99 THE COURT:

Excuse me, Mr. Goldberg. You are blocking juror no. 7.

100 MR. GOLDBERG:

We botched preservation documentation and collection in the hypothetical. Identification we nailed, right?

101 DR. LEE:

Yes.

102 MR. GOLDBERG:

Comparison we nailed?

103 DR. LEE:

Yes.

104 MR. GOLDBERG:

Correct? Individualization depends on how many problems?

105 DR. LEE:

Right.

106 MR. GOLDBERG:

Okay. Reconstruction probably not?

107 DR. LEE:

Yes, that's correct.

108 MR. GOLDBERG:

So doctor, if we wanted to change the title of the chart from "Steps in forensic examination" to "Garbage in, garbage out," that would be incorrect from a scientific standpoint, wouldn't it?

109 DR. LEE:

No, you cannot change my title.

KEY QUOTE
110 MR. GOLDBERG:

Okay. Thank you. Good.

111 DR. LEE:

But garbage in, garbage out, that is a common thing I use in lecture. You collect a lot of garbage from the crime scene. Laboratory scientist, my report going to like garbage. You don't really don't know where it come from, what is going to happen, like a garbage report. You have to do a so-called total team approach. Everybody have to work together do the best job.

112 MR. GOLDBERG:

Right. But known cases, just as the one I related, sometimes--I won't say that you can save the case, but you can still get some very meaningful test results, very meaningful evidence?

113 DR. LEE:

Yes, that's correct.

114 MR. GOLDBERG:

Now, if we changed our hypothetical again, Dr. Lee, see that the police officer photographed the bloodstain properly--

115 DR. LEE:

Uh-huh.

116 MR. GOLDBERG:

--before he stepped in it, then we might even be able to do some reconstruction as well; is that true, limited?

117 DR. LEE:

Limited.

118 MR. SCHECK:

Your Honor, I will again object to--unless there is facts in evidence, I think the hypotheticals and changes have no basis in foundation.

119 THE COURT:

Overruled. Overruled.

120 MR. GOLDBERG:

Doctor, when I was questioning you a little while ago, you were talking--I think that you said something to the effect that you wouldn't recommend someone using their hands to touch the swatches to see whether they were dry?

121 DR. LEE:

Yes.

122 MR. GOLDBERG:

But if we had someone who did that, and let's say our same police officer, our new police officer who is new, oh, my heavens, not only did I do all those other things, I also touched the swatches with my hands--

123 MR. SCHECK:

Your Honor, this is foundation, facts not in evidence; swatches.

124 THE COURT:

Overruled. Overruled.

125 MR. GOLDBERG:

Dr. Lee, would your procedure there be that you would take a blood sample from the police officer, correct?

126 DR. LEE:

Yes.

127 MR. GOLDBERG:

And you would test his--depending on what testing you were doing, you might do conventional serology, you might do PCR and RFLP, correct?

128 DR. LEE:

Yes.

129 MR. GOLDBERG:

And you would still then test the evidence; is that true?

130 DR. LEE:

Yes. I will test the evidence with the control. If somebody touch it, the body cell may contaminate to the evidence. That is one possibility. Second, only for the protection of the individual may have a cut, some hepatitis or aids or other virus may infect the individual, so touching, not only is a contamination, also protection. If have some body material transfer to that sample, now you are going to have a contaminated sample. We have to have a known control compare, try to resolve, see what we can do.

131 MR. GOLDBERG:

And although things like that aren't supposed to happen, every once in awhile there are cases where something like that does occur?

132 DR. LEE:

Yes.

133 MR. GOLDBERG:

All right. Now, you were asked about the socks being packaged together in an envelope and I just wanted to clarify your testimony on this topic. Is the packaging--let's say that you have two socks at a crime scene and you collect them together and you put them in the same bag together.

134 DR. LEE:

Yes.

135 MR. GOLDBERG:

Is it your position that there could be a transfer from one sock to another sock?

136 DR. LEE:

Could be.

137 MR. GOLDBERG:

Okay. And that transfer could be hair and trace?

138 DR. LEE:

Also could be biological material.

139 MR. GOLDBERG:

If the socks are wet at the time they are collected?

140 DR. LEE:

If the socks are wet, if have some body tissues or body material can cause a transfer.

141 MR. GOLDBERG:

Are you going to expect a transfer, in your experience, at that time if the socks are dry?

142 DR. LEE:

If have dry skin, tissue, those you don't need any wet material. If it is bloodstain, sometime this touch can have a trace transfer. If it is wet, you definitely going to expect transfer.

143 MR. GOLDBERG:

Is packaging the socks together the way that I just described going to change the DNA type on the socks that was deposited there?

144 DR. LEE:

I cannot say specifically will relate to this case, but if a case, for example, a simple example, let's say ABO typing, the victim is type A, the decedent is type B. If have a transfer, our reading going to be type AB, a mixture. What AB means could be an AB type. There are people AB type. There could be a mixture of a and B. In other words, the interpretation gets so complicated now. Sometime possible to resolve; other times just impossible. You just call it could be a mixture.

145 MR. GOLDBERG:

All right. Let me make the hypothetical a little bit more specific then. Let's say that in our hypothetical we have a 15-probe RFLP match--

146 DR. LEE:

Uh-huh.

147 MR. GOLDBERG:

--on one of the stains on our hypothetical socks that were packaged together at the time they were collected.

148 DR. LEE:

Yes, right.

149 MR. GOLDBERG:

Does packaging at the time that they were collected change the DNA type?

150 DR. LEE:

In theory shouldn't; however, if let's say hypothetical because a lot of impossible, let's say just happen, I have to look at the band, I have a homozygote or heterozygote--let's call the band a heterozygote, two bands instead of one, it is remote, almost remote, but do have a possibility two individual, each one have one band mixed together become two bands.

151 MR. GOLDBERG:

Okay. Now, if we know the contributors to the biological evidence on that sock and let's say we know there is more than one donor--

152 DR. LEE:

Uh-huh.

153 MR. GOLDBERG:

--to the blood on the two socks--

154 DR. LEE:

Uh-huh.

155 MR. GOLDBERG:

--then we can eliminate some of those mixture problems; is that correct?

156 DR. LEE:

If we have a complete profile maybe we can be able to do that.

157 MR. GOLDBERG:

And would you agree that even if the two socks are packaged together, a 15-probe match would be an extremely significant piece of evidence?

158 DR. LEE:

If it is genuine, that is an important piece of evidence.

KEY QUOTE
159 (Discussion held off the record between the Deputy District Attorneys.)
160 MR. GOLDBERG:

Now, Dr. Lee, just very briefly on the issue of collecting clothes and then we will move on to a different topic. Is it your position that in training police officers that where clothes are in a pile, for example, a number of different articles of clothes, they should in fact collect the clothes as a group and package them together in the same package? Is that the way that you train them?

161 DR. LEE:

Yes.

162 MR. GOLDBERG:

Okay. So there is not an absolute that you always have to package the clothing separately?

163 DR. LEE:

If they are separate, you should package separate. If you have clothing on top of each other, or mingled together, for example, certain people take off their pants, the underpant come with it altogether, you don't have to separate them in the crime scene, you should collect as one group.

164 MR. GOLDBERG:

And would you agree that with respect to the sock photos that you have seen in this case, in your analysis of the sock, we could never exclude the possibility that the sock came into contact with one another prior to being collected anyway?

165 DR. LEE:

I only can testify what I see. I saw the picture, there is two socks separate.

166 MR. GOLDBERG:

Right.

167 DR. LEE:

Clearly. Before that, I don't know.

168 MR. GOLDBERG:

Thank you. Now, the--getting back just to our chart, do you have another chart that you sometimes use in explaining the concept of crime scene investigation called your four-way transfer theory that is contained in the--excuse me. I think it is four-way linkage. I got it wrong. That has become an international well-known four-way linkage theory?

169 DR. LEE:

That is one of my theory, yes.

170 MR. GOLDBERG:

Okay. Can we mark as People's next in order, it will be 591, your Honor.

171 THE COURT:

All right. You have given a copy of this item to Mr. Scheck?

172 MR. GOLDBERG:

Umm, I don't know if we gave him a copy or whether we just showed it this morning.

173 (Peo's 591 for id = document)
174 THE COURT:

All right.

175 MR. GOLDBERG:

But it is also--

176 (Discussion held off the record between the Deputy District Attorneys.)
177 MR. GOLDBERG:

Your Honor, I'm just going to give Mr. Scheck a copy of the--I'm not going to give it to him, I'm going to let him borrow the page in the book.

178 MR. SCHECK:

That is okay.

179 THE COURT:

All right. Proceed. This is a slide you had made up?

180 MR. GOLDBERG:

Yes.

181 (Brief pause.)
182 MR. GOLDBERG:

And Dr. Lee, is this exhibit that we have just marked as "Henry Lee's four-way linkage theory," a--

183 DR. LEE:

I wish only one Henry Lee. There are too many people called Henry Lee. I just found out in L.A. the telephone books a lot of Henry Lee.

184 MR. GOLDBERG:

Okay. Is this a summary of your concept of four-way linkage?

185 DR. LEE:

Yes, sir.

186 MR. GOLDBERG:

And is it true that this is the goal of crime scene processing?

187 DR. LEE:

Yes.

188 MR. GOLDBERG:

So if we are--if a criminalist goes out to a crime scene, what he is trying to accomplish is the idea of--I'm sorry--what he or she is trying to accomplish is the idea of four-way linkage?

189 DR. LEE:

Yes.

190 MR. GOLDBERG:

Can you please explain this to the ladies and gentlemen of the jury.

191 DR. LEE:

With a pointer, your Honor, or if is--

192 MR. GOLDBERG:

I don't know if there is a pointer.

193 THE COURT:

No, we don't have that working right now.

194 DR. LEE:

The crime scene--

195 MR. GOLDBERG:

I think that we can use the telestrator.

196 DR. LEE:

Just the pointer is fine.

197 MR. GOLDBERG:

Okay.

198 DR. LEE:

Any investigation involve four important elements. One is the scene, the crime scene itself has to be in fact preserved. Anytime have a crime, have a victim, so victim itself become a crime scene. For example, a hit and run case, a pedestrian got hit, the pedestrian's body become a crime scene. A rape case, same thing. The rape victim become a crime scene. Of course the suspect who person or persons commit the crime become a crime scene itself. And physical evidence such as guns, shoeprint, hair, sometime earring can become a piece of physical evidence, tire track. All those four area as a good investigator, good criminalist, we have to have a concept of this back in our mind. When you walk through the crime scene you should understand this nature. To link you need the four-way linkage. You can link the suspect to the scene if you find certain crucial physical evidence. Also you can link the physical evidence back to the suspect or suspects. Also you can link the physical evidence to the victim. So this four-way linkage is rather important by using same analogy to case, let's say, a hit and run case. On that street we have a scene. At the scene you can find blood, you can find tire track, you can find glass, metal, soil. The victim's body take to the hospital. On his chest maybe we find tire track. On his clothing we may find imprint pattern. Maybe have glass fragment. The vehicle itself become a physical evidence which--such as a broken lens, lost--of course ideally lost an muffler, we can pick up the muffler, and it physically fit, you can have a link. And the suspect, of course if the suspect after hit and run stopped, step in the blood, now we have a footprint. We can link the suspect. So this so-called four-way linkage you have to always consider all the possibilities.

199 MR. GOLDBERG:

Doctor, can we perhaps use a simpler analogy or fact pattern. Let's say that we have a crime scene.

200 DR. LEE:

Yes.

201 MR. GOLDBERG:

Let's say it is a robbery.

202 DR. LEE:

Yes.

203 MR. GOLDBERG:

Just so we are understanding the concept. And there is an article of clothing at the scene that has a hair that is consistent with the suspect that he dropped at the crime scene.

204 DR. LEE:

Yes.

205 MR. SCHECK:

Your Honor, I think at this point it is foundational, 352.

206 THE COURT:

Overruled.

207 MR. GOLDBERG:

And on that same article of clothing there is also a hair that is consistent with the victim.

208 DR. LEE:

Yes.

209 MR. GOLDBERG:

Can you explain how that would work with your four-way linkage theory?

210 DR. LEE:

Let's say piece of garment which we do have cases, for example, robbery or burglary, getting too hot, they take off their jacket, somehow left in a hurry leaving the scene. We found hairs. That hair can link to a victim. That hair also can link to a suspect. This hair also can link to a crime scene.

211 MR. GOLDBERG:

And if the suspect and victim hair is found on the same item, it also links the victim to the suspect?

212 DR. LEE:

Yes. Link depend on the condition of the hair, depends on whether or not this hair so-called secondary transfer.

213 MR. GOLDBERG:

And it would also, if the clothing is found at the crime scene, link the physical evidence up to the scene?

214 DR. LEE:

Yes, sir.

215 MR. GOLDBERG:

All right. And is it true, Dr. Lee--I think we are finished with that. Is it true, Dr. Lee, that the hallmark of a crime scene identification is whether or not we were successful in establishing four-way linkage?

216 DR. LEE:

Yes.

217 MR. GOLDBERG:

Now, would you agree that it is very often that very experienced capable criminalists or crime scene technicians or police will go out to a crime scene and very carefully systematically process the crime scene, but they can't establish four-way linkage?

218 DR. LEE:

Yes. Do have cases, either failure of recognition or failure of any of those steps, and sometime maybe just not exist.

219 MR. GOLDBERG:

And is it also true that sometimes a less careful processing of the crime scene, less capable processing of the crime scene can, nevertheless, result in four-way linkage?

220 DR. LEE:

Yes, sir.

221 MR. GOLDBERG:

Now, let's get to the issue, Dr. Lee, of the Bronco that you testified to a little bit in your direct testimony. Now, did you ever physically inspect the Bronco yourself?

222 DR. LEE:

No. As I indicate to the jury, I never physically personally look at the Bronco.

223 MR. GOLDBERG:

And were you present--excuse me. Did you know that there was a search of the Bronco that was done on August 26th of 1994?

224 DR. LEE:

I don't remember specific date.

225 MR. GOLDBERG:

Okay. Were you generally aware of some search of the Bronco that was done in August of `94 at which some Defense people and some--

226 DR. LEE:

Yes.

227 MR. GOLDBERG:

--Prosecution people were present?

228 DR. LEE:

Yes.

229 MR. GOLDBERG:

And did someone disallow you from coming there?

230 DR. LEE:

Not exactly the situation disallow me. I only can work on my spare time on weekends.

231 MR. GOLDBERG:

Okay.

232 DR. LEE:

I cannot come here--I have an official duty also. The world cannot stop just because this case.

233 MR. GOLDBERG:

Okay. So with respect to your analysis in this case, is it true that part of the limitation was your own busy schedule?

234 DR. LEE:

Yes, because the day I wanted was not available to me, and the day they wanted I cannot come here.

235 MR. GOLDBERG:

Okay. Now, with respect to the amount of blood that we are going to expect to find in an item such as the Bronco, do you agree with the idea that we can only interpret the bloodstains that are physically present and that no one should speculate as to why a Defendant was not blood stained except in the most unusual cases?

236 DR. LEE:

Yes, in general.

237 MR. GOLDBERG:

Okay. And do you agree, sir, that in the forensic scientific literature that there is a lot of literature that indicates: "Numerous references state assailant is not always blood stained as a result of their active participation in the blood letting events."

238 DR. LEE:

That again in general depends on type of crime and what condition of the crime, what type of physical force involved.

239 MR. GOLDBERG:

Do you also agree that forensic scientists have to interpret what they see as opposed to what they don't see?

240 DR. LEE:

I disagree that. Absence of evidence not necessarily wasn't there. Absence of evidence may be wasn't there; maybe somebody just not experienced enough or incapable or inability to see that.

KEY QUOTE
241 MR. GOLDBERG:

Okay. All right. Have you read Mr. MacDonnell's article on the "Absence of evidence is not evidence of absence"?

242 (No audible response.)
243 MR. GOLDBERG:

"Absence of evidence is not evidence of absence"?

244 DR. LEE:

I'm a Chinese. Take me a while to think about this double-talk. Absence--

KEY QUOTE
245 MR. GOLDBERG:

Let me see if I can get that for you and--

246 (Discussion held off the record between the Deputy District Attorneys.)
247 MR. GOLDBERG:

Okay. I put some lines on my copy. May I approach the witness?

248 THE COURT:

Can you show Mr. Scheck?

249 (Discussion held off the record between Deputy District Attorney and Defense counsel.)
250 MR. GOLDBERG:

May I approach?

251 THE COURT:

Yes.

252 MR. SCHECK:

May I?

253 MR. GOLDBERG:

Dr. Lee, why don't you just take a quick look at that and see if that refreshes your recollection if you have read that article?

254 DR. LEE:

I have read a lot of article. Which part do you want me to read?

255 MR. GOLDBERG:

You don't have to read it. I just want to see if looking at it silently to yourself if you recognize it?

256 DR. LEE:

Okay. (Witness complies.)

257 THE COURT:

All right. Dr. Lee, do you recognize the article?

258 DR. LEE:

Sort of. I don't remember every line.

259 MR. GOLDBERG:

I know, there is an enormous amount of forensic science literature out there, isn't there?

260 DR. LEE:

Yes.

261 MR. GOLDBERG:

And do you agree generally with the findings of MacDonnell in this particular article?

262 DR. LEE:

In general, yes, but the specific example he give maybe not totally cover the whole situation.

263 MR. GOLDBERG:

Okay. But in general do you agree with the proposition that we really can't infer that someone cannot participate in a crime involving a bloody event simply because they don't have blood on them, on their clothing or on their person?

264 DR. LEE:

Again, as I indicate before, depend on situation. One example said beat up a rabbit. Rabbit, human two different scene. You beat up a rabbit, did not get blood spatter on your clothing. Doesn't mean you beat up a human did not get blood on your body, and I guess depends on situation. If you standing a distance, firing a shot, gunshot, thirty feet away, kill somebody, I don't expect to find blood spatter on somebody's clothing. That is correct. However, if you put the gun next to somebody's head, fire a shot, nothing, no clothing, block the back spatter, I expect to find some blood spatter, so it varies. I cannot in certain senses, correct. In other situation maybe not.

265 MR. GOLDBERG:

Okay. Isn't there a lot of forensic science literature out there that generally cautions the forensic scientists who are involved in blood spatter that you can't really say that someone didn't participate in a crime just because they are not covered in blood even if it is something like a stabbing?

266 DR. LEE:

Yes, sir.

267 MR. GOLDBERG:

All right.

268 (Discussion held off the record between the Deputy District Attorneys.)
269 MR. GOLDBERG:

Your Honor, perhaps I can mark the article as People's next in order. I guess that would be 592.

270 THE COURT:

All right. People's 592.

271 (Peo's 592 for id = article)
272 MR. GOLDBERG:

I will put a 592 on it.

273 (Brief pause.)
274 MR. GOLDBERG:

Sir, do you agree with the concept that we can only interpret the bloodstains that are physically present and that no one should speculate as to why a Defendant was not blood stained except in the most unusual cases?

275 MR. SCHECK:

Objection. Is he reading from something, your Honor?

276 MR. GOLDBERG:

These are my notes.

277 THE COURT:

Overruled.

278 DR. LEE:

Again, generally we only can interpret a certain pattern which we can see. If you did not see it, not necessary wasn't there. You cannot interpret something you did not see. Then you say not there.

279 MR. GOLDBERG:

What I want to know, doctor, is do you agree with that particular quote that I just read?

280 DR. LEE:

In general.

281 MR. GOLDBERG:

Okay. Now, have you been involved--let me ask a couple other questions first. Is it true generally that stabbings, generally speaking, involve less blood than beatings?

282 DR. LEE:

No. Stabbing depends where you stab. You can have a lot of blood. Beating depends where you beat. If you beat somebody's rear end, when I was young my mother used to discipline me, I don't see blood spatter, so all different.

283 MR. GOLDBERG:

Well, I'm talking about beating deaths.

284 DR. LEE:

Beating death?

285 MR. GOLDBERG:

Where someone was--

286 DR. LEE:

Beat the head, beat the body, it is all different.

287 MR. GOLDBERG:

Let's say that we have a situation where someone has beaten another person to death in the head with a brick.

288 THE COURT:

This is not particularly relevant, counsel.

289 MR. GOLDBERG:

Well, it goes to the Bronco and a number of other items that the Defense got into.

290 THE COURT:

The cause of death here is clear.

291 MR. GOLDBERG:

Well, I'll just--

292 THE COURT:

Let's proceed.

293 (Discussion held off the record between the Deputy District Attorneys.)
294 MR. GOLDBERG:

All right. Now, sir, have you had some cases yourself in your own career as a forensic scientist where the crime scene was extremely bloody?

295 DR. LEE:

Yes, sir.

296 MR. GOLDBERG:

Yet--yet the suspect did not have a lot of blood on his clothing?

297 DR. LEE:

Off my head I don't really remember every crime scene I went. In general more blood, I should expect to find some blood on the suspect. Again, depends on situation. You have a shooting at a distance, yes, the victim lying there, have a lot of blood. Suspect with a long gun, you don't expect to find that. Those are correct. If a closed compact situation, maybe different.

298 MR. GOLDBERG:

Okay. Now, with respect to the Rockingham location, Dr. Lee, you saw some spots in the foyer; is that correct, of blood?

299 DR. LEE:

Yes.

300 MR. GOLDBERG:

And can you determine the difference, as a forensic scientist, between a one-centimeter cut and a two-centimeter cut based upon those six spots?

301 DR. LEE:

If the cut into a blood vessel, maybe; if not, I cannot tell you.

302 MR. GOLDBERG:

So if we are dealing with a cut that did not go into a blood vessel, then we cannot say from the number of dots that you had how big the cut was?

303 DR. LEE:

No, just can say a small cut.

304 MR. GOLDBERG:

All right. Now, in addition to that, doctor, when you were at the Rockingham location did you have occasion to find any item that in your forensic opinion was consistent or appeared to be blood in the area of air conditioning near Kato Kaelin's house?

305 DR. LEE:

Yes, sir.

306 MR. GOLDBERG:

And was that something that you believed that--that you thought appeared to be blood?

307 DR. LEE:

I test some doorknobs, some sink traps and air conditioner.

308 MR. GOLDBERG:

I'm just asking about the air conditioner.

309 DR. LEE:

I saw in different places.

310 MR. GOLDBERG:

That is all right, your Honor. I will move on. I think he has answered the question.

311 MR. GOLDBERG:

Now, sir, with respect to the Bundy crime scene location, I would like to ask you a little bit about what you did in terms of the reconstruction at that location.

312 DR. LEE:

Yes.

313 MR. GOLDBERG:

And I would like to mark--

314 MR. GOLDBERG:

Well, first of all, let me ask you, were your opinions that you offered regarding the Bundy location based upon what you saw in the photographs or did you also take into consideration the testimony of pathologists in this case?

315 DR. LEE:

What my observation regards to imprint is my direct observation on June 25th on the tile. Also look at some physical evidence. Regards to this closed-in area, basically looking at photograph, the distribution of the pattern, the location of scene. Regard to some other information, they did relate to me some number of cut or stab or injury.

316 MR. GOLDBERG:

Okay. Let me just make sure we are clear. So is it your position that as a forensic scientist looking at the Bundy location you have to set aside what the pathologists say and just concentrate on what you see?

317 DR. LEE:

And the majority part. Of course I considered a number of injury. Not only one thing I look at. I did not look at stomach contents, lividity or postmortem change.

318 MR. GOLDBERG:

Okay. So in other words, things that you can see yourself in pictures?

319 DR. LEE:

Right, right.

320 MR. GOLDBERG:

Now, I would like to mark as People's next in order an exhibit that is going to be 593 and it is a board of the Bundy location concentrating on what we've referred to in this case as the caged area and some photographs. Your Honor, one of the photographs is perhaps one that should not be suited for display. All right.

321 (Peo's 593 for id = posterboard)
322 THE COURT:

Mr. Bancroft acknowledges that.

323 (Brief pause.)
324 THE COURT:

All right. Why don't you set the easel up here.

325 (Brief pause.)
326 THE COURT:

All right. Mr. Bancroft, stay off the bottom row.

327 MR. BANCROFT:

Yes, your Honor.

328 (Brief pause.)
329 MR. GOLDBERG:

Dr. Lee, directing your attention to the exhibit that we've marked as People's 593 for identification, can you see that?

330 DR. LEE:

May I step down, your Honor?

331 THE COURT:

Yes, you may, Dr. Lee?

332 DR. LEE:

(Witness complies.) Yes, I can see those in general.

333 MR. GOLDBERG:

And, doctor, do those appear to be the same exact photographs that were used on a Defense exhibit that you were using to explain to the jury some of the blood pattern or blood reconstruction analysis in the case?

334 (No audible response.)
335 MR. GOLDBERG:

The nine photographs you used?

336 DR. LEE:

Some appear to be the same; some maybe there are differences.

337 MR. GOLDBERG:

Are there any--which are the ones that you think are different?

338 DR. LEE:

The picture I use, for example, this key, I did see some reddish stain; however, this picture, one look at now, I don't see any reddish stain.

339 MR. GOLDBERG:

Because we are getting a different view of the key?

340 DR. LEE:

I have no idea.

341 MR. GOLDBERG:

Okay.

342 DR. LEE:

And this boots, (Indicating), the picture provide to me have more like a bloodstain, compared to this, yes, I do see bloodstain, soil material, trace, but much less. And this one, (Indicating), is a much closer--it is a closer shot, but in general this is the same. And some of those--this, (Indicating), must be a so-called first generation, better picture than what I get is a printout of a print. I would say in general it depicts the scene. I wasn't there. I wasn't the one took those pictures, so I can't really come here misled you, say that is exactly what I see at the crime scene.

343 MR. GOLDBERG:

Okay. For the record, the ones that Dr. Lee indicated could be somewhat different than the photos that he saw are on the right-hand side of this exhibit in what would be the extreme right portion as you are facing the exhibit; the bottom photograph depicting Ronald Goldman's boots and the photograph above that depicting the keys and the photograph above that appears to be a close-up of the card that has item no. 108 in it.

344 MR. GOLDBERG:

Is that correct, doctor?

345 DR. LEE:

Yes.

346 MR. GOLDBERG:

All right. Now--but other than that, we've depicted all of the areas that were the subject of your testimony in terms of the reconstruction of what happened at the Bundy location; is that correct?

347 DR. LEE:

Yes, sir.

348 MR. GOLDBERG:

All right. Now, Dr. Lee, could you use some red tape, if you have any, to show us where these items are on the diagram. I think I have some red tape here.

349 DR. LEE:

I have some. You don't have a pole here. Basically it is around here, (Indicating). I don't have a diagram of body, so I really cannot tell you.

350 MR. GOLDBERG:

Okay. Just give us the--

351 DR. LEE:

General location, all right.

352 MR. GOLDBERG:

What are you pointing from? From what to what?

353 DR. LEE:

The pole should be like this area, landmark, (Indicating).

354 MR. GOLDBERG:

The--you have put some tape from the sapling?

355 DR. LEE:

Right.

356 MR. GOLDBERG:

Over to the general location.

357 DR. LEE:

I cannot tell you the specific location. This diagram has no what you call, sapling?

358 MR. GOLDBERG:

Sapling, a small tree. Here, let me ask you this--

359 DR. LEE:

Is this a tree? It look like a 2-by-4 to me. In front have a pole.

360 MR. GOLDBERG:

Take a close look. Does that look like a tree that is attached to a stake for support?

361 DR. LEE:

Yeah.

362 MR. GOLDBERG:

All right. Now, maybe we could just indicate--you could indicate for us this from the gate, the stain.

363 (Witness complies.)
364 MR. GOLDBERG:

Okay. You are connecting to--let's not cover it up. Let's go like this. Would that be okay?

365 DR. LEE:

Sure.

366 MR. GOLDBERG:

So you have connected two photographs; is that correct?

367 DR. LEE:

Right.

368 MR. GOLDBERG:

And those are the photographs in the upper right-hand corner of the exhibit. Can you connect this gate that has the photo card 108 in it to where the gate would be, approximately?

369 DR. LEE:

Okay.

370 MR. GOLDBERG:

At the crime scene?

371 DR. LEE:

If you draw the picture, diagram with the number of pole, I will tell you exactly. I only go tell that is no. 8 (Sic) here in the picture. I would say approximately in this location, (Indicating).

372 MR. GOLDBERG:

Is that a little close to the corner?

373 DR. LEE:

You have one--one, two, three, four, five, six--six.

374 MR. GOLDBERG:

Six bars?

375 DR. LEE:

You have eight bar. When you look at this picture, when you look at this picture, give you a round projection. That is called depth of the view. When we take a picture, the closer place looks like bigger. The distance one like a distance shorter. Can you see the gap here? Much bigger, (Indicating). In real sense all those gaps should be identical.

376 MR. GOLDBERG:

And with respect to the photo of the keys, can you connect that up to the general location?

377 DR. LEE:

Yes, sir. Again just a general location. I don't have a plane here shows me exactly the scene. I would say around here, (Indicating).

378 MR. GOLDBERG:

So that is somewhere--understanding this is an approximation of the area of where Mr. Goldman's feet would be?

379 DR. LEE:

Very general. Very general.

380 MR. GOLDBERG:

Well, I don't know if we should connect up the shoe--let me think. I don't know if we should.

381 DR. LEE:

Because after--

382 MR. GOLDBERG:

Let's not connect that, but can we connect the photograph that has photo card 119 in it?

383 DR. LEE:

Again I have to make some assumption this is here again, (Indicating), because the picture--the diagram did not show me. I would say in this general location, (Indicating).

384 MR. GOLDBERG:

So that is kind of like the post that you would expect the gate to swing opened and closed on?

385 DR. LEE:

Right.

386 MR. GOLDBERG:

Now, directing your attention, now we are going to move over to the left-hand side of this exhibit.

387 DR. LEE:

Uh-huh.

388 MR. GOLDBERG:

Why don't you just describe this for us orally and then we will connect it. The gate portion--excuse me. Gate is the wrong word. The fence portion at the bottom?

389 DR. LEE:

Yes.

390 MR. GOLDBERG:

Where is that?

391 DR. LEE:

This looks like somebody took a picture from other side, (Indicating), other side of the fence look into the fence. For example, let's say jury box here is the fence, I'm taking a picture from here, not inside of jury box, so has to be other side.

392 MR. GOLDBERG:

Okay. Now, Dr. Lee, would it appear to you then that the photo card bearing 109 is the same stain that is contained in the lower photo only it is the--this is from the inside view?

393 DR. LEE:

Definitely different. It is same location but here shows different stain, (Indicating).

394 MR. GOLDBERG:

You mean this stain in the bottom photograph is not the same as this--

395 DR. LEE:

This one, (Indicating), is this, (Indicating). This dripping, not showing in this photo.

396 MR. GOLDBERG:

Because we are showing--

397 DR. LEE:

Here have more spatterings along the column that is not showing in this photograph, (Indicating).

398 MR. GOLDBERG:

Okay. But would it be fair to say that at least the 109 stain is showing the stain with the photo card 109 is showing in the lower photograph?

399 DR. LEE:

Barely, partially.

400 MR. GOLDBERG:

And from the other side?

401 DR. LEE:

From the other side.

402 MR. GOLDBERG:

Would it be fair then for us to link these two photographs up?

403 DR. LEE:

I will try, unless we put the tape other side.

404 MR. GOLDBERG:

Let's try to block as little of the picture as we can.

405 DR. LEE:

Right, right.

406 MR. GOLDBERG:

Do you want me to put this over here, (Indicating)?

407 (Witness complies.)
408 MR. GOLDBERG:

Can we just trim this a little bit so it is not blocking too much of the stain.

409 DR. LEE:

Actually we should--if for real we have to go other side.

410 MR. GOLDBERG:

Right.

411 DR. LEE:

Not this side, (Indicating).

412 MR. GOLDBERG:

And can you tell us where this--the photograph that we are seeing now also has a stain on the lower portion of the rail. Is that stain the same as the 109 stain?

413 DR. LEE:

Yes, sir.

414 MR. GOLDBERG:

Okay. Can we connect those--well, I don't want to block too much of the--without blocking the picture, can we connect those two stains?

415 (Witness complies.)
416 MR. GOLDBERG:

So the view that we have with the 109 card in it is simply a closer up view of the view that we have with the 101 card that shows the beeper well; is that correct?

417 DR. LEE:

Yes, sir.

418 MR. GOLDBERG:

Okay. And then the view above that also shows the beeper, so can we connect the two beeper photos.

419 (Witness complies.)
420 MR. GOLDBERG:

Let's not block that. Let's cut this a little bit.

421 (Witness complies.)
422 MR. GOLDBERG:

Now, can you locate for us, using our diagram, the approximate location of the beeper?

423 DR. LEE:

Okay. Now, we know that is pole no. 6; however, again I don't know--no indication of a sort of a measurement. All I can say, it is a round here, general location, (Indicating).

424 MR. GOLDBERG:

Could this beeper be in the approximate location--if Ronald Goldman's head was up against a tree stump that is depicted in the photo that has the 101 card in it, could the beeper be a little bit further to the Bundy--the Bundy side of the street?

425 DR. LEE:

Just stretch it a little bit.

426 MR. GOLDBERG:

Should we add a little bit--do you want to add a little bit more tape on that?

427 DR. LEE:

This is typical example of a two-dimensional background. We try to visualize a three-dimensional setting, it is almost impossible, but in general probably this location, (Indicating). If this diagram give me number of pole, I can tell you exactly.

428 MR. GOLDBERG:

But at least we are getting a general location?

429 DR. LEE:

Right, right.

430 MR. GOLDBERG:

Is there anything else that you feel should be connected up on this--hold on for a second. Let me just give you a photograph first, Dr. Lee. I think it has been marked as People's--I want to show him People's 56-D, but this is a photograph that also should not go out over the elmo. We are going to show you a photograph.

431 MR. SCHECK:

Can I see that first?

432 (Brief pause.)
433 MR. GOLDBERG:

Dr. Lee, I just want you to take a look at this photograph for a moment and try to get yourself oriented a little bit.

434 (Witness complies.)
435 MR. GOLDBERG:

Particularly on the beeper.

436 DR. LEE:

This beeper shows under almost no. 3 pole and here you may less in between here no poles, then you have too big a gap, looks like no. 4 pole.

437 MR. GOLDBERG:

Dr. Lee, if you take a closer look at this, does it appear that what we've been referring to as the sapling in photograph that bears the 101 card, that is more of a perspective shot that the sapling and the stake are blocking one of our poles?

438 DR. LEE:

Yes.

439 MR. GOLDBERG:

All right. So would the beeper be a little bit further back towards Ron Goldman's buttocks?

440 DR. LEE:

That is two-dimensional. Looks like this picture could be even little further here, (Indicating). It is kind of difficult now. If I go that far, here impossible to have three poles in that little corner area. Something wrong with this area, something wrong with perspective of this picture. You can eat the pie both ways.

441 MR. GOLDBERG:

Is it correct to say that when we are interpreting photographs we have some problems with perspective and distortions that occur?

442 DR. LEE:

Exactly.

443 MR. GOLDBERG:

As a result of the photography?

444 DR. LEE:

Yes.

445 MR. GOLDBERG:

All right. So is there an area where you would be more comfortable with placing this red dot--this red tape than where you have it now?

446 DR. LEE:

If I know exactly how many pole, if you give me a number, I can evenly divide it up and count the number of pole, tell you exactly the location.

447 MR. GOLDBERG:

Would it be safe to say that the beeper appears to be far east or at least east of Ronald Goldman's shoulder?

448 DR. LEE:

That doesn't make too much difference.

449 MR. GOLDBERG:

So Dr. Lee, would it be fair to say that with respect to all of the bloodstains that we referred to or that you referred to on the board that you were shown by the Defense, when you were discussing Bundy, that all of them happened in an area that is west of the--the portion of the fence that is parallel to Bundy, they are west of there?

450 DR. LEE:

Yes.

451 MR. GOLDBERG:

And all of them are south of the fence that is parallel to the neighbor's yard?

452 DR. LEE:

With this particular set of picture, I don't have an overall shows this part, (Indicating). I did see another picture relate to really, so in other words, there are other patterns which are inability for me to see it. I only can testify on the picture I saw.

453 MR. GOLDBERG:

All right. As to the pictures that you saw, all of the bloodstains are to the east of--

454 DR. LEE:

West.

455 MR. GOLDBERG:

Of--

456 DR. LEE:

West. That is the west direction.

457 MR. GOLDBERG:

Okay. Well, I want to ask you about toward the east.

458 DR. LEE:

Toward the east.

459 MR. GOLDBERG:

Okay. All of the bloodstains are to the east of the area where the stump is located?

460 DR. LEE:

No. The stump is located here, (Indicating). Clearly it is the west side of the stump.

461 MR. GOLDBERG:

When I was saying "Stump" I was referring to what appears to be--

462 DR. LEE:

Oh, okay. A good portion is to the east. There are some, for example, this three--those little spatter drops, it appear to be to the west of the stump.

463 MR. GOLDBERG:

So would it be fair to say, doctor, that with respect to the photographs that you discussed on direct examination--

464 DR. LEE:

Uh-huh.

465 MR. GOLDBERG:

--that these photographs and the location of the blood spatters indicate that the murder occurred in an area with respect to Ron Goldman about the size of a very small walk-in closet?

466 DR. LEE:

Like my house.

467 MR. GOLDBERG:

Maybe like my house.

468 DR. LEE:

I don't know a definition of a small walk-in closet. I do know this area is 68 inches total. If we divided it by the pole, then we can get the number.

469 MR. GOLDBERG:

Your Honor, could I just--

470 (Discussion held off the record between the Deputy District Attorneys.)
471 MR. GOLDBERG:

Could I have a few more minutes or did you want to break for lunch now?

472 THE COURT:

Do you have just a few more minutes?

473 MR. GOLDBERG:

Yeah. I just wanted to tie up this last--I just wanted to--

474 THE COURT:

All right. Let's finish the exhibit.

475 (Discussion held off the record between the Deputy District Attorneys.)
476 MR. GOLDBERG:

Doctor, using the scale on the bottom of this exhibit, can we just get a measurement--let's see if we can do this--as to the approximate area that would contain all of the bloodstains that we have here?

477 MR. SCHECK:

Your Honor, I think I have an objection to this on foundational grounds.

478 THE COURT:

Sustained.

479 MR. GOLDBERG:

As to what?

480 THE COURT:

Foundation, scale.

481 MR. GOLDBERG:

Well, I have to be heard on that, your Honor, so perhaps we need to break for the--

482 THE COURT:

All right. All right. Ladies and gentlemen, we are going to take our recess for the morning session. Please remember all my admonitions to you. Don't discuss the case among yourselves, form any opinions about the case, conduct any deliberations until the matter has been submitted to you, or allow anybody to communicate with you with regard to the case. We will stand in recess until 1:15. All right. Dr. Lee, you can step down.

483 (Appearances as heretofore noted.)

Temperature

tense

Key Quotes (5)

Dr. Henry Lee
If it is genuine, that is an important piece of evidence.
Lee agrees a 15-probe RFLP match would be extremely significant—but his qualifier 'if it is genuine' encapsulates the entire defense theory that the evidence was planted.
Dr. Henry Lee
I'm a Chinese. Take me a while to think about this double-talk. Absence--
Lee's disarming self-deprecating humor defused a pointed question about the MacDonnell article on 'absence of evidence is not evidence of absence,' while still allowing him to eventually agree with the prosecution's point.
Dr. Henry Lee
I probably tell don't dab, just give me your shoes and don't do it next time.
Lee's wry answer to Goldberg's hypothetical about a cop stepping in blood confirmed that even badly collected evidence can still be tested—a key prosecution concession.
Dr. Henry Lee
No, you cannot change my title.
Lee firmly rejected Goldberg's attempt to relabel his forensic chart 'garbage in, garbage out,' only to then volunteer that he actually does use that phrase in lectures—a moment of candor that cut both ways.
Dr. Henry Lee
Absence of evidence not necessarily wasn't there. Absence of evidence may be wasn't there; maybe somebody just not experienced enough or incapable or inability to see that.
Lee resisted the prosecution's framing that forensic scientists should only interpret what they see, preserving the defense argument that missing blood evidence could reflect investigator failure rather than innocence.

Evidence (7)

Defense 1350
Defense chart depicting basic steps in forensic examination (recognition, preservation, documentation, collection, identification, comparison, individualization, reconstruction)
discussed; Goldberg used it to extract concessions that evidence value survives collection errors at earlier steps
People's 591
Document summarizing Dr. Henry Lee's 'four-way linkage theory' (linking scene, victim, suspect, and physical evidence)
introduced; Lee explained the theory to the jury and Goldberg used it to argue the physical evidence links Simpson to both crime scenes
People's 592
Herbert MacDonnell article titled 'Absence of Evidence Is Not Evidence of Absence' on blood spatter and assailant bloodstaining
introduced to refresh Lee's recollection; Lee agreed generally with its proposition that suspects are not always blood-stained
People's 593
Posterboard of Bundy crime scene photographs focusing on the caged area, including photos of Goldman's boots, keys, beeper, fence stains, and photo cards 101, 108, 109, 119
introduced; Lee and Goldberg used red tape to connect photographs to approximate crime scene locations on a diagram
People's 56-D
Photograph of the Bundy crime scene used to help orient Dr. Lee to the beeper's location relative to fence poles
shown to witness for orientation; not displayed publicly due to graphic content
Informal
The socks from OJ Simpson's bedroom—two socks packaged together—discussed regarding potential cross-transfer of biological material during collection
discussed
+ 1 more

Notable Exchanges (4)

Hank GoldbergDr. Henry Lee
Goldberg's extended 'bumbling police officer' hypothetical series—officer steps in blood, touches swatches with bare hands, doesn't photograph the scene—designed to get Lee to agree that flawed collection still yields testable evidence. Lee conceded each point while consistently noting the evidence would be on 'shaky ground' for reconstruction.
strategic
Hank GoldbergDr. Henry Lee
Goldberg asked whether a 15-probe RFLP match on the socks would be 'an extremely significant piece of evidence' even if socks were packaged together. Lee agreed—but only with the qualifier 'if it is genuine,' pointedly preserving the defense's planting theory.
revealing
Hank GoldbergDr. Henry Lee
Goldberg turned Lee's own four-way linkage theory against the defense, walking through how physical evidence found at Bundy and Rockingham links suspect, victim, scene, and evidence together—essentially using the defense expert to articulate the prosecution's theory.
strategic
Hank GoldbergDr. Henry Lee
Extended red-tape exercise connecting crime scene photographs to a diagram of the Bundy location. Lee repeatedly noted the diagram lacked measurements and pole numbers, limiting precision, but provided general location estimates for the beeper, keys, and gate stains.
procedural

Light Moments (5)

Dr. Henry Lee
When Goldberg referenced 'Henry Lee's four-way linkage theory,' Lee quipped: 'I wish only one Henry Lee. There are too many people called Henry Lee. I just found out in L.A. the telephone books a lot of Henry Lee.'
Dr. Henry Lee
On the 'absence of evidence is not evidence of absence' question: 'I'm a Chinese. Take me a while to think about this double-talk.'
Dr. Henry Lee
When Goldberg asked if juror box hairs could include his own, Lee replied: 'If you give me time I will found a lot of hairs and fibers, maybe nothing to do with the jury panel... Maybe I can find your hair there, too.'
Dr. Henry Lee
Looking at the crime scene diagram, Lee said of what Goldberg called a sapling: 'Is this a tree? It look like a 2-by-4 to me.'
Dr. Henry Lee
Explaining a non-bloody crime scenario, Lee noted: 'If you beat somebody's rear end, when I was young my mother used to discipline me, I don't see blood spatter.'

Credibility Attacks (2)

⚔ Dr. Henry Lee
turning witness's own theories and published statements against him
Goldberg repeatedly used Lee's own forensic framework (four-way linkage, 'garbage in garbage out' lecture phrase, published statements on trace analysis certainty) to extract concessions favorable to the prosecution, effectively making the defense's star expert a partial prosecution witness
⚔ Defense forensic methodology
hypothetical reframing
Goldberg's extended hypotheticals about a clumsy rookie officer were transparently designed to analogize to actual defense criticisms of LAPD collection, getting Lee to agree that the resulting evidence would still be scientifically testable and significant

Witness Demeanor

(Witness complies.) — repeated throughout photograph/diagram exercise as Lee stepped down and applied red tape
(No audible response.) — when first shown the MacDonnell article and when asked to compare Defense and People's photographs
Consistently conversational and unflappable under sustained cross-examination; volunteered information beyond what was asked

Objections

10 objections (0 sustained, 10 overruled)
Proceeding 7447 • 483 utterances • Defense witness
Criminal Trial
Department 103
⚖️ Start
📂 AUG 28, 1995 📄 Cross-examination of Dr. Henry
AUG 28, 1995 KRT DvH TD