📄 Exhibit rules and foundation — Monday, August 28, 1995
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▲ Day 143 of 167

Exhibit rules and foundation

Date: Monday, August 28, 1995 • Utterances: 39
Before bringing the jury back in, Barry Scheck apologized to Judge Ito for making a speaking objection in front of the jury during Dr. Lee's cross-examination. The parties clarified the proper procedure for using learned treatises in cross-examination — Scheck needed time to review materials before they were used, and Ito noted that a simple 'Foundation' objection would have been sustained rather than the speaking objection Scheck made. The discussion also touched on whether Goldberg's use of a drying-time chart from an outside article may have opened the door to additional defense evidence.
1 THE COURT:

All right. Back on the record in the Simpson matter. All parties are again present. The jury is not present. All right. Deputy Magnera, let's have the jurors, please.

2 MR. SCHECK:

Your Honor, please?

3 THE COURT:

Yes, Mr. Scheck. Hold on, Deputy Magnera.

4 MR. SCHECK:

Your Honor, my apologies for making a statement to the court in the presence of the jury about these exhibits. I just want to be clear about the rules. If the witness is going to be questioned about a section from a treatise, it has to be established, as I understood, that he relied upon it, and I thought as well that counsel would be given an opportunity.

5 THE COURT:

Correct.

6 MR. SCHECK:

I just want to make it clear to the court that we had some discussion about what would be used with Dr. Lee and I was handed this paper seconds before the question was asked and that is the only reason I wanted time to see exactly what was being asked of the witness.

7 THE COURT:

You were given--you see, let me tell you what my perspective is, Mr. Scheck, so we understand each other.

8 MR. SCHECK:

Yes.

9 THE COURT:

I did not hear the foundational questions to Dr. Lee that he was about to be cross-examined as to somebody else's opinion in a learned treatise. I didn't hear the questions. I didn't hear anything read from an article, so I assumed that your objections were premature. And that is the way I felt at that time and I think that is the way the testimony unfolded, that is what came out, because he was not cross-examined or impeached as to anything in a learned treatise that he didn't rely upon or agree with.

10 MR. SCHECK:

Well, if I--

11 THE COURT:

I have much more confidence in this witness than apparently the lawyers do.

KEY QUOTE
12 MR. SCHECK:

No, nobody can--I yield to no one in my confidence in this witness. But the point is simply a procedural one because I don't want to be in the position of where I say something in front of the jury that--

13 THE COURT:

But understand the context of my comment.

14 MR. SCHECK:

--if you and I get into a dialect--

15 THE COURT:

This witness is not going to argue with either side about other scientist's opinions.

16 MR. SCHECK:

Your Honor, the point I want to maybe, for the record--

17 THE COURT:

You are entitled to it, and if he is about to be cross-examined, you have the opportunity to read to see what it is.

18 MR. SCHECK:

And he did. And just so that I'm clear on the practice, he was asked about labor and Epstein generally he said excellent people, and then Mr. Goldberg read something from his notes which in fact it was my understanding was either a direct quote or a summary of this and I thought at that point--

19 THE COURT:

It was such an innocuous question, aren't there variables that have to do with how long it takes something to dry? That is a question that doesn't have to come out of a learned treatise and was obviously the focus of where Mr. Goldberg was going. It was not directly from this article. I agree with you, you have got the materials, if he is going to use specific passages to cross-examine before he goes into it.

20 MR. SCHECK:

Just for the record, I will make a copy. What then unfolded is that specific tables were used with different conditions for drying cloth swatches with one drop of blood.

21 THE COURT:

But the objection should been then foundation.

22 MR. SCHECK:

Well, I thought I was trying to make them, but I also--

23 THE COURT:

Mr. Scheck, that was a speaking objection. If you had said "Foundation" you probably would have been sustained.

KEY QUOTE
24 MR. SCHECK:

Well, your Honor, I will get to it. I just want to have any misunderstanding between us--

25 THE COURT:

We have none.

26 MR. SCHECK:

Okay. And I will make an application when this is done, I want you to take a look at it, because I think it opens the door to some other things that had previously been--

27 THE COURT:

It may very well might.

28 MR. SCHECK:

Thank you, your Honor.

29 THE COURT:

That thought crossed my mind when I heard it.

30 MR. COCHRAN:

Ours, too, your Honor.

KEY QUOTE
31 MR. GOLDBERG:

I didn't ask about any experiments. I asked him about the generalized knowledge that he has which is what he testified to on direct. He was testifying from his generalized knowledge.

32 THE COURT:

I understand, but then you went into this chart where somebody else did an experiment about drying times.

33 MR. GOLDBERG:

He was the one that told me about it. I wasn't going to get into that except Dr. Lee wanted to.

34 THE COURT:

Just because they go into it doesn't mean you should cross-examine on that. I thought he left you with a pretty wide parameter, if you set it out to dry at night and you come back the next morning it ought to be dry. I think that left you a wide enough parameter to work with, but you insisted on making it tighter, so I don't know. But I will see what the article says and probably get to read the article over the lunch hour, not that I have other things to occupy my time with.

35 (Discussion held off the record between the Deputy District Attorneys.)
36 THE COURT:

If the Defense insists on pursuing this particular line.

37 MR. SCHECK:

I read you, your Honor, but you should look at it.

38 THE COURT:

But you got the transfers. I mean, what more do you want?

KEY QUOTE
39 MR. SCHECK:

Yes.

Temperature

procedural

Key Quotes (4)

Lance A. Ito
I have much more confidence in this witness than apparently the lawyers do.
Ito signals his high regard for Dr. Lee and implicitly criticizes both sides for underestimating the witness's ability to handle cross-examination without coaching.
Lance A. Ito
Mr. Scheck, that was a speaking objection. If you had said 'Foundation' you probably would have been sustained.
Ito tells Scheck plainly that his objection failed on procedural grounds of his own making — a notable concession that the defense had a valid substantive point.
Lance A. Ito
But you got the transfers. I mean, what more do you want?
Cryptic closing remark suggesting the defense already achieved a key evidentiary gain from the exchange, hinting at transfer evidence favorable to the defense.
Johnnie Cochran
Ours, too, your Honor.
Cochran confirms the defense also recognized that Goldberg's use of the article may have opened the door to additional evidence, signaling a potential strategic opportunity.

Evidence (1)

Informal
Article by 'labor and Epstein' containing tables about drying times of blood on cloth swatches under different conditions
discussed; Goldberg used it during Dr. Lee cross-examination; Scheck argues improper foundation; Ito to review over lunch

Notable Exchanges (2)

Barry ScheckLance A. Ito
Scheck apologizes for the speaking objection and lays out his understanding of the rules for learned treatises; Ito explains he never heard proper foundational questions and assumed the objections were premature, but concedes Scheck would have been sustained with a proper 'Foundation' objection.
candid, collegial
Hank GoldbergLance A. Ito
Goldberg defends his cross-examination by claiming Dr. Lee volunteered the drying chart information. Ito pushes back, saying Dr. Lee had already given him a 'wide enough parameter to work with' and Goldberg insisted on making it tighter.
mildly reproachful

Light Moments (1)

Lance A. Ito
Ito says he will 'probably get to read the article over the lunch hour, not that I have other things to occupy my time with' — dry sarcasm about his workload.

Credibility Attacks (1)

⚔ Henry Lee
learned treatise impeachment
Goldberg attempted to cross-examine Dr. Lee using a chart from an article by 'labor and Epstein' on blood-drying times, apparently to challenge or narrow Lee's testimony. The attempt was procedurally contested; Ito noted Lee was not ultimately impeached on anything he didn't rely on or agree with.

Objections

None recorded
Proceeding 7446 • 39 utterances
Criminal Trial
Department 103
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📂 AUG 28, 1995 📄 Exhibit rules and foundation
AUG 28, 1995 KRT DvH TD