📄 Sidebar: letter exhibit use — Tuesday, August 8, 1995
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▲ Day 131 of 167

Sidebar: letter exhibit use

Date: Tuesday, August 8, 1995 • Utterances: 26
Defense attorney Peter Neufeld objected to the prosecution's use of a letter by Dr. Speed criticizing the NRC report, arguing that the quoted passage referred to the ceiling principle and product rule — issues outside the scope of direct examination — and would open up days of additional testimony. Judge Ito agreed the letter was being taken out of context and restricted Harmon to using only the sentence about assumptions, limiting it to a comment about the credibility of the NRC report's authors rather than any substantive statistical methodology.
1 THE COURT:

All right. Let me see counsel at the side bar.

2 (The following proceedings were held at the bench:)
3 THE COURT:

All right. We are over at the side bar. Peter, what is your objection?

4 MR. NEUFELD:

Your Honor, first of all, the reason I asked for side bar before is now that I see the context in which Dr. Speed--look at paragraph--11 made the remark about assumptions in the report, it had nothing to do with what they wrote about error rates. It had to do with their discussion of the ceiling principle and the ceiling principal is completely beyond the scope of this man's direct. I have been extremely careful not to get into ceiling principle, substructures or any of those issues at all. This entire letter--

5 THE COURT:

Isn't the point here that he is making fun of the staff of the scholar who put together the report?

6 MR. NEUFELD:

He is not making fun. What he is saying is, "It amazed me that assumptions escaped the notice of all the eminent people in the NRC panel." But the assumption is not an assumption at all having to do with his testimony as to error rates and the statistics involving error rates. It has to do with a completely separate issue--this was brought up in the Frye hearing--the ceiling principal, the product rule. He has not offered any testimony on the ceiling principle. That is different. The paragraph is simply limited to the committee's dealing with the ceiling principle and what is going to happen here is two problems; a 356 issue about completeness, and more importantly, we are going to have a 352 problem because we are going to get into the ceiling issue. We will get into all the issues about the ceiling principle and the product rule. You are talking about days of extra testimony and other witnesses and Professor Quinn coming in to testify about substructure and the like. It is absurd. This--

7 THE COURT:

You mean that comment brings all of that into play?

8 MR. HARMON:

I hope not.

9 MR. NEUFELD:

It brings in the ceiling principle and the product rule and the statement, "It amazed me about its assumptions" is clearly referring to the way the NRC committee handled the issue of the product rule and the ceiling principle. It is clearly referring to that. It is not referring to anything at all--it is not referring to anything at all that he has testified to. It would be as if, let's say, he criticized the NRC report. For a statistician, I understand that, but he is saying he was a scientist who says--criticizes the NRC for their assumptions about the role of lawyers or something.

10 THE COURT:

All right. Mr. Harmon.

11 MR. HARMON:

Thanks, your Honor. Nice to get to say something. It is criticizing the people and here is the point. All those flashy quotes yesterday, half of them are from section 3 or chapter 3 and that is from this chapter. He is criticizing the people that wrote chapter 3. And I am entitled to elicit names, and the reality is there are two people who he thinks very highly of; Mary-Claire King and Eric Lander, so at least in terms of how he feels about those people and their product, which is chapter 3, I think I'm entitled to--I mean, I've already elicited--I just want to put it there and ask him a few more questions.

12 MR. NEUFELD:

First of all, there is no testimony that those people wrote chapter 3. The lawyers already elicited that it is a consensus of opinion from the NRC committee people. There is no testimony that this chapter was written by one person or two people or three people. It is a completely unrelated point.

13 MR. HARMON:

Can I just say something?

14 THE COURT:

We've heard enough. This is a big tempest in a teapot here.

KEY QUOTE
15 MR. HARMON:

It is.

16 THE COURT:

Mr. Harmon, I'm going to preclude you from putting this up on the elmo because it is just one sentence--

17 MR. HARMON:

Uh-huh.

18 THE COURT:

--out of a long letter. You may use the sentence, "It amazed me how its assumptions" referring to that particular chapter of the NRC report.

19 MR. HARMON:

I can do that.

20 MR. NEUFELD:

I wouldn't say chapter. He can say ceiling principles, ask him about that.

21 THE COURT:

If you get into ceiling principles you open up all the problems. That is my suggestion. Don't go away.

22 (Brief pause.)
23 THE COURT:

Okay.

24 MR. NEUFELD:

The only thing I want to say is, your Honor, if you want to let him ask a question about assumptions, I would then say that the remarks should be limited to assumptions about the method for calculating that frequency so you don't write out the words "Ceiling principle."

25 THE COURT:

This is a comment regarding the people who did the report and their, quote, eminence or non-eminence. All right. That is what it is restricted to.

KEY QUOTE
26 MR. NEUFELD:

Okay.

Temperature

tense

Key Quotes (4)

Lance A. Ito
We've heard enough. This is a big tempest in a teapot here.
Ito dismisses the dispute as overblown before ruling in Neufeld's favor on the scope issue.
Peter Neufeld
You are talking about days of extra testimony and other witnesses and Professor Quinn coming in to testify about substructure and the like. It is absurd.
Neufeld's core 352 argument — that one sentence in a letter would balloon into a sprawling mini-trial on DNA statistics.
Lance A. Ito
This is a comment regarding the people who did the report and their, quote, eminence or non-eminence. All right. That is what it is restricted to.
Ito's final ruling narrowing the permitted use of the letter to a credibility observation about the NRC authors, not the methodology itself.
Rockne Harmon
All those flashy quotes yesterday, half of them are from section 3 or chapter 3 and that is from this chapter. He is criticizing the people that wrote chapter 3.
Harmon reveals his strategic purpose: to undercut the NRC report's authors, including Mary-Claire King and Eric Lander, whose work the defense relied on.

Evidence (2)

Informal
Letter by Dr. Speed containing the sentence 'It amazed me how its assumptions escaped the notice of all the eminent people in the NRC panel'
disputed; Judge Ito restricts use to single sentence, prohibits display on ELMO
Informal
NRC report (National Research Council), particularly Chapter 3, dealing with the ceiling principle and product rule for DNA frequency calculations
discussed as context for the letter's meaning

Notable Exchanges (2)

Peter NeufeldRockne HarmonLance A. Ito
Neufeld argues the letter passage concerns the ceiling principle and product rule — not error rates — and admitting it would open a 352 can of worms. Harmon counters he is entitled to use it to attack the credibility of the NRC chapter's authors. Ito cuts both off and issues a narrow ruling.
tense but controlled
Peter NeufeldLance A. Ito
After Ito's ruling, Neufeld continues to press for even tighter language, suggesting Harmon say 'ceiling principles' rather than 'chapter.' Ito shuts that down too, issuing a final framing.
strategic

Light Moments (2)

Rockne Harmon
Harmon, repeatedly cut off, finally gets acknowledged by Ito and quips 'Nice to get to say something.'
Rockne Harmon
Harmon agrees with Ito's 'tempest in a teapot' characterization: 'It is.'

Credibility Attacks (1)

⚔ NRC report authors (Mary-Claire King, Eric Lander, NRC panel)
prior written statement / impeachment by learned treatise author
Harmon sought to use Dr. Speed's letter to show that scientists Speed respected had made flawed assumptions in the NRC report, undermining the DNA statistical methodology the defense relied upon.

Witness Demeanor

(Brief pause.)

Objections

1 objections (1 sustained, 0 overruled)
Proceeding 7228 • 26 utterances
Criminal Trial
Department 103
⚖️ Start
📂 AUG 8, 1995 📄 Sidebar: letter exhibit use
AUG 8, 1995 KRT DvH TD