You were asked a question as to whether or not you have conducted any experiment to determine whether or not EDTA on a bloodstain on a rusty surface will degrade as a result of contact with that rust. Do you recall that question?
Can--could Dr. Rieders perform such an experiment, sir, to determine whether or not EDTA would degrade under those conditions?
You recall you were asked a question as to whether or not you conducted any testing as to whether or not fertilizer--if EDTA in a bloodstain was subjected to fertilizer, whether that would break down the EDTA. Do you recall that question?
Do you recall questions concerning whether or not high intensity light focused on the socks might degrade any EDTA that was present in the bloodstains on that sock? Remember?
To your knowledge, could Dr. Rieders perform such an examination or such an experiment to determine whether or not EDTA would degrade under that condition?
You were asked a series of questions concerning whether or not sudden temperature changes could cause EDTA to degrade in blood. Do you recall that?
Could Dr. Rieders perform experiments to determine whether or not sudden temperature changes would affect or degrade EDTA?
Now, you indicated that you did confer with Dr. Rieders concerning the subject matter of this case on a couple of occasions, correct?
Now, the graphs that you generated as a result of the testing that you conducted were furnished to the Prosecution and to the Defense back in late February, early March?
Other than the ones that you did this last weekend, were the other--was the other data submitted to the Defense and the Prosecution months ago?
At any point, did Dr. Rieders call to tell you that he could not form conclusions or opinions because such experiments as I previously outlined to you had not been done?
Now, you recall that Dr. Rieders testified that he felt that based on the EPA study concerning the maximum tolerance for EDTA in the blood based on an experiment with fish extrapolated from that that the normal amount or the maximum amount you would find in people would be in parts per billion. Do you recall that testimony?
In your expert opinion, sir, is it--was it appropriate for him to use that EPA study to form a conclusion as to what would be the normal amount of EDTA you would expect to find in an average person?
I don't believe so. When I first got that study, which was I believe two nights ago, maybe it was Sunday night, I received that study, and the first thing in looking at it, it appeared to be out of place. They were talking about toxic clean-up of EDTA and they had a lot of things that were mentioned, and all of a sudden, out of nowhere came the fact that it said one part per billion would be normally expected in a human or considered to be the normal level. And it just didn't make sense to me why that would be there. So what I did was, the next morning, I called back to the laboratory and had them search the same reference. And it ended up that it was not a part per million, but it was a thousand--or a part per billion. It was a thousand parts per million. Evidently when it was printed out without good resolution--I really don't have the explanation now. In talking to EPA, they claim that it's a thousand parts per million is what it's supposed to be. So I did some further research, and it ended up that that was solely based on some studies to determine how much EDTA was needed to preserve blood. It had absolutely nothing at all what to do with the amount that would be expected in a person or could be toxic to a person. It was completely out of context and it was wrong.
Now, if all of the--well, are you aware, sir, of any study that has been conducted to determine what amount of EDTA you could expect to find in any one of us on a given day?
Now, you were asked a series of questions about the quantification of blood in the samples that you took for testing. You recall those questions?
Now, if you wanted the exact quantification of the amount, of the amount of blood that you are testing, you could do the tests that counsel proposed; is that correct?
Well, what that does is determines how many hemoglobin is in the blood, and from that, you can estimate how much blood is present.
All right. Now, the evidence that you're speaking of that you tested, sir, is that evidence is still in existence?
And are you aware, sir, that the evidence has been in the possession of the Defense on more than one occasion?
And could they have conducted the tests they propose to you to conduct in terms of quantifying the amount of blood in any given sample?
Could a scientist with the capabilities that you're aware of in Dr. Rieders' lab conduct the test outlined to you by counsel for a quantification of blood in any given sample?
Now, if what you want to know is whether or not any EDTA that may be detected in a stain comes from preserved tube, a preservative EDTA tube or comes from natural blood that has low levels of EDTA, would it be important to quantify with precision the amount of EDTA that you would find?
Not in this particular case. The studies that I did and the studies that were done at Quantico demonstrated very easily that you could determine between preserved blood and nonpreserved blood. We're talking a factor of 100 to a thousand times as much EDTA in preserved blood. And as I mentioned, we don't even know what the amount of EDTA is in human blood. And as I mentioned also, we don't even know whether in fact EDTA was found in these particular samples. The only thing I know for sure is, EDTA was present in the control blood samples that I made from the K67 and K68 blood samples.
Now, you were asked if you had determined whether or not the red top tube has some EDTA in it just by the virtue of the way it's manufactured. Do you recall that question?
With respect to--you were questioned about destroying data, the digital data. First of all, what is counsel referring to with respect to the digital data?
Well, in the mass spectrometer, it's a very complex instrument and you're acquiring a lot of data. For all the points that you want, you're acquiring a lot of data that is really not relevant and it takes up a lot of computer space. What you're doing is waiting for the peak to come out, but you're acquiring the data the whole time. So each time you perform a scan on the instrument, you're saving that data. Each one and a half seconds, I'm storing a lot of data on the computer. I'm recording all the masses that I'm looking for and putting it on the computer so then I can retrieve after the run is over and look to determine whether something is present or not, and then I will print out that data that is relevant to the case.
And when you print out the data that's relevant to the case, are you referring to the graphs that have been--some of which have been shown?
Well, the digital data allows me to select the appropriate scan or mass spectrum to print out. The printout is what I interpret, which comes from the digital data. But I make my interpretation based upon the chart that is printed out.
Now, if what someone wants is the digital data that backs up the graphs that you have generated, could you go back and test the evidence again and preserve that digital data?
And the graphs that you've presented here in court, are those an accurate depiction of the results of the testing that you performed?
Well, it has all the data that's been stored. Only some of that is relevant. I will go through, take out the relevant data, print it out and put that with the case.
Okay. And so what that--the relevant data being the graphs that we've seen here in court?
All right. You're aware of Dr. Rieders' capability, sir. Could he test the blood of Nicole brown Simpson that is currently in evidence for EDTA?
In fact, as far as you know and as far as you are aware, sir, Dr. Rieders has done nothing more than take your test results and give his own interpretation to them. Is that your understanding?
KEY QUOTESir, you were asked whether or not you had taken bloodstains recovered from metal and aged them for three weeks to determine whether or not you could still detect EDTA in them. Do you recall that question?
If the hypothesis given to you is that there is an allegation that evidence has been planted at or near the time of collection and not aged for three weeks, would it be--would it have any relevance to age that bloodstain for three weeks before testing it for EDTA?
No. I mean, if you're going to try to duplicate exactly what happened, you would want to do it the same time period. As I mentioned earlier, I don't believe that either of those would be necessary in the case of EDTA. It is such a stable chemical.
Well, EDTA is used as a preservative. It's used because it is a very stable chemical and it also helps to stabilize other chemicals. Its melting point or decomposes at about 300 degrees centigrade. That's a very hot temperature. I've seen no studies at all that EDTA will break down when it's in the dry form, and based on the studies that I've done on the blood, I can very easily identify EDTA in preserved blood that is several years old.
Well, I took the bloodstains that we had in the laboratory that were on swatches since 1993 and I analyzed those, and I got similar results as I get from preserved blood that's preserved today or weeks ago.
You were talking about a validation study, sir. First of all, let me ask you this. The procedures and methods that you employ to detect--determine whether or not you could detect and then identify EDTA in any of the samples in this case, was that any new method that you never used before?
No. I'm basically using the mass spectrometer which I've used in the laboratory since 1975. That's--my opinion is based on the mass spectrum of the chemicals.
In the course of your work for the FBI, sir, over the past 20 years, how common is it for you to be asked to look for a certain chemical in A--in either blood or urine?
And so your being requested to ask to look for EDTA in this case, was that an unusual request in terms of being asked to look for a chemical in either blood or urine?
It had absolutely nothing at all what to do with the amount that would be expected in a person or could be toxic to a person. It was completely out of context and it was wrong.
In fact, as far as you know and as far as you are aware, sir, Dr. Rieders has done nothing more than take your test results and give his own interpretation to them. Is that your understanding?
That's my understanding.
Its melting point or decomposes at about 300 degrees centigrade. That's a very hot temperature. I've seen no studies at all that EDTA will break down when it's in the dry form.
Never sleeps.