📄 Cross-examination of Roger Martz — Tuesday, July 25, 1995
Address:
C:\DEPT103\CRIMINAL\1995\JUL\25\CROSS-EXAMINATION-OF-ROGER-MAR.DOC
TRIAL
▲ Day 121 of 167

Cross-examination of Roger Martz

Witness: Roger Martz
Examiner: Marcia Clark
Called by: Defense • Date: Tuesday, July 25, 1995 • Utterances: 486
Marcia Clark conducts redirect examination of FBI forensic chemist Roger Martz, rehabilitating his EDTA testing methodology after cross-examination by defense counsel Blasier. Using a series of comparison graphs (People's 543–547), Martz demonstrates that blood recovered from the rear gate and sock showed no identifiable EDTA daughter spectrum, while known EDTA-preserved reference blood samples produced clear, unambiguous signals. He also directly rebuts defense expert Dr. Rieders' interpretation of the same graphs, calling Rieders' reading of noise as signal 'totally wrong' and scientifically inappropriate.
1 THE COURT:

Thank you, ladies and gentlemen. Please be seated. Agent Martz, would you resume the witness stand, please. All right. You got enough water there? All right. Miss Clark.

2 MS. CLARK:

Good afternoon.

THE JURY: Good afternoon.

3 MS. CLARK:

All right, sir. Now, you indicated that you did not identify the substance found on the rear gate and on the sock or in your blood as EDTA because it did not present the full daughter spectrum for EDTA, correct?

4 MR. MARTZ:

That's correct.

5 MS. CLARK:

Now, you have met with Mr. Blasier in Washington D.C., correct?

6 MR. MARTZ:

Yes, I have.

7 MS. CLARK:

And you have spoken to him on the phone?

8 MR. MARTZ:

Yes, I have.

9 MS. CLARK:

You have been accessible to him, correct?

10 MR. MARTZ:

Yes, I have.

11 MS. CLARK:

And did you explain to him why you did not identify the substance on the rear gate and on the sock as EDTA?

12 MR. MARTZ:

I believe that I did, yes.

13 MS. CLARK:

Because of the absence of the full daughter spectrum?

14 MR. MARTZ:

That's correct.

15 MS. CLARK:

Did you refuse to answer any questions that he posed to you concerning this case?

16 MR. MARTZ:

No, I did not.

17 MS. CLARK:

Did he make any request of you that you conduct any of the experiments he outlined here in court today when you spoke to him on previous occasions?

18 MR. MARTZ:

No, I don't believe he did, no.

19 MS. CLARK:

Did he ask you at that time when he spoke to you on--previously in Washington or on the telephone whether or not you were aware of any validation studies conducted by Quantico?

20 MR. MARTZ:

Uh, I'm sure we talked about Quantico, but I don't remember the specific details.

21 MS. CLARK:

And the information that was generated by Quantico concerning the 93 percent average EDTA extraction, that study--did it indicate that when you--your extraction method would on the average remove 93 percent of the EDTA from any stain?

22 MR. MARTZ:

I believe I--in looking it over this afternoon, it said very little EDTA remained in the second extract. It did not give a percent in the information that he received.

23 MS. CLARK:

Okay. When it said that very little EDTA remained in the second extract, does that mean that in order to determine if your extraction methods were appropriate and efficient, that they extracted the EDTA using the method you used and then attempted to go back and extract it again?

24 MR. MARTZ:

That's correct.

25 MS. CLARK:

And is that an appropriate method to use to determine whether an extraction method is efficient?

26 MR. MARTZ:

That is one way, yes. Another way would be just to quantitate absolutely how much you remove knowing how much you placed on the sample.

27 MS. CLARK:

And by conducting the study that they did, was it essentially found that the extraction method you used was appropriate?

28 MR. MARTZ:

I think that it was, yes.

29 MS. CLARK:

All right. Now, you indicated that you continued testing on February 22nd even though you had determined there was no EDTA from a preserved test tube and you went into another mode to do that testing?

30 MR. MARTZ:

Yes. I conducted a positive ion mode looking for the 160 daughter from the 293 quasi molecular ion or the m plus 1 parent ion.

31 MS. CLARK:

Now, did you--was there something different about the method of testing you used on the 22nd from the method you had used on the 19th?

32 MR. MARTZ:

It was the same method of extraction. The instrumentation perimeters varied.

33 MS. CLARK:

And what do you mean by that?

34 MR. MARTZ:

Well, with the instruments, you can look at the positive ions or the negative ions that are produced in the ionization. And the first day when I set up the experiment, I was looking for the negative ion, the EDTA form with the ion complex. On the second day or on the 22nd, I was looking for a protonated EDTA.

35 MS. CLARK:

And why did you do that? What would that give you more than you already got from your previous testing?

36 MR. MARTZ:

Well, I determined that it was a little bit more sensitive. So I would be able to detect lower amounts of EDTA that may be present naturally in human blood.

37 MS. CLARK:

Now, when you talk about doing these tests, sir, you indicated that you tested your own blood. Do you recall that?

38 MR. MARTZ:

Yes.

39 MS. CLARK:

Did anyone ask you to do that?

40 MR. MARTZ:

Not that I remember, no.

41 MS. CLARK:

It was just your idea?

42 MR. MARTZ:

Yes. That's correct.

43 MS. CLARK:

Nevertheless, did you generate graphs showing the results of the testing on your own blood?

44 MR. MARTZ:

Yes, I did.

45 MS. CLARK:

And did you generate graphs showing that your--showing your blood tested with EDTA and without?

46 MR. MARTZ:

Yes.

47 MS. CLARK:

Now, when I say with and without, I'm talking about adding EDTA preservative to it.

48 MR. MARTZ:

Yes.

49 MS. CLARK:

And those graphs were turned over to the Defense?

50 MR. MARTZ:

Uh, those were turned over when we met. I guess it was about weeks ago now.

51 MS. CLARK:

All right. Back to the testing on February 22nd.

52 MS. CLARK:

Your Honor, I have here a series of four charts that I would like to be marked People's next in order, A, B, C and D.

53 THE COURT:

543.

54 MS. CLARK:

Thank you.

55 THE COURT:

People's 543, a through C.

56 (Peo's 543-A through D for id = graphs)
57 MS. CLARK:

All right, sir. I'm going to show you first of all on the elmo People's 543-A.

58 THE COURT:

Are these the graphs on Martz' blood?

59 MS. CLARK:

No, your Honor. These are going to be on the sock.

60 THE COURT:

All right.

61 (Discussion held off the record between the Deputy District Attorney and Defense counsel.)
62 MS. CLARK:

First of all, 543-A, this is on Q206. Is that the socks, sir?

63 MR. MARTZ:

That's correct.

64 MS. CLARK:

All right. Could you please interpret for us what we see in Q--the sample of Q206?

65 MR. MARTZ:

The bottom chart is the total ion chromatogram.

66 MS. CLARK:

I'm sorry?

67 MR. MARTZ:

The bottom chart, it would be what's called the total ion chromatogram or all the ions that were looked for. The top chart is the 160 ion which is a daughter ion of EDTA. It has the m/Z160, which indicates master charge 160.

68 MS. CLARK:

Now, this is the evidence from the sock itself, correct?

69 MR. MARTZ:

That's correct.

70 MS. CLARK:

Did you attempt then to determine whether or not you could get the full daughter spectrum, that is the 132 as well on the evidence of the sock?

71 MR. MARTZ:

Yes, I did.

72 MS. CLARK:

And showing you 543-B, does this graph depict your attempt to see whether or not you could detect the full daughter spectrum in the evidence of the blood from the sock?

73 MR. MARTZ:

Yes, it does.

74 MS. CLARK:

Now, you recall, doctor, you were present in court when Dr. Rieders testified?

75 MR. MARTZ:

Yes, I was.

76 MS. CLARK:

And you saw his--you heard his testimony concerning this graph that's now before the jury?

77 MR. MARTZ:

That's correct.

78 MS. CLARK:

Do you agree with the opinion that he gave on this graph?

79 MR. MARTZ:

No, I do not.

80 MS. CLARK:

Please explain why.

81 MR. MARTZ:

This particular graph depicts a lot of noise is all it depicts. As I mentioned before with the electro spray, everyone is running a 50-yard dash. Everyone is coming to the finish line about the same time. There are many, many, many chemicals in blood that are going to come across the finish line at the same retention time as EDTA. So we're going to get a lot of noise signal at that area. The noise in this case is no larger really than--than--it--it just doesn't increase anywhere, and where it increases may be slightly where Dr. Rieders was pointing out in the one area. That's only because everything was coming out of the instrument at one time and it caused electrical noise. This is not real peaks. This is electrical noise. This is very common in mass spectrometry. It's electrical noise. It is not signal. Any time you would identify something as signal, you would want something larger than the noise. There's nothing here that's larger than the noise. It's random noise that's very common in mass spectrometry, especially in electro spray where you're using different I should say electrical settings than you're using with conventional mass spectrometry. This is standard noise in electro spray mass spectrometry. This should never be considered signal or should never be interpreted as anything other than noise.

What you would want to do and what I did, and unfortunately I didn't print it out, but there was a mass spectrum taken of that particular peak, and it showed that it was just noise. Since there was nothing there, I didn't print it out. But for someone to try to make this into something other than noise is totally wrong.

82 MS. CLARK:

In your opinion then, is his--scientifically speaking, was it scientifically and forensically inappropriate for Dr. Rieders to have interpreted this graph in the manner that he did?

KEY QUOTE
83 MR. MARTZ:

In my opinion, it was, yes.

KEY QUOTE
84 MS. CLARK:

Now, you point out the issue with respect to retention time. And you recall that Dr. Rieders testified that at about the same time, there was what he determined to be peaks of significance by looking at the retention time. Do you recall that testimony?

85 MR. MARTZ:

I recall that, yes.

86 MS. CLARK:

Now, Dr. Rieders works on the gas chromatograph mass spectrum?

87 MR. MARTZ:

Yes.

88 MS. CLARK:

And in the gas chromatograph machine, the column in that machine is used for separation purposes, correct?

89 MR. MARTZ:

Yes, it is.

90 MS. CLARK:

And in that regard then, the time at which things come out or things pass through the column and get to the mass spec is of significance, correct?

91 MR. MARTZ:

Yes, it is.

92 MS. CLARK:

In your machine, the LC tandem ms with electro spray, you have indicated I believe an analogy that it's kind of like measuring how fast people will go in a 50-yard run?

93 MR. MARTZ:

That's correct.

94 MS. CLARK:

They'll all run approximately at the same pace?

95 MR. MARTZ:

Well, they're going to be a lot closer than if they were running a two-mile race.

96 MS. CLARK:

Okay. And why is that true in your machine and not true in his?

97 MR. MARTZ:

Well, it could be true in anyone's machine. It's just the perimeters that are set up with this instrument at this particular time. I'm using the mass spectrometer, the triple stage mass spectrometer for my separator, more so than I am the liquid chromatography part of it. The liquid chromatography is giving minimal separation. Everything is coming out pretty much at dead volume. That's the shortest time something can go through that column. But I can allow this to happen because I have the resolution capability of a triple stage mass spectrometer and I can only let a particular ion go through. So I'm using that as my resolving power and not my chromatography.

98 MS. CLARK:

Physically speaking, in your machine, sir, you have a column, right?

99 MR. MARTZ:

That's correct.

100 MS. CLARK:

And you would use a liquid to push whatever material you want to test through that column; is that right?

101 MR. MARTZ:

That's correct.

102 MS. CLARK:

Then it comes to a very small capillary, a very small hole; is that right?

103 MR. MARTZ:

That's correct.

104 MS. CLARK:

Probably smaller than I can make, right?

105 MR. MARTZ:

It's a very small hole.

106 MS. CLARK:

And it's pushed through that capillary. When it's pushed through it, is some kind of electrical charge given to it?

107 MR. MARTZ:

It goes through an electrical voltage of about 4,000 volts.

108 MS. CLARK:

Okay. And then is it vaporized with that electricity?

109 MR. MARTZ:

Well, it's a combination of a lot of things. It's--they're very small droplets. They're being forced out of a small tube. There's other gases around there, and all this helps the very small droplets to evaporate.

110 MS. CLARK:

And when that happens, when the small droplets evaporate, they have an electrical charge given to them?

111 MR. MARTZ:

Well, the electrical charges are on the particles and they're transferred from one to the other. But there's a lot of electrical charges that are transferred at that particular time, yes.

112 MS. CLARK:

Okay. And the purpose of that is so that you can visualize or see what you've got?

113 MR. MARTZ:

Well, so you can create an ion. A mass spectrometer isn't any good unless you can create an ion. You either need a positive ion or a negative ion in order to separate it and identify it.

114 MS. CLARK:

So it helps you to identify what you've got?

115 MR. MARTZ:

That's correct.

116 MS. CLARK:

All right. And then in your machine, I think you indicated--you mentioned something earlier called a quadrupole?

117 MR. MARTZ:

Well, it's a triple stage quadrupole. I have three quadrupoles, yes. That's something--it's a mass filter. It's used to separate out the different masses.

118 MS. CLARK:

Okay. And the quadrupole, is it like four rods kind of like--it would be like four pencils through which the item--the material is passed?

119 MR. MARTZ:

Well, the ions are passed, yes.

120 MS. CLARK:

And then you determine by changing the voltage of those poles what can pass through and what can't?

121 MR. MARTZ:

That's correct.

122 MS. CLARK:

So you decide, okay, I'm going to let through all 293's in this case, right?

123 MR. MARTZ:

That's correct.

124 MS. CLARK:

And so only the 293's are going to make it through?

125 MR. MARTZ:

That's correct.

126 MS. CLARK:

Okay. Then it's going to pass through another set of four poles?

127 MR. MARTZ:

Right.

128 MS. CLARK:

And with that second set of four poles, does that do anything?

129 MR. MARTZ:

Well, that's where the collision takes place. That's where you break down that ion and produce the daughter ions, the 132 and the 160 ion.

130 MS. CLARK:

So that--is that like a reaction chamber?

131 MR. MARTZ:

It's a collision chamber.

132 MS. CLARK:

A collision chamber.

133 MR. MARTZ:

Yes.

134 MS. CLARK:

And then is there a third set of four poles that that broken-down ion goes to?

135 MR. MARTZ:

That's correct.

136 MS. CLARK:

Now, this third set will let through what?

137 MR. MARTZ:

It will let through what I select. In one case, I let just the 160 ion go through, and in another case, I let from mass 130 up to 295 go through so I could get the full daughter spectrum.

138 MS. CLARK:

So in that way, you run the material through your machine and adjust the voltage so that you can pass through and select out 293, 160 and 132?

139 MR. MARTZ:

Well, you can do it that way. What I elected to do is allow the 293 to go through and then just look at the 160 or let the 293 go through and then look at the full daughter mass spectrum from mass 130 to 295.

140 MS. CLARK:

Now, was that an efficient way to look for the 132?

141 MR. MARTZ:

Well, it's not the most efficient way, but it's the only way that I would look for it in order to identify EDTA. I mean, I could look for 132 by itself, but my purpose is to identify EDTA.

142 MS. CLARK:

Do you recall counsel asking you the questions about selective response?

143 MR. MARTZ:

Selective ion monitoring.

144 MS. CLARK:

Monitoring?

145 MR. MARTZ:

Yes.

146 MS. CLARK:

Yes. And in that procedure, you were going to focus only on the 132, correct?

147 MR. MARTZ:

That's correct.

148 MS. CLARK:

Why was that not appropriate to do in this case?

149 MR. MARTZ:

Well, it would just be another screening test. It would not positively confirm EDTA. What I need for the confirmation is the three ions I mentioned in a particular ratio. And the only way I can do that is to get the full daughter. If I look for them individually, it is not proof that the other compounds or ions are not there. In other words, if I have a camera and I look for one person, another person, another person, it doesn't prove that there aren't people between those people. So I need to look at the full spectrum to see if it's EDTA. If there's something there in the middle that doesn't belong, it's not EDTA. So I need to look at the full spectrum to determine whether or not it's EDTA.

150 MS. CLARK:

Okay. So if you're looking only for 132's, you could be missing 160's?

151 MR. MARTZ:

You could be missing a lot of ions. There could be other ions there. There could be a 150, a 170. You don't know unless you look.

152 MS. CLARK:

So if you look for only 132's, you could be missing other ions that would prove to you it was not EDTA?

153 MR. MARTZ:

That's correct.

154 MS. CLARK:

All right. So in your--for the manner in which your machine works, the separation occurs in the areas of those four poles, the quadrupoles?

155 MR. MARTZ:

Well, some of the separation does take place in the chromatography, but very little. Most things are coming through a dead volume. The highest selectivity is in the quadrupoles, allowing only mass 293 to go through.

156 MS. CLARK:

Okay. So in the column that you--in the way you use your machine, the column is not particularly used for separation purposes?

157 MR. MARTZ:

Well, it's used for separation, but it's certainly not used for identification.

158 MS. CLARK:

Okay. It does not have the identification properties or capabilities that Dr. Rieders' machine does, correct?

159 MR. MARTZ:

It does not have the normal resolution that you would expect from chromatography.

160 MS. CLARK:

Okay. So given what you're saying, sir, the fact that in your machine, all material is pretty much going to pass through the column at about the same time as opposed to Dr. Rieders' machine in which things pass through the column at very different times, would it ever be appropriate to use retention time as a factor to determine whether or not you identify a compound?

161 MR. MARTZ:

Well, I mean, it could be used, but I certainly wouldn't give it much weight. I personally would not use that. I use the full daughter mass spectrum. The separation technique that I use is just simply to allow the electro spray ionization to happen, not to identify the compound. Now, certainly, the compound has to come out there. But all compounds or most compounds I would identify would come out there. So it just doesn't have what we call resolution, the ability to separate one component from the other.

162 MS. CLARK:

Then would you say, sir, that the retention time in your machine is not a discriminating factor in terms of being able to identify one compound as opposed to another?

163 MR. MARTZ:

Yes. That's a fair statement.

164 MS. CLARK:

And do you think that--strike that. To your knowledge, has Dr. Rieders ever operated the electro spray?

165 MR. MARTZ:

To my knowledge, he has not. He admitted that yesterday.

166 MS. CLARK:

And what impact, if any, would that have on the knowledge that retention time is not a discriminating factor in your machine?

167 MR. MARTZ:

Well, it could have some. But what you need to consider here is the fact that everything was coming out in about a minute. Now, under normal chromatography like I did the one day to differentiate the bloodstains, the chromatography was like 10 minutes. Generally, if you see something in chromatography that's coming out at about one minute, you should be able to realize that's pretty much dead volume and that everything else is going to come out there, and you wouldn't want to use that to help discriminate a compound.

168 MS. CLARK:

What do you mean when you say "Dead volume"?

169 MR. MARTZ:

Well, in other words, there's a certain flow through the column. If I inject something here, it physically takes a certain amount of time to come out the other end. So when I inject EDTA or anything else, it just races through the column and comes out in the minimum time and something can pass through that column. Now, retention time generally, you want something to be absorbed somewhat onto the column so it will take longer to pass through, it will react with the column as it goes through. So it will take a long time to come out. In this particular case, it's just passing through.

170 MS. CLARK:

And that's the major difference between the machine he operates and the one you operate?

171 MR. MARTZ:

Well, not necessarily the machine, but--

172 MS. CLARK:

The column.

173 MR. MARTZ:

--the type of chromatography that I'm doing versus what the normal chromatograph person would expect.

174 MS. CLARK:

Now, you heard Dr. Rieders testify that he was surprised that there was only a few minutes between each scan?

175 MR. MARTZ:

Each run.

176 MS. CLARK:

Each run. Was that surprising to you, sir?

177 MR. MARTZ:

No, because that's the way I designed it.

178 MS. CLARK:

And you run this machine almost every day?

179 MR. MARTZ:

Pretty much. Unfortunately, I still try to maintain my proficiencies on the instruments in the laboratory even though I'm in a management role. I do actively operate the instrument.

180 MS. CLARK:

Now, given that you would not--you said signal to noise. The random peaks that you see on the chart before you on 543-A, how would you characterize those?

181 MR. MARTZ:

Well, the first indication that you don't want to give much credence to this is the fact that we've got 10 to the minus fourth for noise. I mean, this is a large count. So someone that didn't know a lot about mass chromatography would want to know why do you have noise that's that large. I mean, that's a thousand ions or something. Why do you have electrical noise that's a thousand ions. I mean, that's the first thing if I didn't know anything about electro spray or how this was done, I would want to know that before I made any interpretation. Generally, with most instruments, your noise level is going to be very, very small. Now, electro spray, the manufacturer suggests that you use the higher settings because they determine that it works better that way. And this is not normal noise level that you would expect in a mass spectrometer, plus your noises increase by the fact that you're doing tandem mass spectrometry. So you're got two different techniques here that require you to have this very large noise. And any time you have noise that's a thousand counts high, you'd better be very, very careful before you try to interpret and make a peak out of that noise.

182 MS. CLARK:

Because?

183 MR. MARTZ:

Because it's just noise. It's not a peak.

184 MS. CLARK:

It's not--it's not a readable?

185 MR. MARTZ:

It's random noise. I mean, I certainly would want something at least three times the noise before I would even consider it to be a signal.

186 MS. CLARK:

Okay. Yeah. We talked a little bit about that, the ratio of signal to noise. Does--can you--does that mean that the highest peak has to be at least three times higher than any of the smaller random peaks--

187 MR. MARTZ:

That's correct.

188 MS. CLARK:

--before you call it as an identification of some kind--

189 MR. MARTZ:

That's correct.

190 MS. CLARK:

--or detection?

191 MR. MARTZ:

Yes.

192 MS. CLARK:

And do you see any peak in this graph that qualifies as being three times noise?

193 MR. MARTZ:

No, I don't.

194 MS. CLARK:

No peak three times as high as any noise or random peak?

195 MR. MARTZ:

I consider all that to be electrical noise.

196 MS. CLARK:

All right. Next in order, 543-B.

197 MS. CLARK:

So then the daughter 132 is not shown on the sock; is that correct?

198 MR. MARTZ:

Not in my opinion, and taking the full mass spectrum, it was not present.

199 MS. CLARK:

Showing you 543 B. C? Oh, that was B. C. Can you tell us what this graph shows, sir?

200 MR. MARTZ:

This is the K67 blood which was used as a control for Q204. This is--

201 MS. CLARK:

206?

202 MR. MARTZ:

I'm sorry. 206. This is a known blood that I took and placed on a cutting of the sock.

203 MS. CLARK:

Now, when you say the known blood that you took, that was from an EDTA tube, correct?

204 MR. MARTZ:

Right. That was from the K67 EDTA preserved blood.

205 MS. CLARK:

And what do you see here?

206 MR. MARTZ:

That is signal. When you have something that's--in this case, we have 10 to the fifth, six times 10 to the fifth, that's a large signal for--representing the ion 160, which is a daughter ion of EDTA. There's a substantial amount of that particular compound coming up at that scan 39.

207 MS. CLARK:

Now, in this graph, I don't see any of the random little jagged peaks that we did on the last one where you found that there was no full daughter spectrum.

208 MR. MARTZ:

Well, the reason you don't see the noise is because the signal is so large.

209 MS. CLARK:

Can you explain that?

210 MR. MARTZ:

Well, if you have noise that's--that's an inch high and your signal is 10 feet high, on a relative scale, you won't see that. So what you do is take your 10 feet and you kind of bring it down, and the one inch of noise disappears. That's a very, very large signal and we're plotting it on the same scale. So the noise disappears.

211 MS. CLARK:

So if you were to generate a graph that kept the noise in it, but wanted to also depict the relative size of the peak that we see here, would you have graph paper big enough?

212 MR. MARTZ:

Well, I mean, you can plot any of these things and that's why I plot it on that particular graph paper, the comparison of the ion counts for the blood and the questioned stains.

213 MS. CLARK:

All right. So this is how a peak looks on known EDTA blood?

214 MR. MARTZ:

That's correct.

215 MS. CLARK:

All right. And that's for the 160 daughter?

216 MR. MARTZ:

That's correct.

217 MS. CLARK:

And going back to the evidence of the sock from the 160 daughter, okay, now, that's the evidence of the sock, correct?

218 MR. MARTZ:

That's correct. That's the bloodstain on the sock.

219 MS. CLARK:

Again, for the 160 daughter?

220 MR. MARTZ:

That's correct.

221 MS. CLARK:

And here you see all of those jagged lines and then that jagged peak?

222 MR. MARTZ:

You see the jagged lines because the signal is not that much greater than the noise.

223 MS. CLARK:

Okay. Now, I want to show you 543-D. In 543-D, this is again the sock with the blood you put on it from the EDTA test tube, correct?

224 MR. MARTZ:

That's correct.

225 MS. CLARK:

So this is what they call a positive control?

226 MR. MARTZ:

That's correct.

227 MS. CLARK:

And here you're trying to see if you can detect in the known reference blood the full daughter spectrum?

228 MR. MARTZ:

That's correct.

229 MS. CLARK:

And did you find it?

230 MR. MARTZ:

Yes. And you can see on those traces the 132 ion, the 160 and the 293, those are all much larger than the noise.

231 MS. CLARK:

Then looking at all of these together, sir--I'm going to try and show you if I can the two reference sample, that is the two known EDTA bloodstains that you put on the sock that shows the parent ion and the full daughter spectrum.

232 MR. MARTZ:

Well, those are the reconstructed ions of the daughter spectrum, yes.

233 MS. CLARK:

And on these readings, would you identify EDTA?

234 MR. MARTZ:

Yes, I would.

235 MS. CLARK:

Now, by way of contrast, I'm going to show you 543-A and C. I'm going to show you the evidence, the blood taken from the sock itself. Okay. Now, this depicts your attempt to find the full daughter spectrum on the evidence of the sock?

236 MR. MARTZ:

That's correct.

237 MS. CLARK:

And would you identify the full daughter spectrum on the sock based on what you see in these graphs?

238 MR. MARTZ:

No, I would no.

239 MS. CLARK:

And that is because?

240 MR. MARTZ:

Because there is no signal above noise in the daughter ion spectrum.

241 MS. CLARK:

And so would you identify the substance found in the blood on the sock as EDTA?

242 MR. MARTZ:

No, I would not.

243 MS. CLARK:

And scientifically, sir, in your opinion, would it be appropriate to identify EDTA from the graphs and the results shown in these graphs?

244 MR. MARTZ:

No.

245 MS. CLARK:

In the blood on the sock?

246 MR. MARTZ:

No, it would not.

247 MS. CLARK:

And that is because?

248 MR. MARTZ:

There is no full daughter spectrum for the EDTA chemical.

249 (Brief pause.)
250 MS. CLARK:

All right. And you also did testing on the blood from the rear gate on February 22nd, sir?

251 MR. MARTZ:

That's correct.

252 MS. CLARK:

And what kind of test did you perform on February 22nd on the blood taken from the rear gate?

253 MR. MARTZ:

The same as I did on the sock. I analyzed in the positive ion mode doing both the daughter spectrum of 293 looking at the 160 ion in the full daughter spectrum.

254 MS. CLARK:

I have another series of four charts, your Honor, People's 544-A through D.

255 THE COURT:

So marked.

256 (Peo's 544-A through D for id = graphs)
257 MS. CLARK:

Showing you first of all People's 544-A, what is that?

258 MR. MARTZ:

That's the Q204.

259 MS. CLARK:

And that is the gate?

260 MR. MARTZ:

That's correct.

261 MS. CLARK:

Okay. Now, that is the evidence, right?

262 MR. MARTZ:

Correct. That's the blood stain from the gate.

263 MS. CLARK:

And is this an attempt by you to determine whether or not you can find the daughter 160 ion?

264 MR. MARTZ:

That's correct.

265 MS. CLARK:

Do you identify this as the daughter of 160 ion being present?

266 MR. MARTZ:

That is correct, yes.

267 MS. CLARK:

Now, how do you account for the random peaks that you--the jagged peaks below the one larger peak?

268 MR. MARTZ:

Again, that's electrical noise.

269 MS. CLARK:

Now, the fact that you see that electrical noise and in addition to that one peak, what does that tell you about the strength of the signal for the 160 daughter ion?

270 MR. MARTZ:

Well, it's closer to the noise level or becoming very close to the noise level in the instrument.

271 MS. CLARK:

Does that mean it's a weaker signal?

272 MR. MARTZ:

That's correct.

273 MS. CLARK:

And showing you 544-B. Is this an attempt by you to see if you can find the full daughter spectrum, that is the 132 as well as the 160, in the rear gate stain?

274 MR. MARTZ:

Yes. That's correct.

275 MS. CLARK:

And are you able to identify anything that would allow you--are you able to identify the full daughter spectrum in the rear gate bloodstain?

276 MR. MARTZ:

No, I am not.

277 MS. CLARK:

Can you explain why?

278 MR. MARTZ:

Well, there's several possibilities. One is that it's not EDTA. Another would be that it's below my detectable limit.

279 MS. CLARK:

But what do you see here in the graph?

280 MR. MARTZ:

Well, the graph is just strictly instrumental noise. There's no signal that's recognizable above the noise level.

281 MS. CLARK:

Do you have an identification of the 132 daughter?

282 MR. MARTZ:

No.

283 MS. CLARK:

And if there was 132 daughter below your detectable limit, could it have come from an EDTA test tube?

284 MR. MARTZ:

Yes.

285 MS. CLARK:

And what is your detectable limit?

286 MR. MARTZ:

It's difficult to tell, but it's somewhere around 10 parts per million.

287 MS. CLARK:

And what was the amount of EDTA you found in the blood taken from the test tubes?

288 MR. MARTZ:

Well, calculated, it should be between 1- and 2,000 parts per million.

289 MS. CLARK:

And based on the findings in the last two charts, sir, a and B, 544-A and B, on the rear gate stain, is there a full daughter spectrum?

290 MR. MARTZ:

No, there is not.

291 MS. CLARK:

Would you identify the substance found in the blood on the rear gate as EDTA based on that finding?

292 MR. MARTZ:

No, I would not.

293 MS. CLARK:

Would it be scientifically appropriate or correct in your opinion to do so?

294 MR. MARTZ:

No, it would not.

295 MS. CLARK:

Showing you 544-C, tell us what that is, sir.

296 MR. MARTZ:

That's the bloodstain that I prepared. Can you move it down a little bit?

297 MS. CLARK:

Can you move it down?

298 MR. MARTZ:

The K68 bloodstain that I prepared as a control for the Q204.

299 MS. CLARK:

The K68, meaning the blood taken from the test tube containing Mr. Simpson's blood?

300 MR. MARTZ:

That's correct.

301 MS. CLARK:

And in this case, you applied the blood taken from his test tube, his blood, EDTA blood onto the cotton swatch for the rear gate?

302 MR. MARTZ:

That's correct.

303 MS. CLARK:

And this is the result you obtained?

304 MR. MARTZ:

Yes.

305 MS. CLARK:

And based on this graph, would you say that the 160 daughter ion is present?

306 MR. MARTZ:

Yes.

307 MS. CLARK:

And showing you 544-D, did you then make an attempt to determine whether you could find the full daughter spectrum on the known stands, that is the cotton swatch on which you placed the reference blood from Mr. Simpson?

308 MR. MARTZ:

Yes, I did.

309 MS. CLARK:

And showing you 544-D, can you tell us whether or not you were able to detect the full daughter spectrum based on the results on this graph?

310 MR. MARTZ:

Yes, I was.

311 MS. CLARK:

And can you explain to us why?

312 MR. MARTZ:

Well, if--clearly seeing that the ions 132, 160 and 293 are all ions that come out approximately 30 scans that are all above the noise level.

313 MS. CLARK:

I'm going to show you--all right. Those are the results of your testing of the cotton swatch on which you put the blood from the reference tube of Mr. Simpson, correct?

314 MR. MARTZ:

That is correct.

315 MS. CLARK:

And based on these results, would you identify the substance found in his blood as EDTA?

316 MR. MARTZ:

Yes, I would.

317 MS. CLARK:

And in these graphs, you see the full daughter spectrum?

318 MR. MARTZ:

Those are the items that represent the full daughter spectrum, yes.

319 MS. CLARK:

All right. And then contrasting those--contrasting those results, sir, from the known--the blood that we know to have been taken from a reference tube containing EDTA, here we have the results of the blood recovered from the rear gate, the evidence blood. Based on the results in these graphs, sir, would you identify the substance--would you identify that a full daughter spectrum has been obtained?

320 MR. MARTZ:

A full daughter spectrum was not obtained.

321 MS. CLARK:

And based on that fact, sir, and on the results shown in these graphs, would you identify the substance found in the blood on the rear gate as EDTA that came from a preserved blood tube?

322 MR. MARTZ:

No, I would not.

323 MS. CLARK:

And in your opinion, would it be scientifically correct to do so?

324 MR. MARTZ:

No, it would not.

325 MS. CLARK:

Your Honor, I have another chart. I ask that it be marked People's 545.

326 THE COURT:

545.

327 MS. CLARK:

Thank you.

328 (Peo's 545 for id = chart)
329 MS. CLARK:

Did you generate a graph to illustrate the results of all of the testing that you conducted on the 22nd?

330 MR. MARTZ:

Well, the--some of the results, not all of them. I didn't include the blanks, but most of the results. Some of them.

331 MS. CLARK:

And did you run blanks in-between each of your evidence runs?

332 MR. MARTZ:

Yes, I did.

333 MS. CLARK:

And what was the purpose of doing that?

334 MR. MARTZ:

Just to show that there was no carry-over from one injection to the other.

335 MS. CLARK:

Can you interpret for us the results--soon as we can see them--shown in this graph that's been marked as People's 545?

336 MR. MARTZ:

The two blood samples, K67 and K68, which I prepared and placed on the sock and a cotton swatch, clearly demonstrate that EDTA is present in these samples. This is the amount that we would want to find in the sock and on the gate if we were to say that it came from preserved blood. But as you can see, the sock and the gate gave a very minimal response for this particular ion of EDTA. In my opinion, EDTA from preserved blood is not present on the sock and the gate. These stains did not come from preserved blood.

337 MS. CLARK:

Now, you were asked on direct by Mr. Blasier whether or not you had tested any blood of Nicole for the presence of EDTA. Do you recall that question?

338 MR. MARTZ:

Not specifically.

339 MS. CLARK:

Okay. Did you test a swatch of the dress in which she was found?

340 MR. MARTZ:

Uh, yes, I did.

341 MS. CLARK:

And did you test a swatch of the dress that contained blood as well as a swatch of the dress that did not?

342 MR. MARTZ:

Yes, I did.

343 MS. CLARK:

And in your testing of that swatch that did not contain, did not contain blood, do you show those results here on this graph?

344 MR. MARTZ:

Yes. The K65, I ran the dress, one that was an area that wasn't blood-stained and the other area was blood-stained.

345 MS. CLARK:

Now, you have an item there on the far left that's known as K65C?

346 MR. MARTZ:

Right.

347 MS. CLARK:

And is that the area of the dress that you tested that had no blood?

348 MR. MARTZ:

That's correct.

349 MS. CLARK:

Well, that has a higher reading it would appear than either the gate or the sock.

350 MR. MARTZ:

That's correct.

351 MS. CLARK:

And what do you attribute that to?

352 MR. MARTZ:

Well, I attribute it to the possibility that EDTA is present in the garment, either the garment or the dye that the garment is made out of.

353 MS. CLARK:

And directing your attention to the bar just to the right of that, K65, is that the swatch of the dress that did contain blood?

354 MR. MARTZ:

That's correct.

355 MS. CLARK:

Is it your information it contained her blood?

356 MR. MARTZ:

That's correct.

357 MS. CLARK:

Is that--does that bar appear to be higher to you than the bar that shows the testing of the swatch from her dress that was not blood-stained?

358 MR. MARTZ:

It's slightly higher.

359 MS. CLARK:

To what do you attribute that?

360 MR. MARTZ:

Well, I mean, it could be attributed to anything. I mean the instrumental technique, the way that I've set it up cannot distinguish between peaks of that height. I--I really didn't attribute it to anything.

361 MS. CLARK:

Okay. Based on the methods that you were using, it was your determination--you had to make the determination as to whether or not the blood in the evidence came from a test tube with EDTA or not, correct?

362 MR. MARTZ:

That's correct.

363 MS. CLARK:

And in that regard, the method you used, was it effective and efficient for that determination even though it did not permit precise quantification?

364 MR. MARTZ:

Yes, it was. I mean, in all the charts that I prepared and all the tests, I could clearly distinguish between preserved and nonpreserved blood. On two of the days, the testing in the negative ion mode, which required EDTA, the complex with iron, I got no signal whatsoever for EDTA. And again, on the 28th, when I performed liquid chromatography by itself, which EDTA had to bind with a copper compound, I received no signal for the EDTA. It was very easy to distinguish between the preserved and the nonpreserved blood.

365 MS. CLARK:

Can you tell us, sir, whether or not you confirmed with the full daughter spectrum on the dress?

366 MR. MARTZ:

The dress I was able to get pretty much what I call sufficient daughter spectrum, and I think I dictated as traces of EDTA were indicated on the dress.

367 MS. CLARK:

And was that the dress with the blood or without the blood or both?

368 MR. MARTZ:

I can't remember which one I ran. I would have only run one of the daughters. I don't remember right now which one it was.

369 MS. CLARK:

You don't remember which evidence stain you ran it on, whether it was the dress with the blood or without the blood?

370 MR. MARTZ:

That's correct.

371 MS. CLARK:

But on one of them at least, you obtained the full daughter spectrum?

372 MR. MARTZ:

That's correct.

373 MS. CLARK:

And what is the significance of that to you?

374 MR. MARTZ:

Well, the significance is that levels of EDTA that are used in manufacturing can be identified with the procedure that I used.

375 MS. CLARK:

So you do I--now, has anyone--no. Strike that. You do then identify EDTA as present on the dress Miss Brown was found in?

376 MR. MARTZ:

I think what I used was the term "Detected." The daughter spectrum wasn't the best. I could expect a little better spectrum, but in my opinion, it is EDTA on the dress.

377 MS. CLARK:

As opposed to the gate and the sock?

378 MR. MARTZ:

That's correct. I did not receive any daughter spectrum at all in those two, plus I did not get results in the negative ion mode nor the results from the liquid chromatography, in my opinion, EDTA was not identified and those bloodstains did not come from preserved blood.

379 MS. CLARK:

Now, there has been much said about the variability of the quantification in the runs.

380 MR. MARTZ:

Right.

381 MS. CLARK:

From day to day. And I believe you indicated that it's true that a run will vary in quantity shown. For example, if I run a test today, it will come up a certain level. If I run that same evidence tomorrow, it will come up a different level. Is that a fair characterization?

382 MR. MARTZ:

Yes. And it can also come up a different level on the same day.

383 MS. CLARK:

If there is--now, let me ask you about that. There is one particular graph that has been shown to you by counsel, and I'll fish it out later, but it shows two runs on the same day. Do you recall that chart?

384 MR. MARTZ:

Well, I showed a multitude of runs on the same day. Yeah, I think I remember the one with two run on the same day, yes.

385 MS. CLARK:

And it showed that on one run, you showed a very low level of EDTA and on another run, a very higher--a much higher level?

386 MR. MARTZ:

Yes.

387 MS. CLARK:

Now, were those two runs made at the same time?

388 MR. MARTZ:

No, they were not.

389 MS. CLARK:

What divided those two runs? What came between them?

390 MR. MARTZ:

I think it was several--several hours, many hours and, you know, many runs on the instrument.

391 MS. CLARK:

Do you recall whether that was a day on which you ran as many as 30 samples?

392 MR. MARTZ:

I don't know if it was exactly 30, but it was probably at least 20 samples. I ran a significant number of samples on the 22nd.

393 MS. CLARK:

Now, sir, bearing in mind that variability, if you run all samples at the same time, will the ratio you get between their various amounts remain constant or remain reliable as a method of determining the relative amounts between them?

394 MR. MARTZ:

I don't know that I understand that question.

395 MS. CLARK:

Okay. Let me ask another one. If you--the machine varies from time to time in terms of the quantity it measures?

396 MR. MARTZ:

Right.

397 MS. CLARK:

Does that have to do with the column getting--losing sensitivity?

398 MR. MARTZ:

Well, it's more the mass spectrometer becoming dirty. The column, because of interference, it can widen the peak and sometimes you can lose signal. But it's a very complex system. There's many reasons the signal can be reduced.

399 MS. CLARK:

Be that as it may, if you run all the samples at the same time that you are attempting to compare, they're all going to be either depressed or heightened to the same degree?

400 MR. MARTZ:

Generally throughout the day, the--the runs would depress.

401 MS. CLARK:

But what I'm getting at is a little different, sir. Would it be valid in your opinion, would it be appropriate to compare an item run in the morning with a different item run later in the day for their relative amounts of EDTA?

402 MR. MARTZ:

Well, I mean, it depends on the amounts that we're looking at. If we're looking at parts per million, 1 part versus 2,000, you can certainly differentiate those types of analysis. If you tried to run 49 parts per million versus 50 parts per million, you couldn't differentiate those types of analysis.

403 MS. CLARK:

Let me see if I can make my question a little clearer. If I take--let's say you took that gate stain and you ran it today.

404 MR. MARTZ:

Right.

405 MS. CLARK:

And you come up with 2 or 3 parts per million, and then you run it tomorrow and you come up with only 1 part per million. When you run it today and you come up with 2 or 3 parts per million and you want to compare it to a known reference sample and you run them at the same time, you know, one right after another, is that ratio that you get reliable, in other words, one being a hundred times more than the other?

406 MR. MARTZ:

Well, I mean, it can be. I don't understand the question totally, but you certainly can do comparisons with ratios on the mass spectrometer.

407 MS. CLARK:

I think what I'm getting at, sir, is, you--the--Mr. Blasier talked a lot about the variability of the quantification.

408 MR. MARTZ:

Right.

409 MS. CLARK:

From day to day.

410 MR. MARTZ:

Right.

411 MS. CLARK:

Does that affect the reliability of your results?

412 MR. MARTZ:

Not in this particular case, no.

413 MS. CLARK:

Why not?

414 MR. MARTZ:

Because the difference between 1 part per million and a thousand parts per million, the instrument can very easily distinguish those differences. We were talking on one day a magnitude of 4, and between 1 part per million and a thousand parts per million, we have a magnitude of a thousand. So it's very easy to differentiate those types of differences.

KEY QUOTE
415 MS. CLARK:

No matter when you compare them or when you run them?

416 MR. MARTZ:

Well, I mean, you'd want to run them on the same day.

417 MS. CLARK:

And why is that?

418 MR. MARTZ:

Because instruments do change over time. You don't know who else used the instrument. They do have electronics that have to be adjusted. You can compensate by running a standard to get the same signal, but you generally would want to compare samples run on the same day.

419 MS. CLARK:

And when you compare samples run on the same day, do you have a valid comparison between the amounts? In other words, does it give you an accurate assessment in relative terms as to a large amount versus a small amount?

420 MR. MARTZ:

Yes, it does.

421 MS. CLARK:

As is depicted in this graph?

422 MR. MARTZ:

That's correct.

423 MS. CLARK:

Now, you indicated that you also did testing on A--another form of chromatography. Was that the high pressure--

424 MR. MARTZ:

Liquid chromatograph, yes.

425 MS. CLARK:

Liquid chromatograph?

426 MR. MARTZ:

Right.

427 MS. CLARK:

And did you generate graphs for that?

428 MR. MARTZ:

Yes, I did.

429 MS. CLARK:

And was that done on the 23rd of February?

430 MR. MARTZ:

That is correct, yes.

431 MS. CLARK:

Now, as a result of these tests, the high--high pressure? High pressure liquid or high-power?

432 MR. MARTZ:

Well, you can call it high pressure or high performance. They've both been used.

433 MS. CLARK:

As a result of this second--this third test, the results of this third test told you what with respect to the question you were asked as to whether or not the blood on the rear gate and on the sock could have come from an EDTA tube?

434 MR. MARTZ:

I got the same results that I got the other two days. The stains in question from the gate and the sock did not come from preserved--EDTA preserved blood.

435 MS. CLARK:

Now, I'm going to show you the graphs that were generated as a result of those tests.

436 MS. CLARK:

On People's 546, your Honor, I'm going to label A, B and C and et cetera.

437 THE COURT:

Yes.

438 (Peo's 546-A through D for id = graphs)
439 MS. CLARK:

Showing you first 546-A, this is the HPLC?

440 MR. MARTZ:

That's the better way--

441 MS. CLARK:

Is that right?

442 MR. MARTZ:

Yes.

443 MS. CLARK:

For--for the evidence of the gate stain, that would be 204?

444 MR. MARTZ:

That's correct.

445 MS. CLARK:

Can you tell us what we see here, sir?

446 MR. MARTZ:

Well, you can see the peak from the injection and no other peaks were detected.

447 MS. CLARK:

All right. And then I'm going to show you--and what does that indicate, sir, that no other peaks were detected?

448 MR. MARTZ:

Well, on this particular case, no EDTA was present.

449 MS. CLARK:

None at all?

450 MR. MARTZ:

None.

451 MS. CLARK:

And now I'm going to show you People's 546-B, and this is your testing of the evidence blood from the sock on February 23rd. Can you tell us what does this graph indicate to you?

452 MR. MARTZ:

Again, this is the injection and that's the solvent coming out and no other peaks were identified. That large peak is the solvent peak.

453 MS. CLARK:

Which means?

454 MR. MARTZ:

That no EDTA was present or identified in the sample.

455 MS. CLARK:

Okay. Now, I'm going to show you, sir, a graph run on the reference blood of Nicole brown, People's 546-C? Am I at C? 546-C. Okay. This is the testing on the reference blood from Nicole brown. And would you tell us whether or not, based on these results, you would determine and conclude that EDTA from preserved blood is present?

456 MR. MARTZ:

Well, from this test alone, I wouldn't conclude that. But certainly, there's indication that EDTA is present.

457 MS. CLARK:

And showing you 546-D, this is the testing of the reference blood of--taken from the test tube for Mr. Simpson. Can you tell us what the results indicate to you in this test?

458 MR. MARTZ:

Again, the peak at the end is indicating that EDTA could be present in the sample.

459 MS. CLARK:

Could be?

460 MR. MARTZ:

Right. I mean, this is just a preliminary test by itself.

461 MS. CLARK:

In this case, sir, having already conducted the negative ion mode and then the positive ion mode test and forming a conclusion that EDTA from preserved blood was not present in the evidence stains on previous dates, did this test operate, this HPLC test operate to confirm or corroborate those conclusions?

462 MR. MARTZ:

Yes. This corroborated the fact that EDTA is present in the preserved blood.

463 MS. CLARK:

And not present in the evidence?

464 MR. MARTZ:

That's correct.

465 MS. CLARK:

And lastly, a chart, People's 547.

466 (Peo's 547 for id = chart)
467 MS. CLARK:

Did you have a graph prepared to depict the results obtained from the HPLC rub?

468 MR. MARTZ:

Yes, I did.

469 MS. CLARK:

And showing you this graph, sir, does this depict accurately the results you obtained on February 23rd?

470 MR. MARTZ:

Yes, it does.

471 MS. CLARK:

Could we make it a little clearer.

472 (Brief pause.)
473 MS. CLARK:

Okay. The two known reference samples from the Defendant and Miss Brown are to the far left, sir?

474 MR. MARTZ:

That's correct. That's the--the counts that represent where EDTA comes out in an area on the chromatograph run that day indicating the presence of EDTA.

475 MS. CLARK:

And the Q206 and Q204 that we see to the right of those for the sock and the rear gate indicates?

476 MR. MARTZ:

The sock and the rear gate did not give a signal or a response where EDTA would come out on those chromatograms.

477 MS. CLARK:

And then to the right of that, you have a 5 PPM, 5 parts per milligram? What's that?

478 MR. MARTZ:

5 parts per million.

479 MS. CLARK:

Million I mean. Sorry.

480 MR. MARTZ:

That's a standard of EDTA that was run on the instrument that day.

481 MS. CLARK:

And does that indicate that you can detect an amount as low as 5 parts per million?

482 MR. MARTZ:

Well, I didn't use this quantitatively. But the range would be around 5 parts per million for that sensitivity of the instrument.

483 MS. CLARK:

Then based on all of the tests that you conducted, the negative ion mode, the positive ion mode and the HPLC, were all of those tests consistent and uniform in their results?

484 MR. MARTZ:

Yes, they were.

485 MS. CLARK:

And in that regard, the result for all of those tests was?

486 MR. MARTZ:

That EDTA was present in the K67 and K68 blood samples and was not present on the sock and the gate.

Temperature

tense

Key Quotes (5)

Roger Martz
For someone to try to make this into something other than noise is totally wrong.
Martz directly attacks Dr. Rieders' interpretation of the sock graph, which the defense used to argue EDTA was present — framing the defense's expert as scientifically incompetent.
Roger Martz
These stains did not come from preserved blood.
The clearest, most direct conclusion Martz offers — the central factual dispute of the EDTA testimony. The defense theory was that blood was planted from EDTA-preserved reference tubes.
Roger Martz
Because the difference between 1 part per million and a thousand parts per million, the instrument can very easily distinguish those differences. We were talking on one day a magnitude of 4, and between 1 part per million and a thousand parts per million, we have a magnitude of a thousand.
Martz rebuts Blasier's cross-examination attack on quantification variability, arguing the magnitude of difference between evidence and preserved blood is so large that day-to-day instrument variability is irrelevant.
Marcia Clark
In your opinion then, is his--scientifically speaking, was it scientifically and forensically inappropriate for Dr. Rieders to have interpreted this graph in the manner that he did?
Clark elicits a direct professional criticism of the defense's expert, a key rehabilitation goal of redirect.
Roger Martz
In my opinion, it was, yes.
One-line confirmation that the defense expert acted outside the bounds of proper forensic science — highly damaging to the defense's EDTA theory.

Evidence (8)

People's 543-A through D
Four graphs depicting LC-MS/MS testing of Q206 (sock evidence blood) in positive ion mode, showing attempted detection of 160 daughter ion and full daughter spectrum, plus known EDTA control samples on sock
introduced, interpreted by Martz to show no EDTA daughter spectrum in evidence blood
People's 544-A through D
Four graphs depicting LC-MS/MS testing of Q204 (rear gate blood) in positive ion mode, plus known EDTA control (K68, Simpson's reference blood) on cotton swatch
introduced, interpreted by Martz to show no full daughter spectrum in rear gate evidence blood but clear signal in known preserved blood
People's 545
Summary comparison bar chart of all February 22nd LC-MS/MS results, including K67, K68 reference samples, sock (Q206), gate (Q204), and Nicole Brown's dress (K65)
introduced, used by Martz to visually demonstrate magnitude difference between preserved and non-preserved blood EDTA response
People's 546-A through D
HPLC (high performance liquid chromatography) graphs from February 23rd testing of gate stain (Q204), sock stain (Q206), Nicole Brown reference blood, and Simpson reference blood
introduced, corroborated earlier LC-MS/MS findings — no EDTA detected in evidence stains
People's 547
Summary bar chart of HPLC results from February 23rd showing all samples and a 5 PPM EDTA standard
introduced, used to visually summarize third round of testing confirming absence of EDTA in evidence
Informal
Dr. Martz's own blood, tested with and without EDTA added, to establish baseline and validate extraction methods
discussed; graphs previously turned over to defense
+ 2 more

Notable Exchanges (4)

Marcia ClarkRoger Martz
Extended walk-through of the 543 and 544 graph series in which Clark systematically contrasts the flat noise of the evidence blood samples against the sharp, unmistakable peaks of the known EDTA-preserved reference samples. The visual contrast is the prosecution's core rebuttal to the defense's blood-planting theory.
strategic
Marcia ClarkRoger Martz
Clark elicits Martz's step-by-step explanation of how his LC-MS/MS machine works — columns, capillaries, 4,000-volt ionization, triple quadrupole collision chamber — to establish that the machine's lack of chromatographic separation (the 'dead volume' issue) means retention time cannot be used as an identification factor, directly undercutting Rieders' methodology.
strategic
Marcia ClarkRoger Martz
Clark addresses Blasier's cross-examination attack on day-to-day quantification variability. Martz explains that since the difference between evidence blood and preserved blood is a factor of 1,000 (not 2 or 3), instrument variability is irrelevant to the conclusion.
rehabilitative
Marcia ClarkRoger Martz
Clark asks whether Martz refused to cooperate with Blasier prior to trial; Martz confirms he met with Blasier in Washington D.C., spoke on the phone, and answered all questions, preemptively neutralizing any suggestion of prosecution stonewalling.
strategic

Light Moments (2)

Marcia Clark / Roger Martz
Clark asks whether the capillary hole in the LC-MS/MS machine is small, and Martz responds dryly: 'It's a very small hole.' Clark had offered: 'Probably smaller than I can make, right?'
Marcia Clark
Clark repeatedly conflates 'parts per milligram' and 'parts per million,' catches herself, and Martz gently corrects: 'Parts per million.' Occurs twice.

Credibility Attacks (1)

⚔ Dr. Fredric Rieders
expert disagreement / methodology attack
Martz testifies that Rieders' interpretation of the sock graph — reading electrical noise as EDTA signal — was 'totally wrong' and 'scientifically and forensically inappropriate.' He notes Rieders works on GC-MS, has never operated an electrospray instrument, and therefore would not know that retention time is meaningless in Martz's machine. Clark asks directly whether it was inappropriate for Rieders to interpret the graph as he did; Martz answers: 'In my opinion, it was, yes.'

Witness Demeanor

(Brief pause.) — noted twice during exhibit transitions
(Discussion held off the record between the Deputy District Attorney and Defense counsel.) — before sock graph presentation

Objections

None recorded
Proceeding 7015 • 486 utterances • Defense witness
Criminal Trial
Department 103
⚖️ Start
📂 JUL 25, 1995 📄 Cross-examination of Roger Mar
JUL 25, 1995 KRT DvH TD