Redirect examination of Roger Martz (afternoon, part 1)

📄 Redirect examination of Roger Martz (afternoon, part 1) — Wednesday, July 26, 1995

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C:\DEPT103\CRIMINAL\1995\JUL\26\REDIRECT-EXAMINATION-OF-ROGER-.DOC

TRIAL

▲ Day 122 of 167

◀ Jury returns Sidebar: blood spot photographs ▶

Witness: Roger Martz
Examiner: Robert Blasier
Called by: Defense • Date: Wednesday, July 26, 1995 • Utterances: 256

Defense attorney Robert Blasier conducts a withering redirect of FBI forensic chemist Roger Martz, attacking his EDTA testing methodology on multiple fronts: a mislabeled sample he had to pencil-correct, the destruction of raw mass spectrometry data for the gate and sock stains, and his unscientific 'eyeball' approach to quantifying blood samples. The examination reaches a memorable low point when Martz cannot recall the value of pi — prompting Judge Ito to interject — undermining his credibility as a scientific expert.

# 1 THE COURT:

All right. Thank you, ladies and gentlemen. Please be seated. Agent Martz, would you resume the witness stand, please. And Mr. Blasier, you may continue with your redirect examination.

# 2 MR. BLASIER:

Thank you, your Honor.

# 3 MR. BLASIER:

Agent Martz, in your opinion is it appropriate to compare ion counts from one sample to ion counts from another sample to draw some conclusion as to whether one has more EDTA than the other?

# 4 MR. MARTZ:

Certainly you can do that if it is a large difference. If you are trying to differentiate 99 from a hundred, no, you can't do that, but if you are trying to differentiate one from a thousand you can do that, yes.

# 5 MR. BLASIER:

How about with--is there a difference of ten times, ten times the ion count from one, ten times--ten times higher on the other?

# 6 MR. MARTZ:

Well, I mean it would depend on the day, the circumstances, the chemicals being analyzed. There is a lot of variation depending on what you are doing.

# 7 MR. BLASIER:

Now, you tested your own blood both on May 11th and on July 22nd, did you not?

# 8 MR. MARTZ:

That's correct.

# 9 MR. BLASIER:

What was your ion count for your own blood in the red-topped tube on May 11th?

# 10 MR. MARTZ:

54,946.

# 11 MR. BLASIER:

54,000?

# 12 MR. MARTZ:

Yes.

# 13 MR. BLASIER:

What was it on July 22nd?

# 14 MR. MARTZ:

64,882.

# 15 MR. BLASIER:

Now, you were shown three charts indicating your results on your own blood with and without EDTA from May 11th, were you not? Miss. Clark showed you that this afternoon?

# 16 MR. MARTZ:

Yes.

# 17 MR. BLASIER:

And there was another chart that is a record of another test that you did on your own blood at the same time, isn't there?

# 18 MR. MARTZ:

Well, May 11th?

# 19 MR. BLASIER:

Uh-huh.

# 20 MR. MARTZ:

Yes.

# 21 MR. BLASIER:

May I have this marked next?

# 22 THE COURT:

1272.

# 23 (Deft's 1272 for id = chart)

# 24 MR. BLASIER:

Let me show you what is 1272, Defense, and tell me if that is the chart that Miss Clark didn't show you?

# 25 (No audible response.)

# 26 MR. BLASIER:

Didn't show the jury?

# 27 MR. MARTZ:

That one there?

# 28 MR. BLASIER:

Yes.

# 29 MR. MARTZ:

I don't know if she did or not.

# 30 MR. BLASIER:

Do you remember seeing that displayed to the jury today?

# 31 MR. MARTZ:

No, I don't. I don't think I did.

# 32 MR. BLASIER:

I would like to put this on the elmo, please.

# 33 MR. BLASIER:

Who tells the computer what sample it is looking at or the mass spec machine?

# 34 MR. MARTZ:

I--in this particular case I did.

# 35 MR. BLASIER:

Okay. Could we zoom in on the top left corner.

# 36 MR. BLASIER:

Would you agree that when that chart was printed out it was printed out as "Operator blood, no EDTA added, red top"?

# 37 MR. MARTZ:

Right.

# 38 MR. BLASIER:

That has been changed, hasn't it?

# 39 MR. MARTZ:

Yes.

# 40 MR. BLASIER:

And you wrote that it was some other sample in later, didn't you?

# 41 MR. MARTZ:

That's correct.

# 42 MR. BLASIER:

That was a sample mix-up, wasn't it?

# 43 MR. MARTZ:

No.

# 44 MR. BLASIER:

It was a mistake, wasn't it?

# 45 MR. MARTZ:

If you look at the previous chart which is EDTA 583, that was the previous run and that that is operator's blood, no EDTA added. The next run I didn't change the label and after the computer has acquired that data it is too late to change the label, so I penciled it in.

# 46 MR. BLASIER:

That was a mistake, wasn't it?

# 47 MR. MARTZ:

I don't know if I would call it a mistake. I just wasn't paying attention. I guess you could call it a mistake.

# 48 MR. BLASIER:

Did you check the sample afterwards to make sure that you had labeled it properly when you had changed the label?

# 49 MR. MARTZ:

Well, I knew that is the sample that I had run. I just didn't label it properly.

# 50 MR. BLASIER:

You knew at the time that you hadn't labeled it properly?

# 51 MR. MARTZ:

After the run I did.

# 52 MR. BLASIER:

And you knew after the run because you just looked at the chart?

# 53 MR. MARTZ:

No, that is not true at all.

# 54 MR. BLASIER:

How did you figure it out?

# 55 MR. MARTZ:

Because I knew which sample I ran. I told you, you label the chart. I changed the run number. You have to change--after you change the run number it doesn't automatically change the sample. You have to change that always. In this case I didn't change the sample.

# 56 MR. BLASIER:

What was the time difference between that run and the one right before it?

# 57 MR. MARTZ:

Umm, three minutes.

# 58 MR. BLASIER:

And you changed the labels each three minutes as they are going through the system?

# 59 MR. MARTZ:

Yes. You know, there is a lot to do in that three minutes, and I made a mistake in that three-minute time period.

# 60 MR. BLASIER:

Now, yesterday you were asked questions about the dress. Do you remember that?

# 61 MR. MARTZ:

Yes.

# 62 MR. BLASIER:

And you said that you detected EDTA on the dress?

# 63 MR. MARTZ:

That's correct.

# 64 MR. BLASIER:

And the difference between the EDTA or the EDTA like substance on the dress and the evidence was the presence of the 132 ion, correct?

# 65 MR. MARTZ:

Well, I got the full daughter spectrum, yes. The 132 is part of the full daughter.

# 66 MR. BLASIER:

And you indicated I believe yesterday that you would not identify the 132 daughter ion unless its signal was three times higher than the noise. Do you remember that?

# 67 MR. MARTZ:

Umm, I said that is what people like to look for, three times the noise, for identification of a signal, yes.

# 68 MR. BLASIER:

May I mark another chart?

# 69 THE COURT:

Yes. Defense 1272.

# 70 (Deft's 1273 for id = chart)

# 71 (Discussion held off the record between the Deputy District Attorneys.)

# 72 THE COURT:

And what is it, Mr. Blasier?

# 73 MR. BLASIER:

This is a chart labeled "Control for dress for K65 dress."

# 74 THE COURT:

Thank you.

# 75 (Brief pause.)

# 76 THE COURT:

Mrs. Robertson, 1272.

# 77 MR. BLASIER:

Agent Martz, let me show you 1272 and ask is the full daughter spectrum--the full spectrum for the control for the dress?

# 78 MR. MARTZ:

Yes, it is.

# 79 MR. BLASIER:

May I show this on the elmo, please?

# 80 THE COURT:

Yes.

# 81 MR. BLASIER:

Agent Martz, do you see numerous spikes--let me cover up the top part to illustrate this--in the bottom area going all the way along the bottom axis?

# 82 MR. MARTZ:

Yes.

# 83 MR. BLASIER:

Is that noise?

# 84 MR. MARTZ:

Yes.

# 85 MR. BLASIER:

Now, let's look at the 132 ion. It is not much higher than the noise, is it?

# 86 MR. MARTZ:

No, it is not.

# 87 MR. BLASIER:

So your standard of three times, you didn't apply it here?

# 88 MR. MARTZ:

Well, if you remember, in my report I said it was detected. I did not identify EDTA in the sample and that is why I said it was detected and not identified. I used that because I wasn't comfortable identifying it to the exclusion of all other chemicals, but I thought I had enough there to say it was detected.

# 89 MR. BLASIER:

You testified here that you believe that is EDTA, correct?

# 90 MR. MARTZ:

I believe it probably is.

# 91 MR. BLASIER:

And the reason that you will not say that the evidence is EDTA is because you couldn't identify the daughter spectrum, right?

# 92 MR. MARTZ:

Yes.

# 93 MR. BLASIER:

All right. Let's compare this to the full spectrum that you did on the gate stain. Do you have that chart with you?

# 94 (No audible response.)

# 95 MR. BLASIER:

The chart that corresponds to this chart that is on the screen?

# 96 (Brief pause.)

# 97 MR. MARTZ:

I don't have the one that corresponds to that because there was no spectrum to print out.

# 98 MR. BLASIER:

Let's look at the one for the sock that corresponds to this chart for the dress.

# 99 MR. MARTZ:

I don't have that one also because there was no spectrum to print out.

# 100 MR. BLASIER:

So you didn't print out any results at all like you did for the dress?

# 101 MR. MARTZ:

No, there was nothing to print out.

# 102 MR. BLASIER:

So--and that data has been destroyed, hasn't it?

# 103 MR. MARTZ:

Yes.

# 104 MR. BLASIER:

So we cannot look at your chart that you did on the back gate and the sock to see whether the 132 ion is really there, can we?

# 105 MR. MARTZ:

Yes. You can look at the RICs that I employed.

KEY QUOTE

# 106 MR. BLASIER:

With a chart like this, this is a full spectrum, isn't it?

# 107 MR. MARTZ:

Yes, it is.

# 108 MR. BLASIER:

We don't have a chart like this for the gate or the sock, do we, because you destroyed the data and you never printed out the report?

# 109 MR. MARTZ:

I looked at the chromatogram and it does not show EDTA and I didn't print it out. There was nothing to print out. It was all noise.

# 110 MR. BLASIER:

But you have nothing to show us that demonstrates that?

# 111 MR. MARTZ:

Yes, I do. I have the RIC chromatogram which shows that that there is no signal.

# 112 MR. BLASIER:

That is the one that shows that the 160 disappeared also?

# 113 MR. MARTZ:

If you look back, I probably have the RIC for the gate. Let's see if I have it.

# 114 MR. BLASIER:

You don't want to admit that there is EDTA on the back gate and the sock because it hurts the Prosecution, do you?

# 115 THE COURT:

Sustained. The question and answer is stricken. The jury is to disregard it as argumentative.

# 116 MR. BLASIER:

Now, Agent Martz, you testified that your basis for estimating the quantity of blood in the evidence that you started with was looking at it, correct?

# 117 MR. MARTZ:

Yes.

# 118 MR. BLASIER:

You did no analytical method whatsoever to try and quantify the amount of blood that you started with in the evidence?

# 119 MR. MARTZ:

I believe I answered this question yesterday and I will give the same answer. I looked at the stain. It was consistent with blood undiluted. I cut out the stain and then I extract it with water. I looked at the water extract. They had similar colors. And I will do a presumptive test, phenolphthalein, which gave similar responses.

# 120 MR. BLASIER:

You didn't use any analytical tests that are designed to determine quantity, other than looking at it, did you?

# 121 MR. MARTZ:

I believe I just answered that question.

# 122 MR. BLASIER:

Okay. Now, you made an estimate of--now, incidentally, have you ever tested your ability to measure quantities of blood by looking at it?

# 123 MR. MARTZ:

I think I did in this particular case. I mean, if you look at my controls that I ran on the samples, I got fairly similar results.

# 124 MR. BLASIER:

Have you ever done a blind study where you don't know how much blood there is and you are tested on your ability to recognize and quantify blood by just looking at it?

# 125 MR. MARTZ:

No.

# 126 MR. BLASIER:

Is there any textbook, any chemistry textbook that you have ever looked at or seen that recommends as a valid way of quantifying something for analytical purposes to just look at it?

# 127 MR. MARTZ:

Oh, I don't know specifically if there is or not, no.

# 128 MR. BLASIER:

Now, one of the calculations that you made here had to do with what is the biggest swatch we need to detect EDTA blood. Let's assume EDTA blood is on it and that is the biggest swatch we need to detect, right?

# 129 MR. MARTZ:

That's correct.

# 130 MR. BLASIER:

It would be very unfair if you ran a sample of the evidence stains that was around or smaller than what you knew to be the minimum detectable amount, right?

# 131 MR. MARTZ:

Yes.

# 132 MR. BLASIER:

Now, I would like to use the paper chart back there.

# 133 (Brief pause.)

# 134 MR. BLASIER:

Agent Martz, you can step down if you like.

# 135 (Witness complies.)

# 136 THE COURT:

Can everybody see?

# 137 THE COURT:

The problem is juror no. 7 I don't think can see that because of the angle.

# 138 MR. BLASIER:

All right.

# 139 THE COURT:

And 165 may not be able to see it because of the height.

# 140 JUROR NO. 165:

I can see it.

# 141 THE COURT:

You can see it?

# 142 JUROR NO. 165:

Yes.

# 143 THE COURT:

Thank you, sir.

# 144 (Brief pause.)

# 145 THE COURT:

Mr. Blasier.

# 146 MR. BLASIER:

Now, Agent Martz, you determined the minimum size of a swatch that you needed to use to detect blood with EDTA in it as one square millimeter, correct?

# 147 MR. MARTZ:

That is based on negative ion results.

# 148 MR. BLASIER:

Okay. And would you tell us how you arrived at that calculation?

# 149 MR. MARTZ:

I took cuttings of different sizes of swatches and I was able to draw a photograph and calculate that that would be the minimum size needed.

# 150 MR. BLASIER:

Well, you made a--you put ten microliters of blood on some cloth material, did you not?

# 151 MR. MARTZ:

Yes.

# 152 MR. BLASIER:

And you measured the diameter--I'm sorry, the radius--the diameter of that, did you not?

# 153 MR. MARTZ:

That's correct.

# 154 MR. BLASIER:

Could you draw, not to scale obviously, a circle?

# 155 (Witness complies.)

# 156 MR. BLASIER:

That represents the ten microliters of blood that you--

# 157 MR. MARTZ:

Okay.

# 158 MR. BLASIER:

Did to determine your minimum detectable amount--

# 159 MR. MARTZ:

Right.

# 160 MR. BLASIER:

--that is ten microliters of blood? Did you want to write ten microliters of blood?

# 161 MR. MARTZ:

I think it is probably five is what I used.

# 162 MR. BLASIER:

Do you want to look at your notes?

# 163 MR. MARTZ:

I think for cutting this out I used five microliters.

# 164 MR. BLASIER:

Well, I want you to be accurate. Would you look at your notes.

# 165 (Witness complies.)

# 166 MR. BLASIER:

You are right. I think you are right; five microliters.

# 167 MR. BLASIER:

And you found that five microliters of blood gave you a spot that was how big?

# 168 MR. MARTZ:

Well, I had pictures of it. I can't remember.

# 169 MR. BLASIER:

Do you want to look at your notes?

# 170 MR. MARTZ:

Is it in there?

# 171 MR. BLASIER:

What was the diameter?

# 172 MR. MARTZ:

About five milliliters.

# 173 MR. BLASIER:

Okay. Do you want to draw a line that represents the diameter and write "Five milliliters."

# 174 (Witness complies.)

# 175 MR. BLASIER:

Okay. Now, below that I want you to draw a little square that represents a swatch. Way below it.

# 176 (Witness complies.)

# 177 MR. BLASIER:

There you go. Thank you. Well, we wanted a square one. You determined that you needed a square one millimeter on each side?

# 178 MR. MARTZ:

Right.

# 179 MR. BLASIER:

Right?

# 180 MR. MARTZ:

Okay.

# 181 MR. BLASIER:

Now--and you had previously determined by other tests that you needed not only a swatch one millimeter on the side, but .5 microliters of blood as the minimum detectable blood, correct?

# 182 MR. MARTZ:

Based on negative ion. On positive ion it would be one/tenth of that.

# 183 MR. BLASIER:

Now, put .5 microliters down by the swatch.

# 184 (Witness complies.)

# 185 MR. BLASIER:

So is it accurate that you calculated that you needed a swatch one half the size--I'm sorry--one/tenth of the size of your five-microliter circle to get a big enough swatch to have a minimum detectable amount of EDTA?

# 186 MR. MARTZ:

Based on negative ion.

# 187 MR. BLASIER:

Okay. But that is the ratio we are talking about, correct?

# 188 MR. MARTZ:

No. We were talking about positive ion there. It would be one/tenth.

# 189 MR. BLASIER:

In terms of five microliters, .5, there is a ten-fold difference?

# 190 MR. MARTZ:

Right.

# 191 MR. BLASIER:

So the area of your circle should be ten times bigger than your swatch, right?

# 192 MR. MARTZ:

Right.

# 193 MR. BLASIER:

Can you calculate the area of a circle with a five-millimeter diameter?

# 194 MR. MARTZ:

I mean I could. I don't--math--I don't--I don't know right now what it is.

# 195 MR. BLASIER:

Well, what is the formula for the area of a circle?

# 196 MR. MARTZ:

Pi r squared.

# 197 MR. BLASIER:

What is pi?

# 198 MR. MARTZ:

Boy, you are really testing me. 2.12, 2.17.

KEY QUOTE

# 199 THE COURT:

How about 3.12.14.

# 200 MR. BLASIER:

Isn't pi kind of essential to being a scientist knowing what it is?

# 201 MR. MARTZ:

I haven't used pi since I guess I was in high school.

# 202 MR. BLASIER:

Let's try 3.12.

# 203 MR. MARTZ:

Is that what it is? There is an easier way to do--

# 204 MR. BLASIER:

Let's try 3.14. And what is the radius?

# 205 MR. MARTZ:

It would be half the diameter, 2.5.

# 206 MR. BLASIER:

2.5 squared, right?

# 207 MR. MARTZ:

Right.

# 208 MR. BLASIER:

Your Honor, may we borrow a calculator?

# 209 (Brief pause.)

# 210 MR. BLASIER:

Can you use calculator?

# 211 MR. MARTZ:

Yes, I think.

# 212 MR. BLASIER:

Tell me what pi times 2.5 squared is?

# 213 MR. MARTZ:

19.

# 214 MR. BLASIER:

Do you want to write down 19?

# 215 (Witness complies.)

# 216 MR. BLASIER:

Square millimeters, right?

# 217 (No audible response.)

# 218 MR. BLASIER:

The area. What is one/tenth of that?

# 219 MR. MARTZ:

1.9.

# 220 MR. BLASIER:

You miscalculated by a factor of two, the size, the minimum size of a swatch you needed to detect EDTA, didn't you?

# 221 MR. MARTZ:

I don't know that I did or not. I calculated a little differently. I didn't use this.

# 222 MR. BLASIER:

Well, does the area change by the different method of calculation?

# 223 MR. MARTZ:

Well, this is all estimations based on my eyeball. I didn't use any scientific math to determine it. What I did was I took the circle and I divided it in half and then I divided it in half again and I just cut out a piece and that is how I did it.

# 224 MR. BLASIER:

So when you say in your report that you determined that you needed a square one millimeter--

# 225 MR. MARTZ:

I said approximately. This is all approximate.

# 226 MR. BLASIER:

Would you agree that under the conditions that you set forth in your report that one/tenth of a circle of five microliters of blood is a swatch two square millimeters, not one?

# 227 MR. MARTZ:

That is approximately right. As I mentioned before, though, in the positive ion mode it really doesn't make any difference because it would be one/tenth that.

# 228 MR. BLASIER:

Were you trying to be careful in the quantifications that you used?

# 229 MR. MARTZ:

I told you what I did, and I took small portions of it and used that to calculate how much my minimum detectable limit was.

# 230 MR. BLASIER:

You can retake the stand.

# 231 (Witness complies.)

# 232 MR. BLASIER:

Did you just say that you did this in a way that wasn't very scientific?

# 233 MR. MARTZ:

Well, I don't know if--what the definition of "Scientific" is, but I took the circle and divided it into pieces and cut a piece out.

# 234 MR. BLASIER:

Not very scientific, is it?

# 235 MR. MARTZ:

Well, in this particular case we got to go back to the original focus, can we distinguish between preserved and non-preserved blood? We are talking a thousand-fold difference. Any imprecision that I may have had here will not affect my results.

KEY QUOTE

# 236 MR. BLASIER:

Could we have chart B.

# 237 (Brief pause.)

# 238 MR. BLASIER:

I don't remember the number.

# 239 MR. BLASIER:

1271-B. Do you remember that chart, Agent Martz?

# 240 MR. MARTZ:

Yes.

# 241 MR. BLASIER:

Does that look like a thousand-fold difference? Those are your measurements, aren't they?

# 242 MR. MARTZ:

Well, you have got to remember--

# 243 MR. BLASIER:

Agent Martz--move to strike.

# 244 MS. CLARK:

Objection, your Honor. He is an expert.

# 245 THE COURT:

He can answer the question. Ask him the question.

# 246 MR. BLASIER:

Does that appear to be a thousand-fold difference to you from your own data?

# 247 MR. MARTZ:

In that particular thing?

# 248 MR. BLASIER:

Yeah.

# 249 MR. MARTZ:

No, no.

# 250 MR. BLASIER:

Now, Agent Martz, I would like to ask you some questions about your ability to determine quantities of blood by looking at them. Okay?

# 251 MR. MARTZ:

Okay.

# 252 MR. BLASIER:

You provided me with some pictures of different spots of blood, did you not?

# 253 MR. MARTZ:

Yes, I did.

# 254 (Brief pause.)

# 255 MS. CLARK:

There will be an objection, your Honor.

# 256 THE COURT:

Side bar with the court reporter, please.

Temperature

tense

Key Quotes (5)

Roger Martz

Boy, you are really testing me. 2.12, 2.17.

Martz cannot recall the value of pi during a math exercise central to his own methodology, devastating his credibility as a forensic scientist.

Lance A. Ito

How about 3.12.14.

The judge himself corrects the FBI expert on a basic mathematical constant, an extraordinary moment that signals how badly the examination is going for the prosecution.

Roger Martz

Yes. You can look at the RICs that I employed.

Martz's only defense after admitting the full-spectrum data for the gate and sock was destroyed — pointing to a less complete record that cannot replicate what he destroyed.

Roger Martz

Well, in this particular case we got to go back to the original focus, can we distinguish between preserved and non-preserved blood? We are talking a thousand-fold difference. Any imprecision that I may have had here will not affect my results.

Martz's fallback defense after conceding his quantification was unscientific — but Blasier immediately undercuts it by showing his own chart does not reflect a thousand-fold difference.

Roger Martz

I looked at the stain. It was consistent with blood undiluted. I cut out the stain and then I extract it with water. I looked at the water extract. They had similar colors.

Martz openly admits that his primary method for quantifying blood in evidence was visual inspection of color — an admission Blasier uses to portray the entire testing regime as unscientific.

Evidence (5)

Defense 1272

Chart originally labeled 'Operator blood, no EDTA added, red top' that was subsequently corrected by hand after Martz failed to update the label between runs

Introduced by Blasier to demonstrate sample labeling error; displayed on ELMO

Defense 1273

Full daughter spectrum chart labeled 'Control for dress for K65 dress'

Introduced to show the 132 ion signal barely exceeds noise level, undermining Martz's claimed EDTA identification standard

Defense 1271-B

Chart showing Martz's ion count measurements for evidence samples

Used to challenge his claim of a thousand-fold difference between preserved and non-preserved blood

Informal

Raw mass spectrometry data (full daughter spectra) for the back gate stain and sock stain

Martz confirms this data was destroyed and never printed out; no equivalent chart exists to compare against the dress control

Informal

Martz's own blood samples tested May 11 and July 22 (red-topped tubes)

Referenced to establish baseline ion counts and variation across testing days

Notable Exchanges (4)

Robert Blasier•Roger Martz

Blasier walks Martz through a live calculation of the minimum swatch size needed to detect EDTA, revealing Martz used 'eyeball' division of a circle rather than any mathematical formula, and that his reported figure of one square millimeter was off by a factor of approximately two.

methodically devastating

Robert Blasier•Roger Martz•Lance A. Ito

Blasier asks Martz to calculate the area of a circle. Martz cannot recall the value of pi, guessing '2.12, 2.17.' Judge Ito interjects with '3.12.14' before Blasier corrects to 3.14.

darkly comic

Robert Blasier•Roger Martz

Blasier presses Martz on whether full-spectrum data exists for the gate and sock comparable to what exists for the dress. Martz confirms no such chart exists because he destroyed the raw data, saying 'there was nothing to print out.'

revealing

Robert Blasier•Roger Martz

Blasier confronts Martz with Defense 1272, a chart whose original label 'Operator blood, no EDTA added' was crossed out and hand-corrected. Martz concedes he 'wasn't paying attention' and made 'a mistake in that three-minute time period.'

uncomfortable

Light Moments (2)

Lance A. Ito

Judge Ito interjects during Blasier's math exercise to supply the value of pi — slightly garbling it as '3.12.14' — after Martz guesses wrong.

Roger Martz

Martz says he hasn't used pi 'since I guess I was in high school,' prompting Blasier to question whether knowing pi is essential to being a scientist.

Credibility Attacks (4)

⚔ Roger Martz

Prior inconsistent labeling / documentation error

Blasier introduces Defense 1272 showing Martz hand-corrected a mislabeled mass spec chart. Martz concedes he 'wasn't paying attention' and made a mistake, raising questions about the reliability of his sample tracking.

⚔ Roger Martz

Destruction of evidence / missing records

Blasier establishes that Martz never printed full daughter spectrum charts for the back gate or sock stains — comparable to what exists for the dress — and that the underlying raw data was destroyed, leaving no way to verify his conclusion that those samples showed no EDTA.

⚔ Roger Martz

Unscientific methodology

Blasier extracts admissions that Martz quantified blood amounts by visual inspection ('looking at it'), performed no blind studies to validate his eyeballing, could cite no textbook supporting visual quantification, and calculated minimum swatch sizes by physically dividing a circle rather than using mathematics — including being unable to recall the value of pi.

⚔ Roger Martz

Internal inconsistency in expert conclusions

Blasier uses Martz's own chart (1271-B) to show that his data does not actually reflect the 'thousand-fold difference' Martz claimed would make any imprecision in his methodology irrelevant.

Witness Demeanor

(Witness complies.) — repeated multiple times as Martz steps down, draws diagrams on chart paper, and returns to the stand

(No audible response.) — when shown Defense 1272 and asked if Clark had shown it to the jury

(Witness complies.) — writing down 19 square millimeters on the chart after calculator computation

Objections

3 objections (1 sustained, 1 overruled)

Proceeding 7029 • 256 utterances • Defense witness

Criminal Trial

Department 103