📄 Sidebar: witness exhibits — Wednesday, July 5, 1995
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C:\DEPT103\CRIMINAL\1995\JUL\5\SIDEBAR-WITNESS-EXHIBITS.DOC
TRIAL
▲ Day 108 of 167

Sidebar: witness exhibits

Date: Wednesday, July 5, 1995 • Utterances: 28
During a sidebar, Marcia Clark objected that F. Lee Bailey was using exhibits during cross-examination of a hair expert witness without giving her advance notice. Judge Ito clarified the rules — exhibits must be shown to opposing counsel before use, but not necessarily to the witness — and resolved the dispute by having copies made and giving both sides a moment to review. The exchange ended with light banter and laughter.
1 (The following proceedings were held at the bench:)
2 MS. CLARK:

Your Honor, I haven't been shown any of these items, and counsel is basically throwing them at the witness without even letting me see what he's doing. I thought before cross began, we were supposed to be shown exhibits which were intended for use.

3 THE COURT:

What's your objection?

4 MS. CLARK:

Objection, discovery as well as foundational as to this--he's asking to show the witness this exhibit and ask him if he's familiar with it and if he relies on it or refers to it in some manner.

5 THE COURT:

But let me ask you this, Miss Clark. Let's assume that true, we may have a 721 problem because he hasn't referred to this particular item in reaching his conclusions. This is just a listing of all the various basic and accepted characteristics of hair.

6 MS. CLARK:

Uh-huh.

7 THE COURT:

And he's going to say, "Yes, I considered all of these things with the exception of the DNA stuff."

8 MS. CLARK:

Right. I have no problem as long as he is allowed to look at it ahead of time and say--given a fair opportunity to examine the list and say, "Yes, these are the things I looked at." That's fine. But I mean, I'm not an expert, Judge, so I don't know--

9 THE COURT:

Well, counsel, you can take two minutes to look at that and you can tell that those are the basic standard hair comparison characteristics.

10 MS. CLARK:

Why don't you let the expert do that. That's all I'm saying. Have him study it enough to--

11 MR. BAILEY:

He's testified to all these things.

12 THE COURT:

I know.

13 MS. CLARK:

I'm just--

14 THE COURT:

How about if I have Mrs. Robertson step back and shoot you all a copy, give him an opportunity to look at it for a few moments. But if you look at them--I know them all. You know them all. Even Mr. Cochran knows half of them.

15 MS. CLARK:

I don't know about that. Any other exhibits counsel intends to use?

16 MR. COCHRAN:

This may be released. Take umbrage to that.

17 MS. CLARK:

I think the record should reflect this is all tongue and cheek and we're laughing. We're laughing, right, Johnnie?

KEY QUOTE
18 MR. COCHRAN:

Right.

19 MS. CLARK:

Are there any other exhibits Mr. Bailey intends to use with the witness?

20 MR. BAILEY:

There's a similar list in the book you were holding published by the FBI, which I presume won't come as a surprise to him.

21 MS. CLARK:

That will not. Anything else?

22 MR. BAILEY:

That's the only thing. Just so I understand the rules, your Honor, realizing we are winding down the cross-examination by the Defense, what are the requirements of previewing cross-examination with the opponent?

23 THE COURT:

No. If you are going to have some exhibits, we need to see them. They don't necessarily--they don't have to be shown to the witness themselves, but anything that you're going to use as a demonstrative exhibit, you need to show to counsel before we start.

24 MR. BAILEY:

That from time to time could reduce some of the value of the items.

KEY QUOTE
25 THE COURT:

Oh, I know. That's why you don't show it to the witness. Mr. Bailey, two to you, Miss Clark. And, Mr. Bailey, you can share one. Why don't you give him the book.

KEY QUOTE
26 MR. BAILEY:

I was going to give him the book.

27 THE COURT:

Okay.

28 (The following proceedings were held in open court:)

Temperature

light

Key Quotes (4)

Lance A. Ito
Even Mr. Cochran knows half of them.
A rare moment of judicial levity, prompting Cochran to take mock offense and Clark to note for the record that everyone was laughing.
Marcia Clark
I think the record should reflect this is all tongue and cheek and we're laughing. We're laughing, right, Johnnie?
Clark explicitly preserved the joking tone for the record, signaling collegiality between adversaries in a rare light moment.
F. Lee Bailey
That from time to time could reduce some of the value of the items.
Bailey candidly acknowledges the strategic value of surprise when using cross-examination exhibits — showing them in advance blunts their impact.
Lance A. Ito
Oh, I know. That's why you don't show it to the witness.
Ito draws a practical distinction: exhibits must be previewed by opposing counsel, but surprise can still be preserved by not showing them to the witness beforehand.

Evidence (2)

Informal
A list of standard hair comparison characteristics used in forensic hair analysis
Discussed; court ordered copies made and gave parties time to review before use
Informal
An FBI-published book on hair analysis containing a similar characteristics list
Flagged by Bailey as a forthcoming cross-examination exhibit; Clark indicated no objection

Notable Exchanges (2)

Lance A. ItoMarcia ClarkF. Lee Bailey
Ito clarified the pretrial exhibit disclosure rule: demonstrative exhibits must be shown to opposing counsel before use, but need not be shown to the witness in advance. Bailey accepted this, noting that advance disclosure to counsel (but not the witness) still preserves some element of surprise.
procedural
Lance A. ItoMarcia ClarkJohnnie Cochran
Ito joked that Cochran only knows half the hair characteristics; Cochran feigned umbrage; Clark put the laughter on the record explicitly.
light

Light Moments (1)

Lance A. Ito
Judge Ito quipped 'Even Mr. Cochran knows half of them,' prompting Cochran to say 'Take umbrage to that' and Clark to put the laughter on the record.

Objections

1 objections (0 sustained, 0 overruled)
Proceeding 6630 • 28 utterances
Criminal Trial
Department 103
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📂 JUL 5, 1995 📄 Sidebar: witness exhibits
JUL 5, 1995 KRT DvH TD