📄 Administrative matters: discovery — Monday, June 26, 1995
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C:\DEPT103\CRIMINAL\1995\JUN\26\ADMINISTRATIVE-MATTERS-DISCOVE.DOC
TRIAL
▲ Day 103 of 167

Administrative matters: discovery

Date: Monday, June 26, 1995 • Utterances: 81
Between witnesses, the court handles two disputes: the defense requests Dr. Weir's DNA statistics computer program to independently verify his calculations, which the judge denies while ordering the underlying data produced by end of day. Defense counsel Blasier also raises a late discovery objection over 33 pages of new materials — including a first-time report from upcoming witness Denise Lewis and handwritten notes from Susan Brockbank — and a chain-of-custody chart not previously disclosed. The parties sort out that Lewis can proceed immediately while Brockbank's examination will be deferred.
1 THE COURT:

All right. Dr. Weir, thank you very much, sir. You are excused. All right. Ladies and gentlemen, I think we're going to switch to a different witness at this point. I'm going to ask you to step back into the jury room. We need to change some exhibits and things, and we'll have you back out here as soon as we're ready to go.

2 (The following proceedings were held in open court, out of the presence of the jury:)
3 THE COURT:

All right. Let the record reflect that the jury has withdrawn from the courtroom. Counsel, what's your pleasure? Who is your next witness, Miss Clark?

4 MS. CLARK:

Miss Lewis.

5 THE COURT:

Is she available?

6 MS. CLARK:

Yes.

7 MR. SCHECK:

I think Mr. Bailey and Mr. Blasier are looking at charts.

8 MR. NEUFELD:

Your Honor, I have one application to make as well, which is that--Dr. Weir is still here. I hope he is. Well--

9 THE COURT:

Yes.

10 MR. NEUFELD:

Good. Dr. Weir furnished us with a few hundred pages of tables for the pairings for the two and three contributor assumptions to the data in this case, and he didn't give us the tables and hard copy for the four because he just said it was too voluminous. And I certainly accept that. In order though for our own experts to independently evaluate his calculations and what he's done here, what we would like to have and what we need to have is simply a copy of his computer program because I believe we already have the data of the frequencies; and I would simply ask the Court to ask the Prosecution to simply have Dr. Weir make a copy of that program available so our experts could independently evaluate it prior to their taking the witness stand in this case.

11 MR. CLARKE:

We have no opposition providing the Defense the data itself, but I don't feel that Dr. Weir has to provide everything in his laboratory that relates to this type of matter. In other words, not the program.

12 MR. NEUFELD:

It's not everything. It's just that there's no way we can check his numbers unless we have his program. That's the whole point. I'm not asking for everything in his laboratory. He has a computer program.

13 THE COURT:

I'm sure it is a proprietary program though.

14 MR. NEUFELD:

I'll put it under protective order, your Honor. We will not let anybody else see it or expose it to anybody. And if we give it to one or two of our experts to evaluate, they too can sign a protective order if that's the concern. Other than that, since he relied on that computer program to generate this data, we're entitled to it. I'm not asking him to create something that doesn't exist. He already has the program.

15 MR. CLARKE:

They are welcome to the data, your Honor, but I don't think there's any basis to order somebody to turn over a program and how to interpret the data. If they have the data, then the Defense expert can interpret it just as well.

16 THE COURT:

All right. When can you have that date available?

17 DR. WEIR:

In just a few hours. Soon. Today.

18 THE COURT:

All right.

19 MR. NEUFELD:

The data is inadequate for our experts to determine whether or not he in fact conveyed these or did his calculations properly. His calculations are predicated on his computer program. The only way we'll know if he did it right is to at least rely on the same computer program. It can't be done any other way.

20 THE COURT:

Have the data valuable tomorrow.

21 MR. CLARKE:

Very well.

22 THE COURT:

The request for the computer program itself is denied. All right. Next witness. Mr. Blasier, good afternoon.

23 MR. BLASIER:

Good afternoon, your Honor. Before we do the next witness--I'm assuming we are getting into hair and trace evidence--we were just presented with I think 33 pages of new discovery on the next two witnesses. One is a five-page typed report from the first witness we had nothing from before. The rest of it are handwritten notes by Susan Brockbank, which we have other material from her. This is new material. We object to the late discovery. There is also a large board that they want to use that we've never seen before until just now. It has a lot of chain of custody information on it. It may be perfectly fine, but we haven't had a chance at look at it. I've reviewed Miss Lewis' report. I'm prepared to go ahead with her today. I am not prepared to go ahead with Miss Brockbank. Her handwritten notes, I have to sit down and go through them and correlate them to her old notes before I am prepared to cross-examine her. So we need some time to look at their chart before we can start with--and anything else that they might want to use with this first witness.

24 THE COURT:

All right. Mr. Fairtlough, is this the chart?

25 MR. FAIRTLOUGH:

Yes, your Honor.

26 THE COURT:

All right. Why don't you bring that up. Why don't you just lean it up against the jury rail there, please. All right. Mr. Blasier, you want to take a look at that and see what your concerns are?

27 MR. BLASIER:

Well, I don't have all these dates in my head, your Honor. I can't--

28 THE COURT:

No. I mean, just wanted to know what the nature of your objection--or you said you hadn't had a chance to look at it.

29 MR. BLASIER:

Correct. I haven't had a chance to correlate the numbers and the dates. They sent us one other chart on exemplars which we're prepared to stipulate to that did have dates on. We could cross-compare those. But there's a lot of information on this chart and we just haven't had a lot of time to absorb it. We've had a couple of minutes.

30 THE COURT:

Well, how much time do you need, Mr. Blasier?

31 MR. BLASIER:

I don't know how many items they're going to cover with Miss Lewis. Do you know, Miss Clark?

32 MS. CLARK:

Uh-huh. We'll do the--it will be basically all the knowns.

33 MR. BAILEY:

Exemplars?

34 MS. CLARK:

Exactly. It will be--not all the knowns obviously. Just the items that came from the Coroner's office, item 73, 79, 81, 83, 86--

35 THE COURT:

And 122?

36 MS. CLARK:

That's it on that board.

37 THE COURT:

What about 122?

38 MS. CLARK:

No. That doesn't pertain to Miss Lewis, your Honor.

39 THE COURT:

All right. That's all you're going to cover with this witness?

40 MS. CLARK:

That's correct.

41 THE COURT:

Mr. Blasier?

42 MR. BLASIER:

May I have a moment, your Honor?

43 THE COURT:

Sure.

44 (Discussion held off the record between Defense counsel.)
45 THE COURT:

And I take it Miss Lewis is readily available?

46 MS. CLARK:

Yes. With respect to the records that Mr. Blasier referred to, your Honor, he got them as soon as I got them. I haven't even read Susan Brockbank's notes and I was reading Denise Lewis' notes that he's talked about during this witness.

47 THE COURT:

Well, there's no objection to Miss Lewis, and I assume that tomorrow morning, we'll hear about Brockbank if there's a problem.

48 MS. CLARK:

All I'm saying is that the notes did not exist until this morning. So it's not late discovery. That's when they were written.

49 MR. BAILEY:

Just for purposes of calculating time, I understood from Mr. Darden this morning in chambers that the main emphasis on comparison will be with Deedrick and not the whole litany with Brockbank.

50 MS. CLARK:

That's exactly right. There's not going to be any testimony about comparison with Brockbank at all. At all.

51 THE COURT:

Who is your comparison expert?

52 MS. CLARK:

Doug Deedrick of the FBI. I've attempted to make sure there's no overlap. So--

53 THE COURT:

All right. So how many hair and trace witnesses are we going to have?

54 MS. CLARK:

Three.

55 THE COURT:

Got it. Okay.

56 MS. CLARK:

And that's why I just proposed a stipulation concerning the taking of other exemplars to prevent the calling of other witnesses to just say "I took an exemplar," and they've agreed I believe.

57 THE COURT:

Okay.

58 (Discussion held off the record between Defense counsel and the Deputy District Attorney.)
59 THE COURT:

Mr. Blasier.

60 MR. BLASIER:

We do have objections--we're not prepared to stipulate to the collection of any evidence items by the Coroner's office or by Mr. Yamauchi. There are exemplars, and we presented a stipulation--the fingernail kit, the hair kits, those--

61 MS. CLARK:

The fingernail kit and the hair kit are already done by business records. The only thing I'm asking you to stipulate and is already in the stipulation you looked at is the collection of exemplars from the clothing by Yamauchi and Raquel.

62 MR. BLASIER:

Fabric samples are fine. I have no problem with that.

63 MS. CLARK:

And the Bronco carpet fiber exemplars.

64 MR. BLASIER:

I have no problem with that either.

65 MS. CLARK:

That's all you asked for. That's all we need.

66 MR. BLASIER:

Well, we aren't agreeing to anything done by Ratcliffe at the Coroner's office. We aren't agreeing that the clothing of the victims was properly preserved by the Coroner's office, and we would object to testimony about what happened to that clothing unless it's subject to connection at some later point in time.

67 MS. CLARK:

We are putting in the clothing of the victims and the hair samples taken from the victims. Mr. Kelberg laid the foundation through business records as far as the Coroner's office is concerned. We pick up the chain from Denise Lewis who will identify by Coroner's number and packaging exactly what the items were that she recovered from the Coroner's office that was attributed to the decedents, and we believe that's sufficient to complete the chain. If Defense wants to call witnesses that pertain to that in their case in chief, they're welcome to do so. But I don't think the People are required to do anything further other than identify from the packages--unless the Defense can make a challenge that there's something wrong with the chain under People versus Riser, we can do so by the identity of numbers on the packaging and the descriptions of the items themselves, and we intend to do so with the witnesses that we will call.

68 THE COURT:

All right. So what's the roadblock at least starting with this witness this afternoon?

69 MS. CLARK:

None.

70 MR. BLASIER:

No. I have no objection with going ahead with this witness. I just want to make it clear we're not stipulating--for instance, with the clothing, the shirt obviously was not properly collected because it was moldy and smelly by the time it got to the crime lab. We've had testimony that if it was collected properly, that wouldn't happen. So we know presumptively that wasn't collected properly and we are not agreeing that it was.

71 MS. CLARK:

I'm not asking them to do either.

72 THE COURT:

All right.

73 MS. CLARK:

I'm just saying that that was the shirt collected.

74 THE COURT:

I just wanted to know the perimeters of what the objections are. But if there's no objection based upon the report that was disclosed this afternoon to proceeding with Miss Lewis, let's proceed with Miss Lewis. All right. Anything else?

75 MR. COCHRAN:

May we approach without the reporter?

76 THE COURT:

Yes.

77 (A conference was held at the bench, not reported.)
78 (The following proceedings were held in open court, out of the presence of the jury:)
79 THE COURT:

All right. Mr. Fairtlough, would you turn that down, please, so the jury can't see it until it's going to be used.

80 MR. BLASIER:

Your Honor, Mr. Fairtlough indicated that he would fax me a copy of that tonight so that we can take a look at it over the evening break.

81 THE COURT:

Fine. All right. Counsel, anything else before we invite the jurors to rejoin us? All right. Let's have the jury, please.

Temperature

procedural

Key Quotes (4)

Peter Neufeld
There's no way we can check his numbers unless we have his program. That's the whole point.
Captures the core dispute over whether data alone is sufficient for independent verification of Weir's DNA statistics.
Robert Blasier
We were just presented with I think 33 pages of new discovery on the next two witnesses. One is a five-page typed report from the first witness we had nothing from before.
Frames the late-discovery objection and sets the stage for delaying Brockbank's testimony.
Marcia Clark
The notes did not exist until this morning. So it's not late discovery. That's when they were written.
Prosecution's rebuttal to the late-discovery claim — the notes were freshly created, not withheld.
Robert Blasier
The shirt obviously was not properly collected because it was moldy and smelly by the time it got to the crime lab.
Previews a chain-of-custody challenge to victim clothing, a theme the defense intends to develop.

Evidence (7)

Informal
Dr. Weir's DNA statistics computer program and associated frequency tables for two-, three-, and four-contributor assumptions
Defense requested; prosecution opposed; judge denied program, ordered underlying data produced same day
Informal
Large chain-of-custody chart to be used with witness Denise Lewis
Disclosed to defense minutes before proceedings; Fairtlough to fax copy to Blasier overnight
Informal
Five-page typed report from Denise Lewis (hair/trace evidence custodian from Coroner's office)
Disclosed same afternoon; defense prepared to proceed despite late production
Informal
Handwritten notes from Susan Brockbank (hair/trace witness)
Disclosed same afternoon; defense not prepared to cross-examine; testimony deferred
Items 73, 79, 81, 83, 86
Coroner's office items (victim knowns/exemplars) to be covered with Denise Lewis
Identified as scope of Lewis direct examination
Informal
Victim clothing including a moldy, malodorous shirt
Defense flagged improper collection; prosecution noted chain established through business records and Lewis packaging identification
+ 1 more

Notable Exchanges (3)

Peter NeufeldGeorge ClarkeLance A. Ito
Neufeld argued the defense cannot verify Weir's DNA calculations without access to his proprietary computer program; Clarke opposed on grounds the data itself was sufficient; Ito noted the program was likely proprietary and denied the request while ordering data produced by day's end.
strategic
Robert BlasierMarcia Clark
Blasier objected to the last-minute production of Brockbank's notes and the chain-of-custody chart, while Clark countered that the notes were written that morning and she herself had not yet read them. The parties clarified that Lewis could proceed immediately and Brockbank's issues would be sorted the next morning.
tense but resolved
Robert BlasierMarcia Clark
Extended colloquy over whether the defense would stipulate to the chain of custody for victim clothing and exemplars. Blasier drew a line at anything touching the Coroner's office or Ratcliffe, while accepting fabric and Bronco carpet fiber exemplars.
strategic

Credibility Attacks (2)

⚔ Bruce Weir
challenge to methodology/independent verification
Neufeld argued that without access to Weir's computer program, the defense cannot independently verify whether his statistical calculations were performed correctly.
⚔ Coroner's office / Ratcliffe
improper collection/chain of custody
Blasier pointed to the moldy, malodorous condition of the victim's shirt as circumstantial evidence of improper collection, and declined to stipulate to Coroner's office handling.

Objections

1 objections (0 sustained, 0 overruled)
Proceeding 6552 • 81 utterances
Criminal Trial
Department 103
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📂 JUN 26, 1995 📄 Administrative matters: discov
JUN 26, 1995 KRT DvH TD