📄 Redirect examination of Dr. Bruce Weir (part 2) — Monday, June 26, 1995
Address:
C:\DEPT103\CRIMINAL\1995\JUN\26\REDIRECT-EXAMINATION-OF-DR-BRU.DOC
TRIAL
▲ Day 103 of 167

Redirect examination of Dr. Bruce Weir (part 2)

Witness: Dr. Bruce Weir
Examiner: George Clarke
Called by: Prosecution • Date: Monday, June 26, 1995 • Utterances: 104
Prosecutor George Clarke rehabilitates Dr. Bruce Weir on redirect, focusing on two goals: clarifying why the defense's NRC-based mixture frequency calculations are scientifically invalid, and establishing that Weir is an unbiased, unpaid expert testifying on his own vacation time. Weir uses a slot machine analogy to explain that the proper calculation requires the full profile combination (all three fruits), not just the chance of any single component appearing, directly undercutting the defense's 1-in-4 or 1-in-2 figures from cross-examination.
1 (The following proceedings were held in open court, in the presence of the jury:)
2 THE COURT:

Thank you, ladies and gentlemen. Please be seated. All right. Dr. Weir, would you resume the witness stand, please. All right. Mr. Clarke.

3 MR. CLARKE:

Thank you, your Honor.

4 MR. CLARKE:

Dr. Weir, while we're on item no. 78, if I could ask you just one or two more questions.

5 DR. WEIR:

All right.

6 MR. CLARKE:

There were also estimates made by you of frequencies for this mixture based on the RFLP results; is that right?

7 DR. WEIR:

Yes, that's right.

8 MR. CLARKE:

And for two contributors, they range from 1 in 300 million to 1 in one trillion approximately; is that right?

9 DR. WEIR:

Yes. Uh-huh.

10 MR. CLARKE:

And for three contributors, from approximately 1 in one million to 1 in 300 million; is that right?

11 DR. WEIR:

Yes.

12 MR. CLARKE:

The fact that you made changes or recalculations, as to the PCR estimated frequencies, do those have any effect whatsoever on the RFLP estimates?

13 DR. WEIR:

No, they don't.

14 MR. CLARKE:

Now, I'd like to refer you, if I could, to one of the Defense exhibits, and I believe it's exhibit 1208, the drawing that Mr. Neufeld did about mixture frequencies.

15 DR. WEIR:

Of the chart, yes. This morning? Yes.

16 MR. CLARKE:

Do you recall that mixture frequencies chart?

17 DR. WEIR:

Yes, I do.

18 MR. CLARKE:

I believe that is exhibit 1208, your Honor.

19 THE COURT:

Yes.

20 MR. CLARKE:

Dr. Weir, you expressed a desire to explain one of your answers to Mr. Neufeld. What did you want to explain?

21 DR. WEIR:

Well, I wanted to explain how to interpret a mixture. There are some mixed stains, and we would like to assign a frequency to those mixtures on the assumption they came from some people unknown to us. So we need to calculate the frequency of two or three or four people, however many people we think are likely to have contributed to the mixture. And if we don't know, we'll just give the range of answers. And I've been trying to think of an appropriate analogy, and I was thinking of maybe playing a slot machine where in order to win, we had to have three different fruits showing, a lemon, a cherry and an orange. And we will win only if the whole three different fruits show. It just has three wheels on it. So what I've calculated is the frequency of getting that set of three fruits showing, a lemon, an orange and a cherry.

22 MR. CLARKE:

So in your example, there's only a payoff if a lemon, a cherry and an orange show up, one on each of the wheels?

23 DR. WEIR:

That's right. The whole three have to be there. It doesn't matter on which wheel, but we've got to get the whole three. Now, before we even walk into the casino, we know it's going to be a rare event. That's the way things are stacked. Anyway, this is what we have to get to--we need to get the whole three. What Mr. Neufeld had me calculate was the frequency of getting some of them, either two of them or one of them. It depended on the circumstances. Two out of three doesn't pay. One out of three doesn't pay. I don't care how often an orange shows up. I've got to get an orange, lemon and cherry to pay off.

24 MR. CLARKE:

Now, how does that relate to--and there's this third column on these mixtures frequencies. First of all, the first two columns relate to frequencies that you estimated last week and then testified to today; is that right?

25 DR. WEIR:

Those first two columns, one of them is much better than the other, they give us the frequency of the set of three; in this case, set of DNA bands, and my example, the set of three fruits. What Mr. Neufeld's--what the NRC's number is the chance that any of the three show up. Now, supposing there were only three fruit on the wheel. All three are going to--and the mixture is the three-fruit mixture, the chance of getting any one of the three is a hundred percent because those are the only three possible. So in some of his examples--in the polymarker examples, he said it wouldn't exclude anybody. Well, that's right. If you spin the wheels, you're going to get something showing up. So nothing is excluded. If there are more than three fruits on the wheel, there's also bananas which we don't see, then the frequencies won't be a hundred. But the essential thing is, this is a mixture. I think everyone has agreed it's a mixture because there's more than two bands that are probed that was contributed by more than one person. The question is, how unusual is this mixed profile to have come about if there were more than one contributor. It doesn't matter how many times the cherry shows up. It's the whole three needed for payoff.

26 MR. CLARKE:

Then what's wrong with this column labeled "NRC" where these numbers 1 in 4, 1 out of 10 or 1 out of 2 are written?

27 DR. WEIR:

It doesn't give us the frequency of the evidence. The frequency of the evidence, if there were two people unknown to us or if there were three or if there were four, that's what we have to calculate. It's the frequency of the evidence.

28 MR. CLARKE:

And in your view, is that third column a scientifically appropriate way of describing the relevant frequencies of these mixtures?

29 DR. WEIR:

No, it's not.

30 MR. CLARKE:

Incidentally, is there any relation between proficiency tests and whether a mistake was made in this case?

31 DR. WEIR:

No.

32 MR. NEUFELD:

Objection. No foundation.

33 THE COURT:

Overruled.

34 DR. WEIR:

No, there's not.

35 MR. CLARKE:

Do either proficiency tests or whether a mistake was made in this case affect your calculations at all?

36 DR. WEIR:

No, they do not.

37 MR. CLARKE:

Now, you described, Dr. Weir, the fact that--and you expressed some reservations about being a witness for a criminal defendant. Do you recall that?

38 DR. WEIR:

Yes. There was some conversation, yes.

39 MR. CLARKE:

Are you biased against criminal defendants?

40 DR. WEIR:

No, I'm not.

41 MR. CLARKE:

Are you biased against this Defendant in this case?

42 DR. WEIR:

No, I'm not.

43 MR. CLARKE:

Are you biased against any criminal defendant?

44 DR. WEIR:

No, I'm not.

45 MR. CLARKE:

Are you biased against any attorney on this case on either side?

46 DR. WEIR:

No, sir. No, sir.

47 MR. CLARKE:

As far as your testifying, is that because your university has a contract with one of the laboratories in this case?

48 MR. NEUFELD:

Objection, your Honor.

49 THE COURT:

Overruled.

50 DR. WEIR:

No. I'm here as a private citizen.

51 MR. CLARKE:

Why did you agree to testify in this case?

52 MR. NEUFELD:

Objection. Irrelevant.

53 THE COURT:

Overruled.

54 DR. WEIR:

I'm very concerned that the statistical interpretation of DNA evidence is done correctly. I've been very angry over the last four years at some of the statements made in courts about the statistics attached to DNA profiles. I am very anxious that they be done correctly and I am therefore willing to testify when possible.

KEY QUOTE
55 MR. CLARKE:

If a criminal defendant wanted you to present evidence about statistics or frequencies attached to either a match or a mixture using the proper scientific manner of doing so, would you so testify for that Defendant?

56 MR. NEUFELD:

Objection.

57 THE COURT:

Overruled.

58 DR. WEIR:

Yes, I would if I had the time.

59 MR. CLARKE:

Dr. Weir, how much are you being paid for your work in this case?

60 DR. WEIR:

I'm not--

61 MR. NEUFELD:

Objection, your Honor. Irrelevant.

62 THE COURT:

Overruled.

63 DR. WEIR:

I'm not being paid.

64 MR. CLARKE:

How much are you being paid for your testimony in this case?

65 DR. WEIR:

I'm not being paid for any aspect of this case.

KEY QUOTE
66 MR. CLARKE:

As far as the university is concerned, what is your status while you're out here in Los Angeles testifying?

67 DR. WEIR:

I'm on vacation.

68 MR. CLARKE:

Now, these numbers that are presented on these boards--and we have before you and the jury exhibit 259, the Bundy results boards. But let's take all five of the results boards into account. What are these numbers that are written up there? Are they exact numbers?

69 DR. WEIR:

Oh, no. No. They're estimates of the frequency with which these various profiles would arise from unknown people.

70 MR. CLARKE:

What do numbers in the millions or billions mean?

71 DR. WEIR:

Well, there's two parts to that. They convey a very real sense how rare these profiles are. I think they're very good at doing that. But specifically, numbers in the billions are a little hard to understand. We don't have experience in having to deal with numbers in the billions. The only time we see them written down anywhere is to do with the national debt. I don't think anybody understands that. We just have these enormous numbers. They're good at saying this profile or that profile is rare, and I think when they are so rare, they're based on so many loci, I would be happy to just leave it at that.

72 MR. CLARKE:

I would like to direct your attention or I would like to have you direct your attention to a few of the stains on this board, in particular, item no. 47.

73 MR. NEUFELD:

Objection. Beyond the scope, your Honor, of cross-examination.

74 THE COURT:

Overruled.

75 MR. CLARKE:

And would it help you first of all to use the smaller charts that you have in front of you?

76 DR. WEIR:

Yes, it would.

77 MR. CLARKE:

I would like to direct your attention to items 47, 48, 49, 50, 52. First of all, amongst that group, that includes PCR results, and as to 52, RFLP results as well; is that right?

78 DR. WEIR:

That's right.

79 MR. CLARKE:

And then lastly, 115, 116 and 117. Do you see those?

80 DR. WEIR:

Yes.

81 MR. NEUFELD:

Your Honor, objection. All of this is beyond the scope. None of this goes to cross.

82 THE COURT:

Overruled.

83 MR. CLARKE:

And 117 has RFLP results as well; is that right?

84 DR. WEIR:

It doesn't show on my copy of the chart, but I see it is on that, yes.

85 MR. CLARKE:

From a population genetics standpoint as well as a statistical standpoint, what do those results tell us in terms of the evidence presented on this particular board?

86 MR. NEUFELD:

Objection. No foundation and vague as well.

87 THE COURT:

Sustained. It's vague.

88 MR. CLARKE:

As far as those results are concerned, do those results--I'm sorry--results reveal a rare profile?

89 MR. NEUFELD:

Objection. No foundation. The numbers speak for themselves.

90 THE COURT:

Overruled.

91 DR. WEIR:

Yes. But--well, especially the RFLP frequencies. When they're in the millions, that certainly indicates a rare profile.

92 MR. CLARKE:

And as far as RFLP results, are you referring now to what would be one of the Bundy walkway stains, item no. 52, as well as the rear gate, item no. 117?

93 DR. WEIR:

Yes, I am.

94 MR. CLARKE:

And do those results reflect RFLP matches with any particular individual?

95 DR. WEIR:

Mr. Simpson is not excluded from having contributed to that stain.

96 MR. CLARKE:

What can you tell us about the meaning of that evidence in terms of--

97 MR. NEUFELD:

Objection. As to meaning, it's not his province either.

98 THE COURT:

Overruled.

99 MR. CLARKE:

What can you tell us, Dr. Weir, about the meaning of those pieces of evidence referring to the RFLP matches from a statistical and population genetics standpoint?

100 DR. WEIR:

Well, the statistics and population genetics is concerned only with determining how frequent that profile is in the general population and people other than--in some unknown person. So we--the numbers represent that frequency.

101 MR. CLARKE:

As far as Mr. Simpson is concerned, is he an individual that's simply not excluded or is this evidence from a frequency standpoint something more powerful than that?

102 DR. WEIR:

Well, the evidence is that it's very unlikely we would see that evidentiary profile if it came from somebody else.

KEY QUOTE
103 MR. CLARKE:

Your Honor, at this time, I would like to put on the easel the Rockingham residence results board.

104 THE COURT:

Let me see counsel with the court reporter.

Temperature

procedural

Key Quotes (5)

Dr. Bruce Weir
I'm very concerned that the statistical interpretation of DNA evidence is done correctly. I've been very angry over the last four years at some of the statements made in courts about the statistics attached to DNA profiles.
Establishes Weir's motivation for testifying — not financial gain or prosecutorial bias, but professional outrage at scientific misuse of DNA statistics.
Dr. Bruce Weir
Two out of three doesn't pay. One out of three doesn't pay. I don't care how often an orange shows up. I've got to get an orange, lemon and cherry to pay off.
Core of the slot machine analogy dismantling the NRC column on defense exhibit 1208 — the defense calculated single-component frequencies rather than the full profile frequency.
Dr. Bruce Weir
I'm not being paid for any aspect of this case.
Eliminates financial bias as an impeachment angle; combined with 'I'm on vacation,' it strongly rehabilitates his credibility.
Dr. Bruce Weir
I'm on vacation.
Unexpectedly humanizing and credibility-enhancing — Weir is spending personal time testifying, underscoring his testimony is driven by principle, not compensation.
Dr. Bruce Weir
The evidence is that it's very unlikely we would see that evidentiary profile if it came from somebody else.
Clarke's successful redirect pivot from 'not excluded' to positive probabilistic language, strengthening the match evidence for items 52 and 117.

Evidence (5)

Defense 1208
Mixture frequencies chart drawn by Neufeld during cross-examination, containing three columns including one labeled 'NRC' with frequencies as low as 1 in 2 or 1 in 4
discussed and challenged — Weir argues the NRC column does not calculate frequency of the full evidentiary profile
People's 259
Bundy walkway DNA results boards
referenced during discussion of items 47, 48, 49, 50, 52, 115, 116, 117
Informal
Item 52 — Bundy walkway stain with RFLP results
discussed as a rare RFLP profile from which Simpson is not excluded
Informal
Item 117 — rear gate stain with RFLP results
discussed as a rare RFLP profile from which Simpson is not excluded
Informal
Rockingham residence results board
requested to be placed on easel at end of proceeding — not yet examined

Notable Exchanges (3)

George ClarkeDr. Bruce Weir
Extended slot machine analogy to explain why the NRC column on defense exhibit 1208 is scientifically inappropriate — Weir explains you need all three fruits (all DNA bands) to 'pay off,' not just any one of them. This directly rebuts Neufeld's cross on mixture frequencies.
strategic
George ClarkeDr. Bruce Weir
Clarke walks through bias and compensation questions: bias against defendants? No. Bias against this defendant? No. Paid? Not at all — and he's on vacation. Systematic deconstruction of Neufeld's implied bias attack.
rehabilitative
Peter NeufeldLance A. Ito
Neufeld repeatedly objects on scope grounds (items 47-52 and 115-117 not covered on cross) and is overruled each time, suggesting Ito interpreted Clarke's redirect latitude broadly.
procedural friction

Light Moments (1)

Dr. Bruce Weir
When asked about his status at the university while testifying in Los Angeles, Weir simply replies 'I'm on vacation,' a disarming answer that drew implicit contrast with paid expert witnesses.

Credibility Attacks (2)

⚔ Dr. Bruce Weir
bias — pre-emptive rehabilitation
Clarke preemptively addresses Neufeld's implied bias attack from cross (university contract with a lab, reluctance to testify for defendants) by directly asking Weir whether he is biased against defendants or this defendant specifically. Weir denies all bias and reveals he is unpaid and on vacation.
⚔ Peter Neufeld (defense methodology)
scientific impeachment of exhibit
Weir directly critiques the NRC column in defense exhibit 1208 as not giving 'the frequency of the evidence,' calling it not 'a scientifically appropriate way of describing the relevant frequencies of these mixtures.'

Objections

10 objections (1 sustained, 9 overruled)
Proceeding 6548 • 104 utterances • Prosecution witness
Criminal Trial
Department 103
⚖️ Start
📂 JUN 26, 1995 📄 Redirect examination of Dr. Br
JUN 26, 1995 KRT DvH TD