Thank you, counsel. Proceed.

Miss Brockbank, I note from your CV that you also have provided training in field investigations for hair and trace analysis or collection of hair and trace evidence?

Umm, for other criminalists?

Yes.

Yes.

Is that at LAPD?

Yes.

Incidentally, your primary training in learning the techniques that you have described how do you this kind of analysis, did you obtain that--get that at LAPD or someplace else?

At LAPD.

Did you receive any training at the Orange County crime lab?

No.

Okay. Now, I think you described that the trace unit at LAPD is in its own little separate room; is that right?

That's correct.

And how big is that room?

Umm, maybe about a quarter of the size of this courtroom.

And is that your--is that room used by you just for hair and trace analysis or are there other kinds of different analyses going on in that room at the same time?

Well, as far as our trace unit, umm, as I mentioned earlier, we perform several types of analysis; hair and fibers, shoeprints, tire tracks, tool marks, paint, glass, so quite a variety that--of different types of analysis do go on there, not just hair and fiber.

Okay. Now, is that room--is there a fan in that room?

Not a fan. We do have an air conditioning system.

Now, is one of the things that you are trying to be careful of when you are doing collections of hairs and fibers is not to have a lot of air current going on in the room, right?

Yes.

Because this stuff is very volatile and can get blown from one place to another if you are not careful, can't it?

Umm, if you are not careful, yes, it could.

And do you try to take precautions to make sure that there aren't a lot of people walking around in the room with maybe lab coats that are flapping on and off or whatever to limit the amount of air current that might be in the room?

Umm, there generally aren't a lot of people walking around. I don't know that walking around creates tremendous air current, though.

You wouldn't recommend, though, as a procedure, that you conduct this kind of analysis and collection in a room with a lot of people in it doing other things, would you?

Umm, if they are doing things where they are just sitting in one place, I don't think that would really matter. If they are walking by briskly, and up know, you are working in a crowded situation, I would say no.

Now, hair and trace evidence is many times difficult to see just with the naked eye looking at a distance, is it not?

Umm, looking at a distance, yes.

If you were looking at a hat or a glove on the ground, for instance, and you were standing up, it would be very difficult for you to identify any hair and fiber evidence on that article, wouldn't it?

You may be able to see it, but you may not.

I mean, the--when you remove hairs, for instance, from the cap, you do a very careful analysis and you roll it very carefully and you look at it very closely in order to see these things, correct?

Yes.

And you see things when you do that that you can't see with the naked eye unless you are specifically looking for them?

That could be correct, yes.

And you have to be very careful because items such as this can get dislodged fairly easily and just fall off, can't they?

Umm, it probably has a lot to do with whatever it is on. You know, if you are talking about layers and fibers on some smooth surface, it would be very easy I think for those to get dislodged if that moved around. Clothing items, depending on the weave of the clothing, may hold those fibers a little more strenuously so moving it around a little they may not fall off. It just really depends.

Okay. And there is no real data that tells you with a particular fabric how well that holds a foreign fiber or not, is there?

And you can, if you brush--if you brushed my coat on something that had some hair on it, that hair could get transferred to my coat pretty easily, couldn't it?

That would be possible, yes.

If I touch somebody else it could go to somebody else or some other place and get transferred over and over and over again, correct?

That could be possible, yes.

And one of the limitations in this kind of analysis is that you have no way of telling when you say something, a hair or a fiber on an object, how many different levels of transfer it has gone through from its original source?

You would have no way of knowing that just by looking at a fiber on a surface, no.

And hair and fiber is--they are both very stable in the sense that they don't break down real quickly, correct?

Objection, vague.

Overruled.

That's correct.

So if your hair--if you have a hair that falls on the ground it is going to stay a hair for a long time?

Yes, it will.

So we have no way of looking at a hair or a fiber and telling from the appearance how long it has been since that was on its original source?

Well, sometimes when you are looking at a hair or a fiber you do see things that might indicate it has been there awhile, like dirt accumulated on the fiber itself, or in the case of a hair that has been there for awhile, it might actually have like bite marks on it where some insect activity has occurred, and that is something that I have seen from time to time in evidence from crime scenes.

So that might be one indication that if you see a hair with bite marks on it, that that is an indication it has probably been there for awhile, maybe?

Now, in your lab you are very careful not to have two items of evidence out at the same time unless it is absolutely necessary, correct?

Umm, that would be correct, unless you are performing a comparison between those two items and you need to see them at the same time.

And the reason for not having them out together is because of the volatility of this kind of evidence? You want to make sure that you don't have something moved from one object to the other?

That's correct.

Now, when evidence is at a crime scene lying on the ground, for instance, for a long period of time, there is no way to protect those individual pieces of evidence to prevent transfers of hair and fiber evidence from one to the other, is there?

There is no way to protect those items, no. I mean, anything you did to protect those would probably create more of a problem.

And there is no way to prevent--let's say, hypothetically, that you have some detectives at a crime scene and they are walking around and they are looking at things, if they have hairs and fibers that have transferred to their clothing, there is no way to protect the evidence from those things falling off clothing and landing on the ground or on an evidence object, is there?

Objection, vague, unintelligible, overbroad.

Overruled.

Umm, I don't think there is a way to prevent that, but then again, I don't know how often, you know, people are just dropping hairs and fibers, or if, you know, it takes some sort of actual contact to transfer fibers.

So there is no data that you are aware of or studies that you are aware of that measure that in terms of how easily hair and fiber can be transferred from one person to another, one object to another?

There may be some studies, but I am not specifically aware of any.

Now, people lose generally a hundred hairs a day, don't they?

I have read that, yes.

So over a thirty day period each person loses maybe 3000 hairs, roughly?

Yes.

That is a lot of hairs, isn't it?

Yes, it is.

And would you agree that a person's natural environment where they spend time, is likely to have hairs that have fallen out of their heads?

I know mine does, yes.

Now, let me ask you, hypothetically, if several police officers, several detectives spent some time at Mr. Simpson's home in an area where he spends a lot of time, perhaps sitting on furniture or whatever, moving around, it is possible that they could pick up trace evidence that might be at that location on their clothing, without knowing it?

That would be a possibility.

And that if they then go back to Bundy to the crime scene before anything has been collected, there is a possibility that things that they might have picked up at Rockingham could be transferred to Bundy?

Is one of the reasons why you try to protect a crime scene quickly, to get the evidence preserved as quickly as possible, is to prevent those kind of cross-transfers and compromise of the evidence?

Yes.

Is one of the reasons why you might want to wear protective footwear at a crime scene is to prevent your transferring or your depositing fiber evidence or hair evidence that might be on your shoes or on your--in the cuffs of your pants?

Objection, this is beyond the scope.

Overruled.

Umm, that may be one reason to wear protective footwear. Usually when we wear that it is to prevent transfer of blood, if there is a particularly bloody crime scene, to us. A lot of the protective wear that what he use, gloves, lab coats, protective footwear, disposable jumpsuits, are more of a protection for us as far as dealing with, you know, blood contaminated evidence, but it also works the opposite way, to protect the evidence from us contaminating it.

For instance, if you had been in your car and picked up some carpet fibers in your shoes, putting on protective footwear would prevent those fibers from getting deposited to where you walk, wouldn't they?

Yes.

Would you agree that it would be improper procedure at a crime scene to bring something into the crime scene, such as a blanket, which might have trace evidence already on it, and hence expose the evidence to whatever might have been on a blanket, umm, that is not something that--

Objection, your Honor, beyond the scope, irrelevant.

Overruled.

That is not something I would recommend doing.

Okay. Now, would you agree that you also would not recommend taking something like a blanket or a large object and splaying it out or putting it down in a way that causes air current that might move other things around in a crime scene.

Objection. This calls for speculation and assumes facts not in evidence.

Sustained.

Would you agree that in order to preserve a crime scene, at least as to trace and fiber evidence, you want to be careful not to do anything--anything that creates air current that might move the evidence around?

Yes, I would try to do that.

I'm sorry.

I wouldn't want to do anything that promoted that.

And would you also, in order to preserve the integrity of any hair and trace evidence that might be at a crime scene, avoid moving one object across another object--well, let me be more specific. Dragging a body across pieces of evidence? You wouldn't want to do that, would you?

No, I would not.

You would not want to move pieces of physical evidence from one place to another before they are collected, would you?

Objection, beyond the scope, your Honor.

Overruled.

Umm, when I'm collecting evidence at crime scenes, I do not move evidence until I collect it.

Okay. If you pick something up, did something with it, just held it or whatever and then put it down at a different place, that might compromise the integrity of any trace evidence on that item, wouldn't it?

It might, yes.

Moving things across dirt, for instance, that alone might cause the object to pick up hair or fiber that is in the dirt?

That could be a possibility.

Would you agree that if there are two different environments, two different locations where a person spends time, that it is likely that you might find trace evidence of that person at both of those locations?

Objection, calls for speculation. Assumes fact not in evidence.

Sustained.

If you have--let's--hypothetically, if you have a person who--

This exceeds the scope of the direct examination, counsel.

Do you know whether there are any studies that look into whether dogs and their fur can transfer trace evidence from one place to another?

Objection, beyond the scope.

Overruled.

There may be studies but I am not aware personally of them.

Do you know whether or not dogs or animals lose hairs faster than people do?

Again, I don't know the rate animals lose hairs.

Would you agree that you would not--would it not be unusual to find an abundance of dog hairs consistent with a dog that frequents a particular area?

I would not find that unusual.

The notes that you would prepare, you do that when you do your work, you do that contemporaneous when you prepare the work?

Yes.

They are all done in chronological sequence and describe in great detail what do you from one step to the next?

Usually.

That is the procedure that you have been taught is the proper procedure?

Yes.

Do you ever--if do you something on an item of evidence that you have already done something on before, do you ever just go back to your old notes and just kind of make a notation that you have done something else to it or do you create a whole new note in sequence so that you can reconstruct exactly what you have done from start to finish?

Umm, I usually make new notes just continuing on where I left off. Umm, in this case on I believe the little glove diagrams that I made, I did add some additional notes to them and I made a note of that in sequence that I did add additional notes to it.

So even when you do that, you can tell what you did?

Right.

And you don't have to rely on your memory to remember what you did, you can look at your own paperwork a year, two years from now and this is what I did?

Right.

Now, you told us in a lot of detail about how you change your gloves between every single item that you look at?

Yes, I do.

And that is the proper procedure that you have been taught, is it not?

Yes.

And you change paper between every single item that you look at, don't you?

Yes, I do.

And that is good procedure, isn't it?

I believe so.

And that is because even though you look at the paper, you may miss something? Let me be more detailed. After you are done looking at an item, you examine the paper to see if there is any trace evidence there and if you see trace evidence you try to put it back in the container?

Correct.

If you don't see trace evidence, you get rid of the paper, don't you?

Yes.

And that is because some of this you may just miss?

There may be something there very tiny that you might miss. There also may be biological contamination, you know as far as--because a lot of the evidence we deal with is bloody evidence and so you don't want that around for the next item, so you just want to make sure you've got a clean working surface.

And you are careful to have a lab coat on at all times?

Yes.

And that is to prevent things from your clothing getting into the evidence, isn't it?

That and also to prevent things that I'm working with to get on me.

Now, do you use a new lab coat each day?

Umm, no.

How frequently do you change?

Umm, I wear the same lab coat most of the time. It is laundered weekly, and you know, if I was to get something on it, then I would launder it, you know, immediately. I do have two lab coats that I can--

Alternate?

--alternate on, if I need to.

Mr. Deedrick didn't wear a lab coat?

I don't believe so.

Did he change gloves between every single item?

Umm--

Objection, that is vague, your Honor.

Sustained. Rephrase the question.

Between every single evidence item that he examined in your presence, did he change gloves?

Yes, he did.

Did he change paper on the table between every evidence item that he examined in your presence?

Umm, we were doing this together, so I don't know if he changed paper or I changed paper, but paper would have been changed, yes.

Okay. Now, you testified on direct that you saw--there was--some of the hairs that you examined had what appeared to be blood on them. Do you remember that testimony?

Yes, I do.

You have no way of telling, from looking at a hair that appears to have blood on it, when the blood got on the hair, do you?

No.

You have no way of telling whether the blood was on an object and then the hair got on it or the hair was on the object and then the blood got on it, do you?

No.

And you have who way of telling whether the hair and the blood got together before they got on the object either, do you?

No.

Now, you talked about the difference between water mounts and permounts yesterday. Do you remember that?

Yes.

Now, water mounts I think you said was not the desirable procedure?

No.

Okay. What did you say about that?

That may have been what I said.

Okay.

It is not the desirable procedure.

And the reason for that is because it affects your ability to look at colors, doesn't it?

To look at most characteristics of the hair; color being one of them.

It doesn't prevent you from counting hairs, does it?

Well, it could if two hairs happened to be, you know, crossing over very close to each other. Because of that, you know, difference, the dark black line I told you about, you may actually obscure a couple hairs.

When you counted the hairs in this case on the wet mounts, were you pretty careful about--were you very careful about counting the number of hairs?

I try to be careful.

And you take your time and you count everything that is there that you see?

Yes.

And you indicated that some of the slides that you mounted and counted and recorded the number of hairs, when they got to Washington more hairs were found on those slides, correct?

Well, they were just water mounted by me, so no hairs were found on the slides, but in the bindles.

So after you--after you look at it on the water mount, you take it off that and put it in the bindle?

That's correct.

And you are careful to make sure that you don't add anything to the bindle when you do that?

That's correct, yes.

And when those bindles got to Washington some of them had more hairs in them?

Do you have--you were asked to look at the property reports yesterday to tell us what the description was for the blood-stained items that you also looked at in either box no. 1 or box no. 2. Do you remember that?

Yes.

Do you have those property reports with you?

No.

You were asked to tell us what the description was and you said that the descriptions were swatch or swatches. Do you remember saying that?

Yes.

Almost every one of those descriptions in the property report was singular, "Swatch," wasn't it?

Swatch.

Objection, this is irrelevant.

It is vague.

How many of the items that Miss Clark read to you, while we were standing up there, referred to anything other than swatch singular?

Objection, this is irrelevant.

Your Honor, what time are we going to break?

About four or five minutes; 10:30.

You indicated yesterday that you put--at one point you put both gloves on the floor to do a comparison photograph?

Yes.

And they were on separate pieces of paper?

Yes, they were.

Are you positive about that?

Yes.

Could we have exhibit 444, please. (Brief pause.)

May we put People's 444 on the elmo?

Is that a picture of the comparison that you did on the floor?

Yes.

Do you see any seam showing individual pieces of paper between the gloves?

I do not see a seam.

Do you have any other picture that shows that, that shows a seam?

Umm, I don't.

Let me go back for a minute to your hair description chart. Back out of that a little bit.

And this is 12--

1217.

Thank you.

I want to ask you just one more question about hair analysis. Is there any standard in the field of hair analysis for what characteristics have to be present to say that two things are consistent?

So one examiner may have different criteria in terms of what specific characteristics or the number of characteristics that they require before they say something is consistent than another examiner?

Objection, beyond the scope.

Overruled.

That may be correct.

You referred to at one point that people or somebody was sent back to Mr. Goldman's apartment to get an exemplar from a hairbrush. Do you remember that?

Yes.

That is a fairly common procedure if you need extra hairs from--extra exemplars, to get them from a person's hairbrush, isn't it?

It is something I personally had never done before. I understand that it is done.

And you would expect to find a person's hair in their hairbrush?

I would.

I would imagine so, yes.

Your Honor, perhaps this might be a good time.

All right. All right. Ladies and gentlemen, we are going to take our mid-morning break at this time. Please remember all of my admonitions to you. We will see you back here in fifteen minutes. Miss Brockbank, come back in fifteen minutes. All right. Thank you.