Day 48 centered on competing procedural battles: the defense mounted a last-minute attempt to resurrect a Kelly/Frye hearing for DNA evidence after having waived it, while simultaneously raising multiple discovery violation complaints against the prosecution regarding missing, late-disclosed, and withheld evidence including a videotape of Rockingham and lab records. Westec Security director Susan Silva testified about the alarm system at Simpson's estate, establishing that no alarm signals were received on June 12, 1994. Judge Ito largely sided with the prosecution on several issues but ordered informal questioning about the disputed videotape for the following morning.

• Media photographer fined $50 for unauthorized photographs of judge during lunch recess
• Westec Security director testified the Rockingham alarm system detected no signals on June 12, 1994
• Defense attempted to resurrect Kelly/Frye DNA admissibility hearing after formally waiving it in January
• Multiple discovery violations alleged including withheld Rockingham videotape and missing lab notes
• Judge ordered informal questioning about disputed videotape for next morning session
• Cellular telephone records for Allan Park, OJ Simpson, and Detective Ron Phillips stipulated as authentic