📄 Sidebar: hypothetical questions and cross-contamination — Thursday, May 11, 1995
Address:
C:\DEPT103\CRIMINAL\1995\MAY\11\SIDEBAR-HYPOTHETICAL-QUESTIONS.DOC
TRIAL
▲ Day 72 of 167

Sidebar: hypothetical questions and cross-contamination

Date: Thursday, May 11, 1995 • Utterances: 14
The defense (Neufeld) sought to ask hypothetical questions about whether cross-contamination between Bundy and Rockingham blood samples could have altered DNA results, arguing that Fung and Mazzola processed both sets of samples simultaneously in the same room. The prosecution (Clarke) objected that the hypothetical misstated the evidence and lacked foundation, as no evidence showed the swatches were ever mixed or in contact. Judge Ito overruled the objection.
1 (The following proceedings were held at the bench:)
2 THE COURT:

We're over at sidebar. Mr. Clarke.

3 MR. CLARKE:

I think at this point, there's two misstatements of the evidence. This second version so to speak included that, quote, the blood drops at Bundy did not come--it wasn't even an assumption this time around. Secondarily, it included that these drops came into contact with the drops from the Rockingham scene. So I think at this point, there's two misstatements of the evidence.

4 MR. NEUFELD:

Wait a minute. If your objection is that I have to repeat each time I say the Bundy drops didn't come from Mr. Simpson, that's an assumption, I have no problem with that, although I think it's clear from the series of questions that's all part of the initial assumption. I have no problem repeating that each time. Secondly, I'm saying that they came in contact with the swatches of the blood drops from Rockingham, and if your objection is that I omitted the word "assumption," I would be more than happy to include it.

5 MR. CLARKE:

I think that misstates the evidence also, that they came in contact with one another.

6 MR. NEUFELD:

Assumes for purposes of the hypothetical I believe there is insufficient evidence, your Honor, given the way this evidence was poorly processed by Fung and Mazzola. And by the way, we intend to, you know, call other witnesses as well on our case that we're allowed to suggest the we're allowed to suggest the hypothesis here there was cross-contamination just to show if there was cross-contamination, we would get this result because it's been suggested repeatedly by the People in their direct examination that degradation can never change a genotype or DNA type and we want to show through this witness that in fact degradation in conjunction with cross-contamination--

7 THE COURT:

I understand what you are trying to do. The problem is, you have to have some good faith basis to offer the condition in the hypothetical.

8 MR. CLARKE:

The evidence I think to this point is absolutely contrary to that fact about swatches--different samples getting mixed up or in contact with one another, and that's the major problem with this hypothetical.

9 MR. NEUFELD:

Your Honor, the evidence so far is that the Bundy drops and the Rockingham drops were processed by Fung and Mazzola at the same time in the same room both on the evening of the 13th and again on the morning of the 14th. Moreover, there is testimony subject to connection, which you'll hear from Mr. Yamauchi, that actually the serology process of all the Bundy blood drops occurred at the same time as Mr. Simpson's reference sample, and that's going to be the next part of this hypothetical. So we have a good faith basis for every single question.

10 MS. CLARK:

Could counsel keep his voice down?

11 THE COURT:

Mr. Neufeld, I've asked you to keep your voice down now about 18 times.

KEY QUOTE
12 MR. CLARKE:

I think the problem is, there has not been and never will be a foundation that swatches were mixed up, came into contact with one another in this case, and the evidence is to the contrary. At the point that various items were processed, the testimony is clear at this point they were done one at a time and there's no basis to conclude, even for purposes of a hypothetical, that in fact the type of mixing up or contact of samples that Mr. Neufeld has just described has any basis in fact whatsoever. In other words, the problem is, the hypothetical is irrelevant, extremely misleading.

13 MR. NEUFELD:

Well, your Honor, we take the position--

14 THE COURT:

Objection overruled.

Temperature

tense

Key Quotes (5)

Peter Neufeld
we're allowed to suggest the hypothesis here there was cross-contamination just to show if there was cross-contamination, we would get this result because it's been suggested repeatedly by the People in their direct examination that degradation can never change a genotype or DNA type
Articulates the defense's core theory: countering the prosecution's claim that degradation is harmless by showing degradation plus cross-contamination could explain the DNA results
Lance A. Ito
The problem is, you have to have some good faith basis to offer the condition in the hypothetical.
The legal standard at issue — Ito requiring evidentiary grounding before permitting the hypothetical
Peter Neufeld
the Bundy drops and the Rockingham drops were processed by Fung and Mazzola at the same time in the same room both on the evening of the 13th and again on the morning of the 14th
The factual predicate Neufeld offers as good faith basis for the cross-contamination hypothetical
Lance A. Ito
Mr. Neufeld, I've asked you to keep your voice down now about 18 times.
Reveals ongoing friction between Neufeld and the bench throughout the civil trial
George Clarke
the problem is, the hypothetical is irrelevant, extremely misleading.
Prosecution's bottom-line position: the hypothetical has no basis in evidence and would confuse the jury

Evidence (4)

Informal
Blood drops collected at Bundy crime scene
discussed as subject of cross-contamination hypothetical
Informal
Blood drops from Rockingham estate
discussed as potentially cross-contaminated with Bundy drops during processing
Informal
Serology processing by Fung and Mazzola on June 13 evening and June 14 morning
cited by Neufeld as good faith basis for cross-contamination hypothesis
Informal
OJ Simpson's reference blood sample
referenced as processed simultaneously with Bundy drops during Yamauchi's serology work

Notable Exchanges (2)

Peter NeufeldGeorge ClarkeLance A. Ito
Extended argument over whether the defense has sufficient evidentiary foundation to hypothesize that Bundy and Rockingham swatches came into physical contact during lab processing. Neufeld argues simultaneous processing in the same room by Fung and Mazzola provides the basis; Clarke counters that testimony shows samples were processed one at a time with no mixing.
strategic
Marcia ClarkLance A. ItoPeter Neufeld
Clark asks Neufeld to lower his voice; Ito reveals he has made the same request approximately 18 times during the proceedings.
tense

Light Moments (1)

Lance A. Ito
Ito's exasperated comment that he has asked Neufeld to keep his voice down 'about 18 times' carries a weary, almost comedic resignation.

Credibility Attacks (1)

⚔ Dennis Fung / Andrea Mazzola
incompetence / procedural failure
Neufeld characterizes the evidence as 'poorly processed by Fung and Mazzola' to lay the groundwork for the cross-contamination hypothesis, implying their simultaneous handling of multiple samples created conditions for error

Objections

1 objections (0 sustained, 1 overruled)
Proceeding 6034 • 14 utterances
Criminal Trial
Department 103
⚖️ Start
📂 MAY 11, 1995 📄 Sidebar: hypothetical question
MAY 11, 1995 KRT DvH TD