📄 Cross-examination of Dr. Robin Cotton (part 2) — Monday, May 15, 1995
Address:
C:\DEPT103\CRIMINAL\1995\MAY\15\CROSS-EXAMINATION-OF-DR-ROBIN-.DOC
TRIAL
▲ Day 74 of 167

Cross-examination of Dr. Robin Cotton (part 2)

Witness: Dr. Robin Cotton
Examiner: Peter Neufeld
Called by: Prosecution • Date: Monday, May 15, 1995 • Utterances: 467
Peter Neufeld continued cross-examining Cellmark Diagnostics lab director Dr. Robin Cotton, focusing on two main areas: the mixed bloodstain on the Bronco steering wheel (item 29) and the absence of substrate control swatches for the Bundy walkway stains. Neufeld methodically established that the LAPD never sent Cellmark the substrate controls for items 47, 48, 50, and 52, and that Cellmark itself failed to run reagent blank controls during the initial extraction of items 49 and 50, undermining the integrity of the DNA evidence. The session also included heated bench conferences over Neufeld's courtroom conduct and repeated hearsay objections blocking his attempts to read from the NRC DNA report.
1 (The following proceedings were held in open court:)
2 (Discussion held off the record between Defense counsel.)
3 MR. NEUFELD:

One moment, your Honor.

4 (Brief pause.)
5 MR. CLARKE:

Could we see you briefly, your Honor? We would like to make a request of you.

6 THE COURT:

No. Let's proceed.

7 (Brief pause.)
8 THE COURT:

Mr. Neufeld.

9 MR. NEUFELD:

Thank you.

10 MR. NEUFELD:

Dr. Cotton, given the observed alleles on item 29, the mixed bloodstain on the steering wheel, there is a category here called "not excluded." Do you see that?

11 DR. COTTON:

Yes.

12 MR. CLARKE:

I'm sorry, your Honor. May I walk through so that I can see this chart?

13 THE COURT:

Certainly.

14 (Brief pause.)
15 MR. NEUFELD:

Sure.

16 MR. NEUFELD:

And the alleles observed again on sample 29 are 1.1, correct?

17 DR. COTTON:

Yes.

18 MR. NEUFELD:

1.2, correct?

19 DR. COTTON:

Yes.

20 MR. NEUFELD:

And finally the 4?

21 DR. COTTON:

Yes.

22 MR. NEUFELD:

And if we were able to make a separate column called "not excluded," you would agree--you would agree, Dr. Cotton, that Mr. Simpson could not be excluded as a contributor to this mixture; is that correct?

23 DR. COTTON:

That's right.

24 MR. NEUFELD:

So I'm going to add his name into the column of people who cannot be excluded. And would you agree that given the alleles in this mixture that Nicole Brown Simpson cannot be excluded?

25 DR. COTTON:

That's right, I agree.

26 MR. NEUFELD:

So I'm going to add her name to the column of people who cannot be excluded. Is that consistent with your testimony?

27 DR. COTTON:

Yes.

28 MR. NEUFELD:

And would you agree, Dr. Cotton, that also given the presence of the 4 allele, that anyone else who has a genotype for DQ-Alpha of either 4 comma 4, 4 comma 1.1 and 4 comma 1.2 cannot be excluded?

29 DR. COTTON:

Yes, I do.

30 MR. NEUFELD:

So may I add that collective person, if you will, as a third category under not excluded?

31 DR. COTTON:

Yes. That would be another group of people that wouldn't be excluded.

32 MR. NEUFELD:

Thank you.

33 MR. NEUFELD:

And is it consistent with your testimony if I simply describe this person as someone of either type 4 comma 4 or 4 comma 1.1 or 4 comma 1.2; is that correct?

34 DR. COTTON:

Yes.

35 MR. NEUFELD:

So but your testimony and your observations of this DQ-Alpha type then, it would be these three different listings under the "not excluded" column; is that correct?

36 DR. COTTON:

That's the three different listings you get if you are assuming three contributors. You can break it down in that manner--

37 MR. NEUFELD:

I'm not assuming anything.

38 MR. CLARKE:

I'm sorry, could the witness finish her answer, please?

39 THE COURT:

Yes.

40 MR. NEUFELD:

Please do.

41 DR. COTTON:

You could--you could simply also make a list of all the possible genotypes that could be in there and it would include the ones you have listed there, including the one for Mr. Simpson and the one for Nicole Brown.

42 MR. NEUFELD:

In your column where you have "not excluded," you didn't make an assumption that there was simply two donors, did you?

43 DR. COTTON:

No. We didn't make any assumption at all about how many donors there were.

44 MR. NEUFELD:

Right. So likewise, if we don't make any assumption as to how many donors there are in the categories of people not excluded, then would you agree then with the three different groupings that I have placed on Defendant's next in order--which would be what, your Honor?

45 THE COURT:

I believe it would be 1151.

46 MR. NEUFELD:

1151.

47 THE COURT:

1151.

48 (Deft's 1151 for id = chart)
49 MR. NEUFELD:

Is that correct, sir? Ma'am? Doctor? Excuse me. Long weekend. I apologize.

50 DR. COTTON:

Yeah. What I'm--you are correct, but what I'm trying to get--the point I'm trying to get to is that if you don't make any assumptions at all about how many donors there are in there, there are genotypes that aren't on your list.

51 MR. NEUFELD:

You wouldn't exclude a 1.1, 1.1? You wouldn't exclude a 1.2, 1.2? I'm sorry. 1.1 is on the list, isn't it?

52 DR. COTTON:

That's right. Okay.

53 MR. NEUFELD:

Isn't that Nicole Brown Simpson?

54 DR. COTTON:

You are right, I guess we have--

55 THE COURT:

Wait, wait, wait, wait, wait. First of all, you can't talk at the same time. Secondly, when I say "Wait," everybody stops, including you, Dr. Cotton, including you, Mr. Neufeld.

56 MR. NEUFELD:

I'm sorry.

57 THE COURT:

You can't argue with the witness and with the answer that she is giving. You get to ask questions and you get to give answers, doctor. Proceed.

KEY QUOTE
58 MR. NEUFELD:

Thank you.

59 (Discussion held off the record between Defense counsel.)
60 MR. NEUFELD:

With the Court's permission, your Honor, I would just like to be able to move the pad so the rest of the jurors can see it as well.

61 (Brief pause.)
62 THE COURT:

Mr. Neufeld.

63 MR. NEUFELD:

Thank you.

64 MR. NEUFELD:

Now, in terms of eliminating other possible contributors to this mixed stain, Dr. Cotton, are you aware that neither Dennis Fung or Andrea Mazzola could have contributed the no. 4 allele to this mixture?

65 MR. CLARKE:

Objection, assumes facts not in evidence.

66 THE COURT:

Sustained.

67 MR. NEUFELD:

All right. Let me ask you a hypothetical based on a good faith basis. May I just show something to the Court?

68 MR. CLARKE:

I'm sorry. Your Honor, may we approach the bench, please?

69 THE COURT:

Yes, with the court reporter.

70 (The following proceedings were held at the bench:)
71 MS. CLARK:

Your Honor, may I be heard on this? This has gotten out of hand and ridiculous.

72 THE COURT:

No, you may not.

73 MR. CLARKE:

Your Honor, this is outrageous in my view. Counsel is producing pieces of paper, attempting to show them in front of the jury as a basis for asking questions and is being demonstrative in front of the jury--let me finish, please--to be able to establish certain points to the jury. Now, I think that is absolutely outrageous conduct. It is done with a particular point to make in front of the jury. It is done--and I don't know about in New York it being proper, but it is clearly improper in a California courtroom, and I venture to say certainly in any courtroom, for counsel to be attempting to prove facts in front of the jury through an improper means, knowing that objections will be made to those acts and seeking to get across those points by the very acts themselves.

74 MS. CLARK:

Second time in twenty minutes.

75 THE COURT:

All right.

76 MR. CLARKE:

When the Court takes that into consideration, along with what happened this morning, which was blatantly showing an item that had never been shown to us, had never been brought up with the Court and was knowingly objectionable, this is twice within the first short period of time and I think counsel needs to be told by the Court this cannot happen again.

77 MR. NEUFELD:

May I be heard, your Honor?

78 MR. CLARKE:

And--

79 THE COURT:

Wait. What is your hypothetical question?

80 MR. NEUFELD:

The hypothetical question--well, I can read it to you. I have it right there.

81 (Brief pause.)
82 MR. NEUFELD:

My understanding under California law is for a hypothetical I don't have to--I'm not limited to the facts that are actually in evidence if I have a good faith basis for asking the question. The hypothetical will be as follows, your Honor--

83 MR. CLARKE:

I'm sorry. Could counsel keep his voice down.

84 MR. NEUFELD:

A tow truck driver testified that the Bronco was locked when he towed it from Mr. Simpson's home to the LAPD print shed for safekeeping. Dennis Fung testified the Bronco was locked when he and Andrea Mazzola arrive at the print shed to collect the bloodstains the next morning. Assume that the LAPD ran DNA tests on some of the employees in the SID lab. And assume further that criminalist Dennis Fung and Mazzola were among the group tested. Would you agree as an expert that if their DQ-Alpha types did not include the no. 4 allele then they could not have contributed--

85 MR. CLARKE:

Adjust the volume.

86 MR. NEUFELD:

They could not have contributed the no. 4 allele to the mixture? That is it and this is the good faith basis for asking that question.

87 THE COURT:

Mr. Clarke.

88 MR. CLARKE:

I think it is just outrageous to take that report and parade it in front of the jury. I can't urge that to the Court enough, particularly since it has happened twice today. I think it is absolutely wrong. And I'm going to ask that the jury be admonished about this waving, showing exhibits that are absolutely improper in court.

89 THE COURT:

Do you object to the hypothetical question?

90 MR. CLARKE:

Yes.

91 THE COURT:

Why?

92 MR. CLARKE:

Because it assumes facts not in evidence at this point.

93 MS. CLARK:

Also improper foundation.

94 MR. CLARKE:

And it is also misleading because there is a second report that demonstrates, for instance, genotypes that are going to play a role of these particular individuals. Counsel is selectively picking various pieces of evidence to use with these witnesses, and the answer to the question isn't helpful; it is argumentative. This witness has already said the person has a 4 allele, whoever that it is. What good does it do to this jury to establish that this person doesn't have a 4 allele? We could take any of the detectives. I mean, we could go on forever and ever. Andrea Mazzola, for instance, to my knowledge, was never in the Bronco.

95 MR. NEUFELD:

I'm not--I'm not going on forever. I'm simply asking about the two other people who said they were at the Bronco collecting this stain. And frankly, the D1S80 result is completely irrelevant because as their witness has already testified once, you have an exclude--the person is excluded. All I want to show is that neither of these people could have contributed the no. 4 allele. Good faith basis.

96 MR. CLARKE:

I'm sorry; volume.

97 THE COURT:

All right. The objection is sustained.

98 (The following proceedings were held in open court:)
99 THE COURT:

Thank you, counsel. Proceed.

100 MR. NEUFELD:

One moment, your Honor.

101 (Discussion held off the record between Defense counsel.)
102 MR. NEUFELD:

Dr. Cotton, the first samples that were sent to you by the Los Angeles Police Department were sent on or about June 22nd, 1994; is that correct?

103 DR. COTTON:

That's right.

104 MR. NEUFELD:

At least initially the person that you were expected to contact with the results of your testing was Michele Kestler with the LAPD; is that correct?

105 DR. COTTON:

She was one of the contacts, yes. There were--there was another person who could also be a contact, if I remember correctly.

106 MR. NEUFELD:

Let me just show you a document to see if it refreshes your recollection on this point. Let me ask you this question: Were you, at least initially, instructed by the Los Angeles Police Department that the results should be communicated to Michele Kestler?

107 DR. COTTON:

Yes.

108 MR. NEUFELD:

And I believe on September 8, 1994, your laboratory prepared a report on DNA results, did it not?

109 DR. COTTON:

We have a lot of reports. Which one--

110 MR. NEUFELD:

The one dated September 8th?

111 DR. COTTON:

Yes, I found it.

112 MR. NEUFELD:

You found it?

113 DR. COTTON:

Yes.

114 MR. NEUFELD:

Okay. And that is a report written to Michele Kestler?

115 DR. COTTON:

That's right.

116 MR. NEUFELD:

And isn't it a fact that on September 12th of 1994 Cellmark actually faxed a copy of this report to Michele Kestler at the Los Angeles Police Department?

117 DR. COTTON:

We may have. I don't have all those records down here with me.

118 MR. NEUFELD:

Perhaps I can help you.

119 (Brief pause.)
120 MR. CLARKE:

I'm sorry, may I see what counsel is referring to, your Honor?

121 MR. NEUFELD:

Sure.

122 (Discussion held off the record between Deputy District Attorney and Defense counsel.)
123 MR. NEUFELD:

What is next in order, your Honor?

124 THE COURT:

152. Excuse me, 1152.

125 (Deft's 1152 for id = document)
126 MR. NEUFELD:

I will show you a document which has been marked as 1152 which is a five-page letter--five-page report, excuse me, and ask you if you can identify that document?

127 DR. COTTON:

Yes. This is a copy of the September 8th report, and although the fax cover is not here and I can't exactly read all the figures at the top, it seems to say "From Cellmark Diagnostics." I don't--I can't read any fax date on the top, however.

128 MR. NEUFELD:

If you look at the next page, or the page after where it seems to be a little bit clearer, can you see a date?

129 DR. COTTON:

There we go. Right, right, and the date is September 12th, 1994, at 1:45.

130 MR. NEUFELD:

Okay. So that would indicate, Dr. Cotton, thank you, that this September 8th report was faxed to Michele Kestler at the Los Angeles Police Department on September 12th, 1994?

131 DR. COTTON:

Yes.

132 MR. NEUFELD:

Now, did Cellmark disclose the results in that report to anyone, other than Michele Kestler, during the month of September?

133 DR. COTTON:

No.

134 MR. CLARKE:

Objection, relevance.

135 THE COURT:

Overruled.

136 MR. NEUFELD:

Did Cellmark disclose any of the results contained in that report of September 8th to anyone in the media?

137 MR. CLARKE:

Same objection.

138 DR. COTTON:

Absolutely not.

139 THE COURT:

Overruled.

140 MR. NEUFELD:

Are you aware, Dr. Cotton, that there were certain media reports on September 12th concerning the results?

141 MR. CLARKE:

Objection, assumes facts not in evidence.

142 THE COURT:

It is irrelevant.

143 MR. NEUFELD:

I want to ask you some questions, Dr. Cotton, about the substrate controls in this case. All right?

144 DR. COTTON:

Sure.

145 MR. NEUFELD:

Now, in this case Andrea Mazzola testified that she created substrate control swatches for every stain that she collected at Bundy and Rockingham. Are you aware of that, by the way?

146 MR. CLARKE:

Objection, relevance.

147 THE COURT:

Overruled.

148 DR. COTTON:

Umm, no. I've watched little bits and pieces of testimony here and there, but I have not listened to the entirety. I didn't have time to do that, so I'm not--

149 MR. NEUFELD:

Now, you stated--okay, thank you. You stated on direct examination, Dr. Cotton, that testing the substrate control swatch can be informative if the testing of that swatch reveals the presence of DNA; is that correct?

150 DR. COTTON:

Yes.

151 MR. NEUFELD:

And would you agree that if DNA is found, one explanation could be that there were certain biological materials in the area immediately adjacent to the bloodstain?

152 DR. COTTON:

Yes, that would be the interpretation.

153 MR. NEUFELD:

And would you agree that another explanation, Dr. Cotton, could be that both the blood stained swatch and the substrate control swatch were cross-contaminated at some point after the collection of the evidence? Is that another possible interpretation?

154 DR. COTTON:

If you are testing the substrate control and you found DNA on it, then that would say that your first explanation would be correct and the other explanation which you just said is that it could have been contaminated later, but it doesn't say anything about whether the actual piece of evidence was contaminated later. It only says something about that substrate control.

155 MR. NEUFELD:

I know, but as an expert in the field, Dr. Cotton, if you saw that--if you thought that there may have been a cross-contamination of that substrate control and the substrate control was also handled all the way along the process of the evidentiary stains, would that cause you to consider the possibility in your mind that the evidentiary stains may also have been cross-contaminated?

156 MR. CLARKE:

Objection, irrelevant. Also assumes facts not in evidence.

157 THE COURT:

Overruled.

158 DR. COTTON:

It certainly would say--it would raise that possibility in your mind, but it wouldn't tell you definitely one way or the other.

159 MR. NEUFELD:

Okay.

160 DR. COTTON:

It wouldn't tell you anything.

161 MR. NEUFELD:

Well, it would tell you that you should be concerned about that possibility; is that correct?

162 DR. COTTON:

Yes, but being concerned about it and knowing something aren't the same thing.

163 MR. NEUFELD:

Well, I think you also said that you can't know for sure whether there was cross-contamination with a sample before you ever received it anyway; isn't that right?

164 DR. COTTON:

Of course.

165 MR. NEUFELD:

Well, would you agree with the following proposition, Dr. Cotton: When a stain of blood is analyzed with PCR it is important to analyze the unstained materials next to the stain with PCR as a control for contamination?

166 DR. COTTON:

I think it is--I think you can--I know you can do that. Sometimes, depending on the nature of the evidence, it may be more important to do that than other times. We do not in our laboratory routinely request a substrate control. If we are requested to do one, of course we do it, but we do not routinely request one, or if we are given a big stain, we don't routinely take one, because it is--it is not always going to be informative, depending on the nature of the evidence.

167 MR. NEUFELD:

So what you are saying is that it is your policy to defer to the submitting agency as to whether or not the control swatches get analyzed?

168 DR. COTTON:

That is what we would generally do.

169 MR. NEUFELD:

Now, just getting back to the proposition that I asked you about, Dr. Cotton, would you agree that it is important to analyze the control swatch at the same time for PCR testing as you analyze the evidentiary stain?

170 DR. COTTON:

I don't think it makes any difference if you do it one way or the other.

171 MR. NEUFELD:

But do you believe it is important to do it?

172 MR. CLARKE:

Objection, vague.

173 THE COURT:

Overruled.

174 DR. COTTON:

I'm not sure what you are asking me. Are you asking me is it important to at the same time that you do the DNA extraction from the evidence swatch that you do the DNA extraction from the control swatch at the same time?

175 MR. NEUFELD:

Did you say on direct examination, Dr. Cotton, that it is important, when you have a certain kind of control, be it a negative control or a positive control, that the control should be run in parallel to the actual evidentiary items?

176 DR. COTTON:

Well, I said you should run a reagent blank control in parallel to the actual items.

177 MR. NEUFELD:

And did you also say that you should run the amplification control in parallel to the items?

178 DR. COTTON:

Yes, the negative reagent--the negative control that you set up at the time of amplification is always run in parallel.

179 MR. NEUFELD:

Did you also say that you should run the positive control in parallel--

180 DR. COTTON:

Yes.

181 MR. NEUFELD:

--to the other items of evidence?

182 DR. COTTON:

Yes.

183 MR. NEUFELD:

And you said on direct examination that another type of control that exists is this substrate control; isn't that correct?

184 DR. COTTON:

That's right.

185 MR. NEUFELD:

So my question, Dr. Cotton, is would you agree with the following proposition: That when the bloodstain is analyzed for PCR it is important to analyze at the same time the unstained material which makes up the substrate control?

186 DR. COTTON:

No, I don't think that--I don't think it is important. I think you can do it later and it will still give you the same information as if you do it at the same time.

187 MR. NEUFELD:

So what you are saying, and correct me if I am misstating it, Dr. Cotton, that as long as you do it later, when you do it is not critical?

188 DR. COTTON:

That's what I'm saying.

189 MR. NEUFELD:

Now, in this case, Dr. Cotton, you received blood-stained items, swatches from items 47, 49, 50 and 52 last summer; isn't that right?

190 DR. COTTON:

Yes.

191 MR. NEUFELD:

And is it also true that when the LAPD sent you those items representing stains from the Bundy walkway, they failed to send you substrate control swatches for the same items?

192 MR. CLARKE:

Objection, argumentative.

193 THE COURT:

Sustained. Rephrase the question.

194 MR. NEUFELD:

When the Los Angeles Police Department sent you last summer the blood-stained swatches for items 47, 49, 50 and 52, did they send you the substrate control swatches for the same items?

195 DR. COTTON:

No, they didn't.

196 MR. NEUFELD:

And in October of 1994 you received the blood-stained swatches for item no. 48, did you not?

197 DR. COTTON:

You will have to let me check my sheets first.

198 (Brief pause.)
199 DR. COTTON:

Can you give me some kind of number that I'm looking for here?

200 MR. NEUFELD:

Umm--

201 DR. COTTON:

Or specifically a date?

202 MR. NEUFELD:

October 12. On or about October 12.

203 (Brief pause.)
204 MR. NEUFELD:

If you take a look in your report dated November 11, 1994, you may see a reference.

205 DR. COTTON:

Okay. Great. Thank you.

206 (Brief pause.)
207 DR. COTTON:

Okay.

208 MR. NEUFELD:

Is that correct, that on or about October 12th you received blood-stained--two blood-stained swatches representing what was purported to represent item 48?

209 DR. COTTON:

Yes, but I think that was the actual item 48. I got a lot of stuff here, so let me go back, okay?

210 MR. NEUFELD:

Sure.

211 DR. COTTON:

All right.

212 (Brief pause.)
213 (Discussion held off the record between Defense counsel.)
214 MR. NEUFELD:

Dr. Cotton, I may have created a misunderstanding and not as been as clear as I should have been there in my question, and perhaps I could save you some time. Isn't it true that on or about October 12th, 1994, that you received two blood-stained swatches which were labeled item 48 from the Los Angeles Police Department?

215 DR. COTTON:

Yes.

216 MR. NEUFELD:

Okay. And in that same shipment did they send you the control swatch, substrate control swatch for item 48?

217 DR. COTTON:

Yes.

218 MR. NEUFELD:

And what record do you have of that--of receiving that control swatch on that date?

219 DR. COTTON:

We have a log-in for item no. 48 with a "C" after it.

220 MR. NEUFELD:

Well, let me ask you this question: In the report that I just referred you to--

221 DR. COTTON:

The--

222 MR. NEUFELD:

--which you referred you to which referred to the October 12th date, didn't that say that you only received two swatches, both of which were stained?

223 DR. COTTON:

Yes.

224 MR. NEUFELD:

It doesn't refer to an unstained swatch being received in that shipment, does it?

225 DR. COTTON:

It doesn't, but we have a statement in our--I'm sorry, I misspoke. I'm only finding the information about item 48 itself in this report with the types from item 48.

226 MR. NEUFELD:

Which would be the stained, the blood-stained portions, correct?

227 DR. COTTON:

That's right. That is why I'm getting confused. I'm not finding what you are referring to and I don't know if it is simply not here or I'm not finding it.

228 MR. NEUFELD:

Well, there is no indication anywhere in your report that you received the substrate control swatch for item 48 in that shipment on October 12th; isn't that right?

229 DR. COTTON:

That's right.

230 MR. NEUFELD:

And since you did not receive from the Los Angeles Police Department the substrate control swatches for those five--for the stains from the purported Bundy drops, would it be fair to say that you also did not run control swatches when you actually did the DNA testing on the evidence itself?

231 DR. COTTON:

We didn't run any control swatches on that early set of evidence at the time that we analyzed that group of samples.

KEY QUOTE
232 MR. NEUFELD:

And would it be fair to say, Dr. Cotton, as an expert, that since the Los Angeles Police Department did not ship to you the substrate control swatches for the Bundy walkway stains at the same time as the evidentiary stains, that you have no knowledge regarding how these control swatches were handled since their purported collection to the present?

233 DR. COTTON:

That would--that would be true, however, we did receive some control swatches later and I would have to look at which samples those were control swatches for. To say I had no knowledge--

234 MR. NEUFELD:

All right. Well, let's start out with the first step.

235 DR. COTTON:

Okay.

236 MR. NEUFELD:

Assuming for a moment that you did receive some control swatches much more recently--is that what you are saying?

237 DR. COTTON:

Yes, that is what I'm saying.

238 MR. NEUFELD:

Okay. Certainly based on the fact that you didn't receive the control swatches along with the evidentiary stains, last summer and in October, would you agree that you have no knowledge regarding how those control swatches were handled since their purported collection up until the time much more recently that you received any of those control swatches?

239 DR. COTTON:

Yes, that--of course that would be the case.

240 MR. NEUFELD:

And Dr. Cotton, in this case there was also testimony that--by Andrea Mazzola that when she testified or August 23rd, 1994, that she had testified that she put her initials on bindles that she processed on the morning of June 14th. My question to you, Dr. Cotton, is do your records reflect that any of the bindles that you received from the Los Angeles Police Department bore Mazzola's initials?

241 MR. CLARKE:

Objection, argumentative, the first portion.

242 THE COURT:

Sustained. Rephrase the question.

243 MR. NEUFELD:

Do your records have Andrea Mazzola's initials on any of them--I'm sorry. Do your records reflect that on the bindles that you received, whether Andrea Mazzola's initials appeared on any of those bindles?

244 DR. COTTON:

They don't reflect whether they do or don't. That is, we wouldn't be writing that down. We would be writing down what was inside the bindle.

245 MR. NEUFELD:

Did you look at bindles yourself when they came in?

246 DR. COTTON:

On the original pieces of evidence or the control swatches later on?

247 MR. NEUFELD:

The original pieces of evidence?

248 DR. COTTON:

We did look at them and we--this is on the first group of stuff that we received, yes, we did look at them.

249 MR. NEUFELD:

And to the best of your recollection isn't it a fact that Miss Mazzola's initials were not on any of those bindles?

250 DR. COTTON:

I don't have any specific recollection. It is not a piece of information that I would have been likely to remember.

251 MR. NEUFELD:

Now, Dr. Cotton, you said that you did receive some control swatches more recently; is that right?

252 DR. COTTON:

Yes, we did.

253 MR. NEUFELD:

Would that be in April, this past April of 1995?

254 DR. COTTON:

Yes, it would.

255 MR. NEUFELD:

And isn't it a fact, Dr. Cotton--I'm sorry. Would that be the only time you received any control swatches in this case?

256 DR. COTTON:

I believe those are the only swatches that we received.

257 MR. NEUFELD:

Okay. Would it be fair to say, Dr. Cotton, that from the very first time you received item 47 in this case until today as you sit on this witness stand, that the Los Angeles Police Department never sent to you the substrate control swatch for item 47?

258 DR. COTTON:

Yes, that would be correct.

259 MR. NEUFELD:

And so item 47's control swatch has never been examined or tested by your laboratory?

260 DR. COTTON:

That's right.

261 MR. NEUFELD:

Would it be fair to say, Dr. Cotton, that from the time they first sent up item 48 in this case until today as you sit on this witness stand, the Los Angeles Police Department never sent you the substrate control for item 48?

262 DR. COTTON:

That's correct.

263 MR. NEUFELD:

Dr. Cotton, apparently they did send you, on April 4th, material labeled item 49, but it doesn't say it was the item 49 control; isn't that correct?

264 DR. COTTON:

It didn't state on the label the word "control."

265 MR. NEUFELD:

It just said "item 49," correct?

266 DR. COTTON:

That's right.

267 MR. NEUFELD:

All right. So do you have independent knowledge as to whether you received on April 4th the control for item 49 or did you just receive a portion of item 49?

268 DR. COTTON:

I have photographs in the case folder of what that item looked like, but I don't have any on-paper writing that says anything other than item 49.

269 MR. NEUFELD:

Okay. So you have no document or record which reflects that you received the control for item 49 either in that batch; is that correct?

270 DR. COTTON:

That's what I just said.

271 MR. NEUFELD:

Now, I call your attention to item 50, the fourth of those stains at the Bundy location. From the date that you first received item no. 50, the evidentiary stains, until today, as you sit here on this witness stand, have you ever received the substrate control swatch for item no. 50?

272 DR. COTTON:

No, we haven't.

273 MR. NEUFELD:

Finally, for item no. 52, Dr. Cotton, on the day you received the evidentiary portion of item 52 until today as you sit here on this witness stand, has the Los Angeles Police Department ever sent to you the substrate control swatch for item 52 for DNA analysis?

274 DR. COTTON:

No, they haven't sent it to us.

275 MR. NEUFELD:

In your laboratory, Dr. Cotton, is there a standard procedure that every employee who removes or puts something into a bindle puts his or her initials on the bindle?

276 DR. COTTON:

Yes.

277 MR. NEUFELD:

And are you familiar with the practices in other laboratories, Dr. Cotton?

278 DR. COTTON:

Not particularly.

279 MR. NEUFELD:

Well, Dr. Cotton, to the extent that you have expertise in this area, would you agree that it is a standard procedure at every forensic science laboratory to have an individual who either removes or puts something into a bindle to initial that bindle?

280 DR. COTTON:

I can really only speak for what we do in our laboratory, and when we take something in and out the bindle is taped and initials are put across the tape and the adjacent paper.

281 MR. NEUFELD:

Now, referring to another type of control, Dr. Cotton, you mentioned something called a reagent blank; is that right?

282 DR. COTTON:

Yes, I did.

283 MR. NEUFELD:

And is the reagent blank sometimes referred to as an extraction blank also?

284 DR. COTTON:

Yes.

285 MR. NEUFELD:

And is that because this control starts at the beginning of the processing of the sample at the laboratory when you first extract the DNA from the sample?

286 DR. COTTON:

That's exactly right.

287 MR. NEUFELD:

And am I correct in saying, Dr. Cotton, that a reagent blank is simply a tube without any DNA in it that gets processed along with all the other evidentiary samples?

288 DR. COTTON:

Yes. Generally that is what it is, or it could, on rare occasions, contain--if you had to swab a stain off of something, if we had to do that in the lab and that hadn't previously been done for us, we might include a piece of the swab before it was used, so it is not always absolutely empty, but most of the time it is.

289 MR. NEUFELD:

And generally, at least in this case, that is what you meant by a reagent blank, one that was empty?

290 DR. COTTON:

That's right.

291 MR. NEUFELD:

One moment.

292 (Discussion held off the record between Defense counsel.)
293 MR. NEUFELD:

Now, if at the end of all those steps that comprise the DNA typing procedure, Dr. Cotton, the reagent blank tests positive for the presence of DNA, it means the control failed; is that correct?

294 DR. COTTON:

You are putting a very black and white interpretation on there. It means that you have some DNA that was in there at some point, and that is not a term to say a control failed. That almost means to me that the control didn't provide you with the information that you need, instead of did, so--

295 MR. NEUFELD:

Well--

296 DR. COTTON:

--I--I wouldn't choose that term myself.

297 MR. NEUFELD:

All right.

298 DR. COTTON:

But it does mean that you have some DNA in there that you normally would not expect to have in there.

299 MR. NEUFELD:

Well, it is not just normally, Dr. Cotton. The way you run your experiment and the reason you have this reagent blank is--and the way it is run in this case, for instance, is because if the test is run correctly, there shouldn't be any DNA in the reagent blank at the end of all those steps when you analyze it; isn't that correct?

300 DR. COTTON:

That is exactly right, yes.

301 MR. NEUFELD:

And in fact, if you do see the presence of DNA, it means that the experiment was not a success? Would you agree with that?

302 DR. COTTON:

Well, again, it is the same thing. It is--it is informative. It doesn't necessarily mean your results are wrong if you equate wrong with success or correctness with success. That doesn't mean your results are wrong. It does mean that you want to go back and possibly redo it, possibly, you know, relook at what you did. You might only go back--if you thought something had happened just at the very last part, you might want to just go back and do the very last part. That means you want to go back and look at what you've done carefully.

303 MR. NEUFELD:

Well, Dr. Cotton, if in fact you see DNA profile in the reagent planning, which is supposed to have no DNA in it, could that also mean that evidentiary specimens that were processed at the same time as the reagent blanks were contaminated by some form of DNA?

304 DR. COTTON:

It could mean that.

305 MR. NEUFELD:

In fact, isn't that one of the dangers? When you see a DNA profile in what should be a negative control, isn't that an indication of the possibility that contamination or cross-contamination occur early on in the process?

306 DR. COTTON:

It indicates that that could have happened, yes.

307 MR. NEUFELD:

In fact--now, the first two items of evidence that you received in this case were items 49 and 50; is that right?

308 DR. COTTON:

That's right.

309 MR. NEUFELD:

And when you received each of those two items, Dr. Cotton, I believe you said you cut off ten percent for future testing and you began your testing on the remaining ninety percent; is that right?

310 DR. COTTON:

That's right.

311 MR. NEUFELD:

And so the first step that you undertook when you received those two samples in June of 1994, was to extract the DNA from the ninety percent portion of those two samples; is that correct?

312 DR. COTTON:

Yes, that's correct.

313 MR. NEUFELD:

And this extraction of items--of DNA from items 49 and 50, this was done before Dr. Blake and Dr. Lee even visited your laboratory; isn't that correct?

314 DR. COTTON:

That's right.

315 MR. NEUFELD:

After the extraction process, Dr. Cotton, you took a small portion of the extracted DNA and you ran I think what you described as either a test gel or a yield gel to determine approximately how much DNA is present?

316 DR. COTTON:

That's right.

317 MR. NEUFELD:

And is that what you actually did with items 49 and 50?

318 DR. COTTON:

Well, I didn't actually do it myself, but that is what was done with 49 and 50.

319 MR. NEUFELD:

And as to both items 49 and 50, when that little mini gel test was run, you concluded that there was too little DNA present for RFLP testing; is that correct?

320 DR. COTTON:

We concluded it was too degraded for RFLP testing.

321 MR. NEUFELD:

Okay. Now, in some situations, Dr. Cotton, after you take that small portion of the ninety percent and do that test, would you be able to recycle the balance of the ninety percent to use for other forms of testing, such as PCR testing?

322 DR. COTTON:

Only--we would only do that if we had run a reagent blank control during that DNA extraction.

323 MR. NEUFELD:

If you had run a reagent blank control that we just described during that port--excuse me--during that part of the process of items 49 and 50, then you would be able to recycle the balance of that ninety percent of the unused DNA; is that right?

324 DR. COTTON:

That's correct.

325 MR. NEUFELD:

But in this case, Dr. Cotton, your laboratory simply didn't run a reagent blank negative control for items 49 and 50; is that correct?

326 DR. COTTON:

Not at the time that we did that first extraction.

327 MR. NEUFELD:

And so for use 49 and 50, at least to the bulk of the ninety percent that you received, it could not be recycled for PCR testing, could it?

328 DR. COTTON:

Well, you could do it. You simply wouldn't have a reagent blank control to run along with it, so we did not use that initial extracted DNA when we did our PCR test on that sample.

329 MR. NEUFELD:

Well, the reason you didn't use the balance of that ninety percent portion is because you could not know for sure whether or not there was some contamination that occurred with respect to items 49 and 50 without having a reagent blank; isn't that right?

330 DR. COTTON:

Yes, we couldn't know what had happened during that DNA extraction.

KEY QUOTE
331 MR. NEUFELD:

And so to be scientifically cautious, you didn't use that portion of 49 and 50 which you failed to use a reagent blank on for follow-up PCR testing; is that correct?

332 DR. COTTON:

That's right.

333 MR. NEUFELD:

Does your laboratory keep a centralized log indicating the number of times that you failed to run a particular control?

334 DR. COTTON:

No, we don't have any kind of log like that. There are--there--never mind. We don't have a log like that.

335 MR. NEUFELD:

All right. Dr. Cotton, do you agree with the following proposition: If a negative control is positive in one experiment, it indicates a potential problem, not just for that experiment but for any experiment performed by the laboratory at about the same time?

336 DR. COTTON:

I agree that that might be the case, but in other words, it might--it might indicate that there were problems with other experiments or it might indicate there was a problem just with the one thing that you did, and you would have to go back and look at other things to make that determination.

337 MR. NEUFELD:

Well, that is all--

338 DR. COTTON:

So I guess I don't agree with that statement.

339 MR. NEUFELD:

You don't agree with it?

340 DR. COTTON:

Not completely, no.

341 MR. NEUFELD:

Well the statement simply indicates a potential problem, not a definitive problem?

342 DR. COTTON:

Okay. I will go for potential problem.

343 MR. NEUFELD:

Would you agree with that?

344 THE COURT:

Wait, wait, wait.

345 MR. NEUFELD:

Sorry.

346 MR. NEUFELD:

Let me repeat the proposition one more time, Dr. Cotton.

347 MR. NEUFELD:

If a blank control is positive in one experiment, it indicates a potential problem, not just for that experiment, but for any experiment performed at about the same time? Would you agree with that proposition.

348 MR. CLARKE:

Objection, asked and answered.

349 THE COURT:

Overruled.

350 DR. COTTON:

I would agree with that statement as you read it, yes.

351 MR. NEUFELD:

Okay. And Dr. Cotton, are you familiar with that portion of the National Academy of Science report, "DNA Technology in Forensic Science," which addresses the issue regarding the consequences of a control failure in PCR testing?

352 MR. CLARKE:

Objection, assumes facts not in evidence.

353 THE COURT:

Sustained.

354 MR. NEUFELD:

Well--

355 MR. CLARKE:

Also move to strike counsel's comments.

356 THE COURT:

Overruled. Ask Dr. Cotton if she is familiar with that part of the report.

357 MR. NEUFELD:

Are you familiar with the portion of the NRC report entitled "DNA Technology in Forensic Science" which addresses that same issue, the consequences of a control failure?

358 DR. COTTON:

Can you just tell me what the title of that section is?

359 MR. NEUFELD:

Page 67 of the NRC report, if you would like to take a look at it. It begins on 65 and runs through 67.

360 (Witness complies.)
361 MR. NEUFELD:

In particular, Dr. Cotton, could you take a look at one portion of that, just to save time.

362 DR. COTTON:

(Witness complies.) The statement that you just pointed out to me is the one that you just read to me.

363 MR. NEUFELD:

Okay. And in fact in your own copy of that book do you have that same statement underlined?

364 DR. COTTON:

Yes. I have many things highlighted in this book.

365 MR. NEUFELD:

And is that statement that I just read to you in fact one of the those statements?

366 DR. COTTON:

Yes.

367 MR. NEUFELD:

And is that a portion of the NRC report that you in fact relied upon in coming to an expert opinion as to the consequences of the control failure in PCR testing?

368 DR. COTTON:

I have read this portion of the book. I'm having a little trouble with this concept of "relied upon." I have read this portion of the book. I agree with some of it and I don't agree with other parts. I happen to agree with that statement, but if you ask me did I agree with and rely upon that whole section, I would have to say no.

369 MR. NEUFELD:

But--

370 THE COURT:

All right. She has indicated she agreed with the portion that you read.

371 MR. NEUFELD:

All right.

372 THE COURT:

All right. Next question.

373 MR. NEUFELD:

And when you read that paragraph, did you also read the very next sentence?

374 DR. COTTON:

Umm, not just this--not when I was looking at it just now.

375 MR. NEUFELD:

Okay. Please do.

376 MR. CLARKE:

I'm sorry, objection. Relevance.

377 THE COURT:

Overruled.

378 DR. COTTON:

Back on 67, right?

379 MR. NEUFELD:

Yes.

380 DR. COTTON:

(Witness complies.) I don't really agree with this next statement, but our laboratory hasn't been in that position, so I don't know--I don't really have a strong opinion one way or the other.

381 MR. NEUFELD:

Well, Dr. Cotton, would this be--portion of the NRC report, namely this next sentence, that you relied upon in reaching your own opinions as to what actions to take when there was a failure of a control in PCR testing?

382 DR. COTTON:

No.

383 (Discussion held off the record between Defense counsel.)
384 MR. NEUFELD:

One moment.

385 (Brief pause.)
386 MR. NEUFELD:

With the Court's permission may I read the entire sentence that she said she agreed with?

387 THE COURT:

We have been through this already.

388 MR. NEUFELD:

As I stated as a proposition, a portion of the sentence. She has now read the entire sentence and said that she agrees with it.

389 THE COURT:

Ask her the question.

390 MR. NEUFELD:

Thank you.

391 MR. NEUFELD:

Dr. Cotton, do you agree with the opinion of the scientist who authored the DNA technology and forensic science book or the National Academy of Science in which they say, quote--

392 MR. CLARKE:

Excuse me, objection, hearsay as framed.

393 THE COURT:

Sustained, as framed.

394 MR. NEUFELD:

Well--may we have a side bar, your Honor?

395 THE COURT:

No. Very simple hearsay issue, counsel. Proceed.

396 (Discussion held off the record between Defense counsel.)
397 MR. NEUFELD:

Dr. Cotton, a moment ago when you said you agreed with and relied on that sentence, were you referring to this sentence, and I quote--

398 MR. CLARKE:

Excuse me. Objection, misstates the evidence.

399 THE COURT:

Sustained.

400 MR. NEUFELD:

May I be heard on this issue, your Honor?

401 THE COURT:

Very simple hearsay issue, counsel. Move on.

402 MR. NEUFELD:

I would simply ask to make a record on the--on that issue, your Honor.

403 THE COURT:

No. Move on. The objection is sustained. You can make any argument at the break. We will break at 10:30.

404 MR. NEUFELD:

In your laboratory, Dr. Cotton, whenever there has been an instant--I'm sorry. One moment.

405 (Brief pause.)
406 MR. NEUFELD:

In your laboratory, Dr. Cotton, has there ever been an instance when in a similar period of time several different technicians saw DNA results on the negative controls where nothing should be visualized?

407 DR. COTTON:

Yes, we had that occur one time.

408 MR. NEUFELD:

And whenever there has been an instance when more than one technician or scientist observes a failure in the negative controls, do you document that phenomena in any laboratory-wide log?

409 DR. COTTON:

The instance is documented in terms of a report that goes to the quality control assurance manager and what was done to correct it also goes to her.

410 MR. NEUFELD:

So that there will be--

411 DR. COTTON:

In terms of a brief statement of this is what happened, this is what we did.

412 MR. NEUFELD:

So even at Cellmark there have been occasions where the negative controls failed?

413 DR. COTTON:

Yes, and I want to--

414 MR. CLARKE:

Excuse me--

415 DR. COTTON:

I want to be very clear about what I'm saying. We had one instance in which the negative control that is set up at the time of amplification was giving us a signal and we had to go back and figure out that that negative control just--turned out that it by itself was contaminated, but it could have been some other result. And anyway, we had to stop doing what we were doing, go back and figure that out and then restart testing.

416 MR. NEUFELD:

And would it be fair to say, Dr. Cotton, that for each and every time where you've had the negative control failure, you haven't been able to determine, by your investigation, exactly how the contamination occurred in every instance when it did occur?

417 MR. CLARKE:

Objection, misstates the evidence.

418 THE COURT:

Sustained. Rephrase the question.

419 MR. NEUFELD:

Well, there have been more than one occasion where a negative control has failed; is that correct?

420 DR. COTTON:

No. What I--what I'm trying to tell you is there was one instance where we saw that, and I'm calling it one instance because it was confined to a period of one or two days. And so--so it wasn't just one test. Let me be clear. It wasn't just one test. There were several tests done over that period of two days, but it was this period of a couple of days that we had this problem, and that is the only period of time that we have had that particular problem.

421 MR. NEUFELD:

So with respect to having that particular problem where the negative control failed over a period of one or two days in multiple tests, were you able to determine the precise cause for that failure?

422 DR. COTTON:

We were able to--the--the answer is really no, we didn't know the precise cause.

423 MR. NEUFELD:

One moment.

424 (Discussion held off the record between Defense counsel.)
425 MR. NEUFELD:

And Dr. Cotton, in your laboratory when that phenomena occurred over a period of one or to days in multiple tests seeing DNA in the negative controls where it shouldn't be, would you refer to that phenomena as an outbreak of contamination?

426 DR. COTTON:

I didn't refer to it like that, no.

427 MR. NEUFELD:

Would you say that that is a fair characterization of it?

428 DR. COTTON:

No.

429 MR. NEUFELD:

Have you ever heard that term before?

430 DR. COTTON:

I've heard it in court before. I have not heard it in scientific discussions.

431 (Discussion held off the record between Defense counsel.)
432 MR. NEUFELD:

You just said a moment ago that you only heard it in court proceedings and not in scientific papers; is that correct?

433 DR. COTTON:

I said discussions. That is discussions I've had or--I can only talk about what--discussions I've had, discussions I've had with people in other laboratories or in my own laboratory. If we have one instance of contamination, we don't generally refer to it as an outbreak. It sounds like we are getting the measles or something and it is just not a term that I have heard used in discussing this potential problem with other scientists.

434 MR. NEUFELD:

Dr. Cotton, you said that you read the NRC report many times; is that right?

435 DR. COTTON:

Yes.

436 MR. NEUFELD:

And when you read the NRC report did you see them describe it as an outbreak of contamination?

437 MR. CLARKE:

Objection, irrelevant, calls for hearsay.

438 THE COURT:

Overruled.

439 DR. COTTON:

Well, they may well have. I don't know--I mean, if you look at all the stuff that I have to read, I cannot remember word for word what is in the NRC report, what is in our standard operating procedure and so forth, so if it is in there, fine, but--

440 MR. NEUFELD:

Dr. Cotton--

441 MR. CLARKE:

I'm sorry, could the witness finish her answer?

442 MR. NEUFELD:

Sorry.

443 DR. COTTON:

But it doesn't change the fact that when we discuss it in our lab and when I discuss it with other people that is not the terminology they used or I have heard anyone else use in the setting as I characterized it.

444 MR. NEUFELD:

Dr. Cotton, please go back and look at the very same page we just looked at a moment ago, page 67, and the very next paragraph.

445 MR. CLARKE:

Sorry, objection, hearsay.

446 THE COURT:

Overruled.

447 DR. COTTON:

(Witness complies.) Yes.

448 MR. NEUFELD:

Isn't it a fact that the NRC report states--

449 MR. CLARKE:

Objection, hearsay.

450 THE COURT:

Sustained.

451 MR. NEUFELD:

It is for a different purpose, your Honor.

452 THE COURT:

Sustained. Ask the question appropriately.

453 (Discussion held off the record between Defense counsel.)
454 MR. NEUFELD:

Isn't it a fact, Dr. Cotton, that the NRC report describes this phenomena?

455 MR. CLARKE:

Same objection, your Honor.

456 THE COURT:

Sustained. Dr. Cotton, you have reviewed that paragraph?

457 DR. COTTON:

Yes, sir. Yes, I have.

458 THE COURT:

All right. Does that refresh your recollection as to that terminology?

459 DR. COTTON:

They use the term "outbreaks of contamination" in this paragraph.

460 THE COURT:

Fine. Thank you.

461 MR. NEUFELD:

Thank you, your Honor.

462 MR. NEUFELD:

Do you agree, Dr. Cotton, that it is important to discover the source of an outbreak of contamination so that the laboratory can be cleansed of it?

463 DR. COTTON:

No, I don't agree that you must determine the source. Sometimes that is simply not possible.

464 THE COURT:

All right. Mr. Neufeld, the court reporter tells me she is about to run out of paper, so we will take our break at this point. Do you have one or two more wind-up--

465 MR. NEUFELD:

No, I don't. We can take our break right now.

466 THE COURT:

All right. Ladies and gentlemen, we are going to take a recess for the morning session. Please remember all of my admonitions to you. Do not discuss the case among yourselves, form any opinions about the case, don't conduct any deliberations until the matter has been submitted to you, don't allow anyone to communicate with you with regard to the case. And we will take a 15-minute recess.

467 (Recess.)

Temperature

tense

Key Quotes (5)

Dr. Robin Cotton
We didn't run any control swatches on that early set of evidence at the time that we analyzed that group of samples.
Admission that Cellmark failed to run substrate controls on the initial Bundy walkway stain evidence, a key defense argument about compromised chain of custody and contamination.
Dr. Robin Cotton
Yes, we couldn't know what had happened during that DNA extraction.
Concedes that without a reagent blank, contamination of items 49 and 50 during initial extraction cannot be ruled out.
Dr. Robin Cotton
It sounds like we are getting the measles or something and it is just not a term that I have heard used in discussing this potential problem with other scientists.
Colorful pushback on Neufeld's use of 'outbreak of contamination' — only to be contradicted moments later when Judge Ito asked her to read the NRC report paragraph, which used that exact term.
Lance A. Ito
You can't argue with the witness and with the answer that she is giving. You get to ask questions and you get to give answers, doctor. Proceed.
Ito rebukes Neufeld for talking over the witness, illustrating the tense courtroom dynamic throughout this session.
George Clarke
Counsel is producing pieces of paper, attempting to show them in front of the jury as a basis for asking questions and is being demonstrative in front of the jury... I think it is absolutely outrageous conduct.
Prosecution's bench objection captures the recurring conflict over Neufeld's courtroom tactics, which the prosecution viewed as deliberately prejudicial showmanship.

Evidence (5)

Defendant's 1151
Chart showing DQ-Alpha alleles observed in item 29 (Bronco steering wheel mixed bloodstain) with 'not excluded' categories for OJ Simpson, Nicole Brown Simpson, and others with 4-allele genotypes
Created and marked for identification during examination
Defendant's 1152
Cellmark's September 8, 1994 DNA results report faxed to Michele Kestler at LAPD on September 12, 1994
Marked for identification; used to confirm timing and recipient of Cellmark's first report
Informal
NRC report 'DNA Technology in Forensic Science,' pages 65-67, addressing consequences of control failures in PCR testing and 'outbreaks of contamination'
Referenced and read from; repeated hearsay objections blocked direct quotation into record; Ito resolved by asking Cotton directly whether it refreshed her recollection
Informal
Items 47, 48, 49, 50, 52 — blood-stained swatches from Bundy walkway drops
Discussed; Neufeld established that substrate controls for 47, 48 (as documented), 50, and 52 were never sent to Cellmark; item 49 control receipt was undocumented
Informal
Item 29 — mixed bloodstain from Bronco steering wheel
DQ-Alpha alleles (1.1, 1.2, 4) discussed; 'not excluded' contributors identified as OJ Simpson, Nicole Brown Simpson, and any person with a 4-containing genotype

Notable Exchanges (4)

Peter NeufeldGeorge ClarkeMarcia ClarkLance A. Ito
Extended bench conference in which Clarke accused Neufeld of twice showing documents to the jury without court approval to make points through 'improper means,' knowing objections would be raised. Ito sustained the objection to the hypothetical about Fung and Mazzola's DQ-Alpha types but did not formally admonish the jury.
heated
Peter NeufeldDr. Robin CottonLance A. Ito
Neufeld attempted to get Cotton to agree that the NRC report used the term 'outbreaks of contamination.' Cotton resisted, saying the term was not used in scientific discussions — only in court. Ito cut through repeated hearsay objections by simply asking Cotton directly whether the paragraph refreshed her recollection, forcing her to confirm the NRC did use that exact term.
strategic
Peter NeufeldDr. Robin Cotton
Neufeld systematically walked through items 47, 48, 49, 50, and 52 one by one, confirming for each that Cellmark never received the substrate control swatch from LAPD. Cotton was forced to concede each point, building a cumulative picture of missing controls across all Bundy walkway evidence.
methodical/revealing
Peter NeufeldDr. Robin Cotton
Neufeld established that Cellmark failed to run a reagent blank during the initial extraction of items 49 and 50, and that as a result Cellmark could not reuse the extracted DNA for PCR testing — because contamination could not be ruled out.
revealing

Light Moments (3)

Peter Neufeld
Neufeld accidentally addressed Dr. Cotton as 'sir,' then corrected himself: 'Excuse me. Long weekend. I apologize.'
Dr. Robin Cotton
Cotton compared Cellmark's contamination episode to 'getting the measles,' rejecting the NRC's own term 'outbreak of contamination' as unscientific — only to have Ito ask her to read the paragraph aloud, confirming the NRC used that exact word.
Lance A. Ito
Court reporter ran out of paper mid-session, prompting Ito to offer Neufeld 'one or two more wind-up' questions. Neufeld declined and took the break.

Credibility Attacks (2)

⚔ LAPD / Cellmark procedures
Omission / failure to follow protocol
Neufeld established that substrate controls for items 47, 48 (no documentation), 50, and 52 were never sent to Cellmark, and that Cellmark itself failed to run reagent blank controls during initial extraction of items 49 and 50, leaving open the possibility of contamination that cannot be detected or disproven.
⚔ Dr. Robin Cotton
Prior inconsistent statement / learned treatise
Neufeld used Cotton's own highlighted copy of the NRC report to confront her testimony that 'outbreak of contamination' was not scientific terminology — she ultimately had to concede the NRC used the term on the very page she had highlighted.

Witness Demeanor

Cotton was precise and resistant to Neufeld's framing throughout, frequently qualifying her answers ('I want to be very clear') and pushing back on loaded propositions.
At several points Cotton acknowledged she was confused by the volume of documents ('I don't know if it is simply not here or I'm not finding it') before locating the relevant records.
Cotton showed mild exasperation when Neufeld interrupted her mid-answer multiple times, prompting both Clarke's objections and Ito's direct intervention.

Objections

26 objections (11 sustained, 7 overruled)
Proceeding 6056 • 467 utterances • Prosecution witness
Criminal Trial
Department 103
⚖️ Start
📂 MAY 15, 1995 📄 Cross-examination of Dr. Robin
MAY 15, 1995 KRT DvH TD