📄 Sidebar: exhibit — Monday, May 15, 1995
📅 May 15 — Day 74
⚖️ Lance A. Ito🛡️ Peter Neufeld
chain_of_custodydnajury
Address:
C:\DEPT103\CRIMINAL\1995\MAY\15\SIDEBAR-EXHIBIT.DOC
TRIAL
▲ Day 74 of 167

Sidebar: exhibit

Date: Monday, May 15, 1995 • Utterances: 20
During a sidebar, Judge Ito ruled that a metallic label Peter Neufeld wanted to add to a prosecution DNA chart — reading 'third person identity unknown' — was argumentative and sustained Clarke's objection. Ito also admonished Neufeld for directly addressing jurors during examination, which is improper under California practice.
1 THE COURT:

Let me see counsel over at the side bar, please.

2 MR. NEUFELD:

Sure.

3 THE COURT:

With the reporter.

4 (The following proceedings were held at the bench:)
5 THE COURT:

Why don't you show Mr. Clarke what it is you were posting on there.

6 MR. NEUFELD:

Sure. Similar to what they did on the blood vial that we put up. I can't put up something permanent, so I have a metallic piece that simply adds another category of people who cannot be excluded by this result, which is simply a third person.

7 THE COURT:

Keep your voice down. One other thing. Do not directly address the jurors other than to say good morning. All right. On about four or five occasions you have directly addressed jurors. That is not appropriate in California.

8 MR. NEUFELD:

You mean the jurors at all?

9 THE COURT:

You can say good morning to them. You can't speak directly to them.

10 MR. NEUFELD:

Okay. I'm sorry about that. I really was unaware.

11 THE COURT:

What you--

12 MR. NEUFELD:

So I did something neutral. I didn't try and put who the person was. I just said "third person identity unknown," as another class of people who cannot be excluded by this typing and obviously the person has the 4 allele.

13 THE COURT:

Mr. Clarke.

14 MR. CLARKE:

The first item is Mr. Neufeld was just asked, immediately prior to court, did he have any new exhibits that he was going to seek to use and he said no. That is the first objection. The second relates to, first of all, I don't want and I think the Court should not allow any alteration of our charts whatsoever. This represents an alteration of that chart. It cannot be preserved, shouldn't be preserved and it shouldn't be used on our chart. It is one point to point to items on the chart, have testimony and so forth, but I think any alteration is improper. And third of all, this is clearly misleading because there is no evidence that there is a third person. All we know is two people cannot be excluded, as are ten people couldn't be excluded, but to reach the conclusion as this does, a third person identity unknown, is contrary to the facts of this case.

15 THE COURT:

All right. I find this to be argumentative, counsel.

16 MR. NEUFELD:

Your Honor, the objection about altering the board, I'm not altering the board.

17 THE COURT:

I'm not worried about that. I find that to be argumentative.

18 MR. NEUFELD:

I deliberately picked "third person identity unknown" because it is not argumentative, your Honor.

19 THE COURT:

It is. It is. Sustained. Sustained.

KEY QUOTE
20 MR. CLARKE:

Your Honor--

Temperature

tense

Key Quotes (4)

George Clarke
this is clearly misleading because there is no evidence that there is a third person. All we know is two people cannot be excluded, as are ten people couldn't be excluded, but to reach the conclusion as this does, a third person identity unknown, is contrary to the facts of this case.
Articulates the prosecution's core objection: Neufeld's label overstates the DNA result by implying a third unknown person exists.
Peter Neufeld
I deliberately picked 'third person identity unknown' because it is not argumentative, your Honor.
Neufeld pushes back, arguing the phrasing is neutral — Ito immediately disagrees twice.
Lance A. Ito
It is. It is. Sustained. Sustained.
Emphatic double ruling signals Ito's impatience with the defense's framing attempt.
Lance A. Ito
Do not directly address the jurors other than to say good morning. All right. On about four or five occasions you have directly addressed jurors. That is not appropriate in California.
A procedural admonishment that reveals Neufeld's unfamiliarity with California courtroom norms — he is a New York attorney.

Evidence (2)

Informal
Prosecution DNA typing chart (previously introduced)
Defense attempts to add a metallic label reading 'third person identity unknown' to expand exclusion categories
Informal
Blood vial DNA chart used earlier by defense
Referenced by Neufeld as precedent for adding metallic overlay labels

Notable Exchanges (2)

George ClarkePeter NeufeldLance A. Ito
Clarke objects on three grounds: no notice of new exhibit, improper alteration of prosecution chart, and misleading inference of a third unknown person. Ito cuts past the first two and rules solely on argumentativeness.
strategic
Lance A. ItoPeter Neufeld
Ito admonishes Neufeld for directly addressing jurors on four or five occasions; Neufeld says he was genuinely unaware of the California rule.
procedural

Objections

3 objections (1 sustained, 0 overruled)
Proceeding 6055 • 20 utterances
Criminal Trial
Department 103
⚖️ Start
📂 MAY 15, 1995 📄 Sidebar: exhibit
MAY 15, 1995 KRT DvH TD