Thank you, ladies and gentlemen. Please be seated. Mr. Sims. All right. Let the record reflect that we have been rejoined by all the members of our jury panel. Mr. Scheck, you may continue with your cross-examination.
Mr. Sims, at the break you were kind enough to review your notes with me concerning those--the 21 samples. Do you recall that?
All right. And you indicated that the maximum number of samples that you processed from the initial cutting of the swatches to the reporting of results in one run was 21 samples, correct?
Yes, and that would include the quality control sample, the extraction blank and then substrate controls intervening the stains.
Right. Now, at the break you and I reviewed your notes as to how long--how long it took you to do that procedure with the 21 samples from beginning to end?
Altogether, between yourself and Miss Montgomery, who participated in the process, how many days did it take you to process those samples from beginning to end?
Can you imagine being able to process those samples, 21 samples from beginning to end, in one day?
Now, the--there are other kinds of precautions that one takes in terms of processing samples for purposes of forensic DNA typing, aside from the ones we've previously reviewed, in terms of which kind of samples one would handle at different times and different places?
Now, one kind of aerosol we have already discussed is the kind of spray that can occur when one opens up a tube?
Yes. If one has not spun it down, that is a concern because you can get liquid accumulating under the top of the cap.
Uh-huh. And this would apply also to one of these lavender-topped tubes that contains reference samples?
Well, they are under vacuum, so yes, that is a concern when you open one of those for the first time.
And when you open one of those for the first time, one has to be quite careful about the aerosol of whole blood from the reference tube?
And in pouring that out, let's say, onto one of these paper cards, one has to take great care?
Now, aside from aerosols from liquids, can one have aerosols from dried biological particles?
I don't know if they are possibly called aerosols, but you can have, for example, powdered blood, something like that. You have to be concerned about that.
Now, if one were to take a test-tube that contained blood swatches that had dried on the inside of the test-tube--
--and then one takes a pipette, holding the test-tube up and scrapes the bloodstains out of the test-tube with the pipette--
Could that not cause an aerosol of powdered blood to fall on the surface over which the test-tube was held?
Well, in my experience, with that kind of a sample you usually see some flakes. It is not as fine a powder but you see more of like a flake, flaky effect.
Again, I'm not sure that is the right term, but if you are talking about airborne particles, yes.
Now by pipette do you mean one of those that has a disposable tip on it or do you mean like a glass--can you--
I was going to say if you had a large flake, then that would be nanogram quantities, but not the kind of minute specks that I think you are talking about. Those are not nanogram quantities usually.
Well, from that, if it was solid blood, it would be a very small flake, something like that.
When examining biological specimens, is it not an important precaution, to change paper just in examining each item?
So just so we know what we are talking about, let's say you were examining a blood swatch on a white piece of--what do they call it in labs? Butcher paper?
After examining that swatch it would be important to remove the paper from which the swatch came before then examining another swatch on that paper?
Yes. In other words, you wouldn't want to put two swatches on the same piece of paper. I would agree with that.
All right. And in terms of--let's go back to our situation with the test-tube being with the dried swatches being scraped out with the pipette.
Would it not be an important precaution against cross-contamination to change the paper every time you removed a set of swatches?
I'm having a little trouble conceptualizing what is that swatch then being directed into? I need to get clarification on that.
And that the test-tube with the dried swatches is being--the swatch is being scraped out of that test-tube with the pipette aiming for the bindle surrounded by the paper.
Would it not be sound fundamental laboratory practice to change the paper underlying the bindle every time you moved to a new item?
I think I would do that. I don't know if it is absolutely mandatory to do that, because the bindle does act like a new piece of paper if it is big enough, but I think it would be a good idea to put a clean piece of paper underneath each bindle, yes.
And to protect against cross-contamination from those particles, it would be sound practice to change the paper?
Well, I would--I think it would be a good idea to either change the paper or to put like a wipe or something, some kind of tissue over that paper so that you covered that area, yes.
Instruments. Withdrawn. Before I move from--now, in your laboratory is it not part of your protocol that not only--that the paper underlying an item that you just examined, right, should be changed every time you examine another item of evidence?
And when you are cutting or sampling an item you would change the paper for each different item?
Now, instruments. There are various kind of instruments that are used to manipulate biological evidence in a crime lab?
And is it important to make sure that you clean all instruments that are used in manipulating biological specimens?
Gloves. Is it part of your protocol to change gloves every time you handle a different item of biological evidence?
I don't believe I change my gloves after every item. Umm, what I do sometimes would be usually to wash my gloves, and certainly if I had any indication at all that I may have something on my gloves, I would discard them right away and after, for example, I have been working around the laboratory and handling doors and things like that, I would change my gloves also, but I don't believe I would change my gloves necessarily between each separate item.
Would you agree that not changing gloves--well, let's start this way: In handling a wet swatch would you change your gloves between handling each swatch?
In removing a swatch, wet swatch from a plastic bag, would it be sound practice to change gloves between handling each set of wet swatches?
Well, I think if you mean by the scenario we talked about earlier where you are sticking the tube up in there--
--I think if there was any danger that you would have blood getting onto that tube and then you touched that tube, for example, that would be a good idea to change your gloves, yes.
Uh-huh. And in the process we talked about where you are scraping the swatches out of the test-tubes onto the bindle and paper, between each set of evidence items would you change your gloves?
Well, now there--as you are explaining it, you are sort of--you know, you are creating a situation where it is coming down onto your gloves. I'm not sure that the criminalist might have the--the material out in front of him or her so that they are really not having the particle come down onto the gloves. Do you understand what I'm saying?
Well, if--are you--would you, as a precautionary practice, describing--looking at the process we are talking about, scraping the swatches out of the tube--
--dried swatches out of the tube, would you change your gloves between handling each of those items?
No, I don't--I don't think so, because I think one could reach into that tube and dislodge that sample in such a way that then one wouldn't get powder onto the gloves. I don't--I don't know that I have ever done that procedure, so it is hard for me to evaluate it on my own experience, but I think at least one might wash one's gloves after each item. That would probably be a good idea.
So your testimony then is you would either change your gloves or wash your gloves between each of these items?
I think that would be a good idea, but again, it depends on how exactly that manipulation is performed.
Maybe I asked you this question--let's make sure I asked you this question: Did you either change your gloves or wash your gloves between handling each swatch in this case?
All right. You testified a second ago that you didn't necessarily change your gloves between each item?
All right. Would you, between handling each of the swatch items in this case, have either changed your gloves or washed your gloves?
All right. So you were either using a new set of gloves when you handled each separate item or you were using a set of gloves that you had washed?
Now, would you agree that with respect to--well, actually--can we move to I? In viewing each of these different factors in terms of cross-contamination, okay--
Right. And we agreed that in handling degraded samples, that is, the fact that samples are degraded creates a risk of cross-contamination in and of itself?
And handling a reference sample, I am now looking at the test-tube plus one, all right?
--reference sample in the same area during the same period, either by pouring off sample from the--popping up the top of the tube, pouring it onto a card and in the same area during the same period, one is handling evidence samples, that kind of situation can increase of risk of cross-contamination?
And handling samples from a suspect and a victim at the same time can create a risk of cross-contamination of sample?
Can we clarify a little bit about suspect and victim? I think we had a had a little--
You recall that discussion that is represented by that logo, without reviewing it all?
And then we talked about samples represented by that scale of samples with high DNA concentration and low DNA concentration?
Now, with respect to all those different contamination factors to the right of the line, those represent in a sense situations that can raise the level of risk in terms of making an inadvertent transfer of cross-contamination?
Excuse me, counsel. This witness has never adopted your characterization of aerosol. Airborne particles perhaps; not aerosol.
KEY QUOTECombining that with any of these other situations to the right of the line, that is a--sort of a mechanism of transfer that would increase the risk of cross-contamination?
If you combine not changing paper with each of those situations, that is a mechanism of transfer that can increase the risk of cross-contamination?
And with respect to the bunsen burner representing the cleaning of instruments, if one does not adequately clean instruments, that can be a mechanism of transfer that facilitates cross-contamination, raises the level of risk in the other situations to the right of that white line?
And with respect to gloves, gloves, either not changing gloves or washing gloves--
--okay, between samples, combined with any of those other factors to the right of the line, can become a mechanism of transfer for cross-contamination?
Good. That saves me some time. Would you agree, and I'm now referring to section 7.3 of your protocol, that the functions of note taking are: "to support the conclusions in the laboratory report, to permit internal review of the work product, to allow reevaluation of the data by outside scientific observers, and to provide a foundation for the introduction of work product into Court"?
Do you agree that: "notes are to be made at the time the work is done and to accurately reflect what was done"?
So the way that you filled out notes in this case, is that you would perform a procedure and then after performing the procedure you would write down what you did?
Yes. In some instances I did that early on, and then as things became more routine, I just kind of knew that that was part of the routine.
Would you agree that for case work analytical notes should be recorded on DNA case note forms or the appropriate run sheet or checklist and each page should be numbered?
All right. When you make your initials on various pieces of packaging, you do them in ink?
--should be made by lining through the original so the original text is still visible?
And do you rely on the section of your protocol entitled "documentation," section 3.3?
Would you agree that note keeping is defined as documentation of work is performed?
I think a couple of them did, but I don't--I certainly--you asked me earlier if I saw any with the June dates, and I don't think I had any with the June dates on them, if is that your--
Did you see one bindle with the initials "A.M." for Andrea Mazzola on any of the swatches you handled?
And the provisions of that manual are not just guidelines that analysts are free to ignore if they feel they want to--
And would you agree, as an expert in crime lab procedure, that being careful and paying attention to detail in the handling and the documentation of samples is very important?
And that being sloppy about the handling of biological samples with respect to DNA testing, umm, is something that should be avoided?
Because of the dangers of cross-contamination or at least that is certainly one of the reasons?
And when we talk about inadvertent transfers, would you agree that sometimes one makes accidents in the handling of samples that one is aware of?
And it is for that reason that it is important to follow the precautions that we reviewed so far this afternoon?
And in terms of at the end of a DNA analysis, when you are looking at an autorad or a typing strip, and there is some indication in your controls, positive control, negative control or quality control sample, of a irregularity, it is often difficult to go back and figure out what stage of the process went wrong that caused that irregularity?
It can be difficult, but one can take a systematic approach to that and track back and perform the different parts of the experiment, and also if one has, for example, extracted DNA or raw material, one can repeat that analysis. That could be part of the way of tracking that back. You may not figure out exactly what happened, but then you could still get the correct result, for example.
And when certain dots light up, that is an indication that perhaps some amount of DNA associated with an allele has been detected?
But sometimes dots can light up and one wonders whether or not that is DNA that really comes from the starting material that you are examining as opposed to something that may be just what's called an artifact in the process?
What is--can dots light up on that PCR strip and it not be the DNA from the starting material?
Yes. That could happen, for example, if you had a mix-up of sample or something like that, yes.
And--or it could happen from some kind of contaminant that gets into the reagents?
It can happen from some cross-contamination in the handling, in the extraction--cutting and extraction of the sample?
--it can often be difficult to figure out exactly what occurred to cause the dot to appear?
No. My--well, as far as doing it--my first training in DNA went back to 1988, but that was--that was a class that I took in how to perform DNA analysis.
And could you describe for us--and you didn't--I think you told us on direct examination that you didn't begin doing case work until May or June of 1993?
`92, I'm sorry. So how long was that from the time you first started at the DOJ lab?
But before you started at the DOJ lab, did you have extensive experience in crime lab procedures?
Well, as part of my--all the time that I was in criminalistics, so that would be, what now, about fourteen years of experience in criminalistics before I went to the Department of Justice, something like that.
And when you did your training, did you receive guidance from people that had Ph.Ds or doctorate degrees?
I think the phrase you used on direct examination, when Mr. Harmon was asking you why it took so long, you said something to the effect that it is important to know what makes a good bloodstain into a bad bloodstain?
Yes. That was part of I think what we were discussing, our environment abuse experiment where we exposed blood and semen stains to a wide variety of environment conditions to evaluate whether or not we would get the right or the wrong answer.
And so it would be important, for criminalists who are collecting, packaging, processing, extracting, performing DNA analysis, to have an understanding of what causes degradation in samples?
Yes, I think that would be important, that people collecting biological evidence should have some basic understanding.
And this, I think you indicated, is only the eighth time you have testified in court about your forensic DNA work?
You indicated that the Department of Justice is accredited by what is known as Asclad lab?
And I think you said that I think it was, to save me some time, that with respect to the recommendations of the national research council of the national academy of science in their book "DNA technology in forensic science" that you don't rely on any of it?
I think you--as I understand, Mr. Harmon's question was did I rely on anything in there to reach the conclusions that I reached in this case.
Oh, okay. Are you familiar with the recommendations in that book concerning laboratory accreditation?
Well, do you know whether you would rely on any part of this chapter as a--in terms of your expertise in criminalistics?
Objection. It is vague--it is irrelevant what he would rely on. It is hearsay, foundational 721.
Mr. Scheck, why don't we move on. I'm not overly optimistic on this line of questioning.
Wait, wait. I am discussing this with counsel. I am trying to give him some guidance. Why don't you sit down. I'm not overly optimistic, Mr. Scheck, given the lack of the foundation at this point, so why don't we move on.
I have located the sentence. Let me just ask this one and then I will move on, your Honor.
Let me just call your attention to the sentence on page 102 in the--the section dealing with establishing standards in forensic DNA typing, starting at the bottom of the page and moving into the top of page 103.
Have you relied upon that in forming your opinions with respect to accreditation of laboratories?
Now, do you believe--do you have--you were asked questions about clinical medicine on your direct examination and DNA typing in clinical medicine.
All right. Are you aware of standards or regulations in clinical medicine and how they compare to the standards on forensic laboratories?
But you are not aware of the standards required of laboratories who are using DNA typing in clinical medicine?
All right. So you couldn't tell us whether they are more rigorous or less rigorous than forensics?
Now, in terms of discussing forensic DNA typing, Asclad sets standards which your laboratory had to meet?
And would you agree that the process of preparing your laboratory for Asclad accreditation improved in some measure the work in the laboratory?
I don't--I don't think it necessarily improved our work product. I think what it did was to bring it all together for us, and I think it--it addressed some issues. I mean, when you talk about accreditation, this would even include safety issues, evidence handling issues as far as security of the laboratory, all those things are part of it. I don't think in a particular way that it changed our work product. I don't think it changed the quality of our product. I think what it helps to do is to tell the users of our services that we are meeting certain minimum standards and so it is--it is saying that we meet those standards.
All right. I'm not asking you--I think you were asked on direct examination were your results as reliable before the accreditation process as after. Do you recall that?
Right. On the other hand, would you agree that the process of accreditation which I think you have indicated you review all the different techniques in your laboratory?
You would look into some of the factors that we discussed this afternoon in terms of trying to prevent cross-contamination and precautions that ought to be taken?
And during the accreditation process did you work on that manual that we've talked about?
And in putting together the manual you went through the details of exactly what people did?
Well, people didn't hear that from the manual. We knew those things so we incorporated those things into our manual to say as a reference that that is how we are doing things and we are telling you that this is how we are doing things.
Right. And maybe some people in the laboratory had one way of doing things and other people had others?
Well, we were--we were actually pretty much all on the same wavelength as far as those concerns, but there were some minor things, yes, that we improved upon.
And in the process of accreditation and in putting together of this manual, what happens is, is that you set out uniform standards that you can be sure everyone associated with that crime lab will follow?
Right. And you would agree that that is a benefit of going through the accreditation process?
Now, on direct examination there was some discussion of your role in what is known as certification?
And I think you told us something about being on the board of American--what is the title of that organization?
I was on the board of examiners that--that--for example, I would work on certain test questions. I would also proctor the examination.
And would you agree that the process of preparing for the test has the effect of improving the work of an individual analyst?
Yes. I think--I think that is a fair statement. In other words, part of that is the educational benefit that one gains from preparing for that sort of examination, yes.
I mean, no matter how experienced one is, you can always learn some new technique that will improve your level of practice?
So you would agree it is important that criminalists who work for a number years in the field be certified?
I think it is important that the criminalist move toward certification, yes. Our field has been slow to do that, and we are now coming on line with certification more and more.
Are you familiar with the guidelines for the collection of DNA evidence that was published by the FBI?
For purposes of methods that you in your expert opinion would believe were sound for the collection of evidence items for purposes of forensic DNA analysis?
Now, as the last part of this section of our discussion here, Mr. Sims, I have a series of photographs, your Honor, that I would like to mark--
And this--these photographs were--showed you at different stages of the process by which you, I guess, initially handled and cut the samples in this case?
Yes. Dr.--Dr. Blake asked me to reconstruct and just sort of go through what it looked like as I was processing the samples in this case.
Yes. Those are, I believe, my hands. What I'm showing is the process of how I am cutting out a sample here. This is just a blank card. Obviously, it is a white card. I'm showing that I have the--I have a laboratory bench that I have bleached now. I have a--
Well, let's just stop right there. The laboratory bench is the bench that that blue what would you call it, hospital--
All right. So before you put that hospital type diaper on the bench you bleach it?
And the purpose of bleaching it is to make sure that you get rid of biological material that could contain DNA?
Okay. I would--the way I am processing this case--the way I processed this case and other cases certainly, too, I would put down a new one of these blue pads for each one of the items that I looked at. Keep in mind that each item is--generally each item is a coin envelope that contains two bindles, so inside this coin envelope are two bindles. One of the bindles would contain the swatch with the bloodstain on it. The other bindle would contain the substrate control, so I would change this blue pad between each one of those coin envelopes. So now when I would open the coin envelope--I'm sorry. Before I would open the coin envelope there would be one of these white chem wipes, just a piece of white tissue, a large size tissue like a Kleenex somewhat.
Chem wipe is the large white object--larger white object on top of the blue blanket?
Yes. And so I would process the bindle containing the stain on top of one chem wipe and then I would change the chem wipe and then process the next bindle containing the substrate control with a new chem wipe.
So what you are actually doing there, is that just for one item, all right, one item that contains the swatch with the specimen on it and the substrate control, between the substrate control and the specimen you would change the surface you were working on that chem wipe?
Yes, in most cases. I think on some of these it may have just been one chem wipe that I am working on. You can see it is a large chem wipe, so I would work on two different areas of it.
All right. And on the upper left-hand--well, I guess it is the upper right-hand corner of the screen, we see another one of those blue hospital blankets?
Excuse me. Well, that would now contain the--that orange object is a test-tube rack and soap. As I process these test-tubes, I would place each tube individually into that rack. In other words, once you put a stain swatch into a test-tube, then it is capped and placed into that rack, so it is out of the way of the other material. And then also on there you can see a--this is another little chem wipe that has a little blue plastic tube popper on it. That is used to pop these tubes open so that that way you don't do it with your glove; you do it with the tube popper. And then finally I think I'm laying out another chem wipe that would have the cap, unused tubes. In other words, where I would get the new tubes from, because those come out of an autoclave jar at one point and you would lay some of those out.
Yes. It is a process whereby reagents and equipment are--is steam sterilized. In other words, it takes things up to a very high temperature to sterilize.
Well, the purpose of that is to destroy biological material and to break DNA down into various small--very, very small fragments.
You were asked some questions on direct examination about your forceps. Sometimes people call them tweezers?
They are like the tweezer or the forceps that jewelers use, they are ground down, correct?
All right. And it is your understanding that forensic DNA scientists that do the work you do will employ such ground down forceps?
It is a general practice among criminalists to avoid handling samples with serrated tweezers because the problem with serrated tweezers is that you can get--they are harder to clean?
Well, I am just proceeding to cut into this sample is what I would be doing, and I think that is it.
Just tap water. In other words, a big gush of water to get any of the bulk material off.
All right. So you start with the water to get the bulk material off; is that correct?
Now, at this point this is the next part of the cleaning process where I'm actually rinsing them down with a little spray bottle of alcohol.
This--this is the flaming process. Whenever that bunsen burner was lit, people in the laboratory knew that Dr. Blake and I were working together, but that is used to what we call fire or flame the actual tools and that is sort of a final ultimate killer of anything. I mean, it would certainly carbonize any biological material that may be left over.
And then you would move to the specimen or specimen, substrate control, you clean in between?
And the last picture, which I know you didn't want me to show, that is you in the lab, right?
What is our timing? I can't even remember. Did we take a break or are we moving right through?
Now, plastic bags. In your opinion, sir, putting a wet swatch--swatches in a plastic bag that folds over and then putting that plastic bag in a coin envelope, putting it on--on the floor of a crime scene truck for seven hours in the month of June--I won't say anything about--just make assumptions about the temperature being something on the order of in the sixties in Brentwood--
I grew up in L.A. So I know--I know what June is like. It is usually a little overcast part of the morning.
Would you agree that putting swatches in a plastic bag, wet blood swatches in that fashion would have the effect of degrading the DNA in those samples?
Provided that there was some bacterial action, for example, that came with the substrate material, yes, that could get that process going.
And the bacterial agents could be on--you saw some pictures on direct examination about the locations of items 47, which was photo no. 117, 48, photo no. 118, 49, photo no. 119, 50, photo no. 120 and 52, I think photo no. 122. You saw those?
Would you have a reasonable expectation that those--that swatches made from those blood drops would contain biological--bacterial agents that when put--those swatches put in the plastic bag, kept there for seven hours, moist and wet, would begin a process of bacterial degradation?
Yes. In other words, if this is a blood sample, then the bacteria would feed on the blood, and yes.
In your opinion is a sound practice to collect wet blood swatches of this kind containing from substrates that have some dirt, put them in plastic bags, such--in the truck in my hypothetical for seven hours? Is this a sound practice?
Well, because it is hard to predict exactly how extensive the process of degradation might be?
Well, I don't know if it is that hard to predict. I mean, bacteria have certain growth cycles and people have characterized these things quite well, so I think you could do the experiment. I think you just don't know exactly how much is in the starting material. That is what would be hard to predict.
And the results of your yield gels indicated that they contained lots of bacterial DNA?
Well, that is--that is what it suggested, although once you keep in mind we did not do a specific test for bacteria, but that is what I interpreted to be the most likely cause.
In these yield gels I think--did you see that part of Dr. Cotton's testimony where she put a yield gel up there for the jury?
And sometimes at the bottom of those bands there is something that are called plasmids?
Yes. A plasmid is a relatively small piece of circular DNA that is usually found inside a bacterium. It is separate from the bacterial DNA, but it goes along for the ride with the bacterium.
Well, I'm--the point is I know the bands you are speaking of and I believe they are bacterial origin. Whether they are plasmids or not I'm not sure.
But those bands indicate to you that there was substantial bacterial degradation in the Bundy blood drops?
Well, that would suggest to me that there is substantial bacteria. For example, when we look at a vaginal swab from a case, you will frequently see bacteria, but that doesn't mean that the female's DNA is degraded.
All right. Now, after the yield gel for these Bundy drops, you conducted something that you described before as a southern transfer process?
And that was done to determine if you could identify the amount of human DNA that were in these samples?
And that can't--that--and you were able to get some--and then you did what is known as a slot-blot?
Did you do that before--I think you did that before or after the southern transfer?
Are you finished? But the slot-blot is a way of determining the amount of human DNA--
And so what we had in these Bundy blood drops was a substantial amount of bacterial DNA?
Now, let's talk about how much human DNA you were able to identify in these samples.
You are not going to take my word what is on this chart, are you? You are going to look it up in your own notes?
Okay. I had, by the way, prepared a little spread sheet that--just as a roadmap to my notes. That is what I'm looking at to find these things.
That sounds about right. I had about 3.8 after--after I did the quantitation. When Dr. Blake and I would review these quantitations, I went back and figured out--he went back and figured out the total yield, I believe, is what my notes would reflect how much was left after I had done the quantitation because that is what I had left to work with, about four nanograms?
Now, let's assume that there were five other swatches associated with sample 47, weighing 28 milligrams, and let's further assume that the biological matter, the blood, was randomly or evenly distributed over those other swatches.
And let's further assume that--maybe this will be the easiest assumption to just make and quantify. Let's just assume that out of all the material associated with sample 47, all seven swatches, you extracted 12.9 or 13 percent of the DNA.
Would you project then that associated with all the swatches there would be about 33.6 nanograms?
That if we were to calculate--thank you, your Honor--if we were to calculate the total amount of human DNA in the sample, it would come to something on the order of 33.6 nanograms?
You received two swatches weighing 8.1 milligrams, extracted 6.5 and got a slot-blot of 4 nanograms.
So based on the weight, assuming that you extracted eighty percent of the total amount in those two swatches, that if you were to project total amount of DNA on the swatches, it would be 5 nanograms?
You received about two swatches in I think something like a thread that weighed 4.6 milligrams altogether?
Well, there were--keep in mind on 49 there were two different submissions on that, but you are talking about the initial one?
Yeah. Well, to cut to the bottom line, let's assume that there were altogether five swatches--
--associated with this sample weighing a total of--and--19.6 milligrams you extracted 2.5 milligrams and got a quantity of .24 nanograms, which would mean that your quantification represents 13 percent of the total sample extracted and therefore the total amount of human DNA in the sample would be on the order of 1.8 nanograms?
Assume that this is a total of four swatches with a total weight of 22.2 milligrams.
Well, wait if there is 4 and I've got 7.2? Doesn't it have to be closer to about 30 milligrams?
Your Honor, objection. Is this a hypothetical? And if it is, there is no foundation for it. It is improper hypothetical.
You are aware that all the swatches were weighed in this case at your laboratory, at Cellmark diagnostics?
I was trying to save the taxpayers a little money by washing them.
This witness has never adopted your characterization of aerosol. Airborne particles perhaps; not aerosol.
Airborne articles represented by the clip art of fireworks?
No, I don't recall seeing 'A.M.' on any of those bindles.
It would be weird that I would ever have a pencil around in my lab.