Are you familiar with that study in the context that I described it in the question?
Could we have the sock photo board and the sock result board? The photo board is 262-A and the result board is 262.
Mr. Sims, while we're waiting, we're just going to go in the order that the stains--the numerical order that they're listed there and initially discuss the significance of the 11-probe RFLP match that--on DOJ 42A-1, sock 13, the Greg Matheson cut-out stain. Okay?
How did you approach your calculations to this 11-probe or 11-genetic marker match between Nicole Brown and the cut-out that Greg Matheson made from sock A?
The approach that I used was to go to the bin tables, those are the tables that list the frequencies for these RFLP bins or alleles within the bins, and I made a determination based on six loci.
What significance do those other five probes that you did not use in your calculations have in--giving the jury some appreciation for how common or rare this match is?
Yes. The idea is that these additional systems are also highly polymorphic. They have great powers of exclusion. And so I looked at those additional loci to check the results of the sock against the reference sample.
It means that--that if you were to take two individuals at random, there would be a very good likelihood that you would be able to separate them based on this type of analysis. Any one of those probes is very strong for that purpose.
As you demonstrated on all of the autorads when it was easy to distinguish from among the three reference sources?
Could you--just the way we approached the other statistics, could you describe from among the three major population groups that you've used in your calculations the frequency estimate for those three groups and the match between Nicole Brown's reference blood and Greg Matheson's cut-out stain on the sock?
Yes. For those--the six loci that I looked at, these are RFLP loci D1S7, D2S44, D4S139, D5S110, D10S28 and D17S79, the profile detected in stain 42-A(1) occurs in approximately 1 in 21 billion Caucasians, 1 in 41 billion African Americans and 1 in 7.7 billion Hispanics, again indicating that this profile is a rare event and pointing out that these are for unrelated individuals.
Now, is there any way to express to the jury what impact those other probes that do--those other genetic markers that have not played a role in your calculations have on describing how common or rare the pattern of Nicole Brown's blood is when you look at it and see it in the sock?
Would you please relate to the jury in your opinion the impact on those numbers that you've just communicated to the jury in helping them evaluate how common or rare that pattern is?
I'm going to sustain an objection to that question because I think the statistic itself speaks for itself, how common or rare.
KEY QUOTEDo each of the additional genetic markers that do not play a role in those calculations that you've just presented to the jury, do they have an impact on those calculations?
Well, as I started to say earlier, these tests are very good at distinguishing between individuals. And so what we're looking at is more and more genetic markers, more and more places on the chromosomes where we see whether or not a given stain and a given reference sample match. And the more of those that one looks at, the rarer the profile must become.
And--okay. In addition to those 11 genetic markers, your laboratory performed PCR tests on that same stain; is that right?
What I would like you--have you been provided data based on Cellmark's analysis of extracted DNA from the very same stain that you extracted which demonstrates the commonness or uncommonness of the PCR results in this case?
And in--have you also considered the population data that you have for the PCR markers that your laboratory used in testing the exact same DNA in this case?
Okay. Is it possible for an expert to calculate the combined frequency of the poly-marker inclusion, those five genetic markers, the DQ-Alpha inclusion by Cellmark, your DQ-Alpha inclusion and your D1S80 inclusion so that you could describe to the jury the commonness or rarity of the match between those PCR markers and this stain that Greg Matheson cut out from that sock?
Okay. Would you please then describe to the jury in the same way that we have--I forgot to have you write up the RFLP results. So when we do the PCR results, let's do the RFLP statistics too. Could you please express to the jury the calculation for the frequencies between--and the PCR markers matches between Cellmark and the Department of Justice?
If you'd just describe that, and then I'll ask you to write in both of those slots there. We've got a patch for one of those boards.
That's correct. I was going to ask that after we got it up there, and I'll clarify that in a moment if I could.
Do you want to go up there and write up--why don't you write out the RFLP if there's enough room for that. And I've got a cover for the PCR.
Your Honor, while we're doing that, can we approach for just a second on a related issue?
the profile detected in stain 42-A(1) occurs in approximately 1 in 21 billion Caucasians, 1 in 41 billion African Americans and 1 in 7.7 billion Hispanics, again indicating that this profile is a rare event
People are pretty different from one another?
I'm going to sustain an objection to that question because I think the statistic itself speaks for itself, how common or rare.
the more of those that one looks at, the rarer the profile must become.