📄 Sidebar: exhibit presentation objections — Thursday, May 18, 1995
Address:
C:\DEPT103\CRIMINAL\1995\MAY\18\SIDEBAR-EXHIBIT-PRESENTATION-O.DOC
TRIAL
▲ Day 77 of 167

Sidebar: exhibit presentation objections

Date: Thursday, May 18, 1995 • Utterances: 55
The defense team (Scheck) previews a slide presentation numbered 1-A through 9-J to be used during cross-examination of DNA analyst Gary Sims. Harmon objects to several graphics as argumentative, and Judge Ito sustains the objection to slide 5-E (the 'exploding thermometer,' actually a blood vial graphic). The session ends with Scheck requesting Sims' own PCR strip photographs and the judge ordering a recess so both sides can exchange materials.
1 THE COURT:

Okay. I take it--we are over at the side. Mr. Harmon, I take it you have had no objection to any of the photographs that Mr. Sims and Mr. Scheck have presented?

2 MR. HARMON:

They are handsome photographs. I couldn't object to them.

KEY QUOTE
3 THE COURT:

Okay. I have before me a--two pages of miniaturized--I take it these are boards. Are these going to be--

4 MR. SCHECK:

Slides.

5 THE COURT:

Video presentations that are no. 1-A through 8-H. And these are boards which say, for example, 1-A says "cross-contamination factors." 2-B says "degradation." 3-C says "high DNA content versus low DNA content." no. 4-D says "different scenes" and has various graphics, an automobile and then two residences. There is a 5-E, has an exploding thermometer, plus the--

6 MR. HARMON:

That is what?

7 MR. SCHECK:

That is a--the same logo that was used in a previous recitation of a test-tube.

8 THE COURT:

Well, that is--I thought you were talking about high temperature and degradation.

9 MR. SCHECK:

No, no, no. That is a reference sample tube.

10 THE COURT:

Well, 6-F says "suspect reference samples" and then has the international symbols for man and woman. 7-G is just a series of numbers. 8-H has "aerosols, paper, gloves, instruments" and then 9-J combines many of these aspects. Mr. Scheck, I have a problem with the thermometer.

11 MR. SCHECK:

Umm--

12 (Discussion held off the record between Defense counsel.)
13 MR. SCHECK:

Your Honor, I will make it clear that that is a blood vial and that was a logo that was used previously in one of our exhibits for the blood vial.

14 THE COURT:

Well, my concern, too, is that we don't have an exploding blood vial or a spewing blood vial. That is beyond the scope here.

15 MR. SCHECK:

Well, the--the way this question is going to be formed has to do with the testimony--well, first of all, the--the questions of the witness will have to do with statements in his protocol and in the AMP-FLP type user guide and in the other publications about reference samples and test-tubes and their proximity to evidence samples and rules about not combining them. Also, there is testimony in the case with respect to Greg Matheson testified that opening the tops of reference tubes should be done with chem wipes because they have sprays that come when you open the top of the reference tube, and he testified to that when he was talking about the amount of blood.

16 THE COURT:

Let me ask, rock, what are your--

17 MR. HARMON:

Well, this is entertaining, but it is argument. Can we borrow a phrase that we were talking about a while ago? It is also redundant argument. The words are fine, although I think that is still argument. Up there on the chart, something that actually illustrates the phenomena, that is okay, the degradation, but 3-C, that looks like the scales of justice and we don't talk about justice, because it is hard to talk about, but that just looks like the scales of justice. That is a symbol of something that has no place on this chart. There is a place for it, but it is not on this chart. Everybody knows what a house and a truck and a house look like, but the point I'm making, all these together is that you can jumble them until they are together in 9-J and it looks like a Sunday morning cartoon thing and says whose name is this spelled out by and the symbols, and I wrote in on 6-E should put "hombres" and "mujeres" because that looks like the bathroom signs, so it is misleading because we don't want people to think that is what they have to do here. It is just a suspect reference sample. The tube, I agree with you, the whole thing is just as argumentative as the boards that I put forth that you kept out. I don't really disagree with you, that you kept these out, but this is just argument that words can illustrate, but I don't know. Maybe there is danger if you connect the dots on those it will spell guilty. On 9-J there is probably something cryptic in here that we are not aware of, but I think words and clear non-argumentative symbols are what is appropriate to this by the jury, but not the stuff that you all combine together. That is 9-J is clearly argumentative. It is just a compilation of things that may or may not have any application to this case. And this would be beautiful argument material, just like our boards that were used for that point, but at this point I think that dazzling people with these slides, which may or may not be a basis for this testimony, you know, this--we might be having this discussion at a later point when they say I'm going to have a witness who is going to say all these things happened, but this is cross-examination of our witnesses, and these symbols are going to be up there whether or not Gary Sims admits that they are factors to consider, and I think that changes the picture completely.

18 (Discussion held off the record between the Deputy District Attorneys.)
19 THE COURT:

Mr. Scheck.

20 MR. SCHECK:

These are all taken right out of his protocol and the guides as precautions, and all that these symbols are, are visual aids, just like the blood drops on their board, et cetera. If we already used most of these in previous displays--the only ones that we haven't are the houses and the car and the man and the woman which I think in a piece of paper--and there are certain limitations one has in terms of clip art, but I think that these all roughly approximate what it is, and I will ask questions with respect to the blood vial indicating exactly what is at issue. Those are the DQ-Alpha strips--pictures of it I'm not going to introduce--these are just the strips, the pictures that Dr. Blake took.

21 THE COURT:

Okay. I'm going to sustain the objection to 5-E, the exploding thermometer.

22 MR. SCHECK:

Can we--

23 THE COURT:

I don't think that is--

24 MR. SCHECK:

Can we try to--we have certain limitations to our clip art.

25 THE COURT:

Well, life in the big city.

KEY QUOTE
26 MR. SCHECK:

We will try to change that one maybe to just--

27 THE COURT:

If it is just a test-tube, that is one thing, but--

28 MR. NEUFELD:

We have a test-tube.

29 THE COURT:

That is a spin on the evidence.

KEY QUOTE
30 MR. SCHECK:

We have a test-tube and we will substitute that.

31 THE COURT:

Let me see it when we come back.

32 MR. HARMON:

Judge, could we--this has happened consistently. Can we get a disk copy of this and can we also get a color copy? We asked Howard and he said it would take some time and I notice he is gone.

33 MR. HARRIS:

It has already started to print.

34 MR. SCHECK:

We will just change the blood vial.

35 MR. HARMON:

Then I have no objection to the strips because they are DOJ record.

36 MR. SCHECK:

I would actually make a request that we--your Honor, I would like them to produce copies of Mr. Sims' strips of the same photographs. If you recall, this actually happened during DNA discovery where we gave them more than they gave us in terms of proficiency. I think 3000 pages worth.

37 THE COURT:

Uh-huh.

38 MR. SCHECK:

But the point is, is that we were forced to rely on Dr. Blake's photographs of these strips. Now some of the interpretations of these strips are going to come into issue and I want to see their photographs of the same strips, so that I'm not put in a position--

39 THE COURT:

All right. Does Sims have them with him? Mr. Sims?

40 MR. SIMS:

Yes, your Honor.

41 THE COURT:

Do you have the photographs of the PCR strips in this case?

42 MR. SIMS:

Yes, I do have those with me.

43 THE COURT:

All right.

44 MR. SCHECK:

Okay.

45 MR. HARMON:

Judge, now the only problem is, you know, he has got everything. He has got hundreds of things and so it is nice to have notice because he has got to eat lunch; too. We have everything, but the timing of how we get it, it gets complicated, and that is why a courtesy notice--

46 MR. SCHECK:

I did.

47 THE COURT:

Well, if it is not too much trouble, see if you've got the photos for the PCR strips for here.

48 MR. HARMON:

For which?

49 MR. SCHECK:

The ones--

50 MR. HARMON:

Can I talk to them about them?

51 MR. SCHECK:

I just want to get just these copies.

52 THE COURT:

Okay.

53 MR. HARMON:

Have them down here when we come back.

54 THE COURT:

All right. We will stand in recess.

55 MR. HARMON:

Okay.

Temperature

procedural

Key Quotes (5)

Rockne Harmon
They are handsome photographs. I couldn't object to them.
Dry opening quip setting the tone for a relatively collegial sidebar; rare moment of Harmon complimenting defense materials.
Rockne Harmon
I wrote in on 6-E should put 'hombres' and 'mujeres' because that looks like the bathroom signs, so it is misleading because we don't want people to think that is what they have to do here.
Harmon's colorful argument that the international male/female symbols are confusing and potentially misleading to jurors.
Lance A. Ito
Well, life in the big city.
Judge's wry response to Scheck complaining about limitations in their clip art library — one of Ito's rare dry humor moments.
Rockne Harmon
Maybe there is danger if you connect the dots on those it will spell guilty. On 9-J there is probably something cryptic in here that we are not aware of.
Sarcastic argument that slide 9-J is a jumbled, argumentative compilation — illustrates prosecution's consistent theme that defense visuals are advocacy dressed as illustration.
Lance A. Ito
That is a spin on the evidence.
Judge's stated rationale for excluding the exploding thermometer/blood vial graphic — captures the core evidentiary standard being applied.

Evidence (4)

Defense slides 1-A through 9-J
Defense slide/video presentation for cross-examination of Gary Sims covering cross-contamination factors, degradation, DNA content comparisons, scene differentiation, reference samples, and aerosols/instruments
previewed and partially challenged at sidebar; slide 5-E excluded pending substitution
5-E
Graphic depicting what appeared to be an exploding thermometer, described by Scheck as a blood vial logo previously used in defense exhibits
objection sustained; defense to substitute plain test-tube image
null
DQ-Alpha strips — photographs taken by Dr. Blake
discussed; Harmon withdrew objection once confirmed these are DOJ records
null
Gary Sims' PCR strip photographs from the case
Scheck requests production; Sims confirms he has them; judge orders them made available at recess

Notable Exchanges (3)

Barry ScheckLance A. Ito
Scheck argues the blood vial graphic is consistent with previously admitted exhibits and grounded in Sims' own protocol; Ito rejects it as a 'spin on the evidence' and sustains the objection, but leaves the door open if Scheck substitutes a plain test-tube.
strategic
Rockne HarmonBarry Scheck
Harmon delivers an extended, sardonic critique of the entire slide deck — comparing symbols to bathroom signs, Sunday morning cartoons, and cryptic dot-to-dot puzzles — while Scheck defends each element as drawn from Sims' own published protocol.
heated but witty
Barry ScheckRockne HarmonLance A. Ito
Scheck requests that the prosecution produce Sims' own PCR strip photographs, citing a prior discovery imbalance of 3,000 pages. Harmon raises logistics concerns about timing. Ito cuts through and simply asks Sims directly if he has them.
strategic

Light Moments (4)

Rockne Harmon
Harmon opens with 'They are handsome photographs. I couldn't object to them' when asked if he had objections to prior defense exhibits.
Rockne Harmon
Harmon jokes that the male/female symbols look like bathroom signs and suggests labeling them 'hombres' and 'mujeres.'
Rockne Harmon
Harmon quips that if you connect the dots on slide 9-J it might spell 'guilty' and there is 'probably something cryptic in here that we are not aware of.'
Lance A. Ito
Ito responds to Scheck's complaint about clip art limitations with 'Well, life in the big city.'

Witness Demeanor

(Discussion held off the record between Defense counsel.)
(Discussion held off the record between the Deputy District Attorneys.)

Objections

2 objections (1 sustained, 0 overruled)
Proceeding 6113 • 55 utterances
Criminal Trial
Department 103
⚖️ Start
📂 MAY 18, 1995 📄 Sidebar: exhibit presentation
MAY 18, 1995 KRT DvH TD