📄 Sidebar: exhibit foundation — Tuesday, May 2, 1995
Address:
C:\DEPT103\CRIMINAL\1995\MAY\2\SIDEBAR-EXHIBIT-FOUNDATION.DOC
TRIAL
▲ Day 65 of 167

Sidebar: exhibit foundation

Date: Tuesday, May 2, 1995 • Utterances: 8
Defense attorney Blasier objected at sidebar that the prosecution had not laid sufficient foundation to analogize blood sample 42 (from the ground) with blood found under fingernails. Goldberg argued the physical contact between hands and blood made the analogy valid and that the court had already ruled on the issue. Judge Ito overruled the objection.
1 (The following proceedings were held at the bench:)
2 THE COURT:

All right. We're over at the sidebar. Mr. Blasier.

3 MR. BLASIER:

Yes. He's attempting to analogize 42 with fingernails.

the only testimony that's been elicited concerns the tackiness of the blood on the ground. He's not demonstrated that the conditions of collection, the manner of preservation, the conditions of the fingernails are in any way the same as the blood on the ground. Therefore, any testimony that you can somehow analogize these two samples together would be inappropriate for lack of foundation.

4 THE COURT:

All right. Mr. Goldberg.

5 MR. GOLDBERG:

What, your Honor?

6 THE COURT:

Mr. Goldberg.

7 MR. GOLDBERG:

I thought the Court already ruled on this, and we argued extensively about it. But what the evidence shows is the bare hands are put in physical contact with the blood, and as I argued previously, are contiguous and continuous with the blood, and then explaining why Mr. Matheson believes it is legitimate to draw inferences about 42 and under the fingernails will do that. Showing the picture will do that. It is the simplest way of conveying that testimony.

8 THE COURT:

All right. Objection is overruled.

Temperature

procedural

Key Quotes (2)

Robert Blasier
He's not demonstrated that the conditions of collection, the manner of preservation, the conditions of the fingernails are in any way the same as the blood on the ground.
Articulates the foundation gap the defense is exploiting — the two samples are being treated as comparable without establishing comparable conditions.
Hank Goldberg
the bare hands are put in physical contact with the blood, and as I argued previously, are contiguous and continuous with the blood
Prosecution's theory of physical continuity as the basis for the analogy between ground blood and fingernail blood.

Evidence (3)

42
Blood sample collected from the ground at the crime scene
discussed as basis for analogy to fingernail evidence
Informal
Blood found under fingernails
discussed as comparable sample to ground blood
Informal
A photograph ("the picture") referenced by Goldberg to illustrate physical contact
proposed as demonstrative aid for Matheson's testimony

Notable Exchanges (1)

Robert BlasierHank Goldberg
Blasier challenged foundation for the nail board exhibit analogy; Goldberg countered that physical contiguity of hands with blood was sufficient and the court had already addressed this.
strategic

Objections

1 objections (0 sustained, 1 overruled)
Proceeding 5880 • 8 utterances
Criminal Trial
Department 103
⚖️ Start
📂 MAY 2, 1995 📄 Sidebar: exhibit foundation
MAY 2, 1995 KRT DvH TD