📄 Redirect examination of Gary Sims (part 1) — Monday, May 22, 1995
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▲ Day 79 of 167

Redirect examination of Gary Sims (part 1)

Witness: Gary Sims
Examiner: Rockne Harmon
Called by: Prosecution • Date: Monday, May 22, 1995 • Utterances: 638
Prosecution's Rockne Harmon conducts redirect examination of DOJ DNA analyst Gary Sims, methodically rehabilitating him after Barry Scheck's lengthy cross-examination. Harmon walks Sims through the full dataset of DQ-Alpha and D1S80 results on Bronco and Bundy stains, emphasizing that Scheck's hypotheticals and charts deliberately excluded significant corroborating data. Sims confirms his rehybridization of item 52 (Bundy driveway drop) validated his original 1.1, 1.2 call, and explains that the seven-day processing timeline was actually unusually slow due to double-documentation requirements for Dr. Blake's presence.
1 (The following proceedings were held in open court, in the presence of the jury:)
2 THE COURT:

All right. Thank you, ladies and gentlemen. Please be seated. Let's have it quiet, please. Let the record reflect that we have been rejoined by all the members of our jury. Mr. Sims, would you resume the witness stand, please. All right. Good afternoon again, Mr. Sims. Mr. Harmon.

3 MR. HARMON:

Thank you, your Honor. Good afternoon, ladies and gentlemen.

THE JURY: Good afternoon.

REDIRECT EXAMINATION BY MR. HARMON

4 MR. HARMON:

Mr. Sims, I want to start out addressing some of the issues that Mr. Scheck raised in cross-examination with you. Is that okay?

5 MR. SIMS:

Okay.

6 MR. HARMON:

I noticed that in response to many of Mr. Scheck's hypotheticals, you gave answers that things were possible. Do you recall that?

7 MR. SIMS:

Yes.

8 MR. HARMON:

Did any answer that you gave expressing a possibility to Mr. Scheck's hypotheticals, did any of those answers in any way undermine any of the results and opinion that you've previously addressed on direct examination?

9 MR. SCHECK:

Objection. Speculative, argumentative.

10 THE COURT:

Overruled.

11 MR. SIMS:

No.

12 MR. HARMON:

And why did you say "It's possible" so many times?

13 MR. SIMS:

Well, when you--

14 MR. SCHECK:

Objection. Vague.

15 THE COURT:

Overruled.

16 MR. SIMS:

When hypotheticals are created, certainly you get to a point where you can say anything is possible, and anything is possible.

KEY QUOTE
17 MR. HARMON:

Now, Mr. Sims, do you remember Mr. Scheck asked you whether or not you had any reason to believe Robin Cotton was involved in a conspiracy?

18 MR. SIMS:

Yes.

19 MR. HARMON:

Okay. Do you have any reason to believe Greg Matheson is involved in any conspiracy to frame the Defendant in this case, Mr. Simpson?

20 MR. SIMS:

No.

21 MR. HARMON:

Do you have any reason to believe that Dennis Fung is involved in a conspiracy to--

22 MR. SCHECK:

Objection. No foundation, outside the scope.

23 THE COURT:

Sustained.

24 MR. HARMON:

Mr. Sims, Mr. Scheck asked you to--in another one of these hypotheticals to describe the numbers of possible combinations that could be accounted for in the stain on the console, item 303, and he asked you to assume that the Defendant's type, a 1.1, 1.2 is in there, and he gave you that sheet. Do you recall that sheet?

25 MR. SIMS:

Yes.

26 MR. HARMON:

And you looked very carefully at that sheet; did you not?

27 MR. SIMS:

Yes.

28 MR. HARMON:

And it's true, is it not, that that's only one of the markers that you performed on that stain--on that stain on 303?

29 MR. SIMS:

Yes. DQ-Alpha was only one of the markers we tested for.

30 MR. HARMON:

So that sheet and that entire series of questions ignored an entire set of data that you produced from your analyses on those stains; did it not?

31 MR. SIMS:

Yes, it did.

32 MR. HARMON:

But let's take it at face value if you will, okay, Mr. Sims?

33 MR. SIMS:

Okay.

34 MR. HARMON:

You described ignoring half of the data that your lab produced, that--

35 MR. SCHECK:

Objection.

36 THE COURT:

Rephrase the question.

37 MR. HARMON:

You've described in not addressing the D1S80 data that you produced in your test to that stain, that only two of the 37 combinations were consistent with combinations of the victims? Is that the way you've described it?

38 MR. SIMS:

The way the hypothetical was presented, yes.

39 MR. HARMON:

Okay. And let's talk about possible interpretations of those 37 results, only two of which were consistent with the victims in this case, okay?

40 MR. SIMS:

Okay.

41 MR. HARMON:

Could that mean that there were 35 other people killed that night whose blood was in that car?

42 MR. SCHECK:

Objection.

43 THE COURT:

Sustained.

44 MR. SCHECK:

Argumentative.

45 THE COURT:

Rephrase the question.

46 MR. HARMON:

Could that mean that there were 35 other dead people whose blood was found on that console in that car?

47 MR. SCHECK:

Objection.

48 THE COURT:

Sustained. Rephrase the question.

49 MR. HARMON:

Could that mean that there were 35 other deceased people whose blood was found in the stain in 303?

50 MR. SCHECK:

Objection.

51 THE COURT:

Sustained. Rephrase the question.

52 MR. HARMON:

Does that mean that there were 35 other living people whose blood was found on that stain in the car?

53 THE COURT:

35 other persons who may have contributed with different genotypes.

54 MR. SIMS:

Yes.

55 MR. HARMON:

Okay. For example, you can't exclude the possibility that 35 other people with different genotypes had nosebleeds on that same spot on the console, can you?

56 MR. SIMS:

Well, again, they'd have to miss the substrate control area, but that's true.

57 MR. HARMON:

Okay. Is there something funny about broncos that might cause nosebleeds like that?

58 MR. SCHECK:

Well, your Honor--

59 THE COURT:

Sustained.

60 MR. HARMON:

Mr. Scheck asked you and you struggled to try to think of a casework experience you've had--

61 MR. SCHECK:

Your Honor--

62 THE COURT:

Sustained. Why don't you rephrase it without the characterization.

63 MR. HARMON:

Sure.

64 MR. HARMON:

Remember Mr. Scheck asked you whether or not you'd had an actual case where you had blood mixtures?

65 MR. SCHECK:

Objection. That's not what I asked him. Proficiency tests.

66 THE COURT:

Overruled. In the context of proficiency testing.

67 MR. HARMON:

Well, and then you went on--he went on, and I believe you said you thought you'd encountered such a thing in casework. Do you recall that?

68 THE COURT:

Let's have him--

69 MR. SCHECK:

Your Honor, objection. I only asked him about proficiency tests.

70 THE COURT:

Sustained.

71 MR. HARMON:

Have you ever encountered a blood mixture in actual casework?

72 MR. SIMS:

Yes, I have.

73 MR. HARMON:

Could you explain the scenario or the setting of that case?

74 MR. SIMS:

Yes. The--

75 MR. SCHECK:

Objection. Beyond the scope.

76 THE COURT:

Overruled.

77 MR. SIMS:

The scenario, as I recall it, was, an individual was beaten with a weapon, a blunt object that caused a lot of bleeding of the victim, and the issue was whether or not we could find some of the perpetrator's type who also we thought might be bleeding on that particular weapon, that perhaps had put the handle in, and we were able to show that there was a mixture of victim and perpetrator blood and it did happen that the blood then did match also the perpetrator's type or--I'm sorry--or the suspect's type. So those things will happen, yes.

78 MR. HARMON:

So in the context of that case, it was the mixture of these two coincidental types that were significant to you; is that right?

79 MR. SIMS:

Yes.

80 MR. HARMON:

And it is a challenge trying to sort those things out, is it not, when they're blood mixtures?

81 MR. SIMS:

Yes, it is. And that's why I think it's important to look at all the data.

KEY QUOTE
82 MR. HARMON:

All the different markers that you test?

83 MR. SIMS:

All the different markers and all the results.

84 MR. HARMON:

And in the context of that case, you found the victim's blood on something associated with the suspect?

85 MR. SIMS:

Yes. That was it.

86 MR. HARMON:

And then the suspect's own blood mixture on something associated with him?

87 MR. SIMS:

Yes. That was it basically.

88 MR. HARMON:

Okay. Just to digress for a second, if you saw Mr. Simpson's type in a stain and you were unable to see a c dot there, how would you report that?

89 MR. SIMS:

In our laboratory, we would not consider that to be a typeable result. We would note the types, but we would not consider it to be a reportable result.

90 MR. HARMON:

Okay. Now, Mr. Scheck asked you whether or not your tests can show the order of deposition or when or the order of deposition on the console. Do you recall that?

91 MR. SIMS:

Yes.

92 MR. HARMON:

In fact, regardless of when or how or the sequence of events that caused stains to be deposited there, if your tests showed the types that are actually there, they perform successfully; is that true?

93 MR. SCHECK:

Objection. Move to strike the characterization.

94 THE COURT:

Overruled.

95 MR. SIMS:

I would say yes.

96 MR. HARMON:

For example, the steering wheel, can you tell when or the order those stains or those actual biological materials were deposited there?

97 MR. SIMS:

No.

98 MR. HARMON:

And Mr. Scheck's--the handwritten chart with those large numbers on it, do those numbers also ignore some of the data that was produced in this case--on that stain?

99 MR. SCHECK:

Objection.

100 THE COURT:

Rephrase the question.

101 MR. SCHECK:

Move to strike.

102 THE COURT:

Rephrase the question.

103 MR. HARMON:

Is there other data that was produced as a result of yours and Cellmark's testing on the steering wheel that could tend to contribute to the frequencies that you calculated?

104 MR. SIMS:

Well, yes. There was data generated by Cellmark with regards to the poly-marker.

105 MR. HARMON:

Is your opinion as it was when you testified last week concerning being unable to say that the 1.3 allele is not there?

106 MR. SIMS:

Can you rephrase that again?

107 MR. HARMON:

Sure. Is your concern or your opinion about the results of 29, the steering wheel stain, is it as you expressed it last week; that you can not say that because of the low amount of DNA that was in that sample, that the 1.3 allele is not there?

108 MR. SIMS:

That's correct. In other words, I can not unequivocally say that we would have seen the 1.3 allele in that test.

109 MR. HARMON:

And in that regard, in that context, including all the data that was produced in this case, what is the significance of Mr. Scheck's handwritten chart summing up frequencies?

110 MR. SCHECK:

Objection.

111 THE COURT:

Sustained. Rephrase the question, significance.

112 MR. HARMON:

What is the forensic significance of the summed-up chart--

113 MR. SCHECK:

Move to strike.

114 THE COURT:

No. It's not a motion to strike. It's an objection. Rephrase the question.

115 MR. SCHECK:

Objection.

116 MR. HARMON:

In your opinion, does Mr. Scheck's chart in light of the concern that you--or the limitation or the reservation you have about 29, what does the chart mean when it sums up all the frequencies?

117 MR. SCHECK:

Objection. Objection.

118 THE COURT:

Sustained. Rephrase the question. The question is unintelligible.

119 MR. HARMON:

Do those frequencies reflect anything significant in your opinion with regard to the results that you obtained from steering wheel item no. 29?

120 MR. SCHECK:

Objection. Move to strike, argumentative. Frequencies are the frequencies.

121 THE COURT:

Motion to strike the question is not appropriate in California, counsel.

122 MR. SCHECK:

My apologies. Objection.

123 THE COURT:

Sustained. Rephrase the question.

124 MR. HARMON:

Okay. Do those frequencies reflect anything in relation to your opinion and your reservation about the results on item 29 from the steering wheel?

125 MR. SCHECK:

Objection.

126 THE COURT:

Rephrase the question.

127 MR. HARMON:

What if anything do those frequencies reflect in light of your reservations about your test results from item 29?

128 MR. SCHECK:

Still objection.

129 THE COURT:

Mr. Sims, you saw that chart?

130 MR. SIMS:

Yes.

131 THE COURT:

You indicated that you had some concern about the numbers that were there, the assumptions that were behind it.

132 MR. SIMS:

Yes. My concern was just that--with the assumption.

133 THE COURT:

What assumption concerns you in rendering that opinion?

134 MR. SIMS:

Well, what concerned me was that I again couldn't absolutely rule out the possibility of the 1.3 allele not being detected in that weak mixture. That's all.

135 THE COURT:

Proceed.

136 MR. HARMON:

Thank you, your Honor. May we see Defendant's exhibit 1166 on the elmo, your Honor?

137 THE COURT:

Yes. Mr. Fairtlough. This is the dot blot photo.

138 (Brief pause.)
139 MR. HARMON:

Mr. Sims, you recognize that when you saw 1166, that's Dr. Blake's photo; is that right?

140 MR. SIMS:

Yes. I believe that one was, 1166, yes.

141 MR. HARMON:

But the handwriting on there is your handwriting?

142 MR. SIMS:

The--the writing on those strips is by Renee Montgomery.

143 MR. HARMON:

Let's start at the top and describe the items so that the jury can appreciate all the results that are contained on exhibit 1166. DNA 17, what LAPD item does that correspond with?

144 MR. HARMON:

May we have the--might be hard--the Bundy or the Bronco board up there?

145 (Brief pause.)
146 MR. HARMON:

Mr. Sims, while we're getting to that, in spite of all the questions that Mr. Scheck asked you about Defense exhibit 1166, do you have any doubt about the results that you expressed on direct examination?

147 MR. SIMS:

No. I was confident of all the calls we made on this run.

148 MR. HARMON:

In fact, focusing on exhibit 1166 ignores all of the D1S80 results which were produced from analysis of these samples? Is that true?

149 MR. SCHECK:

Objection to the characterization of the word "Ignores."

150 THE COURT:

Sustained. Rephrase the question.

151 MR. HARMON:

Mr. Scheck's discussion of Defense exhibit 1166 does not take into account any of the D1S80 results on the items that were analyzed that are listed on 1166?

152 MR. SCHECK:

Objection. Objection to the phrasing of this question.

153 THE COURT:

Sustained. It's leading.

154 MR. HARMON:

What if anything do the D1S80 results contribute to your understanding and your expression of the results that are reflected on 1166, simply the DQ-Alpha strips?

155 MR. SIMS:

Well, again, we look to the consistency of the additional systems that were tested; and in this case, it would be D1S80.

156 MR. HARMON:

Okay. While you're looking there--let's look at every alternate strip if we would, starting from the second from the top. DNA 17C, that's a substrate control?

157 MR. SIMS:

Yes. DNA 17C, that's cut off a little bit by the post-it, but that's the substrate control, yes.

158 MR. HARMON:

And there's no typeable activity in there; is that right?

159 MR. SIMS:

That's correct. No dots light up at all.

160 MR. HARMON:

And what does that mean?

161 MR. SIMS:

That means that no activity--no DNA was detected in the substrate control for that particular sample.

162 MR. HARMON:

Okay. And let's move down to DNA 18 control. That is the Bronco center console 31 substrate control?

163 MR. SIMS:

Yes.

164 MR. HARMON:

And that--again, would you describe those results?

165 MR. SIMS:

Yes. That control on DNA 18, which is 31 LAPD, again totally negative, no dots light up at all.

166 MR. HARMON:

And DNA 29 which corresponds to LAPD 293, the Bronco carpet, driver's side that was consistent with Nicole Brown, is that substrate control--what result does that produce?

167 MR. SIMS:

Again, the substrate control for that item is totally negative. No dots were seen.

168 MR. HARMON:

And jumping another strip down to the lane or the label DNA 30 control, is that the substrate control for LAPD item 305 on the center console?

169 MR. SIMS:

Yes, it is.

170 MR. HARMON:

And that substrate control produced no typeable results; is that true?

171 MR. SIMS:

That's correct. No dots. Not just no typeable results, but no dots period.

172 MR. HARMON:

No dots whatsoever. And we'll discuss substrate controls in a while. Do these substrate control strip results show that there was or that there was no typeable activity on all of those strips and all of those stains?

173 MR. SIMS:

That's correct.

174 MR. HARMON:

Okay. Now, let's start out with DNA 17. What was your result on that?

175 MR. SIMS:

The type for that was 1.1, 1.2.

176 (Discussion held off the record between the Deputy District Attorneys.)
177 MR. HARMON:

DNA 18?

178 MR. SIMS:

On DNA 18, that was--now, that was a mixture of types with the main type being a 1.1, 1.2 with the weaker type being a 1.3, 4. And what made this one more difficult was the assessment of whether or not the 1.2 allele was really there. I think we talked about this earlier, that there's not a distinct separate probe for the 1.2 allele. So you have a dot there, the 1.2, 1.3, 4 dot, that can be lit up by any of those three probes. And the key here that we--and admittedly, this one was one where we had to take a hard look at--was that that intensity is so great in that 1.2, 1.3, 4 dot that the 4 and the 1.3 alone would not produce a dot of that intensity. So we made the determination from that that we felt that the 1.2 allele was present which meant that the main type was 1.1, 1.2 and that the weaker components were 1.3, 4.

179 MR. HARMON:

And D1S80 results on that stain?

180 MR. SIMS:

On DNA 18?

181 MR. HARMON:

Yes.

182 MR. SIMS:

That was the--we found both the 24 and the 25 alleles present.

183 MR. HARMON:

And Mr. Goldman is a 24, 24?

184 MR. SIMS:

That's correct.

185 MR. HARMON:

Mr. Simpson is a 24, 25?

186 MR. SIMS:

That's correct.

187 MR. HARMON:

And that narrows down the possibilities when you include that?

188 MR. SIMS:

Yes, it does significantly.

189 MR. HARMON:

And let's move on then to DNA 29.

190 MR. SIMS:

Okay. On DNA 29--excuse me. The--the call on DNA 29--and this is actually LAPD no. 293. The main--the call there was that that--the main type was a 1.1, 1.1 and there's--it's--it's hard to see on mine, but there was--there was a little bit of activity at the--at the 1.2, 1.3, 4 dot. So we interpreted that to be a 1.1, 1.1 with a possible trace of 1.2.

191 MR. HARMON:

And there's none of this funny stuff with the 1.3 dot on this strip, is there?

192 MR. SIMS:

On that strip?

193 MR. HARMON:

Yes.

194 MR. SIMS:

No. It was negative.

195 MR. HARMON:

Let's move on to DNA 30 then.

196 MR. SIMS:

Okay. For DNA 30, this is LAPD no. 305. Now, in this particular case--this is where we talked about the tough call. If you contrast DNA 30 with DNA 18, you can now see that there is a 1.1 dot, there's a 1.3 dot, there's a 4 dot, but now the question is, is the 1.2 allele definitely present. And we argued--well, we discussed it. We decided that no, you could not definitely say that the 1.2 allele was present because that 4 dot and the 1.3 dots could possibly give an intensity similar to that. So that's why on our chart, we see over there possible 1.2.

197 MR. HARMON:

Okay. Mr. Scheck asked you with regard to results on Defense exhibit 1166--or strike that. He asked with regard to one of the other sets of strips. Could another trained eye disagree with you? Do you recall that question?

198 MR. SIMS:

Yes.

199 MR. HARMON:

Has any other trained eye disagreed with you?

200 MR. SCHECK:

Objection. Hearsay.

201 THE COURT:

As to these results?

202 MR. SCHECK:

Yes.

203 THE COURT:

Sustained.

204 MR. HARMON:

Would you like to see another trained eye disagree with you on those results?

205 MR. SCHECK:

Well--

206 THE COURT:

Overruled.

207 MR. SCHECK:

Argumentative.

208 THE COURT:

Overruled.

209 MR. SIMS:

I'd be happy to discuss any result we generated in this case with any other expert.

210 MR. HARMON:

Has anyone had that discussion with you?

211 MR. SCHECK:

Objection. Calls for hearsay.

212 THE COURT:

Overruled. Yes or no? Have you discussed these results with any other experts other than Miss Montgomery.

213 MR. SIMS:

No. No, other than people in our laboratories as I mentioned as part of the team.

214 MR. HARMON:

And if some trained eye discussed it with you, could they also retest with the remaining evidence in this case?

215 MR. SCHECK:

Objection. Move to strike. He's calling for hearsay about trained eyes.

216 THE COURT:

Overruled. But the question was regarding retesting.

217 MR. SIMS:

Yes. If somebody disagreed with these results, then they could retest the evidence. They could request the extracted DNA. They could retest the product, the PCR product.

218 MR. HARMON:

Mr. Scheck discussed in the context of this strip the possibility of PCR carryover. Do you recall that?

219 MR. SIMS:

Yes.

220 MR. HARMON:

PCR product carryover?

221 MR. SIMS:

Yes.

222 MR. HARMON:

And do you see any signs of PCR product carryover in any of the substrate controls or any of the negative controls in this case?

223 MR. SIMS:

No, I did not.

224 MR. HARMON:

And I believe you said this is Dr. Blake's photo?

225 MR. SIMS:

Yes, I believe this one is.

226 MR. HARMON:

The Defense expert in this case?

227 MR. SIMS:

Yes.

228 MR. HARMON:

Were you present when he took the photo?

229 MR. SIMS:

Yes, I believe he was because he was also present at the reading of that--

230 MR. HARMON:

Were those two separate--I'm sorry.

231 MR. SIMS:

He was present at the reading of these strips. We took our photo and then I believe he took his photo, but I'd have to check my notes on that.

232 MR. HARMON:

Could you do that?

233 MR. SIMS:

(Witness complies.) I--I believe it was photoed at that same time. I--yes. I do believe it was.

234 MR. HARMON:

At the same time?

235 MR. SIMS:

Well, right after we made our photograph. That's my recollection.

236 MR. HARMON:

Okay. And throughout this whole photography and reading process, have you consistently interpreted the strips the way you've described your conclusions to this jury?

237 MR. SIMS:

Yes.

238 MR. HARMON:

And also including the D1S80 results?

239 MR. SIMS:

Yes.

240 MR. HARMON:

And nothing has happened to sway your opinion at all; is that correct?

241 MR. SIMS:

No.

242 MR. HARMON:

Let's move to Defense exhibit 1168.

243 (Brief pause.)
244 MR. HARMON:

Now, do you rec--I believe you said you recognize the handwriting on this one?

245 MR. SIMS:

Yes, I do.

246 MR. HARMON:

That's Dr. Blake's handwriting?

247 MR. SIMS:

Yes. That looks like Dr. Blake's handwriting at the top and on the right side.

248 MR. HARMON:

What sorts of contact did you have with Dr. Blake with respect to the set of strips that were run that are reflected on Defense exhibit 1168?

249 MR. SIMS:

Can you rephrase that question for me, please?

250 MR. HARMON:

Sure. What were the nature of your contacts with Dr. Blake? I'm not asking you to describe conversations. What kinds of contacts did you have with regard to the strips that are shown in Defense exhibit 1168?

251 MR. SIMS:

Well, Dr. Blake photographed these results in our laboratory. Again, I'd want to check because there were a couple times when he came back and photographed our photos, like there was some glare problems or something like that. So I think--I think though on this particular one, he was probably present. But if I could have one second, I'll check on that.

252 MR. HARMON:

Sure.

253 MR. SCHECK:

Your Honor, while he's doing that, can we approach for a second about a matter?

254 THE COURT:

No.

255 MR. SCHECK:

1054 matter.

256 THE COURT:

No.

257 MR. HARMON:

Your Honor, could we have 259, the Bundy board, up there now?

258 (Brief pause.)
259 MR. SIMS:

No. It's not clear exactly when that photograph was taken by him.

260 MR. HARMON:

Okay. Was he present when you read those strips?

261 MR. SIMS:

I don't believe he was. I don't--I didn't record that. So I don't think he was.

262 MR. HARMON:

When you actually read them, are you writing them down, the results, on some sort of piece of paper?

263 MR. SIMS:

Well, the way it's done is, we have a run sheet where you fill out the results for each one of these dots and the--the primary analyst, the one who does the actual run, writes down his or her results. And then what happens is, the second reader comes along, looks at just the strips and tells the primary analyst what his or her interpretations are. So we have two separate readings of these--of these strips.

264 MR. HARMON:

Okay. And at a later point, you show all those things to Dr. Blake?

265 MR. SIMS:

Well, yes. In other words, Dr. Blake would review the strips.

266 MR. HARMON:

And again--well, strike that.

267 MR. SCHECK:

Move to strike, unreviewed, the implication. I want to approach.

268 THE COURT:

Overruled. No.

269 MR. HARMON:

Now, Mr. Scheck spent quite a bit of time about whether or not the 1.3 was an artifact. Do you recall those series of questions?

270 MR. SIMS:

Yes.

271 MR. HARMON:

And you feel that it is; is that correct?

272 MR. SIMS:

On that particular sample, I believe it is, yes.

273 MR. HARMON:

Okay. And we'll talk about your rehybridization in a couple minutes. But do Cellmark's DQ-Alpha, poly-marker and RFLP results corroborate your opinion that the 1.3 allele that you detected or the 1.3 artifact that you detected in that strip is in fact an artifact?

274 MR. SCHECK:

Objection. Irrelevant.

275 THE COURT:

Overruled.

276 MR. SIMS:

Yes, they do corroborate that.

277 MR. HARMON:

And would it be sound scientific practice to focus on the first of two hybridization strips to debate about whether or not the 1.3, which is seen on the strip on 1168, is an artifact when that issue is resolved by another laboratory's DQ-Alpha, poly-marker and RFLP results?

278 MR. SCHECK:

Objection.

279 THE COURT:

The question is argumentative.

280 MR. HARMON:

What impact do--or could you explain the impact that Cellmark's DQ-Alpha, poly-marker and RFLP results have on the discussion you had with Mr. Scheck about the 1.3 artifact that might have been on the strip reflected by no. 52 on exhibit 1168?

281 MR. SIMS:

Well, it doesn't--as far as the interpretation of that particular data, that's--I repeated that result because of the overall pattern that I saw on the strips. But the--it doesn't--the final interpretation is consistent with that being an artifact.

282 MR. HARMON:

And by that, Cellmark's DQ-Alpha results were what?

283 MR. SIMS:

They were 1.1, 1.2.

284 MR. HARMON:

Not a mixture?

285 MR. SIMS:

I--that's my recollection.

286 MR. HARMON:

And their poly-marker results?

287 MR. SIMS:

I believe they were also--

288 MR. SCHECK:

Objection. Move to strike. He can't comment on poly-markers for me.

289 THE COURT:

Sustained.

290 MR. HARMON:

Assume hypothetically Cellmark's poly-marker results included Mr. Simpson. Would that corroborate the fact that the 1.3 was an artifact?

291 MR. SIMS:

Yes.

292 MR. HARMON:

And also, we can't forget your D1S80 results. Were they corroborative of the fact that that stain was consistent with Mr. Simpson and did not appear to be a mixture?

293 MR. SIMS:

Yes. When we looked at an additional system, we saw no evidence that there was a weak component in a mixture.

294 MR. HARMON:

Now, again, other trained eyes could disagree with you, couldn't they?

295 MR. SIMS:

Yes.

296 MR. HARMON:

Have any other trained eyes disagreed with you?

297 MR. SIMS:

No.

298 MR. SCHECK:

Objection. Same objection as before, hearsay.

299 THE COURT:

Overruled.

300 MR. HARMON:

And has anything happened since you first interpreted the DQ-Alpha strip for your DNA item 55A, which is LAPD 52, which is on the projection screen as Defense exhibit 1168, that causes you to question that that is a 1.1, 1.2?

301 MR. SIMS:

No.

302 MR. HARMON:

Okay. But nonetheless, you rehybridized is; is that true?

303 MR. SIMS:

Yes. In other words, within our own laboratory, we checked it out.

304 MR. HARMON:

Okay. But before we move on to that, you mentioned a couple of times that this was a tough call for you. Do you recall that?

305 MR. SIMS:

Yes.

306 MR. HARMON:

And would you explain what you mean or what you meant by that to the jury?

307 MR. SCHECK:

Objection. Asked and answered already on redirect.

308 THE COURT:

I think we've asked that already.

309 MR. HARMON:

Have you already answered that question?

310 MR. SIMS:

I think we talked about it in the context of that other--that other stain, which was really the tough call about whether or not the 1.1 and the 1.2 were together in that stain.

311 MR. HARMON:

Okay. Well, let's--can we put--may I have it marked as People's next in order, a--

312 MR. HARMON:

You--Mr. Sims, do you have the hybridization photo for the rehybridization of 52--oh, you know, before--I'm sorry. Before we move on, let's stay with 1168 if we can for a couple minutes. Start at the top, Mr. Sims, and tell us--there are a lot of things up there that have C's next to them. There's a 52C, a 47C, a 48C, a 50C. You see all those?

313 MR. SIMS:

Yes, I do.

314 MR. HARMON:

Are those substrate controls?

315 MR. SIMS:

Yes. All of those with the c at the end are substrate controls. From the top, it would be for LAPD no. 52, LAPD no. 47, substrate control 48, substrate control 50, substrate control--those are all substrate controls for Bundy drops.

316 MR. HARMON:

And just to summarize them, did they all produce no typing results?

317 MR. SIMS:

Well, again, not--no dots at all were seen with those.

318 MR. HARMON:

And what is the importance of those stains having produced no typing results just in the context of this series of tests that are reflected on 1168?

319 MR. SIMS:

Just within this series?

320 MR. HARMON:

Yes.

321 MR. SIMS:

Well, again, you don't see any level of contamination such as PCR product control as you look across the series of strips like this.

322 MR. HARMON:

Okay. And do they also have an important role in the bigger picture?

323 MR. SIMS:

I think they have a very important role in the bigger picture.

324 MR. HARMON:

And we'll talk about the bigger picture in a while, okay?

325 MR. SIMS:

Okay.

326 MR. HARMON:

Can we have the--

327 MR. HARMON:

Did you give me your photo that shows the rehybridization of 52? I believe that's back there. You want to check up there, Mr. Sims? We seemed to have lost it.

328 MR. SIMS:

Yes.

329 (Brief pause.)
330 MR. SIMS:

I do have it. No. I'm sorry. This is not it. This is a different photo.

331 MR. HARMON:

I have it.

332 THE COURT:

All right. Have you shown that to Mr. Scheck?

333 MR. HARMON:

May we have that marked as People's next in order?

334 THE COURT:

274.

335 (Peo's 274 for id = photograph)
336 MR. HARMON:

Okay. Mr. Sims, could you just start at the top of People's exhibit 274 and describe the samples that are represented by those horizontal strips?

337 MR. SIMS:

Yes. This is--this is some rehybridizations of some of the samples that we wanted to take a second look at in this case. The first one is 42B1, which was stain B1 from the sock. The next one is 41B2, which is also from the sock. And then there's a positive control that was being rehybed, a negative control. And then the 55A on the--which is the one, two, three--the fifth strip down, that's no. 52, the rehybe.

338 MR. HARMON:

The second one from the bottom?

339 MR. SIMS:

The second one from the bottom. And then the last one is a rehybe of the positive control that was run at the same time that 52 originally was run.

340 MR. HARMON:

And is your opinion still the same about LAPD 52, which is the stain out in the driveway in the rear of the Bundy residence, that drop of blood, as it was when you saw the strips the first time you hybridized them?

341 MR. SIMS:

Well, yes. But now I have--I have checked it to make sure that that is the correct type, the 1.1, 1.2 is the correct type.

342 MR. HARMON:

Okay. And in this rehybridization process, is that something that another trained eye could do if they had any of the DNA?

343 MR. SIMS:

Yes. That's--that's something you could do with the PCR product.

344 MR. HARMON:

Anyone who's conversant with this system?

345 MR. SIMS:

Yes.

346 MR. HARMON:

And you've already described, there's quite a bit of PCR product around on these samples?

347 MR. SIMS:

Well, there's--on all these samples, I believe we still have PCR product left on all of them.

348 MR. HARMON:

Would that be one way of confirming or refuting the results that you produced here in Court?

349 MR. SIMS:

It would be one check, yes.

350 MR. HARMON:

Okay. And we talked about the poly-marker and D1S80 results. How do they support your initial and now confirmed opinion that 52 is a 1.1, 1.2?

351 MR. SCHECK:

Motion to strike with respect to poly-marker.

352 THE COURT:

Sustained. Rephrase the question.

353 MR. HARMON:

Do the Cellmark poly-marker, DQ-Alpha results and your D1S80 results--

354 THE COURT:

Poly-marker is the problem.

355 MR. HARMON:

Excuse me?

356 THE COURT:

Poly-marker.

357 MR. HARMON:

Do the Cellmark poly-marker--

358 THE COURT:

No. No. No. No poly-marker.

359 (Discussion held off the record between the Deputy District Attorneys.)
360 MR. HARMON:

Do the Cellmark results and your D1S80 results confirm your finding that the 1.3 was an artifact in light of the fact that--

361 THE COURT:

Sustained. It's vague. I think you're restricted to the D1S80.

362 MR. HARMON:

And the DQ-Alpha, your Honor.

363 THE COURT:

And the DQ-Alpha that Cellmark did.

364 MR. HARMON:

Do the Cellmark RFLP and DQ-Alpha results and your D1S80 results confirm your initial opinion which is confirmed on People's 274, that the 1.3 was an artifact in item 52?

365 MR. SIMS:

Well, again, there's consistency in all those results.

366 MR. HARMON:

And other trained eyes could disagree with you?

367 MR. SIMS:

Yes.

368 MR. HARMON:

But none have to your knowledge?

369 MR. SCHECK:

Objection. Move to strike.

370 THE COURT:

Sustained.

371 MR. HARMON:

Mr. Scheck asked you a lot of questions about your sound scientific practice. Do you recall those a couple days ago?

372 MR. SIMS:

Yes.

373 MR. HARMON:

Does that mean that the way you do things is the only way to do things?

374 MR. SIMS:

No.

375 MR. HARMON:

For example, you use a restriction enzyme HAE 3, Cellmark uses hin-f1?

376 MR. SIMS:

Yes. That would be a difference.

377 MR. HARMON:

So HAE 3 isn't the only sound scientific practice then?

378 MR. SIMS:

That's correct.

379 MR. HARMON:

What about extraction techniques? That's one of the initial steps in the process. You use the organic extraction process?

380 MR. SIMS:

Yes. In this case, we used the organic extraction process. For example, there's a chelex extraction process and that's--that's an acceptable practice.

381 MR. SCHECK:

Your Honor, I move to strike these questions as outside the scope of cross-examination in terms of these particular type things. It's not what I asked him about.

382 THE COURT:

Overruled.

383 MR. HARMON:

When you said--when you describe things as sound scientific practice, do you mean that any other way things are done is unsound?

384 MR. SIMS:

No.

385 MR. HARMON:

Have you always done things the way you do them now?

386 MR. SIMS:

No.

387 MR. HARMON:

For example, did you always flame your tools?

388 MR. SIMS:

No.

389 MR. HARMON:

Were you unsound before you flamed your tools?

390 MR. SIMS:

I don't think so.

391 MR. HARMON:

Why do you flame your tools?

392 MR. SIMS:

Well, there's some things that you do in this business just because that shuts down anyone saying, "Well, why didn't you do that," or, "What did you think about that," or, "Is it possible that you had something on there?" And so there's certain steps that one can take to just eliminate any of those possibilities. And I've been involved in a case recent--not too long ago where it was inferred that the way I was cleaning my tools was insufficient. And so what I decided to do was to say, okay, let's remove that argument. Let's just burn these things.

393 MR. HARMON:

To your personal knowledge, does Dr. Edward blank flame his tools?

394 MR. SCHECK:

Objection. Irrelevant.

395 THE COURT:

Sustained.

396 MR. HARMON:

Even if an analyst wasn't as meticulous as you, if he follows the PCR, DQ-Alpha user guide, including the use of positive, negative and substrate controls, in your opinion, would those results be sound scientific results?

397 MR. SCHECK:

Objection. Move to strike without foundation.

398 THE COURT:

Overruled.

399 MR. SIMS:

Yes. I think if one follows the user guide, that those are--those would lead to sound results. Those are sound practices leading to good results.

400 MR. HARMON:

Other sound practices?

401 MR. SIMS:

Yes.

402 MR. HARMON:

Mr. Scheck asked you some questions about your QA manual, your quality assurance manual?

403 MR. SIMS:

Yes.

404 MR. HARMON:

Recall those?

405 MR. SIMS:

Yes.

406 MR. HARMON:

Do you believe that the examiner should only or should examine only one item of evidence at a time?

407 MR. SIMS:

Yes.

408 MR. HARMON:

In fact, that's what your QA manual says; is that right?

409 MR. SIMS:

Yes, it does.

410 MR. HARMON:

And do you believe that this practice of examining only one item of evidence at a time will guard against sample mix up and cross transfer?

411 MR. SIMS:

Yes. It's a very important tool because that way, you only have one thing in front of you that you're dealing with at any given moment when you're talking about examining a basic bloodstain or swatches for example.

412 MR. HARMON:

And that's from your quality assurance manual?

413 MR. SIMS:

Yes, that is.

414 MR. HARMON:

Do you believe that reasonable care will be taken to ensure that the risk of inadvertent transfer between high and low DNA concentration samples, evidence and reference samples and between victim and suspect is minimized if you take reasonable care?

415 MR. SIMS:

Yes.

416 MR. HARMON:

And do you believe that this may include only processing the samples at a different time or space and/or processing only a few samples at a time?

417 MR. SIMS:

Yes. That's from our QA manual.

418 MR. HARMON:

Is it that hard to do?

419 MR. SIMS:

No. It's done routinely in laboratories all over the country.

420 MR. HARMON:

Now, Mr. Scheck asked you several days ago about a seven-day period from start to finish with some of your evidence processing through typing. Do you recall that series of events and questions?

421 MR. SIMS:

Yes. I believe that was from some time in August.

422 MR. HARMON:

Okay. And now, in that context, I'd like to actually describe what you did versus what you normally do. Okay, Mr. Sims?

423 MR. SIMS:

Okay.

424 MR. HARMON:

Did that seven days represent the fastest period of time within which those complete set of tests could have been performed?

425 MR. SIMS:

By no means. In fact, it was September now. I remember it was a series of days in September. But I think what that would represent was about the slowest it could ever take to do that series of tests.

426 MR. HARMON:

Okay. Why was it so slow?

427 MR. SIMS:

Well, we were being extremely methodical as far as sampling this evidence. We were--we were documenting each part of the process--

428 MR. SCHECK:

Excuse me, your Honor. Could he be specific as to which samples because I asked him about a few.

429 THE COURT:

Yes.

430 MR. HARMON:

Sure.

431 MR. HARMON:

Could we focus on what--the series of questions this was about? Do you recall the dates?

432 MR. SIMS:

Yes. It began I believe on September 8th.

433 THE COURT:

And do you recollect what items you were testing?

434 MR. SIMS:

Well, again, I'm going to have to refer to my notes to refresh my memory.

435 THE COURT:

All right.

436 MR. SIMS:

Is there a question in front of me?

437 MR. HARMON:

Sure. What items did that sequence or that series represent, Mr. Sims?

438 MR. SIMS:

That would be item no. 47, item no. 1, item no. 20, item no. 14, item no. 15, item no. 16, item no. 17, item no. 18, item no. 19, item no. 20, item no. 26. I think that's--well, no. There was some additional items. Now, item no. 293, item no. 305.

439 MR. HARMON:

Mr. Sims, are you going back and forth between your DOJ numbers and the LAPD numbers on us?

440 MR. SIMS:

Oh, I'm sorry. I'm doing that, yes.

441 MR. HARMON:

Could we get them in terms of LAPD numbers?

442 MR. SIMS:

Well, no. Actually I don't--yes, I'm sorry. I did do that. I mentioned 47, I mentioned 1, 20, 24, 29, 30, 31, 32, 34, 55, 293, 305. I think that's it for those samples.

443 MR. HARMON:

Well, what took so long that you don't normally do in the processing of these samples?

444 MR. SIMS:

Well, I think--I think you begin by the fact that any time you have a guest in the laboratory, that automatically adds a certain amount of time to the process.

445 MR. HARMON:

Is that unusual?

446 MR. SIMS:

No. I mean, there's a certain level of hello, how are you and all that kind of thing that always goes on. But more to the point would be that the documentation would be twofold. In other words, I would take a photograph and then Dr. Blake would take a photograph and then I'd stop and make sure he had taken his photograph before I moved on to do my next step and et cetera, et cetera, et cetera. So that's--that's a long part of the process. And that--now, that would include just the actual sampling of these items. In other words, to get it out of that coin envelope, documented, photographed, et cetera, and then put into a test tube for later testing.

447 MR. HARMON:

What about the weighing of samples? Did that take place during this sequence?

448 MR. SIMS:

Yes. This was something that I had never done before in a case, where I actually weighed the swatches, individually weighing them. And, you know, as you can imagine, one has to be very careful because you're starting to now handle the evidence in an unusual way. And so you have to make sure that goes right. And that takes time.

449 MR. HARMON:

Having never done this before and adding a new step in the sample processing, does that increase the likelihood or possibility of some sort of problem?

450 MR. SIMS:

Well, it--any time you excessively handle things, it makes me nervous. But I--I just had to slow things down to make sure that we didn't lose one of these. For example, in other words, one didn't fly off the forceps or something like that and land on the floor. That would be the kind of concern that I would have.

451 MR. HARMON:

Is there anything in your protocol about weighing samples?

452 MR. SIMS:

No.

453 MR. HARMON:

How much additional time do you think this weighing, double documentation, double photographing contributed to the process?

454 MR. SIMS:

Well, I mean, to the whole--it's hard for me to say exactly, but it would at least double, maybe triple the amount of time that I'd spend, something like that. I don't know exactly.

455 MR. HARMON:

Okay. Now, I believe you mentioned that you did the organic extraction process?

456 MR. SIMS:

Yes.

457 MR. HARMON:

And chelex you mentioned earlier, that's a much faster process?

458 MR. SIMS:

Yes. The chelex extraction can be done in a matter of a couple hours. The organic for one thing would take overnight, and then there's a lot more processing down at the--afterwards.

459 MR. HARMON:

And there's another step called the product gel?

460 MR. SIMS:

Yes.

461 MR. HARMON:

And do you usually do that before you--the final product or the typing is conducted?

462 MR. SIMS:

Usually, but not always.

463 MR. HARMON:

Okay. Sometimes you do it afterwards?

464 MR. SIMS:

Yes. Sometimes I do it afterwards.

465 MR. HARMON:

If you do it afterwards, then you can start from sampling to typing in a shorter period of time?

466 MR. SIMS:

Yes, because it's one step that you do later. So you could have a typeable--you could have a typing result and then just do that later.

467 MR. HARMON:

And is that sound scientific practice to do it afterwards just as it is to do it before?

468 MR. SIMS:

I have no problem with that.

469 MR. HARMON:

Okay. And you believe--I believe in the sequence, you also did a slot blot, did you?

470 MR. SIMS:

Yes. I believe it was a slot blot was run on these samples, yes, and that was by Renee Montgomery.

471 MR. HARMON:

And how much time does a slot blot contribute to this entire seven-day period?

472 MR. SIMS:

Well, overall, that would probably add about a day's worth of work to this because there was the preparation of the slot blot. Then it's got to be hybed. Then you do the actual test. Then there was the documentation of it. For example, Dr. Blake would come over and review all of our results. So we would spend time putting--figuring out what the quantities were and then we'd review all that stuff. So that takes a lot of time.

473 MR. HARMON:

So is there any way to compare how long you took in that seven-day process with someone else who's trying to exonerate or implicate someone else in short order?

474 MR. SIMS:

I don't think it's a fair comparison.

475 MR. HARMON:

Let's talk about the EAP marker specifically as it relates to the fingernail scrapings.

476 MR. SIMS:

Okay.

477 MR. HARMON:

Okay? On direct examination, you briefly referred to scientific literature about the EAP system. Could you just briefly summarize general concerns about the EAP system?

478 MR. SIMS:

Yes. Briefly this is--

479 THE COURT:

Counsel, haven't we been through this with this witness on direct and with Mr. Matheson? I mean the jury has heard the concerns about EAP.

480 MR. HARMON:

I've got a few questions. Mr. Scheck went into it on cross, your Honor.

481 THE COURT:

I understand that. But I'm saying I don't think the foundation is necessarily required at this point. The jury has already heard this discussed three times before.

482 MR. HARMON:

I'm sorry, your Honor.

483 THE COURT:

That's the point I'm trying to make.

484 MR. HARMON:

You've reviewed Mr. Matheson's notes and you've reviewed his electrophoretogram marked as People's 273 for identification; have you not?

485 MR. SIMS:

Yes, I have.

486 MR. HARMON:

Okay. And you're aware of the number of samples that are on there?

487 MR. SIMS:

Yes, I am.

488 MR. HARMON:

Could you from left to right read the number of evidence samples that are on that electrophoretogram?

489 MR. SIMS:

80--

490 MR. SCHECK:

Objection. Hearsay.

491 THE COURT:

Overruled.

492 MR. SIMS:

84A, 84B, 85A, 85B, 115, 116 and 117.

493 MR. HARMON:

Okay. And reviewing 84A and B, which purport to be from the fingernail scrapings of Nicole Brown taken at the--during the autopsy process, how would you report the EAP type for 84A and B?

494 MR. SCHECK:

Objection. Beyond the scope of cross-examination. I asked about degradation matters.

495 THE COURT:

Overruled.

496 MR. SIMS:

Well, I mean this is--this is somewhat difficult because obviously I'm not the one that read the original plate. But I think if you look at this particular set of results, you do see that some of these samples have their a bands starting to fade away. I can--I can see consistency in that. And I also note that in that critical area of the plate on the left side where 84A and B are, there is some distortion in the gel. And I don't--I don't think you can definitely say that that's a B result. That would be my conclusion.

497 MR. HARMON:

What would you say?

498 MR. SIMS:

Well, I recognize that there are the bands--I see some bands there that you could say, you know, may be attributable to a B. In other words, it's not an a, for example. There's no doubt in my mind that it's not an a result. But I don't think you can absolutely say that that's a B either.

499 MR. HARMON:

Okay. Would you look at 117?

500 MR. SIMS:

Okay.

501 MR. HARMON:

What's that look like?

502 MR. SCHECK:

Objection. Beyond the scope of cross.

503 THE COURT:

Sustained.

504 MR. HARMON:

May we approach on that, your Honor?

505 THE COURT:

117 was not an issue discussed. Proceed.

506 MR. HARMON:

May we approach, your Honor?

507 THE COURT:

No. Proceed.

508 (Discussion held off the record between the Deputy District Attorneys.)
509 MR. HARMON:

Is 115 and 116 also on that electrophoretogram?

510 MR. SIMS:

Yes.

511 MR. HARMON:

Would you exclude Nicole Brown as the source of the blood under her nails now that you've explained to the jury what you think 84A and B look like, if you assume that she was an EAP type BA?

512 MR. SIMS:

Well, it's--I'm not looking at this result just in that vacuum of the particular gel. I mean, I'm taking into account the information that we derived from the PCR results and I'm also taking into account my understanding that there was no indication of any tissue as found on the sample. So from that--those to me are powerful pieces of information because it indicates that this is not just some isolated sample, but this would be part of that entire mix that was looked at by the PCR testing, which included Nicole Brown. And so I would not use this to exclude her.

513 MR. HARMON:

Okay. And I believe your description of what you see, you see some possible a bands there. Is that consistent with the scientific--the primary scientific literature that Mr. Scheck referred to on cross-examination?

514 MR. SCHECK:

Objection. Leading.

515 THE COURT:

Sustained. Rephrase the question.

516 MR. HARMON:

Are your observations about seeing something in the a band area consistent with the main stream scientific literature on the subject?

517 MR. SCHECK:

Objection. Vague, objection, as to where.

518 THE COURT:

Overruled.

519 MR. SIMS:

Well, my concern was that that key area where the most stable a band is is not really--

520 THE COURT:

Excuse me, Mr. Sims. The question was, is that consistent with what you have seen in the scientific literature on the subject? Yes or no?

521 MR. SIMS:

I'm sorry. Is what consist--

522 THE COURT:

Rephrase the question, counsel.

523 MR. HARMON:

Okay. You've described--you've told the jury that you would not describe that as a B. You've told the jury that you see something in the a band area. Knowing the degradation process of an EAP type BA, in seeing what you see in the a band area, is your observation consistent with a BA degrading to a B based on the main stream scientific literature on that point?

524 MR. SCHECK:

Objection. Vague as to that question, your Honor.

525 THE COURT:

Overruled.

526 MR. SIMS:

Well, my concern--I think that misstates what I said somewhat about seeing some a bands there. My concern is that critical area is not where the a band would be, one of the key a bands would be is not that clear from this particular result. So that--and that is consistent with the scientific literature, that one of those a bands is more stable than the other.

527 MR. HARMON:

Okay. I would like to talk about--

528 MR. HARMON:

What time are we going to break, your Honor?

529 THE COURT:

3:30.

530 MR. HARMON:

3:30. Okay.

531 THE COURT:

3:30.

532 MR. HARMON:

I'd like to talk about Dr. Blake and his presence in your lab a little bit more. Mr. Scheck elicited from you that you frequently change gloves between samples in this case. Do you remember that last week?

533 MR. SIMS:

Yes.

534 MR. HARMON:

Did Mr. Blake's involvement in this case have some impact on your changing gloves between samples?

535 MR. SIMS:

Yes, it did.

536 MR. HARMON:

Could you explain at each point in the process why Mr. Blake's involvement caused you to change gloves in this case between samples?

537 MR. SIMS:

Yes. When we were processing the samples, the--one of the activities I mentioned was weighing of the swatches. So that meant that for each one of these, I had to go one at a time around different areas of the laboratory. And I was particularly concerned about having handled doorknobs and touching different things as far as what that may potentially be on my gloves. So I would contrast that with the situation where you're just working with clean tools, then it's unlikely that you would get any contamination on your gloves, where you're just working in one area. And it was because of the request for the weighing of the swatching that that would--would necessitate or would make me want to be more concerned about how those--about the changing of gloves.

538 MR. HARMON:

So would you actually--with each sample that was taken, would you then go take it and be weighed and photographed individually?

539 MR. SIMS:

Yes. It would be taken to another room for photography and then taken to another room for weighing and then brought back into the main laboratory area where I was working.

540 MR. HARMON:

And is that why you changed gloves between samples?

541 MR. SIMS:

Well, that was one of the key concerns in my case because I was handling a lot of different surfaces at that point.

542 MR. HARMON:

Okay. Now, so it's not your practice then to routinely change gloves between every sample that you're processing in a case, in a normal case?

543 MR. SIMS:

That's correct.

544 MR. HARMON:

Okay. And is your practice consistent with the amplitype PCR, DQ-Alpha user guide?

545 MR. SIMS:

Yes, it is.

546 MR. HARMON:

In that regard, do you change gloves frequently to avoid sample-to-sample contamination?

547 MR. SIMS:

Yes.

548 MR. HARMON:

And do you change them whenever they might have been contaminated with DNA and whenever exiting the work area?

549 MR. SIMS:

Yes. Whenever for--whenever I would think that I may have contaminated my gloves, I would immediately take them off.

550 MR. HARMON:

Do you recognize that language from section 2.2.2 of the user guide?

551 MR. SIMS:

Yes, I'm familiar with that.

552 MR. HARMON:

Is it that hard to do?

553 MR. SIMS:

No.

554 MR. HARMON:

Have you ever had Dr. Blake take photos of you in a case before?

555 MR. SIMS:

We've--we've been involved in several cases over the years. I--I can't recall one where he took photos of me, you know, as opposed to photos of the evidence.

556 MR. HARMON:

Okay. Did your examination of the glove, no. 9, from Rockingham take a long time in this case?

557 MR. SIMS:

Yes, it did.

558 MR. HARMON:

Do you recall how long it took?

559 MR. SIMS:

I think that was on a--that was on a Sunday as I recall.

560 (Brief pause.)
561 MR. SIMS:

Actually it was a weekend. It was a good part of a weekend was spent on that glove initially, and then there was additional examination in I believe in November of the glove.

562 MR. HARMON:

And did you engage in the documentation practice that you've described where you took photos and weighed things and have Dr. Blake take his own photos?

563 MR. SIMS:

Well, in that case now, we didn't weigh anything from the glove. But there was the kind of documentation that you mentioned.

564 MR. HARMON:

Why were those samples not weighed?

565 MR. SIMS:

We were not asked to do that by the Defense.

566 MR. HARMON:

Who actually--how did that come about, that you weighed samples for the first time in this case?

567 MR. SIMS:

Dr. Blake told me that he, that the Defense wanted--

568 MR. SCHECK:

Your Honor, I have no idea what he's going to say next, but we would stipulate we asked to weigh the samples.

569 THE COURT:

All right. Pursuant to a Defense request?

570 MR. SIMS:

Yes. Pursuant to a Defense request.

571 MR. HARMON:

Okay. Let's talk about the glove exam just for a moment while we're talking about the glove. Why did you look in the notch area?

572 MR. SIMS:

Yes. This was--this was after looking over a lot of--

573 MR. SCHECK:

Outside the scope of cross-examination.

574 THE COURT:

Overruled.

575 MR. SIMS:

Well, the way this came about was, I started thinking about how someone with a bloody finger might want to take a glove off and use that notch to do it.

576 MR. SCHECK:

Move to strike as speculation.

577 THE COURT:

Sustained.

578 MR. HARMON:

What drew your attention to the notch on the glove?

579 MR. SIMS:

There was a small amount of stain down in that area.

580 MR. HARMON:

And had you already sampled the blood in other areas?

581 MR. SIMS:

Yes, I had.

582 MR. HARMON:

Had you done testing in those other areas?

583 MR. SIMS:

Well, I hadn't--I didn't have any results at that point. I had just taken samples from other areas.

584 MR. HARMON:

Okay. And then you mentioned there was some small stains in that area?

585 MR. SIMS:

Yes. There was a small stain in particular that caught my eye.

586 MR. HARMON:

And where was that?

587 MR. SIMS:

That was down by that notch.

588 MR. HARMON:

And why was that of significance to you?

589 MR. SCHECK:

Objection, form of the question.

590 THE COURT:

Overruled.

591 MR. SIMS:

Well, there were a lot of stains on that glove to look at, but I--I--again, that's why I looked in that particular area, was because I thought there may be some significance to one taking a glove off and using the notch to do that.

592 MR. SCHECK:

Move to strike.

593 THE COURT:

Overruled.

594 MR. HARMON:

Could we get the glove photo board and the glove result board up there? Put the result board up--272-A and B. Put the result board up first, please.

595 (Brief pause.)
596 THE COURT:

Continue, counsel.

597 MR. HARMON:

Okay. Mr. Sims, could you show us the--

598 (Brief pause.)
599 (Discussion held off the record between the Deputy District Attorney and Defense counsel.)
600 MR. HARMON:

I think you've described your attention being drawn to the notch. What drew your attention or what stains are we talking about that drew your attention to the notch area of the glove from Rockingham no. 9?

601 MR. SIMS:

Well, on this--this again would be from my notes on page 71. I noted an area on the inner surface with the notch that showed what I said was macro interest. And that means that I saw there was some of that blood, small amount of blood staining down in that G10 area. And I also noted what I thought was--and then I looked at it under the stereomicroscope, and I thought it looked like a possible piece of tissue in that area.

602 MR. HARMON:

Okay. And why was that of interest to you?

603 MR. SIMS:

Well--

604 MR. SCHECK:

Objection. Calls for speculation.

605 THE COURT:

Overruled.

606 MR. SIMS:

Well, because tissue is normally something that's produced by, for example, a fairly deep--a wound as opposed to just blood by itself.

607 MR. HARMON:

And why was the notch area of interest to you?

608 MR. SIMS:

Well, again, from my--I guess this is my training and just common sense and all that goes into it, but I started thinking about where blood--

609 THE COURT:

Counsel, I think we've asked this question now four times.

610 MR. HARMON:

I'm not sure we got an answer.

611 THE COURT:

Yes, we did. We got an answer.

612 MR. HARMON:

Mr. Sims--

613 THE COURT:

You also have to trust the common sense of the jurors about how one takes gloves off and how one puts them on.

614 MR. HARMON:

Okay. Mr. Sims, just to kind of summarize here where we are with the glove, could you show the jury where the stains are located that are consistent with Mr. Sims as one of the contributors? Would you--I mean Mr. Simpson. Mr. Simpson. Well, we don't know his type, you know.

615 THE COURT:

All right.

616 MR. SCHECK:

Well--

617 MR. HARMON:

Could you show us where they are on the photo board?

618 MR. SIMS:

On the--

619 MR. HARMON:

On the photo board.

620 MR. SIMS:

Oh, I'm sorry. I couldn't see it from here.

621 MR. HARMON:

Oh, I'm sorry.

622 THE COURT:

We may have to move that over here so all the jurors can see what you are talking about because it's pretty subtle what's there. And if you could, Mr. Fairtlough, could you move that up so 1492 and 165 aren't blocked by the podium? All right. Mr. Harmon.

623 MR. HARMON:

Mr. Sims, could you just point out the three different areas that you found a mixture consistent with Mr. Simpson on the glove?

624 MR. SIMS:

Okay. Again, I just want to review, make sure I've got those numbers correct. Yes. It's 10 up here. This is the one I was talking about. It's near the notch. It's actually down a little bit closer than the red shows, but there's a stain down in this area (Indicating). This was--9 was where I thought I saw the possible tissue and then 11 is on the outside of the glove to the side of the notch there down towards the wrist area and then 13 was along the actual stitching of that notch.

625 MR. HARMON:

Okay. Now, while you're there--and I've got some photos if you need to have your recollection refreshed. But of those three stains that had 25 allele which could have been contributed by Mr. Simpson, but not Mr. Goldman, not Miss Brown, were any of those close to cut-out areas that were on that glove when you first saw it?

626 MR. SIMS:

I did--the only--the only one that at all comes to mind to me would be this cut-out here (Indicating) is somewhat close to g--

627 MR. HARMON:

You pointed to it. Could you relay it to one of the other markings on the board?

628 MR. SIMS:

Yes. The mark--the cut-out here near G14. In other words, G14 is down in this area (Indicating). There's a cut-out above it that somewhat opposes it now. When it's right side out, it would somewhat impose this area on G10.

629 MR. HARMON:

And the other two stains that had the 25 allele were not close to any areas that appeared to have been cut out?

630 MR. SIMS:

I wouldn't describe them as being close.

631 MR. HARMON:

Okay. Could you just tell the jury, when I say areas that were cut out, tell us what the glove looked like when you got it?

632 MR. SIMS:

Well, when I got it, it was--it appeared to me that cut-outs had been made from the different areas, some of the different areas along the glove. In other words, I didn't know exactly who cut them out, but it appeared that there were some sort of squarish cut-outs made in different areas of the glove.

633 MR. HARMON:

And were those consistent with having been sampled by a forensic scientist?

634 MR. SIMS:

That's typical of what I would expect to see.

635 MR. HARMON:

Okay. Thank you. I have no further questions. We can take a break.

636 THE COURT:

All right.

637 MR. HARMON:

I have more questions, but not before the break.

638 THE COURT:

No, no. Ladies and gentlemen, we're going to take a 15-minute recess. Please remember my admonitions to you; don't discuss the case amongst yourselves, form any opinions about the case, conduct any deliberations or allow anybody to communicate with you. And we'll be in recess for 15.

Temperature

tense

Key Quotes (5)

Gary Sims
When hypotheticals are created, certainly you get to a point where you can say anything is possible, and anything is possible.
Sims explains to the jury why he said 'possible' so often on cross — defusing Scheck's strategy of accumulating 'possible' concessions to suggest doubt.
Gary Sims
That's why I think it's important to look at all the data. All the different markers and all the results.
Core rebuttal to Scheck's approach of isolating single markers; Sims reframes the proper analytical methodology.
Gary Sims
By no means. In fact...I think what that would represent was about the slowest it could ever take to do that series of tests.
Directly inverts Scheck's implication that the seven-day processing timeline showed rushed or careless work — Sims says it was the opposite, slowed by Blake's documentation presence.
Gary Sims
I've been involved in a case not too long ago where it was inferred that the way I was cleaning my tools was insufficient. And so what I decided to do was to say, okay, let's remove that argument. Let's just burn these things.
Explains why he flames his tools — not because it's required protocol, but as prophylactic litigation defense. Reveals how legal pressure shapes lab practice.
Gary Sims
I don't think you can definitely say that that's a B result. That would be my conclusion.
Sims reviewing Matheson's electrophoretogram casts doubt on the EAP-B typing of Nicole Brown's fingernail scrapings — suggesting the defense's interpretation was overstated.

Evidence (6)

Defense 1166
Dot blot photo of DQ-Alpha strips — Dr. Blake's photograph, with handwriting by Renee Montgomery
Reviewed strip by strip with substrate controls; Sims confirms confidence in all calls despite cross-examination
Defense 1168
Second dot blot photo with Dr. Blake's handwriting, includes item 52 (Bundy driveway drop) and substrate controls for Bundy drops
Discussed at length; Sims maintains 1.3 allele is artifact; Cellmark RFLP/DQ-Alpha corroborate
People's 274
Photograph of rehybridization strips including DNA 55A (LAPD item 52), sock stains 41B1 and 41B2, and controls
Newly introduced on redirect; confirms Sims's original 1.1, 1.2 call on item 52
People's 273
Electrophoretogram from Greg Matheson's EAP testing of fingernail scrapings (items 84A, 84B, 85A, 85B, 115, 116, 117)
Sims reviews and concludes 84A and 84B cannot definitively be called EAP type B due to gel distortion
Informal
Scheck's handwritten chart showing 37 possible DQ-Alpha combinations for Bronco console stain item 303 (LAPD), based only on DQ-Alpha marker
Challenged — Harmon elicits that it excludes D1S80 data and that only 2 of 37 combinations matched the victims
Informal
Bronco Bundy board (People's exhibit 259) and Bundy/Bronco item reference board
Used as reference while walking through item numbers and stain locations

Notable Exchanges (5)

Rockne HarmonBarry ScheckLance A. Ito
Harmon attempts multiple phrasings of a question about what Scheck's frequency chart means in light of Sims's reservations about item 29 (steering wheel). Sustained four consecutive times as vague or argumentative. Judge Ito ultimately asks Sims the question himself directly, getting Sims to articulate his concern about the 1.3 allele assumption.
procedural frustration
Rockne HarmonBarry Scheck
Harmon asks three consecutive times whether '35 other deceased/dead/living people' had their blood in the Bronco console stain — each version sustained. Ito ultimately rephrases it neutrally as '35 other persons who may have contributed with different genotypes.'
strategic / argumentative
Rockne HarmonGary Sims
Sims explains that the seven-day processing period was unusually slow because Dr. Blake's presence required double-documentation and double-photography at every step, plus Sims introduced unprecedented sample weighing at defense request.
revealing
Rockne HarmonGary Sims
Discussion of why Sims flames his tools — not protocol, but learned from a prior case where his cleaning method was challenged. Frames extra precautions as litigation-driven rather than scientifically required.
candid
Barry ScheckLance A. Ito
Scheck attempts to approach the bench on a '1054 matter' while Sims checks his notes. Ito flatly refuses twice. Scheck also tries to move to strike a question, prompting Ito to note: 'Motion to strike the question is not appropriate in California, counsel.'
tense / procedural rebuke

Light Moments (3)

Rockne Harmon
Harmon asks: 'Is there something funny about broncos that might cause nosebleeds like that?' — immediately sustained before Scheck can even finish objecting.
Gary Sims
Sims, after Harmon asks if he has the rehybridization photo: 'I do have it. No. I'm sorry. This is not it. This is a different photo.' Harmon then says 'I have it.'
Gary Sims
When Sims gets confused switching between DOJ item numbers and LAPD numbers, Harmon gently asks him to convert — Sims apologizes and rattles off a long list of LAPD item numbers.

Credibility Attacks (2)

⚔ Gary Sims
scope challenge / methodology challenge
Scheck's cross-examination strategy (rehabilitated here) involved isolating single markers, focusing on the 1.3 artifact question, and presenting frequency charts based on incomplete data. Harmon's redirect establishes that each of these ignored corroborating data from other markers and other labs.
⚔ Greg Matheson
re-reading of results by competing expert
Sims reviews Matheson's EAP electrophoretogram and declines to call item 84A/84B definitively a B type, suggesting gel distortion makes the reading unreliable — implicitly questioning the defense's reliance on a B typing to exclude Nicole Brown.

Witness Demeanor

Methodical and careful; frequently asks for questions to be rephrased before answering
Checks notes multiple times when asked about specific dates, items, and photography sequences
Candid about tough calls and uncertainty (1.3 artifact, EAP 84A/B), without retreating from core conclusions
Slightly flustered when searching for the rehybridization photograph before Harmon locates it

Objections

45 objections (22 sustained, 18 overruled)
Proceeding 6128 • 638 utterances • Prosecution witness
Criminal Trial
Department 103
⚖️ Start
📂 MAY 22, 1995 📄 Redirect examination of Gary S
MAY 22, 1995 KRT DvH TD