📄 Cross-examination of Renee Montgomery (part 3) — Tuesday, May 23, 1995
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C:\DEPT103\CRIMINAL\1995\MAY\23\CROSS-EXAMINATION-OF-RENEE-MON.DOC
TRIAL
▲ Day 80 of 167

Cross-examination of Renee Montgomery (part 3)

Witness: Renee Montgomery
Examiner: Robert Blasier
Called by: Prosecution • Date: Tuesday, May 23, 1995 • Utterances: 542
Defense attorney Robert Blasier cross-examined DOJ criminalist Renee Montgomery on the reliability of her DQ-Alpha and D1S80 DNA testing in the Simpson case. Blasier methodically documented a series of technical problems — failed amplification of OJ's reference sample, gel distortions on the Rockingham glove run, control band intensity discrepancies — and elicited Montgomery's admission that these issues were 'not typical' for the D1S80 system. A critical concession came when Montgomery confirmed that OJ Simpson is excluded as a contributor from all 23 stains tested on the victims' clothing.
1 THE COURT:

All right. Thank you, counsel.

2 MR. BLASIER:

Miss Montgomery, let me show you two pages of discovery, page 803, and ask if you recognize these as work sheets on a proficiency test that you did.

3 MS. MONTGOMERY:

Yes, I do.

4 MR. BLASIER:

And those are--that's just one proficiency test, is it not, that's--that was rehybridized twice or a second time?

5 MS. MONTGOMERY:

Yes. This is one proficiency test.

6 MR. BLASIER:

So you're testing the same samples in both, both of those work sheets?

7 MS. MONTGOMERY:

Correct.

8 MR. BLASIER:

But you're doing a different hybridization? Those represent two different hybridizations?

9 MS. MONTGOMERY:

Yes. And there are some different samples.

10 MR. BLASIER:

Okay.

11 MR. BLASIER:

Your Honor, I would like to have these marked.

12 THE COURT:

Mrs. Robertson. 1172.

13 MR. BLASIER:

1172-A and B or--

14 THE COURT:

Yeah. A and B.

15 (Deft's 1172-A and B for id = work sheets)
16 MR. BLASIER:

I would like to put 1172-A on the elmo first.

17 (Brief pause.)
18 MR. BLASIER:

Miss Montgomery, the two pages I showed you, one was numbered page 6 of 9 and the other was page 8 of 9. Do you recall that?

19 MS. MONTGOMERY:

I'd have to look at it again.

20 MR. BLASIER:

And I want you to tell me which one of these you did first.

21 MS. MONTGOMERY:

Well, actually, that's not my writing at the top of the page. My writing's at the bottom and I can not tell the whole--it hasn't been Xeroxed completely.

22 MR. BLASIER:

Can you tell from your own notes?

23 MS. MONTGOMERY:

Well, this is a proficiency. This isn't something that I brought to court with me today.

24 MR. BLASIER:

Okay.

25 MS. MONTGOMERY:

But it appears that one says 14 of 22 and the other says 19 of and there's a 2. So--if I could see the original documents or a better copy, that would be even better. But just by looking at it, it appears that the 14 of 22, the other one's trying to say 19 of 22 maybe.

26 MR. BLASIER:

Let me show you the rest of the document that those pages came from and see if that helps you.

27 MS. MONTGOMERY:

Yeah. It--it appears that this is--this second page is probably part of the same document. It has the same proficiency number and also has a date two days later. So this is the first one that has a date of the 18th of October and the second one would be the 20th of October.

28 MR. BLASIER:

All right. For the record, she's referring to 1172-A as the first one and 1172-B as the second one.

29 THE COURT:

Thank you.

30 MR. BLASIER:

Let's look at 1172-A. Let me give you the rest of this packet in case you need to refer to it.

31 MS. MONTGOMERY:

And do you also have the original or a copy of the photos that go with these?

32 MR. BLASIER:

I don't believe we do. Now, this is the work sheet--what we have up on the elmo is the work sheet that describes what results you saw after you performed the test, correct?

33 MS. MONTGOMERY:

Yeah. This multi media, I can't decide what to look at.

34 MR. BLASIER:

Whatever's easiest.

35 MS. MONTGOMERY:

The clarity is not very good on this. So maybe if I came down there, it would be easier for me to see.

36 MR. BLASIER:

Sure.

37 MS. MONTGOMERY:

Okay.

38 MR. BLASIER:

Can we pull it in a little bit to the 432-51? Right there. That's good.

39 MR. BLASIER:

432-51, that line refers to one of the samples that was provided in the proficiency test, correct?

40 MS. MONTGOMERY:

Actually that's dash S. That's an S.

41 MR. BLASIER:

Okay. And that's one of the samples you were supposed to type and get a result, correct?

42 MS. MONTGOMERY:

Correct.

43 MR. BLASIER:

And QC839 in the middle of the screen there toward the bottom, what's that?

44 MS. MONTGOMERY:

That's a quality control. What would be more helpful is if I had the whole file on this. It's difficult just to take this all out of context to actually see what the notes are prior to the samples being written on here because a lot of times, what you want to do--when you talk about sample, you can't write everything that pertains to that particular sample. So you write a certain section in that sample, and then in your actual--the body of your notes, you write a little more description.

45 MR. BLASIER:

What you write in the little boxes there is what you see on the dots. Or I'm sorry--

46 MS. MONTGOMERY:

I'm sorry. I'm talking about--

47 MR. BLASIER:

I'm sorry.

48 MS. MONTGOMERY:

I'm talking about the sample lane.

49 MR. BLASIER:

Okay. Now, this is actually a DQ-Alpha proficiency test, correct?

50 MS. MONTGOMERY:

Correct.

51 MR. BLASIER:

And what you write in the boxes there is what you see on the dots, correct?

52 MS. MONTGOMERY:

Correct. Now, you're over to the dots.

53 MR. BLASIER:

Yeah. On QC839, do you see where it says there's a hint of a 1.3?

54 MS. MONTGOMERY:

Yes, I see that.

55 MR. BLASIER:

That's not the correct result for QC839, is it?

56 MS. MONTGOMERY:

No. That must be the correct result because this goes through approval. We have this approval process where, first of all, a second reader reads the strips and then the results are given to a supervisor to review the whole case, and the QCs are unknown to us and the supervisor reviews the results of your QC. And if you--and they check to make sure those QCs are giving the proper results. If the QC doesn't give the proper results, then something needs to be done.

57 MR. BLASIER:

The box under "Type," that's the type of that quality control sample; is it not?

58 MS. MONTGOMERY:

Correct.

59 MR. BLASIER:

And that's indicated as a 1.1, 3, correct?

60 MS. MONTGOMERY:

Right.

61 MR. BLASIER:

Nothing in there about a 1.3, is there?

62 MS. MONTGOMERY:

Oh, no, because that's a hint. It's--

63 MR. BLASIER:

What's the diff--what's a hint?

64 MS. MONTGOMERY:

A hint is just an indication of some--I believe Gary Sims talked to you yesterday or the day--or a couple days ago about this. When you look at the DQ-Alpha strips where there are a series of the dots and next to the 1.3 in this case, if I document--if I wrote that that's a hint, then there was some outline or a hint of some activity seen at that dot. But it was significantly less than the C dot. So it was--it had to be documented, but it wasn't significant to the analysis. When--in our laboratories, things need to be C or greater before they're actually called.

65 MR. BLASIER:

If this were a mixture, however, you interpret mixtures where you have dots less than the C dots as being alleles, don't you?

66 MS. MONTGOMERY:

Dots less than the C dot?

67 MR. BLASIER:

Yes.

68 MS. MONTGOMERY:

If you see a C dot, then that would--you do report that out. As far as a C minus or a trace or a hint, you note it, but as far as any interpretation, one needs to be cautious about interpretation on that.

69 MR. BLASIER:

You're not supposed to see anything at the 1.3 dot with a quality control sample that's a 1.1, 3, are you?

70 MR. HARMON:

Objection. That's argumentative, your Honor.

71 THE COURT:

Sustained. Rephrase the question.

72 MR. BLASIER:

Are you supposed to see anything in the 1.3 dot with the quality control sample that it's a 1.1 and a 3?

73 MS. MONTGOMERY:

Well, if you--you shouldn't see a substantial amount of activity at that 1.3 if that's truly--if that is a 1.1, 3. It's one of the limitations of the system; at the 1.3, you could get cross-hybridization. And this is where sequence that's complimentary or to the 1.3 will actually cause some hybriding--or cause some of the 1.3 dot to show up. But this is just an artifact of the system and at such a low level, one wouldn't even interpret that result.

74 MR. BLASIER:

So you can get 1.3 dots when there's nothing there?

75 MS. MONTGOMERY:

When there's--

76 MR. HARMON:

Objection. Vague as to "Dots," argumentative.

77 MR. BLASIER:

When there's--

78 MR. BLASIER:

Let me rephrase it.

79 THE COURT:

Overruled.

80 MR. BLASIER:

You can get a 1.3 dot when there's no DNA there?

81 MS. MONTGOMERY:

It's not a dot that would be interpretable. As I stated, that's--that's a hint. It's not a C dot. The intensity is substantially less than that C, the C dot.

82 MR. BLASIER:

What's the difference between a hint and a trace?

83 MS. MONTGOMERY:

We have a--in our laboratory, we have a scale of progression on how to call these dots. An outline hint means there's a--you can see something on the strip, but it's just a small amount. A trace is a little more and then there's a C minus and then a C and then a C plus.

84 MR. BLASIER:

What's a trace? Is a trace an indication of some DNA there?

85 MS. MONTGOMERY:

A trace is a little more than a hint, but once again, it's not significant for the analysis. It just happens to be an artifact or a limitation of the sys--or not a limitation. An artifact of the system. A trace would not be interpreted in the results.

86 MR. BLASIER:

What's the difference between a system that gives you artifacts and a system that has limitations that gives you an artifact?

87 MR. HARMON:

Objection. That's argumentative, compound.

88 THE COURT:

Overruled.

89 MR. BLASIER:

Now, you indicated it wasn't a limitation of the system?

90 MS. MONTGOMERY:

Right.

91 MR. BLASIER:

Whose fault is it that you get dots at 1.3 when there's no DNA there?

92 MR. HARMON:

Objection. That's argumentative.

93 THE COURT:

Sustained. Rephrase the question.

94 MR. BLASIER:

Are the 1.3 dots caused by limitations in the system or something else?

95 MS. MONTGOMERY:

Well, it's caused by a little of both. And what happens--you know, these are not significant dots. They're hints and traces. They aren't--they would not be counted in your interpretation. But what happens is, if a--with slight variations in the typing, some trace amounts of 1.3 activity can be seen on the strips. And it's--I guess one could say it's a limitation as Mr. Blasier says, but also it's an artifact of the system. And if it was something--these dots are so faint and so weak that, you know, as I have said, it just wouldn't be counted in your interpretation.

96 MR. BLASIER:

It could also be a minor component of a mixture that has a 1.3 and a small quantity in it, couldn't it?

97 MS. MONTGOMERY:

It could be, but it wouldn't be interpreted at that level.

98 MR. BLASIER:

And is there some sort of uniform scale within the forensic community by which you determine the difference between a hint and a trace?

99 MS. MONTGOMERY:

No.

100 MR. BLASIER:

Does it have anything to do with the results that you expect to get out of a test as to whether you're going to call it a hint or a trace or a C minus?

101 MR. HARMON:

Objection. That's argumentative.

102 THE COURT:

Overruled.

103 MS. MONTGOMERY:

No.

104 MR. BLASIER:

Now, the positive control, the lane second from the bottom, that was supposed to be a 1.1, 4, correct? That's what the type was that was put in that lane, correct?

105 MS. MONTGOMERY:

That is a 1.1, 4.

106 MR. BLASIER:

Now, you got a trace of a 1.3 in that lane, correct?

107 MS. MONTGOMERY:

Correct.

108 MR. BLASIER:

And that's more than the hint in the quality control sample?

109 MS. MONTGOMERY:

Yes, it is. As I said, on our scale of progression, a trace is slightly greater than a hint.

110 MR. BLASIER:

Now, are you supposed to get these kinds of traces and hints when you perform tests? Are they expected?

111 MS. MONTGOMERY:

No, they're not.

112 MR. BLASIER:

So this is an unexpected result; is it not?

113 MS. MONTGOMERY:

This is something that you--it's not unexpected. I think "Unexpected" is a bad word to use with it. It's something--as I said, it's just an artifact of the system, and by doing reanalysis, you could probably get rid of those hints and traces.

114 MR. BLASIER:

Okay. Let's talk about the reanalysis which is the page 2, correct?

115 MS. MONTGOMERY:

Correct.

116 MR. BLASIER:

This is 1172-B. Now, you did this one again, the one we just looked at, and the sheet that's on the elmo is the results of the second run or second hybridization on the same samples; is that correct?

117 MS. MONTGOMERY:

Yes. Some of the samples are the same.

118 MR. BLASIER:

Why did you run it the second time?

119 MS. MONTGOMERY:

I'd have to see the notes to know why.

120 MR. BLASIER:

Is there anything in that packet there that tells you?

121 MS. MONTGOMERY:

No.

122 MR. BLASIER:

Well, what--ordinarily, what would be your reason for running a proficiency test a second time?

123 MS. MONTGOMERY:

There could be various reasons. I think I'd need to see the actual--my actual notes to be able to explain why I reran this a second time.

124 MR. BLASIER:

Would one reason be the hints and the traces that you got the first time?

125 MR. HARMON:

Objection. Calls for speculation.

126 THE COURT:

Sustained.

127 MR. BLASIER:

If the results that you got on the first one were totally as expected, would you have any reason to run it a second time?

128 MR. HARMON:

Objection. Calls for speculation.

129 THE COURT:

Overruled.

130 MS. MONTGOMERY:

Well, that's possible. You know, I would--I would need to see the actual--to speculate on this or it's best not to speculate. It's best to actually see my notes in this particular instance.

131 MR. BLASIER:

Okay. Now, these are your notes with respect to how you read the strips, correct?

132 MS. MONTGOMERY:

Right.

133 MR. BLASIER:

Now, let's look at 432S1, the top lane. That's the first one. Now, would you agree that you found that there was a hint at 1.3 and a hint at 1.1 that was unexpected?

134 MS. MONTGOMERY:

Once again, by saying "Unexpected," I think you're--you're putting more emphasis on it than you should. There was--I did notice hints in both of those samples. And once again, the hint is not significant to the results of that analysis.

135 MR. BLASIER:

So these are hints that show up now in the same sample that didn't show up the first time you did it, correct?

136 MS. MONTGOMERY:

Could you put the first one back up?

137 MR. BLASIER:

You've got the first one in your hand.

138 MS. MONTGOMERY:

Oh, you're right. Yes. Yes.

139 MR. BLASIER:

They did not show up the first time, did they?

140 MS. MONTGOMERY:

Correct.

141 MR. BLASIER:

Now, in 433S2, we've got a trace at 1.1 and a trace at 1.3 that don't conform to the genotype of the sample which is 1.2, 3, correct?

142 MS. MONTGOMERY:

Correct.

143 MR. BLASIER:

And that didn't show up the first time you did that sample, did it?

144 MS. MONTGOMERY:

That's correct.

145 MR. BLASIER:

434S3, we now have a trace at 1.1 that is not consistent with the type of that sample which is a 4, 4, correct?

146 MS. MONTGOMERY:

Right.

147 MR. BLASIER:

Now, quality control sample 839, we have two hints that are inconsistent with the genotype of that quality control, correct?

148 MS. MONTGOMERY:

Well, no. They're not inconsistent with the genotype of that quality control. I have to keep emphasizing that a hint is not significant. A hint is just noting that something--you're seeing a little darkening in the dot and it's not significant to your interpretation. The results of that QC are 1.1, 3 and those were the correct results.

149 MR. BLASIER:

Isn't one of the tests of whether a system like this is a reliable system, whether or not if you do the same samples two times, you're supposed to get the same results, aren't you?

150 MS. MONTGOMERY:

Yes. And as you can see in this case, the same results were obtained.

151 MR. BLASIER:

Okay. You can resume your seat.

152 (The witness complies.)
153 MR. BLASIER:

So is it fair to say that this one particular proficiency test that we've looked at is an example of one which has been scored in some fashion that you got the right answers?

154 MS. MONTGOMERY:

Yes. The right results were obtained from that proficiency.

155 MR. BLASIER:

Who grades these?

156 MS. MONTGOMERY:

Excuse me?

157 MR. BLASIER:

Who grades these?

158 MS. MONTGOMERY:

Grades them. The individuals review them. First of all, my--the--a supervisor in the laboratory would review the results, and then secondly, a--the outside agency that submitted the samples to us would review our results and then determine--send out a result whether we obtained the correct results or not.

159 MR. BLASIER:

Do you know what a laminar flow hood is?

160 MS. MONTGOMERY:

Yes, I do.

161 MR. BLASIER:

And do you use that--performing any kind of PCR amplification, the various steps that you perform in that test, do you do them within a laminar flow hood?

162 MS. MONTGOMERY:

Yes. I do the set-up of the amplification in a laminar flow hood.

163 MR. BLASIER:

Would you ever use a hood that is called a flume hood I believe that sucks air from the outside of the lab into the area of the hood and then out?

164 MR. HARMON:

Objection. Irrelevant.

165 THE COURT:

Sustained.

166 MR. BLASIER:

Laminar flow hood, is that something that's pretty standard in terms of your education as a criminalist that you're taught what that is and how to use it?

167 MR. HARMON:

Objection. It's irrelevant.

168 THE COURT:

Overruled.

169 MS. MONTGOMERY:

Well, it's--it's just a hood that has air flow and a window of air that separates the inside environment from the outside environment, and there's really not much training on it. You just turn the switch on to activate the hood.

170 MR. BLASIER:

But you're taught what a laminar flow hood is, aren't you?

171 MS. MONTGOMERY:

I don't recall being taught. It's just something that I'm aware of, something that I'm familiar with.

172 MR. BLASIER:

The kits that you use to perform DQ-Alpha and D1S80 tests require that you do them in a laminar flow hood, don't they?

173 MR. HARMON:

Objection. Vague as to "Require."

174 THE COURT:

Sustained. Rephrase the question.

175 MR. BLASIER:

The kits that you use that are provided by Roche that produces the kits state that various steps should be done in a laminar flow hood?

176 MR. HARMON:

Objection. That's still vague, "Various steps," your Honor.

177 THE COURT:

Overruled.

178 MS. MONTGOMERY:

I'm not quite sure. I don't recall seeing that in there. If you could show me the section.

179 MR. BLASIER:

I'll get that at the break. Have any of the proficiency tests that you've taken involved mixed bloodstains?

180 MS. MONTGOMERY:

No, I don't believe so.

181 MR. BLASIER:

Most of the or many of the stains that you looked at in this case, you--your test results indicated could be mixed stains, correct?

182 MS. MONTGOMERY:

Some of them, yes.

183 MR. BLASIER:

And so you've never undergone any kind of testing to see whether you're able to do mixed bloodstains accurately?

184 MS. MONTGOMERY:

No. That's incorrect.

185 MR. BLASIER:

What kind of testing have you undergone for that?

186 MS. MONTGOMERY:

I've--part of the validation process of the D1S80 marker, I looked at mixed--mixed samples, and these were both mixed--they're mixed DNA's. So not actually the mixed bloodstain together, but the DNA or an extraction process where the two DNA's were mixed together. And I looked at that during the validation process in use in our laboratory. And I believe that's the only--those are the mixed bloods that were examined. There are mixed samples that are examined also in the laboratory and this--sexual assault samples, you know, vaginal swabs where you'll have epithelial cells and then if there's sperm present also.

187 MR. BLASIER:

But there are no proficiency tests that you've taken that involve mixed samples of blood, are there?

188 MS. MONTGOMERY:

Well, you know, I was just looking at this as you were or as I was talking, and it's--one of the proficiencies I did was blood semen mix. And that was a cellmark proficiency. And so that's where some of the blood and semen was mixed together. It wasn't two bloodstains, but it was two different samples mixed together and one of them happened to be a bloodstain.

189 MR. BLASIER:

Without getting into any detail, sexual assault samples are different than mixed blood samples, aren't they?

190 MS. MONTGOMERY:

Right. But this--correct.

191 MR. BLASIER:

You have other methods that you can use, a differential lysis to split them apart, can't you?

192 MS. MONTGOMERY:

Correct.

193 MR. BLASIER:

But you can't do it with bloodstains?

194 MS. MONTGOMERY:

Right.

195 MR. BLASIER:

Incidentally, did you perform any kind of analysis on any of the stains that you looked at under the microscope to determine whether you could tell if there was a saliva component to any of these mixed stains?

196 MS. MONTGOMERY:

No. As I stated earlier, Mr. Sims looked at all the evidence initially and I did the D1S80 or DQ-Alpha analysis on the samples after he examined the samples.

197 MR. BLASIER:

So you have no way of determining whether any of the components of the mixtures you testified to are--have saliva contributions from a source as opposed to blood?

198 MS. MONTGOMERY:

Correct.

199 MR. BLASIER:

Now, I want to ask you some questions about the victims' clothing with respect to the D1S80 results. Do you have that in mind?

200 MS. MONTGOMERY:

Yes. I'll--I'll pull up the notes.

201 (Brief pause.)
202 MR. BLASIER:

Could we have slide--we need to have a number for slide presentation.

203 THE COURT:

All right. Next in order will be 1173. 1173.

204 (Deft's 1173-A through I for id = slides)
205 MR. BLASIER:

And could we have the fourth slide, which is d?

206 THE COURT:

Mrs. Robertson, 1173.

207 (Brief pause.)
208 MR. BLASIER:

Now could we have slide e?

209 MR. BLASIER:

Now, Miss Montgomery, you conducted tests on three items of clothing, correct?

210 MS. MONTGOMERY:

I conducted analysis on two items of clothing and Steve Myers in our laboratory examined Nicole Simpson's dress.

211 MR. BLASIER:

Okay. And the two items that you looked at were the shirt and the pants of Ronald Goldman?

212 MS. MONTGOMERY:

Correct.

213 MR. BLASIER:

And the dress was looked at by Steve Myers, that was Nicole Brown Simpson's dress?

214 MS. MONTGOMERY:

Actually the DNA was analyzed. The items were looked at by someone else.

215 MR. BLASIER:

Okay. And there were certain D1S80 results that came out of that analysis of those three items, correct?

216 MS. MONTGOMERY:

Correct.

217 MR. BLASIER:

Now, I've indicated on my chart up there that I've--I just color-coded it so it's a little easier to understand.

218 MR. BLASIER:

Could we have slide F.

219 MR. BLASIER:

Now, would you agree that from your results, yours and Steve Myers' results, there were six stains looked at on Nicole Brown Simpson's dress, three of which indicated a contribution by--possibly by Ronald Goldman?

220 MS. MONTGOMERY:

I'm referring to the report at this time.

221 MR. BLASIER:

Sure.

222 (Brief pause.)
223 MS. MONTGOMERY:

Yes. A total of six stains were examined and three of the stains had a weaker contribution of a 24 allele.

224 MR. BLASIER:

Now, could we have slide g, please.

225 MR. BLASIER:

Would you agree that there were nine stains examined from Ronald Goldman's jeans, five of which had an indication of an 18 allele which is consistent with Nicole Brown Simpson?

226 MS. MONTGOMERY:

Well, four of them had a weaker 18 allele. One of them had G6 from the left thigh area, had a possible trace 18. And that's what I had talked about earlier, where there was a darkening on the band, but it could not definitely be determined that it was a band.

227 MR. BLASIER:

Okay. And can we have slide H.

228 MR. BLASIER:

Would you agree that there were eight stains examined from Ronald Goldman's shirt and all eight of those stains showed an 18 allele consistent with Nicole Brown Simpson?

229 MS. MONTGOMERY:

That's correct.

230 MR. BLASIER:

Now, could we have slide I, please.

231 MR. BLASIER:

Now, to summarize, there were a total of 23 stains tested on these three items of clothing, correct?

232 MS. MONTGOMERY:

You added up the numbers that you--

233 MR. BLASIER:

Yes.

234 MS. MONTGOMERY:

Okay. Yes. I'll take your word for it.

235 MR. BLASIER:

I'm sorry. 16 of those stains--let's make that 15 since you said the one was just a trace--indicated mixtures containing possibly both victims?

236 MS. MONTGOMERY:

Correct.

237 MR. BLASIER:

Now, is it also accurate to say that of all of those 23 stains, O.J. Simpson is excluded?

KEY QUOTE
238 MS. MONTGOMERY:

That's correct.

239 MR. BLASIER:

Now, would you agree that--

240 MR. BLASIER:

Could we go back to slide h, please. That's okay.

241 MR. BLASIER:

Would you agree that this is a fairly--withdraw. The shirt that was tested, these were stains that were taken from all over the shirt, correct?

242 MS. MONTGOMERY:

I'll have to look at the notes.

243 MR. BLASIER:

Let me withdraw that one and I'll ask you another one. Did you do any of the cuttings on the shirt for these stains?

244 MS. MONTGOMERY:

No, I did not.

245 MR. BLASIER:

And did you examine the shirt at all?

246 MS. MONTGOMERY:

No.

247 MR. BLASIER:

Ever? Did you see Gary Sims examining it at all?

248 MS. MONTGOMERY:

No, I don't recall looking--seeing it.

249 MR. BLASIER:

There was a considerable amount of blood on the shirt; was there not? Do you know that?

250 MS. MONTGOMERY:

From some of the photos I've seen, it appeared to be.

251 MR. BLASIER:

Now, would you agree that one way that there could be such carry-over from one victim to the other would be if the clothes came into contact in some way?

252 MR. HARMON:

Objection. Calls for speculation, argumentative.

253 THE COURT:

Sustained.

254 (Discussion held off the record between Defense counsel.)
255 MR. BLASIER:

Now, Miss Montgomery, can you tell us in your opinion, how would you get the kind of mixed stains on both sets of clothing in so many different stains?

256 MR. HARMON:

Objection. It's argumentative, may call for speculation the way it's phrased.

257 THE COURT:

Sustained.

258 MR. BLASIER:

Now, one of the stains on I believe it was the shirt was the substrate control; was it not? Actually, it wasn't a stain. It was a control.

259 MS. MONTGOMERY:

Correct. There was a substrate control submitted or substrate control taken with that.

260 MR. BLASIER:

And do you know who made the cutting for the substrate control?

261 MS. MONTGOMERY:

No, I do not.

262 MR. BLASIER:

Now, the substrate control, we've had a lot of testimony about what they are. But just very briefly, that's supposed to be an area of the shirt where there's no apparent tape, correct?

263 MS. MONTGOMERY:

Right. It's best to take a substrate control that--close to the stain in question, but without any biological fluid that's detectable such as no blood present.

264 MR. BLASIER:

And would you agree that that substrate control showed the presence of alleles?

265 MS. MONTGOMERY:

Yes, I believe it did.

266 MR. BLASIER:

And is that an indication that there can be enough blood or biological material in the sample to cause a result where you can't see it on the original sample?

267 MR. HARMON:

Objection. Assumes facts not in evidence if that's the case.

268 THE COURT:

Overruled.

269 MS. MONTGOMERY:

Umm, could you rephrase that?

270 MR. BLASIER:

Yeah. There are two possible ways that could happen. One is, the controls failed, correct, if you get a reading on a substrate control that's supposed to be empty?

271 MS. MONTGOMERY:

Well, the substrate control is to test what the background of that substrate is.

272 MR. BLASIER:

Okay.

273 MS. MONTGOMERY:

So I wouldn't say it failed.

274 MR. BLASIER:

Well, "Failed" probably was the wrong term. If it shows something, it indicates that there's DNA there?

275 MS. MONTGOMERY:

Correct.

276 MR. BLASIER:

And this particular control showed that there was DNA in an area of the shirt where there didn't appear to be any stain?

277 MS. MONTGOMERY:

Well, it showed an 18 allele in a region that was called a control.

278 MR. BLASIER:

Was that a yes?

279 MS. MONTGOMERY:

Well, if it was taken as a control, then the individual wanted to see what the background of that material was, and it did show some activity in the background of that material.

280 MR. BLASIER:

But by definition, that would have been an area that didn't have any apparent stain?

281 MR. HARMON:

Objection. That's argumentative, your Honor.

282 THE COURT:

Sustained.

283 MR. BLASIER:

Substrate control, is that supposed to be an area that doesn't show any apparent stain?

284 MR. HARMON:

Same objection, your Honor.

285 THE COURT:

Overruled.

286 MS. MONTGOMERY:

Yes. As I stated, the substrate control should be an area that's near the stain, but one that does not give you a presumptive test for blood or anything such as that.

287 MR. BLASIER:

Now, I want to ask you some questions about the specific testing that you performed in this case. Do you have your notes with you?

288 MS. MONTGOMERY:

Yes, I do. Excuse me.

289 MR. BLASIER:

Could you refer to page 5 of your notes?

290 THE COURT:

Excuse me. Mrs. Robertson.

291 MS. MONTGOMERY:

I'm sorry. What page was that?

292 MR. BLASIER:

5.

293 (Brief pause.)
294 MR. BLASIER:

Now, you on I believe it was August 6th of 1994, you started testing, and you started to test the reference samples to see what the types were, correct?

295 MS. MONTGOMERY:

Thank you. I believe the analysis began on August 4th of 1994.

296 MR. BLASIER:

And you amplified--you tried to amplify Mr. Simpson's reference sample the first time and you got no results, did you?

297 MS. MONTGOMERY:

That's correct.

298 MR. BLASIER:

And that was a sample that you assumed came from Mr. Simpson because it was in the reference file labeled Mr. Simpson, correct?

299 MS. MONTGOMERY:

Well, actually that was a tube. Gary Sims examined the bloodstains that were submitted pertaining to O.J. Simpson, Ronald Goldman and Nicole Brown, and he took a portion of the bloodstain and put it into a centrifuge tube and then he gave me those tubes for the extraction process. And so the tube was labeled--I have it specifically--he labeled it with our case number, he labeled it with the evidence number and then he labeled it O.J. Simpson.

300 MR. BLASIER:

Now, that was a sample that you expected to have bands show up, but nothing showed up, correct?

301 MS. MONTGOMERY:

Yes. That's a sample, reference bloodstain from the individual.

302 MR. BLASIER:

Now, you had to do that one over again, didn't you?

303 MS. MONTGOMERY:

Yes.

304 MR. BLASIER:

And that was because you got no bands the first time?

305 MS. MONTGOMERY:

Yes. There was inhibition in that sample. So there was no visible band on the D1S80 gel for O.J. Simpson's reference bloodstain.

306 MR. BLASIER:

Now "Inhibition" is a term that I think we've heard it a couple of times. But that means that something happens with the DNA that the alleles don't amplify. Is that an accurate description?

307 MS. MONTGOMERY:

Yes. It's during the amplification process. Somehow, there's inhibition of the polymerase to--for the amplification of that specific allele.

308 MR. BLASIER:

And that can occur in samples other than reference samples too, can't it?

309 MS. MONTGOMERY:

Oh, yes.

310 MR. BLASIER:

So in mixed samples, you can have inhibition, and some of the alleles that might be there don't show up?

311 MS. MONTGOMERY:

That's unlikely. If you--when you have inhibition, the whole sample is inhibited. You don't just have inhibition of select alleles within an amplification.

312 MR. BLASIER:

I thought you just said a question or so ago that you could have alleles that don't show up because of inhibition?

313 MR. HARMON:

Objection. That's argumentative.

314 THE COURT:

Sustained.

315 MR. BLASIER:

So you're saying that if there's going to be any inhibition at all, all of the alleles are going to be inhibited?

316 MS. MONTGOMERY:

Yes. You would have inhibition of the sample, not inhibition of one particular allele, but inhibition of the alleles in general.

317 MR. BLASIER:

Can you have partial inhibition in--question mark?

318 MS. MONTGOMERY:

I've--I have not seen partial inhibition, no.

319 MR. BLASIER:

You can have differences in the efficiency of the amplification; can you not?

320 MS. MONTGOMERY:

Well, the system has been optimized so you don't get any of this--what was the word you stated?

321 MR. BLASIER:

Inhibition?

322 MS. MONTGOMERY:

Well, the system has been optimized so you don't have some of the partial amplification of alleles.

323 MR. BLASIER:

When you say it's been optimized, what do you mean?

324 MS. MONTGOMERY:

It's been optimized both at the manufacturer and also through validation studies, an in-house evaluation of the system. And this, as I was talking about, the Twgdam requirement, this was one of the requirements that had to be addressed before D1S80 or any PCR marker can be used in the laboratory.

325 MR. BLASIER:

You're not aware of the phenomenon where a minor component of a mixture might get lost in the amplification process and not show up in typing because of the relative quantities of the two contributors?

326 MS. MONTGOMERY:

Oh, now you're talking a different thing. Now, what you're referring to is stoichiometric effect where if you have a minor component, that it's possible--depending on how much of that minor component is present, it's possible not to see the other contribution. But that would be at very low levels of DNA.

327 THE COURT:

All right. Would you spell stoichiometric for the reporter?

328 MS. MONTGOMERY:

S-T-O--I believe I need to write it down.

329 MR. BLASIER:

S-T-O-C-H-I-O-M-E-T-R-I-C.

330 MS. MONTGOMERY:

Correct.

331 MR. BLASIER:

I think.

332 THE COURT:

We'll accept that.

333 MR. BLASIER:

The test in this case, some of the minor components of the mixtures involved very small amounts of DNA, didn't they?

334 MS. MONTGOMERY:

Small relative to the initial start--initial DNA, but not small as I was referring to just in your previous question.

335 MR. BLASIER:

So the amounts that you used in this case, you would never expect to see an allele drop out in amplification?

336 MS. MONTGOMERY:

Well, there was some samples where we amplified a small amount by DQ-Alpha and I believe it was--I'd have to look at my notes, but I believe it was 400 picograms that was amplified. But with D1S80, we--the smallest amount that was amplified I believe was 800, and typically we were amplifying well over one nanogram of DNA.

337 MR. BLASIER:

Now, you also had a problem with one of your standards in the D1S80 tests that you performed in this case; did you not? I'm referring to page 28 and 29 of your notes.

338 MS. MONTGOMERY:

Yes. That's not--that does not have anything to do with the D1S80 system though, and what that is is a slot blot.

339 MR. BLASIER:

Well, the slot blot--you used the slot blot to determine the quantity that you were then going to use for the D1S80 gels, correct?

340 MS. MONTGOMERY:

That's correct.

341 MR. BLASIER:

And one of the standards didn't work right, did it?

342 MS. MONTGOMERY:

Right. On this one, one of the higher standards, it was a 40 nanogram, that was outside of the range that we were even comparing our samples to. These are the standards that are used for comparison with our unknown DNA's. And one of the 40 nanograms was--was out of balance compared to some of the other standards that were on the gel.

343 MR. BLASIER:

And you had to discard that particular standard because of that; did you not?

344 MS. MONTGOMERY:

Yes. I threw that standard away.

345 MR. BLASIER:

Did you do the slot blot over again?

346 MS. MONTGOMERY:

No, I don't believe I did because the 40-nanogram standard was irrelevant on the results of the other samples that were on the gel because everything was at a lower level and it wasn't--the 40-nanogram standard wasn't used as a comparison for the unknown samples.

347 MR. BLASIER:

So when something goes wrong with the test, you make some kind of an assessment that whether it really would affect your results or not in deciding whether you do something over again?

348 MS. MONTGOMERY:

Yes. One needs to--if something such as that where the 40-nanogram standard was less intense than the 20-nanogram standard, if something like that happens, one should troubleshoot it and determine what is happening. And if it appears that it had any bearing on--or any bearing on your results, then your analysis needs to be repeated. In this particular case, it was shown that the 40-nanogram standard was irrelevant because what I was looking at was low levels of DNA in the unknown samples. And so I was comparing at the lower levels, the lower-level standards as opposed to the 40-nanogram standards. So--and basically that 40-nanogram standard did not even need to be placed on that gel.

349 MR. BLASIER:

So your answer is yes. Can we put that down as a yes?

350 MS. MONTGOMERY:

You'd--actually you'd have to reask the question, please.

351 MR. BLASIER:

You also had a problem--I'll pass on that. You also had a problem with the Rockingham glove, didn't you?

352 MR. HARMON:

Objection. Vague as to "Problem."

353 THE COURT:

Sustained.

354 MR. BLASIER:

Refer you to page 46 of your notes. The first time you did it, you had a problem, didn't you?

355 MS. MONTGOMERY:

Oh, yes. That gel was reanalyzed.

356 MR. BLASIER:

And what happened was, the ladder was smeared and distorted and you had some crossover from one lane to another on the gel, correct?

357 MS. MONTGOMERY:

Yes. And this demonstrates that when something is unacceptable in our laboratory, we do reanalysis of the samples. If there's ever any question, then we reanalyze samples.

358 MR. BLASIER:

Now, let me refer you to page 62 of your notes. One of the standards that's used on these gels--and let me ask if we could have some photographs marked. Actually let me use one of the Prosecution's, exhibits 275-H.

359 (Brief pause.)
360 MR. BLASIER:

Can we show that on the elmo, please?

361 MR. BLASIER:

I just want to use this for illustrative purposes. The--if we count three lanes over from the left--

362 MS. MONTGOMERY:

I'll need to come down there to get a look at it.

363 MR. BLASIER:

Okay.

364 (Brief pause.)
365 MR. BLASIER:

Three lanes over from the left is called the one-nanogram control lane; is it not?

366 MS. MONTGOMERY:

Yes, it is.

367 MR. BLASIER:

And that is a known sample that has genotype 1831, correct?

368 MS. MONTGOMERY:

Yes. That's a--that's an additional standard that's placed on the gel. It's provided within the Roche kit. And as you can see, the first lane--if I had the little telestrator, I could--

369 MR. BLASIER:

Well, I'll show you another picture. We can highlight the other picture.

370 MS. MONTGOMERY:

Okay.

371 MR. BLASIER:

That is supposed to be--that's supposed to come up 1831 each time you do it, correct?

372 MS. MONTGOMERY:

Well, that's an additional control. The one--the control that must--

373 THE COURT:

Excuse me. Miss Montgomery, the question was, is that what comes up.

374 MS. MONTGOMERY:

Could you--I'm sorry. What--

375 MR. BLASIER:

That one-nanogram control, that's one of the controls that you use and that's supposed to light up at 1831 if your test is being done properly?

376 MS. MONTGOMERY:

Yes and no. That is a--an additional control, but the control in question that must respond properly is the first one in that--after the ladder, and that's the four-nanogram control of an 1831.

377 MR. BLASIER:

And the bands on the one-nanogram control, should they be of equal intensity?

378 MS. MONTGOMERY:

Yes. They're--yes, they should. But the one--the one in question is actually the four-nanogram.

379 MR. BLASIER:

No. The one I'm asking about is the one-nanogram.

380 MS. MONTGOMERY:

Right.

381 MR. BLASIER:

Should those be of equal intensity?

382 MS. MONTGOMERY:

One would want them to be of equal intensity, yes.

383 MR. BLASIER:

Well--you can resume your seat, please.

384 (The witness complies.)
385 MR. BLASIER:

I believe you indicated on direct that your system has been optimized so bands with equal amounts of DNA will show up with equal intensity. Did I hear that right?

386 MS. MONTGOMERY:

Correct.

387 MR. BLASIER:

Miss Montgomery, I showed you a series of pictures or I gave them to you at lunch for you to look at to see if they were accurate pictures of some of the films that we've already seen, correct?

388 MS. MONTGOMERY:

Correct.

389 MR. BLASIER:

And did you agree that the packet I gave you was an accurate--these were accurate pictures of your films?

390 MS. MONTGOMERY:

Yes, they were.

391 MR. BLASIER:

Your Honor, I need to have these marked.

392 MR. BLASIER:

Let me ask you just to look at these again just to satisfy yourself that they're the same.

393 THE COURT:

All right. Mr. Blasier, I think these would be 1174. How many do you have?

394 MR. BLASIER:

There are one, two, three, four--seven pictures.

395 (Brief pause.)
396 MR. BLASIER:

Do we have photo no. 96? And this is--your Honor, what was the first number?

397 THE COURT:

1174.

398 (Deft's 1174 for id = photograph)
399 MR. BLASIER:

Now, Miss Montgomery, this is the--this is just a picture of the film that you showed us that contains the Bronco samples, no. 30, 31 and 293, correct?

400 MS. MONTGOMERY:

Yes.

401 MR. BLASIER:

And I'm going to highlight or I'm going to--actually I'm going to magnify the one-nanogram control lane.

402 MS. MONTGOMERY:

Mr. Blasier, are we going to go through all of these at this time? Would it be easier if I just stayed down at the--

403 MR. BLASIER:

Well, I think you should be able to see these on the monitor. Now, you agree that the lane there on the right is the one-nanogram control lane?

404 MS. MONTGOMERY:

Yes.

405 MR. BLASIER:

Now, you can refer to page 70 of your notes. Would you agree that when you read this, you read the 18 band of that one-nanogram control as being brighter than the 31 band? It's a little difficult to see in the picture. That's why I referred you to your notes.

406 MS. MONTGOMERY:

I'm--you said page 70 of my notes?

407 MR. BLASIER:

Yes.

408 MS. MONTGOMERY:

Could you show me the full scale of this?

409 MR. BLASIER:

The picture?

410 MS. MONTGOMERY:

Yeah.

411 MR. BLASIER:

Sure.

412 MS. MONTGOMERY:

It's difficult looking at it out of context.

413 (Brief pause.)
414 MS. MONTGOMERY:

Yes. That's not page 70 of my notes.

415 MR. BLASIER:

Okay. Do you have the page of your notes that shows your work sheet for items 30, 31 and 293? Let me show you my copy.

416 MS. MONTGOMERY:

Actually, yes. It's page 44.

417 MR. BLASIER:

Page 44?

418 MS. MONTGOMERY:

Yes.

419 MR. BLASIER:

Would you agree that your notes indicate that the 18 is more intense than the 31?

420 MS. MONTGOMERY:

No. I disagree with that.

421 MR. BLASIER:

Okay.

422 MS. MONTGOMERY:

My notes don't indicate that at all.

423 MR. BLASIER:

All right. Take a look at page 70 of your notes. Are you looking at your notes?

424 MS. MONTGOMERY:

Yes, I am.

425 MR. BLASIER:

That was--that's your run sheet from which samples?

426 MS. MONTGOMERY:

Page 70, this is AG, analytical gel, 267, and this is a composite of many samples, quality control samples, positive controls from different amplification days and also two controls relating--two control samples relating to the Bronco, and those are DNA 17--DNA's our DOJ number--17, which is what, LAPD 30, and then also DNA 18 control, which is LAPD 31.

427 MR. BLASIER:

So that's--is that a different run of the same samples that we showed in the last picture?

428 MS. MONTGOMERY:

Well, the first picture you showed was actual samples that were taken. The samples that related to the controls of the Bronco, they were samples DNA 17 and DNA 18. Those were two Bronco samples. And then on the next gel, the one you're referring to now, AG 267, those are the controls that go with the Bronco samples on that previous gel.

429 MR. BLASIER:

Okay. And those controls were done at a different time than the samples to which they belonged?

430 MS. MONTGOMERY:

Yes. There's only a limited space on a gel. You can't--sometimes you can't fit all the samples.

431 MR. BLASIER:

Well, on many of these runs, you did put the control samples with the samples to which they belonged; did you not?

432 MS. MONTGOMERY:

Yes. When--when there's enough space, I'll put as many samples as I can on the gel. But if there's not enough space, then you're limited with the number you can put on the gel and you'll have to put it on a different--a separate gel.

433 MR. BLASIER:

Now, would you agree on your run for the controls, page 70 of your notes, that you determined that the 18 band in your standard, one-nanogram standard band was greater than the 31 band?

434 MS. MONTGOMERY:

Umm--no. The positive control that goes with those control samples functioned properly.

435 MR. BLASIER:

My question was, did you note in your run sheet that 18 was brighter than 31?

436 MR. HARMON:

Objection, vague as to which control.

437 MR. BLASIER:

One-nanogram control lane.

438 THE COURT:

That's fine.

439 MS. MONTGOMERY:

Oh, okay. The one-nanogram control. Now, this pertains to a different amplification. This doesn't pertain to the controls that were put with the Bronco. And yeah, there was an 18, a weak 18, and the 31, there was a hint at the 31. There was a difference in the intensity of those alleles.

440 MR. BLASIER:

And your four-nanogram control lane also had a difference in intensity; did they not--did it not?

441 MS. MONTGOMERY:

Yes, it did. There was a gel problem on that region of the gel. That was the--the farther region of the gel, the last four lanes.

442 MR. BLASIER:

That's not the way those controls are supposed to work, is it? They're supposed to be of equal intensity, aren't they?

443 MS. MONTGOMERY:

Yes. We've optimized the amplification so you get equal intensity of those alleles. This was a gel effect.

444 MR. BLASIER:

Somehow this one didn't get optimized.

445 MS. MONTGOMERY:

No. This was a gel effect. This isn't an amplification effect.

446 MR. BLASIER:

So there are some effects on the gel that can cause there to be different intensities of bands in the same lane?

447 MS. MONTGOMERY:

Yes. I mean that was demonstrated on that particular sample, on those samples towards the further region of the gel, that there was a discrepancy between those alleles. And it's a gel art--or it's a gel polymerization problem.

448 MR. BLASIER:

Now, you also indicated on your work sheet for that--those controls that your 31A allele was smeared and not well defined. Is that also--is that another manifestation of the gel problem?

449 MS. MONTGOMERY:

I'm sorry. What--which sample?

450 MR. BLASIER:

The same one we were looking at, page 70.

451 MS. MONTGOMERY:

Yes. And that gave you an indication that that--that region of the gel wasn't functioning properly.

452 MR. BLASIER:

Now, let me refer you to page 62 of your notes. And that was the run for the positive controls for what? Actually those are sock samples; are they not?

453 MS. MONTGOMERY:

Yes, they are.

454 MR. BLASIER:

And you have both some controls and some of the evidence samples on that run, correct?

455 MS. MONTGOMERY:

Correct.

456 MR. BLASIER:

And you had a problem on that run as well, did you not, with your 31 band?

457 MS. MONTGOMERY:

Now--well, that wasn't a problem because on this run, four nanograms--no, that wasn't a problem.

458 MR. BLASIER:

It didn't come out the way it was supposed to come out, did it?

459 MS. MONTGOMERY:

The one-nanogram control had--the 31 band was darker than the 18 band, and that's for the one-nanogram control. The four-nanogram control gave equal intensity of the two alleles.

460 MR. BLASIER:

The one-nanogram control was supposed to also give you bands of equal intensity, correct?

461 MS. MONTGOMERY:

Well, the one-nanogram control, you would like to have equal intensity of those two alleles, yes.

462 MR. BLASIER:

And--

463 MS. MONTGOMERY:

But there--

464 MR. BLASIER:

Go ahead.

465 MS. MONTGOMERY:

I'm sorry. There are situations where you don't get equal intensity of those two alleles. And that's why at lower levels of DNA amplification, you need to be cautious with your interpretation. That's why you strive to amplify more than a nanogram of DNA.

466 MR. BLASIER:

Doesn't that mean that with small concentrations of DNA, you can't really make very precise assessments about band intensity vis-à-vis who the contributor was?

467 MS. MONTGOMERY:

Well, you're saying with--when you have a low level of DNA, that it's difficult to tell which bands go to which bands? Is that what you're saying?

468 MR. BLASIER:

You have to be much more cautious in terms of trying to determine who contributed what bands when you're talking about low levels of DNA?

469 MS. MONTGOMERY:

If you're talking about very low levels of DNA, yes.

470 MR. BLASIER:

Now, we've talked about the--your being unable to amplify Mr. Simpson's standard--or reference sample the first time, problems with the standard--the glove that you had to redo, the gel problems that you've had and the 31 control band that we've talked about. Is this number of problems typical for the D1S80 system?

471 MR. HARMON:

Objection. That's argumentative, compound.

472 THE COURT:

Sustained. Rephrase the question.

473 MR. BLASIER:

Did you ordinarily have these types of problems with D1S80 or in this case, did you have more problems than usual?

474 MR. HARMON:

Objection. "Problems" is argumentative.

475 THE COURT:

Sustained.

476 MR. BLASIER:

These kinds of things going wrong, is this typical of this system?

477 MR. HARMON:

Same objection, your Honor.

478 THE COURT:

Overruled.

479 MS. MONTGOMERY:

With the amplification, that's a PCR phenomenon, the fact that the reference sample did not amplify. And as far as the other--the other things, the one-nanogram control is used or the one-nanogram standard is used as an additional control. The main control that we're concerned with is the four-nanogram, and we want to see equal intensity of those four-nanogram controls. The system, I have all the confidence in the system and with the results of the system. So if that answers your question.

480 MR. BLASIER:

I move to strike all of that as nonresponsive.

481 THE COURT:

Overruled.

482 MR. BLASIER:

Was that a yes or a no? Are these the kinds of things that happen routinely with the D1S80 system?

483 MR. HARMON:

Objection. It's argumentative, it's been asked and answered.

484 THE COURT:

Rephrase the question.

485 MR. BLASIER:

The things we've just been talking about, are these typical of the D1S80 system?

486 MS. MONTGOMERY:

They're not typical, no.

KEY QUOTE
487 MR. BLASIER:

So more things like we've described happened with respect to this case than you would expect to see in other D1S80 cases?

488 MR. HARMON:

Objection. It's argumentative.

489 THE COURT:

Sustained. Rephrase the question.

490 MR. BLASIER:

Okay. You said it's not typical. Would you expect in D1S80 system on a particular case there to be more problems like this or less?

KEY QUOTE
491 MR. HARMON:

Objection. It's compound.

492 THE COURT:

Overruled.

493 MS. MONTGOMERY:

Over 20 gels were run in this particular case, which is more than most cases. And as far as the problems, there were no significant problems. There was reanalysis on a few of the gels, but nothing was significant to cause problems with this result. I--there were not more problems seen in this particular case than seen, you know, with D1S80 analysis and they weren't major problems.

494 MR. BLASIER:

So when you said that this was not typical, you were indicating that in other cases, you're likely to see more types of things like this?

495 MR. HARMON:

Objection. It's argumentative, asked and answered.

496 THE COURT:

Sustained. Rephrase the question.

497 MR. BLASIER:

Well, you said this wasn't typical, and I asked you, are there more things, problem areas let's call them, here than in a typical case. And I don't think you answered that. Could you answer that?

498 MR. HARMON:

Objection. It's compound, it's argumentative, calls for speculation.

499 THE COURT:

Overruled.

500 MS. MONTGOMERY:

By typical doesn't mean--it's not routine that you see some of these phenomenons occurring. That's what I meant by it's not typical.

501 MR. BLASIER:

So in ordinary cases, you don't see these kinds of things happen. Is that what you said?

502 MS. MONTGOMERY:

In ordinary cases. Umm, I'm not quite sure what you mean.

503 MR. BLASIER:

May we have photo 100, please? And this will be 1175?

504 THE COURT:

1175.

505 (Deft's 1175 for id = photograph)
506 MR. BLASIER:

Now, Miss Montgomery, could you take a look at this and tell me which run this is? This is--I'll tell you. It's AG184, correct?

507 MS. MONTGOMERY:

Correct.

508 MR. BLASIER:

And this was the run where you did samples from the Bundy drops, correct?

509 MS. MONTGOMERY:

Yes, it was.

510 MR. BLASIER:

Now, on this sample, you did both samples of those drops as well as some of the controls; did you not?

511 MS. MONTGOMERY:

Correct.

512 MR. BLASIER:

And the writing at the top is--that just identifies what's in the lane below it, correct?

513 MS. MONTGOMERY:

Yes. That's--actually that's Dr. Blake's writing and his photographs.

514 MR. BLASIER:

But do you concur that he has properly labeled the lanes?

515 MS. MONTGOMERY:

Yes, he has.

516 MR. BLASIER:

Now, the last two lanes over here--I've got the little arrow on it--the first one is DOJ 24. And what is that?

517 MS. MONTGOMERY:

DOJ 24 as written here is what we call DNA 24. Dr. Blake tended to call our samples DOJ and in-house we called them DNA, and that relates to LAPD no. 50 control.

518 MR. BLASIER:

Now, that's a substrate control for a Bundy drop, correct?

519 MS. MONTGOMERY:

I believe it is, yes.

520 MR. BLASIER:

And that shouldn't have any lanes in it should it, any bands in it?

521 MS. MONTGOMERY:

Correct.

522 MR. BLASIER:

What is that, Miss Montgomery?

523 MS. MONTGOMERY:

It's not a band. That's--yeah. If you look at the--yes. If you look at the original gel, you can see that there's some blip or glitch. I'm not sure if it's actually cut out of the gel or not. That's right in between the two lanes, but it's not a band. It's definitely not a band.

524 MR. BLASIER:

Would you agree that if that were a band, that means that your control, the substrate control showed the presence of DNA that shouldn't be there?

525 MR. HARMON:

Objection. Calls for speculation.

526 THE COURT:

Sustained.

527 MR. BLASIER:

Now, how do you tell the difference between something like that that looks like a band and something that is a very faint band?

528 MS. MONTGOMERY:

Well, first of all--first of all, this is right in between two lanes, and samples are loaded into the lane and you would see distinct banding pattern within that well where they were loaded. As I'm holding up a gel to demonstrate for you, this is where the wells, where samples are loaded. Can you see this? And there's a separation between each--each--where your sample's loaded. That blip right in there (Indicating) is diffuse smearing blip in the gel, and it could either be--like I said, it could be just where the gel's been darkened right in that area, and when it was photoed, it was captured by that. But it's definitely not a band. It's not a distinct thickened blind.

529 MR. BLASIER:

It's not something you expect to see, is it?

530 MS. MONTGOMERY:

Well, you wouldn't expect to see it, but it's not anything that concerns me.

531 MR. BLASIER:

It indicates that something is going on there that shouldn't be going on there; isn't that accurate?

532 MS. MONTGOMERY:

No. I think that's inaccurate to say that.

533 MR. BLASIER:

Now, we described this as having a band-like appearance. Would you concur with that? Looks like it could have been a band?

534 MS. MONTGOMERY:

Yeah. It has a--you know, there's some darkening in that region of the gel.

535 MR. BLASIER:

And it's at an allele--I'm sorry--it's at a level on the ladder different from any of the people that you've tested in connection with this case?

536 MS. MONTGOMERY:

That's correct.

537 MR. BLASIER:

And it's--I believe it's at a 15 allele, isn't it, if that is a band. That band-like appearance, is a band, it's a 15?

538 MR. HARMON:

Objection. It's irrelevant, what it could be.

539 THE COURT:

Overruled.

540 MS. MONTGOMERY:

Well, if you--if you're saying it's a band, then that would be in between that 14 repeat and the 16 repeat. So that would be the 15 repeat.

541 MR. BLASIER:

This might be a time.

542 THE COURT:

Ladies and gentlemen, we'll take our break. Please remember all of my admonitions. We'll be in recess for 15 minutes.

Temperature

tense

Key Quotes (5)

Robert Blasier
Now, is it also accurate to say that of all of those 23 stains, O.J. Simpson is excluded?
Forces the key defense point explicitly on the record: all victim clothing stains exclude Simpson as a contributor
Ms. Montgomery
That's correct.
Unequivocal confirmation that Simpson is excluded from all 23 stains tested on victims' clothing
Ms. Montgomery
They're not typical, no.
Admission that the accumulation of technical problems in this case — failed amplification, gel smearing, control intensity discrepancies — exceeded what one would normally expect
Ms. Montgomery
I have all the confidence in the system and with the results of the system.
Prosecution witness defending her results despite conceding multiple anomalies; Blasier immediately moved to strike as nonresponsive
Robert Blasier
You said it's not typical. Would you expect in D1S80 system on a particular case there to be more problems like this or less?
Closing the loop on the pattern of anomalies, pressing Montgomery to characterize this case as an outlier in quality

Evidence (6)

Deft's 1172-A and B
Proficiency test worksheets showing two hybridization runs on the same DQ-Alpha samples
introduced and examined in detail for anomalous hint/trace dot readings
Deft's 1173-A through I
Defense slides summarizing D1S80 mixture results from victims' clothing (Goldman shirt, Goldman jeans, Nicole Brown Simpson dress)
introduced and used to establish that 15-16 of 23 stains show mixtures of both victims, with Simpson excluded from all
People's 275-H
Photograph of D1S80 gel film containing Bronco samples (items 30, 31, 293)
used illustratively to examine one-nanogram control lane band intensity
Deft's 1174
Seven defense photographs of D1S80 gel films, confirmed by Montgomery as accurate copies
introduced to examine control lane band intensity discrepancies
Informal
Montgomery's case notes (pages 5, 44, 46, 62, 70) containing run sheets and work sheets for reference samples, Bronco samples, sock samples, and glove
referenced throughout to probe specific technical anomalies in each run
Informal
Rockingham glove D1S80 gel (page 46 of notes) — first run discarded due to smeared ladder and lane crossover
discussed as example of required reanalysis

Notable Exchanges (5)

Robert BlasierMs. Montgomery
Blasier walked through all 23 stains on victims' clothing (Nicole's dress, Goldman's jeans, Goldman's shirt) and secured confirmation that Simpson is excluded from every single one — a clean, structured defense victory presented through the prosecution's own witness.
strategic
Robert BlasierMs. Montgomery
Extended exchange on 'hints' and 'traces' on DQ-Alpha strips — Blasier pressed that unexpected dots appearing on the second hybridization that weren't present on the first run undermines the claim that the system gives reproducible results. Montgomery insisted they are not significant to interpretation but conceded they were not expected.
revealing
Robert BlasierMs. Montgomery
Blasier catalogued a list of testing anomalies (failed OJ reference amplification, glove gel rerun, slot blot standard discarded, one-nanogram control intensity imbalances) and pressed Montgomery to admit they were 'not typical.' She conceded.
methodical and damaging
Robert BlasierMs. Montgomery
Exchange on stoichiometric effect — Montgomery initially denied that individual alleles could be inhibited, then had to walk back to acknowledge that minor mixture components at low DNA concentrations could drop out. Judge Ito asked counsel to spell 'stoichiometric' for the court reporter.
technical, slightly awkward
Robert BlasierMs. Montgomery
Blasier challenged whether the proficiency tests Montgomery had taken ever involved mixed bloodstains, establishing that her validation experience with mixtures was limited and did not directly replicate the conditions of this case.
probing

Light Moments (3)

Ms. Montgomery
Montgomery complained about the multi-screen setup: 'This multi media, I can't decide what to look at,' prompting Blasier to say 'Whatever's easiest.'
Lance A. Ito
Judge Ito interrupted technical testimony to ask counsel to spell 'stoichiometric' for the court reporter; Blasier spelled it out and added 'I think,' to which Ito replied 'We'll accept that.'
Ms. Montgomery
Montgomery asked if she could come down to the elmo to see the gel images more clearly, noting 'The clarity is not very good on this.'

Credibility Attacks (4)

⚔ Ms. Montgomery
pattern of testing anomalies
Blasier systematically compiled a list of technical failures across her work on this case — failed OJ reference amplification, gel rerun on the glove, discarded slot blot standard, control band intensity imbalances — then secured her admission that this accumulation is 'not typical' of the D1S80 system
⚔ Ms. Montgomery
reproducibility challenge
Blasier used her own proficiency test worksheets (1172-A and B) to show that the second hybridization produced hints and traces at positions where the first run showed nothing, undermining her claim that the system reliably reproduces results
⚔ Ms. Montgomery
lack of relevant validation experience
Established that none of Montgomery's proficiency tests involved mixed bloodstains, the precise condition she was called to interpret in this case, limiting the foundation for her mixture interpretations
⚔ Ms. Montgomery
internal inconsistency
Montgomery initially said inhibition affects 'the whole sample' and that 'partial inhibition' is not something she has seen, but was then forced to acknowledge the stoichiometric effect where minor mixture components at low DNA levels can drop out — a distinction she had to be walked into admitting

Witness Demeanor

(The witness complies.) — after being asked to return to her seat, twice
(Brief pause.) — multiple times while Montgomery located pages in her notes
Montgomery repeatedly hedged with 'I'd have to see the notes' and 'I'd have to look at it again,' signaling discomfort with questions taken out of her full case file context
Montgomery volunteered a closing statement of confidence — 'I have all the confidence in the system and with the results of the system' — unprompted, which Blasier immediately moved to strike as nonresponsive

Objections

23 objections (13 sustained, 9 overruled)
Proceeding 6162 • 542 utterances • Prosecution witness
Criminal Trial
Department 103
⚖️ Start
📂 MAY 23, 1995 📄 Cross-examination of Renee Mon
MAY 23, 1995 KRT DvH TD