📄 Direct examination of Dr. Robin Cotton (part 7) — Tuesday, May 9, 1995
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Direct examination of Dr. Robin Cotton (part 7)

Witness: Dr. Robin Cotton
Examiner: George Clarke
Called by: Prosecution • Date: Tuesday, May 9, 1995 • Utterances: 109
Prosecutor George Clarke conducts foundational direct examination of Dr. Robin Cotton, the Cellmark Diagnostics lab director, covering how the lab received and tested DNA samples using both RFLP and PCR approaches without knowing the identities of the known reference samples. Cotton affirms that all lab procedures were correctly followed by analysts Julie Cooper and Paula Yates, with only one minor anomaly (faint dots in one reagent blank). The session ends abruptly when Clarke attempts to distribute copies of exhibit 246 — an autoradiograph of the three known DNA samples — to the jury, prompting Neufeld to request a sidebar.
1 (The following proceedings were held in open Court, in the presence of the jury:)
2 THE COURT:

Thank you, ladies and gentlemen. Please be seated. Dr. Cotton, would you resume the witness stand. All the jurors have now rejoined us. And as I recollect, we were just talking about the designation of the exemplars by letter.

3 MR. CLARKE:

Yes. Thank you, your Honor.

4 MR. CLARKE:

So again, Dr. Cotton, as far as your laboratory was concerned at the time of testing, the identities of the persons from whom those three blood samples came from, known samples were basically unknown to your laboratory?

5 DR. COTTON:

That's right.

6 MR. CLARKE:

Now, after receiving various pieces of evidence in this case, was testing conducted on them using various DNA typing approaches?

7 DR. COTTON:

Yes.

8 MR. CLARKE:

And would that be the RFLP as well as PCR approaches?

9 DR. COTTON:

That's right.

10 MR. CLARKE:

How did you make decisions about which items, whether evidence and known samples or known samples and which approach was going to be used with those various items? How do you do that?

11 DR. COTTON:

Well, for some of the items, we were requested to do a particular thing. Most of that would be PCR. For some of the items, umm, we were directed to do testing, and if possible, do RFLP testing. So for those items, we would have made an assessment of the quantity and quality of DNA that was extracted from those items, and then we would have proceeded to make some judgment as to whether we should try RFLP or go straight to PCR.

12 MR. CLARKE:

As far as the actual testing conducted in this case, do you have with you today the autorads from RFLP testing that was done?

13 DR. COTTON:

Yes, I do.

14 MR. CLARKE:

Do you also have photographs from the various typing strips that were interpreted or results were obtained from after PCR amplification?

15 DR. COTTON:

Yes, I do.

16 MR. CLARKE:

As far as the testing itself--and I'm referring to all of the testing conducted in your laboratory--did the controls work properly?

17 DR. COTTON:

The controls worked properly for all of the testing with one exception, and we had a--very faint dots in one reagent blank for one of the PCR tests.

KEY QUOTE
18 MR. CLARKE:

All right. We'll return to that later. Was that, to your knowledge, the only instance in which that occurred?

19 DR. COTTON:

Yes.

20 MR. CLARKE:

Incidentally, why was--does the fact that you weren't informed of who these reference samples play any role in the testing itself?

21 DR. COTTON:

No, it doesn't.

22 MR. CLARKE:

Why didn't you know who they were from?

23 DR. COTTON:

Umm, I'm not sure who made that determination. I've been assuming that it was--

24 MR. NEUFELD:

Objection as to assume.

25 THE COURT:

Sustained.

26 MR. CLARKE:

Was a determination--I'm sorry. Was it a determination made by you?

27 DR. COTTON:

No.

28 MR. CLARKE:

Was it a determination made by anyone in your laboratory?

29 DR. COTTON:

No.

30 MR. CLARKE:

In the course of testing--well, let me rephrase that, go back one step. As far as your not being informed of the identity of those known samples, is that unusual or normal?

31 DR. COTTON:

It's unusual, but it's not the only time that we've received samples coded in some manner.

KEY QUOTE
32 MR. CLARKE:

As far as the results that were ultimately obtained, did they include indications to you of mixtures of DNA?

33 DR. COTTON:

There is--there are two samples in the results that are clearly mixtures of DNA.

34 MR. CLARKE:

What is a mixture of DNA? Can you describe that briefly?

35 DR. COTTON:

Well, in this circumstance, we're talking about the idea that the DNA that was extracted from the sample contains DNA from more than one person.

36 MR. CLARKE:

How are you able to determine that a sample has DNA from more than one person?

37 DR. COTTON:

For an RFLP test--well, actually it's the same for both. Any time that you look at a single genetic location and you see more than two types for an RFLP test, that would be, instead of just seeing two bands, you saw three, or for a PCR test, would be instead of seeing just two types like an a and a B, you would see an A, a B and a C. Under those circumstances, you know immediately that you have DNA from more than one person.

38 MR. CLARKE:

As you've used the term earlier, is that "contamination" as you've used the term?

39 DR. COTTON:

If you view contamin--if you--let me back up a second. If you have--if those two DNA's are part of the original evidence as it was left at the scene, then in my view, that's not an instance of contamination. That's the true nature of the sample. If you want to back up and say are these sterile samples, no. We've got two DNA's that are mixed together, but that's not a good reference point for this kind of discussion.

40 MR. CLARKE:

With regard to the procedures--and you've had an opportunity to review all of the material relating to this case?

41 DR. COTTON:

I have.

42 MR. CLARKE:

That includes the autorads themselves?

43 DR. COTTON:

It does.

44 MR. CLARKE:

Does it include photographs?

45 DR. COTTON:

Photographs of results?

46 MR. CLARKE:

Yes.

47 DR. COTTON:

Yes.

48 MR. CLARKE:

Have you had an opportunity to review all of the documents that you've described are kept in the course of testing in your laboratory?

49 DR. COTTON:

Yes, I have.

50 MR. CLARKE:

From that review of the various documents and data, whether photographs or autorads themselves, do you have an opinion about whether or not correct procedures were used by the two analysts in this case, Julie Cooper and Paula Yates?

51 DR. COTTON:

Yes, I do.

52 MR. CLARKE:

What is that opinion?

53 DR. COTTON:

My opinion is that the procedures in the protocol were followed correctly in the testing in this case.

KEY QUOTE
54 MR. CLARKE:

As far as the procedures that were used in this case, in your opinion, are those proper scientific procedures for DNA typing?

55 DR. COTTON:

In my opinion, they certainly are.

56 MR. CLARKE:

Now, with regard to--and let's focus immediately on RFLP testing itself. Do you have with you an autoradiograph that depicts the three standards or known samples in this case?

57 DR. COTTON:

Yes.

58 MR. CLARKE:

And have you also-- well, first of all, do you have the original autoradiographs with you?

59 DR. COTTON:

Yes, I do.

60 MR. CLARKE:

Do you have a policy in your laboratory about releasing original autoradiographs?

61 DR. COTTON:

Yes, we do.

62 MR. CLARKE:

What is that policy?

63 DR. COTTON:

We don't release them until we come to Court. If they are left as part of the Court record, that's okay. But prior to that, we maintain the original data, which is the autoradiographs, in our custody.

64 MR. CLARKE:

For what reason? Actually, let me rephrase that question. In terms of the originals themselves, do they represent the best data available?

65 DR. COTTON:

They do.

66 MR. CLARKE:

All right. With regard to the autoradiograph I mentioned that deals or demonstrates the results obtained from DNA from the three identified samples, that is without name, but identified as known persons, does that autorad--has it already been marked in this case?

67 DR. COTTON:

They all have the three known people on them.

68 MR. CLARKE:

Okay. Let's go back then to what I believe is exhibit 246 if I recall correctly.

69 MR. CLARKE:

And may I approach the witness, your Honor?

70 THE COURT:

You may.

71 MR. CLARKE:

Showing you exhibit 246, can we use that autoradiograph to show what the DNA appears or what it appears like for the three known samples in this case?

72 DR. COTTON:

Yes.

73 MR. NEUFELD:

I'm sorry. May I just approach and take one look at what she's looking at?

74 THE COURT:

Sure.

75 MR. NEUFELD:

Thank you.

76 (Brief pause.)
77 THE COURT:

That's People's 246.

78 MR. NEUFELD:

Thank you.

79 MR. CLARKE:

Your Honor, at this time, I have or actually the laboratory has made a number of copies of this particular autoradiograph that shows the three standards, that is the three known individuals. It has one evidence lane with nothing showing. And it would be my request that these copies be distributed to the jury.

80 THE COURT:

Can I see that?

81 MR. CLARKE:

Yes.

82 THE COURT:

Have you shown them to counsel?

83 MR. CLARKE:

They have one copy.

84 THE COURT:

Mr. Clarke, may I see one of those, please?

85 MR. CLARKE:

Yes.

86 THE COURT:

I take it these are all duplicates of the same?

87 MR. CLARKE:

Yes. Am I approaching in the wrong direction?

88 THE COURT:

You want to hand it to Mrs. Robertson? I just need to see one of them.

89 (Brief pause.)
90 THE COURT:

All right. And, Mr. Clarke, these are exact duplicates of 246?

91 MR. CLARKE:

Yes.

92 THE COURT:

And that's with item 56 removed, correct?

93 MR. CLARKE:

I'm sorry?

94 THE COURT:

That's with item 56 removed? Never mind. All right. Mr. Clarke, do you have enough to go around?

95 MR. CLARKE:

Yes.

96 THE COURT:

Mr. Neufeld?

97 MR. NEUFELD:

I just hadn't seen the copies, your Honor. That's why I didn't--

98 THE COURT:

Okay.

99 MR. NEUFELD:

Sometimes there's some variation. That's all I--

100 THE COURT:

Mr. Clarke, why don't you let Mr. Neufeld take a look there.

101 MR. NEUFELD:

May I?

102 (Brief pause.)
103 MR. NEUFELD:

Just one moment, your Honor. I want to compare the two.

104 (Brief pause.)
105 THE COURT:

I take it this is for demonstration purposes at this point because we're not doing any comparison yet, correct?

106 MR. CLARKE:

Only amongst the three knowns.

107 MR. NEUFELD:

Your Honor, can we have a brief sidebar?

108 THE COURT:

All right. With the Court reporter, please.

109 MR. NEUFELD:

Thank you.

Temperature

procedural

Key Quotes (4)

Dr. Robin Cotton
The controls worked properly for all of the testing with one exception, and we had a--very faint dots in one reagent blank for one of the PCR tests.
Cotton volunteers the only anomaly in Cellmark's testing, getting ahead of a likely defense attack while minimizing its significance.
Dr. Robin Cotton
My opinion is that the procedures in the protocol were followed correctly in the testing in this case.
Direct endorsement of her analysts' work — the core credibility pillar the prosecution is building.
Dr. Robin Cotton
If you have--if those two DNA's are part of the original evidence as it was left at the scene, then in my view, that's not an instance of contamination. That's the true nature of the sample.
Cotton preemptively reframes 'mixture' evidence to distinguish it from lab contamination — a key distinction the defense would later challenge.
Dr. Robin Cotton
It's unusual, but it's not the only time that we've received samples coded in some manner.
Acknowledges the blind testing was atypical while normalizing it — addresses the implicit suggestion that something was hidden from the lab.

Evidence (1)

People's 246
Original autoradiograph showing RFLP results for the three known DNA reference samples (identified by letter, not name), with one evidence lane showing nothing
Shown to witness; copies distributed to jury (interrupted by sidebar request)

Notable Exchanges (2)

Peter NeufeldLance A. Ito
Neufeld asks to compare the jury copies of exhibit 246 to the original before distribution, citing potential variation between copies, then requests a sidebar just as distribution is about to proceed.
strategic
George ClarkeLance A. Ito
Clarke asks to distribute jury copies of 246; Ito clarifies this is for demonstration only among the three knowns, not yet making comparisons to evidence samples.
procedural

Light Moments (1)

George Clarke
Clarke approaches the bench from the wrong direction and catches himself: 'Am I approaching in the wrong direction?'

Witness Demeanor

Measured and technical throughout; careful to self-correct and clarify (e.g., 'let me back up a second') when answering complex questions about mixtures vs. contamination

Objections

1 objections (1 sustained, 0 overruled)
Proceeding 5983 • 109 utterances • Prosecution witness
Criminal Trial
Department 103
⚖️ Start
📂 MAY 9, 1995 📄 Direct examination of Dr. Robi
MAY 9, 1995 KRT DvH TD