📄 Cross-examination of Gary Sims (part 2) — Wednesday, September 13, 1995
Address:
C:\DEPT103\CRIMINAL\1995\SEP\13\CROSS-EXAMINATION-OF-GARY-SIMS.DOC
TRIAL
▲ Day 153 of 167

Cross-examination of Gary Sims (part 2)

Witness: Gary Sims
Examiner: Barry Scheck
Called by: Prosecution • Date: Wednesday, September 13, 1995 • Utterances: 45
Barry Scheck wraps up his cross-examination of Gary Sims by methodically establishing that the RFLP results Harmon highlighted on direct examination were narrow in scope — covering only samples 303, 304, and 305 — and did nothing to address Dr. Gerdes' contamination concerns about Collin Yamauchi's handling of the Rockingham glove. Scheck also established that Sims never reviewed Gerdes' contamination study of the LAPD lab.
1 THE COURT:

All right. Thank you, counsel. Proceed.

2 MR. SCHECK:

Now, Mr. Harmon asked you some questions on direct examination about these RFLP results allaying concerns that dr. Gerdes expressed with respect to cross contamination. Do you recall that?

3 MR. SIMS:

Yes.

4 MR. SCHECK:

He asked you that question very generally, didn't he?

5 MR. SIMS:

Yes.

6 MR. SCHECK:

Now, these RFLP results only deal with samples 303, 304 and 305?

7 MR. SIMS:

That's correct.

8 MR. SCHECK:

These RFLP results do not address any issues of cross-contamination with respect to the Bundy blood drops, 47, 48, 49, 50 and 52?

9 MR. HARMON:

Objection. That is vague, your Honor.

10 THE COURT:

Overruled.

11 MR. SIMS:

No, these results relate to these samples.

12 MR. SCHECK:

All right. They don't relate to any problems of cross-contamination that occurred in the evidence processing room on June 14th when Collin Yamauchi examined the Rockingham glove?

13 MR. HARMON:

Objection, it is beyond the scope.

14 THE COURT:

Overruled. You can generalize this.

15 MR. SCHECK:

I only have two or three more questions, just to show what it doesn't concern.

16 MR. HARMON:

It also misstates the testimony.

17 THE COURT:

Overruled.

18 MR. SIMS:

The question again, please?

19 MR. SCHECK:

The question is these RFLP results don't do anything--don't address the issues of cross-contamination that have been raised by dr. Gerdes concerning Collin Yamauchi's handling of the Rockingham glove in the evidence processing room on the morning of June 14th, right?

20 MR. SIMS:

I'm trying to recall what issues dr. Gerdes specifically raised about those, because I don't recall seeing any issue with those particular samples.

21 MR. SCHECK:

Well, you don't recall his testimony about that? Is that what you are telling us?

22 MR. SIMS:

I don't recall the detail of his testimony about those particular samples.

23 MR. SCHECK:

You don't recall his testimony about Mr. Yamauchi--

24 THE COURT:

Counsel, counsel.

25 MR. SCHECK:

All right.

26 MR. SCHECK:

You don't recall it? Is that your testimony?

27 MR. SIMS:

I said I don't recall all the details. When you start talking about issues, you are putting a plural on it and you are implying there is some--

28 MR. SCHECK:

Mr. Sims, even if you don't recall all the details of what dr. Gerdes said, you don't believe that these RFLP results on 303, 304 and 305 have anything to do with it?

29 MR. HARMON:

Objection, that is argumentative.

30 THE COURT:

It is.

31 MR. SCHECK:

Do you believe they have anything to do with it?

32 MR. SIMS:

Well--

33 MR. SCHECK:

Do they address those concerns about cross-contamination?

34 MR. SIMS:

I think in the narrow sense of your question, no, the answer is no, they don't address that.

KEY QUOTE
35 MR. SCHECK:

Thank you.

36 MR. SCHECK:

Now, dr. Gerdes gave extensive testimony concerning a study he performed of contamination at the LAPD laboratory and the efficacy of controls in sample handling procedures used at the LAPD laboratory. Are you familiar with the fact that he testified about such a study?

37 MR. HARMON:

Objection. Beyond the scope of direct examination.

38 THE COURT:

Overruled.

39 MR. SCHECK:

My question last on this question.

40 MR. SIMS:

Yes, I am aware that he presented that.

41 MR. SCHECK:

You didn't review that, read that study or review his data, did you?

KEY QUOTE
42 MR. SIMS:

No, I did not.

43 MR. SCHECK:

Now--your Honor, I actually think I'm finished.

44 (Discussion held off the record between Defense counsel.)
45 MR. SCHECK:

Your Honor, I have no further questions, but I would request, based on what we've discussed, that this witness be subject to recall on another matter.

Temperature

tense

Key Quotes (3)

Gary Sims
I think in the narrow sense of your question, no, the answer is no, they don't address that.
The key concession Scheck was driving toward — the RFLP results touted on direct do not address the contamination issues raised by Gerdes about the Rockingham glove processing.
Gary Sims
When you start talking about issues, you are putting a plural on it and you are implying there is some--
Sims attempts to resist the framing before being cut off — reveals the witness parsing language to avoid the concession Scheck is extracting.
Barry Scheck
You didn't review that, read that study or review his data, did you?
Establishes that Sims cannot rebut Gerdes' contamination study because he never examined it — undermining any implicit suggestion that Sims could vouch for the LAPD lab's practices.

Evidence (4)

Informal
RFLP results for samples 303, 304, and 305
discussed — scope limited to these three samples only
Informal
Bundy blood drops samples 47, 48, 49, 50, and 52
referenced to establish RFLP results do not address contamination of these samples
Informal
Rockingham glove and evidence processing room handling by Collin Yamauchi on June 14th
referenced to establish RFLP results do not address contamination concerns from that event
Informal
Dr. Gerdes' contamination study of the LAPD laboratory
referenced — Sims confirmed he never reviewed it

Notable Exchanges (2)

Barry ScheckGary Sims
Scheck methodically narrows the scope of the RFLP results, getting Sims to concede they don't address any of the specific contamination concerns Gerdes raised — Sims first tries to resist by claiming he doesn't recall Gerdes' specific testimony, then attempts to parse the word 'issues,' before finally conceding the point.
strategic
Barry ScheckRockne HarmonLance A. Ito
Harmon objected five times in rapid succession during a short cross — vagueness, beyond scope, misstatement, argumentative — with Ito overruling four of them. The lone sustain was on 'argumentative,' but Scheck immediately rephrased and got the same answer.
adversarial

Credibility Attacks (2)

⚔ Gary Sims
exposing limited scope of knowledge
Scheck established that Sims never reviewed Dr. Gerdes' contamination study, undermining any implicit authority Sims might have to vouch for the LAPD lab's procedures or to rebut Gerdes' findings.
⚔ Prosecution's use of RFLP results
scope limitation
Scheck used Sims as the vehicle to establish that Harmon's framing on direct — that RFLP results 'allayed concerns' about contamination — was misleading, since those results only covered three samples and said nothing about Yamauchi's glove-handling or the Bundy blood drops.

Witness Demeanor

Sims hedges repeatedly before conceding — 'I'm trying to recall,' 'I don't recall the detail,' attempts to challenge Scheck's framing mid-answer before being cut off by the judge
Brief off-record discussion between defense counsel before Scheck announces he has no further questions

Objections

5 objections (1 sustained, 4 overruled)
Proceeding 7657 • 45 utterances • Prosecution witness
Criminal Trial
Department 103
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📂 SEP 13, 1995 📄 Cross-examination of Gary Sims
SEP 13, 1995 KRT DvH TD