📄 Motion: MacDonell surrebuttal admissibility — Monday, September 18, 1995
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C:\DEPT103\CRIMINAL\1995\SEP\18\MOTION-MACDONELL-SURREBUTTAL-A.DOC
TRIAL
▲ Day 156 of 167

Motion: MacDonell surrebuttal admissibility

Date: Monday, September 18, 1995 • Utterances: 31
Defense counsel argued for the right to call Dr. Herbert MacDonell as a surrebuttal witness to testify about a glove-drying experiment showing that blood saturation — not weather conditions — could account for the 15% shrinkage observed in the Aris Isotoner gloves. Marcia Clark objected that MacDonell's blood-shrinkage experiment was irrelevant to Rubin's rebuttal testimony, which focused on weather conditions, calling the two topics 'apples and oranges.' Judge Ito overruled the objection and allowed MacDonell to testify, then ordered a recess so Clark could gather her materials.
1 THE COURT:

Indeed we do. All right. Mr. Cochran, assuming that the Prosecution rests their case at this point--and I've indicated to them that I'm going to allow them to conditionally rest because you have not concluded your Defense case. You know how that goes.

2 MR. COCHRAN:

I do, your Honor.

3 THE COURT:

Do you have any other witnesses you're prepared to present this afternoon?

4 MR. COCHRAN:

Yes. I would like to proceed right away and I would like the court's indulgence because some of the witnesses we can't get until tomorrow probably. So at this point, I'd like to call Dr. Herbert MacDonell. It might be better to characterize him as a surrebuttal witness, but we'd like to call him now. We'd like to proceed.

5 THE COURT:

This is as to what issue?

6 MR. NEUFELD:

Primarily as to the glove drying, glove shrinkage in light of the testimony of Mr. Rubin when he came back here in the rebuttal case.

7 THE COURT:

What are we going to get into? Are we going to get into the glove experiment?

8 MR. NEUFELD:

Glove experiment which you already passed on and authorized.

9 MS. CLARK:

May I be heard? Obviously, this has got to be part of the Defense surrebuttal, correct? I don't know what it relates to in terms of dr.--excuse me--Mr. Rubin's testimony. How is it relevant?

10 MR. NEUFELD:

Well, Mr. Rubin testified that when he looked at the gloves that Mr. Simpson was wearing initially in 1990 and wearing up until December of 1993 I believe, he testified that--in fact, I think he testified that the gloves appeared in the pictures to be somewhat bigger even in 1993 than they were in 1990. That in conjunction with his earlier testimony back in June of this year, leads to the clear inference that the substantial shrinkage that occurred, which he said was about 15 percent, was due from the blood being soaked and smeared on the gloves during the night that these two people were killed. It had been somewhat suggested before that that could have been the result of weather. But since we saw Mr. Simpson wearing these gloves in a number of pictures where it's raining on them, where it's snowing on them, where it's sleeting on them--

11 THE COURT:

I don't think we ever saw snow or sleet, but did see a lot of rain.

KEY QUOTE
12 MR. NEUFELD:

Okay. A lot of rain and very cold rain and discussion of hand warmers and the like. But nonetheless, the gloves were at least as large at the end of `93 as they were in December of 1990, and the inference unmistakenly the Prosecution will be arguing is that 15 percent shrinkage occurred as a result of the event of June 12th, 1994. And so he will be testifying to his glove drying experiment which deals with substantial quantities of blood being smeared on the gloves to show that that's just not right.

13 THE COURT:

My recollection is--did we have a videotape of this or was it still photos?

14 MR. NEUFELD:

No. It was still photos and which were given to the People and given to the court. We had a hearing on the admissibility of this evidence and you ruled that it was admissible.

15 THE COURT:

All right. Miss Clark, who was the--was it Mr. Goldberg who was handling this?

16 MR. NEUFELD:

Miss Clark.

17 THE COURT:

Miss Clark.

18 MS. CLARK:

I thought--okay. It was my recollection Mr. Rubin's testimony, your Honor, that he testified it was a combination of the weather conditions to which gloves would be subjected as well as perhaps the introduction of the blood with the freezing and the drying and the unfreezing, et cetera. But the issue is really not shrinkage as much as it is stretchability, and I don't think that anything Mr. Rubin testified to in the People's rebuttal case opens up that issue for Mr. MacDonell.

19 THE COURT:

We did discuss, however, the issue of shrinkage during the course of Mr. Rubin's third appearance as a witness and we discussed it in terms of the weather conditions, in terms of rain and in terms of the heat generated by hand warmers if such were the case. So we did discuss the shrinkage during the course of--and if you recollect, the argument was that the Defense also withheld for tactical reasons presenting Dr. MacDonell on this shrinkage experiment so as to hope to preclude Mr. Rubin from coming back and testifying again with--

20 MS. CLARK:

If that was their reason, I don't think it has--

21 THE COURT:

I understand, but I'm just putting our discussions back into context.

22 MS. CLARK:

And I understand that. But--and the court's characterization of course with respect to Mr. Rubin's testimony and it being subject to weather conditions, but it had nothing to do with shrinkage caused by the introduction of blood on the gloves, and that's the subject matter of the glove drying experiment that Mr. MacDonell performed. So it's not relevant surrebuttal because we are talking apples and oranges. Mr. Rubin talked about the weather conditions to which the gloves were subjected. Mr. MacDonell is supposed to talk about what happened to the gloves as a result of blood, and that's two different things.

23 THE COURT:

But I think the point though that Mr. Neufeld is trying to make is that soaking in blood can account for the amount of shrinkage that we see here and that if it fits Mr. Simpson apparently as it does in the videotapes as well as it does, then it may not be the same pair of gloves now since the one that we have here in evidence, there appears to be shrinkage by 15 percent I think. I think that is the inference they're trying to draw here.

24 MS. CLARK:

It is. But is it a fair inference and is it fair in terms of surrebuttal in view of what we introduced in our rebuttal case? It's not the same thing. If you talk about subjecting it to weather conditions, you might let Mr. MacDonell testify he's a glove expert and he knows what the fat liquor and all the other aspects of leather is going to do when they're subjected to weather conditions, but it certainly has nothing to do with introduction of blood. I mean, we are talking apples and oranges here. So I don't see the relevance here in addition to what kind of gloves did he test.

25 THE COURT:

All right. My recollection though is that he did the glove experiment on one of the gloves that were from--

26 MR. NEUFELD:

He did the experiment on the glove that Mr. Rubin provided, which are the Aris Isotoner lights, the same exact pair of gloves that Mr. Darden used for his second glove demonstration with new gloves.

KEY QUOTE
27 THE COURT:

All right. I am going to overrule the objection. Miss Clark, do you have your materials?

28 MS. CLARK:

No, I don't.

29 THE COURT:

Why don't we take a recess then until 2:00 o'clock. Get your materials and then we'll reconvene. I'll allow you to rest conditionally in front--rest the People's rebuttal case subject to application should it become necessary to reopen and proceed. Then we'll proceed.

30 MR. NEUFELD:

I just want you to also know in light of--I've also had Professor MacDonell listen to Mr. Bodziak's testimony, and he may also be rebutting certain things he just heard Mr. Bodziak say this morning. I'm talking to him this moment about those things.

31 THE COURT:

Before we launch into that, we'll have a hearing outside of the jury--outside the presence of the jury to see where we're going on that.

Temperature

tense

Key Quotes (4)

Marcia Clark
Mr. Rubin talked about the weather conditions to which the gloves were subjected. Mr. MacDonell is supposed to talk about what happened to the gloves as a result of blood, and that's two different things.
Clark's core argument for exclusion — that the surrebuttal subject matter doesn't match what was opened on rebuttal.
Peter Neufeld
He did the experiment on the glove that Mr. Rubin provided, which are the Aris Isotoner lights, the same exact pair of gloves that Mr. Darden used for his second glove demonstration with new gloves.
Establishes the chain of the gloves used in MacDonell's experiment, tying the test directly to the prosecution's own evidence.
Lance A. Ito
I don't think we ever saw snow or sleet, but did see a lot of rain.
Rare moment of levity from the bench, gently correcting Neufeld's rhetorical flourish mid-argument.
Peter Neufeld
I've also had Professor MacDonell listen to Mr. Bodziak's testimony, and he may also be rebutting certain things he just heard Mr. Bodziak say this morning.
Signals the Defense is expanding MacDonell's surrebuttal scope beyond gloves, prompting Ito to order a separate admissibility hearing.

Evidence (3)

Informal
Aris Isotoner Light gloves used in MacDonell's glove-drying/blood-shrinkage experiment
discussed as basis for surrebuttal testimony
Informal
Still photographs of OJ Simpson wearing the gloves from 1990 through December 1993
discussed to establish glove size over time and undermine weather-shrinkage theory
Informal
Previously ruled-admissible glove experiment photos/results (Ito had already passed on admissibility)
referenced as prior ruling supporting MacDonell's testimony

Notable Exchanges (2)

Peter NeufeldMarcia ClarkLance A. Ito
Neufeld argued that Rubin's rebuttal testimony — that gloves appeared as large in 1993 as in 1990, implying 15% shrinkage occurred on June 12, 1994 — opened the door for MacDonell's blood-drying experiment. Clark countered that weather conditions and blood introduction are categorically different topics. Ito sided with the Defense, articulating the inference the jury was meant to draw.
strategic
Lance A. ItoPeter Neufeld
After the glove ruling, Neufeld disclosed that MacDonell had been listening to Bodziak's morning testimony and might rebut it. Ito immediately pumped the brakes, ordering a separate hearing outside the jury's presence before allowing that expansion.
procedural

Light Moments (1)

Lance A. Ito
Neufeld claimed Simpson was photographed wearing gloves in rain, snow, and sleet; Ito dryly corrected: 'I don't think we ever saw snow or sleet, but did see a lot of rain.'

Objections

1 objections (0 sustained, 1 overruled)
Proceeding 7734 • 31 utterances
Criminal Trial
Department 103
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📂 SEP 18, 1995 📄 Motion: MacDonell surrebuttal
SEP 18, 1995 KRT DvH TD