📄 Recross-examination of William Bodziak — Monday, September 18, 1995
Address:
C:\DEPT103\CRIMINAL\1995\SEP\18\RECROSS-EXAMINATION-OF-WILLIAM.DOC
TRIAL
▲ Day 156 of 167

Recross-examination of William Bodziak

Witness: William Bodziak
Examiner: Barry Scheck
Called by: Prosecution • Date: Monday, September 18, 1995 • Utterances: 158
Barry Scheck recrosses FBI shoe print expert William Bodziak, targeting two main vulnerabilities in his testimony: first, that his opinion about parallel line imprints partly relied on what he did NOT see (a border), contradicting his redirect claim that he based opinions only on what he could see; second, and more significantly, that his entire conclusion about 'darker impressions' necessarily existing rests on the assumption that any perpetrator had to walk through Nicole Brown Simpson's blood pool — an assumption Scheck challenged with a multiple-perpetrator hypothetical where Goldman's killer left before Nicole's throat was cut. Scheck also pressed on the unidentified shoe print Dr. Lee found on June 25th, confirming no submitted officer shoes could account for it.
1 (The following proceedings were held in open court, in the presence of the jury:)
2 THE COURT:

All right. Thank you, ladies and gentlemen. Please be seated. And, Mr. Bodziak, would you resume the witness stand, please.

William Bodziak, the witness on the stand at the time of the lunch recess, resumed the stand and testified further as follows:

3 THE COURT:

All right. Good afternoon again, Mr. Bodziak.

4 MR. BODZIAK:

Good afternoon.

5 THE COURT:

All right. Miss Clark, have you concluded your redirect examination? Miss Clark.

6 MS. CLARK:

I'm sorry. Yes, your Honor.

7 THE COURT:

All right. Mr. Scheck.

8 MR. SCHECK:

Thank you, your Honor.

RECROSS-EXAMINATION BY MR. SCHECK

9 MR. SCHECK:

Good afternoon. Just a few questions, agent Bodziak. Miss Clark asked you on redirect examination about--she asked you can anyone examine what's obscured. Do you recall that?

10 MR. BODZIAK:

Yes.

11 MR. SCHECK:

And she asked you if you based your opinion about the parallel line imprints on what you could see and not on what you couldn't see.

12 MR. BODZIAK:

That's correct.

13 MR. SCHECK:

And you said yes.

14 MR. BODZIAK:

Yes.

15 MR. SCHECK:

Now, was not part of your opinion concerning the parallel line imprint evidence on the envelope and the piece of paper based on the fact that you did not see a border?

16 MR. BODZIAK:

That's one part of it, yes.

17 MR. SCHECK:

Well, that's something that you did not see, correct?

18 MR. BODZIAK:

The fact that I did not see it is the whole point, sir.

19 MR. SCHECK:

Well, you said just a second ago you based your opinion based on what you could see, not on what you can't see, didn't you?

20 MR. BODZIAK:

Absence of characteristics is the significance here.

KEY QUOTE
21 MR. SCHECK:

Now, would you not agree that there are bloodstain impressions over the parallel line imprint on the piece of paper?

22 MR. BODZIAK:

Yes, there are.

23 THE COURT:

And, Mr. Scheck, you're making reference to a particular exhibit that's before the jury?

24 MR. SCHECK:

1338.

25 THE COURT:

Right. Making reference to the upper left-hand photograph.

26 MR. SCHECK:

And there are also bloodstain impressions over the area of the parallel imprint on the envelope?

27 MR. BODZIAK:

Yes, I'm well aware of that.

28 MR. SCHECK:

And with respect to--now, you gave testimony or redirect testimony that you based your conclusion that the imprints on the jeans did not come from shoes based on the manner in which the imprints appeared on the shoes.

29 MR. BODZIAK:

I'm not sure--

30 MR. SCHECK:

On the jeans. I'm sorry.

31 MR. BODZIAK:

No. It's based on several things.

32 MR. SCHECK:

You don't recall that question on redirect?

33 MR. BODZIAK:

I don't recall the exact quote. My answer is, it is based on many things. If you ask me was it in part based on that, I would have said yes.

34 MR. SCHECK:

Okay. Now, you indicated on redirect examination that the use of the Identicator kit to make test impressions and to draw conclusions about imprints on the jeans from fabric was Agent Deedrick's area?

35 MR. BODZIAK:

With regard to the fabric impressions, yes.

36 MR. SCHECK:

And you would rely on his expertise in conducting that examination?

37 MR. BODZIAK:

He would do it independently. I wouldn't rely on it. I mean, he doesn't come back to me and report to me and that is the basis for my opinion. He does that independently and reports that independently.

38 MR. SCHECK:

But I think that Miss Clark's question to you on redirect examination, that's not your area, that's his area?

39 MR. BODZIAK:

That's correct.

40 MR. SCHECK:

And are you aware that Agent Deedrick testified that as far as he could remember, he had never done such an analysis before of bloody imprints on fabrics?

41 MS. CLARK:

Objection. That misstates the testimony.

42 THE COURT:

Sustained. Rephrase the question.

43 MR. SCHECK:

Are you aware of what Agent Deedrick said about the amount of experience he had in terms of doing analysis of bloody instruments in imprint fabric on fabric?

44 MS. CLARK:

Objection. Irrelevant.

45 THE COURT:

Overruled.

46 MR. BODZIAK:

I did hear that part of his testimony, yes.

47 MR. SCHECK:

Okay. Now, on redirect examination, you complemented the Los Angeles Police Department saying that they had done an excellent job photographing imprints at the crime scene.

48 MR. BODZIAK:

That's correct.

49 MR. SCHECK:

Because they made both color and black and white.

50 MR. BODZIAK:

And the manner in which they took them and the quality of the subsequent photographs that they developed.

51 MR. SCHECK:

But, agent Bodziak, in your book, you emphasized before beginning the crime scene search, careful thought should be given to what occurred at the crime scene, how footwear impression evidence could contribute to the proof of fact and what area of the crime scene might contain impression evidence, then footwear impressions should be looked for and aggressively and carefully, what is not looked for will not be found. Do you agree with that?

52 MS. CLARK:

Objection. Asked and answered.

53 THE COURT:

Overruled.

54 MR. SCHECK:

Do you agree with that?

55 MR. BODZIAK:

Absolutely.

56 MR. SCHECK:

Now, based on--have you reviewed the testimony of Dennis Fung, Andrea Mazzola, Detective Lange as to how the Bundy crime scene was processed?

57 MS. CLARK:

Objection. Beyond the scope.

58 THE COURT:

Overruled.

59 MR. BODZIAK:

I have some knowledge of that, yes.

60 MR. SCHECK:

Do you feel that you're in a position to say that they did an excellent job in giving thought before they began the crime scene search to what could have occurred and how footprint impression evidence could contribute to the proof of fact and aggressively searching out footwear impressions?

61 MR. BODZIAK:

Yes. They knew what the crime was. It was quite obvious. They could see bloody shoeprints leading from an area which was totally, almost totally covered in blood. They, as far as I remember from their testimonies, looked for other evidence of shoe marks and they did their best to preserve it and they ordered that it be photographed and recorded it, which it was. As to anything else that went through their minds that they didn't state, I wouldn't be able to testify to that. But from what I've heard, that's exactly what they did. They made a point of looking for footwear impressions. There were those that were obvious, and they also looked all the way down the walkway, documented them all the way to the end in the back of the residence and photographed everything that they could see.

62 MR. SCHECK:

Agent Bodziak, in terms of--you didn't read their transcript, right?

63 MR. BODZIAK:

I haven't read anybody's transcripts.

64 MR. SCHECK:

And what percentage of the testimony of Fung or Mazzola or Detective Lange with respect to how they sought out and examined footwear impressions do you think you heard?

65 MS. CLARK:

Objection. Argumentative.

66 THE COURT:

Sustained.

67 MR. SCHECK:

How much--what percentage of their testimony do you think you heard?

68 MS. CLARK:

Objection. Argumentative.

69 THE COURT:

Sustained.

70 MR. SCHECK:

How much of their testimony did you hear?

71 MS. CLARK:

Objection. Argumentative.

72 THE COURT:

Let's not get into this.

73 MR. SCHECK:

Do you feel comfortable based on your knowledge of what occurred at this crime scene that you can tell this jury that they did an excellent job in aggressively seeking out latent and/or nearly invisible footwear impressions at the Bundy crime scene? Do you feel comfortable with that?

74 MS. CLARK:

Objection, your Honor. That's argumentative.

75 THE COURT:

Overruled. Overruled.

76 MS. CLARK:

Nearly invisible.

77 THE COURT:

Overruled.

78 MR. BODZIAK:

Of course, Mr. Scheck, if there were any invisible imprints at the scene, certainly they could have missed them. The point is, they would not be invisible if they were in blood. You wouldn't have footwear impression--for instance, the one with parallel lines on tile 10 that was in blood 10 tiles down, there would be no other parallel line footwear impression before it. It's impossible unless the person that committed the crime can fly and there is no way for them to have walked through that blood and not leave other impressions, and with the tiles that they photographed with the general scene photographs, there's no evidence of any other footwear impressions.

79 MR. SCHECK:

Agent Bodziak, you say "Walked through the blood," right?

80 MR. BODZIAK:

That's correct.

81 MR. SCHECK:

You are referring to the pool of blood that was on the walkway that appeared to have come from Nicole Brown Simpson?

82 MR. BODZIAK:

Yes.

83 MR. SCHECK:

In fact, when you were asked questions on redirect examination about whether or not there could be other imprints from shoes, you said no because they would have left dark impressions. Do you recall that on redirect?

84 MR. BODZIAK:

Would have left darker blood impressions, yes.

85 MR. SCHECK:

Darker blood impressions, right?

86 MR. BODZIAK:

Yes.

87 MR. SCHECK:

And that again is based on the assumption that somebody would have to have walked through the crime scene, stepping through the pool of blood on the walkway that was left by Nicole Brown Simpson?

88 MR. BODZIAK:

That's correct.

89 MR. SCHECK:

And that is based further on the assumption, sir, that somebody who was involved or person or persons involved in this crime would necessarily have had to have walked through that pool of blood?

90 MR. BODZIAK:

If they were at the scene of the murder, since I have been to the scene and I believe everyone else has, it's so small, so confined in line with the fact that people do not consciously think of what they're walking in on an every-day basis, much less under that kind of a stressful situation, they would not have been able to be at that scene involved in the murder without walking through that blood and leaving evidence of it.

91 MR. SCHECK:

Agent Bodziak, I ask you to assume that a struggle occurred with more than one perpetrator with Ronald Goldman and that one or more of those perpetrators left the scene before Nicole Brown Simpson's throat was cut, causing that pool of blood on the walkway. Do you have that in mind?

92 MS. CLARK:

Objection. Objection, your Honor. That's an improper hypothetical. Assumes facts not in evidence.

93 THE COURT:

Overruled.

94 MR. SCHECK:

Do you have that in mind?

95 MR. BODZIAK:

Are you asking me to isolate that thought for a moment?

96 MR. SCHECK:

I'm asking you to keep that thought in mind.

97 MR. BODZIAK:

I'll keep it in mind.

98 MS. CLARK:

Objection. Speculation.

99 THE COURT:

Overruled.

100 MR. SCHECK:

Now, if that occurred, one or more perpetrators could have left the crime scene without walking through that pool of blood?

101 MR. BODZIAK:

Are you suggesting there were two independent murders at the same place 10 minutes apart?

KEY QUOTE
102 MR. SCHECK:

Oh, is that necessary for this hypothetical?

103 MR. BODZIAK:

It seems to me that's what you're suggesting, that there was one person that might have murdered Ron Goldman and then left the scene and then along comes somebody else and murders Nicole Brown two feet away. That's the way I understand it.

104 MR. SCHECK:

Agent Bodziak, I'm only asking you to make this assumption, that the murder of Ron Goldman occurs and then as among the last things done at the crime scene, the throat of Nicole Brown Simpson is cut causing the pool of blood in the walkway. Can you keep that in mind?

105 MR. BODZIAK:

I can keep it in mind, yes.

106 MR. SCHECK:

Did you hear eight days of testimony from Dr. Lakshmanan which included that hypothetical?

107 MS. CLARK:

Objection. That misstates the testimony.

108 THE COURT:

Sustained.

109 MR. SCHECK:

Now, if this were to occur, could a perpetrator or perpetrators have left the crime scene without walking through that pool of blood?

110 MR. BODZIAK:

In this case, I don't believe that's what happened. But if you're to suggest that I consider it under your hypothetical where there was one murder and later another one, I suppose that it could, but I don't believe that's what happened.

111 MR. SCHECK:

You don't believe that's what happened?

112 MR. BODZIAK:

No, sir.

113 MR. SCHECK:

You weren't there, were you?

114 MS. CLARK:

Objection.

115 THE COURT:

Sustained. Rephrase the question.

116 MR. SCHECK:

The imprint evidence, the bloodstain imprint evidence that Dr. Lee discussed, that whole board, you don't recall that testimony?

117 MS. CLARK:

Objection. Vague.

118 THE COURT:

Sustained.

119 MR. SCHECK:

Do you remember an analysis of the order of deposits on the envelope that Dr. Lee made in his testimony?

120 MR. BODZIAK:

I previously testified that I did not see that part.

121 MR. SCHECK:

All right. Well, would it not be consistent with the hypothetical I posed to you, that there were a set of imprints made at the crime scene that were partial based on less blood flow, somewhat less blood flow than the pool of blood?

122 MR. BODZIAK:

I don't think that the sequence--the fact that there were--there may be an imprint and then later blood would flow on the envelope or may get moved and acquire other blood in one manner or another would have nothing to do with my exam of the imprint.

123 MR. SCHECK:

But wouldn't it be a fair statement that your answers to my questions here and your statement on redirect examination that if there were other imprints from shoes, bloody imprints from shoes, that the impressions would have to be dark is based on your assumption that the perpetrator or perpetrators of this crime would of necessity have to have walked through the pool of blood on the walkway?

124 MR. BODZIAK:

It's based on my visit twice to the crime scene, my view of volumes of notebooks of photographs of the crime scene, my examination of the quantity of blood on the walkway, the distance that a person would have to jump if they for some reason were conscious of footwear impressions, which they're not, and all of the other factors. In looking at crime scenes over the years, with that kind of scenario and that kind of confined area, a person that was in that area would leave bloody shoe impressions. They would be first dark and then get lighter as they walked away.

125 MR. SCHECK:

Well, all of what you've just said is based on the assumption that somebody would have to walk through the pool of blood caused by the severing of the neck of Nicole Brown Simpson, right?

KEY QUOTE
126 MS. CLARK:

Objection. Asked and answered.

127 THE COURT:

Overruled.

128 MR. BODZIAK:

Of course it would. Yes.

129 MR. SCHECK:

All right. Now, you were asked on redirect examination about the parallel line shoeprint impression that Dr. Lee identified as a shoeprint which he found on June 25th.

130 MR. BODZIAK:

Is that the one on the 10th tile I believe?

131 MR. SCHECK:

Yes.

132 MR. BODZIAK:

Yes.

133 MR. SCHECK:

Now, could we play 1011?

134 MS. CLARK:

Can I see what counsel is proposing?

135 MR. SCHECK:

Do you recall--I'll preface it this way. As part of the examination of Dr. Lee that you saw, do you recall a time when Mr. Goldberg played a tape of two police officers breaking down the Bundy crime scene?

136 MR. BODZIAK:

Yes, I recall seeing that.

137 MR. SCHECK:

All right. Could I play that?

138 THE COURT:

Yes. Which exhibit is this, Mr. Harris?

139 MS. CLARK:

Your Honor, this is beyond the scope.

140 THE COURT:

Overruled.

141 MR. SCHECK:

I think that it's 127.

142 (At 1:26 P.M., people's exhibit 127, a videotape, was played.)
143 MR. SCHECK:

There's more? Okay.

144 (At 1:27 P.M., the playing of the videotape was concluded.)
145 MR. SCHECK:

Now, agent Bodziak, you collected the shoes of officers that were present at the crime scene?

146 MR. BODZIAK:

There were photographs of some of the officers sent to me to view with regard to what design shoes they had on.

147 MR. SCHECK:

And this thing also included the photographer, Mr. Rokahr?

148 MR. BODZIAK:

I believe so. It's been a while. I'd have to go back and look at the officers' names.

149 MR. SCHECK:

And would it be your testimony that none of the shoes that you were given of people that were involved in the crime scene would match the parallel line imprint impressions of the shoeprint Dr. Lee identified on June 25th?

150 MR. BODZIAK:

No. That's correct.

151 MR. SCHECK:

Have you been shown by the prosecutors a videotape of the inside of the Bundy residence where candles are lit?

152 MR. BODZIAK:

I--not by the prosecutors. I think I saw something like that on the news one time.

153 MR. SCHECK:

Have you been provided any other shoeprints from other people that might have been at the crime scene on June 13th for comparison to the imprints that dr.--the imprint that Dr. Lee identified as a shoeprint on June 25th?

154 MR. BODZIAK:

None other than those of the officers that were submitted to me.

155 MR. SCHECK:

And it's your testimony that they could not have accounted for those imprint--that imprint?

156 MR. BODZIAK:

That is correct.

157 MR. SCHECK:

I have nothing further.

158 THE COURT:

Miss Clark.

Temperature

tense

Key Quotes (4)

William Bodziak
Absence of characteristics is the significance here.
Bodziak is forced to acknowledge that his conclusion about the parallel line imprint partly depended on what he did NOT see — directly contradicting his redirect testimony that he based his opinion on what he could see, not what he couldn't.
William Bodziak
Are you suggesting there were two independent murders at the same place 10 minutes apart?
Bodziak resists Scheck's hypothetical about sequential perpetrators, revealing his own interpretive assumptions about the crime — a witness volunteering a theory he wasn't asked to give.
William Bodziak
It's so small, so confined in line with the fact that people do not consciously think of what they're walking in on an every-day basis, much less under that kind of a stressful situation, they would not have been able to be at that scene involved in the murder without walking through that blood and leaving evidence of it.
Bodziak's core argument — but Scheck has established it is entirely predicated on the assumption that Nicole's blood pool was present when all perpetrators were still at the scene.
Barry Scheck
Well, all of what you've just said is based on the assumption that somebody would have to walk through the pool of blood caused by the severing of the neck of Nicole Brown Simpson, right?
The culminating point of Scheck's recross — pinning down that the 'no other shoe impressions' conclusion depends entirely on an unproven sequencing assumption about the murders.

Evidence (3)

People's 1338
Photographs showing parallel line imprints on envelope and piece of paper, with bloodstain impressions overlaid
discussed
People's 127
Videotape of two police officers breaking down the Bundy crime scene
played in court (approx. 1 minute)
Informal
Photographs of officers' shoes submitted to Bodziak for comparison to the parallel line imprint Dr. Lee identified on tile 10 on June 25th
discussed — none matched the imprint

Notable Exchanges (3)

Barry ScheckWilliam Bodziak
Scheck caught Bodziak in a logical contradiction: on redirect Bodziak said he based his opinion on what he could see, but Scheck showed that the absence of a border — something he did NOT see — was central to his conclusion. Bodziak's response ('Absence of characteristics is the significance here') was substantively defensible but exposed as inconsistent with his own prior framing.
strategic
Barry ScheckWilliam Bodziak
Scheck posed a hypothetical that Goldman was killed first and one or more perpetrators left before Nicole's throat was cut (creating the blood pool), arguing someone could have left without walking through Nicole's blood. Bodziak resisted, mischaracterizing the hypothetical as requiring two separate murders, until Scheck clarified — then Bodziak conceded it was theoretically possible but said he didn't believe it happened.
revealing
Barry ScheckWilliam Bodziak
Scheck confirmed that the unidentified parallel line shoe print Dr. Lee identified on tile 10 on June 25th could not be matched to any officer shoe submitted for comparison, and that Bodziak had not been given shoes of any other individuals who might have been at the scene.
strategic

Credibility Attacks (3)

⚔ William Bodziak
prior inconsistent statement
Scheck showed that Bodziak's redirect claim — that his opinion was based on what he could see, not what he couldn't — was contradicted by his own admission that the absence of a border was a key part of his analysis.
⚔ LAPD crime scene team (Fung, Mazzola, Lange)
impeachment by omission / lack of foundation
Scheck challenged Bodziak's redirect praise of LAPD's 'excellent job' by pressing on how little of their testimony Bodziak had actually heard and whether he was qualified to vouch for their footwear impression search methodology.
⚔ William Bodziak
assumption challenge
Scheck methodically established that Bodziak's entire conclusion — that no other shoe impressions could exist because they would have been dark with blood — rested on the unproven assumption that all perpetrators necessarily walked through Nicole's blood pool, which is itself contingent on the sequencing of the murders.

Objections

15 objections (7 sustained, 8 overruled)
Proceeding 7714 • 158 utterances • Prosecution witness
Criminal Trial
Department 103
⚖️ Start
📂 SEP 18, 1995 📄 Recross-examination of William
SEP 18, 1995 KRT DvH TD