📄 Sidebar: closing argument objections — Friday, September 29, 1995
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C:\DEPT103\CRIMINAL\1995\SEP\29\SIDEBAR-CLOSING-ARGUMENT-OBJEC.DOC
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▲ Day 164 of 167

Sidebar: closing argument objections

Date: Friday, September 29, 1995 • Utterances: 49
During Marcia Clark's closing argument, Barry Scheck brings a series of objections to the bench, arguing Clark misrepresented the DNA and serology results for item 42 (a swatch from the blood pool under Nicole Brown Simpson's body), mischaracterized testimony about PCR testing on Egyptian mummies, and made a false claim that defense requests for DNA exemplars from police officers would have been honored. Judge Ito largely declines to intervene, telling counsel the jury has been admonished that arguments not matching their recollection are made 'at their peril.' The sidebar ends inconclusively with a recess.
1 (The following proceedings were held at the bench:)
2 THE COURT:

Mr. Scheck.

3 MR. SCHECK:

Your Honor, I have a number of objections. The first one is that Miss Clark was making argument about there being no--that you should have--item 42, there should have been DNA result--kept on referring to as DNA results as showing the blood of Nicole Brown Simpson being taken from the samples. She was making this argument and she is indicating that--her argument was that the swatches and bindle 42 showed that it was the blood of Nicole Brown Simpson. Now, what's misleading and without--devoid of any factual support in the record, highly misleading is that there are no conventional serology results and no DNA test results on those swatches. So it's improper argument. There's no factual foundation at all in the record for that and it's highly misleading. That's no. 1. No. 2, she made an argument that the PCR testing here can detect DNA from Egyptian mummies.

4 THE COURT:

That's not what she said. There was testimony that PCR has been used to type Egyptian mummies.

5 MR. SCHECK:

Therefore, you should be able to find DNA from degraded samples here. It seems to me, your Honor, this is highly misleading and argument that is without support in the record, the DNA typing for Egyptian mummies.

6 THE COURT:

You've made the point. Let's--

7 MR. SCHECK:

Well, that's wrong. No. 3, she misquoted--misled the jury with respect to the testimony of Dr. Baden about blood searches being planned, an excerpt that she read with respect to the testimony of Dr. Baden. She did not tell the jury and she misled them because they were--made statements about his own records, not their records on June 22nd where they talked about--

8 THE COURT:

What's misleading going off his notes?

9 MR. SCHECK:

She did not mention June--she contemplated it as though discussion about the June 29th blood search when this was taking place on June 22nd. That was wrong and highly misleading. She gave a page number. I may get it wrong. I may have to go back--40098 with respect to Dr. Gerdes talking about conventional serology.

10 THE COURT:

As being a confirmation.

11 MR. SCHECK:

Confirming. I can't find that in that citation.

12 MS. CLARK:

I'll read it for the jury--for counsel.

13 MR. SCHECK:

I just want to know--

14 MS. CLARK:

I checked everything.

15 MR. SCHECK:

I may have misheard your page reference. Just give me that. The page reference I wrote down I don't see as relating to what she said. But definitely, the one statement that she made that is completely improper--and perhaps she doesn't know it, but the court should think back--and that is around the time that we withdrew the DNA motion, we had in writing and on the record made a request for exemplars, DNA exemplars from the officers in the case. We asked for that. If you recall, what they agreed to do was give us exemplars where DNA typing--I should say from the evidence collections, but they refused to give them to the police officers. You can check with Mr. Clarke and Mr. Harmon. You can go back and get the report. Please search your memory. We had specifically requested that. What she just told us--

16 THE COURT:

Hold on. Hold on. Stop there. Tell me about 42, the blood testing on 4--what testing was done on 42?

17 MS. CLARK:

The conventional serology. 42 is the one that gave us the EAP degraded also to a B, and I told--what I actually told the jury is, you know, it is her blood because it's under her body, pool of blood. That's what I said. And the--there was testimony concerning conventional serology done on that. I think there was--was there PCR on that? Also PCR in that. Collin did that. So there was a type on that.

18 MR. SCHECK:

Why don't we tell the results? On their board, they show conventional serology, just inconclusive typing results and the DNA typing by Mr. Yamauchi on sample 42 showed no results. Those are the facts in the record, not this nonsense that she's telling us now.

19 MS. CLARK:

What do you mean?

20 MR. SCHECK:

Well, because you are misstating the record.

21 THE COURT:

Wait, wait. Miss Clark.

22 MS. CLARK:

These are the most specious objections and counsel's inappropriate demeanor is something that I want to raise with the court separately when we conclude this. But I have not misrepresented anything to this jury. I have told this jury that it is her pool of blood that is underneath her body. And if there was contamination, you know, what counsel is saying doesn't disprove a thing. I said nothing--in fact, it proves it better because if it was totally degraded and no results was obtained, then it should have gotten the Defendant's type also. If, according to his testimony, contamination is correct, then that should have come up. Nothing I had said misled the jury.

KEY QUOTE
23 THE COURT:

How about the business about the request? My recollection is, that's true.

24 MS. CLARK:

I have no knowledge of that. You would not have opposed it. And Johnnie knows. He asked me to get the elimination standards for hair, and I went and I got the hair--

25 MR. COCHRAN:

That's right. She cannot--

26 MS. CLARK:

Let me check with rock. And rock don't trust anything he said.

27 MR. SCHECK:

Her specific statement was, a request for these samples would have been honored.

28 THE COURT:

What I want you to do is come back with, with regard to 42, the most we could say about the blood underneath her--and the results are posted on the results board, correct?

29 MR. SCHECK:

No.

30 MS. CLARK:

Yeah.

31 MR. SCHECK:

No, no. It's wrong. Now--

32 THE COURT:

Counsel, listen. You should understand I'm not going to go over--this has been a nine-month trial. If you want to go back through argument and fight over what the testimony was or wasn't when you have conflicting testimony about just about everything that went on in this case, we're not going to do that. The jury has been admonished that counsel can argue the facts in the case. And if they argue something that's not to the recollection of the jury, they do that at their peril. We're not going to go back and search through each and every item.

33 MR. SCHECK:

We're not asking you to do that. Please let me make my record.

34 MS. CLARK:

How many times--

35 THE COURT:

Counsel, don't interrupt counsel.

36 MR. SCHECK:

All I am asking the court to do--I think it's in accordance with proper procedure when statements are made without any factual foundation in the record, and frankly, I think if you look back at the argument here in a way that is totally misleading, there are no DNA results on sample no. 42.

37 THE COURT:

I don't recollect it.

38 MR. SCHECK:

Then who--please check the record. Please check the serology board.

39 THE COURT:

What item is that?

40 MR. SCHECK:

It shows no results.

41 THE COURT:

What item is that? Would you answer my question?

42 MR. SCHECK:

Item no. 42. I'm being very direct.

43 THE COURT:

What chart is that?

44 MR. SCHECK:

Conventional serology chart and then the--their own DNA testing shows no result.

45 MS. CLARK:

How is that--you know what I'm missing here is that I said that is obviously her blood because it's under her body, and if there was contamination, that blood that was collected should have shown his type as well. How have I misled them?

46 THE COURT:

Does that infer there was testing?

47 MS. CLARK:

There was testing.

48 MR. SCHECK:

No results on any of it show that and results which is--because there were no results. No result.

49 (Recess.)

Temperature

heated

Key Quotes (4)

Barry Scheck
On their board, they show conventional serology, just inconclusive typing results and the DNA typing by Mr. Yamauchi on sample 42 showed no results. Those are the facts in the record, not this nonsense that she's telling us now.
Scheck's sharpest factual challenge — directly accusing Clark of misrepresenting the evidence record to the jury on a key blood sample
Lance A. Ito
The jury has been admonished that counsel can argue the facts in the case. And if they argue something that's not to the recollection of the jury, they do that at their peril. We're not going to go back and search through each and every item.
Ito declines to police the accuracy of closing argument, effectively overruling most of Scheck's objections by deferring to the jury's memory
Marcia Clark
These are the most specious objections and counsel's inappropriate demeanor is something that I want to raise with the court separately when we conclude this.
Clark counter-attacks on Scheck's conduct rather than defending the substance, signaling how combative this sidebar became
Marcia Clark
If it was totally degraded and no results was obtained, then it should have gotten the Defendant's type also. If, according to his testimony, contamination is correct, then that should have come up. Nothing I had said misled the jury.
Clark's substantive defense — arguing that the absence of DNA results actually undermines the contamination theory rather than supporting it

Evidence (4)

Item 42
Blood swatch from the pool beneath Nicole Brown Simpson's body; conventional serology returned inconclusive/degraded results, PCR by Yamauchi returned no results
Disputed — Clark claims it confirms Nicole's blood, Scheck argues no results were obtained
Informal
Conventional serology results board and DNA results board referenced by both parties during argument
Disputed — parties disagree on what the posted results show
Informal
Dr. Baden testimony at page 40098 regarding blood searches on June 22 vs. June 29
Challenged — Scheck argues Clark conflated two different dates
Informal
Dr. Gerdes testimony on conventional serology as confirmation (page reference disputed)
Challenged — Scheck cannot locate the citation Clark used

Notable Exchanges (3)

Barry ScheckMarcia Clark
Scheck calls Clark's characterization of item 42 'nonsense'; Clark fires back that Scheck's objections are 'specious' and flags his 'inappropriate demeanor' for a separate complaint to the judge
heated
Lance A. ItoBarry Scheck
Ito repeatedly cuts Scheck off and refuses to audit the trial record item by item, telling him 'this has been a nine-month trial' and the jury decides what the evidence showed
tense
Marcia ClarkJohnnie Cochran
Clark invokes Cochran to corroborate her account of obtaining hair elimination standards, and Cochran briefly confirms ('That's right') before Clark cuts herself off
strategic

Credibility Attacks (2)

⚔ Marcia Clark
Misrepresentation of record
Scheck argues Clark told the jury item 42 showed Nicole's blood when in fact both conventional serology and PCR DNA testing returned no usable results, calling her characterization flatly wrong
⚔ Marcia Clark
Misquotation / date conflation
Scheck contends Clark misled the jury about Dr. Baden's testimony by attributing June 29 blood search statements to notes that actually dated from June 22

Objections

4 objections (0 sustained, 0 overruled)
Proceeding 7892 • 49 utterances
Criminal Trial
Department 103
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📂 SEP 29, 1995 📄 Sidebar: closing argument obje
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